Document LvKoDj66nLMqmMzB0g9p36ng

Cyprus Industrial Minerals Company S5S South Flower Str~t Los Angeles, California 90071 Telephone 213) ~9-3700 October 18, 1977 TWX 910) 321-5753 ,. To You, Our Customer ..... D.P,K. .0CT?_J 1977 We would like to take this opportunity to clarify some of the confusion which appears to be building in terms of talc and asbestos. A number of significant developments have recently occurred which tend to cloud the regulatory aspects of the problem. In May, 1977, OSHA published a booklet entitled "A Report on the Fiber Content of Eighty Industrial Talc Samples Obtained from, and Using the Procedures cf the Occupational Safety and Health Administration". You may have received a letter from one of your suppliers analyzing the data presented in this OSHA report. We feel that this analysis of the data was misleading in the manner in which it was offered. While we are of the opinion that the OSHA method of fiber analysis is not adequate to identify asbestos, OSHA does continue to employ this method. The conclusions drawn by the National Bureau of Standards in its discussion of the results states quite conclus ively that they also feel the OSI~ method is in dire need of review. We quote from the NDS report, Section V, Conclusions, P. 17, as follows: The variability of these results Paises several quastions regarding the OSHA proced11r-e, particularly sampling technique, sample homogeneity, and deter mining fiber morphology. It is the opinion of NBS that, even under favorable circumstances (e.g., homogeneous samples, easily identified fibers , etc. ), the existing OSHA procedure is useful only for determining 'fiber' content and not 'asbestos' content, Although capeful - manipulation of the mounting medium might make it pos-sible to i'd~ntify some of.the fibers as 'asbestos', the p1'oblem of fhe definition o'f 'asbestos' stil 1 remains. NBS believes that the resolution of the measurement problem, including the _definition and identification of asb-estos, w:i,il pe 'accomplished only by s.ignificant changes in th~ procedure Qn9 probdbly the i,ethod as well," L ' .. .. ., CAM-3~7J'9 013445678999  ToUowing tlcis ll."eport; a ',Jor>kshop on Asbestos" was held at the Na'tumal ~urea,u of Standards in Washington, July 18-20, 1977. U:.irt~ort:unate.ly, this wo!'k.shop did not reault in any cha.ng.e of test uet:hod but did serve to point out the extreaie ir..a.:!\~uacy of the procedure as it is presently constituted. We do no~ fee: w,e shouJ.d s~e.ax for the talc industry in genet'al, b~ '!'a.~be-r, rill revie-w our own situation as it presently rt~s. In titiE 1SRA report, 16 s amples were tested wh~~ ~~e ide~':ified as Cyprus Industrial Minerals Cc~a:-.:/ tal..:::. ~n,'! r-es:.;.l t:; cf the tests on these 16 samr.- lea ars s r:0 ;..n ::: ~ : -.:,-.; ; Hon tar_.a. :e x 2.s -::alif':)cd:: No .Fib er fiber Present 40 10 ~7 l0 As caP. De :!'-:e::. :---;.;ii ti:i.:s c.:te, both o..ir Hontana and Texas tal~s ar-e i.ndi::a~e~ tc be t".N::e of asbestiform material. Our CaJ. ifor-ni.a "t~:!:.."5 c,~ntai.n cllt'.!y very llUnute quantities of tremcli te i..~ some ~::,st,.a.nc~- ~e do state that they are free of as':i<:stif:-nt in:;,:1riti.es 1:0 t:'::'Je level of sensitivity as measured by Ji-!'ay Dlif::'~-:--:ii::-n !'!:-e:J!mii.~ues. This is approximat ely 0.1\ tc D: 3'\. !.i ,ce..--d.f ica+-- j ,rir. to zero asb<!S tiforru level is deemed nec~ssa-""')' t~ y::,a:.~ =-om~"::1y) ~nly our Montana talc based grades should be cu;,ec. . ) .. ,, 013445678999