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FILE NAME Talc TALC DATE 1978 or 1979 DOC TALC018 DOCUMENT DESCRIPTION Book Chapter - Impact of Govt Regs on the Mineral Producing and Consuming Industries pid 1978 or 1979 _~. . a ST a fa 2 Seer Se ete ee ee te ote eccrine gid controls have emoval from the rooms showers for construction mber trial data with name ilable for inspec- one year for im- for a periopderiod of 40 ichever longer sent to an outside my containers for with provisions ultants and their ultanlts ongrange closing lead > that with the new air 45 511 fewer as base for normal s will affected ms that current stay from the lead ay the arbitraary rbitrary 50 pingregulations ne solubility of lead alicates or lead frits 1 silicates and frits from 1976. Forty asteful or questionable Impact ofGGovernmentalovernmental Regulations on the Mineral Producing and Consuming Industries ALLAN M. HARVEY AND C. S. THOMPSON R. T. Vanderbilt Co. Inc. 31 Winfield St. Norwalk Conn 06855 Suppliers and users of mineral raw materials in the ceramics industries have been unjustly subjected to economically ruinousgovernment regulations as a result of gross errors in mineral definition The asbestos standard throughincorrect definition has already caused great economic hardship as will the planned silica and talc documents unless a strong unified stand is taken by the mineral industries Although a host of regulatory burdens have been heaped on the mineral industry over the last decade this paper will be limited to the impact of regulations concerning asbestos and proposed or impending regulations of a similar nature exposure limiting to a number of other mineral dusts Ironicallythe goveofrgnovmerenmnentt asbestos regulationis being felt more by the producing and using segments of the mineral industries than by those few operations in the U.S. in which asbestos fiber is actually being produced and consumed on a commercial scale For example Reserve Mining Company in Minnesota a producer oftaconite Fe ore for the steel industry after almost a decade of court battle with state and federal environmental authorities has been forced to design a zero effluent land disposal system for its taconite and control systems throughout all its operations with all the costly safeguards required for control of asbestos- containing wastes This happened despite extensive testimony by mineral experts that the material in question was not asbestos The Gouverneur Talc Company mining tremolitic tale in St. Lawrence County northern New York State has been waging a costly struggle with the U.S. Occupational Safety and Health Administration for almost eight years in an attempt to introduce into asbestos regulations appropriate and correct mineral definitions and methods of analysis amendments that would vindicate the com- pany from scientifically unsubstantiated accusations that its talc contained asbes- tos . The quarry and crushed stone industry has more recently come under fire as an asbestos producer Trace quantities of chrysotile discovered in some serpen- tine ore bodies such as the Rockville Quarry in Maryland have about the brought usual hysteria now commonly associated with the word asbestos resultingin of costly paving ovegrravel roads removal of crushedstone from playgrounds and bicycle trails and a number of other expensive operations of questionable value to the health of the people supposedly affected It is just a matter of time before the regulators get around to the rest of the mining operations and the industries using their products The Homestake Gold Mine in South Dakota the major U.S. gold producer has been studied by the National Institute for Occupational Safety and Health NIOSH the research arm 79 aL ARR ee NM te eee tee wR ee eens Nem cee nn cea Bae meee ae 2 ten enero of both OSHA and the Mine Safety and Health Administration NIOSH inves- sem tigators claim to have found asbestos in the form offibrous cummingtonite ter particles in mine atmospheres at Homestake and have attributed their finding of an excessive rate of lung cancer among the miners to this form of the mineral NIOSH continues to hold this position in spite ofa more recent independent study by C. McDonald et al in which an excessive canof ccaencrer was not found to exist among an even larger and more comprehensive cohort of Homestake workers In due time they will discover that amphibole minerals are common in Cu Ag and Zn bearing ores and in fact in almost all hard rock and many soft rock ore bodies Because of OSHA's simplistic definition of asbestos fibers these operations too will become suspect and be investigated and subjected to the intensive regulation specifically developed for the asbestos mining industry At the heart of the problems annoying the mineral industry is the federal government's definitioonf what is an asbestos fiber and the methods of detection and analysis they have adopted based on this definition Despite expert testimony from noted mineral scientists such as Zussman Hurlbut etc. the judge in the Reserve Mining trial chose to describe particles of cummingtonite ore in Reserve's taconite wastes as indistinguishable from amosite asbestos therefore hazardous and subject to the same regulations designed for containing materials Only a clear lack of provable health problems in the Duluth area of Minnesota saved the operation from being closed down until a land disposal system could be built and put into operation Similar government findings and subsequent regulations of mine wastes could conceivably take place in the vast Cu mining industries of the West which process ores containing similar amphibole varieties of minerals in appreciable - quantities If an asbestos fiber is any mineral particle of the amphibole group with a 3 aspect ratio then it is impossible to mine mill and process almost any mineral ore without producing government asbestos If the words mineral fiber are substituted for the word asbestos as was recently proposed by the former Mine Enforcement and Safety Administration now MSHA in an attempt to amend its asbestos regulations then we are faced with the impossible situation of the complete U.S. mineral industry's being subjected to the stringent and economically burdensome rules originally developed to take care of a serious and proved health hazard to the workplace and the fiber environment All crushers and grinders become fiber producers since even grinding ordinary beach sand produces these government fibers Many synthet- ic mineral fibers in ceramic applications could also fall into this category Fortunately time is on the side of the regulated and considerable progress has been made in the struggle to force the government into adopting appropriate years scientific definitions and analytical methods in the almost eight since the first geE asbestos standard was published in 1972 ee When OSHA'OsSHA's official analytical laboratory in Salt Lake City first analyzed a Farce sample of New York State tremolitic talc in 1974 a result of 50-60 fibrous ns eete tremolite was reported After considerable effort on the part of the talc producer RES to familiarize the laboratory with accepted methods of asbestos analysis the eR ema amount of asbestos found in the same talc dropped to 10 at ae metr Following a visit by the company's mineralogist to the Salt Lake City laboratory in 1976 at which time the standard methods ofdetection of minerals by Fev the petrographic microscope were demonstrated the asbestos content of the tale dropped to % Subsequent court challenges of the OSHA method of analyzing talc for asbestos resulted in a finding by the OSHA laboratory in 1978 of six asbestos par observed tre these numb counted are realm of tra which is no mineral con It is qu demonstrate the same co for asbestos not all regul techniques asbestos fib not gover Furthe the regulato silicates ha tonite atta ceramic ind is compose produce ek scrutiny Z discovery volcanic as identified a were prono three or fou crystal par OSHA realization with a pos proposed 1 serious eff Cristobalit the TLV I A talc developed tually OSH process w sible limit maintain i pure talc : I we mineral o employee no disagre point of c include al little or no continuing Re em er ee er tenet eter enn Cte 2 eNInS mug ye enneiee cone on : BE ee ee tee te er ee re Siaeammamnerenenes eT v a erne > om, nistration NIOSH inves- us cummingtonite stributed their finding ofan irm of the mineral NIOSH independent study by C. not found to exist among mestake workers herals are common in Cu ird rock and many rock : of asbestos fibers these ated and subjected to the asbestos asbestos mining industry ral industry is the federal d the methods of detection on dentists such as Zussman ose to describe particles of ststeses as indistinguishable ject the same regulations clear lack of provable dd the operation from being ilt and put into operation egulations of mine wastes dustries of the West which of minerals in appreciable the amphibole group with a process almost any mineral The word asbestos as was and Safety Administration gulations then we are faced mineral industry's being he rules originally developed i to the workplace and the iber producers since even ment fibers Many synthet- fall 1 and considerable progress ent into adopting appropriate host eight years since the first Salt Lake City first analyzed a a result of 50-60 fibrous i the part ofthe tale producer ds of asbestos analysis the to of detection of minerals by asbestos content of the talc : OSHA method of analyzing IA laboratory in 1978 of six asbestos particles per 1000 counted in a bulk sample of talc Anyone who has observed tremolitic talc particles under the microscope can readily conclude from of these numbers that the true asbestos content the talc if indeed the six particles | counted are asbestos particles and not cleavage fragments lies somewhere in the realm of trace or negligible on a weight basis And this particular type of talc which is not beneficiated to any significant degree has not changed in general mineral composition since it was first mined in 1948 It is quite possible that similar improvements in analytical technique will demonstrate that Reserve Mining's taconite wastes contain little or no asbestos and the same could apply to the Homestake ores But official government regulations for asbestos have not been changed significantly since they were promulgated and not all regulatory agency laboratories are necessarily following identical analysis techniques The nature of the technique alone coupled with the controversy over asbestos fiber definition still leaves the mineral industry uncertain as to whether or not government asbestos will be found in its ore or finished products Furthermore there is uncertainty over the next mineral or group of minerals the regulators will decide to pounce upon Since asbestos minerals are silicates all silicates have come under suspicion --zeolites tale kaolin pyrophyllite wollastonite attapulgite feldspars of which are used to some degree by the ceramic industry This is of particular concern since over 90 of the earth's crust is composed of silica and silicate minerals Any of these that can be construed to produce elongated fragments when processed may possibly come under special scrutiny Zeolites in particular have come under recent attack through the discovery of high mesothelioma incidence in two Turkish towns Local rocks and volcanic ash were searched for asbestos and when elongate mineral particles later identified as two varieties of zeolite were found the search ended and zeolites of were pronounced to be as dangerous as asbestos Extrapolations this type from three or four extremely rare forms of common minerals to cleavage fragments and crystal particulates of similar dimension are scientifically unacceptable OSHA has been promising a silica standard for years The holdup is OSHA's realization that the term silica covers a of diffedrifefen ret nt mineral forms each with a possibly distinct biological reactivity ranging from hazardous to inert A proposed PEL of 50 ...gcrystalline quartz air in the workplace could have a serious effect on the use of products containifrneeg silica in the ceramic industry industry Cristobalite or tridymite produced during the firing of ceramic bodies carry haloff the TLV levels of quartz A talc criteria document referring to talc free of quartz and asbestos is being developed by Stanford Research International under contract with NIOSH Even- tually OSHA will receive the document and institute a tale standard development process with publication possible in a year or two The proposed permissible limit of 1.5 ...g for talc is considered extremely low and certainly costly to maintain in the workplace Documentation to justify this low level for essentially pure talc is extremely limited and subject to question I would like to conclude by asserting that hazardous products whether mineral or organic chemicals should be controlled in the workplace so that employees enjoy the freedom from hazard they are entitled to On this point there is no disagreement between the regulators and those who are regulated Where the point of contention arises is the attempt by the regulator to use a broad brush to include all the maybe's the similar or associated materials for which they have little or no medical data but which they feel sure might be dangerous and the continuing efforts to reduce all dust exposures even remotely harmful to zero 81 of result of a lack of expertise in the subject to In addition contention arises as a NIOSH but they profess to be regulated There are no mineralogists in OSHA or asbestos fiber and how to know all about minerals especially hotwhetom dies fmianedeanto feel that he has no regard analyze for it Anyone who challenges for the safety and health of the worker the mineral industry millions upon Government regulation has alreadaylready cost use If and prices the products you millions of dollars reflected in higher ctohsatts these regulations specifically those we could see any concrete evidence in the nonasbestos mining industry associated with the control of alleged oafsbtehsetopseople exposed to mineral dusts we contributed to the safety and health with the regulators instead of could find it profitable and rewarding to cooperate always seeming to be at war against them eres Impact o on the R PATRICIA ( J. E. Baker 232 E. Mar The impleme potentially to to these regu performed a The impact it could not remarks are and will not of Transpor the Environ Administra MSHA To fur receiving it been aided association consumers would not TRI cover vario TheT Toxic Sub stances Th the membe agency or merely ma companies the indust TSC tory under seemed si ceramics reporting: of CO2 up to the rep include th occurring bauxites ee eee