Document NeEEwzG54j7qdbKVRpLXQgYRy

FILE NAME: RT Vanderbilt (RTV) DATE: 2006 July 21 DOC#: RTV236 DOCUMENT DESCRIPTION: Vanderbilt Documents from Margaret Baumgardner C laims R esolution Ma nage me nt C orporati on VIA FEDERAL EXPRESS July 21,2006 Lawrence Madeksho Law Offices of Lawrence Madeksho 8866 Gulf Freeway, Suite 440 Houston, TX 77017 MARGARET ]. BAUMGARDN ER RESEARCH COORDINATOR Re: R.T. Vanderbilt Dear Mr. Madeksho: Enclosed are the documents from microfilm relating to R.T. Vanderbilt along with my affidavit. Below are the charges for this research. The charges include time for me to prepare an affidavit and have it notarized. Also included is time for me to prepare the INQUIRE search. Research Coordinator's time 1.5 hours x $150.00 per hour $225.00 Production Assistant's time 13.25 hours x $55.00 per hour Bates labels - 985 labels x $.07 each Copies, microfilm - 984 pages x $.40 per page $728.75 $ 68.95 $393.60 TOTAL $1,416.30 Please forward a check for $ 1,416.30 payable to the Claims Resolution Management Corporation, to my attention in Aurora. If you have any questions, please do not hesitate to contact me. Sincerely, A Margaret J. Baumgardner cc: Joanne R. Marvin Enclosures ASBESTOS CLAIMS RESEARCH FACILITY: 3390 PEORIA STREET, SUITE 304, AURORA, CO 80010 PHONE: 303.364.8158 FAX: 303.364.9603 WWW.CLAIMSRES.COM AFFIDAVIT STATE OF COLORADO COUNTY OF JEFFERSON ) ) ss. ) I, Margaret J. Baumgardner, being o f full age and first duly sworn do hereby state: 1. Iam the Research Coordinator for the Claims Resolution Management Corporation ("CRMC"), a wholly owned subsidiary o f the Manville Personal Injury Settlement Trust ("Trust"). The CRMC was created in December 1998 and is staffed by former Trust employees. On January 1, 1999, CRMC began providing claims resolution facility services to the Trust. 2. In this position, I manage the Asbestos Claims Research Facility ("Facility"), a document and records repository located at 3390 Peoria Street, Suite 304, Aurora, Colorado. The Facility contains the business records including but not limited to correspondence, memoranda, reports, records and data compilations ("record") of Manville Corporation or related entities ("Manville"), generally, as well as Manville records relevant to litigation o f asbestos liability. The Trust has managed and operated the Facility from November 28, 1988, the date on which the Manville bankruptcy plan was consummated. 3. M y experience and familiarity with the documents at the Facility began in 1983 while working for Manville. In my work as a paralegal for Manville, I assisted in locating, indexing and packing many o f the records which became the foundation documents for the Facility. I continued to work for Manville until September 1987. From March 1988 to September 1 9 8 8 ,1 was hired to supervise and assist in the indexing o f the first 20,000 boxes which were turned over to the Trust in November 1988. From September 1988 to January 1989, I assisted in the privilege review o f documents to be given to the Trust. From November 1988 to April 1994,1worked for Freeborn & Peters and was put in charge o f the Facility, managing all productions and "new" acquisitions. In September 1995,1was hired by the Trust to manage the Facility. In December 1998,1was hired by the CRMC to manage the Facility for the Trust. Accordingly, I am personally familiar with many of the records stored at the Facility, as well as how the records have been gathered. 4. To the best o f my knowledge, information and belief, I certify that these records were made at or near the time by, or from information transmitted by, a person with knowledge, were kept in the course o f the regularly conducted business activity o f Manville, and it was the regular practice and the business activity o f Manville to make the records. Margaret J. Baumgardner Affidavit Page 2 5. Documents from this Facility were copied for the Law Offices o f Lawrence Madeksho. The copies have come from microfilm at the Facility and are bates labeled CRMC- MAD-000001 through CRMC-MAD-000985 and these documents are true and correct copies of documents found at the Facility. Subscribed and sworn to before me this 21st day o f July, 2006. Notary Public CHRISTINE M. SMITH NOTARY PUBLIC STATE OF COLORADO My Commission Excires 11/08/2008 COPY PORK INITIALS BOX NUMBER fKx/sM I Jk SEGMENT NO. NOT ES REQUESTING PARTY M<JcJtcL I ' " ! " 8 8 8 I 1 8 8 - " __ * ... DATE ~ ; ' r -------;--------: i 1 1 8 | I ' . . -----------;-- :--------------- ;---------:-- ---- ;------------- ------------ -- !-------- - ' . . - \ ~ r r > i j. CRMC-MAD-000001 \ FINAL REPORT / INDUSTRIAL HYGIENE STUDY CF THE GOUVERNEUR TALC COMPANY, NUMBER CUE MINE AMD MILL Balmat, Mew York Volume I REPORT PREPARED BY John M. Dement. Ralph D. Zumwalde SURVEY DATE November 3-7, 1975 FINAL REPORT DATE June 3, 1977 Department of Health, Education, ar.c Welfare Center for Disease Control National Institute for Occupational Safety anc Health Division of Surveillance, Hasard Evaluations and Field Studies Cincinnati, Ohio CRMC-MAD CONTENTS Abstract Acknowledgements Introduction Description of the Facilities Description of Operations and Controls Medical, Industrial Hygiene and Safety Programs Inspection of Mine and Mill Operations Potential Health Hazards Housekeeping Study Methods Bulk Sample Collection and Analysis Air Sampling and Analysis Study Results Bulk Sample Analyses Air Samples Comparison of Sampling and A.r.alytical Methods Comparison of Present and Past Exposures Discussion Conclusions and Recommendations References Appendixes I Mineral Product Safety Data Sheets for R.T. Vanderbilt Talcs II Results of individual Air Samples and Summary Statistics for NICSH Industrial Hygiene Study FIGURES 1 Gouverneur Talc Company, Inc. Simplified Flew Sheet 2 Aspect Ratios for Airborne Anthophyllite Fibers 3 Aspect Patios for Airborne Tremolite Fibers 4 Electron Photomicrograph of Airborne Particulates 5 Electron Photomicrograph of Airborne Particulates 6 Electron Photomicrograph of Airborne Particulates 7 Comparison of Time-Weighted-Average Fiber and Respirable Dust Exposures, Mill Samples 8 Comparison of Fiber Concentrations by Cptical and Electron Microscopy 9 Mean Yearly Impir.ger Dust Concentrations for Mine Operations 10 Mean Yearly Impinger Duse Concentrations for Mill Operations TABLES 1 Sources of Talc Bulk Samples Obtained from Talc Suppliers 2 Summary of Independent Analyses of Talcs Produced an the Gouverneur Talc Company and obtained from Suppliers iv 1 3 5 9 10 10 10 11 11 13 15 15 22 38 45 51 60 61 7 32 33 34 35 36 39 43 48 49 12 16 CRMC-MAD-000003 < Tables Con't CONTENTS 3 Surinary of NICSH Electron Microscopic Analyses of Talcs Produced at the Gouverneur Talc Company and Obtained From Suppliers 4 Results of P a y Diffraction and Petrographic Microscopic. Analyses of Talc Samples Collected During Study 5 Results of Trace Metal Analyses of Bulk Talc Samples Collected During Study 5 Results of Major Element Analyses of Gouverneur Talc Company Product Samples 7 Summary of Time-Weighted-Average Exposures by Job, Gouverneur Talc Company Number One Mine 8 Summary of Time-Weighted-Average Exposures by Job, Gouverneur Talc Company Number Cne Mill 9 Comparison of Optical and Electron Microscopic Fibers Concentrations 10 Summary of Airborne Fiber Types Determined by Analytical Electron Microscopy 11 Summary of Airborne Fiber Diameters for Positive Amphiboles 1 ** Summary of Airborne Fiber Lengths for Positive Amphiboles 13 Aspect Ratios for Positive Amphiboles Determined by Electron Microscopy 14 Summary of Stationary Samples for Correlation of Sampling Methods 15 Comparison of Impinger and Optical Fiber Count Results 16 Comparison of Optical and Electron Microscopic Fiber Concentrations 17 Summary of Historic Impinger Dust Measurements at the Gouverneur Talc Company 18 Summary of Historic Fiber Exposure Measurements at the Gouverneur Talc Ccnoanv CRMC-MAD-000004 ABSTRACT A industrial hygiene study vus undertaker, at the Gouverneur Talc Company, number one nine ar.d .nil.' . during Mcvember 3-7, 1975. Samples ware collected to evaluate exposures to respirable dust, free silaca and asbestos fibers. In addition impir.ger samples were collected nor* corr.Cairl.3cn with past exposure measurements. Bulk prcduc t talc samples were also co llected for mineralogical analyses by both MICSH and independent consultant laboratories. Results of mineralogical analyses of talc product samples by all laboratories concluded that asbestiform minerals (tre.r.olite ar.d anthophyllite) were pre sent. Time-weighted-average fiber exposures in mine and mill operations were found to range from 1.7 to 9.3 fibers > 5 ym/cc ar.d time-weighted-average re spirable dust exposures were found to range from 0.25 to 2.96 mg/m3 . Mo free silica exposures were found to exceed the MICSH recommended standard of 50 ug/ m 3. Electron microscopic analyses of the airborne dusts shewed 28 to 45% of airborne fibers to be anthophyllite with lesser quantities (12 to 19%) of tremolite. More than 90% of the airborne fibers were shorter than 5 um in lengt A review of historic exposure data cf these operations and epidemiological data concerning health effects of exposures to tremolite ar.d anthophyllite are included in addition to recommendations for workplace improvements to reduce exposures. CRMC-MAD-000005 ACKNOWLEDGEMENTS Mike Crar.nan and Eric Kus of MIC-SH and Jim Salois of MESA assisted in collection of the industrial hygiene samples. Mike Grannan, Robert hhiiii;.", and Kenneth M. Wallingford assisted in the optical asbestos fiber analyses and Terr/ Hoyle and Dennis Roberts assisted in reduction of the field and laboratory data. Dr. D.R. Bowes of the University of Glasgow kindly performed major element analyses of talc bulk samples. Analyses of talc bulk samples were performed by W.C. McCrone Associates and the 'At. Sinai School of Medicine of the City University of New York. a iv CRMC-MAD-000006 INTRODUCTION The term "talc" in the mineraiogical sense denotes a specific rockforming mineral of the sheet silicate category [Mgg (SigC2o) (011)4 ]; however, "talc" m the industrial sense may represent a varied mixture of minerals with similar physical properties as talc. Unfortunately, many past studie of the health effects of industrial talc exposures have not adequately inden- tified the various hazardous agents which may have been present in the talcs. The National Institute for Occupational Safety and Health (NIOSH) has underway ar. industrywide study of the talc mining and milling industry. These studies include both epidemiological studies of exposed worker populations to determine health effects which may be attributed to the work environment and detailed industrial hygiene studies to characterize the various agents to which these workers have been exposed. The "talc" mining area in the vicinity of St. Lawrence County, Mew York, represents a complex association of amphiboles '(anthophyllite, tremolite, etc.) talc, quartz, and serpentines.(D Proportional mortality studies by Kleinfeld et.al.^3) Qf talc miners and millers in this area have demon strated significantly increased mortality due to both malignant and nonmalignant respiratory diseases. Also, MICSH analyses of talcs (Mytal 2C0) certified by the Vanderbilt Company not to contain asbestos have demonstrated significant contamination levels of both fibrous tremolite and fibrous antho phyllite. (4) However, it has been stated that these studies are not appro priate since the mineral make-up of talc deposits in this area differ sub stantially with each deposit; some containing asbestos while ot.ners do not. Cne study(-^5 has suggested differences ir. toxicity amcnc these minerals. CRMC-MAD-000007 Those questioning these studies base their arguments on the definition of a fiber (3 to 1 aspect ratio) as described in OSHA s t a n d a r d s ^ rather than mineralgica! fiber identification. In order to resolve the question concerning the tonicity of these talcs, it was decided that NIOSH would conduct epidemiological mortality, morbidity, and industrial hygiene studies of the Gouverneur Talc Co. which produces Mytal and other talcs which Vanderbilt contends do not contain asbestos. The Vanderbilt Company pre sently markets products from one mine and mill (t 3) which the company admits to containing asbestos and are so labeled. During November 3-7, 1975, an industrial hygiene study was conducted at the number one mine and mill of the Gouverneur Talc Company, Balmat, New York. Air samples were collected to evaluate worker exposures to asbestos fibers, respirable dust, free silica, and talc dust. A progress report of this study containing all personal exposure data was issued on May 25, 1976 which demon strated exposures to asbestiform minerals to exceed current OSHA and M2SA standards. This final report contains a descripcin of facilities studied, sampling and analytical methods employed, sample results and conclusions and recommendations for workplace improvements to help protect employee health at this and other facilities using these or similar products. CRMC-MAD-000008 DESCRIPTION OF THE FACILITIES i.T . Vanderbilt began talc operations at the Gouverneur Talc Cor.pany in 1947 with one nine (41) and one mill (#1). In 1974, the Vanderbilt Corporation^ acquired all talc operations of the International Talc Company. From this purchase, Vanderbilt was operating two mills (?] and 46), one underground mine (43 mine) and one open pit (Arnold Pit) at the time of this study. Only the 43 mine contains what the Vanderbilt Corporation considers to be fibrous anthcphyHite and this ore is processed in the #3 mill. The total employment at all R.T. Vanderbilt New York talc operations at the time of the present study was approximately 170 persons. These are broken down as follows: Underground Open Pit Mills Salaried - 41 - 13 - 67 - 49 170 Employees of these operations are represented by Local 44979 of United Steel 'Workers which organised in these talc operations in 1954. All operations were on a 5b day per week schedule with the mine operating only during the day shift while the mill operates three shifts. A list of jobs and a de scription of related duties in the number one mine and mill are giver, in Appendix II. Approximately 13 talc products frcm all of the Company's New York talc operations are marketed. Mineral Product Safety Data Sheens for these urcducts (supplied by R.T. Vanderbilt), are shewn in Appendix I. These talcs are used in numerour products. Some typical uses are as follows: 3 CRMC-MAD-000009 C R M C - M A D -000010 DESCRIPTION OF OPERATIONS AND CONTROLS Und..--ground sock mining methods are employed using jackieg drills to make holes or blasting the ore in open stapes. The number one mine consists of one main shaft 1250 feet in depth with three main working levels branching off. During the present survey, ore was being mined from ap proximately 6 of 2 follows a typical cycle: blasting is done with gelatin dynamite and ANFO; time is allowed for dust and gases to dissipate; stoning operations are begun including drilling for the next shifts, blasting, and removal of ore. However, seme secondary blasting is done during the work shift. Ore (muck) from the .stoping areas is loaded into 2 ton rail cars using either gravity drawpoint loading or scraper (slusher) loading. Ore from these cars is discharged into a central jaw crusher located at the 700 ft. level although seme crushing is also done on the 1110 ft. level. The crushed ore is loaded into a skip and carried to the mine headframe where a gyratory crusher reduces the ore to approximately 3/4 inch screen size. The ore is then transported by conveyor belt to one of four wet ore storage bins in the mill. Approximately 40,000 cfm of mining ventilation is provided to this mine. In addition, the ore may be quite moist, thereby further reducing dust exposures. Drilling is usually dene using wet methods. At the 700 ft. level crusher, water sprays, are also used for dust suppression. 5 In addition to ores from the number one mine, the number one mill also receives ores for first stage crushing from the Arnold Pit located ap proximately one mile from the mill. Cres are mined from the Arnold Pit using traditional hard rock open pit mining methods by drilling blastholes then blasting to break the ore. A front loader is used to load ore into trucks by which the ore is transported to the primary crushers which are located at the open pit. There are no dust collectors on the open pit crusher. In the number one mill, various grade talc products are produced by dry grinding operations. A simplified flow sheet for the milling operations is given in Figure 1. Ores from the vet ore storage bins are periodically sampled by the quality control lab to determine appropriate product grade. The ores are first ground in a cone crusher followed by drying in a rotary dryer. The dry ore is next further reduced using a gyratory disc crusher to produce a minus 12 to 14 mesh product. The product is next screened on vibratory screens and transported to one of six dry ore silos. Fine grind products are made from these ores using either Kardinge pebble mills in closed circuit with ?-aymond separators or impact crushers in closed circuit with fluid energy mills. The fine ground powder is stored in one of several concrete silos. These silos are filled using a bet:tern filling technique patented by ?..T. Vanderbilt. Material from these silcs is withdrawn by air slides and pumped to the packaging and shipping areas. C R M C - M A D -000012 Talc may be cither sold in bulk or packaged in 50 lb. valve type lirait paper bag:;. Sag packaging is done using pneumatic packing machines. In general, ventilation systems within the mill are quite good, .'lost material transfer points are provided with local exhaust ventilation and bucket elevators and conveyors are maintained under negative pressure. At the bugging machines, local exhaust ventilation is provided at the filling spout in addition to downdraft ventilatioh at the bag hopper. For bull; car loading, the telescopic loading spout is provided with a local exhaust ventilation collar. Air pollution controls consist largely of baghouse dust collectors, although a cyclone is used or. the mine headframe gyratory crushers. Much of the collected material is recycled to the product streams. Mo products from the number cr.e mine or Arnold Pit were being labeled with the OSHA asbestos warning at the time of this study. OTHER MIMES AMD MILLS The #3 mine was not observed during this study. The 3 and #6M mills were observed during a previous visit. The fr3 mill produces products considered by the Company to contain anthcphyllite asbestos. These products are 1 3V*.p 2.^ci with the CSI-LA asbestos warning label. Milling <5 operations at these mills are basically the same as those previously described for the 1 mill with minor variations. Dust control measures are not, however, as effective as those observed in the =fl mine ar.d are being further i.T.prov CRMC-MAD-000014 3 MEDICAL, INDUSTRIAL HYGIENE A'.'D SAFETY PROGRAMS Only first-aid medical facilities are available at the Gouverneur Talc to, ','tiw umployeas arc given a pre-employment examination consisting of a work history, medical history, physical examination, and chest x-ray. Periodic examinations including a chest x-ray have been given at yearly intervals. All examinations are given by a local physician who consults with the Plant.. Plant safety is handled by a Plant Safety Director (Eloyd Robinson). Monthly departmental safety inspections are conducted by Union and Plant personnel in addition to monthly safety meetings. Personnel protective equipment presently used in the mine includes hard hats, mine lights, personnel rescuers, safety glasses, and safety boots all of which are pro vided by the Company. Ir. the mill, safety glasses are encouraged and workers at talc bagging operations are provided with dust masks which, according to observations made during this study, are only sporadically used. Hearing protection is provided for specific operations in the mill and mine. In 1974, there were 9 reported (lost time) accidents in the mine and 2 in the mill. The Company presently does not maintain the services of a full time industrial! hygienist. Seme sampling is conducted by the Plant Safety Director in additio to yearly sampling by the: insurance carrier. Air sampling in these operations, has also been conducted by the Hew York Division cf Industrial Hygiene and '! the Mining Enforcement and Safety Administration (MESA). 9 CRMC-MAD-000015 INSPECTION OF MINE AND MILL OPERATICMS POTENTIAL HEALTH HAZARDS The following are potential health hazards noted during this visit: 1. Respiratory exposures to mineral dusts (fibrous and non-fibrous tremolite and anthophyHite, talc, serpentine, quartz, etc.) in mining and milling operations. 2. Excessive noise exposures in selected plant operations, 3. Exposures to blasting gases in mining operations during secondary blasting. HOUSEKEEPING In general, housekeeping in these operations was judged to be acceptable Some loose talc was, however, noted on the floors in the talc bagging operations. Numerous leaks at material transfer points were noted in the mill. 10 CRMC-MAD-000016 Table 1 Sources of P.T. Vanderbil *<-x>1>w-* Produced at the Gouverneur Talc Company, Humber One Mine and Mill and Obtained from Suppliers Product liaim; Ny tal 3G0 Hytal 400 5:< 325 X FT 3X Source Crone Chemical P.O. Box 14042 Houston, Texas 77021 Paul Crazier Company 1115 Silver St. Houston, Texas 77007 HI OSH * 001 002 003 004 005 006 007 12 CRMC-MAD-0000] seven a:;-.: . j a *.jj stvct methods :? a m : a w a l s i s ara leant produced and bagged surine rha indus triai 1lacte ;';r labcru-ury mineralsgicai assay. In addition oduc;c at this mins and mill wesa collected from iners (Table 1) for mar.aralcgical assay. Several ore lac ted durur.g nine sampling. Analyses of collected bull: camples were performed by both WIC3K ar.d inde pendent consultant laboratories. The seven talc bulk samples collected from talc suppliers were submitted to both Walter C. McCror.e Associates Incorporated and to the Mount Sinai School of Medicine for independent analysis by x-ray diffraction, optical microscopy and electron microscopy. These came samples wore also analyzed by MICSK for the presence of ashestiform fibers by electron microscopy using electron diffraction ar.d energy dispersive x-ray analysis for fiber identification.(?) Bulk samples collected during the industrial hygiene study were submitted to Walter c. McCrone Associates Incorporated for mir.eralcgical analyses by x-ray diffraction (using step scanning m.ethods) and optical microscopic analyses. These same samples were analysed by MICSH for selected trace metals by atomic absorption spectroscopy (after acid digestion). O In addition to the above a; alyses, several products produced at the number one mine and mill and subn tted to NICSK by Vanderbilt were analyzed for chemical composition by hr D.?.. Bowes of the Department of Geology, the CRMC-MAD-000018 University ot' Glasgow. For those analyses, Dr. Dowes used spectrophotom etry for SiOo, TiO-,, Ai-O}, total ?e (FeT^ by difference from FeO) and determinations. Atomic absorption analysis was used for Mno, MgO and CaO. Flame ohotcmetry was used fer Na 0 and 0 .(1 0 ) and wet chemical assay was used for AIR SAitl'T.IMG AND ANALYSIS Personal air samples were collected from the breathing acne (miners and millers" to determine tima-v/e1 gh ted-average exposui :o respirable dust, free silica, m o ascestos ;rsor.;al samoles for resoirabia dust and free silica were collected at a flew rata of 1.7 1pm using 37 mm diameter polyvinyl chloride filters (pre-weighed) preceeded by 10 mm nylon cyccne separators. Samples for asbestos fiber analysis were collected on open faced 37 mm diameter^ Millipore Type AT. filters (0.3 um pore sice) at a flew rate of 1.7 1pm. Re spirable samplers were allowed to operate for the full work shift while asbestos samples were changed periodically during the work shift as needed to prevent overloading of filters. Free silica concentrations were determined using x-ray diffraction as specified in the NICSH Silica Criteria D o c u m e n t . ^ All asbestos samples were analyzed using the NICSH phase contrast counting technique. ( 6 ) r n addition, a representative portion of the asbestos samples were randomly chosen and analyzed by electron microscopy using selected area electron diffraction and energy dispersive x-ray ar.aiys. ; for fiber identicication. Electron microscopy was also used to determine airborne fiber concentrations, / *7 and sice (diameter and length) distribution^. Camples for electron microscopic analysis were prepared using a modification cf methods described byCrtiz.(S) 13 CRMC-MAD-000019 In order to relate results of the present industrial hygiene study to past- studies in these operations, midget impinger samples also were taken in a manner identical to past sampling techniques. 3reathir.g cone impinger samples were collected in ethyl alcohol at a flow rata of 0 . 1 cin with sampling period:; ranging from 15 to 30 minutes. These samples were counted at the end of each work shift using Dunn counting cells and bright field optical microscopy (10CX). Two preparations were made for each sample ar.d allowed to settle for 30 minutes and counts made by two counters. When counts differed by more than 10%, new preparations were made and recounted. In addition to personal sampling, stationary samples were taken to further attempt correlations between impinger counts, respirable mass concentrations, total mass concentrations, and asbestos fiber concen trations. Midget impingers were collected as described above using a sequential sampler (24 samplers) such that the entire work shift was sampled. Simultaneously, respirable and total mass samples were col lected at flow rates of 10 1pm using 37 mm diameter polyvinyl chloride filters (pre-weighed) The respirable samples were collected using stainless steel cyclone and free silica analyses of the respirable dust performed using x-ray diffraction.^ Asbestos count samples were collected and analyzed as described above for personal samples. CRMC-MAD-000020 3ULX S.'d:.RLE lnITC STUDY RESULTS Resu1re of o of the oev talc s are snew r. in Tabl^ ; 2 and 3. Cop ies of and M Son ai analytical data obtai :r of th.i.: repor_. These repo rt.3 all c ar.d anth r,phyiirta were present in these and i;ICS H reported trace cuant Lti es of only "**.J or discree ar.cy notable .J a nig; repor ted by Mt. Sr nai. NICSH ar.alyses resul s whi ch is substantiated by the a Results of HIOSH electron microscopic analyses of these talcs, given in Table 3, shew that a majority of the fibrous particles in these samples are anthophyllite (67 to 38%) with smaller quantities of tremolite (4 to 12%). A large majority of the tremolite identified by x-ray diffraction is not fibrous. Anthcphyllite fibers with very large aspect ratios (1000/1) were observed. A close association between talc and tremolite has been demon strated by Stemple and Brindley. Results of further x-ray diffraction and petrographic microscopic analyses (McCrone) of product samples collected during the study are shown in Table 4. These results are in basic agreement with previous results given in Table 2. As can be seen in Table 5, all trace metals for which analyses were performed, with the exception of iron and manganese, were essentially absent. Only insignifleant quantities of iron and manganese were detected. CRMC-MAD-000021 Table 2 Summary of Independent Analyse;; of Talcs Produced at the Convenient Talc Company Number One Mine and Mill. Samples Obtained From Talc Suppliers -la L ------------------- - U v tal 400 ile one S i na 1 50-O 2'i by H i t e OUc S in a i Present 2-1 N y ta l 300 40-50 18 * 4-5 P e r c e n t C o m p o s i t i o n by V.'e i ^ h t 5X X 3X 40-50 27 >50-60 50-60 50-60 32 ] FT \ 5-U 17 Present P resen t k * 7-9 -- k UllC Sinai tLi neb i otic Sinai 0 .5-1.0 7-10 10-15 14-18 2 9-10 10-15 14-18 vl.5 8-9 10-12 14-18 <0.5 9-10 M5 26-30 0 .5 -1 .0 7-8 -v30 31-35 k k k k ^20 26-30 below detection limits using x-ray diffraction (line scan by McCrone, step scanning by Mt. Sinai), below detection limits by step scanning. 32 5 'v 6 0 24 * 5-7 ^ 1 .5 3-4 10-12 19-23 0 1. Table 2 Summary of Independent Analyses of Talcs Produced it the Gouverneur Talc Company Humber One Mine and Mill. Samples Obtained From Talc Suppliers Nytal 400 50-bO 2 A Present 2-1 Hy ta1 100 40-50 1 k 4-5 Percent Composition liy Weight 5X X IX 40-50 27 >50-60 50-60 50-60 32 Present Present A 7-9 ~- k FT 50-60 17 A A 325 n-60 24 A 5-7 0.5-1.0 7-10 2 y-io M .5 B-9 <0.5 0.5-1.0 A A ^1.5 9-10 7-8 A A 3-4 10-15 14-1 10-15 14-18 10-12 14-18 M5 26-30 'v.30 31-35 n-20 26-30 limits using x-ray diffraction (line scan by McCrone, step scanning by Mt. Sinai), limits by step scanning. 10-12 19-23 CRMC-M^dj o o o o 0 b-> CRMC-MAD-000024 Tiih 1e ,'J Summary of NIOSII Electron Microscopic Aiwi lyses of Title Produced at the (louvernear Title* Company Number One Mine and Mill Samples Obtained From Talc Suppliers i.llC 5ai..p 1 . 17 L a i `'.00 l y t . j l .100 II K.inge of Fiber Aspect Fat ios 1/1 Lo KJUO/l M l to 100/1 5/1 Lo 100/1 H/l to HO/1 S/l LO 100/1 1/1 to 50/1 1/i to 50/1 Fiber 'Identification (Percent)** Pos i1 1ve Ainpliil>o1es Tiemo lite AnLliopliy11 ILe Pos 11ive Clirysoti ie Non Asbes tos e 88 N .I). 6 12 72 N.D. A 11 80 Trace A 6 80 N.D. 2 12 67 W .D . 6 16 72 N.D. A A 88 Trace 7 s^Uiteil area d Ir1rac tion patterns not sufficient for positive Identification vi.-cni - L at all libers ana 1yzed by count and not by mays. All fiber lengths analyzed l( ' None IlcLecLcd Not* Identified -- 12 5 12 16 8 -- !1 Iii: I a ' ..ls ellL i'io lI I l'r el.iO 11t e Do Ioi.i1te be i p e 111 in u i Table A Kcsuks of X-Kay Diffract Ion and Petrographic Microscopic. Analyses of Hulk Talc Samples Collected During Study Couverneur Talc Company, Number One Mine and Mill Ta Ic I'T 'll-ID <A0 <10 2.0 1 1 10-15 My Lai 100 A 3-A 8 '<3 7 '<A. 5 <0.25 <0.5 <0.5 10-15 Sample Analyses , % liy Weight Ceramet a3c HOT Nyta 1 200 30-35 33-3 <A9 '<A3 ^5 '<8 <0.25 0.7 0 0 <0.5 <0.5 10-15 10-15 / lie lodes lizard! te and antigorite. Ny tal 300 35-AO '<38 10 0.8 <0.5 <0.5 10-15 My La 1 200 '<1 A '<59 35 1.1 <1 <0.5 '<10 CRMC-MAD-000025 4__ T i- ^ -sV. 88<jfcJrlv & O eeon : CRMC-MAD-000026 ' i . ..lie, L IUO y l a 3 n J i. a o i' i,ur/ci nein T L'act : La 1 A n a l y s e ; ; o f B u l k T a l : !e s k f / i l e c: Ce ci b u r i n i ' , Stanly u y , N u m b e r O n u M i n e n u n MMii 1 lit. U/'.//: 11/4/75 .// 11/3//' il/:;//: Cr 3 3 ') 3 ') 3 r Co ~ M e t a l , ' M :7 Ni 1 1100 l'/OO 1 <1 1000 H40 CJ 2 1000 6 2 9/0 300 7 3 1000 170(1 5 2 900 IA00 5 absorption soc ctroscouy 2 II CM 20 <1 19 <1 17 < 1 20 <1 23 <1 22 <1 Results of major element analyses by Dr. Scves are shown in Tabia 6 . The high CaO content of these talcs correlates reasonably .ell with the observed high tremolite content. Other carbonates except traces of calcite are absent or negligible in these talcs as demonstrated by low CC2 v a l u e s . T h e Fe and Mn analyses are consistent with the results shown in Table 5. These major element analyses are in basic agreement with results obtained by Ross et.al.^'^ for talcs in the Arnold Pit and by Dreesser.^) for talcs in this ar Ross et.al. also suggested that an additional manganese-rich amchibole, tiredite, may be found in trace quantities in these deposits. Also, the major element analyses shown in Table 6 do show 0.12 to 0.22% MnO; however, no manganese-rich amphiboles were detected by the electron microscope analyse ;f using selected area electron diffraction and microchemical analysis. CRMC-MAD-000027 T able 6 Results of Major Element Analyses of Gouverneur Talc Company, Number One Mill, Product Samples* Ny La 1 100 N y ta 1 200 !lyLa 1 A00 Sample Analyses, 7. liy WeiliL* 'Ceram i ta le 1 Cerami talc 10A Cerami talc 1OAC Cerami talc 11DT Talc Scds** 54.85 5A .52 56.11 56.1 A 52.81 52. A7 55.47 61.49 0.4 0.15 0.07 0.03 0.08 0.A 0.07 0.01 0.18 0.12 0.13 0.13 0.16 0.11 0.13 1.20 0.10 0.11 0.08 0.11 o.oa 0.06 0.11 0.38 (i. 0A 0.0 1 0.06 0.03 0.03 0.01 0.03 1.07 0.2 1 0.20 0.22 0.15 0.12 0.10 0.12 0.00 28. AO 28.78 20. A0 20.56 30.20 30.56 29.10 30.54 V .02 8.51 7.50 7. A0 8.15 8.30 8.25 0.A6 0.28 0. AA 0.18 0.25 0.30 0.16 0.18 -- 0. 10 0. 17 0.10 0.10 0.10 0.10 0.13 -- U .0 J 0.01 0.03 0.03 0.03 3.03 0.03 -- 5.1/ 5.07 5.00 5.56 6.07 6.6? 5.24 5.00 1.15 1.15 1.03 0.06 1.30 0.98 0.84 5.00 1 0 0 .! 7 99.52 j _________________________ ----- _ _ ----__1 00.00 100.A5 99.51 99.59 99.59 ea subii.i 1 1 cil to 1II0SII by K.T, Vanderbilt, Analyses performed by Dr. D.R. Boues, University of Glasgou. t a l c S t a n d a r d a n a l y s e s in reference 10. --... !.. CBMC-MAD-000028 S A I R SAMPLES A brief description of each job, sampling and analytical methods used, resuits of all individual samples and appropriate summary statistics are shown in Appendix II. Jobs are identified by 4 digit job codes. Tabular summaries of tome-weighted-average exposures by job category for the mine end mill are given in Tables 7 and 3, respectively. Tables 7 and 8 show free silica exposures to be very low. The highest time-weighted-average free silica exposure observed was 0.040 mg/n3 which is below the 3 hour time-weighted-average exposure value of 0.05 mg/m3 re commended by '.IICSH for this material. Respirable dust exposures ranged from 0.25 to 2.96 mg/m3 . Ho respirable dust standard has been determined fo the mineral talc or talc containing fibrous tremolite or anthcphyllite. Breathing none impir.ger concentrations ranged from 0.5 to 15.3 million particles per cubic foot of air (mpocf) with highest concentrations being observed in the mine. The present CSKA and MESA standard for "talc" contain ing < 1 % free silica and no asbestos fibers is 20 mppof.^ Due to its fiber content, the occupational asbestos exposure standard must be applied to exposures to materials from these mining and milling operations. Time-weighted-average asbestos fiber exposures in excess of five fibers > 3 yn/cc were observed for the following job categories: (1) Mine Crusher Cperator (2) Trammer (3) Mine Cageman 22 C R M c -m a d .o o o o 29 Table 7 Summary of Time-weighced-Average Exposures By Job, Gouverneur Talc Co. Number One Mine Job Cede 0102 0103 Job T iri ! | Crsaner Opera cor -Vx>i asj.ic.ry- Asbes cos fibers > 5 ym/cc (Optical Microscopy) j 9 . 3 (A) 5.6 (25) 0104 | Scraoper Man 1 0105 Underground Laborer -- 0106 Driller 3.0 (5) 0114 Mucker -- 0115 0301 Cageman Repairman 9.5 (5) -- 0302 Repairman's Helper -- 0303 0304 Blacksmi th MainCenance Mechanic 2.6 (3) 1.7 (12) Resp. Mass mg/m-' -- 0.64 (3) 1.29 (3) 0.58 (1) 0.98 (3) -- 0.23 (1) 1.14 (1) 0.86 (1) -- 0.42 (1) Impinger mppcf Free SO2 mg/ttP -- 10.1 (3) 1 1 . 8 (5) -- 00.7 (1) 15.8 (1) 2.0 (1) -- 3.6 (1) -- 1.5 (1) -- 0.020 (3) 0.012 (3) 0.006 (2) 0.014 (2) -- -- -- 0.000 (1) -- 0.000 (1) ( ) = Number of samples used for calculacin of cime-weighced-average values for each job caca gory. Samples for respirable mass and free S1 0o were full s h i r e samples. Table 8 Summary of Time-Weighccd-Avernge Exposures 3y Job, Gouverneur Talc Co. 'lumber One Mill J ob I Cene Job T i d e 0201 ----- r _0203_! Ml 1! Te r e m a n _______ Genera 1 laborer 020,J Crusher Oyera cor 02Co ! Cari ir.y : Cners crr 0203 | Tneeler 0ocra :or ___ Q2Q9 I 0211 j 0212 ! 0213 | 021': j Packer Serviceman ?a e house Foremar. Far;; Lift Cperacor Car Liner___________ 0220 1 3ul.k Car Loader 0401 Hillvriph c _____ '____ 0402 Instrument Repairman 0403 Mach ini a c___________ 0405 M iIlw righ c Helper 0406 Sheer Metal Worker 0410 Piler________________ 0411 './elder Asbestos fibers > 5 pm/cc (Opcical Microscopy) 5.3 (9) 5.6 (5) 5.1 (16) 7.9 (14) 8.4 (]4) 5.1 (48) 3.6 (11) 1.5 (5) 4.0 (15) 3.4 (4) 2.0 (3) 1.9 (3) 2.8 ( 6) 1.8 (3) 4.0 (2) 1.7 (3) 4.0 (4) 1.9 (3) Rcsp . Mass mg/m^ 0.58 (2) 1.14 (1) 0.35 (2) 1.09 (2) 1.56 (2) 0.59 (9) 0.42 (2) 0.25 (2) 0.35 (3) 0.31 (1) 0.25 (1) 2.37 (2) 0.59 (2) Q .40 (1) 2.96 (1) 0.50 (1) 0.72 (1) 0.75 (1) ( ) = Number of samples used for calculacin of time-veighred-average values for each job cacagory. Samples for respirable mass and free Sit^ cere full shirr samples. 24 (}) Mill Foreman (5) Mill Laborer (6 ) Crusher Operator (7) Hardmge Operator (3) Wheeler Operator ('.)) lacker In addition, 17 of the 24 job categories samples had time-weighted-average exposures exceeding the current OSHA standard of 2.0 fibers > 5 y m / c c ^ and all operations exceeded the CSHA proposed standard of 0.5 fibers > 5 yra/ cc.(12> T h e f o l l o w i n g job c a t a g o r i . e s h a d e x p o s u r e s i n e x c e s s o f t h e C S H A a n d M S S A allowable ceiling value of 10 fibers > 5 ym/cc: (1) Mine Crushers Operator (2) Trammer (3) Mine Cageman (4) Mill Foreman (5) Mill Laborer (6 ) Crushers Operator (7) Hardinge Operator (8) Wheeler Operator (2) Packer Individual sample results, as determined by electron microscopy, are shewn in Table 9 and time-weighted-average fiber concentrations by jcb are shewn in Table 14 of Appendix It. In these tables, "positive asbestos" means only those identified by electron diffraction; therefore these concentrations 25 amis CRMC-MAD-000032 I present minimum e s t i m a t e s o t t r u e t o t a l a i r b o r n e a s b e s t o s c o n c e n t r a t i o n s As s h o w in Appendix II, time-weighted-average positive asbestos fiber ex posures as determined by electron microscopy ranged from 9.5 to 70.6 fibers/ or ( . i l l lengths) with concentrations in the mill tending to be slightly nxgher. As shown in Table 9, total fiber concentrations (all types and lengths) for individual samples ranged from 11.5 to 199.5 fibers/cc. A summary of airborne fiber types as determined by electron microscopy is s h o w in Table 10. In the mine, 38% of the airborne fibers were identified as anthophyllite while 19% were tremclite and 39% were unidentified. In the mill, 45% of the fibers were anthophyllite, 12% tremolite and 33% unidentified. Three percent of the fibers in the mine and 2% in the mill gave chrysotile electron diffraction patterns. The presence of chrysotile in the air samples is consistent with the results of built sample analyses by Mt. Sinai and NIOSH where trace quantities of chrysotile were noted in seme samples. All chrysotile fibers observed in the air samples were less than 1 yn in length. Nearly all of the serpentine minerals identified in the bulk samples is lizardite. Results of airborne fiber size determinations (diameter and length) for tremolite and anthophyllite fibers are shewn in Tables 11 and 12 with appropriate summary statistics. As was expected, tremolite fibers tended to be larger in diameter and shorter in length than anthophyllite fibers with size distributions for these minerals being similar for the mine and mill. Median fiber diameters of 0.19 and 0.13 ym were observed for tremolite and anthophyllite, respectively. In the mine, median fiber lengths of 1.5 urn for tremolite and 1.5 ym for anthophyllite were observed. Similar lengths 26 CRMC-MAD-000033 i Table 9 Comparison of Optical and Electron Microscopic Fiber C o n c e n t r a t i o n s , Couvernuur Talc Company, Number One Mine and M il l Samp le t Job i Code \ i C.19 4 1 0103 Job T i d e ' ........... T r.i.oinor Pllii C . 20.2 Cl 56 0103 Trammer 22.6 Cl*'.9 0103 Tea inner 13.2 C237 0103 T rammer 8.9 0240 0.06 Driller 9.5 C23 0 I!5 O.KMniwiu L7.5 COs 0201 Mill Foreman 18.9 C42 0201 Mill Foreman 33.7 C98 0203 General laborer 36.6 Cl 7.6 0203 General Laborer 9.0 C77 0209 Crusher Operator 9.0 033 0209 Crusher Operator 13.6 C101 C22 C1M G02 C9G C47 C85 CIO C113 0206 Hardinga Opcracor 0206 Hardinge Opcracor 0208 'heeler Opcracor 0208 '.heeler Operator 0209 Packer 0209 Packer 0211 Packer Serviceman 0211 Packer Serviceman 0212 j Packhouse Foreman 102.7 33.6 18.2 25.5 31.9 91.8 7.3 26.7 13.6 COS 0212 Pacfchouse "orcri.vi > 26.2 i C31 0213 Fork Lift Cperacar 36.0 G 19 7 Cl 80 C197 0309 Maintenance Mechanic 0903 Machinist 0911 j Welder 16.7 29.9 9.9 Fibers/cc H o c cron M ioiMsonnv LU?. j to i.n l -'ib(.r-i A l t ' Ul.r Uniiea 1 > 5lru " 1 92.1 1.2 3.5 'i 29.8 5.9 27.8 2.9 ' 19.1 2.0 2.7 ' i 9.2 P 9.7 } 19.9 30.3 28.8 70.0 1.3 i l 2 '2 5.3 7.0 No counr 6.0 5.8 :i 5.3 y 69.9 9.3 5.9 19.9 1.3 2.9 95.5 2.8 3.8 27.2 A .A 189.5 6.2 2.2 | " J 8.9 51.5 9.2 5.5 3}..3 9.1 6.8 37.4 9.0 57.5 9.3 6.0 ; j 1.2 73.5 3.5 11.6 0.5 39.7 A.A 3.2 . 1.6 9.2 18.9 -------------- J* 23.A 1.9 5.7 71.9 3.7 26.6 1.7 1.6 | 1.1 3.3 2.3 'W*/ 1 i .vl 42.5 3.6 3.6 19.6 2.1 3.1 * Include:; only chose Ivin;; 1der cifl.,b lc electron .l11tfffraccion pattern:/ therefore, represent:: a :ansersativcly law esLiniate. 27 CRMC-MAD-000034 T ab le 10 Summary of Airborne Fiber Types Determined By Analytical Electron Microscopy Gouverneur Talc Company, Number One Mine and Mill Oneration Mine Mill Percent of Airborne Fibers (All Lengths) Posi rive Amnhiboles* Positive Mon iTremolite** j Anthop'nyllite** j Chrysotiie I Asbestos Mot Identified*** r 19 38 3 12 45 2 * Airborne fibers were identified as positive amphiboles by selected area electron diffraction. ** Amphiboles differenciaced by energy dispersive microchemical analysis *** Electron diffraction patterns not sufficient for identification; however, many had x-ray spectra identical to tremolite. CRMC-MAD-000035 T a b le 11 Summary of Airborne Fiber Diameters for Positive Amphiboles Gouvcrneur Talc Company, Number One Mina and M i 1 Operation and Fiber Type Median Diameter pm Mine* Tremolize (N~33) Anthophyiiice (N=164) Mill* Tremolice (N=160) Anthophyiiice (N=537) 0.19 0.13 0.19 0. 13 Geo. Std. Deviation 2.3 2.4 2.4 2.9 95% Conf. Incurvai for Median Diameter pm 7. <_ 0.5 pm in Diameter 0.16-0.23 83 0.12-0.15 9 3 0.17-0.22 37 0.12-0.14 90 * Results of all samples combined for distribution analysis. N = Number of individual fibers analyzed. CRMC-MAD-000036 29 T a b l e 12 Summary of Airborne Fiber Lengths for Positive Amphiboles Gouverneur Talc Company, Number One Mine and Mill Operacin and Fiber Type Median Length urn Mine-1' Tremolice (N-33) 1.6 Anchoen'/1 lite (N-164) 1.5 . ` '- . - Mili-'' Tremolite (M-LO) 1.5 AnthophylLi te (11--687) 1.1 Geo. Std. Deviation 1.8 2.6 1.9 2.9 95% Conf. Interval for Median Length pm 1.4-1.8 1.3-1.7 1.4-1.7 1.3-1.5 * Results of all samples combined for distribution analysis. N = Number of individual fibers analyzed. % 5 um in Length 97 90-92 97 90 CRMC-MAD-000037 .-re -c-n in -he mill. In Che mine ar.d mill, only 3% of the tremolite ihers were longer than 5 cm whereas 3-10% of the anthophyllite fibers era longer char, this length. The trend for airborne anthophyllite fibers to have larger aspect ratios car. be observed ey inspection of Figures 2 and 3 and Table 13. .Median aspect ratios of 0.5 and 7.5 were observed for anthophyllite and tremolite, respectively. Only 30% of the tremolite fibers had aspect ratios greater 11-.;-..-. 10 to 1 './hor-aas 40% of the anthophyllite fibers had aspect ratios greater than this value. Typical electron photomicrographs of airborne particulates from the mine and mill are shov.-n in Figures 4,5 and 6 . In addition to large amounts of analytical data already presented, the asbestiform nature of these fibers may be further appreciated by observation of their "fibril" structures. 31 CRMC-MAD-00003 8 I FIGURE 2 Aspect Riitlos For Airborne Anthophyllite Number One Mine nnd Mill (Combined) Fibers I I ASPECT RATIO ( Length to Width) N = 85 CUMULATIVE % OF VALUES t 1_____ 1____ I______I___ . 1 2 5 10 20 30 < GIVEN RATIO J __ I__ I_I____L--------1------L 40 50 60 70 80 90 95 _i___ I 98 99 ASPECT RATIO ( Length to W id t h )  ' u r t ;. A: E l e c t r o n P h o t o m i c r o g r a p h o f A i r b o r n e P u r t i c u l a c e a f r o m n u m b e r o n e M i l l a n d M i n e CRMC-MAD-000041 l.'lvure 5: E l e c t r o n P h o t o m i c r o g r a p h of Airborne Particulates from N u m b e r one Mine and Mill CRMC-MAD-00004 Figure 6 : Electron Photomicrograph of Airborne Particulates from number one Mine and Mill u 1 V t- .i fr- s'',..; 4 . . ^ V Y ; '- V s V '/> -\ iu> ^ _ A U :W V ..r X. \ : i' V* ! V. .f^U V/ V , * ' r. 1.,##"ac y . ( I s. v , o * ii J " w S v, ^ . '/ / m, ,tj .T-4 -t > *h i'i V r \ A'. V ' me A Vo i/ ,r ' / y X V*- \ Tc * i\ V, i. I ; V>, rV, , >-'/ Ah V-Ki 8 ^ x ,.> 1 v h 1 i JT - \ O f n o o < ,/W o -fc. JKf \ to . f i - /y * * ,* V -..v i ^ r s< V * . # ., *1 . i i ', i ; 1v r 1 / MW 'y` ' y s ", ftn,';. *-_>' .f.v '" 'vi'.'i A (( < .F\ H1 V. j} *'4 y? .j- -:~ w fir,s> ' Wv- * $ \ i.' , / v` '(* T a b l e 13 Aspect Ratios for Positive Amphiboles Determined by Electron Microscopy Gouverneur Talc Company, Number One Mine and Mill j Aspect Ratio Measurement Median Aspect Ratio Aspect Ratio 1 5/1 <_ 1 0 / 1 20/1 <_ 50/1 Tremoli te* Mine Mill 7.5 7.5 23% 70% 96% >99% 24% 70% 96% >99% Anthophvllite* Mine Mill 9.5 9.5 17% 15% 52% 52% 85% 88% 99% >99% * Data shown are for all fiber lengths CRMC-MAD-000044 COMPARISON OF SAMPLING AND ANALYTICAL METHODS In order to compare results of the present study with historic dust measurements, several comparisons were made. Results of the stationary samples for correlation of sampling and analysis methods are shown in Table 14. Based on these limited data, the following average relationships were calculated: Ratio resp. dust, mg/m^/mppcf fibers > 5 vjm/cc/rcsp. dust mg/m^ fibers > 5 pm/cc/mppcf Average 0.22 6.7 1.2 Range 0.12-0.29 3.1-11.9 0.9-1.4 These data also show that an average of 28 percent of the airborne dust in the mill is respirable. A further comparison of fiber concentrations determined by optical micro scopy and respirable dust concentrations is afforded by the paired persor.nal dust measurements mace in the mill. A linear regression analysis of these time-weighted-average values is shown in Figure 7. The regression lint was forced through the null points after this null hypothesis was tested and could not be rejected. A good correlation (r=0.73) was found between these two sampling methods. The results of this analysis demonstrated the following: relationship: fibers > 5 yn/;c/r esp. dust, mg/m" = 6.3 CRMC-MAD-000045 38 T a b l e 14 3unwary of Stationary Samples for Correlation of Sampling Methods Gouverneur Talc Company, Number One Mill Sample S t;a Lion Total Dust mg/m J 1 2.44 (N-l) > 1.47 (N-l) 1 8.81 (N= 1 ) Time-Weighted-Average Concentrations Resp. Dust mg/m^ ' ' .. Impinger mppcf Asbestos Fibers > 5um/cc 0.38 (N=l) 3.5 (N-l2) 4.4 (N-3) 0.36 (N-l) 3.0 ohs) 4.3 (N-3) 2.14 (N-l) 7.2 (N-6 ) 6.7 (N-2) N = Number of individual samples collected. CRMC-MAD-000047 The 95% confidence interval for this ratio was calculated to Lc i.l to 8.5. . These results are consistent with those shewn in Table 14 for the stationary mill samples. A comparison was also made between time-weighted-average fiber exposures (fibers > 5 ym/cc) and impinger dust exposures tapped) for individuals in the mine and mill. These results are shewn in Table 15. As can be seen, no consistent conversion between these sampling methods was obtained although scrr.e differences in conversion values in the mine and mill are evident. A median conversion ratio (fibers > 5 ym/cc/mppcf) of 0.5 was obtained for mine samples whereas a median ratio of 1.7 was obtained for the mill. These differences are statistically significant (p<0.001). Several possible explanations exist for this difference; however, the most plausible is that fine grinding, which takes place in the mill, liberates greater numbers of "free" fibers from the host rock. In addition, finer dust particles in the mill are less efficiently collected and counted by the impinger method. A graphical comparison between total fiber concentrations by electron micro scopy and fibers > 5 yn by optical microscopy is shown in Figure 3. These data were found to be highly scattered with no consistent correlation. These data are summarized in Table 16 and show a significantly different ratio of total fibers by electron microscopy to fibers > 5 urn by optical microscopy between mine and mill samples although no single predictive values can be estimated. 41 CRMC-MAD-000048 T a b l e 15 Comparison or Impinger and Optical fiber Count Results Gouverneur Talc Company, Number One Mine and Mill ! 1> Summaryj ! Statistic Median Ratio Range of Ratios Number of Comparisons 95% Coni. Interval for Median Ratio* Ratio (fibers > 5 um/cc^nppcf) Mine 0.5 Mill r 1.7 0 .2- 1 . 2 0.6-3.4 6 15 0.3-0.8 1.3-2.2 * Based on log - normal distribution model. CRMC-MAD-000049 7 - FIGURE 8 i Compariaon of Fiber Concentrations by Optical uml Electron Microuc&py 6 - 5 4 - 0 3 L ___________ l 0 10 1 CRMC-MAD-000050 1___ 20 J----------- 1__________ 1___________ i____ ______ l___________ 1________ _JL 30 40 50 60 70 80 90 Total Fiber Concentration (Ftbera/cc) by Electron Microscopy T a b l e 16 Comparison of O p tical and E lectron M icroscopic Fiber C oncen trations Gouverr.eur Talc Company, Number One Mine and Mill Summary Statistic : Median Ratio Range of Ratios | 1 Number of Comparisons 95% Coni. Interval* for Median Ratio Ratio (EM total fiber/cc/Opt. fiber > 5 ym/.cc Mine 7 Mill l 7.1 11.0 4.1-12.0 4.7-47.9 5 17 6 .7-7.5 10.7-11.3 * Based on log - normal distribution model. CRMC-MAD-000051 COMPARISON OF PRESENT AND PAST EXPOSURES The present studies demonstrate elevated exposures to asbestiform minerals in nearly all mine and mill process operations. Comparisons between present dust (mppcf) and fiber (fibers > 5 pm/cc) exposures and historic exposure measurements are shown in Tables 17 and 18, respectively. These data were gathered from a number of sources. Trends in dust concentrations as a function of calendar time are difficult to intrepret for several reasons. First and most important is the relative pausity of data on some operations prior to approximately 1970. Secondly, very few samples were taken in any given year and the representativeness of these samples is unknown. For visual inspection of trends in dust concentrations, average values for mine and mill operations by year were calculated and are shown in Figures 9 and 10, respectively. Inspection of Figure 9 shows no consistent trends in dust concentrations when all mine operations are considered. On the other hand, the mine exposures for such operations as drilling, dragline loading, tramming and mucking show relatively consistent exposure levels over the years with only slight deviations. This might be expected as wet drilling has been a routine practice. In addition, ores being mined are relatively wet. Primary crushing and hoist loading operations show somewhat of a de creasing trend. Such controls as water sprays fer dust suppression at the primary crusher are the most probable explaination for this trend. CRMC-MAD-000052 Summary of Historic lmplnger Dust Measurements at the Oouverneur Talc Company, Number One Mine anil Mill (1) V a l u e s for 1954 - 1970 taken from reference 16. ( 2 ) C a l c u l a t e d from MESA reports references 33-42 CRMC-MAD-000053 Table 18 Summary of Historic Fiber Exposure Measurements at the Oouverneur Talc Company, Number One Mine and Mill Ju Ij or OjiL*raiion -- (1 ) 19 70 Mine h r i1 1 ing 8 Dree line Loading 16 1 ramming 6 Mucking 22 Primary Crushing 260 Holst I.wading 29 (2 ) 1972 4 6 6 22 5 Mean F iber Concentration (fiber > 5 pm/cc) (2 ) 1973 (2) 1974 (2 ) 1975 HI0S11 1975 1 1 1 3 1 2 6 1 3 6 5 9 20 10 10 13 3 10 .`Ml! Secondary Crusli13 5 14 6 9 5 ing Wlieelei' (Minding 30 14 13 17 8 Ikiid inge Cl ind- 33 ing 13 10 8 I'aggi ug 30 j kailet icing 2 7 I hit)I'. I.Ucivl![1^ a 11 15 6 5 8 15 4 2 l.oui! inif 3 ''.her ; *11 iii:l igi.t 9 2 | Me JnLclunCe 14 2-4 (11 Taken from reference 16 () Calculated from MESA reports, references 33-43 CRMC-MAD-000054 ggitew-.. , v . -. (2) 1976 24 8 25 12 18 14 14 14 38 F i g u r e 1 0 : MEAN YEARLY IMPINGER DUST YEAR OF MEASUREMENT CRMC-MAD-000056 a greater trend for decreasing dust concentrations in mill operations is demonstrated in Figure 10 for all mill operations combined. Figure 10 also snows a greater decreasing trend in exposure whan the uncontrolled operation of loading bagged talc into box cars is excluded from the calculated yearly averages. Engineering controls for talc milling operations have improved with tune. As shown in Table 13, fiber exposure measurements have only been made since 1970. Results of the MICSK 1975 survey tend to show a reduction in fiber exposure 'when contrasted with earlier data for most operations. Radon daughter measurements have been made in the number one mine by the Mining Enforcement and Safety Administration (M.ESA) . Measurements taken in 1973 and 1976 shewed only nil to trace levels. CRJVrC-M A D -000057 DISCUSSION Results of the present industrial hygiene study and past surveys demon strate significant exposures to airborne fibers in both mine and mill operations at this facility. Electron microscopic analyses of both bulk talcs and airborne dust samples have shown that these airborne fibers are largely asbestiform tremolite and anthophyllite with airborne fibers sizes (length and diameter) consistent with those found for industrial processes using .asbestos.(-7) ay any reasonable mineralogical or physiological de finition of "fiber", one must consider tremolite and anthophyllite fibers in these talcs to be asbestiform. More than four decades have elapsed since the first epidemiological data were published demonstrating adverse health effects of tremolite talc ex posure. In 1933,. Creessen^8) published the results of a chest x-ray study of 57 workers engaged in the mining and milling of talcs containing up to 45% tremolite and little free silica. This study showed that all workers with greater than 10 years exposure had increased lung markings ranging from increased fibrosis to what was termed "second stage" pneumoconiosis. Among these 17 workers, no cases of active tuberculosis were observed. Dreesser. stated that the observed pneumoconiosis had not lad to disability. The respiratory effects cf exposures to talc containing 10% "bladed" tremolite in two Georgia talc mines and mills were reported by Dreessen and Dalle Valle in 1 9 3 5 . A total of 65 workers were given physical examinations and chest x-rays of which 1 ? were exposed for more than 10 years with only 2 having 20 or more years of exposure. Twenty two cf these workers de monstrated pneumoconiosis with varying severity. Approximately half cf the mill workers exposed to an average dust concentration cf 300 mppcf 51 CRMC-MAD-000058 were diagnosed as having pneumoconiosis with 8 having frank symptoms such as dyspnea, cough, chest pain, rales, and finger clubbing. Examination of 9 former talc workers who had been separated frcm exposure more than 3 years demonstrated pneumoconiosis in all cases with 4 cases in advanced stages causing these authors to conclude that the lung changes were per manent. Additional case studies of Mew York tremolitc talc workers were reported by Porro et.al. Fifteen pneumoconiosis deaths in talc workers were studied addition to 5 autopsy studies. Thirteen of these deaths were considered to be directly attributable to the pneumoconiosis confirming the disabling character of this exposure. These authors concluded that the disabling tissue changes were due to tremolits talc exposure. Seme calcifications were noted. Siegal et.al. (21,22) rep0r*;ed a study of roentgenological findings .among Mew talc workers in addition to an assessment of their exposures. These talcs were described as containing fibrous tremolite and ar.thophyllite and less than 1% free Si0 2- A total of 221 talc workers in three mines and five mills were given chest x-ray examinations. Of the 221 men examined, 32 showed marked fibrosis. Those workers with 10 or more years employment de monstrated an incidence of fibrosis of 29.9% whereas those employed for more than 30 years had a fibrosis incidence of 74%. This fibrosis was described as disabling and often accompanied by dyspnea, cough and fatigue. "Talc plaques" were identified in 6.3% of the workers examined. These authors described the fibrosis observed as resembling that seen among asbestos workers 52 CRMC-MAD-000059 t h !P The 32 cases of pneumoconiosis identified by Siegal et. al. '^ ) were followed prospective!/ by Xleinxaid e t . a l . I n the 14 year period a f t e r the Siegal study, 19 of the 32 workers died with the ages at death rang ing from 48 to 94 years. Four of these 19 deaths were believed to be sii directly attributable to talc pneumoconiosis. One death due to pleural | mesothelioma was reported. Medical examinations of the 13 living workers i were performed including a physical examination, chest x-ray, EXG and peripheral blood studies (Hgb, R3C, WEC, Diff Count). Dyspnea was found in all workers of such severity as to limit ordinary physical activity. Moderate to severe progression of lung x-ray findings were seen in 10 of these workers and "talc plaques" were seen in all but one worker. Six out of 1 1 demonstrated an abnormal electrocardiogram. Peripheral blood findings were not considered of significance. These authors also reported the presence of "asbestos bodies" histologically. Similar findings were reported in a latter study of six pneumoconiosis with autopsy studies. A comparative clinical and environmental study of workers exposed to fibrous and non-fibrous talcs in Mew York State was reported by Messite et.al.^2^ Three talc operations in St. Lawrence County (fibrous) and one operation in Lewis County (r.on-fibrous) were selected for study and a total of 299 workers were given physical examinations and chest x-rays. Among miners, the incidence of pulmonary fibrosis was low for both the St. Lawrence and Lewis County cohorts; however, the mean duration of exposure was only 12.7 and 10.3 years, respectively. Among millers, the incidence of fibrosis was 12.2% and 4.3% respectively for the St. Lawrence and Lewis cohorts. Exposure levels in the plants were described as being similar with all talcs 53 0()(X60 having a low free silica content. These authors concluded that both typesof talc were cap tbie of producing pulmonary fibrous although the trenol-ite (fibrous) variety was more pathogenic. In addition, these investigators stated that no oases of fibrosis was found in millers of either talc variety whose average exposure was less than 20 rr.ppcf or whose duration of exposure was less than 10 years. In a follow-up study, Kleinfeld et.al.^2) made additional comparisons, includir lung function, between the St. Lawrence and Lewis County Mew York cohorts \ d e s c r i b e d a b o v e . Thirty workers exposed to fibrous and 13 exposed to nonfibrous talcs were given chest x-rays and pulmonary function tests. Dyspnea was present in 16 of 30 workers in the fibrous talc exposed group and 6 of 13 in the nen-fibrous talc exposed group. Abnormal auscultatory findings (rales, rhonchi, wheezing) were found in 8 of the 30 workers and 6 of 13 workers exposed to fibrous and non-fibrous talc, respectively. The incidence | of pulmonary infiltration as seen in chest films v/as 13 of 30 for the fibrous group and 3 of 13 for the non-fibrous group. Both groups showed pulmonary function changes with 4 of 13 workers in the group exposed to non-fibrous talc A and 14 of 30 v/orkers in the group exposed to fibrous talc shewing significantly reduced vital capacity. Exposures to both croups were considerably in excess of 20 mppef. Several additional studies of lur.g function have been conducted among talc workers in Mew York State. '22'2^ Kleinfeld et.al. --26) studied the lung, function of sixteen tremolite talc workers who ranged from 39 to 69 years of age (mean age 54.8 years). All had been exposed to talc dust in milling operations for 10 or more years and had no previous occupational dust CRMC-MAD-000061 exposures. The clinical examinations showed 14 of the 16 workers studied to have dyspnea on exertion, 10 had rales or wheezing and clubbing of the lingers was found in 6 workers. Increased lung pulmonary infiltration was noted in the chest x-rays of all workers studied and cardiac enlargement was noted in 5 of these 16 workers. The lung function studies showed 7 of 16 to have reduced vital capacities and one worker was found to have a lung function consistent with restrictive lung disease. The.mean duration of ex posure for these 16 workers was 20.4 years and the mean weighted average exposure was 63.9 mpccf. Thirteen of the 16 workers studied gave a positive smoking history (20 cigarettes per day for a minimum'of 5 years). In a subsequent study Xleinfeld(27) performed similar studies as those describe above among a group of 43 tremolite talc workers and 41 controls of similar age and smoking history. In the talc cohort, 29 had dyspnea versus only 2 in the control population. Eleven talc workers gave a history of chronic ? sfi cough and none in the controls and 8 talc workers showed finger clubbing whereas no clubbing was noted among controls. Sixteen of 43 talc workers had positive x-ray findings of pulmonary infiltration and none in controls and, in addition, reduced vital capacity was found in 13 talc workers and I one control. These talc workers had a mean exposure duration of 19 years and a weighted average exposure of 62.3 mppcf. J i . 4 A study of chest x-ray findings and clinical symptoms among miners and millers | at the Gouverneur Talc Company, number one mine and mill has been reported by Kleinfeld et.al.^-6^ Thirty nine workers with a mean exposure of 16.2 years (range 11-22 years) were studied in addition to 41 controls who lived 55 CRMC-MAD-000062 in the same geographic area and who were of the same sex and mean age but having no occupational dust exposure. Dyspnea was present in 23.1% of the talc workers versus 7.3% for controls,a finding similar to that seen in anthophyllite asbestos workers. One worker studied was said to have radiologic findings compatible with pneumoconiosis whereas no cases were found among controls. These authors suggested that talc containing tremolite and anthophyllite may be less fibrogenic than chrysotile or amosite asbestos at similar exposure levels and exposure duration; however, these authors did not preclude the possible existance of pneumoconiosis among these workers as no lung function studies were conducted. Although the above studies have demonstrated the presence of pneumoconiosis among tremolite talc miners in Mew York, these study designs were insensitive for detection of carcinogenic risks. However, two retrospective proportional mortality studies have demonstrated an increased risk of cancer of the lur.g and pleura among these workers.(2,3) The initial study by Kleinfeld et.al.(3) included 220 talc miners ar.d millers employed in 1940 who had 15 or more years of exposure to talc dust in addition to those who achieved a minimum of 15 years of exposure between 1940 and 1965. Among this cohort there were 91 deaths of which 10 (1 1 %) were due to malignacies of the lur.g or pleura whereas only 2.9 (3.2%) were expected. In addition, 23 deaths were due to pneumoconiosis or its complications. Cne of the respiratory cancers was a fibrosarcoma of the pleura. In a subsequent follow-up study, Kleinfeld e t . a l . ^ extended the observation the previous cohort from 1960 to 1969. This cohort consisted or 260 workers. 56 CRMC-MAD-000063 among which there were 108 deaths. Thirteen of these deaths (12%) were due to respirator/ cancer whereas only 4 (3.7%) were expected. Twenty nine deaths were due to pneumoconiosis or its complications. These authors analyzed mortality patterns by 5 year intervals between 1940 and 1969 .and concluded that the respiratory cancer risk approached expected values after the period 1960-64. The validity of this conclusion must be questioned as an analysis of mortality in relation to cancer latency was not undertaken. In addition, the limitations of proportional mortality studies in the presence of an elevated pneumoconiosis risk are now well known. An excess cancer risk has been demonstrated among workers exposed to anthophyllite asbestos. ^ Kiviluoto and Meurman studied 1,092 anthophyllite asbestos workers who had worked for more than 3 months between 1936 and 1367 and compared cause specific mortality with rates for Finland. In addition, chest x-rays where read for 252 living workers. Twenty one lung cancers were observed whereas only 12 were expected which was statistically significant. Thirteen of these lung cancer victims had been exposed less than 10 years and only one of these cases was known to have asbestosis. Mo pleural or peritoneal mesotheliomas were observed. M u r m i n e n ^ ^ has also reported on the mortality experience of anthophyllite asbestos workers in Finland. This study included 1020 workers who had been employed for three months or more from 1926 to. 1966 and followed until 1963. Expected cause specific deaths were calculated using Finland national rates for 1951-1964. There were 224 deaths in this cohort whereas 204 were ex pected with a mean age at death of 53.4 years. Twenty five deaths (12%) CRMC-MAD-000064 had asbestosis as an underlying cause and, in addition, there was a highly significant excess risk of respiratory cancer (13 obs. versus 6 exp., p<0.01). Mo mesotheliomas were detected. The mean latency between first exposure and death due to asbestosis was 19 years. One of the most comprehensive studies of mortality and morbidity among anthcphyllito asbestos workers was.reported by Meurnan A cohort of 1092 workers who had worked at least 3 months between January 1936 and June .367 was obtained from two mining operations; one of which produced anthophyllite asbestos and the other produced mainly trsmolite talc. For calculation of expected age, cause specific deaths, proportional rates for Finland were used for 1958 which was the median year of death for these workers. In addition, a control group matched for date of birth and sex was chosen from a local population registry. Of the 1092 employees, 248 deaths were observed. Thirteen deaths due to asbestosis were observed for the cohort and none in the controls. Twenty one lung cancers were observed in the worker cohort versus 13 in the control group. The most significant cancer risk was observed in those with ten or more years of exposure. These authors adjusted lung cancer rates for smoking habits and concluded that a non-smoking asbestos worker had a re lative risk of 1.4 whereas the smoking asbestos worker had a relative risk of 17.0. Mo cases of mesothelioma were reported. All of the above epidemiological studies of workers exposed to fibrous tremoli or anthophyllite have demonstrated an excess risk of both pneumoconiosis and lung and pleural cancer. No evidence of an excessive risk of mesothelioma CRMC-MAD-000065 a _-,uch exposed workers has yet been demonstrated; however, an excessive hence of pleural changes including pleural calcifications have been ob~ ad in chest films. CRMC-MAD-000066 CONCLUSIONS AND RECOMMENDATIONS Resulto or the present industrial hygiene study show numerous operations in both the number one mine and mill to have excessive exposures to air borne fibers. Analyses of both bulk talcs samples and airborne dust samples by analytical electron microscopy have shown that a majority of these fibers are asbestiform tremolite and anthcphyHite. Based on these studies and on exhaustive review of the epidemiological literature concerning health effects of such exposures, it is concluded that immediate corrective actions to re duce exposures must be taken as recommended in the Progress Report issued on May 25, 1975. Specific actions include the followingi 1. Mine ventilation should be evaluated with considerations for increasing air volume and distribution. Water sprays should be installed at the ore pockets. 2 . Curing the present study, numerous leaks were observed at material transfer points within the mill. More emphasis should be placed on maintaining equipment in proper working order. 2. At the packing stations, ventilation improvements are needed. Local exhaust hoods at these machines are located too far from the filling spout to be effective. Hood designs at these machines should be further evaluated. In addition, bursting bags at these stations are a significant source of exposure? therefore, use of bags with a greater bursting strength should be considered. 4. Until ventilation and work practice improvements are made and asbestos fiber e>:ccsures reduced to acceptable levels, employees should be provided with respiratory protection as specified in the OSHA asbestos; standard. CRMC-MAD-000067 60 5. All provisions for medical examinations specified in the CSHA asbestos s t a n d a r d ^ should be followed. The asbustiform mineral contone of products from the number one mine and mill make it imperative that these talcs be labeled with the OSHA warning label. CRMC-MAD -000068 61 REFERENCES 1. Ross, M. Geology, Asbestos, and Health. Environment Health Perscect. 9: 123-124, 1974 2. Kleinreld, M . , Messite, J. and 2aki, H. Mortality Experiences Among Talc Workers: A Follow-up study. Journal of Occupational Med. 15, Mo. 5: 345-349, 1974. 3. Kleinfeld, M . , Messite, J. and Kooyman, 0. Mortality Among Talc Miners and Millers in Mew York State. Industrial Hygiene Review, Mew York Department of Labor. 9: 3-12, 1967. 4. Peter J. Bernnan versus Borg Warner Corporation, Plumbing Products Division. GSAHRC Docket Mo. 10757, Richland'County Administration Building, Mansfield, Ohio. Complaints Exhibit Mo. 19, April 2, 1975. 5. Criteria for a Recommended Standard: Occupational Exposure to Chrystallire Silica. U.S. DHEW, CDC, Maticnal Institute for Occupa tional Safety and Health, 1974. 6 . Criteria for a Recommended Standard: Occupational Exposure to Asbestos. U.S. DHEW, CDC, Mational Institute for Occupational Safety and Health, 1972. 7. Gillam, J.D., Dement, J.M., Lemen, R.A., Wagoner, J.K. and .'archer, V.Z. Mortality Patterns Among Hard Rock Miners Exposed to an Asbestiform Mineral. Ann. M.Y. Acad. Sc. 271: 336-344, 1976. 8 . U.S. Department of Labor, Occupational Safety and Health Administration. Occupational Safety and Health Standards. Federal Register 39: Number 125, June 27, 1974 as recoded, May 28, 1975. 9. Ortiz, L.W. and Isom, 3.L.: Transfer 1 of Membrane Filter Samples. Amer. Ind 1 0 . Rohl, A.M., Longer, A.M. , Selikoff, I.. Bowes, D.R. and Skinner, D.L. Consume. and Chemical Characterisation. Jour. Tox and Zr.v. Hlth. 2: 225-294, 1976. 11. Snedecor, G.W. and Cochran, W.G.: Statistical Methods. The Iowa State University Press. 6 th Ed., 1967. 12. U.S. Department of Labor, Occupational Safety and Health Administration. Notice of Proposed Rulemaking, Occupational Exposure to Asbestos. Federal Register, October, 1975. Docket Mo. 11-033. 62 * K * -r CRMC-MAD-000069 REFERENCES 13. Pask, J.A. and Warner, M.F.: Fundamental Studies of Talc I. Con stitution of Talcs. Journ. of the Amer, Ceramic Society 37 No. 3: 118-123, March 1954. 14. Ross, M . , Smith, W.L. and Ashton, W.H.: Triclinic Talc and Associated Amphiboles from the Gouverneur Mining District, New York Amer. Mineralogist 53: 751-769, May-June, 1968. 15. stemple, i.s. and Brindley, G.W.: A Structural study of Talc and Talc-Tremolite Relations. Journ. of the Amer. Ceramic Society 43 No. 1: 34-42, January, i960. 16. Kleinfeld, M, Messite, J. and Langer, A.M.: A Study of Workers Exposed to Asbestiform Minerals in Ccrmerical Talc Manufacture. Env. Research 6 : 132-143, 1973. 17. Lynch, J.R., Ayer, H.E. and Johnson, D.L.: The Interrelationships of Selected Asbestos Exposure Indices. Amer. Ind. Hyg. Assoc. Journal 31: Sept.-Cct., 1970. 18. Dreessen, W.C.: Effects of Certain Silicate Dusts on the Lungs. Jour. Ind. Hyg. 15 Mo. 2: 66-78, March, 1933. 19. Dreessen, W.C. and Dalla Valle, J.M.: The Effects of Exposure to Dust in Two Georgia Talc Mills and Mines. Public Health Reports 50 No. 5: 131-141, 1935. 20. Porro, F.W., Patton, J.R. and Hobbs, A.A.: Pneumoconiosis in the Talc Industry. Amer. Journ. of Roentgenology and Radium Therapy 47 No. 4: 507-524, 1942. 21. Siegal, W., Smith, A.R. and Greenburg, L.: The Dust Hazard in Tremolite Mining, Including Roentgenological Findings in Talc Workers. Amer. Journ. of Roentgenology and Radium Therapy XLIX: 11-29, 1943. 22. Siegal, W., Smith, A.R. and Greenburg, L . : Study of Talc Miners and Millers. Industrial Bull. 22: 3-12, 1943. 23. Kleinfeld, M . , Messite, J. and Tabershaw, I.: Talc Pneumoconiosis. A.M.A. Archives of Ind. HLTK 12: 66-72, 1955. 24. Messite, J. , P.sddin, G. and Kleinfeld, M. : Pulmonary Talcssis, A Clinical and Environmental Study A.M.A. Archives of Ind. Health 20: 408-413, 1959.25 25. Kleinfeld, M. , Giel, C.P. , Majeraor.owski, J.F. and Messite, J. ; Talc Pneumoconiosis: A report of Six Patients with Post Mortem Findings. Ind. Hyg. Review 6 : 5-29, 1964. 63 CRMC-MAD-000070 REFERENCES 26. Kleinfeld, M . , Messite, J . , Kooyman, 0. and Shapiro, J .: Pulmonary Ventilatory Function in Talcosis of Lung. Ir.d. Hyg. Review 7: 14-23, 1965. 27. Kleinfeld, M. , Messite, J. , Shapiro, J. and Swencicki, ?.. : Effect of Talc Cost Inhalation on Lung Function. Ir.d. Hyg. Review 7: 25-36, 1965. 28. Kleinfeld, M.J., Messite, J. Shapiro, J ., Kcoyman, 0. and Swencicki, R . : Lung Function in Talc Workers: A Comparative Physiologic Study of Workers Exposed to Fibrous and Granular Talc Lusts. Ind. Hyg. Review 7 No. 1: 3-13, 1365. 29. Kleinfeld, M . , Messite, J . , Shapiro, J . , Swencicki, R. and Sarfaly, J .: Lung'Function Changes in Talc Pneumoconiosis. Journ. of Occup. Med. 7 No. 1: 12-17, 1965. Kiviluoto, it. and Mauraan, L. j Results of Asbestos Exposure in Finland, In: International Comferer.ee on Pneumoconiosis. Johannesburg: 107-108, 1969. 31. Nurminen, M . : A Study of the Mortality of Workers in an Anthochyllite Asbestos Factory in Finland. Work Env. Health 9: 112-113, 1962. 32. Meurman, L.C., Kiviluoto, R. and Hakama, M . : Mortality and Morbidity Among the Working Population of Anthcphyllite Asbestos Mines in Finland. Brit. Journ. of Ind. Med. 31: 105-112, 1974. 33. New York Department of Labor and Industry, Division of Ir.d. Hyg. : Report of Field Investigation, Gouverneur Talc Co., 3almat Mine, July 23, 1972. "54 Mew York Department of Labor and Industry, Division of Ind. Hyg.: Report of Field Investigation, Gouverneur Talc Co., Balmat Mill, August 10, 1972. 35. Mew York Department of Labor and Industry, Division or Ind. Hyg.: Report of Field Investigation, Gouverneur Talc Co., 3alm.at Mine Sec. Crusher, July 11, 1972. 36. Mew York Department of labor and Industry, Division of Ind. Hyg.: Report of Field Investigation, Gouverneur Talc Cc., Salmat Mine, June 20, 1973. 37.. Mew York Department of Labor and Industry, Division of Ind. Hyg.: Report of Field Investigation, Gouverneur Talc Co., 3almat Mill, November 20, 1973. CRMC-MAD-000071 64 REFERENCES 38. U.S. Department of Interior, Mining Enforcement and Safety Administration: Dust Survey of the American Talc Mill, Gouverneur Talc Co., Balmat, N.y., Sept. 19-20, 1973. 39. Mew York Department of Labor and Industry, Division of ltd. Hyg.: Report of Field Investigation, Gouverneur Talc Co., Salmat Mill, July 18, 197 1. 40. U.S. Department of Interior, Mining Enforcement and Safety Administration: Moi.naraj-idu.-n to Lewis Roberts, Evaluation of Airborne Dust Samples, Gouverneur Talc Co., St. Lawrence County, M.Y., Cct. 22 , 1974. 41. New York Department of Labor and Industry, Division of Ind. Hyg.: Report of Field Investigation, Gouverneur Talc Co., Salnat Mine, July 18, 1974. 42. O.S. Department of Interior, Mining Enforcement and Safety Administration: Memorandum dated September 23, 1976, Gouverneur Talc Co., Inc, Samples, Denver Technical Support Center File HLS 3-l-6h. 43. U.S. Department of Interior, Mining Enforcement and Safety Administration: Memorandum dated February 10, 1977, Fiber Counts for Gouverneur Talc, No. 1 Mine/No. 1 Mill, 3almat, New York, Denver Technical Support Center File HLS 3-1-6, HLS5. 44. U.S. Department of Interior, Bureau of Mines Health and Safety A.ctivity: Health and Safety Report, Health and Safety Spot Inspection (Radiation), American Mine, Gouverneur Talc Co., Inc., Balmat, St. Lawrence County, N.Y., February 28, 1973.45 45. u.s. Department aS interior. Mining Enforcement and Safety Administration Health and Radiation Inspection Report, Gouverneur Talc Co., Mine No. 1 and Mill, Balmat, M.Y., March 24, 1976. CRMC-MAD-000072 APPENDIX I CTfecy Data Sheers ncral P r o d u c t Satccy For R.T. Vanderbilt Products CRMC-MAD-000073 \ ! s d e 3 1 ; S r n m - z m MINERAL PRODUCTS SAFETY DATA SHEER! NOTE, ttcosure tu ail aircome mineral ousts 'S suoiec: !o OSHA regulations m accorgance witn Section 1910.93 ol tna Cccuoanonai Heaiin and Safely Administration Stancara as ouousneo in tna receral Register ol Octocer 19. 1372. starting on sage 22139 TRACE name ano s yn o n ym s MINERAL f 4 MIL Y CHEMICAL COMPOSITION SECTIO N 1 FT FIBER N o . 1 , IT Fiber 6 N Industrial Fibrous Talc Hydrous silicates Comolex hydrous calcium mcanesium silicates material S E C T I O N II I N G R E D I E N T S A h e s t i ? n r m i o l r r' r ' i./<-.r ' ' r b ^ s t i f r m o n t h o ^ h v ! 1it* Talc - non-a:bes:iform N cn-csb estircrm trem clite cnd /or anthoohvllite - Q u artz S e rp e n tin e CClOR APPcAflANCS OTHER PPCPEPTIE S E C T I O N III P H Y S I C A L D A T A V/h!te Fibrous S P E C IF IC G R A V IT Y ( H O -1 ) % RANCE 20 - O . 5-15 40 - 60 1- 5 10-20 2 .7 MATERIAU S E C T IO N IV H E A L T H H A Z A R D D A T A A sb e sfio rm tele end asb esti Farm a n th o n h v ll ite T a lc - non-csbestircrm N o n - c :b e s ti;o rm Tremol ire and c n t h c a n v llit a Seroentine Q ucrtz 30 m g . / c u . m . ~ % Q u c r t z -r 2 *TUV 5 f i b e r s / c c > 5 M m . in 1s n a t h 20 M o ccr 20 M occi 50 M o c c i | SECTION V SPECIAL PRECAUTIONS precautions TO5"aken in wangling anOSTORING A v o id b r e c r h in c c u s . Use re s o ira fc r ir T L V 's e x c e e d e d . CRMC-MAD-000074 1975 CVgRrOrt r ' j U fHAif.PQPMA>?j VT .. -T .. _i 'i j" / i b V -, \ * L O q A,,_ fH / / i h ;r - o j n : l | u <o | !-V | ,|.}^ ; MINERAL PRODUCT* i SAFETY DATA SHEET MOTE Eisc ^r-. :o aa .ungerne rnmnrji aii-,rj 'i suonici to OSHA reuianons m accordance wnn Section I9t0 93 ot inc Occvoai'onai `temiti ano Safely Acmini^traiion Staraaro as cuoiisned *n ihe Federal Register ot Ociooer 18. 1972. starting on oage 32139 SEC T IO N TPAceMAMeA.,oiy.MCMVM3M o U L D E N E , i FIBER N o . '.NEPAL FJ'.IiL< Hydrous sii Icates Chemical COMPOSITION Complex hydrous c a lciu m magnesium silicctes Industrial Fibrous Tele MATERIAL S E C T I O N II I N G R E D I E N T S A sb estifo no trie m d / c r a sb e stiform a n th o a h v llite T a lc - non-asbestiform N an-csbesH form trem ciite and/or cnthoohyllite Quartz Serpentine CO LO R APPEARANCE O T H E R P R O P E R T IE S S E C T I O N III P H Y S I C A L D A T A W hite Fibrous S P E C IF IC G R A V IT Y { H r O --t) 0 o 1 da BANGS 4 0 - AO 5 - 5 1 -5 5-10 2 .7 MATc R'RL S E C T IO N IV H E A L T H H A Z A R D D A T A A sb e stifo r m talc and c s b e sfifo rm a n r h o o n v l l i t e T e l e - non--ashes fi farm . . Non-asbestirorm Sem entine Q u crtz 3 0 m a . / c u . m , -f- 0,n Q u c r t z 2 *n.v 5 fib e r s / c c > 5 Um 'n length 20 M pocf 20 M pocf 50 M opcf SECTION V SPECIAL PRECAUTIONS PPCaijT:Cn 3 TO EE "`Ae'E'j N mangling ano storing A void breatnina dus!'. Use resoirofer if TL'/'s exceeded. CRMC-MAD-000075 DATE. Ovfl rCN *<Ma 'vV ' ! - ' r/ rn . : p r ir r t -y i i % i .,. - i ; V ' / * :"^ l 1 0 -.v2 .u- 'J X `>.U: 1 'xO. *M>r**v-w**+,**.,**>*<<+;<" MINERAL PRODUCTSAFETY DATA SHEET I NOTE. Ejcosus 10ai aireme mineral cuss 13 suciecl 10 CSHA recuiaiions m accoraance wiin Saclicn ;910.93 o me Occuoaiional Mealiri ard Saiely Acmimstraiion Sancarcr as jususnea in :r.e Federal egisier ol Cc'.ooer 19. 1972. siarung on gage 22139 SECTION 1 TrlACe N A M E A N O 5 `rNC'N C M S .MINERAL ?-MiLv 'C HEMICAL C C M A C S iTICN N Y TA L 99, NY TA L ICO, N Y TA L 100HR Industrial Tale Hvdrous sil icates Comolex hvdrous calcium mccnesium silicates i U O h- MATEr-'AL S E C T IO N II IN G R E D IE N T S N o n -a s b e s tifc rm rre m o lite e n d /o r c n fh o o h y llte S e roe ntin e Q u a rta % BANG6 20 - 30 50 - 70 20-30 1 -5 ccLOn APPEARANCE o t h e b p b c p e b t ;3 S E C T I O N III P H Y S I C A L D A T A W hite Powder SPECIFIC GBAVlTY (HjO - I) ir?, fi V1ATEBIAI S E C T IO N IV H E A L T H H A Z A R D D A T A T a lc N o n - a s b e s f i f o r m t r e m e ir e r a a n t h o c h y l ' i t e Sem entine Q u artz > 30 m a ./c u .m . -- % Q uartz 2 SECTION V SPECIAL PRECAUTIONS AR^CAuTlCNS TO tE TakcN n .-anCL'NG ano STORing Avoid breaming dust. Use resoiraror if T L V s exceeded. date M . ! 10~-, . . . A .. *TLV 20 M pocf 20 M a scf 50 M oocF CRMC-MAD-000076 ---- ----- OVER rGH tMA f  *rV* ' HC I u t C 'O H ill: <<) .il ...iDOrne Tuni.v.il <Ju',i "i is luO|i!Ct to O S H A n jq u l,liio n s in jc c o rtM n c o w ild S o clio n 101 0 '.)'J o l Idi} C c c u 0.1 li0 n .il H fM lin ,111(1 Gli.'iy A n rn .n iilr.iiio n s M n cnrd .is c u o usned n '|> ; r i d e r a i PeqtS ler Ol O c lo u c r 18. ! 9 '2 . SMrtm q o n can e material SECTION II I N G R E D I E N T S Tnlr Non-csbestiforrn tremol ite cn d /cr anthoohyllife Sementine Quartz RANGE 20-40 . 40 - 6 0 20 - 30 1- 5  .. ,,/ - ri < i : ' ' I s' I J ( V ( 2-1 ' 11 I \ - ; n i I ' .I n * > I MINERAL PRODUCI' SAFETY DATA SHEET T , NOTE Eirosure 'c jii j'iootne nmerai Cuzts suolaci io OSHA rooui.ificns m occarrionct; won Section i9iQ 93 ot ;ne Cccuoationm nLMi:n .nn., Solely Anmimsirjn c n Slonaorn as -u.-.tisnea >n trie rosemi Resister oIOctober !3. 19TO. stoning on poco 39139 SECTION I TRACE NAME a u Q 'YMCNYMS M,NEPAL H'1,1 Chemical composition CERAMITALC 1QA, CERAMITALC HPT_________I n d u c i c i Talc Hydrous sil icoles Complex hvdrous colcium mccnesium silicates M A T ER IA L SECTION IIINGREDIENTS Talc N op -fcbesfforrn Tremol'fe cpd/or cntbopHvl 1ite Serpentine Q ua rt: N RANGE 20 - 30 50 - 70 20 - 30 1- 5 i 11 ! cr q O u appearance SECTION lit PHYSICAL DATA V/h rte Pov/der SPECIFIC GRAVITY iH.Q-i) 2.8 MATERIAL SECTION IV HEALTH HAZARD DATA Ta<c Non-csbesrircrm rrerr.clIfe end cnrboor.yllite Serpentine ________ Q u c r ir :________________ 3 0 m a . /e u . m . b* o G u c r f z - 2 * SECTION V SPECIAL PRECAUTIONS PRECAUTIONS -J : : - i . E * I ,n - j n CLING a; jO STORING A v o id breafp.ir.o dust. Use re scircto r if T L V ' s e x c e e d e d . O a 7 c M a y 1, i 97. * tlv 20 M oocf 20 M ppcf 50 M ppcf . C R M C -M A U -U U U U / * NOTH E c c iu it* toa.t dircom e o ils is suOiect to OSHA mouianons in accordance wiin Section 1910 93 ot me Occuoationai H eaitn ana Safely A rtm iri',tf;)u-,n Stono.jro .is ccr usned m me re c e la i Angt$ter ot Cctcoor 19, 1973. starting on oage 33139 SECTION rwAce name Ano Sy.CNrt.rj CERA.ViITALC N o . 1, CERAMITALC 1 0 - A , IT 3X MINERAL f**M iL < CmCMICaLCC`-1 ai7>QN Hydrous Silicctes _CA] plex hydrous ccl .3i un ngyposiu m si I lent' e<_ Industrial Talc MATERIAL SECTION II INGREDIENTS Talc Non-csbestiform trerrtol its cr.d /cr c n fn o o h y llite Serpentine Quartz % RANGE 20 - 40 40 - 60 20 - 30 1- 5 COLOR APPEARANCE OTHER PaCPSSTIES SECTION III PHYSICAL DATA White SPECIFIC GRAVITY (H,0-t) Powder 2.8 MATERIAL SECTION IV.HEALTH H A Z A R D DATA Talc Non-csbesri form Tremai Ire one c n rh c o n v llite Serpentine Quartz 30 m g . / c u . m . -- % Quartz x 2 SECTION V SPECIAL PRECAUTIONS T.G*<j O zE N A.*;0 3"CRINC1 A v o id b re a th i r a d u st. U se re s p ira to r i- T L V ' s e x c e e d e d . *TLV 20 M o o c f 20 M ppcf 50 M ppcf c m c - ^ 000079 MINERAL PRODUCT: SAFETY DATA SHEET* NOTE E^poSu.v? to mi mrcorne rrunerji Ousts suGiect !o OSHA nguiai'0ns maccordance wiin Section 1910 93 of ?n#C ccuoafon.u Hcnitn .utci Safety Administration Standard ,is cuansned m tne rderai Remisier of Cctooer 18. 19rii. starting on once 139 trace amc a',-b MINERAL ?am;i.v CHEMICAL CCMPCS'TCN SECTIO N 1 i X , (T 3 X , IT 5X, IT FT, IT 325, IT 625 Hydrous Silicates Complex hydrous calcium magnesium silicates Industrial Talc o o 1 o -R i_____ matriau S E C T I O N 1! I N G R E D I E N T S T a lc N o n -c sb e sti farm tremolio a n d /o r cnfho o hvl ! ite S erD en tin e Q u arta ........ col on appearance OTHER PROPERTIES S E C T I O N III P H Y S I C A L D A T A White Powder SPECIFIC GRAVITY ,m,0.11 ..M l 2 0 - 40 20 - 30 1- 5 2.8 MATERIAL Talc S E C T IO N IV H E A L T H H A Z A R D D A T A N o n - a s b e s t i f o r m f r e m e i i f e e n d e n f h o p h y l !i t e Serpentine Quartz 30 ma./cu .m . ~ % Quartz - 2 irTLV 2 0 f'Appci 20 M oper 50 M p p c f SECTION V SPECIAL PRECAUTIONS FFECAunCN-j ;c 2" -'-I -anci :NG a.0 57CSINO A v o id b recfh in o dust. Use resoirofer if T L V s e x e s e d e d . --------------------- =---------------------------------------------------------------------------CRMC-MAD-000080 ' APPENDIX I I 2 Results of Individual Air Samples And Summary Statistics for NIOSH Industrial Hygiene Study CRMC-MAD-000081 J n H oic 1!-'./r C-.OE ji.u m u t .... .......- --- 11u1 ; >.t i n i - 1s 0 1 <l' S*f. l'i*'( M*1lH 0 I ') 5 fi 10u j CP<Pl't P M4H 01os ll'.Ol bGuUUM) HBUHtH t 106 0>' !U t w n 107 fi 1i H(i:.0 Oh1LI tH 0 1Oh b*I 5E BUYING mAUUnE qPtHATUH 01Oq Kii.sf ntwi'.u HALHir;t .ELPtH 0110 11.r.WGOUtKiO HUI i IAU o i 11 ii f 5 r **< 0| 1 n\r>t wG^uUno 3KICK CLfMK Oi1 } S u m i m u r 1I u El"CU M*'(MUCntM) i c r M C -M A D -00 00 83 D'i|H S UNDERGROUND SUPERVISOR rn HEr.ui.AU and control n o me m a t e r i a l CRi i Sh i hg C I RC U I T It n IE3. from crude ore p a c k e t TO T ? h s t o c k P I U S through Tor OR L O i O l N t t PA f I L L S l)R CARS w i t h b r o k e n ore or t r a n s p o r t s T(| AS DI RE C T E D . ha ste from d r i f t s , r a i s e s or s t o r e s and ORE POCKETS,ORE PASSES nH OTHER PLACES - - - ............. .............. LOAD ORE INTO TRAM CARS PEREUHH3 r.fne RAL LABOR work s uch as o i r . G i N r . , s h o v e l i n g , c l e a n i n s d r i f t s , h a w ol INO T I M B E R , H I N t StlPPL IE 8# T C , ........... ................. .... ............ -------------- OPERATES ALL RtOUlRED D R I L L EOUTPMENI a n d h Ov ES E O U I P h ENT I n AND OUT OF-- - BL A S T I NG AREA TO OPERATE D I A h o n D CORE - - .... - D R I L L FOR D R I L L I N G TEST AND BLAST HOLES.' ............ ............ HOVE, SET UP AlH> OPERATE ... . RAI SE BORING MACHINE TO b u l l h o l e s .' ..........____________ m A S 3 I S T RAI SE B O R I N G ___________ _ _________ _______ MACHINE OPEN ATOR TO mOv E , S T Up ANO OPERATE HACMJn E.,' Tfl OPERATE HOI ST AND RELATED EOUI Ph L u T OURTu G k Jh j E WORK a >(0 SHAFT DEVELOPMENT TO OPFIIATF HOIST LOWER OH Ha I SE c a g e a n d SKI P a s s i g n a l e d a n d o p e r a t e m i n e A I R COMPRESSOR RESPONSIBLE f OR R E C E I V I N G , RECi a ! m ! n G , R P A lH,5TOf AG a n D COn 5 I C n h EMT Of hIE u n d e r g r o u n d STOCK EQUI PMENT , Pa HTS e t c . ' , a n d PREPARES and c osig ns d a il y explosive s u p p l ie s PROCURES AND D I S T R I B U T E S THE SUPPL I ES NECESSARY F()R thf. o p f r a t i o n s u r f a c e a n d UNDEHGHOUHO mBHKI NGS- . . . . of the h INE . --------- . -- LOADS HROKEN ORF F R . ORE poc kets in t o tram cars using t man l o a d in g m ac hine -- j m9 OICHU' IA c.C l Jl.M H I L E n i IS 0^0 1 " III < ) P ' ) - ILLEH i<) )5 r.l '-I<*At t 1 ........... H I,,jIj -A1J5*-1 ^ r, p ) s f u t Lf K*1' I un ( 't'f K* TOp npOo Ii**llj|-(GL Uf'tHAlUH Ip 0 / r e l i e f SS A H UHtMAlU r.p (M El EM l/HE HA ll)H |^u<5 I'lCK'H n p i o p C " hI)USE u l i t l i v haw )?l l PSt Rf H i>EHVlCtM*N om its -- (rjMcn MACHjNf} OPERATES THE COMBINED CAGE ANO S K I P i n TRANSPORT HN, MATERI AL AND i OUJ PMENT TU An d f h Oh S" t f FACE TO UNDERGROUND STATI ON LE.VELS AND I H HAUL AGt UF ORE OR WASTE FROM or e POCk T4 TO S U - - FACE SUPERVISES MILL GRIND ING,OQTInG anD product blending g e n e r a l HILL work e h i n P E R f o i m ALL, TYPES OF LABOR WORK A3 ASSI GNED I N AND ABOUT THE H l U AN BU I LD I N G YAROS* -- OPERATES i n f DRYER, .......... - - ------- ------ ---------------- - SECONDARY CRUSHERS AND ALL A U X I L I A R Y EOt I JPHf NT I N THE s e c o n d a r y CRUSi ' E r a r e a t o d r y a n d REDUCE th e ORE i n S U E fur THEIR PROCESSING i n SERVICE P a c k a g i n g OPERATION UT O P T R A I I r G F - K EQUIPMENT a n d TO L f l A O BULK PRODUCT ! N | U DESI GNATED CARRIER Tn n P f i i a i e The u a RDINGEGRI NDI NG H11 l S , S P A RA TOR3 #A l P I n E C L A S S I FI E R S AND ASSOCI ATED F DUJ PHENI to PRODUCE E I N I SM E D PRODUCT a n I n t e r m e d i a t e p r o o u Ct fo r u s e -as f e e d to o t h e r I TUNS ALL no s e c . OPERATES THE M I L L a i r _ .. COMPRESSOR,ALCORN h Ea TR#AND ALL AUXI LI AR Y I n t h e PHOCFSS A I R a r ea EQUIPMENT OPE R ATE S IMF H O F E L t R m 11L GRI NDI NG E OU1P mNT THE DUSTt X CYCLONE ASSOCIATED EOUJPHfNl ..................... AND ALL - ------ OPERATES The S E H I - A U T O HATIC Packer and l o a d s BAGGED,f i n i s h e d RAI LROAD CARS a n d TRUCKS PRODUCT I ------ TO SERVI CF PACKI NG -- -- -- OPERATI ON BY M A I N T A I N I N G b a g s u p p l y o p e r a t i n g L I F T T R U C K , an d A S S I U N G I N OTHER SERVI CE O U I I E S I THE PACKHnUSE A3 DI RECTED ........... - - - -- ----------- TO SERVI CE PACKI NG AND CHECKING WEIGHT OF BAGGED, F I NI SHED PRODUCT - -----OPERATION BY M A I N T A I N I N G AND S T E N C I LL I NG PAG SUPPLY jnH oicltUN*r c ..f) JHH T IT L E ' - n p I 2 i ` a Cs w' l uS E f u P t H<,,< rJ?]j Fuu, [I* 1 '.Htrt*liJP/TO" UUTOW UPfl OPtu r * u L I '' t u f,p IS | S i/C H D l< I V t K o p I6 slot* C i t a * - - c p W ^ U ' i C I L ` " U CHELKx E I G h h AH f,;> i n s . i f wv I j i ' i UP I ' . V I M i j i i Y CUMIPUL n p I y r L l f l i `' -. 1 * PWUCLSb U P f P ^ T U H u l * c*-< L' Jaoeh O jf) I 6 t P ! `i * ' * ' * ( Ml ,<t) Pt a * I h ` U>. 5 u t l P E * n p l a Ck s ' 1I I k (ilUu `'lIM'`,'Ct PtCHAXId r>i&s " Us i l e t u u i p p i x i k e c m a u i c I CRMC-MAD-000085 DUTIES '! < SUPERVISES Talc b a g g in g Do n a t e s THE TUM HflTUR AND m a i n t a i n s wiMsEHOUSE I NVENTORY RECORDS P f l t p AM3 EMPTY RAILROAD CARS AND t r u c k s e i i h LOADI NG a n d PREPARES COMPl ETED CARS FOR SHIPMENT ...................... _ l) PEWATt S SERVICE VEHICLE in transport various materials in AREA, LOADS AND u n l o a d s VEHI CLE OR o u t s i d e p l a n t ------ RFSPIJNSIIILE FOR H E C f l V - . _ - ... . I NGSTUR I n G a nd CONSIGNMENT OF EOUI Ph En T , S l l P P l I f 3 AND SPARE P A R T S , E T C , ' , AND ASSI TS I N M A I NT A I N I N G a d e q u a t e s t o c k l e v e l s ()E SUPPL I ES a n d SPARE P A R T S ................................. LABELS TALC BAGS- SMlPBf N PROPERTY CONTPOL LOADS TALC I NTO R A I L OU* LK CARS USI NG PNLUHATI C F I L L I N G S Y S T E M ...................................... . TO M A I N T A I N AND REPAI R H t n E F o u l P m F NT SUCH AS TUGGER Hf11 S T3 , AND t NS T A L L * ------------ c o n s i h u c t an d r e p a i r v a r i o u s wood and c on cr et e s t r u o URES TO ASSI ST THE REPAIRMAN a n o m a i n t e n a n c e m e c h a n i c i n THE A T I O M , m a i n t e n a n c e an d REp Al r nF EQUIPMENT CONSTRUCTION,INSTALL m ! n E m A C H U E r v An O --------- i n f o r g e , h a m m e h - k E.l d , -- h e a t t r e a t a n d FOSE BY w e l d i n g H T a L m* t e B I a L 3 R f - 0111RI n I n 1he C O N S I RU C T I O N , m a i n t e n a n c e a n d I k e sur f a c e and i i n o e Rgruumd m a c h i n e r y a n d f o u i p m f n t --------- perform the l a y o u t , A S S E M B L Y , I N S T A L L A T I O N , R E P A I R AND HATNTt NANCf f)F MINE - - SURFACE a n d u n d e r g r o u n d m a c h i n e r y , EQUI PMENT a n d wood WORK r ONSTRUCTI OH INSPECT,TEST,ADJUST* DISMANTLE a n d REPLACE m a k E COMPLETE REPAIRS POWERED EQUIPMENT UNI T ASSEMBLI ES UR PARTS*.! TO GASOL I NE, ELEC1 RJ C ANO D l f S E t - Me f (1,(1 Jl<n ! I n. HuOI. Hiu-wll-"! 0 (J n 2 \ t.s f o u ^ t ' lut j i,|o ir |isT Fli fl u 0 u 1 1 1' [ H * >> < M 1 1 L ) 0u0 JLL *'> I<"t 'ILf'ttt r ^ ^f'f J mt U L - - - f't.07 *)(.** L Tv CiiMWUL U C . . . t ,..i* ru. i) 9 i ` I C*' ICI*. . i j S I I a s ! I. * a U C H M C I M f.u I a M i l 0 (|jt| SOI kilD I F l f C T M l C U . *N L EC TH I C APPRENTICE r>SQZ J i s l m os<M E t o f f l OUT I f S - KOt l i, ------------- ---------------- ------- ---------------- --------------------- TO I N S P E C T , R E P A I R , R E * PlACF. . I N S T A L L , a d j u s t and M A I N T A I N I L L HECHA41CAI EQUIPMENT i n THE MILL - - TO I N S T A L L , R E P A I R , C A L - - - ---------------- J R R * T F , T L S T AND ADJUST ANY TYPE OF I N T E G R A T I N G , I N D I CA J IMG,OR GRAPHIC ELECTRI CAL HR MECHANI CAL I N STRUMENT ... ----------- TO LAY OUT W(|Rk , SET UP AND OPERATE MACHINE TOOLS,AND PERFORM I nt. , ( 11TI N(i UR a 5SE H5L T WORK REQUIRED TENANCE 0 c u ' i s T R U c r i n N ANY FOR D I S M A N T l " --------PLANT MAIN JNSPtri,REPAIR,REPLACE, I NSTALL ,ADJ UST and MAINTAIN ALL MECHANICAL EQUIPMENT I N THE M i l L --------------------------------------- ----------- ------------ A S S I S T Til I NS PE CT . R E P A I R R E P L A C E , I N S T A L L , A D J U S T AND M AI NT AI N ALL MECHANI CAL---------EQUIPMENT I N THE MI LL TO PERFORM ANY T I N O R ------------------------------------------------------------------ --- -- SHEET METAL monk REOUIREO FOR PLANT MAI NTENANCE ANO CONSIRUCTION TAKES Ta l c 3a Mi Lts FOR LAP ANALYSIS ASSI ST IN DC ANALYSI S RESPONSi r i LL m i l THE PROPER l . UD R I CA I IUN OF ALL MACHINERY - AND L D U I P mENT --- GENERAL HELPING I N H R L to i n s p e c t , r e p a i r , ano ; WIRE ALL F L f C T R J CA L APPARATUS, DEVI CES, AND C I R C U I T S OE AMY VOLTAGE I N THE PLAN! OR A SSt CNf D A & t l I N C L U O * ----- l i e PMMfH TRANSMI SSI ON L I N E S T H i h 5 F O H M E 0 5 , AND E L * T ED fOIIJPMENT TO S h FEP An O CLFAN floor OF M I N E , H I L L , O f F I C E S , L A V A T O R I f S , C M A N G E AND D I N I N G ROOMS AmD LAHOHAIORY ------------------------ --------------------- ----------------------- TO PERFORM ALL KI NDS OF h Fl D I n U , R R A 7 ! N G ANO CUTTING ON USI NG GAS AND ELECTRI C EL DI NG ANY TYPE OF EQUIPMENT m ETAL I ------------- J . 1 Ol t ` Cn 0 ^JjdlllLE . . (.G0q "11G] e t u 11U 1 i H t P4111fl r. i, J S .. 4 i C><M1 * n s ' ' 6 " ! '-U HI LL l f' G J *-1 f p i.f.0 1 i S S I r ( . M M4N4G t `l o0o jupf *i.11';j*<r f i , o l " I LU Si j Pt *<I '< 1 1 ' KAf . T n,,0.i r.f'tOAL magaci ii n 0S P t ^ b i ' i n L L 4M) S a F ETT f) I HEC TUH n,,o/, i * f i r t ' ` ' ` g [ k iif u i f `-r, r . t t p ,,0 r - . G I - t I E C " I C l 4 k ( O H 4 F I i H A N ) u,oq 5 r-1 ^f l sG 4 n t) l ' . v E M D V y CIIUMO [rATUH i, l I v i . >. [ ` i>( r Cu M p u l C L E mK ir.ll t r e n i ' ; . T S PAr AbLL CLEMk .. . ' t , U < ! F p | *.G CLtHn Obl i s CF I aKr .Tf.l-1 F L C E P H i J ' - l S I .............................. er. i s f i e u t C L t P n Gn l b b ' i t F I 5'1 Af' CRMC-MAD-000087 DUMES nor t t TO W f RATE MO B I L t EQUI P MENT JH VARI OUS C A PAC I T I ES SUCH A3 C l F * H C U t a A S f , DIHT and DER MIS,SM)* EHUVAL ETC, HI E -IND M I L S E C U H I I V - . ................. .............. ................... ............... O iM C r DUMES OFFICE DUMES OFFICE DUMES OFFICE DUMES OFFICE DUTIES O F F I C E DUT I E S Si-'H |>,G K/[iCI.fJ'i'U s a mp l i n g t HTi i uu a n a l y t i c a l t l c m.' GHa v I mITHIC P US T - P 8 t MF1GHT I Mp IN GEH Sample o p t i c a l MICRO, c r m c -m a d -000088 ( PICE | 9 HESPI BAf t LF h * SS S * mPLF 3 <E COLLECTED On S i POLYV I n YL CHLnt t l OF F J L TFHS CS . D U m PORE S I Z E ) w l T H FLOw 1 , 7 L I TE R S PER P I MU T E . NYLO'A C YCLONES ( I O u h ) i r f u SFD FOR S I ZE SEPARATI ON, ' FI LTERS ARE WEIGHTED TO Tk f NEAREST U . ' l H c USING A CAIlN GRAM L ECIRQBALANCF an d DU3T CONCFNTHa T KINS I l f POH TEO AS H C / H J . h t d GET I h R I N gei i Sa h PLFS i E COLLECTED USI NG e t h y l A L Cnun L AS t he COLLECTING hE O J um w i t h F l o P . M L I T ERS PER HJNUTF. AFTER DI LUTI ON SAMPLES ARE P I P E T T E D INTO DUNN COUNTING CELLS ALLOWING A TO HI NUTE SETTt ING T I H F . PARTI CLE COUNTS ARE HADE RY Two COURIERS USING BRIGHT FJELf> OPTI CAL HI CROSCOPr AT 1 0 0 X * C t i N C f NT A TTONS ARE RFPORTE0 AS H l L L I O N S OF PARTI CLE S PER CU B IC FOOT OF A I R ( M P P C E ) , ....................- ................................ - --------- ------- - 1 J\D fV 1n U `L 5 i `lPlf ^ I S U L I S ; IM c t 'ct.'i S"M Mi' >.') 7Jc4t 'IE'1'-1uijfI 1,4aVI"L 1-*IC S4--UE G`IE I I- n.`. 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I 12 4 fl 1 u ." ; I i*' II f. J > , - I X/ 1/ 75 (j.oi'ti I ? I'i I et 1t-" I I fl i >5 i*jU t I '.< 1f ') li t . - 1 I 4 <4 9 / 75 4 , ;I. 5 P I 11/U/7S 0 , b'4 lt I P5b ; , E 15 i r o * I I 40 M/ ?5 /i . : 2 n s 2,4 !uy tlu-HO ni,: ! I / X J/ 7S O.xxg 1 M n., UIJ Tl1*9 lui o 70 fl 1 U II t. U7o 7 l'iuU 1 1H 4T 125 2218 J U2S 2217 I 9 1U 22 lu i 1 f *t IG" rt 0 i u-S i tu Ji |0i n f II /U9/7S 0 , ?Sb II/i)u/75 0. y t 5 uTuO (47a J 1917 1920 i t r. i p .10-1(0 I . f . s 11/ u u / 7 5 u . 72 8 147 'iS 1921 I )7 niiu - t I 0--7f O 1 * 1 . : I |H | .,89 -tlC, -1(0 i * i , = i I / 0 * / 7S . 19 1 1) 4Uu /4 S O. x t i U UT i 1 UT i 1 1927 192b 1 I 1M. V - I f- f f n i * f . = 11/ I 11/ 7S o.uij UT i u 19 29 7 1u /^ . I O" 1( 0 ( U 11401/75 0,199 I50 2298 2* iuiS .|0-I(f) i f , ; II/oi/75 0 , 9 1S?6 2251 1 29 I ,, so -ElO-iff) * ,f.: II /01/7S U7I 9 1 >*?0 2250 I rt Iil<77 tI/u</75 U73O 128 CRMC-MAD-000090 /PUbl-t'Hf lH| VU L U ME Ml CIJNC, U. 729 1 1,132 0,8159 0,600 0.792 1.56| 0* 80Ob 0,609 0,7510 2,735 U,8021 0,009 O.bTaft 0,756 U,b78 U,ui5 0 t 67 JJ 0.720 14, 79J1 0,191 0,7190 0.960 U , 7190 0,911 O.TbtS 0,999 u . 759 0.997 0,7609 0,719 U, 71U5 0,9 1b UMTS Mr,/M j nr,/Hj hC/H J HG/H3 hG/HJ M G/M J hG/HJ hG/M3 HG/H J hf./H J MG/HJ HG/H J HG/M 3 hG/h3 HG/HS HG/H 3 1 \f> IVIIUII S*'**'1 KtSULIS *1 TJ CH - ' U C - I ^ I f,UVINt !MJc i l ! 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SANALE NAS HUUKI U UNTU INAHHEM L * K 1 0 * 1 / H I N D U S S a k P' LEN HUUM. 0 UN l U t H A f l f i i N u L H FUN 0 H l N U l t S HPPCF SCMAiPPtHHAH HULLI NG UWE (U ?0U L t V t L HPPCF 3CA&PI NG UN t DUmN I U / n o FUI L t v E L * NU w E S H I M A T u , HPPCF HP PCF . HPPCF HPPCF U R J t L I NO H l t S I NTO HOC* S I a h I I N u A l B U O U t T ANO hiI H A I nS DOWN I I * 9 0 0 FEET NO N t S P l N A l U H . HPPCF P J t J H G UP I l H t NJTH HUC*11N(i PACHINE ANO PUTTI NG I N CAAS R t S P I W A U N *>AS N i l i "UHI HPPCF HPPCF CHECKI NG I NST MUMt NT SCONVt EH * N u COLLI CTHS ON ROOF FOR 20 H I N U l t S 10 H J N U l t I N CONIHUC POUh # DU3_ THIS 2 TIMES PIN SHIFT *J, I !V "tbULI !i iM r j t " i i . ! > , / i \ : i ' 1 11 a ! 11 L " i *`J t t p i'im .t*' u r n ' l l /<>*" I l c A l I b-i 11 i 'a - i f - L i I - i . ' ) , \'i, 1 li <1 1 J i'1 11 I 1 / u3/ ?b I 1*1 (!', i it u i VllLUMt L ^ 3, UUoO CUNC. 1,013 l . 1 0 " M b A vf . - I 1'. 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OUOU 3.V26 3 , OUO .oeu 3.UUUU 3,b79 3.0000 E 1Umi D A v f . a . b o o CRMC-MAD-000094 t I 11 units MPPCF CHECKING INSTRUMENTS FUR 12 MI NUTES, I N CONTROL RUOH FOR REMAI NI NG 16 MINUTES, KUHt t S P l R A T U R MPPCF HdVl NG 3CH*R 1HUN (JUT 3 1PL MPPCF HPPCF t' R t i a S a j N G H t t UHE F HUH n u o L t V E L 3ECUNOARY C R U S H t f OPERa TUH RUNNING CHUSHER FRAME HEAD hPPCf- ATCMED U l N 3 I F T AND Chl CKEO CUNVE.YUR, 3 1 A Y E 0 - I K c o n Thol houh h i s t u f Tin t- hPPCF CHECKING INSTRUMENTS FUR 7 M J N U T t 3 , STAYED I N CONTROL HUGH FUH 2 1 H l N U f E S , N O R t &P i R A T O R .............. ............... HPPCF r e i g h i n g OUT SAMPLES AND c h e c k i n g INSTRUMENTS FOR TO TAL TIME UF JO MI NUT ES, Hi A VY EXF-OSUHE, hOM RESPJHA, MP?CF TAKI NG MUuKLY SAMPLE FCJR 3 M I N u U S , STAYED I N CONTROLRUUM FUR OTHER 25 MINUTES, MEANS H 3 P I RA 1 UK HPPCF LEAK C0HHECTI UN3 ANO I NSTHUHt NT A I ION CHECK FOR 7 MI NUTES, h Eh A I n DER 2 J H 1HUT 1 3 UUTSI DE UF CONTROL R . _____ HPPCF IN S P E C T IN G 3C * L E S , CUMPRE3 SUH ANO OUST C O L L E C T O R S ON HOOF FUR 10 H 1N U I E 3 , 20 M IN U U S IN COn THUL ROOM# MORE RESPIRATOR -- - .............. .......... , I/. J.0 IV I|nJL 5 '`'LL H t S U L | 3 p ^:; t ''Ll / - . i t i t 1 c . 1 t C *' ' 1 s o t 1 1 I" [ jMi*. 11 11 b : ` ` LI t.11 t liA 1t 1I* t Us ,, `J s i . 1 !.. r k 0 Is i -i i j : j h b t> 1 1 / . U ' * / / `j 0 . 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O U O O 1, UUU0 . -. i.O U U O .. . 2 .1 9 9 2 I2 S5 nb l.u u o u 2 .1 1 1 1 ,6 18 1 .6 1 J.6 JJ 1 .9 6 9 CRMC-MAD-000095 HPPCF hppcf HPPCF - - ......................... - ~ ~ -------------- - HPPCF HPPCF HPPCF FILLING SACKS H U M PRODUCT BY NACHINt# SEVERAL BAGS BURST DURING s a m p l i n g -------- - HPPCF HPPCF HPPCF HPPCF HPPCF WORKING At SHAFT STATION sf*nsTiC3 u c " , 1,, . K j / u . A l ' t : c - c l u . " -1 " 1 1 r, WAV 1 r. l l c /| ' U3 1-' t " t i O M T J..M C'-: , 1. i ij i ii > in 0 1 ,, 6 oi i5 4 | t IJf fA' .OL 10 / MA 5i " " Li 5 * j - U -) u u S ,10 J , 4 ' j ^ t 1, 12 5 .i. 1 0 0 1 . / 2 1- 0 . S * t U'l 1 U U U 5 b " uU. . 1 4 2 uu 1 0 0 1 , H 4 - o u i , 115 0 4 o o . ' i i - o O w ' . t ' 11 "LAN "4/" i 1, 00 t i .4 1 u . VJ 2 i, , 401 0 , 21 M t u l kH -l,/'ll o , boo 1.1 o4 O.S02 1 . " 01 0.211 1. " , ST Au Ua HD AVt. UtvlAlltlN 0,0 44 1.201 0,4 S0 0 . O20 O.Sd 0,4/6 V, 000 0.442 0.211 0, ooo U 1 OU 1 uU 1 '- i a u 2 ; 6 0/ , d >;. 4 .,2 1 1 . 2 1 ? Ji>l 1 u? 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REPAIRMAN'S HELPtR MAINTENANCE h E C H A N I C -------------- S i c CU'J[|1u9to GUUVtUUMjH TALL t U , * L l j O V t H : i [ |ih i !i , 1, lJilt Uf SIUU1I ( | / U i / / b " 1 1 / U7 / 7 5 * O t" l a lu u llu i SILICA ( U U i l i n i l , LAHKtMCt ) CRMC-MAD-000098 wwiictou^ta s a c p l I nl ntliiiiu anaL t !1C*L ILCH, NNAVlMtlMlt XMAYU1FI-HAC110M ?tet i il i KESPIKAULfc HaSS 5 A H P US AHt t U L L t C l t U UN MS A POt-t v i N t u CMLUMlue f I L t t K S t S . U M PuHt S i i t i a i * H O * l U T t Uf 1. 7 H i t HtK M l N U l t , NYLON CTLLUNt 3 ( 10KH) ARE u s t o f UH S U I S t P A M A I l U N , 1 K U S l l l C A Ut 11HHIkA.. . _ H O H 3 AHI HAOt USINO t U A H l K A I l V t A-NAt O l M B A C U O N AND B I L I C A C U N L t N l H A U U N S H L H U R I O A3 * U / M 3 , CRMC-MAD-000099 E . i-.o;-[)'" l s i Htat/L5 t : Ml |f. > / \ Ml. T1|F H, I t i " ! i.i'l t r.ii*Vl'1i MIC l VI i 1 /*M*U|>7mH I ION S ^L 1 ili 1E i r-E llL - . 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I U'1 i 1 uoS ( t I o Mf 0 A Vf , ; H 1 i n Mt 1 0 - i f O Vf1 10 A , *1/2 1G 1uSu ll/Ob/75 ,,ooo 1 1/ uo/ 75 II , u u u 11/o 7/75 0 .'Mo 1 1/07/75 U ot>5 11/ u l / 75 0655 OTO 1 155 l 55 o f 15 . 1327 0 7*1 1125 07?* 1 31o 0,015*7 0,0057 0,000 0,000 0.0323 0,01b 0.01 53 . 0 065 0,0153 0,000 MO* 1.1 1H7u k.t 10 Ml f O AV| , 1l/ui/75 0 , 000 0 7ab 1loo 0,5337 OcOOO CRMC-MAD-000102  8, !-.ri v Ir U l *>x " u u ut SUI 15 k ti M it i :_K 4 ' /i i 1 r i , . ; ' 1i ( 1 . . 1 f. 4 * * 1" 1 1M1c i v ; <t Si i l - 1'- ' 1 s , i, i 1f 3 1 * .` U i ] 'J * " A / , i 1 1 / 'J / / / ^ ' i V J il*: 0?1 1 * 1J 4 A : 1 M 4lJ ! 1/ u 1 / ' S Ul - t I ^ ` W ) J f . 2 D . U l 1i i l t, 1 c .E lo -u O 1M 14 i*i ! 1/ u / / / >. a `j > 0 7 1 1 1> tS li -t it-MfO IW * f . - ! 1/ j u / 7S >>. -MI 0 707 1u 7 1 1 > 1u / 5 1t /u 7/75 ! U - I f D i vf . o . 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Hi 1 r> r>i ,r) 0 J i r> r, i '< 1 1/05/7 5 <1,792 1 1 /U5/75 11/O5/75 1 1/05/75 11/ 0 5 / 75 oo7 11/05/75 11/05/75 1257 1250 1112 _ 0 o6 070O 1 ino 1 lo 10 1 5 . - 1 2 7 , 2 0 0 0 lUui 124,1000 114 0 -- .. 5 4 , 4 0 0 0 1112 240,2000 uoo 100,2000 1 o55 1 JOU 127,5000 197,2000 2.571 9,625 2,8b 5,079 01 i o - G 1'<5 11/05/75 - }1 1 0 C. t ^ t> 11 / 05/75 10 l u 0 ? 52 1 1 / u 5 / 75 f - I 0 -1 I f 0 i . ; 5 . 7 o l0 1 1 G i 4 'i 11/05/75 10 J 1 f G? t 1 1 i / u 5 / 75 . I Old . . 1 l 04 OPS' loot 0 7n i 0059 -. . 107, IO00 17 1,4000 197,2000 -OOq U 105 170,5000 1ou5 1151 1 12.2000 IE G21 7 11/05/75 H5> 1055 112,0000 CRMC-MAD-000107 P iC i t X UNITS - - F B/ CC -- - ----- ........................................................................... too rout cru sher man FB/CC - - - - - ------------------------------ -- 11 00 FT CRUSHER, S()0 HI GH TU COUNT, --------------- F R / C C ............ ........... ... -- -------------------------- -------- ---------------------- ------ --------------------1 CHARGES SET OFF * ORI L L E O a n d NOHKEO CRUSHER-DUSTY, F U / C C ................................ ............. - ---------------------------------- - ---------------------- RORKlNG CRUSHER i OR I L L I N G , OO-^OX AT CRUSHER, FH/CC - - -............... ... - ------------------------------------------------------------------------------20 HI N IN BREAK FOOH, F B/CC _________________________________________ _________ FB/CC FH/CC FH/CC FB/CC .. - ........ .............-- ........... - - ----------------- TRAHHING 2 5 SLOPE TUOK LUNCH B R t * K 1 1 3 0 - 1 2 1 5 FU/ CC ----------- . ------- -------------------- -- ---------------------------------------------------------------- FH/CC FH/CC TBAMHING 2 3 STORE, FB/CC FB/CC f B/CC TBAMHING 2 3 STUPE, TBAMHING 3TOPE 23,TOOK B5 MIN LUNCH BREAK, f 11, J *,0 J V I *t- S * Mt>Lt wt SUL >3 B ' . i 1 7 S *f S ( 11G | * * i " t !..)' /--. i l I I C * ' . 1 i " K l ht +v L f h i ci'. I..I, 0 a 11 ii} ) ( 0 / 1f* 1 1 / o3 / 7b i * I G - ! f 0 i . - il , u UJ i-, i i ? f* ; i o 1 1/03/73 I flo tM LUUN1 I ju t J*. lift UF F ofno 09 U 0 o fl 16 1 021 /illicit- mcKu, vuiu* L I 11 *13 CUNC, 197,2000 2,819 17 8 , 3 0 0 0 8,703 1? r-;>!9 1 1? U ` * t 1o i' i ( r> 1 11 , * r " [n 1 ) G i Su 13 t 7 C? 1J |0i 7 G/26 1 1.03/73 t i / o3 / 73 7, J o G 11/03/73 11/03/73 11/u3/7S t?t Il 6 3 1 1 1 9| Ul 136,0000 t 73, 1000 10,626 . 3,798 12 80 ~ 1 0 1 ' o6s9 1033 1 1 OU 9u2 229,3000 - 2,672 . 69,7000 19,399 209,1000 8,319 [1 . 1 17 G/ 28 | *, t I G `<TfD i l l , ! r<i to Gi uo 1 1/UG/73 0 , 0 1u 1 1/03/73 U9 1)2 1 3?5 1019 m3 130,9000 83,0000 3,179 8.209 :i lu J 1 0 G ( o j IG r, ; 1 J 11/03/73 11/03/73 U* 32 1022 187,0000 9,728 . I l (2 - 1195. _____7 i , 1001) . 1 1 , 0 3 7 11 1 IG G/ J f 11/03/73 0 7 fl 0 08 12 136,9000 8,697 il 1 J 1 9 0 / '2 i . I G i ! f 0 t V( , H 1; > 16 G 1>6 11 to G/'") Il. G lo 6 /Ug 1 1 /o 3/73 7 , Hou 1 1/03/73 11/03/73 I I / o`j /73 10 22 I luO 09 i 7 1 OUU 1102 1 o37 1000 1200 68,0000 1 10,9000 11.157 - 9,ba m .io o o 6,828 209,0000 8,722 1)06 lo ' m t IG- l i 0 6/29 if ,* I l 06 1 G Cu U 11/03/73 U 14 1 11/03/73 , 0 6 3 8 . . 091 1 1)9 UO 10 13 . 2 3 o , 3000 967,3000 2,578 0,876 CRMC-MAD-000108 - : UN I I 3 ...................- - - ............- -- ------------------ F B / C C ------------------ ------------- ----- ------------------------------TRa m h ER 2 J STUPE, F U/ CC F /CC FB/ CC 08AGGING UH , SHA L L CAVERN TOOFT, -------------------- ------ ------------- --- --------------------- FH/ CC ----- -------- ------------- -------------- ----- - - - - - .............. ............................................... FH/CC FB/CC DRAGGING ROCK DKN FROM SOOFT LEVEL,LAFIGE CAVERN, FB/CC FU/CC SPENT 20 MIN In 'BREAK RUOM, FB/CC F B/ CC ................................... .......... ........................... -- ------------------ ----------------------------------- f b / cc . .. ORAGGIn G ORE ,5FIALL-- CAVEHN .700E-I_LEVEL,--- ----------- FB/CC FB/CC FB/CC F B / C C ............................... ------------------------------------------------------------------------------------------ TOOK 45 MIN LUNCH BREAK. F B / C C ........................................... -- -------------------------------------------------------------------------- ORILLER *23 STUPE FB/CC TOOK LUNCH BREAK FOR 5 HIN,SPENT AFTERNOON IN LUNCH 1\ 1 1! I r '*L S ****. t MtSULlJ I t 1 * >-r 5 t yx h t " ` I- 1 r r j c u ' 11 C" '* I t - W. l ( r|nH L U JUT 1 i ' ' f f * '"'l* I J 0*U r 1 I M n*. It L /Ut'tlCAL *IC U , vtJLU"L 1 1 1L 3 cuic. I 1 ^ <? .C 1 1 / /S/ /s b 0 ft* V. ; o . e '/ 6 I' b S' UV*JtJ y t>/ , b u o 0,000 1 1/ 0 b 1 75 OOP t 1 UU0 ll>7, 1 ouo 8,377 's 1 s r.? i s 1 1 / u b / 7b - 1On - l l u U <75,2000 1 8 , 1 5 2 1 s C?i 1 | / u S / 7b I 2 u0 1y 1b ) 6 | 5000 5,<765 1 s G? SI 1 t / n b / 7b I 10 t 0 I b i , 2000 I 1,068 [ t5 I* 1G" I ; 0 * f - 1 I / u b / 75 q.518 I 1 J 0 22 1 1/0/7b . E K - ' - l f 0 u f - 10 . <J ib 1 *0 r. t* 1 1 ! /0U/7S 0656 l?p5 U7 1 0 Ul l 300 U8i<7 212.5000 7 , 7 35 <75,5(700 16,035 1 3 6 , OOO 3,630 { 1 r, 7 b 1 1/0/75 U 8 J<7 I ooo 2 1 b , <7U0U 2,371 \ t u r.JV 1 1 /t<u/7b 10 u6 12o5 ! 3, 3000 7,532 1 u Gi'i J irt I C*" r 1 !> f vt I 1/ U * v7 b o ob t Sno .. 1 2 0 .. 1 3 b , 0 000 <1, 693 l 4 t; tj U t 1/ o 1 /75 -- l b t 3 . 1 7bS ..... 27 5 , 0 0 0 0 . . 5 , 8 1 6 .. ) U 2 ,, r.u? 1 1/o i/7b I 755 1 <7b<7 2 1 0 , HUGO 5,284 r.J i 1 1/ o i / 7b l >i S 7 2I2<7 153,0000 3,30b 1. r.'i? 11/u J/7b 2 1 2 2 38 117,3000 - 3.703 o Vf 0 ,** 12 i 1 " IS fu i o r,f)H 1 1 / j 'i / 7b 1 1/ou/ 5 1uu 7 0 7 31 Llbb oyo . 1 1 7 , 3uoo 117,3000 0,000 13,243 Ivi ; i s r . o 1) 1 1 /UW/7S Uftuii ' ' C R M C -M A D -000109 to5 110,5000 5.473 unl 13 F l i / CC FB/ CC F B/ CC Ml/ CC FB/ CC Ml/ CC AflfA, TOO HIGH ID COUNT, HIGH CONCENTRATION, E3TIHATEO COUNT ONLY, Fh /CC FB/ CC FB/ CC USUALLY H0V3 AROUND OUTSIDE HEARS RtSPIRATOH ALHQ3T ALL THE TIKE ... .. -- -- ----------------------- ---- FB/ CC ~ 1 FB/ CC .............. , ________________________________________________________________ FB/ CC _______ FB/ CC FB/ CC FU/CC . . . FB/ CC FU/ CC f b /cc TOO U I 6 H 7 0 C O U N T . . . ------------ ------- ---------------------------^ , CONSTANTLY MOVING THROUGHOUT-- THE--AREA HEARS ESPIRATO---FT ALL OF THE TIME l - . O t v l ^ H L 5 * ,JWl t ut S ' < U 5 j't - f i \ . M IMI I t C H ' U i j i ' f I F I' i f tl C U . ) ' H s Ir.l b*' I F 1 Mili ,{)# 1 S 'J. r.'-j* M it 1 | / u u / 75 I U-l O*: 0 4 ij S 1 1Mt t If f 1047 / I I P IcAL HICHU, VULUCt U Itob cune |U5,4000 .- 5,901 I..1 1 S r, i l. i 1/ 0 4/ 7S 1 155 1115 170,0000 1.507 1'5 1 s m i E IG-'fD 0i G A Vf , 5 p.i 1 ' G i on m e ' E I G--i 0 n i .= p*/u II G i 1S r E I G - i f O t *( . = 1? ;| U 1 1 r.Si> 1 1/ u u / VS 5.55u 1 1/ U 7/ 7b 1, t K 11/04/75 u , 7 71> ji/uu/75 - - 1 115 U7 M6 1040 0 7 19 14 0 ........ 9 1 , 5 0 U 0 U4uS 1150 u t 26 I 34, 1000 119,0000 111.9U00 2.927 1.666 4,776 7,612 Rv. 1 1 r. 7 7 RO 1 1 (. i e J [?0" 11 i; i \ s I? J4 1 1 r. i 3 o lie 1 1 Gt ib li> ; R a E.1 C h i f 0 A Vf . * lo 1 * r,G 1 l r 4. 1 !><T 6 AVF . S p7 0 21 r..i 1 1 1/OU/75 1 1/OU/75 11/uo/75 11/04/75 t t/U4/75 7.440 I l / u / 75 *) u 7 11/ 1/75 OftPb 0945 134.3000 u 4<i 5 1040 93,5000 l i s o ---- 1255 ____ 1 10 , 5 0 0 0 1255 1 145 05,0000 1 150 14 25 59,5000 07 1 1 14 j e OH27 1055 129,2000 212,9000 3 i BOB' .372 6,664 ! 1,6|7 11,030 9,367 1.065 |j?J4 2t 2. * il r./u G/6 1 1/01/75 1l/oi/75 1 755 17S- 1752 . 96,9000 1b52 102.U0 2,168 ,632 y ? o -* 1 r, i * i 1/O 1/75 CRMC-MAD-OOOllO 1 652 1950 112,2000 2,168 ' PACE I i units FH/CC FH/CC FU/CC _____ . . . . . . ------- -------------- -------- ----------------------------------------------------------------- J TOO HI GH H) COUNT WORKED OUT5 1 OE MOVING RU3TY PI PE FUR MlN, OUTSIDE WORKING f b / cc FB/CC FB/CC FB/CC FB/CC I BUN TO SWEEP AND BRUSH UP FOR 10 H I N U S U a LLV STAY# - I n s i d e w e a h s - r e s p i r a t o r h o s t - g f -t h e t i m e -------------------------- FH/CC FB/CC FB/CC FB/CC FH/CC 15 MIN BREAK, , HADE 6 CHECKS on m a c h i n e r y . A F T E R 1 9 0 0 W I L L B I - M A k I R C ----sample runs i n a d d i t io n to c he c k in g m a c h in e r y . FB/CC U b u n s t o CHECK HACH1NEY#6 m i n , FH/CC FB/CC I RUN TO DISENGAGE BY HANHERl NGi HEAVY EXPOSURE, 2 RUN* TO CHECK h a Ch I NEHY# OMI N, t 5 5 RUNS,10 H I N , I'.OfvIO'ML WtSOLtS *M I - t ! . S. ' / - ` lI K*L ~>l i 3 S-'lr U ' PI f Vi H i ' . 1,0, f?i I t 1" f. 0 5 1 1/U 3/75 f i vt w CHUM Tjvf in. 1I" t Utt 1 <JSB U59 - /OPT Ic *1. MICMU, VULU*t U Ttwb cim e. 103,7000 1,915 Cii ? 1 r.S 1 1 1 / u 3/7 5 11^9 15 93,5000 5.91 J o u >1 r.Mi . I G - U f f) * v f , 1 1 /u 3/75 ? , p5u 1 1 / <j t</ 7S I S -- 2 Jt> - - M l . u o o u -- 2 , 6 0 7 KisS 1200 110,5000 6,593 M fc 1 r, 5 8 1 1/u/75 uro 0 8u 1 158,, 1 0 0 0 11,197 ?C6 1 ? G 7 g . 1 1/' I U/75 ?06 2u6 1 ? Gio 1 ? Gl 6 1 l/uu/75 1l /o/75 2"o 1 r,i j,> 1 1/ ' i u / 7 5 0 b 1 ? }`t -t l c . ' , r o r.i5 V,: 11/96/75 1 J. H I 2 bb 1 r.o 1 1l/uJ/75 . nnq 1 U 9 u 0 110,5900 o^ub 1200 1 055 1255 117,3000 93,5000 1?S5 1 JiiS 1 J 5 1025 85,0000 b8,00 00 1 Ou b .... 1 6 0 8 - - 2 0 7 , 0 9 0 0 13,622 8.932 8,622 1 6 , 9 30 26,829 1,725 06 i i2 v*> f \ l2u6 i \ t l 06 I ) ? 06 1 G G 1 G 0 r.ufl r.5o 11/93/75 1l/uJ/75 1 1/U 3/75 ) 1/ u l / 7 5 11/03/75 CRMC-MAD-000111 I lbuH 1 7 fl 150 2oo5 2to5 1708 1850 005 105 155 102,0000 1o 5 , o 000 127,5000 1 0 2 , 0001) 8 5 , 0 ` 00 5,527 3,570 2.891 6,233 5.562 UMTS . FB/CC ................... ........ ----------------------------------------------------------------------------------- 5 BUNSi 6 K I N , FH/CC ......... - --------------------------- ---------------------------------------- 1 RUM TO CLEAN UP PER S H I F T , 2 3AHPLE RUNS PER S H I F T , F H / C C ....... ........- ................................................... -- ---------------------------------------------------------HADE J RU MS* 10 M I N , Ffi/CC F8/CC 1 SAMPLE RUN PER HR TAKES CARE OF 3PIL13 TOO USUALtf - - STAYS OUTSIDE- NEARS RESPIRATOR-SOh E OF THE Tint----- FB/CC - - BLEW H I M S E L F - O F F K I T H - A I R CUN------------------------------------------------- FB/CC FH/CC FH/CC BLM HIMSELF OFF PITH AIR CUN, FB/CC FO/ CC - .................................... ............. ............;------------------------ ---------------------------------- -2 SAMPLE HUN3,F0R S HIN,I RUN PER MR,ALSO CLEANS UP t PILLS,ACCOUNTS FOR 2 TO J HRS OF TOTAL SHIFT PORK, FH/ CC 3 SAMPLE R U N S , 5 M I N , FU/CC 2 SAMPLES RUN *3 HIN FH/CC 2 SAMPLE R JM3, l CLEAN UP*TO0K IS HIN, FB/CC FH/CC | RUN TO SHEEP UP PER SHIFT,2 SAMPLE RUNS|5 MIN, 2 SAMPLE RUNS,|0 HIN I l , I-iOlvlft'.UL 3 * E t s u n s S- c3 I 'IS e I H) / i l l ! ( CH 11C*< l'i'Jf I f l 'f 1* C'-'L'NI -It 7 Si-^lf ' 'J, 1 l'4,t i i-e 1 I M 0 . Uff 2 \ r. SS I 1/01/7$ - 215$ 2217 - re D * f . = 5, ni 7 1 'i Mil 1 i / u/ 7$ - i f 0 4Vf .t S , 1y V 1 II u 0 I l5 9 1 1 r,$7 M /U/7b U 7o 7 0820 / i i ^ t l C U HlCU, VULU^fc II ItS cune. - 7 1,000 . _ 3, 6 9 11 y , Suo o 5, J9 1 2, 1 000 1 t 070 05 1 1 r,7S 1 1/ U u / 7S 0820 U9 JO 119,0000 7,08 I 1 c i <>o I t r-i25 11/u/75 1 i / o u / 75 09 JO 1 I 5 1 0U 1 0 1 19,0000 59,$000 5,060 29,1 1 1 f. 1 VU 1t/u/75 1 1 c. i 1i /o/7S 1 1 " I f f) AVf I 1/u/75 1? . 1y l W * r,;*? 1 1 / u 1/7$ 1 ?20 liio 1u ,,8 1 119 t 31u 1 0 li lo9 119.0000 69 , bOOO 37,000 6,831 23,115 15,639 212,5000 5,979 r,? 1 11 ZOO/7S I 6 99 1 79 io,oooo 8, 1 f.25 11/01/75 1 T i)9 1H 8 1 o o , 300O 2 , 6 1 0 *? r. 9 1 1/UJ/7S 0/1 U'O 102,0000 3,72 <?> r. 19 1 t / u 1/ 7b t r.$ l 11/ M / 7 $ *M TF 5.<>5 ?0<J If r. 71 11/ 0 u / 7 S 1 fiuh 2i$s 2 u(i ib 7 o0 o9a CRMC-MAD-000112 { 136.0000 69,7000 17 i , 000 5,t 6 , 170 ,122 fH/CC ------- ---- --------5 JAHPLE RUNS.5 MIS fB/C C f r /cc 1 CLEANUP OF SPILL 3 SHEEP UP 1 Sa h PLE RUN OUTSIDE MUST ALL UF THE Tlft&'HEARS HESPIRATOR MOST OF THE-llHt-- F H/CC - - 1 RUM T O CLEAN UP-SPILL ,OUR INC-SAMPLE PERIOD---- ----- - f h /cc FH/CC USED AIR CUN ON EOUlPMEHTfHEAVY EXPOSURE F H/CC F H/CC - - FH/CC FH/CC -MADE 2 SAMPLE RUNS -1-HUN-PER H O U R -------------------- FR/CC j SAMPLE RUNS. HlU-- ------------------ ------ ------------ - FH/CC 1 SAMPLE RUN, 3 HIM. --- -- ----------------------------- FB/CC __ j P U N TO CLEAN UP.RLOMS THE MILL5 I T M . h r M PER SHIFT.2 3AMPLE RUNS,15 MIN, CUNO N E - T X -- FH/CC 2 SAMPLE HUNS,5 Ml, - ............ - ....... ....... -- FU/CC ... . ----------------------------- ----------- 2 SAMPLE HUNS,5 MIN, FH/CC WEARING r e s p i r a t o r . l_ |, i >oi V1v u _ ^t.S<->Lf S i1 : t -; i S r J * ' t i TIC l 11. C i - 1. I i l " ' 1 ... , - 1 1 i j i 1f ! J . 1 1 F I -t CLk.N I M " IM E l.f F il i :'> 1 1 '.9 > I 1/j M )b 1 r, i , S 1 1 / 0 >J 7 7 b 1n il 10 il 12 J J / . I M 1C * L * I C U U t VULCi T' t U ItHS CUMC, 117, luoO 5,000 2 0 7,9 ou0 9,260 ,, t 1 M- ri 0 L - ` - ?J9 1 f r.o 1 u , 7- 7 1 1/0u/7b 0 70 J U9 U9 19o , 2 0o0 , J Ifl 'j'l 1 F r, i o u 1 1/ 9 / 75 t/b lo/O 1711,5000 5,195 .,9 1 f r. i o 9 1 1/uo/ 7b l 0 ? 9 - 123b -- - 2 1 U . 2 U0 2 0 , 1 1 1 >09 1 f M il 1 1/OU/ 7 5 . u 9 1 f . u . " l f T>9 If, C.9 10 f. 1 ? 7 Vt . = '.li M io .11/09/75 . 9,10 1 1 / u o / 7b 1 1/uu/7b C 9 1 0 G| 12 1 1 / o u / 7b : 9 i r. r. i o t 1/uO/75 o' I 0 f. i "1 1 1 / o u /7 5 ? ,, t I o - I f r, Vf . = 09 I 7 r.59 b.9:i 1 I /u/7b 0 9 0 9 12 1 J - 0 7u 5 . 1 0 30 09 i 0 1212 1 1 5 il 7 i 1 _ . 1 029 m / .. 09J9 1195 1UJ 1921 12 32 U ll .. 1Jo.OO t 7b , boo0 5,091 - 7,186 151.3000 6,208 127,5000 7,919 129,2000 5,953 Iflb.JoO -. 3,579 79,9000 8 , 9b8 102,0000 . 8.087 ;.9 1 7 r, a o -9 ! 7 -.h 7 09 1 7 G9 1 09 1 7 G | 2" C 9 1 7 O lii ,,9 1 7 G t 9 J c f1r0 .... _, i. 0 vf ,= 1 I /09/7 5 1 1/u/7b 11 / U / 75 11/09/75 11/nu/75 1 1/uo/75 1. 'li 119 i I ... 1 0 1 1 ... 1 u 2 , 0 0 0 0 9.681 lo ti 1111 102,0000 13,872 0 11 0911 102,0000 7 , 7 31 1 1 1 1 - 1230 _ 1 J 9 . J 0 0 - 5 , 0 6 6 tajo 1 JJo 102,0000 7,202 t JJO 1927 96,9000 ,93'J CRMC-MAD-000113 ( PACI I % X UMJT3 Fb/CC fB/CC CHANGED fft(|H N Y H L 100 TO CERAMAT A^ HP t AT 111111,100 K 50 MIN LUNCH BREAK, F B/CC Fb/CC fb/CC f fl/CC Hl/CC Wf AR1NG RESPIRATOR c h a n g e d f r o m n y t a l 100 TO CERAMATALC HDTAT U U 5 , t o o k . lo HIM LUNCH BREAK, FB/CC -- - FB/CC fB/CC FB/CC .-- ... fH/CC TOOK 30 H1N-LUNCH-BREAK, fB/CC ... 15 HIN BREAK AT 0 115,K5 MIN LUNCH AT U i 5 , f B / C C --fB/CC f B/CC FH/ CC----FB/ CC FB/CC ;v. H, I'.'iJvIMJiL l'tSOUS i : : - - s r : i ii \ . ............... 1 i C- I U O ' M i n ' i F ' t'ffi CUuM i) t I f i ! *T 1 1ME i -u 1 t - T 1 1 > 0 1 1.7 ' 1 8 Ci 11 .< 1 ! > If 0 r, , S7 * Jf , - 1 w r. t. o i i /i-*/7S 1 i /I, U/ 7S 1 1 / V' J / 7 5 1 1 / O " / 7b b .22o 1 1 / 1) 9 / 7S 0V7 1?u 1 1 30 1 3u0 07 1 <1 1027 1 JGii 1290 1 U20 Ol t / | J P ! I C * L MICHO, VUtUME I l I L HS CUNC, 1 1 7 , 30 <. t>000 2 0 9 , U UGO 1o 2 . o o O 1 , 1 ! 7,792 10 , 0 0 0 b , 088 70,2000 9,39 9 b , 9000 6,699 1 9 f.n i 1 1/Ou/75 1 9 r.oo 1 1 / 0 / 71 f.7? 1 1/Ou/75 1 9 Gi 1 1 1 / O / 75 19 C| 9 1 I / o u / 75 1 9 -L i C-. 1f 0 > 4 9 I C f f f) C 1\> 1 ` .: r. l'h *VF .= 1 i / u J /75 t. n u 1 1 / U 3/ 75 G.u? 2 i r. 1 1 1/ u 3/75 0 9 1a 1 Gl G 08|2 1 11 12J7 1337 1U 1G 1 0 2 , UOUO 3.011 111. - 102,0000 6,93 0 1 105,000 3.808 1237 1 1 . 1000 5,33 . 1337 . . 1 0 2 , 0 0 0 0 - 5 , 9 0 3 192 08,9000 12.991 1S ? 0 . 1 U7 1983.9000 0,202 16(|7 19UG 2 3 b , 3000 9,30b 2 7 r. 35 1 1/ u 3/ 75 7 r. u u 1 1/ 0 3/75 2 7 r, J 7 1 1/u 3/75 t 11 Tf l ) A7 f , 2 u . 17u M r,.)* 1 1/03/75 19 h 6 1GI 0 1o 152t. 2 u 1b 229 21 1 1G90 1 19,0000 1l 3,9000 19,5000 139.UOOO 6,760 3,20 3 . 2 37 2,900 2 r.| ? 1 1 /O 3/75 i C R M C -M A D -000114 1 b'I* 10 5b 2 1 7,6000 7,999 UUIT3 M i / C C --------------------------------------- ---------------------- ;----------------------------------------------------- ------ -------- i t H/CC FH/CC ! F l l / C C ------------------- -- fH/CC ------------------------------------------------------------------------------------------------ ------ J i Fti/CC fH/CC tn/cc IS HIN BREAK,45 HIN LUNCH F l l / C C -------------- ------------------------------------------------------------------------------------------------------------------- FH/CC FH/CC f H / C C ____________________________________________ ______________________________ _-- FH/CC FH/CC FB/CC f b / cc f b / cc took Co ffee b r ea k , - -- -------------------------------- TOOK 15 MIN COFFEE BREAK, f h / cc Fll/CC BAC BURST AT 1600 HRS,  II. 2 * i *. < ! -. fi J j I MI SUI. t S - . . I . r t 1C 5 L '? l f MA I i r. i i 1 1/u 1/75 'E I r I -if CUU-M / u P I I C i l H l C HU, 7!- r.s 11" LE vbLUHE liie o s CtJ^c. no 2 2 2 ' 7 - o o , J o o 1 5 , <308 r. So i 1 / u J/ 75 no 5 2 1 JO 1u , 5 0 00 1 0 ,Ubi r, 17 L 11* Tf 0 i < ( , 0 o r. j 7 u'V 2 0 r.i M/O J/75 9, lio 1 1/(.' 1/75 1 1/o J/75 0 . f. 1 s I l /O 1/75 o r. //< * 1 1 / 0 J / 7 5 w r, j h 1 1/ o J / 75 t lo-IfO t O ,s n 6'<6 U , M9u 1l/OU/75 1 t* r.'S 1 H 6" 6 1 M r. o 'j 1 >> r. i lo 1 -i r. i i s 1 n i 5 t 10 I f 0 i - i f. 10 2* r. i u i r.o 1 1/ o o / 75 1 1/uo/75 1 1/06/75 1 1/ u o / 75 1 1/uo/ 75 1 l / O / 75 o,|71 11/ u 1/75 1l/uJ/75 1 1/O J / 75 i r,l 1 1/u J/75 22? 251 oo, bouo 20,956 15 / 0 160 5 1607 1Vuo 107,0000 . 216,1000 1.016 6,013 19f)U 2 l uu 0)2 . 012 2250 too 115,6000 112.2000 156,0000 6.35 6.037 1 , OSO 0? JO 00 \ J 101 i 08 \ i 1100 12 12 1 112 >5/5 1O S ') 1650 2o 11 uB 12 1u 5 , oOOQ lo ll 11 I d `712 12 Jo 1112 1o r i 612,0000 l1U.5U00 . 102 , OOO HS.oOOO 102,0000 75.2000 l 65 0 2011 1050 151,1000 158,1000 210,8000 2252 219,7000 5 , 7 11 1,60 6.10 7 . 38 8.288 7,586 5,515 .218 2.176 1.1 2 1,812 CRMC-MAD-000115 m g c 139 UNITS f H / C C ..................................... BAG BURST AT 2225 FR/CC - --- ---------- - t o o k 15 m u coff e e b r e a k .c l e a n e o h i m s e l f >.i t k c o k f >s e s s EO AIH.8AG BURST 2125. f R/CC FR/CC F R / C C ----- ------ - --------- TOOK DINNER BRtAK JO HIN FR/CC - ............. - ----- --F fl/CC FR/CC TOOK 15 HIU, COFFEE BREAK, FR/CC - 1 5 IN BREAK,--------------- FR/CC Fli/CC FH/CC'-- -- -------------------------FU/CC FH/CC FR/CC - ---- - ~ -- ------------ F ll/CC FR/CC F R/CC FH/CC - ............ .... TOOK DINNER BREAK,10HIN. TOFIK 15 MIN COFFEE BREAK,  U. I -. OI V [ r \ ' U l HE SUL I S *. i : n5 P| i " l l-M. / A . AL / T ! c ` 1 1t C"*' I (;u i ( I nLW b~ 1C T- bT -^L F U l c 1 -0 - ' 0 ' t : /, i . t . = 2 . 7J6 T! " E On U'UN Tl^E U7 F ? 1 ! r. 78 1 ! /G u /75 0 10 1oo 7 1 ! r. M 5 11/00/75 1(1 G 7 1U . /i0* 1 1C *L M I C K H , vuiu^t L I IF.OS' CUNC. 19 d , 9000 0 0 $ , 7UOO J .911 1,588 ,,t I(.-t O I/` = 12 25 r..ib I.0*8 11/u 3/75 15/1 1810 297,5000 1,079 ( 12 >2 : -l i / b r. 1 o S r-.J 1 n l i f ,~ 1 i f, o 5 11/ 0 J / 7 5 11/0 J /75 1. 28o 1 1/uu/75 I'M 6 2 (>3o 20 J o . 2 Joo OT i 5 08 JO 227,8000 255,0000 127,5000 1.859 1.015 5.07B i ) 1 i f, M0 1 1/Ou/75 \ j 1 * r. HH tl/OO/75 ii i r, o i 11/OU/75 11 1 1 r,. // 1 i /ou/75 i ) 1 1 f. i 12 11/ou/75 5 1 1 r. i *. 7 { 0 r-I f 0 * ' f . * 11/uu/75 5 , 7 5u 1 3 IK Go/ 1t/ou/75 1 3 1 ' r.ft $ 1 1/uu/75 ! $ 1 n r. i I M 11/Ou/75 09 $0 0 8 $0 tojo 12 j5 11 J 7 1 J j5 ! 0 $0 09 JU 1 I 37 t JJ5 1235 IU20 0 7J 7 09 1I 09 11 1lu i l i n t - 12 37 102,0000 0.722 102,0000 5,020 1 1 3.9000 6,280 102,0000 7.261 90,6000 0 , 6 10 11$, JOOO 6.592 159,8000 18 7 , oOOO U3.2U0O 3.135 1.106 1,653 1 3 l - I in tf n Ci ;9 i . t .= r.d? 11/0U//5 2. l o j t /') 5/T> 17 J 7 I5?l r, i 1 /O 3/75 C R M C -M A D -000U 6 iTno l2l 1 7 CO 195 3 17 6, 80 00 168,$000 9 , 1000 2,598 2,581 3,300 Fa/CC TOOK 50 HIH LUNCH BHEAK, F5/CC FB/CC FH/CC WENT TO Ml HILL DURING SAMPLE FOR 10 MIN, - - -------- ---------------------------------- -------- - TOOK 15 HI M BREAK, f h /cc FH/CC FH/CC FH/CC FH/CC 15 MIN BREAK, - - ---------- ------------------------------- FH/CC FH/CC FH/CC FH/CC FB/CC _. . ------- ------------------------- CHANGED FROM NYTAL 100 TO CERMATAl C hDT AT ! U S TOOK 3n m i n LUNCH BREAK FH/CC F R/CC PACKING NYTAL 200 UNTIL 6100?" ,THEN NYTAL 300. | l, I r>, ir. |<L S *-*pU Mt 5UL S 1 iJfS t'S c r ..U- / ' -u l <' JC ' l l C M" t |,l> 1 f I `iH C ' j u u t 5 'If 1 - . 11, S< ' ' , .> t!" t 11') ll* uf 1 I 1 /., CIO 1 1 /o J / 75 5 /h r. U - I i. - I f 0 > , s tu )C r. / o la IC ".i"? 11/0 1/75 J . 7?5 11/ o o / /5 11/ou/75 1ot, i ? 150 0 7 \u 00)8 2 15 U 227 0O| 1000 I o IC r' l i I J 1 C i 5 1 -. I (>H 0 )> . e J lu r. 70 i 0 1 M r, *i 2 h* |H f. |.|fi it 10 " 1f 0 * v f , * 1 )s 1 H G i Gu :i .1 1 f. G?.) 1 11/ua/75 11/00/75 J . Jo5 ll/uo/75 11/no/75 1I / /0/75 2 . 0 1? t 1/05/75 1i /05/75 1 0 <10 1H ' 0fc5 U0?6 1? u 5 1? . H 1 1o 1117 |0?9 00 26 12 " 5 1 13 155 1201 / [ I f l l c u M1C, vUHjh u n to C0'<c, 19 b , 9000 3, 19 9 0 , <70 0 0 6,260 17b,H000 10 6 , 2 0 0 0 1,116 5.350 2 9 0 , 1 0 0 0 - 2 , 0 3 6 80,0000 - 5,556 150,7000 118,1000 109,6000 1,573 2,367 1,750 227,8000 158,(000 0,0(0 3.736 :.lo 1 la G? 2 ? "c , I G " 1f 0 , f , a 1 JU 1 G2 1 . 1G " Tf 1) Vf , E 4 1C G 2 j 5 11/05/75 2.0'lu 1 1/ 5 / 75 Il , 7n J 1 1/1)5/75 OTn1- -- 1108 .019,9000 - 1,195 0655 -- Ilio 0*7(10 219,1000 . . ... - M57 3H5.900 0,763 1,007 U IC G? Il I" -LloUfO Vf,* wlaa ir r, t n I 11/05/75 |,1 Sm 1 1/ 0 5 / 7 5 o m2 1y | o 1 112 1055 025,0000 76,5000 1,269 1,818 C R M C -M A D -000117 i `.r t\ UM15 FH/CC FH/CC TOOK Ol NNER BREAK. TOOK I S HJN COFFEE BREAK, F0/CC FR/CC --- - .... ..... -- -------------- ;--- hand sweeping dust frqh broken bags during survly, TOOK JO MIN LUNCH BREAK, FR/ CC - ................ - * --------------------------------------------------------------------------------- FH/ CC -------------- -----------------------------------------------------------------------------------------------------------FR/CC FH/CC FH/CC h o r k i n G a t s h a f t s t a t i o n ,t o o k l u n c h b r e a k f o r 10 m In , F B / C C -- ...................... .................................................................................................... .................. maintenance at shaft station, FR/CC REPAIRING SLU5HH#aFW RAMP, FB/CC - TOOK-JO MIN LUNCH BREAK,-------------------------------- FB/CC - MAINTENANCE AT SHAFT STATION,---------------- ---------- FB/CC li, I*-0 !vIo'lil K15UII3 %i : i sa. 5>is t "t i t - r / ' - i u v i i c u l t C M,<lu u t ! * IU t w CUUn T / u f l l c At. H l c ^ U , 3**1* I Si'^lf Mi ' . l.O, '!, :*U T)m E IlM n i,t U7f voLUMt L !U i cunc. ti 1 r G , >7 1 l / u 5 / 75 1 32 1)0 - 76,20.10 1.063 U |< 5 2 0 l 1/ o5 / 75 102 1 1 1 37 129,2000 2.716 u 1 < G 2 10 1 1/ o 5 / 75 113 7 1 32 161 , 9UU 0 2.786 ,f IGmi .O if 2.65/ is j.umjo 93.5000 ]6 3.bOO 0 166,6000 065 - - 090 . . 221,0000 1,112 i b 1 10 EIG-lfO I 0 r, 16 M & 1 6 ,r r. i n |/o7/75 . 609 31 in gp t & I IP G 15 o E El G-|fD kV^,3 1G G1'll 1 r. i .. 2 i r. Gi io i r, G i 71, MTFO i ^ r .= 1 n r, i -i 3 lM G |00 1/u 7/75 Juo 1 1/0/275 1 1/07/75 11/07/75 11/07/75 2,165 11/07/75 11/07/75 CRMC-MAD-000118 132 0 7 | 5 132 19 o , 00 0 - 0952.--2b6.9000 -- 2,560 0,916 1I J 3 .. 132 266,9000 0,000 0 9 5 5 _ . 1 133 .... . 2 0 6 , 9 0 0 0 . . 0 , 0 0 0 0 7 2 3 .... 0955 . 2 5 6 , 9 0 0 0 2,3b 090 0 .... 0937 . .. 62, 9000 . 0729 0900 15,7000 09^7 I 1 30 192,1000 1 1 31 1325 193,8000 3,025 2.912 2,299 1,216 1 Iu5 09 o5 1 3uO 11 5 127,5000 272,oO0 3,198 9.029 f b /cc FH/CC m/cc MAINT,AT OFH RAMP,TOOK LUNCH BREAK,5 HJN, Fll/CC Fli/CC f r / cc FB/CC - ---------- --------------.----------------------------------------------------------------- ^---------------------- MAINTENANCE AT- 5LUSHER Fm RAMP-TOOK LUNCH 8REAK AT--- -, 1130-1215 MAINTENANCE REPURINfi SLU3HER UfH RAHP, FB/CC FB/CC---------------------------------------------------------------- FB/CC ...... .. .............. - --------------------------------------------------------------------------TOO HIGH TO COUNT, FB/CC....... ..... .... .............................................. TOO HIGH TO COUNT, f h / c c ______ ____ _______________________________________ _________ '------------------ ------ F B / C C --------------------- .-------------------------------------- -- FB/CC FB/CC ' FH/CC . . . ------ ------- -- -------------------------------- ----;--- . FB/CC {. 11. l O l v l i m S ^ c E KEiut ! s *.j'i i||l.W',H!|CU UCH'.lijl.El MHkH COUNT 1( t S * " u L f - 1 , 0 i t i , : 5, li* U T F-F (u. l"E iif f 6-i 5 1 * f. t t 5 ! * 6 i 7U 1 > f. 1 *) H ' l l 0 Vf .3 1 r, i 7 J 1i /u7/7S t 1/o 7/75 11/07/75 1.773 11/07/75 1 1 33 00 s 1 07 1 2 11V 1 1 520 1133 0051 1 324 / C I V I l c * t H 1CHU, viiiUME U I[h S CHOC, 188,7000 173,4000 270,3000 0,542 0,285 3,586 2 7 , 3uoO 0,000 0*.1 1 If 6)77 1 6|^2 - t f o ivi , I 1 c 6)72 1 c l.|9| 1 c 6) Z 1" Tf 0 A , C . 3 1 6 r. bu 1 6 6 I )7 1 f. 6 I 17 1 b 6 I .7 ! f C vl ,= 1 f 01 54 11/U7/75 11/07/75 3.9ol 11/07/75 11/07/75 1 1/07/75 1.712 11/00/75 ll/uo/75 11/uO/75 11/00/75 u , u 33 1t/07/75 07/5 09$4 1)95 1 1 34 253.3000 170,0000 0,677 6.8S5 0 9 5 0 07 18 1 1 35 1 1 34 0950 1 324 I7o,boo0 258,4000 185,3000 2,107 - 1.235 1.01 J 0 71)7 09^8 0958 1 142 1 1u? . 1342 1 3/12 1427 290,7000 176,8000 . . 2 0 4 , 0 O0 O 76,5000 4,453 0,010 ,339 1,656 07/7 0957 2 5 5 , OO 1,570 1 r C 1 7 1 1/ 0 7/ 75 O9 5 7 1152 195,5000 3,141 1 F 6)5 1 J / u 7/ 75 1152 1 326 156,4000 0.751 l,o7 CRMC-MAD-000119 FB/CC F P / C C ----------------------------------------------------- -- f b /cc FR/CC FR/CC f b /cc TOO HIGH 10 COUNT,------------------------------- f h /cc FR/CC . --------------------------------------------------- f b /cc f b /cc FR/CC fH/CC -----------------------------------------------------FB/CC FB/CC - HIGH CONC. ESTIMATED CONC. -ONLY----------------- FB/CC FB/CC HOBKER TURNED OFF PUMP DURING 30 PIN FOR LUNCH, E i a . i0iVInu *L 54p t WtSULlS u r : l * S Mt S i *>s " 11- Lm esi ite.,luM E : f P U H 5 !r T M i S i " 0Lf DUE T I me III. I n G i u 11/05/75 1| U u CUU'V T II^ E . UFE liUU - / L tC I< "i VULUMt UI IEKS 197,2000 - F I C , ' f f 0 V f , - 20. 152 1 7 G i St, -E ! G- Tt D H f 1I / h 5 / 7 5 22,5 u 1 1 9 G u9 1 1/u5/75 12u 0 1 125 |u55 1u 15 229,5000 5 , uooo 11.223 1 0 G2 57 1 1/ Ub / 7S I G I f 0 I V f ,1 10. J M 1 * G 2 u 0 1 1/U5/75 IG-'lfO i v i 9 , uou 1 5 f.22 1 1 1/05/75 I G- 11 0 AVf . i 17 . 5 2 1 2u r. nu 11/01/75 2 u r.u2 11/ J / 7 5 E I G J r O *U , i 2 5 , 0 1 c 1 S r,9tt 11/00/75 0 70 U U5 9 12u0 15 1 1 i?s5 09 U5 0 12 15t>, ouui) 0 9 U 0 271,7000 8,855 9,060 1 U 15 - 161,5000 -17,521 1755 . . 2 7 5 , UOOO 195*3 210.0000 18,365 31.705 1 OU 7 105,9000 16,561 1 s r. i u t, 1 1/0O/75 1 115 im o 91,5000 9,016 t JG' -Tf d * VF .'S 2 1 . 0 1 2 ?in I 1 i'' t ! G >t f 0 20 U 2 1 r, 7 7 vF .a f. 1." 1 1/ o J / 75 . '< 7 . U 6 U9u5 ____ 1 1 9 , 3 0 0 0 . 8 , 9 6 7 11/ o 1/75 . _ Jfi<i2 - - 195 ____ 1 1 2 , 2 0 0 0 - . 1 5 , 5 6 3 " - I G-1 f n i V f . = 15 . 5o 1 'ht, 1 2 IG - ,,0 r. i .n 11/ o u /75 1 . F . : 10 2.ee>? 09u6 1055 1 17 , l u 0 0 1 0 2 , 6 6 2 2 1 r. 2 2 1 1/o 1/75 1h u K 17o a 102,0000 31,607 fi .E 1Gr. [ f G u n 11,0*7 c k m c -m a d -oo 1 2 0 FH/CC ----------- -- -- -- *------------------------------TAa MHJNG 23 5L0PE TOOK LUNCH BREAK U30 1 2 | 5 , Fh /CC F H/CC FH/CC SPENT 20 HIN IN 0HEAK ROOM, DRAGGING ORE# SMALL CAVERN 700 FT LEVEL, FB/CC -TOO HIGH TO COUNT,----- F H / C C ---------------------------- FH/CC - FB/CC - --------------- - FH/CC TOO HIGH TO COUNT-- FD/CC - - OUTSIDE WORKI NG- ------ FB/CC _ -------------- FB/CC------------------------5 RUNS, 10 HIN, FH/CC FH/CC 3 SAHPLE RUNS# 5 I N , n i s - i s i r . f -l i / 1 `- l r i IC ` t i. I C h ' i 1j u f i , into CUn'M i>M < f ,!) 5i"OLf L'4 , E J i-t rm I IH Ut F 1 i , I g -m <0 0 | -j u i ^f . ; 11/ u u/75 l.215 // 0 .1 2 11/O 1/75 1? / o 1 0/|0 111(1 1609 /tLLCT'lN HICRU, VIILUMt UK3 CMHC, 119,0000 10,215 212,3000. 25,501 .10-1,0 * n . 1 25.501 1 " O', t. 1|/o/75 ,E 10- i f r> I V F , ! 31 . *>7/ / J r.7 11/03/75 UP? 7 2 0 16 1027 2101 2ou,ouou 31,077 100,5000 1,752 . 10-11,0 4 I , . = ii 1. 75/ I 0 r.BO I 0>i i f o * , S ll/ou/75 7 . /BO 2 * r. i n 11/o 1/73 , U-Mi f 0 1 v , a / . 0 6 1 1 1 GM J ll/0/75 o 33 15/5 l nn7 lu ll 1650 128 612,0000 7,280 151 . JOOU 2b,bbJ 03,7000 3,570 10-1 /S A /f .= 11,570 r.iiS I ! / u 1/ 75 15/1 1016 . 2 9 7 , 5 0 0 0 -- 1 6 , 1 9 1 E I 0 - i f 0 V . i I t . . 1** 1 //, I o- ,f o G ll 1v f , ; 11/ o 1/75 51>. o ii I 5 G | 9 7 11/05/73 E i o - . i f r. A V f 16.701 i 11"- r ; o G 1B J 1 1 / -J 7 / 7 3 / u ,o o 9 11 10-,r n r. i ? 6 a .7 . - 1 1/O 7/75 9 . aOci 2150 090 07j/ 09<j7 2207 0959 0951 1132 9 6 , VUOO 36,090 91,5000 l b , 793 270,1000 20,909 195,5000 9,85b UNITS -------- ------------------------------------------------------------ FH/CC ........................ ................... - - ----------------------------------------m a d e 2 SAHPLE h u m s 1 RUN PER MUUR FH/CC m /cc FB/CC TOOK 15 HIN COFFEE BREAK, Ffl/CC FB/CC - TOOK 30 HIN LUNCH BREAK-,------------------ FH/CC -----------------------------------------------------------------------------------------WENT TO 3 HILL DURING SAHPLE FOR 10 HIM, FH/CC FB/CC FB/CC FB/CC PACE I tfd WEIGHTED AVERAGES C R M C -M A D -0 0 0 121 fc,, , , , 1 r * I fS f 11 3 i 5 <i % i 'I S <( i . . : o / r . t l n K " - ! 1 O '' 1'H'fc t rid tw cuunt /up i I c*u Micmj, Jilt* t-l-f V 1 fl ? i` 1a i l 11 *> ,-l,5 H i l IF n r . ( . t Fu/CC 5i -6i 5 i-l-L-i-) U 1' o o | o , 6 / 1- 0'/ 7, / | 0 625 0 1u , 5 9 9 - 0 0 2 , i " 9 n l' 5 0 0 6 . " 20-0 0 6 , 6 7 9 u o5 016, 152-uO5,9,,5 hC1n >H/cc I 0,2 50 o.m i 1,929 j u .259 riOI*N f y /cc 9,il>7 <,.079 g.o'jg 8,177 l , 1", 3T*NUiH0 * v t , o e v U M un 9,792 l.U b l 5,575 1.50 l.o ll 2,275 9,5)8 0,778 *6f , 0 1 9 7" 1 'V' 1 ... 9 0 6 7 .i o V.. o ? i, 8 ' >i 1 iD|H o; ? 0 U 19 ,i 1o , , 5 2 - 0 0 9 , 0 7 9 199 ( 1t j , 9 1>- o 0 2 , 57 1 o **5 0 1 1,2-J i " 0 |7| , 5u7 1o (1 1 , i, 1 7-00 1, oo 6 .1 1>i o 2 O , *2 9 - o 0 1, /2 5 0 1 J o29 , 1JO-Oo2 ,9 | 9 i( ft , o2o . 0 5 0 - 0 0 6 , 2i i 2 n i 1 00" , 2oO-y 0 1,oi)U 1oS r o l , 8 | i - u o l , o l 5 i i 5 i) a *, 2" u- 0 0 1. 1o 9 u 0 ! P. |,; . 5 5 n - u i >| , j Jo 0 0 J 0 0 2 , l o 7-06 1, 5 7 1 o.90<? 5.8|9 5.818 5.52 9 6,7169,910 0,692 0.9u2 l.o9d 0,990 1,79 7 1,697 6,500 0.091 5.871 o , 70 8 6.811 6.501 6,06 1 5.515 1,560 0,010 0 , 10c 1.750 5.105 5.550 5 0 70 7,901 6,191 5 , 0 71 1,618 1,067 1,962 1, 165 2.012 1,909 0,128 0,511 1,060 6,701 7 , 0 Ifl 0 , 170 2.007 0,020 2,096 2026 0,017 U 0 ^A i WC 4 o i 00n 1 9 J .i 2 0 u It 1 9o)5 l.9/l6 7 i J U Oa | l *P A U <1 I uu 029.100-000,202 0 0 1 0 o u , u 1o - o u 1, 19 5 6 12 , i o 1,67 o-oou , 2 19 0.127 1.115 1.66 5,876 1,710 1.865 2,000 1,650 0,810 1,697 1,006 0! 5 Oo'i.o|o-n 00,2)9 U II 1 0 il 0 0 O 1 0 9 2 06 1 00 4 00 1 0o2,58u00o,9|b Pi'61, ii 2 9 - u 0 1 , 2 16 Oil 1 , 5 6 6 - 0 0 0 , 2 8 5 oO .*'55-000.677 002 . 19 7 - o o l , 2 55 no i , o5 ) - u o 1, o 5 b oOl.lo|-0O0,7S| 2.117 2.121 1.907 2,772 1.071.. 0.760 1.782 1,617 1,022 2.106 ?.9b9 0,502 0.760 1.911 0,179 1.570 1,200 1,675 2,807 1,771 1,961 1.712 o .o ll 1 . 8o7 0,901 0,901 --1,616 5,781 0.090 1,120 1,210 u2o O O o . 6 55 -00 0, 28 5 2.571 2.121 1,6 lb pLtt,T TUl *L 12 029,100-000,02 5.751 0,72 0,51b CRMC-M AD-000122 STANDARD fRROR 1,531 0 , 7t)9 1,017 ? , 1 3T JOB. T I T L E - - - ................................... CRUSHER TPAHh EH DRILLER CAGEm a N OPERATOR ............................ .............. 0 . 6 52 1,176 2.027 0,(163 1,002 2,095 0.602 0,7Jrt 0,189 0,5<J1 1,013 0,2! H H . L FOREMAN GENERAL L ADORER CRl i SHf H OPERATOR NAWOINGE OPERATOR wheeler operator PACKER PACKER SERVICEMAN PACKMOUSF f o r e m a n FORK L I F T OPERATOR/TOW CAR L I NE R BULK CAR LOADER HOTOR-OPER, O.UOI 0.980 0,102 BLACKSMITH maintenance mechanic 0,120 0,520 0,185 1,060 fl.089 0,285 0,66d 0,701 MILLWRIGHT INSTRUMENT REPAIRMAN HACHI M13T ----------------------- MILLWRIGHT HELPER SHEET METAL WQHKER OILER - ------ WELDER . stu stics A59c 3n:S r - l Tmil) / l ' U 1 1 i [ C al' 1t CM`<1Otlf : r T ' t M t count /E U C T iIn h IC , Jf It C-' oui OI n i i S N I. Ilf u a-.st f n /C 3 * " wL t S 6 0 6 n22,6'-) 5-000, 056 OO 1 (, 6 9 , uf, 6- 009, 6 t 6 6 0 1 Di 7 . 6 2 3 - 0 1 7 . 6 2 1 h Au Ul/CL 1t>,l9d 9,nod 1 7 , S2 5 uf.OlAH FH/CC I o , btjU 9 , Ubi) 17,521 7 , " , STANCANO A V t . )> v i A 11<IN 17,5 9,qoU 6,296 0,000 17,621 0,000 ST AtlIlAHn fuso 1, 19B 0,000 0,000 1 *2 e , u 1 92n 1 >'?> 1 o2r 9 6? n6 6 ? i) 0 62 9 02i 1 '> i 2 <2 i 1 0 0Ti 6 2 2. 6 6 3- oC0 , n6 6 .,1,2 m2 6 1: 2 of, 2 on 2 o' 12 6 0 2 162 60 1 ,) 1 5. 71,6 - 0 1n. Jo6 li Jf-. 6n 1- u u ' i . 6 1h 0 16 . 6o 4- 06 0 , 9 t, / 10 2 , 6 6 2- U i >. 6 6 7 1)25.56 1-y 10,2 ! 6 O u i . 762-0 J l , 077 i) 2n , n6 3-6 17, ni) i 1t,, 19 1-0 1i , 6 70 h 5o , o o ij - u 4o , j u u I 6.2 oo 2o.o55 2.7"9 |2.2n5 66.166 1 ,66o O .M 6 |o,972 16.601 lii.ouu 16.371 26,015 22,7(39 l2,2o5 OH, l 55 2|,H6B I b . 15 16,972 ly.HHt lo,uno 25,016 21.012 11.969 7u,662 2 2 . U 16.972 1 1.122 I o, o22 lu.090 5.67 1u , 8 7 J9.1I77 9,669 U.flOI 5.152 6,981 11,706 1.851 0,000 2.110 7,670 11.772 1.290 1U.S07 1.691 9,917 9.691 1,310 o , non A9f 1 0? rM o i 9 1 0 6 1,1 6 6)1 o i ; t 6 2 . o1, 2- 00 7,2 0 0 on t n 1o . 7 l - o 1a , l u 1 27.975 10,7! 25,501 16.791 16,791 22,129 O.OUO 001 O to .7 i- o l6 , 7 1 Ul) 1 l l 20, OOV-o29, 90q Ufi 009,060-009,066 16 ,7 9 1 2 9 , 6 U'V 9.06o 16.79 1 2u,9U9 9.056 29,qU9 9,056 O , #00 0,000 0,000 5,166 0,000 n,000 0,000 0,000 *'( i Vu' 9 02 Il 26 , 9 6 9 - 0 9 9 , 06(, 1 7 . 9 0 1 1 7 . 9 0 1 10,672 7,596 'IAn T TT* L " t , I02,6b2-OD7,0 21,099 1(1,290 - . INO 0 / I I L P H l ...... l6 ,*9 l .... - 3,715 CRMC-MAD-000123 T8AHHER DRILLER - -- CAGE MAH I ! H I L L F O R E M A N --------------------------------------------------- ----------------------------------------GENERAL LAPOHER CRUSHER OPERATOR HARO INGE O P E R A T O R -------------------------------------------------------------------- ------------- hMEELER OPERATOR packer PACKER SERVI CEh a n ----------------------------------------------------------------------- ------------- packmouse foreman FORK L I F T OPERATOR/TOH MOTOR O P E * , ..... ......... .............. j MAINTENANCE HECHANIC ! m a c h i n i s t --------WELDER FINAL REPORT ILLUSTRIAL HYGIENE STUDY OF THE GOUVERNEUR TALG COMPANY, NUMBER ONE MINE AND MILL Balmat, New York Volume II Talc Bulk Sample Analyses By NICSH, W.C. McCrone and Mt. Sinai School of Medicine Department of Health, Education, and Welfare Center for Disease Control National Institute for Occupational Safety and Health Division or Surveillance, Hasard Evaluations and Field Studios Cincinnati, Ohio C RM C -M A D -000124 Electron Microscopic Analyses of R.T. Vanderbilt Talcs Collected from Talc Suppliers Analyses Performed By John M. Dement Ralph D. Zumwalde Date October, 1976 Department of Health, Education, and Welfare Center for Disease Control National Institute for Occupational Safety and Health Division of Surveillance, Hazard Evaluations and Field Studies Cincinnati, Ohio CRMC-MAD-000125 INTRODUCTION As a part; of ongoing research by the National Institute for Occupational Safety and Health (NIOSH) concerning health effects of occupational exposures co talc and as requested by the Occupational Safety and Health Administration, seven bulk talcs produced by the R.T. Vanderbilt were analyzed for asbestos content. These talcs were obtained from independent talc suppliers and have been "certified" by Vanderbilt not to contain asbestos. Samples were analysed for asbestos content by analytical electron microscopy. The following para graphs describe sample preparation and analytical methods employed along with results CRMC-MAD-000126 -s?'fife' i- METHODS Given in Table 1 are descriptive data for the 7 talcs obtained and analyzed including source and NIOSH sample number assigned. Samples for transmission electron microscopic analyses were prepared by dis persing the powder samples in ethyl acetate by ultrasoneration. Approximately 10 mg of each powder was placed in 10-20 ml. of ethyl acetate followed by vigorous ultrasoneration for 10-15 minutes using a cell disrupter. Samples were prepared using a micro capillary tube to place a drop of the solution onto 200 mesh Formvar/earbon substrate copper electron microscope grids. The ethyl acetate was allowed to evaporate in a laboratory clean hood. If neces sary, an additional drop of the solution was used to insure sufficient material for efficient analysis by electron microscopy. Blank grids were prepared in the same manner as the samples. ; Samples were analyzed by first scanning the entire grid at low magnification to ascertain the suitability of the preparation for analysis. At a magnifica | tion of approximately 17,0Q0x, all particles with an aspect ratio (length to diameter) of 3 to 1 or greater were identified using both selected area electron diffraction and energy dispersive microchemical analysis for fiber identification. A total of 25 to 50 individual fibers were so analyzed for each sample. A JEOL, JEM 100B transmission/scanning electron microscope equipped with an EDAX energy dispersive x-ray analyzer was used for all analyses. Electron micrographs of typical fibers along with their diffraction patterns <:.r '-d and x-ray spectrum were recorded for each sample. CRMC-MAD-000127 rrrp Table 1 S o u r c e s o f R.Tt V a n d e r b i l t T a l c s P r o d u c e d at the Gouverncur Talc Company, Number One Mine and Mill and Obtained from Suppliers Product Name Nytal 300 Nytal 400 5X 325 X FT 3X Source Crone Chemical P.O. Box 14042 Houston, Texas 77021 Paul Crazier Company 1115 Silver St. Houston, Texas 77007 NIOSH ft 001 002 003 004 005 006 007 CRMC-MAD-000128 RESULTS AND DISCUSSION Results of all analyses are shown in Table 2 and typical micrographs of fibers in these samples along with electron diffraction patterns and x-ray spectra are shown in the Appendix. Based on their selected area electron diffraction patterns, fibers were classified as positive amphiboles, positive chrysotile, non-asbestos or "ambiguous" meaning that the pattern w j :; not sufficiently clear for positive identification. The energy dis persive x-ray spectra were used to classify the amphiboles as to type and for further confirmation of chrysotile identification by electron diffraction. As shown in Table 2, results of these analyses show all talcs analyzed to be of essentially the same fiber composition. The major fiber component is asbestiform anthophyllite, ranging from 67 to 88% of the fibers present in addition to fibrous tremolite (4 to 12%). Aspect ratios for these fibers ranged up to 1000 to 1, with the longer, thinner fibers being anthophyllite. Trace quantities of chrysotile were found in two of the samples. Chrysotile fibers observed were small in diameter (< 0.1 urn' and short in length (most < 1.0 um). CRMC-MAD-000129 Table 2 Summary of NIOSll Electron Microscopic Analyses of Talc Produced at the Gouverneur Talc Company Number One Mine and Mill Samples Obtained From Talc Suppliers ' ! -VJO N y : 1 100 r / >: [` 325 nge of 11 jtr Aspect tios 3/1 Co 1000/1 1 / 1 to 1 0 0 / 1 5 / 1 to 1 0 0 / 1 a/i to 8 0 / 1 5 / 1 to 1 0 0 / 1 i/i to 5 0 / 1 3 / 1 to 5 0 / 1 Fiber Identification (Percent) Posttive Amphiboles Tremolite Anthophylli te Positive Chrysotlle Non Asbestos 8 88 N.D. 4 12 72 N.D. 4 11 80 Trace 4 6 80 N.D. 2 12 67 N.D. 4 16 72 N D. 4 4 88 Trace 7 * Selected area diffraction patterns not sufficient for positive identification ND - None Detected CRMC-MAD-000130 Not* Identified -- 12 5 12 16 8 -- CONCLUSIONS Using present "state-of-the art" techniques for asbestos fiber analyses, all 7 talcs analysed demonstrated large quantities of asbestiform tremolite and anthophyllile to present. Only trace quantities of chrysotile were detected in 2 of the 7 talcs. Based on these analyses, all talcs analyzed should be lobciC'd with the OSH A asbestos warning label. CRMC-MAD-000131 APPENDIX Electron Micrographs, Electron Diffraction Patterns and X-Ray Spocta for Typical Fibers in R.T. Vanderbilt Talcs. CRMC-MAD-000132 SAMPLE ,001] .ut *4i(i4I Im * f $ i 1 fn \ (V.V m '-Y'.1-' A V V 'r.4 ? . y- -.vi-'.! '!"3 N hr-`.'.>!>-.?I t o h L - M ; - . ;. ,'J Ligi!* I r"-...."'7 |* V li ', 3V' . . . : i , i *'.* > Mngnif icai:ion 1,700 :: IO Micron CRMC-MAD-000134 h MAGNIFICATION 3,-000 X 1 MICRON - 10 MICRON --------------------- C R M C -M A D -0 0 0 135 j MAGNIFICATION 3,000 V. 1 MICRi _ i < '<' " A V, Magnificacin 10,000 X 1 Micron c* m c -m a d - SAMPLE.^002 Mcrnir icaticn 10.000 X 1 Micron Magnifieacion 1,700 X ' 10 Micron |-------- 1 SAMPLE 003. : Magnificacion 10,000 X 1 Micron Magnification 5,000 X 1 Micron CRm c -m a d -ooo140 SAMPLE 003 CRMC-MAD-000141 MAGNIFICATION 3,000 X 1 MICRON 10 MICRON ----------- Magnificacion 10,000 1 Micron Magnification 10,000 X 1 Micron CRMC-MAD-000146 l'y.'-,., .`n fc ' tW L . a , `I "ij'r.'r' i 1 /1 ' > > ." . w' ' ....... ..s/:.u^icrr-->* V ' % r i ; V ... V , i y . ;r . - V S' V -V * MAONiFICATIQN 3,000 X 1 MICRON _ 10 MICRON__ _____ _ CRMC-MAD-000149 ! Magnificacion 10,000 X 1 Micron y Maguification 20,000 X CRMC-MAD-000151 1 Micron CRMC-MAD-000 152 if Magnification 10,000 X 1 Micron Magnification 20,000 X 1 Micron *" C R M C -M A D -0 0 0 154 5P T / *** MagnifIcation 10,000 X 1 Micron ntav. " vjr :.**&*/ \ "V V*<K., r % 'V' ``t&X :v . i H. 'i .,.)ML-i Magnifcation 20,000 X 1 Micron *" CRMC-MAD-000155 SAMPLE 005 rraregrsj:L,m',miur- 4 t ,, :' f V--' *&* < V,'. t^'*V**VV*r,-'*-V If f''- A\ .v-`/s- t - < a IVaw3>'w >7 . ''*,*' 7- -v *: . ..v-i;vv,r. Magni!: ication 10,000 X 1 Micron C R M C -~Ma d . 00ls7 SAMPLE 6 MAGNIFICATION 3,000 X 1 MICHON -- i n M T P i? n r j.................. .... .. - VV * . '-1 J . vti ' *} I CRMC-MAD-000159 SAMPLE 0 0 7 ' * 30.&&L~Jtei&& Vfl jm V. ZiL** *^aa Magnification 10,000 X 1 Micron CRMC-MAD-000160 9 SAM. mP.LET*o. .7..4- Magnification 10,000 X 1 Mieren Magnification 1,700 X ]n wj-rnn -f C R M C -M A D -0 0 0 161 SAMPLE 007 : t MAGNIFICATION 3,000 X 1 MICRON _ IO MICRON ----------- CRMC-MAD-000162 SAMPLE 007 Mngnificjc ion 7,000 K 1 Micron ' ' C R M C -M A D -000163 SAMPLE 007 MAGNIFICATION 3,000 X 1 MICF-CN _ 10 MICRON------- !___ CRMC-MAD -000164 / ;-A\\ ' ^Of9- M O U N T SINAI S C H O O L OF M E D IC IN E oj The City Llniixrsity oj Nav York I I HT H A V E N U E A N D IU0 T M S T H E E T - N E W V O HN N in o 'l D rp tirlm tnl of i.om m utuiy . U r J it inf April 2 9 197(3 Mr. John Dement NIOSH Hoorn 027 Post Office building Fifth and V/alnut Street Cincinnati, Ohio '5202 Deal4 Mr. Dement : This report covers the results of analyses of seven NYTAL samples; 400, 3X, X, FT, 300, 325 and 5X. The seven samples were analyzed quant it4at ivcly for three varieties of asbestos minerals - chrysotile, anthophyllite and tremolite and also for quartz. Ana lytical techniques included polarized optical microscopy, .x-ray diffraction, transmission electron microscopy and scanning electron microscopy with energy dispersive analytical systems. Quantitative determinations by x-ray diffraction of the four minerals in ques tion wore made by comparison with dilution standards of these minerals. A uniform method of back mounting in which the sample is remounted and re-run four times at identical instrumental settings over diagnostic reflections has been shown to be reproducible and accurate. Quantitation of thes44 minerals was also done by x-ray diffraction in the step-scan, fixed count mode. Integrated intensities for diagnostic x-ray reflections were measured using both the back-mounting and step-scan techniques. When referred to calibration curves prepared by each technique-, the NYTAL unknowns showed 'agreement, averaging about 10% standard error. The results are as follows: NYTAL 400 SERPENTINE PHASE c,0r 14-18 TREMOLITE OjfO 24 ANTHOPHYLLITE % 2-3 QUARTZ O!of 7-10 " 3X " X " FT 300 " 225 31-35 26-30 26-30 14-18 19-23 32 50-6C 17 18 24 not detected not determined not detected 4-5 5-7 7-8 9-10 U ;' - not det/ected /" v 9-io/=7 Is 3-4 r Ma y iv c ,,. 14-18 27 7-9 8-9 Because of the largo amounts of tremolito (50-60%) present in sample X arthophyllltu could not be quant1 1 at 1 ,'ely determined by x-ray diffraction. Hmw ivorjfli'fPC?-' CRMC-MAD-000165 Mr. .John Dement chemical analysis of fibers on the SE\1 shows that anthophyllite is present. X-ray d iltract ion indicated flic presence of serpentine phases in all samples, but the 1izardite, could not be positively identified although the latter most closely fitted the x-ray putterns. Examination by TEM and SEM with energy dispersive analysis system confirmed that virtually all of the sperpentine phase consists of lizardi te. Chrysolite was detected by electron microscopy in the samples. (See accompany 1 ng photomicrographs). The samples were prepared for analysis by transmission electron microscopy by means of a technique which did not niter the size distributiin of particles. Two square:: froi.i three EM grids were scanned at 25,000x magnification on a Hitachi HU 125 microsee.pe. fibrous particles were abundant in all seven samples. Morphol ogical and ' r y . i l a 1 cleavage eha rac terist ics indicated the presence of amphibolcs . This was verified by.observing a typical layer-type selected area electron diffrac tion pattern on the fibrous particles. The layer line distance normal to the long fiber axis was consistently observed to be 5.3/?, which is characteristic of the c-axis repeat, of amphiboles. These particles were defined as amphibole and their location on a grid facsimile recorded. The specimens wore transferred to a scanning electron microscope (CWIKSCA.V) equipped with an energy dispersive x-ray spectrometer. The amphibole particles were analyzed by point count and were found to fall into two general morphological-chemical types of populations w'hich permits them to lie defined as different mineral species. The long, thin fibers (aspect r a tio 19/1 or Mono) bhotved Si/Mg in ration co n sisten t with a nthoph yllite composi tion. Those fibers contained little or no iron. Short prismatic fibers with aspect ratios from about 3/1 to 5/1 contained Si/Ca/Mg proportions consistent with tremolite. No iron was found in tremolite. ANK:si Enc. Arthur N. Rohl, Ph.D. Environmental Sciences Laboratory CRMC-MAD-000166 Chrysotile- talc standard dilution - step-scanned 0.02 degrees twu- theta over 2.66 A (00-1) reflection ( 2x 10 ) 5 / C R M C -M A D -0 0 0 167 / ifeSSP Chrysoti le- talc standard dilution 3 reflection ( 2x 10 ) step-scanned 0.02 degrees two theta over 3.66 A (004) I M1 / /y / * 'ftUvik - i i i 1 ' ! .i i,ir i : _(./ } ) , ' . - t h .L.i 1 / ! :- -',,L.: : L --.Li r .: X* j r i z : :6yii.fz~i.T i i t <i i t . : 1 i J J . ..2 3 : o /?. :: i-m H i i liil.l i l i H i t-J ij 1 1 : H ! I l i t , it l.j r n* Ai i l Xt j;U J d 7 H r l. i. 1 .i'lT .Y X 7 H I 4 - H i i - l i l i 4* .iC -' Xj' ijn ! 1 1J i 3 V i 1 h 1i 7 A f D . _ i c x a ;) 1 !.J ; j i . i / i 7 H ~ l i t i : ri ri ? --i_J_! -i-. ! ' 1 i . . i ! - : i i i : l i i. rr t : r 1 ! - .1 i_:. : i ; i j 1 n :.n . : i j ; ti. ' I : ! ; , J__ 1 1 X- : I i 1 1 1 I i l . ;H 1 1 j " , 1~.j _ l2 . ! . i 1 L : 7 1 1-L. 1 L 1 1 1 ' ; i ! 1 i i : i / ILI lu ' 112i l"i;Xj ! I ! 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I :. ! 1 : 1 . : . t I t . * I I 11! 11. : > ..fi-, i 1 i : i ! i : i ` ! r 1 I 1 ; i * i , S : i i i i ... ___ i L. i ' .1 i ' L ' _i 1 .i i ' ! i_. . : / : , ! , i 1 Fw iL & * - __ i l t > ; ___ _ if 1! i 1i ' 111 ..li!'-:' . f ` t . 1 < i . - / . i , . ! i . : 1 i I ^ 11' t * ( 1 1 >' . i:. 1I! i 1 i i ; ` i i ; i i i0 , i t , i ; i . t . ; - i . 11' . .1111 . i ' i'1 T 1 1 !iXi j-.rri-'l- \JfUt 'V\ _L-i- "? : {'. 33T!^_ y [> __ i. ~~.L~ TrTT'.''T /;-,,.;/,,i'--J;,;,^7(.:,,,.'.<, ir..-- J; ,*> ^-V' r - y. P. t , - ` Vfc,- V y '?*-'**!' fi y V v';;'; 'i. ' ^ W^ ' ' -v.' ll-'. % `i ''11; (' .1 't} ?' .fc `"il-A r'I. - V .*.**>< "' '- ." 'C ' y.-j:* -.-.-i* ':*, . - /ji.y;.*' V^I, < V:; vv'V ' ' .i- ;' : ^ . . ' ... &4-: ',. \ x*.i U # t i * p } ' . ?-- { W ^ . ' v :-i . . * 4 , . ..V; ; , ; :'1 . V ' . - 'A 7. . iJr^ '`. Jt,r * > -, Pm*T* -.V.!-v,Hl,.w.'..'. ' ,*... \V. ,.:'.'l'V';'f.c.^-I5.'J}./P. .P.:t ->.T*, f -T V!.: :V f { * P'. r1 S W y* -*> Vi-rjiaVfiti 3g r/T^i''.f V' ? s s i.wS m r n 0 ^ w y $ ::*:- "-v^''-S'}.!':?'.'.:-!'-- . . 1' ' i s S i l t i i V ? k -, H ^..jb'iir 'yyyftV f? rfc^r- ./..,>:VS> * -ir/* *1. " ' '1; ':'- U ~ '.n V r- - ^ -. .1,r. y, *>V.v J **" ^ : ' ': .'/ ': Vl jt L * M .'A4- - NYTAL X MAGNIFICATION 10,000 X (X2.5) 4 ;v iLifcaiJl'Uteij c r m c -m a d -o o 172 'NYTL Y ' .. . ... ;...'I MAGNIFICATION 3,500 X 1 (X2.5)j CRMC-MAD-000173 CRMC-MAD-000175 NYTAL FT MAGNIFICATION 3,500 X (X2.5) CRMC-MAD-000176 CIIRYSOTILE MYTAL FT MAGNIFICATION 7,100 X CRMC-MAD-000177 \ \ CHRYSOTII.E NYTAL 3!25 MAGNIFICATION 7,100 X NYTAL 3X " MAGNIFICATION 3,500 X j : (X2.5)j CRMC-MAD-OOOISI CRMC-MAD-000182 CURYSOTILE NYTAL SX MAGNIFICATION 19,000 xj - 'V ,. # $ .* * * : ,,,,i,Vai'i -*r`1-."'r , '.i>iC'-'l'<' : i'iv-}-i^ ' .. * J'`/r .V;.* ~ i 'y ^ ' fei:,; k : i; i:j'j'/*.i; ri t:*> '. ;:M $ f it , JP I v,^..V NYTAL '300 MAGNIFICATION 31,000'Xl (X 2 .5 )! fi>w nrm tiilM aaiiagB gM ga C R M C -MAD-000185 '-`5* il mrnW m VNYTAL;-300 \*: v* '~**i .,, . j 11AGNICATION .-3/500 X ;j CRMC-MAD-000186 8iooo-crm-3mD ;,c (L\ A Report to Dr. John 'Jement NiOSII Cincinnati, Ohio 45202 EXAMINATION OF TALCS FROM GOUVERNEUR DISTPACT - NEW YORK _ 12 December 1975 Date: M A Number: 4800 copy y of f waiter c mecrone associates, inc. 2820 S O U T H M I C H I G A N 4 V E N U E CHICAGO. ILLINOIS 6C6I6 CRMC-MAD-000189 TABLE OF COiNTENTS Summary Introduction Material and Method of Conducting Tests Light Microscopy X - r a y Diffraction Electron Microscopy ' Results Light Microscopy X-ray Diffraction Electron Microscopical Examination Conclusions Page no. 1 2 2 2 2 3 3 3 4 7 10 CRMC-M A D -0 0 0 190 waiter c. mc crone associates, inc. EXAMINATION OF SEVEN TALCS F R O M T H E G O U V E R N E U R DISTRICT, N E W Y O R K SUMMARY A n extensive examination has been carried out of seven talcs submitted by the National institute of Occupational Safety and Health, to determine their asbestos content. These talcs all originated from the Gouverneur District of N e w York State and were identified by n u m b e r code in the series 83775-837G1. Examination was carried out by a combination of light microscopy, using both polarized light and dispersion staining, x-ray diffraction, and electron microscopy combining electron diffraction and elemental analysis. The results of the examination showed the presence of asbestiforra amphibole in all seven samples. The amounts of the total amphibole and of the fibrous amphibole differed between the various samples. In all cases the principal asbestiform amphibole was identified as tremolite, but this was of a low calcium variety, containing approximately 2 - 3 % calcium. In Sample 83757, x-ray diffraction examination suggested that a small percentage of anthophyllite was also present. Examination by light microscopy, however, could not conclusively differentiate between anthophyllite and tremolite in this sample. The identification of tremolite rather than a calcium bearing anthophyllite in'all samples was based on the extinction angle, observed under crossed polars, of the fibrous amphibole. _________________ CRMC-MAD-000191 . - 1 - waiter c. TiccrGneassociai^e.nrj. INTRODUCTION The National Institute of Occupational Safety and Health is currently sponsoring a study of occupationally related disease in the talc industry. A s part of this study, Walter C. M c C r o n c Associates, Inc., has been contracted to study and characterize the raw talc ores. The present work is related to this major program and is concerned with a study of seven specific samples from the Gouverneur talc ore body. Materia 1 and M o t hod of Conducting Tests Seven talc samples were submitted to Walter C. M c C r o n c Associates, by .John Dement of NfOSH. These samples were identified by numbers running in sequence from 83755-837G1. No indication was given of the sample location within the Gouverneur talc body. The samples were examined by light microscopy, using both polarized light and dispersion staining,- x-ray diffraction, and transmission electron microscopy combined with electron diffraction and elemental analysis. Light microscopy Permanent mounts were prepared for all seven samples, using Aroclor 54-12 as a mounting medium. These preparations were examined under partially uncrossed polars to obtain a general indication of the mineral types present together with their shapes and sizes. Samples for examination by dispersion staining were prepared using Cargille high dispersion refractive index liquids with n values of 1.550 and 1.605. The lower refractive index was used to examine the serpentine content of.the-talcs; the higher value was chosen to enable identification of the amphibole present. Examination by dispersion staining was at a magnification of approximately 200X in plane polarized light. X-ray diffraction For x-ray diffraction examination, samples of the powders were packed into aluminum cup holders and placed in the Norelco diffractometer. The samples were rotated around an axis perpendicular to the axis of the diffractometer which was scanned through a 26 range from approximately 6 to approximately walter c. me crone ; i i". -2 - CRMC-MAD-000192 G0 with a scanning speed of 1 per minute and a chart speed of ]/2 inch per minute. Cu radiation, nickel filtered, was used at an accelerating voltage of 42 kV, and a current of 25 milliamps. The quartz content of the samples was determined by step scanning through the 2. 25 A line for quart/ and c o m paring the resulting data with that for "spiked" standards of quartz in talc. The step increment was 0.01, 20 with a counting time per step of 50 secs., an 8 sec. time constant and a chart speed of 1/8 inch per minute. Electron microscopy For electron microscopic examination samples of the powder were suspended in isopropanol and lightly ultrasoncratcd. A drop of this suspension was placed on carbon coated Nylon grids. Examination of the samples was carried out in a combined elcctron-nucroscopc-microprobe-analyzer, E M M A - I V . The samples were examined and photographed at several different mSignifications, electron diffraction patterns were obtained from typical fibers present and energy' dispersive x-ray analysis was performed on these fibers. RESULTS 1) Light microscopy The following general statements can be made: All the samples contained a serpentine which, on the basis of dispersion staining and morphology, has been identified as lizarditc. Chrysotilo (tire asbestiform variety of serpentine) and antigorite were not detected. All the samples contain tremolite identified by dispersion staining and polarized light microscopy and, although it would be possible to miss a small percentage of anthophyllite particles,since most anthophyllites give nearly the s a m e dispersion staining colors as tremolite, appreciable amounts of anthophyllite would not be missed because a significant number of particles would lie in the proper orientation for positive identification. With the exception of an occasional particle in Sample SC757, all the particles which showed Lhe tremolite/ anthophyllite dispersion colors showed oblique extinction under crossed polars - 17-1S3), thus identifying them as tremolite. j waiter c. mecrone asscccres, inc. - 3 - f All samples contain laic in a form which. look like fillers. These give typical talc colors by dispersion staining. The majority of these tnlc fibers are apparently long talc rods. These talc fibers are especially lung in Sample S:i75`. Most samples are believed to contain a little quartz on the basis of the light microscopical examination. It is difficult to put an accurate value to the amount of quartz present, .since it is extremely difficult Lo distinguish between quartz and lizardite under dispersion staining conditions. A calculation of the percentage of amphibole present and of the portion of this amphibole which was fibrous was m a d e as follows. First the portion by volume of the total tremolite present as fibers was estimated taking cognizance of both .'article size and numbers present. Subsequently, 30 fields, in each sample were examined in detail and the percentage by area of the total particle area occupied by amphibole particles was estimated. Table 1 summarizes the observations m a d e by light microscopy. X-ray diffraction All samples showed the presence of talc, an amphibole and a serpentine. Inconclusive evidence of quartz was detected by x-ray diffraction on the normal scan. By step scanning, however, low levels of quartz were found. The quartz data arc presented in Table 2 and Figure 1. The serpentine minerals are difficult to distinguish from each other by x-ray diffraction. A paper by Mumpton^ indicates certain lines which m a y be used to distinguish the three serpentine polymorphs provided that the samples are relatively monomineralltc. Specifically, M u m p t o n mentions that lizardite is characterized by a strong doublet at 1.531 A. This doublet has indeed been observed on our x-ray diffraction trace, thereby confirming the light microscopic identification of lizardite by dispersion staining. 1 Characterization of chrvsotile asbestos and other m e m b e r s of the serpentine groun of minerals, Siemens review XLI (1971) 7th special issue, X-ray and Electron Microscopy Mews. - 4 - welter c. mecrone associates, met CRMC-MAD-000194 Sample Tabic I S u m m a r y of Light Microscopical Data Njsj\ ipo 83755 tN uicy _ HC 8375G H 83757 83758 X 83759 Ff 83760 XX 837G1 Total trernolite (% of sample by area) 25-30 Fibrous trernolite: (estimated % by vol. of total trernolite) 5 Quartz + Serpentine + Talc "fibers" (rolls,shards etc.J -1- Comments 15-20 20-25 25-30 25-30 15-20 25-30 25 8-10 5 possible .. + + 1 ? - +? 1 25 10 -? . +? + ? + probable probable + + + +(long) + + large trernolite plates large particle size small particle size * I CRMC-MAD-000195 V<-r~nx I l I * j I Sample Quartz Content** Content tfcmolitc . Table II Tremolite and Quantity Content of Talc Samples 83755 83756 S3757 83758 83759 83760 83761 2% 1/2-1% 1 1/2% ~1 1/2% <1/2% below 1/2-1% detection f limit >10--50% 50-00%*? 40-50%* '~G0% >50-60%* 50-60% 40-50% ** Step scanning data. * Indicates possible anthophyllitc present in addition to tremolite. C R M C -M A D -0 0 0 196 This leaves only the amphibole to be characterized in all seven samples. The primary amphibole observed is tremolitc. The diffraction lines observed arc consistent with A S T M Card 13-- 137 for tremolitc and with published data for tremolites. from the Gouverneur district. In one sample, however, Sample 83757, a distinct side peak on the tremolitc 8.110 line is observed and if is believed that tills side peak is due to the presence of s o m e anthophyllito. l.css distinct evidence of tins side peak is also present on Sample 8G75G and possibly also 53759 (see F igures 2-8 for a com parison of the 0-12, 20 range on these samples). As is clear from these figures, in addition to the side peak attributed to anthophyllite there is considerable variation in the ratio of talc to amphibole in these samples. A n attempt to quantitate this relationship in terms of percentage of amphibole present is also given in Table 2. Electron microscooical examination Electron microscopical examination showed that all seven samples contain substantial amounts of fibrous material. This was highest in Sample 83757 and lowest for Samples 8375G and 83701. Several typical electron m i c r o graphs showing general areas of the samples are appended to this report (Figures 9-17). The electron microscopical examination concentrated on the fibrous material and an attempt was m a d e to estimate h o w m u c h of this m aterial was in fact asbestiform, that is, a fibrous 'amphibole as distinct from the fiber forms of talc consisting of ribbons, shards, rolls, etc. This examination was conducted both by electron diffraction and by elemental analysis using energy dispersive x-ray. The results of these examinations are summarized in Table 3, the estimated percentages being based on occluded area. S o m e typical electron micrographs, diffraction patterns and energy dispersive x-ray spectra are appended. In none of these fibers examined was there a particularly high per centage of calcium noted; however, calcium was observed at the level of the order of 1-3% in all the amphibole fibers examined. The only conclusion which CRMC-MAD-000197 _ 7 _ waiter c. me crone associates, inc. i *?tP ` . V. fm ,4m m Table HT Electron Microscopical Estimates ol Fiber Content Baniple 83755 Total libers -10% Fibrous amphi bole (as % of total sarnple) <5% 8375G -10% <5% 83757 S3758 `- 4 0 % -30%. 83759 83760 83761 -5-10% -20% -- 10% 15-20% 10-15% <5 % '-- 5 % <5% JI 4 f li * | - 8 - CRMC-MAD-000198 Table IV Over .'ill Data S u m m a r y Sample 83755 8375 83757 83758 83759 83760 837G1 Total fiber;;(TH M) 10" Amphibole fibers1 (TEM) <5% Total amphi bole12345(XRD) Total amphi bole3 (LM) 40-50% 25-30% Fibrous a m phibole'1 (LM) Serpentine 2 '5 (XRD) 1-2% 10-15% Quartz^'^ (S.S. X-RD) 2% 10% <5% 50-60% 15-20% 3-5% 10-15% 1/2-1% 40% 30% 5-10% 20% 10% 15-20% 10-15% <5% 5% <5% 40-50% ~60% >50% 50-60% 40-50% 20-25% 25-30% 25-30% 15-20% 25-30% 1-3% 1-2% <1/2% 3-5% 2-3% 10-12% 10 -12% - 1 5 % -20% -- 30% ~1 1/2% -1 1/2% <1/2% B. D. L. 1/2-1% I NOTES: 1. Based on occluded area 2. Estimated weight percentage 3. Based on occluded area 4. Derived from estimated % of total ampnibole which was fibrous. 5. Identified as lizardite by light microscopy 6* S,S* X R D = Step scanning x-ray diffraction See also Table I. CRMC-MAD-000199 - 9- can be drawn from the electron diffraction and energy dispersive x-ray analysis is that one has a fibrous ainphibole of the trcmolite or anthophyllitc t\-pe. It is generally not possible to distinguish between trcmolite and anthophyllitc by elcctrcji diffraction and one would therefore be tempted to suggest that the fibers were anthophyllitc with a truce amount of calcium. Taken in conjunction, with the light microscopical examination, however, during which a diligent search was made, particularly on ample 83757, for fibers which might be anthophyllitc rather than trcmolite, one is forced to the conclusion that, rather than being a calcium bearing anthophyllitc, the fibers are in fact a low calcium tremolite. The aspect ratios of m a n y of the fibers observed are quite high and numerous fibers, such as those shown in Figures 20, 22, 24 and 30 showed the classic fibrous structure of the asbestos minerals. There 13 no doubt in our minds that these are indeed asbestos fibers rather than cleavage fragments of a m o r e massive amphibolc. Massive forms of the amphibolc are, however, present and the fibrous amphibole content represents only a fraction of the total amphibole content of the samples. CONCLUSIONS Table 4 .summarizes the results of all the investigations which we have carried out. In answer to the specific question, "Do these particular talc samples contain any asbestos minerals?", the answer m u s t be an unequivocal yes. The asbestos mineral present appears to be a low calcium tremolite and is definitely asbestiform by any definition of the word. The asbestos content in the samples varies from less than 5% to approximately 20%, based on occluded areas observed in the transmission electron microscope. Respectfully submitted, Ralph J. Hinch, Jr. Research Chemist hfu. Lucy B. McCrone Senior Research Scientist tichard J. Slumps Research Chemist - 10 - IanM. Stewart Manager, Electron Optics Group welier c. me crone cssociares, inc. FIGURES 1 THROUGH 40 EXAMINATION OF TALCS FROM GOUVERNEUR DISTRICT -- NEW YORK CRMC-MAD-000201 Figuro 1 Step scanning data for quartz -.7i 7 \ ( y_ - o ln .j v : Sample S0755 (001) Talc (a-SiO^-i-) Sample 8375G (002) Talc (a-SiO^-) j'Il I .. .I *m S-3 " Tu-.os': zo.ss' Sample 83757 (003) Talc (u -SiO +) Sample 83758 (004) Talc (a-SiO + ) 2 ':& I 00 -80 -- .... 7 0 /I:^v ff'f'-' 1 1 ' VoS . ___ __ f\ v9 * o ''oA1ismp V-J 1#M| f J '4 ..... 60 50 `H -- A O ____ _____- 3 < \ -20 . - V - >v ''W - v V ' y . ---- 1 0 - n ---- o CO waiter c. me crone associates, inc. a Vl to General view (1!), QOOX) Figure 13 83759 General view (12.000X) CRMC-MAD-000214 i +-r* ' .< ' \ It x-'r l.'-Gv . - - i r ^ -'* --. - ; *.l1. VV*/ '1.V " i ' v i a ;;' V v V l V A V - V V gv/ r:,*.*A'-.'-a; ^r,i*.v-H .'', s a ; i i p ` v : ;,- v W ..;}i`V V : ^ '/iv. '* .' r .*' Vi > .i v *;i,o>v. . . ... 'v4#jf # f# Figure 15 83760 General view (30,000X). '* I ^ ; i _Z i r : . . . . . i C R M C -M A D -0 0 0 2 16 Figuro IG 837l Geiler;!! view (12,000X) CRMC-MAD-000217 r / k Figure 18 S3 7."5 Tromollte fiber (30, 00OX) CRMC-MAD-000219 t /;vv;< i'^U iVV/; tfls S ? ?i r :;.;'Xy -* n --i: : r ^. m y - '.rJy^r'.'F ` { .. .; ;` F'; ' I*,r-*Ajfi.*'* *,'?* '.*'tj',v.` f`,V'*o r '4f#<v ' . .'.##,* -;' v,,... t-*-v!**v* , f?-:>r) ify .-^iv*.;*...V{:.*-7. ,v* *--v -i .v* T v*:*.rVt''-V' '* -`-.i r\x>.^,'s*'.,. 1 .'-Vs;:;;*./y!V Y1 rr:.&:-&.&.if ..../.`.`ic-v.'.-v-.O:/:V ; Ci`v''iV'S.C f ,Y '.. ,<> T i 'C- , 'ij.'--..AV nV5-/7Wv.J4if5 Ir'.C'i--'v')-!v ,y^ .^Cai c. '.;! :',;' V --`I- ; < . ;c.YVcCrjVyr.if>I.r-.*;i./'i ' . i"?:''>? ; z'fci ; '-Y-V--'-v:-.-j.- -.:/ l ^'c; A-- .,i v, . S - / ' j ! r ; ' ' n'. >! "/ <; ;,> ,. .'I'i- - -: . 7 v _ J . . . -. ; .- / , .. i, * >:: ., . - , . -..--i *i ( / .'C-y',VJ ,; 'v' v'vY- H't *'>'$''.*. '.% 'i.,`'..i.! v '' [T*.f-1 fy 'jj . '/i s'"''I>'" r t'/''.li"vVi'It'tif**'''iVT ``1,t'.^\; jv<,,>"?c';` ^ J^.J"V Ati..';.',`:^1 `rivVTiivVi^fa^il f> Figure 19 S3755 Diffraction pattern of trernolite fiber shown in Fi^fure IS. CRMC-MAD-000220 Figure 21 33755 Diffraction pattern of tro moli to fiber ylioMii in Figure 20. CRMC-MAD-000222 4 ' *w -tr ' .*y. 'y i-ft * Ntir 4-* '</ !;- W <`kj. . w *:- :''k,*4if ..'w.(V,. .*'.' v . S. .'' h,,-`ii,.' .V Figure 23 33755 Diffraction pattern of tremoliti liber shown in Figure 22. CRMC-MAD-000224 1 Figure 24 33757 Tremoli to bers (30, OOX) CRMC-MAD-000225 Figuro 29 33753 Di l'irac tic.-i pattern of tremoliti iiber shovm in Figure 23. C r m c -M a d ^ 000230  < Figure 30 83701 Tremol ite fiber (0 0 , OOOX) CRMC-MAD-00023 1 Mir Si Figure 53 Sample 5:175."/ - Probe of fflier in /bolo i3A I'i and Cu are background ,< i_ Figured;; Sample 53756 - Probe of fiber in photo -lA - Ti and Cu are background CRMC-MAD-000233 Figure 34 Sample S3757 - Probe of fiber in photo 9A - Ti and Cu in background CRMC-MAD-000234 Figure 35 Sample 83753 - Probo of fiber in photo 15A - Ti and Cu are background CRMC-MAD-000235 Figure 33 Sample 33739 - Probe of tab' CRMC-MAD-00023 8 w EST*; &^Sj Mg Si Ca Ti , U V - t i'Sv' '" f - -- , "; S'}'*# Cu gure 39 Sample 83700 - Probe of photo 21A fibers Tt and Cu are background Figure 40-Sample 63701 - Probe of fiber shown m photograph 2 1A CRMC-MAD-000239 Desert; Minerals Inc. January 25, 1973 F. J. Solon, Jr. H. M. Jackson E. M. Fenner W. B. Reitze >y Dr . G. Wright Dr . S. Speil Dr . J. Leinewebe Dr . E. Marriner R. P. Carter W. L. VanDerbeek P. A. Mart inson H. K. Keefe R. S. Lamar N. B. Scheffel E. B. Smith R. T. VANDERBILT ACTIVITIES FDA - OSHA REGULATIONS On January 11 as arranged by Norman B. Scheffel, a meeting was held at the R. T. Vanderbilt Now York offices to observe a presentation of the field by RTV to Government agencies concerning talc vs. asbestos. In attendance were Dr. Spell, R. S. Lamar, N. B. Scheffel, and E. B. Smith. The presentation consisted of a series of slides as photomicrographs comparing ) j Vanderbilt New York State talc (Nytal 100, 200, 300, 400) , California talcs < (Westal 101, 303, and 404), and beneficiated California talcs. Compared also - i were slides of asbestos minerals. In this presentation, it is the objective of Vanderbilt to establish that tremolite is non-fibrous and non-asbestoform ' in order to obtain an amendment or variance in the OSHA regulations to exclude , tremolite. The presentation did contrast the particle shape of their talc j mineral as compared to asbestos fibers but lacked any real scientific evidence to differentiate current definitions. Vanderbilt has made this presentation to the New York State Bureau of Mines attended by Dr. Jacquelin Messite, Merley, Sheffield, and Stein. Kleinfeld not present due to his retirement. Vanderbilt has also made this presentation to Earl Goodwin at the U. S. Bureau of Mines. They have also made these presentation to EPA at Durham attended by Mr. Arthur Stevens, Deputy Director of the Bureau of Mines and Safety. Vanderbilt feels that they have cast some doubt on the definition and are hopeful to pursue Government agency toward a new definition of "commercial asbestos" as opposed to tremolite as an asbestos mineral. Vanderbilt has also been in communication with the A.S.T.M. Committee D-l-3107 concerning extender pigment. Pj'esentation made by Mia n Harvey at Miami was oriented towards the removal of tremolite from the asbestos definition. It is their hope to obtain A.S.T.M. approval and use this approval with other Government agencies. Vanderbilt has justifiably been reluctant to tackle NI0SH until more confidence is developed in their presentation. Dr. Speil was of considerable help at this meeting in pointing out the pitfalls and errors in Vanderbilt's thinking. It was concluded that the attack on tremolite vs. chrysotile must be medically oriented as opposed to a simple fiber definition or redefinition. Speil suggested that a more appropriate approach would be to obtain an exclusion CRMC-MAD-000240 j auuaty l j , l'-j /J , rage i of tremolite based on scientific or medical reasons as opposed to a redefinition separating tremolite from chrysotile and/or asbestos. However, Vanderbilt intends to pursue the subject by enlisting the Talc Industry Association's help in developing an acceptable definition of talc, asbestos, etc. at the meeting scheduled for February 5 in New York. In view of the expertise obtained by J-M people in this mineralogical area and the Government communications area, we urge that Dr. Spell and additional environmental people at J-M attend the February 5 meeting in New York. Attached to this memo are some definitions that Bob Bacon has extracted from various encl.ydoped!as and from the Federal Register concerning asbestos fibers. It is in tills direction that RTV intends to proceed. We certainly question this attack and increased help from J-M to guide this program properly and scientifically and not to the detriment of the talc industry. Karl B. Smith EBSrcks CRMC-MAD-000241 Greenwood Pa -a 1 North January 31, 1973 P. A. Martinson - 2 West j i LIE ms' EBS~ T ? " -- TER JEC RFI3 S RM DEN o id t * J. -- 1RON AJM -- OHM KJB fjr ' YOUR MEMO OF JANUARY 23, 1973 TALC PRODUCER'S ASSOCIATION (PROPOSED) R. T. VANDERBILT COMPANY .Attached is a proposed draft of a letter v/hich is intended to indicate our (-M) stand on this subject. We agree that this should trobably go out over 7. J. Solon's signature, h.- fee L 'lost s .;oi'.v!l y , however, that both S. Spoil and V. C. Strcib should approve of the technical soundness of the letter before it is sent. We believe that the letter should go to the presidents o all of the talc producers in the United States, to the Talc Producer's Association, and to the appropriate A.S.T.M. Committee. R. S. Lamar ain cc : W. L. Vanderbeek F. J. Solon H. R. Keefe E. B. Smith R. F. Bassett S. Spoil w. c. Streib R. P. Carter J. M. Sharratt - 2 Viest - 1 West - 2 West - Long Beach, - Long Beach, - 3 West - 3 West - 5 West - 2 We st Carson i Carson crmc-mad. i r \ *'*/Avy ot. r n o i t M BOOO I AT J C m .M S O li AVE, k t h o ' v , M e m i g a n 4 n 2 u r t i o f t * j i .1 , ? o n o o n 1NTERNATI0KAL UNIO, UNITED AUTOMOBILE. AEROSPACE l AGftCULIIJEAL IMPLEMENT WORKERS OF AMERICA.u \ LEONARD WOODC OCX, n s s i o t M EMU MAZEY , s f c i c u u m f a s u i i * V I C f .p r $ I D ! II I 5 PAT GREATHOUSE: KEN HANNON DOUGLAS A. FRASER DENNIS McDERMOTT IRVINC HLUESTONE ODESSA KOMER MARC STEPP February 2, 1976 M r . P c t e r l i r o 'A , St a ff M a n a g e r Standards Development Division A STM 1916 R ace S tre e t Philadelphia, Pennsylvania 19103 Dear Mr. Brown: I would like to express m y d isagreem ents with the apparent ASTM consensu ; ex p re sse d in com m ents on the proposed OSHA rules on asb esto s. T h e se c o m m e n ts w e re subm itted on behalf of C o m m itte e E -3 4 . There arc many item s in the comments with which I disagree. Given the s h o r t n e s s of t im e , I will c o n c e n t r a t e on Sections 3 and 12. The o rig in a l OSILA a s b e s t o s s t a n d a r d w a s e s s e n t i a l l y a n a s b e s t o s i s s t a n d a r d t r a c k i n g the B ritish regulations (NIOSH, 1972). That 2 fib re/cc asbestos standard was based on a single B ritish study w h i c h found t h a t t h is l e v e l wou ld r e d u c e a s b e s t o s i s b e l o w 1%. ( B r i t i s h O c c u p a t i o n a l H y g i e n e S o c i e t y , An n . O e e . I-Ivg. 11 47 (1968)). R e v i e w of this data by Lewinsohn, the company physician, found m ore eases of asbestosis than previously rep o rte d . (If. Lew insohn, Royal Soe. Health J . , 92, 69 (1972). D r . M c D o n a l d r e p o r t e d c o n s i d e r a b l y l o w e r i n c i d e n c e o f d i s e a s e wTTTi e x p o s u r e l e v e l s t h a n o t h e r i n v e s t i g a t o r s . ( M c D o n a l d , et a l , A r c h . E n v . H e a l t h , 28 61 (1974)). McDonald's work is c o n tro v ersial and at odds with the work o fo th e r r e s e a r c h e r s . This parag rap h should at le a s t face the issu e of the bulk of data such as those reported by Sclikoff (Sclikoff, et al, Proc. of Lyons C onference, 1972, 209). This standard was not proposed to protect against the carcinogenic action of a sb esto s. The reports by Sclikoff of a s b e s to s -re la te d c a n c e rs and even lung d is e a s e am ong f a m ilie s of a s b e s to s w o r k e r s , due to a ta k e -h o m e effect, indicate that low levels of exposure a r e indeed a cause for concern (Anderson et al, N. Y. A c a d . S c i , in p r e s s ) . CRMC-MAD-000243 V ATc.ri.ofln Society for Tenting nrd Materials Committoe E 3A Task Group on Naturally Uccuring Inorganic Fibers Minutes of the 16th meeting New York Airport 2 March 1977 PRESENT The list of those present is presented in Annex- 1 AGENDA The agenda is presented in Annex 2 BUSINESS 16.1 Chairmen'.opening remarks 16.1.1 it was announced that the meeting hall was sponsored by the R.T. Vanderbilt Co. Ltd. Appreciation wan extended on behalf of the Task Group 16.1.2 It was mentioned that excuses for absence had been made by the following members: G.F.A. Brink, w.h. Cooling, M. Grinunard, P.A. Filteau, and J. L poutre. 16.2 Minute- of the last mooting 16.2.1 Photocopies of hand-written minuten wore distributed, with apologies. The minutes were read. 16.2.2 These minutes were adopted, as read. 16.3 Business arising from the minutes 16.3.1 Objections were raised with regard to item No. IV.7.3 concernid,-, the suggestion to replace the monitoring method by a reference to the NIOSH method. This suggestion was firmly opposed on the bari3 that the NIGSH method was inadequate, and that the proposed monitoring method, as presented in Annex A3, differed significantly on the following points: CRMC-MAD-000244 2 or not the cation . Section A3.1-3 Regarding aspect ratio. Section A3.3.2 Concerning the need to verify wether fibers counted are asbestos. Section a 3.A with regard to definitions. Section A3.5 With regard to criteria for identifi -Section A3.9-2 About the mounting technique. 16.3.1.1 monitoring method. Accordingly, it was resolved to ret.-.in the present ]6.'.2 Goridf rning .item 13.3.19.1 in the minutes of the proviouo meeting, concerning justification for 0 double nt/mdnrd, it was sug gested that the standard be; justified on the basic that OSHA enforces 0 two-fiber limit for manufacturing and end-use applications while MESA enforces a five-fiber limit for mines and mills. This suggestion was not adopted, 16.3.3 It was proposed that the statements in the minutes of the previous meeting (15.3.19.1 mentioned above) be modified by stating the facts that reliable epidemiological data exist, for mines and mills, and that the standard will remain under continual review. 16.3.A Further to Section 16*3.1 above, last item concerning the mounting technique, it was stated that in practice, the OSHA enforce ment laboratories use a variant of the NfOSH method. It was also reported that MIOSii teaches a somewhat different method when training tegnologists from industry in the techniques of fiber counting,-at Cincinnati. The possibility that MlOSH may have changed their metho dology at the laboratory level, was raised- The Recording Secretary was directed to enquire about this from Dr. J. Finkle, Director of NIOSH. 16.A Letter ballot on exposure limits,and adoption of the Standard on occupational F.xposure to Asbestos. 16.A.1 It was announced that the ballots had not yet been fully returned; having been mailed only rocently. 16.A.2. It was resolved that the following action would be taken depending upon the outcome of the lettor ballot: 16.A.2.1 If the ballot favors a five-fiber limit, the statements on exposure limits such as contained in the ninth draft would be adopted. 16.A *2.2 If the ballot favors a two-fiber limit, then statements on exposure limits such as contained in the tenth draft would be adopted. CRMC-MAD-000245 - 3- J6.A-2.J If the ballot favors a dual limit, then a statement callin'* for a five-fiber limit in mines and mills, and a two-fiber .limit in manufacturin'' and end-use industries, would be adopted with a statement to the effect that the threshold limit value can be more; closely approached in mines and mills because of the availability of reliable epidemiological data. 16./,.3 It was proposed that Section 5.-1.1.1 of the tenth draft be revised to eliminate the requirement for initiating medical surveilance at one half of the exposure limit, i I. was argued that this in effect creates an additional more stringent standard. This proposal was adopted by the Task Group but it was felt that this decision would have to be confirmed by a letter ballot of the Task Group. Accordingly, the Recording Secretary was directed to mail out such a letter ballot. 16.5 Regulatory nitration in England. 16.5.1 It was reported that to react against unnecessarily stringent A newspaper article that appeared in the 1977 was mentioned (refer to Annex 3). organized labor in England has begun regulations on asbestos exposure. Daily Telegraph on 2U February 16.6 Centers for the study of microscopic mineral particles. 16.6.1 It wan announced that the U.S. Bureau of Mines had created a Unit for Study of Microscopic Mineral Particles, at College Park, M.D. It was explained that the main purpose of this organization was to identify minerals for regulatory purposes. It was added that their first tank would be the idenMfication of asbestos fibers. 16.6.2 General approval was voiced. 16.6.3 It was reported that the EP,1 (nnvironmontal Protection Agency) have endorsed this endeavor. 16.6./, it was also reported that Tibor and Zoltai of the University of Minnesota, strongly faver the establishment of this unit. 16.6.5 Refer to A m ir x /, attached hereto for complete details- 16.6.6 The initiative of the USBM ir. setting up the particulate mineralogy unit was commended, and it was resolved unanimously that this Task Group favor, and recommend the establishment of similar groups with similar objectives, and personnel, internationnally. ' * ' " ' 1,1 0 . u - 16.7 Old business 16.7.1 It wns stated that the two-fiber exposure limit used aa a guideline in Ontario, Canada, was not a regulation, and had not been adopted as a lav. it was added that only one asbestos producing plant operated under this guide line. The opinion was expressed that the operation in question could not possibly continue to operate economically under such severe constraints. 16.7.7 It was agreed that Section 2 . 2 . 1 of the Rationale Supporting the Select Lon of a Dual ASTh Standard should bo modified accordingly. 16.3 New business 16.6,1. (ontion win made of a publicaU o n by 6. Sarkis and Ampian1 Asbestos Hi no iv.Is and their Monn sbes bos ;.nalogs' presented at the confe rence on hi oo Iron microscopy of liicrofibnrs, at I'onn State University 2J-20 Aim' 1676. 16.6.7 T!ie correct address of hr. v.ii. Ashton was ,given as follows: A.H. Ashton Director of Seotechnology .Johnson & Johnson Research Division US Route 202 Raritan, N.J. 08869 Tel.: 201-52V-U75 16.9 Date arid place of the next mooting. 16.9.1 It vas resolved to hold the next meeting of tiie Task Group with the main meeting of ASTm Committee 34 at the Sheraton Hotel, in Philadelphia, PA on 18 April 1977. It was agreed that endeavors would be made so that the Task Group could meet a half clay prior to the subcom mittee meetings. 16.9.2 hdiborial note: It was subsequently decided to meet on Monday, 18 April 1977 from 8:30 to 12:00 a.m. in addition to meeting on Tuesday, 19 April. CRMC-MAD-000247 AMttX 1 a IYl NAHC.C '"Ixtcontyi ment i r a o f t h e t a s k Gr r,up un N a t u r a l l y Ocouring Inorganic Fibern of ASTA Committee . 34, at the JFK nirport in New York, N.Y., ?. 'larch 1977. VU;. Ashton Fi. Co; sette A.ii. Harvey C.5. Thompson A.A. Winor - J ohns on l Johnson, Research - University of Sherbrooke Recording Secretary - R.T. Vanderbilt Co. Ltd. - M . Vaniiorbi] t Co. Ltd. -- 'AT/CAL'Ujf Ottawa* Ont. Chainnan Dir. CRMC-MAD-000248 ANNEX; 2 AC i'll Commi ileo h-34. Task: Croup on Naturally occurring Inorganic Fibers AGMA 16th mooting 2 march 1977 JFK Airport New York, N.Y. Chairman's opening remarks Minutes of `he last mooting Business arising out of the minutes Lettor ballot on exposuro limits and adoption of the Standard on Occupational exposure to Asbestos. Regulatory situation in Lngland. Centers for study of microscopic mineral particles. Old business New business Date and place of the next meeting CRMC-MAD-000249 g ' The DaUg Telegraph, Thuirriay,February U, 1977 T U C SAFETY LIMIT IFOR ASBESTOS TOO LOW, SAYS UNION By }01W DUNSFORD rp iIR T U C recommended asbestos safety limit -* is too low and could wipe out the industry and create havoc throughout the economy in sectors where asbestos products are used, a union claimed yesterday. Thic Association of Professional, Executive, Genas! and Computer Staff (APEX) said the limit puts thousands of jobs at nski. The union has decided to set up jts own advisory com m ittee in opposition to th e T U C 's m a in recommenda tions od asbestos. ' It also accused th e.T U C ; of Submitting "unnecessary, unrealistic and unsubstantiated " recommendation* to Govern ment. The T U C has urged an eventual total ban on asbrfctos product* and, as an immediate measure, the introduction of a maximum .allowable concentra tion of 9% fibre* per millilitre (7MI) of air, , J The urtimi claims the "hiither but still safe*" level of two fibres per miIliEtre .should be laid ditwrt ns the \e%& maximum in a working environment. . Costa f'GO million; ' The 0-2 level would prob ably co*t TB.A Industrial Pro ducts, of Rochdale, on of J the World's binges? maoufacticrm of Asbestos, m are than 50 mil lion In adapting! existing produc tion m e t h o d s , a n impossible figure." the tnllon daim*. * " I t U a t t unachievable">rrel and, if Introduced, would mean the end of tbe asbestos Indus try," said Mr Peter Goodwin, J A P E X north west area organ iser. Some 20,000 Jobs, at all grades, would be lost In the region alone. Mr Keith Standring,' tbe union's national executive secre tary, said A P E X "had disso ciated itself from the T U C 's findings and has proposed a re examination of methods used to establish link* between health hazards in the asbestos industry and to " ensure i its fact* are indeed facts." 1 Thru nfon daim* the T U C arrived at its findings by only sIttsuedlyf inog ersetapbolristsh about asbestos or check facts. The Health and Safety Com mission's recent interim report on health harards and pre- ; cautions involving asbestos had f recommrndfd 2 millilitres as the ; jrermitted maximum occopa- j tional exposure level to most i asbestos dusts, It recommends an exposure ceiling of only 0-2 millilitres for " b lu e " asbestos, or Croddolite the import of which has now been banned. CRjVfc D E P A R T S ^ EE&2T o f f i l e I M T E R B Q R BUREAU OF MINES news release For Release November 15, 1976 Alan,Cole (202) 634-1006 HINES BUREAU UNIT FOR STUDY OF MICROSCOPIC MINERAL PARTICLES ESTABLISHED AT COLLEGE PARK, MARYLAND Studies of microscopic mineral particles using specialized scientific disciplines that can clearly identify such potentially harmful substances as asbestos, and distinguish them from thousands of other mineral particles, will be performed by a new research unit just established at the College > Park (Md.) Metallurgy Research Center of the Interior Department's Bureau of Mines. Formation of the new group was announced today by Bureau of Mines Director Thomas V. Falkle. He said the Bureau's recognized expertise in particulate mineralogy will be used "to help clarify a situation, with environmental and health implications, that so far has been characterized more by confusion and ambiguity than by reason and fact." "The best-known environmental questionmark in particulate mineralogy in asbestos," Dr. Falkie said. "The entire field has been riddled by the extreme lack of precision with which the term 'asbestos' has been used." "In many instances," the Director said, "non-asbestos mineral par ticles have been mistaken for microscopic, fibers of related asbestos minerals. The Bureau's new particulate mineralogy unit has been assigned to clear up such confusion wherever it can, by replacing misinformation with fact. Its job is to develop a solid scientific basis for research into particle-related pollution problems and for the process of decision making by regulatory bodies." Dr. Falkie said the particulate mineralogy unit, besides helping in the Bureau's own minerals research, will serve as a focal point for identification of particulates involved in regulatory and research activities of Federal, State, and local agencies. Whenever technical information about the nature of asbestos and other mineral particulates is needed, such agencies can consult directly with the College Park staff, without going through the Bureau's main headquarters offices in Washington, D.C. (more) CRMC-MAD-000251 MILLI P O K E K c c o m m e n d e d 31r a d i e c ANNEX 5 P r o c e d u r e for rendering M F -M illiporc (m ixed e s t e r s of cellulose) and Cclotate (cellulose acetate) m em brane filters transparent. 1. S c o p e : T his p ro c e d u re p ro v id e s a c h e m ic a l clearing technique* th at y ields a tra n sp a re n t m em b ran e p erm an en tly affixed to a glass slide and b e c au se o f t h e n a t u r e o f t h e c l e a r i n g p r o c e d u r e , tVie c o n t a m i n a t i o n i s a l s o p e rm a n e n tly affixed lo tire m e m b r a n e resu ltin g in a p e r m a n e n t s a m p le . 2. O ut l in e of M ell poT C o n tam in an ts m u st be c o llected on a M F -M illip o rc (white o r b lack plain) or Celotate m em b ran e disc w here vacuum has been used lo im oinge the particles upon the surface of the filter. The filter disc is rendered* transpar ent by dissolution, thus, the particles can be o b se rv e d using transm itted light m icroscopy. 3. A n n a r a i n s ; A) G la s s s lid e s 2Mx 3" (for 37 aird 4 7 m m filte rs ) M i l l i p o r c C a t a l o g ii X X 10 0 7 6 15 B) F i l t e r fo rc e p s , s ta in le s s , sm o o th -tip M i l l i p o r c C a t a l o g H X X G Z 000 06 C) E yedroppers with rubber bulbs D) W a t c l r g l a s s ( d i a m e t e r g r e a t e r th a n 47rnm ) K) G l a s s S y r i n g e ( 5 0 - 1 0 0 m l ) F) M icro -sy rin g e, E u cr inlet, 25rnm M i l l i p o r c C a t a l o g l' X X 30 0 2 5 00 G) F l u o i o p o r e m e m b r a n e f i l t e r s (por e s ia c 0. 2pm) M il l ip o r e C a ta lo g v F G E P 025 001 11) L a r g e d i a m e t e r p e t r i d i s h e s CRMC-MAD-000252 A) C learing Solution A 33mls Hexane, Technical G rade 3 3 m l s 1, 2 - D i c h l o r o e t h a n e , T e c h n i c a l G r a d e 3 3 m l s 1, 4 - D i o x a n e , T e c h n i c a l G r a d e 15) C l e a r i n g S o l u t i o n 13 Acetone, Technical Grade F i t t e r C t e a r i ng P r o cedurc: A) F i l t e r c le a r i n g so lu tio n A u s in g F G B P (0. Zprn p o r e size) filler into pre-clcancci container. B) U sing an eyedropper, freshly rinsed with a filter solvent (Freon TF is rccom m cndod), dispense sufficient clearing Solution A to thoroughly w et a cleaned 2" x 3" m ic ro s c o p e slide. C) C arefully roll the dry test filter particle side up, onto the p r e - w e tte d g lass slide. (Caution: do not re le a s e m e m b ra n e on this slide.) Im m ediately roll the wet filter onto a clean, d ry glass slide and cover the glass petri dish. D) Aftei* 30 s e c o n d s , r e m o v e the g la s s p e tr i dish and in v e rt the sam p le over a watch glass half filled with acetone. Allow t h e s a m p l e t o b e c o m e c o m p l e t e l y t r a n s p a r e n t (Z t o fi m i n u t e s ex p o su re tim e to the acetone vapors). 3s) R em o v e the sam ple from the watch glass and place on a level su rface covering it with the petri dish. F) A llow the filler to dry 2 to 5 m inutes at room tem p eratu re. F ilte r is now ready for analysis. CRMC-MAD-000253 ABSTRACT * MIEME ORAL ASBESTOS STUDIES John A. Moore, D.V.M. 'I 5 < Epidemiologic data clearly associates inhalation of asbestos with an increased incidence of cancer. In addition to pulmonary and thoracic neoplasia, there is data which associates an increased incidence of gastrointestinal and peritoneal tumors. Controversy exists as to whether these latter types of neoplasia result from asbestos fibers that were ingested subsequent to clearance from the respiratory system. Exposure to ingested asbestos does occur in the general population through the presence of fibers in water and food. The N1EHS oral asbestos studies in rats and hamsters represent a systematic attempt to assess the biological effects associated with primary ingestion of selected asbestos fibers. The objectives of the studies include: assessment of biological (carcinogenic) effects as a consequence of exposure to one of several types of asbestos; assess if an interaction may exist between a chemical carcinogen which is known to produce bowel cancer and ingestion of asbestos. The specific experimental design of this series of ongoing studies will be presented.* *To be presented at: the. Workshop on Asbestos: Definitions and Measurement: Methods, July 18-20, 1977, National Bureau of Standards, Gaithersburg, Maryland CRMC-MAD-000254 Thero ir, strong evidence that associates occupational exposure to chrysotiio, amps ito, and crocidoli tc to a resulting high incidence* of lung cancer. Exposure to these forms of asbestos has also been observed to result in an increased incidence of pleural and peritoneal mesothelioma and an excess risk of gastrointestinal cancer. Er.vironmenta' exposure to asbestos through living in the 4 * neighborhood of asbestos factories or mines or through residing in households of asbestos workers also correlates with increased mesotheliomas (IARC Monograph on Asbestos, Volume 14, 1977). It is plausible to speculate that the increased incidence of gastrointestinal cancer in occupationally exposed populations may be a consequence of asbestos fiber ingestion. Fiber ingestion in these circumstances may result through the swallowing, of fibers cleared from the nasal or tracheobronchial tree. Direct ingestion of fibers deposited in the oral cavity also occurs. Exposures of the general population to asbestos occurs through ingestion of materials and substances that contain fibers. For example, several million fibers per liter v/ere found in Canadian tap water (Cunningham and Pontefract, 1971); Great Lakes and St. Lawrence River water shov/ed average concentrations of about 1.7 million asbestos fibers per liter (Cook et al., 1974); water collected Tom the north shore of Lake Superior in the Silver Bay/Duluth region were found to have even higher fiber levels. A number of studios have reported the appearance of asbestos fibers in commercial 1 CRMC-MAD-000255 beverages such as beer, vermouth, arid soft drinks (Cunningham and Forito tract, 197!}, The fibers found in these products may be a result of the use of asbestos filters used in their preparation (Cunningham and Pontefract, 1971). Food may contain asbestos through the use of asbestos. filters or the use of talc, which has an asbestos impurity (Merliss, 1S71; VicIff and Oehme, 1974). in response to a growing co n c e rn about the possible biological effects of ingested asbestos, a conference was held in 1973, co-sponsored by the National Institute of Environmental Health Sciences and the Environmental Protection Agency. The meeting confirmed that the preponderance of biological data concerning exposure to asbestos focused on the inhalation and not the ingestion route of exposure. A concensus of that international conference was that research was needed on health effects associated with asbestos ingestion. A Subcommittee of the DHEW Committee to Coordinate Toxicology and Related Programs (CCTRP) subsequently reviewed the existing data, recommended that additional research be undertaken, and prepared a draft research protocol that it felt would be responsive to the scientific needs. This protocol was widely distributed for comments both within and without the Government. Based on the comments received, a final protocol was developed and submitted as part of its final report. In response to the Subcommittee's report, Congress appropriated specific funds directing the National Institute of Environmental Health Sciences to research the effects 2 CRMC-MAD-000256 of ora! asbestos ingestion. The NIEHS is conducting this research primarily through its research contracts program. The Environmental Piui-utLon Ayi'ncy -.Iso corvtrIbutod funds for these studies. The design these; studies are in concert with the recommendations of the CCTRP Subcommittee. The basic design of(the studies provides for an evaluation of cbrysotile, a serpentine asbestos; and amo.vite and crocidolite, fibers representative of amphibole asbestos; plus a non-fibrous tremolite which does contain low levels of asbestiform fibers. The studies call for asbestos to be fed continuously in the diet over the entire lifespan of the test animal. Each form of asbestos is contained at a }% level in a pelleted rodent diet of constant ingredient formulation (NIB Feect 31 )\ The proposal to incorporate the asbestos within a pelleted diet form was approved only after studies indicated that the pelleting process did not alter the physical integrity of the fiber. The utilization of an asbestos diet in a pelleted form has obvious advantages: it minimizes fiber aerosols which would occur with greater ease in a non-pelleted form; it minimizes va:'itions of asbestos concentration in the diet due to segregation of fibers that would occur during shipping, handling, and feeding. Incorporating asbestos into food rather than water eliminates settling and subsequent uneven distribution. All materials are being fee to the F-344 strain of rat; whereas two forms of asbestos, chrysotile and amosita, are also to be tested in hamsters. Golden Syrian hamsters represent a second test species and are being fed a serpentine or amphibole form of asbestos. All 3 CRMC-MAD-000257 s r . u d e n c o m p a s s the lifespan of the animal, which is defined as the age at which the animal begins eating solid food until its death. To insure asbestos ingestion at a young age, these studies are initiated by feeding the asbestos diet to a nursing mother, which is removed once the peps are weaned. These latter animals that begin eating asbestos at two weeks of age constitute the test generation. In the basic studies, the test group size is 500, composed of equal numbers of males and females. In each of the rat and hamster slucHc-s., there is a composite total of 1,000 animals that receive diet which does not contain asbestos and serve as controls. The experimental group size allows one to detect a statistically significant increase in gastrointestinal tumors in the treated groups at a 2% increase above the ca n ir$ T poputertron. in another rat experiment, two subset of 200 animals each are to receive asbestos from the first to the 28th day of life by gastric intubation. The rat pups received 2.35 mg of an aqueous asbestos suspension daily. At weaning, the rats are placed on the appropriate asbesto. diet for the remainder of their lifespan. One subset of 200 animals is to receive chrysotile while another subset is to receive amosite. The objective of these experiments is to see if a possibility exists that neonates may be a special risk population. There is also scientific interest in determining if asbestos in the diet alters the expression of intestinal neoplasms induced by a known chemical 4 CRMC-MAD-00025 8 careinorjen. Studies of this type are performed in rats that are fed cither diryr.otilc or arnosite. A similar study will be conducted in hamsters receiving the chrysotile diet. There are 350 animals in each of tiios.i* three groups. The chemical carcinogen to be utilized was selected after a series of dose-ranging experiments of one-year's duration was performed in each species. In these dose ranging studies, both dimethyl hydrazine and methylazoxyrnethanol were evaluated. The results indicated that dimethyl hydrazine was the chemical carcinogen of choice due to lower toxicity and greater specificity of intestinal tumor response. The dose selected is one that will produce approximately a 10% incidence of intestinal tumors. That dose for hamsters is 4 mg/Kg, whereas for rats it was 7.5 mg/Kg and 15 mg/Kg in male and female rats respectively. The dimethyl hydrazine is administered by gavage once every fourteen days until five doses have been administered. The initial dose was administered at six weeks of age. Tables 1 and 2 summarize the design of the animal study. The animal testing phase of the experiments commenced in late 1975. Since the natural lifespan of the F-344 rat is 26-30 months and 1< 23 months for the hamster, definitive interpretation of these studies is several years away. All animals receive a thorough pathologic evaluation at time of autopsy. In conformance with the NCI Carcinogen Bioassay protocol, some thirty tissues In addition to any gross lesions will be examined under light microscopy. 5 CRMC-MAD-000259 The r a t studies are being performed through a contract with Hazleton Research Laboratories, Vienna, Virginia; whereas the hamster experiments are being performed by the Illinois Institute of Tehcnology Research I n s t i t u t e , Chicago, Illinois. As a biologist, I wish to emphatically state that the most difficult decision in the design of these studies was determining the types and specific forms of asbestos that were to be fed. The literature clearly indicated chat some previous studies v/ere flawed due to unwi t t i ng physical violence imposed upon the asbestos during its preparation. In some cases, there was concern about contamination by organic chemicals. In medical research circles, the issue still rages with respect to the size of fiber that may be associated with observed neoplastic response. It is necessary to relate size that produces optimal biological response to the distribution of fiber sizes to which there is general human population exposure. The common fiber found in municipal water supplies represents one of serpentine origin. From a numerical standpoint, the preponderance of these fibers are of the low micron and submicron lengths. To accommodate to these circumstances, it was decided that tfr-e would be two chrysotile asbestos materials used in the rat and hamster studies. These are referred to as the NIEHS short-range chrysotile and the NIEHS intermediate-range chrysotile. deposits in California, This chrysotile is o F very small fiber length and diameter. It is a single lot produced by Union Carbide and is referenced by then: as COF-25. The NIEHS intermediate-range chrysotile originated from the '.ohns-Manville Jeffrey Mine in Canada. This material has genera! analogies to their Plastobest 20, * * One method of comparing these two chrysotile samples is by - comparing surface area determinations. Table 3 presents the results of such tests; the UICC chrysotile surface area values are listed for comparison. The UICC samples have been the asbestos source for the majority of biological studies over the past several years. As can be seen from the table, the NIEHS intermediate-range chrysotile compares quite favorably with the UICC Canadian chrysotile. The two fold increase in surface area of the NIEHS short-range chrysotile compared to its intermediate-range counterpart reflect the much smaller fiber size found in this sample. The amphibole samples, amosite and crocidolite,were prepared by the Ontario Research Foundation under the direction of the U.S. Bureau of Mines' College Park Laboratory. This asbestos, purchased commercially, has been processed by air jet milling to better standardize the range of fiber size contained in the material. The tremolite sample was mined and milled to -325 mesh by the R. T. Vanderbilt Company, Balmat, New York. It was subsequently 7 CRMC-MAD-000261 blended by the U.S. Bureau of Miner, personnel to insure homogeneity of the Sampie. Ail test materials are being extensively characterized as to chemical an; fiber size characteristics. The characterization data include X-ray diffraction parameters, chemical composition, DTA, TGA, optical constants, density, and surface area. These studies are being performed by crie U.S. Bureau of Mines. Exhaustive electron microscopic characterization of each material as to fiber length, fiber diameter, surface area, distribution of fiber size, and selective pore volume measurements are being performed by the Fine Particles Laboratory of the Illinois institute of Technology Research Institute, Chicago, Illinois. The characterization studies on tremolite and the short-range and intermediate-range chrysotile are nearly complete. The characterization of amosite and crocidolite are scheduled for completion by the end of the year. Two recent ingestion studies that have been reported within the past year yielded variable results. In a British study, a group of 32 Wistar rats were fed 100 mg per day of UICC Canadian chrysotile prepared in milk powder cn a five-day a week schedule for a total of 100 days of ingestion. There were 16 control animals which were'fed only the malted milk. The animals were then allowed 'to live out their lifetime, which was a mean survival of 619 days for those animals on chrysotile 8 CRMC-MAD-000262 * versus 641 days for the controls. One gastric leiomyosarcoma was observed in the chrysotile group, ho tumors of this type were found to occur in the controls (Wagner et al., 1977). m a study reported in the East German literature, a statistically significant (p < 0.01) increased indicence of malignant tumors occurred in rats that received asbestos filter material in the diet (Gibe! et ai., 1976). The exact composition of the asbestos filter material was not given in this paper. In this study, 2b male and 25 female Wistar rats were given 50 mg/Kg body weight per day of asbestos filter material which contained approximately 52% chrysotile asbestos. This asbestos containing filter material had been previously powdered and added as a water suspension to the diet. In the group of 4k animals which received the asbestos filter material, the average survival time was 441 days. Untreated controls had an average survival time of v 702 days. Of the 42 treated rats available for pathologic evaluation, 12 malignant tumors were found. This is to be compared to 7 tumors (two liver cell carcinomas and five mammary fibroadenomas) observed in 49 control animals. The tumor types observed <n the animals fed the asbestos filter material included four kidney carcinomas, one lung carcinoma, three reticulum cell sarcomas, and four liver cell carcinomas. Two mammary fibroadenomas as well as a lung adenoma, two cbolangiomas, and two forestomach papillomas were also observed. ip P f ? m em * r The NIEHS Oral Asbestos Studies should provide controlled data from *- large enough sample sizes to allow for initial formulation of basic principles as to the biological effects of exposure to ingested asbestos. 9 CRMC-MAD-000263 REFERENCES i-I iAUC Monograph:. on the Rvair ton o' Carcinogenic Risk O Chemicals Lo Man, Asbestos, volume 14. International Agency for Research on Cancer, Lyon, France (1977). Cunningham.. H. H, and Pontefract, R. 0., Asbestos fibres in beverages and drinking water, nature (Loud.) 232, 332-333 (1971). 13] Cook, P. M . , Glass,.6. E and Tucker, J. H., Asbestiform amphibole minerals: detection and measurement of high concentration- in municipal water supplies, Science 185, 853-855 (1974).. [4j Cunningham, H. M. and Pontefract, R. D., Asbestos fibres in beverages and drinking water, Rature (Lond.) 232, 332-333 (1971). Cunningham, H. M. and Pontefract, R. D., Asbestos fibres in beverages and drinking water, Nature (Lond.) 232, 332-333 (1971). Merli ss, R. R., Talc and asbestos contaminant of rice, J. Amer.. Med. Assoc. 215, 2144 (1971). Wolff, A. H. and Oahme, F. W., Carcinogenic chemicals in food as an environmental health issue, 0. Amer. Vet. Med. Assoc. 164, 623-629 (1974). Wagner, J. C., Berry, G., Cooke, T. J., Hill, R. J., Pooley, F. D., and Skidmore, J. W., Animal experiments with talc, in Inhaled Particles and Vapours, IV, W. C. Walter, ed., New York, Pergamon (in press Gibel, W., Lohs, K., Horn, K.-H., Wildner, G. P. ar.' Hoffmann, F. Tierexperimentelle Untersuchungen ber eine kanzerogene Wirkung von asbestfiltermaterial nach oraler aufnhme, Arch. Geschwulstforsch 46, 437-442 (1976). CRMC-iVAD-0002S4 FABLE 1 NIEMS oral asbestos study 1, f * Golden Hamster Asbestos diet Asbestos diet plus a dimethyl hydrazine Control dietb Control diet plus dimethyl hydrazine CHRYSOTILE INTERMEDIATE 500a 350 500 250 CHRYSOTILE SHORT RANGE 500 NO 250 ND AMOS ITE 500 ND 250 ND CRMC-MAD-000265 aNumber of animals (equal numbers of each sex) bControl allocations are descriptive only. Experimental response will be evaluated against total controls (1000). Subsets of control w i .. reflect temporal differences 1n commencing phases of study which is expected to be aggregates of 250-350. NO - Not done studies conducted by Illinois Institute of Technology Research Institute, Chicago, Illinois. i ,1 I . TABLE 2: NIEHS oral asbestos study ,i: | CHRYSOTILE INTERMEDIATE Asbestos diet Asbestos diet plus dimethyl hydrazine Preweaning asbestos gavage plus asbestos diet 500a 350 200 Control diet^ 175 Control diet plus dimethyl hydrazine3 250 F-344 Rat CHRYSOTILE SHORT RANGE 500 ND AMOSITE INTERMEDIATE 500 350 NO 200 175 175 ND 250 CROC IDOL ITE 500 ND TREMOt 50 0 NO NO NO 175 175 ND NO CRMC-MAD-000266 aNumber of animals (equal numbers of each sex) ^Control allocations are descriptive only. Experimental response will be evaluated against total controls (1000), Subsets of control will reflect temporal differences in-commencing phases of study which is expected to be aggregates of 250-350. NO - Not done Studies conducted by Hazleton Research Laboratories, Vienna, Virginia. . TABLE 3: Comparison of UICC and NIEHS chrysoti'le samples ASBESTOS IDENTIFICATION UICC VALUE (m2/g) IITRI VALUE (m2/g) UICC Rodesian Chrysotile UICC Canadian Chrysotile NIEHS Intermediate Range Chrysotile NIEHS Short Range Chrysotile 21.3 - 1.5 26.8 i 0.7 +1 +1 22.35 27.1 27.8 ~ 2.7 59.0 - 6.2 nr/s I 'i M l Johns-r/ianviile R. P. Carter To; W. A. Cooper W. B. Reitze ftom: E. M. Fenner Copies: File & C interna! C o r r a s p c n c f o n c s s' ij y F. J. Solon, Jr.- .i S. Spoil w. C. Streib D'1,e: July 31, 19 74 ,1 A Subject: M E E T I N G - 9:00 A.M., AUGUST 6 , 1974 DEFINITION OF AN ASBESTOS FIBER - OSHA STANDARD As you are aware, -there has been considerable discussion concerning the definition of an asbestos fiber as presently used by OSHA, particularly in regard to the prescribed aspect ratio of 3 to 1. ASTM has organized Committee E-34, "Conunittce on Occupational Health and Safety Aspects of Materials, Physical and Biological Agents". There are a number of subcommittees and task groups within this committee. One of these task groups is concerned with "naturally occurring inorganic fibers". This task group is presently engaged in writing for submittal to ONHA through normal ASTM channels a revised standard for occupational exposure to asbestos fibers. One of the important sections being written by this task group is concerned with the definition of asbestos fiber. The next meeting of the Task Group on Naturally Occurring Inorganic Fibers takes place on August 14 and 14 in Canada. 1 would very much like to be able to submit to the group a Johns-Manvi1le definition of an asbestos fiber. Jn order to nccom.nlish this, I am requesting that you attend a meeting to discuss the subject at 9:00 A.M. on Tuesday, August 6, in our Conference Room, 4 North. For background information prior to the meeting, I enclose the following: (1) A letter to F. J. Bolen, Jr., describing ASTM Committee E-34. (2) A definition for asbestos fiber as prepared by a subsection of the task group for affirmative or negative ballotting by the group members. CRMC-MAD-000268 k. P, Carter, .et al Pacte 2 July 31, 1974 {3} A series of definitions of asbestos as previously submitted by the following people: A. A . Hodgson, Cape Asbestos Fibres Limited G. Gagnon,, Lake Asbestos of Quebec Limited M. Grimnrd, M. D, , Department of National Health & Violfare of Canada R. B. S t a c i e , Asbestos Corporation Limited A. A. Harvey, R. T. Vanderbilt Company (4) A defini tion of an asbestos fiber as prep-' ^ / i)r, Hteven Holmes of the Asbestosis R o s e rch uncil. (5) The ASTM present definition of asbestos fiber. (6) & (6A) T w o anonymous definitions of asbestos. (7) An anonymous definition of naturally occurring inorganic fibers. (8 ) A cony of the original proposal for the formation of (..ho uiouj) oil N a t urally Inorgarrc Fabers. (9) A listing of active members of the task group and all others on the mailing list for material. E. M. Fenner CRMC-MAD-000269 Attachment 3 SUPPLEMENTAL LISTIN 07 DEFINITIONS APPENDIX 9 Document No, 11 19 April 1974- This listing is n supplement tc Document Ho. 5 published as Append'x 6 of the minutes of the second meeting of the Task Group on Naturally Occuring Inorganic Fibers of ASTM Committee E-34- 1. Definitions submitted by Mr. A. A. Hodgson, Capo Ash' ' 24 Jan 1974. ores Limited, fjbrer. Fibres are defined as being of a length greater than 5pm and having e ler.gth/brcath ratio of at least 3:1. There is no upper limit for the length of the fibres, but a maximum diameter of 3pm is defined. Airborne asbestos dust concentrations arc expressed in fibers per milliliter of air (f/ml). (taken from the Asbestosis Research Council's Technical Note 1, paragraph 2.1) asbestos - acicular silicate mineral, with a structure based on silicon oxygen totrahedra, composed of crystals in a predominantly parallel orientation, and distinguished by its ability to split indefinitely to breath ratio of 3 to 1 and cross sectional dimensions approaching 0.01 pm. ?.. Definitions submitted by Mr. G. Gagnon, Lake Asbestos of Quebec Limited, 28 Jan 1974: fjbre ~ any material in a form such that it has a minimum ratio of length to average maximum transverse dimensions of 10 to 1. asbestos fibre - silicate mineral, 'with a structure based upon silicon oxygen totrahedra, that fits the definition of a fibre and is composed of single crystals in predominantly parallel orientation. Common usage also designates a collectivity of asbestos fibres as asbestoo fibres. 3. Definitions submitted by Or. M. Grimard, Chief, Heath Effects Division, Environmental Health Directorate, Department of National Health and Welfare of Canada, f jPro - (definition as applied to minerals): any material which by micros copy presents the following optical characteristics: a filiform or bundle of filiform bodies having a length to dlamotor ratio of at least 3:1 asbestos fiber - acicular ailicato mineral, with a structure based upon silicon-oxygen totrahedra, that fits the definition of a fiber, and is composed of single crystols in predominantly parallel orientation. CRMC-MAD-000270 '** . D e f i n i t i o n s submitted by Mr, A. M. Harvey, Manager, Legal and Products A p p l i c a t i o n , R. T. Vanderbilt Company, Inc., U Jan 197A: rn;norn \ iLiR'I " any form of mineral characterized by properties of f l e x 3 b l i i and length to width ratio of at least 100, and composed o f clef i n i to ci-ystal unit cells oriented with respect to a specific axis. asbestos - is a generic term for . nvmber of hydrated silicate mineral! that, when crushed or processed, separate into flexible fibers made up of fibril.-:.. These minerals include ahrysotile, erocidolite, amoslte, anthophyllite asbestos, treroolite asbestos and actinolite asbestos. Definitions suiv.n tied by Mr. R. B. Steele, Labors cry ( ^ices Engineer, Product Research and Development Department, Asbestos Corporation Limited, 5 March 197/,: Fibril - Is n polymeric form of solid whose component repeating sub-units extend along a single major axis, and which can not be subdivided along this longitudinal axis without destroying the integrity of the structure. Fiber - Is a bundle of fibrils in parallel alignment, the composite possessing a maximum diameter of 100 microns, and a minimum aspect ratio of 20. Asbestos - Is a generic term for a number of silicate minerals, the morphology cf whose component particles fits the definition of h fiber. Ashes (.os Fiber - Is a fiber belonging to one of the six types of asbestos minerals: crysotile, erocidolite, amosite, anthophyllite asbestos, tremolite. asbestos, and actinolite asbestos. 6. Definitions submitted by Mr. A. A. Harvey, Manager, Legal and Products Application, R. T. Vanderbilt Company, Inc., 30 Jan 197A; Definitions taken from pages 26, 27 17/+ and 175 of the 1973 A S M Glossary: Refor to page 3. 7. Refer to Appendix 5 and 6 of the minutes of the third meeting of the Task Group on Naturally Occuring Inorganic Fibers. CRMC-MAD-000271 tt aLds.'&istf* -(i Attachment 9 Tn ird meeting of Ph iladelphia, i'e w. Ashton M. Co ssettc E. M. Fenner G, J. Foy A. M. Harvey S. Holmes 1!. H. Kaufman A. M. Kooiinon U? F. Mar ton! k R. McCarthy P. VI. McDaniel R. H. Me reness P. V. Pelnar, M.! C. S. Thompson A. A. Winer ATTENDANCE APPENDIX I - Johnson & Johnson Co. - Recording Secretary - Quebec Asbestos Mining Association - Vice- Chairman, Johns-Hanvi.; - Department of Natural nes^ 's of Quebec - R. T. Vanderbilt Co. Secretary of the Asbcstosis Research Council T.D.A. industrial Products Limited - GAP Corporation - Representative of the Editorial Subcommittee - iiotor Vehicle Manufacturers1 Association - MESA, Department of the Interior Washington D.C. - International Talc - Union Carbide Corporation - Asbestos Information Asccciation/North America - Institute of Occupational ancl Environmental Health - R. T. Vanderbilt Company. - Chairman, Department of Energy, Mines and Resources of Canada Dr. J. W. Axel son Dr. E Derry R. A. Bramley-Mooro V/. R. Cooling H. A. Eschc::,bach P. A. Nilteau 0. Gagnon G. VI. Gibbs Dr. M. Grimard MAILING LIST - Johns-Manvillo Research and Development Center - Department of Materials Chemistry - Chrysotilc Corporation of Australia Pty. Ltd. - Asbestos Corporation Limited - Industrial hygienist W. R. Grace Co. - Quebec Asbestos Mining Association - Assistant Mill Superintendent Lake Asbestos of Quebec Limited - McGill University Department of Epidemiology and Health - Department of National Health and Vlclfare of Canada CRMC-Ma D-000272 cz O A. Goodvrin A. A. Hodgson Dr K. A. Kur.Au Dr. J . Lcpout . e, B. L i n c o l n 0. G. fioj-r-r-.r( K. Kori;.-irc:dgc T. ). Oui ion L. C. Piur.e H. Q. Dcoworoft VJ. II. Smith . D. Stcole . K. S tic fk e n E. T. Triglea MAIT.JKG I.ir-T (r.i.il In ) - Head, Health Division - Capo Asbestos Fibers Limited - Ontario Research Foundation - Eternit G. A. - Turner Nev/all Fibre Laboratory - North American Asbestos Corporation - Food and Drug Research ir;' atorico, Inc. - Research Associate Minerals A: Chemicals Div .on - Lake Asbestos of Quebec Limited - Asbestos Textile Institute - Bell Asbestos mines Limited - Asbestos Corporation Limited ~ American and Refining Co.. Ltd. - Engelhard Chemical A: Mineral Industries \ l"- R. T V A N D E R B I L T C O M P A N Y . I N C . .13 W IN F IC L O B r O E t r L A ' r N O n w A L U . C O N N I C T 1C U T O Gi'.'iS C<- . A l . L I A t . [j l . l. . .. im Ivan NIw hi i.'n Januury 2 , '1.973 Mr. w !1l.Iain J;. lei v/.e, Manager '.'j<ient Prevention t-. Health Administration i [.osM'ianvi l i e C o r p o r a t i o n / . `t'r i Cyraeuse Circle De nv er , C o l o r a d o (JO.1.10 boar Mr. Peitze: rue one 1.eied copy of a report describing a recent visit with hr. William K. Mini Lh, o !' Kuir.1 eigh Dickinson University, may be of interest to yon. Very truly yours, H. T. VANDERBILT COMPANY, JNC. AMH: ::r line Ii.Jiuri: a*. ^ M i a n K. Harvey, Manager Patent and Legal Liaison Department li.dl.in-, I ,* l! I' III <HI| H ull I ;!-, m i' !'i'rf | itjVxi td'ila l'ln v I 1f> In' H 'Ii.i Mm I t w m ii vw- i(.i n.r| . | i-.n iin l.c I I mi |e !. ! >> . CRMC-MAD-000274 Johns-Manville Internal Correspondence T . E. M. Fenner R. P. Carter Date: August 28, 1974 From: G. L. SwallOW E .uL-^alnru-uk, Copies: v/. B. Reitze Fi le & Chron Subject: CONVERSATION WITH HOWARD J. SCHULTE/OSMA, AND RAY McCLURE/OSHA REFERENCE: JOHN STENDER'S LETTER OF AUGUST 6, 1974, TO MR. H. B. VANDERBILT, R.T. VANDERBILT CO., INC. In response to your request, I called Howard Schulte and discussed with him the subject letter. He was obviously entirely familiar with it. Mr. Schulte stated that the whole interpretation of the letter hinges upon the definition of "asbestiform" and "non-asbestiform". In response to my question as to what was the current definition of as bestiform, or differentiation between ashes ti form and non-asbestiform, he stated that the definition is the same as previously used in conjunc tion with the asbestos regulations, specifically that the aspect ratio bo 3*1 '1nO H j A f ]npnf'h n r o fi t r . r f'han ^ mirv*nf|C: amplified his definition by saying that if a talc samle were examined under a microscope and more than 5 artifacts/cc were counted, which fit this definition, it would be termed a violation of the OSHA regulations. When I pressed him concerning the difference between artifacts and tremolite, he stated that ,"We cannot take tremol i'te from the standard at this time." He further stated that OSHA technicians have never seen arti facts which fit the above definition which they consider to bo non-tremo- litic. He stated that NIOSH is currently studying the possibility that there do exist non-tremolitic "slivers" which should be differentiated from the tremolitic fibers and which, because they are (perhaps) not a health hazard, should not he counted when evaluating a talc sample. However, the results of this study are one to two years off. In answer to my query, he stated that the Vanderbilt Company argued the above point, namely that such "slivers" do exist and that it is inac curate and unfair to include them in any fiber counts associated with talc sampling. He went on to say that despite Vanderbilt's arguments, OSHA was not going along with this concept, unless and until the NIOSH study mentioned above confirmed it. As our conversation drew to a close, Mr. Schulte suggested that since I had asked so many detailed and technical questions, it would be well for me to talk to Ray McClure. He told me that he would have Ray call me later today. CRMC-MAD-000275 E. M. Fenner/R. P. Carter August 28, 974 Page Two Later this morning, Ray McClure called and referred to my conversation with Howard Schulte. He started by explaining that the Vanderbilt mining operations are un der the jurisdiction of MESA, not OSHA. Their concern with the OSHA regulations is because of their customers who have read the asbestos regulations rind are worried about being cited in their plant operations because of possible tremoiitic content in the talc. Mr. McClure said that John Stender's letter of August 6, 1974, was an attempt to give some relief for this situation, but doubted that it did so very effect! ve ly. He stated that he was presently urging certain modifications to the standard as presently written. His recommendations are to NIOSH, and must be approved by NIOSH before they con be seriously considered or promulgated. In answer to my Question as to what specifically he was recommending, he cautioned me to realize that these were wholly tenta tive and stated that they were: 1. Revise the asoect ratio in the fiber definition (as associated with talc) from 3:1 to 5:1. He noted that such a recommendation would be contingent upon NIOSH"opinion regarding the health aspect. 2. Do not count any fibers whose diameter is greater than 5 microns. 3. Require that the microscopist attempt to make positive identifi cation of fibers as being asbestos particularly by means of observ ing the fiber end configuration. He stated that the Salt Lake City laboratory consists chiefly of OSHA people, now, and that the microscopisfcs already attempt to differen tiate between true tremoiitic fibers rand other non-fibrous artifacts which would be classified as fibers if judged only by aspect ratio and length. (Please note the discrepancy between this note and Howard Schulte's) Mr. McClure stated that if the above changes are successfully promul gated, the standard will probably require sampling by the "asbestos technique" and by imoinnor. Whether or not a given station is over TLV will be judged by whichever criterion is stricter. OSHA is also consi dering requiring high volume air sampler, to permit chemical or mineralogical analysis of the airborne dust. /i. L. Swa 11ow ' GLS/jmb CRMC-MAD-000276 * iw / V 'i 1 * K > " I j.wijriu,i* *" K&I7 Wt;Ik(j(iofi' -- 1uV1J i).u October 23, 197** Vj. o t j ' i U U 1 1 Cl* U* i i I' ' VC i ' o u '.. i* ic ;V,M A,.v LELECVEb AH HA PJFKKACTION PATTiiHKS OF ASBESTOS MINERALS IK FGU. AALL SAMPLES PRODUCED BY K. T. VANDERBILT COMPANY At your n-`)U":,L, I war; able to contract time on the Philip:} 200 'troa icro:;co|-i; at Denver Renenren Institute to confinr. By selectee area di t'i'rnc t,:ion pattern;;, the presence of chrysotllo, 111te and l.re.o.i ito in all t,he R. T. Vanderbilt taler; ,naten a./i.n'i P e e , .e/Lal itOu, Asbestine 3 X , and Asbestine 3P`// ipi >-a.,i; iv;Ar a, n.y e. tt<-r of October 0, 1'/{a , which in bs.;eu tJ;.ica !iy o.a EbA .,pt.iCai UKiUlOii,} .'Hid t))C line of our HCA u'iectl'O!. icroscwpes to conl'ir; chrysotMo). it was felt that selectee ar.-a u iffraoti on pattern:; of the asbestos minerals using the laiiipa Poo would lend positive icienli f.ication - a type of n:..ily;. ia which cannot be Alone on onr HCA EMU-3b model. Va.nl e ho. J not only identifies samples, nut; also identifies all. TEM prints and selected area diffraction patterns of tile 3V prints attached to this letter. The TEM plates are always on file. Tiio microscope constant (L A) was derived by averngir,, 21 microscope constant values based on lines of Au and Pd. The microscope constant is: L A = It.*t51 A cm t 0.003 Vo calculate u-spucing in Angstrom units, the following formula V/ ii j U o O (* -- -- ---L---A ,--lA-- --c' i'h ) spot pa.rr ruinim (cm) _ (, i-spaci. nK (/ 9Ay\ 1 ;. Cnrysotilo, antnophyllite, and tremoli t e were all found in each.o .la: four H. V. Vanderbilt talc .sample:;. 5'art icu.'Iar datii for eaei. pic are found in V:..oie ho. 1 and appropriate attached electro;, diffraction patterns. ,/ l /. l w f '.:U j- V. E. Wolkodoff At, laehments 'VE'bGOK pi'. ( V ' ~ W i y, CRMC-MAD-000277 TABLE 1 Tr,M Tnnulal, ion of Micrographs and .Selected Area Diffraction Pattern.. of Four Tale Sampler. From H. T. Vanderbilt Co. i i i 1 ; ; ;jji <( ')"J-- f>- ! Y;"j';~ i 1 i'.ytal Fou io/tal FoO jiyi.fil. f'Ow iiyt.nl F00 2 iate h'o . , M;1;a1 f.ication F.yjJA , Ii ,000a 231 YA, 1 u ,U00X ;v -f a , 2 2 ,00uX i.y[.a1 FOO i nytal. Foo l Nytal. 2 -0 v,-. iiytatl FOO r'jO('A , 2 2 ,000X - F30YA, 22 ,000X - \*,'\>`j-'<! Y'- V - p Y'*: NyLat 7oo Nytal AOO Nytal Yin) i'iyUa.1. 700 V;>*'>W Nytui 700 77255-2 Nytal 700 77255-2 Nytal 700 '['"`'/j"'** Nytal Y00 2 3 0 2 1), 1.1 ,0 0 0 X 23.1C, 1.6,00()X 230ftA, 2 2 ,000X - 2309A , 22 ,000X - 2 3 1 0 A, 22,00OX - Asla-r.t Lrio 3X ''A".} As bostine 3X Y'120 5-3 Asbestine 3X 7'.255-3 Asbent,ine IX 77; Asben t inc 3X J"M Asbestine 3X '.'7255-3 Asbestine 3X 7-205-3 ai.br:atine 3 X 23030, 11 ,00OX 23191), .10 ,000X 2 3 1 1 A , 22,00OX F31.2 A , 2 2 ,0 0 0 X - 2313A, 22 ,00GX - 7 a ;`5 5 -7 Asbestine 325 230U, 11,000X 77255-7 Asbestine 325 2 3 2 2 A , lo.OOOX *jii!t('ii A rea 1)i t'r.'iction I'attern, 35X ,, 2 30 53 2306b __ 230YB i\ tiTij i*'/ '<> __ C'Lrysoti 1 e 1".i.ej i'attern is of v: fiber in Pitta , Chrysotilc AnthophyJ lit.- fi Aa tiiojia.VJ li 0- f' Jll r fi'ri;[no] itc i'i.H > 'IVeliiOli te fi 2 307 A 2308i) > 2309B 2 31 OB - Chrysotile 1 > i Pattern of o..r\. ,>t.;Il above Anttiophyl 1 1; Pattern of Anti.c above Tremolite i*-I, Pattern of ',/ ... above 231 IB 2312J) . 23133 - Chrysot'i 'bo 1 . bottom Pattern of on.-;/.. 'li* above Anfhophyll i1 < I'attern of A., . i I.U above Tremolite ft Pattern of . above - Fiber is con.1 : Cijryac tile and Air.ani!... CRMC-MAD-000279 : a l / i < 1, c o n i M i e i .1 ; i. \i a - r a ji !, i ; i ; * a l i O n j''i;: i'Late n o . , f ia t a i f l c u ti, on , ' t ! e c !a m A r e n . \>i ffruoti (j)j pattem, yyi. Bei.'.arUr. . p ! V i , , S ~ * t A s s e a L i i *t - .. ; p > - J` A nne u t in e / \ a ?6; S o L L U A 'P ;u A . : V t . ' k k - 1* A s i n i * r , t i n e 3 2 3 .. ' \ , - h a : A / < ;; l . n e a-'A .. . / - p V P -- a A ; , j e L i t i li'-' ' 1 3 A s s e s l i n e .JJ'tj.lJ] x'.:n 231 AB P-'SVjb 2316b *'iryr.ol .W1 /<i-<a s u p e r im p o stai or, A m p h ib o lo pn '.t Chrysotilc finer Pa tte 'r n O C nr.'/notl i above I.n;',est fi bei- ii. Anthophyll it<- `n U crn <:' A... .vV iv ''>iho lll/OVt i >tiJ*/*e i l l XSO ** Tremoliti? Pattern of Tr. :ite above CRMC-MAD-000280 lSif' L`-j iiJohns-Manviile To: R. V/. W. P. A. B. Carter Cooper Reitze nom: E. M. Fenner 1F. S. W. J. Solon, Speil C. Streib Jr. la '(it*)' Doto: July 31, 1974 to!"1" F 1 jt I, C SubjcL':. MEETING - 9 : 0 0 A.M., AUGUST 6, 1974 DEFINITION OF AN ASBESTOS FIBER - OSHA STANDARD A: you arc aware, there has been considerable discussion concorninq the definition of an asbestos fiber as presently used by OSHA, particularly in regard to the prescribed aspect ratio of 3 to 1. ASTM has organized Committee E-34, "Committee on Occupational Health and Safety Aspects of Materials, Physical and Biological Agents". There are a number of subcommittees and tusk groups within this committee. One of these task groups is concerned with "naturally occurring inorganic fibers". This task group is presently engaged in writing for submittal to OSll/v through normal .ASTM channels a revised standard for occupational exposure to asbestos fibers. One of the important sections being written by this task group is concerned with the definition of asbestos fiber. The next meeting of the Task Group on Naturally Occurring Inorganic Fibers takes place on August 14 and 14 in Canada. I would very much like to be able to submit to the group a Johns-Manville definition of an asbestos fiber. In order to accomplish this, I am requesting that you attend a meeting to discuss the subject at 9:00 A.M. on Tuesday, August 6, in our Conference Room, 4 North. For background information prior to the meeting, I enclose the following: (1) A letter to F,, J. Solon, Jr., describing ASTM Committee E-34. (2) A definition for asbestos fiber as prepared by a subsection of the task group for affirmative or negative ballotting by the group members. CRMC-MAD-000281 4 R . P . Carter, et al Page 2 July 31, 1974 (3) A series of definitions of asbestos as previously submitted by the following people: A. A. Hodgson, Cape Asbestos Fibres Limited G. Gagnon, Lake Asbestos of Quebec Limited M. Grimurd, M.D., Department of National Health h Welfare of: Canada R. B. H tee lo, Asbestos Corporation Limited A. A. Harvey, R. T. Vanderbilt Company (4) A definition of an asbestos fiber as prepared by Dr. Steven Holmes of the Asbcstosis Research Council. (5) The ASTM present definition of asbestos fiber. (G) & (GA) Two anonymous definitions of asbestos. (7) An anonymous definition of naturally occurring inorganic fibers. (8) A cony of the original proposal for tho fnmiaH on of the Task Group on Naturally Inorganic Fibers. (9) A listing of active members of the task group and all others on the mailing list for material. E. M. Fenner I CRMC-MAD-000282 Attachment 3 SUPPLEMENTAL LISTING OF DEFINITIONS APPENDIX 9 Document No. 11 19 April 1974- This listing in n supplement to Document No. 5 published as Appendix 6 oi' the mluutoii of the naeunci mooting of the Tank Group on Nnturn.lly Occuring Inorganic Fibers ol' ASTM Committee E-3A* 1. Definitions submitted by Mr. A. A. Hodgson, Cape Asbestos Fibros Limited, ?J, Jon 197A fibres Fibres are defined as being of a length greater than 5pm and having a length/breath ratio of at least 3:1. There is no upper limit for the length of the fibres, but a maximum diameter of 3pm in defined. Airborne asbestos dust concentrations are expressed in fibers per milliliter of air (f/ml). (taken from the Asbestosis Research Council's Technical Note 1, paragraph 2.1) asbestos - acicular silicate mineral, with a structure based on silicon oxygen tetrahedra, composed of crystals in a predominantly parallel orientation, and distinguished by its ability to split indefinitely from its macro form to individual flexible fibrils having minimum length to breath ratio of 3 to 1 and cross sectional dimensions approaching 0 .0 1 |jm. 2. Definitions submitted by Mr. G. Gagnon, Lake Asbestos of Quebec Limited, 23 Jan 1974: fibre - any material in a form such that it has a minimum ratio of length to average maximum transverse dimensions of 10 to 1. asbestos fibre - siliento mineral, with a structuro based upon silicon oxygen tetrahedra, that fit3 the definition of a fibre and is composed of single crystals in predominantly parallel orientation. Common usage also designates a collectivity of asbestos fibres ns asbestos fibres. Definitions submitted by Dr. M. Grimard, Chief, Hea'th Effects Division, Environmental Health Directorate, Department of National Health and V/clfarc of Canada, flbro - (definition as applied to minerals): any material which by micros copy presents the following optical characteristics: a filiform or bundle of filiform bodies having a length to diameter ratio of at least 3:1 asbestos fiber - acicular silicate mineral, with a structure based upon silicon-oxygon tetrahedra, that fits tho definition of a fiber, and is composed of single crystals in predominantly parallel orientation. CRMC-MAD-000283 -2 r 4. Definitions submitted by Mr. A. M. Harvey, Manager, Legal and Products Application, R. T. Vanderbilt Company, Inc., 4 Jan 1974: mineral fiber - any form of mineral characterized by properties of flexibility and length to width ratio of at least 100, and composed of definite crystal unit cells oriented with respect to a specific axis. asbestos - is a generic term for a number of hydruted silicate minerals that, when' crushed or processed, separate into flexible fibers made up of fibrils. These minerals include chrysotile, crocidolite, amoslte, anthophyllite usbestos, tremolite asbestos and actinolite asbestos. . Definitions submitted by Mr. R. B. Steele, Laboratory Services Engineer, Product Research and Development Department, Asbestos Corporation Limited, 5 March 1974: Fibril - Is a polymeric form of solid whos* component repeating sub-units extend along a .single major axis, and which can not be subdivided along this longitudinal axis without destroying the integrity of the structure. Flbor - In a bundle of fibrils in parallel alignment, the composite possessing a maximum diameter of 100 microns, and a minimum aspect ratio of 20. Asbestos - Is a generic terra for a number of silicate minerals, the morphology of whose component particles nts-tne aennition oi a fiber. Asbestos Fiber - Is a fiber belonging to one of the six types of asbestos minerals: crysotile, crocidolite, amosite, anthophyllite asbestos, tremolite asbestos, and actinolite asbestos. 6. Definitions submitted by Mr. A. A. Harvey, Manager, Legal and Products Application, R. T. Vanderbilt Company, Inc., 30 Jan 1974; Definitions taken from pages 26, 27 174 and 175 of the 1973 ASHA Glossary: Refer to page 3. 7. Refer to Appendix 5 and 6 of the minutes of the third meeting of the Task Group on Naturally Occuring Inorganic Fibers. CRMC-MAD-000284  ASBESTOS INFORMATION ASSOCIATION 1743 jafferson Davis Hfgnway, Crystal Soutra 4. Suita 509 Arlington, Virginia 22202 (703) 979*1150 22 Nove mber 197? Memorandum For: Subject: EXECUTIVE COMMITTEE Forwarding of Executive Committee Minutes Please find enclosed minutes of the Executive Committee meeting, Tuesday, November 15, 1977. Executive Director Enclosure CRMC-MAD-000285 ASBESTOS INFORMATION ASSOCIATION AU*ICA 1745 JHraon D*vi HJghwiy. Cryatt-'-Souve 4, Suit# 509 Arlington. Virgin! 22202 (703) 979-1150 EXECUTIVE COMMITTEE MEETING Tuesday, November 15, 1977 Association Office Arlington, Virginia The meeting was called to order at 9:25 AM in the Association office, Arlington, Virginia. Present were: Thomas A* Dougherty John H. Marsh Dimitry Poutiatine Harrison B. Rhodes, Edward R. Zacharias Ph.D. CsrtainTeed Corp., AIA/NA President Raybestos-Manhattan, Inc. Johns-Manvilie Corp. Union Carbide Corp. Molded Materials Co. Others: R. H. Mereness B. J. Pigg John Autry Earl Parker AIA/NA Executive Director AIA/NA Administrative Assistan Johns-Manrille Corp. Johns-Manville Corp. Minutas On motion, minutes of previous meeting, October 11, 1977, were approved except for following correction: The'word "friable" inserted between "all" and "materials," second sentence, para graph 2, page 3. The Executive Director said follcw-up action from last meeting which required letters to GAT Corporation and Crown Zellerbach concerning membership and an irresponsible ad vertisement, respectively, had been done. In response to the Committee's agreement of October 11 that Dr. Hilton Lewinsohn, Medical Director, Raybestos-Manhattan, Inc., would be "the most appropriate correspondent" with Douglas A. Fraser, President, International Union, UAW, r e g a r d i n g `'allegations of an asbestoshealth nature contained .n his July letter to the Secretary cf Labor, Mr. Marsh explained that he did not deem it appropriate for Dr. Lewinsohn to pursue this matter since his company is not directlv involved with the UAW. CRM C-M AD-000286 Page 2 Mr. Dougherty expressed appreciation to Messrs. Poutiatine and Marsh for their assistance in obtaining the services of Messrs. Carter (J-M), Fenner (J-M), Reis (J-M), and Weaver (r /m ) to servo in various committee assignments as was agreed on at last meeting. Introduction Mr. Dougherty explained the circumstances that precluded the attendance of*committee members Messrs. Rainey and Schwarz at the meeting. In addition, Mr. Dougherty said Mr. Rainey had advised that press of business made it necessary for him to resign from the Executive Committee. Mr. Dougherty advised that Mr. Gabrielson had been invited to attend the meeting but was in formed that he could not attend. Financial Affairs ' The financial statement for the ten months period ended October 31, 1977, was reviewed by the Executive Director. Total assets of $154,034 and liabilities of $107,692 result in a net worth balance of $46,342 on an accrual basis. Net worth of preceding month's statement was $30,203. Variances between budget and expenditures were explained. Payments to date on EEH Study total $166,677.34. It was reported at the October 11 meeting that Will i a m T. Malloy, executive vice president, EEH, had confirmed that the total cost for completion o f the study as currently defined is $170,000. A total of $22,950.41 has been expended to date on Dr. Er.terline's research of medical literature and review of work by Dr. Ian H i g g i n s , University of Michigan. Dr. Enterline ex pects to finish the asbestosis phase of his project by end year. It is not expected thatthis w ork will result in significant e x penditures. As a related matter, "physician'' review of the completed work has been completed by Dr. Weill and is now in progress by Dr. Lewinsohn. It was agreed that Special Counsel should also request similar review by Dr. Kotin. The Executive Director was requested to so advise Special Counsel. A general discussion followed concerning the legal-medical research project and the anticipated state of the medical art paper being developed by Special Counsel. On motion, the financial statement was accepted as presented. CRMC-MAD-000287 Page 3 Executive Director's Report OSHA -- Award of a contract by OSEA to RTI for purpose of consolidating the CONSAD and RTI technological and* economic impact assessment studies of the manufacturing and construction industries, respectively, appears imminent. The delay has been due to negotiations on cost of contract. A spokesman for the consulting fina, JRB Associates, coordinating economic impact assessments for OSHA, has advised that a completion date of April 15, 1978 is now forecast for this work. The principal task in consolidation of the two studies relates to resolving different economic methodology used in development. There is no indication that OSHA is proceeding with any priority in preparation of a proposed standard for the construction industry which cannot be published prior to issuance of an economic impact assessment. It is, therefore, unlikely that a public hearing on the asbestos standard(s) will be scheduled prior to mid to late summer 1978. Issuance of a proposed labeling standard by OSHA for hazardous substances may be expected by end year, according to Assistant Secretary of Labor (OSHA), Dr. Bingham, in remarks to meeting of National Safety Congr'ess on October 20. I n 'this connection, Edmund Fenner, J-M Coro., and Chairman AIA/NA Technical Committee designate, will represent his company and the Association at a Labeling and Warning'' Systems Symposium sponsored by American Conference of Governmental industrial Hygienists in Washington, D. C . , on November 21-22. EPA -- An EPA representative has advised that final amendments extending prohibition of spraying provisions of national emissions standard to all friable materials sprayed on buildings, structures, etc., containing more than 1% asbestos by weight, m a y be expected to be published in the Federal Register in January 1978. On November 10, E P A published its intent in Federal Register to determine extent of asbestos emissions than may exist rrom use of crushed stone produced from serpentine-containing rock quamries. The study was precipitated by early 1977 reports by EPA and Mt. Sinai School of Medicine that ambient air concentra tions of chrysotile fibers were as high as 17 million per cubic meter in areas adjacent to a Montgomery County (Rockville), Maryland, quarry. MESA -- President Carter signed bill November 9 which trains zers Mining Enforcement a n d - S a f e t y Administration from Interior to Labor Department, effective March 1978. CRMC-M a d . 000288 NZOSfi -- The National Institute for Occupational Safety and He a l t h awarded over 30 research contracts totaling about $6 mill i o n at close of fiscal y ear ended September 30. Of interest is a three-year contract for an inhalation study of short asbestos fibers using rats and monkeys awarded to Inter national Research and Development Corp. in the amount of $395,000. C?SC -- A final ban on asbestos-containing patching compounds, as recommended to the Commission by the staff, would encompass patching compounds which a consumer can purchase. In addition to products sold to the c o n s u m e r , the ban applies to patching compounds (containing respirable free form asbestos) which are used in residences, schools, hospitals, public buildings or other areas where consumers have access. The Commission will be briefed by staff in public meeting November 17. The use of patching compounds in consumer environments determines their status as consumer products regardless of who applies the compounds. This definition was taken from the Anaconda decision, although CPSC admits the courts have not yet reached a definitive decision on the coverage of the term "consumer product." As proposed, the effective date of the ban would be 30 days from publication of the final rule. In consnents, the staff noted that the continued marketing of the merchandise from inventory should not be permitted as the consumer would be exposed to the unreasonable risk of cancer w hich the Commission is seeking to reduce or eliminate. 3y way of recognizing the impossibility of a zero exposure level,* the*ban would allow a trace amount of asbestos in a sample because of the ever present background contamination. This limit in 1 fiber/1000 particles in a sample. This w ould limit the fiber content to less than 0.25% by weight. Dr. William Nicholson, Mt. Sinai School of Medicine and CPSC consultant, advised on this standard. Emberizing -ash would be banned im mediately on publication of the ban. (Note: A t the Commission briefing November 17, considerable discussion centered on back ground contamination and definitions, e.g., fiber and particulates. Since data now available to CPSC staff is incomplete, the Commission indicated it is leaning toward "intentional addition of asbestos" rather than a specific level of fibers for definition of bar. on asbestos-containing?spackling compounds in order to proceed as soon as possible. The Commission is expected to extend publication of the ban from November 23 to December 12.' CRMC Page 5 I I State Developments -- A comprehensive digest of state laws and regulations affecting asbestos is nearing completion by Mark Grayson of staff and will be distributed to members for information and guidance in the near future. States which have been recently or are currently active in this area include: Mew Jersey, Iowa, California, Illinois, Washington and Con necticut. Specifics have been provided to Dr. Rhodes, Chairman of the Standards Advisory Committee. R. T. Vanderbilt Co_.__-__O__S_H_A__C_o_n_gressional Let t er Exchange -- Trui recent exchange of correspondence between R. T. Vanderoiic CO., and OSHA and members of Congress which primarily deals with the controversy over whether tremolitic talc contains asbestos was reviewed. It was agreed that the subject should be followed,, but that no resoonse to the "Asbestos Fact Sheet" issued by OSHA to members of Congress in August would be made by the Association. Meetings of Interest -- Attention was invited to upcoming meetings od"interest to the Association. Specific reference was macla to the Confsrsnc* on occupational Exposure -t o 'Fibrous had Particulate Dust and their Extension into the Environment scheduled for December 4-7, Mayflower Hotel, Washington, D. C . , jointly sponsored by the Society for Occupational and Environmental Health and MESA. The program was discussed. It was noted that announced speakers are in*the main associated With distinct bias against the asbestos industry. Attendance of AIA/NA members was encouraged. Directors Meeting, December 14 -- It was reported that Dr. Eula Bingham, Assistant Secretary of Labor (OSHA), had accepted an invitation to be luncheon speaker at the Directors Meeting, December 14, Stouffer's National Center Hotel, Arlington, VA. Technical Committee Report and_AIA/NA Asbestos Dust Sampling and Exchange Program As a follow-on to committee assignments agreed on at last Executive Committee meeting, October 11, Dr. Rhodes said he had recently visited with Mr. Fenner, Chairman designate, Technical Committee, and discussed in general terms a program of work for the year. Thorough review of the EEH draft document ana development of the work practices approach for an asbestos construction standard alternate were identified as priority projects. The Technical Committee will meet November 16 in the Association office. A refinement of membership composition is in order and will be ac complished. CRMC-MAD -000290 Pace 6 Dr. Rhodes reported on responses to the AI A / N A round robin dust sampling and exchange program- Seventeen recipients of the protocol have agreed to participate by collecting and counting and 8 have agreed to count. Dr. Rhodes spoke of a meeting with NTOSK representatives on October 12 in Cincinnati regarding carticipation. (Notes In letter dated November 11 NIOSH has declined to participate in the program.) A meeting with Mr. Phillip Brown, OSHA, is scheduled to further explore the pos sibility of OSHA's participation. The Asbestos Sampling and Exchange Program Committee will meet in the Association office, November 17. Government Activities Committee Dr. Rhodes reviewed current status of the recent generic cancer regulation proposed by OSHA. It was emphasized that formidable opposition to the proposal is being developed by the Manufacturing'Chemists Association and Synthetic Organic Chemical Manufacturers Association. The Executive Director referred to an Inter-Industry Task Force comprised of about 30 large firms which is developing" a "rational cancer policy" for submission to OSHA. It was stated that Dr. Paul Kotin, J-M Corporation, is a con tributor to the task force project. The due date for comments on the prooosal will be extended from December 8 to January 9, 1978. Dr. Rhodes said it was his understanding that two law suits, one ir. New York and one in Texas, were being filed by industry or. the generic cancer proposal. The suits allege denial of due process and that the proposal was?improperly issued since no economic impact assessment had been made. A third suit challenging OSHA's statutory authority was also mentioned as being a possibility . As to possible actions by AIA/NA, Dr. Rhodes suggested that: close touch be maintained with other industry associations such as MCA and SOCMA; efforts should be directed to only those areas that m ight specifically affect asbestos; Dr. Weill might consider his medical.statement submitted with the Association's response to OSHA on the proposed revision to the manufacturing, standard; consideration might be given to development of an "estimate of risk" for occupational exposure to asbestos. Alternatively, the Association might endrse a response such as being prepared by SOCMA, etc.; a token or comprehensive asbestos industry response by AIA/NA could be prepared. Indi vidual member companies may wish to comment. No specific decision was made as to the Association's possible actions with ragard to OSHA's generic cancer proposal. The matter will be further con sidered at the next-regular meeting. CRMC-MAD-000291 Page 7 Draft 1978 Budget Mr. Dougherty referred to a first draft of an Association budget for fiscal (calendar) year 1978 as prepared by staff. The various line items were spoken to briefly . Committee members were requested to be prepared to give detailed consideration of the 1978 budget at next regular meeting of the Committee prior to budget presentation to Directors, December 14. Captive Insurance Program The Executive Director said Araxisk, Inc. had received completed ^questionnaires 'from nine of the 15 participating companies. Effort will be made to obtain the remaining questionnaires as soon as possible in order to complete the study. Medical Revlew/Intemational Activities Mr. Marsh made reference to three new medical papers by the doctors McDonald which ^re yet to be published. He said one paper states that "almost all cases of mesothelioma are traceable to crocidolite and amosite." Mr. Marsh stated that the Asbestos International Association is currently working wi t h the Commission of the European C o m munities as that organization prepares a directive on asbestos. In addition, AIA is active with the British Parliamentary Com mission on Asbestos in an effort to achieve mutually acceptable regulations. Mr. Marsh stated a report: on the October Executive Committee meeting of the' international association would be circulated in the near future. Resolution on Association Representations in Re3Pnse to Government Initiatives Mr. Dougherty said that written comments on this item have been received from Hollingsworth & Vose C o ., Onion Carbide Cor?., and Johns-Manville Corp. Copies were provided to committee members. In vie w of Mr. P o u t i a t i n e 's letter o f November 1, Mr. Dougherty exoressed the hopeithat the issue could n ew be resolved at the December Directors meeting without necessity for any change to the A s s o c i a t i o n 's b y l a w s . Other Business Messrs. John Autry and Earl Parker, Johns-Manville Corp., were present during office luncheon to explain details and current C RM C -M A D -000292 status of the Asbestos Health Hazards Compensation Act, H.P.. 3689, which was introduced by Rep. Millicent Fenwick (R-NJ) and others earlier this year. The bill is expected to be scheduled for hearings during next session of Congress. Fol lowing discussion, and as an adjunct to the Directors meeting, December 14, it was agreed that Dennis H. Markusson, Legal Affairs Dept., J-M C o r p . / w o u l d be invited to give a presentation on the Act for the benefit of interested directors and others at a dinner on December 13. The Executive Director was requested to ro advise directors in meeting announcement and include copy of H.R. 8639 and digest thereof in mailing. Mr. Dougherty said that the December Directors meeting could be the last one for George Barge prior to his planned retirement April 1, 1978. In recognition o f his outstanding and dedicated work on behalf of the Association as a director since 1971, including service o n the Executive Committee front September 1974 to September 1977/ the Committee agreed and the Executive Director *was requested to obtain an appropriate memento for presentaiton at the December meeting. The next -regular meeting of the Executive Committee is scheduled for Tuesday, December 13, 1977, commencing at 10:00 AM in the Association office. Adjournment There being no further business, the meeting was adjourned at 2:45 PM. .r + ? n n . , j L' R1 R. Mereness Executive Director 22 November 1977 RHM:pl CRMC-MAD-000293 4 November 19 77 Memorandum F o r : S u b je c t! E X E C U T IV E COM M ITTEE M e e tin g , Tu e sd ay, Novem ber IS En c lo s e d p le ase fin d th e agenda to r th e n e x t re g u la r m eeting o f th e E x e c u t iv e C o m m itte e , T u e s d a y , Novem ber 1 5 , com m encing a t 9 t0 0 :M i n t h e A s s o c i a t i o n 's o f i f i c e . L u n c h e o n w i l l b e s e rve d in th e o f f ic e ; Adjournm ent is e xpected a t about 3 00 p m . - The fo llo w in g m a te ria ls are forw arded as m a tte rs o f in te r e s t to th e C om m itteet A . A IA /N A le tt e r to c h ie f e xe c u tive o ffic e r , Crown Z e lle rb a e h ; C o rp . re g a rd in g , "M ine F ib e r s In c . a d ve rtis e m e n t in Modern P a in t t C o a tin g s . A l s o , J o h n s -M a n v ille l e t t e r on same s u b je c t . B . Memo fro m D i r e c t o r - G e n e r a l , A s b e s to s i n t e r n a t i o n a l A s s o c ia tio n e n c lo s in g d r a ft rs s o lu tio n (E v a n s Report) on h e a lth h a za r d s 'o f :asb estos fo r European P a rlia m e n t (Com m ittee on th e En v iro n m e n t, P u b lic H e a lth and Consumer P r o te c tio n ). C . L e tte r to O r . W e ill o f 1 0 / 3 1 / 7 7 , correspondence V a n d e r b ilt C o -O S H A t o members o f C o n g re s s . D . News c lip s r n ;A s b e s to s H e a lth H a za rd s Com pensation A c t , H .R . 8689. U, RBM tv En c lo su re s CRMC- m ASBESTOS INFORMATION ASSOCIATION 17*8 M ltm a h Davi* MlQf>^*CrytS;auv#l<, Sum 809 AringtM, VkgkW 3 0 3 (703) 979-1ISO EX EC U T IV E COM M ITTEE M EETIN G A s so c ia tio n O ffic e A rlin g to n , V irg in ! Novem ber 15 , 19 77 Agenda I M inu tes o f L a s t M a ttin g I I Fin a n c ia l Report H I Ex a e n tiva D ir a c to r1a R apo rt A . F e d e r a l - S t a t e R e g u la t o r y Activities B . V a n d e r b iltC o . -- OSHA C on gre ssion al L a tta r Exehanga C . M eetingsvend A c t iv it ie s o f X n ta ra a t D . D ira e to ra M a s tin g , Decem ber 14 I V S ta n d a r d 8 T e c h n ic a l Coannit t a a R a p o r t A IA /N A D u a t Sam plin g and Exehanga Program -- D r . Rhodas v "G o ve rn m e n ta l 'A c t i v it i e s Com m ittee" -- M r. D o u g h e rty a.A . C o n l p o s i t i o n ,T a s ) c s F u n c t i o n s C u rra n t% Zta m a ^fo rk C o n a id a ra tio n l l ^ O S I^ p r^ tfid M G a n a rie lC a n e a r P o lic y 2 ) 0 S H A :> P t^ p b 1 li'd ? 'R ttla o n R i g h t t o Know (Em plo yie iacoe ss to lo g o f o c c u p a tio n a l in ju tia s and illn a a s a s ) 3) Cl'SC I n q u i r y i n t o " o t h e r p ro d u c ts w h ic h n ay exposa consum ers to re s p ira b le asbestos fib e rs " 4) P o s s ib le a c tio n s on s ta te in itia tiv e s v z A c tiv ity Areas A . L e g a lH K e d ie a l .R e se a rch P rog ram -- M r. G a b rie ls o n B . C a p tiv e ln s u r n e e Program - - M r. R ainey c . M ed ic alR evie w -- M r. M arsh D . In te r n a tio n a l 'A e tit iv ie s -- M r. Marsh E . M em bership :-- M r. Sehw ars i--- M ssrs. Schw arz Zach a rie s ta tio n . P u b lic a tio n s -- M r. P o u tia tin e l o n i T a s J c F o r c e -- M r . G a b r i e l s o n Ltion f o r p u b l i c h e a r i n g o n (Over) CRMC-MAD-000295 Pag 2 V II R a a o la tio n on A a a o e ia tio n *a p r* n ta tio n a in M i r o n i * t o G o v a **** X n i t i a f c i v a * M r . D o u g n a r ty VIII Draft Budgat -- 1978 I X O th a r B u ainaaa H a x t M aatlng X A d jo u rx u n a n t N o t: Lunchaon w i l l ba aarvad in A lA /N A o ffic a . John A o try and E a r l ia r k a r io f Jo h n n -M a n villa w i l l d ia cuaa H .R . 8 6 8 9 , "A a b a a to a S a a lth H a za rd a Cora- p a n a a tio n A e t" CRMC-MAD-000296 Johns-Manville mm ""-' < i-y/tj/.y,,,, ........ .. ..... , ... Internal Correspondence R. P. Carter To; w. A. Cooper W. B. Reitze .,,S' P. J. Solon, J r . * ^ S. Spoil ^ W. C. Streib July 31, 1974 From; E. M. Fenner CopfM: File & C D**' Subjoct: MEETING - 9:00 A . M . , AUGUST 6, 1974 DEFINITION OF AN ASBESTOS FIBER - OSHA STANDARD As you are aware, -there has been considerable discussion concerning the definition of an asbestos fiber as presently used by OSHA, particularly in regard to the prescribed aspect ratio of 3 to 1. ASTM has organized Committee E-34, "Committee on Occupational Health and Safety Aspects of Materials, Physical and Biological Agents". There are a number of subcommittees and task groupswithin this committee. One of these task groups is concerned with "naturally occurring inorganic fibers". This task group is presently engaged in writing for submittal to OSHA through normal ASTM'channels a revised standard for occupational exposure to asbestos fibers. One of the important sections being written by this task group is concerned with the definition of asbestos fiber. The next meeting of the Task Group on Naturally Occurring Inorganic Fibers takes place on August 14 and 14 in Canada. I would very much like to be able to submit to the group a Johns-Manville definition of an asbestos fiber. In order to accomplish this, I am requesting that you attend a meeting to discuss the subject at 9:00 A.M. on Tuesday, August 6, in our Conference Room, 4 North. For background information prior to the meeting, I enclose the following: (1) A letter to F. J. Solon, J r . , describing ASTM Committee E-34. (2) . A definition, for asbestos- fiber as prepared by a subsection of the task group for affirmative- or negative ballotting b y t h e group members. * . CRMC-MAD-000297 R. P. Carter, -et al Page 2 July 31, 1974 (3) A series of definitions of asbestos as previously submitted by the following people: A. A. Hodgson, Cape Asbestos Fibres Limited G. Gagnon, Lake Asbestos of Quebec Limited M. Grimard, M.D., Department of Nationa-l-Health & Welfare of Canada R. B. Steele, Asbestos Corporation Limited A. A. Harvey, R. T. Vanderbilt Company (4) A definition of an asbestos fiber as prepared by Dr. Steven Holmes of the Asbestosis Research Council. i5) The AST M present definition of asbestos fiber. (6) & (6A) Two anonymous definitions of asbestos. (7) An anonymous definition of naturally occurring inorganic fibers. (8) A copy of the original proposal for the formation of Idle Task Group on Naturally Inorganic Fibers. (9) A listing of active members of the task group and all others on the mailing list for material. E. M. Fenner * * CRMC-MAD-000298 SmUMBBTAI* LISTING OF DEFINITIONS APPENDIX# Doounrat No. 11 19 April 1974 This listing is a supplement to Document No. 5 published as Appendix 6 of the minutes of the second meeting of the Task cs-oup on Naturally Occuring Inorganic Fibers of ASTM Committee E-34. 1. Definitions submitted by Mr. A. A. Hodgson, Cape Asbestos Fibres Limited," 24 Jan 1974. fibres Fibres are defined as being of a length greater than 5m and having a lengtb/breath ratio of at least 3:1. There is no upper limit for the length of the fibres, but a maximum diameter of 3t-cx is defined. Airborne asbestos dust concentrations are expressed in fibers per milliliter of air (f/ml). (taken from the Asbestosis Research Council's Technical Note 1, paragraph 2.1) asbestos - acicular silicate mineral, with a structure based on silicon - oxygen tetrahedra, composed of crystals in a predominantly^-parallel orientation, and distinguished by its ability to split indefinitely from iua macro form to individual flexible fibrils having minimum length * to breath ratio of 3 to 1 and croes sectional dimensions approaching 0.01 m * ... ... 2. Definitions submitted by Mr. G. Gagnon, Lake Asbestos of Quebec Limited, 28 Jan 1974: fibre - any material in a form such that it has a minimum ratio of length to average maximum transverse dimensions of 10-to 1. asbestos fibre- - silicate mineral, with a structure based- upon silicon oxygen tetrahedra,that fits the definition of a fibre and is- composed of single crystals in predominantly parallel orientation*. Common .usage also designates a collectivity of asbestos fibres aa asbestos fibres. Definitions submitted by Dr. M. Grimard,. Chief, Heath-Effects Division, Bhvlronmental-Health Directorate, Department of National Health and. Welfare of Canada, " flbre - (definition as applied to minerals)! any materiel which by micros copy presents the following; optical characteristics: a ffUfform or- bundleof filifon bodies having, a length to diameter-ratio of at least 3:T asbestos- fiber -- acicular silicate; mineral, with: a. structure based upon silicon-oxygen tetrahedra,. that fits the definition or a fiber, and-is composed* of single crystala in predominantly: parallel orientation. ___ ^ C R M C -M A D -000299 - 2- 4 Definitions submitted* by Hr. A- M. Harvey, Manager, Legal and Product*' - Application, R. T. Vanderbilt Company* Inc., 4 Jan 1974: mineral fiber - any fora of mineral characterized by properties of flexibility and length to width ratio of at least 100, and composed of definite crystal unit cello oriented with respect to a specific axis. asbestos - is a generic term for a amber of hydrated silicate minerals that, when crushed or processed, separate into flexible fibers made up of fibrils. These minerals include chrysotile, crooidolite, aaosite, anthophyllite asbestos, tremolite asbestos and actinolite asbestos. 5. Definitions submitted by Mr. ft. B. Steele, Laboratory Services Engineer, Product Research and Development Department, Asbestos Corporation Limited, 5 March 1974: Fibril - Is a polymeric form of solid whose component repeating sub-units extend along a single major axis, and which can not be subdivided along this longitudinal axis without destroying the integrity of the structure. Fiber - Is a bundle of fibrils in parallelalignment, the composite possessing a maximum diameter of 100 microns, and a minimum aspect ratio of 20. _____ . Asbestos - Is a generic term for a number of silicate minerals, the morphology cf whose component particles fits the definition of a fiber. Asbestos Fiber - Is a fiber belonging to one of the six types of asbestos minerals: crysotile, orocidolito, amosite, anthophyllite asbestos, tremolite asbestos, and acilnblite asbestos. 6. Definitions submitted by Mr. A. A. Harvey, Manager, Legal and Products Application, R. T. Vanderbilt Company, Ine., 30 Jan 1974? Definitiona taken from pages 26, 27 174 and 175 of the 1973 ASIM Qlcrsaary: Refer to page 3. 7 Refer-to Appendix 5 and 6 of the.minutes ,of the third meeting of the Task Group on Naturally Occurring Inorganic Fibers "I * * & CRMC-MAD-000300 - .* Environmental Affairs Department Denver GHQ March: 23, 19 73 MEMO TO FILE TALC PRODUCERS MEETING W. T. VANDERBILT OFFICES, NEW YORK CITY MARCH 21, 1973 The major part of the meeting was a presentation by Dr. William Smith of Fairleigh Dickinson University, discussing the results of his asbestos fiber and talc animal studies utilizing hamsters. I consider the following comments made by Dr. Smith to be important information: k (1) Hamsters were used because their response to asbestos fiber inhalation is very similar to that of man. Additionally, they have a short life span which speeds the determination of results. (2) Dr. Smith stated that tremolitic talc was not carcinogenic in his animals. It appeared to be innocuous and induced only minor response. (3) As opposed to talc, Dr. Smith reported much carcinogenic activity in his animals with intrapleural dosages of asbestos fiber ranging from 6 to 25 milligrams. He reported that crocidolite was the most carcinogenic, amosite the next and chrysotile the least. E. M. Fenner EMF/emr CRMC-MAD-000301 * C O P' Y October 9, 1974 Mr. H. B. Vanderbilt President Chief Executive Officer R. T. Vanderbilt Company, Inc. 30 Winfield Street Norwalk, Connecticut; 08855 Dear Mr. Vanderbilt: of This is in reply to your letter of September 26, concerning your request for relief from the asbestos standard for your talcs containing non-fibrous trenolite, actinolite, and' anthophyllite. My letter of August 6 stated'that.non-fibrous or non-asbestiform ninerals such as non-asbestiform trenolite are not within the scope of the asbestos standard and, therefore, the provisions of that standard do not apply to talc containing non-asbestiform minerals. NIOSH is currently conducting a thorough investigation into the exact minerals to which talc workers were exposed in those studies where asbestosis or ocher adverse medical effects were found. Pending the receipt and evaluation by OSHA of the report by NIOSH on this investigation, if you,have'scientific evidence that the naturally occurring talcs, prior to processing by milling or crushing, do not contain fibrous or asbestiform trenolite, antophyllite, actinolite or other asbestiform minerals, you may certify to your customers that the talc does not contain asbestos. . Fibrous, asbestiform minerals such as fibrous trenolite means naturally occurring asbestiform minerals which prior to or after crushing and processing, contain fibers made up of fibrils. Sincerely, /b / John H. Stender A/.' John H. Stender Assistant Secretary of Labor CRMC-MAD-000302 Johns-Manville Corporation Greenwood Plaza Denver, Colorado 80217 Health, 8afety A Environment Department N o v e m b e r 21, 1974 Mr. J. S. G i b b o n s Manager of Purchases R. T. V a n d e r b i l t C o ., 30 W i n f i e l d St. Norwalk, CONN 06855 Inc. Dear Mr. Gibbonss Y o u r r e q u e s t .,,for.,Mat.e,ria,l_,Safety ...Data .Sheets ohas b e e n referred to me for reply. E n c l o s e d is a ;U.S. D e p a r t m e n t :o f Laloor M a t e r i a l S a f e t y D a t a S h e e t ;f o r iJohns-Manville 's . M I C R O - C E L E . If additional information is needed, please contact me directly. V e r y truly, yours, A E d m u n d t.M. F e n n e r , Technical Affairs Director EMF/emr Enc. CRMC-MAD-000303 Johns-M anville To: p. Kotin, M.D. InternalC orrespondence /? Dote: May 26, 1976 From: E. M. Fenner Copier,: G. W. bright, M.D. w. B. Reitze Subiect: AMI:'.K1 CAN MI NI NG CONGRESS NONCOAL OCCUPATIONAL HEALTH COMMITTEE R. P. Carter This committee held its first meeting in Washington on Tuesday, May 25. The first half of the meeting was a discussion of the purpose and scope of the committee. Then considerable time was devoted to comments on the forthcoming meeting of the Federal Metal and Nonmetal Mine Safety Advisory Committee (see copy of our meeting agenda a ttached). An item on the Advisory Committee meeting agenda is the MESA suggested revised standard for exposure to asbestos (copy attached). The critical change they proposed is the substitution of the term "mineral fibers" for asbestos, and the elimination of any definition of asbestos. Literal interpretation of the proposed standard could mean that any naturally occurring mineral fiber which meets their definition: "A fiber is defined as a particle that exceeds 5 microns in length but not 5 microns in width and which has a length to width ratio of at least 3 to 1" could be subject to this ruling. The chairman of the committee, Bernard R. Roy of Amax Inc., appointed an ad hoc subcommittee consisting of: C. S. Thompson, Ph.D., R. T. Vanderbilt, Chairman David J. Smith, M.D., U. S. Steel Corporation Michael J. Doyle, The Hanna Mining Co. E. M. Fenner (<> prcp.it i' A M O ' s ('oiuttUMil s on <!<( e r m iin* the m o s t e l l o c t i v o not to endorse t h e proposal. I lie p rogos/'d : ; l a n d a id way oi convincing the and I d commi lice For your further information, lists of the Committee members and those attending the May 25 meeting are attached. May I please have your comments. CRMC-MAD-000304 H om oo J o h n s -M a n v ilie F. J. Solon, Jr. IFll8^3I^Orrc9puiiueH6^ B& Oat; N o v e m b e r 26, 1974 From: e . M. F e n n e r Cop!*.: P . Kotin, M.D. W. B. Reitze Subject: O S H A M e m o r a n d u m -- A s b e s tos R. S. L a m a r r e c e i v e d a p h o n e cal l t o d a y f r o m R o b e r t B a c o n o f R. T. V a n d e r b i l t Company. Mr. B a c o n c a l l e d Mr. L a m a r w h e n h e was unable to c o n t a c t R. P. Carter. Mr. Bacon w i shed to inform Johns-Manvilie that he had received a copy of an OSHA field memorandum concerning a policy change in the interpretation of the asbestos standard. Mr. Bacon agreed to se n d Mr. Lamar a copy of the memorandum and read to him over the phone its major points. These points are: 1. T h e O S H A m i c r o s c o p i s t w i l l b e i n s t r u c t e d to c o u n t only fibers, notiineedlelikeVparticles or slivers. F i b e r s m u s t ,be* made'' u p Of"fibr i l s a n d h a v e fr a y e d ends. Tremolite is to be considered a sliver. 2. I n a d d i t i o n to c o u n t i n g o n l y fibers t h a t m e e t the above definition, the following size limitation will apply. A n a s p e c t r a t i o o f 5 to 1. A f i b e r d i a m e t e r n o t o v e r 3 m i c r o n s a n d a f i b e r l e n g t h n o t o v e r 30 microns. CRMC-MAD-000305 Johns-Manville To: P. Kotin, M. D. Internal Correspondence 3, Date: March .18 , 1975 From: E. M. F e n n e r Copies: File & C Subject: BORG WARNER TALC SIT U A T IO N Following your suggestion, I talked with John Dement of N IOSH this morning. The main points of information that John supplied are: (1) The talc.being used by Borg Warner is..:R. :T.: Vanderbilt's NYTAL 200. . - : (2) Both bulk and airborne samples were taken by the .OSHA inspector. :? . . (3) Their X-ray and electron microscope -examination of the tale showed no appreciable chrysotile but. ^considerable amounts of tremolite and anthophyllite. (4) Their examination of the samples using..the industrial hygiene analysis procedure from'the OSHA asbestos standard and using the S t e n d e r r e v i s e d 'definition of a fiber found approximately 40 fibers per cc in the airborne samples. John Dement asked that we keep him apprised of developments in the talc situation. / CRMC-MAD-000306 Johns-Manville Internal Correspondence To: R. J. Rushforth - 4S Date: March 10, 19 75 ---- - From: E. M. Fenner - Copies: Subject: W. B. Reitze H. L. Rucker H. W. Gilbert - R&D J. B. Lee - l.aurinburg W. Kiser - Manville W. A. Brausa Waukegan PHENYL-BETA-NAPTHYLAMIN. S YOUR LETTERS OF. F E B . 27 and MARCH 3 W. B. Reitze and I have reviewed your two letters and the attached correspondence, particularly the letter from DuPont and the Material Safety Data Sheet they forwarded to u s - Based on our past experience with DuPont and our knowledge of the thorough product testing they do, we are inclined to believe that the comments on their Material Safety Data Sheet are factual. It may be that V a n d e r b i l t 's Agerite Powder is contaminated with phenyl-beta-napthylamine and D u P o n t 's product is not. We have no knowledge of any potential hazard associated with the substitute materials suggested by Research. If you can obtain Material Safety Data Sheets for the other materials, I will be glad to review then with W. B. Reitze and forward you our opinion as to their suitability. However, w e s e e no problem with DuPont's NEOZONE D, based on their letter and Material Safety Data Sheet. CRMC-MAD-000307 \ tv f* * - >, O 'l ' - Johns-iVlanville T/JU, - i O . w ' Interna! Correspondence Date: N O V . 6, 1974 ; / i g n t , Y, D. - 4N T / U r ' M E E T I N G -- R & D PillDAY , MOV . 8, 19 74 ? . K o t i n , M.D. - 4N A r e i b - R&D :>pe:u. - R&D :5. Leineweber - R&D F , Finkbiner III - 5W F. J. Solon, Jr. E. M. Fenner - 4N H. R. Keefe - 2W R. S. Lamar - R&D W. B. Reitze - 4N As i discussed with each of you, a meeting has now been confirmed for 2:00 P.M. on Friday, November 8, to review o u r analysis o f Vanderbilt's N y t a l , to consider the possibility o f a meeting with Vanderbilt to review our r e s u l t s and t o explore further action which we may want co pursu0 with respect to the talc labeling situation. This meeting will be held at the Research and Development Center in the Second Floor Conference Room, West End. Enclosed is a package of certain documents for you to review prior to the meeting. Enos. CRMC-MAD-000308 Johns-Manville Internal Correspondence lb: F. J. Solon, Jr, Date: August 21, 1974 From: R * P . Carter Copies: E. M. Fenner File & C Subject: CLASSIFICATION OF TREMOLITE UNDER OSHA ASBESTOS STANDARD CONVERSATION WITH BOB BACON ON AUGUST 19 Bob Bacon of R. T. Vanderbilt Co. called me on August 19 to advise me that he received a letter last week from John Stender which contained OSHA's opinion as to the applicability of the Asbestos Standard to talc. Bob read Stender's letter to me over the telephone and indicated that he would immediately send a copy to me air mail. Stender basically stated in his letter that OSHA's Asbestos Standard applied only to fibrous minerals and talc containing non-asbestiform tremolite is not covered within the Standard... --Fibers -must -conform to- the definition contained within OSHA's Asbestos Standard to be included therein. Bob Bacon acted as if he had achieved a victory from OSHA, but the preliminary data we have received from Research concerning our evaluation of their talc, would indicate contrary. However, Vanderbilt is relying on their own conclusion that the tremolite contained in their talc is "non-fibrous". As you may be aware, R. T. Vanderbilt recently bought International Talc. Bob Bacon indicated that one portion of an International Talc deposit contains a considerable amount of fibrous chrysotile and anthophyllite, in addition to containing a minerological phenomenon, fibrous talc. In view of this finding, Vanderbilt intends sometime in the future to insert an asbestos warning label on talc mined from this portion of that particular deposit. However, they have no present intention of labeling any other talc. Based on the letter which Vanderbilt received from John Stender, it would be my recommendation that we reconvene another meeting with those individuals who attended the talc labeling meeting on July 24, and recommend that we promptly advise our customers of our intention to label talc and to proceed with such labeling. CRMC-M AD-000309 F. J. Solon, Jr. Page 2 August 21, 1974 Naturally, we should first carefully review Stender's letter as soon as we receive a copy. It would also be my recommendation that prior to our institution of asbestos warning labels on talc, we should present Vanderbilt with the results of our analysis of their talc and urge them to c o n s i d e r .applying a.similar label. In view of the above developments, I see no reason for us to schedule a special meeting with OSHA as was discussed at the July 24 talc labeling meeting. R. P. Carter CRMC-MAD-000310 m Johns-Manville internal Correspondence To: F. J. Solon, Jr. Oat: Oct. 4, 1974 from: R. P. Carter Copies: File & C Subject: TREMOLITIC TALC Bob Bacon called me this afternoon to advise me he had received a telephone call from Dan Boyd. Boyd indicated that he had been directed by John Stender to prepare a letter to R. T. Vanderbilt for Stender's signature, advising Vanderbilt that they can certify to their customers that Vanderbilt's talc (NYTAL) does not contain asbestos, provided the talc ore does not contain fibers in R. T. Vanderbilt's judgement. Boyd believes that the letter will be signed early next week. Boyd indicated to Bacon that this decision was based on guidance from Jon May at NIOSH, who advised OSHA that the evidence currently is inconclusive as to whether tremolite is carcinogenicr " Therefore, Vanderbilt should be granted some relief until NIOSH completes its investigation of tremolitic talc. As soon as this letter is signed by Stender, Boyd agreed to call Bacon and read the contents of the letter to him. Bob Bacon, in turn, has agreed to call me as soon as he hears from Boyd and will immediately forward a copy of the letter to us. If what Bob Bacon has reported is correct, I am at a loss to understand OSHA's rationale for such action. In the past, OSHA has not hesitated to regulate a substance even though there was little, if any, evidence to establish that a particular substance was harmful to man at certain exposure levels. If such a letter is in fact issued by Stender, then, in effect OSHA would be holding in abeyance the application of the asbestos definition in OSHA's asbestos standard with respect to tremolite.I I advised Bob Bacon that we were still planning to commence the insertion of warning labels on all commercial talc on or about November 1, and would not reconsider this decision until such time as we had an opportunity to review Stender's forthcoming letter. CRMC-MAD-000311 F. J. Solon, Jr. Page 2 O c t . 4, 1974 In the event we should decide to schedule a meeting with Howard Shulte, Dan Boyd and Alexander Reis, it might be advisable to first meet with Jon May at NIOSH to ascertain where they stand in their study of tremolitic talc and learn first-hand what his recommendation was to OSHA with respect to Vanderbilt's request. This background may be beneficial to us at a meeting with Shulte, Boyd and Reis. R. P. Carter RPC/emr CRMC-MAD-000312 ........ ...... ...... ....... .. ' M \ Johns-Manville Internal Correspondence To: F. J. Solon, Jr. ^ Date: Oct. 31, 1974 From: R. P. Carter Copies: File & C Subject: TELEPHONE CONVERSATION WITH BOB BACON Bob Bacon, Assistant to the President, R. T. Vanderbilt Co., called me this morning to advise that our talc labeling decision is causing a "big stink". Vanderbilt's talc customers are very concerned as to why J-M has decided to commence inserting asbestos caution labels on all packages of talc. R. T. Vanderbilt Co. is of the opinion that it is Johns-Manville's intention to hurt their company. Bob Bacon requested that I bring this matter to the highest level of management within J-M and indicate that Vanderbilt is "very, very upset" with our labeling decision, which they feel will result in "irreparable damage" to them. Bob Bacon indicated that he is going to request Hugh Vanderbilt to personally call a Senior Officer at Johns-Manville to voice their concern. It has been obvious for some time from my conversations with Bob Bacon that Vanderbilt is very concerned about our talc labeling decision. Without attempting to characterize the motivating factors behind Bob Bacon's frequent telephone conversations to me, their concern may very well be based on a distinct difference between their "corporate conscience" and ours. Certainly, our decision in no way reflects any intention on J-M's part to hurt or destroy Vanderbilt, which is Vanderbilt's current feeling. It is Vanderbilt's opinion that based on John Stender's letter of October 9, 1974, to Hugh Vanderbilt, their talc does not contain asbestiform minerals such as fibrous tremolite. Perhaps that is true, and it is even possible that our talc does not contain asbestiform minerals based on the definition contained in Stender's letter. Basically, Vanderbilt is requesting, if not demanding, that J-M reverse its talc labeling decisior based on Stender's letter. As you will recall, I recommended several weeks ago that we promptly take the following actions in the sequence listed below: (1) Reconvene a meeting of the talc labeling group which met early this past Summer to review R&D's analyses of Vanderbilt's Nytal and to determine J-M policy and action in response to Stender's October 9 letter. ! CRMC-MAD-000313 m Johns-Manville To: R.P. Carter - 4N From: P . A . M a r t i n s o n Copies: Subject: LABELLING DESERTALC PRODUCTS Internal Correspondence Date: October 25, 1974 At the F&M Division staff meeting last week, there appeared to be general consensus that J-M should approach R.T. Vanderbilt people and outline, in some detail, why we are taking the position to label our talc products. It is the feeling that J-M should not take the position of policing such matters and certainly not suggest to Vanderbilt that they should label their products. Perhaps, this point can be put across by implication. Purpose of this letter is to suggest that you discuss the matter with R.S. Lamar. I believe you gentlemen can best resolve at what level the follow up should be made, i.e., Research or your level which essentially would be legal. I am sure that you are aware that Dick Lamar is acquainted with Mr. Bacon and "Slim" Thompson of Vanderbilt. Please let me know what is determined after your discussion with Mr. Lamar. A/i *i V T * y .J . Sulewski /it.S. Lamar P. Kotin F.J. Solon W.B. Reitze A.C.F. Finkbiner H.R. Keefe D C CRMC-MAD -000315 A ly l Johns-Manviile Internal Correspondence To: See Below* From: r . p. Carter Gopies: p i l e & C Date: July 22, 1974 Subject: TALC LABELING MEETING *H. R. Keefe Paul Kotin, M.D J. A. McKinney F. L. Pundsack W. T>. Reitze F. J. Solon, Jr S. R. S p e i l W. C. Streib This is to confirm my telephone conversation with each of you, scheduling a meeting for 11:00 a.m. Wednesday, July 24, to discuss our proposed labeling of talc. This meeting will be held in the Small Board Room, Plaza West. Attached is a memo which I have prepared as background on the tremolite asbestos question. Please read the memo prior to our meeting. CRMC-MAD-000316 r^ S/Ul Johns-Manville Internal Correspondence P`. J. Solon, Jr. Date: July 16, 1974 ? V From: R . P . Carter Copies: F i l e & C h r o n o Subject: t r e m o l i t e ASBESTOS - .%*<* Ever since August 12, 1972, when the Food & Drug Administration published a proposed regulation which would prohibit the use of talc containing asbestos in food and food packaging materials, R. T. Vanderbilt Company, a leading talc producer,, has taken the position that the tremolite in their talc is not fibrous, but acicula (needle-like), and therefore cannot be con sidered "asbestos." s.-r-- < Sid Speil, Bill Streib, Dick Lamar and other personnel from J-M, including myself, have attended meetings with Vanderbilt to explore their rationale for such a position. Our Research people have always taken the position that they cannot agree with Vanderbilt's approach, as tremolite is fibrous, but have wished them luck in convincing various government agencies on their position. , ~ Not only has Vanderbilt taken such an approach with FDA, but similarly through meetings, letters and petitions, with other government agencies -- all of this intended to convince them not to classify all tremolite as "asbestos." Thusfar, Vanderbilt has been successful with two government agencies, EPA and MESA. On May 3, 1974, EPA published an amendment to its April 6, 1973 National Emission Standard for Asbestos, wherein they added the term "commerical asbestos" to distinguish between asbestos that is produced as a product and asbestos that occurs as a contaminant ingredient in other materials. The purpose of adding the term "commercial asbestos" was to make it clear that materials that contain asbestos as a contaminant only, are not covered. In the May 3 amendment, EPA indicated that questions were raised concerning the applicability of the standard to manufacturing operations that used talc. EPA indicated j that when their regulations were first proposed, talc mines were not covered by the EPA proposed standards; this was also intended to indicate that manufacturing operations !, that used talc or other materials contaminated with asbestos >, were not covered by the standard. CRMC-MAD-000317 Page 2 7 /1 6 /7 4 In addition, the information available to EPA at the time of promulgation (April 6, 1973) did not demonstrate that the mining and milling of such materials were major sources of asbestos emissions. Therefore, such materials and manu facturing operations in which they are used are excluded from the EPA Asbestos Emissions Standard. On Jury 1, 1974, the US Department of the Interior (MESA) published an asbestos standard for metal and non-metallic open pit mines. In this standard, MESA distinguished between "tremolite asbestos" and "non-asbestiform tremolite." Tremolite asbestos, under MESA's standard, is covered by a five fiber per cc standard, whereas non-asbestiform tremolite is covered by the ACGIH TLV for tremolite, 5 million particles per cubic foot. MESA, in the standard, indicated that nonasbestiform tremolite which occurs in talc deposits is not mentioned in the definition, therefore, it is not covered. Further, MESA pointed out that on May 8, 1973, a public symposium was held in Washington, D.C., to receive data on talc dust hazards in the metal and non-metallic mining industries. At that time, medical data based on both human and animal studies were presented, supporting the opinion that talc and talc-with-tremolite are not as hazardous as chrysotile and other true asbestos minerals. I spoke this week with Dr. Aurel Goodwin, Chief of Health Standards for MESA, to ascertain how MESA distinguishes between "tremolite asbestos" and "non-asbestiform tremolite." Dr. Goodwin said that MESA has no exact definition that makes such a distinction, but indicated that "a fiber must look like a fiber"; that is, have an aspect ratio of at least 50-to-l or 100-to-l, and not merely a 3-to-l aspect ratio in accordance with OSHA's definition of asbestos. In addition, MESA agrees with Vanderbilt's position that a distinction should be made between those particles which are truly fibers and those which are needle-like in shape (acicula particles). Dr. Goodwin said further that in all the talc samples they have analyzed, they have detected no asbestos fibers. This apparently supports their conclusion that tremolite, as it exists in commercial talc, is not fibrous. Dr. Goodwin is presently checking to determine whether or not MESA has examined J-M talc. If not, MESA is agreeable to examining J-M talc to determine if the tremolite it contains is or is not fibrous. CRMC-MAD-000318 Page 3 7 /16/74 Last week Bob Bacon, Assistant to the President o R. T. Vanderbilt Company, called me to report on a meeting he had on July 2, 1974, with John Stender, Alexander Reis, Howard Schulte and Dan Boyd of OSHA. Bacon reported that Stender was quite sympathetic to Vanderbilt's position and asked Reis: "Why are you holding these people hostage?" According to Bacon, Stender also told Reis that: "OSHA should;'t base standards on things not proven to be guilty." Bacon left the meeting quite optimistic that OSHA would modify' its definition of the term "asbestos." Bacon further noted that Dan Boyd, Chief of OSHA's Office of Standards, will visit Vanderbilt's talc mine in New York State on July' 19. It is uncertain at this time whether or not OSHA will modify its present definition of the word "asbestos", in accordance with Vanderbilt's position as was recently done by MESA. However, last week when Ed Fenner, as Chairman of AIA's Technical Committee, met with John O'Neill of OSHA, 0"Neill requested that AIA's Committee prepare a new definition of the term, "asbestos." Notwithstanding the recent action taken by EPA and MESA, Bill Reitze and I do not believe that OSHA will modify its present asbestos standard to conform to the recently pro mulgated MESA standard. Reitze spoke yesterday with Howard Schulte, Deputy Assistant Secretary for Occupational Safety & Health to check the result of Vanderbilt's meeting with OSHA. Schulte reported that Dan Boyd and someone from NIOSH in Salt Lake City, will visit Vanderbilt's mine this week and will take talc samples to determine if the tremolite present is fibrous or acicula. According to Schulte, even if the tremolite is found to be non-fibrous, OSHA is not planning to change its current asbestos standard with respect to tremolite. However, OSHA would grant Vanderbilt a variance from the OSHA asbestos standard and similar variances to other talc producers whose tremolite content is non-fibrous. However, Schulte told Reitze no decision with respect to Vanderbilt's request will be made until mid-August at the earliest. In the meantime, he cautioned that OSHA has cited and will continue to cite talc producers and their customers for violations of OSHA's asbestos standard. These recent developments raise a question as to whether J-M should begin to insert "warning" labels on its commercial talc packages. As I see it, three alternative courses of action are available to us. First, we can go ahead with our agreed upon label. Second, we could simply caution with respect to talc dust at the present time, until OSHA makes a decision with respect to tremolite. Third, we could take no action whatsoever until OSHA makes a decision. CRMC-MAD-000319 Page 4 7 /1 6 /7 4 I would suggest we very promptly call a meeting of the J-M personnel involved to review the current situation and make an interim or final decision. I hope this memo will be helpful as background material to be read by all attendees prior to that meeting. CRMC-MAD -000320 .***0 c^ ~*P UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON. D.C. 2^460 % 0 JUN 1973 Mr. Allen Harvey Patent and Legal Department R. T. Vanderbilt Co., Inc. 33 Winfield Street East Norwalk, Conn. 06855 Dear Mr. Harvey: This letter is in response to your inquiry as to the appli cability of the asbestos hazardous air pollutant standard to talc milling operations. "The proposed National Emission Standards for Hazardous Air Pollutants (NESHAPS) defined asbestos mill as a facility engaged in the conversion of asbestos ore into commercial asbestos. Since it has been determined that talc milling does not fit this definition, the asbestos standards do not apply to this operation. In addition, it has been determined that the asbestos standards do not apply to any manufacturing processes that use commercial dr industrial talc as an ingredient (unless asbestos as defined by AO CFR 61.21, with the above exception, is used in the process). It should be noted that 40 CFR 61, NESHAPS, will be amended in order to properly clarify this situation. Sincerely ,:y*. / Richard D. Wilson Director, Division of Stationary Source Enforcement CRMC-MAD-000321 R . T. VANDERBILT COMPANY, INC. 30 WINFIELD STREET NORWALK, CONNECTICUT 068 5 5 Mr. Marcel Cossette Q u e b e c A s b e s t o s M in in g A s s o c ia t io n University of Sherbrooke, P.Q. Sherbrooke, QUEBEC J1K 2R1 July 18, 1978 CABLE ADDRESS " BILTVAN** NORW ALK. C O N N E C T IC U T TWX 7 l 0 - * 0 '2 0 4 0 (203) 6 * 3 * 1 4 0 0 9ft Si M tv m r,'A, J} - .3 Dear Mr. Cossette: It has come to my attention that the requirement for caution labels as stated in paragraph 5.3.1. of the 12th draft of the ASTM E-34 Standard for Occupational Exposure to Asbestos is unworkable as written. The wording "caution labels should be affixed to all raw materials, mixtures, a scrap, waste, debris, and other products containing asbestos fibers, or to their *} containers," could be interpreted by the courts, in the absence of any qualifying minimum concentration of asbestos fibers in the product, to mean any concentration above zero. Such an interpretation was taken by the courts in the case GAF Corp oration v. OSAHRC and Dunlop (No. 76-1028) in relation to the OSHA asbestos standard requirements for medical exams for exposed employees. The court ruled that "con centrations of asbestos", as stated in the regul?vtion, meant any concentration of asbestos.above zero. : Obviously, a similar interpretation of "containing asbestos fibers" for pur poses of labeling, would mean that the asbestos warning label would be required on mineral product containers where the concentration of asbestos was in the parts per million range. The possibility that this might happen is supported by a recent finding, through Freedom of Information Requests, of a recommendation by the OSHA Solicitor's office that talcs containing any amount of asbestos be labeled with the official Asbestos Warning Label. It has been argued that the OSHA requirements for labeling products containing asbestos, which uses essentially the same language as the ASTM draft standard, might be interpreted to mean that only products containing sufficient asbestos "so that during any reasonably foreseeable use, handling, storage, disposal, processing, or transportation, no airborne concentrations of asbestos fibers in excess of the pre scribed exposure limits" be labeled. Naturally it would be unreasonable to believe that a product containing, for example, 0.1% asbestos could release more than 2 fibers/c.c. under normal conditions of use. But as long as the language of the standard remains vague or unspecific, the courts, in their efforts to favor the protection of the employee, might easily adopt an attitude similar to that applied in the GAF case. However, the GAF case points out the need for precise terms in regulations of importance to human life. Circuit Judge MacKinnon, in his concurring opinion in the GAF case criticizes the regulation: CRMC-MAD-000322 ThereccfT'notxidtcnr*bruseofcxrmatane* basedupontestsbele^edtobereliableHoweverwedonotguaranteetheresultstobeobtained R . T. V A N D E R B I L T C O M P A N Y , I N C . C.F.K. ,?19I0.1001(h)(1) and (2) (P"h). The prescribed standards in these regula tions were: "five fibers, longer than 5 micro meters. per cubic centimeter of air," and after July 7, 1976, "two fibers." These standards inform the nation's employers precisely what degree of exposure is per mitted and what exposure is excessive, but the regulation requiring medical examina tions is almost completely deficient in this respect. What number of fibers, of what length, per what volume of air will constitute a "concentration" is nowhere stated or even hinted at--and like the regulation, the court's opinion leaves the matter completely to conjecture. This is particularly unsettling Page 2 to law abiding citizens when the agency is dealing with tremendously minute quan tities of infinitesimally small particles. It makes compulsory' law enforcement diffi cult and it lessens the likelihood of volun tary compliance with the law, a result devoutly to be wished. The first requirement for uniform and voluntary compliance with the law is a clear understandable statement of what conduct is required and this regula tion falls woefully short of that minimal requirement. Regulations that have the great im portance that this regulation has to human life should be written in more precise terms--so people of ordinary understanding can determine what course of conduct is being required of them. What one person might consider to constitute a "concentra tion" will differ greatly from the interpre tation that another wouid give to that term; and what one person today might regard not to constitute a concentration" might be considered tomorrow, on the basis of hind sight as medical knowledge increases, to conic within that term.1 Xbelicve, however, that the Occupational Safety and Health Review Commission should clarify the regulation governing medical examinations so as to give other persons subject to the regulation reasonable notice of some measurable quantity of air borne asbestos the Commission intends to trigger the medical examination require-mcnl. Merely to state that all emplnvers must provide medical examinations when ever their employees arc exposed to "con centrations" of asbestos libers docs not provide an ascertainable standard for those who wish to comply with the law. For the above reasons we believe the language of paragraph 5.3.1. concerning caution labels should read: CRMC-MAD-000323 R.T. V A N D E R B I L T C O M P A N Y . I N C . Page 3 Caution labels should be affixed to all raw materials, mixtures, scrap, waste, debris, and other products containing more than 1 percent asbestos on a dry weight basis or to their containers, except that no label is required where asbestos fibers have been modifier' by a bonding agent, coating, binder, or other material so that during any reasonably foreseeable use, handling, storage, disposal, processing, or transportation, no airborne concentrations of asbestos fibers in excess of the exposure limits prescribed in 5.1 will be released. This is the same exclusion allowed in the EPA National Emission Standard for Asbestos (Federal Register 2.f 8829 April 6, 1973), for spraying, which reads: (e) Spraying: There shall be no visible emissions to the outside air from spray-on application of materials containing more than 1 percent asbestos, on a dry weight basis, used to isolate ......... Furthermore, the practice of setting exclusion levels for regulated materials has been followed by OSHA in the case of the 14 carcinogens (29CFR 1910.1003 through 1910.1016) wherein exclusion levels of 0.1 and 1.0 percent were allowed for various carcinogenic chemicals before the regulation applied, and more recently in the case of the OSHA benzene standard (29CFR 1910.1028) wherein there is no warning label requirement for mixtures containing 0.5 percent benzene (0.1 percent after June 27, 1981). The practice of choosing exclusion levels for regulated materials could be considered as an effort by OSHA and other regulating agencies to now recognize "feasibility" m the development of standards. It would not be feasible to analyze all silicate mineral mixtures for any asbestos content, yet a requirement to label talcs or any other silicate minerals assemblages such as pyrophyllite, kaolin, montmorillonite, etc. containing any asbestos would obligate the producers of many non-beneficiated mineral products to maintain an extremely costly program of trace analysis. In addition to feasibility, the agencies are also questioning the necessity of stringent regulation in areas such as label requirements. The exception to labeling in the OSHA standard for materials containing asbestos that has been modified with a binder, etc., is evidence of a recognition that only trace amount of asbestos will be released by the normal handling of these products. If only trace amounts of asbestos can be released from a non-modified mixture containing a low percentage of asbestos, then there is similarly no need to label or regulate the mixture. In a final consideration of the need to stipule*-" a concentration of asbestos in a mineral product mixture below which no warning laf . would be required the state of the art of asbestos detection .u.d counting should be recognized. Despite some published reports that concentrations of asbestos Lelow 1 percent can be detected with accuracy, it remains that the accurate identification and quantitative determina- CRMC-MAD-000324 R. T. V A N D E R B I L T C O M P A N Y , I N C . Page 4 tion of some of the amphibole varieties of asbestos in an unknown mixture is difficult below 5 percent and almost impossible below 2 percent by weight concentration. This coupled with the present unresolved controversy over the definition of an asbestos fiber favors the setting of a minimum asbestos concentration for purposes of labeling requirements in the ASTM draft standard for asbestos. I would be pleased to discuss this matter further at our next meeting of E-34 committee. Sincerely, R. T.. VANDERBILT COMPANY, INC. AMH:lsm Allan M. Harvey, Manager Technical Development Department CRMC-MAD-000325 3j l ! Johns-iVianviile Interna! Correspondence To: F. J. Solon, Jr. From: R. P. Carter Copies-. p i l e & c h r o n o Date: j u l y 1 6 f 1 9 7 4 Subject: T R E M 0L I T E A S B E S T O S Ever since August 12, 1972, when the Food & Drug Administration published a proposed regulation which would prohibit the use of talc containing asbestos in food and food packaging materials, R. T. Vanderbilt Company, a leading talc producer, has taken the position that the tremolite in their talc is not fibrous, but acicula (needle-like), and therefore cannot be con sidered "asbestos." Sid Speil, Bill Streib, Dick Lamar and other personnel from J-M, including myself, have attended meetings with Vanderbilt to explore their rationale for such a position. Our Research people have always taken the position that they cannot agree with Vanderbilt's approach, as tremolite is fibrous, but have wished them luck in convincing various ' government agencies on their position. Not only has Vanderbilt taken such an approach with FDA, but similarly through meetings, letters and petitions, with other government agencies -- all of this intended to convince them not to classify all tremolite as "asbestos." Thusfar, Vanderbilt has been successful with two government agencies, EPA and MESA. On May 3, 1974, EPA published an amendment to its April 6, 1973 National Emission Standard for Asbestos, wherein they added the term "commerical asbestos" to distinguish between asbestos that is produced as a product and asbestos that occurs as a contaminant ingredient in other materials. The purpose of adding the term "commercial asbestos" was to make it clear that materials that contain asbestos as a contaminant only, are not covered. In the May 3 amendment, EPA indicated that questions were raised concerning the applicability of the standard to manufacturing operations that used talc. EPA indicated that when their regulations were first proposed, talc mines were not covered by the EPA proposed standards ; this was also intended to indicate that manufacturing operations that used talc or other materials contaminated with asbestos were not covered by the standard. CRMC-MAD-000326 Page 2 7 /1 6 /7 4 In addition, the information available to EPA at the time of promulgation (April 6, 1973) did not demonstrate that the mining and milling of such materials were major sources of asbestos emissions. Therefore, such materials and manu facturing operations in which they are used are excluded from the EPA Asbestos Emissions Standard. On July 1, 1974, the US Department of the Interior (MESA) published an asbestos standard for metal and non-metallic open pit mines. In this standard, MESA distinguished between "tremolite asbestos" and "non-asbestiform tremolite." Tremolite asbestos, under MESA's standard, is covered by a five fiber per cc standard, whereas non-asbestiform tremolite is cohered by the ACGIH TLV for tremolite, 5 million particles per cubic foot. MESA, in the standard, indicated that nonasbestiform tremolite which occurs in talc deposits is not mentioned in the definition, therefore, it is not covered. Further, MESA pointed out that on May 8, 1973, a public symposium was held in Washington, D.C., to receive data on talc dust hazards in the metal and non-metallic mining industries. At that time, medical data based on both human and animal studies were presented, supporting the opinion that talc and talc-with-tremolite are not as hazardous as chrysotile and other true asbestos minerals. I spoke this week with Dr. Aurel Goodwin, Chief of Health Standards for MESA, to ascertain how MESA distinguishes between "tremolite asbestos" and "non-asbestiform tremolite." Dr. Goodwin said that MESA has no exact definition that makes such a distinction, but indicated that "a fiber must look like a fiber"; that is, have an aspect ratio of at least 50-to-l or 100-to-l, and not merely a 3-to-l aspect ratio in accordance with OSHA's definition of asbestos. In addition, MESA agrees with Vanderbilt's position that a distinction should be made between those particles which are truly fibers and those which are needle-like in shape (acicula particles). Dr. Goodwin said further that in all the talc samples they have analyzed, they have detected no asbestos fibers. This apparently supports their conclusion that tremolite, as it exists in commercial talc, is not fibrous. Dr. Goodwin is presently checking to determine whether or not M ESA has examined J-M talc. If not, M ESA is agreeable to examining J-M talc to determine if the tremolite it contains is or is not fibrous. CRMC-MAD-000327 Page 3 7 /1 6 /7 4 Last week Bob Bacon, Assistant to the President of R. T. Vanderbilt Company, called me to report on a meeting he had on July 2, 1974, with John Ste n d e r , Alexander Reis, Howard Schulte and Dan Boyd of OSHA. Bacon reported that Sounder was quite sympathetic to Vanderbilt's position and asked Reis: "Why are you holding these people hostage?" According to Bacon, Stender also told Reis that: "OSHA s h ouldn't base standards on things not proven to be guilty." Bacon left the meeting quite optimistic that OSHA would modify its definition of the term "asbestos." Bacon further noted that Dan Boyd, Chief of OSHA's Office of Standards, will visit Vanderbilt's talc mine in New York State on July 19. It is uncertain at this time whether or not OSHA will modify its present definition of the word "asbestos", in accordance with Vanderbilt's position as was recently done by MESA. However, last week when Ed Fenner, as Chairman of AIA's Technical Committee, met with John O'Neill of OSHA, 0"Neill requested that AIA's Committee prepare a new definition of the term, "asbestos." Notwithstanding the recent action taken by EPA and MESA, Bill Reitze and I do not believe that OSHA will modify its present asbestos standard to conform to the recently pro mulgated MESA standard. Reitze spoke yesterday with Howard Schulte, Deputy Assistant Secretary for Occupational Safety & Health to check the result of Vanderbilt's meeting with OSHA. Schulte reported that Dan Boyd and someone from NIOSH in Salt Lake City, will visit Vanderbilt's mine this week and will take talc samples to determine if the tremolite present is fibrous or acicula. According to Schulte, even if the tremolite is found to be non-fi b r o u s , OSHA is not planning to change its current asbestos standard with respect to tremolite. However, OSHA would grant Vanderbilt a variance from the OSHA asbestos standard and similar variances to other talc producers whose tremolite content is non-fibrous. However, Schulte told Reitze no decision with respect to Vanderbilt's request will be made until mid-August at the earliest. In the meantime, he cautioned that OSHA has cited and will continue to cite talc producers and their customers for violations of OSHA's asbestos standard. These recent developments raise a question as to whether J-M should begin to insert "warning" labels on its commercial talc packages. As I see it, three alternative courses of action are available to us. First, we can go ahead with our agreed upon label. Second, we could simply caution with respect to talc O dust at the present time, until OSHA makes a decision wiuh respect to tremolite. T h i r d , we would take no action whatsoever until OSHA makes a decision. Page 4 7 /1 6 /7 4 I would suggest we very promptly call a meeting of the J-M personnel involved to review the current situation and make an interim or final decision. I hope this memo will be helpful as background material to be read by all attendees prior to that meeting. CRMC-MAD-000329 't.J j CRMC-MAD-000330 Johns-Manville Internal Correspondence To: F. J. Solon, Jr. Date: Oct. 31, 1974 From: R. P. Carter Copies: File J & c Subject: TELEPHONE CONVERSATION WITH BOB BACON Bob Bacon, Assistant to the President, R. T. Vanderbilt Co., called me this morning to advise that our talc labeling decision is causing a "big stink". Vanderbilt's talc customers are very concerned as to why J-M has decided to commence inserting asbestos caution labels on all packages of talc. R. T. Vanderbilt Co. is of the opinion that it is Johns-Manville's intention to hurt their company. Bob Bacon requested that I bring this matter to the highest level of management within J-M and indicate that Vanderbilt is "very, very upset" with our labeling decision, which they feel will result in "irreparable damage" to them. Bob Bacon indicated that he is going to request Hugh Vanderbilt to personally call a Senior Officer at Johns-Manville to voice their concern. It has been obvious for some time from my conversations with Bob Bacon that Vanderbilt is very concerned about our talc labeling decision. Without attempting to characterize the motivating factors behind Bob Bacon's frequent telephone conversations to me, their concern may very well be based on a distinct difference between their "corporate conscience" and ours. Certainly, our decision in no way reflects any intention on J-M's part to hurt or destroy Vanderbilt, which is Vanderbilt's current feeling. It is Vanderbilt's opinion that based on John Stender's letter of October 9, 1974, to Hugh Vanderbilt, their talc does not contain asbestiform minerals such as fibrous tremolite. Perhaps that is true, and it is even possible that our talc does not contain asbestiform minerals based on the definition contained in Stender's letter. Basically, Vanderbilt is requesting, if not demanding, that J-M reverse its talc labeling decision based on Stender's letter. As you will recall, I recommended several weeks ago that we promptly take the following actions in the sequence listed b e l o w :1 (1) Reconvene a meeting o! the talc labeling group which met early this past Summer to review R&D's analyses of Vanderbilt's Nytal and to determine J-M policy and action in response to Stender's October 9 letter. F. J. Solon, Jr. Page 2 Oct. 31, 1974 (2) Arrange a meeting in Denver between certain R. T. Vanderbilt personnel and appropriate individuals from R&D to review our analyses of Nytal and to inform Vanderbilt officially as to J-M policy and contemplated actions on this matter. (3) Meet with Jon May and perhaps other NIOSH personnel to review the details of their study of tremolitic talc and their recommendations to OSHA, which I have been told were incorporated in Stender's letter. (4) Arrange for a meeting with OSHA, including Alexander Reis, Dan Boyd and Howard Schulte,to discuss the talc labeling situation, and perhaps point out the error in Stender's definition of "fibrous, asbestiform minerals". I believe this matter warrants our immediate attention. R. P. Carter RPC/emr CRMC-MAD-000331 Johns-Manville Interna! Correspondence To: F. J. Solon, Jr. Date: August 21, 1974 From: R. P . Carter Copies: E. M. Fenner File & C Subject: CLASSIFICATION OF TREMOLITE UNDER OSHA ASBESTOS STANDARD CONVERSATION WITH BOB BACON ON AUGUST 19 Bob Bacon of R. T. Vanderbilt Co. called me on August 19 to advise me that he received a letter last week from John Stender which contained OSHA's opinion as to the applicability of the Asbestos Standard to talc. Bob read Stender's letter to me over the telephone and indicated that he would immediately send a copy to me air mail. Stender basically stated in his letter that OSHA's Asbestos Standard applied only to fibrous minerals and talc containing non-asbestiform tremolite is not covered within the Standard. Fibers must conform to the definition contained within OSHA's Asbestos Standard to be included therein. Bob Bacon acted as if he had achieved a victory from OSHA, but the preliminary data we have received from Research concerning our evaluation of their talc, would indicate contrary. However, Vanderbilt is relying on their own conclusion that the tremolite contained in their talc is "non-fibrous". / As you may be aware, R. T. Vanderbilt recently bought international Talc. Bob Bacon indicated that one portion of an International Talc deposit contains a considerable amount of fibrous chrysotile and anthophyllite, in addition to containing a minerological phenomenon, fibrous talc. In view of this finding, Vanderbilt intends sometime in the future to insert an asbestos warning label on talc mined from this portion of that particular deposit. However, they have no present intention of labeling any (N cn other talc. m o o o Based on the letter which Vanderbilt received from John Stender, it would be my recommendation that we reconvene another meeting with those individuals who attended the talc labeling meeting on July 24, and recommend that we promptly advise our customers of our intention to label talc and to proceed with such labeling. O F. J. Solon, Jr. Page 2 August 21, 1974 Naturally, we should first carefully review Stender*s letter as soon as we receive a copy. It would also be my recommendation that prior to our institution of asbestos warning labels on talc, we should present Vanderbilt with the results of our analysis of their talc and urge them to consider applying a similar label. In view of the above developments, I see no reason for us to schedule a special meeting with OSHA as was discussed at the July 24 talc labeling meeting. R. P. Carter CRMC-MAD-000333 7 joa'fis-itoanvn;ii,r\ U xtaW LiX .C-x 'xJ'O'ii iW O j j W W J U--- R. S. Lamar- - R&D V. E. Wolkodoff - R&D Date: October 23, 197*+ Distribution on Reverse Side SELECTED AREA DIFFRACTION PATTERNS OF ASBESTOS MINERALS IN FOUR 'LES PRODUCED BY R. T. VANDERBILT COMPANY 1. At your request, I was able to contract time on the Philips 200 electron microscope at Denver Research Institute to confirm by selected, area diffraction patterns, the presence of chrysotile, anthophyllite and tremolite in all the R. T. Vanderbilt talcs designated Nytal 200, Nytal 1+00, Asbestine 3X, and Asbestine 325X (please refer to my letter of October 9, 197*+, which is based basically on FDA optical methods and the use of our RCA electron microscopes to confirm chrysotile). It was felt that selected area diffraction patterns of the asbestos minerals using the Philips 200 would lend positive identification - a type of analysis which cannot be done on our RCA EMU-3B model. 2. Table No. 1 not only identifies samples, but also identifies all TEM prints and selected area diffraction patterns of the 33 prints attached to this letter. The TEM plates are always on file. The microscope constant (L A) was derived by averaging 21 microscope constant values based on lines of Au and ,Pd. The microscope constant is: L A = lt.l*51 A cm i 0.003 To calculate d-spacing in Angstrom units, the following formula was used: L A (A cm) = d-spacing (A) spot pair radius (cm) 3- Chrysotile, anthophyllite, and tremolite were all found in each o:' the four R. T. Vanderbilt talc samples. Particular data for each sample are found in Table No. 1 and appropriate attached electron diffraction patterns. ? .. i d r i k c i i j J - ' V. E. Wolkodoff t w u iicruncntis NOTEBOOK pp. 03-81 CRMC-MAD-000334 rIj*.V'/1i ohns-ll'lanville tUhji t f j j internal Correspondence t To: Filtration and Minerals Environmental Committee Members* From: Harry R. Keefe Date: July 17, 1974 Copies: Listed Below Subject: Talc Labeling *E. M. Fenner R. P. Carter W. A. Cooper D. E. Hillier T. M. Jackson R. tv. Kclndoe W. B. Reitze S. W. Schulmeyer F. J. Solon, Jr. W. C. Streib A. Finkbinder P. Kotin, M.D. G. Swallow R. S. Lamar E. Parker Re my i q -h - q v r>f , i Q 7 A j r n x r - i r-w of the recent develop- ment>i^$tifTrr_T^ VanderBlTrtr-d^lSesa7~^ix^ormation published in the Federal Register of July 1, 1^7^T~~th^lse appears to be some confusion as to,.the definition of trepolite in talc as ari asbestos fiber. After discussionsjaiitn E. Fenner and R. Ca^ter^ i t is the decisioii_-o--fehe~''FiItration and Minerals Division~to noid xn abeyance our labeling plans for talc until an emergency meeting of the Filtration and Minerals Environ mental Committee is held. F. Scion is requested to call such a meeting to determine the significance of the above mentioned published information. cc: C. J. Sulewski W. L. VanDerbeek P. A. Martinson H. Kranich N. B. Scheffel G . Coombs R. G. Riede K. R. Comann D/C CRMC-MAD-000335 f -* *! <v",',>> 1' ''-VX 23 < second? MR. HULCE: I second the motion. THE PRESIDENT: Are there any questions? MRS. DAVIS: First of all, on the subject of the legal fees, which is in my resolution I want to ask the auditors what they are doing to check the legal fees ar , to see that all those are ordinary and necessary expenses and what they are doing to check 11 kickbacks, if any, to the general counsel and corporate 12 secretary and what was the total amount of legal fees. THE PRESIDENT! The total amount of legal fees was $1,101,322 to outside attorneys. Internal expenses were $571,398. MRS. DAVIS: T h a t 's for house counsel. I want to bring to the attention of the stockholders too that President Carter denounced the lawyers today in a speech, and this I 'm sure everyone has seen in the Wall Street Journal and the Boston Globe, and a lot of these expenses are not ordinary. Here I read one sentence by Curtis Wilkie of the Boston Globe Bureau in Washington: "President Carter scolded the legal profession for long, high fees, elitism and opposition to change" etcetera, so it shows CRMC-MAD-000336 that President Carter agrees with that. He has seen some of my resolutions and he got some of his ideas from Evelyn Davis. After all, people say something like we won't make it to Broadway. I was recognized ;is an editor by the President. Some people can not even go to the ladies room in the White House. I'm asking for the accountant. I'm asking and want to know what they are doing to check these legal fees, and that they are ordinary and necessary. I want to know from them what they are doing about it. FROM THE FLOOR: We examine legal fees in the same manner that we examine other expenses of the corporation. Basically, those procedures would be reviewing legal disbursements to determine the nature of them and also discussing them with legal counsel in the company. MRS. DAVIS: On the subject of political contributions, and we do have some ex-politi~ clans or politicians like Governor Love and Mr. Zwick and the gentleman from Canada was also in politics, how Is It now with political contributions? THE PRESIDENT: I'll answer that we made contributions in Canada of $3,650. CRMC- 25 MRS. DAVIS: What about Colorado? What about the State of Massachusetts? Any? THE PRESIDENT: No. MRS. DAVIS: Have you been supporting Dukakis, Senator Mogan and Kennedy and Tip O 'Neil? THE PRESIDENT: The only political contribution made by the corporation or any of the subsidiaries was the $3,650 contributed In Canada. MRS. DAVIS: Do we have a so-called pact,a political axe committee,and what are the auditors doing to check that? THE PRESIDENT: We do have one. MRS. DAVIS: How much is that? $8, 500, THE PRESIDENT: Well, we collected MRS. DAVIS: Who were some of the candidates? Did any of them go to Massachusetts? THE PRESIDENT: We have not yet distributed it so far as I know, but the rules of the pact, which isn't called pact anymore-- we have another name for it but under those rules the contributions must be made to candidates or potential candidates who support the free enterprise system. CRMC-MAD MRS. DAVIS: Well, some do part of the time. We could say Tip O'Neil and Senator Kennedy and Senator Brooke are supporting the free enterprise system. THE PRESIDENT: I don't think we have contributed to them. MRS. DAVIS: I see. You may not be able to have a lot of eating in Massachusetts. Who knows? I have one more point on charitable contributions. What are the auditors doing to audit those, that they really go to charities and that they aren't political contributions? What was the total amount? THE PRESIDENT: I can give you the total amount on the charitable contributions and the auditors can answer the rest of it. In 1977 we contributed a total of $570,000. MRS. DAVIS: How much of that went to charities, which officers and directors were connected with? THE PRESIDENT: I don't think I can give it to you that way. The data doesn't show it that way. CRMC-M A D -0 0 0 3 39 Johns-Manville '? - ..." Internal Correspondence To: See below* From-. Paul Kotin, M.D. , 4N Copies: Subject: f . J. Solon, Jr. R. Carter TALC LABELING Date: November 7, 1974 NOV 8 *w. R. Goodwin, 5W F. II. May, Jr., 5W J. A. McKinney, 5W L. Pundsack, R&D c. J. Sulewski, 2W w. L. VanDerbeek, 2S We have been informed by Mr. 'Robert Bacon, Assistant to the President of H. T. Vanderbilt Company (a major talc competitor) that J-M's decision to insert asbestos caution labels on all talc shipments will result in "irreparable damage" to Vanderbilt. Mr. Bacon requested that this matter be brought to the attention of the highest level of management, and he stated that he was asking Mr. Hugh Vanderbilt, President of R. T. Vanderbilt, to call a senior officer at J-M to voice their concern and their belief that it is J-M's intention to hurt their company. The purpose of this memorandum is to alert you to the situation in the event you are contacted by Mr. Vanderbilt. Our decision to label talc was based on our conviction that J-M's talc contains fibrous asbestos and in no way reflects any intention to hurt or destroy the Vanderbilt Company. If you would like additional details on this matter, please call me. CRjVfC-M A D 000340 Eh Eh )-;VianvG I. W' ' H. G. Lamar- - h&D V. G. Woikodoff - R&D Diil,' October 23, 197^ Distribution on Reverse Side fm and selected area diffraction patterns of asbestos minerals in four ALC SAMPLES PRODUCED BY R. T. VANDERBILT COMPANY At your request, I was able to contract time on the Philips 200 electron microscope at Denver Research Institute to confirm by selected area diffraction patterns, the presence of chrysotile, anthophyllite and tremolite in all the R. T. Vanderbilt talcs designated Nytal 200, Nytal LOO, Asbestine 3X, and Asbestine 325X (please refer to my letter of October 9, 197**, which is based basically on FDA optical methods and the use of our RCA electron microscopes to confirm chrysotile). It was felt that selected area diffraction patterns of the asbestos minerals using the Philips 200 would lend positive identification - a type of analysis which cannot be done on our RCA EMU-3B model. Table No. 1 not only identifies samples, but also identifies all TEM prints and selected area diffraction patterns of the 33 prints attached to this letter. The TEM plates are always on file. The microscope constant (L A) was derived by averaging 21 microscope constant values based on lines of Au and Pd. The microscope constant is: LA = U 5 1 1 cm 0.003 To calculate d-spacing in Angstrom units, the following formula was used: -- ----L:-A---(A-r-.-c-m)S -- r = d,-spaci.ng (A)\ spot pair radius (cm; Chrysotile, anthophyllite, and tremolite were all found in each oi the four R. T. Vanderbilt talc samples. Particular data for each sample are found in Table No. 1 and appropriate attached electron diffraction patterns. luriMiU / -/: Wolkodoff ,jc Attachments NO'-'PBOOK 1*1*51, pp. 02-8U CRMC-MAD-000341 Distribution : R. P. C a r t e r * - UN E. M. F e n n e r - UN Paul Kotin, M.D. W. B. R e i t z e - UN - UN F. J. S o l o n , Jr. - UN G . L . Swallow - UN A. C. F. F i n k b i n e r , I II 5W J. A. M c K i n n e y 5W H. R. K e e f e * 2W P. A. M a r t i n s o n - 2W C. J. S u l e w s k i - 2W W. L. V a n D e r b e e k - 2S R. G. R i e d e " 2 S ' F. L. P u n d s a c k J, P. L e i n e w e b e r * W. C. S t r e i b S. S p e i l * R. S. L a m a r * V, E. W o l k o d o f f * *Prints attached only to those names followed by asterisk CRMC-MAD-000342 TABLE 1 TEM Tabulation of Micrographs and Selected Area Diffraction Patterns of Four Talc Samples From R. T. Vanderbilt Co. Vanderbilt :;o. LikO. No Designation a: 71.2 5 5 - 1 Nytal 200 ec 7`255-1 Hytal 200 s EC 7-255-1 Nytal 200 * EC 71255-1 Nytal 200 TEM Plate No., Magnification 2301A, 11.000X 2317A, l6,000X 2305A, 22.000X s ;c 71255-1 Nytal 200 o nC 7^2^ -1 nvj.r.*,oc,,x-->l. nt-nwn 7 E2 71255-1 Nytal 2-0 n r,C 7-255-1 Nytal 200 U 7*.255-2 Nytal lOO . o 71255-2 Nytal lOO 71255-2 Nytal lOO - r.C 7-255-2 Nytal lOO EC 71255-2 Nyxal lOO EC 71.2 5 5 - 2 Nytal lOO ;v ,-,2 71255-2 Nytal lOO u. lui 71255-2 Nytal lOO 2306a , 22.000X " 2307A, 22.000X " 2302D, 11.000X 2 3 1 8 c, l6,000X 2308A, 22.000X " 2309A, 22 ,000X - 2310A, 22 ,000X 17 7 1 2 5 5 - 3 Asbestine 3X 2303D, 11.000X .-i: 7-255-3 Asbestine 3X 2319D, 16.000X ' .2; 71255-3 Asbestine 3X 2311A, 22,000X ' - M ' 7-255-3 Asbestine 3X - 71255-3 Asbestine 3X 7 1 2 5 5 - 3 Asbestine 3X 2312A, 22 ,000X ' '.'1255-3 Asbestine 3X 2313A, 22.000X * ... '.'1255-3 Asbestine 3X -- : ''1255-1 Asbestine 325 230lA, 11,000X 1 7-25 5-1 Asbestine 325 2322A, l6,000X Selected Area Diffraction Pattern, 35X 2305B ?3o 6b 2307B - 2308b 2309B 2310B - 2311B 2312B 2313B - Remarks _ Chrysotile fiber Pattern is of vide: fiber in 2305A, Chrysotile Anthophyllitc fibre Anthophyllite fiber in 2 ,06A Tremolite fiber Tremolite fib< r ir. 2307A " Chrysotile fiber Pattern of Cnrysot above Anthophylli t<- .'ibe Pattern of Ar.tnopE; above Tremolite fiber Pattern of Tr..:,.c..iJ above " Chrysotile f;n:r 0 bottom Pattern of CEr.vrc.'. above Anthophyllite fib. Pattern of An1..-'> above Tremolite fii. Pattern of Vr. me ; above - Fiber is coir.i:.;7on tile and Amphibcle CRMC-MAD-000343 Vanderbilt TEM Plate No. ..ns No. Designation No., Magnification o Asbestine 325 - C\i co 55-!* Asbestine 325 231^A, 22.000X 55-1* Asbestine 325 C Y't255-^ Asbestine 325 2315A, 22.000X ni; YU255-U Asbestine 325 :iC Asbestine 325 2316A, 22.00X ;-,d Y't255-A Asbestine 325 Selected Area Diffraction Pattern, 35X 2322B 231 **B 2315B 2316b Remarks Chrysotile pattern superimposed on Amphibole pattern Chrysotile fiber Pattern of Chrysotile above Longest fiber is Anthophyllite Pattern of Ar.t.hcvphy'.1it' above Largest fiber is Tremolite Pattern of Tremolite above C R M C -M A D-000344 J u h n s -IV ia n v iiie i j & t ,_Cw isir*LC>s i V. E. Wolkodoff o.-t.nOctober 11, 1974 R. S. Lamar See end of correspondence YOUR MEMO OF OCTOBER 9, 1974 OPTICAL AND TEM COUNTING OF ASBESTOS MINERALS IN ASBESTINE 3X, ASBESTINE 325, NYTAL 200, AND NYTAL 400 AS CURRENTLY PRODUCED BY R. T. VANDERBILT CO. Thank you Vlad for your very fine report covering your microscopic examination of these samples. Your data confirm analyses we have had made on these same samples by J. P. McGourty using X-ray diffraction techniques (Report No. 414-T-33) and by K. Jaunarajs using differen tial thermal analysis - primarily for the detection of serpentine mineral. These present samples are really no different from previous samples of Nytal and Asbestine that I have examined periodically over the.years. They all contain very sub stantial amounts of both tremolite and chrysotile and in two cases substantial amounts of a third asbestos mineral, anthophyllite. In numerous discussions I have had with R. T. Vanderbilt people, they have readily admitted to having tremolite ("which is not an asbestos mineral and is not fibrous"), but they have never admitted to the presence of either chrysotile or anthophyllite. They do admit that years ago, when they were deliberately mining certain sections of their deposits for fiber, some of their products did contain chrysotile. This product, "Mouldene," was sold as a direct replacement for asbestos in the manufacture of vinyl tile. I have examined "Mouldene" in the past and it was in fact almost entirely chrysotile. "Mouldene" is no longer being made, but all of the International Talc Company and R. T. Vanderbilt Company talc products always have and continue to contain chrysotile as a significant mineral component (in addition to tremolite and anthophyllite). CRMC-MAD-000345 v . K. W o l k o d o l f -2- O u t o b o r .11, 1H7 4 It is apparent that tho ft. T, Vanderbilt. proflon t;aL1on to OS11A, NIOSll, PDA, MESA, etc. avo baited on Bomothing loan than tho truth. I find it difficult to believe that they could bo so grossly misinformed as to wlmt thoir materials really are. How this information is ultimately used in someth I . . h a t will have to bo docidad at higher levels within J-M. However, it is my boliof that H. T. Vanderbilt, wi th a continuance of thair present methods, does nothing but confuse the .issue among tho talc producers ami with the various Federal agencies involved. Any properly inton\ed person would know that they aro wrong. R. S. Lamar kjm cc : R. P. Carter E. M. Fenner P. Kotin W. B. Reitze F. J. Solon, Jr. G. L. Swallow A. C. F. Finkbiner, J. A. McKinney H. R. Keefe P. A. Martinson C. J. Sulewski W. L. VanDerbeek R. G. Riede - 4N - 4N - 4N - 4N - 4N - 4N Ill - 5W - 5W - 2W - 2W - 2W - 2S - 2S File 414-C R. T. Vanderbilt F. L. i'undsack W. C. Stroib J. P. Leinoweber S. Spoil A. J. McArthur CRMC-MAD-000346 v'ohns-Manville A } < / >!> > / 7 3 Internal Correspondence To F. L. PundsacK - R&D Center Date: August 28, 19 73 From: s. Soeil - R&D Center $0 Subject: TREMOLITE IN TALC You asked that I review the background for our decision not to support Vanderbilt's claim that "tremolite is not asbe '-.os". I need not dwell on the technical reasons involved since you are well acquainted with these. However, to summarize briefly, tremolite is an amphibole mineral differing from amosite, crocidolite, and other amphiboles only in the substitution of calcium for part of the magnesium, iron, and/or sodium present in the internal structure of other amphiboles. Fibers of tremolite and actinolite are generally much shorter and usually more brittle than those of croci dolite and amosite and, therefore, find little commercial utility as a reinforcing agent. From a scientific stand point, any tremolite particles which are fiber-form must be categorized as asbestos since all fibrous amphiboles are included in this definition. The first indication of J-M's stand on tremolite as an as bestos mineral is included in the minutes of a meeting of Celite and Environmental personnel held on October 2, 1972 (see Attachment A ) . The conclusions of this meeting regarding reclassification of tremolite is summarized on page 5 and includes the following statements: "E. M. Fenner expressed firm opinion that we haven't got a prayer concerning establishing a variance or amendment to the OSHA regulation with respect to tremolite"......... "Fur thermore, E. M. Fenner and H. M. Jackson report that amosite and crocidolite have proven causative to mesothelioma. Both these materials have a 'fibrous' nature that is similar to tremolite. The electron micrographs exhibited in a symposium of papers presented to the Canadian Institute of Mining and Metallurgy and reprinted by the Quebec Asbestos Mining Asso ciation '1958' exhibit this characteristic on pages 21-23 comparing amosite, crocidolite, and tremolite. Thus, H. M. Jackson expressed the opinion that an attack on 'fibers' delineated from tremolite would be a long-term study. Tre molite was not separately identified in the OSHA hearing, so evidence would have to be developed to disclaim tremolite functioning as an asbestos mineral. There appears to be no CRMC-MAD-000347 -2- . L. P u n d sack A ugust 28, 1973 area of attack by reclassification of treraolito through mineralogical or structural definition. Any approach to disassociation will require medical evidence." Although no Research representatives were present at this meeting, I heartily agree with the conclusions of the group. On January 11, 1973, S. Speil, R. S. Lamar, N. B. Sheffe^, and E. L. Smith were given a presentation at the New York offices of R. T. Vanderbilt of the story put together by Mr. C. S. Smith, Vanderbilt geologist, to "prove" that tremolite, especially that present in the Vanderbilt Company New York State talc, was not asbestos. Unfortunately, this presentation gave no technical evidence to support Vanderbilt's position. The photomicrographs showed that the particles of tremolite were, indeed, much shorter than chrysotile fibers and did have an aspect ratio (L/D) less than that of crocidolite and amosite used commercially. However, the L/D for many particles was definitely over 3 (the present limit esta blished by ACGIH and accepted by OSHA) and, therefore, they would be included in the category of "fibers". Many of these particles had L/D's greater than 10. It is conceivable that the presentation would have an impact on the layman, but assuredly not on any person having technical competence in the field of asbestos or asbestos regulation, The presentation relied heavily on layman-type definitions of a "fiber" from various encyclopedias and a list of asbestos minerals proposed by Mr. Thompson which he indicated came from THE FEDERAL REGISTER and which included tremolite and actinolite as non-fibrous varieties. This information is in cluded as Attachment B. In the amphibole field, amosite and crocidolite fibers have their non-fibrous counterparts with specific terminology-cummingtonite and riebeckite, respectively. Normally, anthophyllite, tremolite, and actinolite are used to include any occurrence of these amphiboles whether fibrous or non-fibrous. At this meeting I indicated that J-M could not support techni cally Vanderbilt's position. Mr. Harvey stated that the Talc Producers had scheduled a meeting in early February to develop new definitions of asbestos, talc, and commercial talc which they would propose for acceptance by an ASTM Subcommittee on Paints and Pigments. Once accepted, this would serve as a springboard to foster approval by Government-regulating agen cies. I pointed out that definitions for asbestos and for the term "fiber" already existed under the auspices of other .ASTM groups and agreed to supply this information, as well as CRM C-M A D-000348 -3- L. P u n d s a c k August 28, 1973 to participate in the February 5 meeting on definitions. Subsequently, I sent to Mr. Thompson copies of the defi nitions relating to "asbestos fiber" under ASTM D2946-71T in which fiber was defined with a L/D of 10:1 as well as the definition of fiber for textile purposes under ASTM Committee D123 in which an L/D of at least 100 was speci fied. These are included as Attachment C. At the February 5 meeting none of the attendees from other talc producers concurred with the Vanderbilt proposal that tremolite was not asbestos. During the discussion I empha sized: 1 . that one of the major items requiring action was to secure elimination of the ACGIH definition "talc (fibrous)Tremolite" and the concomitant 5 fibers/cc TLV established by the ACGIH; 2 . that tremolite particles could be classed as non-fibrous or fibrous depending upon the L/D ratio for each indi vidual particle and that the thrust here should be to attempt to establish a higher L/D than the 3:1 currently accepted. Because time was of the essence, I suggested that we propose the 10:1 ratio of ASTM Designation D2946-71T; 3. that we not try to redefine asbestos to specifically ex clude tremolite since assuredly this could only lead to a long-term technical and scientific debate; 4. that any presentation to the FDA or to the Bureau of Mines Symposium which had been arranged at Vanderbilt's behest should concentrate on the medical evidence regarding the difference in biological effect of tremolite and other amphibole fibers; and, 5. that we propose a single definition of commercial talc which would include all types of talc and, therefore, eliminate the need for differentiating between "pure" talc and talc (fibrous)-Tremolite as defined by the ACGIH. In general these recommendations were adopted by the group and the following definition proposed by me was tentatively accepted for presentation to the Talc Producers Association: 'Industrial talc is a product varyingq in mineral composition from the mineral talc jfMg6 (Si80?Q) (OH)4j to mixtures of mineral talc and other naturally assod a t e d non-fibrous and/or fibrous minerals as defined by ASTM Designation D2946-71." CRMC-MAD-000349 r. i,. hunduaek August 28, 1973 Acceptance of this definition would automatically infer a change of the L/D of a fiber to 10:1 and eliminate many tremolite particles from the "fiber" category and, there fore, from the asbestos category. However, a considerable percentage of the tremolite particles would still be classed as "asbestos fiber". Although ASTM would probable accept this definition of talc, I frankly doubt whether ^ i/ernment agencies would. Subsequent to this meeting, R. S. Lamar on January 31, 1973, proposed to P. A. Martinson that we issue a letter giving our position to our customers and the industry, and stating that tremolite is an asbestos mineral. 1 commented at length on this letter on February 14 (see Attachment D) recommending that we not send out such a letter. The major thrust of my comment was addressed to the point that tremolite can be either fibrous or non-fibrous, i.e., either asbestos or not depending on the shape of each individual particle and that we should not categorically state that all tremolite was indeed asbestos. (Incidentally, some of my much earlier comments might be inter preted as indicating that all tremolite was asbestos.) Since that time I have had essentially no contact with the tremolite in talc situation which has been Bill Streib's responsibility. My understanding is that at the Bureau of Mines Seminar in May 1973 the J-M presentation was restricted primarily to medical aspects, differentiating between the effects of tremolite and other asbestos fibers. I also under stand that the Vanderbilt presentation included the same story which was given to us in January, to "prove that tremolite was not asbestos", but possibly modified somewhat in the light of our discussions. In July 1973 Vanderbilt through their attorneys petitioned OSHA to modify asbestos standards promulgated pursuant to the OSHA Act. This is presented in Attachment E. I am entirely in accord with their petition to replace the word "tremolite" by "asbestiform tremolite" to distinguish this from the nonfibrous (by definition) forms of tremolite. In this way nonasbestiform tremolite and talc would be subject to the "mineral dust standard" and asbestiform tremolite would continue to be subject to the "asbestos standard". Their proposal summarized in Appendix I of Attachment E is based on the February 5 meeting previously referred to and, there fore, is entirely acceptable although personally I see no possibility of Government agencies changing the L/D definition of a fiber from 3:1 to 1 0 : 1 except by the presentation of CRMC-MAD-000350 -5- -. L . Pundsack August 28, 1973 valid medical evidence to support such a change. Some of the work that the QAMA is supporting at Fairleigh Dickenson and the work being done by Stanton on sized fibers prepared by us might serve as the basis for requesting such a proposed change which would, undoubtedly, be opposed by Selikoff on the basis of the limited data available. Incidentally, I have been told thirdhand that Vanderbilt secured concurrence of their original proposal to eliminate trcmoiito as an asbestos mineral from Governmental regula tions (EPA) and that this is supported by Appendices 9 and 10 of Attachment E. A close reading of these letters from EPA indicates the presence of "weasel words" since they both include the statement "the standard is applicable, however, to paint and coatings manufacturing when asbestos as defined by 40 CFR 61.20, with the above exception, is used in the manufacturing process". Tremolite is included as an asbestos mineral in 40 CFR 61, and even though both letters state that 40 CFR 61, National Emis sion Standards for Hazardous Air Pollutants, will be amended in order to properly clarify this situation, neither letter indicates that tremolite will be removed from the definition of 40 CFR 61.21, It is hard to understand how industrial talc, some of which contains 50 per cent or more of tremolite, can be specifically excluded merely by calling this material talc (containing tremolite) rather than calling it tremolite (con taining talc). A copy of the applicable portions of the National Emission Standards for Hazardous Air Pollutants for asbestos is in cluded as Attachment F. In the J-M "crisis" meeting on August 24, 1973, to discuss the FDA decision to issue proposed standards on food grade talc which presumably would also include talc used in paper for wrapping foods, R. P. Carter stated that he had been told by FDA middle-management personnel responsible for preparing the regulations that they were in favor of issuing an interim regulation which would continue the status quo for at least 2 to 3 years while technical and medical evidence were being accumulated to insure a fair and reasonable set of regulations. However, they had been instructed instead by their superior, the new Commissioner of FDA, to prepare proposed regulations restricting the use of talc-containing asbestiform minerals for immediate publication. Carter was told that the entire technical and medical evidence presented by J-M and other industrial petitioners was completely ignored in this decision which was motivated by po)itical pressure from the Environmen tal Defense Fund and other groups. CRMC-MAD-000351 F. L. Pundsack A ugust 28, 1973 Finally, to complete the record, I am attaching a copy of mv letter of August 9, 1971, to F. D. Richards (Attachment 6) pointing out the possibility of future difficulties with FD hofnrp we ourchased Grantham Talc. s. SPIL SS/rs Attachments A through G 4 * s CRMC-MAD-000352 'etition to Modify 29 CPR 1910*93 nd 29 CFR 1910.93(a), Presented ;o the Occupational Safety and lealth Administration b y R. Vanderbilt Company, Inc., ana International Talc Co., m e . CRMC-MAD-000353 Appendix 1 PROPOSED AMENDMENT TO 29 CFR 1910 1. Table G-3 - Mineral Dusts of Section 1910.93 is amended by deleting therefrom the references to Talc (non-asbestosform), Talc (fibrous) and Tremolite, and by substitutin, therefor the following: "Substance Mppcf Talc 20n Tremolite (non-asbestiform) 20 Tremollte (asbestiform). Use asbestos limit -- " 2. Sub-section (a) of Section 1910.93a is amended to read as follows: I*ip \ T) ymi vtja o o C S wC.12_OT~l (1) 'Asbestos1 refers to a hydrated silicate mineral, with a structure based upon siliconoxygen tetrahedra, fitting the definition of a fiber, and composed of single crystals in ^predominantly parallel orientation. These minerals are chrysotile, crocidolite, amosite, anthophyllite asbestos, tremolite asbestos, and actinolite asbestos. (2) 'Fiber1 means any material in a form such that it has a minimum length to average maximum transverse dimension of 10 to 1, a . maximum cross sectional area of 7.85 x 10-5 in^ (5.06 x 10"2 mm) (corresponding to a circular cross section of 0.010 in. (0 .25^ mm) in diameter) and a maximum transverse dimen sion of 0.010 in. (0.254 mm). (3) 'Asbestos fibers' means asbestos fibers f longer than 5 micrometers." ' ' I CRMC-MAD-000354 "i & * A.M.Davis <tooo tzi) A. M. Gilbert J o s h u a Lk v ix f: ^ i i l i . i r K; S c h w a r t z 'A T H IC 1 A llA T M Y T iikodohc A. Kau tka n P niLU* S. R e i s s Paul P. Ouivey, J h R o s s L. G i l b e r t Lzo xard Orkin S o IjOMOV P I'milPMAN Ma HTIS A . R e m NITZ G ERALD B- SCHW ARTZ Mil e s B aum A l a n D. Kr o i l S t u a r t Le e F r i l d e l Michael D . D itzian D a v i s , G i l u k r t , L e v i n e 8c S c h w a r t z GOO F i r m Av e n u e , K r.w Yo r k , N. V. i o o o g July 19, 1973 Hovtaiid P.Peck Counsel Cable Ad d ress "D a v a n o il" T elephone A r e a Co d e ir E6A-0530 Hon. John Slender Assistant Secretary of Labor Occupational Safety and Health U. S'. Department of Labor Railway Labor Building First and D Streets, N. W. Washington, D. C. 20210 Administration Dear Sir: We are attorneys for R. T. Vanderbilt Company, Inc. with offices at 230 Park Avenue, New York, N.Y., and for International Talc Co., Inc. with offices at 420 Lexington .Avenue, New York, N.Y. Our clients, either directly or through wholly owned subsidiaries, are miners and producers of talc. Pursuant to 29 CFR 1911.3, we hereby petition, on behalf of our said clients, for the modification of the air contaminants and asbestos standards promulgated pursuant to the Occupational Safety and Health Act (29 U.S.C. 655) The Petition. Specifically, we petition for the modification of Table G-3 (Mineral Dusts) of 29 CFR 1910.93, and we further petition for the modification of 25 CFR 1910.93(a). Our particular proposals are'attached hereto as Appendix 1. . The proposed amendment to the said Table G-3 would divide the reference therein to the mineral tremo]ite into two separate references, one being for non-asbestiform tremo lile and .the other being for'asbestiform tremolile, and would consolidate the references therein to talc into a single reference. We propose that non-asbestiform tremolile and CRMC-MAD-000355 Da v i s , G il d e k t , L a v i n e 8c S c iiw a it z Hon. John Stender -2- . July 19, 1973 talc be subject to the mineral dust standard, and that asbestiform tremolite continue to be subject to the asbestos standard. The proposed amendment to Section 1910.93(a) v/ouxd amend the definition of asbestos so as to include therein the asbestiform forms of tremolite, anthophyllite and actinolite, and define "fiber", all based on the definitions of the Amer ican Society for Testing and Materials (Designation: D2946-71T) Background. The present definition of asbestos, as contained in the asbestos standard (29 CFR 1910.93a), includes therein, as asbestos, the mineral tremolite. It appears that this inclu sion was made rather loosely. For example, the criteria document (HSM 72 - 102o7) of the National Institute for Occu pational Safety and Health mentions tremolite only once, and t.T-*+^<-01+ pnu fsoCtTvfci.f'-c . t}T*occoci.s on idlio assumption that tremolite is an asbestiform mineral. Little or no'attention was paid to tremolite during subsequent hear ings .and proceedings. Talc producers, not realising that tremolite was being considered as an asbestiform mineral, did not participate in the hearings preceding the adoption of the asbestos standard,"and thus found themselves facing a fait accompli when the asbestos standard was adopted. Tremolite 'is often found mixed with the pure mineral talc, and is con sidered to be a normal part of industrial talc. This in turn has led to industrial talc being considered under the asbestos standard as some kind of asbestos. The effect of this con sideration of industrial talc as asbestos portends disastrous economic consequences, hereinafter discussed, without any firm scientific basis or resulting health benefit to justify same. Vie submit that the inclusion of all tremolite, within the definition of asbestos contained in the asbestos standard, is in error for mineralogical and medical reasons, and hence we are filing this petition for modification. / Mineralogy. Enclosed with is a paper (Appendix 2) entitled "Discussion of the Mineralogy of Industrial Talcs" by C. L. Thompson, I'h.D., together with the accompanying pictorial study. CRMC-MAD-000356 Da v i s , G ilxjisit, Lk v in e & S c iiw a u t z Hon.John Stender -3- July 19, 1973 Dr. Thompson demonstrates that tremollte is an asbestos mineral only in rare circumstances. H i s discussion of mineral- ugical history, examined in conjunction with h fiamatic photomicroiifaphia presentation, clearly demonstrates that if tremolite, like riebeckite, only had a different name for its fibrous form, then this petition would be entirely unnecessary. However, since the term "tremolite" covers .all varieties, asbestiform and non-asbestiform, said mineral has been lumped, even in its non-asbestiform form, with the fibrous asbestiform minerals. The proposed amendment to Table G-3 will make this distinction between the asbestiform and non-asbestiform forms of tremolite, retaining the former within the strictures of the asbestos standard, while relegating the latter to the mineral dust standard where it more properly belongs. It will further remove the confusing reference to "talc fibrous", since talc is fibrous only by virtue of other minerals contained therein, which minerals should be governed by the particular standards affecting them. Said proposed amendment also will supply an accepted definition of "fiber", enabling all affcited parties "to Kr'O'w cort-P-int-v *bli0 n-ilsuro of' ths r. which arc the subject of the standards: it will fill a glar- .ing omission in the present standard by placing the definition in the standard itself, rather than requiring reliance on some unspecified source. Medical Studies. There heretofore appear to have been few authoritative writings on the fibrogenicity and carcinogenicity of industrial talcs. One of these few was by Morris Kleinfeld, M.D. Dr. Kleinfeld has now significantly furthered his study, and this was done at our clients' operations. We are submitting to you herewith "Paper Presented at the Metal and Nonmetallic Mine Health and Safety Symposium on Talc Dust Hazards on May 8, 1 9 7 3 " by Morris Kleinfeld, M.D. (Appendix 3), "The Biological Action of Talc and Other Silicate Minerals" by Gcrrit V/. H. Schepers, M.D., D.Sc. (Appendix 4) and "Experimental Studies on Biological Effects of Tremolite Talc on Hamsters" by William E. Smith, M.D. (Appendix 5) For, even leaving aside the problem of the non-fibrous nature of most tremolite, there would still remain the question as to the physical effect thereof on the health of the workers using same. But what physical evils can be shewn to be caused by tremolite? CRMC-MAD-000357 Da v is , Gil h e it , Le v in e & S chw artz Hon. John Stender July 1 9 , 1973 Crocidolite, chrysotile and amosite are often mentioned in medical literature in connection with various pathogenic responses and hypotheses, but it appears that tremoliti x l not so mentioned. Vie believe that the question has been rather definitively answered by Drs. Kleinfeld, Schepers and Smith. The qualifications of these doctors are beyond ques tion, and their experience is vast. They are truly experts in the broad field of the effects of silicate minerals. It wouia be a disservice to their presentations to attempt to summarize them in any way here, and probably unnecessary. Suffice it to say that the experimental, clinical and epi demiological evidence compiled by them points inescapably to the conclusion that talc and tremolitic talcs are biologically inert, non-carcinogenic, and with little or no adverse fibrogenic effect, or effect on the heart. Given this lack of pathogenic effect, we suggest that tremolite (but, in the interests of limiting our request, only the non-fibrous form thereof) be treated as other mineral dust. We think that the ma.terials here enclosed rather conclusively establish the ba. ject of "asbestos" simply do not deal directly with the sub ject of tremolite and industrial talcs, and are not apposite to this petition. Vie know of no studies contrary to those presented here. Economic Impact. It is naturally temptin, when dealing with a subject of such importance as health, to regulate broadly on the theory that such regulation will aid in achieving the desired goal. But however lofty the motives, the more mundane subjects, such as the economic impact of such regulation, must be carefully considered, for they too have an enormous effect on the quality of life. So also, in evaluating the asbestos standard as it relates to industrial talcs, the effects thereof, not only on talc miners and millers, but also on those workers and busi nesses which depend on talc, and on consumers who use products made with talc, must be carefully weighed. Tremolitic talcs make up approximately one-half of all talcs mined in the United States. Such talcs are used extensively in the paint, rubber, plastics and ceramic wall tile industries. If such talcs are to be considered as CRMC-MAD-000358 Da v i s , Gie ije k t , Le v i n e 8: Scm vA irrz Hon. John Stender -5- ' July 19* 1973 asbestos under the asbestos standard, then, as hereinafter discussed, both the paint and ceramic tile industries will have to eliminate the use of talc. With their major users thus gone, our clients will be forced out of the talc .:1ness. The local effect of unis will be severe. Both of our clients have facilities in St. Lawrence County, New York. This county is an economically impacted area (see letter dated June 20, 1973 from Congressman Robert C. McEwen to Assistant Secretary of Labor John Stender, attached hereto as Appendix 6). The talc operations of our two clients em ploy 373 people, whose aggregate annual payroll, including fringes, amounts to almost L million dollars. In addition, our clients pay almost a quarter of a million dollars annual ly in local and state taxes. If our clients are forced to discontinue their talc operations, because of a loss of cus tomers, then the aforesaid jobs, with the accompanying payrolls and the taxes paid, will all simply disappear. The impact of this on any area, and especially on an impacted area, is not hard to imagine. . In addition, if our clients arc forced to discontinue their talc operations, certain of their suppliers will also be hard hit. For example, our clients annually purchase over a quarter of a million dollars in products of the paper bag industry. In addition, our clients pay more than 4.7 million dollars annually to the transportation industry for transpor tation of talc products. These supplying industries would therefore suffer substantial damage If our clients must dis continue their talc operations. And the figures given above do not reflect the further damage which will be done when other miners of talc are forced out of operation by loss of customers As to the effect on the paint industry of the applica.tion of the asbestos standard to tremolitic talcs, attach ed hereto as Appendix 7 is a letter dated July 3, 1973 from Loyal A. Brown of the National Paint & Coatings Association to Mr. Gerard Scannell, Director of the Office of Standards, Occupational Safety and Health Administration. It is apparent. therefrom that the aoplication of the asbestos suanaara t.o 1miusc rial taj.es w i n render inuor.s'iule lac- con tinned use'of title oy the pain if industry. The Toss oi' uie paint incus try" as a customer, will, in itself, require our clients to cease operations in the talc field, with all of the concomitant economic results w'n.m.h nave been discussed above. In addition, please note that the use of a substitute material in paints "would result in higher costs to the consumer for products CRMC-MAD-0003 59 Da v is , Gil b e r t , Le v in e & S chw artz Hon. John Stender *6 ~ July 19, 1973 which could fail to provide the standard of performance of tho existing coatings products". In these days of severe inflation, it is certainly clear that consumer;: " well do without increased costs, coupled with inferior products. Yet the continued application of the asbestos standard to tremolitic talcs will, in the paint field, result in just that. With respect to the effect on the ceramic tile industry of the application of the asbestos standard to tremo litic talcs, attached hereto as Appendix 8 is a letter dated July 18, 1973 from J. V. Fitzgerald of the Tile Council of America, Inc. to Mr. Robert Bacon of R. T. Vanderbilt Company, Inc. It would be a fair summary of Mr. Fitzgerald's statement to say that the application of the asbestos standard to the talcs used in the ceramic tile industry may very well result in the destruction of that industry. Note that twenty-five of the thirty-two ceramic tile factories in the United States depend on tremolitic talc, that they produce over .80$ of the 1:0 ^ ^~1 v>-! "t.i.c*"' oi* cci'CjtlLc g ci* vni*.*r* o c v c ^liO million uuiiarS, and that these factories directly employ some 4,300 persons. The technology of that industry, coupled Vith the economics thereof, makes it plain that said industry cannot survive in this country if it must apply the asbestos standard to its use of tremolitic talc. Environmental Impact. 'Effectuation of the modification of the asbestos standard, here proposed, should have no 'adverse environmental impact. Although the Environmental Frotection Administration has defined "asbestos" in the same manner as has the Occupa tional Safety and Health Administration, it is clear that the Environmental Protection Administration has never considered industrial talc as coming within the ambit of ins asbestos regulations. For in its emission standard for manufacturing (40 CFR 61.22(c)), no mention whatsoever is made of the manu facture of ceramic wall tile, which industry, in itself, is one of the largest users of tremolitic talcs. Furthermore, in a letter dated June 13, 1973 to the counsel for the National Paint & Coatings Association (attached hereto as Appendix 9), the Environmental Protection Administration stated "* * * the CRMC-MAD-000350 Da v i s , G i l d e h t , Lk v in k <Sc S c iiw a iit z Eon. John Stender 7- July 19, 1973 standards were never intended to cover the manufacturing of paints or coatings when commercial or industrial talc is used as an ingredient." This" was made even clearer by the E.. xion- Eientai" Protection Administration in its letter of June 20, 1973 to Mr. Allen Harvey of R. T. Vanderbilt Company, Inc. (attached hereto as Exhibit 10), wherein it was stated that a* * *- the asbestos standards do not apply to any manufacturin processes that use commercial or industrial rale as an ingre dient * (emphasis added). Said Administration conse- 'quently p.ians to amend its regulations to make this clear. From the foregoing, we believe it obvious that the granting Of the proposed modification will not have adverse environ mental impact. Conclusion. For all of the foregoing reasons, we submit that the inclusion of non-asbestiform tremolite in the asbestos standard is an error, which error should be corrected. standard be amended as we have proposed in Appendix 1. Neither the safety nor the health of the American worker will be adversely affected by such amendment, which amendment will effectively preserve the Jobs and livelihoods of thousands Very truly yours, y Enclosures: Petition - 5 additional copies Appendix 1 - 6 copies Appendix 2 - 6 copies Photomicrographic Study - 3 copies Appendix 3 - 6 copies Appendix 4 - 6 copies Piotos. of slides accompanying Appendix 4 - 2 copies Appendix 5 - 6 copies Appendix 6 - 6 copies Appendix 7 - 6 copies Appendix 0 - 6 copies Appendix 9 - 6 copies Appendix 10- 6 copies CRMC-M AD.00036I THE FOLLOWING DOCUMENTS) IS ILLEGIBLE OR OF POOR LEGIBILITY IN THE ORIGINAL. THIS IS THE BEST COPY AVAILABLE. c *m c .M a d _, >0hQikrr.cr, NewY*** vyw- 'C-V^v^U c^?vi*cC^i i2)o;:i: cl iL^yuiiiCr.lr.if'oijS GUui.'ji-.^ion. 23.C. 20515 June. 20, 1973 Appendix 6 hr, John fto.iv'cv Assisc;jnc SeevcCary Occupational Gaiety and be.fi.eh .VJr.ir.lstrntioa De.pnrtr.ent of i.abor Idea street ana Constitution L'a.shinpeon, P. 9, 20210 Avenue Deer .hr. Stenber: X w is h to tnhc this oppop .)/ to .r/.yro::;'. c.y appreciation to hr. J e r r y Ccar.ncil o', your ' or p i v i n t w o talc cor.pnnios, v/alch hove -.tincs and -.sills in t.' [rrcrict, r.n opportunity to infor rr.Ily express their concept-- awn;: ms. or,:l\ standards pertaining to asbestos. X also wis/yto \> , ,'r. Carry Gilbert and Dr. John O 'Ceil who participated lft-, chi; 5tin~. V^-fV 7hc two coy'V-ri.o.'--. ilT 7. Vanderbilt Cor,pony, 7nc. nnd International 'Tali/Co. ,C.r.e. own ar.d operate talc wines and nillo located near th e of Gouve.meur and e.,;.loy over 0 ",'topic. 7ii0.se co.vh>i_Jch pay out in salaries and wnfy.-s in excess of '3 rillion and pay town, county and school taxer, of nearly 0390 thousand. 7hey'arc both substantial employers when you consider that Coavorncur is a co:r;r,unity of epproxi.mtely d ,COO people. I should also n.id chat 5t. Lawrence County, in which those i,.lr.es nub r.illn are located, 'war. ho..an boaip,aacob by the. Department of Ccw.cree as a county which Is eligible for all poar.iblo. federal assistance proprn.v.s because, of the LipL uaer:plo-S',er.c veto and the outr;i;ytation factor. Should these r.inas bo forced to close, you can readily understand that it would have a serious and adverse ccoasnic effect ir. that area. It is r-iy under stand lap, that Che G.-.f.A asbestos standards will be reopened for further consideration. Altaonp.Vi these, standards do not apply to the tnlc industry directly, those two CRMC-MAD-000363 ? Mr. John Stender Page Two Juso 20, 1973 ccr../.".;-.lo3 hr.vc already b<_e.n told by their customers, mainly paint manufacturers and ceramic tile manufacturers, t' because trow.olito which in found in talc nan been c.LSSsiriad an asbestos and thereby cancer causin'*., they must find other sources of supply iron companies which do not produce talc with trenolite in it. It is r.y further understand ins that there is no evidence that trenolite is carcinogenic. I can readily understand your desire to protect the hor.ltl', of American workers and with that position i moat heartily agree, however, if the facts demonstrate that tremolite is not an asbestos and is not causely related to cancer, then I urge that CSuA expedite an order amending the asbestos standards so that this matter can be quickly resolved to the benefit of all concerned. Again, thank you and the members of your staff for your consideration in this matter. Sincerp.lv voarn. J Robert C. Menwen RC'i:lg bee: R. C. Bacon, Assistant to the President R. T. Vanderbilt Company, Inc. P. F. McCarthy, Executive Vice-President International Talc Co., Inc. V Paul B. Gibney, Jr., Esq. Davis, Gilbert, Levine & Schwartz Mr. Jerry Ciovaniollo Office of Congressman Jerry Pettis ? CRMC-MAD-000364 i "i-O, j ' v 1.; j July 3, I97C IJ'fT tf mAnm-j /\55ufjrj-JAYJON Appendix 7 M r. Geroici Scunnoll Director, O ffic e of Standards Occupational Safety cr.d Heclth Administration Room 504 Railway Lcbor Building First and D Streets, N . W . Washington, D. C . 2COiO Dear M r. Sccnnell: Wo wish to emphasize tire importance to the paint industry of industrial tele as a raw m ateriel. Some 172,053 ions of industrial talc in various grades are used annually in our industry to manufacture high quality indusirial and architectural paini products. It is considered a very valuable ingredient by the paint and coatings industry. It is our understanding that OSHA is presently attempting to clarify the con fusion which exists in the definition for asbestos, /Occupational Safety and Health Standards (Pert 29 CFR I9 I0 .??'j) T V ? T 3 c not N H N v - it was ins inten tion f O f " ` hi include Industrie; iuic in reg u latio n s governing the handling and procarsing of asbestos. Due to a technicality in the definition for asbestos, however, most Industrie:: talc used by our'industry may be covered by the present standard. The OSHA definition for asbestos includes "trem o lite." Trernolitc is an asbestos mineral only when if occurs in the fibrous form. Industrial talc as used in paint and coatings products may or may not contain tremolite; however, industrial talc supplied for this use is nen-fibrous as identified by the proposed 7\S lM definition. This same problem resulted from the EP/y definition for asbestos in their Natural Emission Standards for Hazardous A ir Pollutants and was clarified at our request os indicated by the June 13, 1973 letter from EPA (enclosed). If this problem is not cleared up, and a separate definition for industriol talc is not adopted, most point manufacturers feci it w ill be necessary for. them to eliminate the use of talc in paint products rcthcr than attempt to comply with the stringent OS! /a asbestos regulations. The reformulation ontJ re-engineering to eliminate tolc would be an extremely costly and time-consuming undertaking. If would result in higher costs to the consumer for products which could fail to provide the standard of performance o f tiie existing coctings products. y*taf****** *"! i> O/J CRMC-MAD-000365 vit piKu- y . Talc is used in lilo rt.il)' hundreds 01 differcnl joint products which arc processed 1))' m:.ny different types of equipment and is added in various stages of the paint manufacturing process. The complexify of talc usage by our industry would make the !v:.nciling ana' processing of industrial talc, impractical and prohibitive if the rules governing asbestos opply. V.'.? agree with the precautions and procedures required by OSHA standards for the handling and processing of asbestos. These are designed to provide health safeguards for the use or a pio on nazardous material. V.'c believe however, that two separate d efin itio n ; for asbestos end industrial talc ero absolutely necessary. We respectfully urge you to consider cdoplion o proposed definition for industrial talc developed by Committee D -l of the American Society for Testing and M aterials. S i n c e r e ly , 1 u0fiz< RoJ/al A . Brown Director, Technical Division RAB:seh Enel t? CRMC-MAD-000366 n ii ii 11 t n i AppeiiuxX O t J rT ` ! l! k A i .'\e9!***(-*0 ,o W /r-lJOJ-'*''? i.7o. L.>- A V,>J l"C*Z**>J/:`i>U /f/6. ' T / P .0 . / J r * j ?o * P r i n c e to n , t i J, CCO-W CO? ?.? ) / ' . & July IS, 1973 Mr. Robert Bocon Talc Industry Association R. T. V a n d e r b i l t Co., I n c . 33 W i n f i e l d S t r e e t E.st Uorwalk, Connecticut 06855 Dear Mr. Bacon: For o v e r 25 y e a r s , the T i l e Council o f America lias wor ked, through Research and A d v e r t i s i n g , t o c r e a t e and expand the market f o r cerami c t i l e . At t h e p r e s e n t t i m e , T i l e Counci l members produce 69 p er c e n t o f the 3 1 1 m i l l i o n square f e e t o f ce ra mi c t i l e p r o d u c e d annually in the United States, To o b t a i n a f a c t u a l p i c t u r e o f the s i g n i f i c a n c e o f t r e m o l i t i c t a l c as a raw m a t e r i a l f o r the t i l e i n d u s t r y , I have c o n f e r r e d w i t h L h i c i e x ec u t i v e s o t both T i l e Counci l o f Any* r i m nv>mh*r and nonmon.be r m a n u f a c t u r e r s . Talc, i s used in a l l 32 American w a l l t i l e f a c t o r i e s t o reduce s h r i n k a g e , and t h e r e b y c o n t r o l th e u n i f o r m i t y o f s i y.e r e q u i r e d in a l l cerami c t i l e . T a l c a l s o reduces m o i s t u r e e x pa ns i on , t h e r e b y e l i m i n a t i n g the o c cur re nc e o f cr acks and c r a z i n g t h a t woul d o t h e r w i s e o c c u r s e v er a l year s a f t e r i n s t a l l a t i o n . To a chi eve t h i s d e s i r e d dimensi onal s t a b i l i t y , a t i l e body is composed o f from k5 p er c e n t t o 70 p er cen t t a i c . . T a l c a l s o i s used t o manu fa c t u r e ceramic bathroom f i x t u r e s , glazes f o r ceramic t i l e and cerami c mosaic f l o o r t i l e . T a l c i s a component o f the r e f r a c t o r i e s that support tile s during th e ir manufacture. Twenty-five of the th ir t y - t w o ceramic t i l e fa c to rie s in th is country ( a l l o f those located in United States Regional Marketing Areas numbered i , 2, 3, k and 6 in the mon t hl y I n d u s t r i a l Reports p u b l i s h e d by t.he Department o f Commerce) use and depend on t r e m o l i t i c t a i c . In March o f 1973, a l o n e , these p l a n t s are r e p o r t e d t o have produced 17,579,000 square feet o f glazed w al l t i l e , or 8k percent o f t o t a l domestic, p r o d u c t i o n . The f a c t o r i e s in these f i v e r eg i on s employ some k,300 persons and produced 217, 028, 000 square f e e t o f glazed w a l l t i l e in 1972, r ep re sen ting $110,k0 0,000. ' j! |o tin r . M>:< > '] Ibc*.'/. . . -]r| > I f (<1 } N v ?.*, h. "1 \ Ptt *! *Vr cl ! | J.V M /t i'-rjM 1 u f ' v i i,*'. t i n t }\ i.t.O tin r.l /tciejn!' *AruU*t fX'MufncOMMK'is A 'n e tifJ 'i Cs<\ r.!.- L'i. U x , i Ancc Cco nTH i*n* A n:vd, T rial C t r r 1 i V M a n u ljl 'U 'tn g lj C*f'rn,.ili.O m o " Oustin'*'.1CrijTVi r.'11*1':.MTtul.ru IX. MV**'.'w| t ^ r I. mtl. f IMlKfAC! I n A`f Aj f c 'ti.j V.'iarc K ':< .iT**c Ci> Celi>*l". tr ,, ` '.csrVj' Ce' 'maC). DjCji.hut V Mr* Ine. Iflis *.hr>.< ii:r Ji'c .Sonhti'chr* : C 1 M .'pM iUH i ;>;.*.inr. N`o n j i;h M'* Sj ' Artj.f ' m i * r^-Tionj 7lr Ma*jlifrJr'Ofttj P-. i r o n J . f j D'o t ..* ..1.. Ii. ll. .1M<AlVl'Ml .*! M n ,(' .1 V', I-IU. T v s iv \ \ cirl l- > l . i * * It i>u. >. N<** |r**' UfMirll.iKii J jillp i lll'fM i \ \ , (,R , n V \ M . r v i t .*< 1(t. 1 i . 4i>J CRMc -MAD-000367 Mr. Robert bacon - 2- J u l y 18, 1973 Ceramic t i l e m a n u f a c t u r e r s , t h e r e f o r e w i l l be s e v e r e l y i n j u r e d sh ou ld t r c m o l i t i c t a l c become u n a v a i l a b l e o r shoul d t h e y be compel led t o comply, i n the h a n d l i n g o f t h i s r a w m a t e r i a l , v/i th th e s t r i n g e n t new OSHA s t a n d ar d s f o r asbestos and o t h e r to x ic substances. Application o f asbestos r e s tr ic tio n s to t r c m o l i t i c t a l c would c r i p p l e American m anufacturers1 c a p a b i l i t y o f f u rn is h in g t h e i r product in the market th a t they have worked to cr e a te . Recognizing th a t t h i s m att er is c r i t i c a l , t h e Hoard o f D i r e c t o r s o f the T i l e Council o f America has requested t h a t I a s s i s t and s upp or t the T a l c I n d u s t r y A s s o c i a t i o n in i t s p e t i t i o n t o exempt t r e m o l i t i c t a l c from i n c l u s i o n under OSHA st a nd ar ds f o r asbestos m i n e r a l s and o t i such to x ic substances. The average a f t e r ta x p r o f i t margin is 4.2 percent in the t i l e i n d u s t r y . This is sa lew,, i t is q u e s t i o n a b l e t h a t many ce r a mi c t i l e f a e t p r i e s c o u l d a f f o r d the phy si cal changes req uir ed by im p o s it io n on the h an d li n g o f t r e m o l i t i c t a l c o f the OSi:A a sbest os s t a n d a r d s . T hi s becomes o bv i ou s when the i n d u s t r y p r o f i t s o f - 1.1 p e r c e n t in IS6 3 , 2.0 p e r c e n t in 1970 and . 9 percent in 1971 a r e c o n s i d e r e d . Some o l d e r f a c t o r i e s might w e l l n o t a f f o r d ' t h e $250,000 o r more In c a p i t a l expenditures required to comply. The a l t e r n a t i v e - r e p l a c i n a t h i s b a s i c raw m a t e r i a l w i t h some o t h e r p r o du c t - w oul d a l s o be e x t r e m e l y d i f f i c u l t and c o s t l y as t o t i m e , c o s t o f e x p e r i m e n t a t i o n , and p o s s i b l e revamping o f d ie s and o t h e r equipment. Reserves o f the t a l c - l i k e m i n e r a l , , p yr ophyI 1i t e , whi ch i s used t o m a n uf a ct u r e some t i l e , are i n s u f f i c i e n t t a meet demands s h ou ld t r e m o l i t i c t a l c become u n a v a i l a b l e . F u r t h e r , the va l ue o f e x i s t i n g i n v e n t o r i e s at both f a c t o r i e s and d i s t r i b u t o r s would be s e r i o u s l y a f f e c t e d , a ^ pr x-r* /v mnfrktnn c ! tr> V ffv**^ U J c 5k 1 ^ f 1 C r</*> que stion that the q u a l i t y o f the product would s u f f e r by any such change, making Ft even more d i f f i c u l t t o compete w i t h th e l owe r co st o f f o r e i g n i mpor t s w h i l e m a i n t a i n in g q u a l i t y standards f o r the domestic i n d u s t r y . Thus the a l t e r n a t i v e f o r sane American manufacturers could be e c o n om ic al ly im p r a c t ic a l and cause them to go. out; o f b u s i n e s s . Wi t h these c h o i c e s , one company has r e p o r t e d t o me t h a t , i f the s t r i n g e n t asbestos s tandar ds arc imposed on t r e m o l i t i c t a l c , t h e y w i 11 have t o c l o s e down and b u i l d a p l a n t in a f o r e i g n c o u n t r y and e x p o r t t o the U n i t e d S t a t e s . Thus, t h e r e is no q u e s t i o n but t h a t the domesti c cerami c w a l l t i l e i n d u s t r y w i l l be s e r i o u s l y i n j u r e d Ff QSHA r e q u i r e s t r e m o l i t i c t a l c t o be c l a s s i f i e d and handl ed as a t o x i c asbestos mineral'.. ' . Sincerely yours, J... V... F i t z g e r a l d JVFcnk cce: J'.. Druce t?.. Gibney CRMC-MAD-000368 WASHINGTON. D.C. 20-G0 1 3 JUil 1373 Appendix 9 Mr. Larry Thomas Counsel National Paints and Coatings Assoc. 1550 Rhode Island Avenue, NW Washington, D. C. 20005 Dear Mr. Thomas: This letter is in response to your inquiry as to the appli cability of the national emission standards for the hazardous air pollutant of asbestos to the paints and coatings manufacturing industries that use talc. It has been determined that the standards were never intended to cover the manufacturing of paints or coatings vhen commercial or industrial talc is used as an ingre dient. The standard is applicable, however, to paint and coatings manufacturing when asbestos as defined by 40 CFR 61.21, with the above exception, is used in the manufacturing process. ? It should be noted that 40 CFR 61, National Emission Standards for Hazardous Air Pollutants, will be amended in order to .properly clarify this situation. Director, Division of Stationary Source Enforcement C R M C - M AD-000369 `"`" N T h U N ITED STATES EN V IR O N M EN TA L PROTECTION AGENCY W A SH IN G TO N . D.C. 20460 ?. 0 JUN 1973 Mr. Allen Harvey Patent and Legal Department R. T. Vanderbilt Co., Inc. 33 Winfield Street East Norwalk, Conn. 06855 Dear Mr. Harvey: This letter is in response to your inquiry as to the appli cability of the asbestos hazardous air pollutant standard to talc milling operations. The proposed National Emission Standards for Hazardous Air Pollutants (NESHAPS) defined asbestos mill as a facility engaged in the conversion of asbestos ore into commercial asbestos. Since it has been determined that talc milling does not fit this definition, the asbestos standards do not apply to this operation. Tn ndrl-rtinr J.t hns been dctermir-sd that the asbestos standards do not apply to any manufacturing processes that use commercial or industrial talc as an ingredient (unless asbestos as defined , by 60 CFR 61.21, with the above exception, is used in the process).( It should bo noted that 40 CFR 61, NESHAPS, will be amended in order to properly clarify this situation. Sincerely, y Richard D. Wilson Director, Division of Stationary Source Enforcement ; ' t j I n f t i f f i f t~; CRMC-MAD-000370  Greenwood Plaza - 3 West February 14, 1973 P. A. Martinson - 2 West TALC PRODUCER'S ASSOCIATION (PROPOSED) K. S. L a m a r 's letter of January 31, 1973 Dick Lamar's letter suggested that I comment on the technical soundness of the letter before it is sent. Before doing so, I would like to raise a question as to the desirability of sending such a letter out after attending the recent meeting of the Talc Producer's Association in New York City. While the intent of the meeting was to promulgate a series of definil-inns differentiating asbestos, tremolite, talc and commer cial talc, I believe I was instrumental in changing the end result so that only one definition is being proposed, i.e., industrial talc. While the exact wording may differ very slightly from the definition below, the general gist was as follows: "Industrial talc from the mineral mineral talc and fibrous minerals is a product varying in mineral composition talc [}lg6 (SigOjo) (Oil) 4 ] to mixtures of other naturally associated non-fibrous and/or as defined by ASTM Designation D2946-71. While we should clear with the Vanderbilt people whether they intend to continue their previous plan to convince Government officials that tremolite is not an asbestos mineral, my own impression from the meeting is that they are convinced of the futility of this approach. The much more reasonable approach, and one which has some slight possibility of bearing fruit, is to concentrate on the definition of fiber. The ASTM definition referred to above uses an aspect ratio of 1 0 : 1 rather than the ACGIH ratio of 3:1. 1'. T. Vanderbilt appears to be the spearhead for the whole effort to disassociate tremolite from the list of asbestos minerals. If they are not going to push this approach, then there is little need, in my opinion, for sending the letter to Talc Producers or to the Talc Producer's Association. So much for the political aspects of the letter. With reference to the technical aspects, I should like to make the following points, some of which obviously will be minor. CRMC-MAD-00C371 1 February 14, 1973 Page 2 P. A. Martinson - 2 West T tem 2. While tremolite does have a fibrous "crystal habit" the particles can be fibrous or non-fibrous. In essence, a fiber is a particle with a defined minimum ratio of length to width. Unfortunately, this aspect ratio (L/D) is not a definitely established limit. As a matter of fact, in the ASTM definitions there are two ratios given as minimum. In the ASTM definition of asbestos minerals, the ratio is 10:1; in the Textile Fiber section, the limit is given as 100:1. However, the more important aspect ratio limit, whether it has any more scientific significance or not, is that promulgated by the ACGIIi, namely, an aspect ratio of 3. If the tremolite particles have an aspect ratio greater than 3:1, they are fibrous as far as OSHA is concerned. If the ratio is less than 3:1, the tremolite particle is a particle, not a fiber. Tlius, although "tremolite is a fibrous mineral" as stated in Item 2, the individual particles may be fibrous or may not be fibrous, depending on their specific aspect ratios. Starting with this distinction, we go to Item 1 which says that tremolite is clearly a member of the "asbestos family" of minerals. Again, this is correct, but since the asbestos minerals are fibrous by definition, then we could conclude that those particles of tremolite whose aspect ratio is ex tremely small are really not fibers and, therefore, they could be considered as not being asbestos. What I am trying to point out is that whether tremolite is to be classed as an asbestos minera.: is secondary to whether the particles are really fibrous or not insofar as the OSHA regulations are concerned, and we should try to pin our argu ments on the aspect ratio factor. Item 3. X-ray diffraction methods make possible a positive "TlTffcrentiation between" both minerals. It will not definitely identify tremolite in a mixture containing small quantities of tremolite in a large concentration of talc. Strongest identifying X-ray lines for tremolite are essentially the same as those for anthophyllite and several other amphibole minerals. The statement that pure talc mineral is fairly common in nature in something that I must defer to R. Lamar's knowledge. I had not anticipated that there were any large deposits of pure talc mineral without concomitant impurities, albeit non-fibrous impurities such as carbonates, oxides, etc. CRMC-MAD-000372 February 14, 1973 Paye 3 P. A. Martinson - 2 West Item 8. While I am sure that our Industrial Hygienists can supply information regarding correct procedures for dust control and other protective measures that may be required, it will be a long time before sufficient medical or epidemio logical data are available on which to pass any recommendations other than to include tremolite as either an asbestos fiber, in which case the fiber count limitations will be paramount, or at; a nuisance dust in which particle count would be para mount. Dick Lamar is to be congratulated on preparing a summation of this type which brings together at one point pertinent informa tion of a technical nature. s. SPEIL SS/rs cc W. T j- t . VanDerbeek J. M. Sharratt II. R. Keefe W. C. Streib R. P. Carter R. S. Lamar E. 13. Smith R. F. Bassett - 2 West - 2 West - 2 West - 3 West - 5 West - 1 North - Long Beach, Carson - Long Beach, Carson CRMC-MAD-000373 n n t ~ n "> ~ ~ >J M I ! IJ January 25, 1973 F. J. S o l o n , Jr. ii. M. Jackson E. M. Fenner W. B. Reitze Dr.. G., Wright Dr., S., Speil -/ Dr., J. Leineweber Dr,, E. Marriner R. P. Carter W. L. VanDerbeek P. A. Martinson H. R. Keefe R. S. Lamar N. B. Scheffel E. B. Smith R. T. VANDERBILT ACTIVITIES FDA-OSHA REGULATIONS Y j On January 11 as arranged by Norman B. Scheffel, a meeting was held at the R. T. Vanderbilt New York offices to observe a presentation of the field by RTV to Government agencies concerning talc vs. asbestos. In attendance were ? Dr. Speil, R. S. Lamar, N. B. Scheffel, and E. B. Smith. .1 The presentation consisted of a series of slides as photomicrographs comparing j Vanderbilt New York State talc (Nytal 100, 200, 300, 400), California talcs 1 (Westal 101, 303, and 404), and beneficiated California talcs. Compared also J were slides of asbestos minerals. In this presentation, it is the objective | of Vanderbilt to establish thattremolite isnon-fibrous andnon-asbestoform ' in order to obtain an amendment or variance in the OSHAregulations toexclude j V tremolite. The presentation did contrast the particle shape of their talc mineral as compared to asbestos fibers but lacked any real scientific evidence to differentiate current definitions. J -Cj Vanderbilt has made this presentation to the New York State Bureau of Mines || attended by Dr. Jacquelin Messite, Merley, Sheffield, and Stein. Kleinfeld not present due to his retirement. Vanderbilt has also made this presentation s to Earl Goodwin at the U. S. Bureau of Mines. They have also made these presentations to EPA at Durham attended by Mr. Arthur Stevens, Deputy Director of the Bureau of Mines and Safety. Vanderbilt feels that they have cast some doubt on the definition and are hopeful to pursue Government agency toward a new definition of "commercial asbestos" as opposed to tremolite as an asbestos mineral. Vanderbilt has also been in communication with the A.S.T.M. Committee D-l-31- 07 concerning extender pigment. Presentation made by Allan Harvey at Miami was oriented towards the removal of tremolite from the asbestos definition. It is their hope to obtain A.S.T.M. approval and use this approval with other Government agencies. Vanderbilt has justifiably been reluctant to tackle NIOSH until more confidence is developed in their presentation. Dr. Speil was of considerable help at this meeting in pointing out the pitfalls and errors in Vanderbilt's thinking. It was concluded that the attack on tremolite vs. chrysotile must be medically oriented as opposed to a simple fiber definition or redefinition. Speil suggested that a more appropriate approach would be to obtain an exclusion nn t *! M I I n i ~i m l ' f I CRMC-MAD-000374 ---- of tremolite based on scientific or medical reasons as opposed to a redefinition separating tremolite from chrysotile and/or asbestos. However, Vanderbilt intends to pursue the subject by enlisting the Talc Industry Association's help in developing an acceptable definition of talc, asbestos, etc. at the meeting scheduled for February 5 in New York. In view of the expertise obtained by J-M people in this mineralogical area and the Government communications area, we urge that Dr. Speil and additional environmental people at J-M attend the February 5 meetihg in New York. Attached to this memo are some definitions that Bob Bacon has extracted from various enclyclopedias and from the Federal Register concerning asbestos fibers. It is in this direction that RTV intends to proceed. We certainly question this attack and increased help from J-M to guide this program properly and scientifically and not to the detriment of the talc industry. E a rl B. Smith EBS: cks CRMC-M A D -0 0 0 3 75 January 22, 1973 Jr. C. S. Thompson n. T. Vanderbilt Company, Inc. 33 viinfield Stroot naat Iforwalic, Connecticut 00355 Dear Dr. Thompson; I am s o r n to have delayed ao long in sanding you samples of the UICC floor, but wo could not locate our own samplos nor descriptive material o n tho fibers because of our move currently undorway. I an enclosing two small plastic anvelopcs--one containing UICC crocidolite, and tho o t h o v UICC anthophyllita. You will nota that these arc comparatively short fibers, but possibly not as short as the troirolito in your talc. In any case, tho UICC crocldolito has caused carcinoma in animals, although I do not know of any specific results from animal experiments with the anthophyllita. I ora also enclosing copies from tho 1S72 ASTM Yearbook. On page 595 arc listed tentative definitions of tarms r e l a t i n g to asbostoa fiber. These aro under the jurisdiction of ASTd Committee D-30 on Uigh-Hpdulus Fibers. Tho defi nitions on thin page are specifically related to asbestos. On pago 20 aro a corioc of other definitions relating to the word fiber under the auspices of A5TJ-5 Committae D-12 3. vhoso arc related to the use of fibrous materials in tex tile products. You will notice the difference between, the definitions. When referring to asbestos, tho fiber defini tion calls for a 10:1 ratio in length to average maximum transverse dimension. ivPicn related to weavable fibers, the corresponding ratio is 100 times. These specifications are already in tho ASTM litoraturo. ;'hilo I appreciate tho intention of our Talc Producers Committee to get a still different definition into tho AST.-l litoraturo through tno pigment uubcomraittoo, such a CRMC-MAD-000376 January 22, 1973 Page 2 Dr. C. S. Thompson R. T. Vanderbilt Company definition would probably still be related to tho application involved, that is, pigmont3 and would have no more standing with tho Goveminont than tho two definitions already in tho literatura. In fact, tho ACGIH has established their own definition, as you know, based on what they consider to be the properties of a fiber related to their own particular field, that in, health effects. I will be glad to discuss this with you in moro dotail, and am trying to got still other definitions of fiber which have been racognizod cither commorically or by health regulatory groups ooforo tho mooting on February 5. Sincoroly, Dr. Sidnoy Spoil, Director Central Research Department Enclosures (3) bee: E. a. Smith - Desert Minerals N. Scheffel - Desert Minerals R. S. Lamar - 1 North, Denver CRMC-MAD-0003 77 Johns-M anville Products Corporation Filtration &Minorala Division Greenwood Plain Denver, Colorado 80/17 (303)770-1000 April 18, 1975 Mr. H. B. Vanderbilt, President R. T. Vanderbilt Company, Inc. 30 Winfield Street Norwalk, CT 06855 Dear Mr. Vanderbilt: Your ^coi^yfesy in meeting with us earlier this week is gre'atly appreciated. We felt that it was important , for you to understand our position with respect to \talc labeling and the various actions we are currently taking in the market place in this regard. Our intent xn sharing with you our analytical data on your products is an attempt to be helpful and is most certainly friendly. m this regard, if we can in any way be of assistance to your technical people through an exchange of information and samples we would be glad to do so. If Dr. Thompson would care to meet with our Research people to review our findings we would be pleased to arrange this for him. This kind of techni cal exchange would be helpful to both companies. Following our meeting in Norwalk, I have reviewed with Dr. Paul Kotin, Medical Director for Johns-Manville Corp., the various points we discussed. He has indi cated that if you so desire he would gladly meet with you and various members of your staff to describe the medical aspects of the situation. Will you please convey my thanks to the other members of your group who attended our meeting on April 16. Sincerely, 52, R. S. Lamar, Manager Filtration and Minerals Growth Development Division cl ] a cc: Dr. Paul Kotin Dr. Fred Pundsack A, W bcc : S. W. Schulmeyer H. R. Keefe PST, chrcno file r Vandort file C. J. Sulewski P. A.. Martinson R. P. Carter W. C. Streib CRMC-MAD-000378 Johns-Manville Internal Correspondence MEMu TO FILE Date: NOV. 13, 19 7 3 R. P. Carter File & C RE: MEETING WITH JOHN O'NEILL - NOVEMBER 8 , 1973 MEETING WITH JERRY SCANNELL AND JOHN O'NEILL - NOV. 9 , 1973 Several weeks ago, upon learning that John Stender had decided not to appoint a Standards Advisory Committee in connection with the reopening of the asbestos standard, I called Jerry Scannell's office for the purpose of setting up a meeting with Jerry to determine why this decision had been made and what Johns-Manville and the asbestos industry could do to assist OSHA in promulgating a new standard. Jerry Scannell was out of town on business in Hawaii for a period of three weeks"and therefore, t h e 'meettTTg^ouId not"'Be set up until fTovember 9. After a meeting was scheduled with Jerry Scannell for November 9, I was advised that John O'Neill would be delivering a presentation to the annual meeting of the A/C Pipe Producers Association in Washington on November 8 . I attended that meeting and had the opportunity to informally speak with John O'Neill in addition to listening to his presentation. During our informal conversation, John O'Neill indicated that one of the primary reasons for Stender's decision against the establishment of a Standards Advisory Committee was due to the fact that if such a committee was appointed, Dr. Irving J. Selikoff would have to be included as a member of the committee. I got the impression from O'Neill tjiat Stender felt that Selikoff's presence on the committee would impair the functioning of the committee. O'Neill further indicated to me that the thrust of the revision would be the establishment of work practices. I indicated to John that it could conceivably take several years to prepare work practices for each segment of the asbestos industry. John agreed, but indicated that they would attempt to prepare work practices by processes which were common in each segment of the industry. During our informal discussion, John O'Neill mentioned that he had read the first two installments of Paul Brodeur's series of articles in the New Yorker Magazine. John was not happy CRMC-MAD-0003 79 MEMO TO FILE Page 2 November 13, 1973 with these articles as it presented a very une-siueu picture of the asbestos industry and was concerned with several unfavorable comments made about certain government employees. During his presentation, John O'Neill made specific reference to the unfair treatment of the asbestos industry in the news media and how only one side of the story was being told, which in his opinion, was quite unfair. During his presentation before the A/C Pipe Producers Association, John O'Neill was quite candid in his remarks regarding the reopening. I did not get the impression that John O 'Neill was speaking from any prepared notes but was rather making off-the-cuff remarks. The key points covered by John O'Neill in his presentation were as follows: (1) The OSHA standard for exposure to asbestos dust was written only to prevent asbestosis and was not designed to prevent mesothelioma or cancer. (2) The new evidence which OSHA now has is that fibers other than asbestos can cause mesothelioma. (3) The British data upon which the current OSHA standard was based is weak and not scientific. (4) OSHA wants to re-evaluate the TLV for asbestos. (5) When preparing the current asbestos standard, OSHA did not take into consideration the talc mining problem. He indicated that tremolite is not fibrous and it has not been proven that tremolite causes any harm. OSHA therefore, must re-examine the types of asbestos covered. (During this past Summer, R. T. Vanderbilt and Company, a major talc producer, filed a petition with OSHA requesting a modification of the asbestos standard, basically deleting tremolite from the standard.) (6 ) The method of sampling and measurement must be re-examined. In a phase contrast system, it is difficult to differentiate and distinguish fibers. (7) The types of respirators permissible must be re-examined. As of April 1, 1 * 7 4 , many respirators will lose their current approval. MEMO TO FILE Page- 3 November 13, 1973 (8) OSHA wants to re-examine monitoring. (9) Work practices must be developed, evaluated and made mandatory. (10) Asbestos is essential in many uses and OSHA has no intent to ban its use, Rather, OSHA is desirous of establishing safe ways of using asbestos. (11) John Stender has opted for the use of outside consultants in lieu of appointing a Standards Advisory Committee. (12) OSHA wants the new standards to be very clear. One of the strong reasons for reopening the standard is due to a large number of inquiries OSHA has received during the past year and a half for clarifications and interpretations of the standard. It is their conclusion based on the volume of requests that the current standard is not clear. (13) The current numerical standard will probably remain unchanged. (14) OSHA would like considerable input from industry to assist them in drafting a new standard. On November 9, Jack Solon and I met with Jerry Scannell at his office. When we arrived, John O'Neill was also present in Jerry Scannell's office. Jerry indicated that he was currently in the process of preparing a written proposal to John Stender which would consist of a procedure to draft and promulgate a revised asbestos standard. This proposal would be in lieu of the establishment of a Standards Advisory Committee, in view of the fact that Stender had rejected the establishment of such a committee. Jerry's recommendation to Stender will be for OSHA to prepare a draft of a new asbestos standard which would take at least three to four months. Then OSHA would use outside consultants, individuals picked from industry and labor, to be used by OSHA on an individual basis. For example, Scannell would propose contacting AIA to receive recommendations for individuals to be used as consultants. At individual meetings with these consultants, OSHA would discuss particular prrtions of the proposed revisions with experts in specific areas. After OSHA has met with these consultants they would the: irrange tn visit various plants in the asbestos industry to determine the oracticality of the revised standard. Jerry Scannell indicated that he had CRMC-MAD-000381 MEMO TO FILE Page 4 November 13, 1973 received a ruling from their attorneys to the effect that :uch a plant visit could not be the basis for an OSHA citation. Jerry was quite concerned that various companies might object to OSHA's presence in a plant due to a possible citation exposure. Jerry would like every effort to be made by OSHA to insure their credibility with industry that citations would not be issued as a result of these plant visits. As a matter of fact, he would attempt to work out an arrangement with OSHA enforcement people so that no plant inspections would be made in those establishments visited for a period of at least one year after their plant visit. Following the plant visits, OSHA might perhaps meet on a group basis with all of the consultants for the purpose of reviewing a final draft of the proposed regulations. During the entire process, the proposed regulations would be revised and altered informally as necessary. The final step would be the publication of a new proposed standard in the Federal Register, which probably would not take place before a period of one year from now. At the time the new proposed regulations are published, OSHA might announce a hearing date at that time if they feel there will be substantial comments or objections to the proposal. Jerry indicated it was conceivable that if no meaningful objections were made to the proposal, no hearing at all might be scheduled. Towards the conclusion of our meeting, Jerry Scannell indicated that there were severaj. things he would like from J-M: (1) A letter on how we would like the asbestos standard modified. For example, what aspects of the standard are currently unclear or impractical. (2) Provide OSHA with suggestions for improving monitoring and fiber counts, perhaps including a proposal for scrapping fiber counts. (3) How can OSHA get Labor and Management together to discuss a new proposed standard without such a meeting being conducted on an adversary basis. (4) After Ed Fenner establishes a Technical Committee within AIA, Ed Fenner should contact John O'Neill to discuss whatever assistance t.:e Technical Committee can give him in drafting a new standard. CRMC-MAD-000382 MEMO TO FILE Page 5 November 13, 1973 (5) Jerry Scannell may need assistance from J-M and other companies in the industry in selling his new proposal to John Stender. In view of the fact that J-M and other companies have sent letters to Stender advocating the establishment of a Standards Advisory Committee, it might be desirable at some point in time for us to advise Stender that we support Jerry Scannell's new proposal. In this regard, it is my intention to contact Jerry Scannell at the earliest possible time to advise him that J-M fully supports his new proposal to Stender and advise him that we would like to cooperate in any way possible to assist him in selling his proposal to Stender. I will suggest to Jerry that he give consideration to arranging a meeting for J-M with Stender, at which time he should be present, for us to convey our support of his proposal to Stender. The timing of such a meeting should be left to Scannell. R. P. Carter P.S. - After dictating this memo, I spoke with Jerry Scannell by telephone at which time he advised me that he had presented his proposal to Stender and Stender had accepted his suggestions. I then asked Jerry if we should either write or call Stender for a meeting to indicate our support of their new proposal. Jerry said the decision was up to us but we should either call for a meeting or present our views in a letter to Stender. It is my present plan to draft a letter to Stender withdrawing our request for the establishment of a 15-man Advisory Committee and supporting Scannell's proposal. I intend to read a draft of this letter to Scannell over the telephone and ask his suggestion as to whether or not the letter should be sent or a personal meeting arranged. CRMC-MAD-000383 October 9 1974 * . / r > . <*- +- `S,- ,, Mr. 11. 35. Vanderbilt " ; President.' . 'V.-'/> Chief Executive Officer ' *' .'> R. T. Vanderbilt Cenpany, Juay- 30 Vinficld Street - : ;,Jr Norwalk,, -Connecticut 08855. r Sear Mr. Vanderbilts/-' : '' ' 'o f !? ' This Is in reply to your letter of September 26, concerning your request for relief froo the asbestos standard for your talcs' containing non-fibrous trecolite, actinolitc, and anchophyllifit Hy letter of August 6 stated that non-fibrous or non-asbestiforsa minerals such as non-asbestifora txecolita are not within th* ceope of the asbestos standard and, therefore, the provisions of that standard do not*apply to talc containing non-asbestifora mineral*. KIOSII is currently conducting a thorough `investigation into the exact minerals to which sale workers were exposed -da. chose studies where asbescosis or other adverse medical effects were found. Pending the receipt and evaluation by CSEA of the report by NIPSS on this investigation, if you have scientific evidence that the naturally occurring talcs, prior t'e* processing by Billing or crushing, do not contain fibrous or asbescifom trescolice, nutophyllite, accir.olite or other asbestifera minerals, you nay certify to.your customers chat the talc does not contain asbestos. Fibrous, asbestlfora cierais such as fibrous trenellte eeans naturally occurring asbescifom cierais which prior to er after crushing ar.d processing, contain fibers nade up of fibrils. Sincerely, /s/ John H. Stender ; John K. Stender * Acsi*tant Secretary of Labor C 15656 CRMC-MAD-000384  , cutoi-cv v , t* * Mr. 1?. B. Vanderbilt: President Chici Executive Officer K. T. Vanderbilt Conpany, Inc.30 V.Unficld Street Korwnlk* Connecticut 08855 Dear Mr. Vanderbilt:. > o r J:' This is in reply to your letter of Sept ri-bei enure, n iny. your request for relief iron the asbestos Mandarcl for your talcs containing non-fib: our trenolite, nclinolite, Vinci nntliophyllite. My letter of August 6 stated that non-fibrous or non-r.r.bestiforra minerals such tfs non-asbestiforev trenolite are not within the ccopc of the asbestos standard and, therefore, the provisions of that standard do not'apply to talc containing non-ar.bor.tiforn minerals. KIOSH is currently conducting a rnorouch V r . v ; :p.afio.. into tint o:act minerals to which talc workers were exposed -itr those studies where asbestosis or other adverse nodical effects were found. * * Pending the receipt and evaluation by OSHA of the r e p o r t by KIOSH on this investigation, if you have, scientific evidence that the naturally occurring talcs, prior to1processing by nilling or crunching, do not contain fibrous or asbestiforn trenolite, nntophyllite, actinolite or other, asbestiforn minerals, you .' may certify to.your customers that the rale does not. contain asbestos. . Fibrous, asbestiforn minerals such as fibrous trenolite means naturally occurring asbestiforn minerals which prior r.o or after crushing and processing,- contain fibers made up of fibrils. Sincerely, /s/ John H. Stender John M. Stender Assistant Secretary of Labor w a sm p io i- io l CRMC-MAD-000385 This is in reply to your letter of Sep te mb er .26, concerning your request for relief iron the asbestos standard for your talcs containing non-fibrous trenolite, actinolite, and anthophyilite. My letter of August 6 stated that non-fibrous or non-asbestiform minerals such as n o n - a s b e s t i f o n trenolite are not vithin the scope of the asbestos standard and, therefore, the provisions of that standard do not"apply to talc containing non-asbestiforn minerals. ^ K I O S H is currently c o nd u ct i ng a thorough "investigation into the exact minerals to v'nich talc vorkers vore exposed -in. those Etudies vherc asbestosis or other adverse medical effects were found. P o n d i n g the receipt and evaluation by DSHA of the report by h'lOSH on this investigation, if you have scientific evidence that the n a t u r al l y occurring talcs, prior tir p ro ce ss in g by milling or crashing, do not contain fibrous or a s b e s t i f o m trenolite, nnt'ophyllite, actinolite or other a s b e s t i f o m minerals, you nay certify to-your customers that the talc does not contain ECDCStOS. Fibrous, a s b e s t i f o m minerals such as fibrous trenolite means naturally occurring a s b e s t i f o m minerals vhich prior to cr after c ru shing and p r o c e s s i n g , contain fibers made up of fibrils. Sincerely, . . Is! John K. Stender J oh n K. Stcndcr A c s i E t a n t Secretary of Labor .00036 C K N l O-VIA0 B 26771 Johns-Manvilie Products Corporation C*llte Dlvlilon Greenwood Plaza Denver, Colorado 0217 (303)770-1000 August 27, 1973 Mr. Robert H. McCarthy, president International Talc company, Inc. 420 Lexington Avenue New York, N.Y. 10017 Dear Mr. McCarthy: Confirming our phone conversation Friday morning, I am enclosing a copy of "Food Grade Talc Specifications to be Proposed by FDA" as published in Food Chemical News, August 20, 1973. Although the article and the reported regulation forth coming from FDA is pointed toward asbestos, there is by association regulatory aspects that directly affect talc containing asbesto-form fibers. As a matter of information there has been or will be shortly, communications between J-M counsel and Mr. Robert Bacon of R.T. Vanderbilt relative to the subject. It appears to the writer that to those of us directly concerned with talc processing and marketing there is justification.for questioning issuance of the regulation in question. There appears to be little or no supporting scientific data as a basis to issuing the regulation. The enclosed is sent along for information only. Sincerely, P.A. Martinson Vice President General Manager CCj W.L. VanDerbeek - 2W J.L. Solon - 4n R.P. Carter - 4M W.B. Reitze - IS g .e . Parker -- 5W S. Speil - R&D R.S. Lamar - RScD R.F. Bassett H.R. Keefe - LB - 2W D CRMC-MAD-0003 87 Legal Services Denver - GHQ April 23, 1973 F . J. Solon E. M. Fenner Dr. G, Wright S. Speil J. Leineweber Dr. E. Marriner W. B. Reitze -- iS P. A. Martinson H. R. Keefe W. C. Streib R. S. Lamar G. Coombs N. B. Scheffel E. B. Smith W. L. VanDerbeek FDA PROPOSED TALC REGULATIONS Enclosed is the final version of J-M's comments and exhibits regarding the FDA's proposed regulations banning the use of talc in food and food packaging materials. The letter with our comments and the attached exhibits was mailed to FDA this morning. The final version of our comments contains many modifications and additions from the last draft circulated on April 6. I am presently planning to contact Allen Spiher of FDA to set up a meeting with him in the near future to review our com ments with FDA and to get an indication as to the direction in which they are proceeding on this matter. Also enclosed is a copy of R. T. Vanderbilt's comments to FDA which I received today. Of most significant interest is Appendix C to their comments, which is a copy of a letter from Dr. Schepers to Bob Bacon, Director of Research for Vanderbilt. I would appreciate receiving comments concerning our use of the information contained in Dr. Scheper's letter in our pre sentation at the Bureau of Mines Talc Symposium in Washington on May 8. Additionally, I have enclosed a copy of a letter dated March 2, 1973 from Dr. Alfred Weissler of FDA to the Environ mental Defense Fund in response to their inquiry about asbestos CRMC-MAD-000388 i (9 4 in talc. Dave Malino of The Government Research Company forwarded a copy of this letter to me. The last paragraph on page 2 is of interest in that FDA indicates, much to my surprise, that they have undertaken extensive literature surveys cn the carcinogenicity of asbestos and of talc. This was a total surprise to me as I found FDA to be totally unknowledgeable regarding the question of carcinogenicity of asbestos and talc when I met with them last September. Perhaps, they were embarassed as to their lack of knowledge at that time and have now attempted to educate themselves. Again, if any of you have any comments relating to the contents of this letter from Dr. Weissler, I would appreciate hearing from you. Richard Carter enclosures CRMC-MAD-000389 -2 - R. T. V A N D E R B IL T C O M P A N Y . IN C . 33 W INriELD S T R EE T E A S T N O R W A L K , C O N N E C T I C U T 066. " April 17} 1 9 7 } CAe.ca5c csi BtLTVAN St* vU0- Mr. Alan T. Spiher, Jr. Chief, GRAS Review Branch Division of Petitions Processing Bureau of Foods 200 C Street, S. W. Washington, D. C. 20201 Dear Mr. Spiher: We are sending you the attached documents pertaining to "Proposal Regarding Regulation of Pricr-Sancticned Food Ingredients" ifl at the request of Dr. Corbin k'yles, with whom we have been in telepho:ne cor eet regarding our petition i'or an extension of tire for comment. We sincerely appreciate the opportunity to elaborate on the cues of possible health hazards of industrial talcs. It is important that r**,n **rin medical and mineralcgical facts of the situation be known and veil un .erstccd In the discussion preceding the proposed talc amendment it is sta that it is prudent to require that rale which is to be used in the manufacture food and food packaging be free of "asbestos-form particles". Certain .medical reasons for this judgment are given. Our studies of talc have shewn that great care must be taken to define the term "asbestos-form particle" in order to avoi prejudicial attitude toward the majority of the industrial talcs sold today, especially when so little evidence of physiological harm has been exhibited. It is true that no firm nirleralcgic definition of commercial talc exists today, but the majority of talcs that are useful in food packaging raterial consist essentially of the two minerals, talc and tremlate. Talc mines almost always contain a wide variety of silicate minerals, some of which are considered asbestos, as defined in the discussion to fellow. When true asbestos minerals are present, it is often possible to selectively mine the talc portion of the ores without extracting the asbestos minerals, and this is being done. ~ne tremolitic talcs used in food packaging materials can be considered to be truly free of fibre particles, and therefore, by inference, free of hazard in the particular context under discussion. What has confused the issue, both here and in the reason! regulations promulgated by ether government departments, is the pecuiie of the mineral tremolite in the category of asbestos. Ur.fort-unately.tr been portrayed, as a fibrous mineral more as a result of its similarity j.i c:.l composition to true asbestos minerals than because of any similarity ir. form. A study of the attached set of photomicrographs end a considerao following interpretation of asbestos mineralogy will prove that tremoli be categorized as asbestos without some sort of qualification such as asbestos" or "fibrous tremolite", with the true meaning of "fibrous" ur. properly defined. CRMC-MAD-000390 Mr. Alan T. Suiher, Jr. - 2 April 17 Asbestos Is a non-scientific, commercial. term normally restricted in use to the long, threadlike fibrous varieties of several hydrated silicate minerals, whose fibers can be separated mechanically and pressed, spun, cr woven into articles of all types that are resistant to heat and chemical accin. Alth present usage is generally limited to the commercially available silicate riera chrysotile, crocidolite, amosite and fibrous anthophyllite, ocher minerals regar of chemical composition, which possess similar qualities of greac elongacin, flexibility, high tensile strength, heat and chemical resistance, spir.ability, e could properly be classified as asbestos. The asbestos minerals mentioned above have non-asbestos counterparts of the same chemical composition and crystal scru which are far more abundant and widespread than the asbestos counterpart and occ as common rock-forming mineral constituents of many igneous and metamorphio r o d (see Table I). The crystallization of these minerals in fibrous form is a rare occurrence in nature dependent upon combinations of unusual physical and ch-arnica conditions during the metamerphism cf pre-existing ncn-asbescifcrm rierais. As shown in Table I, the asbestiferm varieties of the serpentine and anchbale mine- groups have, in part, been given individual names which, in themselves, imply ch fibrous nature. In the case of the three amphiboles, anthophyllite and actinolite which occur so rarely in fibrous form (all three acc r an estimated 1$ of the total asbestos production), no special name was given to th asbestiform variety, and therefore, a qualifying mir.eralogical term lite asbestos, tremolite asbestos ana actinolite asbestos must be u to that particular crystal form. TABLE I "ASBESTOS " KEISRAIS AS LISTED IN FEDERAL RESISTE?. Asbestos or Fibrous Variety Chrysotile Crocidolite Amosite ( ) ( ) ( ) Chamical Ccmoosition MgaiSiaOs) (0H)4 Na2Ee3Fe2(Si3022 ) (OH)^ (Mg,Fe)7(Si=022/ (0h')2 (Mg,Fe)y(Sis022) (OH,?)2 Po,,Mrr_(s-i-rud fnw Non-Asbestos cr Kon-Fitrcus Varie Antigorite, Linardite Ri eb e d i t e Cummingtcnite Anthophyllite Tremolite A.ctinoiite It is this lack of a special name in the mineralgica! and other literature, which caused, incorrectly, the inclusion of all forms cf anthoghylli tremlate, .and actinolite in the Asbestos Dust Standard (Title 2 9 , 07?. Part lylinstead of only the asbestiform varieties, as was undoubtedly intended by the fornulators of the regulation. It is obvious from the studious emission of the CRMC-MAD-000391 Mr. Alan T. Soiher, -Jr. -3 - April 17, 1973 non-fibrous varieties of the other asbestos minerals, i.e. antigcriti, riobeckit and cumraingtonite from the asbestos standard, that if special names had existed for the fibrous varieties of the regaining amphiboles, they would have been included as well, and anthophyllite, tremolite and actinolite would also have be omitted. This distinction between the fibrous and non-fibrous forms of serpent! and the amphiboles under discussion, is substantiated by the references cites. ir. Appendix A-l. The accompanying set of photomicrographs (Appendix A-2) illustrate conclusively the inaccurate placement of the mineral trenolite per sc in the category of asbestos. It would make as much sense to include the minerals riebeckite and cumningtonite in the category of asbestos, since the shape ana distribution of their crystal shapes are almost identical with those of actansla trenolite and non-fibrous anthophyllite. If we turn to a consideration of the medical aspects of th ii-C situation, seme light can be thrown on the reasons behind the indictment 01 J-C a suspicious mineral and tremolite as a "bad actor". As far back as 195 Dr. G. V/. H. Schepers reported on the effects of talc dust on the hum: study of tremolitic talc miners in Western New York State. Later, in the Ij-st's Dr. Morris Kleinfeld made epidemiological studies of talc miners and mil New York State. Although their findings were not conclusive, and no sci evidence of any carcinogenicity of talc per se was disclosed, they did t certain amount of suspicion on tremolite and talcs in general. Unfcrtur. these studies not only have cast a prejudicial light on the question of css_ response to commercial talcs, but have resulted in the lumping together of t and the "fibrous" form of talc with dangerous types of asbestos such as cr:c. that have been proven definitely harmful. It was because of the uncertainties of various epidemiological stu that Dr. W. E. Smith, working in the Health Research Institute at Hairlsigh LidUniversity in Madison, Hew Jersey, embarked on a project to study the carcir.:.;o of various mineral dusts, using the hamster as a suitable, experimental animal : A copy of Dr. Smith's report is enclosed as Appendix B. The tremolite talc { - - in Dr. Smith's project is a Hew York State talc containing 5G$ trendies, I d antigorite, 2-5$ chlorite, and 55$ talc, with a median particle sice of e.5 micr A photomicrograph of the sample reveals the usual distribution of rode, nodules, plates and short acicular particles characteristic of Hew York State talcs. lie lack of pleural tumors in animals injected with this talc is significant when a comparison is made with the results from animals injected with true asbestos. tore recently, Dr. Schepers, now Chief, Medical Services, a Veterans Hospital, Lebanon, Pennsylvania, has come forth with a new conoi of the relative hazards of various silicate minerals. Dr. Schepers has w letter (see Appendix C) to to. R. C. Bacon, former Director cf Mining d e R. T. Vanderbilt Company, Inc., in answer tc a request for the chest surg opinions on talc and asbestos in the light of all the investigations that place in this area since the early 1950's. You will note that Dr. Ici.cto: CRMC-MAD-000392 Mr. Alan ?. Eniher, Jr. -h - April 17, 1975 different ratings of hazard to each type of silicate mineral, and that trer_oiite comes closer to talc than to the true asbestos minerals. Vie find the some regard for the degree of hazard indicated in regulations concerning silicate and asbesto minerals in Great Britain, where experience with various forms of asbestos is probably greater and of a longer time period than any ether industrial nation. I not surprising that Dr. Smith finds a varied biologic response to different types dosages and shapes of silicate mineral dusts, but it is surprising and un fortunat that hygienists and medical consultants in this country continue to disregard the wide differences in degree of hazard of the substances for which government regui tions are laid down. In conclusion, it should be stressed that a valuable, economic product is in jeopardy of being penalized for lack of adequate' definition when no conclusive evidence of hazard has been disclosed. V.'e maintain that the trend found in tremolitic talcs is not asbestos ar.d, therefore, no^more hazardous than itself. However, unless a realistic definition of the tern "asbestos-form partic is rendered, not only a great portion of the pure talc being sold today but ait o those talc products containing even the slightest proportion of the talc-like mineral tremolite will be eliminated from food packaging materials. It is even possible to foresee the elimination of all mineral dusts from the role cf fillers and coatings for these materials if the term "asbestos-form particle" is misir.ter preted or stretched to include particles of certain shapes regardless of chemical composition. Very truly yours, R. T. VAIZDERBILT COMPANY, IRC. Allan M. Harvey, Manager Patent and Legal Liaison Department AMH: sb Enclosures P. S. In our original request for additional time in which to comment cn the prep talc amendment, we referred to proposed studies of talcs by x-ray diffraction techniques. Considerable work was done but no meaningful contribution to the pro of defining "asbestos-form particles"`was generated since this means of identific does not differentiate between asbestos-form and non-asbestos-form minerals. How since the proper identification of various types of minerals to be found in talcs normally used in food packaging materials is critical, our opinion regarding a satisfactory method is expressed in the accompanying statement (Arper.dix L,. CRMC-MAD-000393 Attoendix A - 1 Bibliography of Asbestos T e n s "In the mineralogical sense the tern asbestos is extended in part also to other fibrous minerals,, without reference to composition, structural cor.szii properties, and technical-industrial significance. Two main group entiated with respect to origin, mode cf formation, mineralcgical structure, composition, and properties of the asbestoses: namely, asbestoses (chrysotiles) and the amphibole asbestoses. The fibrou variants of the minerals have in part been given individual names the interest of a precise terminology, the word asbestos must nos For example, the fibrous form of serpentine is called chrysotile, asbestos, or fibrous serpentine - but IDT chrysotile asbestos. ~r. names of the five asbestoses used commercially are given as follow Grouu Designation of Mineral Desirr.ation of Serpentine Asbestos Amphibole Asbestos Serpentine Riebeckite 1 Gruenerite L-.-hiboles Anthophyllite Tremolite Chrysotile Crocidolite, Slue Asbestos Amosite Anthophyllite AstesTremolite Asbestos'"' *These varieties have no special designation." (Reference: Berger, Hans, trans. by Ralph E. Osper, Asbestos Eurf sals - Origins, Properties, Mining, Processing, Utilisation Uncstical Publishing Company, Inc., Hew York, 196p.) 2. "Asbestos is the common name given to a number of inorganic, silicate minerals that possess a crystalline structure. Chrysoti. abundant of these fibrous silicates and the one most extensively t industry, belongs to the serpentine group cf rock-forming mineral: mainly in Canada, Russia, and Rhodesia. The other forms of asbes: to the amphibole group. They are crocidolite, commonly imovn as ' which is found in South Africa; Western Australia and Bolivia; am: occurs only in South Africa; anthophyllite, the fibrous form of va in Finland and Africa; and the fibrous forms of tremolite (availat and actinolite, which has been found in South Africa. " " 'iAsbestos1 means any of the following minerals, that is to sc amosite, chrysotile, fibrous anthophyllite and any mixture contain: said minerals. " (Reference: Health and Safety at Work Asbestos Health Freer.'.:7. Derartment of Emoloyment, KM Factory Xnsrectorate, l:i 1971.) ` V. .--c:. C R M C -M A D -0 0 0 3 94 R.T. V A N D E R B IL T CO M PANY, IN C . Bibliography cf Asbestos Terns - 2 Appendix A - 1 3. "Asbestos, 'amphibole' asbestos, 'hornblende'.asbestos, and 'Italian' asbestos are various terns given to the monoclinic amphiboles, trameliae Ca2^5(SiB022) (OH,F)2 and actinolite, Ca(Mg,Fa)2(Si03 )4, when they occur in fine silky fibers." (Reference: Ladoo, Raymond Bardeen, Non-Metallic Minerals, 1st Edition, McGraw-Hill, New York, 192 > Ladoo, Raymond Bardeen, and W. M- Myers, Non-Metallic Minerals, 2nd Edition, McGraw-Hill, New York, 1951*) * * * * * h. "Actinolite. Calcium-magnesium-iron amphibole.... Ln crystals, either short- or long-bladed, as in tremolite; columnar or fibrous; granular massive... The fibrous and radiated kinds are often called asbestiform actinolite and radiated actinolite.... ASB23T0S. Asbestos. Tremolite, actinolite, or.d other varieties of amphibole, excepting those containing much alumina, pact into tier; varieties, the fibers of which are sometimes very long, fine, flexible, and east separable by the fingers, and look like flax. These kinds are called asbestos, (from the Greek for incombustible)..... CROC UDOLITE. 31ue Asbestos -- Probably to be considered as a fibrous variety of riebeckite. Fibrous, asbestos-like; fibers long but delicate and easily separable." (Reference: Dana, Edward Salisbury, A Textbook of Mineralogy with nr Pxtended Treatise on Crystallography art! Physical Miner alary, J:hr. hi ley Sons, Inc., New York, 19^7*) * * * * * 5- "Serpentine occurs in two distinct forms: (l) a platy variety, antirori which conforms in its properties to those of the phyllcsilicates, and :.2,' a fibrous variety, chrysotile."..."The variety chrysotile is the chief scarce : asbestos. Hie uses of asbestos depend upon its fibrous, flexible nature, vhi allows it to be made into felt and -woven into cloth and other fabrics, and up its incombustibility and slow conductivity of heat. Asbestos products, there are used for fireproofing and as an insulation material, against heat and electricity. Massive serpentine, which is translucent and of a light to dark green color, is often used as an ornamental stone and may be valuable ac but] material." (Reference: h'urbut, Cornlius S. Jr., Dana's Kanual of Kineralogy, iSth Edi ;le:. John Wiley & Sons, Inc., New York, 1971) * * * * * 6. "Amosite: A commercial term for an iron-rich, asbestiform variety t amphibole occurring in long fibers. It may consist of an orahor;..:. lie a , (anthophyllite or gedrite) or of a monoclinic amphibole (Cummings:nito cr grunerite)." CRMC-MAD-000395 M N D ERB I LTX'O'M PAN V.'TKTC BibliocTT3hy of Asbestos Terns -5 - Appendix A - 1 c+ b "Asbestos: A commercial tern applied to a group of highly fibrous si'-' ` minerals that readily separate into long, thin, strong fibers of sufficien flexibility to be woven,.... certain fibrous varieties of arrphibole... " "Crocidolite: A laver.der-blue, indigo-blue, or leak-green asbestiform variety of riebeckite, occurring in silky fibers ar.d in massive and earthy forms. Syn: Blue asbestos: Krokidolite." (Reference: Gary, Margaret, R. McAfee, Jr., and C. L. Wolf, Glossary of Gool: American Geological Institute, Washington, D. C., 1572.) 7- "Riebeckite also occurs as an extremely fibrous mineral, when it is known as blue asbestos or crocidolite. The best known occurrences of blue asbestos are in South Africa where it occurs in bedded ironstones, the seams of crccidtl conforming to the bedding of the ironstones. The composition of the crocidolit is remarkably similar to that of the ironstone and the crystallisation of the amrohibole, initially in the form of massive riebeckite, occurred with little no addition of material under conditions of moderate temperature ar.d pressure consequent on the burial of the ironstones to moderate d e p t h . .''Both Roaosrk (1928) and Hall (1932 ) favour the hypothesis that Wa2i was originally -onif.r:\iv distributed throughout the ironstone ar.d subsequently concentrated in certain bands. The later transformation of the massive riebeckite to the fibrous craoi may result from the instability of the riebeckite during a period when the iron stones were subjected to shearing stress.".... The members of the cutmingtor.ito grunerite series are typically found in both regionally and contact met arm27.hoc rocks. The more magnesian members are found also in seme igneous rocks, ir.clui those of hybrid origin. The asbestiform varieties amosite and mor.tasitc arc 0: economic importance."...."The characteristic habit of the members of the cvouiin ionite-grunerite series is acicular or fibrous. The asbestiform variety, am:.:! when fresh is ash-grey in colour; the mineral, however is frecuentiy coated wit iron oxides, when the colour is brown to yellow. The fibres of the mor.caoice variety are less harsh than amosite and are often soft and silky in texture.".. "The habits cf the anthophyilite minerals vary from fibrous and 'asbestiferm. to bladed and prismatic. The fibers of anthcpyllite asbestos generally do not have any great tensile strength and are of less economic importance than the amosite and crocidolite fibres.".... "Mass-fiber anthophyilite asbestos occurs as a replacement mineral in ultrabasic rocks at Ksmiah, Idaho (Anderson, 1557. ..... Laudermilk and Woodford (lJ50) have described an asbestiform aothcthyl.lite in veins in serpentinite at Coffe Creek, Carvill, California." (Reference: Deer, W. A., R. A. Howie, and J. Zussman, Rock Fcrmin: Volume 2, Longman Group Ltd., London, 1963.) CBMC-MAD-000396  ..........., .. , .......... .......... R. T. V A N D E R B ILT C O M P A N Y. I N C . Bibliograthy of Asbestos Trros -h - Asm endix A - i 8. "The principal minrala o? the serpentine group all have t; : p~r'::i" composition ^M-^SioC-,, eu i comparatively little substitution o; ooh or i-ono is found to occur in natural, specimens. The most well known set sentina rie-ral, chrysotile, often occurs in veins of silky fibers and is the most important source of commercial asbestos." (Reference: Deer, W. A., R. A. Howie, and J. Zussnan, Koch Fsrmir.r Minerals, Vol. 3) Logmans, Green and Co. ltd., London l $ o 2 . / 9- "MLneralcgically, asbestos includes the fibrous forms of amphibole; the fibers are generally very long, fine, flexible, and easily separated by the fingers; the color.... The term asbestos in the strictest sense is confined to the fibrous forms of actinolite, but the asbestos of commerce includes fibre', varieties of a number of silicates...." (Reference: Read, H. H., Rutley1s elements of Mineralogy, 2pth Edition, Murby & Co., London, 19? > J 10. "Tremolite does not break down into fibers that approach a uniform rectar.m cross section, as crodidolite does. Two samples -(figs. 9 and 10; indicate that the fibers break'into fragments. Seme of the fragments are quite thin, ..hile others are rather thick. The fragments are composed of thin sheets. Some of the small sheets (fig. 9) are so thin that they, are almost translucent to the electron beam. Dark streaks are again noticeable in the thin sheets of treat 11' as they are slightly wrinkled for 3ragg reflections. The thin sheets are pro cm: less than 100 A. in thickness." "Actinolite is generally considered the basic amphibole asbestos member. The fibers of actinolite are quite poor; and, because it rarely has commercial value, it is not very well known. The sample examined was splintery and very brittle. It was not expected that the mineral -would break down into fibers for electron microscopic study, but we felt it worth the effort to try, since it is the basic member of the amphibole group, figure 11 reveals that it id not break; intc single fibers. Low magnification was used, as the material broke into large, opaque pieces. " (Reference: Huggins, Charles W., Electron Micrographs of Asbestiform Minerals.. Report of Investigations 5551, Bureau of lines, U. S. Department os The Interior, 1959-) 11 "The name 'asbestos' is used to describe any mineral that break: fibers when it is crushed or processed." (Reference: Gaze, Richard, "The Physical and Molecular Struct: jf Asee: Ann. N. Y. Acad. Sci., Art. 1, 132, pp. 2J-30 lyo: CRMC-MAD-000397 Bi_blio--g7ra--ohvv--of Asbes-t--o-s--T-e-ri.m-s. - 5 - Appendix A. - 1 12. "Asbestos: 'Asbestos* is the name given to a group of hydrous marncou-m silicate minerals which have a. fibrous texture. The crystal structure of there minerals is characterized by the presence of long chains of silicate tetraheira which can be readily cleaved in directions parallel to the silicate chains out not in directions that cut the chains, with the result that these minerals car. be shredded into fibers..." (Reference: Kingery, W. D., Introduction to Ceramics, John V.'iley and Sent, Ir.c New York, 19oJ.) * * * * * 13. "Asbestos is not a distinct material but a commercial term used to express the fibrous nature of several, minerals. " (Reference: United States Bureau of Mines, Foreign Minerals Divisi n, .'an Raw Materials, p. 16, McGraw-Hill Book Company, Inc., > 1937. ) * * * * * ll. "Asbestos, any of several varieties of fibrous minerals whose fi be spun or felted to make fabrics, panels, or coatings that are recic heat and chemical action. Asbestos is also valued for its electrical properties." (Reference: Colliers Encyclopedia - 1972.) * * * 15- "Asbestos, general name for a group of silicate minerals that occur as fibers or fibrous masses and that can be woven into heat, resistant materials. The fibers are separated mechanically ana pressed, spun, or woven, often with cotton, wire, rubber, or cement, to produce ilreproof articles of all tyres: clothing, curtains, electric cable insulation, brake linings and clutch facingc insulating boards, sheets, shingles and talcs. " * *** 16. "Asbestos is a fibrous mineral substance... In its natural state, asbestos is found encased in rocks. Its fibrous quality makes it a remarkable mineral. Asbestos is as dense as the rock in which it it encased, but it is a mass of tiny fibers that become as fluffy and light at thistledown when separated mechanically from rock. (Reference Encyclopedia Americana International Edition / * * * * * CRMC-MAD-000398 r : t ^ a 'n d e r b i l t COMPANY, I N C . Bibliorranhy of Asbestos Terrs 17. "fibre - A fibre nay be defined as a unit of natter of hair-like dinencacns whose length is at least 200 tines greater than its width. (Reference: Enclyopedia Britannien - 1971*) 1 -Si CRMC-MAD-000399 2. M a r c h 23, 1973 S. Lincoln iV-onnc Lebanon, PA 17042 R. C. Bacon Director, Research and Development R. T. V a n d e r b i l t Company, Inc. 33 Winfield Street East Norwalk, Connecticut 06855 Dear Mr. Bacon RE: T a l c (0) T r emolite (H) , Chryso t i l e (2+) , A n t h o p h y l l i t e (3+) > A m o s i t e ('4+ ) , Crociuolite (10+) etc Thanks for consulting me about these items. As y o u kr.ow from my publications I have had considerable experience in decoding the biological action of the fibrous silicates. This is based both on elaborate inhalation experiments, human exposures with necropsy studies, and of course review of the literature. The order in w h ich I have listed these fibrous minerals represen!:, my interpretation as to their capacity for inducing biological responses. Talc is listed first and given a zero rating since it is.in pure form, practically innocuous except for overwhelming p r o l o n g e d exposure. The l a t t e r is n o `l o n g e r permissible in the USA so, for practical purposes, this substance is harmless. Crocidolite, by contrast, is listed last and given a 10+ or maximal rating. It can with relatively minor exposure, produce exceedingly serious and progressive changes in the lungs or wherever it becomes lodged. One of these effects is the capacity to produce neoplastic disease. Talc, Tremolite and Chrysolite need to be discussed a little more fully. Pure mineral talc of the non-tremolite kind, does not induce a tissue response of any clinical significance. If there is prolonged exposure the lung aleoli and some lymphatics can trap phagocytic cells which ingested the talc particles and this may block out their functions temporarily. This type of pathology is called a thesaurosis or storage effect. It is usually reversabic on cessation or decrease of exposure and no significant permanent after-effects result. The same applies for tremolite talc. It is inert.like Georgia talc.and induces only a thesaurosis effect when there is excessive pro l o n g e d exposure. However, Tremolite sometimes is "confamine ter.. CRMC-MAD-000400 atp e :: X-RAY DIFFRACTION ON TALCS AND TALC MINERALS X-ray diffraction studies of the sernentine polymorphs,' chrysotile, antigorite, and lisardite indicate that the presence of this group can be detected at levels of approximately 1 % in spiked samples but this presence in an unknown mixture cannot be verified until levels approximate 3-5%, particularly with the presence of chlorite group minerals. The individual poly morphs cannot be distinguished, fibrous vs. non-fibrous forms, until m u c h higher levels are o b t a i n e d (25%) and even then with difficulty. The same holds true for the amphibole group. At the Is level, the presence of a member of this group could he detect'd (or at least suspected) but higher levels m u s t be present before specific species c o u l d be i d e n t i f i e d . I n p a r t i c u l a r , it is v o r v difficult to distinguish between fibrous and non-fibrous forms of the same mineral by this method, i.e, crocidolite vs. richockito. Yet, X-ray diffraction is the only generally available method of qualitative and quantitative mineral phase docemir.aticr.rof industrial minerals. It is, therefore, strongly urged that X - r a y d i f f r a c t i o n s c a n n i n g b e d e s i g n a t e d as th e p r i m a r y s c r e e n in;: instrument in the detec t i o n of susoe c t e d asbestos minerals. If reflection peaks are present in areas which are indicative cf ser pentine or amphibole group minerals, light microscopy with a petrographic microscope should be used to identify the particular phase present and determine, if possible, its general r.orcholcgv, i.e. fibrous or non-fibrous. Further identification and merehological determination could be gained using dispersion staining arb phase contrast microscopy. CRMC-MAD-000401 R. C. B a c o n M a r c h 23, 1973 with chrysotile or other true asbestos type fibrous minerals. When this is the case, the thesaurosis becomes a thesaurismosis ie the alveolar walls and perilymphatic tissues begin to react, and fibrous tissue forms. This is due to the asbestos fibers and not the tremolite component. The fibrotic response is dire c t l y propoi'tional to the ratio of asbestos fibers admixed with the tremolite. You will note from one of my experiments that when small quantities of chrysotile were mixed with gypsum the chrysotile effect never-theJess prevailed despite dilution with the inert gypsum. This sounds like I make chrysotile out to be a bad actor. It is true that prolonged exposure to chrysotile will produce asbestosis but of a relatively mild kind. In comparison, however, with what Crocidolite does, Chrysotile is a relatively tame beast. There are a number of persons currently making excessive propa ganda about Chrysotile. Their noise tends to drown out the voices of sanity. The hullabaloo will of course go on for some time. Progressively, however, the evidence is coming in that Chryso t i l e causes only a fine int e r s t i t i a l fibrosis wit:'.out blocking off the respiratory surfaces. The patient develops some disability because of stiffening of his lungs, but can survive f o r a l o n g time w i t h fairly good gas exchange. I 'nave never yet seen a case of lung cancer caused by Chrysotile alone and no one else has ever been able to show me a case either. In mixed sequential exposure experiments w i t h beryllium sulfate as a potent carcinogen and Chrysotile as a potential co-carcinogen, the suprise finding was that Chrysotile acted as an anti-carcir.oge Of course, if one mixes Chrysotile with Amosite. Crocidolite or Silica exposures, ba d effects follow - read bad. Possibly this i.c why Chrysotile got a bad name. I hope this summary' is of help to you. If I can provide more detail, please let me know. Sincerely, t- \ - v ? -- GERRIT W. H. SCHEPERS, M.D., D.Sc. CRMC-MAD-000402 affe: v D X-RAY DIFFRACTION ON TALCS AND TALC MINKPALS X-ray diffraction studies of the serpentine polymorphs, chrysotile, antigorite, and lizaruite indicate that the presence of this group can be detected at levels of approximately 1% in spiked samples but this presence in an unknown mixture cannot be verified until levels approximate 3-5%, particularly with the presence of chlorite group minerals. The individual pclvm o r p h s c a n n o t b e d i s t i n g u i s h e d , f i b r o u s vs. n o n - f i b r o u s f o r ^ t u n t i l m u c h h i g h e r l e v e l s a r e o b t a i n e d (2 5%) a n d e v e n t h e n wii difficulty. The same holds true for the amphibole group. At the Is level, the p r e s e n c e of a m e m b e r of this g r o u p could, he detected (or at least suspected) but higher levels must be present before s p e c i f i c s p e c i e s c o u l d b e i d e n t i f i e d . I n p a r t i c u l a r , it is ve-rv difficult to distinguish between fibrous and non-fibrous forms of the same mineral by this method, i.e, crocidolite vs. rieheck Yet, X-ray diffraction is the only generally available method of qualitative and quantitative mineral phase determinati of industrial minerals. It is, therefore, strongly urged that X-ray diffraction scanning be designated as the primary sereonin instrument in the detection of suspected asbestos minerals. If reflection peaks are present in areas w h i c h are indicative, cf so pentine or amphibole group minerals, light microscopy with a petrographic microscope should be used to identify the particule phase'present and determine, if possible, its general morcholcgv i.e. fibrous or non-fibrous. Further identification and merrhological determination could be gained using dispersion staining phase contrast microscopy. CRMC-MAD-000403 R . T. V A N D E R B IL T C O M P A N Y , INC. 33 W IN FIELD S T R E E T EAST NORWALK,CONNECTICUT 00655 April 18, 1975 CABI.C Aooness ILt V A N n e w V O A Mr. Richard Carter Counsel Johns-Manvilie Corporation 5680 South Syracuse Circle Denver, Colorado 80217 Dear Dick: Paul Gibney asked me to send you our latest revision of the FDA talc comment. Attached are all documents except the book of microphotogr&ph and Dr. W. E. Smith's report, which I believe you already have. Very truly yours, R. T. VANDERBILT COMPANY, INC. AMH: sb Enclosure O JL Allan M. Harvey, Manager Patent and Legal Liaison Department CRMC-MAD-000404 The necommenditjoo, foe use ofour materiel, are be*ed upon tests betie/ad to be reliable Hoover wo do not the m utts to be obtJ-l it' * C.J. SuJevnki P.A. Martinson August _'1, ]07i TALC lj/vi>FuINTi II.II. Keefe and the writer mot this date with J.F. Solon, R.P, Carter, and F.M, Feunor. There is obviously considerable confusion on the total subject including the interpretation of the definition of an asbestos fiboi, It is recognized that the 1972 OSHA regulation clearly requires thuttalc containing asbestos fiber must be labeled. However, M.L.S.A., who hat published th e same definition of asbestos fiber as osm, has advised H.P. Garter that in all of the talc samples they' have analyzed thus far, they have detected no tremolito fibers in accordance with the unmibli sited and informal defini<..io;i of a fiber. Apparently, some governmental agencies interpret the definition in another manner than literally. Because of this confusion, Filtration and Minerals management to date has delayed labeling Desertalc products. In consideration of the many facets, including continued confusion, brought out at today's meeting, the vrt-ier is making the decision io further delay labeling to not later than November 1, 1974, providing a label is required and this requirement subject to clarification baser on investigations and findings as follows: 1. R.P. Carter to contact R. Bacon of R.T. Vanderbilt Company to determine status of visit by OSHA and HIOSH people to their plant for the purpose of taking samples for analysis. 2, R.P. Carter to contact Me. Boyd of OSIIA regarding talc sampling -- the source of samples - whether air samples (plant or mine or both, etc.). Also, details of methodology for sample evaluation, analytical or other. CRMC-MAD-000405 C.J. Sul ovsh i Talc Labeliii': jlngu-s(-- -Iy--19-7*- Villi the irforawtj on of Ttems -JI and mu! through Mr. Solon and his people, a decisj on vi !1 lm made vital fur Dior xumpl iiit needs, to he done in J-M operat ions -- plants or mines as v l i as fjni < product sumpling and evaluation -- the latter usin;; OSH mothodoiogv.--------- -------- ----- - -- 'ft;I'f -Ou r l.ej1VlTl~~rdTl.ov vi th OSnA/KIOSI! to determine results of sampling at R.T. Vanderbilt and determine if a.;? samjtl e analytical results are to be interpreted us representative of actual product samplin'' and evaluation. All of above in attempt to have OSUA/NIOSTI evaluate J-M talc on same basis as (bey evaluate R.T. Vanderbilt talc and for opinion from OSHA/NIOSII u s to the question of: Does J-M talc contain asbestos fiber in 0SIL\^20jSIlI^-pirR5i7" ` '----- ------ 1t is expected that guidance from Solon's people on Item I through h vill be available vithin the next 13 duvs and further procedural steps vill be determined and implemented and all advised accordingly.*V. cc: J.A. McKinney 51V F.L. Fundsack - USD J*F<. Solon,Jr. W V,L. YanDerbeek - 2S Dr. Faul Kotin E.M. Fenner - 4N _ ii R.P. Carter _ If V. B. Reitze . _ ff R. Se Lamar S. R. Speil - rsd ~ it W. C. Streib - it H.N. Havens T.M. Jackson C.I. Keelan F. D. Richards D C CRMC-MAD-000406 Johns-Manville Internal Correspondence to: MEMO TO FILE Date: Nov. 13, 1973 From r . p. Carter Copies File & C S ubject: RE; MEETING WITH JOHN O'NEILL - NOVEMBER 8, 197 3 MEETING WITH JERRY SCANNELL AND JOHN O'NEILL - NOV. 9, 1973 Several weeks ago, upon learning that John Stender had decided not to appoint a Standards Advisory Committee in connection with the reopening of the asbestos standard, I called Jerry Scannell's office for the purpose of setting up a meeting with Jerry to determine why this decision had been made and what Johns-Manville and the asbestos industry could do to assist OSHA in promulgating a new standard. Jerry Scannell was out of town on business in Hawaii for a period of three weeks and therefore, the meeting could not be set up until November 9. After a meeting was scheduled with Jerry Scannell for November 9, I was advised that John O'Neill would be delivering a presentation to the annual meeting of the A/C Pipe Producers Association in Washington on November 8. I attended that meeting and had the opportunity to informally speak with John O'Neill in addition to listening to his presentation. During our informal conversation, John O'Neill indicated that one of the primary reasons for Stender's decision against the establishment of a Standards Advisory Committee was due to the fact that if such a committee was appointed, Dr. Irving J. Selikoff would have to be included as a member of the committee. I got the impression from O'Neill that Stender felt that Selikoff's presence on the committee would impair the functioning of the committee. O'Neill further indicated to me that the thrust of the revision would be the establishment of work practices. I indicated to John that it could conceivably take several years to prepare work practices for each segment of the asbestos industry. John agreed, but indicated that they would attempt to prepare work practices by processes which were common in each segment of the industry. During our informal discussion, John O'Neill mentioned that he had read the first two installments of Paul Brodeur's series of articles in the New Yorker M a g a z i n e . John was not happy CRMC-MAD-000407 MEMO TO FILE Page 2 November 13, 1973 with these articles as it presented a very one-sided picture of the asbestos industry and was concerned with several unfavorable comments made about certain government employees. During his presentation, John O'Neill made specific reference to the unfair treatment of the asbestos industry in the news media and how only one side of the story was being told, which in his opinion, was quite unfair. During his presentation before the A/C Pipe Producers Association, John O'Neill was quite candid in his remarks regarding the reopening. I did not get the impression that John O'Neill was speaking from any prepared notes but was rather making off-the-cuff remarks. The key points covered by John O'Neill in his presentation were as follows: (1) The OSHA standard for exposure to asbestos dust was written only to prevent asbestosis and was not designed to prevent mesothelioma or cancer. (2) The new evidence w h ich O S H A now has is that fibers other than asbestos can cause mesothelioma. (3) The British data upon which the current OSHA standard was based is weak and not scientific. (4) OSHA wants to re-evaluate the TLV for asbestos. (5) When preparing the current asbestos standard, OSHA did not take into consideration the talc mining problem, He indicated that tremolite is not fibrous and it has not been proven that tremolite causes any harm. OSHA therefore, must re-examine the types of asbestos covered. (During this past Summer, R. T. Vanderbilt and Company, a major talc producer, filed a petition with OSHA requesting a modification of the asbestos standard, basically deleting tremolite from the standard.) (6) The method of sampling and measurement must be re-examineu. In a phase contrast system, it is difficult to differential and distinguish fibers. (7) The types of respirators permissible must be re-examined. As of April 1, 1974, many respirators will lose their current approval. CRMC-MAD-000408 MEMO TO FILE Page 3 November 13, 1973 (8) O SHA wants to re-examine monitoring. (9) Work practices must be developed, evaluated and made mandatory. (10) Asbestos is essential in many uses and OSHA has no intent to ban its use, R ather, OSHA is desirous of establishing safe ways of using asbestos. (11) John Stender has opted for the use of outside consultants in lieu of appointing a Standards Advisory Committee. (12) OSHA wants the new standards to be very clear. One of the strong reasons for reopening the standard is due to a large number of inquiries OSHA has received during the past year and a half for clarifications and interpretations of the standard. It is their conclusion based on the volume of requests that the current standard is not clear. (13) The current numerical standard will probably remain unchanged. (14) OSHA w o uld like considerable input from industry to assist them in drafting a new standard. On November 9, Jack Solon and I met with Jerry Scannell at his office. When we arrived, John O'Neill was also present in Jerry Scannell's office. Jerry indicated that he was currently in the process of preparing a written proposal to John Stender which would consist of a procedure to draft and promulgate a revised asbestos standard. This proposal would be in lieu of the establishment of a Standards Advisory Committee, in view of the fact that Stender had rejected the establishment of such a committee. Jerry's recommendation to Stender will be for OSHA to prepare a draft of a new asbestos standard which w o uld take at least three to four months. Then OSHA would use outside consultants, individuals picked from industry and labor, to be used by OSHA on an individual basis. For example, Scannell would propose contacting AIA to receive recommendations for individuals to be used as consultants. At individual meetings with these consultants, OSHA would discuss particular portions of the proposed revisions with experts in specific areas. After OSHA has met with these consultants they would then arrange to visit various plants in the asbestos industry to determine the practicality of the revised standard. Jerry Scannell indicated that he had CRMC-MAD-000409 MEMO TO FILE Page 4 November 13, 1973 received a ruling from their attorneys to the effect that such a plant visit could not be the basis for an OSHA citation. Jerry was quite concerned that various companies might object to OSHA's presence in a plant due to a possible citation exposure. Jerry would like every effort to be made by OSHA to insure their credibility with industry that citations would not be issued as a result of these plant visits. As a matter of fact, he would attempt to work out an arrangement with OSHA enforcement people so that no plant inspections would be made in those establishments visited for a period of at least one year after their plant visit. Following the plant visits, OSHA might perhaps meet on a group basis with all of the consultants for the purpose of reviewing a final draft of the proposed regulations. During the entire process, the proposed regulations would be revised and altered informally as necessary. The final step would be the publication of a new proposed standard in the Federal Register, which probably would not take place before a period of one year from now. At the time the new proposed regulations are published, OSHA might announce a hearing date at that time if they feel there will be substantial comments or objections to the proposal. Jerry indicated it was conceivable that if no meaningful objections were made to the proposal, no hearing at all might be scheduled. Towards the conclusion of our meeting, Jerry Scannell indicated that there were several things he would like from J-M: (1) A letter on how we w o uld like the asbestos standard modified. For example, what aspects of the standard are currently unclear or impractical. (2) Provide OSHA w ith suggestions for improving monitoring and fiber counts, perhaps including a proposal for scrapping fiber counts. (3) How can OSHA get Labor and Management together to discuss a new proposed standard without such a meeting being conducted on an adversary basis. (4) After Ed Fenner establishes a Technical Committee within A I A , Ed Fenner should contact John O'Neill to discuss whatever assistance the Technical Committee can give him in drafting a new standard. CRMC-M A D -0 0 0 4 10 MEMO TO FILE Page 5 November 13, 1973 (5) Jerry Scannell may need assistance from J-M and other companies in the industry in selling his new proposal to John Stender. In view of the fact that J-M and other companies have sent letters to Stender advocating the establishment of a Standards Advisory Committee, it might be desirable at some point in time for us to advise Stender that we support Jerry Scannell's new proposal. In this regard, it is my intention to contact Jerry Scannell at the earliest possible time to advise him that J-M fully supports his new proposal to Stender and advise him that we would like to cooperate in any way possible to assist him in selling his proposal to Stender. I will suggest to Jerry that he give consideration to arranging a meeting for J-M with Stender, at which time he should be present, for us to convey our support of his proposal to Stender. The timing of such a meeting should be left to Scannell. R. P. Carter P.S. - After dictating this memo, I spoke with Jerry Scannell by telephone at which time he advised me that he had presented his proposal to Stender and Stender had accepted his suggestions. I then asked Jerry if we should either write or call Stender for a meeting to indicate our support of their new proposal. Jerry said the decision was up to us but we should either call for a meeting or present our views in a letter to Stender. It is my present plan to draft a letter to Stender withdrawing our request for the establishment of a 15-man Advisory Committee and supporting Scannell's proposal. I intend to read a draft of this letter to Scannell over the telephone and ask his suggestion as to whether or not the letter should be sent or a personal meeting arranged. CRMC-MAD-000411 m Johns-Manville Interna! Correspondence fo: See below* From Paul Kotin, M . D . , 4M CopJ*: Subject F . j . Solon, Jr. R. Carter talc labeling *W. R. Goodwin, 517 F. II. May, Jr., 5W J. A. McKinney, 5W Date: N o v e m b e r 7, 1974 W8 m L. Pundsack, R&D C. J. Sulewski, 2W W. L. V a n D e r b e e k , 2S We have been informed by Mr. Robert Bacon, Assistant to the President of R. T. V a n d e r b i l t Com p a n y (a major talc competitor) that J-M's decision to insert asbestos caution labels on all talc shipments will result in "irreparable damage" to Vanderbilt. Mr. Bacon requested that this matter be brought to the attention of the highest level of management, and he stated that he was asking Mr. !Iugh Vanderbilt, P r e s i d e n t of R. T. Vanderbilt, to call a senior officer at J-M to voice their concern and their belief that it is J - M 's intention to hurt their company. The purpose of this m e m o r a n d u m is to alert you to the situation in the event you are contacted by Mr. Vanderbilt. Our decision to label talc was based on our conviction that J - M 's talc contains fibrous asbestos and in no way reflects any intention to hurt or destroy the Vanderbilt Company. If you would like additional details on this matter, please call me. CRMC-MAD-000412 I C.J. >1:! i,i !' , \ . Mi 1 ! 111 ni A11;11-1 .M, l'.'V'i TAI .<: LM.I.I II.).', 'IO e i e ;i ! i h e v. r i i v r ilio I i b i ' l l i . l r r i I 1, . i . r . It i 1e , i n n i l . , M . l e n i i i , ') ! ' T i ' i s o l n i Oii . 1.1 t 0 [ 1> (li : J a li ) , * ( di i l i ! i n o t>` i D i e 1 n i a l - n i i I n- 1 m i i l i ; 1 l i t e i iii l i J p i r 1 i ol i a l i i 1( (Il * i 11 ' 1 1 ol i o 1 Oli il I . , ' . Il 1 i 1 C( i n ; / ( ' il1 i hot I li* 1174 r - li . r t p i u l i 1 i ni ; e 1 e i i r 1 \ r e i l i i i c e 11 i 1 ; ii i o - Co I o 1' i b e r ' , 1 1 in l a b l e d . I l o ,. e \ ' T , v h o li;m |>llb 1 i y o r l l . r n b. n a ; 1 i " fi I i. a- , l.o. l' i Ile r .i ( ni v i s e t i I b i ' , ( ' o ' 1 ( r : i r i. { o a ( 1 ' i ! f . K I . i l C .- ii tip l e - ; l e ( ' p l . I m ' I n r , i b i : V ! r \ r d e i . r t . e d n o ( JM,:.m i i i e l 1 11e i l o a e i o--M U l u l i l i ' i 1 - i ' 111 : i ' i 11.1: C :',-L l _ j ' c L l i j . ; . ( l ( : i r : ; . r . \p;i; ri n ; ( o v e n i 'i " 0 1 | 'r r M j li- ' ii" i . i ! 1 I ! ! ' : i .i ! , I , a n o ( Ve li. l ei-a 1 r lin eale - e (il III i > r ' M i " (In l e In, y do 1:i\ i-d 1 1 OM, 1'j 1 f i ; \ * ' r>11 m I : i i 1i io r i i 1- j I l l M . ' l , , . 1 ( ! 11 M i n : i ;;i; i o 111 CO' !,- i 1) e o e ; : li 1 l in i !km a 1a b e 1 oli i n v e <]' r i i ! i o:,i n r M o t,', 'n . v l ' i i e i . . . . i ! i r 1 n j ; ii ; ' OMl ,i i ( - t \ ' *. t,11'!' 1 i l " ' . , ; 1i > -' ; o : ! ,! t i r i n y 1 C r i I : . 1 (1 : .(i 1 i o ! ; r ; ri . ( i ,. l'd.o | y r ' -ii*; 1 r >1 . o r i (M 1 1 ( -111i i < ,'!(' ! ! 1 .- r .!'( i l i i ' U l >o r :*!!'] |- i m i l i " fi il - r M I t (|\| .; : :, ! i m i , : 0". i i r * 1 . 1* < ' lo fi i i ! 1 . K . 1 ' . Ci n r i l o ( i r 1. II. U t ' i u 1' H . i \ : 111( i b i | ! ( l e t o rni i n o s 1 o r \ i : i 1 b \ il.' 1 V e n d \ , f II.'di 1i n o | e 1 0 p l a n i l ' o r i h r ; ` *.i j iii 1- r o !' 1 il' i ; ' n. pl i. 1o r .i n o ! v i . U . b . l ' . v o t i , : t n < Mi. i,.< i I r . !.. \ .1 O 1 o. - ; i A i i :.;i i d i l e t r l r I b e : ou r r r O 1 . . . . . . | -- w'1r i : i , , i ! i ' .; . ; , ( n i T l ! ,, or ri)' 1'' I *IiH *iI I I m,.i|\ i1. CRMC-MAD-000413 C.J. Nulew-I.i T i i l c I.lllie I i ii/' -1 :m , r/, IV. . \ \ i i 11 i i i i ..........: i., I i "U n i i i i '.i - I li i |> 111 ! r . .i *1<m i - i c.t i- i ! I in- t o in ti n' / 1' i .: ' ................... " ! 1 i! ji e< ni il e i . ..nu .v . i . l i n , ' me I li ei ' i I " " . ; ! i ! . i i ! m i i i I. * ! I!\ ie,|t.Il . inIne m i ! ........ ...Il,.| d i 11 e l 11 I I I :lI ie n I ., II ii.n 'II' Ilr.il 1(.; i:i ,n Al 1 n i ' ,l 1in \ . i i e i i . .t.jil I n !i . \ e ( i 1; . ; 11 ': \ i - ' l 1 . ' le. , n - 1 i.e \ . '. . ! < ' !'. 1 . ' . . . . r i : 1 n , . 1 ; . ` 1 i " <- ; i ( I M , T.' . Il . I l r 1 r . " 11 n i 1 i in i n i : / 1. r , .1. M u l i r t i i : 1 ;i ' 11 ! ` ' i n (K M \ / M II '1 1 , ]. 1 11 i n i ; V J 1 i e e \ | i r e 1 e . i 1 1i . , 1 ; n i il . i n <! i enill S u 1n 11 ' i | , (* u 1' r m , 1 1 r \ t > l \ . i 1 1 l i e <i\ n i i ;i' l e \ i t 1 i 11 1 11e 11' \ 1 I n l i. . u n 1 1 11 i 11.: I' j)l M' . ( ` , , 'I (, i li.- \ . i 1 1. l i e d e 1 i i i l i i K' ll I I H' I i l i i n i enli . .1 m l . i i i ' l a 1 1 m i \ i e v (1 i r -,ii 11' " ci: : J . A . MeKiuiiey F . L . l 'm u t a e l . J .F , Soi on,O r. W .F . ViHiDci-l.eeU D r . P u , i l Ko ' Lu E.M. F en n er n .P . C arier W.li, liai l/.t' It.S. Lannr S .11. S p e i l W.C. S l r r i b 11.N. H a rem s l`. M , J a c k s o n C .1 . K ee1an F . l ) . H i c h a r il s 1) c _ fW - clJ) - hX - hX - 1t - M -- n - RI) - n - H C R M C -M D -000414 Continuation Sheet Schedule Name of Offeror or Contractor Ref . No. of Doc Being Cont'd tonm S f 7 7 - C - S 7 1 Page 8 SECTION I - INSPECTION & ACCEPTANCE 1-1. INSPECTION AND ACCEPTANCE POINTS: [ See Section E, hereof [ ] Origin, Item(s) _____________ [ ] Destination, Item(s) ______________________ I-2. INSPECTION SVSTEM/QUALITY PROGRAM FOR NT;! MATERIAL: a. The Contractor shall maintain an Inspection System/Quality Program in accordance with General Provisions clauses in Section L hereof which are applicable to this contract. In addition the following Inspection/Quaiity requirements shall apply: b. [ ] 100% End Item Inspection (Applicable if checked) c. (X) MIL-I-45208A 1-3. INSPECTION NOTIFICATION: Government inspection is required during manufacturing, the processing of material, or the performance of a service. Upon receipt of th contract and prior to the start of work, promptly notify the Government Quality Control Representative of the office to which the contract has been assigned for admin istration. NOTE: If surplus material is involved, refer to 1-4, Inspection and Acceptance of Surplus Material, for Inspection and Acceptance criteria. OC/UCF/I-1 77 APR 13 CRMC-MAD-000415 Continuation Shoe!'.' j-l<i*Tilo of Doc Being Cont'd Page Schgdy-1e _ _ _ _ _ _ Name o f O f f e r o r o r C entrai*t o r Contract 'lo:. s e c t i o n ) - M . s ^ c c v ; n t t . t ki i > - ; r i ns t ruct i o n s for r t r r ia l i u s cu c t: ch ?; r e c t i v i n g KCi'wu'ih \i rpE.3 30): The :>? F-jrms r ? o r e q u i r e d by th e c la u s e o f th e c o n t r a c t (.-cl i t le d " M a t e r i a l Inspect, ." i end '-* ' " port" w* 1 ; I r fo rw a rd e d 1e V a V ! luv'ir.p a..: ' * :.'-a.j i nu ufi'i'-.e copy to thy ?11u r i il-.; l . ^ y ... i ` .c r \ o t Procurer`'ri. U ", r . r, '=L.y h r- Loou-tic.:-. ce n to : ! T i-i ' \ i i .'ce base, h : -o ?50 mu.V* O ffice ' U'vW t.V -1-t-0 -c is a t d e s ti n a tio n . -,. /* i s and one; cecy musi. U i ; ;:'t v d . ro ve r jury-.. ' (4', com e: et tu'0 nn Porm \ ' r i ' r,.!.'1 : . a t i or. These S;J ic i where ;; ~. t r . Seven ;TOa '.. , '* '''!) ;'r. i ! r, * .t ru o ti on F w i ll be in c i t h - .ut'COtit-.*Ct > uro te : ; -, V:.y ;,of.:*r. e t he round e.. -.; t;tc i dinc.ci.ly to the [ J .1- j . t r i" . ` >';y... f**VfUtC. : (1949 Jt.iL \y , . ( v v ' . i ' . ?r. iM,ecK is ched..d. ) asf;-. o Tti'.'. M .itr ...y j 1 : i be s u b je c t ;0 t.hr ve' i : \ - y ' OjVi; ovi C'; tiifi te r ro ta ry o r his & s ! y uui.h V' K 'oru n te ti ve an r ha l ' so: *j * y *;,u r.9 u s i1'1 per ll-. j ; ; : v . 1 ,j7n . y n r w s n is r .i'c TIOMS - Far. , v;c p t V/' 'v / s r :*-1 \ *unis clause the ron-ec i V . ^.; >' f i rei- ;r y fu rn is 1; t :V. * * >.*S, ih 1' t i s i o r amendso s t . ; t ;.! . "r.st! 1 ` '* '.i to cot j..1 * ' i'*' *\ ! :,'*l i r.c >j,y '': u o tio n y . 4 ;ni laccio; i :! h re f o r th j !j un' n./S C in ! r 0 0vner c e n tra c i t a l dec unie; t. v i ; '< i'.c re j ' Ut -. r-v tim o r i rr-ndments vi i': bu used (h) contractor s h a l l com ply v rith su ch iia .t v e o i. i c r i s <v.ui i t w i l l be assume:', tr..v,t tir:-".a it *; adjustment In the contract r*"co deli(.ry schedule. (o) If -.ic- fontracter takes exception to --s:'.oipnlishiny the hi root ions received at no che.;K in pi ice or delivery schedule, he shal I so advise the contraction office"' within thirty (30)____________ days after rr.eelot of the SF30. The contractor shall**pV<vveed 'with directions given in the SF.l'), and submit any claim for equitable adjustment pursuant to the "charges'1 clause cf the contract. The negotiated sett!utrcnl of such claims shell be reflected in i Supple-mental Agreement- id) The ror tractor agrees that no claim for adjustment shall be submitted if he nas net so notified t h e PCO within said thirtv 130) day period. ---------------------- oc/ucr/.!-! C R M C -M A D -000416 77 MAY 5 COPY October 9, 1974 Mr. H. B. Vanderbilt President Chief Executive Officer R. T. Vanderbilt Company, Inc. 30 Winfield Street Norwalk, Connecticut 08855 Dear Mr. Vanderbilt: This is in reply to your letter of September 26, concerning your r e q u e s t f o r ralief from the asbestos standard for your talca containing non-fibrous tremolite, actinolite, and anthophyllite. ....B ? 'Jl!ETLll UJL form the scope of the of that standard minerals. FLii j n u ll / nt nfrnfl i Vi i > ii.uiI. f ttJlUUSI jy n m F c L b U b s t i fflLliw asbestos standard and, therefore, the provisions do not apply to talc containing non-asbestiform NIOSH is currently conducting a thorough investigation into the exact minerals to which talc workers were exposed in those studies where asbestosis or other adverse medical effects were found. Ponding the receipt and evaluation by OSHA of the report by NIOSH on this investigation, if you have scientific evidence that the naturally occurring t alcs, prior to processing by milling or crushing, do not contain fibrous or asbestiform tremolite, anto- phyllite, actinolite or other asbestiform minerals, you may certiT7" 111) . Fibrous, asbestiform minerals such as fibrous tremolite means naturally occurring asbestiform minerals which prior to or after Sincerely, /s/ John H. Stender John H. Stender Assistant Secretary of Labor p 147827 CRMC-MAD-000417 CAPABILITY OF EMVENTIONS. INC FOR ASBESTOS DETECTION AND ESTIMATION EMvention, Inc. is a company founded around a fo rm er Sperry Rand laboratory. The new company retained the technical staff and continued the programs in electron microscopy which involved technical and instrumental innovations and problem solving in m aterials and biomedical areas. During the past few years our laboratory has become involved in the detection and estimation of asbestos in water, drugs, and the environment for U. S. Rubber Reclaiming C o ., Vanderbilt, Johnson & Johnson, Diamond Shamrock, Donaldson, and the Food and Drug Adm inistration. In addition we are now carrying out an academic investigation of asbestos in w ater samples with D r. Henry Wehman of Rosewood Hospital in B altim ore. Our capability in the area of asbestos detection has been enhanced by acquisition of two new scanning e^ctron microscopes, one of which has high resolving power (< 100 A) and energy disper sive microanalysis equipment. Following i s a description of our technical approach and the capabilities of our staff and consultants. 2~31 SHADY GROVE ROAD ROCKVILLE. MARYLAND 20850 (30U 94S-543-' CRMC-MAD-000418 MICROMETHODS FOR ASBESTOS SAMPLING Prepared by: EMVENTIONS, INC. Microanalysis Laboratory 2351 Shady Grove Road Rockville, Maryland 20850 (301) 948 - 6494 CRMC-MAD-000419 e n t r o n s INC MICROANALYSIS LABORATORY ASBESTOS Asbestos is the name commonly used for a group of silicate minerals which occur naturally in fibrous aggregates. These hydrated silicate minerals have the following common properties: have good electrical and thermal insulation properties, can be separated into fine fibers which can then be spun and woven into fabrics, are resistant to chemi cal attack, and can be fabricated into a wide range of forms easily. Mineral group Serpentine Amphibole Variety Chrysotile Tremolite Act inolite Crocidolite Amosite Anthophyllite Structure Chrysotile asbestos has a sheet structure in which there are continuous sheets of Si04 tetrahedra with each tetrahedron sharing three oxygens. The amphibole asbestos occurs in a chain structure in which there are continuous chains of S O 4 tetrahedra. The tetrahedra share alternately two and three oxygens. Chemistry Asbestos Type Serpentine Chrysotile* General Formula Mg3Si205(OH)4 Amphiboles Actimolite Amosite Anthophyllite Crocidolite Tremolite Ca2MgFe)5S8C>22(OH)2 (FeMg)7Si8022(0H)2 (FeMg)7Si8022(0H)2 Na2FeFe2S8022(0H)2 Ca2Mg5Si8022(0H)2 * 95% of asbestos used inthe United States. In addition to the above elements trace amounts of other metallic elements can be found in chrysotil and the amphiboles. 2351 SHADY GROVE ROAD ROCKVILLE, MARYLAND 20850 (301) 048-6494 CRMC-MAD-000420 TECHNICAL STAFF OF EMVENTIONS MICROANALYSIS LABORATORY J A M E S H. NIC A L E A R (Fh.D. Biology, Harvard '58). President. D r . M c A l e a r is a well-known electron microscopist and the author of n u m e r o u s papers on biological ultrastructure and techniques. In addition to his capabilities in determining the biological affects of asbestos, he is particularly concerned with development of methods for quantitative auto mation of asbestos analysis. J O H N M . V E H R U X G (M.S.E.E., George Washington '65), Vice President. Mr. W e h r u n g is an established expert in scanning electron microscopy (SE?.I) and. as former Director of the Sperry Fvanu Microanalysis Laboratory, has experience with over 300 customers in materials and biologic disciplines. In collaboration with industry and government, research agencies he has pioneered in the application of S E M to asbestos detection. R I C H A R D J. H A R N I M A N (3. A . Biology, Hartwick '68). Senior Associate. Mr. Harnimar. formerly applied scanning electron microscopy techniques to materials anc microar.aiysis investigation for four years with the U S A F in N e w Mexico. Presently he is responsible for imp l e menting the asbestos research p r o g r a m and carrying out the observations and estimations of asbestos. J. T E M P L E T O N S P A R R O W (Ph.D. Textiles, University of Manchester England '72). Staff Scientist. Dr. S p a r r o w is a co-author of a recent treatise on " T h e Uses of S E M " , P e r g a m o n Pre s s 1972, and has over five years of experience in applications of the S E M to fibrous materials. His background provides an unusual capability in basic research on the ~ nature of asbestos fibers using a materials approach. L O U I S T . G E R M I N A R I O {Ph. D. in Biology, Catholic University expected October 1973). Staff Scientist. M r . Germinario has been involved in the development of S E M methods. Recently he has developed a scanning transmission capability for the estimation of asbestos in the S E M . This method duplicates transmission E M methods and incorporates m a n y of the advantages of the S E M such as rapidity of operation and microanaiysis. This is of great importance in quantisation of asbestos. A D D I S O N R . K E T C H U M (B.S. Civil Engineering, Union College). Vice President. M r . K e t c h u m is a f o r m e r A r m y officer and industrial executive with experience in the use of asbestos products in vatcr end sewer facilities. He is particularly concerned with the practical aspects of civil engineering as applied to the asbestos pollution problem. CRMC-MAD-000421 MICROMETHODS FOR ASBESTOS SAMPLING METHOD Light Microscopy INFORMATION PROVIDED Opaque morphology COMMENTS Resolution limited to >0.2 micron. X-ray Diffraction Lattice structure Bulk sampling only; 2% detection capability. TEM Electron Diffraction Morphology; 'hollow core structure Resolution < 5oX ; specimen prep aration difficult, time consuming and susceptible to contamination. Lattice structure Specific but critical operation. SEM Energy X-ray Analysis STEM 3-D morphology Resolution *e 10o5l; rapid, direct examination; little specimen preparation. Chemical analysis Rapid; specific for Mg, Si, Na, Ca. of individualfibrils Fe. Morphology; hollow core structure Resolution 75$ ; specimen prep aration difficult, time consuming and susceptible to contamination. Method 3 o r 3,4 suitable for identification. Method 5, 6 or 5, 6, 7 suitable for identification. 000422 CRMC-MAD 2351 SHADY GROVE ROAD ROCKVILLE. MARYLAND 20850 1.301) 948-S494 CRMC-MAD-000423 K/ * Sot Subj Coaaander, Havel S u Systems Coanand Commander, Mar* Island Haval Shipyard 05D2/6101C/JJT 9631 . 8r 55 m 30 MAY Asbestos Contrat of Magnesian Silicate Rsv Matarais Usad In Manufsatura of MIL-P-24441Bpary Coatings ftef: (a) HAVSBC Project Ordar H6519779P090020 1. It Is requested that Mara laland Haval Shipyard (HAVSHXPTD Mara) evaluate magnesium alllcate frou: SU T. Vanderbilt Co* CSytal 300) yi Pflxer Co. ( Minarais 6 Plgnrats (CP 20-30) i Cyprus Mistin Desert Minerals Talc Co. 039) (By-Una 80) to determina asbestos fibercontrat. 2. Although traaollts Is theAajor ulnaral fiber In asbestos, other min eral flbera areychrysollta, aaoslta, crocldollta, anthoplyllte, and actlno- llta. These^fibers are to be" Identified also and. If present, reported along ulth traaollts ' 3. The aagneelua silicate plgarata of paragraph one (1) shall also be eraluatedaphyeleallyAandschaalcally. In partlenlar, oil absorption should be daternlned and comparad to *the material used to sake reformulated K3L-P-24441 aaterlals, l.e. Pflsar Cp. 20-30 magnesium silicate. ihrashie effort Is vlthln the scope of funding of reference (a). A.T . A M O P H O H dieofiK Blind copy to: NAVSEA 05D23/6101E 534/6159C 921TH3 Prepared by: John J. Tock/05D21/6101C/20214 Typed by: L. Sendsjo Hager/24 May 1979 C RM C -M A D -000424 B 09398 I. Revised 1975 Talc Forecast vs. Original Plan Grade Std. Grind DT-51 DT-54 DT-55 DT-84 D-H2 Fractionated Hi Press Hi Fine 80 Micronized DT-57 DT-506 DT-507 DT-706 DT-707 Cyclonized Cyclo-Fil Cvclo-Sorb Clay PV #1 PV #3 Crude TOTAL 1975 Original Plan Tons $ 14,600 1,150 775 400 2,500 $ 775,900 64.400 44,950 22.400 100,000 2,500 1,900 107,500 125,400 3,100 200 650 250 750 285,200 16,800 64,350 22,500 72,000 5,000 5,-000 485,000 *w v t w v sj 6,000 800 3,000 49,175 303,600 40,000 69,000 $3, 049,000 1975 Forecast As Of 4 /1 / 7 5 Tons ~ ~ $ 1 19,600 1,150 775 400 2,500 $ 921,200 64.400 44,950 22.400 250,040 2,500 3/400 105,000 221,000 1,600 200 650 250 750 2/500 3/500 144,000 16,400 61,750 21,500 69,000 235,000 315,000 6,000 800 3^/200 47,775 270,000 37,600 120.023 $2,919,263 CRMC-MAD-000425 II. Revised Sales and Net vs. Original Plan P U N N E D EARNINGS- DIVISION Division Date prepared. For Original Revised C Plan C Plan % % OftO&S SALES TO C USTO M ERS 3124 4/1/75 TRANSPOR TATIO N RETURNS D IS C O U N T S ALLOWANCES 45 . 30 SALES TO OTHER D IV.FO R USE NET SALES VALUE STO. COST SHIPPED EARNS. A FTE R STD.COSTSHP. 3047 2194 855 2919 1815 1104 NON-STD. PLANT COST O PERATING VOLUME TR A N S F E R R E D -N E T TOTAL GROSS EAR NING S 161 5* 156 699 515 " 568 D ISTR IC T EXPENSE SALESMEN SALES O FFICE IN T E R -O IV . COMM. * WAREHOUSES TOTAL EA R N IN G S A FTE R DIST. EXP. GENERAL & A D M IN . EXPENSES D IV IS IO N A D V E R TIS IN G RESEARCH TECH; SERVICES ENG. & TECH. PROJECTS D IVIS IO N A D M IN . TOTAL MISC. INCO M E & *O E O U C T. D IV IS IO N O PERATING EAR N. COMPANY A D M IN . & A D V ER T. 62 88 " I T 1,1 167 532 20 - Ill 50 30 105 316 15* 201 156 60 O f\ V u Id 164 404 20 -- m-- 5o 30 : loo 311 15* 78 150 .197. r i % 1 . * .. j -------------1 PRE-TAX EARNING S INCO M E TAXES N ET EARNING S 45 (72) 9 15 r^r> a /rr^ A A T-\ r\r\r\ 36 (57) *1 ;stiilated by Il . K. Comann .ncliides non-s tane ard costs -H III. Influences External 1. Labeling-- During June of 1974 we discussed with various customers the possibility of labeling our talc products. This resulted in an immediate loss of some accounts. Letters were sent to our customers advising that the label would be affixed to our bags effective November 1, 1974. These letters were sent out in September of 1974. The results of the letter in September and the actual lab ling November 1 caused a further loss of customers. Our estimate of lost business on an annual basis was approximately 30 percent of our tonnage and 40 percent of our dollar volume. Please refer to my attach ed letter to P. Kotin which shows this effect. R. T. Vanderbilt and Pfizer (California talc) are not labeling. R. T. Vanderbilt is certifying their talcs are asbestos-free, but we have no knowledge that Pfizer is doing the same. We feel that Vanderbilt and Pfizer (California talc) will be required to label before the end of 1975. The adverse publicity generated concerning asbestos and tremolite has been such that even if we could remove the asbestos label from our talc, it would be some extended period of time, possiDiy a year or more, before we could regain business lost to asbestos-free talcs. 2. OSHA and NIOSH-- Jointly studying asbestos in talc. OSHA has requested NIOSH to study asbestos in commercial talc, and NIOSH is studying asbestos content of talc mines with MESA. NIOSH considers all particles of chrysotile and the amphiboles that have three-to-one aspect ratio and over 5 a as asbestos fibers. We expect increased activity from state (particularly California) OSHA offices on our talc customers because of tremolite. 3. FDA-- Does not appear to be a problem at the moment. Their position stated in the Federal Register March 14, 1975 withdraws their proposed ban of talc in food packaging. The proposed ban drew attention to asbestos in talc and we will have an uphill battle to get back market share we lost. CRMC-MAD000427 4. General Market Conditions-- See Talc Sales attached a. Olir c e r a m i c a n d t i l e b u s i n e s s r e m a i n s r e l a t i v e l y strong in spite of our problems. b. Paint is weak due to the economy and our tremolite/labeling problems. c. Our plastic business has all but disappeared due to the tremolite problem with the exception of Solo Cup which we started to sell in October of 1974. Solo remains strong but tremolite and the label are an ever present potential problem. Competition from Pfizer is fierce but we manage to hold on because Solo likes our product. d. Tremolite, the label, and quality, plus a poor business climate have combined to hurt our sales to the paper industry. Competitors from Montana talcs have been only too eager to point out to our customers that our talcs contain asbestos fiber. This is very rough competition, and coupled with the economy and quality problems, makes for difficult marketing conditions, to say the least. e. Price increases--We had planned a six percent price increase for talc on an annual basis. Vie have implemented a three percent (annual basis) increase and have met great customer resistance. It is doubtful that a six percent will be achieved in 1975. A decision to label by Vanderbilt and Pfizer could reduce the pressure on Desertalc and allow for selective price increases. Internal Influences 1. Ore Quality and Control Related to F.P.S.-- The problems with ore quality came about when we were forced to above ground mining. The lack of selective mining has caused virtually all of our problems con cerning brightness and acid solubles. The Mining Division is formulating a mining plan which should be completed soon to alleviate this problem. Problems encountered at the milling locations resulting in inability to meet F.P.S. stem primarily from the crude ore being shipped from Warm Springs. This, hopefully, will be corrected by the mining plan mentioned above. Other quality problems were caused by grinds being too coarse and poor plant management. Plans to train and adequately staff quality control personnel have been put into effect by Mining and Research. Plant management and supervision should improve dramatically when the Mining Division implements their new organization plan for Desert Minerals on April 1, 1975. IV. Action That We Plan to Minimize Unfortunate Influences Tremolite and the Label-- We are and will continue to educate our customers on the necessity of proper dust control not only for asbestos fiber, but for all dust which is required by OSHA. Our industrial hygiene studies are very helpful in this respect. We believe and are attempting to convince the customers that they must clean up their plants and control dust to comply with OSHA regulations. By so doing, he eliminates the problem of asbestos. Wherever possible, we discuss bulk shipments to avoid dust problems. B, Ore Quality-- This problem is critical and compounds our problems with tremolite and the label. We are in constant contact with the Mining Division and communicating our problems in this regard. The formu lation and implementation of a good sound mining program, properly supervised, will eliminate this problem area. C. Quality Control Problems at Grinding Locations-- G o o d quality crude is paramount, as it is the one area that the grinding plants have no control over. The training of plant quality control personnel so they know what they are looking for and can interpret their results properly will alleviate the problems of coarse grind. This, with better plant management which should be accomplished with the new plant organization, should reduce these problems to a minimum. T. E. Remmers has been assigned the responsibility of the key marketing liaison person to work and communicate to the Mining Division and to follow problem areas through. V Recommendations The initial crunch of lost business due to the label has been felt. Our business seems to have stabilized. We expect further erosion in paint and possibly the loss of Solo Cup in plastics. Our ceramic business remains strong. We believe we can regain some lost paper tonnage with improved quality from Warm Springs and the grinding locations. During April we will phase out production from Los Angeles and move all production to Dunn. Some Cyclo-Fil may have to be made at Los Angeles on an intermittent basis due to capacities at Dunn. The consolidation of virtually all production at Dunn will cause Dunn to run at capacity for six-day weeks. The concentration of managerial personnel at Dunn should improve the plant's efficiency and eliminate CRMC-MAD-000429 many quality, shipping, and outage problems we have been experiencing. The costs used to arrive at net earnings with the revised forecast were submitted by the Mining Division. The cost includes the fixed cost for the Los Angeles Plant, which are estimated at $200,000 per year while closed down. If we were to dispose of this plant the fixed cost would be eliminated. The cost of operating Dunn and Warm Springs, in my judgment, appear to be overstated. We have never operated Dunn at full capacity with full management capa bilities which should insure better efficiency. We believe we still have a 45,000-plus ton per year business. Mining Division believes this business concentrated at Dunn will improve our profitability. We would like to stay in the California talc business at least until Penhorwood comes on stream, to maintain continuity in the market. The Desert Minerals operation should be reviewed for profitability progress after May results are in. If this business, with the changes contemplated over the next two months, can be made profitable, it will remain a good small business as Penhorwood should have virtually no effect on Desert Minerals. c r m c MAD .000430 To: P. A. Martinson - 2W Dato: March 20, 1975 Troni: Copies: R. S. Lamar - 2W / J. M. Fletcher - 2S 'll. R. Keefe - 2W J. M. Sbarrati - 2S Subject: AN ASSESSMENT OF THE J-M POSITION WITH TALC Three years since J-M's entry into the talc business with the acquisition of Desert Minerals Company is time enough for an appraisal of our position. This assessment is broken down into eight sections as follows: 1. The Effects of Labeling: Our position here has been the only accept ab1e acti on J-M could take. According to the definitions that are a part of the law, our California talc products all contain asbestos in the form of tremolite. No play on words will change this fact. r.. ^ v i i r ni . i* ^ > ... 1 l'zi'J. L i U J.JL *'M m r t * f i m y j_t* i u i j j the uniquely high brightness and relatively low acid soluble content of G-l and G-2 talc ores, we could hold onto most of the critical markets, in spite of labeling. I now seriously doubt our ability to do this. The "talc-asbestos" problem is quite different from the "asbestos-asbestos" problem. In many applications for asbestos, there are no acceptable substitutes. With our asbestos-containing talc, there are numerous possibilities for substitution: (a) Non-asbestos containing talcs from both Pfizer and Cyprus from Montana sources and Cb) Other extender pigments such as kaolin and calcium carbonate (in paints, for example, and in paper filling uses). We see this type of substitution being made and long-established markets for Desertalc products evaporating in the process. CRMC-MAD-000431 P, A. Martinson Page Two 2. The R. T. Vanderbilt Position; Their position with respect to labeling must be deliberatcly perfidious; they cannot be this misinformed. Slim Thompson, their technical director, has a Ph.D. in mineralogy. At the moment, Vanderbilt is misleading their customers and confusing ours with their decision not to label. Ultimately, the truth will out, and they will be forced to label. Pfizer's position is the same with their California talcs. With all asbestos-containing talcs labeled, far greater value and emphasis in the market will be applied to asbestos-free talcs. I seriously question the capacity of these asbestos-free talcs to satisfy the total market. Also, in some applications, the asbestos-free talcs are just not a suitable sub stitute quality-wise. For example, in ceramic wall tile (a major market for tremolitic talc) there are few, if any, asbestos-free talcs that show the same forming and firing properties. Penhorwood fires to a brown color due to high,iron content. G-l Fires white due to very low iron content. Nevertheless, it is a fact that the Montana talc (asbestos-free) business of both Cyprus Industrial Minerals and Pfizer is booming, while we are in the doldrums. 3. Quality; Historically, talc mining has been a highgrading operation with selective mining required to maintain acceptable quality fer various uses. This type of selective mining was done successfully for over 25 years at the Grantham Mine. Proper quality and uniformity of ore were seldom, if ever, problems and sizeable markets were built on this foundation of quality. The unique high brightness of Cyclo-Fil (95% G.E.) was, in the past, properly maintained and a good and profitable market developed for this product in paper filling. With the brightness of current quality Cyclo-Fil dipping as low as 89%, there is no way we are going to maintain this business. Clays and other fillers at half the price of Cyclo-Fil can and are being used. CRMC-MAD-000432 P. A. Martinson Page Three Other quality considerations relating to high acid soluble content and improper grind have caused an elusion of our paper industry business until virtually nothing remains. 4. Markets: At one time (less than three years ago) sizcab.ic markets for Descrtalc products existed in paper, paint, plastics, and ceramics. Both DT-51 and DT-57 were the most widely usud fillers in 40% talcfilled polypropylene. We lost this business prior to labeling because of tremolite content. Many of our paint and paper accounts have been lest for the same reason and labeling has accelerated this loss. Labeling, plus the loss of proper quality, has been disastercus. Ceramic sales of DT-51 have been difficult to maintain. High acid soluble and water soluble contents of G-l ore have resulted in casting slip gelation and rheological problems. The high acid soluble content of current quality G-3. and G-2 ore has increased the alum demand of uuIn Cyclu-Suxu and Cyclo-Fil in paper applications to the point where, even if we had proper brightness, a paper mill could not afford to use our products. I can foresee no markets that can be built or rebuilt under present conditions. 5. New Technology: Froth flotation will reduce the trerrolitc content of G-2 ore to less than 1%, but will not remove all of the tremolite. In such a wet process, acid leaching will increase brightness several points. HIMS could probably also be used to remove even paramagnetic material to improve brightness still further. Newly developed sand or attritor milling procedures can grind down to a maximum particle size of under 2 microns, but I believe that all of these new techniques are a waste of time as long as we have to label. Also, the relatively high mining costs at Warm Springs, plus the absence of adequate water for these wet processing methods makes the development of other sources more attractive. CRMC-MAD-000433 P, A. Martinson Page Four Penhorwood: Based on detailed testing, we feel certain that Penhorwood talc can be developed as a major source for pitch control and should be directly competitive with Mistron Vapor (Cyprus Industrial Minerals Montana talc). Other markets may be developed for Penhorwood in plastics filling, elastomer reinforcement and paint. Although in this latter use, the relatively low brightness of Penhorwood is going to be difficult * to overcome. If higher brigheness grades could be developed from the same mining area, additional markets would become available. In paint uses, wet color uniformity is a major considera tion and must be maintained with Penhorwood talc or any other extender pigment. Analyses of Penhorwood core samples suggest that this may become a major problem. 7. Other Worldwide Talc Sources: With the worldwide decline in the industrial use of tremolitic or asbestos containing talcs, sources for asbestos-free talc will surely become more valuable. Major sources for tills type of ore exist in France, Italy, Spain, India, Red China and other parts of the world. Generally, all of these deposits are selectively mined. Only Finntalc and Johnson and Johnson are using froth flotation to separate talc products of acceptable quality. We will do the same at Penhorwood,* and the industry must move in this direction as deposits amendable to high-grading are depleted. Talc producing areas in California, Nevada, and Montana have been thoroughly--if not systematically and profes sionally explored. It is uhTikely that new largescale talc-mining properties could be developed. However, this possibility should be explored--but only for asbestos-free materials. There would appear to be an opportunity for good geological work. CRMC-MAD-000434 P. A. Martinson Page Five 8 . Conclusions and Recommendations a. Labeling, plus a general decline in quality, has caused a disasterous loss in J-M talc business. Some of this business might be regained in spite of labeling, providing we could 're-establish prior high quality standards in both our mining and milling of these products. However, the effects of labeling will always place us in a serious competitive position. The economic viability of such an operation is also highly questionable. b. Until Penhorwood is in operation, we should try to hold onto as much of our existing talc business as possible. Such a holding action will be difficult, expensive, and disheartening, but should be done. Penhorwood will not replace all existing markets for Grantham talc because of darker color and other differences. c. Beyond the development of Penhorwood, J-M should attempt to develop, on a worldwide scale, other asbestosfree "sources for talc mineral. These will most surely become more valuable with time. It would be unfortunate, indeed, if we were to let our poor performance with Grantham talc interfere with J-M development of other worldwide talc sources under more desirable conditions. CRMC-MAD-000435 Celite DHQ January 23, 1973 R. S. Lamar TALC PRODUCERS' ASSOCIATION (PROPOSED) R, T. Vanderbilt company__________ _ in view of the developments at the recent meeting in New York City attended by you and Dr. Speil, it appears very much in order to go on record not only with the Vanderbilt people, but also others in the industry interested in OSHA, FDA and other matters of concern at this time. Pursuant to our conversation last week in Denver, it is therefore suggested that you immediately propose a letter, which you indicated you would do, and send it to the writer, it is asked that you indicate to whom you feel this letter should be addressed, in accordance with the foregoing statement. Also, it is my suggestion that perhaps jack Solon should initiate the letter and follow through. I am giving a copy of your January 18 letter to both Messrs. Solon and Dick Carter. It is my strong feeling on this matter that johns-Manville's position must be based on facts. I know on this you agree, and also, in general, others in the industry of necessity for the good of the industry, certainly must take the same position. H. R. Keefe E. B. Smith R. F. Bassett W. C. Streib -R-. p . carter J. M. Sharratt d CRMC-MAD-000436 TO FROM 0 . S. Spell . R.S. Lamar INTER - OFFICE MEMORANDUM % f f in DATE : denary 18, 1973 SUBJECT . Telephone conversation FOLLOW-UP : 1/16/73 vith William Ashton, Johnson & Johnson*I As you know, we have joint development o^ ^ been working with Bill Ashton on Caad*,an M3n"a * talc with J-M the and possible J&J. Bill probably knows as much about talc as anyone. He is very honest and Quite outspoken sometimes in expressing his opinion. He is a great person! Bill Ashton is vary upset about what R.T. Vanderbilt Company is trying to do through the Talc Producer's Association, and more particularly, what they are attempting to do by having Alan Harvey made chairman of the A.S.T.M. sub-committee to re-define "asbestos". According to Ashton, they also hope to define "talc" through this ame committe.. This is what has Ashton really upset! I know that both you and I came away from our January 11, 1973 meeting at R.T. Vanderbilt Company, New York City not agreeing vith their definition of "tremolite". They are playing with words and ignoring facts. Aahton said today that they (Vanderbilt) plan to use this same A.S.T.M. committee to re-define talc as: 1. Pure talc mineral (never found in nature). 2. Commercial talc which is always associated with tremolite. Both definitions are not true but are obviously aimed at strengthening Vanderbilt's marketing position. These are obvious and deliberate attempts by Vanderbilt to bend the truth. We have seen numerous samples of natural pure talc mineral. Many commerical talcs, even though they are not pure talc minerals, do not contain tremolite. I do not believe that we should allow Vanderbilt to proceed unchallenged with this type of approach. It might be very worth while if you were to talk with Bill Ashton about all of this prior to the forthcoming Talc Producer's Association meeting on February 5, at R.T. Vanderbilt Company offices New York City. ' CRMC-MAD-000437 It our very strong belief that J-M should not endorse something we know to be untrue even if it may help us in our present difficult position with respect to tremolite. Sincerely, R.S. Lamar RSL:lk cc: W.L. VanDerbeek P.A. Martinsonv/" J.M. Sharratt W.C. Streib fl.R. Keefe EB Smith R.F. Bassett R.S. Lamar t CRMC-MAD Vsf>. . i I \ Johns-Manville - t 't/iuep *`t. Interna' Correspondence fo; F. J. S o l o n , Jr. fr*TM R. P. C a r t e r Copies: F i l e & C Oct. 4, 1974 Subject: T R E M O L IT IC TA LC Bob Bacon called me this afternoon to advise me he had received a telephone call from Dan Boyd. Boyd indicated that he had been directed by John Stender to prepare a l e t t e r to R. T. V a n d e r b i l t for S t e n d e r ' s s i g n a t u r e , advising Vanderbilt that they can certify to their customers that Vanderbilt's talc (NYTAL) does not contain asbestos, provided the talc ore does not contain fibers in R. T. V a n d e r b i l t ' s j u d g e m e n t . B o y d b e l i e v e s tha t the letter will be signed early next week. Boyd indicated to Bacon that this decision was based on guidance from Jon May at NIOSH, who advised OSHA that the evidence currently is inconclusive as to whether tremolite is carcinogenic. Therefore, Vanderbilt should be granted some relief until NIOSH completes its investigation of tremolitic talc. As soon as this letter is signed by Stender, Boyd agreed to call Bacon and read the contents of the letter to him. Bob Bacon, in turn, has agreed to call me as soon as he hears from Boyd and will immediately forward a copy of the letter to us. If what Bob Bacon has reported is correct, I am at a loss to understand OSHA's rationale for such action. In the past, OSHA has not hesitated to regulate a substance even though there was little, if any, evidence to establish that a particular substance was harmful to man at certain exposure levels. If such a letter is in fact issued by Stender, then, in effect OSHA would be holding in abeyance the application of the asbestos definition in OSHA's asbestos standard with respect to tremolite.I I advised Bob Bacon that we were still planning to commence the insertion of warning labels on all commercial talc on or a b o u t N o v e m b e r 1, an d w o u l d n o t r e c o n s i d e r this decision until such time as we had an opportunity to review Stender's forthcoming letter. CRMC-MAD-000439 F. J. Solon, Jr Page 2 Oct. 4, 1974 In the event we should decide to schedule a meeting with Howard Shulte, Dan Boyd and Alexander Reis, it might be advisable to first meet with Jon May at NIOSH to ascertain where they stand in their study of tremolitic talc and learn first-hand what his recommendation was to O S H A w i t h re s p e c t to V a n d e r b i l t 's request. This b a c k g r o u n d may be beneficial to us at a meeting with Shulte, Boyd and Reis. R. P. Car t e r RPC/emr CRMC-MAD-000440 TO FROM SUBJECT S. Spell R.S. Lenar INTER - OFFICE MEMORANDUM DATE ym : January 18, 1973 Telephone conversation______ FOLLOW-UP : 1/16/73 with William Ashton, Johnson & Johnson As you know, we have been working with Bill Ashton on the possible Joint development o^ Canadian Mari"0'*1 talc with J-M and J&J. Bill probably knows as much about talc as anyone. He is very honest and quite outspoken sometimes in expressing his opinion. He is a great person! Bill Ashton is very upset about what R.T. Vanderbilt Company is trying to do through the Talc Producer's Association, and more particularly, what they are attempting to do by having Alan Harvey made chairman of the A.S.T.M. sub-committee to re-define "asbestos". According to Ashton, they also hope to define "talc" through this same committe.. This is what has Ashton really upset! I know that both you and I came away from our January 11, 1973 meeting at R.T. Vanderbilt Company, New York City not agreeing with their definition of "tremolite". They are playing with words and ignoring facts. Ashton said today that they (Vanderbilt) plan to use this same A.S.T.M. committee to re-define talc as: 1. Pure talc mineral (never found in nature). 2. Commercial talc which is always associated with tremolite. Both definitions are not true but are obviously aimed at strengthening Vanderbilt's marketing position. These are obvious and deliberate attempts by Vanderbilt to bend the truth. We have seen numerous samples of natural pure talc mineral. Many commerical talcs, even though they are not pure talc minerals, do not contain tremolite. I do not believe that we should allow Vanderbilt to proceed unchallanged with this type of approach. It might be very worth while if you were to talk with Bill Ashton about all of this prior to the forthcoming Talc Producer's Association meeting on February 5, at R.T. Vanderbilt Company offices New York City. t- CRMC-MAD-000441 -2- It our very strong belief that J-M should not endorse something ve know to be untrue even if it may help us in our present difficult position with respect to tremollte. Sincerely, R.S. Lamar RSL:lk cc: W.L. VanDerbeek P.A. Martinson v/ J.M. Sharratt W.C. Streib H.R. Keefe E.B. Smith R.F. Bassett R.S. Lamar 000442 Cr MC-^aD ...... .I... .... -L-- . .. ____ _ Dick Lamar's letter suggested that I comment on the technical soundness of the letter before it is sent. Before doinc so, I would like to raise a question as to the desirability of sending such a letter out after attending the recent meeting of the Talc Producer's Association in New York City. While t h e i n t e n t of the m e e t i n g w a s to promulgate a s c r i e s of d e f i nitions differentiating asbestos, tremoiite, talc and commer cial talc, I believe I was instrumental in changing the end result so that only one definition is being proposed, i.e., industrial talc. While the exact wording may differ very slightly from the definition below, the general gist was as follows: "Industrial talc from the mineral mineral talc and fibrous minerals is a product varying in mineral composition talc [Mg5 (SigC^o) (OH)4! to mixtures of other naturally associated non-fibrous and/or as defined by ASTM Designation D2946-71. While we should clear with the Vanderbilt people whether they intend to continue their previous plan to convince Government officials that tremoiite is not an asbestos mineral, my own impression from the meeting is that they are convinced of the futility of this approach. The much more reasonable approach, and one which has some slight possibility of bearing fruit, is to concentrate on the definition of fiber. The ASTM definition referred to above uses an aspect ratio of 1 0 : 1 rather than the ACGIH ratio of 3:1. R. T. V a n d e r b i l t a p p e a r s to b e t h e s p e a r h e a d f o r the w h o l e effort to disassociate tremoiite from the list of asbestos minerals. If they are not going to push this approach, then there is little need, in my opinion, for sending the letter to Talc Producers or to the Talc Producer's Association. So much for the political aspects of the letter. With reference to the technical aspects, I should like to make the following points, some of which obviously will be minor. CRM c -M AD-000443 February 14, 1973 Page 2 P. A, M a r t i n s o n - 2 W est / Item 2, While tremolite does have a f i b r o u s " c r y s t a l h a b i t " ^ H e p a r t i c l e s can be fibrous or non-fibrous. In essence, a fiber is a particle with a defined minimum ratio of length to width. Unfortunately, this aspect ratio (L/D) is not a definitely established limit. As a matter of fact, in the ASTM definitions there are two ratios given as minimum. In the AS T M definition of asbestos minerals, the ratio is 10:1; in the Textile Fiber section, the limit is given as 100:1. However, the more important aspect ratio limit, whether it has any more scientific significance or not, is that promulgated b y t h e A'CGIH, n a m e l y , an a s p e c t r a t i o of 3. If the t r e m o l i t e particles have an aspect ratio greater than 3:1, they are fibrous as far as OSHA is concerned. If the ratio is less t h a n 3 :1 , the t r e m o l i t e p a r t i c l e is a p a r t i c l e , n o t a fiber. Thus, although "tremolite is a fibrous mineral" as stated in I t e m 2, t h e i n d i v i d u a l p a r t i c l e s m a y b e f i b r o u s o r m a y n o t be fibrous, depending on their specific aspect ratios. Starting with this distinction, we go to Item 1 which says that tremolite is clearly a member of the "asbestos family" of minerals. Again, this is correct, but since the asbestos minerals are fibrous by definition, then we could conclude that those particles of tremolite whose aspect ratio is e x tremely small are really not fibers and, therefore,, they could be considered as not being asbestos. W hat I am trying to point out is that whether tremolite is to be classed as an asbestos mineral is secondary to whether the particles are really fibrous or not insofar as the OSHA regulations are concerned, and we should try to pin our argu ments on the aspect ratio factor. Item 3. X-ray diffraction methods make possible a positive "differentiation between" both minerals. It will not definitely identify tremolite in a mixture containing small quantities of tremolite in a large concentration of talc. Strongest identifying X-ray lines for tremolite are essentially the same as those for anthophyllite and several other amphibole minerals. The statement that pure talc mineral is fairly common in nature is s o m e t h i n g t h a t I m u s t d e f e r to R. L a m a r ' s k n o w l e d g e . I h a d not anticipated that there were any large deposits of pure talc mineral without concomitant impurities, albeit non-fibrous impurities such as carbonates, oxides, etc. C R U c -M AD-000444 February 14, 1973 Page 3 P. A. M a r t i n s o n - 2 W e s t Item 8. While I am sure that our Industrial Hygienists can supply information regarding correct procedures for dust control and other protective measures that may be required, it will be a long time before sufficient medxcal or epidemio logical data arc available on which to pass any recommendations other than to include tremolite as either an asbestos fiber, in which case the fiber count limitations will be paramount, o r as a nuisance dust in w h i c h particle count w o u l d be p a r a mount , Dick Lamar is to be congratulated on preparing a summation of this type which brings together at one point pertinent informa tion of a technical nature. S. SPEIL SS/rs cc: W. L. J. M. H. R. W. C. R. P. R. S. E. B. R. F. VanDerbcek Sharratt Keefe Streib Carter Lamar Smith Bassett 2 West 2 West 2 West 3 West 5 West 1 North Long Beach, Long Beach, Carson/*' Carson c r m c -m a d Greenwood Plaza - 1 North January 31, 1973 P. A. M a r t i n s o n - 2 W e s t EJE EBS TER T | ,:0N NBS JEC RFB I SRM DEN ; :. t i o la , < AJM | KJB OHM I ur YR M E M O OF JANUARY 23, 1973 TALC PRODUCER' S ASSOCIATION (PROPOSED) R. T. VANDERBILT COMPANY Attached is a proposed draft of a letter v/hich is intended to i n d i c a t e our (J-M) s cand on this subject. We a gree t h a t th i s s h o u l d p r o b a b l y c o o u t o v e r 7. J. S o l o n !' s S i g n a t u r . f e e l nos t s I r o n g l y , hows'ver, t h a t b o t h S. S u e i l a n d v\. C. S t r e i b s h o u l d a p p r o v e of t h e t e c h n i c a l s o u n d n e s s of the letter before it is sent. We believe that the letter should go to the presidents of all of the talc producers in the United States, to the Talc P r o d u c e r 's A s s o c i a t i o n , a n d to the a p p r o p r i a t e A . S.T.M. Committee. R. S. L a m a r am cc ; w. L. V a n d e r b e e k F. J. Solon H. R. K e e f e E. B. Smith R. F. Ba s s e t t S. S p e i l W. C. Streib R. P. C a r t e r J. M. Sharratt - 2 West - 1 West - 2 West - Long Beach, - Long Beach, - 3 West - 3 West - 5 West - 2 West C a r s o n * Carson CRMC  H H OUTLINE ASBESTOS-CEMENT BACKGROUND PAPER I. INTRODUCTION A) B r i e f H i s t o r y 'E) Uses C) Specs - P . H . S . ---W.H.O BACKGROUND TO HEALTH ISSUE A) Nashville accusation B) PHS inquiry III. EVIDENCE SUPPORTING A/C PIPE A) Wright/Selikoff quotes B) Four types of supporting evidence; 1. No unusually high GI cauicer aunong asbestos workers a 2. No GI cancer in animal experiments 3. Preliminary results of municipal water tests for asbestos content 4. Decrease of Gi cancer in U.S. and Europe IV CONVULSIONS r CRMC-MAD-000447 DJv-FT # 5 - MMS/WPR April 9,' 1968 ASBESTOS-CEMENT WATER PIPE AND HUMAN HEALTH Asbestos-cement (A/C) pipe for water supply and disposal systems was developed in Europe in 1913 and introduced into the United States in 1929. Asbestos fiber, added to Portland cement and silica, provides the structural strength required for durable, lightweight, rustproof, economical piping. These advantages have led to the use of great quantities of A/C pipe, over the past half century, for water supply and sewer systems, irrigation projects, drainage systems, industrial processes, heating and cooling installations, gas systems, and as conduits for electrical and telephone wires. For water'supply systems, A/C pipe meets the specifications of the American Water Works Association and of the U. S. Government. Under Federal Specification SS-P-351A, A/C water pipe is sold to the U. S. Public Health Service. The World Health Organisation uses large quantities of A/C pipe in its programs to improve the quantity and quality of water systems throughout the world. Because of A/C p i p e 's unique advantages for community water systems, it is important to clarify a question raised, late in 1967, in Nashville, Tenn., concerning the suggestion of a possible health hazard related to the use of A/C pipe. CRMC-MAD-000448 More .... On November 30, 1967, THE NASHVILLE BANNER, in a story on this proposal, reprinted a letter from Dr. James D. Snell, Jr., Assistant Professor of Medicine at Vanderbilt University, suggesting that it would be 'h medical hazard of significant degree to use such pipe in a water system until the U. S. Public Health Service had checked it out completely ..." Dr. Snell's letter stated that medical circles have established "fairly well" that asbestos causes a "high incidence of cancer in the lungs if breathed or in the gastrointestional tract if swallowed, even in amounts small enough to be visible only under a microscope." He added that if any particles of asbestos were released from A/c pipe into a municipal water system, "current medical knowledge suggests that a rise S in certain types of cancer could be expected in about 20-50 years among I || the population." \\ Dr. Snell offered no evidence in his letter to support his allegations! Later, when Nashville Councilman James LaPenna asked to see medical literature in support of this position. Dr. Snell submitted two papers which dealt solely with the problem of occupational exposure to the inhalation of asbestos fibers. Neither paper suggested any problem arising out of the swallowing of asbestos fiber by the general public. Upon receiving Dr. Snell's letter, Nashville authorities turned to the U. S.Public Health Service for advice. o More .... Ac t io n o f t h e s c ie n t is t s The Public Health Service contacted two prominent medical authorities in the field of asbestos and health "to confirm our view that there is a low probability of any health hazard associated with this use of asbestos cement pipe." If The two experts were Dr. George w. Wright end Dr. Irving J. Seiikoff, wh o are referred to b y the PHS as "recognized authorities in the f M d . " Dr. Wright is Chairman of the Institute for Occupational and Environmental Health, and head of the Medical Research Department, St. Luke's Hospital, Cleveland, Ohio. Dr. Selikoff is professor and chairman, Divfeion of Environmental Medicine, Mt. Sinai School of Medicine, New York City. Briefly, the opinions of these two prominent authorities are as follows: "To my knowledge,, there have been no reports in medical literature of any relationship between gastrointc-stional cancer and the drinking of water supplied through an asbestos-cement pipe water system. Most assuredly, the ingestion of one or a hundred or a thousand asbestos fibers, on one or more instances, cannot be related to gastrointestional cancer, since in asbestos workers exposed far more heavily five days a week, over a period of many years, there is no evidence of a higher than average frequency of GI cancer." CRMC-MAD-000450  -4- ; There is 'h o evidence at all at this time that the presumably very low level exposure by ingestion which might occur by intake of water supplied through asbestos-cement pipe has resulted in a recognized health hazard." rsckcrff EVIDENCE SUPPORTS COMMENTS BY DOCTORS The comments of Dr. Wright and Dr. Selikoff are supported by four types of evidence: 1. workers in certain asbestos-related trades have been exposed to heavy concentrations of asbestos dust on the job and have, as a reiult, swallowed considerable quantities of this material. Despite this exposure, they have not had .an unusually high rate 'A of gastrointestional cancer. 2. The exposure of laboratory test animals to heavy concentrations of asbestos dust has resulted in no cases of gastrointestional cancer. 3. Recent -iivniliim irm.rj research indicates that no significant amounts of asbestos are released into drinking water which flows through A/C pipe. 4. The death rate from gastrointestional cancer in the United State; has shown a steady decline over the last 20 years. This national trend also applies, in general, to those cities More .... CRMC-MAD-000451 -- 3V-- where A/C pipe has been used in water systems for long periods of time. Similarly, in most of the European countries where A/C pipe has been used extensively -- in many countries for more than half a century -- the death rate from this type of. cancer has also declined. Those four points will now be discussed in further detail. 1. OCCUPATIONAL EXPOSURE TO ASBESTOS HAS NOT RESULTED IN ABNORMALLY H IGH GI CANCER RATE ____ Scientists are now investigating a possible relationship between heavy occupational exposure to inhaled asbestos dust and lung cancer; however, there is no evidence whatever to support; the Contention that the swallowing of asbestos fibers produces any disease. Dr. Wright points out that insulation workers are "heavily exposed" to the ingestion of asbestos because a certain percentage of inhaled asbestos dust is coughed up and then swallowed. "I would reason from this, therefore, that in the insulation workers the gastrointestional exposure to fiber would be high and therefore if there was a strong relationship of fiber ingestion to gastrointestional cancer, it should not be difficult to demonstrate it." Dr. Wright declares , " there is no evidence to support the contention that even the highest intensity of exposures that we know of in industry leads to More .... CRMC-MAD-000452 clear-cut increased frequency of gastrointestional cancer." SUMMARY Studies made on workers exposed to a heavy concentration of asbestos dust do not support -he allegation that the minute amounts of asbestos present in water would lead to increased GI cancer risks. 2 . ANIMAL EXPERIMENTS WITH ASBESTOS HAVE NOT PRODUCED GI C A N C E R __________________________________________ Laboratory test animals are used extensively in cancer research to study their reactions to various substances that are suspected of having some relationship to cancer in humans. Tests of this nature, using asbestos, have been conducted on.mice for periods as long as two years and on dogs for four or more years. The amount of fiber swallowed by these / experimental animals far exceeds even that of insulation workers. These animal tests have shown no relationship between fiber exposure and gastrointestional cancer. In fact, there is no record of a tumor of any sort forming in the gastrointestional tract of the test animals. In addition, experiments conducted by Dr. Selikoff on hamsters generally support the dog-and-mice-feeding findings. "Yet," Dr. Selikoff commented, "the exposure to ingested asbestos in this experimental work was very much larger indeed .^AD-000453 -7than might be anticipated in water obtained from asbestos- cement p i p e s ." 5 / A>y/^ SUMMARY Animal experiments confirm the studies made of the health records of asbestos workers, which show no relation ship between asbestos exposure, whether by inhalation or swallowing, and GI cancer. 3. MUNICIPAL WATER AND ASBESTOS Even the so-called "pure" water distributed through municipal systems contains traces of many minerals and chemicals, the amount and type depending upon the source and location of water supplies, it would not be surprising, therefore, to find trace particles of asbestos in water supplied through almost any type of piping system. A recent study showed that the water passing through two miles of 17-year-old A/C pipe, in San Diego, contained a mere 4 micrograms - - about one seven-millionths of an ounce - - of asbestos fiber per gallon. In terms of human consumption this means that if a man were to drink eight glasses of water per day, he might swallow a cotal of eighteen-ten-thousandths of an oun^-' (.0018) of asbestos in a lifetime of 70 years. How does this compare with the exposure of a man working in an .MAD-000454 O asbestos plant? Under the accepted Threshold Limit Value (TLV) for asbestos inhalation in industry, in 45 years a worker would inhale 8,000 times more fiber than anyone could get from the drinking water in 70 years. What is relevant here is the fact that there is no increased frequency of GI cancer among asbestos workers, who cough up and swallow a substantial portion of the fiber they inhale. SUMMARY Although additional research is being carried on, present evidence does not support the contention that A/C water pipe releases asbestos into water .tmppliikrs- in amounts than can constitute any health hazard to the general public. DECREASE IN FREQUENCY OF GASTROINTESTIONAL (GI) CANCER IN THE UNITED STATES______________________________________ Figures from both the National Office of Vital Statistics of the United States Public Health Service and from the American Cancer Society show a steady decline in the frequency of GI cancer in the United States from 1947 to 1966. The death rate per 100,000 of population from GI cancer dropped from 55.2 in 1947 to 48.4 in 1966. Available U. S. figures also show GI cancer declining since 1960 as a percentage of total deaths: More ... Year i960 1962 3<3& 19^5 Table I. Deaths from Selected Causes f o r t h e J M ^ ' Total Deaths All Causes Deaths from GX Cancer GI Cancer as of All Deaths 1,711,982 91,035 5.3 1,756,720 92,Ob? 5-2 1,798,051 93,158 5.1 1,828,136 9^,305 5.1 Similar trends can be found in cities all across the country.* Of special interest is the comparison between Nashville, Term., where no A/C pipe has been used and Knoxville, Term., where A/C pipe has been used since 1938. Here' how U.S. government figures apply to those two cities. * -Table XI. Nashville-Knoxville Comparisons Deaths from All Causes Deaths from GI Cancer GI Cancer Deaths as Percent of Total Nashville *(no A/C pipe) I960 1?6| 3,675 3,70b 129 166 3.555 b.55i Knoxville (A/Cpipe since 1938) 1956 1965" 3,038 3,256 131 133 b.3$ b.lf, Stunr s'* -10- Similarly, in Europe, where A/C pipe has been in u&e for fifty years or more, the death rate from GI cancer is generally downward. For example, in Switzerland, where the use of A/C pipe is the highest per capita of any Western European country, the death rate, per 100,000 of population, for GI cancer has dropped from 81.9 in 1951 to 63.9 in 1962, according to the latest figures available from the World Health Organiza tion. Thus, the actual frequency of gastrointestional cancer in no way J supports the allegation that the use of A/C water pipe can cause an increase in this type of disease. It is also interest ing to note that during the very years that the use of A/C pipe has increased in the United States, the rate of GI cancer has declined, although no conclusion should be drawn from this comparison. On the other hand, it is clear that no causal connection is shown between A/C water pipe and GI cancer in human beings. SUMMARY "Substantial amounts of asbestos fiber have been used in various ways from 1930 on in the United States, and one would anticipate that if this fiber was playing a role in the causation of gastrointestinal tumors, it might be expected to have led to an increase in tumors, rather than the observed decrease." (Dr. George W. Wright) More .... CRMC-MAD-000457 -11- f. ftov*70 CF *(In considering these figures, it is important to remember (a) that cities tend to have higher rates of cancer than rural areas, so some city figures will rui higher than the U. S. average, and (b) that minor fluctuations from year to year in the percentage figures, whether up or down, are of little or L no significance, especially if the numbers are small.) CONCLUSIONS Four types of evidence have been examined: (1) occupational exposure of workers to inhaled and swallowed asbestos dust particles; (2 ) results of experiments with test animals exposed to large quantities of asbestos particles (3) results of tests to determine the amount of asbestos in municipal wat e r supplies and (4) the frequency of GI cancer in the U.S. and Europe, including those areas using A/c water pipe. All of this evidence is against the allegation that the use of A/C water pipe has any influence on the development of GI cancer. Finally, it is important to view Dr. Snell's concern'about the health safety of A/C pipe in its proper perspective. Asbestos is by no means alone in having the finger pointed toward it as a possible health hazard. Literally hundreds of substances -- as common and everyday as fuel oil, charcoal broiled steaks, iron rust and egg yokes are known or suspected of being cancer causing agents under certain experi mental conditions. CRMC-MAD-000458 More .... The point is that nearly everything w e use and create in our in c re a s in g ly complex s o c ie ty has been suspected, b y someone, o f being a potential hazard. To forego the many benefits of these products of modern technology - simply on the basis of suspicions that are unsupported by medical evidence would be a great and unwarranted disservice to the American public. # # ## CRMC-MAD-000459 CRMC-MAD-000460 R. T. V A N D E R B I L T C O M P A N Y , INC. 33 W t N r i C L D & T P E C T CAST NOOWALK.CONNECTICUT O O D S S CAALt AOQ*Cl PlWTVAN N e w December 13, 19T2 Mr. Norman Scheffel Vice President Desert Minerals P. 0. Box 155 Yardley, Pennsylvania 1906? Dear Mr. Scheffel: The attached information may be of interest to you in our continued efforts to differentiate between the physiological effects of talc and asbestos. Very truly yours R. T. VANDERBILT COMPANY, INC. Allan Patent and Legal Liaison Department Attachment CRMC-MAD-000461 R.T. V A N D E R B IL T COMPANY, IN C . Copy of memo, Erdmon to Harvey - December k, 1972 * Talcosir. vs. Ar.ber.tor.ln Thank you for the data you supplied recently on dust disease studies. After gleaning over these studies I find no mention of the 19il study with tile unexposed blank on local pcap.lo that van run. Perhaps there in no comparison made with thin unexpooed group because it does not reinforce Dr. Kleinfeld's point that he makes in each.paper. Practically speaking He makes a devastating case that the New York State talcs are responsible for an increased death rate duo to cancer of the lungs and gastro-intestinal tract. However, there are many unanswered questions raised by his study that can bo somewhat helpful to us. 1. Much of his "conclusive" evidence is based on tho 221 talc minors studied in 19^0 and on the follow-up of 32 of these workers in 195** Thus the major portion of the defamatory data is based on the work experience of earlier talc companies, since our operation did not commence until 19L7. If that talc of a reputedly fibrous nature very similar to asbestos did in fact contain small quantities of asbestos, it could accelerate the onset of fibrosis and cancer. In fact Kleinfeld in. one place states that examination of lung tissues showed fibrotic stranding indistinguish able from asbestos. * 2. 'The levels of dust exposure indicated in those studies are extremely high and almost never found today where modern dust collection practices are in force. Many of the "Medium" exposure levels listed for the period before 19^5 are absolutely intolerable today. Thus a study of the incidence of .lung cancer occurrence in employee:) under today's exposure could be expected to be substantially less. Kleinfeld in fact recognizes this fact at one point (P665 Mortality Among etc.). 3 . On PS67 of Mortality Among Talc Miners, Kleinfeld makes an interesting and puzzling observation that the average age at death of the 91 talc ^ workers followed in the study was 60.L years where according to the l n a t i o n a l average it should have been only 5^*^ years. In other words in spite of the dust exposure and the eventual death by cancer of the lungs or gastro-intestinal tract the group of talc workers on the average lived 6 years longer than the average American male born at the some time.' Thus it becomes somewhat questionable whether the talc exposure actually shortened their lives. In any event Kleinfeld's data would indicate less than half the mortality rate for talc as compared to asbestos which is a very good point for a different TLV for talc. ; U. While the incidence of death by cancer from talc exposure is reputed to be L times that of the "control population" we find no mention of CRMC-MAD-000462 R.T. V A N D E R B IL T COMPANY, INC. Talconls vs. Arbgstor.i what that population is and are left to assume that it is the U. S. population in General. This approach ignores our local background which is replete with cases of lung infection due to dairy farm dust exposure according to many medical authorities. In summary the results of Kleinfeld's work published in the Mortality Among Talc Miners etc. would indicate that prolonged exposure to very hlrh levels of talc dust will produce cancer deaths at an indicated rate of F u m e s the 1965 national average. The data would indicate that the percentages of cancer deaths are less than one half those caused by similar asbestos exposure and therefore a TLV of at least twice that of asbestos should be tolerable. More modern data and comparisons with the local population should have been made but have been neglected, thus the talc industry is being singled out for what happened prior to 1940 rather than what it is doing today. s\ r \ CRMC-MAD-000463 C e lit e DHQ September 5, 1972 ,/ // / / , f (< . Em M. Jackson OSHA - TALC Attached is copy o f R. c . Bacon'a (R. t . V a n d e rb ilt) l e t t e r o f August 17, 1972, \A iid ti ia s e lf-e x p la n a to ry . attachment cc* w. L. vanDerbeek R. P. c a rte r P . Dm Richards T . M. Jackson H* R. Keefe D C CRMC-MAD -000464 R.T. VA N D ER B ILT COM PANY. INC. 3 3 W IN riC L O S T R E E T CAST N O R W A LK ,C O N N EC TIC U T O O O S9 M ) G 2 1 1572 CAUC ADOBE B U T VAN MCW TO August 17, 1972 Mr. W illia m B. B e itz e Johns-M anville Corporation 5680 South Syracuse C irc le Denver, Colorado 80110 II If V Dear B ill: Enclosed a re copies o f two form l e t t e r s which we w i l l use fo r c e rta in o f our customers regarding the trem ol i t e s it u a t io n . You may f in d these o f h e lp . Sincerely yours, Research & Development D iv is io n RCB:mjh * Enclosures ThNCMWNndwieri hr uh ofourworUlt m ponKMbBKvBdle tu CRMC-MAD-000465 utdortXfruvrt t mnlt>to botAsincd REPLY TO CUSTOMER INQUIRY RE THE 3FF3CT 0? THE ILLINOIS POLLUTION CONTROL BOARD'S REGULATIONS FOR ASBESTOS DUST _____ ______ ON THE USE OF VANDERBILT TALCS In answer to your letter of : _________ , wo have j determined that about one-third of our NYTAL talc' consists of the mineral tremolite. Although the overwhelming percentage of tremolite in our product is of the non-fibrous type, particles can be found whose length to breadth i ratio is J to 1 or greater, thus putting them into the category of a fiber as defined by the Illinois Standard. / / ()''< Since our NYTAL ores are not mined or used as asbestos, vc take issue-with the Illinois Pollution Control Board, both in Xftio of an asbestos fiber and the inclusion of tremolite per se_ us asbestos. At present, it is our belief that the existence of tremolite in our produodoes not constitute a mineral dust exposure hazard greater then that of non-asbestiform ta lc . Furthermore, although an exact determination has not been made, we believa that the content of so-called "fibers" in cur product is low enough to present little or no inconvenience to the u s e r in complying with' the Illinois -Standard limit for ambient air of w o * per cubic centimeter of air. 1 . . fibers 8/ 15/72 CRMC-MAD-000466 ASTtf COMMITTEE >34 TASK GROUP ON NATURALLY OCCURRING INORGANIC FIBERS * A, W in er, Chairman Mines Branchf Canada E. M. Fenner'; V ic e Chairman ' Johns-M anville V ' ' < ; v W. H. Ashton Johnson & Johnson A. M. Harvey R. T. V a n d e rb ilt C. S. Thompson R. T. V a n d e rb ilt G. Foy Quebec Department o f N a tu r a l Resources M. G riraard, M .D ., PhD Department o f H e alth and W elfare o f Canada P. V. P e ln a r, M.D, in s titu te fo r Occupational & Environmental Health J . LePoutre, M.D. Belgium E t e m it G. Gagnon Lake Asbestos P. C. Cooling Asbestos Corporation R. H. Mereness Asbestos Info rm ation A ssociation P. A. F ilte a u Quebec Asbestos M ining A s s o c ia tio n T . D. Oulton Engelhart M inerals M. C o s e tte , S e c re ta ry Quebec Asbestos M ining A s s o c ia tio n M. LaChance Quebec Asbestos M ining A s s o c ia tio n CRMC-MAD-000467 Johns-Manville Internal Correspondence To: J. H. Swen s e n Date: April 22, 1976 From: R. S. Lamar P. Kotin, E. M. Fenner, R. P. Carter, H. R. Keefe, Copi: h . Kranich, D, C Subject: REPRINT OF PAPER: "MORTALITY STUDY OF T A L C M I N E R S A N D M I L L E R S " BY G I O V A N N I F. RUBINO, ET. AL. FROM THE JOURNAL OF OCCUPATIONAL MEDICINE, MARCH, 1976 VOL. 18, NO. 3, pp. 186 - 193 The attached reprint was sent to us from our good friend W. H. Ashton, J o h n s o n 6 J o h n s o n Co. There are several key points: (1) The studies of K l einfeld, et. al. of N e w Y o r k state "talc" workers show that the incidence of carcinoma of the lung and p l e u r a a m o n g t hese w o r k e r s is about four times that of the general population. (2) T h e s e N e w Y o r k " t a l c s " are k n o w n to c o n t a i n not o n l y the mineral talc but also other silicates such as serpentine, tremolite, and anthophyllite. In this respect Kleinfeld's findings are misleading since the effects of exposure to talc mineral are not defined. (3) R u b i n o ' s studies, c o n d u c t e d among talc w o r k e r s at Val Chisone, Italy, are far more definitive regarding exposure to pure talc mineral since these products contain at most only trace amounts of tremolite and chrysotile. C4) Rub i n o c o ncludes f rom his studies that there is no cancerogenic effect attributable to pure talc (mineral). It would be my recommendation that this information be used in our marketing efforts with Penhorwood. It would appear that Vanderbilt's problems are multiplying (not to mention our own with Desertalc). R. S. Lamar CRMC-MAD-000468 Johns-Manvi!! f Internal Correspondence To: H. R. Keefe - 2W From: R. S. L a m a r Copies: g e e en(j Q f c o r r e s p o n d e n c e Date: J a n u a r y 7, 1975 Subject: Y O U R M E M O OF J A N U A R Y 2, 1 9 7 5 TO P. KOTIN, " T A L C A N D A S B E S T O S " I cannot help but feel that some additional input from Research is needed here. Several points: 1. T h e N a t i o n a l P a i n t and C o a t i n g A s s o c i a t i o n is s i m p l y a trade organization. It carries no legal weight. We are still bound by the law as described in OSHA documents. It seems to me that Stender, in his l e t t e r o f O c t o b e r 9, 1974, d e s t r o y s h i s o w n organization. Until this confusion within OSHA is resolved, we have no choice but to comply with the law as written. 2. A s I r e a d t h e N P & C A B u l l e t i n No. 20, I g e t two strong impressions: a. R a t h e r t h a n c l a r i f y i n g t h e m a t t e r , as stated, they only add to my confusion. b. A s b e s t o s is n o t r e a l l y a s b e s t o s , b u t it c a n be anything you w ant to call it, e.g., "commercial talc." 3. I a m g r e a t l y c o n c e r n e d w i t h th e p o i n t r a i s e d by A. F i n k b i n e r at o u r l a s t m e e t i n g . T his h a s to do specifically with the fact that we are "sitting" on information which shows quite conclusively that R. T. V a n d e r b i l t ' s t a l c p r o d u c t s c o n t a i n n o t o n l y tremolite, but significant amounts of chrysotile and anthophyllite as well. What might be J-M's legal responsibility by withholding such information? Refer t o : CRMC-MAD-000469 H R. K e e f e - 2- J a n u a r y 7, 1975 M e m o O c t o b e r 9, 1974 V. E. W o l k o d o f f to R. S. L a m a r R e p o r t No. 41 4 - T - 3 3 , O c t o b e r 4, 1974 M e m o O c t o b e r 10, 1974 K. L. J a u n a r a j s to R. S. L a m a r M e m o O c t o b e r 23, 1974 V. E. W o l k o d o f f to R. s. L a m a r M e m o O c t o b e r 11, 1974 R. S. L a m a r to V.'E. W o l k o d o f f 'Do we still intend to provide OSHA with this informa tion on Vanderbilt's talc products? I also feel that w e s h o u l d p r o v i d e t h i s i n f o r m a t i o n to R. T. V a n d e r b i l t . 4. F i n a l l y , t h e r e a l q u e s t i o n is m e d i c a l in nature. F r o m information I have from Kotin and Fenner, there is more than ample reason why we should label regardless of what the law might say. And, this could in time have a great deal to do with J-M's legal as well as its moral obligations. I guess what I'am really trying to say, Harry, is that the decision to label was right and should not be subject for reconsideration. We have to learn to live with it in a business sense regardless of how difficult this appears. R. S. L a m a r kjn attachment cc: P. K o t i n 4N F. J. S o l o n 4N E. M. F e n n e r 4N A. C. F i n k b i n e r - 5W P. A. M a r t i n s o n - 2W H. Kranich - 2W W. C. S t r e i b File: 259-6.1 CRMC-MAD-000470 Johns-Manvle Internai Corresponden P. Kotin Date: January 2, 1975 Ff0m: H. R. Keefe Copt#*: listed Below Subject; Talc and Asbestos Attached is a letter we recently received from he National Paint and Coating Association. This letter has been sent to all members of this Association. Please note Page 3 under Recommendations. We feel quite confident that R. T. Vanderbilt Company will certify that their talc does not contain asbestos per this paragraph. A speedy resolution of the confusion caused by OSHA and their definition of fiber is necessary so that me might have answers concerning our talc for our customers. Harry R. Keefe HRKtccr Attachment cc: P. A. Martinson H. Kranich A. C. F. Finkbiner F. J. Solon R. S . Lamar ^ E. M. Fenner D/C CRMC-MAD-000471 N o . 20 December 5, 1974 TALC A N D THE OSHA ASBESTOS STANDARD 1910.93a NATIONAL PAINT & COATINGS ASSOCIATION 1100 Rhodt Itltnd A ttn vt, N.W. Wtihlngton, O.C. 2W0S Ttltphont 202 4C2-<272 ROUTE TO: Dtptumtni Fin n ic* A pm lnitlr*l-cn S titt Ttchm ctl P ro d u ctio n Executive Synopsis The OSHA Asbestos Regulation 1910.93a includes, in its definition of asbestos, a mineral form (tremolite) that is found in some talcs, but is not generally considered an asbestiform material (see Safety and Health Bulletin N o . 15, "Asbestos Handling Guidelines" dated October 30, 1973). Through the extensive efforts of several NPCA members, a clarification of the regulation was obtained from OSHA. This now allows talc manufacturers to certify their material is "asbestos free" and the user of that talc is then exempt from regulation under 1910.93a. A C T IO N REQUIRED BY Y O U - Forward this Bulletin to the person or persons responsible fc<- your safety and health operations. A C T IO N TAKEN BY NPCA - Through the efforts of NPCA members and the Occupational Health Task Force a clarification of the standard was accomplished. OPERATIONS AFFECTED IN YOUR CO M PA NY - Manufacturing, safety and health. STAFF CONTACT AT NPCA -- Richard W . Murry, Assistant Technical Director CRMC-MAD-000472 BACKGROUND Page 2 With the promulgation of the asbestos Standard 1910.93a in July 1972 the possibility of certain talc materials being regulated as asbestos was created. According to the regulation, asbestos is defined as the following mineral forms: chrysotile, amosite, crocidolite, tremolite, anthophyllite, and actinolite. While some talcs are indeed marketed as containing asbestiform minerals and noted for their fibrous properties, the standard also encompassed other talcs not previously considered to be fibrous or considered to contain asbestiform materials. These are the tremolite (or more correctly non-asbestiform tremolite) containing talcs. Since late 1972 the R. T. Vanderbilt Company Inc. and the International Talc Company (later purchased by Vanderbilt) have had numerous meetings with O S H A officials to obtain a clarification on the regulation of the talcs under 1910.93a. RECENT DEVELOPMENTS On October 9 , 1974 in a letter to M r. H . B. Vanderbilt, President of R. T, Vanderbilt Company, In c ., M r. John .'tender, Assistant Secretary of Labor, stated in part: " . . . i f you (the talc manufacturer) have scientific evidence that the naturally occuring talcs, prior to processing by milling or crushing, do net contain fibreu $ or asbestiform tremolite, anthophyllite, actinolite or other asbestiform minerals t you may certify to your customers that the talc does not contain asbestos." (A copy of the letter is attached to this bu lletin.) Also a directive to such effect has been issued to OSHA field personnel as a guide in making inspections. This directive indicates that if a taic user,i^e., a paint and coatings manufacturer, is monitored for asbestos the person behind the microscope counting fibers should use the following identification criteria: A . Particles must appear to be fibrous rather than as crystals or slivers. B. The maximum diameter of a fiber to be counted is 3 microns. C . The maximum length of a fiber to be counted is 30 microns. CRMC-M A D -0 0 0 4 7 3 D . The length to width ratio must be 5 or m o r t o 1, that is, 5 times or more longer than wide. E. The separate or individual fibers must contain fibrils or the "bundle of sticks" effect, unless they are at a nondivisible stage. A fibril cannot be subdivided dnd would be counted, if it meets the other criteria. The electron microscope may be used to prove the fibrous nature of the particles. The length to width ratio of 5 cr more to 1 is not meant to imply that other particles are not hazardous. Page 3 The directive further states that if the talc is of the non-asbestiform or non-fibrous variety the time weighted average (TWA) of 20 millions of particles per cubic foot of a ir (mppef) w ill be used. If monitoring of your operations using talc is done by the OSHA inspector you should retain a sample of the talc material being used in the event a discrepancy may arise. RECOMMENDATION If you have been using talc products that have been questionable regarding asbestos ifj content, request certification from the manufacturer that they do ;iot contain asbestos, ijj Retain this certification to show to an OSHA inspector if he questions the asbestos content of the ta lc . If it is however determined that a talc does contain true asbestiform minerals, that material w ill not be certified and is subject to the provisions of the regulation.' 0 l CRMC-MAD-000474 U.S. DEPARTMENT OF LABOR Occupational Safety and Health Administration WASHINGTON, D.C, 30210 Office of the Assistaat Secretary OCT 9 1974 Mr. B ..B . Vanderbilt President .Chief Executive Officer R. T. Vanderbilt Company, Inc. . 30 Winfield Street .Norwalk, Connecticut ; 08855 ' .* `.Dear Mr. Vanderbilt: This is in reply to .ym:x J-tter ;of .September ;26, concerning your .request. for relief from .the asbestos.standard.t o r .your talcs containing non-fibrous tremolite; actinolite, and anthophyllite. ;My letter'of'August- 6 stated that nen-fibre us or nen-asbestifem minerals such.as non-ashestiform tremolite are not within.the -scope of the asbestos standard and, therefore, the provisions of that standard do not apply to talc containing non-asbestiform minerals. # NIOSH.is currently.conducting a thorough investigation into the exact minerals .to .which talc workers were exposed in those ..studies .where,asbestosis or.other.adverse medical.effects were.found. * Pending .the receipt and evaluation by OSHA .of the report by NIOSH on.this investigation, if y o u h a v e scientific:evidence that the naturally occurring talcs, prior to processing by milling or . crushing, do not contain fibrous or asbestiform tremolite, ' anthophyllite, actinolite or other asbestiform minerals, you may.certify to.your customers.that the talc does.not contain asbestos. Fibrous, asbestiform minerals such as fibrous tremolite means naturally occurring asbestiform minerals which prior to or after crushing and processing, contain fibers made up of fibrils. Johns-Manville Internal Correspondence To: P. Kotin, M.D. 1'. P. C a r t e r Dr,*: April 8 , 1975 Copi: File & Chrono Subject: MONTHLY ACTIVITY REPORT DIRECTOR, GOVERNMENT AFFAIRS MARCH, 1975 FDA REGULATION OF GLASS FIBER FILTERS The Food and Drug Administration promulgated a regulation restricting the use of glass fiber filters in the manufacture of parenteral drugs. Met with J-M*s Washington law firm to prepare a notice contesting this regulation. Met with various FDA officials to ascertain why this regulation was promulgated. PVC PIPE MIGRATION STUDIES Prepared and sent letters to both EPA and FDA reporting the results of Phase II of J-M's PVC pipe (VCM migration) studies. Met with EPA and FDA officials along with Randy Prust of R&D to review our test results. No objections were received from either agency as to J-M's test procedures or results. EPA has agreed to conduct field studies in communities supplied drinking water through PVC pipe. UNI-BELL BOARD OF DIRECTORS MEETING Delivered a presentation to the Board of Directors of Uni-Bell on J-M's PVC pipe migration studies and a prognosis of actions by EPA and FDA on PVC pipe. The member companies of Uni-Bell agreed to supply necessary data to EPA for PVC pipe field studies. FEDERAL TRADE COMMISSION - TALC LABELING Met with two members of the FTC staff along with Aaron Fir.kbine. ^ to discuss the possibility of the FTC bringing suit against ^ R. T. Vanderbilt Company for false certification of their talc. i FDA REGULATION OF TALC CONTAINING ASBESTOS 9, . ; ! --' 3 As a result of studies conducted by 0-M, the FDA published o a notice in the Federal Register withdrawing its proposed % regulation restricting the use of talc containing asbestos ^ in food and drug packaging paper and paperboard. ( \ Johns-Manville To: v. E. Wolkodcff From: r . s. Lamar DMP October 11, 1974 Copies: see end of correspondence Subject: y o u r MEMO OF OCTOBER 9, 1974 OPTICAL AND TEM COUNTING OF ASBESTOS MINERALS IN ASBESTINE 3X, ASBESTINE 325, NYTAL 200, AND NYTAL 400 AS CURRENTLY PRODUCED BY R. T. VANDERBILT CO. Thank you Vlad for your very fine report covering your microscopic examination of these samples. Your data confirm analyses we have had made on these same samples by J . P. McGourty using X-ray diffraction techniques (Report No. 414-T-33) and by X. Jaunarajs using differen tial thermal analysis - primarily for the detection of serpentine mineral. These present samples are really no different from previous samples of Nytal and Asbestine that I have examined periodically over the years. They all contain very sub stantial amounts of both tremolite and chrysotile and in two cases substantial amounts of a third asbestos mineral, anthophyllite. In numerous discussions I have had with R. T. Vanderbilt people, they have readily admitted to having tremolite ("which is not an asbestos mineral and is not fibrous") , but they have never admitted to the presence of either chrysotile or anthophyllite. They do admit that years ago, when they were deliberately mining certain sections of their deposits for fiber, some of their products did contain chrysotile. This product, "Mouldene," was sold as a direct replacement for asbestos in the manufacture of vinyl tile. I have examined "Mouldene" in the past and it was in fact almost entirely chrysotile. "Mouldene" is no longer being made, but all of the International Talc Company and R. T. Vanderbilt Company talc products always have and continue to contain chrysotile as a significant mineral component (in addition to tremolite and anthophyllite). CBMC-MAD-000477 V. E. W olkodoff 2- O ctober 11, 1974 It is apparent that the R. T. Vanderbilt presentations to OSHA, NIOSH, FDA, MESA, etc. are based on something less than the truth. I find it difficult to believe that they could be so grossly misinformed as to what their materials really are. How this information is ultimately used is something that will have to be decided at higher levels within J-M. However, it is my belief that R. T. Vanderbilt, with a continuance of their present methods, does nothing but confuse the issue among the talc producers and with the various Federal agencies involved. Any properly informed person would know that they are wrong. R. S. Lamar kjm cc: R. P. Carter E. M. Fenner P. Kotin W. B. Reitze F. J. Solon, Jr. G. L. Swallow A. C. F. Finkbiner, J. A. McKinney H. R. Keefe P. A. Martinson C. J. Sulewski W. L. VanDerbeek R. G. Riede - 4n - 4N - 4M - 4N - 4N - 4M Ill - 5W 5W - 2W - 2W - 2W - 2S - 2S File 414-C R. T. Vanderbilt F. L. Pundsack W. C. Streib J. P. Leineweber S. Speil A. J. McArthur CRMC-MAD-000478 j *uyynTDwTwW wIOtiiw . (VwA mWinwfnPinPllfPflPfifrf mfYinnfni 1 1 St a t u s Re p o r t De v e l o p m e n t o f Asbestos St a n d a r d f o r the Pr o d u c t i o n : : ^ cffitjDF Crushed St o n e 'aSflip-jja-.-.' April 7, 1978 Background1 B y n o w / m o s t p e o p l e o n the Ea s t Co a s t a n d m a n y p e o p l e t h r o u g h o u t t h e Un i t e d St a t e s k n o w t h a t t h e Un i t e d St a t e s En v i r o n m e n t a l Pr o t e c t i o n Ag e n c y (EPA) w a s a p p r i s e d t h a t c r u s h e d s t on e f r o m the Ro c k v i l l e Cr u s h e d St o n e , In c o r p o r a t e d , q u a r r y c o n t a i n s a s b e s t o s a n d t h at t h e use o f t h a t c r u s h e d s t o n e in an u n b o u n d f o r m on r o a d w a y s r e s u l t e d in e l e v a t e d l e v e l s of a i r b o r n e a s b e s t o s n e a r t h o s e r o a d w a y s * Se v e n y e a r s a g o , t h e Na t i o n a l Ac a d e m y of Sc i e n c e s , f o l l o w i n g the l e a d o f m a n y o t h e r m e d i c a l e x p e r t s , c o n c l u d e d that exposure to airborne asbestos fibers is di re c t ly related to human diseases such as pulmonary fibrosis, carcinoma, and pleural m e s o t h e l i o m a . Th u s , EPA, in c o n j u n c t i o n fWiTH t h e Mo n t g o m e r y Co u n t y De p a r t m e n t o f En v i r o n m e n t a l Pr o t e c t i o n a n d t h e Ma r y l a n d Bu r e a u of Air CRMC-MAD-000479 2 Qu a l i t y Co n t r o l , c o n d u c t e d a Df-tAiLED i n v e s t i g a t i o n of the Ro c k v i l l e - ' .#.-! '* > s i t u a t i o n * Sa m p l e s c o l l e c t e d i n -an EPA a n d Mo n t g o m e r y .Co u n t y lEP c o o p e r a t i v e s t u d y a n d a n a l y z e d b y EPA c o n f i r m e d t h a t e l e v a t e d l e ve l s of AIRBORNE ASBESTOS CAN OCCUR FOR SOME UNBOUND USES OF THE CRUSHED STONE* So m e o f t h e r e s u l t s w e r e so h i g h EPA He a l t h Ef f e c t s Re s e a r c h La b o r a t o r y c o n c l u d e d t h a t t h e 'coNC^iTfiATiONS "a r e s u f f i c i e n t to c a us e g r ave concern for the health of people thus exposed" and recommended that "m e a s u r e s be i n s t i t u t e d i m m e d i a t e l y t o r e d u c e t h e s e c o n c e n t r a t i o n s of a i r b o r n e a s b e s t o s a s m u c h a n d as r a p i d l y a s is t e c h n i c a l l y f e a s i b l e * " 2 Ac c o r d i n g l y , on Jun e S, 1977, EPA f o r m a l l y r e c o m m e n d e d th at the Mo n t g o m e r y Co u n t y Ex e c u t i v e i m p l e m e n t s e v e r a l s p e c i f i e d i n te r i m and p e r m a n e n t a c t i o n s to p r e v e n t o r r e d u c e the e x p o s u r e t o a s b e s t o s .3 Su c h a c t i o n s h a v e been i m p l e m e n t e d in Mo n t g o m e r y Co u n t y a n d t h e Ma r y l a n d Bu r e a u of A ir Qu a l i t y is p r o p o s i n g r e g u l a t i o n s t o a p p l y t o the e n t i r e St a t e * Ot h e r q u a r r i e s are e x p e c t e d to p r od u c e a s b e s t o s - c o n t a i n i n g c r u s h e d s t o n e * EPA has initiated a p r o g r a m to d e t e r m i n e the e x t e n t a n d to d e v e l o p a Fe d e r a l s t a n d a r d if n e c e s s a r y to s u p p l e m e n t St a t e r e g u l a t i o n s * toHQ&iiQILCi; As s t at e d in the No v e m b e r 1 0 ,;19 7 7 , Ad v a n c e No t i c e of Pr o p o s e d Ru l e m a k i n g (42FK58543), t h e U n i t e d .St a t e s En v i r o n m e n t a l Pr o t e c t i o n Agency is studying the c r u s h e d stone industry t o d e te r m in e the extent to which q u a r r y i n g o p e r a t i o n s a r e b e i n g c o n d u c t e d in a r e a s c o n t a i n i n g s e r p e n t i n i t e ROCK DEPOSITS, THE ASBESTOS CONTENT OF THE ROCK BEING MINED, AND WHETHER CRM C-M AD-000480 3 THE PUBLIC IS BEING EXPOSED TO ASBESTOS FROM VARIOUS USES OF THE ROCK*^ ,Th e Ad v a n c e No t i c e i n c l u d e d a b r i e f s u m m a r y o f t h e d a t a a n d the a c t i o n s TAKEN IBnTGOMERY COUNTY* ALL INTERESTED PERSONS WERE ASKED TO SUBMIT ADDITIONAL INFORMATION BY JANUARY 10, 1978. On l y f i v e c o m m e n t a t o r s r e s p o n d e d : ASARCo, In c o r p o r a t e d ; R. T . Va n d e r b i l t Co m p a n y , In c o r p o r a t e d ; Jo h n s -Ha n v i l l c Sa l e s Co r p o r a t i o n ; t h e Na t i o n a l Cr u s h e d St o n e As s o c i a t i o n ; a n d Ve n a b l e , Ba e t j e r a n d Howard (r e p r e s e n t i n g Ro c k v i l l e Cr u s h e d St o n e , In c o r p o r a t e d ; t h e Ar u n d e l Co r p o r a t i o n , D. f-1* St o l z f u s a n d So n , In c o r p o r a t e d ; a n d Blue i'Io u n t Crushed St o n e , In c o r p o r a t e d )* Ea c h o f the f ive c o m m e n t a t o r s s t a t e d e i t h e r that a NATIONAL EMISSION STANDARD WAS NOT JUSTIFIED OR THAT A WELL-DEFINED ASBESTOS HEALTH EFFECTS THRESHOLD SHOULD BE ESTABLISHED BEFORE AN EMISSION STANDARD IS DEVELOPED* No NEW DATA WERE SUBMITTED IN RESPONSE TO THE Ad v a n c e No t i c e * In f o r m a l c o m m e n t s b y e n v i r o n m e n t a l i s t s who had previo usly URGED EPA TO PROPOSE A STANDARD AS SOON AS POSSIBLE REITERATED THEIR POSITION THAT THE DATA WERE SUFFICIENT TO DEMONSTRATE THE NEED FOR A STANDARD* Other than the health effects c o m m e n t s , the most significant comments WERE THOSE THAT QUESTIONED THE ACCURACY AND PRECISION OF THE AIRBORNE ASBESTOS DATA* Of COURSE, EPA HAS BEEN AWARE FOR SOME TIME THAT ASBESTOS ANALYSIS RESULTS HAVE A U R G E VARIANCE WHEN DIFFERENT METHODS ARE USED BY DIFFERENT LABORATORIES* FOR THAT REASON, THE EPA OFFICE OF RESEARCH AND De v e l o p m e n t (ORD) h a s e x p e n d e d c o n s i d e r a b l e e f f o r t o v e r the l ast three YEARS IN DEVELOPING A STANDARDIZED/ DETAILED PROCEDURE FOR ELECTRON CRMC-MAD-000481 MICROSCOPE MEASUREMENT OF AIRBORNE ASBESTOS CONCENTRATIONS* A PROVISIONAL Methodology i'Ia nual (EPA-600/2-77-178) was published in Au g u s t , 1977, a n d IS CURRENTLY UNDERGOING DETAILED REVIEW BY CRD AND THE ASBESTOS ANALYSIS c o m m u n i t y * Th e Of f i c e o f Re s e a r c h a n d De v e l o p m e n t w a s r e c e n t l y a s k e d to PREPARE AN ASSESSMENT OF THE STATUS OF DEVELOPMENT OF AN ASBESTOS ANALYSIS p r o c e d u r e * Th e Pr o v i s i o n a l Me t h o d is e x p e c t e d to be c o n f i r m e d as the INTERIM PROCEDURE THIS MONTH* Qu a r r y Id e n t i f i c a t i o n La s t s u m m e r , the En v i r o n m e n t a l Pr o t e c t i o n Ag e n c y r e q u e s t e d the a s s i s t a n c e of the Bu r e a u of Mines (BGM), the Un i t e d St a te s Ge o l o g i c a l Su r v e y (USGS), a n d the M ining En f o m i m e n t and Sa f e t y Ad m i n i s t r a t i o n (MESA) to determine the extent to which quarrying operations are being conducted in a s b e s t o s -c o n t a i n i n g r o c k * E S A is c o n d u c t i n g a l o n g -t e r m s t ud y to d e t e r m i n e w h i c h m i n i n g o p e r a t i o n s e x c e e d the MESA w o r k e r e x p o s u r e s t an d a rd of f i ve a s b e s t o s f i b e r s per c u b i c c e n t i m e t e r o f a i r * The rESA s t u d y is an i n v e s t i g a t i o n o f a l l m i n i n g o p e r a t i o n s in a r e a s o f m e t a m o r p h i c r o c k * S ince the PESA s t u d y e n t a i l s a n i n v e s t i g a t i o n o f s e v e r a l t h o u s a n d m i n e s , INCLUDING 1574 ROCK QUARRIES, CONSIDERABLE TIME AND EFFORT WILL BE REQUIRED* In THE MEANTIME, EPA IS CONCENTRATING ON ROCK QUARRIES THAT f-lAY CONTAIN SERPENTINITE (GEOLOGISTS AGREE THAT SERPENT1NITE USUALLY CONTAINS AT LEAST SOME ASBESTOS)* CRMC-MAD-000482 Last w i n t e r , th e US6S a n d BUil p r o v i d e d EPA w i t h m a p s of s e r p e n t i n ite AND OTHER ULTRAMAFIC ROCK DEPOSITS AND MAPS OF MOST QUARRY LOCATIONS* DY COMPARING THE MAPS AND USING APPROPRIATE MARGINS TO ALLOW BOR THE IMPRECISION OF THE MAPS, EPA WAS ABLE TO PREPARE A LIST OF APPROXIMATELY 300 QUARRIES LOCATED WITHIN OR IN THE VICINITY OF SERPENTINITE BELTS* HE a p p r o p r i a t e St a t e g e o l o g i s t s w e r e th en a s k e d f or THEIR ASSESSMENTS OF THOSE QUARRIES BY MARCH 1* SEVERAL HAVE STILL NOT RESPONDED* HIS SCREENING PROCEDURE HAS ALLOWED EPA TO CLEAR APPROXIMATELY 100 QUARRIES FROM THE LIST OF 300* Ha v i n g t h u s a s s e s s e d a l l o f t h e Un i t e d St a t e s e x c e p t Al a s k a ,'EPA h a d ORIGINALLY PLANNED FOR GEOLOGISTS TO INSPECT EACH OF THE SUSPECT QUARRIES TO DETERMINE IF SERPENTINITE IS PRESENT* IN FACT, EPA AND EPA CONTRACTORS HAD SPENT CONSIDERABLE TIME IN DEVELOPING A STANDARD PROCEDURE* nOWEVEK, THE CRUSHED STONE INDUSTRY REFUSED TO COOPERATE IN A PROGRAM TO ESTABLISH THE ACCURACY AND RELIABILITY OF SUCH INSPECTIONS* Co n s e q u e n t l y , EPA n o w p l a n s t o o b t a i n c r u s h e d s t o n e p r o d u c t s a m p l e s FROM THOSE QUARRIES FOR WHICH NO FIRM ASSESSMENT HAS BEEN RECEIVED* Ad d i t i o n a l i n f o r m a t i o n is n e e d e d f o r q u a r r i e s in 12 St a t e s * EPA h a s STARTED ISSUING CONTRACTS FOR PETROGRAPHIC ANALYSES OF THESE SAMPLES* Al s o , c o ntr ac ts ar e be ing issued for elect ro n m i c r o s c o p e an aly se s of CRUSHED STONE SAMPLES FROM THOSE QUARRIES WHICH ARE KNOWN, OR FOUND, TO CONTAIN SOME SERPENTINITE* BEGINNING NOW AND CONTINUING OVER THE NEXT FOUR TO SIX MONTHS, EPA INTENDS TO HAVE CONTRACTORS EXAMINE CRUSHED STONE CRMC-MAD-000483 6 SAMPLES FROM AT LEAST 80 QUARRIES TO DETERMINE WHETHER THEY CONTAIN SOME SERPENTINITE AND TO START ELECTRON MICROSCOPE ANALYSIS PROGRAMS FOR QUARRIES FOUND TO BE MINING ROCK CONTAINING SOME SERPENTIN ITE St a n d a r d s De v e l o p m e n t Or d e r l y p r o g r e s s t o w a r d s d e t e r m i n i n g w e t h e r EPA s h o u l d p r o p o s e a NATIONAL EMISSION STANDARD IS DEPENDENT NOT ONLY ON DETERMINING WHICH QUARRIES CONTAIN ASBESTOS DUT ALSO ON ASSESSING THE DEGREE TO WHICH THE PUBLIC IS EXPOSED TO UNBOUND USES OF THE CRUSHED STONE INFORMATION HAS BEEN REQUESTED FROM FEDERAL, STATE, AND LOCAL HIGHWAY DEPARTMENTS; STATE AND LOCAL AIR POLLUTION CONTROL AGENCIES; STATE MINERAL RESOURCES DEPARTMENTS,* CRUSHED STONE TRADE ASSOCIATIONS; AND CRUSHED STONE PLANTS Su c h in formation is not r e a d i l y a v a i l a b l e Wh i l e EPA h a s b e e n g a t h e r i n g t h e p r i n c i p a l i n f o r m a t i o n o n a s b e s t o s OCCURRENCES AND AIRBORNE ASBESTOS CONCENTRATIONS^ EPA HAS ALSO BEEN PREPARING SUPPLEMENTARY INFORMATION, SUCH AS COMPUTER MODELLING OF THE DISPERSION OF THE ASBESTOS EMISSI^ AND THE ECONOMIC IMPACTS OF CONTROL ALTERNATIVES Th e CURRENT SCHEDULE INCLUDES COMPLETION BY THIS FALL OF THE ALREADY STATED EFFORT TO DETERMINE WHICH QUARRIES CONTAIN ASBESTOS AND COMPLETION OF QUANTIFICATION OF THE ASBESTOS CONTENT BY THE FIRST OF NEXT YEAR Th e s e e f f o r t s a r e t h e p r i n c i p a l p a c e -s e t t i n g f a c t o r s for the d e v e l o p m e n t CRMC-MAD-000484 7 OF AN SI I SSI ON STANDARD IF NECESSARY TO SUPPLEMENT STATE REGULATIONS* OiNCE THE ANALYSES ARE COMPLETED, A DRAFT STANDARD SUPPORT AND ENVIRONMENTAL Im p a c t St a t e m e n t c a n b e d i s t r i b u t e d w i t h i n a m o n t h o r t w o * CRMC-MAD-000485 Re f e r e n c e s ! Ju l y 7, IS77, Fa c t Sh e e t 2. Ju ne 1, 1377, He a l t h As s e s s m e n t by EPA He a l t h Ef f e c t s Re s e a r c h La b o r a t o r y 3. Ju n e 6, i977, Re c o m m e n d a t i o n s t o Mo n t g o m e r y Co u n t y Ex e c u t i v e fr om EPA Re g io n III 4 No v e m b e r 10, 1977, Ad v a n c e No t i c e of Pr o p o s e d Ru l e m a k i n g CRMC-MAD-000486 To UUa <lk1 nepvniee, la MraOaaci wltl prrxrtnrta 4nrlad wlifc Qm tm nrrme a t t a Amar and Nrr Manidon Botri 0 mrrlem et tfcs m tnctiac aad prtearmmt Onn iM laTHlm f Ih Wir u< N 7 * pam nant. U caaafcOoa U h p ii a r iti and ra U ta i a B ar*. To * * * pnhrtm em w lth part to ladine d a ta a ta rla i, aad da- a n a fir aa (a ra tri a la tili, p orm ant (e n e d a * n a t u t r a q p m tta aa Nott, T m v o n , b j ttU* of th autierity -reetad Lo th afo n td Director of Prioritiaa, it i* beroby orderrd tin i : L VaLcumor u n E n a ra a x or Pa m oo* Faratira* A c m n airi O -- AH preJreix ratinr certificata, blanlat prefennoa ratine orden, and otber ardan and direction ertablialng p rioritta and all otbar action* witb m pact to pnferenca ralinga and prioritiea,and Triti napeet to ralatad mature, bamtofora nuad, r ig a i, ardend, direotad or takan by tba PrioriLi Oommitta o! tbaA ray andNary Ma n itr a Board, by tha Array and Nery linnitiooi Board, by id f o r a r Adminfcrmtor of Priaritiw and mid f o r a r P rioritio* Board, and by aaid Dinotar ofP rio rit , and by tbrir aotbority, a n bareby validatad and oont^pn ralid in effaotnatii taminatlon or expiraton by tb* t a r a th an o f^^d rau n sian o ea or oo&ditiooi of their application, or ntil Im MfiiTtri'lTatiiTiaiiiiiTialjiiiiiliriiiil. iIiiiij^i 1or arm dad by action by tba aaid Diradar of Priorit a . IL D c n n aro P atena* or m Psxsm a O m u o rra or thx A u rr i n K m H cffisan B ot L JCeUAlimont 0/ Sei dui 0/ Pr*f erm e RoXmfi (a) f a r d m y aatf Aacg anC*n.~Tba Prioritiaa Oommtta of tba Ansy *nd;Ki l'Boud dbaQ,:itb tbaieoaonnraa ef tba ......... .... ' ,taablkhaeidoJ**of lord |rimoaa-Pro- .fjpto%am. -a- - - dhpwy|ri<ta-.lba Pri* aub- ...................^ lof prtfcDa n tin p tb aorignad toeaageriai e f poetat a and ordan of tba athar a|riaa of tbe Unitad 8 ta ta G oneeaant, Kieh ball taoM ^ rn til firib a r d ar, tb* Q o t G tard, fa ritia * Commiaaiori, --rase vltk p ro m ivm rrtm i. vita tk J tfaaJdaMBoar,tkam e r k m aftktm m - \3nadaiaMdpmMUtstratdmfaUtmanW. ir ud Xtry Do -4 jAe muue ttotoaniatetftinpetMWHmi aaadateooroipdalmatateda#aa- -''ytr&ssf &s*i \Jtj * * dJCD t w . .. / V : . t*uc, K ta h t prafutaaa m in j e ra n , , tateteaSfog priotfcjaa u d all othar ;P<x ttiSgi aad priaritaa, u d witb n! r=jr PrigiiaaaBatrd, aad by j7*titirsibsefcj,rt btnby rtlidated r*`a$5' ] togshc&'r) ocyiratooby tba tenar "* ndlfixi of aar ggSrkcpj cr cat 'f.; ^a2ad^ chavad cr atondad hridtioa . .. **$ ~ W T aT c - la a Q anr?;aa cr n n Aaarr . 'AH cx es-r>ts Bou ..J ' AJar / fte /rw w I d fcft `Itfi--Tba PrittiarOonmjfciaa of tba tbo ,*. .|..i.::..'Wjl Ooaat ud Goetie Surrey, Pt&unt Can), tnd Katkusi] Adriaory Cbauntteaoc Aaranaotiea. (e) P o r f o r t if * fio * tn m * * t o rd e n .-- T h o Prioritiaa Committeaof tha x a g aadNavyIfunitiooaBoardahall,aubjacttotbaapprondof Iba Director of Priortiw, aalabliib achaduka of praftrtna* rati&p* to ba amigaed to cate*oriae of contracta and orden of ceruin fomign govaamantaiadudinc,until furtbaronkr, GraatBritaia ndCaada. t. Jm ifo m m i o f P n f e r e tm Jt o t m f* Tba aangornaat of aU aacb prafn aca n tia p to dd in riat of mate ria] usdar all eootraete acd arder berainbaiora apadfird ir paragrapb 1, asd tba exteoiion of web p n lm m n tiB ti to W irtri* of material wbkb aatar diracy or iadiractly iato tba manufactura of anj mata ra] for daliray nadar aoeh praftraaea ratiaga to dalivaria* of material 4 Priorioaa Onmnlttaof thaAnay and Kary ifunkloat Board acd tba *oatract aad piwuiamaot ofloara aad iiupartora of tba Abbj and ta r y , io aeaonlaBW uritb tba A n ^ aadXaay Prioritiaa lamnMtaaoa (eopy of bkb Ji baratoattaebad); Proridad, (a) Bocbprafaraaoanti&c abaDappljoolj to itasa vbieb appaar poo;tba Prioritiaa'Ortica] Lkt aa rariaad to liareb lt, 1M1, of tba PrfntaCkaiim^liw'yLrajr aod'KaVf Md&itkoa BC!1^ (oopgr e f ;o d d ^ k i t t ^ W b ) ; w tbcaamama; b a a o ^ ^ a modBador'Cban|d fratcuito tima br aaid immitlaa 'ntEtbaapproral oftialKmetarofTriaritim. (b) That rainp bijbar tbaa tbeaa adbcrad by tba tbao ourrwt Prieritiaa Dimetina nfam dlo b parafrapb 1 abara map ba aat&md 1 tytbaPrioritiaa OoBanitWtf tba Aimj aad K tiy bfuri^ooa Board Witbtbaooooomomof tbaDimetorof Prioritiaa. (5foad) X. B. Snaronm , J r , ICardb 1?, 1ML P irm to r o f P r ie r lm . "jp^oV..wras.oTiynrrm-v 'XS'xSr; yt, i V .fj "I *K o <f J TBS8^>5w8bs! - C6^;6t^lle^Oidi^ . ;- .. T*..*>'' - . . i : - 1 < > . - *jk CRMC-MAD-000488 4ii Ore room v \th two heira 1 designated lo r tsio ti'vav&ast of injurisn of the loror oxtrettltisse Oo Or room with 4 tables ia provided for treataoat of 7 eonditionso Infra-rsd has been used la the treatment of eoae 70 flash es, with one benefits ascribed. do One minor surgery 1 loeated oosrrsniestly to X-ray reoa sad anbulosoe entroaoeo fwo tables are provided along with nsoessary cnecbhetio fa o ilit ie s end othar equipment*. Oo A two bed word for trauen and a four bed ward for men ore prwidtd* without ssgrogation for raess f . A dootor* 8 o ffle e and examination room are present* go Burses* dressing room i s prervidedo ho A 15 m illiaapere X-ray ia available. Anything requiring a nor* powerful unit ie referred to the looal hospitalo io A physiotherapy room with 6 - 7 infra-red lamps and 5 work tables ere provided* A ll diathermy ie referred to the hospital So cost* of the referral woo obtained but in a ll other yards I t hae been found mere eoonamieal cf gewersnest funds and worker* e tia s to provide one or ere naohises cf th is typo0 I t ia reoomasnded that th is be dose here aleoo jo T oilet f a c ilit ie s ere adequate ko fitorsroaa ie nuffioient. lo looessery dark rooa and viewing apparatus I d available0 Io inforaation of scd leal costs were available. c e m c -w ^ ' 000489 m m B Z ^ r r -^ r ^ -5 E2j gqulpBoat a Ob* aabvianoe is aov provided. I t Is a sofsrtsd station wagon whioh is about torn oste I as Inferred th a t request fear re plaesrent has basa mad# This should be granted as seen as pesslbls to assure th at adequate transportation is available b So au xiliary transportation is proridod although a p ritate tabulano nay bo obtained i f needed o X-ray equipment is adequate* do Beoesesry dispeaaary stores aro proridod* E5 Reoorde sad Pores 5*1 SuaaaryofEeoordeandFornB a* A foertnaa* pass is required fo r aaoh r l s i t r which shoes tin e the pass is issued* The tia e patieat leatss the dispeascry ie also narked The patient does not oheok iato the dispensary but presseds d ireo tly fo r treatment. Ths nareeor doeier nakes the aeeoascjry notes,, laeludlag diagnosie and treatasat aad disposition of the oase on the forareaVs pass, a fte r whioh the patient then goos tooths olerk etere a reeord card ie nads out* This do net pretide opportunitie s fo r oheekisg the patient into the dlcpsnsary There is thus no opportunity of detem iaing the tin e taken by the patient in arriving a t the dispensary or tino spent in resetting treatsent* Oaspliaaos w ith "Xiainua Reqrireaento... paragraph 5ln is th is regard is raeoareadod* This ooold be easily done by plaoiag a tin e narking dorioe a t the szitronee fo r men or a elerk to use in stamping the firs t-a id pass* b. Subsequent ra ri sits or rcoerded and noted on the foronanvs pass which aro supposed to be transcribed to the original reeord eard. C R M C -M A D -000490 * I Oc t*'.'ci 9, 1974 t )Jr. 1?. B. Vanderbilt Trcsidcnt Chief Executive Officer ft. T. Vanderbilt Conpany, Inc.* 30 Vinfield Street Korvalk, Connecticut 08855 Dear Mr. Vanderbilt # cz -h' This is in reply to your letter of September '2(5, concerning your request for relief iron the asbestos standard for your teles containing non-fibrous trcaolite, actinoiite, 'and anthophyllite. My letter of August 6 stated that non-fibrous or non-asbestiforn minerals such as non-asbestifora tromolite are not within the ccope of the asbestos standard and, therefore, the provisions of tbst standard do not 'apply to tele containing non-asbcstifora minerals. * * KIOSH is currently conducting a thorough 'ir.vcstigatiu;: into tise exact minerals to which tale workers were exposer* cl those studies vhere asbestosis or other adverse medical effects were found. Tending the receipt and evaluation by OSEA of the report by KIOSH on this investigation, if you have, scientific evidence that the naturally occurring talcs, prior,to| processing by milling or crunching, do not contain fibrous or ashestiform tremolite, AQtophyllite, actinoiite or other, csbestiform minerals, you nay certify to-your customers that the talc does not contain acbcstos. , Fibrous, asbestiform. minerals such as fibrous tremolite means naturally occurring asbcsciform minerals which prior to or after crushing and processing,- contain fibers cade up of fibrils. Sincerely, , /s/ John H. Stender . . John It. Stender Assistant Secretary of Labor CQ14583 C R M C -M A D -000491 by Jar.*-? V-dman A recent wortcahop on asbr-os attracted experts from mcny disciplines -id severs, nat.ons. Information on cu-ront - othods and experiments irr.olvine asr' -n was pre* ser.'ecJ. and mer, fy .a ir iuestions we; a raised. One bas e oengreement cerv terc j around a definition of :*e -err. " ai.estos." " ~ Utile millions of Americans flocked to asbestos "aodardized procedure likely to be , beaches and lemonade stands for relief universally acceptable to the scientific and in- y fiu.ii hr mid-July heat wav, do- dmtriai communities. . ::shed scseatists frcaj the L'.S.<>td abroad .'"red the sweltering amditions to gather at the '-.ere complex of the National Bureau of i 'Jards (NBS) in Gaithersburg. Maryland. 1: rr-e. the torrid weather was an incongruous !<..r?und for the July 18-20 meeting. The ;s were discussing a heat-resistant mate-s--but not how it might be applied to the threat of heat prostration. Eminent ; c;iic;aIot3b. biuiucivo industrial -r. nis. and physicians had congrcr *ed at the >C5!hA*spor.sored "Workshop n Asbeso discuss what factors must be considered rs-rarchers and governmental regul. ory - when addressing health problems (luag pleura! and peritonea! mesoAciiuatii, cstosis) assouidied with asbestos expo- T ie standard p- jeedure also dd have to be acceptable to t- s many rover: ntmt agencies involved in regulating asbestos exposure. 1;. addition to OSHA, the Environmental Prater tion Agency (EPA ), the Food ana Drug Admii istratsou, the Consumer Product Safety Comni;son. and ti e Mining Enforcenen: ar.d Safety Adniintstrauon are loolrcg at the preclerc. posed by asbestos expos. as it occurs in hp r respective regulc ory :res. Ncnreguhior. agencies s-:h as NIOSH, he National Intitule of Environmental Health Sciences, and the Nauona! Cuncer Institute are also researching the healf. effects of asbestos exposure Currer::* ty, only EPA has-a firmly established procedure for analyzing fibers suspected to be asbtstifi nm In conducting analyses, OcHA uses a very c!:oertte series of tests which wrre recommer Jed by ' '-iainc: what OSHA huped To gain in"NfOSH. Mirtonik exp'ains, "t>u; Su.. La'> c tig the conference. John Marton.lt, an Gty laboratory must devote so tuc.. of its tu: r : ;i hygienist in OSHA's Directorate of to analysis work that there is rrcct 1 ' i. .. Support ana cnairperson lor the work- in which to develop formal procedure '* osing session, said. "We wanted to ob- While Martonik > -eves that OSl iA can de- - ariety of opinions concerting the defini- fine a project for Nb. purvu. m liyht ot '-'lor- :' -ibestos and the latest methodology for (nation presented at the workshop. arn parwe.- asbestiiem fiber. " 'After reviewing part who !..*ped that the coni, :ni.e * 'ulc settle . d .1 comments ano que-tion' broached some of the controvert, .u'r.'L" ' a't>- : nierencu. OSilA wdi drvc'.r-p research health problems would have IHi . *vr. p b'r it edit- t.. be w,.n,, : by NBS. disuppoime'! .'SHA wc.itcw ; h; 1 .pes that, w completed the NBS of'opinionv '- .vtri tna: o .. . *.* .1! h-ve e- ...cd fur the anulys. of Many problems inu qu. - " CRMC-MAD-000492 iCti . * A, A M M photOQraph8 uwdftUtcanning mksfowcopB. 18 s e r r e v L - R tos were raised by workshop participants; few, if any, were resolved. Indeed, the-e was a wide difference of opinion as to which of the many qcSuU uuu,ait-il.wci'citiivkupunart. Oat point of agreement There was, however, one per. upon winch seemingly all workshop participants agreed--the need for a precise determination of which min erals are, fact, asbestos or asbestl'orm. In the conference s open. ;g presentation, University of Minnesota geologist Dr. Tibor Zoltai noted that, until about five years arc there had never been a problem with terminology. Before that time, interest in fibrous silicates was pretty much the exclus.*c izm oi gculogiiis. who always understood what their colleagues meant by terms such as "asbestos," "asbesufonn," "fiber." and "fibrouv" With the growth of interest in the health ; -oblems related to asbestos and the subsequent discussions and research b\ scientists from other discirhnes such as b.ok-.p medicine, and chemistry, the fine distinction-, inherent in the terms as u:>cJ h. g 'si -~:.t l -mu. N-rred. Zoisai sa.u The nou-r.o2\ tcrrr.tm.ioirv. he said, has leu to fa'sc or t;., '' i r> .Sa. acteru non of mans 'rune*-.- a. a : ' or "asbcsti- fortn" which were never previously considered as such by mineralogist. Part of the reason for the prr z r .i cc fusion litItlluillUlO^I IStin I4M'uldi <UwC>,wj U 1specific mineral; it is a generic name for by'drated mineral silicates. In addition to,the sh asbestos minerals named in the OSHA stanJ^rd. there are several other varieti-.. ot asbev orrr. ninerals--fibrous silicates which have chemical and physical charactirisu;s si- ul; to thos. oi CGtlllftcrCiai aSbeiiui Zoltai called for creation of an "inter..... r u n ary language" acceptable to researcher u the scientific sphe- s now investigating a?*xs:..-s charactisticsand effects. The necess.ty of -me A univcrMu, prcw.< iwiTu r#w*w%!y .ter* time-and again during the work.hop In his closing remarks. Dr C. S (Si.tn) Thompson, a naneralct-st for -he Va.tJerbi.t Company and rep-tentative of ::-.c Americ:.-! Mining Contcrence. reitatu-J the ccasu. by loose tcrminolt>-.,\ 'T-.cntx.. kr t v.he: asbestos is." he >jm. -bu' ires u. . k.-.nv w. rr isn't. . 'Let va! or- what the) arc T.. * v.*, crals must r, - . . h . . - - v fv medical reseat*.:- wrve*, . tv CRMC-MAD-000493 dost " Otherwise, he said. the researchers don't know what they are testing, and the government agencies that use the results of these studies as the buses for iheif sandirds know what they arefegularing Seve.si possible definitions of ashe*:.^ were offered at the works iop. Robert F ib e r o: U J . Steel proposed that all silicates which separate into fibers after light griraing be classified as asbcsifoim if the fibers meet three criteria: They have a lenglb-to-width ratio greater than 10:1; they have parallel sides; and they are more than two in length. Fisher added the caution that o ir-ra l fragments are not the same as mineral f riers and that th:s distinction must be necognired in any regulation. Dr. Malcobn Ross of the U.S. Geolopca! Survey sa.d there re three possible definitions of asbestos: 1) all siUcatts with a 3*1 iencxb- to-width ratio; 2 ) all silicates with a 3-1 length- to-width ratio that arr either amphibole or ser pentine; and 3 ) on! those silicates known tr have coBunern'il value as asbestos. Ross advised reguiitoty a? -cie s to consider carefully the economic impact of any new regulations A araadly inclusive definition of asbestos couio result in sbuttuig down many hard rock quarry ing operations, and "the small mining industries will be wiped out," he claimed. Co- sing to "despair" over the evident con fusion in terminology. D r. Jack Zussman, a mineralogist from d.e University of Manchester, pointed out one bad effee: that the lack of a preciu definition cf asbestos havnn rhi* ruthn-- "The loose"labeling of materials as 'ashes' r' generates alarm. When we find '-ter that these minerals aren't asbestos, it's too .`ate to undo the anger and worry caused by the orig,;.q! inisident.:' cation." Summing up the current stare of t::hnical knowledge about asbestiform minerals, Zussman said, "We pretrv well know the effrr?; of commercial asbestos-- though they may need to be quantified a bit more-Wi-t we don': kn~w, and what we need to pr used with cauiiun on. are the effects, if anv.'oi noncommercial mineral fibers." A great i One of the biggest questions about asbestos is * Exactly what is it about asf stos fibers that causes adverse nealth effects'* Thr importance of tfe precise chemical coaipov.iion of a .be-:form fibers is, larjely-uciaawr. AI>o. thouj some rc.earchcrs believe (hot ar. fibrous s.licaie can OSHA's Asbestos Standard-- A Status Report OSHA's current standard on asbestos was promulgated on lone 7, 1972. It defined "as bestos" as chrysotile. s "osite, crocidolite, trem- olite, aittbophyllite, and actmolite and included every product containing any of these minerals. For regulatory purposes, m asbestos fiber was defined as a particulate form of asbestos, longer than 5 microns, with a length-to-diamc'er ratio of at least 3-to -l ^sd a maximum diaaetu: of S microns. The 1972 standard originally established a maximum 8-hour time-weighted-avers?; (TW A } concentration of 5 asbestos fibers per cubic centimeter of air, and a ceiling exposure limit of io &b.*s pr cubic cenbm^icr. On July 1, 1976, a further provision of t*-? standard took , effect, lowering Me permissible 8-hour TW A to two fibers per cubic centimevor of air. The two- fiber limit remains in effect today. On October 9, 1975, OSHA proposed a cere regulation for asbestos. Among other things, tfie proposal would Sower the permissible 8-hour TW A exposure level to 0.5 fibers per cubic centimeter and would educe the permissible ceiling exposure level to 5 fibers per cubic centi meter for any 15-minute period. This p-oposal would not apply to the construction industry, which would be required to follow a differe:; r-f--i'nH-i--.rH IVVmu MJfVaTVMaIwmu*. A separate asbestos standard for the construc tion industry has not yet been proposed, nor have hearings on the 1975 propc-al been sched uled. An economic impact statement concerning the proposed revision is nearing completion. Meanwhile, on December 2, 1975. OSHA asked NIOSH to. reevaluate available infs rota tion. on the health effects of occupatiorrl ex posure to asbestos. Completed in December of 1976, the NIOSH reexamination was forward;- to OSHA in May. Finding no evidence of a I4M*a9 %(! amvvl"w.w.*M> vfortf -va-s. .siV*M.. recommended treating asbestos like other carcinogens by allowing only the lowest exposure level detectable by available anah cal tech nique, NIOSH recommended a 0.1 fiber TW a and a 0.5 fiber ceiling limit for occupat'ona) exposures to asbestos. \ > ^ . -A . jZ ^ Ar fc ' 7 A' 2 HE- CRMC-MAD-000494 caul araoar, othm believe that virtually ary time reduces the ak of disease an a level "ac substance, sod asCShergiam, o n Induce the ceptable'' to those people they aie responsible a o e health problems tf its fibers are of the sane for protecting. Exprttswg "sympathy" for rejo* size ta d long,dun shape is tsbcttosfiben. latn faced with mo^ng this datnttinacion tor Another .modal issue that most be resolved asbestos exposure, C ooper observed, "We know is the imponance ef fiber size in causing disease. v thfi; fibers cause h.shh efiects, but we don't have M t -Sinai Hospital's Dr. Arthur Larger dotec ' reliable baoioproJ data an winch to base rtgula- dm , although some studies have produced dif ` 'tion." ferent results, there is evidence dua small fibers (less than five xmenjoeters in length) are bro logical}} active. Taking the opposite position. Dr. Clark"Cooper of Equitable Environmental Gting the r ted for detesaniag what is an acceptable asbestos mk, Cooper continued, "R egrr'ler whether ere is a threshHd or aoq the odds-- a tbselotea--am wbaa is im- Health, lac. stared. "We have no eccec'.sbik. "pertant in life We live n a world of constdera evidence on the pethegeaidt? cf fibers t- .' te::, probability, and acceptable risk. The suu- live micrometers in length. . . . The evidence of t* i with asbestos not aoalrgoas m that v * nest animal tests is overwhetming that short fibers do not cause fibrosis or malign; ncy." The importance of fiber size must be taken .mo account when anbtipaLog any new asbestos regu-atici. O SHAT current standard, which stipLiats that only f l * n at least' five suoth meters. i<mg be cc^ted-whim'detemininr: expo sure .-veb_ [see bos], was characterized by Coopt a s ^ a fb & w based on little more than the fat. diat fibers of this s^e are visible undr: vtayI chlond. . wo-tre not dealing with a v.mthet- ic molecule, but with a physical agent that occurs Ggsv.t ; ; :.? ?;* varizbla." M alela ua reiterated this thought Noting the pervasiveness of fibrous ucates in American rock loeexhoes, Ross WLrr.sd, "Wc.wCLhave-.to Jad-m: aeeept- abl. hralth nsk. or else we .till ham lo shut down the surface of the earth." A loe* ahead the light microscope." However, he pointed out, ' "For every fiber you can see in the light m ierr- scope, there are tea you can see a . the dear. microscope. No one will be satisfied with lz anaivucaJ method'.based on light microscopy alone," he cooduded. But while Cooper had some reservations about r ssaoAsrd cegteriag on fibers at cast five .uicror., kmfcalohns-Manvflle's D r. Paul Kotin ;est:c.ed that most fibers making their way into the human body and lodging there are less than At the end of the conference, a sonsnem made from tb.- floor seemed to meet with wido- epp:y:zL A --e rk ito p p fk if*U sug gested establishing or. interagency taskforce that wo: -j periodically review oofoag research pro .r.s dealing with asbestos. The taskforce could offer researchers guidance sod direction to assure that they were considering all pertinent variables in their analyses. The taskforce also could serve to avoid cverduplication of research by keeping abreast of the multitude of projects 3.5 microns wide and 20C microtis long, and greater than 5 lakroos in length. K.o(io also stated his belief that, though no `safe level of asbestos exposure has vet being conducted indepndemly by uateruties. industry, and government. This suggestion was perhaps the one new idea to come out ot the tkraa rr***f- oetensioed, medical research eventually will de.erraine a "no effca" dose level for asbestos as it has for other toxics. In asserting that a toleranc. threshold wJl be found. Ko<. i noted that no epidemiological study has been able to determine the dote amounts suffered durmr human exposure. Summing up his impressions of the workshop, M t. Struts Lunger -m l. "We've really learned n:j;h;rt.- r? Wc kr.^* we rt d a lot c -` research to dc:r-taint the b.<*:. ..I activity of rock- l :, atev and.' usow tha: the whole problem hs> been muddied by the misuse of terms'' krfu ..r.g to be nverwhe!med<by>thr *nast Accxniable risk \Vt...e the existence of a tctcr..nccfhrmh:iL' re s u n a question, regulator)' ag;:..ies ire u>iifrnntvj w' a hard decision how to m u .it iihung a percuss.ble exposure le.r. ir. . x :.'> u > :r: -aiiy feailPle U> attain md ai the sune of urna * r r r J q estior.s lurrounding aibes- i > r -c !.u ; adsned, " Remember, this iva ver, orv* ub.vw: ft s .. -.ell c. * big'problem. ' and tr.fr s ,, : . * * i .i'. this (coiJerencel i um .*'mi ..... *. /Mi.- i/ lt>f*VJn* re CRMC-MAD-000495 nr O ctober 9, 1974 M r. H. B. V a n d e rb ilt P re s id e n t C h ie f E x e c u tiv e O ffic e r R. T . V a n d e rb ilt Company, In c . 3Z W in fie ld S tre e t N o rw alk, C o n n e c tic u t 08855 Dear M r. V a n d e rb ilt: ^Phis is in reply to your letter o f Septem ber 2 6 , concerning your re q u e s t fo r r e l i e f from th e as b es to s stan d ard f o r y o u r t a lc s c o n ta in in g n o n -fib ro u s tr e m o lite , a c t in o lit e , and a n th o p h y llite . `"""" ""h s y "jlir t ! tie i5 aao iTM iie e e e s e e s e s s s a iM s s e e * e e ^ f i^ ? ? ir 5 w S S B,w !^ *lT*55>S 5 K f e s t i - fo rt 'the scope o f th e as b es to s s ta n d a rd arid , t h e r e f o r e , th e p ro v is io n s cf th a t stand ard do n o t a p p ly to t a lc c o n ta in in g n u n -a s b e s tifo rm ra in e ra is . KIOSE i s c u r r e n t ly c o n d u c tin g a th o ro u g h in v e s t ig a t io n in t o th e e x a c t m in e ra ls t o w hich t a l c w o rke rs were exposed in th o s e s tu d ie s where a s b e s to s is o r o th e r adverse m ed ical e ffe c ts w ere : nunc. P ending th e r e c e ip t and e v a lu a tio n b y OSHA o f th e r e p o r t b y NIOSH on t h is in v e s t ig a t io n , i f ycu h a v e ' s c i e n t i f i c e v id e n c e t h a t th e n a tu r a lly o c c u rrin g t a lc s , p r io r to p ro cessin g by m illin g o r c ru s h in g , ~v ., ^4 w t f c e rtiT do not Uw < c o n ta in fib ro u s o r a s b e s tifo rm tr e m o lit e , ant o a s b e s tifo rm m ir e r * 1 is; you wav V<y. F ib ro u s , a s b e s tifo rm m in e ra ls such as fib rous tr e m o lite means n a tu ra lly o c c u rrin g a s b e s tifo rm m in e ra ls w h ir h p r io r to o r a f t e r ***-- a **3 Sincerely, / s / John H. Stender John H. Stender Assistant S e c r e t a r y o f L a b o r CRMC-MAD-000496 (M ein 197/# 111 . v. r . W.m.Y: *. !) : } J ( i.'c- \ Ch r 1 l> t c u t 1v c C ' i c CI n. 7. Vondt'ib il t Cer.p O I.y , 1 3C` Viril eld S t : t t i Korvali., Connecticut 08855 Dear Hr. Vanderbilt: r h* This i s in reply to your le tte r o Septecbcr 6 , concerning your request ior r e lie f iron the asbestos standard for your ta lcs containing n oo-iib rou s t r c a o lit e , a c t i n o l i t c , and a n th o p h y llite . My l e t t e r o f August 6 sta ted that n on -fib rou s or n o n -ssb e sti fore, n in cra ls such as n on -asb estiforo tT c r o litc are not w ithin the acope of the asbestos standard end, th erefore, the previsions of that "standard do n o t-a p p ly to t a lc con ta in in g revn-nsbestif c m c i e r a is. 5r cv: rent jy cr r.cuc tins c thorough invc: : ; gatior. in to the exact c i e r a is to which ta lc workers were exposed -ic. those stu d ie s where a tb e s to s is or other adverse m edical e f f e c t s were found, ft p* o rci.: i n f the r e c e i p t r.d e v a l a b y OSRA o f t h e r e p o r t by r . t . ;l l:.". ; C* ' V.: t , r t *. i .tiro: ; i f y n M h v r f : i t r . t i c e v i d i .. Cl LPSt - - . w. . . ( i . : r' * i +r *- - t7 , r c r cr- r kw.1 b y c : e: ct n e t c : * -..* f j o r o r h . r t i f Om t r e r . Y . r e , , o : t : r. C.J. ~ I w c ; c*; wl . - CUr nk*%4"Wf-I T t u n e r o , yo u any c e r t i f y - t o y o u r CUS t o s e r s Lhot t h e t a l c Clo e s n o t c o n t a i n fiC D C S IO S . Fibrous, a sb estifo ra c i r e r c l s such as fib ro u s t r e c o lit e scans n atu rally occurring a sb estifo ra nir.erals which prior to or a fte r crushing and p rocessin g, contain fib e r s cade up of f i b r i l s . fine tt cly , /o/ Job:. K. Slender CRMC-MAD-000497 /V *l qt #* r V, 197 /, * Ih . V . I . Y .n .\ : ; '] : ) > C! i ' i CM ci I x c v tiv f ('M e: C I n. v a n J v t b i 1 1 C i : p " >*yi i 3C` V ' i r i i c 1 <' S i : 11 i Korvalk , Connecticut 08855 D ear Hr . V a n d e r b i l t : , This i s ip reply to your le tte r of Scptecbcr 6 , concerning your request for r e lie f iron the asbestos standard for your talcs containing non-fibrous t r c a o lit e . s e t i n o l i t e , and a n th o p h y llite . Hy l e t t e r o f August 6 sta ted that n on -fib rou s or n o n -ssb e stifo r c n in cra ls such as n o n -a sb estifora tr c a o lite are not v ith in the score of the asbestos standard and, th erefo re, the previsions of that standard do not "apply to t a lc ccn ta in ir-, r o n -a s b e s tifo m n in c r a ls. K I O ' l ' 5 r c u : r e r r ! y er, exact n in e : els to vni studies vhcrc atbeste c u c ti rg a thorough i n v t : : g a l ion. in to the ta lc workers were exposed .n. those is or other adverse tsed ical e f f e c t s were four. r e n d i n y the receipt r r d evaluation. b y O S H A o f the r e p o r t by i.'I O S H C t ' M r.t ira: ;rr ;f ynn b;vr 5 t i e r . : i f i c evid.;.c.L t eat. t M . c * -- u:: : tt net c t . 1 ( i , p r i o r t r , r c r c s r i r . g by r M M r .g o: r f ; rr r:-.. o r f r b .r t i f e m t r e r - M . i t , actir.cli : v t : c*t as: estiferr. aincrcl:, you cay ccitiiy to your customers Lh2t the ta lc cots not contain asbestos. Fibrous, asbestiforra c in e r a ls such as fib ro u s t r e c o lit e ccans n atu rally occurring asbestiiorrs nincrals which prior to or a fter crushing end p rocessin g, contain fib e r s cade up of f i b r i l s . f i n e ctcl y, . John It. Slender /x c ic ta n t Secretary of Labor * CRMC-MAD-000498 October 9, 1974 Ur. 1!. B. Vanderbilt President Chief Executive Officer R. T. V a n d e r b i l t Conpany, I n c . 30 IMnficId Street Korvalk, Connecticut 08835 Dear Hr. Vanderbilt:. < Of h* Thla la In reply to your le t t e r of Septeeber 6, concerning your request for r e li e f froa the asbestos standard for your ta lc s non-fibrous tr e n o lic e , a c t i n o l i t e , and a n tb o p h y llite . nr l e t t e r o f Angust 6 sta te d th at n on -fib rou s or n o n -ssb estifo rB m inerals such a's n on~asb estlfon s t r e a o lit e are not w ithin the scope o f the asbestos stcr.card and, th erefo re, the provisions o f th at standard do r o t'a p p ly to t a lc con tain in g n o n -a sb c stlfo m m in erals. KICS1I Is currently conducting a thorough 'in v e s tig a tio n into the Ci;act minerals to w h i c h t e le workers were exposed those sto d ie* where asb e s t c c i r o; other adverse m edical e f f e c t s were found Pending the receipt and ev a lu a tio n by OSEA o f the rep ort by N20SH on th is in v estig a tio n , i f you have s c ie n t if ic evidence that the n a t u r a l l y occurring talcs, p r i o r t'c* p r o c e s s i n g b y trilling or crvrl.i:.*, d c not ccr.rsir. fibrous or a s b e s f - i o m trer.ol : e , nntorb;- Hite., aetir.oiitc or other osbest iiorra c i e r e i s , you may certify to ycur customers that the talc does not contain a c h e s tos. Pibrous, ssb estlfora c i e r a is such as fibrous tr e o o llte ceans n atu relly occurring a sb e sc iio r j c i e r a is which prior to or a fte r crushing and processing, contain fib e r s Bade up of f i b r i l s . Sincerely, /r / Job.:-. H. S t e n d e r /'w John It. Stender Assistant Secretary of Labor CRMC-MAD-000499  f Cu t ohe r 9, 197A * li }lv. 1!. B. Vanderbilt Tresident . ' Chief Executive Officer H. T. Vanderbilt Company, Inc,' .30 V'inficld Street Korvalk, -Connecticut 08855 Pear Hr. Vanderbilt:, j - o f h This is in reply to your letter of Septenber 6, concerning your request for relief from the asbestos standard for your talcs containing non-fibrous trenolite, actinolite, and anthophyilite. * Hy letter j o f August 6 stated that non-fibrous or non-asbestiforn minerals such a's non-asbestiforn treaolite arc not within the scope of the asbestos standard and, therefore, the provisions of that standard do not-apply to talc containing non-asbestifora* minerals. ,, KIOSH is currently conducting a thorough "investigation into the exact minerals to which talc workers were exposed -in. those studies where asbestesis or other adverse medical effects were found. e Fending the receipt and evaluation by OSHA.of the report by II0SH on this investigation, if you have, scientific evidence that the naturally occurring talcs, prior to| processing by milling or crushing, do not contain fibrous or asbestifom trcr.olite, nntophyllite, actinolite or other asbestifora minerals, you may certify to-your customers that the talc does not contain asbestos. . Fibrous, asbostifora minerals such as fibrous trenolite means naturally occurring asbestifora minerals which prior to or after crushing and processing,- contain fibers made up of fibrils. Sincerely, , / s f John H. Stender John H. Stender Assistant Secretary of Labor CQ11906 * r CRMC-MAD-000500 ZOSOOO-QV]A- Docket Mane Docket Nuaber Haue and Address (Corp) u Federal Register Cite: pate: Deadline: Ext d. A ffi, o f Writer ___________ Attachments (Ifa n v l Comments on the reviewed Asbestos proposal He. Pos. ithPJP tr > 3J > Johna-tfanvllle Corporation coment rollate on the dune 2 and 3, 1976 Asbestos subgroup ni I CRMC-MAD-000504 Federal Register Cite: Date: Deadline : Ex te : Cooaittee Xecoaoendadona for tie 1976 period Mlnutea of eating of January 7-10 /7 Consenta by the Onion Carbide i Corporation on the January 21 and 22, ^ 1976 Construction Advlaory Coenittea Meting Inatructlona to Coeaiittee Drafting 1976 Aabeatoa Kecoeaendatlona CRMC-MAD-000505 CRMC-MAD-000506 Docket Name Pocket Number ASBESTOS/1975 11-033 Name and Address (Corp) Asbe ;? Inforostlon Association 1660 L Street, H.W. Wash! untesi, b.C. 20036 Date Submitt IIT Research Institute 10 West 35th Street Chicago, Illinois 60616 Royal Industries Braks Products' Stewarts Lane Danville, Kentucky 40422 The Halmeatann Medical College 6 Hospital of Pliiladephle Two-Thirty North Braod Street 917 Schaff Bldg. Philadelphia, Pa. 18102 Johns-Manville Corp Creenwood Plaza Denver, Colorado 80217 R.T. Vandervllt Conpany, Inc. 10 Winfield Street Norwalk, Conn. 06852 Friction Mat'ls Standards Dergen Mall Office Center S. 210 Route 4 I'arasnts. N.J. 07652 Institute, Inc. C R M C - M A D -0 0 0 5 0 7 Submission Federal Register Cite; Date: Deadline; Fxtd: Docket Name Docket Nunber H-033 i . 1 Marne and Address (Corp) 8. Carlisle Corp. P.O. Box P, Gillls Avenue Rldgiwcy, Pa. 15853 9. Geoffrey Nicholson 822 Oak Ridge Road Winchester, Va. 22601 'O, Z*V .'.aaoeiatea-Mlcroanalyfla Lab 15I25 Shdy Grove Road Rockville, Maryland 20850 il. II.i:. Porter Coapany, Inc. Potter Building Pittsburgh, Pa. i*. Nlcolet, Inc. Executive Offices Wlssahlckon Avenue Aabler, Pa. 19002 u. Western Electric 222 Broadway New York. N.Y. 10038 M. Abex Corp. P.0. Box 607 Winchester, Va. 22601 Bocket Nane Docket Nunber ASBESTOS/1975 H-033 U Federal Register Cite: Date: ( Deadline: f xtd: o. I_and Address (Corp) Rubber Manufacturer* Assoc, 1901 Pena Avenue, H.U. . Washington, D.C. 20006 16. American Iron A Steel Institute 1000 16tb Street. H.U. Washington, D.C. 20036 17. Armstrong Cork Company Lancaster, Pa. 17604 IS. Union Carbide Corp. 270 Park Avenue, H. Hew fork, i.Y. 10017 19. K ansas C i t y Power & L ig h t Company 1330 B a ltfa o re Avenue Kansas C ity , M isso u ri 64141 Palnt Engineering 333 Kearny Street Room 403 San F r a n c i s c o , CA 94108 .1. Cali-Bloclc 15930 S. Fi gueroa S Gardena, CA. 90248 Date Substi tted I Submission 1 A ff), o f Writer Attachments ( i f any) f t ,0 0 Mo. Codino .U 3C i 3l ( CRMC-MAD-000509 Docket Name >JgBESTOS/WW Docket Number H-033 ( Name and Address (Corp) Inited State Steel Corp tOO Grant Street P'ci.burgh, Fa. 1S230 W.R. Grace 4 Co. Industrial Cheatcala Group 62 Whitteaore Avenue Cambridge, Haas. 021A0 Brake and Clutch Service Co. 3404 Ela Street . Dallas, Texast 73226 Industrial Safety Equipment Assoc,, Inc. 1901 N Hoore Street Arlington, Va. 22209 Industrial Safety Equipment Assoc., Inc. 1901 N Hoore Street Arlington, Va. 22209 Mobil Oil Corp. 130 e 42nd Street lew York, N.Y. 10017 International Paper Co. 220 East 42nd Street iew York, N.Y. 10017 Docket Name Docket Number /* ? N-033 >. Name and Address (Corp) 9. Hi-Process Brake Engineers, Inc. 2807 Olive Street St. !.oula( HO 63103 JO Ma.'et'ont Corp. 700 Wist Caroline St. PaulJlng, Ohio 45879 31. Sourthern Asbestos Co, P.O. Box 10516 Charlotte, H.C, 28237 32. SARCO Inc. Legal Dspataent 120 Braodway Hew York, N.Y. 10005 33. Zldell Explorations, Inc, 31nl S.W. Hoody Avenue Portland, Oregon 97201 34. Phillips Petroleum Co. itartlesvllle, Oklahoma 35. Ill, cheatleal and Atomic Workers International Union 1126 16th Street, N.U. lashlngton, D.C. 20036 Date Submitted Submission Docket Naae Docket Nunber stMF ASBESTOS/1975 **-033 Federal Register Cite: Date: Haae and Address (Corp) 16. Standard Oil Coaipany 206 Cast Randolph Drive* f.C. Box 5910-A Chicago, 111. 606BO 1 /. American Trucking Associations, Inc. 1616 P Street, N.W. Washington, D.C. 20036 Phillips Petroleua Coapany kartleaville, Oklahou V ). Golf States Asphalt Co., Inc. P.O. Box 508 South Houston, Texas 77587 3org-Warner Corp. 290 South Hlchigan Avenue Chicago, 111. 60604 'll. Consuaers Powers Co, 212 West Hicliigan Avenue Jackson, Hlchigan 49201 St. Joe Minerals Corp, ffioaca, Pa. 15061 Date Subitted Subalsslon A ffi, of Writer y Deadline: fxtd: Attachants ( | f an ______ `>diKI I .H 1 SW li Mb 32 7 P'i C R M C - M AD-000512 Docket Name ^SBESTO^/1975 Docket Number H-033 V Federal Register Cite: Date: I~'t------ -------------Haiwand Address (Corp) Ztdell ExplortIone, Ine, 3121 S.W. Moody Avenue' Portland, OR 97201 Date I Submitted | Submission Asbestos Spelcalltlea Co. 392 W. 7 Mile Road Detroit, Hl 48203 Vagner Electric Corp. 6400 Plymouth Avenue St. Louis, MO 63133 Siienango Ine. Neville Island Pittsburgh, Pa. 15225 lUveg Industries, Ine. *900 Creenbank Road Wllalngton, Delaware 19308 Organization Raso>irces counselors, lue. M 6 0 L Street, H.W. Washington, D.C. 20006 T'h lo k o l C o r p , Newtown, Po, 58940 A ffi, o f Writer Deadline: Extd: No. Attachments ( I f any) P9S. m Vif ;v7 jV ) CRMC-MAD-000514 t \ Docket Naae Docket Nuaber ASBESTOS/1975 11-033 Federal Register Cite: Cate; 57. 53. .9. I. (it. (>i. Date , ..... . ., ,a.iral^-.,-"wi'.i'Mnrr:rrirrae Subeitted Halcoab Safety-Caraent Co. North Jefferson Street Chicago, 111 60606 W. Clerk Cooper, M.D. 2180 Hllvla Street Berkeley, Ca. 94704 State of California - Occupational Safety and Health Administration 1006 Fourth Street Sacramento, Ca. 95814 3H Company 3H Center St. Paul. Hlnn. 55101 Air Transport Association of America 1709 New York Avenue, N.W. Washington, D.C. 20006 Pacific Harltiae Association 635 Sacramento Street San Francisco, Ca. 94120 Congress of the United States House of Representatives Washington, D.C. 20515 1 Subaission A ffl. of Mrtter Dead)ine; Ci Extd: Attachaewts ( If an) J ___ t'odtjUH '(C L' VA? S// -000515 JNlAU C,k M C Socket Nane Docket Nutiber ASBEST0S/197S 11-033 1 1 Nitse <id Address (Corp) 64. Contre*! of the United States United Jtatea Senate Wauhf ngan, D.C. 20510 65. Aaerlca; Retail Federation 1616 11 Street, H.W. Washington, D.C. 20006 66. Congress of the United States House ri Representatives Washing ton, D.C. 20515 67. Hat lorn l ReSourcea Iiefenae Council', 15 Weait 44th Street Hew Tart, H.t. 10036 r.8. ' Congreis of the United States ! United States Senate Washir^ton, D.C. 20510 6-7. Edteor. Electric Institute 90 Part Avenue Hew Y<erk, H.Y. 10016 70. Aaerii.m Petroleun Institute 2101 i Street, H.W Washtr^ton, D.C, 0037 Docket Ha ^ STOS/I975 Docket Hurtber t*"33 Hane end Address (Corp) Motor Vehicle Manufacturing 320 Mrw Center building D e t r M t , MI. 48202 Assn. Motor Vehicle Manufacturing AsBn. 320 New Center Building Detroit, MI 48202 The Markham Company, Inc. 1184 Aiden goad Orlando, Fla. . 32803 3M Conpany 3M Center St. Paul, Minn. 55101 Edison Electric Institute 90 Park Avenue . Hew York, H.Y. 10016 Republic Powdered Metals 2628 Pearl Road Medina, Ohio The Brelner Co. P.0. Box 31168 Indianapolis, In. 46231 Deadline: fxtd: foro odino HHw? */r spy C R M C - M A D - 0 0 0 5 18 Docket Mase Docket Hunter ASBESTOS/!975 H-033 Harne hd Address (Cor C s U - f 'isk 15930 Stfuth Figueroa Street Gardena,)' Ca. 9Q24B The Hastinga Co. P.O. Boat 445 King, H.C. 27021 Ueatllreg Manufacturing Co. 3900 Loulalana Circle St. Lotitia Park, .Minn. 55426 Service Parta 6 Machine Co. 731 Prsbandt San Anionlo, Texas Arrow iatnotive Industries P.O. B.;x 1748 . Spert&rburg, S.C. 29301 Cuatota Clutch & Jolrt, Inc, 3417 S t . Clair Avenue Cleve.lind, Ohio 44114 San Asr.tonio Brake fe Clutch Service P.0, kox 976 San Atrtonio, Texes 9C205 Submission Docket Haae Docket Nuaber*1 ASBESTOS/l975 11-033 I Hnc and Address (Corp) Frictle'. Supply, Inc. 7500 H-R Eleventh Avenue Portla'oJ,, 0 97211 Asbestos Information Assoclstlon 1660 L Street, H.W. Washington, D.C. 20036 Eaton Corporation Forge Division . Herion Plant 1550 Harlon Agoata Road Harlon, Ohio 43302 Industrial Casket Inc. 801 S. walker !P.O. Sox 24048 IOklahoma City, Oklahcaa 73124 [Appalachian Gasket Co. IP.O. Box 991 1industrial Park, State Line Road [Ellzabethton, Tenn. 37643 JH.R. Grace & Co. 1Industrial Chenleala Group [62 Whittenore Avenue lCaabridge, Hass 02140 u Federal Register CUe: Date: Deadline: Extd: V ?<t wo vvy V'/-2- >7. Friction Material a Standards Institute Bergen Mall Office Center E. 210 Route 4 Parapus, N.J. 07657 d. Friction Haterlala Standards Institute Bergen Mall Office Center E. 210 Route 4 Paramos, H.J. 07652 Lasco Brake Produce Corp., Ltd 2615 Magnolia Street Oakland, Calif. Office of the Assistant Secretary of Defense for Manpower and Reserve Affairs Oe.id) ine: .7 fr.td: AtUchwents (1f iny) No. -ISL, J.C.P.. '-odinq -yyi 4V Wi y'/f it CRMC-MAD-000521 Docket None Docket Nuflber ASBESTOS/1975 H-033 Mime end Address (Corp) 98. C S a r l M W. Fiahburn, M.D. I?il5 U. Cleveland Avepue Hrw Berlin, UI 53151 99. Rockwell International Automotive Operation 2135 Vest Maple Road Troy, MI 4B084 100. Aabestoa Textile Inatitute, P.O. Box 471 131 North York Road Willow Grove. Pa. 19090 Inc. 101 . Univeralty of Wisconsin Hospitals Center for Hcilth Sciences Univeralty of Wlsconsln-Hadison 1300 University Avenue Madison, WI 53706 10. Abex Corp. Friction Products Group Suite 205 1650 W. Big Beaver Road Troy, HI .48084 ioa. Hutco * Materials Division 1600 West 135th S t r e e t Gardena, Calif. 9)249 Date Subaltted Subals s Ion y y Federal Register Cite: Date: DeadIIne: frtd: Docket Name Oocket Humber ASBESTOS/)975 H-033 J U r e j w d _ M d r e 5 S (Corp) _____ Submitted Waise and Address ( r . o r p j ____________ j V u b o f t t M Submission SUDmltsTofiT Standard Automotive Components 10225 rag IMuBtria 1 BJvd. St. Louts, MO 63133 Cellulo Company 27 North Avenue East Cranford, N.J. 07016 Western States Brake Manufacturing 1902 Potrero Avenue South El Monte, Ca. 91733 Chassis Products, INc. Highway 80 West Hontogonery, Alabama 36108 llaveg Indusrles, Inc, 900 Creenhank Road Wilmington, Delavare 19808 Alsop Engineering Corp. Milldale, CT 06467 Beaver Industries Inc. C.P.O. Box 597 Kingston, N.Y, 12401 Docket NMK Docket Nwber ASBESTOS/975 H-033 ( Naae and Address (Corp) IB. Dow Climicel USA Benne ct Building 2030 jow Center Midland, Ml 48640 Dte Subtil tted 19 Naturel Keeourcea Defense Council, Inc. 13 West 44th Street New Turk, B.T. 10036 20 Norplex Divi Ion 1300 Norplex Drive Legrasen Vi '54601 |?1 22. i n s t r M i g Cork Co. Lancaster, Pa. 17604 ASARCO Inc. 120 Broadway New Pork, N.Y 10005 23. American Petroleum Institute 2101 L Street, N.U. Washington, D.C. 20037 Research and Development Division Fruehauif Coxp. P.0. Bom 238 Detroit, HI 48232 Subatsston -- -- ----- y Federal Register Cite: Date: m b 'TA"*:f*f--i1, o f W~r>i*t*e'*r*" Deadline: Extd: Attachments (I f any! No. 131, "odine 4U / 7 Docket Name Docket Number ASBESTOS/1975 11-033 Naiie and Address (Cor International Paper Co. 226 tfaat 42nd Street New York. N.T. 10017 Atlantic Richfield Co. Coroorate Employee Realtlona Division Box 2679-T.A. (Loa Angeles, CA 90051 Pfizer, Inc. . 235 Ease 42nd Street New York, N.T. 10017 Aeroquip corp./CuatIn-Bacon Division Barca Plant 500 North llough Street Barrington, Illinois Norplex Divlslon/Unlversal Oil Products Co. 1300 N orplex Drive LaCrosae, UI 54601 The B.F. Goodrich Co. 500 South Hein S tr e e t Akron, Ohio 4431(s Submission Docket Nane Docket Nunber ASBESTOS/1975 tl-033 lo. 03. I Nane andjkddrgss (Corti) E.I. DuPont DeNemours 4 Co. Liigtl Department w.lulngton, Delaware 19898 Date , Submitted Bsaioinxsai 09. Standard Oli Company (Indiana) 200 Eaat Randolph Drive P.O. Boa 5910-A Chicago, 111. 60680 140. Bllllngham Marine 6 Manufacturing P.O. Box 4367 Portland, OR 97208 141. .CAP Corporation 140 West 51 Street Mew Tork, N.Y. 10020 142. SEPCO Corporation P.O. Box 10846 Birmingham, Alabama 3202 IO. Molded M a t e r i a l Company Ridgeway, Fa. 15853 P ack in g S e a l s and E n g in e e rin g Co. 145. S t a n d a r d O i l Company o f C a l i f o r n i a P.O. Box 1272 R iclw o n d , CA 94802 Submission Docket Nae Docket Humber - ASBESTOS/1975 H-033 . -- i miii-.r^.-,' Mi iLi in.iKiiiM.Vnn^aia. Republic Powdered Metale 2628 Pearl to Medina, Ohio 44256 Oate Subait t e d 47. Ethyl Corp. Med leal Department 45) Florida Street Baton Rouge, LA 70801 43. Longhorn Casket a Supply Co. 49. W.S. (Bill) Stuckey, Jr. House of Representative SO. Chamber of Commerce of the U.S. National Economic Development Group 1615 H Street, N.U. Washington, D.C. 20006 1. Republic Steel Corp. Republic Building P.0. Box 6778 Cleveland, Ohio 44101 American Telephone & Telegraph. Co. 295 North Maple Avenue Basking Ridge, N.J. 07920 Subaistton l V Federal Register Cite: . , Oate: ( DeadlIne: Fxtd: A ffi, o f Writer AtUcIwents (1f any) VY Y?(- w j/ n Docket Name Docket Hunter ASBESTOS/1975 H-033 u . ____ N-- a~ae--an---d Address .1 ip iT* ..imiMivj;am I S3. rii. Fluid Sealing Association 2017 Walnut Street Philadelphia, Pa, 19103 1 l Arnold Research Organleation Arnold Air Force Station 1 T .nnessee 37389 Date Subai tted IV. Plastics Engineering Co. P.O. Box 758 Sheboygan, WI . 53B01 IS6. W.R. Grace A Co. 'Industrial Cheeicala Group 62 Whitteaaore Avenue Cambridge, Mass. 02140 IV/. United Paperwofkers International Union 163-03 Horace llardlng Expressway Flushing, H.Y. 11365 r.H. Asbestos Textile Institute, Inc. P.O. Box 471 Willow Grove, Pa. 19090 1 VJ. A/C Pipe Producers Association Suite 1113 1875 Connecticut Avenue, N.W. Washington, D.C. 20009 Subai sslon Docket Nane Docket Number ASBESTOS/1375 H-033 j. Nane and Address (Corpi) Vrnunt Asbeitoa Croup, Inc. P.O. Box 70 Hyde Park, VT 05655 ' C.gnnlratioo Besouces Counselors 1625 I Street, N.U. Uishlngton, D.C. 20006 Shipbuilders Council of Aaerlca Watergate Six Hundred Washington, D.C. 20037 bethlehea Steel Corp. -Bethlehea, Pa. 18016 P ale er A sphalt Coapany 196 West Stli S t r e e t Bayonne, H.J. 07002 Abex Corp; Friction Product Croup P.0. Box 607 Winchester, VA. 22601 Neu Jersey Turnpike Authority Neu Brunswick, H.J. 08903 N ational Paint 6 Coatings Association 1500 Rh>ode I s l a n d Avenue, N.W. Unqhlno-rnn. D.C. 20036 Docket Nane . ' ASBESIOS/ 97S Docket Huiriber *1-033 1 till. Nane and Address (Corp) 'anrlcan Trucking Associations, Inc. 1616 r Street. N.W. Washington, D.C. 20036 faxaestake Mining Coaipany 650 California Street San Francisco, CA 94108 Tennessee Valley Authority Chattanooga, Tennessee 37401 Union Carbide Corp. P.O. Box 379 Nlagra Falls, N.Y. 14302 Thompson, Ogletree and Deaklns for k.T. Vandervllt Co. First National Bank lover Atlanta, CA 30303 Cellulo Coapany 27 Horth Avenue East Cranford, H.J. 070X6 Asbestos Inforastlon Association 1660 L S tr e e t , il.U. W a sh in g to n , D.C 20036 Date Suboltted Subais i i o n Docket Name .WESTos/ m Docket Number H-033 Name and Address (Corp) ft'ver Industrie, Inc. CP.O. Box 597 Kingston, Mew York 12401 Alaop Engineering Corporation Hilldale, Connecticut Alsop Engineering Corporation Mllldale, Connecticut ASTM 1916 Race Street Philadelphia I Pennsylvania 1910) Asbestos Information Association 1835 K Street, N.W. Woshington, D.C. 20006 Asbestos Information Association 1635 K Street, N.W. Washington, D.C.. 20006 Congress of the United States House of Representatives Washington, D.C. 20515 Cahners Publishing Company, Inc. 5 South Wabash Avenue fhtr**n. Illinois 60603 Sugft.d Submission Federal Register Cite: Date: DeadlineExtd: A ffi, of Writer No Attachments ( i f anvl Fr Mancuso, T.F. end E.J. Coulter Methodology In Industrial Health Studies. Arch Environ Health iillB226, (1963) Selikoff, I . J . , Churg, J. end E.C. Il-- ondi Asbestos Exposure end Mcopiasa. J.A.M.A. 168:22-26, (7964) 6%/tif/ Selikoff, I.J., Churg, J. end E.C. Ha-- ond; The Occurrence of Aabestosls Aaong Insulation Workers ia the United States. N.Y. Aced Sci 132>139-155, (1965) Enterllne, P. end M. Kendrick: Asbestos-Dust Exposure at Various Levels and Mortality. Arch Environ Health 15:181-186, (1967) Selikoff, I.J., Churg, J. and E.C. Ha-- ongt Asbestos Exposure, Smoking and neoplasia. J.A.M.A. 204:106-112 (1968) Hurray, H.M.: Report of the Departmental Co-- lttee on Compensa tion for Industrial Diseases. H.H. Stationary Office, London, (1907) Ditc Subottted Submission J r> A ffl. o f Writer t " Attachments ( i f any) Cook, W.E.: Pibroals of the Luna* Due to the Inhalation of Asbestos Dust. Brit. J. Mad. 11 p. 147, (1924) l Herevether, E.R.A., and C.W. Price: Report on the Effects of Asbestos Dust on the Lunas and Dust Suppres h sion in the Asbestos Industry. H.H. i . Stationary Office, London, (1930) Drenasen, W.C., Jallavalle, J.M., Edwards, T.l. at si: A Study of Asbestosls in the Asbestos Textile / Industry. Public -Health Bulletin Ho. 241, p. 126, (1938) British Occupational Hygiene Society Sub-Coanlttea on Asbestos Hygiene Standards for Chryaotile Asbestos Dust. Ann. Occup. Hyg. 11:47-69, (1968) Berry, J.: - Hygiene Standarda-Theory and Application. Biological Effects of Asbestos, pp. 145-149, Interna tional Agency for Research on Cancer, Lyon, (1973). Criteria for a Reconnended Standard.. ..Occupational Exposure to Asbestos, National.lnstJj^Je;jfor Occupational 5s 3 l i t l e ] 4A-PROPOSCO KULE/PROPOSAL DOCUHtKfATION'REPEItEMCfcb Docket Hane Docket Hunber ASBESTOS/1975 H-033 t.O >tVW l'tWiHW*t|^iaa Federal Register Cite: Date: Deadline: Extd: Subsisslon ) y A f f i , o f Writer Attachments ( i f any) Knox, J.F., Bolaee, S., Doll, A. and I.D. Hill: Mortality fro* Lung Cancer and Other Cauaas Among Workara In an Asbestos Textile Factory. Brit. J. Indautr. Mad. 25:293-303, (1968) Lewinsohn, H.C.: Tha Medical Surveillance of Aabeatoa Workara. Boy. Soc. Health J. 92:(2) 69-77, (1972) Andareon, H.A., Sellkoff, I.J, U l ta, H., and 8. Daus: Houaehold Contact Aabeatoa Naoplaatlc Bisk. Ann H.T. Acad. Sci. (In Freaa) Sellkoff, I.J., BaMond, E.C., and H. Seldnan: Cancer Blak of Ineulation Workara in tha United Statea. Biolofical Effacta of Asbeatoa, pp. 209-216, Inter-national Agency for Reaearch on Cancer, Lyon, (1973) Bnterline, F., De Coufle, F. and V.' Henderson: Mortality in Belatlon to Occupational Exposure in the Asbestos Industry. J. Occup. Med. 1*1897-903, (1972) .o?> 55 7 /A f t3 CRMC-MAD-000537 Federal Register Cite: Date: Deadline: Cxtd: A ffl. o f Writer I-___________Attachaents ( I f an Silibff, Haeaond, E.C. and i. Churai Carcinogenicity of Aaoslta Asbesto*. Arch. Environ Health 25:183-186, (1972) Hi''holson, H.J.i Recent Approaches to the Control of Carcinogenic Exposures: Asbestsa-tha "TtV" Approach, Mount Sinai School of Medicina of the City University of Mew York, Hew York, 10029 * Huaond, E.C., and I.J. Sellkoff: gelations of Clgaratte Smoking to Risk of Death of Aabeatos-Assoclated Disease Among Insulation Korkers in tba United States. Biological Effects of Asbestos, pp. 312-317, International Agency for Research on Cancer, Lyon, (1973) Vagner, J . C . , Sleggs, C.A. and P. Manchand D iffu s e P le u r a l Meaothelelona and Asbestos Exposure in the Worth Western Cape Province. B r it, jJ . I n d u s t r . Med, 17:2 6 0 -2 7 1 , (1960) E ntlc k n ep , J . B . en! V.J. S e i t h e r : P eritioneal Tunare ln A sbeotosis. E rit. J . Industr. Hed., 21:20-31, (1964) C R M C - M , ;")-000538 "3 (lUMWh I Federal Register Cite: Date: (fi) Dead; ne: Extd: A ffi. o f Writer Attachments (If anvl Borow, M., Consto, A., Livornese, L.I., end N. Schalet: Hesothallcas Follovlng Exposure to Asbesto a evif u of 72 Ceaes. Chest M i M l 646 (1973). Haan.'od, E.C., Sellkoff, I .J . and 3. ChuTg: Neoplasia Aanng Insula tion Workers In the United States with Special Reference to IntraAbdoalnal Neoplasia. Ann. N.Y. Acad. Scl. 1321519-525, (1965) Newhouse, M.L. and C. Berry: The Slak-of Developing Heaothellona Tunora Anong Workers In An Asbestos Textile Factory, XVIII International Congress on Occupational Health, Brighton, England, (1975). Eines, P.C. and H.J.C. Slapsoo: Insulation Workers In Belfast. 3. Mortality 1940-66. Brit. J. Industr. Med., 28:226-236, (1971) Stell, P.M. and T.McCill: Asbestos and Larynges Cancer. Lancet 2:416417, (1973) Newhouse, M.L. and C. Berry: Letter to the editor: Asbestos and Laryneal Cancer. Lancet 2:615, (1973) CRMC-MAD-000539 bL-l/f# `A * iM $ 7/ ritie] 44-PROPOSED RULE/PROPOSAL DOCUMENTATION/REFERENCES ASBESTOS/1975 Log Sheet Huaber u Federai Register CItei Date: Salikoff, I.J., Haanond, E.C., od J. Thurg: Mortality Experlanca* of Asbestos Worker 1943-1968. Pneuaoconlosis, Proc. Int. Coni. Johannesburg. 1969, pp. 16Q-166, Oxford University Praaa, (1970) Howard, S., Kinleln, L.J., Lswisohn, H.C., Pato, J., and I. Doll: A Mortality Study Aoong Worker* In an English Aabeatoa Factory. XVIlI International Congress on Occupa tional Health Brighton, England. (1975) Brody, J.E.: New York Tinea, Sept 20, 197.4 Webster, I.: Asbestos and Malig nancy. S.A. Med. J. 47:165-171, (1973) Greenberg, M. and T.A. Lloyd Davies: Meaothelioaa Register 1967-68. Brit, j; Induetr. Hed. 31:91-104, (1974) Lillington, G.A., Janpoe, R.W. and J.R. Differdlng: Conjugal Malignant Mesotheliomas. New big. J. Mod. 291:583-584 (1974) CRMC-MAD-000540 Federal Register Cite: Date: Deadline: Exts: A ffi, of Writer Harries, P.G.: Asbestos Hasards ln Naval Dock Yards. Ann. Occup. Hyg. 11:135-145, (1968) Whltvell, F. And Rawcllffe M. ; Diffuse Malignant Fleurai Hesotha lote and Asbestos Exposure. Thorax 26:6, 0971) 37$/' i'A///-3 and A.A,M. Gibson; Mesothelloaa In Schotland, Brit. Had. J. 4:575-578. (1970) h i a t h i U o M on Weicheren Island, irlt; 1. Induatr. Med., 28:59-66, (1971). hears, C. and A.R. Teapleton: effects of Asbestos In Dockyard Jorkers. Brit. Med. J. 7:574-579, (1968) `'letcher, D.E. ; A Mortality Study >f Shipyard Workers with Pleural 'laques. Brit-. J. Industr. Hcd., 9:142-145, (1972) CRMC-MAD-000541 Federal Register CItei Dates ,r- / *.T Deadline: Extc. Submission A ffi. of Writer Attachments ( if envi o. 3^ M a C I U M , J.D., I t MB, .A.. Archer, V.E., Wagner, J.K., ad J. Pa-- nt: Morbidity and Mortality Aaoog Hard Rock Minara Exposed to an Ab-- tifoni Mineral. Ann. I.T. Acad. Set. (In Praaa) Edge, J.R.i Aabaatoa Related Diaease in.Rarrow-ln-Purn-- a. Env. Reati. (In fru) 5$S J O H N S -M A N V IL L E ___ ___ _________M f l i r o a -- __ FACTORY report No-... P ip No.-----------------------Date___ Subjecti pyrox "A" (Pyrophyllite) - Substitute for A.P. Pulp - Spec. #61852-1 RequMtedbriHr. p, l . Hess wentincotJoiuVendor - R. T. Vanderbilt Co ______________________________ _ Pyrox "a ", an alkali-metal aluminum silicate la recommended as a direct substitute for the A.P. Pulp used in the manufacture of both 31-9515-1 Compound and Chenstone Cement 31*9515*1 compound is further processed into #3-S Cement. A.P. Pulp is used am an inert filler in Chemstone Cement. Pyrox "A" is currently being purchased la oarload lots for use in"F" Bldg. at $15.76 per ton delivered and may be transferred from "p"to nB" Bldg. The A.P. Pulp purchased from C. K. Villiams Co. in Easton, Pa., oosts $20.AO per ton delivered, so that there will be a rav material savings of approx. $4.6$ par ton used. Mote: Produot Proposal #$73 Supplement #1 issued 3/24/47 approves the use of a new vhite rubber oompound #31-9962-2 for tho manu facture of a new white 3-S Cement. 31-9962-2 Compound requires no A.P. Pulp in its formulation. The above recommendations have verbal approval of Researoh Laboratory. SUMMARY: Two batches of 31-9515-1 Compound were milled in "BM Bldg, using Pyrox "A" as a substitute for A.P. Pulp. Compound was ohumed in 3-S Cement. #189 Cloth was coated with this cement on the Devlno Machine. Coated cloth produoed satisfactory Kearsarge Caskets. DATA: - A.P. Pulp and Pyrox "A" A. P. Pulp Material Magnesium Silicate Moisture Ignition Loss Benslty-#/ou.ft, Fineness: Passing 100 Mesh n 200 " Color Cost 0.16 - 0.34* 19..3 * 21. 4`0>,.4 - 41 98.0 - 100* 93.1 - 96.25< Oravioh Vhite $20.40 Pvrox nAw Alkali-Metal Aluminum Silloate no2-3?S.s# 10056 94 - 9.0JS Grayish White $15.76 Spec. 61852-1 Magnesium Silloate 0.5 Max. 20.056 Max. 45# Max. IOO56 9 2 % Min. White to Gray ApprovedPomi XMO-M V W J'nnifd iC U.5.A. Report b f. CRMC-MAD-000543 ALWAYS Rtnx TO AMVK RKVOUT NVMBHt IN COMRfvroNOr.NfJc Subject 1 nequeMeJ b; Idenllfleatkmi , ,v -I ' . Ingpection and Control Department J O H N S -M A N V IL L E Report N"-- C . 0 9 6 3 3 - FaieNos-- ,-- ^ ------------ -MM O T i L l FACTORY Palo-_ -5/8/!' PjTOX "A" ^ypophjlllte) - Subltituts for A.P. Palp - Spao. #61852-1 Vendor - Ro To VandOXfellt CO. DATA; - Coat'd. II - PhTsloal Test - 31-9515-1 ConDOtmd Containing Prrox "A" Batoh Batoh Control Soeos. Honaali Barometer Teaslle Strength Elongation 29-6 ,, 79 960 p .S .l * 300JS 29-7 79 1180 p.s.l. 385S* 75 - 85 900 p.s.l. Min 200* Min. 'U JP. 00 - Messrs. P. Ryan P. D# Ceaaoa F. L. Hess Attnt A. D. Carlson E. R. VlUlaas (a) Attar R. T. Raleteed Attat R. s. Parry 0 K. Vinqolst J. R. Robson F U e (3 ) Appro rod r.ff.nXAWil I.'ft K/.ni/ij e U.S.A* CRMC-MAD-000544 ----- Report bp--_ _ 9 * 5 m A U * I c p $ i ___ ALWAYS *rru TO ABOVI REPORT NUMB IN CORREtPOMbFNCK 3/Si Johns-Manville ' Internal Correspondence | k> ME MU TO FILE f,om r , p. carter ** N o v . 13, 1973 r C o p ... File s C Su&,t p j - ; m e e t i n g K IT H JOHN O 'N E I L L - NOVEMBER 8 , 1973 MEETING WITH JERRY SCANNELL AND JOHN O'NEILL - NOV. 9 , 1 9 7 3 Several weeks ago, upon learning that John Stendor had decided not to appoint a Standards Advisory Committee in connection with the reopening of the asbestos standard, I called Jerry Scannell's office for the purpose of setting up a meeting with Jerry to determine why this decision had been made and what Johns-Manville and the asbestos industry could do to assist OSHA in promulgating a new standard. Jerry Scannell was out of town on business in Hawaii for a period of three weeks and therefore, the meeting could not be set up until November 9. After a meeting was scheduled with Jerry Scannell for November 9, I was advised that John O'Neill would'be delivering a presentation to the annual meeting of the A/C Pipe Producers Association in Washington on November 8. I attended that meeting and had the opportunity to informally speak with John O'Neill in addition to listening to his presentation. $ During our informal conversation, John O'Neill indicated - that one of the primary reasons for Stender's decision against the establishment of a Standards Advisory Committee was due to the fact that if such a committee was appointed, Dr. Irving J. Selikoff would have to be included as a member of the committee. I cot the impression from O'Neill that Stender felt that Pelikoff's presence on the committee would irpair the functioning of the committee. O'Neill further indicated to me that the thrust of the revision would be the cst.-jLl 1 sh.-.ent of work practices. I indicated to John that it could conceivably take several years to prepare work practices for each segment of the asbestos industry. John agreed, but indicated that they would attempt to prepare work practices by processes which were common in each segment of the industry. Durinv our informal discussion, John O'Neill mentioned that he had read the first two installments of Paul Brodeur's series of articles in the New Yorker Magazine. John was not happy CRMC-MAD-000545 tMLJX MEMO TO FILE Page 2 November 13, 1973 with these articles as it presented a very one-sided picture of the asbestos industry and was concerned with several unfavorable comments made about certain government employees. During his presentation, John O 'Neill made specific reference to the unfair treatment of the asbestos industry in the news media and how only one side of the story was being told, which in his opinion, was quite unfair. During his presentation before the A/C Pipe Producers Association, John O 'Neill was quite candid in his remarks regarding the reopening, I did not get the impression that John O'Neill was speaking from any prepared notes but was rather making off-the-cuff remarks. The key points covered by John O'Neill in his presentation were as follows: (1) The OSHA standard for exposure to asbestos dust was written only to prevent asbestosis and was not designed to prevent mesothelioma or cancer. (2) The new evidence which OSHA now has is that fibers other than asbestos can cause mesothelioma. (3) The British data upon which the current OSHA standard w*as based is wesk and not scientific. (4) OSHA wants to r-evaluate the TLV for asbestos. (5) When preparing :he current asbestos standard, OSHA did not take into consideration the ta!~ mining problem. He indicated that tremolite is not fibrous and it has not been proven that tremolite causes any harm. OSHA therefore, must re-examine the types of asbestos covered. (During this past Summer, R. T. Vanderbilt and Company, a major talc producer, filed a petition with OSHA requesting a modification of the asbestos standard, basically deleting tremolite from the standard.) (6) The method of sampling and measurement must be re-examinec In a phase contrast system, it is difficult to differentiate and distinguish fibers. (7) The types of respirators permissible must be re-examined. As of April 1, 1974, many respirators will lose their current approval. CRMc -MAD-000546 k MEMO TO FILE Page 3 November 13, 1973 (8) OSHA wants to re-examine monitoring. (9) Work practices must bo developed, evaluated and made mandatory. (10) Asbestos is essential in many uses and OSHA has no intent to ban its use, Father, OSHA is desirous of establishing safe ways of using asbestos. (11) John Stender har opted for the use of outside consultants in lieu of appointing a Standards Advisory Committee. (12) OSHA wants the new standards to be very clear. One of the strong reasons for reopening the standard is due to a large number of inquiries OSHA has received during the past year and a half for clarifications and interpretations of the standard. It is their conclusion based on the volume o: requests that the current standard is not clear. (13) The current numerical standard will probably remain unchanged. (14) OSHA would like considerable input from industry to assist them in drafting a new standard. On November 9, Jack Solon and I met with Jerry Scannell at his office. When we arrived, John O'Neill was also present in Jerry Scannell's office. Jerry indicated that he was currently in the process of preparing a written proposal to John Stender which would consist of a procedure to draft and promulgate a revised asbestos standard. This proposal would be in lieu of the establishment of a Standards Advisory Committee, in view of the fact that Stender had rejected the establishment of such a committee. Jerry's recommendation to Stender will be for OSHA to prepare a draft of a new asbestc^ standard which would take at least three to four months. Then ^ _ OSHA would use outside consultants, individuals picked from industry and labor, to be used by OSHA on an individual basis. ^ For example, Scannell would propose contacting AIA to receive o recommendations for individuals to be used as consultants. ^ At individual meetings with these consultants, OSHA would discuss particular portions of the proposed revisions with experts in specific areas. After OSHA has met with these consultants they would then arrange to visit various plants in the asbestos industry to determine the practicality of the revised standard. Jerry Scannell indicated that he had O Page 4 November 13, 1973 received a ruling from their attorneys to the effect that s u c h a plant visit could not be the basis for an OSHA citation. Jerry was quite concerned that various companies m i g h t object to OSHA'a .resence in a plant due to a possible citation exposure. Jerry would like every effort to be made by OSHA to insure their credibility with industry that citations would not be issued as a result of these plant visits. As a matter of fact, he would attempt to work out an arrangement with OSHA enforcement people so that no plant inspections would be made in those establishments visited for a period of at least one year after their plant visit. Following the plant visits, OSHA might perhaps meet on a group basis with all of the consultants for the purpose of reviewing a final draft of the proposed regulations. During the entire process, the proposed regulations would be revised and altered informally as necessary. The final step would be the publication of a new proposed standard in the Federal Register, which probably would not take place before a period of one year from now. At the time the new proposed regulations are published, OSHA night announce a hearing date at that time if they feel there will be substantial comments or objections to the proposal. Jerry indicated it was conceivable that if no meaningful objections were made to the proposal, no hearing at all might be scheduled. Towards the conclusion of our meeting, Jerry Scannell indicated that there were several things he would like from J-M: (1) A letter on how we would like the asbestos standard modified. For example, what aspects of the standard are currently unclear or impractical. (2) Provide OSHA with suggestions for improving monitoring an! fiber counts, perhaps including a proposal for scrapping fiber counts. (3) How can OSHA get Labor and Management together to discuss a new proposed standard without such a meeting being conducted on an adversary basis. (4) After Ed Fenner establishes a Technical Committee within AIA. Ed Fenner should contact John O'Neill to discuss whatever assistance the Technical Committee can give him in drafting a new standard. __ _____ CRMC-MAD-000548 MEMO TO FILE Page 5 November 13, 1973 (5) Jerr^' Scanr.ell may need assistance from J-M and other companies in the industry in selling his new proposal to John Stender. In view of the fact that J-M and other companies have sent letters to Stender-advocating the establishment of a Standards Advisory Committee,it might be desirable at some point in time for us to advise Stender that we support Jerry Scannell*s new proposal. In this regard, it is my intention to contact Jerry Scannell at the earliest possible time to advise him that J-M fully supports his new proposal to Stender and advise him that we would like to cooperate in any way possible to assist him in selling his proposarl to Stender. I will suggest to Jerry that he give consideration to arranging a meeting for J-M with Stender, at which time he should be present, for us to convey our support of his proposal to Stender. The timing-of such a meeting should be left to Scannell. R. P. Carter P.S. - After dictating this memo, I spoke vitn Jerry Scannell by telephone at which time he advised me that he had presented his proposal to Stender and Stender had accepted his suggestions. I then asked Jerry if we should either write o r `call Stender for a meeting to indicate our support of their new proposal. Jerry said the decision was up to us but we should either call for a meeting or present our views in a letter to"Stender. It is my present plan to draft a letter to Stender withdrawing 'our request for the establishment of a 15-man Advisory Committee and supporting Scannell's proposal. I intend to read a draft of this letter to Scannell over the telephone and ask his suggestion as to whether or not the letter should be sent or a personal meeting arranged. CRMC-MAD-000549 Johns-Manville To. 'P. K O t i n , M.D. Internal Correspondence V ..v WO d m : M a y 26, 1976 fm * 5 M* Fenner Coi: G. W. W r i g h t , M.D. W. B. Reitze Sublet: A M E R I C A N M I N I N G C O N G R E S S NONCOAL OCCUPATIONAL HEALTH COMMITTEE R. R. C a r t e r This committee held its first meeting in Washington on Tuesday, May 25. ' The first half of the meeting was a discussion of the purpose and scope of the committee. Then considerable time was devoted to comments on the forthcoming meeting of the Federal Metal and Nonmetal Mine Safety Advisory Committee (see copy of o u r m eeting agenda a t t a c h e d ) . An item on the Advisory Committee meeting agenda is the MESA suggested revised standard for exposure to asbestos (copy attached). The critical change they proposed is the substitution of the term "mineral fibers" for asbestos, and the elimination of any definition of asbestos. Literal interpretation of the proposed standard could mean that any naturally occurring mineral fiber whichrmeets their definition: "A fiber is defined as a particle that exceeds 5 microns in length but not 5 microns in width and which has a length to width ratio of at least 3 to 1" could be subject to this ruling. T h e c h a i r m a n o f t h e c o m m i t t e e . B e r n a r d R. Ro y o f A m a x Inc., appointed an ad hoc subcommittee consisting of: C. S. T h o m p s o n , P h . D . , R . T. V a n d e r b i l t , C h a i r m a n D a v i d J. Smit h , M . D . , U. S. S t e e l C o r p o r a t i o n M i c h a e l J. Doyle, T h e H a n n a M i n i n g Co. E. M. F e n n e r to prepare A M C s comments on the proposed standard and to determine the most effective way of convincing the committee not to endorse the proposal. For your further information, lists of the Committee members and those attending the May 25 meeting are attached. May I please have your comments. E. M. Fen CRMC-MAD-000550 N onas fntrri -C rm.1 eoa l'.tret with ih? of v o Nat: r .-U Trc.'T.c nnd M- ' * \ ii;. > y.<:< -v Atu of IMO. Ac* >.*. :v. l.vrr.p- -7. i;.r .:v J. JVT7. : ":(.v :-.l H> irci .re M o'.ot V- Ju i > N s. 212.. i.' i. .b. s. r *e UH';, ; !M) .'>r*\. orf.'sr'.epi. t.r. n s | v. *> ' v-.i .!?.1974. JUv*.: i! Ger ,o?r, : : * ~ ` ? r ~ * v* wn * DEPA'Tf.ENT Or A C u .r J IT U r i C-^'r--.'-.Vy A.rrecirity ti-* - s n e.: /.n o I r a e ' . m e H I'U,,iS 7 '" i':. ;I 7 c`.l'oy Co--.- T or uri ! '. < i I 1 .. . :t f;<* C'nlc*r.n c tir? .1 M I. * i >*'! 15. ::.M. r u-j v. ; : ip :-.rv t.ns in* {t;.-. .v-sr.. n w.v.1 c . carcera* l~ ,* : r.".ri tr.'.r.-aciions r.r.4 jv>tfocu of e.ri: *:-) tncit-r. f : :.w: rmatrtn was ruVrr.ltted In cie co;'.. .:.:e rA/ ;.'r; 1 of tire i'ernmed- y 1 . !... r .Vrt t i T.' C M e * .lei rec*::rs .`re~rrre.-v ur-'-r. rc-qncrt of ;t: / f o: en n -r c u e c i con* r r n r t . r . c vr.urn th e -s -c -ri Iti Jurlv ' r rs. to junv.-h r-rd r :r re public the t. -r.re a n i rc-ire-rea c-i *r:r;i traders, t !, f.n tr c i;h informai ;cn c remem in ; thr.r futures trir.saft'.ona. The material 5V.'.>~.*.tred r o 'e r r i tho*e t r a i* in re por.. r - rfrt is (hcidlre portion of 25 contract, or more Is any one lit i cattle future). The C u t wta he cr.iids ar&ilable for inrerection nnd coptine lo nnrone upon repu-rt a* *he Co-r.moiy Eccitane? Au thority e atre la \Yj..h:r.c!on. D.C. or IU rerion.il cEce in C hiesto In accordane with the Department o f ArrSculture fen schedule, copies of the materUil 10 I fum t-hed a t cl..,vrp> o f 10 cents for each cepj of each pace. Esiued: July SU 177. A tra C. C ltM T iU , XfSnlsIttrelgr, C or modi Fzchanct AvfAoetfsf. | rn Dnc 7t-177tS PUMI M l| fwmcit Home MwliilitnO |DnlCMtM Ss IM| TEXAS Oes<;fitKtf ef Emeegeney Ae*M The FcrrrtAr? e f Airrtcaltnm hM !t r it i Uiat o cenerai nerd for aerim iiurta m in ru tta la U f e O n t t f eaaiMT la Teiuts: SwWMr Ti;c Secretary tu flu iv i that tfit* m id ette--. iu a rtt.u". <f * naturai dU- a. U r ror '. . of ;t -I'.'..''d drouitl'.t tr - r . O. U !.. r t'J73 u; ;! As-ftl 1971; e ; - C '" . e r.i`r f..;i Jur.* 5 T .'.'l. ..nlltfms Ut at.d Jure 13. t '7 ; r.fAl . .ivt a .- ` Ju: r 7 U rc : 'fi ~:r11.re. the :---- - I.; ;>'i i ;c. !.. . 1?. 1P71. );.u ir '.- ! T I.n.'r' ' :r*r ! - v> . : u. : i r,t of Ci: - 1 . - ; r. ;.-..i iJev.icp- l'i ' : .".. 1. :. .. : ; V ' .u I. 33 -237. a?. : . * ; ... . f 7 r i ir.r.23<o.) iti- ; :t:-.r II .: :! : Ci.-.v* : - -r i ' . . ' i 'i l i; i .* ; . .:. ti-, il 1o ! A"' ' i iv.i.-.' f T I -- :r Tl'un: ri ", t li r.;u t;l t.'.r (ir . . -i '.ria Si .ri.;W f.;i - t.r -i e ~ rp t> tf-r -ir iT.tcr* ;t io ' \ \ r r...' * r.o'V' ef f . :*-iti n:!* n u l a ; t.:.d ititi te puUUc l '.vrttcpaUon. Itone nt W.vliln.-.Von, D C . this 30th d.iy of July, 197U Er.ANK n. Eiirr-rr. /tf--imuirclor. F e r m e r j U o - i r .1J --.m o lr c h ip n . |m Doe.74-ITTtlJroes ami DEPARTMENT OF HEALTH. EDUCATION, AND VrtUAKt Ccrier foe D .-esss Control COAL PIllE HEALTH Aihrstc* E r p o I n Sorfjre Cent Mleet *rtd Sortrce V.'crV Areas of Undergo jnd Mines: Finomcs ol Fact S?ct!-n 101'e> of the Federal Coal Mine Health and Safetr A it c! 150S <2i O.S.C. 8M<c>t. hrr-tnaitcr referred to ns the "Act." prevt'drs. In part, that vfth ln 6? d^r* a ft'r rnmnletlnn of any ptiMIc heartnc on 'd mandat-ry health or safety tfanda.'tlv the Secre tary who held the heartnc ahaC rn.iVe nndln;* o f fac3 whlcta rhall be public. B in o e m Proposed amendmerst# to mandatory health atandards tor aurfaor wor t ar?M ef underrroundeoal mines and surface coalm ines 30CTJt P m 11 w eredrreloped by the KaftonaJ Xnstltuto for Oe* cupational Rainy and Health pursuant to fectlon 101 ef the Art and tram m ltied to the eeereU r or the Interior far po v. Uration In eeeenl-r.re with Ui* A ct 7 t * amendm. nU were rui.H i.ed urdr n o tice of prepneed rule-m .tuny on Korea*brr T. HT3 '>T FR 23tsi and interested peraom were aHorded a period e f ift day* v tth ln whirl to subm it w rtV j* com - m enu, su rm U en s. and bjcctieae and to reswest a public hearing. O s AprO IE 1*14. the Peetetary of the lM n h r , to awordaww s i f t teetloa 101ID e t Or Art. puSHWrfd a ooUre ( f f * IW 8 3 th.i' oV;ct tloru li.ii.) V rn flit d lo th? pro- ;j ~d mai. `.`.nry f.'idth y! uidiird for tecupitior ' t i e n e lo s t'V.m stai* Ine'tiie for ruch ob.c.Uotts and Iti . l a i :-)'./- ht.ir.tie had been riciutnled. K' . o s ;r..' > it t ont e, liie Department of li' :-'.. Ie!u- ati`*ri. a-ni Welfare pub- li-l. -t a r . e fi.i re a lime imd pl.ve o l li .e vr>:> ,, 1 , l o b ? ln '.il for the rear; " nf re - i . * r* V'ani t". hlcnrc on li.r projo-ed a. bc .'.te. y'.uuUnl 123 i'K 163131. HlAM.SC lf*ar::v ^ h'"*''. <^ J'U'f S. 1074. I V-- i ii/.ii. y .v *- : t'rtir- I.:.-; nt ;!,<*. *.! r . ; I'.-*- i :.:r \ v:e ty U\. v.:-.r r : ).: I ' - J <;, tor'' A v ; it jnrj. K . \ . ' i: (' -.1p . A ' u. In- ..'.i.i - A . .p i . -i. I ;..' d ? f m e \. ' .1 ; : " 1 1: !"..U 1 . ' 1- " 1 cl .' 1 ,, ( > A ViT- i . v. i ; r t : - ' rii is :->r p *.*c ir.*;-'. -n a*, the N.i'. -..al In .re f >r i>."'.;pj'.'.:n3il S-'Criy rvr.r* l ?>n i . r a r i : H-uMirn. Koorn 3-3 2 i f '.3 fV. Lane. Kockvtlie. Mary- Ixr.d. ZhwDDJOS On ihe brl!s of tv - -rt-lcn.'-e prr-rnted a: ;Vc her.r.r ti'id on otiu-r lnfocrr.i'tln -T ..'. .'I f to tur Drpaum-r.t. thr Dirrrtor of the Nvi-.r.-il ir.rtitut? lor Occura; ':*.'2 Pah ty r.r.i! If-.'.lth. |Air*u.int to r.tr.honty e**-:- -j red from the Srerewry a r i the A ' t.vit F o - c '.nry for He.tlth < 3 i r <>. i i i 5 i i . r i mL>t p . a t : 1. 'l.i'.rc U a c.m*a) relationship be re '.-n occuM Honai c-r-vpire to airuotne a te -:.o hbcrj and Uie devriopment of diren-e. 2. Atr-f<rs Is lnfret)Ufp.f!y uerd In sur face coal rr.T.lnc op<*ration, r.d rarely. If crer. tired in surface operations of un derground coal mince. 3. There is medical rrtder.ee which ln- .catcs that n e n lrJreduent exposure to airborne *.*bc*tcs can esin e disease. 4. tfh e n asbestos Is used tn coal m in in e o p erili ana. technology esL-te for m*:nimli.e tlic l-hour average air borne coiKcntra'ton of aibcrtoa diut to which miners are exp ovd at or below two fibers <crr-.tcr than & microns tn lenrtii) per ruble centimeter of air but not to rxcred 10 fibers per cubie centi meter more than one hour of each 6fcour day. 3. A standard requiring en d mine operatcr* to ma inLain the 4-hour averegw airborne concentration of asbeitoe dust to which miners are exposed at or below two fiber* <rreite r than I microns Is ler.-th per ruble renttmeter of alr hug not to exceed 10 fibers per ruble cecrtSweter more than one hour of each B-hoor day. Is norensary for the proteeUon o fltfe ar.d th e prerentieB of aceupaUonal dto wmo o f saisers. Dated: M r *U W i Hunt It JCrr, HJK Dtr/rtcrr. A'clioaaf fuUtwf* far O w s y ilM il fit'd y sa" UtftiUk. im C ee it-tm s p im o-o-n. ) WMM OMMfOBi w*. *. " i M # i , aumw % mw rR M C -M A D -000551 ZS000-OVlA[-3Mtf3 e'WT^/s f-s'o c o ' m grufai aratft (WWC Og*CW*I O0*$C6*7n 00*728*931 Si*; y rtC r C *0 0zi no " ^r" w j-v .gy 0 * ) / ! T '* * > m p*w<w7 ..................... .. 6 f IZ & f. gg f . j !>** . . . . . . . . . . iz - I n**? ......... . tc qorr " 1 *fcf 7C#7l9*ue*2 *600*719 fri#?# zzrux'iL TZS3/9S TS*896`7C7 0b'00l*i 1*727*C6*T C cuo Sic * *0 gol 91 " * Vz ............... K - < N SI ..........................: z ouo I L ............. *3 X *0 "0 9S * ........... * m i *6 - c sor.ii'iH 2 -w iisxijb a r.y a a i L m j r T r *n r r 1c r r .r r y t t i ~5 t i e n o li. M T te ilL I1T 1II nei Afe* JUTUQ3 A ra 3 - 9 , M U a u s nere :tb CL1 asppuza u 6 -3 e i t r < 10 aiM k C.V. F n ttfe r 4*3 6*3 Befane P in ot Corp. 6*3 6^ M Sto va Zao. a** * Bolnad Co. In o. Land * Mortlrup Co. li 4 i< 2 laob and n ofer o. 1 boa-do 6 nlaath iiig fa r fo ra lirthao Bnedlnbora 40606 A laro-as Roooordlac C ostrallnra S ki& ~ 330X 0 3 P 0 0 .0 0 7 2 0 .CO ir'V A U 6 -1 6 -2 C ia n a Co. feU ritta r [ti; pP Ir 6-2 6 -3 fim o * f e lla ? Cotton # TU Co. U (jw i* 6 -3 6*5 CoaandioK G a m i 70 tb Ia f. W v. E le c tr ic Co. VA | -5 6 -5 a la r C lt? CeM M en e Co. M -6 U la m a ? * "* Co. Joanph lo d a r Co. Itetbar /aeu w v 600.C ' S ten tin e /o lio pine ? i l ? 6 ,OC5 .OC j CoafaLaction rod io po-togrmpa o tto In o to el 39710C H-21 AX a t e i ncU ne 13.0X .D C eto . Sfilit e pine # 0 0 .^ 1 JMbar 6 -7 6 -7 U . m ilw w Lafeor Bourlaa f i? 2 ,2 X .:o d o . Qt q j Ga, fe llo * p*n- a^>x.T O CRMC-MAD-000553 10 Canee 5 ^ 1 0 2 .X uence External 1. Labeling-- During June of 1974 we d.'.cussed with various customers the possibility of labeling our talc products. This resulted in an immediate loss of some accounts. Letters were sent to our customers advising that the label would be affixed to our bags effective November 1, 1974. These letters were sent out in September of 1974. The results of the letter in September and the actual labeling November 1 caused a further loss of customers. Our estimate of lost business on an annual basis was approximately 30 percent of our tonnage and 40 percent of our dollar volume. Please refer to my attached letter to P. Kotin which shows this effect. R. T. Vanderbilt and Pfizer (California talc) are not labeling. R. T. Vanderbilt is certifying their talcs arc asbestos-free, but we have no Knowledge that Pfizer is doing the same. We feel that Vanderbilt and Pfizer (California talc) will be required to label before the end of 1975. The adverse publicity generated concerning asbestos and tremolite has been such that even if we could remove the asbestos label from our talc, it wculd be some extended period of time, possibly a year or more, before we could regain business lost to asbestos-free talcs. 2. OSHA and NIOSH-- Jointly studying asbestos in talc. OSHA has requested NIOSH to study asbestos in commercial talc, and NIOSH is studying asbestos content of talc mines with MESA. NIOSH considers all particles of chrysotile and the amphiboles that have three-to-one aspect ratio and over 5 n as asbestos fibers. We expect increased activity from state (particularly California) OSHA offices on our talc customers because of tremolite. 3. FDA-- Does not appear to be a problem at the moment. Their position stated in the Federal Register March 14, 1975 withdraws their proposed ban of talc in food packaging. The proposed ban drew attention to asbestos in talc and we will have an uphill battle to get back market share we lost. CRMC-MAD-000555 4. General Market Conditions-- See Talc Sales attached a. Our ceramic and tile business vc:m 5nc relatively strong in spite of our problems. b. Paint is weak due to the economy and our tremolite/labeling problems. c. Our plastic business has all but disappeared due to the tremolite problem with the exception of Solo Cup which we started to sell in October of 1974. Solo remains strong but tremolite and the label are an ever present potential problem. Competition from Pfizer is fierce but we manage to hold on because Solo likes our product. d. Tremolite, the label, and quality, plus a poor business climate have combined to hurt our sales to the paper industry. Competitors from Montana talcs have been only too eager to point out to our customers that our talcs contain asbestos fiber. This is very rough competition, and coupled with the economy and quality problems makes for difficult marketing conditions, to say the least. c. Price increases--We had planned a six percent price increase for talc on an annual basis. Vie have implemented a three percent (annual basis) increase and have met great customer resistance. It is doubtful that a six percent will be achieved in 1975. A decision to label by Vanderbilt and Pfizer could reduce the pressure on Desertalc and allow for selective price increases. Internal Influences 1. Ore Quality and Control Related to F.P.S.-- The problems with ore quality came about when we were forced to above ground mining. The lack of selective mining has caused virtually all of our problems con cerning brightness and acid solubles. The Mining Division is formulating a mining plan which should be comp]eted soon to alleviate this problem. Problems encountered at the milling locations resulti in inability to meet F.P.S. stem primarily from the crude ore being shipped from Warm Springs. This, hopefully, will be corrected by the mining plan mentioned above. Other quality problems were caused by grinds being _oo coarse and poor plant management. Plans to train and adequately staff quality control personnel have been put into effect by Mining and Research. Plant management and supervision should CRMC-MAD-000556 improve dramatically when the Mining Division implements their new organization plan for Desert. Minerals on April 1, 1975. IV. Action That We Plan to Minimize Unfortunate Influences A. Tremolite and the Label-- We are and will continue to educate our customers on the necessity of proper du^t control not only for asbestos fiber, but for all dust which is required by OSHA. Our industrial hygiene studies are very helpful in this respect. We believe and are attempting to convince the customers that they must clean up their plants and control dust to comply with OSHA regulations. By so doing, he eliminates the problem of asbestos. Wherever possible, we discuss bulk shipments to avoid dust problems. B. Ore Quality-- This problem is critical and compounds our problems with tremolite and the label. We are in constant contact with the Mining Division and c .mmunicating our problems in this regard. The formu lation and implementation of a good sound mining program, properly supervised, will eliminate this problem area. C. Quality Control Problems at Grinding Locations-- Good quality crude is paramount, as it is the one area that the grinding plants have no control over. The training of plant quality control personnel so they know what they are looking for and can interpret their results properly will alleviate the problems of coarse grind. This, with better plant management which should be accomplished with the new plant organization, should reduce these problems to a minimum. T. E. Remmers has been assigned the responsibility of the key marketing liaison person to work and communicate to the Mining Division and to follow problem areas through. V. Recommendations The initial crunch of lost business due to the label has been felt. Our business seems to have stabilized. We expect further erosion in paint and possibly the loss of Solo Cup in plastics. Our ceramic business remains strong. We believe we can regain some lost paper tonnage with improved quality from Warm Springs and the grinding locations. During April we will phase out production from Los Angeles and move all production to Dunn. Some Cyclo-Fil may have to be made at Los Angeles on m intermittent basis due to capacities at Dunn. The consolidation of virtually all production at Dunn will cause Dunn to run at capacity for six-day weeks. The concentration of managerial personnel at Dunn should improve the plant's efficiency and eliminate CRMC-MAD-000557 many quality, shipping, nd outages problems we have been experiencing. The costs used to arrive at net earnings with the revised forecast were submitted by the Mining Division. The cost includes the fixed cost for the Los Angeles Plant, which are estimated at $200,000 per year while closed down. If we were tc dispose of this plant the fixed cost would be eliminated. The cost of operating Dunn and Wan". Springs, in my judgment, appear to be overstated. We have never operated Dunn at full capacity with full management capa bilities which should insure better efficiency. We believe we still have a 45,000-plus ton per year business. Mining Division believes this business concentrated at Dunn will improve our profitability. We would like to stay in the California talc business at least until Penhorwood comes on stream, to maintain continuity in the market. The Desert Minerals operation should be reviewed for profitability progress after May results are in. If this business, with the changes contemplated over the next two months, can be made profitable, it will remain a good small business as Penhorwood should have virtually no effect, on Desert Minerals. CRMC-MAD-000558 tv'JIni t oVU.-'1ins -w'nnviic * P\v*4V'Y*.**'*'o f1""'Vk'',r,*^r***/**\*~ V o ^ **/?.* L*L .t*' U i LCmj Vi^ b d vw- O */ '>-h i. \.j v> >%* lo: P. A. Martinson - 2W Djic March 20 , 197S Fi e rr,- R. S. Lamar - 2W Copies : J. M. Fletcher - 2S Subject: AN ASSESSMENT OF THE J-M POSITION WITH TALC Three years since J - M 's entry into the acquisition of Desert Minerals for an appraisal of our position broken down into eight sections as the talc business with Company is time enough This assessment is follov.-s: 1. The Effects of Labeling: Our position here has been the only acceptable action J-M could take. According to the definitions that are a part of the law, our California talc products ali contain asbestos in the form of tremolite. No play on words wrill change this fact. D *i,* z>, t ]imm *-*1L llint i cov.1c !.n.:'i x?.in the uniquely high brightness and relatively low acid soluble content of G-l and G-2 talc ores, we could hold onto most of the critical markets, in spite of labeling. I now seriously doubt our ability to do this. The "talc-asbestos" problem is quite different from the "asbestos-asbestos" problem. In many applications for asbestos, there are no acceptable substitutes. With our asbestos-containing talc, there are numerous possibilities for substitution: (a) Non-asbestos containing talcs from both Pfizer and Cyprus from Montana sources and (b) Other extender pigments such as kaolin and calcium carbonate (in paints, for example, and in paper filling uses). We see this type of substitution being made and long-established markets for Dcsertalc products evaporating in the process. .000559 CRtfC-M * 0 A. M a r t i n s o n Page Two * * The R. T. V an derbilt P o s i t i o n : The i r p o si ti o n with respect to labeling must be Jo 1 ib e ra to 1y p e r f i d i o u s ; they cannot be this misinformed. Slim Thompson, their technical director, has a Ph.D. in mineralogy. At the moment, V a nd er bi lt is m i sl e ad i n g their c u stomers and c on fusing ours with their d e cision not to label. Ultimately, the truth will out, and they will be forced to label. Pfizer's p os i ti on is the same with their C a li f or n i a talcs. V.'ith all a s be s t o s - c o n t a i n i n g talcs labeled, far greater value and emphasis in the m a r k e t will be applied to a s be st os -fr ee talcs. I se riously q ue st io n the c ap acity of these asbestos -free talcs to s at isfy the total market. Also, in some applica t io ns , the asbestos-free talcs are just not a suitable s u b stitute q u a l i t y - w i s e . For example, in c e ramic wall tile (a maj or market for t r em ol it i c talc) the r e. ar e few, if any, asbestos-free talcs that show the same forming and firing properties. Penhorwood fires to a br ow n color due to h i gh . ir o n content. G-l Fires wh ite due to very low iron c o n t e n t . Neverth el e ss , it is a fact that the M o n ta n a talc (asbestos -free) business of both Cyprus Industrial M in er al s and Pfizer is booming, wh il e we are in the doldrums. Quality: Historically, talc mining has been a highgrading o p er at io n w it h s e lective min i ng r e q u ir e d to maintain acceptable qualityibr various uses. This type of selective mining was done successfully for over 25 years at the G ra n t ha m Mine. Proper q u a li t y and uniformity of ore were seldom, if ever, problems and sizeable markets were built on this foundation of quality. The unique high brightness of Cyclo-Fil (95% G.E.) was, in the past, p ro p e rl y m a i n ta i n e d and a good and pro fi t ab le market' d ev eloped for this p r oduct in paper filling. V.'ith the b ri ghtness of current q ua li t y Cyclo-Fil dipping as low as 89%, there is no way we are going to m ain ta in this business. Clays and other fillers at half the price of Cyclo-Fil can and are being used. CRMC-MAD-000560 P. A. M a r t i n s o n Page Three Other quality considerations relating to high acid soluble content and improper grind have caused an erosion of our paper industry business until virtually nothing remains. 4. M a r k e t s : At one time (less than three years ago) sizeable markets for Desertale products existed in paper, paint, plastics, and ceramics. Both DT-51 and DT-57 were the most w i de l y used fillers in 40" talcfilled p olypropylene. We lost this b u siness prior to labeling because of trcmolite content. Many of our paint and paper accounts have been lost for the same reason and labeling has accelerated this loss. Labeling, plus tlie loss of p r op e r quality, has been disasterous. Cera mi c sales of DT-51 have been di f fi cu l t to maintain. High acid soluble and water soluble contents of G-l ore have resulted in casting slip gelation and rheological problems. The high acid soluble content of current q ua l it y G-l and G-2 ore has increased the alum demand, of both Cyciu-Guiu anu Cycio-Fii in paper applications to the point where, even if we had proper brightness, a paper mill could not afford to use our products. I can foresee no markets that can be built or rebuilt under present conditions. 5. N ew T e c h n o l o g y : Froth flotation will reduce the tremolitc content of G-2 ore to less than 1$, but will not remove all of the tremolitc. In such a wet process, acid leaching will increase brightness several points. HIMS could probably also be used to remove even paramagnetic material to improve brightness still further. Newly developed sand or attritor milling procedures can grind down to a m a xi m u m p a rticle size of under 2 microns, but I believe that all of these new techniques arc a waste of time as long as we have to label. Also,-the relatively high mining costs at Warm Springs, plus the absence of adequate water for these wet processing methods makes the development of other sources more attractive. CRMC-MAD-000561 P . A. Mart inson Page Four 6. Penhorvood: Based on detailed testing, vc feel certain that" I'cnTTorwood talc can be developed as a major source lor pitch control and should be directly competitive with Mistron Vapor (Cyprus Industrial Minerals Montana talc). Other markets may be developed for Penhorvood in plastics filling, elastomer reinforcement, and paint. -Although in this latter use, the relatively low brightness of Penhorvood is going to be difficult to overcome. If higher brightness grades could be developed from the same mining area, additional markets would become available. In paint uses, wet color uniformity is a major considera tion and must be maintained with Penhorvood talc or any other extender pigment. Analyses of Penhorvood core samples suggest that this may become a major problem. 7. Other Worldwide Talc Sources: With the worldwide decline in the industrial use of tremolitic or asbestoscontaining talcs, sources for asbestos-free talc will Qitrply nerriTiie move va Inahl e . M a j or sources fur this type of ore exist in France, Italy, Spain, India, Red China and other parts of the world. Generally, all of these deposits are selectively mined. Only Finntalc and Johnson and Johnson are using froth flotation to separate talc products of acceptable quality. We will do the same at Penhorvood, and the industry must move in this direction as deposits amendable to high-grading are depicted. Talc producing areas in California, Nevada, and Montana have been thoroughly--if not systematically and profes sionally explored. It is unlikely that new largescale talc-mining properties could be developed. However, this possibility should be explored--but only for asbestos-free materials. There would appear to be an opportunity for good geological work. CRMC-MAD-000562 A. M a r t i n s o n Page Five Cone]usions and Recommendations a. labeli Hi:, plus a gcncr.il decline in q u a l i t y , ha? caused a disastcrous loss in J-M talc business. Some of this business might be regained in spite of labeling, providing we could re-establish prior high quality standards in both our mining and milling of these products. However, the effects of labeling will always place us in a serious competitive position. The economic viability of such an operation is also highly questionable. b. Until Penhorwood is in operation, we should try to hold onto as much of our existing talc business as possible. Such a holding action will be difficult, expensive, and disheartening, but should be done. Penhorwood will not replace all existing markets for Grantham talc because of darker color and other differences. c. Beyond the development of Penhorwood, J-M should a 1 1 * *o dov^ior). or* a v'or ^dw ioo scs 1o otihoy a5rvjr`T`T' free sources for talc mineral. These will most surely become more valuable with time. It would be unfortunate, indeed, if we were to let our poor performance with Grantham talc interfere with J-M development of other worldwide talc sources under more desirable conditions. CRMC-MAD-000563 CRMC-MAD-000564 I m ; hi * tas m fted by m l B p pattfcipaatt; fc, tona* stick m a m r preskm fr coadder f U anr. cave resohnd. fndaad. teara vaa a whfc m efedre afecfalQatea. a ffiwa pr e( nrwiaii^ io wbkb dhjfcaaaqr far th^pnaea caafair ^3bs ~ T ta t o , bowewer, oae possi apon U d teeaw anserai* m ncd io th OSHA mmm. eeeaagfr aB workshop partkipaan afrecd--tec tea* are aetenl ottcr saiie o ot ateetefor eed (or a precise deteflbteatkxi t riddi ada* ariwwb--broi fltrMft wtcfe h o t duomi cnb are, is faa, asbesto or asbcteform. lo tee ond phvaical bataewistics snttar to teose c ate tnceVepumg pwantfaiion. Uafrtatey of cow e n cit l ateeo oa. HimMant.i moiopst Dr.Ubor Zeta aoaarfthai, Z olai ctHarf far create of ae "laterdisUpIi: ma aboat five vean ago, teere had arver beco ary lanfoope" aooeptsbk lo m earchm io all tt a peteh a arfe; m iaolory. Befte te * tie, adeatfic apberes aow bm stifwic* asbesti latente ia Sbrodi dlicste a i pretty a n te (he d u r a c i ics and cffocn, "H:? neceniry c ' hrrr txduchre dosate of bo ahran a ooivcryd, piadle tanninolocr a rcfdred aodcroood wbatteesrooUetfaesaMa&tbytcnt lime and ap io duna* che otfcsbop. aacb as "asbesioe,* "asbesttfono," "fiber," and la hit dosine reatarte, Dr. C S (SE "tbmcft.** WUh teegrovth of latean la tbe Tbcsapsoa, a auacnlojpst for tbc Vaaderbi batte prabkau related io ateneos and tee Company aad ieprecM*jvc o tee Amene: teeeqwew db-aiuioos aad laaoarch by adrnrmt Mming Conlcreacc, rettane th probi *3 caute from oteerdhdpltaes sodi as biolofy, mediane, by lese tenninototy. "Everybody L.cm- j asd ebemittry, tee toc dbdoctioot mherem io atentos a," be taid, teey don*: k xw wh tee termi as tated by geoLifgtt tw^wx htoxml. h tsa't . . . Let's odi thtnft wtur tiiev art. n. Zolai taid. Tbc eoa^bazy terminle', ite said. 'hi- teev are nou" Tboapton corarmeJ. "Mi -------- bat ed to t fcbe or at-famsdoppy chnracerisa^ --erah mm: be thorouyhl) tenrec:cnrce) bar: don of many mineral *s "asbesti ' or "asbesti* medical mearte which he-- meanL*.; can t ia u rm m tx tirr f CRMC-MAD-000565 `"-so tcrnta, ta sst t e M M M N f t m casai rron raC"** ggg tus&siu m k<t e y a n a a i '^ftxk-s l * m m t t e tamia af jtimtetes a f^rsi m *dsr frfiimMftiiirfiavK'ftEMMV viM "ry m ^ s t t M t - ?3w I p a rtit te te te at te s te en -: te wtestep. tokn Fiter I US. >f5 r^psaed tint rtl 'tea m fch nputtc -*v 'so t a ta r i$ fa j t bv tf bte (dMe n tMe d a r-iassSiaai f i M k n a M tttrtm u MM s:s : IItteeyy cm gtnmatvu ttee 10::1; ' t A'-rc fswsfki te ; nd te y aro aam t e s nrms la VjraAM tecaMka '"H r?sai E^^BhsQSSScuc aot rt o n sa '-r^* Gare m tes tm rtecRte a n n Sac rry~j^?kiB fCpcteoSL >i3tSartr Eo r t t e UJL Cbrtcgksd r~'d {sens <ssm teae posribk artcdttea -/ r7v ) 3 t e ' i S-l tegs&H rtac, 2 } c a f l t e M M h a S - l M r ^ .-gjj as t aMPfcftolt a k t > arr - i ?CCS2lte >"3W*wlMf %*-* 1^1UMltimiTl r Ri* "" RplMMJ ' Jjcrfrr al Tac 1572 ar, sac cricp exposait MwrWA #*, h ' m a ta ifr. 0 fig C I j y . Os Oater 9. !5, O S H A profond *Vj fix -tebtlng of ttrriah tetete rj?<T^i -.aurt. WM w M Mer te r tese ^srrrvs tu a i m hct. b'itookm to ado t e z.'T'.rr d ony cmaad ky t e ip te l tsm ctb i& ~ t& n " taai^ p te came stec cf ti3usltecwrdgttee Mattona atectah. Eros* sM, "V*c prany *B towvte.affmi c?eaawcul wteios 'rixmfh tey y atei v1u:ratifiai s b c.x ^lu wc tel*! bao*, "d "k iuec io proerod wah e r t e en. C m c4 & s beg^msqboom sten steaaot ha:b usbovitento Abrrtel e a a t eotapote of MbnulonD ".i i x ^ t i y -aalao. Abo. tbouf'i to en c ~ Ixltev tel m y Sbrout itteate ua sw er for m# IteuaaiB period/Tta proposa, mwtk a n cppil 80 te <-- tinette iamtty, w&eh ted iaqawt ofoOo a Oemt A sepcnie ibMoa t e w for tecoostrae* t e bamoy t e aot y M m prapossd, or k m feahapoi; te 197S proposai t e sehsd* AaoeaoaeMpact statcaMM oosaanasf tUT- -/#* JO> 3AFCTY A M O HUi.'m CRMC-MAD-000566 CRMC-MAD-000567 Johns-Manville Internal Correspondence fc- jj' p' our August 28, 1974 r-rom: g . L. Swallow F. J. Solon, Jr. Cop'*: W. B. Re1 tze File iCTfiron^) Subject: CONVERSATION WITH HOWARD J. SCHULTE/OSHA, AND RAY McCLURE/OSHA REFERENCE: JOHN STENDER'S LETTER OF AUGUST 6, 1974, TO MR. H. B. VANDERBILT, R.T. VANDERBILT CO., INC. In response to ycur request, I called Howard Schulte and discussed with him the subject letter. He was obviously entirely familiar with it. Mr. Schulte stated that the whole interpretation of the letter hinges upon the definition of "asbestiform" and "non-asbestiform". In response to my question as to what was the current definition of asbettiform, or differentiation between asbestiform and non-asbestiform, he stated that the definition is the same as previously used in conjunc tion with the asbestos regulations, specifically that the aspect ratio be 3--T or greate*-, and that the length be greater than 5 microns. He amplified his definition by saying that if a talc sample were examined under a microscope and more than 5 artifacts/cc were counted, which fit this definition, it would be termed a violation of the OSHA regulations. When I pressed him concerning the difference between artifacts and tremolite, he stated that,"We cannot take tremolite from the standard at this time." He further stated that OSHA technicians have never seen arti facts which fit the above definition which they consider to be non-tremolitic. He stated that NIOSH is currently studying the possibility that there do exist non-tremolitic "slivers" which should be differentiated from the tremolitic fibers and which, because they are (perhaps) not a health hazard, should not be counted when evaluating a talc sample. However, the results of this study are one to two years off. In answer to my query, he stated that the Vanderbilt Company argued the above point, namely that such "slivers" do exist and that it is inac curate and unfair to include them in any fiber counts associated with talc sampling. He went on to say that despite Vanderbilt's arguments, OSHA was not going along with this concept, unless and until the NIOSH study mentioned above confirmed it. As our conversation drew to a close, Mr. Schulte suggested that since I had asked so many detailed and technical questions, it would be well for me to talk to Ray McClure. He told me that he would have Ray call me later today. _____ ___________ CRMC-MAD-000568 MM* > E. M. Fenner/R. P. Carter August 28, 1974 Page Two Later this morning, Ray McClure called and referred to my conversation with Howard Schulte. He started by explaining that the Vanderbilt mining operations are un der the jurisdiction of MESA, not OSHA. Their concern with the OSHA regulations is because of their customers who have read the asbestos regulations and are worried about being cited in their plant operations because of possible tremolitic content in the talc. Mr. McClure said that John Stender's letter of August 6, 1974, was an attempt to give some relief for this situation, but doubted that it did so very effectively. He stated that he was presently urging certain modifications to the standard as presently written. His recommendations are to NIOSH, and must be approved by NIOSH before they can be seriously considered or promulgated. In answer to my question as to what specifically he was recommending, he cautioned me to realize that these were wholly tenta tive and stated that they were: 1. " Revise the aspect ratio in the fiber definition (as associated with talc) from 3:1 to 5:1. He noted that such a recommendation would be contingent upon NIOSH opinion regarding the health aspect. 2. Do not count any fibers whose diameter is greater than 5 microns. 3. Require that the microscopist attempt to make positive identifi cation of fibers as being asbestos particularly by means of observ ing the fiber end configuration. He stated that the Salt Lake City laboratory consists chiefly of OSHA people, now, and that the microscopists already attempt to differen tiate between true tremolitic fibers and other non-fibrous artifacts which would be classified as fibers if judged only by aspect ratio and length. (Please note the discrepancy between this note and Howard Schulte's) Mr. McClure stated that If the above changes are successfully promul gated, the standard will probably require sampling by the "asbestos technique" and by impinger. Whether or not a given station is over TLV will be judged by whichever criterion is stricter. OSHA is also consi dering requiring high volume air samples to permit chemical or minera lgica! analysis of the airborne dust. /6. L. Swallow ' GLS/jmb ''t. U .S. D E P A R T M E N T O F LABOR Occupational Safety and Health Administration WASHINGTON, D.C. 20210 Office of the Assistant Secretary (*> o, August 6. 1974 Hr. H. B. Vanderbilt President. . . R. T. Vanderbilt Company, Inc. 30 Winfield Street Norwalk, Connecticut 06855 f Dear Mr. Vanderbilti Your request for an interpretation of the asbestos standard, section 1910.93a, as it related to tremolite talc has been given deep consideration. The following interpretation of the standard, 1910.93a, is*collectively the opinions of both the Occupational Safety and Health Administration and the National Institute for Occupational Safety and Health. The present asbestos standard is written for the purpose of controlling exposures to the fibrous or asbestiform minerals commonly considered to be asbestos. This is reflected in the established permissible limit for asbestos air contamination to which a worker may be exposed. This is expressed in terms of numbers of fibers in excess of a pre scribed length per unit of volume. The required method of determination or analysis is also expressed as a method for counting fibers. Therefore, nonfibrous or non-asbestiform minerals such as non-asbesti form tremolite are not within the scope of the existing standard. Talc containing only non-asbestiform tremolite is not regulated by the standard 1910.93a. For emphasis, if only talc and non-fibrous tremolite are present, there is no violation of the asbestos standard. Talc containing asbestiform tremolite or ther fibrous asbestos minerals will be regulated by the standard 1910.93a. < 7 W " '''/> Sa i n t L u k i -'S H o s p i t a l //L 'iH .tl.Ji,t Cl**. I 11311 St I AKLR Ol H' LLVAKl ) CiKvti.ANi). O hio f ilOf November 30, 1967 . -- T T Sr; Mr. Clint Burnett, President Johns-Manvillc Corporation 22 E ast F o r t ie t h S t r e e t New York, New York 10016 Dear Clint: The following is with regard to the apprehension voiced by J a m e s D. Snell, Jr-, M . D - , o f the V a n d e r b u i l t U n i v e r s i t y H o s p i t a l with regard to the potential hazard of asbestos fiber in the drinking water from asbestos cement pipe systems. The current state of our knowledge is essentially as follows. In some reports there has be en a suggestion that gastrointestinal cancer may be higher in some groups who have been quite heavily exposed to the inhalation of asbestos fiber as for example the insulation workers and some of the textile plants- It is assumed that the fiber which enters the gastrointestinal tract is that which has been deposited on the mucous surfaces of the nose and trachea and bronchi from whence it is brought up to the back of the throat on a mucous layer and swallowed. Some, of course, ma y bo swallowed with d r i nking w ater of contaminated glasses or from the surface of the teeth or mouth cavity. I do not know of any responsible investigator including Cuyler Hammond who believe that there has been a clear-cut demonstration of a higher incidence o~f ^ d b f H ^fc>_.xr{te_stinai~ c a n c e r in a r e l a t i o n s h i p w i t h a s b e s t o s f i b e r exposure via these routes. ~~ " There has been demonstrated an unusually high incidence of peri toneal mesothelioma (cancer of the surfaces covering the intes tinal tract) in workers exposed to the inhalation of fiber as for example those -?m m i vnd in i n s u l a t i o n w o r k a n d in t e x t i l e m a n u f a c t u r e The same appears to be true in populations which on rirst glance m a y not bo so intimately exposed to the inhalation of fiber as for example some of the natives in certain parts of South Africa who do not actually w o r k in the mines and mills and somo of the people w ho live in parts of the London area whore the handling of asbestos fiber is geographically prominent. That some of these or perhaps all have had a moderately heavy exposuro to the inhalation of a s b e s t o s f i ber scorns l i k e l y b o e n u s o o f e n v i r o n m e n t a l c i r c u m s t a n c e s w i t h w h i c h you are familiar. In a n y event, t h e y can s c a r c e l y bo considered chance or occasional exposures to the fiber- M y p u r p o s e in citing *v,o s p p o i n t s is that there is e v e r y r e a s o n to b e l i e v e CRMC-MAD-000571 M r. C lin t B u rn e tt Novem ber 3 0 , 1967 th a t w h a te ve r c a r c in o g e n ic e f f e c t s a s b e s to s f ib e r may h ave i t i s a dose re la te d one. M ost a s s u r e d ly th e re i s a s y e t no e v id e n c e to the c o n t r a r y . The q u e s t io n w h ic h i s m ost p e r t in e n t now i s w h e th e r o r n o t th e q u a n t it y o f f ib e r t h a t m ig h t be sh e d fro m t r a n s it e p ip e o v e r a p e r io d o f tim e v ;o u ld c o n ta m in a te th e w a te r s u f f i c i e n t l y to m ake i t re a s o n a b le to t h in k t h a t in a lif e t im e o f u se o f w a te r s ' fro m su ch s o u r c e s a p e rs o n m ig h t in g e s t en o u gh f ib e r to c o n c e iv a b ly y be c a r c in o g e n ic . I aske d D r. S p ie l w h eth er he had an y in fo rm a tio n on th e " w e a t h e r in g " o f t r a n s i t e p ip e an d h e in fo rm e d me t h a t a lth o u g h th e y a re m a k in g su ch a s t u d y he h a s no in fo r m a t io n a s y e t . I u n d e rs ta n d fro m o t h e r s o u r c e s t h a t u n d e r som e c ir c u m s t a n c e s th e in n e r s u r fa c e o f t r a n s it e p ip e becom es c o a te d v /ith lim e and th a t th e s u r fa c e im m e d ia te ly in c o n t a c t v /ith th e w a te r flo w in g th ro u g h th e p ip e soon becom es t h a t o f lim e and n o t a s b e s to s cem ent a t a l l . We t h e r e f o r e d o n o t kn o w t h e a c t u a l p o t e n t i a l f o r f i b e r i n t a k e b y w ay o f th e g a s t r o in t e s t i n a l t r a c t th ro u g h th e m e d ia o f in g e s t e d w a t e r . I t h i n k m o st w o u ld s p e c u la t e v / ith me t h a t t h e nu m b er o f f i b e r s w o u ld be v e r y s m a ll an d f a r lo w e r th a n th e num ber o f f ib e r s in h a le d , b ro u g h t b a c k up and sw a llo w e d b y w o rk e rs who p ro c e s s and f a b r ic a t e th e f ib e r and u t i l i z e i t . I f we know th a t ,! t h e w o r k e r s o f t h i s l a t t e r s o r t h a v e n o c l e a r l y d e m o n s t r a t e d in c r e a s e d in c id e n c e o f g a s t r o in t e s t in a l c a n c e r , I w o u ld t h in k th e r i s k o f c a n c e r p r o d u c t io n fro m d r in k in g w a te r' w o u ld be e ve n le s s by a fa c to r o f se v e ra l tho usan d. One o th e r p o in t d e s e r v e s som e m e n tio n . W h ile we b e lie v e th e c a r c in o g e n ic e f f e c t s o f som e k in d s o f a s b e s t o s f ib e r a re d o se r e la t e d , th e re i s a ls o e v id e n c e th a t th e re i s a lo n g la g p e rio d betw een th e d e p o s itio n o f th e a s b e s to s f ib e r and th e u ltim a te d e v e lo p m e n t o f th e tu m o r. T h is m eans t h a t o v e r a sp a n o f m any y e a rs th e im p o rta n t d o se r e la t io n s h ip i s p ro b a b ly o n ly in th e f i r s t p a rt o f a p e rso n ' s l i f e . H ence, any life t im e in g e s tio n is im p o rta n t in te rm s o f xh o se y e a rs p r io r to th e la s t te n o r f if t e e n y e a r s p r e c e d in g th e d e v e lo p m e n t o f th e tu m o r. Some o f t h is l a s t th o u g h t is s p e c u la tiv e and I o ffe r i t o n ly a s a m a tte r to c o n s id e r. I to o k th e l i b e r t y o f c a l l i n g D r . M u rra y C* B ro w n , C h ie f o f the O c c u p a tio n a l H e a lth Pro gram in th e N a tio n a l C e n te r fo r U rban and In d u s t r ia l H e a lth in C in c in n a t i a b o u t t h is m a tte r. I w anted t o le a r n fro m h im w h e th e r o r n o t th e P u b lic H e a lt h S e r v ic e h a d an o f f i c i a l a t t i t u d e t o w a r d s a s b e s t o s c e m e n t p i p o . H o t o l d mo t h a t th e y w ore in r e c e ip t o f a l e t t e r fro m th e sam e D r . S n e ll and a ls o D r . D is t o w is h o f N a s h v i l l e , T e n n o s s c o t o whom a c o p y o f D r . S n e l l ' s l e t t e r t o f i r - o 'w o n c e h a d b o o n s e n t . H e t o l d me t h a t t h e y h a v o c r m c ~ m a d ~, 0 -3- M r. C lin t B u rn o tt November 30. 1967 answ ered both o f th e se le t t e r s s a y in g e s s e n t ia lly th a t the d e p a rtm e n t d o e s n o t h a v e an o f f i c i a l p o s it io n a t t h i s tim e t h a t i t h a s g iv e n i t som e c o n s id e r a t io n , t h a t i t seem ed t o ' th e n tiiG r i s k w as v a r y m uch lo w e r in th e m a tt e r o f w a te r c o n ta m in a tio n th a n in th e know n p ro b le m o f a i r c o n ta m in a tio n and t h a t th e y w o re n o t in a p o s it io n e ve n now to m ake a n o f f i c i a l s ta te m e n t one w ay o r a n o t h e r . He a ls o t o ld me (n o t a s a p a r t o f th e le t t e r to D r. S n e ll) t h a t th e re i s a l i s t o f a c c e p ta b le p ip e and i t i s h is im p re s s io n th a t a s b e s to s cem ent i s on t h a t . I ho p e th e s e com m ents w i l l be o f som e h e lp to y o u . W ith best w is h e s . S in c e re ly yo u rs Copy: K a rl V. L in d e ll D epartm ent CRMC-MAD-000573 >e U U ' ,> .-< f / " > ^ y ^ / u - - ^ s :\ - / ^ 7 / - ' / ^ 4 sr ' ~% L / e x i ^ - Y r t ^ y j - ^ n % . . 'C 't - e s - * '- 'f f - ' - ' - i f !- - "T^ `*-'_-*' -- .......... - 'l.-'i t -^t tly ~ \ J~ M -- T*>*f ****&& **? ^ - * * r /* z22it- e6-cp^i^SZT - * * c u * 4 * % r j r f a - y J " ^ -r jA t ^ -y *f -- (S * r * * - * * * ~ P ''Z-'trfW^&qfa* - e > ? ~ & ~ e jf J 2^ . *f i r' * ', /' l r\ <y / 'f l> ,.J /i c n A / . , / '/ 'o ** f *?- * ?~ C Johns-Manville Internal Correspondence F. H. May, Jr., 5 West Date May 30, 1975 Pau 1 Kotin , M.D., 4 North See end of memo HEALTH, SAFETY AND ENVIRONMENT ACTIVITIES REPORT-- APRIL 1975 Government Affairs 1. A detailed letter was prepared and filed with the Food and Drug Administration which set forth J-M's objections to the recent FDA regulation banning the use of glass fiber filters in the manufacture of parenteral drugs. In addition, a task force has been established under the chairmanship of S. W. Schulmeyer to identify our needs for data on filter media and to take the necessary steps to acquire those data. George Wright and Richard Carter will represent HS&E on the commi ttee. 2. Another meeting was held with Dr. James Peters, National Cancer Institute, to review plans for the joint TIMA/NCI/NIEHS workshop to develop protocols for testing manmade mineral fibers in animals. Requirements for government support were reviewed and some admini strative difficulties in securing funding from the government have been resolved. The conference will be delayed until October 8 to 10 to allow for sufficient notice to conference participants and for preliminary planning. 3. David Mallino and Tom Sliter of the Government Research Corporation met with the HS&E staff to discuss the Toxic Substances Act and Worker's Compensation legislation. In addition, HS&E has been working with the Public Affairs Office on O-M's position with respect to the Helstoski bill (the so-called white lung bill). A meeting with Representatives Helstoski and Fenwick (both N.J.) is under consideration. 4. A meeting was held with Dr. David Rail, NIEHS, and Raymond Shapiro, FDA, to discuss the protocol for the asbestos study. Aspects of the protocol such as design and logistics and preparation of the sample materials were discussed in considerable detail, and our concern with the importance of proper milling and fiber size clearly expressed. 5. Richard Carter, along with Richard Lamar of R&D, met with various officials of R. T. Vanderbilt Company, a J-M talc competitor, to discuss our decision to insert asbestos caution labels on J-M talc and to review the results of our analyses of Vanderbilt talc which we believe con La, i.- s bstantial quantities of asbestos even though Vanderbilt has been certifying to its customers that it does not. C R M C -M A D -0 0 0 5 75 K !!. May, Jr. - 2- May 30, 1975 Medical Programs 1. Discussions were held with Lloyd Monroe of Mining Division concerning preemployment physicals for the Stillwater mining operation. Physical examination reports and x-rays have been reviewed for all present employees and a mechanism has been developed for continuing to review examination reports prior to employment in order to eliminate individuals at risk. 2. An additional meeting was held with Dennis Carruth and H. 0. McElyea concerning the development of the medical program for the Ken Caryl community. The discussion centered on the types of data that will be necessary before projections can be made; we are in the process now of gathering this information in preparation for future meetings of the committee appointed to coordinate planning. 3. The format for programming data on the Executive Physical Examination Program was finished, and the next step will be inputting the data from our files into the system. We expect that this information will be ready for retrieval by the end of May and that the present delay in the Executive Examinations will be resolved. Target date for effective functioning of the new system is the end of June. 4. The format for the Standardized Employee Health form has been developed with Patient Care Systems. This examination form is to be used on a corporate-wide basis and will allow us to computerize medical information on J-M employees for future data retrieval for epidemiological studies. The forms have been ordered and we expect to be able to institute their use at all J-M locations by August. 5. A standardized form for x-rays using the ILO/UICC 1971 classification of the pneumoconioses has been developed and these forms are now in use. Dr. George Wright is currently reviewing x-rays of employees from our Stockton and Denison plants. These two plants were designed with environmental engineering controls from the beginning of their operations, and the x-ray review should ascertain the effectiveness of these controls. 6. Representatives from HS&E, Employee Relations and Arapahoe Mental Health Center met to discuss the second draft of a proposed "troubled" employee program. Some of the previous problems relating to evaluation techniques have been settled, and we expect to be able to contract with the Arapahoe Mental Health Center for counseling services on a one-year trial basis sometime in June. /. Revision of the PVC employee audiovisual information program and of the employee booklet on PVC was completed. Review of the physical examination and laboratory reports on employees has begun. This program is only in its beginning stages; however, thus far no problems have been encountered among our employees. CRMC-MAD-000576 F. H. May, Jr. May 30, 1975 Environmental Activities 1. The first three environmental evaluation visits to plants were completed. This program has involved preliminary meetings with division management personnel, preparation of background information on the status of each plant in the environmental areas and the development of questionnaires for evaluating p l a nt s during v i s i t s . Detail ad reports of the visits to Billerica, Tilton and Nashua were prepared and follow-up meeting with division management to ascertain progress on our recommendations are being planned. Research has begun on the five plants in the Manville complex which are to be evaluated in May. 2. W. B. Reitze visited 0-M plants in Belgium, France, Germany and Italy to assess environmental problems. Meetings will be scheduled in May upon Mr. Reitze's return to discuss the status of these plants with division management. 3. The requirements and implications of Federal oil spill prevention regulations were reviewed with appropriate representatives of all operating divisions within the corporation. 4. HS&E assisted the Environmental Engineering Department in connection with the development of a Solid Wastes Survey, and an evaluation of the wastewater diversion and recycling plans for Manville was completed. In addition, a number of environmental projects at specific plant locations and a number of Appropriation Requests were reviewed for their health, safety and environmental impact; these included projects at Toronto, Penbryn, Savannah, No Agua and Waukegan. Safety 1. David Noyes attended the OSHA Training Institute Course on safety and health training for the construction industry in Chicago and the Colorado Safety Congress held at the Denver Merchandie Mart. Dr. Kotin participated in one of the sessions of the Safety Congress as a panelist. 2. The plant safety contest program was reviewed to improve the use made of the safety data and to develop better means of communicating with employees and management concerning the program. 3. Representatives from Travelers, Marsh McLennan, Insurance Department and HS&E have met to discuss J-M policies and procedures and to clarify our relationship to Travelers and Marsh McLennan. In addition, at the request of the Insurance Department, an article geared to insurance company risk managers outlining J-M efforts in controlling asbestos health problems was prepared for Insurance Magazine. Communi cati ons1 1. A speciu'. v'ep)rt analyzing recent studies of VCM ingestion was pre pared for distribution to district managers and sales representatives Tor PVC pipe. CRMC-MAD-00057^ F. li. May, Jr. -4- May 30, 1975 2. A bulletin was prepared for the Fiber Jlass Division in response to recent media reports on the relationship of fiber glass and health. In this same area, Dr. Gerald Chase met with Dr. Jon Konzen, OwensCorning, and Mr. Clifford Sheckler, TIMA consultant, to review and analyze the data from the paper on potential fine fiber exposure which David gayliss presented at the New York Academy of Sciences and which precipitated most of the reports in the media. Toxieology and Epidemiological Activities 1. A presentation was made to the Standards Committee of the American Water Works Association concerning J-M's PVC pipe migration studies, relevant animal and human data on exposure to vinyl chloride and government agency actions on vinyl chloride. This presentation was made to persuade the American Water Works Association to approve the use of PVC pipe to convey potable water. A determination by the American Water Works Association is expected sometime in May. 2. A meeting was organized at the Fiber Glass Research and Development Center in Waterville to determine the extent of our knowledge concerning thermal degradation and decomposition products from the binders used with our fiber glass products. 3. Thirty-four written and twelve verbal inquiries relating to the toxicology and safe handling of J-M products were answered. 4. A Datapoint 2200 was ordered with the approval of Data Processing. This equipment will provide us with the capability for epidemiological and statistical analysis of research both in-house and outside J-M. In the interim a commitment for time on the Datapoint at Data Processing has been secured so that the groundwork for the HS&E Information System can continue. 5. Past and potential studies of J-M employees were discussed at a meeting with Dr. Philip Enterline at the University of Pittsburgh and the work of the Environmental Sciences Laboratory was reviewed with Dr. William Nicholson at the Mount Sinai Medical Center. c c : T . R. S m ith II. J . W h ite J . A. C o n s ig li E. P. Burke J . F . M atousek F . L . Page A. B. M Archant J . S. A u try 00578 CONFIDENTIAL - FOR J-M INTERNAL USE ONLY fil 3 v 'i U. *#- v' L i r''.~ I f vvJ5 Or *' frr i,'c r* nc P. A. M m -tins on - 21V Ivi!p March 20 , 197 5 Lama r 2W J. M. F l e t c h e r - 2S 11. R. K e efe - 21V J. M. S h a r r a t t - 2S AN ASSESSMENT OF THE J-M POSITION WITH TALC T h r e e years since J - M 's entry into the acquisition of Desert Minerals for an appraisal of our position. broken down into eight sections as the talc b u s i n e s s w i t h C o m p a n y is time e n o u g h This a s s e s s m e n t is follows: 1. T he E f f e c t s of L a b e l i n g : Our p o s i t i o n h e r e has b e e n The only acceptable action J-M could take. According to the definitions that are a part of the law, our Cali f o r n i a talc products all contain asbestos in the form of tremolite. No play on words will change this fact. Or r in n ! 1v T f 1 f* + h n + i . rr r n u l H T T i n i n t n i n the uniquely high brightness and relatively low acid soluble content of G-l and G-2 talc ores, we could h o l d onto most of the critical markets, in spite of labeling. I now seriously doubt our ability to do this. The " t a l c - a s b e s t o s " p r o b l e m is q u i t e d i f f e r e n t from the " a s b e s t o s - a s b e s t o s " problem. In many applications for asbestos, there are no acceptable substitutes. With our asbestos-containing talc, there are numerous possibilities for substitution: (a) N o n - a s b e s t o s c o n t a i n i n g talcs f r o m b o t h P f i z e r and Cyprus from Montana sources and (b) O t h e r e x t e n d e r p i g m e n t s such calcium carbonate (in paints, for paper filling uses) . as k a o l i n and example, and in We see this type of substitution being long-established markets for Dcscrtalc e v a p o r a t i n g in the process. made and products CRMC-MAD-000579 P, A. 'Martinson Page Two The R. T. V a n d e r b i l t P o s i t i o n : T h e i r p o s i t i o n w i t h r e s p e ct t.o l a b e l i n g m u s t be d e l i b e r a t e l y p e r f i d i o u s ; they cannot be this misinformed. Slim Thompson, their technical director, has a Ph.D. in mineralogy. At the moment, V a n d e r b i l t is m i s l e a d i n g t h eir c u s t o m e r s and c o n f u s i n g ours w i t h their dec i s i o n not to label. Ultimately, the truth will out, and they will be forced to label. P f i z e r ' s p o s i t i o n is the same w i t h t h e i r C a l i f o r n i a talcs. With all asbestos-containing talcs labeled, far greater value and emphasis in the market will be applied to asbestos -free talcs. I seriously q u e s t ion the c a p a c i t y of these asbestos -free talcs to satisfy the total market. Also, in some applications, the asbestos-free talcs are just not a suitable s u b stitute quality-wise. For example, in ceramic wall tile (a m a j o r m a r k e t for t r e m o l i t i c talc) there are few, if any, asbestos-free talcs that show the same forming and firing properties. Penhorwood fires to a b r o w n c o l o r due to h i g h ,iron c ontent. G-l Fires w h i t e due to v e r y low ivon content. N e v e r t h e l e s s , it is a fact that the M o n t a n a talc (asbestos-free) business of both Cyprus Industrial M i n e r a l s and P f i z e r is booming, w h i l e we are in the doldrums. Quality: Historically, talc mining has been a highgrade, ng o p e r a t i o n w i t h s e l e c t i v e m i n i n g r e q u i r e d to m a i n t a i n a c c e p t a b l e q u a l i t y fcr v a r i o u s uses. T h i s type of selective mining was done successfully for over 25 years at the G r a n t h a m Mine. P r o p e r q u a l i t y and uniformity of ore were seldom, if ever, problems and sizeable markets were built on this foundation of quality. The unique high brightness of Cyclo-Fil (95% G.E.) was, in the past, p r o p e r l y m a i n t a i n e d and a g o o d and profitable market developed for this product in paper filling. With the brightness of current quality C y c l o - F i l d i p p i n g as low as 895, there is no w a y we are going to m a i n t a i n this business. Clays and o t h e r fillers at hal f the price of Cyclo-Fil can and arc being used. -0005&0 -MAP >P. A. M a r t i n s o n . * - , Page Three Otlier q u a l i t y c o n s i d e r a t i o n s r e l a t i n g to h i g h a c i d soluble c o n t e n t fttra i m p r o p e r g r i n d have c a u s e d an erosion of^otfr p aper i ndustry b usiness until v i r t u a l l y nothing remains. 4. Ma r k et s : At one time (less than three y e ars ago) iTzeaBTe markets for Desertalc products existed in paper, paint, plastics, and ceramics. Both DT-51 and DT-57 we r e the most w i d e l y used fillers in 401 talcfilled pol y p r o p y l e n e . We lost this b u s i n e s s p r i o r to labeling because of tremolite content. Many of our paint and paper accounts have been lost for the same reason and labeling has accelerated this loss. Labeling, plus the loss of proper quality, has been disasterous. Ceramic sales of DT-51 have been difficult to maintain. High acid soluble and water soluble contents of G-l ore have resulted in casting slip gelation and rheological problems. The high acid soluble content of current quality G-l and G-2 ore has increased the alum demand of both Cyciu-Sorb and Cyclo-Fil in paper applications to the p o int where, even if we had pro p e r brightness, a paper mill could not afford to use our products. I can foresee no markets that can be built or rebuilt under present conditions. 5. N e w T e c h n o l o g y : F r o t h f l o t a t i o n w i l l r e d u c e the tremolite content of G-2 ore to less than 1%, but will not remove all of the tremolite. In such a w e t process, acid leaching will increase brightness several points. HIMS could probably also be used to remove even paramagnetic material to improve brightness still further. Newly developed sand or attritor milling procedures can grind down to a maximum particle size of under 2 microns, but I believe that all of these new techniques are a waste of time as long as we have to label. Also, the relatively high mining costs at Warm Springs, plus the absence of adequate water for these wet processing methods makes the development of other sources more attractive. CRMC-MAD-000581 P. A. Ma rtinson Page Pour 6. P e n h o r w o o d : B a s e d on d e t a i l e d testing, we feel c e r t a i n that P e n h o r w o o d talc can be d e v e l o p e d as a m a j o r source for pitch control and should be directly competitive with Mistron Vapor (Cyprus Industrial Minerals Montana talc). Other markets may be developed for P e n h o r w o o d in p l a s t i c s fil l i n g , e l a s t o m e r r e i n f o r c e m e n t , and paint. A l t h o u g h in this latter use, the relatively low b r i g h t n e s s of P e n h o r w o o d is g o ing to be d i f f i c u l t to overcome. If h i gher brigheness grades could be developed from the same mining area, additional markets would become available. in p a i n t u s e s , wet colui uniformity is a m a j o r c o n s i d e r a tion and must be maintained with Penhorwood talc or any other extender pigment. Analyses of Penhorwood core samples suggest that this may become a major problem. 7. O t h e r W o r l d w i d e T a l c S o u r c e s : W i t h the w o r l d w i d e decline in the industri a l ' u s e of t r emolitic or asbestos- containing talcs, sources for asbe s t o s - f r e e talc will surely become more valuable Majui sources fur Luis type of ore exist in France Italy, Spain, India, Red China and other parts o the world. Generally, all of these deposits are s lectively mined. Only Finntalc and Johnson and Johnson are using froth flotation to separate talc products of acceptable quality. We will do the same at Penhorwood, and the industry must move in this direction as deposits amendable to high-grading are depleted. Talc prod u c i n g areas in California, Nevada, and Montana have been thoroughly--i not systematically and profes s i o n a l l y e x p lored. It is u n l i k e l y that n e w largescale talc-mining properties could be developed. However, this possibility should be explored--but only for a s b e s t o s - f r e e materials. There w o u l d appear to be an opportunity for good geological work. CRMC'MAD-0005 82 P. A. M a r t i n s o n Page Five Conclusions and Recommendations a. Lab e l i n g , p lus a g e n e r a l d e c l i n e in quality, has caused a disasterous loss in J - M talc business. Some of this business might be regained in spite of l a b eling, p r o v i d i n g we c o u l d 'r e - e s t a b l i s h prior high quality standards in both our mini n g and milling of these products. However, the effects of labeling will always place us in a serious competitive position. The economic viability of s uch an o p e r a t i o n is a lso h i g h l y q u e s t i o n a b l e . b. U n til P e n h o r w o o d is in o p e r a t i o n , we s h o u l d try to hold onto as mu c h of our exi s t i n g talc b u s i n e s s as p o s s i b l e . Such a h o l d i n g a c t i o n will be difficult, expensive, and disheartening, but should be done. Penhorwood will not replace all existing markets for Grantham talc because of darker color and other differences. c. B e y o n d the d e v e l o p m e n t of P e n h o r w o o d , J - M s h o u l d a t t e m p t to develop, or. a ' w o r l d w i d e scale, e t h e r a s b e s t o s free sources for talc mineral. These will most surely become more valuable with time. It w o u l d b e u n f o r t u n a t e , indeed, if w e w e r e to let our poor performance with Grantham talc interfere with J-M development of other worldwide talc sources under more desirable conditions. CRMC-MAD-000583 February 71, 1975 I r v i n g J . S e l i k o f f , M .D . Institute of Environmental Medicine Mount Sinai School of Medicine Fifth Avenue and 100th street `Jew York, New YORk 10"2 near Irv: It was good to talk with you last week, and I can readily appreciate the barrage of calls you received from Toronto-- union, Mr. Lewie the M.P.P., and community groups. This situation is clearly relevant to the philosophy we discussed and agreed upon during your visit here-- that our energies should be directed to correcting gross plant problems. The tape of the press conference is being transcribed and I will forward a copy to you along with whatever supplemental information we have available. As I indicated to you when we met in Chicago, we can develop a mechanism for reviewing the films referred to in Goldfield's article "Dust Control Techniques in the Asbestos Industry." I am glad you agree that this is a good time to initiate some way of reviewing each other's films for mutual education and discussion, etc. Just for your interest I am enclosing a copy of an internal memo on VCM sign regulations. Please destroy it when you have read it. I think this demonstrates the seriousness of our concern for health and safety--even in minor details. T havr- learned that Vanderbilt talc cannot be purchased ir. 'Jcv York city but is available in Philadelphia from 4 fedlowino concern: c. A. Wagner Company d4gy North *th Street P h ila d e lp h ia , P e n n s y lv a n ia 71 5/01,''- HA no _ CRMC-MAD-000584 Dr. Selikoff -2- February 21, 19?5 Sine suppliers..'Ate a#are of what is happening and word will probably get back to Vanderbilt, I think it would bevise to have someone pick up the talc directly or else have it shipped to someplace other than Mount Sinai. As 1 mentioned, I am still pursuing the question of A/c pipe in relation to the duration of its use in selected locations, populations exposed, and the presence of hard or soft waiter. Looking forward to seeing you at the Chicago meeting. Cordially, E n c lo su re FCC: Dr. V?right M r. S o lo n CRMC-MAD-0005 85 . SpcuL sc u js 'HnJUL 14> no placx- t 4 ij u J Ou Scita ^ A jA .C p \ .ht. *cft C U J cju U V a v % d U ' a*~ A s lc x J t t 'fZ^C- lLdUj2|5lc4^t ^AITTVV 0 A U j A Q y * t / l 'Q -O H H S S ist. (*m'S + aju Cp u *7 - o i p o o Spc& S o ^ s i . S t ^ h > 4 t h flx x hivw - hccot2t scrryurrui- n. S o n m ^ j p ^ ^ (jfiuA. 2t u p4o YV>/\ & i c u , f <k s SUfip2uU.% asut " h t p " 4 c ukost 0/ h u p j^ t ^ u A ^ io *b u J& \ d L u h Z JL s Q n o b a Jo b n cjai b & c J c , 4 o V ^ M sd y M . CRMC-MAD-000586 r i 4lv"jn R. P . Carter To w . A . C o o p e r W. B . R e it z e From: E . M. F e n n e r F. 0. So' S . S p e il V?. C . S t r e i t Date: 5-IELlO Copies File & C Subject. MEETING - 9 : 0 0 A . M . , AUGUST 6 , 1 9 7 4 D E F I N I T I O N OF AN ASBESTOS F I B E R - OSHA STANDARD th e re h as been c o n s id e ra b le d is c u s s io n c o n c e rn in g th e d e f in it io n o f an a sb e sto s f ib e r as p r e s e n tly used by OSHA, p a r t ic u la r ly in re g a rd to th e p re s c rib e d asp e ct r a tio o f 3 to 1. ASTM h a s o r g a n iz e d C o m m itte e E - 3 4 , "C o m m itte e on O c c u p a t io n a l H e a lth and S a fe ty A sp e c ts o f M a t e r ia ls , P h y s ic a l and B io lo g ic a l A g e n ts " ; T h e re a re a num ber o f su b co m m itte e s and t a s k g ro u p s w it h in t h is co m m itte e . One o f th e s e ta s k g ro u p s i s co n ce rn e d w ith " n a t u r a lly o c c u r r in g in o r g a n ic fib e r s " . T h is ta s k gro u p is p r e s e n tly engaged in w r it in g fo r s u b m itta l to OSHA th ro u g h n o rm a l ASTM c h a n n e ls a r e v is e d s ta n d a rd f o r o c c u p a tio n a l e x p o su re to a s b e s to s f ib e r s . One o f th e im p o rta n t s e c t io n s b e in g w r it t e n b y t h is t a s k g ro u p i s co n ce rn e d w ith th e d e f in it io n o f a s b e s to s f ib e r . The n e x t m e e tin g o f th e T a sk G roup on N a t u r a lly O c c u r r in g In o r g a n ic F ib e r s t a k e s p la c e on A u g u s t 14 and 14 in C a n a d a . I w o u ld v e r y much l i k e t o be a b le to s u b m it t o th e g ro u p a Jo h n s -M a n v ille d e f in it io n o f an a sb e sto s f ib e r . I n o r d e r t o a c c o m p lis h t h i s , I am r e q u e s t i n g t h a t y o u a t t e n d a m e e tin g to d is c u s s th e s u b je c t a t 9 : 0 0 A .M . on T u e s d a y , A u g u st 6 , in o u r C o n fe re n ce Room, 4 N o rth . F o r b a ck g ro u n d in fo rm a tio n p r io r to th e m e e tin g , I e n c lo s e the fo llo w in g : * (1 ) A l e t t e r to F. J . S o lo n , J r . , d e s c r ib in g ASTM C o m m itte e E - 3 4 . (2) A d e f in it io n fo r a sb e sto s f ib e r as p re p a re d by a s u b s e c tio n o f the ta s k gro u p fo r a ffir m a t iv e o r n e g a tiv e b a llo t t in g by th e g ro u p m em bers. CRMC-MAD-000581 R . P . C a r t e r , .e t a l Page 2 J u ly 31, 1974 (3) A s e r ie s o f d e f in it io n s o f a sb e sto s a s p r e v io u s ly su b m itte d b y th e fc M o w in g p e o p le : A . A . H o dgso n , Cape A sb e sto s F ib r e s L im ite d G. G agnon, La ke A sb e sto s o f Q uebec L im ite d M. G rim a rd , M . D . , D e p a rtm e n t o f N a t io n a l H e a lt h & W e lfa re o f C an ad a R . B . S t e e le , A sb e sto s C o rp o ra tio n L im ite d A . A . H a rv e y , R. T . V a n d e rb ilt Company (4) A d e f in it io n o f an a s b e s to s f ib e r as p re p a re d by D r . S t e v e n H o lm e s o f th e A s b e s t o s is R e s e a r c h C o u n c il (5 ) The ASTM p r e s e n t d e f in it io n o f a s b e s to s f ib e r . (6 ) & (6A ) Two anonym ous d e f in it io n s o f a s b e s t o s . (7) An anonym ous d e f in it io n o f n a t u r a lly o c c u r r in g in o rg a n ic fib e r s . (R) A r n n v o f t h e o r i g i n s ] n r o n n c a l f o r t h e fo T -m a tin o o f th e T a sk G roup on N a t u r a lly In o r g a n ic F ib e r s . (9 ) A l i s t i n g o f a c t iv e m em bers o f th e t a s k g ro u p and a l l o th e rs on th e m a ilin g l i s t fo r m a te r ia l. E . M. F e n n e r 4 * CRMC-MAD-000588 Attachment 3 SUPPLEMENTAL LISTING OF DEFINITIONS APPENDIX 9 Document No. 11 19 April 1974 This listing is a supplement to Document No. 5 published as Appendix 6 of the minutes of the second meeting of the Task Group on Naturally Occuring Inorganic Fibers of AS1M Committee E-34* 1. Definitions submitted by Mr. A. A. Hodgson, Cape Asbestos Fibres Limited, 24 Jan 1974- fibres Fibres are defined as being of a length greater than 5ptn and having a length/breath ratio of at least 3:1. There is no upper limit for the length of the fibres, but a maximum diameter of 3>jra is defined. Airborne asbestos dust concentrations are expressed in fibers per milliliter of air (f/ml). (taken from the Asbestosis Research Council's Technical Note 1, paragraph 2.1) asbestos - acicular silicate mineral, with a structure based on silicon oxygen tetrahedra, composed of crystals in a predominantly parallel orientation, and distinguished by its ability to split indefinitely from its macro form to individual flexible fibrils having minimum length to breath ratio of 3 to 1 and cross sectional dimensions approaching 0.01 nm. 2. Definitions submitted by Mr. G. Gagnon, Lake Asbestos of Quebec Limited, 28 Jan 1974: fibre - any material in a form such that it has a minimum ratio of length to average maximum transverse dimensions of 10 to 1. asbestos fibre - silicate mineral, with a structure based upon silicon oxygen tetrahedra, that fits the definition of a fibre and is composed of single crystals in predominantly parallel orientation. Common usage also designates a collectivity of asbestos fibres as asbestos fibres. 3. Definitions submitted by Dr. M. Grimard, Chief, Hea'th Effects Division, Environmental Health Directorate, Department of National Health and Welfare of Canada, fibre - (definition as applied to minerals): any material which by micros copy presents the following optical characteristics: a filiform or bundle of filiform bodies having a length to diameter ratio of at least 3:1 asbestos fiber - acicular silicate mineral, with a structure based upon silicon-oxygen tetrahedra, that fits the definition of a fiber, and is composed of single crystals in predominantly parallel orientation. C R M C -M A D -0 0 0 5 89 V. -2 - 4. Definitions submitted by Mr. A. M. Harvey, Manager, Legal and Products Application, R. T. Vanderbilt Company, Inc., 4. Jan 1974: mineral fiber - any form of mineral characterized by properties of flexibility and length to width ratio of at least 100, and composed of definite crystal unit cells oriented with respect to a specific axis. asbestos - is a generic term for a number of hydrated silicate minerals that, when crushed or processed, separate into flexible fibers made up of fibrils. These minerals include chryaotile, crocidolite, amoeite, anthophyilite asbestos, tremolite asbestos and actinolite asbestos. 5. Definitions submitted by Mr. R. B. Steele, Laboratory Services Engineer, Product Research and Development Department, Asbestos Corporation Limited, 5 March 1974: Fibril - Is a polymeric form of solid whose component repeating sub-units extend along a single major axis, and which can not be subdivided along this longitudinal axis without destroying the integrity of the structure. Fiber - Is a bundle "of fibrils in parallel alignment, the composite possessing a maximum diameter of 100 microns, and a minimum aspect ratio of 20. Asbestos - Is a generic term for a number of silicate minerals, the morphology of whose component particles fits the aeimition oi a xiber. Asbestos Fiber - Is a fiber belonging to one of the six types of asbestos minerals: crysotile, crocidolite, amosite, anthophyilite asbestos, tremolite asbestos, and actinolite asbestos. 6. Definitions submitted by Mr. A. A. Harvey, Manager, Legal and Products Application, R. T. Vanderbilt Company, Inc,, 30 Jan 1974; Definitions taken from pages 26, 27 174 and 175 of the 1973 ASTM Glossary: Refer to page 3. 7. Refer to Appendix 5 and 6 of the minutes of the third meeting of the Task Group on Naturally Occuring Inorganic Fibers. 4 CRMC-MAD-000590 _ ,0|; * 1.) .y I iT'nric pi! . i of ii/Ort. Acr T('Mi|H'l:uy H xrm p 111r JI K i i i . t i ' i . i t y 1, JU 'iV , n.lrd l/> l.iU.1,10 Motor / u u iiin rij No. 212. L. 02-M9, (11 P in t. 1119 (IS U flc ^ n tlo n o f m i'li'- T 'ly a t 43 The Fk^Tfinry has found tim i Ud* n c 'd exist.*, r.s a rr. ult of n r i . ' m ; I dint v l iT c o n -!-t ir i- o f t>ri-lunr.-.l (Pri.u. ht I r :tt. O rUU.i r H'77 u n til A r tll 1*17*: r j . n e u v e r a in f a ll Ju n e b, 11174: b i l l torm a .May 31 end Ju n e 1.7, 1374; r n d cxrcr.-.Svc nwain'1icdndsettJohulionsreeu,r'!o.1Iihitorbtubu-'vhnrncJlctunnlroeyr 3lh.0ar..u*,1r0-h7fnr3-.cl"r- Ion Ju ly 30,3374. J aiics C. G r u c o s r . Administrator. loans, nu'iii.ir.t lo mo r f w i w r : the Consol id a ted 3 arm and K u ra l Brvulopm c n l Act. as amended by 1' ul). L. 93-237, tiuci Die prc-vi: ions of 7 C iT t 3873 3(b) 1.74*17752 Filed 8.5,'.4,:4 ml inciuiim e the u commendation of Gov ernor Doipn h it,to e Unit such dcsigna- R TM EN T OF A C TIC U LTU nE t u n be made. Applications for Emergency loans must nmodity Exchange Authority be received by this D epartm en t i o lr.tcr ERS IN CHICAGO LtVC CATTLE FUTUkEo of Names and Transactions th an September 22. 1974. lo r pit:-.deal losses r.nd A p ril 22. 1575. fo r prccucilon losses, except th a t qualified borrowers who receive in itia l Joans pursuant to lids eretary of Agriculture In rei a letter from the Senate C n n , A griculture and Kort-.try st)b-- th e corr.n:ttee In fo rm atio n disae names and adurcsTs of nil , live cat*.: fu tu re , on l i e C h lntile Exchange uur.ng si.o ricsianatioti m ay be eligible fo r subse quent loans. Ir .e urgency of the need lo r )oar-> ta m e rie-ignate-o arcs ir.alios i t impraxuc.able end contrary to the public interest to rive advance notice oi proposed rule moiling and Invite public participation. 1, 1974 to June 15. 1571. -Kith . whom the S tcrcu iry rues in together trim cl_;a c c r .c c m : transactions and .positions of .tracer. icnnntion was submitted In ac- Done at Washington, D .C , this 30th day of July, 1974. F rank B. E llio tt, Adm inistrator, Farm ers H om e Adm inistration. Itr tth section 8 of trie Ccmmod- |FR Doc.74-17735 Filed 6-2-74:8:45 ami aceA ct (7 U.S.C. 12-1) widen Secretary upr.n request of itte e oi ciir.c r 11once of Conjsg w ith in m e score of its ju ris - DE?/-RT?.'.EKT Or HEALTH. EDUCATION,' AND WELFARE iu m is h and made public tha Center for Disease Control ltd addresses of such traders. ,10). ln fo rm a: ion concerning transactions. The m aterial Kifovered there tm d err in r r - Ettus (ho.duag a position of I..* Sr m ore in any one live ca ttle COAL MINE HEALTH Asbestos Errcsurc in Surface Cc-al V rie s ?.n i Surface V'ork A reas of Ur.Ue rf round Mines; Findings of Feet Section 101 <g) of th e Federal C a rl Muse H e alth and Safety A ct of 19C3 <?C U.S.C. E lli? ) ) . hereinafter referred to w ill be m ade available fo r as the "A ct," provides, in p art, m a t | n d copying to anyone upon le Commodity Exchange A u- ln Wr-ahing-ion. D.c. or Its i In Chicago. In accordance partraect of Agriculture fee Ipies of th e m a teria l w in be a charge of 10 cents fo r leach page. 131. 1974. w ith in C3 c.ays a fte r completion of any public hearing on proposed m an d ato ry health or safety standards, the Sotret.ory who held the hearing shall mr.ite findings of fa c t which shall pe public. B ackground Proposed amendments to m andatory h ealtn standards for surface wort: areas of underground coal mines and surlnr.e coal mines (30 c m P art 71) were devel A tu r C. CALcwrtt. A dm in istra to r, iffy E z c h a n y c AiChrr-iijr. -17739 Filed B-2-7i.B:4t am] oped by the National Institu te for Oc cupational Safety and Health pursuant to section 301 o' the A ct and transm itted to the Secretary of the In te rio r fo r pub lication in accordance w ith the Act. The Home Administration amendments were published under a no tice of proposed rule-m alting on Novem itgiiatloa No. AOCO] TEXAS of Emergency Areas ber 7. 1972 (37 'FH 23G43) ar.d interested persons were allordc-d a per.od of 45 clays w ith in which to subm it w ritte n com ments, suggestions, and objections and ary o f A n rlcu lture has to request a public hearing. O n A p ril 10, general need for cgricul- 1974. the Secretary of the In terio r, in sts In the follow ing county accordance w ith section 1 0 1 (f) of the A ct, published ft notice (39 F i t 13003). .v <um? unit n.vn UTK 10 tilt* '<to* fx v iil tiuuidjeoty lu n lili (laiid n n l fur nr.i )ij>;i tourd er.|vr ure to lu b c.li s :.L:it- ):nr ;: iuimiikJ*. iur .m li liiii i t i e r s iind d ia l u iM.uhr iK unnv I i.m I l ::>'ii ri'iim '-b il. l u l l o v im- r.u> n n o i l 1c. t u e l J '.p a r i m i n t of llm illli. l.rlicntt'*:i. and W elfare ptib- ltsh''d a nutlre livin'* a tlm * rrvl p!a*e oi I ne piJilic h e n riiir to In. held for the t o ; ri:rvi'i. i i let .m l evidence oi. th" [iroiU'C aL-bcslOi i.ancninl (JD I K IGO 1 3 ) . H carino T!io hearing was held on June 5,1074. a t tr.e Lh nartraent of H e alth , Education, and Welfare's P arklaw :i Bulidlng a t UoeV'.viilc. M nrylana. Presentations were made by the following o:'.'ardoatlons: Bitum inous Cual Opem tor.,' Association, H. T . Vonacrsilt Company, .Asbestos I n form ation Aisc-ciaticn, U m icd M in e Worten of America and the Industrial U ih o a Departm ent of / wFJj-C IO . A ve r batim transcript of the proceeding Is available fo r public inspection a t Lho Natlonai Institute for Occupational Safety and Health. Par,: B uilding. P-ootn 3 -3 2 .5CC0 Fishers Dane, r.ocliviUe, M a r y land. P e t t in c s O n the basis of the evidence presented a t tine hearing pad on eth er In fo rm atio n arsihU.-!? to the D epartm ent, the D irecto r of the National Institute for Occupa tio n al Safety End H e a lth , pursuant to au th o rity delegated from the Secretory nr.d the Asristant Secretary fo r H ealth (33 F K 1 1 1 5 ;), finds th a t: 1. There- Is a causal relationship be tween occupational tr.i'osure to airborne asoestoj' fiscrs and the development of disease. 2. Asbestes Is infrequently used In s 'trfre e coal m a ir .' cpe.'atlor.s and rarely, if ever, used in surface operations of u n cergiound coal mines. 3. Thc-re is medical erider.ee which in dicates th e : even ir.irco uent exposure to airborne asucstos can cause disease. A W hen asbestos Is used In cool m in ing c-poralio.-is, lechnoicgy exists fo r m aintain::;t the 6-hour average a lrborr.c concentration of asb io . os dust to w h trh m rie rs are exposed a t or below two Egars (greater th an 5 microtis in lengtn) per cubic centim eter of r i r but not to exceed 10 Ebers per cubic c e n ti m eter more th an one hour of each 8hour day. 5. A stand ard requiring coal tnino operators to maintain the 8-hour average airborne ccr.ccr.tn.tion of asbestos dust to wh.ich m iners are exposed a t or bciow two Ebers icreuter tlirm 5 microns In len gth i per cubic rtr.tim c te r of a ir but n o t to exceed 10 fibers per cubic ce n ti;m :e r c irri- th an or.e hour of each B-hour c.ay. is t.eresr.r.r;- fo rth c pro'.ectlr.u of lUo ana tne prevention of occupational dis eases of miners. D ated : J u ly 31. 1974. M arcus M . K r.r, M .D., D irector, S'etionai In stitute fo r Occupational Sa fety and H ealth. |F It Doc.74-17872 F3 fd B-S-74;8:4 5 im ] FEDERAI REGISTER. VOL 39, NO. 151--MONDAT, AUGJJT S, t 7 4 u l CRMC-MAD-000591 IP^T' " J A t A C C c F r u r r- u is it 4 Nr Kr F: Nc N> K< Fc Oi OI Or 3r: F_' Sot Ec Te* ToUt- Vec Tlr Wt. Ur 'c. x* u.s. d e p a r t m e n t o f l a b o r Occupational Safety and Health Administration WASHINGTON, D.C. 20210 Office of the Assistant Secretary August 6, 1974 Mr. H. B. Vanderbilt .President. . . . . . R. T. Vanderbilt Company, Inc. 30 Winfield Street ' Norwalk, Connecticut 06855 t Bear Mr. Vanderbilt: Your request for an interpretation of the asbestos standard, section 1910.93a, as it related to tremolite talc has been given deep consideration. The following interpretation of the standard, 1910.93a, is'collectively the opinions of both the Occupational Safety and Health Administration and the National Institute for Occupational Safety and Health. The present asbestos standard is written for the purpose of controlling exposures to the fibrous or asbestiform minerals commonly considered to be asbestos. This is reflected in the established permissible limit for asbestos air contamination to which a worker may be exposed. This is expressed in terms of numbers of fibers in excess of a pre scribed length per unit of volume. The required method of determination or analysis is also expressed as a method for counting fibers. Therefore, nonfibrous or non-asbestiform minerals such as non-asbestiform tremolite are not within the scope of the existing standard. Talc . containing only non-asbestiform tremolite is not regulated by the standard 1910.93a. For emphasis, if only talc and non-fibrous tremolite are present, there is no violation of the asbestos standard. Talc containing asbestiform tremolite or other fibrous asbestos minerals will be regulated by the standard 1910.93a. CRMC-MAD-000592 E . M. Fenner - 4N S . S p s i l - RtrD January' 15, 1974 T A S K GROUP ON NATURALLY OCCURRING INORGANIC FIBERS ASTM COMMITTEE S-34 Your note o f January 11, 1974 You are correct that th is is the present ASTM d e fin itio n . Attached is a copy o f the page in the ASTM booh giving these d e fin itio n s. As a matter o f fa c t , the fiber defi nition is the one that X suggested that Vanderbilt try to get accepted in th e ir proposal to the FDA/Bureau o f Mines. As a matter o f information, the d efin itio n o f asbestos fiber is a good commercial d e fin itio n , but could lead to serious problem o f interpretation. For example, i f a microscop1st looks at a t a lc sample and attempts to "count* tremolite fibers what ha is counting normally is individual cr y sta ls . The tremolite "fib e r s" are not "composed o f sin gle crystals in predominantly p ara llel orientation"; there fore, these tremolite p a rticles would not be classed as asbestos fib er under the proposed d e fin itio n . Under the proposed d e fin itio n I doubt whether we could even c la s s ify many o f the cro cid o llte p articles in the UICC sam ple as asbestos fib e r . F in a lly , i f we were to look at a we11-dispersed fie ld o f chrysotile f i b r i l s , obviously each f ib r il would not be an asbestos fiber because i t is one single crystal but not an assemblage o f crystals in predo minantly parallel orientation. While the intent o f th is defin ition is excellent in that under i t much o f the matter, for example in Duluth water, might not be classed as asbestos fiber because i t comes from the cleavage o f a rock during grinding, the microscopist examining the sample would be put to a d i f f i c u l t task under some circumstances to determine whether the individual cry sta ls th at he sees in the microscope fie ld were produced by breaking up a b a sica lly massive material or whether they came from separating crystals which o rig in a lly existed as an assemblage o f "single crystals in predominantly parallel orientation". I hope Z haven't confused you by the fa c ts . I am in favor o f such a d e fin itio n , but I foresee d iffic u lt ie s in it s in terpretation for microscopic studies. CRMC-MAD-000593 m Johns-Manville To F . J . S o l o n , J r . Internal Correspondence Date: N o v e m b e r 3 0 , 1 9 7 3 From 1. M. F e n n e r Copies: F i l e & C Subject- ASTM COMMITTEE E - 3 4 The r e o r g a n iz a t io n o f t h i s C o m m itte e to o k p la c e in H o u sto n , T e x a s , W ednesday and T h u rs d a y , N ovem ber 28 and 29. I t i s c a lle d th e C o m m itte e on O c c u p a t io n a l H e a lt h and S a fe ty A sp e cts o f M a te ria ls , P h y s ic a l and B io lo g ic a l A g e n ts. I t s m a in p u rp o s e i s t o w r it e c o n s e n s u s s t a n d a r d s t h a t w i l l be a p p ro v e d b y th e m a in b o d y o f ASTM an d fo rw a rd e d t o th e O c c u p a tio n a l S a fe ty and H e a lth A d m in is t r a tio n fo r re is s u a n c e o r in c o r p o r a t io n in OSHA O c c u p a tio n a l S ta n d a rd s . T h e C o m m itte e i s s u b d iv id e d in t o w o r k in g S u b c o m m itte e s in tw o c a t e g o r ie s . The f i r s t c a t e g o r y , w h ic h a re c a lle d T a s k F o rc e G ro u p s r a t h e r th a n S u b c o m m itte e s, a re c h a rg e d w ith th e r e s p o n s ib ilit y fo r w r itin g th e sta n d a rd on a s p e c if ic m a te ria l o r p ro c e s s . A l i s t o f th e T a sk F o rce G roups i s appended to t h is re p o rt. A t th e m e e tin g in H o u sto n , I w as e le c t e d V ic e -C h a irm a n o f th e T a sk G roup on N a t u r a lly O c c u rrin g In o r g a n ic F ib e r s , w h o se m a in jo b w i l l b e t o w r it e s t a n d a r d s f o r a s b e s t o s and t a lc . A l i s t o f the atte n d e e s a t our T a sk Fo rce m e e tin g i s ap p en d ed . In a d d it io n to th e T a s k G ro u p s th e re a re S u b co m m itte e s co m p rise d o f e x p e r ts in s p e c if ic a r e a s . The fu n c t io n o f th e S u b co m m itte e s i s to a s s is t th e T a s k G ro u p s in w r it in g th o s e p o r t io n s o f th e docu m en t in w h ic h th e y h a ve e x p e r t is e and la t e r re v ie w in g th e i n i t i a l and f in a l d r a f t s o f th e se p o r t io n s o f th e s t a n d a r d s . A l i s t o f th e S u b co m m itte e s i s a t t a c h e d . I am a m em ber o f C o m m itt e e 3 4 . 4 0 ( E n g i n e e r i n g C o n tro ls ). T h e m a in c o m m itte e m e e tin g w as w e ll a tte n d e d -- a p p r o x im a t e ly 75 p e o p le fro m th e m a jo r in d u s t r ia l fir m s in th e U n ite d S t a t e s . A tta ch s. c r m c -m a d :000594 -34 Agenda Page 2 Wednesday - November 28, 1973 (Continued) 1:30 - 5:00 PM Meetings (The following T.F.'s will meet concurrently) Methyl Ethyl Ketone - Sol Levine Styrene Monomer - Bernard Grabois Stoddard Solvent - Homer Cole Carbon Disulfide - Grover Wrenn Hydrogen Sulfide - John W. Miller Naturally Occuring Inorganic Fibers - A. A. Winer Acetone Carbon Bisulfide Acrylonitrile Methyl Cellosolve Phthalic Anhydride Ozone Nickel Carbonyl Zinc Chromate 3:00 - 5:30 PM Chairmen of Subcommittees available for questions and discussion. Thursday - November 29, 1973 8:00 AM Registration 9:00 - 12:00 AM Subcommittee Meetings E34.10 - Definitions and Nomenclature - Henry M. Kissman E34.20 - Medical - Ernest Dixon E34.30 - Control - C. W. Schultz E34.40 - Toxicology - James M c N e m e y E34.60 - Safety - Darwin E. Rhoads CRMC-MAD-000595 K-34 Agenda Page 3 T liu i tl.i y - NovemlH*f I"), l `>7) (C o n lim ic d ) K34.70 - Data Collection - A. M. Kooiman E34.91 - Liaison E34.92 - Editorial - Fred M. Oberlnder 12:00 - 1:30 PM 1:30 - 4:00 PM LUNCHEON E-34 Main Committee 1. Reports 1.1 Executive Subcommittee 1.2 Task Force 1.3 Subcommittees 2. Discussion 3. New Business 4. Next Meeting 5. Adjournment CRMC-MAD-000596 T A S K G RO U P ON NATURALLY O C C U R R IN G INORGANIC FIBERS Dr. A. A. Winer, Chairman Department of Energy, Mines & Resources of Canada Mining Processing Division Ottawa, Ontario, Canada E. M. Fenner, Vice-Chairman Johns-Manville Corp. Denver, CO 80217 Marcel Cossette, Recording Secretary QAMA Testing Research Laboratories University of Sherbrooke Sherbrooke, PQ, Canada G. J. Foy Department of National Resources of Quebec Quebec, PQ, Canada G. Gagnon Lake Asbestos of Quebec Limited Black Lake, PQ, Canada A. M. Harvey R. T. Vanderbilt Co. East Norfolk, Conn. H. A. Hoffman Assistant Director Building Materials GAF Corporation ISouth Bound Brook, of Quality Divisions N.J. Control CRMC-MAD-000597 Lake Asbestos December 19, 1977 TO: M. Cossette, Q.A.M.A. EvW*:- Fenner* j . M. A.M. Harvey, R.T. Vanderbilt Gentlemen: Please find herewith the minutes of a special meeting on geometric parameters for asbestos fibers. Consensus was reached to undertake a limited study on fiber size d i s tribution and preliminary results should be available during the 3rd week of January. It would be desirable to call a meeting of A S T M Task Group on Asbestos after that time. January 30th was first suggested and written confirmation (or modifica tion) will be sent by Marcel. Yours truly PL/fp cc: AWiner 'jaPrAsbestos of Quebec Limited ack Lakkee.jQuebbeecc. G O N 1 A 0 423*4225 Cable LAQBESTOS BLACK LAKE ASARCO NOTES ON THE SPECIAL MEETING ON THE GEOMETRIC PARAMETERS FOR COUNTING ASBESTOS FIBERS HELD AT THE INSTITUTE FOR OCCUPATIONAL & ENVIRONMENTAL HEALTH, PLACE V1LLE-MARIE. MONTREAL, Q U E . , ON DECEMBER 13. 1977._______________________ 1.0 Participants: see exhibit No. 1. 2.0 Agenda: see exhibit No. 2 . 3.0 The meeting is chaired by Mr. Albert Winer. 4.0 Purpose of the meeting: 4.1 As explained by Mr. Winer, the meeting 1s organized by the ASTM Task Group on Naturally Occurring Inorga nic Fibers in order that a special study be undertaken by official Organizations Including some Regulatory Bodies. Such a study could eventually lead to a re vision of the geometric parameters for counting as bestos fibers and therefore to a better definition of asbestiform minerals. 5.0 PARAMETERS TO BE STUDIED 5.1 Mr, Trudeau proposes that the discussion be restricted to technical considerations only and that the biologi cal aspect of the problem should be 1ft to the specia lists. 5.2 Mssrs Gibbs, Knight and Trudeau propose that distribu tion of fiber lengths and aspect ratios should be stu died from various sample sources. .000599 2 5.3 Mr. Grimard suggests that we should study a few values only Since fiber counting is the main o b j e c t i v e and that practicalness of the technique should be m a i n tained . 5.4 The values selected for the study are shown on the following table: /aspect ratio/ 3:1 length ' to 5:1 5:1 to 10:1 10:1 to over 5 to 10 aJ m 10 to 50 >um 50 x m and over 5.4.1 Mr. Gagan me ntions that coun ti ng p r e c i s i o n beyond 50 m i c r o m e t e r s is ex pected to be p o or due to the r e l a t i vely small n u m b e r of fibers in that range. 5.5 Mr. Laroche suggests that only fibers h a v i n g a diameter sm al le r that 3 m i c r o m e t e r s should be c o n s i d e r e d in the study since thicker fibers are beyond the respirable range. 5.6 Mr. Steel distributes and comments the prel im in ar y results of a U.S.B.M. study on asbestiform tremolite. (see atta ched exhibi t N o . 3). 5.6.1 It is also m e nt io ne d that similar s t u d i e s are being done at E.P.A. and U.S. Steel. CRMC-MAD-000600^ en .6.2 Hr. Winer proposes that available results of studies on this subject should be sent to P. Laroche. 5.7 Mr. Trudeau remarks that the prooosed st ud y could also show that the fiber counting precision is sensitive to a change of the counting parameters. & . Q Mr. Gagan mentions that E n vi ro nm en t C a na da 1n their p u blished regulations on asbestos fiber emissions recom mend an aspect ratio of 3:1 for fiber c o un ti ng . He a l so me ntions the reasons su pp or ti ng t h e i r deci si on i.e. lack of ba ck gr ou nd data su pp or ti ng 5:1 at that time, p o s sible delay to regulations, e t c ...... 5.9 Mr. Piuze reminds the participants that the prime o b j e c tive at this time is to co llect some d a t a on fiber c o u n ting. Results will be analysed at a later meeting and a proposal to main ta in or m o di fy the c o u n t i n g parameters could then be formulated by this group. 5.10 Mssrs. Piuze and Winer suggest that chrysotile only should be co ns id er ed in the study. Du e to the short time period available, we should maintain the study within a manageable size. 5.1 Mr. Gibbs ou tlines an ot he r study that c o u l d ev en tu al ly lead to a co unting "protocole" in the P r o v i n c e of Qubec for both the primary and secondary asbestos industries. A merging of both studies would be d e s i r a b l e but due to time limit, it will not be possible at th is time. 5.0 NUMBER OF SAMPLES AND PARTICIPATING LABS. 6.1 Mr. Piuze suggests the following labs: E n v i r o n m e n t C a nada, U.S.B.M., McGill, Ontario Research Foundation, Qubec and Q .A .M .A . CRMC-MAD-000601 4 6.2 Mr. Trudeau mentions that many sample sources are not required if ev al ua ti on of the counting p r ec is io n is the main objective. 6.3 Mr. Winer remarks that the sensitivity of the fiber counts to various aspect ratios could be di ff e r e n t for different industries. 6.4 Mr. Riley suggests that the following manufacturing industries should be included in the study: asbestoscement, brake lining, asbestos paper and textile. 6.5 In order to save on sampling time, Mr. Gi bb s suggests that some samples already collected could be obtained either from Qubec or from McGill. 7.0 SAMPLING METHOD. 7.1 E v er yb od y agrees to the NIOSH m e m b ra ne f i l t e r method. 7.2 Mr. Gibbs inquires about funding of the study. Mr Piuze answers that no funds are available from the Q.A.M.A. right now. 8.0 ORIGIN OF SAMPLES. 8.1 It is agreed that samples should t e n t a t i v e l y be c o l l e c ted from the following sources: Cascade Paper (Kingsey Falls, Qu.) Asbestonos (St-Lambert, Qu.) Amiante de Sherbrooke (Sherbrooke, Qu.) Atlas Asbestos (Montral, Qu.) Carey Canadian Mines (East-Broughton, Qu.) Lake Asbestos of Quebec (Black Lake, Qu.) CRMC-MAD-000602 8.2 Mr. Trudeau suggests that 2 or 3 samples per source are desirable. 8.3 Mr. Grimard proposes that 2 operators should count the filters at each participating lab. 9.0 SHIPPING OF SAMPLES TO PARTICIPATING LABS. 9.1 Mr. Trudeau agrees to ship the samples to the labs and to supervise the study. 9.2 Mr. Knight agrees to receive and sort the results. He will also arrange the data for statistical analysis at the federal government facilities in Ottawa. 10.0 RULES FOR FIBER -COUNTING. 10.1 The NIOSH rules will be observed except that: 10.1.1 Only fibers with a.diameter smaller than 3 microme ters wil1 be counted. 10.1.2 200 fibers per filter segment must be counted and the number of fields required to obtain 200 fibers should be reported. 10.2 Mr. Trudeau will send the counting rules together with the samples to the labs. 11.0 TIME SCHEDULE. 11.1 Send the samples within a week. 11.2 Fiber counts should be sent to G. Knight by the second week of January. CRMC-MAD-000603 6 11.3 G. Knight will tabulate the results during the third week of January (20th January). 11.4 This Group will meet again to analyse the results one week later. 12.0 MISCELLANEOUS. 12.1 Mr. Steel out", ines the works done in U.S.A. on trans mission electron microscope (T.E.M.) for counting as bestos fibers. There were large differences in the fiber counts from the 8 labs participating to the orlginal study (i.e. in the range fro 0.2 to 8,000 F/cc). 12.2 Mr. Piuze explains some of the advantages of the gravi metric dust measurement techniques (i.e. short-term results, better reliability, etc....). PL/fp Acting Secretary CRMC-MAD-000604 SPECIAL MEETING ON GEOMETRIC PARAMETERS/ASBESTOS COUNTING LISTOF PARTICIPANTS NAME Craigepl, Bill Gagan, Earl W. Gibbs, Graham Grima r. , Michel Knight, Geoffrey Laroche , Pierre Piu2e , Lionel C. Hilty s George Steel, Eric B. Trudeau , Marc Winer, A1bert AFFILIATION Canmet: Energy, Mines & Ressources Environment Canada McGi11 Uni versi ty Health & Welfare Canada (Env. Health Center) Quebec Asbestos Mining Association Lake Asbestos of Quebec, Ltd. Quebec Asbestos Mining Association Canmet; Energy Mines & Ressources U.S. Bureau of Mines Quebec Asbestos Mining Association Canmet: Energy, Mines & Ressources ADDRESS 405 Rochester St., Ottawa, Ont. Air Pollution Control, Ottawa K1A 1C8 3775 University St., Montral, Que. H3A 2B4 RM 112, Ottawa, Ont. K1A 0L2 C.P. 247, Thetford Mines, Qufi. G6G 5S5 C.P. 608, Black Lake, Qu. GON 1AO C.P. 608, Black Lake, Qufi. GON 1AO 405 Rochester St., Ottawa, Ont. College Park, Maryland 20740 603, 3 Place Ville-Marie, Montreal, Qud. 405 Rochester St., Ottawa, Ont. H ' B T* IS) * Z. SPECIAL MEETING ON GEOMETRIC PARAMETERS FOR ASBESTOS COUNTING TO BE HELD AT THE INSTITUTE FOR OCCUPATIONAL & ENVIRONMENTAL HEALTH IN MONTREAL ON DECEMBER 13, 1977. AGENDA 1. Introduction - Purpose of the meeting. 2. Parameters to be studied. 3. Number of samples required for the round robin and duplication of the samples. 4. Sampling method. 5. Origin of samples. 6. Who takes the samples? 7. Duplication of samples for counting. 8. Shipping of samples to participants. 9. Counting and results. 10. Analysis of the results and discussions. 11. Report and conclusions. CRMC-MAD-000606 Authorization No. 9367 Component 1 C n n ? B *T Ni 3 TABLE 2. - Aspect ra tio of particles from milled blocky, acicular, fibrous, and asbestiform tremollte Aspect Ratio M r lfrCPWATtW/ N. 3: 1 >5:1 R. 5: 1 10:1 >10:1 20:1 >20:1 50:1 <50:1 Trcmoli te * M'in.ber of Particles Qlocky w 13 10 2 1 0 Acicuiar* 173 8 12 6 1 0 Fibrous 1Ji 37 37 11 1 0 Asbesti form-1 97 13 26 27 27 10 Asbestiform-2 107 7 29 2 k 26 7 * Low calcium amphibole l a o o >< **r: c * ^ h a g n ; f i <= T''0KJ * i-Css k S S. T H A (O (i-Z* G T A ) : I t o CRMC-MAD-000607 ASTM COMMITTEE MEETING - APRIL 6th. 1979 ATTENDANCE NAME A . Winner Edmund M. Fenner Geoffrey Kni ght George W. Riley Earl W. Gagan Allan M. Harvey W.R. Cooli ng G. Foy Lloyd G. Phelps J .K. Gilman M. Cossette C.S. Thompson ORGANIZATION ADDRESS Canmet (EMR) Johns-Manvi11e EMR Canmet (EMR) Environment Canada R.T. Vanderbilt Co. Asbestos Corporation Quebec Department of Natural Resources Vermont Asbestos Group Inc. Vermont Asbestos Group Inc. (Retired) Universit de Sherbrooke R.T. Vanderbilt Co. Ottawa Denver, Co. Elliot Lake Ottawa Ottawa (Hull ) Norwalk, Ct Thetford Mines Qubec Hyde Park, Vt Hyde Park, Vt Sherbrooke Norwalk, Ct CRMC-MAD-000608 I . J2 t Georges Dahmen Eric Chatfleld Marc Trudeau Mike Bumbaco Dr. M. Alvo Qubec Department Natural Resources Bureau de 1'amiante Ontario Research Foundation 845 0. St-CyMlle Qubec Sheridan Park Mississauga, Ont. L5K 1B3 Association des mines d'amiante du Qubec Environment Canada for Applied Statistics SCS Consultants Inc CASD Environment Canada Thetford Mines Ottawa Ottawa --- l 1 H H ,j h \ i ~ I W l u t . 11 I * Energy Mmet end Energie. Mm n Heaoutce C a w Retaourr.ru Canada George W. Riley, < r-m Manager Induninal Minerete l eboraiory Canada Cantre lot Mineral ^ Energy Technology 40f>nnrhoewr Street - CKh1iAamOaOIOntano (itinotimi I OfI t>(0 i'O CRMC-MAD-000609 flAM H siii\ Johns-Manville R. P. Carter To: b., A. Cooper W. B. Reitze From: e . m . Fenner Internal Correspondence F. J. Solon, Jr. S. Speil W. C. Streib Dirte: July 31, 1974 Copies: File & C Subject: MEETING - 9;00 A.M. , AUGUST 6 , 1974 DEFINITION OF AN ASBESTOS FIBER - OSHA STANDARD As you are aware, there has been considerable discussion concerning the definition of an asbestos fiber as presently used by OSHA, particularly in regard to the prescribed aspect ratio of 3 to 1. ASTM has organized Committee E-34, "Committee on Occupational Health and Safety Aspects of Materials, Physical and Biological Agents". There are a number of subcommittees and task groups within this committee. One of these task groups is concerned with "naturally occurring inorganic fibers". T h is task group is presently engaged in writing for submittal to OSHA through normal ASTM channels a revised standard for occupational exposure to asbestos fibers. One of the important sections being written by this task group is concerned with the definition of asbestos fiber. The next meeting of the Task Group on Naturally Occurring Inorganic Fibers takes place on August 14 and 14 in Canada. I would very much like to be able to submit to the group a Johns-Manville definition of an asbestos fiber. In order to accomplish this, I am requesting that you attend a meeting to discuss the subject at 9:00 A.M. on Tuesday, August 6, in our Conference Room, 4 North. For background information prior to the meeting, I enclose the following: (1) A letter to F . J. Solon, Jr., describing ASTM Committee E-34. (2) A definition for asbestos fiber as prepared by a subsection of the task group for affirmative or negative ballotting by the group members. CRMC'M AD-000610 R. P. C a rter, e t a l Page 2 July 31, 1974 (3) A series of definitions of asbestos as previously submitted by the following people: A. A. Hodgson, Cape Asbestos Fibres Limited G. Gagnon, Lake Asbestos of Quebec Limited M. Grimard, M.D., Department of National Health & Welfare of Canada R. B. Steele, Asbestos Corporation Limited A. A* Harvey, R. T. Vanderbilt Company (4) A definition of an asbestos fiber as prepared by Dr. Steven Holmes of the Asbestosis Research Council. (5) The ASTM present definition of asbestos fiber. (6) & (6A) Two anonymous definitions of asbestos. (7) An anonymous definition of naturally occurring inorganic fibers. (8) A copy of the original proposal for the formation of the Task Group on Naturally Inorganic Fibers. (9) A listing of active members of the task group and all others on the mailing list for material. E. M. Fenner CRMC-MAD-000611 m Johns-Manvill Internal Correspondence To E. M. Fenner - 4N Troni: S. fpei.l - R&D Copies: Da<' January 15, 1974 Subject TASK GROUP ON NATURALLY OCCURRING INORGANIC FIBERS ASTM COMMITTEE E-34 Your note of January 11, 19 74 You are correct that this is the present ASTM definition. Attached is a copy of the page in the ASTM book giving these definitions. As a matter of fact, the fiber defi nition is the one that I suggested that Vanderbilt try to get accepted in their proposal to the FDA/Bureau of Mines. As a matter of information, the definition of asbestos fiber is a good commercial definition, but could lead to serious problems of interpretation. For example, if a microscopist looks at a talc sample and attempts to "count" tremolite fibers what he is counting normally is individual crystals. The tremolite "fibers" are not "composed of sin gle crystals in predominantly parallel orientation"; there fore, these tremolite particles would not be classed as asbestos fiber under the proposed definition. Under the proposed definition I doubt whether we could even classify many of the crocidolite particles in the UICC sam ple as asbestos fiber. Finally, if we were to look at a well-dispersed field of chrysotile fibrils, obviously each fibril would not be an asbestos fiber because it is one single crystal but not an assemblage of crystals in predo minantly parallel orientation. While the intent of this definition is excellent in that under it much of the matter, for example in Duluth water, might not be classed as asbestos fiber because it comes from the cleavage of a rock during grinding, the microscopist examining the sample would be put to a difficult task under some circumstances to determine whether the individual cry stals that he sees in the microscope field were produced by breaking up a basically massive material or whether they came from separating crystals which originally existed as an assemblage of "single crystals in predominantly parallel orientation". I hope I havr 't confused you by the facts. I am in favor of such a dei . n x b u t I foresee difficulties in its in terpretation or micr- -ocpic studies. C R M C -M A D -00 0 612 R. T. V A N D E R B IL T C O M P A N Y . INC. 30 WINFIELD STREET NORWALK, CO N N ECTICU T 0 6 8 5 5 July 18, 1978 COLf iDDSCil TW1*I073iOO-4BA3A-K*ZOBO40 "H.TVAN ' N OAAAUH. C O N N E C T IC U T Mr. Marcel Cossette Quebec Asbestos Mining Association University of Sherbrooke, P.Q. Sherbrooke, QUEBEC J1K 2R1 Dear Mr. Cossette: It has come to my attention that the requirement for caution labels as stated in paragraph 5.3.1. of the 12th draft of the ASTM E-34 Standard for Occupational Exposure to Asbestos is unworkable as written. The wording "caution labels should be affixed to all raw materials, mixtures, scrap, waste, debris, and other products containing asbestos fibers, or to their containers," could be interpreted by the courts, in the absence of any qualifying minimum concentration of asbestos fibers in the product, to mean any concentration above zero. Such an interpretation was taken by the courts in the case GAF Corp oration v. OSAHRC and Dunlop (No. 76-1028) in relation to the OSHA asbestos standard requirements for medical exams for exposed employees. The court ruled that "con centrations of asbestos", as stated in the regulation, meant any concentration of asbestos above zero. Obviously, a similar interpretation of "containing asbestos fibers" for pur poses of labeling, would mean that the asbestos warning label would be required on mineral product containers where the concentration of asbestos was in the parts per million range. The possibility that this might happen is supported by a recent finding, through Freedom of Information Requests, of a recommendation by the OSHA Solicitor's office that talcs containing any amount of asbestos be labeled with the official Asbestos Warning Label. It has been argued that the OSHA requirements for labeling products containing asbestos, which uses essentially the same language as the ASTM draft standard, might be interpreted to mean that only products containing sufficient asbestos "so that during any reasonably foreseeable use, handling, storage, disposal, processing, or transportation, no airborne concentrations of asbestos fibers in excess of the pre scribed exposure limits" be labeled. Naturally it would be unreasonable to believe that a product containing, for example, 0 .1 % asbestos could release more than 2 fibers/c.c. under normal conditions of use. But as long as the language of the standard remains vague or unspecific, the courts, in their efforts to favor the protection of the employee, might easily adopt an attitude similar to that applied in the GAF case. However, the GAF case points out the need for precise terms in regulations of importance to hume life. Circuit Judge MacKinnon, in his concurring opinion in the GAF case criti the regulation: Tha rocu**#' t nr*t (or d cur maim# #f* b*Md upon to ts to be retard Hommv ** do no* "ufl'tn u e CRM wi.'s to be otomad c ^000613 :i>c.r.k. .','U)io.i(K)itbHi) ;hhI<:> (p<-m The prescribed standards hi tlu-se rgulattons were: "the fillers, longer than 5 micro meters. per ctihte centimeter ol air." and alter July 7, 1976, "tun fibers." These standards inform the nation's employers precisely what degree of exposure ts per mitted and what exposure is excessive, but the reputation requiring medical examina tions is almost completely deficient in this respect. What number of fibers, of what length, per what volume of air will constitute a "concentration" is nowhere stated or even hinted at--and like the regulation, the court's opinion leaves the matter completely to conjecture. This is particularly unsettling Page 2 to law abiding citizens when the agency is dealing with tremendously minute quan tities of infinitesimally small particles, it makes compulsory law enforcement diffi cult and it lessens the likelihood of volun tary compliance with the law, a result devoutly to be wished. The first requirement for uniform and voluntary compliance with the law is a clear understandable statement of what conduct is required and this regula tion falls woefully short of that minimal f requirement. Regulations that have the great im portance that this regulation has to human life should be written in more precise terms--so people of ordinary understanding can determine what course of conduct is being required of-them. What one person might consider to constitute a "concentra tion" will differ greatly from the interpre tation that another would give to that term; and what one person today might regard not to constitute a concentration" might be considered tomorrow, on the basis of hind sight as medical knowledge increases, to come within that term.1 .believe, however, that the Occupational Safety and Health Review- Commission should clarity the regulation governing medical examinations so as to give other persons subject to the regulation reasonable notice o) some measurable quantity of air borne asbestos the Commission intends to trigger the medical examination require-' merit. Merely to state that all employers must ptovidc medical examinations when ever their employees arc exposed to "con-ecnttations" of asbestos libers docs not ptovitlr an ascertainable standard for those who wish to comply with the law. For the above reasons we believe the language of paragraph 5.3.1. concerning caution labels should read: R T VANDERBILT COMPANY. INC. ' ago 3 Caution labels should be affixed to all raw materials, mixtures, scrap, waste, debris, and other products containing more than 1 percent asbestos on a dry weight basis or to their containers, except that no label is required where asbestos fibers have been modified by a bonding agent, coating, binder, or other material so that during any reasonably foreseeable use, handling, storage, disposal, processing, or transportation, no airborne concentrations of asbestos fibers in excess of the exposure limits prescribed in 5.1 will be released. This is the same exclusion allowed in the EPA National Emission Standard for Asbestos (Federal Register sl8_, 8829 April 6 , 1973), for spraying, which reads: (e) Spraying: There shall be no visible emissions to the outside air from spray-on application of materials containing more than 1 percent asbestos, on a dry weight basis, used to isolate .......... Furthermore, the practice of setting exclusion levels for regulated materials has been followed by OSHA in the case of the 14 carcinogens (29CFR 1910.1003 through 1910.1016) wherein exclusion levels of 0.1 and 1.0 percent were allowed for various carcinogenic chemicals before the regulation applied, and more recently in the case of the OSHA benzene standard (29CFR 1910.1028) wherein there is no warning label requirement for mixtures containing 0.5 percent benzene (0.1 percent after June 27, 1981). The practice of choosing exclusion levels for regulated materials could be considered as an effort by OSHA and other regulating agencies to now recognize "feasibility" in the development of standards. It would not be feasible to analyze all silicate mineral mixtures for any asbestos content, yet a requirement to label talcs or any other silicate minerals assemblages such as pyrophyllite, kaolin, montmorillonite, etc. containing any asbestos would obligate the producers of many non-beneficiated mineral products to maintain an extremely costly program of trace analysis. In addition to feasibility, the agencies are also questioning the necessity of stringent regulation in areas such as label requirements. The exception to labeling in the OSHA standard for materials containing asbestos that has beer, modified with a binder, etc., is evidence of a reuognj.tion that only trace amount of asbestos will be released by tne normal handling of these products. If cnly trace amounts of asbestos can be released from a non-modified mixture containing a low percentage of asbestos, then there is similarly no need to label or regulate the mixture. In a final consideration of the need to stipulate a concentration of asbestos in a mineral product mixture below which no warning label would be required the state of the art of asbestos detection and counting should be recognized. Despite some published reports that concentrations of asbestos below 1 percent can be detected with accuracy, it rema ... r^at the accurate identification and quantitative determina CRMC-MAD-000615 R! T V A N D E R B I L T C O M P A N Y , I N C . Page 4 tion of some of the amphibole varieties of asbestos in an unknown mixture is difficult below 5 percent and almost impossible below 2 percent by weight concentration. This couplea with the present unresolved controversy over the definition of an asbestos fiber favors the setting of a minimum asbestos concentration for purposes of labeling requirements in the ASTM draft standard for asbestos. I wouiid be pleased to discuss this matter further at our next meeting of E-34 committee. Sincerely, R. T. VANDERBILT COMPANY, NC. AMH:Ism Allan M. Harvey, Manager Technical Development Department CRMC-MAD-000616 R. T. VANDERBILT COM PANY. INC. 30 WINFIELD STR EET NORWALK, CO N N ECTICU T 0 6 8 5 5 February 2, 1976 s- I - CABLE AOORC9S O ' L T v a n ** N O W W A C * . C O N U C C ^ ' C U * -W X 7 '0 -4 -* < M O Mr. Peter G. Brown Staff Manager Standards Development Division ASTM, 1916 Race St. PhiladelDhia, PA. 19103 Dear Mr. Brown: My comments on the E-34 Naturally Occuring Inorganic fibers Task Force comments submitted in your letter of January 28, 1976 are as follows: Page 2. Para. 1.2, first line. line "that" should read "of". The last word in this Page 4. Para. 2.3, 6th line. be deleted. One "committee" should Page 4. Para 2.3, 9th line. "Dr. S. Holmes". "Mr. S. Holmes" should read Page 9. Reference 11. The complete reference should be replaced with the following: "Standard Method No. CTFA J4-1 9-3-75. Cosmetic, Toiletry m d Fragrance Association, Talc Sub committee". Page 9. Reference #7 was omitted. It should read: Deer, W.A., R.A. Howie, and J. Zqssman. Rock Forming Minerals. Vol. 2 & 3, Longman Group Ltd., London, 1963. Pg. 40. Sincerely AMH:aa Al. Tech. Devip. Mgr. c r m c -m a d -oo6" Th# noDmmendstkyts for uo* o4 r wtttriak art Pas<i upon twts to b# rtbaoi* do n<* gua*entw to b# obtained APPENDIX I Testing Research Laboratory University of Sherbrooke Sherbrooke, P.Q. Tel.: 819-565-3659 1 March 1973 MC-150-73 Messrs: J. W. Axelson R. E. Byrne E. M. Fenner P. A. Filteau H. Fawcett W. H. Foster G. Gagnon G. W. Gibbs A. M. Harvey M. J . Neville T. I). Oulton L. C. Piuze M. Q. Scowcroft W. H. Smith H. iu Swetonic T T. Triglea A. A. Winer -Johns-Marrville Research Center -Union Carbide Corporation -Johns-Hanville Research Center -Quebec Asbestos Mining Association -National Academy of Sciences -Chairman, QAi'iA Uniform Classification and Grading Committee -Lake Asbestos of Quebec Limited -McGill University -R. T. Vanderbilt Company, Inc. -Asbestos Cement Products Association -Engelhard Chemical & Mineral Industries -Chairman, QAhA Environmental Control Committee -President, Asbestos Textile Institute -Bell Asbestos Mines Limited -Asbestos Information Association/North America -Engelhard Chemical it Mineral Industries -Department of Energy nines and Resources of Canada Gentlemen: Further to my letter of 1 February 1973 regarding the proposal for the formation of a subcommittee of ASTM Committee E-3A to deal specifically with 1Naturally-occuring Inorganic Fibers' this proposal has been modified to reflect the comments received. A copy of this revised proposal is enclosed herewith for your disposal. Yours very truly MC-hl Enel. K. Cossette 3^^AD-000618 7A34 1 iarch 1973 hC-150-73 wr. P. D. Halley, Chairman ASIh Committee u-34 c/o: Environmental Health Services Standard Oil Company (Indiana) 910 South iiichigan Avenue Chicago, 111. 60605 Dear hr. Halley: At the last meeting of Committee L-34, a proposal for the formation of a subcommittee on asbestos was not entertained on the basis of the Committee's policy of avoiding fields of endeavor already regu lated by any other agency. At that time, you suggested that I submit for your consideration, and that of your Executive Subcommittee, a written statement of my proposal stating what the scope and goals of such a subcommittee could be. Subsequently, at the meeting of Subcom mittee .34.50, the subject was raised again and discussed at some length, with regard to the formation of a Task Group on Asbestos, it wa3 proposed by Chairman Janous that a complete proposal be submitted to him and to you for consideration. Accordingly, on behalf of the following interested persons who are either members of R-34 or prospective members, the enclosed proposal is being submitted for your consideration and that of your Executive Subcommittee. SaJtlfafllL-gil iiessrs: E. M. Fenner G. Gagnon A. n. Harvey J . .. warnhart -Johns-wanviila Research and Development Center Denver, Colo. 80217 Tel.: 303-770-1000 - Lake Asbestos of Quebec Limited Box 608 Black Lake, P.Q., Canada Tel.: 418-423-4221 - R. T. Vanderbilt Company, Inc. 33 Winfield Street East Norwalk, Conn. 06855 Tel.: 203-838-4351 - National Insulation Manufacturers' Association 7 Kirby Plaza Ht. Kisco, N. Y. 10549 CRMC-MAD-000619 - 2- T. D. Ouiton w. H . Smith E. T. riglea U. Byrne, Jr. J. D. Wendlick A. n. Winer - Engelhard Chemical & Minerai Industries aenloe Park Edison, N.J. 08817 - Bell Asbestos Mines Limited Box 99 Thetford Mines, P.Q., Canada Tel.: 418-338-8777 Engelhard Chemical ci: Minerai Industries Menloe Park Edison, N.J. 08817 - Union Carbide Corporation Mining and Metals Division Box 579 Niagara Falls, N.Y. 14302 Tel.: 716-278-3369 - Weyerhauser Co. - Department of Energy, Mines and Resources of Canada Mineral Processing Division 40 Lydia Street Ottawa, Ont. Tel.: 613-996-5449 Also on behalf of and with a mandate from: - ASTm Subcommittee D30.03 on Asbestos and Naturally Occuring Fibers. - Quebec Asbestos Mining Association Suite320 580 Grande Alle, East Quebec 4> P.Q., Canada - Asbestos Textile Institute Box 471 (131 N. York Road) Willow Grove, Pa. 19090, U.R.A. CRMC-MAD-000620 [ - 3- ~ Asbestos Cement Products Association 20th Floor 521 Fifth Avenue New York, N.Y. 10017, .S.A. - Asbestos Information Association/North America 22 Last 4-Oth Street New York, N.Y. 10016 U.S.A. Yours very truly QAiiA Testing Research Laboratory ,C-hl A. Cossette Director c.c. -hr. J. Janous, Chairman A?3K Subcommittee E-34*50 c/o: American Iron and Steol 1000 K Street, N.li. Washington . C. 20036 Institute CRMC-MAD-000621 R . T. V A N D E R B ILT C O M P A N Y . IN C. 33 WINFIELD ST R EET EALT NORWALK,CO NNECTICUT 0 0 6 5 5 December 12, 1973 C A B LE ADOKCS* B ILTV N NEW VON* Mr. Marcel Cossette, Director Testing Research Laboratory Quebec Asbestos Mining Association Universit De Sherbrooke Sherbrooke, Quebec J1K RJ. Dear Marcel: Enclosed is a set of definitions for "fiber" as well as various definitions of the word "asbestos" which contain references to the physical characteristics of naturally-occuring mineral fibers. I am also enclosing reprints from several newspapers of articles commenting on Dr. Zussman's testimony at the recent Reserve Mining Co. trial in Duluth. If some thought is given to the matter, I believe that whole affair in Duluth could end up with the same question we are faced with in our standard setting - "What is a fiber?" And of course, the people in Duluth also must 'answer that question in the context of the pathological response of the mineral shapes in question. Although we have agreed tentatively that the ASTM Designation D 2 9 ^ -TIT definition of a fiber can quite possibly serve our needs, mineralogists and geologists may take issue. A 10:1 ratio mineral particle resulting from the fracture of a shorter particle rather than from the shortening of a long fiber might rightfully be considered not a fiber. It can be argued that a fiber can be shortened until its aspect ratio is 3 ; 1 and it is still a fiber, but a true fiber cannot be formed by the fracturing of a mineral particle that was not a fiber to begin with. In other words, a fiber may have to be defined by its peculiar property to "separate into fibrils" when crushed or processed. To complicate matters, we have the case of minerals which appear fibrous to the naked eye but fracture easily into non-fibrous particles when processed commercially, and are never experienced in the workplace as anything but a non-fibrous dust. Since we are addressing ourselves to "workplace" standards, should we be concerned with the morphology of minerals as they occur in nature or as they are realistically encountered? CRMC-MAD-000622 Th* rtcoffiffttftdwnt fur i ofour materni r* (mod upc* tev* to be retatilo How**' >3 nu guarantM the rrw is to Usotftamod R T. V A N D E R B I L T C O M P A N Y , I N C . Mr. Marcel Cossette, Director - 2 December 12, 1975 To respond to your question of how many times per year our task-force group should meet, I would say about once a year, although it could be more frequent if the need arose. I trust the attached information will be of assistance in your proposed letter balloting, and I hope the mails are good enough to allow this letter to reach you in time. Please call me if you need more data. AMH: sib Enclosures cc: Mr. Albert A. Winer Very truly yours, R. T. VANDERBILT COMPANY, INC. Al Allan M. Harvey, Manager Legal a^d Product Application CRMC-MAD-000623 M Mi I f y I Johns-Manville Internal Correspondence To: P Kotin, M.D. Dato; May 26, 197 6 From: E . M. Fenner , Copies: G . W. Wright, M.D. W . B . Reitze -- -------r Subject: A M E R IC A N M IN IN G CONGRESS NONCOAL O CC U PA TIO N A L HEALTH COM M ITTEE R. P. Carter This committee held its first meeting in Washington on Tuesday, May 25. The first half of the meeting was a discussion of the purpose and scope of the committee. Then considerable time was devoted to comments on the forthcoming meeting of the Federal Metal and Nonmetal Mine Safety Advisory Committee (see copy of our meeting agenda attached). An item on the Advisory Committee meeting agenda is the MESA suggested revised standard for exposure to asbestos (copy attached). The critical change they proposed is the substitution of the term "mineral fibers" for asbestos, and the elimination of any definition of asbestos. Literal interpretation of the proposed standard could mean that any naturally occurring mineral fiber which meets their definition: "A fiber is defined as a particle that exceeds 5 microns in length but not 5 microns in width and which has a length to width ratio of at least 3 to 1" could be subject to this ruling. The chairman of the committee, Bernard R. Roy of Amax Inc., appointed an ad hoc subcommittee consisting of: C. S. Thompson, Ph.D., R. T. Vanderbilt, Chairman David J. Smith, M.D., U. S. Steel Corporation Michael J. Doyle, The Hanna Mining Co. E. M. Fenner to prepare AMC's comments on the proposed standard and to determine the most effective way of convincing the committee not to endorse the proposal. For your further information, lists of the Committee members and those attending the May 25 meeting are attached. May I pleas^ have your comments. CRMC-MAD-000624 bee: G. ],. Fiederlcin ' A . M . Harvey K. S. Karsten T. T. Noland n. B. Vanderbilt R . T. V A N D E R B I L T C O M P A N Y . IN C . 30 WINFIELD STREET NORWALK. CO N N ECTICU T 0 6 0 5 0 June 22, 1976 VIA AIR MAIL Cmduc Ac-or**o HLTVAN* n O f l W A t M, C O N N t C T I C U T TWX 7 l 0 ' 4 6 S ~ f 4 0 (705) 0*3-1400 Mr. Herbert P. Levan Federal Metal and Nonmetal Safety Advisory Committee Room 702 Ballston Tower No. 3 4015 Wilson Blvd. Arlington, Virginia 22203 Mine Dear Mr. Levan: This is to advise you that I will be attending the Federal Metal and Nonmetal Safety Advisory Committee meeting to be held in Burmingham, Alabama on June 29-30 and July 1, 1976. I will be there representing the AMC Noncoal Occupational Health Committee, and accompanied by two other members of the AD HOC Committee on "Mineral Fibers". These gentlemen will be ad vising you of their intentions to attend individually. We are planning on giving a presentation of no longer than a half an hour. Very truly yours, S. THOMPSON, Manager Minerals,'Ceramics & Paper Dept. Research & Development Division CST:dpk cc: Mr. Ernest H. Ronn (Committee Chairman) United Steelworkers of America District 33, P. 0. Box 83 Ncgaunee, Michigan 49866 -.riv ' LM c/c m 1 C' * vp:/ tV.* fcV** la S* t< uiV* U t*'*' <** 3 CRMC-MAD-000625 to S cu To: From: opies: bject. concerning the definition of an asbestos fiber as presently used by OSHA, particularly in regard to the prescribed aspect ratio of 3 to 1. ASTM has organized Committee E-34, "Committee on Occupational Health and Safety Aspects of Materials, Physical and Biological Agents". There are a number of subcommittees and task groups within this committee. One of these task groups is concerned with "naturally occurring inorganic fibers". This task group is presently engaged in writing for submittal to OSh'A through normal ASTM channels a revised standard for occupational exposure to asbestos fibers. One of the important sections being written by this task group is concerned with the definition of asbestos fiber. The next meeting of the Task Group on Naturally Occurring Inorganic Fibers takes place on August 14 and 14 in Canada. I would very much like to be able to submit to the group a Johns-Manville definition of an asbestos fiber. In order to accomplish this, I am requesting that you attend a meeting to discuss the subject at 9:00 A.M. on Tuesday, August 6, in our Conference Room, 4 North. For background information prior to the meeting, I enclose the following: c (1) A letter to F. J. Solon, Jr., describing ASTM Committee E-34. (2) A definition for asbestos fiber as prepared by a subsection of the task group for affirmative or negative ballotting by the croup members. I CRMC-MAD-000626 R. P. Carter, et al Page 2 July 31, 1974 (3) A series of definitions of asbestos as previously submitted by the following people: A. A. Hodgson, Cape Asbestos Fibres Limited G. Gagnon, Lake Asbestos of Quebec Limited M. Grimard, M.D., Department of National Health & Welfare of Canada R. B. Steele, Asbestos Corporation Limited A. A. Harvey, R. T. Vanderbilt Company (4) A definition of an asbestos fiber as prepared by Dr. Steven Holmes of the Asbestosis Research Council. (5) The ASTM present definition of asbestos fiber. (6) & (6A) Two anonymous definitions of asbestos. (7) An anonymous definition of naturally occurring inorganic fibers. (R) A onnv o f fh o o r ig in * ! ) p rn p n n s l f n r fb p f n r w s t in n of the Task Group on Naturally Inorganic Fibers. (9) A listing of active members of the task group and all others on the mailing list for material. E. M. Fenner 4 ' CRMC-MAD-000627 Attachment 1 /W Internal Correspondence To: F. J. Solon, Jr. Date; Nov e m b e r 30, 1973 From: E, M. Fenner Copies: File & C Subject: ASTM COMMITTEE E-34 The reorganization of this Committee took place in Houston, Texas, Wednesday and Thursday, November 28 and 29. It is called the Committee on Occupational Health and Safety Aspects of Materials, Physical and Biological Agents. Its main purpose is to write consensus standards that will be approved by the main body of ASTM and forwarded to the Occupational Safety and Health Administration for reissuance or incorporation in OSHA Occupational Standards. The Committee is subdivided into working Subcommittees in two categories. The first category, which are called Task Force Groups rather than Subcommittees, are charged with the responsibility for writing the standard on a specific material or process. A list of the Task Force oroups is .appended to this report. At the meeting in Houston, I was elected Vice-Chairman of the Task Group on Naturally Occurring Inorganic Fibers, whose main job will be to write standards for asbestos and talc. A list of the attendees at our Task Force meeting is appended. In addition to the Task Groups there are Subcommittees comprised of experts in specific areas. The function of the Subcommittees is to assist the Task Groups in writing those portions of the document in which they have expertise and later reviewing the initial and final drafts of these portions of the standards. A list of the Subcommittees is attached. I am a member of Committee 34.40 (Engineering Controls). The main committee meeting was well attended -- approximately 75 people from the major industrial firms in the United States. Attachs CRMC-MAD-000628 Attachm ent 2 Document No. 13 20 June 1974 TENTATIVE DEFINITIONS a9bestiform - matter structured in the form of asbestos . asbestos - generic term for a number of naturally-occuring mineral fibers^of hydrated silicate that, when crushed or processed separate into flexible fibers-*- made up of fibrils^ (such materials are structured in 'the form of asbestos and are therefore asbestiform-*-) . Minerals included r`under the definition of asbestos are the fibrous varieties of serpentine (chrysotile), riabeckite (crocidolite), cummingtonite (amosite), anthophyllite, tremolite, and actinolite. fiber - for the purpose of this standard, fiber means naturally-occuring mineral fiber-*-. fibrous particulate - for the purpose of this standard, fibrous particulate designates fibers-1, fiber fragments and fiber agglomerates, with a maximum widen ox 3 m cuii a minimum length of 5 m. naturally-occuring mineral fiber - form of mineral characterized by proper ties of flexibility and length-to-width ratio in the order of 100, composed of definite crystal unit cells oriented with respect to a specific axi9. Note 1 - The designated 100:1 aspect ratio is considered to represent a reasonable lower limit for naturally-occuring mineral fibers^-. Fibers*' of these dimensions can be broken into parts of fibers that may maintain their same surface properties and activities. Therefore fiber fragments may have to be evaluated for atmospheric monitoring purposes. However attempting to define a fiber by its aspect ratio alone is inadequate since it is obvious that particles of non-fibrous material do not become fibers as their aspect ratio increases through comminution. FOOTNOTES 1. Definitions of asbestiform, asbestos, fiber, and naturally-occuring mineral fiber, are given in this list. 2. Fibril is defined as single crystal in the form of a fiber in ASTM D2946. 4 c i a A C - M A D - 0 00629 Attachment 3 SUPPLEMENTAL LISTING OF DEFINITIONS APPENDIX 9 Document No. 11 19 April 1974 This listing is a supplement to Document No. 5 published as Appendix 6 of the minutes of the second meeting of the Task Group on Naturally Occuring Inorganic Fibers of ASTM Committee E-34. 1. Definitions submitted by Mr. A. A. Hodgson, Cape Asbestos Fibres Limited, 24 Jan 1974. fibres Fibres are defined as being of a length greater than 5pim and having a length/breath ratio of at least 3:1. There is no upper limit for the length of the fibres, but a maximum diameter of 3ym is defined. Airborne asbestos dust concentrations are expressed in fibers per milliliter of air (f/ml). (taken from the Asbestosis Research Council's Technical Note 1, paragraph 2.1) asbestos - acicular silicate mineral, with a structure based on silicon oxygen tetrahedra, composed of crystals in a predominantly parallel orientation, and distinguished by its ability to split indefinitely from its macro form to individual flexible fibrils having minimum length ` to breath ratio of 3 to 1 and cross sectional dimensions approaching 0.01 urn. 2. Definitions submitted by Mr. G. Gagnon, Lake Asbestos of Quebec Limited, 28 Jan 1974: fibre - any material in a form such that it has a minimum ratio of length to average maximum transverse dimensions of 10 to 1. asbestos fibre - silicate mineral, with a structure based upon silicon oxygen tetrahedra, that fits the definition of a fibre and is composed of single crystals in predominantly parallel orientation. Common usage also designates a collectivity of asbestos fibres as asbestos fibres. 3. Definitions submitted by Dr. M. Grimard, Chief, Heath Effects Division, Environmental Health Directorate, Department of National Health and Welfare of Canada, fibre - (definition as applied to minerals): any material which by micros copy presents the following optical characteristics: a filiform or bundle of filiform bodies having a length to diameter ratio of at least 3:1 asbestos - acicular silicate mineral, with a structure based upon silicon-o: /on *rahedra, that fits the definition of a fiber, and is composed ' single v.tals in predominantly parallel orientation. CRMC-MAD-000630 V - 2 - 4, Definitions submitted by Mr. A- M. Harvey, Manager, Legal and Products Application, r . i . Vanderbilt Company, Inc., 4 Jan 1974: mineral fiber - any form of mineral characterized by properties of flexibility and length to width ratio of at least 100, and composed of definite crystal unit cells oriented with respect to a specific axis. asbestos - is a generic term for a number of hydrated silicate minerals that, when crushed or processed, separate into flexible fibers made up of fibrils. These minerals include chrysotile, crocidolite, axaosite, anlhophyllite asbestos, treraolite asbestos and actinolite asbestos. 5. Definitions submitted by Mr. R. B. Steele, Laboratory Services Engineer, Product Research and Development Department, Asbestos Corporation Limited, 5 March 1974: Fibril - Is a polymeric form of solid whose component repeating sub-units extend along a single major axis, and which can not be subdivided along this longitudinal axis without destroying the integrity of the structure. Fiber - Is possessing of 20. Asbestos morphology a bundle of fibrils in parallel alignment, the composite a maximum diameter of 100 microns, and a minimum aspect ratio Is a generic terra for a number of silicate minerals, the of whose component particles fits the aennition oi a fiber. Asbestos Fiber - Is a fiber belonging to one of the six types of asbestos minerals: crysotile, crocidolite, amosite, anthophyllite asbestos, treraolite asbestos, and actinolite asbestos. 6 . Definitions submitted by Mr. A. A. Harvey, Manager, Legal and Products Application, R. T. Vanderbilt Company, Inc., 30 Jan 1974-; Definitions taken from pages 26, 27 174 and 175 of the 1973 ASTM Glossary: Refer to page 3. 7. Refer to Appendix 5 and 6 of the minutes of the third meeting of the Task Group on Naturally Occuring Inorganic Fibers. 4 CRMC-MAD-000631 57E(/g Attachment 4 APPENDIX 7 Document No. 9 THE DEFINITION OF AN ASBESTOS FIBRE When the United Kingdom Asbestosis Research Council was founded in 1957, its main objective was to carry out research into the causation of the pulmonary fibrosis of the lung known as asbestosis. The existence of protein coated asbestos fibres, known as asbestos bodies, in the lungs of asbestos workers had been known for some consider able time, and it was noticed that such bodies "aged" in the lung, so that the protein envelope disintegrated, releasing the fibre core, which itself often broke up in the process. This breakdown of the asbestos body was considered at the time to play some part in the development of disease. In sampling airborne asbestos, it had been customary up to this time to count all particles, mother, rock and fibres, visible in an optical microscope at 800 to 1000 x magnification. The medical experts had noted, however, that asbestos bodies were only formed on true fibres generally in the length range 10 to 50 microns, and the scientists were asked to provide a sampling and measuring system which would include all fibres within this range. To give adequate cover at both ends of the scale, it was decided to provide counts of all fibres whose length was CRMC-MAD-000632 J JL / between 5 and 100 microns, and it was eventually found that this could best be achieved by collecting on a membrane filter and counting on a phase contrast optical microscope at about 500 x magnification. The development of the method was reported by me at the New York Conference on the Biological Effects of-Asbestos in 1964 and published in the Annals of the New York Academy of Sciences in December, 1965. *' At the time, we were largely concerned with chrysotile asbestos, and it was necessary to give guidance to t h o s e engaged in counting to distinguish between particles of serpentine rock and what could be regarded as fibrous structures. It was found that a suitable convention to .adopt was to regard as a fibre only those particles with a length/diameter ratio (aspect ratio) of at least 3 to 1, but it should be emphasised that this choice was purely arbitrary. The definition of a fibre for counting purposes, therefore, became-- "a particle of length/diameter ratio of at least 3 to 1 and at least 5 microns in length." Later an upper limit of 3 microns was placed on the diameter, because fibres of larger diameter than this were outside the respirable range. A delegation from the U. S. Public Health Service u n d e r Dr. . u. Crallcy visited the Asbcstosis Research I CRMC-MAD-000633 2 / Council in 1963 and were given details of the method, which they subsequently adopted, with minor modifications. In 1970, a meeting of the Asbestosis Subcommittee of the Permanent Commission and International Association on Occupational Health recommended the membrane filter method, fibre definition and all, as the standard method for measuring occupational exposure to airborne asbestos. Modern thinking now believes that asbestos bodies play no part in the asbestos lung diseases, but it is the uncoated fibres which are also present and remain in the lung which are responsible. It is comforting to know, however, that the fibre definition was well chosen, because it has been recently shown that the lung clearance mechanisms can deal with fibres shorter than 5 microns long and definitely cannot deal with those larger than 15 - 25 microns. It must be emphasised that all of the foregoing was concerned with inhalation of asbestos dust and the control of asbestosis and its associated lung cancers. The measuring system was developed before mesothelioma was recognized as an asbestos induced disease. Its relevance e to the question of ingestion of asbestos is extremely doubtful, except that the body clearance mechanisms appear to be able to deal with short fibres and particles, but have diffi u^Ly with the longer fibres. It seems to me to 3 CRMC-MAD-000634 be c pre-requisite to carcinogenesis that the causative agent should remain in the body for a period of time. S. H o l m e s , B . S c . , P h . D . , F. Inst. P. Secretary, Asbestosis Research Council V * 4 CRMC-MAD-00063 5 'frttabhm ent 5 Coarsc-hair content a\ 2 16. f dispute. nuke 1 single ation of the cushmcucashmere as directed in te. make two additional pies and base the den- suit. t fight* in c o n n e c t i o n ihr'rHI%Hit UtiitZing t h e s t a n d a r d f#V-.- ' !i"t1' ',1.' 1.' M Designation: D 294G - 71 T sv-i< a ... . y** ^ 14 *.******* Tentative Definitions of TERMS RELATING TO ASBESTOS FIB ER 1 The*e Tentative D efinitions have been approved hy the sponsoring com m ittee and accepted by ihe Society in accordance iih established procedure*, lo r use pending udoption as Standard. Suggestion fu r revision should be addressed to the So* ttcl> at 1916 Race St.. Philadelphia, Pa. IVIU3. sbestos fiber--acicular silicate mineral, with a structure based upon silicon-bxypen tetrahedra, that fits the definition of,a fiber.' and is composed of single crystals in predomi nantly parallel orientation. Common usage also designates a collectivity of asbestos fi bers as asbestos fiber. bundle--an heavy assemblage of asbestos fibers' in close-packed parallel orientation, which may be partially crushed, and which has a transverse dimension exceeding 8 mm (0.3 in.). cross-fiber--asbestos fiber' that originates from veins or scums in which fibers' are ori ented predominantly at right angles ic th: plane of the vein or seam, crude asbestos--hand-cobbed released from its ore by manual hammer impact cross-vein asbestos in its natural or unfiberi/cd form, rrudincss (krobdincss)--the degree to which an asbestos Tiber' approaches the crude state, crudy (krffodi)--the quality of processed as bestos fiber' with relatively low specific sur face area and degree of Hberization. con taining an appreciable portion of unfiberi/cd agglomerates (derived from the term crude asbestos). ctudy bundle (krobdi)--an heavy assemblage of asbestos fibers' in close-packed parallel orientation, which may be partially crushed, and which has a transverse dimension ex ceeding, 8 mm (0.3 in.). filler--any material in a form such that it has a minimum length to average maximum iiansvcrsc dimension of 10 to I. a maxiinun cross-sectional area of 7.85 x 10'* in.' (5.06 x 10'' min') (corresponding to a circular cross section of 0.010 in. (0.25-1 mm) in diameter) and a maximum trans verse dimension of 0.010 in. (0.254 mm), fiber spicules--rod-like pieces composed of asbestos fibers' in close-packed parallel ori entation, with undisturbed natural relative positions, of sufficient number to imparl rigidity. If dimensions exceed 10 mm (0.4 in.) in length and I mm (0.04 in.) in trans verse dimension, the term pencil may be used. fibril--a single crystal in the form of a fiber.' fines--the Hnest class of material produced by particle size classification of asbestos fiber' by any accepted test method. Common usage in the asbestos industry has defined fine as that whien passed through the lincit mesh used in ASTM Method D 2589, Test for Bauer McNctt Wet Classification of Asbestos Fiber.'- ' loftiness--the measure of an asbestos fiber's' loose specific volume. This is inversely re lated to the dry bulk density, milled asbestos--all grades of asbestos pro duced by the mechanical treatment of as bestos ore. milling--a process by which asbestos ore is treated mechanically to produce grades of asbestos fiber' with desired properties. nonHbrous spicules--acicular particles resem bling assemblages of asbestos fibers' com posed of nonfibrous, or semifibrous min erals such as picrolite. 'These d efinitions are under the jurisdiction o f A S T M Comnntt*'* W .'.'.'ykr. S``v; . .ind Ih yif C\nvi* p o n e *. 1 h i\ le n u tu e in the direct rcsponvibilitv ot Sub* com m ittee U JO.U5 on AsbeMuv and N j i u r j l l ) O ccurring Fif*cr v b lie c liv c Jan. S, 1971. ; l\T in .tn tn > fur the terms fiber and asbestos fiber arc included in this jit. ` Annual Hook o / A S T k t Standards, Part 25. . 585 CRMC-MAD-000636 "i-1* *^7*v r'TT''*'*tv ,*;1 -g.VTtT ^.Tr 'v*.r**"rv rr'i|raT.H*' .(, 'rffP ',yi*y.*-' s.m iirw w ^ ."ly i'.s* -**^1 *.i ts Attachm ent 6 Definition of Asbestos Asbestos: "Asbestos" is a generic tern for a number of hydrated silicate minerals that, when crushed or processed separate into flexible fibers made up of fibrils. Minerals included in the definition of asbestos are chrysotile, crocidolite, amosite, anthophyllite asbestos, trenolite asbestos and actinolitc asbestos. A mineral fiber is any form of mineral characterized by proper ties of flexibility and length to width ratio of at least 100, and composed of definite crystal unit cells oriented with respect to a specific axis. Note: The designated 100:1 aspect ratio is considered to represent a reasonable lower limit for naturally occurring mineral fibers. This is not to say that fibers of these dimensions cannot be broken down into parts of fibers which could maintain their same surface properties and activities, and there fore conceivably be as biologically active as the parent material. However, attempting to define a fiber by its aspect ratio alone is inadequate, since it is obvious that particles of non-fibrous material do not become fibers as their aspect ratio increases through processing. 4 CRMC-MAD-000637 A tta c h m e n t 6A DEFINITIONS Task Group on Naturally Occuring Inorganic Fibers ASTM Committee E-34 fiber - any material in a form such that it has a miniram ratio of length to average maximum transverse dimension of 10 to 1, a maximum cross-sectional area of 5.06 x 10"^ mm^ (7*85 x 10"5 iru^) {corresponding to a circular cross section of 0.254- mm (0.010 jn.) in diameter] and a maximum transverse dimension of 0.254 mm (0.010 in.) asbestos fiber - acicular silicate mineral, with a structure based upon silicon-oxygen tetraheda, that fits the defi nition of a fibre, and is composed of single crystals in predominantly parallel orientation. Common usage also designates a collectivity of asbestos fibers as asbestos fibre. i c r m c -Ma d '000638 Attachm ent 7 Naturally Occurring Inorganic Fibers APPENDIX 6 Definition: A naturally occurring inorganic mineral fiber is any form of mineral characterized by properties of fle x ib ility and length to width ratio of at least 100, and composed of definite crystal unit cells oriented with respect to a specific a x is . Note: The designated 100:1 a sp e c t ratio is considered to represent a reasonable lower limit for naturally occurring mineral fibers. This is not to say that fibers of these dim ensions cannot be broken down into parts of fibers which could maintain their same surface properties and activities, and there fore conceivably be as biologically active as the parent material. However, attempting to define a fiber by its aspect ratio alone is inadequate, since it is obvious that particles of non-fibrous material do not become fibers as their aspect ration increases through processing. CRMC-MAD -000639 Attachm ent 9 APPENDIX I ATTENDANCE Third meeting of the Task Group on Naturally Occuring Inorganic Fibers, Philadelphia, Pa. 18 and 19 April 1974 W. H. Ashton M, Cossette L. M. Fenner G . J . F oy A. h. Harvey S . Holmes H. H. Kaufman A. M. Kooiman J. P. Martonik R. McCarthy P. W. McDaniel R. H. Mereness P. V. Pelnar, M.D. C. S. Thompson A. A. Winer - Johnson & Johnson Co. - Recording Secretary - Quebec Asbestos Mining Association - Vice- Chairman', Johns-Manville - Department of Natural Resources of Quebec - R. T. Vanderbilt Co. Secretary of the Asbestosis Research Council T.B.A. Industrial Products Limited - GAF Corporation - Representative of the Editorial Subcommittee - Motor Vehicle Manufacturers' Association - MESA, Department of tho Interior Washington D.C. - International Talc - Union Carbide Corporation - Asbestos Information Association/North America - Institute of Occupational and Environmental Health - R. T. Vanderbilt Company. - Chairman, Department of Energy, Mines and Resources of Canada Dr. J. W. Axelson Dr. E. Berry R. A. Bramley-Moore W. R. Cooling H. A. Eschenbach P. A. Filteau G. Gagnon G. W. Gibbs Dr. M. Grimarr MAILING LIST - Johns-Manville Research and Development Center - Department of Materials Chemistry - Chrysotile Corporation of Australia Pty. Ltd. - Asbestos Corporation Limited" - Industrial Hygienist W. R. Grace & Co. - Quebec Asbestos Mining Association - Assistant Mill Superintendent Lake Asbestos of Quebec Limited - McGill University Department of Epidemiology and Health - Department of National Health and Welfare of Canada CRMC-MAD-000640 MAILING LIST (suite) A. Goodwin A. A. Hodgson Dr. R. A. Kuntze Dr. J. Lepoutre, M.D, B. Lincoln C . G . Morgan K. Morgareidge T. D. Oulton L. C. Piuze K. Q. Scowcroft VJ. H. Smith R. B. Steele C. E. Stiefken E. T. Trigiea - Head, Health Division - Cape Asbestos Fibers Limited - Ontario Research Foundation Eternit S. A. - Turner Newall Fibre Laboratory - North American Asbestos Corporation - Food and Drug Research Laboratories, Inc. - Research Associate, Minerals & Chemicals Division - Lake Asbestos of Quebec Limited - Asbestos Textile Institute - Bell Asbestos Mines Limited - Asbestos Corporation Limited - American and Refining Co.. Ltd. - Engelhard Chemical & Mineral Industries I CRMC-MAD-000641 Attachm ent 8 FjcS' PROPOSAL FOR THt FORMATION OF A SUBCOMMITTEE ON NATURALLY-OCCURING INORGANIC FIBERS PURPOSES: To study the OSHA document on asbestos (?3 209510) Critiria for a Recommended Star.daro/Occupational Exposure to Asbestos. The regulations contained therein are based upon data the value of which is being increa singly questioned and criticiseo, ana upon a method of test that gives unacceptable interlaboratory reproducibility. To gather new data, and to re-asses the presently available data critically for the purpose of recommending more valid threshold limit values. To define each type of asbestos, or other naturally occuring fibers exactly, and to asses the data relating to each type with a view to proposing valid regulations for each type. To apply statistical techniques to determine appropriate sampling strategy, to determine probable sampling error, to measure single operator repro ducibility and inter-laboratory precision. To define more precisely the type of optical microscope used for maxing fibre counts, and the conditions under which such counts are determined to ensure reliable results. To develop quantitative analytical methods for tho analysis of specimens colleted on filter membranes to replace unreliable fiber counts. SCOPE Responsible for the gathering and assesment of scientific data, development of statistical-sampling methods, evaluation of the presision of existing methods, development of valid test methods, specifications,recommended practices, nomenclature, classification, stimulation of research and investigation of naturally occuring inorganic fibers, in direct collabora tion with each of the other competent Subcommittees. 4 CRAiC-MAD-000642 U.s. DEPARTM ENT OF LA . )R Occupational Safety and Health Administration WASHINGTON, D.C. 20210 Office of the Assistant Secretary August 6, 1974 Hr. H. B. Vanderbilt President. . . R. T. Vanderbilt Company, Inc. 30 Winfield Street Norwalk, Connecticut 06855 t Dear Mr. Vanderbilt: Your request for an interpretation of the asbestos standard, section 1915.93a, as it related to treraollte talc has been given deep consideration. The following interpretation of the standard, 1910.93a, is*collectively the opinions'of both the Occupational Safety and Health Administration and the National Institute for Occupational Safety and Health. The present asbestos standard is written for the purpose of controlling exposures to the fibrous or asbestiform minerals commonly considered to be asbestos. This is reflected in the established permissible limit for asbestos air contamination to which a worker may be exposed. This is expressed in terms of numbers of fibers in excess of a pre scribed length per unit of volume. The required method of determination or analysis is also expressed as a method for counting fibers. Therefore, nonfibrous or non-asbestiform minerals such as non-asbestiform tremolite are not within the scope of the existing standard. Talc containing only non-asbestiform tremolite is not regulated by the standard 1910.93a. For emphasis, if only talc and non-fibrous tremolite are present, there is no violation of the asbestos standard. Talc containing asbestiform tremolite or other fibrous asbestos minerals will be regulated by the standard 1910.93a. CRMC-MAD-000643 E. M. Fenner - 4N S. Spell - R&D January 15, 1974 TASK GROUP ON NATURALLY OCCURRING INORGANIC FIBERS ASTM COMMITTEE B-34 Your note of January 11, 1974 You are correct that this la the present ASTM definition. Attached ia a copy o f the page in the ASTM book giving these definitions. As a natter of fact, the fiber defi nition is the one that I suggested that Vanderbilt try to get accepted in their proposal to the FDA/Bureau of Mines. As a matter of Information, the definition of asbestos fiber is a good commercial definition, but could lead to serious problems of interpretation. For example, if a microscopist looks at a talc sample and attempts to "count" tremolite fibers what ha is oounting normally is individual crystals. The tremolite "fibers* are not "composed of sin gle crystAls in predominantly parallel orientation"r there fore, these tremolite particles would not be classed as asbestos fiber under the proposed definition. Under the proposed definition Z doubt whether we could even classify many of the crocidolite particles in the UICC sam ple as asbestos fiber. Finally, if we were to look at a we 11-dispersed field of chrysotile fibrils, obviously each fibril would not be an asbestos fiber because it is one single crystal but not an assemblage of crystals in predo minantly parallel orientation. While the Intent of this definition is excellent in that under it much of the matter, for example in Duluth water, might not be classed^as asbestos fiber because it comes from the cleavage of a rock during grinding, the microsaopist examining the sample would be put to a difficult task under some circumstances to determine whether the individual cry stals that he sees in the microscope field were produced by breaking up a basically massive material or whether they came from separating crystals whioh originally existed as an assemblage of "single crystals in predominantly parallel orientation". I hops ' haven't confused you by the facts. I am in favor of sue a >flnition, but I foresee difficulties in its interpre ation . r aicrosoopic studies. CRMC-MAD-000644 2/31 Johns-Manville Internal Correspondence To F. J. Solon, Jr. Date: N o v e m b e r 30, 1973 From; E. M. F e n n e r t~uples; 1 ^ mr nx- Subject ASTM COMMITTEE E - 3 4 The reorganization of this Committee took place in Houston, Texas, W e d n e s d a y and Thursday, N o v e m b e r 28 and 29. I t i s c a l l e d t h e C o m m i t t e e on Occupational Health and Safety Aspects of Materials, Physical and Biological Agents. Its main purpose is to write consensus standards that will be approved by the main body of ASTM and forwarded to the Occupational Safety and Health Administration for reissuance or incorporation in OSHA Occupational Standards. The Committee is subdivided into working Subcommittees in two categories. The first category, which are called.Task Force Groups rather than Subcommittees, are charged with the responsibility for writing the standard on a specific material or process. A list of the Task Force Groups is appended to this report. At the meeting in Houston, I was elected Vice-Chairman of the Task Group on Naturally Occurring Inorganic Fibers, whose main job will be to write standards for asbestos and talc. A list of the attendees at our Task Force meeting is appended. In addition to the Task Groups there are Subcommittees comprised of experts in specific areas. The function of the Subcommittees is to assist the Task Groups in writing those portions of the document in which they have expertise and later reviewing the initial and final drafts of these portions of the standards. A list of the Subcommittees is a t t ached. I am a m e m b e r of C o m m i t t e e 34.'40 (Engin e e r i n g Controls). The main committee meeting was well attended -- approximately 75 people from the major industrial firms in the United States. Attachs. CRMC-MAD-000645 E-34 Agenda , Page 2 t ' Wednesday - November 28, 1973 (Continued) 1;30 - 5:00 PM ^Tosl^Forc^Meetings (The following T.F.'s will meet concurrently) Methyl Ethyl Ketone - Sol Levine Styrene Monomer - Bernard Gra) ji.s Stoddard Solvent - Homer Cole Carbon Disulfide - Grover Wrenn Hydrogen Sulfide - John W. Miller Naturally Occuring Inorganic Fibers - A. A. Winer Acetone Carbon Bisulfide Acrylonitrile Methyl Cellosolve Phthalic Anhydride Ozone Nickel Carbonyl Zinc Chromate 3:00 - 5:30 PM Chairmen of Subcommittees available for questions and discussion. Thursday - November 29, 1973 8:00 AM Registration 9:00 - 12:00 AM Subcommittee Meetings E34.10 - Definitions and Nomenclature - Henry M. Kissman E34.20 - Medical - Ernest Dixon E34.30 - Control - C. W. Schultz E34.40 - Toxicology - James McNerney E34.60 - Safety - Darwin E. Rhoads CRMC-MAD-000646 B -3 4 A nem ia 3 Tlnii'i;il:iy - NovcmlH* J>73 (Continued) K34.70 - Data Collection - A. M. Kooiman E34.91 - Liaison 12:00 - 1:30 PM 1:30 - 4:00 PM E34.92 - Editorial - Fred M. Oberlnder LUNCHEON E-34 Main Committee 1. Reports 1.1 Executive Subcommittee 1.2 Task Force 1.3 Subcommittees 2. Discussion 3. New Business 4. Next Meeting 5. Adjournment CRMC-MAD-000647 TASK GROUP ON NATURALLY OCCURRING INORGANIC FIBERS Dr. A. A. W i n e r , C h a i r m a n Department of Energy, Mines & Resources of Canada Mining Processing Division Ottawa, Ontario, Canada E. M. Fenner, Vice-Chairman Johns-Manville Corp. Denver, CO 80217 Marcel Cossette, Recording Secretary QAMA Testing Research Laboratories University of Sherbrooke Sherbrooke, PQ, Canada G. J. F o y Department of National Resources of Quebec Quebec, PQ, Canada G. G a g n o n Lake Asbestos of Quebec Black Lake, PQ, Canada Limited A. M. H a r v e y R. T. V a n d e r b i l t Co. E a s t N o r f o l k , Conn.. H. A. Hoffman Assistant Director Building Materials GAF Corporation South Bound Brook, of Quality Divisions N.J. Control Kenneth Morgar.eidge Food and Drug Research Waverly, N . Y . Laboratories, Inc. T. D. O u l t o n Englehard Chemical Edison, N.J. and Mineral Industries .000648 c r m c -m m > Ji>l-'ooimo-u'lanv:;k' [t' 'r' o ! Ml P LO l* u h l< & V Lv.y. To: J * E. C o n n e r 2-04 D illo : O c t o b e r 1, 1976 from: J * W. A x e l s o n - R & D C o p ie s : D. P o u t i a t i n e - 2-04 J. F. R e i s 2-04 W. C. S t r e i b - RfiD W. J. P l i c h t a -- R & D Subject: A M E R I C A N M I N I N G C O N G R E S S PAPER ENTITLED "AS3EST0S IN YOUR FUTURE" T h i s p a p e r w a s p r e s e n t e d b y C. S. "Slim" T h o m p s o n , M a n a g e r , C e r a m i c s , P a p e r a n d S p e c i a l t i e s R&D, R. T. V a n d e r b i l t , Inc., Norwalk, Connecticu , at a Safety and Health Session. He started his pres s tation with a statement that regulatory agencies are creating asbestos where it never was before. This includes products, mine wastes and other areas that are not related to the asbestos industry. A table was shown which had been made up by Mr. Thompson and shows the normal six varities of asbestos as asbestiform materials and a number of other non-asbestiform materials some of which had the same name but were not asbestos by his definition. These included antigorite, lizordite, riebechite, cuminglonite, gunerite and anthophyllite, tremolite and actinolite. The history of the various promulgations and regulations by EPA, OSHA, and MESA was given in chronological sequence. The aspect ratio was set at 3/1 and EPA regulations covered anything containing asbestos. With prodding from the talc industry, the Bureau of Mines h a d a s y m p o s i u m o n talc w i t h a b o u t 50 p e o p l e attending. From this the Bureau of Mines only included asbestiform materials in their thinking. OSHA issued a memorandum listing five criteria for fiber identification including that it has to be of a fibrous nature and with the ultimate size being a fibril rather than cleavage particles. EPA set a 1 percent level on the maximum allowable quantity of asbestos in a material before it has to be handled like asbestos, and MESA followed OSHA's lead. H owever, o n O c t o b e r 9, 1975, O S H A w e n t b a c k to its o r i g i n a l definitions and negated the memorandum. EPA has included Wollastonite in its effluent discharge requirements. And, CRMC-MAD-000649 2/SI Johns-Manvitle Interna! ^vfIiti pondenc To: R. P. C a r t e r 4N Onte: J u l y 18, 1975 From: J. P. L e i n e w e b e r - R&D Copies: Se e R e v e r s e Side Subject: R . T . VANDERBILT PRESENTATION TO OSHA As I m e ntioned in our telephone conversation, there are s e v e r a l p o i n t s in the R. T. V a n d e r b i l t p r e s e n t a t i o n w h i c h require clarification, particularly to NIOSH and OSHA offi cials, First, a nd foremost, is the i m p l i c a t i o n tha t our reporting of chrysotile in the Vanderbilt products was in error. This was reported only after very careful analysis and confirmation by several techniques. There is no doubt in my mind that the results are accurate and valid for the particular sample we examined. It must be recognized that the amount of any mineral in such a product can vary con siderably from lot to lot, but it is a well known fact that chrysotile does occur in the Groveneur deposit. It is also somewhat surprising that the chrysotile was not detected by McCrone Associates. It would be worthwhile for us to have McCrone analyse the sample in which we found a high concentration o f .chrysotile. Any samples sent for this purpose should be "blind", with the request for the type and amount of any asbestiform minerals present. The comment that J-M ..."would use the outdated and inadequate definition of a fiber..." is totally unjustified. For pro b lems of this type we use the definitions in the OSHA regula tions and the supporting N I O S H criteria documents. There is no other definition to be considered for analyses to determine compliance with the OSHA regulations. In this same context the regulations limit the number of asbestiform fibers per cc in the w o r k i n g e n v i r o n m e n t . The c o m m e n t on P a g e 5, r e g a r d i n g the state of the art of analysis of a s bestos fiber in talc is completely irrelevant. F i n a l l y , t hey use the r e s u l t s o b t a i n e d by Dr. W. E. S m i t h to indicate that tremolitic talc is not biologically active. At a meeting of the IOEH in Montreal last year, it was determined that this particular sample did not contain sufficient fiberous tremolite to yield conclusive results. Johns-Manviiie To. P. Kotin Inter,n a lC o rre s p o n d e n e Dt: January 2, 1975 Fr0>TV H. R. Keefe copie.: L isted Below Subject: T a l c a n d A s b e s t o s Attached is a letter we recently received from the National Paint and Coating Association. This letter has been sent to all members of this Association. Please note Page 3 under Recommendations. We feel quite confident that R. T. Vanderbilt Company,will certify that their talc does not contain asbestos per thisparagraph. A speedy resolution of the confusion caused by OSHA and their definition of a fiber is necessary so that me might have answers concerning our talc for our customers. H arry R. Keefe HRK:ccr Attachment cc: P. A. Martinson H. Kranich A. C. F. Finkbiner CRMC-MAD-000651 ooo r\pc NATIONAL PAINTS C O A T IN G S A S S O C IA T IO N IMO RltoO Ulon4 WMMftffM, D.C ToloohOM lot M IT I N o. 20 December 5, 1974 TALC AND THE OSHA ASBESTOS STANDARD 1910.93a BOUTE TO: runMt '' AdmMiUttlOn , Stitt Ttehnleal P/odueilon-l 'H . 55 * irjr V' h I ________ ____________________ Executive Synopsis_________________ _______. I The OSHA Asbestos Regulation 1910i93a includes, in its definition of asbestos, a mineral form (tremolite) that is found in some talcs, but is not generally considered an asbestiform material (see Safety and Health Bulletin N o. 15, "Asbestos Handling Guidelines" dated October 30, 1973). Through the extensive efforts of several NPCA members, a clarification of the regulation .was obtained from OSHA. This now allows talc manufacturers to certify their material is "asbestos free" and the'user of that talc is then exempt from regulation under 1910.93a. ACTION REQUIRED BY YOU - Forward this Bulletin to the person or persons responsible fc- your safety and health operations. $! . ACTION TAKEN BY NPCA - Through the efforts of NPCA members and the Occupational 9 Health Task Force a clarification of the standard was accomplished. OPERATIONS AFFECTED IN YOUR COM PANY- Manufacturing, safety and health. STAFF CONTACT AT NPCA - Richard W . Murry, Assistant Technical Director CRMC-MAD-000652 Page 2 BACKGROUND With the promulgation of the asbestos Standard 1910.93a in July 1972 the possibility of certain talc materials being regulated as asbestos was created. According to the regulation, asbestos is defined as the following mineral forms: chrysotile, amosite, crocidolite, tremolite, anthophyllite, and actinolite. While some talcs are indeed marketed as containing asbestiform minerals and noted for their fibrous properties, the standard also encompassed other talcs not previously considered to be fibrous or considered to contain asbestiform materials. These are the tremolite (or more correctly non-asbestiform tremolite) containing talcs. Since late 1972 the R. T. Vanderbilt Company Inc, and the International Talc Company (later purchased by Vanderbilt) have had numerous meetings with OSHA officials to obtain a clarification on the regulation of the talcs under 1910.93a. RECENT DEVELOPMENTS On October 9, 1974 in a letter toM r. H. B. Vanderbilt, President of R. T. Vanderbilt Company, Inc., M r. John Stender, Assistant Secretary of Labor, stated in part: i " . . . i f you (the talc manufacturer) have scientific evidence that the naturally occuring talcs, prior to processing by milling or crushing, do not contain fibrous or asbestiform tremolite, anthophyllite, actinolite or other asbestiform minerals, you may certify to your customers that the talc does not contain asbestos." (A copy of the letter is attached to this bulletin.) Also a directive to such effect has been issued to OSHA field personnel as a guide in making inspections. This directive indicates that if a talc user,L e ., a paint and coatings manufacturer, is monitored for asbestos the person behind the microscope counting fibers should use the following identification criteria: A . Particles must appear to be fibrous rather than as crystals or slivers. B. The maximum diameter of a fiber to be counted is 3 microns. C . The maximum length of a fiber to be counted is 30 microns. D. The length to width ratio must be 5 or more to 1, that is, 5 times or more longer than wide. E. The separate or individual fibers must contain fibrils or the "bundle of sticks" effect, unless they are at a nondivisible stage. A fibril cannot be subdivided and would be coun'i ' if it meets the other criteria. The electron microscope may be used to p ove ttw fibrous nature of the particles. The'length to width ratio of 5 or mo . tn 1 i s * ' - a n t to imply that other particles are not hazardous. CRMC-MAD-000653 The directive further states that if the talc is of the non-asbestlform or non-fibrous variety the time weighted average (TWA) of 20 millions of particles per cu b iefo o t of a ir (mppcf) w ill be used. If monitoring of your operations using talc is done by the 0 5 H A inspector you should retain a sample of the talc material being used in the event a discrepancy may arise. R E C O M M E N D A T IO N If you have been using talc products that have been questionable regarding asbestos fin content, request certification from the manufacturer that they do not contain asbestos. |}l Retain this certification to show to an OSHA inspector if he questions the asbestos content of the ta lc . If It is however?determInedthat a toIc:d6es?contain true asbestlform minerals, that material w ill not be certified and 1s>subject to the provisions of the regulation,' CRMC-MAD-000654 U.S. DEPARTMENT OF LABOR Occupational Safety and Health Administration WASHINGTON, D,C, 302JO Office of the Assistant Secretary OCT 9 1974 Mr. H . B . Vanderbilt President Chief Executive Officer R, T. Vanderbilt Company, Inc. . -30 Winfield Street Norwalk, Connecticut 08855 ` .Dear Mr. Vanderbilt: This is in .reply to your letter ;of September >'26, concerning .your .request.for relief from the asbestos.standard;for.yourtalcs containing.non-fibrous tremolite; actinolite; and anthophylllte. My letter of August 6 stated thatnon-fibrous or non-asbostiforra minerals such.as non-asbestiform tremolite are not within.the 8cope of the asbestos standard and, therefore, the provisions of that standard do not apply to talc containing non-asbestiform minerals. 0 NIOSH .is:currently.conducting a thorough.Investigation into .the ;exact minerals .to.which'talc workers were exposed'In :those studies where.asbestosls or other adverse medical.effects were.found. ' Pending the.receipt and evaluation by OSHA ;of-the.report by; NIOSH on this investigation, ;if you h a v e !scientific .evidence that the 'naturally.occuring;talcs,-prior to'processing-by milling'or crushing, do not contain fibrous or asbestlform tremolite, anthophylllte, actinolite or other asbestlform minerals; you may .certify to your customers .that the talc does not contain asbestos. Fibrous, asbestlform minerals such as fibrous tremolite means naturally occurring asbestlform minerals which p r ior.to or after crushing and processing, contain fibers made up ;of fibrils. as8iscan' secretary ox ;,aoor CRMC-MAD-000655 U.S. D EPA RTM EN T OF LABOR Ucaipation.il Safety am! Health Administration WASHINGTON, O.C. 20210 Ollicc of die Assistant Secretary I 3 JAM 1975 Paul Kotin, M.D. Vice President H ealth* S a fe ty and Environm ent Johns-Manvi11e Corporation Greenwood Plaza Denver, Colorado 80217 Dear Dr. Kotin: This is in reply to your letters of December 17 and 19, 1974 regarding our Field Information Memorandum 74-92 of November 21, 1974. You asked for further clarification and guidance and requested to meet with us to discuss the matter. Our purpose in preparing the Field Information Memorandum was to provide guidance in distinguishing between fibrous and nonfibrous talc or tremolite. Here are our comments to your observations: 2C Fiber length - We agree that fibers up to 200 micrometers in length should be counted, providing the diameter is not more than 3 micrometers. 2D The standard does not address length to width ratio. Five or more to one, length to width ratio is an arbitrary matter of convenience in counting to distinguish siivers or crystals from fibers. The three to one ratio provides some additional difficulty in distinguishing fibrous from non-fibrous. Again, length to width ratio and diameter are not in the present standard. Minimum length is stated in the standard as 5 micrometers. We see no need to change the standard because of Field Information Memorandum 74-92 of November 21, 1974. CRMC-MAD-000656 2 2E The "bundle of sticks" effect is mentioned in the literature as a distinguishing characteristic of fibrous minerals, as compared with very fine fibrous glass, for example. It can be seen under phase contrast microscopes with 400 X magnification, according to our laboratory in Salt Lake City. Only in cases where further proof 1s needed would electron microscopy be used. This advice was given to the Occupational Safety and Health Administration (OSHA) field offices and labora tory. Field Information Memoranda are available to the public, but are primarily for guidance to OSHA staff. You are under no requirement to use electron microscopy, nor are your customers. OSHA reserves the right to use it to prove that a mineral 1s fibrous or non-fibrous. The asbestos standard is being studied for possible revision. Your comments will be considered in revising the standard at a later date. Please arrange to meet with Dr. Daniel Boyd, Mr. John P. O'Neill, Mr. Harry Gilbert, Mr. Ray^McClure*, Mr. Richard' Wilson, and Mr. Howard Schulte, DeputyHAssistant Secretarj/ of" Labor, on this matter. You may contact Mr. Schulte, area code 202-961-2144, for the time and place. Sincerely, i J f / L . jyLJu-h- Tohn H. Stender Assistant Secretary of Labor CRMC-MAD-000657 r .kttachod if; copy of their January 2, 1975 letters addressed to a customer and copy they attach of Stender October 9, 197 4 t1- letter. Those copies were secured by our Houston Area i Manager, -Frank Buck, from a Vanderbilt customer. The distri bution of this letter is confirmed as I had the same letter V read to me over the phone from another source. ! You vrill observe the 1st paragraph "hanging" phrase "we hereby certify the following grades of talc". They certify nothing except by inference to Stender letter. By this inference, they certify from Stender: -4th paragraph i *f ^ - -- . _ -- .}. --J. *> H T i .3 vI*!I t *? *A V v* *'r> 1 i1' r* vs I mention of having "scientific evidence". This latest action makes it imperative we have a "position" response agreed upon to explain our Deser.talc label. Not a rebuttal to Vanderbilt, but a factual statement to effect our talc contains tremolite. Tremolite is asbestos according to 1910.93a and until true clarification made, we will conform to the "law of the land", etc. I R. 3. Lamar R. P. Carter-41- V!. C. Streib D/C * ;<!fr X CRMC-MAD-000658 R . T. V A N D E R B IL.1 C O M P'A N V . !N C j o wiN *ic i. d f>i u n 1 NOf'WA!.K , C''th LC 'ICU r January 2 , 1975 '.AM I t '* M i.' U~ t.* , .,>.# C f fC5>* *w ; M U*0 t/O 1/ **b|- Gent! emori: Effective January 2, 1975, in accordance with procedures laid down by tbs Occupational Safety and Health Administration of the IG S . Department of Labor in a letter of October 9, 1974, to the R. T. Vanderbilt Company, Inc. (copy attached), we hereby certify the following grades of talc: NYTAL 99 NYTAL 100 NYTAL 100HR NYTa L 2Gu NYTAL 300 NYTAL 400 X 3X " 151A 5X FT MSK 325 425 10A 10AC HDT 1R 1C Please keep this certification with your permanent records, if you are inspected by OSHA, please show the inspector this letter, if he questions any of the above products. Very truly yours, R. T. VANDERBILT C O M P A N Y , IN C . HWH:ld one Harry Vr. Howard, Sales Manager Paint and Paper Deportment CRMC-MAD-000659 Thf r*eowr*fidt4 f<r , e cfeur *" urn" tM Umm! te U' K w m- on r** gun-ont* 0 rmull to t* otiiiin) R . T . V A N D E R B I L T C O M R A N T. I N C . 3 0 WIN r u t t o STNf . T, -f NORWALK. C O M N O C NC.U1 Jenanry 2, J.97S AMI f*ii i . t <i' . C.*"># V't* # e ^ r. ,, (hl, 1 Gentlemen: In the course of our assuming the Ine; .non oi the International Talc C omnany, w o win. continue, tv mackm. five fibrous (aebestiforni) type ta.leu previously mippl.i'vl by them, namely: 1. Fiber #1 2. F i b e r #2 3. Mou3dono 4. OK F i b e r 5. P L F i b e r Vie intend to 'label b a y s coni:n.i.iny theue p r o d u c t w i t h un Asbeo to;-; CAUTI Ob Label an follows: CAUTION PRODUCT C O U T A TNG A S B E S T O S -FXBEltK. A V O I D CREAT INO DUST, BREATHING ASBESTOS DUST RAY (MUSE SERIOUS BODILY HAEM. A n y o u k n o w , th < w h ic h M ake th -m mineral f i b e r p r u d e n t i n d im t r i. u U y u o e fu l., a r e in th e n g ra d e s , the* a a b o s t i f o r m v a r.u t ( ,| ( 11r >,,i m i n e r a l * n o r m a l l y c o n t a i n e d i n e o r n m e r o La i ' . I - a n ! o e n .e q u o n u .y ifl.ll t h e ( IAEA A; )a <.;! El a m l a r d , u n d e r S e c t io n 1 9 1 0 .9 3 a # Vv ry tr u .1y y o u r n , HW!2: I'I . Harry l. Howard, Galea Mgr. Paint b Paper Department CRMC-MAD-000660 nf**-'*mili a ,f>t.> S I,I,,i*> I 'I V./,M If n ' I II I'M' K rt . Tron idon Chini: K.-vrative Officer R. T. Vanderbilt Ov:yeny, Inc TO Vii.iui c. " (, n ! : r , o u O'J.k, (0 o L1ci:t 08835 J.v.-ir Or, Vmidt a 2y l:o your letter of September 26, concerning your requern: Tor relief from the asbestos standard for your talcs containing nen-fibrous tremolxte, actinolitc, and anthophyllite. My let to? of August 6 stated that non-fibrous or non-asbestlform r.inej .iis such as no*.i-asbestifera trnmolite arc .not within the m-o;,'.- of tua asbestos standard and, therefore, the pr..visions of that standard do not apply to talc containing non-asbestifora minerals. IVIOhH is currently conducting a thorough investigation into the c-ract minerals, to which talc workers were exposed in those todies whore' asbestos is or other adverse medical effects were found Pending the receipt and evaluation by OSBA of the 'report by NIOSH on this investigation, if you have scientific evidence that the naturally oscurino, talcs, prior to processing by milling or crushing, do not contain fibrous or asbestltora trisnolite, anthophyllite, actinolitc or other asbestiforn minerals, you p may certify to your customers that the talc does not contain |\ asbestos. Fibrous, anbestifoim minerals such as fibrous trcmollte means naturally occurring asbestiforro minerals which prior to or after crushing and processing, contain fibers made up of fibrils. John H . S ton V r 'Assistant 8 c*. ''tarv of Labor CRMC-MAD-000661 ' ** R. S. L a m a r J a n u a r y 20, 1U75 Ml 11. R. K e e f e P. A. Mart.i n;:on, W. C. Streib, F. Y o u r L e t t e r J a n u a r y 7, 1975 Talc and /Asbestos I am aware that the National Paint and Coatings Association carries no legal weight. Their bulletin, however, will cause us marketing problems which are o b v i o u s . Concerning the talc label, we have no objection with a label for talc. It's the asbestos label which causes our problem. Stender's letters and the more recent letter from OSHA to its area personnel, in my opinion, attempts to remove tremolite in talc from the OSHA asbestos regulation. J-M Research and Medical Department, on the other hand, appear to be adamant .in m a k i n g sure t r e m o l i t e is c o n s i d e r e d as a s b e s t o s . I d o n 't h a p p e n to b e as c o n v i n c e d t h a t t r e m o l i t e as f o u n d in our talc is as dangerous as other forms of asbestos. We estimate that as label, we have lost expect even further a result of our labeling with the asbestos 30 to 40 p e r c e n t of our talc tonnage. We erosion of business. C o n c e r n i n g c o n t a c t w i t h R. T. V a n d e r b i l t a n d / o r OSHA, F & M has nothing to say concerning disclosing the data you have. This decision was to be made by Legal, Medical, and Research. The last meeting I attended concerning contact with Vanderbilt a n d / o r O S H A w a s at the R e s e a r c h C e n t e r O c t o b e r 8, a n d it w a s my opinion Research was to put together the information you have and go to Washington, to see Stender. I don't know who cancelled this plan, but it wasn't F&M. i-- K e e f e 'iIIV :ccr 1 John8-Manvi!le Corporation Qroenwood Plaira Denver, Colorado 80217 Health. Safety 4 Environment Department F e b r u a r y .10, 19 75 Mr. W. H. Mo r t o n s o n , M a n a g e r Manufacturing & Technical Service Flintkote Building Products Group Flooring & Industrial Products Div. 480 Central Ave. East Rutherford, N.J. 07073 * Dear Bill : I h a v e r e c e i v e d y o u r l e t t e r o f F e b r u a r y 5, r e g a r d i n g the recent OSHA Field Information Memorandum #74-92 on tremolite and talc. Our i n t e r p r e t a t i o n of this O S H A M e m o r a n d u m is that it relates solely to talc and asbestiform minerals found in talc. With that interpretation in mind, I have answered W. J. D i c k e n s o n ' s s p e c i f i c q u e s t i o n s in his l e t t e r of J a n u a r y 31, 1975. (a) The 30 m i c r o n top l i m i t for fiber length app l i e s to any a s b e s t i f o r m fiber f o und in talc.' (b) Yes - u n l e s s f u r t h e r e x a m i n a t i o n b y e l e c t r o n m i c r o s c o p y determined that the particle was truly fibrous or asbestiform. (c) No - This asp e c t r a t i o a p p l i e s o n l y to a s b e s t i f o r m fibers found in talc. (d) T h e o v e r 5 - m i c r o n m i n i m u m leng t h used in the a s b e s t o s standard applies here. Part 1 - Yes - for asbestos fiber determination. I assume the 1910.93a standard would apply to fibrous tremolite other than that found in talc. Part 2 - Yes - to determine quantity of asbestiform or fibrous tremolite in talc. However, the aspect (length to d i a m e t e r HwidthJ ) r a tio m u s t be 5 o r m o r e to 1. T) a 3 to 1 a s p e c t ratio does not apply in this situation. CRMC-MAD-000663 Mr. W. H. M o r t o n s o n Page 2 February 10, 1975 Part 3 - No - not if counting asbestiform particles in talc. The OSHA L a b o r a t o r y m a y do this b u t it is n o t necessary for talc users or producers. Fart s - Yes - but not gravimetric - microscopic light field count only. Mr. Dickenson also poses three questions in the last three paragraphs of his letter. I have answered these also. Mr. Dickenson questions gravimetric vs. i m p i n g er/microscopic light field determination. By OSHA definition, talc concentrations must be sampled by impinger and counted by light field microscopy. However, OSHA utilizes respirable mass (size-selective gravimetric) for most other mineral dusts, particularly silica. M i d g e t impi n g e r - No, the m i d g e t impinger is not the same unit as Mine Safety Appliances gravimetric sampling kit. The midget impinger is a small version of the Greenburg-Smith impinger that has been used for many years for particulate dust sampling. The M S A kit referred to is the size-selective gravimetric sampler I mentioned in the paragraph above. The National Institute for Occupational Safety and Health gives training courses in occupational dust sampling. Contact: Mr. J a m e s S. Ferguson, D i r e c t o r Division of Training National Institute for Occupational Safety & Health Cincinnati, Ohio 45202. If further information is needed, I suggest either you or Mr. Dickenson call me in Denver. Very truly yours, Edmund M. Fenner, Director Technical Affairs EMF/emr MR. A.R. HOOKER, JR. KUTUl KFORD W.J. DICKSON RUTHERFORD JANUARY 31, 1975 OSHA AIR SAMPLINGS; TREMOLITE AND TALC I have read the a .I.A. Field Information Memorandum 174-92, on the subject of Tremolite and Talc. The purpose of tie Memo randum is to clarify policy changes regarding airborne particulate monitoring resulting from the letter from John H. Stendr, Assis tant Secretary of Labor, to Mr. H.B. Vanderbilt, Presidnt of the R.T. Vanderbilt Company, on October 9, 1974. There are still questions, however, that I would like to have resolved, if possible. a) Is the 30 micron top limit for fiber length in the counting procedure applicable only for tremoli :e, or does it apply to all other fibers as well? b) Re the "bundle-of-aticks" classification of paragraph Ex I have seen this effect fairly often with Chrysotile asbestos, very seldom with tremolite. If I observe a tremolite particle less than 3 miarona thick, less than 30 microns long, and meeting :he 5 ' to 1 length to width aspect ratio, would it be dis carded from a fiber count if I could not discern that it is composed of fiber subdivisibns, i.e., th "bundla-of-sticks" composition? c) Does the 5 to 1 length-to-width ratio in any way modify or replace the current 3 to 1 ratio as defined in Standard #1910.93a? d) Standard #1910.93a is applicable only to fibers over 5 microns in length. I see no minimum fiber length defined in Memorandum #74-92. Is there one? A careful perusal of Standard #1910.93a and of Memorandum #74-92 leads me to believe that an airborne particulate monitor ing report should now contain a minimum of four parts. I would like to know if my understanding is correct in this respect. Part Is - A fiber count for chrysotile and all types of amphibole asbestos, with the exclusion of all talc and tremolite. This would include all such fibers longer than 5 microns, with a length to width ratio of 3 to 1 or greater; and with no top limit for length (as defined in Standard 1910.93a). Part 2: - Count o,. tremolite particles that appear as either indiv B i b U '>r bundled fibers, judged to be neither crye s U nor . 'ivers, that are no more than 3 microns CRMC-MAP-000666 MH. A .K . HOOKI U , JK. KUTluiRFORU W.J. DICK 3Oil RUTHERFORD PACK 2 JANUARY 'll, 1975 OSHA AIR SAMPLINGS: tremoliti; and talc thick, no longer than 30 microns, that aro more than 3 times longer than they are wide, but not longer than 5 times their width. Part 3: - Count of tremolite particles that appear as either indivisible or bundled fibers, judged to be neither crystals nor slivers, that are no more than 3 microns thick, no longer than 30 microns, and that are five times or more longer than they are wide Part 4: - An air-impingar count, either gravimetric or lightfield, of all non-fibrous or non-asbestiform talc and tremolite. In addition to the above, please clarify the following: should we in the future be running routine air samplings by either gravimetric or light-field counts in all of our tile plants? (wsr) Is the "midget implnger" referred to in A.I.A. Field Informa tion Memorandum #74-92 the same unit as Mine Safety Appliance's Gravimetric Dust Sampling Kit #456241 (the mini-cyclone separator)? If we should be running these tests, how and where should we be obtaining the instruction and training that would qualify us to run them in the manner approved by OSHA a n d N I O S H ? Who in Flintkote would be responsible for conducting such a monitoring program at the various plants? WJD:pb cc: Mr. M.L. Johnson M r J W . H . M o r t o n s o n Mr. J T Schmitt Mr. S. Weiss Rutherford Rutherford White Plains White Plains CRMC-MAD-000667 BUILDING PRODUCTS GROUP / FLOORING & INDUSTRIAL PRODUCTS DIVISION 480 Centra' Avenue, East Rutherford, New Jeraey 07073 (201) 438-2800 February 5, 1975 Mr. Edmund M. Fenner Johns-Manville Corporation Greenwood Plaza Denver, Colorado 80217 Dear Ed: I am attaching a photocopy of an interoffice letter from Mr. W.J. Dickson of my Technical Service Laboratory to Mr. A.R. Hooker, Jr. regarding the recent AIA Field Information Memorandum #74-92. Mr. Dickson, who does our microscopic examinations for asbestos fiber count, has raised a number of questions involving interpretation of changes indicated in the above reference Memorandum. I am wondering if you would be kind enough to give u& your opinion wherever possible on the questions he has raised. The last several questions in his letter, of course, are internal questions but the others do involve interpretation of policy as now stated by the Depart ment of Labor. I would appreciate any assistance you can offer us on the various questions in the attachment. Very truly yours, THE FLINTKOTE COMPANY W H M :p b Attach. W.H. Mortonson, Manager Manufacturing and Technical Service CRMC-MAD-000668 j 5J U S 1 Johns-Manville Internal Correspondence To: 1. Kotin, M. D. Dato: March 18, 1975 From: Copies: E. M. Fenner, 0r i File & C ; <// - Subject: BORG WARNER TALC SITUATION Following your suggestion, I talked with John Dement of NIOSH this morning. The main points of information that John supplied are: (1) The talc being used by Borg Warner is R. T. Vanderbilt's NYTAL 200. (2) Both bulk and airborne samples were taken by the OSHA inspector, (3) Their X-ray and electron microscope examination of the talc showed no appreciable chrysotile but considerable amounts of tremolite and anthophyllite. (4) Their examination of the samples using the industrial hygiene analysis procedure from the OSHA asbestos standard and using the Stender revised definition of a fiber found approximately 40 fibers per cc in the airborne samples. John Dement asked that we keep him apprised of developments in the talc situation. CRMC-MAD-000669 m Johns-Manville Internal Correspondence To: J. H. Swensen Date: April 22, 1976 From: R. S. Lamar P. Kotin, L. M. Fenner, R. P. Carter, H. R. Keefe, Copias: H. Kranich, I), C Subject: REPRINT OP PAPER: "MORTALITY STUDY OF TALC MINERS AND MILLERS" BY GIOVANNI F. RUBINO, ET. AL. FROM THE JOURNAL OF OCCUPATIONAL MEDICINE, MARCH, 1976 VOL. 18, NO. 3, pp. 186 - 193 The attached reprint was sent to us from our good friend IV. H. Ashton, Johnson 6 Johnson Co. There are several key points: (1) The studies of Kleinfeld, et* al. of New York state "talc" workers show that the incidence of carcinoma of the lung and pleura among these workers is about four times that of the general population. C2) These New York "talcs" are known to contain not only the mineral.talc but also other silicates such as serpentine, tremolite, and anthophyllite. In this respect Kleinfeld's findings are misleading since the effects of exposure to talc mineral are not defined. (3) Rubino's studies, conducted among talc workers at Val Chisone, Italy, are far more definitive regarding exposure to pure talc mineral since these products contain at most only trace amounts of tremolite and chrysotile. (4) Rubino concludes from his studies that there is no cancerogenic effect attributable to pure talc (mineral). It would be my recommendation that this information be used in our marketing efforts with Penhorwood. It would appear that Vanderbilt's problems are multiplying (not to mention our own with Desertalc). R. S. Lam r CRMC-MAD-000670 2 Johns-Manville U Internal Correspondence To: H. R. Keefe - 2W Da,#: January 7, 1975 From: R. S. Lamar Copie; See end of correspondence Subject: YOUR MEMO OF JANUARY 2, 1975 TO P. KOTIN, " TALC AND ASBESTOS " I cannot help but feel that some additional input from Research is needed here. Several points: 1. The National Paint and Coating Association is simply a trade organization. It carries no legal weight. We are still bound by the law as described in OSHA documents. It seems to me that Stender, in his letter of October 9, 1974, destroys his own organization. Until this confusion within OSHA is resolved, we have no choice but to comply with the law as written. 2. As I read the NP&CA Bulletin No. 20, I get two strong impressions: a. Rather than clarifying the matter, as stated, they only add to my confusion. b. Asbestos is not really asbestos, but it can be anything you want to call it, e.g., "commercial talc." 3. I am greatly concerned with the point raised by A. Finkbiner at our last meeting. This has to do specifically with the fact that we are "sitting" on information which shows quite conclusively that R. T. Vanderbilt's talc products contain not only tremolite, but significant amounts of chrysotile and anthophyllite as well. What might be J-M's legal responsibility by withholding such information? Refer to: CRMC-MAD-000671 H. R. Keefe -2 - Jan u ary 7, 1975 Memo October 9/ 1974 V. E. Wolkodoff to R. S. Lamar Report No. 414-T-33, October 4, 1974 Memo October 10,1974K. L. Jaunarajs to R. S. Lamar Memo October 23,1974V. E. Wolkodoff to R. S. Lamar Memo October 11,1974R. S. Lamar to V.'E. Wolkodoff Do we still intend to provide OSHA with this informa tion on Vanderbilt's talc products? I also feel that we should provide this information to R. T. Vanderbilt. 4. Finally, the real question is medical in nature. From information I have from Kotin and Fenner, there is more than ample reason why we should label regardless of what the law might say. And, this could in time have a great deal to do with J-M's legal as well as its moral obligations. I guess what I"am really trying to say, Harry, is that the decision to label was right and should not be subject for reconsideration. We have to learn to live with it in a business sense regardless of how difficult this appears. R. S. Lamar kjm attachment cc: P. Kotin 4N F. J. Solon 4N E. M. Fenner 4N A. C. Finkbiner 5W P. A. Martinson 2W H. Kranich 2W W. C. Streib File: 259-6.1 m Johns-Manville li,. P. Kotin Internal Correspondence d<: January 2, 1975 From: H. R. Keefe Copie: Listed Below Subject: Talc and Asbestos Attached is a letter we recently received front the National Paint and Coating Association. This letter has been sent to all members of this Association. Please note Page 3 under Recommendations. We feel quite confident that R. T. Vanderbilt Company will certify that their talc does not contain asbestos per this paragraph. A speedy resolution of the confusion caused by OSHA and their definition of a fiber is necessary so that me might have answers concerning our talc for our customers. Harry R. Keefe H R K :ccr Attachment cc: P. A. Martinson H. Kranich A. C. F. Finkbiner F. J. Solon R. S. Lamar t/ E. M. Fenner D/C CRMC-MAD-000673 N o . 20 December 5, 1974 TALC A N D THE OSHA ASBESTOS STANDARD 1910.93a ROUTE TO: D$pirt/imt nui** S Admihtrtilt SU** Djp l*ehie*t . Producan _______________________________ Executive Synopsis___________________ ______________ The OSHA Asbestos Regulation 1910.93a includes, in its definition of asbestos, a mineral form (tremolite) that is found in some talcs, but is not generally considered an asbestiform material (see Safety and Health Bulletin N o . 1/f. "Asbestos Handling Guidelines" dated October 30, 1973). Through the extensive efforts of several NPCA members, a clarification of the regulation was obtained from O SHA . This now allows talc manufacturers to certify their material is "asbestos free" and the user of that talc is then exempt from regulation under 1910.93a. AC T IO N REQUIRED BY Y O U - Forward this Bulletin to the person or persons responsible fcr your safety and health operations. A C T IO N TAKEN BY NPCA - Through the efforts of NPCA members and the Occupational Health Task Force a clarification of the standard was accomplished. OPERATIONS AFFECTED IN YOUR CO M PAN Y - Manufacturing, safety and health. STAFF CONTACT AT NPCA - Richard W . Murry; Assistant Technical Director CRMC-MAD-000674 BACKGROUND With the promulgation of the asbestos Standard 1910.93a in July 1972 the possibility of certain talc materials being regulated as asbestos was created. According to the regulation, asbestos is defined as the following mineral forms: chrysotile, amosite, crocidolife, tremolite, anthophyllite, and actinolite. While some talcs are indeed marketed as containing asbestiform minerals and noted for their fibrous properties, the standard also encompassed other talcs not previously considered to be fibrous or considered to contain asbestiform materials. These are the tremolite (or more correctly non-asbestiform tremolite) containing talcs. Since late 1972 the R. T. Vanderbilt Company Inc. and the International Talc Company (later purchased by Vanderbilt) have had numerous meetings with OSHA officials to obtain a clarification on the regulation of the talcs under 1910.93a. RECENT DEVELOPMENTS On October 9 , 1974 in a letter to M r. H . B. Vanderbilt, President of R, T. Vanderbilt Company, In c ., M r. John Stender, Assistant Secretary of Labor, stated in part: " . . . i f you (the talc manufacturer) have scientific evidence that the naturally occurina talcs, prior to processing by milling or crushing, do net contain fibrous or asbestiform tremolite, anthophyllite, actinolite or other asbestiform minerals, you may certify to your customers that the talc does not contain asbestos." (A copy of the letter is attached to this bulletin.) Also a directive to such effect has been issued to OSHA field personnel as a guide in making inspections. This directive indicates that if a tale user, M S., a paint and coatings manufacturer, is monitored for asbestos the person behind the microscope counting fibers should use the following identification criteria: A . Particles must appear to be fibrous rather than as crystals or slivers. B. The maximum diameter of a fiber to be counted is 3 microns. C . The maximum length of a fiber to be counted is 30 microns. D. The length to width ratio must be 5 or more to 1, that is, 5 times or more longer than wide. E. The separate or individual fibers must contain fibrils or the "bundle of sticks" effect, unless thr ' are at a nondivisible stage. A fibril cannot be subdivided and would be co n ttJ- if it meets the other criteria. The electron microscope may be used t' p ove t: fibrous nature of the particles. The length to width ratio of 5 o r r t - i rr>eant to imply that other particles are not hazardous. CRMC-MAD-000675 Page 3 The directive further states that if the talc is of the non-asbestifornv or non-flbrous variety the time weighted average (TWA) of 20 millions of particles per cubic foot of air (mppcf) w ill be used. If monitoring of your operations using talc is done by the OSHA inspector you should retain a sample of the talc material being used in the event a discrepancy may arise. R E C O M M E N D A T I O N *l If you have been using talc products that have been questionable regarding asbestos (| content, request certification from the manufacturer that they do not contain asbestos. i| Retain this certification to show to an OSHA inspector if he questions the asbestos content of the ta lc . If it is however determined that a talc does contain true asbestiform minerals, that material w ill not be certified and is subject to the provisions of the regulation.' 0 l CRMC-MAD-000676 U.S. DEPARTMENT OF LABOR Occupational Safety ant* Health Administration WASHINGTON, D.C. 20210 Office of the Assistant Secretary OCT 9 1974 Mr. H . B . Vanderbilt President .Chief Executive Officer R, T. Vanderbilt Company, Inc. . *30 Winfield Street '.Norwalk, Connecticut - 08855 * * '.Dear Mr. Vanderbilt: This is in reply to.your letter ;of .September<26, concerning your .request.for relief from the asbestos standard for y o u r talcs containing non-fibroustremolite, actinolite, and anthophyllite. My letter of August 6 stated that nen-fibreue or non-asbestifora minerals such .as non-asbestiform tremolite are -not within the scope of the asbestos standard and, therefore, the provisions of that standard do not apply.to talc containing non-asbestiform minerals. N I O S H .is .currently.conducting a thorough investigation into .the .-exact minerals.to-whichtalc workers were exposed in those ..studies w h e r e .asbestosis or.other adverse .medical:effects .were.found. .Pending the receipt and evaluation by OSHA ;of the .report by. NIOSH .:onthis investigation, .if you have scientific-.evidence that .the naturally occuring talcs, prior to processing-by milling or .crushing, do not contain fibrous or asbestiform-tremolite, anthophyllite, actinolite or other.asbestiform mineralsi you may certify to.your customers.that the talc does n o t .contain asbestos. Fibrous, asbestiform minerals such as fibrous -tremolite means naturally occurring asbestiform minerals which prior to or.after . crushing and processing, contain fibers made up of fibrils. ..assista /; secretary oi i>onor CRMC-MAD-000677 Johns-Manville Internal Correspondence To: From: J. P. Leineweber 1-04 Dat*: February 17, 1977 Copies: R . Lamar 3-05 W. C. Streib R&D File Chrono Subject: PAPER BY C . S . THOMPSON "ASBESTOS IN YOUR FUTURE" I believe there is sufficient information in our files concerning our opinions on Dr. Thompson's campaign to convince the regulatory authorities that a fiber is not a fiber. This type of thinking is one of the reasons that industry in general, will continue to have a bad reputation in the eyes of those who sincerely want to protect the worker. The quality of this Paper is typified by the illustrations of the asbestiform and non-asbestiform varieties of chrysotile and amosite. Obviously, a competent mineralogist would not let an error of this magnitude slip through. J . P . Leineweber /pa Attachment CRMC-MAD-000678 f i t t 1. ` w l c Internal Correspondence To: E. M. Fenner, 1-06 Date: February 18, 1977 From: R. S. Lamar, 3-05 copie; J. H. Swensen, J. P. Leineweber, W. C. Streib, D, C Subject: Paper by C. S. Thompson "Asbestos in Your Future". Dr. Leineweber's comments on this paper, given in his memo to you dated February 17, 1977, are in my opinion correct but perhaps too mild. One of the few technically correct statements made by Dr. Thompson appears on page three. I agree that chrysotile is not a member of the pyroxene group, but disagree with almost everything else said by Thompson. I object strongly to an earlier statement on page three regarding "misinformation" supplied by a competior. Furthermore, in all of Thompson's gobbledygook regarding the mineralogy of Vanderbilt's "talc" at nofpoint does he admit to the fact that their "talcs" contain not only fibrous tremolite but chrysotile and anthophyllite as well. This we have proved by every available technique. These findings are well documented in numerous R&D reports. I'm afraid that Dr. Thompson long ago gave up any professional ethics he might have had and is now persist ing with a program that is not only technically false but even more tragic morally and ethically wrong. He totally ignores the medical consequences of his immorality. R. S. Lamar ib Attachments all copies CRMC-MAD-000679 m Johns-Manvillo Internal Correspondence V) !.. .M. Fenn e r 1- ori Fmin J. P. T.einewcber 1-04 Gupirv R. L a m a r 3-nn'p! W. C . Subject : P A P E R BY C. S. TIIOMPS "ASBESTOS IN YOUR FUTURE" 0" February 17, 1977 I believe there is sufficient information in our files concerning our opinions on Dr. Thompson's m campaign to convince the regulatory authorities that a fiber is not a fiber. This type of thinking is one of the reasons that i ndustry in general, wi l l continue to have a bad reputation in the eyes of those who sincerely want to protect the worker.- The quality of this Paper is typified, by the illustrations of the asbe.stiform and non-asbestiform varieties of chrysotile and amosite. Obviously, a competent mineralogist would not let an error of this magnitude slip through. . -y.\7 > J ''.<y7 ;u / ,y J. P. L e i n e w e b e r /pa Attachment CRMC-MAD-000680 >3 /\>T3\ by C. S. THOMPSON Manager--Minerals, Ceramics and Paper R&D, fl. T. Vanderbilt Co. Reprinted from the December 1976 issue of Mining Congress Journal CRMC-MAD-000681 by C. S. THOMPSON Manager Minornix. Ceramics and Paper PAD, P f. Vanderbilt Co To many, the title of these comments might infer a ma jor discovery of new asbestos deposits, tin increase in production, or new areas of application. However, others might suspect a more serious and sinister meaning, and, unfortunately, the^arc correct. Relative to world asbestos production and reserves (with the exception of the huge ore body of short fiber in the New Idria serpentinite in California), the United States has always been a small contributor, involving a very limited number of mining companies. This situation appears likely to remain the case since nature, apparent ly. saw fit to distribute the majority of this unique and highly useful material elsewhere in the world. "Asbestos" minerals created by regulations However, in the last few years, since excessive expo sure to asbestos has been shown to be a serious health hazard, the United .States government, through various regulatory agencies, has promulgated and proposed nu merous regulations that have created "asbestos" miner als where they have never existed before, and thereby caused essentially every mining company in this country to be an "asbestos" miner and "asbestos" miller. In most cases, this also makes them guilty of contaminating the environment with "asbestos" by dumping their tailings so that the natural weathering processes redistribute these newly invented " asbestos" minerals into the air, surface runoff and ground water. In the case of many min ers and producers of industrial minerals these new " as bestos" materials are distributed into a wide variety of manufacturing operations as mineral fillers in paint, plas tics. rubber, or as basic ingredients in cements, spackling compounds and ceramic products. To understand how this startling situation hits come about, let us examine the chronology of the chain of events which has occurred over the past few years. Issuance of standard in 1972 start bain of events It all began with the issuance f the Oca 'utional Safe ty and Health Administration Aha) Asic.,,. v andard in July 1972,' based on the Na . * . . Occupa tional Safety and Health (Nir ,'t) criteria document,1with the purpose of controlling I i nan exposure to asbestos. Without the benefit of rcadi / available mineralogical ex- pcrtisc (USBM, USGS, etc.), "asbestos" was defined as tiny one of six minerals. Table I lists these six minerals showing the correct ter minology for describing the asbestiform varieties of anthophyllite, tremolite and actinolitc. The first three minerals listed in the Osha document-- chrysotilc, crocidolilc and amositc--designate specifical ly the fibrous or asbestiform varieties of their vastly more abundant non-fibrous counterparts. In contrast, the latter three amphiboles--anthophyllitc, tremolite and actinolite--as listed erroneously, include all forms of these very common rock forming minerals which rarely occur in fi brous or asbestiform habit. Tabic 1. "Asbestos" minerals as listed in Federal Register (Listed minerals are italicized) Asbestiform Variety Chemical Composition SLR PI- NTl NL G ROUP Chrysolite Mg:i(SiX)*)(OH), AMPHIBOLK GROUP Crocidatile NajFe:,Fej(SiN0 2.,)(()H,F) Amosite (Mg.FcMSuC^-.tHOH), Anthophyllite asbestos (Mg,Fe)7(SiK0 22)(OH,F)a Tremolite asbestos CaJMg,,(SillO;1..>)(OH,F).,( Actinolitc asbestos Ca2(Mg,ire)-,(SiM()22)(OH,F); NonAsbestiform Variety Antigoritc, liza olite Ricbcckite Cummington- ite--gruneritc Anthophyllite Tremolile Actinolitc Simple error has created confused situation It was this simple error which has been perpetuated by other agencies and is now being expanded through pro posed regulations by both Osha and the Mining Enforce ment and Safety Administration (Mesa) that has created the confused situation that exists today, This error was further complicated by defining a "fiber" ns any mineml particle three times longer than it is wide (3:1 aspect ra tio), through reference to the Niosh criteria document. These simplistic definitions of "asbestos" and " fiber" were eagerly and immediately accepted by essentially all other agencies is illustrated by the proposed and/or prom- ulgutcd regulations listed in table 2. It is obvious from these documents that the majority of standard producing Table 2. Inilia! Reaction. (Primary definitions covering asbestos exposures) Agency Osha USHM (Coid) EPA (Air) Dale July 7. 1972 (Revised Oct 18.1972) Nov. 7. 1972 Apr. 6, 1973 Definitions fiMinerals (Sec table 1) I'iber 3:1 1.engtli:width ratio 5 Micrometers in length Some as (Kha Same as ( )slia Asbeshts a n o m a l Asbestos or any material containing ashestos Asbestos tailings ~ Any solid waste product of asbestos mining or milling operations which con tains asbestos agencies are reluctant to develop definitions of their own and are perfectly satisfied to incorporate those promul gated by others even to the perpetuation and expansion of erroneous ones. Bureau of Mines tried to clarify issue with symposium The first major breakthrough in correcting the errors in the original asbestos definitions came as the result of a concerted effort by the Bureau of Mines to clarify the situ ation by holding a Symposium on Talc on May 8, 1973 in 'fable 3. Turn about or Sidestep. (Secondary reactions concerning asbestos definitions) Ascili y Date Definitions the realization that materials to be regulated must be cor rectly defined and described by the field of science to which they belong if meaningful standards arc to be devel oped. To quote Professor Tibor Zoltai of the Department of Geology and Geophysics, University of Minnesota, in comments to the Minnesota Pollution Control Agency* regarding the distinction between fibers of natural asbes tos and of cleavage fragments: U n fo rtu n ately, the m isuse o f som e relevan t m in e ra l g ica ! concepts an d term s are becom ing so w ide sp read th at it m ay be extrem ely d ifficult to correct th em . H o w e v e r, i f th a t is n o t d on e, som e m in e ra l g ic a ! concepts an d expressions w ill have double definitions: one f o r m in eralog ists a n d p h y sica l scientists, an d one f o r use in en viro n m e n ta l p u b lic h ealth sciences an d p ractices. The continuing use o f these double definitions w ould b e m o s t u n fo r tu n a te as it w ill u n d o u b te d ly le a d to a d d i tio n a l m isunderstanding an d conflict betw een m in era l ogists a n d geologists, on one side, a n d en viro n m e n ta l a n d p ub lic h ealth p erson n el on the o th er. A s the con cepts a n d expressions are m in era l g ic a!, the lo g ic a l so lu tio n to this p ro b lem w o u ld be f o r th e p ers o n n el in the second categ ory to re strict them selves to the p ro p e r use o f m in eral g ica! term s. On May 3, 1974, the Environmental Protection Agency (KPA) issued its "Revised National Standard for Asbes tos Air Pollutant" 6 in which the asbestos definition was side-stepped by stating that the standard was meant to deal only with "commercial asbestos" and that materials "containing asbestos as a contaminant only arc not cov ered." They specifically mention talc mines and manu facturing operations and the "releases of asbestos from taconitc milling operations" as being excluded from cov erage. CRMC-MAD-000683 I EPA May?, 1974 Same as Osha (Air) Standard revised to include only Effort was made to correct error * "commercial asbestos," not opera In the meantime, through the diligent and consistent ef tions where asbestos was a con forts of a small group of interested parties. Osha became 1 USBM July 1, 1974 taminant Only includes asbestiform varieties aware of the errors in definition and the Department of (Metal- of six minerals. Recognizes exis Labor issued an agreement on Oct. 9, I9747with one in nonmetal) tence of non-fibrous forms. Based dustrial talc producer stating that "non-fibrous or non-as- decision on data presented it bestiform minerals such as non-asbestiform tremolite arc symposium on talc1' not within the scope of the standard . . ." Soon there Osha Oct. 9, 1974 Agreement with tide producer7 after, on Nov. 21. 1974, Osha issued a Field Information Nov. 21. 1974 Issued field memorandum" using ! five criteria for fiber identifi i. cation (see table 4) ! EPA Oct. 25, 1974 Set exclusion level of one percent ; (Air) asbestos content1' Memorandum" recognizing the two forms of the amphibolc minerals and listing five criteria to be used in detcr- Tahlc 4. Criteria to be used by Osha incounting fibers 5 Mesa Dee. 13. 1974 Issued memorandum requiring use A. Particlesmust appeal'tobe fibrousratherthaniscrystalsor ; of criteria similar to ( )sha for slivers. counting fillers U. The maximum diameter of a fiber to be counted is 3 mi crons. Washington, D.CV1 Numerous speakers presented data on the medical effects of talc and associated minerals on both humans and animals. Also, methods for the identifi cation and classification of these minerals were discussed in detail. Subsequent evaluation of all ne pre.."illations resulted in the Bureau of Mines publis' ne in hr . '-ral Register of July 1.1974 Amendments i".... \ b.-sm. Stand C'. The maximum lengthofafibertobecounted is30microns. I). The length to width ratio must be 5 or more to I, that is, 5 times or more longer than wide. I-. The separate or individual fibers must contain fibrils or the "bundle of sticks" effect, unless they arc at a nondivisihlc stage. A fibril cannot be subdivided and would be counted, ifitmeets the othercriteria.The electron microscope may be used to ptove the fibrous nature of the particles. The length to width ratio of 5 or mote to Iis not meant to imply ard.4 Included were miner; . ......... collect definitions that other particles arc not hazardous. for asbestos and the rcco/ a/ed asbestos minerals (see table 3). This document stt i Js today as the turning point mining whether a mineral particle could be considered as f. and landmark in governor Mal regulation of minerals by fibrous or asbestiform. These are tabulated in table 4. Osha's recognition of the prohlem as evidenced by these two documents and its repeated verbal assurances that correct mincralogical terminology and identification method would be incorporated into the asbestos amend ment appeared to signal a real and welcome change in this agency's attitude toward the scientific correctness of its standards. Very soon there.aftcr, on Dec. 13, 1974, Mesa issued " Health Division Instruction Memorandum No. 8-- Defi nition of Asbestos Fiber for Trcmolite Occurring in Talc." which listed criteria for fiber determination similar to those outlined in the Osha document. The year 1974 ended with a feeling of optimism that science had won out and that future regulatory documents dealing with " asbestos" would contain definitions and terminology hat would limit their application to the true asbestos min erals upon which all medical data concerning human health hazards has been obtained. Plan to rescind Labor Dept, agreement revealed The first indication that all was not well was a thinly veiled threat early in 1975 that Osha was considering the rescinding of the Department of Labor agreement with the before mentioned talc producer and the withdrawal of Osha Field Information Memorandum #74-92. This ma neuver was based on misinformation supplied by a com petitor concerning the mineralogy of the talc products in question and on continuing pressure from Niosh which, to this day, insists on using only the simplistic 3:1 (length:width) criterion to define a fiber. A meeting was held with the then Assistant Secretary of Labor, John Stcndcr. with all principals represented, at which Stcnder stated that as long as he held office both the agreement and Field Information Memorandum would remain in force. Stcndcr left the Department of Labor soon there after. ' "Another document was brought to our attention late in the summer of 1975 by Bureau of Mines personnel. This was a study, commissioned by EPA, published by Battelle, Columbus Laboratories entitled "Identification and Assessment of Asbestos Emissions from Incidental Sources of Asbestos.""1This publication deals primarily with the occurrences of amphiboles, all lumped together under the subtitle of "Asbcstiform Minerals of Interest." All amphiboles arc grouped, regardless of crystalline form, because, the authors state, the excellent prismatic cleavage characteristic of all members of this mineral se ries (some 27 individual species) "causes the mineral to fragment into fibers." This statement is directly contrary to the principle, in general acceptance among mineralo gists, that mineral fibers grow as fibers and that fibers are not generated from non-fibrous crystalline material by fragmentation. This paper goes on to discuss essentially all the major mining districts in the United States, state by state, with the consistent inference that the presence of amphiboles in any rock makes that rock a potential "incidcntial source of asbestos." Proposed amendment to st r . ..step The shoe dropped ot Oct. 9, 1975 (Black Thursday) with the issuance of the . sha proposed amendment to its Asbestos Standard (sec table 5)," Not only did Osha pro pose to take the step backward and use the aspect ratio as the sole criterion in defining a fiber but also to lower the threshold limit value (TLV) from 5 fibcrs/cm:i (this TLV was automatically dropped to 2 fibcrs/cm* on July 1, 1976) to 0.5 fiber. In the preamble to this document Osha continues to show its lack of mineralogica! expertise by Table 5. Back to go and worse. (Most recent reactions concerning asbestos definitions) Agency Osha Dale Oct. 9. 1975 EPA (Air) EPA (Water) Oct. 14. 1975 Oct. 16. 1975 Mesa June 29, 1975 (Metalnonmctal) Definitions 6 Minerals--No distinction asto crystalline form 'her - 3:1length:wittlh ratio - >5 micrometers in length (negates field memorandum") No change from original--details disposal methods No change from original--groups wollaslonitc with asbestos for re quired effluent controls Removes "asbestos" tcrminalogy and substitutes "mineral fiber" Mineralfiber ~ any mineral par ticle with a 3:1 aspect ratio or more >5 Micrometers in length <5 Micrometers in width copying an asbestos definition from a New York Acad emy of Science publication dealing with the biological ef fects of asbestos rather than consulting a more appropri- , ate mincralogical reference. The definition chosen was in gross error in that it included all pyroxenes, in addition to all amphibolcs, and classified chrysotile as an example of the pyroxene group, which it is not. This inclusion of an additional group of minerals never before considered to be asbestos indicates the never ending attempts by some regulatory agencies to expand theirjurisdiction indefinite ly. The Osha publication was followed in quick succession by two documents issued by the EPA on Oct. 14 and 16. 1975, dealing with "asbestos" contamination of air and water, respectively.,,,,a The former details the method of disposal of asbestos and any material containing more than one percent by weight of asbestos. The latter further modifies the effluent guidelines for mineral mining and processing numerous minerals including a category en titled "Asbestos and Wollastonitc." This expansion of the inferred health hazard to a non-asbestos mineral ap parently slipped by unnoticed by the industry since no counteracting comment has been discovered to date. Mesa proposal would expand mining regulation The latest in this long list of regulations ostensibly di rected at reducing or eliminating exposure of the worker, consumer and the general public to "asbestos" is aimed directly at the mining industry by its own regulatory agen cy. The-..proposed Mesa regulation,14 presented to the Federal-"Mine Safety Advisory Committee in Birming ham. A!.. June 29. 1976, would expand the asbestos regu lations to cover essentially all minerals known to man re gardless of composition. Mesa would accomplish this very simply by removing the term "asbestos," which everyone has such a difficult CRMC-MAD-000684 CRMC-MAD-000685 lime ikTming, from the sliiiulanl ml replacing it with two containing material . . . it the end of each operating words, ' `mineral fiber," The agency would further simpli day." fry to imagine the situation the mining industry fy the regulator's task by defining a " fiber" as any " pani would be in when the EPA starts to apply the proposed cle that exceeds 3 microns in length but not 5 microns in Mesa " mineral fiber" definition to (he hundreds of thou width, and shall have a length-to-wiilth ratio of at least 3 sands of tons of mine tailings and overburden dumped to I ." While the terminology and definitions arc altered, daily, liven worse, try to dream up a soil or cover of any the requirements tor handling these " mineral fibers" re kind which would not contain any "mineral fibers." main the same as those promulgated for true asbestos. Many stale agencies try to improve on their federal coun To my knowledge, there is no mineral assemblage terparts by setting more stringent standards. The Illinois being mined, milled, processed and cither used as such or EPA, for example, requires that any " asbestos" con discarded is tailings that would not contain significant taining material be disposed of in steel drums. a m o u n ts o f m in e ra l p a rtic le s w h ic h w o u ld be classified is " mineral fibers" using the Mesa definition. The majority of silicates, including those most common in mineral de Every mining company would be affected posits (i.e. amphiboles, pyroxenes and feldspars), and nu merous nonsilicates have, by nature, cleavage character istics that cause them to elongate during comminution. Nature itself forms particles meeting Mesa's criteria through normal weathering processes. Two points should be made quite clear at this time: --All of the medical data concerning the nature and ex tent of health hazards related to asbestos exposure has been gained, on: truly asbestiform varieties of only four minerals, chrysotile, crocidolite, amositc and anthophyllite groups of workers exposed to extremely excessive .amounts of these asbestiform minerals, usually is mixtures of it least two types. --No definitive medical data has been presented to in dicate that comparable health hazards exist with re spect to the non-asbestiform varieties of the true as bestos minerals. No references at all regarding expo sures to tremolitc or actinolitc, in any form, were included in the list of 70 plus references listed in the Osh.t Asbestos Standard and the additional 42 con taining " new information" in the proposed amend ment. The extrapolation of hazard from three or four extremely rare forms of common minerals to the in clusion of cleavage fragments and particles of csscn* lially all other minerals is entirely unwarranted. All the potential problems need not be elaborated on here. Everyone in the business of mining has been greatly affected by one or more of the multitude of safety and health regulations now on the books, but this latest " min eral fiber" proposal by Mesa is probably the only stand ard that afreets every mining company in this nation. To make it worse, it is based on a lack of medical data, a to tally unjustified extrapolation of hazard from fibers to non-fibers and acomplete absence of mineralgica! under standing and expertise. In conclusion, I would urge the entire mining industry to support the efforts now being spearheaded by the AMC Noncoal Occupational Health Committee to coun teract the evergrowing umbrella of the " asbestos-miner al fiber" regulations. An AMC ad hoc subcommittee on " mineral fibers" has already made a presentation to the Federal Mine Safety Advisory Committee in Birming ham, resulting in the assignment of that topic to subcom mittee for study. Continued efforts will be made to pre sent any and all data which w ill aid all regulatory agencies, federal and state, to correct past errors in min eral definitions and to make use of the vast reservoir of mincralogical expertise in the U.S. Bureau of Mines and the U.S. Geological Survey in all future standards dealing with minerals. To accomplish this, the backing of the en tire mining industry will be needed. Almost everyone knows what asbestos is, but there Ramifications to mining boggle the mind seems to be a great many people in numerous regulatory agencies that do not know what " asbestos" is not. Un There are many ramifications of the present and pro less these people are enlightened, most everyone who posed " asbestos" regulations, which would directly af has not had " asbestos" in his past will find that he has fect the mining industry, that may not be immediately ap " asbestos" in his future. parent. As mentioned earlier, regulatory agencies show a References great reluctance to develop definitions of their own and 'Federal Register. Vol. 37. No. Ill), July 7, 1972. p. 11320-11322. eagerly adopt those supplied by others. The EPA is using 'Criteria For A Recommended Standard . . . Occupational F^xposure the 3:1 aspect ratio exclusively for the six listed "as To Asbestos, National Institute F'or Occupational Safety and Health, bestos" minerals in its extensive study of water con 1972. 'Proceeding of the.Symposium on Talc, Washington, D.C.. May 8, tamination by mines, mills and manufacturing facilities. 1973. U.S. Itureau of Mines Information Circular 8639, 1974. 3 At present, the EPA requires that any material containing -Federal Register. Vol. 39. No. 127. July I. 1974. p. 24316. V.ollai. Tibor and J. H. Stout. "Comments on Asbestiform and Fi CRMC-MAD-000686 one percent or more " asbestos" must be disposed of by hrous Mineral Fragments, Relative to Reserve Mining Company Taco covering with "it least 13 cm tea. h in.) of non-asbestos nile Deposits." Minnesota Pollution Control Agency, Mar. 24, 1976. "Federal Register. Vol. 39. No. 87, May 3, 1974, p. 15396. ( . S h e h l o n '1h i > n i p \ o n is / ( A l ) M i n i - 'Letter lo H. IT Vanderbilt from John H. Slender, Assistant Secre tary of l.nbor, dated Oct. 9, 1974. n g e r-M in e riils , ('e rn n iie s u n ii P a p e r De- "Field Information Memorandum #74-92, Nov. 21, 1974, "Tremolitc fn irln ii'iir, II. I. V n n ile rh ll C n. T lnnnp- and Tale." Occupational Safety and Health Administration. snn h e g n n h i\ p ro fe s s io n a l r n r - e r in th "Federal Register, Vol. 39, No. 208. Oct. 25. 1974, p. 38064-38073. I t i l i ! n i T n i n e r o l o g y i n /V.5.5 h a , i/i'jwr "'Knryvial. R. J.: R. A. Wood, and R. K. Harrell. "Identification n i W 'rs lin in is trr ( o lir n e in soli 'o h e And Assessment of Asbestos Fmissions From Incidental Sources Of ( Itv. T 'olltnvin n lim i. I llu n i u n i seri-, ' Asbestos." LPA-650/2-74-087, Hattclle Columbus Laboratories. Sept. ha r r s r a r i li m in r r tilo g is l- .s - i ni I.0J1 1974. "Federal Register. Vol. 40, No. 197. Oct. 9, 1975. p. 47652-47665. K rn n e e o tt ( upper C m p ; in in e riilo g ist-g ra u p num i . ' ., "Federal Register, Vol. 40, No. 199. Oct. 14. 1975. p. 48292-48302. "Federal Register, Vol. 40, No, 201, Oct. 16. 1975, p.48652-48668. u ie iu e s . U n io n ( a rh itli ( orp. M in in g "Agenda for the |9th Meeting of the Federal Metal and Nonmetal m iti M e ta ls D iv is im i. I in ip s m i liiis n Mine Safety Advisory Committee. June 29-July I. 1976, Birmingham, l 'Ill) f r n m lite U n iv e rs i!\ i f U m h . Al J.vil J 0 ili?E: i.i.;-n /iilo r.. , ?i ^ i 7 /-L : i C o r r e s p o n d ao nn cc e '-% E . M. Fenner l:rOI" ]j, R. Keefe .Uipius P . A. Martinson, w. C. Streib, D/C Sui,r,;<: Talc Certification Letters 1975 o- ) v, y jj^ 1 .Si W o a r e receiving letters, particularly from paint customers, requesting that we certify that our talc do not contain asbestos fiber. Considering the various statements contained in John Slender's letters and our meetings with OSHA to clarify the meaning of his statements, I propose to answer customer letters with the sample letter attached. Time is short as we need to answer our customers promptly and we are holding one letter dated January 10, 1975. Please advise me by February 19, 1975 if you have objections to our sending this letter. We do n o t h a v e a copy of the photograoh referred to in the .i_t; IthLLciJ- a iiu . vvts aJuc: a. L Lum p u J-iiy LC y u 'L SOmc jlITOui Ix u o u u jT C ii Karr p ,S 3 L . Keefe HR^e'cr Attachmeni CRMC-MAD-000687 i Johns-Manville Products Corporation Filtration & Mineral* Division Groonwood Plozo Denver. Colorado 80? 17 (303) 770 1000 Gentlemen: Thank you for your letter requesting certification that our Dcsertulc products do not contain asbestos. Please permit me to explain our position. Our talc contains a mineral called tremolite. OSHA, in the Federal Register, defined asbestos and asbestos fiber as follows: Asbestos includes chrysotile, amosite, crocidolite, tremolite, anthophylite, and actinolite. Asbestos fiber means asbestos fibers longer than 5 micrometers. There had been and still is, much confusion as to whether or not tremolite is asbestos. John H. Stender, the Assistant Secretary of Labor, on October 9, 1974, stated: Fibrous, asbestiform minerals such as fibrous tremolite means naturally occurring asbestiform minerals which prior to or after crushing and processing, contains fibers made up of fibrils. On November 21, 1974, OSHA issued "Field Information Memorandum #74-92," copy attached. This Memorandum contains a policy change concerning tremolite in talc and what is to be considered asbestiform or fibrous. Section 2E states: 2. Policy Change: In order to be considered asbestiform or fibrous the following criteria will be used by the Salt Lake City Laboratory of OSHA: A. Particles must appear to be fibrous rather than as crystals or slivers. ' Thf maximum diameter of a fiber to be counted is 3 '..rons. C. The maximum length of a fiber to be counted is 30 microns C R M C - M A D - 0 0688 Page 2 D. The length to width ratio must be 5 or more. to 1, that .is, 5 times or more longer than wide. E . The e p a t a tn or individual fibers m u t c o n t a i n fibril/-; or the "bundle of sticks" effect, unler.r, thoy are at a non-divisible stage. A ! ibr ii cannot be subdivided and would be counted, i! it meets the other criteria. The electron m ar..ros copo may be used to prove the fibrous nature of the particles. The length to width ratio of 5 or more to 1 is not meant to imply that other particles are not hazardous. On December 17, 1974, Johns-Manville's Vice-President of Health, Safety, and Environment, Dr. Paul Kotin, wrote to Mr. John Stender requesting clarification and guidance on Section 2 of the Field Memorandum #74-92. Attached is^ Mr. Stender's replies to our questions. We have attached a photograph of our Desertalc at 400X magni fication. The long, stick-like particles are the tremolite in question. You will note they do not exhibit the "bundle of sticks" effect as mentioned in Mr. Stender's letter of January 13, 1975. Further, if we look at photographs of t|juhjilsL itoalelac watf 1yj0.c,i0iiu00lX-lLmeagwnhiifcihcaWtoiuolnd, IiwOeu ustesevisstiibclke-_liakt e 400a >' magnification. Therefore, the t r e m o H t e ^ a r t lcies_seen at > 400X magnification are not'"at' 'a"Ti5n^Iy^ , If, then, the tremolite particles viewed at 400X magnification ) do not contain the "bundle of sticks" effect and are not at a n o n - d i v i s i b l e stage, they should not be considered as asbesti- 1 form or fibrous. Meetings between Johns-Manville and OSHA continue. We still have much confusion as to what is or is not fibrous. It is for this reason we can neither state that our talc contains asbestos fiber or does not contain asbestos fiber. Please accept our apology for not answering your question directly. We arc sure you can see the quandry we have. If you should have any questions, please contact us. Sincerely yours, Harry R. Keefe Vico-Presiden*- and General Marketing Ma? s -'r, Minerals H R K :ccr Attachment .... .. . . CR.MC-M AD-000689 U.s. DHRARTiViLMT ()!' LABOR ( l u l l p . l l MUl.l I S l f c l y .1111i i l l '. l U l l A dill M11>r I ,| ( 1)11 v.'.aviin'i,!(),;, iiC, / O m , L t h f A'.MSi.uu ! \) Paul Kotin, M.D. Vice Pres i<Jen t Health, Safety and (inviron me lit Johns-Manvi11e Corporation Greenwood Plaza Denver, Colorado 00217 Dear Dr. Kotin: This is in reply to your letters of December 17 and 19, 1974 reaardino our Field Information Memorandum 74-92 of November 21, 1tnu "t7A You asked for further clarification and guidance and requested to meet with us to discuss the matter. Our purpose in preparing the Field Information Memorandum was to provide guidance in distinguishing between fibrous and nonfibrous talc or tremolite. Here are our comments to your observations: 2C Fiber length - We agree that fibers up to 200 micrometers in length should be counted, providing the diameter is not more than 3 micrometers. 2D The standard does not address length to width ratio. Five or more to one, length to width ratio is an arbitrary matter of convenience in counting to distinguish slivers or crystals from fibers. The three to one ratio provides some additional difficulty in distinguishing fibrous from non-fibrous. Again, length to width ratio and diameter are not in the present .uandard. Minimum length is stated in the standar as r' micrometers. Ke see no need to change tho H r i'!' v! ause of Field Information Memorandum 74 -92 , . 21 , 1974. CRMC-MAD-000690 i 2 2 E The "bundle of sticks" effect is mentioned in the literature as a distinguishing characteristic of fibrous minerals, as compared with very fine fibrous glass, for example. It can be seen under phase contrast microscopes with 400 X magnification, according to our laboratory in Salt Lake City. jOnly in cases where further proof is needed would electron j microscopy be used. This advice was given to the Occupational ! Safety and Health Administration (QSIIA) field offices and labora tory. Field Information Memoranda are available to the public, but are primarily for guidance to OS HA staff. You are under no requirement to use electron .microscopy, nor are your customers. OSHA reserves the right to use it to prove that a mineral is fibrous or non.-f ibrous . liie asbestos standard is being studied for pussibie revision. Your comments will be considered in revising the standard at a later date. Please arrange to meet with Dr. Daniel Doyd, Mr. John P. O'Neill, Mr. Harry Gilbert, Mr. Ray McClure, Mr. Richard l/ilson, and Mr. Howard Schulte, Deputy Assistant Secretary of Labor, on this matter. You may contact Mr. Schulte, area code 202-961-2144, for the time and place, Siqcerely, Assistant Secretary of Labor CRMC-MAD-000691 N o v e m b e r 21, 1074 cm;]. Director:? u-JTid Area Directors SUBJECT: Trerolitu and Talc >l* \ u'.d- The attached letter frem Assistant .Secretary of labor John H. Stermer gives iurtber policy guidelines in regard to trarolita . cird talc that are not asbestiform or fibrous. 2. Bolder/ Chance: In order to be considered asbestifo:ra or fibrous the following criteria vrill be used by the Salt lake City Laboratory of OSHA: A. Particles must appear to be fibrous rather than as crystals or slivers. B. Tixe iKodmum diameter of a fiber to be counted is 3 microns. C. The maximum length of a fiber to be counted is 30 microns. D. The length to width ratio must be 5 or more to 1, tint is, 5 times or more longer than wide. JE. . Tin separata or individual fibers must contain fibrils or the "bundle of sticks" effect, unless they are at a non--, divisible stage. A fibril cannot be subdivided ami v-ould lv if it thn o'Jv'r criteria. The electron > n l o n v . i nny Iti usol to piov<i Viia fibroid nature of tho particles. TIvj length to width ratio of 5 or more to 1 is not inumt to imply that other particles are not hazardous. 3. Sample C o llor. Lion and Submission: If the Compliance Safety and Health Officer (CSH0) is reasonably sure that the. talc or travelitc is fibrous or anbestiferm, he will sample following the CSHA Sampling Data Sheet #2 for asbestos. CRMC-MAD-000692 J - 2- In .ili othor cases for tale or txcsroljbe, he vili (1) sanplc 'ioU ow ir/j Livi Data S h e d --2 fa r asbesto? arci (2) sanplo " usincj tho midcjet impiagar l'or r.er.-erhjstifcrr., non-fibrous tale or tremo].ilo. Vfren i'-pir.gcr rarplor ore token, an air carpio mst ).* cx)J Jcoi od b !jcvir.g CfJHA. Carpiir.cj luto Sheet #3 for crystalline siile.;'. ....r detemining tic percent quarto at tho itola ito:e Cb. v e... L\ .dimoratorv. Midget impjnear samples must be analyzed within 24 lours after collection Tor too results, to be valid. Therefore, arrangements rrust bo irado by the Industrial Hygienist vrith a local laboratory concerning the analyses prior to raking the inspection. Those samp] es arc not to be sent to tl-.e OSHA laboratory, Salt Lake City; they will not to analyzed there. if"the Industrial Hygienist as certain tout too talc or trerofite is asbestifom or fibrous, impinger samples ray be emitted from tlie .inspections. Resuli:s and Interpretation (1) Results from the irpingcr samples will be used if the talc or trcvolitc is non-ashestiform or r.on-fibrous. Table 0-3 of 1910.93 would apply. Tito Tire Weighted Average (TV70 for tciU: or tnunlilo tlvit is non-asbostifom, non-fibrouii is 2 0 millions of particles par cubic foot of air by the light-field count method. (2 ) Tiie laboratory will give two results for the talc or trend ite tout is asbestifom or fibrous submitted for analyses of asbestos. Cne for definite asbestifom fibers meeting the criteria of 5 or more to 1 and cne for those fibers meeting the older asbestos criteria, namely those particles having a length to width ratio of 3 or more to 1. Samples having a 5 or more to 1 length to width ratio and meeting the other .criteria of paragraph 2 Policy Chance would nvsan that fibrous or asbestifom talc or trevolTts is present. There- ' foro, the standard for asbestos, 1910.93a, would apply. Tillti gnidhneo is temporary and may ckwjo as a result of findings from an on-going MOSIl study on this subject. v w CRMC-MAD-000693 Any questions msy ho directed to Hr. Charles McClure, Divi.cion of Cccap:.t:io;al Health Prrx;rasnu.r/:j, Occupational Safety and Health A&unistration, Washington, D. C. 2 0 2 1 0 , telephone 202-S61-2726. f * /. O J u t r * Barry J. VJhite Associate Assistant Secretary for Kagional Programs Attachment ' "V .* - f ' CRMC-MAD-000694 fr* * ** Johns-Manville Sales Corporation Ken-Caryl Ranch Denver, Colorado 80217 Edmund M. Fenner Vico President Director, Environmental Services Health, Safety &Environment Department November 23, 1976 Mr. R. H. Mereness Executive Director Asbestos Information Association/NA 1835 K Street, N.W. Washington, DC 20006 Dear Bob: r Attached is a brief report of our Task Group meeting in Denver on Tuesday, November 16. Please call me if you have any questions. Very truly yours, 2 *^-- EMF: j h Enel. CRM C-M AD 000695 Report of Meeting of the Task Group on Naturally Occurring Inorganic Fibers of ASTM Committee E-34 A copy of the agenda for this meeting is attached. A list of meeting attendees is also attached. Most of the meeting was devoted to review of the tenth draft of the Standard for Occupational Exposure to Asbestos. After the resolution of a few minor points in the draft, the meeting was confined to a discussion of the exposure limits that ASTM would recommend. It was finally agreed that this could not be resolved at the meeting, and-^that it would be necessary to ballot by letter all members of the Task Group to determine which of the two following proposals should be adopted. 1. All Uses - 2 fibers longer than 5 microns per cubic centimeter 8-hour time-weighted average. 10 fibers longer than 5 microns per cubic centimeter ceiling concentration. 2. Mining andjMilldng - 5 fibers longer than 5 microns per cubic centimeter 8-hour time-weighted average. 10 fibers longer than 5 microns per cubic centimeter ceiling concentration. Product Manufacturing, and End Use - 2 fibers longer than 5 microns per cubic centimeter 8-hour timeweighted average. 10 fibers longer than 5 microns per cubic centimeter ceiling concentration. The meeting was adjourned at 12:00 Noon. The next meeting was tentatively scheduled for March 8, 1977 at Kennedy International Airport in New York City. CRMC-MAD-000696 A tfcanclaea Chairman - A. A. Winer# Department of Energy# Mines and Resources, Canada Vice Chairman - E. M. Fenner, Johns-Manville Corp. & AIA/NA Secretary - Marcel Cossette# QAMA G. F. A. Brink# QAMA & Asbestos Corp. P. Laroche, Lake Asbestos A. E. Martin, M.D., NIEHS Rita Or^iel, Consumer Products Safety Commission Bernard Lincoln, T-N Ltd. A. M. Harvey, R. T. Vanderbilt H. d . Stanley, Pfizer H. H. Kaufman, GAF R. A. Clifton, BU Mines C R M C -M A D -0 0 0697 fcWfkW,"7^W|g T ftS (< y ** \ <S-C<.cJp o \ J AM T U A/4-CL.y O d e <J R K . /V<?- W O . < ^ f\jt c f=?( P E: /^ 3 It* November #74. P*ive*> C. C i *. t h ha. m ?J Gyo <?*\ K'tf 'K&. !r S \ / k , M t * u f" 5 a -A H t (a~si~~ *h. c c / " / ` 4. V| Ofk." t 6. 7. p o- s / h ts.^ 3 cl r J f v j R e ^ i > lu o /~ */" ii e T y { $ - / 0 k o / / > : is t'h c s & u~f~ o f- i~i* f~e/i H c d r c a fi- J j e 1r s J ) r A/ J>Lf s i ' h e.X S' C X f ~ e . &n<A p (*. c <c f i ~ l l c 11C K >14 e e . / / V ^y , ! ! .--i-- :o_. "'Il i I l.,.v i- V, . :3*. a^ie &> ....'. ^4y A CRMC-MAD-000698 r * F. J. Solon, Jr. Reitze F11 iChron ) CONVERSATION WITH HOWARD J. SCHULTE/OSHA, AND RAY McCLURE/OSHA REFERENCE: JOHN STENDER'S LETTER OF AUGUST 6, 1974, TO MR. H. B. VANDERBILT, R.T. VANDERBILT CO., INC. In response to your request, I called Howard Schulte and discussed with him the subject letter. He was obviously entirely familiar with 1t. Mr. Schulte stated that the whole interpretation of the letter hinges upon the definition of "asbestiform" and "non-asbestiform". In response to my question as to what was the current definition of as bestiform, or differentiation between asbestiform and non-asbestiform, he stated that the definition is the same as previously used in conjunc tion with the asbestos regulations, specifically that the aspect ratio be 3:1 or greater, and that the .length be greater than 5 microns. He amplified his definition by saying that if a talc sample were examined under a microscope and more than 5 a r tifa c ts/c c were counted, which f i t this definition, it would be termed a violation of the OSHA regulations. When I pressed him concerning the difference between artifacts and tremolite, he stated that,"We cannot take tremolite from the standard at this time." He further stated that OSHA technicians have never seen arti facts which fit the above definition which they consider to be non-tremoUtic. He stated that NIOSH is currently studying the possibility that there do exist non-tremolitic "slivers" which should be differentiated from the tremolitic fibers and which, because they are (perhaps) not a health hazard, should not be counted when evaluating a talc sample. However, the results of this studyare~one to two years off. In answer to my query, he stated that the Vanderbilt Company argued the above point, namely that such "slivers" do exist and that it is inac curate and unfair to include them in any fiber counts associated with talc sampling. He went on to say .that despite Vanderbilt's arguments, OSHA was not going along with this concept, unless and until the NIOSH study mentioned above confirmed it. As our conversation drew to a close, Mr. Schulte suggested that since I had asked so many detailed and technical questions, it would be well for me to talk to Ray McClure. He told me that he would have Ray call me later today. CRMC-MAD-000699 if r E. M. Fenner/R. P. Carter August 28, 1974 J Page Two Later this morning, Ray McClure called and referred to my conversation with Howard Schulte. He started by explaining that the Vanderbilt mining operations are un der the jurisdiction of MESA, not SHA. Their concern with the OSHA regulations is because of their customers who have read the asbestos regulations and are worried about being cited in their plant operations because of possible tremolitic content in the talc. Mr. McClure said that John Stender's letter of August 6, 1974, was an & & ?+* to give some relief for this situation, but doubted that it did so very effectvr?!". He stated that he was presently 'ir r it e ? certain modifications to the standard as presently written. His recomrh&VKfetions are to NIOSH, and must be approved by NIOSH before they can be seriously considered or promulgated. In answer to my question as to what specifically he was recommending, he cautioned me to realize that these were wholly tenta tive and stated that they Were: 1. ' Revise the aspect ratio in the fiber definition (as associated with talc) from 3:1 to ,5:1. He noted that such a recommendation -- would be contingent upon NIOSH opinion regarding the health aspect. 2. Do not count any fibers whose diameter is greater than 5 microns. 3. Require that the microscopist attempt to make positive identifi cation of fibers as being asbestos particularly by means of observ ing the fiber end configuration. He stated that the Salt Lake City laboratory consists chiefly of OSHA people, now, and that the microscopists already attempt to differen tiate between true tremolitic fibers and other non-fibrous artifacts which would be classified as fibers if judged only by aspect ratio and length. (Please note the discrepancy between this note and Howard Schulte's) Mr. McClure stated that if the above changes are successfully promul gated, the standard will probably require sampling by the "asbestos technique" and by impinger. Whether or not a given station is over TLV will be judged by whichever criterion is stricter. OSHA is also consi dering requiring high volume air samples to permit chemical or minera lgica! analysis of the airborne dust. v; t,* n U.S. DEPARTM ENT O F LABOR Occupational Safety and. Health Adminiurauon WASHINGTON, D.C. 0210 Office of the Assistane Secretary 0 0> ' * August 6, 1974 Hr. H. B. Vanderbilt President........ R. T. Vanderbilt Company, Inc. 30 Winfield Street Norwalk, Connecticut 06855 . 4 Dear Mr. Vanderbilt: Your request for an interpretation of the asbestos standard, section 1910.93a, as it related to tremolite talc has been]given deep consideration. The following interpretation of the standard, 1910.93a, is'collectively the opinions of both the Occupational Safety and Health Administration and the National Institute for Occupational Safety and Health. The present asbestos standard is written for the purpose of controlling exposures to the fibrous or asbestiform minerals.commonly considered to be asbestos. This is reflected in the established permissible limit for asbestos air contamination to which a worker may be exposed. This is expressed in terms of numbers of fibers in excess of a pre scribed length per unit of volume. The- required method of determination or analysis is also expressed as a method for counting fibers. Therefore, nonfibrous or non-asbestiform minerals such as non-asbestiform tremolite are r-at within the scope of the existing standard. Talc containing only non-asbestiform tremolite is not regulated by the standard 1910.93a. For emphasis, if only talc and non-fibrous tremolite are present, there is no violation of the asbestos standard. Talc containing asbestiform tremolite or other fibrous asbestos minerals will be regulated by the standard 1910.93a. [JohftpH. Stender isiBtant Secretary of Labor :js>* CRMC-MAD-000701 Johns-Manville Internal Correspondence To: P. Kotin, M.D. P. .'ter */ D a t o : April 8, 19 75 C o p i e : File ii Chrono Subject: M O N T H L Y A C T I V I T Y REPORT DIRECTOR, GOVERNMENT AFFAIRS MARCH, 1975 FDA REGULATION OF GLASS FIBER FILTERS The Food and Drug Administration promulgated a regulation restricting the use of glass fiber filters in the manufacture of parenteral drugs. Met with J-M's Washington law firm to prepare a notice contesting this regulation. Met with various FDA officials to ascertain why this regulation was promulgated. PVC PIPE MIGRATION STUDIES Prepared and sent letters to both EPA and FDA reporting the results of Phase II of J-M's PVC pipe (VCM migration) studies. Met with EPA and FDA officials along with Randy Prust of R&D to review our test results. No objections were received from either agency as to J-M's test procedures or results. EPA has agreed to conduct field studies in communities supplied drinking water through PVC pipe. UNI-BELL BOARD OF DIRECTORS MEETING Delivered a presentation to the Board of Directors of Uni-Bell on J-M's PVC pipe migration studies and a prognosis of actions by EPA and FDA on PVC pipe. The member companies of Uni-Bell agreed to supply necessary data to EPA for PVC pipe field studies. FEDERAL TRADE COMMISSION - TALC LABELING Met with two members of the FTC staff along with Aaron Finkbiner to discuss the possibility of the FTC bringing suit against R. T. Vanderbilt Company for false certification of their talc. FDA REGULATION OF TALC CONTAINING ASBESTOS c. As a result of studies conducted by J-M, the FDA published J a notice in the Federal R e g i s t e r withdrawing l t . ' J proposed ) regulation restricting the use of talc containing asbestos in food and druc packaging paper and paperboard. CRMC-MAD-000702 V Johns-Manville To: W. C. Streib, R&D Center From: r . s. Lamar, R&D Center Copies: See End of Correspondence S u b j e c t : TELEPHONE CONVERSATION NOVEMBER 26, 1974 WITH BOB R. T. VANDERBILT COMPANY REGARDING CHANGE IN OSHA TREMOLITE TALC Bob Bacon had been trying to reach Dick Carter to inform him of a basic policy change within OSHA. Bacon has within the last few days received a copy of an OSHA Information Memo, dated November 21, 1974, directed to all OSHA field managers. The memo is too long and complicated to reproduce here. Bacon promised to mail a copy to me. There are, however, a number of key changes in policy that would appear to bear directly on our decision to label our talc products: 1. O n l y f i b e r s n o t s l i v e r s o r a c i c u l a r p a r t i c l e s w i l l be counted. Fibers must be composed of fibrils and must exhibit frayed ends. If necessary TEM's will be used to identify frayed ends of fibers. Under this definition tremolite in no way can be counted as a fiber. u 3. Only fibers gj^terj than 3 n diameter anda.30 u in length shall bacounted. M V* 4. A fiber must have an aspect ratio greater than 5/1 (not 3/1) . Beyond just compliance with the law what now is J-M's moral obligation? R. T. Vanderbilt Company is still very upset with our decision to label. Bacon now feels more strongly than ever before that they are not subject to the law and that neither is J-M. I kind of like our present "Mr. Kleen" stature. R. S. Lamar rr See Distribute . on Reverse Side CRMC-MAD-000703 c /L y c ^ ** ff*' e s * " '? * 1' * Area Sales Managers Harry '. A. ' CAUTION R. Keefe CONTAINS h W Z R T O S FIBERS AVOID CRD.Y1 IDO DOST. Martinson# H. Kranich# N. B. Scheffel# C t : R z < , `.>;> b.FLV September 20# 1974 T. E. R e a m e r s / D / C Talc Label *rni;. o.vnt'rcul :alc product contains fibrou3 ru n h '.en ci:.S 3i*:i-.ci bv 05KA. Ail shipments of Desert Minerals Talc shipped from Los Angeles o r Dunn will bea r the a t t a c h e d label eff e c t i v e N o v e m b e r 1, 1974. The attached letter should/must be sent to all carload a n d si g n i f i c a n t L C L c u stomers b y O c t o b e r 1# 1974. Ple a s e direct letters to an individual# by name instead of just to corporate name where possible. The use of the asbestos label is required by law. 1 believe you all know the reasons why we have to use this particular label but if you have any questions# please: call me. The label may have a serious effect on our talc business. Please report any/all reactions to the label# particularly a d v e r s e reactions. , ;..r. i.sv.u r y. n. Initially# the label will be a paste-on. When we re-order bags# the label will be imprinted. We will use a stamp with water soluble ink for cyclonized shipments in white# repulpable bags. On the good side# the FDA has accepted our migration data on tremolite talc in paper and it is expected that within the next three months they will publish a position paper in the Federal Register s t a t i ngthere is no need for a regulation banning the use of talc in food packaging. More information on this will be sent to you shortly. Harry R. Keefe H R K :ccr Attachment CRMC-MAD-000704 fct ,,  CAUTION CONTAINS ASBESTOS FIBERS AVOID CREATING DUST. BREATHING ASBESTOS DUST MAY CAUSE SERIOUS BODILY HARM. This commercial talc product contains fibrous treraolite, w h i c h has been classified by OSHA as an asbestiform mineral. Compliance with OSHA standards and regulations for exposure to asbestos and compliance with any state and local standards which may exist is required. CAUTION PROLONGED EXPOSURE TO EXCESSIVE' - QUANTITIES OF TALC DUST ALONE MAY ' BE INJURIOUS TO HEALTH. AVOID ^ CREATING AND BREATHING TALC DUST. RESPIRATORS OR DUST MASKS APPROVED BY NIOSH OR THE BUREAU OF MINES ARE RECOMMENDED. v,. ' CRMC-MAD Johns-Manvile Products Corporation nitration A Minonli DMtlon Gratnwood Plazu Donvar, Colorado 80217 (303)770-1000 Our California talcs contain varying percentages of tremolite, a crystalline mineral w h i c h m i n e r a l o g i c a l l y hac been defined as an amphibole of asbestos. A c c o r d i n g l y , e f f e c t i v e N o v e m b e r 1, 1974, al l b a g s of Desert Minerals Talc shipped from our California plants will be labeled with an asbestos caution notice. Since the major percentage of the mineral in the bag is talc, we have also included on the label a caution notice concerning the inhalation of talc dust. Below is the text of the label which will appear on our bags: CAUTION CONTAINS ASBESTOS FIBERS AVOID CREATING DUST. BREATHING ASBESTOS DUST MAY CAUSE SERIOUS BODILY HARM. This commercial talc product contains fibrous tremolite, which has been classified by OSHA as an asbestiform mineral. Compliance with OSHA standards and regulations for exposure to asbes t o s and c o m p l i a n c e w i t h a n y state and' local standards which may exist is required. CAUTION PROLONGED EXPOSURE TO EXCESSIVE QUANTITIES OF TALC DUST ALONE MAY BE INJURIOUS TO HEALTH. AVO,ID CREATING AND BREATHING TALC DUST. _ .. RESPIRATORS OR DUST MASKS APPROVED' BY NIOSH O R THE BUREAU O F MINES CRMC-MAD-000706 ARE RECOMMENDED. Page 2 If you should have any questions, please do not hesitate to contact us. -- Sincerely yours, Vice-Pi^ General Marketing Manager, Minerals HRK:ccr CRMC-MAD-000707 TAI.C bAliF!/IK(> !!.!'. lw >!' and the writer mot Ihi s dute with J.F. Solon, R.F, Curter, ;ri:<I Fenner. There Is obviously considerable confusion on the total subject iiu: I.ud iug Uio interpretation of the definition of an asbestos fiber. If is recognized that the 1972. OSIJA regulation clearly requires that talc coniaining asbestos fiber must be labeled. However, M.E.S.A., who lias published the same definition of asbestos fiber as OSHA, has advised R.P. Carter that in all of the talc samples they have analyzed thus far, they have detected no tremolitc fibers in accordance with their unpublished and informal definition of a fiber. Apparently, some governmental agencies interpret the definition in another maimer than literally. Because of this confusion, Filtration and Minerals'management to date has delayed labeling Dcsertalc products. In consideration of the many facets, including continued confusion, brought out at today's meeting, the wrtior is making the decision to further delay labeling to not later than November 1, 197^> providing a label is required and this requirement subject to clarification based on investigations and findings as follows: 1. R.P. Carter to contact 11. Bacon of R.T. Vanderbilt Company to determine status of visit by'OSHA and NTOSH people to their pi nit for (lie purpose of taking samples for analysis. 2. Ji.I'. Carter !o contact Mr. Boyd of OSHA regarding talc sampling -- the source of samples - whether air samples (plant or mine or both, etc.). Also, details of methodology for sample evaluation, analytical or oilier. CRMC-MAD-000708 C.J. Su Icvv'slii Tale Labeling . Augii.!. -2] , 1 9 7 4 . l'ago 2 Vitli Ilio in l'orma li on of Tloms //l and 2 ami ihrough Mr. Solon and iiis poople, a duci ai on vili, la: mudo what' furthcr sampling neodu lo lx; dono in J-M operations -- plants or niincs as wol l as fini siici odaci sampling and ovuluali on -- Ilio lattar u s i i j -fflaiicodo logy-,------ ----------- al It.F Curler will follow with OSIIA/NXOSII to doterminc results of sampling at It.T. Vanderbilt and determine if oir sample analytical recoil is are to be interpreted as representative, of .actual product sampling and evaluation. All ol above in attempt to have OSIIA/NTOSH evaluate J-M talc on some basis as (hey evaluate R.T. Vanderbilt talc and for opinion from OSIIA/NIOSII as to the question of: Does J-M talc contain asbestos fiber in o s i r A / M o ^ ; --------- ----- _ It is expected that guidance from Solon's people on Item 1 through 4 will be available within' the next 15 days and further procedural steps will be determined and implemented and all advised accordingly / ./1 cc : J.A. McKinney F.L. l'und.sack J.F. Solon,Jr. W.L. VanDei'beek Dr. Paul Kotin E.M. Fenner R.P. Carter W.B. Reitze -Vi R.S.-Lamar ' S. R. Spoil W.C. Streih II.N. Havens T.M. Jackson C.I. Keel an P.D. Hicliards D C - JW - Jl&D - 4N - 2S - 4N - " - " - " P&D . -- " CRMC-MAD-000709 T: G. L. Swallow Dato: July 2, 1974 From: h . Kranich Copies: See Below S u b je c t: /Talp^Labeling ^ o u r Letter 6/24/74 to H. R. Keefe Your letter seems to make it impossible to use our previously stated position and we will have to omit it from our announce ment letter. In effect, then, we have no "easy" response to customer queries other than they have to meet asbestos standards even though they may meet talc levels. Is there any option left? Your letter refers to our own plant surveys--at a time when we had poorer control. Would new tests there be any different? I seem to recall we (you) made checks at one to two customer work stations. Were these results any better? Would you consider these questions in light/possibility any chance at all to salvage the qualifying statement? I will hold off preparing the letter until next week. Please give me your advice and comment. Thanks. cc: R. P. Carter, 4N W. A. Cooper, 4N E. M. Fenner, 4N D. E. Hillier, 4N T. M. Jackson, 2W P. Kotin, M.D., 4N R. S. Lamar, Research R. W. MeIndoe, 2W F. J. Solon, J r . , 4N W. C. Streib, Research R. B. VonWald, 5W D/C CRMC-MAD-000710 m Johns-Manville lb: R. G. Riede Internal Correspondence Date: July 2, 1974 From: H. K r a n i c h Copies: See Below Subject: Talc Labeling We will need to label all talc shipments starting September 1, 1974. This to include: 1. Desertalc in bags 2. Bulk shipments 3. Products in white, repulpable bags Plants will need to arrange for bag imprinting for deliveries on and after September 1, but not use before September 1. Until bags are in they will need to arrange to have glue-on labels prepared. Glue-on labels could be a problem for white beater bags. I can only suggest the making of a large rubber stamp (perhaps two) and use water soluble ink. Perhaps this may be obtained from bag supplier. For bulk shipments we can use glue-on labels affixed somewhere to the truck or tanker for each delivery. The copy for the label is attached. Some comments: 1. We want the imprint/label on the back of the bag, not the face. 2. The label is in two parts and should be slightly separated. 3. We want the notice to be small in dimensions (particularly in Cyclo products) but still has to be legible. 4. The capitalized portion should stand out. 5. I'd think the label and/or notice can be about 3%" x 4" in size, and still be legible. 6. As above, perhaps two rubber stamps for Cyclo. Stamp the talc caution below the asbestos in middle of bag. 7. Propose a local printer print up labels on "tan Kraft" color stock to match kraft bag color, CRMC-MAD-000711 R* G. Riede Page 2 J uly 2, 1974 Please let me know if I may advise further. Thanks. Herb Kranich HK:ccr P.S. Please send me couple label samples when run off. cc: R. K. Comann D. T. T ash H. R. Keefe N. B. Scheffel R. P. Carter W . A . Cooper E. M. Fenner D. E. Hillier T. M. Jackson P. Kotin R. S. Lamar ft. w. Mc t n d o e . W. B. Reltze'4^ " " S. w. Schu l m e y e r F. j. Solon, Jr. W. c. S treib R. B. VonWald D/C CRMC-MAD-000712  < 9 \ i ( 11 r ) \9 y * . * . 4 ..C CAUTION CONTAINS ASDESTOS FIBER ` I AVOID CREATING DUST. BREATHING ASBESTOS FIBER MAY CAUSE SERIOUS BODILY HARM. This commercial talc product contains fibrous TremolitG/ v/hich has been classified by OSHA as an asbestiform mineral. Adequate dust control as is currently required by OSHA mineral dust standards is recommended'to bring this product into compliance with OSHA's standard for exposure to asbestos dust. CAUTION PROLONGED EXPOSURE TO EXCESSIVE QUANTITIES OF TALC DUST ALONE CAN BE INJURIOUS TO HEALTH. AVOID CREATING AND BREATHING TALC DUST. RESPIRATORS OR DUST MASKS APPROVED BY NIOSII OR THE BUREAU OF MINES ARE RECOMMENDED. P it { CRMC-MAD-000713 V* 2431G RUIES AND REGULATIONS Title 30-- Mineral Resources cernlng wire rope uttc liments has been Part 55, Title 30 Code of Federal CHAPTER I-- BUREAU OF MINES, deferred so Hint the Department may Regulations is amended and revised as undertake additional review, study and follows: DEPARTMENT OF THE INTERIOR analysis of aueh changes .prior to taking 9 .i.Vj I Vinemieill SUBCHAPTER N-- METAL ANO NONMETALLIC MINE SAFETY further action with respect to tills stand ard. Most of the comments received were 1. Standard 55.5-1, promulgated on PART 55-- HEALTH AND SAFETY STAND In response to proposed health standard December 8, 1070 (35 FR 18587), Is re- ARDS-- METAL AND NONMETALLIC 55.5-1 (38 FR 23383 >. As a result of these vised to rend as follows: OPEN PIT MINES comments the following changes lire 55 5-1 ,Mandatory. Except as permitted by Miscellaneous Amendments made: I 66.5-6: Pursuant to the authority vested in Standard 55.5-1. <n) Editorial changes <al Except ns provtded in paragraph lb), tho Secretary of the Interior under sec havo been made in paragraphs (id and ib) to clarify the requirements of these tho exposure to airborne contaminants shall mil oxceed, on the basis of a time weighted tion 6 of the Federal Metal and Nonmetallic Mine Safely Act <30 U.S.C. 725) provisions: and average, the threshold limit values adopted by the Armerlcan Conference of Govern to develop, revise and promulgate health (b) The Threshold Limit Values pub mental Industrial Hygienists, as set forth and and safety standards for metal and non- lished In the 1972 edition of the American explained In tho 1973 edition of the Con- metal mines, there was published on Conference of Governmental Industrial fcrcnce'n publication, entitled "TLV's Thresh Wednesday, August 29, 1973, a notice Of Hygienists publication have been up- old Limit VsluM for Chemical Subsume iiroiMtaetl ruh'inn HiUK In the Yl'KSsL Register <38 FR 23383 and 23384), to dated to te Conference's 1073 edition which supersedes and replaces the 1972 in Workroom Air Adopted by ACOIit lor 1073." pages 1 through 64, which are hereby amend Part 55, Subehapter N, Chapter I, edition: nnd incorporated by reference and made a part hereof. This publication may be obtained Title 30, Code ot Federal Regulations, by (c> An 8-hour time weighted average from the American Conference of Govern revising and revoking certain standards exposure of personnel to airborne con mental Industrial Hygienists by writing to currently in force and by adding new centrations of asbestos dust has been the Secretary-Treasurer, P.O. Dox 1037. Cin standards Each of the standards con specified In paragraph (b ); and ^ cinnati. Ohio 45201, or may be examined In tained in the notice was developed or revised after consultation with the Fed ^ (d) The paragraph term (b> is "asbestos" as used in* defined to Include only any Metal and Safety District Nonmetal Mine Health and or Subdistrict Ofilce of the eral Metal and Nonmctal Mine Safety chrysotlle, nnioslte, crocldollte, antho- Mining Enforcement and Safety Administra tion. Excursions above the listed thresholds Advisory Committee appointed pursuant phylite asbestos, tremollte asbestos, and shall not he of a greater magnitude than Is to section 7 of the Act <30 U.S.C. 728). actinollto asbestos, or thoso minerals characterized as permissible by the Confer The notice further provided that each which are essentially known as asbestos ence. w proposed standard which is to be a man minerals. The latter three minerals use (b) The R-hour tlma weighted average air datory standard was so designated by the word asbestos because the same min borne concentration of asbestos dust to the word "Mandatory" which appeared eral name is used for both the asbestl- which employees are exposed shall not ex at the beginning of the standard and if a standard had been recommended by form and non-asbestlform varieties of these minerals. Tremollte of a non- ceed 6 fibers per milliliter greater than 5 microns In length, as determined by the the Federal Metal and Nonmetal Mine asbestlform which occurs In tnlc deposits membrane filter method at 400-400 magni fication. (4 millimeter objective) phase con Safety Advisory Committee, such stand- is not mentioned in the definition _and, trast Illumination No employ hn <;- *r2 Wd.s cmiiud by uie letters theiefore, is not covered. posed at any time to airborne concentra "MNMSAC." Under the provisions of Note: On May 8, 1973 a public symposium tions of asbestos fibers In excess of 10 fibers subsection 6(e) of the Act <30 U.S.C. was hold in Washington, D.C. to receive data "longer than 5 micrometers, per milliliter of 725(e) ) a standard recommended by the on talc dust hazards In the metal and non- air, as determined by the membrane filter Advisory Committee was not subject to hearings. metal mining Industries (see 38 FR 7822). Medical data based on both human and method over a minimum sampling time of 15 minutes. "Asbestos" Is a generic term for Subject to the provisions of subsection animal studies were presented. This data supported the opinion that tnlc nnd tnlc with a number of hydrated silicates that, when crushed or processed, separate Into flexible 6(e) of the Act and in accordance with tremollte are not as hazardous ns chrysotlle fibers made up of fibrils. Although there the provisions of subsection 6(d) (30 or other true asbestos minerals. The Mining are many asbestos minerals, the term "as UJS.C. 725(d) ) on or before the last day Enforcement and Safety Administration and bestos" as used herein is limited to the fol of the period fixed for the submission of the National Institute or Occupational Safety lowing minerals; chrysotlle, nmosit, crocldo written data, views, or armaments, any and Mealtli are planning a Joint atudy to llte, nnthophyllte asbestos, tremollte asbes person who may be adversely affected by determine the toxic nature of talc and tre tos, nnd actinollte asbestos. a proposed standard which had,not been mollte dust exposure. Pending the results of this study both fibrous talc and tremollte (c) Employees shall be withdrawn from areas where there Is present an airborne con recommended by the Federal Metal and (non-nsbcstlforiii) arc subject to the adopted taminant given a "C" designation by the Nonmetal Mine Safety Advisory Com threshold limit values under paragraph (a) Conference and tha concentration exceeds mittee was afforded an opportunity-to of this standard (see page 33 of the confer the threshold limit value listed for that file with the Secretary of the Interior ence's 1973 publication). contaminant. written objections thereto stating tin grounds for such objection and rcquesl lng a public hearing (subject to the Ad' ministrative Procedure Act) on su< subject. Interested persons were requested submit written data, views, arguments and requests for hearings to the Admin istrator, Mining Enforcement and Safety Administration (MESA) on or before October 15, 1973. No hearings were re quested on the proposed standards which were designated as "Mandatory" by the Secretary of the Interior, and all of the data, views and arguments rcrelved con cerning the standards were given careful consideration. The comments and recommendations received Indicated supiw t for the stand ards which are promulgated below Pro mulgation of the proposed revision to standard 55.19-24 (38 FR 23384) con- (e) Paragraph (b> is further revlscdl 2, Standard 55.5-5, promulgated on to provide the allowable peak or celling ,December 8, 1970 (35 FR 18587), is re concentration of asbestos fiber. This vised to read as follows: celling concentration is 10 fibers longer] than 5 micrometers, per milliliter of nlr.i 55.5-6 Mandatory. Control of employee ex as determined by the membrane filter | posure to harmful 'shall be, insofar as airborne contaminants feasible, by prevention method over a sampling time of 15 [ of contamination, romoval by exhaust ven minutes. tilation. or by dilution with uncontaml- Effective date. The amendments, re nated air. However, where accepted engineer visions and revocation of standards, and ing control measures have not been devel new standards shall become effective on oped or when necessary by the nature of July l. 1974. work Involved (for example, while establish ing controls or occasional entry Into haz Part 55 of Chapter Xof Title 30 of the ardous atmospheres to perform maintenance Code of Federal Regulations is amended or Investigation), employees may work for asset forth below: reasonable periods of time In concentrations luce, 8. Federal Metal and Nonmetalllc Mine ot airborne contaminants exceeding permis Safety Aet( 80 Stat. 772; (30 U.S.C. 725)) sible levels If they are protected by appro priate respiratory protective equipment. Dated: June 28,1974. Whenever respiratory protective equipment la used a program for selection, maintenance, C. K. M allory, training, fitting, supervision, cleaning, and Deputy Assistant Secretary use shall meet the following minimum of the Interior. requirements; FIOfKAl REOISTIt, VOl. 34, NO. 12F-- MONDAY, JUtV 1, W 4 CRMC-MAD-000714 RULES AND REGULATIONS 24317 (a) Mining Ernorccment and Safely Ad 55.15 [Amended] the beginning of the standard and if a ministration pitrevecl rrxptrRtors which ir applicable and auliable Mr lha purpovi in. a, Standard 68.16-13, promulgated on standard had been recommended by the Federal Metal and Nonmetal Mine Safety tended ahall be furnished, and employees shall use the protective equipment in ac February 25. 1970 <35 FR 3664). is revoked. Advisory Committee, such standard was cordance with training and Instruction. identmed by the letters "MNMSAC." (b) A respirator program consistent with 55.19 [Amended] Under the provisions of subsection 6<e) the requirements of ANSI ?.88.'J-190U, pub 9. Standard 55.19-7, promulgated on of the Act <30 U.S.C. 725(e)) a standard lished by the American National Standards July 31, 1969 (34 FR 12509) Is revised recommended by the Advisory Commit Institute and entitled American National to read as follows: tee was not subject to hearings. Standards Practices for Respiratory Protec Subject to the provisions of subsection tion ANSI Z88.2 1909." approved August 11, 55.19- 7 Mandatory. All man hoists shall 6te) of the Act and in accordance with 1969. which is hereby Incorporated by refer ence and made a part hereof. This publi be provided with devices to prevent over travel. When utilized In shafts exceeding the provisions of subsection 0(d) <30 cation may be obtained from the American 100 feet In depth, such hoists shall also U.S.C. 725(d)) on or before the last day National Standards Institute, Inc., 1430 be provided with overspeed devices. of the period fixed for the submission of Broadway, New York, New York 10018. or may be examined In any Metal and Non- 10. New standard 55.19-13 Is added to written data, views, or arguments, any person who may be adversely affected by metal Mine Health and Safety District or read as follows: a proposed standard which had not been Subdistrict Office of the Mining Enforce 55.19- 13 Mandatory. Where any diesel or recommended by the Federal Metal and ment and Safety Administration. similar fuel-injection engine Is used to power Nonmetal Mine Safety Advisory Com (c) When respiratory protection Is used In atmospheres Immediately harmful to life, the a hoist, the engine shall be equipped with a damper or other cutofT In Its air Intake sys mittee was afforded an opportunity to file presence of at least one other person with tem. The control handle ahall be clearly with the Secretary of the Interior writ backup equipment and rescue capability labeled to Indicate that Its Intended func ten objections thereto stating the shall be required in the event of failure tion Is for emergency stopping only: grounds for such objection and request of the respiratory equipment. 11. Standard 55.19-26, promulgated on ing a public hearing (subject to the Ad ministrative Procedure Act) on such sub 3. Standard 55.6-5, promulgated on December 8. 1970 <35 FR 18587), is July 31, 1969 <34 FR 12509) Is made mandatory and revised to read as ject. revised to read as follows: follows: Interested persons were requested to submit written data, views, arguments 66.6-5 Mandatory. Areas surrounding 55.19- 28 Mandatory. Safety device attach and requests for hearings to the Ad magazines and facilities for the storage of blasting agents shall be kept clear of rubbish, ments to hoist ropes shall be selected, In stalled, and maintained according to manu ministrator, Mining Enforcement and Safety Administration (MESA) on or be brush, dry gras3. or trees (other than live trees 10 or mors feet tall), for a distance not facturers' specifications to minimize internal corrosion and weakening of the hoist rope. fore October 15, 1973, No hearings were leas than as feet in all directions, and other requested on the proposed standards unnecessary combustible materials for a dis 12. New standard 55.19-109 is added which were designated as "Mandatory'' tance of not less than 50 feet. to read as follows: by the Secretary of the Interior, and all 4. New standard 55.6-12 is added to 55.19- 109 Mandatory. Shaft Inspection of the data, views and arguments re read as follows: and repair work In vertical shafts shall be ceived concerning the standards were performed from substantial platforms given careful consideration. 65.6- 12 Mandatory. Prior to Interior repair equipped with bonnets or equivalent over c: facilities for storage of evplnsives includ head protection. The comments and recommendations received indicated sunoort. for the stand ing blasting agents, all materials stored within the facility shall be removed end 13. New standard 55.19-129 is added ards which are promulgated below. Pro the Interior cleaned. Prior to the exterior to read as follows: mulgation of the proposed revision to repair of such facilities, all materials stored within the facility shall be removed if there 55.19- 120 Mandatory. Holstmen shall ex standar cerning d 56.19-24 wire rope a (38 ttac FR hme 23388) nts lias con been exists a possibility that such repairs may amine their hoists and shall test overtravel, deadman controls, position Indicators, and deferred so that the Department may produce a spark or flame. The explosives removed from storage facilities to he re braking mechanisms at the beginning of each undertake additional review, study and paired shall be placed either In other stor shift. analysis of such changes prior to taking age faculties appropriate for the storage of (FR Doc.74-14976 Filed 6-28-74:8:45 am] further action with respect to tills such materials under this section or a safe standard. Most of the comments received distance from the facilities under repair were in response to proposed health where they shall be properly guarded and PART 56-- HEALTH AND SAFETY STAND standard 56.5-1 (38 FR 23385). As a re protected until the repairs have been com ARDS-- SAND, GRAVEL, AND CRUSHED sult of these comments the following pleted and the materials have been returned STONE OPERATIONS changes are made: to storage within the facilities. Miscellaneous Amendments Standard 56.5-1. (a) Editorial changes 55.8 [Amended] 5. New standard 55.8-6 is added to Pursuant to the authority vested in the Secretary of the Interior under section 6 have been made In paragraphs (a) and <b> to clarify the requirements of these read as follows: of the Federal Metal and Nonmctnllic provisions: and 66.6- 6 Mandatory. The oxygen Intake Mine Safety Act <30 tr.S C. 725) to de (b> The Threshold Limit Values pub coupling on Jet-plerclng drills shall be con velop, revise and promulgate health and lished in the 1972 edition of the Ameri structed so that only the oxygen hose can be coupled to It. safety standards for metal and nonmetal can Conference of Governmental Indus trial Hygienists publication have been 6. New standard 55.8-7 is added to mines, there was published.on Wednes day. August 29, 1973, a notice of proposed updated to the Conference's 1973 edition read as follows: rulemaking in the F ederal R egister <38 which supersedes and replaces tho 1973 FR 23384-23386), to amend Part 56, SQb- edition; and 58.8-7 Mandatory. The combustion cham ber of a Jet drill stem which has been sit chapter N, Chapter X, Title 30. Code of <c> An 8-hour time weighted average ting unoperated In a drill hole shall be Federal Regulations, by revising and re exposure of personnel to airborne con .flushed with a suitable solvent ofter the voking certain standards currently In centrations of asbestos dust has been stem Is pulled up. force and by adding new standards. Each specified in paragraph (b); and 6 55-12 [Amended] of the standards contained In the notice <d> The term "asbestos" as used in was developed or revised after consulta paragraph <b) is defined to Include > 7. Standard 55.12-32, promulgated on tion with the Federal Metal and Non- chrysotlle. amoslte, crocldollte. July 31, 1909 <34 FR 12507) Is made metal Mine Safety Advisory Committee thophyllte asbestos, tremollte ast* mandatory and revised to read its appointed pursuant to section 7 of the and octlnolitc asbestos, or those mUu -is follows: Act <30 U.S.C. 726t. which are essentially known as axLc.-tos 65.12-32 Mandatory. Inspection and cover The notice further provided that each minerals. The latter three mineral > use plates on electrical equipment and Junction proposed standard which is to be a man the word asbestos because the same boxes shall be kept in place at all times datory standard was so designated by the mineral name la used for both the as- except during testing or repair. word "Mandatory" which appeared at bcstlform and non-asbcstlform varieties FIDtKAl HOIST!*, VOl. 3*. NO. 127--MONDAY, JULY I, 1974 ti *i ta' -,* sI fcab vi.* i Johns-Manville interna! Correspondence t To: Filtration and Minerals J Environmental Committee Members-* Pinm; Harry R.,,_Keae Dato: June 21, 1974 Copier, Listed Next Page Sub, *E. M. Fenner R. P. Carter W. A. Cooper D. E. Hillier T. M. Jackson, Jr. R. W. Mclndoe W. B. Reitze * S. W. Schulmeyer F. J. Solon, Jr. W. C. Streib R. B. VonWald Paul Kotin, M.D. G. Swallow R. S. Lamar Attached is the tentative letter we will send to our talc customers over my signature adivisng them that we will label all plant shipments effective September 1, 1974. Please review to prevent any erroneous statements. I particularly call your attention to the third paragraph. It is my understanding from tests run by Environmental Control Department that these statements are correct. I request that W. B. Reitze and D. Hillier/G. Swallow comment. The label itself has been modified, removing the "% fibrous tremolite" and changing the wording of this paragraph. Many of you in your comments to my June 12, 1974 letter questioned our timing. Our plan and the reasons are as follows: Customers will be contacted by letter during the month of July informing them of our September 1, 1974 labeling schedule. Some customers will be contacted personally. It is necessary to give some customers 30 days or more time to formulate us out and find and receive a suitable substitute. If we were to label immediately, we could have customer plant shutdowns in various locations due to employees' refusal to handle or customers' refusal to accept material and consequently have no alternate raw material. CRMC-MAD-000716 Environmental Committee Members Page 2 June 21, 1974 Considering our plan to have Penhorwood on stream in mid '75 with a tremolite-free talc, these same asbestos concerned customers would be potentials for Penhorwood talc. We would not like to leave them with a bitter taste for J-M by a hasty labeling action. H R K :ccr Attachment cc: C. J. Sulewski W. L. VanDerbeek P . A . Martinson H. Kranich N. B. Scheffel G. Coombs R. G. Riede K. R. Corcann D/C c k m c -m a d -000117 Johns-Manville Products Corporation FfUration A Mlnarala Dlvlalon Greonwood Pin Donvor, Colorado 80217 (303) 770-1000 Gentlemen; Never in the history of American industry has so much emphasis (and rightly so) been placed on employee safety. The voluntary and required installation of dust control equipment is testimony to this statement. There is no good that will come from the inhalation of any dust. Dust must be controlled. To emphasize this point, all bags of Desert Minerals talc will be labeled with a caution notice effective September 1, 1974. Our California talcs contain varying percentages of tremolite, a crystalline mineral which mineralogically has been defined as an amphibole of asbestos. Due to this, it is our opinion the bags should contain an asbestos caution. Since the major percentage of the mineral in the bag is talc, we have also included on the label a caution notice concerning the inhalation of talc dust. OSHA regulations require the control of talc dust to 20 MPPCF. If the talc is controlled to this level, our tests have shown you will also meet the OSHA asbestos standards. Below is a sample of the .label which will appear on our bags: CAUTION CONTAINS ASBESTOS FIBER AVOID CREATING DUST. BREATHING ASBESTOS FIBER MAY CAUSE SERIOUS BODILY HARM. This commercial talc product contains fibrous Tremolite, which has been classified by OSHA as an asbestiform mineral. Adequate dust control as is currently required by OSHA mineral dust standards is recommended to bring this product into compliance with OSHA's standard for exposure to asbestos dust. CRMC-MAD-000718 Page 2 CAUTION PROLONGED EXPOSURE TO EXCESSIVE QUANTITIES OF TALC DUST ALONE CAN BE INJURIOUS TO HEALTH. AVOID CREATING AND BREATHING TALC DUST. RESPIRATORS OR DUST MASKS APPROVED BY NIOSI) OR THE BUREAU OF MINES ARE RECOMMENDED. We feel the labeling of our product, as with all products which could cause a dust condition, is in the best interest of you and your employees. Should you have any questions, please do not hesitate to contact me directly. Sincerely yours, Harry R. Keefe Vice-President and General Marketing Manager, Minerals IIRK:ccr CRMC-MAD-000719 Johns-Manville internal Cdrrfespondence H. R. Keefe - 2W/2 June 13, 1974 D. E. Hill 1er - 4N/3 Paul Kotin, M.D. E, M. Fenner R. P. Carter F. J. Solon, Jr. File & Chrono TALC LABELING YOUR LETTER JUNE 12 In accordance with your request, I would like to comment with regards to the proposed label. I would use the word "approximately" instead of "maximum" and would change other words per the following rewrite: This commercial talc product may contain approximately ___ % fibrous Terrnolite, which has been classified by O.S.H.A. as an asbesti-form mineral. Under normal conditions of usage, with adequate dust control as required by O.S.H.A. mineral dust standards, the use of this product will comply with O.S.H.A.'s standard for exposure to asbestos dust. I suggest the elimination of the first sentence under the second caution label. Following is a rewrite; Avoid creating and breathing talc dust. Respirators or dust masks approved by N.I.O.S.H. or the Bureau of Mines are recommended. D. E. HiHi er CRMC-MAD-000720 i : r * /. internal Correspondence To: W . B. Reitze - 4N F r o m : V . E . Wolkodoff - R&D C o p i e s - J . P. Leineweber - R&D M. Fenner - 4N Subject: Date: July 23, 1975 1. As of 4:30 P.M. yesterday, I have to change Windsor Talc from containing 10 percent by weight of chrysotile to one of not containing any deleterious asbestos minerals except for background count fibers found at 20,000X by scanning electron microscopy (SEM). 2. I am personally and fully responsible for this error and please accept my apology for any embarrassment and any type of inconvenience this may have caused you. 3. For matter of record, the Windsor Talc is composed pre dominantly of talc with appreciable amounts of the ser pentine mineral group, dolomite, magnesite, two types of chlorite and trace amounts of biotite and magnetite. The serpentine minefal group refers to one or more of the following minerals: chrysotile, antigorite, and lizardite. All these have the same chemical formula but differ in morphology. 4. Our initial findings were based on clean and sharp peaks by X-ray diffraction and optical observations on hammered raw material which is exceptionally coarse grained. At that time we did not realize that two types of chlorite were present, since only one type is usually present in talc, and these two types of chlorite evidently have a pronounced effect on chrysotile diffraction peaks. Also, the hammered and flatened platelets of talc had many of the optical characteristics of chrysotile including indices of refraction which is the first time this has happened to me. Literally speaking, we have examined several hun dred talc samples and have always been able to differentiate chrysotile from talc which is notorious for mimicking chrysotile fibers. 5. The correct analytical approach for the determination of chrysotile or amphibole asbestos is to run routine X-ray diffraction, conduct cursory petrographic examination and then go to the most important method which is transmission CRMC-MAD-000721 W. B. Reitze -2- July 23, 1975 electron microscopy (TEM) and check each fiber by a selected area diffraction pattern (SAED). Our TEM is quite old but satisfactory for some problems; however, it does not have modern SAED c a p a b ility which are essential for accurate determination of minerals especially the family of asbestos fibers 6. If we had SAED capabilities the erroneous results would not have been reported. 7 . Again, please accept my apology. sm Notebook: 4533, p 88 CRMC-MAD-000722  I 3 1 Johns-Manvilie T IL E cor/-zX+A**------------ -- ~ Internal Correspondence To: J . P. LE INEW EBER - RSD Dato: J U L Y 1 8 , 1 9 7 5 From: W . B . R E I T Z E - i+N Copies: e . m . FEN N ER; V. E . WOLKODOFF Subject, TALC A N A L Y SIS S E V E R A L MONTHS AGO WE R E C E I V E D T H E A T T A C H E D C O R R E S P O N D E N C E FROM W INDSOR T A L C , OUR S U P P L I E R O F T A L C AT THE WAUKEGAN P L A N T . AS YOU CAN S E E , T H EY A TTA CH ED A L E T T E R FROM THE I L L I N O I S EPA WHICH S T A T E S THAT THE TA LC IN Q U ESTIO N DOES NOT CONTAIN ANY A S B E S T O S . IN ORDER TO D ETER M IN E WHETHER T H I S WAS C O R R E C T , I HAD F R A N K A N G E L O S , OUR I N D U S T R I A L . H Y G I E N I S T A T W A U K E G A N , B R E A K O P E N A NEW B A G O F T H E W IN D S O R M A T E R IA L , O B TA IN A S A M P LE , AND I SEN T I T ALONG AS THE ATTACHED CORRESPONDENCE IN D IC A T ES. T H ER E SEEM S TO BE SOME D IF F E R E N C E OF O P IN IO N BETW EEN THE I L L I N O I S E P A , MCCRONE A S S O C I A T E S , A N D O U R OWN R E S E A R C H . J I M , DO Y O U H A V E A N Y I D E A A S TO WHO I S R I G H T AND W H Y ? L$l W. B. R E IT Z E ATTACH. SfiSi Johns-Manville Internal Correspondence To: W. B. Reitze 4N Date: July 10, 1975 Fr om: V. E. Wolkodoff - R&D Copies: E. M . Fenner - 4N J. P. Leineweber - R&D Subject: ANALYSIS OF TALC FROM W. B. REITZE, SUBMITTED JUNE 30, 1975. LOCALITY AND MANUFACTURER ARE UNKNOWN. The predominant constituent is Talc with subordinate amounts of akermanite and chrysotile asbestos fiber. Chrysotile constitutes between 10 and 15 percent of the sample by volume. Akermanite is a complex silicate, but is a non-asbestos mineral. v. E. Wolkodoff sm t f^ CRMC-MAD-000724 Johns-Manville U + i i-i 'w X Internal Correspondence lo: J . LEIN EW EB ER - RSD Dato: J U N E 3 0 , 1 9 7 5 Fn>:n' W. B . R E I T Z E - 4N Copies: E . M. F E N N E R Subites SAMPLE OF TAL C ATTACHED IS A SAM PLE OF T A LC U SED IN ONE OF OUR P L A N T S . WOULD I T B E P O S S I B L E F O R Y O U T O R U N T H I S T H R O U G H A N A L Y S I S A N D DETERMINE, C l ) I F TH ER E IS ANY A S B ES T O S F I B E R P R E S E N T , ( 2 ) HOW MUCH F I B E R I S P R E S E N T , ( 3 ) W H E T H E R T H E F I B E R I S C H R Y S O T I L E , T R E M O L I T E , OR A N T H O P H Y L L .IT E . I F YOU N EED I T , YOU A LR EA D Y HAVE OUR CHARGE NUM BER. aC ' W. B . R E I T Z E ATTACH. 4 CRMC-MAD-000725 M l Johns-Vianvi!ie Internal Correspondenc To: W. H. Gates - Denver 5S / Di>t0: April 22, 1975 From: C. R. Wikel/L. D. Mutaw ' Copies: See below: Subject: TALC VS ASBESTOS There has always bean some question as to asbestos found in Talc. Tor your information we are enclosing copies of a letter from Roger N. Miller, President of Windsor Minerals lnc. and Martin J. Sheahnn, Illinois E.P.A. cc: W. B. Reitze - Denver 4N J . N. Siegfried - Denver AN P. J. Niccolai - 44 F. J. Angelos - 3 11 3.3 CRMC-MAD-000726 WINDSOR MINERALS INC. P .O .B o x 680 Windsor. Vermont 05089 April 16, 1975 Johns-Manville Products Corp. Waukegan, Illinois 60085 Attn: Mr. Peter Nicoli Roofing Sunt. D e a r Mr. Nicoli: I am attaching a letter from The Illinois Environmental Protection Agency which I believe will be of interest to you and should be in your files. This was a difficult situation to resolve and the regula tions need amendment but we are glad to be able to provide you with this assurance of quality. We thank you for your confidence in, and use of our product. Yours very truly, WINDSOR MINERALS INC. RNM :rg Enc. EPA L etter Roger N. Miller President CRMC-MAD-000727 Jl Reply to: Windsor Minerals Company P. O .Box 680 Windsor, Vermont 05089 Dr. Richard H. Briceland, Director April 10, 1975 Environmental Protection Agency D iv. of A ir Pollution Control Naval Armory East Randolph at the Lake Chicago, Illinois 60602 Attn: Mr. Roger Miller-President Dear Mr. M iller: As you know the State of Illinois E . P . A . has collected samples of talc in many manufacturi plants during the last year. These samples would be routinely forwarded to our laboratory with a request lo analyze the samples for asbestos. Three of the Windsor talc samples, collected from local roofing material plants, were reported as definitely containing a form of asbestos. At this time the E . P. A . did not have an electron scanning microscope and had to r e l y on the electron microscope work of the University of Illinois. During a scries of telephone calls to our local office you seriously objected to these findings and it was decided to have a meeting in Chicago to resolve the issue. During the meeting Ian Stewart of Walter C . McCrone Associates, In c ., presented clear and logical reasons why talc can be mistaken for asbestos. It was then decided to resolve the issue by taking two random samples from local plants and presenting a portion of each sample to McCrone and our laboratory. In this way any discrepancy in the results could be resolved between the respective technicians and hopefully a uniform opinion would result. As you know McCrone was prompt in reporting their results. Our ov/n results were delayed pending the final installation and debagging of the E . P . A. ' s new electron microscope. We would like to report that both laboratories have found no asbestos in the random talc samples. We would also like to express our regrets to you and your customers for any inconvenience which our initial findings may have caused. I am sure you know that we were proceeding in good faith and did not hove good reason to doubt the original findings of our laboratory and the University of Illinois. CRMC-MAD-000728 100% recycled iw pcr .riI 10, 1975 .ige II /indsor Minerais Company We do intend to continue random sampling of talc in this region. At this point in time we feel that our laboratory does have the capability to do this work and problems such as the one enumerated above will not occur in the future. If you have any further questions on this matter, please feel free to contact our Chicago O ffice. MJStek cc: Fry Roofing Company - Mr. D. Foster Flintkoie- Mr. J . Butera Certain - Teed - Mr. W . J . Neville CRMC-MAD-000729 U E i Johns-Manville To G e o r g e S w a l l o w - 4 N o r t h Internai Correspondenc Dflte: F e b r u a r y 21, 1 97 5 C o p ie s : H. R. Ke e f e , P a u l K o t i n - 4 N - W . R e i t z e - 4 N - C DESERTALC - CUSTOMER HELP George, I'd like to express thanks and appreciation real h e l p g i v e n u s on several recent o c c a s i o n s ~ in arranging really rapid customer w o r k station visits D e s e r t a l c ^tajor accounts. for the your to Ben Hanson of Mineral Ceramic Products personally told me how valuable your help was and what a pleasure it was these days to have a supplier react fast and follow through! I'm sure we have built some same bridges with Solo Cup with such equally quick response these past few days. These efforts are really helping. CRMC-MAD-000730 M \ Johns-Manville Internal Correspondence To: Labeling R e v i e w Co m m i t t e e * Date: A p r i l 11, 1975 From: e . M. F e n n e r - 4N Oopies: P i l e & C S u b j e c t : TALC Paul Kotin, M.D. - 4N M. J. C o w a n - 1W J. P. L e i n e w e b e r - R&D A. C. F i n k b i n e r - 5 W ^ W. B. R e i t z e - 4N R . F . Sliker - 1W G. W. W r i g h t , M.D. - 4N Paul Kotin has asked me to circulate to you for your information the attached two letters that he r e c e i v e d f rom W i l l i a m E. Smith, M . D., Director, Health Research Institute, Fairleigh Dickinson University. Attach. CRMC-MAD-000731 7airhigh Dickinson University RUTHERFORD TEANECK MADISON 31 March 1975 Paul Kotin, M.D. Vice President for Health Johns-Manville Corporation P.O. Box 5108 Denver, Colorado 80217 FLORHAM MADISON CAMPUS 285 Madison Avanuo Madison, Now Jtrtey Ai 201 77-47QO Dear Paul: Enjoyed our conversation in New York. I talked on Saturday with Dr. Hildick-rSmith Johnson and learned of two papers that may be of you. He says these papers are to be p r e s e n t e d on oi: Tuesday, April 15, at the American Industrial at the San F r a n c i s c o Hilton. at Johnson & interest to the afternoon Health C o n ference One is by Dr. Fine from Harvard, who apparently w i l l suggest that the TLV for talc should be lowered because he finds impairment in the pulmonary function tests in a group of workers exposed to "talc" in the rubber industry. Hildick-Smith says that less the 50% of this material was talc, that 55% was magnesium carbonate. The o t h e r p a p e r is by Prof. R u b i n o f r o m Turin. It w a s n o t submitted in time to be listed in the printed program. I under s t a n d that Prof.' R u b i n o w i l l say t h a t he finds no exc e s s mortality and no difference in incidence of cancer in about 1200 deceased talc miners in Pinerola (Italy) as compared to a comparable number of deceased agricultural workers who lived nearby. I gather that the Pinerola mine is one of the largest and oldest talc mines in Europe. Information on the conference is available from: Howard N. Schultz Executive Director American Occupational Medicine 150 N. W a c k e r D r ive Chicago, 111. 60606 (Telephone 312 782-2166) Association Sincerely, WES/elc cc: Dr. J.P. Leineweber George Wright, M.D. W i l l i a m E. Smith, M.D. Director Health Research Institute CRJViC-MAD-000732 RUTHERFORD TEANECK MADISON 31 March 1975 Dr. R a y m o n d E. S h a p i r o E p i d e m i o l o g y Unit-., H F F - 1 0 8 Bureau of Foods Food l Drug Administration 200 C Street South West Washington, D.C. 20204 FLORHAM-MADISON CAMPUS 285 Madiion Avenu* Madison, Naw Jersey An* * 20) 127*4200 Dear Ray: Further to our conversations about talc, this is to mention a paper, that I u n d e r s t a n d w i l l be p r e s e n t e d on the afternoon of Tuesday, A pril 15 at the A m e r i c a n Industrial Health Conference at the San Francisco Hilton. This paper is by Prof. Rubino from Turin. It was not submitted in time to be listed in the printed program. I understand that Prof. Rubino will report that he finds no excess mortality and no difference in incidence of cancer in about 1200 deceased talc miners in Pinerola (Italy) as compared to a comparable number of deceased agricultural workers w h o lived nearby. I gather that the Pine r o l a m i n e is one of the largest and oldest talc mines in Europe. Information on the conference is available from; Howard N. Schultz Executive Director American Occupational Medicine 150 N. W a c k e r D r i v e Chicago, 111. 60606 (Telephone 312 782-2166) Association Sincerely, WES/elc W i l l i a m E. Smith, M.D. Director Health Research Institute CRMC-MAD-000733 iffll Johns-Manville la Internal Correspondence To: From: Copies: Subject: Filtration & Minerals Environmental Committee* E. M. F e n n e r P. Kotin, M.D. J. D. M c G r a t h File & C OSHA DIRECTIVE - TREMOLITE AND TALC Dat#: Dec. 2, 1974 *R. P. C a r t e r W. A. C o o p e r A. C. F. F i n k b i n e r III D. E. H i l l i e r T. M. J a c k s o n , Jr. H. R. K e e f e R^W. B. S. W. F. J. W. C. G. W. Me Indoe Reitze Schulmeyer Solon, Jr. Sfcraib Wright, M.D. Attached for your information is a copy of OSHA Field Memorandum #74-92, subject - tremolite and talc. Attach. CRMC-MAD-000734 U.S. DEPARTMENT OF LABOR Occupational Safety Health Administration cWA^ific'iow, q.c. zoiio m N o v e m b e r 21, 1974 0 * WTEX.D INFORMATION MEMORANDUM #74-92 TO: OSHA Assistant Regional Directors and Area Directors SUBJECT: . Ttemolite and TSlLc - 1. Background: Ote attached letter frem Assistant Secretary of Labor John H. Stender gives further policy guidelines in regard to trenolits and talc that are not asbestiform or fibrous. 2. Policy Change: In order to be considered asbestiform or fibrous the following criteria will be used by the Salt Lake City laboratory of OSHA: A. Particles must appear to be fibrous rather than as crystals or slivers. ^ B. Ote maximum diameter of a fiber to be counted is 3 microns. C. The maximum length of a fiber.-to e counted is 30 microns. 4 ' D. The length to width ratio must be 5 o r more to 1, that is, 5 times or more longer than wide. E. The separate or individual fibers must contain fibrils or the "bundle of sticks" effect, unless they are at a n o n - . divisible stage. A fibril cannot be subdivided and would b e counted, if it meets the other criteria. The electron microscope may be used to prove the fibrous nature of the particles. The length to width ratio of 5 or more to 1 is not meant to imply that other particles are not hazardous. 3. Sample Collection and Submission: If the Compliance Safety and Health Officer (CSKO) is reasonably sure that the talc or tremolite is fibrous or asbestiform, he will sample following the OSHA Sampling Data Sheet #2 for asbestos. CRMC-MAD-000735 1 $ - 2- * In all other cases for talc or tremolite, he will (1) sample following the Sampling Data Sheet tt2 for asbestos and (2) sample using the midget impinger for non-asbestiform, non-fibrous talc or tremolite. i\hen impinger samples are taken, an air sample most be collected following OSHA Sampling Data Sheet #3 for crystalline silica for determining the percent quartz at the Salt Lake City OSHA Laboratory. Midget impinger samples must be analyzed within 24 hours after collection for the results to be valid. Therefore, arrangements must be made by the Industrial Hygienist with a local laboratory concerning the analyses prior to making the inspection. These samples are not, to be sent to the OSHA Laboratory, Salt Lake C i t y ; they will r-ot be analyzed tsre..7lf tfe Industrial Hygienist is certain that the talc*or tremolite is asbestiform or fibrous, impinger samples may be emitted from the inspections. 4. Results and Interpretation (1) Results from the impinger samples will be used if the tele or tremolite is non-asbestiform. or non-fibrous. Table G-3 o f 1910.93 would apply. The Tims Weighted Average (TWA) for talc or tremolite that is non-asbestiform, non-fibrous is 20 millions of particles per cubic foot of air by the .light-field count method. * "* (2) The laboratory will give two results for the talc or tremolite that is asbestiform or fibrous submitted for analyses of asbestos. One for definite asbestiform fibers meeting the criteria of 5 or more to 1 and one for those fibers meeting the older asbestos criteria, namely those particles having a length to width ratio of 3 or more to 1. Samples having a 5 or more to 1 length to width ratio and meeting the other criteria of paragraph #2 Policy Change would mean that fibrous or asbestiform talc or"tremolite is present. There fore, the standard for asbestos, 1910.93a, would apply. This guidance is temporary and may change as a result of findings from a n on-going NIOSH study on this subject. I 4 CRMC-MAD-000736 / - 3Any questions m a y be directed to Mr. Charles McClure, Division of Occupational Health Programing, Occupational ^ministration, Washington, D. C. 20210, telephone 202-961-2726. P o d s^ Barry J. VJhite Associate Assistant Secretary for Regional Programs Attachment ti * 4' CRMC-MAD-000737 I COPY October 9* 1974 0 % Hr. H. B. Vanderbilt President Chief Executive Officer R. T. Vanderbilt Company, Inc. 30 Winfield Street Norwalk, Connecticut 08855 Bear Mr. Vanderbilt: of This is in reply to your letter of September 26, concerning your request for relief from the asbestos standard for your talcs containing non-fibrous tremolite, actinolite, and anthophyllite. Hy letter of August 6 stated "that non-fibrous or non-asbestiform minerals such as non-asbestiform tremolite are not within the scope of the asbestos standard and, therefore, the provisions of that standard do not apply to talc containing non-asbestiform minerals. NIOSH is currently conducting a thorough investigation into the exact minerals to which talc workers were exposed in those studies where asbestosis or other adverse medical effects were found. Pending the receipt and evaluation by OSHA of the report by NIOSH on this investigation, if you have'scientific evidence that the naturally occurring talcs, prior to processing by milling or crushing, do not contain fibrous or asbestiform tremolite, antophyllite, actinolite or other asbestiform minerals, you may certify to your customers that the talc does not contain asbestos. Fibrous, asbestiform minerals such as fibrous tremolite means naturally occurring asbestiform minerals which prior to or after crushing and processing, contain fibers made up of fibrils. Sincerely, /s/ John H. Stender John H. Stender Assistant Secretary of Labor CRMC-MAD-000738 TTC M n r , , m W Occ t * iJQR strraattiion N o v e m b e r 21, 1974 ' FIELD INFORMATION MEMORANDUM #74-92 TO: OSHA Assistant Regional Directors and Area Directors SUBJECT: Tremolite and Talc 1- Background: The attached letter from Assistant Secretary of Labor John H. Stender gives further policy guidelines in regard to trenolite and talc that are not asbestiform or fibrous. 2. Policy Change: In order to be considered asbestiform or fibrous the following criteria will be used by the Salt Lake City laboratory of OSHA: A. Particles must appear to be fibrous rather than as crystals or slivers, " "~ B. The maximum diameter of a fiber to be counted is 3 microns. C. The maximum length of a fiber,-to e counted is 30 jnicrons. D. The length to width ratio must be 5 or more to 1, that is, 5 times or more longer than wide. E. The separate or individual fibers must contain fibrils or the "bundle of sticks" effect, unless they are at a nondivisible stage. A fibril cannot be subdivided and would be counted, if it meets the other criteria. The electron microscope may be used to prove the fibrous nature of the particles. The length' to width ratio of 5 or more to 1 is not meant to imply that other particles are not hazardous. 3. Sample Collection and Submission: If the Compliance Safety and Health Officer (CSHO) is reasonably sure that the talc or tremolite is fibrous or asbestiform, he will sample following the OSHA Sampling Data Sheet #2 for asbestos. CRM C'M AD~000739 In ill other cases for talc or traro.ite, he will (1) sample following the Sampling Data Sheet #2 for asbestos and (2) sanple using the midget impinger for non-asbestiform, non-fibrous talc or tremolite. When impinger samples are taken, an air sanple uost be collected following OSHA Sampling Data Sheet #3 for crystalline silica for determining the percent quartz at the Salt lake City OSHA Laboratory. Midget impinger samples must be analyzed within 24 hours after collection for the results to be valid. Therefore, arrangements must be made by the Industrial Hygienist with a local laboratory concerning the analyses prior to making the inspection. These samples are not to be sent to the OSHA Laboratory, Salt Lake~C~ity; they w ill not be analyzed there... If the Industrial Hygienist is certaxn that the talc or tremolite is asbestiform or fibrous, impinger samples may be emitted from the inspections. 4. Results and Interpretation (1) Results from the impinger samples will be used if the talc or tremolite is non-asbestiform.or non-fibrous. Table G-3 of 1910.93 would apply. The Time Weighted Average (TWA) for talc or tremolite that is non-asbestiform, non-fibrous is 20 millions of particles per cubic foot of air by the light-field count method. -- (2) The laboratory will give two results for the talc or tremolite that is asbestiform or fibrous submitted for analyses of asbestos. One for definite asbestiform fibers meeting the criteria of 5 or more to 1 and one for those fibers meeting the older asbestos criteria, namely those particles having a length to width ratio of 3 or more to 1. Samples having a 5 or more to 1 length to width ratio and meeting the other criteria of paragraph #2 Policy Change would mean that fibrous or asbestiform talc or tremolite is present. There fore, the standard for asbestos, 1910.93a, would apply. This guidance is temporary and may change as a result of findings from an on-going NIOSH study on this subject. CRMC-MAD-000740  / - 3' Any questions may be directed to Mr. Charles McClure, Division of Occupational Health Programming, Occupational Safety and Health Administration, Washington, D. C. 20210, telephone 202-961-2726. P. o d b ^ Barry J. White Associate Assistant Secretary for Begional Programs Attachment s4 * . V' CRMC-MAD-000741  COPY October 9, 1974 Mr. H. B. Vanderbilt President Chief Executive Officer R. T. Vanderbilt Company, Inc. 30 Winfield Street Norwalk, Connecticut 08855 Dear Mr. Vanderbilt: Of h' This is in reply to your letter of September 26, concerning your request for relief from the asbestos standard for your talcs containing non-fibrous tremolite, actinolite, and anthophyllite. My letter of August 6 stated that non-fibrous or non-asbestiform minerals such as non-asbestiform tremolite are not within the scope of the asbestos standard and, therefore, the provisions of that standard do not apply to talc containing non-asbestiform minerals. NIOSH Is currently conducting a thorough investigation into the exact minerals to which talc workers were exposed in those studies where asbestosis or other adverse medical effects were found Pending the receipt and evaluation by OcHA of the report by NIOSH on this investigation, if you have'scientific evidence that the naturally occurring talcs - prior to processing by milling or crushing, do not contain fibrous or asbestiform tremolite, antophyllite, actinolite or other asbestiform minerals, you may certify to your customers that the talc does not contain asbestos. Fibrous, asbestiform minerals such as fibrous tremolite means naturally occurring asbestiform minerals which prior to or after crushing and processing, contain fibers made up of fibrils. Sincerely, fb ! John H. Stender John H. Stender Assistant Secretary of Labor CRMC-MAD-000742 W. A. C o o p e r 4N R. S. L a m a r D.,10: J a n u a r y 24, 1974 W. C. S t r e i b R&D F. J. S o l o n 4N W. B. R e i t z e IS R. P. C a r t e r 4N YOUR M E M O OF JANUARY 22, 1974 The J-M position with respect to the proposed FDA speci- . fication and test method has been outlined in detail in Richard Carter's letter of December 21, 1973 to the FDA, This is now a part of the public record and could be o b tained by Mr. Lindesmith. On page 14 of Carter's letter he states that we believe the method to be unworkable. This has been confirmed by numerous other qualified people who have attempted to use the method. Numerous statements to this effect have been made to the FDA. These also are now a part of the public record and could be obtained by Mr. Lindesmith. We most certainly agree with Mr. Lindesmith that the pr o posed method is "unbelievable" to say the least. However we have attempted in every possible way to be cooperative with the FDA and to be helpful where we believed our special knowledge or expertise might fit. In this spirit of cooperation we submitted as a part of Richard Carter's D e c e m b e r 21,! 1973 l e t t e r to t h e F D A a " M o d i f i e d F D A Optical for Asbestos in Talc." This is our Report No. V W 7 3 - 6 2 , d a t e d D e c e m b e r 17, 1973 b y V. E. W o l k o d o f f . A copy is attached. Even this procedure is very difficult and time-consuming. It requires a highly trained p e t r o g r a p h e r . A full day is required for one sample. We do not fully understand what we have when we complete the test. What do the results mean? On what medical data has the FDA decided that the ingestion of asbestos is harmful? On what medical data has the FDA decided that chrysotile 10X more harmful than tremolite? How were the limits of 100 fibers for chrysotile and 1000 fibers for tremolite established? It is important to remember at this point that this is still only a proposed test method and specification. Just how the FDA might ultimately rule remains to be determined. We know that there have been numerous and vehement re sponses to their proposal. CRMC-MAD-000743 ed :: r ,;c ? r', r ; ,y it 3 CZIjTEH RcrwrtNo. V W 7 3 - 6 2 XtiiiilT V,..,. 1 i'uLe D e c ember 17, MODIFIED FDA OPTICAL FOR ASBESTOS IN TALC x. The method is essentially similar to the p r o c e d u r e as outlined by A. E. S c h u l z e and W. V. E i s e n b e r g of the 0. S. Food and D r u g A d m i n i s t r a t i o n , W a s h i n g t o n , D.C., August 20, 1973. C o n s i d e r a b l e exp e r i e n c e is n e c e s s a r y co obtain a u n i f o r m l y w e l l - d i s p e r s e d s a m p l e o n t h e slide. 2. E q u i p m e n t , etc.: A . Leitz Orthoplan Petrographic iMicroscope. B . Magnification 500X. Resolution is 0.4 m i c r o n . ( D C. D i a m e t e r of f i e l d at 500X is 0.350 mm. D. A r e a of the f i e l d at 5 00X is 0. 0 9 6 m m ^ . E. A r e a of 100 f i e l d s (which a r e t a k e n at random) is equal to 9.60 mm2. F. Use 18 x 18 m m s q u a r e c o v e r s l i p o v e r 1 m g of sample. Area of the cover slip is 342 m m ^ . G. F o r e a c h f i b e r d e t e c t e d in 100 fields, m u l t i p l y b y 34 for total number of fibers in 1 mg sample. H. If the p o p u l a t i o n of a s b e s t o s is heavy, o n l y 5 to 10 fields are n e c e s s a r y for c o u n t i n g w h i c h is th e n extra-r polated to the entire sample under the cover glass. 1. U s e O S H A d e f i n i t i o n of fibe r : 5 m i c r o n s o r g r e a t e r in length and a length-to-width aspect ratio of at least 3:1. (1) N ote: 500X m a g n i f i c a t i o n is r e c o m m e n d e d 'rather t h a n the approximately 400X of the o r i g i n a l p r o c e d u r e in o r d e r to (a) assure Becke L i n e d e t e r m i n a t i o n ; and (b) f i e l d c o n t a i n s f e wer particles and is less confusing. ic should be r e c o g n i z e d t h a t t h e o r e t i c a l l y w e c o u l d o b s e r v e at 500X some f i b e r s w h i c h m i g h t n o t be d e t e r m i n e d at 400X, thus resulting in a slightly higher "asbestos fiber count" than for the same s a m p l e o b s e r v e d at 400X. 3. From a p e t r o g r a p h i c v i e w p o i n t , we p r e f e r to go i m m e d i a t e l y after "culprits" w i t h a p p r o p r i a t e ind e x oils r a t h e r t han the t w o - s l i d e m e t h o d as p r o p o s e d by S c h u l z e and E i s e n b e r g CRMC-MAD-000744 * r: ih.** k.u u iL Ilti ReportNo. V W 73-62 Page 2 in w h i c h a s b e s t o s lib e r s are c o u n t e d r e l a t i v e to talc i n dices of refraction. This method presents too many tech nical (optical) p r o b l e m s and c a n be m i s l e a d i n g . For example, if sepiolite fibers are present, and using the FDA 1.574 liquid slide, these fibers have to be counted as ch r y s o t i l e . Be sure the material is essentially talc. Use liquid with n of 1.590 for confirmation and at same time look for apparent gross contamination. 1 The Becke Line is extremely d i f f i c u l t to i n terpret on f i brous-appearing talc. More often than not, there is d i s agreement among petrographers in the same laboratory on precisely the same fibrous-appearing talc particle as to whether the Becke Line is moving in or out. With experience, however, the talc particles standing on edge can readily be determined by the relatively high interference order color. Also, in an oil of 1.556 under plane polarized light, the particles will match the oil from an angle of approximately 45 to 80, but never in the N-S or E-W directions. If not present as large bundles, the m o s t d i f f i c u l t asbestos m i n e r a l to d e t e r m i n e is c h r y s o t i l e . The g a m m a i n d e x (Xdirection) we use is 1.556. Prepare 1 mg slide with 1.556 oil and proceed with determination. Under conditions of crossed Nicols and near maximum light intensity, proceed to look for chrysotile showing maximum interference color at 45. Now check for parallel extinction. Switch to plane polarized light, reduce the light intensity and iris diaphragm for contrast and check the gamma index. If fiber is chrysotile, it will nearly disappear or show Christiansen effect for gamma index. Rotate the stage 90 to get rela tive bearing of Alpha index. The fiber should now stand out in high relief with Becke Line going into the oil. Then check for positive elongation. The most common asbestiform amphibole to be associated with talc is t r e m olite. P r e p a r e 1 m g s l i d e w i t h 1.622 oil (gamma index for tremolite) and proceed with determination (now, all n o n - t r e m o l i t i c p a r t i c l e s stand out in high r e l i e f ) . Go for tremolite's most characteristic feature which is in clined extinction of about 10 to 14 (gamma index to the Z direct i o n ) . At position of extinction check for gamma index. If these match, r o t a t e stage 90 to get r e l a t i v e r e a d i n g of Alpha index which is below 1.622. Confirm tremolite with positive elongation. i CRMC-MAD-000745 ktf *W b>tuL* bttt*3Ucirfc*V^sN Report No. VW73-62 Page 3 s. if s t e p 7 i n d i c a t e s the p r e s e n c e of a m p h i b o l e fibers other than t r e m o l i t e by d i f f e r e n c e s in e x t i n c t i o n a n g l e or i n d e x of r e f r a c t i o n , t h e n t h e s e can be d e t e r m i n e d b y routine pet r o g r a p h i c methods. Once species is e s t a blished use same p r o c e d u r e as in (7) (1 m g of s a m p l e o n s l ide in a characteristic oil of the mineral for counting purposes) giving due allowance for differences in extinction angle and elongation. CRMC-MAD-000746 Johns-iVianvilie ***'%. R. S. L a m a r - R&D Dato: O c t o b e r 9, 1974 V. E. W o l k o d o f f - R&D Distribution at End of Memo FDA OPTICAL METHODS FOR OSHA DEFINITION IN FOUR VANDERBILT COMPANY COUNTS OF ASBESTOS MINERALS T A L C S A M P L E S P R O D U C E D B Y R. MEETING T. 1. T h r o u g h J. P. L e i n e w e b e r , R. P. C a r t e r h a s r e q u e s t e d that this memorandum listing asbestos fiber counts on four s a m p l e s of talc f r o m R. T. V a n d e r b i l t C o m p a n y ( s u b mit t e d by Charles Wagner Company) be on his desk on Friday, October 11, 1974. 2. T h e R. T. V a n d e r b i l t C o m p a n y t a l c s a m p l e s are i d e n t i f i e d as follows : 1. Lab. No. R C - 7 4 2 5 5 - 1 2. Lab. No. R C - 7 4 2 5 5 - 2 3. Lab. No. R C - 7 4 2 5 5 - 3 4. Lab. No. R C - 7 4 2 5 5 - 4 Nytal 200 Nytal 400 Asbestine 3X Asbestine 325 Since the samples are extremely complex due to types of asbestos being present, the J-M modified optical method could not be used for each determination but rather wo had to use the FDA Microscopical Detection of Asbestos in T a l c b y A r n o l d El S c h u l z e and W i l l i a m V. E i s e n b e r g issued on A ugust 20, 1973. The J- M modified optical technique, however, was used on each samples (clarified Millipore membrane) in conjunction with Zernecke phase contrast microscopy as a check on the total number of fibers in each sample. In all tests only fibers meeting OSHA definition were counted; that is, at least a 3:1 aspect ratio and fiber lengths have to be at least 5 microns or longer. 4. T o t a l n u m b e r of a s b e s t o s f i b e r s p e r m g in e a c h sample: a. N y t a l 200 b. N y t a l 400 c. A s b e s t i n e 3X d. A s b e s t i n e 325 1.055.000 2.146.000 1.460.000 1.526.000 fibers/mg fibers/mg fibers/mg fibers/mg 5. F i b e r s p e r rag o f e a c h a s b e s t o s c o m p o n e n t for the four CRMC-MAD-000747 (2) R. S. L a m a r O c t o b e r 9, 1974 samples studied are as follows: SAMPLES 1 i | Nytal 200 ! I Nytal 400 t Asbestine 3X Asbestine 325 TREMOLITE 604,000/mg 1,931,000/mg 876,000/mg 992,000/mg CHRYSOTILE 300,000/mg 86,000/mg 561,000/mg 503,000/mg ANTHOPHYLLITE 151,000/mg 129,000/mg 23,000/mg 31,000/mg The predominant fiber in each sample is Tremolite which can be somewhat blocky, with clipped ends, is very harsh, but most are narrow and rigid fibers. The Chrysotile ranges from silky (very small percentage), bundles of few fibrils, and bundles containing numerous fibrils. In general, the Chrysotile is considered medium-harsh to harsh. The Anthophyllite is characterized by having vary narrow diameters, being extremely rigid, being almost spear-like since individual fibers can show one end as acicular (needle-like) and others show a double termination of acicularity. 6. By t r a n s m i s s i o n e l e c t r o n m i c r o s c o p y ( T E M ) , six p l a t e s were taken of each sample. One print of each sample to show at least a few Chrysotile fibers are attached and the magnification is 11,000X. At this magnification 1.1 cm equals one micron. The TEM plates on file are as follows: a. N y t a l 200 b. N y t a l 400 c. A s b e s t i n e 3X d. A s b e s t i n e 325 TEM TEM TEM TEM Plate Plate Plate Plate Nos. Nos. Nos. Nos. 2301 2302 2303 2304 A-F A-F A-F A-F All plates were taken at 4400X, and after enlargement for prints, the magnification would be 11,000X. All TEM plates were taken on our RCA EMU-3B electron microscope. We had planned to use a better model, Philips 200, at The Denver Research Institute for greater CRMC-MAD-000748 R. S. L a m a r (3) O c t o b e r 9, 1974 clarity, better resolution, obtain plates at higher magni fication and do selected area electron diffraction to prove the identity of the asbestos minerals (which cannot be done on our RCA mod e l ) , but the instrument at DRI was not available for our use at the time; and in all probability even if available, the work could not have been finished by October 11, 1974, since the optical work took a great deal of time. 7. If b e t t e r TEJJ4 m i c r o g r a p h s are n e e d e d w i t h s e l e c t e d a r e a electron diffraction patterns for your FDA presentation, and if you somehow can get additional time before the presentation, I will make arrangements for our use of the Philips 200 electron microscope at DRI. |/. f. b J U k r f j V. E. W o l k o d o f f Applied Research Section Distribution: R. P. C a r t e r - 4N E . M. F e n n e r - 4N Paul Kotin, M.D. - 4N W. B . R e i t z e - 4N F. J. Solon, Jr. - 4N G. L. S w a l l o w - 4N A. C. F. F i n k b i n e r , Ill - 5W J. A. M c K i n n e y - 5W H. R. K e e f e - 2W P. A. M a r t i n s o n - 2W C. J. S u l e w s k i - 2W W. L. V a n D e r b e e k - 2S R. G. R i ede - 2S F. L. P u n d s a c k J . P . Leineweber W. C. St r e i b A. J. M c A r t h u r S. S p e i l NOTEBOOK 4454 pp 70-77 CRMC-MAD-000749 TKM Ny t a l 2 0 0 , RC 7 4 2 V>~ ! !;M- 2 50.11) 1 i , OOOX CRMC-MAD-000750 C R M C - M A D ' 0 0 0 7 51 k m -2.303o i. ! , O0 0 X ! Johns-Manville Internal To: p. K o t i n , M . D . , F. J. S o l o n , E. M. Fennemate: O c t o b e r 17, 1974 M . B. Reitze, G. L. S w a l l o w from.- r . p. C a r t e r Copies: F i l e and C. S u b ject: Tremolitic Talc - Asbestos Standard Letter from U.S. Department of Labor to R. T, Vanderbilt Company Here is a copy of John Stender's O c tober 9 l e t t e r to R. T. V a n d e r b i l t C ompany. RPC:jp Enclosure CRMC-MAD-000754 .S. DEPARTMENT OF LABOR Occupational Safety and Health Administration WA5HINGTON, D.C. 20210 Office of the Assistant Secretary OCT 9 1974 li % -, Mr. H . B ; Vanderbilt President :Chief Executive ;Officer R . .T. Vanderbilt Company,:Inc. . '30 W i n f i e l d S t r e e t Norwalk, Connecticut.- 08855 ' Dear Mr; Vanderbilt: ; . , * , . This .is i n . r eply.to .your l e t t e r ;o f .September .>26, c o n c e r n i n g .your .request.for.relief from.the.asbestos.standard for.your-tles ' ..containing.non-fibrous tremlite;iactinolite; and:anthophyllite. M y l e t t e r o f A u g u s t 6. s t a t e d '.th a t n o n - f i b r o u s or n o n - a s b e s t i f r m m i n erals :s u c h .as n o n - a s b e s t i f o r m t r e m l i t e r e .not w i t h i n :the scope .of .the asbestos s t a n d a r d and, .therefore, the p r o v i s i o n s :o f .that s t a n d a r d .do not a p p l y .to t a l c c o n t a i n i n g n o n - a s b e s t i f o r m 'minerals. 0 NIOSH.is .currently .conducting a :thorough. i n v e s t i g a t i o n into-.the' .:exact minerals .to-.which t a l c .workers .were exposed': in :t hose ' . .studies .where.a s b e s t o s i s -or .other .adverse .medical -.effects .ver.found. .Pending ,the .receipt :a n d .e v a l u t i o n by'.OSHA .o f .the'.reprt ;by'NIOSH . :on.this invest i g a t i o n , ; i f y o u h a v e i s c i e n t i f i c :e v i d e n c e t h a t the n a t u r a l l y ioccur l a g t a l c s , p r i o r .to *p r o c e s s i n g -b y m i l l i n g 'or .c r u s h i n g , .do n o t .contain f i b r o u s o r a s b e s t i f o r m tremlite, anthophyllite, actinolite orother.asbestiform minerals, you m a y .c e r t i f y .t o . y o u r . c u s t o m e r s .t h a t .the t a l c .d o e s .n o t .c o n t a i n .asbestos. Fibrous, asbestiform minerals.such as fibrous -tremllt means . n a t u r a l l y :o c c u r r i n g a s b e s t i f o r m m i n e r a l s w h i c h p r i o r . t o o r - a f t e r > crushing and processing, c o n t a i n f i bers m a d e tip .of fibrils. iJbhn'B. Stender rAsalstant Secretary of Labor CRMC-MAD-000755 Johns-M anville Internal Correspondence To: See Below* Date: S e p t e m b e r 30 , 1974 F ro m : R. P. C a r t e r C opies-. File and Chrono Subject: FDA REGULATIONS ON THE USE OF TALC *J. S. A u t r y H. R. K e e f e P. K o t i n R. R. L a m a r E. M. F e n n e r J. P. L e i n e w e b e r P. A. M a r t i n s o n G. E. P a r k e r F. L. P u n d s a c k -W. B. Reitze N. B. S c h e f f l e F. J. S o l o n W. C. S treib C. J. S u l e w s k i W. L. V a n D e r b e e k R. R. Z a z e n s k i In my memo of S eptember 13, 1974 , I i n d i c a t e d that during a m e e t i n g w i t h F D A o f f i c i a l s o n S e p t e m b e r 12,..w e agr e e d to conduct additional tests to determine the lowest level of detectability of tremolite in food. The FDA requested these additional tests in an effort to quantify our con clusion that tremolite does not migrate from food packaging paper containing tremolitic talc. Enclosed for y o u r inf o r m a t i o n is a copy of a letter d ated S e p t e m b e r 27 from J i m L e ineweber and Rich Zazenski to Dr. Corbin Miles of FDA reporting the results of our latest tests.I I have been advised that a final draft of FDA's position paper on talc will be forwarded this week to the General Counsel's Office of FDA, with our latest test data included. I have been further advised that the position paper will indicate that FDA is w i t h d r a w i n g its p r o p o s e d restriction of the use of talc containing asbestos in food and drug packaging materials, based on J-M's migration studies. A t the p r e s e n t time, it is not p o s s i b l e to estimate when FDA will publish its position paper on talc in the Federal R e g i s t e r . The d o c u m e n t may b e p u b l i s h e d as soon as next month if no complications are encountered during the internal FDA review procedure. CRMC-MAD-0007 56 September 27, 1974 Dr. Corbin M ilos (HFF-335) Food & Drug Administration 200 C Street, S.W. Washington, D.C. 20204 -' . Dear Corbin: A t o u r last meeting w ith y o u on September 12, 1974 , you raised a question regarding the limits of detectability of trcmolite in various food samples. The main reason for your question was to be able to specify a reasonable lower limit to 0 fiber counts. In o r d e r to a n s w e r y o u r question, w o ag r e e d to p e r f o r m tl>e following three tests: 1. Determine tho limit o f - d e t e c t a b i l i t y o f tremolite in salt spiked with tremolitic talc. 2. Determine the limit o f d e t e c t a b i l i t y of tremolite in meat spiked with tremolitic talc. 3. Determine the limit o f d e t e ctability of tremolite in salt spiked with ash from paper manufactured with tre molitic talc. The details of the experiments are attached. All of the counting was done by the optical microscope at 50OX magni fication. The samples were prepared by filtering on a 47 nro diameter, 0.2 m i c r o m e t e r m i l l i p o r e filter. The m a x i mum amount of total material which can be deposited on this filter is 0.5 rag. Any g r e a t e r concentrations result in too great a probability of fibers being hidden behind other particles. The results that we have obtained indicate that tremolite can be detected at a level of about 20 ppm in any residue. The detectability in any foodstuff will, therefore, depend upon the amount of ash remaining when the food is ignited. CRMC-MAD-000757 Dr. Corbin Milos, F D A Washington, D.C. September 27, 1974 Pag 2 As an example,- if a food yields 1 p e r cent ash, then the limit, of detectability of tremolite in the food would be 200 parts per billion. In the case of the spiked salt, the limit of detectability is about 0.1 parts per billion. We hope that this information has answered your questions. If we can be of any further assistance, please do not hesitate to contact either Rich Zazenski or myself. As y o u requested, under se p a ra ta co v e r w ar also send ing several paper samples made with various amounts of tremolitio talc. Very truly yours, Dr. James P. L e i n e w e b e r Manager, Applied Research Richard J. Zazenski Research Engineer rs Attachment jjcc : Dr. P. Kotin - 4N Att: F. J. Solon R. P. Carter - 4N W. C. St reib - R&D R. S. Lamar - R&D J. P. L e i n e w e b e r - R&D Att: S . Speil R. J. Zazenski - R&D CRMC-MAD-000758 Attachment Dr.'^Coiebn Milos, FDA SUPPLEMENTARY FDA WORK Item I ; 150 gm of meat was spiked with 0.0060 gm of F-l talc standard (0.25 per cent tremolite). This produced the equivalent of 100 ppb trem/meat. Based on the original fiber count of 41,000 tremolitic fibers/mg of F-l standard, there were approximately 246,000 fibers contained in the ash. The 150 gm of meat ashed down to 1.25 gm. For petrographic slide preparation, 0.5 mg of this ashed was dispersed on a 47 mm millipore filter. Assuming a homogeneous mix of ash and fibers there should have been approximately 98 tremolite fibers depo s i t e d on the m i l l i p o r e filter. O p t i c a l e x a m i n a t i o n o b s e r v e d 70 Item I I : 250 gm of salt was spiked with 0.1 mg of F-l standard In the 0.1 mg of talc, there were approximately 4,100 fibers. This corresponds to 1 ppb tremolite/salt. The salt was com p l e t e l y d i s s o l v e d a n d f i l t e r e d through a 0.2 fJ m i l l i p o r e filter If no fibers were lost during the procedure, all of the 4,100 fibers should have been collected on the filter. Optical exa mination observed 4,200 tremolite fibers on one sample and 3,450 fibers on another. Item III: A paper containing 3 per cent CYCLO-FIL talc was ashed and prepared for tremolite fiber count. The count was 390,770 30 per cent tremolite fibers per mg/ash. Then 0.1 mg of this paper ash was mixed with 250 gm of salt and the procedure for the recovery of insolubles was performed If no fibers were lost during preparation, there should have been approximately 39,000 fibers collected on the filter. Optical examination revealed 35,000. I tem I V ; 400 g m of salt was spiked w i t h 16 micrograms of F-l standard. This introduced approximately 656 tremolite fibers into the salt. This corresponds to approximately 0.1 ppb trem./salt. The salt was dissolved and filtered through 0.2 millipore. Optical examination observed 290 fibers. R. J. Z a z e n s k i CRMC-MAD-000759 9-27-74 CRMC-MAD-000760 `***0 pa ! Johns-Manville P1T7 internal Correspondence To: N. B. S c h e ffe l - 2 West Date: O ctober 2 , 1974 From: G. L. Swallow - 4 N orth Copies: T. E. Remmers - 2 West E. M. Fenner - 4 North D. R. C hristen sen - S u b ject: PAPER MILL SPECIAL EN1 USAGE CENTAL SAMPLE F. J . Angelos - Waukegan M- R- ' 4 Wnrth M. A. Baloga - 4 mNorth B/U - 10/14/74 F ile Chron This is to o u t lin e plans and a c tio n to date r e s u lt in g from y e s te rd a y 's m eeting w ith you, Tom Remmers, Ed Fenner, and me. I t was agreed t h a t t e s tin g shou ld be done in s e v e ra l paper m ills in o rd e r to determ ine the le v e l o f a s b e s tifo rm d u st generated in the use o f v a rio u s J o h n s -M a n v ille t a lc s . The f i r s t p r i o r i t y is t o be th e Ho ward Paper Company o f Dayton, O hio. Second p r i o r i t y is th e N orthw est Paper Company o f Pomona, C a lif o r n ia . O ther p la n ts m entioned were Flam beau Paper Company in Park F a lls , W isco n sin , and Weyerhauser Paper M ills . Based upon our telep hone c o n v e rs a tio n o f y e s te rd a y a fte rn o o n , we plan our sam pling a t Howard Paper Company t o in c lu d e : 1. An am bient a i r sample in th e warehouse a d ja c e n t to t a l c storage. 2. An am bient a i r sample in th e h y d ra p u lp e r a re a , w h ile n o t using ta lc . 3. An am bient a i r sample in th e h y d ra p u lp e r a re a , w h ile using ta lc . 4. A personal sample on th e Fork L i f t Truck O perato r as he tra n s p o rts t a lc from the warehouse to the hydrapuloer area. 5. A personal sample on th e H yd ra p u lp e r O perato r w h ile t a l c is not being used. 6 . A personal sample on th e H yd rap ulp er O perato r w h ile t a lc is being used; 7. I f a r a i l shipm ent is in th e p la n t d u rin g o u r v i s i t , we w ill also m onitor the unloading o f the car. Frank Angelos, S u p e rviso r o f the C entral In d u s tria l Hygiene L a b o ra to ry, has discussed d e t a ils w ith J e r ry Timmin and has arranged to a r r iv e by autom obile in Dayton on Monday; e ve n in g , O ctober 7 th . He w i l l spend a l l o f Tuesday a t th e Howard Paper Company; sam pling Tuesday m orning f o r c o n d itio n s when t a l c is n o t being used, and Tuesday a fte rn o o n f o r c o n d itio n s when t a l c is being used. P rovided a l l arrangements are s a t i s f a c t o r i l y m et, we expect to have p re . - lim in a r y in fo rm a tio n f o r you n o t l a t e r - than e a r ly in the. week o f October 14, 1974. 1 a. G /L . Swallow LS/jmb CRMC-MAD-000761 Johns-Manvle Internal Correspondence ToFrom: CELITE ENVIRONMENTAL COMMITTEE MEMBERS _ _ E. M. F e n n e r Copies: p i l e & c Onto: August 2, 1973 Subject: A C G I H D O C U M E N T A T I O N F O R T A L C T H R E S H O L D L I M I T V A L U E S *R. P. C a r t e r E. M. F e n n e r D. E. H i l l i e r T. M. J a c k s o n H. R. K e e f e E. F. M a r r i n e r , M.D. W. B. R e i t z e F. J. Solon, Jr. W. C. S t r e i b G. W. W r i g h t , M.D. in the action minutes of the last Celite Environmental Committee m e e t i n g , h e l d T u e s d a y , J u l y 17, 1973, I w a s given the assignment of again rewriting the ACGIH Documentation of Threshold. Limit Values for Talc in accordance with recommendations made by committee members during the meeting. The assignment also included distribution of the revised documentation to committee members for review before it is sent to Dr. Stokinger, Chairman of the T LV Committee, ACGIH. The rewritten copy is attached. E. M . i F e n n e r EMF/emr Attachs. CRMC-MAD-000762 DRAFT A u g u s t 2, 1973 PROPOSED REWRITE OF DOCUMENTATION FOR TALC - ACGIH COMMERCIAL TALC (non-asbestiform) Although the term talc in its mineralogic sense refers to a specific substance, a hydrous magnesium silicate, it is applied commercially to a variety of products with similar physical properties. Some of these contain only a small talc component. Accessory minerals commonly found are tremolite, serpentine, anthophyllite, magnesite, dolomite, calcite, diopside, chlorite, and quartz. Pyrophyllite has similar uses and is often grouped with talc in commercial statistics. Only talc containing tremolite has been definitely associated with diffuse pulmonary fibrosis, similar tc asbestosis. The T L V of 20 mppcf is b a s e d largely on the work of Dreessen and D a l laValle (1), w h o st u d i e d 66 individuals w h o h a d b e e n e x p o s e d to d u s t in .two m i l l s a n d m i n e s h a n d l i n g G e o r g i a s t e a t i t e talc (soapstone) with 10% tremolite content; they found no pneumoconiosis in those who worked at an average dust concentration of 17 mppcf, but severe and disabling cases were detected in groups working at average dust concentrations of 135 and 300 mppcf. The TLV for talc containing asbestiform minerals is based on the S o fiber count. For talc without identifiable asbestiform minerals o a T L V of 20 mppcf, based on the light-field dust count, is recommended. In some cases it may be desirable to make both dust and fiber counts, if the fiber content is variable or unknown.1 1. D r e e s s e n , W . C . , D a l l a V a l l e , S . M . : Pub. H e a l t h Repts. 50, 1 3 1 (1935) C-lV\ADJ DRAFT A u g u s t 2, 1973 . <: PROPOSED REWRITE OF DOCUMENTATION FOR TALC - ACGIH COMMERCIAL TALC (containing Asbestiform Minerals) The pure talc mineral, which is platey or micaceous, normally is found in nature combined with a number of other minerals which may include the asbestiform minerals: tremolite, chrysotile and anthophyllite. In a number of environmental and clinical studies of w o r k e r s exposed to talc dusts, t a l c c o n t a i n i n g a s b e s t i f o r m minerals has been shown to be of greater physiological significance than talc which does not contain identifiable asbestiform minerals. A proper evaluation of the mineral dust hazard requires a :'*s differentiation in the Threshold Limit Values for the asbestiform mineral containing and non-containing forms. 4pP orro, P a t t o n and H o b b s (1), on the b a s i s o f 15 cases w i t h five | '1 post-mortem examinations, reported that asbestos bodies were almost invariably present in the fibrotic areas in cases of talcosis and noted a degree of similarity between asbestosis a n d p n e u m o c o n i o s i s due to talc. S i e g e l a n d a s s o c i a t e s (2) f o u n d an advanced fibrosis incidence rate of 14.5 % in a study covering 221 miners and millers of talc containing tremolite. The dust to which these workers were exposed was largely fibrous and this physical characteristic was considered to be responsible for the pathology of the lung lesion, particularly because of its resemblance to asbestosis. Findings by McLaughlin and co-workers (3) i n d i c a t e d t h a t t a l c p n e u m o c o n i o s i s c o u l d b e c a u s e d o n l y by CRMC-MAD-000764 -2- the varieties of talc that contain asbestiform minerals. In post-mortem examinations on eight talc industry workers, S c h e p e r s a n d D u r k a n (4) f o u n d h i s t o l o g i c a l f e a t u r e s w h i c h suggested that tremolite was the main pathogenic agent in provoking the characteristic talc lung lesion. In studying th e e f f e c t s of t a l c d u s t on a n i m a l t issue, the s a m e a u t h o r s (5) found that the degree to which the fibrosis supervenes depends on the length of the fibers rather than on their chemical composition. K l e i n f e l d e t al (6) r e p o r t e d p o s t - m o r t e m f i n d i n g s o n s i x t a l c industry workers in which the bodies found in respiratory bronchioles or imbedded in fibrous tissues were indistinguishable from asbestos bodies as seen in asbestosis. Because of the striking similarity in the fibrotic reaction caused by asbestos fibers, and that produced by talc containing asbestiform minerals, the suggested Threshold Limit of 5 fibers exceeding 5 microns in length per milliliter of air is recommended for talc containing identifiable asbestiform minerals. ,<T 1. Por o , F . W . , P a t t o n , J. R . , H o b b s , A . A . : Am. J. R o e n t g e n o l . 47 507 (1942). 2. S i e g a l , W . , Smith, A. R . , G r e e n b u r g , L . : Am. J. R o e n t g e n o l . 9 11 (1943). 3. M c L a u g h l i n , A . I . G . , Rog e r s , E . , Dunham, K . C . : Brit. J. Ind. Med. 6, 184 (1949). 4. S c h e p e r s , G . W . H . , Durkan, T.M.: Arch. Ind. H e a l t h , 12, 182 (1955) 5. Ibid.: 12, 317 (1955) 6. K l e i n f e l d , M . ,. Giel, C.P. M a j e r a n o w s k i , S.F. , M e s s i t e , J.: Arch. Env. H e a l t h 7, 101 (1963). CRMC-MAD-000765 Johns-Manville Internal Correspondence lb: M. A. B a l o g a - 4N Dw* July 22, 1974 From; R. K. C o m a n n -* 4S Copi: Subject: W. L. V a n D e r b e e k , R. G. Rie d e , D. E. H i l l i e r , G. L. S w a l l o w , W. B. R e i t z " `le, C h r o n o SEMI-ANNUAL [STRIAL HYGIENE SURVEY - TALC PLANTS RE: YO U R L E T T E R JUN E 18, 1974 As you know, our most recent survey sited a number of stations at our Los Angeles Plant as being over the TLV of 10.0 or 2.0 F/CC for talc dust. Based on this survey we are taking immediate steps to correct the s ituation so as to b e in compliance w i t h the 1972 OSH A Standards mentioned in your June 18 letter. However, in Mr. F. J. S o l o n ' s l e t t e r o f J u l y 15, 1974, t h e r e is a n Environmental Affairs Checklist which states the following: No. 11. M E S A T a l c S t a ndard M E S A has announced that it is planning a joint study with NIOSH to determine the toxicity of T alc and Tremolite dust exposure. Until the s t u d y is completed the t h r e s h o l d limit values (TLV) p u b l i s h e d in the 1973 edition of the American Conference of Governmental I n d u s t r i a l H y g i e n i s t s (ACGIH) w i l l b e ;u s e d t o m e a s u r e and regulate talc exposure. MESA officials have determined, as a result of the May 1973 Pub l i c Talc S y m p o s i u m , t h a t T a l c and T e r m o l i t e e x p o s u r e are n o t as hazardous as Chrysotile o r o t h e r true-asbestos minerals. Thus, a revised Talc standard can wait until the joint study is f i n i s h e d . ..probably several years. What does this mean to us? Are we still going to be required to reduce our in-plant Talc dust to 10.0 or 2.0 F/CC? Since we are planning some rather expensive appropriations very soon to correct our dust problems, it is essential that we know what standards we are going to be required to meet. Please advise right away. R. K. C o m 2 CRMC-MAD-000766 Johns-Manville fc. E. M. Fenner ' R. P. Carter d m : August 28, 197 From: G. L. SwallOW F. J. Solon, Jr. CopiM: w - B- Reitze m e & Chron Subject: CONVERSATION WITH HOWARD J. SCHULTE/OSHA, AND RAY McCLURE/OSHA REFERENCE: JOHN STENDER'S LETTER OF AUGUST 6, 1974, TO MR. H. B. VANDERBILT, R.T. VANDERBILT CO., INC. In response to your request, I called Howard Schulte and discussed with him the subject letter. He was obviously entirely familiar with 1t. Mr. Schulte stated that the whole interpretation of the letter hinges upon the definition of "asbestiform" and "non-asbestiform". In response to my question as to what was the current definition of as bestiform, or differentiation between asbestiform and non-asbest1form, he stated that the definition is the same as previously used in conjunc tion with the asbestos regultlons, specifically that the-aspect ratio be 3:1 or greater, and that the length be greater than 5 microns. He amplified his definition by saying that if a talc sample were examined under a microscope and more than 5 artifacts/cc were counted, which fit this definition, it would be termed a violation of the OSHA regulations. When I pressed him concerning the difference between artifacts and tremoH t e, he stated that,"We cannot take tremolite from the standard at this time." He further stated that OSHA technicians have never seen arti facts which fit the above definition which they consider to be non-tremolitic. He stated that NIOSH is currently studying the possibility that there do exist non-tremolitic "silvers" which should be differentiated from the tremol1tic fibers and which, because they are (perhaps) not a health hazard, should not be counted when evaluating a talc sample. However, the results of this study aresone to.two years off. In answer to my query, he stated that the Vanderbilt Company argued the above point, namely that such "slivers" do exist and that it is inac curate and unfair to include them in any fiber counts associated with talc sampling. He went on to say that despite Vanderbilt's arguments, OSHA was not going along with this concept, unless and until the NIOSH study mentioned above confirmed 1t. As our conversation drew to a close, Mr. Schulte suggested that since I had asked so many detailed and technical questions, 1t would be well for me to talk to Ray McClure. He told me that he would have Ray call me later today. CRMC-MAD-000767 E. M. Fenner/R. P. Carter August 28, 1974 Page Two Later this morning, Ray McClure called and referred to my conversation with Howard Schulte. He started by explaining that the Vanderbilt mining operations are un der the jurisdiction of MESA, not OSHA. Their concern with the OSHA regulations is because of their customers who have read the asbestos regulations and are worried about being cited 1n their plant operations because of possible tremol1t1c content in the talc. Mr. McClure said that John Stender's letter of August 6, 1974, was an attempt to give some relief for this situation, but doubted that 1t did so very effectively. He stated that he was presently urging certain modifications to the standard as presently written. H1s recommendations are to NIOSH, and must be approved by NIOSH before they can be seriously considered or promulgated. In answer to my question as to what spedfi cally he was recommending, he cautioned me to realize that these were wholly tenta tive and stated that they were: 1. Revise the aspect ratio in the fiber definition (as associated with talc) from 3:1 to 5:1. He noted that such a recommendation would be contingent upon NIOSH opinion regarding the health"aspect. 2. Do not count any fibers whose diameter 1s greater than 5 microns 3. Require that the microscopist attempt to make positive Identifi cation of fibers as being asbestos particularly by means of observ ing the fiber end configuration. He stated that the Salt Lake City laboratory consists chiefly of OSHA people, now, and that.the microscoplsts already attempt to differen tiate between true tremolitlc fibers and other non-fibrous artifacts which would be classified as fibers if judged only by aspect ratio and length. (Please note the discrepancy between this note and Howard Schulte's) Mr. McClure stated that 1f thevabove changes are successfully promul gated, the standard will probably require sampl1ng-by the "asbestos technique" and by 1mp1nger. Whether or not a given station Is over TLV will be judged by whichever criterion 1s stricter. OSHA 1s also consi dering requiring high volumeair samples to permit chemical or minera lgica! analysis of the airborne dust. CRMC-MAD-000768 U .S. DE Occupational PS Aaf eRtyTaMndE HNeTa l tOh V A dLmAinBisOtraRti o n W ASHINGTON, D.C. 20210 Office of the Assistant Secretary August 6, 1974 Mr. H. B. Vanderbilt President. . . R. T. Vanderbilt Company, Inc. 30 Winfield Street Norwalk, Connecticut 06855 t Sear Mr* Vanderbilt; Your request for an Interpretation of the asbestos standard, section 1910.93a, as it related to tremolite talc has been given deep consideration. The following interpretation of the standard, 1910.93a, is *collectively the opinions of both the Occupational Safety and Health Administration and the National Institute for Occupational Safety and Health. The present asbestos standard is written for the purpose of controlling exposures to the fibrous or asbestiform minerals- commonly considered to be asbestos. This is reflected in the established! permissible limit for asbestos air contamination to which a workerrmay be exposed. This is expressed in terms of numbers of fibers in excess of a pre scribed length per unit of volume. The required method of determination or analysis is also expressed as a method for counting fibers. Therefore, nonfibrous or non-asbestiform minerals-such as non-asbesti form tremolite are not within the scope of the existing standard. Talc containing only non-asbestiform tremolite is not regulated by the standard 1910.93a. tor emphasis, if only talc and .non-fibrous tremolite are present, there is no violation of theasbestos-standard. Talc containing asbestiform tremolite or other fibrous'asbestos minerals will be regulated by the standard 1910.93a. CRMC-MAD-000769 Johns-Manville Internal Correspondes ib: R. R e i d e Dat#: J u l y 17/ 1974 From: W. B. ReltZ Copie: r . p. c a r t e r , H. K e e f e , W. V a n D e r b e e k , Dr. P. K o t i n Subject: P O S S I B L E C H A N G E IN T R E M O L I T I C T A L C R E G U L A T I O N S On Monday, July 15 I spoke w i t h Mr. Howard Shulte, Deputy Director, OSHA, regarding recent developments in the regulations of tremolite. Mr. Shulte informed me that after hearing the presentation b y t h e R. T. V a n d e r b i l t C o m p a n y o n t h e d i f f e r e n c e s b e t w e e n fibrous talc and platey talc, OSHA had-agreed to travel to New York state, obtain samples of the Vanderbilt talc, and have the laboratory people at Salt Lake City analyze them. If, after consultation w i t h NIOSH on the results of the a n a l y s i s , t h e y f i n d t h a t ^ t h e ^ s i t u a t i o n d s ^ a s r e p o r t e d -by . Vanderbilt, they will in turn grant Vanderbilt a variance from compliance with the published asbestos regulations. If this variance is granted, they obviously would be under obligation to go through the same procedure for all other talc producers. OSHA has no intention of.changing the asbestos-regulations t o e x c l u d e t r e m o l i t e f r o m 1t h e ^ d e f i n i t i o n o f a s b e s t o s . Howard Shulte further/stated*that theirscientific.people were not overly optUimistic about arrivings at a conclusion t h a t t r e m o l i t i c t a l c 'w a s f r e e - o f f i b r o u s - m a t e r i a l . This procedure is estimated to take in excess of 30 days, and the results will prbhably be announced around the first of September. W. B. Reitze WBR/lc CRMC-MAD-000770 : Johns-Manville Groonwood Plara Denver, Colorado 8021 7 (303)770-1000 June 11, 1974 Professor William A. Burgess Dept, of Environmental Health Science Harvard School of Public Health 665 Huntington Avenue Boston, Mass. 02115 Dear Bill: I have finally had an opportunity to speak to some of our research people regarding our discussion on the NIOSH study you are doing with the Vermont talc miners. Our research people would be only too happy to meet- wi t h y ou and-show you w h a t they have done* to date regarding identification of f i b r o u s t a l c a n d p l a t e y talc. I t is myjtu n d e r s t a n d i n g t h a t they have done work*with the light micrOiscOpe, the trans mission electron microscope, as well as the scanning electron microscope. I would suggest that you contact William C . S t r e i b at our Research Center, PiO. Box 5108, Denver, Colorado 80217. He a n d his p e o p l e w o u l d b e h a p p y to sit d o w n and* ta l k w i t h y o u at our Research Center and 'show y o u our facilities at the same time. With the vacation schedule coming along, would have to be some time in mid-July. contact Bill directly and let me know if this way for the visit. it looks like this Perhaps you could you can get out With best regards, W. B. Reitze Manager, Accident Prevention and Industrial Health WBR/lc cc: W. C. S t r e i b - R 6 D C S M C - M A D ' 000111 m Johns-Manville Internal Correspo To: W. C. S t r e i b - R & D Date: M a y 21, 1974 From: W. D. Reitze - GHQ Copies: F. J. Solon, Dr. G. W r i g h t , H. R. K e e f e Subject: TALC AND HEALTH - YOUR MEMO At the recent AIHA Meeting in Maimi, I discussed this contract with Bill Burgess, w h o is the r ecipient for Harvard University. I do not feel that we will have any problem obtaining information. We may be asked to furnish some methodology to assist Bill in his work. W. B. R e i t z e WBR/lc CRMC-MAD-000772 Johns-Manville Internal Corr To: F. J. S o l o n - 4N From: W. C. S t r e i b - R & D Copies: Subject: Dr. G. W r i g h t - 3W H. R. K e e f e - 2W TALC HEALTH Dote: May 1, 1974 W. B. Reitze - IS I j u s t n o t e d i n t h e A p r i l 16 i s s u e o f C O M M E R C E 9'BUSINESS d a i l y (U.S, D e p a r t m e n t o f Commerce) that N I O S H is n e g o t i a t i n g w i t h H a r v a r d ''University S c h o o l o f P u b l i c "Health for a study to ascertain whether Vermont talc is nonfibrous and to determine the safe level of exposure to this dust. I'm just passing this along in the event .that some Com m i t t e e m e m b e r m i g h t h a v e c o n t a c t s a t H a r v a r d vw h o c o u l d supply us w i t h details. rs CRMC-MAD-000773 r CRMC-MAD-000774 Johns-Manville To: S e e b e l o w * Taie. Internal Corresponds ' Date: N o v e m b e r 7, 1 9 7 4 From: P a u l K o t i n , M . D Coplas: F ^ J . S o l o n , J r i/R, C a r t e r Subject: ( T A L g x L A B E L I M G . *W. R. Goodwin, F. H. Hay, Jr., 5W J. A. McKinney, 5W F. L. Pundsack, RSD C. J. Sulewski,-2W W. L. VanDerbeek, 2S We have been informed by Mr. Robert Bacon, Assistant to t h e P r e s i d e n t of R. T. V a n d e r b i l t C o m p a n y (a m a j o r t a l c competitor) that J-M's dcision to insert asbestos caution labels on all talc,.shipments will,.result in "irreparable damage" to Vanderbilt. Hr. Bacon requested that this matter be brought to the attention of the highest level of management, and he stated that he was a s k i n g Mr. Hugh Vanderbilt, P r e s i d e n t of R. T. V a n d erbilt, to call a senior officer at J-M to voice their concern and their belief that it is J-M's intention to hurt their company. The purpose of this memorandum is to alert you to the situation in the event,you are contacted by Mr. Vanderbilt, Our decision to label talc was based on our conviction that J-M's talc contains^fibrous asbestos^and-in no way reflects any intention to hurt or destroy the Vanderbilt Company. If you would like additional details on this matter, please call me. CRMC-MAD-000775 u- Johns-Manville F. J. Solon and lo: F i l t r a t i o n a n d M i n e r a l s Environmental Committee From: H. R. K e e f e . copi: p. a . M a r t i n s o n , R. K. C o m a n n , H. K r a n i c h , N. B. S c h e f f e l , T. E. Remitters, D / C Subject: T a l c L a b e l Attached is the tale label which will appear on our talc products bag. Please advise the print and size of this label as required by OSHA. Attachment To: R. P. C a r t e r W. A. Cooper E. M. F e n n e r A. C. F. F i n k b i n e r III D. E. H i l l i e r T. M. Jackson, Jr. R. W. M c l n d o e W. B. R e l t z e f c ^ S. W. Schdlirieyer c. F. J. Solon, Jr. W. Streib G. w. W r i g h t , M.D. CRMC-MAD-000776 -------------- FPtt*#r'Fa*r'T'Si 'V- % 'V il T 7T J CAUTION CONTAINS ASBESTOS FIBERS AVOID CREATING DUST. BREATHING ASBESTOS DUST MAY CAUSE SERIOUS BODILY HARM. This commercial talc product contains fibrous tremolite, which has been classified by OSHA as an asbestiform mineral. Compliance with OSHA standards and regulations for exposure to asbestos and compliance with any state and local standards which may exist is required. CAUTION PROLONGED EXPOSURE-.TO EXCESSIVE . QUANTITIES;OFTALC DUST"ALONE.MAY . BE - INJURlOUSjjTOju HEALTH. AVOID CREATING JW D^ATHING' TALC DUST. RESPIRATORS OR|DST%MASKS APPROVED BY NIOSHftORS.THE&BUlRfeAU OF MINES ARE RECOMMENDED. *>#**M* v'i * . r, CRMC-MAD-000777 *is ***38 Johns-Manville Internal Correspond Labeling Review Committee* 0 ^,, Oct. 15, 1974 E. M. Fenner - 4N F. J. Solo n , Jr. H. R. K e e f e - 2W H. K r anich - 2W File 1LC JELINQj REVIEW COMMITTEE MEETING 55ER 15, 1974 REVIEW OF TALC LABEL The proposed talc label was reviewed and decisions made as follows: (1) P r i n t e d l a b e l ( A t t a c h m e n t 1) w i l l b e u s e d for the label to be placed either,by means of rubber stamp or gummed label on'the existing,supply"of bags. The p l a n t w ill a rrange to' have a series; of rubber stamps made of varying type sizes to*determine the optimum size for proper legibility. (2) The printed label to be put on future-b a g s will be identical to the gummed label except that the word caution will be printed in larger, bolder type. (See A t t a c h m e n t 2). *P. Kotin, M.D. - 4N M. J. C owan - 1W A. C. F. FinJcbiner III - 5W W. B. R e i t z e - 4R J. P. L e i n e w e b e r - P & D CRMC-MAD-000778 C A U T IO N CONTAINS*ASBESTOS FIBERS AVOID CREATING DUST BREATHING ASBESTOS DUST MAY CAUSE SERIOUS BODILY HARM f This commercia! talc, product contains fibrous tremollte. which has'rbeen classified by O S H A as an asbestiform mineral. Compliance with O SHA standards and regulations for exposure to asbestos and compliance with any state and local standards whichm ay exist is required. Prolonged e x p o s u re ^ excessive quantities of talc dust alonemay?be injurious to health. Avoid creating andjitfreathing talc dust. Respirators or dst;msks.approvedby N IO SH or The Bureau of Mines are recommended. I CRMC-MAD-000779 I CONTAINS'ASBESTOS FIBERS AVOID CREATING DUST BREATHING ASBESTOS DUST MAY CAUSE SERIOUS BODILY HARM This commercial talc product contains fibrous tremolite, which has been classified by O SH A as an asbestiform mineral. Compliance with OSHA.standards and'regulations for exposure to asbestos and compliance with any state and local standards which may exist is required. Prolonged exposure to excessive quantities of talc dsral0ne^itf(y$biri|iiirl6usHo health. Avoid creatlngiahdibrething talc dust. Respirators or dst masks approved'by N IO SH or Th Burau,f;Mins are recommended. ,,r. CRiVfc. Ma d . 000780 Johns-Manville Internal Correspondence To: L a b e l i n g R e v i e w C o m m i t t e e * Date: O c t o b e r 15, 1974 From: E. M. F e n n e r - 4N Copie: F. J. Solon, Jr. File & C Subject: A B E L I H G ^ R E V I E W C0O1M M I T T E E M E E T I N G ^OCTOBER 15, 1974 GENERAL DISCUSSION in our discussion today, the Committee decided it was necessary to review the present status of product labeling in the Company. Therefore, the following action items were assigned: (1) C h e c k to d e t e r m i n e if a m a s t e r l i s t o f a l l w a r n i n g l a b e l s p r e s e n t l y i n u s e is a v a i l a b l e - (M. J. COWAN) (2) P r e p a r e a n i n v e n t o r y o f a l l p r e s e n t w a r n i n g l a b e l s (E. M. FENNER) (3) C h e c k i n f o r m a t i o n o b t a i n e d *f r o m (1) a n d (2) a b o v e against updated product dictionary when it is i s s u e d - (E. M. FENNER) (4) R e v i e w f o r m e r l a b e l i n g ; p r o c e d u r e s b u l l e t i n as i s s u e d by the Senior Vice President for Research & Development to d e t e r m i n e if d u t i e s 's e t f o r t h in t h e b u l l e t i n s h o u l d be included in the activities of the Labeling Review C o m m i t t e e - (E. M. FENNER) (5) C h e c k J o h n F i s c h e r (Int e r n a t i o n a l ) o n p r o d u c t s m a n u f a c t u r e d a n d s o l d a b r o a d - (M. J. COWAN) It was decided that the Committee would meet at regular intervals but not at any specific date or time. Meetings to be called as n e eded w h e n s uggested b y E. M. F e n n e r and agreed to by P . K o t i n , Mi D . *P. A. M. "W. J. Kotin, M.D. C. F. Fin k b i n e r III J. C o w a n - 1W B. Reitze - 4N P. L e i n e w e b e r - R & D CRMC-MAD-000781 Mr. H. B. V a n d e r b i l t Dear Mr. Vanderbilt: This is in reply to your letter of S e p t e m b e r 26, concerning your request for release from the Asbestos Standard of minerals containing non-fibrous tremolite, actinolite and anthophyllite. My letter of August 6 stated that non-fibrous or nonasbestiform minerals such as asbestiform tremolite are not within the scope of the Asbestos Standard and therefore the provisions of that Standard do not apply to talc containing non asbestiform minerals. NIOSH is currently conducting a thorough investigation into the exact minerals to which talc workers were exposed in those studies where asbesfcosisor other adverse medical effects were found. Pending the receipt and evaluation by OSHA of the report by NIOSH on this investigation, if you have scientific/evidence t h a t t h e naturally, o c c u r r i n g t a l c s , p r i o r <t o p r o c e s S i n g y b y m i l l i n g o r c r u s h i n g , d o n o t c o n t a i n ,f i b r o u s ,o r a s b e s t i f o r m tremolite, actinolite,anthophyllite or other asbestiform minerals, you may certify#-to your customers that the talc does not contain asbestos. Fibrous, asbestifornrminerals, such as fibrous tremolite means naturally occurring asbestiform minerals which prior to or after crushing and processing contain fibers made up of fibrils. Sincerely, John STender CRMC-MAD-000782 Johns-Manville lo: L a b e l i n g R e v i e w C o m m i t t e e * Oct. 14, 1974 From: E. M. F e n n e r - 4K Copte*: F i l e & C r LARflLTMti R F V T F H C O M M I T T E E M E E T I N G TUESDAY, OCT. 14, 1974 9:00 A.M. - 4 North Conference Room A meeting of the Labeling Review Committee is scheduled for 9:00 A . M . , Tuesday, Oct. 15, in the Conference Room 4 'North. Attached is a copy of the proposed talc label to be discussed at this meeting. Attach. *P. Kotin, M.D. - 4N M.J. Cowan - 1W A. C. F. F i n k b i n e r III - 5W W. B. Reit z e - 4N CRMC-MAD-000783 `TS- C* CAUTION CONTAINS ASBESTOS F 3ERS. AVOID CREATING DUST. BREATHING ASBESTOS DUST MAY CAUSE SERIOUS BODILY HARM. This commercial talc product contains fibrous tremolite, which has been classified by OSHA as an asbestiform mineral. Compliance with OSHA standards and regulations for exposure to asbestos and compliance with any state and local standards which may exist is required. Prolonged exposure to excessive quantities of talc dust alone may be injurious to health: Avoid creating and breathing talc dust. Respirators or dust masks approved by N IO S H or The Bureau of Mines are recommended. _ --=> CRMC-MAD-000784 fou'JU je t 2 ncu>xat/3 fie*, '.jgk3?T' 4he *s u -- n i;v;:> \ iohns-Manville To; H. R. Keefe - 2 West Fiom-. g . L. Swallow - 4 North copi-.i,; see Below Suivct: TALC LABELING YOUR LETTER OF JUNE 21, 1974 In answer to your request, I am commenting with regard to your para graph number 3 which states, "OSHA regulations require the control of talc dust to 20 MPPCF. If the talc is controlled to this level, our tests have shown you will also meet the OSHA asbestos standards". Unfortunately, our corporate survey results from both the Los Ange les Talc plant and the Dunn Talc mill do not confirm this statement. At the Los Angeles plant in July 1973, we took simultaneous impinger and membrane filter samples. In order for your statement to be cor rect, it would be necessary for the'impinger counts expressed in MPPCF, to exceed the membrane filter counts expressed in F/cc, by at least a factor of 4. A few typical pairs actually run as follows: Station # Survey Results -MPPCF Survey Results - F/cc D-1M D-2M D-3M D-8M 36.4 32.2 41.4 8.6 40.2 12.0 59.0 4.6 Similarly, at Dunn, typical results were: Station f Survey Results - MPPCF Survey Results - F/cc D-1M D-4M D-5M 2.4 13.1 9.1 3.3 11.2 10.5 We are enclosing the All Stations List In order that you may see the total picture as it exists based upon-the Los Angeles plant surveys of 1972 and 1973, and the Dunn Talc mill survey of 1973. total /G . L. Swallow GLS/jmb cc: R. P. Carter - 4 North W. A. Cooper - 4 North E. M. Fenner - 4 North D. E. Hillier - 4 North T. M. Jackson. Jr. - 2 West P. Kotin, M.D. - 4 North R. S. Lamar - R&D R. W. Mclndoe - 2 West !- B . . w. Jelt.--. 4... senuimeyer - est F. J. Solon, Jr. - 4 North W. C. Streib - R&D R. B. VonWald - 5 West CRMC-MAD-000785  l \ Jonns-Wianville internar C< poi nee To- H. R. K e e f e Date: J u n e 20, 1974 From: W. B. R e i t z e Copies: F. J. S o l o n Subject; T A L C L A B E L I N G The attached eoiwments r e l a t i v e to the J u n e 5 hear i n g s may have some b e a r i n g on just how soon the O S H A p e o p l e w i l l look into the talc industry's compliance with labeling regulations, M y g u e s s is t h a t n o w t h a t B o b B a c o n h a s revfealea,t h e t a l c i n d u s t r y ' s s t a n d o n a n o f f i c i a l b a s i s , t h e oisHA" p e o p l e will proceed immediately to check all talc operations for asbestos compliance. This is mos t certainly another good argument for getting the labels on the bags as soon as possible. W. B. R e i t z e WBR/lc Attach. CRMC-MAD-000786 V* restaurant imisi s.y\e 1.15] $2 lunches for a single $100 aCClYont. A I 'om inii*it sa!i S ,28 pairs of boy sock: in older to make up <hc loss from a $100 accident. Small businessmen should remember that they are trodl. Slender said. " This'm eans that the loss of even a single employee, whether its from a short-time illness or Injury, or the perm anent loss from death, is a real disaster "y their very nature, most small businesses rely on th 'ir employees for a wide variety of duties. Their larger counterparts have many highly-specialized em ployees, and it is relatively easy to fill the gap." OSH A is not em barked on any sort o f attack against retail establishments. Slender said. Of the nearly 60,000 inspections OS!A conducted since last July, only about 2,700 or less than 5 percent were in retail establishments. i Washington OSHA RECEIVES NO PUBLIC COMMENTS ON WASHINGTON PLAN PROPOSED CHANGES No public com m ents were received by the Occupational Safety and Health Administration and no internal OSHA adverse com m ents were generated concerning .Washing* ton's enabling legislation which was subm itted to OSHA as a proposed supplement to the state plan, an OSHA spokesman told OSHR. Comments were requested by OSHA up to May 29 regarding the issue of whether the supplement conforms with tire state's assurances as set out in the state's proposed bill subm itted as part of the state plan (Current Report, May 2, p. 1525). A final OSHA decision approving the supplement will appear in a future Federal Register notice, the spokesman said. A sb e sto s TALC INDUSTRY CHALLENGES ASBESTOS STANDARD DEFINITIONS OF ASBESTOS, FIBER The definitions o f asbestos and asbestos fiber were challenged by Robert C. Bacon, assistant to the president, R. T. Vanderbilt Company, St. Lawrence County, N.Y., at a hearing held by the National Institute for Occupa tional Safety and Health in Rockville, Md,, on June 5. The hearing concerned proposed standards for occupa tional exposure to asbestos m surface coal mines and surface work areas of underground coal mines proposed ' on November 7, 1972,.. ... .... ................ , ....... ...... A A .'cording to Bacon, trcmolitc, anthophyllite, and `aetinolitc haw been historically catacoii/ed as a: ;.e..tos.< lie m aintains t!-.r. this catentmizina is " scientifien';;/ ta iM , i . h e w i - it ! is no medical evidence showing! m, a m. 'ive of the talc'industry-suggested fj . me d a o f asbestos should ' bch changed tqf OCCUPATIONAL SAFETY & HEALTH REPORTER ' . ' 'in-libif'is ofui*. rit' troitmli'r. atit/iopln 11)to, atiUj . ilue I'mms of asbestos uc-conimod n> by 1, ,i| y ! ' e-.-;-s-arc-v".'rianecs*. . ` ' Dacon snid also that (lie definition o f asbestos fiber "is unreal and skirts any nature of the definition o f a fiber'' (Reference File p. 31:5304). He proposed that the defini tion o f fiber is itself crucial to the standard. Robert L Vines, vice president, Bituminous CoaLOperators Association, opposed the proposed amendment to the asbestos standard as unnecessary. Bill Thurber, board member, Asbestos Information Association, commented that the proposed five fiber per cubic centim eter am end ment is too strict. Dr. Loren Kerr, director, occupational health, United Mine Workers o f America, opposed the five fiber limit as too high. He said that the threshold limit concept itself is a hazard to woi kers. Sheldon Samuels, director, health, safety, and environ mental affairs, Industrial Union Department, AFL-CIO, agreed with the UMW stand. He called for a " no measureable am ount o f asbestos" standard, stating that asbestos application should be enclosed and well-ventilated, and that asbestos counting equipment should be checked and logged each week. The hearing was chaired by Dr. Raymond T. Moore, associate director of the National Institute for Occupa tional Safety and Health. General Policy GIDEL URGES INSURANCE INDUSTRY TO ASSIST CLIENTS IN SAFETY CONTROL A $1,000 fine from the Government forcing an em ployer to control a hazardous condition may save the employer from more costly action later, Robert Gidcl, Occupational Safety and Health Consulting Associates, Inc., told the American Insurance Association Adminis trative Engineers at a June 10 conference in Boca Raton, Fla. Gidel advised that the least an employer should worry about is a visit by an Occupational Safety and Health Administration inspector. He said they should concern themselves about legal actions that may be brought by an injured employee, new job standards which can outlaw or force complete redesign o f operating processes and pro cedures, new technical standards which will outlaw or force the complete redesign or retrofitting of machines and equipment, and health standards which may outlaw the use o f certain materials or require such costly control measures that die same effect results. Gidel urged employers to voluntarily comply with safety standards since OSHA cannot inspect every busi ness establishment under its jurisdiction. To aid and advise employers, Gidel called upon the insurance indus try to interpret the "vaguely comprehensible" format of OSHA standards and to further suggest to employers ways to alleviate hazardous conditions. C R M C -M A D -000787 Occupational'Safety & Health Rapar tar a J W . Johns-Manville Internal Corresi *> H . R. K e e f e - 2 W Drte: J u n e 18, 1974 f From: E i p1V Copies: P r R F ^F*`` Subject: \yf. B. R e i t z e R. B. V n W a l d Pile & C TALC LABELING YOUR LETTER OF JUNE 12, 1974 M y s u g g e s t e d l a b e l for y o u r d e s e r t t a l c p r o d u c t s is: CAUTION CONTAINS ASBESTOS FIBER A V O I D C R E A T I N G .D U S T BREATHING ^ASBESTOS 'FIBER MAY CAUSE SERIOUS BODILY HARM. T h i s c o m m e r c i a l t a l c p r o d u c t may. c o n t a i n fibrous tremolite, w h i c h :has been classified by OSHA as an asbestiform mineral. If excessive dust is created, use respirators approved by NIOSH or the Bureau of Mines for protection against pneumoconiosis producing dusts. Ji V CRMC-MAD-000788 Johns-Manville To: From: P. Kotin# M.D. G. W. W right# M.D. H. L. O l s o n R. P. C a r t e r J. S. A u t r y G. R. Cha s e E. M. F e n n e r Date: D e c e m b e r 22# 1976 Subject: F E D E R A L G O V E R N M E N T A C T I V I T I E S R E L A T I N G T O A S B E S T O S Approximately twice a year# EPA's Office of Toxic Substances prepares a list of federal government activities related to asbestos. The last such list was prepared and circulated in June 1976. Attached is a draft of an updated asbestos activities list prepared by the Office of Toxic Substances. This list is presently under review and is likely to be expanded and published sometime next month. >0-- R. p . C a r t e r /jh c k m c -m a d -000189 HEALTH EFFECTS Carcinogenicity A study of the carcinogenicity of various fiber types to rat or hamster was begun in October, and is expected to continue for three years. This study hopes to help determine if asbestos is carcinogenic via the oral route, a question which needs a clear answer and which is abviously, important in regulation. The problem in starting the project was acquiring about 1000 lbs. of fibers of definite type. Robert Tardiff, ORD, 8-684-7213, (513) 684-7213. Cellular Transformations The cultured cells of the hamster colon are being used to evaluate cellular transformation caused by asbestiforra fibers. This project has been going on for about ten months, and should continue for approxi-' mately another two years. Robert Tardiff, ORD, 8*684-7213, (513) 634-7213. Mutagenesis Mammalian cells in culture are being used for an in vitro evalua tion of mutagenicity of asbestos. Work was begun six months ago and should be completed in another 2 1/2 years. Robert Tardiff, ORD, 8-684-7213, (513) 684-7213. Effects of Mine Samples Samples of amphiball fiber from the Mitchell Pit in Minnesota are being administered introtracheally to rats. Later these animals will be examined for carcinogenic and co-carconigenic effects. The study was just begin and will run for several years. The most unusual aspect of this project is that a detailed mineralogical study of the minerals used is involved. David Coffin, ORD, 8-629-2585. Impact of A/C Pipe "Practically all" the communities in Connectinut have been screened via the tumor registry for cancer incidence. An attempt was made to correlate this with'ithe use of asbestos/cement pipe . or other kinds of pipe in the community water supply. A final report is being prepared. Gunther Crawn, ORD, 8-684-7218, (513) 684-7218. California Epidemiology Study Five counties in California are being surveyed to determine if there is a correlation between cancer and asbestos drinking water contamination. The study should be completed in 18 months. Lee McCabe, ORD, 8-684-7211, (513) 684-7211. CRM C-M A D-000790 Duluth Epidemiology Study A feasibility study is being undertaken for an epidemiological study invthe Duluth area (Reserve Mining). This is co-ordinated with OWS. Lee McCabe, 8-684-7211, (513) 684-7211. Talc Facility A detailed Study has been undertaken in upstate New York to document environmental levels of asbestiform fibers near a talc facility and morality and mobidity data on workers. The preliminary report on environmental levels is now in review. The mortality study should be completed May '77. John Dement, NIOSH, (513) 684-3191 with H.P`. Richardson, MESA, (202) 235-8308. Underground Mine Workers The contract has just been let for a 24 month study of health effects and environmental levels at the Homestake Gold Mine. All causes of death will be examined (respiratory cancer and other respiratory disease). Environmental work will commence in the spring. Johm Dement, NIOSH (513) 684-3255, 8-684-3255 with H.P. Richardson, MESA (202) 235-8307. Effect on Toxicity Studies Bioassay experiments to, determine if the asbestos fiber content of Lake Superior water may affect the results of toxicity tests have been completed. Cadmium andEndium were used as typical toxic compounds. No dramatic effect was attributable to the contaminated water. A report is expected within six months. Philip Cook, ORD, (218) 727-6692, 8-782-9574. Fiber Concentration in Tissue . A study.is just beginning which will devise a method for detection and quantification of asbestos.fibers in fish flesh. Natural fish from Lake Superior will be used. This will take approximately two years. Philip Cook, ORD, (218) 727-6692, 8-783-9594. Tagged Fibers in Tissue Amphibole fibers will be radioactively tagged. After exposure to water containing these fibers, fish will be;sacrificed and sectioned. The sections will then be examined radibautographically for hot jpots; as in indication of where-the fibers travel within the fish. This project is just beginniftg*and is expected to take one year. Philip Cook, ORD, (218) 727-6692, 8-783-9594. CRMC-MAD-000791 ,-sV Asbestos in Urine (Possible project, still in thinking stage). Asbestos fibers have been found in the urine of residents of Duluth. This project would discover a reliable method for determination of these fibers in urine, as a possible monitoring technique. Philip Cook, ORD, (218) 727-6692, 8-783-9594. Tagged Fibers/lntubation Asbestos fibers with a high specific activity tristium label have been synthesized. (This is not a surface label that could separate from the fiber after ingestion.) These fibers will be given to rats via intubation. The animals' feces will then be monitored. Later, animals will be sacrificed and examined for'location of any fibers remaining in the body. Since fiber size can be controlled, a comparison will be made of absorption of short versus long fibers. A pilot study has been completed. Fiber synthesis will begin next month; the animal work should follow a year later, after variability has been worked out of synthetic technique. Richard Bull, ORD, (513) 684-7418. Effects of Synthetic Fibers Using the synthetic technique mentioned above, "cold" (non-labeled) fibers will be made. They will be intraperiteneally injected into rats, and their carcinogenicity compared with that of natural fibers, similarly injected. Richard Bull, ORD (513) 684-7418. / CRMC-MAD-000792 EXPOSED POPULATIONS, ENVIRONMENTAL ,,EVELS Problem Identification Sices of possible fiber concentration are being identified from geological maps. Air samples are then taken to see if a possible problem exists. Dr. Goodwin, MESA, 235-8307. Runoff from Roads Six sites are being selected for the identification and enumeration of asbestos fibers by type in road dust. These sites are Milwaukee WI(tvo sites), Harrisburg PA, Nashville TN, Denver CO and Baton Rouge LA -- chosen for geographic distribution and highway design. First analyses have been done: no asbestos found to date. (Analytical work being performed by McCrone -- E.M. with chemical verifications). A report on the whole study is planned for March 1978. Bryon Lord, DOT, 426-4980. Levels in Lake Superior Levels of asbestos in Lake Superior, rivers emptying into Lake Superior, and water intakes from Lake Superior are being established. Samples were collected in 1974. There were approximately 1000 samples; each fiber's length and width was noted. Date is still going into the computer, and.%there:is^ae yet no anticipated date for the final report. (Note: this is.not an ongoing-monitoring program). William Fairloss, Region V, (312) 353-8370; 8-353-8370. Particulate Minerology Unit has established a group to assist in identification of specific minerals in particulate samples. R.A. Clifton, Bom, 634-1206. Releases from Industry Air is being sampled around iron ore benefication plants, and. several have been found to have at least some asbestos. Gilbert Wood, OAQPS, (919) 688-8146 X 295; 8-629-5301. -*** *vv }' C R M C - M AD-000793 PRODUCTION AND USE TRENDS Bureau of Mines Reports Every five years, a new book, Mineral Facts and Figures Is prepared. The most: recent chapter on, asbestos has been completed and is available; the entire book should be printed shortly. Also, a Mineral Yearbook is published annually. This asbestos chapter is ready to go to the printer. The only major new development in asbestos during the past year from BOM's point of view - is the re-opening of a large asbestos mine in California. The management is co-operating closely with safety authorities, and so far all safety standards are being met at the mine. CRMC-MAD-000794 CHEMICAL PROPERTIES & ANALYTICAL cTHODS C haracteristic Fiber Sizes (Possible p ro jec t, s t i l l in thinking stag e). Under consideration is a project which would characterize fib e r size fo r each of various occupations (operations). Correl'lation between electron microscopy and optical determination w ill be evaluated. John Dement, NIOSH (513) 684-3191; 8-684-3191. Air Analysis' Work has been completed on a method for the analysis of a ir samples, which combines electron microscopy and X-ray d iffra c tio n . Report should be out w ithin 6 mos. to one year. P h illip Cook (ORD) (218) 727-6692; 8-783-9574. Leaching from A/C Pipe Water of varied aggressiveness is being run through 90 foot loops of abestos/cement pipe, and leaching of abestos is being examined. Studies have also been done in real communities with water of various aggressiveness. Report w ill be available in mid 1978. (This work w ill evaluate ASTM's formula to determine a water supply's aggressiveness to A/C pipe. I t involves varying the parameters of ph, hardness of w ater). Earl McFarren, ORD (513) 684-7236; 8-684-7236. Electron Microscope Methods-for Analysis An evaluation of electron microscope methods for measurement of airborne asbestos concentrations and the development of an optimal measurement procedure are under study. This a c tiv ity w ill be completed in April 1977. Jack Wagman, ORD, (919) 549-8411; 8-629-1428. X-ray D iffraction Method fo r Analysis Naval Research Lab, in cbrijunction with ORD, has developed a new X-rayydlffraction-proce'dure^inVo^Ving.-flber pre-allignm ent. This wil 1 be used as a rapid screening enforcement method. It is sp e cific and u a n tita tiv e .. Work w ill be completed by July '77. Jack Wagman, ORD, 919) 549-8411; 8-629-1428. Air Monitoring Work has begun on an automatic real-tim e fib e r-d e te c to r and counter, to be used for c o n tin o u s-m o rrito rin g o fair. A prototype Instrument should be made by December '77. Jack Wagmen, ORD (919) 549-8411; 8-629-1428. CRMC-MAD-000795 CONTROL AND DISPOSAL Asbestos in a Community Water Supply Greenwood, SC has a problem of leaching from the asbeacoa/eemenfc pipe carrying the community's water supply. Various control methods will be tried; including addition of ___________ ortho phosphate to the water. (In common use as a coat to prevent corrosion of metal pipes, never before tried on A/C pipe) and pH adjustment. Earl McFarren ORD (513) 684-7236, 8-684-7236. Solid Waste Disposal Studies to develop techniques for control of emissions from asbestos-containing waste piles at asbestos/cement pipe have -been completed. Chemical coverings and soil coverings have been Investigated I plus ways to minimize dust during dumping. Mary Stinson, ORD, (201) 321-6683, 8-340-6683. .000796 c r m c -m a d REGULATORY OPTIONS Workplace Standard The workplace standard is being changed from 5 f/ml to 2 f/ml. This is now undergoing promulgation. Dr. Goodwin, MESA, 235-8307. Drinking Water Standard Asbestos is one of the contaminant being considered in a study by the National Academy of Sciences on the health effects of contaminants in drinking water as a requirement'of the Safe Drinking Water Act. The report should be available by March 1977. If NAS identifies asbestos as a health problem, WS0 will then evaluate economic factors Of regulation. Pat Tobin, 26-8877. CRMC-MAD'000797 Manville M. S h u m a t e R-06 J. P. L e i n e w e b e r W. P l i c h t a W. B. R i t z e 1-06 R-34 1-06 TALC IN TRANS SHIELD h:tio A p r i l 28, 1983 Thank you for the data on the asbestos fiber content of the talc proposed for use as an asbestos substitute in Trans Shield. Considering the nature of the talc business I recommend that the following actions be taken to assure us of a continued supply of fiber free product. 1. T h e p u r c h a s e s p e c i f i c a t i o n f o r t h e t a l c s h o u l d i n c l u d e the fact that it should contain less than 1% of p otential asbestiform minerals as determined by X-ray diffraction. 2. Th e q u a l i t y a s s u r a n c e p r o g r a m s h o u l d i n c l u d e f r e q u e n t analysis of the talc samples to be certain that the product is within the above specification. J. P. L e i n e w e b e r CRMC-MAD-000798 /< 7 S ^ interna! Correspondence Sept. 4, 1974 R. P. C a r t e r Copies: F i l e & C Subject: FDA's regulation on the use of talc J. S. A u t r y E. M. F e n n e r H. R. K e e f e P. Kotin, M.D. R. S. L a m a r J. P. L e i n e w e b e r P. A. M a r t i n s o n G. E. P a r k e r F. ^W. N. F. W. C. w. R. L. P u n d s a c k B. R e i t z e B. S c h e f f e l J. Sol o n , Jr. C. S treib J . Sulewski L. V a n D e r b e e k J. Z azenski As you will recall, the Food and Drug Administration ini t i a l l y p u b l i s h e d a p r o p o s e d regulation on A u g u s t 12, 1972, banning the use of talc containing asbestos in food and food packaging materials. On April 20, 1973, J -M forwarded its comments to FDA on that proposal. We included in our comments a substantial amount of data confirming our conclusion that nc such regulation was justified or necessary. On September 28, 1973, F D A pu b l i s h e d a second proposal which would additionally restrict the use of talc containing asbestos in any drug, drug ingredient or drug packaging material. J-M's comments with respect to both proposals focused attention on four major areas: the value and use of talc in food and drug packaging materials; the results of migration s t u d i e s c o n d u c t e d b o t h i n - h o u s e arid o u t s i d e ; r e l e v a n t m e d i c a l studies; and suggested modifications to FDA's proposed test method for the identification of the presence of asbestos in talc. On F e b r u a r y 27, 1974, Dick Lamar and J i m Leineweber of our Research and Development Center and myself met with three officials from FDA to review various questions raised by FDA with respect to our comments in response to FDA's proposed regulations. As a result of that meeting, we agreed to respond to eleven specific questions raised by FDA and to conduct certain additional studies to confirm our earlier findings that tremolito does not migrate from paper packaging CRMC-MAD-000799 J. S. A u t r y , e t al Page 2 Sept. 4, 1974 materials containing tremolitic talc to the food or drug contents during commercial handling and shipping. Our Research and Development Center has now completed the additional studies requested. Attached you will find a c o p y o f o u r c o v e r l e t t e r d a t e d S e p t e m b e r 4, 1 9 7 4 to F D A and a memorandum responding to FDA's=eleven^questions. A meeting has been scheduled with FDA officials for September 12,at which time we will review the attached documents. We are optimistic that FDA will confirm our conclusion that there is no migration problem. FDA is presently in the process of drafting a position paper to be published in the Federal Register, specifically reviewing the many comments submitted in response to their two proposals.and reporting their conclusions, thereon. I was advised by FDA.this week that they believe it is still possible*-to include our new-,data in their position pap e r . A t our^Septeinber 12* m e e t i n g , w e w i l l m a k e e v e r y effort to convince FDA not to impose any restriction on the use of talc containing tremolite in food and drug packaging applications. I will keep all of you advised as to the results of this meeting. R. P. C a r t e r RPC/emr Attachs. CRMC-MAD'000800 Johns-Manville Corporation Grnwood Plaza Denver, Colorado 802i 7 Environmental Affaire Department S e p t e m b e r 4, 1974 Dr. C o r b i n I. M i l e s GRAS Review Branch Division of Food and Color Additives Bureau of Foods Food and Drug Administration 200 C Street, S.W, W a s h i n g t o n , D. C. 2 0 2 0 4 Dear Corbin: As y ou will recall, on December 21, 1973, Johns-Manville Products Corporation submitted written comments to the Food and Drug Administration in response to FDA's Notice of Proposed Rulemaking relating to asbestos particles in food and drugs, as published in the F e deral Register on September 28, 1973 (hereinafter referred to as the "Proposal"). On February 27, 1974, Dick Lamar and Jim Leineweber of our Research and Development Center and myself met with you, A1 Holtz and Bill Eisenberg to review eleven questions raised by F DA with respect to our December 21, 1973 submission. O n A p r i l 2, 1974, I f o r w a r d e d a l e t t e r to y o u o u t l i n i n g our understanding of the eleven questions posed, setting forth answers to those questions where information was readily available and outlining what we proposed to do to provide the requested information for the remaining questions. Attached to this letter, is a memorandum listing each question posed and the information requested by FDA and J o h n s - M a n v i l l e 's r e s p o n s e s th e r e t o . I n c l u d e d in this memorandum, for the purpose of clarity and continuity, are those questions previously answered in part or in f u l l in m y A p r i l 2, 1974 letter. The necessary Research work undertaken to provide FDA with the information requested has taken a considerable amount of time. This was due to the nature of the work involved C R M C -M A D -0 0 0 8 0 1 Dr. C o r b i n I. M i l e s Page 2 September 4, 1974 and the considerable demands placed on our Research facilities and personnel with respect to other important projects. Additionally, our Research personnel place considerable importance on the integrity of the research work undertaken in response to FDA's questions and the necessity to obtain valid results. The results of the research work undertaken in response to FDA's questions confirm the conclusion reached by Johns-Manvilie in our submission dated December 21, 1973, t h a t t r e m o l i t e does, n o t - m i g r a t e f r o m p a p e r p a c k a g i n g materials containing tremolitic talc to the food or drug contents during commercial handling and shipping. It is our hope that FDA will reach the same conclusion from the attached memorandum, and as a result, will not impose any restriction on the use of talc containing tremolite in food and drug packaging applications. As we discussed in our telephone conversation yesterday, I am not enclosing the original photographs or charts, as we do not have any additional copies. I will bring the originals with me for our meeting at 2:30 P.M. on September 12. Dick Lamar, J i m L e ineweber and Rich Zazenski from our Research and Development Center will accompany me at this meeting. I look forw a r d to s e e i n g y o u on S e p t e m b e r 12 and h o p e it will be a most productive meeting for all concerned. We will be prepared to answer questions which you and your associates may have with respect to the attached memorandum Very truly yours, R i c h a r d P. C a r t e r , D i r e c t o r Government Relations RPC/emr Attach CRMC-MAD-000802 MEMORANDUM PREPARED BY JOHNS-MANVILLE PRODUCTS CORPORATION IN RESPONSE TO ELEVEN QUESTIONS POSED BY THE FOOD AND DRUG A D M I N I S T R A T I O N AT A MEETING HELD ON FEB. 27, 1974 These questions and the answers thereto relate to the comments dated December 21, 1973, submitted by Johns-Manville Products Corporation to the Food and Drug Administration in response t o F D A 's N o t i c e o f P r o p o s e d R u l e m a k i n g r e l a t i n g to a s b e s t o s particles in food and drugs, as published in the Federal Register on September 28, 1973. T h e q u e s t i o n s r a i s e d b y F D A a n d J o h n s - M a n v i l l e 's r e s p o n s e s th e r e t o are as follows; QUESTION 1 WHAT IS THE RELATIONSHIP BETWEEN THE FIBER COUNT AND THE SURFACE AREA OF THE CONTAINER (FOOD CONTACT AREA)? The areas for the various food containers are as follows: Salt shaking or scuffing Macaroni container' Carnation dried milk Quick rice Cornflakes Morton's salt test 18.18 sq. in. 88.0 sq. in. 138.0 sq. in. 160.0 sq. in. 304.0 sq. in. 45.0 sq. in. In the case of the five packaged food items, TEM and petrographic analyses could not detect the presence of tremolite in any of the food that was packaged in tremolitic talc containing paper. Thus, the ratio of fibers to food contact area is zero for each item. There was no migration. In the case of the four test containers (salt packaged in tremolitic-talc containing paper) that were shipped by truck approximately 4,000 miles, petrographic analysis revealed no evidence of the presence of any chrysotile or tremolite fibers due to migration. TEM examination of all four samples indicated only the possibility of one tremolite fiber in one of the test contents. For all practical purposes, the ratio of fibers to s u r f a c e a r e a for e a c h o f t h e s e s a m p l e s is 0 f i b e r s / 1 8 . 1 8 sq. in. (Each c o n t a i n e r ha d an e f f e c t i v e co n t a c t area of 18.18 sq. in. and a void space of 15 p e r c e n t interior c o n t a i n e r volume to allow free movement of contents within the container.) QUESTION 2 . WHAT ARE THE LOWER LIMITS OF DETECTABILITY BY TEM, PETROGRAPHIC AND XRD METHODS FOR TREMOLITE AND CHRYSOTILE IN TALC? The work which was undertaken to respond to this question should be qualified in one important aspect. Wo have interpreted the CRMC-MAD-000803 -2- limits of identification to mean the levels at which positive identification can be made by each method. As a review of the data below will indicated, this is an important consideration. A. P e t r o g r a p h i c i d e ntificati o n o tremolite and chry s o t i l e in comminuted talc using Johns-Manville's modified FDA method at a magnification of 500X. 1. T r e m o l i t e - In g e n e r a l , p o s i t i v e i d e n t i f i c a t i o n of t r e m o l i t e can be made on fibers as small as 2.5 x 7.5 microns. However, in some samples examined, positive identification can be made on fibers as small as 1.5 x 5 microns. Unlike "fibrous talc", the Becke line can be followed readily if there is a mis-match in indices of refraction. However, by our method, we use an index oil of 1.622 to match the gamma index at the position of inclined extinction which can vary from 14 to 20 degrees (gamma index relative to the Z direction). Tremolite is also non-pleochroic whereas actinolite and ferroactinolite can be highly pleochroic, accompanied by higher indices of refraction. An experienced petrographer will also look for good cleavage along (110), parting along (100), and twinning along (100), and sometimes along (001). At a position of 90 degrees from inclined extinction, the fiber w i l l show high relief since alpha index is indicated and is on the order of 1.599. 2. C h r y s o t i l e - T h e i d e n t i f i c a t i o n o f c h r y s o t i l e is v e r y much liketremolite since positive optical identification can be made on fibers as small as 2.5 x 7.5 microns. The technique involves using 1.566 oil to capture the gamma index in parallel extinction in which the fiber will disappear or show Christiansen effect in plane p o l a r i z e d light. At 90 degrees from the gamma position, the fiber will show high relief since the alpha index is 1.549 or less. Maximum interference color (Birefringence) is shown at 45 degrees. It is not unusual for chrysotile to show undulatory extinction. Fibrous talc also shows parallel extinction, but the relief is high in either direction; but a match with the 1.556 oil can occur a n y w h e r e f r o m 45 to 80 d e grees. B. T E M d e t e c t a b i l i t y 1. T r e m o l i t e - T r e m o l i t e f i b e r s c a n n o t b e p o s i t i v e l y identified by TEM. Usually, tremolite is verified by chemical, optical or X-ray diffraction methods and then dense asbestiform amphibole morphology is viewed by TEM as tremolite. The eleftron diffraction pattern o f t r e m o l *he is s i m i l a r to all o t h e r m o n o - c l i n i c a m p h i b o l e s . (See F i g u r e :To. is possi>l z to A n g s t r o m "',*+* 1, a t t a c h e d ) . U s i n g the R C A E M U 3B, it ~e tremolite on the order of a few hundred owever, it appears to be the nature of tremolit remain on the coarse side when compared to chrysot:le. CRMC-MAD-000804 -3 - 2. c h r y s o t i l e - C h r y s o t i l e f i b e r s can b e p o s i t i v e l y 'identified by morphology and electron diffraction. (See F i g u r e No. 2, a t t a c h e d ) . T h e e l e c t r o n d i f f r a c t i o n pattern is distinctive since alternate rows of Laue spots are not spots but rather elongated streaks. The morphology is most unusual since chrysotile is c h a racte r i z e d b y an internal low density tubular structure which is sometimes beaded. The most narrow of individual fibrils of chrysotile are on the order of 250 Angstrom units. Below this width, t he m i n e r a l c e a s e s to be c h r y s o t i l e . The most common magnification employed for the study of chrysotile and asbestiform amphiboles is 8000X. The negative is enlarged 2.5 times to provide an 8.5 x 10-in. print at a magnification of 20,000X. C. X R D i d e n t i f i c a t i o n Qualitative evaluations at 2/minute and quantitative evaluations at l/4/minute were performed using Ni filtered CuK radiation. 1. .T r e m o l i t e - W i t h q u a l i t a t i v e e x a m i n a t i o n t h r o u g h the 5T3 A ""peak area, d e t e c t i o n c o u l d b e m a d e at the level of 0.5% tremolite in talc. However, quantitative evaluation could not be made below 1.0% even though samples containing 0.0, 0.25, and 0.5% tremolite were compared to background counts, with none having counts above background. 2 * Chrysotile - While 1.0% chrysotile can be detected by XRD under the 7.3 A peak, positive identification by this means may be difficult because of the conflict between major chlorite peaks and serpentine peaks. The former appear at 7.3 and 3.65 A and would obscure chrysotile concentrations. Serpentine has a minor peak at 2.15 A which differs slightly from the minor 2.10 A peak, but neither would be apparent at low concentrations of either mineral or combinations of the two. In the a b s ence of chlorite, 1% c h r y s o t i l e (in talc) w as measurable, but small quantities of chrysotile in the presence of serpentine would not be detected. From the foregoing, we believe the following conclusions can be substantiated: (1) I n d i v i d u a l t r e m o l i t e p a r t i c l e s 2.5 x 7.5 m i c r o n s can be positively identified petrographically and under some circumstances, articles as small as 1.5 x 5 microns can a l s o be identi :ied. CRMC-MAD-000805 -4 - (2) T r e m o l i t e p a r t i c l e s c a n n o t b e p o s i t i v e l y i d e n t i f i e d as s u c h by TEM, since they cannot be distinguished positively from other amphibole mineral~. (3) T r e m o l i t e p a r t i c l e s car be d e t e c t e d at t h e 0 .5% l e v e l b y XRD but their quantity cannot be determined accurately below 1.0%. (4) C h r y s o t i l e f i b e r s 2.5 x 7.5 m i c r o n s c a n a l s o b e p o s i t i v e l y identified petrographically. (5) C h r y s o t i l e can b e p o s i t i v e l y i d e n t i f i e d b y T E M m o r p h o l o g y and electron diffraction, with the lower limit of fibril width being of the order of 250 Angstrom units. Below this figuref the mineral ceases to be chrysotile. (6) T h e c h r y s o t i l e c o n t e n t o f t a l c can b e d e t e r m i n e d a t t h e 1.0% level only if the commonly associated minerals, chlorite and serpentine,are not also present. If they are present, chrysotile may not be positively identified. QUESTION 3 PROVIDE VALIDATION AND RECOVERY DATA FOR TREMOLITE AND CHRYSOTILE IN SPIKED SAMPLES OF TALC - SAMPLES OF TREMOLITE AND CHRYSOTILEFREE TALC TO WHICH KNOWN AMOUNTS OF TREMOLITE AND CHRYSOTILE HAVE BEEN ADDED. The following data contains our findings with respect to Petrographic TEM and XRD examination of a series of standards made from amphibolef r e e t a l c and v a r y i n g p e r c e n t a g e s o f t r e m o l i t e . In a d d i t i o n , X R D examination of similar talc - chrysotile standards was m a d e , but a set of talc - chrysotile standards suitable for Petrographic, and TEM examination was not available. Because little, if any, chrys o t ile-containing talc is used by the pulp and paper industry, it was decided that the very time consuming preparation of such standards was not warranted in view of the detection data already made available. A. Tremolite validation The following t a bulation sets forth trem o l i t e cont e n t vs. numbers of "fibers" in talc samples. In all cases, the number of tremolite particles should be read as +20%. So-called fibers are tremolite particles having a 3:1 aspect ratio and a length of at least 5 microns counted at 500X. CRMC-MAD-000806 Sample F-l Standard Percent Tremolite By Weight 0.25% No. of Tremolite "Fiber's" per mg of Talc 41.000 F-2 Standard 0.50% 61.000 F-3 Standard F-4 Standard 1.00% 2.00% 111,000 207.000 F-5 Standard 4.00% 400.000 F-6 Standard 16.00% 1,800,000 Tremolite-free Talc 0 The slight lack of linearity is due to the difficulty in obtaining sufficiently dispersed slides to permit unhindered counting, i.e., a top layer of particles obscuring lower layers, and the counting precision noted above. F i g u r e s 3 and 4,attached, are e l e c t r o n p h o t o m i c r o g r a p h s (TEM) of two of the above materials. Figure 3 is the tremolite-free talc at 2Q,000X as reproduced here. Figure 4 is the same talc s p i k e d w i t h 0 .5% t r e m o l i t e (F-2 S t a n d a r d ) . T h e r e are t h r e e (3) tremolite "fibers" present and these are the most dense in the entire print. Other similar looking particles in both pictures are talc platelets on edge. Each tremolite particle identified represents 1,100 particles per mg of sample. F i g u r e 5, a t t a c h e d , is a c o m p o s i t e X R D t r a c i n g c o v e r i n g the same series of samples used for the petrographic examination. The various levels of tremolite added,from 0 to 16% by weight, are indicated along with the height of the 9.4 A peak for each. Fo r samples having no or 0.25% t r e m o l i t e , t h e r e is no discernible peak. At 0.5%, an identifiable peak appears which becomes more prominent as the percentage of tremolite increases. This latter phenomenon can be used to estimate the amount of tremolite present when compared to a sample containing a known and discernible amount of tremolite. This is done by determining the n u m b e r of c o u n t s o r u n i t s of a r e a u n d e r the p e ak. F i g u r e 6, attached, is a plot of counts vs. t remolite cont e n t of the same standards, extended in this case to include one having 50% tremolite. All counts are corrected for background. The lowest level having a count above back , ound is 1.0%. Above this point, the relationship between point cour : anJ tremolite content is seen to be quite linear, a n d it c o u l d b e u ad as . '-liable m e a n s o f a s s e s s i n g t r e m o l i t e content above tha CRMC-MAD-000807 -6 - B. C h r y s o t i l e As noted previously, no comparable series of chrysotilespiked samples suitable for petrographic and TEM examination is available. Differences in the manner of dispersion of the fibers,makes samples for microscopy much more difficult to prepare than those for XRD. Some samples for XRD were prepared for this study. F i g u r e 7, a t t a c h e d , is a c o m p o s i t e X R D t r a c i n g o f talc, and talc with chrysotile added in the amounts of 1.2 and 2.21 respectively. It s h o u l d be noted that the 7*3 h peak is sufficiently well developed to indicate that a q u a n t i t a t i v e e v a l u a t i o n c o u l d b e m a d e at a b out 1%. However, It must be emphasized that chlorite and serpentine produce identical to similar peaks if present. As an i l l u s t r a t i o n , F i g u r e 8, a t t a c h e d , is an X R D t r a c i n g for a mixture of 60% chrysotile and 40% serpentine (without talc) showing the peaks b etween 2.10 and 4.57 A. Only the peaks at 2.10 A for chrysotile and 2.15 A for serpentine are distinguishable. However, if these were included in a mixture which was mainly talc, they would no longer be discernible. The above leads to the conclusion that chrysotile can be positively and quantitatively identified by petrographic or TEM means. However, a quantitative gravimetric evaluation must take into account that chlorite and/or serpentine minerals cannot be present. QUESTION 4 A REQUEST WAS MADE THAT, WHEREVER POSSIBLE, WE RETAIN ALL SAMPLES, PREPARATIONS, SLIDES, ETC. Wherever possible, we are doing this. however, are not permanent. Immersion and exposure to air. We are retaining TEM's. Petrographic slides, oils change with age the negatives for all QUESTION 5 IN O U R S A L T - S C U F F I N G TESTS, D O W E H A V E D A T A F O R 10 CPS T E STS S I M I L A R T O 19 CPS T E S T S ? DO W E H A V E T E M T E S T R E S U L T S A T 10 C P S ? DO WE HAVE RETAINED ASH SAMPLES? T h e d a t a on the 10 cps t e s t is as follows: CRMC-MAD-000808 7- Sample RS 73242-2A RS 73242-2B % Tale in Paper Residue Due To Scuffed P a p e r (gms) 1.0 0.00000 1.0 0.00000 Number of Talc Particles* 0 0 Number Of Chrysotile & Tremoliate Fibers 0 0 Residue viewed petrographically at 500X. These results are discussed on pages 3 and 4 of Report No. E 4 1 4 - 2 , Preliminary Studies of Food Contamination by C o n t a c t w i t h P a p e r (Exhibit I, Johns-Manvil'le s u b m i s s i o n "dated D e c e m b e r 2i, 1973). T h e r e are n o T E M r e s u l t s at 10 cps, as there are none for any of the artificial test results. TEM analysis began on samples that had actually endured road travel and on the analysis of actual food contents. Except for TEM negatives, we have not retained ash samples o f an y w o r k p r i o r t o M a r c h 1, 1974. W h e n e v e r p o s s i b l e , w e are doing so now. Although FDA requested that we repeat these salt-scuffing tests, based on the research work undertaken in preparation of our submission dated December 21, 1973, and based on the additional work reported herein, we have reached the conclusion that it is futile to run additional artificial scuff tests at this time. An artificial test is generally any test which Simulates an actual occurrence. It is usually run on a smaller scale and at accelerated times. Before any laboratory test can be designed to simulate an actual or large-scale occurrence, all of the parameters and variables must be known so that they can be s c a l e d down correctly. O n l y b y k n o w i n g t h e s e p a r a m e t e r s and variables, can one even begin to design and build a simulated model which will produce valid test results. In the case of the artificial scuff tests, we were requested by FDA to run and re-run paper samples on the artificial scuff tests. It was assumed that a test of this nature would simulate the vibrating action which food packages undergo during normal commercial shipping and handling. This is a dangerous assumption. The simple procedure of placing a test container on a vibrating table, vibrating at an arbitrarily chosen amplitude and frequency fnran arbitrarily chosen period-of time, simply cannot be said to simulate actual shipping and handling. Any conclusions or correlations between this artificial test and actual road travel would be completely unfounded. Yet, in the months of study on this subject, many people have tried to compare the two. Such erroneous assumptions can lead to mistaken conclusions. Based on that the w h i c h is contents the research work completed thus far, we have concluded only data.which warrants consideration is that data supplied examining actual food contents and test t h a t unde :go a c t u a l r o a d travel. F o r t h e s e r e asons, CRMC-MAD-000809 -8- the results and conclusions discussed in Report No. E414-6, L a c k O f `F o o d C o n t a m i n a t i o n B y C o n t a c t W i t h P a p e r D u e T o S h i p p in g (Exhibit II, Johns-M a n v i l l e submission dated December 21, 1973), and the data furnished in response to Question s herein, should be regarded with the utmost importance. QUESTION 6 PROVIDE A DESCRIPTION OF OUR METHOD AND A SAMPLE CALCULATION OF OUR XRD ANALYSIS OF FOOD P A C K A G I N G P A P E R F O R TALC CONTENT. XRD analysis of food packaging paper for talc content is performed by scanning the paper over the 9.4 A peak and computing the percent of talc present from the ratio of the area count obtained for the unknown paper to the area under the peak of a standard paper of known talc content. Papers of verified talc contents ranging from 0.53% to 12% talc are used for standards. A. S a m p l e C a l c u l a t i o n : U n k n o w n P a p e r S a m p l e Scan 200 sec from 9.9 to 8.23 20 = 64,056 counts Background Determination: C o u n t f o r 100 s e c o n d s at 9 . 9 20 = 2 5 , 3 9 4 c o u n t s C o u n t for 100 s e c o n d s at 8,23 20 = 2 4 , 1 8 7 counts 49,581 counts (total background count) 64,056 -49,581 14.475 counts counts counts (total sample counts) (total background counts) contributed by talc in paper sample B. S t a n d a r d S a m p l e : 2.5 P e r c e n t T a l c The same procedure determines that the 2.5 percent standard has a total count due to the talc of 15,069 counts. The percent talc in the unknown paper sample is computed by: 14.475 counts (unknown sample) ,, 0 _ 1 r ' r\ C\ -- r ir niir- 1 ' _ r ^ A~ r " ~ j . X 15,069 counts (2.5 p ercent standard) 2 5% bSlC 2.4% talc in unknown paper sample QUESTION 7 IN T A B L E I V - A O N : 7\GE ; 1 . R E P O R T NO. E 4 1 4 - 2 (Exhibit I, J O H N S - M A N V I L L E S U B M I S S J >N DATE-.. "K C E M B E R 21, 19 7 3), T H E S I X - H O U R R E S U L T S A P P E A R 01 ._E. C A N T H I S A N O M A L Y BE E X P L A I N E D ? CRMC-M A D -0 0 0 8 10 As for the irregularity of the six-hour results, we can only suggest.the possible source of error, since a definite explanation is not known. We st rongly believe the anomaly is a result of a human error, probably committed early in the weighing procedure. The belief that the anomaly is due to human error, is strongly supported by the other data. Since six out of seven data points form a definite, regular curve, and since the irregular data point is not at either end of the curve, but somewhere in between, scientific logic suggests that the point should be disregarded and labeled as a procedural error. QUESTION 8 PROVIDE VALIDATION OF THE MEAT WRAPPING AND SAMPLING TESTS AND THE SENSITIVITY OF THESE TESTS. IN ADDITION, RELATE ANY MIGRATION TO MEAT SURFACE OR MEAT WEIGHT. This question relates to the McCrone meat wrapping studies (Exhibit E, J o h n s - M a n v i l l e sub m i s s i o n d a t e d A pril 20, 1973) in which talc-containing papers were placed in contact with raw meat. Subsequent examination of the meat, both in thin sections and after ashing, showed no migration of tremolite. The question raised by FDA was whether talc containing tremolite would have been detected if present in the meat in McCrone's studies. The answer is essential to the validity of McCrone's finding that no migration of tremolite had occurred. An e x p e rimental plan, a copy of w h i c h is attached her e t o as F i g u r e 9, w a s d e v i s e d t o c o n f i r m t h e p r e s e n c e o r a b s e n c e of tremolitic talc on meat under known conditions. Preliminary experiments indicated that there is no practical w a y to determine the lowest level of detectability, which was one element of the FDA question, because we could not uniformly spread extremely small amounts of tremolitic talc over a known area. Applications of the order of 0.1 to 0.2 mg/cm2 are so apparent, however, that the limit of detectability is probably at least three orders of magnitude lower, i.e., 0.0001 to 0.0002 mg/cm2 . We were unable to devise a means of applying such small amounts. Test Results U s i n g the p r o c e d u r e d e s c r i b e d in F i g u r e 9, s a m ples w e r e p r e p a r e d from three steaks, the first a control having no contact with tremolitic ta1. except what might have come from the wrappings and mask, the secur'd h a v i n g an a p p l i e d do s e of 0.12 m g / c m 2 o f J - M C Y C L O - ORB, u.. ' the t h i r d h a v i n g an a p p l i e d d o s e of 0.16 m g / c m 2 c ' ` ~ -- 0-FIL. Samples of all paper in CRMC-M A D -0 0 0 8 1 1 -10- contact with the meat were also obtained to identify any source that could have lead to contamination of the control. The three samples of raw meat scrapings were examined by optical microscope at 500X. Results are reported as follows: Sample Number Sample Talc Tremolite 4384-38-4 (Fig. 10) Meat Control None detected None detected 4384-38-5 (Fig. 10) Meat with 0.12 mg/cm^ CYCLO-SORB Present Present 4384-38-6 (Fig. 11) Meat with 0.16 mg/cm^ CYCLO-FIL Present Present Three pictures, attached, as Figures 10 and 11, are photomicrographs of the three meat samples above, taken at 500X. It should be noted that talc and tremolite particles are readily visible in the samples to which CYCLO-SORB and CYCLO-FIL were applied, but neither talc nor tremolite could be confirmed in the blank. The CYCLO-FIL-dosed sample also illustrates the problem mentioned earlier of obtaining even distribution of dispersion of very small amounts of talc, in this case 0.16 mg/cm , and obtaining representative samples therefrom. The fibrous material in all of these pictures is part of the raw meat structure. M e a t and p a p e r samples w e r e then ashed for 16 h o u r s at 800F. There was considerable difficulty in reducing the carbonaceous content of these samples to low enough levels to permit reliable examination, but this was finally achieved. Optical microscopy results are as follows: Sample Number Sample Talc Tremolite 4384-38-4 Meat Control None detected None detected 4384-38-5 Meat W/CYCLO-SORB Present Present 4384-38-6 Meat w/CYCLO-FIL Present Present 4384-38-1 Mask Paper Trace None detected 4384-38-2 Outside, Wrapper Trace None detected 4384-38-3 Meal c^rtact Wrap None detected None detected CRMC-MAD-000812 -1 1 - The final part of FDA's question relates to number of tremolite particles applied meeting the standard of 5 length with a 3:1 aspect ratio. The 0.12 mg/cm2 CYCLO-SORB applied is estimated to cont a i n 390,000 (20 percent) t remolite p articles m e e t i n g the above criteria. The 0.16 m g / c m 2 CYCLO-FIL applied is e s timated to contain 1,250,000 (20 percent) tremolite particles meeting the criteria. No attempt was made to enumerate talc particles in either case, since such particles do not generally fit the criteria. However, many millions of particles can be seen and particle size analysis indicates that theie are many millions more that are sub-optical microscopic. Based on the high numbers and degree of detectability of both talc and tremolite particles on meat samples and ash in this study, it is concluded that McCrone's finding, that migration of tremolite from the tremolitic talc-containing wrappings did not take place, is valid. Had even a very low order of migration taken place, it would have been detectable. QUESTION 9 PERFORM BOTH SCUFFING AND SHIPPING TESTS USING PAPER WITH HIGH LOADINGS OF TREMOLITIC TALC (PAPER WITH THE HIGHEST LEVEL OF TREMOLITIC TALC THAT IS COMMERCIALLY USED FOR FOOD PACKAGING WRAP) See our answer to Question 5 as to why we did not perform additional scuffing tests. As requested by FDA, salt shipping tests were repeated, employing papers with high loadings of tremolitic talc. To briefly review the test , it consists of lining salt-filled glass jars with test papers and shipping them by truck approximately 4,000 miles (For a more complete description of the test procedure utilized, see John s - M a n v i l l e ' s s u bmission dated December 21, 1973). By utilizing this procedure, we can duplicate, if not exceed in stringency, the conditions under which food packages are shipped. The test results reported hereinafter were obtained from papers with exceptionally high loadings of tremolitic talc. The papers used to line the salt-filled glass jars contained 9%, 14% and 20% of Johns-Manville's CYCLO-FIL talc. The 9% and 14% CYCLO-FIL papers were obtained from a Johns-Manville customer which purchases CYCLO-FIL. The 20% CYCLO-FIL papers were previously made by Johns-Manville for testing purposes, using CYCLO-FIL. Therefore, we knew that tremolite was present in all of the paper used to line the salt-filled glass jars, as CYCLO-FIL c o n t a i n s a pproxiir'fcely 3 0 % t r e m o l i t e . To c o n f i r m the p r e s e n c e of t a l c in the p; oer u s e d in this test, the a n a l y t i c a l m e t h o d CRMC-MAD-000813 set forth in our answer to Question 6 of this memorandum was utilized. Our XRD analysis of these papers confirmed the presence of talc. It is essential to note that after an exhaustive search, we were unable to locate any food packaging paper containing loadings of talc in excess of the paper utilized in the salt shipping tests reported in Exhibit n to our December 21, submission. As n oted in our December 21, 1973 submission, papers with high talc loadings would normally not be used for direct food packaging applications. However, FDA requested that we specifically subject highly loaded talc papers to the salt shipping test. Therefore, these highly loaded talc papers, which are manufactured for such purposes as writing paper, t e x t b o o k s , etc. (as i n d i c a t e d b y o u r c u s t o m e r s ) , w e r e utilized. 1973 A m i s u n d e r s t a n d i n g w h i c h m a y have arisen from our D e c ember 21, 1973 submission should be clarified. High brightness talc (i.e., CYCLO-FIL) is used in the manufacture of fine paper products as a high-brightness filler and opacifying pigment. Its loading ranges may vary from 2% to 15% by weight. CYCLO-FIL and other related ultra-fine particle size white pigments are used to increase opacity and brightness and in many instances to improve the printing characteristics of the paper. The ultra-fine particle size also develops a unique synergistic effect when blended with Ti02 It not only acts as a spacing mechanism, but also attracts the Ti02 to the platey planar surface, thus resulting in increased efficiency from TiO? usage. However, it is important to e m p h a s i z e that high b r i g h t n e s s fillers and pigments are used only for fine paper products, such as printing (magazine) paper, writing paper, labels, etc. Costs prohibit its use in paper whose application does not warrant high brightness and opacity, such as newspaper, cardboard, paper bags, etc. Most paper which is used in food packaging applications would fall into this second lower grade category. There is no need to load this paper that comes into direct c o n t a c t w i t h food w i t h h i g h b r i g h t n e s s .f i l l e r s a n d p i g m e n t s , because it is rare that this paper is ever used for outside labeling. However, this lower grade paper (lower grade so far as brightness and ink receptivity are concerned) is generally then wrapped with a bright, high grade paper, which is then suitable for labeling and attractiveness. Therefore, papers that are loaded with high concentrations of high brightness pigments and fillers are used only indirectly so far as food w r a p p i n g applic tions are concerned. This type of p a per is n o r m a l l y n o t u: on ;n a d i r e c t f o o d - c o n t a c t basis. A s a r e s u l t CRMC-MAD-000814 of all of our research efforts and investigations, we have bee", u n a b l e to l o c a t e f o o d p a c k a g i n g p a p e r c o n t a i n i n g m o r e than 1.5% talc. Such paper was utilized in the scuffing and salt shipping tests reported in Exhibits I and II of our December 21, 1973 submission. The salt shipping tests which were repeated with highly loaded talc paper, utilized the identical test procedure employed in the tests d e s c r i b e d in o u r D e c e m b e r 21, 1973 submission. The results reported in Table 1 below were obtained by employing the TEM at 11,000X. The proposed FDA criteria for identifying a s b e s t o s f i b e r s (as p u b l i s h e d in t h e F e d e r a l R e g i s t e r o n September 28, 1973) was employed. Table 1 Examination of Shipped Test Sample Residues By Transmission Electron Microscopy - Plain Uncoated Paper Sample No. Percent Talc in Paper 11,000X TEM Plate No. Chrysotile Tremolite 4385-78-7 9 4385-78-10 14 2282A B C D E 2283A B C D E 0 0 0 0 0 0 1 Bundle * 0 1 0 M long 1 Fiber * 0 10 long 0 0 0 0 0 0 0 0 0 0 4385-78-12 20 2284A B C D E 0 0 0 0 0 0 0 0 0 0 T a b l e 2, f o l l o w i n g , r e p o r t s s h i p p i n g t e s t r e s u l t s u s i n g t h e same papers, after they were coated with a thin film of Flexbond 811 p r i o r to testing. As i ndicated in our April 20 and D e c e m b e r 21, 1973 submissions, paper food containers are normally either lined on the inside with plastic (such as polyethylene) or coated with a thin f i l m o f w a x o r p l a s t i c . T h i s is d o n e for two re a s o n s : (1) to h e l p k e e p the f o o d fresh, a n d (2) t o p r e v e n t t h e p a p e r f r o m ooo a b s o r b i n g m o i s ire, oils, t a s t e a n d f r a g r a n c e f r o m the food. o Because this i> a -eal situation, we decided to simulate this t y p e o f conta: aor tt. eo if it w a s p o s s i b l e for the s a l t to 6 a b r a i d throug. 'v ' .ng, thus e x p o s i n g the p a p e r to the food. s T h e F l e x b o n d ,*. e m p l o y e d in this t e s t w a s a p o l y v i n y l a c e t a t e co-polymer. ` Most likely due to contamination, as bundles of not found in Johns-Manville's -1 4 - Table 2 Examination of Shipped Test Sample Residues by TEM Papers Coated with Flexbond 811 Sample No. Percent Talc in Paper 8 ,000X TEM Plate No. Chrysotile Tremolite Salt Blank 2293A B C 0 0 0 0 0 0 4385-78-7F 9 2290A B C 0 0 0 0 0 0 4385-78-10F 14 2291A B C 0 0 0 0 0 0 4385-78-12F 20 2292A B C 0 0 0 0 0 0 CONCLUSIONS: 1. T h e r e s u l t s r e p o r t e d in T a b l e s 1 a n d 2 c l e a r l y i n d i c a t e that even the most severe of actual shipping and handling conditions are not severe enough to cause distruction of food packaging paper. Since the paper is not degraded, there is no migration of tremolite fibers. 2. Th e a b o v e c o n c l u s i o n is s u p p o r t e d b y s h i p p i n g t e s t r e s u l t s on test papers that had as little as 0.25% tremolitic talc to as much as 20% tremolitic talc. 3. T h e r e s u l t s a l s o i n d i c a t e t h a t the m i g r a t i o n o f p a p e r a d d i t i v e s , such as tremolitic t a l c , depends on the strength of the paper and not the amount of additives that are contained in the paper. Since we have determined that the paper itself must be physically degraded in order for migration to occur, and since we have found that actual shipping and:handling conditions are not severe enough to cause commercial paper to degrade, the fact remains that regardless of the quantity of tremolitic talc which commercial food packaging paper may contain, there should be no fear of tremolite migf tion and contamination. The conditions are simply not present tc c a ^ e such an occurrence. To visibly demonstrate this c o n c l u s i n, w o . vo a t t a c h e d SF.M p h o t o g r a p h s d i s p l a y i n g the s u r f a c e o f on -c *'* sst p a p e r s (14% t a l c b y w e i g h t ) . F i g u r e 12 CRMC-MAD-000816 attached, is a picture of the surface of the paper before going through tho shipping test. Figure 13, attached, is a picture of the Surface of the paper after testing. Both pictures are virtually identical and indicate that the paper obviously was not degraded. Q U E S T I O N 10 WHAT ARE THE EFFECTS OF ASHING TREMOLITE AND CHRYSOTILE? WHAT HAPPENS WHEN PAPER CONTAINING TALC, TREMOLITE AND CHRYSOTILE IS INCINERATED? When any sample containing tremolite or chrysotile is ashed, the purpose is to eliminate any carbonaceous material which might mask the sample and hinder its examination. However, in order not to affect the tremolite or chrysotile, a temperature is selected which is a safe distance below that which would alter the lattice crystals. For our own analytical preparations, we use 800OF. In an oxygen rich atmosphere, this temperature is sufficient to oxidize the carbon which may be present in the form of cellulose or any other organic materials. However, this temperature is well below that which would affect the asbestos. Chrysotile will remain unaffected until 1382F and tremolite will withstand temperatures to 1796F. At these respective temperatures, the minerals will lose their bound water and the crystal lattices would collapse. QUESTION 11 EXPLAIN THE HIGH TALC CONTENT IN THE SALT BLANK AND REPEAT THE TEST RESULTS. When we initally began our test program to study the possible migration of tremolite from tremolitic-talc containing paper, laboratory work was performed in an area which also houses many talc-related testing equipment. Therefore, it is very likely that the first few test results (artificial scuff test results) were artifically high in talc,content due to airborne contamination. When the first salt blank was reported to contain approximately 8,000 talc platelets in its residue, the laboratory work was immediately moved to an area which would be less likely to contain airborne contamination. Future salt blanks showed a decrease in talc content down to ranges of 700 to 1000 platelets per membrane. In an effort to further decrease this level, modifications were designed into the testing procedure to reduce as much as possible the open-air time exposure of all test components. This last measure reduced the backgrourd count to less t h a n 50C . very fact that we could not completely CRMC-MAD-000817 e liminate the talc b a c k g r o u n d i n d i c a t e s that, T E M eva l u a t i o n s of actual test samples may have detected talc platelets which did not come from migration. However, since ou r December.' 21, 1973 submission, time has permitted the set-up of a " c l e a n room", in which the background count of airborne contamination is essentially zero. The test results reported i n , r e s p o n s e to Question. 9 .herein, w e r e obtained from samples which- w e r e completely'prepared for microscopy in this "clean room". CRMC-MAD-000818 5/31 Johns-Manville internal Correspondence To: From: Copies: M. Harris - 2S2 [y: / D a tjji D. . M illie r - 4N3 Paul Kotin, M.D. - 4 N 2 ^ ^ J. M. Fletcher - 2S3 A. T. Stroebel - 2S3 J. Goldfield - 4N4 F. E. Brandt - 4N4 File h Chrono SubjSC: LOS ANGELES TALC PLANT C50-7261 This is in reply to your request for an estimate of the cost to provide a ll necessary equipment at the L. A. Talc niant to reduce dust exposure in total plant to be level of 2F/CG. Estimated Costs 1. Dust Control Packers 2. Dust Control - Unloadinq, Crushinq Transfer & Storaoe 3. Vacuum Cleaninq System 4. Uoorade Existinq F a c ilit ie s TOTAL (Indluces Continqencies K Enqineerinq) $ 97,600 159,300 18,000 38,000 $312,900 NOTES: No escalation in above^timate. No noise control included. A ll work by outside contractor Estimated completion time 6-8 months. * l have advised P. Kotin that i f th is money is approved and a Type "D" assignment placed on Environmental Enqineerinq, we would sta rt immediately and issue monthly, or more frequent, status reports on job proqress. D. E. M illie r ' Y'I. CRMC-MAD-000819 Johns-Manville MAR 2 5 1976 Internal Correspondence . W. B. Reit20 - R. K. Comann - 2S Kotin, M. D. - 4N J . M . Fletcher - 2S Dntf: March 22, 1976 rt $ G. E. Parker - 5W L. Turner - L.A. Talc Subject- LOS ANGELES TALC PLANT RESPIRATOR AND HOUSEKEEPING PROGRAMS This will confirm the following action program taken at the L.A. Plant: 1. Respirator program has been established. Please refer to the attached letter dated March 12 from L. Turner. 2. Additional portable vacuum cleaners have boon obtained and will be used in place of brooms in the plant. Present small Hoffman cleaner also being Used all possible. 3. Daily and weekly spot checks on all shifts being made by either L. Turner or her designate to insure that all employees are wearing respirator masks. Written report being submitted each week to you and to DIIQ from Mrs. Turner confirming that this is being done. Strict dis ciplinary action being taken on any violations. 4. Daily and weekly housekeeping inspections being made by L. Turner and staff with results and corrective action discussed at weekly staff meetings. 5. Additional warning signs have been installed per your recommendations. I feel confident that L. Turner is doing all possible to com ply with instructions from Dr. Kotin and from you. During my visit last week, I found the housekeeping much .improved with all employees and visitors wearing masks. We certainly appreciate the assistance and recommendations you and Dr. Kotin have given Loretta. If you have any further recommendations that should be done at this time, please let Loretta or me know. / R. K. Comann CRMC-MAD-000820 Johns-Manville Internal Correspondence r,, R. K. C o m a n n - 2S frorn L. Turner - L.A. Ta]c Copto* Sub,ret R E S P I R A T O R PROGIW-1 OMn March 12, 1976 An established program for cleaning and inspection of employee respirators at the L.A. Talc plant has been completed. The guildlines as outlined by Dr. Paul Kotin were the basis for the following procedures. 1) A cabinet has been purchased and installed in the Abrasion Room for individual respirators. A bin has been labeled and assigned to each individual employee. 2) Daily a clean respirator, sealed in a plastic bag, will be placed in each individual bin by supervisory personnel. 3) No employee will be permitted to enter the plant area, at the beginning of his shift, without obtaining his clean respirator from the respirator cabinet. 4) 2 respirators, labeled with the employees initials, has been issued per person. W. Reitze concurred in the issuance of the two respirators per person, and a new set of 30 was purchased. 5) A daily and weekly respirator cleanup program has been established to be completed by supervisory personnel. 6) Daily Procedure: (a) Plastic container, marked "Dirty Respirators" has been placed on top of respirator cabinet. Each shift leader will be responsible for depositing the dirty respirators for each member of his crew, at the end of the shift. (b) Supervisory personnel will collect dirty respirators once per day - wash, sanitize, change filters and replace in sealed plastic bag. (c) Each morning cleaned respirators will be replaced in proper employee bins. 7) Weekly Procedure: (a) J. Boyer, Quality Control Technician, will check each respirator for de fective parts. (b) Replacement of worn parts will be made and a written report ccrpleted show ing - Date of Inspection - Parts Replaced. L. Turner Acting Plant Manager CRMC-MAD-000821 PJoroldnuric-MtsoCnvoirlplcoration .'^OS Ml'.^.1'-.Ilno.-trj I re, A o 'j.-lf"-,. C .'ilif fiOO?3 01.1) Wl. 411/ l-V.r.,ih 12, 1976 uarice 'io a m , empiovi-.i-'S A now to;pirntor program is now in offeet. Listed below are the new rules and pi.ocexlures each employee w.i.ll follow: #1. All hourly enployees are assigned 2 respirators w.i.Hi their: .initials marked on each respirator. 12. At the sl.ni t of your shift/ each employee will obtain their clean ros pi od or fto:n r;lot nvnlcxl with their name in the tespi rnfor cubi.net, (hi-uir-d in 1].;valley abrasion room). Put empty plastic logs in bux irnl.ixl "Plastic hays". #3. At ilio end of your shift, each employee will turn in his dirty respir ator 'IO HJS CREW LEADER. i`4. The crow leader in r;lmrgQ will lje responsible to see that all employee's respirators on his shift: ore deposited in the plastic pail marked "Dirty Respirators" at the end of hirt shift. H5. All employee's respirators will be cleaned and filters re-placed on a daily basis by; the cavpany. Each v:cck an inspection will l:c nvado of all respirators and parts will Jo replaced as needed. if6. l'inp.1oyccs w.i.ll no longer need to contact Jolm Poyer, Quality Control Tech., for respirator parts or supplies. All employees are required to follow the afove rules and proceedurcs willout: fail. Any employee found neglecting these rules will be subject to disciplinary action. I). Turner Acting Plant Munger CRMC-MAD-000822 m Johns-Manville FEB 2 7 1976 Internal Correspondence J. FLETCHER Dat8: FEB. 26, 1976 W. B. REITZE Copies: p> KOTIN, MD; R. K. COMANN Subject: VACUUM SYSTEM AT KENT COMANN*S REQUEST, I CALLED LORETTA TURNER AT THE L .A . TALC PLANT AND DISCUSSED WITH HER IN QUITE SOME DETAIL THE RESPIRATORY PROTECTION PROGRAM. IN OUR CONVERSATION REGARDING GENERAL HOUSEKEEPING, THE USE OF BROOMS WAS MENTIONED. I INFORMED HER THAT THE USE OF BROOMS FOR SWEEPING ASBESTOS DUST WAS POOR HOUSEKEEPING PRACTICE AND DUST SHOULD BE VACUUMED UP. LORETTA INFORMED ME THAT THERE IS A RATHER NEW VACUUM SYSTEM WHICH HAS BEEN DIS ASSEMBLED AND IS CURRENTLY LAYING AT THE DUNN PLANT. SHE ALSO INFORMS ME THAT THERE IS NO MONEY AVAILABLE TO MOVE THIS VACUUM SYSTEM TO THE L .A. OPERATION. I WOULD LIKE TO STRONGLY URGE THAT MONEY BE MADE AVAILABLE FOR THE MOVE AND INSTALLATION OF THIS VACUUM SYSTEM FROM THE CLOSED DUNN OPERATION TO L .A. BOTH DR. KOTIN AND I FEEL THAT WE ARE BEING JUST A BIT UNREASONABLE IN TELLING LORETTA TURNER THAT SHE MUST MAINTAIN GOOD HOUSEKEEPING PRACTICES AND THEN NOT GIVING HER THE TOOLS TO WORK WITH. IF YOU SHOULD NEED ANY ASSISTANCE FROM EITHER DR. KOTIN OR MYSELF IN SECURING THE NECESSARY FUNDS, PLEASE DO NOT HESITATE TO CONTACT US. W. B. REITZE CRMC-MAD-000823 m CONFIDEN Johns-Manville T I A L Internal Correspondence To: Kotin, M.D. - 4N From: j. M. F l e t c h e r - 2 S Copies: F i l e & c Date: Feb. 19, 1976 Subject: LOS A N G E L E S P L A N T We appreciated your visit and your advice to both Mrs. Loretta Turner and Kent Comann. vou will appreciate that the whole Western Talc situation has been a very traumatic experience. We now believe that we have a handle on markets, optimum production output, best mine contractor prices, and environmental engineering situation. Th e w h o l e L .A. p i c t u r e d e p e n d s o n w h e t h e r t h e m a r k e t s will hold with the prices necessary to make the operation profitable. Assuming that the results will be positive, we have specific steps planned to turn this whoie operation around into a proper on-going contributing situation. Recognizing that we only have five salary people who now know what they must do, our present priority is simply to buy a little time. Other than giving us the assistance and direction of Bill Reitze (which we will follow to the letter), we would ask for nothing further until your next visit in April. At that time we will know whether we can go forward or be plowed under. You and I both realize that none of the original appropriation environmental steps were taken, even though $1.5 million was allotted in the purchase appropriation. We also both know that because of the history since acquisition, everybody would like to see it off the books. I just don't feel that it has ever had a fair chance with either operating or engineering know-how, nor with required expenditures. Together with John Swensen, we want to give it one last try and believe that nothing further can assist other than having a little time to prove out one way or the other. CRMC-MAD-000824 ' ' M l johns-Manviiie Internal Correspondence To' j,. FLETCHER j Date: JAN. 9, 19 75 Frnm: w ., B. REITZE Cf C()pM*S p . KOTIN, Miyf^T. STROEBEL I Subject: L .A . TALC IN LINE WITH OUR CONVERSATION, BELOW IS OUTLINED A SURVEILLANCE ! P R O G R A M TO ENSURE THE PROTECTION OF OUR L .A . TALC EMPLOYEES. WF UNDERSTAND THAT THIS IS AN INTERIM SITUATION AND THAT THE NECESSARY A.R. WILL BE APPROVED BY MAY 1, 1976, AND SHORTLY THEREAFTER WORK WILL BEGIN TO CORRECT THE SERIOUS ENVIRON MENTAL PROBLEMS AT L .A . TALC. THE SURVEILLANCE PROGRAM SHOULD CONSIST OF AT LEAST ONE UN- $ ANNOUNCED INSPECTION PER WEEK PER SHIFT. A REPORT SHOULD BE ISSUED AND CERTIFIED BY THE INSPECTOR LISTING NAMES, EMPLOYEE 5 NUMBERS, WORK STATIONS, TIME, ETC. IN ALL CASES WHERE AN | EMPLOYEE IS NOT WEARING A RESPIRATORY PROTECTIVE DEVICE. J AS YOU KNOW, INTERIM MEASURES SUCH AS THE WEARING OF RESPIRA- - TORY PROTECTIVE DEVICES OFFER A POOR SUBSTITUTE IN THE PRO TECTION OF WORKERS SIMPLY BECAUSE THE WORKER HIMSELF IN MANY CASES WILL SHORT-CIRCUIT THE BEST INTENDED EFFORTS ON THE PART OF MANAGEMENT TO PROTECT HIM. L5 MO ADDITIONAL INDUSTRIAL HYGIENE SURVEYS WILL BE NECESSARY SINCE NO CHANGES HAVE BEEN MADE IN AMY OF THE DUST COLLECTION EQUIPMENT. WE WILL CONTINUE TO MONITOR THE INDUSTRIAL HYGIENE ASPECTS ON A REGULAR BASIS FROM OUR OWN SHOP. WE ARE NOT REALLY CONCERNED WITH WHETHER THIS IS DONE BY SOMEONE APPOINTED FROM YOUR SHOP OR WHETHER WE SEEK AN OUT SIDE INSPECTOR TO DO THIS WORK. WE ARE, HOWEVER, VERY S E R I O U S IN OUR ATTEMPTS TO RECEIVE AN ACCURATE PICTURE OF THE S I T U A T I O N IN THE PLANT. IN ANY EVENT, WHETHER THE I N S P E C T I O N IS DONE INTERNALLY OR EXTERNALLY, WE WILL MAKE PERIODIC SURPRISE VISITS FROM OUR OWN DEPARTMENT. I HAVE C H E C K E D WITH DR. KOTIN, AND HE HAS NO SPECIFIC NAMES OF FIRMS TO RECOMMEND. PERHAPS THOSE ENGINEERING FIRMS THAT YOU HAVE BEEN DEALING WITH MIGHT PROVIDE A SUITABLE INSPECTOR. HOWEVER, IN LIGHT OF YOUR PLANS TO PLACE ADDITIONAL SUPER VISION IN THIS PLANT, PERHAPS THIS PERSON WOULD BE WELL SUITED TO PERFORM THIS DUTY. CRMC-MAD-000825 JIM, I CONCUR WITH YOUR THOUGHTS. C O SINCE WE HAVE PURCHASED THE L .A . TALC OPERATION, NO SUBSTANTIAL CHANGES HAVE BEEN MADE ON THE ENVIRONMENTAL CONDITIONS AT THE LOCATION (THIS, IN SPITE OF THE FACT THAT MONEY WAS ORIGINALLY APPROPRIATED IN l| J. FLETCHER JAN. 9, 1975 PAGE 2 THE INITIAL PURCHASE PRICE TO DO THIS.) (2) ENOUGH TECH NOLOGY IS CURRENTLY AVAILABLE ON THE SHELF TO AT LEAST RE DUCE THE FIBER LEVELS TO THE 2 F/CC LEVEL. I BELIEVE THAT SUFFICIENT TIME HAS BEEN ALLOWED IN THE PAST AND INCLUDING THE FIRST FOUR MONTHS OF 1976 TO MAKE AN ECONOMIC REVIEW AND SOME DECISIONS. IF THIS SITUATION CANNOT BE RESOLVED WITH A SIGNED A .R . AND A FIRM DATE FOR THE CONSTRUCTION START, THEN I MOST CERTAINLY WOULD URGE THAT THIS SUBSTANDARD OPERATION BE SHUT DOWN ONCE AND FOR ALL. W. B. REITZE '1, CRMC-MAD-000826 m Joh n s-M an ville To: R . K. COMANN From- w . B. REITZE Copies: p . KOTIN, MD ^ Subject: TALC OPERATIONS In te r n a l C o r r e s p o n d e n c e J Dnle; DEC. 22 , 1975 I RECEIVED YOUR MEMO CONCERNING THE CHANGES OF PLANS FOR THE TALC OPERATIONS AND YOUR INTENTIONS TO PROCEED WITH THE NEEDED ENVIRONMENTAL CONTROLS FOR THE LOS ANGELES PLANT AND THE SHUT-DOWN OF THE DUNN OPERATION. AS SOON AS YOU ARRIVE AT ANY DEFINITE PLANS, SUCH AS: WAS AN A .R . SIGNED, WHAT THE BEGINNING DATE FOR ACTUAL C O N STRUCTION TO START, AND WHAT THE ESTIMATED COMPLETION DATE IS FOR INSTALLATION OF ENVIRONMENTAL CONTROLS, COULD YOU PLEASE ADVISE. COULD YOU ALSO PLEASE SEND A COPY OF THE SIGNED A .R . PLEASE ADVISE BY THE 15TH OF JANUARY SO THAT WE MAY REVISE OUR MONITORING SCHEDULE IF THIS SHOULD BE NEEDED. IN THE EVENT THAT THE DECISIONS HAVE NOT BEEN REACHED BY THIS TIME, COULD YOU PLEASE GIVE US AN IDEA OF WHEN A DECISION MAY BE REACHED. W. B. REITZE CRMC-MAD-000S27 Joh n s-M an ville In te r n a l C o r r e s p o n d e n c e To: W. B. Reitzo - 4N D.ito; November 19 From: K. K. Comann - 2S Copies: M. Harris - 4W, LU. Kotin . M. D . - 4N, J. M. Fletcher - 2S L . I I . i a L h "~ L . A * , F & C Subicct. LOS ANGELES TALC PLANT RE: YOUR LETTER DATED NOVEMBER 14, 1975 Upon receipt of your letter I immediately called Dan Tash, our L. A. Plant Manager, and read your letter over the telephone. I expressed my concern and asked Dan to check into this situation at once and to advise me. I have just received the following wire from Mr. Tash: "In answer to Bill Reitze letter of 11/14/75 regarding his visit 11/13/75, I would like to let you know that I questioned the maintenance men involved and they all say that they had taken their respirators off to discuss the job they were doing. They were in the process of installing the 150 HP motor on VM2 moved from Dunn. This is a heavy motor and installation does required good coordination. On the part of the maintenance men, I would like to mention that I talked to Larry Schriver and he said he noticed during his recent survey that the maintenance men were very good in wearing their respirators. Larry Schriver did say that he thought some areas of the plant such as warehouse, shop and loading dock were below TLV but would not verify this until he has finished dust counts on samples taken during his survey. Until any given areas in the plant can be confirmed as b e l ow TLV, it has been made mandatory that all men wear respirators when in the plant buildings and ear plugs when working in designated noise areas. This means respirators must be worn by anyone visiting or working in the plant. Personnel found not complying with these rules can be terminated without further warning." D. B. Tash Until a decision is made on whether or not we are going to spend the necessary funds to bring the L. A. Plant into E. C. r eq uir eme nt s, every effort will be made by the Plant Manager to see that the plant housekeeping is as good as possible and that all employees wear protective devices as required in those areas above the TLV. We should point out that the present salaried supervisory staff at L. A. consists of the Plant CRMC-MAD-000828 W . 13. Re i tze - 4N November 19, 1975 Page 2 Manager only. The plant is operating 3 shifts, 5-7 days per week with.only hourly Leadmen as "supervisors". We expect to reach a decision around the first of the year as to the future course of our West Coast Talc operations. At that time funds must be committed and additions made to our L. A. Plant staff in order to operate the plant properly on a long-term basis. We will keep you advised. recent visit. Thanks for your comments on your CRMC-MAD-000829 I/S l Johns-Manville Internal Correspondence To: R. K. COMANN Dale: N O V . W t , 1975 From W. B. REITZE C ipics P. KOTIN, MC^TM . HARRIS; J. FLETCHER Subject VISIT TO L .A . TALC PLANT ON NOVEMBER 13, WHILE ON OTHER BUSINESS I DROPPED BY THE LOS ANGELES TALC PLANT J. B. FANNING ACCOMPANIED ME. IN LOS ANGELES, FOR A VISIT. THE HOUSEKEEPING WAS SOMEWHAT IMPROVED SINCE MY LAST VISIT. THE SWEEPER WAS IN ACTION AND THE FLOORS AND YARDS LOOKED SOMEWHAT BETTER THAN IN THE PAST. WHILE THERE, I OBSERVED THE EMPLOYEES AND WHETHER THEY WERE WEARING THE REQUIRED RESPIRATORY AND HEARING PRO TECTION. TWO MEN (SWEEPER DRIVER AND PV CLAY PACKER) WERE WEARING THEIR RESPIRATORS. THE 4-MAN MAINTENANCE CREW, HOWEVER, WERE NOT WEARING RESPIRATORS. AS SOON AS WE APPROACHED THEM, THEY IMMEDIATELY PULLED THEIR RESPIRA TORS FROM AROUND THEIR NECKS AND PLACED THEM OVER THEIR MOUTHS AND NOSES. WHEN WE TURNED OUR BACKS TO LOOK AT OTHER AREAS OF THE PLANT, THEY PULLED THE RESPIRATORS OFF AND DID NOT PUT THEM BACK ON UNTIL WE REAPPEARED. I MENTIONED THIS TO DAN TASH AND ATTEMPTED TO IMPRESS UPON HIM THE IMPORTANCE OF WEARING RESPIRATORY PROTECTIVE DEVICES. I MUST AGREE THAT THE WEARING OF RESPIRATORY PROTECTIVE DEVICES IN HOT, HUMID WEATHER WHEN PERFORMING STRENUOUS WORK IS EXTREMELY UNCOMFORTABLE; BUT NONE OF THIS ALTERS THE FACT THAT ENVIRONMENTAL CONDITIONS ARE SO POOR THAT PROTECTIVE DEVICES MUST BE WORN. IF IT IS DIFFICULT TO ENFORCE THE WEARING OF RESPIRATORY PROTECTIVE DEVICES DURING DAYTIME SHIFTS, I CAN ONLY SURMISE WHAT COMPLIANCE MUST BE LIKE ON THE TWO OFF-SHIFTS. IF IT CAN BE DETERMINED IN THE NEXT FEW MONTHS FROM BOTH DAN TASH'S WEEKLY REPORTS AND OUR UNSCHEDULED VISITS THAT THE RESPIRATORY PROTECTIVE DEVICE REQUIREMENT IS NOT BEING COMPLIED WITH, I BELIEVE WE MUST VERY SERIOUSLY CONSIDER SHUTTING DOWN THE TALC OPERATIONS IN LOS ANGELES. MORALLY, WE CANNOT CONTINUE TO INJURE THE HEALTH OF OUR WORKERS; AND LEGALLY, WE CANNOT CONTINUE TO WILLFULLY DISREGARD FEDERAL AND STATE REGULATIONS. ASIDE FROM THE MORAL CRMC-MAD-000830 R. K. COMANN NOVEMBER 1+, PAGE 2 1975 ASPECTS, BOTH THE STATE AND FEDERAL GOVERNMENTS HAVE VERY SEVERE PENALTIES, INCLUDING JAIL SENTENCES FOR THOSE WHO WILLFULLY DISREGARD REGULATIONS. PLEASE KEEP ME INFORMED OF YOUR PROGRESS. 1 W. B. REITZE CRMC-MAD-000831 J. M. FLETCHER, 2-SOUTH PAUL KOTIN, H.O.,4-NORTB M. HARKIS, 4-WEST W. VANDERBEEE, 2-SOUTS REOPENING OP L.A. PLANT OCTOBER 29, 1975 CONFIDENTIAL YOUR MEMO OF OCTOBER 23 CLEARLY ILLUSTRATES THE DILEMMA FACING J-M. WHILE THE ECONOMIC ASPECTS OF TEH TALC OPERATION C A M W T BE EXCLOTED IN AMY DELIBERATIONS RELATINO TO HEALTH, SAFETY AND ENVIRONMENT IT IS IMPERATIVE THAT WE TAXE ALL NECESSARY ACTIONS TO ENSURE EMPLOYEE PROTECTION. OUR POSITION ON THE 1E0PENZ8G OP THE LOS ANGELES P^AKT DEPENDS UPON THE MAINTENANCE Ot' A HAZARD-FREE ENVIRONMENT. TOlASSURR OURSELVES OF THIS WE PLAN TO, (1) iREVZBM OR EMPLOYEE USE';OF RESPIRATORS; .( 2 ) ? s | ^ ^ i C X f l ^ > P i t ^ ( t F M i i * KEEPING AND SURVEY THE USE OFRKSPIRTORS ON UNANNOUNCED VISITS; AND (3) KA1X UNANNOUNCED INDUSTRIAL HYGIENE MEASUREMENTS TO DEI tlM I. THE EFFECTIVENESS OTHOUSEKERPINC, OUR CONCERN OVER THE J-K TALC OPERATION EXTENDS TO PENBORWOOD, AND WE ARE ANXIOUSLY AWAITING THEENGINEERING REPORTFROM D. HUAlit'S GROUP. CRMC-MAD-000832 V. Johns-Manville To: Kotin, M.D. From: J. M. Fletcher - 2S Copies: Drt#: Oct. 23, 1975 Subject: REOPENING OF L . . PLANT AND COMPLETE WESTERN TALC SITUATION T can well appreciate your disappointment at once again o o e r a t i n c r t h i s facility. T would like to add a few comments. I am equally distressed a t t h e complete situation. There are so many areas of endeavor which should be receiving attention and yet our efforts are continually diluted in trying to find a solution for Western Talc. It has been reviewed and analyzed in detail. We has to be done to make it a proper operation but forecasts and product prices just do not permit. carryinq charges are horrendous. know what the sales The Attached is the latest list of alternatives prepared by Kent Comann. We are pushing Penhorwood as fast as we can. In the interim, we have been asked to supply the existing small Western Talc markets in order to maintain a marketing position. The product split is such that we cannot do it from only one location, even though total capacity is considerably under-utilized.I I can only assure you that one of my personal objectives is to get out from under this impossible and intolerable situation at the earliest date. A ttach . CRMC-MAD-000833 J o h n s - Manville ' Mi Internal Correspondence To: R. s . L a mar - 2W D.it October 20, 1975 From. R. K . C o m a n n - 2S Copies: Subject: ,J._ M .__Fp e t cilex , - 23, J. 11. Swenson - 2W, iff R. Keefe - 2W, C . I . Ke .Ian -* 2W, F L PUS Sli3LE PLANS - W E S T COAS 1976 CONTRACT PLAN P . Simpson - 2S, At our joint F i, M and Mining Division mooting on the 1976 Contract Plan held October 7, it was decided to present possible divestment plans as a part of our 1976 program. I was rogues ted to prepare various alternative possibilities and, after review by you, then our Division Controller could put down some numbers as to the effect on 1976 earnings with the various alternatives. briefly, here are the major alternatives as I sec them for Western Talc in 1976: 1. Divest entire operation. Assume a selling price of say $2,000,000 to maximum of '$4,000,000 after Penhorwood comes on stream. (Still awaiting word from Cyp ru s-- two other prospects turned us down.) 2. Divest Dunn Plant only when Penhorwood comes on stream. Retain Warm Springs and L. A. Plant. A. Assume selling price of Dunn at say $200,000. D. Assume L. A. can produce 45,000 tons/yr. - all products (15,000 tons fine grind). C. Assume cost to fix up L. A. and Warm Springs for EC standards. Alpine production at L. A., bulk loading at L. A., underground mining at Warm Springs, etc. at $400,000 - $500,000. 3. Divest L. A. Plant only when Penhorwood comes on stream. Retain Warm Springs and Dunn Plant. A . Assume selling price of L. A. only at $750,000. U. Assume Dunn can produce 35,000 tons/yr. (7200 tons fine grind-with 3 vertical mill). C. Assume cost to fix up Dunn and Warm Springs for EC standards, yard paving, warehouse, improve Dunn's efficiency, underground mining at Warm Springs, etc. at $500,000 -- $600,000. CRMc -MAD-000834 R. F . Tinnar - ?.W October 20, 1975 Page 2 4. Tf no buyers can be found by the time Penhrowood is in production, then close down entire operation, noli plant equipment to used machinery dealers, or hold for possible future use within J-M at another location. 5. Another possibility that could be raised is to continue to operate Dunn and/or I,.A. after Penhorwood is .in operation witho ut spending anv major funds for improvements or P.C work and to utilize all possible rcadilv accessible c^o at Warm Springs without major expenditures for resuming underground work. Wo could probably drag out such a plan uurinq 197 G. 'However, I would not recommend such a plan owing to the following considerations. A. We have delayed long enough to fix up our talc plants as far as PC work and other improvements are concerned This is understandable and acceptable until Penhorwood comes on stream, but I would not recommend continuing such an operation after Penhorwood is in operation. P. Present talc plant salaried organization is not ndcuuato to continue operations longer than the Penhorwood start-up. If we are to continue West Coast Talc operations after that, then T would want to make some major changes and improvements in the talc nlants' salaried oraanization. We are shorthanded now to adcguatelv staff two talc nlants but we will do the best we can until Penhorwood is in operation. We should keen in mind that our present salaried staff and probably the hourly personnel arc generally aware of the fact that we may qet rid of one or both of our plants. Naturally, this creates some morale problems. In summary, if we keen operating after Penhorwood, wo should spend considerable money to fix up our plants so that they can be clean, dust free, well run efficient operations with 'a strong and adequate staff having a degree of permanency. 6. The Federal government could possibly shut down all mining in Death Valley if .the pending bill is passed declaring a 3-yenr moratorium on all surface mining and surface disturbances in the Valley. If you need further information, plea s e let me know. CRMC-MAD-000835 R. K. Comann J o h n s-M a n v ille In te r n a l C o r r e s p o n d e n c e To: From: Copie: Subject: D. B. Tash - L. A. Talc D. E. Deem - Dunn Date: October 22, 1975 R. K. Comann - 2S // M. Harris - 4W, J. M. Fletcher - 2 S , E*. Kotin, M.D. - 4N, W. B. Reitze - 4N, F & C DUST PROBLEMS Per my previous discussions and letters, all of your employees are to wear respiratory protection when working in or around the plant where the dust is above the TLV. On October 7, d . b . Tash confirmed that this is b e in g done at both locations and that signs have been posted to this effect. Employees not following these instructions will be terminated after proper warning and layoff. To insure that these procedures are being followed, I will need from each of you a weekly report certifying over your signature that the employees are wearing the proper protective device. This report should show the name of each employee and his normal work area. This report need not take but a few minutes of your time each week to review and sign, but it will give us the insurance we must have that every employee is wearing the proper protective devices at all times. This reporting procedure will continue until further notice. Please start with receipt of my letter. Mail your report on Friday of each week directly to me. CRMC-MAD-000836 U, c o m m , 28 P, KOI'IK, M.D, ,*N If. B. RETZE; M. HARRIS, AN; J. FLETCHER, 28 File KJrENUK or L.A. TALC PLANT OCTOBER 16, 1975 t at VERY DISTRESSED THAT WE WERE NOT CONSULTED BEFORE THE DECISION WAS MADE TO REOPEN THE L.A. TALC FACILITY. WE ARE ALL AWARE OF THE TOTALLY UNSATISFACTORY CONDITIONS THAT PREVAIL AT THE PLANT AND THAT THE LEVELS OF ASBESTOS FIBER (TRBMOLITB) IN THE ENV^OHNXNTAL WORK PLACE EXCEED RECOMMENDED TLV*S BY, IN SOME CASES, A MACNITUDE OF 10 TIMES SINCE WORKERS ASSIGNED TO THIS TWKTION MOST WEAR RESPIRATORY PRO TECTIVE DEVICES, I AM SUPPLEMENTING W. B. REITEE'S MMD OF OCTOBER 7, 1975, TO YOU AND ASKING THAT A WEEKLY REPORT BE COMPLETED BY THE PLANT MANAGER CERTIFYING THAT EACH EMPLOYEE IS B S p f M t N I S H I D WITH RESPIRATORY PROTECTION AND THAT THE PROTECTIVE BEING WORN. THE WEEKLY REPORT SHOULD CONTAIN THE NAME OY HE tNDIVIDUt EMPLOYEE AND HIS WORK STATION. THE8E REPORTS SHOULD CONTINUE UNTIL THE OPERATION IS ONCE AGAIN PHASED OUT. CRMC-MAD-000837 m jo h n s-M an v iiie In te r n a l C o r r e s p o n d e n c e To: K . COMMAN .-- " Date: OCTOBER 7, 1975 From: W. B. REITZE Copies: P . KOTIN, i/MD; J. FLETCHER Subject. REOPENING OF LOS ANGELES TALC ENVIRONMENTAL CONDITIONS AT ALL THREE TALC LOCATIONS THIS WILL CONFIRM OUR RECENT CONVERSATION ENVIRONMENTAL CONDITIONS AT DUNN AND WARM STATEMENT THAT THE LOS ANGELES TALC PLANT THIS WEEK. REGARDING THE SPRINGS, AND YOUR WILL RE REOPENED SINCE I THINK WE ARE ALL AGREED THAT ENVIRONMENTAL CONDITIONS ARE EXTREMELY BAD AT ALL THREE LOCATIONS, I AM GOING TO REQUEST THAT ALL EMPLOYEES AT ALL THREE LOCATIONS BE EQUIPPED WITH RESPIRATORY PROTECTION AND THAT IT BE MADE MANDATORY ' THAT THIS RESPIRATORY.PROTECTION BE WORN AT ALL TIMES. I AGREE THAT IT IS IMPRACTICAL TO SPEND MONEY WHEN THE OPERATION WILL BE PHASED OUT SHORTLY. . HOWEVER, IN THE INTERVENING SIX, NINE OR TWELVE MONTHS, THE EMPLOYEES MUST BE AFFORDED SOME PROTECTION. IN YOUR NOTIFICATION TO THE LOCATIONS, REMIND THEM THAT IF THEY HAVE ANY QUESTIONS REGARDING TYPES OF RESPIRATORS TO BE USED, THEY ARE TO ugly CONTACT THIS OFFICE. W. B. REITZE CO u+i. CRMC-MAD-000838 \ 7 i johns-Manviiie ' ' Internal Correspondence To: w. B . Reitze - 4N Dato: October 6, 1975 From: Copies: Subject: u. K. Comann - 2S / / / 1/ M. Harris - 4W, P. Kotin,MD-4M, J . M. Fletcher - 2 S , J. H. Swensen - 2W , D. B. Tash - LA, D. E. Deem - Dunn, F & C L. A. AND DUNN TALC PLANTS Thru will, c o n f i r m my co nversation with you today in which I advise that, due to increased sales forecast for fine grind products, it has been decided to re-open the L.A. Plant for a temporary period. This temporary period along with the continued operation of the Dunn Plant will probably extend until the new Penhorwood Plant comes on stream around March or April, 1976, depending on sales volume. When Penhorwood is in production, then a decision will be made on the future operations of Dunn and/or L. A. Plants. At that time, necessary major expenditures will have to be provided if it is decided to keep the Dunn and/or L. A. Plants open. In the meantime, I have again instructed the local management of L. A. and Dunn Plants that respirators must be w o r n by all employees in areas over the TLV. If non-compliance, employees are to be terminated. R. K. Comann CRMC-MAD-000839 I f f i l Joh n s-M an ville i w u :: In te r n a l C o r r e s p o n d e n c e To, W. B. Reitze - 4N Date: August 18, 1975 R. K, Comann - 2S Subject W. L. VanDorbeek - 2S, M. Harris - 4W, J. M. Fletcher - 2S, J. li. Swensen - 2W, P. A. Martinson - 2W, P. Ko' ' , M.D. - 4 N , G. W. Wright, M.D. - 4N, F & C TALC PLANS - LOS ANGELES AND DUNN RE : YOUR LETTER AUGUST 5, 19 75 MY LETTER AUGUST 4, 1975 The plans are to close down the L. A. Plant entirely as far as production of Talc and PV clay are concerned as of August 31, 1975. We will ship from remaining finished goods inventory at L. A. until inventory is sold. Regarding Dunn, the Mining Division has made a divestment recommendation on Dunn and Warm Springs and we are now awaiting a review from the F & M Marketing Division. We expect a reply within a month or two, so that plans can be made accordingly. We will keep you advised . / R. K. Cornar 1 I CRMC-MAD-000840 m Johns-Manville Internal Correspondei&e To W. B. Reitze - Denver 4N Date: AugUSt 4, 1975 From: Copies. Subject: R. K. Comann - Denver 2S / P. Kotin, M.D. - 4N J. M. Fletcher - 2S PLANS FOR LOS ANGELES TALC PLANT RE: MY LETTER MAY 30, 1975 YOUR LETTER MAY 29, 1975 G. W. Wright, M.D. - 4N Chrono/File As a follow-up to my letter of May 30, it has been decided to shut down all Talc production at the Los Angeles plant as of August 31. Production during August is being curtailed with only around 12 employees working at L.A. The Dunn Plant is continuing in full operation, at least for the time being. A decision will be made shortly as to whether we will continue to operate Dunn and Warm Springs or divest. If it is decided to continue operations of the Dunn Plant, then major commitments will have to be made to bring this plant up to required E.C. standards. Also E.C. considerations would then be necessary for Warm Springs Mine when we go back under ground next year. I will continue to keep you advised. CRMC-M AD-000841 Johns-Manville J U N O ; 1 : 'J Internal Correspondence / J. W . b . Hui tzu - 4U Data: May 30 , 19 7 5 From R. K. Cornanti - 2S Copies: P. Kotin, M.D. - 4N, G. W. Wright, M.D. - 4M, J. M. Fletcher - 2S, F &C Subject: FUTUR!-; PLANS FOR L. A . TALC, DUNN AND WARM SPRINGS OPERATION RE: YOUR LETTER DATED MAY 29, 1975 At the present time we are having our Controller prepare a profit analysis of both Los Angeles and Dunn Plants to see which plant should continue to produce Talc products. This analysis should be completed by July 1. Shortly thereafter a decision will be made as to which plant will continue to produce Talc products. It is planned to operate only one plant on Talc and possibly utilize the other mill on grinding other industrial minerals such as Calcium Carbonate (Calcite) or Barite We will then request funds as soon as possible after July 1, to bring the one remaining Talc mill up to required environmental standards. The mill operating on other industrial minerals will be analyzed for environmental needs when the type of minerals and operating requirements are determined. As far as Warm Springs Mine is concerned, we plan to continue open-pit mining with an outside contract for the near term, up to perhaps a year. However, we are preparing a Mining Plan with the help of outside consultants that will very likely include going back underground, either in the old workings or perhaps a new area. One of the consultants we have contacted is a specialist in underground mining environmental control applications. We plan to discuss the situation with this person shortly and see how he can assist us in the environmental aspect of our Mining Plan. We expect to have our Mining Plan completed in July. if you have any further questions, or can offer any suggestions on improving our plans, please let me know. I will keep you advised as to our decision on the plans for our two mills and the mine. C R M C - M A D ' 000842 joiin s-M a n v iiie In te r n a ! C o r r e s p o n d e n c e FUTURE PLANS FOR L.A. TALC, D U N N , AND WARM SPRINGS OPERATIONS D r . George Wright has filled me in on your discussions relative to the future of the three locations mentioned above. Apparently at least at the time of his meeting with yon, no firm plans had been decided upon. A s you know, we are very much concerned about the health problems at all three of these locations, and I would like to request that you inform me by June 16 regarding what the specific plans will be * It is important for us to be aware of future activities at these locations in order that we may complete our own plans for health and environmental control maintenance. *> / W . B. Reitze CRMC-MAD-000843 l! Johns-Manville ' ' A T 7'' Internal Correspondei To: R. K. Cotnann - 45 0Me: January 15, 1975 From: W. B. Reitze - 4N Copies: Drs . P. KotirKsf G Subject: LOS ANGELES TALC This memo will serve two purposes: (1) to confirm our recent conversation, and (2) to discuss the latest industrial hygiene report. As I mentioned in our recent conversation, we are all aware o f the economic facts at Los Angeles Talc. The operation has been only marginally profitable, and a rather large sum of money is needed to remedy all of the environmental problems at the plant (1/2 to 1 million dollars). We also realize that to make a decision to spend this large sum of money on a marginally profitable operation is indeed a tough decision. But the fact still remains that workers are being exposed to levels of tremolitic talc far exceeding the Federal regu lations . It is our opinion that workers at the Talc plant are being subjected to considerable health risks. Therefore, steps have to be taken immediately to remove these employees from risk. We also discussed some of the temporary methods that you were putting into force immediately. The installation of a Hoffco vacuum system should help greatly to reduce the housekeeping problems and thereby prevent asbestos fibers from being reintrained into the ambient air. Your plans to temporarily make repairs and replacements in the existing dust collection system should help at least on an interim basis to reduce the fiber levels. The one program that must be reinforced is the respiratory protective device program. As it stands now, this program is not being rigidly enforced and workers are working in a high exposure area without respiratory protection (see attached Industrial Hygiene Survey results). We must not lose sight of the fact that a vital part of every respirator program is a respirator maintenance program as outlined by the ANSI Regulation Z88.2, 1969. If this respirator maintenance program becomes too burdensome, then I would recommend that we switch over to disposable respirators. These respirators can be used until they are loaded, which varies in time from several hours to several days. They cost'about $1.50, so it would bo in my opinion cheaper for the plant to maintain adequate reusable respirator programs. CRMC-MAD-000844 R. K. Comann January 15, 1975 Page 2 All of these methods are only acceptable as interim solu tions and will barely suffice as stop-gap methods. The decision to do a complete environmental cleanup or the alter native ... shut the plant down...must be made at the earliest date possible. W. B. Reitze VJBR/lh Attach. CRMC-MAD-000845 Environmental Control Department Denver - GHQ January 9, 1975 TO: D. B. Tash - Los Angeles Tale FROM: G. L. Swallow - Denver 4N COPIES: R. K. Comann - 4 South L. A. Schriver - Lompoc D. R. Christensen - R&D W. B. Reitze - 4 North TTTe------------------ SUBJECT: BIENNIAL INDUSTRIAL HYGIENE SURVEY - NOVEMBER 11-15, 1974 MINING DIVISION - LOS ANGELES TALC Attached is the numerical recap and the All Stations List giving the re sults of the Los Angeles (Talc) Industrial Hygiene Survey conducted dur ing the week of November 11th. The majority of established dust stations (19 of 23 established) remain above TLV. With one exception, station D-4S, these stations were over TLV on the basis of airborne asbestos (tremoiite) concentrations or com binations of tremoiite and quartz levels. Station D-4S is above TLV strictly on the basis of a respirable gravimetric quartz exposure in mg/m3 (milligrams/cubic meter). The respirable gravimetric sampling technique has superseded the former impinger method which is currently being phased out. The respirable gravimetric procedure has been proposed by NIOSH as *t the, method for evaluation of airborne quartz concentrations. In antici pation of this method becoming law, we are now using it as our criterion. The following stations have exceeded the tremoiite TLV consistently for every survey since the initial surveys of June and July, 1972; D-1M, D-2M, D-3M, D-5M, D-7M, D-8M, D-10M, D-11M, D-12M, D-13M, D-14M, D-15M, D-1S, D-2S, D-3S, D-5S, and D-7S. The only variation in results has been in terms of magnitude. Two examples of this situation appear below: D-11M, No. 2 Raymond Mill Packer Operator 07/26/72 07/26/73 05/21/74 05/23/74 11/13/74 12.3 61.2 18.7 112.3 173.5 F/cc TWA F/cc TWA F/cc TWA F/cc Peak F/cc Peak D-14M, G.A.S. - Mezzanine Floor (East of Alpine Packer 07/25/72 07/24/73 07/26/73 12/04/73 12/06/73 05/20/74 05/21/74 11/11/74 11/11/74 17.6 F/cc TWA 20.0 F/cc TWA 35.1 F/cc TWA >2.0 F/cc TWA >2.0"F/cc TWA 17.5 F/cc TWA 21.8 F/cc TWA 5.0 F/cc TWA 3.8 F/cc TWA CRMC-MAD-000846 iki i S S i. BIENNIAL INDUSTRIAL HYGIENE SURVEY - NOVEMBER 11-14, 1974 MINING DIVISION - LOS ANGELES TALC January 9, 1975 Page Two_________________________________________________ The hygienist's field notes emphasize several important points. Leaking equipment, inadequate ventilation capture velicities, and general poor de sign of the ventilation system, are the main contributors to the high dust levels encountered within the plant. Housekeeping efforts are good but are negated due to these unfavorable circumstances. Please note that at several dust stations, which are over TLV, no personal protection continuing high dust levels, the immediate necessity. (e.g. D-3M, D-1S, D-2S, D-3S), is being worn. In light of the implementation of its use is a Five noise stations were found to be above TLV. At two of these stations, no personal protective equipment is being worn; again, its immediate use should be implemented. The results are reported in accordance with the latest Federal OSHA practice. An excerpt from the Federal Register which deals with the subject of noise is attached. The actual noise levels mea sured at the stations above TLV follow: N-3M N-5M N-6M N-7M N-8M 91 dBA 95 to 98 dBA 95 to 96 dBA 93 to 94 dBA 100, 101, 102, 103, and 112 dBA The attached field notes give a good deal of detail regarding housekeeping and safety observations made during the survey. The Industrial Hygienist made a number of housekeeping and safety suggestions to the plant manager. A summary of them is as follows: 1. Although housekeeoing efforts in the Packer Area are good, the results are not. Inadequate ventilation and improper hood design results in extreme build-ups of dust throughout the area despite the clean-up procedures used. 2. In the Warehouse Area, the ambient air is generally and obviously dust laden, the major contribution to this condition appears to be the Flex-Clean baghouse discharge and the No. 2 Raymond Mill Feed System. i 3. Conditions in the warehouse affect the boxcar loading operation result ing in a highly variable and frequently concentrated dust exposure to the operator loading railroad cars. !] A number of instances where inadequate maintenance causes or contributes to . )\ dust exposures are: r CRMC-MAD-000847 1, .Bauer Mill Area a. Leaking seals on No. 1 Hurricane Feed Screen b. The product discharge from the No. 1 Hurricane Mill c. The product discharge from the No. 2 Hurricane Mill d. The product discharge from the Screw Conveyor following the Centri' sonic Mill. e. The product discharge from the No. 4 Hurricane Mill f. Leaking flanges on the discharge from the No. 6 Hurricane Mill to the No. 6 Flex-Clean Raghouse. Attife, mmt (NMtt BIENNIAL INDUSTRIAL HYGIENE SURVEY - NOVEMBER 11-15, 1974 MINING DIVISION - LOS ANGELES TALC January 9, 1975 Page Three_______ ___________________ ____________________ 2. No. 1 Raymond Mill - There 1s no effective ventilation on the elevator at tFns location, because two gates were in the closed position between the elevator and the dust collecting unit. 3. The Quality Control Lab - The exhaust hood moves very little air, result ing in visible dust during mixing operations and settled dust on laboratory equipment. Suggestions for corrective measures in general call for improved dust con trol and ventilation throughout the plant. It is my understanding that pro posals have been made by the Air Engineering Group, but that to date, no monies have been approved. No substantial orogress can be made until such time as an. adequate system is installed. In the meantime, the installation of gaskets where needed, skirting along belt conveyors, a low level Bindicator to minimize dust emissions from the No. 2 Raymond Mill Surge Bin, a Braking Device to eliminate backward movement of the conveyor associated with the Raymond Mill Surge Bin, and improving various local exhaust systems, will effect improvements in certain''specific areas. In the area of safety, it was noted and reported that there is a stumbling hazzard on the center support (at floor level) of the baghouse. G. L. Swallow KJW:GLS/jmb Attachments CRMC-MAD-000848 Denver Industrial Hygiene Laboratory R&D Center . 0 p a ^e December iy/4 CONFIDENTIAL- P l a n t M a n a g e r p. b . Ta sh BIENNIAL INDUSTRIAL HYGIENE SURVEY D I V I S I O N Mining______ P LAN T Los Angeles (Talc) Following is a summary of the Industrial Hygiene Survey conducted N o v e m b e r 11, 197-1 . 1. The f o l l o w i n g s t a ti on s w h i c h were p r e v i o u s l y o v e r T L V are below TLV in the current survey: . N-1M, N-2M, N-10M 2. The f o l l ow i ng s t at i on s we r e no t o p e r a t i n g d u r i n g the c u r r e n t survey: D-SM, D - 6 S , N-4M 3. The f o l l o w i n g st ati on s we r e found to be o v e r T L V in the cu rr e n t survey: D - 1 M , D - 2 M , D-3M, D-5M, D-6M , D - 7 M , D-8M, D-10M, D-11M, D-12M, D-13M, D - 1 4 M , D-15M, D-1S, D-2S, D-3S, D-5S, D-7S, N-3:M, N-SM, N-6M, N-7M, N-3M, V-2S , D--1S _ _ T_ T_ _______ '.............. ' ALL I \| A-\S, S. DUST * NOISE F /V A d.,,ai v4.1 G N L V 1. T o t a l n u m b e r of e s t a b l i s h e d sampling stations. 23 11 2 5. N u m b e r of st ati on s sampled during current survey. 21 -- 10 2 6. N u m b e r of s u r ve ye d stations above TLV. 19 - 5 1 36 23 1 33 21 25 19 ' D. K. Chr intenson Industrial Hygienist / * '/ *CDCA - Cleaned Dust Control Air CRMC-MAD-000849 DIVISION Page 2 of 7 DATE D e c e m b er 12, 1974 BIENNIAL INDUSTRIAL HYGIENE SURVEY ALL STATIONS Los Angeles M i n i n g _____ __ P L A N T (Talc) SURVEY DATE 11/11/74 OCCUPATIONAL DUST STATION NO. STATION DESCRIPTION Box Car Crude Unloading Operator HAZARD Tremolitic Asbestos Tremolitic Asbestos General Crusher Floor Area Sample Building, 2nd 4% Quartz Tremolitic Asbestos Tremolitic Asbestos Tremolitic Asbestos 4% Quartz D-4M General Area Sample Incline & Shuttle C o n v e y o r Ar ea (To Storage Bins) General Area Sample Rear Yard (East of Mill Building) Tremolitic Asbestos 4% Quartz Tremolitic Asbestos Tremolitic Asbestos 16% Quartz Cp'-st-O General Area Sample South Side of Building (Bauer Equipment Area) Tremolitic Asbestos Tremolitic Asbestos 16% Quartz DNO CD General Area Sample - Storage Yard (North of Mill BuildincO Tremolitic Asbestos 'remoli tic Did N o t Ooeratr- CRMC-MAD-000850 asbestos ADOVO TLV .6% Quartz Personal Protective Equipment Not Norn TLV 10.0 10.0 1.67 2.0 2.0 10.0 1.67 10.0 1.67 2.0 2.0 0.56 2.0 2.0 0.56 -2.0 2.0 0.56 CURRENT SU-*~ RESULT** *" (15.5 F/cc) (38.2 F/cc) 1.51 mg/m3 3'.0 F/cc 1 1.5 F/cc (1.7 F/cc) 0.68 mg/m3 (28.8 F/cc)* 1.37 mg/m3 1.2 F/cc* 0.4 F/cc* 0.00 mg/m3 1.1 F/cc 7.1 F/cc 2.02 mg/m^ 2.1 F/cc* 2.1 F/CC* 0.02 mg/m3' DIVISION Pago Mining DATE Docombor 12, 19 74 BIENNIAL INDUSTRIAL HYGIENE SURVEY ALL STATIONS Los Angeles PLANT (Talc) SURVEY DATE of 11/11/74 OCCUPATIONAL DUST . STATION NO. STATION DESCRIPTION General Area Sample - Under Crude Storage Bins HAZARD Tremolitic Asbestos Tremolitic Asbestos No. 1 Raymond Mill Packer Operator 16% Quartz Tremolitic Asbestos Tremolitic Asbestos 16% Quartz D-9M Alpine Packer Operator Tremolitic Asbestos Nos. 1 & 2 Vertical Mills Packer Operator Tremolitic Asbestos Tremolitic Asbestos 16% Quartz No. 2 Raymond Mill Packer Operator Tremolitic Asbestos 16% Quartz CP-12M Bauer Hurricane Mills & Tremolitic C en t r i s o n i c 'Packer Operator Asbestos Tremolitic Asbestos 16% Quartz General Area Sample Electrical Control Panels Tremolitic Asbestos East End of Building DNO - Did Not Operate C U D - Above TLV Tremolitic Asbestos 16% Quartz * - P e r s on al Protective Equipment Not VJorn eppsuro TLV 10.0 CURRENT SUPVZV RESULT (21.0 F/CC) 2.0 0.56 1.3 F/cc 2.72 mg/m3 2.0 2.0 0.56 DNO 5.9 F/cc 12.2 F/cc 0.36 mg/m3 * 2.0 3.1 F/cc 2.0 0.56 6.5 F/cc 1.41 mg/n3 10.0 0.56 (173.5 F/cc) 5.38 mg/n3 2.0 3.1 F/cc 2.0 0.56 6.4 F/cc 1.05 mg/n3 2.0 18.8 F/cc 10.0 0.56 (8.3 F/cc)^ 5.19 mg/n3 CRMC-MAD-000851 DIVISION M ining DATE December 12, 1974 ALL STATIONS Los Angeles PLANT (Talc) SURVEY DATE 1 1 / 1 1 / 7 4 OCCUPATIONAL DUST ` STATION NO. < 2 ~14ff^> ' STATION DESCRIPTION General Area Sample Mezzanine Floor (East of Alpine Packer)' Mill Crew Leader D-16M General Room Sample Lunch Room General Area Sample Shop Area 0 >-2 S j > General Area Sample Warehouse (West End of Building) Loader - Loading R. R. Box Car ^D-4S~~~2> Oiler HAZARD Tremolitic Asbestos Tremolitic Asbestos 16% Quartz TLV 2.0 2.0 0.56 Tremolitic Asbestos Tremolitic Asbestos 16% Quartz 2.C 2.0 0.56 Tremolitic Asbestos Tremolitic Asbestos Tremolitic Asbestos Tremolitic Asbestos 2.0 10.0 2.0 10.0 Tremolitic Asbestos Tremolitic Asbestos 16% Quartz 2.0 2.0 0.56 Tremolitic Asbestos Tremolitic Asbestos 6% Quartz 2.0 2.0 1.25 Tremolitic Asbestos Tremolitic Asbestos 6% Quartz 2.0 2.0 1.25 Tremolitic Asbestos 16% Quartz 10.0 0.56 CURRE NT SUP/." " RESULT 5.0 F/cc 3.8 F/cc 2.40 mg/m3 8.8 F/cc 16.7 F/cc 1.67 mg/m-1 0.4 F/cc* (1.8 F/cc)* 0.6 F/cc* (1.0 F/cc)* 5.7 F/cc* 15.2 F/cc* 0.85 mg/n3 6.2 F/cc* 12.6 F/cc* 0.55 mg/m3 4.0 F/cc * 35.8 F/cc* 0.33 mg/rn3 ' (5.3 F/cc) 7.23 mg/m3 DLd Not Operate Above TLV Personal Protective Equipment Not Worn Zen' ic*" CRMC-MAD-000852 DIVISION Mining DATE December 12, 1974 BIENNIAL INDUSTRIAL HYGIENE ALL STATIONS Lds Anglu3 PLANT (Talc) SURVEY SURVEY DATE 11/11/74 NOISE STATION N O . _______STATION DESCRIPTION <J)-5S Maintainer D-6S <Zp-is General Area Sample Bulk Loading Station (West of Building) General Room Sample Quality Control Lab - HAZARD TLV Tremolitic Asbestos 2.0 Tremolitic Asbestos 10.0 Tremolitic Asbestos 10.0 16% Quartz 0.56 Tremolitic Asbestos DNO Tremolitic Asbestos 2.0 Tremolitic Asbestos 2.0 CURRENT SURVEY RESULT 6.6 F/cc (27.8 F/cc) (20.4 F/cc) 0.31 mg/m^ -- 3.5 F/cc 11.8 F/cc DNO - Did Not Operate 5- Above TLV * - Personal Protective Equipment Not Worn ( ) - Peak Expousre ! CRMC-MAD-000853 I i ~ --- i . \ Form ECD9-73 Rev DIVISION Mining Page of DATE December 12, 1974 BIENNIAL INDUSTRIAL HYGIENE SURVEY ALL STATIONS Los Angeles PLANT (Talc)______________ SURVEY DATE 11/11/74 NOISE STATION NO. N-1M N-2M C3-5M 0-7M^> O n-8M^> N-9M N-10M N-1S STATION DESCRIPTION Front End Loader Operator HAZARD Noise C rusher Building, 2nd Floor Noise No. 1 Raymond Mill Packer Operator Noise Alpine Packer Operator Noise Nos. 1 & 2 Vertical Mills Packer Operator Noise No. 2 Raymond Mill Packer Operator Noise Bauer Hurricane Mills & Centrisor.ic Packer Operator Noise South side of Building (Bauer Equipment Area) Noise Mill Crew Leader Fork Lift Operator Noise I Noise. Shop Area Noise TLV 1.0 1.0 1.0 1.0 1,0 1.0 1.0 CURRENT SURVEY RESULT 1.17 2.17 1.77 1.57 8.00 < 1.0 < 1.0 < 1.0 DNO - Did Not Operate C__ Above TLV * - Personal Protective Equipment Not Worn ( ) - Peak Expousre CRMC-MAD-000854 FormECD8-73 Rev. D IV IS IO N Page 7 o f 7 DATE December 12 1974 BIENNIAL INDUSTJUAI HYGIENE SURVEY ALL STATIONS . . JjOS Angelos Mining_________ PLANT (Talc) ___________SURVEY DATE 11/11/74 NOISE STATION NO. V-1S STATION DESCRIPTION General Area Sample Warehouse Loading R. R. Box Car HAZARD Carbon Monoxide Carbon Monoxide TLV 50.0 ppm 50.0 ppm CURRENT SURVEY RESULT 10.0 ppm* 4 10.0 ppm* Carbon Monoxide 50.0 ppm 11.0 ppm* Carbon Monoxide 50.0 ppm 130.0 ppm Carbon Monoxide 50.0 ppm 120.0 ppm i Carbon . * t Monoxide 50.0 ppm 10,0 ppm bs ; f 'i DNO - Did Not Operate <__ P - Above TLV * - Personal Protective Equipment Not Worn ( ) - Peak Expousre CRMC-MAD-000855 Form ECD8-73 Rev. n o i s e c s p o M ir c m i ,in m: i n <*.<(<*! u n c n llio sound l\ri-, exceed line. shown in Tublc 0-10 when m^SMiirti on the A calo Of n stninl.irri sound level meter at low re sp o n se . When noise levels ure de t e r m i n e d hy-octave hand .uiiilyMS, m e e q u i v a l e n t A-wcielitcrl s o u n d level m a y be d e t e r m i n e d as follow s: Hi * Equivalent sound level contours. Octave band sound pressure levels may be cooverted to the equivalent A-wncfucd sound level by plotting them on this crapo and n o tin g the A-svelghtcd sound level corre sponding to the point of inchest penciration Into the sound level contours. T.U3 equiva lent A-welghtcd sound level, which may differ from the actual A-wci' btcd sound level of the noise, is '-'id to determine exposure limits from Table I.O-I6. (b) (1) Whoa employees arc subjected 'to sound exceeding those listed m Tabic 0-16, feasible administrative or engi neering controls shall be utilized. If such . controls fall to reduce sound levels wit;; In the levtl': o;' Table G-t'l. r.iji'-on.'.l piotcctlvc equipment shall be provided and ' used to reduce sound levels within the levels of the table. <2) If the variations in noise level In volve maxima at intervals of l second or loss, It Is to be considered continuous. . (3) In all eases where the sound levels exceed the values shown herein, a con tinuing, effective bearin': conservation program shall be administered. .Tadic O-IG-- Peamissirle N oise Exposures* Puraffon per day, hour* 8 ............................. C ............................. 4 ............................. S ............................. ' 3 ............................. 1V4 ......................... l ............................. V4 ........................... U or less................ Sound (crei - dDA slots rejponie W hen the dally noise exposure Is com posed of two or more pr.-icrs cf ncise ex- posure of different levels, their combined effect should he considered, rather than the Individual eneet cf each. If the sum of the following fractions? C I/T H C.i/ra ^.i'ecrtll sillily, l:ir ri, Inc m-v?<1 rspoiuro X^lsould he considered to e.scccd tuo l.iu'.t value, C'n indicates the total I'.rue of cv- pCsure si a specified noise lesti, n::u Tn Indicates the miai urne ol exposure prrmil- ted a t that level. i , Kxpoimc to Impulsive or impact noise sh ould n o t exceed MO tiu peak in u m i pres ule level. s CRMC-MAD-000856 U.S. D EPA R TM EN T OF LABOR Occupational Safety and Health Administration WASHINGTON. D C. JOiJO Office of the Assistant Secretary O C T 9 1974 Mr. H. B. Vanderbilt President Chief Executive Officer R. T. Vanderbilt Company, Inc. 30 Winfield Street Norwalk, Connecticut < 08855 Dear Mr. Vanderbilt: This is in reply to.your letter of .September^26, concerning your .request for relief from the asbestos standard tor your talcs containing non-fibrous tremolite; actinolite, and anthophyllite. My letter of August 6 ^teted that ncn-fihrous or nou'-aebastifora minerals such as non-asbestiform tremolite are not within .the scope of the asbestos standard and, therefore, the provisions of that standard do not apply to talc containing non-asbestiform minerals. NIOSH.is currently conducting a thorough investigation into.the ^exact minerals.to-which talc workers were exposed in those .studies where.asbestosis or other adverse medical.effects were.found. .Pending the receipt and evaluation by OSHA ;of the report by NIOSH on.this investigation, ;if you have^scientific evidence that the naturally occuring talcs, prior to processing by milling or crushing, do not contain fibrous or asbestiform tremolite, anthophyllite, actinolite or other asbestiform minerals, you may.certify to your customers that the talc does not contain asbestos. Fibrous, asbestiform minerals such as fibrous tremolite means naturally occurring asbestiform minerals which prior to or after crushing and processing, contain fibers made up of fibrils. John H. Stender 'Assistant Secretary of Labor CRMC-MAD-000857 1 Environmental Control Department Denver - GHQ January 9, 1975 TO: D. B. Tash - Los Angeles Talc FROM: G. L. Swallow - Denver 4N COPIES: R. K. Comann - 4 South L. A. Schriver - Lompoc D. R. Christensen - R&D W. B. Reitze - 4 North TTTe--------------------- SUBJECT: BIENNIAL INDUSTRIAL HYGIENE SURVEY - NOVEMBER 11-75, 1974 MINING DIVISION - LOS ANGELES TALC Attached is the numerical recap and the All Stations List giving the re sults of the Los Angeles (Talc) Industrial Hygiene Survey conducted dur ing the week of November 11th. The majority of established dust stations (19 of 23 established) remain above TLV. With one exception, station D-4S, these stations were over TLV on the basis of airborne asbestos (tremolite) concentrations or com binations of tremolite and quartz levels. Station D-4S is above TLV strictly on the basis of a respirable gravimetric quartz exposure in mg/m3 (milligrams/cubic meter). The respirable gravimetric sampling technique has superseded tne former impinger method which is currently being phased out. The respirable gravimetric procedure has been proposed by NIOSH as the. method for evaluation of airborne quartz concentrations. In antici pation of this method becoming law, we are now using it as our criterion. The following stations have exceeded the tremolite TLV consistently for every survey since the initial surveys of June and July, 1972; D-1M, D-2M, D-3M, D-5M, D-7M, D-8M, D-10M, D-11M, D-12M, D-13M, D-14M, D-15M, D-1S, D-2S, D-3S, D-5S, and D-7S. The only variation in results has been in terms of magnitude. Two examples of this situation appear below: D-11M, No. 2 Raymond Mill Packer Operator 07/26/72 07/26/73 05/21/74 05/23/74 11/13/74 12.3 61.2 18.7 112.3 173.5 F/cc F/cc F/cc F/cc F/cc TWA TWA TWA Peak Peak D-14M, G.A.S. - Mezzanine Floor (East of Alpine Packer 07/25/72 07/24/73 07/26/73 12/04/73 12/06/73 05/20/74 05/21/74 11/11/74 11/11/74 17.6 F/cc TWA 20.0 F/cc TWA 35.1 F/cc TWA >2.0 F/cc TWA >2.0 F/cc TWA 17.5 F/cc TWA 21.8 F/cc TWA 5.0 F/cc TWA 3.8 F/cc TWA CRMC-MAD-000858 BIENNIAL INDUSTRIAL HYGIENE SURVEY - NOVEMBER 11-14. 1974 MINING DIVISION - LOS ANGELES TALC January 9, 1975 Page Two____________________ __________________________ The hygienist's field notes emphasize several important points. Leaking equipment, inadequate ventilation capture veli cities, and general poor de - sign of the ventilation system, are the main contributors to the high dust levels encountered within the plant. Housekeeping efforts are good but are negated due to these unfavorable circumstances. Please note that at several dust stations, (e.g. D-3M, D-1S, D-2S, D-3S), which are over TLV, no personal protection is being worn. In light of the continuing high dust levels, the immediate implementation of its use is a necessity. Five noise stations were found to be above TLV. At two of these stations, no personal protective equipment is being worn; again, its immediate use should be implemented. The results are reported in accordance with the latest Federal OSHA practice. An excerpt from the Federal Register which deals with the subject of noise is attached. The actual noise levels mea sured at the stations above TLV follow: N-3M N-5M N-6M N-7M N-8M 91 dBA 95 to 98 dBA 95 to 95 dBA 93 to 94 dBA 100, 101, 102, 103 dBA The attached field notes give a good deal of detail regarding housekeeping and safety observations made during the survey. The Industrial Hygienist made a number of housekeeping and safety suggestions to the plant manager. A summary of them is as follows: 1. Although housekeeping efforts in the Packer Area are good, the results are not. Inadequate ventilation and improper hood design results in extreme build-ups of dust throughout the area despite the clean-up procedures used. 2. In the Warehouse Area, the ambient air is generally and obviously dust laden, the major contribution to this condition appears to be the Flex-Clean baghouse discharge and the No. 2 Raymond Mill Feed System. 3. Conditions in the warehouse affect the boxcar loading operation result ing in a highly variable and frequently concentrated dust exposure to the operator loading railroad cars. A number of instances where inadequate maintenance causes or contributes to . dust exposures are: 1, .Bauer Mill Area IT. Leaking seals on No. 1 Hurricane Feed Screen b. The product discharge from the No. 1 Hurricane Mill c. The product discharge from the No. 2 Hurricane Mill d. The product discharge from the Screw Conveyor following the Centrisonlc Mill. e. The product discharge from the No. 4 Hurricane Mill Leaking flanges on the discharge from the No. 6 Hurricane Mill to it,-anftJ he^Ng. .,.6<E3exa&lean^Baghouse. CRMC-MAD-000859 BIENNIAL INDUSTRIAL HYGIENE SURVEY - NOVEMBER 11-15, 1974 MINING DIVISION - LOS ANGELES TALC January 9, 1975 Page Three____________________ _________________________ 2. No. 1 Raymond Mill - There is no effective ventilation on the elevator at this location, because two gates were in the closed position between the elevator and the dust collecting unit. 3. The Quality Control Lab - The exhaust hood moves very little air, result ing in visible dust during mixing operations and settled dust on laboratory equipment. Suggestions for corrective measures in general call for improved dust con trol and ventilation throughout the plant. It is my understanding that pro posals have been made by the Air Engineering Group, but that to date, no monies have been approved. No substantial progress can be made until such time as an adequate system is installed. In the meantime, the Installation of gaskets where needed, skirting along belt conveyors, a low level Bindlcator to minimize dust emissions from the No. 2 Raymond Mill Surge Bin, a Braking Device to eliminate backward movement of the conveyor associated with the Raymond Mill Surge Bin, and improving various local exhaust systems, will effect Improvements in certain specific areas. In the area of safety, it was noted and reported that there is a stumbling hazzard on the center support (at floor level) of the baghouse. G. L. Swallow KJW:GLS/jmb Attachments CRMC-MAD-000860 Dcnvcr Industrial Hygiene Laboratory R&D Center L .. Date December 1 Q _. '4 >*4W. ti, .. - . CONFIDENT IAL- P l a n t M a n a g e r p. b . T a s h ___________ % BIENNIAL INDUSTRIAL HYGIENE SURVEY d i v i s i o n Mining P L ANT Los Angales (Talc) Following is a summary of the Industrial Hygiene Survey conducted November 11f 1974. 1. T h e f o l l o w i n g s t a t i o n s w h i c h w e r e p r e v i o u s l y o v e r T L V a r e below TLV in the current survey: . N-1M, N-2M, N-10M 2. T h e f o l l o w i n g s t a t i o n s w e r e n o t o p e r a t i n g d u r i n g the c u r r e n t survey: D-9M, D-6S, N.-4M 3. T h e f o l l o w i n g s t a t i o n s w e r e found to b e o v e r T L V in the c u r r e n t survey: D-1M, D - 2 M , D-3M, D-5M, D-6M,.D-7M, D -8M, D-10M, D-11M, D-12M, D-13M, D-14M, D-15M, D-1S, D - 2 S , D - 3 S , 'D - 5 S , D-7S, N-3M, N-SM, N-6M, N-7M, N-8M, V-2S, D-4S ALL DUST 1" 1 -- * NOISE 4. T o t a l n u m b e r of e s t a b l i s h e d sampling stations. 23 11 1 ASB.F / V T O T A L w.Lti i 2 36 23 5. N u m b e r of s t a t i o n s s a m p l e d during current survey. 21 -- 10 2 33 21 6. N u m b e r of s u r v e y e d sta t i o n s above TLV. 19 - 5 1 25 19 *CDC/i - C l e a n e d D u s t C o n t r o l A i r -- ' / j A/, D. K. C h r i s t e n s o n " Industrial Hygienist JCI jar, O E C CRMC-MAD-000861 DIVISION Page 2 of Mining DATE D e c e m b e r 12, 1974 BIENNIAL' MblJS'S^tfrOTGrENte".S U R V E Y ALL STATIONS Los Angeles P L A N T ___ (Talc) SURVEY DATE 11/11/74 OCCUPATIONAL DUST STATION NO. STATION DESCRIPTION Box Car Crude Unloading Operator HAZARD Tremolitic Asbestos TLV 10.0 C U R R E N T SUP.7Z* RESULT (15.5 F/cc) Tremolitic Asbestos 10.0 <( ^ ( 3 8 . 2 F / c c T ) 4% Quartz 1.67 1.51 mg/m3 General Area Sample Crusher Building, 2nd Floor Tremolitic Asbestos Tremolitic Asbestos 2.0 3.0 F/cc t 1 2.0 1.5 F/cc Tremolitic Asbestos 4% Quartz 10.0 1.67 (1.7 F/cc) 0.68 mg/m" General Area Sample Incline & Shuttle C o n v e y o r A r e a (To Storage Bins) General Area Sample Rear Yard (East of Mill Building) Tremolitic Asbestos 4% Quartz Tremolitic Asbestos Tremolitic Asbestos 16% Quartz 10.0 1.67 2.0 2.0 0.56 /(28.8 F/cc)* 1.37 m g / m 3 * J| 1.2 F/cc* 0.4 F/cc* 0.00 mg/m3* General Area Sample South Side of Building (Bauer Equipment Area) Tremolitic Asbestos Tremolitic Asbestos 16% Quartz 2.0 2.0 0.56 1.1 F/CC 1 7.1 F/cc I 2.02 mg/m3 | DNO CO - *. - General Area Sample Storage Yard (North of Mill Building) Did Not Operate Above TLV Personal Protective K b O tlCrt-v, Equipment Tremolitic Asbestos Tremolitic Asbestos 16% Quartz 2.0 2.0 0.56 2.1 F/cc* I '^1 2.1 F/CC* I 0.02 m g / m 3 * If N o t Wo r n CRMC-MAD-000862 DIVISION Pago Mining DATE December 12, 1974 BIENNIAL INDUSTRIAL HYGIENE SURVEY ALL STATIONS Los Angeles P L A N T (Talc) SURVEY DATE of 11/11/74 OCCUPATIONAL DUST STATION __ N O . ____________S T A T I O N D E S C R I P T I O N <^>-7^0 General Area Sample - Under ^ ---- Crude Storage Bins HAZARD Tremolitic Asbestos Tremolitic Asbestos 16% Quartz No. 1 Raymond Mill Packer Operator Tremolitic Asbestos Tremolitic Asbestos D-9M Alpine Packer Operator 16% Quartz Tremolitic Asbestos Nos. 1 & 2 Vertical Mills Packer Operator Tremolitic Asbestos Tremolitic Asbestos 16% Quartz p-np No. 2 Raymond Mill Packer Operator Tremolitic Asbestos [ <J>-12M~ 16% Quartz Bauer Hurricane Mills & C e n t r i s o n i c 'P a c k e r O p e r a t o r Tremolitic Asbestos Tremolitic Asbestos \ CP-13tO 16% Quartz General Area Sample Electrical Control Panels East End of Building Did Not Operate Above TLV Personal Protective Exposur* Equipment Tremolitic Asbestos Tremolitic Asbestos 16% Quartz Not Worn TLV 10.0 C U R R E N T SU?:.-Zli RESULT U (21.0 F/cc) 1 2.0 0.56 2.0 2.0 0.56 DNO ` 1.3 F/cc \ 2.72 mg/m3 5.9 F/cc 4\ j vi 12.2 F/cc I 0.36 mg/m3 * 2.0 3.1 F/cc 6.5 F/cc 1.41 mg/n3 10.0 0.56 / (173.5 F/cc) 5.38 mg/n3 2.0 3.1 F/cc 6.4 F/cc 1.05 mg/m3 2.0 10.0 0.56 (8.3 F/cc)^ 5,19 mg/m 3 CRMC-MAD-000863 . r-: ' DIVISION Page 4 of ** DATE December 12, 1974 b i e n n i a l " in d u s t j u a ^ hygiene s u r v e y ALL STATIONS , ' Los Angeles M i n i n g _________ P L A N T ( T a l c ) ______________ S U R V E Y DATE 11/11/74 OCCUPATIONAL DUST STATION NO. <^D-14f-r> STATION DESCRIPTION General Area Sample Mezzanine Floor (East of Alpine Packer)1 O - isjO Mill Crew Leader # D-16M !' \ General Room Sample Lunch Room C d -is 3 General Area Sample Shop Area . 0-3S^> General Area Sample Warehouse (West End of Building) L o a d e r - L o a d i n g R. R. Box Car * 0'0 Oiler HAZARD Tremolitic Asbestos Tremolitic Asbestos 16% Quartz TLV 2.0 2.0 0.56 Tremolitic Asbestos Tremolitic Asbestos 16% Quartz 2.0 2.0 0.56 Tremolitic Asbestos Tremolitic Asbestos Tremolitic Asbestos Tremolitic Asbestos 2.0 10.0 2.0 10.0 Tremolitic Asbestos Tremolitic ' Asbestos 16% Quartz Tremolitic Asbestos Tremolitic Asbestos 6% Quartz 2.0 2.0 0.56 2.0 2.0 1.25 Tremolitic Asbestos Tremolitic Asbestos 6% Quartz 2.0 2.0 1.25 Tremolitic Asbestos 16% Quartz 10.0 0.56 C U R R E N T SUF.VZ RESULT 5.0 F/cc 3.8 F/cc . 2.40 mg/m3 8.8 F/cc 16.7 F/cc 1.67 mg/nv" 0.4 F/cc* (1.8 F/cc)* 0.6 F/cc* (1.0 F/cc)* 5.7 F/cc* 15.2 F/cc* 0.85 mg/n3* 6.2 F/cc* 12.6 F/cc* 0.55 mg/n3 4.0 F/cc* (35.8 F/cc*^> O'.33 m g / n 3 * (5.3 F/cc) 7.23 mg/m3 DNO - Did Not Operate O -- A b o v e T L V D IV IS IO N M in in g Page J5___ of _7____ D A T E D e c e m b e r 12, 1974 BIENNIAL IN D U S T R IA L H YG IEN E ALL ST A TIO N S Los Angeles PLANT (Talc) SURVEY SURVEY DATE 11/11/74 NOISE STATION NO. J 3 - 5 S 2>' STATION DESCRIPTION Maintainer D-6S General Area Sample Bulk Loading Station (West of Building) General Room Sample Quality Control Lab - HAZARD TLV Tremolitic Asbestos 2.0 Tremolitic Asbestos 10.0 Tremolitic Asbestos 10.0 16% Quartz 0.56 Tremolitic Asbestos DNO o CN Tremolitic Asbestos Tremolitic Asbestos 2.0 CURRENT SURVEY RESULT 6.6 F/cc (27.8 F/cc) (20.4 F/cc) 0.31 mg/n3 3.5 F/cc 11.8 F/cc .- ',! : DIVISION Page 7 of 7 Mining DATE December 12, 1974 BIENNIAL INDUSTRIAL HYGIENE SURVEY ALL STATIONS Los Angeles _______ P L A N T (Talc)_____________S U R V E Y DATE 11/11/74 N O ISE STATION NO. V-1S STATION DESCRIPTION General Area Sample W arehouse Cy-2S^> L o a d i n g R. R. B o x C a r HAZARD TLV CURRENT SURVEY RESULT Carbon Monoxide 50.0 ppm 10.0 ppm' Carbon Monoxide 50.0 ppm 10.0 ppm Carbon Monoxide 50.0 ppm 11.0 ppm Carbon Monoxide 50.0 ppm 130.0 ppm Carbon Monoxide 50.0 ppm 120.0 ppm Carbon Monoxide 50.0 ppm 10.0 ppm DNO - Did Not Operate C-- Above TLV * ~ Personal Protective Equipment Not Worn ( ) - Peak Expousre CRMC-MAD-000867 noise ex p o su r e .m i.in do p n r . i ii r u u ii c u Uio sound levels exceed those sh o w n in Table G - tC w h e n m e a s u re d o n t h e A calo Of a s t a n d a r d so u n d level m e t e r a t low r? ? p o n 5C. w i t e n noise levels nre d e termined t*y ouiivve Unnci-ininiyii, tits equivalent A-wcirrhfed sound level may be determined as follow s: Equivalent sound level contours. Octave ' band sound pressure levels may be eon'1 verted to the equivalent A-weialncd cound level by plotting them on this graph and ! BOtins the A-welghtcd sound level corre sponding to llie point of hlqSest p e s e tm io n Into the sound level contours. 7nls equiva len t A-welghtcd sound level, which atay differ from the actual A-wenrhted sound level of the nolso, is used to determine exposure limits from Table 1.0-16. i <b)tl> W h e n , em ployees nre s u b je c te d 'tosound exceeding; th o s e listed in T a b ic '. 0 - 1 6 , fe a s ib le a d m i n i s t r a t i v e o r c n g l* necring controls shall be utilized. If such . controls fall to reduce sound levels within t h e level': o:` T a b le G -l.J. p e rs o n a l p i o - tectivc e q u ip m e n t s h a ll be p ro v id e d a n d 'used to re d u c e s o u n d levels w ith i n the , .levels of th e table. (2) If the v a r i a tio n s in n o ise level in volve m a x i m a a t .in te rv a ls of 1 seco n d or less,ItIs to be c onsidered co n tin u o u s. . (3) In all c ases w h e re t h e s o u n d levels exceed t h e values sh o w n h e re in , a c o n tinuing. effective h e a r i n g c o n s e r v a tio n program s h a ll be a d m in is te re d . .Tavle 0-16-- Permissible Noise Exposures Sound level dDA slow Duration per day, hours response 8 ........... 8 ........... 4 ...... -.... ........ SO ____ 92 ___ 05 8 ........... " S ........... ........ 97 ___100 ___102 . . . . . 105 H .......... 110 V4 or l e s s . . . . . . . ................. n s When the dally noise exposure is com posed of two or more pcncPo cf ncisc ex posure of different levels, their combined effect Should he considered, railicr than the Individual cuvet cf each. If the sum of the following fractions: CI/7T -f C2/T2*Cn/Tn .exceeds unity, then, me mixed o po.uro Y^tiould be considered to exceed tno hmh, value, Cin Indicates the tclal time of cx- ficsurc at tpevifted imiso level, and Tn ndleairs the total lime of exposure permit- tf d a t llia l level. , .E xposure to Impulsive or Impact noise ehould not exceed 140 oil peak sound presture level. CRMC-MAD-000868 The Board o f D ire c to rs Report of Activity On h ea lth a spec ts of a sbesto s J u n e 1, 1 9 6 6 t o J a n u a r y 1, 1968 J a n uary 15# CRMC-MAD-000869 Report o f A ctiv ity On HEALTH ASPECTS C? ASBESTOS I. G E N E R A L B A C K G R O U N D A tta ch e d fo r re fe re n c e is the o n ly p r io r re p o rt to th e. B o a r d o n t h i s s u b j e c t , d a t e d J u n e 10, 1966. ( A p p e n d i x A ) It traces the origin of the asbestos-health problem and activities undertaken by Johns-Manville between March and June 1966. This status report summarizes what has transpired since June 1966 and discusses current projects. I I . DEPARTMENT OF ENVIRONMENTAL CONTROL In March 1967 Johns-Manville established a new Department of Environmental Control. Its director, Ed Fenner, a mechanical engineer b y training, reports to A. C. Smith, Senior Vice . t President for Research, Development and Engineering. He directs a coordinated approach to the overall J-M environmental control situation dealing with both employee and general public covering all divisions, plants and mines. Every 60 days, this g r oup gives C. B. Burnett and the President's Staff a detailed briefing on environmental control activities, backed up by a carefully documented written report. CRMC-MAD-000870 More A s indicated b y the a t t a c h e d ext r a c t from the N o v e m b e r 1, 1967 Report (Appendix B ) , p r i o r i t y at t e n t i o n is b e i n g g i ven to locations where asbestos dust levels are higher than we consider acceptable. Because Johns-Manville was one of the first industrial firms to take a "total environment" approach and set up a special department, we have had favorable publicity in several trade publications, including OCCUPATIONAL HAZARDS. A r e p r i n t of the latter a r t i c l e is a t t a c h e d (Appendix C ) . O n e p r o j e c t to w h i c h the Environmental Control Dep a r t m e n t is giving high priority is the development of "Codes of Practice" for the guidance of contractors and customers who handle and work with asbestos-containing products in the field. Several of these booklets are presently being prepared by the EC working with the Public Relations Department. MEDICAL ADVISOR In November, C. B. B u r n e t t a n n o u n c e d the a p p o i n t m e n t o f Dr. George W. Wright as Consultant to the President on medical matters. Dr. Wright, Head of the Department of Medical Research at Saint Luke's Hospital, Cleveland, Ohio, is a recognized authority on asbestos and human health. A copy o f h i s "Curriculum Vitae" is att a c h e d (Appendix D ) . M o r e .. CRMC-MAD-000871 -3- c I V . ENVIROM M SHTAL H EA LTH CO M M ITTEE To m ake c e r t a in th a t J-M ta k e s a c o o rd in a te d , h ig h p r io r it y a p p ro a ch to th e a s b e s t o s / h e a lth p ro b le m , C .B . B u rn e tt e a r ly in 1 9 6 7 , d e s ig n a te d an "E n v iro n m e n ta l H e a lth C o m m itte e ," u n d e r th e c h a irm a n sh ip o f F . J . S o lo n , J r . , V ic e P r e s id e n t , A d v e r t is in g and P u b lic R e la t io n s . T h is C o m m itte e , w h ic h m eets b i-m o n th ly to re v ie w p r o g r e s s , p ro b le m s and p la n s , i s com posed o f th e fo llo w in g p e rso n n e l: C . B . B u rn e tt, P re s id e n t H . M. B a l l , S e n io r V ic e P r e s id e n t , G e n e ra l C o u n s e l E . M. F e n n e r, D ir e c t o r , E n v iro n m e n ta l C o n tro l H . M. Ja c k s o n , M an ager, In d u s t r ia l R e la t io n s and D e v e lo p m e n t K . V . L in d e ll, S e n io r V ic e P re s id e n t A sb e sto s F ib e r D iv is io n A . B . M arch an t, S e n io r V ic e P re s id e n t In d u s t r ia l R e la tio n s W. P . R a in e s D ir e c to r o f P u b lic R e la tio n s * ` Iv a n S a b o u rin , L e g a l c o u n se l to th e Q uebec A sb e sto s M in in g A s s o c ia t io n C . L . R h e c k le r , M anager, O c c u p a tio n a l E n v iro n m e n ta l C o n tro l A . C . S m ith , S e n io r V ic e P re s id e n t R e s e a r c h , D e ve lo p m e n t & E n g in e e r in g F . J . S o lo n , J r . , V ic e P re s id e n t, A d v e r t is in g and P u b lic R e la tio n s D r . G e o rg e W. W r ig h t , M e d ic a l c o n s u lt a n t to t h e P r e s id e n t CRMC-MAD-000872 more. 4- r V . P U B L IC R ELA TIO N S A C T IV IT IE S F o llo w in g a re h ig h lig h t s o f th e p u b lic r e la t io n s a c t iv it ie s , in c o n n e c tio n w ith th e a s b e s t o s / h ^ a lth p ro b le m , t h a t h a ve been u n d e rta ke n b y th e J-M P u b lic R e la tio n s D ep artm en t w ith th e a s s is t a n c e o f H i l l & K n o w lto n , o u r P u b lic R e la t io n s C o u n s e l, d u rin g th e p a s t 18 m onths: A . P U B L IC R E LA TIO N S M A TER IA LS A tta c h e d i s a p r e c is e ly w orded sta te m e n t t it le d "A sb e sto s and Human H e a lt h " (A p p e n d ix E) w h ic h su m m a rize s p r e s e n t ly known s c ie n t if ic fa c t s c o n c e rn in g th e r e la t io n s h ip betw een / a s b e s to s and hum an h e a lt h . I t w as d e v e lo p e d b y th e P u b lic R e la t io n s , In d u s t r ia l R e la t io n s , R e se a rc h and E n v iro n m e n ta l C o n t r o l D e p a rtm e n ts and w as re v ie w e d and c le a r e d b y a l l m em bers o f th e a fo re m e n tio n e d E n v iro n m e n ta l H e a lth C o m m itte e . Q u o tes from t h is sta te m e n t w i l l be u se d , a s n ee d ed , b y th e * P r e s id e n t , C h a irm a n o f C a n a d ia n J o h n s -M a n v ille , V ic e P re s id e n t fo r F in a n c e , V ic e P re s id e n t and G e n e ra l C o u n se l, C o n t r o lle r , th e E n v iro n m e n ta l C o n tro l D ep artm en t and th e P u b lic R e la t io n s D ep artm en t in h a n d lin g in q u ir ie s from s to c k h o ld e rs , f in a n c ia l a n a ly s ts , p u b lic o f f ic ia ls , th e p re ss and o th e r o u tsid e g ro u p s. C R M C -M A D -0 0 0 8 73 more m mi -5- In addition, copies of "Asbestos and Human Health" have been distributed to Senior Officers, Division General Managers, Division Staff Managers, District Sales Managers, Plant and Mine Managers and Industrial Relations Managers at all J-M locations. B. BACKGROUND PAPERS We contemplate that this basic statement will answer most questions on the asbestos/health problem. However, for those dealing with scientific writers, the general press, financial analysts, etc., we decided it advisable to have greater detail available on a number of specific aspects of the asbestos/health question. Therefore, preparation K is underway on seven "background papers" that will be, in effect, appendices to the basic position paper. Subjects include asbestos-cement pipe, asbestosis, mesothelioma, lung cancer, asbestos bodies, types of asbestos, asbestos an^ the general public. C. A C T I O N PRO G R A M The development and use of the basic statement and the background papers, are part of an overall public relations action program that has been developed and approved by the Environmental Health Committee. A copy of this action p r o g r a m is a ttached (Appendix F ) . **'VW$T%V C R W C - M a d .000874 more. -- 6-- D. H A N D L I N G PRESS RELATIONS IN T H E MANVILLE. N E W J E R S E Y ARI In August, 1967, THE JOURNAL OF THE AMERICAN MEDICAL ASSOCIATION published an article by four doctors at Somerset Hospital, Somerville, New Jersey, who said they h a d d i a g n o s e d 17 cases of mesoth e l i o m a , a v e r y rare form of ancer, among patients living in the vicinity of the Johns-Manville Plant at Manville, New Jersey. They associated this frequency of mesothelioma with asbestos. On Sunday, S e p t ember 10, 1967 the N E W A R K - S T A R L E D G E R ran a Page One article (Appendix G ) , reporting on this finding. Subsequently, every newspaper covering the general area of New Jersey where the Manville P l ant is located ran articles on the subject. A lthough the basic statement had not been finalized at that time, the public relations Department worked with Legal, ft Industrial Relations and Environmental control in developing interim statements that were used to help answer the accusations. In every case, the company was successful in working with editors in the development of follow-up articles that, while they did not absolve asbestos, did present the matter in an objective and realistic light and removed it from the "epidemic scare" at m o s p h e r e that had boon generated by the initial reports. Attached CRMC-MAD-000875 m ore is a typical follow-up article, from the SOMERSET MESSENGER GAZETTE (Appendix H ) . E. A S B E S T O S - C E M E N T P IPE A L L E G A T I O N S Late in November, 1967 allegations about the possible hazard of drinking water supplied through asbestos-cement pipe were introduced into a politically-oriented fight in the metropolitan government of Nashville, Tennessee. Briefly -- for many years only cast iron pipe, supplied b y one vendor, has been used in the Nashville water system. The Purchasing Committee of th@ City Council introduced the idea of asbestos-cement pipe as a possible alternate to cast iron. Through means, not entirely clear at present, Dr. James Snell, a medical professor at Vanderbilt University, was inspired to write the head of the Nashville Metropolitan Water Department, expressing concern about the safety of asbestos-cement pipe, in view of the publicity that asbestos had received as an alleged cancer-causing agent. Dr. Snell's letter is attached (Appendix I ) . Publication of Dr. Snell's letter in the NASHVILLE BANNER (Appendix J) and an n o u n c e d plans by the P u r c hasing Committee of the City Council to visit J-M's Manville Plant m ore . generated considerable publicity and attention in Nashville. Working with the Pipe Division, arrangements were made to host the city councilmen and Dr. George w. Wright talked with the group at length on asbestos/health. He put the problem into perspective by emphasizing that asbestos appears to be, at most, an occupational hazard that is definitely dose-related. He stated that there is no evidence to support Dr. Snell's allegation that the use of asbestos-cement water pipe might cause cancer. Dr. Wright's comments were given prominence by the NASHVILLE TENNESSEEAN, the city's largest circulation newspaper, in its Decem b e r 12, 1967 issue, clipping attached (Appendix K ) . Following their return, the Nashville councilmen made further favorable comment about asbestos-cement pipe ito the n ewspapers. (Appendix L) . Shortly after his talk with the Nashville group, Dr. W r i g h t put h i s ver b a l coitiments into w r i t t e n form in a letter addressed to F. J. Solon, Jr. (Appendix M ) . A further outgrowth of the Nashville situation has been the stated intent (based upon letters from Nashville officials} b y the U. S. D e p a r t m e n t of Health, E d u c a t i o n CRMC-MAD-000877 m ore - 9 - * and Welfare, to investigate the alleged health hazards of asbestos-cement pipe. Photocopies of the damaging November 30th NASHVILLE BANNER article questioning asbestos-cement pipe began turning up in various other parts of the country, in the hands of officials charged with specification or purchase of water pipe. We had sufficient evidence to indicate these clippings were being placed by people connected with the cast iron pipe industry. So, with legal counsel present and all proceedings tape recorded, a meeting was held at J-M's invitation o n J a n u a r y 3, 1968, amo n g the four p r i n c i p a l m a n u facturers of asbestos-cemsnt pipe with the Director of the American Water Works Association also present. These future courses of action were determined: 1. T h e n e e d to v i s i t i n f o r m a l l y w i t h p e r s o n n e l of the \ Department of Health, Education and Welfare, to determine the future course of the proposed investiga tion of asbestos-cement pipa and the feasibility of broadening such an investigation to include all types of pipe carrying potable water. 2. T h e D i r e c t o r o f Public R e l a t i o n s and Hill and Knowl t o n to proceed with a background paper on asbestos-cement pipe. CRMC-MAD-000878 . m ore. 3. The Gen e r a l Cou n s e l of J ohns-Manville, as authorized by the other asbestos-cement manufacturers# to discuss with the Counsel for the Cast Iron Pipe Research Institute the poor advisability of using health hazard allegations as a device to promote the sale of any type of water pipe. F. G O VERNMENTAL INTEREST In addition to the above-stated involvement of the Department of Health, Education and Welfare with asbestos-cement pipe, several other indications of interest in asbestos and health, at the government level, are worthy of note. President Johnson's comments to a group of labor editors and Surgeon General Stewart' remarks at a Senate hearing are contained in our Ju n e 10, 1966 repo r t to the Board. In addition, N e w Jersey Congressman Patten of Perth Amboy, in September 1967, introduced a bill designed to set standards in sbestos manufacturing and transportation. Attached is a copy of the newsletter (Appendix N) to his constituents, in which Representative Patten explains his proposed legislation. This Patten Bill received' very little national publicity and the best information n o w t hat it is m o s t u n l i k e l y that any action w ill b e taken upon this proposed legislation. ^RMC-MAD-000879 o r e ... To date, none of these actions has led to serious governmental interference with the asbestos industry but such interference as well as congressional investigation, remain quite distinct possibilities. G. INDUSTRIAL H Y G I E N E FOUNDATION ADDRESS In O c t o b e r 1967, F. J. Solon, Jr., Vice President, A d v e rtis in g and P u b lic R e la tio n s , d e liv e re d a paper on the subject "Communicating the Effectiveness of I n d u s t r y ' s H a z a r d r.nd P o l l u t i o n C o n t r o l s - W h o s e Job?" to the annual meeting of the Industrial Hygiene Foundation in Pittsburgh. He stressed both the importance of positive communication by industry of the facts regarding its occupational and environmental control problems, and the responsibility of medical and scientific people to challenge those of their colleagues who make sensational charges merely for the sake of publicity, without backup proof. t being printed and distributed by IHF. The p a per is H. Monitoring, Evaluating and Circulating Medical Articles, N e w s p a p e r and M a g a z i n e C l i p p i n g s ,e t c . _______ ________ A n important public relations activity is the continuous monitoring of medical journals, both domestic and foreign, as well as newspapers, magazines and radio and television programs, for scientific papers and articles relating to asbestos and health. I 4` AMERIC MINING CONGfti ' FOUNOI D SUITE 300 1920 NSTREET NW WASHINGTON DC 20036 202/861*2800 TWX710*822*0126 J. ALLEN OVERTON JR PRESIDENT memorandum C-A I '<!; r >i. it / i d , 1 TO: ERPM : AMG Occupa t:iona 1 He .i1t11 ' '<nnai it 1<< Task Group on As 11e ;;1i j;; Task Group on ,'1 lie. AMC O c c u p a L ion.i 1 II'*a 1t.h C< in u ]t.i:G II. Bradley Johns on, Vice.' President NI OSH Study o f Asbestos and SiJ ica Oust Control JRB Associates, McLean, Virginia, is conduct ilag a MIOSH-sponsored technology assessment of asbestos and silica dust control in the mining industry. This study will parallel NI.OSH activity to develop revised m i!' exposure standards for asbestos and silica. The new Task Groups on Asbestos and Silica of the AMC Occupational Health Committee should be.prepared to follow this activity and to comment on the results of the study. The purposes of the contract are to: Estimate the extent and degree of worker exposure to asbestos and silica and develop a profile of exposure in terms of each mining and milling process, or other appropriate classifications; Evaluate the state-of-the-art technology for controlling exposure to asbestos or silica at mines and mills; and Evaluate the technological feasibility of applying alternate permissible exposure limits for asbestos (If/cc, 0.5f/cc, O.lf/cc) and silica (0.075mg/cu m, 0.0 50mg/cu m) . The scope of work includes mine and mill site visits to obtain information on exposure control and control methods. It is understood that: no sampling or other measurements will he conducted by the contractor. .Enclosed is a copy of the statement of work from the contract, able '>! cite juries o f specific mining and milling operations dove loped by .IRli, and JEB's list of potential sites. on .January l'1, AMC staff met with Robert .1. Ka 11 and Patrick Bannister of ,JRB Associates and James Warren and Roy Fleming of N10SI1 ioi a review ot the project. The control technology study was appat "lit Ly designed to parallel N T O S H 's in-house health evaluations d isi'<-stos and silica. The health studies have apparently been delayed, i* i1 1 ipp'Mi:; that the scope of the contract study is extremely broad m b if a.ay .have to be modified. A 1so enclosed arc rosters of f11<* Asbestos and Silica Task Groups. Enclosures CRMC-MAD-000881 TASK GROUP: Asbestos 2/18/82 C. Thompson Manager, Research & Development R. T. Vanderbilt Co., Inc. 10 W infield: Street No rw. 11k , CT 0 68 5 5 201/953-1400 D. ''S o n n y 1' Mukherjee Industrial Hygienist-Mining Medical Division CONOCO, Inc. P . 0. Box. 1267 Ponca City, OK 74603 405/767-5489 0 Minerals Carlson Environmental Technical Pickands Mather & Co. 1100 Superior Avenue Cleveland, Ohio 44114 210/094-5934 Supervisor William J. Hollar, dr. Environmental Health Engineer Bethlehem Steel Corporation B 238 Martin Tower Bethlehem, PA 18016 215/694-7518 Warfield Garson, M.D., P.M.H. Medical Director, Legislative and Regulatory Health Affairs Consolidation Coal Company Consol Plaza 1800 Washington Road Pittsburgh, PA 15241 412/831-4483 C. W. Gtallurd, Jr., M.D. Director, Health, Services The standard Oil Company Midland Building Cleveland, Ohio 44115 .1 1 0 / 3 7 0 - 5 9 2 0 Harry P. Rhodes occupational Health Manager Union Carbide Corporation 134 - 4 7th Street Niagara Fa] Is, NY 14 302 710/238-3375 Kenneth A. Robert:; Manager, Environmental Services Manville Service Corporation Ken-Caryl Ranch Denver, CO 80217 303/978-3120 Robert L. Bockstahler Eagle-Picher Industries, 580 Walnut Street Cincinnati, OH 45202 513/721-7010 Inp. CRM C-M AD-000882 TASK GROUP: Silica Warfield Garson, M.D., M.P.H. Medical Director, Legislative Regulatory Health Affairs Consolidation Coal Company Consol Plaza 1800 Washington Road Pittsburgh, PA 15241 412/831-4483 (Chairman) and Doane Lucio Chief Industrial Hygienist Henderson Mine Climax Molybdenum Company P. O. Box 08 Umpire, CO 80438 303/569-3221, Ext. 284 Robert W. Pickarz Vice Prcsidc-nt-Engineering and Environmental Affairs Minerals Division Eagle-Pichor Industries, Inc. P. 0. Box 12130 Reno, NV 89510 702/322-3331 Donald L. Webster Senior Environmental Health Bethlehem Steel Corporation B 238 Martin Tower Bethlehem, PA 18016 215/694-4387 Engineer Larry W. Youngblood Corporate Industrial Hygienist Union Carbide Corporation Old Ridgebury Road - Section Q-2 Danbury, CT 06817 203/794-5273 Joseph Schwerha, M.D. Assistant Medical Director U.S. Steel Corporation 600 Grant Street Pittsburgh, PA 15230 412/433-2447 2/18/82 CRMC-MAD-000883 1 I Johns-Manville Internal Correspondence to Ken Roberts, HS&E DDaattee:: 20 May 1982 .1 Nancy Olson, Public Affairs Office, Washington Subject NIOSH Study of Asbestos and Silica Dust Control At your request I attended a meeting here in Washington of the American Mining Congress' Occupational Health Committee (Task Group on Asbestos and Silica) on Wednesday, May 19, 1982. It was attended by two officials from NIOSH, a representative from JRB Associates, three people from the American Mining Congress, representatives from Eagle Pitcher, SOHIO Industries, RT Vanderbilt, and me. The meeting began at 9 a.m. and ended around 11:15 a.m. The purpose of the meeting was to review the status of a NlOSH-sponsored technology assessment study of asbestos and silica dust control in the mining industry. The contractor, JRB Associatees, has completed Task I (development of exposure profiles) and is proceeding with Task II (evaluation of control technologies.) They expect to complete Task II by the end of May 1982. Task III will combine the results of I and II so that the feasibility of reducing dust levels throughout the mining i n d u s t r y can be determined. Completion of Task III is estimated for late summer. Robert Katt of JRB Associates took over an hour reviewing their progress as outlined in the attached 80-page report. At the conclusion Katt emphasized that, if industry has any data beyond what is in this report, they would be happy to include it. Following your review, I would encourage you to share your comments with either Toni McCrary (202) 861-7509 or Henry Chajet (202) 861-2851 (both of the American Mining Congress), and then with NIOSH. It was a most interesting meeting, and I was glad I was able to attend it on your behalf. NJO/rt Attachment CRMC-MAD-000884 U.S. DEPARTMENT OF LABOR Occupational Safety and Health Administration WASHINGTON, D C. ,210 Office of the Assistant Secretary JAM A Mr. H. B. Vanderbilt, President R. T. Vanderbilt Company, Inc. 30 Winfield Street Norwalk, Connecticut 08855 Dear Mr. Vanderbilt: This is to advise you that the Occupational Safety and Health Administration (OSHA) is rescinding the October 9, 1974 letter addressed to you from John H. Stender. A copy of this letter has been enclosed for your information. The decision to rescind this letter was based on information recently supplied to OSHA by the National Institute for Occupational Safety and Health (NIOSH). In a current medical evaluation by NIOSH of Vanderbilt employees significantly exposed to airborne dusts including fibers, lung changes were demonstrated by x-rays in the exposed workers. In addition, NIOSH's review of medical records of former employees revealed that the number of deaths attributed to both respiratory disease and lung cancer appeared to be significantly above those expected. Although the data are preliminary, they indicate the hazardous nature of tremolytic talc. In light of the information supplied by NIOSH, OSHA must rescind the above mentioned letter of October 9, 1974. In a recent memo to our Regional Administrators and Area Directors, OSHA cancelled Field Information; Memorandum #74-92. Our compliance officers have been advised to follow the sampling method for asbestos when evaluating employee exposure to fibrous tremolytic talc. They have been so advised because a tremolite fiber is an asbestos fiber under OSHA's asbestos standard 29 CFR 1910.1001. A copy of this memo has also been enclosed. If you have any questions regarding our compliance policy where tremolytic talc is concerned, please do not hesitate to contact me. Morton Corn Assistant Secretary of Labor Enclosures fc' REDACT! CRMC-MAD-000885 J- K *k* r>. '* . i n i y f!, IS '6 9 C^oro^F'iy f o C - T ^ y ^ s J O clLL R< .<>*! o', v-' i' !o 'r>. .rr. ',<lm Co. :'.inc_ i11f no;'.' To -lolir;.1 fc\ r ;ri1 ?*y o' <-meg c tci1 c. pucker for packaging Pj-n^Al P i ! ! f i s J o ^ c t o J a b o u t C tni. 1 o r s o u t h o " Lo',.n o f o o u v e r n e u r 1!. Y . . L'iy'o;-o.*-o->r ; ; . i r c a t d K i l l I r . v i ' " i i n c l o s e p r o x i m i t y . Tol.'.l work force :.tcx\ ed as 1 r with 50 irr underground. Merk on day s M rt only with SOM-.' overlie.:*. Use v.v.ge incentives underground .. as in mill '\.r:ni"-' s e t ion. Ur.ioniz":! by United Steel .iorters. base rate? ?2.17 for joniior end $3.3 3 for electrician. Ore is described as tromolito and the samples r.heo.'n us varied from massive samples to fibrous type of sample similar to our slip fibre although the fibres arc rot clearly delineated. Silica content stated as being SO:. Product is used for paint and ceramic tile manufacture. We were received by o. U. Krdmun, mine manager and wc visited parts of the Kill only in company vrith the manager and the Hill Superintend ent. We vure not invited to loo'* at the U/C, the head frame, the quality control lab nor were we shov/n any flow sheets^plans, etc. Although all questions were answered very little was volunteered. Underground Mine Described as having levels at the 300, 500 and 700` elevations, and producing 600 tons of ore daily. Mining is by open stoping leaving pillars as required. Denches are drilled as blasted with Jacklegs and the stope lef*- empty. Backs are supported with roof bolts. Waste material now being used for back filling upper level stopes. Rail tramming to 36" x 42" underground Jaw crusher and then skipped to surface. General conditions stated as good requiring little support. 4i ; i'a } 1 .>1 7 *fc $ ip 'Si. > CRMC-MAD-000886 a - 2- The o-iri mine ..1 rights to 1V.o f >.*ly were hold by fin in-1'vidvnl who apoari-rP.ly sold'lb. *.u.11v - riyh's to tit. doe I-cad 'Co. but hold o: to t rigV. s .no *h* :i I'-'-ntually di sponod of th-i;* to the predore >" of V' ; Var'i( ''ilv. Co. / a result the tv:o cor.;'*.*::: 'r.-s ap >;,rf:r,i:ly rniTu* n:s the' Si : ''O' iy , V C"< . ji (. fi:s1 *h o loc.-itil'.-' cf ib'- tc1c r;i:' ::1- f ore cictc.tc.d by Si . do.: ]C^r*1. :rd:r l st trrl Uiat nrc>\!"0 11. wore wo r \ j: g;; \'ity.''in ?S 1 o' c,v-.,-v. ot V-r crc errcpirn i.h~ir shaft -ic:1 l.b.t- 1] to * level int. or ( body. irdicat jrig the rwv.rt i-iVif'i. in the ha ng j' MIL); broecna is purely MoehrinieoJ. Ore from underground va'o crushed again in a 36" gyratory crusher followed by cone crushing, ball mills (using ceramic balls end specially imported store liners) and energy mills. Only screens used were scalping screens. Apparently ore is dried but were r.ot shown this facility. Basic ally there are 5 grades of product llytol 99, 100, 200, 30C end 4C0. V The Pytol 40C is the most finely ground and is the premium grade ip apparently used for ceramic finishes. 65T<1 nf their production is bagged in 5C lb valve paper bags and the regaining 35',i is bulb shipped by railway in customer rented hopper cars and occasionally in a box car specially supplied by the benn. State RR. Bagging operations consisted of 2 banks of 4 haver type impeller packers and a bark of 2 jet flow packers. Cycle time per 50 lb. bag is B seconds. Bags wem dropped from packer onto a conveyor belt flattened out, and then hand palletized and were being loaded into a box car. Mill apparently able to produce up to 600 tons/day of product. Product v.'as quite dense and free-flowing. CRMC-MAD-000887 -rtf'* - 3- r? ,,'nr. r.t<t.r (; i" w no*, j.b .r} <s V.-bny hur.el<<! V-y or.e large u'lv-oli'b- ,.1n> , \ >. vb th . rly fil i -on 2 I'.-Tsor.s filters. bid rol ?: 1>-. Ch.-'.M. ro.'Mri tin:.. 1n.o.-r.-iprr.-!. appeared to be <i!:)1T'.:*< . 'Mu; o-by ro; V-:voV >) i o shu-.-r ha] aspiration bonds t (he for.) end tail end '-t 1 hr- >ol * was not enclosed. <"enc.:`a' c. iiin-, .r.d d : of .r.piru!in:, pi pirn, etc. looked neglected. Mouse-keep; Tg was not ronrl. /vl1 1.ori 1 n r 2" o f whi t n p r o d u c t:. h.ul s-rfanes covered with r K .. x * . * : ' J k4. ' '..'hen qvf.-rt .ione.-' r.r- to T.L.V1r. fo- Talc, hron-ti was uncertain but thought, it night be Stated that dust surveys were made but uncertain of instrument used. Claim'd that the only pneumoconiosis -cases or i-.ri-pective canes: wore employees that had formerly worked at other mires. The only respirator seen was produced by an employee palletizing a broken bay. Respirator v;earing on a voluntary basis. Manager felt that- their dust handling system was far in advance of other local talc producing mines. General impression during our visit was that dur.t conditions seen were not severe but that they certainly could be improved. Beams of sunlight in some areas showed dust. Mill was by no means as clean as ours nor as well aspirated. Buildings and facilities were second class. Conclusion as to puroosc of visit Since material appeared to be very free flowing and fairly dense we could see no particular advantage to pressure packing. Wo felt that the bags would not hold their shape and packers would be somewhat slow. Since they wore tcly palletizing one pallet high - deformation, is not a problem. Going .o 100 lb. bags seemed out of the question since their customers were nil formulating on bag counts of 50 lb. bags. RBGiJmgb 3 R. B. Gresham -iisr*. CRMC-MAD-000888 johns-Manviiie Internal Correspondence To. F. J. Solon -- 4 North From: R. S. L a mar - R&D Center Copies: See below Date: Aug u s t 31, 1973 Subject; DIFFERENCES AMONG DESERTALC G-l, G - 2 , VANDERBILT AND INTERNATIONAL NEW YORK STATE TALCS PER YOUR REQUEST O F AUG U S T 30, 1973 Desert Minerals mines two distinct grades of crude talc ore in Warm Springs Canyon. These form the base for the bulk of our present talc business. G-l ore contains 30 to 35 per cent tremolite and n o detectable chrysotile by the usual petrographic and/or X-ray diffraction methods. G-2 ore contains 5 to 10 per cent tremolite and again no detectable chrysotile by the usual methods of ana lysis. The New York State talcs pro d u c e d by b o t h R. T. V a n d e r b i l t and international Talc Company are considerably higher in tremolite-- up to as much as 50 to 70 per cent and contain, in addition, s ignificant amounts of chrysotile. For example, differential thermal analyses (DTA) tests on some samples show nothing but serpentine (chrysotile is the fibrous variety of serpentine). DTA does not distinguish between the fibrous and non-fibrous varieties, but transmission electron micro graphs of these products confirm the presence of much chryso tile. These are the major differences among these products. R. S . LAMAR ITS cc: w. L. Va n D e r b e e k - 2 W e s t p. A. Ma r t i n s o n - 2 W est J. M. Sharratt - 2 W e s t H. R. Keefe - 2 West / ?.. P. Carter - 5 West / G. E. Parker - 5 Westy F. L. Pund8ack - R&D Center S. Speil - R&D Center W. C. S treib - R&D Cen t e r CRMC-MAD-000889 'ir F ? MEMORANDUM TO: FROM: SUBJECT: DATE: R. F. B assett Earl B, Smith Monthly Report f o r Septem ber 1972 October 10, 1972 I. Final tonnage 4479 H. FDA-OSHA A . D elegation of Jackson, C arter, Scheffel called at W ashington FDA headquarters to m eet with Spier to discuss the .postponement of O ctober 12 deadline for com m ents re proposed FDA regulation. B. Talc Industry A ssociation m eeting held at R. T . Vanderbilt head quarters New York Septem ber 28 w ith C arter and Scheffel in attendance. C . FDA-O SHA c o n fe r en ce h eld O ctob er 2 - 3 a t DHQ rep o rted in E SS m em o to F . A. M artinson under date October 2, 1972. Attendance at m eeting M artinson, Fenner, Jackson, R eitze, S ch effel, C arter, Donovan and Sm ith. C onclusions, plans and actions defined-in m eetin g m inutes. D. B u siness lo st to date due FDA or OSHA as follow s: ' 4 . S in c la ir P a in t C om pany, L o s A n g e l e s ---- lo s t one 3 0 -to n c a rlo a d ^ Septem ber m ixed products DESERTALC 54, DESERTALC HIFIN E 8 0 , and DESERTALC MIKRO 707. 2 . C row n S im p so n P u lp C om pan y, A r e a ta , C a lif o r n ia -----tw o 2 2 -to n truck loads Septem ber postponed due proposed FDA regulations. Consum ption two truck loads p er month w ill be postponed until disposition of proposed regulations is established. 3 . C row n Z e lle r b a c h , W auna, O r e g o n ---- one 5 0 -to n c a rlo a d CYCLO SORB scheduled October postponed due proposed FDA regulations 4. N orth W estern Pulp and P aper D ivision , Hinton, A lberta, Canada a would b eMcustom er requiring one carload p er 60-day period. Potential bu sin ess postponed due FDA proposed regulation. 5 . N a tio n a l G yp su m , L ong B e a c h , C a lif o r n ia ---- w ould be c u s to m e r requiring 50-ton carload per month " tr e m o lite -fre e " per OSHA regulations. Cost DESERTALC HI-PURE se r ie s uneconom ical vs. com petition. Desert Minerals, Inc. - Long Beach October 10, 1972 I / v -1 W. L. VanDerbeek P. A. Martinson* E. M. Fenner* H. M. Jackson* W. B. Reitze* N. B. Scheffel* R. P. Carter* S. Speil H. G. Donovan* Et B. Smith* FDA - OSHA MEETING RE TALC OCTOBER 2, 1972 This is a report of meeting (* in attendance) convened on October 2, 1972, in Celite Division conference room to define plans of action in matters relating to DESERTALOB and CYCLONIZED products under the proposed FDA regulations and the existing OSHA regulations. The meeting was called per PAM memo dated 9/22/72. Objectives and agenda were defined per EBS memo dated 9/26/72 (copy attached). Minutes of meeting and plans of action as follows-- I. FDA PROPOSED AMENDMENT OF PART 121 (FOOD ADDITIVES) CONCERNING FOOD OR FOOD PACKAGING MATERIAL CONTAINING TALC A. STATUS TO DATE . 1. RPC reported on meeting at Washington offices of FDA on September 20 with Allan T. Spiher, Jr., (HMJ, RPC, and NBS attending). Assumption that talc is carcinogenic originates entirely from recent publication in Science Magazine, Vol. 173, pages 1141-1142, dated September 17, 1971. No further- FDA studies were made. Assumption in proposed regulation is that talc is 100% free of asbestos-form particles. No studies nor knowledge concerning processing to remove asbestos-form par ticles. It was further implied during discussions that even asbestos-free talc may be considered carcinogenic and that further studies are planned in this direction. Spiher reported that two comments had been received to the publication in the Federal Register. A Japanese housewife wrote in stating that she was pleased to see some Government action to protect the populace. Also, a medical doctor in Columbus (R. J. Manner, M.D.) wrote that he was aware of no studies concerning ingestion and carcinogens and that he would appreciate receiving the written reports on which this FDA proposal is based. Also submitted for consideration at the meeting was a publishment in the Food Chemical News, dated September 25, 1972, which reported on a USD proposal requesting a limit of 1% asked for asbestos in talc. This should be considered in our further actions. CRMC-MAD-000891 Conclusion of the delegation was that industry is considered guilty until proven innocent. Spiher indicated that a post ponement against the 60-day deadline (October 12, 1972) could be obtained provided good and sufficient reasons were presented indicating a factual program of study to refute the claims for the proposed regulation. Report from NBS and RPC on the R. T. Vanderbilt Talc Industry Meeting at the RTV offices in New York on September 28. Apparently neither RTV nor the fractured Talc Industry Association has a positive program in either the FDA or the OSHA matter. RTV continues to study the medical aspect but no positive results are indicated. RTV claims to have developed an endorsement through EPA at Durham, North Carolina,which will classify "industrial asbestos" and not include tremolite per se. EMF reacted that this may not be an effectove approach since EPA and other agencies are not necessarily in communication because of differing objectives. Arguments: a. General discussion on the definitions of "asbestos-form." PAM suggests approaching the word talc to develop a dif ferentiation from the proposed definition. It was concluded that further consideration of the nature of the particles as asbestos-form or fibers or alternatively another definition should be considered. b . Health hazard: Hie reference article by Blaegher and Arlon concerning industrial carcinogens and concerning migration of particles into the bloodstream is being secured by RPC and will be further evaluated in consideration of ingestion versus respiration. Dr. George W. Wright, Medical Research Division at St. Lukes Hospital in Cleveland, submitted a letter to HMJ, dated September 18, expressing opinions of doubt as to the medical proof provided in this connection by the subject publication. This will be further investigated. c. Processing for removal: Opinion expressed from this talc producers knowledge that processing to remove tremolite from talc is impractical as a 100% beneficiation and should be further explored in the context of the proposed regulation. d. Migration of particles from packaging materials: The FDA meeting in further considerations indicate that the best approach to the proposed article is to develop proof that the particles do not migrate from food packaging material and a programmed study will verify this fact. Any tremolite particles present In our talcs would be In sufficiently small percentage in packaging materials and will further be locked in or bonded to the extent that they will be nonmigratory. NBS presented a proposal of study for paper test program to CRMC-MAD-000892 - 3 prove the matter. Additional studies will be programmed for coatings and plastics to present similar evidence for other food packaging materials. ACTION RFC presented a proposed letter to be directed to the Hearing Clerk, at the Department of HEW, proposing a postponement of the October 12 deadline during which prescribed and defined studies will be conducted presenting evidence in refutation of the proposed regulation. The article was edited in detail by all committee members and finalized for submission by certified mail, return receipt requested. A copy of this letter will be forwarded to the J-M Washington office (W. Winblat) for personal follow up from that office to ascertain acceptance and action taken. Follow-up documents and procedures: Assignments were made according to the five proposed studies listed in the FDA proposal as foxlows: a. Re definition of "asbestos-form particle" versus fiber, etc. Drs. Spei.l and Wright will collaborate in the development of an appropriate definition. HMJ to advise Dr. Speil and Dr. Wright. Consideration will be given to medical evidence reported and related publications, and to mineralogical considerations concerning particular matter as talc, tremolite, in relation to fibers or nonfibers. b . Tests concerning measurement of the content, size, and identification of particles contained in talc. Dr. Speil and Dick Lamar will collaborate in this study. EBS to advise RSL and HMJ to advise Dr. Speil. c. Migration studies: Norman Scheffel has scheduled a 2 - 3 day study at Western Michigan University starting October 23, 1972. CYCLO-FIL, CYCLO-SORB, and asbestos will be evaluated by code number. HGD to forward quantity of asbestos for these tests. Dr. Kukolich, Professor of Paper Technology, will coordinate and work with NBS in this study and submit final report. NBS to secure additional samples of paper utilized for packaging from Brown Paper at Kalamazoo and others for further veri fication on commercial stock. It is anticipated that the results of this study will be available from NBS in report form by Also, NBS will contact W, C. Streib in reference to a similar study for plastics and coatings concerning availability of J-M Research and Development facilities. A meeting was arranged with Streib, Lamar, Scheffel, and Smith on October 12 to discuss this and further action in relation to FDA and OSHA regulations. CRjVf. Mad. 000893 - 4 - d. Re processing to remove asbestos-form particles. EBS and RSL to explore processing methods and present conclusions and opinions and feasibility and j conomics of the beneficiation of talc to remove tremolite and the practical degree to which removal can be expected. Dr. Speil to also be consulted in this connection. e. Medical evidence to refute carcinogenic aspects. Dr. George Wright will conduct this study as an independent project. HHJ will notify. Included will be consideration of the Blaegher and Arlon article, Kleinfelt studies on the talcosis in talc workers, consideration of LD 50 or other animal studies at the Hazelton Laboratory, information that may be available through and with the National Institute of Health, and any other areas of consideration. 3 Further action and thoughts for action: a. A meeting is suggested to include Dr. Wright, Dr. Speil, R. S. Lamar, EBS and HMJ to explore various medical, physical, mineralogical, and practical aspects of this FDA proposed regulation. HMJ will schedule this meeting as soon as Dr. Wright returns from Europe and that it can be coordinated with all other interested parties. b. HMJ suggests that we can reserve the studies concerning lethal dosage (LD) evaluations or the usage of the Hazelton Laboratory at Falls Church, Virginia, for an extension beyond the sixmonths period, if necessary. In other words, these studies may require more time than initially proposed in this request for postponement, and such studies could be beneficial subject further consideration by Dr. Wright and Dr. Spell. c. It is further suggested that Mr. Frank Gunderson, a former technical director of Quaker Oats Company, and currently a consultant to Brown Paper Company, may be considered at a later date for assistance with the FDA presentations or hearings that may develop from these studies proposed at this time. d. NBS, EBS, RSL and WCS to consider internal or external means by which studies can be conducted concerning plastics and coatings migratory tests. NBS suggested the Polymer Laboratory of the University of Akron will be a candidate to conduct these studies. Battelle, McCrone & Associates, D. H. Litter Laboratories, and others may be considered. These matters to be discussed at the proposed conference for Research and Development October 12 in Denver. CRMC-MAD-000894 n. OSHA REGULATIONS PART 1910 CONCERNING TREMOLITE AS RELATED TO ASBESTOS FIBERS A. RECLASSIFICATION OF TREMOLITE: EMF expressed firm opinion that we haven't got a prayer concerning establishing a variance or amendment to the OSHA regulation with respect to tremolite. It is true that we are "damned by association" because there have been no studies to present medical evidence concerning actinolite or tremolite in the matter of mesothelioma. The cases developed concerning talc workers (Vermont and New York State) concerned talcosis. This evidence was comparable to silicosis documentation and the studies covered a similarly long-term period of three years or more. However, since mesothelioma was not known or defined in those prior years, no evidence was developed relating to this condition. Furthermore, EMF and HMJ report that amosite and crocidolite have proven causative to mesothelioma. Both these materials have a "fibrous" nature that is similar to tremolite. The electron micrographs exhibited in a symposium of papers presented to the Canadian Institute of Mining and Metalurgy and reprinted by the Quebec Asbestos Mining Association "1958" exhibit this charac teristic on pages 21-23 comparing amosite, crocidolite, and tremolite. Thus, HMJ expressed the opinion that an attack on "fibers"delineated from tremolite would be a long-term study. Tremolite was not separately identified in the OSHA hearing, so evidence would have to be developed to disclaim tremolite functioning as an asbestos mineral. There appears to be no area of attack by reclassification of tremolite through mineralogical or structural definition. Any approach to disassociatlon will require medical evidence. MEDICAL EVIDENCE: Since there.may be a key medically, it is proposed that the services of Dr. Wright and Dr. Speil be enlisted for suggestions on a literature search and medical studies that could be developed. HMJ will determine when Dr. Wright will be available and EMF will determine when Dr. Speil will be available. A meeting is to be called at the earliest opportunity to explore this approach. EBS will also explore any information that may be available from California mining-and/or insurance records related to exposure in California talc mining operations. TALC INDUSTRY ASSOCIATION: To date, the Talc Industry Association has been ineffective. USD and Pfizer have declined to participate. RTV has been the only active member in calling the meetings and in conducting exploratory studies in this area. International Talc has attended the meetings, but apparently have made no contribution. The other talc producers attending have similarly been inactive. The only area of interest that RTV has developed concerns EPA at' Durham, North Carolina, regarding a proposal to exclude talc from the regulations and consider only "commercial asbestos" for environmental control. EMF considers this information will be no help to OSHA because of dissimilarity of interest and incompatability of the organizations. It is concluded that we CRMC-MAD-000895 -> rial ' 6 - should attend future meetings and be guided accordingly. In view of the fact that New York State talcs are considerably more tremolitic than California talcs; it should be considered a caution in all meetings that we should avoid a direct classification with New York State talcs. Our percentage of tremolite in all of our products is lowered, which we consider "residual", and any usage conditions should be considered in this context. III. MARKETING PROGRAM WITHIN EXISTING OSHA REGULATION A. COMPETITION: New York State talcs (RTV and International) are tremolitic. California talcs (USD, Pfizer, RTV) are semi-tremolitic including some grades at very low to nil tremolite content. Montana talcs (USD and Pfizer) are tremolite free. Accordingly, our competitors are directing their marketing program in this pattern. RTV has submitted to the trade a statement attesting that their talcs conform to regulations under usage conditions. USD and Pfizer are advising their customers similarly and, in fact, with considerably greater strength because of their Montana talc characteristics. B. FIBER COUNT IN USAGE "AIR-BORNE CONCENTRATION": I. EBS memo September 20 re Use Tests at Lompoc: EMF discussed memo in reference response from Dr. Speil. Answers to questions posed from page two by items as follows: Item 1 The fibers in the fiber count reported were not evaluated as to whether they are truly tremolite. They are truly fibers according to the fiber definition of 3/1 size ratio. It is not known if they are truly fibers of tremolite. Nontremolitic particles of a fibrous shape are not counted. In other words, these comments indicate some uncertainty as to whether the fibers counted are truly tremolite. In view of further uncertainties of the test, it is suggested that these tests be rerun and further monitoring of the nature of the fibers be conducted. Item 2 The order of testing was G-l, G-2 products, and White Eagle products. Apparently there was cross contamination in the tests which distorted fiber counts from lower level tremolitic materials into an abnormally high-count range. Retesting will eliminate this hazard. Item 4 Variation between Finderne and Lompoc counts explain by procedures and location of millipore filter mounting location. Again, retesting is indicated. CRMC-MAD-000896 *ki - 7- Item 5 Ambient air value should not be deducted since measurement of fiber count in usage is the .criteria. Item 6 Variances are significant enough and too short to be considered unreliable. Retesting is indicated. Item 7 A maximum 10 fibers should be applied to this data as well as additional data on studies that are of short duration. Item 8 Concerning developing an official statement, see Item III D, below. 2. Customer environmental testing: Sinclair Paint test results reported per memorandum submitted to committee by EMF, dated September 26, 1972, written by Kenneth Williams and directed to G. L. Swallow. Report indicates neither USD Fibrene C-400 nor DESERTALOS 54 conform to the maximum fiber count of 10 fibers per cc; although USD products just slightly over limit and DESERTALC 54 2\ to 3 times over the limit. Customer will react that C-400 is close enough with proper ventilation, but what does DESERTALC 54 do? This reaction was later verified in personal call at Sinclair Paint by EBS on October 6 , 1972. Further tests again indicated. BAG LABELING: HMJ states OSHA citation concerning inadequate or improper labeling can result in a'fine of a minimum of $600 and possibly up to $1 ,000. Our position concerning studies in progress could be a mitigating factor to avoid a citation, but this is problematical. PAM suggests changing the wording to "asbestos-form." HMJ reaction that the only official and acceptable wording is that as described in the regulations, and that any deviation therefrom could be damaging if considered in terms of willful violation of the law. In this context, no statement during our investigation would be better-than a misstatement. Therefore, since it is felt from the fiber counts determined to date that our talcs will conform to OSHA regulations when used under appropriate manufacturing conditions, that these studies should be continued and completed as soon as possible before the final decision is made concerning bag labeling. See statement below concerning proposed marketing statement. OFFICIAL MARKETING STATEMENT: The following statement was drafted jointly for consideration by all parties and legal counsel concerning usage: 1. "Under normal conditions of manufacturing with adequate dust control as required by OSHA regulations, our DESERTALCS and CRMC-MAD-000897 n jO C 8 - CYCLONIZED products will comply with the OSHA maximum allowable fiber levels." EBS will put this statement into a letter form and submit to P. A. Martinson for channeling for official approval. HMJ also commented on the regulation that the requirements of special clothing, two lockers for clothing exchange, etc., are not required if the products are used in conformance with OSHA regulations. However, HMJ stated that the periodic medical examinations are required for any exposure to asbestos. EBS to obtain an official statement concerning this application of the regulations. E. CUSTOMER ENVIRONMENTAL USAGE ASSISTANCE; To be further considered as marketing requirements dictate. Immediate action required on Sherwin-Williams proposal for testing. EMF will have Braram in San Francisco contact Sherwin-Williams to schedule testing for both asbestos and DESEKTALC environmental usage at the Oakland plant. EBS will secure costs from Jack Garber for further consideration of handling with the customer. EBS follow up and develop future policy for customer environmental assistance. IV. CONCLUSIONS AND PLANS OF ACTION A. FDA PROPOSED REGULATIONS*1 Follow-up postponement of October 12 deadline and investigations of all items programmed to redefine proposed regulation per I, Item 1 above. OSHA REGULATIONS: 1. Pursue potential medical studies in conference with Drs. Wright and Speil intended to establish variance or amendment to regulation per II above. 2. Develop official marketing statement (EBS), for customer re usage of our products under OSHA regulations. 3. Schedule new series of tests at Lompoc under the following * conditions: a. Use peak tests only. b. Three tests each product at 12 bags each test. c. Evaluate competitive product (C-400). d. Test each material one day apart to eliminate cross contamination. e. Change monitor each cycle. f. Utilize ventilation conditions. g. Test the following samples: DESERTALC 54, DESERTALC 24, DESERTALC HI-PURE 144, CYCLO-FIL, CYCLO-SORB, USD C-400. h. EMF department to define test program to Lompoc; EBS ship materials to Lompoc and coordinate schedule of test program CRMC-MAD-000898 - 9 - A. Bag labeling Labeling decision pending teats at Lompoc and customer usage study. 5. Customer environmental usage assistance Develop marketing program after Sherwin-Williams Tests. 6 . New products program Meeting scheduled at 3 p. m. October 12 for Research and Development program to consider modification of products for entirely new approach to OSHA problem (attending WCS, RSL, NBS, HRK, and EBS). EBS develop agenda in consideration following general outline: 1. Pellets 2. Slurry 3. Binder for industry usage (paper, paint, plastics, rubber, etc.) 4. Beneficlation 5. Any other approach Earl B. Smith - Sales Manager i EBSttjf I ft I 4 I CRMC-MAD-000899 R. T. V A N D E R B IL T C O M P A N Y . IN C . 3 3 W INFIELD STR EET CAST NO RW ALK,CONNECTICUT 0 0 6 5 5 H U G 2 1 1572 CAILC ADDRESS IUTV A N N E W V O M * August 17, 1972 Mr. William B. Reitze Johns-Manville Corporation 5680 South Syracuse Circle Denver, Colorado 80110 Dear Bill: Enclosed are copies of two form letters which we will use for certain of our customers regarding the tremolite situation. You may find these of help. Sincerely yours, R. C. Bacon, Director Research & Development Division RCBsmjh Enclosures '( S - 4* H-- wnrfriOBi far afcuriwUn.1rbmd port>t t f w dlob Ho w --dono!yutctrtm tflu lu tobCtuinoi CRMC-MAD-000900 REPLY TO CUSTOMER INQUIRY RS TILE EFFECT OF THE.ILLINOIS POLLUTION CONTROL BOARD'S REGULATIONS FOR ASBESTOS DUST __________________ ON THE USE OF VANDERBILT TALCS In answer to your letter of , we have determined that about one-third of our NYTAL talc consists of the mineral I tremolite. Although the overwhelming percentage of tremolite in our product ia of the non-fibrous type, particles can be found whoso length to breadth ratio is 5 to 1 or greater, thus putting them into the category of a fiber as defined by the Illinois Standard. Since our NYTAL ores are not mined or used as asbestos, we N take issue-with the Illinois Pollution Control Board, both in the definition of an asbestos fiber and the inclusion of tremolite per se as asbestos. At present, ,it is our belief that the existence of tremolite in our product does not constitute a mineral dust exposure hazard greater than that of non-asbestiform talc. Ibrthermore, although an exact determination has not been made, we believe that the content of so-called "fibers" in our product is low enough to present little or no inconvenience to the user in complying with' the Illinois Standard limit for ambient air of two fibers per cubic centimeter of air. ; 8/15/72 y ; i i CRMC-MAD-000901 t V Po le ! REPLY TO CUSTOMER INQUIRY RE TALC AND ASBESTOS _____ FOR OGiiA ASBESTOS LUST REGULATIONS of our In-reply to your recent inquiry concerning the r ; , j it has been determined that ___________ content NYTAL -- about one-third, NWESTAL -- a small proportion t I consists of the mineral tremolite, most of which:exists- in tho form of l nodules, rods and plates. To the best of our. knowledge, there are no ! asbestos fibers in our talcs according to the .definition of a fiber as a soft, threadlike object that has a length usually many hundred or thousand .times greater than its width and that possesses considerable tensile strength, According to the Occupational Safety and Health Act standard dealing with, asbestos dust, tremolite has been lumped into the category of asbestos. However, we axe in-the process of gathering evidence to refute the governmental contention that tremolite per sc is asbestos and therefore governed by asbestos regulations. When we have accumulated sufficient data, we plan to petition for an amendment to tho standard, so .'that tremolite may be classified with other mineral du3ts. We would like to call your attention to the fact that neither the asbestos dust standard nor the original air contaminant standard of the Occupational Safety and Health Act prohibits the use of tremolite-containing dusts or any other dust-producing mineral. Both standards do, of course, regulate air quality in the workplace, so that adequate dust control measures must -be taken no matter what dusts are involved. * > . We would be pleased to discuss this matter further with you, should you. so desire. \ , \ ) : '!. . C R M C -M A D -0 0 0 9 0 2 Juno 21, 1972 Mr. G. L. Fiederlein R. T. vandarbilt company, Inc. 230 park Avenue N e w York, New York 10017 Dear Mr. Fiederleint Enclosed is johns-Manvilla check, in the amount of $300.00, for expenses in connection with the talc producers* group, as requested in Mr. R. C. Bacon's letter of June 6, 1972. Sincerely, P. A. Martinson Vice President General Manager enclosure BC: H. M. Jackson W. B. Reitze E. M. Fenner C CRMC-MAD-000903  y ,. *". RFQUEST CASH PAY TO: FOR CHECK G. L. Fiederlein Form 3-90 fid . in U. 5. A. IN PAYM EN T FOR (CIRCLE ANY PORTION OF EXPLANATION TO EE SHOWN ON CHECK VOUCHER) date__ June 20, 1972 .CHECK n o _______________________ $300.00 Talc Industry producers' Survey Please send check to Kay Silverman - 2nd West for transmittal with covering letter VOUCHES NUMBER C01004 ACCOUNT NUMBER OTHER COOES AMOUNTS CORRECT APPROVED CASHCR TOTAL RECEIVED CASH PAYMENT- $300.00. CHECKS ARE ALWAYS SENT TO PAYEE. IP THIS CHECK IS NOT TO SENT TO PAYEE, GIVE NAME AND ADDRESS AND STATE REASON. CRMC-MAD-000904 CABLEAODRCSO ILTVAN NEW YOfll* ifPWPSPSPWP Mr. Peter McCarthy, International Talc Company, New York, N. Y. Mr. William Stephenson, Pfizer, Inc., New York, N. Y. Mr. Alan Dankworth, Engelhard Minerals & Chemicals C o r p . , Edison, N. J. Mr. Peter Bixby, American Talc Company, Summit, N. J. Mr. Carl Klaus, American Olean Company, Lansaale, Pa. Mr. L a rry Dr.Lsco.ll, Whittaker, Clark & Daniells, So. Plainfield, N. J , Mr. Norman Schoffel, Desert Minerals, Laguna Beach, California Mr. William Reitze, Johns-Manvilie Corporation, New York, N. Y. Mr. H. B. Vanderbilt, R. T. Vanderbilt Company, Inc., New York, N. Y. Gentlemen: I have been asked by the talc group to write you and request that you prepare and have ready for shipment representative samples of at least five pounds each of your crude ore or ores (if you have different types) as well as of your major talc products. As you will see from the copy of the minutes you will receive from Alan Dankworth of Engelhard, several company representatives indicated the possibility of cooperating in gathering extensive mineralogical data on the different talc ores for use in our dealings with the authorities in Washington and in the various states in connection with health and safety and environmental regulations. It is agreed that the data developed from these samples will be open to all the members of the talc group who contribute to it financially. It is further agreed that this data will not be available to anyone else without written permission from the particular company involved. Portions of the samples if needed by others in the group for mineralogical testing not available at the above two laboratories would be sent to the particular company laboratory in question under the same conditions. The above can be discussed further at our next meeting scheduled for June 15th at 10 A.M. in the Vanderbilt offices. Sincerely yours, R. C. Bacon, Director Research & Development Division The neommendeborofor use ofour meteneb ere based Hm CRMC-MAD-000905 m do not 5ueranu the results to be obtained i h m i k Ah m m h m a m , He;: y&rk Jena 2, l/,72 H. H. Jackson, 5>vr. P, A. uirtinucn, Dvr. TA7,c r.ionjcnari k h ;:t i h g juiu: 1 <-n l, l':72, at 2:0') P.M. a neeting va3 held la thfi office of A. T. u 0; iuc., 2DJ Park Avenue, Acw York, . Y. The following people vc.ro in attendance: Ur. Peter McCarthy, Motac. V.P. International Talc Company Hr. Robert McCarthy Infcernaticnai Yale Company Mr. Alan J. Dankworth Product l.iiHus'trial Products Engcltwru Minora la A Chersicala Corp. Mr. Lawrence Driscoll, President UhlCtahe::, Clark Daniciia Mr. Ksrrvuv Schcffel, V. P. V ' Technical Service Dosert Miueralo lir. R. C. Pec on, Director Research R. T. Vanderbilt Company, Inc. 4'r. Paul Ti, nlbnoy> Attorney Davis7^ei`iTSTC7-Xirvine & Schwarts Tho group was of the opinion that they would remain as ft loo.3e.ly-forned organisation until such tine as it boenvo necessary to incorporate. Several points v:ero discussed. 1. There will probably be 6 to renbers including International Talc Co.f Pfiocr, Inc., Engelhard Minerals A Chemicals Corp., Whittaker Clark U Daniolls, and Desert Minerals (J-li). ___ **s 2. The cost cf becoming a r-cubcr would bd^$300 per J.rrt.'> It was felt that this amount ot money from each provide enough funds to tiiuke preliminary investi '.nticas. Vhsae.prcliviir.ary investi gations would then lead to a cu>ce positive course of action far the group. CRMC-MAD-000906 3. A rroatln is tentatively planned .tr.a 15. 1072 at which tiro the group or committee w ill a n t wlf:a"T*;ffCpv.yStSlscs to dlseusa talc, and it s associated health r r'n>le*.-.<. :oi three physicians are G. /. L-dicporo, M.D., I>r. yjoinfclt of the. I.'ow York State group, and Dr. /fii.r.gcrrtf'.n of the University of Pennsylvania* T.t la h>pad tSial these physic.Inns will be obi9 to advise the group o? possible {*?-.>:-1era no well an 3a': :est stud lea Chat could bo under taken to refute ti'.o existing, uedlcai evidence* A. A plan v n also advanced to have sovcrTl of the ccinber companies, namely, Vanderbilt and lingciliard undertake analytical) studios on both crude- and products* I the r-.vaup that outf reaoureh lob w ill bo In the process of moving-end their help night be soaewhat llwltcd, Thera are several things wo rruat ennoitier. First of oil, this group is o u i i ratluir intent uatpr w i nsjto G^- :A people, tiiatt Treraollto is (rean .buutisoe nineai. inl9 -concept" eccKts contrary to every knownocsct written on tiio subject. - I a.i u,t personally acquainted with any of tha physicians. Ur. Kleinfolt certainly has o good reputation and it is vy undcratending that ho is still coutreotvd with a state agency. Dr. hiiiv.cr,ian la a dermatologist end would be of limited value in pulmonary'work, khe attached CV for I?r. chepers is rather impressive* Foyeycr, the also attached reprint leaves much to bo desired. $incc\fk;r. Gubc-pcr# lias spent 3oaa tine at daranac Lake, perhaps George Wright cc^ cT c v 2Tu2 uq hia uuefulucaa in this area. \ The one decision which must be made La fore June 15, io whether J-ii wants to continue to participate at a coat of $300. It is ay reeoraaecdatier that \:c participate in this group fit least until tliey are able to better define their goals. / CRMC-MAD-000907 vi- x,, 'VanDarbeak MEBVXM3 OF ALO PRODUCERS w. B. Rcltze*s tettar of Aprii 28, 1972 to H. M. Jackson The writer has reviewed with B* M Fenner subject report. It was agreed with Mr* Fenner that nothing further would be done prior to the neatnoaHttg of the group in the r . T. vandexbiXt offices in* York City early in June. I a giving a copy of Hr Rsitse'a report to A B.Marchant For Mr. Reitee* infornetion*l believe,that the natter of consideration and follow^g p cnenvironeantal-control, "duet OTRtrol, workmen's ooapinaatlon, etc; 'heve -been*initiated '' with nr. Marchent*,peo0lhi/e|dMieiwork,that hai been initiated will be cloeiy followed. p . A . Martinson CCS H. M. Jackson w. B. Reitze H. it. -Fanner T. M. Jackson H. Kranich A. B. Marchant D c w/attaclMsnt -* CRMC-MAD-000908 pp . r . t P o l;c r M cC a rth y, E x e c . V . P. : n t u r n a t io n a i Talc Company .'0 L e x i n g t o n Avenue ~ "" . r.v Y o r k , N. Y . 1 0 0 1 7 r. Frank X ilchi.. ;f e r r a t i on aI Talc C o m pany '"20 Lexington Avenue ^ Y o r k , N . Y. 10017 As.. R o b ert M cCarthy IA l t e r n a t i o n a l Talc Company. k0 L e x i n g t o n Avenue e w York,`w. Y. 10017 W illia m Stephenson : re c to r o f M ark e tin g . P.l. J liy is io n ' i t e r .,.,...I n c .... ' if Mast 42nd Street v Y o r k , M. Y . 1 0 0 1 7 r/Mr-.--Lawrence "Dri-st:o-]rl Whit t a ko r , Cl a lk &...Daniel 1 0 00 Cooiiclge Street So. Plainfield, N. J. 07080 Mr. Frank Zimmerman 25 Delaware Avenue Buffalo, Mew York M r . E a r l Smith, Exec. V. X Desert Minerais. 1891 South.Coast Highway Laguna Beach, California 92651 Mr. Norman Scheffel, V. P. Technical Service Desert Mi n erals'"! 1891 South"Coast Highway Laguna Beach, California 92653 kr. Alan J . Dankworth r o d u c t . M anager.,,. I n d u s t r ia l . P ro d u c ts laigelhard .M i n e r a l s .. &. X h e m i c a i s ^ o r p X .".'nlo Park Edison,' N e w Jersey 08817 'age Gcntch. s ite d S ie rra D iv is io n fV p rt^ Je in o C o rp o ra tio n ^ A5 0 S co to f i "R o ach------- - -- '.'s e n t on, New Jersey 08 628 Woodward Glenn. c Southern Talc Company inTSftgWrth', Georgia _E r. Peter Bixby__ A: orican Talc C ompany^ S iH S u A t," New" J ercey ^Donald 7ice President X^~7mrican Talc Company" STMtuti N e w T r s e jo^Mifierals lT ). O . B o x ^ S jQ__ _ Windsor, Vermon-~'-05080 Mr. William B. Reitze, Manager Accident Prevention & Health Admin istration--i J m &s-Manville Corporation 270 Madison Avenue New York, N. Y. B . Van de rb i-11 Exec. V . F R. TM "Vander It Company, _Inc'. 230 Park Avenue New York, N. Y. 10017 .Mr.._R..__C. Bacon T. Vanderbilt Company, InC 230~ Park~Avenue New York, N. Y. 10017 M r . Paul B. Gibney, A t torney Davis, Gilbert, Levine & Schwarts STKT'Fifth Avenue- R. T. V A N D E R B IL T C O M P A N Y , INC. 33 W INFIELD STREET EAST NORWALK.CONNECTICUT 0 6 8 5 S April IS, 1975 CAtLC AODHCSI ILTVA N N C W Y O R K Mr. Richard Carter Counsel Johns-Manville Corporation 5680 South Syracuse Circle Denver, Colorado 80217 Dear Dick: Paul Gibney asked me to send you our latest revision of the FDA talc comment. Attached are all documents except the hook of microphotographs and Dr. W. E. Smith's report, which I believe you already have. Very truly yours, R. T. VANDERBILT COMPANY, INC, AMHrsb Enclosure Allan M. Harvey, Manager Patent and Legal Liaison Department 3 -, CRMC-MA D -0 0 0 9 10 A lan T. Chief, _GRAS Review Branch Division of Petitions Processing Bureau of Foods 200 C Street, S. W. Washington, D. C. 2020*1 Dear Mr. Spiher: We are sending you the attached documents pertaining to the "Proposal Regarding Regulation of Prior-Sanctioned Food Ingredients" ( 3 7 F-P- l6 * .0 7 ) at the request of Dr. Corbin Rories, with whom we have been in telephone contact regarding our petition for an extension of time for comment. We sincerely appreciate the opportunity to elaborate on the question of possible health hazards of industrial talcs. It is important that the true medical and mineralogies! facts of the situation be known and well understood. In the discussion preceding the proposed talc amendment it is stated that it is prudent to require that talc which is to be used in the manufacture of food and food packaging be free of "asbestos-form particles". Certain medical reasons for this .judgment axe given. O u r studies of talc have shown that great care must be taken to define the term "asbestos-form particle" in order to avoid a prejudicial attitude toward the majority of the industrial talcs sold today, especially when so little evidence of physiological harm has been exhibited. It is true that no firm mirieralogic definition of commercial talc exists today, but the majority of talcs that are useful in food packaging materials ccnsi.st essentially of the two minerals, talc and tremolite. Talc mines almost always contain a wide variety ,of silicate minerals, some of which are considered asbestos, as defined in the'discussion to follow. When true asbestos minerals are present, It is often possible to selectively mine the talc portion of the orebo without GX"b2T3.C't>a.n| wilG .S^3vC3 u3.nOjTaJLS; cLTIcI. "fcilXG XS wGXHgJ uOuc* The tremolitic talcs used In food packaging materials can be considered to be truly free of fibrous particles, and therefore, by inference, free of hazard in the particular context under discussion. What has confused the issue, both here and in the reasoning behind regulations promulgated by other government departments, is the peculiar placement of the mineral tremolite in the category of asbestos. Unfortunately tremolite has been portrayed as a fibrous mineral more as a result of its similarity in chemical composition to true asbestos minerals than because of any similarity in physical" form. A study of the attached set of photomicrographs and a consideration of the following interpretation of asbestos mineralogy will prove that tremolite shSfeld be categorized as asbestos without some sort of qualification such as "tremolit asbestos" or "fibrous tremolite", with the true meaning of "fibrous" and "asbes properly defined. TH TK3r~ m ixxm teruset 'cm*.-a-j'j j t bsd tpen 431 trA sc ;:<5 na z ^ n -je CRMC-MAD-000911 re*. 3 3 :< `j- -4m0^ R. T V A N D E R B IL T C O M P A N Y*, INC. Mr. Alan T. St>iher, Jr. 3 - April 17, 1973 non-fibrous varieties of the other asbestos minerals, i. e. antigorite, riebeckite and cummingtonite from the asbestos standard, that if special names had existed for the fibrous varieties of the remaining amphiboles, they would have been included as well, and anthophyllite, tremolite and actinolite would also have been omitted. ^ This distinction between the fibrous and non-fibrous forms of serpentine and the amphiboles under discussion, is substantiated by the references cited in Appendix A-l. The accompanying set of photomicrographs (Appendix A-2) illustrates conclusively the inaccurate placement of the mineral tremolite per se in the category of asbestos. It would make as much sense to include the minerals riebeckite and cummingtonite in the category of asbestos, since the shape and distribution of their crystal shapes are almost identical with those of actinolite, " tremolite and non-fibrous anthophyllite. If we turn to a consideration of the medical aspects of the talc situation, some light can be thrown on the reasons behind the indictment of talc as a suspicious mineral and tremolite as a "bad actor". As far back as 1953 Dr. G. V/. H. Schepers reported.on the effects of talc dust on the human lung in a study of tremolitic talc miners in Western New York State. Later, in the 19o0*s Dr. Morris Kleinfeld made epidemiological studies of talc miners and millers in New York State. Although their findings were not conclusive, and no scientific evidence of any carcinogenicity of talc per se was disclosed, they did throw a certain amount of suspicion on tremolite and talcs in general. Unfortunately, ; these studies not only have cast a prejudicial light on the question of biological response to commercial talcs, but have resulted in the lumping together of tremolite and the "fibrous" form of talc with dangerous types of asbestos such as crocidolite,' that have been proven definitely harmful. It was because of the uncertainties of various epidemiological studies;; that Dr. W. E. Smith, working in the Health Research Institute at Eairleigh Dickinsiiil University in Madison, New Jersey, embarked on a project to study the carcinogenicity' of various mineral dusts, using the hamster as a suitable, experimental animal model. A copy of Dr. Smith's report is enclosed as Appendix B. The tremolite talc (ylh) in Dr. Smith's project is a New York State talc containing 50$ tremolite, 10$ antigorite, 2 -5$ chlorite, and 35$ talc, with a median particle size of 8.5 microns. :'j A photomicrograph of the sample reveals the usual distribution oi. rodk., n.* plates and short acicular particles characteristic of New York State talcs. The lack of pleural tumors in animals injected with this talc is significant when a comparison is made with the results from animals injected with true asbestos. More recently, Dr. Schepers, now Chief, Medical Services, at the Veterans Hospital, Lebanon, Pennsylvania, has come forth with a new consideration of the relative hazards of various silicate minerals. Dr. Schepers has written a letter (see Appendix C) to Mr. R. C. Bacon, former Director of Mining Operations, R. T. Vanderbilt Company, Inc., in answer to a request for the chest sturgeon's latest! opinions on talc and asbestos in the light of all the investigations that have taken ,| place in this area since the early 1950's. You will note that Dr. Schepers applies hr, CRMC-MAD-000912 R .T. V A N D E R B IL T C O M P A N Y , IN C . Mr. Alan T. Spiher, Jr. -h - April 17, 1975 different ratings of hazard to each type of silicate mineral, and that tremolite comes closer to talc than to the true asbestos minerals. We find the some regard for the degree of hazard indicated in regulations concerning silicate and asbestos minerals in Great Britain, where experience with various forms of asbestos is probably greater and of a longer time period than any other industrial nation. It is not surprising that Dr. Smith finds a varied biologic response to different types, dosages and shapes of silicate mineral dusts, but it is surprising and unfortunate that hygienists and medical consultants in this country continue to disregard the wide differences in degree of hazard of the substances for which government regula tions are laid down. ' ' In conclusion, it should be stressed that a valuable, economic product is in jeopardy of being penalized for lack of adequate definition when no conclusive evidence of hazard has been disclosed. We maintain that the'tremolitefound in tremolitic talcs.is not asbestos and, therefore, no more hazardous than talc itself. However, unless-a realistic definition of the term "asbestos-form particle" is rendered, not only a great portion of the pure talc being sold today but also those talc products containing -even- the slightest proportion of thebaic-like mineral tremolite will be eliminated from food packaging-materials. It is even possible to foresee the elimination of all mineral dusts from the role of fillers and coatings for these materials if the term "asbestos-form particle" is misinter preted or stretched to include particles of certain shapes regardless of chemical W lU ^ V k )A V4,Vi Very truly yours, R. T. VANDERBILT COMPANY, INC. Allan M. Harvey, Manager Patent and Legal Liaison Department AMH: sb Enclosures P. S. In our original request for additional time in which to comment on the proposed; talc amendment, we referred to proposed studies of talcs by x-ray diffraction techniques. Considerable work was done but no meaningful contribution to the problem?, of defining "asbestos-form particles" was generated since this means of identification does not differentiate between asbestos-form and non-asbestos-form minerals. Howeverj since the proper identification of various types of minerals to be found in-talcs normally used in food packaging materials is critical, our opinion regarding a satisfactory method is expressed in the accompanying statement (Appendix D). CRMC-MAD-000913 R. T. V A N D E R B IL T C O M P A N Y , IN C . 1 - Appendix A - 1 Bibliography of As-estes Terris "In the mineralgica! sense the term asbestos is extended in part also other fibrous minerals, without reference to composition, structural constitutive properties, and technical-industrial significance. Two main groups are differ- ^ entiated with respect to origin, mode of formation, mineralcgical relationships, structure, composition, and properties of the asbestoses: namely, the serpentine! asbestoses (chrysotiles) and the amphicole asbestoses. The fibrous crystalline, variants of the minerals have in part been given individual names to which, in the interest of a precise terminology, the word asbestos must not be appended'. For example, the fibrous form of serpentine is called chrysotile, serpentineasbestos, or fibrous serpentine - but TOT chrysotile asbestos. The accepted names of the five asbestoses used commercially are given as follows: Group Designation of Mineral Designation of Asbestos Serpentine Asbestos Amphibole Asbestos Serpentine Riebeckite Gruenerite U-mhiboles Anthophyllite| Tremolite Chrysotile Crocidolite, Blue Asbestos Amosite Anthophyllite Asbestos* Tremolite Asbestos* *These varieties have no special designation." (Reference: Berger, Hans, trans. by Ralph Z. Osper, Asbestos Fundamentals Origins, Properties, Mining, Processing, Utilization Chemical Publishing Company, Inc., Tew York, 1963.) "Asbestos is the common name given to a number of inorganic, fibrous, silicate minerals that possess a crystalline structure. Chrysotile, the most abundant of these fibrous silicates ar.d the one most extensively used in industry, belongs to the serpentine group of rock-forming minerals and is mined ^ mainly in Canada, Russia, and Rhodesia. The other forms of asbestos belong to the amphibole group. They are crocidolite, commonly known as 'blue asbestos', which is found in South Africa; Western Australia and Bolivia; amosite which occurs only in South Africa; anthophyllite, the fibrous form of which is found " in Finland and Africa; and the fibrous forms of tremolite (available in Italy) and actinolite, which has been found in South Africa." <t,Ji "'Asbestos' means any of the following minerals, that is to say, crocidolite^ amosite, chrysotile, fibrous anthophyllite and any mixture containing any of the' said minerals." (Reference: Health and Safety at Work ^bk, Asbestos Health Precautions i n .lr.di Department of 'xhroloyaent, -HM Factory Inspectorate, United Kingdom/: 19T1.) *U A a CRMC-MAD-000914 R. T V A N D E R B IL T C O M P A N Y , IN C . Bibliography of Asbestos Teros -2 - fW-**{*.^^ Appendix A - 1 3. "Asbestos, 'amphibole' asbestos, 'hornblende' asbestos, and 'Italian' asbestos are various terms given to the monoclinic amphiboles, trenolite Ca2Mg5(SiB022 ) (OH,F)a and actinolite, Ca(Mg,Fe)2 (Si03 )4, when they occur in fine silky fibers. " (Rference: Ladoo, Raymond Bardeen, Non-Metallic Minerals, 1st Edition, McGraw-Hill, New York, 1925 Ladoo, Raymond Bardeen, and W. M. Ifyers, Non-Metallic Mdnerals, 2nd Edition, McGraw-Hill, New York, 1951*1 "Actinolite. Calcium-magnesium-iron amphibole..... In crystals, either short- or long-bladed, as in tremolite; columnar or fibrous; granular massive... The fibrous and radiated kinds are often called asbestiform actinolite and 'si radiated actinolite.....ASBESTOS. Asbestos. Tremolite, actinolite, and other _v varieties of amphibole, excepting those containing much alumina, pass into fibrstfs varieties, the fibers of which are sometimes very long, fine, flexible, and easier separable by the fingers, and look like flax. These kinds are called asbestos (from the Greek for incombustible).... CROCIDOLITS. Blue Asbestos -- Probably to be considered as a fibrous variety of riebeckite. Fibrous, asbestos-like; \ fibers long but delicate and easily separable." h (Reference: Dana, Edward Salisbury, A Textbook of Mineralogy with an Extended Treatise on Crystallography and Physical Mineralogy, John Wiley a Sons; Inc., New York, 1 9 W * ) tJ *#*** ` `4 "Serpentine occurs in two distinct forms: (l) a platy variety, antigorite,- which conforms in its properties to those of the phyllcsilicates, and (2 ) a fibrous variety, chrysotile."..."The variety chrysotiie is the chief source of to asbestos. The uses of asbestos depend upon its fibrous, flexible nature, which allows it to be made into felt and woven into cloth and other fabrics, andupon - its incombustibility and slow conductivity of heat. Asbestos products, therefo: are used for fireproofing and as an insulation material against heat and : electricity. Massive serpentine, which is translucent and of a light to dark green color, is often used as an ornamental stone and may be valuable as building^; material." ' '* (Reference: Hurbut, Cornelius S. Jr., Dana's Manual of Mineralogy, l8th Edition,John Wiley & Sons, Inc., New York, 1971.) "Aoosite: A commercial tern for an iron-rich, asbestiform variety of , amphibole occurring in long fibers. It may consist of an orthorhombic anphibo (anthophyllite or gedrite) or of a monoclinic amphibole (cumningtonite or grunerite)." . CRMC-MAD-000915 R .T V A N D E R B IL T C O M P A N Y , I NC. Bibliography of Asbestos Tenas Appendix A - 1 "Asbestos: A commercial term applied to a group of highly fibrous silicate J minerals that readily separate into long, thin,, strong fibers of sufficient flexibility to be woven,.... certain fibrous varieties of amphibole..." "Crocidolite: A lavender-blue, indigo-blue, or leak-green asbestifora variety of riebeckite, occurring in silky fibers and in massive and earthy forms.'! Syn: Blue asbestos: Krokidolite." (Reference: Gary, Margaret, R. McAfee, Jr., and C. L. Wolf, Glossary of Geology, American Geological Institute, Washington, D. C., 1 9 7 2 . ) "Riebeckite also occurs as an extremely fibrous mineral, when it is known as blue asbestos or crocidolite. The best known occurrences of blue asbestos are in South Africa where it occurs in bedded ironstones, the seams of crocidclite.-! conforming to the bedding of the ironstones. The composition of the crocidolite is remarkably similar to tnat of the ironstone and the crystallisation of the amphibole, initially in the: form of massive riebeckite, occurred with little or ' no addition of material under conditions of moderate temperature and pressure consequent on the burial of the ironstones to moderate d e p t h . " B o t h Peacock < ( 1 9 2 8 ) and Hall . ( 1930) favour the hypothesis that i:& s 0 was originally uniformly distributed throughout the ironstone end subsequently concentrated in certain bands. The later transformation of the massive riebeckite to the fibrous crocidoll may result from the instability of the riebeckite during a period when the iron-M|| stones were subjected to shearing stress.".... The members of the cummingtonite- 'S| grunerite series are typically found in both regionally and contact metanorphosed|f rocks. The more magnesian members are found also in some igneous rocks, including those of' hybrid origin. The asbestiforn varieties amosite and m.ontasite are of '.I economic importance.".... "The characteristic habit of the members of the cunning-lgl toraite-grunerite series is acicular or fibrous. The asbestiforn variety, ?mositB when fresh is ash-grey in colour; the mineral, however is frequently coated with iron oxides, when the colour is brown to yellow. The fibres of the mor.tasite variety are less harsh than amosite and are often soft and silky in texture.".. "The habits of the anthophyllite minerals vary from fibrous and asbestifora to bladed and prismatic. The fibers of anthopyllite asbestos generally do not have any great tensile strength and are of less economic importance than the amosite and crocidolite fibres.".... "Mass-fiber anthophyllite asbestos occurs as a replacement mineral in ultrabasic rocks at Ksmiah, Idaho (Anderson, 1931)." .... Laudernilk and Woodford (1930) have described an ascestifom anthophyllite in veins in serpentinite at Coffe Creek, Carvill, California." (Reference: Deer, W. A,, R. A. Kowie, and J. Zussman, Rock Forming Minerals, Volume 2, Longman Group Ltd., London, 196371 -*?j CRMC-MAD-000916 .ri ggs$#sfe "R .T . V A N D E R B I L T C O M P A N Y , I N C . I Bibliography of Asbestos Teres -b - Appendix A - 1 Jj i ` 8. "The principal minerals of the serpentine group all have the approximate m i composition H^-gsSisOs, and comparatively little substitution of other irons is found to oGcuu- in natural s p e c i m e n s * T h e m o s t v e i l K n o w n serpentine mineral, chrysotile, often occurs in veins of silky fibers and is the most important source of commercial asbestos. " (Reference: Deer, W. A., R. A. Howie, and J. Zussman, Rock Forming Minerals, Vol. 3, logmans, Green and Co. ltd., London 1962.) * * * * 9. "Mineralogically, asbestos includes the fibrous forms of amphibole; the fibers are generally verylong, fine, flexible, and easily separated by the fingers; the color..... The term asbestos in the strictest sense is confined to the fibrous forms of actinolite, but the asbestos of commerce includes fibrous varieties of a number of silicates...." (Reference: Read, H. H., Eutley's Elements of Mineralogy, 25th Edition, Thomas Murby & Co., London, 1955*) * # * # 10. "Tremolite dees not break down into fibers that approach a uniform rectangula cross section, as crodidolite does. Two samples-(figs. 9 and 10) indicate that the fibers break'into fragments. Seme of the fragments axe quite thin, while others are rather thick. The fragments are composed of thin sheets. Some of the small sheets (fig. 9 ) are so thin that they are almost translucent to the electron beam. Dark streaks axe again noticeable in the thin sheets of tremolite, as they axe slightly wrinkled for Bragg reflections. The thin sheets axe probably less than 100 A. in thickness." "Actinolite is generally considered the basic amphibole asbestos member. The fibers of actinolite axe quite poor; and, because it rarely has commercial value, it is not very well known. The sample examined was splintery and very brittle. It was not expected that the mineral would break down into fibers for electron microscopic study, but we felt it worth the effort to try, since it is the basic member of the amphibole group. Figure 11 reveals that it did not break into single fibers. Low magnification was used, as the material broke into large, opaque pieces." (Reference: Huggins, Charles W., Electron 1-S.crographs of Asbestiform Minerals, Report of Investigations 5551, Bureau of Mines, U. S. Department of, The Interior, 1959*) * * * # * 11. "The name 'asbestos' is used to describe any mineral that breaks down into fibers when it is crushed or processed." |I8 | c ,i, VVi 5 (Reference: ----- Gaze, Richard, "The Physical and Molecular Structure of Asbestos," ".:. Ann.. N.Y. Acad. Sci.,Art. 1, 152, PP- 25-50 1965.) * * * * * ... CRMC-MAD-000917 :> ' 7~~TT>, r^i-- ------ ___ R.T. V A N D E R B IL T CO M PANY, IN C . Bibliography of Asbestos Terms -5 Appendix A - i "Asbestos: 'Asbestos' is the name given so a group of hydrous magnesium silicate minerals which have a fibrous texture. The crystal structure of these minerals is characterized by the presence of long chains of silicate tetrahedra which can be readily cleaved in directions parallel to the silicate chains but'' not in directions that cut the chains, with the result that these minerals can be shredded into fibers..." (Reference: Kingery, W. D., Introduction to Ceramics, John Wiley and Sons, Inc. New York, 1963*) 13. "Asbestos is not a distinct material but a commercial term used to express the fibrous nature of several minerals." (Reference: United States Bureauof Mines, Foreign Minerals Division, Mineral Raw Materials, p. 16, McGraw-Hill 3ook Company, Inc., Hew York, 1937.) 14. "Asbestos, any of several varieties of fibrous minerals whose fibres may be spun or. felted to make fabrics, panels, or coatings that are resistant to heat and chemical action. Asbestos is also valued for its electrical insulating! properties." (Reference: Colliers Encyclopedia - 1972.) 15. "Asbestos, general name for a group of silicate minerals that occur as fibers or fibrous masses and that can be woven into heat resistant materials. The fibers are separated mechanically and pressed, spun, or woven, often with ` cotton, wire, rubber, or cement, to produce fireproof articles of all types: clothing, curtains, electric cable insulation, brake linings ana clutch facings, insulating boards, sheets, shingles and talcs. " , 16. "Asbestos is a fibrous mineral substance... In its natural state, asbestos is found encased in rocks. Its fibrous quality,; makes it a remarkable mineral. Asbestos is as dense as the rock in which it is encased, but it is a mass of tiny fibers that become as fluffy and light as thistledown when separated mechanically from rock. - (Reference: Encyclopedia Americana - International Edition - 1959.) CRMC-MAD-000918 V5' riA APPE1H3IX C March 23, 1973 S. Lincoln Avenue Lebanon, PA 17042 R. C. Bacon Director, Research and Development R. T. Vanderbilt Company, Ino. 33 Winfield Street f East Norwalk, Connecticut 06855 Dear Mr. Bacon RE: Talc (0) Tremolite (IQ > Chrysotile (2+), Anthophyllite (3+), Amosite (4+), Crocidolite (10+) etc Thanks for consulting me about these items. As you know from my publications I have had considerable experience in decoding the biological action of the fibrous silicates. This is based both on elaborate inhalation experiments, human exposures with necropsy studies, and of course review of the literature. The order in which I have listed these fibrous minerals represents my interpretation as to their-capacity for inducing biological II responses. Talc is listed first and given a zero rating since it is.in pure form, practically innocuous except for overwhelming prolonged exposure. The latter is n o `longer permissible in the USA so, for practical purposes, this substance is harmless. Crocidolite, by contrast, is listed last and given a 10+ or maximal rating. It can with relatively minor exposure, produce exceedingly serious and progressive changes in the lungs or wherever it becomes lodged. One of these effects is the capacity to produce neoplastic disease. Talc, Tremolite and Chrysolite need to be discussed a little more fully. Pure mineral talc of the non-tremolite kind, does not induce a tissue response of any clinical significance. If there is prolonged exposure the lung aleoli and some lymphatics can trap ph a gocytic cells which ingested the talc particles and this may , block out their functions temporarily. This type of pathology i s called a thesaurosis or storage effect. It is usually reversable on cessation or decrease of exposure and no significant permanent after-effects result. The same applies for tremolite talc. It is inert.like Georgia talc.and induces only a thesaurosis effect when there is excessive^ prolonged exposure. However, Tremoli.te sometimes is "contaminated!' CRMC-MAD-000920 m R. C. Bacon larch 23, 1973 with chrysotile or other true asbestos type fibrous rierais. When this is the case, the thesaurosis becomes a thesaurismosis ie, the alveolar walls and perilymphatic tissues begin to react, and fibrous tissue forms. This is due to the asbestos fibers and not the tremolite component. The fibrotic response is directly proportional to the ratio of asbestos fibers admixed with the tremolite. You will note from one of my experiments that when small quantities of chrysotile were mixed with gypsum the chrysotile effect never -the less prevailed despite dilution with the inert gypsum. This sounds like I make chrysotile out to be a bad actor. It is true that prolonged exposure to chrysotile will produce asbestosis. but of a relatively mild kind. In comparison, however, with what Crocidolite does, Chrysotile is a relatively tame beast. There are a number cf persons currently making excessive propa ganda about Chrysotile. Their noise fends to drown out the voices of sanity. The hullabaloo will of course go on for some time. Progressively, however, the evidence is coming in that Chrysotile causes only a fine interstitial fibrosis without blocking off the respiratory surfaces. The patient develops some disability because of stiffening of his lungs, but can survive for a long tim with fairly good gas exchange. I have never yet seen a case of lung cancer caused by Chrysotile alone and no one else has ever been able to show me a case either. In mixed sequential exposure experiments with beryllium sulfate as a potent carcinogen and Chrysotile as a potential co-carcinogen, the suprise finding was that Chrysotile acted as an anti-carcinogen Of course, if one mixes Chrysotile with Amosite, Crocidolite or Silica exposures, bad effects follow - read bad. Possibly this is why Chrysotile got a bad name. I hope this summary is of help to you. If I can provide more detail, please let me know. Sincerely, A (_ .1'?, A ^ A( A GERRIT W. H. SCHEPERS, M.D, D.Sc. CRMC-MAD-000921 APPENDIX D X-RAY DIFFRACTION ON TALCS AND TALC MINERALS X-ray diffraction studies of the s e m e n t i n e polymorphs, chrysotile, antigorite, and lizardite indicate that the presence of this group can be detected at levels of aporoxixnatelv 1 % in spiked samples but this presence in an unknown mixture cannot be verified until levels approximate 3-5%, particularly with the presence of chlorite group minerals. The individual polvm o r p h s c a n n o t be distinguished, fibrous vs. n o n - f i b r o u s forms, unt i l m u c h h i g h e r levels are o b t a i n e d (25%) and e v e n then w i t h difficulty. T h e same holds true for the a n p h i b o l e group. A t the 1% level, the presence of a member of this group couid be detected (or at least suspected) but higher levels m i s t be present before specific species could be identified. In particular, it is verv difficult to distinguish between fibrous and non-fibrous forms -- of the same mineral by this method, i.e, crocidolite vs. riebeckite Yet, X-ray diffraction is the only generally available method of qualitative and quantitative mineral phase determinations of industrial minerals. It is, therefore, strongly urged that X-ray diffraction scanning be designated as the primary screening instrument in the detection of susnected asbestos minerals. If reflection peaks are present in areas which are indicative of ser pentine or amphibole group minerals, light microscopy with a petrographic microscope should be used to identify the particular phase present and determine, if possible, its general morphology, i.e. fibrous or non-f i b rous. Further identification and morpho logical determination could be gained using disoersionstaining and phase contrast microscopy. C R M C -M A D -000922 DEPARTMENT OF HEALTH. EDUCATION, AND WELFARE PUBLIC HEALTH SERVICE FOOD ANO DRUG ADMINISTRATION WASHINGTON. O.C. 20204 March 2, 1973 Dr. Lucile Adamson, Staff Scientist Mr.' Scott Lang, Washington Counsel Environmental Defense Fund 1712 N Street, N.W. Washington, D.C. 20036 Dear Dr. Adamson and'Mr. Lang: I regret the long delay in replying to your letter about asbestos in talc. Part of the delay was due to a heavy load of other responsibil ities! and part was due to a hopa that events might have proceeded to the point of resolution of the; various questions involved. Even though this hope has not yet been realized, the lapse of time has been great enough to impel me to write as follows in response to your specific ques tions. Your remarks on the health hazards of asbestos are of course wellfounded; this has been of concern to us for some time. In August 1971 I organized a discussion session at FDA on asbestos in talc, which was attended by almost fifty representatives of industry, universities, and government. A major topic at the meeting was the analytical methodology for detecting small amounts of asbestos in talc. This was recognized as a difficult problem which is best attacked by:a battery of four methods (optical microscopy, X-ray diffraction, electron microscopy, and electron diffraction) and possibly a fifth method, elemental analysis by electron microprobe. However, it was noted that the combined use of all the methods would be almost prohibitively expensive. One of those in attendance at the meeting was Prof. Seymour Z.Lewin of New York University, a recognized expert On mineralogical chemistry and analysis. Some time after the meeting, I asked Dr. Levin-to undertake the analysis of samples of commercial talcum powder products for asbestos (particularly the chrysotile and tremolite varieties) by means of the X-roy diffraction technique primarily, with additional work by optical microscopy as needed. He carried out most of this work during 1972; to date he has examined 195 samples of talcum powders plus some miscellan eous samples for others at FDA. Dr. Lewin has given us reports on his results from time to time, but we do not yet have a truly final report from him. Until we receive it, we cannot publicize the incomplete information in our possession. Dr. Lewin has written that the final report will be ready "within a few weeks" but he is a very busy man and-our past experience suggests that it may not arrive until a few months from now. CRMC-MAD-00092. Page 2 - Dr. Lucile Adamson and Mr. Scott Lang I hold a high regard for Dr. Lewin and the scientific quality of his vork; of course, it is always necessary to maintain a critical attitude towards the results obtained by sophisticated analytical techniques. This has been particularly true in the present case, where the small amounts of asbestos involved, and the presence of transitional and altered mineralogical species, led to ambiguities in the data. In his eagerness to piotcct the public interest to the fullest extent, Dr. Lewin in certain cases interpreted borderline results as showing the presence of asbestos, in his earlier reports, but he later used a more conservative interpreta tion. He has spent a lot of time and energy in creative scientific work aimed at resolving the ambiguities (for which the public and FDA'owe him a debt of g r a t i t u d d ) . * p a v e . . 'ou-vuiy know, some discussion of Dr. Lewin's earlier in.terpretar.icn of v/.ie data was included in an article on asbestos in the Wall Street Journal of February 26, 1973. Inasmuch as Dr. Lewin's results are judged acceptable, subject to the above comments, we have not undertaken a repeat survey. Because of the possibility that optical microscopy alone nay constitute an acceptable technique for the detection of asbestos in talc (and is more generally available than X-ray diffraction) we are currently making a comparison between Dr. Lewin's results on selected samples and the results obtained by in-house FDA microscopists. After this comparison work is completed, a decision will be made as to the preferred procedure for detection of asbestos in talc. Details of the analytical procedure are needed for the official statement which FDA plans to issue on asbestos contamina tion of talc. One more point should be noted, that FDA activities have already led to a substantial upgrading of the quality of talc used in cosmetic products. This is evident both from*the results obtained by Dr. Lewin upon re analyses of a given product where repeat purchases were made at retail over a period of time,* and also from discussions with a principal sup plier of talc who indicates'that he now sells only asbestos-free grades of talc to the cosmetics industry. With reference to your last question, FDA has undertaken extensive litera ture surveys on the carcinogenicity of asbestos and of talc, but the re sults thus far do not establish that talc itself is carcinogenic. We also have had discussions with members of the National Cancer Institute, where work is currently underway, on carcinogenesis by fibers and minerals as well as other chemicals. As you probably realize, the mission and facilities of the National Cancer Institute are more appropriate than those of FDA for resolving the question of the possible carcinogenicity of pure talc; also, a period of many years will be needed to obtain the answer. ^rT Celite DHQ S e p t e m b e r 22, 1972 W. L. V a n D e r b e e k E. M. F e n n e r H. M. 'Jackson W. B* Reitze -- b t ~b . S m i t h - L o n g B e a c h N. B. Scheffel -- Philadelphia R. P. Car t e r S. Speil H. G. Donovan MEETING CALL Talc: FDA-OSHA Matters Mr. Smith, I h a v e s i n g l e f o r y o u a t Green-ifj w o o d i n n - a r r i v a l O c t o b e r 2, departure October 4. Kay EJE ,,RSL RFB Hft S * NBS SRM TER JEC DEN P2oW2 C3T AJM KJB RON OHM TJF ZTSS Celite conference Room - plaza west 1 : 3 0 P M M o n d a y , Q H - n h o r 0J 1 9 7 2 ufi^,erraarto"be^ i s s u e d b y E. B . S i i m t h , - Second Floor Chairman. Of particular concern: 1. A c t i o n t o t ake (J-M a l one o r in con c e r t w i t h o t h e r t a l c i n d u s t r y p e o p l e i.e., R. T. Vanderbilt, sierra, international Talc, etc.) on proposed FDA regulations, 2. F u r t h e r i n d u s t r y a c t i o n r e l a t e d to O S H A r e g u l a t i o n s (asbestos fiber, tremolite, etc.) 3. T e c h n i c a l c o n s i d e r a t i o n f o r i s s u i n g s t a t e m e n t to customers covering Desertalc relative to tremolite presence and vs. competitive products. FDA related. m m CRMC-MAD-000926 vl /<-*#* m l Johns-lVianviMe To: E. M. F e n n e r - 4 N From: R i c h a r d C a r t e r Copies: See below. Subject: Interna! C o r r e s p o n d e n c e Dale: j une 1 9 , 1 9 7 3 E n c l o s e d is a c o p y of a letter d a t e d J une 13, 1973 from the Environmental Protection Agency to the National Paints and Coatings Association, a copy of which was sent to m e by Eob B a con of R. T. Vanderbilt. It .is m y u n d e r s t a n d i n g that we w e r e p r e v i o u s l y informed by the EPA that it was not their intention to apply their new asbestos emission standards to talc. The attached letter now affirms at least part of this understanding and states that the standards were never intended to cover the manufacturing of paints or coatings when com mercial or industrial talc is used as an ingredient. Bob Bacon has advised me that the EPA is presently drafting a similar letter stating that the standards were never intended to cover talc mining and milling operations. As soon as Bob Bacon receives this latter letter, he will forward a copy to me and I will distribute it. Bob Bacon indicated to me in a telephone conversation last week, that he is planning to meet with OSHA this week to obtain a similar modification to the OSHA asbestos dust standard. RlCP<. C.fl. CAft!/><;Kf ^ ffflSSgTf at|c/lbUo3Tc'Vi . X1 cc: D. E. H i l l i e r H. R. Kee f e E . F . Marr.iner W. B. Rei t z e E. B. S m i t h F. J. Solon, Jr. W. C. Stre i b G. W. W r i g h t CRMC-MAD-000927 tcXc V/ioVw IlfPi (loW)fcrx ituoiujU WKvlflPS (4o Cfft 4i). c.bt,'i i f U J k*j Io-u c j Slolbu-- (kancl^r tfc lu-^. yiCtu^<f j/iiAv 5MA.CL 0 OoU/'vuJli' of y ^LCJu fe KCJUi. Wo CcfwUoP UiWf" llKfteUr,jyCVt cu/ltetUj' iM <X~ .^UAvvt. SkJd d - W U L u W ,ati ` <f\)<>(&cC` /iiiCfwb,4 i Desert Minerals, Inc. - Long Beach October 17, 1972 E. M. Fenner H. M. Jackson W. B. Reitze P. A. Martinson H. R. Keefe R. P. Carter R. F. Bassett R. S. Lamar E. J. Ellsworth R. L. VANDERBILT LETTER TO FDA RE POSTPONEMENT PROPOSED REGULATIONS. Here is a copy of the letter submitted to the FDA by Mr. Paul Gibney representing R. L. Vanderbilt concerning their request for an extension of 120 days in which to file comments. Earl B. Smith EBSsjec Ends. CRMC-MAD-000928 AK.CIUEHT J oshua Levine PBiZSP K. Schwartz Patricia Hatry Theodore a. Raudun Philip S. Reiss Paul B. Gibney. J r Ross L. Gilbert Leonard Orkin Solomon P Friedman Martin a. Remnitz Gerald B. Schwartz Miles Baum Alan D. Kroll Stuart Lee Friedel* Michael D. Ditzian *<orMAiVlAMOIOC AHHi* D a v i s ,G i l b e r t ,L e v i n e & S c h w a r t z SCOFifth Avenue,NewYore,N.Y. 10036 e.;e TCR f ' udL .J.EC.j1 -f;OcNJj --i J. 0 . (U',1J iKJB j OHM!.. MJF f' Hearing Clerk Department of Health, Education and Welfare Room 6 - 8 8 5600 Fishers Lane Rockville, Maryland 20852 Dear S ir : We are attorneys for R. T. Vanderbilt Company, In c. and it s subsidiaries, Gouverneur Talc Company, Inc. and Western Talc Company, I n c ., with o ffice s at 230 Park Avenue, New Yorfc, N. Y ., and fo r International Talc C o ., I n c ., a corporation with o ffic e s at 420 Lexington Avenue, New York, N. Y. Vanderbilt and International are unrelated to one another. Each of the afore said companies is a miner and producer of t a lc . Reference is made to the "Proposal Regarding Regulation of Prior-Sanctioned Food Ingredients" (21 CFR Part 121), published in the Federal Register of August 1 2, 1972 (37 F.R . 16407). Our clien ts have noted with great interest the proposal to ban ta lc "containing asbestos-form particles" from food packaging. We note from the September 22, 1572 le tte r of the Director of the' O ffice of Product Technology to Mr. P. F. McCarthy that the afore said proposal is directed against fibrous forms which distinguish asbestos from t a lc . Talc produced in the United States generally contains trem olite, and this mineral has too often been c la ssifie d with asbestos, which is truly a fibrous m aterial. Our clien ts wish to establish, not" only for the benefit of the Food and Drug Administration, but also for the benefit of other federal agencies asserting Ju risd ic tion on the general question of asbestos, that the tremolite contained in ta lc seldom occurs in a fibrous form. Assuming the establishment of th is -fa c t to your sa tisfa ctio n , non-fibrous trem olitlc ta lc s should therefore be without the fie ld of your concern. Furthermoret i t seems that there exists' a great deal of confusion over the mineraiogical natures of true asbestos and other minerals CRMC-MAD-000929 D J W s , G i u d e h t ,L e v i x e 8 c S c h w a r t z October 5, 1972 Hearing Clerk Department of Health, Education and Welfare Page 2 which h isto r ic a lly have been classed as asbestos. Modern s c ie n t ific techniques can, we believe, demonstrate the raineralo g lc a l and physical differences between true asbestos, which i s fibrous, and those other minerals. Our clien ts have, prior to the publication o f the aforesaid proposal, begun research designed to establish the nature of a fiber and to establish that trem olite, as found in most U.S.-produced t a lc s , is not in fa c t fibrous. The results of this research should be of enor mous value to the Food and Drug Administration both in evaluating the aforesaid proposal regarding ta lc in food and food packaging, and also in i t s inquiry into the uses of various ta lcs and ta lc components in cosmetics. Our c lie n ts ' research is divided into two parts. Our clien ts have undertaken f i r s t a microscopic study to determine the shape factors of asbestos and of the various components of td lc products. An indication of the proportions of the various shapes found within the subject materials w ill also be ascertained. This study W ill include ta lc products representative of-the entire line that may be destined for use in food and food packaging, as well as other in dustrial ta lc products. Other producers of ta lc have undertaken to send samples of th eir ores and products to our clie n ts in order that a thoroughly representative study may be made. The results of this research w ill be incorporated in a written report which w ill include numerous photomicrographs. The second phase of our clie n ts' research w ill constitute studies by X-ray d iffra ctio n techniques. The same ta lc products as used in the microscopic study w ill be examined by X-ray d iffra ctio n fo r q ualitative id e n tifica tio n and quantitative determination of th eir various components^ The1quantitative part of th is work involves considerable effo rt in the development of standards for the relevant raineralogical components. As-stated above, this research is already under way. However, i t w ill be impossible to conclude same within the period set forth for comment in the aforesaid proposal. Accordingly, we respect fu lly request an extension of 120 days within which to f i l e written comments to the aforesaid pronosal. We submit that this extension w ill b e n e fit'a ll parties concerned by permitting the formulation of precise mineralogical definitions of so -called .<"asbestos" substances used in food and cosmetics and by identifying with p articu larity the exact minerals, the characteristics of which, may render them possibly injurious- to health. V ` C R M c -MAD-000930 ` ' `VA D J & ^ bj G i l b e r t ,L e v i n e & S c h w a r t z October 5, 1972 Hearing Clerk Department of Health, Education and Welfare Page 3 Furtherniore, I t Is our understanding that other producers of ta lc are undertaking research to show that there can be no migration o f ta lc p a rticle s, as used in food packaging, into the food i t s e l f , thereby avoiding the p o ssib ility of ingestion of those^particles. We further understand that other producers intend to produce medical evidence th a t, contrary to the assumption of the aforesaid proposal, there is no carcinogenic e ffe ct which results from the ingestion of t a lc . These,^studies also should be of. great;value . to the Food and Drug Administration in determining the v a lid ity of the aforesaid proposal, and we believe that no action should be taken on said proposal u n til those studies!have been submitted and evaluated. L a stly , we note w ith,interest the statement in the proposal that "ta lc can be processed||toremove asbestos-form p a rtic le s". Our clien ts know of no" cbmmercialiy' feasible^process to remove- such K-*- p a rtic le s. We shouldfa'p^reciat'e -a description of the process .re ferred to in order that we-may have the opportunity to comment on same. Your prompt attention to our request for an extension of 120 days within which to comment- on the aforesaid proposal w ill be greatly appreciated. Very truly yours* PBGibney ,Jr./ rd e i? ) j \J ( M s M CRMC-MAD-000931  I 4 Octcbcr 9, 1974 M. t Hr* 11, B. V a n d e r b i l t President . ' Chief Executive O fficer M. T. Vanderbilt Company, Inc;* 30 Winfield Street Korwalk, Connecticut 08855 Hear Hr. Vanderbilt:. * i . * . of This is in reply to your le tte r of September 2(5, concerning your request for r e lie f iron the asbestos standard for your talcs containing non-fibrous trcmolite, a c tin o lite , and anthophyllite. My le tte r c f August 6 stated that non-fibrous or non-ssbestifom minerals such as non-asbestifora trcm olite are not within the scope of the asbestos standard ar.d, therefore, the provisions; of that standard do no"apply to ta lc containing non-asbestixora minerals. .* * * KIOSH is currently ccr.cuctin.fc a thorough `investigation into the exact minerals to which talc workers were exposed .in. chose studies where asbestosis or other adverse medical effects were; ;ounc Pending the receipt'and; evaluation by OSEA of the report by HIOSH on this investigation, , i f y o u :have ^sciehtific. evidence that the naturally occurring talcs, prior processing by m illing or crashing, do not contain fibrous or asbestifom trer.o lite, antophyllite, a c tin o lite or other, asbestifom minerals, you m y c e rtify to-your customers that the talc does not contain asbestos. . . * . Pibrous, asbestifom minerals such as fibrous tre c o lite means naturally occurring asbestifom minerals which prior to or after crushing and processing,- contain fibers made up of f ib r ils . Sincerely, I s / John H. S.cender John 11. Stcndcr Assistant Secretary of Labor CRMC-MAD-000932 October 9, 1974 % Mr. II. B. Vanderbilt President . - `Chief Executive O fficer S. T* Vandarbilt Company, Inc. 30 W infield Street Norwalk, Connecticut 08855 Pear Mr. Vanderbilt: o f Jh* This i s in reply to your le t t e r o f September 26, concerning your request fo r r e l i e f from the asbestos standard for-your ta lc s containing non-fibrous t r e h o litc , a c t in o lit e , and a n th o p h yllite. My l e t t e r o f August 6 stated that non-fibrous or non-asbestiforn minerals su ch a s non-asbestiforc tren o lite are not within the scope o f the asbestos standard and, therefore, the provisions c f that standard do not apply to t a lc containing r.on-asbestifora m in erals. NIOSH i s currently conducting a thorough in v e stiga tio n in to the exact minerals to which ta lc workers were exposed'ifr those e b u d i o s w h t t r e a s b e s t o s i s ' o r i o t h e r 'a d v e r s e - m e d i c a l ? e i : c c e s - w e r e r o u n d . - Pending the re ce ip t and evaluation by OSHA o f the report by NIOSH on th is in v e stig a tio n , i f you have, s c i e n t i f i c evidence :that the1 n a tu ra lly occurring t a lc s , prior to-processing by m illin g or crushing, do not contain fibrous or asbestiform tremolate, s n to p h y llite , a c tin o lite or other a sb e stifo ra m in e ra ls, you may c e r t ify to your customers that the t a lc does not contain asbestos. . Fibrous, asbestiform minerals such as fibrous tre n o lite means n atu rally occurring asbestiform minerals x^hich prior to or a fte r crushing and processing, contain fib e rs made up of f i b r i l s . Sincerely, / a / John H. Stender . .John II. Stender Accistant Secretary of labor . . - A'* ' C R M C -M A D -000933 ---------------- -------- IV.'. ****< HBEHGDCF TB HDK 2.0 dineral Hitarais A Associated Teete 2.1 Asbesto* fiber - General 2.1.1 Mill Method ft Quebec Shaker Tests 2.1.2 Botep Screen Tests 2. 1 .3 Fiber benfth - Oenersl 2.1.3.1 BadOllet Air Analysis 2.1.3-2 Bsdollet tfaifJLcw Filtration Tests 2. 1. 3.3 Deterstomtlcu of CxuAy Fiber ft Bosk Badollet 2.1.3.1 Asbestos Fiber-Aspiration Test on Short liber 2.1. 3.$ Msiettfest c 2.1.1 Buoysaey Test 2.1.5 Analysis ofHlghTeop. Insolation-Ignitionloss ob Fiber 2.1.6 Mlcnoscopialdsntification of Chrysotils 2 . l.T Blue ft Aaoslte Fiber - Vet Screen Test 2.1.8 Asbestos Fiber - Coop. Analysis of "C" Fiber by Fusion Methodiro.BoillinfVith Cow. BB1. 2.1.9 Fiberln 85* Magnesia Bleaks 2.1.10 Iron ia Chrysotils Asbestos Fiber 2.1.11 Asbestos Fiber la Be. 1150 Osassi 07694 CBMC-MAD-000936 Asbestos liber -Oenexml - continued 2.1*12 Asbestos flbw Disaster Tester 2*1.13 Asbestos fiber Moisture Cosi k Coke - Osnerel 2.2.1 8u3sbnr la Cosi A Coks 2*2.2 MoistureinCcal 2.2.3 Hast Value ofCcemstible fuel 2.2.A CcelVCkeFsrtieles desoline - Mepbtba k Petroleum Products - organic solvents 2.3.1 desoline - Evaporation Method for Kcpbthes 2.3.2 AxaJlnePoint of Petroleum Solvents A Solubility of Cael^TiriBisiiis. 2.3.2.1 Aneline Points of Hydrocarbons 2.3*3 Mrtfcodofdaglng la Stonata 2.3.1 Solito? - Oblarlas in dateline lapbtbe k Kerosene 07685 .METHOD Of TEST INDEX Mineral Oils Glossary of Petroleum Teme Gravity Flash & Fire Color Viscosity Klsetsatic Viscosity Viscosity IndftX'SAE SAE Kuaberc Dilution of CrankDsr> Oils Cloud It PovsrPoints Neutralisation and Saponification Vos-. Btoaa Benlait^Ncsfrftr Freoipitatlon HUaiher Ash Content Carbon Residue Sulphur Content Corrosion Oxidation Test Distillation Reid VSpAr Pressure Octane Kusber Cetane Euafibar Qua in Gasoline Thermal Value of Fuel Oils Penetration Dropping Point of Grease Melting Point Paraffin OilContent - Paraffin Cartonitene SULstaacea Dielectric Strength Aneline Point CRMC-MAD-000938 Msn** o r n a r ijtok 2.5 lubricants V%ui4 Fuels - Mise. PBhlete Coacsrclal hts fc OU - flsspltng &Analysis - Ic i. & &)g. Ctctristry 2.6*1 Orense - Determination of 8oep 2.6.2 Detection offish Olii la Vegetable Oils 2.6.3 Characterisitie* T Petty Acids 2.6A Linseed Oil Sulphomted Oils Method of Test Rosin - Dateroinntion of Hsin Acids in Rosin Oils Roelns - Plastics - V119 Resin (Barrett) M.O.T. /V 2.10.1 Cosar - BarrettM.O.T. for Floor Tile ResJUis 2.10.2 VlDyllt* - 'MsithvBaicelite Methodof Test 2.10.3 Plsstlc Coithd Fabrics and All Plastic 8heeting 2.10A Hercules Test Methods - Vinsol Resins 2.10*3 Rpoxy Rasine General 2.10.5*1 Citai Cdogany 2.10.5*2 fts ll ChMlcal C&ny 210*3*3 MSlon^osxhide - Bskeiita Tr V. 2. 1.5A FsnttUstlos Inc. 2.S0.9.5 OattMhlMUls ftlfft ^e^es fishney c r m C-m a d -o o o 939 METHOD Of fffiT IHDZJt 'V- 2.10.6 Pluoroethyene Resins (ciiea) 2.10.7 Polyaaide Resins (VersaMd) 2.10.8 Polyvinyl Chloride 2.10.9 CWPdollte BeSStt* (forttevly 0.1.12) Z . i O . ? , / - M o. ,3- - (jSALo lb Crt-6ji0 , 2.10.10 Phenol-rarasldshde Synthetic Resins (Dure?,, BsVeliif., Pdlyree SclftmStfcdy, Vhfett) (formerly 8.5 srier) 2.10.10.1 Screen Test - Ory Hsthol r . 2.10.10.2 Crit Test on Pctedered Rceins for F o r a i l^y 2.10.10.3 BOt PlStS Cores 2.10.10.U MeltingPoint Setenednstioas (Cs.pllire: Tv:. rs> 2.10.10.5 Percentage of CL & SO in Spent Cetal;'-c. - l ili 2.10.10.6 JTell Tin nt 250'T. or nid Reslrr 2.10.10^7 SpecificOravity by Hydrc-aetor 2.10.10.8 Viscosity In Centipelseo 2.10.10.9 pH by1S ^ a i pH^Keter 2.10.10.10 Hoo-Volfctile letter by Weight - ASXK lotted I -M 2.10.10.11 Vinyl ChlOride-Aee-tat0 Resins - Esielits Spees. 1i ffethbdn 2.10.10.12 Moulded Compound 2.10.10.13 Molds for Resinlasting CRMC-MAD-000940 V l%j r `*W method o r tw mm 2 .11 Mbara * (Sie Tila 5*3) 2.12 Alcohol* fc Polybydrle timbal* - Oenwml orgtaie chealeaH 2.12*1 Methyl, Ithyl *nd Isopropohol alcohol 2.12.2 (pirint a-tfci raid to oirca 2.12*3 fettlt sribfetltot* for glytrl&e TremiagPoiat et vulcus fctttrec - Alcho.> ethylene, glytol>ilyiii 2.12*5 Plyhyrlc Aleahcl 1st** 2 .12.6 !Titroctllla*o 2.13 Yana ccd Cloths 2.13.1 Crtton IJHB - Slagl U Pl4 2 .13 *2 2.13*3 2.13*1 2. 13.5 beton'Ttrtie* bttcnia AMbtoto* Yttma (Se* Tile 3.k) Hoopnerph tfar ftetwainlai ootton ln Ml>*stoo tertilich TsoctllB - Test Methods - Tad. Spec. CCC-T-19Ib 2*lh- P&liits h PlBKCrtB OorfSoti <0es File: 13.h.i<) 2.1h .l Ttb*eatth*to * TlBts 2.1A.2 Control tests for TlfcMmts la Asbestos Shingles 2.IH.3 Wst fila tfclolM** - 0*s* 2.1h.h Ziyeq!cOrN(iMhttiil*s TcMdor Co.) 2 *Uh*5 g#Xh.6 't CRMC-MAD-000941 W ..-V S i r ' ; - " w . y*".' ? .' ..V ,J^f Metal Powdara - Metal Pcwler Aaaoeiatloii Bells 2.36.1 Plate ob Bella ft Boita Scapa, Detergente Vettlag Agesta - cleaning 2.1T.1 ft*0el 2.17*2 C a l 2<1T*3 TM#^tol Meter * General 2.16.1 Bollir, f M & ft Procese B t i r l P w t (Corrent) 2.16.2 Bollir, BisftiiiHiSeaaBtttfrJMtt*(ftaelcte) 2.36.3; W ft B.D. BilftjBltM^ft'Bellilimte 2 .1 6 .1 B<*&rltttrjIMtM& - 10 *eelUuieoas 2 .1 6 . 3 SeAlir Plite BBirittliaaBt, Cflrroeion ft CnaeKag 2 .1 6 .6 Itetser 2.16.6.1 Beata NUlpere Aaalyala and CootrcOe CRMC-MAD-000942 K i E C B or ` Z X CS.TO ?ori.V;.nd QsS'Xt - C'C-'.J. 2lptl 555 tfcaiag - 3sr*;xal 2.1M .1 Sr.3 C;i.'tss-t icocu'-'cM'i I' W > .o'.,,*> oti c:." Circs' cvcia& i& Ciic np'ilrvr.:- Iv.v^lv.": <:.* stav- cirios : 2.1 ?." 2.19.3 scaaui fc'yl'xts -rr<i:<s:/i*GZ.:. T&xJbmi>tV..r A1* .!?.?: - <*B*f <v> Wl */Ml*VOa.<ut. S.V/.>.**j V, **' **?*'*p. r.+-,r*.*; ',' i <* *O N 2;.'w"0 * crrwrt'i Ttr-rrl.v.-,*. >w *\ - \fr,.m-.* ,P** ' <>.;*> .- ?T *i**-i 'y. . ' /.r*-'ry,- 1WYir'*tn*l"t"Aa*">.^..*..1 vv-^ .-j-....-,--... r#.-- f-to - CRMC-MAD-000943 0? a&t ISSIVI '* - - GC.ZCJ - GcuH'il 2 .20.1 Ilaio?. o O&sraiica c I v m G.-.3 30, Cg, cui CO # ^ * ''* ' '* 2.23.2 * #h <-, ^ .i- J ^ A* 1 i;-r.c ipiatmCvOrir. zx ~:jr,z r:' H'/ir^ec/.'Vv;. V.U . C V*#/Vo*,u* 2.?2 Vy c~c~ c2 r, Sc c k 3*1 :.;,;;rv^c"" 7.*.5 r.3. tent cuCL '.:! o / /'t ' 2 *2-0 ;*>JSw*f*'l'*f+* cr "olv.r.2 to air :;x-zr..?~ ..Q<^te&r&zics * i ^r'*.*-\><***' fot surto: tfcr. of. (CO). Cftvln Ks-'cto:Vi I'to; f.rtoOy s;.;.*.;.:r.:.-c* Zi^'^rtoytu- ` i* i* Gxv^v /* * '.. ^ .*-v. .**-* **V~vr' ..>. --.. .. .*. *1 . 1; <*j IX :* (V >i ,,, ,, ; >-. . - ^ f /w*i "*'*'* Z*** -r; r 2.?.',.2 fCl,i <V*'***uJ><:,,w<t> f * ''Vf,'" **. ;I; G JV*** *;*a ^** * */+ ?S*;y /. ~ -nV*/." -;Z it*T".r ' i / ' **'' *Zm.***/-! *;- vr.?;" V`2. '`t\. **'11'^* *C*V*1*.V" Xc#rc* f C i f f M M or s w n o n e 2.30 ftodiu* Silicat 2.30.1 Sedi* o Pattassi*Tests * : 2.U0 Sille I 2.V0.1 SiOa in Sieb SilicIhtmriti 2.fc0.2 S10g 2^id otbofl io C-- nt mad 81mg | 2.U0.3 SlOa ftoo Siiiomin*imn*itePip * ' '' i 2.50 71yu. flirto 2.60 Siliceo t 2.60.1 Dev ^ - .:'k".)J 2.70 Wax ' ' 2 .6 0 Chemical - (Also fll* : 2.12) 2.60.1 Ael&s a%\ '?Hu*-u>9 4*&v*k C R M C -M A D -000945 0 9 3 0 3 OeBanl Analytical Method and Haegwts 3.1 FUher XLeetrqffeotoMter 3.2 Maher Mrlatter * pH 3.3 Special AaelftSeel Baegante <1 Tectaiqj** 3*3*1 3*3*2 O m U (hlttHtijr Periodic Acid mad Softie Add cod their Salt 3*3*3 Faxehlorle Aeld and Wet Aefclaclfcthoae 3*3*1 Pharanthrmllne tad etfbedtatdFfceoentt^^ U bU B m S V 3.3*3 *MtnIailitorB 3*3*6 3*3*7 8Wrdimpqplnoillae D w o y l t i qf AlaHwn BiUettt 3*3*8 Y la tla a iu * 3*3*9 3*3*10 3*3*11 U d tA , Iren aad Other-Wax* Otiite AmlytletiL filter ASA Seetlag ofgloee roll--trie egolpeent 3*3*12 Aahydrooa MGgReeloa Perchlorate 3*3.13 ^ Ctaprolaa, leocT^radae, 3*3*11 Purl Maher Heagent - Determination of Water 3*1 etleldel^KBwe^e^SteadBZde- Umpire end Proeodorea T Alio# labelled Ocqpomds * * * * * m . * . ^ e * I * i * * M P /**. CRMC-MAD-000946 > 7 7 0 5 IE7SEO0 &if e s t n u s ; T Ganaovil Asatria M fc.13 EC5-C2C3S-2k 2SC2 -2 EC33-31 Alfa 2.Lalaviesa Ulz-tAu IaitLcls Kc-OT.stiosa H a s t i e laiariiala J^sartLe Taiet Zfaasol Perorici Eia:?! 'vai* Acis 2313-[>1 Aleefael H e r Test Zfc-w &3?2fj-n2 Parsasi; FcrialiaTijric JarcaoV lu ZSGS-SS Lbtivacl CcrAe 2ercc.ls:iy* R:ls.vie::o ESaps-Sl FsrosS Griho-Cresol C e r A c i A i:V, '. I3230-S1 F-reset lists. Cresol C e r Acy 13332-SI Frac Asii Silzs ntcT-rs.-'; r%SS-5i Total Vctor 5rsslt3:lc Alfa ist-ollis Ot-*r E & 3 Sc.r,?3ir.:-;Flsstic-^Asriiv. I31-A' rc-osvt ikiatu:;c lAes' is foteri:Ac EC2-3X /cllity '? .mlSnity FI?;:#* ?l-.tr.:.-;'.rIr. uros-cx rOV.^r,-. Svr: H a s t i e ILtsviAs C-r. / r a t i t a Flostla !:-* c v i v l r;:i-./-.'.t.V-r. H . v l i a * rctr-ni Gvit riV a-co I-Atcr :Af. Ciar E & 3 H - 3 X Atrassi:'. Cer.v.t .'.evert.*.:-: 1; u-avila O a r . v W :t-/.-.' 1; s;: .V *t*w'v *- FarAfo ri "-*" w ;r.rAv*;at: LJ1T-2.2 ivsltlur Cranio C^cveAs E533.P-S1 ForczlC^'ni'cl'; RrXztices rSOSO-ri' Parco* Afailar* 'Sinei:.a SSCSW*?. 2 DC2-r, Z2;&n:.- E&BSfrSX E3CS5-CJ. 3027-31 Etl-Sl E85&-S3LESCASI PwZi;tr.v.ti.rA Tl.tor PcTW.o H a ' ; Vk.v T."-;: ;v -. l';-.cor-" .vizt -;`.:s <&teCo C ^ .i-3,.ctic Rase?. Enteric* Asa rveitT VsKiish C; C.C.or Al- ':,j"'v `" 1'.Cc.r /iCii.c R o li J^ Tc.iet asscoes 5roi.tr`SsSKi ~.aUv :.`.c.-; nsyftcr Colv.'T. ri.-mir/'.l'.r U- : Ec3--.01 loiio! Srrr-rv-isi.rr rvT 1 :a r .3.-- :. : 2021-SI Ara !V;cic-::.:r.s-r l.Vit-.e-.rl Ilv'.-V .: .i Solva C.voss.^o OwiS;*^. c-.-. ....l"c lacscIAtzsow Hot*-eco :.;. /r.:.tvrie Usa e" Hai:'..eaaiivc taVvir Cualitativa &z Ci at 1. ' tr rely-tiCa asi r.r -000941 C cVLC -M A D Maraco er rara nwa Specific Method for vnrieas Eleoant* fc fcterie.1". 4 f * * * * SttLtf 4.2 r r B o A Colorioter for Sulftur *nd other deterrirstionc fis 4 & * 0 X $ p Odsfnrnmff*9^ 4.4 rrhmm*rx*-i Omani Procedures /Car** UBO and CaO bearing aatoriala H.9 Detwoining of irm in Httodr driora. 4.10 Phcto8i>1t*tion 4.11 ChlcroaBilato BMcaot for chMieal waJjrsl* 4.12 Spot toots for plastica. 4.13 DotondnstlooOf^Motiaoin vator aa&wtor laaehicst by MrenitieiiRtMt^ CRMC-MAD-000948 SaD Ci- K3S? IH-2 Vi 5.0 Ic'rr::atory Alis 5 . 1 Si'd c.l!3r=vir.ticr-s for Ccimtiric Es l^xsi.vir^ Seras 5.2 Georgs EJdsreca'c nacfcrc:. 5*3 rH - Besaa Crert 5 .5 S t ' a ire5.l3*o fttL cc2.5ar.13. 5 .6 nt' Igig?.:*:*er. vc3tt*:a-rS.c tr.*o?.c3 5 .7 s-ri Kcols - r.vy rMclncCerne. 5 .9 Cceiraciers ft&r.r.tv.cy o tarsaas or sarete IXliC: (V.\ui 6 ?:0 > ^aiv:23.e. e:ls# T--*s:/.;?.) 5 ..1 D .Me Hala Goesc-aX 5.1^.?. Stesiti' fttla or C-^sro?. wisf.* C 'crt'.t:'. Ceritei- Ozz'MZltice 5.:C. fcir.rs C3.x.i-.3 rJxAf.cz - :*.:;"5.' l'O. 5 .V..?. LtC&vAc .Mo..-.ti ; ..U , *. u * - - --. a,** .-..*-, f.1 5 iMcvst'.- LTat.y Ic.jc.1 ?-cr 3 .1 ':-ITr/icatl. Ko. Ss*- ^VT-S-r-s- (.Ttt.. c?.v er _ _ St/5 etJO & K U iti T *.. /</C3 T i 5 v * **fo**t efiUiUAizn P eutJD S CRMC-MAD-000949 0 0: * K2PIT0D oar TEST V 6.2.15 V&poi Truwaiaaion j 6.2.16 Uriberg COMuaticottirnace | 6 *2 .3 ? Kethod of Kaaeuring theroal cond"ctirity at P a r tie e tr i.? '.. j fl 6.2.16 Huppert Furmc* 6.2.19 Zn3trustlacui for MMbliog and epeiuting Sargen>: i i - r c r r . * ! | TtaerBaregulator 1 J 'ds 6 .2.20 Giuriity Oren 6.2.21 Cenco Air Agitator for Oven 6.2.22 Tyro^WftgneetliF 6.2.23 Bottoa Plato Trent Electric Furu^ee 1 6.2.2U Precielon Infra-dry Cabinet 1 6.2.25 Oltibar XlMMnts 1 f w t Pry 1 CRMC-MAD-000951 i *-yy..5. . ViYM.VV j .W ? `*\*,**,*vV,? ^ i V j ' ' ' iV*V ***' MESSRS) or HOT 2XDBC Viscosity - General 6.3.1 Viscosity ad Viscosity Index 6.3.2 Viscosity Y3. Tenpereturs charts for Petroleum Products 6.3. fe ,9.9 6.3.3 Stomer Viscosieseter K U c s i ^ C*P* Mhreh Vhnnsl (See 9*2*3) 6.3.6 Brookfield Viscoaster 6. 3. T Bendi* Ultra Vlseosowtsr 6.3.8 Sunshine Scientific Instrument's Ocl-Tia* Tester 6. 3.9 Gardner Bubble ViscoMtsrs Stiffness - Olsen (Also see 12.3*3) CRMC-MAD-000952 0VV14 mms or tsers xmm Tensile Testers General Madul^i - Deflection - Coapressf.-v-e Btr 6.5.1 Scott Tensile Tester 6.5*2 Schopper Tensile Tester Kacblne Inc. 6.5*3 Tinius Olsen Tensile Tester 6.5** 6*5*5 Riehle Tensile Tester Proving Bings 6.5*6 i.r? Dillon Tester ffes+iM* fcevre i3re*e ftr#* RefraetosBter - Fisher thickness fegnc - Oege -(Also see 22.7*1; 12.1.1, 12.1.22) Color Electronic Mwsurwmit Pressures, Flows, Vhcuua, Regulators - General 6.10.1 Pressure Regulators (U-10 Cane) 6.10.2 Flow Bator - Air 6.10.3 Vacuua Compressor Puap 6.10.fc 6 .io*r fr.lo.g ASKF-API Metal Oofie POmrsh Outturn K|s/sfsri C R M C - M A D - 0 0 0 9 5 3 ()7J<j[g 6,U 6.12 Kauo-.- op Trs? Cexitilf'J^e E lectronic Rel-iy 6 . 1U. 6.15 6..16 6.17 6.18 6.19 6.20 ' tr y - Methods V o lt C haster K loroseope - Use and Cere 6 . 1 6 .1 M icroscope Ie ^ p Adboratozy Ba5.r-.nca3, A n a ly tic al, V s c tp ir lt TiripV I> - c. 6.17.1 Calibration' of A nalytical righte 6.17.2 Seales 6-17 3 -^PCMiUr O a f a v r t Varie.c 0-j.rver and o t t e r Pres*e P a r tic le Sica - General (See F ile 5.9 f s r cbeehirs 'sera:-6.20.1 Blaine 6 -20.2 P o rtab le Paper Jogger f o r Ble-'.co T este or-. Cel:.; 6 .30.3 T y ler Rot&p - Screen* 6.22 M M .M M M . CRMC-MAD-000954 Q 7716 r , 6.23 6 .2b 6.25 6 .2 6 K2SBCD 0? TEST U D E X Veter Still - Precision M s m m TacteFiiotgraphic Sniipoent Rexograph Replicator 6.28 6.29 6.30 6.31 6.32 6.33 6 .3b 6.35 6 .3 6 Aiding Machine 6.26.1 Monroe Adding Calculator Instruction* Electric Typewriter Btatlgon - to check static charge Polarographlc Analysis & Cpectrognphic Analysis Sandier - Sears - Instructiono i>MriCut Slit ~ Screens and 8crean Testing Tlners Coodactlrlty Torque Vrenoh CRMC-MAD-000955 0 7 7 1 7 6.3T MSCSC0 u? TOBT IF'.OT Stroboscopec 6.38 i^ 9 L^o . Vf 6 *Vi fe&croceater* - Surffcce ^ <r**s-*VfryCt*** f a u < J fot/ fk* Pupkek'hor* 7%aL^yi0rm^h^^/ ' m W & b * P ritt P r i n t s .y< '*A < e- 4 b *rMLA% A *9 So t,s) J? V y.sz T j j buta&s) > ~TT'-s pffejs ) A # HVPA^->t ic A c P>*frr S f t T T w ^ ^ e w w ^ f r t , U X T K * o r f . c 'b&r&cf'o*/ / a/ * M - A v o Jt*r*Lrxtx PrrO'fi'C- h&S*Gf>r*aJ ' F r * v * f t JD*/***frrC-*. SorT*s^ "0 feot** V CRMC-MAD-000956 07718 o FCona 7,1 Cesprsssel Asbestos Sheet Packings 7.1.1 Oosprsssed Asbestos Sheet Banking Al?-3231 Oil Xssosrsion Tests 7,1.3 CosresscA Asbestos Sheet Batkin**. /!!3-32$I Cil 7 . t'i Resisting R a p -o i w r f u T M T r-,!t -S*F*r f.i.3 x /. <*- loifii 30 Sfesst IhcM V r i # t Sp3. 5951 tfsirrePiitA A w t+ h ****, **,* , ffcft > 74 7.2 Knhber flieet Baching - Res. Report o. 11-7537 Ti t i i fe e s m s m i e s j u r r s i F s e p e t i l n s f i i s s i sweSPf P n w m e 7*3 Braided Packings - Analysis of Asb. Risking ir. F.irg or Coil Forr. 7.#- 5 Ajx.p*tb ItfSStMor ^P%RT*e, 7.*. I 7.^* C-t-h.p v c a a . /-,**Ut T S S T S ^ W<w RfrueseB h t arCfrtfc C S i ( u i r ^ i 7.7 Chlorine In 76 Sheet Reeling 7.8 Agerite Eeozone "Br Spec. 7 .9 KEC In E^-vica Ehaet - p u t a t i v e Test 7.10 T4:lr P.nl .-"olveots used for testing Servies Shsct end . r 7.11 hr. 76 Corprassei Asbestos Sarat Packing to E.*.S-.'US-3?32,-< 7.32 Ckjj for Jf.rntt.Ocap. e r 5 i 7 ,; 5 5 PC'STl CATe*K> j 2 , t h S r aa NSfc-vu-of, 2. S A 13 , 3 tk A l J2 . 4 - O fr>T v. / . /- Nva*/V 7 o i l fi CRMC-MAD-000957 CRMC-MAD-000958 METHOD GT TEST ZHDBC a.o m m m mmam & 8.1 Brake Linings^Jenexal, Benilx Cor. Bag. Spae. B5-06W> and Ford. 8.1.1 Brake T.4nwg . Fhenel-Farmldehyia Bealaa A ftLLlet Frees 8.1.1.1 Teat Methods for Cashew lot Deriritiye Sbterlals - 8.1.2 Brake Linings - Alloy Analysis of Brass Chips 6.1.3 Brake Linings - Copper and/or Brass Wire 6.1.1. Br^ke Linings - Beoprene Compounds 6.1.5 Brake Linings A Blocks - Dry Nix acetone extract & Ignition loes 8.1.6 Brake linings wear tester - flexibility tester. 8.1.7 Inspection of Lining for Firestone Tire A Robber Co. 8.1.8 Brake Lining U3&-B - Cfcryeler 8 .1 .9 Chart for detersdnlng rejection of allied #TOfc 8.1.9.1 Shemal swell and blistering 6.1.10 Barret - Minot Lining Bonder - Bonding of Friction Materials l 8.1.11 naaiun 110 Ream (Barrett) M. of T. (gee File: 2.10) CRMC-MAD-000959 07721 ^ ________ ILlJiS Ctaleaj,t tesla* - See File t.W.9) NBTBOD OF TE3T IHDEZ FEICTIOS MKTERIAIfi 8.1 Brake T-<"-t"ga General - continued 8.1.13 Shear Teat for Bonded Lining 8.1.1% Tnnsalssian Benda - In-Process and finiehed product 8.1.19 Activated Alenina c * Zu*' * ,i f././{./ f./. *t.2- //. /,J 43r * -<**1* 8 .2 f .i . t t AT 8.2.2 Clutch Pacings - Ignition Loss am ine T *tf 8.2.3 Hot Spin fester and Associated Sqpipnsnt 8 .2 .% Weight Loes of Dry Ids Lining Slabs or heating at 300*7. 8 .3 Rubber - Pastosare 8 .3 .1 Boivent for use on Vulcanised Rubber 8 .3.2 Flexing Tests for Rubber Products 8 .3 .3 Robber - Adhesion of Vulcanised Rubber to Retal 8 .3.% Accelerated Aging of vulcanised Rubber ` \ & METHOD 0 BT XRDBC .o m m m m m m 8.3 BuUwr - Daetonere - contino*! 8 .3 .$ U. S. Oovernoent General Spec, ft Krthod of Physical Test and Chwdcal Analysis 8 .3 .6 Rubber ftSynthetic Rubber Cospound Freeze Reslsstaaea 8 .3 .7 Speclflcetlca for OR-S and IKM Synthetic - Maturai Rubber 8 .3 .8 QOocaary Rubber Coeponndlng Ingredients 8 .3 .9 Effect of Bap. of Resilience of Saturai ftSyn. Rubber 8 .3 .IO Method Test Racialned Rubber 8 .3 .L Scott Rubber ftFabric Testing Direction 8 .3.12 Ryear lfcll Fonder 8 .3 .13 Accelerator, Auto Qaddent, eto. R. T. Vhadertilt 8 .3 .3A CruMb Rubber Ash test for percent Talo 8 .3 .1$ Oysleveld Flo - Test Frooedare 8 .3.26 Chatios! Aaalsysis of Retarsi CRMC-MAD-000961 8.3.17 CJaenJUssl Resistance of B r i RUMmrs 07723 METSOD CS T S T IUDEX 8.0 sracnc matsriaib 8 .3 Rubber SLMtoatr - continued 8 .3 .IB leta Rubber 8.3.19 Byntbtttle XUstcnere 8 .3 .19.1 Viten 5.3.19.2 ox9l - Sthylcne Propylene (Dupont) 8 . 3 . 19 .3 Phillipe Petrleos 8 .3.I9 A Tenu D. 8. Chealeal 8 . 3 . 1 9 .5 Goodrich (Juif 8.3*19*8 Ooodywur 9.t. rt.7 (Vtepreiwe g % %0 PUtftWtfri A r Kuttorl ^Vx#ei/ CRMC-MAD-000962 07724 MBECD OF WBT ODBC FKtCTIOIWOBRA1B 8.4 Metallic Chips or Partidas, Brass, Ceppar, Ziro, Cast Iran iS PXtT)C-LirS m m mum m m 8 .0 rmcnoa Htrsmis 8.5 Synthetic Atria* - eootiaaed 8.5.13 Mold^for Rs*in Twtiag 3 .6 Brake Blocks 8.7 Solvent Recovery Tests aad Methods 8.7.1 Activated Osrtoo Test Method* 8.8 Carbon Black 8 .9 Sulphur 6.10 Ozmphite *vr. *vu METHOD OP TEST XHDEX 9.0 MM2HE8XA 9 .1 Magnesia - Qeneral Control Testo 9.1.1 Control Toots on Solution at Mixing Boon 9.1.3 9 .1 .k 9 .1.5 9.1.6 9.1.7 Deteroimtioo of Btatoaeeeous Berth in Jtog. Insulation Magnesia - Sand Density fasts & Standards * Wet Density Determination of Asb. in Mag. Blocks & Covering Mhgaosla In Rysatuzuted Urns Calcium in Magnesia Block 9.1.9 Percent Solids in Slaked Dolomite Slurry 9*1.10 water Absolution 9.!> fUay*'* * *ta%*m Intel 9.2 Supcrex - General Control Tests 9 .2 .1 Supcrex - Shrinkage 9.2.2 Magnesia in Soperex 9.2*3 Gel value on Marsh Funnel - Bentonite Oel Value 9.2 .k Charts for simplifying calculation of MR on P/C 9*2*5 Charts for estimation of MBC in Supere* 9 .2 .6 Description of Method for Making Insulation Blocks 9.3 Magnesia - Supere* Pipe Covering & Blocks Method of Test t 9 .U Viscoslmatdr tests for Bentonite (See 10.1.2) 9.6 Investigation of the Detercdmtion of Calciun and Magnesium 9.7 Tests on Sil-O-Cell * 4 (*\icroctU 9*8 Zonolite (Unaxpanded Tera&culita) 9.10 Control Testo for presence of Miodex 617 for P. Ins. Jacketing Cloth 9.U Analysis of Variases and Acceptance Stapling Plan far Celite Blaine Suxfaoe'Areas 9*12 Coepressive Strength - Mtaosla end Buperax Blocks CRMC-MAD-000966 0 7 7 2 8 CRMC-MAD-000967 m m at m a m a x 10.0 C02BRTS 10.1 Refmrtorlea - O m n i Control Touts 10.1 .1 Sefmetorias So & Calcine Cloy 10.1.2 Refractories, Bentonite (See 9*0 10.1.3 Refractories, Analysis for High Alcals Bsfmctaries iO.l.fc Cross Section Constants for K.H. Calculations 10.1.3 Lonpoc Insulating Brick 10.2 Insulating - Genomi Control Tests 10.2.1 Tfisnlit1gggCgoed A M Btttofls for Testing Thersal 10.2.2 Insulating Shgsadte Vermiculite 10.2 .3 BsmlOene test for Bentonite 10.3 Plaster of Fari* Cenemi 10.3 .1 Control Tests 10.I Insulating Bridt Cenemi 10.U.1 Fireclay Brisk - Bor. of Stds. 10.5 Clays Miscellaneous Psnjhlcts 10.6 Vet Cements Cenemi 10.6.1 Consistency - Free Fall Kstbod of Tests (l&nvllle) 10.6.2 Consistency of Insltete 10.8 Linear Shrinkage of Haduins at Rupture - das Test Coment 10.9 Bpruyte Asbestos Fireproofing - Proposte Tentative Product and Inspection Standards CRMC-MAD-000968 i or r m m m ix,,o aorat p o o l s s r h o x o b t wxx 1 1 .1 Boeb o d - f l u i i 1 1 .1 .x o a etjn i fa sts 11.1.2 Potorinatlqa of M U H m n of PMilioot Patto 11.1.3 Pcfculaoftiao of Shot 1 1 .1 .P (1 * oc/fla&ar foots u/l/5 abilitar 11.1.6 Potarlaatioa cf faltbar 11.1.7 Etorprocfnoas U.1.8 Potcrlaotlca of Solubility of Mlaotml bol 11.1.9 Gala la ooigbt Aulas law <*ignition ^ 11.1.10 Patorlaotlon of Oat-cf-Oortca tfadmooo of roaUloat batto U ,1TU flig#lUiABd|iia 11.1.12 Potadaot&oa of IbgOj lo Slags A Mol 1 , 11.1.13 MDB SIP OcatoA H U a g por - otrUdag thni MBfin Of 1JRP X8DBC IlcO JOCK WOO. - OTBWaOBT wot 11.2 Bock Cock 1 1 ,3 Zam U tiag Boeri - O w o n l U . 3 .1 Xm o US&m Boord noiotaro control tcot U .3 r t . M * - O. S . B w t. f C-- K . CRMC-MAD-000971 0 7 7 3 3 mscDfXfTm m m 12.0 PAPgK MXli - HXUBOm 12.1 Paper Tasting * Osnarol * Conditioning & Weathering of Paper 13.1*1 Measuring Tbictaoss of Paper 1 2 .1 .2 Keroeeae Vent 12.1.3 Saturating Efficiency of Hoofing Pelts 12.1.4 Qal Teat Starch - Glue 12.1.5 Sponge Waste 12.1.6 Microscopic Brantnation 12.1.6.1 Pulp b Bapar fiber Coaposltlan 8ta0e. Bur. of 8ts> 12.1.7 Testing Pulp 12.1.8 Bags - Slide Bole for Dry Weight 12.1.9 Bags - Grading & Moisture 12.1.10 Apparatus tor determining vapor, etc. 12.1.13 TJUP.P.I. Ifcthoda Sonerai (All ln ana Book) .1 Molature in WOoA Cbip end SesiGnst by Toluene T-3 .2 Spedo* Identification of Wood liWood Pibera T-8 .3 Oondltlonlng and veatberlng of Paper .4 Secpltng and Rreparlng Wood fbr Annidale T-ll .5 strt in bod Chips T>JV .6 Smpllng Paper flor Testlng T-400 .7 Flber Ocnposltloa of Popar T-401 .8 Conditlonlng Espor and Papezhoard for Tostine T~k02. .9 Burotlng Strangth of Ppcr T-4Q3 .10 Tensile breaking atrengtb of peper and paperbcard T-4c4 .31 Psraffln in Paper -405 .12 Thlcimase snd Denslty of Paper T-411 .13 Molature In Popar end Baperbocrd T-412 .14 Ash in Piger T-413 .15 Internai Tsaring Seslatanee of Paper T-414 .lo Starch In Popar T-419 .17 Qualitative Analysis of tonerai Filler o d Minerei Casting of Paper f-4. .18 Settantine FTopertles of Booflng Pelt T-427 .19 Alpin Bota & Starna Cellulose ln Paper T-429 .21 Vet Tensile Bmaklng Strengtb of fiper and Fapsxboard .22 Surface Wettebllity of Pepar *>458 .23 Wax Tast to t Surffcse Strengtb of Paper - T-459 .24 WaecnMllty of Tratad Paper and Fagerfroard T-45i .25 Water Yspor PaxiBsabllltr of sbeet arteriale ah high par atura and bnaldlty T-464 CRMC-MAD-000972 8T .28 *29 crfEst^aa T-6S6 Point of Paraffin Wax T -630 Drainage tine of palp Tor XhsuUhing iUWtU u. 22,1.1b Rag Felts - General 12.1.15 Asbestos Papers - General 12.1.16 Mxllen Tester 12.1.17 Bonding of Hoist Brake Lining (Ko. 1 Tc^iv iAcliinc' 12.1.18 Determination of Chloride in Water and Water Letting:: .j Paper Laboratory /.par&tue for Making Paper Miscellaneous Equipment for Testing Paper 12.3 .1 Tear Taster 22.3 .2 Gurley Dcnsooeters 12.3.3 Stifftiesa Teatoro - General 12.3 .3.1 Tinlue Oleea StiffnftFC tiCCtcrs 32.5 .3 .2 iterloy Stiffncc; Tester 12.3 .3 -3 Stiffness Taster Clr.v 12.3 .^ Villiasc Freo^tra Teeter' 32." .5 Eiuipasat Tooting Piipov (Feaorccj:' 12.3 .6 Determination of Barnett Sice end Starch 12.3 .7 Sliaicide Residual Teat (Xeleo & Dovclde) 32.1 .2 Bennett Eire 12.5 12.6 12.7 Ibbortcoa Felts 1 2 .5 .2 Permit Fcra-Dlschergc to Eruvit'-'j*~cv?:t Saral! System Millboard General 12.7 .1 Hillbocrd TbicJmecs 12.72 Millboard Deflection 32.7-3 EULboerd -Triton BB Reagent IT.." .-: irillb-jf.3 Jlnos tlcrio? 32.7.5 KUXbotri - Alkalinity Teote 1 7 .7 .1' .iailbar.'C. Stare's Tectr xariicz Twrc: ' TJ5.C 7^6.1- on. Cortes': CRMC-MAD-000973 1 jwV>. 07736 %.-f rVA.\ .vy. *. M2TSCD OF SSST DESI 1 3 .0 pes coveremo - BEicaraas - saeacoustic 33. 1 Mpa Covwri - t e m i 13.1.1 Preahrunk Asbestocel ftPreahrunk Lodeoted Wool Pelt 13-1.2 Shrinkage Ssstc I3 .I.3 Conductivity Apparatus 13.1.3 .1 White Oteed Wfcegpere - P/C 13.1.3 .2 White Stoned P/C Untoruritoro' fixe test 13.IA Orovity of Selgslite Saturants 13 .2 elgolit# General 13.2 .1 Soig^alite (Plsct Fiber 8hoet Pecking) 13.2.1.2 Bevy Leakage t e t e 13.3 Glue far 8clgellte 13 A Control t e t e on SaaaeosifltiQ Coating 13A.I Salt spray test far corrosion of pointed surfaces I3 A .2 Sin Plato 13 A .3 Sont solutions for Parker Bust Proofing Teot Unit (Saaaoouctlc) 13A A point Seating (8ee file 2.1k) 13A.5 Balding teer in T Bars (Ssaccouatlc Pans Typs IAS) CRMC-MAD-000974 3 '*738 JffiTBOD OP VEST XXDEX. ik .o w m m lk.1 General - Analysis & Vesting lk.1.1 Texas Booting Go. lfe.1.2 The Buberold Oocpany lk.1 .3 Fllnttote - Qrcsula Vest lk.l.3 .1 Flintlcote Go. Cone Penetration Vest Ik.l.k U. 8. Oypstaa Co. lk.1 .5 Bird ftSon lk.1.6 Fhllllp Carey lk.1 .7 Certain-Teed Co. Ik.1 .8 Asphalt Booting Industry Bureau lk.1.9 Underwriters' laboratories lk.2 Sl&tpo - General lk.2.2 Slates - Adhesion of Hoofing Grandulec lk.2 .3 Booting Gabsule Gftloreseonoe lk.2.k BootingOracule Asphalt Stain lk.2 .3 Booting Crsnulo - Asphalt cdhesion J.!I. Method lk.2.6 Booting Granule Acid Beolotanee lk.2 ,7 RoofingGranule Blistering lk.2.8 Booting Qrerailo Eulfido Discoloration lk.2 .9 Booting Orenulos Semen Grading lk.2.2ft Booting Oramile Curftaoe Alkalinity . i4 .1 k .it deer/M C M * * * * trtm m m tm r* # 1k.2.12 Booting Granule Pigncnt Fixation lk.2.13 Booting Granule Hardness Ik.S.lk Booting Granule Steen Letch Test lk.2.13 Booting Porosity of Granules CRMC-MAD-000975 METHOD OF TEST DDDEX lk .0 BOQFXHG - continued 14.3 Tests on Mtualnca Mstsrlsls 14.3 .1 Softening Foist of Bit. Matorial Bing sad.Boll Katbod 1^.3 .2 Asphalt Products - Solubility In Carton Tetrachloride of C8g *! lU.3 .3 Asphalt Products - Loss on Boating 14.3.4 Asphalt Products - Specific Gravity lk .3.5 Particle Size of Axrphclt Eculsion (Inculicoto) 14.3.6 Fhoto-Bcusitivlty of Acphclt coating - Res. Test 11736 14.3.7 Filler la Costing Asphalts for Hoofing 14.3.8 Idvering Test 14.3 .9 Viscosity Chart 14.3.10 Fila Preparations end Bird Applicator 14.3.11 Kasticolca 14.3.12 Cfcroaatograpfcic separation of asphalt covenants 14.3.13 Barrett Slide Tests (Underwriters* Procedure R-99) 14.4 Flaoh Point - Various Methods 14.5 Penetration 14.3.1 Penetration - Stove Ritty Beedle 14.5.2 feeclslon Universal Penetroaater 14.5.3 Precision JOnior PenctroBcter 14.6 Fosa Test X4.7 Stain 14.7.1 CospataMllty Test 14.8 Weight per gallon 14.8.1 Valght per gallon sad Specific Qraivity 14.9 Consistency 14.9.1 Consistency of Silent Satuxont CRMC-MAD-000976 07741 SHOD 07 TEST IHEEZ lk.O ROOF3BO - continued lk.10 Tensile Strength end lacilnnr Strength lk.ll Hullen Strength Ik *12 m m i i t y 8& 7? SF F. 1U.12.1 Flexibility at 30 degrees F. lk.13 Kerosene Test Ik.lk Saturation Efficiency Ik.15 Extraction of Booflngs - Marrero lk.15.1 Extraction of Hoofing - Pittsburgh lk.15.3 Percent ^saturation - Tor Saturated Felts Ik.lJ.k HJUC.E. Asbestos Pipe Line Felts InirGaalc Content Ik.16 15 lbs. Asbestos Pipe Line Felts lk.16.1 Sot Tensile Strength lk.17 Perforated Felt lk.lB Silento Felts lk.19 ImraUrote lk.20 Apprtadmte Analysis of Aggregate from Masticofce lk.21 Dcflh Liners - Shsulctlon Tests lk.22 Oliensls Eetargenlty of Asphalt lk.23 Investigation o f Black Idne Products for Bed Label end Flash lk.2k Accelerated Weathering Tests lk.25 laboratory Asphalt still Asu*. PIibtiiI'v I OlidM etiing Preeedain lk.26 SUb Tests lk.27 Still too* Products Specifications lk.23 Faint Shop Product Specifications lk.29 Biqposune Decks CRMC-MAD-000977 p-- ____ ____ 77 ___ 07742 NB33QD OP TEST SUCK 14.0 BOQFTBQ - contlnnofl < v 14.30 White Top - Vlretard Bfft. Sffectivenesa of Vatenwoofing 14.31 Analysis of laSantrlal Flooring Mastics 14.32 Asphalt Boofing or Waterproofing Felts. - Lose on Beating 14.33 Volus Calibration of Booflng Plant Still 14.34 Back Coating Thickness 14.3$ Water Absorption 14.37 Stoaalte Solution Tests 14.38 Asphalt in Tar 14.39 Insulation Board Brick Siding 14.40 Roofing - Repairs and Utilities - War Dept. Kamel EI-5-6L7 14.41 Merrill Oil - Percent 8olids 14.42 Insulated Brick Siding Slnsv Test Coating Weight Shrinkage Blistering Test 14.43 Dye Test for Felt Saturation 14.45 Proposed Method of Test - Coal Tar Satunmt 14.46 Sesl-O-lfctic Splitting and 8ecling Desosstration 14.47 drays Ferry Accelerated Oscicg Test (Barrett) 14.48 Tar Saturated Volts M M V . f 0 C f f i # A A r M M * f a * a t Fi<xf CRMC-MAD-000978 07743 07744 MS39QD OF S E T IEEX 0 FLOCK CTUE (See 2.10.1 fbr Resin Test Mstho&s) 15.1 Asphalt ^1 - General Aephelt Kle institute 15 1.1 Heavy Tile 15.2 Inspection and Testing 15 .3 Brittleness 15 .t Color Ootqpsrlsca of Bose Cox^ounds 1 5 .5 Olsen Special 2fle Testing Machine 1 5 .6 Biehlo Hanfisaas Heater 15.7 Floor Tile - Miscellaneous 1 5 .U Methods end Specs. for Soap used on Floor file 15*12 Floor Hie Binder Contest 15.13 Csra end operation of IfcBurney Mentation Hester 15.lt Specification for Aagbalt HUe Adhesive 15.15 Methods of Heat - Vinyl fieola 15*16 Solids In Tile Vox CRMC-MAD-000980 07745 I mamapmrmsx. l.0 BBXHCOSt 1 6 .1 Asbestos Stains Shingles - General 16.X.X watzol Tests an 10$ Siding Shingle - Vet end Dry Process 16.1.2 Oraim& Scrap for Rigid Ehinglen 16.1.3 Itspact Apparatus 26.1 .1 Add Dipping l6.1.$ Density by Mercury Dlcplscanent 16.1.6 Chemical Analysis 16.1.7 Vadhing Eb. 607 Shingles 16.1.8 Mstbo& of Tout 16.1.9 Dye fbr Stashing Adtsstos Shingles 16.1.10 Silicone Sects 16.2.1 Scg Test Procedure Us. 9 *<.4140 tttf M M U d M S d CRMC-MAD-000981 07747 1G2B0D OP TEST JUDEX. 17.o m u o m w o o d akd f l exb qa rd 17*1 Asbestos Wainscoting 17.2 Flat Transit - General 17.2.1 Encased Transit 17.2*2 Transit Cora EUfces 17.2.3 Perforated Trancite Panels and Acoustical Tils 17.2.4 Ebony, Cfcastane and Cboostoee 17.2.3 Modulus of Rupture Cfcrrvgated Transit end Density 17.3 Corrugated Transits - Freezing and Tawing Resistance 17 .4 Ground Flertboard Scrap CRMC-MAD-000982 07749 # mm> w new m n a | C\_. " lfl.o'33UBQE ras JU8.1 Transit* Pressure Pipe and Couplings - General 18.2 Transits Conduit - General 18.2.1 Conduit Couplings - Plastic 18 .3 Busbar Bings - General 18.3 .1 Hostess* of Rubber 18 .5 Protectivo Costings on Corrugated Transit* Bolts end Fasteners 16.6 Asbestos Lusher (Trenslto) General Electric Cb. 18 .7 Alkalinity In Asbestos Csaant Pipe 18.7.1 flulitoie Acid Extraction Tsat 18.7 .2 Free Zdss Test for Transit Pipe 18.8 Eepid Matted todaternine percent- iwaido is ?t 18.8.1 Deteredeatlon of mlstur In Asbestos Cesaast Protects using Alcohol as AbcoAeat 18.9 Transit* Air Duct Corrosion Resistance, non-disintegrating and fire resistance. 18.10 Bing- Tits Lubricant 18.11 Boldness of Rsv Srcaslte Pipe Pleat 8aads by grinding cosparlcon 18.12 Oca Vent Boll Bosistaueo Test 18.13 Colson Content - Mold Shower Voter I8 .1V Pleat 325 UiSh ScreenAaalyris for Silica Flour 18.15 Crushing Strength - Brrse Edge Bearing Method ( CRMC-M A D -0 0 0 9 8 3 07751 ______ utU7 Jly 19. 193* * f i n c m i or acrac o b l o b x k f t CLtAinO Wf T PKOTKTOBl ,,.m m eiA s------- ------- ,r ( I Bureari feltri C m l eksywtlAi* 1 IjfirtAlwrll 4 M Alhl U W SB* 1.0 0 p . T.S 100.00 w . 505.00 la tU lo i IfO U tm km 100*00 . ' \ \ 9 CRMC-MAD-000984 07753 , V? pctobcf 9 197h J f. Hr. 1!. 8. Vanderbilt "**** * President . _ . Chief Executive Officer * * . R. T. Vanderbilt Company, Inc.* . . .30 Vinficld Street Korvalk, Connecticut 08855 ** * Hear Mr. Vanderbilt:. . * * . of 1 This is In reply to your letter of Septeeber 26, concerning your request for relief froa the asbestos standard for your talcs containing noa-fibrous trenolite, actinolite, and anthophyllite. MFjr letter of August 6 stated that non-fibrous or non-asbestiforo minerals such as non-asbestifora trenolite are not within the ccopc of the asbestos standard and, therefore, the provisions of that standard do not 'apply to talc containing non-asbestifora minerals. KIOSH is currently conducting a thorough 'invest! jliic the exact minerals to which talc workers were exposed -in. those studies where asbestosis or other adverse nedical effects were found Pending the receipt and evaluation by OSEA of the report by KIOSH on this investigation, if you have scientific evidence that the naturally occurring talcs, prior to' processing by cilling or crashing, do not contain fibrous or asbestifom trecolite, nntophylllte, actinolite or other asbestifom ninerals, you nay certify toyour customers that the talc does not contain asbestos. Fibrous, asbestifom ninerals such as fibrous trenolite ceans naturally occurring asbestifom ninerals vhich prior to or after crushing and processing,- contain fibers, cade up of fibrils. Sincerely, /s/ John H. Stender - John H. Stender Assistant Secretary of Labor ______ ^ SUT0 0 2 0 __ C R M C - M AD-000985