Document OGpDBbvyowgJwKznYjEwprde

FILE NAME: Talc (TALC) DATE: 2019 Feb DOC#: TALC189 DOCUMENT DESCRIPTION: Journal Article - Asbestos Commercial Indian Talc Received: 8 August 2018 I Revised: 14 February 2019 I Accepted: 17 February 2019 DOI: 10.1002/ajim.2299 BRIEF REPORT W il e y n>Cho^.: 'or updates AMI KK W JiM R\ \ l Ol I M X M K I M Ml I H H M Asbestos in commercial indian talc Sean Fitzgerald BS, PG1 | Elizabeth Harty M P H J | Tushar Kant Joshi MBBS, MS, MSc3 Arthur L Frank MD, PhD4 i5 1Scientific Analytical Institute, Greensboro, North Carolina 2HHC Environmental, Lebanon, Ohio 3Mlnlstry of Environment, Forests, and Climate Change, Government of India, New Delhi, India 4Drexel University Dornsife School of Public Health, Philadelphia, Pennsylvania Correspondence Arthur L Frank, MD, PhD, Drexel University Dornsife School of Public Health, 3215 Market Street, 7th Floor, Philadelphia, PA 19104. Email: Alfl3@drexel.edu Abstract Background: Easily available commercial Indian talc products widely used in Southeast Asia were examined for the presence of asbestos. Asbestos in talc Droducts carry all risks of asbestos-related disease. Methods: Using polarizing light microscopy, transmission electron microscopy (TEM), electron diffraction, and X-ray analysis, multiple over-the-counter Indian talc products were examined for the presence of asbestos. Results: Results In an initial group of five Indian talc products, one was found to contain tremolite asbestos. The second group of eight products was tested and six of eight contained tremolite asbestos as well. No other regulated amphibole was found. Conclusion: Large quantities of body talc products containing asbestos are used throughout Southeast Asia and are likely to pose a public health risk for asbestosrelated diseases, especially for the cancers related to asbestos exposure. The country of origin in which the talc examined was sourced for production is unknown to the authors, and further investigation to measure associated public health risk is needed. KEYWORDS asbestos, cancer implications, consumer products, Indian talc, trem o lite 1 | INTRODUCTION As the international e ffo rt to elim inate asbestos-related diseases continues1 public health concerns surrounding the presence of asbestos in consumer talc products persists.2' 5 This is not a recent developm ent6 Rohl, Langer, and Selikoff78 raised the awareness of asbestos in talc and personal talc products over 25 years ago. Talc is composed o f the elements magnesium, silicon, and oxygen, and is classified as a hydrous silicate mineral.51 The asbestos-forming minerals serpentine and amphibole form under sim ilar geologic conditions as talc, and are also hydrous silicate minerals containing magnesium, silicon, and oxygen. It is this close minralogie relation ship th a t is responsible fo r the common comineralization o f talc and asbestos, not to be confused w ith a contam inant th a t was added after the mine.10 Talc has been comm ercially used in personal hygiene and cosmetic products to aid in keeping skin d ry and prevent rashes, as this mineral can be fin e ly ground, provide absorbent anticaking properties, and prom otes a soft, cool feel.4,5,9 Since the late 19th century, the intim ate relationship between talc and asbestos form ations has been observed by the geological and industrial communities.7,8'10"13 The International Agency fo r Re search on Cancer (IARC) recognizes this relationship and holds the position th a t any talc supply o r products th a t contain asbestos should be treated as asbestos, accordingly a Group I carcinogen. In fact, the IARC W orking Group decided to expand the name of the Group I carcinogen from "talc containing asbestiform fibers" to "talc contain ing asbestos o r o th er asbestiform fibers," which " should be under stood to mean any mineral, including talc," when it grows in the asbestiform habit.5 It is, therefore, relevant to consider w hat the medical implications and public health consequences are fo r This is an open access article under the terms of the Creative Commons Attribution-NonCommercial-NoDerivs License, which permits use and distribution in any medium, provided the original work is properly cited, the use is non-commercial and no modifications or adaptations are made. 0 2019 The Authors American Journal of Industrial Medicine Published by Wiley Periodicals, Inc. Am J ind Med. 2019;l-8. wileyonlinelibrarY.com/journabailm | 1 FITZGERALD rr al. populations which are exposed to these substances in domestic settings in addition to traditional workplace settings. The medical implications o f using talc products containing asbestos include the m alignant and nonmalignant diseases associated w ith any asbestos exposure as w ell as those related to talc.5 IARC has established a causal association between all form s o f asbestos exposure and cancer o f the larynx, lung, ovaries, peritoneal mesothelioma, and pleural mesothelioma.5 Nonmalignant diseases associated w ith asbestos include asbestosis, asbestos warts, and pleural effusion, pleural plaques, and diffuse pleural fibrosis514 O ther reports o f disease among those exposed to asbestos include renal, oropharyngeal, and gastrointestinal cancers.14,15 Talc w ith o u t asbes tos can itse lf produce talcosis.16,17 A review o f the lite ra tu re th a t examines asbestiform materials not regulated as asbestos finds th a t either deposits w ith only true asbestos are being reported on w ith no admixed minerals. W hen there is evidence o f asbestiform materials as part o f the talc deposit there is usually also evidence o f regulated asbestos fibers; therefore, it is d iffic u lt to state w hat role ju st nonasbestos asbestiform materials on th e ir own may be playing in the health o f those populations studied.18 The W orld Health Organization (WHO) reports th a t 125 million people are occupationally exposed to asbestos w orldw ide and th a t approxim ately half o f all occupational cancer deaths are believed to be caused by asbestos.1The W H O fu rth e r states that global asbestos exposure in the home is associated w ith several thousand deaths annually.1 There are no population estimates o f those exposed to asbestos contaminants in personal care products; therefore, sub stantial data to measure the past and fu tu re asbestos-induced burden o f disease are not available. This lack o f adequate data is significant when considering the traditional underreporting of diseases, such as mesothelioma.19 W hile W estern countries, such as the United States, have the capability to engage in the surveillance o f diseases, such as mesothelioma,20 many developing nations throughout Southeast Asia exercise minimal to no mesothelioma surveillance.21 In addition to the minimal surveillance o f asbestos-related diseases in Southeast Asia, the m ajority o f these countries continue to perm it the commercial use o f asbestos despite its health effects,22,23 which is counter to the trends in global asbestos production and consump tio n .23 The com bination o f these circumstances amplifies the challenge fo r public health. Many o f these nations, such as India and other Southeast Asian countries, face the risk o f dermal heat disorders due to the hot and tropical climate.24,25 One such disorder is miliaria, a widely recognized, heat-induced dermatitis that presents as a rash and has been documented since the tim e o f Hippocrates.26 In modern vernacular, the condition is commonly referred to as " prickly heat".26 The risk of miliaria is significant fo r anyone exposed to a hot and humid climate. Those o f lower socioeconomic status, who usually have more exposure to these conditions, are at elevated risk.25 In India alone, the population exceeds 1.33 billion, representing a significant portion o f the global population exposed to the risk o f heat stress.27 To combat the risk of sweat-induced dermatitis, major manu facturers m arket talcum powders (cosmetic-grade talc) to the Indian and greater Southeast Asian populations,16 These powders are advertised to cool against the effects o f " p rickly heat" and some claim to have bacteriostatic effects. These powders come in a variety of scents that would appeal to a wide range o f consumers. In light o f the recent evidence o f the asbestos contam ination (or, more accurately asbestos comineralization) and subsequent personal in ju ry litigation related to personal hygiene and cosmetic talc products sold in the W est, the objective o f this study was to determ ine if sim ilar product contam ination is observed in cosmetic talc sold in the East, as it is known th a t commercial talc deposits exist in India2,3,10,28-30 2 | METHODS 2.1 I Analytical procedures Polarized Light Microscopy (PLM) and Transmission Electron M icro scopy (TEM) analyses were conducted follow ing the analytical procedures described in the U.S. Environmental Protection Agency "Test Method EPA/600/R-93/116. Method fo r the Determination of Asbestos in Bulk Building M aterials". PLM analyses were conducted on a Leica DM 750P petrographic microscope w ith cross-polarized filters, wave retardation, and dispersion staining techniques at magnifications up to 400. TEM analyses were conducted on a JEOL 2000FX TEM equipped w ith energy-dispersive X-ray analysis (EDXA) and selected-area electron diffra ctio n (SAED) at magnifications up to 50,000, a t an accelerating voltage o f lOOKeV. Since it has been repeatedly found th a t countable asbestos structures can occur in talc below the resolution o f PLM7,31 TEM analysis was conducted on all samples when definitive results were not obtained through PLM alone. Further, it has been shown th a t as little as 0.001% o f asbestos in loose clay soil can produce around 0.1 fib e r/cc o f asbestos in the a ir w ith a respirable dust concentration o f around 5 m g/m 3.32 Data from Libby, Montana, and o ther sites in the US provide evidence th a t soil/debris containing significantly less than 1% asbestos can release unacceptable air concentrations o f all types o f asbestos fibers (ie, serpentine chrysotile and amphibole trem olite).33 The TEM analytical area o f final preparations was therefore expanded to increase analytical sensitivity, i.e., th e area of th e final filte r analyzed was increased to facilitate detection o f low er asbestos fiber concentrations. Q uantification o f countable asbestos structures per gram weight talc (str/g) was facilitated in TEM final analyses based on the asbestos counting criteria fo r structures containing fibers greater than 0.5 microm eters in length w ith at least a 5:1 aspect ratio, as described in the Asbestos Hazard Emergency Response A ct (AHERA) and ASTM methods D6281, D5755, D5756, and D6480, as w ell as in ISO 10312 and 13794. These counting criteria are consistent w ith the procedure fo r the analysis o f talc fo r asbestos as published by M ille tte.34 Also consistent w ith M ille tte, analytical sensitivity varied based on to ta l filte r particle loading and area analyzed.3" 16 FITZGERALD n al 2.2 | Preparations The samples were prepared fo r PLM analysis by in itial examination under a stereomlcroscopc at magnifications between 4 to 20*. Grain mounts were representative o f the homogeneous powder con structed using appropriate refractive index llquid(s) fo r the d eterm i nation of optical characteristics consistent w ith the asbestos-forming minerals. For electron microscopy analysis, a portion o f the sample was weighed and suspended in an alcohol/ deionized w a te r mix. Measured aliquots o f the sample suspension were then filte re d through a 0.2 pm mixed cellulose ester filte r (MCE). The final MCE filte r was dried, collapsed w ith acetone, and coated w ith carbon in a vacuum evaporator The fibers and solids collected on the carboncoated filte r replicate were transferred onto copper grids fo r TEM analysis. 2.3 I D etection limits A ll TEM scans in this analysis were at a minimum o f 200 grid openings fo r samples w here no fibers are identified. If there are abundant fibers, that number can decline significantly when a smaller number o f grid openings demonstrate sufficient concentration calculation. The analytical sensitivity is therefore variable based on the overall loading of the filter, the number o f grid openings, analyzed aliquot o f the suspension, size o f the individual grid openings, and weight o f the original talc suspended. O f course, the actual size o f fib e r can vary greatly, so concentrations calculated as asbestos structures per gram are not d ire ctly comparable to a weight percent o r parts per m illion value. Detection lim its in this study, therefore, varied from sample to sample, depending on the optim um suspension d ilution required to achieve appropriate loading, as w ell as relative ease o r d ifficu lty in finding the asbestos fibers on the final filtrations. Generally, the lowest detection lim its calculated were fo r those samples w here no fibers w ere detected, in the 1 x 106 structures per gram range, which w ould equate to <0.0001% by weight, assuming average fibers o f 5 pm x 0.25 pm, and the specific gravity o f those fibers based on the mineral trem o lite (the most common asbestos type determ ined in this study). Each sample was prepared by suspending 20 to 80 mg o f th e talc product in 400 mL o f w ater/alcohol mix, followed by filte rin g 1 to 5 mL o f that suspension onto a 47 mm filte r which was then prepared fo r direct examination under TEM on copper grids. The analysis is an in itial scan o f the preparations, a minimum o f tw o grids each containing 100 grid openings o f variable size (usually approxim ately 0.0 1m m 2) are scanned at 1200x, and individual fibrous structures evaluated at 25,000x (chemistry by EDS, crystal structure by diffraction, and fib e r morphology, eg, length and width). 2.4 I Initial sample set In February 2015, five samples o f commonly available, over-thecounter brands o f cosmetic talcum powders were purchased in India; WLEY some products were manufactured by multi-national corporations that originated in the United States. The mining source and location o f talc used in these products are unknown. These purchases were made on the open m arket available to all Indian customers. The products were marketed fo r personal application as " beat the heat" fragranced talcum powders to be applied to the skin o f the consumer. A ll samples were shipped to a testing laboratory fo r the purpose o f evaluation. The product samples were labeled as 1) '1A Talc," 2) 'IB Talc,"3) '1C Talc,"4)'1D Talc,"and 5)'1E Talc." Testing o f these talc products was conducted to assess the presence o f asbestos, and w hether the asbestos present in these samples was aerosolizeable and quantifiable. W hen testing is conducted fo r asbestos and talc in th e lab setting, the presence o f fibrous talc and possible transitional structures are noted when observed. The samples were tested to include examination by SAED) and EDXA; a.k.a,, EDS o r EDX). 2.5 I Repeat testing o f initial sample set To confirm the firs t test results, these original five samples underw ent a repeat analysis using the same test methods. The presence o f asbestos, specifically, asbestiform trem olite, was confirm ed in one o f the products (" ID Talc"). As the presence o f asbestos in this commonly available talc product was found to be substantial and repeatable, it was decided th a t fu rth e r testing of o th er available personal hygiene talcs from India was warranted. The testing lab made online purchases o f fo u r additional varieties o f talc products sold by the same m anufacturer as the above product, as well as fo u r varieties o f another talcum brand ('fA Talc') through an Indian based retail outlet. 2.6 I Second sample set This second set o f samples were labeled as ( l) 'f D . l Talc," (2)'1D.2 Talc,"(3)'1D.3 Talc,"(A) '1D.4 Talc,"(5)'1A.l Talc,"[6)'1A.2 Talc,"(7)'1A.3 Ta/c,"and (8)'IA.4 Talc "T h e samples w ere tested in the same manner as the initial sample set fo r the presence o f asbestos in those products using the same analytical methods. 3 | RESULTS 3.1 | Initial sample set product; analyses, light microscopy In th e in itia l sample set, analysis o f preparations revealed abundant mineral particulate, including platy and fibrous talc in all products tested (see Table 1). PLM analysis was able to determ ine th a t the products contained fibers w ith optical properties consistent w ith talc and some possible asbestiform amphiboles. Overall, th e talc product was found to be fibrous by light microscopy. Preparations o f the sample were, therefore made fo r the determ ination o f potential asbestos content by TEM. W iley T A B L E 1 Initial sample set analytical summary Product (initial sample set) IA Talc IB Talc 1C Talc ID Talc IE Talc First qualitative assessment of trem olite asbestos Presence: Yes or No No No No yes No Second qualitative assessment of trem olite asbestos Presence: Yes or No No No No Yes No 3.2 I Initial sample set: Asbestos analysis Subsequent analysis o f the initial set by TEM analysis confirm ed the PLM findings o f abundant m ineral fibers including fibrous talc in all of the initial Indian talc products tested. Fibrous talc is noted when the mineral appears as fibrous o r bundles both by light microscopy, such as PLM, and electron microscopy, such as TEM. The presence of asbestos, specifically asbestiform trem olite, was confirm ed only in the 'ID Talc"p ro d u c t (see Figure 1); the asbestiform structures were o f a countable concentration above baseline background.34 This is classified as substantial asbestos, th a t is, asbestos fibrous structures were found m eeting the counting criteria o f all airborne asbestos containing methods.35,37'39 FITZGERALD et al T A B L E 2 Second sample set analytical summary Product (second sample set) IA1 Talc IA 2 Talc IA3 Talc (A4 Talc ID .l Talc ID.2 Talc ID.3 Talc ID.4 Talc PLM findings of abundant mineral fibers including fibrous talc? Yes Yes Yes Yes Yes Yes Yes Yes TEM quantitative identification of trem olite asbestos? Yes Yes Yes Yes No No No Yes 3.3 | Second sample set: PLM and TE M analyses for fibrous talc and asbestos PLM findings o f abundant m ineral fibers including fibrous talc was evident in all o f the second sample set o f products. TEM analysis was able to qualitatively id e n tify trem o lite asbestos present in '1D.4 Talc" and th e '1A1 Talc,"'1A2 Talc,"'1A 3 Talc,"and '1A4 Td/c"products (see Table 2 and Figures 2-5). Asbestiform trem o lite fib e r s tr/g were also quantified fo r these same talc products. Concentrations of trem olite asbestos in the products were calculated fo r structures less than 5 pm and greater than 5 pm; the sum o f the structure totals (less than 5 pm and greater than 5 pm) are reported as all structures (see Table 3). Among these,'1A3 Talc" had the lowest to ta l trem o lite asbestos at a sum o f 4.55 million str/g, w ith higher levels in 'I A l Talc" (10.5 m illion structures per gram), '1A2 Tofc"(14.4 m illion str/g), '1A4 Talc" (20.4 m illion str/g), and '1D.4 Talc," which contained a sum of 59.9 m illion str/g o f trem o lite asbestos. 170015 TEM Magntftcabon 4,000k fOTmk: ttrimUt* F IG U R E 1 Trem olite asbestos fib e r in " ID Talc," found in the firs t testing of this product. TEM magnification 4000x. Total fiber dimensions 61.5 pm long by 0.5 pm wide equates aspect ratio >120:1 This figure shows the part of the fiber extending into the grid opening. The m ajority of the fiber-structure length extends underneath the copper grid bar (to the right of the structure), extending into the adjacent grid opening. As can be seen from the micron marker, less than one-third o f the e n tire length was captured in this image. This image demonstrates well th e amphibole details alongside platy/sheets o f talc. TEM, transmission electron microscopy [Color figure can be viewed at wileyonlinelibrary.com] 3 .4 I A sbestiform talc structures d etected in samples Abundant fibrous structures o f the m ineral talc were identified in the cosmetic talcum powders tested. Two basic morphologies were common o f the fibrous talc: more parallel fibers or ` bundle of sticks" talc structures were observed, in addition to more lath-like " ribbons" o f talc, often exhibiting kinks, beds, o r folds. Although many o f these structures would be countable as asbestos if they were th e minerals regulated as such, the use o f the term "asbestiform " when describing talc is controversial. As talc is a replacement mineral th a t does not crystallize from m olten rock, it is often pseudomorphic a fte r the protolith, th a t Is, form s the shape o f the m other rock from which it was derived. Although it is common to observe the mineral anthnphyl Iite in association w ith talc, th a t mineral was not observed in any o f the samples in this study. Fibrous talc was observed in all o f the samples analyzed fo r this study, occasionally in abundance, but talc fibers or fib e r structures w ere not quantified, as there are no published methods or counting criteria fo r talc fibers or complex structures. FITZGERALD et al W iley i 10W2015 HT 100KV TEM M agnicson SfXXtt tD.4 Tak: TrtfttoUt* F IG U R E 2 Trem olite asbestos fib e r bundle in "ID.4 Talc," found in the second batch of testing this productTEM magnification 3000. Bundle dimensions are 13.1 pm long by 0.74 pm wide. Bundle thickness comprises numerous individual fibers w ithin the structure; therefore, length to w id th aspect ratios should be based on constituents rather than whole bundle widths. As this structure comprises over a dozen individual fibers, it is inappropriate to calculate aspect ratio as 13.1/0.74 = 1:17.7, as known individual fibers greatly exceed th a t aspect. TEM, transmission electron microscopy [Color figure can be viewed a t wileyoniinelibrary.com ] -C'*' Six-Jn li F IG U R E 4 Selected-area electron diffra ctio n (SAED) o f tre m o lite structure found in the Indian talc product "ID.4 Talc." All asbestos structures used in the calculation o f concentrations in this report were confirmed by morphology, chemistry (by energy-dispersive X-ray analysis: EDXA/EDS). and crystalline structure as demonstrated here by diffraction (SAED). Notice the 5.3 Arepeat o f streaking lines consistent w ith the amphibole structure, and the arcing b righter bands dem onstrating a nearby crystal zone axis Analysis and quantifications were therefore lim ited to the six minerals regulated as asbestos, w ith established counting criteria. 4 | DISCUSSION 1W W 3015 nr tootcv TEMMsgntc*on 5000 f A / tak. Trrpwkto F IG U R E 3 Trem olite asbestos fib e r bundle in " IA 2 Talc," found in the first testing o f this product. TEM magnification 5 0 0 0 . C onstituent fibers >10 pm in length, less than 0.1 pm in w id th demonstrate aspect ratios up to and exceeding 100:1. Note both platy and fibrous talc also observed.As a bundle is defined as three o r more fibers (or 2, by the international Organization fo r Standardization (ISO)) parallel and not separated by more than the w idth o f a fiber, a bundle contains constituent fibers by definition. The m icron m arker was placed on the image when at the scope. This provided the ability to resolve the other end through the crystal from which it protrudes (conservative analysis indicates aspect ratios exceeding 100:1) [Color figure can be viewed at w ile yo n lin e lib ra ry .c o m ] This product study o f various talcum powders m arketed to combat prickly heat, purchased from Indian retailers both over-the-counter and online, demonstrates the ease o f general population access to such products and th e potential fo r significant exposure to asbestos. The analytical results o f this study confirm th a t asbestos exposure o f the Indian and potentially greater Southeast Asian populations is not lim ited to trad itio n a l occupational settings. Products sampled in this study are sold in containers w ith 150 grams o f product o r more. For those products that tested positive fo r tre m o lite asbestos, the to ta l product contamination fo r their containers ranges between a low of 600 m illion asbestos structures to high o f 8 billion asbestos structures. These findings im ply th a t the asbestos-related medical and public health implications to consider w ill need to extend to persons o f both genders and all ages among this population group. This study's confirm ation o f an underappreciated source of asbestos exposure, through personal care products, also highlights the risk th a t anyone w ith in breathing range o f these aerosoiizeable, contaminated, talcum products incurs. W ith products o f this nature being readily available and appealing to both genders, it is necessary to consider w hat the potential health risks and burdens o f disease are fo r m illions o f exposed wom en o f childbearing age and the children fo r whom th e y provide care. IARC has confirm ed the causal association o f asbestos w ith ovarian cancer and o th er cancers.5 Shifts in perspective in epidemiologic surveillance are needed to F IG U R E S Energy-dispersive X-ray spectrum (EDX/EDS) showing chem istry o f amphibole structure pictured in Figure 3 (trem olite bundle in " IA 2 Talc"). Relative ratios o f magnesium (Mg), silica (Si), calcium (Ca), and iron (Fe) are consistent w ith th e recognized chemical form ula fo r the mineral trem olite: {Ca2KMg5.0-0.5Fe0.0-0.5}(Si8O22)(OH)2. O th e r peaks observed include oxygen (O) observable from the low-element detector used, and copper (Cu) resulting from the copper grid sample substrate [Color figure can be viewed at w ileyonlinelibrary.com ] consider how to b e tter collect, analyze, and disseminate data th a t apply to these consumer product exposures. It may also help us better understand a previously underappreciated source o f exposure fo r those w ith asbestos-related cancers when no history o f exposure can be elicited from those individuals. A necessary measure to prom ote public health is to mandate quality control standards th a t guarantee all talc intentionally added as an ingredient to consumer products is tested before production and repeated testing is applied during production. Analyses conducted by the most rigorous and sensitive methods possible are required to assure the absence (ie, nondetectability) o f asbestos in products. Further records o f where the talc was mined, and the specific records o f testing must be maintained. End-users and m anufacturers o f those talc o r talcum powder products should be held accountable fo r this inform ation and make it available to consumers. India's Consumer Protection Bill 2018 proposed legislation th a t would provide a measure o f increased consumer protection; although, it remains under pending status in parliam ent.40,41 If this o r a sim ilar bill eventually passes, India w ill be taking needed steps tow ard (a) establishing a central consumer protection authority, (b) subjecting manufacturers to imprisonment if they are found guilty of false o r misleading advertising, (c) subjecting manufacturers to im prisonm ent if they are found g u ilty o f the sale, storage, d istrib u tion, o r im porting o f products th a t contain adulterants, and (d) introducing product lia b ility action and class action concepts as avenues fo r consumer compensation.40 W hile the passage o f this bill is a start tow ard protecting public health in general, un til asbestos is also viewed as a hazard in India and banned, there w ill still be considerable risk to h e a lth *'21 The presence o f amphibole asbestos (trem olite) among th e products analyzed in this study confirm s th a t asbestos exposure in India and potentially beyond is not lim ited to occupational origins. This heightened awareness o f trem olite exposure in consumer products in India should also raise public health concern fo r the co u n try th a t utilizes roughly 350,000 tons o f chrysotile asbestos in approxim ately T A B L E 3 Trem olite asbestos structures count per gram (str/g) product Product IA. 1 Talc IA.2 Talc IA.3 Talc IA.4 Talc ID.4 Talc Structurer <5 pm 6,280,000 str/g 7,210,000 str/g 3,030,000 str/g 15,300,000 str/g 20,000,000 str/g Structures ^5 prr 4,190,000 str/g 7,210,000 str/g 1,520,000 str/g 5,090,000 str/g 39,900,000 str/g A il Structures 10.5 million str/g 14.4 million str/g 4.55 million str/g 20.4 million str/g 59.9 million str/g FITZGERALD ETAL. 100 manufacturing plants--producing products such as cement piping, cement roofing, frictio n materials, textiles and insulation-- w ith little regulatory oversight.42 These 100 m anufacturing plants employ nearly 300,000 employees.42 The products these asbestos using m anufacturing plants produce are reaching m illions w ith in India alone. The lim itations o f this study pertain to its design. The study was designed to demonstrate the potential fo r health risks and did not endeavor to id e n tify health outcomes. It is not known to the authors where the manufacturers o f these products marketed throughout India and Southeast Asia sourced th e ir talc supply. The only fibers analyzed fo r this study were the six regulated fibers collectively called asbestos. 5 | CONCLUSION Some global talc deposits are free o f asbestos, w hile others are not.5,7,8,10' 13 Therefore, significant policy updates are necessary to promote product safety and accountability that protects the interest o f consumers.42 W ith o u t such measures, m illions o f people w ill be at heightened risk fo r asbestos exposure due to personal care talc products th a t contain millions o f countable asbestos structures in every teaspoon fu ll equivalent and diseases caused by such structures. It is confirm ed th a t these product samples are among those marketed and sold over-the-counter and online In India and other Southeast Asian countries. It is believed th a t this is the firs t report of such findings in India. It carries public health implications fo r Southeast Asia in general, and perhaps beyond. This study confirm s th a t asbestos exposure in India and potentially elsewhere is possible through nonoccupational avenues previously overlooked. AUTHO R C O N TR IBU TIO N S TKJ conceived th e idea fo r this w o rk assisted w ith w ritin g and p a rticip a te d in th e fin a l approval o f th e version to be published. EH assisted w ith w riting, conducted bibliographic research, and participated in the final approval o f the version to be published. SF assisted w ith w ritin g , conducted analyses o f materials, participated in the final approval o f the version to be published, and was engaged in geologic, minralogie, and laboratory w ork regarding asbestos, and has been retained by both p la in tiffs and defendants in asbestos and talc-reiated m atters. ALF participated in the design o f the w ork, provided bibliographic references, assisted w ith w ritin g , participated in the final approval o f the version to be published, and has engaged in m edical/legal w o rk regarding asbestos, generally fo r plaintiffs. ETHICS A P P R O V A L A N D IN F O R M E D CONSENT No reviews and approvals needed, no human subjects. DISCLOSURE (AU TH O R S) -WILEY Dr. A .L Frank regularly engages In medical/legal w o rk regarding asbestos, generally fo r plaintiffs. S. Fitzgerald, PG regularly engages in geologic, mineralogie, and laboratory w o rk regarding asbestos, and has been retained by both plaintiffs and defendants in asbestos and talc-related matters. DISCLOSURE BY A J IM ED ITO R OF RECORD None. D ISCLAIM ER None. O R C ID Arthur L Frank 0 http://orcid.org/IXi00-0001-704O -9520 REFERENCES 1. Asbestos: Elimination of Asbestos-related Diseases. wvrw.who.inL http://www.who.int/news-room/fact-sheets/detail/asbestos-eliminationof-asbestos-related-diseases. Updated February 15,2018. Accessed July I t 2018. 2. Feeley J, Cronin-Fisk M. J&J faces high stakes trial over 22 women's talc claims. Bloomberg Web site. https://www.bloomberB.com/news/ articles/2018-06-06/j-j-facing-high-stakes-talc-trial-over-22-womens-cancer-claims. Published June 6, 2018. Updated June 6, 2018. Accessed July 11, 2018. 3. Gordon RE, Fitzgerald S, M ille tte J. Asbestos in commercial cosmetic talcum powder as a cause o f mesothelioma in women. 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Accessed July 20, 2018. H ow to cite th is a rticle: Fitzgerald S, H a rty E, Joshl TK, Frank A L Asbestos in commercial indian talc. Am J Ind Med. 2019; 1-8. https://doi.org/10.1002/ajim .22969