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FILE NAME Talc TALC DATE 2014 DOC TALC118 DOCUMENT DESCRIPTION Journal Article - Asbestos in Commercial Cosmetic Talcum Powder as a Cause of Mesothelioma in Women Asbestos in commercial cosmetic talcum powder as a cause of mesothelioma in women Ronald E. GordonSean FitzgeraldJames Millette Department of Pathology Icahn School of Medicine at Mount Sinai New York USA 2SAI Laboratory Greensboro NC USA MVAInc. Duluth GA USA Background Cosmetic talcum powder products have been used for decades The inhalation of talc may cause lung fibrosis in the form of granulomatose nodules called talcosis Exposure to talc has also been suggested as a causative factor in the development of ovarian carcinomas gynecological tumors and mesothelioma Purpose To investigate one historic brand of cosmetic talcum powder associated with mesothelioma in women Methods Transmission electron microscope TEM formvar grids were prepared with concentrations of one brand of talcum powder directly on filters from air collections on filters in glovebox and simulated bathroom exposures and human fiber burden analyses The grids were analyzed on an analytic TEM using dispersive spectrometer EDS and selected electron diffraction SAED to determine asbestos fiber number and type Results This brand of talcum powder contained asbestos and the application of talcum powder released inhalable asbestos fibers Lung and lymph node tissues removed at autopsy revealed pleural mesothelioma Digestions of the tissues were found to contain anthophyllite and tremolite asbestos Discussion Through many applications of this particular brand of talcum powder the deceased inhaled asbestos fibers which then accumulated in her lungs and likely caused or contributed to her mesothelioma as well as other women with the same scenario Keywords Asbestos Talcum powder Chamber test TEM SEM EDS SAED Mesothelioma Introduction Malignant mesothelioma occurs in both the perito- neum and in the lung pleura Mesothelioma cases have been attributed to direct occupational exposure indirect exposure and secondary exposure A higher rate of idiopathic mesothelioma has been reported in women as no link between asbestos exposure and patients has been identified Previous research suggests that ovarian cancer and peritoneal mesothelioma may be directly attributed to the use of talcum powder contaminated with asbestos or from exposure 7 to partners occupationally exposed to asbestos. Using talcum powder in closed spaces may increase the likelihood of inhaling the powder laced with asbestos Repeated applications increase the oppor- tunities for inhalation and the asbestos could become concentrated in the peripheral airways and alveoli of the lungs of the talcum powder users This has been supported by the presence of granulomas in the lungs of some talcum powder users Correspondence to R. E. Gordon Department of Pathology Icahn School of Medicine at Mount Sinai 1 Gustave L Levy Place New York 10509 USA Email Ronald mount@smiounnatstin.aot.rorgg In 1976 Rohl and Langer tested 20 consumer products labeled as tale or talcum powder including body powders baby powders facial talcums and a pharmaceutical talc.6 Of the 20 products tested 10 were found to contain tremolite and anthophyllite principally asbestiform The product with the highest asbestos content was the same product tested in this study Both asbestiform anthophyllite and asbestiform tremolite were found in the Rohl and Langer tests Given that asbestos has been determined as the primary cause of mesothelioma it is important to note that cosmetic talc contained asbestos in the past The contamination results from the mining process since ore specimens taken directly from the mines have repeatedly been tested and shown to contain asbestos most often anthophyllite and ! tremolite but also serpentine chrysotile asbestos In part from the review of corporate documents and the sworn testimony of those responsible for the sourcing of talc used in the products studied here it was determined that three mines provided the aw material for use as talcum powder The tale used by this cosmetic company that manufactured and 'W. S. Maney & Son Ltd 2014 DOI 2049396714Y 0000000081 International Journal of Occupational and Environmental Health 2014 VOL OC NO 000 Gordon et al Asbestos in commercial cosmetic talcum powder distributed the talcum powder was from three distinct regions the Willow Creek mine in Southwest Montana the Regal mine near Murphy North Carolina and imported tale from the Val Chisone region of the Italian Piedmont The specific geology of tale is an important indicator of whether a tale source may be contaminated with asbestos These three mines all contained asbestos fibers anthophyllite and tremolite The Val Chisone tale from Italy was studied by Pooley in 1972. Mine sample had intergrowths with serpentine chrysotile asbestos along with tremolite and anthophyllite asbestos The tale from Italy was named American 21 Ground Italian and designated as AGI 1615.19 This talc was diluted with a tale from another source to make it acceptable based on ray diffraction XRD protocols However it contained asbestiform tremolite and anthophyllite.22 In this study three laboratories analyzed a specific brand of tale from more than 50 containers of this cosmetic talcum powder product of different sizes and colors produced over a year time span to determine the presence of asbestos The authors conducted independent product testing in unassociated laboratories in North Carolina Georgia and New York A fourth laboratory which also tested this product will herein be referred to as Laboratory D. The lung and lymph node tissues from a woman who died from mesothelioma and testified to only using this specific brand of talcum powder were analyzed for the presence of asbestos and talc This is the first report that explores the hypothesis that a specific brand of talcum powder coming from asbestos contaminated mines can find its way into the finished product that can be inhaled during use and cause or contribute to the development of mesothelioma Materials and Methods Laboratory A product testing In Laboratory A over 50 containers of this particular brand of talcum powder were acquired from a variety of sources for bulk testing Some of the containers were purchased online while others were provided directly from the manufacturer All of the containers were verified to be the correct brand and product Laboratory A tested talcum powder from each of the 50 samples using transmission electron microscope TEM methods The procedure for testing by Lab A was as follows 0.01 g of talcum powder was removed from its vial and suspended in 1 ml of distilled water with one to two drops of ethanol by brief sonication From this suspension 10 ...laliquots were removed and placed on a series of five formvar- coated nickel grids 100 grid openings each In some cases it was necessary to prepare additional sets of five grids from the same 0.01 g sample of powder The drops were allowed to dry in a covered Petri dish The grids were then examined and analyzed with a Hitachi 7000 STEM equipped with an Evex dispersive composition and microscope was rotary specimen spectrometer EDS for elemental relative amounts of clements The equipped with a tilt stage and a holder which was employed with selected electron diffraction SAED analyses as described below Structures seen as fibers measuring at least five micrometers in length with aspect ratios of 5.1 or greater were analyzed to determine if they were regulated asbestos mineral fibers We used EDS to chemically establish the presence of asbestos fibers and the crystalline structure was assessed using SAED All 100 grid openings were observed and analyzed on each of the five grids for each product sample at least 500 grid openings per sample analyzed Analyses were performed using a modification of the techniques described by Yamate et al and similarly adopted techniques used by the Environmental Protection Agency EPA American Society for Testing and Materials ASTM and International Organization for Standardization.23 All techniques required the use of a TEM equipped with an EDS system Only in Yamate level III is the tilt and rotary stage optional to perform advanced SAED zone axis analysis Yamate et al stated that zone axis diffraction analysis is useful in differentiating between otherwise unidentifiable fibers In the Laboratory A analysis zone axis analyses were not necessary as the identified amphiboles clearly demonstrated that they were asbestiform tremolite and anthophyllite confirmed by morphology EDS chemistry and characteristic 5.3 ^ inter repeats on diffraction without tilting Both asbestiform and non- asbestiform particles and fibers were present However in most cases this manuscript will refer to asbestiform fibers and state when they are tremolite anthophylite or chrysotile type asbestos A nonasbestos tremolite anthophylite will not be referred to as asbestos To calculate the fiber concentrations per gram of talcum powder we first determined the number of asbestos fibers on average per grid opening This number was multiplied by 552. The product of that equation was multiplied by 100 and then divided by 0.01 to yield the fibers talcum powder value The constant 552 is the number of grid opening areas on the entire grid One hundred is the number of 10 ...l drops in 1 ml that the talcum powder was dispersed and the 0.01 was the weight of the talcum powder dispersed Quality control procedures which included testing of blanks from water working in a clean hood environment and working with only one International Journal of Occupational and Environmental Health 2014 VOL 000 NO 000 Gordon et al Asbestos in commercial cosmetic talcum powder Figure 1 Pouring of powder into hands in glovebox sample at a time ensured that no laboratory contamination of samples Laboratory B asbestos releasability testing To determine if the user could inhale asbestos during a talcum powder application Laboratory B assessed asbestos releasability by air sample Air samples were generated during simulation in a glove box consistent with normal product use in a controlled environment These three samples included the same samples tested by Laboratory A. Environmental and personal air samples were collected using standard airborne asbestos techniques using volume air pumps for environmental stationary samples inside and outside of the controlled area and volume air pumps for personal samples taken at a distance comparable to the breathing zone of the person simulating application Standard TEM 385 mm effective filter area 25 mm cassettes with 0.45 ...m MCE filters were used on the calibrated high 712 min and low volume 1-4 min air pumps Figs 1 and 2 The resulting air samples were analyzed for airborne asbestos following the analytical procedures described in the U.S. Environmental Protection Agency Code of Federal Regulations 40 CFR part 763 subpart E. Appendix A - AHERA for direct preparation of MCE filters.24 All final analyses by Laboratory B were conducted on a JEOL 2000FX TEM equipped with an dispersive ray analyzer detector and SAED at magnifications up to x 50 000 using the fiber counting criteria specified by Yamate et al.'s protocols Laboratory C product bulk testing and bathroom chamber releasability Bulk methods Laboratory C examined nine samples under an Olympus SZ stereomicroscope at magnifications from 7 to 40. Portions of the particulate found in the sample were mounted in Cargille refractive index liquids for analysis by polarized light microscopy PLM using an Olympus BH PLM with a magnification range from ^ 100 to ^ 1000 The PLM analysis followed the procedures for bulk analysis of building materials described by the US EPA in 1993.24 Characterization of the fibers was performed using a Philips EM420 100 kV TEM equipped with an Oxford INCA EDS ray analysis system and capable of SAED work involving tilting of amphibole fibers Zone axis determinations were also conducted We used TEM asbestos fiber counting criteria of fibers greater than 0.5 ...min length with at least a 5.1 aspect ratio as described in Asbestos Hazard Emergency Response Act AHERA and ASTM methods D6281 D5755 Figure 2 TEM cassettes in simulation area in glovebox International Journal of Occupational and Environmental Health 2014 VOL 000 NO 000 3 Gordon et al Asbestos in commercial cosmetic talcum powder D5756 and D648.24-28 Data were recorded using the ASTM D6281 format XRD analysis was performed by an outside laboratory DCM Science Laboratory Inc , Wheat Ridge CO USA scanning over a range of 3 45 20 using 40 kV 25 mA Cu K radiation Mineral phases were identified with computer programs accessing powder diffraction database the aid of a ROM Air testing Tests to determine airborne levels of asbestos fibers resulting from application of this brand of talcum powder were performed in a testing chamber The chamber was built to match the bathroom of the patient that used this brand of cosmetic talc Her bathroom was measured at 7 feet 9 inches high by 5 feet by 4 feet 1 inch All talc products used in these chamber tests had previously been tested in Laboratories A B or both Air test shaker container Using Personal Protective Equipment a volunteer applied one of the bulk tested cosmetic talcum powders to his body using a shaker container This particular talcum powder contained approximately 0.1 by weight and approximately 18 million anthophyllite asbestos fibers per gram The container was weighed before and after the testing to determine the approximate weight of material applied The talcum user wore a respirator and a bathing suit The volunteer twisted the top of the container and shook material onto his hand He applied the tale under his arm and around the shoulder and upper arm area He then shook the talcum powder onto his other hand and applied it to the other underarm shoulder and upper arm area He shook out additional material and applied it to his neck and upper torso He shook out and applied material two more times for a total of five applications The total talcum application time was approximately 1 min and amounted to 0.37 g of the talcum powder Two air samples were collected in the applier's breathing zone at 0.5 1 per minute 1pm and two additional air samples were collected in the breathing zone at 1.0 1pm with commercial open air cassettes The minute sampling time included the application time and a waiting period The bystander in the test chamber had two air cassettes in his breathing zone for the minute period including application and the additional waiting time The bystander wore a respirator and full protective clothing These air samples were collected at rates of one and 2 1pm No activities were conducted during the waiting period other than checking the pumps and cassettes The air filters and two additional blank filters were analyzed by phase contrast microscopy PCM using National Institute for Occupational Safety and Health NIOSH Method 7400. Two air samples NIOSH and two blanks were also analyzed by Method 7402 via transmission electron microscopy to determine the percentage of asbestos fibers among the fibers counted by PCM.2 An air sample collected from within the test chamber before the study was analyzed by a more sensitive TEM procedure following the EPA AHERA method Air testing puff applicator In this test a volunteer applied a different cosmetic talcum powder sample using a puff applicator This particular talcum powder contained approximately 0.05 anthophyllite asbestos approximately 70 million asbestos fibers per gram The container was weighed before and after the testing to determine the approximate weight of material applied The talcum user wore a respirator and a bathing suit The talc user opened the puff container and applied the talcum powder as described above only this time with a powder puff He then repeated the process for a total of six applications The talcum application time was approximately 1 minute Two air samples were collected in the applier's breathing zone at 0.5 1pm for a sampling period of 4 minutes One air sample was collected for a shorter period 33 33 minutes that included the application period Another air sample was to be collected after the application period but this sample was voided because the volunteer hit the air cassette and the cassette fell off the vacuum hose The bystander in this test followed the same protocol as described above Both air samples were collected at a rate of 0.5 lpm No activities were conducted during the waiting period other than checking the pumps and cassettes The air filters and two additional blank filters were analyzed by PCM using NIOSH Method 7400 as described above.29 One air sample and two blanks were also analyzed by NIOSH Method 7402 via TEM to determine the percentage of asbestos fibers among the fibers counted by PCM.30 An air sample collected from within was tested as described above by EPA AHERA method Human Tissue Analysis TEM Tissue samples from a woman with no other known exposure to asbestos other than her use of the product tested was supplied to Laboratory A. Human tissue analysis was performed according to 29 the techniques described in Wu et al Lung and lymph node tissue was received fixed in formalin Half of the tissue was removed from the lung and the lymph node tissue Two grams of lung tissue were divided twice The two halves of the lymph node weighed 0.16 g together The two specimen types were separated throughout the study The tissue from each was first digested in a % solution of potassium International Journal of Occupational and Environmental Health 2014 300 NO 000 Gordon et Asbestos in commercial cosmetic talcum powder hydroxide KOH for approximately hour at 60 C. The dissolved lung and lymph node material was then centrifuged in a speed centrifuge to separate the inorganic material from the dissolved organic tissue The solute material containing the dissolved organic material and KOH was removed and distilled water was allowed to dry in a covered Petri dish The stub was then coated with vaporized carbon and observed with a Hitachi 4300 field emission scanning electron microscope equipped with an Evex EDS system The entire filter sample surface was scanned for fibers and asbestos bodies was added The inorganic material was suspended in the water by brief sonication The material was recentrifuged and the process of washing the inorganic material was performed five times After the fifth wash the distilled water was removed and replaced with 10 ml of fresh distilled water and the inorganic material was suspended by brief sonication Ten microliter samples were removed from the suspension and placed on formvar nickel grids on a metal mesh in a covered glass Petri dish to dry Five grids were initially prepared and an additional set of five grids was prepared for each tissue type for a second analysis The dried grids were observed with a transmission electron microscope Four hundred grid openings on at least four grids were analyzed and a fifth grid was used if grid openings were broken in the initial four examined grids The fiber concentrations per gram wet weight lung or lymph node tissues were calculated from the number of fibers observed the area analyzed the aliquot ratio and the total weight of the tissue sample digested Light microscopy Tissue sections Small lung tissue samples were put into % phosphate formalin and processed for embedding in paraffin Five micrometer paraffin sections were cut mounted on glass slides and stained with hemotoxylin eosin and an iron stain The tissue was evaluated for the presence of altered morphology and ferruginous bodies two characteristics often seen in lung tissues that are a byproduct of iron protein deposits on asbestos fibers resulting from macrophage frustrated phagocytosis Digested lung and lymph node tissue Two hundred and fifty microliters of digested lung and lymph node material suspension used for TEM analyses was placed in a cytocentrifuge and the slides were cover slipped and observed by phase contrast light microscopy The entire area was counted for ferruginous bodies and calculated back to the weight of the tissue to determine the concentration of bodies per gram of wet weight tissue Scanning electron microscopy SEM SEM samples were prepared by taking 250 lof the suspended inorganic material used for the TEM and light microscopy analyses and placed on a 01 ...m pore size Nucleopore filter mounted on a carbon planchette on an aluminum SEM stub The material Results . All three laboratories confirmed in multiple tests the presence of asbestiform anthophyllite and asbestiform tremolite in the talcum powder products just as had been found and described by Rohl and Langer over three decades ago Initial bulk analyses of 50 samples of this product in Laboratory A showed that all of the samples contained asbestos fibers Eighty percent contained only anthophyllite asbestos % only tremolite asbestos % anthophyllite and tremolite asbestos and % anthophyllite tremolite and chrysotile asbestos The range in asbestos concentrations of fibers > ...min length were calculated to be at a minimum between 1840 and 1 104 000 fibers per gram of talcum powder More than % of the tested cans and plastic containers contained over 10 000 asbestos gram of talcum powder Four of the containers had less than 5000 fibers per gram and six containers had more than 250 000 fibers per gram However it should be noted that there were many asbestos fibers that also had aspect ratios less than 1 These fibers were generally found to be shorter than 5 ...mand were noted but not counted in the original product testing or in the lung and lymph node tissue testing by Laboratory A. There were also a number of fibrous tale particles that were easily distinguishable from asbestos by morphology If there was a question regarding their identity both EDS and SAED were employed to recognize such fibers as talc All the fibers that were actually counted in bulk and tissue preparations were 5 ...mor greater in length with aspect ratios for the most part greater than 10 The majority of asbestos structures counted demonstrated aspects ratios 15 with many 20 A minimum of four fibers was identified in each sample making the concentration determinations of asbestos statistically significant and reproducible Laboratory C. using PLM TEM and XRD tested nine samples of the specific brand of talcum powder described above Generally the PLM analysis showed that the samples contained both platy and fibrous talc less than % by volume of the PLM visible amphibole fibers and some quartz The majority of the PLM amphibole particles had low aspect ratios length to width but some were 10 By XRD one of the talcum powder samples was found to contain % anthophyllite No amphibole International Journal of Occupational and Environmental Health 2014 VOL 000 NO 000 Gordon et al Asbestos in commercial cosmetic talcum powder Figure 3 Application of powder from shaker in bathroom- sized chamber Figure 4 Application with powder puff in bathroom chamber minerals were detected in the other eight samples by XRD The XRD detection limit was approximately 2 by weight In TEM analysis all nine samples were positive for amphibole asbestos primarily anthophyllite and were confirmed with zone electron diffraction measurements At least five asbestos fibers per sample were recorded in each sample with concentrations ranging from 0.004 to 0.9 by weight and from 3 to 200 million asbestos fibers per gram of fibers greater than 0.5 ...min length with at least a 5 aspect ratio Air monitoring Releasability of asbestos into the air from the products was assessed by glove box simulation testing by Laboratory B and by full chamber testing by Laboratory C. In a manner consistent with methods used by the EPA NIOSH or ASTM study product body powders and dusting powders were applied hand to hand and hand to arm Consistent with bulk testing results anthophyllite and tremolite asbestos was repeatedly found in the air tests resulting from these simulations Figs 6-8 Shaker container test The shaker application test used 0.37 g of talcum powder Fig 3 For the talc user the average PCM fiber concentration in his breathing zone during application was 4.8 cc 3.1 7.3 3.9 and 4.9 cc The asbestos to total fiber percentage as determined by TEM was 40 Therefore the asbestos concentration in the breathing zone of the talc user during application was 1.9 cc For the bystander the PCM fiber concentration was 1.35 cc 0.9 and 1.8 cc and the TEM derived percentage of asbestos was 35 which results in a bystander asbestos concen- tration of 0.5F No asbestos fibers were found in the sample collected in the chamber before the testing or in the blank filters PCM fiber concentration in his breathing zone during the minute sampling period was 20 cc 23.6 and 16.5 cc The asbestos to total fiber percentage as determined by TEM was 21 Therefore the asbestos concentrations in the breathing zone of the talcum powder user were 5 and 3.5 cc The short term sample in the breathing zone of the applier had a PCM value of 60 cc Using the derived percentage of asbestos of % result for the shortterm sample was an asbestos concentration of 13 F cc For the bystander the PCM fiber concentration was 11.7 cc 13.7 and 9.7 cc Using the mini- mum derived percentage of asbestos of 36 results in a bystander asbestos concentration of 4.9 and 3.5 cc No asbestos fibers were found in the sample collected in the chamber before the testing or in the blank filters The tests performed independently by Laboratory C using a bathroom room confirmed the findings for asbestos fiber release found by Laboratory B's glovebox testing Samples showed that significant concentrations of anthophyllite tremolite and occasionally chrysotile asbestos were released in the simulated application of several iterations of the products This confirmed not only Puff application The puff application test used 6.25 g of talcum powder Figs 4 and 5 For the talc user the average Figure 5 Application with a powder puff in bathroom chamber International Journal of Occupational and Environmental Health 2014 VOI 000 NO 000 Gordon et al Asbestos in commercial cosmetic talcum powder 11293012 11293012 HT 100KV TEM Magrificaban 1500 1300866 Tremolite ** 100KV TEM Macbon 13000x CB_Air CB_Air 4b Tremolite 3 Figure 6 Tremolite asbestos from TEM analysis of releasability air testing of product images EDS and SAED the presence of asbestos in the talcum powders but also that the asbestos contained in the friable powders was easily aerosolized in a manner consistent with the products intended use confirming the hypothesis that the cosmetic powders are capable agents of exposure to asbestos Human tissue analysis Electron microscopic analysis of the lung tissue revealed amphibole type asbestos fibers in a calcu- lated concentration of 1380 and 4150 fibers per gram wet weight respectively with a limit of detection of 690 fibers per gram wet weight All fibers counted International Journal of Occupational and Environmental Health 2014 VOL 000 NO 000 Gordon et al Asbestos in commercial cosmetic talcum powder Mime Be eae fate Sa Fade, F 1300061-1 Antsophylle SAED 9/24/2013 1300881-1 Anthophyllite near ZA 6 degrees cow Figure 7 Anthophyllite asbestos from TEM analysis of releasability air testing of product images EDS and SAED were 5 mor greater in length and had aspect ratios of 20 or greater The amphiboles were identified by EDS and SAED analysis as anthophyllite Fig 9 and tremolite Fig 10 asbestos The asbestos fibers were seen in a ratio of 1 and 2 respectively anthophyllite There were many anthophyllite and tremolite asbestos fibers less than 5 m in length that were not counted The majority of these smaller asbestos fibers were of the anthophyllite type Light microscopic analysis of the cytocentrifuge preparation revealed a calculated concentration of 140 asbestos bodies per gram wet weight of lung tissue by phase contrast light microscopy in both samples .. Electron microscopic analysis of the lymph node tissue revealed amphibole asbestos fibers in a calculated concentration of 12 738 fibers per gram wet weight with a limit of detection of 2123 fibers per gram wet weight All counted fibers were at least 5 ...min length with aspect ratios of 10 or greater The amphiboles were identified by EDS and SAED analysis as anthophyllite and tremolite and they were seen in a ratio of 5 anthophyllite There were many anthophyllite and tremolite fibers less International Journal of Occupational and Environmental Health 2014 VOL 000 NO 000 Gordon et al Asbestos in commercial cosmetic talcum powder oF Ile ***** ***** ***** 1300886 Chrysobile Figure 8 Chrysotile asbestos from TEM analysis of releasability air testing of product image and SAED than 5 ...min length that were not counted We also observed but did not count tremolite cleavage fragments Light microscopic analysis of the cytocentrifuge preparation revealed a calculated concentration of 92 asbestos bodies per gram wet weight of lymph node tissue by phase contrast light microscopy Fig 11 Histological sections of the tissue showed focal areas of mild parenchymal fibrosis and a more generalized pleural fibrosis Although many ferruginous bodies were identified in the cytocentrifuge preparation most were relatively small and not seen in the stained paraffin sections These macrophages were clustered and contained a combination of fibrous and platy tale and small asbestos bodies In addition to the fibrous and platy tale described above other inorganic materials were seen Aluminum silicates and magnesium aluminum silicates in both fibrous and platy form were identified We elected not to count these fragments Their presence supports the hypothesis that the lung and lymph node samples match findings from the tested talcum powder The two analyses performed on the lung tissue were from two separate tissue digestions The second was prepared with tissue not previously analyzed but saved from the original half of the tissue retained by Laboratory A. The results proved to be completely reproducible with no finding of any additional fiber types other than those reported above Confirmation of interlaboratory analyses After several years of independent testing in separate laboratories the authors became aware of one another's work through litigation The finding that this historic brand of cosmetic talcum powder contained asbestos fibers with generally the same morphological and chemical assemblage was con- firmed A fourth laboratory Laboratory D tested many of the same samples but did not report asbestos findings Owing to the inconsistency with the other laboratories examination of results from Laboratory D was warranted Two of the three authors of this study went to the Laboratory D and were supplied with the prepared filters on TEM grids or SEM stubs previously analyzed by Laboratory D. They were also supplied with both TEM and SEM microscopes to analyze the specimens along with data and locator sheets allowing for the same grid openings and areas to be observed as in the initial analyses Reanalysis of subject product samples One author analyzed the TEM preparations of 20 study products of talcum powder prepared by Laboratory D. Asbestos structures were found in the analysis some of which were named in the original analysis as cleavage fragments intergrowths or fibrous tale rather than as asbestos Although the reviewer agreed with many of the nonasbestos fibers identified he concluded the original analyses were incomplete Additional analyses by the reviewers showed some of the incompletely analyzed fibers to be asbestos In other cases asbestos found on analysis was located on areas of the filter where no fibers were recorded in the original bench sheets or reports In some instances the overall distribution of particulates on the preparations was inhomogeneous in contrast with the method of choosing grid openings for the original analysis by skipping every other opening in a checkerboard fashion Furthermore the methods named on the analytical count sheets were not the same as the methods cited in the reports from Laboratory D Laboratory D reported no asbestos fibers in the 20 samples analyzed In contrast asbestos fibers were identified in all 20 of the same products in Laboratory A and in 16 of 20 products tested by Laboratory B. In the analysis of those same 20 samples originally analyzed by Laboratory D via TEM eight were found to contain asbestiform anthophyllite six asbestiform tremolite and two were found to contain chrysotile fibers These findings were significant because analysis was not a International Journal of Occupational and Environmental Health 2014 VOL OJC NO 000 Gordon et al Asbestos in commercial cosmetic talcum powder FA13-27LA2 117 Count kev 10.230 3:39:12 PM 2014 75KV 40 Degree Figure 9 This asbestos fiber is a representative sample removed from the lung tissue of the patient exposed to cosmetic talcum powder Anthophyllite asbestos fiber is observed and its SAED pattern is demonstrated beside it with the EDS spectra complete replication of the original analysis due to time constraints damage or unsuitable preparations It was apparent that the technicians in Laboratory D missed fibers and misidentified asbestos fibers as asbestos analysis of human tissue Laboratory D also performed fiber burden analysis on human tissue with differing results than the study of the authors Similar to the evaluation of bulk analyses two reviewers analyzed the human tissue sample preparations of Laboratory D together and found significant differences in their analyses compared to the technicians who originally analyzed the grids and stubs We determined that the technicians misidentified anthophyllite asbestos fibers that had been coated with iron and protein antho- phyllite asbestos bodies as either cleavage fragments or as amosite fibers Fig 12 Furthermore it is the authors consensus that there are no generally accepted cleavage contains criteria to classify individual fibers as fragments by TEM when the sample attributes of an asbestos fiber or countable structure When Laboratory D technicians initially looked for asbestos bodies to determine the fiber core they concluded that most were amosite However when the two reviewers examined International journal of Occupational and Environmental Health 2014 VCL 000 NO 000 FA13-27LA2 120 18 Gordon et al Asbestos in commercial cosmetic talcum powder Count 328 01 PM Jan 2014 key 75WV 40 Degree 230 Figure 10 This asbestos fiber is a representative sample removed from the lung tissue of the patient exposed to cosmetic talcum powder Tremolite asbestos fiber with its corresponding EDS spectra the same structures it was clear that the cores were either anthophyllite or could not be determined because there was exposed fiber core In previous studies of human tissue having anthophyllite and anthophyllite bodies Fig 11 it was common to find that the entire anthophyllite core even if quite long was completely coated Zone axis confirmation in bulk tissue and air Laboratories A. B and C confirmed original amphibole asbestos structures by zone axis diffraction Laboratories A B. C and D analyzed archived preparations with the intent of confirming amphiboles by zone axis diffraction In all four sets of analyzed preparations anthophyllite and tremolite asbestos were consistently SEM MAO 198 k 198 BEM HV 00 WY WD 144 144MB Dar Be View ...m...m Date 1894813 TESCSAEM N MAO 132 132 k SEM HV 00 W WD 87 mm Det SE View feld 1142um 1142um Dateonidro 120013 20 um Figure 11 These are asbestos bodies from the patients lung tissue taken by SEM It is possible to see in the one to the left that the fiber is almost completely covered by the iron protein coating This is compared to the one at the right which appears to have much more fiber exposed However upon EDS testing it was determined that in both cases these were anthophyllite fibers and they were both entirely coated although much thicker is some areas as opposed to others International Journal of Occupational and Environmental Health 2014 VOL 000 NO 000 Gordon et al Asbestos in commercial cosmetic talcum powder Figure 12 Tremolite and anthophyllite asbestos from analyses of Lab D preparations images EDS and SAED confirmed by zone axis diffraction pattern measure- ments This included confirmation of asbestiform am- phiboles including anthophyllite and tremolite asbestos from the original product testing from the releasability air tests and from TEM preparations oflung and lymph _node tissues International Journal of Occupational and Environmental Health 2014 VOL 000 NO 000 Gordon et al Asbestos in commercial cosmetic talcum powder Discussion Historically many mesotheliomas abdominal mesotheliomas in women particularly have been labeled idiopathic due to a lack of an identifiable source for asbestos exposure Further there has been an increase in the number of idiopathic pleural and abdominal mesotheliomas in women using this specific brand of talcum powder There have been a few studies that have examined talcum powder and its potential to cause ovarian tumors The studies were inconclusive but suggested that talc asbestos or both may cause these cancers through vaginal exposure These studies attributed asbestos found within the women's lesions to result from contact with their partners There was no consideration for the potential of the asbestos being a contaminant in powder the women's talcum 3,4 However it has been reported that cosmetic talcum was contaminated with asbestos and that asbestos was found in the mines from which the talc originated Our findings indicate that historic talcum powder exposure is a causative factor in the development of mesotheliomas and possibly lung cancers in women Talc has been identified as a causative for mesotheliomas in New York talc miners In recent years more than 10 women developed mesothelioma and their only source of asbestos exposure was the use of one brand of talcum powder This study demonstrates that the brand of talcum powder tested contained asbestos Furthermore we have traced the asbestos in the tale to the mines from which it originated into the milled grades into the product and finally into the lung and lymph nodes of the users of those products including one woman who developed mesothelioma Based on the testing and testing conducted by the authors it is evident that this product line has been consistently contaminated with asbestos tainted talc derivatives The amount of asbestos was variable based on the time of manufacture and the tale source There have been numerous publications that have indicated that the talc in many tale deposits had asbestos contamination The most common types of asbestos were tremolite and anthophyllite These are the same asbestos fiber types found in the autopsied lungs and lymph nodes tested here for asbestos presence In a few containers tested in this study chrysotile was also found consistent with the source ore geology Most if not all testing of cosmetic talc was performed using techniques designed for light microscopy PLM or by TEM criteria designed to test air and water samples Testing determined if asbestos levels were above the EPA standards under AHERA or the Occupational Safety and Health Agency standards These protocols are based on the parameters described in the Yamate method There are significant limita- tions to these methods PLM analysis misses small fine asbestos fibers or fibrils because the limits of the resolution are approximately 0.2-0.5 ...mfor different forms of light microscopy Based on our findings approximately 90 of the fibers identified fall into this category Determining the number of TEM grid openings to be counted during the analysis requires stopping factors or limits on the quantity of analysis to be performed The Draft Yamate method 1984 gives the guidelines of 100 fibers or 10 grid openings whichever is first This counting rule was instituted for cost limitation purposes The Draft Yamate method describes that while this guideline of using 10 grid openings represents a judicious compromise between a reasonable experimental effort and a fairly low value of the detection limit the analysis of additional TEM grid openings reduces the detection limit and improves the precision of the estimates In the tale study described here a very low level of detection was desired and therefore in some cases as many as 500 plus grid openings were analyzed to reduce the detection limit and improve sensitivity of the test TEM testing has been adequate for evaluating building material asbestos abatement projects local air sampling and potential water contamination with asbestos However these criteria are not acceptable for assessing asbestos fiber burden analyses in human tissues and for low asbestos content products that are used intermittently in small quantities over long periods of time such as cosmetic talcum powder Talc related asbestos exposures can be heavy at times above 4000 cc The inhaled asbestos fibers are extremely variable in the causation of asbestos related tumors and fiber burdens found in the deceased woman were within the reported ranges for amphiboles to be causative factors in the development of such a tumor Therefore it is imperative to analyze products such as talcum powder for small amounts of asbestos fibers This requires that the limits of detection be lower than levels required in a typical Yamate analysis The reviewers observed that the Laboratory D analyses were done using Yamate methodology and no more than 10--25 grid openings on bulk TEM grid preparations were observed Based on Laboratory D's protocols for testing millions of fibers of talc would have to present in order to find fibers Lower concentrations in the ranges found by Laboratories A B and C demon- strated that fibers were detectable and present at levels sufficient to cause mesotheliomas Although long narrow asbestos fibers are highly carcinogenic shorter narrow fibers are also 36 38 dangerous It is now more common to find shorter narrow fibers in human tissue digestions than long narrow fibers especially for chrysotile This International Journal of Occupational and Environmental Health 2014 VOL 000 NC OCO Gordon et al Asbestos in commercial cosmetic talcum powder study provides evidence that low concentrations of asbestos in raw materials do not necessarily correlate 38,39 to low health risk Examples of recent studies of low asbestos content producing significant airborne concentrations in simulated activity include activity- based monitoring of asbestos as it naturally occurs in several sites as conducted by the EPA and Agency for Toxic Substances vermiculite and Disease Registry and 40 attic insulation studies These studies have repeatedly shown that substantial airborne concentrations could be derived from materials with only a fraction of a percent asbestos content This has been especially true when a product was in a friable state or where the obvious use of material intimates aerosolization of fibers Significant airborne concentration can be easily generated from such conditions when asbestos is a constituent The talc application studies were simulations of exposures to talc used by a deceased woman who had mesothelioma The air volume in the testing space was 158 cubic feet This is in the range of the chamber sizes used by talcum powder manufacturers in the 1970s in their studies of the quantity of talcum powder used in normal application The space used by Russell was 171 cubic feet and the space used by Aylott was between 152 and 163 cubic feet The amount of material used in the shaker test was 0.37 g The amount used for the puff applicator test was 6.25 44,45 The shaker test was a light application and the puff a heavy application However the heavy application was within the ranges published by Russell of 8.32 g and Aylott of 12.5 g The talcing times or the duration of talcum powder application were approximately 55 seconds for the shaker test and approximately 57 seconds for the puff applicator 44.45 These were within the ranges published by Russell of 83 33 seconds and Aylott of 28-78 seconds for adult dusting Laboratories A and B determined that the contami- nated talcum powder released inhalable asbestos into the air Another issue in this study was the documentation and identification of cleavage fragments The scientific community has not generally adopted cleavage fragment differentiation criteria It is unclear how to identify a cleavage fragment once the stone or material has been finely ground Two criteria for distinguishing cleavage fragments from asbestos fibers have been proposed The first is that the ends of cleavage fragments have oblique angles and second is that the aspect ratios are all less than 20 The ends criterion has not been validated with known cleavage fragment standards and while an aspect ratio of 20 1 suggests that a fiber is likely to be an asbestos fiber some fibers with aspect ratios below 20 are also asbestos As the fiber aspect ratio increases the percentage of asbestos fibers versus 47 cleavage fragments also increases However this criteria falls short when the fiber is extremely thin and is the smallest unit of diameter ofa fiber When these small fibers are removed and analyzed from human tissue these criteria have to be discarded because enzymes with basic and acidic molecules within cells can leach elements from the surface causing a breakdown of the fibers especially when thin in diameter van Orden et al propose criteria to identify cleavage fragments by SEM The criteria are based on surface contours which identify a cleavage fragment However this method has not been verified and is not generally accepted There were no photographs of TEM or resolution highmagnification SEM provided by Laboratory D which classified potential asbestos fibers as cleavage fragments In conclusion we found that a specific brand of talcum powder contained identifiable asbestos fibers with the potential to be released into the air and inhaled during normal personal talcum powder application We also found that asbestos fibers consistent with those found in the same cosmetic talc product were present in the lungs and lymph node tissues of a woman who used this brand of talc powder and developed and died from mesothelioma Disclaimer Statements Contributors All authors did studies relevant to the manuscript and all contributed and accepted all the writing Funding The work done was paid for by attorneys for litigation purposes No funds were for writing of this manuscript Conflicts of interest Funding for all Labs was provided as part of litigation No funds were for writing this article Laboratories are available for defense or plaintiff litigation Ethics approval Ethical consent was not needed References 1 Robinson BM Malignant pleural mesothelioma an epidemiological perspective Ann Cardiothorac Surg 2012,1 491 6 2 Ilgren EB Wagner JC Background incidence of mesothelioma animal and human evidence Regul Toxicol Pharmacol 1991,13 133 49 3 Heller DS Gordon RE Katz N Correlation of asbestos 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