Document a1nqVb8oDYXKwz2rbRZYd6zyb

waiter c. me crone associates, Inc, =- CONSULTING : U LTRAM ICRO AN ALYSIS M IC R O SC O PY 3 MALL PA.TUCI.E P C O S '-E V S fOUO-.-iA-fc u 12 March 1976 Up , Norman Estriii _ Cosmetics Toiletries and Fragrances Association 1133 15th Street, N.VV. Washington, D.C. 20005 Dear T>r. Estrtn: This letter will amplify our recent conversation on-talc analyses tor asbestos. Since'1971, W alter C. McCrone Associates, The., has worked with several producers and users of talc, the majority of them involved with cosmetic grades of talc. During this period wo have analyzed several mndmt talc _ samples for the presence of asbes.tiform minerals. 1 ho mctnodologies Uscu have been principally X-ray diffraction and light microscopy using dispersion staining, although extensive transmission electron .microscopy examinations have been carried out for some companies. Subject to the approval ox our clients, wo ate prepared to make available to the FDA .through CFFAfyn. results of these analyses. We also have available retained samples lor mom of the analyses. Verbal agreement to release this data has been already given by clients accounting for probably 80-90fyof the samples; the others have not yet been approached. It would,, however, be improper for us to comment on specific samples until such time as written approval is received from our clmn-s, together with identification of those materials used in cosmetic production. The latter point is stressed because several of our ana lyses represent the resu lts of raw material assessm ents which some companies initiated am might include talc ore bodies which are unacceptable.for cosmetic applica tions. ; I do not think, however, that I would be violating any company confidences if I were to comment on the asbestos in talc situation as wo saw it over the last 5 years. 1 think our view can be summarized quite briefly as follows. 2320 S O U T H h V C t l'd A N AVEN U E < C U IC A U O , IL U N G I; EOT,16 - S i T / b V ' m c . C.V3LL C H :V iC riO N E PLAINTIFF'S EXHIBIT WCD-44 12 March 1976 Bh * Norman Estrin C osm etics T oiletries and Fragrances A ssociation Page Two Some cosm etic talcs prior to about mid-1972 to early 1973 were found to contain amphiboles -- principally-of th Tromolite-Anthcphyllite type at le v els, determined by X -ray diffraction, of the order of 5-15% by"w eight. M icroscopical examination of these ta lcs, however, indicated that the bulle of this amphibole content (>99%) was non-fibrous, even applying the 3:1 aspect ratio criterion for a fiber, and hence not asbestos. No ehrysotile asbestos was found in thse talcs. Since 1973 none of the talcs which we have examined and winch have been identified to us as production m aterials have shown any detectable level:; of either ehrysotile or asbestjform amphibole. " Yours sincerely, P- In M. Stewart Manager, Electron Optics Group Companies contacted and granting verbal approval to release, inrbrmctiar include : ~ Avon Products, Inc. Bristol-Myers .Products Chesebrough-Ponds, IncColgate-Palmolive, Inc. Fabrge, Inc. Johnson & Johnson Windsor Mrnerals, Inc. Whittaker, Clark' & Daniels, Inc. . lmh