Document aJ77k8LgVD6yDa8dL5xdLaBky

FILE NAME: RT Vanderbilt (RTV) DATE: 1974 Dec 5 DOC#: RTV203 DOCUMENT DESCRIPTION: Safety & Health Bulletin - Talc and the OSHA Asbestos Standard 1910.93a - National Paint & Coatings Assoc. I\CO N o . 20 December 5, 1974 TALC AND THE OSHA ASBESTOS STANDARD 1910.93a NATIONAL PAINT & COATINGS ASSOCIATION 1AR1ht0to0ndvtt,ItHlt.nWd. WIOOliOhSlngton, O.C. Ttltphont 202 42-272 ROUTE TO: D tp in m tn l F lninc * A dm inittrtuer $103 T o e h m c / P roduction 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 O SH A . 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 fer 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 YO U R CO M PA N Y - Manufacturing, safety and health. STAFF CO N TA CT 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 OSHA officials to obtain a clarification on the regulation of the talcs under 1910.93a. RECENT DEVELOPMENTS O n October 9 , 1974 in a letter toM 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 occurina talcs, prior to processing by milling or crushing, do r.ct contain fibrous of asbestiform tremolite, anthophyllite, actinolite or other asbestiform minerals, you may certify to your customers that the talc does not contain asbestos." (A 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 taie u ser,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. CRMC-MAD-000473 D . The length to width ratio must be 5 or mor* 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 nd 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 air (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. R ECO M M EN D A TIO N If you have been using talc products that have been questionable regarding asbestos !fj 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.' ' V. 0 l CRMC-MAD-000474