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FILE NAME Talc TALC DATE 2010 May 19 DOC TALC095 DOCUMENT DESCRIPTION Dr. Elaine Panitz to NIOSH RE Comments on NIOSH Draft on Asbestos Fibers Elaine B. Panitz MD MPH May 19 2010 . Re Docket Number 099 Elaine B. Panitz MD MPH Occupational and Environmental Medicine P. O. Box 936 Sheffield MA 01257 Email epanmd@yahoo.com Tel 413 229 3390 Fax 413 229 3391 ; May 19 2010 Diane Miller . NIOSH Docket Officer niocindocket@cdc.gov Robert A. Taft Laboratories 4676 Columbia Parkway M C34 Cincinnati Ohio 45226 Telephone 513 533 8611 Re Docket number 099 Comments on the Draft NIOSH Current Intelligence Bulletin on Asbestos Fibers and Other Elongate Mineral Particles State of the Science and Roadmap for Research Version January 2010 Background . medicine in the state of New Jersey and I am a physician and internist licensed to practice specializing in occupational and environmental medicine for the past 35 years I received a BA degree with a major in biology and a minor in chemistry from Vassar College in 1968 an MD degree from Harvard Medical School in 1972 and an MPH degree from the Medical College of Wisconsin in 1998. am certified by both the American Board of Internal Medicine and the American Board of Preventive Medicine as an occupational and environmental disease specialist I am currently living in Massachusetts and from time to time serve as a consultant in and environmental medicine I have over thirty years of experience as an occupational hundreds of individuals with occupational disease specialist and have personally evaluated asbestos diseases I am intimately familiar with the reviewed scientific literature relating to asbestos exposures and the risks of asbestos diseases I have recently been asked by plaintiff attorneys to evaluate the illness and death of a ceramics teacher from mesothelioma Her major exposure was to ceramic dust containing fibrous talc from upstate New York In evaluating this matter I have reviewed most of the * extensive literature surrounding asbestos diseases from elongate mineral particles , EMPs Reason for Critique am writing to express concern over inconsistent and inaccurate statements in the Roadmap statements that add additional confusion to an already confused arena The Roadmap to create broader and clearer understanding of the important determinants of toxicity proposes for asbestos and other EMPs Yet in many sections of the Roadmap NIOSH appears to restrict the discussion to asbestos and its asbestiform analogs only and not to other EMPs In other sections NIOSH often seems to exclude some or all of the other EMPs even though they habve been heavily associated with known asbestos health effects e.g. fibrous talc winchite richterite erionite edenite Below please find a detailed discussion of what in my view are inconsistent inaccurate or confusing comments that hinder the Roadmap's stated goal of broader and clearer ' understanding of an admittedly very difficult problem Suggestions are made in the spirit of lending greater clarity and understanding to the Roadmap effort Forward ; The Foreword by John Howard MD Page ) clearly states the mission for the Roadmap The Work Group is trying to summarize NIOSH's understanding of occupational exposure and toxicity issues concerning asbestos fibers and other EMPs that will provide a broader and clearer understanding of the important determinants of toxicity for asbestos and other EMPS Dr. Howard in my view has properly framed the issue with this terminology a Executive Summary The Executive Summary however introduces major confusion to Dr. Howard's clear terminology of the Foreward Paragraph 2 of Page vii correctly points out that the term mineral fiber has been used by mineralogists to encompass thoracic EMPs that include a asbestiforms b nonasbestiforms and c cleavage fragments It correctly states that asbestiform EMPs are clearly of substantial concern and that the asbestiform and cleavage fragment EMPs are less clearly of concern Having broached the topic of EMP habit however the paragraph should . then mention the substantial and fractious debate concerning the determination of EMP fiber habit i.e. asbestiform v nonasbestiform The paragraph should point out that regardless of EMP habit determination other EMPs should be studied further if they have already been associated with asbestos disease Paragraph 3 of Page vii discusses NIOSH's 1990 recommendation to include only asbestos and its asbestiform analogs in regulatory efforts Paragraph 1 of Page viii properly notes that this NIOSH 1990 recommendation inappropriately excluded other EMPs and cites as examples winchite richterite and erionite All three are EMPs that have been associated with substantial asbestos disease in humans For the same reason NIOSH should include upstate New York and Vermont talc and edenite in its examples of other EMPs associated with substantial asbestos disease in humans It is recognized that edenite was not yet known as a health threat when NIOSH made its recommendations in 1990 but it should now be grouped with winchite richterite erionite and fibrous talc as other EMPs of substantial concern Paragraph 2 of Page viii correctly notes that its 1990 recommendations created confusion causing many to infer that the nonasbestiform minerals included in the NIOSH definition are . asbestos However Paragraph 2 should also mention that NIOSH's 1990 recommendations caused many to infer that asbestos other EMPs do not need to be regulated Epidemiologic studies have made it abundantly clear that richterite winchite erionite fluoro- edenite and fibrous talc cause asbestos disease and should be under active consideration for regulation . Similarly Paragraph 2 of Page ix discusses the epidemiology relating only to asbestos and its asbestiform analogs and not to other EMPs Although the paragraph suggests interest in epidemiologic studies of workers in upstate New York talc mines it then states that talc exposures involve predominantly nonasbestiform EMPs This comment fails to reflect the fact that determination of EMP habit especially in relation to upstate New York talc is a debated and unsettled issue In this Executive Summary NIOSH should avoid making judgments in the contentious issue of whether other EMPs are asbestiform or asbestiform NIOSH should focus on which of the other EMPs have shown epidemiologic evidence of disease potential and therefore deserve further epidemiologic study regardless of EMP habit NIOSH should completely remove the sentence beginning Populations of interest ~ NIOSH should simply amend the next sentence to read Populations of interest for possible epidemiologic studies include workers and others exposed to EMPs in relation to a talc mining in upstate New York and Vermont b vermiculite mining in Libby MT c taconite mining in northeastern Minnesota d gold mining in South Dakota e erionite contamination in Turkey f edenite contamination in Sicily and ) any other EMPs exposure that may show epidemiologic evidence of asbestos disease in the future Note that the term others should be included to reflect the growing evidence for asbestos disease in the general populations around workplaces exposed to other EMPs e.g. Libby MT northeastern MN and upstate New York The remaining paragraphs of the Executive Summary correctly return to the scientific evaluation of asbestos and other EMPs Introduction Introduction Page , Paragraphs 1-2 of the Introduction correctly reiterates NIOSH's interest in the study of asbestos and other EMPs Paragraph 3 correctly notes that health effects of other nonasbestos EMPs have not been studied as much as asbestos However Paragraph 3 then cites as examples of other EMPs a the amphiboles in Libby MT b those encountered in hardrock mining and c erionite in Turkey For clarity and consistency NIOSH should also _ list the health effects of the EMPs in upstate New York and Vermont talc mining and e the EMPs in the quarry near Biancavilla Sicily The remainder of the Introduction correctly refers to both asbestos and other EMPs Overview of Current Issues 2.1 Background * Paragraph 2 of Page 4 states that interest in EMPs other than asbestos fibers has been focused primarily on fibrous minerals exploited commercially e.g. wollastonite sepiolite and attapulgite This comment omits mentioning the other commercially exploited substances that contain fibrous minerals e.g. fibrous talc and vermiculite containing winchite and richterite and omits the major interest in EMPS occurring as contaminants in central Turkish erionite and Sicilian edenite rocks and soils Paragraph 2 of page 4 goes on to note that the asbestos minerals as well as other types of fibrous minerals are typically associated with other minerals in geologic formations at various locations in the United States citing Van Gosen 2007. NIOSH should name the other types of fibrous minerals especially since the main types of other fibrous minerals discussed by the cited Van Gosen 2007 article are fibrous talc and vermiculite containing winchite and richterite Paragraph 2 continues on to state that the biological significance of occupational exposure to airborne particles remains unknown for many of these minerals This is simply untrue for the two major other types of fibrous minerals mentioned by Van Gosen 2007 fibrous talc and vermiculite containing winchite and richterite This sentence should be removed or clarified 4 Paragraph 3 of Page states the lack of uniformity in the use of terms and the lack of precision in the definitions of many of the scientific terms remain issues which cannot be resolved in this Roadmap This unfortunate comment suggests that NIOSH is not striving for precision in its use of certain key terms such as other EMPs I would argue that until NIOSH resolves its lack of consistency and clarity in the definition and use of the term asbestos and other EMPs it will not succeed in creating a broader and clearer understanding of the Roadmap issues Minerals and mineral terminology Section 2.2 Paragraph 4 of Page 5 states that both asbestiform fibrous and nonasbestiform massive versions i.e. analogs of the same mineral can occur in juxtaposition or matrixed together This sentence implies that the term fibrous can substitute for the term asbestiform While all asbestiform particles are certainly fibrous particles not all fibrous particles are asbestiform particles It also implies that all nonasbestiform fibers are massive - Nonasbestiform fibers can occur in a range of habits from massive to prismatic to acicular to very fibrous up to but not including asbestiform fibers This unfortunate sentence therefore implies that all nonasbestiform EMPs are massive and do not occur in fibrous forms The sentence should be removed and replaced with the following Nonasbestiform fibers can occur in a range of habits from massive or platy or tabular to prismatic to acicular to very fibrous up to but not including asbestiform Both asbestiform and nonasbestiform habits of the same mineral can occur in juxtaposition or matrixed together often within a narrow geological formation Paragraph 1 of Page 6 addresses itself to the habits of amphibole EMP minerals only For greater clarity NIOSH should address itself to a more inclusive term such as hydrous magnesium silicates in order to address the habits of other important but amphibole EMPs such as fibrous talc and erionite Although not amphiboles fibrous talc see reference ) and erionite see Roadmap 2.6.2 p 35 have been associated with significant asbestoslike human disease and should be included in any listing of important EMPs Paragraph 2 of Page 6 continues the confusion by equating the terms fibrous and asbestiform and suggesting that acicular fibers are not fibrous The final sentence again excludes non- asbestos EMPs from the discussion Geological Definitions In Sectioin 2.3.1 NIOSH states that in addition to asbestos there is interest in related materials that may resemble asbestos e.g. fibrous antigorite richterite and winchite unrelated fibrous minerals e.g. the zeolites erionite and mordenite the clay materials sepiolite and palygorskite etc. and individual particles or fragments of the nonasbestiform asbestos minerals Again it is unclear why fibrous talc and edenite both unrelated fibrous minerals are not included in the listing when erionite another unrelated fibrous mineral is listed All three asbestos materials erionite fibrous talc and fluoro- edenite have been heavily associated with asbestos health effects The NIOSH Recommendation for Occupational Exposure to Asbestos Section 2.6 In 1990 NIOSH recommended microscopic methods be used to define fibers as particles having ) an aspect ratio of 3 to 1 or greater 2 the mineralogic characteristics of the asbestos minerals and their nonasbestiform analogs and 3 cleavage fragments from the nonasbestiform analogs of the serpentine minerals antigorite and lizardite and the amphibole minerals in the series cummingtonite ferroactinolite and glaucophane- riebeckite This paragraph should also note that NIOSH 1990 excluded asbestos other EMPS such as fibrous talc erionite winchite and richterite edenite had not yet declared itself in terms of human.disease Amphibole Asbestos and Other Fibrous Minerals Section 2.6.1.2 Paragraph 2 of Page 19 cites concerns over the fact that current OSHA and MSHA asbestos definitions cover only the asbestiform varieties of the six commercially important asbestos materials NIOSH specifically cites the problem of OSHA and MSHA regulations not including the asbestiform amphiboles winchite and richterite in Libby MT vermiculite exposures and the asbestiform amphibole edenite in the Biancavilla Sicily exposures NIOSH should also mention the failure of OSHA and MSHA to include to Turkish erionite and upstate New York talc both of which have been found to exposure contain asbestiform fibers by at least some investigators see below Epidemiologic Studies Section 2.6.1.3.1 On Pages 23-27 the NIOSH discussion of the epidemiology of upstate New York talc workers assumes that the talc EMP exposures are nonasbestiform and the talc epidemiology discussion with that on gold and taconite miners Such a ggrroouuppsing suggests that the results of epidemiologic findings in talc workers have been similar to those in gold and taconite miners In fact studies of talc workers have demonstrated a clear pattern of asbestos disease including increased risk for pleural plaques and a three increased risk for lung cancer and a number of reports of pneumoconiosis mesothelioma in miners see below Studies of gold and taconite workers have malignant shown little or no evidence of asbestos disease see below Upstate New York talc workers No explanation is given for designating the fibrous talc exposures of upstate New York as nonasbestiform other than mentioning that the exposures have been reported to be no,, asbestiforbmy RT Vanderbilt Kelse 2005 NIOSH does state that the NIOSH 1980 industrial hygiene analysis of RT Vanderbilt talc showed 4.5-15 anthophyllite some of which was asbestiform But because the NIOSH 1980 study proved to be the subject of debate NIOSH suggests that the asbestiform anthophyllite fibers may have been transitional minerals - as if the fibers were therefore no longer asbestiform and were not to be considered biologically significant NIOSH should clarify that a number of independent investigators and organizations over a period of some 50 years have found the EMPs in upstate New York talc to be asbestiform in habit see below Engel 1962 of the USGS describes the talc of upstate New York as highly striated fibrous bundles of anthophyllite and tale Rohl and Langer 1974 note the presence of at , least three asbestiform minerals tremolite anthophyllite and chrysotile in upstate New York talcs IARC 1987 after extensive review and analysis of the world's literature found that certain talcs primarily from upstate New York contain asbestiform fibers and meet the criteria for a Group 1 human carcinogen Beard 2001 at Research Triangle Institute in an independently funded analysis founRdT Vanderbilt talc from upstate New York to contain more than 20 asbestiform fibers including asbestiform talc .81 asbestiform anthophyllite 4.4 and asbestiform transitional fibers 16 The 2005 USGS dataset on asbestos sites in the Eastern United States notes that the Arnold talc mine in upstate New York contains asbestiform anthophyllite and asbestiform tremolite The dataset cites as references Ross 1968 Van Gosen 2004 and Webber 2004 as well as Engel 1962 and Beard 2001 Van Gosen 2007 reports that regional metamorphism of dolomitic marbles in Gouverneur talc mining district created fibrous varieties of talc tremolite and anthophyllite as well as unusual transitional fibers a Webber et al 2004 see footnote 14 of the New York State Department of Health analyzed samples of talc ore from upstate New York and reported that % of crushed Arnold pit ore was respirable The respirable fraction contained large proportion of asbestiform fibers typified by aspect ratios exceeding 10 often in the hundreds curved fibers and fibers terminating in frayed ends When the crushed ore samples were aerosolized the airborne fibers were found to be anthophyllite 40 tremolite % intermediate 48 and talc % The authors then reconstructed air concentrations of anthophyllite asbestos near the talc mines from 1846 to 1967 using nearby lake sediment samples They demonstrated that airborne anthophyllite asbestos concentrations a increased more than five times over the studied time period b correlated significantly p .01 with annual production of local talc and c were much higher p = .004 than concurrent concentrations in a control lake located upwind of the mines and mills As discussed on Page 23 an excess of pulmonary fibrosis and pleural plaques is well recognized to have occurred among workers exposed to fibrous talc Siegel 1943 Kleinfeld 1955 NIOSH should emphasis however that lung cancer mortality has been consistently reported to be elevated in studies New York talc miners Kleinfeld 1967 Kleinfeld 1974 Brown 1980 and NIOSH 1990 Stille 1982 Lamm 1988 Gamble 1993 Honda 2002 despite various study weaknesses that make dose- evaluations difficult NIOSH should mention that there have been a number of response mesothelioma cases reported among NY talc workers including Kleinfeld 1955 Kleinfeld 1967 and 1974 and NIOSH 1980 see footnote ) Vianna 1981 see footnote 5 Honda 2002 Hull 2002 and Rubin 2006 At least some of the cases included of other markers of asbestos disease including pleural plaques asbestosis or rpenpeourmtsoconiosis asbestos bodies and asbestos fibers in lung tissue Kleinfeld 1955 Hull ; 2002 Rubin 2006 Given the dramatic findings of Webber 2004 above it is important for NIOSH to mention that the residents of St. Lawrence County are also exhibiting evidence suggestive of asbestosrelated diseases The mortality rate for all pneumoconioses in St. Lawrence County was 5-10 times higher than NYS rates from 1975 to 2004 NIOSH WORLD 2007 see footnote 5 Mortality from asbestosis specifically was 4 times higher than the NYS rate from 1995 to 2004 NIOSH WORLD 2007 see footnote 5 The incidence of lung and bronchus cancer for 2003-2007 in St. Lawrence County is 43 higher than in New York State in both men and women There is a higher than expected number of lung cancer cases for 2002-2006 in over half the zip codes of St. Lawrence County including the Gouverneur zip code 37 cases v 17.2 predicted The lung cancer incidence in Jefferson County is also elevated in both men 38 and women 36 compared to New York State rates These elevated lung cancer rates not appear related to increased smoking rates in the local populations Smoking rates in St. Lawrence and Jefferson counties are similar to those in the rest of NYS excluding NYC 22.2 v 22.1 of adults Mesothelioma rates from 1966 to 1981 were significantly elevated in Jefferson County the site of some of the talc industry in New York and located only a few miles from the concentration of talc mines in adjacent St. Lawrence County Vianna 1981 Enterline 1987 see reference 5 In more recent years 1999-2004 the mesothelioma mortality rates in St. Lawrence and Jefferson counties appear to be only slightly higher than NYS % and % respectively see reference 5 Vermont talc workers On Page 27 NIOSH discusses the cohort study of Vermont talc workers Selevan 1979 and states that available evidence indicates that Vermont talc is free of asbestos fibers without citations In addition to indicating sources for this statement NIOSH should mention that several investigators have reported asbestos in Vermont talc Zodac 1940 describes of fibrous actinolite in the talc quarry in Chester VT Van Gosen radiating masses in some areas host 2004 see reference 13 of the USGS reports that Vermont talc deposits developed chrysotile asbestos citing Bain 1942 and Cady 1963 However NIOSH should also address whether Vermont talc contains asbestiform minerals other than asbestos per se NIOSH should mention for instance that the companion NIOSH industrial hygiene study for Selevan 1979 found talc shards and ribbons both in bulk talc and in airborne dust samples Boundy 1979 NIOSH should also mention that sotahmeprlesstudies of Vermont talc report the presence of asbestiform amphiboles structurally and . chemically intermediate between anthophyllite and talc and similar to those reported in the Gouverneur talc mining district by Ross in 1968 Veblen 1977 and Veblen 1978 Van , Gosen 2004 see reference 13 NIOSH notes that the mortality study of Vermont talc workers reveals significantly increased risk for malignant respiratory disease with significantly increased risk among millers but not miners Selevan 1979 NIOSH should also mention that a most of the men who died of NMRD had radiographic readings consistent with pneumoconiosis and b the concluded that the ray evidence supported talc as the etiology of NMRD in the authors risk NIOSH should also millers but that data were too limited in miners to judge their true mention the subsequent Harvard School of Public Health PFT and ray study of Vermont talc workers in which PFT abnormalities and small irregular opacities on chest ray were significantly related to years of employment and years of exposure The authors concluded that talc workers were being affected by their work exposures Wegman 1982 Respiratory cancer risk in the Selevan 1979 study was significantly increased among miners and not millers a pattern similar to that in RT Vanderbilt miners and millers NIOSH notes that the authors suggest that their respiratory cancer findings might be due to talc NIOSH should also note that the authors also suggest that talc may be acting in exposures combination with other factors to affect cancer risk Summary ofEMP epidemiology On Page 31 NIOSH then summarizes the epidemiologic studies of cohorts exposed to nonasbestiform EMPs The section heading and the ensuing discussion imply that NIOSH has been tasked to consider only the other EMPs that are nonasbestiform rather than all other EMPS including the asbestiforms According to Dr. Howard's Foreward this is not so see Pages ii This epidemiologic summary should include an handed review see above of all of the other EMPs that have been heavily associated with asbestos diseases including upstate New York and Vermont talcs Libby MT vermiculite Cappadocian erionite and Sicilian edenite It should then conclude with the more limited evidence of asbestos disease associated with South Dakota's gold mine and the northeastern Minnesota's taconite mines Some Minerals ofPotential Concern Not Covered by the NIOSH REL This section belongs in the 2.6.1.3.1 Epidemiologic Studies section on Pages 22-32 as discussed above Covered Some Minerals ofPotential Concern Not by the NIOSH REL On Page 35 the Roadmap states in reference to EMPs that only for erionite has the IARC made an assessment that the evidence was sufficient to determine that it is a human " carcinogen This is simply untrue and NIOSH should correct this sentence to properly reflect IARC's findings on talc In 1987 IARC opined that there is sufficient evidence for the carcinogenicity to humans of talc containing asbestiform fibres In fact in 2007 IARC opined that there is limited evidence for the carcinogenicity in experimental animals of talc not containing asbestos or asbestiform fibers and classified such talc as Group 3 not classifiable as to its carcinogenicity to humans Summary ofKey Issues On Page 68 NIOSH attempts to summarize key issues developed by the Roadmap But once again the paragraph begins by framing its first question around fibers from the asbestos minerals rather than asbestos and the other EMPs In the next paragragh Page 69 the summary shifts back briefly to EMPS and mentions erionite as well as the asbestos minerals It even mentions EMPs such as quartz and yet does not mention important other EMPs including upstate New York and Vermont talc Libby vermiculite containing winchite and richterite and Sicilian edenite a Unfortunately this summary reflects the Roadmap's failure to define and use the term asbestos and other EMPs in a consistent manner as intended by Dr. Howard in the Foreward Pages ii Frameworkfor Research clear and consistent use of the Fortunately Page 70's Framework for Research returns to a term asbestos and other EMPs as stated by Dr. Howard in the Foreward Pages ii to Asbestos Fibers and Develop Information and Knowledge on Occupational Exposure Other EMPs and Rel3a.t5e.d2HtehaeltRhoaOudtmcaopmeagsain reverts to the statement that the body of of On page 86 section human health effects from exposure to EMPs consists primarily knowledge concseturdniiensgof workers exposed to asbestos fibers and several other types of EMPS of examples is epidewmoilollaosgtiocnite attapulgite erionite As pointed out above this listing e.g. It cites two EMPs associated with very little epidemiologic incomplete and misleading fails to cite other EMPS evidence of asbestos disease wollastonite attapulgite yet heavily associated with asbestos disease upstate New York and Vermont talc Libby vermiculite containing winchite and richterite and Sicilian edenite the Roadmap seeks to ensure a clear science base In the last sentence of the same paragraph to all a formal recommendation for control of occupational exposures that might support fibers This terminology is confusing and inappropriate It limits the asbestiform amphibole nonasbestiform EMPs It further recommendation EMPS eliminating recommetondoantliyoansbteostifaomrpmhiboles eliminating both erionite and upstate New York limits the associated with asbestos disease NIOSH should and Vermont talc which are heavily in the interest of clarity and change this terminology to all asbestos and other EMPs consistency with Dr. Howard's Foreward + of EMPs from nonasbestiform amphiboles and seeks to The next paragraph then speaks Although it is important to their health risks to those of asbestiform amphiboles compare the nonasbestiform EMPs as well as the asbestiform EMPs mentioned above the consider exclude amphibole EMPS such as erionite and upstate New consideration should not York and Vermont talc This entire section is crippled by its changing terminology It and other EMPs in concert would be greatly strengthened if it used the terminfoolrogRyesaesabrecsthossection on Page 70 with Dr. Howard's Foreward and the Framework Conduct Selective Epidemiological Studies of Workers Exposed to Asbestos FibersFibers and Other EMPS 87-90 categorize upstate New York and Vermont talc exposures as Section 3.5.3 Pages out above using the term EMPs from nonasbestiform amphiboles As has been pointed in relation to upstate New York and Vermont talc nonasbestiform is inappropri3aotfe this commentary Using the term amphiboles is also too exposures see above at page although a magnesium silicate is not considered to be one of limiting in that the mineral talc the amphiboles Summary of Critique is intended to define the As stated in the Roadmap Executive Summary this document scientific and technical research issues that need to be addressed to ensure that workers are ^' from health risks posed by exposure to asbestos fibers and other EMPs includes a optimally protected To make its point more vivid concerning other EMPs the cover of the Roadmap remarkable USGS photograph of upstate New York talc fibers - must now effectively frame its epidemiologic discussion to include all other TEhMePRSoadbomtahpasbestiform and nonasbestiform - beyond the six types of asbestos and their asbestiform analogues The EMP health problems in Libby MT winchite richterite Cappadocia erionite Biancavilla edenite upstate New York and Vermont fibrous northeastern MN taconite and perhaps others cry out for proper overview analysis talc further investigation NIOSH must follow through on its promise to protect humans from and asbestos and other EMPs all of them - or it will miss or misinterpret current and future opportunities to prevent EMP disease Yours truly Elaine B. Panitz MD MPH 2 patterns Fibrous tale a Kleinfeld M Messite J Kooyman O et al Mortality among talc miners and millers in New 1 Messite J. Mortality experience among talc York State AEH 1967 May 14 663-667 b Kleinfeld M workers a follow study J Occup Med 1974 May 16 345-349 c NIOSH Technical Report to talc containing asbestos US DHEW PHS CDC NIOSH 1980 d NIOSH HHE Occupational exposure R. T. Vanderbilt Company Gouverneur New York 1990 Selevan SG Dement Report HETA 90-390-2065 miners and millers of asbestiform talc preliminary JM Wagoner JK et al Mortality among * J Environ Pathol ToxicolToxicol 1979 2 273-284 reporetdenite a Comba P Gianfagna A Paoletti L. Pleural mesothelioma cases in Biancavilla are b Biggeri 2 related to a new edenite fibrous amphibole Arch Environ Health 2003 229-232 Pasetto Belli Bruno Di Maria Mastrantonio Trinca Uccelli Comba P. Mortality from chronic disease and pleural mesothelioma in an area contaminated by natural fiber fluoro- obstructive pulmonary Health 2004 249-52 c Bruno Comba Zona A. Adverse health edenite Scand J Work Environ Ann NY NY Acad Sci 2006 effects of edenitic fibers epidemiological evidence and public health priorities 778-83 review Mortality in Libby Montana 1979 to 1998. August 8 2002 3 ATSDR Mortality www.atsdr.cdc.gov/asbestos/sites/libby_montana/mortality Peipins LA Lewin M Campolucci S w w.atsdr.cdc.gov/asbestos/sites/lib y_montana/mortality www.atsdr.cdc.gov/asbestos/sites/libby_montana/mortality vermiculite in the community of et al Radiographic abnormalities and exposure to contaminated Libby Montana USA EHP 2003 Nov 111 1753-1759 Horton DK Bove F Kapil V. Select mortality contaminated and cancer incidence among residents in various US communities that received vermiculite ore from Libby Montana Inhal Toxicol 2008 20 767-775 of Health Cancer incidence rates in northeastern Minnesota with an emphasis on 4 Minnesota Department mesothelioma MCSS Epidemiology Report 03 February 2003 of Health Mesothelioma in Northeastern Minnesota and Two Occupational Cohorts Minnesota Department 2007 Update Center for Occupational Health and Safety Chronic Disease and Environmental Epidemiology Section Minnesota Department of Health St. Paul MN December 7 2007 http://www.health.state.mn.us/ documents nemeso1207.pdf nemeso1207.pdf 5 Vianna NJ Maslowsky J Roberts S et al Malignant mesothelioma Epidemiologic patterns in New York State New York State J Med 1981 Apr 735-738 Enterline PE Henderson VL Geographic patterns for pleural mesothelioma deaths in the United States 1968-81 JCNI 1987 Jul 79 31-37 NIOSH Work- Related Lung Disease WORLD Surveillance System Malignant mesothelioma mortality http://www2.cdc.gov/drds/WorldSectionDetails.asp NIOSH Related Lung Disease WORLD Surveillance System All pneumoconiosis mortality and Asbestosis mortality http://www2.cdc.gov/drds/WorldReportData/http://www2.cdc.gov/drds/WorldReportData/ FigureTableDetails.aspRefNumberF01-03b 6 Engel AEJ The prercambrian geology and talc deposits of the Edwards district northwest Adirondack Mountains New York US Geological Survey Open File Report preliminary 1962 7 Rohl AN Langer AM Identification and quantitation of asbestos in talc EHP 1974 9 95-109 8 IARC Monographs on the Evaluation of the Carcinogenic Risk of Chemicals to Humans Silica and some , silicates talc 42 185-224 1987 9 Beard MR Crankshaw OS Ennis JT et al Analysis of crayons for asbestos and other fibrous materials and recommendations for improved analytical definitions Center for Environmental Measurements and Quality Assurance Research Triangle Institute 2001 Feb 28 10 Van Gosen BS Reported historic asbestos mines historic asbestos prospects and natural asbestos occurrences in the Eastern United States US Geological Survey Open Report 2005-1189 Version 2.0 http://pubs.usgs.gov/of/2005/1189/pdf/Plate.pdf http://pubs.usgs.gov/of/2005/1189/pdf/Plate.pdf htp:/pubs.usg.gov/of/205/189/pdf/Plate.pdf . 11 Ross M Smith WL Ashton WH Triclinic talc and associated amphiboles from Gouverneur mining district New York The American Mineralogist 1968 May 53 751-769 12 Van Gosen BS Lowers HA Sutley SJ et al Using the geologic setting of talc deposits as an indicator of 13 amphibole asbestos content Environmental Geology 2004 45 920-939 Webber JS Jackson KW Parekh PP Reconstruction of a century of airborne asbestos concentrations Environ Sci Technol 2004 38 707-714 14 Van Gosen BS The geology of asbestos in the United States and its practical applications Environ & Engineer Geoscience 2007 Feb XIII 55-68 15 Siegal W Smith AR Greenburg L. Report on study of talc miners and millers in St. Lawrence County The Industrial Bulletin 1943 Nov 434-437 468 16 Kleinfeld M Messite J Tabershaw IR Talc pneumoconiosis AMA Indust Health 1955 66-72 experience 17 See reference . , 18 Stille WT Tabershaw IR The mortality of upstate New York talc workers J Occup Med 1982 Jun 24 480-484 19 Lamm SH Levine MS Starr JA et al Analysis of excess lung cancer risk in short employees Am J Epidem 1988 127 1202-1209 20 Gamble JF A nested case control study of lung cancer among New York talc workers Int Arch Occup : mining Environ Health 1993 64 449-456 21 Honda Y Bealk C Delzell E et al Mortality among workers at talc and milling facility Ann Occup Hyg 2002 46 575-585 22 Kleinfeld M Messite J Tabershaw IR Talc pneumoconiosis AMA Arch Indust Health 1955 66-72 23 See footnotes above . http://www.cdc.gov/ ) workers in asbestiform bearing talc mines 24 Hull MJ Abraham JL Case BW Mesothelioma among in New York State Ann occup Med 2002 Suppl 132-135 25 Rubin E. Letter to J. Kelse RT Vanderbilt Company Inc. dated November 8 2006 docket kelse_sub.file3.pdf htp:/w.health.stae.nyus/taistcs/ancer/egistry/zipcode/lung/stlawrenc.htm http://www.health.state.ny.us/statistics/cancer/registry/zipcode/lung/stlawrence.htm 26 New York State Cancer Registry Cancer incidence and mortality by county and gender St. Lawrence htp:/w.healt.saeny.us/taisc/aner/gistry/volcst.lawrenc.htm and htp:/w.health.stae.ny.us/taistics/cancer/egistry/pdf/volume1.pdf htp:/w.health.sate.nyus/taistc/ancer/gistry/pdfvolume1.pdf htp:/w.health.stae.ny.uhs/ttaistticsp/can:cer//eg/istrwy/vowl/vwlcst..lahwrenece.hatmlth.state.ny.us/statisticsh/tcp:a/nwcew.rh/earlethg.istsatter.nyy/.upsd/sft/atviostlicusm/cea1nc.epr/drfegistry/vol/vlcst.lawrence.htm htp:/ww.health.state.ny.us/statistics/cancer/registry/vol/vlcst.lawrence.htm bronchus County 2003-2007 htp:/w .health.stae.ny.us/taistics/cancer/egistry/vol/vlcst.lawrence.htm htp:/w.health.stae.ny.us/taistics/cancer/egistry/vol/vlcst.lawrence.htm htp:/w.healt.sate.nyus/taisc/ancer/gistry/volcst.lawrenc.htm htp:/w .health.stae.ny.us/taistics/cancer/egistry/pdf/volume1.pdf 27 New York State Cancer Registry Lung and htp:/w.health.stae.nyus/taistcs/ancer/egistry/pdf/volume1.pdf cancer incidence by zip code St. Lawrence County 2002-2006 htp:/w.health.stae.ny.us/taistics/cancer/egistry/zipcode/lung/stlawrence.htm htp:/ww.health.state.ny.us/statistics/cancer/registry/zipcode/lung/stlawrence.htm and mortality by county and gender Jefferson 28 New York State Cancer Registry Cancer incidence County 2003-2007 htp:/w.healt.saeny.us/taisc/aner/gistry/volcjefrson.htm htp:/w.healtse.nyus/taics/anergistry/volcjefrson.htm htp:/w.healt.sate.nyus/taisc/ancer/gistry/volcjefrson.htmhttp://www.health.state.ny.us/statistics/cancer/registry/voll/vlcjefferson.htm htp:/w.health.stae.ny.us/taistics/cancer/egistry/vol/vlcjeferson.htm Tracking Public Health of Health St. Lawrence County Indicators for 29 New York State Department stlawrence.htm Priority Areas http://www.health.state.ny.us/prevention/prevention htp:/w.health.stae.nyus/prevntion/prevntion http://www.health.state.ny.us/prevention/prevention htp:/w.health.sate.nyus/prevntio/prevntio_agenda/indcators/county/jefrson.htm htp:/w.healt.saeny.us/prevntio/prevntio_agend/icators/cunty/jefrson.htmhtp:/w.healts.nyu/prevntio/prevntio_aged/incators/unyjefrson.htm http://www.health.state.ny.us/prevention/prevention_agenda/indicators/county/jefferson.htm and VT Rocks and Minerals 1940 15 369-371 . A 30 Zodac P. talc quarry near Chester related to talc and asbestos deposits In Newhouse WH ed Ore deposits as 31 Bain GW Vermont Princeton University Press 1942 pages 255-258 structural features Princeton UniversitAy HPreBsesdrock geology and asbestos deposits of the upper Missisquoi 32 Cady WM Albee AL Chidester Bulletin 1122 1963 78 pages 1 plate Survey Valley and vicinity Vermont US Geological Presented at Conference on to asbestiform talc in Vermont 33 Boundy M. Occupational exposure Their Extension into the Environment Washington to Fibrous and Particulate Dust and Occupational Exposure eds Dusts and Disease Park Forest South IL Pathotox DC December 6 1977. In Lemen R Dement JM Publishers 1979 chain silicates new minerals and structural groups 34 Veblen DR Buseck PR Burnham CW Asbestiform VT I. Descriptive Science 1977 198 359-365 Veblen 78 Burnham CW New biopyriboles from Chester mineralogy American Mineralogist 1978 63 1000-1009 and millers Peters JM Boundy MG et al Evaluation of respiratory effects in miners 35 Wegman DH 39 233-238 exposed to talc free of asbestos and silica Br J Indust Med 1982 of the Carcinogenic Risk of Chemicals to Humans Silica and some 36 IARC Monographs on the Evaluation silicates including talc 42 185-224 1987 and talc not containing hazards from inhaled carbon black titanium dioxide 37 Baan RA Carcinogenic IARC Monographs Working Group Inhal Toxicol asbestos or asbestiform fibers recent evaluations by an 2007 Suppl ) 213-228 New York talc fibers along with the acknowledgment of the 38 Why has the cover photograph of upstate of the 2009 draft been eliminated from the January 2010 draft USGS for its contribution both previously part