Document dd0zeNMMGjeBNqN1jvLgngBe

CLEVELAND pr.i n i 1977 OCT 31 19TT TECH CENTER Cyprus Industrial Minerals Company 555 Soutti Flower Street Los Angelos, California 90071 Telephone 213) 469-3700 October 16 , 1977 TWX 910) 321-5753 * To You, Our Customer D. P.K . .Ocr 8 7 1977 We would like to take this opportunity to clarify some of the confusion which appears to be building in terms of talc and asbestos. A number of significant develop ments have recently occurred which tend to cloud the regulatory aspects of the problem. In May, 1977, OSHA published a booklet entitled "A Re port on the Fiber Content of Eighty Industrial Talc Samples Obtained from, and Using the Procedures cf the Occupational Safety and Health Administration". You may have received a letter from one of your suppliers analy- zing the data presented in this OSHA report. We feel that this analysis of the data was misleading in the manner in which it was offered. While we are of the opinion that the OSHA method of fiber analysis is not adequate to identify asbestos, OSHA does continue to employ this method. The conclusions drawn by the National Bureau of Standards in its discussion of the results states quite conclusively that they also feel the OSHA method is in dire need of review. We quote from the NBS report, Section V, Conclusions, P. 17, as follows: "The variability of these results raises several questions regarding the OSHA procedure, particularly sampling technique, sample homogeneity, and determi ning fiber morphology. It is the opinion of NBS that, even under favorable circumstances (e.g., homo geneous samples, easily identified fibers, etc.), the existing OSHA procedure is useful only for determining 'fiber' content and not 'asbestos' content. Although careful manipulation of the mounting medium might make it possible to identify some of the fibers as 'asbestos', the problem of the definition of 'asbestos' still re mains. NBS believes that the resolution of the measure ment problem, including the definition and identification of asbestos, will be accomplished only by significant changes in thd procedure and probably the method a3 well." PLAINTIFFS EXHIBIT CAM-379 aken.'. ' i j .a SW Goodhue 000253  i >'n F o llo w in g t h i s rep o rt^ a MJorkshop on A sb e sto s" was held at the Natiurval Bureau of Standards in Washington, July 18-20, 1977. Umf-ornusate.iy, t h is workshop did not r e s u lt in any change of test method but did serve to point out the extreme inadequacy of the procedure as it is presently constituted. ; We do not feel w h should speaJc for the talc industry in general, hurt rather, will review our own situation as it presently stands . In this ISHA report, 16 samples were tested which wjr= identified as Cyprus Industrial Minerals Ccspar.y talc. The results of the tests on these 16 samples are shown ieicr: CYPRUS IifflU ST R Ill MINERALS COMPANY . Montana. Texas Cal iformia T U 1 u CYPRUS T H Q g'STY, WIL.VKAS . Z'Z-YI?ANY 'Georgia 1 As can he seez from tils data, both our Montana and Texas talcs are indicated to be free of asbestiform material, Our California talcs contain only very minute quantities of tremolite In some Instances, We do state that they are free of asbestifrra impurities to the level of sensitivity as measured by X-ray Gf_ffraction Techniques. This is approximately 0.11 tc D:3'i. II .certificatlcm. to zero asbestiform level is deemed necessary h*y your company, only our Montana talc based grades should be e&ei. The one sample in c lu d e d in th e su rvey from our Cyprus Thompson Weinman s u b s id ia r y i s in clu d e d o n ly to i l l u s t r a t e the weakness - o f the OSffiA am alystB .methud. T h is sa a p le i s an alyzed as t a l c but i s , iis r e a l i t y , a p l a t a y m ica ( s e r i c i t e ) , not a t a l c m a te ria l at a l l . 323., l e t ns p>oajt: o u t , the 0SI1A method o f fi b e r an - l"-'''/' alysis by o p t i c a l on ciHBSC&y is in ca p a b le o f i d e n t i f y i n g the e x a c t inaaral sartOT" off th e sample b e in g in s p e c te d . In the Banner-:' i f $ in uhicla tk e r m litg * are s t a t e d , fib e r s are not to be considered >i*` ,-fV. m`l / ' <Ml asfc-aBtos K s Je s s They are p o s i t i v e l y i d e n t i f i e d as being one o f six xineraJLc i f i - c a l l y s t a t e d in the F e d e ra l R e g is t e r , 29 * !t. - -V C2'E 1S I C . 109 *2 l a ) I'c iir a ilic -n is. Thesa m in e ra ls can b e st be p o s i t i v e l y iikecatiiiibd l>y Ttaraunijseian E le c tr o n M icroscopy co*bined : with S e le c t e d tz'va E le c tr o s . M f f r a c t i o n . -ti'vc.V i,:: :`--v SW Goodhue 000254