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FILE NAME Talc TALC DATE 1973 DOC TALC441 DOCUMENT DESCRIPTION Memo RE Tremolite in Talc From: From Copies: gubiact: TREMOLITE TREMOLITE Subject view packg rou ch the claim ecision our 15 rite "hrem asked nce that you as Vanderbilt's to to tremolite decision tremolite arize not os sup ort st rot x pnical wevers gfering from a technical technical reasons not on since since involved rons technical t you you acquainted However these e summarize briefly amphibole mineral mineral However from nerally you amosite briefly crocidolite crocidolite and other amphiboles calcium for part magnesium differing in crock substitution the magnesium ercia and present the internal actinolite other - generally amphiboles amphiboles Fibers usually tremolite actinolite more brittle general y those generally dolite ' utility amosite find commercial aL commercial utility reinforcing From utility reinforcing point particles scientific categorized be point included categorized categorized tremolite asbestos definition definition definition pe cate! nis bestos first Celite Environmental Environmental Attachment Environmental Environmental Attachment reclassification reclassification includes reclassification following definition included personnel in stand on the minutes minutes on The tremolite summarized statements * statements includes Fenner M. Fenner following expresed expressed that enol tremolite as meeting meting meeting 1972 meeting n cing cel {gee Celite Celite ge & naven * gotto the we haven't got "Pure crocidolite prayer amendment amendment . am site with respect regulation tremolite tremolite the Fur- poth thermore thermore respect Jackson Fenner proven causative report mesothelioma amosite oma c ium these materials a causative mesothelioma is similar Both a og these materials have electron fibrous exhibited symposium a symposium tremolite presented electron the micrographs Institute exhibited Mining Min g ASSOT Metallurgy Canadian the of Asso- 21-23 and ciation reprinted Quebec Quebec characteristic Asbestos Ss 21-23 1958 comparing crocidolite characteristic pages and tremolite THus + veypers M. Jackson opinion tremolite Thus K fibers vret delineated Jackson tremolite tremolite long term long on _ study 3 8 Trehearing hearing fear ng, wasnot separately identified OSHA , ite ovidence have developed developed to OSHA prem no tremolite pe There functioning asbestos @ar functioning ate aeLin mineral epa There to minera+: moLite ta fh pest wide g gunctions | Ee | Beeprterccesen F. L. Pundsack ; August 28 1973 area of attack by reclassification reclassification of tremolite through mineralogical or structural definition Any approach to disassociation will require medical evidence Although meeting no Research representatives were present I heartily agree with the conclusions of at this the group On January 11 1973 S. Speil R. S. Lamar N. B. Sheffel and E. L. Smith were given a presentation at the New York offices of R. T. Vanderbilt of the story put together by Mr. C. S. Smith Vanderbilt geologist to prove that Unfortunately tremolite especially that present in the Vanderbilt Company this New York State calc was not asbestos no technical evidence to support Vanderbilt's pproessietnitoantionThegavpehotomicrographs showed that the particles of tremolite were indeed much shorter than chrysotile fibers and did have an aspect ratio R less than that of crocidolite and amosite used commercially However the D for many particles was definitely over 3 the present limit established by ACGIH and accepted by OSHA and therefore they would be included in the category of fibers Many of these particles had D's greater than 10 by It is conceivable that the presentation would have an impact on the layman but assuredly not on any person having technical in the field of asbestos or asbestos regulation Tchoempperteensceentation relied heavily on layman definitions of a fiber from various encyclopedias and a list of asbestos minerals proposed Mr. Thompson which he indicated came from THE FEDERAL REGISTER and which included tremolite and actinolite as fibrous varieties This information is in- cluded as Attachment B. and In the amphibole field amosite and crocidolite fibers have their fibrous counterparts with specific terminology-- cummingtonite riebeckite respectively Normally antho- phyllite tremolite and actinolite are used to include any occurrence these amphiboles whether fibrous or fibrous I indicated that M could not support techni- At this meeting stated that the Talc cally Vanderbilt's position Mr. Harvey Producers had scheduled a meeting in early February to develop new definitions of asbestos talc and commercial talc which they would propose for acceptance by an ASTM Subcommittee on Paints and Pigments Once accepted this would serve as a apringboard to foster approval by Government agen- cies I pointed out that definitions for asbestos and for the term fiber already existed under the auspices of other ASTM groups and agreed to supply this information as well as 000053 F. L. Pundsack August 28 1973 participate 5 meeting on definitions in the February of the defi- to Subsequently I sent to Mr. Thompson fiber copies under ASTM D2946-71T to asbestos as well as nitions relating in which fiber was defined with a L of 10 textile purposes under ASTM the definition of fiber for least 100 was speci- D123 in which an / of at Committee included as Attachment C. fied These are with from other 5 meeting none of the attendees that At the February with the Vanderbilt proposal ttarleemoplriotdeucweas rs noctoncausrbreedstos During the discussion I empha- sized 1 items requiring action was to that one of the major the ACGIH definition talc fibrous elimination of secure 5 fibers TLV established Tremolite and the concomitant by the ACGIH could be classed as fibrous 2 that tremolite particles the / ratio for each indi- . or fibrous depending upon the thrust here should be to vidual particle and that D than the 1 currently attempt to establish a higherof the essence I suggested accepted Becausteheti1 me0warsatio of ASTM Designation D2946-71T that we propose specifically ex- not try to redefine asbestos to lead to a 3 that we since assuredly this could only clude tremolite and scientific debate long technical to the FDA or to the Bureau of Mines 4 that any presentation at Vanderbilt's behest Symposium which hadobneetnhearmreadnigceadl evidence regarding the and other should conceinntrbaitoelogical effect of tremolite a difference amphibole fibers and . single definition of commercial talc 5 that we propose a of talc and therefore which would include all types between pure eliminate the need for d-iTfrfeemroelnittieataisngdefined defined by the ACGIH talc and talc fibrous adopted by the group and were recommendations tentatively accepted In general these definition proposed by me was the following the Talc Producers Association . for presentation to talc is a product varying in mineral ] Industrial mineral tale Mg6 Si8020 ) OH naturally natural y composition from the and other naturaly asso- to mixtureosf mineral talc minerals as defined ciated fibrous and fibrous , by ASTM Designation D2946-71 000054 F. L. Pundsack 4- . , August 28 1973 Acceptance of this definition would automatically infer a change of the / of a fiber to 10 and eliminate many tremolite particles from the fiber category and therelore from the asbestos category However a considerable percentage of the tremolite particles would still be classed as asbestos fiber Although ASTM would probably accept this de.inition of talc I frankly doubt whether Government agencies would | Subsequent to this meeting R. S. Lamar on January 31 1973 a proposed to P. A. Martinson that we lettlee ttr er giving our position to our customers and the industry and stating that tremolite is ar asbestos mineral I commented at length on on this letter February 14 see Attachment D recommending that we not send out such a letter The major thrust of my comment was addressed to the point that tremolite can be either fibrous or fibrous i.e. either asbestos or not depending on the shape of each individual particle and that we should not categorically state that all tremolite was indeed asbestos Incidentally some of my much earlier comments might be inter- preted as indicating that all tremolite was asbestos Since that time I have had essentially no contact with the tremolite in talc situation which has been Bill Streib's responsibility My understanding is that at the Bureau of Mines Seminar in May 1973 the M presentation was restricted - primarily to medical aspects differentiating between the effects of stand that tremolite and other asbestos fibers I the Vanderbilt presentation included the also same understory which was given to us in January to prove that tremolite was not asbestos but possibly modified in the light of our discussions In July 1973 Vanderbilt through their attorneys petitioned OSHA to modify asbestos standards promulgated pursuant to the OSHA Act This is presented in Attachment . I am entirely in accord with their petition to replace the word tremolite by asbestiform tr^molite to distinguish this from the non- fibrous by definition forms tremolite In this way nonasbesti tremolite and talc would be subject to the mineral dust standard and asbestiform tromolite would continue to be subject to the asbestos standard 5 Their proposal summarized on the February meeting in Appendix I of Attachment previously referred to and E is based there- fore is entirely acceptable although personally I see no possibility of Government agencies changing the L definition of a fiber from 1 to 10 except by the presentation of 000055 F. L. Pundsack August 28 1973 evidence valid medical to support such a change Some of the work that the QAMA is supporting at Fairleigh Dickenson and the work being done by Stanton on sized fibers prepared by us might serve as the basis for bequesting such a proposed change which would undoubtedly be opposed by Selikoff on the basis of the limited data available Incidentally I ha been told thirdhand that Vanderbilt secured concurrence of their original proposal to eliminate tremolite as an asbestos mineral from Governmental regula- tions EPA and that this of Attachment E. A close indicates the presence of is supported by Appendices9 and 10 reading of these letters from EPA weasel words since they both include the statement the standard is applicable however to paint and coatings manufacturing when asbestos as defined by 40 CFR 61.20 with the above exception is used in the manufacturing process Tremolite is included as an asbestos mineral in 40 CFR 61 and even though both letters state that 40 CFR 61 National Emis- sion Standards for Hazardous Air Pollutants will be amended in order to properly clarify this situation neither letter indicates that tremolite will be removed from the definition of 40 CFR 61.21 is hard to understand how industrial talc some of which contains 50 per cent be specifically excluded merely by containing tremolite rather than or more calling calling of tremolite can this material talc it tremolite con- taining talc A copy the applicable portions of the National Emission Standards for Hazardous Air Polluft oraan sbet sts os is in- cluded as Attachment F. In the M crisis the FDA decision to meeting on August 24 1973 issue proposed standards on to discuss food grade _ talc which presumably would also include talc used in paper for wrapping foods R. F. Carter stated that he had been told by FDA management personnel responsible for preparing the regulations that they were in favor of issuing an interim regulation which would continue the status quo for at least 2 to 3 years while technical and medical evidence were being accumulated to insure a fair and reasonable set of regulations However they had been instructed instead by their superior the new Commissioner of FDA to prepare proposed regulations restricting the use of containing asbesti minerals for immediate publication Carter was told that the entire technical and medical evidence presented by M and other industrial petitioners was completely ignored in this decision which was motivated by political pressure from the Environmen- tal Defense Fund and other groups 000056 SAIS SALAS top an bere PONS EU NESNARSESME VINE see Taran ~6- F. L. Pundsack August 28 1973 - of the record I am attaching a copy of - Finally to complete F. D. Richards Attachment G " pmoyinlteintgte ourt tAhuegusptoss9ibi1l9i7t1y otfo future difficultiwietsh FDA before we purchased Grantham Talc SS Attachments A through G 000057 CRMC bie 6. X January 25 1973 De : B co. F. J. Solon Jr. H. M. Jackson E. M. Fenner W. P. Reitze Dr. G. Wright . Dr. S. Speil r J. Leineweber , Dr. E. Marriner R. P. Carter W. L. Va Durbeek P. A. Martinson H. R. Keefe R. S. Lamar N. B. Scheffel . ; - ds. oe R | ; j Lt : : s ; 5 i . | R. T. VANDERBILT ACTIVITIES FDA OSHA REGULATIONS REGULATIONS On January 11 as arranged by Norman B. Scheffel a meeting was held at the R. T. Vanderbilt New York offices to observe a presentation of the field by RTV to Government agencies concerning talc vs. asbestos In attendance were Dr. Speil R. S. Lamar N. B. Scheffel and E. B. Smith of The presentation consisted series of slides as photomicrographs comparing Vanderbilt New York State talc Nytal 100 200 300 400 California talcs Westal 101 303 and 404 and beneficiated California talcs Compared also of were slides asbestos minerals In this presentation it is the objective of Vanderbilt to establish that tremolite is fibrous and asbestoform in order to obtain an amendment or variance in the OSHA regulations to exclude tremolite The presentation did contrast the particle shape of their tale mineral as compared to asbestos fibers but lacked any real scientific evidence to differentiate current definitions Vanderbilt has made this presentation to the New York State Bureau of Mines attended by Dr. Jacquelin Messite Merley Sheffield and Stein Kleinfeld not present due to his retirement Vanderbilt has also made this presentation of to Earl Goodwin at the U. S. Bureau Mines They have also made these present Bureau of to EPA at Durham attended by Mr. Arthur Stevens Deputy Director the of Mines and Safety Vanderbilt feels that they have cast some doubt on the definition and are hopeful to pursue Government agency toward a new definition of commercial asbestos as opposed to tremolite as an asbestos mineral Vanderbilt has also been in communication with the A.S.T.M. Committee 1-31- Presentation made by Allan Harvey at Miami 07 concerning extender pigment the asbestos definition It was oriented towards the removal of tremolite from is their hope to obtain A.S.T.M. approval and use this approval with other Government agencies Vanderbilt has justifiably been reluctant to tackle NIOSH until more confidence is developed in their presentation Dr. Speil was of considerable help at this meeting in pointing out the pitfalls and errors in Vanderbilt's thinking It was concluded that the attack on tremolite vs. chrysotile must be medically Speii oriented as opposed to a simple fiber definition or redefinition obtain an exclusion suggested that a more appropriate approach would be to 000061 of tremolite baseodn scientifiocr medical reasons as opposed to a redefinition separating tremolite from chrysotile and asbestos However Vanderbilt intends to pursue the subject by enlisting the Tale Industry Association's help in developing an acceptable definition of talc asbestos etc. at the meeting scheduled for February 5 in New York In view of the expertise obtained by M people in this mineralogical area and the Government communications area we urge that Dr. Speil and additional environmental people at M attend the February 5 meeting in New York Attached to this memo are some definitions that Bob Bacon has extracted from various enclyclopedias and from the Federal Register concerning asbestos fibers It is in this direction that RTV intends to proceed We certainly question this attack and increased help from M to guide this program properly and scientifically not to the detrimenotf the talc industry Earl B. Smith EBS CRMC