Document kDk5Xp7ZEDveY2b600Qj4Ykp0
Intftr Offloe
General Product* Division
Saline Plant
August 26, 1975
To: D. A. Greschaw Industrial Hygiene
From:
W. B. Kozemchak
CC: F. J. Croskey F. J. Serbus
N. S.Tracy J, D. Woods
Subject: Talc Evaluation (Method of Testing for Asbestos)
Please find enclosed two samples of talc to be evaluated for asbestos or asbestiform minerals. A detailed percent chemical analysis is required. This information is required to establish a second talc source for our Plant.
The following two samples are being submitted:
a) Pfizer Minerals, Montana Talc - Grade BX #128 b) R. T. Vanderbilt, New York Talc - Grade 200
The above two talcs have been evaluated by Ford Motor Gate #4. Their analysis indicates asbestos contents in both grades. However, the suppliers have cer tified that their products contain no asbestos or asbestiform minerals, detectable when examined by X-ray diffraction. They indicate they comply with OSHA 1910.93A and OSHA Field Directive #74-92.
The disagreement between the suppliers and Gate #4 is on the method of testing. Asbestos fibers cannot be found using the X-ray diffraction method and found using the transmission electron microscope.
A uniform Company test method should be established for asbestos detection to comply with existing OSHA regulations and proposed regulations.
Due to reordering commitments, a 9-15-75 answering date would be desirable.
Safety Engineer
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Inter Office
Personnel end Organization Staff
8007 0504
Mr. W. B. Kozcmchak Safety Engineer
Saline Plant
October 28, 1975
cc R. J. Foster, M.D. F. H. Sayles J. D> Wood
Subject: Determination of "Asbestos Fiber" Content of Bulk Talc
As requested and discussed, we concur there is a need for a uniform procedure for determining "asbestos fibers" in bulk filler material prior to introduction
of questionable material in plant operations. This was precipitated by the needs of the Saline Plant in considering two suppliers of talc and interpreta tion of results.
In discussions with other environmental' health personnel, it is apparent there are differences of opinion on needed procedures and interpretations of any
results. However, it appears that the approach by L. Roslinski, Industrial Toxicologist, is a practical approach based on current knowledge and require
ments.
In summary, questionable bulk material procedure:
1. Obtain written certification from supplier of absence of asbestos and methods utilized.
2. Confirm by X-ray diffraction analysis to determine quantitatively and qualitatively if a "pattern" indicative of asbestos does not exist.
3. If asbestos is indicated from above, microscopy studies would be needed. Scientific Research has such instrumentation.
With respect to the two suppliers, Pfizer Minerals, Montana Talc (Grade BX-128) and R.T. Vanderbilt, Hew York Talc (Grade 200), the following is thus needed by this office.
. Copy of certification and method from suppliers, you indicated has already certified the absence of "asbestos or ashestiform minerals" by X-ray diffraction.
. Copy of any completed Gate 4 laboratory results and analytical methods utilized.
. If confirming X-ray diffraction was not performed, request Gate 4 and/or other
approved laboratory to perform Buch.
1 Based on a review of the above data by this office, a determination can be made pt further laboratory/field evaluation is needed. As you know, some form of documenta
tion is necessary either before or after any government inspection where airborne results indicate excessive "fibers^1 which could be from many sources such as card board shredding.
D. A. Greschaw .................
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Inter Office Mr. Don Greschaw
Personnel end Organization staff September 10, 3975
Subject; Asbestos Sampling and Identification
There appears to be a debate regarding the determination as to whether mineral materials used primarily as "filler" materials are composed of or contain asbestos. The sampling of such materials far determination of compliance to OSHA requirements and/or for the determination of "asbestos" fibers is clouded by the uncertainty of the two questions: Is an observed entity a fiber, and if so, is it an asbestos fiber':
The following recommendations may aid in resolving this problem. 1. Bulk samples of the material(s) in question should be analyzed initially by
x-ray diffraction to determine quantitatively and qualitatively if a "pattern" indicative of asbestos results and what percent, if any, of such a sample constitutes asbestos. If asbestos is indicated or suspected after x-ray diffraction analysis, a bulk sample should be prepared for microscopy studies. Any fibers present should be evaluated and classified (length to width rails, evidence of fibrils, etc.). Although phase-contrast microscopy at around 50Qx is called for by OSHA, it would seem that electron microscopy when available would be a more accurate and ideal tool. If asbestos fibers are identified and confirmed by these two techniques asbestos should be assumed to be in the sample and an industrial hygiene determination must be made to determine the likelihood of OSHA standards being exceeded for any particular operation.
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.2 Breathing zone samples of material!; currently In use and known to be or
contain asbestos should be analyzed by microscopy to determine OSHA comi>l lance. 3 Breathing zone samples of materials of questionable asbestos nature should be
supplemented wit!) x-ray diffraction analysis of bulk samples of the same material.
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