Document mpRxna3Qk1JzgMbMkr064w3D0

The Cosmetic,Toiletry arid Fragrance Association, Inc. 1133 16th STREET. .W.; WASHINGTON. D,C. 20Q5 -202/331-1770 TELEX 69-2673 Jp.mcr H M 'jriu l Prised-;!tt Norman F, F^tHn. Fh.D. Vtce Prc*; -- Stvf*iet- March 15th, 1976 Mr.. Heins; J. Eiermanri _ Food -and Drug A d m in istra tio n 2 0 0 C S t r e e t , S . W. *. . W a sh in gto n , D,C. 20204 On March 11th, 1976, Mr, Eiermahn^ -- the CTFA Talc Subcommittee, met to discuss the current sta tus 'of talc It was recognized'that a need exists oo rring t o your a t t ^ t L n a -profile of the analyses f o r asbestos form materials in talc used in the U.S. production of co$ai,u.c,, and toiletry products. 5 i v r ^ u a S L i n a e " a t h e fre e a e m ite m e o n t ^ i n a t i t , b , asbestos form materials of cosmetic talc products. Individual companies are .more, than willing to discuss the detailed data with you at your convenience. Norman F. Estrin, Ph.D. Vice President - Science N F E :j j " Attachments PLAINTIFFS EXHIBIT WCD-39 ' The Cosmetic, Toiletry and Fragrance Association, Inc. 1 1 1SH> STREET. N.W.. WASHINGTON. D C. 20005 202/331-1770 TELEX 9-2673 Jam e H M em it NOfllWIf.Eslrin.Pti.O. Wu ArtMN--ScMXCf March 15th, 1976 Hr. Heinz J. Eiermann Food and Drug Administration 200 C Street, S.W. Washington, D.C. 20204 On March 11th, 1976, Mr. Eiermann -- -- the CTFA Talc Subcommittee met to discuss the current sta tus of talc;. It was recognized that a need exists to bring to your attention a profile o f the analyses for asbestos form materials i n talc used in the U .S . production o f cosmetics and toiletry product*. The attached letters demonstrate responsibility of industry in monitoring its talcs. We are certain that the summary will give you assurance as to the freedom from contamination by asbestos form materials of cosmetic talc products. Individual companies are more than willing to discuss the detailed data with you at your convenience. Cordially, Norman F. Estrin, Ph.D. Vice President - Science H F E j JJ Attachments FISHBAINWCD-00000001 jr s \ / ) The Cosmetic,Toiletry and Fragrance Association, Inc. 133 t6 lh STREET, N.W.. WASHINGTON, D.C, 2000S * 202/331-1770 * TELEX 88-2673 A l M i H. Merritt Normen F Eatrtn. PhD. Tti* --$c>*yn MBMORAMDUM TO: FROM: PATE: Norman F . Estrin, Ph.D, Anita s. Curry March 12th, 1976 Jim Jenkins called regarding the letter you have ashed f a ? B r e n t talc analyses. He wishes to inform you as to what they hve been doing: 1. Hr. Clements contacted Or. Langer who gave him the code on the Coty Airspun that was tested. It turns out that this was a July, 1969 produc tion item, 2. In 1970 Coty changed to a completely different talc; since that time the supplier (WC&D) has supplied letters to the effect that they do continuous monitoring of production, even though individual batches sold to Coty may not be individually tested. 3. Coty has had tests run on intermittent batches at the Pfizer Laboratory in Easton, Pennsylvania. These were done by x-ray diffraction and TEM. The results were all negative. Also, in the last week they have tested 1974 and 1975 lots. These too were negative. ASCijj A von PRODUCTS, m e. s u m * H HEW Y O R K roi DI March 12, 1976 Or. Norman Estrin CTFA 1133 15th Street. N.W. Washington, D.C. 20005 Dear Norm: This 1s to confirm our Indication yesterday of our w illingness to disclose to you and/or the Food and Drug Administration the results of our analyses of a ll lo ts of talc we have used In our products during the past three years. During 1973 a ll of our talc receipts were sampled, and aliquots were sent to HcCrone Associates for X-ray diffraction analyses with the specific request for confirmation of the presence or absence of chrysotile. We did not specify other amphiboles at that time because our ea rlier data indicated that they were present only rarely in the talcs'we examined. A total of 170 samoles of talcs used in our products were examined by HcCrone during that year. The X-ray diffraction patterns are on f ile at McCrone and can be reviewed by authorized people. The results were negative. Since February, 1974, we have analyzed about 250 samples of talc receipts in-house by DTA fo r chrysotile and IR for tremolite. As mentioned above, we fe lt that IR for tremolite was adequate for screening purposes, because Of the rareness of other amphiboles. The data from these analyses can be made available, also, i f needed. The results were negative. Please le t us know i f there I s anything else we can do to help resolve the question of asbestos 1n cosmetic talc. Yours truly. JJT:m c Ce: C. S. Rowland G. A. Sprott R. C. Reardon Central File r FISH B A IN W C D -0 0 0 0 0 00 2 Chesebroughfonds lac. M I E A R C H LABORATORIES TRUMBULL INDUSTRIAL PARK, TRUMBULL. CONNECTICUT 06811 PHONI-B03 *77-7100 March 1 2 , 1976 Dr. Norman Estrin Cosmetic, Toiletry &. Fragrance Association 1133 - 15th Street, N.W. ' Washington, D.C. 20005 Dear Norman: For some years, Chesebrough-Pond's Inc. has been concerned about reports' that some talcs might contain asbestos as a naturally-occurring contaminant. As you know, vie have cooperated with CTFA, and through CTFA with the FDA in developing suitable and practical methodology to resolve the very complex and difficult task of identifying asbestiform fibers in talc. We have also worked closely with responsible talc suppliers to identify high quality sources of talc. By the beginning of 1973, we felt that practical methodology for the purpose was applicable. Since then, we have utilized the techniques described in the attachment to monitor incoming cosmetic talcs of three types that we have been using. These three are from three different geographical areas. I have reviewed the results of these analyses on the incoming lotB of these talcs used In recent production of cosmetic and toiletry products In the United States. The last 8A reports, covering a three-year period, are, without exception, negative for ehrysotile and negative for fibrous amphlboles. If it can be useful, we would be pleased to discuss these data with scientists at the Food and Drug Administration. MB/bm end. Murray Berdick " Director of Regulatory Affairs nJ CD4 (j. * O.n; t / `if " 3 0 20; rcuections ana snowing no iino la toc 14.GA chlorite region la necessary and suinclcnt evidence (or the presence of chrysotilo. A Une at 14.GA la addition to, and of tho proper Intensity relative to,the T.3A and 3.G5A lines Identifies chlorite rather than chrysotilo. W h e n tha x-ray evidence la equivocal, optical crystallography m a y bo Used to confirm chrysotilo. Positive Identification will then be based nn the known morphological and optical properties of chrysolile. The normal form of chrysotilo la a parallel bundle of long fibers, each a hollow cylinder only about 220A In diameter. It la roonoclioie with y ranging from 1.545 -- 1 .5 5 6 , p from 1,539 -- 1.559 and or from 1.532 -- 1.550. The sign of elongation Is positive since y Iles nearly parallel to tho length of the needles. The birefringence Is about 0.015 hence a 5 p m thick hundlo will how a retardation of 75 a m (gray). The birefringence of a 2 p m thick bundle of . chrysotilo libers would be barely detectable even with a.first order red plats. Dispersion staining Is a sensitive and spcifi method (or long-fiber chrysotilo, la IhcCargillc high dispersion liquid nZj5 * 1.550 most chrysotilo fiber bundles show >. colors la the blue-magenta region with the central stop lor the vibration direction parallel to the length and In the blue for vibration directions . crosswise. Unfortunately, to a preparation of quartz particles about 10% will tie In position showing the same two colors for vibration directions 90' apart. These can usually be Identified as quartz by morphology or by tho fact that the sample contains m a n y other particles of similar morphology but showing blue central stop colors In all positions of stage rotation. All chrysolite fiber bundled are constrained by shape to lying flat,hence always showing both blue (crosswise) and blue-magenta (parallel to the length) for central stop colors, Trcmollte -- Necessary and sufficient evidence for the presence of trcmolltc is an X-ray powder diffraction pattern with linos at 8,4 Q.1A, 3.27 O.OSA, 3.03 * 0.03A And 2.92 O.OSA. (Note: zinc and magnesium stcarato m a y Interfere at 8.4A and calcltc H3.03A.) . t I When the x-ray evidence Is equivocal, optical crystallography m ay be used to verify the presence of trcmolitc. Positive evidence will then bo based on accepted morphological and optical properties of Lrcmotitc, The c o m m o n form is monocllnic rods elongated nearly parallel toy (about X.G3) but with oblique extinction of 10-21' for crystals lying on the 010 face. The optic axial plane Is 01<lhcnce o (about 1.G0) Is also chown on tho 010 view. The view showing p (about 1.G1S) and y' (about l.G3`) shows parallel extinction, Tho optic axial angle Is about 80" with a negative sign and weak dispersion, v > r. Polarization colors are moderate and approximately 100 n m (gray) for a 10 p m thick rod In all crosswise orientations, 200 n m (yellow) for a 30 p m thick crystal. Characteristic dispersion staining colors are observed la Cargilic high disper sion liquid 1.COS: about 430 n m 1$ X0 for y,blue-violet with the annular stop and yellow with the central slop; about 490 nm for f i , bluo-grccn (annular stop) and golden magenta (central stop); and about GOOn m for o . yellow-orange (annular stop) and blue (central *?). . ' . * -f i FISH BAI NWCD-00000003 r if COLGATE-PALMOLIVE COMPANY 909 River Road PiBeataway N.J. 08854 March 15, 1976 Norman F. Estrin, Ph.D. Vice President The Cosmetic, Toiletry and Fragrance Association, Inc. 1133-15th Street, N.W. Washington, D.C. 20005 Dear Dr. Estrin: Attached please find a summary of Analytical Data on 42 Talc Samples (representing 20 raw materials and 17 finished products) covering the period 1971 to present and examined by various tech niques by the Colgate-Palmolive Research and Development Analytical Department and McCrone Associates. Asbestos minerals were not detected in any of these samples, with the exception of insignificant trace amounts found by micro scopic methods in three samples from 1971-1972, which is believed due to laboratory contamination. Other methodologies indicate the absence of any asbestos. The results of these analyses indicate to us that tale products produced by the Colgate-Palmolive Company since 1972 are free of asbestos minerals when subjected to the most sophisticated methodology available. We have ascertained by inspection of the package and analyses of the product that the sample of Colgate-Palmolive's Cashmere Bouquet examined by Dr. Langer of Mt. Sinai Hospital was manufactured prior to 1970. The Bauer and Black Talc reported by Dr. Langer has not been manufactured since the end of World War II. This company was acquired by Colgate-Palmolive approximately three years ago. Very truly yours. CHC:nip Attachments Christopher H. Costello, Ph.D. Administrator Regulatory Affairs March 12, 1976 To: From: Dr. C. H. C o ste llo J , P. Simko, J r. Subject: Analytical Data on Talc Samples 1972-Present Since late 1972 when the possibility of asbestos in talc was first raised, RED Analytical has been engaged in re-analyzing U.S. talc raw material and finished products for asbestos minerals by the most sophisticated methodology available at that time. Analyses were made on a spot-check basis. Techniques used inhouse are .x-ray diffraction followed by optical and scanning electron microscopy, if necessary. X-ray is the basic screening tool and examination by microscopy is made when positive responses occur. Additional tests on random samples were made by trans mission electron microscopy and selected area electron diffraction by an outside consulting firm. Forty-two samples ffrom 20 raw materials and from 17 finished products!, covering the period 1971 to the present, have been examined by these various techniques. Asbestos minerals were not detected in any of these with the exception of trace amounts in J samples from 1971-2. These levels arc considered generally below the normal background levels encountered when this microscopic methodology is employed. It is believed that these tTace amounts are due to laboratory contamination. A detailed tabulation is attached. JPS/ed A tt. FISH BAI NWCD-00000004 .> */ Ho, of Semples Enmilnad for Asbestos Minerals 1972-76 Method T3J-SAZD Sample dates (yrs.) Rav Talc *5 1S71-72 Cashmere Boiiouet ##7 1972-76 X-ray* plus microscopy (optical - SlDi) Sample dates (yrs,) 12 1971-76 u 1972-76 m Sample dates (yrs.) 6 1972 1 1972 *1 senile 1971 rax talc contained 10-100 prpnu chrysctile *1 sample 1971 raw talc contained 1-10 ppm. chrysotile These levels represent possible background con- . tamination **1 satple 19T2 Cashmere Bouquet talc contained < 5 ppo. chrysotile Bo Rmphitole detected in any of these. J?S/ed 3- 12-76 -t 'CTFA V5H W VSH 1LXAl'4B VAFI39( 1427) (1-01S216A0T2TPD 03/12/76 1424 TVX CIMI S3 LSA 00 LOSA CA m s THE COSMETIC. TOILETRY AND FRa GABNCE ASSOCIATION, IN. 1133 FIFTEENTH STREET, M. V . ' WASHINGTON, 0. C. 0005 MARCH 12, 1576 ITU NORMAN ESTRIN VICE PRESIDENT - SCIENCE EEAR DR. ESTRIN 1 AS A RESULT OF DISCUSSIONS I HAVE HAD WITH LOUIS MURINO CONCERNINS THE MARCH 11, 1976 CTFA TALC SUD-COKHITTSE MEETING. I VOULD LIKE TO STATE THAT US HAVE A CONTINUING PROGRAM Itl EXISTENCE TO TEST OUR MONTANA GRADES OF TALCS THAT ARE B E I N G `OFFERED TO THE COSMETIC INDUSTRY. PRIOR CORRESPONDENCE BETWEEN OURSELVES AND MR. GEORGE V. SAKCLAND, CHAIRMAN OF THE TALC SUB-COMMITTEE, HAS ESTABLISHED THAT VE HAVE TESTED 2,39 SAMPLES FROM OUR CORE DRILLING PROGRAM AND BY X-RAY DIFFRACTION PATTERNS HAVE NO SEEN ANY DETECTABLE LEVELS OF CHRYSCTILD AMD TREVOLITE. OUR X-RAY DIFFRACTION TECHNIQUES ARE IE ACCORDANCE VITH THE CTFA J-4-1 METHOD QUTH11ED FOR USE WIDER CTFA SPECIFICATIONS FOR COSMETIC TALC. SINCE CUR ORIGINAL INVESTIGATIOH AND SUBMISSION (AUGUST 6, 1975). VE HAVE EVALUATED AN ADDITIONAL FIFTY MONAtAil PRODUCTION SAMPLES VITH THE SAME EXCELLENT RESULTS. VE CONTINUE TO USE X-RAY DIFFRACTION TECHNIQUES AS OUTLINED BY CTFA J-4-1. VE SHALL BE HAPPTY TO CONTINUE TO COOPERATE VITH CTFA IN OUR TESTING PROGRAM. VERY TRULY YOURS. FISH BAI NWCD-00000005 . CYPRUS INDUSTRIAL MINERALS COMPANY 555 SOUTH FLOUES STREET LOS ANGELES, CALIFORNIA 900T1 TELEPHONE (213) 489-3700 END WJNN H- T. MULRYAN PRESIDENT 323PEST CfA VSH TALC INVESTIGATIONS Our investigation of talc dates back to November 1972, when the following samples, were analyzed by McCroite Associates and found to be free of any asbestos content: Music Talc Aphrodlsia Women's .Talc Aphcodiaia Men's Talc Flambeau Talc Vcodhue Men's Talc Straw Nat Talc Tigress Talc Brut Talc Kiku Talc Woodhue Women's Talc Xanadu i'alc Zlzanie Talc 9-26-72 9-26-72 9-26-72 9-26-72 9-26-72 9-26-72 9-26-72 9-26-72 9-26-72 9-26-72 9-26-72 9-26-72 In November 1975, the following samples were again analyzed by MeCrone Associates and found to be free of any asbestos content: Brut Tale Brut Tale Kiku Tale Kiku Tale Kiku Tale Xanadu Tale 3.4.75 20.6.75 11.11.75 24.4.75 3.7.75 20.6.75 On March 9, 1976, JlcCrone Assoc, purchased in a Chicago store, one 4 oz. container of Brut Talc, Lot #2585, which was produced on September 15, 1975. This sample was also found to be free of any asbestos content. FfiBEHGE DIVISION 1$ R A ILR O A D AVENUE. RIDGEFIELD, NEW JE R S E Y 0?65 7 |201) 94&-SAOO __ + M B V PRODUCTS COMPANY mi on NEW BRUNSWICK. N J, 0 6 9 0 3 March IS, 1976 Dr, Norman F, Estrin Vice President - Science Cosmetic, Toiletries, and Fragrance Association 1133 15th Street, N.lr. Washington, D.C, 20005 lie: Examination for Asbestos In Talc Dear Dr. Estrin: The talc which is used by Johnson Si Johnson is solely derived from its own mine in Vermont, where the ore is mined selectively and then beneficiated by the process of flotatiop. Shipments of this highly purified talc are routinely examined by our own laboratory to verify the absence of asbestos minerals. Historically, Johnson Sc Johnson has always been concerned about the mineralogicai integrity of its talcs and even its earliest speci fications have required the examination for acicular particulates. When it was erroneously reported in 1971 that our powder contained asbestos, we sponsored a scientific seminar of inineralogical and analytical experts for the FDA to prove that our talc is not con taminated with asbestos. At that time numerous samples were analyzed by experienced consultants such as McCrone Associates, Colorado School of Hines, Professor F. D. Pooley (of the University College, Cardiff), Professor G. Brown (of Princeton), and Professor M. Buerger (of H.I.T,). These examinations included X-ray diffrac tion analysis, differential thermal analysis, and transmission electron microscopy. During the period December 1972 to October 1973, 93 lots were indi vidually sampled and examined by X-ray diffractometry for the presence of asbestos minerals. No amphiboles or serpentine minerals were detected in any sample. FISH BAINWCD-00000006 */ Dr. N. F. Estrin C.T.F.A. - 2- Uarch 15, 1976 Beginning in October 1973, differential thermal analysis was added to our specified requirement. Both, differential thermal analysis and X-ray diffractometry were instituted for the routine examination of sequential lots, A further 100 lots have since been examined, applying both methods to each sample. Again, no amphlbole or ser pentine minerals have been detected. I would like to advise that we are continuing to employ differential thermal analysis and X-ray diffractometry in the examination of sequential lots for the detection of amphibole and serpentine min erals. It should be pointed out that we also maintain a worldwide monitoring of talcs used by our Johnson & Johnson affiliates, employing these same techniques. Finally, let me add that periodically, we also submit sub-samples for Transmission Electron Microscope examination and these have always verified the absence of asbestiform minerals. It is our understanding that you would wish to submit this information to the FDA. Please regard this letter as non-confideatisi. Sincerely yours, ( . George Dee Director of Applied Research GL/mm jjofwiDiioiJufiinon ABY PRODUCTS COMPANY NEW BRUNSW ICK. N J. OSSOS March 14, 1976 EXAMINATION OF AMERICAN & BRITISH TALCUM POWDER __________PRODUCTS BY DR, F. D, POOLEV___________ A total of .38 samples originating from the laboratory of the Department of Environmental Health, Ut. Sinai Hospital were ex amined by Dr. F. D. Pooley in an effort to substantiate results reported by staff of the Mt. Sinai Hospital. American Talcum Products A total of 20 samples (corresponding to 19 American products) were subjected to examination by X-ray and electron microscope. Dr. Pooley verified that five products contained several percent, by weight, of fibrous anthophyllite asbestos. This is in contrast to the Mt. Sinai report that five of the products contained 8 to 20% asbestos and that another five of the products contained less than 5% asbestos. British Talcum Products Similarly, 18 products were examined by Dr. Pooley. He verified one product as containing anthophyllite. On the other hand, the Mt. Sinai laboratory reported finding tremolite in three products and anthophyllite in a fourth product. They further reported that tre molite or anthophyllite were "Indicated at or near the lower limit of detectability" in five other samples. It was also reported that "serpentine phase was found in two, and possibly in several other samples," but "electron microscopic examination would be required to resolve the possiblity of the existence of chrysotile". However, Dr. Pooley's subsequent examination with the transmission electron microscope has refuted the existence of any chrysotile. It should be emphasized that these American products were sampled in 1973 and arc not necessarily representative of current American talcum production. FISH BAINWCD-00000007 > w aiter c. me crone associates, inc. C O N S U L T S . ULTflAMICRQANALYSIS M ICROSCOPY SMALL PARTICLE PROBLEM S SOUO-STATC CHEMISTRY 12 March 1976 D r. Norman Estrln Cosmetics Toiletries and Fragrances Association 1133 15th Street, N.W, Washington, D.C. 20005 Dear ftr. Eatrto: This letter will amplify our recent conversation on talc analyses for asbestos. Since 1971, Walter C. McCrone Associates, Inc., has worked with several producers and users of talc, the majority of them involved with cosmetic grades of talc. During this period we have analyzed several hundred talc samples for the presence of asbestiform minerals. The methodologies used have been principally X-ray diffraction and light microscopy using dispersion staining, although extensive transmission electron microscopy examinations have been carried out for some companies. Subject to the approval of our clients, we are prepared to make available to the FDA.through CTFA.the results of these analyses. We also have available retained samples for most of the analyses. Verbal agreement to release this data has been already given by clients accounting for probably SQ-90% of the samples; the others have not yet been approached. It would, however, be improper for us to comment on specific samples until such time as written approval is received from our clients, together with identification of those materials used in cosmetic production. The latter point is stressed because several of our anafyses represent the results of raw material assessments which some companies initiated and might include talc ore bodies which are unacceptable for cosmetic applica tions. I do not think, however, that I would be violating any company confidences if 1were to comment on the asbestos in talc situation as wo saw It over the last 5 years. I think our view can be summarized quite briefly as follows. M t o SOUTH M ICHIGAN AVENUE CHICAGO. ILLINOIS 60516 - 3 12/64J-7100 - C A K E CHEMlCRONE f* U March 1976 Df Norman Estrln Cosmetics Toiletries and Fragrances Association Pag Two Some cosmetic talcs prior to about mid-1972 to early 1973 were found to contain amphiboles -- principally of the Tremotite-Anthophyllite lype at levels, determined by X-ray diffraction, of the order of 5-15% by weight. Microscopical examination of these' talcs, however, Indicated that the bulk of this amphibole content (>90%) was non-fibrous, even applying the 3:1 aspect ratio criterion for a fiber, and hence not asbestos. No chrysotlle asbestos was found in these tak a. Since 1973 none of the talcs which we hare examined and which bare been identified to us as production materials have shown any detectable levels of either chrysotlle or asbestlform amphibole. Yours sincerely, lan M. Stewart Manager* Electron Optics Group Companies contacted and granting verbal approval to release information include : Avon Products, Inc. Bristol-Myers Products Chesetrough-Ponds, Inc. Colgate-Palmolive, Inc. Faberge, Inc Johnson G Johnson Windsor Minerais, Inc. Whittaker, Clark G Daniels, Inc. F ISH B A IN W C D -00000008 S v a t L J Q D l i liiftftl, executive ornes 9<3 P A R K A V E N U E . N E W Y O R K . N Y. 1 0 0 1 9 March 12, 1976 C orporat< Director of Quality M U COOCUt cm U- innoMit mi Mit Dr. Korin an Estrin Vice President - Science The Cosmetic, Toiletry & Fragrance 1133 Fifteenth Street N.W, Washington, D.C. 20005 Association, Inc. Dear Borman: Sterling Drug Inc. initiated testing in November 1971 of the talc used in "ZBT Baby Powder" for the presence of a"beftti form minerals. Since that time we have had tested by x-ray diffraction analysis about one-third of the lots received. In all instances the results indicated there was no detectable asbestiform minerals present in these samples: We also have had assurance from our supplier, Whittaker, Clark & Daniels, Inc., that they routinely monitor the shipments of talc supplied us for the presence of asbestiform minerals and have found no detectable amounts. We are willing to meet with FDA at some future date to present the detailed results of this testing. As I told you the code on the package of "ZBT Baby Powder" tested by the Mount Sinai Hospital group was coded and was produced in June 1970. We are of the opinion that the testing we and our suppliers have performed assures us that the "ZBT Baby Powder" produced since late 1971 does not contain asbestiform minerals. Sincerely, RAM:mm ; Roderick A. Mundy - ft r-:.' -<f- : V ' CABLE -ILEINAD' i i t O l l M l 4 1 DO 'lOOO COOL1DOE ETNEET * SOUTH PLAINFIELD. n j 0 7 0 8 0 M a rc h i t , 176 O r. Norman E strin CTFA H eadquarters 1t33 Fifteenth S tre e t,N .W . W ashington, D .C . 20005 D ear D r. E strin: 1171 In A ugust/a te s t p ro g ra m w as in stitu ted by o u r com pany to in su re cu sto m rs using o u r co sm etic g rad e ta lc s that they a re Free of fib ro u s asb esto s . It w as d eterm in ed th a t the u se of X -ra y d iffraction would be the m o st p ractical m ethod of detecting the possible p resence of asbestos and thus a ssu re us of a reliable and w orkable m eans of p e rio d ic m onitoring o u r ta lc s . In th e event th at the re s u lts of th is testing showed possible positive re su lts , the sam ple was fu rth er subjected to o p tic a l m ic r o s c o p y . In a ll cases the te s tin g of ou r p ro d u c ts w as perform ed by outside independent lab o rato ries. We have also used other te st m ethods such as Differential T herm al A nalysis and Optical M icroscopy, however X -ray diffraction gave us the best reproducable resu lts. O ur file contains re p o rts on v arious grades of cosm etic talc from a re a s in A labam a, N orth C aro lin a, M ontana, Italy, South K orea and V erm ont. T h ese re p o rts w ere b ased on ap p ro x im ately 74 ground o re sa m p le s analyzed over a period of four y e a rs all of which show non-detectable am ounts of fibrous asbestos form m in erals. Additionally, sep arate tests m ade during th is p erio d by m any of o u r customr-i-s suppcrteci anti substantiated our test re su lts. A ll o f th e te s tin g f o r th e p r e s e n c e of a s b e s to s form m in e r a ls In ta lc h as been p erfo rm ed by "o u tsid e e x p e rts" including th e Following: W alter C, M cCrone A sso ciates, Chicago, Illinois E r n e s t F u llo m A s s o c ia te s , S ch en ectsd y r, Mow Y ork E . S . L ab o rato ries, M ar.lton. New Je rsey Prof* C harles R, M anning, North Carolina U niversity P ro f. S ey m o u r Z . L ew in, New Y o rk U n iv ersity D r. Gordon Brow n, P rinceton U niversity continued .............. ^ . . . IMPORTERS * MANlirAC11IHFHS . TM'ORW IINERALS, COLORS. PIG M EN TS FISH BAI NWCD-00000009 / W De Bell a R ichardson, E nfield, Connecticut Columbia S cientific Industries, A ustin, Texas W e a r e w illin g to su b m it th is in fo rm a tio n to th e c o m m itte e In d e ta il to help substantiate th eir claim s. V ery truly ycrurs, W HITTAKER,CLARK a DANIELS,IN C. F re d erick F* Roesch Executive V ice P resident F F R /d m