Document oepXn79QBK25MKd2KJ8j2zvjD

MINERALS, I^G^ENTS & METALS DIVISION 2800 AYERS AVENUE. LOS ANGELES. CALIFORNIA 90023 - 213 268-8331 October 8, 1984 Dear Customer: In May of this year, we sent a letter to our California talc customers advising them that OSHA had scheduled a public hearing in Washington, D. C. to hear testimony relating to proposed ^ changes in OSHA's asbestos regulations, including their defini tion of asbestos. Of major concern to talc producers and talc users is the in elusion of tremolite in tne current OSHA definition of asbestos. At these hearings, OSHA was to hear testimony on their proposed change in the definition of "asbestos" which would eliminate nonasbestiform tTemolite from their cuTTent asbestos regulations. As you know, under current OSHA rules, tremolite cleavage fragments which fall within the dimensions specified by OSHA for fibers are regulated under the asbestos rules. Thus, even though the tremolite in California talc is not a true mineral fiher and is not asbestos, OSHA continues to regulate it under the asbestos regulations. Other government agencies, such as the Consumer Products Safety Commission the Mine Safety and Health Administration, the Environmental Protect ion Administration, and the Department ef Education, have long made I the distinction between fibrous and non-fibrous tremolite. OSHA itself has stated that they are the only federal government, agency that regulates non-asbestiform tremolite as asbestos and they anti cipate that they will adopt the proposed new definition. I Because of the large number of proposed rule changes, the hearing 1. I extended from June 19 to July 12. The proposal to change the de finition of asbestos was heard on July 5. Testimony in favor of the proposal was ably presented by representatives from the R. T. Vanderbilt Company and their consulting microscopist. Other in terested parties, including Pfizer, submitted written testimony favoring the proposal. Testimony presented by the National Institute for Occupatioiial Safety and Health (NIDSH) included a recommendation for a new definition for asbestos that was virtually identical to tR^one- RECEIVED OCT 121984 oonn 47 013 proposed by OSHA. As in all such hearings, the public is permitted to offer rebuttal testimony. In the matter of the tremolite issue, such rebuttal was minimal. Altogether, there were 17 major issues covered in these lengthly hearings, many of which were:far more controversial than the tremolite question. Unfortunately, OSHA's process of deliberation and rule making will take time and we do not expect to see final rules pub lished until mid-l?85. Pfizer representatives who attended the hearings on the tremolite issue are confident that it will be favorably resolved and that nonasbestifrom tremolite will no longer be specifically regulated under the OSHA asbestos standard. The current situation within OSHA and other federal and state agencies has resulted in inequitalbe and unfair administration and enforement of the asbestos regulations. Such inconsistent actions have created severe problems for producers and users alike. In some cases, "fiber free" talc or other alternative materials have been pressed into service even though quality may suffer and costs increase. We are looking forward to a logical and reasonable resolution to this prohlem and will do all we can to speed the process. In the meantimef we will continue to produce and sell our high quality California talc products and will endeavor to comply with the maze of regulations tnat affect all of us. We will issue information to our customers on these matters whenever significant events occur. Very truly yours, PFIZER INC, ' David G. Hansen Director of Sales Minerals ab 4? 017