Document pm7dMZRvyQ3KZ30z3eJXYOo0D
FILE NAME: RT Vanderbilt (RTV)
DATE: 1971 Sept 15
DOC#: RTV156
DOCUMENT DESCRIPTION: Letter from American Conference of Govt Hygienists to Desert Minerals, Inc. RE TLVs for the 2 Different Types of TALC
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Of
GOVERNMENTAL INDUSTRIAL HYGIENISTS
September V j , 1971
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Mr. E. J, Ellsworth, President
D*rt Minerals, Inc.
American Mineral Company
I89I South Coast Highway
.Laguiia Beach, California
92651
Dear Mr, Ellsworth;
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This is in response to your letter of September 8 in which you question whether the tLVs for the two different forms of TALC are now a part of the Rules and Regulations of the Department of Labor, as set forth in the Federal Register, Volume 36, No. 157, August 15, 1971,.
Reference to Table G - 5 -- Minral Dust, page I5IC& of the cited Federal
Register volume, shows TREMOLITE with a standard of 5 million particles per
cubic foot and talc to be 20 mppcf, This is not in conformity with the
recommended values of the TLv.JCornmittee as t forth in the TLVs for 1970,
in whlch-the TLV for fibrous talc is pegged to the Asbestos limit, which .
has now been modified to be 5vfibers^per ml greater than 5 microns in
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length. ;-
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In regard to ;which s fcandard is to be 'used,.w would._s.'>agaar... tha.t_.you, follow the TLVs as provided in the booklet on the TLVs for 1970. We will call ;attention of, the^Dopartraent of Labor to this discrepancy with the request. that they modify this and other discrepancies in conformity with the recom mendations of the!TLV Committee.:
As to the status of the TLV.Committee of the ACGIH, this body has served
for more than a quarter of a century as a purely recommendatory group. With
the passage of the Occupational Health and Safety Act the Department- of
Labor waa
-cced to set standards for Airborne Substances in 'Workplaces
and to rew -*ate their compliance; thus the recommendations of the TLV
Committee, when accepted by the Department of Labor and published in the
Federal Register, now become enforceable standards. How the TLV Committee
has operated is described in the accompanying reprint. "ModusOperand! of
Threshold Limits Committee of ACGIH." I am also enclosing a copy of the TLVe
for I97O for your information^
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Sincerely yours,
bi'i A'i r>j
CRMC-HT-TALC-000106