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FILE NAME Talc TALC DATE 1973 Nov 15 DOC TALC461 DOCUMENT DESCRIPTION Memo RE Some Comments on the Use of Talc in Paper aa cetioceoe Manvil e Manvil e Manville W. C. Streib D Center in = R. S. Lamar D Center in rs reeport reeport reeport reeport ince EM bite, pt reeport in reeport ince STL. reeport reeport Date November 15 1973 NOV . NOV j Subject SOME COMMENTOSN THE MIGRATION STUDIES OF USE OF TALC FILLED . IN PAPER WITHA SUMMARY OF PAPER FOR FOOD PACKAGING I. Uses for Talc in the Paper Industry These uses can be divided into several catagories A. B. C. D. Pitch and tramp organic control in pulp mills Pitch and tramp organic control in fine paper and board mills High brightness filler and white pigment in fine paper Titanium dioxide extender in fine paper function In each of these uses talc provides a valuable . For example and in Ai For tram trp amp organic control pulp mills no other material functions as well as talc The talc adsorbs pitch and other oleoresinous selectively are released from the wood during substances as they The talc with its adsorbed pulping and digestion The talc holds pitch remains in the sheet of paper a the pitch in finely dispersed innocuous state When first released these organic substances are colloidal in size If not properly controlled they form agglomerates that deposit out on the machinery and necessitate frequent downs for cleaning methods of control have involved the use of surface Prior to form an emulsion or active agents wetting agents with the pitch that is then washed out sotfuditehse piunlp and into the river or stream Recent British Columbia where they have a strong fishing and tourist industry as well as many large new pulp mills have shown that these surface active agents and emulsified pitch effluents are hightloy cltoosxeic upto their of fish These mills are being required the discharge pitch and toxic emsuylstseimosnsto Tshtiosp greatly aggravates the problem within the unless talc is used for control 000067 - Page 2 W. C. Streib . November 15 1973 , When using talc for pitch control in the pulp mill no surface active agents are needed The talc is added at several points during processing to adsorb the pitch as it is released from the pulp The fine particles of talc with adsorbed pitch remain in the pulp Mills can then be closed up to reduce or eliminate the unscharge of toxic substances into streams and rivers No other white adsorbenits known to possess these unusual surface characteris- tics of talc Normal rates of talc addition in a pulp mill will vary with the severity of the problem These rates range from little as 0.05 percent to 1.5 percent based on the weight of dry pulp For pitch and tramp organic control in fine paper and board mills additional talc is required even though control might have been exercized in the pulping operation As the pulp is beat and further refined in the paper mill additional pitch is released and additional talc is needed for control Also in the manufacture of fine paper rosin sizing in many cases accentuates the pitch problem Rosin size made from pitch is Under certain conditions added back to the paper impropeprH control hard water etc. this rosin size will precipitate recombine with natural pitch and magnify the problem In the paper mill the pitch is generally in more agglomerated form than in the pulp mill The talc is not as effective in adsorbing and controlling these larger agglomerates Therefore heavier dosages are needed Paper mill talc additions for pitch control percent generally range again depending from 0.25 percent to 2.5 on the severity of the problem vary Talc retention in paper will with a number of factors including the freeness or degree of beating of the pulp the type of pulp sulfite or kraft basis weight etc. In most cases talc retention is higher than with other pigments such as clay TiO2 etc. Talc with its adsorbed pitch is mostly retained in the sheet White water problems are reduced through the use of talc in the paper mill Effluents to streams , and rivers are similarly reduced High brightness filler and in the manufacture of fine white paper pigment uses are growing for In talc this CRMC Page3 W. C. Streib November 15 1973 ' II use rather substantial additions up to 20 percent by weight of talc are added to paper to improve brightness opacity smoothness and receptivity to high fidelity color printing With the growing shortage of titanium dioxide this use for talc in this industry is becoming increasingly important Certain commercial grades of ta having very high brightness whiteness and the proper particle size for optimum light scattering efficiency probably perform these combined functions better than any other white pigment D. Another rapidly growing use for talc in the paper industry involves its use as an extenter pigment for titanium dioxide TiO2 tends to form tight agglomerates which act as larger particles thus reducing opacifying efficiency which is a function of both particle size and index of refraction Talc of the proper particle size helps disperse the TiO2 and hold it in the properly dispersed state The talc particles act as spacers between the TiO2 particles be From the above you can see that the use of talc in paper is not only important to M but is also important to the paper industry Talc serves a number of valuable important functions Its restricted use would detrimental to the paper industry and would create additional environmental control problems The Proposed FDA Test Method andSpecificatifoonr Talc . in Food and Food Packaging Materials This would severely restrict and limit the use of talc containing minor amounts of asbestos minerals in food packaging uses paper plastics etc. It is of the greatest importance here that a distinction be made between the use of talc as a direct food additive and its use in food packaging materials Direct food additive uses for talc are of minor even insignificant commercial importance These include the coating and polishing of rice dusting of chewing gum to prevent sticking in the wrapper and the preparation of tablets for pharmaceutical use In these applications where ,,>alc kind of control might is directly ingested perhaps some of be justified if indeeidt is shown that the ingestion containing talc is medically harmful The ques tion here is without any doubt primarily medical 000069 SU it RTE ra ea ss receipe 8 ce nteonm seaee pe . Page 4 ; November 15 1973 In these direct food additive uses talc serves no real it purpose that might not be served by the use of some other agent or by a change in processing methods In this respect is quite different from the valuable uses for talc in food packaging and most specifically paper a In food packaging applications for talc the really important question has been Does the talc stay in the paper under normal use conditions or does it somehow leave the paper and contaminate the food If no or contamination occurs then it is our opinion Mtihgatratiinonthis use taic'in food packaging should not be classified as food additive and no restrictions should be necessary We have for this reason devoted a great deal of time to migration studies This work has been confined to filled paper In filled plastics used for food packaging the talc would be even more tightly lockead nd if no migration occurs in paper it would be logical to assume that migration from plastics would also not occur III A Summary of Migration Studies of Filled Paper for Food Packaging a M Recognizing the great importance andparstiigcnuilfairclayncethetheCelFiDtAe attaches to these studies and Research and Basic Research groups have devoted a great deal of time and expense to this subject It is fair to that it has received our finest efforhot nest have state been completely objective and scientifically honest in all of these evaluations performed at the M Research Center All of those working on the project understood that complete objectivity and scientific honesty were of paramount importance regardless of the outcome regard- less of the findings These migration studies have taken several different forms A. The preparation of filled paper on the pilot machine at Western Michigan University B. An evaluation of these papers at Western Michigan University by means of a pick test a An evaluation of these same papers by Walter C. McCrone C. and Associates using meating wrapping test and freezing procedure to simulate actual use conditions CRMC ERNE Page 5 W. C. Streib November 15 1973 D. The development of a dry scuffing test to study the breakdowonf filled paper An extension of this scuffing practical and real use conditions test into more F. An examinati of various dry packaged foods to determine the actual presence of talc in the paper food container or paper and to resolve the question Does talc in fact migrate from the paper container under actual use conditions and thereby contaminate food Sections A A summary of points A is given by R. P. Carter in his letter of April 20 1973 to Allen T. Spiher Jr. Food and Drug Administration These will not be repeated in detail here but several comments should be restated from page 8 of Carter's letter As Mr. Stewart states in Exhibit E referring to the Even test in which the meat was sandwiched between the thoug thoh ugh in come instances the paper had been completely saturated by the natural juices from the meat tremolite of there was no quantifiable transfer from the paper to the meat In other words McCrone was unable to find any tremolite fibers in the meat following these test procedures therefore concluding that absolutely no migration had taken . place Even more significant was the finding resulting from the meat wrapping tests which found no tremolite migration whatsoever This was a test involving the normal and regul usa e r of food packaging paper by the consuming public As Mr. Stewart has stated in Exhibit E The object of these wrapping tests was the to subjec papt er to folding and handling similar to those which it would undergo normal use and which might result in greater degradation of the paper and hense greater migration of the tremolite than would the sandwich tests described above The test evidenced the total absence of any tremolite . migration from the paper to the food Second commercial food packaging paper always contains a coating of wax or polymers which our test papers did CRMC 0071 Page 6 oe - W. C. Streib November 15 1973 not have and ' migration which would further retard any possible Section D The Dry scuffing Test This test was de sed after talking with some of the people at FDA NaCl would be We all agreed that dry salt a good abrasive material for granular this kind - of evaluation A test method was developed and a number of commercial grades of filled paper evaluated See M Research and Engineering Center Report No. 414-2 September 28 1973 The test can be varied in degree of severity simply by varying the shaking . time In fact the amount of paper scuffed or abraded away was found to be a linear function of time Salt was found to be extremely abrasive under these test conditions and even attacked and frosted the necks of the glass jars used in the test - The results of these simulated use tests showed that . talc and associated tremolite used to fill paper does not selectively migrate from the paper Any of migration that does occur is the result a complete breakdown of the structure of the paper itself Unless the paper fiber structure is destroyed by some scuffing or abrasive action the talc does not otherwise leave this structure SectioEn more An Extension Practical and Real of the scuffing use Conditions Test into ; These results have been described in detail M and - Enginee Engr ini een rig ng Center Report No. 414-6 November 15 1973. Here paper glass jars identi- cal to those used in the simulated scuffing test and were shipped by truck from Denver Colorado to Manville New Jerse bay ck This was meant to simulate actual use and transportation conditions After being received back in Denver the salt was examined petrographically and by means of the transmission electron microscope for paper and fiber talc tremolite chrysotile contamination These results show that under these actual use conditions the paper structure is not destroyed and no contamination with talc tremolite or chrysotile occurs These results also show that the simulated scuffing test is far too severe and does not simulate use conditions The CRMC ares, Spratt tear: a Page 7 _ W. C. Streib November 15 1973 simulatteesdt has performed one valuable function It proves that talc and asbeston minerals migrate only when the paper structure itself is destroyed Those later tests prove prove that this does not normally occur during prolonged transportation Section E An Examination of Various dry Packaged Foods This work is also described in Report No. 414-6 Various dry packaged foods were purchased at a local supermarket These paper food containers were tested petrographically and by ray diftraction to confirm the presence of talc in the paper The various foods packaged in each paper were also examined by the same proceduretso determine of if any detectable amounts talc tremolite or chryso- tile were present due to contamination In these studies the careful and detailed examinations were made using the electron microscope These tests also show that even though talc is presenitn most the paper containers no talc or asbestos minerals were present in the packaged foods We must therefore conclude that migration does not occur under actual conditions with a variety of dry packaged foods Since migration does not occur considered a food additive when talc used should not be in paper _ IV Conclusions Both meat wrapping and dry scuffing tests devised to simulate as closely as possible actual conditions| have shown that talc and asbestos mineral contained in paper does not migrate or contaminate food Migration only occurs when conditions are severe enougtho destroy the paper structure itself condition which we have no reason to believe occurs in actual use situations An examination of a numbeorf dry packaged foods has shown that these packages remain intact and in use and no contamination results If medical evidence indicates that the ingestion of talc and associated asbestos minerals is harmful then FDA restrictions need be applied only to direct food or drug additive uses not to food and drug packaging materials R. S. Lamar rr See on Distribution Reverse Side 000073 L. VanDerbeek A. Martinson J. Solon C. Parker. M. Fenner I. Keelan P. Carter R. Keefe L. Pundsack Speil W. W. C. Streib K. L. Kinder 2 West West West 41 West 4 North West West 2 West D Center D Center D Center D Center Sf File No 259-16.2 Key Words FDA talc asbestos packaging 000074 t