Document zQX8nV3LYG4oGzgvOe9XBwxm

FILE NAME: Goodyear (GY) DATE: 1977 Feb 9 DOC#: GY099 DOCUMENT DESCRIPTION: Letter to GY from Pfizer RE Asbestos in Talc & OSHA Standards '/fa - MINERALS, PIGMENTS G M ETALS ^ '''i^ in fv T p e n t * in c.. aas e. n o s t New y o r k . n y . 10 0 17 >-11 - _ February 9, 1977 GTR mar 7 19T7 Mr. R. H. Gerster I Material Development INDUSTRIAL HYGIENS' Goodyear Tire & Rubber Co. 1144 East Market street Akron,. Ohio 44316. % _,jf v-v . *'"*0,,,,`,, *,tA,rsO MFTA*tlSSo"i'vV,I.SION " -- u. h * v T*'*<>}'/ ear Mr. Gerster: C < .* ^ l/U AhJr* f* . n recent months there has been increasing interest in he subject of talc, particularly with regard to the ature ana extent of its asbestos content. Since you . re one of our many valued talc purchasers, we feel ou should.be aware of important information on this unmeet, he Occupational Safety and Health Administration (OSHA) urrently has m effect an asbestos standard which pre:ribes that employees may be exposed to no more than asbestos fibers per cubic centimeter of air for an -nour tame-weighted average, and to no more than 10 bestos fibers per cubic centimeter at any time. In < Jtober, 1975, OSHA proposed to lower the 8-hour time* aghted limit to 0.5 asbestos fibers per cc. and 5 bestos fibers per cc. for any period not exceeding 15 13 nutes. Very recently it has been reported that the *. tional institute for Occupational Safety And Health has X commended the respective permitted exposure levels be 1 mated even further - to 0.1 asbestos fibers and 0 5 a bestos fibers per cc. I its* October, 1975 proposal, OSHA defines asbestos to i elude cnrysotile, amosite, crocidolite, tremoli'te, a. ?nd actinolite, and every product containing a / of these minerals. OSHA also defines an asbestos f oer as a particulate form of any of these minerals - wi Left IS longer than 5 micrometers, and has a maximum d meter of 5 micrometers and a length to width ratio of a least 3 to 1. -4f,t .C F G Y 0 1 -020239 GIH000589 >* a I +V The reason for the proposed revision of the standard for occupational exposure to asbestos is that asbestos, in its several commercial forms, has been associated with the production of not only asbestosis but a variety of cancers and malignancies. Because of the many unknown factors, including the variability of individual ' response to carcinogens and the absence of data to establish a safe level, OSHA has concluded that employee exposure must be reduced as low as is feasible. OSHA proposes to hold hearings on the entire subject, but until those hearings and subsequent deliberations take place there will continue to be considerable uncertainty. Nevertheless it is prudent for your workers, while usintr m g h t COntain asbestos fibers, to avoid 9 dUS extent possible. Monitoring hould employed to determine dust concen trations under working conditions. Where appropriate, r use o respirators should also K?d "5ker trainin9 programs implemented, if i-h^icwa WiSr tc review fche various provisions *t*ndafd for occupational exposure to asbestos (29 Code of Federal Regulations 1910.1001) and the pro posed amendments which appeared in the October 9, 1975 -ssue of the Federal Register. ince we have no control over the conditions of use of ale products m your plant, it is not possible for us 0 indicate the airborne fiber concentrations which ould possibly result from your use of talc. However, e can provide information on the asbestiforro mineral ontent of the talcs we supply. fizer research has developed .the most accurate and ensitive method available today of analyzing for sbestos and asbestiform minerals in talc. This method, ased on step scanning x-ray diffraction, electron iffraction, and transmission electron microscopy, armits identification of true chrysotilo asbestos at jvels of 0.5% and fibrous amphiboles, such as tremolite, -levels as low as 0.1% in the talc. No other identifi1 ion methods in use today, including optical microscopy id-scanning electron microscopy, are as sensitive and ; direct. GIH000590 --r t z j ' -3- -f-*- Pfizer roiitineiy monitors,its talc production, usinq this ? ,i i i i 2 " t S i t i OSy` BaSe4 "Bn5r " nth" o f evaf uatio n , - California CP talcGj.which you purchase r- - * normally contain between 1% and 5% total . i tremolite with a fiber content of less . " ' *1% bY weight (the practical detection . limit of the analytical method). ' The Montana MP- talcs which you purchase . contain no detectable quantities of .... tremolxte or any of the asbestiform ..... minerals. Thus, you can employ these . MP talcs with full assurance that you .' ' `` are fully in compliance with the OSHA ' asbestos worker exposure standard. nformatinnt^ t+-^ iS your best interests and ours that on,this subject be brought to your attention. f n ^ Si:iyOU*ua11 flnd this letter useful, and that you ill follow the OSHA hearings and other developments as hey occur. We will continue, to monitor these hearings nd try to keep you aware of significant developments, f you have any questionsr please do not hesitate to OAuSiCb 1X8 ** ery truly yours, 1 rp / < r P. Bartels esident B:sp : v,--.r GY01-02024' GIH000591