Asbestos in Talc Breakout Session B November 28, 2018 

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1 COSMETIC SYMPOSIUM 

2 "Asbestos in Talc" 

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 TRANSCRIPT OF CONCURRENT BREAKOUT SESSION B 

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8 MEASUREMENT CRITERIA FOR IDENTIFICATION AND FIBER COUNTING 

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11 Moderators: Arthur M. Langer

 - and -

12 Anne G. Wylie 

13 Location: The Hotel at the University of Maryland

 7777 Baltimore Avenue 

14 College Park, Maryland 20740 

15 Time: 1:42 P.M. 

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COLLEGE PARK, MARYLAND 

Wednesday, November 28, 2018, 1:42 P.M. 

MR. LANGER: This is the session to establish 

concurrence on morphological criteria for identification 

of mineral fibers in the analysis of cosmetics 

containing talc. Use of reference standards will also 

be discussed. 

You heard many presentations this morning. 

You heard Van Gosen talk about various deposits and 

geological characteristics and criteria. The 

interesting part of his presentation is that the 

Yellowstone talc has no amphibole. The Yellowstone talc 

may have been used in cosmetics. All of the other talcs 

that he described, whether from Death Valley or Texas or 

New York State, all contain amphiboles. They've never 

been used -- not most deposits, Allamore, Texas, or 

Gouverneur in New York State or the Talc Bill which lies 

to the east of the Gouverneur deposit, these all contain 

fibers, fragments predominantly in Gouverneur. But 

they've never been used as a cosmetic source. 

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1 Interestingly I think Dr. Van Gosen added that 

2 he was not in a position to recommend this Yellowstone 

3 talc. That's mountain. Yellowstone, Beaverhead is a 

4 very pure talc. It has been used in the industrial 

5 setting but only in paper making, because it contains no 

6 grit. It has no amphibole materials. 

7 Dr. Meeker suggested that the federal asbestos 

8 standard is incomplete. He's right. There are other 

9 asbestos amphibole materials that have been identified 

10 and reported on in the literature, whether it's 

11 winchite-asbestos in Allamore or whether it's richterite 

12 and winchite in Libby, Montana, or the fluoro-edenite, 

13 which is implicated in mesothelioma in Italy, or the 

14 bentonite asbestos, another amphibole, implicated in the 

15 Ural mountain mesotheliomas. 

16 MS. WYLIE: Do you have a sample of that? 

17 MR. LANGER: Say again? 

18 MS. WYLIE: Do you have a sample of that? 

19 MR. LANGER: No, I do not. No. That's a very 

20 good question. 

21 MS. WYLIE: I would add it to my collection. 

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MR. LANGER: Speaking of collections, Dr. Nolan, 

who is here in attendance, has all of the UICC standards 

in 5-pound or 10-pound bags, the original materials. We 

took that out of Sinai when we left. But we also had 

about 80 canisters of talcum products. The first 

20-some-odd were reported years back. But we have those 

samples, and many are interested in reanalyzing the 

pallets. We understand why. 

The -- as an example, the litigations today 

with Johnson & Johnson really has nothing to do with 

science. It has to do with their corporate 

communications amongst themselves, which are damning, 

meaning that they generated the enemies lists and 

they -- some people they relied on, others not. 

So the -- Johnson & Johnson, they took it on 

the chin with Jackie Fox in St. Louis and the cases out 

in Los Angeles as well in which the rewards were just 

huge. 

Rutstein described the methods. He did not 

endorse any one specifically, other than you see a lot 

more with an analytical electron microscope. And, of 

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course, Dr. Harper stressed statistical analysis of the 

data and the number of fibers required to characterize 

the material. 

These are important issues today, meaning that 

the limit of detection -- what is it actually telling 

you? Is the limit of detection of the mineral content 

important? Or are we dealing with -- are we dealing 

with the issue of risk analysis? Meaning that, if we --

if we looked at risk analysis, we're looking at a 

certain material contaminated or associated with mineral 

fiber. Let's assume anthophyllite or tremolite 

asbestos. What is the risk? 

If your analysis indicates that you're dealing 

with .01 percent level of fiber and someone is using 

this for 15 minutes a day and the exposure level is .15 

per cc, which is the current standard, the protective 

level, the question is, if you use this every day of the 

year, 365, if you were to use this for 75 years, what 

would the risk be? 

Well, I've done the calculation. And this is 

for chrysotile in talc, because we know something about 

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1 chrysotile. There are plenty of studies in which the 

2 epidemio- the mortality has been determined at certain 

3 levels of exposure. We calculate the cumulative 

4 exposures, and we determine what the risks are. That's 

5 using the linear no-threshold model, which means, for 

6 every increment of exposure, there's an increment of 

7 risk. Now, whether this is actually happening is 

8 another story. But it is the most protective model, 

9 lineal through zero. 

10 Yes? 

11 SPEAKER: Does that model --

12 MR. LANGER: You have to tell us your name. 

13 SPEAKER: John Field, Ottawa, Canada. 

14 Does that model account for -- and I realize 

15 that it accounts for the amount you're exposed to, but 

16 does it also account for the potential for it to 

17 accumulate in your system? 

18 MR. LANGER: No, of course not. It's only for 

19 inhalation, and the models that we use are inhalation 

20 and mesothelioma. 

21 SPEAKER: No. But, I mean, is the mechanism it 

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basically gets in and chokes out the --

MR. LANGER: Well, there's all kinds of 

mechanisms. Ann briefly went into this. She's 

indicated the importance of widths. That controls 

aerosol stability, inhalation potential, penetration 

through the pulmonary architecture, lodging in the 

alveolar spaces. And if you have a very narrow width 

fiber, it penetrates from the alveolar membrane out 

into, first, the visceral pleura and then the parietal 

pleura, where the mesotheliomas arrive. 

So all of these are -- these are important 

factors. These are --

SPEAKER: But I guess is what I'm saying is 

that -- I get that part. I'm just wondering, though, 

why can the accumulation aspect -- I mean, it is 

relevant. 

MR. LANGER: Certainly. 

SPEAKER: Potentially could smaller -- if a whole 

bunch of smaller doses could essentially lead to a big 

dose? 

MR. LANGER: I understand that. There are certain 

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fibers in which the material accumulates, and there are 

others where the material does not accumulate or it 

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breaks down. Chrysotile tends to break down. 

SPEAKER: Okay. 

MR. LANGER: This is the early stuff that 

Chris Fogman did in 1970s. 

SPEAKER: Okay. 

MR. LANGER: But it's been demonstrated by other 

techniques in other circumstances chrysotile is -- I 

guess mineralogists will call it a labile material. It 

is not stable in the biological environment. 

Now, there are different components in the 

lung so that the stability of chrysotile varies in terms 

of where it is deposited. In some regions, it's very 

difficult for it to get out and be mobilized. 

Yes? 

SPEAKER: This is Frank Ehrenfeld.

I want to follow up on that a little bit. 

think you -- I mean, you actually must have calculated 

it on the basis of a cumulative risk over time, because 

clearly someone who is exposed for one year is going to 

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have less risk than someone who is exposed for five 

years or ten years at the concentration involved. 

MR. LANGER: Yeah. We have --

SPEAKER: So we --

MR. LANGER: Sorry. 

We calculate cumulative exposure. That would 

be some value of fibers for whatever, fibers per cc 

multiplied by the number of years that the individual is 

exposed at that level. 

SPEAKER: Right. That was your question; right? 

SPEAKER: It does kind of address it. 

MR. LANGER: Yes, we have a paper in press. 

Langer, Nolan Journal of Regulatory Toxicology and 

Pharmacology, the role of fiber type and cumulative 

exposure in imparting mesothelioma risk, so both of 

those factors. It's based on three mortality studies 

out of Mount Sinai. 

This is -- I'm sorry. 

SPEAKER: This is Steve Wolfgang. 

I think that .15 fiber per cc, that was 

derived for an occupational education observation; 

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1 right? 

2 MS. WYLIE: Yes. 

3 SPEAKER: 45 years' working life, eight hours a 

4 day, it was based originally on epidemiology of asbestos 

5 of textile mills and that sort of thing. 

6 MS. WYLIE: Crocidolite primarily? 

7 SPEAKER: Right. 

8 MS. WYLIE: Is that correct? Crocidolite 

9 exposures primarily? 

10 SPEAKER: I'm not sure. 

11 MR. LANGER: Which study is that that you're --

12 MS. WYLIE: I think it's crocidolite primarily. 

13 MR. LANGER: Which study is that? 

14 MS. WYLIE: Regarding the risk. 

15 MR. LANGER: Is that Peto's study at Rochdale? 

16 SPEAKER: I can't give you a citation. 

17 MR. LANGER: Okay. Yes? 

18 SPEAKER: I --

19 MR. LANGER: You have to tell us your name. 

20 SPEAKER: My name is Kapal Dewan, FDA. 

21 Kapal Dewan. 

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MR. LANGER: That's okay for me, but he's the 

reporter. 

SPEAKER: My question is to be talking about the 

topical exposure, and is there a chance it's also toxic 

to that? 

MR. LANGER: Well, this is a hot topic, isn't it? 

Topical exposure? 

SPEAKER: Yes. 

MR. LANGER: Talc dusting the perineum and various 

cancer in women. I don't have the foggiest feel for how 

those particles end where they're supposed to end. I 

don't know. 

SPEAKER: Okay. 

MS. WYLIE: May I comment? 

I served on the IR panel that produced the 

document on bottle powder; so I listened to the -- I was 

there for two weeks, and I listened. And we never had a 

discussion of female anatomy, and so the issue of why 

and how it gets there is really, in my memory, I don't 

think that that was approached. It was only the use. 

And that there was some reference to some -- I thought 

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it was a gorilla that they held upside down -- I don't 

know -- some bizarre thing. 

So I think that it's -- the issue of mechanism 

of how the talc actually gets to the ovary is unknown. 

SPEAKER: In relation to that exposure -- any 

other exposure over the skin, because skin in different 

types of the body could be different. People use it 

under the arms and many areas. Do you have any 

information if that's been done with talc? 

MR. LANGER: Unless it came out of a canister. 

MS. WYLIE: I don't think so. It's -- you know, 

70 micrometers -- and I think you can get -- I believe 

you can get titanium dioxide of sunscreen through your 

skin. 

SPEAKER: Yes. 

MS. WYLIE: Is that not correct? 

No particles are on the order of a micron; so 

I do think there is -- I think the vast majority of talc 

is much too large to enter the body. 

SPEAKER: I am just stating it the same way. How 

do particles get -- if the size is smaller, then that 

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could be a possibility. So I'm just looking to opening 

that discussion, that, depending upon its size and other 

characteristics, like you said, then it's not the 

criteria. But other criteria come into play. That's 

what my question is. Is there any other characteristics 

that should be --

MR. LANGER: I wish I could be more helpful. I 

have no idea. 

SPEAKER: Okay. Thank you. 

SPEAKER: John Field again. 

I guess -- and I know there's been some 

controversy around this as well, but I know there were 

excised tissues that did -- they find talc in them. 

MS. WYLIE: I believe that's correct. 

SPEAKER: Yes. 

SPEAKER: Yeah. So I guess you can only argue how 

those others get there, because if that is true, then --

MS. WYLIE: It doesn't mean it came up through the 

vagina. 

SPEAKER: No. But --

MS. WYLIE: No, we do not know how it got there. 

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MR. LANGER: This is a very interesting point. 

You raise a fascinating point. Every presentation this 

morning did not focus on talc. It focused on other 

minerals. What about talc? Talc was found in ovarian 

tissues. This is Henderson's study in the early 1970s. 

What does it mean? Good point. 

SPEAKER: The other thing -- and I'm going to play 

the ignorant Canadian card here. I've been hearing a 

lot of people mention the J & J lawsuits. And, I mean, 

we're certainly not privy to any of these details. 

Is the mechanism by which ovarian cancer is 

occurring -- is that really being sort of mapped out to 

asbestos impurities within the talc? 

MR. LANGER: Well, asbestos seems like a likely 

candidate, if it's true asbestos fiber. All of the 

epidemiological data, all of the exposure data, all of 

the risk analyses, risk assessments based on fiber, 

asbestos fiber. Talc? 

I mean, we know a great deal about asbestos. 

We know a great deal about silica. We know a great 

deal -- the talc -- the early talc studies are all talc 

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studies of workers who worked in tremolite talc 

deposits. The problem was that the exposures were never 

properly characterized. 

You heard that this morning. People talked 

about asbestos, whatever, without defining the nature of 

the fiber. 

MS. WYLIE: Yes. There's also that same IARC

document, and it very clearly stated that talc is not a 

carcinogen. It very clearly states --

SPEAKER: Could it not -- I mean, I know some of 

the mechanisms that were proposed is, you know, just 

your body can't clear it and, you know, eventually it 

creates some sort of a --

MS. WYLIE: There's no evidence of inflammation, I 

understand. And I don't know why the argument would 

hold to clay also, then. You know, I mean, you know, we 

don't have any mechanism to know. And talc, like I say, 

IARC says "not a carcinogen." 

MR. LANGER: You know, Nolan is --

MS. WYLIE: -- for lung cancer -- lung cancer. 

SPEAKER: Yeah. 

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MR. LANGER: Unless you smoke cigarettes. 

MS. WYLIE: Right. 

MR. LANGER: Nolan is engaged in a project now. 

And those fibers have been, I suppose, put under to the 

umbrella of asbestos minerals. That's a long time ago. 

MS. WYLIE: That they're asbestiform? 

MR. LANGER: Yeah. Well, they're asbestiform, 

using it as a generic kind of morphological sense. 

SPEAKER: So the question I have is is the data 

for the morphological criteria for identification? 

MR. LANGER: Oh, yes. We're going to get to that 

right now. 

SPEAKER: What I would like to know and understand 

that, this morning, when we had this discussion and 

people were talking about the nexus, so it's -- what I 

got from that is how the sample is prepared depends --

and what method -- that's the key part. It sounds like 

it's not prepared correctly and doesn't matter what 

method you're going to use. You may get from different 

labs data showing different results. 

MR. LANGER: Sure. 

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SPEAKER: So what morphological criteria do you 

think should be considered for identification? 

MR. LANGER: Well, we're going to get into the 

nature of this session here. I'm glad you asked that. 

This is what the goal of this session is supposed to be: 

to establish concurrence on morphological criteria for 

identification of mineral fibers in the analysis of 

cosmetics containing talc. 

Morphology implies the visual method of 

analysis. What are the criteria for analysis by light 

microscopy, by electron microscopy? Are these criteria 

the same? We have a series of questions. And at the 

end of the discussion, we'll vote as to whether we agree 

or disagree with it, from your own experience, from what 

you've heard this morning, and whatever we contribute to 

the discussion. 

The first question is the following: Do we 

agree that a 5-micron length particle with an aspect 

ratio of 3 to 1 or greater, as determined by visual 

analysis -- you can choose your own microscope -- may be 

defined as asbestos but may also be inclusive of 

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cleavage fragments, talc fibers, and other minerals that 

occasionally fail and yield fibrous particles? 

Now, the definition is the federal definition 

of asbestos. The federal definition of asbestos is one 

of ease of microscopic analysis by light microscopy of 

some sample. It's a standard of convenience that 

separates nonfibrous particles, dust particles, from 

fibers. 

So do you agree that that could be very useful 

in defining and determining that this material is 

asbestos? Do you agree with that? 

SPEAKER: I do in a sense, but my concern would be 

is it a mineral fiber or not? 

MR. LANGER: You mean there may be false 

positives? 

SPEAKER: Well, it could be something else --

MR. LANGER: Sure. 

SPEAKER: -- other than a mineral fiber. We're 

here to talk about mineral fibers. 

MR. LANGER: You're right. Now you have 

reservations; so you may not agree. 

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MS. WYLIE: I'll disagree. If it can't be inhaled 

and it can't be broken out into small fibers, I don't 

think it's sufficient. 

SPEAKER: I would disagree with that, because you 

can inhale particles up to 100 micrometers, as the 

inhalable dust criteria. It doesn't go to the alveolar 

region and probably getting into the mesothelium, which 

was described by Dr. Mossman. But it's inhalable and 

can end up in the lung. 

And I think the last question is --

MS. WYLIE: Isn't the aerodynamic diameter 3? 

SPEAKER: Pardon? 

MS. WYLIE: Isn't the aerodynamic diameter of 

getting to the lung 3? 

SPEAKER: The reason the World Health 

Organization, in their asbestos rule or method, has an 

upper limit of 3 micrometers diameter is the aerodynamic 

diameter of a fiber is to the width and, at a density of 

that of asbestos, a 3-micron width is approximately 

equivalent to a 10-micrometer --

MS. WYLIE: Micronic sphere, yes. 

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SPEAKER: So it's essentially a size that will get 

below the bronchial entry. 

SPEAKER: Into the alveolar? 

SPEAKER: Right. So 3 micro- --

MS. WYLIE: So a 3 width, it would have to be 

narrower than 3 microns? 

SPEAKER: Right. 

MS. WYLIE: But that's not what this says. 

MR. LANGER: Well, I think that we should vote on 

this. Do we agree that a greater than 5-micron length 

particle with an aspect ratio of, and so on and so 

forth, 3 to 1, as determined by some visual analysis may 

be defined as asbestos but may also include -- it should 

be two questions. Can you define asbestos on the basis 

of the federal standard? If you know you're dealing 

with asbestos in a situation, that's fine. If you're 

looking at an isolated particle in whatever, tissue, 

air, whatever, you can't. 

MS. WYLIE: The original methodology that's 

incorporated into the regulatory policy was written by 

Liddell. I think that might be right. And in the 

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analysis and where he talks about this, he says an 

absence of evidence to the contrary. The particles that 

meet these definitions should be included as asbestos. 

But if you have evidence to the contrary, then that --

he recognizes that's the case. So --

SPEAKER: I've got to believe that we're actually 

taking ourselves down a wrong track here. You know, the 

federal fiber definition, if you want to call it that, 

is a definition for an index of respirable fibers on air 

sample that could cause disease; right? And those 

words -- "index" and "air sample" -- are very important. 

And I just don't understand why we would want to look at 

bulk materials and apply a definition -- a size 

definition that is applicable to a risk assessment of 

air samples. It just doesn't make sense to me. 

MR. LANGER: But what you're saying is the 

following: What you're saying is that, depending on 

your sample, by this definition, it fails. I agree with 

that. 

In the United States, we have different 

characteristics for assaying the environment. If you 

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were to work for the EPA and you were doing indoor 

pollution studies, you wouldn't use a phase contrast 

microscope. You would use a transmission electron 

microscope. 

SPEAKER: Well, yeah. I mean, there's a question 

about that too. Because the EPA uses a transmission 

electron microscope but uses a risk assessment based on 

PCM fiber counts, and I have a lot of issues with that 

position too. 

MR. LANGER: That's very interesting. You're 

absolutely right. 

SPEAKER: Yeah. 

MR. LANGER: Because the original studies -- we're 

talking about the Mickelson update that was embraced by 

the EPA in 1986 and revised --

SPEAKER: I am of the belief that, if the EPA 

really wants to use transmission electron microscopy to 

assess the risks of asbestos inhalation, they should do 

it based on a risk assessment that uses TEM data. 

MR. LANGER: I agree, but they're not going to do 

it, of course. 

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SPEAKER: They don't have it. 

MR. LANGER: It needs -- it takes an act of 

Congress to change that standard. 

MS. WYLIE: But they don't have any asbestos 

exposures to assess it against. 

MR. LANGER: Well, not in the United States. 

Maybe elsewhere, yeah. 

SPEAKER: But I don't see any reason at all why 

the FDA has to go down the same route as the EPA and 

just repeat, you know, these issues of the past. We --

you know, the FDA has the opportunity here, because it's 

dealing with a specific material, talc, as a consumer 

product to, you know, initiate whatever standard works 

best for the FDA. 

MR. LANGER: I agree with you. I agree. 

SPEAKER: And also to add to what Martin has said, 

for us, talc is an ingredient, but asbestos is a 

contaminant in the ingredient. It is not the case like 

for EPA products where asbestos may be added 

intentionally to make a solid material. 

MR. LANGER: Whatever, yeah. 

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SPEAKER: In the case of consumer products, such 

as the samples, it adds it as a contaminant, not as an 

intentional additive. 

MR. LANGER: Yeah. 

SPEAKER: Steve Wolfgang from FDA. 

I think it's more akin to a naturally 

occurring asbestos in the environment than it would be 

to an asbestos added. 

MR. LANGER: You're saying asbestos occurring in 

some outcropping contributing to the environment that's 

not an asbestos pit --

SPEAKER: Right. 

MR. LANGER: -- or a mine? 

SPEAKER: Exactly. 

MR. LANGER: It's just present. 

SPEAKER: Well, perhaps we should go one step 

even, you know, closer to the kernel of this, and that 

is to define asbestos. And since there never really has 

been a geological definition of asbestos that's, you 

know, accepted by everybody, the commercial and legal 

areas have corrupted the word and turned it into 

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something for their purpose. 

My personal definition of asbestos is anything 

that was commercially mined and sold as asbestos, no 

more and no less than that, which means that all of 

those asbestos outcrops that people refer to as 

naturally occurring asbestos would not, in my 

definition, be asbestos. We would call them what they 

are, nanofibrillar amphiboles or chrysotile or whatever. 

And maybe we should just stop using the word 

"asbestos" here and start talking about contamination of 

talc by nanofibrillar amphiboles. 

SPEAKER: I agree. The -- well, if you look at 

the goals of the three sessions, we say mineral fibers. 

We don't say asbestos. 

MR. LANGER: Yeah. And I took issue with that 

from the very start. Are we going to analyze mineral 

fibers? Which talc? Structural integrals? Talc fiber? 

Talc fiber that twists? That's easily distinguished 

from an amphibole. All you need is a transmission 

electron microscope and be able to do electron 

diffraction. 

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MS. WYLIE: Just need the PLM. It's a no-brainer. 

SPEAKER: So let me ask you this, then, just so 

this will maybe clarify. It's just to establish 

concurrence on morphological criteria or --

MR. LANGER: That is what our assignment is. 

SPEAKER: Well, should --

MR. LANGER: Morphological criteria. 

SPEAKER: -- should we propose including something 

else? 

MR. LANGER: I was given the assignment. It's 

morphological criteria. If you don't think it's a way 

to go, I agree with you. There are other diagnostics 

that are far more specific, definitive, if you like. 

SPEAKER: Well, all I'm thinking is what I heard 

this from the geologist. 

MR. LANGER: What did you hear that you liked or 

didn't like? 

SPEAKER: What you would expect to find in a talc 

mine and what you need to be looking for. I thought 

that was one of the first questions that was supposed to 

be answered. 

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MR. LANGER: What should be --

SPEAKER: Types of minerals of concern in talc, 

bullet point No. 1. 

MR. LANGER: But that's the whole point. Those 

talcs would never have been used as cosmetic ingredients 

or pharmaceutical grade talcs that are used in the 

surgical procedures. 

SPEAKER: But didn't you say that there was mixing 

sometimes? 

MR. LANGER: Oh, yes. Absolutely. The cosmetic 

grade talcs consist of mixtures. People select talcs 

from different deposits, blend these talcs. And talcs 

have a certain color. They allow it to be incorporated 

with a fragrance of some kind, and the talc permits the 

fragrance to be listed. 

SPEAKER: I -- just speaking from our perspective 

in Canada, what would be really incredibly useful for us 

would be just like what we were talking a second ago, if 

you could define what, sort of, the normal background 

level was or how would you define like a normal 

background. And then --

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MR. LANGER: You mean a background level for talc? 

SPEAKER: Sorry. No, no, no. For asbestos. 

MR. LANGER: Oh. 

MS. WYLIE: Asbestos or amphibole? 

SPEAKER: Well, this is what I am getting at. 

From our perspective it's naturally occurring, and so 

you can't have a level of zero. Like, that's -- but 

unless we can sort of define what a normal background 

is -- and I know that's kind of a loaded -- then it 

makes it very difficult for us to sort of act on things, 

because there are two parts of this. There are trace 

levels, and there's also the people who put it in 

intentionally. And they're two very different... 

MR. LANGER: All of the early studies with 

asbestos in the environment focused on chrysotile. I 

mean, it was a rationale thing to do. 95 percent of the 

fibers consumed in the United States was chrysotile; so 

people looked to chrysotile. Not only that, you 

actually find some in the ambient air. You can look for 

a long time and not see amphiboles. 

MS. WYLIE: So I think we should focus more 

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future, going from here forward. I don't think we 

should talk about what happened 30 years ago, because, 

you know, we don't know. And it's the FDA's job right 

now, going forward, if talc is sold under cosmetic talc, 

how do they know it's asbestos-free? Isn't that the 

basic issue going forward? 

MR. LANGER: Of course. 

MS. WYLIE: Correct, going forward. 

And so most of the deposits that Bradley then 

goes and shows down in California are not put in 

cosmetics, have never, never would be, and are not put 

there. 

I don't think there is a background asbestos 

level in some talc at all. There's no asbestos at all. 

There might be a background tremolite level but not an 

asbestos level. Asbestos occurs in very distinctive 

geologic environments. You don't have to have it. It's 

not distributed like magnetite as a trace element or 

something, one fiber here and one fiber someplace else. 

But I don't think there's -- you can talk about 

background levels. 

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SPEAKER: Except in California. 

MS. WYLIE: Yeah. California is weird. 

SPEAKER: But I think the global market -- we 

cannot limit ourselves to the discussion to your point 

to make it very clear. I think you've got to know about 

the mine. But I think the global market -- it would be 

helpful for us to have a study that, yes, maybe the mine 

maybe not be using the ones for consumer products, but 

what about if the products are coming from all of the 

different parts of the world? Then how do we --

SPEAKER: It's incredibly difficult to figure out 

the distribute chain and know where things came from. 

MS. WYLIE: Yeah. So we need a standard. We need 

a dimensional standard so we can do analysis. 

SPEAKER: That's exactly right. 

MS. WYLIE: And I -- and, you know, toward that 

end and to move that direction along, I think the 

questions are do we focus only on 5 micrometers? Should 

we start there? So should our analysis focus only on 

particles that are longer than 5 micrometers? 

That's what we have the occupation standard 

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for. That's what the risk assessment is based on. I'm 

not telling you that those necessarily are the only 

particles that may cause disease. But do we start with 

5 micrometers for these purposes? 

All right. And if we have 5-micrometer 

particles, then I think we have to ask are they thin? 

Do you have a population less than .2 or equal to .2, 

less than .2? If the answer is yes, then I think you 

have a fail. 

I don't care how it's called, whether it was 

asbestos or cleavage. If it's a reproducible and it's 

in there, then you have a reason to say "I have some" --

and I don't know how much, but at least you have some 

and you have a positive ID for the presence of asbestos. 

SPEAKER: Going back to the 5 microns and provide 

why 5 microns was chosen? 

MS. WYLIE: Well, that was the occupation standard 

put in play when this membrane filter method was 

produced. This all goes back to the assessment of 

occupation exposure to known asbestos. It has nothing 

to do with anything else related. 

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SPEAKER: If you read Henry Waltman's occupational 

hygiene review from -- I think it's 1970 or 1971 -- he 

does touch on the choice of 5 microns at the time. And 

it was based on results of something that was done in 

Germany for several years prior. And I think they were 

lobbying for 10 microns, actually, as a safe cutoff, and 

they selected 5 to provide a safety factor. 

MS. WYLIE: Also, reproducibility. There are 

studies that showed that if you started counting by 

phase contrast microscopy -- and I know there's a couple 

of references I can give on those -- that they found 

they had nonreproducible results. And it wasn't until 

they began counting 5 micrometers and above that they 

got reproducible data. 

SPEAKER: Because there were fewer particles at 

10 microns longer than there are 5. 

MS. WYLIE: Right. 

SPEAKER: But, I mean, I see a laboratory taking 

measurements and recording lengths and widths. 

MS. WYLIE: But you're not -- if you don't have a 

5-micrometer particle in there, even the question is do 

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Page 33 

1 you have a problem? 

2 SPEAKER: Well, as you pointed out, the number 

3 sub-5-micron particles far exceed others? 

4 MS. WYLIE: Yes. 

5 SPEAKER: But these are related, and that's part 

6 of the problem of trying to tease out a roll of actual 

7 dimensions -- is that every time you have an exposure to 

8 one particular size B, you have a correlated exposure 

9 with another size B. 

10 MS. WYLIE: They're indexed. 

11 SPEAKER: So you're saying that may act as a 

12 surrogate to everything that's there. 

13 MS. WYLIE: Well, just for analytical purposes. 

14 This is analysis. It's just a question. Do we focus 

15 only on 5-micrometer particles and above? 

16 SPEAKER: Does it shorten the analysis time? 

17 MS. WYLIE: Well, yeah. Sure. Easily. 

18 SPEAKER: Once you get -- by the way, under the 

19 optical microscope, once you get below 5 micrometers, it 

20 becomes harder to determine an aspect ratio of 3 to 1. 

21 And when you're down around 2 micrometers under the 

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optical microscope, it's very difficult to say whether 

it's 3 to 1. 

MR. LANGER: What happened with the standards 

changing from the millions of particles per cubic foot 

to fibers per cc, and that is you went from a dust 

standard to a fiber standard, which had limited 

biological data to support it. But, nevertheless, that 

occurred, and that occurred in the UK with the membrane 

filter technique being brought over by Howard Ayers and 

his colleagues at NIOSH. That's in the 1960s. 

MS. WYLIE: Remember, you're not trying to 

establish an analytical protocol that counts every fiber 

that's dangerous or that ascends to prove -- determine 

what's hazardous and what's not. 

What you're looking for are hallmarks of the 

presence of asbestos. 

So if we start -- also, very, very short 

particles, 1 and 2 micrometers, are very hard to 

discriminate one from the other. You didn't really know 

their source. 

So if you start with 5-micrometer particles, 

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they will be present if you have asbestos. It has high 

test strength. Long fibers persevere. 5 micrometers is 

not very long, really. So if you start from there and 

say "Okay. Let's only analyze those particles, and then 

let's look for widths that conform to the most abundant 

widths of asbestos." And if you have them, then I think 

you would have the answer to the question. 

SPEAKER: What do we do with a 4-micron long 

asbestos structure that's .1 microns in diameter? 

MS. WYLIE: They'll count it. But --

SPEAKER: Like, people come to me saying "Can you 

test my product and certify that it's asbestos-free?" I 

can't do that. You know, there's other indications. 

SPEAKER: You cannot certify something as being 

asbestos-free. That's ridiculous. 

SPEAKER: Of course. But they're asking --

SPEAKER: If there's asbestos in the talc and you 

find one 4-micron long fiber, then if there's any more 

asbestos, it has a high chance of being longer than 4 

microns. 

MS. WYLIE: Right. 

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SPEAKER: And so at some point you will see a 

5-micron fiber, and you say "Yes, there is asbestos." 

If you give me a sample of talc and the only 

thing I find in it is one 4-micron fiber, I'm not going 

to be very worried about it. 

SPEAKER: Right. 

SPEAKER: I mean, statistically, that has an equal 

chance of being zero. 

SPEAKER: Correct. I agree. 

SPEAKER: Even though you've seen it, which is 

counterintuitive --

SPEAKER: Well, we also have to determine -- I 

guess that's the other session -- how much do you look 

at? How much of an area do you look at? 

MR. LANGER: Well, you're talking about a limit of 

detection --

SPEAKER: Absolutely. 

MR. LANGER: -- and the level of fiber in some 

sample. But they can't ask you to prove the negative. 

SPEAKER: Oh, I agree. 

SPEAKER: There is discussion, though, of actually 

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coming up with a number. And I've just been doing this 

as back-of-the-envelope calculations. I know I 

shouldn't do this. I'm not a risk assessor. I should 

stick to my own wheelhouse. 

But, you know, with -- as Marty pointed out 

the word "asbestos" is fraught with, you know, emotional 

connotation, because we all got taught that one fiber 

can be yielded and all of the rest, and yet that is a 

myth that's been exploded fairly recently with the 

publication of the high risk assessment for amphibole, 

because there they have set a reference fiber 

concentration at which you can be exposed every day for 

a 70-year lifetime without the risk of getting a lung 

cancer endpoint. 

And by "lung cancer endpoint," they mean 

pleural thickening. And every physiologist I've ever 

spoken to said you're not going to get mesothelioma 

without pleural thickening. 

So if this is a limit value that stops you 

from getting pleural thickening -- so the fact that it's 

a limited value that's going to stop you from getting 

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mesothelioma. Right? 

And I've done the calculation. It's .00-

MS. WYLIE: Whatever. 

SPEAKER: It's 9 times to the minus-5 per cc. And 

if you do that calculation --

MR. LANGER: Is that over eight hours? 

SPEAKER: No. 24 hours a day. 

MR. LANGER: 24 hours a day? 

SPEAKER: 365 days a year for a 70-year lifetime, 

that ends up being a fiber berth of almost 6 million 

fibers over a lifetime. And it ends up being around 

4,000 fibers per gram of lung tissue. 

And, you know, by the areas of publication in 

2012, the lowest fibers of a mesothelioma patient that 

he had in that was 110,000 fibers per gram. So it's 

three times less than that. 

So, I -- you know, and -- and there is a 

point. It's in the literature that populations of 

people that were exposed to asbestos that did not get 

mesothelioma have less fibers in their lungs than the 

people that do get mesothelioma. 

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MS. WYLIE: How many fibers per gram of lung was 

that? 

SPEAKER: Look, check my calculations. 

MS. WYLIE: No, I'm not going to check it. Did 

you say 100,000? 

SPEAKER: At 2012, the lowest in the set of 

mesothelioma patients he looked at was 110,000. 

MS. WYLIE: 110,000. Okay. 

SPEAKER: Correct. And I believe that there is a 

cutoff where it's assumed that, below that level, it's 

not very likely that you're going to get mesothelioma, 

and above a certain level, it's likely you are. 

And, you know, so these are calculations that 

can be done. And then you come backtrack -- and then 

you can look at a normal use of talcum powder, what the 

normal concentration of dust in the air would be, the 

time that you're using it for, the number of times you 

use it over your lifetime, and then you can backtrack to 

what would be the fiber concentration you would allow to 

stay below this level. Okay? 

And then you can work out -- that's your 

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target now. That's what you want to make sure you don't 

exceed in any talcum product that you produce. So now 

you've got a number. 

And I'm telling you that the analytical people 

among us, that's what -- we don't want to go around 

trying to certify that this is asbestos-free, because we 

know we can't. But we can tell you it's below a number, 

if you tell us what number you want and here's a way to 

do it. 

But it -- you know, you're -- you know, you're 

going to get those adverts, you know, like for the 

drinking water, where the guy says "Would you like to 

try one of these tap waters? They all contain less than 

the amount of -- the allowable amount of lead according 

to the EPA." 

"Would you like one of these talcum powders? 

They all contain less asbestos than" -- yeah. I'm 

sorry. 

But, you know, the fact is people have to get 

used to this. Zero does not exist. 

MR. LANGER: I would like to get one vote in. 

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SPEAKER: I have one question of morphological 

function to the analysis of the counting fibers and the 

mentions and all of that on aerosolized talc, which you 

hear should be aerosolized under the microscope. 

MR. LANGER: That's the way it should be done. 

Absolutely right. 

SPEAKER: There's information about maybe the use 

of fluidized bed asbestos segregator, which was designed 

as a way of determining releasable asbestos fibers from 

things like soils, you know, as a risk assessment 

technique. And they've tried it. And, unfortunately, 

it just doesn't work because the talc in cosmetic 

products is so fine that it blows up in the air too. 

And so all it does is clog the filters up with the talc. 

SPEAKER: But it's interesting. Because if we use 

the airflows that Jan put together, we'd have to make 

some adjustments based on that. 

SPEAKER: And I did point out, but I also pointed 

out that the original FDAS from Idaho National 

Engineering Lab was the flow rates and such were formed 

by calculations on movement, flow, and so on and so. 

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What they ended up with was an iteration of 

that based on actual practical experience. And my guess 

is, if you want to change it, you're probably going to 

have to go through probably several iterations again 

until you get it right. 

So it's going to be problem. 

SPEAKER: So, actually, our panel published the 

Tuesday Morning articles from Goodyear from issue 40 --

I mean PS 40, issue 4 and the PS 43 issue 4, and we kind 

of looked at those. We proposed the Weinstein 

concentration method there. 

And so -- yeah. But, anyway, I just came 

here -- you know, one thing I agree with is to spend --

for our conversation, to have the comparison standard to 

make sure -- as to the talc, to improve the asbestos 

method, our panel is working on that. And keep an eye 

open for our forum. And also our announcement indicates 

we need more discussion and will support any feedback. 

SPEAKER: Okay. Just so everybody understands 

where we are at this point, when we wrote the letter, it 

was at the point which we realized that the X-ray 

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diffraction was basically the no-go test. 

MR. LANGER: That sounds pretty good. A good 

X-ray diffraction, that's excellent. 

SPEAKER: The X-ray diffraction, it was our 

understanding that it was half a percent, roughly, of 

the detection. 

MR. LANGER: It depends on the mineral and the 

matrix. You're right. 

MS. WYLIE: Talc and -- chrysotile in talc. 

SPEAKER: The back-of-the-envelope calculation, 

how many fibers that corresponded to, caused some 

concern. 

MR. LANGER: I've never done the calculation. I 

have no idea. 

MS. WYLIE: Well, there's a lot of data on X-ray 

and tremolite in talc. I thought it was at .1 percent. 

SPEAKER: We believe it could be more than .1 

percent if done by an expert who knows how to run it. 

MS. WYLIE: Okay. 

SPEAKER: The problem is very few laboratories and 

pharmaceuticals have expertise in this area. 

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1 MS. WYLIE: And it doesn't tell you that it's 

2 asbestos either. 

3 SPEAKER: No, it doesn't. 

4 MR. LANGER: It depends on the preparation and 

5 the --

6 SPEAKER: Well, microscopy doesn't specify the 

7 element and it doesn't specify diffraction, none of 

8 that. 

9 MS. WYLIE: You need that. If you put talc in an 

10 oil that matches the indices of diffraction of talc, you 

11 can find any impurity in there like that. I mean, the 

12 slides I showed you, that was all talc in the 

13 background. You couldn't see it, because it had the 

14 same index as the oil I had. It makes it invisible. 

15 But not tremolite, not amphibole, not 

16 carbonate, not any of it. You can see them in these 

17 very, very clearly. So PLM has got to be part of it. 

18 Right. 

19 SPEAKER: So by bringing us back to the question 

20 of criteria, I guess the question here becomes what 

21 should be the accepted criteria? What should be the 

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criteria for counting something when it's observed, say, 

by PLM, TEM, or whatever, and what is the decision 

point? How is the decision made as to whether that 

material is suitable or not suitable for use? 

MR. LANGER: I think you heard this morning the 

plea that there are multiple instruments available and 

that each one provides a different set of information. 

Would you use X-ray diffraction to determine the habit 

of a mineral? No, of course not. 

SPEAKER: Right. 

MR. LANGER: Form is not its strength. 

Concentration? Well you can do well. 

If you want to do polarized light microscopy 

with large particles, it's fine. It's perfect, an 

excellent instrument. 

If you're going to have a population of fibers 

or mineral -- elongated mineral particles that align at 

2/10 of a micron and lower, then you need an analytical 

electron microscope. 

So each problem has its own set of 

requirements -- instrumental requirements. 

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SPEAKER: Right. 

MR. LANGER: And so if you've got a client who is 

interested in asbestos in whatever, you can begin with a 

light microscopy technique, polarized light microscopy. 

Immersion oil is also proper; you can do that. 

You could go to X-ray diffraction, get a feel 

for how much is present of some mineral. At a 10th of a 

micron, there is a limited amount of detection based on 

the matrix effects. And then eventually if you detect 

something and it might be an asbestos fiber, then you go 

to analytical TEM. 

Of course, no one discussed this morning the 

time and the cost of doing analyses by analytical 

transmission electron microscopy. Because you can have 

an analyst spend a half a day analyzing a single 

particle. 

MS. WYLIE: Well, right now, they're just simply 

counting 3 to 1 -- actually, they're 5-mic- --

particles that are longer than .5 micrometers and have a 

5 to 1 aspect ratio. And it just has no bearing. It 

has nothing to do with identifying asbestos. 

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And they -- well, the data that I showed you, 

to me, don't show that it's in there. That's just one 

data set. I didn't gather it. I don't know. Maybe 

there's other data out there that I don't have. 

But, you know, you have to have something with 

analysis of TEM that you can be critical of. You can't 

just say "3 to 1, longer than 5, and I find that, by 

analysis of TEM, I have asbestos" because you're back 

doing exactly what -- you need to show that they have 

these particles in there, in which case, I wouldn't 

worry about it. I would just say the talc failed. 

MR. LANGER: Consider the Russians and the Ural 

deposits of chrysotile. They think fiber count 

something of a waste of time, and a lot of time. They 

do it gravimetrically. They weigh the dust. So there's 

an index. Our dust is running 6 percent chrysotile, and 

they extrapolate from there and use a gravimetric assay 

and a gravimetric health standard, whatever. 

MS. WYLIE: If you use heavy liquids and separate 

the talc and you look at the residue by PLM, you will 

see that there's asbestos in there or not. 

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SPEAKER: So what if you say you're using a fluid 

with this idea of a filter and then weighing the filter 

afterwards of some period of time? 

SPEAKER: Well, I sample --

SPEAKER: No. First off, we're not there with the 

FDA as to technique yet. I mean, if you felt that the 

FDA test technique had value and Julie is not convinced 

that it does, then it would still require some time and 

effort to evaluate it and get it right. 

SPEAKER: I've heard it's very reproducible, 

though. 

SPEAKER: Hmm? 

SPEAKER: I heard it very reproducible. 

SPEAKER: It is. And it can go down to very low 

levels. But the issue is, when you try to use it for 

quantitative purposes, is that there is a recovery. You 

don't get a hundred percent of the material in there. 

And, in fact, for the soils that we looked at, the soils 

that they looked at at Libby and the soils I looked for 

erionite, the recovery was running around 1 percent. 

SPEAKER: But for the purpose of --

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SPEAKER: No. It's because you don't -- you don't 

flush all of the particles out of the fluidized bed. 

MR. LANGER: I'd like to ask you a question. 

SPEAKER: Uh-huh. 

MR. LANGER: I'd like to ask how much iron did you 

find in your erionite sample? 

SPEAKER: The -- very little. And there's a 

problem with EDS analysis of anything that's less than 

1 percent of the total mass. The errors with EDS are 

huge at that level, and most people don't recognize it. 

And they still pump out numbers to three significant 

figures. It's just ridiculous. 

MR. LANGER: Well, you need a handheld calculator. 

SPEAKER: It's very easy, also, to have iron 

amination in your EDS system, because iron is 

everywhere. 

We actually ran a microprobe, because that 

ended up being better, and then we calibrated our TEM 

EDS. We realized you have to be very, very careful. 

It's very -- you know, it's an electron beam, for 

heaven's sake. And zeolite is -- you heat it --

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MR. LANGER: Easily. 

SPEAKER: I've burned holes right through zeolite 

particles. 

MR. LANGER: Yeah. Easily. 

SPEAKER: So it's not difficult. So at the end of 

the day, being quantitative, particularly with iron, is 

very difficult. 

Probably a more useful assay is maybe some 

bole, but to do that, you need a pure sample. The 

problem is, even the purest erionite you have is 

probably only about 85 percent pure erionite. 

MR. LANGER: Yeah. Mixed with the mordenite 

and --

SPEAKER: And what else have you got in there? 

Probably containing iron, you know. So essentially I 

just don't think our analytical capabilities are there. 

MR. LANGER: Well, the bulk chemistry show a trace 

to nil of iron. I know that many of the 

experimentalists focus on iron as a free radical and 

engage in a number of reactions to the behavior cycles 

and they like iron. 

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SPEAKER: I know --

MR. LANGER: But there are many noniron-containing 

materials that are biologically active, and erionite is 

the most mesothelioma-genic material known. 

SPEAKER: Well, I'm not certain about that. 

MS. WYLIE: From our end. 

SPEAKER: I'm not certain. 

MR. LANGER: What is it that concerns you, that 

blunts your --

SPEAKER: We have -- we published a paper last 

year. The first author is Yan Marlan, if you want to 

look it up. And it's a comparative cycle toxicity of 

asbestos in erionite. And it appears that erionite 

induces its toxic effect through an entirely different 

mechanism than does asbestos. 

MR. LANGER: Absolutely. Iron is not the sine qua 

non. There are many other mechanisms. You're right. 

SPEAKER: Right. And it appears that this may be 

related to a genetic disposition of one particular group 

of people lacking the defense mechanism that all of the 

rest of us have. 

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MS. WYLIE: I have in my lab a drawer of erionite, 

and I think I probably have 20 samples of erionite. And 

the morphology is all different, and so I don't think 

you can make generalizations about erionite. I just 

don't. 

MR. LANGER: They have different chemistries? 

MS. WYLIE: They have different chemistries, 

different morphology. It's some that may be probably 

harmless. 

SPEAKER: And, in fact, the chemistry of said 

erionite also varies tremendously from particle to 

particle based on the local ionic gradients and 

potentials where they crystallized. And so we found 

that you have to analyze dozens of particles even to get 

an average. And for the exchangeable cations, we found 

ranges from, you know, plus or minus 100 percent. 

SPEAKER: Aren't we digressing from our goal? 

MR. LANGER: Yes, we are digressing. 

SPEAKER: I'm sorry. 

MR. LANGER: But that's all the fun. Certainly. 

SPEAKER: It is fine. 

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MR. LANGER: All right. Well, we'll never get 

past question 1. 

Question 2. We'll all agree that particle 

morphology alone may in some cases exaggerate asbestos 

by fiber count, false positives. Sure. And if you 

don't find it, it may be a false negative, but that's 

another story. 

3, the third question, do we agree that 

decreasing false positives for asbestos may be achieved 

by the selection of an instrument that may permit the 

analyst to observe other diagnostics that may be used to 

distinguish among the mineral forms present? 

If you understand that question, I would like 

to hear from you. 

Well, basically it says do you agree, 

depending on the instrument you use, you're going to get 

different results? In fact, we've just discussed that. 

SPEAKER: Yeah. 

MR. LANGER: Of course. It depends on the light 

microscope, whether it's polarized light, so on and so 

forth, and immersion oils. 

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SPEAKER: Can I ask Rob what he typically charges 

for this package of XRD PLM on a talc sample? 

SPEAKER: It depends on if it's one sample or many 

or -- but it's somewhere under $1,000 to $1,500. 

SPEAKER: Per sample? 

SPEAKER: Yes. 

SPEAKER: And so if we were interested in 

categorizing an entire deposit or an entire mine, they 

may have to provide you with hundreds of samples? 

MR. LANGER: They can't -- it cannot be done. It 

can't be done. 

Take 1 ton of ore, a long ton at that, a 

metric ton. How many samples do you need within that 1 

ton to characterize it? Then you multiply that by 

350,000 or 580,000. There aren't enough electron 

microscopes in the world or analysts that know what 

they're doing. That's another story. 

MS. WYLIE: That's very important. 

MR. LANGER: Someone with the skills and can 

interpret the data. That is tough. 

So all of this, when you talk about "Can you 

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characterize the deposit?" that would be ideal for all 

of the talcs used to formulate consumer talcum product. 

If you can do that, then you don't have to look at the 

80 million canisters of J & J baby powder or Gold Bond 

powder or -- and it goes on and on. 

You have to look at market share. You have to 

look at the number of potential samples. How many of 

the canisters do you have to look at? This is a tough 

problem, and it is a statistical problem. How much are 

you going to actually look at? 

SPEAKER: And statistics involves probability and 

involves risks. And, you know, who's to say that a 

canister will not get through? 

MR. LANGER: Absolutely right. 

MS. WYLIE: You can't analyze every canister for 

$1000. Come on. 

SPEAKER: I think you've raised an important 

point, quality assurance versus quality and control, and 

the need for the quality assurance approach is very high 

here. 

MR. LANGER: Absolutely. 

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SPEAKER: So what does the QA approach look like? 

MR. LANGER: Yeah. 

SPEAKER: And that was discussed. Where's the 

asbestos being mined from? So you have to start from 

the point of origin. 

MR. LANGER: For example, the Italian talcs. 

We've got four analyses of Italian talc. Two are 

negative, we think. Two are negative, and two are 

positive for minerals. It's the same source. 

SPEAKER: Yeah. 

MR. LANGER: But it's like the mining industry. 

They dropped rocks in different parts of the pit or the 

mine. They drop rocks. Sometimes the rock is 

juxtaposed a scene that's contaminated with whatever, an 

unwanted fiber. They drop it, and they say "Let's bring 

it to the mill and the mill is going to separate the 

material. It's their problem, not ours, because we get 

paid by the amount of rock we drop." So there's all 

kinds of interesting issues. 

SPEAKER: They don't like a solution, pollution. 

MR. LANGER: Well, listen, we understand that but 

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it's a --

MS. WYLIE: Standard mining technique. 

SPEAKER: Just like we have something called good 

manufacturing practices on the drug side, and we don't 

know if we have good mining practices. 

MS. WYLIE: But it's standard. That's standard 

mining. If you go into a mine and you only take the 

highest grade of ore, say, we're mining gold, your mine 

might last a year. If you take the highest grade of ore 

and you mix it with a lot lower grade of ore, then your 

mine lasts two years. And if you mix it with an even 

lower grade and you mix it with as low a grade as 

possible to get -- this is standard mining practice. So 

this is not -- you're not trying to pull anything over 

on anybody here. It's just the way that miners do it. 

MR. LANGER: Okay. Well, we've just gone through 

No. 3, I guess. 

Do we agree that a decrease in false 

positives, and so on and so forth, may be used to 

distinguish among the mineral forms present? 

Well, if we know the width and the size, the 

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length, and we analyze by ATM, we might be able to do 

that. 

Question No. 4. Do we agree, that if light 

optical analysis is performed, that the instrument of 

choice is the polarizing microscope, with immersion 

oils, with a suitable range of indices of refraction? 

You're not going to disagree with me. 

MS. WYLIE: No, I'm not. 

SPEAKER: I agree. 

MR. LANGER: Good. We agree on that. It's 

remarkable. 

Do we agree that, if we observe a fibrous 

particle, as defined by OSHA, a length greater than 5 

microns, aspect ratio of 3 to 1 or greater, that the 

presence of a continuous striation parallel to the fiber 

length, the long axis, defines it as asbestos or more 

likely asbestos? 

MS. WYLIE: No. 

MR. LANGER: I disagree with that. Yes, you're 

right. 

SPEAKER: I also disagree. 

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MR. LANGER: The striations. What do the 

striations tell you? Well, you would have to do 

something else or use a different immersion oil. Yeah. 

MS. WYLIE: No. 

MR. LANGER: Okay. 5, do we agree that if we 

observe a fibrous particle, bup-ba-bup-ba-ba --

MS. WYLIE: 6. Go to 6. 

MR. LANGER: Let's go to 6. Do we agree that 

fibers with a width of about 1 micron or greater are 

most likely cleavage fragments? Do we agree that 

measurement of particles in a population might be useful 

in distinguishing between asbestos and nonasbestos 

fragments of the same mineral? 

MS. WYLIE: Can we qualify? You could have a 

1 micron particle of asbestos, and it's obviously a --

MR. LANGER: It's possible. 

MS. WYLIE: Right. So I think if it's a single 

crystal, then the answer would be yes. 

SPEAKER: Well, yeah. I mean, that's the reason 

why I'm, you know, against the air samples, because in a 

lot of air samples these days, you may only have three 

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fibers on the air sample and if one of those is on the 

fence, well, you know, what do you say about it? 

The important word there is "population," and 

I think what we need to do or we ought to do is to 

define what is the minimum population number that we 

need in order to be able to make this generalization as 

to the population and not forgetting that we can have 

mixed populations? So --

MR. LANGER: Sure. 

SPEAKER: So you may have some cleavage fragments, 

and you may have some asbestos minerals. And so, you 

know, if you've only got two particles, you may have one 

of each, and now what are you going to say? So what, 

for us, is the -- what would we think is the minimum 

number of particles that need to examine to be able to 

make that distinction? 

MS. WYLIE: I think you had 30 on your slide, and 

I think --

SPEAKER: 30 for chemistry. 

MS. WYLIE: If you had -- if you had 30 particles 

that are longer than 5 micrometers, I don't think you 

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have a problem. I think you have a very clear 

distinction on whether it's asbestos or not. 

SPEAKER: Yeah. 

MS. WYLIE: I really do. You know, one, that's 

obvious, but --

SPEAKER: Yeah. 

MS. WYLIE: -- you don't need that many. Asbestos 

minerals are very uniform material. That's the nature 

of it. If you saw the slides, I mean it's all -- it's 

uniform. It becomes less uniform as it becomes a lower 

quality asbestos and -- you know, but it still has its 

characteristics. 

SPEAKER: If you want to take a precautionary 

approach and say that "If any of them are less than 1 

micron width, then this indicates the possibility of 

asbestos," then I would say the number you need is quite 

small. 

MS. WYLIE: But I wouldn't take the 1 micrometer 

because that doesn't make sense of what asbestos 

actually is. 

SPEAKER: Well, we can argue about the precise 

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number. As I said, with the materials I created, albeit 

artificial, only 85 was actually best separation. I 

mean, we can argue over the precise number. But once 

you have the number, I think, as long as you are willing 

to say that anything less than that number is an 

indication of asbestos, even a single particle less than 

that number is an indication of asbestos. And we move 

to the next level. 

I mean that's the whole point of the D7200 

method. It just doesn't count particles and divvy them 

according to cleavage fragments or asbestos particles 

and then stop. It says if you have more than so many of 

these, you might want to go on to TEM. 

MR. LANGER: I wouldn't --

MS. WYLIE: If you have enough to establish a 

mode, I think if you have it; right? I think if you 

have a clear mode, you have enough. 

SPEAKER: Yeah. 

MS. WYLIE: It could be 30. It could be 100. It 

depends on the variance within the width measurement. 

SPEAKER: It does. And I'm not sure that I have 

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the data immediately in my head to decide what --

whether it's 30 or 100. But the data is out there. You 

know, we don't need to do further studies on this. We 

have lots of numbers. 

SPEAKER: The problem is there's scientific 

definitions, but then there's also product liability and 

legal definitions. And so will they accept a certain 

amount of particles that we think look like asbestos but 

may not rise to the level of being --

SPEAKER: What do your customers require now? An 

actual, you know, certification from you that you have 

looked as hard as you can and found nothing? 

SPEAKER: We don't provide them that. They ask 

for it, but we just give them the results down to a 

certain detection level. 

MR. LANGER: And that makes sense. 

SPEAKER: And how do you define your detection 

levels? 

MR. LANGER: The detection limit is defined by the 

instrument. 

MS. WYLIE: Going back to width, Martha Warnock 

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has great -- huge studies on lung tissues of people with 

mesothelioma, and she sent me all of her data. I have 

all of her data. 

MR. LANGER: Really? 

MS. WYLIE: Yes. And the width of all of that 

material, there were, in the hundreds and hundreds and 

hundreds and hundreds -- I mean, huge numbers -- I think 

I saw two particles that had a width of 2 micrometers. 

SPEAKER: Yeah. But don't forget all of those 

bundles broke up in the lungs. 

MS. WYLIE: That's right. They did. That's what 

happened. 

SPEAKER: And they do, and I perfectly agree that 

they do. But they may not have been fibers going in. 

MS. WYLIE: Yeah. Yeah. They would be bundles. 

And you could see them as bundles. 

SPEAKER: So if I understand this, as we can --

the number criteria -- it's the one where they're 

starting to come up with what's the number criteria? 

MS. WYLIE: Yeah. 

SPEAKER: But it's probably -- I guess, you do 

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lots of testing and have a small idea, including the 

consumer products? We say "What should be the number 

that you guys commonly see when you're doing a consumer 

product, or, I guess, testing for other products -- or 

any other products?" 

MR. LANGER: Would you have different standards, 

then? 

SPEAKER: That's what I'm saying. What's the 

number? 

SPEAKER: I'm guessing the lab doesn't know the 

end use of the materials that are being provided for 

analysis. 

SPEAKER: Well, sometimes. We get raw and 

finished products. 

SPEAKER: Right. But you don't always know what 

it is. You may just get a little package. 

SPEAKER: Anything from talc fibers to 

non-processable tremolite. 

MS. WYLIE: I think Martin's approach of trying to 

go from the risk assessment has basis and establishes 

the percentage you want analysts to focus on. 

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SPEAKER: And then we just make sure that our 

methods can actually meet that level. 

MS. WYLIE: Well, that's -- yeah. But that would 

be the way I'd go. I have some data that allows you to 

form a basis on what's tolerable. 

SPEAKER: I think another thing is it needs to be 

formulated so they can make compliance decisions against 

their scrutinized procedure. 

But what you're talking about for bulk 

material and acceptability criteria is really kind of a 

policy decision based on what I would call your beta 

error. How much risk do you want to take for being 

wrong if you say there is no asbestos when there is 

asbestos? And that determines how many -- how far you 

need to go. And that is a policy thing. It really 

isn't something that science -- except maybe Martin's 

calculation of risk can help be a guide to that policy. 

SPEAKER: Yes. 

MS. WYLIE: I thought so too. I thought that's a 

real way to get at it. 

SPEAKER: I mean, it's going to take work. I 

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mean, somebody has got to try to figure out what a, you 

know, typical talcum dust cloud is going to be in terms 

of concentration, how long you're likely to be in it, 

how much -- how many particles you're likely to breathe? 

And then, you know, figure out what percentage of those 

particles could be asbestos and still be below the 

standard if you use that talcum powder so many days per 

year. 

You know, there's work to be done. And all of 

those assumptions, of course, can be questioned, which 

makes it have to probably go out to public review and be 

allowed to be questioned. 

And it may take you 10, 15 years to get 

through that process. I mean, I've worked on, you 

know -- even in the scientific communities, I've worked 

on ASTM standards where I've issued Version 16 of the 

standard. You know, and at twice a year, that's eight 

years. So, you know, it could take a while. 

SPEAKER: I'd be happy if was provided information 

that's interpretable and what are the metrics at this 

point? 

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MS. WYLIE: We know what the limiting material 

looks like. Yeah, we've got data. We know. 

SPEAKER: Why did you pick that? 

MS. WYLIE: Libby? 

SPEAKER: Yeah. 

MS. WYLIE: Because that's what we have --

SPEAKER: Because that's the only one that we have 

a limit factor for. 

SPEAKER: So if it's a known amphibole in the 

environment that people are exposed to? 

MS. WYLIE: Yeah. If there's mesothelioma 

associated with it. 

SPEAKER: And you can get that information right 

out of the assessment, you know, just Google Libby 

amphibole. 

MS. WYLIE: And I had four analyses of Libby 

amphiboles that were taken in very different ways by 

different labs and analyzed, and it's the most uniform 

material that I said I had. I couldn't believe it. I 

couldn't believe how uniformly those percentages of each 

of those categories of fibers were reproducible, plus or 

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Asbestos in Talc Breakout Session B November 28, 2018 

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minus 1. 

SPEAKER: Right. 

MS. WYLIE: I mean, it's amazing. 

SPEAKER: What we need to guard against most 

rigorously is those labs that are just willing to take 

the money and certify zero. We know that happens with 

asbestos fiber count in PCM. We know it happens. 

And, you know, the only way you can guard 

against it is by a rigorous system of participation in 

proficiency test programs and presentation of the 

laboratory, participation in blind PT and accreditation. 

It's the only way. 

MR. LANGER: You folks are welcome to sit here and 

stay. Those of you who want to move on, by all means. 

In fact, we're up to question 6 now, weren't we? We've 

got a long way to go. 

MS. WYLIE: I think we will start all over again. 

We've got a new group, and we start all over again. 

(Session B concluded at 3:04 P.M.) 

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202-857-3376 
<%18240,Signature%>

Asbestos in Talc Breakout Session B November 28, 2018 

Page 70 

1 REPORTER'S CERTIFICATE 

2 

3 I, DANIEL E. WILLIAMS, RPR, certify: 

4 That the foregoing proceedings were taken 

5 before at the time and place therein set forth, at which 

6 time the witness was put under oath by me; 

7 That the testimony and all objections made were 

8 recorded stenographically by me and transcribed by me or 

9 under by direction; 

10 That the foregoing is a true and correct record 

11 of all testimony given, to the best of my ability. 

12 I further certify that I am not a relative or 

13 employee of any attorney or party, nor am I financially 

14 interested in the action. 

15 IN WITNESS WHEREOF this 7th day of December 

16 2018. 

17 

18 

19 DANIEL E. WILLIAMS, RPR 

20 

21 My commission expires 08/14/22. 

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202-857-3376 
Asbestos in Talc Breakout Session B November 28, 2018 

[& - amphibole] Page 1 

& 20 4:6 52:2 

2012 38:14 39:6 

2018 2:2 70:16 

20740 1:14 

24 38:7,8 

28 2:2 

3 

3 17:19 19:11,14 

19:17,19 20:4,5,6 

20:12 33:20 34:2 

46:18 47:7 53:8 

57:17 58:14 

30 29:2 60:17,19 

60:20 62:19 63:2 

350,000 54:15 

365 5:18 38:9 

3:04 69:19 

4 

4 35:8,18,19 36:4 

42:9,9 58:3 

4,000 38:12 

40 42:8,9 

43 42:9 

45 10:3 

5 

5 4:3 17:18 20:10 

30:18,20 31:4,5 

31:15,16 32:3,7 

32:13,16,21 33:3 

33:15,19 34:21 

35:2 36:2 38:4 

46:18,19,20 47:7 

58:13 59:5 60:21 

580,000 54:15 

6 

6 38:10 47:16 59:7 

59:7,8 69:15 

7 

70 12:12 37:13 

38:9 

75 5:18 

7777 1:13 

7th 70:15 

address 9:11 

adds 24:2 

adjustments 41:17 

adverts 40:11 

aerodynamic 

19:11,13,17 

aerosol 7:5 

aerosolized 41:3,4 

ago 16:5 27:18 

29:2 

agree 17:13,18 

18:9,11,21 20:10 

21:18 22:20 23:15 

23:15 25:12 26:12 

36:9,20 42:13 

53:3,8,15 57:18 

58:3,9,10,12 59:5 

59:8,10 64:13 

air 20:18 21:9,11 

21:15 28:19 39:16 

41:13 59:20,21 

60:1 

airflows 41:16 

akin 24:6 

albeit 62:1 

align 45:17 

allamore 2:17 

3:11 

allow 27:13 39:19 

allowable 40:14 

allowed 67:12 

allows 66:4 

alveolar 7:7,8 

19:6 20:3 

amazing 69:3 

ambient 28:19 

amination 49:15 

amount 6:15 

40:14,14 46:8 

56:18 63:8 

amphibole 2:13 

3:6,9,14 25:19 

28:4 37:10 44:15 

68:9,15 

& 4:10,15 14:9 

55:4 8 

80 4:5 55:4 

85 50:11 62:2 

0 

00 38:2 

01 5:14 

08/14/22 70:21 

9 

9 38:4 

1 95 28:16

1 17:19 20:12 27:3 a

33:20 34:2,18 

35:9 43:16,17 

46:18,20 47:7 

48:20 49:9 53:2 

54:12,13 58:14 

59:9,15 61:14,18 

69:1 

1,000 54:4 

1,500 54:4 

10 4:3 19:20 32:6 

32:16 67:13 

100 19:5 52:16 

62:19 63:2 

100,000 39:5 

1000 55:16 

10th 46:7 

110,000 38:15 

39:7,8 

15 5:15,15 9:20 

67:13 

16 67:16 

18240 70:18 

1960s 34:10 

1970 32:2 

1970s 8:6 14:5 

1971 32:2 

1986 22:15 

1:42 1:15 2:2 

ability 70:11 

able 25:20 58:1 

60:6,15 

absence 21:2 

absolutely 22:11 

27:10 36:17 41:6 

51:16 55:14,21 

abundant 35:5 

accept 63:7 

acceptability 

66:10 

accepted 24:20 

44:21 

account 6:14,16 

accounts 6:15 

accreditation 

69:11 

accumulate 6:17 

8:2 

accumulates 8:1 

accumulation 

7:15 

achieved 53:9 

act 23:2 28:10 

33:11 

action 70:14 

active 51:3 

actual 33:6 42:2 

63:11 

add 3:21 23:16 

added 3:1 23:19 

24:8 

additive 24:3 

2 

2 31:7,7,8 33:21 

34:18 53:3 64:8 

2/10 45:18 

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Asbestos in Talc Breakout Session B November 28, 2018 

[amphiboles - body] Page 2 

amphiboles 2:16 approximately 

25:8,11 28:20 19:19 

68:17 architecture 7:6 

analyses 14:17 area 36:14 43:21 

46:13 56:7 68:16 areas 12:8 24:21 

analysis 2:6 5:1,8 38:13 

5:9,13 17:7,10,10 argue 13:16 61:21 

17:20 18:5 20:12 62:3 

21:1 30:14,19 argument 15:15 

33:14,16 41:2 arms 12:8 

47:6,8 49:8 58:4 arrive 7:10 

65:12 arthur 1:11 

analyst 46:15 articles 42:8 

53:11 artificial 62:2 

analysts 54:16 asbestiform 16:6 

65:21 16:7 

analytical 4:21 asbestos 1:2 3:7,9 

33:13 34:12 40:4 3:11,14 5:12 10:4 

45:18 46:11,13 14:13,14,15,18,19 

50:16 15:5 16:5 17:21 

analyze 25:16 18:4,4,11 19:16 

35:4 52:14 55:15 19:19 20:13,14,16 

58:1 21:3 22:18 23:4 

analyzed 68:18 23:17,19 24:7,8,9 

analyzing 46:15 24:11,18,19 25:2 

anatomy 11:18 25:3,5,6,7,10,14 

angeles 4:17 28:2,4,15 29:5,13 

ann 7:3 29:14,16,16 31:11 

anne 1:12 31:14,20 34:16 

announcement 35:1,6,9,12,15,17 

42:17 35:19 36:2 37:6 

answer 31:8 35:7 38:19 40:6,17 

59:18 41:8,9 42:15 44:2 

answered 26:21 46:3,10,21 47:8 

anthophyllite 5:11 47:21 51:13,15 

anybody 57:15 53:4,9 56:4 58:16 

anyway 42:12 58:17 59:12,15 

appears 51:13,18 60:11 61:2,7,11 

applicable 21:14 61:16,19 62:6,7 

apply 21:13 62:11 63:8 66:13 

approach 55:19 66:14 67:6 69:7 

56:1 61:14 65:19 ascends 34:13 

approached 11:20 asked 17:4 

asking 35:16 

aspect 7:15 17:18 

20:11 33:20 46:20 

58:14 

assay 47:17 50:8 

assaying 21:21 

assess 22:18 23:5 

assessment 21:14 

22:7,19 31:1,19 

37:10 41:10 65:20 

68:14 

assessments 14:17 

assessor 37:3 

assignment 26:5 

26:10 

associated 5:10 

68:12 

assume 5:11 

assumed 39:10 

assumptions 

67:10 

assurance 55:18 

55:19 

astm 67:16 

atm 58:1 

attendance 4:2 

attorney 70:13 

author 51:11 

available 45:6 

avenue 1:13 

average 52:15 

axis 58:16 

ayers 34:9 

backtrack 39:14 

39:18 

bags 4:3 

baltimore 1:13 

based 9:16 10:4 

14:17 22:7,19 

31:1 32:4 41:17 

42:2 46:8 52:12 

66:11 

basic 29:6 

basically 7:1 43:1 

53:15 

basis 8:20 20:14 

65:20 66:5 

beam 49:20 

bearing 46:20 

beaverhead 3:3 

bed 41:8 49:2 

began 32:13 

behavior 50:20 

belief 22:16 

believe 12:12 

13:14 21:6 39:9 

43:17 68:19,20 

bentonite 3:14 

berth 38:10 

best 23:14 62:2 

70:11 

beta 66:11 

better 49:18 

big 7:19 

bill 2:18 

biological 8:11 

34:7 

biologically 51:3 

bit 8:18 

bizarre 12:2 

blend 27:12 

blind 69:11 

blows 41:13 

blunts 51:9 

body 12:7,19 

15:12 

b 

b 1:6 33:8,9 69:19 

ba 59:6,6,6 

baby 55:4 

back 4:6 31:15,19 

37:2 43:10 44:19 

47:8 63:21 

background 27:19 

27:21 28:1,8 

29:13,15,21 44:13 

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Asbestos in Talc Breakout Session B November 28, 2018 

[bole - content] Page 3 

bole 50:9 

bond 55:4 

bottle 11:16 

bradley 29:9 

brainer 26:1 

break 8:3 

breakout 1:6 

breaks 8:3 

breathe 67:4 

briefly 7:3 

bring 56:15 

bringing 44:19 

broke 64:10 

broken 19:2 

bronchial 20:2 

brought 34:9 

bulk 21:13 50:17 

66:9 

bullet 27:3 

bunch 7:19 

bundles 64:10,15 

64:16 

bup 59:6,6 

burned 50:2 

candidate 14:15 

canister 12:10 

55:13,15 

canisters 4:5 55:4 

55:8 

capabilities 50:16 

carbonate 44:16 

carcinogen 15:9 

15:18 

card 14:8 

care 31:10 

careful 49:19 

case 21:5 23:18 

24:1 47:10 

cases 4:16 53:4 

categories 68:21 

categorizing 54:8 

cations 52:15 

cause 21:10 31:3 

caused 43:11 

cc 5:16 9:7,20 34:5 

38:4 

certain 5:10 6:2 

7:21 27:13 39:12 

51:5,7 63:7,15 

certainly 7:17 

14:10 52:20 

certificate 70:1 

certification 63:11 

certify 35:12,14 

40:6 69:6 70:3,12 

chain 30:12 

chance 11:4 35:19 

36:8 

change 23:3 42:3 

changing 34:4 

characteristics 

2:11 13:3,5 21:21 

61:12 

characterize 5:2 

54:14 55:1 

characterized 

15:3 

charges 54:1 

check 39:3,4 

chemistries 52:6,7 

chemistry 50:17 

52:10 60:19 

chin 4:16 

choice 32:3 58:5 

chokes 7:1 

choose 17:20 

chosen 31:16 

chris 8:6 

chrysotile 5:21 6:1 

8:3,9,13 25:8 

28:15,17,18 43:9 

47:13,16 

cigarettes 16:1 

circumstances 8:9 

citation 10:16 

clarify 26:3 

clay 15:16 

clear 15:12 30:5 

61:1 62:17 

clearly 8:21 15:8,9 

44:17 

cleavage 18:1 

31:11 59:10 60:10 

62:11 

client 46:2 

clog 41:14 

closer 24:17 

cloud 67:2 

colleagues 34:10 

collection 3:21 

collections 4:1 

college 1:14 2:1 

color 27:13 

come 13:4 35:11 

39:14 55:16 64:19 

coming 30:9 37:1 

comment 11:14 

commercial 24:20 

commercially 

25:3 

commission 70:21 

commonly 65:3 

communications 

4:12 

communities 

67:15 

comparative 

51:12 

comparison 42:14 

compliance 66:7 

components 8:12 

concentration 9:2 

37:12 39:16,19 

42:11 45:12 67:3 

concern 18:12 

27:2 43:12 

concerns 51:8 

concluded 69:19 

concurrence 2:5 

17:6 26:4 

concurrent 1:6 

conform 35:5 

congress 23:3 

connotation 37:7 

consider 47:12 

considered 17:2 

consist 27:11 

consumed 28:17 

consumer 23:12 

24:1 30:8 55:2 

65:2,3 

contain 2:16,19 

40:13,17 

containing 2:7 

17:8 50:15 51:2 

contains 3:5 

contaminant 

23:18 24:2 

contaminated 

5:10 56:14 

contamination 

25:10 

content 5:6 

c 

calculate 6:3 9:6 

calculated 8:19 

calculation 5:20 

38:2,5 43:10,13 

66:17 

calculations 37:2 

39:3,13 41:21 

calculator 49:13 

calibrated 49:18 

california 29:10 

30:1,2 

call 8:10 21:8 25:7 

66:11 

called 31:10 57:3 

canada 6:13 27:17 

canadian 14:8 

cancer 11:10 

14:11 15:20,20 

37:14,15 

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Asbestos in Talc Breakout Session B November 28, 2018 

[continuous - distinction] Page 4 

continuous 58:15 

contrary 21:2,4 

contrast 22:2 

32:10 

contribute 17:15 

contributing 

24:10 

control 55:18 

controls 7:4 

controversy 13:12 

convenience 18:6 

conversation 

42:14 

convinced 48:7 

corporate 4:11 

correct 10:8 12:16 

13:14 29:8 36:9 

39:9 70:10 

correctly 16:18 

correlated 33:8 

corresponded 

43:11 

corrupted 24:21 

cosmetic 1:1 2:21 

27:5,10 29:4 

41:12 

cosmetics 2:6,14 

17:8 29:11 

cost 46:13 

count 35:10 47:13 

53:5 62:10 69:7 

counterintuitive 

36:11 

counting 1:8 32:9 

32:13 41:2 45:1 

46:18 

counts 22:8 34:12 

couple 32:10 

course 5:1 6:18 

22:21 29:7 35:16 

45:9 46:12 53:19 

67:10 

created 62:1 

creates 15:13 

criteria 1:8 2:5,11 

13:4,4 16:10 17:1 

17:6,10,11 19:6 

26:4,7,11 44:20 

44:21 45:1 64:18 

64:19 66:10 

critical 47:6 

crocidolite 10:6,8 

10:12 

crystal 59:18 

crystallized 52:13 

cubic 34:4 

cumulative 6:3 

8:20 9:6,14 

current 5:16 

customers 63:10 

cutoff 32:6 39:10 

cycle 51:12 

cycles 50:20 

decisions 66:7 

decrease 57:18 

decreasing 53:9 

defense 51:20 

define 20:14 24:18 

27:19,20 28:8 

60:5 63:17 

defined 17:21 

20:13 58:13 63:19 

defines 58:16 

defining 15:5 

18:10 

definition 18:3,3,4 

21:8,9,13,14,18 

24:19 25:2,7 

definitions 21:3 

63:6,7 

definitive 26:13 

defraction 43:1,3 

43:4 

demonstrated 8:8 

density 19:18 

depending 13:2 

21:17 53:16 

depends 16:16 

43:7 44:4 53:19 

54:3 62:20 

deposit 2:19 54:8 

55:1 

deposited 8:14 

deposits 2:10,17 

15:2 27:12 29:9 

47:13 

derived 9:21 

described 2:15 

4:19 19:8 

designed 41:8 

details 14:10 

detect 46:9 

detection 5:5,6 

36:16 43:6 46:8 

63:15,17,19 

determine 6:4 

33:20 34:13 36:12 

45:8 

determined 6:2 

17:19 20:12 

determines 66:14 

determining 18:10 

41:9 

dewan 10:20,21 

diagnostics 26:12 

53:11 

diameter 19:11,13 

19:17,18 35:9 

different 8:12 

12:6,7 16:19,20 

21:20 27:12 28:13 

30:10 45:7 51:14 

52:3,6,7,8 53:17 

56:12 59:3 65:6 

68:17,18 

difficult 8:15 

28:10 30:11 34:1 

50:5,7 

diffraction 25:21 

44:7,10 45:8 46:6 

digressing 52:17 

52:18 

dimensional 30:14 

dimensions 33:7 

dioxide 12:13 

direction 30:17 

70:9 

disagree 17:14 

19:1,4 58:7,19,21 

discriminate 

34:19 

discussed 2:8 

46:12 53:17 56:3 

discussion 11:18 

13:2 16:14 17:13 

17:16 30:4 36:21 

42:18 

disease 21:10 31:3 

disposition 51:19 

distinction 60:16 

61:2 

d 

d7200 62:9 

damning 4:12 

dangerous 34:13 

daniel 70:3,19 

data 5:2 14:16,16 

16:9,20 22:19 

32:14 34:7 43:15 

47:1,3,4 54:20 

63:1,2 64:2,3 66:4 

68:2 

day 5:15,17 10:4 

37:12 38:7,8 

46:15 50:6 70:15 

days 38:9 59:21 

67:7 

deal 14:19,20,21 

dealing 5:7,7,13 

20:15 23:12 

death 2:15 

december 70:15 

decide 63:1 

decision 45:2,3 

66:11 

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Asbestos in Talc Breakout Session B November 28, 2018 

[distinctive - fibers] Page 5 

distinctive 29:16 

distinguish 53:12 

57:20 

distinguished 

effort 48:9 51:3,13,13 52:1,2 

ehrenfeld 8:17 52:4,11 

eight 10:3 38:6 error 66:12 

67:17 errors 49:9 

exposures 6:4 

10:9 15:2 23:5 

extrapolate 47:17 

eye 42:16 

25:18 

distinguishing 

59:12 

distribute 30:12 

distributed 29:18 

divvy 62:10 

document 11:16 

15:8 

doing 22:1 37:1 

46:13 47:9 54:17 

65:3 

dose 7:20 

doses 7:19 

dozens 52:14 

dr 3:1,7 4:1 5:1 

19:8 

drawer 52:1 

drinking 40:12 

drop 56:13,15,18 

dropped 56:12 

drug 57:4 

dust 18:7 19:6 

34:5 39:16 47:15 

47:16 67:2 

dusting 11:9 

either 44:2 essentially 7:19 

electron 4:21 20:1 50:15 

17:11 22:3,7,17 establish 2:4 17:6 

25:20,20 45:19 26:3 34:12 62:15 

46:14 49:20 54:15 establishes 65:20 

element 29:18 evaluate 48:9 

44:7 eventually 15:12 

elongated 45:17 46:9 

embraced 22:14 everybody 24:20 

emotional 37:6 42:19 

employee 70:13 evidence 15:14 

ended 42:1 49:18 21:2,4 

endorse 4:20 exactly 24:14 

endpoint 37:14,15 30:15 47:9 

ends 38:10,11 exaggerate 53:4 

enemies 4:13 examine 60:15 

engage 50:20 example 4:9 56:6 

engaged 16:3 exceed 33:3 40:2 

engineering 41:20 excellent 43:3 

enter 12:19 45:15 

entire 54:8,8 exchangeable 

entirely 51:14 52:15 

entry 20:2 excised 13:13 

envelope 37:2 exist 40:20 

43:10 expect 26:18 

environment 8:11 experience 17:14 

21:21 24:7,10 42:2 

28:15 68:10 experimentalists 

environments 50:19 

29:17 expert 43:18 

epa 22:1,6,15,16 expertise 43:21 

23:9,19 40:15 expires 70:21 

epidemio 6:2 exploded 37:9 

epidemiological exposed 6:15 8:21 

14:16 9:1,9 37:12 38:19 

epidemiology 10:4 68:10 

equal 31:7 36:7 exposure 5:15 6:3 

equivalent 19:20 6:6 9:6,15 11:4,7 

erionite 48:20 12:5,6 14:16 

49:6 50:10,11 31:20 33:7,8 

f 

fact 37:20 40:19 

48:18 52:10 53:17 

69:15 

factor 32:7 68:8 

factors 7:12 9:16 

fail 18:2 31:9 

failed 47:11 

fails 21:18 

fairly 37:9 

false 18:14 53:5,6 

53:9 57:18 

far 26:13 33:3 

66:14 

fascinating 14:2 

fda 10:20 23:9,11 

23:14 24:5 48:6,7 

fda's 29:3 

fdas 41:19 

federal 3:7 18:3,4 

20:15 21:8 

feedback 42:18 

feel 11:10 46:6 

felt 48:6 

female 11:18 

fence 60:2 

fewer 32:15 

fiber 1:8 5:11,14 

7:8 9:14,20 14:15 

14:17,18 15:6 

18:13,18 19:18 

21:8 22:8 25:17 

25:18 29:19,19 

34:6,12 35:18 

36:2,4,18 37:7,11 

38:10 39:19 46:10 

47:13 53:5 56:15 

58:15 69:7 

fibers 2:6,20 5:2 

8:1 9:7,7 16:4 

e 

e 70:3,19 

early 8:5 14:5,21 

28:14 

ease 18:5 

easily 25:18 33:17 

50:1,4 

east 2:19 

easy 49:14 

edenite 3:12 

eds 49:8,9,15,19 

education 9:21 

effect 51:14 

effects 46:9 

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202-857-3376 
Asbestos in Talc Breakout Session B November 28, 2018 

[fibers - hear] Page 6 

17:7 18:1,8,19 

19:2 21:9 25:13 

25:17 28:17 34:5 

35:2 38:11,12,14 

38:15,20 39:1 

41:2,9 43:11 

45:16 59:9 60:1 

64:14 65:17 68:21 

fibrous 18:2 58:12 

59:6 

field 6:13 13:10 

figure 30:11 67:1 

67:5 

figures 49:12 

filter 31:18 34:9 

48:2,2 

filters 41:14 

financially 70:13 

find 13:13 26:18 

28:19 35:18 36:4 

44:11 47:7 49:6 

53:6 

fine 20:16 41:13 

45:14 52:21 

finished 65:14 

first 4:5 7:9 17:17 

26:20 48:5 51:11 

five 9:1 

flow 41:20,21 

fluid 48:1 

fluidized 41:8 

49:2 

fluoro 3:12 

flush 49:2 

focus 14:3 28:21 

30:18,19 33:14 

50:19 65:21 

focused 14:3 

28:15 

foggiest 11:10 

fogman 8:6 

folks 69:13 

follow 8:18 

following 17:17 

21:17 

foot 34:4 

foregoing 70:4,10 

forget 64:9 

forgetting 60:7 

form 45:11 66:5 

formed 41:20 

forms 53:12 57:20 

formulate 55:2 

formulated 66:7 

forth 20:12 53:21 

57:19 70:5 

forum 42:17 

forward 29:1,4,6 

29:8 

found 14:4 32:11 

52:13,15 63:12 

four 56:7 68:16 

fox 4:16 

fragments 2:20 

18:1 59:10,13 

60:10 62:11 

fragrance 27:14 

27:15 

frank 8:17 

fraught 37:6 

free 29:5 35:12,15 

40:6 50:19 

fun 52:20 

function 41:2 

further 63:3 70:12 

future 29:1 

g 

g 1:12 

gather 47:3 

generalization 

60:6 

generalizations 

52:4 

generated 4:13 

generic 16:8 

genetic 51:19 

genic 51:4 

geologic 29:17 

geological 2:11 

24:19 

geologist 26:15 

germany 32:5 

getting 19:7,14 

28:5 37:13,20,21 

give 10:16 32:11 

36:3 63:14 

given 26:10 70:11 

glad 17:4 

global 30:3,6 

go 19:6 23:9 24:16 

26:12 40:5 42:4 

43:1 46:6,10 

48:14 57:7 59:7,8 

62:13 65:20 66:4 

66:15 67:11 69:16 

goal 17:5 52:17 

goals 25:13 

goes 29:10 31:19 

55:5 

going 8:21 14:7 

16:11,19 17:3 

22:20 25:16 29:1 

29:4,6,8 31:15 

36:4 37:17,21 

39:4,11 40:11 

42:3,6 45:16 

53:16 55:10 56:16 

58:7 60:13 63:21 

64:14 66:21 67:2 

gold 55:4 57:8 

good 3:20 14:6 

43:2,2 57:3,5 

58:10 

goodyear 42:8 

google 68:14 

gorilla 12:1 

gosen 2:10 3:1 

gouverneur 2:18 

2:19,20 

grade 27:6,11 

57:8,9,10,12,12 

gradients 52:12 

gram 38:12,15 

39:1 

gravimetric 47:17 

47:18 

gravimetrically 

47:15 

great 14:19,20,20 

64:1 

greater 17:19 

20:10 58:13,14 

59:9 

grit 3:6 

group 51:19 69:18 

guard 69:4,8 

guess 7:13 8:10 

13:11,16 36:13 

42:2 44:20 57:17 

64:21 65:4 

guessing 65:10 

guide 66:17 

guy 40:12 

guys 65:3 

h 

habit 45:8 

half 43:5 46:15 

hallmarks 34:15 

handheld 49:13 

happened 29:2 

34:3 64:12 

happening 6:7 

happens 69:6,7 

happy 67:19 

hard 34:18 63:12 

harder 33:20 

harmless 52:9 

harper 5:1 

hazardous 34:14 

head 63:1 

health 19:15 47:18 

hear 26:16 41:4 

53:14 

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Asbestos in Talc Breakout Session B November 28, 2018 

[heard - know] Page 7 

heard 2:9,10 15:4 

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48:10,13 

hearing 14:8 

heat 49:21 

heaven's 49:21 

heavy 47:19 

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help 66:17 

helpful 13:7 30:7 

henderson's 14:5 

henry 32:1 

high 35:1,19 37:10 

55:19 

highest 57:8,9 

hmm 48:12 

hold 15:16 

holes 50:2 

hot 11:6 

hotel 1:13 

hours 10:3 38:6,7 

38:8 

howard 34:9 

huge 4:18 49:10 

64:1,7 

huh 49:4 

hundred 48:17 

hundreds 54:9 

64:6,6,7,7 

hygiene 32:2 

imparting 9:15 ingredients 27:5 

imperious 14:13 inhalable 19:6,8 

implicated 3:13 inhalation 6:19,19 

3:14 7:5 22:18 

implies 17:9 inhale 19:5 

importance 7:4 inhaled 19:1 

important 5:4,7 initiate 23:13 

7:11 21:11 54:18 instrument 45:15 

55:17 60:3 53:10,16 58:4 

improve 42:15 63:20 

impurity 44:11 instrumental 

include 20:13 45:21 

included 21:3 instruments 45:6 

including 26:8 integrals 25:17 

65:1 intentional 24:3 

inclusive 17:21 intentionally 

incomplete 3:8 23:20 28:13 

incorporated interested 4:7 

20:20 27:13 46:3 54:7 70:14 

incredibly 27:17 interesting 2:12 

30:11 14:1 22:10 41:15 

increment 6:6,6 56:19 

index 21:9,11 interestingly 3:1 

44:14 47:16 interpret 54:20 

indexed 33:10 interpretable 

indicated 7:4 67:20 

indicates 5:13 invisible 44:14 

42:17 61:15 involved 9:2 

indication 62:6,7 involves 55:11,12 

indications 35:13 ionic 52:12 

indices 44:10 58:6 ir 11:15 15:7,18 

individual 9:8 iron 49:5,14,15 

indoor 22:1 50:6,15,18,19,21 

induces 51:14 51:16 

industrial 3:4 isolated 20:17 

industry 56:11 issue 5:8 11:18 

inflammation 12:3 25:15 29:6 

15:14 42:8,9,9 48:15 

information 12:9 issued 67:16 

41:7 45:7 67:19 issues 5:4 22:8 

68:13 23:10 56:19 

ingredient 23:17 italian 56:6,7 

23:18 italy 3:13 

iteration 42:1 

iterations 42:4 

j 

j 14:9,9 55:4,4 

jackie 4:16 

jan 41:16 

job 29:3 

john 6:13 13:10 

johnson 4:10,10 

4:15,15 

journal 9:13 

julie 48:7 

juxtaposed 56:14 

k 

kapal 10:20,21 

keep 42:16 

kernel 24:17 

key 16:17 

kind 9:11 16:8 

27:14 28:9 42:9 

66:10 

kinds 7:2 56:19 

know 5:21 11:12 

12:2,11 13:11,12 

13:21 14:19,20,20 

15:10,11,12,15,16 

15:16,17,19 16:13 

20:15 21:7 23:10 

23:11,13 24:17,20 

28:9 29:3,3,5 30:5 

30:12,16 31:13 

32:10 34:19 35:13 

37:2,5,6 38:13,17 

39:13 40:7,10,10 

40:11,19 41:10 

42:13 47:3,5 

49:20 50:15,18 

51:1 52:16 54:16 

55:12 57:5,21 

59:20 60:2,12 

61:4,11 63:3,11 

65:10,15 67:2,5,9 

67:15,17,18 68:1 

i 

idaho 41:19 

idea 13:8 43:14 

48:2 65:1 

ideal 55:1 

identification 1:8 

2:5 16:10 17:2,7 

identified 3:9 

identifying 46:21 

ignorant 14:8 

immediately 63:1 

immersion 46:5 

53:21 58:5 59:3 

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202-857-3376 
Asbestos in Talc Breakout Session B November 28, 2018 

[know - means] Page 8 

68:2,14 69:6,7,8 

known 31:20 51:4 

68:9 

knows 43:18 

large 12:19 45:14 

lasts 57:11 

lawsuits 14:9 

lead 7:19 40:14 

left 4:4 

legal 24:20 63:7 

length 17:18 20:10 

58:1,13,16 

lengths 32:19 

letter 42:20 

level 5:14,15,17 

9:9 27:20 28:1,7 

29:14,15,16 36:18 

39:10,12,20 49:10 

62:8 63:9,15 66:2 

levels 6:3 28:12 

29:21 48:15 63:18 

liability 63:6 

libby 3:12 48:19 

68:4,14,16 

liddell 20:21 

lies 2:18 

life 10:3 

lifetime 37:13 

38:9,11 39:18 

light 17:10 18:5 

45:13 46:4,4 

53:19,20 58:3 

liked 26:16 

limit 5:5,6 19:17 

30:4 36:15 37:19 

63:19 68:8 

limited 34:6 37:21 

46:8 

limiting 68:1 

lineal 6:9 

linear 6:5 

liquids 47:19 

listed 27:15 

listen 56:21 

listened 11:16,17 

lists 4:13 

literature 3:10 

38:18 

litigations 4:9 

little 8:18 49:7 

65:16 

loaded 28:9 

lobbying 32:6 

local 52:12 

location 1:13 

lodging 7:6 

long 16:5 28:20 

35:2,3,8,18 54:12 

58:16 62:4 67:3 

69:16 

longer 30:20 

32:16 35:19 46:19 

47:7 60:21 

look 21:12 25:12 

28:19 35:5 36:13 

36:14 39:3,15 

47:20 51:12 55:3 

55:6,7,8,10 56:1 

63:8 

looked 5:9 28:18 

39:7 42:10 48:18 

48:19,19 63:12 

looking 5:9 13:1 

20:17 26:19 34:15 

looks 68:2 

los 4:17 

lot 4:20 14:9 22:8 

43:15 47:14 57:10 

59:21 

lots 63:4 65:1 

louis 4:16 

low 48:14 57:12 

lower 45:18 57:10 

57:12 61:10 

lowest 38:14 39:6 

lung 8:13 15:20,20 

19:9,14 37:13,15 

38:12 39:1 64:1 

lungs 38:20 64:10 

m 

m 1:11 

magnetite 29:18 

majority 12:18 

making 3:5 

manufacturing 

57:4 

mapped 14:12 

market 30:3,6 

55:6 

marlan 51:11 

martha 63:21 

martin 23:16 

martin's 65:19 

66:16 

marty 37:5 

maryland 1:13,14 

2:1 

mass 49:9 

matches 44:10 

material 5:3,10 

8:1,2,10 18:10 

23:12,20 45:4 

48:17 51:4 56:17 

61:8 64:6 66:10 

68:1,19 

materials 3:6,9 

4:3 21:13 51:3 

62:1 65:11 

matrix 43:8 46:9 

matter 16:18 

mean 6:21 7:15 

8:19 13:18 14:6,9 

14:19 15:10,16 

18:14 22:5 28:1 

28:16 32:18 36:7 

37:15 42:9 44:11 

48:6 59:19 61:9 

62:3,9 64:7 66:21 

67:1,14 69:3 

meaning 4:13 5:4 

5:8 

means 6:5 25:4 

69:14 

l 

lab 41:20 52:1 

65:10 

labile 8:10 

laboratories 43:20 

laboratory 32:18 

69:11 

labs 16:20 68:18 

69:5 

lacking 51:20 

langer 1:11 2:4 

3:17,19 4:1 6:12 

6:18 7:2,17,21 8:5 

8:8 9:3,5,12,13 

10:11,13,15,17,19 

11:1,6,9 12:10 

13:7 14:1,14 

15:19 16:1,3,7,11 

16:21 17:3 18:14 

18:17,20 20:9 

21:16 22:10,13,20 

23:2,6,15,21 24:4 

24:9,13,15 25:15 

26:5,7,10,16 27:1 

27:4,10 28:1,3,14 

29:7 34:3 36:15 

36:18 38:6,8 

40:21 41:5 43:2,7 

43:13 44:4 45:5 

45:11 46:2 47:12 

49:3,5,13 50:1,4 

50:12,17 51:2,8 

51:16 52:6,18,20 

53:1,19 54:10,19 

55:14,21 56:2,6 

56:11,21 57:16 

58:10,19 59:1,5,8 

59:16 60:9 62:14 

63:16,19 64:4 

65:6 69:13 

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202-857-3376 
Asbestos in Talc Breakout Session B November 28, 2018 

[measurement - numbers] Page 9 

measurement 1:8 micron 12:17 

59:11 62:20 17:18 19:19 20:10 

measurements 33:3 35:8,18 36:2 

32:19 36:4 45:18 46:8 

mechanism 6:21 59:9,15 61:15 

12:3 14:11 15:17 micronic 19:21 

51:15,20 microns 20:6 

mechanisms 7:3 31:15,16 32:3,6 

15:11 51:17 32:16 35:9,20 

meeker 3:7 58:14 

meet 21:3 66:2 microprobe 49:17 

membrane 7:8 microscope 4:21 

31:18 34:8 17:20 22:3,4,7 

memory 11:19 25:20 33:19 34:1 

mention 14:9 41:4 45:19 53:20 

mentions 41:3 58:5 

mesothelioma microscopes 54:16 

3:13 6:20 9:15 microscopic 18:5 

37:17 38:1,14,20 microscopy 17:11 

38:21 39:7,11 17:11 18:5 22:17 

51:4 64:2 68:11 32:10 44:6 45:13 

mesotheliomas 46:4,4,14 

3:15 7:10 mill 56:16,16 

mesothelium 19:7 million 38:10 55:4 

method 16:17,19 millions 34:4 

17:9 19:16 31:18 mills 10:5 

42:11,16 62:10 mine 24:13 26:19 

methodology 30:6,7 54:8 56:13 

20:19 57:7,8,11 

methods 4:19 66:2 mined 25:3 56:4 

metric 54:13 mineral 2:6 5:6,10 

metrics 67:20 17:7 18:13,18,19 

mic 46:18 25:13,16 43:7 

mickelson 22:14 45:9,17,17 46:7 

micro 20:4 53:12 57:20 59:13 

micrometer 19:20 mineralogists 8:10 

31:5 32:21 33:15 minerals 14:4 

34:21 61:18 16:5 18:1 27:2 

micrometers 56:9 60:11 61:8 

12:12 19:5,17 miners 57:15 

30:18,20 31:4 minimum 60:5,14 

32:13 33:19,21 mining 56:11 57:2 

34:18 35:2 46:19 57:5,7,8,13 

60:21 64:8 

minus 38:4 52:16 

69:1 

minutes 5:15 

mix 57:10,11,12 

mixed 50:12 60:8 

mixing 27:8 

mixtures 27:11 

mobilized 8:15 

mode 62:16,17 

model 6:5,8,11,14 

models 6:19 

moderators 1:11 

money 69:6 

montana 3:12 

mordenite 50:12 

morning 2:9 14:3 

15:4 16:14 17:15 

42:8 45:5 46:12 

morphological 2:5 

16:8,10 17:1,6 

26:4,7,11 41:1 

morphology 17:9 

52:3,8 53:4 

mortality 6:2 9:16 

mossman 19:8 

mount 9:17 

mountain 3:3,15 

move 30:17 62:7 

69:14 

movement 41:21 

multiple 45:6 

multiplied 9:8 

multiply 54:14 

myth 37:9 

nature 15:5 17:4 

61:8 

necessarily 31:2 

need 25:19 26:1 

26:19 30:13,13 

42:18 44:9 45:18 

47:9 49:13 50:9 

54:13 55:19 60:4 

60:6,15 61:7,16 

63:3 66:15 69:4 

needs 23:2 66:6 

negative 36:19 

53:6 56:8,8 

never 2:16,21 

11:17 15:2 24:18 

27:5 29:11,11 

43:13 53:1 

nevertheless 34:7 

new 2:16,18 69:18 

nexus 16:15 

nil 50:18 

niosh 34:10 

nolan 4:1 9:13 

15:19 16:3 

non 51:17 65:18 

nonasbestos 59:12 

nonfibrous 18:7 

noniron 51:2 

nonreproducible 

32:12 

normal 27:19,20 

28:8 39:15,16 

november 2:2 

number 5:2 9:8 

33:2 37:1 39:17 

40:3,7,8 50:20 

55:7 60:5,15 

61:16 62:1,3,4,5,7 

64:18,19 65:2,9 

numbers 49:11 

63:4 64:7 

n 

name 6:12 10:19 

10:20 

nanofibrillar 25:8 

25:11 

narrow 7:7 

narrower 20:6 

national 41:19 

naturally 24:6 

25:6 28:6 

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202-857-3376 
Asbestos in Talc Breakout Session B November 28, 2018 

[oath - possibility] Page 10 

o original 4:3 20:19 

22:13 41:19 

originally 10:4 

osha 58:13 

ottawa 6:13 

ought 60:4 

outcropping 

24:10 

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ovarian 14:4,11 

ovary 12:4 

62:11 63:8 64:8 

67:4,6 

particular 33:8 

51:19 

particularly 50:6 

parts 28:11 30:10 

56:12 

party 70:13 

patient 38:14 

patients 39:7 

pcm 22:8 69:7 

penetrates 7:8 

penetration 7:5 

people 4:14 12:7 

14:9 15:4 16:15 

25:5 27:11 28:12 

28:18 35:11 38:19 

38:21 40:4,19 

49:10 51:20 64:1 

68:10 

percent 5:14 

28:16 43:5,16,18 

47:16 48:17,20 

49:9 50:11 52:16 

percentage 65:21 

67:5 

percentages 68:20 

perfect 45:14 

perfectly 64:13 

performed 58:4 

period 48:3 

permit 53:10 

permits 27:14 

peroneum 11:9 

persevere 35:2 

personal 25:2 

perspective 27:16 

28:6 

peto's 10:15 

pharmaceutical 

27:6 

pharmaceuticals 

43:21 

pharmacology 

9:14 

phase 22:2 32:10 

physiologist 37:16 

pick 68:3 

pit 24:11 56:12 

place 70:5 

play 13:4 14:7 

31:18 

plea 45:6 

plenty 6:1 

pleura 7:9,10 

pleural 37:16,18 

37:20 

plm 26:1 44:17 

45:2 47:20 54:2 

plus 52:16 68:21 

point 14:1,2,6 

27:3,4 30:4 36:1 

38:18 41:18 42:20 

42:21 45:3 55:18 

56:5 62:9 67:21 

pointed 33:2 37:5 

41:18 

polarized 45:13 

46:4 53:20 

polarizing 58:5 

policy 20:20 66:11 

66:15,17 

pollution 22:2 

56:20 

population 31:7 

45:16 59:11 60:3 

60:5,7 

populations 38:18 

60:8 

position 3:2 22:9 

positive 31:14 

56:9 

positives 18:15 

53:5,9 57:19 

possibility 13:1 

61:15 

oath 70:6 

objections 70:7 

observation 9:21 

observe 53:11 

58:12 59:6 

observed 45:1 

obvious 61:5 

obviously 59:15 

occasionally 18:2 

occupation 30:21 

31:17,20 p 

occupational 9:21 

32:1 

occurred 34:8,8 

occurring 14:12 

24:7,9 25:6 28:6 

occurs 29:16 

odd 4:6 

oh 16:11 27:10 

28:3 36:20 

oil 44:10,14 46:5 

59:3 

oils 53:21 58:6 

okay 8:4,7 10:17 

11:1,13 13:9 35:4 

39:8,20 42:19 

43:19 57:16 59:5 

once 33:18,19 

62:3 

ones 30:8 

oo0oo 69:20 

open 42:17 

opening 13:1 

opportunity 23:11 

optical 33:19 34:1 

58:4 

order 12:17 60:6 

ore 54:12 57:8,9 

57:10 

organization 

19:16 

origin 56:5 

p.m. 1:15 2:2 

69:19 

package 54:2 

65:16 

paid 56:18 

pallets 4:8 

panel 11:15 42:7 

42:16 

paper 3:5 9:12 

51:10 

parallel 58:15 

pardon 19:12 

parietal 7:9 

park 1:14 2:1 

part 2:12 7:14 

16:17 33:5 44:17 

participation 69:9 

69:11 

particle 17:18 

20:11,17 32:21 

46:16 52:11,12 

53:3 58:13 59:6 

59:15 62:6 

particles 11:11 

12:17,21 18:2,7,7 

19:5 21:2 30:20 

31:3,6 32:15 33:3 

33:15 34:4,18,21 

35:4 45:14,17 

46:19 47:10 49:2 

50:3 52:14 59:11 

60:12,15,20 62:10 

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Asbestos in Talc Breakout Session B November 28, 2018 

[possible - reporter] Page 11 

possible 57:13 procedure 66:8 

59:16 procedures 27:7 

potential 6:16 7:5 proceedings 70:4 

55:7 process 67:14 

potentially 7:18 processable 65:18 

potentials 52:13 produce 40:2 

pound 4:3,3 produced 11:15 

powder 11:16 31:19 

39:15 55:4,5 67:7 product 23:13 

powders 40:16 35:12 40:2 55:2 

practical 42:2 63:6 65:4 

practice 57:13 products 4:5 

practices 57:4,5 23:19 24:1 30:8,9 

precautionary 41:13 65:2,4,5,14 

61:13 proficiency 69:10 

precise 61:21 62:3 programs 69:10 

predominantly project 16:3 

2:20 proper 46:5 

preparation 44:4 properly 15:3 

prepared 16:16,18 propose 26:8 

presence 31:14 proposed 15:11 

34:16 58:15 42:10 

present 24:15 35:1 protective 5:16 

46:7 53:12 57:20 6:8 

presentation 2:12 protocol 34:12 

14:2 69:10 prove 34:13 36:19 

presentations 2:9 provide 31:15 

press 9:12 32:7 54:9 63:13 

pretty 43:2 provided 65:11 

primarily 10:6,9 67:19 

10:12 provides 45:7 

prior 32:5 ps 42:9,9 

privy 14:10 pt 69:11 

probability 55:11 public 67:11 

probably 19:7 publication 37:10 

42:3,4 50:8,11,15 38:13 

52:2,8 64:21 published 42:7 

67:11 51:10 

problem 15:2 33:1 pull 57:14 

33:6 42:6 43:20 pulmonary 7:6 

45:20 49:8 50:10 pump 49:11 

55:9,9 56:17 61:1 pure 3:4 50:9,11 

63:5 purest 50:10 

purpose 25:1 

48:21 

purposes 31:4 

33:13 48:16 

put 16:4 28:12 

29:10,11 31:18 

41:16 44:9 70:6 

reactions 50:20 

read 32:1 

real 66:20 

realize 6:14 

realized 42:21 

49:19 

really 4:10 11:19 

14:12 22:17 24:18 

27:17 34:19 35:3 

61:4 64:4 66:10 

66:15 

reanalyzing 4:7 

reason 19:15 23:8 

31:12 59:19 

recognize 49:10 

recognizes 21:5 

recommend 3:2 

record 70:10 

recorded 70:8 

recording 32:19 

recovery 48:16,20 

refer 25:5 

reference 2:7 

11:21 37:11 

references 32:11 

refraction 58:6 

regarding 10:14 

region 19:7 

regions 8:14 

regulatory 9:13 

20:20 

related 31:21 33:5 

51:19 

relation 12:5 

relative 70:12 

releasable 41:9 

relevant 7:16 

relied 4:14 

remarkable 58:11 

remember 34:11 

repeat 23:10 

reported 3:10 4:6 

reporter 11:2 

q 

qa 56:1 

qua 51:16 

qualify 59:14 

quality 55:18,18 

55:19 61:11 

quantitative 48:16 

50:6 

question 3:20 5:17 

9:10 11:3 13:5 

16:9 17:17 19:10 

22:5 32:21 33:14 

35:7 41:1 44:19 

44:20 49:3 53:2,3 

53:8,13 58:3 

69:15 

questioned 67:10 

67:12 

questions 17:12 

20:14 26:20 30:18 

quite 61:16 

r 

radical 50:19 

raise 14:2 

raised 55:17 

ran 49:17 

range 58:6 

ranges 52:16 

rates 41:20 

ratio 17:19 20:11 

33:20 46:20 58:14 

rationale 28:16 

raw 65:13 

ray 42:21 43:3,4 

43:15 45:8 46:6 

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Asbestos in Talc Breakout Session B November 28, 2018 

[reporter's - speaker] Page 12 

reporter's 70:1 

reproducibility 

32:8 

reproducible 

31:11 32:14 48:10 

48:13 68:21 

require 48:8 63:10 

required 5:2 

requirements 

45:21,21 

reservations 

18:21 

residue 47:20 

respirable 21:9 

rest 37:8 51:21 

results 16:20 32:4 

32:12 53:17 63:14 

review 32:2 67:11 

revised 22:15 

rewards 4:17 

richterite 3:11 

ridiculous 35:15 

49:12 

right 3:8 9:10,10 

10:1,7 16:2,12 

18:20 20:4,7,21 

21:10 22:11 24:12 

29:3 30:15 31:5 

32:17 35:21 36:6 

38:1 41:6 42:5 

43:8 44:18 45:10 

46:1,17 48:9 50:2 

51:17,18 53:1 

55:14 58:20 59:17 

62:16 64:11 65:15 

68:13 69:2 

rigorous 69:9 

rigorously 69:5 

rise 63:9 

risk 5:8,9,12,19 

6:7 8:20 9:1,15 

10:14 14:17,17 

21:14 22:7,19 

31:1 37:3,10,13 

41:10 65:20 66:12 

66:17 

risks 6:4 22:18 

55:12 

rob 54:1 

rochdale 10:15 

rock 56:13,18 

rocks 56:12,13 

role 9:14 

roll 33:6 

roughly 43:5 

route 23:9 

rpr 70:3,19 

rule 19:16 

run 43:18 

running 47:16 

48:20 

russians 47:12 

see 4:20 23:8 

28:20 32:18 36:1 

44:13,16 47:21 

64:16 65:3 

seen 36:10 

segregator 41:8 

select 27:11 

selected 32:7 

selection 53:10 

sense 16:8 18:12 

21:15 61:19 63:16 

sent 64:2 

separate 47:19 

56:16 

separates 18:7 

separation 62:2 

series 17:12 

served 11:15 

session 1:6 2:4 

17:4,5 36:13 

69:19 

sessions 25:13 

set 37:11 39:6 

45:7,20 47:3 70:5 

setting 3:5 

share 55:6 

short 34:17 

shorten 33:16 

show 47:2,9 50:17 

showed 32:9 44:12 

47:1 

showing 16:20 

shows 29:10 

side 57:4 

signature 70:18 

significant 49:11 

silica 14:20 

simply 46:17 

sinai 4:4 9:17 

sine 51:16 

single 46:15 59:17 

62:6 

sit 69:13 

situation 20:16 

size 12:21 13:2 

20:1 21:13 33:8,9 

57:21 

skills 54:19 

skin 12:6,6,14 

slide 60:17 

slides 44:12 61:9 

small 19:2 61:17 

65:1 

smaller 7:18,19 

12:21 

smoke 16:1 

soils 41:10 48:18 

48:18,19 

sold 25:3 29:4 

solid 23:20 

solution 56:20 

somebody 67:1 

someplace 29:19 

sorry 9:5,18 28:2 

40:18 52:19 

sort 10:5 14:12 

15:13 27:19 28:8 

28:10 

sounds 16:17 43:2 

source 2:21 34:20 

56:9 

spaces 7:7 

speaker 6:11,13 

6:21 7:13,18 8:4,7 

8:17 9:4,10,11,19 

10:3,7,10,16,18 

10:20 11:3,8,13 

12:5,15,20 13:9 

13:10,15,16,20 

14:7 15:10,21 

16:9,13 17:1 

18:12,16,18 19:4 

19:12,15 20:1,3,4 

20:7 21:6 22:5,12 

22:16 23:1,8,16 

24:1,5,12,14,16 

25:12 26:2,6,8,14 

s 

safe 32:6 

safety 32:7 

sake 49:21 

sample 3:16,18 

16:16 18:6 21:10 

21:11,18 36:3,19 

48:4 49:6 50:9 

54:2,3,5 60:1 

samples 4:7 21:15 

24:2 52:2 54:9,13 

55:7 59:20,21 

saw 61:9 64:8 

saying 7:13 21:16 

21:17 24:9 33:11 

35:11 65:8 

says 15:18 20:8 

21:1 40:12 53:15 

62:12 

scene 56:14 

science 4:11 66:16 

scientific 63:5 

67:15 

scrutinized 66:8 

second 27:18 

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[speaker - thing] Page 13 

26:18 27:2,8,16 23:13 30:13,14,21 

28:2,5 30:1,3,11 31:17 34:6,6 

30:15 31:15 32:1 42:14 47:18 57:2 

32:15,18 33:2,5 57:6,6,13 67:7,17 

33:11,16,18 35:8 standards 2:7 4:2 

35:11,14,16,17 34:3 65:6 67:16 

36:1,6,7,9,10,12 start 25:10,16 

36:17,20,21 38:4 30:19 31:3 34:17 

38:7,9 39:3,6,9 34:21 35:3 56:4 

41:1,7,15,18 42:7 69:17,18 

42:19 43:4,10,17 started 32:9 

43:20 44:3,6,19 starting 64:19 

45:10 46:1 48:1,4 state 2:16,18 

48:5,10,12,13,14 stated 15:8 

48:21 49:1,4,7,14 states 15:9 21:20 

50:2,5,14 51:1,5,7 23:6 28:17 

51:10,18 52:10,17 stating 12:20 

52:19,21 53:18 statistical 5:1 55:9 

54:1,3,5,6,7 55:11 statistically 36:7 

55:17 56:1,3,10 statistics 55:11 

56:20 57:3 58:9 stay 39:20 69:14 

58:21 59:19 60:10 stenographically 

60:19 61:3,6,13 70:8 

61:21 62:18,21 step 24:16 

63:5,10,13,17 steve 9:19 24:5 

64:9,13,17,21 stick 37:4 

65:8,10,13,15,17 stop 25:9 37:21 

66:1,6,18,21 62:12 

67:19 68:3,5,7,9 stops 37:19 

68:13 69:2,4 story 6:8 53:7 

speaking 4:1 54:17 

27:16 strength 35:2 

specific 23:12 45:11 

26:13 stressed 5:1 

specifically 4:20 striation 58:15 

specify 44:6,7 striations 59:1,2 

spend 42:13 46:15 structural 25:17 

sphere 19:21 structure 35:9 

spoken 37:17 studies 6:1 9:16 

st 4:16 14:21 15:1 22:2 

stability 7:5 8:13 22:13 28:14 32:9 

stable 8:11 63:3 64:1 

standard 3:8 5:16 study 10:11,13,15 

18:6 20:15 23:3 14:5 30:7 

stuff 8:5 

sub 33:3 

sufficient 19:3 

suggested 3:7 

suitable 45:4,4 

58:6 

sunscreen 12:13 

support 34:7 

42:18 

suppose 16:4 

supposed 11:11 

17:5 26:20 

sure 10:10 16:21 

18:17 33:17 40:1 

42:15 53:5 60:9 

62:21 66:1 

surgical 27:7 

surrogate 33:12 

symposium 1:1 

system 6:17 49:15 

69:9 

55:2 56:6 

talcum 4:5 39:15 

40:2,16 55:2 67:2 

67:7 

talk 2:10 18:19 

29:2,20 43:9 

54:21 

talked 15:4 

talking 11:3 16:15 

22:14 25:10 27:18 

36:15 66:9 

talks 21:1 

tap 40:13 

target 40:1 

taught 37:7 

tease 33:6 

technique 34:9 

41:11 46:4 48:6,7 

57:2 

techniques 8:9 

tell 6:12 10:19 

40:7,8 44:1 59:2 

telling 5:5 31:2 

40:4 

tem 22:19 45:2 

46:11 47:6,8 

49:18 62:13 

ten 9:2 

tends 8:3 

terms 8:13 67:2 

test 35:2,12 43:1 

48:7 69:10 

testimony 70:7,11 

testing 65:1,4 

texas 2:15,17 

textile 10:5 

thank 13:9 

thickening 37:16 

37:18,20 

thin 31:6 

thing 10:5 12:2 

14:7 28:16 36:4 

42:13 66:6,15 

t 

take 54:12 57:7,9 

61:13,18 66:12,21 

67:13,18 69:5 

taken 68:17 70:4 

takes 23:2 

talc 1:2 2:7,13,13 

2:18 3:3,4 5:21 

11:9 12:4,9,18 

13:13 14:3,4,4,13 

14:18,21,21,21 

15:1,8,17 17:8 

18:1 23:12,17 

25:11,17,17,18 

26:18 27:2,14 

28:1 29:4,4,14 

35:17 36:3 41:3 

41:12,14 42:15 

43:9,16 44:9,10 

44:12 47:11,20 

54:2 56:7 65:17 

talcs 2:14 27:5,6 

27:11,11,12,12 

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[things - wish] Page 14 

things 28:10 30:12 tough 54:20 55:8 

41:10 toxic 11:4 51:14 

understanding 

43:5 

vote 17:13 20:9 

40:21 

think 3:1 8:19 toxicity 51:12 

9:20 10:12 11:20 toxicology 9:13 

12:3,11,12,18,18 trace 28:11 29:18 

17:2 19:3,10 20:9 50:17 

20:21 24:6 26:11 track 21:7 

28:21 29:1,13,20 transcribed 70:8 

30:3,5,6,17 31:6,8 transcript 1:6 

32:2,5 35:6 45:5 transmission 22:3 

47:13 50:16 52:2 22:6,17 25:19 

52:3 55:17 56:8 46:14 

59:17 60:4,14,17 tremendously 

60:18,21 61:1 52:11 

62:4,16,16 63:8 tremolite 5:11 

64:7 65:19 66:6 15:1 29:15 43:16 

69:17 44:15 65:18 

thinking 26:14 tried 41:11 

third 53:8 true 13:17 14:15 

thought 11:21 70:10 

26:19 43:16 66:19 try 40:13 48:15 

66:19 67:1 

three 9:16 25:13 trying 33:6 34:11 

38:16 49:11 59:21 40:6 57:14 65:19 

threshold 6:5 tuesday 42:8 

time 1:15 8:20 turned 24:21 

16:5 28:20 32:3 twice 67:17 

33:7,16 39:17 twists 25:18 

46:13 47:14,14 two 11:17 20:14 

48:3,8 70:5,6 28:11,13 56:7,8,8 

times 38:4,16 57:11 60:12 64:8 

39:17 type 9:14 

tissue 20:17 38:12 types 12:7 27:2 

tissues 13:13 14:5 typical 67:2 

64:1 typically 54:1 

titanium 12:13 u 

today 4:9 5:4 uh 49:4 tolerable 66:5 uicc 4:2 

ton 54:12,12,13,14 uk 34:8 topic 11:6 umbrella 16:5 topical 11:4,7 understand 4:8 total 49:9 7:21 15:15 16:13 touch 32:3 21:12 53:13 56:21 

64:17 

understands 

42:19 

unfortunately 

41:11 

uniform 61:8,10 

61:10 68:18 

uniformly 68:20 

united 21:20 23:6 

28:17 

university 1:13 

unknown 12:4 

unwanted 56:15 

update 22:14 

upper 19:17 

upside 12:1 

ural 3:15 47:12 

use 2:7 5:17,18 

6:19 11:20 12:7 

16:19 22:2,3,17 

39:15,18 41:7,15 

45:4,8 47:17,19 

48:15 53:16 59:3 

65:11 67:7 

useful 18:9 27:17 

50:8 59:11 

uses 22:6,7,19 

v 

vagina 13:19 

valley 2:15 

value 9:7 37:19,21 

48:7 

van 2:10 3:1 

variance 62:20 

varies 8:13 52:11 

various 2:10 11:9 

vast 12:18 

version 67:16 

versus 55:18 

visceral 7:9 

visual 17:9,19 

20:12 

w 

waltman's 32:1 

want 8:18 21:8,12 

40:1,5,8 42:3 

45:13 51:11 61:13 

62:13 65:21 66:12 

69:14 

wants 22:17 

warnock 63:21 

waste 47:14 

water 40:12 

waters 40:13 

way 12:20 26:11 

33:18 40:8 41:5,9 

57:15 66:4,20 

69:8,12,16 

ways 68:17 

we've 53:17 56:7 

57:16 68:2 69:15 

69:18 

webstine 4:19 

wednesday 2:2 

weeks 11:17 

weigh 47:15 

weighing 48:2 

weinstein 42:10 

weird 30:2 

welcome 69:13 

went 7:3 34:5 

wheelhouse 37:4 

whereof 70:15 

width 7:7 19:18 

19:19 20:5 57:21 

59:9 61:15 62:20 

63:21 64:5,8 

widths 7:4 32:19 

35:5,6 

williams 70:3,19 

willing 62:4 69:5 

winchite 3:11,12 

wish 13:7 

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[witness - zero] Page 15 

witness 70:6,15 

wolfgang 9:19 

24:5 

women 11:10 

wondering 7:14 

word 24:21 25:9 

37:6 60:3 

words 21:11 

work 22:1 39:21 

41:12 66:21 67:9 

worked 15:1 

67:14,15 

workers 15:1 

working 10:3 

42:16 

works 23:13 

world 19:15 30:10 

54:16 

worried 36:5 

worry 47:11 

written 20:20 

wrong 21:7 66:13 

wrote 42:20 

wylie 1:12 3:16,18 

3:21 10:2,6,8,12 

10:14 11:14 12:11 

12:16 13:14,18,21 

15:7,14,20 16:2,6 

19:1,11,13,21 

20:5,8,19 23:4 

26:1 28:4,21 29:8 

30:2,13,16 31:17 

32:8,17,20 33:4 

33:10,13,17 34:11 

35:10,21 38:3 

39:1,4,8 43:9,15 

43:19 44:1,9 

46:17 47:19 51:6 

52:1,7 54:18 

55:15 57:2,6 58:8 

58:18 59:4,7,14 

59:17 60:17,20 

61:4,7,18 62:15 

62:19 63:21 64:5 

64:11,15,20 65:19 

66:3,19 68:1,4,6 

68:11,16 69:3,17 

x 

x 42:21 43:3,4,15 

45:8 46:6 

xrd 54:2 

y 

yan 51:11 

yeah 9:3 13:16 

15:21 16:7 22:5 

22:12 23:7,21 

24:4 25:15 30:2 

30:13 33:17 40:17 

42:12 50:4,12 

53:18 56:2,10 

59:3,19 61:3,6 

62:18 64:9,15,15 

64:20 66:3 68:2,5 

68:11 

year 5:18 8:21 

37:13 38:9,9 

51:11 57:9 67:8 

67:17 

years 4:6 5:18 9:2 

9:2,8 10:3 29:2 

32:5 57:11 67:13 

67:18 

yellowstone 2:13 

2:13 3:2,3 

yield 18:2 

yielded 37:8 

york 2:16,18 

z 

zeolite 49:21 50:2 

zero 6:9 28:7 36:8 

40:20 69:6 

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