U.S. Department of Labor Occupational Safety and Health

Salt Lake Technical Center

Sandy, Utah 84070

Report of Evaluation of Cosmetics and Cosmetic Talc for FDA

Daniel T Crane

23 February 2019

This report is a response to an Agency Technical Assistance Request dated 23 March 2018 

between 

The Office of Cosmetics and Colors (OCAC), Center for Food Safety and Applied Nutrition 

(CFSAN), US Food and Drug Administration (FDA) 

 and 

The Salt Lake Technical Center, Directorate of Technical Support and Emergency Management, 

Occupational Safety and Health Administration (OSHA), US Department of Labor

This report presents data and evaluation of the materials examined. It does not express any 

opinions of OSHA regarding any issues within the purview of the requesting Agency.

Ten different materials were submitted to the Salt Lake Technical Center (SLTC) for evaluation 

for the presence of asbestos. Eight of the samples were commercial cosmetics. Two samples 

were talc from different sources. SLTC was instructed to hold one of the samples back without 

analysis. (Claire’s Highlighting Pallet, 945287). Appendix A contains photos and chemistry of 

each sample. Appendix B documents the samples as received.

The samples were examined by light microscopy, scanning electron microscopy with energy 

dispersive analysis by X-ray, and X-ray diffraction. 

The samples were examined by phase contrast with polarized light illumination (PCM-PLM). 

The test used is standard at the Salt Lake Technical Center for screening talc samples for 

amphibole asbestos.1,2 Samples are mounted in index of refraction liquid n = 1.605 and analyzed 

using central stop dispersion staining (CSDS). Generally, if any fibers are present which have 

indices of refraction above 1.605, the samples are analyzed in scanning electron microscopy 

(SEM) with x-ray energy dispersive analysis (EDX). In this investigation, all samples were 

analyzed by SEM whether or not fibers were present with indices greater than n = 1.605.

Samples were mounted for examination by SEM and analyzed for the presence of fibers. When a 

fiber was found, a chemical spectrum was obtained using EDX to determine the chemistry of the

mineral. Representative fibers were photo-documented. Initially, the samples were not coated 

 1 PCM-PLM analysis procedure given in OSHA Method ID-191 and 29 CFR 1910.1001 Appendix J 2 Screening test outlined in Dixon, W.C., Applications of Optical Microscopy in Analysis of Asbestos and Quartz, 

Analytical Techniques in Occupational Health Chemistry, edited by D.D. Dollberg and A.W. Verstuyft. Wash. D.C.: 

American Chemical Society, (ACS Symposium Series 120) 1980. pp. 13-41.
Page 2 of 24

with a conductive metal (gold) in order that the gold not interfere with the chemical evaluation.

The samples were coated with gold and high-resolution photos were obtained. The SEM images

in Appendix A are of coated samples, except as noted.

Sub-samples of each submitted sample were examined by wide-angle scan using a Cubix Pro 

Panalytical X-ray Diffractometer (XRD) and the data evaluated using Rigaku PDXL software for

best match and also for forced match to actinolite (card 9001922), anthophyllite (card 9016381), 

chrysotile (card 1010960), grunerite (card 9000000), riebeckite (card 9004132), and tremolite 

(card 9003673). In addition to software search, a manual visual search for the presence of the 

highest three tremolite peaks was performed for each of the submitted samples. None of the 

XRD results was positive for the presence of any of these regulated asbestos minerals. 

Table 1 summarizes the results for the 9 analyzed samples.

Appendix C provides definitions. A fiber is an elongate particle, longer than 5 micrometers and 

at least three times longer than it is wide. Minerals fitting this criterion are known as elongate

mineral particles (EMP). 

The second column of Table 1 indicates the presence of elongate mineral particles (EMPs) in the 

sample. The third column of Table 1 indicates if the EMPs have indices greater than n = 1.605. 

These have the potential to be amphibole asbestos. 

Column 1 is the FDA-assigned number and description of material. 

Column 2 indicates whether there are EMPs (possible regulatory fibers) present in the sample 

Column 3 indicates whether the EMPs have a morphology consistent with asbestos. 

Column 4 indicates the presence of fibers in the SEM.

Column 5 indicates if there are fibers with chemistry consistent with a regulated amphibole. 

Column 6 indicates whether or not a regulated mineral was detected by XRD

Column 7 indicates the name of a mineral.
Page 3 of 24

Table 1

1Both tremolite and talc fibers were found 2 Amphibole not seen. EMP present that may be a hornblende. 3 Tremolite was found as well as other unidentified EMP 4 No amphibole found, titanium oxide fibers found. 

5 Tremolite was found as well as possible EMP that may be hornblende 6 PCM-PLM showed amphibole, SEM-EDX did not. 7 Talc fibers found 8 No amphibole found.

All of the samples had fibers present in PLM. 

Samples generally have EMP fibers of multiple minerals.

Samples 761227, 761230, 761231, and 1027488 are positive for elongate particles of tremolite. 

These fibers appear morphologically fibrous, and likely asbestos. No other species of regulated 

mineral were found. 

All of the results by XRD are ND, none detected. The amount of potential regulated fiber in the 

samples as noted by PCM/PLM and SEM/EDS is very small and likely below the limit of 

detection for the XRD, which is generally taken as 1% in practice.

Appendix A contains the photos and chemistry of the samples

Appendix B contains the sample receiving information

Appendix C contains definitions

Appendix D contains preparation and analytical description for PCM and PLM

Appendix E contains preparation and analytical description for SEM and EDS

Sample 

Number

Fibers 

Present in 

PCMPLM

Possible 

amphibole 

fibers 

present in 

PCM-PLM

Fibers 

Present in 

SEM

SEM + EDX 

(chemistry) consistent 

with regulated 

minerals

XRD Regulated asbestos 

name

761227

Eye shadow

Yes Yes Yes Yes (talc fibers also 

noted)1

ND Tremolite asbestos

761228

Love

Yes No Yes No (hornblende, 

other?)2

ND

761230

Compact 

Powder

Yes Yes Yes Yes (other fiber)3 ND Tremolite asbestos

761231

Contour

Yes Yes Yes Yes ND Tremolite asbestos

945288

Shadow & 

Highlight

Yes Yes Yes No (Ti fiber)4 ND

1027488

Just Shine

Yes Yes Yes Yes (other, 

hornblende?)5

ND Tremolite asbestos

1036658

NVF talc

Yes Yes Yes No (talc)6 ND

1036659

NVF Talc

Yes Yes Yes Yes (talc)7 ND

5063618

Ombre

Yes No Yes No (Unidentified 

mineral)8

ND
Appendix A

The following are photos and spectra of the samples. Not every type of photo is provided for 

every sample. Scale bars are included in the light microscopy samples.

Page 4 of 24

761227 

3 

5 

1 

4 

6 

2 

1. Bright Field (PCM) of sample showing a fiber in the center 160X 

2. Central Stop Dispersion Stain of the fiber in figure 1. 160X 

3. Central Stop Dispersion Stain of a fiber bundle. 160X 

4. Crossed polarized light with first order red plate of a fiber in the center 400X 

5. SEM of asbestiform tremolite 21 micrometers x 0.7 micrometers 

6. EDX spectrum of the fiber in 5, consistent with tremolite. 
Appendix A

The following are photos and spectra of the samples. Not every type of photo is provided for 

every sample. Scale bars are included in the light microscopy samples.

Page 5 of 24

761228 

5 

3 

1 

4 

6 

2 

1. Bright Field (PCM) of sample showing a fiber in the center 160X

2. Bright Field (PCM) of sample showing a fiber in the center 160X 

3. SEM of non-asbestiform, non-regulated EMP (uncoated with gold) 

4. EDX showing Mg, Al, Si, Ti, Ca Not consistent with regulated mineral

5. SEM of non-asbestiform, non-regulated EMP. (uncoated with gold) 

6. EDX showing Mg, Al, Si, Ti, Ca Not consistent with regulated mineral. 

Morphology and chemistry are consistent with organic (plant) fiber. 
Appendix A

The following are photos and spectra of the samples. Not every type of photo is provided for 

every sample. Scale bars are included in the light microscopy samples.

761230 

Page 6 of 24

3 

1 

4 

6 

2 

5 

1. PCM-PLM at 400X With several EMPs visible.

2. PCM-PLM with the microscope stage rotated 90o. Note that fibers in photo 1 which 

appear yellow, appear blue in photo 2 and vice-versa.

3. Bright Field (PCM) 160Xshowing several fibers. 

4. Field of Photo 3 in CSDS showing fibers with indices greater than n=1.605 (yellow) 

5. SEM photograph of tremolite fiber at 3000X. 23 micrometers x 0.7 micrometers.

6. EDX spectrum of top fiber in Photo 5. It is consistent with tremolite. 
Appendix A

The following are photos and spectra of the samples. Not every type of photo is provided for 

every sample. Scale bars are included in the light microscopy samples.

761231

Page 7 of 24

5 

3 

1 

4 

6 

2 

1. Bright Field (PCM) 160Xshowing several fibers 

2. Field of Photo 1 in CSDS showing fibers with indices greater than n=1.605 

(yellow)

3. Bright Field (PCM) 160Xshowing a long fiber. 

4. Field of Photo 3 in CSDS showing fibers with indices greater than n=1.605 

(yellow)

5. SEM of asbestiform tremolite. 700X. 109 micrometers x 0.4 micrometers. 

6. EDX spectrum of the fiber in 5, consistent with tremolite. 
Appendix A

The following are photos and spectra of the samples. Not every type of photo is provided for 

every sample. Scale bars are included in the light microscopy samples.

945288 

Page 8 of 24

5 

3 

1 

4 

6 

2 

1. Bright Field (PCM) 160Xshowing several fibers 400X 

2. PCM-PLM of fiber in Photo 1 160X 

3. CSDS of fiber in Photo 1 showing index greater than n=1.605 

4. CSDS of fiber rotated 90o to Photo 1 showing index greater than n=1.605 

5. SEM of typical fiber

6. EDX of the long fiber in Photo 5 showing K with Al and Si. Not a regulated 

mineral.
Appendix A

The following are photos and spectra of the samples. Not every type of photo is provided for 

every sample. Scale bars are included in the light microscopy samples.

1027488

Page 9 of 24

5 

3 

1 

4 

6 

2 

1. PCM-PLM of EMP at 400X

2. CSDS of fiber in Photo 1 showing index of refraction greater than n=1.605

3. SEM of tremolite fiber3000X 17.3 micrometers x 1.8 micrometers.

4. EDX of the tremolite fiber in Photo 3 

5. SEM of tremolite fiber 5000 X 14.5 micrometers x 0.9 micrometers. 

6. EDX spectra of the fiber in 5.
Appendix A

The following are photos and spectra of the samples. Not every type of photo is provided for 

every sample. Scale bars are included in the light microscopy samples.

1036658 

Page 10 of 24

3 

1 

4 

2 

1. Bright Field PCM at 160X 

2. Bright Field PCM at 160X organic (plant) fiber 

3. SEM Elongate particle

4. EDX of particle in Photo 3. The particle is talc.
Appendix A

The following are photos and spectra of the samples. Not every type of photo is provided for 

every sample. Scale bars are included in the light microscopy samples.

1036659 

Page 11 of 24

5 

3 

1 

4 

6 

2 

1. Bright Field PCM 400X asbestiform 

2. PCM-PLM 400X same fiber as photo 1 

3. CSDS of fiber 160X index greater than n=1.605 

4. CSDS of fiber 160X index greater than n=1/605 

5. SEM of EMP

6. EDX of fiber in Photo 5. The particle is talc. 
Appendix A

The following are photos and spectra of the samples. Not every type of photo is provided for 

every sample. Scale bars are included in the light microscopy samples.

5063618

Page 12 of 24

5 

3 

1 

4 

6 

2 

1. Bright Field PCM 160X some EMP 

2. Bright Field PCM 400X some EMP 

3. SEM EMP, foliar morphology, (uncoated with gold) 

4. EDX of particle in Photo 3. NOT regulated mineral 

5. SEM EMP, foliar morphology, (uncoated with gold) 

6. EDX of particle in Photo 5. NOT regulated mineral 
Appendix B -- Receipt of Samples

Page 13 of 24

Firm Name Product Description Shipping Information and Sample 

Identification

Claire's

761227

Eye shadow pallet SKU84716 UPS 1ZA49E154493007077

INV 761227 

(rcd. 30 March 2018)

(14 boxes)

Claire's

761228

Love labeled box of mixed product 

SKU33411

UPS 1ZA49E154492098463

INV 761228

(rcd. 30 March 2018)

(12 boxes with 2 units each)

Claire’s 

761230

Compact Powder UPS 1Z A49E150196670130

761230

(rcd 10 May 2018)

(24 units)

Claire’s

761231

Contour UPS 1ZA49E150196670130

761231

(RCD 10 May 2018)

(24 units)

Claire’s

945288

Shadow & Highlight UPS 1ZA49E150196670130

945288

(RCD 10 May 2018)

(27 units)

Tween Brands

1027488 

JUSTICE JUST SHINE SHIMMER 

POWDER 

UPS 1Z2R3A560107281092

1027488 

(rcd. 30 March 2018)

(6 units)

Beauty Plus

5063618

CITY COLORS SHIMMER OMBRE 

HIGHLIGHT PINK OPAL C-0025A 

(SK-17061A)

UPS 1Z2R3A560107281092

1030370 

(rcd. 20 March 2018)

(6 boxes with 2 units each)

1036658

NVF talc

FDA sample and sampling 

equipment

UPS 1ZA4744W8591420444

(rcd 27 March 2018)

2 bottles and assorted implements

1036659

NVF talc

FDA sample and sampling 

equipment

UPS 1ZA4744W8591420444

(rcd 27 March 2018)

2 bottles and assorted implements

Claire's

945287

NOT ANALYZED 

PER FDA 

REQUEST

Highlight

Highlighting Palette

UPC 61960-1 

UPS 1ZA49E154494870454

INV 945287

(rcd. 30 March 2018)

(26 boxes with 2 units each)
Appendix B -- Receipt of Samples

Page 14 of 24

Sample INV 761227 was received in a single box Salt Lake Technical Center on 30 March 2018. 

Sample INV 761227 consisted of 14 boxes (units).
Appendix B -- Receipt of Samples

Page 15 of 24

Sample 761228 was received in a single box Salt Lake Technical Center on 30 March 2018. 

Sample 761228 consisted of 12 boxes with 2 units each. 
Appendix B -- Receipt of Samples

Page 16 of 24

Sample 761230, 761231 and 945288 were received in a single box Salt Lake Technical Center 

5on 30 March 2018. Sample 761230 consisted of 24 units, sample 761231 consisted of 24 units 

and sample 9455288 consisted of 27 units. 

 

 761230 761231
Appendix B -- Receipt of Samples

Page 17 of 24

 945288
Appendix B -- Receipt of Samples

Page 18 of 24

Samples 1027488 and 1030370 were received in a single box at the Salt Lake Technical Center 

on 20 March 2018. Sample 1027488 consisted of 6 units. Sample 1030370 consisted of 6 boxes 

with 2 units each
Appendix B -- Receipt of Samples

Samples 1036658 and 1036659 were received in a single box. Each consisted of two glass bottles 

of white powder and a bag containing sampling implements. The sampling implements were set 

aside and have not been analyzed. 

Page 19 of 24

 

Note: Sampling implements not shown.
Appendix B -- Receipt of Samples

Page 20 of 24

Sample INV 945287 was received in a single box Salt Lake Technical Center on 30 March 2018. 

Sample INV 945287 consisted of 26 boxes with 2 units each. 
Appendix C -- Definitions for Regulated Asbestos

Page 21 of 24

In order to avoid any confusion, the following nomenclature is used. This is based upon the 

definitions that have been established by regulation and litigation.3, 4

Asbestos includes only the minerals chrysotile, Amosite, crocidolite, tremolite asbestos, 

anthophyllite asbestos, and actinolite asbestos.

5 An asbestos mineral has a fibrous growth habit. 

Asbestiform The term “asbestiform” is not a growth habit. It is a description of a mineral which 

has a fibrous growth habit. The growth habit used in mineralogy is “fiber.” Individual fibers of 

asbestos are held together by Van der Waals forces rather than ionic or covalent bonds.

“It (asbestiform) is an inherent, fine-textured morphology in a mineral. Resulting from 

unequal relative development of the principle crystal faces, which ideally produces a 

predominant release of strong, flexible fibers having (1) microscopic to submicroscopic 

diameter and (2) and aspect ratio often exceeding 20:1, when the mineral is subjected to 

comminution.”6

Fibrous is a mineralogical term for growth habit for crystals that are composed of long thin 

fibers. In mineralogy, there is no fixed aspect ratio (length to width ratio) that defines a fiber. 

Commonly used aspect ratios are 3:1, 5:1, 10:1, 20:1 and 100:1 depending upon use. In 

regulation, a 3:1 aspect ratio is established by regulation and case law.

A regulatory fiber is a fiber of asbestos

1. Having an aspect ratio greater than or equal to 3:1

2. Longer than or equal to 5 micrometers

3. Visible in a phase contrast microscope (PCM)

A fibril is a single crystal of an asbestiform mineral. A fibril, is, by definition, a fiber. Fibrils 

nominally have diameters of about 50 nm for chrysotile and about 100 nm for amphiboles

(depending upon the species and growth conditions.).

A bundle is an assembly of fibrils and is usually considered to be a fiber.

A matrix is a matted mass of fibers, considered a regulatory fiber if one or more fibers extends 5 

micrometers from the mass. (In the TEM, a matrix is considered equivalent to one fiber)

Elongate particle (EMP) is a particle with an aspect ratio generally longer than 3:1 regardless 

of whether it is fibrous or is elongate due to comminution (grinding).

Growth habit Crystal habit is the tendency for specimens of a mineral to repeatedly grow into 

characteristic shapes.7

 3 Secretary of Labor v Borg Warner, OSHRC Docket No. 10757, 22 February 1978 4 29 CFR 1910.1001 and others, Occupational Safety and Health Administration, 

5 29 CFR 1910.1001 (b) definitions 

6 Definitions for Asbestos and other Health-related silicates, Levadie, B., ASTM STP834, 1982 7 https://geology.com/minerals/crystal-habit/
Appendix D

PCM-PLM-Dispersion Staining Go/No-Go Test for Amphibole Fibers in Talc

Page 22 of 24

The PCM-PLM Dispersion Staining Go/No-Go test is used as a screening test to determine 

whether or not amphibole fibers are present in powdered samples of talc. 

A sample is examined using a polarizing phase-contrast microscope (PCM-PLM) at 400X and 

160X magnifications. Any fibers meeting the federal definition for asbestos will be visible 

because of the use of PCM. Fibers with diameters greater than 0.5 to 1 micrometer may be 

examined for the presence of retardation colors. If there are any visible fibers, they are examined

using central stop dispersion staining (CSDS) using the same microscope. 

A preparation of powdered sample is made in high-dispersion refractive index liquid with n = 

1.605. The observable indices of refraction of all of the regulated amphiboles are greater than 

1.605, while the indices of refraction for talc is less than n = 1.605. 

Because of this, the central-stop dispersion staining (CSDS) colors observed for amphiboles will 

indicate that the particle indices are greater than the index of the liquid. Generally, this will be 

yellow orange to yellow, or yellow-white. Talc, brucite and chrysotile fibers will be blue to bluewhite. 

If there are no fibers with CSDS colors indicative of possible amphibole present (e.g. yellow to 

yellow white) then it is unlikely that any amphibole asbestos is present.

When fibers are visible that have CSDS colors indicating indices greater than n = 1.605, further 

examination in matching liquids as well as other measurements are required to identify the 

amphibole. 

The index of refraction liquid n = 1.605 is not a matching liquid for talc or any amphibole and is 

insufficient to identify any of the regulated minerals.

The samples submitted for this investigation were either packed powder or loose powder. All 

were apparently dry with no apparent wetness, equilibrated to the local humidity.

For this examination, no gravimetric reduction was performed. (e.g. the samples were not 

subjected to acid, heat or chemicals designed to remove unwanted substances, and examined as 

received.). 

Samples were prepared individually in a table-top laboratory hood, and all instruments and 

horizontal surfaces were cleaned in between samples. This is a measure to prevent crosscontamination between the samples.

At least three separate slide preparations were made and examined for each of the samples. 

1. Two to three drops of high dispersion index of refraction liquid are allowed to drop by 

gravity onto the surface of a cleaned 1 x 3 in. glass slide.

2. A clean dissecting needle is used as a sampling probe. The tip is wetted in the index of 

refraction liquid on the slide and then dipped into the sample. A small amount of powder 
Appendix D

PCM-PLM-Dispersion Staining Go/No-Go Test for Amphibole Fibers in Talc

Page 23 of 24

clings to the dissection needle. The amount is determined by the diameter of the captured 

powder clump and is usually less than a 0.5 mm.

3. The dissection needle with the powder is introduced into the liquid on the slide and 

stirred gently to disperse the powder as evenly as possible.

4. A clean, No 1 1⁄2 glass cover slip is gently lowered onto the liquid. 

NOTE 1: The amount of index of refraction liquid placed on the slide in step 1 is 

determined by experience such that little to no liquid extends beyond the boundary of the 

cover slip.

NOTE 2: If the preparation is cloudy, it indicates that too much powder was on the 

dissection needle when the powder was sampled. Discard this preparation and perform 

steps 1 to 4 using a smaller amount of powder until a suitable preparation is made. Too 

much powder in the preparation will interfere with the optical tests. These tests generally 

depend on particles being dispersed in the liquid sufficiently far apart so that their images 

do not interfere with one another.

Examination

A phase contrast microscope which also has crossed polarizing elements and a first-order red 

compensator is used to examine the samples. (See OSHA ID-191 for a full description of PCMPLM examination.)

A slide preparation is placed on the microscope stage and examined at 160X and 400X. (The 

sample may also be examined at 100X if the microscope is equipped for PCM at 100X. In this 

particular investigation, little use was made of the 100X magnification because the particles were 

very finely divided.)

An initial scan of the slide is made at 160X and 400X to note the presence of any elongate 

particles. The morphology of any observed elongate particle is evaluated whether it is, organic, 

synthetic or mineral, and if mineral, consistent with asbestiform growth habit or other growth 

habit. Any observed fiber is evaluated for the presence of birefringence observed as retardation

colors. 

Any mineral fibers are examined at 160X using CSDS. If the colors observed indicate that the 

fiber may be amphibole, further analysis of the sample is indicated. The sample prep is scanned 

at 160X to determine if any amphibole source mineral is present.
Appendix E

Preparation and Analysis of Samples by Scanning Electron Microscopy and X-ray Energy 

Dispersion

Page 24 of 24

The samples were examined by scanning electron microscopy (SEM) and x-ray energy 

dispersive analysis (EDX). In combination, SEM and EDX provide visual evidence of the 

morphology of the fibers and a semi-quantitative measure of which elements are present in 

individual particles.

The SEM uses a beam of electrons accelerated to a high voltage focused to a point and scanned 

across the surface of the sample. Secondary electrons generated when the beam strikes the 

sample are used to form a dimensional image of the surface of the sample. At each point where 

the primary electron beam strikes the sample, x-rays are generated which have energies 

characteristic of the elements at that location. These x-rays are captured, and the energies 

analyzed to provide a spectrum representing the elements present in the particle.

Samples for SEM are made by applying a very small amount of powder on a spectrometrically 

pure carbon adhesive surface on a carbon SEM mount. The powder is smeared onto the surface 

in a very sparse layer to provide adequate separation between the particles. If the particles are too 

close, the analytical signal may be affected by other particles nearby.

For high resolution images, conductive coatings are evaporated or sputtered onto SEM samples 

to render the surface sufficiently conductive electrically that the surface cannot build up a surface 

charge and degrade the image. 

In the first analytical trial, the samples were examined in the SEM without any conductive 

coating. This was to obtain particle spectra free of any interference from the conductive metal. 

However, images obtained without a metal coating do not have the resolution necessary to reveal 

the fine structure of the surfaces of non-conductive particles. During the analysis, it was noted 

that there were no elements intrinsic to the particulate present in the cosmetics that preclude the 

use of gold as a coating metal.

A second analytical trial looked at selected samples which have been coated with sputtered gold 

to a thickness of 5 to 10 Å (0.5 to 1 nm). This thickness is less than the analytical resolution of 

the SEM, but sufficient to provide a conductive surface and thereby a better evaluation of the 

morphology of the fibers. 

The SEM used for this is a Hitachi S-3500 VP. It was operated in high vacuum mode at and 

acceleration voltage of 25kV and a working distance of 10mm. A variety of magnifications were 

used as noted on the photographs. Magnifications greater than about 2,000X were not usable for 

uncoated samples. Gold coating is necessary for higher magnification evaluation. 

The surface of the samples were scanned at between 500 and 1000X to find any fibers. When 

found, the electron beam is focused on a single spot on the fiber and an EDX spectrum is 

collected and a determination as to the possible identification of the mineral. Fibers are photodocumented as well as a corresponding EDX spectrum.