The Long Road to Updating Asbestos in Talc Analytical Testing Protocols

The relationship between the asbestos-forming minerals and talc has been well recognized in the mineralogic community for over 150 years. Concern over the potential for asbestos in talc products rose close on the heels of the first testing proving negative human health effects of asbestos exposure, with asbestos being found in consumer talcum products in the 60s, 70s, and sporadically throughout the last 50 years, generally ignored as an inconvenient truth. Unfortunately, we were never able to codify a method to assure that asbestos fibers, that causation experts inform us poses a real danger, are absent from talc and talc-based products. Although slowed through the pandemic, reactions to relatively recent findings of asbestos in talc and talcum-based products have blossomed into an apparent blitz of new information and political saber-rattling, including special meetings sponsored by regulatory bodies such as the FDA, congressional sub-committee meetings in Washington, DC, and even international government meetings and forums throughout Europe and beyond. Partly as a result of the USA pushing forward with thousands of legal actions, testing in the United States of talc-containing cosmetics has led the charge through public outcry toward revision of analytical standards. This paper will outline this historical trail, which has recently come to a significant milestone. In a new law signed by President Biden that went into effect January: The Consolidated Appropriations Act, 2023, mandates that the US FDA must promulgate regulations that establish and require standardized testing methods to be used to detect asbestos in talc -containing cosmetics, no later than one year after enactment (by end of calendar year 2023). How we have historically tested talc for asbestos and latest methods will be discussed. Along with more familiar air, dust, water, and bulk methods, more arcane techniques such as Addison-Davies reduction and Blount liquid separation (HLS) shall be discussed as to their effectiveness to accurately determine tremolite-actinolite, anthophyllite, other amphiboles, and serpentine asbestos occurrence in sheet silicate mineral resources such as talc.