Tremolitic Tergiversation or Ex-PIRG-Gation?

My first encounter with the Public Interest Research Group (PIRG) was as an undergraduate when my college mandated that part of the student activity fee went to New Jersey PIRG. The college administration gave students no choice in the matter.

Upon investigating PIRG’s activities and rhetoric, I found the organization filled with self-aggrandizement, and puffed out with a self-satisfied arrogance. Epistemically, politically, and historically, an organization that declared all its goals to be “in the public interest” was jarring and objectionable, but it was probably just my own idiosyncratic sensitivity.

Many of my fellow students and I protested the forced support for PIRG, and ultimately the college yielded to the tide of opinion. Students were give a choice to opt out of paying the portion of their fees that went to PIRG.

Almost 50 years later, I still have a healthy skepticism of most self-proclaimed “public interest” groups, including PIRG. And so, my antennae went up upon seeing a New York Times article about a PIRG back-to-school shopping guide, with warnings about hazardous materials in crayons and magic markers. See Niraj Chokshi, “Asbestos in a Crayon, Benzene in a Marker: A School Supply Study’s Toxic Results,” N.Y. Times (Aug. 8, 2018). The hazard lurking in crayons, according to PIRG, was none other than the emperor of all toxic substances: asbestos. The Times dutifully reported that PIRG had found only “trace” tremolite, but the newspaper made no attempt to quantify the amount found; nor did the paper describe the meaninfulness of inhalational exposure from trace amount of tremolite embedded in wax. Instead, the Times reported a worrisome quote: “Tremolite is responsible for many cases of asbestos-related cancer and asbestos diseases, according to the Abramson Cancer Center at the University of Pennsylvania.”

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A thing is a phallic symbol if it is longer than it is wide.” 

Melanie, Safka (1972)

A thing is a fiber if it is three times longer than it is wide.” 

O.S.H.A., 29 C.F.R. § 1910.1001(b) (defining fiber as having a length-to- diameter ratio of at least 3 to 1).

Ergo, all fibers are phallic symbols.

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The New York Times article did link to PIRG’s report, which at least allowed readers to inspect the inculpatory evidence. U.S. PIRG, Safer School Supplies: Shopping Guide: Consumer Guide for Finding Non-Toxic School Supplies (2018). Unfortunately, the PIRG report did not answer crucial questions. There was no quantification of the tremolite asbestos, and there was no discussion of the ability of the tremolite to escape the wax matrix of the crayon, to become airborne, and to be inhaled. The report did cite the methodology used to ascertain the presence of the tremolite (EPA Method: EPA/600/R-93/116). Safer Schools at 5. In Appendix A to the report, the authors showed two microphotographs of tremolite particles, but without any measurement scale. One of the two tremolite particles looks like a cleavage fragment, not a fiber. The other photomicrograph shows something that might be a fiber, but without a scale and a report of the elemental peaks, the reader cannot tell for sure. Safer Schools at 21.

The controversy over the potential health effects of tremolite cleavage fragments has a long history. Compare Robert Reger & W. Keith C. Morgan, “On talc, tremolite, and tergiversation,” 47 Brit. J. Indus. Med. 505 (1990) with Bruce W. Case, “On talc, tremolite, and tergiversation. Ter-gi-ver-sate: 2: to use subterfuges,” 48 Brit. J. Indus. Med. 357 (1991). The regulatory definition of fiber does not distinguish between biologically significant fibers and particles with an aspect ratio greater than three. John Gamble & Graham Gibbs, “An evaluation of the risks of lung cancer and mesothelioma from exposure to amphibole cleavage fragments,” 52 Regulatory Toxicol. & Pharmacol. S154 (2008) (the weight of evidence fully supports a conclusion that non-asbestiform amphiboles do not increase the risk of lung cancer or mesothelioma); Brent L. Finley, Stacey M. Benson & Gary M. Marsh, “Cosmetic talc as a risk factor for pleural mesothelioma: a weight of evidence evaluation of the epidemiology,” 29 Inhalation Toxicol. 179 (2017).

Surely the public interest includes the facts and issues left out by PIRG’s report.



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