Comments to the FDA on Testing Methods for Asbestos in Talc and Cosmetic Products Containing Talc

The letter from the U.S. Chamber Institute for Legal Reform (ILR) responds to proposed recommendations issued by the Food and Drug Administration (FDA)'s interagency working group on asbestos testing in talc-containing products. ILR argues that the recommendations improperly treat asbestos and certain non-asbestos mineral particles known as cleavage fragments as equivalent for testing purposes, despite longstanding scientific and regulatory distinctions between the two. The letter contends that the working group's approach lacks adequate scientific support and overlooks research and regulatory findings indicating that non-asbestiform mineral particles do not pose the same health risks as asbestos. 

ILR further warns that adopting the recommendations could have far-reaching consequences for industries that rely on talc and other minerals, including cosmetics, pharmaceuticals, food products, plastics, automotive components, and manufacturing. The letter urges the FDA to withdraw the recommendations and subject any future proposals to a formal rulemaking process that includes public notice, stakeholder input, and a more comprehensive review of the scientific evidence. According to ILR, a transparent, science-based regulatory approach is necessary to avoid unwarranted economic disruption while ensuring that legitimate health concerns are addressed appropriately.