The proposed limit of two fibers...is impossible to meet....The cost of attempting to reach such a low limit would be astronomical and entirely unrealistic....The added expense would definitely force us out of business and would entail the loss of hundreds of jobs.
Past experience would indicate that in a sizable number of operations it will be impossible to reduce the levels to two fibers, no matter how much money is spent. In these cases, the operations obviously would have to be shut down and the men thrown out of work. We have a very rough idea at this time how large a segment of the manufacturing industry would be affected ion this manner, but an estimate of perhaps 15% to 20% seems reasonable.
Such a label would surely spell the demise of a number of major product lines of the industry....there is no doubt that our competitors will attempt to take advantage of the situation by encouraging the public to avoid asbestos-containing products because of the potential health hazards implied in the warning label, even though to the customer no such hazard exists.
The labels prescribed...are not needed for most asbestos-containing products since the asbestos fibers are “locked in” and cannot be released into the air.
We are concerned, not only about the substantial loss of business to us, but also the loss of jobs among thousands of mechanics who install such products.
There is no evidence that ingestion of asbestos fiber is any way harmful.
A two fiber standard would require that GAF reconsider the economic feasibility of continued operation....These plants provide the livelihood for more than 4,000 employees. There is little, if any, medical evidence to support a two fiber standard.
One must keep in mind that certain of the above products are consumer oriented....A Warning label would be a substantial and unnecessary deterrent to the sale of these products. Since these products are not hazardous under any conditions, they should not be labeled as such. Their demise would mean the abolition of thousands of jobs at the manufacturing, distribution, contractor, and retailer levels.
The major problem imposed on us by the labeling requirements of the proposed regulation, which imply to the general public an exposure to the risk of asbestosis and cancer. In products ---for example, like ordinary Asbestos-Cement Siding-Shingles --- where the fibers are locked into the cement, it is highly misleading, if not downright dishonest, to scare the homeowner into believing he is exposed to cancer risk.
We have also removed the reference to cancer in the warning sign. Before using such scare tactics in the workplace, we feel much more should be known about the relationship between cancer and asbestos than is known at present.
