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.
I urge you and others involved in the preparation of this Standard to avoid hasty decisions that may place unnecessary economic burdens on the companies that will be forced to comply, with the possible ultimate result putting them in a position where they will no longer be able to compete.
As the dust would be ubiquitous, complete vacuum cleaning of a posted construction would be a daily occurrence. This monstrous task would be a nightmare and totally unfeasible. Alternately, enclosures to capture dust are equally unfeasible.
Minimally, these actions would generate costs incalculable, yet STAGGERING [format from original].
The people in this room have the same amount of lead in their blood as do the natives in New Guinea. If you take lead out of the air, you’ll still have it in your body.
You could wake up with egg on your face if you force a double cost on the consumer.
There is no evidence that lead in the atmosphere, from autos or any other source, poses a health hazard.
