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.
The major component in many of these products is not asbestos. Paints and plastics contain less than 127 percent asbestos by weight, asbestos cement products less than 25%...
Let me state, first, that achievement of a standard of 2 fibers per cc is not, at the present time, technically feasible in all areas of our manufacturing operations. Thus, I cannot estimate fully the total final economic impact on our business, or the total final capital investment required.
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.
Minimally, these actions would generate costs incalculable, yet STAGGERING [format from original].
