It is the firm opinion of technical experts in our engineering and production departments that we could not continue to operate our plants and contemporaneously meet the proposed OSHA standard of ‘no detectable level’ of vinyl chloride.
[M]uch of the scientific data obtained by researchers to date is inconclusive….misplaced reliance on mere suspicions rather than proven data, or precipitous and emotional reaction to such incomplete information…could lead to major economic consequences.
[N]one [of our members] could operate if the NIOSH [vinyl chloride] Work Standard were imposed upon the industry.
[Anything beneath the level of 50 parts per million parts per million (ppm) is] uneconomic and all but impossible to meet...[it would be] simply a requirement for liquidation of a major industry.
Rulemaking should not be based on conditions that existed in the past, but should be based on conditions as they exist now...we believe a temporary emergency standard would result in polarization rather than constructive definition of areas of concern and constructive problem solving.
It could be read to require the Secretary to ban all occupations in which there remains some risk of injury, impaired health, or life expectancy…the present criteria could, if literally applied, close every business in this nation.
[The strong Democratic bill will] bring about conditions in the business community which will be chaotic…and could bring about a breakdown between government and those in labor and management with which it deals.
I believe that Congress and the people must realize that if this bill…is passed, we are direct[ing] attention to less than 10 percent of the safety problems in the country….From my own personal experience and evaluation of available statistics, the basic cause (85% to 95%) of occupational injuries is some type of ‘people failure.’ Inadequate equipment or facilities accounts for a very small percent of the total injuries experienced….‘people failure’ cannot be eliminated by legislation.
Under the [Democratic] bill, according to the [Chamber], ‘employers would be treated worse than criminals,’ and there would be ‘penalties on the innocent’
The industry representatives also object to a requirement in [the Democratic] bill that employers provide ‘a place of employment which is safe and healthful’ as being ‘vague and undefined’ and possibly unconstitutional.
