The [vinyl chloride standard would be the] tip of an enormous regulatory iceberg….If government allows workers to be exposed to the gas, some of them may die. If it eliminates all exposure a valuable industry may disappear.
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.
Such a tax inevitably discourages capital investment that is so important for the development of new energy resources. There is a definite psychological effect on investors who know that any success will be subject to a tax that could consume almost the entire profit.
[I]f GM is forced to introduce catalytic converter systems across-the-board on 1975 models . . . [i]t is conceivable that complete stoppage of the entire production (system) could occur, with the obvious tremendous loss to the company, shareholders, employees, suppliers and communities.
We firmly believe that if we are required to label our pipe as has been proposed, we will be unable to sell our product and would be out of business within two years.
In summary, then, the proposed regulation could have a very serious adverse impact on my company, an impact which cannot be justified by any demonstrable benefit to our employees, to the employees of our customers, or to the general public.
If these label requirements are adopted in their proposed form, they will in our opinion destroy large amounts of the industry and eliminate thousands of jobs. and they will do this without any significant evidence that the proposed types of labels are necessary.
