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.
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.
