Achieving a standard of [5 fibers] will cost millions of dollars and cause a significant number of American jobs to be shifted to foreign workers. Requiring a more stringent standard and requiring unnecessarily frightening labels can have a catastrophic effects on the very people OSHA’s and the industry are attempting to protect, without really solving the human problem.
With no scientifically credible evidence to prove the need for such a low standard of 2 fibers per cc, it would be nothing less than complete social irresponsibility [to issue this standard].
At this time we have no figures on the two fiver fiber level, if it can be in fact accomplished. These costs may keep us from being able to operate, but if they didn’t, labeling, as proposed, would surely put us out of business anyway.
To do more would constitute an unreasonable use of the police power and would result in an unjustifiable deprivation of property....without fair compensation.
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.
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.
To the extent that it makes the manufacture of asbestos materials in the United States technologically unfeasible or uneconomic, it will force the purchase abroad of products for which there is no-asbestos substitute, with consequential losses in profit, increases in unemployment, and deterioration in the nation’s balance of payments.
Such a label would surely spell the demise of a number of major product lines of the industry....there is no doubt that our competitors will attempt to take advantage of the situation by encouraging the public to avoid asbestos-containing products because of the potential health hazards implied in the warning label, even though to the customer no such hazard exists.
The proposed regulations would also produce a loss in sales of at least $400 million because of the labeling requirements and the shut down of operations where two fibers [are] technologically unfeasible. A number of companies have already indicated that they do not believe a two-fiber standard is feasible in many operations, and that if such a standard is promulgated, they will close down those operations immediately rather than spend millions of dollars in a vain attempt to achieve the unachievable. The loss of jobs will be substantial.
Trying to put a handle on the potential number of lost jobs is extremely difficult....Perhaps 15 to 30 thousand is about as close as we can come at this time.
