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.
To destroy or seriously cripple the asbestos industry in this country through hastily developed or unnecessarily severe regulations will benefit neither the employee, the industry, nor the country as a whole, and could quite possibly have serious economic, social, and other consequences both now and in the future.
Any such warning label we might be required to use in connection with our products containing five percent or more asbestos content by weight would be unnecessary, inappropriate, ineffective and potentially damaging to the sales of the products and thus to the job security of employees engaged in their production.
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.
There will no doubt be cases where the technology is available to reduce levels to two fibers, but where the cost involved would make a particular product line either no longer profitable or no longer competitive on the open market....In these cases, the plant or manufacturing operation would also be shut down.
