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.
I am sure that there is no one here who would wish to increase the margin of safety in our dust standards so far beyond the point at which employee health is adequately protected that, as a consequence, we deprive of their means of livelihood the very persons whom we are trying to benefit. This would be an action foolish as it is absurd.
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.
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].
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.
The proposed limit of two fibers...is impossible to meet....The cost of attempting to reach such a low limit would be astronomical and entirely unrealistic....The added expense would definitely force us out of business and would entail the loss of hundreds of jobs.
Past experience would indicate that in a sizable number of operations it will be impossible to reduce the levels to two fibers, no matter how much money is spent. In these cases, the operations obviously would have to be shut down and the men thrown out of work. We have a very rough idea at this time how large a segment of the manufacturing industry would be affected ion this manner, but an estimate of perhaps 15% to 20% seems reasonable.
