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.
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.
We have also removed the reference to cancer in the warning sign. Before using such scare tactics in the workplace, we feel much more should be known about the relationship between cancer and asbestos than is known at present.
The major component in many of these products is not asbestos. Paints and plastics contain less than 127 percent asbestos by weight, asbestos cement products less than 25%...
Let me state, first, that achievement of a standard of 2 fibers per cc is not, at the present time, technically feasible in all areas of our manufacturing operations. Thus, I cannot estimate fully the total final economic impact on our business, or the total final capital investment required.
If there is no danger of the airborne concentrations exceeding those provided in Section (a) of the standard, we feel that there should be no need to alarm employees with inflammatory arid suggestive signs. Industry would be opened up to hazard pay and workman’s compensation claims, even though no special care or protection is required in the workplace.
In our opinion, an incalculable and insupportable cost would be required to reduce emissions to the [two] fiber level....it would take considerably more than two years to attain such levels if in fact, they could be reached at all.
The labels prescribed...are not needed for most asbestos-containing products since the asbestos fibers are “locked in” and cannot be released into the air.
We are concerned, not only about the substantial loss of business to us, but also the loss of jobs among thousands of mechanics who install such products.
