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.
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.
There is no evidence that ingestion of asbestos fiber is any way harmful.
A two fiber standard would require that GAF reconsider the economic feasibility of continued operation....These plants provide the livelihood for more than 4,000 employees. There is little, if any, medical evidence to support a two fiber standard.
