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.
One must keep in mind that certain of the above products are consumer oriented....A Warning label would be a substantial and unnecessary deterrent to the sale of these products. Since these products are not hazardous under any conditions, they should not be labeled as such. Their demise would mean the abolition of thousands of jobs at the manufacturing, distribution, contractor, and retailer levels.
The major problem imposed on us by the labeling requirements of the proposed regulation, which imply to the general public an exposure to the risk of asbestosis and cancer. In products ---for example, like ordinary Asbestos-Cement Siding-Shingles --- where the fibers are locked into the cement, it is highly misleading, if not downright dishonest, to scare the homeowner into believing he is exposed to cancer risk.
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.
I urge you and others involved in the preparation of this Standard to avoid hasty decisions that may place unnecessary economic burdens on the companies that will be forced to comply, with the possible ultimate result putting them in a position where they will no longer be able to compete.
As the dust would be ubiquitous, complete vacuum cleaning of a posted construction would be a daily occurrence. This monstrous task would be a nightmare and totally unfeasible. Alternately, enclosures to capture dust are equally unfeasible.
