Today’s competitive markets, whether we seek to recognise it or not, are driven by an international version of Adam Smith’s "invisible hand” that is unredeemably opaque. With notably rare exceptions (2008, for example), the global “invisible hand” has created relatively stable exchange rates, interest rates, prices, and wage rates.
I think you cannot write a law for every extreme situation. We just have to write the best law we can that has common sense in it.
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.
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].
Such a label would surely spell the demise of a number of major product lines of the industry....there is no doubt that our competitors will attempt to take advantage of the situation by encouraging the public to avoid asbestos-containing products because of the potential health hazards implied in the warning label, even though to the customer no such hazard exists.
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.
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%...
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.
