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.
The proposed regulations would also produce a loss in sales of at least $400 million because of the labeling requirements and the shut down of operations where two fibers [are] technologically unfeasible. A number of companies have already indicated that they do not believe a two-fiber standard is feasible in many operations, and that if such a standard is promulgated, they will close down those operations immediately rather than spend millions of dollars in a vain attempt to achieve the unachievable. The loss of jobs will be substantial.
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 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.
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.