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.
Achieving a standard of [5 fibers] will cost millions of dollars and cause a significant number of American jobs to be shifted to foreign workers. Requiring a more stringent standard and requiring unnecessarily frightening labels can have a catastrophic effects on the very people OSHA’s and the industry are attempting to protect, without really solving the human problem.
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].
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.
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.
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.
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.
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.
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.
