The [vinyl chloride standard would be the] tip of an enormous regulatory iceberg….If government allows workers to be exposed to the gas, some of them may die. If it eliminates all exposure a valuable industry may disappear.
It is the firm opinion of technical experts in our engineering and production departments that we could not continue to operate our plants and contemporaneously meet the proposed OSHA standard of ‘no detectable level’ of vinyl chloride.
[M]uch of the scientific data obtained by researchers to date is inconclusive….misplaced reliance on mere suspicions rather than proven data, or precipitous and emotional reaction to such incomplete information…could lead to major economic consequences.
[N]one [of our members] could operate if the NIOSH [vinyl chloride] Work Standard were imposed upon the industry.
[Anything beneath the level of 50 parts per million parts per million (ppm) is] uneconomic and all but impossible to meet...[it would be] simply a requirement for liquidation of a major industry.
Such a tax inevitably discourages capital investment that is so important for the development of new energy resources. There is a definite psychological effect on investors who know that any success will be subject to a tax that could consume almost the entire profit.
[I]f GM is forced to introduce catalytic converter systems across-the-board on 1975 models . . . [i]t is conceivable that complete stoppage of the entire production (system) could occur, with the obvious tremendous loss to the company, shareholders, employees, suppliers and communities.
To destroy or seriously cripple the asbestos industry in this country through hastily developed or unnecessarily severe regulations will benefit neither the employee, the industry, nor the country as a whole, and could quite possibly have serious economic, social, and other consequences both now and in the future.
At this time we have no figures on the two fiver fiber level, if it can be in fact accomplished. These costs may keep us from being able to operate, but if they didn’t, labeling, as proposed, would surely put us out of business anyway.
We firmly believe that if we are required to label our pipe as has been proposed, we will be unable to sell our product and would be out of business within two years.
