Document 7RQgk7qK3Vo38650xVQd5zO9j

PLAINTIFF'S EXHIBIT GF-996 ,0 ,,) A- M MlNTte mu 9 . INTEROFFICE CORRESPONDENCE ' QAf CllMwnon to location location w. Fassuliotis New York T. F. Gedettis Bound Brook VV - ,!HN ? oatc 6 January 1976 : Dr. N. P. Klaas Mr. F. E. Wetherill wtJier ECONOMIC IMPACT OF PROPOSED ASBESTOS STANDARDS ,\ In reviewing the draft of the report of the Asbestos Standard Task Force, I am somewhat concerned that the required investment at " Erie 16th ^thhv k* >yp the low side. The proposed pe ran sable exposure level of 0.5 fibers/cc is extremely low. It has fceeik By ... experience, in other areas of dust collection, that the letter the l.*:' limit becomes, the higher the capital investment following -the law*._ of diminishing returns. It is my concern that as the major areas are brought under-contfol*.''-and meet permissable exposure levels, it will become apparent that other areas will also need dust control. I do not have the initial dust count reports and it could be that some other job classifications, that are not routinely sampled, may require rpiinftinn of exposure levels. , The increased cost resulting from the new lowepda standard would . have only minimal effect on the Erie 16th Street operation. The 1 total annual cost increase, both for depreciation and for increased I , operating costs, is in the neighborhood of 140.600 per year. This results in about aj^.no pr ton increase on a product that has an ____ average standard cost of over $300.0(L This resulting ,6/10 oL.14 w cost increment should not have any adverse effect on tne operation of the plant. Although these costs cannot be absorbed, I am sure they ^o^d^jb*L myjjogUpn within the marketplace. I mighf jIlSjSCoi^^^^ cost increase is negligible compared to the raw liateMw^Q^elj&s that we are experiencing. I d<Cnoa i?W'*>7&*]btitute materials that could be used for asbes tos in our products,"although some may exist. It is questionable that a comparable product could be made without the use of asbestos. At present, a substitute for asbestos roofing felt is available in the form of glass matt. As I understand it. the cost iff somewhat higher tnan tne asbestos paper but there is a continuing increase in the use of this material for roofing. '~ MICH08278 2- SUBJECT: ECONOMIC IMPACT OF PROPOSED ASBESTOS STANDARDS With the type of products we are producing, I do not believe that the . end user would have difficulty meeting exposure levels so I would not l anticipate a declining market for that reason. * In general, I feel that the additional costs would have very little effect on the Erie 16th Street operation either directly or through a declining market. T. F. Gedettis des MICH08279