Document 9jNDg0d4wV1b1o679ZZO59R6
his use of asbestos as a direct result of the aggressive
elimination of asbestos by a domestic manufacturer, and
thereby gain a price advantage over domestic producers? We
do not believe this is a logical way to regulate.
Our concern is heightened by the cost advantages
currently enjoyed by foreign producers of gaskets. These
cost advantages have been exacerbated by the new OSHA
regulations which are applicable only to domestic producers
and which will require expensive plant modifications. The
EPA proposal threatens to provide even more advantages to the
foreign producers. The U.S. government should do all that it
can to avoid this result.
For all of the above reasons, we support a regulation
based upon product group categories. This regulation should
contain specific dates after which asbestos may not be used
in products manufactured - n- or- imported- into the United
States. This restriction need not apply at the customer or
installer level, since that use will automatically be
eliminated a relatively short time after importation or
manufacturing is halted.
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What should that timetable be? Our companies are
moving to asbestos-free products as rapidly as technology and
competition will permit. To use substitutes prematurely --
before- they are proven safe and effective -- would amount to
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