Document MxJoKq0Gq0n0Z7QLOwjX9vVM

NU8B-BB06789 Excerpt from "Technological Feasibility sod Economic Impact of OSHA Proposed Revision to the Asbestos Stsnderd" prepared by WESTON Environmental Consultants. With verification still required in the secondary and con sumer segments of the industry, it now is possible to conclude: 2=3 1. That it is not technically feasible for any segment of g the asbestos industry to meet a 0.5 fiber per cc (TWA) exposure .--ij level. " 2. That the primary producers can, at substantial cost, within three to five years meet the 2 fibers per cc (TffA) standard. 3. That large portions of the secondary and consumer segments of the industry cannot economically (and perhaps cannot techno logically) meet the 2 fibers per cc (TWA) standard without the option of using personal protection as their primary mode of compliance, particularly when they must shoulder the pass-through costs of "best available technology" (BAT) in the primary sector. 4. That the enforcement, without exceptions, within the secondary and consumer segments of the industry, of the July 1, 1976, 2 fibers per cc (TWA) standard, and, a fortiori, a change in the standard to any lower level, will lead to undesirable con centration within the industry. 5. That, because the projected construction industry regulation inevitably will have a profound economic impact upon segments of the asbestos manufacturing industry, va cannot intelligently comment upon the economic impact of the proposed manufacturing regulation separata and apart from the economic impact of the projected construction regulation. We believe, in short, that the most serious problems raised by the regulation proposed on October 9, 1975 lit in its potential impact upon the secondary and consuasr segments of the industry.... z i PLAINTIFFS EXHIBIT <2 WH-382 03114827