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Federal Register / Vol. 51. No. 119 / Friday, June 20. 1966 / Rules and Regulations 22667 brake and clutch repair, and shipyards. Model plant sizes-were selected based on data obtained from the RTI survey |Exhibit 84-473). After the model plants were developed for each industry segment, the total number of employees in the segment was used to compute the number of model plants needed to describe the segments (e.g., if total employment in a segment was 1.000 and average employment per plant was lOOi then the estimated number of plants was 10). The distribution of sizes and ail other attributes of the model plants were based oh information contained in the RTI Phase I Report [Exhibit 84-473). While none of the comments received by the Agency disputed the use of RTI's model plant approach. OSHA believes that some critical comments reflected a misunderstanding of RTFs methodology. For example, in their post-hearing comments, the Asbestos Information Association or North America criticized the estimates for the numbers of workers exposed for some model plants in the impacted sectors (Exhibit 312AI Tab N). This misunderstanding appears to arise from the fact that the model plants do not represent typical plants in each sector. By design, the model plant approach describes the average state of the existing engineering controls and ancillary measures within a particular industry segment. Thus, in most cases, the number of model plants calculated by RTI to represent the industry does not equal the actual number of plants in the industry, and the number of workers at each model plant does not'equal the typical number of workers at a typical plant. Although the number of model plants in an industry may differ from the actual number of plants, the aggregated complian.ee cost estimates that are based on the level or existing engineering controls present in a model plant should be accurate. . Other comments received by the Agency questioned the unit cost estimates used by RTI (see Exhibit 84273. Table'4-1). OSHA has carefully reviewed these comments and has revised many of the unit cost estimates in the RTI model. Thus, although OSHA used a similar approach'to the one presented by RTI. OSHA's industry cost estimates differ from those developed by RTI. Table 26 presents the unit cost estimates used by OSHA in its analysis. ' From this information and the Agency's Technological Feasibility Analysis, OSHA developed a compliance strategy for each size and type of model plant. (Another source of . differing cost estimates between OSHA and RTI are the differences in the . feasibility analysis.) Finally, the costs for each type of plant were calculated based on the estimated compliance levels, and the costs to each industry sector were estimated by aggregating the per plant costs. Table 27 presents OSHA's estimates of the annual compliance costs for the individual industry sectors. Table 28 presents OSHA's estimates of the cost to revenue ratios for the 17 primary manufacturing, secondary manufacturing, and service sectors. The compliance costs Tor each sector were obtained directly from Table 27 and the revenues for each sector were obtained from Table 5-5 of the RTI report [Exhibit 84-473). As can be seen from the Table V, the cost-to-revenue ratios for 14 of the 17 sectors are below 2 percent with most-below 0.5 percent. In three sectors (i.e., the manufacturing of primary and secondary asbestos friction products and the manufacturing of primary asbestos-reinforced plastics), the ratios are between 2 and 5 percent. Ratios of this magnitude indicate that these sectors may have some financial difficulty in complying with the requirements of the revised standard if the costs cannot be passed through to consumers in the form of higher prices. Nevertheless, OSHA believes these firms would avoid major disruptions by switching to the production of non asbestos products. Table 26 --Item Cost Estimates for Control Requirements in Primary Manufacturing, Secondary Manufacturing, and Service Sectors item Unit'cost (1984 dollars) Comments used to develop estimate Local exhaust Rotated to CFM Exhibit 84-73 and 3i2a. Tab N. end transcript of July 9. 1984. page 204. ventilation. needed. Lunch rooms. Related to Area Exhibit 84-473. Shower rooms needed. and change rooms. Caution tape......... $8.00/sgn............. Exhibits 84-473. 84-474. and 179 Suits ol protective $3.00/suit.............. Exhibits 84-473. 84-474. and 179. clothing. Hall-Mask cartridge respirator: Units-............. $t4.05/unit.......... - Exhibits 84-473. 84-474. 123A. 179 end 330. Fitters.....-.... . S6.t5/litlor pair...... Powerod-Air purifying respirator: Exhibits 84-473. 84-474, 123A. 179 and 330. Accessories S25-00/OOI......-'.-I. (filter and battery). Solvent spray------- $1.7S/can____ ___ OSHA telephone survey. HEPA vacuums: Exhibits 84-473. 64-474. 179 and 272. Filter........ $3S0.00/fMer-...... Exposure monitoring: Sampling...... $300.00/ Exhibits 84-473. 84-474, 179, 3t2A. 258. and 272: Hearing transcript of July it. technician/day. 1984, pages 698 and 892; hearing transcript of June 29. 1984, page H6. Analysis....... 00.00 pot sample. Medical exams...... $100.00 per exam. Exhibits 84-473. 84-474. 179, 123A. and 272: hearing transcript of Jufy 2. 1984. pages 53 and 253. and hearing transcript ot June 29.1984, page 117. Training-....-........... Gasod on wage Exhibits 84^473, and 84-474; transcript ol June 20. 1984, page 179; transcript of rate and time. June 29.1984, page 201 and transcript ot July 11.1984. page 89. Source; U.S. Department of Labor, OSHA. Office ot Regulatory Analysis. Table 27.--Annual Compliance Costs (No price or quantity changes) Industry sector Annual compliance costs (in thousands Of 1984 dollars) Most expensive provision Annual cost ot the most expensive provision as a percentage ot annual compliance costs -Primary manufacturing: A/C Sheet.................................. ............ ..... . .................................... ................ Friction materials........... -...................... :...... --...... .......... -.......................... -- Floor tile...-......--............_........................... .............-.......----- ------------- :....... Gaskets and packings......-........................................................................ ..........Paper....................................... -................ :.....--.......................................... -- Coatings and sealants...........................................................................................: Plastics.... . 642.8 Ventilation...22.661.3 .....do___ --... 305.1 758.8 834.8 1.223.9 474.6 .....do...... . .....do........... .....do-.... . ... .do........... 91 91 75 83 81 55 86 GLEASON-000915