# Appendix — American Textile Mfrs. Institute, Inc. v. Donovan > Briefs, arguments, decisions, and more. URL: https://www.frixlaw.com/law-library/documents/brief%3Amicro_IA40385006_2223%3A03 ## Record - **Collection:** Supreme Court brief - **Document type:** Appendix - **Published:** January 1, 1981 - **Citation:** 452 U.S. 490 ## Text Nos. 79-1429 and 79-1583 IN THE Supreme Court of the United States OCTOBER TERM, 1980 AMERICAN TEXTILE MANUFACTURERS INSTITUTE, INC., ET AL., Petitioners, V. RAY MARSHALL, SECRETARY OF LABOR, UNITED STATES DEPARTMENT OF LABOR, ET AL., Respondents. NATIONAL COTTON COUNCIL OF AMERICA, v, Petitioner, RAY MARSHALL, SECRETARY OF LABOR, UNITED STATES DEPARTMENT OF LABOR, Respondent. On Writs of Certiorari to the United States Court of Appeals for the District of Columbia Circuit JOINT APPENDIX NEIL J. KING WADE H. MCCREE, Jr. Counsel of Record Solicitor General A. STEPHEN Hut, Jr. KENNETH S. GELLER ANDREW N. VOLLMER Deputy Solicitor General WILMER & PICKERING BARRY SULLIVAN 1666 K Street, N.W. Assistant to the Solicitor Washington, D.C. 20006 General (202) 872-6000 Department of Justice Washington, D.C. 20530 (202) 633-2217 (Additional Counsel listed inside) PETITIONS FOR WRIT OF CERTIORARI FILED MARCH 14, 1980 (No. 79-1429) AND APRIL 9, 1980 (No. 79-1583) CERTIORARI GRANTED ON OCTOBER 6, 1980 tg ROBERT H. BorRK 142 Huntington Street New Haven, Connecticut 06511 GREGORY B. TOBIN OGLETREE, DEAKINS, NASH, SMOAK, STEWART AND EDWARDS First National Bank Tower Two Peachtree Street, N.W. Atlanta, Georgia 30383 Counsel for Petitioner American Textile Manufacturers Institute, Ine. ROBERT T. THOMPSON GARY S. KLEIN THOMPSON, MANN & HUTSON The Daniel Building Suite 2222 Greenville, S.C. 29602 Counsel for Petitioner Milliken and Company JOSEPH K. MADDOX, JR. P. O. Box 5784 Spartanburg, S.C. 29304 Counsel for Petitioner Spartan Mills ROBERT T. THOMPSON GARY S. KLEIN THOMPSON, MANN & HUTSON The Daniel Building Suite 2222 Greenville, S.C. 29602 Counsel for Petitioner Hermitage, Inc. SAMUEL K. ABRAMS BRIAN E. MORAN BAKER & HOSTETLER 818 Connecticut Ave., N.W. Washington, D.C. 20006 H. J. ELAM, III NEIL W. KOONCE Cone Mills Corporation Greensboro, N.C. 27405 Counsel for Petitioner Cone Mills Corporation CARIN A. CLAUSS Solicitor of Labor BENJAMIN W. MINTZ Associate Solicitor ALLEN H. FELDMAN DENNIS K. KADE DIANE E. BURKLEY JOHN A. BRYSON Attorneys Department of Labor Washington, D.C. 20210 Counsel for Respondent Secretary of Labor GEORGE H. COHEN Counsel of Record for Union Respondents ROBERT M. WEINBERG JEREMIAH A. COLLINS BREDHOFF, GOTTESMAN, COHEN, CHANIN, WEINBERG & PETRAMALO 1000 Connecticut Ave., N.W. Washington, D.C. 20036 (202) 833-9340 Counsel for American Federation of Labor and Congress of Industrial Organizations, Industrial Union Department, AFL- CIO and Amalgamated Clothing & Textile Workers Union, AFL-CIO LAURENCE GOLD 815 16th Street, N.W. Washington, D.C. 20006 J. ALBERT WOLL General Counsel, AFL-CIO 815 15th Street, N.W. Washington, D.C. 20005 ELLIOT BREDHOFF General Counsel Industrial Union Department, AFL-CIO 1000 Connecticut Ave., N.W. Washington, D.C. 20036 ARTHUR M. GOLDBERG General! Counsel Amalgamated Clothing & Textile Workers Union 15 Union Square New York, New York 10003 Of Counsel DAN M. Byrp, Jr. J. SPRATT WHITE P. O. Box 70 Fort Mill, S.C. 29715 Counsel for Petitioner Springs Mills, Inc. ROBERT H. BoRK 142 Huntington Street New Haven, Connecticut 06511 Counsel for Petitioner Fieldcrest Mills, Inc. THOMAS A. EVINS CLYDE H. HAMILTON BUTLER, MEANS, EVANS & BROWNE P. O. Box 451 Spartanburg, S.C. 29304 Counsel for Petitioner Arkwright Mills ROBERT T. THOMPSON GARY S. KLEIN THOMPSON, MANN & HUTSON The Daniel Building Suite 2222 Greenville, S.C. 29602 Counsel for Petitioner Blair Mills, Inc. HARLAN H. HUNTLEY ROGER L. TUTTLE 2291 Memorial Drive Danville, Virginia 24541 Counsel for Petitioner Dan River, Ince. THOMAS A. EVINS CLYDE H. HAMILTON BUTLER, MEANS, EVINS & BROWNE P. O. Box 451 Spartanburg, S.C. 29304 Counsel for Petitioner Mayfair Mills FRED M. RICHARDSON Lovic A. BROOKS, JR. CHARLES A. EDWARDS CONSTANGY, Brooks & SMITH 1900 Peachtree Center Building 230 Peachtree Street, N.W. Atlanta, Georgia 30303 Counsel for Petitioner Riegel Textile Corporation RICHARD H. MONK, JR. C. POWERS DORSETT West Point-Pepperell, Inc. P. O. Box 71 West Point, Georgia 31833 Counsel for Petitioner West Point-Pepperell, Inc. CHARLES M. CRUMP Counsel of Record APPERSON, CRUMP, DUZANE & “MAXWELL 2610 100 North Main Building Memphis, Tennessee 38103 (901) 525-1711 JOSEPH A. Moss 4143 27th Street, N. Arlington, Virginia 22207 (703) 525-4063 Counsel for Petitioner National Cotton Council of America + TABLE OF CONTENTS Page I. Relevant Docket Entries in the Courts of Appeals.. 1 II. Exhibits Submitted in the Proceeding Before the FR ee NEST PCL IE TE Shey 7 1. National Institute for Occupational Safety and Health, “Criteria for a Recommended Standard: Occupational Exposure to Cotton Dest” (ix. 1, emcerphed) 9 2. Roach & Schilling, “A Clinical and Environ- mental Study of Byssinosis in the Lanca- shire Cotton Industry” (Ex. 6-1, excerpted) ._.. 14 3. Bouhuys, “Byssinosis in the United States” CS Ren RTL OE ME Pah a eS Teh 15 4. Braun, et al., “Prevalence of Respiratory Signs and Symptoms Among U.S. Cotton Textile Workers” (Ex. 6-19, excerpted) 23 5. Bouhuys, et al., “Byssinosis in Cotton Textile Workers” (Ex. 6-24, excerpted) 24 6. Bouhuys, “Breathing, Physiology, Environ- ment and Lung Disease” (Ex. 6-27, ex- GE ee ee ee 25 7. Merchant, et al., “An Industrial Study of the Biological Effects of Cotton Dust and Cigarette Smoke Exposure” (Ex. 6-44, ex- I Seahaatha pascal 8 aa es 27 8. Merchant, “Dose Response Studies in Cotton Textile Workers” (Ex. 6-51) 29 9. Molyneux & Berry, “The Correlation of Cot- ton Dust Exposure With the Prevalence of Respiratory Symptoms” (Ex. 6-55, ex- MRE USE RCE EL Craton MUM ERBN I” BN Seat > me 56 10. Imbus, “Experience with Medical Surveillance Programs” (Ex. 6-57, excerpted) 58 i. 12. 13. 14. 15. 16. 17. 18. 19. 20. 21. 22. ii TABLE OF CONTENTS—Continued Molyneux & Tomblesen, “An Epidemiological Study of Respiratory Symptoms in Lancashire Mills” (Ex. 6-66, excerpted) .............0........------ Schilling, et al., “Cardiovascular Disease in Cotton Workers—Part I” (Ex. 6-73, ex- IE roiglie ends cate butcstlccsccaneinica cece secdeabeesnspnedsaeiadaaSenck Research Triangle Institute, Technological Feasibility Assessment and Final Inflationary Impact Statement (Ex. 6-76, excerpted) ....... Statement of Dr. Arend Bouhuys (Ex. 11, I er eit ee hs ea es ETRE aR, NPE TRO S ONT TK OTE EE, CPOE HERI Weill, “Report to the American Textile Manu- facturers’ Institute on a Study Entitled Assessment of Respiratory Responses in Tex- tile Workers Exposed to Low Levels of Cotton Dust” (ix. 154, excerpted) ..................-....... Statement of Bruce Held (Ex. 15, excerpted).. Research Triangle Institute, “Technological Feasibility and Economic Impact of Regula- tions for Cotton Dust” (Ex. 16, excerpted) .... Merchant, Memorandum to Grover C. Wrenn: “Review of Draft Proposal for Cotton Dust Standard” (Ex. 26, excerpted) ....00000.000..00000.... Statement of Edward J. Baier (Ex. 38a, ex- ERTS PCR aa LIne Sere aPC Merchant, “Epidemiological Studies of Respi- ratory Disease Among Cotton Textile Work- ers 1970-1973” (Ex. 38D, excerpted) ............. Morgan, et al., “Report on Survey on Preval- ence of Byssinosis and Respiratory Symptoms in Three Textile Mills” (Ex. 39, excerpted) .... Page 61 151 156 157 164 167 174 175 176 179 23. 24, 25. 26. 27. 28. 29. 30. 31. 32. 33. 34, 35. 36. iii TABLE OF CONTENTS—Continued Page Supplemental Submission to Statement and Testimony of W. K. C. Morgan, M.D. (Ex. i IED Soctiesesisccs ceri ar Oe 183 Statement of W. K. C. Morgan, M.D. (Ex 40, vse, sete he a RC Me Pe Re 185 Statement of Russell A. Harley, M.D. (Ex. a er an ti EOP NRO 190 Annual Cotton Dust Survey (Ex. 48) 198 Supplemental Submission to Statement and Testimony of Harold R. Imbus, M.D., Sc.D. (me. 47d, Qxcerpéed) 200 Statement of M. C. Battigelli, M.D. (Ex. 48, II ate e 203 “Burlington Industries Took Our Breath Away” (Ex. 54, excerpted)... 208 Statement of Carolina Brown Lung Assorcia- tion (Ex. 54a, excerpted)... 217 Statement of Moon W. Suh, Ph.D. (Ex. 55)... 221 Statement of Hovan Hocutt eee 234 Statement of L. K. Fitzgerald (Ex. 69, ex- IE ee ie i ai aie ti xan. 252 Submission of Amalgamated Clothing and Textile Workers Union: Vol. 1 (Ex. 78, IN idekinsiicd etisalat. 266 Statement of Parker C. Reist and Lawrence D. Kornreich (Ex. 79a, excerpted) ..:.............. 293 Reist, et al., “The Impact of New Production Equipment on Control Costs to Meet the Pro- posed Cotton Dust Standard” (Ex. 79c, ex- sen as ise, Re TO RT CRIED 296 37. 38. 39. 40. 41. 42. 43. 44, iv TABLE OF CONTENTS—Continued Page Statement of William A. Burgess (Ex. 80a, CID aces inscicsviesineccwicendstsinsnantacinabcene eas 309 Statement of Eric Frumin (Ex. 82, ex- IID usscttsenicsanisicctscoi-rveieshecmanmeenaaigineiiioamase esas 316 Statement of U.S. Department of Agriculture (ie, SGC, Ceeeteees: ..nc ee 325 Statement of John S. Barr, III (Ex. 101, ex- 1} SRNR Ne OPENER ON rt Me UREN Ee Tn NR 327 Comments of the Council on Wage and Price Stability (Ex. 111, excerpted) .................0..... 331 Statement of Dr. Sidney Wolfe & Peter Greene (ix. 228, GCE? Lo MPS 343 Bouhuys, et al., “Epidemiology of Chronic Lung Disease in a Cotton Mill Community” CHER BG, GOES bck xchat ae 344 Supplemental Submission of Amalgamated Clothing and Textile Workers Union (Ex. 143, CIID Siciisccetnccndncdacunsdinataneecsascieaaaea is 348 45. Post-Hearing Comment of the American Tex- tile Manufacturers Institute, Inc. (Ex. 160, SU iaeccinisnctisesaicsghcesccinasab biaieaatiin 372 46. Letter from F. S. Love to Eula Bingham (Ex. EV R\ SIONS | nvisnncccinncicciateces 388 47. Statement of Arthur Thomas (Ex. 62, Attach- a | a ae NC Be: SOMME Ce AC ae 486 III. Transcript of Hearing Before the Agency .............. 399 1. Excerpted testimony of Dr. Bouhuys .............. 401 2. Excerpted testimony of Dr. Kilburn .............. 410 3. Excerpted testimony of Dr. Weill .........000000000.. 410 4. Excerpted testimony of Mr. Held -.................. 412 5. Excerpted testimony of Dr. LeSourd ............ 414, 418 6. Excerpted testimony of Dr. Lee ~...0000.00000000.... 416 7. Excerpted testimony of Dr. El Batawi .......... 421 IV. v TABLE OF CONTENTS—Continued Page 8. Excerpted testimony of Dr. Merchant....423, 435, 485 9. Excerpted testimony of Dr. Taylor... 434 10. Excerpted testimony of Dr. Baier... 442 11. Excerpted testimony of Dr. Morgan _............ 444 12. Excerpted testimony of Dr. Harley ........... 444 18. Excerpted testimony of Dr. Martin... 445 14. Excerpted testimony of Dr. Imbus ................ 445 15. Excerpted testimony of Dr. Neefus ......__. 449 16. Excerpted testimony of Ms. Norton ......... 451 17. Excerpted testimony of Ms. McCoy _.............. 452 18. Excerpted testimony of Mr. Harrell... 453 19. Excerpted testimony of Mr. Sandlin ......._. 453 20. Excerpted testimony of Mr. Hassell... 454 21. Excerpted testimony of Mr. Baldwin ......___ 455 22. Excerpted testimony of Mrs. Sanders... 456 23. Excerpted testimony of Mr. Graves _............. 457 24. Excerpted testimony of Mr. Hocutt... 458 25. Excerpted testimony of Mr. Figh _............... 473 26. Excerpted testimony of Mr. Chapman ............ 476 27. Excerpted testimony of Dr. Reist 477 28. Excerpted testimony of Prof. Burgess ............ 481 29. Excepted testimony of Mr. Davis _............... 482 30. Excerpted testimony of Mr. Mabe _................. 483 31. Excerpted testimony of Mr. Frumin .....___. 484 Order of Supreme Court granting Petitions for Writs of Certiorari in Nos. 79-1429 and 79-1583... 487 I. Relevant Docket Entries in American Federation of Labor & Congress of Industrial Organizations, et al., Vv. Ray Marshall, et al. No. 78-1562 (D.C. Cir.) (and Consolidated Case Nos. 78-1736, 78-1979, 78-1980, 78-1981, 78-1982, 78-1983, 78-1984, 78-1986, 78-1987, 78-1988, 78-1989, 78-1990, 78-1991, 78-1992, 78-1993, 78-2013, 78-2014, 78-2016 and 78-2018) Date Filings, Orders, and Proceedings 1978 June 19 June 19 July 27 August 2 August 3 August 7 August 7 August 10 August 14 August 15 August 16 Filing of Petition for Review of Cotton Dust Standard by American Federation of Labor & Council of Industrial Organizations, et al. (D.C. Cir.) Filing of Petition for Review of Cotton Dust Standard by American Textile Manufacturers Institute, Inc. (4th Cir.) Filing of Petition for Review of Cotton Dust Standard by Milliken and Company (4th Cir.) Filing of Petition for Review of Cotton Dust Standard by Arkwright Mills (4th Cir.) Filing of Petition for Review of Cotton Dust Standard by Spartan Mills (4th Cir.) Filing of Petition for Review of Cotton Dust Standard by Blair Mills (4th Cir.) Filing of Petition for Review of Cotton Dust Standard by Hermitage, Inc. (4th Cir.) Filing of Petition for Review of Cotton Dust Standard by West Point-Pepperell, Inc. (5th Cir.) Filing of Petition for Review of Cotton Dust Standard by Dan River, Inc. (4th Cir.) Filing of Petition for Review of Cotton Dust Standard by Cone Mills Corporation (4th Cir.) Filing of Petition for Review of Cotton Dust Standard by Nationai Cotton Council of America (6th Cir.) _ PREVIOUS PAGE WAS BLANK | 4 Date Filings, Orders, and Proceedings 1978 August 16 August 16 August 17 August 18 October 3 October 6 October 7 October 13 December 15 December 15 December 15 December 15 Filing of Petition for Review of Cotton Dust Standard by Springs Mills (4th Cir.) Filing of Petition for Review of Cotton Dust Standard by Mayfair Mills (4th Cir.) Filing of Petition for Review of Cotton Dust Standard by Riegel Textile Corporation (4th Cir.) Filing of Petition for Review of Cotton Dust Standard by Fieldcrest Mills, Inc. (4th Cir.) Order transferring Cotton Dust Petitions for Review pending in the Fourth Circuit to the District of Columbia Circuit Order transferring National Cotton Council of America Petition for Review from the Sixth Circuit to the District of Columbia Circuit Order transferring West Point-Pepperell, Inc. Petition for Review from the Fifth Circuit to the District of Columbia Circuit Order consolidating Cotton Dust cases in the District of Columbia Circuit Filing of Opening Brief of Petitioners Ameri- can Federation of Labor & Congress of In- dustrial Organizations, et al. Filing of Joint Brief of the American Textile Manufacturers Institute, Inc., et al. Filing of Supplemental Brief of Petitioner, National Cotton Council of America Filing of Amicus Curiae Brief of American Farm Bureau Federation Date Filings, Orders, and Proceedings 1979 January 26 February 7 February 7 February 7 February 14 October 24 November 7 November 7 1980 January 11 January 11 January 16 Filing of Brief for the Secretary of Labor Filing of Reply Brief of Petitioner National Cotton Council of America Filing of Reply Brief and Brief in Interven- tion of Petitioners American Federation of Labor & Congress of Industrial Organiza- tions, et al. Filing of Joint Reply Brief of the American Textile Manufacturers Institute, Inc., et al. Oral Argument in the United States Court of Appeals for the District of Columbia Circuit Entry of Judgment and Opinion of the United States Court of Appeals for the District of Columbia Circuit (Reprinted in the Appendix to the Petition for Writ of Certiorari at 19) Filing of Petition for Rehearing and Sug- gestion for Rehearing En Banc of Petitioner, National Cotton Council of America Filing of Joint Petition for Rehearing and Suggestion for Rehearing En Banc of Ameri- can Textile Manufacturers Institute, Inc., et al. Order denying Petitions for Rehearing (Re- printed in the Appendix to the Petition for Writ for Certiorari at 103) Order denying Suggestions for Rehearing En Banc (Reprinted in the Appendix to the Peti- tion for Writ of Certiorari at 104) Motion of National Cotton Council of Ameri- ca for Stay of Mandate Date Filings, Orders, and Proceedings 1980 January 16 January 17 January 17 January 22 March 14 April 9 October 6 Filing of Joint Motion for Stay of Mandate by the American Textile Manufacturers Insti- tute, Inc., et al. Filing of Opposition to Motions for Stay of Mandate by the Secretary of Labor Filing of Response of Union Petitioners to Motions for Stay of Mandate Order directing clerk to issue mandate (Re- printed in the Appendix to the Petition for Writ of Certiorari at 106) Filing of Petition for a Writ of Certiorari by Petitioners American Textile Manufacturers Institute, Inc., et al. Filing of Petition for a Writ of Certiorari by Petitioner National Cotton Council of America Entry of Order granting Petitions for Writs of Certiorari (Reprinted in this Joint Ap- pendix at 489) II. EXHIBITS SUBMITTED IN THE PROCEEDINGS BEFORE THE AGENCY 9 EXHIBIT 1 National Institute for Occupational Safety and Health, “Criteria for a Recommended Standard: Occupational Exposure to Cotton Dust” Feasibility of Control Control of dust levels in cotton-processing operations can be achieved by changing or treating the raw mate- rial which is the source of the dust, by changing the process which produces the dust, or by removing the dust from the air once it is generated. The transition from natural to synthetic fibers in the past decade has resulted in lower byssinosis-producing dust levels in those mills using synthetics or blends. Mer- chant et al [18] reported a median dust level of 0.485 mg/cu m for 493 samples collected in mills working with pure cotton and a median dust level of 0.163 mg/cu m for 237 samples collected from mills using blends of nat- ural and synthetic fibers. The synthetic fibers are vir- tually trash free and thus contribute little to the total sample collected. [136] It would be expected that, as the synthetic content of the raw material increased, the dust levels in most work areas would decrease. A second method of changing the raw material is through the improvement of growing techniques to reduce the trash content of the cotton. Approaches such as de- veloping cotton varieties which shed their bracts prior to maturation and harvest or the development of dwarf determinant cottons with increased fruiting potential compared to the production of vegetative parts [137] offer future potential methods of dust control, but at present these approaches are not feasible. There is little doubt that exposure to cotton dust trash has been greatly augmented by the replacement of handpicking by ma- chines. [138] Studies are in progress to find new chem- _ PREVIOUS PAGE WAS BLANK | ‘ 5 10 icals which will more efficiently defoliate cotton and re- duce the trash content of the harvested seed cotton. [137] A third method of changing the raw material is by steaming. Studies of this technique indicated that steam- ing could reduce the toxic effect of the cotton dust with- out rendering the cotton unsuitable for processing. [94] Some investigators conclude that the byssinosis-producing dusts are not removed or detoxified, but are just made to adhere more firmly to the cotton fibers; therefore the byssinosis problem is not solved but only moved from the opening, picking, and carding areas to the winding and weaving operations. [139] However, recent studies in a cotton spinning plant do not show an increase in down- stream dust levels when processing steamed cotton. [140] Thus, while steaming may not be at this time a feasible alternative to dust control, it may become effective as a supplementary control method after further development. [140] Work is also in progress on improved ginning methods to allow for more efficient trash separation and/or fractionation. [137] There appears to be little that can be done now to change the process in which cotton fibers are formed into yarn and woven into cloth in order to control dust production. The cotton manufacturing process is essen- tially one of fiber cleaning and alignment with the de sired goal of removing all material in the cotton except the mature fibers. The dust in the cotton is thus an unwanted byproduct which must be dealt with. It is possible that the ginning process could be changed, and work is being actively pursued along these lines [137]; but at present process change does not appear to be a feasible alternative to dust control. There are also a number of environmental factors which can be adjusted to some extent to control dust levels. As the opening and cotton cleaning machinery more efficiently removes trash and dust from the cotton 11 stock, the release of this material into the work areas diminishes. Thus, dust levels in the picking room, card- room, and subsequent operations can be reduced by better cleaning of the cotton in the opening and cleaning line. [141] Decreasing the production machine density in a work area should decrease the dust levels in that area also. Conversely, if the machines are crowded together, higher dust levels would be expected. Dust emission is also increased by higher card speeds. Improperly or poorly maintained production machinery can also lead to higher dust levels. Hocutt [141] reports that cardroom dust levels are lower when the cards are well maintained and properly operated with alert operating personnel using precise machine settings. Large central air-conditioning systems will tend to even out dust concentrations over the entire mill. [141] Of course, this might create new problems instead of getting rid of one, since it would cause increased dust level in some area while decreasing those in others. How- ever, air-conditioning a textile mill does provide some dust control, but the control is incidental and the in- creased dust load in the air-conditioning unit will result in increased maintenance costs and impede the perform- ance of the air conditioner. Dust is removed by the washer, a unit which acts as the primary humidifier and heat exchanger in the air-conditioning system. The washer is about 25% efficient for large particles [141] and much less efficient for smaller ones. Reliance on the air conditioner for dust control means that the dust must travel through the work area to reach the air-conditioner inlet, usually located on one wall of the room. Thus, the very nature of the system makes it inefficient for dust reduction or removal. The capture and removal of dust from the air after it has been generated from the cotton represents the most 12 widespread and efficient method of dust control at the present time. Table IV-3 gives summarized results from a study conducted recently by Barr et al [127] on the effectiveness of dust controls in mills having different degrees of dust control and processing varying grades of cotton. These results serve only to indicate the ranges of concentrations which may be expected for the different operations, with and without dust controls. It appears that in some instances there may be dust concentrations (80 F% — 0.06- —0.20 >80 Fl >- —0.20 >80 F2 — 60-79 F3 — ? Blend Mills by Median Dust Level Dust 0 -057 0839 .1255 .1878 .2809 .4202 .6287 .9405 1.408 Level to to to to to to to to to to -056 -0888 .1254 .1877 .2808 .4201 .6286 .9404 1.407 2.105 Men n 70 34 104 144 61 122 69 65 80 42 Mean Age 39.5 36.9 38.7 42.1 33.6 87.8 $8.8 $7.1 41.4 38.7 % Current Smokers 67.1 64.7 56.7 54.9 718.8 53.3 73.9 55.4 73.3 66.7 % Former Smokers 14.3 23.5 19.2 22.2 9.8 18.0 10.1 16.9 18.3 14.3 % Black 5.8 8.8 7.7 19.0 26.2 29.2 27.5 36.9 13.3 64.3 Women n 15 87 89 135 17 85 17 0 1 0 Mean Age 41.5 43.9 44.4 42.9 39.6 88.8 37.7 21.0 % Current Smokers 44.0 $2.4 25.8 86.3 47.1 86.5 $2.5 0 0 0 % Former Smokers 12.0 0 4.5 6.7 5.9 12.9 10.4 0 0 0 % Black 19.2 10.8 5.6 17.9 52.9 16.9 27.8 0 100.0 0 Percent change in FEV, with six hours of dust ex- posure for cotton/blend mill preparation and yarn area workers and synthetic/wool mill workers by dust level is shown in Table 5. Linear regressions truncated at 1 mg/m were calculated and the regression lines and cor- relation coefficients shown in Figure 6. Kenneth A. Busch, National Institute for Occupational Safety and Health, analyzed prevalence data using a pro- bit model,’?** and developed Table 6 through 9 and the probit curves in Figs 2 through 4. His protocol for an- alysis was as follows: For each set of data, the method of maximum likelihood was used to fit a straight line to Y= probit (prevalence ratio) vs. X= log, (median dust level in mg/m*). A chi-square goodness-of-fit test was made to test jointly for both nonlinearity and excessive variance about the fitted curve as compared to theoretical results expected under the probit model. Ninety-five per- cent statistical confidence limits were put upon the true 33 dose-response curve as well as upon predicted dust levels corresponding to eight arbitrary levels of hypothetical byssinosis prevalence: p= 1%, 2%, 3%, 4%, 5%, 10%, 25,% and 50%. Pairs of curves for Groups 1 and 2, and for Groups 3 and 4, respectively, were tested for parallel- ism and, if found to be parallel, a “relative toxicity” metameter R was estimated along with its 95% confidence limits. By “relative toxicity” is meant the ratio between dust levels which produce the same prevalence of byssin- osis in the two groups. Thus an R-value of 1.0 would imply the two curves were coincident. When curves for two groups are found to be non parallel, the difference be- tween them is difficult to interpret since relative toxicity would not be constant at all levels of response. In such a case, a conditional relative dose metameter Rp was calculated for several p-levels of prevalence of byssinosis in the two groups. Results Table 2 summarizes 985 vertical elutriator (Fig 1) dust samples by mill type, work area, measures of central tendency and range. The greatest number of samples was collected in the preparation areas of the cotton and blend mills. The highest dust levels are recorded in the slash- ing and weaving areas of cotton and blend mills where sizing is used and contributes to the dust concentration, Where sizing is not used, the dust levels in the prepara- tion area were consistently much higher than in the yarn processing areas. The mean dust levels were gen- erally higher than the median or geometric mean levels, reflecting the effect of high out-liers. In synthetic and wool mills there was little difference in dust level between preparation and yarn processing areas. The highest dust levels in these mills were found in the preparation area of the wool mill and the preparation area of a synthetic mill where gasoline driven machinery was used. 34 Demographic and smoking characteristics for men and women in cotton preparation and yarn areas by dust level are shown in Table 3. No clear age trend is ap- parent among men or women, nor is there a consistent difference in the proportion of current or ex-smokers be- tween dust subgroups. Among men, a greater precentage of blacks were found with increasing concentration of dust exposure. This was less apparent among women who rareiy work in the dustiest areas of the mills. Busch concluded from his analysis that the log-probit model fitted the data well in every case. The points were scattered randomly about the fitted dose-response curve and the variance of deviations from the curve was not significantly greater than would be expected based upon an assumption of binomially-distributed prevalence ratios at each dust level. Slopes (b) and intercepts (a) of the fitted log-probit dose-response curves, Y= a + bx, are shown in Table 6 together with three calculated points (ordinates Y) for each fitted curve and their 95% confidence limits. The curve equation was then inverted to predict dust levels corresponding to arbitrary prevalence levels. Table 7 shows the predicted dust levels and their 95% confidence limits for the six groups of workers for prevalence levels of 1%, 2%, 3%, 4%, 5%, 10%, 25% and 50%. Chi-square tests for goodness-of-fit of the individual curves and for parallelism of pairs of curves (1 vs. 2 and 3 vs. 4) are shown in Table 8. Curves for current smokers (Group 1) and those who never smoked (Group 2) were found to be significantly different although nearly parallel but not coincident. A relative toxicity of R= .56 with 95% confidence limits of R= .35 to R— .83 was found (Table 8) ; this suggests that only 56% (35% to 83%) as much cotton dust is associated with any given prevalence of byssinosis among smokers as among ¥ 35 those who never smoked. Curves for all prepartion and yarn workers (Group 3) and for all slashing and weav- AIR FLOW GONTROL SAGE (LIMITING ORIFICE) Diigo: © VACUUM —— PUMP | SETTLING — CHAMBER VERTICAL ELUTRIATOR COTTON DUST SAMPLER ~Fig 1. FY 36 ing workers (Group 4) were not found to be parallel. Therefore a single R-value was meaningless and it was necessary to calculate R,-value as a function of eight arbitrary prevalence levels which are shown in Table 8. Curves for Groups 3 and 4 were found to be significantly different but yielding R,-values which ranged from .087 at a byssinosis prevalence of 1% to .56 at a prevalence of 50%. Therefore, only approximately 9% (4% to 15%) as much cotton dust is associated with a 1% bys- sinosis prevalence for workers in the preparation and yarn areas of cotton mills as compared to the amount re- quired for the same prevalence for cotton slashing and weaving workers. At a prevalence of 5% an average of 15% as much dust is required, as a prevalence of 25%, 32% as much, and at the 50% prevalence level 56% as much dust is required. The probit-dose response curves are shown in Figs 2, 3, 4, together with the linear regression plots and cor- relation coefficients. The truncated linear plots are ob- served to fall within the 95% confidence limits of the probit curves below a dust level of 0.5 mg/m*. Both dose response curves for cotton slashing and weaving workers fell nearly on the same line through 2.0 mg/m? of dust. The strength of the linear association between dust level and byssinosis prevalence was uniformly high except for those who had never smoked (Group 2) where the cor- relation coefficient was .52; however, one subgroup within this population contained only seven workers, none of whom had symptoms of byssinosis. Expected byssinosis prevalence levels are shown in Table 6 and the curves plotted for Groups 3, 5 and 6 in Figure 4. Prevalence of Grade 2 byssinosis (Group 5) ranges from 1.3% (0.7- 2.3) at 0.1 mg/m* to 3.0% (2.1-4.3) at 0.2 mg/m to 8.0 \6.1-10.2) at 0.5 mg/m*, as computed from the probit curve. When Grade 1 and 2 byssinotics are combined (Group 6) the probit prevalence levels are 2.1% (1.3- 3.3) at 0.1 mg/m’, 5.0% (3.9-6.6) at 0.2 mg/m? and 13% (10.7-15.8) at 0.5 mg/m‘, 72 37 Table 5 and Fig 5 show percent change in FEV,, with increasing levels of exposure among cotton preparation and yarn area workers and synthetic and wool workers. The truncated linear regression (Fig 5) for the cotton population again showed a strong linear association (r — .82) between biological effect and dust level. No decre- ment in percent changes in FEV,, is seen with increasing levels of exposure to synthetic and wool dust. Discussion Dust Sampling.—In the year preceding this study, sev- eral cotton dust sampling techniques were evaluated." The sampling device desired was to be relatively easy to operate, portable, durable, operable unattended for a full shift and provide a lint free dust sample. Of the sam- pling devices evaluated, the vertical elutriator developed by Lynch and Lumsden * was found to best fulfill these criteria. The instrument was designed to sample dust with a mass median aerodynamic diameter of 15. and less which effectively eliminated biologically inert lint while retaining particles of the size expected to be in- haled. Since high correlations between byssinosis symp- toms and dust level have been observed with the middle fraction (7. to 2mm) of dust, *" it was thought that larger particles (7y-15,) as well as “respirable” parti- cles ( asuro> 00 =| uinipayy Le 255805 ais WNIpryy asur0> wnipay > asuro> wnipay 21805 wnipay 2005 wripay 281805 wnIpasy 2007) wnipay ‘981205 WIP r, w~ © t+ of = oo mM oe — AT AA mn ae bie or owe = Oh ee ee - ee se (%) aausporasg WwW SONNE oo OC ose oe Se ee eee coels (ajeus) ucwoisey (ajrw) soancqr’y ** (ayeusay) souuids Sury (ajeuss;) s3)u91 s2qwo> (9jeusd§) 42;u9} Swesjpradg (ojewsay) 32)U9) wey neg ee (2;eway) J33u3} pied (aut) J9puisd pue sodding (ajew) Japsessopun ‘sapsey uonvdnr»O (2/twW) J9QWwey> UoO}}02 pur Wool no;g STUW 3SHVOD GNV Wha NI SNOILVdNDIO O} NI (% ¢ JIGVL ) BINIIVAIAY SISONISSAG 64 EXHIBIT 6-73 Schilling, et al., “Cardiovascular Disease in Cotton Workers” * * —_ o * Sources of Unreliability in Mortality Rates Many doctors certify multiple causes of death from which the Registrar General must select one for com- puting death rates for specific diseases. The practition- ers often cannot verify their diseases either by necropsy or special investigation. Thus both the Registrar Gen- eral and the general practitioner introduce possible sources of error into the mortality rates ascribed to specific diseases. And as the habit of multiple certifica- tion has become more common in recent years, the secular trends in the mortality rates of certain diseases may therefore be seriously misleading. Multiple Certification—When the medical practitioner gives more than one cause of death on the certificate the Registrar General selects one according to certain rules. In 1921-23 and 1930-32 any definite diseases of the heart or kidneys was preferred to any disease of the respiratory system when both were mentioned together. In 1939 the Registrar General’s selection rules were revised. Prefer- ence is now given to the disease which, as far as can be ascertained was, in the opinion of the certifying medical practitioner, the starting point of the sequence leading up to the immediate cause of death. The effect of adjust- ing bronchitis and cardiovascular death rates for 1921- 23 and 1930-32 in the light of this revision cannot be shown accurately, but it is possible to get some idea of the likely change from two different sources—the Regis- trar General’s statistics for 1939 (the year of change), when he classified all the death certificates according to both new and old rules, and from a review of the death certificates of card room workers, applied by the trade unions. The latter is a source of information often avail- able but seldom used. 69 The relevant conclusion of the Registrar General (1947) as regards our particular problem is: “Bronchitis and asthma death rates have been affected considerably . . . by the increasing mention of myocardial degeneration as a contributory cause of death and consequent classification by the (old) rules of selection, of increasing numbers to heart disease.” He gives conversion factors so that an estimate may be made of the number of deaths before 1939 from diseases, of the myocardium among the general popula- tion which would be put back to respiratory deaths if the new selection rules applied. For bronchitis in all males there is added 0.237 times the number of deaths which were previously ascribed to diseases of the myo- cardium. But for groups with a high respiratory mor- tality a higher proportionate transfer should be made. There is, however, another method available for the very necessary interpretation of the Registrar General’s rates of cardiovascular and respiratory mortality before 1939. But it must be emphasized that it is a highly tentative procedure. In 1939, when deaths were given classified under both rules, the bronchitis deaths under the new classification were increased by transference from dis- ease of the myocardium, endocarditis, and arteriosclerosis from amounts varying from 30% at ages 25-34 to 114% at ages 65-69. If these age-specific conversion factors are applied at the appropriate ages, the death rates from cardiovascular causes in 1930-32 are reduced by the fol- lowing amounts for ages 25-69 (Tables C and E). ESN Lae 8% SE Ce 10% Strippers and grinders ................ 24% Ee 10% 66 We have assumed that practitioners combined bron- chitis and heart diseases on their death certificates in much the same proportions in 1930-32 as in 1939 and that the practice was similar among practitioners in cot- ton areas as elsewhere.* We have no means of verify- ing these two proportions, but if our assumptions are reasonable, cardiovascular death rates for strippers and grinders would be reduced under the new system of classification by more than twice as much as the similar rates for all males and the other cotton groups. Death certificates of 256 card and blow room workers, or known ex-card and blow room workers, of all ages in the Rochdale, Oldham, and Bury areas, obtained from the trade unions, were examined. These covered a period from 1941 to 1948. In Fig. 4 the effect of the change in methods of classification is shown for the 25-69 age group in which there were 164 deaths. Of the 24 additional deaths from respiratory causes under the new system of classification, 19 were trans- ferred from diseases of the myocardium, three from endocarditis, one from “other heart diseases’, the re- maining one coming from chronic rheumatism. This transference lowers the cardiovascular death rate for ages 25-69 by 23 67 This compares with the 24% estimated by the other method. + x 100 = 34% ** * As multiple certification continued to increase between 1930 and 1940 we may have overestimated the reduction. ** In addition to transferring 23 deaths from cardiovascular to respiratory causes, two other deaths were transferred to the cardio- vascular group from other causes, giving a net loss of 21 deaths as shown in Fig. 4. + For all ages, the transference lowered the cardiovascular death rate by 30%. 67 Figure 4 se « DF 64 CARD AND BLow ROOM WORKERS SSIFICATION OF CauUSe OF DEATH ! —_—— I941 - 1948 Aces 25- 69 ”? 9 - | & p | oc ae 2 e Vv ] J s| | &R: ° ° 36 zx = - ° ° 3 y whe 7 3 £ 4 42 a $ ‘io ot be e{ 2] + $ z ey = - Fd O.o SYSTEM New System oF OF CLASSIFICATION CLASS! FICATION [ree 1935] [Posy 1935) The Registrar General (1949) records that in the 1921-30 decennium 33% of all death certificates for non-violent deaths gave “multiple” causes. By 1935 this proportion in all death certificates had risen to 43%. It is reasonable to infer that there was a substantial in- crease in multiple certification between 1921-23 and 1930-32, which would mean that a higher proportion of respiratory deaths would be allocated to cardiovascular deaths in the latter than in the former triennium. This may be a possible explanation of the opposite secular 68 trends in cardiovascular and respiratory mortality, and in fact both these death rates may have been falling. The North IV (Lancashire and Cheshire) region in 1930-32 showed a mortality excess from respiratory dis- eases over all males at all ages. Some of the cardio vascular mortality excess for this region can be similarly explained. But, even after reclassification by the meth- ods given above, death rates for heart diseases and nephritis for males in North IV are still significantly greater than rates for all males at ages 45 and over, but spinners and strippers and grinders have higher rates than North IV at ages over 55 (Table D). These high cardiovascular death rates for North IV cannot be explained. Errors in Diagnosis.—It is not possible to be certain about the effects on mortality rates of using vague terms to describe causes of death, or of frank errors in diag- nosis. The cardiovascular group of diseases includes myocardial diseases and degeneration which are vague labels used for diseases in which the exact pathology is not known. The use of “heart failure” as a cause of death is not favoured by the Registrar General, and for these diseases of uncertain pathology in which cardiac failure is the terminal result, the general practitioner undoubtedly uses “myocarditis” and the like in order to avoid enquiries about his certificates. We have considered the reallocation to respiratory deaths of certificates on which both cardiovascular and respiratory causes are mentioned; but it is probable that there are some death certificates with no mention of respiratory disease, even though such a disease was the starting point of the pathological changes leading to death. And it is also probable that such an event occurs even t It is of interest that in 1947-8 a similar excess for heart disease is still present, in spite of the new methods of classification. 69 more often among cotton workers exposed to dust than among all males or men of the same social class, for rea- sons which will now be discussed. Byssinosis has been repeatedly described as a disease which closely simulates chronic bronchitis and emphy- sema, but O’Sullivan found that among 33 men suffering from disabling byssinosis 12 had no clinical evidence of bronchitis. Shaw Dunn, and Sheehan (1932) did nec- ropsies on 10 cotton mill workers, nine of whom had been exposed to dust; while all of these nine had some evi- dence of chronic bronchitis and emphysema, six showed hypertrophy of the right ventricle, four of whom died of congestive cardiac failure. Thus cotton workers with disabling byssinoisis, with its characteristic asthmatic symptoms, may present a clinical picture of cardiac asthma or congestive cardiac failure, which so masks the respiratory disease that it is not mentioned on the death certificate. For nephritis it is possible to make more definite assumptions about mistakes in diagnosis. Platt (1947a) suggests that most of the deaths as- signed by the Registrar General to nephritis in the older age groups are not renal deaths at all. In his own 161 cases for which full records were available, the main incidence of deaths from nephritis was under the age of 45. The Registrar General’s figures for age incidence are totally different, with the main mortality over the age of 45. Platt’s own experience is that many cases of hypertensive cardiac failure with albuminuria are diagnosed by their general practitioners as chronic in- terstitial nephritis. Nephritis death rates are particularly high in certain occupations. Greenwood and Russell (1988) showed that in the 1921-28 triennium the textile trades, pottery dip- pers and file cutters, all of whom had high nephritis death 70 rates also had a high risk of dying from respiratory disease. For all occupations there is a significant correlation between the standardized death rates for bronchitis and nephritis in 1921-23 (Table 2). In 1980-32 the same type of occupations appear to have high nephritis death rates—blow room workers and foremen, strippers and grinders, and cutlers—but for this period, as shown in Table 2, there is a significant correlation between the standard mortality ratios of bronchitis and nephritis only for Social Classes III and IV. A possible explanation for this relationship is that many of the men in these trades died of congestive cardiac failure caused by respiratory disease and were certified as nephritis deaths.* Thus there is some evidence that medical practitioners may fail to distinguish renal disease from other dis- eases which in their terminal stages simulate renal disease. It seems possible, therefore, that the mortality excess from nephritis in cotton workers may be due to deaths from respiratory disease, which terminates as congestive cardiac failure. If, however, occupational in- fluences cause hypertension, as has been suggested, there will be another reason for high “nephritis” death rates in cotton workers. Conclusions In order to get a clearer picture of any occupational mortality excess due either to cardiovascular and respira- *In the same paper Greenwood and Russell drew attention to the high nephritis death rates in barmen and inn and hotel keepers for whom an excess of alcohol is probable. In the triennia 1921-23 and 1930-32 there is a significant correlation between standardized death rates for nephritis and cirrhosis of the liver. It is possible that this correlation is due to some cases of cirrhosis of the liver which terminally have oedema being misdiagnosed as nephritis. Fishberg (1939) quoting his own experience and that of others is very sceptical of the role of alcohol in producing renal disease. _. 71 tory diseases for the triennium 1930-32, cardiovascular and respiratory deaths are given in Fig. 5, added to- gether, for the cotton trades, for all males, and for males of similar social classes to the cotton workers. The occu- pational hazard of the cotton trades, particularly of the stripper and grinder, is obvious. We know that most of this is respiratory and that in the past respiratory mor- tality of cotton workers has almost certainly been under- estimated; but when a correction is attempted for the respiratory deaths allocated to the cardiovascular group of diseases, there still seems to be an excess of deaths for the cotton workers and particularly so for the strip- pers and grinders. Thus there may be a real excess of heart disease due to occupational influences. The latter possibility is so important in view of the very high na- tional death rate from cardiovascular diseases and the absence of information on its relation to environmental factors that this clue must be followed up. As Morris (1951) said, cardiovascular disease of middle and old age is one of the darkest areas of vital statistics and at present the main source of information must be the mortality rates. In another paper the results of a clinical investigation of more than 300 men employed in cotton textile mills will be described. TABLE 2 CORRELATION BETWEEN NEPHRITIS AND BRONCHITIS (AGEs 20-64 YEaRs) Nephritis and Bronchitis rT No. of Groups P 1921-23* 38+ .04 164 P bh. 7 = = oo,," v FN Fe : . 2 NSS = LL EYN TS & 45- 65-69 pe 45 Figures above columns for coulion workers arc number of deaths upon which rates ure bused. (See Appendix, Tables C and E.) Summary Since 1891 the Registrar General has recorded high death rates from cardiovascular diseases among cotton workers. It has been suggested that this mortality excess may be due to hyperpiesis caused either by the inhalation of textile dusts or by inbreeding in Lancashire cottun towns. In this paper the Registrar General’s figures are ana- lysed principally for the triennium 1930-32 (the last to be published). It is shown that in the three occupational groups studied, strippers and grinders, weavers and spinners, there is an association between mortality and the extent of dust exposure. The significantly high death rate of the strippers and grinders (the occupation with the highest dust exposure) from cerebral vascular lesions supports the hypothesis 73 that hyperpiesis may be the cause of this mortality eXcess. Two sources of unreliability in mortality rates are discussed. (1) Since 1920 medical practitioners have entered multiple causes of death with increasing fre- quency on death certificates. The Registrar General makes rules for selecting one cause of death from certificates with multiple causes. Before 1939 these rules exaggerated cardiovascular mortality and reduced respiratory mor- tality. Since 1939 more reliable methods of selection have been used, and some of the cardiovascular mortality of cotton workers who it is known have high respiratory death rates from byssinosis can be explained simply by methods of book-keeping. (2) The use of convenient though vague terms such as “myocarditis” to describe causes of death, and errors in diagnosis, particularly of nephritis in the older age groups, may also exaggerate cardiovascular death rates. When all possible corrections are made for the exag- geration of cardiovascular mortality through the errone- ous allocation of respiratory deaths to it, there still re mains an excess of cardiovascular mortality particularly for strippers and grinders. This may well be real and may be due to occupational influences. We should like to thank Dr. J. N. Morris of the Social Medicine Research Unit of the Medical Research Council, Dr. W. P. D. Logan of the General Register Office, Mr. G. Hart of Rugby Mill, Hollin- wood, and our colleagues inside and outside our Department for advice and criticism; Mr. A. Robertson, Mr. H. Chorlton and Mr. J. Meadowcroft of the Card and Blowing Room Operatives and Ring Spinners Association. 74 EXHIBIT 6-76 Research Triangle Institute, Technological Feasibility Assessment and Final Inflationary Impact Statement ‘Table I-6. Total Installed and Annualized Compliance Costs: -all Sectors (Costs in Millions of Dollars) Industry Exposure .|Install-| Annualized [Direct Energy — Sector Limit ed Cost Capital Operating |Cost {| Annualized (mg/m) Charge Cost | cost Yarn Production | 0.5 211.8 33.8 6.9 20.6 61.5 0.2 984.4 158.3 15.6 67.9 241.6 0.1 2,802.7 450.6 ra 147.0 620.6 Cotton Ginning 0.5 16.9 2.7 4.9 1.8 9.4 0.2 292.2 47.0 13.2 30.3 90.4 | 0.1 343.6 55.2 14.7 35.4 105.3 Cotton Weaving 0.5 9.1 1.5 1.7 0.6 3.7 0.2 1,387.9 223.1 40.7 86.3 350.1 0.1 3,939.1 633.2 112.6 245.1 990.9 Waste Processing | 0.5 17.3 2.8 2.6 2.5 7.9 0.2 32.0 5.2 2.9 4.7 12.8 0.1 56.1 9.0 3.4 8.2 20.6 Total 0.5 255.1 40.8 16.1 25.5 82.5 0.2 2,696.5 433.6 72.4 189.2 694.9 0.1 7,141.5~- {1,148.0 154.0 435.7 1,737.4 * * +. * a III. BENEFITS OF THE PROPOSED STANDARD 1. Introduction This chapter identifies occupational groups exposed to cotton dust, discusses the inherent problems of benefit estimation, and estimates the benefits expected to result from implementation of the proposed standards. Yarn preparation workers and other cotton industry workers are discussed separately herein. 2. Occupational Groups Exposed to Cotton Dust Two large groups of workers known to be exposed to cotton dust are considered in this evaluation. They are: 75 1) yarn preparation workers, and 2) workers engaged in weaving, ginning, cottonseed oil milling, and industries using cotton waste. a. Yarn Preparation Workers In August 1971, 338,310 production workers were employed in cotton and man-made fiber mills* in the United States according to a Bureau of Labor Statistics (BLS) survey [1]. Cotton mills employed 193,014 pro- duction workers, while man-made fiber mills employed 145,296 such workers. Of the total production workers, an estimated 22,609 were employed in bleaching, cloth dyeing and finishing, and fabricating departments; hence, they were not considered part of the regular textile operations work force. The regular textile operations work force then becomes, by subtraction, 315,701. At the time of the BLS survey, slightly less than one half of the industry’s production workers were employed in mills manufacturing all or most of their products entirely of cotton fibers and approximately one-fifth were in mills manufacturing products of cotton and man-made fibers (blends). The balance of the production workers (thirty percent of the production work force) were em- ployed in mills manufacturing all or most of their prod- ucts entirely of man-made fiber. The BLS survey estimated the number of workers in cotton mills and all textile mills by selected production occupations. The estimates for cotton mill yarn prepara- tion workers were excerpted without change from the BLS report and are shown in Table III-1. The numbers of yarn preparation workers in blend plants, also shown in Table III-1, were obtained by multiplying the BLS estimates for all textile mills by 0.2 (the fraction of * Includes SIC 2211, Weaving Mills, Cotton; SIC 2221, Weaving Mills, Manmade Fiber and Silk; SIC 2281, Yarn Mills, Except Wool; SIC 2282, Throwing and Winding Mills; and SIC 2284, Thread Mills. 76 workers in mills manufacturing products of cotton and man-made fibers). Maintenance and miscellaneous worker estimates for both cotton and blend mills were prorated from figures for all textile production employees. The me- dian dust concentrations assigned to the severa] produc- tion occupations listed in Table III-1 are from Merchant, et al. [2], and are measured dust levels from six cotton mills and eleven blend m*'ls. The dust samples were of approximately six hours duration and were collected with the Lumsden-Lynch vertical elutriator. Inspection of Table III-1 reveals that 105,193 and 21,230 yarn preparation workers are exposed to cotton dust in cotton and blend mills, respectively, and are at risk of developing byssinosis.* * * * * s A commonly used measure of the benefit of health programs is the value of future earnings lost due to premature death. Since byssinosis rarely appears as a cause of death on a death certificate, and further, since the relationships are not well defined between cotton dust exposure, byssinosis, and chronic bronchitis-emphysema deaths which are more commonly recorded, lost earnings due to premature death could not be calculated. While excess mortality ** due to bronchitis and pneumonia has been observed in English workers exposed to cotton dust [8], it has not been seen in the limited number of studies of mortality in the U.S. textile industry. Thus, Enterline and Kendrick [9] studied 6,281 white male cotton textile workers aged 15 to 64 as a control population in an examination of mortality in asbestos workers. Using the U.S. white male population as the standard, a Standard- ized Mortality Ratio (SMR) ([Observed deaths/Expected * Office and yarn dyeing workers are not included. ** More deaths than would be expected in a given population dur- ing a given period. ° e * “OE 2- O22 “dd (C26 44?}4) £ ON “SL “LOA **pay *dnary t *.S434404 PLEIXOL VOIIOD Uy Saipnys Jsuodsay asog, * ue “32 “Queyrsay *y'¢ eG {921119 Su Bhd Wa49709_ “SN =" 2°0_“vorfuyysen * tog, us291 109 aes 126i 35 SOL} axel *AdAIng Obey Alisnpay *uogey $0 QUawIsedAQ “$"M zaDuN05 eIeZ 414 *pecuey pue voII0D *“USsd4d Ysnp 4ayV0 pue ysnp 1103309 gO aungxiy 3 “SI_dwes 4oRessgNLa LertqIaA anoy FIS, “$$9{ JO W03302 quarzad as Guy $sa2014) a ———— Of2" tz - CE SOt Widl t9l"0 BEL*2 seb"o rl6°9 SNOIUEL[TISjm Pur arueudzUy ey; 610 = o1"0 t10"s 62°0 = 02°0 602" ze 2905 Sit'9 O82 ce usek *surrein 0S> --- (42413 Aga | S29zSIMId] F 80t"t 126‘! aura zGuya *sacpusy s0asing Guy sing ep *furpuy: "Gut poogs 60°0 - 00°09 hv ae 4 62°0 - 02°0 Cel‘os Lear gKs zi ses Bupa wey, 49yI0 ‘awesy *suduMeds SiC*p 210°62 outsy Guys *suauuids ¢28 itg*2 ($49x}4) UAW yory>I=>> 00s‘2 960°8t mats Bujyvutds *sagy jig Gurusyds lti‘2 col*2t L&203qNs 6t°0 - OL’O veo" 69°0 - 0b°0 659° Wwesp Buoy ‘ssapuay saqqnis 6I°C - Ot’o 6SI 60 - Ob'0 ee Psepueys *sagpud, sagqnis 6€°0 - ot'0 £06 62°0 ~ 02°0 v08'2 S4APUI Dwiesy-Guimesg 6€°O0 - Of’O e9t 62°C - 02°0 8S9 S4apuay 49qu99 69°0 - 09°0 80l 62° - O2°t 2is‘t (S4aysjuty) ssapuoy paey 69°0 - 09°0 zt GL*t - OL t2t S4addisys psep 69°0 - 09°0 ttt 62" > 22° C2" S4apuisG pied Buimesp puc Guipsez . 2202QN5 ls y90°2 t oun % 5 rrr S4dPUI} Jd4IIg 6$"0-05°0 ze §9°1-09"t a t $aapua} sauadg 6£°0-0£°0 lez 6S 1-0S'I 6us4240 pur buyvodg 2q! 2/64) U¥0}3e43U22U0) $49440% 30 sdquny ( t/fan) yop .04 420009 S4PYAO}|] JO saquny 33g uP | PeW SS aseq_weypoi NOLIVILSISSY1? 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Other Workers Exposed to Cotton Oust ahd Assuncd [zposures Assumed Esposure Nuaber e } sic Title a Workers Cpoeration Oust Concentration (wg/a°) Method Country Reforerce 0724 — Cotton ginning 40,436" gin stand 1.05 (medtan) vertical U.S.A. r) elutrlator baling press 0.48 do éo ¢o other 0.59 do 6o eo overall 0.67 do do 6o 2074 = Cottonseed of mills soo® seed house 73-$90 total dust filter thimble Egypt 4 linter 5-18 de Greenburg- Australts s Saith impinger baler 20-37. de do 221 Veaving mills, cotton slashing and warping 1.0-1.03 feedtan) vertical U.S.A, 2 - es elutriator 4 weave rous 1.0-1.09 do do do 83,216 cloth roca 1.0-1.09 do do do pa incenance 1.0-1.09 do éo éo 2221 Weaving mills, sansude slashing and werpthg 1.0-1.09 do éo an 2 fiver and silk weave roca 0.59 do do Je cloth room 0.59 do co eo maintenance 0.59 do do 60 224) Marrow fabric mills 23,500 weave room, blend afl! 0.89 do vertical U.S.A, 2 : elutristor weave rous, cotton af}! 1.0-1.09 do ¢o vo 2293 Paddings and upholstery 3,500 garnett roos 6.06 (mean) éo ¢o + fillings 2294 Procesied teatlle waste 3,100 sorting 6.5) (respirable horizontal Toyrt 7 ‘ éust) elutrisetor fiber loosening 6.84 do do 6o carding . $.02 ¢o do do splaning 1.12 eo vo felt processing 3.20 de 6e 60 2296 = Tire cord and fabric 2,214¢ weave roca 0.59-1.09 (medtan) vertical U.S.A, 2 : elutristor 2658 Mattresses and bed- 23,200 gernett roca 6.06 (mean) o U.S.A. ] springs tepe edge 0.36 do éo 40 quilt 0.28 do .& do boa spring 0.43 @& 6o 6o hand tie and 0.24 do do oO coll tack everall $.02 do do bo &@ Odtelned from 1972 Census of Manufactures unless nutet otherwise. bd If a ain crew ts 12.5 workers (Mattonal Cotton Courcil), then tn 1972 there would have been 12.5 workers/gin X 3.517 active gins * 43,953 workers. Wowever, 8 percent (3,517) of these are assueed te be office workers, Wence, the workers exposed to.cotton . Gust fs estimated as 40,446, ; ¢ Twenty percent of production exployees (4,500) Is assume! based on conversations with {ndustrial representative. ¢ e@ Estrured. ot 1977, Part § Cottua 79 deaths] X 100) of 59.4 was calculated for respiratory disease, indicating that respiratory disease mortality in white male cotton textile workers is less than that of the U.S. white male population. This finding was confirmed and extended in a recent analysis [10]. The results of a study of mortality in female cotton textile workers re- ported by Daum, et. al. [11] are suggestive of increased emphysema deaths. Given the large number of female workers in the cotton textile industry (about 55 percent of the work force), it is especially unfortunate that hard mortality data are not available. SMR’s for chronic bronchitis and emphysema in both male and female cot- ton textile workers would be especially appropriate for use in this analysis; unfortunately they are not avail- able at this time. * o * * * 4, Engineering Controls Engineering controls are defined herein as substitution of a less toxic substance for a more toxic one, modifica- tion or isolation of a process, or local or general exhaust ventilation for the purpose of reducing or eliminating a worker’s exposure to a potentially harmful substance. Thus, dust concentrations in the textile industry may be controlled by modification of the dust-producing processes or operations, or removal of the dust from the environ- ment by ventilation. a. Yarn Production 1) Process Modification The yarn production process is essentially one of fiber cleaning and alignment with the desired goal of remov- ing all material in the cotton except mature fibers, which are then spun into yarn. The dust associated with cot- ton processing is thus an unwanted residue which is inherent in the operation. Textile processes have changed 80 little over the past several decades although there have been modifications of some operations, primarily to in- crease productivity; hence, process modification, other than improved maintenance, has had little effect on dust concentrations. The design of high speed cards did re- quire substantially improved dust capture to avoid pro- duction problems arising from the larger volume and greater agitation of materials being processed. On the other hand, open end spinning, which eliminates roving, may produce more dust than ring spinning. Decreasing machine density in a work area, which is mentioned in the literature as a means of reducing ex- posure, does not, in fact, reduce the concentration of dust in the room air. Area dust levels would build up more slowly in the larger volume of room air, but would eventually reach the same equilibrium levels if. other controls were unchanged. This technique is, therefore, felt to offer little to the solution of the problem of dust control in the textile industry. Replacement of older, low-speed production equipment with more modern, high- speed machines can: reduce the generation of dust. How- ever, very fine yarns cannot be produced by the higher speed equipment, so replacement is not a universal solu- tion. Only in instances where large amounts of lower quality yarn are desirable would replacement be ap- plicable. Presently, process modification appears to be a feasible but limited alternative for dust control [2]. 2) Ventilation The capture and removal of dust from the air at the point of generation (i.e., local exhaust ventilation) ap- pears to be the most efficient method of dust control at the present time. Effective dust removal in cotton process- ing areas depends on two factors: capture devices located as close as possible to the point of dust generation and efficient filtration methods [2]. Considering only the tech- nological feasibility of efficient capture devices and filters, 81 the scope of ventilation control at the dust source could range from complete enclosure of each machine (including total enclosure, ducting, and filtration) to application of local exhaust ventilation hoods and ducts and adequate collection devices. Most older textile equipment has very few enclosed dust generating points. When local exhaust ventilation systems are included, they are usually retrofitted devices. The efficiency of these devices can be improved signifi- cantly by providing as much enclosure of the machine as practicable. By confining the contaminant to a smaller volume, air flow requirements, and hence, energy costs are reduced. Since the air volume required for the major- ity of the dust capture devices is directly proportional to the capture distance, a reduction of one-half of the capture distance results in a corresponding decrease of one-half of the air volume required, and hence, corre- sponding reductions in energy requirements. Many of the more modern machines are well enclosed and are equipped with dust capture devices as a standard feature. There is little variation in the physical configuration of the capture devices required to attain the levels of control ranging from 1.0 to 0.2 mg/m*. Vendors of exhaust ventilation systems currently prefer to add dust capture pickups, filtration devices, and/or increase air- flows to reach desired room concentrations. The level of dust control effected is generally related to the number and design of local exhaust hoods, air volumes, and the number of filter Stages through which the contaminated air passes. By employing a sufficient number of well-designed dust capture devices (e.g., hoods, slots, and plenums), sufficient air volumes, and efficient single-stage filtration, dust levels in the range of 1.0 mg/m* (total dust) can generally be expected in the working environment; with two-stage filtration (and air washing) , levels not exceeding 0.5 mg/m® (V.E.) may be 82 expected; if efficient third-stage filtration is added (and air washing), workroom dust concentrations should not exceed 0.2 mg/m* (V.E.) fcr an eight hour time-weighted average (TWA) for yarn-producing mills. Controls to comply with a 0.1 mg/m?’ (V.E.) level of control are cur- rently technologically feasible, but may require complete equipment enclosure and stringent three-stage filtering of both recirculated and make-up air in the ventilation sys- tem since dust in the ambient make-up air may on occa- sion exceed 0.1 mg/m* (V.E.). Control of cotton dust concentrations in the yarn manu- facturing industry to levels as low as 0.1 mg/m* (V.E.) thus appears to be technologically feasible by application of existing technology. This assessment is based on RTI’s understanding of the processes and operations in- volved, the amount and velocity of particle release from various dust generation points, and the general capabili- ties of current engineering controls. It appears that con- trol of dust levels to meet the 0.1 mg/m exposure limit will require: (a) complete enclosure of openers and pickers, cards, draw frames, combs, roving frames and spinning frames with air exhaust; (b) filtration of the exhaust air from the enclosures to levels approximating 0.1 mg/m*; (c) recirculation of the filtered exhaust air through the central air conditioning system, where addi- tional cleaning takes place; and (d) filtration of air con- ditioning make-up air to a level not exceeding 0.1 mg/m’. Such a system is conceptually feasible although no em- pirical verification can be provided since it apparently has not been tried in any installation. The configuration of the enclosures may be expected to provide the greatest design problems, since it will be necessary to provide numerous access ports and a means to check for operating malfunctions either by direct inspection or by automatic indicators. 83 2) Yarn Processing Yarn processing is a term used to cover those opera- tions through which yarn may pass after leaving the spinning frame. These include winding, spooling, twist- ing, warping, and weaving, all of which are described in Appendix A. Engineering controls are available for four of the five processes cited above; the exception is weaving. Based on information obtained from vendors, local exhaust ven- tilation systems could be used to maintain median dust concentrations of 0.5 and 0.2 mg/m® in areas housing these processes. RTI estimates that the 0.1 mg/m* limit could be achieved by adding filtration of the make-up air for the air conditioning system to the local exhaust ven- tilation systems. Commercially available engineering controls applicable to weaving processes were not identified and it is, there- fore, assumed that none exist. Some experimental work has been done with the concept of using general room ventilation as a dust control measure in weave rooms. This basically consists of modifying existing ventilation systems to produce air currents of such speed and direc- tion as to capture a portion of the dust emitted from the weaving process and then liltering the dust from the air. No information on cost or effectiveness of this con- trol technique is available. Although the residue of particles of bract, stem, and leaf (the material suspected of being the causal agent in byssinosis) in weaving yarns is relatively very small, there is substantial evidence that enough exists in the dust found in weave rooms to pose a significant hazard for workers exposed over long periods. The bulk of weave room dust, however, apparently is sizing used to treat the yarn and the total airborne dust normally will exceed the 0.1, 0.2, and 0.5 mg/m* exposure limits considered 84 in this analysis, although cotton dust may be only a small portion of the total. No documentation of engineering controls for looms was found in the course of this study. The discussion that follows is, therefore, entirely speculative. Three kinds of engineering controls may be suggested. Perhaps the simplest and most obvious is to isolate the weave room from other dusty areas. It was observed that in inte- grated mills the doors connecting the weave room with yarn production areas may stand open during production, with substantial dust drifting into the weave room. Elimination of such a dust source is easy and poses no cost penalty. Similarly, room ventilation systems should be separated so that dust is not introduced through recir- culation from dusty areas. The room ventilation system may be the primary means of lowering dust concentrations in the weave room. A very high air flow through the room, combined with high efficiency filtration, would appear to be appropriate. The use of floor vents drawing air at high rates from under looms may also be used. Another engineering con- trol technologically feasible for control of most looms, apparently is local exhaust ventilation. It is probabie that hoods can be installed above most looms and that quite high rates of air flow can be employed to capture dust released from the loom or blown off by travelling cleaners where they are employed. Without knowing the range of possible specifications for air flows or distances from hood to dust source (which would require specific preliminary design analysis), it is not possible to estimate the collection efficiencies that can be attained with local exhaust ventilation. Air filtration is less difficult to con- ceptualize, since high efficiency can be achieved with multi-stage filter systems. Good housekeeping procedures provide one other obvi- ous control measure that can contribute significantly to 85 maintenance of low dust levels in the weave rooms. Care- ful and thorough cleaning of the room weekly to remove accumulated dust from equipment and from the room in general tends to prevent the build-up of excessive dust levels. This should be done at a time when production is shut down. The aggregate effect of a combined control program such as discussed here is hard to estimate. RTI engineers are of the opinion, however, that such a program may reasonably be expected to achieve an exposure limit of 0.2 mg/m*® TWA. It is not clear whether a limit of 0.1 mg/m* can be attained in this way. * * * * * b. Reduction of Workers Exposure: Yarn Production Mills A wide range of engineering controls are technologically feasible to control dust levels in yarn mills. The industry naturally has chosen methods that are most cost effective. The controls specified herein as most probable for com- pliance with the proposed standards are those now in use, modified to achieve the required efficiencies. Their feasi- bility has been demonstrated and they are readily avail- able from vendors. These controls reduce the dust con- centration in the work area by capturing and removing the dust as it is generated through the use of local exhaust ventilation on production equipment. A typical system consists of dust capture devices (such as hoods or enclosures over dust emission sources) , ducts for trans- porting the contaminant, and a filtration system for ¢iimi- nating the dust from the airstream. These systems are discussed in Chapter IV and Appendix A. Basically, the physical configuration of local exhaust ventilation systems is independent of the dust concentra- tion considered. However, differences do arise in the additional stages of filtration required to control at the lower dust concentrations and in the dust capture devices and air volumes. The plant areas in which the systems 86 are employed also affect the control strategy required to comply with different levels of control. To achieve dust concentrations not exceeding 1.0 mg/m’, it is as- sumed that local exhaust ventilation systems are now employed on opening, picking, carding and drawing opera- tions and that a single stage of filtration is used. To achieve dust concentra.ions not exceeding 0.5 mg/m! (V.E.), RTI’s analysis indicates that, in addition to the above operations, local exhaust ventilation will also be ap- plied to combing, roving, and spinning operations and that two stages of filtration will be employed. To achieve dust concentrations not exceeding 0.2 mg/m® (V.E.), these data indicate that ventilation systems will be ap- plied to the same operations with a third stage of filtra- tion added, consisting of either an electrostatic precipita- tor or a high efficiency bag filter. Control to the 0.1 mg/m* limit requires enclosure of equipment, exhaust to high efficiency filters, and filtering of air conditioner make-up air. In addition to engineering controls, a program to re- duce worker exposure through improved specific work practices designed for each work position will be insti- tuted. Although no specific modifications in work prac- tices are suggested, for costing purposes it was assumed that a study of the work practices for a total of 21 work positions will be instituted by firms in the industry to identify possible improvements and workers will be given appropriate training based on the findings of the study. The type of work practice changes that may be instituted are discussed in Chapter IV. During cleaning operations and certain other opera- tions, such as waste collection and bale opening, which require manual handling of cotton fiber, the described ventilation controls are not adequate to maintain the exposure of the individuals involved in these operations at acceptable levels (see Chapter IV). Therefore, the probable methods of compliance include the use of per- 87 sonal protective devices for these individuals. Specifically, it is assumed that respirators are used by all individuals involved in blow down, stripping, grinding, dry sweeping, and manual trash collection. It is also assumed that disposable respirators are the most probable choice of the industry. * x € * * 4. Compliance Costs Costs associated with the implementation of controls to attain proposed cotton dust standards fall into two general categories: ® costs associated with the installation/operation of engineering controls © costs associated with ancillary programs, e.g. medical surveillance, environmental monitoring, respirators, recordkeeping, and training. All of the cost estimates shown are calculated as the incremental costs required for compliance with the pro- posed cotton dust standards, at alternative dust exposure levels. It is assumed that the existing regulation limiting worker exposure to dust concentrations not in excess of 1.0 mg/m* (TWA) applies to yarn production and processing industries and that for these industries there is no incremental capital cost for engineering controls to comply with an exposure level of 1.0 mg/m* (TWA). At the time this study was performed it was evident that not all firms were, in fact, in compliance with the existing regulation, although the actual level of controls operating in the cotton yarn industry could not be deter- mined. In order to provide a reference point for the incremental costs presented in this report, the costs of going from zero dust control to compliance with the ex- isting 1.0 mg/m* exposure standard was estimated at $143.3 million, in 1974 dollars.’ Other costs associated with additional requirements of the 1.0 mg/m* standard scenario, such as medical, posting, personal protective 7% 88 equipment, employee information, work practices, and monitoring and recordkeeping are addressed and are shown in the appropriate sections. There is some ambiguity regarding the application of the existing regulation to the other industries for which costs are shown. It is Department of Labor policy that no regulation will apply to an agricultural operation un- less it is so stated explicitly in the regulations. Since cotton gins are not explicitly covered by the existing reg- ulations, it is assumed that industry is not covered. It appears that the cotton waste processing industries and the cottonseed oil industry have not been required to comply with the existing regulations although it might be construed technically to apply to them. For this analy- sis, they were not assumed to be in compliance with the current standard. Costs associated with compliance at the 0.5, 0.2 and 0.1 mg/m*® (TWA) (TWA) are shown as the increments required for compliance at those exposure levels assum- ing compliance with the current regulations, where applicable. a. Yarn Production 1) Engineering Controls For engineering controls, capital costs include the pur- chase price of the control systems, labor and materials required for the installation of the control systems, and costs associated with building and utilities modification required for the installation of the control systems. Oper- ation and maintenance costs include the labor and mate- riais required for the day-to-day operation of the control system, including repair parts and filter replacement. Energy costs, expressed as kilowatt hours, are reported separately and reflect the incremental increase in energy consumption resulting from the operation of the control system and the increased load on existing air conditioning systems. Additional labor requirements (man-hours) to operate and maintain the control system are also pre- — 89 sented. These cost elements are integrated in estimating annualized costs in the economic analysis of Chapter VI. Engineering costs were initially computed on the basis of cost per cubic foot per minute (CMF) of air required to control dust generation from yarn production and processing equipment. These were then converted to a per machine basis, and subsequently to a cost per pound of raw cotton processed through the equipment. Data used in determining costs were obtained from control system vendors, textile plants in which control systems are in operation, and from data published by the R.. S. Means Company pertaining to the costs of various types of con- struction. Table V-1 contains the basic cost data by equipment type for yarn mills. Details as to how these data were developed are presented in Appendix B. Equipment inventory data were obtained from US. Bureau of Census publications. Equipment capacities and throughputs were obtained from various literature sources. A summary of these data is shown in Table V-2. Details as to how the data in Table V-2 were generated also appear in Appendix B. In order to provide estimates of the cost. of engineer- ing controls for yarn manufacturing processes to achieve 0.1 mg/m' limits, it was necessary to extrapolate from the costs for less stringent controls. This procedure is valid as a means of providing a first estimate of coat because (a) the control techniques postulated to achieve the 0.1 mg/m limit are essentially extensions of the techniques used for lesser control, i.e., ventilation and air filtration, and (b) the cost data for controls at 1.0, 0.5, and 0.2 mg/m’, as well as RTI’s experience with similar controls in other applications, indicates that there is a reasonably stable functional relationship between control cost and level of control. Mathematically, this calculation, for any machine type, is as follows: where: X = control cost at the 1.0 mg/m® limit, Y = control cost at the 0.5 mg/m limit, Z = control cost at the 0.2 mg/m* limit, and U = control cost at the 0.1 mg/m? limit. Solving for U gives the expression: _ 56 (ZY)? “@ YX The incremental control cost at the 0.1 mg/m? limit, therefore, is U - X. 3) Overall Industry Costs Industry-wide costs, initial and recurring, are shown in Table V-5. These costs are based on applying feasible controls on all cotton/yarn equipment regardless of type of fiber being processed. Exclusion of equipment process- ing man-made fibers only could reduce these costs by as much as 30 percent. Presumably, a mill processing syn- thetic fibers exclusively will not be subject to regulation under the proposed standard. It is not clear, on the other hand, just how the proposed standard will be applied in mills that process both cotton and synthetics. The equip- ment used in both processes is essentially the same and is convertible from cotton to synthetics and vice versa. The conservative estimate was made, therefore, that controls would be applied to all the production equipment in mills processing cotton and cotton-synthetic blends, even if part of their product is pure synthetic. +Z. 91 Costs per pound of raw cotton are shown in Talie V-6; manpower requirements in Table V-7. Where a range of costs is presented, the lower figure reflects the cost of controlling equipment on which cotton or cotton blends is processed; the higher figure reflects the cost of con- trolling all yarn processing equipment regardless of fiber being processed. ’ . * * «e * 2) Weaving a) Engineering Controls Cost estimates for engineering controls for yarn proc- essing equipment in weaving mills were obtained by soliciting estimates from vendors of dust control equip-. ment. Costs were estimated using the same analytical, steps as described for the yarn production industry (See p. V-10). Table V-9 gives the ventilation requirements to control the median dust concentrations to 0.5 and 0.2 mg/m! (V.E.), and gives the cost per machine, the annual main- tenance and operating costs, and the annual energy con- sumption for dust control systems for the processes indi- cated. As indicated in Table V-9, no controls are esti- mated to be required in twisting, weaving and warping to achieve a median dust concentration of 0.5 mg/m® (V.E.). * r * * * Additionally, based on vendor data, it is estimated that dust control systems for winding and spooling would be required in only 20 percent of the installations to achieve 0.5 mg/m* (V.E.). These installations are those in which the yarn being processed was manufactured from very low quality cotton or which for some other reason have a greater than average dust problem. To estimate the cost per machine for dust control systems, the costs obtained from vendor data were multiplied by the estimated frac- tion of installations which would require dust control *“spurpueys pasodetd [pe 4ol OOO'Gios Aue SzSS> ius Jazjy “S[ouquod BuiruaautGua jo uopze;,e}3Ssul Guppuad ‘,os3u0d o4az Cutunsse ‘pojued eduetjduoz-aud Buranp £450) iy “ILTPLLeA® PZED YsazelL ay ‘LOL QdUINSNOD 1107169 MeL F/6, UO P3seq BuP UMS $3569 491170 Liv “Lape ZeYR JO SZULBAZSUOD BYR YZIM YUazs;suod 8q OF [A AaZdeY UL LOpoM yndyng-ynduy Jy OJUL pauszus sua $}]Ss03 assay] *(@Leq/q, OBP) SaLeq GzZ‘Z 40 YOLyZdwWNSUOD UOR}OD Me Z/GT UO paseg aie [ ] SJANXDeUG UL UMOYS S}509 3 ‘passadoud uaqij Jo Ssajpuebau quauidinba swazshs u0z3209 {Le 4oj pauinbaa sjosjU07 R *$3SOD UOLJeULUZIOpU; pue BuLULe4y au4Z-su0 pue *SzS0> quawdinbzZ [eqLde) Sapniou] fi 4snrvad bur peusdo Dae S_GAQWT? butasvutous Ci°vdt] (8°28) [2°22] (2° tvez] [8666 ] [2°stz] O'Esl L*bZ L'b2 8°SLSz 9°88 6061 /gierol O'T o'l o'r - ~ fgtesboud 407 eALdsay) “4 ’ - 10 10 10 Butzsog v‘0 “v0 "0 S*? S‘t S*t HulsozpUuOW LeyUaWUOILAUG ra | 2°L rae | et + 2% ra | BURL LLaAINS [PIL pay (2°tSt] e°vet | [s°69] s"t9 [6°02] Sst - - - /g53800 A6s0N3 & 5°6 1 (2°9 ) (v°2 ) (s*8Zet) (e°96b ) (€°66 ) saures4 Buyuurds BT (O° ) (0 ) (e*sst ) (o°00T ) (e*se ) Buy aoy 10 (T°0 ) J (et) i we} e:4 squio) £°0 (p50 ) (to ) (6‘b2t ) (6"6€ ) (tz) sawesy Meg ‘7s (S*I ) (s*0 ) (2°602 ) (2°22 ) (12 ) spue) vil (6°0 ) (v0 ) (9° tet ) (e'e9 ) (pat ) 6ujuea,) pue Buyuado 2°91 ‘ol Le l'orsz 8°68 2°S8l [zurudynby Loryues git/Ou 1-0 git/Ou 2°0 gt/ou so gives to clu/bu 2°0 g@/m S°0 quawdinhz yo adty (S42, 100 JO SUOL{LIW) $3809 Buysunday (sue_{og JO Suot Lith) Ai $3SO) Let ztuy 4 UOLZINPOAg UALA 2SZLW] Junsodxz a[qisspuuiay sAaLYDy 03 $380) Gulusnsay pue LeLzpUy api M-Aagsnpuy LeqUsUM10.UZ PazeU3sz “S-A aiqzyL 93 systems. Because of this, the cost figures appear quite low. This method of presenting costs was chosen to permit total industry costs to be obtained by multiplying the fig- ures in the table by the total equipment in place. A simi- lar discussion applies to the figures given for the 0.2 mg/m* exposure limit. In this case, based on vendor supplied data, controls are estimated to be required in 80 percent of all installations. Installations not requir- ing controls are those which process yarn made from very high quality cotton. Consequently, the fraction which re- quires dust control systems is much greater than for the 0.5 mg/m*® limit. Data on the number of units of each piece of equipment now installed in the industry, shown in Table V-10, were obtained from [3] and [4]. Costs for weaving looms are based on engineering con- trols estimated ‘to be applicable to the operation. For cost- ing purposes, these consist of local exhaust ventilation systems over the area of the loom where the shuttle passes back and forth. It is estimated that a hood for this application would need to be aproximately two feet by five feet, based on an | * * * * a estimated average loom width of 54 inches. It is further estimated that an air velocity of 200 feet per minute at the face of the hood would be needed to adequately cap- ture the dust, which results in a requirement for 2,000 cfm per loom. The costs per cfm for application of hoods in such systems are estimated to be about the same as in the yarn production industry. The figure used for deter- mining costs was $3.00 per cfm. Using this figure and an air requirement of 2,000 cfm along with the estimated 209,792 looms [4] processing cotton or blends of polyester and cotton, a total industry capital cost of $1,258.75 mil- lion is derived. Annual operating and maintenance costs are estimated at 3 percent of capital costs, or $37.76 mil- lion. Energy consumption is estimated at 12.5 Kwh/ 94 ig0‘'2S*t | €2°S6e*bl Z9°St2°* Ol] 98° BLS‘ S9K*6ES O8'byz"S} 95°292°2G §86S2°8S2°T nnad woee ooc- ---- swoo] 940° 061 81°09 €SO&e*L €16°601 826°99 162 692 0S° 890 202° 8€ none aes win ovee Suadsem 613°SZL 66°€19 09° LEZ‘ 862° bEL 806° 19 O2E * LEZ Sf Efe v9b' lb —-- ——- es sic SAITSIM] Sy9*2bl 2b° L6¥ £5666 0/2001 o1s*os Lel'sdt 09° 1SE 90€°SE Lis‘9 eet “ie L4LS°S¥ 880 °9 $43, 00ds S20‘ tt 2£°88 20°SSL v6L°L1 006‘E OLOLE 665° #S $92°9 609‘ 1 Ose *s £92°tt 029°t S4apuim RNA oT (247,018) | (01S) (24 7sq-wew (ax 7yny gt} (447,018) (018) [[4%7say-wew]( aX 7 gt} (447,018) (018) 4oqe} Afisduj suo{jeuedg 1e3}de9 409e} A630} suo} 3euadg 1e34de9 40qe} ABs9uz | Suojjesadg| jez;de9 - pue pue pue quad ynb3 ja2ueuaz ul PW J 2UeUS2 UY} PW a2ueuazU I ey —-—---—— : w/6u {° ' ° i cf/ t°o ct/Su 2°0 ct/bu S“0 (Gujaeam) s043u0) bursaaus6uz 404 $350) Aagsmpuy (e370, “[ I-A e191 95 cfm/yr., which is the approximate average of systems in the yarn production industry at the 0.2 mg/m* (V.E.) level. Cost estimates for the 0.1 mg/m® (V.E.) level were obtained by assuming the increment over the costs of 0.2 is equal to that determined for the yarn production industry. The costs obtained for each level are given in Table V-11. + * * * * The Long-term Arrangement Regarding International Trade in Cotton Textiles (LTA) provided the vehicle for import quotas on cotton textiles and apparel and was of major importance for a number of years. The sharp rise of man-made fiber products in the late 1960’s led to ex- panded trade agreements in 1971, and finally to the Multi- Fiber Arrangement Regarding International Trade in Textiles (MFA), which dealt with cotton, wool and man- made fiber products. These arrangements have tended to smother the effects of a small change in the relative prices of domestic versus foreign textile products [See Section 10 of Appendix C.I]. * + * * * 4) Impact of OSHA Cost-Related Cotton Yarn Price Increases An important intermediate step in determining the final impact is to determine the impact upon plant profitability of the different exposure limits. This exami- nation leads to other considerations such as industry- wide price increases resulting from control expenditures and the availability of labor force, energy and capital for investment in control equipment. Estimations of potential plant closures also resulted from this analysis. This analysis relies upon the assumption that the com- panies affected by the regulations will pass on fully their increased costs via price increases and thus escape the cost burden of the proposed OSHA regulation. 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S000° £200° 8910" S‘0 8°9092T WILOL 8800° 2200° p 4aqaweurd {eroueury Bburyey Aq pays; {dworce sem UOLJELJUL SLYL “S[AAAL H/G1 02 S2INSAU asoyy burze_zut Aj quanbasqns Aq pue 02-8961 Pue 99-S96L Poluad Ph ¢ ay? 2Oy ejeEp butbesaae Aq pauieiqo auam SWULJS JO SSOLD aZIS Aq Suaqawesed jPrduPULy ay), $900 9v0°0 800 916°0 SIZ°0 UUU ‘000 OU0' TS 4240 2bu 0 920°0 900 vS6 0 2290 UU0‘0UG*OUUTT = — LOU‘ UDO OLS 0vo'o BE0'°0 990°0 bE6°O 9£6 0 UL0 * 000 ‘GUS — VOL‘ OUL‘OSZ d€0°0 820°0 1S0°0 6b6°O $91°0 060 * G00‘ US2z — 000600‘ ULI 0v0°O 820 °U 1s0°0 606 °U 169°0 000‘ UL0‘ OOT — 000° 0000S 9b0°0 $20°0 9b0°0 bS6 0 UvS 0 G06 *U0U* US — O0uU*UUU ‘UT > 2t0 0 020°0 6£0°0 196°0 8lb°U UU0*UU0 ‘UT — U0G*uuUs vai vv0'"O 610°0 St0'0 $960 S9b°U 090 “UL0'S — OuU‘uOU'T b£o°0 st0'0 b2UU 9160 6£b°U WU0 *OUU'T — 00U‘UUS §00°0 p00 "0 z10°0 886 “0 bES"O 000 ‘005 — QU9* OU £60°0- 9£60°0- 0£0°0- ofo'[ ¥E9°U 000 ‘OUT — QUu0‘0S 920° 0- 2610°0- Z10°0- ZW €eZ°0 000 ‘0S $ — Wwo'sz $ Ii t'o- 661° I- 8bI I- 8bI 2 U8Z OI 000*S2$ s4apun 1bo'O S20°0 9bU'0 S6°U 219 °0 Sapuedwo) (iy ‘abesaay Wow Ssauy 0} Saxe] 4waz4y Saxe] auojag $3S0) [e320] S7essy jelol sapes penuuy uAnjQay jO azey 31504 3tJO4g a(SPL2S JO 4e10G/$ = 34uUN) Satuedwoy 3(13x91 Jo sassely azig quauajjig Guowy ssazowesey (erQueULYy D1Sey yo uostuedwoy “YI-1A ayqey 108 vices are applied to each piece of equipment and there are no significant economies of scale). Therefore, sub- stantial differences are not expected in relative changes of post-control profitability from pre-control ones due to different production cost increases among the different size classes of companies. The ratio of capital requirements to profit after taxes is used in this study as a measure of the ability of each class of textile company to finance the compliance capital costs. If the ratio is substantially larger for a size class than those for most other size classes, then those com- panies belonging to this size class are likely to have capi- tal shortage problems and probably will be forced to rely heavily on external debt financing, and thus pay higher capital costs. Therefore, rates of return to investment for these companies will be further depressed. One realistic and convincing theory of investment is that the level of investment expenditures is proportional to profits'’!. Two alternative rationalizations of this theory can be offered. First, realized profits measure expected future profits and so it is almost a tautology to say that investment is governed by profits expectations. Second, the rate of investment may be constrained by the supply of funds. In reality, some kind of financial constraints operate at all times; the cost of funds sched- ule becomes highly inelastic when internal funds are ex- hausted. The cash available for investment, which is the source for internal financing, is usually measured by the sum of retained earnings and depreciation allowances. However, there is a strong recent claim by corporate finance analysts that the depreciation on plant and equip- ment, which are subtracted from gross profits before computing corporate tax bills, cannot begin to cover the cost of replacing production capacity'*). This under- depreciation is largely due to the fact that such produc- tion capacity will be very expensive to replace because 109 of recent high inflation and that depreciation allowances are based on original purchase costs. The above discussion implies that the cash available for both capacity expansion investment and nonproduc- tive capital investment such as capital costs for com- pliance with the standard should come from the retained earnings. Therefore, the profit after tax should be a good measure for the flow of internal funds available for investment, remembering that the average share of re- tained earnings out of profit after taxes has remained stable over time for the textile industry. The above analysis indicates that as the ratio of compliance capital costs to profits after taxes is larger, the company is likely to face more severe difficulty in financing the compliance capital. First, because the smaller profit after taxes predict the poor expected future profits, and second, because the smaller profit after taxes indicates the smaller flow of internal funds available for investment. Table VI-11 presents the ratio of capital costs for compliance to profit after taxes for each size class of company within each of the six SIC sectors and for three exposure limits based on the financial data by company size presented in Table VI-10. The profits after taxes are calculated assuming that prices of industry outputs have been raised enough to maintain pre-control return on investment as shown in Table VI-8. It seems clear from Table VI-11 that the greatest difficulties in financing capital costs for compliance will fall on the two sectors, SIC Code 2211 (Weaving Mills, Cotton) and SIC Code 2281 (Yarn Mills, Except Wool). The exposure limit of 0.1 mg/m* will require compliance capital ex- penditures in excess of 700 percent of annual profits after taxes for all the size classes of companies in SIC Code 2211 and in excess of 500 percent of profit after taxes for all the size classes of companies in SIC Code 2281. The exposure limit of 0.2 mg/m? will require com- pliance capital expenditures in excess of 300 percent of 110 annual profit after taxes for all the size classes of com- panies in SIC Code 2211 and substantial expenditures in SIC Code 2281 as well. However, the limit of 0.5 mg/m* reveals significantly smaller ratios for all sectors except some smaller size classes in SIC Code 2211, and the ratios are less than unity for this exposure limit for all size classes of firms in each of the six SIC sectors, ex- cept SIC Codes 2211 and 2281, and for the medium to small classes of SIC Code 2221 and 2284. The ratios for the 0.1 mg/m* exposure limit are ex- tremely large for SIC Codes 2211 and 2281, ranging from 7.95 (compliance capital costs equal to 795 percent of profits after taxes) to 28.96 for SIC 2211, ignoring three smallest size classes for which pre-control profits were negative. The comparable range for SIC 2281 is from 5.32 to 24.81. For the 0.1 mg/m* exposure limit, even SIC Codes 2221 and 2284 reveal large ratios rang- ing from 2.51 to 16.73 for SIC Code 2221 and from 1.94 to 14.19 for SIC Code 2284. The ratios for the 0.2 mg/m* exposure limit are also large for SIC Codes 2211 and 2281, ranging from 3.56 to 20.46 for SIC 2211. The comparable range for SIC 2281 is from 2.19 to 15.82, and for SIC Code 2221 the range is 0.95 to 8.29. The ratio for this exposure limit exceeds unity for all but the largest size class in SIC Codes 2221 and 2284, and is below unity for nearly all size classes in SIC Codes 2257 and 2296. In all cases, ignoring negative profits (for which the conclusion is clear), the ratios generally decline as company size in- creases, i.e. the ratios are larger for small size classes than for larger size classes. Also, the differences in the size of ratios between classes is quite pronounced, sug- gesting that the difficulty of financing the compliance capital costs within a given SIC sector is inversely re- lated to size of firm. These observations are true for each of the 0.5 mg/m’, 0.2 mg/m* and 0.1 mg/m* limits, but the impact is much more pronounced at 0.1 mg/m* level. 111 “OL-IA 2192] UL uMoYs se xe 49358 345040 (043U09-aud jo ONLeA BAL Iebau ay2 03 anp aue “OL-IA pue SOSSEL2 OTIS Sai pews aauyy ayz u0y 8-IA seiqey SOf}e4 DALZebAU ay, :$22un0s 18° o£ "0 10°0 61 §9°0 £1'0 0v'0 £10 £0°0 000°000"000' I$ .12A9 Iv"! £S°0 z1°0 b2°€ 6I'I 620 02°0 p20 s0°0 000‘000‘000't ~- 000*000'005 00°! L€°0 80°0 Se°Z ¥8°0 it'0 6b°0 it'0 £0°0 000°000°00$ — - 000*000'0Sz 1e"l 6b°0 110 £0°€ oll 22°0 $9°0 22°0 b0'0 000°000'0S2 - 000"000'00I Ta | 0s"0 110 60°€ €l't £2°0 99°0 £2°0 60°0 000000001 - 000‘ou0'NS abl SSO £1'0 6o°€ b2"t S2°0 £2°0 $2'0 s0°0 000°000‘0S - 000" 0U0'OT 0g°I 89°0 91°0 60°» 2s"t 1£"0 06°0 1€°0 90°0 000‘000'01 - 000°000'S To £1°0 41'0 62°b 29°1 ££°0 960 £e°0 90°0 000°000'S - 000'000' t 2e°2 06°0 120 00°S 16°1 Iv'0 at 190 80°0 000‘000° I - 000°00S eZ 10°€ £1°0 61 pI 62°9 tpl 68°E Ov'I 82°0 000*00S - 000‘001 12"I- Ib"0- 600- 19°€- onI- 81°0- $S‘0- g1°0- £0°0 000001 - 000°0S 0S*2- 08°0- i10- 91°6- £0°2- be “0- 80°I- be ‘0- 90°0- 000°0S $ - 000°S2 $ £0°0- 10°0- —-£00°0- 90°0- £0°0- 10°0- 20°0- 10°0- —- 100°0- 000°S2$ sapun Th $s°0 £1°0 ee b2°1 $2°0 £2°0 $2°0 s0°0 sapuedwoy (iy ‘abesaay ca/Su 10,4 /6u 2-0 w/w 5*9 ct/4 1-0 ,8/bu 270 ,w/bu 50 ct/ 10 8/6 2°90 ,w/bu “0 Sales enuuy 9622 DIS vaz2 JIS tSe2 31S 2€°S 61°2 1s‘0 1S*2 $60 12°0 S6°L 9S°€ i8°0 000‘000‘000*1$ 4249 66°C 29°¢ 68°0 It'd £9°t L£°0 80°IT 99'S 05"I 000‘000'000't ~- 000°000'00S 12°9 99°2 29°0 20°€ I'l 92°0 20°6 £2"b 9071 000°000°00S - - 0v0‘000'DSz S9°L Ov'e 28°0 18°€ 25°T St‘0 Si‘Ol ve°S Ov"! 000‘000°0S2 - 000°000‘00I 08°¢ ove »8°0 $6°£ Ss‘I St"0 96 Ot Sb’S 2e'1 000°000°001 —- -ov0*n00"0S Ov's 6L°E £6°0 I€"> Via 6£°0 itl 26°S is‘l 000‘000'0S - 000°000'O! 91°6 SS‘b bil 91°S 60°2 8b'0 92°E1 00°¢ 26°t 000‘000'01 - 000°000'S 966 Ta 12°1 6£°S 12°2 150 62°E1 b2°L £0°2 000°000°S - 000°0U0't £9°0l 1$°S 8b'I 91°9 99°2 190 eal s0°8 9p°2 000‘000* I - 000*00S 18° bz 2€°ST S8'b £1°91 62°98 91°2 96°82 9b Oz 2L°L 000*00S - 000°001 62°9b- feb - 1£°0- b's - bb't- 82°0- 28°/£ £9°0I- Of ‘t- 000001 - 000°0S 26° St 2e°Ul- = ab t- 95°91- v0'e- »S “0- 19°61 S1°6L- 1L°2- 000°0S $ - 000°Sz $ 12°0- 600- 2°0- I1'0 - »0"0- 10°0- ap0 - 910- w'o- 000°S2$ 4#pun ve'8 Tir 26°0 62°» oL"I 6£°0 “stl 88°S 9S°1 Sayuedwoy (ty ‘abeusay c¥/fu 10 cw/6u 279 -m/bu 5G c™/Su 10 -w/6u 27°90 w/w 5-9 cu/ou to cw /bw 2°90 -w/bu ¢*0 sapes [enuuy Tazz 31s 1222 1S Tlzz 91S of9A9T Gansodxy pur 21S Aq ‘xe, 4995y 345044 03 $3809 (eI1de7 aruC} {duo yo sorgry “TE-TA 21qe 112 The evidence presented in Table VI-11 clearly indicates that unless the compliance capital investments are spread over a substantial number of years, all the companies engaged heavily in cotton yarn production will face severe difficulty in financing compliance capital for the 0.2 mg/m* and 0.1 mg/m* exposure limits and the dif- ficulty will be more intense for smaller companies. However, the above analysis only points out the relative difficulties among size classes of companies and industry. sectors. It fails to identify specifically which plants are likely to be closed due to compliance capital require- ments. It is impossible to state with any certainty that a certain plant might close as a result of the exposure limits. It can only be recognized that the possibility of closure does exist, due to the difficulty in financing capi- tal costs for the 0.2 mg/m* and 0.1 mg/m® exposure limits. Two sectors, SIC Code 2211 (Weaving Mills, Cotton) and SIC Code 2281 (Yarn Mills, Except Wool), in par- ticular, and to some degree SIC Code 2221 (Weaving Mills, Manmade Fiber and Silk), will have severe prob- lems in acquiring compliance capital necessary to meet the 0.2 mg/m* and 0.1 mg/m* exposure limits. Appendix D presents some estimates of financial im- pacts of OSHA exposure limits for each of 35 publicly- owned major textile companies. However, it should be noted that financial impacts of OSHA exposure limits for these major producers are likely to be substantially different from the minor producers. Since Table VI-11 clearly indicates that the difficulty of financing the compliance capital costs within a given SIC sector is inversely related to size of firm, the dis- tribution of companies, plants and sales within the major SIC sectors by size of annual sales is presented in Table VI-12. However, it should be hastily pointed out that the information contained in Table VI-12 cannot be 113 directly linked to Tables VI-10 and VI-11 because while the latter tables are classified by the total annual sales of each company including products which do not belong to the six SIC codes studied, the former table is ex- clusively classified by annual sales belonging to the SIC sector designated in the column heading. Therefore, any company classified in, for example, the 5-10 million dol- lar (of SIC 2211) annual sales classification in Table VI-12 should have financial parameters of the annual sales class greater than 5-10 million dollars in Table VI- 10, unless that company produces only SIC 2211 products and nothing else. Thus the information in Table VI-12 should be used with appropriate caution. For example, if some other source of information suggested that all the companies producing SIC Code 2211 products in the less than 5 million dollars (annually) classification would be forced to close their plants due to the compliance capital costs, Table VI-12 indicates that the number of companies in SIC Code 2211 will decrease to less than one-half of the current total number of companies (from 182 to 79 com- panies) and the production capacity of SIC 2211 will be reduced by 6.4 percent (assuming capacity utilization rates are uniform among different size classes of com- panies). Furthermore, if all the companies producing less than $10 million of SIC 2211 products annually are forced to close due to the compliance capital require- ment, the total number of companies will be reduced from 182 to 45 and production capacity will be reduced by 14.3 percent of the current level of capacity. cm * oe * f. Empioyment Impact 1) Output Demand Elasticity The hypothesized exposure limits may have either one of two effects on producers of cotton yarn and cotton 114 fabric. First, managers of marginal plants may choose to close their facilities rather than bear the cost of meet- ing the new cotton dust exposure limits. Second, those plants which remain open, as well as any new entrants into these industries, will incur higher costs, which in turn will necessitate charging higher unit prices to in- sure continued profitable operations. Quantity demanded will be less at the new higher prices and the industry (s) will contract. The magnitudes of these price increases and the quantity contractions will depend upon the price. elasticity of demand and the price elasticity of supply for the products of the industry(s). In the short run, the closing of productive capacity could reduce supply below the new and lower level of supply and demand equilibrium causing a temporary upward pressure on prices, rising above the long-run equilibrium level. Such pressure is not, in all probability, te be expected in the cotton textile industries since these industries have typi- cally experienced excess capacity, and the closing of marginal firms would not reduce the quantity supplied below the equilibrium level. In the absence of excess capacity, new investment would soon absorb, in any event, any excess profit caused by temporary price aber- rations. The question remains as to how the market would react. In order to predict the cotton consumers’ responses to price increases, reasonable estimates of price elasticities of demand are necessary for each of the 477 PCE items so that estimates can be made of the previously discussed contraction in demand and the subsequent reduction of production and employment in the cotton yarn producing industries. used since long-run elasticities were not available except Direct price elasticities of demand were obtained from An Investigation of Consumer Demand Elasticities by Ernst and Ernst!**!, Only the short run elasticities were 115: for a few industries, and short-run elasticities were available by SIC Code products for the year 1972. When necessary, the estimates of price demand elasticities for PCE groups made by Houthakker and Taylor"! were also utilized. Estimates of price demand elasticities for the 25 major cotton consuming PCE items are listed in Table VI-14a. 2) The Contraction of Cotton Yarn Production In order to obtain the percentage contraction of de- mand for each of the 477 PCE items, the price elasticities of demand matched to each of the 477 PCE items were then multiplied by the estimates of percent price in- creases for each PCE item obtained by the second ap- proach in Section e. Table VI-14b presents estimated declines in final demand for the 25 major cotton consum- ing PCE items. Table VI-14b indicates that for the 0.1 mg/m*® limit the most significant declines in final demand will occur in Men’s and Boy’s Gloves (43.8%), Tents and Other Canvas Products (22.3%), Thread Mills (11.9%), and Awnings and Tarpaulins ( 11.0%). The 0.2 mg/m ex- posure limit results in smaller declines in final demand than does the 0.1 mg/m® limit, i.e., the decline in final demand due to the 0.2 mg/m! limit is approximately one- third of that due to the 0.1 mg/m* limit. Again, de- clines in final demand due to the 0.5 mg/m* limit are relatively insignificant and are approximately one-fourth of those due to the 0.2 mg/m? exposure limit. While the two largest cotton consuming PCE items, Men’s and Boy’s Apparel (0.4, 1.6 and 4.3 percent de- clines at the three exposure limits) and Home Furnish- ings (0.8, 1.8 and 3.5 percent), reveal significant de- clines in demand, Women’s and Children’s Apparel (0.04, 0.16 and 0.41 percent) reveal only a minor slackening in final demand. 116 *[tt] 40¢Ae, pue 2axyxey3Nn0y pue (O1] 3Su43 pue ysusj 2324NOS 0S ‘0- S°8P 90°OI S@p4OSsadIy AsEIELIW 0002 901 0s*0- 6°21 ol°9I SLLtW Ppeasyy 00s0S €22 08 ‘0- 8° 189t 12st Burystiqng 400g 00106 i8¢ 0S*I- 9° L801 26°02 Aaa} SOW 10€02 ti 09°0- 8° 861 o9°EZ2 S2LEMD pue *ssaz40jwoD ‘SmMol [id 00%0S 8ZI lv‘0- ¢ O00! 49°€2 . S2INPOig SALSeigy 0090S $92 00*I- £69 SE “IE APIMZOO4 Aaqqny 00102 og 06°0- L°021T 6f°E€ S6ujadspag pue sassaiz3eW OOTOS Tol 02°0- 8°68 06 °9E 2}4ge4 UsAOMpeRdig TO€02 89 02°0- 9 °2S2 oL°ze Szaquelg 00v0S Sit 0s*0- 0°99T Ose susdeig 10£02 81 £2°0- O°L146 S8°st S@DpAUaS [&7,dSoH 00909 bee 61°0- 9° vESY 88 °6€ 489M} 004 00102 £9 02°0- 6°2¢ Te ‘2e suginedse, pue shujumy 00%0S 6ZT Ov ‘0- £°0€Z 2b Sb Saj4edeig pue supeqing 00S0S L22 0S*2- S°2162T 60°ES - $42) 4abuasseg may TO108 bre Ov’2- 9°96 2b°9S - SZINPOig SAVE) 49YIQ puke SqUs, 0006 rat) OS*I- ¢° 20S b°o9 asoy ,SA0g pue S,uay 20£02 S6 OS *¥- 0°201 0€°29 6ujy2019 ,SAog pue s,uay 20€02 66 02°0- €*ezi 86°EZ buyyz019 ASU Lt 0002 SCI 0€°0- L°OvEZ 98 °S6 s6ny pue szeduez 000s 9T 02°0- o° 220 6I°STE 2p4gey UsAOMpROig 00S0S 222 ss*0- S*€66ST Sr led lesveddy ,Suaupi iy) pue s, uawoy TOe0z 9Z 09°0- 1°90S2 SI 616 sButystuany awoy 00S0S 822 i é> 6°1226 06 “1S2T laaeddy ,sAog pue s,uay 20£02 16 S$O43'353S5013 (90T$) (’sat 901) UO}3dt49S9Q waz] 39d a2tug $3.4n} | puadx3 uot zdwhsuo> J4aquny Aaquny uny 2404S 33d L961 403230) apo) [eiuas 30 SazewIzS3 L961 33d 33d "Sw29] 32d 4OFEW SZ 404 S2174243S213 22444 puewag UNY Z4OUS JO SazemI3Sz “epI-IA a1qGe1 117 “PPL-IA PUR EL-IA Saiqey *su0}2e3ndwo> yiy pue S49WOJSN $2] SJUNOD UOZIO) :sarunos “y2eoudde puodas ay3 uO paseg, VHSO 02 @ng pueweg jeury : ; : . S2p4Ossadzy Auer 1 4W 0002 901 $9°I £9°0 St'0 of : re fin oundas 00S0$ £22 26°IL 9b to"r bi'9 6uyyst (qng yoog 00106 Lee blo 500 10°0 so £491 SOK to¢0z 7 9p°0 L1°0 0'0 + Be: S3L}M puke ‘s19z40j;woD “smol {ig 00%0S BLT ell tb'0 Ol'o i S32NpoOug BAL seugy 0090S 692 92°T £9°0 91°0 a 4RaMZ004 Uaqqny 00102 09 £2°0 82°0 £0°0 ee s6ujudspag pue sassas3 ze OoTOS a fb'0 91°O v0"O 9 244qe4 UaAcMpRoug Toe0z 89 Cf "oO Ito £0°0 06° szayuelg 0005 sit ib'0 8I°0 v0'0 OL "ce suadeyg Toe02 84 281 69°0 £10 Ol “se S2}A4a5 [ezLdsSOH 00909 vee 20°0 900°0 200°0 as 4PaM}004 00102 €9 £0°0 10°0 200°0 a Su} {Nedse, pue s6ujumy 00605 641 66 “Ol iU'b 20°1 2y°Sp Sapuadeug pue sujequn7 00S0$ 22 7. rte ae aq (“SGL g0L) uoL ydwnsuoy 403309 2/61 dnoug asp-puz- 4NdyNnQ JO S$L9AI7 2/61 IE YOLINIIASqNS UagijuazUT JO $729443 puPWAG *9L-IA aLqRL 122 upon employment will be in the yarn spinning and weav- ing sectors. All the SIC sectors studied (except SIC 2211) include plants which do not specialize in cotton products. Therefore, it is difficult to derive the employ- ment-output relation directly related to the cotton yarn consumption level from the data on these sectors. SIC Code 2211 (Weaving Mills, Cotton) had total employment of 121,300 and total raw cotton consumption of 2027.6 million pounds in 1972 (see Tables VI-la, and C-1), indicating that 59.8 employees per year in this in- dustry in yarn spinning and weaving processes will be directly affected by a contraction of one million pounds in the annual consumption of cotton yarn, ignoring process losses between raw cotton and cotton yarn. Simi- lar information derived for SIC 2281 (Yarn Mills, Except Wool) '"*! indicates that only 34.4 employees will be af- fected in the cotton yarn spinning process by a contrac- tion of one million pounds in annual cotton yarn con- sumption. Total employment of 34,000 persons in SIC 2281, who specialized in cotton yarn spinning, was ob- tained from Table 5A of Census of Manufacturers 1972. This represents 38.2 percent of total employment in SIC Code 2281. Dividing this employment number by raw cotton consumption in SIC Code 2281 (987.6 million pounds), resulted in the 34.4 employees per one million pounds of cotton. The difference between the above two figures in SIC Codes 2211 and 2281 indicates that ap- proximately 25.4 employees will be affected in the weav- ing process only due to a contraction of annual cotton yarn production of one million pounds. When this labor/output ratio was applied (59.8 em- ployees/million pounds of cotton yarn) to the contraction of cotton yarn consumption expected at the 1972 level of output, 14.2, 58.3 and 152.5 million pounds, the im- plication is that OSHA cotton dust exposure limits of 0.5, 0.2 and 0.1 mg/m* will result in a reduction of , 123. employment by 850, 3487 and 9120 employees, respec- tively, for the cotton yarn spinning and weaving proc- esses. These employment reductions may then be sub- tracted from the additional manpower required by the three exposure limits (393, 776, and 1049, respectively) (see Table VI-1la). The final result implies that employ- ment in this part of the textile industry will be reduced by 457, 2711 and 8071 persons at the exposure limits of 0.5, 0.2 and 0.1 mg/m*. These figures are 0.1, 0.6 and 1.8 percent of the 1972 total employment (450,400), re- spectively, in the six SIC sectors studied. However, it should be mentioned that the labor/output ratio, 59.8 employees/10* pounds, is biased upward to the extent cotton weaving mills consume yarns obtained from yarn spinners. Consequently, the employment impact may be biased upward, but this bias should not be substantial. The employment impact of the proposed standards at the 1976 level of output will be less or similar to the above figures because the projected mill consumption of raw cotton for 1976 is substantially lower than the con- sumption level in 1972 (see Table VI-6). Therefore, the above result can be interpreted as meaning that the cotton dust exposure limits imposed on the 1976 level of output will reduce employment in this part of the textile industry at most by 0.1, 0.6 and 1.8 percent of the 1976 total employment, respectively, in the six SIC sectors. Table VI-17 details the employment impact of proposed cotton dust exposure limits by SIC sector. Total reduc- tions of employment are distributed to each of the six SIC sectors according to the share of raw cotton con- sumption out of total raw cotton consumption by the six SIC sectors. As would be expected, SIC Code 2211 (Weaving Mills, Cotton) reveals the most significant reduction of em- ployment, i.e., 0.2, 1.2 and 3.5 percent reduction of cur- 124 rent employment level for the 0.5, 0.2 and 0.1 mg/m* exposure limits, respectively. Approximately 53 percent of total employment reduction due to the proposed limits will fall within SIC Code 2211. While the next im- portant raw cotton consuming SIC sector 2281 (Yarn Mills, Except Wool) reveals large employment reductions (0.1, 0.8 and 2.3 percent for the three exposure limits), all the remaining sectors reveal minor employment im- pacts except for 0.1 mg/m* limit. One should take ac- count of the fact that the estimate of the employment im- pact for SIC Code 2281 was biased upward because it also includes employment reductions due to weaving processes. The reductions will, in fact, fall on other sec- tors which purchase cotton yarns from sector 2281. When this is taken into account, it seems clear that even the employment impact on SIC Code 2281 will not be very large, again with exception of 0.1 mg/m* limit. * * * * * Compliance by the cotton weaving industry with 0.2 and 0.1 mg/m* exposure limits will require 19.6 and 55.6 cents per dollar of sales, respectively, in capital costs which are significant. Somewhat surprising is the low capital compliance cost of 0.129 cents per dollar of sales for the 0.5 mg/m*® exposure limit. These costs are ef- fectively weighted averages of the costs for the indi- vidual sectors of the industry, SIC Codes 2211, 2221 and 2241. These costs and those for the individual sec- tors must be interpreted with care due to yarn pur- chases by non-integrated firms, but the $1.10 installed cost per sales dollar for SIC 2211 for the 0.1 mg/m exposure limit are noteworthy. The corresponding cost for the 0.2 mg/m* limit is also worthy of note, at $0.39 per sales dollar. . «© * a . Table VI-24 shows computations similar to those de- tailed above, but they are estimated per dollar of in- 125 dustry shipments for yarn consuming sectors. The final column of Table VI-24 shows the average price increase per dollar of sales required due to exposure limits on ginning, yarn spinning and yarn processing (weaving). This column is not equal to the sum of columns four and five due to cotton yarn purchases of non-integrated producers. The price increases required for SIC Code 2211 (Weav- ing Mills, cotton) are 1.9, 17.8 and 47.0 cents per dol- lar of sales for the 0.5, 0.2 and 0.1 mg/m! exposure lim- its, respectively. Similarly, 0.4, 3.8 and 10.0 cents in price increases were required for SIC Code 2221 (Weav- ing Mills, manmade fiber and silk) ; 0.3, 3.2 and 8.4 cents for SIC Code 2241 (Narrow Fabric Mills) ; 0.3, 1.2 and 3.0 cents for SIC Code 2284 (Thread Mills) ; 0.2, 0.9 and 2.3 cents for SIC Code 2257 (Circular Knit Fabric Mills) ; and 0.1, 0.5 and 1.8 cents for SIC Code 2296 (Tire Cord and Fabric) to comply with the 0.5, 0.2 and 0.1 mg/m* exposure limits, respectively. It is particularly noteworthy that the imposition of the 0.1 mg/m* exposure limit on SIC Code 2211 (Weaving Mills, cotton) will result in a 47.0 percent price increase of its products. d. Impact on Market Structure and Marginal In- dustries for Cotton Weaving Sector and Cotton Waste and Linters Consuming Sectors Due to the lack of necessary financial data for the cotton ginning sector, the discussion of the capital avail- ability problem in this section will be confined to cotton weaving sectors (SIC Codes 2211, 2221 and 2241) and cotton waste and linters consuming sectors (SIC Codes 22938, 2294, and 2515). The ratios of capital requirements to profits after taxes for the three weaving sectors were computed using the “B-IA F192, - Bupuugds use, UO S34m17 SuNsodxZ 03 anp asee.ru] Qt4ug “82-3 FLGeL - pewnsuoy usea UOZIOD JO AZEQUeNH (230, “OE-) puke */-9 ‘Z-) S@iqel - SzUawdLYS Aaysnpuy yO anjeaA :adunos “(31923 SI4R JO OM} UWL OD) SzUarxlrYys Aaysnpur yo aniea ayq Aq POPLAIP *F[qe} SEyZ JO UWNLOD P4yYyZ GYR PUR CZ-1A FLGeL JO UWNLOD [BUZZ YZ UE $3U9!I} 5,202 OY} JO oNpoad ByQ aue SAN; eA q *(21qe3 Sty} 4O OMZ UUN;OD) SjUsWdyYS AuQSMpUy yO aNleA ayy Aq paprayp (21ge2 S143 JO aa4y2 UWN,OD) pawnsuOd usek 02302 30 Azyquenb ayy pue (€Z-1A aiqel JO wuN[OD Puyyz yz wo.) fuissaz0ud uuek pue Guyuuj6 uo szywi, aunsodxa 03 anp punod sad aseaiduy ad44d Leuoszippe B42 40 2onposd BYR Jue sanyeA e L210° 0100° 6110° To S00° 8000° 800° 2°0 £100° 1000° £100° $0 O'ly 1°s89 9622 £620° 9100° £820° 10 slo" €100° 9010° 2°0 §200° 1000° §200° s°0 6°ce Sec v8zz €€20° Z100° 9500° 10 2600° 1100° 2200° 20 0200° 1000° 9000 ° $0 L°St2 8°9092 L£S22 = £80" £150" WN U0 NX 61£0° S610" VN 20 rei p£00" p00" WN s°0 0°Ss8 2°995 Tv2z 1101° 2290" 68£0° 10 étt0° £Z0° 610° z°0 100" S000" 8€00° $°0 1° 969 £°9S8€ 1222 1ULb" £682" vol" 10 9LL1" 0601" $290" z°0 0610" 2200° SSI0° s‘0 2°L222 9°0992 1122 (sajes sO 481 100/$) p(S®les 30 4k (00/$) (sa_es JO 4211 0G/$) ct/be ("S41 92?) (,01$) apoz gq SUISS89044 Bulssac01g use, pue Gupuuyy Bujuusds use, uo pew pewnsuo) Squeudpys a1S vsea pur Buiuuids use, uo 31WL 7] aunsodx3 3417 aunsodx3 aunsodx3 UsRA 0230) JO Aaqysnou: Gujuuiy vO Z1WLz aunsodx3 03 anp 0} anp Ayiquend (eyo, gO anjea 03 enp @SeasDU] GIL4y LeuUOLIEppy aseasduy atu Saseauquy a2tug *(sapes gO 401 (0G/¢) Buyssar0sq use, pure Buyuurds use, *Gupuus9 UO Sz{wt] aansodxz 03 ang U4eA UOZ}O) JO SBSeI4WU] FI4d YZ -IA F1GR4 127 compliance costs data contained in Table VI-26 and the price increase estimates from the final column of Table VI-24. Table VI-27 clearly demonstrates that, except at the 0.5 mg/m* exposure limit, the cotton weaving sectors (SIC Codes 2211, 2221, and 2241 ), will face difficult capital problems, as measured by the ratio of compliance costs to profits after taxes. For the sector most heavily impacted at the 0.1 mg/m® exposure limits, namely SIC 2211 (Weaving Mills, Cotton), compliance capital ex- penditures for all size classes average 2910 percent of annual profits after taxes as compared to 1204 percent for SIC Code 2221 and 787 percent for SIC Code 2241. Further, for the fourth size class (firms with annual sales between $100,000 and $500,000) in SIC Code 2211, this ratio of costs to profits jumps to 66.29, implying ex- penditures of 6629 percent of after-tax profits. The low- est ratio for this sector at the 0.1 mg/m* level is 21.00. For Sector 2221, the comparable ratios range from 7.05 to 46.96 for the 0.1 mg/m* exposure limit, and SIC Code 2241 shows a range between 4.24 and 46.14 for the size classes with positive profits. Although the ratios at the 0.2 mg/m* exposure limit for each sector are significantly smaller for all size classes than at the 0.1 mg/m* exposure limit, the im- plied expenditure levels are still Substantial for SIC Code 2211 (Weaving Mills, Cotton). Ratios for SIC 2211 range from 10.02 to 49.83 and are approximately one half the 0.1 mg/m!® level for this sector. SIC Code 2221 faces the next highest compliance cost require- ments at the 0.2 mg/m* exposure limit, with ratios from between 2.67 to 23.45. The comparable range for SIC Code 2241 is 1.49 to 16.25. 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The full text is on the page linked above.] --- Source: Frix Law Library, https://www.frixlaw.com/law-library/documents/brief%3Amicro_IA40385006_2223%3A03. Public record. Not legal advice.