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tion, intimating to the man that I was the person reporting him, and he was going to report back to me.

In this report here I wrote, I asked them if they cannot do anything else, just leave me out of it, because they were doing nothing but causing me problems.

Congressman LEVITAS. He endangered your life more than the safety inspector had helped !

Mr. NORMAN. That is right.

Congressman LEVITAS. Mr. McGarity, this forced air respirator, Mr. Norman indicated that OSHA's position is as a result of a regulation, and yet he also indicates, and he has got first hand experience, that he gets cleaner air through the respirator than he does without the respirator.

Do you know whether OSHA did any studies, any research, any scientific testing, to justify a regulation, that eliminated this respirator?

Mr. McGARITY. No, sir. I do not know how they came about the regulations.

We know the respirator is approved, and when they came to our place and made the test, all of the tests were made on the man's lapel, it was not of the air that he was breathing, it was the air of his lapel which was exposed, and it was not at his nose.

Congressman LEVITAS. The National Institute of Occupational Safety, they are supposed to be doing research before they issue these regulations, and apparently they have not done so.

They are also supposed to train the inspeetors, and they have not done so either.

Mr. NORMAN. Over a year ago, they came to the town and spent several days in Elberton making testing, but OSHA knows nothing of this.

Congressman LEVITAS. Just one last question, that is really not funny, but it is pathetic, but it is just another example of the kind of thing you point out.

Do you have a pension program for your employees?
Mr. McGARITY. Yes.

Congressman LEVITAS. Are you subject to the requirements of ARISA?

Mr. McGARITY. Yes, sir. Congressman LEVITAS. Have you found any difficulty in complying with that?

Mr. Norman. It is a union pension plan, and it has been completely redone as a result of all of this.

Congressman LEVITAS. Thank you very much.

Senator Nunn. I thank both of you. You have been a great help. We appreciate it very much.

I am glad to see employers and employees working together so well. I think that is very important. We are all in our economy, and I am glad both of you came to give us the benefits of your thinking. Mr. NORMAN. Thank

you. Senator Nunn. Our next witnesses are Morris Bryan, Jr., Jefferson Mills, Jefferson, Ga.; Mr. Floyd C. Newton, Jr., Dundee Mills, Griffin, Ga.; and L. K. Fitzgerald, Deering-Milliken Services Corp., Spartanburg, S.C.

Mr. Bryan, Mr. Newton and Mr. Fitzgerald, we are delighted to have all of you, Mr. Bryan. we will turn it over to you, and let you proceed in any way you see fit. TESTIMONY OF MORRIS M. BRYAN, JR., JEFFERSON MILLS, INC.,

JEFFERSON, GA. Mr. Bryan. Thank you, Senator.

We do greatly appreciate the oportunity of being here. We particularly are interested in your proposed legislation. We think this is extremely commendable, and it is courageous in this day and time, we appreciate it very much.

We think it is significant that two of our younger members in Congress have taken such a tremendous lead in this respect.

We are speaking on behalf of the American Textile Manufacturers Institute. The Institute represents the majority of the textile producers in the United States.

My colleagues are Mr. Floyd, Newton, and Mr. L. K. Fitzgerald. Floyd will talke about the EPA, and its impact in the pollution field, and Mr. Fitzgerald is quite an expert on noise and dust as it affects the textile industry.

I will comment briefly later about flammability, and its impact on the American consumer, as well as on our industry.

Senator, I hope my presentation will not be too unsophisticated, but you know, we get so damned confused with all these regulations, that we have found it necessary to go back and just sort of wipe everything clean, and start out with a basic set of fundamentals.

Representative Levitas, you mentioned a fundamental a minute ago, in mentioning Adam Smith. A group of us have really studied, and we have come up with something that we can hang our hat on, and as long as we keep this fundamental in front of us, we are not going to be in too bad a shape. If you do not mind, I would like to share it with you. It is a little bit corny, but it is something we can remember, and it has been very helpful to us, and it goes like this.

We asked ourselves, what is the wealth of the United States of America that we keep talking about, as being what made us great. Without going through a lot of things, we come up with the fact that the wealth of this Nation has to be one thing, one thing only, "its ability to produce," and its ability to produce in world competition.

Oddly enough, Karl Marx in his Manifesto, Adam Smith in his “Wealth of Nations”, both said that our wealth is what we produce.

The only real economic wealth the nation has is that which it produces. The primary sources of economic wealth-farming, mining, fishing, and manufacturing—provide all the basic economic wealth of this Nation. This wealth in turn supports all the services including government, transportation, education, medicine, arts, athletics, and even religion. From the basic sources of wealth comes compliance with OSHA, EPA, and other regulatory rules and laws.

When one studies the three laborious volumes written by Gibbon concerning the Fall of the Roman Empire, several factors are dominant:

A. The fall began when Romans learned they could vote themselves money through their Senate.

B. The procedure worked fine as long as the wealth which they distributed continued to be produced.

C. They exploited the system by voting more money for nonproductive purposes and as a result discouraged the production of goods or wealth.

D. They become lazier, more and more dependent on handouts and less and less on production.

E. As a result, their morals declined.
F. They went broke.

In another way, it can be said that disaster can occur to our Nation's wealth-its ability to produce competitively—when the cost of its wealth, due to regulations or other reasons is too high.

We can increase this cost to such a degree that the system that made us great cannot stand it. We can increase this cost to such a degree that we cannot compete in world market. We can increase this cost to such a degree that the housewife cannot buy the sleepwear, so it is to this subject that we would like to address ourselves with you here so briefly.

On the subject of the two specifics I would like to touch on, the first has to do with reporting,

J. P. Stevens is the second largest company in our industry. They gave permission to submit these figures to you. It is quite unbelievable. Last year the reports filed with the Federal Government by this company, not including taxes, and tax returns, not including W-2's, were a total of 52,429 individual reports.

These reports total in pages 394,960 pages.

Stevens estimated that this number of pages was 130 feet high, which is the equivalent of a 13-story building.

We know by keeping one copy of each report that we send you from our small company, that we buy six file cabinets each year.

The other subject I would like to touch on briefly is that of flammability. The textile industry is concerned about any product that it produces. It has long been concerned about flammability, but when flammability first hit the Washington fan, there were not statistics available as to the number of burns that occurred in the United States.

HEW estimated that there were between 150 and 250,000 incidents of burn. There was no indication whatsoever of fabric-related burns.

The Bureau of Epidemiology in the Bureau of Consumer Product Safety Commission began to accumulate statistics 4 years ago. They began to gather these statistics from medical centers, hospitals, and so forth.

It develops now-4 years later that the figure is more likely in the neighborhood of 20,000 to 25,000 incidents of burns. Now, that is a lot, but look at the difference with records to substantiate compared to bureaucratic guesses 4 years ago. Now, there is no indication either in these figures that if there are any fabric-related burns.

It is hoped that they can continue to develop these figures, and will come up with something that will really give use the magnitude of the problem, but let us assume that they are very small, and we have every reason to believe that they are, as far as fabric-related burns are concerned.

The regulations have been promulgated. Now, this fabric, a beautiful piece of Jefferson Mills corduroy, passes the test. You see, it did not burn up, but it still burned.

Now, in order to produce this result-poor as it is but still passing Government regulations—the cost is 50 cents per yard. The value of the product without the treatment is $1.50, so we are talking about 30 percent of the cost added to it.

It is estimated that 30 percent of the cost added here, applied to all apparel fabrics, will result in some $5 to $6 billion a year.

Yes, we believe that we are somewhat out of proportion here as to what we might make the economy of the United States pay in order to accomplish a purpose, as worthwhile as the purpose is. This industry will solve the problem, but there is a better way than by regulation, and that is by the marketplace.

Now, Mr. Newton will talk about the EPA and its impact on water pollution.

TESTIMONY OF FLOYD C. NEWTON, JR., DUNDEE MILLS, GRIFFIN,

GA.

Mr. NEWTON. I, too, am glad to be here to have an opportunity to present some of the problems the textile industry has and some of the attitudes with regard to the general area of pollution abatement.

Let me say in beginning that the textile industry generally is in agreement with the objectives and the programs to protect our environment. As evidence of this agreement, a concerted effort was started about 4 years ago, with an industry wide push to achieve the immediate goals of water pollution control within the industry by creating an environment preservation committee, whose first objective was to work with EPA in developing effective guidelines in controlling the discharge of pollutants.

This work was expanded to include cooperative work with the National Commission on Water Quality and a number of EPA contractors, and it has been broadened over the years to include air and solid waste disposal.

ATMI and the textile industry have taken a positive approach through these efforts to solve the problem of pollution abatement, but with this approach has come the realization that many aspects of the laws and regulations in this field are unreasonable, they are unachievable from the practical standpoint, and they are unnecessary.

In these comments, I will not attempt to address each of these things but focus on the immediate problems, and those of greatest concern to the industry on water. On water pollution, regulations controlling the discharge of pollutants and waste water were issued in February 1974. These establish the initial levels of abatement to be achieved in 1977, with a second level to be met by 1983, which is considerably more stringent.

The Clean Water Act sets as an ultimate national goal, the total elimination of all pollutants to be achieved by 1985. It is generally felt the majority of the textile industry will meet the requirements for 1977 and much of the technology required to do that is already in place.

There are serious questions, however, that the industry will be able to meet the 1983 levels, for two basic reasons. Because of the high capital expenditures and the high operating and maintenance costs involved, and because many of the technologies that are proposed by EPA have not been evaluated within the industry.

Current administration of Public Law 92-500, the Federal Water Pollution Control Act amendments, presents serious problems to the textile industry. They are marked by inequity, uncertainty, and the absence of reasonable cost considerations.

Under the major inequities: First: Implementing the 1977 requirements; the industry is curently faced with standards which are more restrictive than those which are placed on municipalities. In spite of the fact that municipalities can finance costs from public sources, it is commonly agreed that the majority of them will not even meet the 1977 requirements, much less the 1983 levels, and EPA appears willing to accept this double standard, and is even considering a delay in the compliance dates for municipalities but not for industrial pollution.

Pollution is a problem which addresses itself to total pollutant load in our water supply from all sources and it is inequitable for excessively heavy demands to be placed upon the industry segment, while municipalities continue pollution with lesser restrictions.

Second: A large majority of the discharge permits now in effect for the textile industry were issued before the water pollution guidelines were promulgated and they are more restrictive than EPA's 1977 guidelines. The textile industry feels that the discharge permits which have been issued should be adjusted to the 1977 guidelines, which EPA has issued, upon request from the individual holders of the permits, but no such requests have been granted to date.

The administration of the problem of water pollution is characterized by major uncertainties, one of which is the confusion and the inconsistency arising from overlapping jurisdictions between Federal and State agencies, even where EPA regional offices delegates permissable authority to a State, and it is our experience that an applicant must often negotiate with both State and Federal officials before a permit is finally issued.

Frequent disagreements arise between the agencies with the resulting confusion and delay.

Major uncertainty arises from standards and requirements which are created but which are not issued in time to permit proper planning in order to meet industry responsibilities.

In this area, the impact of the proposed pretreatment standards is one of the most serious unresolved issues. These standards will have a major effect on the textile industry, since approximately 76 percent of our plants, representing 35 percent of our total waste volume discharge into municipally owned facilities. Many mills will be especially hard hit since they do not have access to land for building their own treatment plants, and, therefore, no practical alternatives to utilizing local sewage systems.

The original pretreatment guidelines proposed by EPA would require discharges into municipal systems to perform essentially the same treatment as that required for treatment discharges which is clearly a case of duplication of treatment.

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