ECI' calculated the total costs of

Polyols 1.6 .3 .59 quantified. It is significant that the compliance for each major industry companies supplying cost data to the Total industry 109.6 11.7 29.51 sector at each of the proposed alternarecord during the rulemaking proceedtive sets of permissible exposure ing were most reticent about assigning An essential limitation of the exlimits. Cost estimates were supplied to numbers to these types of costs. One trapolation process used by ECI in de- ECI by various companies within the company stated that a 1-day shutdown veloping industry-wide cost estimates industry sectors affected by the standof their facilities would cost $250,000 is the inherent assumption that all ard. These estimates were then used to (Ex. 92). It was noted at the hearing, plants within an industry sector are at determine the compliance costs of a however, that the company already the same stage of development in con- "typical plant" within each sector, carries out periodic turnaround eftrolling AN exposures. The effects of based upon annual production in forts, for which it does shut down fathis assumption on the overall cost espounds. The typical plant costs were cilities. During these planned shuttimates depend upon the degree to then extrapolated to the whole induswhich the sample plant is representatry sector level on the basis of total downs, an engineering expert for the company agreed that many different tive of the industry sector as a whole. annual production. ECI's data base was limited to that engineering changes could be made in If the sample plant is more advanced data which the companies contacted addition to the programed maintethan most, then the cost estimates nance activities during the shutdown were willing to provide to them. As based on the sample plant can be exnoted at the hearing, except for the period (Tr. 1129). The $250,000 figure, pected to understate the total compliinformation in the supplement to the then, would not be due exclusively to ance costs. On the other hand, if the report ECI took the cost data as they the implementation of engineering sample plant lags behind most of the received it, without independently recontrols, but would be attributable to plants in the sector in controlling ex- a number of different functions within viewing it for proper engineering or posures, then the overall cost estiaccounting (Ex. 15A; Tr. 509). In addithe facility. mates can be expected to be overstattion, data was not received from The type of cost to be incurred died. within all of the major industry secrectly determines the planner's ability The ECI report does not lean contors. Considerable data was received to estimate its magnitude; some cost sistently toward either of these alterfor the nitrile elastomer sector, but no items are basic and must be assessed in natives. For example, ECI's cost estidata on ABS manufacturing was supconnection with the engineering plan, mates for the acrylic fiber manufacplied to ECI until the supplement was whereas others may only be roughly turers are based on data from a comprepared. In determining the costs of projected, but are not at all reducible pany which employs "solution polycompliance for the ABS sector, then, to dollar figures. The form in which merization" as its process. More of the ECI used the nitrile elastomer cost figthe sampled companies in each sector U.S. fiber production capacity, howevures (based on a 30 million pound supplied their data to ECI leaves the er, involves "suspension polymerizaplant) and extrapolated them to the question open as to how much of tion," which is more difficult to con- ABS "typical plant" (figured at 200 either type of cost was included in trol (Tr. 417-418). On the basis of that million pounds) on the basis of simitheir calculations. It must be assumed, factor alone, the ECI estimates for the larity of process and process controls. lacking any information to the confiber production sector might be ex- The ECI method of extrapolation trary, that the costs submitted by the pected to be on the low side. However, relied exclusively on companies within companies reflected what their engion the other hand, the largest produceach industry sector to supply what neering departments determined to be er of acrylic fibers has reported that they estimated to be the costs of comnecessary for compliance with the alits controls for AN are further adpliance for each of the three proposed ternative proposed exposure limits. vanced than the sample plant appears exposure limits. ECI performed no in- This necessarily would include those to be (Ex. 11:(14)). This would indicate dependent engineering assessment of elements customarily assessed in engithat the extrapolation of costs from the data received from these companeering plans, while excluding those the sample plant to the entire indusnies. The data from the sampled comelements which could not be projected try sector would result in the cost estipanies represented what the engineerin dollar figures. Nonetheless, even if mates being overstated. ing departments of those companies this assumption were erroneous, the The variability of this aspect of the determined necessary for compliance. question of downtime costs would not report was recognized by ECI at the There is no clear way to determine detract from the Agency's determinahearing. When asked whether he felt what specific cost items were included tion that the standard is economically the cost estimates were understated, in each company's data. It must be asfeasible for the affected industry. Dr. Bochinski replied, "Maybe in the sumed, however, that the engineers OSHA is satisfied that the data con- 0.2 level we might have understated. engaged in providing the data were tained in the ECI report clearly dem- In some cases, 1 ppm and 2 ppm in not solely concerned with hardware. onstrates the feasibility of a 2 ppm FEDERAL REGISTER, VOL. 43, NO. 192-TUESDAY, OCTOBER 3, 1978 45786 RULES AND REGULATIONS standard for all of the major industry from a "typical plant", therefore, will degree of certainty how much the sectors evaluated in the report. be limited by the total number of total costs would be understated. The AN Manufacturing. There is no quesplants and the determination that any data submitted by other fiber production that a 2 ppm standard is economione plant is "typical" of such a small ers to the record would indicate that cally feasible for the AN manufacturnumber. the difference would in no way constiing sector. As has been stated After the initial ECI report was pubtute an economic burden to the affectthroughout the record, AN manufaclished, Vistron later supplied cost estied industries. turing is essentially a closed process, mates for a 2 ppm standard for their A countervailing consideration in with the greatest potential for expomonomer production facilities. ECI inevaluating the cost estimates for this sures arising from fugitive emissions, corporated this data into their supplesector is the degree of compliance leaks and spills, and during reactor ment and noted that the results were which already exists among fiber procleaning and other maintenace operconsistent with their previous figures ducers. At least two producers of ations. The companies have already for this industry sector (Ex. 15A; Tr. acrylic fibers have reported that most developed engineering plans designed 511). of their operations are already operatto tighten up their processes and limit Acrylic fibers. ECI's estimates for ing at between 1 and 2 ppm on a daypoints of process emissions into the the acrylic fiber industry were based to-day basis (Ex. 11:(14); 11:(10)). Since workplace. The compliance costs for exclusively on data received from Dow the total number of producers in the this sector of the AN industry should Badische. This data was scaled to the industry sector is not large, one would pose no serious economic impact on level of the "typical plant" and was expect that ECI's estimates would be the four affected companies, which toextrapolated from there to the total overstated insofar as they do not congether produce 1.5 billion pounds of acrylic fiber sector. sider the advanced state of exposure AN monomer per year. The difficulty with assessing the accontrol within this sector. The ECI cost estimates in the report curacy of the cost estimates for acrylic The 2 ppm standard is, without for the AN manufactuing sector were fiber manufacturing stems from two question, economically feasible for the obtained solely through a review of countervailing factors. The first conacrylic fiber industry. Most producers the OSHA rulemaking record. Until cerns the type of manufacturing procare well along the way to compliance Vistron supplied additional data for esses used in the sampled plant and in solely by means of engineering and the 2 ppm level (which ECI incorpothe overall industry, whereas the work practice controls in most of their rated into the supplement to the second has to do with the current exoperations. The cost estimates supreport), the only data employed by posure and compliance conditions in plied by ECI indicate that the compli- ECI was from the du Pont and Monthe various companies in the industy. ance costs should not cause the affectsanto submissions to the record. The Dow Badische facility which ed employers undue difficulty. In addi- The du Pont and Monsanto data as. supplied data to ECI produces acrylic tion, ECI's cost estimates undoubtedly submitted were not broken down by fibers by means of "solution polymerinclude items and activities which product, but contained cost estimates ization." Solution polymerization inmost, if not all, of the producers have for the respective companies' total volves the formation of polymer in a already implemented in their facilities. AN-related operations. ECI took the solvent, and the spinning of fibers di- ABS/SAN Resins-Nitrile Elasdata and attempted to split the costs rectly from this solution. This method tomers. The extrapolation procedure up according to product. As will be of production is not the most widely employed by ECI to determine complinoted, the efforts in this regard were used means of manufacturing acrylic ance costs for the ABS/SAN sector not properly performed for the Monfibers. Most fiber production in the and the nitrile elastomer sector of the santo data, resulting in cost estimates United States (over two-thirds, by one AN industry has been strongly chalwhich were too high for the AN-manucompany estimate) involves "suspenlenged by various parties to the profacturing sector. sion polymerization" (Ex. 156). Susceeding. The points of contention pri- ECI assumed that the Monsanto pension polymerization involves a formarily involve the following: The averdata ($34 million incremental costs for mation of polymer in water. The polyaging of the costs for two nitrile reaching 2 ppm) covered the costs for mer if filtered, washed, and dried, at rubber manufacturers which submittheir AN manufacturing and acrylic which point the dried polymer is ted data to ECI; the use of the nitrile fiber manufacturing facilities only. either stored for usage or taken immeelastomer costs to estimate the costs However, as was noted at the hearing diately to be dissolved in a solvent and for the ABS/SAN sector; the formula (Tr. 348), the costs supplied for Monspun directly into fibers. In suspension used by ECI to extrapolate from nisanto were for all of their operations, polymerization, it is necessary to open trile elastomers to ABS/SAN resins; including their ABS manufacturing faup the process in order to isolate dried the size of the "typical plant" within cilities. Therefore, ECI's figures for polymer. Because this system is much the ABS/SAN sector; and the question Monsanto's AN and fiber production less totally enclosed than a solution of "return on investment". are overstated. This is particularly evipolymerization process, it is more ECI determined that the typical nident in light of the fact that control of costly to reduce employee exposures trile elastomer plant produces 30 mil- ABS manufacturing is expected to inat a suspension polymerization facililion pounds per year. This figure has volve higher costs than controls for ty. not been seriously questioned. The monomer or fiber production. ECI acknowledged at the hearing cost estimate for this "typical plant" ECI averaged the du Pont costs with that suspension polymerization faciliwere determined by averaging cost the Monsanto costs to obtain an averties will cost more to control than sodata received from two producers, Unage cost to apply to the AN manufaclution polymerization facilities (Tr. iroyal and BF Goodrich. The cost data turing sector. Insofar as the Monsanto 417-418). Since a solution polymerizafrom these companies were widely dicosts were improperly determined, the tion plant was the source of the data vergent, leading some to conclude that ECI estimates for this sector are clearused to estimate costs for the entire an averaging of these figures would be ly erroneous on the high side. fiber sector, it is clear that this factor of questionable validity in estimating The difficulty with relying upon would result in an understatement of total costs for the sector. The aver- "typical plant" in the context of monthe total compliance costs. (It should aged cost data were scaled by ECI to omer manufacturing is that there are be noted that other fiber companies the level of the 30 million pound only four companies which are in the had the opportunity to submit cost "typical plant". industry, and no company has more data to ECI, but did not do so.) It is Data received after the ECI report than two plants. Any extrapolation not possible to determine with any was published have indicated that the FEDERAL REGISTER, VOL 43, NO. 192-TUESDAY, OCTOBER 3, 1978 RULES AND REGULATIONS 45787 initial estimates in the report may not costs based upon the later data from though the "typical plant" is only 2/5 be very far off the mark for the nitrile an ABS facility for 2 ppm were estias large as the "sampled plant" in this elastomer manufacturers. Cost figures mated to be $3.7 million. case, its capital costs will be more than received from Reichhold Chemicals ECI's extrapolation using the ABS half as much as the larger plant. (Ex. 15A) and Goodyear (Ex. 89) are plant data resulted in a much lower Therefore, an extrapolation to the relatively consistent with the initial total capital cost for the ABS/SAN inwhole industry sector on the basis of ECI estimates for this industry sector. dustry sector for the 2 ppm standard the smaller typical plant will, in this The Reichhold data, when extrapolatthan did the extrapolation from nitrile case, result in a much higher overall ed to the level of the "typical plant" elastomers. However, the estimates for capital cost. In addition, the other ele- (30 million pounds per year), revealed operating costs (labor, materials, and ments which are necessary in all cost estimates for capital investment utilities) from the ABS plant were plants, regardless of size, will increase to be $1.2 million for the 2 ppm standconsiderably higher. in total costs because there are more ard. The Goodyear estimates of capi- The main source of controversy conplants to consider. tal requirements for their production cerning the cost figures for the ABS/ SPI's calculations of the costs for facilities, involving capacity of 31 mil- SAN industry centered around the size their 62.5 million pound "typical lion pounds (1976), were approximateof the "typical plant" selected by ECI. plant", using the ECI formula, result ly $2.8 million for 2 ppm. ECI determined that on the basis of in a capital investment of $2.56 mil- The findings as to estimated costs their knowledge at the time, a 200 million. That figure, when extrapolated for the nitrile elastomer sector reflect lion pound per year plant was typical to the entire industry sector, results in the greater amount of data available of the overall industry. However, in a total capital cost for the ABS/SAN to ECI on this sector in preparing their posthearing comment, SPI inditheir report. Nitrile elastomer producsector of roughly twice the figure arcated that the actual "typical" plant tion provided the largest number of rived at by ECI. was closer to 62.5 million pounds per ECI's estimate of the size of the plant estimates of all of the sectors year (Ex. 148). Although SPI stated sampled for the report (Tr. 508). "typical plant" was based upon their that this was the result of a survey of On the basis of their in-house assessexperience and engineering judgment. their member companies, there was no ment of the alternative proposed expo- SPI's estimate was based on a survey detailed explanation of why their desure limits, Goodyear concluded that 2 of its membership of the industry. scription of a "typical" plant differed ppm was both economically and tech- OSHA is unable to ascertan, with any from that of ECI, nor was there a disnologically feasible for their manufacdegree of certainty, which approach is cussion of how they made their deterturing facilities (and that even 1 ppm more-accurate, nor is such a determimination. would be feasible) (Ex. 89). There is no nation really necessary. OSHA has in- The method that ECI employed to reason to believe that the impacts of a corportated the higher estimate to esscale the costs of the "typical plant" 2 ppm standard on the other nitrile tablish an upper bound of costs of up to the entire industry sector inrubber manufacturers should be much compliance for the ABS/SAN sector. volved the use of an engineering formore severe from an economic stand- We believe that this treatment of the mula: Cost of equipment M=(Cost of point. available data provides an adequate equipment N) In summary, then, the available data basis for evaluating the economic on the nitrile elastomer industry indiimpact of the standard. Cost for plant M = cate that a 2 ppm standard is both Another major issue which arose technologically and economically fea- (Cost for plant N) Capacity of plant 0.65 concerning ECI's cost estimates, not sible for that sector. Capacity of-plant only for ABS/SAN resins but for the ECI determined that the manufacentire report, was the treatment of the turing process and the points of AN This formula allows for "economic concept of "return on investment emission were sufficiently similar bescale"; for example, equipment costs (ROI)." It was contended by several tween nitrile elastomers and ABS/ for a 100 million pound plant will be parties that the ECI cost estimates did SAN resins to allow the control costs less than twice the costs for a 50 milnot incorportate a return on investfor nitrile manufacturing to be exlion pound plant, even though producment as part of the overall costs of trapolated to ABS/SAN manufacturtion capacity is twice as much. compliance with the standard (Ex. 76; ing. This determination received con- The plant (ABS/SAN) which sup- Tr. 304; 393-4). It was argued that a siderable criticism from parties to the plied data to ECI produces 150 million failure to include an amount for ROI proceeding. Exposure conditions, it pounds of resins per year. To estimate would result in an overestimate of the was contended, tend to be higher and the cost for the "typical plant" with industry's ability to pass through costs more variable in nitrile elastomers. In annual production capacity of 200 milto consumers as price increases. SPI, addition, the "typical" nitrile plant is lion pounds (according to ECI), the in the cost tables in their posthearing much smaller than ABS/SAN plant, formula was employed as follows: comment, chose to include an addiand may involve different types of tional cost to represent the purportedcontrol problems. Costs for 200 million 1b. plant = ly omitted figure for ROI, based on In the supplement to their report their assumption that such a cost was (Exh. 15A), ECI included data which (Cost for 150 million lb. plant) not incorporated in the ECI estimates (200 million) 0.65 had been supplied by an ABS/SAN X (Ex. 148). (150 million) resin producer for the 2 ppm standard. The record makes clear, however, The revised total cost for the entire *(Cost for 150 million lb. plant) (1.21) that ECI did, indeed, include the consector (ABS/SAN) differed from the cept of return on investment in develcost figures in the February 21 report- Thus, one can see that although the oping their report. Dr. Henry Beale, a ed by only 2.5 percent. typical plant is 1/3 larger than the sameconomist with Chase Econometrics, The size of the "typical plant" in the pled plant, its capital costs are only 21 testified for ECI as to the handling of ABS/SAN sector was determined by percent higher, using the formula. economic factors in the report. When ECI to be 200 million pounds/year. Using SPI's determinations of the questioned as to whether ROI was in- The capital costs for the typical plant, "typical plant" (only 62.5 million cluded in the capital cost estimates, based upon the nitrile extrapolation, pounds/year instead of 200 million), Dr. Beale responded in the affirmawere $6.8 million at 2 ppm. The capital the formula works the other way. Altive: FEDERAL REGISTER, VOL. 43, NO. 192-TUESDAY, OCTOBER 3, 1978 45788 RULES AND REGULATIONS There is implicitly a 10-percent rate of the total investment needed to achieve average loss of labor productivity for return on investment involved in that the a 2 ppm standard was $1.6 million for the entire AN industry was estimated expenditures, the capital costs are based on the polyol production sector. The anto be 2.89 percent. an assumed useful life of 10 years recouped nualized compliance costs were esti- For the 2-ppm standard, output was at the 10 percent rate * basically is (the same thing as ROI) (Tr. 302). mated to be approximately $0.6 milestimated to decrease by less than 4 lion per year. percent with several sectors, such as Therefore, SPI, in choosing to factor Downstream employers. As discussed AN monomer and polyol production, an additional 10 percent ROI into in the exemptions section, OSHA behaving reductions in output below 2 their calculations, has incorrectly aslieves that the final standard will efpercent. sumed that no ROI was included in fectively limit coverage to those em- Initial capital costs of compliance the ECI report. The additional 10 perployers with the greatest potential for were estimated to be 27.2 percent of cent results in double-counting, and exposure to AN in the workplace. As annual investment for AN production, serves only to inflate both the total was the case with the ETS, we anticias compared with 6 percent for pocompliance costs and, consequently, pate that most downstream employers lyols, and 48.3 percent for fibers. Howthe impacts of the standard on prices will be exempted from coverage. A deever, these costs were estimated to be and competition for ABS materials. termined effort has been made to claras high as 139.1 percent of annual in- SPI's estimates of the effects of the ify the exemption provisions and vestment for ABS/SAN resins, and standard on competition are open to broaden their scope where warranted 554.4 percent for nitrile elastomers. question on several counts. First, as by the evidence. ECI concluded that for AN, polyols, noted above, the erroneous inclusion Economic impacts. After estimating and fibers, the cost of compliance at 2 of an additional 10 percent ROI serves the costs of compliance with the proppm would not have a significant to inflate SPI's estimates of the standposed standard, ECI assessed the efimpact on output. Even for ABS/SAN ard's impact on ABS prices. By artififects of these costs on economic indiresins, ECI estimated that the growth cially inflating the total compliance cators as related to the affected indusprospects of the industry were sufficosts, this element also increases the tries. The impacts on critical matericiently great to make the costs of comprice increases which are necessary to als, market structure, productivity, pliance unlikely to produce any major cover those costs. Second, as noted employment, energy, and prices were reduction in output. The one area of earlier, there is no way for OSHA to examined for each of the major segconcern to ECI at the 2-ppm level inverify whether SPI's "typical plant" ments of the AN industry. The methvolved the nitrile elastomer sector. estimate is more accurate than ECI's odology employed in the analysis of However, additional data submitted to estimate. these impacts was described at length the record by two major producers in To the extent that SPI's typical in the report, and will be discussed this sector (Uniroyal and Goodyear) plant may be smaller than warranted, here only insofar as major issues were indicates that a 2-ppm standard is conthe compliance costs other than capiraised during the rulemaking. sidered by them to be feasible, and is tal will be inflated, since many of Critical materials. ECI determined not expected to have the serious conthese costs are based upon a cost per that critical materials impact was not sequences projected by ECI (Exs. 88; plant basis. relevant for AN or AN-derived materi- 89). Finally, the SPI cost estimates, as do als, since none of these materials are Employment. At the 2-ppm standard, the ECI cost estimates, necessarily currently listed on the Department of ECI anticipated that relatively small assume that the plant supplying the Commerce's list of strategic and critichanges in output will occur, so that cost data is about average for the incal materials. They also determined few, if any, workers will be laid off. dustry. There- is every reason to bethat there would be no indirect effects Any workers that are displaced are exlieve that many companies, including on critical materials due to product pected to be reabsorbed through some within the ABS/SAN sector, are substitution as a result of the standtransfers to other jobs in their compawell along the way in planning and ard. nies. achieving reductions of employee ex- Market structure. ECI concluded Energy. ECI projected that for the 2- posures to below 2 ppm. To the extent that it would be most unlikely that ppm standard, energy consumption that companies have already installed the costs of compliance with the prowould increase for the industry by or are already implementing requireposed AN standard would have any 62,535 barrels of oil per year. or 173 ments of the standard, the incrementsignificant impacts on market strucbarrels per day. al costs of compliance will be that ture at the four-digit [sic] industry, As ECI noted, even if these amounts much lower. At least one producer of level for any of the industry sectors were quadrupled, they would be insig- ABS/SAN resins already maintains studied. Most of the sectors are alnificant on a daily basis in comparison most of its operations below 2 ppm ready highly concentrated. The four to the total energy consumption of the (Tr. 899-900). firm concentration ratios range from affected industry sectors (Tr. 444). Even if the SPI cost estimates were 91 for ABS/SAN resins to 100 for acry- At the hearing, ECI was questioned to be accurate, the economic impact of lonitrile monomer production. The concerning the energy costs contained the AN standard on the ABS/SAN only major exceptions to this concluin their report (Tr. 442-444). It was sector should be well within the capasion would be, in ECI's view, if one or contended that these overall costs did bilities of the affected employers. The more firms in the nitrile elastomer innot include the energy requirements ABS/SAN market is one of the most dustry were to cease production, or if for the high rates of ventilation which buoyant of all products made from compliance costs for the ABS/SAN in- ECI felt would be needed for compli- AN, and the demand for ABS and SAN dustry were to substantially eliminate ance (Ex. 76). resins is expected to grow considerably possibilities for entry into this growing ECI did acknowledge that they did in the future. area by new firms. ECI determined not include the additional energy costs Polyols. Polymer polyol production that at the 2-ppm level, the costs from ventilation as a separate element represented the smallest industry would not be sufficiently large to of their total energy cost estimates. sector investigated by ECI in developcause either of these two eventualities However, this is not to say that such ing their report. Based upon data reto occur. additional costs were omitted from the ceived by one producer, ECI estimated Productivity. ECI calculated the agreport. As we noted in our earlier disthat the "typical" polyol plant has a gregate labor costs of the proposed 2- cussion of costs, ECI's cost estimates production capacity of 53.3 million ppm standard to be $3,557,000 annualwere based solely upon data supplied pounds per year. The ECI estimate of ly. Based on a work force of 5,130, the to them by companies within each FEDERAL REGISTER, VOL. 43, NO. 192-TUESDAY, OCTOBER 3, 1978 RULES AND REGULATIONS 45789 sector. ECI did not apply independent the equipment. Therefore, energy it is clear that the findings of feasibilengineering judgment to the compacosts would be included in the O. & M. ity carry forward to the final standnies' estimates, nor did they break costs for each sector, based on ECI's ard. these estimates down by line items extrapolations of the data as received. As discussed in the exemption secneeded for compliance. Therefore, Prices. Based upon their estimates of tion, OSHA believes that the final ECI's own determination of what was the compliance costs of the proposed standard will effectively limit coverage needed to reach 2 ppm was not reflect- 2-ppm standard, ECI calculated the to those employers with the greatest ed in the costs received from the varcost per pound of product output for potential for exposure to AN in the ious companies. If a company detereach industry sector in the study. workplace. As was the case with the mined that ventilation was necessary, Using that cost per pound, ECI then ETS, we anticipate that most downthen it included ventilation costs in its calculated a maximum passthrough of stream employers will be exempted estimates. Moreover, if a company faccosts, using a markup factor of 0.94. form coverage. A determined effort tored ventilation costs into its esti- Finally, the estimated price increase has been made to clarify the exempwas supplemented by the amount of mates, it must, therefore, also have tion provisions and broaden their compliance costs from AN manufacfactored in the operating and maintescope where warranted by the eviture which would be passed through dence. nance (O. & M.) costs of such ventilato the AN users. The following table ECI did not focus on downstream tion. These costs would be expected to represents ECI's calculations as deemployers in their analysis of the include the energy costs of operating scribed above: costs and economic impacts of the proposal. They apparently assumed that Product Compliance, cost Costs (percent of Percent increase' the exemption would be as wide-rangper pound (cents) price) ing as OSHA intended it to be. In addition, ECI indicated that at the time AN monomer 0.20 0.74 0.70 Acrylic fibers .92 1.48 1.84 they prepared their report, there was AEN/SAN resins 21.25 31.25 2.05 32.98 2.15 3.08 little or no data available on down- Nitrile rubber 1.89 2.82