There have been two significant rulemaking initiatives by the U.S. EPA since 1989 affecting the manufacturing and use of asbestos cement pipe. The first was a regulation published in 1989 which prohibits the manufacture and distribution in commerce of most asbestos-containing products over a period of time. This rule has major impact on asbestos cement pipe. The second initiative was a regulation published in early 1991 which included drinking water standards for asbestos. Based on the reasons detailed in its court brief, and summarized in this paper, the Asbestos Cement Pipe Producers Association concluded that EPA's rule banning the manufacture, importation, processing, and distribution in commerce of asbestos cement pipe should be held unlawful and set aside.