(concurring in part and dissenting in part). While I agree with the majority in remanding this case, I believe that the theory of medical monitoring must be very narrowly drawn —and, if recognized, it should be on a more clearly deserving record. I also have some reservations regarding plaintiffs’ claims for emotional damages.
The cases from other jurisdictions cited by the majority in support of medical monitoring are fact-specific, and involved exposures to hazardous substances of great duration, Mauro v Raymark Industries, Inc, 116 NJ 126; 561 A2d 257 (1989), and intensity, Ayers v Jackson Twp, 106 NJ 557; 525 A2d 287 (1987); In re Paoli Railroad Yard PCB Litigation, 916 F2d 829 (CA 3, 1990). In some cases, there was evidence that the exposures to the hazardous substances occurred in violation of established environmental regulations. Ayers, supra.
In the case at bar, the limited record tends to demonstrate that defendants may have complied with the applicable rules and regulations governing asbestos removal. And, at this stage of the proceedings, the actual extent of the plaintiffs’ exposure to asbestos is uncertain. There is a serious question whether plaintiffs will be able to establish a claim for reasonable and necessary medical monitoring expenses under the five factors outlined in Ayers, supra, as adopted by the major*509ity. Only because this action has come to this Court following a grant of summary disposition pursuant to MCR 2.116(C)(8) do I entertain the legal sufficiency of plaintiffs’ claims.1 Feister v Bosack, 198 Mich App 19, 21; 497 NW2d 522 (1993).
An important issue not addressed by the majority, nor apparently the trial court below, is the effect of the Workers’ Disability Compensation *510Act, MCL 418.101 et seq.; MSA 17.237(101) et seq., upon the claims by plaintiffs against their employers. Plaintiffs’ amended complaint alleges that the City of Detroit retained control of the work premises along with the other defendants. Thus, it would appear that all defendants should be considered coemployers for purposes of workers’ compensation under the "economic reality” test. See Arntz v Southwestern Wilbert Corp, 156 Mich App 309, 313; 401 NW2d 358 (1986). Depending upon which party the individual plaintiffs worked for, it would appear that some, if not all, of the plaintiffs are essentially suing their employers.
Accordingly, to the extent that there is an employment relationship, plaintiffs’ tort claims of negligent infliction of emotional distress due to any alleged asbestos exposure would be barred by the exclusive remedy provision of the Workers’ Disability Compensation Act, MCL 418.131; MSA 17.237(131). See Beauchamp v Dow Chemical Co, 427 Mich 1, 27; 398 NW2d 882 (1986); Bachula v General Motors Corp, 191 Mich App 193, 194; 477 NW2d 486 (1991); Bach v Flint Bd of Ed, 197 Mich App 247, 250; 494 NW2d 815 (1992). In this respect I disagree with the majority’s analysis that plaintiffs’ claims of negligent infliction of emotional distress might have succeeded upon a stronger showing of physical injury.
Although plaintiffs’ claims of intentional infliction of emotional distress may fall outside the exclusive remedy provision, it would seem almost impossible to establish an "intentional” injury if defendants have in fact complied with the applicable safety rules governing asbestos removal. See Oaks v Twin City Foods, Inc, 198 Mich App 296, 297; 497 NW2d 196 (1993). Here, the relevant inquiry would be whether — having followed the applicable regulations for asbestos removal — the *511defendants had "actual knowledge that an injury was certain to occur and wilfully disregarded that knowledge.” Id. Thus, under certain circumstances, it would seem contrary to public policy to allow such a claim of intentional infliction of emotional distress.
Additionally, for some of the plaintiffs, their medical monitoring claims may be precluded by the exclusive remedy provision of the workers’ compensation act. While the theory of medical monitoring is certainly a novel one to Michigan jurisprudence and does not fit the traditional definition of a "personal injury” or "occupational disease” compensable under workers’ compensation, MCL 418.401; MSA 17.237(401), there remains the question whether the exclusive remedy provision should deny an independent tort action for medical monitoring expenses. The difficulty is that medical monitoring is not an occupational disease per se, but rather attempts to predict and diagnose the onset of a disease.
One approach would be to allow medical monitoring as an independent tort where medical monitoring expenses are not covered by workers’ compensation. This was the approach taken by the Supreme Court of New York County in Acevedo v Consolidated Edison Co, 151 Misc 2d 347, 350; 572 NYS2d 1015 (1991) (cited in plaintiffs’ supplemental brief), before it was modified by the appellate division, 189 AD2d 497; 596 NYS2d 68 (1993). This is also the approach taken by the majority.
Another approach favoring a broad interpretation of the exclusivity provision might exclude an independent tort action even though the particular work-related "injury” is not compensable under workers’ compensation. See Cole v Dow Chemical Co, 112 Mich App 198; 315 NW2d 565 (1982) (holding that claims in tort for the employees’ *512sterility were precluded by the exclusive remedy provision of the workers’ compensation act); see also Acevedo, supra, 596 NYS2d 68, 71 (1993) (holding that medical monitoring claims in tort following exposure to asbestos were precluded by the exclusive remedy provision of the workers’ compensation act).
Under a third approach, the Legislature might attempt to incorporate medical monitoring into the current workers’ compensation scheme. In this manner, medical monitoring funds could be allocated as part of a more comprehensive plan in an attempt to minimize total costs. For example— among the numerous factors to be weighed—the "cost-benefits” of early diagnosis could be balanced against the current demands of those patients in the advanced stages of asbestos-related diseases.2
If defendants have in fact complied with all the applicable rules and regulations that presumably have been formulated to ensure the safe removal of asbestos, should defendants still be required to defend against claims for emotional distress and medical monitoring? While the majority has addressed a number of other public policy concerns, this particular concern was not among them. Rather than attempt to answer these questions on the basis of the sketchy record on appeal, I feel that many of the complex public policy questions surrounding the issue of medical monitoring may be best left for the Legislature to decide.
In summary, I respectfully dissent from that portion of the majority’s opinion that suggests that similar plaintiffs could recover for negligent infliction of emotion distress upon a stronger showing *513of physical injury. It appears that, at least for some of the plaintiffs, such a claim would be barred by the exclusive remedy provision of the Workers’ Disability Compensation Act. Although I concur with the decision to remand, I also question plaintiffs’ theory of intentional infliction of emotional distress—especially if defendants have complied with current regulations governing asbestos removal. With regard to the issue of medical monitoring, I concur so that this case may be remanded to the trial court to explore the necessity of medical monitoring for these particular plaintiffs. However, I would also remand the case to the trial court to explore the necessity of medical monitoring for all of Michigan jurisprudence. To say the least, the posture of this case—arising from a grant of summary disposition pursuant to MCR 2.116(C)(8) before any discovery has taken place— is somewhat less than ideal for recognizing an entirely new tort theory.
The trial court granted summary disposition pursuant to MCR 2.116(C)(8), but added that "I guess this might have some aspect of the (0(10) motion . . . .” Although there had been no discovery, the following discourse took place during the hearing regarding the motion for summary disposition:
The Court: The latency, the fact that there isn’t any real treatment for asbestosis. There isn’t any cure. If I know today that I am going to get it five years from now, there isn’t anything that I can do that I am going to prevent it. So, monitoring isn’t going to be helpful.
And also, I guess the Supreme Court is aware of this because they comment upon it in Larson [v Johns-Manville Sales Corp, 427 Mich 301; 399 NW2d 1 (1986)] that it is not more likely than not just because you are exposed to asbestos, you are going to get lung cancer.
Those are the things that I think are factual kinds of things. And somebody that has never been involved in an asbestos case will say you have got to take some depositions. You have got to have some doctors come in and tell us all of that stuff. But everybody in this room who has been involved in asbestos litigation knows all of those facts.
[Plaintiffs’] Counsel: Just one more thing. So those facts, I don’t have a problem with this. But if the Court of Appeals reads Larson and thinks you are taking the allegations in the complaint as true.
The Court: I am taking the allegation in the complaint as true. And inasmuch as there is no allegation that they have an injury now, I feel that their claim is premature.
Even if the trial court’s decision was partially based upon MCR 2.116(C)(10), it would appear from the above excerpt that any "known” facts were analyzed under the prospective damage theory discussed in Larson, supra at 317-318, and not medical monitoring, which does not require a "reasonable certainty” of developing future complications. Although the record is unclear, it may be at this juncture that the trial court erred in using the standard from Larson to analyze the necessity for medical monitoring, because Larson does not discuss medical monitoring. Thus, regarding the medical monitoring claim itself, we are squarely faced with a question of law pursuant to MCR 2.116(C)(8).
Similarly, but not precisely on point, our Supreme Court emphasized in Larson, supra at 319, the importance of compensating those who have already developed asbestos-related cancers over those merely alleging speculative future damages.