Document 2jrKxxqD2ewY767MgxVd0o32N

FILE NAME: Chrysler (CHRY) DATE: 1992 Oct 12 DOC#: CHRY079 DOCUMENT DESCRIPTION: Letter from Chrysler to the EPA RE Phase out of Asbestos in New Vehicles M flV -1 4 -1 9 9 8 11--5S CHD-O PERftTIO NS BRANCH D ale E D aw kin s Director Vehicle end Safely A iff** 202 260 1724 P. I U ' 1 4 ^ m S m S rio n October 12, 1992 Mr. John W. Melone, Director Chemical Control Division United States Environmental Protection Agency W ashington, D.C. 20460 RE: Phase Out of Asbestos in New Vehicles Dear Mr. Melone, Chrysler Corporation submits the following response to your inquiry dated September 1, 1992 regarding our plans for the phase out of asbestos material in new vehicle applications. Our polity is unchanged relative to the phase out of this material in our vehicles. We have been replacing asbestos with other materials as new vehicles and components are developed. H o w ^ ^ ^ it'is impractical to substitute non-asbestos materials \ in some current applications, such as certain existing vehicle brake systems, because the j j other non-asbestos materials have not met necessary performance requirements in these j ^specific applications. _ _ .......... ....... .......................................................... ........... J The EPA has stated that substitute materials are readily available for all asbestos applications and that they are comparable, if not superior, in performance and competitive in price. Chrysler Corporation has found this is not always correct, as we have some current brake system designs where non-asbestos materials were tested; and when evaluated, they did not meet the comparable. performance or cost objective that asbestos materials now achieve, jin these cases, it would have been necessary to redesign the entire brake system' : of an existing vehicle to meet regulatory and corporate performance (ic., stopping distance,/ fade resistance, wear, noise and pedal feel/quality) requirements^jThis redesign would create increased development and tooling costs arid added lead time requirements. Chrysler Corporation will continue to reduce the usage of asbestos containing materials a s ; Jwe support the EPA policy to progressively eliminate this material in automotive ' applications. However, all asbestos containing materials will not be eliminated until suitable substitutes are found for specific applications of vehicle brake systems. We commend the EPA for believing that regulation may be. unnecessary if voluntary compliance is achieved, butjwe are concerned about a significant cost advantage that foreign imports may develop^ ,/if environmental concerns with asbestos are relaxed. Chrysler Corporation QMS 414-01 22 1200C) Chrysler Drive 3I l1ig3hk0iDn6rl 5P0c-9rk0Ml 45208-OftiV 05/14/98 11:45 TX/RX NO.2139 P.011 _ ''im '-1 4 -1 9 9 8 1 2 :0 0 CnD-OPERATIO NS BRANCH 202 260 1724 P .t2 c t4 -2 - If you have additional questions concerning this response, please contact Mr. Len Blazic of my staff at (313) 956-5365. D. E. Dawkins cc: Ms. B. T. Day 05/14/98 11:45 TX/RX NO.2139 P.012