Document 2znvoxwqLjob4oKRRkON4jYp

FILE NAME: Caterpillar (CAT) DATE: 1971 Oct 19 DOC#: CAT041 DOCUMENT DESCRIPTION: Oral Testimony by CAT to IL Pollution Control Board at Regional Hearing on Asbestos and Spray Insulation APPENDIX' B 1 ORAL TESTIMONY by CATERPILLAR TRACTOR CO. to State of Illinois Pollution Control Board at Regional Hearing on Asbestos and Spray Insulation Waukegan, Illinois October 19, 1971 CAT-1007386 015 I Q HI ; , Mr. Chairman, members of Che panel, my name Is Fred EngeIking. I joined Caterpillar in Peoria in 193? after receiving a degree in Choralc.;l En gineering from Purdue University. 1 have been working on friction materials for over 20 years. Presently, 1 direct the Research and Development pro grams for rionmetallic materials, including friction material, in the Research Department. 1 have b e e n member of the American Society for Testing Materials subcommittee on Friction Materials since 1957. Caterpillar is pleased to have the opportunity to appear before the Board today. We have 6lx manufacturing facilities in the state, and are the largest private employer in the State of Illinois, with over 1,000 em ployees. We are vitally Interested in the efforts of the Illinois Pollution Control Board to guard the health and environment. > * I am here today to present to you information that I hope will assist you in efforts to regulate the use of asbestos and spray Insulation in the State of Illinois. Copies of our complete submission are in your hands, and it is our sincere hope that each of you will find time to read the entire booklet. My oral remarks are Included in Appendix B. The Caterpillar product line includes primarily .earthmoving equipment. All of this equipment utilises asbestos brake linings and it 1b for this reason that we are concerned with Section 702 of Part Vll of the pro posed Regulation. _ Appendix'A of the booklet provides a listing of the Caterpillar product line which Includes 52 models of earthmoving equipment and 53 models of material handling equipment. ' B00l 0S95 DDfTM lf'Cr. r>v t-> ^ h c lack of a definition for the word "vehicle" In the proposed Regulation Is also of concern. Typically, regulatory statutes have differentiated between motor vehicles and carthmoving equipment. There are suggestions for the definition of "vehicle" in the written testimony. 1 There arc reasons for our concern: Asbestos Is used in all types of brakes in all Caterpillar machines because it has outstanding safety and durability characteristics. In spite of many years of research,, there are no known safe substitutes for asbestos brake linings for our type of equipment. 1 would like to acquaint you with a few types of machines other than the familiar track-type tractor. . I SITDC 1 . | ^ t a r t i n g in the upper left hand corner end going clockwise, there is a wheel tractor, motor grader, off-highway truck and wheel tractor-scraper. A wheel tractor loader is in the center. Dnlike most vehicles you may know about, we have 5 different types of brakes. They are dry shoe brakes, dry caliper disc brakes, dry bend brakes, oil cooled band brakes, end oil cooled diec brakes. SLIDE 2 . Conventional shoe brakes with dry linings arc used In wheel tractorecrapers, motor graders and most wheel loaders. These brakes arc always shrouded to minimite the entry of debris from the outside. Brake lining wear products can be emitted into the environment from this type brake. Smaller sites of this type arc used on passenger cats.* ' i m i i Wi y n n m i n i s j i m i *001 PR O m ir p n r v pnor> ELIDE 3 The second type is called a caliper disc brake. The asbestos-containing pads are forced to grip the disc to produce the braking powor. This is the most ' exposed type of brake and.obviously, wear products can easily enter the environment} Many U.S.-made passenger cars aro now using this type brake on the front wheels only. We use caliper disc brakes on all wheels of some loaders. SLIDE 4 The next three types of brakes are totally enclosed and may be less familiar to you. Wear products cannot be emitted into the environment due to their i containment. Track-type tractors and track-type loaders use band brakes. In this photo, the covers have been removed from the comportments so that the ^ b r a k e s are visible, Our larger machines use bond brakes bathed in cooling oil such as is shown, The smaller machines use a dry-type band brakes without oil. SLIDE S The fifth type is the totally enclosed oil-cooled disc brake used in our off-highway trucks. These have many.'discs which are forced to rub against mating steel discs and provide braking power. Due to large rubbing surface area and the oil media, there is very little wear in this type brake. There ore no emissions into the environment. BOO 1 6597 T*BKa9P*>erWnWi- tv: PRODI iCF.n RY Fnwn -4. SLIDE 6 This is a typical friction disc with its mating disc as is used in ilcooled, multiple disc brakes shown in the previous slide. Break Wear products: It is my understanding that the technical paper by Mr, Jeremiah Lynch of the U.S. hiblic Health Service on "Brake Lining Decomposition Products" has been entered into the record in earlier testimony before this Board at Granite City, Illinois. We have done similar,, but less extensive work, on brake decomposition SLIDE 7 products. This slide shows scrapings from an unused brake as photographed 'th an electron microscope at high magnification. So you will have a better feel for this high magnification, the thickness of human hair at this same magnification would cover a screen twice as large as we have in this room. 2 have included a 5 micron scale on this and the three succeeding slides because Section 601 in the proposed Regulation states that "only fibers of $ microns or greater in length...shall be counted" in the emissions from a factory into ambient air. We believe that if it is safe for a factory toemit fibers less than 5 microns in length, it should.also be safe for a brake to emit fibers less than S microns in length into the ambient air. Additional research by qualified medical personnel may even show that asbestos fibers much larger than s microns arc safe in the ambient air. Since these arc fibers scraped from unused brake material, they are larger than S microns. 001 0596 PRODUCED BY FORD 4 gnu . ' iat asbestos fibers from new friction material were heated in an oven to remove the water of crystallization inherent in asbestos. This destroys the fibrous nature, and mechanically rubbing the deteriorated fibers further reduces the fibers to powder. This is a simulation of the formation of brake wear products. You will note no fibers are longer than 5 microns. SLIDE 9 . A sample of brake wear products was taken from a dry brake compartment. There are a few fibers showing and they are much shorter, than J> microns. Dust or clumps of dust occupy most' of tno picture. SLIDE 10 . i s last slide on brake wear products from a dry brake compartment also .lows very few fibers and none of significant size. There are many dust particles. We believe that our limited study substantiates the findings of Mr, Lynch of the U.S. Public Health Service, that few fibers are emitted as wear products from brakes. . . Smoothness of brake operation is vital"to safe operation of Caterpillar equipment. You'may have experienced a malfunctioning passenger car brake SLIDE 11 ' which grabbed and threw you forward at the end of a stop. This pair of curves shows what is happening when you brake a vehicle. In curve A, asbestos material nr** snoi o', PRODUCED PV PORP> \ shopping the vehicle. The brake torque or stopping power builds up at e beginning, stays smooth and constant, and finally increases slightly at the end of the stop. The sintered metal friction material produces rough braking in curvo B. There is a lot of vibration and noise followed by a drastic increase in torque at the end. The sudden increase in stopping power causes material to spill out of machines. ` SLIDE 12 If this loader is backing up with a raised bucket full of dirt or rock, and the machine stops abruptly, due to grabbing brakes, the material will spill out of the bucket and end up in the operator's lap. Smooth braking action is absolutely necessary for safe operation of our. machines, ^fety: . hen a brake is designed for a Caterpillar machine, there are three vital factors: safety, durability, and smoothness of stopping. Tne last two factors enhance the safety factor. The brake must be able to stop the machine in a reasonable distance, timo-sfter-time. Asbestos brake materials have proven performance and durability. 1 would like to summarize and make some recommendations. Caterpillar Tractor Co. questions whether the intent of the Asbestos and Spray Insulation Regula tions is actually accomplished by the proposed ban of asbestos brake linings. If research work and data on ambient concentration levels of asbestos fibers which are detrimental to society establish a need for asbestos brake control and/or regulation, Caterpillar recommends that 5cction 702, Part Vll of 16 (Asbestos and Spray Insulation Regulations) be modified to allow the ollowing exceptions: ' BtOl pnnrn irrn r v s n w n 1. That asbestos brake linings (friction material) may be used in a brake gyetea when the friction material operates in either a dry or oil-wotted environment in a totally enclosed brake compartment which prevents the emission of brake wear products into the ambient air. 2 That asbestos brake linings (friction material) may be used in a brake system, when the friction material operates in a nonenc3oscd brake compartment, until conclusive medical evidence proves that the emitted brake wear products contain harmful amounts of asbestos fibers.. I ' i . If all evidence indicates the need for asbestos brake controls and/or regulations, Caterpillar would.further recommend that reasonable threshold limine of asbestos fiber be established by qualified personnel (based on scientific fact and foreseeable technological advances). Test procedures which measure the concentration of asbestos fibers must also be developed which are understandable, repeatable, and realistic. Place the burden on the manufacturer to design his product to meet reasonable, attainable standards -- don't just prohibit the use of asbestos for brakes. ' As mentioned at the beginning of this booklet, Caterpillar Tractor Co. agrees in principle with the objectives of the Environmental Protection Act. The Company stands ready and willing to assist the Board in the establishment of asbestos regulations which serve the intent of the legislation. *003 0603 P k n m irpn v w w n n o LIST OF SLIDES . SLIDE KO. REFERENCE FIGURE NO. 1 ................................................ 1 2 .............................. ................. 7 3 .............................. 8 4 ................ 4 5 ......................................... 1...... 5 6 ........ ............... - ............... !...... 6 7 ......................................... L , . . . 9 o 8 ...............................................!.......10 i ' 9 11 1 0 .................................................................................................................12 11 2 1 2 ........ ...........................;........... 3 BOO} 6594. PRODUPFD r y Fnwn