Document 3Jnb2Xr5mZryK88RvOEvwjrYJ

.... ;. TKLIEJ'HONIE 120\1 84!1-0440 FRICTION MATERIALS STANDARDS INSTITUTE, BERGEN MALL OFFICE CENTER E. 210 ROUTE 4 PARAMUS. N. J. 07652 INC. Aueust 31, 1981 i.1r. B. J. Pigg Asbestos Information Association 1745 Jefferson Davis Hi~ht.Jay Crystal Square 4 - Suite 509 Arlington, VA 22202 Subject: Comnents on Report for EPA by GCA on ~sbestos Substitut& Performance Analysisa (f1ay 1931) Dear !3ob~ On July 10, 1981 you circulated a copy of. GCA Corporatio!l's ~eport "Asbestos Substitute Performance Analysis.~' You aske~ for comments by AuRust 20, 1981, but I trust you will accept these comments des~ite the target date. I'm sure you understand it takes a while lonp:er to consolidate comments uhen an association is the Triter. Tfe will address those sections of the report pertainino to "Friction ~1aterials" only. That ,.,ould be Section 3, Friction Uatertals, Pa~es 6 7 to 102, and the comments on :r?riction :~aterialsa in Section 12. !Jur cot'li!Ients are referenced by Page i:iumher. It must be pointed out that throu~hout the report on friction materials~ the author refers to disk brakes or pads. The correct word is disc, and the use of adisk11 su~~estsan author unfamiliar with the subject on uhich he is reportintt. Under binders, the ~-1ord ''resole:r is used. ~Ye believe the author inte..Tlded cresol or creosol. "cardanalr~ should be ;cardanol. ~ Par;e 59 Table 11 indicates no resl!l or l~r resin content, 'mereas on page 7'J the report states: "Oreenic linings, ~thich must bend, require hi<>,h resin contents '' The table figures are not correct. Page 70 Under ~uses and Ap~lieations, t: the foll0'1ing are listed, a!!long others: Bicycles, tape recorders, typewriters, ~d business machines. As this report is supposed to be directed at appli- cations for "asbestos substitutes,n and the friction materials used in these applications are not the typical asbestos bearing 1!18terials with ~rhich EPA is concerned, these applications are not ~elevant--they don't use asbestos type friction materials. FMSI 07056 (_3) ~lr. B. J. Pig3 Asbestos Information Association -2- August 31, 1981 Page 72 Table 14 is entitled "Uses of Asbestos-Containing Ftiction Materials. This pa~ticular table was earlie~ used by another EPA contractor, the Public ~\edia Center, in their work on educational prograes. Hhile there have been slight changes in the table, we will repeat our earlier comments: Tha table on uses of asbestos-containine friction materials is confusing: The use of the ~10rd primary drum brake linings and secondary drum brake linings as separate products is confusing. Primary and Secondary is a long accepted classification on linings in a particular type of drum brake--the servo brake. The primary and the Secondary segment are both in the same brake. The primary essentially actuates the secondary and both linings are exposed to the same environment--that is temperature. And since they are in the same brake, they fit the same applications. .t-..nd further, Tdth the new downsized American cars, and in just about all imports the servo br&te is declining in usage. The product classification ~s clumsy. ~Te suggest that the listing hav" one product--Drum brake linings to replace the two. The eharacteristics and applications l~ould be as shmm for the '1Primary drum brake linings,;, but we question the necessity for including nminor railcar. a Further down, ,,e question the Product "Class C blocks. 11 Common terminolop:y is ='Brake Blocks. 11 Under characteristics, it should say minimal "fade" rather than "face. 11 Page 74 There are some small errors in Table 15 which might better be corrected by the individual manufacturer. For example, Auto Friction Corporation is the same company as P. T. Brake LininR Company. The table states that Thiokol manufactures ' 1Rebuilt only." Thiokol manufactures friction materials for the original equipment market as well as for the replacement market. Missing from the list are: Guardian Corporation, H. Krasne !Ifg. Co., U, S. Automotive llanufacturing and Virginia Friction Products. ne were not aware that tiGM :Brakes and Eaton Corporation were manufacturers of asbestos bearing friction materials. Paee 91 This report again goes into aircraft brakes and cermets. As the report is ostensibly a study on ''Asbestos Substitutes," and cermets replaced asbestos type friction products in aircraft brakes over a quarter of a century ago, it is difficult to understand how this relates to asbestos substitutes at this time. The use of cermets and full sintered metallics in aircraft brakes is a technological accomplishment that is complete--having started in the 1940's. Hhile continued reference to these types helps fill up pages in a report, the cermets are unlikely candiates for replaci6B asbestos type friction materials in on-highway brakes or mnall clutch facings. FMSI 07057 .j ' iir B J. Pi gg Asbestos Information Association -3- August 31, 1981 Page 93 Table 23 lists "nonasbestos brake manufacturers." He question including American Filler and Abrasives and E. I. DuPont in that table. ffuile these t\JO companies may offer materials which they claim will work in non-asbestos brakes, they are not either brake or brake lining manufac~urers. They are materials manufacturers. It may be that with the many claims by companies such as DuPont for their aramid fibers (Kevlar) that they have over-promoted themselves to the point where the contractor nav7 believes they are n11 onasbestos brake manufacturers. a Page 94 PaP,e 94 again gives considerable space to ~evlar, undoubted~y baaed on DUPont's claims and promotional efforts for this fiber. It a~pears that the contractor is gi~ln~ more weight to the sup~lier's claims for this product than it deserves, and the materials quietly being used by the friction materials manufacturers-~~ho consider naterials information proprietary-are underplayed. Page 96 The paragraph in the "Conclusion" information correctly states that the nonasbestos product for drum brake linings for passenger cars is still in the development state. As the report has indicated, this development will take additional research. It is not a project that will necessarily be accomplished by the regulatory path. ~ole again suggest that cemets are not likely candidates in the automotive brake field. Their usage may gr~ in the heavy duty clutch field, but not in the passenger car and light truck field. In summary, our comments are along these lines. T~e do not feel the cermets, as used on aircraft brakes, are practical candidates for replacing asbestos type friction !!laterials for on-highway use.. Ue believe the claims of SOl!le materials scppliers are given fat' too much we:Lsht. in tba connactor\& tepot:ll whereas most development work on substitute materials is proprietary in nature. The manufacturer who is successful in developing non-asbestos substitutes is not going to freely tell his c01!1petition how it was done. l1hile we feel the report correctly indicated the difficulties in developing nonasbestos drum brake linings, the conclusion inferred that this too would be accomplished in the not-to-distant future. This development, if indeed it is necessary or economically justified, will not be simple, particularly if consideration is given to the replacement market for this type lining. Sincerely, FRICTIOH HATERIALS STANDARDS INSTITUTE EHD/erc E. H. Drislane Executive Director FMSI 07058