Document 4rvQ92gMOZp4r8oXJJKEkB9j
FILE NAME: Friction Materials Standards Institute (FMS)
DATE: 1971 Oct 28
DOC#: FMS013
DOCUMENT DESCRIPTION: Bulletin - Proposed Illinois Ban on Asbestos in Brake Lining
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BULLETIN NO. 1 6 October 28, 1971
PROPOSED ILLINOIS BAN ON ASBESTOS IN BRAKE LINING
There has been considerable a c t iv it y by members of the Asbestos Study Committee as regards the proposed I llin o is regulations on "Asbestos and Spray Insu la tio n * . To quote from Part V II, Section 702 of the regulations proposed by the I lli n o i s Pol lu tio n Control Board:
"The use o f asbestos in the brake lin in p of v e h ic le s manufactured a fte r January 1, 1975, and sold Tor use in I l l i n o i s is p ro h ib ite d ,"
In the Board' s explanation it notes that the proh ib ition is worded to avoid the necessity o f f it t in g vehicles manufactured prior to 1975 w ith "non-asbestos" brakes. However, there is no question but that the ban includes origin al equipment
lin in g s , and there can be l i t t l e doubt but that replacement Iin in g s r on th ese vehicles must also be o f a "non-asbestos" type. Further, interp retatio n o f the proposed reg u lation s in dicates that a l l vehicles are included: Passenger C a r s , Tiucks, O ff High way Equipment, Farm. Tractors and the lik e . Also, the Board apparently considers "clu tch facings to*be the same as brake lin in g s ". While the immediate e f f e c t would be on those supplying o rig in a l equipment lin in g s , the secondary e ffe c t would be fe ltby a l l fr ic t io n m aterial manufacturers.
In the Board' s explanation they sta te : "These p roh ib itio ns have been made with fu ll consideration given to the availab le altern ative m a te ria ls."
From the I llin o is hearings t h is past month, the In s t it u t e has-received several articles of interest:
. (1) Johns-Manvi 1le memorandum, October 20, 1971 r by Mr* Swetonic summa r iz in g the Chicago hearin^on October 15, 1971.
(2) Written presentation by D r .,F . Pundsack o f Jch n s-M an vilie as given
at the Chicago hearings.
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(3) Dr. W. J . Nicholson, Mt. Sinai H osp ital, a presentation in support
of the 8oard' s regulations, at the Chicago hearings.
(4) Chicago Sun-Times October .18, 1971 report on th e Chicago hearings.
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(5) Waukegan newspaper report of October 20, 1971 concerning the hearing; in Waukegan.
(6) Johns-W anville memorandum, October 20, 1971, by tf. Raines summarizing the Waukegan h ea rin g on October 19, 1971.
Attached to the delegates copies only of this B u lle tin are excerpts:
( l) Entire J-M summary o f the Chicago Hearings.
I PLAINTIFF'S "l EXHIBIT I
Continued 'o-*-
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October 28, 1971
(2) E n tire J-M surmary of the Waukegan Hearings.
(3) Pages 20, 21 o f Dr. Pundsack's presentation at the Chicago Hearings.
A ll those who have appeared at the hearings feel it is most urgent that the ,brake lin in g manufacturers advise the Control Beard of th eir, position on th is pro posed ban. It has been learned that the Control 8oard was surprised over the lack of response to the brake lin in g ban from fr ic tio n material manufacturers.
R e a lizin g the anreasor.3bl'e~deadHng"yotrrTmjs~b-work-aga-inst.' comments should be in the hands of the P o llu tio n Control - Board -by-November--1Q. 1971. Please write:
Mr. Samuel T. Lawton S ta te of I llin o is Pollution Control Board 189 West Madison Street Su ite 900 Chicago, I llin o is A0602
The comments must be your own. We suggest that the primary force of these comments might be the lack o f a v a ila b ility o f known su b stitu tes a t th is time. A secondary point might be th at the Federal EPA (Environmental Protection Agency) is curren tly having stu d ies made concerning the extent o f emissions in the general en vironment from brake lin in g s , and these resu lts w ill not be known t i l l mid 1972* Unless you have s p e c ific medical background, we suggest you not question the proposed safety standards on ^asbestos concentrations. Further, as is the case with most government bureaus, any pleading on cost or economics should be avoided. Please note that the portion o f \he proposed regulations that we are concerned with a t .t h is time is the general environment from brake lin in g emissions on vehicles in use. While the in -p lan t environment is a lso covered in the proposed regu latio n s, we are advising our members prim arily on the proposed ban on brake lin in g on v e h icle s.
Should you w rite Mr. Lawton, it would be appreciated i f you would send a copy to the In s titu te . I f there are any questions, please give me a c a l l .
E. W. Drislane Executive Secretary
Distribution: Active