Document 6LE7MkyZVEB2X9ognxVynzmR

FILE NAME: General Motors (GM) DATE: 1985 DOC#: GM044 DOCUMENT DESCRIPTION: EPA Memo with Attached Meeting Notes from 1985 June 5 Meeting between EPA & GM RE Asbestos in Brakes UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON, D.C. 20460 MEMORANDUM SUBJECT: Meeting with General Motors Corporation on Substitutes for Asbestos in Brakes FROM: John Rigby, Attorney-Advisor Chemical Control Division (TS-794) TO: The Record OFFICE OF PESTICIDES AND TOXIC SUBSTANCES On June 5, 1985, John Rigby of the Chemical Control Division, Amy Moll of the Economics and Technology Division, Lynn Delpire of the Exposure Evaluation Division, Steve Shapiro of the Asbestos Action Program, Ronn Dexter of the Office of Policy and Program Evaluation and Andy Gordon of the Office of General Counsel met with a group from General Motors Corporation on substitutes for asbestos in brakes. The meeting had been requested by General Motors and was attended by Thomas C. Woods, William H. Krebs, Charles W. Babcock, M. P. Rose, Howard Silverman, and Bill Gillespie of GM. The GM representative presented information on GM's efforts to replace asbestos in vehicle brakes. That information is summarized in the attached meeting notes prepared by Amy Moll. In addition, the following information was presented at the meeting. GM requests health effects data on substitutes for asbestos. Some suppliers are now conducting animal tests. The tests are of the raw fiber to which GM employees could be exposed and of mixtures of dust and debris. Animal studies may take four to six years. The test results may not be available to EPA because of confidentiality agreements with suppliers. An Occupational Safety and Health Administration standard with a permissible exposure limit of 0.5 f/cc would have little impact since GM has been below that level for years. However, a limit of 0.2 f/cc could have an impact. If necessary, GM could have employees wear space suits. The GM policy is to allow its Divisions to use hazardous materials if they have appropriate controls. GM would find the total elimination of asbestos over ten years hard to tolerate. GM felt there could be a cost penalty involved. The total elimination over ten years could also present a problem for replacement brakes. GM now will not accept performance degradations simply to eliminate asbestos in brakes. GM will not give up performance in a safety related area. 1^ necessary, GM is willing to change a process to use non asbestos products. GM recommends that its dealers use vacuum or wet methods during brake work and reminds them that t-hey are subject to the OSHA rule. GM does not take further steps in this area since its dealers are independent business*.5 A Meeting Meeting Notes Asbestos in Brakes with General Motors Representatives June 5, 1985 Room 232 ET STATUS OF DEVELOPMENT OF SUBSTITUTES FOR ASBESTOS BRAKE LININGS GM now has semi-met disk brakes on almost all cars. 2- 3% of their new cars are still equipped with asbestos disk brakes They expect that all will have semi-met w/in the next 2 years Foresee increased use of disk brakes on all four wheels problems with parking brake installation in these sys terns They've had big problems in developing nonasbestos drum brake linings - They have made semi-met drum brake linings for police car fleets and taxis, but are no longer doing that; in 1981 or 1982 they found that a semi- met. drum brake lining was best suited to meet Los Angeles Police Dept, performance standards for brakes on rear wheel drive cars. (These standards were used by other Police Depts. as well). Since then more of the testing and standard setting is being done in State of Michigan program and police have moved towards front wheel drive cars, so GM is back to asbestos drum brake linings for police car fleets. They've got semi-met. drum brake linings on minivans, but want to get out of semi-met drum brake lining p ro duc ti on due to expense & processing problems. Non-asbestos drum brake lining development Major problems with keeping mixtures (semi-met, fibrous) bound together under high temperatures They have this problem using the rolled process Kevlar-based aramid drum brake linings seem to be best candidates for viable nonasbestos linings. They are about 2-3 years into a 4-5 yr. development cycle. Problems with Kevlar problems keeping formulation together in excessive temp, environments, i.e. thermobalance tests. Kevlar does meet durability stds. Monsanto Phosphate Fiber also being considered for use; only about 1 yr. into 4-5 year development cycle Problems: durability These brakes hold up okay when subjected to high temps. Also looking at carbon fibers, acrylic fibers for use ASBESTOS AND NONASBESTOS BRAKE LINING PERFORMANCE rear disk brakes they're usually heavier than drum brakes on rear they're more expensive than drum brakes on rear can be some brake "drag" which you don't get w/drum brakes b/c disks may hit rotor some while car is in motion problem with installation of parking brake in the rear (U.S. standards say parking brake has to hold on 30% grade; European standards say pk g. brake has to hold on 18% grade) Disk brakes-general semi-mets. have the problem of having a lower coetficient of friction when they're cold, so you have to pump them a little harder (especially in nonpower systems) when you first start up Drum brakes GM developing a semi-met drum brake lining for the Opel. They're experiencing problems with operation of parking brake after it gets wet; it takes too much force to release the parking brake. QUALITY CONTROL IN BRAKE LINING MANUFACTURE/DEVELOPMENT GM sets own performance criteria, e.g.: have to meet Motor Vehicle Safety Standard 105includes: stopping distance capability requirements fade test stds. parking brake test stds. Durability Requirements Customer Satisfaction Noise Pedal Pulsation Standard manufacturers of cars have to self-certify; ensure compliance w/MVSS 105 Aftermarket brake manufacturers really only have to meet size specifications (Developed by Friction Materials Standard Institute) New York State has a certification program set up which requires standardized friction material composition standards set by the Society of Automotive Engineers ASBESTOS USE AS BACKING IN SEMI-METALLIC DISK BRAKES Bendix uses asbestos backing for strength in attaching semi-met. lining for disk brakes Asbestos, incidentally, provides additional thermal insulation for semi-met disk brake GM uses fiberglass as backing instead of asbestos CAPITAL CONVERSION They may have to go from rolled process production to molded process production to overcome some processing problems in developing nonasbestos drum brake linings. This would require a lot of retooling. - They have a development molded production process nowbut not in full scale operation