Document 7M3x30YJXXKKa2mn6K97nq338

FILE NAME: Friction Materials Standards Institute (FMS) DATE: 1971 Nov 8 DOC#: FMS009 DOCUMENT DESCRIPTION: Letter to IL Pollution Control Board RE IL Proposed Asbestos Ban (2 0 1 ) ARmoai* 8 -5 6 3 5 -*5 EA ST 3 TX STR EET PATERSON. NEW JERSEY 07524 OUAUTY FRICTION MATERIALS SINCE 191 Nov.- $, 1971 Stata of Illinois Pollution Control Board 139 West Madison Street Suite 900 Chicago, Illinois 60602 Att: Mr. Samuel T. Lawton Gentlemen: As a brake lining manufacturer whose product contains asbestos we are much concerned over the Illinois Proposed 3an on Asbestos in Brake Lining, particulated by Part VII, Section 7 O 2 from the regulations proposed by the Illinois Pollution Control Board. Our company, and our industry as an entity, is definitely not interested*in producing products which will have harmful emission effects in the atmosphere. But we do believe the above cited section of the proposed law does not have evidence to back up its severity--- evidence that proves a harmful emission-'factor as a result of/or because of the asbestos content in friction materials. Cn the basis of reports of testing emissions we believe that although it is within the power of the State of Illinois Pollution uontrol Board to have asbestos banned from brake linings, we feel that to do so would eliminate an effective and useful,.brake lining component without justification. V'a are certain that many of the emission tests have been forWrded to the Board, and that the Board is aware.of the tests of emissions now being made by the Federal Environmental Protection Agency. We believe that this -lata will be most helpful in determining the effects of asbestos-emissions from use in brake lining, and will establish whether these emissions are of any danger or if they are negligible^. (2 0 1 ) AHmoat S*655 If the emissions prove to be a harmful pollutant our company will certainly support your Board, in eliminating this hazard. But until reliable evidence supports this possibility we are reluctant to accept any unsupported position. Gur company has been producing brake linings since 1919. (The basic company was*formed in 1917.) During this span of over 53-years we have produced hundreds of millions of feet of asbestos brake linings. In our process, we deal closely with raw asbestos fiber. Of course, we use orotective measures in handling these materials-- as well as other fine powders.- Vie have never had,- in our history, a case of asbestosis or anv other asbestos-induced illness among any of our personnel. V,'e believe this record is not uncommon among brake lining manufacturers. We are aware of the fact that in other industries who use asbestos there are systems which do not control or contain the material. However, our chief . concern is with the brake lining industry, and the effects in the atmosphere of the use of asbestos in brake linings._ We believe that the asbestos is locked-into the brake lining; material, and that during its normal usage the heat of the friction converts any residue into an inert non-fibrous material which wil.l not be hazardous in nature. We look to your 3oard for a full analysis of this macter, and a just decision based^upon proved and repeatable cata of a factual, non-emotional, nature. Very truly yours, 33ASS3ZST0S MFG. CORPORATION WILLIAM SIMON President 1