Document 82ooL04EBy79BgVMX777w459y

Telephone (201) 949-0440 FRICTION MATERIALS STANDARDS INSTITUTE, BERGEN MALL OFFICE CENTER E. 210 ROUTE 4 PARAMUS. N J. 07652 INC, 20 March 1986 Mr. John A, Riopelle Allied Automotive Bendix Friction Materials Division ' P.0. Box 238 Troy, NY 12181 Dear Rip: I received your marked up changes to the draft of our earlier letter. I have included the corrected sections in the enclosed draft (Headings entitled: "Asbestos Exposure in the Brake Repair Shop," and "Chrysotile Asbestos in Brake Linings."). in addition I have changed the introduction to be a response to the recent EPA Ban and Phase Out Proposals. Where I simply referred to our earlier letters, I made these the major headings: "Earlier Comments to OSHA on Occupational Exposure to Asbestos," and "Earlier Comments to EPA on Petition to Ban Asbestos Brake Linings." I enlarged on certain points in those earlier letters. Then, 1 added two new sections aimed directly at the new proposals: "Proposed Permit System," and "Labeling of Asbestos Friction Products." And then I closed it with a few new words at the very end. This is a Draft. The two sections noted in my first paragraph are exactly as you had marked up the earlier copy. The rest of the comments are new. Please mark these up in whatever fashion you feel proper. And then, the sooner you get this back to me the sooner I can run it by the Board and Legal Counsel so that we get it in on time to the EPA, If any question, please give me a call. Sincerely, FRICTION MATERIALS STANDARDS INSTITUTE E. IV. Drislane Executive Director FMSI-0446 FMSI02418 EPA PROPOSED NEW ASBESTOS REGULATION PROPOSED RULE o BAN A/C PIPE, ROOFING & FLOORING FELTS, VINYL-ASBESTOS FLOOR TILE, CLOTHING. ` o PERMIT REQUIRED TO USE ASBESTOS IN OTHER PRODUCTS o REDUCE CONSUMPTION ANNUALLY TO ZERO AFTER 10 YEARS, EXCEPT UNDER A SPECIFIC EXEMPTION. o LABEL ALL PRODUCTS CONTAINING ASBESTOS. OPTION 1 - o. BAN CONSTRUCTION PRODUCTS AND CLOTHING IMMEDIATELY p BAN ASBESTOS FRICTION PRODUCTS ABOUT 5 YEARS LATER (CONSIDER A/M EXEMPTION) o GATHER ADDITIONAL INFORMATION ON OTHER PRODUCTS o LABEL ALL PRODUCTS CONTAINING ASBESTOS OPTION 2 o BAN CONSTRUCTION PRODUCTS AND CLOTHING IMMEDIATELY o BAN ASBESTOS FRICTION PRODUCTS ABOUT 5 YEARS LATER (CONSIDER A/M EXEMPTION) o BAN REMAINING ASBESTOS PRODUCTS ABOUT 10 YEARS LATER o LABEL ALL PRODUCTS CONTAINING ASBESTOS ' * OPTION 3 . o BAN CONSTRUCTION PRODUCTS AND CLOTHING IMMEDIATELY o COVER ALL OTHER PRODUCTS UNDER THE PHASE-DOWN ' o LABEL ALL PRODUCTS CONTAINING ASBESTOS o PERMIT REQUIRED TO USE ASBESTOS TIMING o COMMENTS BY APRIL 29, 1986 o PUBLIC HEARINGS START MAY 14, 1986 o EPA PROPOSED FINAL RULE TO OMB - SOMETIME IN 1987 o EFFECTIVE DATE OF NEW RULE - JANUARY 1, 1988 (EARLIEST) J.A.R. 3/3/86 FMS! 02419 T