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PLAINTIFFS.. EXHIBIT AB-204 msur. / Abex Corporation November 8, 1971 Research Center MAHWAH. NEW jrnsn 0743C TIL I01-S2J JSt Mr, Samuel T. Lawton State of Illinois Pollution Control 189 West Madison Street Suite 900 Chicago, Illinois 60602 Dear Mr. Lawcon: In conjunction with hearings recently held regarding Regulation No. R.71-16 "Asbestos and Spray Insulation" proposed by the Illinois Pollution Control Board, we believe it. would be helpful to you to have our comments as a major manufacturer of friction material. ` The Abex Corporation, through its American Brakeblok Division is one of the major suppliers of friction material for brake and clutch use in the United States. During 1971, our sales of asbestos containing friction material for use in vehicles operating in the United States will be in excess of 20 million dollars. Our interest is specific to Part VII, Section 702 of the proposed regulations which states "The use of asbestos in the brake lining of vehicles manufactured after January 1, 1975, and sold for use in Illinois is prohibited". Our comments are as follows: .* 1. Asbestos fiber is an important component of organic friction material used in brake and clutch facings for vehicles manufactured and used in the United States. Of known fiberous material, asbestos imparts unique strength and thermal properties to friction lining, in addition to pro viding unique performance characteristics essential to safe and reliable braking and clutching of vehicles. 2. We are aware of investigations conducted on the nature of wear products from linings in use, as well as the identification of airborne particles from operating brakes. Air sample analysis conducted by our Medical Department to collect wear product particles during brake operation on our laboratory dynamometers confirms the findings of J. R. Lynch as reported in his study "Brake Lining Decomposition Products" published in the Journal of the Air Pollution Control Association, Vol. 18, No. 12, December, 1968. - 3. Abex Corporation, in conjunction with Arthur D. Little, Inc., submitted a technical proposal to the Evirortmental Protection Agency in response to that agency's request for proposal No. EHSD 71-NEG 102 "Characterization of Emission from Automobile Brake and Clutch Linings". In this way we are well aware of the investigation work now being carried out by the Bendix l^jWP^4W Mr. Samuel T. Lawton 2- - November 8, 1971 Corporation under contract to the Environmental Protection Agency. We understand that results from this contract research will not be known until the middle of 1972 at the earliest. It is our opinion that the results of this study will verify again that airborne particulate matter from vehicle brakes and clutches does not con stitute a dangerous health factor in Urban air pollution. We believe that the proposed ban on manufacture and use of asbestos containing friction material is unwarranted and unnecessary. We recommend that Part VII, Section 702 be removed and not made part of regulations proposed by the Illinois Pollution Control Board. Very truly yours. G. R. Graham Director Friction Materials Research GRG: nap BC: Messrs.: N. G. Belury G. L. Romine F. B. Herlihy E. R. Feierabend E. W. Drislane, FMSI, Inc. W. P. Raines, AIA/North America AMERICAN BRAKEBLOK DIVISION TROY OFFICE January 27, 1969 Messrs. fL. H. Evans C. B. Mallory F. E. Tayler J. H. Troester Attached hereto is a draft copy of the "Corporate Strategic Plan" for your advanced information. ; , . , , >f We will be ejected to present, from this Division, a Five-Year Strategic Plan by June 1, 1969. This copy, as I said, is just advance; more specific instructions will come out in the future------we will be expected to set up over-all objectives and plan how to reach them over the five year period, including our dollar needs for plant and equipment------people needs, etc.------we will be expected to express alternative plans and explain why we select the one route which we decided upon----we will be expected to evaluate our people including their strengths and weaknesses------hopefully to assist us on this we will have on' hand our Corporate Strategic Plan in final form as a better lead as to how we are going to accomplish it. . /mlc Enel. cc: M. B. Terry - Enel. P. Weber, Jr. - Enel. D. K. Rennie SPNY 006026 56 Asbestos: Medical and Legal Aspects counter agent to opinions being expressed and conclusions arrived at by Quebec physicians and officials upon the basis of surmise, social ideology, and inadequate information."7' A few days later. Brown invited executives from the fol lowing companies to meet at the Johns-Manville Boardroom to discuss the Saranac report on November 11, 1948: American BrakeBlok Div. of American Brake Shoe & Foundry Gatke Corporation Keasbey & Mattison Company Raybestos-Manhattan, Inc. Russell Manufacturing Company Thermoid Company (Southern Asbestos) Union Asbestos and'Rubber Company United States Gypsum Company t To each, he sent a copy of the report from Saranac, asking that it be treated with the utmost confidence. Brown asked that each addressee return his copy of the draft report by the time of the meeting, concluding: "It is obviously undesirable that the report in its present form receive any distribution or publicitv outside a limited number of people in our respective organizations. "7'1 American Brake Shoe Medical Director Lloyd Hamlin saw nothing in the draft report that he thought warranted concern from a legal viewpoint: "Similar reports are frequent in the literature not only from this country but also from abroad. That company's Executive Vice-President, W.T. Kelly, sent Hamlin's comments and asked Brown to act on his company's behalf at the meeting.78 U.S. Gypsum also wrote that it would not be sending a representative but asked Brown to represent its interests.711 The other firms, except for Russell Manufactur ing, each arranged to send an executive to the meeting.'11'1 The day after the meeting was held, Vandiver Brown re ported to W.T. Kelly and sent a copy to U.S. Gypsum's J.W.