Document DMRq6Zbb6zqY62MGaDMBgakNd

FILE NAME: Ford (FD) DATE: 1985 Mar 15 DOC#: FD245 DOCUMENT DESCRIPTION: Letter to EPA RE Proposal to Commence Rulemaking on Asbestos Brakes h cc: D. M..McCarthy . D. L. Block ". . -R. j . 'Donne!Ion H. Epstein - J . R. Kasmrick R. E. Maugl . 1 ' ' - - Stationary Source Environmental Control . -: ` - -, . - V -Environmental and Satety Engineering ' ' . . . ... . . . . . - - U..S. Environmental Protection Agency TSCA Public Information O ffice {TS-7931 O ffice of Toxic Substances ' ` 401 M Street, SW - Room E-107 ' Washington, D. C . 20460 Attention: Document Control No. 0PTS-211015 Subject: EPA Proposal to Commence Rulemaking . . : on Asbestos Brakes ; .. . Reference: VDecemberl9.l984 Federal Register 40 CFR 763--49 FR 49311-49313 -Docket Clerk: . .... . Transmitted herewith are comments submitted by Ford Motor Company. in response to the EPA request for public comment on this issue. ...,0ur .'submittal supplements .the conments being submitted by the ... . . Motor Vehicle.Manufacturers Association of the United States <MVMA). : :Ford Hotor Company ys:not/iin>thebrakeinanufacturing business. V*We . -purchase a i1 bf'our brake systems and parts, both for the assembly - of ;new vehicles -and'fortheafterroarket, from outside mariufac-; . tufers and.suppliers. -iWhetherj.the' "purchased.in ..assembly" parts {are used jn^Company-built cars, Tight trucks, medium trucks, heavy trucks/ agricultural tractors/ construction tractors, or for the ; ^aftermarket,ral.1 |bf the ifrictio n '^components -- be. ttey pads -or . ' s h o e s r e ^ n u f a c t u r e d : b y O t h e r s / ' , V ; ' ": A :Dur u ppiiers, te ll fiis that-they are now in the process of phasing V;out the;,use'ipf -asbestos ;in the ^friction products 'that 'they supply .. ...to us. We understand that by l990, most i f not all of these pro ducts w ill be 7asbestos-free; as new car and truck lines are phased ;.in,' asbestos-containing .systems are'being phased out. Despite -Home 'technical {problems th a t rem ain ;^ understand th a t good ..progress r -.JAS125:^V v h A 'iy .f s ' ' . V.'V FflFDl 2255 3s**^ir*CTEB PRODUCED BY FORD PLAINTIFF'S EXHIBIT ..FP -4 9 FAFD1000002255 . : - 2- One p articu lar problem th at -concerns us and that we feel must be highlighted is the continued a v a ila b ility of asbestos-containing -parts ;for vehicles currently in production, o r .no longer in pro- , Auction, which employ such p arts. 'Ford Motor Company, through its Parts and Service D iv isio n , is a major.marketer of aftermarket .^i;sc;?and.-.drumbrakes..and related brake system 'p arts.. . , Currently, the Company's aftermarket parts, distribution system has . . on hand some 51,000 asbestosi)rake p artS:in stock at eigh t depots . in the tl-S . and Canada.`...These- parts involve 192 d iffe re n t brake system designs. Me supply these parts (mostly pads, shoes, d isc s, and drums) fo r cars and trucks produced by the Company between . 1957-1985 - - a period o f 28 y ears. I t i s imperative that parts for these vehicles continue to be available to our dealers and customers for the remainder o f the product's useful l i f e , and that any regulatory:program envisioned by EPA not interfere with that need. Car and truck brakes are sophisticated systems made up of parts which are carefu lly matched to function compatibly with each other, so as to provide appropriate braking ch ara cteristics for th e ir vehicles under a.wide range of operating conditions. A brake system is not simply a co lle c tio n of disparate parts -- pads,, shoes, d isc s, drums, e tc . The pads and shoes of car and truck braking systems that use asbestos f r ic t io n m aterials have . very d iffe r e n t:properties from the pads and shoes of those that do not contain asbestos. One cannot simply use a non-asbestos substitute brake shoe in conjunction with a drum that was designed for an asbestos-containing fr ic tio n m aterial. Likewise, a disc brake that, was designed fo r a sem i-m etallic fr ic tio n m aterial.w ill -not perform s a tis fa c to r ily i f an asbestos-containing pad is su b stitu ted . . A whole host of performance, noise, d u ra b ility , and .other.problems may occur i f a fr ic tio n material is introduced into a system which was not designed to employ i t . j i n considering whether to regulate the use of asbestos in brakes, EPA must be sen sitiv e to th is crucial tissue. I t would be neither : c o s t-e ffe c tiv e nor constructive fo r EPA "to force the complete . .^redesign of car and truck'jbrake'systems a t enormous co sts f o r . .^currently-produced veh icles, or for ,Qut-of-production vehicles, . i f o r which the consuming public r ig h tfu lly , expects that aftermarket, p a r t is ^ illb rn iain 'available -for^ o u tin e maintenance service t ' ifeasonabl.e. co st. Me thus strongly recommend th a t EPA not seek to -"regulat the ius of asbestos in th e b ra k e s of v e h ic le s which . . ^currently are being manufactured, or which formerly jwere manufac- . ^red,i.w1th asbestos-containing brake Systems. ; . : ' Very truly yours, ' ' FflFDl 2256 PRODUCED BY FORD F A F D 1000002256