Document ExmOdXrBEQNERka9MdR9G2pnj
Recommend that a ban not take effect until after a period 10 years; and that the EPA permanently exempt aftermarket brake linings.
Volkswagen
Beginning In 1987 model year, no asbestos brake linings on VW.
Proposes Fixed Time Limits for new vehicles.
Product
Clutch Transmission Gaskets Front disc brake pads
(light duty) Rear drum brake lining
(light duty) Medium and heavy duty brakes
[Ik
A years 4 years 4 years
4 years
6 years 10 years
Exemption.allowed if non-asbestos substitutes not available. .
No permits needed.
Exempt replacement parts.
Mercedes
Ban only after 5 years.
Including possibility of exceptions: Indispenslble with respect to replacement parts
Gaskets, particularly cylinder head gaskets, may need even longer lead time.
Alternative 1 is preferable over Alternative 2.
If FMVSS-105 is revised, this might result in further delays.
ord
Introduce changes during model redesign.
Ford supports reasonable fixed time table for removal of asbestos pro ducts, coupled with a procedure for exempting where no reasonable alter natives exist.
Exemption for parts replacement.
Austin
Anticipates lead time of 5 years to remove asbestos from its vehicles.
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