Document JrXrpE4dy7nv4DEbxQ6563ddO

1 r.zwr C:."ica*/ Sn^fiVfiental and 3-ifaty Hni ''^er n$ &nt* firs. Jem T. Fepascn Record Clerk Office of Toxic Eucst;. css ( !-7?3) U.S. Environmental Frcteciic Agency 401 Street 5,W, Kasnington, O.C. 2CS4G Subject Eorrmarcial ard Ire-stria1 of Asbestos Fibers Reference 44 rf? 50021, Octccer 17, 1575 AffFRM unoer 75CA. Cockst ffLTbsr. 073-51CCc Geer firs. Repacch: Refer ones ii rice to tns Cctctar 17, 137? Federal Remoter (44 FR cCC 5 i J, whicn solicited contents r"r" ir'cerescsc :s_cies concerning one sucject Advanced notice of Frooosed ;.ul erasing, Transmitted Herewith are cur cralisnricry comments- 4e resets `rs ngnt to submit additional intGrmatie. to c~A as *-a r iy tecc~e aware :f additional asbestos-rsletad fnforiratio". It is noted that ERA anticicates that rest asbestos reculatory actio*, if an, , mil ce taken urcer 'actio" 6(a) cf 73CA. This Section is ccncarnsa Mitfi the regulation cf enemies3 substances manufacturedt processed distri buted in commerce, used cr d istcsed.of. c5A suggests that it may issue regulations under Section 5(a) cf T5CA involving manufacture of new chemical substances or new usa of existing chemical substances. We further note that possible candidates for early regulatory action include certain frictior products, of wmeft brake 1 imncs constitute the largest single product winin the fncticn product subcatagc*y. Of these, EPA proposes that automobile and light truck brake I'nings will be initial candidates for analysis and possiole rulemaking. , Ford Motor Company uses asbestos-containing materials in the form of brake linings and other friction products as well as gasxet materials, and insulating materials. Actions are being initiated by Ford to investigate asbestos substitutes in sealers and fillers as well as In ether products. Altnough we are not in a position at this time to provide details, we may well be able to address such matters in early 1930. / 001737 PRODUCED BY FORD 105537 44 FR 6!Xo ustMiuer 1 ** i i 579 With respect to any regulations which are to be developed, it is essential that adverse innacts on astestos users be minimized. We agree with EPA that implementation schedules, if required, allow for reasonable transition to substitutes and orderly ob.ase-cut of asbestos processing equipment. Considering the present degree of uncertainty concerning the relative hazards of asbestos and its potential substitutes, care must be taken to see that any action taken to force a substitution for ascastos produce an assured health benefit to balance tne known socic-econo.~ic costs. Peculiar to our industry is the fact tnat past model replacement components have to be supplied to consumers for many years after oroduction may have ended. It follows therefore that any regulation phasing out asbestos components for motor vehicles be geared to a specific future model year ratnar than to parts manufactured after a specific effective date. Of ma.ior_cor.esrn are friction materials such as brake pads/lmings and clutch discs, L'e belie/e that such past model parts shoulc be exempt from any regulation phasing out or banning asbestos products. If "grandfathering" were not to be allowed, a monumental task of past me cel vehicle tsstirg and recertification vntnrn; asoestos components would be required. Availability of past model replace"'-: parts for the consuming public rust not be jeopardized by regulation. You have indicated tnat information ana ccrrents provided by Ford and others under provisions of TSCA are to be taken into account by the C:ns-"=" Product Safety Commission, when tailoring requests for information. To t-*e degree this is done we agree that the potential reporting burdens or nidus should be reduced. This is particularly important when information catner->r.g under TSCA Section S(a} is initiated. Yours very truly, I A. B. H. Houston, f'anagsr Compliance and Liaison Department Stationary Source Environmental Control Office bcc: D. D. Baker E. a. Bennett R. E. Maugh H. A. Nickol t [ G, F. Bolling C. L. Payor O. L. Block., J. Reese p stein J. G. Rivard H. P. Freers W. J. Rooney W. E. Gibbons J . A. Starkey S. Gratch P. E. Toth G. C. Hague A. M. Twilley M. H, Hamburg J. D. Velte A. W. Hanlon F. J. Kail in P. A. Kelly W. L. Kath G. Kircos 001738 Circ: VHS/FPP/HMS/J5A PRODUCED BY FORD