Document LpbgLnd4Lpa67ZGK03zg0d4Ez

BULLET Jli* U 0. 4 1 .6 October 28, 1971 PROPOSED ILLINOIS BAN ON ASBESTOS IN BRAKE LINING There has been considerablo activity by members of the Asbestos Study Conwittee as regards the proposed Ml too is regulations on'"Asbestos and Spray Insulation". To ' quote from Part VI I, Section 702 of the regulations proposed by the Illinois Pol lution Control Board; "The use of asbestos in the brake lining of vehicles manufactured after January 1, 1975. and sold for use in II lino is is prohibited," In the Board*s explanation it notes that the prohibition is worded to avoid the necessity of fitting vehicles manufactured prior to 1975 with "non-asbestos" brakes. However, there is no question but that the ban includes original equipment linings, and there can be little doubt but that replacement linings'on these vehicles must also be of a Bnon*ssfeestos* type* Further, interpretation of the proposed reg ulations indicates that all vehicles are included Passenger Cars, Trucks, Off High** way Equipment, Farm,Tractors and the like. Also, the Board apparently coasidars "clutch facings to*be the same as brake linings". Mnle the immediate effect would be on those supplying original equipment linings, the secondary effect would be felt* by all friction material manufacturers* In the Boards explanation_.they states "These prohibitions have been made with full consideration given to the available "alternative oateFials." From.the J 11 tnois hearings'this past month, the 'Institute*has`received'several articles.df^interests . .T (1) Johns-Uanvi lie memorandum, October 20, 1971, hy Mr. Swetonlc summa rizing the Chicago*Hearings on October .15, 1971. - (2) Written presentation by Dr. F, Pundsock of Jrf>ns-UanviHe as given at the "Chicago'hearings. * *n (3) Dr. W. J. Nicholson^ *4t. Sinai _Hspital, a presentation In support of the Board's regulations, at the Chicago hearings. (4) Chicago Sun-Times October 18, 1971 report on the Chicago hearings. (5) Waukegan newspaper report of October 20, 1971 concerning the hearings in Waukegan. (6) Johns--f.'anvi 11 e memorandum, October 20, 197T, by W. Raines sunrrarizing the Waukegan hearingson October 19, 1971. Attached to the delegates copies only of this Bulletin are excerpts; V" v . (l) Entire J-M surmary of the Chicago Hearings. c 2 v mwSilll - Continued - -ec- WV-06014 i gun et !n 616 2- October 28, WT (2) Entire J-U swrnsry of the flaukegan Hearings. (3) Pages 20, 21 of Dr, Pundsack*s presentation at the Chicago Hearings. AH those who have appeared at the hearings fee* it is most urgent that the .brake lining manufacturers advise the Control Board of their, position on this pro posed ban. It has been learned that the Control* 8oard was surprised over the lack of response to the brake lining ban from friction material manufacturers. Realizing tb^ d^dhir^y-yotr-mu-s-t work--aga~inst. comments shoul 4 be in the hands of the Pollution Control - Board bv-Wovember 10; _1971. Please write: Mr. Samuel T. Lawton State of Illinois Pollution Control Board ' 189 Best Madison Street Suite 900 Chicago, HHnnis *3602 The comments must be your own* 9a suggest that the primary force of these comnents might be the lack of availability of known substitutes at this time. A^ secondary point might be that the Federal EPA {Environmental Protection Agency) is currently having studies made concerning the extent of emissions in the general anvtrorroent from brake 1 livings, and these results will not be known till mid 1972. Unless you have specific medical background, we suggest you not question the proposed, safety standards on^sbestos concentrations, further, as is the case with *oost government bureaus, any pleading on cost or economics should be avoided. Please note that the portion of \he proposed regulations that we are concerned with at this time is the general environment from brake lining emissions on vehicles in use, While the in-plant environment is also covered in the proposed regulations, we are advising our members primarily on the proposed ban on brake lining on vehicles. Should you write Mr, Lawton, it would be appreciated if you would send a copy to the Institute. If there are any questions, please give me a call. E. W. Drislane Executive Secretary Dis tribu tion: Acliv* *-S AUTO FRICTION CORP. MANUFACTURERS OP BRAKE LINING November 3, 1971 Mr. Samuel I. Lawton State of Illinois Pollution Control Beard 183 Vest Madison Street Suite 900 Chicago, Illinois 60602 Dear Mr. Lawton: It has cone to ay accention chat the State of Illinois is considering regulations or legislation which would prohibit the use of asbestos in the manufacture of brake lining for use in your State. Z also understand, chat there was a certain amount of disappointment expressed by members of your Board that there was a lack of response from the friction saterial manufacturers. The reason that we have not responded before this, is that until I read a recent article in Chemical Week Magazine, 1 was not aware that regulations or legislation was being promulgated. I may state quite suecintly two basic objections to this proposed regulation or legislation on the part of our Company: 1.' There is a complete lack of availability of a ,,knowp ..suhsLfcifcure at this time., for asbestos in the manufacture of the broadest range of friction material products for safe and accepted use to automotive vehicles. 2. The Environmental Protection Agency of the U.S. Government has presently commissioned studies to be made concerning the extent of emission in the general environment from brake Lining. The results of this study will not be reported until mid 1972. I appreciate this opportunity to inform you of our comments, and remain. Sincerely, AUTO FRICTION CORPORATION Harman Cfg.ins Vice President beet Jtr* C* J. kebr Kr, 0* ft. Killer ftr* 0* L. Vilaos -- Fit* X, Jtiaost S* V, Drisleae - IKS! ^crmsber L 1571 Kr faMool 7. Lawton State of HItoaii foliation Control Sucrd 18? West Karfl*e& Street Suite POO Chicago, mind* 60602 Sear fcr# lastont As a msBofactorer of brake Halrrfi, It css* u a radiate shock to Vorld Berthe Company, Sirisina of The firestone-Tire * Robber Coapeny, to learn at the proposed 1575 restriction of th* oae of asbestos la the brake lining of vehicles sold for use in Illinois, For neb a widely affecting regulation to hem bees pressed sust hsva bees taped on a substantial tatiual af darning evidence of an unequivocal nature, Ve scold like to be supplied & list of references or still better eopies of all telentifin data epos ^iioh the pro posed ragelatioB tm baaed or naed as support to that we can cake oar ovd analysis f said data and begin our alternative research program iapaediataly. % ..If thsso-ptndies for *hicb the regulations were based open are indeed scientifically reliable , then a three year waiting period is In question* Gan you explain fcev the three fear figure nt arrived at and the thinking and reasoning for such a delay and grace period? We would alee Ilk to bare sade available that information re-* Cardins suitable available alternative aateriala and the test data clearing these matariale, Farther, we mould like to see the available data which supports the alternative materials in brake tests such aa EspartBant of Transportation vehicle tests sad pertinent indoor tyraaceeter tests Vs should like to sar that references which we have sees sad are aware of do not seotest that brake Unlay emission* eoatitute any feiovn health hanird* Therefore, vs feel that the proposed regulation sill set aoces?lsfe la fact its intent (that it, to redoes asbestos levels is cabiant air) three#* toah as eaantasant* Is concludes ecr oeaerratian at the present tins is that the proposed regulation say toe based an s&gtrppurted end insufficiently cceprchessive data to warrant ruch extensive action by the State of Dlinois* Very truly yours. JCVStika Attachment Jaaes C. V. dacmlse Ka&agtar, Technical-fiesearoh MaRSMONT c O pO o AT * O* NORTH HiCNIOiN AVINUK CHICASO. (UINOl* oo November 5, 1971 Mr. Samuel T. Lawton State of Illinois Pollution Control Board 189 West Madison Street Suite 900 Chicago, Illinois 60602 Dear Mx. Lawton: X am writing you to register concern on the part of Maremont Corporation relative to the proposed Illinois ben on asbestos in brake lining, effective after January i, 1975. Maremont currently produces, under the brand name "Grizzly", both pas senger car and heavy duty vehicle brake lining for the aftermarket and has been a part of die Friction Material industry for over twenty years. We are most concerned with this proposed legislation since it is our com bined technical opinion that there is not, at the present time, nor will toere be in the foreseeable future, a suitable alternative to asbestos in friction material that will yield die performance characteristics required In today's braking systems. Further, proposed federal improvements in braking sys tems to be effective after 1975 will require chose macumcturers now par ticipating in the industry to devote their time and energies tz> -scpliis'iltaxed improvements within an asbestos based product, making the research for an asbestos substitute a goal beyond the available technical abilities of most manufacturers, should that substitute really exist. Mr. Lawton, l would appreciate your continued review of the matter and hope that Maremont's concern will be given appropriate consideration. Sincerely, AAL/tflr Andre A. Laus Vice President and General Manager Brake Systems Division .'.liSSBESTOS (201 > ARaOBY fr-696 4S EAST St* STREET RATERSON. NEW JERSEY 07S24 QUAUTY FRICTION MAT2RIALJ} SINCE tCift Nov. 8, 1971 St&te of Illinois Pollution Control Board 109 West Madison Street Suite 900 Chicago, Illinois 60602 Att: Mr. Samuel T. Lawton Sent 1etna n: As a brake lining manufacturer whose product contains asbestos we are much concerned over the Illinois Proposed Ban on Asbestos in Brake Lining, participated by Part VII, Section 762 from the regulations proposed by the Illinois Pollution Control Board. Our comoany, and our industry as an entity, is definitely not interested in producing products which will have harmful emission effects in the atmosphere. But we do believe the above cited section of the proposed law does not have evidence to back up its .severity----- evidence that proves a harmful emission-factor as a result of/or because of the asbestos ..content in friction materials. On the basis of reports of testing emissions we believe that although it is within the power of the State of Illinois Pollution Control.Board to have asbestos banned from brake linings, we feel that to do so would eliminate an effective and useful brake lining component without Justification. We are certain that many of the emission tests have been forwarded to the Board, and that the Board is aware of the tests of emissions now being made by the Federal Environmental Protection Agency. We believe that this data will be most helpful in determining the effects of asbestos-emissions from use in brake lining, and will establish whether these emissions are of any danger or if they are negligible. ;n'ASSBESTOS (01) Av6-*6S5 45 EAST STM STREET PATERSON. NSW JERSEY 07024 OUAU7Y FRICTION MATERIALS SINCE ISIS If the emissions prove to be a harmful pollutant our company will certainly support your Board in eliminating this hazard. But until reliable evidence supports this possibility we are reluctant to accept any unsupported position. Our comoany has been producing brake linings since 1919. (?he basic company was formed in 1917.) during this span of over 53-years we have produced hundreds of millions of feet of asbestos brake linings. In our process, we deal closely with raw asbestos fiber. Of course, we use orotective measures in handling these materials---as well as other fine powoers. We have never has, in our history, a case of asbestosis or anv other asbestos-induced illness among any of our personnel. We believe this record is not uncommon among brake lining manufacturers. We are aware of the fact that in other industries who use asbestos there are systems whicn ao not control or contain the material. However, our chief concern is with the brake lining industry, and the effects in the atmosphere of the use of asbestos in brake linings. We believe that the asbestos is locked-int the brake lining material, and that curing its normal usage the heat of the fnit.ion converts any residue into an inert non-fibrous material which will not be hazardous in nature. We look to your Board for a full analysis of this matter, and a just decision based -upon proved and repeatable data of a factual, non-emotional, nature. Very truly yours, BRASSBESTOS KFG. CORPORATION WILLIAM SIMON President S:g /W -mas Abex Corporation November 6, 1971 Research Center BUtnrwt nr* asm wa m. 3e-ca4t Mr. Samuel T. Lawton State of Illinois Pollution Control 189 West Madison Street Suite 900 Chicago, Illinois 60602 Dear Mr. Lawton: In eonjunction with hearings recently held regarding Regulation Ko. R71-16 `'Asbestos and Spray Insulation*' proposed by the Illinois Pollution Control Board, we believe it. would be helpful to you to have our coarsencs as a major manufacturer of friction material. The Abex Corporation, through its American Brakeblofc Division is one of the major suppliers of friction material for brake and clutch use in the United States, During 1971, out 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 .State*, Of Juuftm -fihexous 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 veil 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 is the Journal of the Air Pollution Control Association, Vol. 18, Ho. 12, December, 1968. 3. Abex Corporation, in conjunction with Arthur D. Little, Inc., submitted s technical proposal to the Evironmental Protection Agency in response to that agency's request for proposal Ho. ERSD 71-17BC 102 "Characterisation of Emission from Automobile Brake and Clutch Linings". In this way we are well aware f the investigation work now being carried met by the BcwBL- Am Mr. Samuel I. Lawton 2- - Boveaber 8, 1971 Corporation under contract t the Environmental Protection Agency, tte understand that results Cross this contract research vill not be known until the middle of 1972 at the earliest. It is our opinion that the results of this study will verify again chat airborne particulate matter from vehicle brakes end clutches does not con stitute a dangerous health factor in Drban air pollution. He believe that the proposed ban on manufacture and use of asbestos eontricing friction material is unwarranted end unnecessary. He recomend that part VII, Section 702 be moved and not made part of regulations proposed by the Illinois Pollution Control board. Very truly yours. C. R. Graham Director Friction Materials Research CRCrmsp SC: Messrs.: N. C. Belury C. L. Romine T, 8. Berlihy t. S. Peierabend S. V. brielane, FMSI, lea. V. P. Raines, ALA/North America British Friction Materials Council ACft. ** C. >* fti< 99. ALDWYCH, LONDON. WC2B 4JY 362/a/HFMC The Secretary, Friction Hateriale Standards Institute. J?0 1'rringtm Avenue, hew lark, K.I.100T7, G.S.A. Inc., 26th Kovember, 19?n. ^\ Dear Sir, We hare bees asked by our members in the British friction materials industry in the UJL to put their views to you on the proposed Illinois - -State Regulations concerning asbestos sod asbestos products. --We enclose herewith, their comments on the friction material aspect of these draft Regulations. Ve have no doubt that the American lining manufacturers will be making strong representations to the Illinois authorities for amendments to the proposals and perhaps you could let us know their comenta. Ve shall also be grateful if you could rake our views known as set out in this enclosure. Secretaries ON -- _U. Tne British friction ostcrisis industry views with deep concern the proposed has on the use of asbestos in brake lining15 b7 the itate of Illinois. It is not etwsre of as; medical evidence that could possibly justify such legislation* Go the contrary it would have'the effect of withdrawing from the market products that were used to promote road safety, without producing assy significant improvement in the levels of urban atmospheric pollution. It would expect any of the known alternatives to asbestos to produce general particulate pollution of a measurable amount. n. Whatever materials are used for brake linings the current state of the art is such that the action of braking will generate products of wear. The asbestos content of convectiosr! brake linings is almost entirely converted by the action of braking into forsterite or other amorphous, inert materials which are no longer asbestos. On the other hand, if non-asbestos alternatives are used (e.g. iron powder, sintered metal, ceramics, steel wool etc.,) the resulting wear products will be .released unchanged. 2. Measurements have been made of the amount of free asbestos fibre left in brake lining dust. It is an insignificant proportion of what is in any case a minute amount of total dust. The amount of free asbestos fibre that has been found in brake lining dust from vehicles, is about 1$ of the total products of wear. (1). Indeed estimates vary down to 10"9g/g, i.e. far each gramme of wear products only 10-9 grammes of free asbestos say may remain. ). be assume that the risk of contracting mesothelioma is the primeip&l cause of environmental concern there is clearly no possibility whatever as a result ef vehicle braking, of a community risk ef asbestosis or lung eancer, which are solely occupational risks. for technical reasons only chrysotile asbestos is used in the manufacture of brake linings one disc brake pads. This is. not the' type of asbestos with which mesothelioma has been mainly associated. ** Measurements of chrysotile asbestos am the ambient sir in as industrial centre in the United Kingdom have shown that the level must be less than 10*? jg/mJ because of the limitations of the method used. This means that they must be a thousand times lower than the British Government acceptable level for occupational exposure. Current investigations using a more sensitive method indicate levels of 1CT* to 10~10 ft/s', i.e. Z or 3 orders lower still. (1). Brake lining wear cannot therefore be a serious source of atmospheric pollution. 5. In one of the largest brake testing laboratories in the world, housing many dynamometers engaged 3fk hours a day in wearing away friction materials, the average monthly asbestos count la 0.2 fibres /cs, a tenth of the British Government's occupations! standard. t .y. U *3?* hi y Chrysotue Asbestos in Urban Air The industrial use of chrysolite asbestos h mcrecung *n me question of whether m eoneemmwn in ureas err emstituio a hazard has been raised. But measurements oi asbestos in air near asbestos factories hove proved aegsiwe With present analytical meheck so under the spoMonbtp e? the Ateestetn Research Council up ere developing * more sensitive te^nr^ot. This 'ankle a a preliminary account of me esumattor of tferyvSTfte nor a large asbestos twite faeory ar IXochdite. Uncashut. There are several uncertainties id the technique, so up were,expecting to obtain only an order of rpagmiuflt : etirmate. Nevertheless this would have best an unpa.*;znJ . figure to have because of the lack of data oa the amount of asbestos m air. As u happened. u were only able to 6ewn*`oe an upper iimts for the chrysolite concernration which turned out to be three orders of magnitude kwrer than Up. Um.v'iote~ value far occupational exposure set by asbestos regulations. Obviously even more sensitive techniques are required ana an now being developed. We used an X-ray diffraction technique based on the maasutv* meat of the integrated area under the (0Q2> r**k of chrysene. ' The equipment, which consisted of PhiHipa 101 generator. * * a verteal goniometer with a step scanning ansshmem. and a , proportional ewiter with pulse height aiscnminanon, could be reliably calibrated down to 10 pj of chrywik twujvred with the \ to 10 rag range reported by treble1, and was cross- cheeked by estmtsting the magnesium comcm of the eabbranon aamptes by atom* absorption spectroscopy. Sampling lavetvod the collection of airborne solids from 1,000 et* f10* tj of air by an c(cnrostsi device fK, Lmon System* iitfj io which up to 10,0001. min-1 art drawn tnrou-h a 20 kV coma dtacterpe Panicles in the air are erecirostaucalJy precipitated ontoa plate and concentrated into - iOO ml. of liquid. The eeltentoft efficiency depends on the mb ^btribatior of the panicles and the samphng rate, but the toe drstrfbution o' ; chrysolite in the atmosphere o net known. , Therefore' e cssemated the cofleetion efficiency indirectly by running tbe . sampler in pan of tiie asbestos factpry where a low coccemtre- - liar, of asbestos h known to occur (Kig. 1) and we found the ccdteeiion efficiency to be almost 100% wbgn the air a sampvd at about 2.009 I, mu'-1, dropping to between 25 and 30% ai the me of lO.ftIO 1, min'1* depending on ti actual uts die* .inbuticn present. As we were aiming at only an order of - v ' 04 Fjg. t bemad amounts of chrysolite tft 5.000 I. of factory an. umpied at diCsreot mo- NATUR5 V0- 234 K3VU18FS \Z U7 T*a* 1 V.*o*ei Oai'Ciiror.; Date 0970) Site Wnfi April 22 AprS 24 AmfllJ April 9 May 4 Mar 1? Mara May a May 30 1 J*W moderate 1 SWtfcetu 1 NE moderate i SW moderate i S strang i N fresh 3 W hjSM 3 4 W light witpu May 3S 4 wiigm * June itsn* 310 2 sw i>mi 2 5W sttjau June 10 1 SW vhtni Onotxr a 3 W mooeratc Oetcbe; 23 J W moderate Octobers ) W moderate October# J N licks Gaeber# \ Nhcn: October a 2 N bgiu S*mng Wratasr Broken cloud Ground t*u Gmuad ftate Ground haxe Ground ham Ground hau (HtRau. dull Omcaauduli Omreast. dull Overcast. dull OHevearttatuxrtn Heat haic brDten cloud Broken cloud Broken eteud Broren dona Brakes tioud ' tude assessment of asbestos in urban air, we were prepared to accept ths uncmaiary in the collegioa efficiency. Toe map (Fig. 2; andYabte 1 $hrrw thelocation of the sampl* inp vies and theconditions in which thesample* acre churned. Tne facaory is m a hollow, and sampling tat No. 2 is at the umc height at the roof of the filter gallery, whkh is the chief air outkt from the factory. Sampling she No. 1 is about 30 fool higher than site No. 2. Sites 3 and 4 were ic the gardens of houses, site 3 being about 5 km upwind of the factory aad me 4 bong about 300 m downwind. AU thediflneuen tracesfforexample. Fig. 3) comainedstfoag hoes ofLaoUnne and qauu, probablyfrom thelocal soil, which made the astewment of ehrysdute difficult bfrrttnr the broad (031) line of kaohniie (7.11 A) a dose to the major {<02) hoe of chrysolite 0.36 A). Fortunately chrysolite is easily decom-' posed by boiling is 1 N hydrochloric acid whereas kaoiiime is tnufiened. so. it should hs possible to measure tbs amount of chrysolite pmeat by oh^eoiag tbs samples to add teaching aad measuring the corresponding reduasos of the tmeauiy of the compouts X*rey band/The fact that this process ted to ao reductions in band intensity for any ofthesamples indiaied that the amausl uf.chrysotile presaat was bdow our detectiofi ixmH- Wc ought to have been pbte to detect lb pg of chrysolite by itself, bur dear)? the presence of kaoiimte stay have reduced the tetuatrdty. Bur she addition of 100 pg ofohrysotUe to ou eoltected samptes rapid easily be detected, so we can y tha our samples collected from I.000 m* of air comaiaed teas tftai SCO (tg ofchrysolite--nn other words, there wn teas than 0.1 |ii ofefirysotiteperm* ai air. Tha threshold limit foroccupations exposure set by the 2M9 Asbestos Regulation*4 te C.l sm"` urti aartt 2CfCuM Fig.3 X-ray diffractionpanera from* typicaldust amplenear ` A more aensHrve method for estimating chrysolite isrequired and we are developing a technique based on electron truer copy. Preliminary dominations under the etearoa micro scope of samples collected by the Litton sampler indicate tha the actual chrysolite level may be a further thro: orders a magnitude below tha X-ray detection kmit {that is. abou 0.1 og). The simples have ao far been collected te she dose vicinit: of the Rochdale factory. It te now proposed to ample ais a certain representative urban and rural locations in UK am estimate tharchiysottie content A.1~Rickauv 23. V. BiPAMi Timer Brother/ Atbtstor Co. Lid, FO Box 40. BcchdeU, Lanaakirt Received April 1$; revised Septcmbct 22.1971. * Mfe. J. y* Amer. twi. fbt /kerne. J^ZT. 2R RRS. * * S/oederdrfor Atkertot Duel Conrmranc^f># Vi* vak ike Asbeaeo .... -f./-* rM^1-S.wnihB..