Document MMkmawVymN0RGm77jOMrNeq5z

FILE NAME: Friction Materials Standards Institute (FMS) DATE: 1971 Nov 8 DOC#: FMS015 DOCUMENT DESCRIPTION: Letter to Illinois Pollution Control Board from Abex Afaex Corporation November 8, 1971 Research Center IU H W AH , NEW JE M JT 07430 T&: 20t-3-245a Mr. Samuel T. Lawton State of Illinois Pollucion 189 West Madison Street Suite 900 Chicago, Illinois 60602 Concrol Dear Mr. Lawton: In conjunction with hearings recently held regarding Regulation No. R71-16 "Asbestos and Spray Insulation" proposed by the Illinois Pollution Concrol Board, we believe it. would be helpful to you. to have cur comnents as a major manufacturer of friction macarial. 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 cccnents 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 fron 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 Che 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 Evironmencal Protection Agency in response to Chat agency's request for proposal No. EP.SD 71-NEG 102 "Characterisation of Emission from Automobile Brake and Clutch Linings". In this way we are well avare of the investigation work now being carried out by the Bendix fbvx- Mr. Samuel I. 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 recoraaend 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: ; 3C: Messrs.: N. G. 3elury ,G. L. Ramine F. B. Herlihy E . -H. Feierabend E. W. Drislane, FMSI, Inc. W. ?. Raines, AIA/North America