Document Ne5xZeKJvMLEGjzaDnL0y4bwD
FILE NAME: Phenolic Resins (PHR) DATE: 1987 DOC#: PHR012
DOCUMENT DESCRIPTION: Excerpt from EPA Report - Asbestos-Cement Shingles, See PHR013
XVII. ASBESTOS-CEMEFT SKIFCLES A. Froduct Description All asbes tos -cement Biding and roofing shingles are Bade from the same
materials; a mixture of Portland cement, asbestos fiber, ground silica, and
sometimes an additional fraction of finely1 ground inert filler and pigment (Supradur 19$6a and b, Krusell and Cogley 1932), Domestically produced shingles now contain IB percent asbestos, while Imported shingles have 13 percent asbestos by weight <FE1 1986, ICF 1986, Atlas 1936c, see Attachment, Item 1),
In manufacturing asbestos-cement shingles, the raw materials are mixed either in a dry or wet state. The mixture is then placed on a moving conveyor belt, adding water if the mixture is dry. The mixture proceeds through a series of press rolls and is then textured with a high pressure grain roll. The shingles are then cured, cut to size, punched, or otherwise molded. Further processing may Include autoclaving, coating, shaping or further compression (AlA/NA and Al 1986, Supradur 1986c).
Asbestos-cement siding shingles usually resemble shakes or machine-grooved shingles, and asbestos-cement roofing shingles generally resemble either shakes or slate (Supradur 1983). The slate style is the most popular asbestos-cement roofing shingle. Most of the siding products are thinner than asbestos-cement roofing shingles and have a painted finish (Supradur 1986b). It is estimated that 77 percent of the asbestos shingle market is siding shingles and 23
percent is roofing shingles (PEI 1936, see Attachment, Item 1),
Asbestos-cement roofing and siding s h i n g l e s h a v e been used primarily on residential properties, although some applications h a v e also been found in schools, churches, and historical restoration projects (Supradur 1936a, Raleigh 1986)* In rural A r e a s they are often found in agricultural buildings and farm houses and are used to prevent fire or water damage because of their resistance
1
to both (National Til Roofing Manufacturer's Association 1986, Raleigh 1986).
Currently, asbestos-cement roofing shingles have relatively no use in nev
construction (Atlas 1986b) and are principally being used for replacement and
maintenance in luxury homes, schools, churches, and historical restorations
(Atlas 1936b, Stpradur 1966a). For historical restoration they could he used
either to preserve the historical integrity of a landmark that originally had
asbestos-cement shingles, or to replace real slate with a variety of
asbestos-cement shingles that resemble slate (Atlas 1986b; National Roofing
Contractor's Association 1986). Asbestos-cement shingles are used mostly in
the Northeast and the Midwest and are generally not found In the Neat or South
(National Tile Roofing Manufacturer's Association 1986),
&. roduers_and_Imor^rB_of_AsbeBtos^emen^_Sh^j|g^
,
In 1961, there were three producers of asbestos-cement shingles:
International Building Products, National Gypsum, and Supradur Manufacturing.
National Gypsum stopped production prior to 1982 (TSCA 1982, IGF 1964).
International Building Products closed thair asbestos Operations completely in
March 1936, however it is not known when they last produced asbestos-cement
shingles (Atlas 1986a), Table 1 presents production data for the only
remaining domestic producer of asbestos-cement roofing and siding shingles.
The only known importer of asbestos-cement shingles is Atlas International
Building Products (AIEP) In Montreal, Quebec, Canadn (Atlas 1986a and 1966b,
Eternit 1986) ,
C. Trends
Domestic production of asbestos-cement shingles for 1981 and 1985 are
presented in Table 2. While total domestic production of asbestos-cement
Table 1. Production of Asbestos-Cernant Shingle*
Total
Source; ICF 1986.
1985
Asbestos Consumption
(tone)
3,893
1985 Asbestos-
Cement
Shingle Production (squat*)
176,643
3
Table 2. Production of Asbestos'Cesene Shingles
Tfear
Number of Producers
Output (squares)
1981
3
1985
1
266,670 176,643
Sources: TCF 1986, TSCA 19B2,
4
shingles has declined 34 percent since 19Si, Supradur's production has
increased 15 percent during this period (see Attachment, Item 3),
It is not know how many asbestos-cement shingles are imported In the U,S,
According to the Bureau of the Census, 10,416.3785 tons of asbestos -cement
products other than pipe, tubes, and fittings were Imported in 19B5, of which
8,489 tons, or 81.5 percent came from Canada (U.S. Dept. Comm. 1986a, 1986b).
Thia number most likely includes flat and corrugated asbestos-cement sheet end
asbestos-cement shingles. AIBP, the only importer of these products.from
Canada roughly estimated that 80 percent of their U.S. shipments are
asbestos-cement shingles (Atlas 1986aT Atlas 1987). Eighty percent of Canadian
shipments, or 6,791 tons, converts to 64,654 squares of asbestos-cement
shingles imported in 1985.
,
D. Substitutes
Table 3 summarizes the primary substitutes for asbestos-cement siding and
roofing shingles. There are no substitutes for asbestos-cement shingles In the
maintenance and repair market because there are no substitute products that
resemble the asbestos-cement product closely enough to be able to replace it in
parts (National Roofing Contractor's Association 1986, Supradur 1986b), Slate
is the only shingle that would be close in appearance to seme asbestos-cement
shingles, but it is much thicker and far more expensive (Supredur 1986b), For
our study, we will consider substitutes that can be used instead of
asbestos-cement shingles for complete remodeling or new construction. The
following section presents separate discussions of substitutes for
asbestos-cement siding shingles and asbestos-cement roofing shingles. 1. Ashestea-Cawent Sfdln Shine!a Substitute*
The three primary substitutes for asbestos-cement aiding shingles are
wood, aluminum, and vinyl siding. Wood siding includes bsrdboaxd siding and
5
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He L a t l w l y h ig h s t r e n g t h / w ig h t ratio . E llfC tlv a In su lato r, A lgid . K ind r e s is t a n t . A ttractiv e.
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Several c o lo r*, L i|h t*a i^ h t. C oxroni.cn r a i l i t a i t . B aid a c o lo r m i l . Bo M ltiten an ce req u ired . S t i f f than v in y l.
Han f l I * - r e s i s t a n t . U su ally e sq u ire s sta in or p ro tectiv e coatin g.
A bsorbs m o istu re. R equire* p ia ta c tIv o p a in t. D o lin 't have L crgev ity o f v in y l and alisninisn, Md: i e x p o n 'E lv a t o I n s t a l l .
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red cedar shakes and shingles^ with a small amount of redwood or cedar
paneling* Hardboard is the most common wood siding product, comprising 69 percent of the wood siding category (American Hardboard Association 1986a, Red Cedar Shingle & Handsplit shake Bureau 1986b, see Attachment, Item 4), Hardboard is made by mixing wood fiber (90 percent) with phenolic resin (10 percent) and compressing them under high pressure. Usually a wood grain Is embossed onto the board to make it resemble redwood or cedar; it can also have a stucco or shake appearance. Hardboard comas in two main sizes; lap panel* which are 1 foot by 16 feet and boards which are 4 by 6 feet. Both come in thicknesses varying from 7/16 to 1/4 inch. Hardboard has a national market, although in the South and the Southwest brick and stucco, respectively, are
*
preferred (Weyerhaeuser 1986). There are about IQ major manufacturers of hardboard siding including U.S. Plywood, Stamford, CT; tfeyerhauesar, Kalamath Falls, Ok; Masonite, Laurel, MS; and Georgia-Pacific, Atlanta, GA (tfeyerhaueser 1966),
Bed cedar siding shakes and shingle* comprise the remaining 31 percent of the wood siding category (American Hardboard Association 1986a, Rad Cedar Shingle 6 Handsplit Shake Bureau 1986b, see Attachment, Item 4). Over 90 percent of cedar siding is used in the Northeast, particularly New England. Red cedar is
an effective insulator because its cellular structure retards the passage of heat and cold through the wood (Red Cedar Shingle L Handsplit Shake Bureau
1986b). Cedar siding is usually stained by users although the stains are usually flammable and make the product much less flame resistant.
Vinyl siding has been one of the largest growing siding products and can especially substitute for asbestos-cement shingles In residential areas. It
^ Shingles are sawed on both surfaces, whereas shakes have at least one split surface and thus present a rugged, irregular texture (Red Cedar Shingle and Handsplit Shake Bureau 1986a).
0
competes mostly with aluminum siding. Vinyl has taken a larger share of the siding market in the past few years, thereby reducing aluminum's share. Doth aluminum and vinyl siding often have a simulated wood-grain finish and are available in several colors- One major problem with vinyl is its tendency to expand and contract with changes in temperature. In hot weather vinyl siding may expand and come loose from the exterior W a l l . In order to minimize this expansion problem, vinyl siding is only available in light colors that do not absorb as ouch heat (Alcoa 1986b, Commonwealth Aluminum 1966). Major producers of vinyl siding include Certain-Teed, Valley Forge, PA; Vipeo Inc., Columbus, OH; Hastic Corp., South Bend, IN; Wolverine, Lincoln Park, MI; Bird Inc., Bardstown, KY; Alcoa Building Products, Sidney, OH; and Alside, a division of USX Corporation (Certain-Teed 1986),
Aluminum is a proven product and has been available for over 10 years, lunger than vinyl siding. While aluminum is more temperature resistant than vinyl, it dents much more easily chan other siding products (Commonwealth Aluminum 1986, Certain-Teed 1986). Though metal, aluminum siding resists rusting by forming a protective oxide coating (Commonwealth Aluminum 1986). Three major producere of aluminum siding are Alcan Aluminum in Warren, OH, Alcoa Building Products in Sidney, OH, and Reynolds in Richmond, VA. Both Reynolds and Alcoa aLso produce vinyl siding.
Fainted steel, stucco, masonry, brick, and concrete blocks may also be used aa aiding, but they will not be significant substitutes for asbestos-cement siding Shingles (Commonwealth Aluminum 1986, Kruse11 and Cogley 1982, American Hardboard Association 1986b).
The primary substitutes for asbestos-cement roofing shingles are asphalt shingles (fiberglass or organic), cedar wood shingles, and tile (concrete or Clay) . Asphalt shingles are the most competitive asbestos-cement roofing
9
fihingles substitute, even though they have a shorter service life than other substitutes (National Roofing Contractor's Association 1986), Before I960, most asphalt shingles had an organic or wood-pulp base. Today, however, 63 percent of standard strip asphalt shingles have a fiberglass base. All asphalt shingles are fire resistant (fiberglass-asphalt shingles have a Class A fire rating, the highest fire rating available; organic-asphalt shingles have a Class C fire rating, which is a lower rating than Class A, but still somewhat fire resistant). Fiberglass-asphalt have slightly less bulk and are lighter weight than the organic-asphalt shingles (Asphalt Roofing Manufacturer1s Association 1964). Some contractor's prefer the organic- asphalt because they have a longer proven track record than fiberglass -asphalt shingles and some of the very light weight and cheaper fiberglass-based Shingles are very brittle; however, any feel that this problem has been resolved by the manufacturers (Qualified Remodeler Magazine 1966. RSI 1966a), There aTe over 20 domestic manufacturers of asphalt shingles including Owens-Coming Fiberglas, GAP, Georgia Pacific, and Lunday-Thagard (Owens-Corning Fiberglas 1986, Asphalt Roofing Manufacturer's Association 1981).
Although not as fire resistant, red cedar wood shingles and shakes are popular roofing substitutes. Cedar shingles are made in the Northwest and In British Colixnbia, Canada by over 450 mills; however, some of these are virtually one man operations (Red Cedar Shingle 6 Handsplit Shake Bureau 19B5). Ninety-five percent of Canadian production is shipped to the U.S. and accounts for 70 percent of U.S, domestic consumption (Red Cedar Shingle A Haudspllt Shake Bureau 1986a). Rad cedar shingles and shakes are distributed across the tf.S,* the highest concentration being in California, Washington, Oregon, and Texas (Red Cedar Shingle A Handsplit Shake bureau 1986b), Only 15 to 30 percent of cedar roofing shingles and shakes are fire resistant, with a fire rating of either Class B or Class C. Because of the fire hazard posed by
10 -
non-fire resistant cedar roofing shingles, some California towns have outlawed their use (RSI 1986b, American Vood Treating 1986, Chemco 1986a and b). Approximately 72,000,OQP squares of asphalt fiberglass and organic strip shingles were produced in 1985 (Asphalt Roofing Manufacturer's Association 1986, See AttachmentT Item 6).
The tile roofing market is about the same sire as the cedar roofing market, each of which are leas than one-tenth the size of the asphalt roofing shingle market (National Tile Roofing Manufacturers Association 198{t Red Cedar Shingle and Handsplit Shake bureau 1986a, Asphalt Roofing Manufacturers Association 1986). Concrete comprises 90 percent of the tile market and clay holds the remaining 10 percent (National Tile Roofing Manufacturer's Association 1986), Tile is used primarily In the Sunbelt -- Florida, California, and the South (Raleigh 1986, National Tile Roofing Manufacturer's Association 1986), It Is very insul&tlve because the air space between the tile and the undarlayment creates a heat flow barrier (National Tile Roofing Manufacturer's Association (n.d,)). Tile is available in three main styles: s-tile, mission, and flat (shakes or slate-like). There are more than 13 U.S. concrete tile manufacturersi the largest in the U.S. and the world is Monier Roof Tile In Orange, CA (Monier 1986a, National Tile Roofing Manufacturer's Association (n.d.)), The four clay roof tile manufacturer's, all located near clay deposits, are ludowici-Celadon, New Lexington, OH,; U-S. Tile, San 'Valle, and MCA in Corona, CA (National Tile Roofing Manufacturer's Association 1986). Slate is very expensive and has a very small share of the roofing market. It la primarily used in the Vermont and New York area, the two states where it is quarried.
The coat of asbestos-cement shingles and substitute roofing and Siding
products are compared in Table k.
11
TflfeU k, C O *t OC A/TC STiitifclM A id S u b s t i t u t *
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Siding. Bood siding is the most expensive asbestos*cement siding substitute o v e r a l l A s b e s t o s - c e m e n t shingles, vinyl siding, and aluminum siding are close in overall price.
The substitute market for asbestos-cement siding shingles is divided among wood (hardboard and cedar shakes and shingles), 40 percent; vinyl, 35 percent; and aluminum, 25 percent (see Attachment, Items 4-5).
Roofing - Table 4 shows that asphalt roofing shingles, the most popular substitute for asbestos-cement roofing shingles, are also the least expensive overall, even though they have half the service life. Both tile and cedar shingles and shake roofing are more than double the cost of asphalt roofing (see Attachment, Items 11-14).
The current market share for substitute roofing shingles, based on 1905 production, is asphalt shingles (primarily asphalt-fiberglass), &6 percent, with tile (primarily concrete) and cedar wood shingles each taking 7 percent (see Attachment, Item 6), Asphalt-fiberglass shingles has been and continues to be the fastest growing segment of the roofing market, while cedar roofing shingle and shake production has declined since 193 (Red Cedar Shingle & Handsplit Shake Bureau 19B6b).
Because the domestic asbestos-cement shingle market is 77 percent siding and 23 percent roofing (FEZ 19B6), the combined roofing end siding replacement market for asbestos*cement shingles would probably breakdown as foLlows (see Attachment, Items 4*7):2
2 For the asbestos regulatory cost model, in order to simplify the number of inputs, wood siding and wood roofing are combined into one wood roofing/ siding category for which price and market share are determined (see Attachment, Item 4*7, 11),
13
Projected Market Share
(percent)
Hood
32
Vinyl
27
Asphalt
20
Aluminum
19
Tile
2
Total
100
Table 5 presents the data for the asbestos regulatory cost model and summarizes the findings of this analysis.
. Summary Asbestos-cement siding shingles resemble shakes or machine-grooved shingles and asbestos-cement roofing shingles gamerally resemble either shakes or slate (Supradur 1585), They are primarily being used for replacement and maintenance in luxury homes, schools, churches, and historical restoration projects (Atlas 1986b, Supr&dur 1986a). Of three domestic producers in 1981, only one, Supradur, remains in 1986. Production has declined 34 percent fro 266,670 squares in 1981 to 176,643 squares In 1985 (ICF 1986, TSCA 1982). Only one company, Atlas International Building Products (AIBP) of Montreal, Quebec, Canada is known to import asbestos-cement shingles into the U.S. (Atlas 1986a, Atlas 1986c). There are no substitutes for asbestos-cement shingles for maintenance and repair applications because no substitute products resemble the asbestos product closely enough to replace it in part (National Roofing Contractor's Association 1986, Supradur 1986b). However, there are many adequate substitutes that can be used for complete replacement, remodeling or in new construction. The replacement market Is as follows: wood siding and roofing,
14
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32 percent; vinyl elding, 27 percent; asphalt-based roofing, 20 percent; eltunInna siding, X? percent; and tile roofing, 2 percent. Vinyl end aluminun Siding cost about the sane as the asbestos product. Asphalt 'based roofing shingles are about half the cost, and tile roofing and wood siding and roofing are 43-60 percent more expensive than asbestos-cenent shingles.
16
ATTACHMENT
(1)
Calculation of percent of asbestos in domestic asbestos-cement ahinples.
One. donas tic producer has a production capacity of 134,800 squares or 12,000 tons for siding shingles and 40,000 squares or 9,300 tons for roofing shingles (PEI 1986), This gives an average weight of 178 lbs*/square ((12,000 tons x 2,000 lbs,/ton)/(134*800 squares)) for siding shingles and 475 lbs*/square ((9,500 tons x 2,000 lbs */ton)/(40,000 squares)) for roofing shingles, This yields a roofing and siding shingle weighted average weight of 246 lbs,/square ((134,800 squares x 178 lbs,/square +- 40,000 squares x 475 lbs,/ square)/l74,800 squares). The domestic producer's shingles have an average of 44 lbs. of asbestos per square. Therefore, ((44 lbs. of asbestoa/square)/246 lbs./square) x 100 -- 17.89 percent ox 18 percent asbestos by weight in asbestos-cement domestic shingles.
From the production capacities In squares shown above, it is estimated that 77 percent of the asbestos-cement shingle market is siding and 23 percent is roofing.
(2)
Calculation for imports of asbestos-cement shinelea.
10,416,3785 tons of asbestos-cement flat and corrugated sheet and asbestos-cement shingles were imported into the U.S. in 1985. 81.5 percent, or 8,489 tons, of this figure was from Canada, Atlas International Building Products (AlbP), the only importer of these products from Canada estimates that 80 percent of their imports is asbestos-cement shingles (Atlas 1986a), Ten percent equals 6,791 tons or 13,382,000 lbs. of asbestos-cement shingles,
AIBP estimates that 60 percent of the asbestos-cement shingles imparts are siding and 40 percent are roofing shingles:
Siding - 0.6 x (6,791 tons) - 4,075 tons - 8,150,000 lbs. Roofing - 0,4 x (6,791 tens) - 2,716 tons - 5,432,960 lbs.
AlBP's siding and roofing shingles weigh 155 lbs./square and 450 lbs./square, respectively.
Siding Shingles -- (6,150,000 lbs,)/(455 lbs./square) - 52,561 squares
Roofing Shingles - (5,432,960 lbs.)/(450 lbs./square) -- 12,073 squares
Total Imports -- 64,654 squares
This estimate may be Low because it does not Include the 18,5 percent of asbestos-cement products other than pipe, tubes, and fittings imported from countries other than Canada. These imports from other countries may possibly include acme flat asbestos-cement shingles (U.S. Dep. Coma. 1986a, 19H6b).
17
(3) Calcult i(ms for changes in production of asbestos -canent shine U s between 1981 and 1985 (TSCA 1982. ICF 1986).
<1985 production - 1981 production/1981 production) * 100
- (176j6^3 squares - 266,670 squares/266,670 squares) * 100
- -33.8% - -34%.
Domestic production has changed as follows :
<1985 production * 1981 production/1981 production) + 100 - (176,643 squares - 153,603 squares/I53,603 squares) * 100 - 15%.
<4)
Calculations for the share of cedar shingle and hardboard In the wood
siding market.
Members of the Red Cedar Shingle and Handtplit Shake bureau produced
355,825 squares in 1985, Since this association accounts for only 70 percent
of the cedar shingle and shake market, 355,825/0.70, or 508,321 red cedar
shingles and shakes were produced in 1985 (Bad Cedar Shingle and Handsplit
Shake Bureau 1986a and b ) , This combined with 1,123,992 squares of hardboard
aiding produced in 1985 makes for a total of 1,637,313 squares (American
Hardboard Association 1986a and 1986b).
'
<508,321/1,637,313) * 100 - 31% red cedar siding <1,128,992/1,637,313) * 100 - 69% hardboard siding
<5)
Estimates of the proiacted market share for wood, vinyl, and n 1mnirmm in
were based on estimates from the following references :
Qualified Remodeler Magazine 1986; Alcoa 1986a and b; Contractor's Guide
1986.
(6) Calculations of proiacted market shares in tho asbestos-cement shingles replacement roofIne. market.
Asphalt fiberglass and organic standard strip shingles produced in 1935 - 71,766,672 <Asphalt Roofing Manufacturer's Association 1966b),
Members of the Red Cedar Shingle and Handsplit Shake Bureau produced 3,885,174 squares of roofing shingles and shakes in 1985, Since this association accounts for only 70 percent of the cedar shingle and shake market, 3,885,174/0.70, or 5,550,249 squares of red cedar shingles and shakes for roofing were produced in 1985 (Red Cedar Shingle and Handsplit Shake Bureau 1986a and b ) ,
About 6,000,000 squares of tile roofing were produced in 1965 (National Tile Roofing Manufacturer's Association 1986).
This makes a total of 83,316,921 squares consisting of 66.1 percent asphalt shingles, 6.7 percent wood, and 7.2 percent tile.
18 -
(7) Calcular ion of total replacement: market shares ,
The following calculations are baaed on the fact that 77 percent of the
asbestos-cement shingle market is siding, and 23 percent is roofing (PEI 1966).
Wood roofing 6.7* (0,23) +
and aiding 40.0* (0,77) - 32.34* - 32*
Vinyl
35.0* (0,77) - 26.95* - 27*
Asphalt
S6.1* (0.23) - 19.60* - 20*
Aluminum
25.0* (0.77) - 19.25* - 19*
Tile
7.2* (0.23) - 1.66* - 2*
(6)
Calculation of costs for asbestos-cement roofing and siding shingles.
Tha asbestos-cavent shingle F.0.B, plant cost le based on Supradur's average price according to an IGF survey (ICF 1986), The aibestOi-cement shingle installation cost is a weighted average for 325 lb,/square and 500 lb./square roofing shingles and 167 lb,/square siding shingles (Means 1986a).
Roofing asbestos-canont shingle cost
325 lb. $40/squara 500 lb. 73/sauare Average $56.50
Siding asbestos-cement shingle cost $46/aquare for 167 lb./square (Means 1986).
Because 77 percent of asbestos-cement shingle market Is siding and 23 percent roofing,
(56,50/square * 0.23) + ($46/square * 0.77) - $68.42
- $48 for installation of asbestos-cement shingles,
(9)
Cost of vinyl siding.
The F.Q.B. plant cost for vinyl siding is based on the following references: Alcoa 1986a and b; Certain-Teed 19B6.
The installation cost is for solid PVC panels 8 h-10t< wide, plain or insulated (Means 1986).
(10) Cast of aluminum aiding
The F,0,B, plant cost for aluminum siding is based on the following
references: Alcoa 1986a and b; Certain-Teed 1986.
The installation cost for aluminum siding is the same as for FVC siding (American Memo Improvement 1986; Wages and Evans 1986; Johnny B. Quick 1986).
19
<11) Cost of wood sidine and roofing.
To determine the cost of wood Biding end roofing, costs era first derived separately for wood siding alone and wood roofing alone. These coats are then multiplied by their share of the asbestos-cement shingle replacement market to give a weighted average cost for wood roofing and siding.
(a) Cost of wood siding.
The F.O.B, plant price of cedar siding shingles and shakes is $80/square (American Wood Treating 1986). The F.O.B. plant price for hardboard wood siding is $40/square (Weyerhaeuser 1986, U.S. Plywood 1986).
Since the 69 percent of the wood aiding replacement market for asbestoscement shingles is hardboard and 11 percent is cedar shakes and shingles (see previous calculations), the average cost for all wood siding will be
($80/square x 0,31) + <$40/square x 0,69) $5 .40/square for wood siding
The installation costs for cedar wood siding shingles and shakes are averaged from Heans 1986.
16" long with 7-1/2" exposure - $7S/square IB" long with 7-1/2" exposure - $7l/square
onp with 8-1/2" exposure - SBO/squara Average of these three * $76.33 or $76/square
The installation costs for hardboard siding was estimated to be double that for aluminum and PVC, or 126/squ*re. Even if this estimate is a bit high, it will include the cost for painting that hardboard siding requires (American Home Improvement 1986, Noon Sidings 1986, National Home Improvement Co. 1986).
The weighted average cost for all wood siding is based on 69 percent of the replacement market being hardboard and 31 percent cedar siding (see previous calculations).
<$126/square x 0,69) + ($76/square x 0.31) - $110.50 or $Lll/*quare is the average installation cost for wood siding.
The operational life for wood siding is determined by taking a weighted average of that for hardboard and for cedar wood.
Hardboard life - 23 years (American Hardboard Association 1985, Weyerhaeuser 1986).
Cedar life
- 40 years (1CF 1985).
(40 years x 0.31) + (25 years x 0,69) - 29.65 years - 30 years
20 -
(b) Coat of wood roofing.
The average estimated F O B , plant cost for non-fire treated cedar roofing shingles is $66/square (American Wood Treating 1986, RSI 198$, Chemco 1986a).
The installation cost is an average of IS" and 18" roofing shingles.
16* -- $64/square 16J^_^_58^sijTjare Average - $61/square
(c) Cost of wood siding and roofing
The vood roofing market represents 1.54 percent of the entire asbestos^cement shingle replacement market. The vood siding market represents 50.80 percent of the entire asbestos-cement shingle replacement market for a total market share of 32.34 percent for vood (see previous market share calculations). Therefore, roofing is ((1.54/32.34) x 100), or 4.8 percent of the vood replacement market and siding is ((30.80/32.34) x 100), or 95.2 percent of the wood replacement market.
Thus the weighted average F.O.B. plant cost for vood is:
($52/squsre x 0.952) + ($68 x 0.048) - $52.77/square -- $53/square
The weighted average cost for Installation of wood roofing and siding Is:
($lll/square x 0.952) + ($61/square + 0.046) - $106.60 - $109/square
The total cost for wood i s :
$52.77 + $108.60 - $161.37/square or ($163/aquare x 0.952) + ($129/square x 0.048) - $167.37/square
The average weighted operating life for wood roofing and siding is:
(30 years x 0,952) + (40 years x 0.048) - 30.48 years - 30 years
(12) Cost^for asphalt, standard strip shinties.
The F.O.B. plant cost for asphalt shingles is a weighted average of asphalt fiberglassi 83 percent, and asphalt organic, 17 percent, shingles (Asphalt Roofing Manufacturer's Association 1986).
Average price for fiberglass shingles - $16.50/squart (Owens-Coming 1986),
Average for organic shingles - $20/*quart (Owens-Corning 1986).
($18.50/square x 0.S3) - <$20/square x 0.17) - $18.75 - $19/square is the cost for asphalt shingles.
Installation cost is also a weighted average of standard strip organic, 235-240 lb./square, and fiberglass, 210-235 lb,/square shingles.
21
Installation cost for fiberglass - $30/square (Means 1986) Installation cost for organic - $27/square (Means 1986)
(SSO/square x 0.83) + ($27/&quaTe x 0.17) - $25.50 - $3Q/square is the average cost for installation of
asphalt shingles.
(13) Cost of roofing tile.
The tile market Is about 10 percent clay tile and 90 percent concrete tile (National Tile Roofing Manufacturer's Association 1986).
The F,0.5, plant cost for clay tile is an average of four companies, San Valle, U.S, Tile, MCA, and Ludovicl-Celadon'a prices for Mission, S, and Flat tile. S-tlle was weighted 65 percent while the Mission and Flat were each weighted 17.5 percent. Ludowici's average price was weighted 30 percent, while the other three companies were each weighted 23.33 percent (U,. Tile 1986, MCA 1986, San Valle 1986, Ludoviei-Celadon 1966). This gave a clay tile price of $134/square.
((0.30 <0.233 <0.233 (0,233
(0.65 * (0,65 * (0,65 * (0.65 *
250,00 + 70.40 + 55.00 + 58.50 +
0,175 * 310.00 0.175 * 0.175 * 0175 *
+ 0.175 97.20 + 106.00 + 90.40 +-
* 310,00))+
0.175 *
114.75)) +
0.175 * 106.00)) +
0.175 *
100.57))).
The national average F.O.6. plant cost for concrete tile is $55/square (Monier Roofing Tile Company 1986a and b).
Using the above tile market shares an average weighted price was derived: ($55/square x 0.90) + <$134/square x 0.10) - $62.90 - $63/square for tile roofing, F.O.B. plant.
Installation cost for clay was based on an average of S and Mission tile:
Mission - $E4/square (Means 1986) B-Tile - $1307aguare (Means 1986) Average cost - $107 for clay tile Installation
Installation for concrete tile Is based on the S-tlle and corrugated tile - $U0/square (Means 1986).
Total installation cost for tile, concrete (90 percent) and clay (10 percent), is: ($110/square x 0.90) + ($107/square x 0.10) - $109.7 * $110/squaTe.
(14) Present value calculations for substitutes.
life of asbestos product life of substitute product
TG - total cost of product
22
PV - TC x (a/b) x (b-l)/(a-l)
a - U.05)N* b - (1,05)N
- 7.0400
(a) Vinyl flIdlnp
TO - $113/square
- 11.4674
FV - $ U J square x (11,4674/7.04003 x (7.0400 - 1)/(11.4674 - 1) - $106.31 - $10&/square
(b) Aluminum aiding
TC - $128/aquare
- 11.4674
FV - $128 square x (11.4674/7.0400) x (7.0400 - 1)/(11.6674 - 1) - $120.31 - $120/square
(a) Wood siding
TC - $16/square - 4.3219
PV - $163 square x (4.3219/7.0400) x (7.0400 - 1)/(4.3219 - 1) - $181.95 - $182/square
(d) Uopd roofInf
- 40 years
Therefore FV - TC
(e)
TO - $l2/&quare
- 4.3219
FV - $162 square x (4.3219/7.0400) x (7.0400 - 1)/(4,3219 - 1) - $180.83 - $181/square
{f) Asphalt roofing
TC - $49/square
N
""
- 2.6533
23
FV - $49 square x (2,6553/7,0400) x (7,0400 - l)/(2.6533 - 1) - $67.47 - $67/square
{g) Tile roofing
TC $173/square
50 years (1.05) - 11.4674
FV - $173 square x (11,4674/7.0400) x (7,0400 - 1)/(1L.4&74 * 1) - $162.61 - $162/square
(15) Calculations for product asbestos coefficient: for Asfrfatos Regulatory Cost Madel,
Tons of asbestos used per unit of output
-- 3,893 tons/176,643 squares 0.0220 tons/square
(16) Calculations for conauaption-productIon ratio for Asbestos Regulatory
Cost Model.
'
(Domestic production + Imports)/Domestic production
(176,643 squares + 64,654 squares)/(176t643 squares) -- 1,37
24
REFERENCES
A3A/NA and AI, 1906 (June 29). Opening written comments of the Asbestos Information Association/North America and Asbestos Institute on EFA's proposed mining and import restrictions and proposed manufacturing, importation and processing prohibitions. Testimony of Alfred E. Nettar, President of Supradur Manufacturing Corporation.
Alcoa. R, Egbert. 1986a (November 25). Alcoa Building Products. Rockville, Maryland. Transcribed telephone conversation with Michael Cesohvlnd, 1CP Incorporated, Washington, D.C.
Alcoa. J, Kelemen, 1906b (December 5), Alcoa Building Products. Rockville, Maryland. Transcribed telephone conversation with Michael Geschwind, 1CP Incorporated, Washington, D.C,
American Hardboard Association. 1985 (June). Association literature; "Questions, Answers: Hardboard Siding." Palatine, IL.
American Hardboard Association. 1986a (October). Association Literature: Exterior vails product shipments 1977-1985." Palatine, IL,
American Hardboard Association. 1986b (November 25). Palatine, IL. Transcribed telephone conversation with Michael Geschwind, 1CF Incorporated, Washington, DC.
American Home Improvement Co, M. Duncan. 1986 (December 11). Brentwood, Maryland. Transcribed telephone conversation with Hichat1 Geschwind, ICF Incorporated, Washington, D.C.
American Wood Treating. J, Feaver. 1986 (November 21). Mission, B.C.,
Canada. Transcribed telephone conversation with Hiehael Geschwind, IGF
Incorporated, Washington, D.C,
`
Asphalt Roofing Manufacturer's Association. 1981. Rockville, Maryland. Association literature: "What you should know about fiberglass shingles."
Asphalt Roofing Manufacturer's Association. 1984. Rockville, Maryland. Association literature; "The Asphalt Roofing Industry."
Asphalt Roofing Manufacturer's Association. 1986 (February 2). Rockville, Maryland. Association Literature: "Production of strip shingles,"
Atlas International Building Products. R. Gadleux, 1986s (October 1 and
December 17). Montreal, Quebec, Canada. Transcribed telephone conversation with Michael Geschwind, ICF Incorporated, Washington, D.C.
Atlas International Building Products. X. Eames. 1986b (November G). Fort Newark, NJ. Transcribed telephone conversation with Michael Geschwind, ICF Incorporated, Washington, D.C.
Atlas International Building Products. J. Payee. 1986c (November 25). Montreal, Quebec, Canada. Transcribed telephone conversation with Michael Geschwind. ICF Incorporated, Washington, D.C.
25
Atlas International Building Products. R, Cadieux, 1587 {July 7). Montreal. Quebec, Canada, Transcribed telephone conversation with Michael Geschvind, ICF Incorporated, Washington, D.C.
Cartain-Teed, S. Howe, 1986 {December 4). Valley Forge, FA, Transcribed telephone conversation With Michael Geschvind, ICF Incorporated, Washington, D,C.
Chetato, D, Fandrem. 19Ba (November 21). Ferndale, WA. Transcribed telephone conversation with Michael Geschvind, ICF Incorporated, Washington, DC,
Chemco. F. TroEi.no. 1986b (November 21, Ferndale, WA, Transcribed telephone conversation with Michael Geschvind, ICF Incorporated, Washington, DC.
Commonwealth Aluminum. B, Sullenberger. 1986 (December 4). Bethesda, Maryland, Transcribed telephone conversation with Michael Geschvind, ICF Incorporated, Washington, DC,
Contractors Guide Magazine. 1986 (February). Skokie, XL. 60077. Siding/Sheathing Survey. Market Report #9- pp. 1-10.
Etemit, Inc, B, Morrissey. 1986 (November 4), Reading, PA, Transcribed telephone conversation with Michael Geschvind, ICF Incorporated, Washington, DC.
ICF Incoxporated. 1985, Appendix H: Asbestos Products and Their Substitutes, in Regulatory Impact Analysis of Controls on Asbestos and Asbestos Products, Washington, D.C.: Office of Pesticides and Toxic Substances, U.S. Environmental Protection Agency,
ICF Incorporated. 1986 (July-December), Survey of Primary and Secondary Processors of Asbestos-Cement Shingles, Washington, DC,
Kruse11 H . , Cogley D. 1982. CCA Corp, Asbestos substitute performance analysis: Revised final report. Washington, DC: Office of Pesticides and Toxic Substances. U.S. Environmental Protection Agency Contract 68-02-3168,
Johnny E, Quick. H. Ryan, 1986 (December 11), Washington, DC. Transcribed telephone conversation with Michael Cesohvind, ICF Incorporated, Washington, DC.
Ludovici-Celadon. D Mohler. 1986 (November 25), New Lexington, OH. Transcribed telephone conversation with Michael Geschwind, ICF Incorporated, Wash ington, DC,
MCA. Sales Representative, 1986 (December 3). Kahanichi Ceramics Company. Corona, C A . Transcribed telephone couveraation with Michael Geschwind, ICF Incorporated, Washington, DC.
Means. 1986. Kingston, MA- 02364. Means Building Construction Cost Data. Shingles, Roofing and Siding, R.S. Means Company Inc. pp, 141-150,
26
Monier Roof Tile Company. B. Mittenmeyer. 1986a (November 25), Lakeland, FL. Transcribed telephone conversation with Michael Geschwlnd, IGF
Incorporated, Washington, DCr
Monier Roof Tile Company. T. L u a . 1966b (November 29). Coronar GA. Transcribed telephone conversation with Michael Geschwlnd, ICF Incorporated, Washington, I>C.
Moon Sidings. S, Cbo, 1986 (December 11), Fairfax, VA. Transcribed telephone conversation with Michael Geschvind, ICF incorporated, Washington, DC.
National Home Improvement Co., Inc, H. Richard. 1986 (December 11). Washington, DC. Transcribed telephone conversation with Michael Geschvind, ICF Incorporated, Washington, DC.
National Roofing Contractor's Association. J. WoLenski, 1986 (November 13). Chicago, IL. Transcribed telephone conversation with Michael Geschwind, ICF Incorporated, Washington, DC.
National Tile Roofing Manufacturer's Association. W. Pruter. 1986 (November 13). Los Angeles, CA 90039. Transcribed telephone conversation with Michael Geschwind, ICF Incorporated, Washington, DC.
National Tile Roofing Manufacturer's Association, (n.d.) Los Angeles, CA
90039. Association literature: Roofing tile; List of Members, 1966-1987.
Owens*Corning Fiberglas. 8. Persinger. 1966 (November 21). Toledo. OB. Transcribed telephone conversation with Michael Geschvind, ICF Incorporated, Washington, DC.
PEI, 1986 (September 26), OTS survey of Suptadur Manufacturing Corporation, Rye, NY. Completed by Alfred E, Setter. President of Supradur.
Qualified Remodeler Magazine, B, Sour, 1966 (November 25), Division of Marcourt, Brace, Jovanlch, Chicago, IL. Transcribed telephone conversation with Michael Geschvind, ICF Incorporated, Washington, DC.
Raleigh Incorporated, B, Raleigh, 1986 (November 17). Belvedere, IL. Transcribed telephone conversation with Michael Geschvind, ICF Incorporated, Washington, DC.
Red Cedar Shingle A Handsplit Shake Bureau. 1965 Bellevue, WA. Association literature: "Of shakes and shingles. ; "Timeless beauty: red cedar
shingles ft handsplit shakes."
Red Cedar Shingle & Handsplit Shake Bureau. P. Wood. 1986a (November 21). Bellevue, WA, Transcribed telephone conversation vlth Michael Geschwlnd, ICF Incorporated, Washington. DC.
Red Cedar Shingle & Mandspllt Shake Bureau. 1986b. Bellevue, WA. Association literature: Production and distribution of red cedar shingles and handspllt shakes, 1963-1985,
RSI, 1986a (August). Chicago, IL. Roofing, Siding, and Insulation Magazine.
- 27
"The fiberglass shingles flap," p. 10.
RSI. 1966b (October), Chicago, IL, Roofing, Siding, and Insulation Magazine, 'ban-aid for wood shakos?' p. 32.
San Vail Tile Company. J. Danner. 1986 (December 3), Corona, CA, Transcribed telephone conversation with Michael Gescbwind, ICF Incorporated, Fashington, DC, Supradur Manufacturing Corporation. 1985 (September), Wind Gap, PA, Product literature on pre-shrunk mineral fiber siding and roofing specifications,
Supradur Manufacturing Corporation, 1986a (July 15), Testimony of Alfred
Matter, President, at the Environmental Protection Agency legislative hearing
on its asbestos ban and phase out proposal.
'
Supradur Manufacturing Corporation, M, Mueller. 1986b (November A). Wind Gap, PA, Transcribed telephone conversation with Michael Geschvlnd, ICF Incorporated, Washington, DC.
Supradur Manufacturing Corporation, A. Hotter. 1986c (November 4). Letter to Michael Geschvlnd, ICF Incorporated, Washington, D,C.
TCA Section 6(a) Submission. 1982. Production Data for Primary Asbestos Processors, 1981. Washington, DC: Office of Toxic Substances, U.S, Environmental Protection Agency, ERA Document Control Ho, 20-3601012,
tr.5. Department of Commerce. 1986a. U.S. Department of Commerce, Consumption of Imports FY 246/1985 Annual. Suieland, MD. Bureau of the Census. U,, Department of Commerce.
U.S, Department of Commerce F. Confer. 1986b (October 3). Suitlaud, HD. U.S. Department of Connerce. Division of Minerals and Metals. Bureau of the Census, Transcribed telephone conversation with Michael Geschvlnd, ICF Incorporated, Washington, DC,
U.S. Plywood. G. LandIn, 1986 (November 25), Stanford CT. Transcribed telephone conversation with Michael Geschvlnd, ICF Incorporated, Washington, DC.
U.S. Tile Company. L. Llnville. 1986 (December 3). Corona, CA. Transcribed telephone conversation with Michael Geschwiud t ICF Incorporated, Washington, DC.
Wages and Evans. G. Evans. 1986 (December 11). Transcribed telephone conversation with Michael Geschvlnd, ICF Incorporated, Washington, DC.
Weyerhaeuser Corporation, G. Downey. 1986 (December 4). Transcribed telephone conversation with Michael Geschvlnd, ICF Incorporated, Washington, DC,
28
M i l . DRUM BRAKE-L1NIHGS A. Product Description Most new light and medium vehicles, i.e,, passenger cars and light trucks,
are equipped with drum brakes on the rear wheels (and disc brakes on the front). A drum brake consists of a metal drum within which there are two curved metal 11shoes,1* lined on the outside with molded friction material, celled drum brake linings. When the brakes are applied, the curved shoes are pressed out against a metal drum that is connected to th* wheels of the vehicle. The pressure of the shoes against the drum stops the turning of the wheels. There are two drum linings (one for each brake shoe) for each wheel (CM 1966a, ICF 1965).
In light and medium vehicles, the lining segments ere usually a third of an inch thick or less. In heavy vehicles (i.e. , heavy trucks and off-road vehicles), the segments are at least three-quarters of an inch thick and are called brake blocks, instead of drum brake linings (Allied Automotive 1986).
Asbestos-based drum brake linings contain approximately 0.38 lbs.l of asbestos fiber per lining on average (IGF 1986a), Asbestos is used because of its thermal stability, reinforcing properties, flexibility, resistance to wear, and relatively low cost (Krusell and Cogley 1962).
The primary production process for drum brake linings is a wet-mix process in which asbestos is combined with resins, fillers, a n d 'other product modifiers and the mixture is then extruded into flat, pliable sheets. The sheets are cut, formed into a curved shape, and then molded for 4 to 8 hours under moderate heat and pressure. After grinding, the linings are bonded (glued) or riveted to the brake shoe (1CF 1965). While bonded brake linings
1 S e e A t t a c h m e n t , T ten 1.
-1 -
have greater frictional surface area, riveted linings are quieter (Allied Automotive 1986)*
Secondary processing of drum linings may be of several types. Some processors install new brake linings into brake assemblies for vehicles. Others repackage linings for sale as replacement parts In the aftermarket. Neither of these secondary processes involve grinding, drilling, or any other treatment of the brake linings that Is performed by the primary processors. Another distinct type of secondary processing is automotive rebuilding. Rebuilders receive used, worn brake linings attached to the shoes. The old linings are removed from the shoes, the shoes are cleaned by abrasion, and nev linings are attached. The rebuilt shoes with linings are then packaged and sold for the aftermarket (ICF 1985, Krusell end Cogley 1982).
B. producerft and Importers of Drua Brake Linings
Table 1 lists the thirteen primary processors of drum brake linings in 1985. All produced an asbestos-baaed product. Nine of the processors also produced substitutes (IGF 1986a).
Changes in primary processors from 1981 to 1985 Include Friction Division Product's purchase of Thiokol's Trenton, NJ, plant and Brake System Inc.'s purchase of one of Raymsrk's Stratford, CT, plants (Friction Division Products 1986; Brake Systems 1986). Brassbestos of Paterson, NJ, vent out of business in August, 1985 (ICF 1986a) and H.K. Porter of Huntington, IN, discontinued production of drum brake linings in 1986 (FBI Associates 1986), Thus, eleven companies continue to produce asbestos drum brake linings.
Table 2 lists the five current secondary processors of drum brake linings.
The Standard Motor Products plant was formerly owned by the 1S division of Parker-Hannifan (ICF 1986a). At Echlin's Dallas, TX, plant, which was formerly owned by Raymark, linings are attached to brake shoes without any
2
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additional processing (Brake Systems 1986). Similarly, Vagner installs brake
linings with no additional processing (Wagner 1986a).
Table 3 lists the twenty-one importers of asbestos-baaed drum brake
linings.
C. Trends
Table A gives the production of asbestos-based drum brake linings and the
corresponding consumption of asbestos fiber. Prom 1981 to 1985 there was a
19.6 percent decline in production of asbestos drum brake linings. This is
probably due to substitution of asbestos in the OEM, and the fact that certain
luxury and high-performance cars, that currently account for roughly 5 percent
of OEM light/medium vehicles, are now equipped with four disc brakes (e.g.,
Cadillac Seville and El Dorado, Corvette, Pontiac STE and Piero, and
high-performance Cemaros and Firebirds) <GM 1986a),^
In addition, it should be noted that some luxury imports, e.g., Mercedes,
BMW, and Saab, use disc brakes on all four wheels (CM 1986a, Saab-Scania of
America 1986). New Saab cars, in fact, use non-asbestos semi-metallic disc
brake pads on all four wheels (Saab-Scania of America 1986). Information was
not available on whether all four disc brakes in Mercedes and EMW cars were
also non-asbestos-based. Nonetheless, the great majority of imported vehicles
are still equipped with asbestos-based rear drum brakes
h
1986, MIT 1986).
(Ford 1986a,
Abex
Producers and purchasers of drum brake linings indicated that as of the
1986 model year, asbestos linings still account for 90-95 percent of the
original equipment market (OEM) and virtually 100 percent of the aftermarket
<GM 1986a, GM 19B6c, Chrysler 1986, Allied Automotive 1986, Wegner 1986b, Ford
1986a). However, producers and users agreed that adequate substitutes have
^ Disc brakes are a higher-performance brake. Applications of drum and disc brakes are discussed in further detail later in this section.
5
{IGF 1986a). Wagner installs asbestos and non-asbestos brake pads with no additional processing {Wagner 1986a)r
Table 3 lists the 19B1 and 1985 importers of asbestos-based disc brake pads.
C, Trends
Table 4 gives the production of asbestos-based disc brake pads (Light/ medium vehicles) and the corresponding consumption of asbestos fiber. The percent change in production and fiber consumption from 1981 to 1985 are -30.2 percent and *25.3 percent, respectively.
It should be noted that some luxury import cars are now equipped wLth four semi-metallic disc brakes (Allied Automotive 1986). Saab is one such example
+ (Saab-Scania of America 1986). However, the great majority of imported cars still have asbestos-based rear drum brakes (Ford 1986a, Abex 1986, HIT 1986).
A survey of producers, purchasers, and other sources revealed that
currently asbestos probably holds no more than 15 percent of the OEM for disc brake pads (light/medium vehicles) (ICF 1986a, GM 1986a, Ford 1986b, Chrysler 1986, Chilton's Motor Age 1986, Allied Automotive 1986, DuPont 1986).4 The
share, however, is significantly higher for the aftermarket, though probably not a majority (GK 1986a),^
Allied Automotive stated that by 1990 asbestos would be replaced by nearly 100 percent in the OEM (Allied Automotive 1986), One source stated that by 1990, 90 percent of OEM light/medium vehicles are projected to be front-wheel drive, requiring semi-metallic disc brakes In the front (Chilton's Motor Age 1986), Given the above two projections and the current trends of GM, Ford, and Chrysler, it is clear that by 1990 asbestos-based pads will be almost
^ See Attachment, Item 2. See Attachment, Item 2.
6
Table 4. Production and Fiber Consumption for Asbestos*Based Drum Brake Linings
1981
1965
References
Production (pieces)
Asbestos Fiber Consumption (tons)
160,470,368 129,042,578*
23,676.0
24,691.
ICF 1966a, TSCA 1982a 1CF 1966a, TSCA 1982a
Abex. Allied Automotive (both plants), Brake Systems, and Brassbestos did not provide production information. Brassbestos went out of business in August, 1965; ft is assumed that they produced asbestosbased drum brake linings in 1965 (IGF 1966a). Production was estimated for these four companies using a method described In the Appendix A of this R l A r
^ Abex, Allied Automotive (both plants), Brake System, and Br&sabestos did not provide fiber consumption information. Brassbestos vent out of business in August, 1965; however, it is assumed that they consumed asbestos fiber for the production of asbestos-based drum brake linings In 1985 (1CF 1966a). Fiber consumption for these four companies was estimated using a method described in Appendix A of this RIA.
7
been developed for many, if not most, OEM drum brake lining applications (Abex
1986, GM 19B6c, Ford 1986a).^ A report by the American Society of Hechanleal Engineers concluded that automobile and most trucks could have completely non
asbestos friction systems by 1992 (ASHE 1987) * Producers and users stated
that time is required to gear up commercial production of the substitute linings, redesign brake systems to accommodate the particular coefficient of friction of the substitute material (where required), and to conduct field
tests in order to gain the acceptance of lining producers, vehicle and brake system manufacturers, and consumers (GM 1986c, Ford 1986a, Abex 1986)*
With the exception of Allied Automotive and Abex, producers are apparently not yet producing substitute drum brake linings in sizeable quantities (ICF
i
1986a),^ Estimates for the tune required to develop adequate production
capacity for substitutes were not available; however, this time period is likely to be linked to vehicle manufacturers' approval of new substitutes*
Unlike disc brakes pads, in which a superior substitute has been available
for the last fifteen years (i.e., semi'metallic pads), non-asbestos drum brake
linings are relatively new (Abex 1986, Ford 1986a), Both producers and users
of brake linings are highly averse to the risk that could be associated with
the use of new materials* The risk is magnified, furthermore, when a major brake system redesign is required for a substitute lining (Abex 1986, Ford
^ Representatives from Ford and GM agreed there vers adequate substitutes for many light/medium vehicle applications (cars and light trucks), but there were problems with finding good substitutes for large cars and medium-sized trucks (e.g,, 2 1/Z-ton delivery trucks) (Ford 1986a, GM 1986c), A representative from Abex, however, firmly believed that adequate substitutes have been developed for all drum brake lining applications (Abex 1986),
k As indicated earlier. Allied Automotive estimates that 18 percent of Its 1986 drum brake lining production will be nan-asbestos (Allied Automotive 1986)* Abex did not provide an estimate of the current share of its OEM drum brake linings that are non-asbestos, but did indicate that a significant percentage was non-asbestos (Abex 1986),
S
1906a, CM 1986c, Allied Automotive 1986, Wagner 1986b).5 This risk translates
into stringent and lengthy testing processes required by both government end
automobile and brake lining manufacturers before acceptance Of new friction
materials and brake systems.
Sufficient laboratory and vehicle testing has been conducted for the
substitute drum brake linings in order to certify that they comply with
federal performance and safety regulations (Abex 1986, Ford 1986a, CM 1986c).
However, vehicle manufacturers also require, on average, a total of one
million miles of field testing in a variety of geographic locations, and under
a variety of road conditions, before a new brake lining material or brake
system design will be Incorporated into OEM vehicles. Brake lining producers
and vehicle manufacturers agreed that this field testing has only begun (Abax
19B6, Ford 1986a, GH 1986c).
According to Ford, a potential alternative for asbestos in drum brake
linings would be to make light/medium vehicles with four non-ashestoe
(semimetallic) disc brakes (Ford 1986a).^ However, brake lining producers
5 Producer* and users stated that there are two general types of substitute linings -- those that require only minor modifications of brake systems and those that require major modifications or total brake system redesigns (Ford 1986a, Abex 1986),
^ Compliance with federal performance and safety regulations *- Federal Motor Vehicle Safety Standards (FMVSS) 105, 121, and the proposed 135 * can he certified at the testing facilities of OEM brake lining producers. At these facilities, producers always employ, at a minimum, dynamometer testing (recognized in the induetry to be the most reliable and accurate laboratory testing method) and vehicle testing in a controlled environment (i.e,, race track) (Abex 1986, Ford 1986a, GJi 1986c).
^ Semi-metallic disc brakes are already used on the front wheels of 85 percent of all new light/medium vehicles (Allied Automotive 19B6), and certain domestic luxury and high-performance cars are now equipped with four non-asbestos disc brakes {GH 1986a). Disc brakes, particularly semi-metallic disc brakes, have higher performance than drum brakes because they have longer service life and are generally better at removing heat quickly (GM 1986a). Perhaps even more important for automakers, disc brakes have a very strong marketing advantage: disc brakes make cars sell. They are an Important selling point with consumers (Ford 1986a, GM 19B6a, Abex 1986).
9
and vehicle manufacturers agreed that there currently is not a significant trend towards four disc brakes in light/medium vehicles, nor is there likely CO he In the near future, because of important performance and economic factors (Abex 1986, GM 1986a. GM 19B6c, GMI 1986, Ford 1986a). First drum brakes make superior parking brakes (GK 1986a, Ford 1986a, Abex 1986). Disc brakes, furthermore, reduce fuel economy because of ''parasitic drag** and are much higher in coat than drum brakes because of the mechanical system required for disc brakes (Ford 1966a, GM 1986a). Because drum brakes are significantly cheaper and are a lover performance brake, they are used for the rear wheels, with disc brakes in the front, in the vast majority of the light/medium vehicle OEM (95 percent) (Gil 1986a). In moat light/taedlum vehicles, particularly those with front-wheel drive, there Is significantly less brake load or brake force In the rear than in the f r o n t . T h e r e f o r e , the cheaper lower-performance drum brakes are used in the rear since the rear brakes do not have to do much work (GM 1986a).^ A final key factor that would stall a significant switch-over to four-disc-brake cars is the enormous equipment redesign that would be required (GMI 1986). Therefore, for the above-mentioned reasons, drum brake linings, at least in the near future, will continue to he produced for the light/medium vehicle OEM at roughly a 1:1 ratio with disc brakes.
The parking brake either utilizes the existing rear drum brakes (service brakes), is a separate rear drum brake, or Is a separate front disc brake (front parking brake) (GM 1986a).
The remaining 5 percent are the luxury and high performance cars equipped with four disc brakes (GM 1986a).
In front-wheel drive cars, the brake load le 85 percent In the front and in rear-wheal drive cars, about 70 percent of the load Is in the front (Ford 1986a, Design News 1989).
H In most cars, In fact, rear drum brakes would have the same service life as rear disc brakes because of tbe light brake load (GM 1986a),
10
D. Substitutes
As indicated earlier, primary processors and vehicle manufacturers agree
that acceptable drum brake lining formultions have been developed for many, if not most, drum brake lining applications. Although these substitutes do not have the same performance characteristics as asbestos-based linings (no substitute currently provides all the advantages that asbestos linings do), they are "acceptable" front the standpoint of vehicle drivers: drivers vill accept changes in performance, as long as there are no "surprises" while driving that reduce safety (Abex 1966, Ford 1906a, Gft 19B6c, MIT 1966). Nonasbestos organics (NAOs) are acceptable substitutes that have been developed for the OEM. Lining producers and vehicle manufacturers agree that NAOs would take the majority of the asbestos-based OEM in the event of a ban (CM 1986c, Abex 1986, Ford 1986a, Carlisle 1986).
NAO drum brake lining formulations, In general, include the following: fiberglass and/or Kevlsr(K), mineral fibers,^ occasionally some steel wool, and fillers and resins (Ford 1986a), Fiberglass and Kevlar (Et), however, usually account for only a Small percentage of the total formulation. For example, a representative from Ford stated that the optimal level of Kevlar(R) in drum brake lining formulations is usually about 3 percent by weight (Ford 1986a). Thus, labelling substitute drum brake linings as Kevlar(R)-based or fiberglass-based (producers tend to do this for marketing reasons) la misleading (Abex 1906, Ford 19B6a, CM 1986c).
Of the thirteen primary processors of drum brake linings In 1986, at least eight currently produce MAO linings. These firms are: Allied Automotive, General Motors Inland Division, Abex, Nutum, Virginia Friction Products,
1? Mineral fibers commonly used by producers include: vollastonlte, phosphate fiber, aluminum silicate fiber, Franklin fiber, mineral wool, and EMF (processed mineral fiber) (ICF 1966a).
11
Chrysler, Carlisle, and Brahe Systems Inc. (1CF 1986a). Although, the producers did not reveal the exact formulations of their NAO linings, they provided partial lists of the ingredients in their mixtures (IGF 1986a).
Five of The primary processors also produce a semi-metallie drum brake lining. These firms are: Abex, Allied Automotive, Carlisle, General Motors Inland Division, and H.K. Porter (Abex 1986, Allied Automotive 1966, IGF 1986a). Lining producers and vehicle manufacturers generally agree, however, that there are serious production and performance problems with semi'metallic drum brake linings (Abex 1986, GM 1986c, Ford 19&6a, Carlisle 1986). H.K. Porter, in fact, discontinued its semi-metallic (and asbestos) drum brake lining operations In 1986; the firm stated that it was unable to find adequate substitute linings (PEI Associates 1986). Representatives from Abex and Ford stated that semi-metallies are very difficult to process into Che required thin arc-shaped lining segments and are. thus, very prone to crack (Abex 1986, Ford 1986a).^ These representatives also stated there vara unacceptable performance problems, including 'morning sickness,* which involves moisture getting into the lining overnight, rendering the product useless until it heats up and dries out (Abex 1986, Ford 1986a). For the above reasons, lining producers and vehicle manufacturers agreed that semi-metallies would not take much of a share of the asbestos-based OEM In the event of a ban (Abex 1986, GH 1986c, Ford 1986a, Carlisle 1986).
Primary processors and vehicle manufacturers agree that there is adequate dynamometer and vehicle-testing capacity among the OEH producers to develop substitutes for the remaining OEM drum brake lining applications, i.e. medium-sized trucks with four-drum-brake systems. The difficulty in
Semi-metallies can, however, be successfully manufactured for very heavy brake block applications, where the arc of the segments is much wider than in drum brake linings (because of the larger drum) and the segments are considerably thicker (Abex 1986).
12
developing acceptable substitute linings for medium-sized, trucks results from the more severe braking requirements for the rear drum brakes of these vehicles than for the majority of light/medium vehicles and the fact that the drum brake linings for medium-sized trucks must be riveted, not bonded, to the brake shoe. Thus, an acceptable substitute lining must have structural strength around the rivet area (Batelie 1987), Nevertheless, given enough time substitute linings for medium-sized trucks will be developed, particularly since brake systems con always be redesigned by including servo mechanical systems to amplify or modify the braking ability of a particular substitute lining in order to achieve the desired performance (Ford 1986a, Abe* 1986, GH 19&6c, IT 1986),
Replacement of asbestos-based drum brake linings in the aftermarket,
however, may be much more difficult. Host asbestos-based drum brake linings
producers and auto manufacturers agree that brake systems designed for asbestos linings should continue to use asbestos linings. The parties maintain a position that substitute lining formulations that ware designed for
the OEM, when used to replace worn asbestos linings, do not perform as wall as
asbestos, and could jeopardize brake safety (Allied Automotive 1986, Gtt 1986b, Gti 1986c, Wagner 1986b, Ford 1986a, Ford 1986b). Abex, however, Indicated that it Is selling Its OEM non-asbestos organic drum brake linings for the aftermarket and reports that they are performing wall (Abex 1986).
In general there are three important reasons for little or no development of substitute formulations engineered for aftermarket brake systems designed for asbestos:
Considerable technical difficulties with developing adequate substitutes for a system designed specifically for asbestos;
- 13 -
* No federal safety and performance standards for brakes for the aftermarket;!^ and,
High cost of producing and testing substitute formulations (Ford 1986a, Vagner 1986b, Abex 1986).
Aftermarket producers, except for those vho also produce for the OEM, are
generally small and almost totally lacking in testing equipment (Ford 1986a),
Two firms stated that if some of these firms devoted substantial resources to
testing and research and development, they would be out of business (Ford
1986a, Abex 1986), As long as there are asbestos drum brakes sold in the
aftermarket, there will be little, If any, economic Incentive to develop
retrofit substitutes (LJ Space Center 1986), however, even with a ban on
t
asbestos Linings for the aftermarket, the cost of substitutes designed for the
i
aftermarket are Likely to be prohibitive, given the technical difficulties
(LBJ Space Center 1986).
Table 5 provides the data for the regulatory coat model. The substitute
linings in the table are an NAG lining produced by Abex and a semi-metallie
lining made by General Motors Inland Division. It is assumed that
semi-metallic drum brake linings will account for a negligible share of the
market, Note that the equivalent price of the NAD lining given In Table 5 is
close to the asbestos lining price because of the longer service life,
E, Simmarv
'
Asbestos drum brakes are found on the rear wheels of most new light and
medium vehicles, i.e., passenger cars and light trucks (GM 1986a), Thirteen
companies produced asbestos drum brake linings In 1985 and by the end of 1986
only eleven continued to produce the asbestos product (IGF 1986a, PEI
Associates 1986). In 1985, these producers consumed 24,691.8 tons of asbestos
to produce 129,042,578 asbestos drum brake linings. Between 1981 snd 1985,
!^ by contrast, OEM brakes must meat federal regulatory standards FMVSS 105 and 121 (and, in the future, the proposed 135).
14
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production of the asbestos linings declined 19,6 percent {IGF 1986a), However, asbestos linings still accounted for 90*95 percent of the OEM and virtually 100 percent of the aftermarket (GM 1906a, GM 1986c, Chrysler 1906, Allied Automotive 1986, Vagner 1986b, Ford 1986a). Acceptable substitutes have been developed for many, If not most, drum brake lining applications. For the OEM, NAQs are expected to take 99 percent and semi-metallice 1 percent of the asbestos drum brake lining market if asbestos were not available, NAQs coat the same as asbestos linings, while semi-metallies cost 73 percent more than the asbestos-based product. Developing adequate substitutes for the aftermarket will be difficult due to technical difficulties and economic factors.
ATTACHMENT
1. The asbestos fiber content per lining waa calculated by dividing the 1965 asbestos fiber consumption for drum brake linings by the 1985 production of drum broke linings for producers for which both fiber consumption end production data were available: 24,691.'8 tons (49,383,600 lbs.) divided by 129,042,570 pieces, or 0.38 lbs per piece.
2. A large producer of asbestos-based drum brake linings in 1981, stated that
the share held by asbestos in Its OEM linings was 97 percent In 1983, 96
percent in 1984, 91 percent in 1989, and is estimated to be 82 percent In
1986, One automobile manufacturer stated that currently 95 percent of its
OEM drum brake linings were asbestos-based (CM 1986a). A second
automobile manufacturer stated that currently 98.5 percent of its OEM
linings were asbestos-baaed (Chrysler 1986). On the basis of these
figures, it is assumed that asbestos holds roughly 90-95 percent of the
OEM for drum brake linings. Two major producers of brake systems for the
automobile and truck aftermarkets stated that 100 percent of the
aftermarket was still asbestos-based
.
3. The product asbestos coefficient is the same value calculated in Item 1 above, converted into tons per piece,
4. The consumption production ratio was calculated using 19,580,493 pieces as the value for the 1985 U.S. imports. (Total 1985 production is 129,042,078 pieces.) This value, however, only includes imports for the firms who provided information (see Table 4).
5. The asbestos product price is a weighted average (by production) of prices
for producers who provided information. The useful life of the asbestos
product was assumed to be the same as that reported in 1984 in Appendix A
(3C7 1985), The two substitute lining prices were calculated by
increasing the weighted average asbestos product price by what Abex and
Gtf, respectively, reported as the percentage price increase for their
substitute product over their asbestos product. One company indicated
that its KAO lining cost 25 percent more than Its asbestos-based lining;
another company stated Its semi-metallic lining was approximately 73
percent higher than its asbestos lining. While the first company did not
indicate the service life of its MAO lining compared to its asbestos
product, another manufacturer linings had the same or up to
of 50
MAO drum brake percent longer
linings, service
a reported that
life. Thus,
MAO
service life Increase of 25 percent over the life of the asbestos product
(that was given in Appendix H) is used in Table 5. It was not clear
whether semi-metallic linings had longer or shorter service life than
asbestos linings; therefore, the same service life as the asbestos product
is used.
17
REFEREHCES
Abex Corp, R, Kelson. 1966 (December 3). American Society of Mechanical Engineers Conference in Washingtont D.C. Transcribed conversation with Richard Hollander, ICF Incorporated, Washington, D.C.
Allied Automotive. E. Rogers, 1966 (October 17). Troy. NY. Transcribed telephone conversation with Richard Hollander, IGF Incorporated, Washington, D, C.
ASNE. 1987 (April, 15). The American Society of Mechanical Engineers. Final Report on Analyses of the Feasibility of Replacing Asbestos in Automobile and Truck Brakes. Prepared for the Environmental Protection Agency,
Automobile Importers of America. 1966. Comments of Automobile Importers of America on Proposed Asbestos Ban Rule, EFA Document Control No, OPTS-62036.
Battolie Columbus Laboratories. E, Barber. 1987 (June 26). Columbus, OH.
Transcribed telephone conversation with Hichael Geschwind, TCF Incorporated, Washington, D.C.
Brake Systems Inc. S. Mayo. 19 B6 (November 18), Stratford, CT. Transcribed telephone conversation with Richard Hollander, ICF Incorporated, Washington,
D.C.
Carlisle. R. Temi. 1986 (October 17). Ridgvay, PA. Transcribed telephone conversation vith Richard Hollander, ICF Incorporated, Washington, D.C.
Chrysler Corp, M. Heitkamp. 1986 (November 4). Detroit, MI. Transcribed telephone conversation with Richard Hollander, ICF Incorporated, Washington, D.C.
Design News, S. Scott.
1984 (March 26),
Asbestos Substitutes in Friction Applications.
Ford Motor Co, A. Anderson. 1966a (December 3), American Society of Mechanical Engineers Conference in Washington. D.C. Transcribed conversation with Richard Hollander, ICF Incorporated, Washington, D.C.
Ford Motor Co. 1986b. Comments of Ford Motor Co. on Proposed Asbestos Ban Rule. ERA Document Control No. OPTS-62036.
Friction Division Products. R. Carney, 1986 (July-December). Trenton, NJ. Transcribed telephone conversation with Richard Hollander, ICF Incorporated, Washington, D.C,
General Motors Corp. F. Brookes. 1986a (November 19). Dayton, OH, Transcribed telephone conversation with Richard Hollander, ICF Incorporated, Washington, D.C,
General Motors Corp. 1966b, Comments of General Motors Gorp, on Proposed Asbestos Ban Rule. BPA Document Control No. OPTS-62036.
16
General Motors Corp. F, Vem i e . 1906c (December 3). American Society of Mechanical Engineers Conference it) Washington, D.C, Transcribed conversation with Richard Hollander, ICF Incorporated, Washington, D.C.
General Motors Institute, 5. Cratch, 1986 (December 3*). American Society of Mechanical Engineers Conference In Washington, D.C. Transcribed conversation with Richard Hollander, IGF Incorporated, Washington, D.C,
IGF Incorporated. 1984. Imports of Asbestos Mixtures and Products, Washington, D.C.: Office of Pesticides and Toxic Substances, U.S. Environmental Protection Agency, EPA C6I Document Control Mo. 20'8600681.
ICF Incorporated. 1985, Appendix H; Asbestos Products and Their Substitutes, in Regulatory Impact Analysis of Controls on Asbestos and Asbestos Products. Washington, D.C,: Office of Pesticides and Toxic Substances, tl.S, Environmental Protection Agency.
ICF Incorporated. 1986a (July-December). Survey of Primary Processors of Disc Brake Fads (Light and Medium Vehicles), Washington, D.C,
ICF Incorporated- 1986b (July-December), Survey of Secondary Processors of Disc Brake Fads (Light and Medium Vehicles), Washington, D C
Kruse11 N . , Ccgley D, 1982. GCA Corp. Asbestos Substitute Performance Analysis, Revised Final Report, Washington, D.C.: Office of Pesticides and Toxic Substances, U.S.. Environmental Protection Agency, Contract 68-02-3168,
Lyndon B. Johnson Space Canter. J. McCullough. 1986 (December 3). American Society of Mechanical Engineers conference in Washington, D.C, Transcribed conversation with Riehard Hollander, IGF Incorporated, Washington, D.C,
Massachusetts Institute of Technology. E. Rabinowicz. 1986 (December 3), American Society of Mechanical Engineers Conference in Washington, D.C. Transcribed conversation with Richard Hollander, IGF Incorporated, Washington, D.C.
Original Quality, Inc, 1986. Comments of Original Quality. Inc. on Proposed Asbestos Ban Rule, EFA Document Control Ho. OPTS-62036.
PEI Associates. 1986. OTS. Survey of Asbestos Product Manufacturers. Washington, D.C.: Office of Pesticide* and Toxic Substances, U.S. Environmental Protection Agency,
Saab-Scania of America. D. Rainey. 1986 (November 21). Orange, CT, Transcribed conversation with Richard Hollander, ICF Incorporated, Washington, D.C,
TSCA Section 8(a) Submission, 1982a. Production Data for Primary Asbestos Processors, 1981. Washington, D.C.: Office of Toxic Substances, U.S. Environmental Protection Agency. EPA Document Control No. 20-8601012.
19
TSCA Section 0(a) Submission. 1962b. Production Data for Secondary Asbestos Processors, 1961. Washington, D.C,: Office of Toxic Substances, U.$. Environmental Protection Agency. EFA Document Control No. 20*6670644. Vagner Corp. F, Hayes. 1966a (December 5). Farsippany, N.J. Transcribed telephone conversation with Richard Hollander, ICF Incorporated, Washington, DC, Vagner Corp. 1966b. Comments of Vagner Corp. on Proposed Asbestos ban Rule. EFA Document Control No. OPTS-62036,
- 20