Document QgzNE8q6VdGmdLBVq2qz996do
Nissan
Need longer lead time: Light-duty vehicle, front brakes -- at least 5 years Light-duty vehicle, rear brakes -- at least 6 years
Light-duty trucks -- impossible to say Clutch linings -- at least 6 years
Rule should not apply to replacement parts.
Rule should only apply to major vehicles redesigned (as new models are introduced).
EPA should devise a flexibleexemption procedure.
Chrysler
Believe they can comply with time table of Alternative 2 except for trucks..
Truck brakes will be asbestos-free at end of 10-year period specified in Alternative 2.
EPA should publish guidelines forexemptions.
Exempt aftermarket.
Proposed schedule:
Product Category Construction products,clothing Passenger car brakes; all transmission
applications All other cases in motorvehicles
Time 2 years
7 years 12 years
Modification of Alternative 2 represents most practical approach.
General Motors
Brake testing process can require up to 5 years.
Exempt aftermarket replacement for older vehicles.
In 1979, GM made goal to eliminate asbestos from brakes by 1985.
Largely met on front disc brakes Not met on rear drum brakes due to:
squeal wear
friction stability
70 percent reduction Is too severe after first year.
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