Document X8rKZJEpV7pj47m9BE6LZmMyR

Loma L Linglel* Mr. J. W. Duxstine John, thought this might bo of interest in your activity. I'-'xr 105567 005994 PRODUCED BY FORD SCF-ALLF-08060 wagner CONSIDERATION ON, REGULATING THE COMPOSITION OF BRAKE LINING Wagner Electric has an interest in the application aspects of any regu lations affecting the composition of brake lining. We do not manufacture brj> lining. We are a major producer of passenger car and truck brakes. We are a major manufacturer of replacement shoes and pad secs for passenger cars and cracks. We therefore are vitally interested in any change m composition of brake lining because of the ultimate effect these changes will have on per formance, wear life, vehicle safety and compliance with existing Federal and state regulations. It has been the experience of Wagner Electric that the rulemaking method employed by various Federal Agencies is an effective means to develop back- ` (j)* grcimd for potential rulemaking activity. The Advance Notice of Proposed Rule making (ANPRM) provides a public announcement of a very general nature. It allows all interested parties to contribute facts and opinions of meric in helping that particular agency develop the course for its future rulemaking action. We have seen instances where the National Highway Traffic Safety A&niniscraclon (NETSA) initiated an Advance Notice of Proposed Rulemaking, and based an the public disclosures and their own research either terminated rulemaking action or progressed deeper into the sequence of rulemaking. We have been reviewing Che input (docket submissions) to the Eavironmeatal Protection Agency (EPA) and Consumer Product Safety Commission (CPSC) Encircled numbers refer to the illustrations in Appendix A. 005995 PRODUCED BY FORD -2files on Che Joint proposal which might result in an ultimate ban on asbestos [44FR60056], Our survey of these submissions thru February 11, 1980 indicates that there have been 37 CPSC Docket" entries and 83 EPA Docket entries for a total of 120 submissions. Some of these filings are duplicate entries. From the standpoint of activity which relates to brakes, vehicles and repair facil ities we have found these following entries: 1 Brake Manufacturers , .0 Lining Manufacturers 0 Lining Associations 3 Vehicle Manufacturers 0 Repair Facilities the EPA file is fortunately not limited to docket submissions by the public. The Zrcket number OPTS 61005 "Record of Rulemaking" has a Table of Contents sscv;-g thirteen categories of activity. Their (EPA) resourcefulness in search ing for facts is to be commended. Their success will be highly dependent on the -pebila- submissions. Ve doubt that this is an adequate public response. The text of the ANPFLM is somewhat lengthy but it is factual and direct to the objective. Many manuf act .iters or interested parties may have elected to not make a submission on the 'itemise that the rulemaking action was directed only to those who convert ashastos into some useable end product. *.agner Electric did not take a limited viewpoint. Our presentation will Iif. ,ome of the highlights from our December 12, 1979 submissions to these d* :s to explain the manner by which we provided the EPA and the CPSC with i-; ation we consider vital to their study. This is an opportunity to help oorr organizations understand the complex technical environment their study erir-iches. This is the time to provide facts and share the coaauerclal experie~'i that we have gained in a highly specialized segment of a large industry. 005996 PRODUCED BY FORD -3- The government groups need to decide whether to terminate r.Is-akirg action on certain products or to continue more intensive and specific rulemaking action. The 3 portions of our docket entry that vill be covered this naming are: (1) the state-of-the-art for non-asbestos lining, (2) Regulatory interface, (Z/ alternatives to a full ban on asbestos. Vs .,..11 not be talking about conversion of asbestos into brake lining. Ue will concentrate on the use of the brake lining and the necessity for the ETA L to evaluate many cotmercial aspects of the problems related to the docfc=t activity. STATE-OF-THE-ART OF NON-ASBESTOS LIKING " c tost recent press (industry) releases and magazine articles imply that there i-T an almost immediate capability to eliminate asbestos from brake lining. Sucn claims are not representative of the true state-of-the-art from non-asbestos lininis We base this belief on the small number of test materials that we have hat frtf lining manufacturers. We'll help you look at the overall scope of the market and the need to evaluate the success or failure of the tests of these mate rial a before concurring in the validity of the development claims. We also must c-temane their true availability based on committed tooling by the manufaccur.r and use these findings to see if we can procure the material needed to serve.*- a very extensive market. , . 'r Look at the number of applications that need to be covered by fit * *aterials in the braking area only. Friction reauirements are eii__* - for a variety of vehicles because of the different types of appli cator- , the speeds at which they operate, the frequency of brake applications, c.*,r t r service and the durability needed to have long intervals between 005997 PRODUCED BY FORD -4relining and servicing. Vagner is extensively involved in supplying original equipment brake assemblies, aftermarket linings and replacement shoe and lining assemblies. Our aftermarket program is one example of the complexity of a changeover. We require 216 dimensionally unique segments for drum brakes and 134 unique disc pads for our passenger car replacement program even though this program already incorporates a high degree of standardization and simplifi cation. We have surveyed our current varieties of lining compounds and the sources for these materials. In these several categories we have a total of 50 materials that ve purchase from 10 different sources. ORIG. EQUIPMENT + AFTERMARKET 'APPLICATIONS PASSENGER CAR TRUCK SEGMENTS TRUCK BLOCKS NUMBER OF LINING COMPOUNDS SOURCES 20 5 18 5 16 6 CUMULATIVE 50 10 Let's look at the characteristics that are needed for OEM and replace- cert materials. Most of these are self-explanatory. DESIRABLE CHARACTERISTICS OF A SUITABLE LINING MATERIAL , "TALLY SOUND NO MORNING SICKNESS -1UM/ROTOR LIFE ACCEPTABLE WATER RECOVERY ,,-_\BING -:TENT FRICTION - HOT & COLD ' ..-.SLE NOISE LEVEL PHYSICAL FLEXIBILITY FOR ATTACHMENT TO SHOES USING STANDARDIZING SEGMENTS LIGHT WEIGHT * Erratic braking or "grabby" lock up on first stops. 005998 PQ PRODUCED BY FORD -5- Now consider the variety of brake designs used on ols and new venicles. PASSENGER CAR & TRUCK HYDRAULIC BRAKE TYPES TRUCK, TRACTOR & TRAILER AIR BRAKE TYPES INDUSTRIAL BRAKES (EXTERNAL) 'JON-SERVO CAH AIR SERVO DISC hydraulic DISC WEDGE SPRING/SOLENOID Tnere is considerable technical literature available on the subject of fcrc. f goeraetry and effect of fricdon materials on design, performance and sensitivity. We have submitted several of these and their bibliographies to t -1 EPA/CPSC dockets for reference purposes. * nsidermg all of the above brake types it aopears likely that only the ;er car and light truck disc brakes will have a suitable non-asbestos tr'f'-on material available In the reasonably near future. Z .ere will be a long transition as development efforts continue to be d Vetted towards the availability of (1) a substitute material that will allow vehicles to remain at or exceed today's safety level, ;2) a suitable substitute for current asbestos based materials at a reasonable cost, (2) a long wearing lining material that also causes minimal drum wear or little rotor wear. ' it this time we have as insufficient number of samples to predict a - ,cic carget date for conversion to non-asbestos strip, segment or block - ai. We expect this to be at least several years away. We look with a.= --."le at the press releases extolling the imminent availability of non- ,, -;.i lining materials without citing the limited number of applications <22 ^ , 805999 PRODUCED BY FORD -6- REGU1AT0RY INTERFACE For a very cursory look at the Federal regulatory bodies and private associations that are affected by plans for asbestos substitutes ve will only deal with 3. They are the ' (1) American Association of Motor Vehicle Administrators (AAMVA), (2) Bureau of Motor Carrier Safety (BMCS) of the Department of Transportation (DOT), (3) National Highway Traffic Safety Administration (NHTSA) (DOT). The registration of lining codes designated according to prescribed Society of Automotive Engineers' Recommended Practices (SA J661) has been facilitated by the work of the AAMVA. A rough count of the edge codes on fiJt with the AAMVA indicates that there are 120 companies who have regis tered over 1620 different edge codes. An extensive test program will evolve as Linings compounded with substitutes for asbestos are developed for release ata production. Even in this day of standardization the number of edge codes for vehicle spolications has proliferated. In the interim there will be even more. There are economic and safety..factors which continue to influence the search for improved compounds. The competitiveness of the marketplace necessitates low cost/prices. The need to meet very stringent and specific requirements for new vcmcle performance requires special materials as the Federal vehicle safety standards are revised and upgraded. The Federal Motor Vehicle Safety Regulations issued by the Bureau of Motor '.Tier Safety provide certain performance parameters for vehicles that are in ,r.ice. While these requirements are not overly stringent, they do require t-r use of reasonably satisfactory lilting materials. The regulations have been extremely beneficial over a period of many years. As simple as they are, they 006000 4 PRODUCED BY FORD -7hsve kent many inferior materials out of the market. The Safety Standards issued by the NHTSA for new vehicles have had the most powerful impact on the development of both passenger car and truck lining materials. Two basic standards cover this multitude of highway vehicles: 1) FMVSS 105 for hydraulic-braked vehicles, 2) FMVSS 121 for vehicles with air brakes. The individual performance requirements for passenger cars and chose proposed for "hides under 10,000-pounds GVWR have generated a whole host of lining materials with special characteristics to provide Che vehicle manufacturers with =o-e measure of reserve when testing to the strict compliance parameters of era f.FTSA. T ; following provides a very simple tabulation of these various require- aerti ".Lv by their title or description. FMVSS 105 SHAKE TEST REQUIREMENTS VEHICLES UNDER 10,000 LBS. GVW AND SCHOOL BUSES FIRST (PREBURNISH) EFFECTIVENESS SECOND EFFECTIVENESS PARKING BRAKE ** LIGHTLY LOADED EFFECTIVENESS PARTIAL FAILURE INOPERATIVE BRAKE POWER AND POWER ASSIST UNITS FIRST FADE & RECOVERY SECOND FADE & RECOVERY FOURTH EFFECTIVENESS WATER RECOVERY 006001 PRODUCED BY FORD -8- PROPOSED FHVSS IDS BRAKE REQUIREMENTS VEHICLES OVER 10,000 LB. CVW (Docket No. 70-27, Notice 19) PARTIAL FAILURE STOPPING DISTANCE INOPERATIVE BRAKE POWER ************************* FHVSS 121 TRUCK-TRACTOR AND TRAILER TE5T REQUIREMENTS STOPS AT GVUR PARKING BRAKE TEST AT GVWR STOPS AT UNLOADED WEIGHT PARKING BRAKE TEST AT UNLOADED WEICHT - ************ ************** FHVSS 121 DYNAMOMETER TEST REQUIREMENTS BRAKE RETARDATION BRAKE POWER HOT STOP RECOVERY 066002 PRODUCED BY FORD `he Office of Standards Enforcement (OSE) of the NHTSA has initiated a compliance evaluation program that created a commercial revolution in the assess ment of Quality Control activity by suppliers. This program enforces the work of the Office of Crash Avoidance (OCA) which must follow the Congressional mandate to issue minimum safety standards. Many persons not directly involved ir. ~ev vehicle safety standards are unaware that the OCA/OSE interpretation of "'.return" would invalidate the use of many AQL (acceptable quality level) *~T.-_ng plans, e.g., MIL-SID 105. Most sampling plans had been used through'.'i. ;~e automotive Industry to establish nominal performance levels with per- deviations. These sampling plan results were understood, accepted t*. '...reed upon when negotiated by supplier and customer in commercial contracts. * ITSA determined, in the case of safety-related products, to not accept ,, - . _-j techniques as proof of compliance to a minimum standard unless there *!'. : .Jf icient overdesign incorporated in the acceptance values to assure 100Z -.capliance. The equipment manufacturers were noc at first aware of the compliance eonsecrceJ when the Industry "nominal" design value became che NHTSA "minimum" i. - essentially making 30Z of the old product noncomplying. The Director ** *e Office of Standards Enforcement, Francis Armstrong, presented a paper -:.i._ed "The Issuea of Complying with Federal Motor Vehicle Safety Standards s ^ther Requirements" in January 1969. See Appendix 2 for excerpt. This . .r has a very clear Illustration [its Fig. 7] of the significance of che -, the suppliers had to make in their designs to assure compliance if . . design sampling plans were employed for manufacturing control. The -- paper should be a parr of che technical reference material in any design . recent for vehicle equipment suppliers or'vehide manufacturers of products 006003 PRODUCED BY FORD 10re gula ted by Federal Motor Vehicle Safety Standards. Mr. Armstrong cautioned "...It is up to the manufacturer to determine the degree of overdesign, rela tive to the minimum requirements of the standard, necessary to maintain as 'in compliance' status for his product." The evolution of FMVSS 121 for the air-braked vehicles went through a < 10-year cycle of standard development. The first version of the Standard had very stringent performance requirements for both vehicle and dynamometer tests. At one time there was only one lining material available which could meet these requirements. At the .same time there were strong objections to the com mercial acceptability of these new vehicles. The NRTSA had to reduce the severity of the stopping distance requirements and the dynamometer require ments. A broad variety of lining materials then evolved. A competitive environment was restored and consumer satisfaction is gradually returning to the heavy highway vehicle industry. ALTERNATIVES TO A FULL BAM ON ASBESTOS As the concern for asbestos fibers in the atmosphere has been given greater publicity, the large processors of asbestos-bearing lining material have taken positive steps to improve the work environment. We know that our suppliers, the lining manufacturers, have imple mented aggressive housekeeping programs and maintain their effectiveness. In the Wagner manufacturing areas we have always maintained good housekeeping practices. We use exhaust and filtering systems in our production areas where we drill, grind and rivet linings to brake shoes. The Occupational Safety and Bealth Administration (OSHA) has provided a technique and published a requirement by which we measure the effectiveness of our controlled environment. It permits us to collect, record and report 006004 PRODUCED BY FORD -11this information in a universally accepted method. Such regulatory practices are bound to have made an improvement in working conditions whether there is any real hazard to health or not. Major manufacturers and processors are able^ to control their environments. The cost of these controls has already been made part of the economic considerations in manufacturing. However, more stringent controls would certainly need cost-to-benefits analysis for Justification. The publicity associated with controls aimed at manufacturing processes has a.so provided the opportunity for preventative action in other areas e^po'-ci to asbestos fibers, fte maintain an even cleaner dynamometer test area add 'Irage area in our development facilities because we use vacuum cleaners to ''t^lett the residue of worn lining3 from both dynamometer and vehicle brake tef ; Tn.is practice could be extended to all commercial repair facilities. 'itier is one of several companies who have already incorporated a major bensfit to a repair shop environment by the preparation technique used for our ^Jtermarket lined shoe sets. Our passenger car sets are pregTound with (j) ar. art or contour of the lining controlled from the anchor pin location.^ This Laminates the need for a garage or repair facility (where there is typically less control of dust) to grind shoe and lining assemblies before ** thev era installed on the vehicle. ?re-arced lining assures better customer satisfaction, from a brake perr-rmance standpoint, because it fits into both new drums and oversize drums > wit;cut alteration. We Introduce the lined shoes into the distribution net^-rV. r-ady to install. This action has caused a significant reduction in concar. ' c.on of asbestos fibers in more public work areas, hore users need to be mane * -re aware of this side benefit of this superior product feature. We mark 006005 PRODUCED BY FORD -12our cartons to highlight (1) that no grinding is reeuired ana (2) the" have a product with asbestos content. Many of the reline shops still purchase material from ocher sources which has to be ground on their premises. If they persist m this practice there are means available to then which will reduce the asbestos fiber content in their snops. Exhaust collection and filtering equipment is available for small grinders used by such shops. We have not tried to specifically measure the magnitude of the change in 5->t- practices to use prec&ntoured lined shoes, but we have contacted manu''t.rers of shop equipment for an indication of shop trends. We learned Chat f : -CT.ber of shoe grinding attachments sold at this time is significantly less T . me number of laches purchased to face rotors ot turn drums. Until recent they sold 10 lathes to 6 grinders. Now its about 10 lathes for each tr'.-dir. Ve conclude, therefore, that the programs of major manufacturers of Afrsrsarket shoe sets which provide pre-arced or preground lining has already Significantly reduced the risk of contamination in these shops. If they use lust collection systems for what little lining dressing is necessary, and systems to clean up the worn lining debris they are well on the way to wr*-..'s atmospheres which are essentially fiber-free. CONCLUSION The actions taken by the EPA, CPSC and OSHA have already brought attention . i'-. fact that care should be exercised with materials chat are suspected -- . ".ng some hazard to health. It has only been a relatively short time : health risks have been publicized for asbestos. Asbestos has been a riruenc of brake lining for over 1/2 a century. A lot of experimentation i. ...:ng place with substitutes for asbestos. These substitutes could, in 006006 PRODUCED BY FORD -13fact, have health risks which haven't been identified. In general, industry can deal with veil Identified situations and we believe tnat the action taken by the EPA, CPSC and OSHA will further identify potential problems and will enable them to assess the cost associated with minimizing health risk. As a brake manufacturer we do not want to conduct repetitive test programs if subsequent candidates for replacement of asbestos are found to have health nsls. The lining industry, as a whole, has developed well in excess of the 57 .-.-"rounds we purchase and has many more sources than the 10 we currently satisfying the commercial needs of the original`equipment and Afterav.: lining business. ''4 emphasize that the publicity associated with new car development and . - -inence given to specific and select applications of non-asbestos :als is not representative of the mass or bulk of friction materials >a-:c it. current new vehicle production or the replacement market. 006007 PRODUCED BY FORD 800900 PRODUCED BY FORD Reproduced by VACHEt CLECTtlC COtPOtATIO* fto an SAE Fapat (Ju. 1969) 690147 CATiS V FOa.O - 017 A??gmrx a The Issues of Complying with Federal Motor Vehicle Safety Standards and Other Requirements MUH w Nf ma i -- ^ -------- yj ____ --* b ]=r menrum Francis Armstrong National Highway Safety Sc*:?-. Federal Highway Adrrvmstration. . S. Department of Transportation Excerpt Fig. 7 - Relationship between FMVSS and nominal designs !r is abundan:'; . : v no form of statistical sampling the bureau, no cleverly conceived, could be reasonably implerr--t'. .'.mdle situation where the buremi assumed ioiIiry for vslidating the manu facturers' cmiricacr*. "i-cher. the legislation is deaHy written to exclude jr .- :rrence, no maser how remote, chat the govemmen- . r .tv, in any way, to the manufac ture!' certification. Within this fnimewr.H: Unions the compliance activi ties of the bureau. Cv.- ire. so to tpetk, ia to find the "bad guys.* It is a we'.i-'.jwa.n axiom in quality control citdes that `you cannot insce-.c Quality into a product.* This ia particularly tnir in c*ir :aae, and accordingly, dm bureau's compliance testing is better defined as an audit-type opereion to proriee x measure of aastnnce that manufac turers are, thonseivc-- ill igetxly pursuing the type of pro grams that will :'eonjtaner with products thm meet, as a minimum. requirements of the Federal Mato* Vehicle Safety Sian. .. Having fecortir.tr: the requremetes exemplified by the Federal Mere- - Safety Standard* are minimum remrimnenrs. it J concluston that we do not talk in tetms of an A* :.. ._ pnY relative to those standards __ -ncr than IQOtl comolisnce. tte do. howe.e: ./* chat industry itself oust, as part or the proeve:--.- -as, think in room of a workable MJL. The ucori^i - - ...and of 'perfection in production' fust cannot be - otisr in the manufacture of such a high volume in.: :er. as the swomohUe. But, j$_ * ^ajsojusLJi, . `specs thm M the Federal Motor Vehicle Safer-' minimum requirements. they should not be used as nominal desien value*. Fig. 7 is a s>r.rv . .. .-.-trays! of thtee possible ap ptoaches iliuitrar::.,. : ' ationahip between FMVSS (Federal Motor Vehicle Safe.-v; . aids) end the establishment of nominal design viur Design value < A) has been establi shed recognizing the ef fect that normal production vatiasce would have on the compliance status of the finished product. The nominal de sign value, in this example, exceeds die requirements of the standard to the degree chat all products manufactured within the normal quality Spread attainable in actual proJi- - tion would be in cooplimsce with the standard. Design value (B). while exceeding the minimal! safety performance requirements of the standard, fails to recognise, sufficiently, the effect of normal production variance on the compliance stmua of the finished product. Accordingly, as pan of the inevitable facts of production life, me measure of noncorrplimsce war certainly exist. Design value (Q, on the otha hand, has been established using the federal standard aa the mean or central tendency of the normal distribution of quality output imder pro duction conditions. Under these circumstances, the incid ence of noacooqiliancc would, of course, be quite high. From my earlier marks establishina 100*; compliance aa the only ACL acceptable to the bureau, it is obvious rhar only die trample denictint "nominal design value (A)* ty pifies conditions that could teslisticslly be expected to achieve acceptable compliance performance bv industry. The haemt is not concerned with desipt for design's sake. The manufacturer aaist, of course, retain complete freedom of design in meeting the performance requirements of rhe in dividual standards. It is up w the manufacturer to deter mine the degree of overdesign. relative to the minimum teouiremrots of the standard, necessary to establish and maintain an *in compliance* status for his product. The degree of overdesign necessary foe any one product, be it vdnde or equipment, can. and probably will, vary from manufacturer to t^anufacrurcr. Certainly, it will be di- reedy related, among other things, to the mroufacturers' ability to monitor and control his production process. PRODUCED BY FORD IN CBSTE5