Document Xzab2vgNB58ByLBxDKxnV4oyB

HPV-.M-1998 11 ' 59 CND-OPeRATfONS BRANCH 202 260 1724 P. 09/M4 Ford Motor Company Environmental and Safety Engineering! Start 330 Town Center Drive Dearborn, Michigan 43126 November 9, 1992 Mr. John Melons, Director Chemical Control DivLslon Environmental Protection Agency 401 M Street SV Washington, D.C. 20460 Dear Mr. Malone; The following is Ford's response to the questions EPA raised in Its Septem ber 1, 1992 letter to Mr. DeWaln Belote. "1. Are asbestos-containing parts still included in new vehicles? 2. What parts still contain asbestos? 3. How extensively are asbestos-containing parts used? For example, what percent of the- market?" Ford has Limited the use of asbestos to less than 15fr of Ford'a 1993 cars and trucks. The only asbestos application remaining are rear drum brake linings where the technical challenge continues to be the development of a non-asbestos material that provides cuatooars with acceptable performance. "4. Are asbestos-containing parts being phased out? 5. What Is the schedule for phasing out of asbestos containing products? 6. What are your company's views on continuing the phase out of asbestos?" Ford's policy and supporting product plans Include replacement of all asbestos In its products with non-asbestos substitutes that will provide customers with acceptable levels of performance, reliability and quality. It is anticipated, barring any unforseen technical Issues, that asbestos will be totally phased out of Ford products over the next several model years. 05/14/98 11:45 TX/RX NO.2139 P.009 SCF-ALLF-10360 MftV--14-1990 11 ' 59 CftD-OPERftrrONS BRftNCH 2- - 202 260 1724 P. 10^'14 Whlie m r aggressively pursuing ellaliutlen of csbactos In Ford product*, Ford* i toxicology axptrtt hove concluded that Mbasco* in product use, when encapsulated Co W*ynt release Of airborne tHyra, does not peut Sw>Iih risk' These experte~bowever, believe materials that are acceptable substitutes for asbeetoe will posses soe of the physical and ohealcal_prop_e.KfeibJL.df asbestosA Therefore, asbestos substitutes should be treated with the sane cere as asbestos Itself. "7. ' Mow will the phase out of asbestos in new -vehicles affect the use of asbestos-containing replacement parts in the aftermarket? Will the aftenaarkat automatically phase out asbestos as new vehicles phase out asbestos, or will asbestos replacement parts continue to be vised ae cheap substitutes for non-original equipment?" It is Ford's understanding that the long term availability of asbestoe will be dramatically curtailed both domestically and abroad. Suppliers of asbestos indicate they will continue to support OEM manufacturers only as long as specific asbestos-containing products remain In production and may require "one-time-buys" for subsequent replacement part inventories,^ Given the --N possibility of scarce availability of asbestos manufacturing sources later In ' . the decade. Ford does not believe "asbestos replacement parts [will be] cheap j , substitutes for non-original equipment" either by OEM or after-market replace-/ V.ment part suppliers. . .. -............................................- Ford will continue to provide. non-asbestos pares as replacement for nonaebeetoe OEM parts. r The use of non-asbestos vs aebee6(Tpafta however,...... - , ./visually requires Changes to other components in brake systems to maintain '. ' acceptable performance, reliability and quality. Accordingly, Ford has no ; 'present plans to develop and test non-asbestos substitutes for asbestos.. .. . presently used in its brake replacement parts..:/'With regard to other than brake ^ /replacement parts, non-aift>&6f6i containing replacements for asbestos parts may / t or may not be provided depending on Inventory levels and availability of acceptable non:..esb.estoa..substltutes>>>Hln any casTe, maintaining acceptable .... / levels of performance, reliability`and quality, not coat, will be the primary factor that determines asbestos or non-asbestos usage. *8. How will one company'a phase out of asbestos affect the company competitiveness in the domestic market end in the international market vis-a-vis another company, foreign or domestic, that does not phase out asbestos"? i Ford has long believed that the phase out of asbestos from its products will not threaten its world-wide competitive position because its non-asbestos I bearing products will continue to provide customers with acceptable levels of \ performance, reliability and quality. ................................ Very truly yours, Executive Engineer Vehicle Safety Assurance 05/14/98 11:45 TX/RX NO.2139 P.010 CMD-OPERATIONS BRANCH 302 260 1724 P. 08' L4 Ford Motor Company Environmental and Safety Englnaertna Staff 330 Town Canter Drive Dnartiom, Mlgfilgan 43123 December 21. 1992 Mr. John Malone, Director Chemical Control Division Environmental Protection Agency 401 M Street, S.W. Washington, DC 20460 ' Dear Mr. Melono: On November 9, 1992, Ford Motor Company responded to the questions MBA raised regarding Ford's current and future use of asbestos. In. response to SPA'a question, "what parts still contain asbestos?", It was stated that rear brake drum linings were the only asbestos containing parts in 1993 Ford vehicles. We hove recently determined that Ford's response Is technically incorrect in that several 1993 Ford vehicle lines identified as having asbestos containing rear brake drum linings, in fact, are equipped with front brake asbestos containing components. Ibese vehicles with asbestos containing front brake components were, however, correctly considered in Ford's response to CPA's questions pertaining to: 1) the percent o 1993 Ford vehicles with asbestos containing parts and 2) Ford's schedule for phasing out asbestos containing parts. . We are sorry for any inconvenience this oversight may have caused, - Executive Engineer Vehicle Safety Assurance \ 05/14/98 11:45 TX/RX NO.2139 P.008