Document gDqDnkM7JYYXEY02B3mwr3NnV

FILE NAME: General Motors (GM) DATE: 1992 Oct 8 DOC#: GM049 DOCUMENT DESCRIPTION: Letter to EPA from GM H R V - 1 3 - 1 9 S 8 16 '23 CMDfOPemTTONS BRRNCt-t 2 0 2 2 6 0 1724 P. 06^'29 General motors corporation 1660 X. CTREltT. N -V . mtXSHtSCTON. D. C. 30036 October 8, 1992 Mr. John W. Melone, Director Chemical Control Division Environmental Protection Agency 401 M 'St, SW Washington, D.C. 20460 Dear Mr. Melon: This responds to the questions posed in your September 1, 1992 letter concerning General Motors use of asbestos-containing products, your questions and our responses are as follows: Are asbestos-containing parts still included in new vehicles? What parts still contain asbestos? Asbestos rear drum brake linings are used on a limited number of General Motors 1993 passenger car models. No other asbestos-containing parts or components are currently used on General Motors vehicles. Bow extensively are asbestos--containing parts used? For example, what percent of the market? For the 1993 model year, it is estimated that approximately 20 of G M rs total North American vehicle production will be equipped with asbestos-containing rear drum brake linings. Are asbestos--containing parts being phased out? What is the schedule for phasing out asbestos-containing products? The use of asbestos-containing products in GH vehicles has been declining for a number of years. Although future product plans are proprietary and 05/13/98 16:16 TX/RX NO.2120 P.006 MAr'13-1998 16--29 CHD-OPERATIONS BRANCH 202 260 1724 P. 07/'29 subject to change, it is anticipated that all hew CM vehicles will be asbestos--free within the general tine frame specified in the now vacated EPA rule. what are your company's views on continuing the phase out of asbestos? As indicated above, our current plan is to continue the phase out of . asbestos on GH vehicles* As GM and others stated during the asbestos rulemaking proceedings, the objective data demonstrates that the use of asbestos in motor vehicle brake linings does not pose a risk to public health or safety. Nevertheless, the tremendous investment cost of converting to non asbestos has been largely expended, and we plan to complete the conversion given the regulatory uncertainty surrounding asbestos. Bow will the phase out of asbestos in new vshlclss affect the use of asbestos-containing replacement parts in the aftermarket? Will the aftermarket automatically phase out asbestos as new vehicles phase out asbestos, or will asbestos replacement parts continue to be used as a cheap substitute for non-asboatoa original equipment? With regard to the products that GM produces and distributes for aftermarket service, it is our intention to provide non-asbestos parts to be used for marvicinq toon-aabeatoe OEM parts. We do not know what third-party aftermarket suppliers might do. fOn a related note, it continues to be GM's osition that asbestos-containing OEM brake inings should be serviced with asbestos- containing replacement linings. At ths OEM level, the conversion to non-asbestos brake linings is accompanied by a redesign of other brake components in an effort to optimize overall brake 05/13/98 16:16 TX/RX NO.2120 P.007 tt: MAY-13-1998 16-`29 CMD-OPERATIONS BRANCH 202 260 1724 P. 067'23 system performance. Using non-asbestos brake linings as replacements parts in vehicles that were originally designed with asbestos-containing linings will result in brake system performance compromises that range from modest customer dissatisfaction (from brake noise, for example) to significant stopping distance penalties. The servicing of asbestos-containing OEM linings remains an issue that the EPA should address. How will one company*s phase out o asbestos affect the company's competitiveness in the domestic market and in the international market vis-a-vis another company, foreign or domestic, that does not phase out asbestos? An automotive company that chooses to phase out asbestos could incur a competitive disadvantage relative to another automotive company that does not phase out asbestos. The disadvantages could include the large investment costs required to convert to non-asbestos, variable cost penalties of non-asbestos versus asbestos, and potential customer dissatisfaction related to noisy brakes, reduced lining life, etc. These competitiveness considerations would likely hold true regardless of the country-of-origin of the manufacturers or the markets in which the vehicles are sold. I hope the above information is helpful to you. If you have further questions, please call Phil Horton, General motors Automotive Safety Engineering, on (313) 947-- 1738. sincerely. ( J & A S O U 2 fri / Edward M. Kavjian, Jr. Industry-Government Relations General Motors Corporation 05/13/98 16:16 TX/RX NO.2120 P.008