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FILE NAME Brakes BRK DATE 0000 DOC BRK163 DOCUMENT DESCRIPTION Report - Asbestos Shingles XVII ASBESTOS CEMENT SHINGLES A. Product Description All asbestos siding and roofing shingles are made from the same materials a mixture of Portland cement asbestos fiber ground silica and sometimes an additional fraction of finely ground inert filler and pigment Supradur 1986a and b Krusell and Cogley 1982 Domestically produced shingles now contain 18 percent asbestos while imported shingles have 13 percent asbestos by weight PEI 1986 ICF 1986 Atlas 1986c see Attachment Item 1 In manufacturing asbestos 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 AIA and AI 1986 Supradur 1986c Asbestos siding shingles usually resemble shakes or grooved shingles and asbestos roofing shingles generally resemble either shakes or slate Supradur 1985 The slate style is the most popular asbestos roofing shingle Most of the siding products are thinner than asbestos 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 1986 see Attachment Item ) Asbestos roofing and siding shingles have been used primarily on residential properties although some applications have also been found in schools churches and historical restoration projects Supradur 1986a Raleigh 1986 In rural areas 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 Tile Roofing Manufacturer's Association 1986 Raleigh 1986 Currently asbestos roofing shingles have relatively no use in new construction Atlas 1986b and are principally being used for replacement and maintenance in luxury homes schools churches and historical restorations Atlas 1986b Supradur 1986a For historical restoration they could be used either to preserve the historical integrity of a landmark that originally had asbestos shingles or to replace real slate with a variety of asbestos shingles that resemble slate Atlas 1986b National Roofing Contractor's Association 1986 Asbestos shingles are used mostly in the Northeast and the Midwest and are generally not found in the West or South National Tile Roofing Manufacturer's Association 1986 B. Producers and Importers of Asbestos Shingles In 1981 there were three producers of asbestos shingles International Building Products National Gypsum and Supradur Manufacturing National Gypsum stopped production prior to 1982 TSCA 1982 ICF 1984 International Building Products closed their asbestos operations completely in March 1986 however it is not known when they last produced asbestos shingles Atlas 1986a Table 1 presents production data for the only remaining domestic producer of asbestos roofing and siding shingles The only known importer of asbestos shingles is Atlas International Building Products AIBP in Montreal Quebec Canada Atlas 1986a and 1986b 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 -2- Table 1. Production of Asbestos Shingles Total Source ICF 1986 1985 Asbestos Consumption tons 3,893 1985 Asbestos- Asbestos- Cement Shingle Production squares 176,643 176,643 Table 2. Production of Asbestos Shingles Year Number of Producers Output squares 1981 3 1985 1 266,670 176,643 Sources ICF 1986 TSCA 1982 shingles has declined 34 percent since 1981 Supradur's production has increased 15 percent during this period see Attachment Item 3 It is not know how many asbestos shingles are imported in the U.S. According to the Bureau of the Census 10,416.3785 tons of asbestos products other than pipe tubes and fittings were imported in 1985 of which 8,489 tons or 81.5 percent came from Canada U.S. Dept. Comm 1986a 1986b This number most likely includes flat and corrugated asbestos sheet and asbestos shingles AIBP the only importer of these products from Canada roughly estimated that 80 percent of their U.S. shipments ere asbestos shingles Atlas 1986a Atlas 1987 Eighty percent of Canadian shipments or 6,791 tons converts to 64,654 squares of asbestos shingles imported in 1985 , D. Substitutes Table 3 summarizes the primary substitutes for asbestos siding and roofing shingles There are no substitutes for asbestos shingles in the maintenance and repair market because there are no substitute products that resemble the asbestos 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 some asbestos shingles but it is much thicker and far more expensive Supradur 1986b For our study we will consider substitutes that can be used instead of asbestos shingles for complete remodeling or new construction The following section presents separate discussions of substitutes for asbestos siding shingles and asbestos roofing shingles 1. Asbestos Cement Siding Shingle Substitutes The three primary substitutes for asbestos siding shingles are wood aluminum and vinyl siding Wood siding includes hardboard siding and Table Jaewroday for oeuUClT) SETUNS WSeTY TdepuegPuy neng % UL Gt2UWs $9G6T QE61 3. GyOYS EGE Asbestos ESSN "a YY 16769 Wp O2eMD Table Asbestos Asbestos Uy wget cepeD Wat Sees PoH TICKET isey 9 61 BO TY ERE)9961 Substitute THUOTI TQBT TEUOF youuT {run ION eH s70y OH Substitutun Canada Efective UTRQs sotequapr @tnQeow Rigd protecive BOTEUZYS arENder Bupiecs Rigd sg U.B Atractive National U.B. Stamford protecive Stamford Stamford 9upedweight eal resistant qacqord Atractive sea; More More vqu0eqy nbeyand More aluminum eoeu Usualy Usualy coating stain TsT^'l "GxiUTNS pequisd pequyed wq protective BF uy 19YQ retcey epay ATUO PURE ean PeIUep 97939 pequep Be Absorbs Absorbs eq protective protecive . Requires paint National vinyl moisture EDATSRO Requires Requires protective Qp National GED . paint e704 PASUMD-Copseqy {huts FOZ IOMITY Doesn't expand and aluminum SEANLH then "IDGUTNEA Doesn't Qupqayes expnsive petnbes yFeq tract vinyl vinyl UN like BA Doesn't con- Pur "OMET) sodnurnpy , "EMUTaNS 01982 EtESL eTNOUT cedar wtooodhcauvteONTT sng poa 2o0O2 90d BAT 'T *TdoyA exojo ays zeTeo opYyQ National Valey Cartin Won't dentd National soweuqyd WAPoTy Won't Elake Can easily National Cartin ValleyCartain Forge , F^ F^ e2a) pie peel peelElake handle blister 2.UoK easily as National National T oy "< oT%] *segonqrasy *pel-ujeq20) pur <n JOINGT Gt *poukya AvailbeAvailbe MIM oce mainteance temperature paw tva temprature a> "yh aI6Q{O 'eF104g OT sob prozueag opeury "Gu0ct] 7640 a f woyy Ta Flexible Flexible *eypon zy Terses pum /CRUPETy FuTp] BO 'gq png CEST asyaoTy deptse20 OJAI Herzen TAPESANE SidneySidney several VOpPry ZoupaT, TTISP pspre wTdeypuvy prvogpa .T^'a anuyENTy @ TRUCTIOM-OcaY Pus neImE Wutzoy ~ORGY 08 2098405 76 ,@ OREL fayzaoy Tal eTfutas wpegs Continued Continued Contiued 70K at 10 48 oes) I TepeD 906 9027 USTaBEsoYy ContiuedTewop aqdsyjni05)U9TIPTO TIZOR 201 pee Mepueg<aeT ENNID UDTIYTo Bue Substiue JFUoyARH SubstiEUTHA TED TI0g yexoTzav Heather Toledo NY waSequnpryg Georgia Pacifio GA Atlant others othersseveral Marica Marica Easy TIB\SUF Lightweight Lightweight OF * Ov Relatively Relatively /strength and ' ante STARS and CeldamMonier CA Monier OrangeLudowick 08 Celedam New Lexington Lexington , weathr Risd ~WEYBSD! Atractive resitan JOTIBM -eTqr Durable weather Beavy resistant IncombustileIncombustibleIncombustileIncombustibleIncombustible resitantPUK ExpensivEexpensive Insulative STT FO GI typ TELOD. WeSoulteaywezl ucyfnce] wqRUT UOTeETH SsTPI0RD eIBARS ASINZIO * ORspus wpeurd 3eqyo PEUOP BISYIO yp * feo SD awo703 *eTRS pO BU *efcemD SIHNW '@ k2m04 yp pocy O'sSy Va [Of TE ARE FFU FIT1Q0 AN Jes 'D'a 7.2 *eqTL opetay zeycon 2ansreg) TMORHT] TAN aLp Ag 'dVO UW pl OF meg ShPUD pus VOUTeWqTIEM seTizeqrs yanporg Way yes" yreudeypustag seTfutng Puy pooy aequg ews30) Types pur er3rB19 red cedar shakes and shingles 1 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 comes in two main sizes lap panels which are 1 foot by 16 feet and boards which are 4 by 8 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 10 major manufacturers of hardboard siding including U.S. Plywood Stamford CT Weyerhaueser Kalamath Falls OR Masonite Laurel MS and Georgia Atlanta GA Weyerhaueser 1986 Red cedar siding shakes and shingles comprise the remaining 31 percent of the wood siding category American Hardboard Association 1986a Red Cedar Shingle & 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 & 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 shingles in residential areas It 1 Shingles are sawed on both surfaces whereas shakes split surface and thus present a rugged irregular texture and Handsplit Shake Bureau 1986a have Red at least one Cedar Shingle 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 Both aluminum and vinyl siding often have a simulated 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 wall In order to minimize this expansion problem vinyl siding is only available in light colors that do not absorb as much heat Alcoa 1986b Commonwealth Aluminum 1986 Major producers of vinyl siding include CertainTeed Valley Forge PA Vipco Inc. Columbus OH Mastic 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 1986 Aluminum is a proven product and has been available for over 30 years longer than vinyl siding While aluminum is more temperature resistant than vinyl it dents much more easily than other siding products Commonwealth Aluminum 1986 Gerta^>n1986 Though metal aluminum siding resists rusting by forming a protective oxide coating Commonwealth Aluminum 1986 Three major producers of aluminum siding are Alcan Aluminum in Warren OH Alcoa Building Products in Sidney OH and Reynolds in Richmond VA vinyl siding Both Reynold ansd Alcoa also produce Painted steel stucco masonry brick and concrete blocks may also be used as siding but they will not be significant substitutes for asbestos siding shingles Commonwealth Aluminum 1986 Krusell and Cogley 1982 American Hardboard Association 1986b The primary substitutes for asbestos roofing shingles are asphalt shingles fiberglass or organic cedar wood shingles and tile concrete or clay Asphalt shingles are the most competitive asbestos roofing 9 shingles substitute even though they have a shorter service life than other substitutes National Roofing Contractor's Association 1986 Before 1960 most asphalt shingles had an organic or pulp base Today however 83 percent of standard strip asphalt shingles have a fiberglass base All asphalt shingles are fire resistant fiberglass shingles have a Class A fire rating the highest fire rating available asphalt shingles have a Class C fire rating which is a lower rating than Class A but still somewhat fire resistant Fiberglass have slightly less bulk and are lighter weight than the asphalt shingles Asphalt Roofing Manufacturer's Association 1984 Some contractor's prefer the organic- asphalt because they have a longer proven track record than fiberglass shingles and some of the very light weight and cheaper fiberglass shingles are very brittle however many feel that this problem has been resolved by the manufacturers Qualified Remodeler Magazine 1986 RSI 1986a There are over 20 domestic manufacturers of asphalt shingles including Corning Fiberglas GAF Georgia Pacific and Thagard 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 Columbia Canada by over 450 mills however some of these are virtually one man operations Red Cedar Shingle & Handsplit Shake Bureau 1985 Ninety percent of Canadian production is shipped to the U.S. and accounts for 70 percent of U.S. domestic consumption Red Cedar Shingle & Handsplit Shake Bureau 1986a Red cedar shingles and shakes are distributed across the U.S. the highest concentration being in California Washington Oregon and Texas Red Cedar Shingle & 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 fire resistant cedar roofing shingles some California towns have outlawed their use RSI 1986b American Wood Trearing 1986 Chemco 1986a and b Approximately 72,000,000 squares of asphalt fiberglass and organic strip shingles were produced in 1985 Asphalt Roofing Manufacturer's Association 1986 see Attachment Item 6 The tile roofing market is abour the same size as the cedar roofing market each of which are less than tenth the size of the asphalt roofing shingle market National Tile Roofing Manufacturers Association 1986 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 insulative because the air space between the tile and the underlayment creates a heat flow barrier National Tile Roofing Manufacturer's Association n.d. Tile is available in three main styles tile mission and flat shakes or slate There are more than 13 U.S. concrete tile manufacturers 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 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 is primarily used in the Vermont and New York area the two states where it is quarried The cost of asbestos shingles and substitute roofing and siding products are compared in Table 4 - 11 - *"furpra 9 60T Table Cost Shingles @uyzoypocy pup = Substiutes OUR " CETUS ese 20J TT fuyzoy e$ C Shingles Siding Aluminum Tepas Asphalt Asphalt &JF1 ATWO Rofing = ple Be pretIFEANS PUQQuTseyIOePt CastCostCast 6t oc ov V4 49 BepATIQ 19 969) BayI0T pocm POON 30 8 POY 49 OF *(7%02 $9 co azu os OzT BIOS life 20 COTIUNS S809 BES) 20 B/V SEY S JO pus euTMae Value 67 260d Atachment ) 113 Sut 206 907 eO7p1 PUP OG Sotid e Attachment SATIUTGS STQUL siding ( rofing siding hardboard and shingles and paen 203 qotin Wo d includes text sidng to PLO Zo wo d post modelare stMQ jaresbe79) ostegory {eznbs/G) se AFOD (exe) wea] L4ZT FePATIU TESTS (exnba/g) * USTACOI8UT quaeEiy Bupaoszedy 59eTDAT9 Iver 3Ww0T)d wo e377 enTe, SUTpTE (qeoy T0ep2rO posdueo(uD Ws [pL mag Boom, bea) a o4U5 Siding Wood siding is the most expensive asbestos siding substiture overall Asbestos shingles vinyl siding and aluminum siding are close in overall price The substitute market for asbestos 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 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 1985 production is asphalt shingles primarily fiberglass 86 percent with tile primarily concrete and cedar wood shingles each taking 7 percent see Attachment Item 6 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 1983 Red Cedar Shingle & Handsplit Shake Bureau 1986b Because the domestic asbestos shingle market is 77 percent siding and 23 percent roofing PEI 1986 the combined roofing and siding replacement market for asbestos shingles would probably breakdown as follows see Attachment Items 4-7 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 Wood Vinyl Asphalt Aluminum Tile Total 32 27 20 19 2 100 Table 5 presents the data for the asbestos regulatory cost model and summarizes the findings of this analysis E. Summary Asbestos siding shingles resemble shakes or machine shingles and asbestos roofing shingles generally resemble either shakes or slate Supradur 1985 They are primarily being used for replacement and maintenance in luxury homes schools churches and historical restoration projects Atlas 1986b Supradur 1986a Of three domestic producers in 1981 only one Supradur remains in 1986 Production has declined 34 percent from 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 shingles into the U.S. Atlas 1986a Atlas 1986c There are no substitutes for asbestos 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 - eoupzey QUOAIETY qaeuoniwy QHOULeTIY queljonazIy quaUse4 yquayUne Gog Table Date Inputs habestos Regulatory Ce ergs wa xzc 27 yOz xaT 17 | cezrbasg) Asbestos Production ao Coefficient Ratio 2U' eopag Gots $ eIts E218 Shingles osved * emed aXOK azuet azeai Asbestos Shingles OF OF as 07 0 0 Siding Sidng teands$) N @o4a4 00 ets On" oo 00 Oa 6% ets 8219 ELT Asphalt ShinglesShingles rAluomixnum ShinglesLOTFINMBo Rofing NotS AplicableyueTr2}J0cD Item qadang (aospnbs) 32Mporg Leu wr V/R /e vu va 50 zo'8 wu v/a VIN wa Wsn HUY HOTIeUNtaze evo A via VER td wiM w/H '92T FOZ =: oT-y SOT JusdeD.ozqyHupGs Suyzoy seTsuTS MUQy aTqeopidy *qUmDTAW PSUUTPTTE Supls Burzocy furpre BATON aon = PON TAU azoqdsy anuynty OT IL - v/a ofS, 32 percent vinyl siding 27 percent asphalt roofing 20 percent aluminum siding 19 percent and tile roofing 2 percent Vinyl and aluminum siding cost about the same as the asbestos product Asphalt roofing shingles are about half the cost and tile roofing and wood siding and roofing are 45-60 percent more expensive than asbestos shingles - 16- 16- ATTACHMENT 1 Calculation of percent of asbestos in domestic asbestos shingles One domestic producer has a production capacity of 134,800 squares or 12,000 tons for siding shingles and 40,000 squares or 9,500 tons for roofing shingles PEI 1986 This gives an average weight of 178 lbs./square lbs./square 12,000 tons x 2,000 lbs./ton)/(134,800 lbs./ton)/(134,800 squares for siding shingles and 475 lbs./square 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 lbs./square +40,000 +40,000 squares x 475 lbs./ square 174,800 squares The domestic producer's shingles have an average of 44 lbs of asbestos per square Therefore 44 lbs of asbestos lbs./square lbs./square x 100 -17.89 -17.89 percent or 18 percent asbestos by weight in asbestos domestic shingles From the that 77 percent is roofing production capacities in squares shown above it is of the asbestos shingle market is siding and estimated 23 percent 2 Calculation for imports of asbestos shingles 10,416.3785 tons of asbestos flat and corrugated sheet and asbestos 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 AIBP the only importer of these products from Canada estimates that 80 percent of their imports is asbestos shingles Atlas 1986a Ten percent equals 6,791 tons or 13,582,000 lbs of asbestos shingles are AIBP estimates that 60 siding and 40 percent are percent of the asbestos roofing shingles shingles imports Siding - 0.6 x 6,791 tons - 4,075 cons - 8,150,000 lbs Roofing - 0,4 x 6,791 tons - 2,716 tons - 5,432,960 lbs AIBP's siding and roofing shingles weigh 155 lbs./square and 450 lbs./square lbs./square respectively Siding Shingles - 8,150,000 455 lbs./square lbs./square 52,581 squares Roofing Shingles 5.432,960 450 lbs./square 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 products other than pipe tubes and fittings imported from countries other than Canada These imports from other countries may possibly include some flat asbestos shingles U.S. Dep Comm 1986a 1986b - 17- 17- 1985 production - 176,643 squares --33.8 --33.8 - -348 1981 production production * 100 - 266,670 266,67 2660 ,670 squares * 100 Domestic production has changed as follows 1985 production + 176,643 squares = 15 1981 production production * 100 - 153,603 153,603 squares * 100 4 siding market Members of the Red Cedar Shingle and Handsplit 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 or 508,321 red cedar shingles and shakes were produced in 1985 Red Cedar Shingle and Handsplit Shake Bureau 1986a and b This combined with 1,128,992 squares of hardboard siding 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 -31 red cedar siding 1,128,992 1,637,313 * 100 - 69 hardboard siding 5 Estimates Estimates siding Qualified 1986 of the projected market share for wood vinyl were based on estimates from the following references Remodeler Magazine 1986 Alcoa 1986a and b Contractor's Guide 6 replacement roofing market Asphalt fiberglass and organic standard strip shingles produced in 1985 - 71,766,672 Asphalt Roofing Manufacturer's Association 1986b 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 Tile About 6,000,000 squares of tile roofing were Roofing Manufacturer's Association 1986 produced in 1985 National This makes a total of 83,316,921 squares consisting of 86.1 percent asphalt shingles 6.7 percent wood and 7.2 percent tile - 18- 18- 7 Calculation of total replacement market shares The following calculations are based on the fact that 77 percent of the asbestos shingle market is siding and 23 percent is roofing PEI 1986 Wood roofing 6.7 0.23 + and siding 40.00 0.77 - 32.34 - 32 Vinyl 35.0 0.77 - 26.95 - 27 Asphalt Aluminum 86.1 25.0 0.23 0.77 - 19.80 - 20 - 19.25 - 19 Tile 7.2 0.23 - 1.66 - % 8 The asbestos shingle F.O.B. plant cost is based on Supradur's average price according to an ICF survey ICF 1986 The asbestos shingle installation cost is a weighted average for 325 lb./square lb./square and 500 lb./square lb./square roofing shingles and 167 lb./square siding shingles Means 1986a Roofing asbestos shingle cost 325 lb. square Average 56.50 Siding asbestos shingle cost square for 167 lb./square Means 1986 Because 77 percent of asbestos shingle market is siding and 23 percent roofing square * 0.23 + square * 0.77 - 48.42 - 48 for installation of asbestos shingles 9 Cost of vinyl siding The F.O.B. plant cost for vinyl siding is based on references Alcoa 1986a and b Certain 1986 the following The installation cost is for solid PVC panels -10 wide plain or insulated Means 1986 10 Cost of aluminum siding The F.O.B. plant cost for aluminum siding is based on the following references Alcoa 1986a and b Certain 1986 The installation cost for aluminum siding is the same as for PVC siding American Home Improvement 1986 Wages and Evans 1986 Johnny B. Quick 1986 - 19- 11 wood To determine the cost of wood siding and roofing costs are first derived separately for wood siding alone and wood roofing alone These costs are than multiplied by their share of the asbestos 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 American Wood Treating 1986 The F.0.B. plant price for hardboard siding is square Weyerhaeuser 1986 U.S. Plywood 1986 square wood Since the 69 percent of the wood siding replacement market for asbestos shingles is hardboard and 31 percent is cedar shakes and shingles see previous calculations the average cost for all wood siding be will square x 0.31 + square x 0.69 52.40 square for wood siding The installation costs averaged from Means 1986 for cedar wood siding shingles and shakes are 16 long with 7-1 - exposure 18 long with 7-1 - exposure 18 long with 8-1 exposure = Average of these three w 76.33 square square square or square The installation costs for hardboard siding was estimated to be double that for aluminum and PVC or square Even if this estimate is a bit high it will include the cost for painting that hardboard siding requires American Home Improvement 1986 Moon 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 square x 0.69 + square x 0.31 - 110.50 or square 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 - 25 years American Hardboard Association 1985 Weyerhaeuser 1986 Cedar life - 40 years ICF 1985 40 years x 0.31 + 25 years x 0.69 = 29.65 years - 30 years - 20 b Cost of woodroofing The average roofing shingles 1986a estimated F.O.B. plant cost for fire treated cedar is square American Wood Treating 1986 RSI 1986 Chenco The installation cost is an average of 16 and 18 roofing shingles 16- 16- square 18 - square Average - square c Cost of wood siding and roofing The wood roofing market represents 1.54 percent of the antire asbestos shingle replacement market The wood siding market represents 30.80 percent of the entire asbestos shingle replacement market for a total market share of 32.34 percent for wood see previous market share calculations Therefore roofing is 32.34 x 100 or 4.8 percent of the wood replacement market and siding is 30.80 x 100 or 95.2 percent of the wood replacement market Thus the weighted average F.0.B. plant cost for wood is square x 0.952 + 68 x 0.048 - square - square The weighted average cost for installation of wood roofing and siding is square x 0.952 + square + 0.048 - 108.60 - square The total cost for wood is 52.77 + 108.60 - 161.37 square or square x 0.952 + square x 0.048 - 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 shingles The F.O.B. plant cost for asphalt shingles is a asphalt fiberglass 83 percent and asphalt organic Asphalt Roofing Manufacturer's Association 1986 weighted average of 17 percent shingles Average price for fiberglass shingles - square Corning 1986 Average for organic shingles - square Corning 1986 square x 0.83 - square x 0.17 - 18.75 - square is the cost for asphalt shingles Installation cost is also a weighted average of standard strip organic 235-240 lb./square lb./square and fiberglass 210-235 lb./square shingles - 21- 21- Installation cost Installation cost for fiberglass for organic = square - square Means Means 1986 1986 30 square x 0.83 - square is the asphalt shingles + square x 0.17 - 29.50 average cost for installation of 13 r Coso t oo f fin tig le The tile market is about 10 percent clay tile and 90 percent concrete tile National Tile Roofing Manufacturer's Association 1986 The F.O.B. plant cost for clay tile is an average of four companies San Valle U.S. Tile MCA and Celadon's prices for Mission S and Flat tile tile was weighted 65 percent while the Mission and Flat were each weighted 17.5 percent Ludovici's average price was weighted 30 percent while the other three companies were each weighted 23.33 percent U.S. Tile 1986 MCA 1986 San Valle 1986 Ludovici 1986 This gave a clay tile price of square 0.30 0.65 * 250.00 +0.175 +0.175 * 310.00 + 0.175 * 310.00 + 0.233 0.65 * 70.40 + 0.175 * 97.20 + 0.175 * 114.75 + 0.233 0.65 * 55.00 + 0.175 * 106.00 +0.175 +0.175 * 106.00 + 0.233 0.65 * 58.50 +0.175 +0.175 * 90.40 + 0.175 * 100.57 The national average F.O.B. plant cost for concrete tile is square Monier Roofing Tile Company 1986a and b Using the above tile market shares an square x 0.90 + square x 0.10 roofing F.O.B. plant average weighted price was derived = 62.90 - square for tile Installation cost for clay was based on an average of S and Mission tile Mission Tile Average - square Means - square Means cost = 107 for clay 1986 1986 tile installation Installation for concrete tile is based on the tile and corrugated tile - square Means 1986 Total installation cost for tile concrete 90 percent percent is square x 0.90 + square x 0.10 square and clay 109.7 - 10 14 Present valus calculations for substitutes N @~ life of asbestos product No - life of substitute product TC = total cost of product - 22- 22- PV , TC x / x a a b 1.05 - 1.05 1,05 INN - 40 years - years - 7.0400 a Vinyl siding TC = square yearsyears N. = 50 years - - 11.4674 PV - 113 square x 11.4674 x 7.0400 -1 11.4674 - 1 - 106.21 - square b Aluminum siding TC = square NN - 50 years - 1.05 - 11.4674 PV - 128 square x 11.4674 x 7.0400 -1 11.6674 - 1 - 120.31 - square c Wood siding TC - square -- N. - 30 year year 1.05 - 4.3219 PV - 163 square x 4.3219 x 7.0400 -1 4.32191 4.32191 4.32191 - 181.95 - square d Wood roofing N - ND - 40 years Therefore PV = TC e Woodrooaf ndi ron ofig ng TC = square N N - 30 years years - 1.05 - 4.3219 PV - 162 square x 4.3219 x 7.0400 - 4.3219 - 1 - 180.83 = square f Asphalt roofing TC - N. - - square 20 years years - 2.6533 PV- PV- 49 square x 2.6533 x 7.0400 -1 2.6533 - 1 - 67.47 - square g Tile roofing TC - square year N. - 50 year NB - 11.4674 PV '173 square x 11.4674 x 7.0400 - 11.4674 - 1 - 162.61 - square Tons of asbestos used per unit of output - 3,893 176,643 -0.0220 -0.0220 square squares Domestic production + Imports Domestic production 176,643 squares + 64,654 176,641763 ,643 squares = 1.37 - 24- 24- REFERENCES AIA and AI 1986 June 29 Opening written comments of the Asbestos Information Association America and Asbestos Institute on EPA's proposed mining and import restrictions and proposed manufacturing importation and processing prohibitions Testimony of Alfred E. Netter President of Supradur Manufacturing Corporation Alcoa R. Egbert 1986a November 25 Alcoa Building Products Rockville Maryland Transcribed telephone conversation with Michael Geschwind ICF Incorporated Washington D.C. Alcoa J. Kelemen 1986b December 5 Alcoa Building Products Rockville Maryland Transcribed telephone conversation with Michael Geschwind ICF Incorporated Washington D.C. American Hardboard Association 1985 June Association Literature Questions Answers Hardboard Siding Palatine IL American Hardboard Association Exterior walls product shipments 1986a October Association Literature 1977-1985 Palatine IL American Hardboard Association 1986b November 25 Palatine IL Transcribed telephone conversation with Michael Geschwind ICF Incorporated Washington DC American Home Improvement Co. M. Duncan 1986 December 11 Brentwood Maryland Transcribed telephone conversation with Michael Geschwind ICF Incorporated Washington D.C. American Wood Treating J. Feaver 1986 November 21 Canada Transcribed telephone conversation with Hichael Incorporated Washington D.C. Nission B.C. Geschwind ICF . 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. Cadieux 1986a October 2 and December 17 Montreal Quebec Canada Transcribed telephone conversation with Michael Geschwind ICF Incorporated Washington D.C. Atles International Building Products T. Eames 1986b November 6 Newark NJ Transcribed telephone conversation with Michael Geschwind Incorporated Washington D.C. Port ICF Atlas International Building Products J. Payac 1986c November Montreal Quebec Canada Transcribed telephone conversation with Geschwind ICF Incorporated Washington D.C. 25 Michael - 25- Atlas International Building Products Quebec Canada Transcribed telephone ICF Incorporated Washington D.C. R. Cadieux conversation 1987 July 7 Montreal with Michael Geschwind Gertain 5. Howe 1986 December 4 Valley Forge PA Transcribed telephone conversation with Michael Geschwind ICF Incorporated Washington D.C. Chemca D. Fandrem 1986a telephone conversation with DC November 21 Ferndale WA Transcribed Nichael Geschwind ICF Incorporated Washington Chemco F. Trosino 1986b telephone conversation with DC November 21. Ferndale WA Transcribed Michael Geschwind ICF Incorporated Washington Commonwealth Aluminum B. Sullenberger 1986 December 4 Bethesda Naryland Transcribed telephone conversation with Michael Geschwind ICF Incorporated Washington DC Contractors Guide Magazine 1986 February Skokie Sheathing Survey Market Report # pp 1-10 IL 60077 Eternit Inc. B. Morrissey 1986 November 4 Reading PA Transcribed telephone conversation with Nichael Geschwind ICF Incorporated Washington DC 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 U.S. Environmental Protection Agency ICF Incorporated 1986 December Survey of Primary and Secondary Processors of Asbestos Shingles Washington DC Krusell N. Cogley analysis Revised Toxic Substances D. 1982. GCA Corp. Asbestos substitute performance final report Washington DC Office of Pesticides and U.S. Environmental Protection Agency Contract 68-02-3168 Johnny B. telephone DC Quick M. Ryan 1986 December 11 Washington DC conversation with Michael Geschwind ICF Incorporated Transcribed Washington Ludowici D. Transcribed telephone Washington DC Mohler 1986 November 25 New Lexington OH conversati wiotnh Michael Geschwind ICF Incorporated MCA Sales Representative 1986 December 3 Corona CA. Transcribed telephone conversation Incorporated Washington DC Maharuchi Ceramics Company with Michael Geschwind ICF Means 1986. Kingston MA Shingles Roofing and Siding 02364. Means Building Construction Cost Data 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 Geschwind ICF Incorporated Washington DC Monier Roof Transcribed Washington Tile Company T. Lua telephone conversation DC 1986b November 25 Corona CA. with Michael Geschwind ICF Incorporated Moon Sidings S. Cho telephone conversation DC 1986 December 11 Fairfax VA Transcribed with Michael Geschwind ICF Incorporated Washington National Home Improvement Co. Inc. B. Richard 1986 December Washington DC Transcribed telephone conversation with Michael ICF Incorporated Washington DC 11 Geschwind National Roofing Contractor's Association J. Wolenski 1986 November Chicago IL Transcribed telephone conversation with Michael Geschwind Incorporated Washington DC 13 ICF 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 1986-1987 Corning Fiberglas S. Persinger Transcribed telephone conversation with Washington DC 1986 November 21 Toledo OH Michael Geschwind ICF Incorporated PEI Rye 1986 September 26 OTS survey of Supradur Manufacturing Corporation NY Completed by Alfred E. Netter President of Supradur Qualified Remodeler Magazine B. Sour 1986 November 25 Division of Harcourt Brace Jovanich Chicago IL Transcribed telephone conversation with Nichael Geschwind ICF Incorporated Washington DC Raleigh Incorporated Transcribed telephone Washington DC B. Raleigh conversation 1986 November 17 Belvedere IL with Michael Geschwind ICF Incorporated Red Cedar Shingle & Handsplit Shake Bureau 1985 Bellevue literature Of shakes and shingles Timeless beauty shingles & handsplit shakes WA Association red cedar Red Cedar Shingle & Handsplit Shake Bureau P. Wood Bellevue WA Transcribed telephone conversation with Incorporated Washington DC 1986a November 21 Michael Geschwind ICF Red Cedar Shingle & Handsplit Shake Association literature Production handsplit shakes 1983-1985 Bureau 1986b and distribution Bellevue WA of red cedar shingles and RSI 1986a August Chicago IL Roofing Siding and Insulation Magazine -27- -27--27- The fiberglass shingles flap p 10 RSI 1986b October Chicago IL Magazine aid for wood shakes Roofing p 32 Siding and Insulation San Valle Tile Company J. Danner 1986 December 3 Corona CA. Transcribed telephone conversation with Michael Geschwind ICF Incorporated Washington DC Supradur Manufacturing Corporation 1985 September Wind Gap PA Product literature on shrunk mineral fiber siding and roofing specifications Supradur Manufacturing Corporation 1986a July 15 Testimony of Alfred Netter President at the Environmental Protection Agency legislative hearing on its asbestos ban and phase out proposal Supradur Manufacturing Corporation M. Mueller Gap PA Transcribed telephone conversation with Incorporated Washington DC 1986b November 4 Wind Michael Geschwind ICF Supradur Manufacturing Corporation A. to Michael Geschwind ICF Incorporated Netter 1986c November 4 Washington D.C. Letter TSCA Section a Submission 1982. Production Data for Primary Asbestos Processors 1981. Washington DC office of Toxic Substances U.S. Environmental Protection Agency EPA Document Control No. 20-8601012 U.S. Department of Commerce 1986a U.S. Consumption of Imports FY 246/1985 Annual Census U.S. Department of Commerce Department of Commerce Suitland MD Bureau of the U.S. Department of Commerce P. Confer 1986b October ) Suitland MD U.S. Department of Commerce Division of Minerals and Metals Bureau of the Census Transcribed telephone conversation with Michael Geschwind ICF Incorporated Washington DC U.S. Plywood G. Landin 1986 November 25 telephone conversation with Nichael Geschwind DC Stanford CT Transcribed ICF Incorporated Washington U.S. Tile telephone DC Company L. Linville 1986 December 3 Corona CA. Transcribed conversation with Michael Geschwind ICF Incorporated Washington Wages and Evans G. Evans 1986 December 11 Transcribed telephone conversation with Michael Geschwind ICF Incorporated Washington DC Weyerhaeuser Corporation G. Downey 1986 December 4 Transcribed telephone conversation with Michael Geschwind ICF Incorporated Washington DC - 28 - XVIII A. DRUM BRAKE LININGS 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 shoes lined on the outside with molded friction material called drum brake linings When the brakes are applied the curved shoes are pressed out against a metal drum that is connected to the 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 GM 1986a ICF 1985 In light and medium vehicles the lining segments are usually a third of an inch thick or less In heavy vehicles i.e. heavy trucks and road vehicles the segments are at least quarters of an inch thick and are called brake blocks instead of drum brake linings Allied Automotive 1986 Asbestos drum brake linings contain approximately 0.38 lbs of asbestos fiber per lining on average ICF 1986a Asbestos is used because of its thermal stability reinforcing properties flexibility resistance to wear and relatively low cost Krusell and Cogley 1982 The primary production process for drum brake linings is a mix process in which asbestos is combined with resins fillers 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 ICF 1985 While bonded brake linings 1 See Attachment Item 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 new linings are attached The rebuilt shoes with linings are then packaged and sold for the aftermarket ICF 1985 Krusell and Cogley 1982 B. Producers and Importers of Drum Brake Linings Table 1 lists the thirteen primary processors of drum brake linings in 1985. All produced an asbestos product Nine of the processors also produced substitutes ICF 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 Raymark's Stratford CT plants Friction Division Products 1986 Brake Systems 1986 Brassbestos of Paterson NJ went out of business in August 1985 ICF 1986a and H.K. Porter of Huntington IN discontinued production of drum brake linings in 1986 PEI 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 EIS division of Hannifan ICF 1986a At Echlin's Dallas TX plant which was formerly owned by Raymark linings are attached to brake shoes without any shujy] Company '2G^'I SxXvIq OSI WIE6T BZO6T Plant Location ( Asbestos Asbestos Non Asbestos SZ06T wegs Refrences aNIp es WIGL WORE Clevland Cleveland Val VOSL VIRL WISI VOSI YOat ICF Uo Autodative BATICWOeyveq^'t 'P9ET B9G6T Gren Island NY K "8947 "967 W906T egpeT Alied 1986 Automtive 1986 dat POT V ADF ADI *eqy ADI 21 IDI 201 BOI JOT 21 JOT oxpig Vas 1982 19826 SBuly 1 peonposd eyftg anag xx x Sieglr JO Vane 9 Winchester Winchester x 1982 x D4 1986 9O6T 1982 dong, 3949 1982 shometnxyg Frictonos xx x x x x x x x x x x x x 1982 POUMESD BE 1982 QI | Products Trento UoysexTay qousyde aoyfjuNg ICF 1986 Avewyig Manufcturing plant woqueIy featery Automtive "oudey (RSEGT Thickol Wetin VA Tapahanock Tapahanock WI 1982a Manufacturing VA 1906 AY CR va ICF Division 1982a a6I BO formerly NJ TR NJ 1982 ZIT) TI PAu FAQ pu GEST fi1GL Control - AsUtoy AT 1986 1982 AUsATBay JO JO POFAQ|NPU] 1982a Echlin Systems Echlin auvTd) TUPI 19864 , NpeUTANG formerly Raymark f4mpog UTNE eionprg TOWOQ Systems Za . YO GemZE OUT sp pedoje [UAE atopad natlic brake lings in 1956 asumed produced 1986 1986 drum Augst Augst asbetos brake busines ) that of August August is that produced linings out 7007] zeqy ICF is S7n that XE based based drum IVD UT MBST 2. Secondary Procesors bOnte VISE VISL JOE ZZOeU 926T '4961 9863 Qzast BoeQds GeOST 21 Plant Location Asbestos Product Product EIS OnerG Motor x WI via Viw JO trHveqsy-t0 | r ]GloesIrg BUQTEGSY xX x x v^'n x fy ml 1M Automive dunye2g woTtqVoe] 39TIOG WO Cast sue, Dalas Zz Wwe IwD 2904 pusg XE YyNOE Information Survey *fearng POL Survey *OTQRFSAG FR6T SE Anat JO ATG SQOMpoT_ Jou siz JO] PATONG MOFQeZJUT eQq0dtousqzed "40'(G-T7eD prUEyS aeuainy PUTY aT494 yy pi d 5@6T Location 9061 S861 9e6t References Refrences 9O6T RST a2 Whiter CA eO;seuy FOTeuy Autombile Autombile Importas of America Gardena CA Ja Jo Automobile Automobile Importers of America CA America wonubzeOy Gardena {Today azeqs0dey FreQzaduy Autombile Autombile Importes of America York New York aT Automobile Importers America Autombile of = Lyndhurst Lyndhurst NJ York ;qounqy Autombile Importers Americ Inc. JDO, of America AutombileAutombile Importes JacksonvileGarden Grove tu Hoy fa Pa Americe UDTYWSICT MIOL of AN Jacksonvile America YA wag of OA40Y-tT "JBI fede) OCF "OU7 T OU Sopzemy our sW0aQr0n%e]t "20d90a5)y TGIIOFNS "ouYON ATO7YH) BFOTOAMY G5OyrTOoQ w3o0y7ae09y AQETANH Geoytedy weoeTy BHoOsg aTAvoAy TOY AVqNg BO4R7 Fepusy T1He5TSs 906t 9G6U PRET 9G61 9G4T QG6T 9R6T sTU T] OFLIG Bayay Bapreay WOFAewY BOPIMCP Soyrmay BOFreay SOTEwy 20 Jo Fa FO 56 JO 1c UNI America America eGaT Orange 2061 eD6T 1984 O06T z2e470deT $seqzOday sTOQIMNT HrsA~Iodwa] szeqToday Gseizodyl e2qToduT 297 Troy 251 ZN 1964 LOE peNg_-soaqy of eTQouEAny eTQouUNMY OTQGUDANYy eyHQaM e7}qomy TQM GowD~NYy Amarion eT} eT '986X b@^'T Montvale Montvale O9G6T 89061 ICF 1984 *8906T EORE e8h^'I 9067 9061 Jo Karhouse Karahouse 4OT Los Angeles CA JOT ICF 1984 JOT JOT ZO DI A201 Ty NW erqodsy fH America yeaput7 poaneTSug varpte eytauw Lyndhurst Lyndhurst ICP uzoqeng OZ2TID eT Bonded PTOTF Yet Motor ce RY O 1986 Los Angeles ICF FE CA IM ww ta BO Ia yO IW VA fa Ca vo TSWITIN 1986 sajaRuy "poantog BJ *doay 198 wexsr ited 'aorseg oupsay eyuoay euys7r ON "OUI (seule JO 70 Importes woyezag) UPTEAO) Autombile seDTAeg(eoFLemy Sueda3 SOxerg Caze PET (sm evaizosyre Caze Englewod Dearborn Leonin Dearborn HJ Vayrecy eopauey Autombile Automobile FO Norwod 7 Autombile Autombile 30 Automobile of of America America Importers of America 196 faudmay Importes of esag oenow oul OS Sze drop 40CH eTOIOH UPUOH F3I9 ) IT9705-Fe1Fots-x907 , BTiwoOg-que wiveasylg Autombile TUNEITH GPoTIeny Ino uoay Irvine Automobils Automobils Importers of America 1936 If sity ata xacter e707 epEyW *(BORET JOT) SHUFT ahuyt] Gyig Corp. 996% 906T 9UET 9061 906, 9U6T PACT SHE, SUT OFEIG P27 COTIMY Tey TOPseuy >FAeUy TOEMY FoTeKH CoFaey COPINY ESFreUY JO JO 7O 30 Jo Jo 70 Jo JO peaEy-sojq EZMTOdW] aTeZICEOT sTe{I0GNT vTstqeaymyonday aTeyZodT ESTxPQoimaOUcNdymr F2eQTOdaE Sxe7TOdeT SOQPEM-UOK T2U8TIO FQouND{Hy Tqaungy FqoUANY HGomO{Ny TQKUN TGA TYRBoLOY America POIT Onjig Inc. PR6T $060 SabT e3eq Volkswagen Inc. 2DE Troy Bact 447 IOUS] ATWO Automotive Automtive TENh ST &) w) #1 Warehouse Distributors Distributors Distributors Los Angeles CA weet 1984 RET we6T BT eT eT WITA s0uday IOI IDI 297 LOT Recine WI LOT 01 1984 IOI 131 Jo NY DY OG TTT vapyods, VO Ta VO Molybdenum WA Golden TH Ca WD Ce fei TH Vo AH" CSTIUCA OTT Ef Jacksonvile Original Quality Q S YO "eAGTH *2e9t Jacksonvile YO FL Orignal 'sejTofuy 1986 WSOX TIe Inc. "BOaFI70E 'oTenIwN Quality America 20790 PT=Fs4IOR ueqnrubg MI Autombile Importes 1986 "OULAL euspreg BIGeL OSU Dearborn ceprtg erg 4025 so] of may xved ETON Tebow IAAT sac CA Autombile 643 Senayreotxeuy Autombile weazneg OvTzemy Corp. FTOEY Irvine pat 1986 OU "OUL UT Services Weg) Southfield of 1986 10904 (ROT "Magy buy QUAI OATaMY Importes soTiemy SeTES 209q4 FO Gardena NY Jo Automobile of "OS Autombile EL of 1986 Bnel IOWY sA0tn dz0g OL 1090 pelDIT Teng f0704 BO [FI Autombile Importers YUION) 2070q) i so FURY. Wasa PYVIQDe uedwesToa, Perak of 1986 uNG)A9Ly Amezkoa Inc. s'N pOoTO ~oq , oO, UIO4TM Automobile Autombile Importes 1p America Fyre TH wet nieqEs FePUTLAG additional processing Brake Systems 1986 Similarly Wagner installs brake linings with no additional processing Wagner 1986a Table 3 lists the twenty importers of asbestos drum brake linings C. Trends Table 4 gives the production of asbestos drum brake linings and the corresponding consumption of asbestos fiber From 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 performance cars that currently account for roughly 5 percent of OEM medium vehicles are now aquipped with four disc brakes e.g. Cadillac Seville and El Dorado Corvette Pontiac STE and Fiero and performance Camaros and Firebirds CM 1986a 2 In addition it should be noted that some luxury imports e.g. Mercedes BMW and Saab use disc brakes on all four wheels GM 1986a Scania of America 1986 New Saab cars in fact use asbestos metallic disc brake pads on all four wheels Scania of America 1986 Information was not available on whether all four disc brakes in Mercedes and BMW cars were also asbestos Nonetheless the great majority of imported vehicles are still equipped with asbestos rear drum brakes Ford 1986a Abex 1986. MIT 1986 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 1986c Chrysler 1986 Allied Automotive 1986. Wagner 1986b Ford 1986a However producers and users agreed that adequate substitutes have disc 2 Disc brakes brakes are a performance are discussed in further detail brake Applications of later in this section drum and 5- ICF 1986a Wagner installs asbestos and asbestos brake pads with no additional processing Wagner 1986a Table 3 lists the 1981 and 1985 importers of asbestos disc brake pads C. Trends Table 4 gives the production of asbestos 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 with four metallic disc brakes Allied Automotive 1986 Saab is one such example Scania of America 1986 However the great majority of imported cars still have asbestos rear drum brakes Ford 19868 Abex 1986 NIT 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 medium vehicles ICF 1986a GM 1986a Ford 1986b Chrysler 1986 Chilton's Motor Age 1986 Allied Automotive 1986 DuPont 1986 The share however is significantly higher for the aftermarket though probably not a majority GM 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 medium vehicles are projected to be wheel drive requiring 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 pads will be almost 4 See Attachment Item 2 5 See Attachment Item 2 Table 4. Production and Fiber Consumption for Asbestos Drum Brake Linings 1981 1985 References Production pieces Asbestos Fiber Consumption tons 160,470,368 23,878,0 129,042.578" 24,691.8b ICF 1986 TSCA 1982a ICF 1986a TSCA 1982a a Abex Allied Automotive both plants Brake Systems and Brassbestos did not provide production information Brassbestos went out of business in August 1985 it is assumed that they produced asbestosbased drum brake linings in 1985 ICF 1986a Production was estimated for these four companies using a method described in the Appendix A of this RIA b Abex Allied Automotive both plants Brake Systems and Brassbestos did not provide fiber consumption information Brassbestos went out of business in August 1985 however it is assumed that they consumed asbestos fiber for the production of asbestos drum brake linings in 1985 ICF 1986a Fiber consumption for these four companies was estimated using a method described in Appendix A of this RIA been developed for many if not most OEM drum brake lining applications Abex 1986 GM 1986c Ford 1986a A report by the American Society of Mechanical Engineers concluded that automobile and most trucks could have completely nonasbestos friction systems by 1992 ASME 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 1986a Estimates for the time 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. metallic pads 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 3 Representatives from Ford and GM agreed there were adequate substitutes for many medium vehicle applications cars and light trucks but there were problems with finding good substitutes for large cars and medium trucks e.g. 2 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 4 As indicated earlier Allied Automotive estimates that 18 percent of its 1986 drum brake lining production will be asbestos Allied Automotive 1986 Abex did not provide an estimate of the current share of its OEM drum brake linings that are asbestos but did indicate that a significant percentage was asbestos Abex 1986 8 1986a CM 1986c Allied Automotive 1986 Wagner 1986b This risk translates into stringent and lengthy testing processes required by both government and 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 Abex 1986 Ford 1986a GM 1986c According to Ford a potential alternative for asbestos in drum brake linings would be to make medium vehicles with four asbestos metallic disc brakes Ford 1986a However brake lining producers 5 Producers 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 6 Compliance with federal performance and safety regulations -- Federal Motor Vehicle Safety Standards FMVSS 105 121 and the proposed 135 .. can be certified at the testing facilities of OEM brake lining producers At these facilities producers always employ at a minimum dynamometer testing recognized in the industry 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 GM 1986c 7 metallic disc brakes are already used on the front wheels of 85 percent of all new medium vehicles Allied Automotive 1986 and certain domestic luxury and performance cars are now equipped with four asbestos disc brakes GN 1986a Disc brakes particularly 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 1986a Abex 1986 -9 and vehicle manufacturers agreed that there currently is not a significant trend towards four disc brakes in medium vehicles nor is there likely to be in the near future because of important performance and economic factors Abex 1986 GM 1986a GM 1986c GMI 1986 Ford 1986a First drum brakes make superior parking brakes GM 1986a Ford 1986s Abex 1986 .8 Disc brakes furthermore reduce fuel economy because of parasitic drag and are much higher in cost than drum brakes because of the mechanical system required for disc brakes Ford 1986a GM 1986a Because drum brakes are significantly cheaper and are a lower performance brake they are used for the rear wheels with disc brakes in the front in the vast majority of the medium vehicle OEM 95 percent GM 1986a . In most medium vehicles particularly those with wheel drive there is significantly less brake load or brake force in the rear than in the front.10 Therefore the cheaper performance drum brakes are used in the rear since the rear brakes do not have to do much work GN 1986a A final key factor that would stall a significant switch to brake cars is the enormous equipment redesign that would be required GMI 1986 Therefore for the mentioned reasons drum brake linings at least in the near future will continue to be produced for the medium vehicle OEM at roughly a 1 ratio with disc brakes 8 The parking brake either service brakes is a separate brake front parking brake CM utilizes the existing rear drum brakes rear drum brake or is a separate front 1986a disa 9 The remaining 5 percent equipped with four disc brakes are GM the luxury 1986a and high performance cars 10 In wheel drive cars the and in wheel drive cars about 70 Ford 1986a Design News 1984 brake load percent of is 85 percent in the front the load is in the front life 11 as In most cars in fact rear rear disc brakes because of drum brakes would have the same service the light brake load GM 1986a - 10 . D. Substitutes As indicated earlier primary processors and vehicle manufacturers agree that acceptable drum brake lining formulations have been developed for meny if not most drum brake lining applications Although these substitutes do not have the same performance characteristics as asbestos linings no substitute currently provides all the advantages that asbestos linings do they are acceptable from the standpoint of vehicle drivers drivers will accept changes in performance as long as there are no surprises while driving that reduce safety Abex 1986 Ford 1986a GM 1986c MIT 1986 asbestos 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 OEM in the event of a ban GM 1986c Abex 1986 Ford 1986a Carlisle 1986 NAO drum brake lining formulations in general include the following fiberglass and Kevlar mineral fibers 12 occasionally some steel wool and fillers and resins Ford 1986a Fiberglass and Kevlar 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 in drum brake lining formulations is usually about 3 percent by weight Ford 1986a Thus labelling substitute drum brake linings as Kevlar or fiberglass producers tend to do this for marketing reasons is misleading Abex 1986 Ford 1986a GM 1986c Of the thirteen primary processors of drum brake linings in 1985 at least eight currently produce NAO linings These firms are Allied Automotive General Motors Inland Division Abex Nuturn Virginia Friction Products 12 Mineral fibers commonly used by producers include wollastonite phosphate fiber aluminum silicate fiber Franklin fiber mineral wool and PMF processed mineral fiber ICF 1986a - 11 - Chrysler Carlisle and Brake Systems Inc. ICF 1986a Although the producers did not reveal the exact formulations of their NAO linings they provided partial lists of the ingredients in their mixtures ICF 1986a Five of the primary processors also produce a metallic drum brake lining These firms are Abex Allied Automotive Carlisle General Motors Inland Division and H.K. Porter Abex 1986 Allied Automotive 1986 ICF 1986a Lining producers and vehicle manufacturers generally agree however that there are serious production and performance problems with metallic drum brake linings Abex 1986 GM 1986c Ford 1986a Carlisle 1986 H.K. Porter in fact discontinued its 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 metallics are very difficult to process into the required thin shaped lining segments and are thus very prone to crack Abex 1986 Ford 1986a These representatives also stated there were 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 metallics would not take much of a share of the asbestos OEM in the event of a ban Abex 1986 GM 1986c Ford 1986a Carlisle 1986 Primary processors and vehicle manufacturers agree that there is adequate dynamometer and testing capacity among the OEM producers to develop substitutes for the remaining OEM drum brake lining applications i.e. medium trucks with brake systems The difficulty in 13 metallics 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 - 12-12- developing acceptable substitute linings for medium trucks results from the more severe braking requirements for the rear drum brakes of these vehicles than for the majority of medium vehicles and the fact that the drum brake linings for medium trucks must be riveted not bonded to the brake shoe Thus an acceptable substitute lining must have structural strength around the rivet area Batelle 1987 Nevertheless given enough time substitute linings for medium trucks will be developed particularly since brake systems can 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 Abex 1986 GM 1986c MIT 1986 Replacement of asbestos drum brake linings in the aftermarket however may be much more difficult Most asbestos 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 were designed for the OEM when used to replace worn asbestos linings do not perform as well as asbestos and could jeopardize brake safety Allied Automotive 1986 GM 1986b GM 1956c Wagner 1986b Ford 1986a Ford 1986b Abex however indicated that it is selling its OEM asbestos organic drum brake linings for the aftermarket and reports that they are performing well 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 a Considerable technical difficulties with developing adequate substitutes for a system designed specifically for asbestos - 13 safety e No federal and performance standards for brakes for the aftermarket and High cost of producing and testing substitute formulations Ford 1986a Wagner 1986b Abex 1986 Aftermarket producers except for those who 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 LBJ Space Center 1986 However even with a ban on asbestos linings for the aftermarket the cost of stitutes designed for the aftermarket are likely to be prohibitive given the technical difficulties LBJ Space Center 1986 Table 5 provides the data for the regulatory cost model The substitute linings in the table are an NAO lining produced by Abex and a metallic lining made by General Motors Inland Division It is assumed that metallic drum brake linings will account for a negligible share of the Barket Note that the equivalent price of the NAO lining given in Table 5 is close to the asbestos lining price because of the longer service life E. Summary 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 ICF 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 and 1985 14 By contrast OEM brakes must meet federal regulatory standards .. FMVSS 105 and 121 and in the future the proposed 135 - 14 - $067 ed961 seat HAO FTO ase ZAI PICs veqy FO 76 9861 FVel J0y V9O6T OQP6TTETT 9S, 09861 OFQST BYY SOL Eogy ZED DT p20d MD zwTable 5. 366 XI Regulatory (seoBTd | = woe pd aooTd arerd 4uayengby pivean asyag Coeficent ACosebffeisctieonst Consumption VsCeOfsul 2699 HS) 129,042,576 piece 0.019 piece 1.15 HeNVIQ HSoY piece 5 N O20 14 aorgqey ertag 18/62 N 2oz 709 0F 06 aWUuyU] ueOTvy seqe3g Aplicable DOT tydumsuoIsNpOtY st't v/u vse uo into lings Items is Apendix drum brakes 34,713,675 Apendix 6T06 eTEPL genera BLS'*Zy0aT andang vial w/a OIMXTH ST TIS qonpozg eW- HOICqeY On FuNg Begtvareq pus + PCLSF'ST)L SOxVIG aftermarket OWT W Ut de op Xipaedy soTUT UT $-G e4vaq wncuUc Sumay WE SezTe 2e0Tqmuotidy QuAEeTay 3an0digne quewcrde: ens oUL pus iw/n C q production of the asbestos linings declined 19.6 percent ICF 1986a However asbestos linings still accounted for 90-95 percent of the OEM and virtually 100 percent of the aftermarket GM 1986a GM 1986c Chrysler 1986 Allied Automotive 1986 Wagner 1986b Ford 1986a Acceptable substitutes have been developed for many if not most drum brake lining applications For the OEM NAOs are expected to take 99 percent and metallics 1 percent of the asbestos drum brake lining market if asbestos were not available NAOS cost the same as asbestos linings while metallics cost 73 percent more than the asbestos product Developing adequate substitutes for the aftermarket will be difficult due to technical difficulties and economic factors + 16- The asbestos fiber content per lining was calculated by dividing the 1985 asbestos fiber consumption for drum brake linings by the 1985 production of drum brake linings for producers for which both fiber consumption and production data were available 24,691.8 tons 49,383,600 lbs divided by 129,042,578 pieces or 0.38 lbs per piece A large producer of asbestos 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 1985 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 GM 1986a A second automobile manufacturer stated that currently 98.5 percent of its OEM linings were asbestos 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 The product asbestos coefficient is the same value calculated in Item 1 above converted into tons per piace The consumption production ratio was calculated using 19,580,493 the value for the 1985 U.S. imports Total 1985 production is 129,042,078 pieces This value however only includes imports firms who provided information see Table 4 pieces as for the 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 ICF 1985 The two substitute lining prices were calculated by increasing the weighted average asbestos product price by what Abex and GM respectively reported as the percentage price increase for their substitute product over their asbestos product One company indicated that its NAO lining cost 25 percent more than its asbestos lining another company stated its metallic lining was approximately 73 percent higher than its asbestos lining While the first company did not indicate the service life of its NAO lining compared to its asbestos product another manufacturer of NAO drum brake linings reported that NAO linings had the same or up to 50 percent longer service life Thus a 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 metallic linings had longer or shorter service life than asbestos linings therefore the same service life as the asbestos product is used - 17- REFERENCES Abex Corp. R. Nelson 1986 December 3 American Society of Mechanical Engineers Conference in Washington D.C. Transcribed conversation with Richard Hollander ICF Incorporated Washington D.C. Allied Automotive E. telephone conversation D.C. Rogers 1986 October 17 with Richard Hollander ICF Troy NY Transcribed Incorporated Washington 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 1986. America on Proposed Asbestos Ban Rule Comments of Automobile Importers of EPA Document Control No. 62036 Battelle Columbus Laboratories S. Barber 1987 June 26 Columbus OH Transcribed telephone conversation with Michael Geschwind ICF Incorporated Washington D.C. Brake Systems Inc. S. telephone conversation D.C. Mayo 1966 November 18 with Richard Hollander ICF Stratford CT Transcribed Incorporated Washington Carlisle R. Tami 1986 October 17 Ridgway PA Transcribed telephone conversation with 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 1986a 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. Rule EPA Document Control No. 62036 on Proposed Asbestos Ban Friction Division Products R. Carney Transcribed telephone conversation with Washington D.C. 1986 December Richard Hollander ICF Trenton NJ Incorporated General Motors Corp. Transcribed telephone Washington D.G. F. Brookes conversation 1986a November 19 Dayton OH with Richard Hollander ICF Incorporated General Motors Corp. 1986b Comments of General Motors Asbestos Ban Rule EPA Document Control No. 62036 Corp. on Proposed -18- -18--18- General Motors Corp. P. Vernia 1986c December 3 American Society of Mechanical Engineers Conference in Washington D.C. Transcribed conversation with Richard Hollander ICF Incorporated Washington D.C. General Motors Institute S. Gratch 1986 December 3 American Society of Mechanical Engineers Conference in Washington D.C. Transcribed conversation with Richard Hollander ICF Incorporated Washington D.G. ICF Incorporated 1984. Imports of Asbestos Nixtures and Products Washington D.C Office of Pesticides and Toxic Substances U.S. Environmental Protection Agency EPA CBI Document Control No. 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 U.S. Environmental Protection Agency ICF Incorporated 1986a December Survey of Primary Processors of Disc Brake Pads Light and Medium Vehicles Washington D.C. ICF Incorporated 1986b December Survey of Secondary Processors of Disc Brake Pads Light and Medium Vehicles Washington D.C. Krusell N. Cogley 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 Center J. McCullough 1986 December 3 American Society of Mechanical Engineers Conference in Washington D.C. Transcribed conversation with Richard Hollander ICF Incorporated Washington D.C. Nassachusetts Institute of Technology E. Rabinowicz 1986 December ) American Society of Mechanical Engineers Conference in Washington D.C. Transcribed D.C. conversation with , Richard Hollander ICP Incorporated Washington Original Quality Inc. 1986. Comments of Original Quality Asbestos Ban Rule EPA Document Control No. 62036 Inc. on Proposed PEI Associates 1986. OTS Survey of Washington D.C Office of Pesticides Environmental Protection Agency Asbestos Product Manufacturers and Toxic Substances U.S. Scania Transcribed D.C. of America conversation D. Rainey 1986 November 21 Orange CT with Richard Hollander ICF Incorporated Washington TSCA Section a Submission 1982a Processors 1981. Washington D.C Environmental Protection Agency EPA Production Data for Primary Asbestos Office of Toxic Substances U.S. Document Control No. 20-8601012 4 1 19 - TSCA Section a Submission 1982b Processors 1981. Washington D.C Environmental Protection Agency EPA Production Data for Secondary Asbestos Office of Toxic Substances U.S. Document Control No. 20-8670644 Wagner Corp. F. Hayes 1986a December 5 Parsippany N.J. Transcribed telephone conversation with Richard Hollander ICF Incorporated Washington D.C. Wagner Corp. EPA Document 1986b Comments of Wagner Corp. Control No. 62036 on Proposed Asbestos Ban Rule - 20 -