Document mqKqb58RK2x2kO8joawQd3NMb

Lama L Langleia Mr. J. W. Ihirstins John, thought this might be of interest in jrour activity-. 105567 005994 PRODUCED BY FORD wagner CONSIDERATION ON,REGULATING THE COMPOSITION OF BRAKE LINING___ John W, Kourik Chief Engineer, Brake Produces Wagner Electric Corporation 1980 SAE Congress Detroit, Michigan February 25, 1980 Wagner Electric has an interest in the application aspects of any regu lations affecting the composition of brake lining. We do not manufacture bra-, lining. We are a major producer of passenger car and truck brakes. We are a major manufacturer of replacement shoes and pad sets for passenger cars and tracks. 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 emaloyed by various Federal Agencies is an effective means to develop back ' ground for potential rulemaking activity. The Advance Notice of Proposed Rule making (ANPKM) provides a public announcement of a very general nature. It aiiovs all interested parties to contribute facts and opinions of merit in heiping that particular agency develop the course for its future rulemaking action. We have seen instances where the National Highway Traffic Safety Administration (NKTSA) initiated an Advance Notice of Proposed Rulemaking, arm? based an ehe public disclosures and their own research either terminated rulemaking action or progressed deeper into the sequence of rulemaking. We have been reviewing the input (docket submissions) to the Environ-- Tn.arira1 Protection Agency (EPA) and Consumer Product Safety Commission (CPSC) * Encircled numbers refer to the illustrations in Appendix A. 005995 PRODUCED BY FORD -2files on the 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 S3 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 Dr'cLet number OPTS 61005 "Record of Rulemaking" has a Table of Contents snovj-g thirteen categories of activity. Their (EPA) resourcefulness in search ing for facts is to be commended. Their success will be highly dependent Dn the -public- submissions. W'e doubt that this is an adequate public response. The text of the ANPRM is somewhat lengthy but it is factual and direct to the objective. Many mamufacurers 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 aar.estos into some useable end product. Wagner Electric did not take a limited viewpoint. Our presentation will li;_ acme of the highlights from our December 12, 1979 submissions to these dr :a to explain the manner by which we provided the EPA and the CPSC with L-; nation we consider vital to their study. This is an opportunity to help oarr organizations understand the complex technical environment their study enr*aches. This is the time to provide facts and share the comercial exper11-that we have gained in a highly specialized segment of a large industry. 005996 PS.ODU.CED BY FORD -3- The government groups need to decide whether to terminate r.ls-akirg action on certain products or to continue more intensive and specific rclena^mg action. The 3 portions of our docket entry that will be covered this morning are: (1) the state-of-the-art for non-asbestos lining, (!) Regulatory interface, (Zi alternatives to a full ban on asbestos. Ve -ill not be talking about conversion of asbestos into brake lining. We will concentrate on the use of the brake lining and the necessity for the E7A & Tf;" to evaluate many commercial aspects of the problems related to the docket activity. STATE-OF-THE-ART OF NON-ASBESTOS LINING ~ c tost recent press (industry) releases and magazine articles imply that there i-- 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 linint= We base this belief on the small number of test materials that we have had fret lining manufacturers. We'll help you look at the overall scope of the mark.-*L and the need to evaluate the success or failure of the tests of these material a before concurring in the validity of the development claims. We also must c-t-rmine their true availability based on committed tooling by the manu facturer and use these findings to see if we can procure the material needed to s=rvi`- a very extensive market. , . Look at the number of applications that need to be covered by fee - -aterials in the braking area only. (2) Friction reouirements are ccf..* - foT a variety of vehicles because of the different types of appli cet-" . the speeds at which they operate, the frequency of brake applications, c.*,; r r service and the durability needed to have long intervals between 805997 PRODUCED BY FORD -4reLining and servicing. Wagner 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 we purchase from 10 different sources. ORIG. EQUIPMENT + AFTERMARKET APPLICATIONS PASSENGER CAR TRDCX SEGMENTS TRUCK BLOCKS NUMBER OF LINING COMPOUNDS SOURCES 20 5 18 5 16 6 CUMULATIVE 50 10 Look at the characteristics that are needed for OEM and replace ment materials. Most of these are self-explanatory. DESIRABLE CHARACTERISTICS OF A SUITABLE LINING MATERIAL ST7L TMHALLY SOUND NO MORNING SICKNESS -Ilrfi/ROTOR LIFE ACCEPTABLE WATER RECOVERY L?\ WEARING cc':-':7Est friction - hot & cold AC" ----3LE NOISE LEVEL PHYSICAL FLEXIBILITY FOR ATTACHMENT TO SHOES USING STANDARDIZING SEGMENTS LIGHT WEIGHT * Erratic braking or "grabby" lock up on first stops. 005998 PRODUCED BY FORD -5- Nov consider the variety of brake designs used on ole and r.ew venicles. PASSENGER CAS & TRUCK HYDRAULIC BRAKE TYPES TRUCK, TRACTOR 4 TRAILER AIR BRAKE TYPES INDUSTRIAL BRAKES (EXTERNAL) NON-SERVO CAH AIR SERVO DISC DISC WEDGE hydraulic SPRING/SOLENOID Inere is considerable technical literature available on the subject of brc. r> goeraetry and effect of friction materials on design, performance and sensitivity. We have submitted several of these and their bibliographies to i -i EPA/CPSC dockets for reference purposes, *. nsidermg all of the above brake types it appears likely that only the i j-r car and light truck disc brakes will have a suitable non-asbestos c-ion material available in the reasonably near future. I .ere will be a long transition as development efforts continue to be cited towards the availability of (1) a substitute material that will allow vehicles to remain at or exceed today's safety level, ;1) 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. Lit this time we have an insufficient number of samples to predict a '-etc target date for conversion to non-asbestos strip, segment or block - ai. We expect this to be at least several years away. We look with fee at the press releases extolling the imminent availability of non lining materials without citing the limited number of applications 005999 PQ 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 (SAE J661) has been facilitated by the work of the AAMVA. A rough count of the edge codes on fi.'c -nth 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 ate production. Even in this day of standardization the number of edge codes for vehicle spoliations 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 onsc/prices. The need to meet very stringent and specific requirements for new vemcle performance requires special materials as the Federal vehicle safety scindards are revised and upgraded. The Federal Motor Vehicle Safety Regulations issued by the Bureau of Motor _-rier Safety provide certain performance parameters for vehicles that are in irvice. While these requirements are not overly stringent, they do require c; use of reasonably satisfactory lining materials. The regulations have been =;:cremely beneficial over a period of many years. As simple as they are, they 006000 i PRODUCED BY FORD -7hsva JceE 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) FKVSS 105 far hydraulic-braked vehicles, 2) FMVSS 121 for vehicles with air brakes. The individual performance requirements for passenger cars and those proposed for '`"hides under 10,000-pounds GVWR have generated a whole host of lining matentJ-S with special characteristics to provide the vehicle manufacturers with =o-.a measure of reserve when testing to the strict compliance parameters of ore f.KTSA. 7 r following provides a very simple tabulation of these various require ment; ~'Lv by their title ox description. FMVSS 105 BRAKE TEST REQUIREMENTS VEHICLES UNDER 10,000 LBS. GW AND 5CB00L BUSES FIRST (PREBURNISH) EFFECTIVENESS SECOND EFFECTIVENESS PARKING BRAKE s. LIGHTLY LOADED EFFECTIVENESS PARTIAL FAILURE INOPERATIVE BRAKE POWER AND POWER ASSIST UNITS FIRST FADE & RECOVERY SECOND FADE S RECOVERY FOURTH EFFECTIVENESS WATER RECOVERY 00600? PQ PRODUCED BYFORD -s- PRQP05SD FMV5S 105 BRAKE REQUIREMENTS VEHICLES 0701 10,000 LB. GVW (Docket No. 70-27, Notice 19} PARTIAL FAILURE STOPPING DISTANCE INOPERATIVE BRAKE POWER ************************* FHVSS 121 TRUCK-TRACTOR AND TRAILER TEST REQUIREMENTS STOPS AT GVWR PARKING BRAKE TEST AT GVWR STOPS AT UNLOADED WEIGHT PARKING BRAKE TEST AT UNLOADED WEIGHT * ************"************ - FMVSS 121 DYNAMOMETER TEST REQUIREMENTS BRAKE RETARDATION BRAKE POWER HOT STOP RECOVERS 006082 PRODUCED BY FORD The Office of Standards Enforcement (QSE) of the KHTSA has Initiated a ooaoiiance evaluation program chat 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 m ~ev vehicle safety standards are unaware that the OCA/OSE interpretation of "-..-vnma" would invalidate the use of many AQL (acceptable quality level) i'T,.,,ng plans, e.g., MIL-STD 105. Most sampling plans had been used through'.'i. ;-s automotive industry to establish nominal performance levels with per'.fu.'U deviations. These sampling plan results were understood, accepted i'. t^reed upon when negotiated by supplier and customer in commercial contracts. ' ~SA determined, In the case of safety-related products, to not accept "c , _-_g techniques as proof of compliance to a ml Mmum standard unless there rat :_(ficient overdesign incorporated in the acceptance values to assure 1001 tcnrliancB. The equipment manufacturers were not at first aware of the compliance consesrtes when the industry "nominal" design value became the NHXSA "minimum" o - essentially making 503 of the old product noncomp lying. The Director -a Office of Standards Enforcement, Francis Armstrong, presented a paper --:.i-_ed "The Issues of Complying with Federal Motor Vehicle Safety Standards ^ '*cher Requirements" in January 1969. See Appendix 2 for excerpt. This .-r has a very clear illustration [its Fig. 7] of the significance of the the suppliers had to make in their designs to assure compliance if . . ^1 design sampling plans were employed for manufacturing control. The - - r. paper should be a part of the technical reference material in any design . recent for vehicle equipment suppliers or'vehicle manufacturers of products 006003 PRODUCED BY FORD -10regulatEd 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 an * 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 tune 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 Che heavy highway vehicle industry. ALTERNATIVES TO A FULL BAS OS 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 aM Health Administration (GSHA) 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_vith_controls aimed at manufacturing processes has a_so provided the opportunity for preventative action in other areas espo=cd to asbestos fibers. We maintain an even cleaner dynamometer test area and girage area in our development facilities because we use vacuum cleaners to ctLl-ict the residue of worn linings from both dynamometer and vehicle brake tsf: Inis practice could be extended to all commercial repair facilities. '.ir.jer is one of several companies who have already incorporated a major benefit so a repair shop environment by the preparation technique used for our -.ftermarket lined shoe sets. Our passenger car sets are preground with an am or contour of the lining controlled from the anchor pin location. This eliminates the need for a garage or repair facility (where there is cypicaliv less control of dust) to grind shoe and lining assemblies before thev ire installed on the vehicle. ?r=-arced lining assures better customer satisfaction, from a brake performance standpoint, because it fits into both new drums and oversize drums J witL'iur alteration. We introduce the lined shoes into the distribution net work r-ady to install. This action has caused a significant reduction in con cern - i-on of asbestos fibers in more public work areas. More 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 recurred ana (2) the"' have a product with asbestos conteht. 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 them 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 = practices tD use precbntoured lined shoes, but we have contacted manu*-'t_rers of shop equipment for an indication of shop trends. We learned that t' : -umber of shoe grinding attachments sold at this time is significantly less Z ' me number af lathes purchased tD face rotors or turn drums. Until recent they sold 10 lathes to 6 grinders. Now its about 10 lathes for each ir'-dir. Ve conclude, therefore, that the programs of major manufacturers of .Aftsrmarket shoe sets which provide pre-arced or preground lining has already significantly reduced the risk of contamination in these shops. If they use fuse collection systems for what little lining dressing is necessary, and va..a,n systems to clean up the worn lining debris they are well on the way to atmospheres which are essentially fiber-free. CONCLUSION The actions taken by the EPA, CPSC and OSHA have already brought attention . t*i fact that care should be exercised with materials that are suspected -- . -ing some hazard to health. It has only been a relatively short time zz : health risks have been publicized for asbestos. Asbestos has been a riruent of brake lining for over 1/2 a century. A lot of experimentation t_..: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 well 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 nsis. The lining industry, as a whole, has developed well in excess of the 5? .T'jtounds we purchase and has many more sources than the 10 we currently satisfying the commercial needs of the original'equipment and After-^r-.r lining business. *'e emphasize that the publicity associated with new car development and . .'inance given to specific and select applications of non-asbestos isls is not representative of the mass or bulk of friction materials u-tt ir. current new vehicle production or the replacement market. 006007 PRODUCED BY FORD *ulbu*ms iequoki IP o making Sequence APPENDIX A PHs- ARCED 006008 PRODUCED BY FORD