Document r03pz8Eynx7a8yVX5wYyE6av

g' I; 96- 0 I 1 13 a I to | to e o' S 5 tfOt 5 s 2! P j.^ECEIVED CEC -al983 A^jFfC. '^ r 'i-'& imauumomAL wunresna November 22, 1983 )0rt U. U. Hoenes T. W. O'Boyle Eaton Corporation P. 0. Box 595 Galesburg, Michigan 49053 Subject: 11/4/83 OSHA Asbestos Emergency Rule 1/} '42c) RECEIVED UOV 2 1983 /*: niu c*c f\cor .Sj d <5> I <3 2 OSHA's recently Issued Emergency Temporary Standard on permissible asbestos fibers reaffirms their continued desire to eliminate the use of this material. In the case of brake linings. I'm sure you're aware IH, as well as other truck manufacturers, have programs to evaluate non-asbestos materials. However, this will be a time consuming process. It Is not only a matter of how soon lining manufacturers will have the capacity to convert all their materials to non-asbestos, but how quickly vehicle manufacturers can conduct the testing necessary to insure themselves they're not resolving one problem and creating others. Our testing to date shows the non-asbestos materials may well create such a situation. In addition, life projections (lining and drum) are not as clearly defined as one would be led believe. My purpose In writing you Is to find out: 1) If your company plans to be active In the upcoming hearings? 2) Does your company or associations to which you belong plan to provide comments to this rule by the 1/3/84 due date? 3) Does the proposed temporary standard present your company any problems In meeting our current demands for your products? If so, describe In more detail. 4) If OSHA plans to pursue a more stringent requirement, which In effect would eliminate the use of asbestos, how long would It take your company to completely convert to non-asbestos products? is 1 tso 2 Ioa 90 e * 1 TftUOC GROUP ENGINEERING 2911 Meyer Rood Fori Wayne. Indiana 48803 Add*MB lopty to P.O. Box 1109 Fort Wayne. Indiana 46801 0 2 to 1<900 to a EAB 009098 SCF-EC-2500