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FILE NAME Caterpillar CAT DATE 1971 Oct 19 DOC CAT042 DOCUMENT DESCRIPTION Written Testimony Submitted to IL Pollution Control Board at Regional Hearing on Asbestos and Spray Insulation ~ 4 i SUBMISSION OF CATERPILLAR TRACTOR CO to State of Illinois Pollution Pollution Control Board at Regional Hearing on Asbestos and Spray Insulation Waukegan Illinois October 19 1971 ~ 1007362 015 ee PREFACE e ;woes ' It is the sincere desire of Caterpillar Tractor Co. to cooperate with and assist the State of Illinois Pollution Control Board in the prep- aration of the proposed Asbestos and Spray Insulation Regulations 271-16 in accordance with the Environmental Protection Act of the State of Illinois The purpose of this booklet prepared by Caterpillar Tractor Co. is to supplement the statement and document the information presented by the Company at the Regional Hearing on Asbestos and Spray Insulation Reg- ulations at Waukegan Illinois on October 19 1971 Included in this booklet are 1 Caterpillar's concerns regarding the possible prohibition of asbestos brake linings and 2 Caterpillar's recommendations relative to the proposed Regulations which would ban asbestos brake linings by 1975. Also includeidn Appendix B is a copy| of Caterpillar Tractor Cov'e oral testimony presented at the Waukegan Hearings October 19 1971 11 meres oe ee Ce 9001 0572 PRODUCEDYRY PRODUCEDYRY BORIS a= t 7 Tae 5 4S5O5RES TABLE OF CONTENTS PAGE NO I. INTRODUCTION coceccccvcccceveccns ethene ae dtee sesrewesuserens i A. Purpose of Booklet B. Caterpillar Product Line II CATERPILLAR CONCERNS .eessccveccevencceccevccsvevesacesseess 2 A. Proposed Regulation R71-16 Asbestos and Spray Insulation B. Definition of a Vehicle C. Reasons for Caterpillar Concerns ; 2 Prohibition of Asbestos Brake Linings 2. Some Types of Disc Brakes are Not'a Solution III PROBLEM IDENTIFICATION ... & Types of Caterpillar Product Brakes B. Brake Wear Products C. Asbestos Usage - Caterpillar vs. U.S. Consumption IV OTHER CONCERNS .. 17 A. An Illinois Standard Would Dictate Worldwide wer Caterpillar Requirement s Dealers Illinois - B. Effect of Proposed Regulations on Caterpillar V. SUMMARY AND RECOMMENDATIONS woven 19 APPENDIX .. ccesrcncerssvccccentannesecenecns pb casnetasseeecs 21 A. Caterpillar Product Line Brochure B. Caterpillar Oral Testimony October 19 1971 Waukegan Illinois 118 ee earners - 8001 0573 PRODUCEN AV BADA LIST OF FICURES PICURE NO PAGE NO 3 1. EXAMPLES OF CATERPILLAR EARTHMOVING EQUIPMENT S 2. TORQUE CURVES OF FRICTION MATERIAL 6 3 TRACK LOADER WITH RAISED BUCKET " 4. TRACK TRACTOR ENCLOSED BRAKE COMPARTMENT 8 5. HIGHWAY TRUCK ENCLOSED OIL COOLED MULTIDISC BRAKE 9 _ 6. FRICTION PLATE AND MATING PLATE FROM BRAKE IN FIGURE NO.5 10 7. MOTOR GRADER SHOE BRAKE DRUM REMOVED 10 8. WHEEL TYPE LOADER CALIPER DISC BRAKE 11 9. ASBESTOS FIBER FROM NEW BRAKE LINING 5000x 14 10. NEW BRAKE LINING SCRAPINGS AFTER HEATING 5000X 11. DEBRIS FROM DRY BRAKE COMPARTMENT 5000X 12. DEBRIS FROM DRY BRAKE COMPARTMENT 5000X 14 14 14 9001 0576 Sv PRODUCED BY FORD Deak 1. INTRODUCTION an ane A. Purpose of Booklet eteat The purpose of this booklet is to supplement and support the oral statement made by Caterpillar Tractor Co. at the Regional Rearing on Asbestos and Spray Insulation Regulations at Waukegan Illinois on October 19 1971. Recommendations and suggestions contained herein are intended to apply only to products of a type and kind built by Caterpillar Tractor Co. The information presented is brief the intent is toprovide the Company's posi- tion relative to the proposed ban on the use of asbestos brake linings B. Caterpillar Product Line Caterpillar currently produces 52 models of track or wheeled earthmoving equipment equipment in addition to 53 models of Towmotor material handling equipmenaltl of which have braking systems which utilize asbestos friction material The following list- ing gives the pumber of models in each specific product line Appendix A pictorially illustrates the Caterpillar product line modela of track tractors models of wheel tractors and compactors models of track loaders 13 models of wheel loaders models of pipelayers 13 models of wheel scrapers models of motor graders 2 models of highway trucks models of highway tractora 52 Total Models 800 0575 PRODUCED RV BORTY CATERPILLAR CONCERNS . A. Proposed Regulation R71-16 Asbestos and Spray Insulation The specific portion of the proposed Regulation that concerns owe Caterpillar Tractor Co. is Part VII - Asbestos Containing Prod- ucts Section 702 which states The use of asbestos in the brake lining of vehicles manufactured after January 1 1975 and sold for use in Illinois is prohibited a eee B. Definition of a Vehicle a Pa The lack of a definition for the word vehicle in the proposed regulation is of concern to Caterpillar Tractor Co. The Vehicle Code Section 1-217 defines a vehicle as every Illinois device in upon or by which any person or property may be transported or drawn upon a highway Although this definition could provide some clarification to the proposed regulation if included it is obviously quite general Earthmoving equip- ment does not normally operate on public highways and is not , designed for such use although certain equipment such as the 613 Elevating Scraper is small and light enough to be driven on the highway in its movement from one job site to another motor graders may also be used to repair and maintain existing roads Regulatory statutes typically have differentiated between motor vehicles and carthmoving equipment It is therefore the Company's suggestion that this distinction should be recognized - ^'s 4158 1008 os : PRODUCED RV FARN and dealt with by including the following definition of vehicle in Section 103 of the proposed Regulations - Vehicle Any propelled device designed primarily for transporting persons or property on a strect or highway A specific definition of this type would properly exclude from the proposed Regulation earthmoving and construction equipment -- pot designed primarifloyr use on public highways . Reasons for Caterpillar Concern Unaware of the full intent of the proposed Regulation and un- certain as to whether or not Caterpillar product is included ad in the proposed Regulation the Company felt it mandatory to present its case assuming the intent was to include earthmov- Ing equipment 1. Prohibition of Asbestos Brake Linings It is the Company's concern that all use of asbestos in brake lining prohibited _ Asbestos brake linings are used in all Caterpillar product because of their demonstrated safety and durability characteristics which will be discussed in wore detail later At this time Caterpillar is unaware of a safe substitute for asbestos brake linings our experience with sintered metal brake material has been unsatisfactory The brakes on some of Caterpillar's equipment are totally enclosed The brakes on many models are immersed and rotat- ing in cooling oil In these cases asbestos wear products 900 0577 PRODUCED BY FORN of cannot get into the atmosphere atmosphere except possibly when the brake compartment covers are removed for service Other models have brakes with shields which are pot air tight rm, and thus brake lining wear products can escape to the atmosphere The characteristics of these wear producta are described in Section III of this booklet Some Caterpillar models use caliper disc brakes which $ are not enclosed and the brake pads containing asbestos can emit their wear products directly into the air 2. x Some Types of Disc Brakes Are Not a Solution . om In the explanation of Proposed Regulations R71-16 the statement is made It is contemplated that the ban will pecessitate design changes probably to disc brakes As previously mentioned Caterpillar Tractor Co. currently . utilizes caliper disc brakes on some of its models however asbestos friction material pads are still utilized in this ~ type of brake because of the safe sure stop they provide |q . be disc It must pointed out that caliper brakes are not an not not alternative solution to banning the use of asbestos brake linings In fact with the open nature of caliper disc brakes it is easy for brake wear products to be emitted 4001 0579 PRODUCED RY FORD 12 PROBLEM IDENTIFICATION A. Types of Caterpillar Product Brakes Asbestos friction material is used for brake lining through- <coNR out the entire line of Caterpillar Tractor Co.'s earthmoving equipment A few of the models are shown in Figure No. 1 A is OMROW wheel * tractor B is a motor grader C is a wheel oe FIGURE NO 1 EXAMPLES OF CATERPILLAR EARTHMOVING EQUIPMENT loader D is a wheel scraper and 2 is an highway truck Asbestos friction material is not used in Caterpillar's : brakes from happenstance but is chosen for its performance re. Hability and safety Some of the products use dry friction surface brakes and some are bathed in cooling oil For example the highway truck E has totally enclosed oil cooled multi- ; disc brakes while the wheel scraper D has shoe brakes + fi : Rach product c.g. truck wheel scraper etc. requires a specific brake type and friction material depending on its primary , ; application ae - os Lit 8001 0579 . tN ome Oe Oe om mata ao mw we wee PRODUCED BY FORD . Q e-ahel As early as 1937 Caterpillar was conducting research work to Pi identify operating characteristics of all known types of brake B, ny lining material It is a necessity that Caterpillar provide ee its customers with the best performing and safest brakes pos- see sible So far a material superior to asbestos that fulfills all the requirements needed for the heavy brakes required on earthmoving equipment has not been found co TORQUE DIAGRAM FOR TWO DIFFERENT FRICTION MATERIALS . . TORQUE ene a5 8.2 EEE Pe ee ae ort bos he a _ CURVE A 7 Liaw ce sere nme co me we 2 yn nr ma cahe amb tame 4 me ame Jom op a ee da ecn ere ew .t g . BEGIN SLIP TIME - \- tT ais END TORQUE CURVE eo . . FIGURE NO 2 MATERIALS TORQUE CURVES OF FRICTION MATERIALS Figure No. 2 is a strip chart recording of the torque re- lationship for two different friction materials These two . traces illustrate the frictional behaviour throughout a brake application In curve A note the smooth deceleration or brak- ing as the wheel speed is reduced to zero from beginning to end of stop This is one of the characteristics we expect from asbestos material On the other hand curve & of a non. asbestos friction material shows undesirable speed change conditions The trace exhibits considerable frictional vibration This results . Se he ee eee wo 8 ea ee en wee - 8001 0580 PRODUCED BY FORD ry oe To in toise and undue stress in the whole brake system The abrupt SRT circled change to a static level at the end of braking as in Figure No. 2 on the right of curve ) causes instability and an erratic unsafe brake operation FIGURE NO 3 TRACK LOADER WITH RAISED BUCKET | If a track loader see Figure No. 3 stops abruptly rather than smoothly while backing up with a raised bucket full of rocks * " some of the rocks leave the bucket and continue in the rearward direction and end up in the operator's lap This safety hazard also applies to other earthmoving machines which can spill a load due to an abrupt stop a , 8001 0581 PRODUCED BY FORD wt FIGURE NO 4 TRACK TRACTOR ENCLOSED BRAKE COMPARTMENTCOMPARTMENT The enclosed brake compartment in Figure No. 4 shown with covers removed has band brakes noted noted by arrows which are used either dry or bathed in oil In either case due to the enclosure brake vear products cannot be emitted into the am- ~ bient air during normal operation When servicing these ^'s + compartments they are exposed to the ambient air and the products found Figures No. 11 and 12 and discussion are powder rather than fibrous in nature and submiczon in size PRODUCED BY FORD wel ee * abt 2 . 8 . Try nd. ENCLOSED FIGURE NO S HIGHWAY TRUCK OIL COOLED MULTIDISC BRAKE Figure No. 5 is an example of multidisc brakes which are totally enclosed and bathed in cooling oil The only time brake wear products from this type brake are exposed to the ambient air is during servicing This brake was originally designed to use sintered metal friction material Poor performance re- liability and safety requirements Decessitated a change to * asbestos material @ 8001 0583 TER ee . eS meee ee wee pee ee ee ee ey mee eee oe Sete OR ee = ee etn ne ee me, PRODUCED BY FORD - POSRetDeT EYLtee ~~ < i *mouaeayeetfiemo FIGURE NO 6 FRICTION PLATE AND MATING PLATE FROM BRAKE IN FIGURE NO S 4 r. Figure No. 6 shows the asbestos containing friction plate used in the previously mentioned multidise highway truck brake design This design of disc brake system cannot enit wear prod- wets into the air and the fact that environment during operation due to its oil it is contained in an enclosed compartment ^' . e: be C pee FIGURE NO 7 MOTOR CRADER SHOE BRAKE DRUM REMOVED oe a -ee 1 * 4 8001 0584 PRODUCED BY FORD 3 Se / nto sete=e tates tat e Figure No. 7 shows a shoe brake located in the wheels of rubber- tired earthmoving equipment Motor grader shoe brakes of this type normally are shrouded to protect the operating mechanism The shrouding way allow brake wear products to be emitted into the ambient air since it does not provide an airtight compartment Caliper disc brakes bn ted KOUSING HYDRAULIC BRAKE CYLINDER S PONE yy" a 4 ~} Ls ia \ 4 . o ; | _ ; { oe, ; i ~ v WS art \ a. 3 4 , 49 \4 , Vey : s FIGURE NO 8 WHEEL TYPE LOADER CALIPER DISC BRAKE Conventional caliper disc brakes are also used on some Caterpillar product and are show in Figure No. B. The pads in the brake cal- iper contain asbestos With this type of brake system any brake wear products are emitted directly into the ambient ambient air 8001 0585 PRODUCED BY FORD 22 The heavy performance of Caterpillar machines and their braking requirements are considerably more stringent than auto- notive applications and need to be explained It is normal for track or wheel loaders to go forward and reverse as frequently as 180 times per hour all day long and often three ^' shifts a day This means as many as 360 brake applications per hour Bulldozing operations also require severe usage of brakes since track tractors are steered by the brakes . - Caterpillar 666 Wheel Scrapers weigh 250,000 pounds when loaded chines to capacity Typical applications going downhill when fully loaded will find these 4s The brakes on a ma- 250,000 pound scraper stopping from 45 miles per hour on the level convert enough energy into heat to melt 41 pounds of iron A typical passenger car stopping from this same speed would develop enough heat to selt 2/3 of a pound of iron Of course downhill operation increases the energy dissipation further highway trucks weigh slightly less and must perform in similar situations ~ Pipelayer brakes must hold as much as 200,000 pounds of pipe sus- pended over a trench while men are working beneath the pipe Track tractors often operate in conditions where very steep slopes must be negotiated in forward and reverse Since these machines are steered by the brakes the safest possible linings must be used to prevent brake failure which could result in a machine attaining runaway speeds on these steep slopes 8001 0566 PRODUBC Y E FOD RD 13 It is Caterpillar's candid opinion that the prohibition of as^ e tosfrom brake linings would place a severe penalty on the performance and safety of earthmoving equipment ' B. Brake Wear Products @ In the December 1968 Air Pollution Control Association Journal Jeremiah Lynch presented the results of his study entitled Brake Lining Decomposition Products In an initial study dust samples taken from automobile brake drums were examined Electron micro- graphs did not reveal the presence of any free fiber Additional study on a laboratory basis was conducted Decomposition prod- ucts of various brake linings were sampled under simulated operating conditions In all but a very few cases the linings tested showed less than % free absestos fiber in the decomposition product This is a significant finding since the original linings averaged 50 asbestos by weight In the isolated cases where significant free asbestop fiber was found the test conditions were such that br^,ke failure would have occurred if the linings had been sudjected to like conditions in.a vehicle Lynch states that in all but the most extreme driving conditions only a very small fraction of the 30 - 50 asbestos present in brake lining escapes into the ambient atmosphere as a free fiber 2587 Wear apparently occurs not by abrasion but in minute areas of Anol Intense heat at points of contact between the drum and lining At these temperatures about 900 decomposition products do not generally contain free fiber but are different mineral resulting from the thermal breakdown of the asbestos . PRODUCED BY HORD ewer + tee gre oie aes: ae ; FIGURE NO 9 Asbestos fiber from new brake lining 5000 . cone FIGURE NO 10 New brake lining scrapings sit beating to 1200 for 30 mi . 5000x All fibers in Figures No. 10. 11 and 12 are below 5 micron in lengt q -* s aor - cor) 54 54 re bee! 7 Ks % a, ee EU. eet. &. RO See RPP ^'Py} Pe ORD SS OF L. 1 At Rowe, oer hee ruts Ne> vA ~T Sift sa m= a mong oe we BS. , Wrst afm, . nf % S 2A, pm * eS Lo Bree ye Vann Sydvr: SS is aim Ck ae 2 s . 3 tL . o. Es 9 Abse h,AS or SL. . Ay PAG , soe, . CW's tae SS ae we ei~ TeN N 5 ot NS, > . ww ah eae Je ae we te aa ry o8 Z ae 2 Ww ror a 2 eet EN ws : mee Fal th Ors ty Debris FIGURE NO 11 from dry brake compartment . 5000x Debris FIGURE NO 12 from dry brake c' 5000x k 35 Microns - Thickness of a human hair at 5000 800 0598 -te PRODUCED BY FORD 15 Recently tests were made by Caterpillar's Research Department on the wear debris found in an enclosed tractor dry brake compartment which corroborates Lynch's findings The four photographs on the opposite page were made with an electron icroscope at 5000 x magnification Note the 5 micron two ten thousandths of an inch or 0.0002 scale in the center of page No. 14. Section 601 in the proposed Regulation states that only fibers of 5 microns or greater in length be . counted in the emissions from a factory into ambient air The scrapings from an unused asbestos brake lining shown in Figure No. $ obviously have fibers longer than 5 microns in length Heating these scrapings which provides a laboratory simulation of continued brake applications from an unused brake lining destroys the fibrous nature This is shown in Figure No. 10 Mechanically rubbing the deteriorated fibers in a brake would ~e further powder this material Figures No. 11 and No. 12 show the actual debris found in dry brake compartments Any fibers 4 Tr visible are submicron in size With the intense heat resulting from brake application it is expected that . . micron debris would also occur in enclosed a breakdown to sub- oil cooled brake compartments If the standards in Section 601 of the proposed Regulation were applied to brake emissions into the air the brake wear products of heavy earthmoving equipment would be under 5 microns in size and therefore be within threshold limits 2001 0584 nn --- nen pr e renn e ta1l : ~ PRODUBYCFEORDD . . 26 ; . -s It should be pointed out that there are well over 100 different natural minerals having a degree of fibrous structure Some investigators consider respirable fibers to be ubiquitous everywhere at the same time and feel that much more definitive information must be obtained on their identification source and biologic response A good example of this is talcum power which is found in almost every home and is a measurable source of asbestos fiber Tremo- lite snother form of asbestos occurs used in this country and is thus found naturally in talcum in most powder tale In- dustrial tale may contain as much as 30 tremolite Since more * thon 750,000 tons of tale are used in this country annually it must be considered to be a prime source of respirable asbestos fibrils The finest single fiber shown in Figure 9 No. can be called a fibril C. Asbestos Usage - Caterpillar vs. U.S. Consumption = Finally it should be pointed out that of the more than 800,000 tons of asbestos used in this country each year only about 32 of this goes into the manufacture of friction materials such as brake linings Caterpillar's dry brake asbestos material usage amounts to 0.006 of the total asbestos usage in the U.S.A. and less than 0.2 of the total friction material usage of asbestos in the U.S.A. It is felt that the amount of free asbestos fiber hat can potentially become airborne as a result of breakdown of brake linings of earthmoving equipment is quite likely to be significant from a health standpoint low and un- 0590 80 1 PRODUBC Y FE ORDD 11 Pott > CONCEPTS e Pee CONCEPTS AE Caterpillar A. in Illinois Standard Would Dictate Worldwide Caterpillar requirement CSM standard ney,* The establishment of a which prohibits the use of a ee Pe paterial in vehicles which are manufactured and sold for use in Illinois has the effect of setting national or even international standards It is impossible to know the ultimate destination of Caterpillar machines as they are assembled and to provide for selective assembly or alternate brake sys- team for those to be sold in Illinois In order to provide competitive leadership on a worldwide basis Caterpillar has established the policy to use interchangeable parts on all models so that specifications can be followed for purchase and manufacture at any plant in the world If there were a material that would do the same job as asbestos in brakes it is highly improbable that it could be a direct substitute would have Other mechanical parts s to be modified to adopt this new material The results would be an Illinois only . machine with parts only available locally not worldwide The customer could immediately react to this and buy a standard machine in a neighboring state and move it into Illinois as a used machine 0 Caterpillar Tractor Co. has long been a leading and vitally in- portant company in Illinois As the state's largest private employer with over 41,000 employees and 6 manufacturing facilities it has become the largest dollar exporter of product in the United 17 8001 8591 PRODUCEN BY BAPT 18 States Over 52 of the 2.1 billion annual sales reached in 1970 were outside the United States Illinois would not be the leading state in exports to other countries without Caterpillar Imposition of a ban on the use of asbestos in brakes would impose a severe restriction upon Caterpillar Tractor Co. B. Effect of Proposed Regulations on Illinois Caterpillar Dealers | The requirement for a specific design of earthmoving equipment * for and Illinois Illinois could result in a hardship for earthmoving contractors and a Caterpillar dealers subsequent loss of sales tax to the State Special brake assemblies to meet the would result Illinois requirement of necessity in higher first cost of product This higher first cost would result in higher bid prices for road building and earthmoving contracts Thus with a fixed State budget for road improvement etc. less work would be done and fewer machines would be sold 8001 0591A PRODUCED BY FORD . . wt Caterpillar Tractor Co. sincerely believes that the information presented in this booklet establishes reasonable doubt about the real contribution of earthmoving equipment to the asbestos en- ; vironmental problem It has been pointed out that each Caterpillar product uses a distinctive brake system design which is influenced by its working environment job application spectrum performance criteria and safety requirements However all Caterpillar prod- _ vet brake systems use asbestos friction material since it has evolved over the years as the most satisfactory material all aspects particularly safety considered Caterpillar Tractor Co. tests and % @ toial Company usage of asbestos both indicate that asbestos friction material used in our product does not significantly contribute to the Jevel of asbestos fibers in ambient air - at least not to the point where its use should be prohibited Based on the aforementioned points and the significant interstate and international commerce aspects Caterpillar Tractor Co. questions whether the intent of the Asbestos and Spray Insulation Regulations ~ . is actually accomplished by the proposed ban of asbestos brake linings If research vork and data on ambient concentration levels of asbestos fibers which are detrimental to society establish a need for asbestos brake control and regulation Caterpillar recommends that Section 702 Part VII of R71-16 Asbestos and Spray Insulation fibe modified to allow the following exceptions Regulations 2 , 19 9001 0592 Pete at eee PRODUBC Y FEORDD  20 wt o - That asbestos brake linings friction material may be used in o brake system when the friction material operates in either a dry or wetted environment in a totally enclosed brake con- partment which prevents the ambient air the emission of brake wear products into 2. That asbestos brake linings friction material may be used in a brake system when the friction enclosed brake compartment until material operates in a non- conclusive medical evidence proves that the emitted brake wear products contain haruful amounts of asbestos fibers If all evidence indicates the need for asbestos brake controls and culations Caterpillar would further recommend that reasonable reshold limits of asbestos fiber be established by qualified per- connel based on scientific fact and foreseeable technological advances Test procedures which measure the concentration of asbestos fibers zust also be developed which are understandable repeatable and realistic Place the burden on the manufacturer to design his product to meet rea- sonable attainable standards - don't just prohibit the use of asbestos for brakes As mentioned at the beginning of this booklet Caterpillar Tractor Co. Protection ^,grees in principle with the objectives of the Environmental Protection Act The Company stands ready and willing to assist the Board in the establishment of asbestos regulations which serve the intent of the legislation " . 3 oo ew te eee ee ee eS ai TAD LP EM te oS, 8001 0593 . PRODUCED BY FORI