Document vR3gkD6MjYy8kEdM7zdnJwrq

Automobile Manufacturers Automobile Importers of America Proposed ruling is unfair to importers 1981-1983 baseline permit--import quotas were in effect and poor economic conditions prevailed Very likely that domestic manufacturer will not be required to meet the 70%, phase-down in the first year New entrants into U.S. market who have no baseline European braking standards based on braking balance and skid avoidance rather than stopping distance as in U.S. European customers accept accelerated brake wear and noise. AIA proposes Allow unlimited use of asbestos for a fixed period Then impose ban for those uses where adequate substitute materials are available Important to continue use of asbestos for replacement parts of previously manufactured vehicles Subaru Support a 5 year lead time required before banning friction products. Include extension clause. Replacement parts for the car produced before effective model year must be excluded from this regulation. Honda Set up timetable based on model year and must consider necessary lead time. Gaskets should be exempted because exposure of asbestos products is very unlikely. Mitsubishi Lead-time too short. 5 years is more reasonable. Need exemption provision if acceptable replacements are not available after 5 years. If FMVSS-135 is adopted, more lead time will be required. Exemption past 5 years may be required for clutch facings and gaskets. 117