Document zy3oBL1ZpVMZ8QwEYQ3LqR96

FILE NAME Brakes BRK DATE 1985 Apr 25 DOC BRK239 DOCUMENT DESCRIPTION Contractor Review of Comments on EPA Proposed Rule WORK ASSIGNMENT NO 15 Received March 6 1985 ANALYSIS OF COMMENTS RECEIVED ON ISSUES A THE PETITION TO PROHIBIT THE USE OF ASBESTO EPA Contract No. 68-02-3861 COMMENT CATALOGUE Date April 25 1985 Submitted to USEPA Office of Toxic Substances 401 M Street SW Washington DC 20460 Submitted by Dynamac Corporation Enviro Control Division 11140 Rockville Fike Rockville MD 20852 CONTENTS INTRODUCTION eeveoreeveeveee0en ec Peeoevovevree veneer eevee eeee ee ee e@eetetee@ ses eee Page i I. IDENTIFICATION AND RECOMMENDATIONS OF COMMENTERS ..... eeeee I A. Trade Associations ... evpeveevvnevrevreeeeereveerees B. Vehicle Manufacturers .. C. Brake Manufacturers .. D. Substitutes Manufacturers ..ccesceevecesves ccc ceeecence E. Miscellaneous Commenters ...csscccceccecreccercseves eee 10 14 17 II LEGAL AND POLICY ISSUES ..cccccsccceceeonesevurereerssevescs A. B. EPA vs. OSHA as Regulatory Agency ..-serereereeeeverees Demonstration of Unreasonable Risk ...-.-seeesseeeees II II II III IV HAZARDS ASSOCIATED WITH ASBESTOS USE IN BRAKES .........--- III A. Epidemiological Evidence and Case Reports ...-.-.-+-++B. Health Effects of Chrysotile Fiber vs. Other Fiber Types III III C. Asbestos Release from Brakes - Properties Amounts Exposure and Health Concerns .....-++-++++-- III SUBSTITUTES wc ccc ccc sce c cn sne cece ees errs ereerererereresers IV A. Emcor 66 .isccccccvercencereccerevevressceseresersscers 1. Applications and Performance .. 2 Commercial Availability 3 Cost ccnccsveveresccece ceeees seer een eee ee eeeee senee 4 5 Health Effects cc cece ence err c cece rcetrvcceersess Experience ..... sec eees ewer eev re eneee eeeeeeeere IV IV IV IV IV IV B. Phosphate Fiber .....-sseeeveres eect c eee meee e rere eeeees 1. Applications and Performance ... 2 Commercial Availability 3 . Cost 4 Health Effects ........ sec c cece renee eae pene cece eer eeeeeees IV IV IV IV IV C. Carboflex Carboflex Carboflex Carboflex Carboflex Carboflex ... 1. Applications and Performance .....eeeseseeereereees 2. Commercial Availability . 3. Cost Lecce ccasrcvvesevenssseseeves emcee ere reereree D. Kevlar Aramid 2... cece ecw c cere nner ne snerrarercreeessenes 1. Applications and Performance .....+-erseeereereress 2 Commercial Availability 3. 3. Cost Cost . 4 Experience oo. ccc cere cers enn ec cre reece nsercreereeee IV IV IV IV IV IV IV IV IV CONTENTS continued E. Substitutes in General - Availability Performance Health Effects Safety ... IV F. Special Considerations for Existing Vehicles ........-. IV V. CRITICISMS OF NRDC PETITION AND EPA RESPONSE eevee eeveeereee A. NRDC Petition seca c cece eer eceeeeenee eaereerererocer ere eoee B. EPA Response ........ APPENDIX A List of Commenters .....ccsccecvvcvscces APPENDIX B References .....ceccee eoereseeeeerene APPENDIX C Cross References .... INTRODUCTION In a December 19 1984 Federal Register notice the Environmental Protection Agency invited the public to comment on issues relating to a Natural Resources Defense Council petition to prohibit the use of asbestos in vehicle brakes This Comment Catalogue contains excerpts from letters received by the EPA in response to the Federal Register notice The Comment Catalogue consists of five major sections and several subsections as shown on the Table of Contents These sections were formulated after a careful review of the issues raised by the commenters Included in the appendices are a list of commenters arranged by category a complete reference list of comments received and cross references showing where comments for each commenter can be located in the catalogue The comments are numbered consecutively from 1 to 90. The reference for each comment is found after the comment itself and each comment is separated by a horizontal line I. IDENTIFICATION AND RECOMMENDATIONS OF COMMENTERS A. Trade Associations The Asbestos Information Association America AIA a nonprofit organization whose member companies in the United States and Canada are involved in the mining and milling of asbestos and the manufacturing and marketing of containing products welcomes the opportunity to comment on the Environmental Protection Agency's response to a citizens petition on asbestos which was published in the December 19 1984 Federal Register First AIA would like to reiterate the position taken in its earlier comments dated November 28 1984 on the petition to ban the use of asbestos in brakes Those comments argued that asbestos should not be banned for the following reasons 1 Ambient levels of asbestos and the small contribu- tion of brake materials to those levels do not represent an unreasonable risk to the public 2 The use of containing products does not constitute an unreasonable risk to brake maintenance workers and in addition EPA should defer to the Occupational Safety and Health Administration on workplace regulation 3 Substituting materials for which the health effects have not been evaluated and whose use is uncontrolled for asbestos which is highly regulated could result in greater health risks to the public and workers 4 A ban would be contrary to the international consensus on the controlled use of asbestos 5 The NRDC petition to ban the use of asbestos in brakes is not based on considerations of un- reasonable risk as required by TSCA but rather on an approach which advocates a zero risk standard for the statute Returning to the particular case in point the Agency comtemplates an action to ban the use of asbestos in brakes in favor of substi- tute materials The economic effects of such action would be certain and substantial The benefits of health effects are speculative and they are of a magnitude that would not of such an action in terms uncertain not only because be detectable but also because no consideration is given to the health effects of the sub- stitute materials which have their own potential for harm Such an action could not be considered to be a reasonable one and would not be permitted under TSCA Asbestos Information Association pp 1 2-3 The Friction Materials Standards Institute Inc. FMSI is a trade association of twenty friction materials manufacturers in the United States with associate Members worldwide The FMSI has read the petition submitted by the Natural Resources Defense Council NRDC to the Environmental Protection Agency EPA for the purpose of prohibiting the use of asbestos in brakes for new cars and trucks and in replacement brakes in existing vehicles We wish to comment comment at this time on certain sections of the petition While we are not now taking a position for or against said petition we believe it is important to submit the following comments Should it be deemed appropriate these comments may be supplemented at a later date by a more depth critique We will refer to the sections as headed in the NRDC petition Ar funmediate ban on the use of asbestos in passenger I and truck brar s cannot be supported because of the importance of safe brake systems on the nation's highways Brake linings are a safety related product We stress consideration of these facts 1 There are legitimate questions on the health hazards of the fibrous substitutes suggested for asbestos replacement . in friction materials 2 There are programs in place by industry c eliminate the use of asbestos in friction materials and these programs realistically address health safety economic performance timing and materials availability issues 3 The industry must be given time to develop a total line of products which will meet all highway safety rerequqirements uirements safety We believe the industry will accept a properly planned program pointed towards the eventual elimination of asbestos in its products We urge that EPA study the suggested substitute materials as well as the feasibility economic impact realistic necessity - if it exists and timing requirements appropriate to the elimination of asbestos in friction materials before re- sponding to the petition or proposing a bon on the use of asbestos in friction materials Friction Materials Standards Institute Att 1 pp 1 4-5 3 I furnish herewith in triplicate the comments of the Japan Automobile Manufacturers Association with the above captioned proceedings Tokyo Japan in connection Based on information received to date EPA is not prepared to make an unreasonable risk finding for an immediate ban of all uses of asbestos in brakes at this time We consider this as an entirely reasonable judgment and agree to such and pay our respect to this Taking into consideration the availability of substitute fibers it is expected that we will encounter difficulties if vehicles decide to adopt the substitute materials It is recommended that the action to prohibit the use of asbestos presently used as a major brake component and the substitution use of a asbestos brake friction material should- be phased in smoothly over time granting sufficient lead time at each stage Japan Automobile Manufacturers Association Att 1 pp 1 5 The Motor Vehicle Manufacturers Association of the United States Inc. MVMA is a profit trade association whose dan members produce more than 98 percent of domestically manufactured motor vehicles and employ nearly 750,000 workers We are pleased to respond to the December 19 1984 Federal Register notice in which the Agency invited the public to submit comments on issues relating to the Natural Resources Defense Council asbestos petition Based on the available information MMVA urges EPA to continue its current strategy as outlined by the Office of Toxic Substances Asbestos Regulatory Program As outlined under the Toxic Substances Control Act TSCA the exercise of authority to regulate a substance under TSCA requires a balancing of societal costs and benefits In the context of the NRDC petition an immediate ban on this use of asbestos is not justified Rather the OTS regulatory plan to eliminate asbestos over a period of ten years as substitutes become available is appropriate MVMA members are AM General Corporation American Motors Corporation Chrysler Corporation Ford Motor Company General Motors Corporation International Harvester Company M.A.N. Truck & Bus Corporation PACCAR Inc Volkswagen of America and Volvo North America Corporation Inc. Motor Vehicle Manufacturers Association pp 1-2 B. Vehicle Manufacturers In view of the controversy and the problems encountered with the development of asbestos substitutes Chrysler Corporation believes that it would be inappropriate to prohibit the use of asbestos in brake linings at this time Chrysler and we believe the other vehicle manufacturers are moving to asbestos brake lining materials as rapidly as technology will permit Any regulation will not increase the rate of this changeover and forcing the use of asbestos materials at a premature date could very well result in compromises in brake performance which are not in the interest of motor vehicle safety In addition to these comments Chrysler Corporation participated in the development of the comments submitted by the Motor Vehicle Manufacturers Association of the United States We endorse those comments and by reference incorporate them as a part of our response Chrysler Corporation p.3 Ford Motor Company is not in the brake manufacturing business We purchase all of our brake systems and parts both for the assembly of new vehicles and for the aftermarket from outside manufacturers and suppliers Whether the purchased in assembly parts are used in Company cars light trucks medium trucks heavy trucks agricultural tractors construction tractors or for the aftermarket all of the friction components -- be they pads or shoes -- are manufactured by others In considering whether to regulate the use of asbestos in brakes EPA must be sensitive to this crucial issue It would be neither effective nor constructive for EPA to force the complete redesign of car and truck brake systems at enormous costs for currently vehicles or for production vehicles for which the consuming public rightfully expects that aftermarket parts will remain available for routine maintenance service at reasonable cost We thus strongly recommend that EPA not seek to regulate the use of asbestos in the brakes of vehicles which currently are being manufactured or which formerly were manufactured with containing brake systems Ford Motor Company pp 1 2 IH's interest in this rulemaking stems from the fact that it is a leading manufacturer of medium- and heavy trucks and buses in the United States having these products Moreover the largest share since the January of the market for 1985 sale of IH's agricultural equipment operations to Tenneco Inc. the company is now completely dependent on sales of trucks and medium diesel engines in North America IH currently purchases from outside suppliers various components containing asbestos These include gaskets clutch facings sealing materials and brake assemblies Because IH is a purchaser rather than a manufacturer of containing products it is extremely concerned about the possible effect that a ban on use of products in motor vehicles would have on its product planning and engineering RECOMMENDATIONS 1 EPA should thoroughly analyze the health risk from exposure to motor vehicle uses of asbestos to determine if such uses present a health problem that must be addressed On this point IH supports the arguments of the Motor Vehicle Manufacturers Association in its comments on this rulemaking 2 Any ban on use of asbestos in motor vehicle applications should allow motor vehicle manufacturers sufficient lead time to test and incorporate new materials into their products 3 In applications where satisfactory substitute materials are not available either in production or aftermarket usage EPA should allow exemptions from the rule International Harvester pp 1 5-6 Renault agrees that certain a threat when released into types of asbestos consist of fibers which pose the atmosphere but the asbestos dust emitted by wear of the brake linings is never found in this form Provided that certain basic precautions are especially during replacement installer taken the handling of asbestos brake linings installation is also without danger to the Renault USA Inc. p 2 C. Brake Manufacturers The Highway Braking Systems Division of the BFGoodrich Company is a producer of disk brake assemblies for loaders scrapers and haulage vehicles We currently purchase individual components including brake linings The prime functions performed at the Highway Braking Systems Division are metal component machining and assembly With regard to the brake linings which use of asbestos contain asbestos BFGoodrich currently uses but we perform no grinding or machining operations to the asbestos containing linings In summary BFGoodrich produces brake systems for a small highly specialized market The unique friction material requirements of the highway market are satisfied for the most part by asbestos BFGoodrich is actively searching for asbestos free substitutes at this time Finding asbestos free linings to evaluate is difficult due to low volume which causes lining vendors to concentrate their efforts in other areas There is no asbestos free lining material currently available to replace asbestos linings BF Goodrich Company pp 1 2 10. Motor Wheel Corporation a wholly subsidiary of The Goodyear Tire & Rubber Company is a major supplier and manufacturer of wheels and brake products for the passenger car truck and highway vehicle North American markets As a manufacturer of automobile and truck brake drums we have dynamometer testing experience with both asbestos and asbestos lined drums We have noted several areas deserving of comment and the Agency's concern prior to final rulemaking Motor Wheel's testing is not extensive enough to formulate any final conclusions However we do recommend extensive testing be undertaken to decisively determine the effect of non- asbestos life linings on vehicle brake performance and brake drum Motor Wheel Corporation pp 1 2 11. Rockwell International is a major manufacturer of foundation brakes for heavy highway highway and military vehicles impacted by the above referenced subject The foundation brakes which incorporate purchased brake linings are supplied to the vehicle manufacturers who in turn integrate the brakes into specific vehicle models and vehicle applications These vehicles are utilized in the trucking construction mass transit and agricultural industries as well as by the U.S. Department of Defense Rockwell International is also a manufacturer of other allied heavy vehicle chassis components such as axles brake drums universal joints and vehicle electronic monitoring systems Rockwell requests that the EPA consider the following in any proposal of rulemaking 0 Establish a phase program for NAB lining based on eliminating the largest amount of asbestos in the best possible time frame This should result in a stage process with the highway trucks and trailers representing 54 of the market as the first stage and where the earliest possibility exists for conversion to NAB lining The second stage should consist transit coach brakes and wedge time will be required of addressing the highway brakes brakes where considerable additional 0 Provide adequate monitoring of NAB programs as they affect the ) vehicle manufacturers 2 brake manufacturers and 3 brake lining manufacturers for the complete range of on- and highway heavy vehicles before establishment of regulatory effective dates 0 Coordinate the regulations affecting transportation with other appropriate Federal Agencies principal of which are the Occupational Safety and Health Administration and the National Highway Traffic Safety Administration It should be pointed out that the most critical test for NAB is the dynamometer requirements of the Federal Motor Vehicle Safety Standards Further any change to NHTSA Safety Standards can have a monumental impact when attempting conversion to new base brake lining materials We feel the suggestions outlined will minimize the asbestos used and enable the vehicle industry to make the transition from asbestos to asbestos material in the most expeditious manner possible In conclusion Rockwell emphasizes that any proposed rulemaking consideration to eliminate or phase out the use of asbestos in the heavy vehicle ' industry should recognize that unlike the passenger car industry asbestos substitutes for the multitude of heavy vehicle applications are only in the early stages of development Further the lining suppliers to this industry are limited in number and development capacity Rockwell International pp 1. 4-5 12 The Wagner Division of Edison International Inc. Wagner is an assembler of brake products Wagner buys its friction materials in accordance with performance specifications from outside suppliers We would strongly recommend that the EPA not regulate the use of asbestos as a component in brake lining for vehicles based upon the current knowledge available regarding substitutability and risks associated with asbestos in brake lining Wagner Division Att 1 pp 1 6 D. Substitutes Manufacturers 13 We wish to call EPA's attention to the availability of and to the possible use of low cost low modulus industrial grade carbon fibers as a suitable substitute for asbestos in automobile and truck brakes Ashland Petroleum Company p 1 14. In a data recent copy of the Federal Register the above on substitutes for asbestos friction petition requested products Enclosed are articles written by Du Pont asbestos friction products We hope the unaswered questions in the article on customers who have develop these articles help clarify Du Pont Canada Inc. p 1 15. These comments are submitted by Engelhard Corporation in response to a request by the Environmental Protection Agency EPA for information on asbestos substitutes in automobile and truck brakes Engelhard manufac tures EMCOR 66 mineral composition a very effective replacement for asbestos in friction products for automobile truck and railroad brakes EMCOR 66 is produced from American attapulgite which has been thoroughly tested and evaluated by independent researchers and has not been found to be associated with either cancer or fibrotic lung disease In addition to discussing the performance of EMCOR 66 as a replacement for asbestos in friction products and the safety of American attapulgite we also wish to respond to the unsubstantiated inaccurate and highly misleading statements and allegations made by certain asbestos product representatives concerning alleged health hazards of asbestos substitutes We have divided our comments into three sections Performance Character- istics of EMCOR 66 Summary of Health Research Conducted Attapulgite and Response to Certain Previous Testimony on American Engelhard urges the EPA to question seriously asbestos product representatives serving allegations that asbestos substitutes have not received adequate testing and scrutiny or that attapulgite carries the same health hazards as asbestos Engelhard believes that American attapulgite has been thoroughly tested and evaluated and does not represent a hazard similar to that presented by asbestos and Engelhard has submitted these comments in order to clarify the record on American attapuglite In addition we hope that the informa- tion presented here on the performance of EMCOR 66 as a friction material component in brake linings will reassure the EPA that feasible substitutes do indeed exist Engelhard Corporation pp 1 6-7 16. Monsanto Company is developing Phosphate Fiber a novel crystalline fiber form of calcium sodium metaphosphate The physical properties of Phosphate Fiber suggest it will be useful as a reinforcing fiber in friction materials and other composite products Monsanto Company p 1 E. Miscellaneous Commenters 17 I am deeply concerned at the Agency decision to grant the NRDC petition to begin an initiative to ban asbestos in brakes I do not believe that the Agency should take this step nor is there any reason that it should My concerns center on the safety of myself and my family if we are required to experiment with replacement brake materials until a satisfactory replacement is hopefully found someday It might be different if there were some reason to believe that such a ban would have a beneficial effect on some sector of and the Agency has no supporting data benefit actually will occur the for public but there is it to believe that a no reason measurable The Agency has no data to support a decision to ban asbestos here or elsewhere There are no scientific facts to support that even a small portion of the estimated 19.2 lives would be saved if the proposed ban were inflicted In fact there is no scientific basis for the risk assessment methodology used to arrive at these estimates That methodology has been criticized by the courts the Science Advisory Board and a large segment of the scientific arena See the comments in response to 49 FR 46294 There certainly is no assurance that any new forced substitution of materials would be better than 99.999 successful day after day year after year We urge the Agency to face up squarely to its responsibility to say no when no is the correct answer and deny the petition to ban asbestos brake linings The safety of my children and my grandchildren depends on this decision John T. Barr pp 1 4 18 The Center for Environmental Health of the Centers for Disease Control has reviewed the 211015 Proposed Rules on Use of Asbestos in Automobile which were published in the Federal Register on and Truck Brakes December 19 1984 Volume 49 No. 245 A reduction in ambient air elimination of asbestos in should be strongly weighed asbestos levels should be encouraged but the brake pads as a means of accomplishing this goal against the safety performance of alternatives Center for Environmental Health p 1 19 The members of the Classic Cars Of Ponca City Club are extremely concerned about the recent EPA plan to ban the use of asbestos in car and truck brakes As owners of antiques collectors and special interest automobiles dating back to the 1920's we strongly object to the use of semimetallic or aramid fiber brakes especially in our older automobiles which are not equipped with power brakes However we suggest that warning labels be placed on all packages containing asbestos brakes and proper instructions included in the packages on how to handle asbestos dust when replacing brakes Such precautions will minimize asbestos fibers ingestion in the lungs and eventually minimize lung cancer Classic Cars of Ponca City p 1 19 II LEGAL AND POLICY ISSUES TT 20 The Stratford Citizens Against Pollution is a local independent responsible this letter environmental group comprised of reasonable residents of both communities The purpose of is to express our legitimate concerns with respect to ambient asbestos concentrations in our neighborhoods as well as to define the sources of these emissions and to endorse fully the citizens petition filed by the National Resources Defense Council to ban the use of asbestos in brakes Our group was formed nearly to the chronically poor air two years ago in direct response quality in our neighborhoods due in most part to offensive and potentially hazardous emissions from Raymark Corporation formerly Raybestos East Main Street Stratford Raymark is a primary containing brake and gasket friction manufacturer of materials and one of the largest industrial users of asbestos in this state The facility is located in the center of densely populated residential areas of both communities Contiguous to the Raymark facility is the Stratford toll station on Interstate 95 Therefore in the absence of a viable effective and comprehensive asbestos enforcement policy by D.E.P. it would appear that the only alternative available othe. to protect our families and heighbors from the risks of asbestos exposure be an immediate ban on the use of asbestos in the manufacture of brakes With the understanding that economically and technically feasible as well as environ- mentally suitable substitutes are available the Milford Stratford Citizens Against Pollution fully support an ~ immediate ban on the use of asbestos in brakes We breathlessly await E.P.A.'s decision Stratford Citizens Against Pollution pp 1 2-3 A. EPA vs. OSHA as Regulatory Agency 21 In addition the only significant area where lives might possibly be saved is within the venue of OSHA and EPA must abrogate Sec 9 of TSCA to take authority there because OSHA already is acting on the problem Thus EPA has no authority to act in this matter John T. Barr p 4 EPA should 22 defer to the Occupational Safety and Health Administration on workplace regulation Asbestos Information Association p 1 23 The FMSI concerns relate to plant regulations versus control of general public exposure to asbestos dust While one agency has proposed to tighten worker exposure to asbestos another is being petitioned to eliminate asbestos in friction materials The disparity between these two situations could well create implementation and economic problems for friction materials manufacturers If asbestos is to be regulated out of friction materials the manufacturers should not be saddled in the meantime with compliance to new tighter regulations of asbestos in the workplace The industry must know which direction regulatory activity will take Friction Materials Standards Institute Inc. Att 1 p 2 B. Demonstration of Unreasonable Risk 24 Ambient levels of asbestos and the small contribution of brake materials to those levels do not represent an unreasonable risk to the public The use of constitute containing products does not an unreasonable risk to brake main- tenance workers The NRDC petition to ban the use of asbestos in brakes is not based on considerations of un- reasonable risk as required by TSCA but rather on an approach which advocates a zero risk standard for the statute Second AIA wishes to comment on a major omission in the December 19 response namely the complete absence of any mention of the potential health effects of substitutes for asbestos in brakes Any rational system of regulation in which the use of a material or substance may be prohibited for reasons related to an unreasonable risk of injury to health or the environment must include an evaluation of the risks resulting from substitute materials If this were not the case it would not be possible to say that any benefit had accrued to society as a result of a regulatory action Section C of the Toxic Substance Control Act TSCA specifically cites that substitutes for a substance must be given consideration in the context of section 6 rulemaking C the benefits of such substance or mixture for various uses and the availability of sub- stitutes for such uses While it may be argued that a consideration of the availability of substitutes does not necessitate a consideration of the health effects of the substitutes the immediately following section which lists additional factors to be considered would require an evalua- tion of substitutes health effects D the reasonably ascertainable economic consequences of the rule after consideration of the effect on the national economy small business technological innovation the environment and public health emphasis added Section D is explicit in stating that the environment and public health effects of a rule must be given consideration If a sub- stance is to be banned in favor of substitute materials Section 6 c D requires that the environmental and public health effects of such an action be considere andd such consideration would have to take into account the environmental and public health effects of the substitute materials Any other course of action would be ir- rational and not permissible under TSCA The entire Toxic Substance Control Act is framed within the context of reasonable regulatory action It does not permit the regulation of any risk but only unreasonable risk The intent of Congress in passing the Act is specific on this issue Section c of TSCA entitled Intent of Congress states It is the intent of Congress that the Administrator shall carry out this Act in a reasonable and prudent manner and that the Administrator shall consider the environmental economic and social impact of any action the Administrator takes or proposes to take under this Act Returning to the particular case in point the Agency comtemplates an action to ban the use of asbestos in brakes in favor of substi- tute materials The economic certain and substantial The effects of such an action would be benefits of such an action in terms of health effects are speculative and uncertain not only because they are of a magnitude that would not be detectable but also because no consideration is given to the health effects of the sub- stitute materials which have their own potential for harm Such an action could not be considered to be a reasonable one and would not be permitted under TSCA Asbestos Information Association pp 1-3 ) 25 OSHA now has an emergency temporary standard of 0.5 cc See 48 FR be reduced at some time in 51086 29 CFR 1910.1001 This will undoubtedly let's use that value for now OSHA has the near future but again concluded that at this new level 1.24 note the precision of the estimate of the workers will develop asbestosis and 1.7 will develop to some 25 who will die of cancer from other cancer. This compares factor of 10 for the thirds of causes and includes an elevation by a All in all it adds up to about a % the workers who smoke cigarettes because of this exposure or estimated increase in deaths of smokers 95 about 75 persons Of course OSHA uses the same exaggerated upper limit risk assessment which EPA does and which is known to overestimate the real value by multiple orders of magnitude see Hoel et al Science 219 1032 1983 However let's continue to play the game by your rules workers after all those who have Over the life of the next generation of are replaced the imposition of a ban experienced past higher exposures the current OSHA exposure limit will save the rather than reliance on This is using the risk lives of about 75 persons or about one per year estimate made by OSHA to justify the present temporary standard and assuming a lifetime exposure at the maximum level Now look at the 550,000 mechanics thiEsntesrhloiunled hparsoduscteateadn tehxactessthelyung are exposed at about 0.3 cc and that No of 0.375 See Session 1 p 28 in Banbury Report cancer death rate of Occupational Cancer Peto and Schneiderman eds, 9 Quantification 1981. At the temporary OSHA standard this wCooludldSpberinag 0H.a2r2b5or eLxacbeosrsataonrdy applied to 550,000 workers would be 18 lives per year over 70 years in the next generation of workers if EPA decides to throw aside Sec 9 of TSCA and use Sec 6 to This to brake linings a maximum of 19 lives per ban occupational exposure time in the next century would be saved using year starting some methods of calculation just for the sake of argument the agency's own this risk seems to Based on comments made in the NESHAPS rule on benzene be too small to warrant Federal regulatory action 49 FR 23558 JAPCA national to aboutMoving now to the public at large the ambient level of asbestos largely natural is about 1.5 ng See Enterline 33 317 1983 Enterline says that this is a total cancer risk of 102 x 10 The EPA gives a range of risks for exposure to ambient fibers in its Asbestos Health Assessment Update 8-84-003 table 6-1,2 Using the midpoint estimate for smokers there is a total added risk of 103 per 100,000 for a lifetime exposure 0.01 ml or 300 would females mto both males and At 1.5 mg this be about 0.5 per 100,000 or ^ 10 '. This is about 7 ^ 10 per year brake linings add or 17 per year for the entire United States However than % of this ambient asbestos according to the Notice so action _ less by EPA here will save 0.2 lives per year beginning some time in the the benzene test next generation Certainly this does not pass You will notice that we have used smoker data in these estimates An employee may claim that the employer caused exposure to asbestos but no employee may claim that the employer required smoking cigarettes The danger of smoking in general and in the presence of asbestos in particular is sufficiently well known that there is no excuse for an employer bearing the added burden of the risk caused by an employee's smoking John T. Barr pp 2 3 III HAZARDS ASSOCIATED WITH ASBESTOS USE IN BRAKES A. Epidemiological Evidence and Case Reports 26 Studies have demonstrated that individuals working with insulation asbestos have five times the risk of acquiring lung disease compared with the risk faced by the general population McDonald Malignant Mesothelioma in North America Cancer 1650-1656 1980 The McDonald study which reviewed occupational risks associated with malignant mesothelioma for 668 cases in North America recorded in the late 1960's and early 1970's reflected the following relative occupational risks compared to matched controls Insulation 46 X Production and asbestos manufacture 6x Heating trades Shipyards Construction x 3x 3x Other Garage workers Maintenance Transportation Industry 1x 1x 1x The mortality study conducted by G. Berry and M.L. Newhouse is also critical in weighing the risks associated with the continued use of asbestos in brake applications Newhouse Mortality of Workers Manufacturing Friction Materials Using Asbestos British Journal of Industrial Medicine 1983 1-7 The study conducted over the period 1942 to 1980 was carried out with respect to 13,460 workers of a factory producing friction materials The only type of asbestos used was chrysotile except for two periods before 1945. The report concluded that Compared with national death rates there were no detectable excesses of deaths due to lung cancer gastrointestinal cancer or other con- cerns The experience at this factory over a 40 year period showed that chrysotile asbestos was processed with no detectable excess mortality Wagner Division Att 1 pp 4-5 27 The introduction of the NRDC petition emphasizes that the link between asbestos exposure and cancer has been conclusively demonstrated by epidemiologists since the early 1950's While this may be true for certain occupational exposures of sufficient length and quantity no association has been demonstrated between exposure to brake dust and cancer There is no evidence in the medical literature demonstrating any significant risk from either brief or term exposure to friction products D. Automobile Maintenance Workers Are At Particular Risk From Exposure To Asbestos Brake Products This section argues that because of the airborne mobility of these small asbestos fibers from brake linings a diverse group of people are at risk The petition includes garage mechanics bystanders tool booth operators families of mechanics and persons living in urban environments as the population at risk The are only two two case mesothelioma citations upon which this argument is based reports which purport to in a pet whose owner was document a a mechani1c5 and a brake mechanic's latter case is not footnote indicates child who had mesothelioma a published case report but the that this was communicated in a The letter from Barry Castleman to a person or persons unknown One case report of a pet and a letter from Barry Castleman are scant support for the sweeping statements made in this section This section concludes by alleging that recent literature also documents mesothelioma among automobile repair workers Greenberg's 1974 The first report 17 literature cited is which found one mesothelioma death in a motor mechanic Greenberg gives no occupational history for the mechanic The other case report cited is that by Langer in 1982 Support for the proposition that there are two additional mesotheliomas in brake mechanics is allegedly found in Castleman's recent book on asbestos and a personal communication by Susan Daum to Castleman Yet important data on these cases are missing such that verification is not possible from these sources alone Thus there are only two cases of mesothelioma in all of the reported medical literature which allegedly implicate brake dust One of those Greenberg is questionable Motor Vehicle Manufacturers Association Att 1 pp 1 2 4-5 28 The Institute does not have epidemiological data to challenge the evidence associating asbestos with lung cancer and mesothelioma We do wish to point out however that the most complete study of the linkage of asbestos to cancer in a friction materials factory concluded that there was no incidence of lung cancer in the friction materials cohort so exposed that any incremental occurrences of mesothelioma were demonstrated in higher and those exposed also to crocidolite asbestos Motor Vehicle Manufacturers Association Att 4 p 2 B. Health Effects of Chrysotile Fiber vs. Other Fiber Types it Chrysler Corporation recognizes the fact that exposure to certain levels of the 29 be a health risk However is generally agreed that asbestos fiber can is on the type of asbestos fiber The only type used in degree of risk dependent which has been shown to be the the manufacture of brake linings is chrysotile least hazardous of the various asbestos forms Chrysler Corporation p 1 30 We would also like to point out that the statements by NRDC regarding the risks associated with asbestos fail to take into account the distinction between insulation asbestos which is not involved in brake application and chrysotile fibers which are Wagner Division Att 1 p 4 31 While is . a demonstrated human carcinogen that that asbestos evidence exists that cancer and other lung disorders of different forms of asbestos varies substantially it is known causes lung the toxicity Two studies both of which entail extensive surveys of in the toxicity of various current literature Bfootuhnd foduinfdfercernocceisdolite to be the most toxic forms of asbestos We have included the comments and chrysotile to be the least of asbestos should be made to OSHA because ditfhfeeroivnegraltloxiecviatliueastion of the risk posed by considered as part of exposure Motor Vehicle Manufacturers Association p 2 32 The assertion is made that animal inhalation studies demonstrate no significant difference in the effects of various types of asbestos NRDC cites a 1974 study by Wagner as authority for that statement The petition subsequent neglects to point out that numerous experiments including the work of Gross 4,5 animal demonstrate precisely the opposite These latter studies type of would tend to asbestos used indicate that in brakes is chrysotile the only significantly less pathogenic than other types of asbestos fibers Motor Vehicle Manufacturers Association Att 1 p 2 33 Chrysotile asbestos is the only asbestos type used in brake linings manufactured in the United States We are aware of only one manufacturer using anthophyllite in a specific clutch application To the best of our knowledge crocidolite and amosite are not used by any United States manufacturer of friction materials A most graphic illustration of the lack of lung cancer for the friction materials manu- facturing cohort is shown in publication of the Newhouse paper in the British Journal of Industrial Medicine Mortality of Workers Manufacturing Friction Materials Using Asbestos Refer to the Newhouse report cited as Ex 84-021 in the Emergency Temporary Standard page 51114 of November 4 1983 FEDERAL REGISTER Motor Vehicle Manufacturers Association Att 4 p 2 34 A. OSHA Should Recognize Differences in the Toxicity of Various Forms of Asbestos The proposed OSHA standard would adopt either a 0.2 or a 0.5 fibres per cubic centimeter cc permissible exposure limit PEL for all forms of asbestos Substantial evidence exists that the toxicity of different formosf asbestos varies substantially In March 1976 the British Health and Safety Commission formed an advisory committee on asbestos with the following charge To review the risks to health arising from exposure to asbestos or products containing asbestos including persons exposed at work members of the public exposed to asbestos generated from work activities members of the public exposed to asbestos from consumer products and from asbestos waste to make recommendations as to whether any further protection is required The Committee's report would be for the consideration of the HSC and Ministers and would be published 1 The advisory committee conducted an exhaustive study surveying existing literature and soliciting the testimony and reports of experts in fields related to asbestos The final report of the advisory committee discussed the relative potency of various forms of asbestos in producing lung cancer in man Evidence in man about the relationship of fibre type to lung cancer is inconclusive but where it exists it indicates that exposure to amphiboles crocidolite or amosite or to mixtures with chrysotile rich in them has been more dangerous than to chrysotile or anthophyllite alone Table 15 However as important gaps in our knowledge of this aspect of the field remain unanswered the weight which can be attached to this conclusion at present is limited The referenced Table 15 appears in this comment as Figure 1. Concerning asbestosis in man the advisory committee's report states Quantitative evidence about impairment of lung function in man in relation to fibre type is limited to one study which suggests that crocidolite may have been more harmful than chrysotile 3 FIGURE 1 per cu ft Table 15 see Vol 2 Table 21 Relative risk of death from correctedcor ected for differenceisn cancer by type of fmiiblrleion particlesparticles years After respiratory cumulauve dust exposure in Enterline and Henderson 1973 Type offibre Respiratory cancer deaths Average cumulative dust exposure Relative risk adjusted for cumulative dust exposure = 330 272 Amosite only 39 244 272 Chrysoule only Amosite chrysotile am 266 272 Chrysoule and 10 crocidolite Amosite chrysotile and crocidolite 2922 208 22 273 22 2922 Any amosite Any chrysotile 2922 Any crocidolite 2922 286 22 244 22 229 : Concerning mesothelioma in man the report states As far is mesothelioma is concerned evidence from miners from process workers exposed to a single fiber type from the distribution of neighbourhood and domestic cases and from the geography of mesothelioma when combined presents a powerful case from four different sources that crocidolite has been more dangerous than chrysotile and anthophyllite The position of amosite may be intermediate between crocidolite and chrysotile 4 In addition to these findings the advisory committee recommended control limits for various types of asbestos as follows chrysotile cc amosite cc and crocidolite cc In addition the advisory committee recommended a statutory ban on the importation of raw crocidolite fiber.5 More recently the Canadian Province of Ontario formed a commission similar to the British Advisory Committee to investigate the health consequences of asbestos The Commission established in April 1980 went to great lengths in its comprehen- sive evaluation of asbestos This involved by way of illustration either personally or through their staff visits to Quebec asbestos mines to the Mount Sinai School of Medicine in New York to Ontario manufacturing establishments and to asbestos removal projects In addition it undertook a research program which yielded two background papers and ten length research studies Testimony alone before the Commission produced 8,378 pages of transcript and the Commission's report comprises three volumes in excess of 900 pages Among the conclusions of the Commission were the following 4. There is strong evidence that crocidolite and amosite fibres tend to be more hazardous than chrysotile fibres primarily because they are more likely to conform to the most hazardous length and diameter and secondarily because they are more likely to become airborne and hence to be respirable It is also possible that crocidolite and ^mosite are more hazardous because of their chemical compo- sition but this possibility rests in the realm of speculation 5 All fibre types can cause all asbestos diseases but mesothelioma is most likely to result from crocidolite exposure has a strong association with amosite exposure and has a weak association with chrysotile exposure III 6. Whatever their type the likelihood that asbestos fibres of the most hazardous dimensions are respirable is strongly a function of the individual process in which asbestos is being used Thus for example the manufacturer of brake linings which involves drilling and grinding is much less likely to generate fibres of hazardous dimensions than textile manufacturing which involves spinning and weaving 6 Elsewhere the report states On the basis of this analysis we conclude that we cannot condone any manufacturing activity that involves the use of crocidolite or amosite asbestos The use of these two types of asbestos in Ontario should therefore be prohibited indefinitely As for chrysotile it is necessary to distinguish the industrial processes in which asbestos is | being used The control limit that the Regulation Respecting Asbestos currently applies to all chrysotile processes is 1 cc If this control limit is rigorously observed so that at the level of an hour weighted average it is rarely exceeded we calculate that the average level of exposure to which workers will be subjected is no greater than 0.5 cc Our data base permits us to calculate the disease risk encountered by workers in the following industrial processes mining and milling general manufacturing excluding textiles and cement products III textile manufacturing and cement products manufacturing We find in the cases of chrysotile mining and milling and of general chrysotile manufacturing that the disease risk associated with chrysotile exposure under a 1 cc control limit effectively enforced involves a projected mortality rate well below the mortality rate that results from industrial accidents in all Ontario manufacturing It therefore falls well within the bounds of societally acceptable industrial risk Thus these two comprehensive studies both of which entail extensive surveys of current literature found differences in the toxicity of various forms of asbestos Both found crocidolite to be the most toxic and chrysotile to be the least These same conclusions are reflected in foreign occupational health standards studies This is apparent if one refers to Permissible Exposure Limits of Foreign Countries in 1983 Table 2 in the preamble to the proposed OSHA standard 49 FR 14135 Britain Finland Ontario Canada Sweden and the European Economic Community all have which apply the most stringent limit occupational health standards to crocidolite and the most lenient to chrysotile Motor Vehicle Manufacturers Association Att 2 pp 1-6 C. Asbestos Release from Brakes - Properties Amounts and Toxicology 35 Renault agrees that certain a threat when released into types of asbestos consist of fibers which pose the atmosphere but the asbestos dust emitted by wear of the brake linings is never found in this form Provided that certain basic precautions are especially during replacement installer taken the handling of asbestos brake linings installation is also without danger to the Renault USA Inc. p 2 . 36 the physical and chemical characteristics Moreover there is evidence that of the material released to the atmosphere as brake linings wear are not asbestiform in nature Research conducted by the National Institute for Occupational Safety and Health NIOSH has indicated that this material is predominantly a thermally degraded compound and is almost entirely fibrous Until there is better evidence that the material released the EPA during should braking is indeed asbestiform in impose a regulation prohibiting naturwee do not believe that the use of asbestos in motor vehicle brake linings Chrysler Corporation p 1 37 Health Risks From Asbestos Brake Products This section begins by asserting that brakes create substantial exposures to asbestos which constitute a serious health threat not only to brake workers but to the general public No scientific basis is referenced for this broad statement The petition asserts that numerous studies have shown that a fraction of process The reader asbestos fibers survive the of this sentence might draw braking the conclusion that this fraction is a significant one The petition neglects to indicate that the three principal studies the subject indicated precisely the opposite Anderson found less than .02 percent of the fibers survived the friction process Lynch found less than 1 percent and Jacko found less than .3 percent More than 99 percent of the formed in the friction process into nonfibrous dust fibers are transa nonasbestos This section stresses the ambient air particularly levels are increasing A danger of asbestos fibers in in urban areas where asbestos private letter from Dr. Wm Nicholson of Mt. Sinai New York City is cited as authority for the proposition that asbestos content in ambient air is this from increased automobile brakes This conclusion is not based upon any published evidence In fact there are several references , which indicate that less than 1 percent of asbestos fibers in city core districts originated from disc brake wear The petition discusses the Jacko Bendix study 9 and cites it for the proposition that American vehicles release approximately 158,000 pounds per year of asbestos into the atmosphere This misrepresents Jacko's findings 158,000 pounds represents the total estimated asbestos emissions potentially produced from brake linings by the friction process Only 3.2 percent or 5,060 pounds of that was found by Jacko to be airborne asbestos fibers 85.6 percent of the asbestos emissions do not remain suspended and dropout from the atmosphere This section goes on to discuss Rohl's 1976 study on the asbestos content of brake dust It notes that Ronl found that more than 80 percent of the surviving fibers were 0.4 micron in length but fails to mention that such short fibers are considered by many medical authorities not to be pathogenic respected at all 11 12 12 This section of the petition concludes with the sentence that the problem of exposure to dangerous levels of asbestos during brake servicing is substantial and that he small asbestos fibers from brake wear can easily penetrate throughout the respiratory system and also migrate to other organs in the body The conclusion is not supported by studies which indicate that the smaller fibers present during brake servicing are less likely to be deposited in (the10 lu1n1g and macrophages more likely to be removed by Motor Vehicle Manufacturers Association Att 1 pp 3-4 38 II RESEARCH DATA AVAILABLE IN JAPAN ON ASBESTOS FIBER DENSITY The results of research into the asbestos fiber density in the atmosphere are reported in the U.S. Similar research has also been carried out in Japan One representative study which has been released to the public is that carried out by the JAPAN AUTOMOBILE RESEARCH CENTER This study measured the asbestos fibers content in worn powders by means of a bench brake test It complements test results already conducted on 142 samples for general environmental conditions and the labor environment The results are as follows a The asbestos fibers content in the brake is 60 Gravity ratio while that in worn powders is 0.12 Gravity ratio b The asbestos fiber density in the atmosphere under general environmental conditions indicates a density of 0 - 0.46 pieces The measurements were obtained in the following areas intersecting points in Tokyo metropolitan city at tollgates on highways and other general urban districts The asbestos fiber density in the labors environment indicates a density of 0.27 TTT 10 pieces which represents a close approximation to the general environment although it is concerned only with one repair shop The asbestos density in the environment obtained in this study indicated a very low value when compared with that of an asbestos density standard in a dusty environment 2000 pcs Director of Labor Standard Bureau No. Circular 408 Therefore it is concluded that under those circumstances no serious problems exist The asbestos fibers mentioned represent fibers with a length greater than Sum and have a length to diameter ratio equal to or greater than 3 to 1 Japan Automobile Manufacturers Association Att 1 pp 1-3 III 39 The use of asbestos in brakes may result in higher levels of asbetos fibers in the ambient air Asbestos is a demonstrated human carcinogen causing lung cancer if the human being exposed to it is not adequately protected Classic Cars of Ponca City p 1 40. In their report Monitored Asbestos Concentrations in Connecti- cut Bruckman and Rubino describe an ambient air asbestos survey which was conducted between 1974 and 1977 order to define the magnitude of the health hazard posed by asbestos fibers in Connecticut The report cites airborne a fold increase in the asbestos mesothelioma incidence rate in Connecticut since 1940 The data was collected in an effort to promulgate a numerical standard for ambient asbestos concentrations since in the judgment of the Connecticut D.E.P. a no visible emission asbestos air quality standard does not provide the State's residents with an adequate degree substance of protection from this carcinogenic the proposed numerical standard of 30 ng was Incidentally never promul- gated Bruckman 10 ng and Rubino reported urban and rural day average values below locations removed from known stationary sources of asbestos emissions However near each of the industrial users of asbestos values above 30 mweredetected For the three toll stations moni- tored those two removed from industrial asbestos users were elevated 10-25 m , but the Stratford toll station showed a day average of 41 ng with traffic nearly identical to one of the other toll stations monitored Certainly the heightened asbestos concentration at the Stratford toll cannot be attributed only to braking vehicles In their report Bruckman and Rubino noted that this highest measured con- centration for the entire survey was recorded at the monitor- ing site located adjacent of the largest industrial to an users urban toll station of asbestos in the and one state Raymark has been cited three times in the past eighteen months by Connecticut State Department of Environmental Protection personnel for asbestos emissions violations of the Federal N.E.S.H.A.P. Amendment to the Asbestos Standard Copies of these notices of violation are enclosed for your information Inasmuch as our group contends as do Bruckman and Rubino that the Federal asbestos standard of no visible emissions to the unaided eye is inadequate to protect the public then certainly repeated asbestos emissions violations by Raymark comprise a tangible threat to the health of all residents living in the vicinity of Raymark's manufacturing facility These periodic visible asbestos emissions violations in conjunction with not visible fugitive dust emissions which most certainly occur as a result of poor maintenance careless handling procedures and innate efficiency restrictions on Raymark's dry dust collection system combined with airborne asbestos fibers resulting from braking vehicles at the Stratford tolls expose residents of Stratford and Milford to an unreasonable even dangerous degree of risk Stratford Citizens Against Pollution pp 1-2 TIT22 TIT22 TIT22 IV SUBSTITUTES <++ A. Emcor 66 1 Applications and Performance 41 Engelhard manufac- tures EMCOR 66 mineral composition a very effective replacement for asbestos in friction products for automobile truck and railroad brakes PERFORMANCE CHARACTERISTICS OF EMCOR 66 For the friction industry more than just the health and safety aspects of asbestos are motivating asbestos substitution Although any substitute used must also be proven to be safe improved performance is another key issue Driven by pressure to reduce component weight and size automobile manufacturers are designing braking systems lighter and smaller As a result the friction surface must withstand higher application pressures and temperatures Engelhard manufactures EMCOR 66 ultra fibers with the specific requirements of the friction industry in mind EMCORfi66 ultra fibers offer a lower volatile matter content than asbestos and therefore offer greater heat stability The oil absorption of EMCOR 66 is equivalent to the grades of asbestos used in friction compounds The abrasion and hardness rating of EMCOR 66 Moh hardness -- which should be lower than that of the metal surface on which the brake lining engages is lower than virtually all other including asbestos Unlike organic components in friction compounds some other substitute materials EMCOR 66 does not cause high noise levels or unusual brake wear Engelhard Corporation pp 1-2 2 Commercial Availability 42. Present reserves of American attapulgite are sufficient to meet market demand for use in brake systems for at least the next 40-50 years There- fore a consistent term supply of this material should be available to the friction industry Engelhard Corporation p 2 TIT 2 3 Cost 43. Finally it is less expensive than other substitutes Engelhard Corporation p 2 4 Health Effects 44. SUMMARY OF HEALTH RESEARCH CONDUCTED ON AMERICAN ATTAPULGITE SUMMARY SUMARY OF HEALTH RESEARCH CONDUCTED Background American attapulgite is a sorptive mineral which has been mined and processed has been in and around Attapulgus GA since 1920. American used commercially for over 60 years in a wide attapulgite variety of applications including as an adsorbent and thickening agent and recently has been introduced as a replacement for asbestos friction materials American attapulgite is composed of ultra fibers Samples of American attapulgite were analyzed for particle size by the National Institute for Occupational Safety & Health NIOSH and found to have an average length of only 0.5 micrometers um In fact over fifty percent of the particles were found to be less than 0.4 km in length The very longest single fiber measured was only 2.5 ...m In contrast material from some other parts of the world which have similar chemical composition and crystalline structure have dramatically different particle morphologies and in particular substantially greater particle lengths For example attapulgite from Torrejon Spain was found to range between 2 and 8 ...m in particle length with an average length of 3.5 ...m In addition 62.5 percent of the Russian material called palygorskite after the Ural mining district where it is located was shown to be longer than 2 ...m30 percent of this material was found to be longer than 5 ...m To our knowledge all attapulgite used in this processed domestically in and around the town of fore all attapulgite encountered in the U.S. is country is Attapulgus composed of mined and GA Therevery short particles similar to those which were studied by NIOSH As many prominent scientists as well as government agencies believe that the potential health hazard of a fibrous material is determined by the number of long particles on other longer than 5 ...mpresent in the material any health research longer materials is applicable to either American attapulgite or the American environment TIZ A Health Effects Research on American Attapulgite NIOSH has been conducting both mortality and morbidity studies of American attapulgite workers since 1975. Its research has involved more than 2,300 workers mining and processing attapulgite since 1940. We understand that reports of these studies will be issued within the next 12 months NIOSH has informally advised Engelhard Corporation that exposure to its attapulgite was not found to be associated with either cancer or fibrogenic lung disease and that there was no relation between pulmonary function and cumulative dust exposure In addition the research of eminent American and European scientists conducting independent experiments on laboratory animals and cell simulations have been reported to confirm that American attapulgite is neither carcinogenic nor fibrogenic For example Stanton's animal implantation work showed that the rate of tumorigenesis for two samples of American attapulgite was not different than that for negative controls More recently Prof. Pott of the University of Dusseldorf Medical Institute for Environmental Hygiene who has studied Russian palygorksite French attapulgite and American attapulgite has shown that only the long Russian palygorskite was tumorigenic in laboratory animals The American and French attapulgite both of which are short were found not to be different than the negative controls Although this information has not yet been published Dr. Pott has provided the results of his research on American attapulgite to NIOSH and is committed we understand to publishing these results in the near future Further in evaluating a life span animal 1 percent and 3 percent attapulgite Prof. Toxicology in Heidelberg West Germany evidence that attapulgite was carcinogenic feeding study using mice and D. Schmahl of the Institute of concluded that there was ---- Looking at the in vitro effects Lipkin of the National Cancer Institute studied the effect of French and American attapulgite on macrophage cells Using several samples of attapulgite Lipkin found the results to be uniformly negative i.e. there was no evidence of cell toxicity as measured by reduction in cell number over a hour period in any of his experiments He has also shown that this cell model correlates well with the in vivo studies conducted by Dr. Merle Stanton Likewise Woodworth Mossman and Craighead of the University of Vermont who studied the ability of attapulgite and other minerals to cause metaplastic changes in the tracheal mucosa of the Syrian hamster found American attapulgite not to be statistically different than negative controls In sum the available epidemiological and experimental data concerning potential health effects of American attapulgite all of which was developed by researchers independent of Engelhard uniformly indicates that American attapulgite is not carcinogenic or tumorigenic and does not cause pulmonary dysfunction TIZ Based upon the foregoing discussions on the effectiveness and safety of one asbestos replacement we believe that testimony to the contrary presented by certain individuals is unsubstantiated incorrect and very misleading In particular we take great exception to the comments of Mr. E.W. Drislane of the Friction Materials Standards Institute Inc. On Page 3 of a letter to the made the following statement EPA dated November 13 1984 Mr. Drislane Sufficient data is not materials to state that place environment or to available at this time on the they do not pose a hazard in the general public substitute the work- As discussed earlier this statement is simply not true for American attapulgite On the same page of his letter Mr. Drislane quotes a reference from the 1984 Report by the Royal Commission on Matters of Health and Safety Arising From the Use of Asbestos In Ontario.8 That quote as well as other sections of the Royal Commission's report clearly reaffirms the wellrecognized concept that hazards of asbestos are related to particle length longer than 5 ...m As discussed here earlier American attapulgite is composed entirely of particles much shorter than this minimum critical length A second quotation referenced by Mr. Drislane which was made by Dr. Pelnar of the Institut De L'Amiante The Asbestos Institute in Quebec Canada alleges that attapulgite is one of several fibrous materials which contain fibers longer than 8 ...m and which have caused mesothelioma in laboratory animals This is a reference to Dr. Pott's 1974 study of Russian palygorskite - a much longer fiber material of no commerical value -which cannot be associated with American attapulgite As discussed earlier Dr. Pott's more recent study with American attapulgite demonstrated that Engelhard's material does not cause mesothelioma Therefore we believe that Mr. Drislane's conclusion that There are legitimate questions on the health hazards of the fibrous substitutes suggested for asbestos replacement in friction materials is unsubstantiated and highly misleading Engelhard Corportion urges the EPA to seriously question the validity of these remarks Likewise in a letter submitted to the EPA by Dr. Arthur M. Langer dated December 7 1984 Dr Langer asks Where are the data to show that substitute friction product materials are safe From the information supplied earlier we believe this data does indeed exist for American attapulgite IV Another inaccuracy is contained in a letter dated November 28 1984 in which B.J. Pigg submitted to the EPA comments by the Asbestos Information Association AIA On Page 20 of these comments the AIA states that the Danish government has established an fiber regulatory standard to assure that any fiber use is closely controlled Dr. Schaich Fries of the Danish National Institute of Occupational Health has informed Engelhard that the Danish Government does not in fact consider our attapulgite a fiber regulated similarly to asbestos We hope the EPA will recognize this distinction as well American attapulgite does not share the hazardous properties of asbestos CONCLUSION Engelhard urges the EPA to question seriously asbestos product representatives serving allegations that asbestos substitutes have not received adequate testing and scrutiny or that attapulgite carries the same health hazards as asbestos Engelhard believes that American attapulgite has been thoroughly tested and evaluated and does not represent a hazard similar to that presented by asbestos and Engelhard has submitted the record on American attapuglite In tion presented here on the performance these comments in addition we hope of EMCOR 66 as a order to clarify that the informafriction material component in brake linings will reassure the EPA that feasible substitutes do indeed exist Engelhard Corporation pp 2-7 Experience 45 EMCOR 66 ultra fibers have been evaluated purchased used commer- cially and recommended by firms worldwide that produce either friction compounds or raw materials for the friction industry There are several firms in Europe that actively purchase and use EMCOR 66 in automotive friction compounds In the United States Friction Company Incorporated Trenton NJ has approved 2 containing EMCOR 66 ultra fibers for a Ford Division Products friction compound Motor Company OEM Original Equipment Market automotive brake Chemicals Incorporated Schenectady NY a leading resins to the friction industry recommends EMCOR 66 lining Schenectady supplier of phenolic ultra fibers to its customers Manufacturers of such diverse friction products as friction papers for heavy equipment wet brakes and elevator brakes have approved and now purchase EMCOR 66 ultra fibers Engelhard Corporation p 2 IV B. Phosphate Fiber TV8 1 Applications and Performance 46. Monsanto Company is developing Phosphate Fiber a novel crystalline fiber form of calcium sodium metaphosphate The physical properties of Phosphate Fiber suggest it will be useful as a reinforcing fiber in friction materials and other composite products We have introduced Phosphate Fiber samples to the worldwide friction industry for the purpose of evaluating this product's effectiveness and market potential While these evaluations are still in progress early indications prove valuable as a full or in brake compounds are that Phosphate Fiber will partial replacement for asbestos EFFICACY IN FRICTION MATERIALS Monsanto has developed and tested prototype friction compounds containing Phosphate Fiber In addition friction material manufacturers around the world have completed some of the evaluative studies required to prove the cost effectiveness of Phosphate Fiber in brakes Manufacturer testing has included bench and pilot scale compounding trials bench performance tests ( on so called Chase or FAST machines full scale dynamometer evaluations and performance trials using instrumented test automobiles This work has demonstrated the following performance advantages for friction materials containing Phosphate Fiber - Compound Processing Phosphate Fiber compounds are easily processed using typical existing manufacturing equipment The fiber is compatible with the full range of friction compound ingredients It is homogeneously dispersed in the finished compound resulting in low performance variability among batches - Thermal Resistance Phosphate Fiber maintains fibrous morphology and its native properties up to a temperature of 740 C 1365 F It is therefore more thermally stable than glass fiber aramid fibers and chrysotile asbestos Phosphate Fiber should provide reinforcement in the brake compound even at the higher temperatures experienced under severe braking conditions - Durability Friction materials containing Phosphate Fiber exhibit excellent cured strength and acceptable uncured or . green strength Brake durability in the tests completed to date has been adequate - Friction Performance Brake compounds made with Phosphate Fiber have exhibited friction levels in the desired range friction coefficients between .2 and .5 More importantly the friction coefficients of these compounds are stable over a broad temperature range and show controlled fade at elevated temperatures Monsanto Company pp 1-4 2 Commercial Feasibility Availability 47 Monsanto operates a pilot facility for the purposes of process development and production of typical Phosphate Fiber samples to support industry evaluations Pilot plant capacity is adequate for satisfying initial market development requirements A larger interim commercial Phosphate Fiber plant is proposed for 1987 or 1988. This plant will be located in the United States and will have production capacity of up to 5 million pounds per year As market demand for Phosphate Fiber grows we plan to make additional investments in worldwide capacity Monsanto Company p 2 10 3 Cost 48 Monsanto's pricing plan for Phosphate Fiber is not formally established However we estimate that Phosphate Fiber market price will be in the range of $ to 2 per pound Interim commercial product price will fall in the upper end of this range As this business grows Phosphate Fiber price will tend toward the lower end of this range Monsanto Company p 2 4 Health Effects 49 Phosphate Fiber is composed of polyphosphate chains Polyphosphates are known to be hydrolyzed in living systems via enzymatic mechanisms While the Phosphate Fiber product contains some fibers in the respirable size class these fibers should be hydrolyzed by living cells Thus Phosphate Fiber should exhibit important health advantages compared to other biologically durable organic and inorganic respirable fibers Monsanto is undertaking an extensive biological testing program prior to full commercialization establish that the health safety risks associated with Phosphate Fiber are acceptably small The main tests included in our safety as- sessment program are - 2 Year Intrapleural Implant in Rats - 2 Year Chronic Inhalation in Rats - 6 Month Tracheal Instillation in Rats Monsanto Company p 2 TIZ 11 C. Carboflex IV 1 Applications and Performance 50 We wish to call EPA's attention to the availability of and to the possible use of low cost low modulus industrial grade carbon fibers as a suitable substitute for asbestos in automobile and truck brakes Carbon fibers have been evaluated and are being used in brake applications for aerospace military and commercial aircraft racing cars road vehicle and industrial and now to some extent in automotive uses in proprietary formulations Here carbon fiber properties of high strength wear resistance good frictional properties good binding qualities high conductance high thermal stability oxidation resistance and low weight them most attractive carbon fiber composites are considered the good heat make material brakes of choice for high performance military and commercial aircrafts Ashland's contacts in brake manufacture also indicate that carbon fibers can and are competitive to an extent with asbestos performance and that neither retooling or special processing techniques would necessarily be required to permit substitution of carbon fibers for asbestos Ashland Petroleum Company pp 1 2 51. Carbon fibers are materials currently used in a number of industrial applications calling for high strength and low weight Examples of its use today include graphite tennis rackets golf clubs and aircraft parts However growth of this market has been limited by the cost of producing high performance fibers used in these applications Ashland's carbon fibers are produced at considerably lower cost and are intended for general applications where specifications are less severe This production breakthrough should help the market expand 1313 Anticipated new markets for general purpose fibers include fillers for polymers engineering plastics brake linings high temperature thermal and sound insulation other temperature applications replacing asbestos automotive parts construction materials carbon fiber composites and a variety of military applications Ashland Petroleum Company Att 1 pp 1-2 2 Commercial Availability 52 Ashland presently has the capability of producing 30 year of general purpose carbon fiber GPCF and will expand production to 100 year in the fall of 1985 Ashland Petroleum Company p 1 3 Cost 53 Ashland's carbon fibers are marketed under the tradename lengths CARBOFLEX range in price from 10 to 12 nonwoven mat chopped 1/8 to 1/2 per pound and come in the forms of , and ground or milled 100 to 400 microns average length In the past the unavailability of low cost fibers has been a deterrent to their exploitation in automotive brake applications although in brake pad formulations we understand that the amount of fiber is rather low in composition Because we manufacture a proprietary raw material from which we produce our fiber and which is sufficient to produce up to 50 million pounds per year of fiber the potential exists for an even less expensive fiber if produced in much large volumes Ashland is dedicated to a continuing effort of further improvements in cost performance so as to enhance the effectiveness of carbon fiber Ashland Petroleum Company p 1 D. Kevlar Aramid 1 Applications and Performance 54 Kevlar was first introduced by E. I. du Pont de Nemours & Company in 1972 with an initial investment commitment of more than 500 million U.S. followed by a 200 million U.S. expansion program in 1982-83 The patented fibre is five times as strong as steel and 10 times as strong as aluminum on a pound for pound basis yet its density is 43 lower than fiberglass The high temperature stability strength and insulation characteristics of Kevlar have made it the preferred product in many applications where asbestos replacement is sought Among them are transmission clutch facings brake linings gaskets tires conveyor belting and high temperature resistant apparel Two years ago after an extensive development program and with the help of Du Pont Canada Canadian Metallic launched a premium line of Super brake linings which proved to last up to four time the life of conventional asbestos linings Some trucks have clocked more than 200,000 miles on Novas with a wear of less than 0.10 inch per 100,000 miles says Anderson Now Canadian Metallic has launched its Nova II asbestos brake linings The Nova II incorporates a lesser amount of Kevlar and is designed particularly for truck fleets whose owners are concerned with environmental problems related to asbestos and who want linings that will last longer says Beri The new linings were subjected to demanding field tests before market introduction We placed test sets on underground scoop trams used by a Sudbury mining company where the brakes would be innundated with water and sticky mud So far they have more than six months of continuous service with no problems says Anderson TXX 16 Overall Canadian for the Nova II Metallic is confident of excellent customer experience line Field testing shows for instance that brake drums are left unscored after up to 100,000 miles of use Du Pont Canada Inc. Att 2 pp 2 3 4 55 And that's precisely why an Arrow Bulk hauling rig was selected in 1983 as test application for new SuperNova asbestos brake blocks Developed by Canadian Metallic Brake Ltd. for use on trucks and heavy road equipment these asbestos brake blocks are com pounded of special resistant resins and reinforced with Du Pont Kevlar aramid fiber along with other high ity friction materials A Better Brake Block The SuperNova is a premium brake block that conservatively offers at least eight times the performance life of conventional asbestos brake blocks boasts Michael Beri president of Canadian Metallic It also delivers twice the brake life of metallic blocks and doesn't score the brake drums the way metallics generally do In all respects it's the enduring performance brake block we set out to formulate five years ago It was 1980 that Beri began focusing on Kevlar an aramid fiber marie only by Du Pont as the reinforcing core of a performance lasting brake block The high track record of Kevlar demonstrated strength low weight abrasion resistance and outstanding thermal properties in applica- tions ranging from aircraft and rockets to boat hulls and protective body armorsuggested a promising candidate for friction products subjected to intense heat and pressure Following two years of try- ing and testing formulations Canadian Metallic went commercial with its SuperNova brake blocks in October 1982. An early priority was to demonstrate the brake superiority of the new blocks through comparative data generated in the field * Hayes Inc. a supplier of truck trailer axle components was signed on as major Canadian distributor for the new asbestos brake blocks Doug Angus ' of Hayes supplied SuperNova blocks to a number of trucking opera- tions for field tests In April 1983. SuperNova brake blocks were mounted on the two drive axles of one of Arrow Bulk's Kenworth tractors and on the three axles of a Knight dump trailer New Kelsey brake drums also were installed at the start of the trial Four times each day this rig made the journey to the Ashcroft siding and back After eight weeks of serv ice reports Jones a visual inspection re- vealed that the blocks still had 75 percent useful lining life remaining At this point he adds three or four replacement sets of asbestos blocks would have been in- stalled due to block disintegration Blocks Drums Fine At 12 Weeks Hubs and drum assemblies were pulled at 12 weeks No disintegration of the SuperNova blocks close to 50 percent of lining life remaining drum sur- faces smooth with no scoring With metallics says Jones we'd have been replacing both blocks and drums by this time The SuperNova blocks were fine so we put them back on the wheels . to see how long they really would last In January 1984 nine months and 65,000 miles after the start of the trial the center axle wheels on the trailer were realigned No new blocks or drums were required In February with 72,000 miles logged all four truck wheels were realigned Brake blocks and drums still were compatible and serviceable It wasn't until April 1984 after 90,000 miles of hauling that Arrow Bulk finally re- placed the brake blocks and drums on the rear axles of the trailer In addition to extended performance life brakes reinforced with Kevlar 1 recover well with controlled fade 2 help minimize cracking around rivet holes 3 won't glaze or smear because Kevlar doesn't melt as glass fiber does and 4 won't rust since Kevlar is nonmetallic Du Pont Canada Inc. Att 1 pp 2-4 56 Canparts Automotive International Ltd. a Cambridge Ontario manufacturer of automotive disc brake pads has developed a line of replacement products which wear like semi- surfaces metallics but are not detrimental to rotor The brake are reinforced with Du Pont's Kevlar aramid fiber segments Integrally molded pads for imported cars have passed a year of extensive field trials Based on their experience with the molded pads the company is now expanding to drilled disc pad segments for domestic cars - <<- a ~*~ Improved performance has made the reinforced product successful says Canparts president Bill Bartels We've sold more than 300 000 pads to North American rebuilders and distributors Based on our lab test results wear rate for the projected life of the pads made with Kevlar is only 10 - 12 percent the same as metallics compared with an 18 - 25 percent wear rate for asbestos products adds Bartels Canparts 681 material has several advantages over metallics as well Unlike metallics the new pad linings are not detrimental to rotor surfaces and do not rust under rivet heads The pads greatly reduce transmission of heat to brake fluid and they are not prone to brake squeal or dusting Kevlar was chosen for its unique combination of high tensile strength high resistance to wear abrasiveness and excellent high temperature performance It can also be used with existing manufacturing equipment One of the most attractive advantages of Kevlar is its processibility says Arnold Salt principal with Canparts and a formulator with 40 years experience We have had no problems using the aramid fiber with our existing equipment Du Pont Canada Inc. Att 3 pp 1-2 TV 10 57 Another Canadian industry has discovered the advantages of and a new use for the world's strongest synthetic fibre Du Pont's Kevlar aramid fibre is now being incorporated in industrial brake blocks used to control the tensioning of yarn twisting machines at one of Canada's largest synthetic rope and twine manufacturing companies Twine a division of Niagara Structural Steel St. Catharines Ltd. a Tecsyn International Company The results are reduced costs increased productivity and fewer plant environmental concerns Du Pont Canada Inc. Att 4 p 1 20 2 Commercial Availability 58 Today Arrow Bulk Carriers are using our Super brake blocks on most of their fleet notes Bob Anderson national sales manager for Canadian Metallic We're now offering worldwide a complete line of brake blocks using Kevlar aramid Du Pont Canada Inc. Att 1 p 3 59 The outstanding success of Canadian Metallic Brake Limited of Toronto in replacing asbestos with Du Pont's Kevlar aramid fibre as the primary reinforcement for brake linings has led to a sales volume increase of roughly 70 in just one year according to sales vice president Robert Anderson Already established as a quality service supplier to the heavy parts distribution industry Canadian Metallic's tough brake linings also being specified by several original equipment makers including Trailmobile Fruehauf and axle manufacturers Hayes Dana & Ingersoll Machine Tool Company Buyers of Super and Nova II linings are our best salesmen says Anderson One customer tells a user who tries them who tells another user who tries them and on Our Kevlar based products have had outstanding acceptance We are now operating three shifts a day six days a week and nearly 60 of our gross business comes from products incorporating Du Pont aramid fibre IV The company's complete line of friction products will eventually be free of all asbestos reinforcement with Kevlar being substituted throughout Beri confirms We now have the technology to blend Kevlar with appropriate resins according to use application regardless of friction classification he says Du Pont Canada Inc. Att 2 pp 1 3 60 Canparts supplies an extensive line of replacement parts to customers in more than 40 countries It has been searching for an organic replacement for asbestos in friction material for the automotive aftermarket since the company was formed in 1980 and finally found it with Kevlar Canparts introduced the new domestic brake pads at the 1982 Automotive Parts Rebuilders Association show in Atlanta in October The complete line will be ready for the U.S. aftermarket in January 1983 and will be priced competitively with metallics Du Pont Canada Inc. Att 3 pp 3-4 IV 3 Cost 61 The SuperNovias a premium brake block that costs twice as mucha traditional asbestos block says Angus We wanted to demonstrate that its extraordinary brake advan- tages make it a sound value buy They pay significant dividends to truck fleets through decreased brake service and parts replacement Kevlar aramid brings a lot of plus features to brake blocks Du Pont Canada Inc. Att 1 pp 2 3 62 We found and our customers now confirm that the Kevlar aramid fibre's exceptional flexibility toughness and abrasiveness make our linings highly effective says Beri Since for many applications as little as 20th of the weight of Kevlar compared with asbestos may be needed the end price to consumers of asbestos friction products can be kept fully cost comparative Du Pont Canada Inc. Att 2 pp 1 2 63 A traditional asbestos pad could contain 40 to 60 percent asbestos he added but we use considerably less Kevlar plus fillers and come up with a product competitive to metallic disc pads Du Pont Canada Inc. Att 3 p 3 IV 23 4 Experience See comments 54-57 on Applications and Performance IV 24 E. Substitutes in General - Availability Performance Health Effects Safety TV 25 64 This report identifies appliaplications cations for which asbestos asbestos has is ised in motor vehicle systems and components and discuses the performance and customer acceptance criteria that the the selection of asbestos for those applications Alterc3- materials materials materials for those applications are examined in relation to selection selection criteria vehicle design substitution and the effect on changes vehicle necessary to accommodate performance including with safety and other governmental regulations I. General Discussion A. Characteristics of Asbestos and the Difficulties of Finding Acceptable Substitutes The advantageous characteristics asbestos imparts to products used in the motor vehicle industry include - fire resistance - thermal and chemical stability - structural and flex strength - moisture resistance - dielectric strength - low cost - good friction and wear properties - permeability There are few alternate materials which have the total combination of these desirable characteristics Developing and approving acceptable substitute materials is a task requiring extensive research and testing programs materials The must many different potential substitute be evaluated over the wide range of environmental conditions under which a motor vehicle operates In addition the ripple effect of a substi- tution must be investigated to be sure the performance of other vehicle components is not adversely affected This is further complicated by the variety of materials used on our many different vehicles and the many customized applications IV 1 Applications and Performance 50 We wish to call EPA's attention to the availability of and to the possible use of low cost low modulus industrial grade carbon fibers as a suitable substitute for asbestos in automobile and truck brakes Carbon fibers have been evaluated and are being used in brake applications for aerospace military and commercial aircraft racing cars road vehicle and industrial and now to some extent in automotive uses in proprietary formulations Here carbon fiber properties of high strength wear resistance good frictional properties good binding qualities high conductance high thermal stability oxidation resistance and low weight them most attractive carbon fiber composites are considered the material brakes of choice for high performance military and commercial aircrafts good heat make Ashland's contacts in brake manufacture also indicate that carbon fibers can and are competitive to an extent with asbestos performance and that neither retooling or special processing techniques would necessarily be required to permit substitution of carbon fibers for asbestos Ashland Petroleum Company pp 1 2 51 Carbon fibers are materials currently used in a number of industrial applications calling for high strength and low its use today include graphite tennis rackets weight Examples of golf clubs and aircraft parts However growth of this market has been limited by the cost of producing high performance fibers used in these applications Ashland's carbon fibers are produced at considerably lower cost and are intended for general applications where specifications are less severe This production breakthrough should help the market expand Anticipated new markets for general purpose fibers include fillers for polymers engineering plastics brake linings high temperature thermal and sound insulation other temperature applications replacing asbestos automotive parts construction materials carbon fiber composites and a variety of military applications Ashland Petroleum Company Att 1 pp 1-2 2 Commercial Availability 52 Ashland presently has the capability of producing 30 year of general purpose carbon fiber GPCF and will expand production to 100 year in the fall of 1985 Ashland Petroleum Company p 1 3 Cost 53 Ashland's carbon fibers are marketed under the tradename lengths CARBOFLEX range in price from 10 to 12 nonwoven mat chopped 1/8 to 1/2 per pound and come in the forms of , and ground or milled 100 to 400 microns average length In the past the unavailability of low cost fibers to their exploitation in automotive brake applications formulations we understand that the amount of fiber is has been a deterrent although in brake pad rather low in composition Because we manufacture a proprietary raw material from which we produce our fiber and which is sufficient to produce up to 50 million pounds per year of fiber the potential exists for an even less expensive fiber if produced in much large volumes Ashland is dedicated to a continuing effort of further improvements in cost performance so as to enhance the effectiveness of carbon fiber Ashland Petroleum Company p 1 D. Kevlar Aramid 1 Applications and Performance 54 Kevlar was first introduced by E. I. du Pont de Nemours & Company in 1972 with an initial investment commitment of more than 500 million U.S. followed by a 200 million U.S. expansion program in 1982-83 The patented fibre is five times as strong as steel and 10 times as strong as aluminum on a pound for pound basis yet its density is 43 lower than fiberglass The high temperature stability strength and insulation characteristics of Kevlar have made it the preferred product in many applications where asbestos replacement is sought Among them are transmission clutch facings brake linings gaskets tires conveyor belting and high temperature resistant apparel Two years ago after an extensive development program and with the help of Du Pont Canada Canadian Metallic launched a premium line of Super brake linings which proved to last up to four time the life of conventional asbestos linings Some trucks have clocked more than 200,000 miles on Novas with a wear of less than 0.10 inch per 100,000 miles says Anderson Now Canadian Metallic has launched its Nova II asbestos brake linings The Nova II incorporates a lesser amount of Kevlar and is designed particularly for truck fleets whose owners are concerned with environmental problems related to asbestos and who want linings that will last longer says Beri The new linings were subjected to demanding field tests before market introduction We placed test sets on underground scoop trams used by a Sudbury mining company where the brakes would be innundated with water and sticky mud So far they have more than six months of continuous service with no problems says Anderson Overall Canadian Metallic is confident of excellent customer experience for the Nova II line Field testing shows for instance that brake drums are left unscored after up to 100,000 miles of use Du Pont Canada Inc. Att 2 pp 2 3 4 55 And that's precisely why an Arrow Bulk hauling rig was selected in 1983 as a test application for new SuperNova asbestos brake blocks Developed by Canadian Metallic Brake Ltd. for use on trucks and heavy road equipment these asbestos brake blocks are com pounded of special resistant resins and reinforced with Du Pont Kevlar aramid fiber along with other quality friction materials A Better Brake Block The Super is a premium brake block that conservatively offers at least eight times the performance life of con- ventional asbestos brake blocks boasts Michael Beri president of Canadian Me- tallic It also delivers twice the brake life of metallic blocks and doesn't score the brake drums the way metallics generally do all respects it's the enduring performance brake block we " set out to formulate five years ago It was in 1980 that Beri began focusing on Kevlar an aramid fiber marie only by Du Pont as the reinforcing core of a performance lasting brake block The high track record of Kevlar demonstrated strength low weight abrasion resistance and outstanding thermal properties in applications ranging from aircraft and rockets to boat hulls and protective body armorsuggested a promising candidate for friction products subjected to intense heat and pressure Following two yearosf try- ing and testing formulations Canadian Metallic went commercial with its SuperNova brake blocks in October 1982. An early priority was to demonstrate the brake superiority of the new blocks through comparative data generated in the field Hayes Inc. a supplier of truck trailer axle components was signed on as a major Canadian distributor for the new asbestos brake blocks Doug Angus of Hayes supplied SuperNova blocks to a number of trucking opera- tions for field tests In April 1983 SuperNova brake blocks were mounted on the two drive axles of one of Arrow Bulk's Kenworth tractors and on the three axles of a Knight dump trailer New Kelsey brake drums also were installed at the start of the trial Four times each day this rig made the journey to the Ashcroft sid ing and back After eight weeks of serv ice reports Jones a visual inspection revealed that the blocks still had 75 percent useful lining life remaining At this point he adds three or four replacement sets of asbestos blocks would have been in- stalled due to block disintegration Blocks Drums Fine At 12 Weeks Hubs and drum assemblies were pulled at 12 weeks No disintegration of the SuperNova blocks close to 50 percent of lining life remaining drum sur- faces smooth with no scoring With metallics says Jones we'd have been replacing both blocks and drums by this time The SuperNova blocks were fine so we put them back on the wheels to see how long they really would last In January 1984. nine months and 65,000 miles after the start of the trial the center axle wheels on the trailer were realigned No new blocks or drums were required In February with 72.000 miles logged all four truck wheels were realigned Brake blocks and drums still were compatible and serviceable It wasn't until April 1984 after 90,000 miles of hauling that Arrow Bulk finally replaced the brake blocks and drums on the rear axles of the trailer In addition to extended performance life brakes reinforced with Kevlar 1 recover well with controlled fade 2 help minimize cracking around rivet holes 3 won't glaze or smear because Kevlar doesn't melt as glass fiber does and + won since Kevlar is nonmetallic Du Pont Canada Inc. Att 1 pp 2-4 56 Canparts Automotive International Ltd. a Cambridge Ontario manufacturer of automotive disc brake pads has developed a line of replacement products which wear like semi- metallics but are not detrimental to rotor surfaces The brake segments are reinforced with Du Pont's Kevlar aramid fiber Integrally molded pads for imported cars have passed a year of extensive field trials Based on their experience with the molded pads the company is now expanding to drilled disc pad segments for domestic cars _ _<- a- Improved performance has made the reinforced product successful says Canparts president Bill Bartels We've sold more than 300 000 pads to North American rebuilders and distributors Based on our lab test results wear rate for the projected life of the pads made with Kevlar is only 10 - 12 percent the same as metallics compared with an 18 - 25 percent wear rate for asbestos products adds Bartels Canparts 681 material has several advantages over metallics as well Unlike metallics the new pad linings are not detrimental to rotor surfaces and do not rust under rivet heads The pads greatly reduce transmission of heat to brake fluid and they are not prone to brake squeal or dusting Kevlar was chosen for its unique combination of high tensile strength high resistance to wear abrasiveness and excellent high temperature performance It can also be used with existing manufacturing equipment One of the most attractive advantages of Kevlar is its processibility says Arnold Salt principal with Canparts and a formulator with 40 years experience We have had no problems using the aramid fiber with our existing equipment Du Pont Canada Inc. Att 3 pp 1-2 57. Another Canadian industry has discovered the advantages of and a new use for the world's strongest synthetic fibre Du Pont's Kevlar aramid fibre is now being incorporated in industrial brake blocks used to control the tensioning of yarn twisting machines at one of Canada's largest synthetic rope and twine manufacturing companies Twine a division of Niagara Structural Steel St. Catharines Ltd. a Tecsyn International Company The results are reduced costs increased productivity and fewer plant environmental concerns Du Pont Canada Inc. Att 4 p 1 2 Commercial Availability 58 Today Arrow Bulk Carriers are using our SuperNova brake blocks on most of their fleet notes Bob Anderson national sales manager for Canadian Metallic We're now offering worldwide a complete line of brake blocks using Kevlar aramid Du Pont Canada Inc. Att 1 p 3 59 The outstanding success of Canadian Metallic Brake Limited of Toronto in replacing asbestos with Du Pont's Kevlar aramid fibre as the primary reinforcement for brake linings has led to a sales volume increase c roughly 70 in just one year according to sales vice president Robert Anderson Already established as a quality service supplier to the heavy parts distribution industry Canadian Metallic's tough brake linings also being specified by several original equipment makers including Trailmobile Fruehauf and axle manufacturers Hayes Dana & Ingersoll Machine Tool Company Buyers of Super and Nova II linings are our best salesmen says Anderson One customer tells a user who tries them who tells another user who tries them and on Our Kevlar based products have had outstanding acceptance We are now operating three shifts a day six days a week and nearly 60 of our gross business comes from products incorporating Du Pont aramid fibre The company's complete line of friction products will eventually be free of all asbestos reinforcement with Kevlar being substituted throughout Beri confirms We now have the technology to blend Kevlar with appropriate resins according to use application regardless of friction classification he says Du Pont Canada Inc. Att 2 pp 1 3 60 Canparts supplies an extensive line of replacement parts to customers in more than 40 countries It has been searching for an organic replacement for asbestos in friction material for the automotive aftermarket since the company was formed in 1980 and finally found it with Kevlar Canparts introduced the new domestic brake pads at the 1982 Automotive Parts Rebuilders Association show in Atlanta in October The complete line will be ready for the U.S. aftermarket in January 1983 and will be priced competitively with metallics Du Pont Canada Inc. Att 3 pp 3-4 3 Cost 61 The SuperNovias a premium brake block that costs twice as much as a traditional asbestos block says Angus We wanted to demonstrate that its extraordinary brake advantages make it a sound value buy They pay significant dividends to truck fleets through decreased brake service and parts replacement Kevlar aramid brings a lot of plus features to brake blocks Du Pont Canada Inc. Att 1 pp 2 3 62 We found and our customers now confirm that the Kevlar aramid fibre's exceptional flexibility toughness and abrasiveness make . our linings highly effective says Beri Since for many applications as little as 20th of the weight of Kevlar compared with asbestos may be needed the end price to consumers of asbestos friction products can be kept fully cost comparative Du Pont Canada Inc. Att 2 pp 1 2 63 A traditional asbestos pad could contain 40 to 60 percent asbestos he added but we use considerably less Kevlar plus fillers and come up with a product competitive to metallic disc pads Du Pont Canada Inc. Att 3 p 3 4 Experience See comments 54-57 on Applications and ) Performance E. Substitutes in General - Availability Performance Health Effects Safety This report identifies applications for which asbestos nas been or is ised in motor vehicle systems and components and discusses the performance and customer acceptance criteria that led to the selection of asbestos for those applications Alterna tive materials for those applications are examined in relation to selection criteria vehicle design changes necessary to accomodate the substitution and the effect on vehicle performance including compliance with safety and other governmental regulations I. General Discussion A. Characteristics of Asbestos and the Difficulties of Finding Acceptable Substitutes The advantageous characteristics asbestos imparts to products used in the motor vehicle industry include - fire resistance - thermal and chemical stability - structural and flex strength - moisture resistance - dielectric strength 1 low cost - good friction and wear properties - permeability There are few alternate materials which have the total combination of these desirable characteristics Developing and approving acceptable substitute materials is a task requiring extensive research and testing programs materials The must many different potential substitute be evaluated over the wide range of environmental conditions under which a motor vehicle operates In addition the ripple effect of a substitution must be investigated to be sure the performance of other vehicle components is not adversely affected This is further complicated by the variety of materials used on our many different vehicles the many customized applications Need for Systems Systems Evaluation Evaluation of Potential Potential Potential Potential Potential Sub Sub Sub ur ' ce ' ' vb eevee vi For the majority of current applications other than brakes many substitutes for asbestos may be available This is a generalization and is conditioned by productand application constraints In most cases the containing material was part of a larger system e.g. asbestos head gaskets are a portion of larger system the engine Thus the question of suitable substitutes must be approached on a total the system basis A direct substitution of some other fiber for asbestos is often not feasible without modification of a larger system While substitutes exist there is still a substantial research effort required before substitute materials can be released for full production Further substitution must be approached on a product function function basis In this way the asbestos substitute can be fully evaluated for performance in the vehicle including related concerns and consumer acceptability Health safety and environmental factors related to substitute usage during vehicle manufacture must also be fully evaluated MVMA cautions against inadequate consideration of all factors involved with a substitute material A substitute which results harmful in unacceptable vehicle performance or safety or is more than asbestos to workers is an unaccept- able substitute Asbestos offers a unique combination of properties in a single material Not all of the properties can be matched with a single substitute therefore total system redesign may be required to achieve the desired considered considered result Ripple effects effects effects must must alals so o be considered 1.9 if compnets componets new bart has a different size or shape rust other the the the the new componecompnonentsts new components components or subassemblies be redesigned part Once a potential system performance tested and if the to accommodate the ne new w is designed it must be substitute meets the performance criteria mass production methods must be devised All this necessitates a considerable design engineering and testing effort C. Status of Substitute Availability - Brakes - One of the primary applications for asbestos in our industry is brake lining materials The suitability of brake linings to the great variety of cars multipurpose passenger vehicles light trucks vans medium and heavy duty trucks tractors and buses requires extensive development Brake systems are required to meet a variety of Federal and State regulatory requirements including FMVSS 121 Air Brakes and 105 Hydraulic Brakes BMCS regula- tions and various state laws Many vehicle manufacturers are dependent upon brake and lining suppliers to develop initially screen new materials produce and The rate of development of these new materials is not only limited to available expertise but to the laboratory and vehicle equipment as well as manpower at vendors Until these materials are manufacturers developed the vehicle Substitution will lead ol in os re c brake can do pads little Drum pasenger brake linings for passenger can probably be asbestos pasenger cars free free free in and the light tr c next several years truck Heavy truck drim crake crake crake crake systems however will take longer In addition to the obvious need to stop the vehicle safely each supplier and manufacturer has requirements which he deems to be important and must be met Among these are Requirements Acceptable Lining Life - Lining materials must provide the customer with acceptable lining life in the great variety of uses to which vehicles are put Leading Lining Material Semi Acceptable Drum and Rotor Life - Brake materials must be compatible with drums or rotors they contact and not cause excessive wear grooving or cracking Asbestos - Structural Strength - Linings must have sufficient strength to prevent cracking chipping flaking and delamination shearing in their various strenuous uses The capability to tolerate flexure of its supporting elements is an essential requirement Green or Preburnish Performance - Linings must provide reasonable performance and stability when new Asbestos Semi Water Recovery - Lining materials must be able to provide adequate performance when exposed to water and to recover the initial performance and stability within a short time Fade Resistance - Linings must provide adequate performance and stability when subjected to high temperatures and then cooled They should provide approximately their original ambient performance after being exposed to temperatures as high as 1200 Parking Capability - Linings must provide sufficient static retarding force to support grade holding demanded of the parking brake system 8 Dimensional Stability - Lining material must not swell at high temperatures or when exposed to moisture or undergo length or width dimensional changes that could result in structural cracks Performance Consistency - Lining material performance must be relatively consistent over a wide range of temperatures and operational conditions 10 Low Temperature - Materials must provide acceptable performance and durability and on the tion at low ambient temperatures first daily brake applica- 11. Lining Attachment to its support element >> Current methods may not be suitable for new materials This interface could require additional development and testing Semi Either with slight edge to asbestos No problem Either Asbestos Asbestos In addition the customer demands a number of th 10 from brakes and linings including Requirements Absence of Noise - Noisy brakes and linings generate driver and community complaints and therefore cannot be tolerated Leading Lining Material Either Modulation and Control - Drivers demand brakes and linings which provide performance and control with reasonable pedal efforts under all conditions of load and traction Asbestos Lining and Rotor Life - Customers demand long service life in a variety of vocational uses environmental conditions duty cycles and geographical locations Lining To meet all these real needs and requirements is an extemely difficult laborious task involving many development hours Materials must be subjected to great variety of test conditions The problem is complicated further by the variety of brakes - both in size and type - that this industry uses in many different vehicles and customized applications Government regulations have further increased the need on heavy trucks to customize brakes and brake systems Prior to FMVSS 121 manufacturers used one brake size and torque capacity for many axle capacities and applications That practice has been curtailed by FMVSS 121's dynamometer requirement and the possibility of reimposed stopping distances as part of this regulation FMVSS 105/75 subjects passenger car MPV and light truck brake systems to severe duty cycles and temperatures which result in very rigorous demands on the brake lining materials ? Lining material selection involves many engineering consumer and regulatory considerations GovernmentGovearnmentall regulatory agencies differing materials such will as OSHA must realize that many be required to replace the . great variety of asbestos linings manufacturers currently use There appear to be a few acceptable linings asbestos lining brake pads and some materials passenger available today car drum brake for disc The processing of asbestos materials may require different manufacturing equipment and techniques because of clumping and chemistry changes mixer speeds have to be varied and pressure changes made It will take time to develop these techniques controls and the machines to support industry volumes Some of the asbestos disc pads used by vehicle manufacturers still incorpo- rate an asbestos backing for reasons explained later in the general discussion on brake friction materials Brake components such as linings have high exposure in the safety compliance recall and product liability areas. Therefore vehicle manufacturers must be certain they are not correcting one problem and creating another It should be pointed out that this was exactly the case with FMVSS 121. The performance levels and effective date mandated by that standard generated the hasty development of components which were unacceptable to the consumer and which introduced new performance problems If justification is found for a change of this magnitude sufficient time must be provided to assure that existing linings will not be replaced with others the consumer will not accept Linings are a key factor in any brake design and asbestos is a key factor in many lining materials If asbestos is eliminated from brake linings manufacturers must retest and requalify every vehicle brake application currently using asbestos Summary and Conclusions ap lications For the majority of the asbestos applications vehicles acceptable substitute materials applications applications materialsmaterials are in motor in varying stages of development It is possible that many substi- tutions i.e. fillers and sealers can be accomplished in the next few years However there are certain critical uses of asbestos for which finding acceptable substitutes will take considerably longer These are heavy truck brake linings and engine preformed gaskets These special applications will require system redesign to accommodate the properties of asbestos materials II B. Specific Vehicle Applications Friction Products - Brakes Passenger Cars & Trucks Discussion Friction materials for automotive brakes are complex composites containing three general types of ingredient materials reinforcing fibers modifiers that adjust or maintain friction level wear rate and noise properties and organic resin binders Historically the foundation or major constituent of automotive friction materials has been chrysotile asbestos fiber so chosen because of thermal stability friction level reinforcing properties availability and relatively low cost metallic asbestos friction materials were originally developed to meet higher capacity and temperature requirements for heavy and front ' wheel disc brakes sucesfuly sucesfuly sucesfuly used metallic lining are Disc now oake oake oake oake asmeaer U aa) eine ue ad 1 u 1 t t sucesfuly sucesfuly successfully successfully used used used for for for a Pasenger wide range of venicles Passenger Passenger Passenger Passenger carscarscars cars lign lign lign lign 6k cars trucks and multi pasengr wil vehicles vehicles requirerequire completely asbestos pasenger passenger vehicles vehicles will will require require require with with with further further further further further further development of asbestos drum brake shoes a drum much more difficult set of design materials and manufacturing problems that existed for disc pads Substitution is especially difficult for dual servo type drum brake systems which are predominant on rear wheel drive vehicles because these systems require highly consistant friction coefficient for smooth application Most hydraulic disc brake shoe and lining assemblies contain an asbestos backing material The primary reasons are to control heat transfer and to aid in attachment of the lining to the metal shoe Eliminating the asbestos backing material requires considerable development in order to maintain attachment strength and control heat transfer to the brake fluid Control of the various materials in lining is critical Wear problems are currently being encountered due to impurities found in a key ingredient Control of materials and processes continues to be a challenge Considerable resources are currently to correct field problems with noise temperature wear being expended and low Heavy Trucks - Air Brake Liners and Blocks asbestos blocks have been found to crack and delaminate This condition causes user concern In addition since asbestos materials do not have the flexure strength of asbestos materials shoe rigidity and dimensional accuracy become new challenges to be resolved from a manufacturing Substi te te Substi Substi ere Substi re Materials Major types of asbestos brake formulations are 1 Organics using combinations of other fibrous materials such as fiberglass and mixed compounds of calcium silicate aramids rein- forcing fibers as substitutes for asbestos in formulations that use an organic resin binder 2 metallics - consisting of steel wool sponge iron graphite ceramic powder and other substances in a phenolic resin binder 3 Sintered and ceramic powders as well as inorganic friction modifiers fused together under extremely high temperature and pressure Organic materials have the least cost the easiest lining attachment and the greatest structural strength However their wear rate and fade resistance are the poorest Lining swell can also be a problem Organic materials are used primarily for drum brake systems metallic linings have better wear and fade characteristics than organic materials However they cost more and have less static retarding force and generally require an asbestos backing material in order to insure adequate attachment shear strength on disc pads Lining swell generally is not a concern Sintered metal materials are very costly extremely difficult to attach to a shoe and have the poorest flexure tolerance However they have the best wear rate and fade resistance at high temperatures Static retarding and burnish performance are also problems with these materials Motor Vehicle Manufacturers Association Att 3 pp 1-12 IV 65 This industry is regulated its products being one of the critical materials in hydraulic and air brake systems Brake Linings used in new vehicle brake systems must undergo lengthy qualification and certification tests by the producer and customer before release Formula or significant processing changes on released products cannot be put in effect without requalifica- tion and recertification There is also considerable lead time involved when formula or processing change is planned Change is not only timeconsuming but it is costly Development of a new formula along with the required testing for compliance with either DOT Standard 105 Hydraulic Brake Systems or 121 Air Brake Systems and moving the product into production can cost in excess of 250,000 and product or process modifica- tion costs may also approach this figure Products using substitute materials have a material cost two to three times the cost of the asbestos based product being replaced The cost increase is not limited to material costs Most substitute materials require sub- stantial capital equipment investment as well as additional labor cost While there has been progress in the automotive highway market the industrial highway market is almost an entirely different market One cannot substitute certain fibers in friction products used in underground mining equipment for fear of a induced explosion The friction material used in overhead cranes handling hot metal or heavy loads may not accept a substitute material without adding another hazard highway friction products have requirements above and beyond usage and must be tailored to the product line These off- normal highway Motor Vehicle Manufacturers Association Att 4 pp 1-2 TIZ 21 66 Further the availability of economically and technologically feasible substitutes for asbestos is an issue in which the friction materials manufacturers are deeply involved The identification of such substitutes is a major ongoing program with the manufacturers and is not a completed program at this point in time Total endorsement of Section - of the petition is not appropriate since friction materials manufacturers produce disc pads and drum segments for passenger cars and light to medium trucks as well as brake blocks for heavy trucks The claims made in Section B relate to brake blocks and cannot be endorsed for all product lines Further actual experience to date has proven that substantial processing modifications and new equipment are required for the asbestos substitute materiais The advantages of metallic brake linings cited in Section - are not necessarily supported by test results generated by friction materials manufacturers While certain of these claimed advantages may be true where the application generates high braking temperatures they are not necessarily true for the average consumer Sufficient data is not at available this time on the substitute materi is to state that they do not pose a hazard in the workplace environment or to the general public We wish to cite a recent study by the Canadian Royal Commission on Matters of Health and Safety Arising from Use of Asbestos in Ontario and an earlier paper on asbestos Related Malig- nant Mesothelioma These comments follow ... the production of substitute fibres in the future should increase the exposure of workers to Long thin durable fibres of dimensions similar to those we have found hazardous for asbestos we cannot be sure that serious health consequences would not result To the face of the existing evidence we believe it would be risky to allow the exposure of workers to respirable fibres longer than 5 microns with small diameters of any material if those fibres are likely to be very durable in the material lungs It has been generally accepted now that the fibre which is carcinogenic is a durable long and thin fibre the diameter of less than 1.5 micron and length of more than 8 micron appearing critical A number of fibrous materials other than asbestos can appear in this size and shape and indeed have been established as couse of mesothelioma in animals such as glass fibres aluminum oxide tremolite attapulgite dawsonite silicon carbide and potassium titanate Report Bae of the Royal Commission of Matters of Health and Safety Arising from the Use of Asbestos in Ontario 1984 Ontario Ministry of the Attorney General Toronto asbestos Related Malignant Mesothelioma - A Review of the and Medical Literature Premysl V. Pelnar MD citing a paper Layard Tegeris Miller May and Kent that appeared in the J. Cancer Inst March 1977 Scientific by Stanton Natl Friction Materials Standards Institute Inc. Att 1 pp 2-4 67 Effective substitutes may not be available for certain applications of asbestos in brakes and substitutes for other applications are not available in sufficient quantities because of limited production capacity III POSSIBLE SUBSTITUTE FOR ASBESTOS Possible substitutes for asbestos are represented by the following materials alamid fiber glass fiber and various inorganic fibers and steel fiber However the safety of these fibers for human health is not yet proved When asbestos is substituted the following conditions will exist a Disc brake pad From a viewpoint of securing a long brake life the metallic pads are adopted to certain types of vehicles especially passenger vehicles However as EPA pointed out the metallic pad is characterized as having a coefficient of friction which varies with temperature Therefore it is not suitable for all types of vehicles Further the asbestos contained friction materials are used as a heat barrier However such materials cannot become a real asbestos friction material unless the heat barrier is asbestos Another type of disc brake pad contains the parking brake built This rod is provided not only with the capability required for normal service brake but also with that for the parking brake In other words for this rod the coefficient value of friction fluctuating in regard to the temperature change is low for this reason very few disc brakes adopt this type of metallic rod b Lining for drum No substitute is available in Japan at this moment c Substitute for asbestos now under development 1 Disc brake pad Besides the above metallic pad the friction material applying different asbestos fiber is now under development However it is expected that such material will be applied to various kinds of vehicles after the mid 1990's As as result it is expected that price increases will follow 2 Lining for drum For this item asbestos brake using different fibers is now under development but wide scale commercial use of asbestos brake pads in vehicles is not expected until on or after the mid 1990's because of the unavoidable rise in prices for these pads until then In any event in order to use asbestos substitutes in various types of equipment additional equipment or renewal of equipment will be required Taking into consideration the availability of substitute fibers it is expected that we will encounter difficulties if vehicles decide to adopt the substitute materials It is recommended that the action to prohibit the use of asbestos presently used as a major brake component and the substitution use of a asbestos brake friction material should be phased in smoothly over time granting sufficient lead time at each stage Japan Automobile Manufacturers Association Att 1 pp 1 3-5 68 Even though these many uncertainties exist we committed to the elimination of asbestos brake linings installed on vehicles we manufacture - are the We have been working diligently for a number of years with the major brake lining suppliers in the U.S. in an effort to find substitute materials for brake linings which do not contain asbestos Our experience to date shows that the development of substitute materials is a very difficult and time consuming task It been fraught with numerous problems many of which are recognized in the subject notice Because of the unresolved problems associated with many currently available substitute materials we cannot project at this time when our suppliers will be able to provide satisfactory asbestos brake linings for incorporation ~ on all of our vehicles The development of satisfactory asbestos brake lining materials will take time Over the years consumers in the U.S. have developed the expectation that vehicle brake systems will provide safe reliable performance during many miles of operation without maintenance and will be noise Many years were required for vehicle manufacturers and suppliers to develop the expertise required to provide asbestos lining compounds which meet these consumer demands and our stringent safety and performance requirements under the multitude of widely differing environmental and driving conditions experienced in the U.S. These lining materials also had to be engineered to provide balanced and consistent stopping ability under all types of vehicle loading conditions under a very wide variety of brake temperature conditions and with green and used linings New asbestos brake lining compounds and formulations must be developed to meet these same objectives Because brake performance is important to vehicle safety it must not be compromised by a premature switch to substitute materials Some substitute materials have been developed and the use of asbestos material has been substantially reduced but there is still much more work to be done before it can be totally eliminated manufactures has metallic Currently all front disc brake but one vehicle pads However that Chrysler we must stil depend on asbestos as an underlayer medium on most applications to eliminate stress cracks that appear during the bonding or riveting of the friction material to the brake pad support plate No entirely satisfactory material has been found to date which will provide the cushioning effect provided by the thin asbestos- based underlayer material Alternate materials for the underlayer are evaluated in hopes of producing pads which are completely free of asbestos being We are working to employ asbestos substitute linings on new model vehicles as part of the design and development process This process has not been without problems however Recently we were forced to revert to containing linings on two introduced vehicles because of heavy disc brake scoring and inconsistent brake performance with asbestos substitutes brake rotor These difficulties appeared very late in the vehicles development program and may ultimately cause a production delay However asbestos linings are planned for several other applications on 1986 model year vehicles Because of weight distribution suspension characteristics and other factors each vehicle has unique braking system requirements Consequently a particular lining formulation that is acceptable on one vehicle may prove to be unacceptable on another In view of the complexity involved with the development of a new brake system we begin nearly three years before the first vehicle rolls off the assembly line The and first step in the process is the establishment of vehicle performance goals objectives These include all the requirements of Federal Motor Vehicle Safety Standard 105 a minimum brake lining life of 50,000 miles under normal driving conditions and noise operation for the life of the vehicle These criterion along with other design parameters are conveyed to our friction material Suppliers for candidate material selection During this critical period of development we are literally totally dependent on the recommendations they provide Controlled laboratory tests narrow the field of candidates to the final material to be used Vigorous tests during highway city traffic and mountain grade driving fine tune the system to ensure that it will meet our stringent safety and performance requirements and consumers demands for quiet effective and trouble performance Chrysler Corporation pp 1-3 69 Our suppliers tell us that they are now in the process of phasing out the use of asbestos in the friction products that they supply to us We understand that by 1990 most if not all of these products will be asbestos as new car and truck lines are phased in containing systems are being phased out Despite some technical problems that remain we understand that good progress is being made Ford Motor Company p 1 70 IH currently purchases from outside suppliers various components containing asbestos These include gaskets clutch facings sealing materials and brake assemblies Because IH is a purchaser rather than a manufacturer of containing products it is extremely concerned about the possible effect that a ban on use of products in motor vehicles would have on its product planning and engineering If EPA prohibits use of containing components IH will need considerable lead time to identify test and adapt its products to the prohibition takes use of asbestos substitutes the effect The attached letter dated March 8 1984 to one of IH's brake suppliers is submitted as Attachment A with these comments as an illustration of the magnitude of the task facing vehicle manufacturers and their suppliers as well as the amount of lead time needed to incorporate the substitute products into the vehicle after qualified substitutes are found IH has already expended considerable component suppliers to identify substitutes However much more needs effort to work with its and test asbestos to be done because safe durable and competitively priced asbestos substitutes have not been found for all containing components in all types of brakes This is all the more true because many of these components are subject to Federal Motor Vehicle Safety Standards which require a high level of performance and reliability EXPERIENCE TO DATE WITH SUBSTITUTE MATERIALS IH's experience with asbestos production hydraulic disc brake linings dates back to 1976. asbestos hydraulic disc brake pads were first released for production in 1980 During the past three years IH has worked directly with its brake . suppliers to find qualify and incorporate asbestos linings into additional types of brake assemblies So far however regular production hydraulic service brakes air brakes and driveline parking brakes still contain asbestos Despite numerous articles in the trade press claiming exceptional durability for asbestos brake linings IH has not always found these claims to be true While laboratory wear tests of asbestos brake linings have shown good durability field tests i.e. tests in actual use have revealed structural problems such a delamination material breakdown and metal pickup in some formulations and shortened drum lives in others IH believes that reports of the availability of suitable reliable and safe substitutes for containing brake linings have been overly optimistic and may have misled customers government agencies and the general public IH is deeply concerned that EPA might consider banning further use of all containing components regardless of whether suitable reliable put into and safe substitutes have been found If such a ban is place IH would recommend allowing exceptions to the ban unless and until qualified substitute materials are found and can be incorporated into products Although the search for suitable substitutes in all applications has still not met with total success IH continues to be actively involved in programs to test new lining formulations As an example the previously mentioned March 8 1984 IH's program for qualifying asbestos materials letter details for foundation air brakes in tractor applications However this program covers only one type of brake system in one application requiremnts The basic types of truck brake systems include actuated can, wedge and disc brakes and hydraulic drum and disc brakes Each must be tested in both tractor and straight system applications The wide range of braking requirements in trucks of uses to which trucks may be stems from the tremendous variety from highway haul tractor operations to put intra delivery garbage and dump trucks and service applications such as oilfield logging and mining operations Each type of brake system is employed because it does the job more effectively in that particular application than any other type of system In the past eight years IH has evaluated asbestos lining formulations for disc brakes one has been found to be acceptable for production several So use far Our dozen only first series of cam drum brake tests started in 1983. These tests were terminated in early 1984 due to unacceptable results We are a second series of tests with the best currently available performing materials on braked trucks and tractors This testing program which began with truck tractors was expanded in the fall of 1984 to testing of buses and medium Class 6 and 7 GVWR straight trucks The test series involves the following phases 1 Screening tests of lining materials by suppliers including dynamometer certification torque capacity structural integrity and wear 2 Vehicle tests at the IH Proving Grounds including tests of . vehicle performance grade holding and compatibility compared to asbestos linings 3 Field tests of selected fleets of approximately 20 tractors Currently we are in the third phase field testing which was begun in the fall of 1984. In order to accumulate the minimum 150,000 miles required this phase will have to last until March 1986. However IH is concerned even at this relatively early stage in the field out unsatisfactory on the test fleet testing that this test series may also turn results Recent inspections of brake systems show that iron brake drum material is being transferred to and embedded in the brake block This accelerated scoring seriously shortens the life of the drum FURTHER TESTING NEEDS As a result of this development IH believes it may not have found a suitable asbestos brake lining substitute even by March 1986 and further development and testing will be necessary after that date In addition it should be emphasized that once a suitable substitute has been found through this testing program another two years is required to release specifications procure material schedule and begin production with these materials The enclosed time chart Attachment B shows graphically the number of steps that must be taken and the amount of time required for each stage of the process It should be emphasized that this testing program covers cam brakes only This system is used on the greatest number of vehicles produced by IH However substitute materials must still be found for other brake systems used by a smaller number of vehicles materials such as wedge and highway cam brakes have not yet been developed for these brake So far test systems IH is concerned that the low volumes involved with these systems may not provide enough economic incentive perform the necessary research and for brake manufacturers to development on substitute materials containing materials will also driveline parking brake applications used with all IH hydraulic service brake located behind the transmission and are have These to be replaced in brakes which are systems designed are drum brakes to restrain the driveline upon actuation of a structural integrity is crucial hand lever In this application for linings because they must meet requirements for grade holding in order to be certified to Federal Motor Vehicle Safety Standard FMVSS 105 Finally while it is true that all IH hydraulic vehicles use asbestos linings in type service brakes disc pads currently use approximately an insulating layer of containing 16th of an inch thick between the wear material material and the steel backing plate IH's suppliers are currently testing possible strength substitute materials with the needed to bond the asbestos improved structural Wear material to the steel backing plate and to act as a thermobarrier At this point however IH does not know how long it will take to develop and qualify a satisfactory substitute material for the insulating layer of asbestos in hydraulic brake disc pads Once the field testing of substitute materials is completed it will take another year for IH actually to incorporate these materials into its products through the design engineering and manufacturing process CONCLUSIONS In recent years IH has voluntarily eliminated use of asbestos in most clutch facings and has eliminated approximately 90 percent of the asbestos in hydraulic service brakes IH's continuing effort to develop asbestos cam brake friction materials demonstrates a commitment to elimination of all asbestos from our products of consistent with preventing any degradation of production performance Although a federal mandate could spur the introduction of more substitute material candidates by the materials manufacturers heavy vehicle manufacturers such as IH will require between three and a half and four years lead time to test and incorporate new materials into their products such new materials are developed In summary IH would make the following points 1 IH's asbestos substitution program is proceeding as rapidly as new qualified substitutes are made available to it 2 Substitute materials suitable for all vehicle applications have not yet been found 3 For economic reasons substitute materials may not become available for aftermarket service parts 4 IH will need three and a half to four years of lead time to develop and produce vehicles with qualified substitute materials International Harvester pp 1-5 7 te .71 Mr. Eaton P.O. Box 595 Galesburg MI 49053 . oo 113857 INTERNATIONAL HARVESTER March 8 1984 ATTACHMENT A RE Asbestos Brake Lining For Tractor Application Dear As you know IH has a program to evaluate asbestos linings on tractors for fiscal year 1984. Over the last several years OSHA has lowered the exposure limit of asbestos in the workplace Recently they proposed to reduce the PEL permissible exposure level to .5f In addition they intend to explore the feasibility of even lower limits of .1f All this has encouraged lining manufacturers to focus .2f nearly and all their development dollars on asbestos materials Presently there is virtually no new developments with conventional asbestos based materials Our work to date has consisted of evaluating approximately 30 field test installations with various materials along with proposed trailer combination tests at our test track Recently however asbestos submissions we learned under failed to live up to field conditions that all advertised claims and desired customer expectations As submissions are undergoing a result in order to correct these problems compounding changes in one form or another all Tne new materials if approved will then make our asbestos field test obsolete Based on this we have decided to temporarily stop and completely reassess our goals and the administration of this program The goals and guidelines are 1. IH remains committed to pursue the qualification and release of asbestos materials on tractor models in an expeditious manner >. The asbestos lining evaluation is starting over with all lining suppliers back to square one Before any material will be accepted at IH for controlled vehicle tests or fleet tests the dynamometer screening results must have been approved by our brake suppliers 3 The material has to provide equal to or nopefully superior lining and . i drum life characteristics when compared to ABB 551 4 The material has to have minimum coefficient of friction and yet be . certifiable 5 We are willing to consider AL changes in order to achieve maximum life dyno performance and standardization willing to consider rerating an axle in order In addition to certify the we are longest life materials 6 Front and rear materials do not have to be the same 7. The lining manufacturer has to convince the brake supplier that their material is worthy of further consideration during the screening phase i of the evaluation Communication however during the screening phase should not be limited to only the lining and brake supplier I do want . to be made aware of all developments which include test results failures compound changes etc. This information can be transmitted to me by either the lining manufacturer or the brake manufacturer or both 8. Coverage AXLE LOAD RATING # RANGE ( # 12,000 8,10-12,00 8,100-12,000 8,100-12,000 20,000 20,000 16,160-20,000 16,160-20,000 16,160-20,000 CURRENT PROD BRK SIZES & LININGS ' 15 551 .. 16-1 D39A CURRENT PROD PWR 20x5-1 5-1 .R RADIUS RANGE " 18.6-21.1 18.6-27.1 Screening Phase The brake suppliers are to screen recommendations After screening the potential number of candidates and make their lining candidates will be reduced to a maximum of two The materials selected will then advance to the IH vehicle and fleet test phase The screening test by lining manufacturers and brake suppliers is to include 1 Dynamometer certification ane 2 Torque curves 2 3 _ Wear test 4 Structural integrity 5 Lining sample tests -3- In order compare the standardize the tests of , 2 various linings 3 & 4 as much as an effort was made - possible Test 5 Lining Sample Tests are in some cases proprietary procedures brake manufacturer They include specific gravity gogan required by each hardness acetone extraction swell growth fast and chase test lining stability Mu vs. temperature pressure and speed The results are to be reported to me similar to 1 2 3 and 4 1. Dynamometer Certification Run per FMVSS Report 50 mph retardation fade and recovery Note that all dynamometer tests are to be conducted with . a Rolling Radius Range -21.1 ! D Cast drums - Front drum weight - Rear drum weight 55-65 lbs 105-115 lbs c Cam rotation - same 2. 2. Torque Curves Run 20 50 and 60 mph at axle rated loads of 12,000 lbs front and 20,000 lbs rear Plot chamber pressure vs. torque 3 Wear vs. Temperature a D to Measure weight of each shoe and lining assembly the nearest gram Measure shoe table and lining thickness in six equally spaced ( locations per block c Measure drum inside diameter at open end center and closed end Repeat at from first measurement d Install thermocouple in the center of each block == recess in lining .040 e Air flow should be set at 2200 min at 75 to 100 F f) Run all snubs from 40 mph to 20 mph at 7 sec Axle load for fronts is to be 12,000 lbs and 20,000 lbs for rears burnish g Condition for wear test by running the lower portion of 121 200 stops from 40-0 mph @ 10 sec- IBT 315 to n Run 2,000 snubs at 250 1,000 snubs at 350 1,000 snubs at 450 1,000 snubs at 600 and 1,000 snubs at 250 : 1 Measure and weigh shoes and drums between each temperature interval including burnish Note lining and drum condition Report wear in weight of material lost and amount of material worn Reseat the lining thermocouples to .040 depth after each measurement 4 Structural Integrity a Static Test Place lining with ends down arc up on a flat surface or parallel blocks Apply a downward force at the center of the arc Record force lbs and deflection in to break ' lining Compare with 551 and D39A b Dynamic Test We are currently working with the brake supplier to develop and verify a dynamic lining structural evaluation at nigh temperatures approx 500-550 This should be resolved in a approximately two weeks| e July , 1984 or before - Begin submission of final the brake suppliers to IH Finalize by August : screening data October , 1984 - IH vehicle tests complete November 1 1984 - IH field test installations complete March , 1986 - Field tests complete 150,000 mile test April 1 1986 - IH Engineering asbestos material recommendation from Meeting this tight schedule is extremely critical in order for the timely completion of our vehicle tests Also it is our goal to obtain approximately 100,000-150,000 miles on each field test unit Please indicate your willingness to participate in this program and meet tne timeframe indicated in a letter to me no later than March 20 1984 Sincerely ) Engineer Foundation Brakes ACTIVITY I. VENDOR MATERIAL SUBMISSION II ENGINEERING VEHICLE TESIS III CUSTOMER FLEET TESTS ATTACHMENT B SCHEDULE FOR ELIMINATION OF ASBESTOS FROM BRAKE LININGS AFTER_SUCCESSFUL AFTER_SUCCESSFUL MATERIAL DEVELOPMENT * 0 4 8 T 16 20 24 29 32 36 40 44 48 | | i J : SCHEDULE CONSTRAINTS I. MATERIAL DEVELOPMENT (+ { { 7 + | II TEST RESOURCES III ONE YEAR MINIMUM REQUIREMENT FOR FLEET TESTS IV ENGINEERING DESIGN AND SPECIFICATIONS | " | i IV COMPLETION OF VEHICLE TEST AND FLEET TESTS V. MATERIAL PROCUREMENT AND SCHEDULING | j V. ONE YEAR STOCK BALANCE | VI PRODUCTION IMPLEMENTATION (| VI RECODES MISBUILDS VI OSBSOLESCENCE * MONTHS FROM PROMULGATION OF FINAL RULES + A FAILURE HERE WOULD FORCE SCHEDULE BACK TO ZERO MONTH AWAITING NEW SUBMISSION OF MATERIAL FROM VENDOR International Harvester Att 1 pp 1-6 72 As a manufacturer of automobile and truck brake drums we have dynamometer testing experience with both asbestos and asbestos lined drums We have noted several areas deserving of comment and the Agency's concern prior to final rulemaking First truck brake drums with asbestos linings appear to be more load sensitive than ones with asbestos linings Our testing indicates medium friction asbestos linings may not have as high a load rating as medium friction asbestos type linings In order to meet dynamometer requirements of FMVSS 121 for effectiveness fade and recovery a higher friction rating for asbestos linings will be required than for asbestos lined drums with a given axle load What we have seen would indicate that for equivalent friction ratings asbestos linings seem to be less effective than asbestos type A less effective lining means that for given vehicle deceleration the air pressure required to effectuate a stop will increase Further with increased pressure required to brake it can be expected that the fatigue life of the brake drum will proportionately decrease Further there will result in all probability an increase in the percentage of cracked brake drums as a result of increased use of asbestos linings as used in current configuration and material speci- fications On the other hand Motor Wheel Corporation has also noted that because of reduced aggressiveness of asbestos linings brake drums will according to our dynamometer tests have an increased wear life This increased wear life however is only beneficial if the brake drums do not crack Motor Wheel's testing is not extensive enough to formulate any final conclusions However we do recommend extensive testing be undertaken to asbestos linings decisively on vehicle determine the effect of non- brake performance and brake drum life Motor Wheel Corporation pp 1-2 73 General It is Rockwell International's experience that economically and technically feasible asbestos substitutes are not developed qualified and available to cover the spectrum of vehicle brake applications Rockwell has had a substantial program underway to incorporate asbestos materials in the production of heavy vehicle brakes This program includes test and evaluation of both prototype and production asbestos brake lining The asbestos lining formulations and brake applications must not only meet our internal test requirements and the requirements of our brake customers but also the specific requirements of the National Highway Traffic Safety Administration's Federal Motor Vehicle Safety Standard No. 121 49 571.121 Rockwell International however as a purchaser of brake blocks and other lining materials for inclusion in foundation brakes is limited by the availability of asbestos materials developed by the brake lining manufacturers In many instances asbestos brake lining is unavailable to us because the materials are not fully developed at this time Basically the problem has been in finding materials to meet the test performance and durability requirements for many heavy vehicle applications Rockwell has . experienced unacceptable durability and performance problems with a number of the asbestos formulations furnished for on- and highway vehicle test programs It should be pointed out that and qualification for each of does for the very high volume it takes as much the small volume vehicles time for development test vehicle requirements as it The following two sections Rockwell Asbestos Lining Program for OnHighway Heavy Vehicles and Rockwell Asbestos Lining Programs for Highway Heavy Vehicles will summarize the current status of our non- asbestos development Rockwell Asbestos NAB Lining Program for Highway Heavy Vehicles As shown on Exhibit I attached the average yearly production estimate of heavy vehicles is approximately 652,000 units Of that number approximately 56 are highway vehicles These highway vehicles encompass three market segments and include heavy highway trucks and trailers and transit and intercity coaches Our NAB lining development for the highway vehicle market has been in process for over five years in conjunction with our lining suppliers and our heavy truck bus and trailer manufacturing customers which include Mack Ford Kenworth IH GMC Truck and Bus Freightliner Peterbilt TMC Greyhound Trailmobile Great Dane and Budd Our NAB program consists of as our internal test programs for performance and durability well as the qualification of Rockwell brakes with NAB lining under the provisions of FMVSS No. 121. During this period four replacement NAB lining formulations have been identified tested and integrated into highway vehicle applications and certified to the requirements of FMVSS No. 121. This represents significant NAB substitute progress as these applications include potentially high volume application areas On the other hand however we utilize over 24 asbestos formulations from primarily two brake lining suppliers for our complete highway brake requirements Therefore numerous additional lining formulations must be developed and certified to satisfy all highway vehicle demands The certification of the base formulations must be made on a wide range of vehicle applications with different braking systems and different basic foundation brakes including cam drum brakes wedge drum brakes and disc brakes It should also be pointed out that in certain highway vehicle categories such as mass transit coaches and braked trucks or trailers the NAB linings required for the demands of these applications are in the undeveloped category at this time These vehicles represent a relatively small but important portion of all the highway vehicle market For the majority of highway applications NAB materials are being developed that can over a reasonable period of testing qualification and NAB lining production build replace asbestos in the major portion of the heavy commercial vehicle market This would include highway trucks and on- highway trailers as shown on Exhibit , which total approximately 54 of the heavy vehicle market As stated however we would currently exclude braked trucks and trailers as well as transit and intercity coaches ' which as a group represent a small portion of the highway market Rockwell Asbestos NAB Lining Program for Highway Heavy Vehicles The typical yearly production estimate of vehicles that falls into the category of highway is approximately 44 of the heavy vehicle market This includes such vehicles as cement mixer trucks moving vehicles crane carriers ore haulers lift trucks agricultural vehicles This program has also been underway for over five years with our lining suppliers and such major highway customrs as Caterpillar FMC Grove Chalmers and John Deere As this time we have been unable to find NAB materials which are equivalent in performance and durability to asbestos linings required to satisfy most highway braking requirements The highway vehicle braking requirements are generally quite severe These vehicles cover a wide range of vocations from industrial lift trucks to giant ore haulers The vehicles vary as to width length and centers of gravity as well as loadings and operating conditions all impacting brakes Much of our brake lining suppliers NAB development and in turn Rockwell's NAB lining qualification to date have involved low and medium friction level classification applications to the higher volume highway trucks and trailers While the result is converting the largest vehicle category in the shortest time to NAB materials it must be recognized that considerable development test and qualification still is ahead the highway vehicles as well as certain highway vehicles such as transit coaches Rockwell has just begun receiving devleoped friction NAB materials for test and certification Completion of this process to cover the complete spectrum of specialty vehicles is a number of years away Summary and Recommendations The NHTSA Federal Motor Vehicle Safety Standard No. 121 for braked vehicles initiated in the early 1970's required brake certification to the existing asbestos commercial vehicle brakes Even with the already existing asbestos lining formulations it required an extended period of time to qualify and certify brakes and brake applications covering the multitude of heavy commercial vehicles Adding the need to develop and test complete new material formulations NAB results in a task that is a greater time consumer Part of the time consuming complexity is the large number of vehicle manufacturers a greater number than normally understood These exceed over three hundred in number and range from very large truck manufacturers to small specialty vehicle manufacturers Rockwell estimates that within the next several years it will be in a position to offer NAB medium friction lining formulations to our vehicle manufacturers for most of the high volume highway heavy truck and trailer brakes This would assume that the upstream lining manufacturers continue their substitute NAB formulation efforts and then can furnish quantities of NAB materials Considerable additional time however will be required to complete work on the higher friction NAB formulations for the wide variety of vehicles such as buses and the large highway vehicles Rockwell International is ) continuing to expand its NAB lining applications and production releases based on the four high volume highway material formulations already approved 2 continuing to test and evaluate new onhighway NAB lining formulations in the engineering and development mode 3 initiating highway prototype NAB lining field test programs on haulers loaders forklifts 4 continuing to aggressively support vehicle manufacturers field test programs and 5 accelerating test efforts on newly developed NAB materials in order to expand the application approval base YEARLY PRODUCTION ESTIMATE OF THE HEAVY VEHICLE MARKET fi - 652,000 UNITS Includes On Highway Heavy Trucks braked straight trucks braked tractors braked fire engines braked military trucks etc. Highway Heavy Trailers braked vans braked reefers braked flat beds braked liquid tankers etc. Coaches braked transit coaches braked intercity coaches Highway Heavy Vehicles Some move from site on the highways trucks braked crane carriers ore haulers haulers moving vehicles agricultural vehicles etc. braked mixer lift trucks earth- MARKET SEGMENTS Highway Heavy Trailers 145,000 Units we LoS > < Highway HeavyDuty Trucks 209,000 Units Coaches 7,000 Units Highway Market - 56 (Ae Highway Market - 44 Highway HeavyDuty Vehicles 291,000 Units Based on an average production year in each category we Some of these large vehicles incorporate drum or disc hydraulic foundation brakes Rockwell International pp 1-6 BFGoodrich uses several types of brake lining other than asbestos containing linings in our brake systems including resin bonded metallic and sintered linings Due to the performance and wear characteristics of the used in our brake systems and our customer various linings requirements we currently containing supply about 80 of our systems with asbestos linings 15 with resin bonded metallic linings and % with sintered metallic linings Our Division has an ongoing program to evaluate new types of asbestos free lining materials To date we have not been able to find suitable asbestos free substitutes for the asbestos containing linings used today in the majority of our braking systems The major stumbling block linings for use in our in finding acceptable asbestos free braking systems has been inferior performance and wear characteristics versus asbestos containing linings The asbestos free linings evaluated to date fade more than asbestos containing linings Both characteristics are undesirable A second hurdle is in finding asbestos free lining materials to evaluate The highway segment of the automotive market is a very small segment of the total market and there is little research aimed at producing an asbestos free alternate lining for this market BF Goodrich Company pp 1-2 75 In determining whether a product is a suitable substi- tute for asbestos in brake applications the factors to be taken into account include the constant coefficient of friction the rate of wear the thermal stability the strength the absence of scoring to the drum or rotor the noise generated by and the cost of the products being compared From our research asbestos has certain unique qualities which have as of 1985 not yet been duplicated for most brake applications in terms of friction performance thermal stability wear resistance strength and cost See e.g. Loken Halvary Asbestos Free Brakes and Dry Clutches Reinforced with Kevlar Aramid Fiber Paper 800667 SAE 1980 We understand that the asbestos fiber in friction mate- rials for brake application is chrysotile That fiber has special characteristics including its ability to stiffen and strengthen the resin matrix which makes up the brake lining and can maintain these properties even under high temperatures Pye A.M. A Review of Asbestos Substitute Materials in Industrial Applica- tions Journal of Haz Matls 3 125-147 1979 glazing High wear on brake linings may cause what is which can cause a reduction in the coefficient termed of fric- tion This reduction is avoided by allowing for a slow alteration in the brake lining materials The chemical change brought about by heat to chrysotile fibers restores the friction surface so as to reduce or eliminate the glazing effect Nicholson W. Investigation of Health Hazards in Brake Lining Repair and Maintenance Workers Occupationally Exposed to Asbestos Task I Brake Materials Products and Usage Draft report submitted to OSHA by Environmental Sciences Laboratory Mt. Sinai School of Medicine New York January 1979 The possible substitutes for asbestos in brake applications metallics and organic fibers are substantially more expensive than asbestos Further metallics cause greater rotor or drum wear and are quite noisy Aramid fibers tend to clump thereby requiring certain mixing procedures Loken SAE 1980 The petition of the Natural Resources Defense Council NRDC misstates the facts when at page fifteen of the Petition it asserts that reinforced brakes have the same basic formulation as asbestos brakes and therefore production techniques already developed for asbestos brake manufacture can easily be retained It is importantto note that NRDC's support for the quoted phrases is Loken However Loken offers no support for the NRDC assertion Other possible substitutes include glass which can melt at high temperatures reached in normal brake applications and be converted through the heat to a form of lubricant ver- miculite which is platy rather than fibrous and therefore does not have the capacity to strengthen the resin mix which asbestos does and silicon nitride and carbon composites which have limited specialized applications such as the Concorde SST or racing cars and are very expensive The foregoing research does not suggest the absence of progress in attempting to find substitutes for asbestos in brake applications For example metallics have been substituted for asbestos in disc brakes front brakes in downsized cars However they are not suitable for rear drum brakes on most American cars and trucks because they cannot be processed into the required arcuate shape In any event more testing must be done on metallics before they could be regarded as safe substitutes for asbestos in brake applications With respect to the substitutability of other products for asbestos in brake applications we enclose a portion of a report prepared by John W. Kourik Chief Engineer Brake Products and presented to the 1980 Society of Engineers Congress in Detroit Michigan Mr. Kourik concludes that while efforts are being made to find replacements for asbestos in brake applications those efforts have not yet been achieved In determining whether to cause the discontinuance of asbestos in brake applications the EPA must take into account not only the uncertainty associated with the health risks claimed to be attributable to exposure to asbestos but also the fact that there is yet no reliable substitute for asbestos as a component for brake lining in most brake applications To accept substitutes without thoughtful and reliable testing programs invites a significant safety hazard for drivers and passengers of vehicles and bystanders as well Moreover it is neither prudent nor costeffective for EPA to require a complete substitute for asbestos on all brake applications Brake systems are very sophisticated and contain many components each of which must have characteristics perfectly compatible with the characteristics of the other components One cannot reliably remove one component of a brake system such as friction material containing asbestos and re- place it with another without considering the effect such sub- stitute will have on the brake system's performance coefficient of friction durability maintenance requirements and noise pro- duction Wagner Division Att 1 pp 1-6 CONSIDERATION ON REGULATING THE 76 WAGNER COMPOSITION OF BRAKE LININLININGG John W. Kourik Chief Engineer Brake Products Wagner Electric Corporation 1980 SAE Congress Detroit Michigan February 25 1980 STATE OF ASBESTOS LINING recent The most press industry releases and magazine articles imply that there is an almost immediate capability to eliminate asbestos from brake lining Such claims are not representative of the true state from asbestos linings We base this belief on the small number of test materials that we have had from lining manufacturers We'll help you look at the overall scope of the market and the need to evaluate the success or failure of the tests of these materials before concurring in the validity of the development claims We also must determine their true availability facturer and use these findings to see based if we on committed tooling by the manu- can procure the material needed to service a very extensive market Let's look at the number of applications that need to be covered by D friction materials in the braking area only Friction requirements are different for a variety of vehicles because of the different types of appli- cations the type the speeds or service at which they operate the frequency of brake applications and the durability needed to have long intervals between relining 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 NUMBER OF LINING COMPOUNDS SOURCES PASSENGER CAR 20 5 TRUCK SEGMENTS 18 5 TRUCK BLOCKS 16 6 CUMULATIVE 50 10 Let's look at the characteristics that are needed for OEM and replace- ment materials Most of these are explanatory DESIRABLE CHARACTERISTICS OF A SUITABLE LINING MATERIAL STRUCTURALLY SOUND NO MORNING SICKNESS * LONG ROTOR LIFE LONG WEARING CONSISTENT FRICTION - HOT & COLD ACCEPTABLE NOISE LEVEL ACCEPTABLE WATER RECOVERY PHYSICAL FLEXIBILITY FOR ATTACHMENT TO SHOES USING STANDARDIZING SEGMENTS LIGHT WEIGHT * Erratic braking or grabby lock up on first stops Now consider the variety of brake designs used on old and new vehicles PASSENGER CAR & TRUCK HYDRAULIC BRAKE TYPES TRUCK TRACTOR & TRAILER AIR BRAKE TYPES INDUSTRIAL BRAKES EXTERNAL SERVO CAM AIR SERVO DISC DISC WEDGE HYDRAULIC SPRING SOLENOID There is considerable technical literature available on the subject of brake goemetry and effect of friction materials on design performance and speed sensitivity We have submitted several of these and their bibliographics to the CPSC dockets for reference purposes Considering all of the above brake types it appears likely that only the passenger car and light truck disc brakes will have a suitable asbestos friction material available in the reasonably near future There will be a long transition as development efforts continue to be directed towards the availability of 1 a substitute material that will allow vehicles to remain at or exceed today's safety level 2 a suitable substitute for current asbestos based materials at a reasonable cost 3 a long wearing lining material that also causes minimal drum wear or little rotor wear At this time we have an insufficient number of samples to predict a realistic target date for conversion to asbestos strip segment or block material We expect this to be at least several years away We look with askance at the press releases extolling the imminent availability of non- asbestos lining materials without citing the limited number of applications covered Wagner Division Att 2 pp 1-5 The 19.2 19 How asbestos grand total of lives saved if EPA grants the petition now is in the occupational field and 0.2 in the general public sure must EPA be that there is a satisfactory substitute for brake materials to make a decision on less than 20 lives per year 108 There are about motor vehicles on the road traveling about 208 208 miles per year My experience has been that a cag needs new each brakes at about ^ 10 miles This calculates to 25 x 10 brake jobs Let us assume that it takes ten catastrophic brake failures to per year actual a fatality I expect that the number is somewhat less cause 200 added failures out of 25 x 10 brake jobs will exactly balance Thus the savings postulated from the proposed ban That requires a confidence of 99.9992 that any proposed substitute is at least equal to asbestos as a brake material Does the Agency have that confidence or data to suggest that such a conclusion is secure is no assurance that any new forced substitution of materTiahlesre woceurltdaibnelybetter than 99.999 successful day after day year after year John T. Barr pp 2-3 4 78 Finally testimony submitted to the EPA primarily in 1984 is sharply critical of metallic friction compounds in general These compounds represent the first generation of asbestos friction materials that has experienced wide distribution While analysis of individual semi- metallic formulations and commerical products is valuable the EPA should not rely entirely on evaluations made on earlier models Rather contact firms whose entire business or the majority of their it should business depends upon manufacturing metallic friction products Such companies market and sell products to customers worldwide with primary emphasis on Canada Europe and the United States These firms technical perspectives on the advantages disadvantages and state of the art in metallic brakes may differ from the previous EPA testimony Engelhard Corporation p 6 79 We believe that it is useful for your agency to encourage the development of nonasbestos brakes but not at the expense of brake performance In only one of the vehicle brake categories light and medium disc brake pads did feel that a satisfactory performance record was evident for nonasbestos you did not have sufficient experience brakes The other vehicle brake categories with the performance record or found that the products performed erratically Motor vehicles are the leading cause of death from injury They are the of loss of life from age 1 to 44 and the leading cause of loss leading causes Even a small amount of of preretirement years of life in the United States erratic brake performance could easily outweigh the potential morbidity and mortality saved by reducing ambient air asbestos by 0.23 to 1.3 percent Much of this decrease could be gained by adequate work practices during mechanical servicing of brakes A reduction in ambient air elimination of asbestos in should be strongly weighed asbestos levels should be encouraged but the brake pads as a means of accomplishing this goal against the safety performance of alternatives Center for Environmental Health p 1 F. Special Considerations for Existing Vehicles 80 The matter of replacement brake linings for older model vehicles still in service warrants additional discussion The general control approach to asbestos in brake linings is to develop substitutes This approach is acceptable for new vehicle designs because brake systems can be engineered around the characteristics of the substitute Substituting asbestos brake linings without redesigning the brake system may result in reduced lining durability adverse effects on other brake system components and even increased stopping distance Thus using asbestos substitutes in brake linings without carefully evaluating the consequences could result in trading reduced health risks for increased traffic safety problems Accordingly the continued use of containing replacement brake linings with proper control measures may be a neccessary alternative for the period of time vehicles with asbestos dependent brake systems are a significant segment of the vehicle population Motor Vehicle Manufacturers Association Att 2 pp 13-14 a TV TV 71 71 71 81 As owners of antiques collectors and special interest automobiles dating back to the 1920's we strongly object to the use of semimetallic or aramid fiber brakes especially in our older automobiles which are not equipped with power brakes These asbestos brakes do not provide adequate stopping distance when they with are cold and this front disc brakes is much more Furthermore pronounced in cars equipped semimetallic and aramid fiber brakes cost would put a two to three times more hardship on some of our than asbestos brakes which members who own several olaer automobiles Classic Cars of Ponca City p 1 82 POTENTIAL IMPACT ON SERVICE PARTS The possibility of a total ban on containing components raises another concern that of the impact of such a ban on the availability of market service parts if worn containing components must in the future be replaced with containing components Aftermarket demand for service parts steadily decreases as the age of a vehicle increases beyond the peak service years IH fears that parts suppliers will not be willing to spend the resources for necessary to develop and produce asbestos substitutes shrinking markets for production brakes There simply may be no economic justification for such an investment International Harvester p 5 83 Asbestos replacement products are are available on the market some of which are of satisfactory quality but these these always have a lower friction coefficient use of these products is therefore only possiblepossible on brakes which provide for this installation from the outset It is not always possible possible to accomodate brakes capable of being fitted with asbestos linings on small vehicles On use vehicles asbestos linings must never be replaced by asbestos linings this could substantially modify braking performance either immediately or following partial wear and could therefore entail considerable risks to safety Renault USA Inc. p 2 84 Vehicles in use are more than hundred brake and brake lining There sizes designed for vehicles still in use that must be serviced It would be a monumental task with substantial economic involvement for service part suppliers to develop asbestos replacements for those applica- tions Motor Vehicle Manufacturers Association Att 3 p 8 85. One particular problem that concerns us and that we feel must be highlighted is the continued availability of containing parts for vehicles currently in production or no longer in production which employ such parts Ford Motor Company through its Parts and Service Division is a major marketer of aftermarket disc and drum brakes and related brake system parts Currently the Company's aftermarket parts distribution system has on hand some 51,000 asbestos brake parts in stock at eight depots in the U.S. and Canada These parts involve 192 different brake system designs We supply these parts mostly pads shoes discs and drums for cars and trucks produced by the Company between 1957-1985 -- a period of 28 years It is imperative that parts for these vehicles continue to be available to our dealers and customers for the remainder of the product's useful life and that any regulatory program envisioned by EPA not interfere with that need Car and truck brakes are sophisticated systems made up of parts which are carefully matched to function compatibly with each other so as to provide appropriate braking characteristics for their vehicles under a wide range of operating conditions A brake system is not simply a collection of disparate parts -pads shoes discs drums etc. The pads and shoes of car and truck braking systems that use asbestos friction materials have very different properties from the pads and shoes of those that do not contain asbestos One cannot simply use a asbestos substitute brake shoe in conjunction with a drum that was designed for an containing friction material Likewise a disc brake that was designed for a metallic friction material will not perform satisfactorily if an containing pad is substituted A whole host of performance noise durability and other problems may occur if a friction material is introduced into a system which was not designed to employ it Ford Motor Company p 2 , CRITICISMS OF NRDC PETITION AND EPA RESPONSE <7 1 A. NRDC Petition COMMENTS ON THE 86 - NRDC PETITION TO THE ENVIRONMEHTAL PROTECTION AGENCY TO BAN THE USE OF ASBESTOS IN AUTOMOBILE BRAKES PETITION SECTION I. INTRODUCTION The introduction of the NRDC petition emphasizes that the and cancer has been conclusively link between asbestos exposure since the early 1950's While demonstrated by epidemiologists of sufficient this may be true for certain occupational exposures demonstrated between length and quantity no association has been exposure to brake dust and cancer The introduction expresses an underlying assumption that no safe threshold levels of exposure to asbestos can be established which is the subject of intense debate in This is an assumption is directly contrary to the the occupational health community community and assumption made by NIOSH in establishing threshold limit values The second expressed assumption assumption of the introduction is that feasible substitutes are available for use in brake linings However as discussed in other other portions of our submission this is not completely true PETITION SECTION IV THE CONTINUED USE OF ASBESTOS IN VEHICLE BRAKE LININGS POSES AN UNREASONABLE RISK TO HEALTH is The petition asserts that that asbestos is one of the largest human cancer in the United States single causes of environmental environmental No reference is cited to support this claim There no because asbestos has has not been associated with human reference cancer outside of specific occupational occupational settings The leading environmental causes of cancer cancer are smoking diet and other lifestyle factors not asbestos asbestos 1978 Health Education and Welfare paper cited announcing The deaths over the next several decades is that 17 percent unpublished of cancer scientifically inconsistent and frequently reviewed and an document The report remains peer inaccurate unaccepted in the scientific community A. Increased Risk of Disease This section stresses the mortality statistics associated with asbestos disease The studies from which the statistics are taken relate to insulation workers and are not relevant in the context of friction materials It is the amount and length of exposure that is significant not the exposure per se subsequent The assertion is made that animal inhalation studies demonstrate no significant difference in the effects of various types of asbestos NRDC cites a 1974 study by Wagner as authority for that statement The petition neglects to point out that numerous animal 4,5 experiments including the work of Gross demonstrate precisely the opposite These latter studies would tend to indicate that chrysotile the only type of asbestos used in brakes is significantly less pathogenic than other types of asbestos fibers B. Brief and Term Exposure to Asbestos This section stresses that both brief and term can result in asbestos disease exposures of the sources cited has anything to do with Again none There is no evidence in the medical friction products literature demonstrating any significant risk from either brief or term exposure to friction products 1 Health Risks From Asbestos Brake Products This section begins by asserting that brakes create substantial exposures to asbestos which constitute a serious health threat not only to brake workers but to the general public No scientific basis is referenced for this broad statement The petition asserts that a fraction of process The reader conclusion that this that numerous studies have shown asbestos fibers survive the braking of this sentence might draw the fraction is a significant one The petition neglects to indicate that the three principal studies the subject indicated precisely the opposite Anderson found less than .02 percent of the fibers survived the friction process Lynch 8 found less than 1 percent and Jacko found less than .3 percent More formed in the than 99 percent of the friction process into fibers are transa nonasbestos nonfibrous dust This section stresses the ambient air particularly levels are increasing A danger of asbestos fibers in in urban areas where asbestos private letter from Dr. Wm Nicholson of Mt. Sinai New York City is cited as authority for the proposition that asbestos content in ambient air is this from increased automobile brakes This conclusion is not based upon any published evidence In fact there are several references , which indicate that less than 1 percent of asbestos fibers in city core districts originated from disc brake wear The petition discusses the Jacko Bendix study and cites it for the proposition that American vehicles release approximately 158,000 pounds per year of asbestos into the atmosphere This misrepresents Jacko's findings 158,000 pounds represents the total estimated asbestos emissions potentially produced from brake linings by the friction process Only 3.2 percent or 5,060 pounds of that was found by Jacko to be airborne asbestos fibers 85.6 percent of the asbestos emissions do not remain suspended and dropout _ from the atmosphere' This section goes on to discuss Rohl's 1976 study on the asbestos content of brake dust It notes that Ronl found that more than 80 percent of the surviving fibers were 0.4 micron in length but fails to mention that such short fibers are considered by many respected medical authorities not to be pathogenic at all 12 This section of the petition concludes with the sentence that the problem of exposure to dangerous levels of asbestos during brake servicing is substantial and that he small asbestos fibers from brake wear can easily penetrate throughout the respiratory system and also migrate to other organs in the body The conclusion is not supported by studies which indicate that the smaller fibers present during brake servicing are less and more likely to likely to be deposited in the lung be removed by macrophages , Automobile Maintenance Workers Are At Particular Risk From Exposure To Asbestos Brake Products This section argues that because of the airborne mobility of these small asbestos fibers from brake linings a diverse group of people are at risk The petition includes garage mechanics bystanders tool booth operators families of mechanics and persons living in urban environments as the population at risk The only two citations upon which this argument is based are two case reports which purport to document a mesothelioma in a pet whose owner was a mechanic and a brake mechanic's child who had mesothelioma The latter case is not footnote indicates a published case report but the that this was communicated in a letter from Barry Castleman to a person or persons unknown ' One case report of a pet and a letter from Barry Castleman statements made are scant support in this section for the sweeping This section concludes by alleging that recent literature also documents mesothelioma among automobile repair workers Greenberg's 1974 The first report literature cited is which found one mesothelioma death in a motor mechanic Greenberg gives no occupational history for the mechanic The other case report cited is that by Langer in 1982 Support for the proposition that there are two additional mesotheliomas in brake mechanics is allegedly found in Castleman's recent book on asbestos and a personal communication by Susan Daum to Castleman Yet important data on these cases are missing such that verification is not possible from these sources alone Thus there are only two cases of mesothelioma in all of the reported medical literature which allegedly implicate brake dust One of those Greenberg is questionable RTP Motor Vehicle Manufacturers Association Att 1 pp 1-5 87. I - INTRODUCTION The stated reasons for the submission of the petition do not appear to be based upon irrefutable evidence Whether or not the occupational asbestos standards and the national emissions standards are insufficient to protect against unreasonable risk posed by asbestos in brakes is highly debatable Further the availability of economically and technologicalltechnyologicaly feasible substitutes for asbestos is an issue in which the friction materials manufacturers are deeply involved The identification of such substitutes is a major ongoing program with the manufacturers and is not a completed program at this point in time II - JURISDICTION The FMSI concerns relate to plant regulations versus control of general public exposure to asbestos dust While one agency has proposed to tighten eliminate worker exposure to asbestos another is being peritioned to asbestos in friction materials The disparity between these two situations could well create implementation and economic problems for friction materials manufacturers If asbestos is to be regulated out of friction materials the manufacturers should not be saddled in the meantime with compliance to new tighter regulations of asbestos in the workplace The industry must know which direction regulatory activity will take III - DESCRIPTION OF PETITIONER No comment 37 37 0 0 0 IV - CONTINUED USE OF ASBESTOS AN UNREASONABLE RISK TO HEALTH of The FMSI does not necessarily agree with the credibility of the con- clusions drawn from the evidence presented on friction materials in this section Therefore the FMSI reserves the right to comment in detail on this section at some Suture date V - SUBSTITUTES Sufficient data is not available at this time on the substitute materials to state that they do not pose a hazard in the workplace environment or to the general public We wish to cite a recent study by the Canadian Royal Commission on Matters of Health and Safety Arising from Use of Asbestos in Ontario and an earlier paper on asbestos Related Malig- nant Mesothelioma These comments follow follow ... the producprodtuction ion of of substitute substitute fibres in the future should increase the exposure of workers to long thin durable fibres of dimensions similar to those we have found hazardous for asbestos we cannot be sure that serious health consequences would not result To the face of the existing evidence we believe it would be risky to allow the exposure of workers to respirable fibres longer than 5 microns with small diameters of any material if those fibres are likely to be very durable in the lungs It has been generally accepted now carcinogenic is a durable long and of less than 1.5 micron and length that the fibre which is thin fibre the diameter of more than 8 micron appearing critical asbestos can appear been established as A number of Fibrous materials other than in this size and shope and indeed have Couse of mesothelioma in animals such as glass fibres aliunde aliunde silicon carbide and ~ tassium tremolite titanate attapulgite dawsonite of metallic brake linings cited in Section - are The advantages not necessarily supported by test results generated by friction materials Manufacturers While certain of these claimed advantages may be true where the application generates high braking temperatures they are not necessarily true for the average consumer Total endorsement of Section B of the petition is not appropriate since friction materials manufacturers produce disc pads and drum segments for passenger cars and light to medium trucks as well as brake blocks for heavy trucks The claims made in Section b relate to brake blocks and cannot be ardorsed for all product lines Further actual experience to date has proven that substantial processing modifications and new equipment are required for the asbestos substitute materiais VI - A REQUIREMENT UNDER THE TOXIC SUBSTANCES CONTROL ACT No comment WWEEII CONCLUSION CONCLUSION oo CONCLUSION CONCLUSION CONCLUSION CONCLUSION No comment Friction Materials Standards Institute Inc. Att 1 pp 1-4 Ce 10 10 88 The petition of the Natural Resources Defense Council NRDC misstates the facts when at page fifteen of the Petition it asserts that reinforced brakes have the same basic formulation as asbestos brakes and therefore production techniques already developed for asbestos brake manufacture can easily be retained It is important to note that NRDC's support for the quoted phrases is Loken However Loken offers no sup- port for the NRDC assertion We would also like to point out that the statements by NRDC regarding the risks associated with asbestos fail to take into account the distinction between insulation asbestos which is not involved in brake application and chrysotile fibers which are Wagner Division Att 1 pp 3 5 B. EPA Response 89. Second AIA wishes to comment on a major omission in the December absence of any mention of the 19 response namely the complete health effects of substitutes for asbestos in brakes Any sub- of material or proatteinotnialal system of regulation in which the use a risk stance may be prohibited for reasons rem lu as tetd it nocluadne unarneaesvoanlaubalteion of of injury to health or the environment from substitute materials If this were not the the risikts woruelsdultniontg be possible to say that any benefit had accrued case to society as a result of a regulatory action Section c of the Toxic Substance Control Act TSCA specifi- cally cites that substitutes for a substance must be given consideration in the context of section 6 rulemaking C the benefits of such substance or mixture for various uses and the availability of substitutes for such uses that a consideration of the availability of While it may be argued consideration of the health substitutes does not necessitate a of the substitutes the immediately following section which evalua- elfifsetcstsadditional factors to be considered would require an tion of substitutes health effects D the reasonably ascertainable economic consequences of the rule after consideration of the effect on the national economy small business technological innovation the environment and public health emphasis added Section D is explicit in stating that ctohnesiednevriartoinomnent Ifanda psuubb-lic health effects ofbananerduleinmufsatvorbe ofgivseunbstitute materials Section 6 stance cD is to be requires that the environmental and public health effects of would have to such an action be considered and such consideration take into account the environmental and public health effects of the substitute materials Any other course of action would be ir- rational and not permissible under TSCA The entire Toxic Substance Control Act is framed within the context action It does not permit the regulation of reasonable regulatory unreasonable risk The intent of Congress in of any risk but only issue Section c of TSCA passing the Act is specific on this entitled Intent of Congress states It is the intent of Congress that the Administrator shall carry out this Act in reasonable and prudent manner and that the Administrator shall consider the environmental economic and social impact of any action the Administrator takes or proposes to take under this Act Asbestos Information Association p 2 90 The Notice points out that there are 2,750 employees potentially exposed during brake manufacture and 550,000 during servicing and repair This last figure is greatly exaggerated for almost no one repairs or services brake linings any more They are simply replaced and the old ones are discarded with minimal exposure but let's play the game by your ; rules and go with that number ~ John T. Barr p 1 APPENDIX A - LIST OF COMMENTERS TRADE ASSOCIATIONS Asbestos Information Association America Friction Materials Standards Institute Inc. Japan Automobile Manufacturers Association Motor Vehicle Manufacturers Association VEHICLE MANUFACTURERS Chrysler Corporation Ford Motor Company International Harvester Renault USA Inc. BRAKE MANUFACTURERS BF Goodrich Company Motor Wheel Corporation Rockwell International Wagner Division SUBSTITUTES MANUFACTURERS Ashland Petroleum Company Du Pont Canada Inc. Engelhard Corporation Monsanto Company MISCELLANEOUS John T. Barr Center for Environmental Health Classic Cars of Ponca City Stratford Citizens Against Pollution APPENDIX B - REFERENCES Asbestos Information Association America - Letter to EPA dated March 7 1985 Ashland - - Petroleum Company Letter to EPA dated March 14 1985 Attachment News From Ashland Petroleum Company February 8 1985 Carboflex Product catalogue Press release Barr John T. - Letter to EPA dated January 15 1985 BF Goodrich Company - Letter to EPA dated March 5 1985 Center - for Environmental Health Department of Letter to EPA dated February 6 1985 Health and Human Services Chrysler Corporation ~ Letter to EPA dated March 13 1985 Classic Cars of Ponca City - Letter to EPA dated March 7 1985 Du Pont Canada Inc. - Letter to EPA dated January 23 1985 - Attachment 1 - Breakthrough in Brake Performance Du Pont Magazine - Attachment 2 - Kevlar Demand High Canadian Metallic Sales Up Du Pont News August 1984 - Attachment 3 - Asbestos Disc Brake Pad Wears Like Metallic Not Detrimental to Rotor Surfaces Du Pont News - Attachment 4 - Kevlar Relieves Tension Headache for Belleville Maker Du Pont News June 1984 Engelhard Corporation - Letter to EPA dated March 13 1985 Ford Motor Company - Letter to EPA dated March 15 1985 Friction Materials Standards Institute Inc. ~ Letter to EPA dated March 13 1985 - Attachment 1 - Letter to EPA dated November 13 1984 International Harvester - Letter to EPA dated March 15 1985 - Attachment 1 - Letter to Mr. Eaton dated March 8 1984 Japan -~ - Automobile Manufacturers Association Letter from Tanaka Walders & Ritger Attachment 1 - Comments of the Japan dated March 22 1985 Automobile Manufacturers Association Stratford Citizens Against Pollution - Letter to EPA dated March 12 1985 Monsanto Company - Letter to EPA dated March 15 1985 Motor Vehicle Manufacturers Association ~ Letter to EPA dated March 15 1985 - Attachment 1 - Comments on the NRDC Petition to the EPA to Ban Use of Asbestos in Automobile Brakes - Attachment 2 - Comments on Proposed Asbestos Standard of the Occupational Safety and Health Administration May 24 1984 - Attachment 3 - Alternatives to the Uses of Asbestos in Motor Vehicles revised March 1985 - Attachment 4 - Letter from the Friction Materials Standards Institute to U.S. Department of Labor May 22 1984 the Motor Wheel Corporation - Letter to EPA dated March 14 1985 Renault USA Inc. 1 - Letter to EPA dated February 21 1985 Rockwell International - Letter to EPA dated March 18 - Attachment 1 - Letter to U.S. 1985 Department of Labor May 25 1984 Wagner - - Division Edison International Inc. Letter from McDermott Will & Emery to EPA dated April 4 1985 Attachment 1 - Response of Wagner Division of Edison International Inc. to the Petition of the NRDC re Asbestos Brakes Attachment 2 - Consideration on Regulating the Composition of Brake Lining February 25 1980 APPENDIX C- CROSS REFERENCES Commenter Asbestos Information Association Comment No. 1 22 24 89 Ashland Petroleum Company 13 50-53 Barr John T. 52272 52272 52272 52272 52272 9 BF Goodrich Company ao Center for Environmental Health ca ca 5230 Chrysler Corporation 5230 5230 5230 Classic Cars of Ponca City 22 22 81 Du Pont Canada Inc. 14 54-63 Engelhard Corporation 15 41-45 78 Ford Motor Company 6 69- 85 Friction Materials Standards Institute Inc. 2 23 66 87 International Harvester 7 70-71 82 Page No. II 5,6 13 15 13,14 18 II 7,8 IV 14 11 IV 18 IV III III 40,41 19 III IV 15 16-23 16 3-7 IV 8 IV IV 4,5 II 35,36 8-10 9 43-52 IV CROSS REFERENCES continued Commenter Comment NO Japan Automobile Manufacturers Association 3 38 67 Stratford Citizens Against Pollution 220 220 Monsanto Company 16 46-49 Motor Vehicle Manufacturers Association . 4 27-28 31-34 37 64-65 80 84 86 Motor Wheel Corporation ON ON Renault USA Inc. Rockwell International 8 mm mm | 11 73 Wagner Division Edison International Inc. 12 26 30 75-76 88 Page No. 5,6 19,20 37-39 20 III 16 9-11 6 4,5 7-15 17,18 26-34 IV IV 3-7 11 53 9 III IV 12 54-57 13 3,4 III 59-66 11 | LITERATURE CITED DRAFT Ahmad N. D. Walgenbuch and G. Sutter 1979. Degradation Rates of Technical Carbofuran and a Granular Formulation in Four Soils with Known Insecticide Use History Bull Environ Contam Toxicol 572-574 M. and M. Aleem 1961. Effect of Chemical Structure on Alexander Microbial Decomposition of Aromatic Herbicides J. Agr Food Chem 44-47 Alexander M. and B. Lustigman on Microbial Degradation of Chem 410-413 1966. Effect of Chemical Substituted Benzenes J. Structure Agr Food Allred R. E. Setzkorn and R. Huddleston ability as Shown by Various Analytical Chem Soc 13-17 1964. Detergent Biodegrad- BiodegradTechniques J. Am Oil Ambrose the R. Jr. Chemical S. Hill and L. 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