Copper-Free Brake Initiative: Brake Manufacturers Road to Compliance - - PDF document

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Copper-Free Brake Initiative:

Brake Manufacturers’ Road to Compliance and Industry OESC Exemption Self-Certification Proposal

STATE OF WASHINGTON DEPARTMENT OF ECOLOGY 16 OCTOBER 2019

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About MEMA & BMC

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The Brake Manufacturers Council (BMC) is a product council of the Automotive Aftermarket Suppliers Association (AASA) – a division of the Motor & Equipment Manufacturers Association (MEMA)

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BMC members are primarily manufacturers of automotive and light truck brake components and brake friction materials. Other BMC members include testing and quality control companies.

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BMC and MEMA work together to advocate on legislation and regulations impacting brakes, brake friction materials and related components.

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/autoalliance /auto_alliance AutoAlliance.org

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Phasing Out Copper in Brake Friction Materials

(a.k.a. brake pads or brake linings) 

In 2010, laws* in States of Washington and California required manufacturers of brake friction materials to phase out the use of copper and other constituents

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In 2012, Washington adopted regulations

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In 2015, MEMA/BMC led coalition of key industry stakeholders to a nationally- focused, voluntary MOU commitment with U.S. EPA and ECOS

 MOU facilitates nationwide phase out of

copper – modeled on CA and WA requirements

 https://www.epa.gov/npdes/memorandum-

understanding-copper-mitigation- watershed-and-waterways

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* State of Washington signed SB 6557 into law in 2010. The “Better Brakes” Rule was adopted in 2012 (Washington Chapter 173.901 WAC). The State of California signed SB 346 into law in

• 2010. The “California Brake Friction Material Requirements” went into effect January 1, 2017.

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As a result of the CA/WA laws/regs and industry-government MOU, BMC brake friction material manufacturers have been:  Expending significant resources

• researching, developing, reformulating,

testing, certifying alternatives to copper

• registering and marking brake

formulations

 Complying with “A” level Asbestos, Cr(VI), Pb, Hg, Cd  Producing early compliant brake pads “B” and “N” levels

The Road to Compliance

• In 2019, almost 50% of

current registered brake friction materials meet “N” level (<0.5 wt%)

• Over 13,000 product

identities have been registered in the State of WA; all BMC members that manufacture friction products are among the 117 companies who registered their products.

• NSF Certification Website:

http://info.nsf.org/certified/f riction_materials/listings.asp ?

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Washington Better Brakes Law

WAC 173-901-060 Self-certification of compliance. “(1) Manufacturers of brake friction material must certify to the department that any brake friction material that is sold or offered for sale in Washington state complies with the requirements ...”

This includes elements such as:

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Lab testing

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Compliance marking

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Industry-sponsored registrar listing and reporting

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Self-certification documentation

Allows for Self-Certification of Compliance 6

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Washington Better Brakes Law

WAC 173-901-150. Brake friction material manufactured as part of an original equipment service contract (OESC) (3) A vehicle manufacturer must have a system in place to ensure that brake friction material manufactured as part of an OESC is only installed on the vehicles for which it is designed. (4) How does a manufacturer of brake friction material manufactured as part of an OESC certify compliance with the requirements of chapter 70.285 RCW and this chapter? * * * (b) If the brake friction material contains more than the specified concentrations, the manufacturer of the brake friction material must follow the same procedure outlined in WAC 173-901-060 except that: * * * (iii) Brake friction manufacturers must include in the self-certification documentation, submitted to the department and an industry-sponsored registrar, a description of the vehicle model and its year of manufacture for which the brake friction material is manufactured.

Allows for Exemption of Original Equipment Service Contract (OESC) Brake Friction Material

OES defined as: “brake friction material provided as service parts originally designed for and using the same brake friction material formulation sold with a new motor vehicle.”

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Basic Supply Chain Structure for Original Equipment in New Vehicles

8 Installs Finished Components / Systems During Final Vehicle Assembly Components and/or Parts Parts, Subcomponents and/or Materials Individual Components and/or Complete Systems

OEM Tier 1 Tier 2 Tier 3

Most brake friction material manufacturers fall in this category

Rarely does an OESC exist directly between OEM and brake friction material manufacturer

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Currently Reported for Self-Certification

Tier 2 Brake Friction Material Manufacturer

Lab Tests/Results Formulation ID by “Edge Code” Compliance Level “A” “B” or “N”

Registrar

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Requirements for OESC Self-Certification

10 WA Regulation: “… a description of the vehicle model and its year of manufacture for which the brake friction material is manufactured. ” WAC 173-901-150(4)(b)(iii):

Tier 2 Brake Friction Material Manufacturer

Lab Tests/Results Formulation ID by “Edge Code” Compliance Level “A” “B” or “N”

Registrar

Automaker/OEM Tier 1 Brake System Supplier

T2 supplies T1 with brake friction material T1 assembles brake system with T2 friction installed

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For self-certification of OESC brake pads – due to the lower volumes of impacted products – industry proposes a narrow scope to self- certify OESC only on vehicles model year 2014 and newer

WAC 173-901-060(8) Brake friction material manufactured prior to 2015 is exempt from self- certification of compliance.

OESC Self-Certification Proposal

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All Brake Friction Materials

OE Brake Friction Materials

OE Service Contract Brake Friction Materials

OESC Brake Friction Materials that Need an OESC Exemption (i.e. only meet “A” level compliance)

Aftermarket Original Equipment 11

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Brake Hardware Evolves Over Time…

Industry proposes to self-certify for OESC on vehicles model year 2014 and newer

Requirements change, and supplier business awards change as vehicles evolve. This drives hardware changes that physically alter the shape of the pad.

Pads from old brake designs cannot physically fit to newer vehicles for which no OESC exemption exists.

2008 Malibu Front Brake 2013 Malibu Front Brake 2016 Malibu Front Brake

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T2 Brake Friction Material Supplier

OESC Self-Certification Proposal

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Using FMSI database and internal company data, T2 brake friction supplier may be able to access edge codes of “A” level compliant formulations and make/model specific to customers’ OE pads Does have friction formulation edge code ID, compliance level May not have vehicle make/model/year specific for each friction

• formulation. But some limited information can be accessed via FMSI data.

FMSI Database Self-Cert Data OEM Vehicle Manufacturer

Does have clear linkage of vehicle make/model/year to friction formula for recent models (2014 and newer). Does not have clear linkage that is easily extracted for legacy model vehicles.

OEM Provided Database for T2 Suppliers Industry Sponsored Registrar and Department

Rarely does an OESC exist directly between OEM and brake friction material manufacturer

Vehicle model year 2014 and newer only because of volume

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