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

10/11/2019 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 1 1

10/11/2019 2 About MEMA & BMC 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) 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. BMC and MEMA work together to  advocate on legislation and regulations impacting brakes, brake friction materials and related components. 2 2

10/11/2019 AutoAlliance.org /auto_alliance /autoalliance 3 3

10/11/2019 4 Phasing Out Copper in Brake In 2010, laws* in States of Washington  and California required manufacturers of Friction Materials brake friction materials to phase out the use of copper and other constituents (a.k.a. brake pads or brake linings) In 2012, Washington adopted regulations  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 * 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. 4 4

10/11/2019 5 The Road to Compliance In 2019, almost 50% of  current registered brake As a result of the CA/WA laws/regs and friction materials meet “N” industry-government MOU, BMC brake level (<0.5 wt%) friction material manufacturers have Over 13,000 product  been: identities have been registered in the State of  Expending significant resources WA; all BMC members that manufacture friction  researching, developing, reformulating, products are among the 117 testing, certifying alternatives to copper companies who registered  registering and marking brake their products. formulations NSF Certification Website:   Complying with “A” level http://info.nsf.org/certified/f riction_materials/listings.asp Asbestos, Cr(VI), Pb, Hg, Cd ?  Producing early compliant brake pads “B” and “N” levels 5 5

10/11/2019 6 WAC 173-901-060 Excerpt Self-certification of compliance. Washington “(1) Manufacturers of brake friction material must certify to the Better Brakes Law department that any brake friction material that is sold or offered for Allows for sale in Washington state complies Self-Certification of with the requirements ...” Compliance This includes elements such as: Lab testing  Compliance marking  Industry-sponsored registrar listing and  reporting Self-certification documentation  6 6

10/11/2019 7 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 Excerpt to ensure that brake friction material manufactured as part of an OESC is only installed on the vehicles for Washington which it is designed. (4) How does a manufacturer of brake friction material Better Brakes Law manufactured as part of an OESC certify compliance with the requirements of chapter 70.285 RCW and this chapter? Allows for Exemption of * * * Original Equipment (b) If the brake friction material contains more than Service Contract (OESC) the specified concentrations, the manufacturer of Brake Friction Material the brake friction material must follow the same procedure outlined in WAC 173-901-060 except OES defined as: “brake friction that: material provided as service * * * parts originally designed for and using the same brake (iii) Brake friction manufacturers must include in the friction material formulation self-certification documentation, submitted to the sold with a new motor vehicle.” 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. 7 7

10/11/2019 8 Basic Supply Chain Structure for Original Equipment in New Vehicles Installs Finished Components / Systems OEM During Final Vehicle Assembly Rarely does an OESC exist directly between OEM and brake friction material manufacturer Individual Components and/or Tier 1 Complete Systems Most brake friction material Tier 2 Components and/or Parts manufacturers fall in this category Parts, Subcomponents and/or Tier 3 Materials 8 8

10/11/2019 9 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 9 9

10/11/2019 10 Requirements for OESC Self-Certification 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 Automaker/OEM Lab Tests/Results Formulation ID by “Edge Code” Tier 1 Compliance Level “A” “B” or “N” Brake System Supplier Registrar T2 supplies T1 with brake friction material T1 assembles brake system with T2 friction installed 10 10

10/11/2019 11 OESC Self-Certification Proposal All Brake For self-certification of Friction OESC brake pads – due Materials to the lower volumes of Original Aftermarket impacted products – Equipment OE Brake industry proposes a Friction narrow scope to self- Materials certify OESC only on vehicles model year OE Service Contract 2014 and newer Brake Friction Materials WAC 173-901-060(8) OESC Brake Friction Brake friction material Materials that Need an OESC Exemption manufactured prior to 2015 (i.e. only meet “A” is exempt from self- level compliance) certification of compliance . 11 11

10/11/2019 12 Brake Hardware Evolves Over Time… Industry proposes to self-certify for OESC on vehicles model year 2014 and newer 2008 Malibu 2016 Malibu 2013 Malibu Front Brake Front Brake Front Brake 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. 12 12

10/11/2019 13 OESC Self-Certification Proposal Vehicle model year 2014 and newer only because of volume Does have friction formulation edge code ID, compliance level T2 Brake Friction Material Supplier May not have vehicle make/model/year specific for each friction formulation. But some limited information can be accessed via FMSI data. Self-Cert Using FMSI database and internal company data, T2 Data brake friction supplier may be able to access edge FMSI codes of “A” level compliant formulations and Database make/model specific to customers’ OE pads Rarely does an OESC Industry exist directly between Sponsored OEM and brake friction material manufacturer Registrar and Department Does have clear linkage of vehicle make/model/year to friction formula for OEM recent models (2014 and newer). Vehicle Manufacturer Does not have clear linkage that is easily extracted for legacy model vehicles. OEM Provided Database for T2 Suppliers 13 13