Global Automakers

Comments on DTSC's Draft, Informal Brake Friction Materials Proposal

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September 4, 2014

The Association of Global Automakers and the Alliance of Automobile Manufacturers submitted joint comments to the California Department of Toxic Substance Control (DTSC) regarding the draft, informal regulations for brake friction materials. While much of the proposed regulations are consistent with the statutory requirements of California’s Brake Friction Material Law, the comments raised the following concerns:

  • To prevent unnecessary regulatory burdens, DTSC should harmonize with the State of Washington's brake friction material program.  Where harmonization is not possible, the two states should provide reciprocity.
  • DTSC should address our concerns regarding the inconsistent markings for the environmental compliance mark between California and Washington.
  • DTSC shoudl also consider our comments on proposal’s processes for certification, exemptions, and extensions.
  • The proposal should address several issues that are not currently included in the regulations but were included in the statute.

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