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6.2 Recommendations
This section will recommend actions steps and areas for further research.
Pursue a Dialogue with Manufacturers
Some technical questions cannot be answered with independent research and require the assistance and
cooperation of manufacturers. Automobile and friction material manufacturers should be involved in
discussions of the technical issues surrounding brake pad reformulation to reduce the copper content. These
two industry groups appear to be the most knowledgeable about the relationship between chemical
composition and safety and performance.
This dialogue should also include discussions of the feasibility of brake pad reformulation from an economic
and environmental standpoint. Regulators must understand the alternatives to copper in brake pads and their
impact on the environment. Manufacturers need to know the potential upcoming regulations that would
affect brake pads.
Pursue a Voluntary Pollution Prevention Program
The results of this research suggest that a voluntary approach may be preferable to a regulatory one to
achieve reductions in copper content of brake pads. It would probably take the government agencies several
years to use their authority to collect product composition information and even longer to regulate brake pad
composition. I recommend that government team with manufacturers to explore the possibility of a
partnership agreement to achieve voluntary reductions in copper content.
A voluntary public/private partnership could mutually benefit manufacturers and the environment.
Manufacturers benefit since copper is generally more expensive than its alternatives and because companies
usually benefit from a positive environmental image. A reduction in the copper content of brake pads will
help the San Francisco Bay, and other similarly affected water bodies, meet water quality objectives.