TRI Pollution Prevention Report for ACE MANUFACTURING & PARTS CO and Lead

Facility ID: 6308WCMNFC3RAMS

Facility Name and Address:
ACE MANUFACTURING & PARTS CO
300 RAMSEY DR
SULLIVAN, MO 63080

Parent Company:

Industry: Motor Vehicle Transmission and Power Train Parts Manufacturing (336350)
Chemical: Lead

Production Related Waste Management for Selected Chemical


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    Waste Management Comparison - 2019



Pollution Prevention Activities for Selected Chemical


Reporting Year Section 8.10: Newly Implemented Source Reduction Activity Section 8.10: Methods to Identify Activity Section 8.11: Optional Pollution Prevention Information*
2022 Other Barriers to Source Reduction - There is currently no source reduction activities for the use of Lead in racing discs at this time. Customer requires our company to continue to provide parts with a friction formulation that was developed years ago that contained lead. Production orders by this customer has increased and as such, wastes containing lead from previous years has increased as well.


Other Environmental Practices: Recycling - All friction material wastes containing lead are sent to outside vendors for recycling.

2021 Barriers: B3-Barriers to P2 B3 - Concern that product quality may decline as a result of source reduction.
Other Barriers to Source Reduction - Lead is used in friction materials in certain racing clutch applications. A new "LEAD FREE" friction formulation was developed by Ace Manufacturing several years ago and presented to all customers. Certain customers however, continue to order racing clutches to the "old" formulation containing lead and so, to service it's customers, Ace Manufacturing continues to manufacture and sell the friction formulation containing lead to these customers.


Other Environmental Practices: Recycling - All wastes containing lead from the manufacture of friction materials used on racing clutch discs are collected and then sent off-site for recycling.

Source Reduction: Source Reduction - Lead is used in certain racing clutch applications. A new "LEAD FREE" friction formulation was developed by Ace Manufacturing several years ago and presented to all customers. Certain customers however, continue to order racing clutches to the "old" formulation containing lead and so, to service it's customers, Ace Manufacturing continues to manufacture and sell the friction formulation containing lead to these customers.

Barriers to P2: B3 - Concern that product quality may decline as a result of source reduction. - Lead is used in certain racing clutch applications. A new "LEAD FREE" friction formulation was developed by Ace Manufacturing several years ago and presented to all customers. Certain customers however, continue to order racing clutches to the "old" formulation containing lead and so, to service it's customers, Ace Manufacturing continues to manufacture and sell the friction formulation containing lead to these customers.

2020 Barriers to P2 - Several years ago, Ace Manufacturing developed a Friction Material Formulation for the racing industry that eliminated Lead, however, select customers, already familiar with the current properties of the friction materials using lead have chosen to continue its use in all of its applications. The option for our customers to switch over to a Lead Free formulation continues to be offered.



Other Environmental Practices: Recycling - Ace continues to collect all friction material wastes that contain Lead. The wastes are then transferred off site for recycling.

2019 Other Barriers to Source Reduction - In years past, Ace Manufacturing HAD developed an alternative friction formula to eliminate the use of LEAD, however, certain customers have not accepted this formulation and hence still require us to use lead in some of their products containing friction formulas (RACING DISCS)


Other Environmental Practices: Recycling - All waste products containing lead are sent to recycling companies.

2018 Source Reduction:: W84: Developed a new chemical product to replace previous chemical product
Methods to Identify SR Opportunities: T11: Other
Barriers: B4-Barriers to P2 B4 - Source reduction activities were implemented but were unsuccessful.
W84: In 2015, Ace Manufacturing developed a formulation for racing clutch friction materials that does not contain lead. This new formulation was presented to Ace customers as an alternative, however, certain customers have not accepted the new formulation. As such they continue to require the formulation containing lead. Ace Manufacturing continues to offer the non-lead formulation to its customers with the hopes that all customers will one day switch to the non-lead alternative.

Source Reduction - Ace Manufacturing will continue to recommend lead free friction formulas to its customers.
Other Barriers to Source Reduction - Lead is used in only a couple of friction material formulas specifically for the RACING clutch applications. In the effort to reduce/eliminate lead usage at our facility, Ace Manufacturing has developed a friction material that does not contain lead. This lead-free formula has been offered to its racing customers as a replacement for friction formulas that currently contain lead, however, Ace customers have chosen to continue using friction formulas with lead. Ace will continue offering the lead free formula to its racing customers in the hopes that the lead free friction material will be adopted by our racing customers, however, at present, some of the Ace racing customers continue to demand friction materials with lead in its composition.


Barriers to P2: B4 - Source reduction activities were implemented but were unsuccessful. - New lead-free friction material has been developed and offered to customers as an alternative, however, some customers continue to demand the formulations with lead. (Max. 5% Lead.)

Other Environmental Practices: Recycling - Ace Manufacturing continues to send products containing lead to waste treatment sources that can recycle.

2017 Other Environmental Practices - Ace Manufacturing and Parts Company has both a Quality Management System AND Environmental Management system that is registered to ISO9001:2015 AND ISO14001:2015. It strives for continuous improvement throughout the organization and as such is always looking for ways to reduce waste. In that policy objective, Ace has developed (3rd Qtr 2017) waste log sheets to assist in better tracking of its waste. The aim is to provide an even more accurate account of its copper and lead wastes. Use of this data will help to provide management with the information to formulate realistic goals for waste reduction.


Other Barriers to Source Reduction - Lead is an element that is used in the manufacture of friction materials of RACING clutches only. Ace has developed a lead free alternative formulation and has offered it to our Customers, however, Ace Customers have not yet committed to using the new formulation. As such, Ace continues to use Lead in a very limited number of racing clutches in order to meet customer requirements.

2016 Source Reduction:: W81: Changed product specifications
Methods to Identify SR Opportunities: T11: Other
W81: Ace Manufacturing and Parts company has developed a Racing friction material that does NOT contain lead. However, currently, no Ace customer has accepted the new formulation for use in its products. For this reason, at present, Ace will continue to use lead in Racing products only. Ace continues to market the lead free formulation to all of its customers with the expectation that at some point in time, these companies will choose the lead free products for their applications.

Source Reduction - The formulation for LEAD FREE Racing discs was a continuous improvement project of Ace Manufacturing and Parts Company.
2015 Barriers: B7-Other Environmental Practices B7 - No known substitutes or alternative technologies.

Other Environmental Practices: B7 - No known substitutes or alternative technologies. - For 2015, Lead continues to be a necessary component of the friction materials used in clutches for the racing industry. Alternative chemicals to replace Lead in racing clutch applications are expected to be investigated in 2016.

Other Environmental Practices: Recycling - As a responsible member of the world community, Ace Manufacturing, in line with its business policy, will strive to reduce/eliminate/recycle wastes. The Ace Environmental Management System is registered to ISO14001.

2014 Source Reduction:: W84: Developed a new chemical product to replace previous chemical product[-50-99%]
Methods to Identify SR Opportunities: T11: Other
W84: In late 2014, Ace found an acceptable alternative for lead in the production of its Heavy Duty clutch applications. Lead continues to be used in Racing Disc clutches.


Source Reduction: Source Reduction - Ace no longer uses Lead in the friction materials for its heavy duty clutches. This represented the majority of the lead usage in prior years. In 2015 and beyond, the total lead useage will be significantly reduced. Ace must continue using Lead in its manufacture of racing discs, therefore, Lead will not be eliminated completely from use at ACE.

Other Environmental Practices: Recycling - Ace does recycle its waste Lead from friction materials.

2013 Source Reduction - Ace continuously reviews its process to reduce/eliminate waste of all kinds. In 2013 a friction material re-formulation was being considered to eliminate Lead from "heavy duty" applications. Lead would continue to remain a component for the much smaller market of racing clutch discs.


Other Barriers to Source Reduction - Lead is used as a component in clutch friction materials. This material is part of a known formula to provide the friction material with specific required properties (i.e. wear and coefficient of friction) therefore, currently, for this application and all of 2013, lead must remain as an integral part of the friction material formula.

2012 Barriers to P2 - Ace continuously reviews its process to reduce/eliminate waste of all kinds. Ace is researching alternate formulas for racing material to exclude lead, however, currently, there are no known manufacturing methods to help reduce the amount of lead from the current waste stream. In the event that new, cost effective solutions are found to reduce lead usage or waste without sacrificing part quality, Ace, in line with its business policy will give full consideration in implementing these solutions as applicable.


Other Barriers to Source Reduction - Lead is used as a component in clutch friction materials. This material is part of a known formula to provide the friction material with specific required properties (i.e. wear and coefficient of friction) therefore, currently, for this application, Lead must remain as an integral part of the friction material formula and thus at present must remain in use for production and will only rise or fall in demand due to customer needs/requirements.

*Classifications of Optional Pollution Prevention Information shown in brackets are provided by EPA.


TRI Pollution Prevention Glossary

The Waste Management Hierarchy

The waste management hierarchy established by the Pollution Prevention Act (PPA) guides waste generators toward the best options for managing wastes. The preferred option is to prevent pollution at its source, but for waste that is generated, the preferred management methods are recycling, followed by burning for energy recovery, treatment and, as a last resort, disposing of the waste.
  • Source Reduction includes activities that eliminate or reduce the generation of chemical waste.
  • Recycling includes the recovery of a toxic chemical in waste for reuse.
  • Energy Recovery includes the combustion of toxic chemicals in waste to generate heat or electricity.
  • Treatment includes the destruction of a toxic chemical in waste.
  • Disposal or Other Releases includes toxic chemical quantities entering the environment.
The PPA requires facilities to provide the following details about each chemical they report to TRI:
Facilities may also provide optional Pollution Prevention Information describing their source reduction, recycling, or pollution control activities.