environment canada proposed r l v compound (voc) content in

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Environment Environnement Canada Canada ENVIRONMENT CANADA PROPOSED REGULATIONS TO LIMIT VOLATILE ORGANIC COMPOUND (VOC) CONTENT IN CONSUMER PRODUCTS (PERSONAL CARE, HOUSEHOLD, AUTOMOTIVE AFTERMARKET AND ADHESIVE PRODUCTS) DISCUSSION PAPER FOR THE DEVELOPMENT OF REGULATIONS Chemicals Sector Division Environment Canada September 2006 Revised September 15, 2006

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Environment Environnement Canada Canada

ENVIRONMENT CANADA PROPOSED REGULATIONS TO LIMIT VOLATILE ORGANIC COMPOUND (VOC) CONTENT IN CONSUMER PRODUCTS

(PERSONAL CARE, HOUSEHOLD, AUTOMOTIVE AFTERMARKET AND ADHESIVE PRODUCTS)

DISCUSSION PAPER FOR THE DEVELOPMENT OF REGULATIONS

Chemicals Sector Division Environment Canada

September 2006

Revised September 15, 2006

Table of Contents

List of Acronyms ............................................................................................................... iii 1. Introduction................................................................................................................. 1 2. Background................................................................................................................. 2 3. Background Information for Consumer Products....................................................... 5 4. Actions in Other Jurisdictions..................................................................................... 7 5. Benefits of Regulations............................................................................................... 9 6. Considerations for the Proposed Regulations ........................................................... 11 7. Benefits and Costs..................................................................................................... 14 8. Path Forward............................................................................................................. 15 ANNEX 1: References and Websites ............................................................................... 16 ANNEX 2: Comparison of CARB, OTC, USEPA and Proposed Environment Canada VOC Limits....................................................................................................................... 18 ANNEX 3: New CARB 2008 Categories......................................................................... 23 ANNEX 4: Category Specific Background Information .................................................. 24

List of Figures

Figure 1 - 2000 Canadian VOC Emissions......................................................................... 6 Figure 2 - 2000 Canadian “Solvent Use” Emissions .......................................................... 6

List of Tables

Table 1 - Possible Canadian Reductions Based on Requirements of US Regulations ..... 12 Table 2 - Compliant Products in the Canadian Market..................................................... 12

i revised September 15, 2006

This document contains the following corrections from the version dated September 13, 2006.

1. page 2 – replaced “excluding windshield washer fluid and surface coatings” with “and specifically excluded windshield washer fluid and surface coatings as these were targeted by other initiatives”

2. page 6 – added “Other initiatives will address some of the other sources.” 3. page 9 – replaced “would be extremely difficult to implement and enforce product

content regulations developed on a regional or provincial basis. Such an approach could result in different VOC content requirements” with “is preferable to create a uniform approach”

4. page 9 – replaced “regions. Consumer products” with “regions, as these consumer products”

5. page 11 – replaced “101 categories” with “98 categories” 6. page 11 – replaced “A consumer product is any chemically formulated product

used by household and institutional customers” with “For the purpose of these regulations, a consumer product is any chemically formulated product used by household and institutional customers as listed in the 98 categories”

7. page 11 – replaced “more of the 101 categories” with “more of the 98 categories”

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LIST OF ACRONYMS

AIM Architectural and Industrial Maintenance ASMAC Adhesive and Sealants Manufacturers Association of Canada CAA United States Clean Air Act CACD Canadian Association of Chemical Distributors CAIE Canadian Association of Importers and Exporters CARB California Air Resources Board CCGD Canadian Council of Grocery Distributors CCME Canadian Council of Ministers of the Environment CCOHS Canadian Centre for Occupational Health and Safety CCPA Canadian Chemical Producers Association CCSPA Canadian Consumer Specialties Producers Association CCTFA Canadian Cosmetic, Toiletry and Fragrance Association CEPA Canadian Environmental Protection Act CPCA Canadian Paints and Coatings Association CSSA Canadian Sanitation Supply Association CWS Canada-Wide Standards ENGO Environmental Non-Governmental Organization FCPC Food and Consumer Products of Canada LVP-VOC Low Vapour Pressure-Volatile Organic Compound NDMAC Nonprescription Drug Manufacturers Association of Canada NOx Nitrogen Oxides OTC Ozone Transport Commission PCPA Pest Control Products Act PM Particulate Matter PMRA Pest Management Regulatory Agency RCC Retail Council of Canada US EPA United States Environmental Protection Agency VOC Volatile Organic Compound

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1. INTRODUCTION

The purpose of this document is to provide background information and supporting rationale for the categories and limits for the proposed VOC Content in Consumer Products Regulations (Personal Care, Household, Automotive Aftermarket and Adhesive Products) which are to be developed under the Canadian Environmental Protection Act, 1999.

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2. BACKGROUND

Smog is responsible for serious health and environmental impacts in Canada, including thousands of premature deaths, hospital admissions and emergency room visits each year, and reduced crop growth. Volatile organic compounds (VOCs) are precursors to ground-level ozone and fine particulate matter (e.g. PM2.5), which are major components of smog. Up to two-thirds of fine particulate matter and almost all ground-level ozone are formed in the atmosphere from gaseous precursors. In order to reduce particulate matter and ground-level ozone, and in turn smog, it is therefore necessary to reduce emissions of their precursors, including VOCs. Consumer products are a significant source of Canadian VOC emissions. VOCs have a variety of purposes in consumer products, for example as solvents and stabilizers. VOCs are emitted to the atmosphere by evaporation when a product is used. As consumer products are widely used in households and institutions, it is not feasible to capture and control VOC emissions resulting at the point of use. The most effective and efficient option to reduce emissions is to limit the VOC content of the products. Establishing VOC content limits for consumer products may require some manufacturers to reformulate their products in order to meet those limits. Over the past two decades, the Government of Canada has been engaged in a number of activities aimed at reducing the health and environmental impacts of smog. The following is a summary of these activities. PREVIOUS ACTIVITIES ON VOCS IN CONSUMER PRODUCTS In 1990, the Canadian Council of Ministers of the Environment (CCME) developed the Management Plan for Nitrogen Oxides (NOx) and Volatile Organic Compounds (VOCs): Phase I. One initiative of the plan described a program to reduce VOC emissions from consumer products, and specifically excluded windshield washer fluid and surface coatings as these were targeted by other initiatives. The 1997 Phase 2 Federal Smog Management Plan renewed this commitment to reduce ground-level ozone by directing Environment Canada to develop, in consultation with stakeholders, a consumer products emission reduction program that would align with U.S. regulations. A Program to Reduce Volatile Organic Compound Emissions by 40 percent from Adhesives and Sealants The CCME published A Program to Reduce Volatile Organic Compound Emissions by 40 Percent from Adhesives and Sealants in 1994. The program was one of thirteen measures that stemmed from the 1990 CCME Phase 1 NOx/VOC Management Plan, and its objective was to reduce VOC emissions by 40 percent by 1997. A Task Force composed of representatives from the adhesive and sealant industry, users, raw material suppliers and government at the federal, provincial and regional levels was formed in 1992 to develop guidelines defining emission limits for adhesive products. In 1993, the Adhesive and Sealants Manufacturers Association of Canada (ASMAC) submitted a short paper on VOC emission reductions from the sector, which indicated the 40 percent reduction goal would be achieved naturally by 1997 through market driven factors, such

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as pressures from environmental authorities, concern for workers’ safety, insurance and solvent costs, and consumer demand. The Task Force agreed with the findings and conclusions of the ASMAC report and recommended that no further action be taken on the initiative, other than to continue to monitor ASMAC data on an annual basis and promote voluntary action. Guidelines for Volatile Organic Compounds in Consumer Products The Guidelines for Volatile Organic Compounds in Consumer Products were published in November 2002, fulfilling commitments under the Federal Smog Management Plan - Phase 2 (Initiative V103), November 1997. The guidelines recommend VOC content limits for 23 consumer product categories and are equivalent to VOC content limits established by the United States Environment Protection Agency in 1998. The guidelines were developed through consultation with stakeholders including industry, industry associations, environmental non-governmental organizations, and the provinces. CURRENT ACTIVITIES Canada-wide Standards In recognition of the adverse human health and environmental effects of ground-level ozone and particulate matter, the Government of Canada and the provinces and territories, except Quebec, adopted Canada-Wide Standards (CWSs) for both of these air pollutants under the CCME in June 2000. The standards establish ambient air concentration target levels to be achieved by 2010: 65 ppb for ozone and 30 µg/m3 for particulate matter less than 2.5 µm in diameter (PM2.5). Achieving these targets will require significant reductions of PM and ozone and their precursors, including VOCs. VOCs as a CEPA Toxic Substance On July 2, 2003, an Order was published in the Canada Gazette Part II adding VOCs, gaseous ammonia, nitric oxide, nitrogen dioxide and sulphur dioxide to Schedule 1 (List of Toxic Substances) of the Canadian Environmental Protection Act 1999 (CEPA, 1999). These substances were added to Schedule 1 due to their role as precursors in the development of ground-level ozone and particulate matter. The listing of the precursors gives the Government of Canada the legislative authority necessary to control the emissions from consumer and commercial products contributing to PM and ozone. Federal Agenda for Reduction of Emissions of Volatile Organic Compounds from Consumer and Commercial Products In March of 2004, the Federal Government published a Notice of Intent (NOI) in the Canada Gazette Part I which outlined Canada's Federal Agenda for Reduction of Emissions of Volatile Organic Compounds (VOCs) from Consumer and Commercial Products. This Agenda was developed after a series of technical studies and through consultation with industry, other government departments and environmental non-governmental organizations (ENGOs), and identifies specific actions to be taken by the Federal Government.

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One of the action items outlined in the Federal Agenda is the development of regulations under CEPA 1999 that would set VOC content limits for consumer products, a category which includes personal care, household, automotive aftermarket and adhesive products. As part of the Agenda, two other similar VOC content limit regulatory initiatives are also being prepared, one for architectural and industrial maintenance (AIM) coatings and another for auto-refinish coatings. The measures outlined in the Notice of Intent also respond to a commitment included in the Ozone Annex to the 1991 Canada-US Air Quality Agreement. The Ozone Annex, signed in 2000, commits Canada and the US to take measures to reduce VOC emissions and contains specific commitments to take action to reduce VOC emissions from consumer and commercial products. Links to further information concerning the activities listed above and others can be found in Annex 1.

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3. BACKGROUND INFORMATION FOR CONSUMER PRODUCTS

Consumer products cover a broad sector which includes personal care, household, automotive aftermarket and adhesive products used in households and institutions. The sector does not include architectural and industrial maintenance (AIM) coatings, auto-refinish coatings or adhesives used in commercial and industrial settings. In surveys completed by Environment Canada in 2005, responding companies reported 178 million tonnes of consumer products sold in 2003. Multinational corporations accounted for a majority of the sales; for instance 90% of reported adhesive sales were from four multinational companies. Most sectors were not this heavily concentrated, with national and regional companies having a greater presence in the personal care, household and automotive aftermarket segments. There are a significant number of stakeholders involved in the consumer products industry, over 1000 identified manufacturers and distributors identified in the personal care and household segment alone. The market is heavily integrated across North America. When possible, companies market a single formulation throughout the entire continent. To date, voluntary measures have been the only mechanisms used by the Government of Canada in its efforts to reduce VOC emissions from this sector. Voluntary action, education and awareness programs have made some progress in lowering VOC emissions from certain segments in industry. However, greater reductions and more certainty in the reductions are needed. VOC emissions continue to rise in Canada, and smog is an ongoing problem in many Canadian cities. The challenge with voluntary measures is that they cannot ensure that any reductions will be achieved. Regulations are therefore the next step to be taken to control VOC emissions. Regulations for VOC content in consumer products, as outlined in the Government of Canada’s Federal Agenda, are in keeping with the Federal Government strategies for reducing VOC emissions. Regulations that limit VOC content in consumer products will work to provide a “level playing field” for manufacturers and importers of products, provide a national approach, align Canadian with U.S efforts on a transboundary issue, and guarantee that reductions in VOC emissions will take place. VOC EMISSIONS FROM CONSUMER PRODUCTS According to the 2000 Canadian Criteria Air Contaminant Emissions Summary, Canadian VOC emission stood at approximately 1841 kilotonnes. Figure 1 outlines the eight major categories into which the Canadian emissions are commonly separated; consumer products are a part of the Solvent Use category.

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Total Emissions - 1841 kT(excluding Upstream Oil and Gas, Oil Sands Development and

Forest Fires)

Transportation 39%

Fuel Marketing 5%

Non-Industrial Fuel Combustion 8%

Industrial Sources 12%

Solvent Use 24%

Other 1%

Agriculture 11%

Electric Power <1%

Figure 1 - 2000 Canadian VOC Emissions

Consumer products contribute a significant amount to the total Solvent Use category, about 19% of the 477 kilotonnes which are considered Solvent Use emissions. Figure 2 illustrates how consumer products compare to other Solvent Use sub-categories.

Total Emissions - 477 kT

Paints and Coatings 27%

Consumer Products 19%

Industrial Non-Process 19%

Printing 8%

Commercial/Industrial Cleaning 7%

Degreasing 5%

Pesticides 2%

Windshield Washer Fluid 13%

Figure 2 - 2000 Canadian “Solvent Use” Emissions

The 2005 surveys identified a total of 28 kilotonnes of VOC emissions from consumer products. These surveys indicated that there are significant opportunities for emissions reductions from this sector. Other initiatives will address some of the other sources.

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4. ACTIONS IN OTHER JURISDICTIONS

As mentioned in the previous section, the Canadian consumer products market is a part of the larger North American market with many of the same products selling in both the United States and Canada. Because of this, it makes sense to review the standards in North American jurisdictions and possibly to align our actions with those occurring south of the border. The following section summarizes the VOC content standards of major US jurisdictions. United States Environmental Protection Agency (US EPA) In 1998, the United States Environmental Protection Agency (US EPA) promulgated the National Volatile Organic Compound Emissions Standards for Consumer Products under its Clean Air Act (CAA). The rule specifies VOC content limits for 24 product categories and applies nationwide to manufacturers, importers and distributors (excluding retailers) of consumer products manufactured after December 10, 1998. To date the US EPA has not announced any plans to review or update these standards. Ozone Transport Commission (OTC) The Ozone Transport Commission (OTC) is a multi-state organization created under the US Clean Air Act and responsible for developing regional solutions to ground-level ozone in the Northeast and Mid-Atlantic regions of the United States. In 2000, the OTC developed a model rule for consumer products. This model rule provides a framework for VOC content regulations for states within the Ozone Transport Region (OTR). The OTC model rule includes the categories in the US EPA regulation, with more stringent limits, as well as an additional 21 categories that are not in the US EPA rule. In all, the model rule provides VOC content standards for 45 consumer product categories, applying to all products manufactured for sale or use within the OTC states after January 2005. Many of the VOC content limits in the OTC model rule are similar to those present in the California Air Resource Board (CARB) rules. OTC members include: Connecticut, Delaware, the District of Columbia, Maine, Maryland, Massachusetts, New Hampshire, New Jersey, New York, Pennsylvania, Rhode Island, Vermont, and Virginia. California Air Resources Board California was the first jurisdiction to enact regulations for VOC content limits for consumer products in efforts to reduce the smog problem affecting many of its cities. In order to achieve reductions in VOC emissions that would help attain state and federal ambient air quality standards, the California Air Resources Board (CARB) developed regulations that prescribed VOC content limits for Antiperspirant and Deodorants (adopted in 1989) and Consumer Products (adopted in 1991). Since those initial promulgations, CARB has made numerous amendments to the regulations. These amendments were required because reductions realised through the initial rules have been overtaken by continuous population and economic growth. The most recent amendment, CARB 2006, will come into effect on December 31, 2006.

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In June of 2006 CARB introduced the next set of amendments to the Consumer Product rules to stakeholders. The amendments include VOC content limits for 61 categories and subcategories of consumer products. These new limits will be effective in 2008. Forty of these new limits are in existing categories while the remaining 21 are in categories that have not previously been regulated by the Board. The new limits for 40 previously regulated categories are found in Annex 2. The new categories and their proposed VOC limits are outlined in Annex 3. These new categories are being reviewed and may be included in Canadian regulations.

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5. BENEFITS OF REGULATIONS

There are a number of reasons as to why regulations will reduce VOC emissions from consumer products. In North America and Europe, regulations have and are being developed to control content and emissions from consumer products, and as such are not new to this sector. CERTAINTY IN REDUCTIONS Given that large reductions in VOC emissions are required to meet the CWS for ozone and PM, it is necessary to guarantee significant reductions in sectors with large emissions of VOCs. Due to their nature, voluntary actions cannot provide this level of assurance. As opposed to a voluntary measure, where the level of compliance can be uncertain, the proposed regulations will result in reduction in VOC emissions when implemented. NATIONAL APPROACH Although smog is a regional issue, with areas of concern such as the Windsor-Quebec corridor, the lower mainland of British Columbia and the Atlantic Provinces, a national approach will benefit the regions of concern while also protecting those areas where smog is not yet a problem. It is preferable to create a uniform approach for consumer products as these consumer products are generally formulated and marketed nationally or internationally; a patchwork of regulations would considerably complicate the manufacture and import of products. ALIGNMENT WITH THE UNITED STATES One of the intentions of the proposed regulations is to align the requirements for VOC content in consumer products with those existing in the United States. Clean air is a transboundary issue, and as such, efforts must be made on both sides of the border to ensure a reduction in smog precursors such as VOCs. The United States has a history of regulatory limits on the VOC content of consumer products, and Canadian regulations are needed to align our efforts. The consumer products market is highly integrated on a North American basis; aligning the proposed Canadian regulations with existing requirements in the United States will facilitate consistency in the North American market ensuring Canadian products can continue to be marketed in the United States, and allow Canada to benefit from the United States experience in implementing VOC emissions reduction strategies. LEVEL PLAYING FIELD FOR INDUSTRY The proposed regulations will act to provide a "level playing field" and provide regulatory certainty for manufacturers and importers of consumer products. Voluntary actions which have been used in the past to encourage VOC reductions from consumer products have been known to give an unfair advantage to companies who choose to not participate in the initiatives and continue to market their products without having to put resources towards the research and development necessary to create lower VOC products. The regulatory approach provides assurance, for purposes of business decision-making, that all manufacturers and importers must meet the same requirement for the VOC content of their products.

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CONCLUSION Regulations have been determined to be the most effective and efficient method to control VOC emissions from consumer products and achieve reductions.

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6. CONSIDERATIONS FOR THE PROPOSED REGULATIONS

The proposed regulations will mandate VOC content limits for 98 categories (including sub-categories) of consumer products. The regulations would apply to manufacturers, importers, distributors and retailers of consumer products sold in Canada. DEFINITION OF CONSUMER PRODUCT For the purpose of these regulations, a consumer product is any chemically formulated product used by household and institutional consumers as listed in the 98 categories, and includes personal care, household, automotive aftermarket and adhesive products. Consumer products do not include architectural and industrial maintenance (AIM) coatings, auto-refinish coatings or adhesives sold for use in commercial and industrial settings. PRODUCT CATEGORIZATION The regulations would apply to any consumer product which meets the category definitions found in Annex 4. Each consumer product may be categorized into one or more of the 98 categories and subcategories. Where a consumer product falls within more than one category, the product must meet the most restrictive VOC content limit of any applicable categories. In other words, if a product from Regulated Product Category A makes any representation that it may be used as (or is suitable for use as) Regulated Product Category B, then the regulated product would be subject to the lowest VOC content limit specified of either Product Category A or Product Category B. The categories chosen for inclusion in the proposed regulations are based mainly on the current CARB regulations for reducing VOC from Antiperspirant and Deodorants and Consumer Products, with amendments that consider the Canadian market. Information on the category definitions, choice of categories and content limits is provided in the category tables appearing in Annex 4. CARB, US EPA and OTC consumer products regulations include categories for several insecticide and terrestrial herbicide products. In Canada, these products are regulated as pesticides by Health Canada’s Pest Management Regulatory Agency (PMRA) under the authority of the Pest Control Products Act (PCPA). The VOC standards for insecticides and terrestrial herbicides listed in the CARB and US EPA rules will be managed by PMRA. The requirements of other jurisdictions will be considered and the timeframe for development will be consistent with the proposed CEPA regulations. VOC CONTENT LIMITS Studies initiated, in 2005, by Environment Canada of the consumer products industry indicated that for most categories surveyed, there is a significant market share complying with the CARB 2006 and OTC Model Rule VOC limits. Details from the studies, including information on compliant market share, sales volumes and product category definitions used are presented in Annex 4.

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Using data collected in surveys, Environment Canada has developed three emissions reductions scenarios. Table 1 outlines estimated emissions reductions for the three different regulatory options.

Category US EPA Reductions

OTC Reductions

CARB 2006 Reductions

Automotive Aftermarket Products 1% 47% 47% Personal Care Products 1% 19% 21%

Household Products 4% 16% 17% Adhesive Products (3%) 68% 68%

Total 2% 31% 32% Table 1 - Possible Canadian Reductions Based on Requirements of US Regulations

Data is also available to determine the extent to which products supplied to the Canadian market already meet the VOC limits in the three different scenarios. Table 2 shows the number of products marketed in Canada which are compliant to the three different regulatory scenarios.

Category US EPA Compliance

OTC Compliance

CARB 2006 Compliance

Automotive Aftermarket Products 95% 49% 49%

Personal Care Products 97% 72% 71% Household Products 96% 91% 90% Adhesive Products 90% 43% 41%

Total 96% 77% 76% Table 2 - Compliant Products in the Canadian Market

The proposed VOC content limits are consistent with CARB 2006, which are also similar to the current OTC Model Rule. The proposed categories and their corresponding limits, as well as how they compare to various US limits can be found in Annex 2. A significant portion of the Canadian consumer products market already complies with the CARB 2006 and OTC Model Rule VOC content limits, making these limits the logical choice in maximizing emissions reductions while minimizing the impact on industry. CARB and OTC represent a significant portion of the marketplace in North America, and as such set the standards for many products sold and imported into the North American consumer market. The CARB 2008 limits are not being presented as a possible scenario at this stage. However, the Government of Canada is following the progress of the proposed limits and will make a final decision concerning their applicability to Canadian regulations at a later date. EFFECTIVE DATE The regulations will become effective on January 1, 2009; all consumer products sold in Canada, and which fall into the product categories defined in Annex 4, must be compliant by that date.

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EXEMPTIONS The proposed regulations will not apply to any consumer product manufactured or sold in Canada for shipment and use outside of Canada. The proposed VOC content limits will not apply to consumer products regulated as pesticides by Health Canada’s Pest Management Regulatory Agency (PMRA) under the authority of the Pest Control Products Act (PCPA). TEST METHODS The reference method used by the proposed regulations to determine the composition of a product is described by California Air Resources Board Method 310. This method may be used for consumer products, antiperspirant and deodorant products, and aerosol coating products. Manufacturers and importers may use Method 310, formulation data or any reasonable means for predicting that the consumer product has been formulated as intended. However, if there are any inconsistencies between the results of a Method 310 test and any other means for determining VOC content, the Method 310 test results would be considered correct. LABELLING REQUIREMENTS Consideration will be given to a requirement in the proposed regulations that manufacturers and importers of consumer products would have to provide specified information on the labels of their products. The labels would have to contain information on the date of manufacture, any specific dilution recommendations and the VOC content of the product. Environment Canada will work with Health Canada to ensure compliance with the Globally Harmonized System (GHS) requirements. REPORTING REQUIREMENTS There will be a reporting requirement for this regulation. This requirement’s exact nature will be proposed during the consultation process. Considerations include reporting of VOC product content to Environment Canada and record keeping provisions.

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7. BENEFITS AND COSTS

VOC REDUCTIONS Based on 2003 survey data, the estimated potential reduction in VOC emissions due to implementation of the proposed limits would be over 8.2 kt or 30% of total VOC emissions from consumer products when implemented. As has been seen in California, economic and population growth quickly overcome reductions achieved when a regulation is first implemented. As an example, an economic growth rate of 2% will reduce a 30% reduction to: 20% in five years; 9% in 10 years and completely eliminate it in 13 years. The proposed VOC content in consumer products regulations will be the first step in controlling VOC emissions from this sector. Environment Canada will continue to monitor VOC emissions and will consider further regulatory actions if necessary in order to achieve its targets for VOC emissions reductions. COSTS Environment Canada is currently conducting studies to estimate the costs associated with implementing the proposed VOC limits regulations. The studies will use available and current data from CARB and US EPA economic analyses, industry estimates and Environment Canada survey information. The studies are expected to be completed by the end of 2006. Information from these studies will be used to develop a Regulatory Impact Analysis Statement (RIAS). The RIAS will provide a clear explanation of the regulations, including their purpose, the analysis substantiating them and the costs and benefits associated with them BENEFITS The proposed regulations generate environmental and health benefits that could be translated into economic terms. For example, health benefits could be translated into avoided costs to the health care system as well as improved individual well-being. Additionally, as mentioned, the proposed regulations will provide regulatory certainty for business decision making and a level playing field nation-wide, this will reduce costs to manufacturers, importers, distributors and vendors of product.

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8. PATH FORWARD

Since the focus of the proposed regulations is on consumer products, stakeholders in the consultation process may include Canadian manufacturers and importers of consumer products, associations representing manufacturers, and importers and suppliers of consumer products including: Adhesive and Sealants Association of Canada (ASMAC), Canadian Association of Chemical Distributors (CACD), Canadian Centre for Occupational Health and Safety (CCOHS), Canadian Chemical Producers Association (CCPA), Canadian Consumer Specialties Producers Association (CCSPA), Canadian Cosmetic, Toiletry and Fragrance Association (CCTFA), Canadian Paints and Coatings Association (CPCA), Canadian Sanitation Supply Association (CSSA), Canadian Association of Importers and Exporters (CAIE), Food and Consumer Products of Canada (FCPA), Nonprescription Drug Manufacturers Association of Canada (NDMAC), and Retail Council of Canada (RCC). Other stakeholders may include government departments, provincial and territorial governments and environmental non-governmental organizations (ENGOs). Stakeholders will be encouraged to provide written comments on the proposed regulations during the consultation process. After reviewing the comments, draft regulations and Regulatory Impact Analysis Statement (RIAS) will be published in Canada Gazette, Part I. This publication is followed by a sixty day public comment period during which stakeholders will have another opportunity to provide comments on the proposed regulations. Publication of the final regulations in Canada Gazette, Part II will follow the public comment period.

Contact Information

For further information on this discussion document or to find out how to get involved in the public consultation activities for the proposed regulations, please contact: Diep Le Chemicals Sector Division Environment Canada 351 St. Joseph Blvd. Gatineau, Quebec K1A 0H3 Phone: 819-953-9451 Fax: 819-994-0007 Email: [email protected]

Blair Batchelor Chemicals Sector Division Environment Canada 351 St. Joseph Blvd. Gatineau, Quebec K1A 0H3 Phone: 819-953-9806 Fax: 819-994-0007 Email: [email protected]

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ANNEX 1: REFERENCES AND WEBSITES References California Air Resources Board. California Code of Regulations, Division 3, Chapter 1, Subchapter 8.5, Article 1, Antiperspirants and Deodorants, Sections 94500-94506.5. California Air Resources Board. California Code of Regulations, Division 3, Chapter 1, Subchapter 8.5, Article 2, Consumer Products, Sections 94507-94517. California Air Resources Board. Method 310 Determination of Volatile Organic Compounds (VOC) in Consumer Products and Reactive Organic Compounds in Aerosol Coating Products. Amended May 5, 2005. Cheminfo, 2004. Volatile Organic Compounds (VOC) Emissions from the Use of Solvents in Canada for the Year 2002. Report by Cheminfo for Pollution Data Branch, Environment Canada, March 2004. Cheminfo, 2006. Technical and Socio-Economic Study for the Automotive Aftermarket Products Industry. Report by Cheminfo Services Inc. for Chemicals Sector Division, Environment Canada. January 2006. Environment Canada, 2004a. A Federal Agenda for Reduction of Emissions of Volatile Organic Compounds from Consumer and Commercial Products - Support Document to the Notice of Intent. Transboundary Air Issues Branch, Environment Canada. March 2004. Environment Canada, 2004b. 2000 National Criteria Air Contaminants Inventory, Pollution Data Branch, Environment Canada. November 2004. Health Canada, 2004, Estimated Number of Excess Death in Canada Due To Air Pollution, Air Health Effects Division, Health Canada. August 2004 Ozone Transport Commission Model Rule: Consumer and Commercial Products, March 6, 2001 ToxEcology, 2006. Collection of Economic and Technical Information on Personal Care and Household Products. Report by ToxEcology Environmental Consulting Ltd. for Chemicals Sector Division, Environment Canada. April 2006. United States Environmental Protection Agency (USEPA), 1998. National Volatile Organic Compound Emission Standards for Consumer Products, 40 CFR Parts 9 and 59, Federal Register, Vol. 63, No. 176, September 11, 1998.

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Websites Environment Canada’s Clean Air Website

http://www.ec.gc.ca/cleanair-airpur/Home-WS8C3F7D55-1_En.htm Information on the Federal Agenda

Notice of Intent: http://www.ec.gc.ca/nopp/DOCS/notices/voc/en/index.cfm

Support Document to the Notice of Intent: http://www.ec.gc.ca/nopp/DOCS/notices/voc/en/voc_noi_e.pdf

Information concerning the CEPA Guidelines for VOCs in Consumer Products

“Guidelines for Volatile Organic Compounds in Consumer Products” http://www.ec.gc.ca/CEPARegistry/documents/glines/voc/toc.cfm

A Notice regarding these Guidelines published in the Canada Gazette Part 1: http://canadagazette.gc.ca/partI/index-e.html

Canadian Council of Ministers of the Environment

www.ccme.ca Information concerning the Federal Government’s Plan to Reduce Volatile Organic Compound Emissions from Consumer Products in Canada

http://dsp-psd.pwgsc.gc.ca/Collection/En46-32-4E.pdf

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ANNEX 2: COMPARISON OF CARB, OTC, USEPA AND PROPOSED ENVIRONMENT CANADA VOC LIMITS This Annex contains a comparison of four different scenarios being considered by Environment Canada for its Consumer Products Regulations. Three of these scenarios are currently in force within their respective jurisdictions in the United States. CARB 2008 is the California Air Resource Board’s most recently proposed limits, which have an effective date of 2008. Environment Canada’s proposed limits for the Consumer Products Regulation are in the final column. Please note that there are limits which do not appear in each category. In this case “No Limit” indicates that there is no equivalent definition for a category in a jurisdiction.

Category US EPA

limit (wgt%)

OTC limit (wgt%)

CARB limit 2006

(wgt%)

CARB limit 2008

(wgt%)

Proposed limit

(wgt%)

Adhesives, Sealants and Caulks Adhesives

Contact Adhesive: General Purpose 80 80 55 55 55

Contact Adhesive: Special Purpose No limit 80 80 80 80 Construction Panel and Floor Covering 40 15 15 1.5 15

General Purpose 10 10 10 10 10 Mist Spray No limit 65 65 45 65 Special Purpose Spray (mounting, automotive engine compartment, flexible vinyl)

No limit 70 70 70 70

Special Purpose Spray (polystyrene foam, automotive headliner)

No limit 65 65 65 65

Special Purpose Spray (polyolefin, laminate repair/edgebanding) No limit 60 60 60 60

Structural Waterproof 15 15 No limit No limit 15 Web Spray 75 55 55 45 55

Adhesive Removers Floor or Wall Covering No limit No limit 5 5 5 Gasket or Thread Locking No limit No limit 50 50 50 General Purpose No limit No limit 20 20 20 Speciality No limit No limit 70 70 70

Sealants and Caulking Compounds (small container) No limit 4 4 0.5 4

Personal Care Antiperspirants

Aerosol 60 50 50 50 50 Non-Aerosol No limit 0 0 0 0

Hair Mousses 16 6 6 6 6

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Category US EPA

limit (wgt%)

OTC limit (wgt%)

CARB limit 2006

(wgt%)

CARB limit 2008

(wgt%)

Proposed limit

(wgt%) Hair Shines No limit 55 55 55 55 Hairsprays 80 55 55 55 55 Hair Styling Gels 6 6 6 6 6 Hair Styling Products: Aerosol and Pump Spray No limit No limit 6 6 6

Hair Styling Products: All Other Forms No limit No limit 2 2 2

Nail Polish Removers 85 75 0 0 0 Personal Fragrance Products

20% or Less Fragrance No limit No limit 75 75 75 More than 20 % Fragrance No limit No limit 65 65 65

Shaving Creams 5 5 5 5 5 Shaving Gels No limit No limit 7 7 7

Underarm Deodorants Aerosol 20 HVOC 0 HVOC,

10 MVOC 0 HVOC, 10 MVOC

0 HVOC, 10 MVOC 10

Non-Aerosol No limit 0 0 0 0 Household Air Fresheners

Single-Phase 70 30 30 30 30 Double-Phase 30 25 25 25 25 Liquid/Pump Spray 18 18 18 0.5 18 Solid/Semisolid 3 3 3 3 3 Dual Purpose Air Freshener/Disinfectant No limit No limit 60 60 60

Anti-Static Products Aerosol No limit No limit 80 80 80 Non-Aerosol No limit No limit 11 11 11

Bathroom and Tile Cleaners Aerosol 7 7 7 5 7 All Other Forms 5 5 5 1 5

Bug and Tar Remover No limit 40 40 40 40 Carpet and Upholstery Cleaners

Aerosol No limit 7 7 5 7 Non-Aerosol (Dilutables) No limit 0.1 0.1 0.1 0.1 Non-Aerosol (Ready-to-use) No limit 3 3 1 3

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Category US EPA

limit (wgt%)

OTC limit (wgt%)

CARB limit 2006

(wgt%)

CARB limit 2008

(wgt%)

Proposed limit

(wgt%) Charcoal Lighter Materials VOC

emission limit 9

grams per start

Ignition must be less than

0.02 pound of VOC per

start

Ignition must be less than

0.02 pound of VOC per

start

Ignition must be less than

0.02 pound of VOC per

start Fluid

0.01 pound of VOC per

start

Impregnated Briquettes

0.01 pound of VOC per

start

Cooking Spray: Aerosol 18 18 18 14 18 Dusting Aids

Aerosol 35 25 25 20 25 Non-Aerosol 7 7 7 5 7

Electronic Cleaners No limit No limit 75 75 75 Fabric Refresher

Aerosol No limit No limit 15 15 15 Non-Aerosol No limit No limit 6 6 6

Fabric Protectants 75 60 60 60 Aerosol 16 Non-Aerosol 1

Floor Polishes/Waxes Products for Flexible Flooring

Materials 7 7 7 1 7

Products for Nonresilient Flooring 10 10 10 1 10 Wood Floor Wax 90 90 90 10 90

Floor Wax Strippers Non-Aerosol (To remove light or medium build-up polish)

No limit No limit 3 3 3

Non-Aerosol (To remove heavy build-up of polish) No limit No limit 12 12 12

Footwear or Leather Care Products Aerosol No limit No limit 75 75 75 Solid No limit No limit 55 55 55 All Other Forms No limit No limit 15 15 15

Furniture Maintenance Products Aerosol 25 17 17 17 17 All Other Forms Except Solid or

Paste 10 7 7 3 7

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Category US EPA

limit (wgt%)

OTC limit (wgt%)

CARB limit 2006

(wgt%)

CARB limit 2008

(wgt%)

Proposed limit

(wgt%) General Purpose Cleaners

Aerosol 10 10 10 7 10 Non-Aerosol 10 4 4 4 4

General Purpose Degreasers Aerosol No limit 50 50 15 50 Non-Aerosol No limit 4 4 4 4

Glass Cleaners Aerosol 12 12 12 7 12 Non-Aerosol 8 4 4 4 4

Graffiti Remover Aerosol No limit No limit 50 50 50 Non-Aerosol No limit No limit 30 30 30

Heavy-Duty Hand Cleaner or Soap No limit 8 8 8 8 Laundry Prewash

Aerosol/Solid 22 22 22 22 22 All Other Forms 5 5 5 5 5

Laundry Starch Product/Sizing/Fabric Finish 5 5 5 5

Aerosol 4 Non-Aerosol 4

Metal Polishes/Cleaners No limit 30 30 30 30 Multi-purpose Lubricant (Excluding solid or semi-solid products) No limit 50 50 45 50

Oven Cleaners Aerosol/Pump Spray 8 8 8 5 8 Liquid 5 5 5 1 5

Paint Removers or Strippers No limit 50 50 50 50 Penetrants No limit 50 50 45 50 Rubber and Vinyl Protectants

Aerosol No limit 10 10 10 10 Non-Aerosol No limit 3 3 3 3

Silicone-Based Multi-Purpose Lubricants (Excluding solid or semisolid products)

No limit 60 60 60 60

Spot Removers Aerosol No limit 25 25 7 25 Non-Aerosol No limit 8 8 1 8

Toilet/Urinal Care Aerosol No limit No limit 10 10 10 Non-Aerosol No limit No limit 3 3 3

Wood Cleaner Aerosol No limit No limit 17 17 17 Non-Aerosol No limit No limit 4 4 4

Automotive Aftermarket Automotive Brake Cleaners No limit 45 45 10 45

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Category US EPA

limit (wgt%)

OTC limit (wgt%)

CARB limit 2006

(wgt%)

CARB limit 2008

(wgt%)

Proposed limit

(wgt%) Automotive Rubbing or Polishing Compounds No limit 17 17 17 17

Automotive Wax/Polish/Sealant/Glaze

Hard Paste Waxes No limit 45 45 45 45 Instant Detailers No limit 3 3 3 3 All Other Forms No limit 15 15 15 15

Carburetor or Fuel-Injection Air Intake Cleaners 75 45 45 10 45

Engine Degreasers Aerosol 75 35 35 10 35 Non-Aerosol 75 5 5 5 5

Tire Sealant and Inflators No limit 20 20 10 20 Undercoatings: Aerosol No limit 40 40 40 40

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ANNEX 3: NEW CARB 2008 CATEGORIES

This Annex contains a list of 21 new categories recently introduced by the California Air Resource Board (CARB) for consideration for their next amendment to the Regulation for Reducing VOC Emissions from Consumer Products. These product categories have not previously been regulated by the CARB. This amendment is set to come into effect in 2008.

Category CARB 2008 proposed limits (wgt%)

Tire Cleaners and Wheel Cleaners 0.1Windshield Water Repellent 11Automotive Wash or Cleaner 0.1Personal Disinfectant (Hand Sanitizers) 1Astringent/Toner 10Temporary Hair Colour Spray--Aerosol 55Nail Coatings Tier 1: 50

Tier 2: 10Aftershave Personal Fragrance 50Brush Cleaner 15Hard Surface Rust Stain Remover--Non-aerosol 1Disinfectant--Aerosol 70Disinfectant--Liquid 5Sanitizer--Aerosol 70Sanitizer--Liquid 5Cooktop Cleaner--Aerosol 7Cooktop Cleaner--Non-aerosol 4Dryer Sheets 1Fabric Softener 1Multi-purpose Dry Lubricant--Excluding Solid and Semisolid 60Spray Buff Products 3Odour Remover/Eliminator 0.5

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ANNEX 4: CATEGORY SPECIFIC BACKGROUND INFORMATION

BACKGROUND INFORMATION The following section includes background information compiled from various sources. The purpose of providing this information is to describe the proposed consumer products categories, to provide results of the Environment Canada survey and to describe a rationale for the selection of the proposed VOC content limits. Sources of Information VOC Content Limits The background information includes a comparison of VOC content limits from the US EPA Consumer Products Rule, the 2006 and 2008 CARB Regulations for Consumer Products, the OTC Model Rule and the proposed regulation where applicable. Definition The definitions provided are generally consistent with CARB Regulations for Consumer Products. The definitions are the same as those that will be included in the proposed regulations. This section also identifies if a category is exempt from the most restrictive limit provision in the proposed regulations. Survey Results The survey results provided in the summary sheets are from the 2005 Environment Canada surveys of manufacturers and importers of consumer products in Canada. Technical Data/Manufacturer Info Where relevant, information obtained from manufacturer interviews, websites or published technical product data sheets is included. [To be added at later date] Information from Other Jurisdictions Where relevant, published information from jurisdictions in the US related to Consumer Products regulations or model rule development was included.

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ADHESIVES, SEALANTS AND CAULKS Contact Adhesive: General Purpose US EPA:

80% wgt OTC:

80% wgt CARB 2006:

55% wgt CARB 2008:

55% wgt Proposed:

55% wgt Definition: An adhesive that:

• is designed for application to both surfaces for be bonded together, and; • is allowed to dry before the two surfaces are placed in contact with each other,

and; • forms an immediate bond that is impossible, or difficult, to reposition after both

adhesive-coated surfaces are placed in contact with each other, and; • does not need sustained pressure or clamping of surfaces after the adhesive-coated

surfaces have been brought together using sufficient momentary pressure to establish full contact between both surfaces.

“Contact Adhesive” does not include rubber cements that are primarily intended for use on paper substrates. Survey Results: Number of products: 12 Products complying with proposed limit: 3 (25%) Canadian reported product quantity: 63955 kg Canadian reported product quantity complying with proposed limit: 577 kg (<1%) VOC content range: 53-100% wgt Technical Data/Manufacturer Information: Information from Other Jurisdictions: The OTC and CARB have both included a maximum container size to which these limitations apply. Environment Canada is reviewing these criteria to determine whether they are appropriate for these regulations. Summary: The propose limit is consistent with the CARB rule. Responses to the Environment Canada survey indicated that there was little product sold in Canada that meets the proposed limit. However, experience in California has shown these limits to be technologically feasible.

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Contact Adhesive: Special Purpose US EPA:

No Limit OTC:

80% wgt CARB 2006:

80% wgt CARB 2008:

80% wgt Proposed:

80% wgt Definition: Survey Results: Number of products: 3 Products complying with proposed limit: 3 (100%) Canadian reported product quantity: 56350 kg Canadian reported product quantity complying with proposed limit: 56350 kg (100%) VOC content range: Insufficient data Technical Data/Manufacturer Information: Information from Other Jurisdictions: Summary: The proposed limit is consistent with CARB and OTC rules. The Environment Canada survey indicated that 100% of individual products sold accounting for 100% of sales meet the proposed limits.

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Adhesive: Construction Panel and Floor Covering US EPA:

40% wgt OTC:

40% wgt CARB 2006:

15% wgt CARB 2008:

1.5% wgt Proposed:

15% wgt Definition: A one component adhesive that is designed exclusively for the installation, remodelling, maintenance or repair of:

• structural and building components that include, but are not limited to, beams, trusses, studs, panelling (drywall or drywall laminates, fibreglass reinforced plastic (FRP), plywood, particle board, insulation board, pre-decorated hardboard, tile board, etc.), ceiling and acoustical tile, molding, fixtures, countertops or countertop laminates, cove or wall bases, and flooring or subflooring, or;

• floor or wall coverings that include, but are not limited to, wood or simulated wood covering, carpet, carpet pad or cushion, vinyl backed carpet, flexible flooring material, nonresilient flooring material, mirror tiles and other types of tiles, and artificial grass.

“Construction, Panel, and Floor Covering Adhesive” does not include “Floor Seam Sealer”. Survey Results: Number of products: 72 Products complying with proposed limit: 19 (26%) Canadian reported product quantity: 3,964,714 kg Canadian reported product quantity complying with proposed limit: 584,516 kg (15%) VOC content range: 0-60% wgt Technical Data/Manufacturer Information: Information from Other Jurisdictions: On June 6, 2006 the California Air Resource Board (CARB) proposed a new limit for Construction Panel and Floor Covering Adhesives. The proposed limit, of 1.5% by weight VOC, will be consulted on over the course of the summer and go to board hearing on November 16, 2006. The OTC and CARB have both included a maximum container size to which these limitations apply. Environment Canada is reviewing these criteria to determine whether they are appropriate for these regulations. Summary: The proposed limit is consistent with the CARB rule. The Environment Canada survey indicated that 26% of individual products sold accounting for 15% of sales meet the proposed limits.

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Adhesive: General Purpose US EPA:

10 % wgt OTC:

10 % wgt CARB 2006:

10 % wgt CARB 2008:

10 % wgt Proposed:

10 % wgt Definition: A non-aerosol adhesive designed for use on a variety of substrates. “General Purpose Adhesive” does not include:

• contact adhesives; • construction, panel, and floor covering adhesives; • adhesives designed exclusively for application on one specific category of

substrates (i.e., substrates that are composed of similar materials such as different types of metals, paper products, ceramics, plastics, rubbers or vinyls), or;

• adhesives designed exclusively for use on one specific category of articles (i.e., articles that may be composed of different materials but perform a specific function such as gaskets, automotive trim, weather-stripping, or carpets)

Survey Results: Number of products: 79 Products complying with proposed limit: 37 (47%) Canadian reported product quantity: 818131 kg Canadian reported product quantity complying with proposed limit: 447482 kg (55%) VOC content range: 0-33% wgt Technical Data/Manufacturer Information: Information from Other Jurisdictions: The OTC and CARB have both included a maximum container size to which these limitations apply. Environment Canada is reviewing these criteria to determine whether they are appropriate for these regulations. Summary: The proposed limit is consistent with US EPA, CARB and OTC rules. The Environment Canada survey indicated that 47% of individual products sold accounting for 55% of sales meet the proposed limits.

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Adhesive: Mist Spray US EPA:

No Limit OTC:

65% wgt CARB 2006:

65% wgt CARB 2008:

45% wgt Proposed:

65% wgt Definition: An aerosol adhesive which is not a special purpose spray adhesive and which delivers a particle or mist spray, resulting in the formation of fine, discrete particles that yield a generally uniform and smooth application of adhesive to the substrate Survey Results: Number of products: 9 Products complying with proposed limit: 9 (100%) Canadian reported product quantity: 9296 kg Canadian reported product quantity complying with proposed limit: 9296 kg (100%) VOC content range: 62.4-65% wgt Technical Data/Manufacturer Information: Information from Other Jurisdictions: On June 6, 2006 the California Air Resource Board (CARB) proposed a new limit for Mist Spray Adhesives. The proposed limit, of 45% by weight VOC, will be consulted on over the course of the summer and go to board hearing on November 16, 2006 Summary: The proposed limit is consistent with CARB and OTC rules. The Environment Canada survey indicated that 100% of individual products sold accounting for 100% of sales meet the proposed limits.

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Adhesive: Special Purpose Spray (mounting, automotive engine compartment, flexible vinyl) US EPA:

No Limit OTC:

70% wgt CARB 2006:

70% wgt CARB 2008:

70% wgt Proposed:

70% wgt Definition: An aerosol adhesive the meets any of the following definitions:

• Mounting – designed to permanently mount photographs, artwork and any other drawn or printed media to a backing (paper, board, cloth, etc.) without causing discolouration to the artwork

• Automotive Engine Compartment – designed for use in motor vehicle under-the-hood applications which require oil and plasticizer resistance as well as high shear strength at temperatures of 93 – 135 Celsius.

• Flexible Vinyl – designed to bond flexible vinyl to substrates. Survey Results: Number of products: 2 Products complying with proposed limit: 0 (0%) Canadian reported product quantity: 113856 kg Canadian reported product quantity complying with proposed limit: 0 kg (0%) VOC content range: Insufficient data Technical Data/Manufacturer Information: Information from Other Jurisdictions: Summary: The proposed limit is consistent with CARB and OTC rules. Responses to the Environment Canada survey indicated that there was no product marketed in Canada meeting the proposed limit. However, experience in California and the OTC has shown these limits to be technologically feasible.

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Adhesive: Special Purpose Spray (polystyrene foam, automotive headliner) US EPA:

No Limit OTC:

65% wgt CARB 2006:

65% wgt CARB 2008:

65% wgt Proposed:

65% wgt Definition: An aerosol adhesive the meets any of the following definitions:

• Polystyrene Foam – designed or labelled to bond polystyrene foam to substrates • Automobile Headliner – designed or labelled to bond together layers in motor

vehicle headliners Survey Results: Number of products: No data Products complying with proposed limit: No data Canadian reported product quantity: No data Canadian reported product quantity complying with proposed limit: No data VOC content range: No data Technical Data/Manufacturer Information: Information from Other Jurisdictions: Summary: The proposed limit is consistent with CARB and OTC rules. Responses to the Environment Canada survey returned no data for this product category. However, experience in California has shown the proposed limit to be technologically feasible.

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Adhesive: Special Purpose Spray (polyolefin, laminate repair/edgebanding) US EPA:

No Limit OTC:

60% wgt CARB 2006:

60% wgt CARB 2008:

60% wgt Proposed:

60% wgt Definition: An aerosol adhesive the meets any of the following definitions:

• Polyolefin – designed or labelled to bond polyolefins to substrates • Laminate Repair/Edgebanding – designed or labelled for:

o The touch-up or repair of items laminated with high-pressure laminates (e.g., lifted edges, delaminates, etc.) or for;

o The touch-up or repair, or attachment of edgebanding materials including, but not limited to, other laminates, synthetic marble, veneers, wood moulding, and decorative materials.

For the purpose of this definition “high-pressure laminate” means sheet materials which consist of paper, fabric, or other core material that have been laminated at temperatures exceeding 130 Celsius and pressures between 1000 and 1400 psi. Survey Results: Number of products: 2 Products complying with proposed limit: 2 (100%) Canadian reported product quantity: No data * Canadian reported product quantity complying with proposed limit: No data VOC content range: Insufficient data * sales volumes were not provided in survey response Technical Data/Manufacturer Information: Information from Other Jurisdictions: Summary: The proposed limit is consistent with CARB and OTC rules. The Environment Canada survey indicated that 100% of individual products sold meet the proposed limits.

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Adhesive: Structural Waterproof US EPA:

15% wgt OTC:

15% wgt CARB 2006:

No Limit CARB 2008:

No Limit Proposed:

15% wgt Definition: An adhesive whose bond lines are resistant to conditions of continuous immersion in fresh or salt water and that conforms with U.S. Federal Specification MMM-A-181 (Type 1, Grade A). Survey Results: Number of products: No data Products complying with proposed limit: No data Canadian reported product quantity: No data Canadian reported product quantity complying with proposed limit: No data VOC content range: No data Technical Data/Manufacturer Information: Information from Other Jurisdictions: Summary: The proposed limit is consistent with US EPA and OTC rules. Responses to the Environment Canada survey returned no data for this product category. However, experience at the US EPA and OTC has shown the proposed limit to be technologically feasible.

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Adhesive: Web Spray US EPA:

75% wgt OTC:

55% wgt CARB 2006:

55% wgt CARB 2008:

45% wgt Proposed:

55% wgt Definition: An aerosol adhesive which is not a mist spray or special purpose spray adhesive Survey Results: Number of products: 6 Products complying with proposed limit: 5 (83%) Canadian reported product quantity: 1471 kg Canadian reported product quantity complying with proposed limit: 1171 kg (80%) VOC content range: 55-75% wgt Technical Data/Manufacturer Information: Information from Other Jurisdictions: On June 6, 2006 the California Air Resource Board (CARB) proposed a new limit for Web Spray Adhesives. The proposed limit, of 45% by weight VOC, will be consulted on over the course of the summer and go to board hearing on November 16, 2006. Summary: The proposed limit is consistent with CARB and OTC rules. The Environment Canada survey indicated that 83% of individual products sold accounting for 80% of sales meet the proposed limits.

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Adhesive Remover: Floor or Wall Covering US EPA:

No Limit OTC:

No Limit CARB 2006:

5% wgt CARB 2008:

5% wgt Proposed:

5% wgt Definition: Products designed or labelled to remove floor or wall coverings and associated adhesive from the underlying substrate. Survey Results: Number of products: 2 Products complying with proposed limit: 0 (0%) Canadian reported product quantity: 2100 kg Canadian reported product quantity complying with proposed limit: 0 kg (0%) VOC content range: Insufficient data Technical Data/Manufacturer Information: Information from Other Jurisdictions: Summary: The proposed limit is consistent with the CARB rule. Responses to the Environment Canada survey indicated that there was no product marketed in Canada meeting the proposed limit. However, experience in California has shown these limits to be technologically feasible.

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Adhesive Remover: Gasket or Thread Locking US EPA:

No Limit OTC:

No Limit CARB 2006:

50% wgt CARB 2008:

50% wgt Proposed:

50% wgt Definition: Products designed or labelled to remove gaskets or thread locking adhesives. Products labelled for dual use as paint stripper and thread locking adhesive remover are considered “Gasket or Thread Locking Adhesive Remover” Survey Results: Number of products: 1 Products complying with proposed limit: 1 (100%) Canadian reported product quantity: 230 kg Canadian reported product quantity complying with proposed limit: 230 kg (100%) VOC content range: Insufficient data Technical Data/Manufacturer Information: Information from Other Jurisdictions: Summary: The proposed limit is consistent with the CARB rule. Environment Canada’s survey identified limited products within this category. However, experience in California has shown these limits to be technologically feasible.

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Adhesive Remover: General Purpose US EPA:

No Limit OTC:

No Limit CARB 2006:

20% wgt CARB 2008:

20% wgt Proposed:

20% wgt Definition: Products designed or labelled to remove cyanoacrylate adhesives as well as non-reactive adhesives or residue from a variety of substrates. “General Purpose Adhesive Remover” includes, but is not limited to, products that remove thermoplastic adhesives; pressure sensitive adhesives; dextrine or starch-based adhesives; casein glues; rubber or latex-based adhesives; as well as products that remove stickers; decals; stencils; or similar materials. “General Purpose Adhesive Remover” does not include “Floor or Wall Covering Adhesive Remover” Survey Results: Number of products: 1 Products complying with proposed limit: 0 (0%) Canadian reported product quantity: 3153 kg Canadian reported product quantity complying with proposed limit: 0 kg (0%) VOC content range: Insufficient data Technical Data/Manufacturer Information: Information from Other Jurisdictions: Summary: The proposed limit is consistent with the CARB rule. Responses to the Environment Canada survey indicated that there was no product marketed in Canada meeting the proposed limit. However, experience in California has shown these limits to be technologically feasible.

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Adhesive Remover: Speciality US EPA:

No Limit OTC:

No Limit CARB 2006:

70% wgt CARB 2008:

70% wgt Proposed:

70% wgt Definition: Products designed or labelled to remove reactive adhesive from a variety of substrates. Reactive adhesives include adhesives that require a hardener or catalyst in order for the bond to occur. Examples of reactive adhesives include, but are not limited to: epoxies; urethanes; silicones. “Specialty Adhesive Remover” does not include “Gasket or Thread Locking Adhesive Remover” Survey Results: Number of products: No data Products complying with proposed limit: No data Canadian reported product quantity: No data Canadian reported product quantity complying with proposed limit: No data VOC content range: No data Technical Data/Manufacturer Information: Information from Other Jurisdictions: Summary: The proposed limit is consistent with the CARB rule. Responses to the Environment Canada survey returned no data for this product category. However, experience at the CARB has shown the proposed limit to be technologically feasible.

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Sealants & Caulking Compounds (small container) US EPA:

No Limit OTC:

4% wgt CARB 2006:

4% wgt CARB 2008:

0.5% wgt Proposed:

4% wgt Definition: A product with adhesive properties that is designed to fill, seal, and waterproof gaps or joints between two surfaces. “Sealant and Caulking Compound” does not include roof cements and roof sealants, insulating foams, removable caulking compounds, clear/paintable/water resistant caulking compounds, floor seam sealers, products designed exclusively for automotive uses, or sealers that are applied as continuous coatings. “Sealants and Caulking Compounds” also does not include units of product, less packaging, which weight more than 454 grams and consist of more than 475 mL. For the purpose of this definition only “removable caulking compounds” means a compound which temporarily seals windows or doors for three to six month time intervals, and “clear/paintable/water resistant caulking compounds” means a compound which contains no appreciable level of opaque fillers or pigments, transmits most or all visible light through the caulk when cured, is paintable, and is immediately resistant to precipitation upon application. Survey Results: Number of products: 292 Products complying with proposed limit: 121 (41%) Canadian reported product quantity: 20013252 kg Canadian reported product quantity complying with proposed limit: 5726692 kg (29%) VOC content range: 0-54% wgt Technical Data/Manufacturer Information: Information from Other Jurisdictions: On June 6, 2006 the California Air Resource Board (CARB) proposed a new limit for Sealants & Caulking Compounds. The proposed limit, of 0.5% by weight VOC, will be consulted on over the course of the summer and go to board hearing on November 16, 2006. The OTC and CARB have both included a maximum container size to which these limitations apply. Environment Canada is reviewing these criteria to determine whether they are appropriate for these regulations. Summary: The proposed limit is consistent with CARB and OTC rules. The Environment Canada survey indicated that 41% of individual products sold accounting for 29% of sales meet the proposed limits.

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PERSONAL CARE

Antiperspirants: Aerosol US EPA:

60% wgt OTC:

50% wgt CARB 2006:

50% wgt CARB 2008:

50% wgt Proposed:

50% wgt Definition: Any aerosol product that is intended by the manufacturer to be used to reduce perspiration in the human axilla by at least 20 percent in at least 50 percent of a target population. Survey Results: Number of products: 3 Products complying with proposed limit: 1 (33%) Canadian reported product quantity: 141,474 kg Canadian reported product quantity complying with proposed limit: 140,049 kg (99%) VOC content range: Insufficient data Technical Data/Manufacturer Information: Information from Other Jurisdictions: Summary: The proposed limit is consistent with CARB and OTC rules. The Environment Canada survey indicated that 33% of individual products sold accounting for 99% of sales meet the proposed limits.

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Antiperspirants: Non-Aerosol US EPA:

No limit OTC:

0% wgt CARB 2006:

0% wgt CARB 2008:

0% wgt Proposed:

0% wgt Definition: Any non-aerosol product including, but not limited to, roll-ons, sticks, pumps, pads, creams, and squeeze-bottles, that is intended by the manufacturer to be used to reduce perspiration in the human axilla by at least 20 percent in at least 50 percent of a target population. Survey Results: Number of products: 67 Products complying with proposed limit: 62 (93%) Canadian reported product quantity: 2,461,391 kg Canadian reported product quantity complying with proposed limit: 2,292,936 kg (93%) VOC content range: 0-16% wgt Technical Data/Manufacturer Information: Information from Other Jurisdictions: Summary: The proposed limit is consistent with CARB and OTC rules. The Environment Canada survey indicated that 93% of individual products sold accounting for 93% of sales meet the proposed limits.

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Hair Mousses US EPA:

16% wgt OTC:

6% wgt CARB 2006:

6% wgt CARB 2008:

6% wgt Proposed:

6% wgt Definition: A hairstyling foam designed to facilitate styling of a coiffure and provide limited holding power. Survey Results: Number of products: 33 Products complying with proposed limit: 17 (52%) Canadian reported product quantity: 1,333,668 kg Canadian reported product quantity complying with proposed limit: 435,902 kg (33%) VOC content range: 5-27% wgt Technical Data/Manufacturer Information: Information from Other Jurisdictions: Summary: The proposed limit is consistent with CARB and OTC rules. The Environment Canada survey indicated that 52% of individual products sold accounting for 33% of sales meet the proposed limits.

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Hair Shines US EPA:

No limit OTC:

55% wgt CARB 2006:

55% wgt CARB 2008:

55% wgt Proposed:

55% wgt Definition: Any product designed for the primary purpose of creating a shine when applied to the hair. “Hair Shine” includes, but is not limited to, dual use products designed primarily to impart sheen to the hair. “Hair Shine” does not include “Hair Spray," “Hair Mousse," “Hair Styling Product,” “Hair Styling Gel,” or products whose primary purpose is to condition or hold the hair. Survey Results: Number of products: 15 Products complying with proposed limit: 13 (87%) Canadian reported product quantity: 21,119 kg Canadian reported product quantity complying with proposed limit: 19,992 kg (95%) VOC content range: 5-69% wgt Technical Data/Manufacturer Information: Information from Other Jurisdictions: Summary: The proposed limit is consistent with CARB and OTC rules. The Environment Canada survey indicated that 87% of individual products sold accounting for 95% of sales meet the proposed limits.

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Hairsprays US EPA:

80% wgt OTC:

55% wgt CARB 2006:

55% wgt CARB 2008:

55% wgt Proposed:

55% wgt Definition: A consumer product that is applied to styled hair, and is designed or labelled to provide sufficient rigidity, to hold, retain and/or (finish) the style of the hair for a period of time. “Hair Spray” includes aerosol hair sprays, pump hair sprays, spray waxes; color, glitter, or sparkle hairsprays that make finishing claims; and products that are both a styling and finishing product. “Hair Spray” does not include spray products that are intended to aid in styling but does not provide finishing of a hairstyle. For the purposes of this subchapter, “finish” or “finishing” means the maintaining and/or holding of previously styled hair for a period of time. For the purposes of this subchapter, "styling" means the forming, sculpting, or manipulating the hair to temporarily alter the hair's shape. Survey Results: Number of products: 53 Products complying with proposed limit: 32 (60%) Canadian reported product quantity: 4,635,480 kg Canadian reported product quantity complying with proposed limit: 1,141,005 kg (25%) VOC content range: 55-93.2% wgt Technical Data/Manufacturer Information: Information from Other Jurisdictions: Summary: The proposed limit is consistent with CARB and OTC rules. The Environment Canada survey indicated that 60% of individual products sold accounting for 25% of sales meet the proposed limits.

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Hair Styling Gels US EPA:

6% wgt OTC:

6% wgt CARB 2006:

6% wgt CARB 2008:

6% wgt Proposed:

6% wgt Definition: A high-viscosity, often gelatinous product that contains a resin and is designed for the application to hair to aid in styling and sculpting of the hair coiffure. Survey Results: Number of products: 25 Products complying with proposed limit: 21 (84%) Canadian reported product quantity: 1,013,356 kg Canadian reported product quantity complying with proposed limit: 833,156 kg (82%) VOC content range: 2-41% wgt Technical Data/Manufacturer Information: Information from Other Jurisdictions: Summary: The proposed limit is consistent with US EPA, CARB and OTC rules. The Environment Canada survey indicated that 84% of individual products sold accounting for 82% of sales meet the proposed limits.

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45

Hair Styling Products: Aerosol and Pump Sprays US EPA:

No limit OTC:

No limit CARB 2006:

6% wgt CARB 2008:

6% wgt Proposed:

6% wgt Definition: "An aerosol or pump spray consumer product that is designed or labelled for the application to wet, damp or dry hair to aid in defining, shaping, lifting, styling and/or sculpting of the hair. “Hair Styling Product” does not include “Hair Mousse,"" “Hair Shine,"" “Hair Spray,"" or shampoos and/or conditioners that are rinsed from the hair prior to styling. For the purposes of this subchapter, “finish” or “finishing” means the maintaining and/or holding of previously styled hair for a period of time. For the purposes of this subchapter, ""styling"" means the forming, sculpting, or manipulating the hair to temporarily alter the hair's shape." Survey Results: Number of products: 21 Products complying with proposed limit: 11 (52%) Canadian reported product quantity: 123,112 kg Canadian reported product quantity complying with proposed limit: 97,091 kg (79%) VOC content range: 6-69% wgt Technical Data/Manufacturer Information: Information from Other Jurisdictions: Summary: The proposed limit is consistent with the CARB rule. The Environment Canada survey indicated that 52% of individual products sold accounting for 79% of sales meet the proposed limits.

revised September 15, 2006

46

Hair Styling Products: All Other Forms US EPA:

No limit OTC:

No limit CARB 2006:

2% wgt CARB 2008:

2% wgt Proposed:

2% wgt Definition: "A consumer product, which is neither an aerosol or pump spray, that is designed or labelled for the application to wet, damp or dry hair to aid in defining, shaping, lifting, styling and/or sculpting of the hair. “Hair Styling Product-all other forms” includes, but is not limited to hair balm, clay, cream, curl straightener, gel, liquid, lotion, paste, pomade, putty, root lifter, serum, stick, temporary hair straightener, wax, that aid in styling but do not provide finishing of a hairstyle, and leave-in volumizers, detanglers and/or conditioners that make styling claims. “Hair Styling Product” does not include “Hair Mousse,"" “Hair Shine,"" “Hair Spray,"" or shampoos and/or conditioners that are rinsed from the hair prior to styling. For the purposes of this subchapter, “finish” or “finishing” means the maintaining and/or holding of previously styled hair for a period of time. For the purposes of this subchapter, ""styling"" means the forming, sculpting, or manipulating the hair to temporarily alter the hair's shape." Survey Results: Number of products: 39 Products complying with proposed limit: 28 (72%) Canadian reported product quantity: 438,322 kg Canadian reported product quantity complying with proposed limit: 432,090 kg (99%) VOC content range: 0-40% wgt Technical Data/Manufacturer Information: Information from Other Jurisdictions: Summary: The proposed limit is consistent with the CARB rule. The Environment Canada survey indicated that 72% of individual products sold accounting for 99% of sales meet the proposed limits.

revised September 15, 2006

47

Nail Polish Remover US EPA:

85% wgt OTC:

75% wgt CARB 2006:

0% wgt CARB 2008:

0% wgt Proposed:

0% wgt Definition: A product designed to remove nail polish or coatings from fingernails or toenails. Survey Results: Number of products: 16 Products complying with proposed limit: 7 (44%) Canadian reported product quantity: 306,762 kg Canadian reported product quantity complying with proposed limit: 247,484 kg (81%) VOC content range: 0-91.5% wgt Technical Data/Manufacturer Information: Information from Other Jurisdictions: Summary: The proposed limit is consistent with the CARB rule. The Environment Canada survey indicated that 44% of individual products sold accounting for 81% of sales meet the proposed limits.

revised September 15, 2006

48

Personal Fragrance Products: 20% or Less Fragrance US EPA:

No limit OTC: CARB 2006:

75% wgt CARB 2008: Proposed:

No limit 75% wgt 75% wgt Definition: A product with 20 percent or less fragrance, which is applied to the human body or clothing for the primary purpose of adding a scent or masking a malodour, including cologne, perfume, aftershave, and toilet water. “Personal Fragrance Product” does not include: (A) Deodorant; (B) medicated products designed primarily to alleviate fungal or bacterial growth on feet or other areas of the body; (C) mouthwashes, breath fresheners and deodorizers; (D) lotions, moisturizers, powders or other skin care products used primarily to alleviate skin conditions such as dryness and irritations; (E) products designed exclusively for use on human genitalia; (F) soaps, shampoos, and products primarily used to clean the human body; and (G) fragrance products designed to be used exclusively on non-human animals. Survey Results: Number of products: 504 Products complying with proposed limit: 429 (85%) Canadian reported product quantity: 1,211,528 kg Canadian reported product quantity complying with proposed limit: 1,155,476 kg (95%) VOC content range: 0-94.3% wgt Technical Data/Manufacturer Information: Information from Other Jurisdictions: Summary: The proposed limit is consistent with the CARB rule. The Environment Canada survey indicated that 85% of individual products sold accounting for 95% of sales meet the proposed limits.

revised September 15, 2006

49

Personal Fragrance Products: More than 20 % Fragrance US EPA:

No limit OTC:

No limit CARB 2006:

65% wgt CARB 2008:

65% wgt Proposed:

65% wgt Definition: A product with more than 20 percent fragrance, which is applied to the human body or clothing for the primary purpose of adding a scent or masking a malodour, including cologne, perfume, aftershave, and toilet water. “Personal Fragrance Product” does not include: (A) Deodorant; (B) medicated products designed primarily to alleviate fungal or bacterial growth on feet or other areas of the body; (C) mouthwashes, breath fresheners and deodorizers; (D) lotions, moisturizers, powders or other skin care products used primarily to alleviate skin conditions such as dryness and irritations; (E) products designed exclusively for use on human genitalia; (F) soaps, shampoos, and products primarily used to clean the human body; and (G) fragrance products designed to be used exclusively on non-human animals. Survey Results: Number of products: 47 Products complying with proposed limit: 30 (64%) Canadian reported product quantity: 47,291 kg Canadian reported product quantity complying with proposed limit: 15,197 kg (32%) VOC content range: 0-88% wgt Technical Data/Manufacturer Information: Information from Other Jurisdictions: Summary: The proposed limit is consistent with the CARB rule. The Environment Canada survey indicated that 64% of individual products sold accounting for 32% of sales meet the proposed limits.

revised September 15, 2006

50

Shaving Creams US EPA:

5% wgt OTC:

5% wgt CARB 2006:

5% wgt CARB 2008:

5% wgt Proposed:

5% wgt Definition: An aerosol product that dispenses a foam lather intended to be used with a blade or cartridge razor, or other wetshaving system in the removal of facial or other body hair. "Shaving Cream" does not include "Shaving Gel." Survey Results: Number of products: 13 Products complying with proposed limit: 11 (85%) Canadian reported product quantity: 2,388,807 kg Canadian reported product quantity complying with proposed limit: 2,387,790 kg (100%) VOC content range: 0-6% wgt Technical Data/Manufacturer Information: Information from Other Jurisdictions: Summary: The proposed limit is consistent with US EPA, CARB and OTC rules. The Environment Canada survey indicated that 85% of individual products sold accounting for 100% of sales meet the proposed limits.

revised September 15, 2006

51

Shaving Gels US EPA:

No limit OTC:

No limit CARB 2006:

7% wgt CARB 2008:

7% wgt Proposed:

7% wgt Definition: "A product that dispenses a gel intended to be used with a blade or cartridge razor, or other wetshaving system in the removal of facial or other body hair. Gel means a colloid in which the dispersed phase has combined with the continuous phase to produce a semisolid material, such as jelly. "Shaving Gel" does not include "Shaving Cream." Survey Results: Number of products: 10 Products complying with proposed limit: 10 (100%) Canadian reported product quantity: 3,246,687 kg Canadian reported product quantity complying with proposed limit: 3,246,687 kg (100%) VOC content range: 2.2-7% wgt Technical Data/Manufacturer Information: Information from Other Jurisdictions: Summary: The proposed limit is consistent with the CARB rule. The Environment Canada survey indicated that 100% of individual products sold accounting for 100% of sales meet the proposed limits.

revised September 15, 2006

52

Underarm Deodorants: Aerosol US EPA:

20% HVOC OTC:

0% HVOC, 10% MVOC

CARB 2006: 0% HVOC, 10% MVOC

CARB 2008: 0% HVOC, 10% MVOC

Proposed: 10% wgt

Definition: Any aerosol product that is intended by the manufacturer to be used to minimize odour in the human axilla by retarding the growth of bacteria that cause the decomposition of perspiration Survey Results: Number of products: 3 Products complying with proposed limit: 1 (33%) Canadian reported product quantity: 61,981 kg Canadian reported product quantity complying with proposed limit: 60,638 kg (98%) VOC content range: Insufficient data Technical Data/Manufacturer Information: Information from Other Jurisdictions: Summary: The proposed limit of 10% applies to total VOC content in the product. The Environment Canada survey indicated that 33% of individual products sold accounting for 98% of sales meet the proposed limits.

revised September 15, 2006

53

Underarm Deodorants: Non-Aerosol US EPA:

No limit OTC:

0% wgt CARB 2006:

0% wgt CARB 2008:

0% wgt Proposed:

0% wgt Definition: Any non-aerosol product including, but not limited to, roll-ons, sticks, pumps, pads, creams, and squeeze-bottles, that indicates or depicts on the container or packaging, or on any sticker or label affixed thereto, that the product can be used on or applied to the human axilla to provide a scent an/or minimize odour. Survey Results: Number of products: 62 Products complying with proposed limit: 34 (55%) Canadian reported product quantity: 369,738 kg Canadian reported product quantity complying with proposed limit: 137,477 kg (37%) VOC content range: 0-94.7% wgt Technical Data/Manufacturer Information: Information from Other Jurisdictions: Summary: The proposed limit is consistent with CARB and OTC rules. The Environment Canada survey indicated that 55% of individual products sold accounting for 37% of sales meet the proposed limits.

revised September 15, 2006

54

HOUSEHOLD Air Fresheners: Single-Phase US EPA:

70% wgt OTC:

30% wgt CARB 2006:

30% wgt CARB 2008:

30% wgt Proposed:

30% wgt Definition: An aerosol air freshener with liquid contents in a single homogeneous phase that does not require that the product container be shaken before use. Survey Results: Number of products: 28 Products complying with proposed limit: 16 (57%) Canadian reported product quantity: 980,620 kg Canadian reported product quantity complying with proposed limit: 895,185 kg (91%) VOC content range: 30-100% wgt Technical Data/Manufacturer Information: Information from Other Jurisdictions: Summary: The proposed limit is consistent with CARB and OTC rules. The Environment Canada survey indicated that 57% of individual products sold accounting for 91% of sales meet the proposed limits.

revised September 15, 2006

55

Air Fresheners: Double-Phase US EPA:

30% wgt OTC:

25% wgt CARB 2006:

25% wgt CARB 2008:

0% wgt Proposed:

25% wgt Definition: An aerosol air freshener with liquid contents in two or more distinct phases that requires the product container to be shaken before use to mix the phases, producing an emulsion. Survey Results: Number of products: 7 Products complying with proposed limit: 5 (71%) Canadian reported product quantity: 1,881,684 kg Canadian reported product quantity complying with proposed limit: 1,868,560 (99%) VOC content range: 24-30% wgt Technical Data/Manufacturer Information: Information from Other Jurisdictions: Summary: The proposed limit is consistent with CARB and OTC rules. The Environment Canada survey indicated that 71% of individual products sold accounting for 99% of sales meet the proposed limits.

revised September 15, 2006

56

Air Fresheners: Liquids/Pump Sprays US EPA:

18% wgt OTC:

18% wgt CARB 2006:

18% wgt CARB 2008:

0.5% wgt Proposed:

18% wgt Definition: Any liquid or pump spray product designed for the purpose of masking odours, or freshening, cleaning, scenting, or deodorizing the air. “Air Freshener” does not include products that are used on the human body, products that function primarily as cleaning products as indicated on a product label, or “Toilet/Urinal Care Product.” “Pump Spray” means a packaging system in which the product ingredients within the container are not under pressure and in which the product is expelled only while a pumping action is applied to a button, trigger or other actuator. Survey Results: Number of products: 68 Products complying with proposed limit: 65 (96%) Canadian reported product quantity: 864,762 kg Canadian reported product quantity complying with proposed limit: 860,900 kg (100%) VOC content range: 1.1-70% wgt Technical Data/Manufacturer Information: Information from Other Jurisdictions: On June 6, 2006 the California Air Resource Board (CARB) proposed a new limit for Liquids/Pump Spray Air Fresheners. The proposed limit, of 0.5% by weight VOC, will be consulted on over the course of the summer and go to board hearing on November 16, 2006. Summary: The proposed limit is consistent with US EPA, CARB and OTC rules. The Environment Canada survey indicated that 96% of individual products sold accounting for 100% of sales meet the proposed limits.

revised September 15, 2006

57

Air Fresheners: Solids/Semisolid US EPA:

3% wgt OTC:

3% wgt CARB 2006:

3% wgt CARB 2008:

3% wgt Proposed:

3% wgt Definition: Any solid or semi-solid product designed for the purpose of masking odours, or freshening, cleaning, scenting, or deodorizing the air. “Air Freshener” does not include products that are used on the human body, products that function primarily as cleaning products as indicated on a product label, or “Toilet/Urinal Care Product.” “Semisolid” means a product that, at room temperature, will not pour, but will spread or deform easily. “Solid” means a substance or mixture of substances which, either whole or subdivided (such as the particles comprising a powder), is not capable of visually detectable flow. Survey Results: Number of products: 25 Products complying with proposed limit: 22 (88%) Canadian reported product quantity: 2,779,198 kg Canadian reported product quantity complying with proposed limit: 2,254,121 kg (81%) VOC content range: 0-100% wgt Technical Data/Manufacturer Information: Information from Other Jurisdictions: Summary: The proposed limit is consistent with US EPA, CARB and OTC rules. The Environment Canada survey indicated that 88% of individual products sold accounting for 81% of sales meet the proposed limits.

revised September 15, 2006

58

Air Fresheners: Dual Purpose Air Fresheners/Disinfectant US EPA:

No limit OTC:

No limit CARB 2006:

60% wgt CARB 2008:

60% wgt Proposed:

60% wgt Definition: An aerosol product that is represented on the product container for use as both a disinfectant and an air freshener, or is so represented on any sticker, label, packaging, or literature attached to the product container. Survey Results: Number of products: 8 Products complying with proposed limit: 4 (50%) Canadian reported product quantity: 25,047 kg Canadian reported product quantity complying with proposed limit: 8,877 (35%) VOC content range: 0.8-83% wgt Technical Data/Manufacturer Information: Information from Other Jurisdictions: Summary: The proposed limit is consistent with the CARB rule. The Environment Canada survey indicated that 50% of individual products sold accounting for 35% of sales meet the proposed limits.

revised September 15, 2006

59

Anti-Static Product: Aerosol US EPA:

No limit OTC:

No limit CARB 2006:

80% wgt CARB 2008:

80% wgt Proposed:

80% wgt Definition: An aerosol product that is labelled to eliminate, prevent, or inhibit the accumulation of static electricity. “Anti-Static Product” does not include “Electronic Cleaner,” “Floor Polish or Wax,” “Floor Coating,” and products that meet the definition of “Aerosol Coating Product” or “Architectural Coating.” Survey Results: Number of products: 2 Products complying with proposed limit: 0 (0%) Canadian reported product quantity: 75,554 kg Canadian reported product quantity complying with proposed limit: 0 kg (0%) VOC content range: Insufficient data Technical Data/Manufacturer Information: Information from Other Jurisdictions: Summary: The proposed limit is consistent with the CARB limit. Responses to the Environment Canada survey indicated that there was no product marketed in Canada meeting the proposed limit. However, experience in California has shown these limits to be technologically feasible.

revised September 15, 2006

60

Anti-Static Product: Non-Aerosol US EPA:

No limit OTC:

No limit CARB 2006:

11% wgt CARB 2008:

11% wgt Proposed:

11% wgt Definition: A non-aerosol product that is labelled to eliminate, prevent, or inhibit the accumulation of static electricity. “Anti-Static Product” does not include “Electronic Cleaner,” “Floor Polish or Wax,” “Floor Coating,” and products that meet the definition of “Aerosol Coating Product” or “Architectural Coating.” Survey Results: Number of products: 18 Products complying with proposed limit: 16 (89%) Canadian reported product quantity: 40,440,404 kg Canadian reported product quantity complying with proposed limit: 40,419,039 kg (100%) VOC content range: 0-100% wgt Technical Data/Manufacturer Information: Information from Other Jurisdictions: Summary: The proposed limit is consistent with the CARB rule. The Environment Canada survey indicated that 89% of individual products sold accounting for 100% of sales meet the proposed limits.

revised September 15, 2006

61

Bathroom and Tile Cleaners: Aerosol US EPA:

7% wgt OTC:

7% wgt CARB 2006:

7% wgt CARB 2008:

5% wgt Proposed:

7% wgt Definition: An aerosol product designed to clean tile or surfaces in bathrooms. “Bathroom and tile cleaner” does not include products specifically designed to clean toilet bowls or toilet tanks. Survey Results: Number of products: 4 Products complying with proposed limit: 4 (100%) Canadian reported product quantity: 1,302,014 kg Canadian reported product quantity complying with proposed limit: 1,302,014 (100%) VOC content range: Insufficient data Technical Data/Manufacturer Information: Information from Other Jurisdictions: On June 6, 2006 the California Air Resource Board (CARB) proposed a new limit for Aerosol Bathroom and Tile Cleaners. The proposed limit, of 5% by weight VOC, will be consulted on over the course of the summer and go to board hearing on November 16, 2006. Summary: The proposed limit is consistent with the US EPA, CARB and OTC rules. The Environment Canada survey indicated that 100% of individual products sold accounting for 100% of sales meet the proposed limits.

revised September 15, 2006

62

Bathroom and Tile Cleaners: All Other Forms US EPA:

5% wgt OTC:

5% wgt CARB 2006:

5% wgt CARB 2008:

1% wgt Proposed:

5% wgt Definition: A non-aerosol product including, but is not limited to, solids, liquids, wicks, powders, crystals, and cloth or paper wipes (towelettes), designed to clean tile or surfaces in bathrooms. “Bathroom and tile cleaner” does not include products specifically designed to clean toilet bowls or toilet tanks. Survey Results: Number of products: 48 Products complying with proposed limit: 44 (92%) Canadian reported product quantity: 2,791,047 kg Canadian reported product quantity complying with proposed limit: 2,636,420 kg (94%) VOC content range: 0-12.2% wgt Technical Data/Manufacturer Information: Information from Other Jurisdictions: On June 6, 2006 the California Air Resource Board (CARB) proposed a new limit for Non-aerosol Bathroom and Tile Cleaners. The proposed limit, of 1% by weight VOC, will be consulted on over the course of the summer and go to board hearing on November 16, 2006. Summary: The proposed limit is consistent with the US EPA, CARB and OTC rules. The Environment Canada survey indicated that 92% of individual products sold accounting for 94% of sales meet the proposed limits.

revised September 15, 2006

63

Bug and Tar Remover US EPA:

No limit OTC:

40% wgt CARB 2006:

40% wgt CARB 2008:

40% wgt Proposed:

40% wgt Definition: A product labelled to remove either or both of the following from painted motor vehicle surfaces without causing damage to the finish: (A) biological-type residues such as insect carcasses and tree sap and, (B) road grime, such as road tar, roadway paint markings, and asphalt. Survey Results: Number of products: 16 Products complying with proposed limit: 11 (68%) Canadian reported product quantity: 80,750 kg Canadian reported product quantity complying with proposed limit: 57,860 kg (72%) VOC content range: 8-100% wgt Technical Data/Manufacturer Information: Information from Other Jurisdictions: Summary: The proposed limit is consistent with the CARB and OTC rules. The Environment Canada survey indicated that 68% of individual products sold accounting for 72% of sales meet the proposed limits.

revised September 15, 2006

64

Carpet and Upholstery Cleaner: Aerosol US EPA:

No limit OTC:

7% wgt CARB 2006:

7% wgt CARB 2008:

5% wgt Proposed:

7% wgt Definition: An aerosol cleaning product designed for the purpose of eliminating dirt and stains on rugs, carpeting, and the interior of motor vehicles and/or on household furniture or objects upholstered or covered with fabrics such as wool, cotton, nylon or other synthetic fabrics. “Carpet and Upholstery Cleaner” includes, but is not limited to, products that make fabric protectant claims. “Carpet and Upholstery Cleaner” does not include “General Purpose Cleaners,”, “Spot Removers,”, vinyl or leather cleaners, dry cleaning fluids, or products designed exclusively for use at industrial facilities engaged in furniture or carpet manufacturing. Survey Results: Number of products: 12 Products complying with proposed limit: 8 (66%) Canadian reported product quantity: 578,363 kg Canadian reported product quantity complying with proposed limit: 303,944 kg (53%) VOC content range: 7-60% wgt Technical Data/Manufacturer Information: Information from Other Jurisdictions: On June 6, 2006 the California Air Resource Board (CARB) proposed a new limit for Aerosol Carpet and Upholstery Cleaners. The proposed limit, of 5% by weight VOC, will be consulted on over the course of the summer and go to board hearing on November 16, 2006. Summary: The proposed limit is consistent with the CARB and OTC rules. The Environment Canada survey indicated that 66% of individual products sold accounting for 53% of sales meet the proposed limits.

revised September 15, 2006

65

Carpet and Upholstery Cleaner: Non-Aerosol (Dilutables) US EPA:

No limit OTC:

0.1% wgt CARB 2006:

0.1% wgt CARB 2008:

0.1% wgt Proposed:

0.1% wgt Definition: A non-aerosol, dilutable cleaning product designed for the purpose of eliminating dirt and stains on rugs, carpeting, and the interior of motor vehicles and/or on household furniture or objects upholstered or covered with fabrics such as wool, cotton, nylon or other synthetic fabrics. “Carpet and Upholstery Cleaner” includes, but is not limited to, products that make fabric protectant claims. “Carpet and Upholstery Cleaner” does not include “General Purpose Cleaners,” “Spot Removers,” vinyl or leather cleaners, dry cleaning fluids, or products designed exclusively for use at industrial facilities engaged in furniture or carpet manufacturing. "Dilutable" means that the product is intended to be used with the addition of a solvent to reduce the concentration of the product." Survey Results: Number of products: 23 Products complying with proposed limit: 18 (78%) Canadian reported product quantity: 111,792 kg Canadian reported product quantity complying with proposed limit: 88,989 kg (80%) VOC content range: 0.1-3.3% wgt Technical Data/Manufacturer Information: Information from Other Jurisdictions: Summary: The proposed limit is consistent with the CARB and OTC rules. The Environment Canada survey indicated that 73% of individual products sold accounting for 80% of sales meet the proposed limits.

revised September 15, 2006

66

Carpet and Upholstery Cleaner: Non-Aerosol (Ready-to-use) US EPA:

No limit OTC:

3% wgt CARB 2006:

3% wgt CARB 2008:

1% wgt Proposed:

3% wgt Definition: A non-aerosol, ready-to-use cleaning product designed for the purpose of eliminating dirt and stains on rugs, carpeting, and the interior of motor vehicles and/or on household furniture or objects upholstered or covered with fabrics such as wool, cotton, nylon or other synthetic fabrics. “Carpet and Upholstery Cleaner” includes, but is not limited to, products that make fabric protectant claims. “Carpet and Upholstery Cleaner” does not include “General Purpose Cleaners,”, “Spot Removers,” vinyl or leather cleaners, dry cleaning fluids, or products designed exclusively for use at industrial facilities engaged in furniture or carpet manufacturing. "Ready-to-use" means that the product is marketed in a finished condition to be used as is." Survey Results: Number of products: 9 Products complying with proposed limit: 6 (67%) Canadian reported product quantity: 327,379 kg Canadian reported product quantity complying with proposed limit: 120,892 kg (37%) VOC content range: 0-94.8% wgt Technical Data/Manufacturer Information: Information from Other Jurisdictions: On June 6, 2006 the California Air Resource Board (CARB) proposed a new limit for Ready-to-use Non-aerosol Carpet and Upholstery Cleaners. The proposed limit, of 1% by weight VOC, will be consulted on over the course of the summer and go to board hearing on November 16, 2006. Summary: The proposed limit is consistent with the CARB and OTC rules. The Environment Canada survey indicated that 67% of individual products sold accounting for 37% of sales meet the proposed limits.

revised September 15, 2006

67

Charcoal Lighter Material US EPA:

VOC emission limit 9 grams per start

OTC: Ignition must be less than 0.02 pound of VOC per start

CARB 2006: Ignition must be less than 0.02 pound of VOC per start

CARB 2008: Ignition must be less than 0.01 pound of VOC per start for Charcoal Lighter Fluids and Impregnated Briquettes

Proposed: Ignition must be less than 0.02 pound of VOC per start

Definition: Any combustible material designed to be applied on, incorporated in, added to, or used with charcoal to enhance ignition. “Charcoal lighter material” does not include any of the following: • electrical starters and probes; • metallic cylinders using paper tinder; • natural gas; and • propane. Survey Results: Number of products: 2 Products complying with proposed limit: 0 (0%) Canadian reported product quantity: 79,567 kg Canadian reported product quantity complying with proposed limit: 0 kg (0%) VOC content range: Insufficient data Technical Data/Manufacturer Information: Information from Other Jurisdictions: On June 6, 2006 the California Air Resource Board (CARB) proposed a new limit for Charcoal Lighter Fluids and Impregnated Briquettes. The proposed limit, of 0.01% by weight VOC, will be consulted on over the course of the summer and go to board hearing on November 16, 2006. Summary: The proposed limit is consistent with CARB and OTC rules. Responses to the Environment Canada survey indicated that there was no product marketed in Canada meeting the proposed limit. However, experience in California has shown these limits to be technologically feasible.

revised September 15, 2006

68

Cooking Spray: Aerosols US EPA:

18% wgt OTC:

18% wgt CARB 2006:

18% wgt CARB 2008:

14% wgt Proposed:

18% wgt Definition: Any aerosol product designed either to reduce sticking on cooking and baking surfaces or to be directly applied on food for the purpose of reducing sticking on cooking and baking surfaces, or both. Survey Results: Number of products: No data Products complying with proposed limit: No data Canadian reported product quantity: No data Canadian reported product quantity complying with proposed limit: No data VOC content range: No data Technical Data/Manufacturer Information: Information from Other Jurisdictions: On June 6, 2006 the California Air Resource Board (CARB) proposed a new limit for Aerosol Cooking Sprays. The proposed limit, of 14% by weight VOC, will be consulted on over the course of the summer and go to board hearing on November 16, 2006. Summary: The proposed limit is consistent with the US EPA, CARB and OTC rules. Responses to the Environment Canada survey returned no data for this product category. However, experience across the United States has shown the proposed limit to be technologically feasible.

revised September 15, 2006

69

Dusting Aids: Aerosols US EPA:

35% wgt OTC:

25% wgt CARB 2006:

25% wgt CARB 2008:

20% wgt Proposed:

25% wgt Definition: An aerosol product designed to assist in removing dust and other soils from floors and other surfaces without leaving a wax or silicone-based coating. “Dusting aid” does not include products that consist entirely of compressed gases for use in electronic or other specialty areas. Survey Results: Number of products: 1 Products complying with proposed limit: 1 (100%) Canadian reported product quantity: 771 kg Canadian reported product quantity complying with proposed limit: 771 kg (100%) VOC content range: Insufficient data Technical Data/Manufacturer Information: Information from Other Jurisdictions: On June 6, 2006 the California Air Resource Board (CARB) proposed a new limit for Aerosol Dusting Aids. The proposed limit, of 20% by weight VOC, will be consulted on over the course of the summer and go to board hearing on November 16, 2006. Summary: The proposed limit is consistent with the CARB and OTC rules. The Environment Canada survey indicated that 100% of individual products sold accounting for 100% of sales meet the proposed limits.

revised September 15, 2006

70

Dusting Aids: Non-Aerosols US EPA:

7% wgt OTC:

7% wgt CARB 2006:

7% wgt CARB 2008:

5% wgt Proposed:

7% wgt Definition: A non-aerosol product designed to assist in removing dust and other soils from floors and other surfaces without leaving a wax or silicone-based coating. “Dusting aid” does not include products that consist entirely of compressed gases for use in electronic or other specialty areas. Survey Results: Number of products: 9 Products complying with proposed limit: 8 (89%) Canadian reported product quantity: 323,249 kg Canadian reported product quantity complying with proposed limit: 322,652 kg (100%) VOC content range: 7-100% wgt Technical Data/Manufacturer Information: Information from Other Jurisdictions: On June 6, 2006 the California Air Resource Board (CARB) proposed a new limit for Non-aerosol Dusting Aids. The proposed limit, of 5% by weight VOC, will be consulted on over the course of the summer and go to board hearing on November 16, 2006. Summary: The proposed limit is consistent with the US EPA, CARB and OTC rules. The Environment Canada survey indicated that 89% of individual products sold accounting for 100% of sales meet the proposed limits.

revised September 15, 2006

71

Electronic Cleaners US EPA:

No limit OTC:

No limit CARB 2006:

75% wgt CARB 2008:

75% wgt Proposed:

75% wgt Definition: A product labelled for the removal of dirt, moisture, dust, flux, or oxides from the internal components of electronic or precision equipment such as circuit boards, and the internal components of electronic devices, including but not limited to, radios, compact disc (CD) players, digital video disc (DVD) players, and computers. Electronic Cleaner does not include “General Purpose Cleaner,” “General Purpose Degreaser,” “Dusting Aid,” “Pressurized Gas Duster,” “Engine Degreaser,” “Electrical Cleaner,” “Energized Electrical Cleaner,” “Anti-Static Product,” or products designed to clean the casings or housings of electronic equipment. Survey Results: Number of products: 58 Products complying with proposed limit: 18 (31%) Canadian reported product quantity: 411,968 kg Canadian reported product quantity complying with proposed limit: 47,754 kg (12%) VOC content range: 20-100% wgt Technical Data/Manufacturer Information: Information from Other Jurisdictions: Summary: The proposed limit is consistent with the CARB rule. The Environment Canada survey indicated that 31% of individual products sold accounting for 12% of sales meet the proposed limits.

revised September 15, 2006

72

Fabric Refresher: Aerosol US EPA:

No limit OTC:

No limit CARB 2006:

15% wgt CARB 2008:

15% wgt Proposed:

15% wgt Definition: "An aerosol product labelled to neutralize or eliminate odours on non-laundered fabric including, but not limited to, soft household surfaces, rugs, carpeting, draperies, bedding, automotive interiors, footwear, athletic equipment, clothing and/or on household furniture or objects upholstered or covered with fabrics such as, but not limited to, wool, cotton, or nylon. ""Fabric Refresher"" does not include “Anti-static Product,” ""Carpet and Upholstery Cleaner,"" soft household surface sanitizers, ""Footwear or Leather Care Product,"" ""Spot Remover,"" or ""Disinfectant,"" or products labelled for application to both fabric and human skin." Survey Results: Number of products: 3 Products complying with proposed limit: 1 (33%) Canadian reported product quantity: 32,356 kg Canadian reported product quantity complying with proposed limit: 10 kg (0%) VOC content range: Insufficient data Technical Data/Manufacturer Information: Information from Other Jurisdictions: Summary: The propose limit is consistent with the CARB rule. Responses to the Environment Canada survey indicated that there was little product sold in Canada that meets the proposed limit. However, experience in California has shown these limits to be technologically feasible.

revised September 15, 2006

73

Fabric Refresher: Non-Aerosol US EPA:

No limit OTC:

No limit CARB 2006:

6% wgt CARB 2008:

6% wgt Proposed:

6% wgt Definition: A non-aerosol product labelled to neutralize or eliminate odours on non-laundered fabric including, but not limited to, soft household surfaces, rugs, carpeting, draperies, bedding, automotive interiors, footwear, athletic equipment, clothing and/or on household furniture or objects upholstered or covered with fabrics such as, but not limited to, wool, cotton, or nylon. "Fabric Refresher" does not include “Anti-static Product,” "Carpet and Upholstery Cleaner," soft household surface sanitizers, "Footwear or Leather Care Product," "Spot Remover," or "Disinfectant," or products labelled for application to both fabric and human skin. Survey Results: Number of products: 6 Products complying with proposed limit: 5 (83%) Canadian reported product quantity: 3,339,696 kg Canadian reported product quantity complying with proposed limit: 3,122,074 kg (93%) VOC content range: 3.8-7% wgt Technical Data/Manufacturer Information: Information from Other Jurisdictions: Summary: The proposed limit is consistent with the CARB rule. The Environment Canada survey indicated that 83% of individual products sold accounting for 93% of sales meet the proposed limits.

revised September 15, 2006

74

Fabric Protectants US EPA:

75% wgt OTC:

60% wgt CARB 2006:

60% wgt CARB 2008:

16% wgt (Aerosol), 1% wgt (Non-Aerosol)

Proposed: 60% wgt

Definition: A product designed to be applied to fabric substrates to protect the surface from soiling from dirt and other impurities or to reduce absorption of water into the fabric's fibres. “Fabric protectant” does not include silicone-based products whose function is to provide water repellency, or products designed for use solely on fabrics that are labelled “dry clean only.” Survey Results: Number of products: 6 Products complying with proposed limit: 2 (33%) Canadian reported product quantity: 12,841 kg Canadian reported product quantity complying with proposed limit: 8,516 (66%) VOC content range: 60-98% wgt Technical Data/Manufacturer Information: Information from Other Jurisdictions: On June 6, 2006 the California Air Resource Board (CARB) proposed a new limit for Aerosol and Non-aerosol Fabric Protectants. The proposed limit, of 16% and 1% by weight VOC for Aerosol and Non-aerosol Fabric Protectants, respectively, will be consulted on over the course of the summer and go to board hearing on November 16, 2006. Summary: The proposed limit is consistent with the CARB and OTC rules. The Environment Canada survey indicated that 33% of individual products sold accounting for 66% of sales meet the proposed limits.

revised September 15, 2006

75

Floor Polishes/Waxes: Products for Flexible Flooring Materials US EPA:

7% wgt OTC:

7% wgt CARB 2006:

7% wgt CARB 2008:

1% wgt Proposed:

7% wgt Definition: A wax, polish, or any other product designed to polish, protect, or enhance floor surfaces made of flexible flooring material (i.e. asphalt, cork, linoleum, no wax, rubber, seamless vinyl, and vinyl composite flooring), by leaving a protective coating that is designed to be periodically replenished. “Floor polish or wax” does not include “spray buff products,” products designed solely for the purpose of cleaning floors, floor finish strippers, products designed for unfinished wood floors. Survey Results: Number of products: 43 Products complying with proposed limit: 42 (98%) Canadian reported product quantity: 2,386,447 kg Canadian reported product quantity complying with proposed limit: 2,346,009 kg (98%) VOC content range: 0-7.9% wgt Technical Data/Manufacturer Information: Information from Other Jurisdictions: On June 6, 2006 the California Air Resource Board (CARB) proposed a new limit for Floor Polishes/Waxes for Flexible Flooring Materials. The proposed limit, of 1% by weight VOC, will be consulted on over the course of the summer and go to board hearing on November 16, 2006. Summary: The proposed limit is consistent with the US EPA, CARB and OTC rules. The Environment Canada survey indicated that 98% of individual products sold accounting for 98% of sales meet the proposed limits.

revised September 15, 2006

76

Floor Polishes/Waxes: Products for Nonresilient Flooring US EPA:

10% wgt OTC:

10% wgt CARB 2006:

10% wgt CARB 2008:

1% wgt Proposed:

10% wgt Definition: "A wax, polish, or any other product designed to polish, protect, or enhance non-resilient floor surfaces by leaving a protective coating that is designed to be periodically replenished. “Floor polish or wax” does not include “spray buff products,” products designed solely for the purpose of cleaning floors, floor finish strippers, products designed for unfinished wood floors. Non-resilient flooring means floor of a mineral content that is not flexible. “Non-resilient flooring” includes, but is not limited to, terrazzo, marble, slate, granite, brick, stone, ceramic tile, and concrete." Survey Results: Number of products: 7 Products complying with proposed limit: 4 (57%) Canadian reported product quantity: 72,969 kg Canadian reported product quantity complying with proposed limit: 58,177 kg (80%) VOC content range: 0-60% wgt Technical Data/Manufacturer Information: Information from Other Jurisdictions: On June 6, 2006 the California Air Resource Board (CARB) proposed a new limit for Floor Polishes/Waxes for Nonresilient Flooring Materials. The proposed limit, of 1% by weight VOC, will be consulted on over the course of the summer and go to board hearing on November 16, 2006. Summary: The proposed limit is consistent with the US EPA, CARB and OTC rules. The Environment Canada survey indicated that 57% of individual products sold accounting for 80% of sales meet the proposed limits.

revised September 15, 2006

77

Floor Polishes/Waxes: Wood Floor Wax US EPA:

90% wgt OTC:

90% wgt CARB 2006:

90% wgt CARB 2008:

10% wgt Proposed:

90% wgt Definition: "A wax-based product for use solely on wood floors. Wax means an organic mixture or compound with low melting point and high molecular weight, which is solid at room temperature. Waxes are generally similar in composition to fats and oils except that they contain no glycerides. “Wax” includes, but is not limited to, substances such as carnauba wax, lanolin, and beeswax derived from the secretions of plants and animals; substances of a mineral origin such as ozocerite, montan, and paraffin; and synthetic substances such as chlorinated naphthalenes and ethylenic polymers." Survey Results: Number of products: 1 Products complying with proposed limit: 1 (100%) Canadian reported product quantity: 2,169 kg Canadian reported product quantity complying with proposed limit: 2,169 kg (100%) VOC content range: Insufficient data Technical Data/Manufacturer Information: Information from Other Jurisdictions: On June 6, 2006 the California Air Resource Board (CARB) proposed a new limit for Wood Floor Wax. The proposed limit, of 10% by weight VOC, will be consulted on over the course of the summer and go to board hearing on November 16, 2006. Summary: The proposed limit is consistent with the US EPA, CARB and OTC rules. The Environment Canada survey indicated that 100% of individual products sold accounting for 100% of sales meet the proposed limits.

revised September 15, 2006

78

Floor Wax Stripper: Non-Aerosol (To remove light or medium build-up polish) US EPA:

No limit OTC:

No limit CARB 2006:

3% wgt CARB 2008:

3% wgt Proposed:

3% wgt Definition: A product designed to remove light or medium build-up of natural or synthetic floor polishes or waxes through breakdown of the polish or wax polymers, or by dissolving or emulsifying the polish or wax. “Floor Wax Stripper” does not include aerosol floor wax strippers or products designed to remove floor wax solely through abrasion. Survey Results: Number of products: 18 Products complying with proposed limit: 14 (78%) Canadian reported product quantity: 428,065 kg Canadian reported product quantity complying with proposed limit: 375,411 kg (88%) VOC content range: 0.5-13.0% wgt Technical Data/Manufacturer Information: Information from Other Jurisdictions: Summary: The proposed limit is consistent with the CARB rule. The Environment Canada survey indicated that 78% of individual products sold accounting for 88% of sales meet the proposed limits.

revised September 15, 2006

79

Floor Wax Stripper: Non-Aerosol (To remove heavy build-up of polish) US EPA:

No limit OTC:

No limit CARB 2006:

12% wgt CARB 2008:

12% wgt Proposed:

12% wgt Definition: A product designed to remove heavy build-up of natural or synthetic floor polishes or waxes through breakdown of the polish or wax polymers, or by dissolving or emulsifying the polish or wax. “Floor Wax Stripper” does not include aerosol floor wax strippers or products designed to remove floor wax solely through abrasion. Survey Results: Number of products: 16 Products complying with proposed limit: 15 (94%) Canadian reported product quantity: 253,831 kg Canadian reported product quantity complying with proposed limit: 252,730 kg (100%) VOC content range: 0-21% wgt Technical Data/Manufacturer Information: Information from Other Jurisdictions: Summary: The proposed limit is consistent with the CARB rule. The Environment Canada survey indicated that 94% of individual products sold accounting for 100% of sales meet the proposed limits.

revised September 15, 2006

80

Footwear or Leather Care Products: Aerosol US EPA:

No limit OTC:

No limit CARB 2006:

75% wgt CARB 2008:

75% wgt Proposed:

75% wgt Definition: Any aerosol product designed or labelled to be applied to footwear or to other leather articles/components, to maintain, enhance, clean, protect, or modify the appearance, durability, fit, or flexibility of the footwear or leather article/component. Footwear includes both leather and non-leather foot apparel. "Footwear or Leather Care Product" does not include "Fabric Protectant," "General Purpose Adhesive," "Contact Adhesive," "Vinyl/Fabric/Leather/Polycarbonate Coating," "Rubber and Vinyl Protectant," "Fabric Refresher," products solely for deodorizing, or sealant products with adhesive properties used to create external protective layers greater than 2 millimetres thick. Survey Results: Number of products: 2 Products complying with proposed limit: 1 (50%) Canadian reported product quantity: 8,469 kg Canadian reported product quantity complying with proposed limit: 774 kg (9%) VOC content range: Insufficient data Technical Data/Manufacturer Information: Information from Other Jurisdictions: Summary: The proposed limit is consistent with the CARB rule. The Environment Canada survey indicated that 50% of individual products sold accounting for 9% of sales meet the proposed limits.

revised September 15, 2006

81

Footwear or Leather Care Products: Solid US EPA:

No limit OTC:

No limit CARB 2006:

55% wgt CARB 2008:

55% wgt Proposed:

55% wgt Definition: Any solid product designed or labelled to be applied to footwear or to other leather articles/components, to maintain, enhance, clean, protect, or modify the appearance, durability, fit, or flexibility of the footwear or leather article/component. Footwear includes both leather and non-leather foot apparel. "Footwear or Leather Care Product" does not include "Fabric Protectant," "General Purpose Adhesive," "Contact Adhesive," "Vinyl/Fabric/Leather/Polycarbonate Coating," "Rubber and Vinyl Protectant," "Fabric Refresher," products solely for deodorizing, or sealant products with adhesive properties used to create external protective layers greater than 2 millimetres thick. “Solid” means a substance or mixture of substances which, either whole or subdivided (such as the particles comprising a powder), is not capable of visually detectable flow. Survey Results: Number of products: 5 Products complying with proposed limit: 5 (100%) Canadian reported product quantity: 39,372 kg Canadian reported product quantity complying with proposed limit: 39,372 kg (100%) VOC content range: 1-5% wgt Technical Data/Manufacturer Information: Information from Other Jurisdictions: Summary: The proposed limit is consistent with the CARB rule. The Environment Canada survey indicated that 100% of individual products sold accounting for 100% of sales meet the proposed limits.

revised September 15, 2006

82

Footwear or Leather Care Products: All Other Forms US EPA:

No limit OTC:

No limit CARB 2006:

15% wgt CARB 2008:

15% wgt Proposed:

15% wgt Definition: Any product, which is neither an aerosol or solid, that is designed or labelled to be applied to footwear or to other leather articles/components, to maintain, enhance, clean, protect, or modify the appearance, durability, fit, or flexibility of the footwear or leather article/component. Footwear includes both leather and non-leather foot apparel. "Footwear or Leather Care Product" does not include "Fabric Protectant," "General Purpose Adhesive," "Contact Adhesive," "Vinyl/Fabric/Leather/Polycarbonate Coating," as defined in section 94521(a), "Rubber and Vinyl Protectant," "Fabric Refresher," products solely for deodorizing, or sealant products with adhesive properties used to create external protective layers greater than 2 millimetres thick. Survey Results: Number of products: 7 Products complying with proposed limit: 6 (86%) Canadian reported product quantity: 35,245 kg Canadian reported product quantity complying with proposed limit: 26,609 kg (75%) VOC content range: 5.9-34% wgt Technical Data/Manufacturer Information: Information from Other Jurisdictions: Summary: The proposed limit is consistent with the CARB rule. The Environment Canada survey indicated that 86% of individual products sold accounting for 75% of sales meet the proposed limits.

revised September 15, 2006

83

Furniture Maintenance Products: Aerosols US EPA:

25% wgt OTC:

17% wgt CARB 2006:

17% wgt CARB 2008:

17% wgt Proposed:

17% wgt Definition: An aerosol product designed for the purpose of polishing, protecting or enhancing finished wood surfaces other than floors. “Furniture Maintenance Product” does not include “Dusting Aids,” “Wood Cleaners,” products designed solely for the purpose of cleaning, and products designed to leave a permanent finish such as stains, sanding sealers and lacquers. Survey Results: Number of products: 8 Products complying with proposed limit: 6 (75%) Canadian reported product quantity: 745,808 kg Canadian reported product quantity complying with proposed limit: 716,650 kg (96%) VOC content range: 17-25% wgt Technical Data/Manufacturer Information: Information from Other Jurisdictions: Summary: The proposed limit is consistent with the CARB and OTC rules. The Environment Canada survey indicated that 75% of individual products sold accounting for 96% of sales meet the proposed limits.

revised September 15, 2006

84

Furniture Maintenance Products: All Other Forms Except Solid or Paste US EPA:

10% wgt OTC:

7% wgt CARB 2006:

7% wgt CARB 2008:

3% wgt Proposed:

7% wgt Definition: A non-aerosol product designed for the purpose of polishing, protecting, or enhancing finished wood surfaces other than floors. “Furniture maintenance product” does not include dusting aids, products designed solely for the purpose of cleaning, and products designed to leave a permanent finish such as stains, sanding sealers, and lacquers. Survey Results: Number of products: 7 Products complying with proposed limit: 6 (86%) Canadian reported product quantity: 156,115 kg Canadian reported product quantity complying with proposed limit: 155,179 kg (99%) VOC content range: 0-40.2% wgt Technical Data/Manufacturer Information: Information from Other Jurisdictions: On June 6, 2006 the California Air Resource Board (CARB) proposed a new limit for Non-aerosol Furniture Maintenance Products. The proposed limit, of 3% by weight VOC, will be consulted on over the course of the summer and go to board hearing on November 16, 2006. Summary: The proposed limit is consistent with the CARB and OTC rules. The Environment Canada survey indicated that 86% of individual products sold accounting for 99% of sales meet the proposed limits.

revised September 15, 2006

85

General Purpose Cleaners: Aerosols US EPA:

10% wgt OTC:

10% wgt CARB 2006:

10% wgt CARB 2008:

7% wgt Proposed:

10% wgt Definition: An aerosol product designed for general all-purpose cleaning, in contrast to cleaning products designed to clean specific substrates in certain situations. “General Purpose Cleaner” includes products designed for general floor cleaning, kitchen or countertop cleaning, and cleaners designed to be used on a variety of hard surfaces. Survey Results: Number of products: 25 Products complying with proposed limit: 14 (56%) Canadian reported product quantity: 163,157 kg Canadian reported product quantity complying with proposed limit: 112,396 kg (69%) VOC content range: 1-100% wgt Technical Data/Manufacturer Information: Information from Other Jurisdictions: On June 6, 2006 the California Air Resource Board (CARB) proposed a new limit for Aerosol General Purpose Cleaners. The proposed limit, of 7% by weight VOC, will be consulted on over the course of the summer and go to board hearing on November 16, 2006. Summary: The proposed limit is consistent with the US EPA, CARB and OTC rules. The Environment Canada survey indicated that 56% of individual products sold accounting for 69% of sales meet the proposed limits.

revised September 15, 2006

86

General Purpose Cleaners: Non-Aerosols US EPA:

10% wgt OTC:

4% wgt CARB 2006:

4% wgt CARB 2008:

4% wgt Proposed:

4% wgt Definition: A non-aerosol product designed for general all-purpose cleaning, in contrast to cleaning products designed to clean specific substrates in certain situations. “General Purpose Cleaner” includes products designed for general floor cleaning, kitchen or countertop cleaning, and cleaners designed to be used on a variety of hard surfaces. Survey Results: Number of products: 219 Products complying with proposed limit: 175 (80%) Canadian reported product quantity: 41,465,986 kg Canadian reported product quantity complying with proposed limit: 36,631,751 kg (88%) VOC content range: 0-100% wgt Technical Data/Manufacturer Information: Information from Other Jurisdictions: Summary: The proposed limit is consistent with the CARB and OTC rules. The Environment Canada survey indicated that 80% of individual products sold accounting for 88% of sales meet the proposed limits.

revised September 15, 2006

87

General Purpose Degreasers: Aerosols US EPA:

No limit OTC:

50% wgt CARB 2006:

50% wgt CARB 2008:

15% wgt Proposed:

50% wgt Definition: Any aerosol product labelled to remove or dissolve grease, grime, oil and other oil-based contaminants from a variety of substrates, including automotive or miscellaneous metallic parts. “General Purpose Degreaser” does not include “Engine Degreaser," “General Purpose Cleaner," “Adhesive Remover," “Electronic Cleaner,” “Electrical Cleaner,” “Energized Electrical Cleaner,” “Metal Polish/Cleanser," products used exclusively in “solvent cleaning tanks or related equipment,” or products that are (A) sold exclusively to establishments which manufacture or construct goods or commodities; and (B) labelled “not for retail sale." “Solvent cleaning tanks or related equipment” includes, but is not limited to, cold cleaners, vapour degreasers, conveyorized degreasers, film cleaning machines, or products designed to clean miscellaneous metallic parts by immersion in a container. Survey Results: Number of products: 16 Products complying with proposed limit: 5 (31%) Canadian reported product quantity: 107,775 kg Canadian reported product quantity complying with proposed limit: 33,441 kg (31%) VOC content range: 18-100% wgt Technical Data/Manufacturer Information: Information from Other Jurisdictions: On June 6, 2006 the California Air Resource Board (CARB) proposed a new limit for Aerosol General Purpose Degreasers. The proposed limit, of 15% by weight VOC, will be consulted on over the course of the summer and go to board hearing on November 16, 2006. Summary: The proposed limit is consistent with the CARB and OTC rules. The Environment Canada survey indicated that 31% of individual products sold accounting for 31% of sales meet the proposed limits.

revised September 15, 2006

88

General Purpose Degreaser: Non-Aerosols US EPA:

No limit OTC:

4% wgt CARB 2006:

4% wgt CARB 2008:

4% wgt Proposed:

4% wgt Definition: Any non-aerosol product labelled to remove or dissolve grease, grime, oil and other oil-based contaminants from a variety of substrates, including automotive or miscellaneous metallic parts. “General Purpose Degreaser” does not include “Engine Degreaser," “General Purpose Cleaner," “Adhesive Remover," “Electronic Cleaner,” “Electrical Cleaner,” “Energized Electrical Cleaner,” “Metal Polish/Cleanser," products used exclusively in “solvent cleaning tanks or related equipment,” or products that are (A) sold exclusively to establishments which manufacture or construct goods or commodities; and (B) labelled “not for retail sale." “Solvent cleaning tanks or related equipment” includes, but is not limited to, cold cleaners, vapour degreasers, conveyorized degreasers, film cleaning machines, or products designed to clean miscellaneous metallic parts by immersion in a container. Survey Results: Number of products: 84 Products complying with proposed limit: 52 (62%) Canadian reported product quantity: 3,242,021 kg Canadian reported product quantity complying with proposed limit: 2,004,355 kg (62%) VOC content range: 0-100% wgt Technical Data/Manufacturer Information: Information from Other Jurisdictions: Summary: The proposed limit is consistent with the CARB and OTC rules. The Environment Canada survey indicated that 62% of individual products sold accounting for 62% of sales meet the proposed limits.

revised September 15, 2006

89

Glass Cleaners: Aerosols US EPA:

12% wgt OTC:

12% wgt CARB 2006:

12% wgt CARB 2008:

7% wgt Proposed:

12% wgt Definition: An aerosol cleaning product designed primarily for cleaning surfaces made of glass. Glass cleaner does not include products designed solely for the purpose of cleaning optical materials used in eyeglasses, photographic equipment, scientific equipment and photocopying machines. Survey Results: Number of products: 28 Products complying with proposed limit: 16 (57%) Canadian reported product quantity: 699,847 kg Canadian reported product quantity complying with proposed limit: 153,284 kg (22%) VOC content range: 4-72% wgt Technical Data/Manufacturer Information: Information from Other Jurisdictions: On June 6, 2006 the California Air Resource Board (CARB) proposed a new limit for Aerosol Glass Cleaners. The proposed limit, of 7% by weight VOC, will be consulted on over the course of the summer and go to board hearing on November 16, 2006. Summary: The proposed limit is consistent with the US EPA, CARB and OTC rules. The Environment Canada survey indicated that 57% of individual products sold accounting for 22% of sales meet the proposed limits.

revised September 15, 2006

90

Glass Cleaners: Non-Aerosols US EPA:

8% wgt OTC:

4% wgt CARB 2006:

4% wgt CARB 2008:

4% wgt Proposed:

4% wgt Definition: A non-aerosol cleaning product designed primarily for cleaning surfaces made of glass. Glass cleaner does not include products designed solely for the purpose of cleaning optical materials used in eyeglasses, photographic equipment, scientific equipment and photocopying machines. Survey Results: Number of products: 49 Products complying with proposed limit: 34 (69%) Canadian reported product quantity: 8,296,582 kg Canadian reported product quantity complying with proposed limit: 7,709,708 kg (93%) VOC content range: 0.1-25% wgt Technical Data/Manufacturer Information: Information from Other Jurisdictions: Summary: The proposed limit is consistent with the CARB and OTC rules. The Environment Canada survey indicated that 69% of individual products sold accounting for 93% of sales meet the proposed limits.

revised September 15, 2006

91

Graffiti Remover: Aerosol US EPA:

No limit OTC:

No limit CARB 2006:

50% wgt CARB 2008:

50% wgt Proposed:

50% wgt Definition: An aerosol product labelled to remove spray paint, ink, marker, crayon, lipstick, nail polish, or shoe polish, from a variety of non-cloth or non-fabric substrates. "Graffiti Remover" does not include "Paint Remover or Stripper," "Nail Polish Remover," or "Spot Remover." Products labelled for dual use as both a paint stripper and graffiti remover are considered "Graffiti Removers." Survey Results: Number of products: 1 Products complying with proposed limit: 0 (0%) Canadian reported product quantity: 1,138 kg Canadian reported product quantity complying with proposed limit: 0 kg (0%) VOC content range: Insufficient data Technical Data/Manufacturer Information: Information from Other Jurisdictions: Summary: The proposed limit is consistent with the CARB rules. Responses to the Environment Canada survey indicated that there was no product marketed in Canada meeting the proposed limit. However, experience in California has shown these limits to be technologically feasible.

revised September 15, 2006

92

Graffiti Remover: Non-Aerosol US EPA:

No limit OTC:

No limit CARB 2006:

30% wgt CARB 2008:

30% wgt Proposed:

30% wgt Definition: A non-aerosol product labelled to remove spray paint, ink, marker, crayon, lipstick, nail polish, or shoe polish, from a variety of non-cloth or non-fabric substrates. "Graffiti Remover" does not include "Paint Remover or Stripper," "Nail Polish Remover," or "Spot Remover." Products labelled for dual use as both a paint stripper and graffiti remover are considered "Graffiti Removers." Survey Results: Number of products: 5 Products complying with proposed limit: 1 (20%) Canadian reported product quantity: 7,526 kg Canadian reported product quantity complying with proposed limit: 636 kg (8%) VOC content range: 30-42% wgt Technical Data/Manufacturer Information: Information from Other Jurisdictions: Summary: The proposed limit is consistent with the CARB rule. The Environment Canada survey indicated that 20% of individual products sold accounting for 8% of sales meet the proposed limits.

revised September 15, 2006

93

Heavy-Duty Hand Cleaner or Soap US EPA:

No limit OTC:

8% wgt CARB 2006:

8% wgt CARB 2008:

8% wgt Proposed:

8% wgt Definition: "A product designed to clean or remove difficult dirt and soils such as oil, grease, grime, tar, shellac, putty, printer’s ink, paint, graphite, cement, carbon, asphalt, or adhesives from the hand with or without the use of water. “Heavy-duty Hand Cleaner or Soap” does not include prescription drug products, “Antimicrobial Hand or Body Cleaner or Soap,” “Astringent/Toner,” “Facial Cleaner or Soap,” “General-use Hand or Body Cleaner or Soap,” “Medicated Astringent/Medicated Toner” or “Rubbing Alcohol.”" Survey Results: Number of products: 111 Products complying with proposed limit: 61 (55%) Canadian reported product quantity: 2,274,140 kg Canadian reported product quantity complying with proposed limit: 1,098,130 kg (48%) VOC content range: 0-47% wgt Technical Data/Manufacturer Information: Information from Other Jurisdictions: Summary: The proposed limit is consistent with the CARB and OTC rules. The Environment Canada survey indicated that 55% of individual products sold accounting for 48% of sales meet the proposed limits.

revised September 15, 2006

94

Laundry Prewash: Aerosol/Solid US EPA:

22% wgt OTC:

22% wgt CARB 2006:

22% wgt CARB 2008:

22% wgt Proposed:

22% wgt Definition: An aerosol or solid product that is designed for application to a fabric prior to laundering and that supplements and contributes to the effectiveness of laundry detergents and/or provides specialized performance. Survey Results: Number of products: 2 Products complying with proposed limit: 1 (50%) Canadian reported product quantity: 44,501 kg Canadian reported product quantity complying with proposed limit: 23,165 kg (52%) VOC content range: Insufficient data Technical Data/Manufacturer Information: Information from Other Jurisdictions: Summary: The proposed limit is consistent with the US EPA, CARB and OTC rules. The Environment Canada survey indicated that 50% of individual products sold accounting for 52% of sales meet the proposed limits.

revised September 15, 2006

95

Laundry Prewash: All Other Forms US EPA:

5% wgt OTC:

5% wgt CARB 2006:

5% wgt CARB 2008:

5% wgt Proposed:

5% wgt Definition: A product, which is neither an aerosol nor solid, that is designed for application to a fabric prior to laundering and that supplements and contributes to the effectiveness of laundry detergents and/or provides specialized performance. Survey Results: Number of products: 13 Products complying with proposed limit: 12 (92%) Canadian reported product quantity: 2,541,579 kg Canadian reported product quantity complying with proposed limit: 2,538,451 kg (100%) VOC content range: 4-16% wgt Technical Data/Manufacturer Information: Information from Other Jurisdictions: Summary: The proposed limit is consistent with the US EPA, CARB and OTC rules. The Environment Canada survey indicated that 92% of individual products sold accounting for 100% of sales meet the proposed limits.

revised September 15, 2006

96

Laundry Starch Product/Sizing/Fabric Finish US EPA:

5% wgt OTC:

5% wgt CARB 2006:

5% wgt CARB 2008:

4% wgt Proposed:

5% wgt Definition: A product that is designed for application to a fabric, either during or after laundering, to impart and prolong a crisp look and may also facilitate ironing of the fabric. “Laundry starch product” includes, but it not limited to, fabric finish, sizing, and starch. Survey Results: Number of products: 14 Products complying with proposed limit: 13 (93%) Canadian reported product quantity: 736,952 kg Canadian reported product quantity complying with proposed limit: 683,394 kg (93%) VOC content range: 5-6.1% wgt Technical Data/Manufacturer Information: Information from Other Jurisdictions: On June 6, 2006 the California Air Resource Board (CARB) proposed a new limit for Aerosol and Non-Aerosol Laundry Starch Products/Sizing/Fabric Finish. The proposed limit, of 4% by weight VOC, will be consulted on over the course of the summer and go to board hearing on November 16, 2006. Summary: The proposed limit is consistent with the US EPA, CARB and OTC rules. The Environment Canada survey indicated that 93% of individual products sold accounting for 93% of sales meet the proposed limits.

revised September 15, 2006

97

Metal Polishes/Cleaners US EPA:

No limit OTC:

30% wgt CARB 2006:

30% wgt CARB 2008:

30% wgt Proposed:

30% wgt Definition: Any product designed primarily to improve the appearance of finished metal, metallic, or metallized surfaces by physical or chemical action. To “improve the appearance” means to remove or reduce stains, impurities, or oxidation from surfaces or to make surfaces smooth and shiny. “Metal Polish/Cleanser” includes, but is not limited to, metal polishes and cleaners used on brass, silver, chrome, copper, stainless steel and other ornamental metals. “Metal Polish/Cleanser” does not include “Automotive Wax, Polish, Sealant or Glaze,", wheel cleaner, “Paint Remover or Stripper,", products designed and labelled exclusively for automotive and marine detailing, or products designed for use in degreasing tanks. Survey Results: Number of products: 26 Products complying with proposed limit: 21 (81%) Canadian reported product quantity: 159,721 kg Canadian reported product quantity complying with proposed limit: 138,486 kg (87%) VOC content range: 2-100% wgt Technical Data/Manufacturer Information: Information from Other Jurisdictions: Summary: The proposed limit is consistent with the CARB and OTC rules. The Environment Canada survey indicated that 81% of individual products sold accounting for 87% of sales meet the proposed limits.

revised September 15, 2006

98

Multi-Purpose Lubricant (Excluding solid or semi-solid products) US EPA:

No limit OTC:

50% wgt CARB 2006:

50% wgt CARB 2008:

45% wgt Proposed:

50% wgt Definition: Any nonsolid, nonsemi-solid lubricant designed for general purpose lubrication, or for use in a wide variety of applications. Survey Results: Number of products: 80 Products complying with proposed limit: 48 (60%) Canadian reported product quantity: 2,470,153 kg Canadian reported product quantity complying with proposed limit: 1,466,821 kg (59%) VOC content range: 1-97% wgt Technical Data/Manufacturer Information: Information from Other Jurisdictions: On June 6, 2006 the California Air Resource Board (CARB) proposed a new limit for Multi-purpose Lubricant (excluding solid or semi-solid products). The proposed limit, of 45% by weight VOC, will be consulted on over the course of the summer and go to board hearing on November 16, 2006. Summary: The proposed limit is consistent with the CARB and OTC rules. The Environment Canada survey indicated that 60% of individual products sold accounting for 69% of sales meet the proposed limits.

revised September 15, 2006

99

Oven Cleaners: Aerosols/Pump Spray US EPA:

8% wgt OTC:

8% wgt CARB 2006:

8% wgt CARB 2008:

5% wgt Proposed:

8% wgt Definition: Any aerosol or pump spray cleaning product designed to clean and to remove dried food deposits from oven interiors. Pump spray means a packaging system in which the product ingredients are expelled only while a pumping action is applied to a button, trigger, or other actuator. Pump spray product ingredients are not under pressure. Survey Results: Number of products: 5 Products complying with proposed limit: 4 (80%) Canadian reported product quantity: 193,409 kg Canadian reported product quantity complying with proposed limit: 190,619 kg (99%) VOC content range: 8% wgt Technical Data/Manufacturer Information: Information from Other Jurisdictions: On June 6, 2006 the California Air Resource Board (CARB) proposed a new limit for Aerosol Oven Cleaners. The proposed limit, of 5% by weight VOC, will be consulted on over the course of the summer and go to board hearing on November 16, 2006. Summary: The proposed limit is consistent with the US EPA, CARB and OTC rules. The Environment Canada survey indicated that 80% of individual products sold accounting for 99% of sales meet the proposed limits.

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100

Oven Cleaners: Liquids US EPA:

5% wgt OTC:

5% wgt CARB 2006:

5% wgt CARB 2008:

1% wgt Proposed:

5% wgt Definition: Any cleaning product, which is neither an aerosol or pump spray, that is designed to clean and to remove dried food deposits from oven interiors. Survey Results: Number of products: 13 Products complying with proposed limit: 12 (92% wgt) Canadian reported product quantity: 382,955 kg Canadian reported product quantity complying with proposed limit: 377,879 kg (99%) VOC content range: 5-8.3% wgt Technical Data/Manufacturer Information: Information from Other Jurisdictions: On June 6, 2006 the California Air Resource Board (CARB) proposed a new limit for Non-aerosol Oven Cleaners. The proposed limit, of 1% by weight VOC, will be consulted on over the course of the summer and go to board hearing on November 16, 2006. Summary: The proposed limit is consistent with the US EPA, CARB and OTC rules. The Environment Canada survey indicated that 92% of individual products sold accounting for 99% of sales meet the proposed limits.

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101

Paint Removers or Strippers US EPA:

No limit OTC:

50% wgt CARB 2006:

50% wgt CARB 2008:

50% wgt Proposed:

50% wgt Definition: Any product designed to strip or remove paints or other related coatings, by chemical action, from a substrate without markedly affecting the substrate. “Paint Remover or Stripper” does not include “Multi-purpose Solvents,” paint brush cleaners, products designed and labelled exclusively as “Graffiti Removers,” and hand cleaner products that claim to remove paints and other related coatings from skin. Survey Results: Number of products: 22 Products complying with proposed limit: 15 (68%) Canadian reported product quantity: 238,000 kg Canadian reported product quantity complying with proposed limit: 193,513 kg (81%) VOC content range: 10-100% wgt Technical Data/Manufacturer Information: Information from Other Jurisdictions: Summary: The proposed limit is consistent with the CARB and OTC rules. The Environment Canada survey indicated that 68% of individual products sold accounting for 81% of sales meet the proposed limits.

revised September 15, 2006

102

Penetrants US EPA:

No limit OTC:

50% wgt CARB 2006:

50% wgt CARB 2008:

45% wgt Proposed:

50% wgt Definition: A lubricant designed and labelled primarily to loosen metal parts that have bonded together due to rusting, oxidation, or other causes. “Penetrant” does not include “Multi-purpose Lubricants” that claim to have penetrating qualities, but are not labelled primarily to loosen bonded parts. Survey Results: Number of products: 36 Products complying with proposed limit: 23 (64%) Canadian reported product quantity: 274,972 kg Canadian reported product quantity complying with proposed limit: 180,647 kg (66%) VOC content range: 7-84% wgt Technical Data/Manufacturer Information: Information from Other Jurisdictions: On June 6, 2006 the California Air Resource Board (CARB) proposed a new limit for Penetrants (excluding solid and semisolid). The proposed limit, of 45% by weight VOC, will be consulted on over the course of the summer and go to board hearing on November 16, 2006. Summary: The proposed limit is consistent with the CARB and OTC rules. The Environment Canada survey indicated that 64% of individual products sold accounting for 66% of sales meet the proposed limits.

revised September 15, 2006

103

Rubber and Vinyl Protectant: Aerosols US EPA:

No limit OTC:

10% wgt CARB 2006:

10% wgt CARB 2008:

10% wgt Proposed:

10% wgt Definition: Any aerosol product designed to protect, preserve or renew vinyl, rubber, and plastic on vehicles, tires, luggage, furniture, and household products such as vinyl covers, clothing, and accessories. “Rubber and Vinyl Protectant” does not include products primarily designed to clean the wheel rim, such as aluminum or magnesium wheel cleaners, and tire cleaners that do not leave an appearance-enhancing or protective substance on the tire. Survey Results: Number of products: 10 Products complying with proposed limit: 3 (30%) Canadian reported product quantity: 72,292 kg Canadian reported product quantity complying with proposed limit: 25,628 kg (35%) VOC content range: 1-90% wgt Technical Data/Manufacturer Information: Information from Other Jurisdictions: Summary: The proposed limit is consistent with the CARB and OTC rules. The Environment Canada survey indicated that 30% of individual products sold accounting for 35% of sales meet the proposed limits.

revised September 15, 2006

104

Rubber and Vinyl Protectant: Non-Aerosols US EPA:

No limit OTC:

3% wgt CARB 2006:

3% wgt CARB 2008:

3% wgt Proposed:

3% wgt Definition: Any non-aerosol product designed to protect, preserve or renew vinyl, rubber, and plastic on vehicles, tires, luggage, furniture, and household products such as vinyl covers, clothing, and accessories. “Rubber and Vinyl Protectant” does not include products primarily designed to clean the wheel rim, such as aluminum or magnesium wheel cleaners, and tire cleaners that do not leave an appearance-enhancing or protective substance on the tire. Survey Results: Number of products: 35 Products complying with proposed limit: 16 (46%) Canadian reported product quantity: 932,260 kg Canadian reported product quantity complying with proposed limit: 369,057 kg (40%) VOC content range: 0-78.8% wgt Technical Data/Manufacturer Information: Information from Other Jurisdictions: Summary: The proposed limit is consistent with the CARB and OTC rules. The Environment Canada survey indicated that 46% of individual products sold accounting for 40% of sales meet the proposed limits.

revised September 15, 2006

105

Silicone-Based Multi-Purpose Lubricants (Excluding solid or semisolid products) US EPA:

No limit OTC:

60% wgt CARB 2006:

60% wgt CARB 2008:

60% wgt Proposed:

60% wgt Definition: "Any lubricant which is (A) designed and labelled to provide lubricity primarily through the use of silicone compounds including, but not limited to, polydimethylsiloxane, and (B) designed and labelled for general purpose lubrication, or for use in a wide variety of applications. “Silicone-based Multi-purpose Lubricant” does not include products designed and labelled exclusively to release manufactured products from molds." Survey Results: Number of products: 28 Products complying with proposed limit: 11 (39%) Canadian reported product quantity: 292,568 kg Canadian reported product quantity complying with proposed limit: 112,924 kg (39%) VOC content range: 4-98% wgt Technical Data/Manufacturer Information: Information from Other Jurisdictions: Summary: The proposed limit is consistent with the CARB and OTC rules. The Environment Canada survey indicated that 39% of individual products sold accounting for 39% of sales meet the proposed limits.

revised September 15, 2006

106

Spot Removers: Aerosols US EPA:

No limit OTC:

25% wgt CARB 2006:

25% wgt CARB 2008:

7% wgt Proposed:

25% wgt Definition: Any aerosol product labelled to clean localized areas, or remove localized spots or stains on cloth or fabric such as drapes, carpets, upholstery, and clothing, that does not require subsequent laundering to achieve stain removal. “Spot Remover” does not include “Dry Cleaning Fluid," “Laundry Prewash," or “Multi-purpose Solvent." Survey Results: Number of products: 9 Products complying with proposed limit: 5 (56%) Canadian reported product quantity: 366,841 kg Canadian reported product quantity complying with proposed limit: 199,325 kg (54%) VOC content range: 4-97% wgt Technical Data/Manufacturer Information: Information from Other Jurisdictions: On June 6, 2006 the California Air Resource Board (CARB) proposed a new limit for Aerosol Spot Removers. The proposed limit, of 7% by weight VOC, will be consulted on over the course of the summer and go to board hearing on November 16, 2006. Summary: The proposed limit is consistent with the CARB and OTC rules. The Environment Canada survey indicated that 56% of individual products sold accounting for 54% of sales meet the proposed limits.

revised September 15, 2006

107

Spot Removers: Non-Aerosols US EPA:

No limit OTC:

8% wgt CARB 2006:

8% wgt CARB 2008:

1% wgt Proposed:

8% wgt Definition: Any non-aerosol product labelled to clean localized areas, or remove localized spots or stains on cloth or fabric such as drapes, carpets, upholstery, and clothing, that does not require subsequent laundering to achieve stain removal. “Spot Remover” does not include “Dry Cleaning Fluid," “Laundry Prewash," or “Multi-purpose Solvent." Survey Results: Number of products: 19 Products complying with proposed limit: 15 (79%) Canadian reported product quantity: 38,270 kg Canadian reported product quantity complying with proposed limit: 32,616 kg (85%) VOC content range: 0-19% wgt Technical Data/Manufacturer Information: Information from Other Jurisdictions: On June 6, 2006 the California Air Resource Board (CARB) proposed a new limit for Non-aerosol Spot Removers. The proposed limit, of 1% by weight VOC, will be consulted on over the course of the summer and go to board hearing on November 16, 2006. Summary: The proposed limit is consistent with the CARB and OTC rules. The Environment Canada survey indicated that 79% of individual products sold accounting for 85% of sales meet the proposed limits.

revised September 15, 2006

108

Toilet/Urinal Care: Aerosol US EPA:

No limit OTC:

No limit CARB 2006:

10% wgt CARB 2008:

10% wgt Proposed:

10% wgt Definition: "Any aerosol product designed or labelled to clean and/or to deodorize toilet bowls, toilet tanks, or urinals. Toilet bowls, toilet tanks, or urinals includes, but is not limited to, toilets or urinals connected to permanent plumbing in buildings and other structures, portable toilets or urinals placed at temporary or remote locations, and toilet or urinals in vehicles such as buses, recreational motor homes, boats, ships, and aircraft. "Toilet/Urinal Care Product" does not include "Bathroom and Tile Cleaner" or "General Purpose Cleaner." Survey Results: Number of products: 5 Products complying with proposed limit: 3 (60%) Canadian reported product quantity: 42,376 kg Canadian reported product quantity complying with proposed limit: 26,194 kg (62%) VOC content range: 10-28% wgt Technical Data/Manufacturer Information: Information from Other Jurisdictions: Summary: The proposed limit is consistent with the CARB rule. The Environment Canada survey indicated that 60% of individual products sold accounting for 62% of sales meet the proposed limits.

revised September 15, 2006

109

Toilet/Urinal Care: Non-Aerosol US EPA:

No limit OTC:

No limit CARB 2006:

3% wgt CARB 2008:

3% wgt Proposed:

3% wgt Definition: "Any non-aerosol product designed or labelled to clean and/or to deodorize toilet bowls, toilet tanks, or urinals. Toilet bowls, toilet tanks, or urinals includes, but is not limited to, toilets or urinals connected to permanent plumbing in buildings and other structures, portable toilets or urinals placed at temporary or remote locations, and toilet or urinals in vehicles such as buses, recreational motor homes, boats, ships, and aircraft. "Toilet/Urinal Care Product" does not include "Bathroom and Tile Cleaner" or "General Purpose Cleaner." Survey Results: Number of products: 45 Products complying with proposed limit: 42 (93%) Canadian reported product quantity: 3,972,294 kg Canadian reported product quantity complying with proposed limit: 3,909,871 kg (98%) VOC content range: 0-10.8% wgt Technical Data/Manufacturer Information: Information from Other Jurisdictions: Summary: The proposed limit is consistent with the CARB rule. The Environment Canada survey indicated that 93% of individual products sold accounting for 98% of sales meet the proposed limits.

revised September 15, 2006

110

Wood Cleaner: Aerosol US EPA:

No limit OTC:

No limit CARB 2006:

17% wgt CARB 2008:

17% wgt Proposed:

17% wgt Definition: An aerosol product labelled to clean wooden materials including but not limited to decking, fences, flooring, logs, cabinetry, and furniture. “Wood Cleaner” does not include ”Dusting Aid,” General Purpose Cleaner,” “Furniture Maintenance Product,” “Floor Wax Stripper,” "Floor Polish or Wax," or products designed and labelled exclusively to preserve or coloured wood. Survey Results: Number of products: No data Products complying with proposed limit: No data Canadian reported product quantity: No data Canadian reported product quantity complying with proposed limit: No data VOC content range: No data Technical Data/Manufacturer Information: Information from Other Jurisdictions: Summary: The proposed limit is consistent with the CARB rule. Responses to the Environment Canada survey returned no data for this product category. However, experience in California has shown the proposed limit to be technologically feasible.

revised September 15, 2006

111

Wood Cleaner: Non-Aerosol US EPA:

No limit OTC:

No limit CARB 2006:

4% wgt CARB 2008:

4% wgt Proposed:

4% wgt Definition: A non-aerosol product labelled to clean wooden materials including but not limited to decking, fences, flooring, logs, cabinetry, and furniture. “Wood Cleaner” does not include ”Dusting Aid,” General Purpose Cleaner,” “Furniture Maintenance Product,” “Floor Wax Stripper,” "Floor Polish or Wax," or products designed and labelled exclusively to preserve or coloured wood. Survey Results: Number of products: 20 Products complying with proposed limit: 13 (65%) Canadian reported product quantity: 181,119 kg Canadian reported product quantity complying with proposed limit: 174,843 kg (97%) VOC content range: 0-100% wgt Technical Data/Manufacturer Information: Information from Other Jurisdictions: Summary: The proposed limit is consistent with the CARB rule. The Environment Canada survey indicated that 65% of individual products sold accounting for 97% of sales meet the proposed limits.

revised September 15, 2006

112

AUTOMOTIVE AFTERMARKET

Automotive Brake Cleaners US EPA:

No limit OTC:

45% wgt CARB 2006:

45% wgt CARB 2008:

10% wgt Proposed:

45% wgt Definition: A cleaning product designed to remove oil, grease, brake fluid, brake pad material or dirt from motor vehicle brake mechanisms. Survey Results: Number of products: 33 Products complying with proposed limit: 18 (55%) Canadian reported product quantity: 3,442,891 kg Canadian reported product quantity complying with proposed limit: 1,893,590 kg (55%) VOC content range: 29-100% wgt Technical Data/Manufacturer Information: Information from Other Jurisdictions: On June 6, 2006 the California Air Resource Board (CARB) proposed a new limit for Automotive Brake Cleaners. The proposed limit, of 10% by weight VOC, will be consulted on over the course of the summer and go to board hearing on November 16, 2006. Summary: The proposed limit is consistent with the CARB and OTC rules. The Environment Canada survey indicated that 55% of individual products sold accounting for 55% of sales meet the proposed limits.

revised September 15, 2006

113

Automotive Rubbing or Polishing Compounds US EPA:

No Limit OTC:

17% wgt CARB 2006:

17% wgt CARB 2008:

17% wgt Proposed:

17% wgt Definition: A product designed primarily to remove oxidation, old paint, scratches or “swirl marks,” and other defects from the painted surfaces of motor vehicles without leaving a protective barrier. Survey Results: Number of products: 11 Products complying with proposed limit: 6 (55%) Canadian reported product quantity: 87,985 kg Canadian reported product quantity complying with proposed limit: 48,392 kg (55%) VOC content range: 3-50% wgt Technical Data/Manufacturer Information: Information from Other Jurisdictions: Summary: The proposed limit is consistent with the CARB and OTC rules. The Environment Canada survey indicated that 55% of individual products sold accounting for 55% of sales meet the proposed limits.

revised September 15, 2006

114

Automotive Wax/Polish/Sealant/Glaze: Hard Paste Waxes US EPA:

No limit OTC:

45% wgt CARB 2006:

45% wgt CARB 2008:

45% wgt Proposed:

45% wgt Definition: An automotive wax or polish which is: (A) designed to protect and improve the appearance of automotive paint surfaces; and (B) a solid at room temperature; and (C) contains 0% water by formulation. Survey Results: Number of products: 8 Products complying with proposed limit: 2 (25%) Canadian reported product quantity: 48,025 kg Canadian reported product quantity complying with proposed limit: 12,006 kg (25%) VOC content range: 3-75% wgt Technical Data/Manufacturer Information: Information from Other Jurisdictions: Summary: The proposed limit is consistent with the CARB and OTC rules. The Environment Canada survey indicated that 25% of individual products sold accounting for 25% of sales meet the proposed limits.

revised September 15, 2006

115

Automotive Wax/Polish/Sealant/Glaze: Instant Detailers US EPA:

No limit OTC:

3% wgt CARB 2006:

3% wgt CARB 2008:

3% wgt Proposed:

3% wgt Definition: A product designed for use in a pump spray that is applied to the painted surface of automobiles and wiped off prior to the product being allowed to dry. Survey Results: Number of products: 5 Products complying with proposed limit: 4 (80%) Canadian reported product quantity: 6,241 kg Canadian reported product quantity complying with proposed limit: 4,993 kg (80%) VOC content range: 2-45% wgt Technical Data/Manufacturer Information: Information from Other Jurisdictions: Summary: The proposed limit is consistent with the CARB and OTC rules. The Environment Canada survey indicated that 80% of individual products sold accounting for 80% of sales meet the proposed limits.

revised September 15, 2006

116

Automotive Wax/Polish/Sealant/Glaze: All Other Forms US EPA:

No limit OTC:

15% wgt CARB 2006:

15% wgt CARB 2008:

15% wgt Proposed:

15% wgt Definition: A product designed to seal out moisture, increase gloss, or otherwise enhance a motor vehicle’s painted surfaces. “Automotive Wax, Polish, Sealant or Glaze” includes, but is not limited to, products designed for use in autobody repair shops and “drive through” car washes, as well as products designed for the general public. “Automotive Wax, Polish, Sealant or Glaze” does not include “Automotive Rubbing or Polishing Compounds,” automotive wash and wax products, surfactant-containing car wash products, and products designed for use on unpainted surfaces such as bare metal, chrome, glass, or plastic. All other forms means all consumer product forms for which no form-specific VOC standard is specified. Survey Results: Number of products: 19 Products complying with proposed limit: 14(74%) Canadian reported product quantity: 306,703 kg Canadian reported product quantity complying with proposed limit: 226,960 (74%) VOC content range: 2-41% wgt Technical Data/Manufacturer Information: Information from Other Jurisdictions: Summary: The proposed limit is consistent with the CARB and OTC rules. The Environment Canada survey indicated that 74% of individual products sold accounting for 74% of sales meet the proposed limits.

revised September 15, 2006

117

Carburetor or Fuel-Injection Air Intake Cleaners US EPA:

75% wgt OTC:

45% wgt CARB 2006:

45% wgt CARB 2008:

10% wgt Proposed:

45% wgt Definition: A product designed to remove fuel deposits, dirt and other contaminants from a carburetor, choke throttle body of fuel-injection system, or associated linkages. “Carburetor or fuel injection air intake cleaners” does not include products designed to be introduced directly into the fuel lines or fuel storage tank prior to introduction into the carburetor or fuel injectors. Survey Results: Number of products: 34 Products complying with proposed limit: 13 (38%) Canadian reported product quantity: 429,416 kg Canadian reported product quantity complying with proposed limit: 163,178 kg (38%) VOC content range: 22-100% wgt Technical Data/Manufacturer Information: Information from Other Jurisdictions: On June 6, 2006 the California Air Resource Board (CARB) proposed a new limit for Carburetor or Fuel-injection Air Intake Cleaners. The proposed limit, of 10% by weight VOC, will be consulted on over the course of the summer and go to board hearing on November 16, 2006. Summary: The proposed limit is consistent with the CARB and OTC rules. The Environment Canada survey indicated that 38% of individual products sold accounting for 38% of sales meet the proposed limits.

revised September 15, 2006

118

Engine Degreasers: Aerosols US EPA:

75% wgt OTC:

35% wgt CARB 2006:

35% wgt CARB 2008:

10% wgt Proposed:

35% wgt Definition: An aerosol cleaning product designed to remove grease, grime, oil, and other contaminants from the external surfaces of engines and other mechanical parts. “Engine degreaser”' does not include any solvent used in parts washing equipment, or any solvent use described in CCME (1995). Survey Results: Number of products: 16 Products complying with proposed limit: 7 (44%) Canadian reported product quantity: 333,261 kg Canadian reported product quantity complying with proposed limit: 146,635 kg (44%) VOC content range: 10-92% wgt Technical Data/Manufacturer Information: Information from Other Jurisdictions: On June 6, 2006 the California Air Resource Board (CARB) proposed a new limit for Aerosol Engine Degreasers. The proposed limit, of 10% by weight VOC, will be consulted on over the course of the summer and go to board hearing on November 16, 2006. Summary: The proposed limit is consistent with the CARB and OTC rules. The Environment Canada survey indicated that 44% of individual products sold accounting for 44% of sales meet the proposed limits.

revised September 15, 2006

119

Engine Degreasers: Non-Aerosols US EPA:

75% wgt OTC:

5% wgt CARB 2006:

5% wgt CARB 2008:

5% wgt Proposed:

5% wgt Definition: A non-aerosol cleaning product designed to remove grease, grime, oil, and other contaminants from the external surfaces of engines and other mechanical parts. “Engine degreaser”' does not include any solvent used in parts washing equipment, or any solvent use described in CCME (1995). Survey Results: Number of products: 7 Products complying with proposed limit: 0 (0%) Canadian reported product quantity: 143,608 kg Canadian reported product quantity complying with proposed limit: 0 kg (0%) VOC content range: 17-90% wgt Technical Data/Manufacturer Information: Information from Other Jurisdictions: Summary: The proposed limit is consistent with the CARB and OTC rules. Responses to the Environment Canada survey indicated that there was no product marketed in Canada meeting the proposed limit. However, experience in California has shown these limits to be technologically feasible.

revised September 15, 2006

120

Tire Sealant and Inflators US EPA:

No limit OTC:

20% wgt CARB 2006:

20% wgt CARB 2008:

10% wgt Proposed:

20% wgt Definition: Any pressurized product that is designed to temporarily inflate and seal a leaking tire. Survey Results: Number of products: 7 Products complying with proposed limit: 6 (86%) Canadian reported product quantity: 144,704 kg Canadian reported product quantity complying with proposed limit: 124,445 kg (86%) VOC content range: 10-21% wgt Technical Data/Manufacturer Information: Information from Other Jurisdictions: On June 6, 2006 the California Air Resource Board (CARB) proposed a new limit for Tire Sealant and Inflators. The proposed limit, of 10% by weight VOC, will be consulted on over the course of the summer and go to board hearing on November 16, 2006. Summary: The proposed limit is consistent with the CARB and OTC rules. The Environment Canada survey indicated that 86% of individual products sold accounting for 86% of sales meet the proposed limits.

revised September 15, 2006

121

Undercoatings: Aerosols US EPA:

No limit OTC:

40% wgt CARB 2006:

40% wgt CARB 2008:

40% wgt Proposed:

40% wgt Definition: Any aerosol product designed to impart a protective, non-paint layer to the undercarriage, trunk interior, and/or firewall of motor vehicles to prevent the formation of rust or to deaden sound. “Undercoating” includes, but is not limited to, rubberized, mastic, or asphalt products. Survey Results: Number of products: 74 Products complying with proposed limit: 20 (27%) Canadian reported product quantity: 821,275 kg Canadian reported product quantity complying with proposed limit: 221,744 kg (27%) VOC content range: 11-87% wgt Technical Data/Manufacturer Information: Information from Other Jurisdictions: Summary: The proposed limit is consistent with the CARB and OTC rules. The Environment Canada survey indicated that 27% of individual products sold accounting for 27% of sales meet the proposed limits.

revised September 15, 2006

122