BETHESDA, Md.—Environment Canada should consider models other than the California Air Resources Board in setting Canadian limits for volatile organic compound emissions, the Adhesive and Sealant Council told the agency.
"In using the CARB approach as a model, Environment Canada is choosing a regulation that is more stringent than either the U.S. Environmental Protection Agency or any of the other 49 states in the Union," wrote Mark Collatz, ASC director of regulatory affairs, in comments to Environment Canada.
One of Environment Canada's primary goals in proposing new VOC limits was to align Canadian standards with those of the U.S., but CARB's standards are the wrong choice for that purpose, according to Collatz. "Such an approach is difficult to describe as an effort in alignment," he said.
Environment Canada issued the Consultation Document on revised VOC limits Jan. 21, requesting comments from interested parties by March 7.
"Given that VOC emissions are precursors to ground-level ozone and smog, continued action on the reduction of VOC emissions is required in order to improve air quality in Canada," the document said.
The proposal covers some 130 product categories and sub-categories in areas such as VOC emissions averaging and trading, permitting, testing methods and labeling.
The EPA and the Ozone Transport Commission—an 11-state organization created under the Clean Air Act to develop regional solutions to ozone problems in the Northeast and Mid-Atlantic—are progressively moving toward adopting the CARB VOC standards, according to the Consultation Document.
"Aligning Canada's regulations with those of California will facilitate consistency across North America and avoid varying requirements across jurisdictions," the document said.
The ASC disagreed. In his comments on the document, Collatz noted that it proposes a limit of 3-percent VOC for chemically cured caulks and sealants, and 1.5 percent for non-chemically-cured ones. "These limits would be lower than every U.S. state jurisdiction but one," he said.
The OTC Model Rule for ozone containment, which goes into effect in January 2014, is a much better model for a revised Canadian VOC standard than the CARB rule, according to Collatz.
"Using a regulatory approach adopted by multiple states, several of which border Canada, seems a better way to address the challenge of regulatory alignment between our two countries," he said.