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ASC Questions Environment Canada’s Proposed Use of California Rule for VOC Reduction

Posted By ASC, Monday, March 25, 2013
Updated: Tuesday, May 12, 2015


Media Contact:

Mark Collatz

Director of Regulatory Affairs

(301) 986-9700 ext. 112

March 25, 2013 – Bethesda, MD – The Adhesive and Sealant Council (ASC) has submitted  comments to Environment Canada (EC) raising questions with a proposed approach that would set volatile organic compound (VOC) limits for a range of consumer products based on the California Air Resources Board’s (CARB) stringent rules.

In January EC published a Consultation Document that is expected to lead to a proposed rule in 2014 establishing VOC limits for consumer products, including several adhesive and sealant categories, throughout Canada.  A rule is expected to be finalized in 2016.

“The EC states in their Consultation Document that they are looking to align their VOC regulation with the United States,” said Mark Collatz, ASC’s Director of Regulatory Affairs.  “Yet they are basing their present assumptions on the regulations of single state rather than looking at how the other 49 states are addressing VOC limits for these types of products.”

ASC cited an example of sealants where the present California regulations mandate a limit of 3 percent for chemically cured products and 1.5 percent for those non-chemically cured while regulations throughout the rest of the U.S. are 4 percent for all sealant categories.

As an alternative, ASC suggested that EC consider adopting the Ozone Transport Commissions (OTC) Model Rule limits which were recently amended and will come into force in January 2014.  The OTC is an organization representing 11 northeast and mid-Atlantic states that have a responsibility for developing regional solutions to ground level ozone in their individual jurisdictions.

“Using a regulatory approach adopted  by multiple states, several of which border Canada, seems to be  a better way to address the challenge of regulatory alignment between our two countries,”  said Collatz.

Other areas that ASC addressed in their comments included a suggestion for more specific definitions for consumer products that differentiate between “household” and institutional” categories; the elimination of acoustical sealants from the proposal; and, changes in record keeping requirements. 

View a copy of ASC’s comments here (login first).

If you have any further questions regarding ASC’s comments, please contact Mark Collatz at 301/986-9700 ext. 112.


The Adhesive and Sealant Council (ASC) is a North American trade association dedicated to representing the adhesive and sealant industry. The Council is comprised of 122 adhesive and sealant manufacturers, raw material and equipment suppliers, distributors and industry consultants, representing more than 75% of the U.S. industry with operations around the world. Offering education, legislative advocacy, professional networking and business growth solutions for its members, the ASC is the center of knowledge and catalyst for industry growth on a global basis for manufacturers, suppliers and end-users. For more information about ASC, visit




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