Summary Report - Information Session on the Key Elements of the Proposed Regulation for the Consumption of Trichloroethylene (TCE) or Tetrachloroethylene (PERC) in Vapour Degreasing

Prepared by: Cheminfo Services Inc.
1706 Avenue Rd., Suite 4, Toronto, Ontario, M5M 3Y6

Telephone: (416) 785-9051 / Fax: (416) 785-9876

AND

Sustainable Consumption Division
National Office of Pollution Prevention
Environment Canada

On July 5, 2001, Environment Canada conducted a one-day information session on the proposed "Regulation for the Consumption of Trichloroethylene (TCE) or Tetrachloroethylene (PERC) in Vapour Degreasing." In exploring the issues of content, design and implementation, the views and concerns from stakeholders were noted and are reported in this document.

The session was attended by a total of 90 people. More than two-thirds of the participants were TCE or PERC end users to whom the proposed regulation would apply directly. Other participants represented various stakeholder groups, including distributors, formulators, recyclers, equipment manufacturers, the Halogenated Solvent Industry Alliance ( HSIA): the association representing manufacturers of TCE and PERC, and an environmental non-government organisation. Environment Canada had several representatives in attendance from Hull, QC and its regional offices.

The presentations provided an overview of the context, both past and present, of solvent degreasing in Canada and the US. In Canada, the use of these CEPA toxics was profiled using 1995 projections; projections that will be updated to year 2000 with the receipt of information pursuant to the CEPA Notice which was published on August 4th, 2001 (Notice with Respect to Trichloroethylene and Tetrachloroethylene). Subject to an analysis of the information that will be received pursuant to the CEPA Notice requirements, vapour degreasers, will be required to comply with the proposed regulation and its legislated reduction schedule. In addition the CEPA Notice information will be used to determine the appropriate threshold consumption level from which vapour degreasers will be required to comply with the proposed regulation.

During the session, the participants were informed that Environment Canada expects the degreasers that are not subject to the regulation (vapour degreasers below a threshold level and non-vapour degreasers) to also reduce their consumption though process efficiencies or the adoption of alternatives.

Industry presented two reasons for their concerns regarding reductions: not being able to meet customer performance requirements, and, not being able to achieve the reduction with increasing productivity. They argued that there was a need for continued use of TCE or PERC for an essential use category. EC agreed that more work with industry was needed to define the domain of an essential use category. Industry's second concern was the ability to meet increasing demand due to expanding markets and the difficulty in maintaining competitiveness in a global reality. EC challenged industry to meet the reduction or replacement objectives through innovation; innovation that would be stimulated by information sharing between users, and technical experts in the field of retrofitting and alternative processes and technologies. EC committed to supporting industry's efforts though publication of relevant materials on the NOPP web site.

The proposed regulation is the product of a process which began in 1993 when TCE and PERC were both declared toxic under Section 11 of the Canadian Environmental Protection Act (CEPA, 1988)(1). Following this declaration, a multi-stakeholder, Strategic Options Process (SOP) was set up in 1994 to provide recommendations on options to reduce emissions and exposure to TCE and PERC used in solvent degreasing operations.

The Report of Stakeholder Consultations (the Strategic Options Report, SOR) was released in 1996 with recommendations for the Federal government to develop a regulation to set up a tradable, user quota system to control TCE and PERC used in solvent degreasing(2). The proposed regulation, which is intended to be promulgated in the middle of the year 2002, will apply only to vapour degreasing operations using more than some predetermined minimum threshold quantity of either substance. This threshold has not yet been determined but will be supported by data received from the CEPA Notice to be published August 4, 2001 with deadline for information September 14, 2001.

This information session was held to increase industry and public awareness of the key elements to be incorporated in the proposed regulation as well as the key issues that are related to its implementation. The session was attended by a total of 90 people. More than two-thirds of the participants were TCE or PERC end users to whom the proposed regulation would apply directly. Other participants represented various stakeholder groups, including distributors, formulators, recyclers, equipment manufacturers, the association representing manufacturers of TCE and PERC, and environmental non-government organisations. Environment Canada had several representatives in attendance from Hull, QC and its regional offices. The consulting firm Cheminfo Services Inc. of Toronto organised and facilitated the conference on behalf of Environment Canada. The following table summarises the attendance of this information session.

**Table 1: Information Session Participation**
Organisation Type	Participants
Users	65
Distributors	5
Formulators	4
Recyclers	2
Equipment Manufacturer	1
Env. Non-Gov't Organisation	1
TCE/PERC Manufacturer's Association	1
Federal Government	8
Consultants	3
Total:	90

This report has been structured to follow the agenda that was established by Environment Canada. A separate chapter is provided for each agenda topic. A brief introduction to each of the presentations that were made under the various agenda topics is provided. The major discussion points made during the open discussion period that followed the presentations are identified in a separate chapter. Appendices in the report contain: (i) the final agenda for the information session; and (ii) details of the session attendees.

Two formal presentations were given at the information session. The first presentation covered the history of the development process for this regulation. The second presentation gave an overview of the proposed elements of the regulation. Brief summaries of the presentations are given below.

Mr. Bill Palmer from Cheminfo Services gave a presentation covering the background to this regulatory development process. Cheminfo Services has supported various stages of this process and organised this information session on behalf of Environment Canada.

The presentation consisted of three broad themes: the Strategic Options Process for TCE and PERC in Solvent Degreasing; the profile of the sector; and the history of initiatives.

The Strategic Options Process for TCE and PERC in Solvent Degreasing was a multi-stakeholder review process that developed the recommendations for the current proposed regulation. The profile of the sector provided estimates of the number of companies using TCE or PERC for degreasing and the quantities of solvent involved based on detailed sales data collected in 1996. The history of initiatives traced the regulatory development from the initial toxicity assessment in 1993 to the proposed regulation and other current year initiatives.

Mr. Denis Landry of Environment Canada (Sustainable Consumption Division, Chemical Industries Section) gave an overview of the proposed regulation. He has been responsible for the organisation of this information session and the drafting of the proposed regulation.

The presentation began with an overview of the context, both past and present, of solvent degreasing in Canada and the US. Although Canada has not yet imposed requirement on the use of TCE and PERC in degreasing, the US has been subject to technical requirements pursuant to National Emissions Standards for Hazardous Air Pollutants (NESHAP)(3) since 1992. More information on NESHAP technical requirements and options can be found at (http://www.epa.gov/ttn/uatw/degrea/haloguid.pdf). In Canada, the user profile is based on 1995 projections. These projections will be refined with the receipt on information pursuant to the CEPA Notice that will be published on August 4th, 2001. Subject to these findings, EC's current position is that vapour degreasers will be subject to the proposed regulation and its legislated reduction schedule. It was emphasised to participants that this approach will not release other degreasers from taking action to reduce their consumption or find alternatives. Addressing the vapour degreasers will be the first phase of the management of TCE and PERC in Canada. Industry was urged to replace TCE and PERC due to its toxicity and find a substitute.

The presentation also included a description of the purpose and elements of the upcoming information request from a CEPA Notice to be published August 4, 2001, the reporting and record-keeping requirements, the proposed reporting schedules, and next steps in the process.

This section contains the issues that were raised by the participants. The main issues are grouped into subsections and the section is presented in question and answer format. Topics that were covered by the presentations are not included in this section.

Vapour degreasing will not be defined by a temperature cut-off. Vapour degreasing is a process where condensing vapours facilitate the removal of soils from the surface of the object. This process requires that a vapour degreaser unit heat the solvent to its boiling point.

Tetrachloroethylene has a higher boiling point (121°C) than TCE (87°C) and is used when more aggressive cleaning is required in order to remove tenacious contaminants such as heavy or waxy hydrocarbons from metal.

The proposed baseline allowance is calculated as the average of any three consecutive years falling into the period from 1994 to 2000, inclusive. The user is free to select any three consecutive years that produce the highest 3-year average. If the user does not have three consecutive years, they will be required to submit what years they do have and provide information as to when they began degreasing operations.

The regulation will apply to users having net consumption higher than a minimum annual quantity threshold of TCE or PERC. At present, the proposed regulation has no firm number for this threshold level, since a current profile of the sector has not yet been completed. Data obtained from the upcoming CEPA Reporting Notice (published in Canada Gazette on August 4, 2001) will be used to determine an appropriate threshold.

What about cold cleaning and other applications? There may be an increase in cold cleaning consumption due to the vapour degreasing regulations.

Cold cleaning is not covered by the proposed regulations. Environment Canada may move to encompass cold cleaning in the regulations in the future. Formulators of cleaning compounds and asphalt testing companies (who use TCE as a non-flammable extraction solvent) are also not included in the proposed regulations, but may be considered in the future. All sectors are encouraged to look for alternatives to these CEPA toxics.

When companies switched from 1,1,1-trichloroethane, some companies installed the best available technology before the baseline years, and will therefore have problems meeting the mandatory reductions. Will changes in solvent use that were implemented before the baseline years be accounted for?

No, the baseline years are calculated as described above. Companies are encouraged to submit their views and examples of pre-1994 actions to Environment Canada's National Office of Pollution Prevention.

The 65% reduction target was selected by the multi-stakeholder group in the Strategic Options Process as a reasonable level of control based on experience in the industry. This is comparable to the U.S. levels achieved by imposing the Maximum Attainable Control Technologies (MACT). The reader is encouraged to look at the Report of Stakeholder Consultations (Strategic Options Report) for answers to this and similar questions about the reasons for the specifics of the regulation.

Other alternatives to the proposed 3-year freeze were considered such as a phase-out schedule in the Strategic Options Process (SOP). The freeze for three years is preferable to one that supports a phase out scheme which would require an annual monitoring and penalizing process with a phase-out schedule. The freeze provides the flexibility for users to impose their own phase-out schedules.

At present, Environment Canada is not planning to take these allowances out of the pool. The businesses who are in possession of these allowances will not be forced to sell the allowances, and may trade or retire them as they desire.

What about new users - do they have an allowance? How are spin-off companies and sister companies treated?

New users (someone who was not in the business of degreasing before 2000) will have to purchase allowances from an authorised transferee.. It is expected that sister and spin-off companies will be able to inherit quotas from parent organisations.

Will companies be required to report the amount of recycled and waste TCE/PERC annually?

This allows the total quantity of TCE and PERC used in vapour degreasing to be regulated, while still providing some flexibility for critical uses and to provide some time for those who have not been able to yet find alternatives.

Has Environment Canada considered other methods to achieve reductions such as tax incentives?

Tax incentives were considered in the SOP. The proposed regulation was determined to be the most appropriate of the alternatives considered in the SOP. Taxes are a fiscal instrument, and are thus under the jurisdiction of the Ministry of Finance. From 1998 to 2000, Quebec imposed a levy on purchases of PERC used for dry cleaning to create a fund to assist companies to purchase of tighter and more-efficient equipment.

The exact mechanism and details for trading consumption allowances have not yet been finalised. The mechanism, however, will not be a marketing board; just caps and limitations. Consumption allowances will be transferred as a sale between companies and the marketplace will determine the price. Each transfer may require ministry approval.

No. Once an allowance for a particular year has been transferred and used by another company - it is no longer available for sale. Companies will be able to purchase available allowances each year to make up their needs.

Will there be a requirement to retire a percentage of the allowances with each trade like the Ontario emissions trading system?

Although this has not been ruled out, the possibility has not been included in the proposed regulation.

Yes, but only for facilities manufacturing, processing or otherwise using more than 10 tonnes of the solvent per year. The NPRI list for TCE and PERC captures emissions and transfers data from only the largest users and the quantity used specifically for vapour degreasing operations is not identified.

What about the extra reporting burden for companies reporting to the National Pollutant Release Inventory (NPRI), Ontario and now Environment Canada?

NPRI and Ontario are currently discussing the possibility of single reporting windows.

Will the upcoming CEPA notice ask about existing emission reduction controls on the degreaser?

No. The degree and extent of control options applied in the process is critical information for the users in determining next steps to achieve the 65% reduction objective but this information would not be necessary for Environment Canada.

Who has to report; the corporations or the individual facilities? How will mergers be handled?

The principle behind the regulation is to keep the reporting burden as simple as possible and allow a reasonable connection between historical use levels and future use levels regardless of the names of companies. It will be the responsibility of the corporations to report for all of their facilities. Merging companies will be able to combine their allowances and spun-off companies should be able to take allowances with them. The allocation of a company's allowance is considered to be an internal matter. While ministerial notification and approval is still necessary for any company changes, the transfers of allowances can be handled as an inter-company transaction at a token transfer price.

Aggregate and regional information summaries will likely be published following an analysis of the data, but facility and company level information will be kept confidential. There will be a provision for confidentiality on the notice, without which all information provided could be accessed by the public under the Access to Information Act.

Along with the publication of the proposed regulation in the Canada Gazette next year, a Regulatory Impact Analysis Statement (RIAS) will be published. The RIAS is the results of a cost / benefit analysis of the regulation, and is legally required by Parliament.

There is a reasonable level of confidence that the companies contacted in the Notice will cover the majority of the market. While some companies may not receive the original mail-out due to name or address changes, Environment Canada has the potential to use current supplier customer lists to identify and contact all users. Once the regulation is promulgated, however, it is ultimately a company's responsibility to apply for a baseline consumption allowance before the deadline for receiving allowances.

No. The purpose of the regulation is to control an absolute quantity of TCE and PERC used in vapour degreasing and move away from the use of CEPA toxics.

TCE / PERC use is not equitably treated internationally. What about the global competition implications of the regulations?

Global differences in regulations are a reality and the Government is required to ensure that competitiveness of Canadian companies are not adversely affected by any inequities in regulatory regimes. The U.S. is regulating consumption through its NESHAP rules and the European Union is also looking at regulating these solvents.

The result is that amongst the major trading partners, the costs of using these solvents should be about equal. In the case of Mexico, although there are no proposed controls for these solvents, the issue of consistency is being debated in North American Free Trade Agreement (NAFTA) discussions through the Council for Economic Co-operation in Montréal.

Does the U.S. have an allowance trading system that will increase their costs as well?

In the U.S., emission control limits are put on halogenated cleaning solvents from vapour degreasers under the NESHAP. The U.S. NESHAP does not have an allowance trading system, but allows several options to comply with limits. The overall Canadian reduction target of 65% versus baseline levels is about equal to that suggested by the MACT standards in the U.S. NESHAP.

What about military and aerospace applications which are required to use specific solvents?

These specifications should be changed to performance requirements rather than naming specific solvent requirements. There is discussion between Environment Canada and the Department of Defence, there is open dialogue on changing such requirements. The U.S. Military has worked to change their specifications in a similar fashion.

The responsibility for reduction is based on a reduction of each company's historical use of TCE or PERC. The purpose of the proposed regulation is to encourage changeover to alternatives and to concentrate TCE and PERC use in the most critical uses who are willing to pay for extra allowances. Any increase in cleaning load would have to be managed through the purchase of allowances.

Are suppliers obligated to ensure that customers are permissible end-users?

At present, there is no burden or imposition of accountability on the suppliers of TCE or PERC at this point. Suppliers are, however, required to report sales figures of TCE and PERC to Environment Canada.

There will soon be a users guide to the regulation (the Plain Language Guide). The National Office of Pollution Prevention (NOPP) has a website for information on toxic substances ( http://www2.ec.gc.ca/nopp/). This site will soon include the Canadian forum for information on TCE, PERC in vapour degreasing and contain technical solutions and alternatives.

What about information sharing? Is there a process for companies and governments to communicate methods and technologies with each other?

An information-sharing forum on the NOPP website will be considered. A technology exchange workshop may be added to the regulatory process.

A technical 'Alternatives Manual' listing the range of alternatives to vapour degreasing systems that use chlorinated solvents will be featured on the National Office of Pollution Prevention (NOPP) web site.

Many Canadian companies have successfully switched to alternatives to TCE and PERC A forum for the exchange of information has been suggested to Environment Canada and may be featured on the NOPP web site.

Mike Gerrard of W.J. Gerrard Mfg. Co. Ltd. gave a short talk on options to upgrade existing vapour degreasers in order to reduce solvent emissions. W.J. Gerrard is a Toronto-based company that supplies and services vapour degreasers. The following options were identified by Gerrard to have good potential to reduce emissions at existing vapour degreasing operations.

Table 2: Emission Reduction Options
for Vapour Degreasers
Option	Reductions	Comments
Refrigerated Cold Trap System	~40-50% based on 5' x 30'' machine w/ rolltop covers	Very effective when combined with rolltop covers & operator training
Operator Training	Large reductions possible from proper draining of parts with complex geometry	· Housekeeping · Correct basket placement · Slow hoist rates recommended
Modern Rolltop Covers	~40-50% based on 5' x 30'' machine w/ cold trap system	Can be designed to close at the center to minimize losses
Timers on Heating System	Cut back on convective losses	Decreases idling emissions especially if downtime significant, but can increase or decrease energy use
2 banks of heaters	Cut back on convective losses	Works well with Cold Trap systems
Extension on Height of vapour degreasing "Freeboard Extension"	Combine with operator training	Old systems may have small or no draining room
Automated (Programmable) Hoist Systems	Variable, depending on the application	Can work well in cases with easy drainage (non-complex parts)
Install VD in a Sealed Room	Good for older, low efficiency systems	All operation must be automated; difficult and costly to meet safety regulations
Internal Solvent Recycling (clean side/dirty side)	Very high, especially when combined a low vapour loss system	Installed in some newer machines

The return on investment for any of the above options depends heavily on the specific vapour degreaser design, operation pattern and amount of solvent saved. In some retrofits, reductions in solvent use of about 40% were cited. Cold trap systems range from $8,000 and up, installed.

Brominated solvents are usually considered as the only non-chlorinated solvent alternatives in vapour degreasers. Typically, hydrocarbon solvent alternatives tend to pose safety issues due to flammability and/or toxicity.

One of the more promising brominated alternatives is n-propyl bromide (NPB). It is marketed as a drop-in substitute (with some limitations) for TCE in degreasers and has similar solvent properties to 1,1,1-trichloroethane (TCA). However, NPB is currently an expensive option compared to TCE and PERC. Lexol was mentioned as the brand name of a NPB-solvent.

Two additional issues with NPB are that it has an ozone depleting potential, and that there is some concern over possible toxicity. The toxic exposure range of NPB is 50~800 ppm. Although it is not yet an air toxic, NPB may still be subject to VOC restrictions. NPB is the subject of an upcoming U.S. EPA Significant New Alternatives Program (SNAP) proposal, and will be subject to CEPA queries in Canada. This may result in future restrictions and so caution should be used in considering NPB as an final alternative.

Pyrene based solvents such as those using n-methyl pyrolidone (nMP) were also mentioned as being potential alternatives.

Typhoon washers, using heated, high-pressure water have been installed in some aerospace operations. Another option mentioned was a mechanical centrifuge and heating system. There is general agreement that these alternative systems are not nearly as good as TCE and PERC. Aqueous systems may leave residue in corners of parts with complex geometry, therefore affecting final cleanliness quality. They may also require changes to more water-soluble lubricating compounds (cutting oils, drawing oils, and buffing compounds). Production cycle times may also be adversely affected. Flash rust and pitting can be problems in some areas. E-coat companies and operations using simple geometries may find that aqueous systems are a viable option.

The practice of pollution prevention would suggest that the best way to avoid using chlorinated solvents would be to eliminate the soils that must be cleaned. Examples of this practice can be seen in the electronics industry, where switching to 'no-clean' solders has been very effective.

1 - Toxicity assessment reports are available at:
http://www.ec.gc.ca/cceb1/ese/eng/PSL1_trichloroethylene.htm &
http://www.ec.gc.ca/cceb1/ese/eng/PSL1_tetrachloroethylene.htm

2 - The Report of Stakeholder Consultations is available at: www.ec.gc.ca/degrease/degrease.htm

3 - U.S. EPA, National Emission Standards for Hazardous Air Pollutants (NESHAP) for Halogenated Solvent Cleaning (originally promulgated 1994).

Appendix A - Final Agenda for the Session

**Information Session Agenda**
Time	Information Session Component
08:30 - 09:00	Coffee, Tea and Juices
09:00 - 09:05	Welcome
09:05 - 09:10	Introductory Remarks
09:10 - 09:30	Orientation (Introduction of Participants)
09:30 - 10:00	Background on Regulatory Development Process
10:00 - 10:30	Overview of Proposed Regulation
10:30 - 10:45	Coffee Break
10:45 - 12:00	Overview of Proposed Regulation (continued)
12:00 - 13:00	Lunch Break
13:00 - 15:00	Open Discussion Forum - Questions & Answers
15:00 - 15:15	Coffee Break
15:15 - 16:00	Optional Exchange of Industry Technical Experience
16:00 - 16:15	Closing Remarks

**List of Attendees at July 5th 2001 Information Session**
(Speakers in Bold)
Company Name	Names Attending
2R Resources	Peter Weinnurm
Acro Aerospace Inc. (Div. of Canadian Helicopters)	Alan Fletcher
Air Canada	Michelle Lue-Reid
Air Canada	Myrka Manzo
Air Canada	Lalitchand Vora
Air Canada Regional Inc.	Rob Morphew
Almor Testing Services	Jim Montgomery
Aries Flexographics Ltd.	Marylou Cunningham
Armstrong Corporation	Stephen Kwong
ASEA Brown Boveri Inc. (Coiltech Division)	Mike Sparrow
Associated Tube Industry Ltd.	Mike Hawkins
Blue Circle Cement	Aimee Colvin
Brenntag Canada Inc.	Greg Brown
Brenntag Canada Inc.	David Bebbington
Bristol Aerospace	Dean Campbell
Canadian Finshing System Ltd.	Derek Vachon
Caloritech Inc.	Stacy Hawke
Cheminfo Services, Inc.	Brendan Hyland
Cheminfo Services, Inc.	Angelo Proestos
Cheminfo Services, Inc.	Bill Palmer
Comet Chemical	Jeff Stewart
Comet Chemical	Nick Morgan
Conam Quantum Inspection & Testing	Gary Isaac
CSL Silicones Inc.	Farooq Ahmed
CSL Silicones Inc.	John Barr
De Caro Manufacturing Ltd.	Frank De Caro
Derlan Aerospace Canada	Steve Little
Derlan Aerospace Canada	Eileen Eves
Derlan Aerospace Canada	Mike Daly
Environment Canada	Denis Landry
Environment Canada	Tim Leah
Environment Canada	Anita Li
Environment Canada	David LaVerdiere
Environment Canada	Alain David
Environment Canada	Grant Mcculloch
Environment Canada	Jean-Francois Banville
Exeltor Inc.	Benoit Wagner
Fielding Chemical Technologies Inc.	Russ Poppe
Geospec Engineering Ltd.	John Barks
Goodrich Landing Systems Services / Menasco Aviation Services	Wayne Green
Goodrich Landing Systems Services / Menasco Aviation Services	Tony Chan
Goodrich Landing Gear Division / Menasco Aerospace Limited	Geoff Lilley
Goodrich Landing Gear Division / Menasco Aerospace Limited	Tad Pawlisz
Halogenated Solvents Industry Alliance	Steve Risotto
Health Canada	Robert Sensenstein
Heroux Devtek Landing Gear Div. - Kitchener (Westheights)	Walter Tonizzo
Heroux Devtek Landing Gear Div. - Kitchener (Westheights)	M. Kaal
Heroux Devtek Landing Gear Div. - Kitchener (Westheights)	Wally Kampijan
IBM Canada (Bromont Site)	Yves Veilleux
Indalco Alloys Inc.	Les Thoms
Industrial Glove & Garment	Brian Bond
Industrial Systech Ltd.	Dean Di Marco
K.G. Packaging (Div. CCL Ind. Inc.)	Frank Chau
Kleen-flo Tumbler Industries Ltd.	Reginald Hui
Lafarge	Ian Wisdom
M. Stanton Electroplating Ltd.	Jim Stanton
McAsphalt Industries Ltd.	Tim White
Medallion / PFA Film and Video	John Walsh
Micro Wire Products (1980) Ltd.	Bill Schurer
Mississauga Metals & Alloys	Lee Bouchard
Mueller Canada	Rick Chevers
Mueller Canada	Semyon Fridlyand
Multi-Circuits (678699 Ontario Inc.)	Mario Lamanna
Orenda Aerospace Corp.	Karen Yoshiki-Gravelsins
Orenda Aerospace Corp.	Ian Leishman
P.R. Resources	Paul Robert
Peto MacCallum Ltd.	Gerald Pacitti
REA International Inc.	Bill King
River Sides Stewardship Alliance	Jason Thorne
Sandvik Steel Canada	Harry Dahme (Gowling, Lafleur & Henderson)
Sentinel Canada, Div. SLC LCLS	M. Samiullah
Snoc (1992) Inc.	Luc Mailhiot
Spar Aerospace Limited	Paul Westlake
Spartan Plastics Canada	Mark Fenton
Spartan Plastics Canada	Valerie Marchand
Specialty Gaskets Inc.	Steve Stefaniak
Spectube Inc.	John E. Nesbitt
Spectube Inc.	Jean Paré, President
Stegg Limited	Pat Mosco
Stegg Limited	Garry Stephanson
Tai Pan Lighting Co.	Rimmer Wang
Terraprobe Testing Ltd.	Keith Buth
Therm-O-Disc (Canada) Ltd.	Dave Brodie
Tremco Ltd.	Ken McCallum
U.S. Filter Niagara Screen Products	Sherry Trowhill
U.S. Filter Niagara Screen Products	John Kuijer
Vac Aero International	John Moate
Vac Aero International	Jose Fuentes
W.J. Gerrard Mfg. Co. Ltd.	Mike Gerrard
Zircatec Precision Industries Inc.	Dave Gilbert

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