Executive Summary

Introduction

Zep Manufacturing Company of Canada (Zep Canada) is a leader in the supply of industrial and institutional maintenance and sanitation products. Zep Canada manufactures and imports products for a wide range of industries which include: Janitorial, Vehicle Wash, Automotive, Hospitality - Laundry/Warewash/General Housekeeping, Food Service - Food Processing; Institutional, and Aviation. Zep Canada has two facilities in Canada. The Edmonton facility of Zep Canada manufactures and imports products which include soap and cleaning products. This facility, along with the Canadian Corporate office, is located at 11627-178 Street in Edmonton, Alberta. Zep Canada's Montreal facility imports products which include soap and cleaning products, and is located at 660 Avenue Lepine, Dorval, Quebec. Zep Canada is a Division of Acuity Specialty Products, in Atlanta Georgia. Suppliers of imported product include Zep Manufacturing U.S. and other manufacturers of aerosols and speciality products. This P2 plan will provide information on both the Edmonton and Montreal facilities.

Requirement to Respond to Pollution Prevention Notice

Companies in Canada who manufacture or import soap and cleaning products which contain NP and NPEs may be required to prepare and implement a pollution prevention (P2) plan as set out by the P2 Planning Notice published by Environment Canada in Part I of the Canada Gazette on December 4, 2004 entitled: Notice Requiring the Preparation and Implementation of Pollution Prevention Plans in Respect of Nonylphenol and its Ethoxylates Contained in Products. The objective of the P2 Planning Notice is to significantly reduce or eliminate the quantity of NP and NPEs contained in soap and cleaning products, processing aids used in wet textile processing and pulp and paper processing aids.

In particular, the P2 Planning Notice applies to Zep Canada due to the following business activities:

• Zep Canada manufactures and imports soap and cleaning products; and,
• During the year 2003, the soap and cleaning products which were imported and manufactured by Zep Canada contained X_{PREP T}kg of NP and NPEs in the final product, which is more than the 2,000 kg threshold stipulated in the P2 Planning Notice. Therefore the P2 Planning Notice applies to the Zep Canada.

Zep Canada has already undertaken activities to remove a significant portion of NP and NPEs from the products manufactured at the Edmonton facility and from products imported into Canada. Zep Canada demonstrated a proactive approach to the elimination and reduction of NP and NPEs used in soap and cleaning products which was a business decision necessitated by the strict sewer use guidelines enacted by City of Toronto that went into effect at the end of June 2002. Zep Canada has exceeded the requirements of the P2 Planning Notice by reducing NP and NPEs from soap and cleaning products manufactured and imported by 96.7% in 2002 from their base year. The risk management objective of the P2 Planning Notice is to reduce NP and NPEs by 95% by 2010 compared to base year values.

Summary of Baseline Review

A baseline review was undertaken by Zep Canada's P2 Planning team to determine the mass of NP and NPEs used in the manufacture and import of soap and cleaning products. The base year was established as the year 2000 as the first available year after 1998 with complete purchasing data. The baseline review revealed the following as shown in Table 1:

The two products which continue to be manufactured with NP and NPEs are:

• Product _{EM 1}, (X_{PRODUCT EM 1} kg or 99% of remaining NP and NPEs); and
• Product _{EM 2} (X_{PRODUCT EM 2} kg or 1% of remaining NP and NPEs).

The products containing NP and NPEs which continue to be imported into both the Montreal and Edmonton facilities in 2003 are shown in Table 2:

The imported products which comprise the greatest quantity of NP and NPEs are: PRODUCT _{I 9}, PRODUCT _{I 11}, PRODUCT _{I 8}, PRODUCT _{I 4}. At the Montreal facility these products represent X_M1 kg (66.1%) of total NP and NPEs imported in 2003, and at the Edmonton facility these products represent X_E1 kg (56%) of the total NP and NPEs imported in 2003. The raw materials containing NP and NPEs are NP-9, NP-4, and NP-15, and these are common to both Montreal and Edmonton facilities.

There are currently 12 products which continue to be manufactured using Octylphenol (OP) and Octylphenol Ethoxylates (OPEs), although no product reformulations have been undertaken that would have used OP and OPEs as the replacement surfactant during the last three years. The use of OP and OPEs are addressed in the 'Factors to Consider' section 6.

A summary of Zep Canada's total quantities of NP and NPEs used on-site during the base year and the preparation year is provided in Table 3.

Identification of P2 Opportunities - Imports

P2 opportunities affecting imports of soap and cleaning products with NP and NPEs have been identified for the Zep Canada facilities at Montreal and Edmonton.

1. Material or feedstock substitution:
   1. Zep Canada will work with the primary current supplier of imported products, Zep USA, who has agreed to reformulate at least one product for sale into Canada.
   2. Zep Canada may block the import of NP and NPE containing products based on viability of sales line (i.e. low-sales).
   3. Zep Canada may block the importation of any new products that contains NP and NPEs.
2. Product design or re-formulation:
   Zep Canada will address each of the imported products on a case by case basis and is committed to manufacturing three products currently imported with NP and NPEs in Edmonton using Linear Alcohol Ethoxylates.

Identification of P2 Opportunities - Manufacturing

The P2 opportunities affecting soap and cleaning products manufactured with NP and NPEs have been identified for Zep Canada's Edmonton facility. The Montreal facility ceased manufacturing soap and cleaning products in 2001 and all manufacturing for Zep Canada was consolidated in Edmonton.

1. Product design or reformulation:
   Zep Canada will reformulate one of the two remaining products manufactured at the Edmonton facility with Linear Alcohol Ethoxylates.
2. Spill and leak prevention:
   Zep Canada will continue to practice spill and leak prevention as per ISO 9001 good operating practices.
3. On-site reuse, recycling or recovery:
   Zep Canada will explore the possible on-site re-use of the washwater used in manufacturing of products containing NP and NPEs as per ISO 14001 good operating practices.
4. Good operating practices or training:
   Zep Canada will continue to use good operating practices and training of staff as per ISO 9001 good operating practices.
5. Other: Formalizing Environmental Management System (EMS) to ISO 14001 standards:
   Zep Canada will formalize their informal EMS with certification as an ISO 14001 facility.

Meeting the Risk Management Objective

Zep Canada has already met the risk management objective set out in the P2 Planning Notice as shown in Table 4. However, Zep Canada is planning further reductions that would exceed the risk management objective. The risk management objective is as follows:

• Risk management objective Phase 1: To achieve at least a 50% reduction of NP and NPEs use in 2007 relative to the base year;
• Risk management objective Phase 2: To achieve at least a 95% reduction of NP and NPEs use in 2010 relative to the base year.

Addressing the 'Factors to Consider' as Outlined in the P2 Planning Notice

The P2 Planning Notice requires all facilities who are affected by the P2 Planning Notice to prepare a P2 plan and report on how each of the 'Factors to consider' were addressed in their P2 plan. These 'Factors to consider', and how Zep Canada proposes to address them, are as follows:

1. The Risk Management Objective for NP and NPEs Contained in Products.

   Zep Canada has already undertaken P2 activities to exceed the reduction targets and timelines outlined in the risk management objective for NP and NPEs in manufactured and imported soap and cleaning products. However, Zep Canada will implement further reductions for NP and NPEs in manufactured and imported products:

   Zep Canada will work with the suppliers of imported soap and cleaning products (Zep USA and others) to eliminate or reduce the NP and NPEs in imported products containing NP and NPES, or switch to comparable existing NP and NPEs free products.

   Zep Canada will reformulate three of the products currently imported which contain NP and NPEs and manufacture these products at the Zep Canada Edmonton facility with Linear Alcohol Ethoxylates.

2. NP and NPEs were declared toxic under section 64 of the Act and added to the List of Toxic Substances in Schedule 1 of the Act.

   Zep Canada will undertake activities within this P2 plan to demonstrate a reduction of NP and NPEs in imported soap and cleaning products

   Zep Canada has already undertaken activities to demonstrate a reduction of NP and NPEs used in the manufacturing of soap and cleaning products.

3. In preparing a plan, priority is to be given to pollution prevention activities, that is, the use of processes, practices, materials, products, substances or energy that avoid or minimize the creation of pollutants and waste and reduce the overall risk to the environment or human health (definition of "pollution prevention" as found in section 3 of the Act).

   Zep Canada has outlined a number of pollution prevention actions that will contribute to further reduction of NP and NPEs and ensure that the P2 plan will be implemented.

   Pollution prevention activities used to reduce NP and NPEs in manufactured soap and cleaning products include: product design or reformulation, spill and leak prevention, onsite reuse, recycling or recovery, good operating practices or training and implementation of an ISO 14001 system.

   The pollution prevention activities which will be used to reduce NP and NPEs found in imported soap and cleaning products are material or feedstock substitution and product design or re-formulation.

4. In order to achieve the risk management objective set out in subsection 4(1), persons subject to the P2 Planning Notice shall consider using the best available techniques economically achievable. These techniques include:
   1. for the manufacture of products containing NP or NPEs: product reformulation including substitution of NP and NPEs or reduction of NP and NPEs concentration in products to the maximum extent possible;
   2. for the import of products containing NP and NPEs: ensuring that imported products contain no NP and NPEs or contain only the minimum concentration of NP and NPEs necessary to achieve the desired result.

   Zep Canada has used product reformulation, that is, substitution of NP and NPEs in their product lines, to reduce the NP and NPEs content to the maximum extent possible, in soap and cleaning products manufactured in Edmonton. Only one product will continue to be manufactured in Edmonton which will contain NP and NPEs, after 2005.

   Zep USA, the primary supplier of imported soap and cleaning products to Zep Canada, will use product reformulation, that is, substitution of NP and NPEs in their product lines, to reduce the NP and NPEs content to the maximum extent possible.

   Zep Canada, as the importer of soap and cleaning products with NP and NPEs, will purchase those products where the NP and NPEs content has been eliminated or reduced.

5. Persons subject to the P2 Planning Notice shall consider including accurate concentrations of NP and NPEs in products (if any) on each product's label.

   Zep Canada has identified the products which would require modifications to the product labels and corresponding considerations that must be addressed. These considerations include:

   1. The product label for PRODUCT _{EI 1} mentions nonylphenol ethoxylate as part of a product ingredient, and a concentration range for that ingredient is provided on the label.
   2. The other remaining soap and cleaning product manufactured by Zep Canada is PRODUCT _{EI 2}, and the NPEs in PRODUCT _{EI 2} will be replaced by 2005.
   3. Zep Canada has provided a list of product names which still contain NP and NPEs (i.e. imported products) for all customers upon request.
   4. The information regarding NP and NPEs in remaining products, including imported products will be included on a new Canadian based Zep Canada website.
   5. The product content information is conveyed directly to Sales reps who are tasked with conveying this information directly to Zep Canada's customers.
   
   
6. Persons subject to the P2 Planning Notice shall consider choosing alternatives to NP and NPEs that reduce or minimize environmental risks. Considerations should include the following:
   1. the Priority Substance List Assessment Report for NP and NPEs indicates that Octylphenol (OP) and its Ethoxylates (OPEs) have similar toxicological properties and possibly greater estrogenic properties than NP and NPEs. Therefore, OP and OPEs are not appropriate alternatives to NP and NPEs since their use may amplify rather than reduce the risk to the environment;
   2. the chosen alternatives should not have, through their degradation, the potential to produce NP and NPEs.

   In the selection of substitutes for NP and NPEs used in soap and cleaning products manufactured onsite, Zep Canada had selected Linear Alcohol Ethoxylates, and will use this substance when replacing NP and NPEs in the product PRODUCT _{EM 2}.

   Zep Canada will work with Zep USA to ensure that the substitute surfactants used in the imported soap and cleaning products do not contain either OP and OPEs or products that would degrade into NP and NPEs.

   Zep Canada is in the process of evaluating OP and OPE use in products currently containing OP and OPEs.

7. The Minister will evaluate the effectiveness of this P2 Planning Notice with respect to the risk management objective set out in subsection 4(1) in order to determine if other steps or programs, including regulations, are needed to further prevent or reduce negative impacts of NP and NPEs on the environment.

   Zep Canada has taken action and is planning further action to reduce NP and NPEs in products which are manufactured and imported into Canada. These actions will contribute to the effectiveness of the P2 Planning Notice and to protection of the environment.

Addressing the Legal Implications as Outlined in the P2 Planning Notice

The following table outlines the legal obligations as outlined by the P2 Planning Notice and how they will affect Zep Canada.