This Toxic Substance Reduction Plan Summary has been prepared in accordance with Section 8(2) of the Toxic Reduction Act and it satisfies the requirements stipulated in Section 24 of Ontario Regulation 455/09. This summary accurately reflects the content of the plan for four substances subject to planning; PMDI, MDI, Nonylphenol, its Ethoxylates and N-Pentane.

Plan Summary Statement

This plan summary accurately reflects the content of the Toxic Substance Reduction Plan for four Substances; PMDI, MDI, Nonylphenol, Ethoxylates and N-Pentane, prepared on behalf of Atlas Roofing Corporation Toronto Facility.

The facility has prepared the Toxic Reduction Plan for the following prescribed Toxic Substances:

1. PMDI (Polymeric Diphenylmethane Diisocyanate) CAS # 9016-87-9
2. MDI (Methylenebis (Phenylisocyanate) CAS # 101-68-8
3. Nonylphenol, its Ethoxylates CAS # NA-20
4. N-Pentane (all isomers) CAS # NA-16

Statement of Intent

Of the four toxic substances used in the manufacturing process, three substances have been consumed. Only N-Pentane remains in the finished product and can be partially released to the environment.

Atlas Roofing Corporation is committed to protect the environment. Atlas is dedicated to reduce the usage of the aforementioned four substances in its process whenever technically and economically viable.

This dedication has led to the previous adaptation of the Montreal Protocol for Ozone protection with led to the total phase out of the use of CFC’s.

In fact, Atlas Roofing Corporation Toronto facility was the first manufacturing facility in Canada to substitute the CFC Ozone Depletion Substance (ODS) in its manufacturing process.

Atlas Polyiso products and the trade association representing the industry, PIMA, have received many environmental awards. These include the Sustainable Buildings Industry Council’s (SBIC) 2003 “Best Practice” Sustainability Award and the U.S. EPA’s Climate Protection Award for the association’s leadership in promoting energy efficiency and climate protection.

Also, in 1999 the U.S. EPA awarded Atlas the Stratospheric Ozone Protection Award for “leadership in CFC phase-out in PolyIso insulation and in recognition of exceptional contributions to global environmental protection.”

Toxic substance reduction will be an ongoing effort at the Atlas Roofing Toronto facility. We continue to monitor technological advancements to ensure that options which are both technically and economically viable are implemented.

Rational for Not Implementing Toxic Substance Reduction Options

As required by s.18 (4) of O.Reg. 454/09, the plan must contain an explanation of why a reduction option for toxic substance is not implemented.

Facility personnel have considered the toxic substance substitution option, no immediate toxic substance substitution option can be identified, and therefore, Atlas Roofing Toronto facility does not intend to substitute the usage of PMDI, MDI, Nonylphenol, its Ethoxylates and N-Pentane from its foam formulation. These substances are the major raw materials necessary for PolyIso foam board manufacturing, and presently, there are no alternative substances available to substitute, which would produce the same physical properties in the finished products.

Description of Toxic Substance Reduction Options to be Implemented

After evaluating all categories of toxic substance reduction and subsequent technical and economic feasibility analyses, the facility has identified two Equipment or process Modification options for consideration.

Both options of equipment modification are being evaluated in a sister facility. If the data gathered from that facility proves that either options would reduce the use of toxic substances. The Toronto facility, will consider the economic viability to implement these options.

Objectives of Toxic Substance Reduction Plan

Atlas Roofing Toronto facility has an Environmental Management Plan, and utilizes the OSHA Process Safety Management (PSM) program for safe handling and processing of flammable liquid (N-pentane) in its foam manufacturing operation. Both, programs and plans address procedures for spill handling, leak detection, and pollution prevention.

Also, the Atlas Roofing Toronto facility, is implementing the Lean Manufacturing Principals into its operation, and managing the level of raw material inventory to reduce leaks and spills from its facility.

The Atlas Roofing Toronto facility, intends to continue to insure that PMDI, MDI, Nonylphenol and N- Pentane are used in a responsible and efficient manner.

All employees at the Atlas Roofing Toronto facility will be involved in the reduction plan of toxic substance usage, and elimination of releases. Toxic substances will be our first priority for reduction. Our goal will be to reduce the usage and release of toxic substance where ever technically and economically feasible.

Description of why Toxic Substances are used.

PMDI, MDI, Nonylphenol, its Ethoxylates and N-Pentane are raw materials used by the facility for production of Polyisocyanurate foam insulation. They are either consumed or contained in the finished products, and their presence is required to maintain the required physical properties.

PMDI, MDI with suitable catalysts react with all active Hydrogen compounds and convert into Polyurethane / Polyisocyanurate polymer. These polymers constitute the cell struts of the finished foam.

N-Pentane with its low thermal conductance and boiling point is used as the blowing agent in the foam manufacturing process. It is contained in the closed cell structure of the finished product which produces boards with improved thermal conductance which means higher R values.

Planer License Number

As required by s.18(2) of O.Reg.455/09 (as amended by s.9(2) of O.Reg.214/11, the licensed toxic Substance Reduction Planner responsible for providing Planner Recommendation on the certification of this plan is as follows:

Toxic Substance Reduction Plan Certification by Highest Ranking Employee

Certification

As of December 20, 2013, I, Tikran Gharakhanian, certify that I have read the toxic substance reduction plan for the four toxic substances referred to below and I am familiar with its contents, and to my knowledge the plan is factually accurate and complies with the Toxic Reduction Act, 2009 and Ontario Regulation 455/09 (General) made under Act.

1. PMDI (Polymeric Diphenylmethane Diisocyanate) CAS # 9016-87-9
2. MDI (Methylenebis (Phenylisocyanate) CAS # 101-68-8
3. Nonylphenol, its Ethoxylates CAS # NA-20
4. N-Pentane (all isomers) CAS # NA-16

Tikran Gharakhanian, P.Eng,
Certified Toxic Substance Reduction Planner (TSRP0209)
Plant Manager