IAC Automotive Components Alberta Ltd. IAC Maple 375 Basaltic Road, Concord, Ontario L4K 4W8

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1 IAC Automotive Components Alberta Ltd. IAC Maple 375 Basaltic Road, Concord, Ontario L4K 4W8 Toxic Substance Reduction Plan Summary Public Report covering Toxic Substance Reduction Plans for 4,4'-Diphenylmethane Diisocyanate (MDI) and Poly-Meric 4,4-Diphenylmethane Diisocyanate (p-mdi) C 2015 ENVIRONMENTAL REPORTING SYSTEMS LIMITED 26 Bristow Court, Barrie, Ontario, L4N 6T1 Tel. (705) Fax (705) webmail@erslimited.com

2 IAC Automotive Components Alberta Ltd. IAC Maple 375 Basaltic Road, Concord, Ontario L4K 4W8 Toxic Substance Reduction Plans 4,4'-Diphenylmethane Diisocyanate (MDI) Poly-Meric 4,4-Diphenylmethane Diisocyanate (p-mdi) Toxics Reduction Act & Ontario Regulation 455/09 For: Nunzio Martone Human Resources & Safety Manager IAC Automotive Components Alberta Ltd., IAC Maple August 31 st, Bristow Court, Barrie, Ontario, L4N 6T1 Tel. (705) Fax (705)

3 Description of Facility Toxic Substance Reduction Plan Summary 4,4'-Diphenylmethane Diisocyanate (MDI) and Poly-Meric 4,4-Diphenylmethane Diisocyanate (p-mdi) Toxics Reduction Act and Ontario Regulation 455/09 IAC Automotive Components Alberta Ltd., IAC Maple (IAC) produces various plastic products for automotive use. Items are produced for major automotive manufacturers and original equipment manufacturers. The main facility activities include receiving, manufacturing, assembly, shipping, and warehousing. The facility operates 24 hours per day, seven days per week and no incidents out of the normal course of events occurred at the facility during This report is specific to Phase 2 substances. It therefore uses 2012 calendar year data for the Phase 2 Substances 4,4'-Diphenylmethane Diisocyanate (MDI) and Poly-Meric 4,4- Diphenylmethane Diisocyanate (p-mdi). The Substances are present in the Foam-in-Place Process of the Production Stage, are TRA Phase 2 substances and National Pollutant Release Inventory (NPRI) Part 1 substances used in excess of 10 tonnes. IAC is committed to environmental sustainability and operates its facility to meet current environmental standards. More information is available at; Facility Name: IAC Automotive Components Alberta Ltd., IAC Maple (IAC) Location: 375 Basaltic Road, Concord, Ontario L4K 4W8 NPRI Identification Number: MOE Identification Number: 8627 Two Digit NAICS Code: 33 Four Digit NAICS Code: 3363 Six Digit NAICS Code: Other Motor Vehicles Parts Mfg. Number of Full-time Employees: ~ 302 UTM Spatial Coordinates: (NAD83-Zone17) mn: me (front door) Substance 1: 4,4'-Diphenylmethane Diisocyanate (MDI CAS# ) Substance 2: Poly-Meric 4,4-Diphenylmethane Diisocyanate (p-mdi CAS# ) Public Contact Name: Nunzio Martone, Human Resources and Safety Manager Address: 375 Basaltic Road, Concord, Ontario L4K 4W8 Phone Number: (905) Ext. 228 Fax: (905) nmartone@iacgroup.com Poly-Meric 4,4-Diphenylmethane Diisocyanate (p-mdi CAS# ) and 4,4'- Diphenylmethane Diisocyanate (MDI CAS# ) are both present from materials used in the Foam-In-Place process of the Production stage. These ingredients are purchased. They are also present in the Chemical Receiving Stage.

4 After the substances have been combined in the Foam-In-Place process they have reacted and are no longer in their original state, though for accounting purposes finished foam disposed off-site as well as contained-in-product is assumed to contain both MDI and p-mdi. The Foam-In-Place process uses three materials in the production of expanded foam automotive products. The MDI, p-mdi and a mold release which contains no MDI nor p-mdi. The MDI and p-mdi are liquids that mixed to create a chemical reaction within a mould to form the hardened foam product. 4,4'-Diphenylmethane Diisocyanate (MDI) is present at a maximum concentration of 45 % (w/w) and Polymeric Diphenylmethane Diisocyanate (p-mdi) is present at a maximum concentration of 55 % (w/w) when mixed. The total amount of material used with the maximum concentrations provided the amounts of substances used. 4,4'-Diphenylmethane Diisocyanate (MDI CAS# ) MDI Use and Release to Air from facility process (foam-in-place) qualified as NPRI Part 1 as threshold surpassed (>10 tonne at >1% conc.) Poly-Meric 4,4-Diphenylmethane Diisocyanate (p-mdi CAS# ) p-mdi Use and Release to Air from facility process (foam-in-place) qualified as NPRI Part 1 as threshold surpassed (>10 tonne at >1% conc.) Statement of Intent MDI and p-mdi are currently used by IAC in two processes. It is intended to reduce the use of these toxic substances at the facility. This facility does not create the substances, therefore this plan will not address the reduction of their creation. Objective of the Plan As options available for reduction are dependent on customer requirements which do not allow for the use of alternatives unless directed, no objective for substance reduction will be made under this plan for MDI or p-mdi. IAC has been informed that the production of the parts that require the substances will cease in 2015 and then only a few parts will be produced as needed for replacement parts supply. As a result of the customer change request, the use of both substances will be reduced approximately 99 percent. Target & Timeline IAC intends to reduce the use of MDI and p-mdi by 99 percent in 2015, though not as a target and timeline under this Plan.

5 Substance Use IAC produces plastic products and foam laminated parts for the automotive industry. Headliners with a moulded substrate are covered in foam. TRA prescribed toxic substances, MDI and p-mdi, are delivered by truck in containers to the facility receiving area. The substances are then transferred by forklift to a storage area. In the Foam-in-Place Process (see Figure 2: Foam-In-Place Process: MDI and p-mdi), MDI and p-mdi are reacted with a thinner product in a mould which is covered in a mould release compound and prepared with a moulded headliner substrate in-place. The reaction of MDI and p-mdi creates a non-reactive foam which no longer contains harmful quantities of either component in the finished product. MDI and p-mdi are not truly present in the remainder of the processes at the facility (Shipping Stage). There is no remaining MDI or p- MDI after the reaction. Component A mixes with Component B in the mould creating a chemical reaction that forms the expanded foam. The Blending process releases MDI to air through ducted venting (on-site emission). Damaged parts also produce off-site disposal of the non-reactive foam that was made up of the Substances. Non-reactive foam is also contained in product. There are no other creations (C), Destruction (D), Transformation (T), releases (L, W), disposal (DIS), offsite transfers (TR) of TRA substances or any substance truly contained in product (P). TRA Summary Table IAC Maple, Concord - TRA Substance Accounting Public Report Substance CAS # Use Used Contained Released Disposed in Product tonnes tonnes tonnes tonnes Poly-Meric 4,4-Diphenylmethane Diisocyanate (PMDI) Foam Seat none ,4'-Diphenylmethane Diisocyanate (MDI) forming The Plan objectives, targets and timelines have not been affected in the reporting year as there were no reduction options for implementation. There was no change in the method or combination of methods used to track and quantify the toxic substances during the previous calendar year. There were no incidents out of the normal course of events, nor were there any significant process changes at the facility during the previous calendar year. These Toxic Substance Reduction Plan Summaries accurately reflect the Plans they summarize.

6 Plan Confirmations for Toxic Substances Due to the lateness of the submission of these Plans with regards to the regulatory deadlines, certifications may not be stated, rather confirmations are required and provided here;

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