Discussion Paper Proposing Indeterminate Exemption for the Use of Leaded Gasoline in Competition Vehicles
December 2009
Canada's Gasoline Regulations have limited the concentration of lead in gasoline that is produced, imported and sold in Canada since 1990. The use of lead in gasoline has virtually disappeared. Today, 99.8 percent of gasoline used in Canada is lead-free.
The Gasoline Regulations do not apply to leaded gasoline used in aircraft, and, since 1994, the Regulations have exempted the use of leaded gasoline in competition vehicles [1]. The current exemption for competition vehicles expires on January 1, 2010.
Amendments are being proposed to the Gasoline Regulations to exempt leaded gasoline for use in competition vehicles indeterminately. This approach is aligned with that of the United States, which exempts leaded fuel for use in competition vehicles and is not currently planning to ban or restrict such use.
Leaded gasoline is not produced in Canada. Its primary use is in piston engine aircraft, while use in competition vehicles is minimal. Recent reporting shows that leaded fuel use in competition vehicles represents only three thousandths of a percent (0.003%) of total gasoline use in Canada. There has been a voluntary transition to unleaded racing fuels by certain North American racing bodies, and the industry is expected to continue to work towards lead-free replacement fuels where feasible.
The current reporting obligation for persons producing, selling or importing leaded gasoline for use or sale in Canada would be maintained to allow Environment Canada to monitor the use of leaded gasoline in competition vehicles.
Environment Canada, with the support of Health Canada, will conduct a five-year review and will revisit this decision based on science, technology and fuel replacement developments. Environment Canada will work collaboratively with the racing industry to encourage a voluntary reduction and phase-out of leaded racing fuel.
This discussion paper provides background information and seeks the views of parties on the proposed continued use of leaded gasoline in competition vehicles.
Lead has historically been added to gasoline to prevent engine damage due to the auto-ignition of gasoline (or "knocking"). Over the past decades, awareness of the human and environmental health impacts of lead has motivated actions to reduce the emission of lead from many sources, including gasoline.
The Gasoline Regulations, made under the Canadian Environmental Protection Act (CEPA) came into force on April 26, 1990. The Gasoline Regulations limit the concentration of lead in gasoline that is produced, imported or sold. There are exemptions allowing for the use of leaded gasoline in competition vehicles (until January 1, 2010) and in aircraft.
Prior to the enactment of the Regulations, vehicular lead emissions, resulting from the combustion of lead-containing anti-knock agents, were the largest source of lead particulates in the Canadian atmosphere. As a result of the Regulations, the use of lead in gasoline has virtually disappeared and gasoline is now 99.8 percent lead-free. The controls on lead in gasoline have significantly decreased airborne lead concentrations, which, in turn, are thought to have resulted in reduced uptake and blood lead levels of Canadians.
A copy of the current regulations can be downloaded from the Department of Justice website.
As a result of the Regulations, the use of lead in gasoline has virtually disappeared and there has been an overall movement away from its use. The Regulations have been amended to remove exemptions for applications where lead is no longer used, such as for farm machinery, boats and large trucks. As a result, 99.8 percent of gasoline is unleaded and the only remaining exemptions are for aircraft and competition vehicles (until January 1, 2010).
The Gasoline Regulations were originally amended in 1994 to allow the use of leaded gasoline in competition vehicles. The 1994 amendments were made in response to evidence of the adverse economic impacts of the Regulations on the activities of some racetracks and communities. In 1993, cancellation of a large racing event at a Quebec racetrack resulted in significant adverse economic impacts for the facility and local community. The 1994 amendments provided the industry with an exemption period to ease the transition to unleaded gasoline or other alternatives, taking into account claims by international race sanctioning bodies indicating that they would convert to unleaded gasoline within two to three years.
The competition vehicle exemption has been extended on four occasions since 1994, in 1997, 1998, 2003 and 2008. On all four occasions, there has been a consistent message from industry that the expiry of the exemption would have a significant, negative impact on the racing industry, related businesses and local communities. A transition to non-leaded fuels in the racing industry had not yet occurred, but progress has been made.
Since the expiration of the original exemption on December 31, 1996, amendments were made as follows to extend the exemption:
- March 1997, the exemption was extended until December 31, 1997;
- March 1998, the exemption was extended for five years;
- March 2003, the exemption was extended for another five years; and
- April 2008, the exemption was extended for two years. (The current exemption expires on January 1, 2010.)
Gasoline is the most common fuel used in racing. Both leaded and unleaded gasoline formulations are used in Canadian racing. For engines with high compression ratios, a very high octane gasoline is required to prevent engine knock (and resulting engine damage) and to maximize power output. Generally, leaded fuel is used in small amounts and only for certain classes of competition vehicles. It is most commonly used in the following types of competition vehicles: stock cars, dragsters, motorcycles and others (i.e. boats, personal water craft, snowmobiles and go-karts). It is estimated that 15 to 40 percent of leaded gasoline is used by stock cars, 40 to 50 percent by dragsters, 10 to 20 percent by motorcycles and 5 to 10 percent by other competition vehicles.
Lead additives are used to achieve this high octane. Leaded gasoline for use in competition vehicles that is imported for use in Canada has reported lead contents ranging from 0.1 to 4.23 g/L.
The Gasoline Regulations have annual reporting requirements for anyone producing, selling or importing leaded gasoline. Leaded gasoline is not produced in Canada, and its use in competition vehicles is minimal and is not increasing. Reporting [2] in 2006 shows 99.8 percent of gasoline, or 41 billion litres, were unleaded, and 0.2 percent, or 92 million litres, were leaded. Most of the leaded fuel was used in piston engine aircraft, while only 2 percent, or 1.3 million litres, were used in competition vehicles.
There are an estimated 165 racing facilities operating in Canada, hosting racing events featuring different types of competition vehicles, including stock cars, dragsters, motorcycles and other vehicles (boats, personal water craft, snowmobiles and go-karts). Many businesses benefit from the operations of these facilities, including racing-affiliated businesses such as fuel suppliers, engine repair and body shops, and local businesses such as restaurants, campgrounds and motels.
Leaded racing fuel use is dictated by the rules of the race association sponsoring the event and is required by the National Hot Rod Association (NHRA) and the International Hot Rod Association (IHRA). Many other large racing associations, such as Indy, Formula One and NASCAR, do not use leaded gasoline.
The racing industry in North America is currently integrated between Canada and the United States, with US competitors participating in Canadian races and vice versa. Canadian racetracks tend to be located near the US border and benefit from the participation of US drivers. For many facilities, the racing events that draw the largest audiences tend to be anchored around events sanctioned by US-based racing bodies such as the NHRA and IHRA (drag race sanctioning bodies). These events draw international competitors and spectators, and Canadian racetrack operators have indicated that these events generate a significant portion of facility revenues.
It is estimated that in 2001, racing events in Canada generated close to $200 million in direct revenues and around 900 full-time-equivalent jobs. In addition, the racing industry attracted approximately $600 million in direct expenditures by non-local people to areas with racing facilities and events, including more than $90 million from non-Canadian visitors. Total spending generated by the racing industry in Canada is estimated at $1.15 billion per year in 2001 [3].
Over the past decades awareness of the significant human health impacts of lead has motivated actions to reduce exposure to lead from many sources, including gasoline. As a result, over 99 percent of gasoline is unleaded.
Past health impact assessments were supported by risk assessments conducted in 1994 and 1997. The 1997 assessments concluded that lead levels in the vicinity of racetracks were acceptable when compared to the World Health Organization's recommended Provisional Tolerable Weekly Intake level for lead.
Since that time, scientific evidence has become available which demonstrates that adverse health effects may occur at lead exposure levels previously thought to be without harm, with children, toddlers and pregnant women being the most vulnerable. As a result, lead is recognized as a non-threshold toxicant by many agencies (US Environmental Protection Agency 2007, U.S. Center for Disease Control 2007 and Ontario Ministry of Environment 2008), indicating that a safe minimum level of exposure to lead has not been found.
Health Canada recognizes that the use of this fuel can increase people's exposure to lead. However, the department is focusing its efforts on reducing exposure to lead in ways that can make the most difference over the long term; for example, by making regulatory changes to lower concentrations of lead in consumer products.
For the segment of the racing industry that uses leaded fuel, the move towards alternative fuels and technology is considered a reasonable long-term solution.
Canada has an approach of generally aligning environmental fuel requirements with those of the United States, while taking into consideration environmental standards developed by the European Union and other jurisdictions [4].
The United States is not currently planning to ban or restrict the use of leaded fuels in racing events. The US Clean Air Act prohibits the use of leaded gasoline in on-road vehicles but specifically exempts fuels for "competition use vehicles." The US Environmental Protection Agency (EPA) has been working with the racing industry to effect change through voluntary means, and there has been voluntary transition to unleaded racing fuels by some US sanctioning bodies. The National Association for Stock Car Auto Racing (NASCAR) fully converted to unleaded from leaded gasoline at the beginning of the 2007 racing season. The US EPA, which worked with NASCAR on their conversion, has indicated that "any changes they (NASCAR) make are expected to have a significant effect throughout the industry" [5]. The Indy Racing League's Indy Pro Series also converted from leaded gasoline to non-leaded alternatives (unleaded gasoline and ethanol) over the 2006 and 2007 seasons. Canadian NASCAR races (formerly CASCAR) do not use leaded gasoline.
The United Kingdom's Motor Fuel Regulations 1999 allow up to 100 000 tonnes (about 139 million litres) of leaded gasoline to be distributed or sold, including for use by competition vehicles.
Australian federal regulations limit lead in gasoline but approve leaded fuel to be sold and used in competition vehicles. Such approvals are restricted to a limited number of government-approved motor and water sport organizations and their members.
Environment Canada is proposing to amend the Gasoline Regulations to exempt the use of leaded gasoline in competition vehicles indeterminately. This approach is aligned with that of the United States, which continues to exempt leaded fuel for use in competition vehicles and is not planning to ban or restrict such use.
Environment Canada will conduct a five-year review and will be prepared to revisit its decision based on science, technology and fuel replacement developments. Environment Canada will work collaboratively with the racing industry to encourage a voluntary reduction and phase-out of leaded racing fuel.
Environment Canada is seeking the views of parties regarding potentially providing an indeterminate exemption for the use of leaded gasoline in competition vehicles.
Parties are requested to provide their views in writing on the issues addressed in this discussion document to Environment Canada by December 30, 2009.
Written comments may be emailed to fuels-carburants@ec.gc.ca, or comments may be mailed to Environment Canada at the following address:
Leif Stephanson
Gasoline Regulations - Competition Vehicle Exemption
Oil, Gas and Alternative Energy Division
Environment Canada
351 St. Joseph Boulevard, 9th Floor
Gatineau QC K1A 0H3
[1] A competition vehicle is defined in the Regulations as "a vehicle or boat that is used exclusively for competition and does not include a vehicle that is used on a highway or a vehicle or boat that is used for recreational purposes."
[2] Information reported to Environment Canada pursuant to the Gasoline Regulations, SOR/90-247.
[3] Economic Impacts of Eliminating the Exemption for Lead in Racing Fuels, ARC Applied Research Consultants, July 2002.
[4] Federal Agenda on Cleaner Vehicles, Engines and Fuels, Canada Gazette, Part I, Vol. 135, No. 7, February 17, 2001.
[5] US EPA, Persistent, Bioaccumulative, and Toxic Pollutants (PBT) Program, PBT National Action Plan for Alkyl-lead, June 2002.
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