Guidance document on Benzene in Gasoline Regulations: chapter 4

Questions on Section 2 of the Regulations

Section 2: Application -- Types and Uses of Gasoline

2.1 What types of gasolines are not required to meet any of the compositional requirements of the regulations?

The following types of gasoline are not required to meet any of the compositional requirements of the regulations (there are records that must be retained):

Aviation gasoline: Aviation gasoline is a high-octane fuel, specially formulated for use in small aircraft. It is not for use in ground vehicles.

Racing gasoline: Gasoline used in competition vehicles is often specially formulated for racing purposes. Racing gasoline has a anti-knock index (road octane) of at least 100. Generally it has very low levels of benzene. Since it is a special fuel used in small volumes and since this fuel generally has very low levels of benzene, it is exempted from the compositional requirements.

Scientific research: Gasoline used in scientific research may have unusual properties depending on the nature of the research. In order to allow continued research into the impacts that gasoline has on the health of Canadians, the state of the environment and the operation of vehicles, this type of gasoline has been exempt from the compositional requirements.

Exported gasoline: The regulations do not specify any compositional requirements for gasoline that is exported.

Gasoline in transit: Gasoline in transit is a subset of exported gasoline. It is any gasoline that passes through Canada from one location outside Canada to another location outside Canada. Some examples of such gasoline are gasoline transported by truck from Washington state through British Columbia to Alaska, or gasoline transported by ship from Europe to terminals in Nova Scotia for subsequent transportation by truck to Maine.

Gasoline-like blendstock: The exemption from the compositional requirements for gasoline-like blendstock is a "temporary" exemption. This type of gasoline is intended to be blended into compliance at a location downstream of the refinery or point of importation. It must meet the compositional requirements before it is sold to the final consumer, or it must be exported or made into aviation gasoline, racing gasoline or used in scientific research. Such a temporary exemption is necessary since a number of primary suppliers ship unfinished gasoline to blending terminals to be "finished". This unfinished gasoline may not meet the compositional requirements of the regulations, and therefore would be out of compliance with the regulations if the regulations did not provide for gasoline-like blendstock.

2.2 Why are U.S. reformulated gasoline and California Phase 2 gasoline exempted from meeting most of the compositional requirements of the regulations?

Both these reformulated gasolines have benzene levels that are equal or lower than those in the regulation. However, because of different (generally more stringent) requirements for emissions of total toxics, these gasoline may not (in theory) meet the requirements for the BEN. Further, given the averaging provisions of the U.S. and California programs for benzene, any one batch may be above or below the Canadian requirements. Therefore, an importer who has selected to be on a per-litre limit for benzene would not be able to import just any batch of these reformulated gasolines -- the importer would have to be selective.

Given the other compositional requirements for these gasolines, they are considered to be environmentally superior to average Canadian gasoline, even after the reduction in benzene. To avoid undue burden on importers, these reformulated gasoline are not required to meet the benzene limit of 1% by volume or the requirements for the BEN.

The compositional requirement for benzene downstream of the refinery, blending facility or import point (i.e., 1.5% by volume) does apply to these "reformulated" gasolines, since both U.S. and California reformulated gasolines must be below this limit anyway. By including this downstream requirement for the reformulated gasolines, the reformulated gasolines can be co-mingled with complying gasoline without complicating downstream enforcement of the limit for benzene.

2.3 What is "northern winter complying gasoline"?

Some primary suppliers make gasoline for use in the Arctic during winter. This gasoline has characteristics that are required for use in very cold climates. The gasoline must be made and transported to the Arctic during the summer. As the equations for the BEN are different for summer and winter, the regulations provide the primary supplier with the option of identifying a batch of such gasoline as "northern winter complying gasoline". This means that, for this batch, the winter equations for the BEN can be used and winter limits for the BEN apply.