Yes. As I stated in our presentation, we would recommend that this be a regulation rather than amending CEPA. If the bill proceeds as is and amends the act, then it will conflict with existing federal regulations. That is a major concern for us.
CCSPA has announced an industry-led initiative that would limit the phosphorus content in household automatic dishwasher detergent to a maximum of 0.5%, so we would support the committee in amending the bill if that is the desire of the committee. As well, we have asked for an implementation date of July 2010. Again, that is in line with the U.S.
The problem with the date of 2009 is that our member companies are still developing new formulations. If it proceeds in 2009, there is no guarantee that our members will be able to have products available for 2009. Our member companies represent 86% of the market in Canada. If we don't have a product for sale for 2009, that means there'll be a huge shortage of the product and it would probably increase the cost of the alternatives.
As well, in our industry-led initiative we support an exemption for commercial and institutional facilities. In these facilities, such as hospitals, universities, schools, restaurants, and hotels, their machines are completely different from a household machine. Their wash and clean cycle is one minute, compared to 30 minutes in a household machine. It's a completely different machine, so you would need a complete exemption for that sort of facility. In the U.S., they have a maximum of 8.7% for those sorts of institutions.