Canadian Finishing and Coatings Manufacturing: Nov/Dec 2022 - 11

CPCA CORNER
BY PETER MIRTCHEV, PH.D.
DIRECTOR OF PUBLIC AFFAIRS, CANADIAN PAINT AND COATINGS ASSOCIATION
ECCC Launches Consultation on Proposed
Amendments to the VOC Architectural
Regulations
I
n October, Environment and Climate Change Canada
(ECCC) launched a pre-consultation document proposing
amendments to Architectural VOC Regulations in Canada
that could significantly affect CPCA's architectural paint
manufacturers.
Despite the fact the coatings industry has made significant
reductions in VOC emissions since the implementation of the
regulations with more than 42 kilotonnes of VOC reductions,
and despite significant improvements in air quality over the past
20 years, ECCC is proposing further actions to decrease VOC
content in numerous product categories.
CPCA is gathering architectural members' feedback to
inform ECCC's policy approach. The Canada-specific approach
largely adopts CARB VOC limits but also includes a few OTC II
VOC limits with no equivalent CARB VOC limits (i.e. calcimine
recoater, thermoplastic rubber coatings and mastics). These
limits are to be accompanied with the option to use VOC
permits. The proposed changes further decrease VOC limits for
certain categories, introduce several new product categories
and merge or delete others. They also revise certain category
definitions while maintaining the status quo for some products
despite existing lower limits in CARB and OTC (i.e. traffic
marking coatings). The small container exemption for volumes
under one litre is also being modified to reduce the number of
eligible categories.
Many of the new proposed limits are overly stringent and the
removal of several categories in the small container exemption
will have a large impact. These changes will surely lead to more
waste across many product lines. CPCA also reminded ECCC
that if later efforts are made to perhaps remove certain VOCexempt
compounds (i.e. TBAc) in order to achieve the current
VOC reductions according to CARB or the SCAQMD, it would be
difficult to sustain and could make it impossible to meet some
limits and deliver the expected VOC reductions.
The deadline to respond to the consultation is January 13,
2023, and CPCA is actively gathering member feedback to
inform our advocacy on this issue.
Government Intends to Introduce Mandatory
Labelling for Some Toxic Substances in
Consumer Products
In November, the federal Government published a Notice
of Intent proposing mandatory labelling requirements
for some substances listed on Schedule 1 of the Canadian
Environmental Protection Act. Primary consideration will be
given to substances of concern starting with flame retardants
and proceeding with cleaning products, and certain allergens
present in cosmetics. Government is targeting these products
in circumstances where providing information to consumers on
the presence of those substances is deemed necessary to reduce
risks to the environment or human health. It is not yet clear what
type of information will be required on a label; it may include
information on the presence of a substance, its concentration,
or its quantity.
Government is currently consulting interested parties on
how it can take action to enhance supply chain transparency
and mandatory labelling of substances in products via the socalled
Policy Lab which will conclude in Fall 2022. CPCA and
other industry association have participated to highlight the
importance of applying a scientific approach to define the scope
of any labelling requirements, taking existing labelling regimes
into account. Following completion of the current consultations
of the Policy Lab project, a strategy will be developed and
published in 2023. This will include regulatory measures and
voluntary, collaborative initiatives. Other federal authorities
on labelling such as those under the Canada Consumer Product
Safety Act will be followed, consistent with the " Best Placed Act "
approach of the Federal Government
Some CPCA members add chemical flame retardants to
certain manufactured materials, such as plastics,
foams,
rubbers, textiles, and surface finishes and coatings, for a
common purpose: to slow ignition and the spread of fire. Under
the Chemicals Management Plan (CMP), 34 flame retardants
(FRs) have been assessed so far; 14 of which were found to be
harmful, with 10 out of 14 additional FRs recently proposed
toxic. As FRs continue to be assessed and risk managed in
CMP, the proposed labelling actions would subsequently and
systematically be imposed on those FRs added to Schedule 1.
November/December 2022
11
Canadian Finishing and Coatings Manufacturing: Nov/Dec 2022

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