Canadian Finishing and Coatings Manufacturing: Nov/Dec 2022 - 30

PAINT AND COATINGS MANUFACTURING: CHEMICAL MANAGEMENT PLAN
simultaneously and often overlap, thus leading to significant
industry-government collaboration. That includes time-limited
data gathering, formal submissions, personal interactions
with member companies and officials, subject matter experts,
and all leading to the final risk management of substances by
government, if so determined. This is an exhaustive process that
ensures there are no negative impacts from the use of chemicals
in products. To suggest otherwise, without any data, would be
false and disrespectful of what federal officials and industry have
achieved over many years.
Third, once a risk management approach is decided for a
chemical that remains in commerce, it doesn't stop there. For
example, more than a dozen coatings substances of interest,
which have already been assessed, are still monitored when
used in other products, referred to as 'significant new uses'
of those substances (SNAc). Several other initiatives are
under consideration by the federal government related to risk
assessments for nanomaterials including titanium dioxide
and zinc oxide nanoforms. Officials are also looking at how to
effectively assess literally thousands of PFAS substances and
how to ensure more supply chain transparency for chemicals in
commerce, as they always have for many substances in the past.
While all aspects of the chemical assessment process are costly,
rigorous and time consuming, both industry and government are
committed to ensuring both human health and the environment
are protected.
Without the substantial data and insights provided by CPCA
members, government assessors would not be able to do their job
as well as they do. Additionally, product stewardship would not
be well served in terms of potential impacts on the environment
or human health, if any. It is clear that the risk-based approach
employed under Canada's Chemicals Management Plan is indeed
working. Anything to subvert what is arguably the 'best practice
approach' to chemicals management, one that has been adopted
by other countries, would do a disservice to what Canada has
achieved to date for the benefit of all concerned. More importantly,
it could compromise and delay similar achievements for a safe
environment for Canadians in the future.
The federal government is now seeking to reform the
Canadian Environmental Protection Act (CEPA 1999), which
industry supports in terms of the need for modernization
of the Act. However, CPCA and industry more widely, have
urged the government to consider the potential for unintended
consequences should those amendments go beyond the scope
of the current Bill. Government and many industry sectors have
committed to ensuring the safe use of chemicals in products.
This will continue as efforts are underway to ensure new
methodologies for improved chemical assessment are adopted
as they continue to evolve. It is important that the best available
science be always used in chemical assessment as it should be for
many other government policies and programs. If it is not data
driven, what is then driving change in chemical assessment?
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Canadian Finishing and Coatings Manufacturing: Nov/Dec 2022

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