Canadian Finishing & Coatings Manufacturing Magazine May/June 2022 - 11

CPCA CORNER
before industry will get back to pre-Covid supply of critical raw
material inputs in 2023.
These disruptions have consumed a significant portion of
CPCA members' resources over the past two years. Product
formulators in all companies, both large and small, are dealing
with long delays for key raw materials, lab equipment, and
needed accessories, all of which negatively impact entire
production lines, inventory, and distribution. As a result,
CPCA has written to government officials to request that any
survey and reporting requirements, consultation periods, and
development/implementation timelines for risk management
instruments be carefully coordinated and extensions considered
when necessary to ensure adequate stakeholder feedback is
provided before final decisions are rendered. CPCA would like
to ensure that Government officials consider all our members'
feedback (including that of the many SMEs) in its ongoing
regulatory development process as it does greatly impact their
operations and products. Depending on the outcome of these
consultations, CPCA members may have to devote further
resources to new product formulations, including field testing
or re-labelling to ensure that certain consumer products can
remain on the market. Fewer products mean less choice, less
competition, and increased costs for consumers.
Government Launches National Consultations
on Supply Chain Transparency, Including
Mandatory Labelling
As part of the announcement in April 2021 on strengthening
the Canadian Environmental Protection Act, 1999, Government
signaled its intent to enhance chemical ingredient transparency
throughout the supply chain and to strengthen mandatory
labelling for cosmetics, cleaning products, and flame retardants
in upholstered furniture. These intentions were reiterated
as part of the February 2022 announcement for Bill S-5,
Strengthening Environmental Protection for a Healthier Canada
Act. Government maintains that Canadians are demanding
greater access to information about the substances to which
they are exposed. It is unclear how strong those demands are,
what chemicals are targeted, and the data supporting those
undocumented demands. Industry must back up its assertions
about product safety with strong, evidence-based decisions and
the same high standard should be applied to government and
stakeholders who argue there is widespread demands for supply
chain transparency.
Environment and Climate Change Canada and Health
Canada have now announced their plan to carry out a series
of workshops and interactive events in a policy lab format, in
which participants will be brought together to develop solutions.
The consultations are open to all Canadians, including those
from across different industry sectors and segments within the
supply chain. However, there is no substantive, verifiable data
as to what those 'solutions' are meant to address. Government
officials have stated that they have a difficult time getting all
the information they require, yet there are already several
federal Acts and regulations that allow them to legally
'demand' industry data as needed. Under Canada's Chemicals
Management Plan there are many in-person, bilateral or
multilateral consultations with government regularly to engage
industry, trade associations, civil society groups, etc. In all of
those meetings there is a robust exchange of evidence-based
information provided via mandatory data calls, countless
industry submissions, risk assessments and more.
This new supply chain transparency push seems to have
been initiated with an intent to add more labelling where
none is needed. This would certainly add more red tape with
rounds of extra consultations likely leading to the status quo.
The first order of business should have been to determine if
the substantive legislation and processes already in place are
enough to adequately protect the health of Canadians and the
environment, which has shown to be case over the last 20 years
of CEPA.
Ongoing Chemicals Assessment Under the CMP
The ongoing risk assessment of chemicals in commerce
continues under the federal Chemicals Management Plan
(CMP). CPCA monitors substances implicated in paint, coatings,
sealants, and adhesives and updates members on regulatory
actions via our digital platform, the Canada Coatings HUB and
regular bulletins to members.
The draft screening assessment (DSAR) was published in
March for 21 substances in the Alcohols Group under CMP3.
Three of the substances, namely methanol (CASRN 6756-1),
1-butanol (CASRN 71-36-3), and benzenemethanol
(CASRN 100-51-6) are proposed CEPA-Toxic for human
health effects (inhalation). Both methanol and 1-butanol are
CASE-implicated; methanol in paint and varnish removers and
1-butanol in lacquers. The RM Scope seeks to reduce inhalation
exposure from both substances. CPCA is currently gathering
feedback from members to inform our comments, which will
seek to underline that both of these substances are commonly
acceptable solvents and there is no evidence to suggest they pose
significant risk to consumers.
A related DSAR for 14 substances in the Esters Group was
also published in March and proposed methyl acetate (CASRN
79-20-9), a common industrial solvent, as CEPA-Toxic for
human health effects. The RM Scope seeks to reduce inhalation
exposure from aerosols and paint removers. Methyl acetate is
being targeted as it can be found in the body upon inhalation
of methanol. Methyl hexanoate, methyl butanoate, and
2-methoxypropyl acetate could face further action if their use
increases. As above, CPCA will reflect member views on the use
of these substances in Canada and draw attention to why these
substances may be unfairly targeted or if targeted what it will
mean for formulations going forward.
The final screening assessment report for the Triarylmethanes
Group was published in October 2021. It concluded that four
dyes, (Basic Violet 3, Malachite Green, Basic Violet 4, and
Basic Blue 7) meet the toxicity criteria under CEPA. A risk
management approach was published concurrently to outline
the proposed risk management actions which didn't specifically
target the paint and coatings sector. The Proposed Order adding
Basic Violet 3 (548-62-9), Malachite Green (569-64-2), Basic
Violet 4 (2390-59-2), and Basic Blue 7 (2390-60-5) to Schedule 1
of CEPA has now been published. Only Basic Blue 7 (2390-60-5)
is suspected of being used in paint in Canada but at low volumes
below the reporting thresholds and its use in a limited number of
products in Canada is not under threat.
May/June 2022
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Canadian Finishing & Coatings Manufacturing Magazine May/June 2022

Table of Contents for the Digital Edition of Canadian Finishing & Coatings Manufacturing Magazine May/June 2022
