Canadian Finishing & Coatings Manufacturing Magazine May/June 2022 - 31

PAINT AND COATINGS MANUFACTURING: IMPACTS OF AMENDMENTS TO CANADA'S ENVIRO ACT
Environmental
Protection and
Regulation
A
s part of the announcement in April 2021 on
strengthening the Canadian Environmental Protection
Act, the Government of Canada 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 specifically. Ostensibly, the goal is to provide Canadians
greater access to information about all substances in commerce.
Currently, a robust system is already in place in Canada to ensure
worker safety first and foremost and then of course consumer
safety. Underpinning this effort is the Globally Harmonized
System for the Classification and Labelling of Chemicals (GHS)
under which the requisite Safety Data Sheets (SDS) remain the
gold standard for all workplaces: manufacturing, transporting,
storage, and retail of hazardous chemicals. This ensures those
handling chemicals in commerce are fully aware of specific uses in
products and any valid concerns with those products. And, where
required by law, labelling is provided for consumers in compliance
with Health Canada's longstanding Consumer Chemicals and
Containers Regulations (CCCR). Furthermore, heavily regulated
sectors, such as paint and coatings, are fully compliant every
step of the way with all federal regulations in place for chemicals
in commerce. Presumably the federal government would not
have approved chemicals in commerce if they did not meet high
standards of assessment for which Canada is well known. This
also includes extensive provincial regulations for worker safety
and federal laws for the transportation of dangerous goods.
Now the federal government seems to be moving forward
towards a series of workshops and interactive events in which
participants will be brought together to " collaboratively develop
and test innovative solutions " . However, there is no substantive,
verifiable data as to what those 'solutions' are meant to address.
Consultations are consultations, whether they are held virtually,
in-person, via bilateral or multilateral consultations with
government, etc. In effect, this is already being done via current
and robust processes in place via the Chemicals Management
Plan with extensive engagement of industry groups, civil society
groups, one-on-one with industry, etc. It is not clear by who
and why this robust system of chemical assessment has been
questioned and what specific demands have been made to have
more information on the chemicals in commerce beyond the
comprehensive data already provided and used to make informed,
risk-management decisions related to both human health and the
environment.
It has been suggested that there is a growing need or demand
by consumers for more information on chemicals in products they
use. It is unclear how strong those demands are, what chemicals
are targeted and the data supporting those demands. Of course,
when asked every consumer will say they want safe products,
which is completely understandable. It has been stated that
Government has a difficult time getting all the information they
require, yet there is already federal legislation that allows them
to legally 'demand' industry data as needed, which industry must
provide by law under various legislation as noted.
Maybe the first order of business is to determine if the
processes in place collecting volumes of substantive data under a
long list of legislation and regulations is enough and then decide if
it's worth creating a whole new apparatus, using more consultants
and 'experts' to duplicate what is already in place and robust.
Many policy areas of government are obviously linked in one way
or another. Surely an array of federal government policies targeted
at specific areas of concern cannot be the reason for creating more
work and programs when those already in place suffice.
Gary Leroux
President & CEO, Canadian Paint and Coatings Association
www.canpaint.com
May/June 2022
31
http://www.canpaint.com
Canadian Finishing & Coatings Manufacturing Magazine May/June 2022

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