Canadian Finishing & Coatings Manufacturing Magazine - May/June 2023 - 13

CPCA CORNER
BY PETER MIRTCHEV, PH.D.
DIRECTOR OF PUBLIC AFFAIRS, CPCA
CPCA Ramps Up Efforts to Engage with PMRA
Following Final Evaluation Decisions for
Biocides in the Paint Cluster
T
he final evaluation decisions for six active
ingredients in the so-called paint cluster took the
paint industry by surprise as there had been no
communication and engagement from PMRA with
industry prior to the publication. With two of the six active
ingredients being cancelled for all uses, and the other four
being further restricted in terms of label rates, these decisions
have the potential to severely harm the already strained
preservation of water-borne paints sold in Canada.
As a result, CPCA convened the second meeting of the
Coatings and Adhesives Working Group with multiple
industry representatives and senior PMRA officials to voice
concerns with these decisions and PMRA risk assessment
in general. CPCA emphasized that PMRA needs to engage
much more frequently and regularly with registrants of
paint preservatives who had limited bilateral discussion
with PMRA for over two years in the assessment. This led
to the PMRA making decisions and using toxicity endpoints
which are often not in line with the latest data from industry.
The importance of including socio-economic cost/benefit
analyses in the risk assessments was also raised as a
serious deficiency. PMRA deals with many other types of
preservatives, mainly for the agricultural sector, and thus has
a lack of understanding as to how their decisions affect the
efficacy of biocides used in water-borne paint and the paint
industry broadly. CPCA offered to organise webinars and
learning sessions with PMRA regulators to help them make
more informed decisions for the paint sector related to the
specific challenges of antimicrobial control for in-can and
film preservation, etc.
Another point of concern is the proposed product
stewardship plan which PMRA put forward without fully
consulting CPCA, registrants, or professional painters'
associations. This could have very serious impacts such as
more product labelling required and the associated costs for
compliance. Registrants pointed out that there is no physical
space remaining on paint cans to add long labelling statements
as proposed by PMRA, which would also need to be bilingual.
Even when on the can there are questions as to their actual
efficacy in reducing occupational exposure for professional
painters.
The option of a QR code to provide health and safety
information was raised as an alternative, as it is being
seriously considered by PMRA's US counterparts, the EPA.
QR codes are increasingly used by professionals as well as by
consumers and recent studies in the US and Canada reveal
that they are effective and flexible for updates and new risk
mitigation measures for primary or secondary users. This will
itself be a costly undertaking as industry will be responsible
for developing it and marketing it to the intended audiences.
PMRA indicated that they are open to the idea, but technical
and IT issues have prevented them from exploring it further.
Industry representatives from the US offered to collaborate
with PMRA to jointly develop a feasible approach for a QR
Code for product stewardship that is aligned between Canada
and the United States. This would be a better approach than
imposing a labelling statement that is unique to Canada, when
60 per cent of products sold in Canada are imported from the
United States.
As next steps, CPCA is stepping up its advocacy efforts on
several other active ingredients used in paint preservation
that are scheduled for assessment in the coming one to two
years. In the short term, this will include a workshop on the
benefits of paint preservation and the critical role of the
shrinking pool of preservatives available to industry. It will
provide an opportunity for industry to show how it views
value versus risks for coatings compared with other products,
while also providing a better understanding of how product
stewardship and can be better integrated for all concerned.
CPCA Letter to Health Canada Follows-Up
Advocacy Efforts on MEKO
In late 2022, Health Canada informed CPCA that it intends
to move forward with a new mandatory risk management
approach (i.e. regulation) limiting the use of MEKO
(2-butanone oxime), an important anti-skinning agent in
alkyd paints. The proposed new limit for MEKO is most
concerning because it is prohibitively lower than in other
jurisdictions globally including the EU and the United States.
Health Canada also provided very limited rationale to justify
such lower limits other than raising further dermal concerns
May/June 2023
13
Canadian Finishing & Coatings Manufacturing Magazine - May/June 2023

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