Canadian Finishing & Coatings Manufacturing Magazine - May/June 2023 - 14

CPCA CORNER
in addition to the initial inhalation concerns.
CPCA recently sent a letter to senior Health Canada
officials following up on discussions that took place in early
2023 on the upcoming risk management [RM] instrument.
The letter restated that the proposed new limits amount
to a practical ban of the substance, and that regulators have
not considered the lack of an available performing and costeffective
alternative. Moreover, upcoming VOC regulations
will further reduce the presence of alkyd products on the
market rendering risk management for MEKO redundant.
CPCA will continue to engage with regulators over the coming
months as the RM instrument is expected sometime before
the end of the year.
Regulations of Interest to the Coatings Industry
in the Coming Months
Government recently shared the Risk Assessment
Publications plan for the period of April to June 2023. The
updated DSARs on 2-pyrrolidinone, 1-methyl- (NMP) and
selected C3-5 alcohols will be of interest to CPCA members as
could the FSAR on coumarin 1. These substances are listed in
the CPCA Database as having uses in the coatings sector. The
draft " State of PFAS " report is also highly expected and CPCA
will keep members engaged once it is published as Canada
initiates its own review of PFAS which has already begun
most notably in the EU and to a lesser extent in the US.
Government also shared both a short- and long-term
publication plan for risk management (RM) instruments.
The short-term RM instrument publications plan include
the regulations on coal tar-based sealant products that CPCA
submitted comments on in 2022. The regulations will seek to
ban the manufacture or import of this class of products. The
long-term publications plan indicates that the Code of Practice
for Benzophenone (CASRN 119-61-9) has been pushed back
possibly to 2024. This was previously expected by the end of
2023. There are also SNAc provisions publications on TMTD
(CASRN 137-26-8) and 2-ethylhexyl-2-ethylhexanoate (CAS
RN 7425-14-1) that are listed on the long-term publications
plan, both of which could impact the coatings sector.
Industry Awaits the Publication of the State
of the Science Report on the Assessment and
Management of PFAS in June
The State of the Science Report on PFAS Exposure is planned
for June 2023. ECCC will also launch a mandatory Section
71 survey on 100-plus individual PFAS by Fall 2023. All
manufacturers/suppliers are legally required to respond
to the survey if they meet the threshold of conditions (use,
concentration, quantities, etc.) related to substances that
are manufactured or imported into Canada. This follows
Health Canada's publication of PFAS Drinking Water Quality
Guidelines, which established a concentration limit of 30 ng/L
for 18 specific PFAS. CPCA recently submitted comments
on this consultation, which does not impact the coatings
industry directly but could impact the industry in the future
as substances used in CASE products will be captured in the
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final definition of PFAS. CPCA and other associations intend
to form a special PFAS group to take action on the current
regulatory developments in Canada for PFAS, which will only
ramp up in the coming months following the publication of
the federal government's comprehensive State of the Science
Report outlining which substances could be targeted, when
and how companies will be legally required to respond.
Crude Tall Oil to be Added to Schedule 1 of CEPA
In July 2022, the federal government published the screening
assessment of the Resins and Rosins Group, which concluded
that Crude Tall Oil (CTO), meets the ecological criterion for
a toxic substance as set out in paragraph 64(a) of CEPA, and
thus constitutes a risk to the environment in Canada. CTO
has in the past been used in the coatings sector in products
available to consumers, such as adhesives and binding agents,
and at low levels in certain colourants.
The regulation did not specifically target the coatings
industry; rather it was focused on releases from pulp and
paper mills. Regardless, CPCA submitted comments that
highlighted the misalignment of this assessment with the
US and EU who also have substantial regulatory measures to
control releases from pulp and paper mills but do not target
CTO in particular. CTO is an unavoidable by-product of pulp
and paper manufacturing and its use in coatings may actually
keep it from being released in the environment. Canada is
the third largest producer of wood pulp (9.5 per cent of global
production) and the eighth largest producer of printing and
writing paper in the world (3.0 per cent of global production).
Restricting the use of CTO in manufacturing may actually
lead to its increased release.
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Canadian Finishing & Coatings Manufacturing Magazine - May/June 2023

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