Canadian Finishing & Coatings Manufacturing Magazine - May/June 2023 - 39

PAINT AND COATINGS MANUFACTURING: CRITICAL ISSUES
Regulatory Tipping Point for
Paint and Coatings
BY GARY LEROUX
PRESIDENT AND CEO, CANADIAN PAINT AND COATINGS ASSOCIATION
T
here are several critical issues being addressed by
CPCA for the paint, coatings, adhesives and sealants
(CASE) industry in Canada. These include:
* recent decisions regulating biocides used in the
preservation of sustainable water-based coatings;
* proposed regulations for much stricter VOC limits in
Architectural and Industrial Maintenance (AIM) coatings,
which represents 60 per cent of the volume of coatings
sold in Canada; and
* impacts from new regulations flowing from amendments
to
Bill
S-5
updating
Protection Act (CEPA).
The three new regulatory initiatives noted above will likely
change the composition and variety of products now on store
shelves if action is not taken now. It's still unclear if the Federal
Government will reconsider the potential for negative impacts
on industry versus the minimal benefits that may result.
This does not follow the 'regulatory efficiency' of previous
Governments in Canada where cost-benefit considerations
were highly valued when regulating products.
Challenges In Preserving Sustainable
Water-Based Paint
A cluster of biocide preservatives for paint, regulated by
the Pest Management Regulatory Agency (PMRA), was reevaluated
over the past two years and final decisions taken
to ban several and severely restrict effective use rates for
the others. These biocides are used for preserving paint and
coatings in the can, in storage, during distribution, at retail and
on the substrate to which they are applied. The data and risk
assessment methodology for those decisions is still unclear
and not based on all of the available data. For example, the
same available data, and likely more, was used by the US EPA to
assess these very same biocides. The result was no restrictions
imposed in the United States for those same biocides used in
paint. This does not support the regulatory alignment sought
by the Canada-US Regulatory Cooperation Council. When
asked about the discrepancy in Canada, industry is told it is a
" matter of policy " for Canada not to use the same toxicological
reference values as the US did for their starting point. One
might then conclude that such decisions are not just a matter
of science per se. This means the Canadian CASE industry will
not align with its largest trading partner from which 60 per
cent of all paint products sold in Canada are now imported.
These lower use rates for critical preservative ingredients
are essential in controlling microbial contamination in waterbased
coatings products especially. Furthermore, these
rates will also have negative impacts on treated articles in
other products imported into Canada. This reduces product
performance leading to more product spoilage from less
the
Canadian
Environmental
effective preservation and the potential for recalls. There are
very few alternative biocides in other countries and the ones
that do exist are not approved in Canada. This means there
will be reduced microbial control for the more sustainable and
recyclable water-based paint, thus reducing consumer choice
and contributing to inflationary pressures and lost sales.
Ultimately it means less trade between Canada and the United
States.
Challenges With New Lower Voc Regulations
The newly proposed VOC limits for the 49 architectural
coatings categories are also problematic. The consultation and
surveys leading up to the proposed lower VOC limits, adopting
the CARB limits in Canada, noted these new limits would
reduce VOC emissions by seven kilotonnes and would cost the
coatings industry $15 million in total. Thus, the cost-benefit
scenario seemed promising. However, we now know that such
an estimate was hugely under-stated. Recent calculations by
CPCA, on behalf of the coatings industry in Canada, revealed
that the expected benefit of a seven kilotonne reduction in
emissions was highly over-stated. One obvious example is the
need for more frequent re-painting required on surfaces due to
reduced product performance and degradation of the coating.
In fact, even if the seven kilotonne reduction is achieved it
could have collateral damage for industry. This would include
fewer product categories manufactured or imported in Canada
and/or abandoned by consumers due to the lack of product
performance. The obvious reason those targets are difficult
for some categories, especially for exterior coatings in a harsh
Canadian climate, is there is little room left for VOC emissions
reduction in both solvent-based and water-based coating
formulations and still have a functional product that works.
And, the industry has already delivered 93 per cent reduction
in VOC emissions in Canada.
A quick look at just several products in a small number
of categories-for just one company-with a proposed VOC
reduction limit of 100 - 250 g/L, down from 500 g/L, would
require a significant investment in R&D to reformulate, field
test product performance over several years, new production
protocols, recurring work related to new product development
and processes, etc. Those approximate costs for one company
are estimated at a minimum of $17 million. This is for several
products only, not the 49 product categories targeted. The
negative impact for just one company exceeds the government's
'estimated' total cost of $15 million for all categories.
Extrapolating one company's estimate puts the total amount
for these few products at $50-100 million or more. There are
still 49 categories to be considered in terms of cost versus
benefit; some can be more easily dealt with than others. Thus,
the estimated $15 million in total costs for the proposed new
VOC regulation in all categories is highly under-stated.
May/June 2023
39
Canadian Finishing & Coatings Manufacturing Magazine - May/June 2023

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