Canadian Finishing & Coatings Manufacturing - Sept/Oct '23 - 14

CPCA CORNER
CPCA Consults on the CMP Plan for
Risk Management
Last year, CPCA consulted with Government on the risk
management measures for the proposed regulations to
prohibit the manufacture, import, and sale of coal tar-based
sealant products in Canada, which is expected to be released
soon, and the proposed regulations, which are amending
the PCB Regulations. These specifically deal with measures
addressing how they will be handled from July to September
2023 and then determine how they will be addressed for the
following quarters into 2024.
CPCA Seeks Clarity on DSAR for Titanium
Compounds
TiO2 is still on the radar in Canada for possible regulation
despite the ongoing challenges to the regulation in Europe,
which the courts struck down in 2021 as a proposed
designation as a Category 2 carcinogen, while France then
moved to appeal the ruling. The publication of the DSAR
is now expected in March 2024. However, recent CPCA
discussions with federal officials on the course of action in
Canada revealed that there was no available information on
the possible titanium dioxide assessment in Canada. This
country is presumably watching the ongoing matter in the
EU and how it will be resolved. The federal Government
did indicate that there were no updates on the ecological
approach for the assessment of titanium substances, although
ecological information for certain titanium substances was
published in the ERC-I science approach document. Some
titanium compounds do indeed have an ERC-I ecological
ranking, and titanium tetrachloride remains a priority for
consideration and possible regulation in future.
Environmental Protection Act with a clearly established
deadline for companies operating or selling product in
Canada to file their reports. Some of these substances have
already been risk assessed over the past three CMP phases
and many are implicated for possible risk management in
the CASE sector in Canada. Presumably the approach taken
in the upcoming information gathering phase will focus on
increased concerns of exposure since the last assessment
was completed, or the need to help assess the performance of
existing risk management instruments in place.
Updated Consolidated CEPA (2023) Finalised
Bill S-5 amended CEPA and received Royal Assent on
June 13, 2023. This Act may still be cited as the Canadian
Environmental Protection Act, 1999. However, moving
forward it will be formally known as the Strengthening
Environmental Protection for a Healthier Canada Act. This
Act and any of its provisions will come into force on a day
or days to be fixed by Order of the Governor in Council and
a number of Bill S-5 amendments could have a significant
impact on chemical assessment in the years to come, including
the new clause on the Right to Healthy Environment (RTHE)
for every Canadian.
The federal Government did indicate that there were no updates on
the ecological approach for the assessment of titanium substances,
although ecological information for certain titanium substances was
published in the ERC-I science approach document.
Canada Issues List of 850 Substances
for Assessment
Manufacturers, importers and users of the 850 substances
identified for assessment in Phase 4 of the Chemical
Management Plan (CMP), should have already started
responding to notices related to these substances, which will
be assessed over the next five years. Mandatory reporting
on those
substances
14
is
required under the Canadian
www.cfcm.ca
New VOC Architectural Regulations to be
Published in Canada Gazette Part I in Spring
2024
In June 2023, CPCA met with federal Government officials to
address a number of concerns raised in CPCA's comprehensive
submission on the proposed limits in a number of the 49 AIM
categories. CPCA challenged some of the questions raised in
that meeting. Very shortly thereafter officials sent a followup
questionnaire laying out their technical questions for
companies manufacturing AIM products in Canada. The
hope is this will provide a more fulsome understanding of
industry's grave concerns with a number of the proposed
lower VOC limits for CASE products. All companies involved
in the manufacturing of AIM products in Canada, or shipping
those products to Canada, are urged to provide substantive
answers to the questions raised by Government officials.
This is the only way industry can be assured officials fully
understand the technical challenges in meeting some of
the proposed lower limits before finalisation and becoming
law. As they currently stand, the proposed limits in certain
categories will have a very negative and costly impact on the
industry. As with many new regulations over the past several
years, a 'whole of industry' approach is needed more than ever
before.
http://www.cfcm.ca
Canadian Finishing & Coatings Manufacturing - Sept/Oct '23

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