Canadian Finishing & Coatings Manufacturing September/October Issue - 11

CPCA CORNER
levels of MEKO are necessary for product performance, the lack
of effective alternatives and already decreasing market demand
for alkyd products. Furthermore, the measure of success was
that the Code achieve two of the three required goals, which it did
and was thus met by industry following awareness campaigns
with videos and posters, etc.
A regulation will now likely be proposed based on new
concentration levels for the list of targeted products. The scope
of products has been expanded to include consumer adhesives
and sealants and not just alkyd paint. The proposed limits
for indoor or dual use spray and non-spray consumer alkyd
paint are very low, far below the typical 0.1 per cent w/w range
that is necessary for MEKO to be effective. In essence, the
limits constitute an effective ban on the substance. The new
regulation is also likely to include a provision for mandatory
labelling on exterior-use only paints to indicate they are not for
interior use. A de facto ban on MEKO could present issues for
industry because substitution of MEKO is often difficult or not
feasible. This could mean certain product lines may have to be
discontinued.
CPCA will consult members for quantitative data to inform its
comments to Health Canada. This includes looking into current
concentrations of MEKO in paint, stains, finishes, adhesives,
and sealants; whether these products are manufactured in
Canada or imported; whether the proposed limits are viable to
begin with; if possible cost-effective alternatives are readily
available to members; and what would be the necessary R&D
development timeline to achieve a similar level of performance.
CPCA Lobbies Ontario Minister of Environment
to Counter Rising Costs and Administrative Red
Tape at RPRA
The Resource Productivity and Recovery Authority (RPRA)
held a consultation on a proposed new supply data verification
approach under the Hazardous and Special Products (HSP)
Regulation in Ontario. The complex and unnecessary process
must be done by an onerous audit procedure, which RPRA
insists is necessary under the HSP Regulation. Over the past
number of years, CPCA and other industry associations have
been very concerned about the duplication of work by RPRA
under the RRCEA and its massively growing budget. In this
case, RPRA is proposing to duplicate the audit approach already
being performed by Product Care (PCA), the program operator
for paint recycling in Ontario. The approach being proposed by
RPRA has no tangible benefit for producers of waste in Ontario.
As a result, CPCA made its submission directly to the Minister
of the Environment (MECP) who is ultimately responsible for
the Act.
In the submission, CPCA reinforced previous concerns with
excessive regulatory costs and the likelihood of more such costs
if this new supply data approach is taken. CPCA questioned
how other decisions are taken with respect to accessibility
requirements for returning waste paint via established municipal
depots and municipal events. There has been no visible increase
in the volume of waste recycling over the last few years, yet the
costs for operating the program keep increasing, with paint now
paying 60 per cent of the total cost of the HSP materials. CPCA
will move forward with its advocacy efforts beginning with a
meeting with the MECP Minister and determine what other
actions need to be taken to address the growing red tape and
costs under Ontario's waste recycling approach.
Government Consulting on the Draft Risk
Assessment Framework for Nanomaterials
The Government of Canada is developing a draft framework for
the risk assessment of nanomaterials. The document has been
in development for several years, following a data gap analysis
that identified 53 substances with possible human health effects
on the nano-scale. At that size scale, certain materials can
behave differently than their standard bulk forms and present
September/October 2022
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Canadian Finishing & Coatings Manufacturing September/October Issue

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