Canada’s Widely Regarded Chemical Management Plan

The Canadian Paint and Coatings industry has been heavily involved with the federal Government for many years regarding ‘chemical assessment’ and the subsequent ‘risk management’ of chemicals in commerce. The same can be said for other industry sectors using chemicals in products. This widely regarded and rigorous world class approach to chemical assessment, the Chemicals Management Plan (CMP), along with literally thousands of other federal chemical regulations, ensures safe products for consumers and protects both human health and the environment. That is as a fact despite suggestions to the contrary in some circles, albeit without a full and complete knowledge of long established, strict protocols on how chemicals are assessed in Canada.

A quick look at what the coatings industry alone is dealing with on chemicals management reveals that there is no stone left unturned when it comes to ensuring chemicals used in Canada are safe. At the same time these chemicals deliver strong performance for many sustainable products used every day. This includes around the home for protection of valuable assets, road markings ensuring safety on our streets, anti-viral coatings ensuring clean surfaces in hospitals and schools, and the list goes on.

First, for the coatings industry alone there are now two pending draft chemical risk assessment reports completed after many months of data gathering and exhaustive science-based evaluation by federal officials, all with strong science backgrounds. For substances concluded as being CEPA-toxic, these assessments may lead to ‘risk management’ measures such as outright bans, regulations, pollution prevention plans, codes of practice, etc. For the coatings industry there are 23 chemical risk assessment and chemical risk management instruments already published covering more than a dozen substances designated as ‘toxic’ under CEPA.

Second, for CMP-3, there are 24 draft and final screening assessment reports being prepared for groups of substances in the costings industry such as ketones, flame retardants, esters, alcohols, and furans. These important reports move forward simultaneously and often overlap, thus leading to significant industry-government collaboration. That includes time-limited data gathering, formal submissions, personal interactions with member companies and officials, subject matter experts, and all leading to the final risk management of substances by government, if so determined. This is an exhaustive process that ensures there are no negative impacts from the use of chemicals in products. To suggest otherwise, without any data, would be false and disrespectful of what federal officials and industry have achieved over many years.

Third, once a risk management approach is decided for a chemical that remains in commerce, it doesn’t stop there. For example, more than a dozen coatings substances of interest, which have already been assessed, are still monitored when used in other products, referred to as ‘significant new uses’ of those substances (SNAc). Several other initiatives are under consideration by the federal Government related to risk assessments for nanomaterials including titanium dioxide and zinc oxide nanoforms. Officials are also looking at how to effectively assess literally thousands of PFAS substances and how to ensure more supply chain transparency for chemicals in commerce, as they always have for many substances in the past. While all aspects of the chemical assessment process is costly, rigorous and time consuming, both industry and government are committed to ensuring both human health and the environment are protected.

Without the substantial data and insights provided by CPCA members, government assessors would not be able to do their job as well as they do. Additionally, product stewardship would not be well served in terms of potential impacts on the environment or human health, if any. It is clear that the risk-based approach employed under Canada’s Chemicals Management Plan is indeed working. Anything to subvert what is arguably the ‘best practice approach’ to chemicals management, one that has been adopted by other countries, would do a disservice to what Canada has achieved to date for the benefit of all concerned. More importantly, it could compromise and delay similar achievements for a safe environment for Canadians in the future.

The federal government is now seeking to reform the Canadian Environmental Protection Act (CEPA 1999), which industry supports in terms of the need for modernization of the Act. However, CPCA and industry more widely, has urged the Government to consider the potential for unintended consequences should those amendments go beyond the scope of the current Bill. Government and many industry sectors have committed to ensuring the safe use of chemicals in products. This will continue as efforts are underway to ensure new methodologies for improved chemical assessment are adopted as they continue to evolve. It is important that the best available science be always used in chemical assessment as it should be for many other government policies and programs. If it is not data driven, what is then driving change in chemical assessment?