NOTE: 15-Days Left Before OIT Ban Takes Effect

The PMRA (Pest Management Regulatory Agency) just confirmed with an expert panel of registrants that an airless spray raw data study was submitted too late to allow sufficient time for the Agency to review as related the decision to ban OIT for film preservation. Therefore, the ban takes full effect on May 31, 2019. Despite the fact that PMRA officials had agreed to expedite their analysis, the PMRA Exposure Assessment Division stated that it was virtually impossible for them to review the data, calculate the tox end-points, have everything peer-reviewed and the decision documents prepared, translated and published in a 2-week period.

CPCA regrets having informed members that it was now on a positive track that might have altered the ban. The PMRA review, however, of the airless sprayer raw data and final study report will continue until after the ban is in effect. Please note that the PMRA risk assessors’ analysis may or may not alter the final PMRA decision on OIT even after the deadline.

As OIT is a dry-film preservative used in a number of architectural and industrial / automotive paint and coating products sold in Canada, US and Canadian paint and coatings manufacturer members should be prepared to remain in full compliance whatever the final decision is on the OIT ban.

More information on the OIT ban and restrictions effective May 31, 2019:

  • The OIT ban for paint and coatings has to do only with OIT added during paint production to preserve dry-paint films. The ban is NOT for the various use rates of OIT that are currently permitted for ingredients or raw materials which are incorporated in the paint mixture. Similarly, OIT can still be present at permitted rates in the colorants added AFTER the finished base paint product at point of sale.
  • CPCA supplier members should note that, as part of the final PMRA decision for OIT that also comes into effect on May 31, 2019, the following reduced rates are imposed on the production of polymer compounds, aqueous emulsions and adhesives (0.54 a.i./L max).

What US and Canadian paint manufacturers should do now:

  • After May 31, 2019, paint manufacturers having added OIT to their products during production for film preservation, can no longer import or sell these products in Canada
  • Any paint products made before the May 31, 2019 deadline, and for which OIT has been added during production, and are in stock at warehouses, distribution centers, or retail outlets in Canada – whether imported or manufactured in Canada – can still be sold, until all existing stocks are depleted. However, all these imported products must have reached Canadian warehouses, distribution centers or retail outlets before the effective date of the ban.
  • No time limit is imposed for the depletion of these stocks containing such OIT stocks that are at the manufacturing facility, stored in warehouses, distribution centres and retail outlets before the ban takes effect.
  • Paint and coatings manufacturers can no longer add OIT to the paint and coatings mixture during production after May 31, 2019, even if it is just for the export of such Canadian products.
  • Canadian manufacturers can continue to use OIT after May 31, 2019, as a preservative for any other registered uses at permitted rates for sale in Canada or for export (e.g., adhesives, aqueous emulsions, polymer compounds, etc.).

MEMBER COMPLIANCE ACTION REQUIRED: CPCA urges paint and coatings manufacturer members to take all IMMEDIATE and necessary actions:

  • To build their inventories in Canada (in order to avoid any trade disruption) with respect to all products for which OIT needs to be added during production
  • To make every effort to remain compliant by working with your biocide suppliers to identify and use alternative dry-film preservatives that are currently registered with the PMRA in Canada. There are 8 dry-film preservatives registered for paint uses: carbendazim (CAS 10605-21-7), diodofon (CAS 20018-09-1), folpet (CAS 133-07-3), 3-iodo-2-propynyl-butylcarbamate(CAS 55406-53-6), 4,5-dichloro-2-n-octyl-3(2H)-isothiazolone (CAS 64359-81-5), 2-(thiocyanomethylthio)benzothiazole (CAS 21564-17-0), chlorothalonil (CAS 1897-45-6) and thiabendazole (CAS 148-79-8). The up-to-date PMRA registration database is provided in the CPCA CoatingsHub for members only or upon request.

All manufacturers of adhesives and suppliers of polymer compounds and emulsions should ensure that any OIT addition to their products does not exceed the above noted limit.

CPCA NEXT STEPS:  CPCA will seek a meeting with the head of PMRA to discuss the possibility of obtaining further sell-through time in what is the industry’s busiest season, given the short time allowed for paint reformulations and the lack of other suitable alternatives used for that purpose. CPCA continues ongoing discussions with PMRA officials to clarify the issue related to the lack of alternatives for OIT, CMIT/MIT and BIT and is currently documenting this issue with members’ help. In the coming months, the CPCA Biocides Panel members will continue to address this important issue of biocide misalignment with the United States and the lack of ‘user’ input and relevant feedback is affecting all manufacturers of CASE products (Coatings, Adhesives, Sealants, Emulsions) with respect to a limited selection of biocides for paint and coatings in Canada.

May 16, 2019

CPCA Bulletin: URGENT NOTICE CONCERNING OIT BAN IN CANADA USED FOR FILM PRESERVATION

NOTE: 15-Days Left Before OIT Ban Takes Effect The PMRA (Pest Management Regulatory Agency) just...

The CPCA Compliance Calendar ensures regulatory staff mitigates risk for their companies. Essential information is provided in support of member companies’ ongoing enterprise risk management (ERM) efforts.