We cannot emphasise enough how important it is to consider how we tackle the challenges before the coatings industry in Canada. The paint and coatings industry is certainly among the most heavily impacted when it comes to issues such as chemicals management with the ongoing assessment of more than 500 substances used in a wide range of product formulations, out of a total 1540 in Phase 3 of CMP. That is just the CMP, there are other challenges on substances used for in-can and film preservation, key registered biocides under the PMRA. The federal government is now looking at chemicals management beyond 2020 and what that might mean for further regulations in the sector. The demand for data by the federal government will certainly not diminish, as they continue to gather relevant data to make informed assessments of the chemicals used in products. In that regard, CPCA and its members continue to lobby for reliance on strong evidence-based data for better regulatory outcomes for our industry.
Before looking at some of the ongoing challenges ahead, it is instructive to look at a few successes in 2018, which shows our sector can get positive outcomes when the industry is united and focused on the things that matter.
While there were successes this past year, as noted above, the level of data and input required to secure positive outcomes can be overwhelming for staff and members. An example of the level of data required with respect to chemicals management includes the government’s national survey on the MEKO Code of Practice coming in January, assessing the success of the Code agreed to by industry in 2014. Then there are two other ongoing mandatory CMP surveys on quaternary compounds and coal tars. The government will also be rolling up information gathering requirements related to 1400 substances contained in multiple ‘inventory updates’ for the federal Domestic Substances List. At the same time, a new microplastics survey will be launched to determine the level of use and potential exposure of microplastics in paint and coatings. Our members will also have to comply with a mandatory flame retardant survey to be completed in the New Year for the coatings industry. A survey was also initiated in 2018 on the 1-litre exemption for VOCs in paints and stains in Canada. For this one, our members will need sufficient time to respond, as the type of information sought is not always readily available. CPCA also continued collecting data on three substances used in some adhesives and sealants products, which should be formally proposed for addition to Schedule I of CEPA and, if so, two of them (DP and DBDPE) could be added to a long list of substances to be targeted in a proposed amendment to the Prohibition of Certain Toxic Regulations, 2012, such as PBDEs, HBCD, PFOS, PFOA, etc.
The federal government will also launch a national survey on VOC content in Architectural and Industrial Maintenance (AIM) paint products sold in Canada for comparison with VOC limits in effect in other North American jurisdictions. Other mandatory surveys under CEPA 1999 for the Chemicals Management Plan will be issued later in 2019 along with other reporting requirements scheduled for the year. There is little development to report with respect to the Federal VOC Agenda 2010-2020, which aims to cover seven industrial categories of products emitting substantial VOCs in Canada. While the current focus is on three major VOC emissions contributors (asphalt cutbacks and printing and portable fuel containers), there have been only limited discussions with federal officials to date regarding the remaining four categories: industrial adhesives and sealants, cars/vans/light truck/assembly coating/auto parts coatings, rubber product manufacturing and plastic parts coatings and aerosol coatings. CPCA continues to monitor this important development and will prepare to respond and inform members as required.
As usual, the industry continues to comply with significant requirements, as they always have, to ensure continued production of sustainable and high-performance products for their customers. CPCA is gearing up to ensure members are fully informed and supported in gathering the data needed for more informed chemical assessment and ultimately better decisions based on science. To help address these challenges CPCA has developed a comprehensive “Canada CoatingsHUB” for members to ensure they have all the tools needed to comply with regulatory requests such as those noted above and more. This new Hub is a robust and relevant platform to help members deal with the flood of data requests in a timely manner, all on a functional, digital platform. This will include a compliance calendar with all the dates noted to ensure targets are not missed and risk is mitigated. It will allow members to select priority issues on which they would like to receive updates and provide a searchable database of relevant information for the coatings industry in Canada. Members can access and search the relevant data via their individual CoatingsHUB dashboard, when and how they wish to. This new digital communications platform was custom-designed for the coatings industry and the first of its kind for more effective association management.