ECCC and HC held a Chemicals Management Plan @Gary LeRoux, CPCA’s President & CEO gave an in-depth overview of the Canadian regulatory landscape and its many complexities. From provincial and federal mandates for product stewardship and the expanding lens of regulatory assessment to the need for greater alignment between Canada and the US, to a brief overview of CPCA’s new, comprehensive Canada CoatingsHUB. Stay tuned for more information on an upcoming summer webinar on how to use the HUB.

Multi-Stakeholder Workshop in Ottawa on May 24th, 2019. The agenda included presentations and discussion on the:

  1. Canada’s Plastics Science Agenda (CaPSA) – research
  2. Post 2020 Occupational Exposure
  3. Commissioner of the Environment and Sustainable Development (CESD) 2018 Toxics Audit Follow-up & Performance Measurement

 

1.         CANADA’S PLASTIC SCIENCE AND RESEARCH

The Canadian plastics industry is worth $35B and up to 90% of plastic waste generated in Canada is landfilled or incinerated, with only 9% being recycled. Only 20-25% of plastic packaging is diverted. In 2016, Canada leaked 29,000 tonnes of plastic waste into the environment. At the G7 Leaders Summit in Charlevoix in June 2018, commitments were made to work with industry towards:

  • 100% reusable, recyclable or recoverable plastics by 2030
  • Increasing recycled content in plastic products by at least 50% (where applicable) by 2030
  • Recycling and reusing  at least 55% of plastic packaging by 2030
  • Recovering 100% of all plastics by 2040

The CCME Strategy on Zero Plastic Waste

On November 23, 2018, under the auspices of the Canadian Council of Ministers of the Environment (CCME), Federal, Provincial and Territorial (FPT) Environment Ministers launched a Canada-wide Strategy on Zero Plastic Waste. The strategy includes  wide reduction of municipal solid waste (30% by 2030 and 50% by 2040) and identifies 10 Results Areas for priority action which includes:

  1. Product design
  2. Single-use plastics
  3. Collection systems
  4. Secondary markets
  5. Recycling capacity
  6. Consumer awareness
  7. Research & monitoring
  8. Clean-up
  9. Aquatic activities
  10.  Global action

The Action Plan on Zero Plastic Waste, to be approved in June 2019 and then released by CCME, is being developed in two phases. The first phase will focus on the first five Results Areas for priority above.

Below Government’s vision is to create a pan-Canadian plastics science agenda

CaPSA Roadmap: Implementation in Fall 2019 and Beyond

After the action plan is released, ECCC will engage with partners and key stakeholders during the implementation phase of CaPSA on how to increase momentum and enhance collaboration as well as to mobilize knowledge to inform decision-making. The follow activities are planned:

Activity #1: Mapping existing assets
Activity #2: Small-group discussions – knowledge generation, mobilization and collaboration

 

2.         POST 2020 OCCUPATIONAL EXPOSURE

2.1 Summary of Results of Canadian Federal/Provincial/Territorial Survey on Chemicals and Workplace Exposures 2018

In the Fall of 2018, FPT jurisdictional members of the Committee of WHMIS Coordinators (CWC) were surveyed to identify potential opportunities to leverage the expertise and data accumulated on hazardous substances used in Canadian commerce through the CMP to benefit worker health and safety. The key benefits identified and supported by the respondents were:

  • Priority setting for inspections, compliance monitoring, Occupational Exposure Limits (OEL) development
  • Development of materials and methods to educate employers and assist them in fulfilling their OHS responsibilities, especially small employers. It would also help support jurisdictions in addressing the risk management challenges posed by the WHMIS excluded products, especially consumer products and achieving pan-Canadian harmonization of occupational exposure limits

2.2 Health Canada Consulted on An Integrated Strategy for the Protection of Canadian Workers from Exposure to Chemicals

Potential opportunities to enhance worker protection were laid out as follows:

  1. Data sharing & prioritization (Access to information received under the CMP on what chemicals are being used in which products, at what quantities, in which industries and in which jurisdictions would support OHS regulators in applying their regulatory authorities. Data sharing & priority identification of chemicals of concern will come from WHMIS 2015 classification, proposed IRAP, Harmonized OEL development and Research & Monitoring).
  2. Occupational exposure limit development (Priorities for OEL development would be decided jointly by the HC-FPT OHS Regulator Committee followed by a scientific review then reviewed and approved by the HC-FPT OHS Committee prior to publication. Potential priorities for OEL development could include: where exposure occurs in multiple jurisdictions, where predicted risks are to be highest, no existing OEL, review of existing provincial, ACGIH or international OELs, chemicals with new tox data, new hazard information or change in hazard classification)
  3. Research and monitoring (OHS regulators do not have a mechanism within the CMP context to influence HC research and monitoring projects to protect Canadian workers, HC-FPT OHS Regulator Committee to identify priorities for HC research and monitoring, HC to put out calls for proposals to HC research scientists, HC research scientists develop project proposals for peer review, HC senior management approval of projects)
  4. Risk assessment & information gathering ( Priorities for risk assessment of existing substances could include: Sensitizers (skin and respiratory), carcinogens and reproductive hazards including endocrine disrupting chemicals, Where there may be concerns with cumulative exposure, When there are workplace exposures to chemicals of concern that are in consumer products, change in hazard classification, international priorities)
  5. Risk management (If risk assessments were to be expanded to include health risks to workers, increased information sharing with OHS regulators would be needed.
    When a risk is identified, RA findings are communicated to HC-FPT OHS Regulator Committee, and appropriate RM measures are pursued)
  6. Strengthen science-based hazard classification (There is a need for a more strategic and targeted approach to data collection and chemical classification)
  7. Increase awareness (Develop customized compliance promotion material and communication tools, Conduct targeted information campaigns to raise awareness, Publish hazard classifications of chemicals online)
  8. Increase compliance & enforcement under the Hazardous Products Act (HPA) (Shift to a proactive and targeted compliance strategy, Gather intelligence to inform C&E activities, Develop a pan-national strategy to prioritize C&E under the HPA)

3.   CESD 2018 TOXICS AUDIT FOLLOW-UP
& PERFORMANCE MEASUREMENT

The reports of the Commissioner of the Environment and Sustainable Development was submitted to the Parliament of Canada in Fall 2018, which found that:

  1. ECCC did not base most of its enforcement priorities on risks to human health and the environment and had not fully addressed selected recommendations found in their previous audits
  2. ECCC and HC had not completed work to assess whether they were meeting their overall objectives to reduce the risks of toxic substances to human health and the environment
  3. Information for the public was often unclear and difficult to find

The report recommended that ECCC/HC set out a long term, systematic approach to evaluate the effectiveness of actions to control toxic substances including setting measurable objectives, monitoring achievement of those objectives and setting timelines for completion.

ECCC’s response was to develop a strategy for performance measurement of risk management actions, which will:

  • Establish a long-term approach to systematically assess the effectiveness of actions to control toxic substances
  • Currently in development, the long-term approach will be made public by Spring 2020, along with a workplan for long-term performance measurement work (also to be updated regularly thereafter)

Why a “long-term’’ and “systematic’’ Approach for Performance Measurement?
Long-term: To ensure RM actions continue to meet their objectives over time:

  • Science and methodologies evolve, with better tools and detection rates
  • Time is required to see patterns/trends for most RM instruments
  • Long-term planning required to develop methodologies and collect data in the short term and in the future to inform evaluation

Systematic – Approach to be applied in a transparent and consistent manner as follows:

  • CEPA-toxic substances would be considered for performance measurement
  • PM Strategy would inform prioritization of evaluations and timelines would be made public

Each step will be informed by establishing data needs, conducting data gathering/ generation and outreach/consultations as per below:

  1. On-ramping of substances to consider
  2. Consideration of available information- which substances can be evaluated and which require more work?
  3. Prioritization – Which substances should be evaluated first and which should be addressed in the medium and long term?
  4. Evaluation and Analysis: Overall findings and potential concerns (i.e. identification of emerging issues)
  5. Outcomes validation: Performance and follow up needs
  6. Reporting and timelines

The government recognized data challenges (lack of availability, representativeness, data incompatibility or inconsistencies, timing) and logistical challenges (resource requirements for data generation e.g., financial and human resources, as well as time, tools to connect and analyze large, multi-source data sets and sampling and monitoring challenges).

In addition to measuring performance of past actions on Toxics, the Program will also:

  • Ensure performance measurement is considered in newly identified toxic substance RM actions (Performance wording now starting to be included in risk management approach documents)
  • Align performance measurement with Post-2020 objectives
  • Strive for continuous improvement in managing risks (lessons learned)

FOLLOW UP ACTIONS: Where performance evaluation shows objectives are not adequately being met, or where the linkage between actions and outcomes are not clear, a range of follow-up activities could be considered by the government.

MEMBER ACTION REQUIRED: The more detailed presentation decks are available from CPCA or can be downloaded from the CoatingsHUB. We expect that minutes of this stakeholder meeting will be published shortly. Please share any comments or questions that you may have with CPCA.

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CPCA member companies reap the rewards of our ongoing international efforts as a member of the International Paint and Printing Ink Council focused on supporting strong national and international brands.