CPCA recently launched a robust Chemical Management Substance Database as part of its Canada CoatingsHUB resources in support of the coatings industry efforts to manage the large volume of data created by Canada’s ongoing assessment of chemicals in commerce. Some of those issues are briefly updated below for those companies doing business in Canada or intending to in future. The database contains 1,100 substances known to be used in the coatings, adhesives, sealants and elastomers sector (CASE) used in a wide range of SKUs. This is the coatings segment of the 4,300 substances categorized for risk assessment and risk management under Canada’s Chemicals Management Plan (CMP) over the past decade and a half. There will be more than 1,500 substances prioritized for assessment beyond 2020 after the third phase of the CMP concludes in 2021. CPCA will add the chemicals in the CPCA substance database by chemical number for ease of access.
There are many chemicals still undergoing risk assessment and risk management in Canada. For example, leftover from Phase 2 of the CMP is the Final Risk Assessment Report (FSAR) for the Phthalate subgroup. These are being further assessed for cumulative effects following a draft risk assessment that proposed declaring two phthalates as toxic (B79P and DHEP). However, based on the information provided by CPCA members in the data-gathering phase several of the remaining 26 Phthalates used in CASE products are proposed for a ‘non-toxic’ designation at current levels, despite some suspected endocrine disruption and cumulative effects. The final screening assessment for certain Flame Retardants will be published in the Fall of 2020. Three of these substances have been proposed as toxic and two of them (DP and DBDPE) will be added to a list of prohibited substances in Canada. Additional flame retardants are scheduled for risk assessment next year.
CPCA recently reminded all members of the assessment of 134 Boric Acid, its Salts and Precursors, which were proposed for a ‘CEPA-toxic’ designation in Canada related to human health and the environment. However, the final screening assessment is still on hold. The government has yet to provide a final decision and propose a ‘risk management’ approach for Soluble Cobalt Compounds already proposed for designation as ‘toxic’ for the environment. Further notice related to the internationally classified substance AEEA is awaiting publication in Canada. AEEA is used as a curing agent for epoxy resins, as a component of adhesives and sealants, used in asphalt paving or patching products, and as a component in super glues and corrosion inhibitors. CPCA also expects the final significant new activity (SNAc) requirements to be published for two MDAs imposing an annual threshold of 100 Kg/year.
In Phase 3 of the CMP there are several groups of CASE-implicated substances remaining to be assessed well into 2021. Some key assessment publications are being delayed because of the COVID-19 pandemic. However, CPCA is closely monitoring the Final Screening Assessment for benzophenone, which will likely be concluded as ‘toxic’ at a very low level later this year. Hence, this will impact some resins currently used for indoor and exterior consumer paint and coatings products. Also coming later this year in early 2021 is the final assessment of pigments and dyes, Epoxides and Glycidyl Ethers and Fatty Acids and their derivatives. All substances in these groups are proposed as being ‘toxic’. In the coming months, there will also be draft risk assessment reports published for Acid and Bases, Alcohols, and Aromatic Amines. CPCA submitted comments on the draft assessment for Ketones, challenging the proposed toxicity decision for MEK, MIBK, and 2,4-PD, which are used in certain liquid and aerosol paint and coatings; and more widely in allied products (thinners, removers) currently available to Canadian consumers. The final assessment report is expected this summer. Talc has been proposed as toxic when available in a powder form in consumer products.
Also coming this winter is the final risk assessment for the Furan group in which Furfuryl Alcohol is proposed as toxic for its current use in wood strippers, and unfortunately with no cost-effective substitute available. The same will apply to Tetrahydrofuran, which is a common solvent in industrial CASE products. The draft assessment for Ethers, Manganese, Low Boiling Points Naphtha, Piperazine, Silver, Substituted Phenols, Benzotriazoles and Benzothiazoles, and Titanium compounds (including TiO2) have been postponed to later in 2021. There has been no definitive timeline provided by the federal government beyond 2020 for these substances.
Apart from chemicals management of chemicals, there is the ongoing re-evaluation, by another arm of the Federal Government, of biocides used as preservatives in paint, coatings, and adhesives and sealants. Information was recently provided on the long-delayed re-evaluation of 6 such preservatives: sodium omadine, chlorothalonil, dazomet, folpet, ziram, and the special review of diodofon. Additional risk mitigation measures include outreach or stewardship programs for professional painters and primary handlers, e.g. industrial handling. Ziram’s registration has been proposed for cancellation for adhesives or as a material preservative generally. The use of folpet as a paint preservative is also proposed for cancellation. Diodofon’s registration will be cancelled for use in exterior paint. The use of Sodium Omadine must be reduced in latex paint emulsions from 0.648 g a.i./kg to 0.058 g a.i./kg while its applicable levels will be reduced in other paint products and building materials. Chlorothalonil use would still be accepted in latex and solvent-borne paint, but reduction of the maximum registered label rates from 9.8 g a.i./L (exterior latex paint) and 11.8 g a.i./L (solvent-based paint) to 8.5 g a.i./L for exterior latex paints and solvent-based paints. Dazomet would still be acceptable for use in paint but with a reduced limit (0.53 g a.i./kg), but cancelled for use in paper coatings.
The biocides file remains an ongoing priority for CPCA. It is critical the coatings industry remains vigilant and can provide all the necessary industry data to support current use levels for biocides in paint and coatings. CPCA recently took further initiatives to ensure greater regulatory alignment with the US EPA on biocide registration and re-evaluation via the Canada-United States Regulatory Cooperation Council and the PMRA. There are a number of other issues the Association is concerned within this area and both staff and technical committees are committed to seeking a resolution for the benefit of industry in the months ahead.
Finally, but not least, VOC emissions and air quality continue to be a strong focus of the current federal government in Canada. In 2019 it conducted a comprehensive study related to existing national VOC limits for 53 categories of Architectural and Industrial Maintenance coatings sold in Canada. It also identified 10 new coatings categories not currently regulated, which are to be included in the proposed amendment to the Architectural regulations. A formal consultation will be organized in the fall of 2020 for those regulations. Government’s goal is to secure additional emissions reduction by aligning the Canadian regulations to California’s CARB-2019 or OTC Phase II VOC limits. CPCA continues comprehensive discussions with officials on the proposed amendment and will consult closely with members on rational approaches to any changes in the current VOC limits.
It is important to remind government that huge emissions reduction has already been achieved in Canada since the first regulations were enacted in 2009. Government must also consider the full impact of any future actions on product performance vis-à-vis any new reductions that could realistically be achieved. The federal government expects to publish the proposed VOC regulatory amendment in 2021, at which time there will be limited opportunities to deal with any outstanding industry concerns. The advocacy on this file must be done now for the best possible outcomes for the coatings sector in Canada.