Canadian Finishing & Coatings Manufacturing Magazine September/October 2021 - 12

CPCA CORNER
The objective of the workshop was to discuss the advantages
and drawbacks of several potential ways forward on the file
ranging from the " status quo " option of no legislative changes to
a full removal of the exclusion from the HPA, to various hybrid
approaches modelled on the U.S. or EU systems.
leading questions favoring the views of labor stakeholders. As
expected, the survey results were dominated by responses from
labor, worker, and provincial/territorial representatives thereby
skewing the results. Approximately two-thirds of respondents
stated that they consider the current requirements under the
HPA to be insufficient to address health and safety concerns
related to the workplace use of hazardous consumer products.
This was despite HC's failure to quantify and show evidence
that the use of consumer products in the workplace is leading to
safety incidents or negative health outcomes for workers. More
than half of all respondents favored removing the exclusion and
requiring an HPR-compliant label and Safety Data Sheet (SDS)
for all hazardous consumer products.
The objective of the workshop was to discuss the advantages
and drawbacks of several potential ways forward on the file
ranging from the " status quo " option of no legislative changes to
a full removal of the exclusion from the HPA, to various hybrid
approaches modelled on the U.S. or EU systems.
There was no consensus reached among participants. Health
Canada will use the feedback obtained at the workshop to inform
its decision-making. CPCA and other industry groups advocated
strongly against removal of the exemption, which would require
industry to align all consumer product labels with WHMIS
standards and would result in significant costs to members.
Following the workshop, CPCA met directly with senior Health
Canada officials handling this file and reiterated industry's
concerns ranging from a lack of adequate representation in the
survey responses/workshop based on the fact that industry will
have to bear the brunt of any legislative amendment that may
result. CPCA was re-assured that any decision taken toward an
amendment would be based on weight-of-evidence and a costbenefit
analysis conducted to justify any regulatory actions.
A " What Was Heard " report will be published in Fall 2021
presenting the results of the survey and all stakeholder input
at the workshop. Shortly after, Health Canada is expected to
publish a proposal on the way forward whether it be a regulatory
amendment or maintaining the status quo with respect to the
exclusion.
Potential Major Trade Impacts of Listing
UV-328 as a Persistent Organic Pollutant Under
the Stockholm Convention
In January, a UN expert committee decided that the widely used
UV-stabilizer UV-328 (CAS RN 25973-55-1) meets the criteria
for listing as a persistent organic pollutant (POP) under the
Stockholm Convention, which could move the substance closer
to a possible global ban. The POP listing could also include three
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other UV stabilizers having similar properties as UV-328. UV328
absorbs radiation to prevent the degradation of plastics and
other materials. It is used worldwide in high volumes - tens of
thousands of tonnes a year - in plastic shrink wraps, outdoor
furniture, clear automotive coating, construction materials,
paints and printing inks, and textile and leather products.
This potential listing of UV-328 as a POP could set the stage
for a global ban starting as early as 2023 and it would then
trigger regulatory actions in Canada, which is a signatory to
the Stockholm Convention. The U.S. is not a signatory, and this
listing will eventually cause a non-tariff barrier to trade in North
America. Several other members of the Convention are opposed
to the listing, including Canada.
CPCA recently sent a letter to a Global Affairs Canada senior
official at the Technical Barriers to Trade (TBT) Committee of
the World Trade Organization (WTO) to inform the Canadian
delegation of this situation. The letter highlights the fact that it is
in Canada's best interest that these concerns be shared with other
TBT Committee representatives of other signatory countries
of the Convention. This would ensure that their respective
authorities are aware of the potential impact that the POP listing
of UV-328 may have on many industry segments, including
plastics. The goal is to have them encourage their own country's
engagement towards a coordinated opposition to this initiative.
CPCA's early involvement seeks to alert Canada and other
members of the Convention that the possible POP listing of
UV-328, which was proposed by an EU member, could have a
major impact on plastics and paint and coatings manufacturers
around the world. The World Coatings Council is also examining
potential actions on this important matter for global trade.
Ongoing Chemicals Assessment Activities
The ongoing risk assessment of chemicals in commerce
continues under the Chemicals Management Plan (CMP). CPCA
continues to monitor substances implicated in paint, coatings,
sealants, and adhesives and update members on regulatory
actions via our digital platform, the Canada Coatings HUB and
regular bulletins. The following publications are of interest to the
coatings industry:
The final screening assessment (FSAR) for talc (CASRN
14807-96-6) concluded that it meets the criteria for toxicity
for human health concerns and is recommended its addition
to Schedule 1. The Risk Management (RM) approach seeks to
reduce exposures to talc in loose powder form from cosmetics
and natural health products by modifying the control conditions
under the Cosmetic Ingredient Hotlist and Natural Health
Products Ingredients Database.
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Canadian Finishing & Coatings Manufacturing Magazine September/October 2021

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