Canadian Finishing & Coatings Manufacturing Magazine March/April 2022 - 29

PAINT AND COATINGS MANUFACTURING: COST BENEFIT OF PAINT RECYCLING
FEDERAL LEGISLATION
AND REGULATION
RAMPING UP
BY GARY LEROUX
T
here are many regulations now flowing from the
federal Government, which the coatings industry,
and many others, will have to deal with in the weeks
and months ahead. CPCA members have spent a lot of
time and effort to address many issues related to the assessment
of chemicals in Canada used in literally thousands of products.
Now the federal government is moving forward quickly on
amending the Canadian Environmental Protection Act (CEPA,
1999). Among other things, CEPA governs everything related
to chemical assessment and risk management instruments
flowing from those assessments such as pollution prevention
plans and regulations. The proposed amendments to the Act
require the federal Government to " implement a framework of
how principles of environmental justice will be considered and
balanced with social, economic and scientific factors. " The Act is
expected to be amended by the end of 2023 or early in 2024.
More than 500 substances used in coatings, adhesives,
sealants and elastomers (CASE) were risk-assessed over the
past five years under Canada's Chemicals Management Plan
and more than 1200 in two previous rounds. Risk Assessment
is not currently codified the Act, but the
plan is to codify it in this current round of
amendments. It's not clear what that will
mean for the assessment of chemicals
for CASE, if anything. However, industry
has maintained all along that a risk-based
approach must be the way forward on
chemical assessment. If codifying it in
the Act helps cement that approach in
stone, then fine. But, if the definition of
risk assessment is altered significantly it
may mean a backward step for chemical
assessment in Canada. CPCA and the
industry generally must be vigilant on
how the proposed amendments play out
as it will impact chemical assessment
and the decisions made on use chemical
use restrictions and bans.
In
terms of the current ongoing
assessment of chemicals, the coatings industry remains
concerned with the high frequency of federal Government
consultations under Canada's Chemicals Management Plan.
This is somewhat worrying for CPCA member companies given
the current economic climate and the long-lasting effects of
the pandemic. The global chemical manufacturing sector is
currently experiencing significant supply chain disruptions and
severe raw material shortages resulting from a combination of
factors precipitated by the COVID-19 pandemic. This has led
to increased shipping and freight delays resulting from a high
demand for manufactured items.
A recent report on the economic outlook for the paint and
A recent report on the
coatings sector found that raw material prices were up an
average of 26% in 2021 and 34% in Q4 versus Q4 2020. Freight
and trucking costs continue to increase as well, up nearly 20%.
As the world begins to gradually recover from the initial impact
of the pandemic, the outlook for supply chain issues is mixed.
Base chemical supply materials and pricing appears to be slowly
improving, but trade indicators still predict levels well below
pre-Covid norms. Although supply chain issues will gradually
improve, recovery will still be slow and could be interrupted by
further waves of the pandemic or economic fallout from it.
These disruptions have consumed a significant portion
of our members' resources over the past two years. Product
formulators in all companies, both large and small, are dealing
with long delays for key raw materials, lab equipment, and
needed accessories, all of which negatively impact entire
production lines, inventory, and distribution. Adding extensive
consultations and demands for data on industry only adds
to the strain. For example, CPCA and its
members, are currently engaged in several
consultations
with
economic outlook for the
paint and coatings sector
found that raw material
prices were up an average of
26% in 2021
and
34% in Q4
versus Q4 2020
federal government
departments, which impact the coatings
sector directly as staff must be fully engaged
in supplying critical data. These includes the
mandatory requirement for Section 71 survey
data for Bisphenol A structural analogues
and functional alternatives targeting
188 substances. All have extensive timeconsuming
requirements placing significant
burdens on the CASE industry. There are
also draft screening assessments and risk
management instruments being considered
for the Flame Retardants group and Phenols,
Methylstyrenated, for which the deadline
was extended to March 2022.
Other regulatory initiatives further
increase the burden substantially such as
the more stringent VOC regulations proposed by the federal
government for architectural coatings, increasing restrictions
on plastics, the upcoming nanomaterials survey for TiO2 and
zinc oxide, and new supply chain tracking requirements. Most
importantly, a large portion of our members will also have to
face the proposed mandatory risk management instrument
for 2-butanone oxime (MEKO, CAS RN 96-29-7), a crucial
anti-skinning agent for alkyd paints. All at a time when our
members' R&D resources and lab support are monopolized by
March/April 2022
29
Canadian Finishing & Coatings Manufacturing Magazine March/April 2022

Table of Contents for the Digital Edition of Canadian Finishing & Coatings Manufacturing Magazine March/April 2022
