Canadian Finishing & Coatings Manufacturing Magazine - May/June 2023 - 40

PAINT AND COATINGS MANUFACTURING: CRITICAL ISSUES
2
Filtration & Separation Technologies 1 2
Folio Instruments Inc. 1
GFL Environmental East Corp 1 2
Gizmo Products Inc. 1
Howard Marten Fluid Technologies Inc. 1 2
Innovative Finishing Solutions Inc. 1 2
Lonza 1
Myers Engineering, Inc. 1
Netzsch Premier Technologies LLC 1
Quickblades, Inc. 1
Radia 1
RB Atlas 1 2
New Regulations For Chemical Assessment
Union Process 1
UV Canada 1 2
UV Process Supply, Inc. 1
Woodman Agitator, Inc. 1
Then we come to the impacts that could evolve from Bill S-5 amending existing
regulations under CEPA, further regulating chemical assessment and risk management
in Canada. The coatings industry is highly impacted in those assessments. Many of the
hastily proposed amendments added by the unelected Senate were, thankfully, removed
by the House of Commons Environment Committee. If the Bill is passed in its current
form by the House of Commons, it could bring some relief for industry in general.
However, the devil is in the details in terms of the administration and/or interpretation
of several clauses in the regulations. One of those clauses is the 'watch-list' for
SensaDyne Instrument Division 1
Ship & Shore Environmental 1 2
Siemens Process Industries and Drives 1 2
Skyray XRF 1
The CMM Group, LLC 1 2
Static Eliminators
Bex Engineering Limited
Bystat International Inc.
Complete Spray Paint Equipment
Innovative Finishing Solutions Inc.
Tech Sales Co.
UV Process Supply, Inc.
vision
chemicals in products, which only
have the " potential to become harmful
in future, " not harmful now.
Many industry sectors have noted
the 'watch-list' could cover a vast
array of chemicals in a huge number
of products. It will also be at the
Minister's full discretion which ones
are put on the list. And, the Minister
makes that decision based on what
members of civil society bring forward
to him. It is not yet clear on what
basis that political decision will be
made. Many have suggested this could
become a long list of chemicals that
are already regulated for safe use in
many products in Canada. Again,
this was never part of any 'regulatory
efficiency' test related to risk
management of anything, including
chemical substances.
It is logical to conclude that
these safe, regulated substances
will very likely be viewed as a 'bad'
list of substances creating concern
for the many products containing
them. The question is: how many
of those watch list products will be
left on the shelf by consumers? No
amount of promoting the benefits
of such products containing watch
list chemicals will win over fatalistic
comments attributed to the safe
products containing them. They will
view them as 'potentially toxic' as per
the definition. Yet, the chemical was
never on the Government's own list
of chemicals of concern for further
regulation in the past, today, or in
future.
Lack of Regulatory Efficiency
A critical challenge for new
regulations is the need to have fair,
evidenced-based regulations that
seek to align with our largest trading
partners. A recent federal Government
economic update stated there needs to
be " greater consideration of regulatory
efficiency and economic growth into
regulatory mandates " and that must
include a 'valid' risk-assessment to
address three simple questions: 1) Is
it affordable? 2) Is it acceptable? 3)
Will it work? There are even more
concerns when those regulations are
going beyond the point where products
can actually remain in commerce.
At a certain point without critical
active ingredients, many products
will cease to exist without the efficacy
those active ingredients provide.
40
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Canadian Finishing & Coatings Manufacturing Magazine - May/June 2023

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