Canadian Finishing & Coatings Manufacturing Magazine November/December 2021 - 11

CPCA CORNER
The regulatory fate of TiO2
the United States, the American Coatings Association, which is
also part of the working group with PMRA. This group can also
include representatives from the US EPA as needed to ensure
the very same science is considered in the ongoing evaluation of
biocides used for paint preservation. That is the only way there
will be alignment to prevent variances in decisions made on
both sides of the border using the very same data. This must also
change as it serves no one's interest, especially not the coatings
industry.
CPCA Advocates for Removal of Costly Provision
in the Hazardous Products Regulations
CPCA members continue to experience difficulties in complying
with the requirement to provide written documents highlighting
" significant new data " as part of Section 5.12 of the Hazardous
Products Regulations (HPR). When significant new data
becomes available manufacturers are obligated to update either
the product label, SDS or both and send a written document
to customers describing the changes. This requires tracking
of all sales data followed by the need to send letters manually
to customers, which is both cumbersome and extremely time
consuming. All members believe the time and resources imposed
by such a requirement would be better spent on updating the
SDSs and getting those documents to customers as quickly
as possible. The trend in industry is for electronic delivery of
SDSs, wherein the different sections of the SDS are parsed and
sent to different departments. The addition of a letter cannot be
processed in this manner by industry customers as it slows down
the process significantly.
CPCA raised these concerns with Health Canada in a
formal submission, which were supported by other industry
associations. CPCA's recommendation was for a complete
removal of this provision from the HPR. This requirement puts
Canada out of alignment with the United States and is not even
required in Europe, which tends to have a strict regulatory
landscape.
in
Europe, the United States, and
Canada is of great concern to CPCA
members. In the EU classification
and labelling requirements for
titanium dioxide (TiO2
) changed in
February 2020.
Under the Canada - US Regulatory Cooperation Council Joint
Forward Plan (RCC), Canada has an international commitment
to align the Hazardous Products Regulations with the seventh
revised edition of the United Nations Globally Harmonized
System of Classification and Labelling of Chemicals (GHS). All
stakeholder groups expressed support for the regulatory proposal,
indicating that they are in favor of maintaining alignment with
the United States, if worker health and safety benefits and
protections are maintained or increased. However, the concern
is with the timing of the coming into force of the amended
regulations and the need for alignment with that of the United
States, to the extent possible. The United States and Europe,
which are major trading partners for Canada, have implemented
reporting periods for changes to SDSs and labels, which serves all
intended purposes without any extra communication required.
If Canada is to maintain alignment with the United States
regarding the manner in which changes to workplace hazards
are communicated, extra written communication in addition to
the standard three months for SDSs and six months for labels, is
unwarranted. It would present an undue burden on industry and
possibly create confusion among users of the SDSs and labels
without adding safety benefits.
CPCA Monitoring TiO2
Developments in Europe
in Anticipation of Canadian Risk Assessment in
2022
The regulatory fate of TiO2
in Europe, the United States, and
Canada is of great concern to CPCA members. In the EU
classification and labelling requirements for titanium dioxide
(TiO2
) changed in February 2020. The European regulatory
body, ECHA recently released a guideline on classifying and
labelling TiO2
requirement for TiO2
upcoming risk assessment of TiO2
manufacturers and suppliers classify and create accurate labels
for TiO2
summarizing the classification and labelling
in Europe. These actions may influence the
in Canada. It is meant to help
in mixtures. The new classification scheme is heavily
dependent on the physical form sold as well as particle size in
the formulation. Liquid mixtures containing TiO2
do not require
carcinogen classification.
As of October 1, 2021, following the Delegated Regulation
(EU) 2020/2017, new classification and labelling requirements
came into force in the EU. TiO2
must be classified as a carcinogen
if inhaled (Carc. 2, H351 - inhalation) when supplied on its own
or in mixtures, where the substance or mixture contains one
November/December 2021
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Canadian Finishing & Coatings Manufacturing Magazine November/December 2021

Table of Contents for the Digital Edition of Canadian Finishing & Coatings Manufacturing Magazine November/December 2021
