Canadian Finishing & Coatings Manufacturing - Sept/Oct '23 - 30

PAINT AND COATINGS MANUFACTURING: REGULATORY CHANGES
REGULATORY OVERLOAD:
A WHOLE OF INDUSTRY
APPROACH NEEDED
BY GARY LEROUX
PRESIDENT AND CEO, CANADIAN PAINT
AND COATINGS ASSOCIATION
C
anada's chemical sector is subject to increasing
legislative and regulatory change, and more
than any other time in the past. How proposed
new regulations are further developed and then
administered will greatly impact the CASE sector for years
to come. If industry wants positive outcomes over the next
several years, the time to engage on these changes is now.
It requires a 'whole of industry' approach to ensure fair
regulations, while continuing to deliver functional products
for customers.
The many proposed regulatory changes noted below will
impact all companies doing business in the CASE sector in
Canada. The work ahead will be time consuming, challenging
and require significant engagement by industry stakeholders
with common interests. The coatings industry is among the
most heavily regulated sectors of the economy when it comes
to chemicals in products. That was evident in the first three
phases of Canada's Chemicals Management Plan (CMP) over
the past 15 years where 4,300 chemicals were prioritised for
assessment and 1,600 of those are used in thousands of CASE
products. The order of magnitude in Canada will very likely
be greater when the legislative and regulatory changes noted
below ramp up.
CPCA's monthly Regulatory Radar provides members
with detailed regulatory updates on 'all' the issues facing the
sector. It details CPCA's ongoing work for the benefit of all
segments of the CASE industry on the proposed changes such
as:
1) lower VOC limits for AIM coatings;
2) ongoing discussions on biocide restrictions for paint
preservation including efforts to 'modernise' the Pest
Control Products Act and its impact on industry;
3) new regulatory initiatives assessing 4,700 PFAS chemicals,
potentially up to 10,000+ chemicals in the coming years;
4) substantive amendments to federal legislation especially
amendments to the Canadian Environmental Protection
Act (CEPA 2023) adding further requirements for risk
assessment and increasing regulations for industry to be
determined more precisely in the months ahead with data
to be gathered from industry;
5) 1000 new substances prioritised for assessment in CMPwww.cfcm.ca
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requiring industry's initial feedback via mandatory data
gathering with even more to follow in 2024;
6) proposed regulations for increased labelling of chemicals
in consumer products;
7) current initiatives to increase supply chain transparency;
8) proposed use of recycled content in plastic packaging,
containers and equipment and new approaches restricting
potential microplastic releases; and the list goes one.
These are in addition to the already significant regulatory
workload the CASE industry experienced over the past fiveto-10
years. Over the past seven years the Canadian federal
government increased staffing levels by 40 per cent and is
forging ahead with these increasing regulatory demands.
A 'whole of industry approach' is now required with input
from all companies doing business in the CASE industry in
Canada. It will require strong datapoints from every corner
of the industry whether it affects manufacturers, suppliers
or distributors. Companies may be compelled to provide data
to quantify information and/or test procedures or laboratory
practices that industry must follow in performing required
testing. Industry's goal must be to ensure the short- and longterm
impacts of proposed regulations remain reasonable,
while retaining the product performance demanded by
customers. All this will be done while ensuring products are
safe and without negative impacts on human health or the
environment. That outcome can only be achieved by relying
on substantive scientific data to guide the way forward
and address the politicisation of the process if and when
evidenced-based data is ignored.
Current and emerging regulatory issues impacting the
http://www.cfcm.ca
Canadian Finishing & Coatings Manufacturing - Sept/Oct '23

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