It’s obvious to all in the coatings industry that a vast array of chemical ingredients is required for thousands of product formulations that range from resins and pigments to performance minerals, surfactants and dispersants. Key customers like many CPCA manufacturer members in the coatings business, including adhesives and sealants, need quality raw materials to meet the strict demands of their customers. The need to increasingly meet those demands is impacted by regulatory challenges that continue to grow, placing greater pressures on raw material suppliers. Suppliers and their distributors understand and advertise the need to be fully conversant with existing regulations for their raw materials. A big part of that equation is understanding the status of substances being actively reviewed by governments at all levels, especially at the federal level in Canada under the Chemicals Management Plan (CMP). This extensive effort in Canada prompted a regulatory manager of a large CPCA multinational member to comment that, “Dealing with the CMP is like drinking water through a fire hose.” He was right in terms of the regulatory monitoring that is required and the robust data gathering effort that is needed for effective chemical risk assessment. Data is the most critical part of the entire exercise, as it assures the assessments of critical ingredients are science based and much of that data resides within industry.
After nine years assessing more than 2,300 substances in phases 1 and 2 of the CMP, Canada is now in the process of evaluating more than 1,500 substances in commerce that are of concern to human health and the environment. This is in stark contrast to current efforts underway in the United States following the reform of TSCA and the plan to assess 10 substances over the next several years. It speaks to the two different forms of government in each country and the priorities of each. The purpose of the CMP assessment of chemicals regulated under the Canadian Environmental Protection Act (1999) is to either ban substances of concern or restrict their use by managing the risks associated with them via increasing regulation or other risk management measures. CPCA works to ensure the worst case is a regulation wherein substances are still permitted for use as opposed to an outright ban limiting options in product formulations. Over the past nine years in Canada we have been fortunate that there have only been two banned substances and 80 risk management measures for ingredients used in all chemical sectors. That does not mean the process is not onerous and costly for industry. The federal government committed C$1.5 billion for this undertaking, and the cost to all chemical sectors has never been calculated, but it is not insignificant.