CPCA Supports Risk-based Assessment in Canada

Before launching the Chemicals Management Plan (CMP) the federal government completed a seven-year triage of 23,000 chemicals in commerce since the 1980s. That triage process identified 4,300 substances for risk assessment, which is now mostly completed with roughly 40% of those 4,300 substances used in CASE industry formulations.

The Canadian Paint & Coatings Association believes that Canada's risk-based approach to managing chemicals in commerce is the only methodology that creates consistent and fair outcomes that benefit the industry, the environment, and the economy. CPCA ensures assessment of chemicals used in the CASE industry are based on robust, relevant, and scientific data, which is critical to achieving the best possible outcomes.

CMP by the Numbers

What is CEPA?

The Canadian Environmental Protection Act (CEPA) is Canada's federal environmental legislation aimed at preventing pollution and protecting the environment and human health. In June 2023 the Act was renamed ‘Strengthening Environmental Protection for a Healthier Canada Act’ with substantive regulatory changes for chemical assessment under Canada’s Chemicals Management Plan(CMP) to be fully developed over the next 2 years and likely beyond. The time to take action for fair regulations is now!

Amendments to the Canadian Environmental Protection Act in 2023

The recent 63 amendments to CEPA in 2023, now called Strengthening Environmental Protection for a Healthier Canada Act, created new approaches to chemical Risk Assessment in Canada. These will incorporate concepts such as the Right to a Healthy Environment (RTHE), a watch-list of chemicals likely to become toxic, shorter timelines for assessment, use of New Approach Methodologies, labelling changes, etc.  These new regulations are being consulted on in the coming months. It is an important time for industry to be fully engaged. How the recent 63 amendments are interpreted by Government officials and incorporated into the new Act over the next 18 months will have an impact on chemicals management in Canada for the immediate future.

Chemicals Management Process

Introduced in 2006 the Chemicals Management Plan (CMP) is a federal government initiative administered cooperatively by Health Canada (HC) and Environment and Climate Change Canada (ECCC). Under the authority of the Canadian Environmental Protection Act (CEPA, 1999) the CMP utilizes established evidence-based risk assessment tools leading to risk management measures such as regulations, pollution prevention plans, Significant New Activity restrictions, Codes of Practice, compliance agreements, etc.

In the first three Phases of the Chemicals Management Plan (CMP) over the past 16 years Canada assessed 4,300 substances in commerce, more than any other country. In 2021 Canada announced CMP Phase 4 prioritizing more than 1,000 substances for assessment with more to come in the months ahead, all to be completed by 2025. The time for industry to engage is now!

As a highly respected risk-assessment approach for chemicals in commerce, the Chemicals Management Plan (CMP) has proven it works because of the following protocol:

  • A systematic science-based process for “Categorization,” “Prioritization” and “Screening Assessment” of the substances of ‘highest concern’ for substances on Canada’s Domestic Substances List (DSL)
  • Both mandatory and voluntary information gathering related to hazard exposures for hundreds of high, medium and low priority substances
  • Regulations developed to restrict and/or phase out certain substances posing an unacceptable risk to human health and the environment
  • Restrictions imposed on new substances of highest concern as well as those rarely used or no longer ‘in commerce’ above 10,000 or 1,000 kg/year, but with the potential to become toxic
  • Rapid screening conducted for lower-risk chemical substances
  • Collaborative work between federal and regional governments, academia, industry, and international authorities in support of a robust information-gathering and risk-assessment approach in Canada

This is where industry can and has made a difference!

CPCA Regulatory Focus on Chemical Assessment

Industry is legally mandated to provide all relevant chemical data in its possession related to volumes, exposures and hazard-related information to help inform the federal Government’s risk-assessment of ‘chemicals of concern’ in commerce. CPCA ensures all implicated substances of concern are fully assessed for the CASE industry based on all relevant data to ensure the best possible outcomes. CPCA members continue to collaborate with Government for better outcomes.

In many cases Canada and the U.S. take different approaches on risk management and often Canada will take actions domestically that differ from the United States and other jurisdictions for various geopolitical reasons. As such, regulatory alignment of chemical assessment is always top of mind for manufacturers and chemical suppliers in Canada and multinational companies shipping to Canada.

No other Act of Parliament will have a more profound impact on chemicals used in thousands of CASE products in Canada over the next 5 years. What are you doing to help shape the outcomes of new regulations and how might changes impact your company? Every company must fully engage to have a robust facts-based regulatory change.

Download the Overview