Page 49 - CFCM Nov-Dec-2020 Final_Neat

from particular products or class of products. The ultimate reminded them of the fact that additives are usually
effect of a well-intentioned effort to protect oceans from incorporated at low concentration levels in products. And,
plastic must not result in causing irreparable harm to in the case of paint and coatings they also remain embed-
Canadian manufacturing and trade due to mischaracteri- ded in mixtures, within a matrix, and in the applied paint
zation of microplastics. film. This provides greater certainty with respect to the
Paint products contain intentionally added polymeric unlikely potential there will be releases and risks to human
forms with a size range of less than 5 mm, such as health and the environment.
microbeads, pellets or microfibers, which provide certain
desirable performance properties but have no possible COnCLuSIOn AnD RECOMMEnDATIOnS
pathways of release to the environment or inhalation CPCA’s main concerns and recommendations with respect
because they are “embedded” in the applied coating. Once to the federal government’s “Science Assessment of Plastic
the paint is applied as a film and fully dried, the microplas- Pollution” can be summarized as follows:
tics in the film are physically bound in a solid matrix.
Possible degradation of a paint film occurs due to a • It is critically important that the federal government
number of factors including weathering (UV light and hu- adheres to the long-established risk-based chemical
midity) and would only be significant when the paint is assessment process (CMP) for macroplastics and
applied on an exterior surface. In the case of degradation, microplastics, which has served Canada well over
the paint film breaks down into flakes or dust, many of many years.
which are in the size range that would label them as sec- • Data gathering, risk identification and assessment, and
ondary microplastics. However, the breakdown of individual appropriate risk management actions must be devel-
ingredients in a film is extremely unlikely. Moreover, there oped jointly with industry to accurately address specific
is currently no reliable evidence that exterior coatings are areas of concern with respect to sources and pathways
a significant contributor to secondary microplastics. of concern microplastic releases.
It has been suggested that consumer paint products, • Much more consideration must be given to a proper
with infrequent release of microplastics, may lead to down- definition of microplastics and the distinction between
the-drain releases, but these releases are estimated to be primary versus secondary releases.
less than one percent. Furthermore, the vast majority of • There has to be recognition of the fact that there is no
leftover paint is already recycled by waste recycling pro- scientific evidence that paint and coatings products
grams across Canada, which is paid for 100 percent by present a significant source of microplastic release to
manufacturers as part of the industry’s commitment to the environment and further research is required in
responsible product stewardship. CPCA strongly supports the area of film degradation and possible release
further research to identify pathways and frequency of pri- of microplastics.
mary and secondary microplastic releases. Based on the • For the overall research strategy supporting the
foregoing challenges there is widespread industry disagree- government’s risk assessment/risk management of
ment with government references to paint and coatings as plastics, industry must be an integral part of the
“one of the major contributors of microplastics.” There is planning and scoping of projects for risk assessment
no evidenced-based rationale for such an assertion. The especially with respect to alternative assessment
primary reason for such a belief is the fact that substances and informed substitution.
or mixtures – and their physical properties – are perma- • A multi-stakeholder expert advisory committee should
nently modified when the substance or mixture is used. At be established to assess, evaluate, prioritize and direct
the time of use it no longer falls under the meaning of a any proposed research on plastic pollution with a
microplastic and thus should be excluded from the scope clearly stated objective and scope.
of research on microplastics altogether.
The same can be said for food packaging. The federal The paint and coatings industry in Canada must stand
government’s report maintains that there is no conclusive on guard with respect to how this issue evolves. It is a po-
scientific evidence that food packaging materials, including litically charged subject related to plastic waste in our
food coating materials when used as intended, are a source oceans that has somehow morphed into a potentially neg-
of microplastics released in food or bottled water, which ative outcome for the chemical manufacturing sector, in-
may lead to health effects of concern. It must also be noted cluding paint and coatings, and this must be checked
that plastic additives are mostly not co-polymerized and sooner than later. n
thus less likely of being leached into the environment.
The report also includes flame retardants and phthalates as Gary LeRoux is President and CEO of the Canadian Paint and
part of these additives, some of which are found in paint Coatings Association www.canpaint.com
and coatings. CPCA has cautioned the government and

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