Page 37 - CFCM May-June 2021_Neat

many SMEs were not fully aware of the impacts of lower limits being companies, operating large production lines, have had to make con-
applied in Canada because they have not yet had to deal with chal- certed efforts to meet Canada’s existing VOC limits. It won’t get any
lenges in complying with OTC Phase II limits, as some larger easier with new limits imposed.
member companies have in the United States. However, CPCA was In the U.S., CARB VOC limits have accommodated industry
able to obtain significant technical feedback on the main categories concerns in product categories such as Industrial Maintenance,
believed to be of most concern to industry, as well as estimates of Zinc Rich Primers, Metallic Pigmented, Rust Preventatives, Con-
what might be acceptable implementation deadlines should govern- crete Cure, and Graphic Arts coatings. Limits in these categories
ment proceed with the new AIM VOC limits. cannot be lowered any further without negative consequences
One of the key recommendations made by the Canadian coatings related to both safety and lifecycle challenges, which will increase
industry was the need for the federal government to take into consid- emissions somewhat rather than lower them. These coatings are
eration that Canadian SME operations will require more time to critical to protecting and extending the life of infrastructure
cope with new VOC limits, and, must account for the already low exposed to the extremes of Canadian climate.
VOC limits used in the majority of water-based products. This is The industrial maintenance category is very important for the
especially the case for the strict California VOC limits, as well as the protection of water and wastewater treatment plants, pipelines,
time needed to reformulate products to meet new specifications. In wind turbines, bridges, and high-performance exterior metal sur-
light of the obvious challenges for the Canadian economy over the faces subject to corrosive atmospheres. The proposed 100 g/L limit
past two years, such an initiative would place greater strain on SMEs for the industrial maintenance category is not feasible for these ap-
who may have to abandon successful product lines or shut down plications. These require high-performance products that cannot
completely. This would not be good for the Canadian economy as it simply be switched to water-based technology without sacrificing
struggles to rebound from a very challenging year and replenish key performance characteristics that will not decrease users’ envi-
revenues and job losses throughout the pandemic.
CPCA members identified 22 product categories that are
particularly problematic should the federal government move
forward with new VOC limits based on CARB 2019. Several of
these are briefly described below. Significant challenges will ensue
for specialty products applied in a Nordic climate especially related
to latex and alkyd-based coatings. There must be more attention paid
to the lifecycle of products in a Canadian climate, which exposes
coatings to low temperatures, salt, high humidity, and degradation by
rain and snow. In particular this applies to all solvent-based product
categories such as rust preventative coatings, solid stains, primer,
floor enamel, driveway sealers, and concrete sealer. They will all be
extremely difficult to reformulate under the new limits without
losing significant product performance.
The most impactful technical difficulties associated with CARB
and SCAQMD limits strongly suggest that Canada should first adopt
OTC Phase II limits rather than CARB 2019. CPCA re-emphasized
the fact that only six states in the U.S. have adopted OTC Phase II
rules as of the end of 2020. Additionally, only four California districts
have adopted the 2019/2020 SCM and most of these California dis-
trict rules include a coming-into-force date of January 1, 2022. The
adoption of CARB 2019 limits in Canada would put Canadian com-
panies ahead of the vast majority of U.S. neighbor states, which
would cause significant disruptions to cross-border trade. It may
also lead to increased cross-border retail trade, i.e., Canadian buyers
(consumers, contractors) crossing to U.S. neighbor states to pur-
chase products with higher VOC limits to achieve the performance
characteristics customers have come to expect, especially related to
the safety benefits.
Even multinational companies based in Canada, and shipping to
Canada, want their business to thrive. Multinationals, both U.S. and
Canadian, represent the major portion of AIM coatings sold in
Canada and they are always striving to meet the lowest North Amer-
ican VOC limits in their product offerings. However, even the largest

WWW.CFCM.CA CANADIAN FINISHING & COATINGS MANUFACTURING 37