CPCA is pleased to provide…

CPCA is pleased to provide feedback on behalf of the paint and coatings industry in Ontario on the draft HSP Regulation posted on the Environmental Registry of Ontario on February 11, 2021 (ERO number: 019-2836). CPCA is a not-for-profit industry association representing the interests of manufacturers and suppliers in the paint and coatings industry in Canada. The industry retains the services of program operators for paint waste recovery and recycling in all ten Provinces and for Ontario that is Product Care Association (PCA). PCA has represented the paint and coatings industry under the current MHSW program in Ontario since 2015 per an Industry Stewardship Plan (ISP) under the Waste Diversion Act.

Since PCA began managing the paint recycling program it has collected more than 53,800 tonnes of paint, recycled more than 31,000 tonnes of paint, including metal and plastic paint cans and paint pails, as of year-end 2020. Product Care actively worked with the producers and increased accessibility by more than 50%since taking over the program. The program inherited 277 municipal and return-to-retail sites in 2015 increasing the number to 424 collection sites by the end of 2020. Municipalities manage their own events and in 2019 there were 298 municipally run events. Product Care continues expanding the collection network in 2021 and is also adding new metal paint collection bins starting in April 2021, which will see a more secure and user safe paint collection container its collection system.

PCA has successfully operated the waste recycling program for paint in Ontario with a robust collection system that we hope can continue under the new HSP regulation. However, we believe there are fundamental changes required to the draft HSP regulation that will ensure a strong paint recycling program can continue to run efficiently, with minimal administrative burden, while continuing to achieve strong waste recycling outcomes. We believe those changes will live up to the key principles noted in the consultation document under “Proposal Details”.

We would be pleased to discuss any of the recommendations contained in our submission should you require further clarificat