Advocacy

and Policy

The Role

 

of the World Coatings Council in Advocacy and Policy

The World Coatings Council provides a forum for information exchange and cooperation on the major issues and priorities facing paint and printing ink industries worldwide. The council acts as a focal point for monitoring and communicating specified international issues; develops recommendations and analyses on selected issues of common interest to the participating organizations and attempts to derive a common consensus position (considering information from policymakers in the governing bodies of the respective participants); coordinates industry positions and communicates with other international organizations, industry publications and other interested parties.

 

Marine Coatings 

The World Coatings Council (formerly the International Paint and Printing Ink Council, Inc., or IPPIC) is a formal contributor to the Lead Paint Alliance (LPA, formerly the Global Alliance to Eliminate Lead Paint), an organization established under the United Nations Environmental Program (UNEP) and the World Health Organization (WHO).

Since its inception in 2010, and with its reorganization in 2015, the LPA has been working to engage national governments, industry and non-governmental organizations in establishing restrictions on lead use in paints that pose public health and environmental risks, especially to children.

The current focus of the LPA is to seek government action restricting lead use in paint.  The council’s contribution to the LPA has been to highlight the widespread existing restrictions on lead use in paints and to encourage the adoption of similar restrictions by governments that currently have none.

In 2018, the council (then known as IPPIC) again reaffirmed its 2009 policy statement and updated it to reflect new global developments by the LPA:

“WCC notes the long-standing effectiveness of lead-use restrictions that are already in place in many jurisdictions around the world and recommends their widespread adoption by authorities not currently regulating the use of lead in paint and printing ink. To this end, IPPIC supports the UN’s Lead Paint Alliance “Model Law”, as a useful starting point for both government and industry to collaborate on developing restrictions that ensure widespread and verifiable compliance.”

The council and its members are encouraged by the continued advancement of LPA objectives, aided by the publication of the UN’s “Model Law”, detailed documentation of current effective restrictions, as well as a useful “toolkit” to help policymakers increase awareness and advance required restrictions.

As the LPA continues its efforts to address lead use in paint and coatings, the council also anticipates working with other LPA partners to assist in industry implementation efforts, this to ensure widespread and verifiable compliance.

For more information on the LPA and efforts to seek restrictions on decorative paints see:

https://www.unenvironment.org/explore-topics/chemicals-waste/what-we-do/emerging-issues/global-alliance-eliminate-lead-paint

 

 

Lead Paint Alliance (LPA)

The World Coatings Council (formerly the International Paint and Printing Ink Council, Inc., or IPPIC) is a formal contributor to the Lead Paint Alliance (LPA, formerly the Global Alliance to Eliminate Lead Paint), an organization established under the United Nations Environmental Program (UNEP) and the World Health Organization (WHO).

Since its inception in 2010, and with its reorganization in 2015, the LPA has been working to engage national governments, industry and non-governmental organizations in establishing restrictions on lead use in paints that pose public health and environmental risks, especially to children.

The current focus of the LPA is to seek government action restricting lead use in paint.  The council’s contribution to the LPA has been to highlight the widespread existing restrictions on lead use in paints and to encourage the adoption of similar restrictions by governments that currently have none.

In 2018, the council (then known as IPPIC) again reaffirmed its 2009 policy statement and updated it to reflect new global developments by the LPA:

“WCC notes the long-standing effectiveness of lead-use restrictions that are already in place in many jurisdictions around the world and recommends their widespread adoption by authorities not currently regulating the use of lead in paint and printing ink. To this end, IPPIC supports the UN’s Lead Paint Alliance “Model Law”, as a useful starting point for both government and industry to collaborate on developing restrictions that ensure widespread and verifiable compliance.”

The council and its members are encouraged by the continued advancement of LPA objectives, aided by the publication of the UN’s “Model Law”, detailed documentation of current effective restrictions, as well as a useful “toolkit” to help policymakers increase awareness and advance required restrictions.

As the LPA continues its efforts to address lead use in paint and coatings, the council also anticipates working with other LPA partners to assist in industry implementation efforts, this to ensure widespread and verifiable compliance.

For more information on the LPA and efforts to seek restrictions on decorative paints see:

https://www.unenvironment.org/explore-topics/chemicals-waste/what-we-do/emerging-issues/global-alliance-eliminate-lead-paint

 

 

Sustainability

The paint, coating and printing ink industries have a long history of sustainable practices and providing products that protect, sustain and add value to the built environment, our infrastructure, and the objects we depend on every day. The industry continues to reduce its environmental footprint and embraces sustainability by increasing resource recovery, reducing and eliminating hazardous emissions, offering products formulated to meet specific safety requirements, and being supportive of efforts to conduct “life-cycle analyses” that evaluate all of the relevant environmental impacts and benefits from preserving and protecting the global infrastructure.  The industry also addresses its social responsibility by creating health and safety programs to protect the workforce that manufactures its products and the communities that use paints, coatings and printing inks.

The World Coatings Council believes that sustainability programs should be developed and implemented by individual associations in a manner that allows for consistency and harmonization across the globe. National or regional paint and printing inks associations are the appropriate organizations to facilitate and help enhance sustainability programs on behalf of the members in their respective country or region. At the same time, The council believes it is essential that national associations create consistent messages and comparable metrics when implementing individual sustainability programs. By pursuing conformity, national associations will be able to compare best practices and indicators of performance, and ultimately, companies can reference consistent programs.

Transport of Dangerous Goods

UN Subcommittee of Experts on the Transport of Dangerous Goods

 

In order to ensure consistency between the regulatory systems in every country and every mode for the transport of dangerous goods, the United Nations has developed mechanisms for the harmonization of transport conditions for all modes for transport (TDG). This harmonization occurs in the SubCommittee of Experts on the Transport of Dangerous Goods (UNSCETDG).  https://www.unece.org/trans/danger/danger.htm  The result of this effort is the UN Model Regulations, which is used by many countries as the basis of the country’s TDG regulations.  The UN Model Regulations is currently in the 16th revision.

The UNSCETDG meets twice a year, in June and December, always in Geneva, Switzerland, to consider proposals from governmental and non-governmental delegations that will be incorporated into the UN Model Regulations.

In 2005, the World Coatings Council was granted Non-Governmental Organization status by the United Nations and is permitted to attend and participate in these meetings.
Participation in the council delegation to the UNSCETDG is open to those participating companies or country trade associations of the council.

Globally Harmonized System

UN Subcommittee of Experts on the Globally Harmonized System of Classification and Labeling of Chemicals (GHS)

In the 1990s, the United Nations Economic Commission for Europe embarked on a journey to design a universal chemical classification system for the entire world.  It was believed that a universal chemical classification system would help to decrease the number of accidents in the workplace and home environments resulting from improper use of chemical products.  It was also believed that a universal chemical classification system would decrease the cost of doing business around the world because in theory one label could be used for the same product sold in many different countries. The development and maintenance of the Globally Harmonized System of Classification and Labeling of Chemicals (GHS) was formally commissioned by the United Nations and assigned to the Subcommittee of Experts on the GHS (UNSCEGHS).

As noted above, the reasons for setting the objective of harmonization were many.  The UNSCEGHS operates with the goal that, when fully implemented, the GHS will:

  • Enhance the protection of human health and the environment by providing an internationally comprehensible system for hazard communication;
  • Provide a recognized framework for those countries without an existing system;
  • Reduce the need for testing and evaluation of chemicals; and
  • Facilitate international trade in chemicals whose hazards have been properly assessed and identified on an international basis.

The World Coatings Council sends representatives to the UNSCEGHS Meetings held twice annually in Geneva, Switzerland. At these meetings, the council’s representatives meet the environmental, health, and safety representatives from member countries who work on each revision of the GHS.  The council can submit white papers to support its member associations’ viewpoints on certain technical issues before the UNSCEGHS.  Input from council representatives has been well-received by the UNSCEGHS.

For more information:

https://www.unece.org/trans/danger/publi/ghs/ghs_welcome_e.html

 

Indoor Air Quality/Paint Emissions 

As a customer-oriented industry, the global paint industry has been actively engaged in research to better understand the impacts their products have on indoor air quality.  Scientific studies in Japan, the US and the EU have independently sought to characterize emissions associated with both the application and drying of indoor house paints, all to develop environmentally responsible products and to advise building occupants on the best way to mitigate potential indoor air quality concerns.

Remarkably, these independent research efforts have uncovered a common set of factors that, when taken together highlight a responsible approach to product safety that reinforces the industry’s right to operate.  This summary is provided to document these efforts and provide a sound basis for continued, progressive product stewardship.

 

Japan

 

The Japan Paint Manufacturers Association (JPMA) research effort on indoor air quality impacts from paint arose from initial government inquiries in 1997 centering around reports of “sick building syndrome” among occupants of new, energy-efficient buildings.  The concern at the time was that the use of common household products, including paints, carpets and cleaning products could be contributing to increased levels of indoor pollutants that, collectively impaired the health of building occupants.  The initial government concerns led to actions that sought to regulate the air quality in buildings, with specific emission limits specified for a wide range of building products, including paints, aimed at reducing potential exposure below acknowledged health thresholds.  The paint industry, represented by JPMA, used these critical thresholds as critical metrics for the testing, and eventual certification of industry products for use indoors.

Commensurate with industry efforts, the government in Japan has also tracked emissions from products in the indoor environment.  The Ministry of Land, Infrastructure, Transport and Tourism, reports that over time, there have been demonstrable improvements in indoor air quality in housing arising from industry efforts to offer lower-emitting building products, including paints.

In general, building products, including paints, increasingly have used less Volatile Organic Compounds (VOCs) in their formulation to meet the established emission limits.  By 2003, however, with overall VOC emissions significantly reduced, the focus of regulatory efforts for indoor air quality in Japan moved to formaldehyde emissions, and the building construction constraints necessary to reduce occupant exposures and health risks.  Over time, the testing program for indoor paints has focused almost exclusively on formaldehyde emissions.

Emerging engineering specification requirements for new construction and periodic maintenance supported establishing a paint emissions testing program to “certify” products suitability for use in the indoor environment.  Emissions testing was done by independent laboratories and the results enabled paint manufacturers to label their products appropriately. In establishing the voluntary product certification and testing program, JPMA and its member companies developed improved standard testing procedures that allowed for reliable results that properly directed product use through a simplified label program.

Over time, JPMA and its members have come to understand the critical features of a valid certification program for paints used indoors:

  • Industry determines the paint is applicable for potential indoor substrates
  • Formaldehyde release is properly measured
  • The measured release and emissions data indicates established safeguards are met
  • Periodic review of the certification program ensures test methods and comparatives are still protective of public health and the environment
  • Product labels convey the acceptable uses for the products, and are widely recognized and understood

In continuing the voluntary certification program, JPMA notes its success, with over 200 companies participating and over 5000 (total) certified products on the market in Japan.  Perhaps the most critical feature of the program in Japan is the collaborative nature of its genesis and management, combining the best elements of government sanctioned safeguards, acknowledged critical assessment criteria and testing, and industry commitment to support comprehensive implementation and market transparency.

 

European Union

 

For some time, academic and government researchers in the European Union and throughout the world have been studying the impacts of building products on indoor air quality.  Countless research studies have identified a wide range of potential sources for pollutants found indoors.  While these sources are widely acknowledged, specific standards for building practices relating to indoor air quality in Europe have initially focused on fixed construction materials (like wallboard, carpet and insulation) and not included interior house paints, which were viewed as “removable, replaceable or subject to re-application”.  While not subject to regulation under construction standards, VOC emissions from house paints is widely recognized as likely to occur and potentially contributory to indoor air quality.

While a wide array of regulatory approaches on indoor air quality operate in the EU member nations, in general all center around the interest of end users to obtain products, including indoor, decorative paints, that do not result in exposures more than an established Lowest Concentration of Interest (LCI), usually referenced to exposures encountered in the indoor environment 28 days after application. These LCI’s are established by national government agencies.

To better understand the impact of potential regulatory schemes using LCI’s, the European Association for the Paint, Printing Ink and Artist Colours Industries (CEPE) analyzed available data and offered some initial guidance on the types of products that might achieve the 28-day LCI’s.  Follow-up work is underway to collect additional data on products intended by the manufacture to meet low emission limits, including available manufacturer testing for a wide variety of paint products in commerce.

Over time, the collection and analysis of available industry data on emissions and indoor air quality is expected to provide important inputs for wider health, safety and environmental assessments including Life-Cycle Analysis (LCA) and the development of more detailed Product Environmental Footprint (PEF) profiles.

 

United States

 

In the United States, concerns for indoor air quality have been evolving over time as well, with multiple sources and pathways identified in much the same way as in the European Union.  Consensus testing programs for product emissions and indoor air quality impacts have also all centered around evaluating changes over time, usually 28 days.  This graph offers a semi-quantitative picture of the likely emissions profile of a typical indoor paint product, and the noted attention arrow emphasizes the need to evaluate continued exposures at 28 days:

 

While research studies continue to validate the 28-day testing protocol approach, new “green building” standards in the US are now requiring similar product emissions testing as part of specifications for a wide range of building materials, including architectural paints used indoors.  Embracing more practical testing methods, a 14-day emissions testing endpoint is now acknowledges because, for all practical purposes, observed emissions from paint drop off dramatically long before 28 days.

To help the paint industry understand and address these new standards, the American Coatings Association (ACA) undertook research using established “chamber testing methods” to evaluate emissions from typical indoor paints.  The goal of the research was to gain a deeper understanding of the impact of paint on indoor air and develop an informed technical position.  Critical too, was the development if an improved analytical method that fairly assessed coatings emissions, and use that method to develop data to support a robust predictive tool and/or model for paint and coatings manufacturers.  The long-term goal is to strengthen industry understanding of paint emissions and help position manufacturers to address emerging green building standards and future legislative or regulatory proposals on indoor air quality.

The results of ACA’s testing program affirmed several findings from research done in Japan and the EU.  The VOC content of nearly all indoor paints continues to be quite low, generally meeting the most restrictive standards established in the US.  Based on a “market basket” survey of indoor paint products, nearly 82% are likely to meet the lowest restrictive standard for emission criteria.  Finally, the ACA testing data shows that there is little correlation between VOC content of indoor paints and the emissions profile (especially in chamber testing taken out to 14 days).

 

CONCLUSIONS

 

These three efforts, each done independently in different parts of the world, and each following a different exploratory pathway, offer remarkably consistent pictures of assessing emissions from indoor paints.  The targeted research efforts underscore the importance of having consensus on important technical reference points for evaluating indoor paint exposure and developing product standards:

  • An acknowledged standard test method to evaluate both the VOC content of indoor paints (in general and for specific compounds) over a specific time (i.e. small chamber tests)
  • A clear indication from independent entities (i.e. government agencies) the profiled emissions coming from paints that are not considered a level of concern, and therefore should be achieved (by manufacturers as a minimum) to be protective of public health and the environment
  • The importance of widely communicating findings to industry, both to stimulate action and to assist in required advocacy

 

Titanium Dioxide in Paint

 

In February 2020 the European Commission codified its adoption of the 14th ATP concerning titanium dioxide (TiO2); classifying TiO2 containing greater than 1% respirable dust content by inhalation as a suspected carcinogen (Cat. 2). Following an eighteen-month transition period, the CLP regulation of TiO2 and TiO2 containing mixtures will be enforceable beginning October 1, 2021.

The result will be that products containing TiO2 will require new warnings.

For example:
• mixtures in powder form containing 1% or more of titanium dioxide which is in the form of or incorporated in particles with aerodynamic diameter = 10. This is likely to result in the vast majority of TiO2 powder mixtures being classified as they are likely to contain the requisite threshold percentage of powder form with the aerodynamic diameter less than 10µm. Such product labels would be required to identify TiO2 as a “Suspected of causing cancer” and include the GHS health hazard pictogram, below.

  • liquid mixtures containing 1 % or more of titanium dioxide particles with aerodynamic diameter equal to or below 10 µm will need to bear the following statement: “Warning! Hazardous respirable droplets may be formed when sprayed. Do not breathe spray or mist.”
  • solid mixtures containing 1 % or more of titanium dioxide (regardless of the presence of respirable dust) shall bear the following statement: “Warning! Hazardous respirable dust may be formed when used. Do not breathe dust.”
  • the regulation will also require changes to manufacturer safety datasheets (SDS);
  • The downstream impacts include potential for waste containing > 1% TiO2 by weight to be classified as hazardous waste, and new risk assessments under regulations for toys and cosmetics.

The TiO2 Category 2 cancer hazard classification by respirable dust inhalation is intended to focus upon the specific hazard where respirable dust exposures occur (i.e., exposure to particles less than 10 µm in diameter). This has led to the classification entry for TiO 2 being more complex than typical entries, containing several specific notes, annexes, and labels. Some of the terminology in the regulation is being used for the first time under CLP.

Due to the widespread use of TiO2, the regulation that will impose new labeling requirements for many products. The regulated community will be required to interpret and apply the various notes, and annexes of the regulation. Accordingly, the classification creates the potential for misapplication and confusion in the marketplace, complications for downstream users and processors and an impact upon global trade.

The Titanium Dioxide Manufacturers Association (“TDMA”) members filed a legal challenge seeking nullification of the TiO2 Classification before the EU General Court. Billions Europe Ltd. v. Commission. Two additional separate challenges were filed CWS Powder Coatings GmbH v. Commission and Brillux GmbH & Co. KG and Daw SE v. Commission.

Six pleas in the main action are:
a. Regulation was adopted in breach of several mandatory provisions of underlying regulation, specifically, TiO2 does not have the intrinsic property to cause cancer, and therefore could not be lawfully classified.
b. The Regulation breaches the principle of legal certainty.
c. Regulation was adopted in breach of the principle of proportionality, the classification is disproportionate to the aims it pursues.
d. The Commission incorrectly exercised its discretion and breached its duty of care, including reliance upon the RAC Opinion without an assessment of the probative value of such RAC Opinion.
e. The Commission breached its duty of sound administration, and the right of the applicants to be heard, the applicants were denied an adequate opportunity to comment meaningfully on the RAC Opinion itself, which significantly deviated from the original classification proposal both about the scientific rationale used and to the final conclusion on the classification of TiO2.
f. In adopting the Regulation without the prior conduct and documentation of an Impact Assessment, the Commission breached the principle of sound administration.

A joint petition to intervene in the action of ACA, the European Council of the Paint, Printing Ink and Artists‘ Colours Industry (CEPE), and the British Coatings Federation (BCF) was granted in February 2021. Briefing of the ACA, CEPE, BCF coalition is due to be filed by May 4, 2021.

The current expectation is that the EU Court will not rule on the matter until the second half of 2022.

 

 

Microplastics & Paint 

Increasingly, the use and fate of plastic materials is coming under scrutiny by government environmental agencies and academic researchers around the world.  This is due in large part to the widespread and highly visible problem of how to manage the large volume of discarded plastic containers and packaging products that end up in the waste stream.

These highly visible discarded materials in the environment are known as “macroplastic” wastes.   Policymakers around the globe are struggling to apply waste management principles, specifically stimulating efforts to “reduce, re-use and recycle” these materials, and meaningful waste management collaborations by diverse stakeholders are emerging.  Given the widespread and visible nature of this waste problem, these efforts are welcome, and all parties are hopeful, that a broad, long-lasting solution can be established.

Environmental researchers are focusing efforts on new categories of waste found in the environment, in some cases arising from use of a variety of plastic materials in formulations for consumer and industrial products.  The first major category is the so-called “primary microplastics” which refer to intentionally-added materials such as “micro-beads” or “microfibers” that provide certain desirable performance properties but without any attendant release[1] to the environment as they become embedded in the applied paint film.

The other major category is known as “secondary microplastics”, which have yet to be formally defined, but can best be described as the “polymeric fragments” released into the environment over time from plastic-containing products, largely through the degradation of larger (i.e. macroplastic) materials.  These secondary microplastics include releases from synthetic fibers in clothing (primarily from the laundering process), weathering of macroplastic wastes, degradation of polymeric surfaces (like paint) on exterior substrates, and wastewater streams that may receive discharges and/or releases of secondary microplastics from all sources.

Numerous studies on the environmental prevalence and fate of secondary microplastics have been published, but differ widely in how they have collected, characterized and quantified the sources and pathways of secondary microplastic releases.

In general, paint is a resinous product intended to provide a continuous protective or decorative film to a substrate, imparting desirable properties that last for a long time.   Extensive efforts are made to ensure economical transfer efficiency and to minimize loss of paint product to the environment during application and subsequent clean-up of application equipment (i.e. brushes and rollers).

All known mitigating factors need to be considered in any effort to quantify the potential release of microplastics from products.  This is especially true for academic researchers, government agencies and advocacy groups as they work to address concerns regarding microplastics in the environment.  For its part, the paint industry stands ready to advance its understanding of the issue and our commitment to product stewardship.

 

Biocides 

The term “biocides” has come to encompass a wide range of materials that control the growth of unwanted, deleterious microorganisms in the environment.  Purification of drinking water sources, cleaning contaminated surfaces in our homes and offices, sanitizing dishes and cookware used in food preparation, sterilizing surgical instruments and treating serious wounds or simple cuts have all become part of the public trust, reinforcing the absolute need for effective biocides to support public health, safety and environmental protection.

The widespread use of biocides in construction products, however, has resulted in increased scrutiny of their inherent safety.  The paint and coatings industry acknowledges the need to maintain proper safeguards when using biocides, and cites a long history of effective collaboration with government to protect public health and the environment, and ensure effective policies for biocide use that support continued availability.

Microbial attack (i.e. mold and mildew) on painted surfaces is a wide-ranging and universal concern that has resulted in a global, coordinated strategy to combat it.  The participants in this effort include the companies that make biocides, paint manufacturers – who add biocides to their products, users of paints containing biocides – who have come to expect the efficacy of these products to protect the painted surface and maintain desired conditions, and the government agencies charged with protecting public health and the environment – who provide oversight and continued scrutiny of the safety and effectiveness of biocidal product use in paints and coatings.

The impact of microbial growth is not limited to degradation of applied paint films, but also occurs during production and storage of paints and coatings.  Increasingly, paint products have embraced waterborne technology, using formulations that are low in volatile organic compounds (VOC’s) with lower emissions during application and drying.  As with most waterborne products, paints require the use of “in-can” preservatives to protect them from spoilage.  Without these biocides, waterborne paints would spoil in storage. In extreme cases, the microbial decomposition can generate gases that rupture the container.

The importance of biocides use for in-can preservation and microbial attacks cannot be understated.  It is a fact that over the past 75 years, market growth and public acceptance of waterborne paints and coatings has only been possible with the use of biocides.  In the efforts to protect waterborne paints from microbial growth, manufacturers have enhanced plant hygiene and developed work practice controls that ensure product integrity throughout the supply chain.  These efforts are part of a holistic approach to microbial control that ensures protection, but also optimizes the use of biocides to a level that is necessary to do the job.

Additional specialized uses of biocides in certain paints and coatings are critical to protection of the substrates to which they are applied.  Wood preservative materials are used to suspend the growth of microorganisms and other lifeforms that are associated with the destruction of wood and wood structures. Marine and offshore protective coatings are used to reduce the growth of marine microorganism and associated biofilms that degrade vessels and steel structures, and slow their propulsion through the water.  Both uses are highly regulated and face increased and stringent regulatory controls whereby end users, paint manufacturers, and the producers of the biocides (i.e. active ingredients) work closely with government agencies to ensure safe use, and supports new ideas that help advance consumer protection and reinforce safe use of biocides in paints and coatings.