Proposed Code of Practice for 2-Butanone, Oxime (Butanone Oxime) Associated with the Interior Application of Consumer Alkyd Paint and Coating Products
January 26, 2013
Document for Public Comment
Consultation period ends March 27, 2013
Table of Contents
- 1.0 Purpose of consultation
- 2.0 Introduction
- 3.0 Background
- 4.0 Next Steps
- 5.0 References
- Annex A
- Proposed Code of Practice for 2-Butanone, Oxime (Butanone Oxime) Associated with the Interior Application of Consumer Alkyd Paint and Coating Products
1.0 Purpose of consultation
The purpose of this consultation document is to:
- Inform interested stakeholders of the proposed Code of Practice for 2-butanone, oxime, as published on January 26, 2013 in Canada Gazette, Part I, and
- Provide an opportunity for interested stakeholders to comment on the proposed Code of Practice.
2.0 Introduction
The Chemicals Management Plan was launched by the Government of Canada on December 8, 2006. A key element in the Chemicals Management Plan is the initiative known as the "Challenge", in which approximately 200 substances identified as high priorities for action have been divided up into twelve smaller groups of substances, or batches, which are being addressed sequentially.
The substance 2-Butanone, oxime, Chemical Abstracts Service Registry Number (CAS RN) 96-29-7, also known as butanone oxime, was included in Batch 7 of the Challenge under the Government of Canada's Chemicals Management Plan.
3.0 Background
3.1 Final Screening Assessment Report
In the final Screening Assessment Report for butanone oxime, published in the Canada Gazette, Part I on March 6, 2010 (Canada, 2010), the potential inadequacy of the margins between estimated exposures to butanone oxime and critical effect levels lead to a conclusion that butanone oxime is a substance that may be entering the environment in a quantity or concentration or under conditions that constitute or may constitute a danger in Canada to human life or health and therefore meets the criterion in paragraph 64(c) of CEPA 1999. It did not meet the criteria in paragraphs 64(a) and (b) (is not entering the environment in a quantity or concentration or under conditions that have or may have an immediate or long-term harmful effect on the environment or its biological diversity or that constitute or may constitute a danger to the environment on which life depends).
3.2 Risk Management Approach Document
The Proposed Risk Management Approach for butanone oxime published in March 2010, outlined that the Government of Canada was considering a restriction on the concentration of butanone oxime in indoor alkyd paints available to consumers (Canada, 2010).
Following the publication of the Risk Management Approach document, information received indicated that modifications to the proposed Risk Management Approach should be considered. Industry stakeholders indicated that the current concentrations of butanone oxime in consumer alkyd paint and coating products were the lowest possible level to remain effective for their intended applications. In addition, since the publication of the Risk Management Approach document, significant changes to the consumer alkyd paint and coating market in Canada have taken place and are continuing to take place. For instance, the Volatile Organic Compound (VOC) Concentration Limits in Architectural Coatings Regulations (Canada, 2009) which took effect in September 2012 for many product categories has begun to result in decreased production of and access to consumer paint and coating products containing butanone oxime.
Upon consideration of this information, a voluntary Code of Practice to be issued under section 55 to meet the requirements under section 91 of CEPA is proposed to achieve the risk management objective through labeling instructions which are intended to reduce inhalation exposure to butanone oxime in the remaining interior alkyd paint and coating products available to the general public. It is estimated that the remaining alkyd paint and coating products, including stains, will represent less than 5% of the overall annual sales of architectural paint and stains available to consumers.
The Risk Management Approach document also recommended adding butanone oxime to the Environmental Emergency Regulations; however, assessment under Section 200 of CEPA 1999 concluded that butanone oxime did not meet the criteria for adding it to the regulations.
3.3 Alternatives
In 2003, the Danish Environmental Protection Agency undertook a project to investigate the possibilities for substituting butanone oxime in air-drying coatings (Denmark 2003). The research concluded that although further work is required, success in substituting butanone oxime seems rather limited. Acetone oxime, though promising as an alternative, was reported to have some concerns regarding health effects as well. Vitamin E was identified as needing further investigation, since it presents the best health profile of all the investigated compounds. Amino/amido compounds use might be limited due to their genotoxic potential (Danish Environmental Protection Agency, 2003).
3.4 Existing Risk Management Activity
In Canada, butanone oxime is subject to the Pest Control Products Act. It is categorized as a List 2 Formulant on the Pest Management Regulatory Agency (PMRA) List of Formulants, which was published on June 28, 2007. A List 2 designation elevates the priority for reassessment within the PMRA (Canada 2007).
All import, manufacture and/or use of butanone oxime in the United States must be reported under the U.S. EPA, Part 799, Identification of Specific Chemical Substances and Mixture Testing Requirements, January 2008 (USA 2008).
In order to meet the ecological criteria for the award of the European Union Ecolabel to indoor paints and varnishes, based on the Commission Decision of 13.8.2008, butanone oxime in alkyd paints must not exceed a limit of 0.3% (European Commission 2008).
Under the Environmental Protection Authority (New Zealand), butanone oxime is identified as a hazardous substance and is subject to relevant Hazardous Substances and New Organisms controls (New Zealand 2004).
3.5 Proposed Risk Management - Code of Practice
This proposed Code of Practice will outline specific information to be added to the labels of relevant products with an aim to change consumer behavior to help reduce air concentrations of butanone oxime during and immediately following interior application of consumer alkyd paint and coating products.
4.0 Next Steps
Please submit comments on the proposed Code of Practice presented in Annex A of this consultation document by March 27, 2013.
The Government of Canada is committed to providing interested and affected parties with the opportunity to take part in consultations at all stages of the proposed Code of Practice's development. All comments submitted will be taken into consideration while drafting the final Code of Practice. The Government of Canada welcomes the distribution of this consultation document to any interested and affected parties.
Pursuant to section 313 of CEPA, 1999, any person who provides information to the Minister of Environment may submit with the information a request that it be treated as confidential. Comments and information submissions on this proposed Code of Practice should be submitted either by e-mail, mail or fax to the following addresses. Please type: "Consultation on Proposed Butanone Oxime Code of Practice" in the subject line of your message.
Mrs. Astrid Télasco
Director
Products Division
Environment Canada
351 Saint-Joseph Boulevard, 9th Floor
Gatineau, Quebec
K1A 0H3
Telephone: 1-888-391-3426 or 819-953-9322 (Local)
Fax: 1-888-391-3695 or 819-953-3132 (Local)
Email: Products.Produits@ec.gc.ca
Following the current consultation, comments received will be considered during the development of the final Code of Practice. The final Code of Practice will then be published in the Canada Gazette Part I, and on the Health Canada web site. Please note that there is no comment period after such a publication.
5.0 References
[Canada], Environment Canada, Health Canada. 2010. Final Screening Assessment Report for 2-Butanone, oxime (butanone oxime) (CAS RN 2426-08-6).
[Canada], Environment Canada, Health Canada. 2010. Proposed Risk Management Approach for 2-Butanone, oxime (butanone oxime) (CAS RN 2426-08-6).
European Commission. 2008. Commission Directive 2009/544/EC of 13 August 2008 establishing the ecological criteria for the award of the Community eco-label to indoor paints and varnishes (notified under document number C(2008)4453).
[New Zealand]. Environmental Protection Authority. Controls applying to butanone oxime, New Zealand.
[USA] United States of America. 2008. US EPA, Part 799, Identification of Specific Chemical Substances and Mixture Testing Requirements, January 2008, Title 40, Volume 31.
Annex A
Glossary of Terms
- CEPA 1999
- Canadian Environmental Protection Act, 1999
- Manufacturer
- A person that produces or prepares butanone oxime and has responsibility for labeling applicable products.
- Importer
- A person that participates in importing butanone oxime and has responsibility for labeling applicable products; import includes movement into Canada, as well as internal company transfers across the Canadian border, but does not include transit through Canada.
- User
- A person that sells, distributes or repackages butanone oxime and has responsibility for labeling applicable products (does not include import and manufacture).
- Consumer Product
- For the purpose of this proposed Code, a consumer product is a product that may reasonably be expected to be obtained by an individual to be used for non-commercial purposes.
- Interior consumer alkyd paint and coating products
- Alkyd paint and coating products that are consumer products and that are to be used for interior applications.
- Dual use consumer alkyd paint and coating product
- Alkyd paint and coating products that are consumer products and that may be used for interior or exterior applications
Proposed Code of Practice for 2-Butanone, Oxime (Butanone Oxime) Associated with the Interior Application of Consumer Alkyd Paint and Coating Products
Purpose of Code of Practice
1. The purpose of this proposed Code of Practice (herein referred to as the "proposed Code") is intended to reduce inhalation exposure to butanone oxime by the general public during interior application of consumer alkyd paint and coating products. This proposed Code will outline information that should be added to the labels of consumer alkyd paint and coating products with an aim to change consumer behaviour to help reduce air concentrations of butanone oxime during and immediately following interior application of alkyd paint and coating products.
Background
2. The substance butanone oxime, Chemical Abstracts Service Registry Number (CAS RN) 96-29-7, is part of the chemical grouping discrete organics and the chemical sub-grouping oximes, or more specifically, ketoximes. Butanone oxime was included in Batch 7 of the Challenge under the Government of Canada's Chemicals Management Plan.
3. The most prevalent use of butanone oxime is as an anti-skinning agent in the formulation of alkyd paints, primers, varnishes and stains. Anti-skinning agents are added to prevent air-dried coatings from forming hard, congealed films on the surface of the coating during storage by preventing the drier effect until application of the coating. In closed containers, the oxidation and skin formation takes place due to the presence of air between the coating surface and the closed lid. Butanone oxime is the most used anti-skinning agent in paints and is a volatile type of anti-skinning agent (i.e. will be volatilized from a formulation upon application to allow drying) (Danish Environmental Protection Agency, 2003). The use of anti-skinning agents is a compromise between preventing skinning and retaining an adequate drying potential of the coating after application. The cross-linking should be as slow as possible during storage and then regain its full drying potential as soon as possible after application. As such, for drying performance, it is preferable that a minimum amount of anti-skinning agent is used (Danish Environmental Protection Agency, 2003).
Elements of Exposure Mitigation for the Interior Application of Consumer Alkyd Paint and Coating Products
4. A study by Chang et al (1998) examined emissions of butanone oxime following application of interior alkyd paint products. This study and a publication on healthy indoor painting practices (US EPA, 2000) have been considered in the development of label statements that will serve to guide the general public on actions intended to reduce indoor air concentrations.
5. Mechanisms to reduce exposure to butanone oxime during and following interior application of consumer alkyd paint and coating products include:
- Increasing ventilation in work area during painting. Maximizing the ventilation and releasing exhaust air to outdoors may result in a reduction in air concentrations of butanone oxime during the work period.
- Using continued ventilation may result in a more rapid decrease in air concentrations of butanone oxime after painting.
- Reducing the concentration of butanone oxime in interior consumer alkyd paint and coating products to lowest level technically feasible.
Applicability
6. This proposed Code applies to all manufacturers, importers and users of butanone oxime in Canada that have responsibility for labeling applicable products (e.g. brand owner), specifically alkyd paint and coating products containing butanone oxime to be sold as a consumer product for interior use.
Applicable Products
7. The label instructions outlined in paragraph 10 of this proposed Code of Practice should apply to the following products:
- Interior consumer alkyd paint and coating products
- Dual use consumer alkyd paint and coating products
Products Excluded from the Proposed Code
8. Consumer alkyd paint and coating products clearly labeled exclusively for exterior application should not be subject to this proposed Code.
Best Practices and Label Statements
9. Reduce concentration of butanone oxime to lowest achievable levels: To achieve reduced indoor air concentrations of butanone oxime, interior consumer alkyd paint and coating products should contain the lowest possible level of butanone oxime necessary to remain effective for their intended applications.
10. Label Statements for Increased Ventilation: In order to help achieve reduced indoor air concentrations the label should outline the following:
- If not already required under the Canada Consumer Product Safety Act (CCPSA): "USE ONLY IN WELL VENTILATED AREAS"
- "OPEN WINDOWS OR BLOW AIR OUTDOORS WITH FAN."
- "CONTINUE VENTILATION FOLLOWING APPLICATION."
Declaration
11. Manufacturers, importers, and users of butanone oxime in Canada who intend to implement the labeling measures in this Code of Practice are advised to communicate, in writing, their intention to the Minister of Health no later than six months after publication of the Code of Practice or six months after they start to use butanone oxime in their products. The Minister of Health should be notified in writing when those subject to this proposed Code permanently cease to use butanone oxime in the applicable products.
Record Keeping and Reporting
12. Record Keeping: It is recommended that the electronic or paper records be maintained at the company principal place of business in Canada, for a period of at least five years after they are made. These records should include the following information:
- A copy of each label for consumer alkyd paint and coating products manufactured, imported or used that are subject to this proposed Code.
- The name and civic address of each facility where the Code of Practice is being implemented.
13. Reporting: Manufacturers, importers and users of butanone oxime who intend to implement the labeling measures in this Code of Practice are advised to provide the records specified in paragraph 12 to the Minister of Health three (3) years following the publication of the final Code of Practice and upon request.
14. The person submitting the records should specify the civic address at which the records, reports and other information can be inspected and identify each facility to which each of those records, reports and other information pertains.
Contact Information to Submit Declarations and Reports
15. Declarations and reporting submissions should be submitted to the Minister of Health either by mail, email or fax to the following addresses. Please type: "Consultation on Proposed Butanone Oxime Code of Practice" in the subject line of your message.
Mail: Chemical Substances Web site
c/o Health Canada
269 Laurier Avenue West, Address Locator 4905B
Ottawa (ON) K1A 0K9
Fax: 613-952-8857
16. Any person who provides information to the Minister of Health, with respect to this proposed Code of Practice, may submit with the information a request that it be treated as confidential and that request will receive appropriate consideration.
Verification
17. In order to evaluate the effectiveness of this Code, the Minister of Health may request the records specified in paragraph 12 at any time and may conduct periodic evaluations to help determine if other risk management measures are needed to further reduce inhalation exposure to butanone oxime by the general public during interior application of consumer alkyd paint and coating products.
References
Chang, John, C., Zhishi Guo, Leslie E. Sparks, (1998). Exposure and Emission Evaluations of Methyl Ethyl Ketoxime (MEKO) in Alkyd Paints, Indoor air: 8: 295-300.
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