ILPPWA Report 2020 from Eco-Accord, Russia

IN PAINT MATERIALS:

FOR HUMAN HEALTH AND

SUSTAINABLE DEVELOPMENT

Webinar, October 26, 2020

Summary of the discussion

Olga Speranskaya, IPEN / Eco-Accord, described the activities of the International Pollutants

Elimination Network (IPEN) in monitoring lead in paint in various countries and the work to develop

legislation to ban lead in paint. Since 2008, 59 countries have been involved in IPEN's campaign to

eliminate lead in paint, including 9 out of 12 countries in Eastern Europe, Caucasus and Central Asia.

Over 3,500 paint samples have been analysed. The results showed the presence of lead in at least 30% of

paint samples taken from each of the participating countries. According to Olga Speranskaya, a WHO

legislative study, shows that lead paints are still used in many countries despite the global goal of phasing

out these paints by 2020. As of 31 May 2020, 39% of countries confirmed that they had legally binding

controls over lead paints. However, many of these regulations are not sufficiently protective as they

contain exemptions, weak restrictions or are not enforced.

countries, except Russia, agree with this. Some Russian government agencies and industry still have

questions about why 90 ppm is proposed, as well as concerns that the transition to the new standards will

require major changes in production technology. The length of the period required for transition to the

new regulations is also a discussion issue. It was agreed that the Russian Federal Service for Surveillance

on Consumer Rights Protection and Human Wellbeing (Rospotrebnadzor) would present its official

position and that the Russian paint and varnish industry would also justify its position. It is expected that

the next meeting on the Technical Regulations will develop an agreed position on this issue - and this

meeting is likely to be the final one.

Dr. Khalidya Khamidulina, Director of the Russian Register of Potentially Hazardous Chemical and

Biological Substances. (Russian Register) of the Russian Federal Service for Surveillance on

Safety of Paints cannot come into force before the end of 2022. Therefore, we have enough time - at least

two years + 36 months, and a lot can be done during this period. We cannot stretch the process for

decades. Just a small number of manufacturers in Russia still use lead. Most paints on the Russian market

contains no lead.

"We are sounding the alarm, as we have a sad example of the implementation of the Rotterdam

Convention on the Prior Informed Consent Procedure for Certain Hazardous Chemicals and Pesticides in

International Trade, for which Rospotrbnadzor is responsible and for which the Russian Register is a

special authorized body," Kh.Khamidulina stressed. - We see how many substances that are banned or

severely restricted in the EU, China, Serbia and other countries around the world enter the Russian

market for the simple reason that we do not regulate these chemicals in any way. It is easier to regulate

where these products are allowed. Therefore, as Khamidulina stressed, we have deep concerns that we

could become a lead paint dump.

Earlier, during the discussion of lead-related regulations, many questions were raised about how lead in

paint could be controlled. Kh.Khamidulina noted that this problem is now being solved. At the initiative

of the Russian Register, the development of guidelines for the control of lead in paint has been included

in the Plan for the development of regulatory and methodological documents of Rospotrebnadzor for the

next year. Thus, by the time the implementation of technical regulations begins, the document will be

approved. If it is necessary to formalize it as an interstate standard (GOST), the Russian Register is ready

to do so.

Mr. Sergei Fedotov, President of the Russian Paint Quality Association (RPQA) noted with

the main of which is the difficulty of controlling the quality of raw materials for small and medium-sized

enterprises, which form the basis of the Russian paint industry: while the RPQA member companies are

large enough and have their own well-equipped laboratories, hundreds of small decorative paint

companies do not have the financial or human resources to test the incoming raw materials for lead

content. According to Fedotov, these companies are unable to effectively conduct the quality control of

raw materials and cannot obtain information on the content of lead and other ingredients in raw materials

supplied from South-East Asia, Western Europe and North America. The documents accompanying the

raw materials for paint manufacturing often do not contain this information. After all, if testing the end

product reveals an increased lead content, this is blamed on small paint manufacturers, whereas in reality

it is the result of a poor quality control system for the raw material, which allows for the import of lead-

contaminated components. According to Fedotov, this not only concerns lead, but also volatile organic

will take to provide all regional centres with the necessary equipment. This is not an easy task and there

is doubt that it will be done in 36 months. But if we have outlined this path, we must follow it.

Mr. Gennady Averyanov, President of the Tsentrlak Association, one of the oldest associations of

paint and varnish industry enterprises, believes that Russia has had a coherent system of market

regulation for paints and varnishes, which includes Unified Sanitary Requirements, GOSTs and Sanitary

Regulations, and is currently developing the EAEU Technical Regulations on the safety of paint. The

standard for lead content in paints and varnishes is quite high (5000 ppm), and our enterprises work as

Rospotrebnadzor allows us to.

Averyanov believes that the situations in the paint and varnish industry in Russia differs from the

situation in Europe and the USA where giant paint manufacturers are located. Russian enterprises are not

represented in the Global Lead Paint Alliance and the recommendations of the Alliance are not suitable

for the Russian paint industry. According to Averyanov, the Model Law does not reflect the specifics of

Russian situation - there are analysts from Africa, Asia and the Caribbean, but not from our country. We

do not know if our paints really affect the health of our people and children. According to materials

provided by the Alliance, dry paint can crumble and sneak into dust, which can enter the body of a child.

But we have no proof that toys painted with our colours can poison children even if they suck on them.

standard varies from 100 ppm to 600 ppm in some countries.

imported pigments from the EU and the USA, the cost of which is approximately 6 times higher than that

of pigments from BRICS countries. Meanwhile, we now have 70% of raw materials from the BRICS

countries and 30% from the EU.

Analysis conducted by Centrallak shows that 90 ppm standard of lead content in paint will be a shock to

the Russian paint industry: companies will not be able to control the compliance, there are no methods,

equipment and lab specialists available. In the meantime, the costs of the final products will increase, and

their competitiveness will decrease. According to Averyanov, the Rospotrebnadzor system also has little

control over the market. It is therefore necessary to approve the 500 ppm standard at this time, while

stricter standards will be applied at a later stage when all necessary technical prerequisites will be met.

G.V.Averyanov expressed no concern about the flooding of the Russian market with lead-contaminated

paint. In his opinion, the share of imported materials in the Russian paint and varnish market is only 10-

Mr. Pavel Filatkin, Deputy Director of the Department of Chemical and Technological Complex

and Bioengineering Technologies of the Ministry of Industry and Trade of the Russian Federation,

periods, the duration of which can be discussed, to find consensus. Even in Europe, the transition to the

new standards takes considerable time.

Filatkin reminded that on 2 October 2020 the Government of the Russian Federation approved the

National Action Plan to ensure the restoration of employment and income, economic growth and long-

term structural changes in the economy. In this document there is a special section devoted to the

postponement of entry into force of normative legal acts in the sphere of technical regulation. As Filatkin

explained, this is due to the fact that the Government understands that in the current situation it is not

quite right to make any sharp moves to tighten requirements. Therefore, the representative of the

Ministry of Economy agrees with industry representatives that it is necessary to approach this issue very

carefully and, of course, transition periods are necessary.

In the discussion, Olga Speranskaya commented on the control of the quality of children's goods by

Rospotrebndzor. She spoke about the research conducted by the Eco-Accord, which revealed significant

heavy metal contamination of children's toys purchased in Russia. She noted that lead concentration in

some toy samples was several times higher than the corresponding Russian standards.

Gennady Averyanov expressed regret that, in his opinion, non-governmental organisations do not hear

industry concerns. Meanwhile, in his opinion, it is necessary to know the production process and listen to

the industry representatives, because a doctor cannot cure a patient without knowing his body. He

suggested going down to earth and building the relationships with industries that fill the budget, provide

employment and produce good quality paints. If someone violates the law, such producers must be fined

by Rospotrebnadzor. The percentage of violations that are recorded is relatively small. Deviations can be

According to G.V.Averyanov, there are potboilers in all countries, but it is necessary to follow an

evolutionary path, not a revolutionary one. "We survived 1917, we survived the 1990s, when everything

stopped," said Averyanov, and we do not need such shocks anymore".

He stressed that the Technical Regulations are just one of the links in the chain for regulating lead in

paint. A quality control system for raw materials needs to be put in place that small businesses themselves

are unable to implement - perhaps by creating a register of hazardous chemicals where they all need to be

a workshop on this topic for Eastern Europe, Caucasus and Central Asia held in Almaty and lost an

excellent opportunity to learn about the work of the Alliance and provide input to the international

Khalidya Khamidulina considers it necessary to maintain a balance between the need to develop the

economy, preserve jobs and protect the health of the population. She urged to tackle the problem

constructively, introduce transitional periods, strive for better standards, and seek compromise on these

material as soon as possible.

All the participants in the discussion expressed high appreciation of the event and agreed that such a

dialogue is very important for all stakeholders. It is important to listen and hear each other and be able to

find a compromise.