0ba0c9c5_t_Red_104___Environment_Canada_Summary_table_Response
[Topic] Substitution and alternatives [Comment] The manufacture, use, release and disposal of lead chromate pigments in Canada are regulated through the complete life cycle in Canada. Termination or unnecessary additional restriction on the production of lead chromate pigments would unnecessarily impact a number of high paying manufacturing jobs in Canada. The impact of such restrictions must be analyzed against the gain in safety or environmental protection, which, in the case of lead chromate pigments would be minimal or nonexistent. There are potential alternatives, but not one for one substitutes for lead chromate pigments. The alternative products require tradeoffs in performance characteristics and in formulation with multiple replacement ingredients for final products. When cost is considered there are no substitutes which perform equivalently to C.I. Pigment Yellow 34 or C.I. Pigment Red 104 in most product formulations. [Response] 
The Government of Canada does not intend to restrict the use of lead chromate pigments for specialized technical purposes for which there are no suitable alternatives.
Public comments for C.I. Pigment Red 104 - Environment Canada