Treated pine

CCA treated timber, or treated pine as it is known in Australia, has been the subject of intense scrutiny for many years. It is ubiquitous in the Australian environment with many uses, including:

• Posts for the viticulture industry (the largest user of treated pine products in Australia)
• Children’s playground structures
• Aquatic uses
• Trellis, sleepers, fencing, decking and picnic tables for home garden use

CCA treated pine is impregnated with a combination of three chemicals, chromium, copper and arsenic. The wood preserving industry always insisted that this process locked the arsenic into the timber, making it highly unlikely that toxic amounts leached into the environment. However, this was not the opinion of some sections of the scientific community and environmental NGOs. In fact, there has been a growing body of published scientific evidence stating that arsenic does in fact leach from CCA treated timber, in amounts that are not only detrimental to the environment, but also pose a threat to the health of animals, aquatic species and humans.

Dr Gary Ginsberg (US Toxicologist) explains

Arsenic is a known human carcinogen and has been linked to nervous system damage and birth defects. According to the National Academy of Sciences, exposure to arsenic causes lung, bladder, and skin cancer in humans, and is suspected as a cause of kidney, prostate, and nasal passage cancer. Numerous studies show that arsenic sticks to children’s hands when they play on CCA treated wood, and can be absorbed through the skin or ingested when they put their hands in their mouths.

It is illegal to burn CCA treated pine as the smoke contains toxic gases that can cause cancer and other medical problems, and under no circumstances must CCA treated timber be burned in a BBQ for cooking food. Disposal in landfill is a huge problem, for now and in the future, due to the leaching potential of not only arsenic, but also the chromium content. There have been reported instances of CCA treated pine sawdust ending up in mulch in the U.S.A. and CCA treated pine chips being coloured red and used in landscaping.

What is being done about the problem?
The U.S. EPA announced a voluntary phase-out of CCA by the wood preserving industry. After December 31, 2003, wood for residential uses may no longer be treated with CCA. A bill to prohibit the use of chromated copper arsenate treated timber for any new public or school playground passed the New York State Assembly and Senate on Monday, June 17 2002. The bill, A10221 and S7167, also requires existing CCA treated structures to be maintained to minimize leaching of the CCA and directs the commissioner of environmental conservation to publish information on the dangers of CCA treated timber and methods and materials to be used to minimize the structures leaching CCA. The bill will take effect within six months of its enactment. An Orlando Sentinel article reported that four Florida playgrounds have been shut down due to unsafe arsenic levels from CCA treated play equipment leaching into the soil.

Results from the largest–ever testing program for arsenic–treated wood, released on the 29th August 2002 by the Environmental Working Group (EWG), showed that the public remains at risk from high levels of arsenic leaching out of pressure–treated wood in older decks, playsets, and picnic tables. Study findings reported in EWG’s “All Hands on Deck” indicated that the U.S. Environmental Protection Agency (EPA) was wrong in reassuring the public last February about the safety of existing backyard structures. The Commission of European Communities issued a Directive concerning the risks associated with CCA timber in January this year. It reads in part:

(3) The risk assessment was referred to the Scientific Committee on Toxicity, Ecotoxicity and the Environment (CSTEE) for peer review and the CSTEE concluded that the main risks had been identified correctly. These risks included those to human health from the disposal of wood treated with wood preservatives containing copper, chrome and arsenic (CCA) and in particular risks to children’s’ health from the use of CCA treated wood in playground equipment. A risk to the aquatic environment in certain marine waters was also identified.

(4) The CSTEE further advised that in the light of a serious knowledge gap in relation to arsenic-treated wood in landfills it would be advisable to exercise caution by limiting the use of arsenic-based wood preservation to those situations where it is absolutely necessary.

(5) In a further consideration of the health effects of arsenic the CSTEE has concluded that the substance is both genotoxic and a well-known carcinogen, and that it may be appropriate to consider that no threshold exists for carcinogenic effect.

The United States Consumer Product Safety Commission (CPSC) recently concluded that arsenic in CCA treated timber poses an unacceptable risk to humans, particularly children:

“Based on the assumptions used in the staff’s risk assessment, the CPSC technical staff concluded that a young child who plays on CCA treated wood playground structures in early childhood has an increased risk of 2 to 100 per million of developing lung or bladder cancer during his or her lifetime. This is an increased risk above the risk of cancer due to other factors during one’s lifetime. Staff believes that increased risk exists despite the age of the wood and whether it has been manufactured specifically for playgrounds.”

Regulatory authorities in Australia have been slow to react to the problem. On behalf of the Croydon Conservation Society, I have been involved in a campaign to alert the National Registration Authority (NRA) and enHealth in Canberra, as well as the Victorian Government and the EPA, to the problem of CCA treated products and to put in place a review process similar to that occurring overseas. On December 11th 2002 I received an email from the NRA, which said in part:

“Noting the movements overseas, the NRA has recently sought and received advice from the Therapeutic Goods Administration and the National Occupational Health and Safety Commission. Both agencies have advised that they are not aware of any new evidence that would suggest health concerns requiring immediate regulatory action.

EnHealth also replied to my request on the 23rd December 2002:

“Members considered the current scientific assessment of the use and potential health impacts of CCA in Australia, noting at this time that the National Regulatory Authority (NRA) advice is that there is not a sufficient health risk to children from playgrounds made out of treated timber (tabled).”

These statements were very disturbing, as there was evidence in the public arena to show that children were at risk, a simple Web search would have revealed the relevant evidence. It would also have been prudent for the authorities to contact their counterparts in Europe and the U.S.A. to ascertain the state of the current research. This ‘smacked’ of laziness, lack of accountability and incompetence by the regulatory authorities. The Victorian Government has still not responded. However, due to the overwhelming weight of adverse findings from the publicly available research, the NRA finally relented and, less than three months after stating there was no new evidence suggesting health concerns, on March 13th issued a press release:
The Australian Pesticides and Veterinary Medicines Authority (APVMA) is to conduct a review of arsenic based timber treatments according to APVMA principal scientist Dr David Loschke.
‘The decision to review the registration of these products follows international reports of new scientific information that suggests possible risks associated with their use,’ Dr Loschke said.
‘We are particularly interested in examining the potential for exposure of people to the chemicals when they are contained in treated timber products, for example in playground equipment. We will also be looking closely at possible environmental impacts associated with their use.’
The last paragraph is ‘nonsense rhetoric’, as a substantial amount of peer-reviewed research is already available and has been acted on by overseas regulatory authorities. Any further research would be a waste of time and public money. The Draft Report is due for public comment in March 2004.

The science has already been completed overseas and the results are clear. Arsenic leaches out of CCA treated timber in amounts that have been identified as a risk to the environment and as a risk to the health of people who are in contact with this poison. There are already alternatives to arsenic and chromium in use. The U.S. EPA is in the process of phasing out CCA treated timber for all residential purposes, as is the European Union. The health implications, particularly for children, are profound. The environmental implications are also profound if new methods are not found to extract the chromium and arsenic from the timber prior to landfilling. There are still data gaps in the research on the effects of the leaching of these chemicals to the environment, particularly for groundwater.

The EPAct 1970 now contains a number of principles for environment protection that are relevant to this issue:
• Precautionary principle
• Principle of intergenerational equity
• Principle of shared responsibility
• Principle of product stewardship
• Principle of wastes hierarchy
• Principle of integrated environmental management
• Principle of accountability

It is prudent for all levels of governments to apply these principles in their decision-making process. Local, State and Federal Governments have a ‘Duty of Care’ responsibility to the public to remove this threat of harm as soon as possible, rather than wait for a process that could take up to two years.

The function of regulatory authorities is to protect humans and the environment from harmful processes. The available research provides a clear mandate for the authorities to act and remove this harmful process as soon as possible.

1. CCA treated pine structures, such as children’s playgrounds, to be removed from publicly accessed areas and replaced with acceptable alternatives such as steel or recycled plastic .

2. The AVPMA publish information for the public, with a summary of current findings, including overseas research.

3. All residential uses and some aquatic uses of CCA treated pine to be banned.

4. The Draft Report to be available within six months, not twelve months.

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