Croydon Conservation Society

Manager Pesticides Review
Australian Pesticides & Veterinary Medicines Authority
PO Box E240
Kingston ACT 2604

CCA Review

29th February 2004

The Croydon Conservation Society strongly supports the APVMA’s statement on the 28th July 2003 that , “….it intends to stop the use of Copper Chrome Arsenate (CCA) as a timber treatment in certain domestic situations such as decking and children’s playground equipment by the end of 2003 unless there is conclusive proof that continued use is safe.” However, we feel that the APVMA needs to address the issue of the CCA treated timber remaining in the public domain. If it is concluded that it is not safe for future use, then it is surely not safe for current use.

In line with our previous submissions, the Croydon Conservation Society makes the following recommendations to ensure that the threat of harm from CCA treated timber products is removed from the public domain:

1. CCA treated pine structures to be removed from publicly accessed areas and replaced with acceptable alternatives such as steel or recycled plastic. This includes fencing, children’s playground equipment, sheds, cubby houses, bollards etc.
2. The AVPMA continue to publish information containing a summary of current findings.
3. All residential uses of CCA treated pine to be banned.
4. The APVMA commission research into the risk to aquatic environments similar to the E.U. Directive.
5. The issue of CCA treated timber disposal to landfill to be discussed with State Governments and protection agencies, with a view to classifying CCA timber as hazardous waste, irrespective of the amount, and disposal only to lined landfill.
6.The APVMA commission research into remediation technologies to remove arsenic, chromium and copper from CCA treated timber prior to landfill or re-use.
7. Mandatory warning labels on all CCA treated timber prior to sale.
8. A public awareness campaign through various media outlets, warning of the potential hazards associated with exposure to CCA treated timber, and a list of safer alternatives.
9. The APVMA commission residue testing on a range of CCA treated timber structures currently in use and publish the findings.
10. The APVMA commission soil testing in the vicinity of CCA treated timber structures currently in use and publish the findings.

The timber preserving industry has always maintained that the arsenic, chromium and copper are ‘locked’ into the timber and will not leach. The Victorian EPA has a similar opinion. There is not one piece of published research that backs up this assertion.

Our research and testing has mirrored overseas research, which demonstrated that arsenic and chromium 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 these poisons. There are already alternatives to arsenic and chromium in use. The U.S. EPA has phased out CCA treated timber for all residential purposes, as has the European Union. The health implications of exposure to CCA treated timber, 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. There is no way to identify CCA treated timber after it has been in use for a period of time, making it very difficult to adhere to safety guidelines, such as, DO NOT BURN OR USE WOOD IN BBQs FOR COOKING.

On the weight of the available evidence, the Croydon Conservation Society believes that:

• CCA treated timber products cause an undue hazard to the safety of people exposed to them during their handling, or people using anything containing their residues
• Are likely to have an effect that is harmful to human beings, and
• Are likely to have an unintended effect that is harmful to animals, plants or things or to the environment.

Environment Protection Acts throughout Australia now contain 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

We believe it is prudent for all levels of governments, and government agencies, 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. 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, and we will strongly support any such action by the APVMA.

Yours sincerely,

Keith Loveridge B Soc Sci (Environment)
President, Croydon Conservation Society

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