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Pesticides: Topical & Chemical Fact Sheets |  |
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Cancellation of Residential Uses of CCA-Treated Wood
On March 17, EPA granted the cancellation and use termination requests affecting virtually all residential uses of chromated copper arsenate (CCA)-treated wood. These CCA products cannot be used after December 30, 2003, to treat lumber intended for most residential settings, including playstructures, decks, picnic tables, landscaping timbers, residential fencing, patios and walkways/boardwalks. Phase-out of these uses will reduce the potential exposure risk to arsenic, a known human carcinogen, thereby protecting human health, especially children's health and the environment. Questions & Answers
1. What is chromated copper arsenate? Chromated copper arsenate (CCA) is a chemical preservative that protects wood from rotting due to insects and microbial agents. CCA contains arsenic, chromium and copper. CCA has been used to pressure treat lumber used for decks, playground equipment (playsets) and other outdoor uses since the 1940s. Since the 1970s, the majority of the wood used in residential settings is CCA-treated wood.
2. What does the voluntary cancellation/termination of certain uses of CCA mean? On Tuesday, February 12, 2002, EPA Administrator Christine Whitman announced a voluntary decision by pesticide registrants to move consumer use of treated lumber products away from a variety of uses of pressure-treated wood that contains arsenic, in favor of new alternative wood preservatives, effective December 31, 2003. This transition affects virtually all residential uses of wood treated with CCA, including wood used in play-structures, decks, picnic tables, landscaping timbers, residential fencing, patios and walkways/boardwalks. This action will result in a reduction of virtually all residential uses of CCA-treated wood within less than two years. This voluntary cancellation of certain CCA products and termination of certain uses of other CCA products greatly accelerates the transition to new alternatives, responding to marketplace demands for wood products that do not contain CCA. This transition will substantially reduce the time it could have taken to go through the traditional regulatory process.
3. Why is the Agency finalizing the CCA cancellation order now? Under FIFRA 6(f), the Agency is required to publish a notice of receipt of the voluntary cancellation/use termination requests and provide for an opportunity for public comments. This notice was published on February 22, 2002, and solicited public comment. The cancellation order being published now includes the Agency's response to comments, and takes action on the majority of the requests to terminate certain uses of CCA. The sale, distribution, and use of CCA pesticide products listed in the notice will only be permitted under the terms, conditions, and labeling set forth in the cancellation order.
CCA is injected into wood by a process that uses high pressure to saturate wood products with the chemical. CCA is a restricted use product and only people who have received the proper safety training are allowed to use CCA to treat wood products. CCA is intended to protect wood from dry rot, fungi, molds, termites, and other pests that can threaten the integrity of wood products. CCA-treated wood is most commonly used in outdoor settings. Around the home, CCA-treated wood is commonly used for decks, walkways, fences, gazebos, boat docks, and playground equipment. Other common uses of CCA-treated wood include highway noise barriers, sign posts, utility posts, and retaining walls. On February 12, 2002, EPA announced a voluntary decision by pesticide registrants to move consumer use of treated lumber products away from CCA pressure-treated wood, in favor of new alternative wood preservatives. As of December 31, 2003, EPA will not allow the affected CCA products to be used to treat wood intended for most residential settings.
5. What precautions should be taken when working with CCA-treated wood? Excessive exposure to inorganic arsenic may be hazardous to your health.
Certain activities can
These precautions will reduce your exposure from inhaling or ingesting sawdust, protect your eyes from flying particles, and prevent exposure to toxic smoke and ash. For more suggestions on avoiding unnecessary exposure to CCA, the Agency has identified some Common Sense Tips. Before working with CCA-treated wood, always consult the Consumer Safety Information Sheet, which is also available in hard copy at 1-800-282-0600.
6. Does arsenic leach from treated wood products into soil? If so, what happens to it? Published results of scientific studies suggest that arsenic, over time,
slowly leaches from
7. How should I use CCA-treated wood? CCA-treated wood is used in a variety of outdoor structures. Many people have used CCA-treated wood for fences, posts, decks, and gazebos. It should not be used where routine contact with food or animal feed can occur. Do not use CCA-treated wood for cutting boards, counter tops, bee hives, compost, mulch, or structures or containers for storing human food or animal feed. Furthermore, since some animals like to eat wood, CCA-treated wood should not be used where animals can chew on the treated wood. Also, do not use where treated wood may come into direct or indirect contact with drinking water, except for uses involving incidental contact with docks or bridges. On February 12, 2002, EPA announced a voluntary decision by pesticide registrants to move consumer use of treated lumber products away from CCA pressure-treated wood effective December 31, 2003, in favor of new alternative wood preservatives. After December 30, 2003, EPA will not allow the affected CCA products to be used to treat wood intended for most residential settings.
8. What is the role of the Consumer Product Safety Commission (CPSC)? In June 2001, CPSC docketed a petition by the Environmental Working Group (EWG) and the Healthy Building Network (HBN) to enact a ban of CCA-treated wood for use in playground equipment. The staff's report that was developed in response to the petition was presented to the Commissioners for their review. The Commission held a public meeting (3/17-18/03) to discuss the staff report and other related information. After the Public Meeting, the Commissioners will vote to grant, deny or defer the petition (which asks the CPSC to initiate a regulatory procedure).
9. What are EPA's plans for the risk assessments for CCA? EPA plans include two Preliminary Risk Assessments (PRAs) for CCA. The first one, the Occupational and Environmental Risk Assessment, has been completed. It has been released to CCA manufacturers for error correction only, and will be made available to the public in the spring of 2003. The children's risk assessment is on a different track, and there are a number of difficult science issues on which the Agency will continue to focus regarding CCA. The Agency expects a variety of new data on the exposure to CCA in residential settings. These data will substantially strengthen the confidence in the risk assessment. We are expecting the PRA (Residential) focusing on children's risk from exposure to CCA from decks and playstructures to be completed in late 2003, when it will be reviewed by the Science Advisory Panel (SAP), and it will be publicly available on EPA's docket and website. We expect it to be completed in 2004.
10. What do you advise consumers who have existing CCA structures? EPA does not believe there is any reason to remove or replace CCA-treated structures, including decks or playground equipment. EPA is not recommending that existing structures or surrounding soils be removed or replaced. While the available data are limited, studies suggest that applying certain penetrating coatings, for example, oil-based semitransparent stains, on a regular basis, can reduce CCA exposure. In selecting a finish, consumers should be aware that, in some cases, "film-forming" or non-penetrating stains (latex semitransparent, latex opaque, and oil-based opaque stains) on outdoor surfaces such as decks and fences are not recommended, as subsequent peeling and flaking may ultimately have an impact on durability as well as exposure to the preservatives in the wood. As always, parents should manage risks to their children, and follow several measures, including:
Consumers should follow the recommendations in the updated Consumer Awareness Program, including the same precautions that workers should take: wear gloves when handling wood, wear goggles and dust-mask when sawing and sanding, always wash hands before eating, and never burn CCA-treated wood. The Consumer Awareness Program is an education program conducted by the American Wood Preservers Institute at retail institutions to inform construction workers and others of measures needed to protect them from potential occupational exposure to CCA.
11. Are there alternatives for the terminated uses of CCA? There are a number of non-arsenic containing preservatives that have been registered by EPA to pressure-treat wood for consumer applications (e.g., ammoniacal copper quat, ACQ, and copper boron azole, CBA). Some wood treated with these preservatives is already available at retail outlets such as home improvement stores. In addition, playground equipment made of other non-arsenic containing components is also available (e.g., woods such as cedar and redwood and non-wood alternatives such as metals and plastics). Consumers may also wish to consider the new generation wood preservative products, such as ACQ and CBA. During reregistration review, EPA will determine the availability of alternatives to the remaining uses of CCA.
12. What is the status of allowing the continued use of CCA to treat agricultural fence posts, and permanent wood foundations? In light of comments received, EPA is deferring any action with respect to requests to terminate CCA use on agricultural fence posts and also on permanent wood foundations at this time. Fence posts for agricultural uses may continue to be treated with CCA. Specifically, fence posts treated according to AWPA Standard C16 are for agricultural purposes only. This particular type of fence post is used by many farmers and ranchers for barbed and other wire fencing. The distribution channels, aesthetics, size, round shape, and random diameter of that type of fence post effectively limit its use for specific agricultural purposes, and make it inappropriate for residential applications. The Agency has determined, based on available information and field investigations, that agricultural fence posts are not sold in the residential market. On the other hand, wood treated for fence posts according to AWPA Standard C5 is sold at the retail level for residential fencing and can be used for other residential applications as well. Therefore, fence posts intended for residential fencing in accordance with the C5 standard cannot be treated with CCA after December 30, 2003. The Agency will review use of CCA to treat agricultural fence posts, as well as permanent wood foundations, through its reregistration process. We believe this temporary deferral for these two uses maintains the principle to phase out CCA for residential uses.
13. Is the process of phasing out CCA by voluntary cancellation/use termination faster than the traditional regulatory process? This action is much faster than the traditional regulatory process, potentially cutting the time in half. The Agency is expediting the risk assessment process so we can better understand any potential risks to children. If at any time we have information that shows an unacceptable risk to children or others is caused by CCA-treated wood, we will take steps immediately to notify the public and reduce any risks to the public. The Agency found that allowing the voluntary cancellation of most residential uses of CCA and phasing CCA out of the residential marketplace over the next nine months was the most expedient way to minimize risk to consumers. While EPA recognizes that the transition to alternative chemicals may pose significant challenges to some stakeholders, including wood treaters who have to convert their plants to alternative chemicals, in their requests for cancellation/use termination the registrants indicated that this time period was adequate. Therefore, EPA did not extend the effective date beyond December 31, 2003.
14. What are the existing stocks provisions in the final cancellation order? With respect to cancelled registrations, the registrants have until May 16, 2003 (60 calendar days from the effective date of the cancellation order) to sell or distribute or use the products affected by the order. Sale, distribution, or use by persons other than the registrant may continue until supplies are exhausted, provided any sale, distribution, or use is in accordance with the existing label of that product. Regarding registrations amended to delete terminated uses, the registrants have until May 16, 2003 (60 calendar days from the effective date of the cancellation order) to use previous (unamended) labels, to allow a sufficient period of time for an orderly transition to the amended labels without disrupting supply and availability of product. Sale, distribution, or use by persons other than the registrant may continue until supplies are exhausted.
15. How do I dispose of CCA-treated wood? CCA-treated wood is classified as non-hazardous waste under the Federal Resource Conservation and Recovery Act (RCRA), and disposal of CCA-treated wood is addressed via the Consumer Awareness Program (CAP). The CAP is a voluntary program established in 1986 (and later updated in 2001) by the registrants of CCA products, to protect consumers by providing them with information on the proper handling, use and disposal of CCA-treated wood. Under this program, instructions on the proper handling, use and disposal of CCA-treated wood are disseminated to consumers upon purchasing CCA-treated wood products via the Consumer Safety Information Sheets (CSIS) and/or end tag labeling applied to the wood product itself. CCA-treated wood should never be burned in open fires, stoves, fireplaces, or residential boilers. Additional information regarding the CAP, handling, use and disposal of CCA-treated wood can be obtained from the Agency's Web site at: www.epa.gov/pesticides/factsheets/chemicals/1file.htm. You can also contact your state or local solid waste management offices to receive instructions on how to dispose of CCA-treated wood.
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