A BANCCA.ORG SPECIAL REPORT

Fact vs. Fiction -

Has the Treated Wood Industry reported the facts

on the Safety of CCA Treated Wood?



By Joseph Prager

December 8, 2002

For the past few years, CCA treated wood has come under fire from the news media, environmental organizations, law firms and government agencies around the world.  In the face of this mounting negative publicity, the American Wood Preservers Institute (AWPI) released statements and video tapes to the press, published information online, and distriubuted brochures around the country, stating that CCA treated wood and other forms of treated wood are "safe and environmentally sound". The brochures, available at the sales counters of most Home Depot, Lowes, and other major lumber retailer stores, reassure consumers that CCA treated wood is "safe for human contact" and that "there is no risk to human health" for users of this product.  

For some consumers, this brochure may be the sole source of information available to them to answer the most important question about CCA treated wood: Is CCA wood really safe?  But, is the information presented in the brochure accurate? And, what about the other public statements made by the treated wood industry about CCA wood safety?

We decided to take a closer look at some of the statements made by the treated wood industry in their interviews with the press, on their Web sites, and in their recently released brochure, "Pressure Treated Wood: Safe & Environmentally Sound". We have researched the AWPI's key statements, and in this article, we are providing fair and balanced counterpoint arguments regarding their statements on CCA treated wood, so that consumers can come to their own conclusions about the safety of this product, and the veracity of the industry's claims.

Are the statements made by the Treated Wood Industry about CCA wood's safety scientific fact or industry propaganda?  We report the facts- you decide for yourself. In the table below, we review these key statements and the facts we uncovered.

Wood Industry Media Statement
Fact or Fiction?
Parker Brugge, President of The American Wood Preservers Institute (AWPI) made this statement, in an article in Barron's magazine, regarding whether CCA treated wood is harmful:

"There's no evidence in a peer-reviewed scientific journal that anyone has ever been harmed from regular use of treated wood."


Source:
"Under Pressure - Companies making CCA-treated wood are pinched by environmental concerns and litigation", Barrons, June 17, 2002, Eric J. Savitz, pg. 18.




Dr. Gilbert Ross, Medical Director of the American Council on Science and Health, is quoted on the cover of the AWPI brochure "Pressure Treated Wood: Safe & Environmentally Sound", as stating that:

"We have found that there is no risk to human health. There has never been any evidence that a human being has ever been harmed by it..."


Source:
"Pressure Treated Wood: Safe & Environmentally Sound", A brochure published by the American Wood Preservers Institute,2001, pgs. 1-2.

 False.

While the numbers of peer-reviewed studies on injuries to humans from CCA wood exposure are very rare- they are not non-existent. To illustrate this point, here is an example:

In 1986, Drs. Peters, Croft, and others published a case report(1) of a 42-year-old woman and a 40-year-old man who were injuried from CCA exposure that occurred while making CCA picnic tables in 1983. At that time, they were working in a small, non-ventilated room, without protective gear. (This is a typical exposure for many users of CCA, including this author, and is still prevalent today.)

To quote from the study's abstract, "Both began to experience spontaneous nose bleeds, itching and burning of the skin, heaviness of the chest and stomach aches. The woman noticed that her hair pulled out when combed. Other symptoms included alterations in memory and darkening of urine. The man suffered from severe tarry stools and massive melena, requiring hospitalization and 7 units of blood..."

Other examples of peer-reviewed studies proving potential harm to humans and animals do exist. A study published on the effects of CCA components on laboratory rats, was published by Drs. Mason and Edwards in 1989 (2). They were assessing the acute toxicity of high and low doses of chromium, arsenic and copper to Wistar rats. They concluded that "CCA may present a greater acute toxicity than exposure of the constituent compounds separately."  So, in this case, "the sum of the parts" may be greater than the whole where CCA's toxicity is concerned.

With that in mind, it is also important to remember that there exist numerous studies of the health hazards posed by CCA's constituent components: arsenic (or other arsenates) and hexavalent chromium (and other chromates) - in peer-reviewed journals worldwide. These studies are not new or novel, as some date back several decades. These well known and widely-available studies cannot be ignored.

Moreover, there are reports of animals injured or killed by exposure to CCA wood. One recent case study (3), published in 1998, reported a case of "arsenic toxicosis attributable to ingestion of ashes from burned posts treated with an arsenic-containing preservative [CCA]… Seven cows from a herd of 37 developed diarrhea, weakness, stumbling and prostration. Four of the affected cattle died within a 48-hour period."

One now famous example of a peer-reviewed scientific journal article (4), showing injury through "irregular use" of CCA wood, was published in 1984 by the Journal of the American Medical Association (JAMA). This classic study described how a rural family in Wisconsin suffered serious health problems when they were exposed to smoke from burning CCA wood scrap in their family wood stove during the winter months.


Sources:
1. Acta Pharmacologica et Toxicologica, Vol. 59, Supplement 7, pages 39-43, 1986.
2. Comparative Pharmacology and Toxicology, Vol. 93C, No. 1, Pages 121-125, 1989.
3. Veterinary and Human Toxicology Vol 40 (3) June, 1998 pgs. 147-148.
4. Case Study from the Journal of the American Medical Association, May 11, 1984, pgs. 2393-2396.
A similar statement to the one made above was also made by Mel Pine, the official spokesman of the American Wood Preservers Institute (AWPI). He made the following statement in a newspaper article published by the Gainesville Sun, regarding whether exposure to CCA treated wood can cause injury or illness:

"If there were a shred of truth to that, some scientist would have found that by now... and published something."



Source: Statement published by the Gainesville Sun on March 17, 2002, in an article entitled "Poison Dreams". 		False.

Many scientists from around the world have published articles in medical journals on the hazards of arsenic and hexavalent chromium, both of which are ingredients of CCA, and as detailed above, there are studies on the CCA formulation itself.

Besides the studies mentioned in the counterpoint above, Dr. Steve Roberts, Chairman of the EPA's FIFRA SAP committee prepared a widely-publized report (1) to the Florida DEP expressing concern about the hazards of CCA, stating that,

“...the plausible ranges of arsenic doses that could result from incidental contact [with CCA wood in playground equipment] includes doses high enough to be unacceptable from a health protection standpoint...”

As a final point, BANCCA.ORG has published several accounts of CCA victims' injuries, taken from the EPA's own archives on our CCA Victim Reports page.


Source:
1. Report by Dr. Steve Roberts and Hugo Ochoa, University of Florida Center for Human & Environmental Toxicology to John Ruddell, Director, Florida Department of Environmental Protection (DEP), dated April 10, 2001. Available online at BANCCA.ORG here.
The American Wood Preservers Institute (AWPI) Web site (www.preservedwood.com) makes this claim about treated wood:

"Studies by the Environmental Protection Agency, the Consumer Product Safety Commission, state and local government agencies and a host of academic researchers have found that properly used pressure-treated wood is no threat to adults, children or the environment that we all live in. "


Source: AWPI Web site, Health and Safety Page: http://www.preservedwood.com/safety/safety.html		 False.

The Environment Protection Agency (EPA), the U.S. Consumer Product Safety Commission, various state agencies, Health Canada and the European Commission have been reviewing the issues related to CCA wood safety, since new information on the toxicity of CCA and how CCA leaches from the wood has become available. Yet, the hazards associated with this product have been known for years by both the EPA and the wood industry.

In 1985, the EPA requested that the treated wood industry develop consumer information sheets with important safety information to provide to consumers (end users) of wood preserved with CCA, creosote, or pentacholorophenol (penta). These warning sheets were to contain steps to prevent potentially hazardous exposures to wood preservatives, and include handling, wood working, and disposal precautions. The EPA stated that "such a program is necessary to assure that the use of pressure-treated wood does not pose an unreasonable adverse effect." (1)

In 1988, when the EPA determined to cancel most non-wood uses of the inorganic arsenicals, the Agency stated that the effects of concern were oncogenicity, mutagenicity, teratogenicity and acute toxicity. The EPA's Carcinogen Assessment Group had recently classified both arsenic and hexavalent chromium as “Group A carcinogens,”which means that significant scientific studies proved these compounds to be cancer-producing agents.(2) At this same time, the EPA acknowledged that both arsenic and chromium had the potential to cause teratogenic/fetotoxic effects (birth defects).

In 1990, the U.S. Consumer Product Safety Commission issued new recommendations that:
1) Treated wood manufacturers & playground equipment manufacturers develop procedures to reduce arsenic in treated wood products.
2) Wood preservers should increase availability of their consumer information safety warning sheets.
3) the exposure of consumers to arsenic during woodworking operations (sanding, sawing, etc.) should be reviewed.

As one example of what state agencies have reported on the hazards of treated wood, in 1987 the California Department of Health Services (DHS) issued a report (3) to the state legislature on the hazards posed by the use of wood preservatives in playground equipment, which made this statement:

"Although chemical preservatives increase the longevity of wood, they have toxic properties that may pose potential health hazards, including cancer. Because of public concern about the potential hazard to children, the state adopted Health and Safety Code Section 25930, which prohibits the use of state funds to purchase wooden playground or recreational equipment when there is a likelihood of children contacting wood treated with pentachlorophenol or creosote. The law applies the same restrictions for arsenic-treated [wooden playground] equipment..."

Last, but not least, most treated wood is very much a threat to our environment. Many of the former and current treated wood facilities in the U.S. are so heavily contaminated with toxic chemicals used to make treated wood, that they are classified as Superfund sites. Nearby homes can be affected, too, as the pollution leaves the site and spreads into nearby groundwater, or as dust or spray drifts by the winds onto adjacent property. One such example is the severely polluted Koppers Company Feather River Plant wood treatment facility site in Oroville, California. Its legacy of contamination is detailed online here.


Sources:
1.49 Federal Register 28682
2. 53 Federal Register 24787, 89 (June 30, 1988).
3. California Department of Health Services. 1987. "Evaluation of hazards posed by the use of wood preservatives on playground equipment", Office of Environmental Health Hazard Assessment. Report to the Legislature.
The American Wood Preservers Institute brochure on pressure treated wood, "Pressure Treated Wood: Safe & Environmentally Sound", also quotes Dr. Gaylord Lopez of the Georgia Poison Control Center.

After explaining that CCA is "particularly popular in Georgia" and that the Georgia Poison Control Center received "very few calls involving the substance", Dr. Lopez is quoted as saying:

"If you look at the safety record and health effects, you find this is a very safe product. The safety record of CCA-treated wood is impeccable."



Source:
"Pressure Treated Wood: Safe & Environmentally Sound", A brochure published by the American Wood Preservers Institute, 2001, pg. 3.
 False.

We invite our readers to review CCA's safety record for themselves. BANCCA.ORG has published excerpts of actual incident reports of CCA victims' injuries, taken from the EPA's own archives on our CCA Victim Reports page. These records were acquired by BANCCA.ORG via a Freedom of Information Act request. We note that two of the reported incidents occurred in the state of Georgia, where Dr. Lopez works.

However, it is important to note that many reports of CCA injuries do not necessarily get reported to the state Poison Control Centers, but instead may be reported directly to the manufacturer. In turn, manufacturers, such as Hickson, Osmose, Chemical Specialties, and others, are required by Federal regulatons [FIFRA 6(a)(2)] to file incident reports of worker and consumer injuries directly to the EPA for their review.

To state that "the safety record of CCA... is impeccable" is ludicrous. Webster's Collegiate Dictionary 10th edition defines impeccable as "free from fault or blame; flawless". The safety record of CCA, as detailed in the EPA's own archives on our CCA Victim Reports page, is anything but impeccable.

Finally, we also publish a comprehensive account of the potential health hazards of CCA, arsenic and chromium, (available here), for those who are interested in learning more about the health consequences that might occur after exposure to CCA treated wood products.
Regarding hazards posed to aquatic life forms, the American Wood Preservers Institute brochure on pressure treated wood next quotes Dr. Kenneth Brooks of Aquatic Environmental Sciences, who has worked as a consultant for the Western Wood Preservers Institute.

After explaining that Dr. Brooks has for the past 5 years studied the impact of pressure-treated wood on the water, fish and other aquatic organisms, the brochure quotes Dr. Brooks as saying:

"There are no documented instances describing a compromised biological intergrity associated with the use of any form of treated wood, including CCA-treated wood."

The AWPI brochure continues with the statement, "Even searching for the "most subtle" environmental impact, the studies did not uncover evidence of adverse impact."




Source:
"Pressure Treated Wood: Safe & Environmentally Sound", A brochure published by the American Wood Preservers Institute, 2001, pg. 3.
 False.

While a review of Dr. Brooks published reports shows that he consistently declares that there is little or no harm caused to aquatic life by exposure to CCA treated wood, or other forms of treated wood such as creosote-treated wood, it is certainly incorrect to state that there are "no documented instances of compromised biological integrity".

During our research, BANCCA.ORG contacted Dr. Judith Weis of Rutgers University, an expert in toxic effects on aquatic life, and obtained a partial list of 16 peer-reviewed study articles. Several of these studies do show harm (i.e. "compromised biological integrity") to aquatic life.

One study in particular (1), reported the bioaccumulation of toxins from treated wood in oysters. In this study, "oysters living inside a residential canal lined with chromated copper arsenate (CCA) treated wood had elevated levels of metals, especially copper, and were sometimes green in color, when compared to reference oysters collected from nearby rocks." Moreover, "these oysters had an elevated prevalence of a previously described histopathological atrophic condition (metaplasia) of the digestive diverticula."

Another of these studies (2) showed that snails feeding on green algae collected from bulkheads made of CCA treated wood soon retracted into their shells and then died. The metals in the CCA treated wood were taken up by attached algae, and when consumed by the grazing snails, proved deadly to this species.

These studies, showing harm to oysters and snails from CCA wood would certainly qualify as"documented instances of compromised biological integrity".

It is unclear if Dr. Brooks, or the AWPI themselves, made the follow-on statement which makes the claim that, "even searching for the "most subtle" environmental impact, the studies did not uncover evidence of adverse impact." But, this statement is clearly false, as we were able to easily obtain several studies that report such adverse impacts.

The AWPI, with increasing regulatory pressures being imposed on the use of treated wood in wetland areas, is trying to make the point that the use of treated wood has a negligible environmental impact. However, both sides of the issue about the toxicity of treated wood to aquatic life are not being presented in their literature.

Finally, the effects of treated wood chemicals on aquatic life continues to be an area of ongoing research, and we note that the Florida Center for Solid and Hazardous Waste Management is planning a research project entitled, “Impacts of Arsenic from CCA-Treated Wood in Marine and Terrestrial Environments” to explore this topic further.

Sources:
1.Weis, P. J.S. Weis and J. Couch 1993. Histopathology and bioaccumulation in oysters (Crassostrea virginica) living on wood preserved with chromated copper arsenate. Dis. Aquat. Org. 17: 41-46.
2. Weis, J.S. and P. Weis, 1992. Transfer of contaminants from CCA-treated lumber to aquatic biota. J. Exper. Mar. Biol. Ecol. 161: 189-199.
The final statement made by a scientist in the AWPI brochure, "Pressure Treated Wood: Safe & Environmentally Sound", is attributed to Dr. Stan Rhodes, CEO of Scientific Certification Systems.

In the brochure, Dr. Rhodes explains how the impact of CCA wood is a major benefit to the environment and goes on to say that

"Dr. Rhodes also pointed out that the minerals used in CCA come from the waste stream resulting from mining and other industrial operations, and thus represent a reuse of products that otherwise would be wasted. "They are put back into a product that does not get back into the environment," he said."


Source:
"Pressure Treated Wood: Safe & Environmentally Sound", A brochure published by the American Wood Preservers Institute,2001, pg. 3.		 False.

Dr. Rhodes in his statement makes misleading assertions that CCA treated wood is a beneficial product that utilizes a recycled chemical formulation, and that this represents a "reuse of products that would otherwise be wasted" and that"the minerals in CCA come from the waste stream from mining and other operations". However, nothing could be further from the truth. Note that the U.S. Geological Survey Mineral Commodities Summary 2002 (1) states the exact opposite about arsenic and and its usage in the U.S.:

"Because arsenic is not recovered from domestic ores, all arsenic metal and compounds consumed in the United States are imported. More than 95% of the arsenic consumed was in compound form, principally arsenic trioxide... Production of chromated copper arsenate (CCA), a wood preservative, accounted for more than 90% of the domestic consumption of arsenic trioxide... Wood preservatives are expected to remain the major domestic use for arsenic. "

Last year, the St. Petersburg Times published an article (2) exposing how the arsenic in CCA is imported from China, where the workers are undergo horrendous working conditions while handling arsenic trioxide. This article, "Arsenic from China arrives in toxic trade", published Dec. 29, 2001 is available online here.

A key point in this article mentions that "America once produced its own arsenic, but the last facility in the U.S. closed down in 1985 after government regulators found widespread pollution. The Tacoma, Wash., plant is now a Superfund cleanup site.... The evidence [of environmental impact] is clearer around Tacoma. ASARCO, the last domestic arsenic producer, left a legacy of pollution in the town.... Bulldozers have descended on neighborhoods, digging up 1,000 arsenic-laced yards so far. It will take years and millions of dollars before the cleanup is finished..."

But, what about chromium? Is it being recycled from mining wastes and industrial operations? Here again, the U.S. Geological Survey Mineral Commodities Summary 2002 report states,

" Chromite ore is not produced in the United States, Canada, or Mexico. In 2001, the United States consumed about 14% of world chromite ore production in various forms of imported materials, such as chromite ore, chromium chemicals, chromium ferroalloys, and chromium metal. Imported chromite was consumed by two chemical firms and two refractory firms to produce chromium chemicals and chromite-containing refractories, respectively. Chromite ore has no substitute in the production of ferrochromium, chromium chemicals, or chromite refractories."

The report makes no mention of chromium reuse from "mining wastes or industrial operations".

Surely, copper is being recycled then? Yes, some copper is being recovered at some mines operating in the United States, and also from our scrap metal waste, but whether this recovered copper is actually used in the production of the CCA formula is unknown. The bulk of our copper, approximately 67%, is imported from Canada, Chile, Peru and Mexico.

Clearly, there is no "major benefit" to the environment where arsenic and the other heavy metals in CCA wood are concerned. Instead, we are being left with a waste stream burdened with hundreds of metric tons of arsenic and chromium and copper, embedded in the CCA wood, as a legacy for generations to come.

It is important to remember that arsenic, copper and chromium are elements. They do not break down and they remain long after the product itself has been discarded into the waste stream. While some scientists are investigating ways to recover the toxic chemicals from CCA waste wood - at present, these projects are only in the pilot stage. Any effort to present CCA wood as a recycled product is specious and misleading.

Sources:
1. U.S. Geological Survey, Mineral Commodity Summaries, 2002, pg. 24.
2. "Arsenic from China arrives in toxic trade", Julie Hauserman, St. Petersburg Times, December 29, 2001.


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