May 15, 2004

Dr. Bonaventure Akinlosotu
Antimicrobials Division (7510C)
Office of Pesticide Programs
Environmental Protection Agency
1200 Pennsylvania Avenue, NW.
Washington, DC 20460

RE: Docket ID number OPP-2003-0250 -Risk Assessment for Wood Preservatives containing Arsenic and/or Chromium Reregistration Eligibility Decision (RED)

Dear Dr. Akinlosotu:

My name is Joe Prager and I am the publisher of BANCCA.ORG, a web site which publishes comprehensive information on the health hazards of CCA treated wood. My family and I are victims of exposure to the toxins in CCA treated wood, which we believe caused our daughter's birth defects and other assorted health problems.

Our family created the BANCCA.ORG web site over two years ago after learning about the real hazards of our exposure to CCA wood - that it is a toxic, carcinogenic and teratogenic product. Our site was designed to provide vital information to the public on the health hazards of CCA wood - something we were sorely absent when we handled this product in in the mid-1990s.

We now have some 20,000+ visitors each month from around the world who visit our site, many of whom write to thank us for the valuable information we provide. Other readers write to tell us about their injuries from CCA wood exposure, or to ask for help with their medical problems, some of which are quite severe.

Since we are constantly in communication with consumers and workers who have been harmed by CCA treated wood, we have a clear view of its real hazards. It is with them in mind that we will now supply you with some frank and straightforward comments on this topic. If you find these comments too blunt or too direct, keep in mind that we speak on behalf of the many people who suffer every day with health problems inflicted on them by their unwitting exposure to toxic treated wood products.

Recently, we attended the International Conference on the Environmental Aspects of Preservative Treated Wood in Orlando, and we learned much about the environmental issues related to preservative treated wood, especially CCA treated wood. Over 150 scientists from around the world attended this conference in Orlando in February, including your own director of the Office of Pesticide Programs, Mr. Jim Jones.

We asked Mr. Jones why the EPA had "drug its feet about CCA for 23+ years" while it knew about the health hazards associated with human exposures to CCA treated wood, his response to our question before the conference attendees was that "we were too busy dealing with issues related to food-use pesticides… [sic]".

Needless to say, this answer falls short of the truth. While it is true that food-use pesticides have been a big issue since the 1980s, this is no justification for how your agency has ignored the problem with treated wood, while the treated wood industry has profited heavily from sales of this toxic product, to the detriment of consumers who have been harmed by it, and to the detriment of our environment. It is nothing short of shameful how the EPA has "looked the other way" where the health hazards of CCA wood are concerned. One need only review the record of how the EPA has treated this product over the last 25 years to see this pattern of neglect.

Workers were the main ones put at risk this past quarter century, but they were not the only ones. Children and the general public have also been exposed and injured by this product in many known incidents over the years. Yet, the industry states in their glossy product brochures that, "There has never been any evidence that a human being has ever been harmed by it..." Your records, that of state agencies, and newspaper and first person accounts tell a different story. The injuries reported by plant workers, lumberyard workers, carpenters, do-it-yourselfers, children, cattle, house pets, and even grandmothers show that CCA treated wood poses an unacceptable health risk to humans and animals.

Now, that CCA treated wood has been "banned", many in your agency may feel that the problem has been dealt with, that the problem is over. It is not. At my local Home Depot, stacks of CCA treated wood are still readily available, still keeping the public at risk of harm, not only from the arsenic residue, but from the toxic sawdust, from potential splinter injuries and other exposure pathways.

This ban, which took effect on Jan. 1, 2004, was merely a compromise effort on your agency's part that has proven ineffective. It should be more appropriately called a "phasedown", as several uses are still permitted, included farm fencing, poles and structural uses. This means that workers and carpenters will still be exposed to this toxic product, many without any knowledge of the hazards of the compounds used to make the lumber they are handling. This is unacceptable.

In the years ahead, taxpayers, not the treated wood industry, will be burdened with the cleanup of the toxic leachate from arsenic-treated wood products as they are discarded and sent to the landfill. This is already a problem here in Florida, where our Department of Environment Protection is proposing legislation to prohibit the disposal of CCA treated wood in unlined C&D landfills, and to restrict the open burning of CCA wood and the recycling of CCA wood into mulch or wood chips for landscaping purposes. But in spite of these progressive regulations in our state, the problem of the arsenic leachate escaping landfills and contaminating ground water resources is a real and serious threat to our environment that will not go away.

It should come as no surprise to the EPA that a great number of treated wood plant sites are heavily polluted, which typically leads to many of these sites being classified as Supefund cleanup sites. The treater typically files for bankruptcy in these scenarios. Again, the taxpayer gets burdened with the "external cost" of the cleanup caused by this so-called miracle product. This is the real legacy of this treated wood products - polluted groundwater and Superfund sites, and toxic waste problems that will last for years to come.

We note that the mission statement of your agency is "to protect human health and safeguard the natural environment" and we offer that this RED provides you with the opportunity to do just that. To do what your agency has failed to do in the past - to protect human health and the environment by cancelling all registrations for CCA, ACC, ACA and ACZA. The public no longer needs to be exposed to these toxic heavy metals, now that other alternative compounds are available that are safer for human health and the environment.

In our opinion, - the choice is simple. Further study of these compounds is moot and unnecessary. The human injury data speaks for itself. Therefore, we urge the EPA staff to cancel all registrations for arsenic and chromium-treated wood products.

Moreover, we urge you to recall all arsenic-treated CCA wood products now. That's what should have been done years ago - a real ban and a real recall. A recall will get the toxic wood out of our stores, and out of our playgrounds, our porches, our pergolas and our piers, before there is another victim of CCA wood, whose health is damaged or ruined by being unwittingly exposed to a product that they thought was safe.

Consumers depend on the EPA (and their government) to do just that - to tell them when a product is not safe and to take action to prevent risk to their health and our environment. We ask that you do just that. This is the only way we can truly ensure the public safety.

Thank you for taking the time to consider this vital information.

Sincerely,

Joe Prager, Publisher
BANCCA.ORG
mail@www.bancca.org

[Editor's Note: We invite you to submit your own comments about the reregistration of CCA treated wood to the EPA's open docket by May 17, 2004. You can submit your comments easily online. Reference EPA Docket # OPP-2003-0250.]

******************************************************************

Home
CCA Victim Accounts
Special Reports

Last Updated: May 15, 2004
© Copyright 2004 BANCCA.ORG, LLC
All Rights Reserved

Disclaimer: BANCCA.ORG makes every effort to ensure the accuracy of the information provided on its Web site. However the information presented is for research and educational purposes only, and is subject to regular review and change without notice. No warranty or representation can be provided regarding this information. We do not accept liability for any losses or damage arising directly or indirectly from reliance on the information in any article written or published on this Web site.