In May, 2001, two environmental organizations, the Environmental Working Group and the Healthy Building Network, petitioned the U.S. Consumer Product Safety Commission (CPSC) to ban the use of CCA treated wood in playground equipment and to review the safety of CCA wood for general use.

After the Environmental Working Group and the Healthy Building Network petitioned the CPSC to ban CCA wood in playground equipment and to study its safety, the CPSC published a notice in the Federal Register about this new petition, known as Petition HP 01-3, and invited comment from the public.

Some 3019 US consumers, including this author, along with representatives of several governmental agencies, joined in writing letters and sending petitions to the CPSC, expressing concerns about the potential hazards of CCA treated wood. On the opposing side, corporations with interests in treated wood products wrote in to express their views that CCA wood is perfectly safe to use.

Since the 107th Congress had shown a special interest in the issue of CCA health hazards in playground equipment, the CPSC asked for and received a 1 million increase in its budget for additional salaries and expenses to prepare this report. In turn, the CPSC promised to keep the public and Congress informed about its findings on CCA wood.

With this new funding in place, the CPSC set about to complete its 2nd report on the hazards of CCA wood in playground equipment. Yes, that's correct- its 2nd report.

The first report, originally released in 1990, became mired in controversy, and was considered flawed by the scientific community, mostly due to the inaccurate tests that were performed and the dubious results obtained. The scientists who worked on the 1990 report had apparently been duped by industry representatives, who provided them with assorted CCA-treated wood samples, of which 7 out of 8 samples were either sanded or pre-treated with stain. This naturally resulted in abnormally low arsenic values in almost all of the wipe tests. In fact, only one sample out of 8 was unfinished, and it was the sample with the highest dislodgeable arsenic value: 68.8 microgram/100 sq. cm. [1]

Yet, the CPSC used this flawed and very limited data to come to a determination that CCA wood used in playground equipment did not present any hazard to children. This report formed the basis of the CPSC stance on CCA wood products for 13 more years, in spite of the open criticism about the 1990 report. During this time frame, an estimated 65 billion additional board feet of CCA treated wood was sold in the United States.

The CPSC Issues New Risk Estimates

Fast forward 13 years. Now, the CPSC has completed its gigantic 2nd CCA wood review project to determine the real hazards of CCA in playground equipment, using their own field tests, their own test equipment, their own studies, methodologies, and statistical analyses. The mistakes of the past would not be repeated. Or, would they?

What were their conclusions? That children exposed to CCA wood in playground equipment from 2 to 6 years of age face an increased risk between 2 in 1 million (2 X 10-6) and 1 in 10,000 (100 X 10-6) of lung and bladder cancer.

Is this number significant? Yes, indeed. Any cancer risk of 1 in 1 million (1 X 10-6) or greater is considered relevant by government agencies for

In this case, the worst case cancer risk is 100 in 1 million, or 1 in 10,000. This is a very significant number in terms of a cancer risk, since it is a 100 fold greater risk than the 1-in-a-million risk used as a minimum threshold for regulatory purposes.

Odds of winning the Florida Lottery: 1 in 22,957,480
Odds of dying in an earthquake: 1 in 11,200,000
Odds of being attacked by a shark: 1 in 700,000
Odds of being struck by lightning in a given year: 1 in 555,000
Odds of a US citizen being killed during the 9-11 terrorist attack: 1 in 94,689
Odds of drowning in a given year: 1 in 68,000
Odds of dying from liver disease: 1 in 11,400
Odds of lung or bladder cancer from CCA in playground equipment: 1 in 10,000
Odds of dying in a motor vehicle accident: 1 in 6,700
Odds of dying from diabetes: 1 in 4,300

Sources: Florida Lottery Web site; 9/11 scenario = current US Census data and personal calculations; Boston Globe Article: "What, Me Worry", November 11, 2001, authors: George Gray, David Ropeik; US CPSC Briefing Report on CCA in Playground Equipment.

Yes, it's shocking, but the worst case risk of your child getting lung or bladder cancer from prolonged exposure to CCA wood in playground equipment is greater than the risk of them dying from drowning, being killed in a terrorist attack, being struck by lightning, or being attacked by a shark - all of which are common everyday worries for the typical parent.

A thorough reading of the massive CPSC report will reveal some interesting concepts and ideas on how to calculate the incalculable - namely, how much arsenic does a little child pick up on his hand and take into his body when he touches or plays on CCA wood playground equipment?

In spite of the painfully obvious conclusion that arsenic is a toxin and a carcinogen, and is unhealthy at any level of exposure, the CPSC desired to try to ascertain with certainty the uncertain, and come up with a one-size-fits-all formula for calculating arsenic exposure in exposed children.

The fact that there are many variables, differences and subtle nuances in the factors involved did not deter them from their task. This in itself proves that with a million dollars to spend, just about anything can be accomplished… and calculated.

To that end, the CPSC conducted exhaustive field tests on 8 decks and 12 playground structures in the Washington D.C, Maryland and Virginia area. They produced numerous individual study reports on all of the factors involved in calculating the total risk of arsenic exposure for children from CCA in playground equipment.

For example, they calculated the appropriate age range (2-6 years) for children who would be exposed, the number of days and visits per year to playgrounds (156 days per year based on 3 visits per week), the best method for wipe tests of the wood (hand vs. wet polyester vs. dry polyester vs. chamois cloth, etc.), the conversion factor for arsenic on wipe cloths vs. arsenic on human hands, the maximum "hand loading" of arsenic on the palms of a child's hand, the typical size of a child's palms, and the amount of arsenic in micrograms that a child could expect to transfer from their palms to their mouths. Needless to say, this was no small effort.

Each of these factors then became part-and-parcel of the CPSC's final mathematical equation, which serves as the basis for their proprietary deterministic model of cancer risk for children from CCA wood in playground equipment. Yes, all of these factors and data boil down to one relatively simple equation:

R = LADD X Q-¹

…where the variables are defined as:

Risk = Cancer Risk
LADD = Lifetime Average Daily Does (in mgram/kg/day)
Q = cancer slope factor, or cancer risk per unit of daily exposure (in mgram/kg/day)

[Note: the CPSC used a range of values for Q, rather than a single value. Their Q values ranged from 0.00041 to 0.023, which resulted in a range of risk results from 2 to 100 per million.]

The Lifetime Average Daily Dose (LADD) is calculated using a slightly more complicated formula:

LADD = (C X HT X EF X ED X B) / (BW X LT)

…where the variables are defined as:

C = the amount of Chemical residue on the palm side, including fingers, of both hands collected during play on a CCA-treated wood playground structure (in mgram/handload)
HT = Handload Transfers to the mouth (in handloads/day)
EF = Exposure Frequency (in days/year)
ED = Exposure Duration (in years)
B = relative Bioavailability , or amount of arsenic that would be likely to be absorbed (in percent, 100% used for this study)
BW = Body Weight (in kg)
LT = Lifetime of the average American (in days; 75 years used for this study)

As even those who are not mathematically inclined can see, modifying any of the variables (factors) in the equation above for LADD will produce a drastically different risk result. The CPSC even admits this in their report on page 318, where they state, "the staff recognizes the inherent uncertainty in the values, especially for parameters for which few data are available… it would be inaccurate to suggest that the range of risk estimates will precisely describe the actual risks for all individuals in a population, and the true risk could be higher or lower."

Realizing the inherent variability in their own equation, the CPSC went on to perform a sensitivity analysis, or a "what-if analysis", on their own formula, to "give an approximation of 'best' and 'worst' cases of risk". The worst case risk using their sensitivity analysis soared to a phenomenal 5 per 1000 (5 x 10-3), or 1 in 200! This dirty little fact seems to have escaped the news media press releases that flooded the Internet in the last two weeks.

While this level of risk may seem unlikely to some, it nonetheless means that if all factors (variables) used in the equation created by the CPSC are adjusted to their highest possible values, (i.e. maximum arsenic residue on the hands, maximum days exposure per year, lowest body weight, maximum hand-to-mouth transfers, and a longer exposure duration), the lung and bladder cancer risk for your child soars to an unbelievably dangerous level of 1 in 200! This is almost twice the risk that a person can die of heart disease in the United States.

Is a 1-in-10,000, or worse yet, a 1-in-200 risk a valid concern? Anyone who has been harmed, or whose family members have been harmed by exposure to the toxic chemicals in CCA treated wood, can assure you that it is. And, one need look no further than the EPA's own archives, where Incident reports of injuries to men, women, children, dogs and cattle can be found. [Editor's note: these reports from the EPA archives are available on this Web site on our Victim Reports page: http://www.bancca.org/CCA_Victims/CCA_victims.htm.]

Researchers and environmental advocates have been warning us for years about the risks associated with CCA treated wood, but due to industry propaganda, many have remained skeptical. The Canadian Institute for Treated Wood, for example, states in articles on their Web site (www.citw.org) that "Canadians should know that treated wood is safe to use and safe for children's playground equipment…Misinformation about pressure treated wood has caused a lot of needless worry." Another article on the same Web site provides the instruction to consumers that, "End-users need not wear gloves when handling CCA treated wood, due to the negligible dermal absorption." This last bit of irresponsible advice can certainly affect the arsenic hand-loading factor in the CPSC equation we just reviewed.

So 1.5 years, one million dollars, and 387 pages later, the results are finally in. The treated wood report-to-end-all-reports is complete, and has something in it for everyone. But, now that it is finished, can we say that we got our money's worth, so to speak? Did the CPSC meet their stated goals and objectives? Can the American consumer rest assured that their children will be protected from the hazards of CCA treated wood?

The new 1-in-10,000 cancer risk statistic has been getting a great deal of press since the release of this report February 14th. By the following day, newspaper stories about this new report appeared on over 55 news media web sites, and the stories continue to appear.

To its credit, the results published in this new report are helping to focus the attention of Congress, state agencies and the general public on the hazards of using CCA wood in playground equipment. For example, on February 24, 2003, a news release stated that the California Senate has introduced a bill to ban the production and use of the three most toxic wood preservatives-CCA, penta and creosote- and repeal their exemption from hazardous waste laws that this treated wood currently enjoys.

Another benefit of this research effort is that the CPSC has set the standard for testing CCA treated wood products, by fabricating new test equipment and designing new test procedures that can be easily reproduced and utilized by others in their research efforts.

But, for those who have taken the time to study this voluminous report, many questions remain. Questions like: Are the CPSC's results valid? Were important facts omitted from this epic research effort? Did the CPSC do all that it could have with the facts and resources it had at its disposal? Or, did this million-dollar report miss the mark?

Our own review of this mega-report found 10 major critical flaws, that illustrate why we believe that the CPSC failed to meet their stated objectives and how their report falls seriously short of its intended goals:

1. The Report Fails to Meet Its Primary Goals. The original petition filed by EWG and HBN requested that 1) the CPSC "enact an immediate ban of CCA treated wood for use in playground equipment" and 2) "the CPSC begin a review of the safety of CCA-treated wood for general use". [2]

Unfortunately, neither of these primary objectives has been achieved by the CPSC. While the CPSC mentions the upcoming EPA ban on CCA wood for residential purposes, they themselves have deferred making any decision to ban CCA themselves, even though they have the authority to do so. Nor have the CPSC made any attempt to review the safety of CCA treated wood for general use. Instead, they have chosen to wait on the EPA, who currently is under a federal lawsuit for failing to act to ban toxic treated wood. This seems to be an attempt at inter-agency buck passing on the CCA wood issue.

2. Skin Cancer Risk is Ignored. The report fails to consider the risk of skin cancer from exposure to arsenic in CCA treated wood, even though the prior 1990 CPSC report, which used limited data, showed a worst case risk of 9 in 1 million, which exceeds the regulatory threshold by ninefold. More to the point, the new CPSC report uses a more up-to-date cancer slope (cancer unit risk) value, and if this new cancer slope were applied to the original 1990 risk assessment report, it "would yield a range of cancer risks of 2 X 10-6 to 1 X 10-4, (editors note: a worst case of 1 in 10,000), which, at the upper end of the range, is more than 50 times greater than the risk estimated in the original 1990 analysis". [3].

Instead, the CPSC chose to focus their report solely on lung and bladder cancer risks, without mentioning in its press releases the added skin cancer risk. Their own report admits this when it states in the body of the report that , "Any increased risk for skin cancer from arsenic exposure would be in addition to the calculated risk for lung and bladder cancer." This appears to be a deliberate omission of facts. [4]

3. Alternative Routes of Exposure Excluded. Several alternative routes of exposure, besides hand-to-mouth exposure, are NOT addressed in this CPSC risk assessment. [5] Instead, these exposures are listed deep within the report itself, and include:

a. exposure through direct mouthing of the wood by very young children
b. direct dermal uptake
c. exposure to arsenic-contaminated soil under playgrounds
d. cross-contamination of food, clothing or other articles handled by the child
e. inhalation of airborne soil or CCA wood residue or sawdust

The fact that these other exposure pathways were excluded is alarming!

4. Other Health Risks Excluded. The CPSC failed to estimate or publish in its press release the other possible health hazards associated with CCA wood exposure, in addition to the lung and bladder cancer risks from arsenic alone. Their 387-page report includes thorough, well-documented summaries of the health risks of CCA's chemical components- arsenic, chromium and copper- yet, they have chosen to disregard these negative health consequences in their own report. The report even mentions additional cancer risks when it says that , "Strong evidence exists also links arsenic… to other cancers, including lung, bladder, liver, kidney and prostrate." [6]

Instead, the CPSC report focuses solely on the arsenic-related risks and glosses over other hazards, stating that, "Any non-cancer health risks from arsenic or potential health risks associated with the other compounds [in CCA treated wood] are not included…"

Among the disregarded risks is hexavalent chromium (or CR 6). Hexavalent chromium is used to make CCA treated wood, and the EPA classifies it as a Group A carcinogen. It is also a known toxin, and is known to cause birth defects in laboratory animals. In fact, the EPA describes its health hazards in these terms, "Chronic human exposure to high levels of chromium (VI) by inhalation or oral exposure may produce effects on the liver, kidney, gastrointestinal and immune systems, and possibly the blood." [7]

Second, some researchers conclude that the CCA formula is likely to be more toxic than just the arsenic alone, due to the negative synergistic effect of the multiple toxic metals contained in CCA. But, the CPSC chose to overlook the additive risk of exposure to the combination of toxic metals in the CCA formula in its CCA research and regulatory efforts.

Since contemporary statistical software programs, such as RiskFX, can calculate additive risks from multiple toxic chemicals simultaneously, one has to wonder why these other toxic chemicals in CCA were not included in the CPSC's risk assessment effort. By focusing solely on arsenic, the CPSC has narrowed the actual overall risk factor for CCA exposure to children and others.

5. Potential Risk for Birth Defects Ignored. The risk of potential birth defects are another important risk factor associated with CCA when people are exposed to the arsenic, chromium and copper in the wood.

During the public comment period, this author brought up the subject of the teratogenic (birth-defect-causing) effects of arsenic and chromium in a letter filed with the CPSC, stating that:

"There are serious concerns with regard to both arsenic and chromium, two of the primary chemical components of CCA (Chromated Copper Arsenate), and their potential to cause birth defects in both laboratory animals and humans. Numerous studies have been published since the early 1940s on the teratogenic effects of these toxic compounds… Therefore, the greatest risk may not be in exposing children to these carcinogenic compounds, but may instead be in exposing pre-pregnant, pregnant or nursing women to CCA-treated lumber, mulch or sawdust!"

The CPSC acknowledged this comment and responded with: "The CPSC staff agrees that there is sufficient evidence to indicate that arsenic is a probable developmenta toxicant and chromium is a probable reproductive and development toxicant in humans. However, the issue of risk depends not only on toxicity, but on the level of exposure…Arsenic causes both cancer and noncancer health effects, but the CPSC staff considers arsenic carcinogenicity to be the most sensitive endpoint… Other exposures to CCA treated wood are outside the scope of this assessment." [8] So, the CPSC's concerns for our health are limited in scope, or is it in budget? Either way, the mothers of the children that play at the playground will be unknowingly exposed to these hazards, which the CPSC failed to address.

6. Special Needs Children Ignored. The CPSC failed to consider Special Needs children in their review of CCA wood products. As an example, children with Down's Syndrome can be severely injured by exposure to CCA treated wood, due to their predisposition to increased hand-to-mouth and other oral activities, including mouthing and licking the wood.

We are aware of one courageous mother of a Down's Syndrome child, Mrs. Laurette Janak, who wrote to the EPA FIFRA Scientific Advisory Panel about this very matter last summer, and described in detail her daughter's injuries. Her letter is posted on our BANCCA Web site here:

http://www.bancca.org/CCA_Victims/Accounts/Testimony1/LJanakstory.htm

Ignoring the protection of handicapped children with regard to exposure to a toxic wood product used in playground equipment, decks, picnic tables, benches and other items across our nation borders on gross negligence.

7. Number of Samples is Too Small. The number of samples in the CPSC's million-dollar report is a very small, as they only chose to take wipe test samples from 8 decks and 12 playground structures. This is a very small 'n' for a major statistical report. In addition, all of these CCA structures were located in Virginia, Maryland and the D.C. area, and no samples were taken of CCA structures in the South, the Midwest, or on the West Coast.

8. CCA Retention Levels Not Provided for Tested Structures. Additionally, the retention level, or percentage of CCA in the wood, is not given for each structure tested. CCA levels in treated wood are typically 0.24 lbs/cubic foot, or 0.40 lbs./cubic foot, although higher retention levels are used for larger poles, and this retention level is very relevant and is likely to have drastic effects on the amount of dislodgeable arsenic extracted in a wipe test. In fact, in the report of the wipe tests for the 8 decks, the CPSC scientists made note of differences they found, stating, "There were significant differences in the arsenic levels among the 8 decks." [9]

To add to this concern, we note that 50% of the 8 decks tested were treated either with a sealer, oil finish, stain, or water repellant, which can lower the amount of surface arsenic in wipe tests. [10] In the study of the 12 playground structures, 5 of the structures are clearly indicated as having been treated with some kind of sealer, and another 5 are listed as "unknown". This certainly adds doubt about the overall levels of arsenic that would be obtained in wipe test samples of these particular structures. While they may in fact be representative of some of the decks and playground equipment, they would not be representative of untreated decks and playground equipment, which is more common and therefore a greater concern. Put another way, their study results are skewed because 50% of the structures tested have been treated with a stain, sealer, finish or water repellant.

9. No Interim Advice Offered to Consumers on How to Mitigate Existing CCA Wood. The CPSC in their report did not explore any kind of method for mitigating existing CCA wood in playground equipment, decks, picnic tables, etc. Knowing that their report would raise consumers' concerns and cause many to want to immediately dispose of CCA treated structures, some interim advice should have been provided on how to treat existing structures to protect consumers, while the CPSC and the EPA ponder the problem at length.

We note that the newly-proposed and much-welcomed California Legislature bill to ban toxic treated wood products would remove the hazardous waste exemption currently enjoyed by CCA wood, and it is possible that the consumer will be "left holding the bag", where their playgrounds and decks are concerned, not knowing whether to remove their CCA structures and risk further exposure, or merely paint over the problem and leave it intact.

The CPSC readily admits the risk of surface arsenic exposure, declaring that they will be "working with staff in EPA's OPP and Office of Research and Development to study possible mitigation measures, [such as] treating the wood with stains or sealants to decreate the amount of dislodgeable arsenic on the surface of CCA-treated wood, as CPSC studies have confirmed that dislodgeable arsenic is available on the wood surface over a period of years." [11]

10. Incorrect Classification Used for Arsenic. In their report, the CPSC has used an incorrect classification for arsenic under the FHSA regulations. [12] Under the Federal Hazardous Substances Act (FHSA), a substance can be defined as either "toxic" under 15 U.S.C. 1261 (g) or "highly toxic" under 15 U.S.C. 1261 (h). The CPSC chose to use "toxic" to describe the arsenic in CCA wood. Is that correct? What is the difference between these two designations?

The definition for "highly toxic" under 15 U.S.C. 1261 specifically states that:

(h) (1) The term ''highly toxic'' means any substance which falls within any of the following categories:

(a) Produces death within fourteen days in half or more than half of a group of ten or more laboratory white rats each weighing between two hundred and three hundred grams, at a single dose of fifty milligrams or less per kilogram of body weight, when orally administered; or

(b) produces death within fourteen days in half or more than half of a group of ten or more laboratory white rats each weighing between two hundred and three hundred grams, when inhaled continuously for a period of one hour or less at an atmospheric concentration of two hundred parts per million by volume or less of gas or vapor or two milligrams per liter by volume or less of mist or dust, provided such concentration is likely to be encountered by man when the substance is used in any reasonably foreseeable manner; or

(c) produces death within fourteen days in half or more than half of a group of ten or more rabbits tested in a dosage of two hundred milligrams or less per kilogram of body weight, when administered by continuous contact with the bare skin for twenty-four hours or less.

(2) If the Commission finds that available data on human experience with any substance indicate results different from those obtained on animals in the above-named dosages or concentrations, the human data shall take precedence.

CCA contains 34% arsenic pentoxide, which is considered "extremely toxic" by the EPA's guidelines. The EPA, under its document for CAS Registry Number 1303-28-2 for Arsenic Pentoxide, describes arsenic's toxicity in these terms:

"Health Hazards (Acute, Delayed, and Chronic): This material is extremely toxic; the probable oral lethal dose for humans is 5-50 mg/kg, or between 7 drops and 1 teaspoonful for a 150-lb. person (*Gosselin 1976). It is irritating to eyes, nose, and throat (Weiss 1980, p. 126). Chronic exposure may cause nerve damage to the extremities, alter cellular composition of the blood, and cause structural changes in blood components (*Goodman 1980). There is sufficient evidence that inorganic arsenic compounds are skin and lung carcinogens in humans (*IARC 1972-85)."

Therefore, by the EPA's own documentation, arsenic should be classified as a "highly toxic" substance, and would fall under said definition in 15 U.S.C. 1261 (h). It is important to note that the lethal dose for a 150 lb. man is as little as 5 mg/kg, or 7 drops, an amount tenfold less than the amount required as a lethal dose for rats in the FHSA definition for "highly toxic". Therefore, it is shocking that the CPSC chose to use the milder "toxic" definition instead? Why?

By the definitions in the FHSA regulations, common household bleach could even be classified as "toxic". By comparison, arsenic is considered "extremely toxic" by the EPA, and a mere 7 drops can kill a grown man! Yet, the CPSC labels it merely "toxic". Should arsenic be ranked in the same class as common household bleach? Of course not. Is this an effort to 'soft-pedal' the risk posed by arsenic in CCA wood by giving it a milder ranking? Only the CPSC scientists can answer these questions.

One can only wonder what the outcome of this report would have been if the proper classification had been used for arsenic. If the CPSC had used the correct classification for arsenic and had taken a broader, holistic view of the toxicity of Chromated Copper Arsenate- rather than simply examining only one of its chemical components-their results would likely have been even more severe, perhaps by "an order of magnitude". Then, they might have been more inclined to take the necessary action to ban this product under their own guidelines.

Assessing the Assessment

So, can we say that we got our money's worth with this report? Did the CPSC meet their stated goals? Are American consumers better protected from the hazards of CCA treated wood? Or, is it just another government boondoggle?

First, let's look at the good points of the report. It is apparent from a thorough reading of this report that the Consumer Product Safety Commission approached this project in a fair-minded manner and with good intentions. This seems indisputable. Certainly, Chairman Hal Stratton, Project Manager Patricia Bittner, and the team of CPSC scientists expended a great deal of time and effort in researching a very complicated subject, and have now published a very informative report that can serve as a valuable resource for all.

Because of their efforts, the CPSC has now set the standard for testing CCA treated wood products, by fabricating new test equipment and designing new test procedures which can be used by other scientists. And, the news about the worst case 1 in 10,000 risk for lung and bladder cancer has spread far and wide, and has even triggered new draft legislation in California.

As a result, county parks and recreation officials and school administrators will likely be quick to decide to remove their CCA treated playground equipment, picnic tables and benches and replace them with safer alternatives. This is certainly a step forward in terms of protecting the public health.

But, is this enough to warrant the one million taxpayer dollars spent? We already knew that arsenic leaches from CCA wood, that wipe tests show excessive and unhealthy amounts of arsenic, and that children put their hands in their mouths and take in this deadly toxin. All of this was already well-established fact and is nothing new.

Instead, what we got for our one million dollars was this: a new equation and a new risk number. That's it in a nutshell.

Not a ban, not a recall, no new warning labels to warn us and protect us from the hazards of cancer and birth defects and other health risks; not even a list of proper steps to follow to protect ourselves from the wood we have now, while our agencies debate what kind of paint we should slop on it in the future.

What we did get, though, was typical Washington bureaucratese: Defer, defer, defer. In effect, they said, 'Let's wait until we have more data'; 'Let's wait until the EPA makes a decision'; 'Let's hope the problem goes away on its own', …It seems that even 4 pounds of report data on a hazardous product is not enough to make a final decision in Washington.

So, is this just a government boondoggle, as our article's title suggests? A "boondoggle" is defined in Webster's Dictionary as "a wasteful or impractical project or activity…". With seemingly-obvious decisions on the fate of CCA treated wood and children's health left hanging in the balance, with final decisions left deferred, we can only wonder if this is not a fitting description.

But being optimistic, we hope that in the long run, the CPSC and the EPA will come to a consensus, and 'do the right thing' to protect consumers from toxic CCA treated wood. We hope that they will make a decision and ban this product once and for all. We hope that there will be no more victims of CCA wood. We hope that this will not all be in vain. We hope that it will not be too late…

References:
1. CPSC Project on Playground Equipment - Transmittal of Estimate of Risk of Skin Cancer from Dislodgeable Arsenic on Pressure Treated Wood Playground Equipment, August 2, 1990.
2. 2003 CPSC CCA Briefing Report, page 39.
3. 2003 CPSC CCA Briefing Report, page 25, par. 2.
4. 2003 CPSC CCA Briefing Report, page 12, par. 3.
5. 2003 CPSC CCA Briefing Report, page 24, par. 1.
6. 2003 CPSC CCA Briefing Report, page 14.
7. EPA Web site article, "Chromium Compounds", available online: http://www.epa.gov/ttn/atw/hlthef/chromium.html.
8. 2003 CPSC CCA Briefing Report, page 360-361.
9. 2003 CPSC CCA Briefing Report, page 222, par. 4.
10. 2003 CPSC CCA Briefing Report, page 211, table.
11. 2003 CPSC CCA Briefing Report, page 31-32.
12. 2003 CPSC CCA Briefing Report, page 26, par. 1.