Questions and answers on the wood preservation industry
These questions and answers have been put together to help outline the findings of DEC's work with the wood preservation industry. These findings are reported in full in the Environmental Compliance Report: Wood Preservation Industry—Part A Compliance Audit (partacomplianceaudit.pdf 190kb requires Acrobat reader) and Environmental Compliance Report: Wood Preservation Industry—Part B Review of Best Practice and Regulation (partbbestpractice.pdf 111kb requires Acrobat reader) and Environmental Compliance Report: Wood Preservation Industry—Part C Final Report (woodpresc.pdf 204 kb requires Acrobat reader)
What is the DEC's role with the wood preservation industry?
Why treat timber with chemicals?
What chemicals are used as preservatives?
Does CCA-treated timber present a risk to my family?
How can I tell if my deck or other outdoor structures are made of CCA-treated timber?
What should I do if I have a CCA-treated timber deck or CCA-treated playground equipment?
What other kind of treated timber can I use instead of CCA-treated timber?
How should I dispose of any CCA-treated timber waste?
Why is the DEC focusing on the wood preservation industry?
What is DEC's environmental compliance program?
What are the key findings of the DEC's audit of the wood preservation industry?
What are the key findings of the DEC's review of best practice?
What are the key outcomes of DEC's review of wood preservation licences?
What are other countries doing?
What is DEC's role with the wood preservation industry?
The EPA (now part of DEC) regulates larger wood preservation premises under the Protection of the Environment (Operations) Act 1997 (POEO Act), by issuing 'environment protection licences' and carrying out a range of checks to make sure licensed facilities operate with the right environmental controls. Local councils regulate wood preservation activities that treat less than 10,000 cubic metres of timber per year.
The EPA also regulates pesticide use (including wood preservatives) in NSW, under the Pesticides Act 1999. The Commonwealth Government body, the Australian Pesticides and Veterinary Medicines Authority (APVMA), is responsible for the approval, registration and labelling rules regarding each pesticide. The APVMA has released a draft report for public comment on the review of arsenic based timber preservation products.
The use of some preservatives in the past, and poor operational practices leading to land contamination, have meant that the EPA has also regulated some wood preservation facilities under the Contaminated Land Management Act 1997.
Further details on the DEC's role with the industry are contained in 'Wood Preservation Industry: Part B Review of Best Practice and Regulation' (partbbestpractice.pdf)
Why treat timber with chemicals?
The wood preservation industry treats timber and wood products with chemical preservatives to protect the wood from degradation due to various organisms including fungi, and insects such as borers and termites. This treatment extends the range of applications and the service life of the wood. By design, the chemicals used to protect wood must be toxic to the target organisms, but they may also affect non-target organisms and the environment.
What chemicals are used as preservatives?
The following groups of preservatives are currently registered for wood preservation use in NSW:
- copper chrome arsenate (CCA)
- copper-based alternatives to CCA (ammoniacal copper quaternary (ACQ) and copper azole)
- boron
- creosote
- pyrethroid- and metal-based light organic solvent preservatives (LOSPs).
What is CCA?
Copper chrome arsenate (also known as CCA or chromated copper arsenate) consists of three metals: copper, chromium and arsenic. All three metals pose a risk to the environment. Both hexavalent chromium and arsenic can cause cancer in humans. CCA concentrate is diluted with water to create a working solution that is used in the pressure treatment of timber.
CCA-treated timber is commonly a greenish colour, but this is also common with the other copper-based preservatives. CCA-treated timber is registered for use in NSW under the Timber Marketing Act 1977. The Act is administered by the Department of Primary Industried (incorporating State Forests NSW). The registered uses include internal building uses and external uses such as decks, walkways, fences, playground equipment and retaining walls, and some marine water applications such as wharfs and jetty piles.
Does CCA-treated timber present a risk to my family?
Published results of scientific studies indicate that copper, chromium and arsenic slowly leach from CCA-treated timber products. All three metals pose a risk to human health and the environment, but also exist naturally in the environment in varying concentrations.
The Commonwealth Government body which registers chemicals for use, the Australian Pesticides and Veterinary Medicines Authority (APVMA), has released a draft report for public comment reviewing the risk CCA-treated timber poses to the community. The review found that at this stage it has insufficient information to be satisfied that continued use of CCA treated timber is safe when used in the manufacture of structures where the general community are likely to come in frequent close contact. As a result the APVMA is proposing that such use no longer be permitted.
The New Zealand Environmental Risk Management Authority (ERMANZ) and the APVMA have suggested some common sense tips to minimise unnecessary exposure to CCA-treated timber:
- Treated wood should never be burned in open fires, stoves, fireplaces, or residential boilers.
- Always wash hands thoroughly after contact with any treated wood, especially before eating and drinking.
- Food should not come into direct contact with any treated wood.
- Precautions should be taken to wear protective gear when working with CCA-treated wood.
Health information about CCA and treated timber is also available from NSW Health.
How can I tell if my deck or other outdoor structures are made of CCA-treated timber?
It is hard to tell just by looking at it. CCA-treated timber is commonly a greenish colour, but this is also common with the other copper-based preservatives. Unless your outdoor structure has been constructed with hardwood, it is most likely that it has been made of CCA-treated timber.
What should I do if I have a CCA-treated timber deck or CCA-treated playground equipment?
The Australian Pesticides and Veterinary Medicines Authority (APVMA) draft review does not recommend the removal of existing structures. However, APVMA will continue to monitor the issue.
The US EPA, the Canadian Pest Management Regulatory Agency and the New Zealand Environmental Risk Management Authority (ERMANZ) have all stated that they are not recommending that existing structures or surrounding soils be removed or replaced. While available data is limited, studies cited by the US EPA suggest that regularly applying certain penetrating coatings, for example, oil-based semi-transparent stains, can reduce exposure to CCA.
What other kind of treated timber can I use, instead of CCA-treated timber?
Alternative wood preservatives, not containing arsenic or chromium, are available in Australia. Timber that has been treated with alternative wood preservatives is also registered for most of the construction uses that CCA-treated timber is used for.
How should I dispose of any CCA-treated timber waste?
Small quantities of household CCA-treated timber waste (e.g. offcuts from a small DIY job) could be placed in your rubbish bin, with the rest of your household waste. CCA-treated timber waste from larger household building and demolition jobs is classified as inert waste, and can be disposed of to most suburban landfills. You should tell the landfill staff if you have CCA-treated timber in your load.
DEC considers that CCA-treated timber waste from industrial sources should only be disposed of to certain landfills, in accordance with DEC's 'General approvals of immobilisation of contaminants in waste'.
CCA-treated timber waste must not be burned or used as mulch/soil amendment.
Why is DEC focusing on the wood preservation industry?
DEC selected the wood preservation industry to pilot a new 'comprehensive approach' to environmental compliance because the industry faces a range of environmental issues relating to air, water and land, and the preservative chemicals used have a potentially high environmental sensitivity.
DEC believes that the findings of its reports will guide how it regulates the industry, and be useful to local councils who regulate about two-thirds of the wood preservation facilities in NSW.
What is DEC's environmental compliance program?
DEC's environmental compliance program is designed to gauge how well an industry is complying with its environmental controls. It includes site inspections, annual compliance reporting by licensees, compliance audits, licence reviews, education and enforcement activities.
DEC has piloted a new 'comprehensive approach' to environmental compliance activities with the wood preservation industry. A key focus, in addition to assessing compliance with existing requirements, is a review of industry best practice and global trends, with the aim of securing improvements in industry environmental performance.
In June 2004 DEC commenced a comprehensive program looking at liquid chemical storage, handling and spill management.
What is a 'compliance audit'?
Compliance audits assess a licensed premise's compliance with environmental laws administered by the EPA. The audits are unannounced and are conducted in accordance with established procedures and protocols.
The findings of each audit and a follow-up action program based on the audit findings are reported in a compliance audit report sent to the audited enterprise. Copies of each audit report are available through the DEC library.
DEC follows up with each audited premises to ensure that all actions identified by the audits are carried out.
Further details on the findings of the audits of the wood preservation industry are contained in 'Wood Preservation Industry: Part A Compliance Audit' (partacomplianceaudit.pdf; 190kb requires Acrobat reader) and are also reported to the community through the media.
What is a 'licence review'?
As set out in section 78 of the POEO Act, the EPA (now part of DEC) reviews environment protection licences every three years. These reviews are aimed at ensuring the accuracy of licences and ensuring that they are consistent with similar licences and industries. The reviews also contribute to licence variations that result in improvements in industry environmental performance.
Further details on the reviews of licences issued to the wood preservation industry are contained in 'Wood Preservation Industry: Part C Final Report (woodpresc.pdf; 204 kb requires Acrobat reader).
What are the key findings of the DEC's audits of the wood preservation industry?
The audited sites were not fully complying with their licence requirements.
DEC found that surface water on three of the five audited wood preservation sites had stormwater that was contaminated with chemicals including arsenic, chromium and copper. Most audited sites were not properly maintaining drains, dams or treatment areas, which could lead to soil and groundwater contamination. Since the audits, DEC has checked that licensees have taken action to deal with these non-compliances.
The audited sites were also not following some parts of the industry's best practice guidelines and Australian Standards relating to wood preservation plants. These issues were considered during the review of all licences for wood preservation premises.
What are the key findings of DEC's review of best practice?
DEC found that Australian Standards contain most of the best environmental management practices used in the industry worldwide. Where appropriate best practices are not contained in the standards, DEC has asked the industry to consider a review of the standards to address these matters.
While DEC has identified best environmental management practices for those facilities using CCA to treat timber, the use of CCA itself as a timber treatment may need reconsideration.
What are the key outcomes of the DEC's review of wood preservation licences?
The DEC has made changes to environment protection licences to better align our regulation with best environmental management practices, and has also recommended changes to the licensing provisions of the POEO Act.
DEC is also continuing to pursue ongoing issues regarding the wood preservation industry including pesticide registration, treated timber waste and possible enhancements of the industry code of practice, AS/NZS 2843 Timber preservation plant safety code.
What are other countries doing?
DEC found that the wood preservation industry is moving away from using pesticides such as CCA and creosote. This trend appears to be driven by recent European risk assessments of arsenic, the application of the 'precautionary principle' and by perceived consumer demand shifts in North America.
US
The US EPA has facilitated the voluntary phase out of CCA-treated timber for most residential uses, following an application to do so from the wood preservation industry. From 1 January 2004 CCA products may not be used to treat timber intended for most residential uses.
Europe
In June 2004 the European Commission placed a partial prohibition on the use of CCA-treated timber. In addition to the residential uses being restricted in the US and Canada, CCA preservatives must not be used in the EU for timber destined for marine and most agricultural uses.
New Zealand
The New Zealand Environmental Risk Management Authority (ERMANZ) has decided not to change the registration of CCA following a 2003 review of the potential public health risks arising from the continuing use of CCA-treated timber. ERMANZ found that the extent of any risk to public health arising from CCA remains unclear but is considering further investigation into the possible environmental and occupational health risks arising from CCA.
What are the next steps?
DEC is also continuing to pursue ongoing issues regarding the wood preservation industry including pesticide registration, treated timber waste and possible enhancements of the industry code of practice, AS/NZS 2843 Timber preservation plant safety code.
The Australian Pesticides and Veterinary Medicines Authority (APVMA) is expected to release a final report on the review of arsenic based timber treatment products in 2005.
If you have any questions about the availability and registration of wood preservatives, you may wish to contact the APVMA.