EPA SAP Meeting On Children & CCA In December
**2/23/04 UPDATE** Scientific Advisory Panel (SAP) report (called Minutes) which incorporates the contents discussed at this December 3-5 meeting have been given to EPA and are posted on the SAP website. The decision whether or not to uphold the preliminary risk assessment of children's short and long-term exposure to CCA-treated wood is now back in the EPA's court.
EPA's FIFRA Scientific Advisory Panel (SAP) is having an open meeting on December 3-5, 2003 in Arlington, VA to discuss the EPA's draft report on:
"Probabilistic Exposure and Risk Assessment for Children Who Contact CCA-Treated Wood on Playsets and Decks and CCA-Containing Soil Around These Structures".
Oral Public Comments will be heard at the meeting from 9am - 12pm on Thursday, December 4.
For those who cannot make it to the meeting - you may also submit your comments to the EPA using Docket No. OPP-2003-0316 preferably by November 25, but no later than December 3. You may also send your comments to Beyond Pesticides by December 2 for hand delivery to the EPA meeting.
INSIDE ANALYSIS: RELEVANCE OF THIS MEETING
In this important
meeting the SAP will either approve or criticize the methodology and conclusions
reached by the EPA in its draft report on CCA hazards to children and
will basically determine SAP recommendations to the EPA on this issue.
The SAP, however, is only advisory and although the EPA
used to always follow its advice, the agency in recent years has taken
a take-it-or-leave-it approach to SAP advice.
The actual risks to children are extraordinary when compared to EPA's usual "acceptable" threshold of one in a million (10 x 10(-6))! The risk factors with CCA in EPA's draft report are between 2,000 and 5,000 times higher than normally viewed by EPA as acceptable for chronic effects like cancer. Following protocol, the agency then looks at various mitigation measures as a means of reducing risk (which would have relevancy to existing structures).
This information is
incredibly important because as EPA itself notes in its document (p. 2-5
first paragraph) "Consumers may continue to buy and use the treated
CCA wood for as long as it is available."
While the major producers of playsets have said that they will no longer use CCA wood, there are smaller companies that are still using the lumber for decks, porches, handrails, etc. around people's homes. The way EPA "phases" out chemical exposures it knows to be harmful is unconscionable. The agency has made a policy decision to negotiate certain uses off the market and allow phase-outs (which can take years to actually remove the product from use) without any consumer notification or warning about the product and recent measures taken.
Meanwhile, the wood preservative industry is mis-informing the public about the safety of CCA wood and downplaying EPA rulings by distributing leaflets in Home Depot stores in Michigan (read the Daily News story).
THE BIG ISSUES:
* Existing structures and continued exposure
* Phase-out period where folks are still purchasing CCA-treated wood without warning or knowledge
* Retained uses that were not affected by phaseout, such as utility poles and their surrounding soils in which people are in direct contact given the placement of poles in front and back yards.
* Disposal and reuse of wood taken out of service
* Clean up of contaminated sites where soil is poisoned
Policy issues for Beyond Pesticides include the regulation of wood preservatives as a case study of the failure of EPA to adequately, and in a timely manner, protect public health and the environment. The negotiating posture of EPA on these chemicals has resulted in a lack of warning to the public about known hazards for over two decades. When EPA agreed in the 80's to allow CCA wood to continue to be sold at the retail level, it originally proposed a mandatory consumer information program and the tagging of wood. The proposal was negotiated back to a voluntary program which has result in virtually no compliance. Even under a newly negotiated warning agreement, there is inadequate notice.