Conclusions & Recommendations
This report documents the fact that the use of treated wood utility poles poses serious threats to health and the environment. The contributing industries are among the most hazardous, polluting, and under-regulated in the world. Furthermore, there are safer, less polluting alternatives readily available. The reason these alternatives are not used is plainly that every regulatory agency involved promotes the dangerous and polluting choice over the safer and environmentally sound choice, reinforcing the status quo in the marketplace.
The regulation of investor-owned utilities has given incentives for utility companies to choose an option that does not save rate payers money or protect their health and safety, but increases the profits of the investors. That option, in the case of utility poles, is choosing wood poles whose price increases on a regular basis. Economics, in the sense that most people view it, is contrary to the best interest of regulated investor-owned utilities.
EPA fails to apply its mandate to the regulation of wood preservatives. Risks to workers using wood preservatives are unreasonable in the extreme --with cancer risks in the range of one in ten or higher. And those are the known risks. As with most pesticide formulations, the identity of the bulk of wood preservative products --called "inert," but biologically active, and labelled trade secret--is kept secret from the people who are exposed to them. However, in the case of wood preservatives, the problem is much worse. Even the identity of the active ingredients (that portion of the formulation that attacks the target pest) is unknown --and unknowable-- to EPA. Wood preservatives are literally toxic soups of unknown composition. However, it is known that some of the ingredients cause cancer, birth defects and genetic damage. There is strong evidence that other ingredients cause these effects as well. Yet EPA's regulation consists mainly of voluntary safety practices, urging industry to voluntarily provide information to consumers.
In addition, EPA fails to perform its duty under the Resource Conservation and Recovery Act to regulate the disposal of wood preserving wastes and treated wood in a way that protects the environment. Through a combination of delays and specially-created loopholes, the agency has allowed these dangerous wastes to be disposed of in the most dangerous ways possible.
Furthermore, it is generous to say that regulators have allowed these bad things to happen. In fact, they have encouraged them. All of these regulatory practices have established a system of incentives that promote the use of treated wood poles over more environmentally friendly alternatives. If wood preservative manufactures were forced to control the manufacturing process to create a known product, and perform adequate tests on these products, then their products would become more expensive. If EPA considered alternatives beyond other (unknown) wood preservative chemicals, and weighed risks as heavily as it does corporate profits, then most wood preservatives would be banned. Even if EPA failed to regulate wood preservatives as pesticides but placed adequate consumer warnings on products and regulated the hazardous wastes produced by the industry as hazardous wastes, wood preserving would become too costly to perform on such a large scale.
And on the other side, we have seen that one alternative to treated wood poles has been made more hazardous by EPA's action. EPA encourages the incineration of hazardous wastes in cement kilns, leading to the dispersal of those wastes in the environment (but especially in the neighborhood of cement kilns and ready-mix plants) and the contamination of concrete products.
There are more lessons to be learned from this examination of treated wood poles.
Wood preservative chemicals provide an excellent example of why risk assessment is doomed to fail in protecting human health. Each of these formulations --penta, creosote and copper chromated arsenic-- is composed of a number of toxic ingredients --sometimes by design, sometimes by happenstance. Unlike most pesticides, though, we happen to know something about the interactions of some of the ingredients in wood preservatives, and we know that the effects are synergistic --the potency of the combination is greater than the sum of the effects of the individual ingredients. Risk assessments performed on individual ingredients cannot predict the effects of the entire formulation when ingredients are synergistic.
Chemical management over prevention
We have seen that utility regulators and EPA combine to promote the use of utility poles treated with toxic chemicals. The regulatory agency is overwhelmed with vested interests that are financially tied to the status-quo. The public interest mandate is lost to the special interests. Regulators do not look around in an effort to promote reasonable approaches that prevent the very problems we are always trying to control fruitlessly. In so doing, government does not provide a climate for innovation and ecologically sound alternatives because it promotes existing practices that pollute. When combined with a regulatory agency that habitually underestimates risks and assumes benefits based on regulatory politics rather than scientific practice, the net effect is a powerful incentive to use pesticides to eradicate instead of ecology to mitigate pest problems --all at a cost of dispersing powerful toxic materials throughout the environment.
The nexus for change is in communities across the country
With a failed regulatory system co-opted by politics and special corporate interests, the focus of action must shift to local communities and the marketplace in which utility companies operate. On a basic level, the line staff people interviewed for this report are becoming aware of the hazards associated with treated wood poles. Many have begun to consider alternative pole materials. But the process of change must be more widespread and at a pace that suggests a greater understanding of the urgency surrounding the environmental degradation and human health effects of wood preservatives. The public can and must lead the way as EPA puts critical health and safety questions on the proverbial backburner. There is enough evidence in this report and in the extensive list of resources cited to justify a swift and concerted effort to phase out the purchase and use of preservative-treated wood poles.
What community groups can do:
Beyond the need for local action, the public should make government work on its behalf.
The regulatory process must change to represent the public interest. Contact the Environmental Protection Agency (EPA) headquarters to let environmental officials know that you are dissatisfied with the level of protection provided by the agency. [Write Carol Browner, Administrator, U.S. Environmental Protection Agency, 401 M Street, SW, Washington, DC 20460]
Tell EPA that you are concerned about the continued use of these hazardous wood preservatives, that these chemicals should be removed from the market and that the situation calls for the following policy changes to prevent the agency's continued failure to regulate chemicals as hazardous as these:
PROHIBIT mixtures of pesticides for which EPA cannot identify the constituent ingredients, their contaminants and breakdown products.
Join with the National Coalition Against the Misuse of Pesticides
Stay informed about what you can do on an ongoing basis to protect yourself, your family and community from hazardous pesticides and promote safe alternatives. Contact NCAMP at:
701 E Street, SE
Washington, DC 20003