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.
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."
THE BIG ISSUES:
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.