Canadian Association of Physicians for the Environment
November 10, 2001
Dear Ms. Barrie,
I am writing to you now to express CAPE's support for your efforts to achieve a ban, or at the very least a sharp restriction in the use of wood treated with chromated copper arsenate (CCA).
As you are no doubt aware, this substance was originally developed in the 1930's, in an era when toxicity testing of industrial chemicals was negligible. It has come under increasingly scrutiny since the 1970's, with voluntary warnings sought from companies by the U.S. E.P.A. in 1984, and increasingly through mandatory warnings today. There is a regulatory process in place to set out voluntary warnings in Canada next year, and the EPA may well put mandatory warnings or use restrictions in place next spring.
We feel that such a toxic substance - in particular one containing arsenic and inorganic chromium, both of which can act as neurotoxins - should no longer be employed as a wood preservative, and should be quickly removed from sites frequented by children. CCA leaches from the wood in which it is impregnated, and can cause dermal toxicity of considerable significance. Ash from burned CCA-treated wood is highly toxic, and can contribute to the burden of dangerous fly-ash currently generated by municipal incinerators. Arsenic is, furthermore, a known carcinogen. It is particularly reprehensible that CCA-treated wood is still used in locations where children or pregnant women might have contact with it - given that these are the most vulnerable sub-populations in our society.
If there were no alternative products, government regulators might be forgiven for allowing CCA to continue to be widely used. But less toxic alternatives exist and are becoming more widely available all the time. One of these is ACQ, wood treated with alkaline copper quaternary ammonium; others, which are even more benign, include cedar, stained spruce or fir, pre-cast concrete, larch, and possibly composite decking.
In short, you are to be commended for coordinating attempts to achieve an elimination of CCA-treated wood, or at the very least its sharp restriction and the placement of stringent and detailed warnings about its used and toxicity. CAPE wishes you well in your ongoing efforts.