Summary of the TPAA survey on members treating with CCA

The Australian Pesticides and Veterinary Medicines Authority (APVMA – formerly known as the National Registration Authority or NRA) is conducting a review of arsenic in timber treatments. This includes CCA and arsenic trioxide, used as a “dust” for termite control.

In response to this action, the Council of the TPAA has collated a response from the Association to address issues of fact about the use of CCA since its introduction to Australia more than four decades ago.  This information will help demonstrate to the APVMA that when used appropriately and correctly, CCA represents minimal if any significant risk to human health, even to those who are directly involved in manufacture and would be expected to have a high potential for exposure.

This, compiled with all our returned surveys, will form the basis of our submission to the APVMA to defend/justify the on-going use of CCA.  The CCA-treaters in New Zealand through the New Zealand Timber Preservation Council have also participated in this survey so that our submission will be Australasian-based.  Naturally, you are also entitled to respond to the APVMA as an individual company. Refer to the APVMA website for further details on the review (www.apvma.gov.au/chemrev/arsenic_scope.pdf).

The results of the survey are as follows:
 

Question		Responses
How long have you been operating a CCA treatment plant (in years)?		1-45 (av. = 24.1 n = 22)
Which of these options best describes your operation?
(a) Wood processor (sawmill) also with treatment facilities		15
(b) Specialist treated timber only producer		11
(c) Treatment service provider		3
(d) Other (please specify)		8
		(n = 28)
How many employees do you currently have at the:
(a) plant (treatment vessel, tanks, pumps, drip pad, etc.)		1–5 (av. = 2.1 n = 21)
(b) yard (area for storage of treated stock)		0-9 (av. = 3.3 n = 19)
(c) site (total premises)		2-180 (av. = 51.5; n = 28)
Based on your employment records, how many individuals have worked in the treatment plant site over the years?		1-200 (av. = 26.3; n = 29)
Your employees will have been medically monitored from time to time. Please indicate if there have been any reported adverse health effects related to their work with CCA solutions or CCA-treated timber (including individuals who may have left your employment).		27 with no reported adverse health effects 1 with elevated As levels; subsequent analyses normal (n = 28)
During your time of operation, have you received any claims/notifications from any of your customers in relation to claims of adverse health effects from your supply of CCA-treated timber?		No – 25 Yes – 3 (n = 28)
What were the notified adverse health effects?		Nauseous feeling when moulding treated timber in enclosed factory area; Minor rashes; Burning throat from inhaled surface contaminants (n = 3)
Do you brand / tag / label / mark your treated product so that the consumer knows what they have purchased and where it may be used?		Yes – 22 No – 6 (n = 28)
What handling and safe using instructions do you place on your product labels?		None – 23 MSDS – 1 Safe handling advice - 4 (n = 28)
Please estimate/collate the volume of CCA-treated timber you produce per year and, if possible, show the figures in cubic metres per Hazard Class, e.g. 8,000 m3 H4, 1500 m3 H5.		H1: 2,400 (n = 1) H3: 600 - 30,000 (av. = 6,138; n = 15) H4: 1,200 – 23,000 (av. = 3594; n = 18) H5: 500 – 12,600 (av. = 4,120; n = 5) H6: 60 (n = 1) Total: 3,700 – 39,000 (av. = 22,900; n = 6)
Do you treat in accordance with and to the requirements of AS1604 series of Standards?		Yes – 28 (n = 28)
Does your treatment plant conform to AS2843 or similar specifications?		Yes – 26 No – 3 (n = 29)

Conclusions:

The TPAA had 29 responses from its survey (a 60% return).

The respondents treat some 406,000 m³ of softwood and hardwood with CCA – about 40-45% of the estimated total of CCA-treated timber consumed in Australia each year. They have a collective experience of more than 4,000 years of treatment plant operation with all but three of the plants conforming with the requirements of good operating practice. They employ about 800 staff and have only experienced one case of adverse health effects related to the use CCA – in this case the elevated As levels returned to normal upon repeat sampling. (Two additional elevated As levels were noted as a result of heavy consumption of seafood prior to sampling, but not as a result of using CCA preservative.)

Only 3 customers using CCA-treated timber supplied by the 29 respondents have reported any adverse health effect (nausea, minor rashes, and burning throat from inhaled surface contaminants – dust?) as a result of handling/working with the timber. The case of nausea was reported to have been caused by machining the CCA-treated timber in a confined space (poor ventilation?).

More than 78% of the treaters identify their product with some form of branding, though all respondents claim to treat in accordance with the national Standard (AS1604). Less than 15% of treaters issue safe handling instructions to consumers and clearly this situation must be improved upon if the industry is to accept some measure of responsibility for its products.

Three of the 29 treaters responding to the survey operate treatment plants that do not conform to best practice, as set down in AS/NZS 2843 and similar guidelines.

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