Submission by Friends of the Earth  Melbourne
312 Smith Street, Collingwood, 3066
Postal Address:  Po Box 222, Fitzroy, 3065
Principle Contact:  Anthony Amis
Position:  Plantation Research Officer
Ph: (03)9419 8700
Fax:  (03) 9416 2081
Email:  anthonyamis@hotmail.com

THIS SUBMISSION CONTAINS NO CONFIDENTIAL MATERIAL

Commonwealth Productivity Commission
Inquiry into waste generation and resource efficiency
Product Commission
Locked Bag 2,
Collins St East,
Melbourne, Vic 8003

Treated Pine Waste

February 2006

I would to like to submit the following paper, concerning issues surrounding Treated Timber and its disposal.  I believe that this is a very substantial waste disposal problem that will increase in significance in the coming years.  
The recent decision by the APVMA to ban the use of treated pine in certain circumstances where people, especially children are exposed to CCA timber is welcomed, however it is Friends of the Earth’s position that the ban did not go far enough because it did not address issues surrounding dismantling of existing CCA structures or issues concerning waste disposal.

The following websites provide further crucial information;
http://www.uow.edu.au/arts/sts/sbeder/CCAtimber/waste/intro.html
http://uow.edu.au/arts/sbeder/CCAtimber/CCAreport.pdf
http://www.ccaresearch.org/
http://www.bancca.org/
TREATED TIMBER - WHY ALL THE FUSS?
(Anthony Amis - Friends of the Earth Forest Network Melbourne - January 04).
People may recently have learnt about the controversy surrounding the use of treated timber. For instance the Age Newspaper ran a front page article on December 23 2003, entitled ‘Cancer Alert on Treated Timber’, whilst ‘A Current Affair’ have featured two stories on the treated pine industry in the past 6 months. Most of the concern has been generated by the use of Copper Chrome Arsenate (CCA) timber in children’s playgrounds. This issue hit main stream media in the US and Canada about 2 years ago, with the Australian media taking a little longer to catch on. 
CCA is an impregnation process where timber, mostly pine, is treated under pressure with a solution consisting of Copper, Chromium and Arsenic. The timber is treated so that it doesn’t rot and is protected from insect and fungus. The solution is supposed to impregnate the wood and is supposedly fixed to the timber. However recent tests conducted in the US have shown that the chemical solution leaches and this has also been proved in Melbourne, where swipe tests conducted by the Croydon Conservation Society in early 2003 revealed that a treated pine playground in Croydon leached 710 micrograms of arsenic, 630 micrograms of chromium and 670 micrograms of copper in only one metre of timber! 
Arsenic is a known carcinogen, and fears have been raised that children playing on these structures could ingest arsenic if they put their hands in their mouths after playing on playgrounds or treated pine house decks. So serious is the problem that the Federal Government regulator, the Australian Pestcides and Veterinary Medicines Authority (APVMA) is considering banning CCA timber in applications such as, timber playgrounds, house decks and fences in early 2004. 
The issue that hasn’t been discussed by the media is that treated timber remains toxic and cannot be landfilled or burnt when it needs to be disposed. This ultimately means that after the timber has reached its use by date after 30-40 years, the timber needs to go somewhere. The only problem is that noone really has a solution to this burgeoning waste problem - a problem that will only worsen over the next decade as potentially millions of cubic metres of treated pine reaches its use by date. At least 50% of treated timber is used for posts and poles. The biggest users of treated pine in Australia is the wine industry. This use has escalated over the past decade with the expansion of the industry. 
In regards to vineyards (Australian Pesticides Veterinary Medicines Authority December 2003 Technical Report p74) the average life expectancy of vineyards is between 20-30 years, often meaning that large percentages of the CCA treated posts have to be removed/destroyed. 15% of posts are replaced each year in NSW, but almost all of the 13.2-26.4 million posts will have to be replaced by 2030 in NSW alone! How is the wine industry attempting to deal with this issue? What impact is this huge use of treated pine posts having on the heath of agricultural/viticulture workers who have the responsibility of replacing and using CCA timber each day? (the same could be said about fence builders and house builders, timber yard workers, treatment plant workers who have to lift, carry and work with CCA timber most days of the year). Given that all of these posts will most likely leach CCA into soil what impact will such a large amount of CCA treated pine posts have on the health of soil etc in vineyards? 26 million posts is a large amount of leachate entering wineyard soils.
Current treated pine pole disposal methods for the wine industry have included burning the waste. This is an extremely dangerous exercise, not only for the people tending the fire, but anyone downwind of the fire itself. Vineyard operators have been fined for burning their waste timber in Victoria and elsewhere. A practice which sullies the industries name. Workers in vineyards are also at some risk when working with the treated timber. Splinters and hand wounds allow arsenic to enter the body and can cause arsenic poisoning - as well as the ingestion of arsenic caused by arsenic on hands etc. 

“The greatest potential for environmental harm is considered to be from leaching or preservation chemicals from the treated timber to the soils thereby impacting on soil quality, surface water quality and possible groundwater quality”
“…increased amounts of preservative chemicals are likely to result in environmental impact from landfills unless these landfills are suitabely engineered. Impact on surrounding groundwater and soils is likely to occur if these levels were exceeded and leachate from the landfill contained significantly high levels of PAH’s, pyrene, PCP, chromium, copper or arsenic” 
1. Chromium and Arsenic leaching from landfills has recently been detected in Florida and is a major environmental worry. http://www.gainesvillesun.com/apps/pbcs.dll/article?AID=/20030907/LOCAL/209070333 Tests conducted by Friends of the Earth in late 2002 at a timber yard in Port Melbourne revealed arsenic, chromium and copper in the soils - leading to claims that the site was contaminated. Wine growers who use treated pine posts and who store their discarded posts on site may in fact be contaminating their properties, leading to potential problems in the valuation of their land! 
Pollution problems at treatment facilities are another major headache with many spills occurring over the past 2 decades. A major spill in Mount Gambier in 1995 threatened that towns water supply (and possibly still threatens water quality). The water supply at Dartmoor in western Victoria had to be shut down in 1996 after an inground tank holding the CCA solution, rusted and 8000 litres escaped into the ground. A housing development in Armidale NSW had to be dismantled after it was learnt that houses had been built on a contaminated site that was once used for treating timber. In 1993, Greenpeace New Zealand identified over 600 contaminated sites where the timber treatment pentachlorphenol had been used. The treatment sites were contaminated with Dioxins. The wine industry by associating itself with such a polluting industry is leaving itself wide open for criticism and potential boycotts. Not to mention ethical considerations such as the fact that most of the arsenic used in CCA is sourced from mines operating in China, a country well known for human rights abuses. It would be a far safer option for the industry to opt for more environmentally friendly timber treatments and alternatives. 
On a more positive side, it would appear that grapevines and grapes do not absorb arsenic, meaning that leachate from CCA treated poles in vineyards will not be a problem for grapes (as it can be in other plants) “A study of the uptake of metals from grapevines in proximity to CCA-treated timber has shown no evidence for accumulation of metals in leaf and stem tissue over a 3 year period” (Levi, Huisingh and Nesbitt 1974). 
THE ALTERNATIVES
The best alternative would be natural hardwood fence poles and posts. But the major problem here is that overexploitation of the native forests of Australia has led to a situation where the removal of any old growth trees or logging in high conservation value forests must be avoided at all costs. Redgum fence posts for instance are not an environmentally friendly alternative unless they have been grown in an agroforestry context. Most durable plantation species grown in Australian plantations are grown for woodchips and not sawn timber. The current burgeoning bluegum plantation industry could be a possible alternative, although fenceposts from bluegum plantations will have to be planned prior to planting and due to the young age of the plantation wood may have to be treated with chemicals. Young bluegum will also most likely warp and crack if cut at a young age. 
Creosote treated pine poles must be avoided at all costs due to the myriad of chemicals that constitute this treatment. Likewise LOSP’s Light Organic Solvent Preservatives) can contain nasty chemicals such as Tri-butyl -Tin). 
The most widely acknowledged ‘environmentally friendly’ alternative to CCA is another treatment called ACQ (Ammoniacal Copper Quaternary) and is also used on pine poles. ACQ consists of not less than 45% copper oxide, which is often sourced from recycled copper and not less than 30% Didecyldimethylammonium (DDAC). ACQ is far from perfect, as it can leach more copper to the aquatic environment than CCA and copper is extremely toxic to fish. There is still problems with disposing ACQ as it cannot be burnt due to copper residues. But by and large ACQ is less toxic than CCA and it is increasingly being used as an alternative in the United States, although it is relatively difficult to come by in Australia and it will cost more than CCA. At this stage Friends of the Earth is unsure if DDAC will be problematic for grapevines. 
A company called OMNIPOL make recycled plastic posts in South Australia, although these posts cost about $1 more than CCA posts. This idea has merits as the poles will last indefinately and can be used over and over again. 
Boron salts and Lanolin may also provide some possible alternatives to CCA. Lanolin (wool grease) is a natural oil and may the best of all possible treatments for timber but further research would need to be carried out to determine its potential - including tests to determine whether the lanolin has been contaminated with dioxin laced sheep dips. An Australian company Lanotec may provide further details about the exciting potential of Lanolin 
CONCLUSION 
The Australian wine industry needs to become proactive in working towards developing environmentally friendly timber treatments. The industry needs to put pressure on companies who supply and produce treated timber to switch away from CCA and onto more environmentally friendly alternatives such as ACQ and Lanolin. The wine industry needs work with companies that currently produce alternatives and use their purchasing power to create markets for non-toxic forms of timber treatments. They should boycott the use of CCA and companies that produce CCA timber and actively buy from companies making the alternative products. If the industry continues to sit on its hands about this issue, it could very well be inviting severe criticism and possible boycotts on its products. 
In the mean time FoE supports these recommendations outlined in the 1999 Sinclair Knight Merz report on treated timber in South Australia; 
*Wineries/vineyards should become involved in developing a nationwide Code of Practice for land care. The Code of Practice must address the bulk storage of treated timber and the curtailing of site burial and other methods of disposing treated timber products which are potentially harmful to the environment. 
*Individual wineries,vineyards should be encouraged to develop their own environmental management plans. If they already have such plans they should be developed so as to incoporate consideration for the appropriate disposal and storage of treated timber. 
*The EPA should consider advising wineries who are unaware of alternatives to treated timber that there are benefits in using these products such as an improved “greener” image for the winery. 
1. Review of the Lanfill Disposal Risks and the Potential for Recovery and Recycling of Preservative Treated Timber - Sinclair Knight Merz Pty Ltd - November 1999. (http://www.www.environment.sa.gov.au/epa/pdfs/timber.pdf) 

The Australian & New Zealand Grapegrower and Winemaker April 2004 (Ryan Publications) 
CCA REVIEW IMPLICATIONS FOR VITICUITURE 
Tony Smith and Dr Mahabubur Mollah Primary Industries Research Victoria. Department of Primary Industries - Mildura 
What is CCA-treated timber? 
Most vineyard owners are familiar with CCA-treated timber; timber treated with a copper, chrome and arsenate (CCA) salt treatment that makes it less susceptible to rot, fungi, termites and other wood-boring insects. CCA-treated pine posts have been used extensively for trellising in vineyards across Australia and overseas, as well as for domestic building, landscaping and outdoor furniture. The life of timber products can be significantly lengthened as a result of CCA treatment. 
What is the issue? 
The Australian Pesticides and Veterinary Medicines Authority (APVMA), national registration authority for agricultural and veterinary chemicals, has undertaken a review of CCA chemical products used to treat timber. APVMA controls the registration, labelling and supply of agricultural and veterinary chemical products. The review was encouraged, no doubt, by the USA and European Union reviews of CCA-treatments. These reviews were initiated due to concerns about the potential exposure of humans (children in particular) to elevated levels of arsenic and chromium from CCA-treated timber structures, including playground equipment, decks and outdoor furniture. The US Environmental Protection Agency has made no conclusion about the risk to the public from CCA-treated timber products, but is of the view that any reduction in exposure to arsenic is desirable. Subsequently in the USA, CCA-treated timber products are being phased out for use in domestic situations such as decking, outdoor furniture and playground structures. 
Why are there concerns about the CCA review? 
The Australian wine industry is susceptible to changes in legislation or regulation regarding CCA-treated timber, due to the significant volumes of treated pine used as trellis posts in established vineyards. In 1999, a report prepared for the South Australian EPA found that wineries were the largest purchaser of preservative treated timber in South Australia, mostly CCA-treated timber. Estimates based on ABS statistics for the area of vines planted indicate that there are between 60 and 120 million posts currently used for trellising in Australian vineyards. Approximately 75% of these are CCA-treated timber posts. 
What are the recommendations of the APVMA? 
The APVMA released a draft review in December 2003 for public consultation, on which comments were sought until 29 February of this year. The draft review has made five key recommendations. 
CCA timber treatment products be declared Restricted Chemical Products. It is in the public interest to ensure that supply of these products will be restricted to suitably trained persons. 
CCA product labels be varied to recommend that timber treatment facilities be designed and operated to meet appropriate Australian Standards (ANZEC guidelines 1996, and AS/NZS 2843.1 2000). 
Product labels be varied so that uses of CCA timber treatment products are not permitted on timber intended for use in structures such as picnic tables, decking, handrails and children's play equipment. 
Product labels be varied to include more detailed instructions for application, mixing and vacuum/pressure operations, management of freshly treated timber, management of liquids, sludge or waste material containing CCA residues, protection of wildlife, fish, crustaceans and the environment, and storage and disposal. 
Registrants be required to generate worker exposure data in relation to risks associated with arsenic and chromium (VI) in CCA. 
It is expected that the review will be finalised by mid 2004. 
What are the implications for viticulture? 
So what does all this mean for vineyard owners and managers? As such the APVMA is recommending that no new CCA-treated timber should be used for domestic use (Recommendation 3). There is no such recommendation relating to the use of CCA treated timber in viticulture or other horticultural production. The APVMA states that there is no evidence to preclude use of arsenic-treated timber products where there is no frequent physical contact, such as telegraph poles, rural fence posts or other structural timbers." Many grapegrowers will sigh with relief at this outcome; the continued use of CCA-treated posts in vineyards is assured. 
Recommendation 1 seeks to declare CCA-treatments as Restricted Chemical Products. A Restricted Chemical Product may be declared under the Agricultural and Veterinary Chemicals Code Act 1994, and the Agricultural and Veterinary Chemicals Code Regulations 1995. A product can be declared a restricted chemical product if the APVMA advises that it is in the public interest for the product to be declared restricted. This recommendation will tighten controls on who will be able to conduct CCA-treatments of timber, and will prescribe a level of training that is deemed necessary to reduce the risk of poor treatment, or environmental problems (leaks, spills) resulting from the treatment. 
2 will result in greater accountability a! environmental responsibility for operators of timber treatment facilities. However, the costs of improving the design operation of timber treatment facilities to meet Australian Standards will be hefty. Ultimately, consumers will bear this cost through price increases for CCA-treated timber. 
Recommendation 4 really has few implications for viticulture as it refers to the actual chemicals used for the treatment of timber not the treated timber itself. This recommendation will ensure that labels are updated to provide a safer and more environmental responsible handing of CCA timber treatment chemicals. 
Recommendation 5 provides that registrants be required generate worker exposure data in relation to risks associated with arsenic and chromium in CCA. This may necessitate the testing monitoring of contractors or workers that install CCA-treated posts in vineyards, especially where they are required to cut or drill posts.

How many posts do we have to deal with? 
As vineyards age, the relatively brittle CCA-treated pine posts are susceptible to breakage under machinery impacts in vineyard. Anecdotal evidence suggests that due to wear and tear, natural decay, the annual replacement rate of posts in a vineyard may be as high as 15%. Within five years, six million posts, require disposal annually, equivalent to over 120,000m3 approximately twice the annual amount of waste deposited in landfill catering for a population of 60,000 people. If vineyards are to be replanted after 25-30 years, a significant volume of CCA-treated posts will require disposal should they be found unsuitable for reuse. Assuming that a vineyard has a span of 25 years, there will be a peak around 2024 at which time somewhere between eight and 16 million obsolete posts will require disposal within the year, in addition to the six million posts requiring disposal as a result of annual breakages. Based on conservative estimates, that equates to the landfill volume required to dispose of a year's waste from a population of 140,000 people. 
How do I dispose of old CCA treated posts? 
The most significant problem associated with the use of CCA treated posts is the disposal of broken or obsolete trellis posts. Burning of CCA-treated products has been prohibited for a decade in some states, as it has been acknowledged that the smoke produced constitutes an environmental and human health hazard. Landfilling CCA-treated timber products is regulated in both New South Wales and South Australia, thereby restricting disposal to licensed or authorised landfills that are lined and/or have an appropriate leachate management system. Even if authorised to receive CCA-treated timber, it is at the discretion of the landfill operator as to whether they shall accept it. In Victoria too, it is at the discretion of landfill operators whether they will take CCA-treated timber. Research is seeking to find acceptable ways to dispose of CCA treated timber, and to recover the arsenic, chromium and copper components from the timber. The Centre for Risk, Environment and Systems Technology and Analysis (CRESTA) at the University of Sydney has undertaken a review of thermal disposal options for the management of CCA-treated timber wastes. They have found that thermal treatment of CCA timber wastes is a technically feasible solution that should be pursued further. Recently the Victorian Department of Primary Industries (DPI) - Mildura, and CSIRO Forest and Forestry Division at Clayton South, Victoria, jointly proposed a number of concepts for extending the service life, and for the environmentally benign disposal of old CCA-treated posts. Australian grape industries should support research into disposal options for CCA-treated posts. 

What are the alternatives to CCA-treated posts? 
Untreated hardwood, creosote-treated pine and hardwood, precast concrete, old rail line, steel and plastic are among the materials that have been used for trellis posts in Australia. Some of these posts are suitable alternatives to CCA-treated pine posts. The first phase of a collaborative project between DPI Mildura, CSIRO Clayton South, Queensland Forest Research Institute and others is nearing completion. One of the aims of this project was to evaluate the suitability of plantation thinnings (irrigated with drainage and industrial wastewater) as vineyard posts. Posts manufactured from various tree species and alternative preservation treatments were tested for bending strengths and surface defects. Preliminary results have shown that radiata pine treated with Alkaline Copper Quaternary (ACQ) might be an alternative to CCA-treated radiata pine. Posts from some hardwood species (mostly eucalypt species) treated with ACQ or Pigment Emulsified Creosote (PEC) also seem to be suitable for vineyard trellising. The project team has planned to conduct accelerated decay tests on all the posts tested in phase one. The results from these tests in conjunction with the bending strength and surface defects will be used for final recommendations regarding the suitability of plantation thinnings as vineyard posts. It is expected that results from the accelerated decay tests will be available in the next 18-24 months. 
Summary 
The continued use of CCA-treated posts in vineyards is assured. Estimates indicate that there are 60 to 120 million posts currently used for trellising in Australian vineyards. Approximately 75% of these are CCA-treated timber posts. There will be a peak around 2024 at which time between 14 and 22 million posts will require disposal within the year, equating to a landfill volume required to dispose of a year's waste from a population of 140,000 people. Wood preservative companies and scientists in Australia are investigating alternatives to CCA-treated pine posts Australian grape industries should be supporting further research into alternative treatments for timber that are equivalent to CCA treatments. Australian wine industry should be supporting research into disposal options for CCA-treated timber. 

EPA South Australia statement on the wine industry and treated pine. By G.Scott (Aug 2004).
The Environment Protection Authority (EPA) appreciates that the proper disposal of copper chromated arsenic (CCA) treated timber ('permapine') is a growing concern and is working in cooperation with the wine industry (SAWIA), and other stakeholders, in developing a management plan.
The EPA is aware that some viticulturists may be engaging in the practice of burning copper chromated arsenic (CCA) posts, particularly during the process of vineyard clearing ('pulling').
The EPA would like to reinforce that burning CCA treated timber, creosote and other treated timber is an unacceptable practice.
CCA treated timber contains copper, chromium and arsenic compounds. Of particular concern is the product of combustion, arsenic trioxide and arsenic pentoxide. (Arsenic trioxide gas is released at temperatures as low as 200oC.) The gases readily solidify into an amorphous ash. The ash resulting from the combustion of CCA treated timber contains extremely high concentrations of arsenic. Arsenic is a recognised carcinogen, mutagen and potential teratogen. The ash presents a high potential risk to human health, can contaminate soil, and can also potentially pollute ground water; ash contamination can therefore make the land unsuitable for vine production. The ash is attractive to stock due to the salty taste and can result in their death.
Creosote contains a variety of poly-aromatic hydrocarbons (PAHs). PAHs are carcinogenic and are potential soil and ground water contaminants. Unless incinerated with controlled residency time and high temperature, creosote can release these volatile organic chemicals on combustion.
When vineyard clearing is being undertaken, care should be given to seperate treated timber from vines and other material so that it is not burnt in stockpile waste. The treated timber (both new posts and waste) should be safely stored or disposed of to avoid soil and water contamination.
Under the Environment Protection Act 1993, 'General environmental duty' [section 25. (1)] 'A person must not undertake an activity that pollutes, or might pollute, the environment...' The burning of preservative-treated timber would constitute an act of pollution.