Regulations
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Australian Pesticides and Veterinary Medicines Authority, APVMA
APVMA
Review
Role
of APVMA
Draft
Recommendations
Responses
to Draft APVMA Review
Final
Review Findings 2005
References
A review of CCA has been carried out by the Australian Pesticides and Veterinary Medicines Authority (APVMA). APVMA is the national registration authority for CCA. It decides whether CCA is safe to use, whether its use and disposal are safe for the environment, and what warnings and instructions should be put on the label of CCA products. The review has been undertaken ‘because of public health concerns primarily about potential exposure of children to arsenic from close contact with treated timber surfaces. The APVMA was also concerned about the potential for environmental effects arising from the use of the timber treatment products’ (APVMA, 2003c).
Before the draft review was finalised, the APVMA sent out a press release to ‘put industry on notice that it intends to stop the use of Copper Chrome Arsenate (CCA) as a timber treatment in certain domestic situations’, and stating intentions to prohibit the use of CCA-treated wood in decking and children's playground equipment (APVMA, 2003d).
When reconsidering the registration of a chemical, the APVMA undertakes a substantial review of available literature and information, then analyses this information in collaboration with government departments, including the Office of Chemical Safety in the Department of Health, the Department of Environment and Heritage, and the National Occupation Health and Safety Commission. A call for submissions is made, and for the review of arsenic-based timber treatments the APVMA received submissions from a ‘wide spectrum of the community, including individuals, relevant state departments, CSIRO, environmental groups and timber industry groups’ (APVMA, 2003b). Of particular note, the APVMA does not conduct independent testing, but relies on existing data provided by industry, academics and individuals. This can result in significant data gaps, which was a concern for this review.
The APVMA engages with a number of committees, including the Community Consultative Committee (CCC), which receives concerns from community members. During the CCA review, CCC representatives from the WA Farmers Federation and the Australian Workers Union reported Occupational Health and Safety concerns by farmers and fencers who work with CCA-treated timber. It also received enquiries from parents, schools and pre-schools, and people with CCA-treated timber in their gardens (Stanton, A., APVMA Community Consultative Committee, Pers. Comm., 4/11/04).
The APVMA (2003a, p.11) review made 5 recommendations in its draft review, namely:
- CCA timber treatment products be declared Restricted Chemical Products…
- CCA product labels be varied to recommend that timber treatment facilities be designed and operated to meet appropriate Australian Standards…
- Product labels be varied such that uses of CCA timber treatment products are not permitted on timber intended for use in structures such as picnic tables, deckings, 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.
* Implementation of this recommendation is contingent upon the successful development of effective ways to segregate CCA-treated timber products that should not be used in specified domestic applications.
Despite the improved management that these recommendations should bring, there are some concerns that they do not go far enough. While Recommendation 1 requires the CCA chemical to be restricted, CCA-treated timber will still be available to be purchased and used by untrained laypeople for a permitted use, such as for use as garden edging or a fence around the backyard (Putcha, S. APVMA, Pers. Comm., 21/12/04). The effectiveness of recommendation 2 is dependent on Australian standards set by a committee where the timber industry is overrepresented. The variations to labels in Recommendation 3 only apply to the chemical container, not to pieces of treated timber. The timber will merely be branded ‘Treated with Copper Chrome Arsenate’ (Putcha, S. APVMA, Pers. Comm., 21/12/04).
In late 2004 the APVMA sent letters to the timber treatment, advising them that the recommendations from the draft review will involve changes to instructions on chemical labels and mandatory user training. In this letter, the APVMA invited timber treatment registrants and the timber industry to ‘work with us to develop suitable new label instructions’. The latest date for providing amended labels is February 2005. (Hogg, 2004).
Responses
to Draft APVMA Review
Final
Review Findings 2005
Standards
Australia
OtherAPVMA (2005a), Arsenic - Review Summary, Australian Pesticides And Veterinary Medicines Authority, Canberra, March 2005 http://www.apvma.gov.au/chemrev/arsenic_summary.pdf
APVMA
(2005b), Arsenic Technical Report (The Reconsideration of registrations
of arsenic timber treatment products (CCA and arsenic trioxide)
and their associated labels. Technical Report), Australian Pesticides
And Veterinary Medicines Authority, Canberra, March 2005
Part 1 - Toxicological Assessment, http://www.apvma.gov.au/chemrev/arsenic_tox.pdf
Part 2 - Environmental Assessment Arsenic based timber treatments
http://www.apvma.gov.au/chemrev/arsenic_environment.pdf
APVMA (2005c), Frequently Asked Questions, Australian Pesticides And Veterinary Medicines Authority, Canberra, 15 March 2005 http://www.apvma.gov.au/chemrev/arsenic_faq.shtml
APVMA (2003a), The Reconsideration Of Registrations Of Arsenic Timber Treatment Products (CCA And Arsenic Trioxide) And Their Associated Labels (Review Summary), Australian Pesticides And Veterinary Medicines Authority, Canberra. (pdf - 1.2MB)
APVMA (2003b), The Reconsideration Of Registrations Of Arsenic Timber Treatment Products (CCA And Arsenic Trioxide) And Their Associated Labels (Technical Report), Australian Pesticides And Veterinary Medicines Authority, Canberra. (pdf - 4.5MB)
APVMA (2003c), Media Release - Draft Report on Arsenic Treated Timber Released for Public Comment, Australian Pesticides & Veterinary Medicines Authority, December 22, Canberra, http://www.apvma.gov.au/media/mr0310.shtml (accessed 22/10/04).
APVMA (2003d), Media Release - Copper Chrome Arsenate (CCA) - APVMA puts industry on notice, July 28, Australian Pesticides & Veterinary Medicines Authority, http://www.apvma.gov.au/media/mr0306.shtml (accessed 22/10/04).
APVMA (2003e) Arsenic Timber Treatments (CCA and Arsenic Trioxide): Review Scope Document. Canberra: Australian Pesticides and Veterinary Medicines Authority, Canberra, March. (pdf - 160kb)
Hogg, R. (2004), Letter to Peter Cobham, Koppers Arch Wood Protection (Australia) from Manager of Pesticides Revierw, APVMA, August 13. http://www.tanalised.com/files/pdf/TreatmentN_Letter.pdf (accessed 22/11/04).