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Chromated Copper Arsenate (CCA):
CCA Guidance - Questions and Answers
CCA Table of Contents
Current as of June 17, 2004
As of December 31, 2003, wood intended to be used in residential settings cannot be treated with chromated copper arsenate (CCA). Existing stocks of the wood may be sold by retailers until such stocks are exhausted, and consumers may continue to buy and use the wood for as long as it is available. In order to ensure clear guidance to wood treaters and others on what uses of CCA are allowed and what uses are discontinued, EPA has prepared this guidance document to ensure that CCA is being used consistently with the terms of the December 31st phase-out. Since there are so many types of dimensional lumber with a variety of uses, it is important to provide clear, easy-to-understand, and consistent guidance for the uses that can continue. Similarly, it is also important to specifically identify the types of wood that can no longer be treated with CCA products.
- Why is EPA issuing this new guidance?
- What was the process for comment and review of the guidance document?
- What is included in the guidance document?
- What is the Agency's position on the use of CCA to treat wood used in the construction of residential retaining walls?
- What is the Agency's position on the use of CCA in skirtboards and sillplates used in the post-frame construction industry?
- What other clarifications are included in the guidance document?
- What about the corrosivity of alternatives (ACQ and copper azole)?
- Does this guidance change any uses of CCA to treat wood for marine (salt water or brackish water) use?
- What are the restrictions on exporting and importing CCA-treated wood?
- What is the enforcement and compliance strategy?
- Where can I get further information?
1. Why is EPA issuing this new guidance?
EPA is releasing the document, Supplemental Guidance on Interpretation of Revised Chromated Copper Arsenate (CCA) Wood Preservative Label, to provide clarification on the allowed and disallowed uses of CCA. As of December 31, 2003, CCA can no longer be used to treat wood that will be used in virtually all residential settings. Along with the pesticide product label, the guidance document provides stakeholders, EPA Regional offices, consumers, public interest groups, wood treaters, and registrants with a reference tool to help determine what types of wood may continue to be treated with CCA. The guidance document also provides a reference table that contains the American Wood-Preservers' Association (AWPA) commodity standards related to CCA, with key examples of some of the uses which are permitted and disallowed. AWPA is an international, non-profit association established to exchange technical information between industry, researchers and users of treated wood.
Also, EPA's Office of Enforcement and Compliance Assurance (OECA) will soon issue a CCA Compliance Strategy (which will be posted on this site) to inform all interested parties about the Agency's plans for compliance monitoring, targeting inspections, and how to report tips and complaints.
2. What was the process for comment and review of the guidance document?
In order to obtain input from interested parties, a draft of the guidance document was sent to various wood treatment experts, other stakeholders, AWPA, EPA Regional Offices, States, public interest groups, and the registrants for review and comment about its accuracy and clarity. In addition, comments were taken from both the EPA-sponsored Antimicrobials Hotline and from meetings with the Regional Offices and States. EPA considered those comments received and then sent a second revised draft of the guidance document out for comment. This document addresses the comments received.
3. What is included in the guidance document?
The guidance document is comprised of two basic sections. First, a narrative section provides an overview of the label revision process, information about exporting and importing CCA-treated wood, and a list of allowed uses of CCA. The other document includes a table which provides information on the AWPA commodity standards related to CCA and some examples of allowed and disallowed uses to provide clarification.
4. What is the Agency's position on the use of CCA to treat wood used in the construction of residential retaining walls?
As of December 31, 2003, CCA cannot be used to treat wood that will be used in the construction of retaining walls in residential settings. The Agency has concerns about the possibility of such treated wood being used in the residential market and the resulting potential for exposure. There are a number of alternatives to CCA-treated wood currently available on the market for use in retaining walls, including other wood preservatives, such as ACQ and copper azole, as well as durable woods such as western red cedar, yellow cypress, eastern white cedar, and redwood, and alternatives to lumber, such as synthetic materials and wood composites.
5. What is the Agency's position on the use of CCA to treat skirtboards and sillplates used in the post-frame construction industry?
As of December 31, 2003, CCA cannot be used to treat wood for skirtboards and sillplates in post-frame construction. The Agency has concerns about the possibility of this size dimensional lumber being diverted to other residential uses where the potential for exposure exists. Dimensional lumber is characterized as having the following measurements: two inches up to, but not including, five inches thick, and two or more inches wide (e.g., 2" x 4"). There are a number of alternatives to CCA for this particular use currently available on the market (see Question 4 for examples of such alternatives).
6. What other clarifications are included in the guidance document?
- Under AWPA Standard C16 - Wood Used on Farms: round agriculture poles and posts (including farm-fence rails) are allowed to be treated with CCA. Under agricultural poles, round farm-fence rails can also be treated with CCA. As before, agriculture fence posts (round, half-round, and quarter round) can be treated with CCA.
- Under AWPA Standard C34 - Shakes and Shingles: tile batts (1" strips used in roofing) can be treated with CCA.
- Under AWPA Standard C30 - Cooling Tower Use, there is new label language (the 2002 edition of the AWPA Standards added the C30 standard--lumber, timber and plywood for Cooling Tower use only as an allowable CCA use).
- Under AWPA Standard C18- Marine/Salt Water Use - there is revised label language, affecting such uses as of December 31, 2004 (members out of water and not subject to splash and not in soil use will not be allowed as of this date-see Question 8).
- Some various use interpretations have been added to the table. For example, wood used in the construction of roller coasters (under AWPA Standard C14) can be treated with CCA, as well as nail laminated members (under AWPA Standard C28).
- Clarification on a number of instances where CCA cannot be used to treat wood used on farms have also been included, such as wooden tomato stakes and wooden grape stakes.
- Additionally, an extensive definition section has been added for reference at the end of the guidance document.
7. What about the corrosivity of alternatives (ACQ and copper azole)?
The Agency is aware of that some new generation wood preservatives may have the potential to corrode fasteners. Manufacturers of ACQ and copper azole are working to provide better information on types of fasteners (e.g., stainless and galvanized steel) that are more appropriate to use with wood treated with these pesticides. Fact sheets on ACQ, copper azole, and other alternatives are available. Additionally, information on the appropriate fasteners can be obtained
8. Does this guidance change any uses of CCA to treat wood for marine (salt water or brackish water) use?
Yes. The registrants have agreed to voluntary cancel the use of CCA under the marine use standard, AWPA Standard C18, effective December 31, 2004. This standard refers specifically to "members out of water and not subject to salt water splash and not in soil use." This means that CCA will not be allowed to be used to treat wood for marine construction on decking, railings, and boardwalks effective December 31, 2004. EPA will publish this label amendment for public comment. Furthermore, it is acceptable to use CCA to treat wood for marine construction in saltwater or brackish water, for such things as pilings and submerged crossbracing.
9. What are the restrictions on exporting and importing CCA-treated wood?
As of December 31, 2003, it is illegal to treat wood with CCA for any prohibited residential use, including wood imported to be used domestically or exported for use in other countries.
10. What is the enforcement and compliance strategy?
The Office of Enforcement and Compliance Assurance (OECA) has developed a strategy (9 pp, 26k, About PDF) that will help ensure compliance with the label and describes EPA's plan for inspections. For inspections, EPA will first inspect CCA-producing establishments to ensure that the correct labeling is being placed on pesticide products that contain CCA. Following that, inspections will be conducted at wood treatment facilities to determine compliance with the new labeling requirements. Inspections may also be conducted at lumberyards and home supply centers to determine if dimensional lumber treated with CCA is being delivered, and, if so, whether the lumber was treated before or after December 31, 2003. The Office of Pesticide Programs has requested that EPA Regional Offices, which reviewed and commented on the strategy, track the outcome of CCA inspections conducted by the States, including those inspections that are a result of a tip or complaint.
11. Where can I get further information?
For more information, contact the Antimicrobials Hotline via fax at 703-308-6467, or email info_antimicrobial@epa.gov.
The Federal Register publication of the cancellation notice.