Arsenic and your playground: the 2004 voluntary phase-out of arsenic-treated wood is giving park and recreation departments nationwide new reason to evaluate their parks.

Arsenic. It's a known human carcinogen, and it may be present in your parks' benches, picnic tables, countertops, handrails and playground structures. But this decades-old wood preservative is receiving attention nationwide because of new evidence pointing to the conclusion that arsenic can leach out of the wood it's treating, and into surfaces and surrounding soils. However, the debate over whether this wood is sale to the touch is still ongoing. With federal government hearings being held and scientific advisory panels issuing reports, local parks and recreation agencies are deciding for themselves on how to respond to the public's growing concerns over the presence of arsenic-treated wood.

An informal survey of park and recreation departments on NRPAnet gave a snapshot of how agencies are dealing with wood treated with chromated copper arsenate (CCA)--the arsenic commonly used to treat and protect lumber. Many of the larger park and recreation agencies have already begun phased replacement programs--gradually replacing CCA-treated structures, especially play equipment, as budgetary constraints permit. Mike Kelly of Palm Beach Gardens, Fla., wrote, "Although we have no formal policy, we have taken steps to resolve these issues in the future. First, we have to assume that all the wood-related products in our system are made of CCA-treated wood. Second, they will phase out within a two-year period. Third, all purchases will be of coated metal, recycled materials, or ACQ-treated wood." He notes that alternatives to wood carry a hefty price tag--as much as two to three times the cost of CCA-treated wood, and that ACQ-treated wood is approximately 30 percent higher in cost.

Carolyn Hanel, director of parks and recreation for West Whiteland Township of Exton, Pa., wrote, "Although we have not received any complaints, we chose not to wait and have replaced all our wooden play units, two in 2003 and the third scheduled for replacement in 2004." Some department directors said that the unanticipated cost for replacement was difficult to accommodate especially in a time of tight budgets. One park superintendent from Virginia noted that he might have asked for increased funding for this purpose, but after three rounds of harsh budget cuts, his agency was told it wouldn't receive any extra funding except for state of federally mandated issues.

Charlie Ziesemer of Kentwood Parks and Recreation Department in Kentwood, Mich., wrote, "We took samples from our structures to an environmental lab and had test run (very reasonable cost). We found a minimal amount of arsenic (well below dangerous levels). It gave us peace of mind as well as the public. And, if there would have been high levels, we would have been justified in removing."

Cost effective or potentially dangerous?

The use of wood for park benches, structures, bridges and play equipment has had a long tradition in parks and recreation areas in America. In the 1930s, the Civilian Conservation Corps workers built park structures from native trees fashioned from lumber cut right from the parks and forests in which they were working. Throughout the 1950s, 60s and 70s, natural wood was the building material of choice for playground structures, park benches, picnic tables, bridges and boardwalks. Even today, timber frame bridges, shelters and buildings are often chosen over metal or composites for their beauty, durability and cost efficiency.

"The use of wood products in the past was both customary and cost effective.... I think it also provided a sense of family and home that individual communities wished to project," says Mike Kelly, parks division director of Palm Beach Gardens, Fla.

However, no matter what type of native woods are used for park construction, insects, rot, fungi and other forces of nature cause decay in the wood. There are certain species of wood such as black locust, white oak and red cedar that are resistant to rot and insects, but such woods can be prohibitively expensive and are rarely suitable for all types of construction.

Southern Yellow pine and spruce have been the most cost effective and useful woods for a wide range of park applications, but these woods and other suitable softwoods are also the most susceptible to decay and insect damage. Wood preservatives have been used for decades to prevent decay and insect damage. Thrifty park managers used motor oil, creosote, pentachlorophenol and other commercially available coatings and sealants to dip, paint and seal wood surfaces and structures to slow the rate of decay. But, over the years, research has found many of these wood preservatives to be toxic, dangerous or cancer causing.

CCA is the latest class of wood preservative to gain this reputation. CCA in an insecticide and preservative that gives treated wood the distinctive green color that is so common on decks, walkways and outdoor furniture. Wood that is treated with CCA has proven to be effective in combating termites and ground rot. However, the Environmental Working Group (EWG), a non-profit environmental research organization, and other research organizations have found that the arsenic in CCA-treated wood may be "dislodgeable" and ingestible from normal contact, especially hand-to-mouth contact. Recent research findings concerning this wood preservative, which has long been considered the standard for effectiveness, durability and safety, have indicated that there are potentially much higher risks for exposure to arsenic than have been previously thought, and the exposure risk in playgrounds and picnic areas may be greatest for the population most at risk--young children.

The Debate

Arsenic, although fairly common in nature, has recently been officially labeled as a known human carcinogen, one that can cause nerve damage, endocrine disruption, and skin, bladder and lung cancer if humans are exposed at high doses. The U.S. Environmental Protection Agency (EPA) has strictly regulated the amount of arsenic that can be found in drinking water supplies. The federal government standard since 1947 has been limited to no more than 50 parts per billion (ppb), but in 2001, proposed to lower that standard to 10 ppb. Currently, there is no comparable federal standard for exposure to arsenic that may come from CCA-treated wood.

In a 2001 report entitled "Poisoned Playgrounds," the EWG estimates that possible exposure risk from pressure-treated wood surfaces found in parks and recreation areas could be five to 10 times as high as from the arsenic found in public drinking water supplies, and that children who regularly play on CCA-treated equipment could have a cancel exposure risk 10 times higher than the EPA standard threshold of one-in-a-million risk level. According to EWG's vice president of research Jane Houlihan, the potential danger of exposure to the treated wood does not change over time. "In testing, we found arsenic levels in 20-year-old structures as high as in those in 2-year-old structures. Old wood can be just as hazardous as new wood in that respect."

There is also a surprising amount of arsenic present in pressure-treated wood--as much as one ounce of arsenic in a 12-foot-long pressure-treated 2-inches-by-6-inches plank. The arsenic solution that also contains copper and chromium is forced into the wood under high pressure and impregnates the wood completely to the heart. The CCA insecticide, which is about 22 percent arsenic by volume, was previously thought to be completely inert and chemically bound to the wood.

The finding that this arsenic can migrate to the surface of the wood and even leach into surrounding surfaces or nearby soil has presented significant challenges to not only federal government regulators, but also to park and recreation departments that have an infrastructure that may be built almost exclusively from pressure-treated wood. A recent study by the University of Massachusetts and Wellesley College found arsenic in soils beneath three-quarters of the play structures in public playgrounds. In more than half of these sites where arsenic was found, the levels were considered dangerous by the state. "Many parks could put people at high risk because the chance of exposure is highest in these settings," Houlihan says. "It is very hard to estimate the exposure risk, but children are our biggest concern. Arsenic residue sticks to CCA-treated wood surfaces, and children have a lot of hand-to-mouth contact."

In recognition of this potential danger, the wood products industry and the EPA, which regulates insecticides under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) in its responsibility to regulate chemicals and known carcinogens, have negotiated a voluntary phase out of all CCA-treated lumber used in residential applications. No CCA-treated lumber sold for residential uses may be manufactured after Jan. 1, 2004, but suppliers may sell existing stocks till they ale depleted.

EPA is also conducting several studies on CCA exposure risk, and a scientific advisory panel recently released a peer review in late February of an EPA study that investigated the potential health hazards for children. The EPA report, "A Probalistic Risk Assessment for Children Who Contact CCA-treated Playsets and Decks," concludes that children who come in repeated contact with CCA-treated wood surfaces may have a significantly higher risk of developing cancer. Further, EPA reports that the problem may be greater in warmer climates where children spend more time outdoors playing on CCA-treated surfaces.

The Wood Preservative Science council (WPSC) and others dispute the accuracy, methodology and use of data for EPA's exposure assessment study. WPSC Executive Director Jim Hale cites a 2002 report from a physicians work group in Florida that asserts "there has never been any disease associated with the recreational use of this product." He cautions that "City and county governments should not rush to spend hundreds of thousands of taxpayers' dollars ripping out CCA-treated structures."

The wood preservative and wood products industries contend that CCA-treated lumber does not pose an unacceptable risk, and can continue to be used. "With regard to manufactured wood play structures, most wood playground manufacturers have informed the Consumer Product Safety Commission (CPSC) that they have stopped using CCA-treated lumber in the construction of their products. In terms of regulatory action, EPA has not mandated the removal or replacement of CCA-treated wood structures. Dave Deegan, a contact for the CCA Scientific Peer Review group convened by EPA, says, "EPA has not made any recommendation that individuals of organizations need to remove or replace structures with CCA-treated wood."

On Nov. 4, 2003, CPSC rejected a petition to begin a rulemaking to ban the use of CCA-treated wood in playground equipment, noting that it would be redundant and unnecessary given the phase out of most residential CCA-treated wood after Dec. 31, 2003. However, in their statements, each of the CPSC commissioners noted their concerns about the risks from arsenic in existing wood structures, and the need for more studies and research. Commissioner Thomas H. Moore stated, "I must stress that I am not totally comfortable with respect to the commission's lack of a recommendation on existing CCA-treated wood playsets. Consistent with this, I direct the staff to continue efforts to identify stains and sealants and any other means to reduce exposure to arsenic from existing CCA-treated wood structures and I also direct the staff to devise strategies to better educate the public about the cancer risk associated with these structures and take steps to minimize the risk." EPA is presently conducting research on sealants that might reduce the contact humans have with arsenic, and a report on the efficacy of such sealants is expected in 12 to 18 months, although interim findings may be released as the study continues.

Phasing out Arsenic

Obviously, there is much that is yet to be determined about the toxicity of CCA-treated wood, and the risks from exposure to arsenic from CCA-treated wood surfaces. But as more independent reports are released to the public about the possible dangers of CCA-treated wood on public structures, pressure is mounting nationwide on park and recreation officials to respond.

A number of park and recreation agencies have taken pro-active steps to address the presence of CCA-treated lumber in their parks and recreation areas by beginning wholesale of staged replacement programs of any wood structures that are accessible to the public, or which could conceivably be a source of human exposure. Some agencies, notably those in Florida, have committed to full-scale replacement programs, and have mandated the use of less toxic preservatives and wood-treating insecticides such as ACQ (a wood preservative that contains a mixture of copper and didecyl dimethyl ammonium chloride, commonly called alkaline copper quat, of just "quat"). In fact, the Florida state procurement system, called PRIDE, makes ACQ lumber available for bulk purchasing by park and recreation departments.

EWG reports that some wood preservative treaters in the industry want to upgrade to a new form of treatment called acid copper chromate (ACC), which is presently legal, but EPA has not granted a "registration" yet. There are concerns that the type of chromium in ACC lumber could pose a cancer risk, and EPA staff has recommended that no new registrations be granted for a year, pending results of further studies.

Parks and recreation agencies should make an informed assessment of risks to workers and the public in conjunction with plans to seal, remove or replace CCA-treated wood in park and recreation areas. Not only will such a risk assessment, however informal, provide data for an action plan, but it will give the opportunity to truthfully inform the public about its risk potential.

Among the elements to consider in assessing risks and developing agency policies are:

* Inventory wooden structures containing CCA-treated wood and particularly concentrate on those that the public may be likely to touch, handle, play on, of eat from. Not all structures and surfaces are at equal risk for human exposure, and common sense should dictate which structures are of concern.

* Carefully inspect wood chips placed under play structures for presence of post-consumer, CCA-treated wood chips that may have been intermixed in plain wood chips. Consider some limited soil testing under structures in play areas.

* Develop an agency policy, even if informal, on what will be replaced, coated, or removed. Such a policy will help justify budget requests for unanticipated expenses.

* Evaluate the budgetary implications. What can be done now, and what must be done in stages?

* Consider temporary measures such as sealing exposed surfaces with oil-penetrating stains and sealers. EPA and CPSC suggest this may have some limited effectiveness in preventing dislodegable arsenic. Encapsulating sealants or paints are not generally recommended for long-term solutions, since weathering or future sanding may complicate the problem by flaking or dust from sanding. Paints and encapsulating sealants may be acceptable if there are plans for replacement of CCA-treated wood soon.

* Do some testing with inexpensively purchased test kits. Such kits can be purchased online (www.ewg.org/ reports/poisonwoodrivals/orderform.php) or tests can be performed at local labs that offer such testing fairly economically. Particularly test in combination with sealing efforts. Test before and after the seal, and again at an interval of time such as six months or a year later to determine possibility of leaching.

* Evaluate worker safety issues as well as public safety issues. Educate them to the risks, and encourage proper safety procedures such as using masks and long-sleeved shirts when cutting CCA-treated wood, using gloves when handling such wood, and not burning it under any circumstances. Incorporate these messages in worker safety training programs, and recognize worker safety initiatives in eliminating possible hazards.

* If treated lumber is purchased from commercial sources, find out if they are continuing to buy and stock CCA-treated wood.

* Amend contracts with suppliers and contractors to prohibit them from using CCA-treated wood in parks and play areas, without specific, signed agency approval.

* Consider an information and education campaign for workers and the public. At least distribute and post the basic EPA guidelines for contact with CCA-treated wood, such as not eating directly from wooden surface picnic tables, washing hands after contact with wood and reducing chances for exposure.

To find out more about arsenic in wood issues, and to obtain EPA guidelines for human contact with CCA-treated wood see www.ewg.org/issues/ arsenic or www.epa.gov/pesticides/ factsheets/chemicals/1file.htm.

SCRATCHING THE SURFACE **

Once the U.S. Environmental Protection Agency released information
Feb. 12, 2002, stating a voluntary phase out of CCA-treated lumber
on consumer products such as playgrounds, decks and picnic tables,
there has been a steady release of new products and preservatives
that do not contain arsenic. Some of the preservatives such as ACQ
and Copper Azole, although viewed as new, have been in use for more
than a decade-mostly overseas.

Below is a list of alternative wood preservatives that can be
purchased from any wood manufacturer. Also, if your CCA-treated
wood is net going to be replaced in the near future, there are
oil-based sealants on the market that can effectively prevent the
arsenic from leaching onto the surface. For more information, refer
to the informational Web sites below the table.

Comparing Alternative Wood Preservatives *

Preservative Types   Popular Brand Names   History/Uses

Alkaline Cooper      Preserve[R]           ACQ-treated wood was first
Quat (ACQ)                                 introduced in the United
                     Preserve Plus[R]      States 10 years ago. It has
                     (built-in water       been successfully used in
                     repellent)            Europe, Japan, New Zealand,
                                           Asia and Australia for the
                     Nature Wood[R]        last 15 years.

                     Nature Wood[R]        Uses: ACQ is a fixed
                     with water            preservative approved for
                     repellent             full exposure to above
                                           ground, ground contact, and
                                           freshwater applications.

Copper Azole (CBA)   Wolmanized[R]         Wood products treated with
                     Natural Select[TM]    Copper Azole have been used
                                           effectively around the
                     Wolmanized[R]         world since 1992.
                     Natural Select[TM]
                     with water            Uses: Copper Azole is a
                     repellent             fixed preservative approved
                                           for full exposure to above
                                           ground, ground contact and
                                           freshwater applications.

Sodium Borates       Advanced Guard[R]     Wood products treated with
(SBX)                                      Borates were initially
                     SillBor[TM]           established in New Zealand
                                           in 1950. Before being
                     TimberSaver PT[R]     introduced into the United
                                           States more than 10 years
                     FrameGuard[TM]        ago, Borates were widely
                                           used in New Zealand, Europe
                                           and Southeast Asia.

                                           Uses: Borates are a
                                           diffusible preservative
                                           approved only for above
                                           ground applications that
                                           are continuously protected
                                           from liquid water, such as
                                           sill plates and other
                                           enclosed structural framing.

* Table information received by the Southern Pine Council.

** This table represents several of the leading preservative types
and popular brand names available to date (May 2002). Additional
preservative types and brand names may enter the market in the
coming months

*** American Council on Science and Health: www.acsh.org

Nonprofit consumer education organization concerned with food,
chemicals, lifestyle and health.

*** American Wood-Preservers' Association: www.awpa.com

Site of the organization that establishes the standards for the
wood preservation industry.

*** American Wood Preservers Institute: www.preservedwood.com

Information on the types, uses, handling and regulation of
pressure-treated wood.

*** Building Products Plus: www.buildingproductsplus.com

Source of treated lumber, specializing in kiln-dried and
hard-to-find products.

*** Forest Products Society: www.forestprod.org

Promotes technical innovation in the environmentally sound
processing and use of wood.

*** NAHB Research Center: www.nahbc.org

Information on building products, contractor certification, and
construction technology.

*** Temperate Forest Foundation: www.forestinfo.org

Source of scientifically credible information on forest issues.

*** Southern Pine Council: www.southernpine.com

Web site information gathered from the Treated Wood Council

Rich Dolesh is the Senior Polity Associate in National Recreation and Park Association's Public Policy Office. He can be reached at [phone] or by e-mail, [e-mail].