.nmfntal Protection
resticides and Tojjlel
Washington DC 2D4J,
HI mi i
Creosote | j
Inorganic Arsenij :a
: l[ II
Pentachloropherj D!
Position Documii t
A !\ 'n : 9 I
540982004
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WOOD PRESERVATIVE PESTICIDES
CREOSOTE, PENTACHLOROPHENOL AND THE INORGANIC ARSENICALS
(tfood Uses)
POSITION DOCUMENT 2/3
OFFICE OF PESTICIDE PROGRAMS
U.S. ENVIRONMENTAL PROTECTION AGENCY
U.S. Environmental Protection Agtncy
«J|ion 5, Library (PL. 12J)
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EXECUTIVE SUMMARY
Wood Preservative Position Document 2/3
contact person: Joan Warshawsky
On October 18, 1978, EPA issued Notices of Rebuttable
Presumption and Continued Registration (RPAR) of pesticide
products containing coal tar, creosote, and coal tar neutral
oils ("creosote"), the inorganic arsenical compounds, and
pentachlorophenol ("penta") and its salts. This Position
Document (PD) 2/3 proposes several regulatory actions to
reduce the human health risks resulting from registered wood
preservative uses of creosote, the inorganic arsenical
compounds, and penta. These proposed actions are based on
the Agency's determination that these uses may result in
unreasonable adverse effects. For creosote, the effects
are oncogenicity and mutagenicity. For the inorganic
arsenical compounds, the effects are oncogenicity, muta-
genicity, and teratogenicity. For penta (or its contami-
nants) , the effects are oncogenicity, fetotoxicity, and
teratogenicity.
The document considers only the wood preservative uses of
these pesticides. For creosote, these uses are pressure
treatment (railroad ties, lumber, timber and plywood,
pilings, posts, crossarms, and poles), groundline treatment
of poles, and home and farm applications. For the inorganic
arsenical compounds, the uses are pressure treatment and
related uses (lumber, timber and plywood, pilings, posts,
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crossarms, and poles). For penta, the uses are pressure
treatment (railroad ties, lura"ber, timber and plywood,
pilings, posts, crossarms, and poles), groundline treatment
of poles, home and farm applications, sapstain control
(sodium penta), millwork, and particleboard.
In general, the risks to applicators, especially treatment
plant applicators, are theoretically very high. Risks to
construction workers and to general population applicators
and to the general population exposed to end-uses of treated
wood are moderate. The benefits from the use of wood
preservatives on the large number of treated wood products
are extremely high. Moreover, the impacts of the cancel-
lation of all three wood preservatives may have been under-
estimated since the required social, institutional and
technological changes which would be required by full
cancellation of preserved wood uses cannot be fully assessed
by conventional marginal cost analysis.
In reaching a regulatory position on the wood preservatives,
the Agency has considered several important factors: the
risk estimates for all three wood preservative chemicals
for pressure and non-pressure treatment plant applicators
and for certain non-plant uses, the uncertainty associated
with the risk numbers, the low number of applicators
involved, the extremely high benefits for each chemical, and
the non-substitutability of alternative chemicals for certain uses,
The Agency is very concerned about reducing the apparently
high risks to treatment plant workers. However, canceling
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a specific use or uses for each one of the three wood
preservative chemicals is unlikely to alter the overall risk
picture for that chemical, since the treatment plant applicator
is likely to apply the chemical to another end-use product.
Thus, in order to appreciably lower the risks from exposure
would have to cancel all uses of that pesticide. Due to the
non-substitutability of the wood preservative compounds and
the lack of acceptable non-wood or other chemical alternatives
for many use situations, the economic impact which would
result from an across-the-board cancellation would be
immense. Moreover the only wood preservative pesticides
which are efficacious for a majority of the use sites are
the inorganic arsenical compounds, which pose the highest
level of estimated risk.
In order to achieve significant reductions in risk while
retaining the benefits of use to the fullest extent possible,
the Agency carefully considered the full range of modifications
to the terms and conditions of registration which are
available under FIFRA. The Agency selected those risk
reduction measures which are cost effective and which will
reduce the risk by a significant amount.
The first regulatory action the Agency is proposing is to
allow registration to continue for the pressure treatment
uses of creosote, the inorganic arsenical compounds, and
penta, with changes to the terms and conditions of registra-
tion. These are by far the largest uses of the wood preserva-
tives. Specifically, for the pressure treatment uses of all
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three wood preservatives, the Agency will classify these
pesticides for restricted use, and will require that: 1)
all applicators wear gloves, 2) all applicators who open
treatment cylinder doors wear respirators, 3) all applicators
who enter pressure treatment cylinders wear neoprene-coated
cotton or rubberized protective clothing and wear respirators,
and 4) all protective clothing and equipment be left at the
plant. Moreover, the Agency will require the use of closed
emptying and mixing systems for all prilled (granular) and
powder formulations, the use of a dust mask for individuals
working outdoors in arsenical treatment plants, and measures
to reduce the surface residues of arsenic on treated wood.
In addition, the Agency will prohibit eating, drinking and
smoking during the application of these pesticides, will
prohibit the application of these preservatives to wood
which is intended for interior use, and will prohibit the
application of these pesticides to wood intended for uses
that may result in contamination of animals, food, feed or
water.
The second regulatory action the Agency is proposing is to
allow registration to continue for poles-groundline use of
creosote and penta, provided certain restrictions are made
on this use. The Agency will require that applicators wear
resistant gloves and coveralls, that protective clothing be
disposed of properly, and that applicators not eat, drink,
or smoke during application of these pesticides. Also, the
Agency will classify these pesticides as restricted use
pesticides.
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Next, the Agency proposes to allow registrations to continue
(with one exception) for home and farm uses of creosote and
penta, provided certain modifications are made to the terms
and conditions of registration. These modifications include:
1) classify all creosote products and pentachlorophenol
products containing a pentachlorophenol concentration
greater than 5$ as restricted use pesticides; 2) require
that applicators wear gloves and coveralls, 3) require the
proper disposal of protective clothing, 4) prohibit eating,
drinking and smoking during the application process,
5) require that all certified applicators who use the spray
method of application wear neoprene-coated cotton or rub-
berized protective clothing, 6) prohibit the application
of these preservatives indoors and prohibit application to
wood which is intended for interior use, and 7) prohibit the
application of these pesticides to wood intended for uses
that may result in contamination of animals, food, feed or
water.
The exception to continued registration for home and farm
uses is the spray method of application for penta products
containing 5$ or less penta. The Agency proposes to cancel
the spray application method for these formulations because
this application method may expose the applicators to high
levels of penta. The Agency believes that non-certified
applicators of these products will lack the special training
and equipment necessary to spray these formulations safely.
Moreover, as these applicators will still be able to apply
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penta "by other methods, this cancellation will provide
significant risk reduction without major economic impact.
For the brush-on use of the inorganic arsenicals, the Agency
is proposing the continuation of registration with modifications:
l) classify the inorganic arsenical compounds as restricted-
use pesticides, 2) require that applicators wear gloves and
coveralls, 3) prohibit eating, drinking and smoking during
application, 4) require the proper disposal of worn-out
protective clothing, 5) prohibit the application of the
inorganic arsenical compounds to wood which is intended for
interior use, and 6) prohibit the application of the inorganic
arsenical compounds to wood intended for uses that may
result in the contamination of animals, food, feed or
water.
Finally, the Agency proposes to allow registrations to
continue for the sapstain control use of sodium penta and
the millwork and plywood, and particleboard uses of penta
with changes in the terms and conditions of registration.
Specifically, for all these uses the Agency will (1) classify
these pesticides for restricted use, (2) require all
applicators to wear gloves in the treatment plants and to
wear neoprene-coated cotton or rubberized protective clothing
and respirators when cleaning treatment vats, and (3)
require all applicators who apply penta by the spray
method to wear gloves and a respirator. Moreover, the
Agency will require that prilled and powder formulations of
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penta and sodium penta be emptied and mixed in closed
systems, that all protective clothing and equipment be left
at the treatment plant, and will prohibit applicators from
eating, drinking, or smoking while applying these pesticides.
The Agency will also restrict the application of these
pesticides to wood intended for outdoor and low exposure
interior use, and will restrict the application of these
pesticides to wood intended for uses that may result in the
contamination of animals food, feed, or water.
In addition to these proposed options for reducing risk
under FIFRA, the Agency believes it is important to reduce
risks to the general population and to specific occupational
groups who use treated wood or treated wood products. Under
the regulations issued pursuant to PIPRA, the Agency does not
currently regulate end-use products, such as treated wood,
where no pesticidal claims are made for the treated item
itself. Therefore, these options will be proposed through a
labeling rulemaking under the Toxic Substances Control Act
(TSCA). The intent of the TSCA labeling is to ensure that
potentially exposed populations are aware of the appropriate
ways to minimize the exposure and risk from wood preservative
compounds.
The Agency recognizes that the Consumer Product Safety
Commission (CPSC) has some regulatory jurisdiction pertaining
to the consumer use of wood treated with pesticides. The
CPSC, however, has not issued any pertinent regulations to
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date. If the CPSC promulgates regulations covering wood
treated with pesticides, TCSA will be preempted to the
extent that the CPSC takes sufficient actions to protect
against the risks of concern. The Agency schedule for
completing this TSCA action includes a Notice of Proposed
Rulemaking by May 1981, public hearings in August, and final
rule by December 1981. This schedule would mesh with the
projected date for a final decision under PIFRA (December
1981).
In developing this regulatory position, the Office of
Pesticide Programs coordinated with the EPA Office of Solid
Waste in the disposal of preservative-treated wood, the EPA
Office of Drinking Water, regarding occurrence of wood
preservatives in drinking water, and the EPA Office of Toxic
Substances, concerning TSCA capabilities in controlling
treated wood. Other organizations the Agency consulted were
the Occupational Safety and Health Administration (OSHA),
regarding their jurisdication over wood preservatives for
worker safety, the CPSC regarding regulation of treated
wood, the U.S. Department of Agriculture (USDA), concerning
benefits of wood preservatives, and the National Institute
of Occupational Safety and Health (NIOSH) about possible
epidemiology studies in treatment plants.
Many companies have registered wood preservative products.
The companies range in size from very small to Portune-
500 giants. There are from 400 to 600 wood preservative
treatment plants, employing about 13,000 workers, and thousands
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of sawmills and other work situations where wood preservatives
may be used. The majority of the treatment plants have
fewer than 20 workers, but about 5$ of the plants
have more than 100 workers. The plant technologies range
from fairly primitive to highly sophisticated.
The economic impacts of the proposed modifications for
treatment plants using pressure or non-pressure applications
are given below. In estimating the costs, the Agency
assumes that these industries already provide employees with
some protective clothing; therefore, these estimates reflect
only the increase in cost to these industries (except for
particleboard).
To the wood preserving industry using pressure treatment,
the total cost to implement the proposed modifications
(protective clothing and equipment, restricted use, closed
systems, and arsenic surface residues) for the three wood
preservatives would range from $4 million to $5-7 million
for the first year and from $J>.8 million to $5.4 million for
each subsequent year.
To the industry which treats millwork and plywood with
penta, the total cost to implement the proposed modifi-
cations (protective clothing and equipment, and restricted
use) would range from $4-1 million to $4-9 million for the
first year and from $4-1 to $4.8 million for each subsequent
year. The total cost of implementing the proposed modifi-
cations (protective clothing and equipment, closed systems,
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and restricted use) to the industry that treats wood with
sodium penta for sapstain control would range from $9.1
million to $11.7 million for the first year and from $4
million to $5 million for each subsequent year. The
total cost to the one plant treating particleboard with
penta, assuming that closed systems are needed and that
protective clothing is not currently supplied by the plant,
is $12,000 to $17,000 for the first year; for each subsequent
year a cost ranging from $1,800 to $5,600 for the protective
clothing would expected.
The total cost of implementing the proposed modifications
(protective clothing and equipment, and restricted use) to
the industry treating the groundline of poles with creosote
and penta would be $45 thousand to $150 thousand for the
first year and from $42 thousand to $160 thousand for each
subsequent year. For the home and farm use, the cost of
implementing the proposed modifications (protective clothing
and equipment, and restricted use) for the certified applicators
is expected to range from $3-5 million to $3-6 million for
the first year and for each subsequent year; for non-certified
home and farm applicators, the cost to each individual will
range from insignificant to $25, depending on the protective
clothing which must be purchased. The cost impacts for the
poles-groundline industry and the certified home and farm
application may be vastly overestimated because the Agency
has developed its figures based on the assumptions that
protective clothing is not currently used.
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Acknowledgements
I. Special Pesticide Review Division "team
A. VJbod Rreservative Team
Paul Gammer, Dean Leader; Project Manager, Pentachlorophenol
and Creosote
Stephanie ft>an, learn leader; Project Manager, Inorganic
Arsenicals
David Brooks, Project Manager; Creosote, Inorganic Arsenicals,
and Pentachlorophenol
Paul Parsons, Project Manager
Lynda Priddy, Project Manager
Joan Warshawsky, Section Head
B. Support lean
Ben Lemlich, Project Manager
Barbara Moore, Secretary
Betty Crcmpton, lypist
Ibnda Hicks, lypist
Donna Peacher, lypist
Mlliam Sfiiftlet, lypist
Dorothy Vaughn, lypist
Artie Willians, lypist
Mike Unerich, Student Assistant
Miriam Smith, Student Assistant
C. Special Acknowledgement
Dan Cirelli
Herman Gibb
Anita Schmidt
Kathy Smith
Geraldine Werdig
Phil Vvilliams
II. lechnical Support Ifeam
A. Benefits and Field Studies Division
William Gummings, Plant Pathologist
Donald Eckerman, Economist
Robert Esworthy, Economist
Mark Glaze, Economist
Edmund Jansen, Jr., Economist (IPA)
George Ludvik, Entomologist
B. Hazard Evaluation Division
Anne Barton, Senior Science Advisor
John Brantner, lexicologist
Bill Burnam, Deputy Branch Chief (lexicology Branch)
Christine Chaisson, Section Head, (lexicology Branch)
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harry Cay, Chemist
Julian Donoso, Chemist
lhanas Edwards, Pharmacologist
Roger Gardner, lexicologist
Judy Hectanan, RPAR Coordinator, Program Analyst
-Bob Hitch, Fish and Wildlife Biologist
Dave Johnson, Chemist
\&n K>zak, Project Director (Chemist)
Albin Kocialski, lexicologist
Abraham Mittleman, Chemist
Ran Rakshpal, Chemist
Amy Rispin, Science Advisor/(Chemist)
Dave Ritter, lOxicologist
Dave Severn, Branch Chief (Environmental Fate Branch)
Minnie Sochard, Biochemist
John lice, Fish and Wildlife Biologist
Daug Urban, Wildlife Biologist
Dave \fan Crmer, Chemist
C. Office of General Counsel
Cara Jablon, Attorney Advisor
D. Cancer Assessment Group,
Robert McGaughy, Acting Director, lOxicologist
Charm Singh, lOxicologist
III. Em Pesticide Chemical Review Committee (PCRC)
Charles Gregg, Office of Water and Waste Management
Richard N. Hill, Office of Toxic Substances
Allen Jennings, Office of Personel Management
Donna ttjroda, Office of Research and Development
Jack J. Nsylan, Office of Enforcement
Raymond Smith, Office ofAir, Noise, and Radiation
Marcia Willians, Special Pesticide Review Division
Michael Winer, Office of General Counsel
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TABLE OF CONTENTS
EXECUTIVE SUMMARY
ACKNOWLEDGEMENTS PAGE NO.
TABLE OF CONTENTS
PART I. INTRODUCTION 1
A. General Background and Organization of this
Position Document 1
B. Legal Background 2
1. The Statute 2
2. The RPAR Process 3
C. Chemical Background 5
1. Creosote 5
a. Chemical and Physical Characteristics.... 5
b. Registered Uses and Production 7
c. Tolerances 7
2. Inorganic Arsenical Compounds 9
a. Chemical and Physical Characteristics.... 9
b. Registered Uses and Production 11
c. Tolerances 12
3. Pentachlorophenol 13
a. Chemical and Physical Characteristics.... 13
b. Registered Uses and Production. 17
c. Tolerances 18
4. Alternative Wood Preservative Compounds 19
a. Chemical and Physical Characteristics.... 19
b. Registered Uses and Production 21
c. Tolerances 22
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PART II. RISK ANALYSES AND ASSESSMENTS 23
A. Purpose and Organization 23
B. Creosote 25
1. Analysis of Rebuttal Comments Concerning
Mutagenicity 25
a. Basis of Presumption 25
b. Analysis of Specific Rebuttal Comments... 27
c. Summary of Rebuttal Comments Concerning
Mutagenic Effects: Conclusion 34
2. Analysis of Rebuttal Comments Concerning
Oncogenicity 36
a. Basis of Presumption 36
b. Analysis of Specific Rebuttal Comments... 46
c. Summary of Rebuttal Comments Concerning
Oncogenicity: Conclusion 56
3. Analysis of Rebuttal Comments Concerning
Human Exposure 58
4. Revised Human Exposure Analysis 64
a. Chemistry 64
b. Description of Treatment Process 66
c. Revised Human Exposure Analysis for
Specific Exposure Situations 68
5. Qualitative Risk Assessment for Mutagenicity. 75
6. Qualitative Risk Assessment tor Oncogenicity. 85
a. Introduction 85
b. Chemical Composition of Creosote and
Creosote/Coal Tar Blends 86
c. Toxicology 87
d. Conclusion 92
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C. Inorganic Arsenical Compounds 95
1. Analysis of Rebuttdl Comments Concerning
Interconversion of Pentavalent to
Trivalent Arsenic 95
a. Basis of Concern 95
b. Analysis of Specific Rebuttal Comments... 97
c. Summary of Rebuttal Comments Concerning
Interconversion: Conclusion 102
2. Analysis of Rebuttal Comments Concerning
Oncogenicity 103
a. Basis of Presumption 103
b. Analysis of Specific Rebuttal Comments... 105
c. Summary of Rebuttal Comments Concerning
Onogenicity: Conclusion Ill
3. Analysis of Rebuttal Comments Concerning
Mutagenicity Ill
a. Basis of Presumption Ill
b. Analysis of Specific Rebuttal Comments... 118
c. Summary of Rebuttal Comments Concerning
Mutagenic Effects: Conclusion 126
4. Analysis of Rebuttal Comments Concerning
Fetotoxic and Teratogenic Effects 127
a. Basis of Presumption 127
b. Analysis of Specific Rebuttal Comments... 145
c. Summary of Rebuttal Comments Concerning
Fetotoxic and Teratogenic Effects:
Conclusion 158
5. Other Health and Environmental Concerns:
Delayed Neurotoxicity 160
a. Basis of Concern 160
b. Analysis of Specific Rebuttal Comments... 166
c. Summary of Rebuttal Comments Concerning
Neurotoxicity Effects: Conclusion 168
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Analysis of Rebuttal Comments Concerning
Human Exposure ............................... 168
a. Basis of Analysis ........................ 168
b. Analysis of Sf.-cific Rebuttal Comments... 170
c. Summary of Rebuttal Comments and Revised
Assumptions ........................... 193
7. Revised Human Exposure Analysis .............. 195
a. Introduction ............................. 195
b. Summary of Breathing Rate Assumptions.... 196
c. Discussion of Data Range Assumptions ..... 196
d. Revised Human Exposure Analysis tor
Specific Exposure Situations ........... 203
e . Summary .................................. 211
8. Quantitative and Qualitative Risk Assess-
ments ...................................... 214
a . Oncogenic Effects ........................ 214
b. Mutagenic Effects ........................ 21b
c. Teratogenic and Fetotoxic Effects ........ 232
D. Pentachlorophenol
1. Analysis of Rebuttal Comments Concerning
Fetotoxic and Reproductive Effects ......... 247
a . Basis of Presumption ..................... 247
b. Analysis of Specific Rebuttal Comments... 253
c. Summary of Rebuttal Comments; Conclusion 261
2. Analysis of Rebuttal Comments About Exposure;
Revised Exposure Analysis .................. 263
a . Basis of Analysis ........................ 263
b. Analysis of Specific Rebuttal Comments... 264
3. Revised human Exposure Analysis .............. 296
a. Assumptions and Methods .................. 296
b. Penta Concentrations Measured in Air ..... 299
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c. Penta Residues in Human Urine and Serum.. 309
d. Revised Human Exposure Analysis for
Specific Exposure Situations 313
e. Summary of Revised Human Non-Dietary
Exposure Analysis 336
f. Dietary Exposure 336
4. Pentachlorophenol's Potential Oncogenicity... 344
a. Introduction 344
b. Hexachlorodibenzo-p-dioxin 345
c. Hexachlorobenzene 345
5. Quantitative and Qualitative Risk
Assessments 347
a. Fetotoxic, Teratogenic, and Reproductive
Effects 347
b. Oncogenicity 356
E. Alternatives 3b7
1. introduction 367
2. Acid Copper Chromate (ACC) and Chromated
Zinc Chloride (CZC) as Chromium , 36b
3. Bis( tributyltin) Oxide (TBTO) 369
a. Acute Toxicology 369
b. Chronic Toxicology 370
4. Copper-8-Quinolinolate (Cu-8) 371
a. Acute Toxicology 3V1
b. Chronic Toxicology 372
5. Copper Naphthenate 372
a. Acute Toxicology 372
b. Chronic Toxicology 373
6. Zinc Naphthenate 374
a . Acute Toxicology 374
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b. Chronic Toxicology 374
7. Tnchiorophenol and Tetrachlorophenol 375
a. Introduction 375
b. 2,4,5 Trichlorophenol 375
c. 2,4,6 Trichlorophenol 376
d. 2,3,4,6 Tetrachlorophenol 376
8. Summary 376
PART III. BENEFIT ANALYSIS 379
A. Introduction 379
B. Pressure Treatments 380
1. Profile of the Wood Treatment Industry 380
a. Introduction 380
b. Usage of Wood Preservatives 381
c. Employment and Revenue 393
2. Comparative Costs of Wood Preservatives
Compounds, Their Future Availability and
Price, and the Projected Service Life of
Treated Wood 394
a. Introduction 394
b. Comparative Costs of Wood Preservative
and Service Life of Treated Wood 395
c. Future Availability and Price of Creosote 410
d. Future Availability and Price of
Inorganic Arsenicals 411
e. Future Availability and Price of Penta... 413
3. Capital Requirements for Alternative
Treatments 413
4. Methods and Assumptions 417
5. Benefit Analysis by Use Category for Pressure
Treatments 421
a. Railroad Ties 421
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b. Lumber, Timber and Plywood 427
c. Pilings 440
d. Posts 454
e. Crossarms 462
f. Poles 467
C. Non-Pressure Treatments 486
1. Profile of the toood Treatment Industry and
Applicators for Non-Pressure Treatments.... 486
a. Poles-Groundline 486
b. home and Fa rm 487
c. Sapstain Control 487
d. Millwork and Plywood 487
e . Particleboard 489
2. Benefit Analysis by Use Category for
Non-Pressure Treatments 489
a . Poles-Groundline 489
b. home and Farm 494
c. Sapstain Control 512
d. Millwork and Plywood 523
e. Particleboard 528
D. Summary of Wood Preservatives Economic Impacts.. 532
1. introduction 532
2. Pressure Treatments 532
3. Non-Pressure Treatments 549
PART IV. DEVELOMENT OF REGULATORY OPTIONS 553
A. Introduction 553
B. Basis and Rationale for Developing Options and
Modifications 553
C. Discussion of Option 2, Modifications to the Terms
and Conditions of Registration 555
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a. Require Protective Clothing: Gloves.... 556
b. Require Protective Clothing: Coveralls. 557
c. Require Protective Clothing: Neoprene
Suit and Respirators 558
d. Require Protective Clothing: Dust Mask. 559
e. Require Special Laundering and Care of
Protective Clothing 559
f. Prohibit Eating, Drinking and Smoking
During Application 560
g. Confine Emptying Bags and Mixing of Powder
and Prilled Formulations to closed
Systems 561
h. Classify for Restricted Use 562
i. Restrict Application of Wood Preserva-
tives to Outdoors and the Application of
Wood Preservatives to Wood Destined for
Interior Uses 563
j. Prohibit Uses Likely to Result in Direct
Exposure to Domestic Animals or Livestock
or in the Contamination of Food, Feed, or
Potable Water 563
k. Require Special Disposal of Treated
Wood 564
1. Reduce Contaminants in Penta 566
D. Other Relevant Statutory Measures 567
1. Occupational Safety and Health Act 567
2. Toxic Substances Control Act 568
3. Consumer Product Safety Act 570
4. Resource Conservation and Recovery Act 571
PART V. REVIEW OF THE IMPACTS OF REGULATORY OPTIONS
AND MODIFICATIONS 573
A. Introduction 573
B. Use Categories: Pesticides Applied at Pressure and
Non-Pressure Treatment Plants 575
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1. Summary of Risks 576
a. Creosote 578
b. Inorganic Arsenical Compounds 581
c. Penta 586
2. Summary of Benefits 590
a. Introduction 592
b. Pressure Treatment Plant Uses 593
c. Non-pressure Treatment Plant Uses 608
3. Risk/Benefit Analysis 612
a. Consideration of Regulatory Options 612
b. Risk/Benefit Impacts of Modifications Under
Consideration for Treatment Plants 613
4. Selection of Regulatory Options and
Modifications for Treatment Plants 633
a. Creosote 635
b. Inorganic Arsenicals 636
c. Penta 637
d. Specific Options Selected 638
C. Use Categories: Pesticides Applied Outside of
Treatment Plants 663
1. Summary of Risks 663
a. Poles-Groundline 663
b. Home and Farm 664
c. Brush-on Applications of the Inorganic
Arsenicals 666
2. Summary of Benefits 666
a. Poles-Groundline 666
b. Home and Farm 660
c. Brush-on Applications ot the Inorganic
Arsenicals 670
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3. Risk/Benefit Analysis 670
a. Consideration of Regulatory Options 670
b. Risk/Beknefit Impacts of Modifications
Under Consideration for Poles-Ground,
Home and Farm, and Brush-on Applications
of the Inorganic Arsenicals 671
4. Selected Modifications for Poles-Groundline
(Creosote and Penta), home and Farm (Creosote
and Penta), Brush-on Applications of the
Inorganic Arsenicals 679
a. Poles-Groundline 680
b. Home and Farm 682
c. Brush-on Applications of the
Inorganic Arsenicals 684
D. End-Uses of Treated Vvood 685
1. Summary of Risks 686
a . Creosote 686
b. Inorganic Arsenicals 687
c. Penta 688
2. Summary of Benefits 690
3. Risk/Benefit Analysis 691
a. Consideration of Regulatory Options 691
b. Possible Modifications Under FIFRA 692
c. Possible Modifications Under 1SCA 696
E. Summary of Proposed Regulatory Action Under
FIFRA 703
F. Summary of Projected Regulatory Measures Under
TSCA 719
Appendix 1A-C: Rebuttal Comments Received
Appendix 2: Concepts that Vvere Considered as Possible Regulatory
Options for the Wood Preservative Pesticides
Bibliography
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1. INTRODUCTION
A. Genetal bacKground and Organization of this Position Document
'ihe Federal insecticide, Fungicide, and Rodenticide Act as
amended (FIFRA) and its regulations require the Environmental
Protection Agency (EPA) to review tiie risks and benerits of che
uses of pesticides. On October ib, 1S78, EPA issued Notices of
Rebuttable Presumption Against Registration and Continued
Registration (RPAR) of pesticide products containing coal tar,
creosote, and coal tar neutral oils, ot those containing the
inorganic arsenical compounds, and ot those containing penta-
chiorophenol and its salts. The presumption against coal tar,
creosote, and coal car neutral oils was based on validated
studies showing that these compounds are oncogenic and muta-
genic; the presumption against the inorganic arsenical compounds
was based on studies showing they are oncogenic, mutagenic, and
tetotoxic; the presumption against pentachlorophenol (penta) was
based on studies showing it is teratogenic and tetotoxic. The
Position Document 1 (PD-1) issued with the Notice of Rebuttabie
Presumption describes these studies in detail. bince the publi-
cation ot PD-i, other validated studies have shown that some
contaminants ot penta are oncogenic.
This Position Document 2/3 (PD-2/3) addresses the risks and
benefits ot the wood preservative uses of creosote, coal tar,
and coal tar neutral oils, the inorganic arsenical compounds,
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and pentachlorophenol. 'ihe other uses ot these pesticides will
be considered in luture position documents. This document
contdins five parts. Part I is this introductory section. Part.
11 evaluates the potential risks ol these wood preservatives.
It includes descriptions and evaluations ot the risK evidence,
exposure data, rebuttal submissions, and the Agency's present
risk assessment. Part 111 estimates and summarizes the economic
benefits ot these wood preservatives tor each use category and
describes the assumptions and limits ot these estimates. Part
IV describes the range oi possible regulatory options ana
modifications to reduce the risks ot these pesticides, and
explains the Agency's selection ot some of these options tor
further consideration. Part V evaluates the specific impact on
the risks, benefits, ana other effects which would occur it each
applicable option and modification tor each use category were
adopted and presents the options and modifications selected by
the Agency.
B. Legal Background
1. The Statute
The F1FRA (7 U.b.C. S136 eL seq.) regulates ail pesticide
products. Unaer Section 12(a)(l)(A) of F1FKA all pesticides
must be registered before they may be sold or distributed.
Before the Administrator may register a pesticide, however, he
must determine that its use will not result in "unreasonable
adverse effects on the environment," which is defined by bection
-------
2(bb) of FIFRA to mean "any unreasonable risK to man or the
environment, taking into account the economic, social, and
environmental costs and benefits of the use of any pesticide."
In other words, any decision about pesticide registration or
continued registration must take into account both the risks and
the benefits of the use of the pesticide.
Section 6(b) of FIFRA authorizes the Administrator to issue a
notice of intent to cancel the registration of a pesticide or to
change its classification if it appears to him that the pesti-
cide or its labeling "does not comply with the provisions oi
[FIFRA] or, when used in accordance with widespread ana commonly
recognized practice, generally causes unreasonable adverse
effects on the environment." Thus, the Administrator may cancel
the registration of a pesticide whenever he determines that it
no longer satisfies the statutory standard for registration;
that standard requires, among other things, that the pesticide
not cause "unreasonable adverse effects on the environment"
[FIFRA Section 3(c) (5 ) ( C)] . He may also cancel the registration
of a pesticide if its labeling does not comply with the misbrand-
ing provisions of FIFRA which require the labeling to contain
language "adequate to protect health and the environment" [F1FRA
Section 2(q)].
2. The RPAR Process
The Agency has designed a process, known as the Rebuttable
Presumption Against Registration (RPAR) process, to gather risk
-------
ana benefit information about pesticides which appear to pose un-
reasonable tisKs to health or to the environment. Ihis process,
designed to allow an open, balanced decision with participation
by all interested groups, is set torth in 40 CFR 162.11. These
regulations describe various risk criteria, and provide that an
RPAR shall arise if the Agency determines that any of the risK
criteria have been met. Once a notice of rebuttable presumption
has been published, registrants, applicants and interested
persons may submit evidence in rebuttal or in support ot the
presumption. All parties may also submit evidence on the
economic, social, and environmental benefits ot any use ot the
pesticide. If the presumptions of risk are not rebutted, the
benefits evidence submitted to or gathered by the Agency must be
evaluated and considered with the risk information. The agency
analyzes various risk reduction methods and their costs. rihe
Agency then determines if a pesticide's use may be regulated so
that its risKS are outweighed by its benefits. If a balance
between risKS and benefits cannot be reached tor a specific use,
the registration for that use must be cancelled or otherwise
restricted, or, in the case ot a new application, denied.
4
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C. Chemical Background
1. Creosote
a. Chemical and Physical Characteristics
Creosote and coal tar are extremely complex mixtures containing
hundreds ot identitiabie constituents. Uhese mixtures are
produced by the high temperature carbonization of coal, a
process referred to as coKing. 'itiey vary in composition,
depending on the temperature of coking and the source ot coal
used (Nestier, 1974). However, unless otherwise specified or
explained, this document will use the term "creosote" to refer
to all three of the wood preservatives derived from coal tat,
that is, coal tar, creosote, and coal tar neutral oil. Products
similar to coal tar-derived creosote, which are ajiso called
creosote, may be distilled from sources other than coal, but
these products are very different in chemical composition, and
therefore this document refers only to those products distilled
from coal tar.
Coal tar is produced by the carbonization (coKing) of coal.
'iheoreticaily, there may be as many as ten thousand compounds in
coal tar, although most of these compounds are present only in
trace amounts (NIOSH, 1977). Over three hundred compounds have
been positively identified in coal tar. The chemical reactions
in the process are not well understood. it is known, however,
that the duration and temperature of the process affect the
-------
mixture of the constituents formed; longer durations and higher
temperatures favor the formation of more highly condensed
aromatic compounds such as polynuclear aromatic hydrocarbons
(PAH's). Low temperature carbonization yields approximately
twice as much oil and tar as high temperature carbonization.
Coal tar is a black, viscous liquid that has a naphthalene-
like odor and a sharp burning taste. It combustible and has a
speciiic gravity of 1.18-1.23 (60/60°F). It is soluble in
benzene, carbon disulfide, and chloroform, partially soluble in
alcohol, acetone arid methanol, and only slightly soluble in
water (Hawley, 1977) .
'Ihe American Wood Preservers Association (AWPA) defines creosote
as a distillate derived from coal tar which consists principally
of liquid and solid aromatic hydrocarbons, although some tar
acids and bases are also present. It is heavier than water and
has a continuous boiling range from about 200 C to about
450°C (AWPA, 1976; Nestler, 1974). The AVvPA promulgates
standards for creosote and blended creosote/coal tar solutions
(e.g., 60/40, 70/30, and 80/20) for use as wood preservatives
based on water content, benzene-soluble material, specific
gravity, and distillation range (see PD-1, Appendices A and B).
bmale (1977) states that coal tar neutral oils are generally
defined as a mixture of naphthalene, fluorene, anthracene, and
other neutral iiydrocarbons. Neutral hydrocarbons are those coal
-------
tar hydrocarbons other tnan coal tat. acids (such as phenol,
cresols, and cresyiic acids) and coai tar bases (such as pyri-
dines, quinolines, and acridines).
b. Registered Uses and Production
By tar the largest pesticidal use (98%) of creosote is as a wood
preservative. Creosote is nearly always (>90%) applied by
pressure-treating methods (American Woou Preservers Institute,
1977). In 1972, of the 1,150 million pounds of creosote used in
the United btates, 972 million pounds were useu as wood preser-
vatives (Von Rumker et al., 1975). In 1975, about 843 million
pounds (96,266,000 gallons of creosote) were used as a wood
preservative (Fuller et al., 1977). Pesticide production data
reported to the Environmental Protection Agency under Section 7
of FIFKA indicated that 366,839,110 pounas of creosote,
34,847,384 pounds of coal tar, ana 2,019,951 pounds of coal tar
neutral oils were formulated or blended tor pesticidai use in
1975. The quantity of creosote and creosote solutions consumed
by the wood preserving industry in 1978 was 34,100,000 gallons
of creosote, 66,400,000 gallons of creosote-coal tar solutions
and 30,200,000 gallons of creosote-petroleum (Kaioney and
Pagiiai, 1979) .
c. Tolerances
This Agency has established no tolerances or exemptions from
tolerances, and the U.S. Food and Drug Administration (FDa) has
-------
established no action levels for creosote in or on raw agricul-
tural commodities. Under the provisions of 21 Ct'K, the FDA has
*
not established an indirect tood additive regulation for
creosote where it may be used safely as a wood preservative tor
holding, transporting, or packaging raw agriculture products.
Ihe absence of tolerances and exemptions from tolerances for
creosote is of concern to the Agency because some use patterns
of creosote may result in creosote residues in food or feed.
* According to CFR 21, Part 170, Section 170.3, "food additive"
includes all substances in which the intended use of which
results, or may reasonably be expected to result, directly or
indirectly, either in their becoming a component of food, or
otherwise affecting the characteristics of tood. Material used
in the production of containers and packages is subject to the
definition it it may reasonably be expected to become a
component, or to directly or indirectly affect the characteris-
tics of tood packed in the container. The general provisions
applicable to "indirect food additives" (Part 174, Section
174.b) are regulations prescribing conditions under which food
additive substances may be safely used and predicate usage under
conditions of good manufacturing practice. The quantity of any
food additive substance that may be added to tood as a result of
use in articles that contact food shall not exceed, where no
limits are specified, that which results from use of the
substance in an amount not more than reasonably required to
accomplish the intended physical or technical effect in the food-
contact article; shall not exceed any prescribed limitations;
and shall not be intended to accomplish any physical or
technical effect in the tood itself.
8
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2. Inorganic Arsenical Compounds
a. Chemical and Physical Characteristics
because arsenic has multiple valence states, the inorganic
arsenical compounds have distinctly ditferent physical and
chemical properties. Arsenic pentoxide, sodium arsenate ,
arsenic acid, and sodium pyroarsenate are pentavalent arsenical
compounds; ammonium arsenite and arsenic trioxide are trivalent
arsenical compounds. These are the compounds used in the
tormulation of inorganic arsenical wood preservatives. (Another
compound of concern is arsine, a toxic gas which may be produced
by burning arsenical-treated wood or by other processes.)
i. Arsenic Pentoxide
Arsenic pentoxide is a white, amorphous solid. Its chemical
formula is As c^, its molecular weight is 221.12, its den-
sity is 4.j, and it decomposes at 315 C. It is very so'iubie
in water, IbUO g/liter "(Oak kidge, 1976).
-------
ii. Sodium Arsenate
bodiuin arsenate's chemical formula is ha hAsG., its moiecu-
lar weight is Ib5.91, and its density is 1.9. It is a grey-
white powder c*nd is very soluble in water (OaK Ridge, 197b)
111. Arsenic Acid
arsenic acid is the common name tor orthoarsenic acid. its
chemical formula is H-.AsO., its molecuiar weight is 141.93,
and its density is 2.0 to 2.5 (heister, 1977). It occurs as
white, translucent crystals at 20 C. Its melting point is
.35.5 C and the boiling point is 160 C in the anhydrous
state. The solubility ot arsenic acid in water is lb7 g/liter
(Oak Ridge, 1ST/6) .
iv. bodium Pyroarsenate
bodium pyroarsenate1s chemical formula is Na.As O^, its
molecular weight is 353.79, ana its density is 2.2. It occurs
as white crystals and decomposes at 1,000 C. its melting
point is 850°C, and it is very soluble in water (Weast, 1977).
v. Ammonium Arsenite
'ihe chemical formula of ammonium arsenite is NH.AsG.,. Its
molecular weight is 125, and its density is 1.3. It forms color-
10
-------
less, hygroscopic rhombic prisms. It is very soluble in cold
water and decomposes in hot water (Vveast, 1977).
vi. Arsenic Trioxide
Arsenic trioxide is the common name tor arsenious (or arsenous)
oxide. Retined arsenic trioxide is Known as white arsenic.
Arsenic trioxide occurs as an amorphous white powder or as a
vitreous solid. Its chemical formula is As2(K (also As.Q,),
its molecular weight is 197.b, and its density is 3.7. It boils
at 465 C and sublimes at 193 C. Its solubility in water is
20.6 g/iiter (Oak Ridge, 1976).
b. Registered Uses and Production
There are three inorganic arsenical wood preservatives of commer-
cial importance: chromated copper arsenate (CCA), ammoniacal
copper arsenate (ACA), and fluor chrome arsenate phenol (FCAP).
These three wood preservatives are various mixtures made, in
part, from ammonium arsenic pentoxide, or sodium arsenate, or
sodium pyroarsenate.
in industrial situations, concentrates of the inorganic arseni-
cal formulations are delivered as powders, liquid concentrates,
or pastes. These concentrates are dumped or otherwise metered
and mixed with water to form dilute treating solutions of 0.75
11
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to 6.0%, depending on the intended end-use of the treated wood.
Although the majority ot wood is treated in closed cylinders
under pressure, sometimes the preservatives are painted on wood
or the wood is dipped or soaked in the solutions.
Ammonium arsenite is formulated with other ingredients (the
final concentration ot ammonium arsenite is 7.7%) tor use in
pressurized wood treatment systems. Arsenic pentoxide and
arsenic trioxide are also formulated with other ingredients
(final concentrations ot arsenic pentoxide or arsenic trioxide
are either 1.5% or 37.0%) for pressure treatment. Sodium
pyroarsenate is formulated with other ingredients (final
concentration = 6.2%) for pressure treatment. Sodium arsenate,
which is also used as an insecticide, is available as a 43%
dust, a 2% solution, and in 14.0% to 43.5% formulations with
other ingredients for pressure use (Meister, 1977; EPA, 1975).
The total volume of inorganic arsenical wood preservatives has
increased threefold, from B,952,000 pounds in 1967 to 27,300,000
pounds in 1977. Nearly 20% ot treated wood products are treated
with inorganic arsenical compounds (AWPA, 1978).
c. Tolerances
This Agency has not established tolerances or exemptions
from tolerances, and the FDA has not established action
levels for arsenic residues in or on raw agricultural
commodities resulting from wood uses ot arsenic pentoxide,
12
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sodium arsenate, arsenic acid, spdium pyroarsenate, ammonium
arsenite and arsenic trioxide, or inorganic arsenical wood
preservative formulations. Under the provisions of 21 CFR, the
*
FDA has not established an indirect food additive regulation
for these wood preservative compounds or their formulations.
The absence of tolerances and exemptions from tolerances tor the
inorganic arsenical compounds is of concern to the Agency
because some use patterns of these compounds may result in
residues in food or feed.
3. Pentachlorophenoi
a. Chemical and Physical Characteristics
Pentachiorophenol is commonly called "penta." It is a buff
colored crystal which is produced in the United States by chlor-
ination of molten phenol in the presence of a catalyst. The
major commercial forms of penta are the unmodified phenol and
the sodium salt. Figure 1 shows the structural formulae of
these forms of penta, while Table 1-1 contains the chemical and
physical properties of these compounds. Two other forms, not
used as wood preservatives, are the potassium salt and the
lauric acid ester.
* See footnote on page 8.
13
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Table 1-1
Physical Properties of Pentachiorophenol and Sodium
Pentachiorophenate
Name Pentachiorophenol Sodium Pentachiorophenol
Formula e.aUOH C,-Ci .ONa .H00
b D b b 2.
Molecular Weight 266.4 306.3
Specific Gravity 1.9 2.0
Density 1.987
Vapor Pressure 0.00015 (25°C)
Solubility,
-O,,
g/100 g, 25 C
33
35
Wa te r
Acetone
Benzene
Diaetone
Alcohol
Ethanol (95%)
Methanol
Isopropanol
Ethylene giycoi
<0.01
50
15
190
120
iyo
85
11
45
65
25
30
40
14
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FIGURE 1
Structure of Penta and Its Sodium Salt
Pentachlorophenol
Cl
Cl Cl
Sodium Pentachlorophenate
FIGURE 2
Structure of Dioxin and Furan
0
6 4
Dibenzo-p-dioxin
6 4
Dibenzofuran
15
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Industrial production of penta is a two-stage process. In the
tirst stage, phenol is chlorinated at 105 C to yield isomers
ot tri- and tetrachlorophenols. In the second stage, the
temperature is gradually increased to 130°C to keep the
reaction mixture molten, and the tri- and tetrachlorophenois are
further chlorinated to form pentachlorophenoi. However, not ail
of these precursor compounds react in the process; some ot the
tetrachiorophenols survive and remain with the penta through
later processing. Technical grade penta, therefore, contains
from 4 to 12% tetrachlorophenols; in fact, one of the three
possible tetrachlorophenol isomers, 2,3,4,6-tetrachlorophenol,
is listed as an active ingredient in some penta products.
Dioxin and furan contaminants also form in the commercial
production of penta. The higher temperatures ot the second
stage of penta production are favorable to the condensation of
the tri- and tetrachiorophenols to form hexa-, hepta-, and
octachlorodibenzo-p-dioxins (dioxins) and various chlorinated
dibenzoturans (furans) . Figure 2 shows the structural formulae
ot the basic molecules of these contaminants. Substitution of
chlorine atoms at one or more of the numbered positions produces
a member ot the chlorinated dibenzc~p-dioxin (dioxin) or chlori-
nated dibenzoturan (furan) chemical families.
Buser and Bosshardt (1976) report that the forms of dioxins most
prevalent in commercial penta are hexa-, hepta-, and octachloro-
dibenzo-p-dioxins (HxCDD, HpCDD, and OCDD, respectively). A
small amount of tetrachlorodibenzo-p-dioxin (TCDD) has also been
16
-------
found in penta (Buser, 1976), although this proved not to be the
extremely toxic 2, 3, 7, b-isomer. The lurans found in penta are
the tetra-, penta-, hexa-, hepta-, and octaehlorodibenzofurans
(buser and Bosshardt, 1976).
b. Registered Uses and Production
Many products containing penta and its soaium salt are regis-
tered as wood preservatives. Ihey are among the most versatile
pesticides now in use, due to their etlicacy against a wide
range of pests (bacteria, yeast, slime molds, algae, fungi,
plants, insects, snails), and to their solubility in both
organic solvents (penta) and water (sodium penta).
As of 1977, about 50 million pounds of penta were produced
annually in the United States; production was expected to
increase to 80 million pounds annually in the near future
(Josephson, 1977). In general, about bO% of all penta produced
is used tor wood preservation. however, this use did not
increase in 1978, when the U.b. wood preservative industry used
only about 29,900,000 Ibs. of penta (Maloney and Pagliai,
1979). Most of the remaining penta is used in register
fungicide products applied to wide variety of industrial
products including leather, burlap, masonry, cordage, paint,
pulp and paper mills, and cooling towers.
17
-------
The absence of tolerances and exemptions from tolerances for
penta is of concern to tne Agency because some other use
patterns of penta may result in residues in food or feed.
c. Tolerances
This Agency has established no tolerances or exemptions from
tolerances, and FDA has not established action levels for
pentachlorophenol in or on ravv agricultural commodities. The
FDA has several regulations permitting the use of penta in wood
*
and non-wood,packaging materials as an indirect food additive .
One of these regulations (21 CFR, Part 178.3800) indicates
that penta and its sodium salt may be applied safely to wooden
articles intended for use in packaging, transporting, or holding
raw agricultural products. The regulation specifies that pentci
residues, which occur when penta is applied as a wood
preservative, are not to exceed 50 parts per million (ppm),
calculated as penta, in the treated wood.
* See footnote on page 8.
18
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4. Alternative Wood Preservative Compounds
a. Chemical and Physical Characteristics
i. Bis( tri-n-butyltin) oxide
Bis( tri-n-butyltin) oxide is a colorless to light yellov, liquid.
Its chemical formula is C-Ht-^OSn., , its molecular weight is
594, and its specific gravity is 1.17 at 25°C (Hawiey, 1977).
Bis( tri-n-butyltin} oxide's boiling point is IbU C at 2mm Hg ana
its freezing point is below -45 C, with negligible vapor
pressure. Its solubility in water is about 20 ppm at room
temperature and it is miscible with most, organic solvents. It is
made through the Grignara reaction with stannic oxide to give
tributyltin chloride, which is then hydroiyzed to the oxiae
(Martin, 1972) .
li . Copper-fa-quinolinolate
Copper-8-quinoiinoiate is a yellov.-green , nonhygroscopic ,
odorless powder. Its molecular weignt is j51.8b (NIGSh, 1977),
i
and its chemical formula is Cu(C H, ON).,. Ic is soluble in
water and most organic solvents. Copper-8-quinol inoiate is
denveu from 3-quinolinoi and a copper salt, such as copper
acetate (hawiey, 1977). boiubiliiied copper-8-quinolinoiate is
the product formed by heating copper-b-quinolinolate with
19
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certain organic acias (naphthenic, lactic, or stuaric, among
others) or their salts, in these products, the copper-8-
quinoiinoidte does not settle out on standing, even after
dilution with various solvents.
111. Copper naphthenate
Copper naphthenate is a green-blue solid. It is practically
insoluble in water, moderately soluble in petroleum oils, and
soluble in most organic solvents. Copper naphthenate is made by
the interaction ot soluble copper salts (cupric suitate) with
naphthenate, the latter being carboxylic acids derived Irom
crude petroleum oils (Hawiey, 1977; hartin, 1972).
iv. Zinc naphthenate
Zinc napnthenate is an amber, viscous, basic liquid (8-10% Zn)
or basic solid (16% Zn). Its chemical formula is Zn(CftH^COU)„
and it is very soluble in acetone. Zinc naphthenate is made by
lusing zinc oxide or hydroxide and naphthenic acids, or by preci-
pitating from a mixture ol soluble salts and sodium naphthenate
(Hawiey, 1977).
v. Acid copper chromate
Acid copper chromate is essentially a mixture of copper suitate
and sodium dichromate with some addition ot chromic acid. The
solutions which are used as wood preservatives have a pH range
from 2.0 to 3.9 (Fuller, 1977).
20
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vi. Chromated zinc chloride
Lhromated zinc chloride is a mixture of zinc chloride and sodium
dichromate. The solutions which are used tor wood preservation
have a pH range from 2.8 to 4.0 (Fuller, 1977).
vii. Sodium tetrachlorophenate
Sodium tetrachlorophenate1s chemical formula is CgHCl.ONaH O.
It occurs as buff to light brown colored flakes. Its bulk densi-
ty is 26 to 29 Ibs/tt and its pH in a saturated water solu-
tion is 9.0 to 13.0. It is soluble in water, methanol, and
acetone (Hawley, 1977).
vin. letrachlorophenol
'ietrachiorophenol' s chemical formula is C^HCl.OH and its
molecular weight is 231.88. It occurs as brown flakes that
melt from 69 to 70°C. Tetrachlorophenoi is soluble in
acetone, benzene, ether, and alcohol (Hawley, 1977).
b. Registered Uses and Production
All the alternatives are registered as wood preservatives, but
some have other uses. Bis(tri-n-butyitin) oxide is used as a
fungicide and bactericide, especially in underwater and anti-
fouling paints. Copper-8-quinolinolate is used as a fungicide
and for mildew-proofing fabrics. Copper naphthenate is used as
21
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d canvas and rope preservative. Zinc naphthenate is used as a
dryer and wetting agent in paints, varnishes, and resins, as
well as an insecticide and miiaewcide. Sodium tetrachlorophenoi
is used as an industrial preservative (Hav.iey, J.y/7).
c. Tolerances
'ihis Agency has established no tolerances, or exemptions trom
tolerances and FDA has established no action levels lor residues
resulting trom wood uses ot bis( tn-n-butyltin) oxide, copper-8-
quinolinolate, copper naphthenate, zinc naphthenate, acid copper
chromate, chromated zinc chloride, sodium tetrachlorophenate ana
tetrachlorophenol, or tor their wood preservative tormulations
in or on raw agricultural commodities. Only copper-b-quinoiino-
late has an indirect tood additive regulation established by the
*
FDA under the provisions ol 21 CFR, Part 178.3800 .
'ihis regulation states that copper-8-quinolinoiate may be salely
used tor treating wood which is used lor holding, transporting,
or packaging raw agricultural products. 'ihe regulation
specilies that the preservative be applied in amounts riot to
exceed those necessary to accomplish the technical etfect ot
protecting the wood.
* See footnote on page a.
22
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II. RISK ANALYSES AND ASSESSMENTS
A. Purposes and Organization
This Part has three purposes. The first is to state the scienti-
fic bases of the Agency's concern about tne possible risks of
the wood preservatives. The second is to analyze comments by
the pesticide registrants and other concerned parties about
these presumed risKs. The third is to assess the risks of the
wood preservatives in light of the original concerns and the
rebuttal comments.
Risk has two components; the toxic effect (or effects) of the
pesticide, and exposure to the pesticide sufficient to cause the
toxic effect(s) . The toxic effects of concern were first
described in PD-1 as the basis tor the rebuttable presumption.
For creosote, the rebuttable presumption against registration
was issued on the basis of oncogenicity and mutagenicity. For
the inorganic arsenicals, the basis of the presumption was
oncogenicity, mutagenicity, and teratogenicity; two other issues
of concern interconversion and neurotoxicity, were also
presented. Although not a basis for the presumption itself,
interconversion will be discussed here because it was a major
factor supporting the presumptions in PD-1. Neurotoxicity will
be discussed because it is still presents a potential concern.
For pentachlorophenol, the basis for the presumption was fetotox-
icity/teratogenicity.
23
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Since publication of PD-1, new information has indicated that
some of the contaminants of penta are oncogenic. Therefore, the
rebuttabie presumption against penta is now based on oncogeni-
city as well as fetotoxicity/teratogenicity. This Part describes
the scientific basis for this new concern and summarizes the
information which formed the basis of the orginal presumption.
Part II is divided into a section for each wood preservative,
creosote, the inorganic arsenicais, and penta, in addition to
asection which discusses the alternative wood preservatives.
Each of the first three sections contains a summary of the basis
of the risk presumption (based on PD-1, and new information,
where available), a summary of the rebuttal comments on the risk
*
presumption , and the Agency1s decision as to whether the
presumption has been rebutted. In addition to the discussion of
risks, each section also includes a discussion of exposure
to the wood preservative and of rebutters' comments regarding
this exposure. Finally, each of the first three sections
contains the Agency's assessment of each risk, in light' of the
i
Agency's revised position on exposure and risk. The fourth
section briefly describes the possible risks of the alternative
wood preservatives.
* After each heading in the rebuttal sections numerical
reference numbers are given in parentheses. These reference
numbers identify the specific rebutters responsible for the
comments; the reference list is given in Appendix 1 of this
document.
24
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B. Creosote
1. Analysis of Rebuttal Comments Concerning Mutagenicity
a. Basis of Presumption
In the studies summarized in PD-1, mutagenic effects of creosote
and coal tar/creosote were studied in Salmonella typhimurium
strains and in L5178Y mouse lymphoma cells. In both cases,
these chemicals, upon metabolic activation, produced dose-
related increases in mutagenic activity.
i. Simmon and Poole (1978)
This microbiological mutagenic assay was conducted on creosote
and coal tar/creosote (4:6) using Salmonella typhimurium
(strains TA 1535, TA 1537, TA 98, and TA 100) and Escherichia
coii VvP2 as mutagenicity detectors both with and without
metabolic activation by Aroclor 1254-induced rat liver homo-
genate. The doses tested ranged from 5 to 5,000 ug/plate. The
TA 1537 and TA 98 strains are sensitive to frameshift mutations;
WP2, TA 1535, and TA 100 are sensitive to base-pair substitu-
tions; and TA 100 is also sensitive to some frameshift mutations.
Both creosote and coal tar/creosote produced positive mutagenic
responses, which were about twice those of the negative controls,
in Sj, typhimurium strains TA 1537 (at lOug/plate) , TA 98 (at 5
ug/plate), and TA 100 (at 50 ug/plate). These responses occurred
only when the two chemicals were metabolically activated by rodent
25
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liver preparations. The S_. typhimurium TA 1535 and E_^ coli WP2
strains did not produce a positive mutagenic response either with
or without metabolic activation. The results of Simmon and Boole
indicate that the mutagenic mode of action of creosote and coal
tar/creosote is frameshift mutation.
li. Mitchell and Tajiri (1978)
This study was an _in vitro mammalian rautagenesis assay. Mouse
lymphoma cells (L5178Y), heterozygous at the thymidine kinase
locus (TK+/-), were used both with and without by Arocior 1254-
induced rat liver homogenate (S-9 fraction) for activation. The
purpose of these tests was to determine the mutagenic activity
of creosote and coal tar/creosote on the forward mutation
frequency of the TK locus from heterozygous (TK+/-) to homozy-
gous (TK-/-). Ethyl methane sulfonate was used as a positive
control in the creosote experiments, and dimethylnitrosamine was
the positive control in the coal tar/creosote experiments. For
each concentration of test chemical, the mutation frequency
results were calculated as the ratio of the number of mutant
cells to the total number of surviving cells. The induced
mutation frequencies for the tested compound are obtained by
subtracting the negative control's average mutation frequency
from the treated sample's mutation frequency.
Creosote and coal tar/creosote had similar effects on the
forward mutation frequency at the TK locus of the L5178Y mouse
ceils, both with and without metabolic activation. Dose-related
26
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increases in mutation frequencies were reported for both test
chemicals following metabolic activation. However, without
metabolic activation, the mutation frequency in the creosote
testswas reported to be weakly positive at trie highest concentra-
tion, whereas the experiments with coal tar/creosote resulted in
significant increases in the frequency of mutations at the two
highest concentrations.
b. Analysis of Specific Rebuttal Comments
Rebuttal Comment 1: Reliability of the Results of Simmon and
Pooie, 1978 (2)
The American Wood Preservers Institute submitted two unpublished
microbial studies performed by Litton Bionetics, Inc. (LBI, 1977,
1978) to invalidate the gene mutation results ot Simmon and Poole
(1978). LBI, using the same assay (Ames Salmonella test) as
Simmon and Poole, twice investigated the mutagenic potential of
creosote and coal tar/creosote.
The rebutter considered the first Litton study (1977) to be
negative; the second Litton study (1978) was positive. The
rebutter's explanation for the positive results in 1978 was that
the creosote may have aged and/or the rat liver preparation was
different from that used in 1977. The rebutter states that the
results of LBI's experiments show that those of Simmon and Pooie
cannot be relied upon as establishing the potential for human
mutagenicity of creosote mixtures.
27
-------
Agency Response; The Agency has reviewed the two studies
submitted by the rebutter and concludes that, although LBI's
1977 mutagenicity assays performed with microbiai systems were
generally negative, the b_. typhimurium strain TA 100 demon-
strated a positive response. This strain, when tested in 1977
with metabolic activation by rat liver preparations, Was
positive for mutagenicity in one experiment and negative in
another experiment. These conflicting results were not
explained by the authors; however, it is unclear whether the
same sample of creosote was analyzed and if the same rat liver
preparation was used.
The Agency agrees that it is possible that there may have been
differences in the rat liver preparations used in the studies.
These differences could have been caused by different dose
levels of Aroclor given to the rats, resulting in different
activation characteristics of the rat liver preparations. (The
doses were not reported by LB1.) As for the possibility of
mutagenic products being formed upon aging of the creosote, this
aging process will also undoubtedly occur in coal tar/creosote
treating solutions.
Consequently, the Agency cannot accept the argument that because
LBI's tests showed some degree of indeterminance the experiments
performed by Simmon and Poole (1978) are invalid. The Agency
concludes that the LBI 1977 study indeed showed a positive
result for S_^ typhimurium TA 100, and the 1978 LBI study also
showed positive results for £>_., typhimurium TA 1537 and TA 98.
28
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Thus, the Agency does not consider LBI's results to be negative,
as does the rebutter, nor that these results conflict with those
reported by Simmon and Poole (1978). Thus, the Agency concludes
that the data ot Simmon and Poole are valid and supportive of
the presumption of mutagenicity.
Rebuttal Comment 2: Reliability of the Results of Mitchell
and Tajiri, 1978 (2)
The American Wood Preservers Institute claims that the study ot
Mitchell and lajiri (1978) is unreliable for the purpose of
demonstrating potential human mutagenicity ot creosote mixtures.
This is due primarily to the difficulty of interpreting the
results of these experiments where only weak mutagenic activity
is observed at the higher doses ot creosote that caused
pronounced cytotoxicity. The rebutter believes chat observed
mutagenic effects are only valid when a 10% or greater survival
rate occurs in the detector cells treated with three increasing
doses. Because the Mitchell and Taj in study did not meet these
i
criteria, the rebutter believes the results ot this study are
difficult to interpret.
In support of this position, the rebutter submitted an unpub-
lished study. In these experiments, diploid human embryonic
lung tissue was used to study the unscheduled DNA synthesis
(UDS) caused by coal tar/creosote. These results showed
evidence ot weak mutagenicity at high (cytotoxic) levels ot
creosote .
29
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Agency Response: The Agency agrees that the occurrence ot
cytotoxicity complicates the interpretation of the mutagenic
responses observed by Mitchell and Ta^iri (1978). However, even
though the cytotoxicity is higher than desirable and masking of
the mutagenic response (e.g., due to the selective Killing ot
mutants or simply due to a low survival rate of all test cells)
may have occurred, the Agency concludes that the Mitchell and
la^iri study demonstrated the mutagenicity ot creosote mixtures
in the test system.
The Agency has reviewed the study submitted by the rebutter and
concludes that the LBI's results are consistent with those of
Mitchell and Taj in, showing that creosote induces unequivocal,
albeit weak, unscheduled DNA synthesis in human diploid Wl-38
cells in the presence ot rat liver preparations.
Rebuttal Comment 3: Insufficient Data to Meet EPA's
Guidelines for Multitest Evidence (2)
The American Wood Preservers Institute submitted the results of
LB1 experiments in which creosote mixtures were tested in five
microbiai systems. in all cases the results were negative for
mutagenicity. The rebutter believes these results show creosote
does not meet the RPAR risk criteria.
Agency Response; To meet the RPAR risk criteria for potential
mutagenicity [40 CFR, Section 162.11(a)(3)(ii)(A)], a chemical
must be shown to cause gene mutations in at least two of the
30
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thirteen test systems listed in the Proposed Guidelines [40 CFR,
Section 163. 84(b) (2 ) ( i-iii] . As it is stated in the Agency's
proposed guidelines [40 CFR Part 163 (III)(G)J, "A compound
would be considered a mutagen it it produced positive results
in: two different kinds of tests for demonstrating gene muta-
tions; a mouse specific locus test; or any kind of test for
demonstrating chromosome aberrations." The positive results of
Simmon and Pooie (1978) and Mitchell and Ta]iri (1978) provide
more than sufficient evidence for meeting the mutagenicity
criteria of the Guidelines. In addition, the positive results
from the Salmonella assays and the human ceil study (both
submitted by this rebutter; see rebuttal comments 1 and 2)
further support the presumption of mutagenicity.
Since two different kinds of tests (Simmon and Poole, 1978;
Mitchell and Tajiri, 1978) showed positive results for mutageni-
city of coal tar/creosote solutions, the five additional LB1
studies showing negative results, although adding to the
Agency's data base, do not rebut the presumption of mutagenicity
in PD-1.
Rebuttal Comment 4; Bacterial Ceil Membrane Uptake of
Creosote (2)
The American Wood Preservers Institute asserts that the
Salmonella strains used by Simmon and Poole (1978) are inappro-
priate for mutagenicity testing. This is because the cell
membranes of these strains have a specific "defect" allowing
31
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greater uptake ot polycyclic aromatic hydrocarbons (PAH's) than
other cell membranes.
Agency Response: The Agency agrees with the rebutter that the
Salmonella strains used in the Ames assay have an increased
permeability toward the large heterocyclic molecules. These
strains are used intentionally to mimic the permeability ol
mammalian ceils as much as possible. This is also true for the
Bacillus subtilis strain (used by LBi), which may have a
permeability to heterocyclic compounds greater than that of the
— typhirourium strain used by Simmon and Poole. The Agency
concludes that the Salmonella strains used by Simmon and Poole
are appropriate for mutagenicity testing.
Rebuttal Comment 5; Appropriateness ot Rodent Liver
Homogenates for Activating creosote
Mixtures (2)
The American Wood Preservers Institute states that rodent liver
enzymes are inappropriate for activating creosote mixtures prior
to the Ames Salmonella test. The metabolic activity in rodent
liver is much greater than that in either human skin tissue or
human liver. The rebutter also points out that qualitative, as
well as quantitative, differences exist between rodents and
humans with regard to the metabolic pattern of polycyciic
aromatic hydrocarbons (PAH's). Consequently, as specific
metabolites of PAH's may be the actual mutagens, a PAH may
32
-------
produce mutagenicity in one species (e.g., rodents) and not in
another (e.g., humans).
Agency Response; The Agency agrees that there are some
qualitative and quantitative differences in enzymatic activity
between rodent liver preparations used in the S_^ typhimurium
mutagenicity assays and preparations from human liver or skin
tissue. However, the bacterial mutagenicity assay is commonly
used by scientists as a primary screening test for chemicals
which have mutagenic potential. A positive result in these
bacterial mutagenicity assays, although not intended to be the
sole basis from which an extrapolation is made to a more complex
biological endpoint (e.g., human mutagenicity), does indicate,
however, that the presumption of mutagenicity for creosote and
coal tar/creosote is not rebutted.
Rebuttal Comment 6; Extrapolation from In Vitro Experiments
to Human Mutagenicity (2)
The American Wood Preservers Insititute points out that complex
factors limit extrapolation from in vitro mutagenicity
experiments to in vivo human mutagenicity.
Agency Response: The Agency agrees that it is difficult to
extrapolate from in vitro mutagenicity to _in vivo human mutageni-
city. however, as discussed above (rebuttal comment 5), i_n
vitro experiments like those of Simmon and Pooie (1978) are
intended to provide a rapid screening device for substances that
33
-------
have a potential human mutagenic effect. The results of the
b_. typhimurium assay are used in this document merely for
qualitative purposes.
Rebuttal Comment 7; Potential for Nonsomatic Cell Mutations (2)
The American Wood Preservers Institute states that although
bacterial mutagenicity assays may be relevant to skin tumors,
the potential for nonsomatic (germ) cell mutations is slight,
since these cells are distant trom the site of contact with
creosote and the creosote is not likely to be systemically
distributed throughout the body.
Agency Response; The Agency rejects the assumption that
creosote is not likely to be systemically distributed throughout
the body. Studies performed by Ames e_t al. (1973) showed that
when certain compounds are applied to the scalp of humans, they
are ultimately found in the urine. Therefore, some compounds
entering by dermal and/or inhalation routes may not necessarily
stay at the site of contact but may be carried by the blood to
other parts o£ the body. Vvhether this fails to occur with
creosote can only be determined by experiments.
c. Summary of Rebuttal Comments Concerning Mutagenic
Effects: Conclusion
The rebuttal comments do not invalidate the studies of Simmon
and Poole (1978) or Mitchell and Ta^iri (1978) as multitest
34
-------
evidence for mutagenicity. The presumption ot mutagenicity tor
creosote and coal tar/creosote, as stated in PD-i, is not
rebutted but is actually strengthened by the additional LB1
studies provided by the American Wood Preservers Institute.
35
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2. Analysis of Rebuttal Comments Concerning Oncogenicity
a. Basis of Presumption
i. Creosote
Dermal application of creosote has also been shovvn to produce
skin tumors in mice (see Table ll.B-1). Roe £jt ai. (1958), for
example, found that dermal application of creosote to mice also
produced lung tumors. Boutwell and Bosch (1958) found that
creosote had the ability to initiate tumor formation when
applied for a limited period prior to treatment with the
promoter croton oil. Sail and Shear (1940) showed that the
number of skin tumors following dermal treatment with creosote
and benzo(a)pyrene was greater than that produced by
benzo(ajpyrene or creosote alone.
It has also been reported that various kinds of workers
occupationally exposed to creosote developed skin tumors (Henry,
1947; Lenson, 1956; O'Donovan, 1920; Cookson, 1924).
ii. Coal Tar
Many studies have shown coal tar to be oncogenic in laboratory
animals. For example, dermal application of coal tar produced
skin tumors in mice (Horton, 1961; Shabad e_t cil., 1971; Watson
and Melianby, 1930; Tsuitsui, 1918; Hueper and Payne, i960;
Deelman, 1962; Bonser and Manch, 1932; Gorski, 1959; Kennaway,
36
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biiambaugh
Mauro
Hosnanith
1935
lybl
1953
TABLL ll.B-1
UF COAL TAR NfcllTRAL OIL STUDIES
OUriL T'AK
human Case Reports
Authors
Substance
arid Type
Year ot Exposure
Occupation
oi txposed
Individual
'iype oL lumor
Response
Coal tar on Fishermen - Net
repair needle lott Vvorkers
held between
lips
handling ot
Goal lar
Pitch
riar distillery
tot
l
-------
TABLE Il.B-i (Continued)
COAL TAR
Animal Studies
Authors
Dermal Exposure
Substance Animal &
Year Tested Strain
Type ot Tumor
tesporise
Yamagiwa 1915
tt Ichikawa
Tsuitsui
191b
Goal tar
Bituninous
coal tar
tabbits (Strain
undefined)
Mice - English
Rjpilianas ot the
ear (site ot
aplication)
Bapillanas,
carcinomas and spin-
dle cell sarcoma
Kennaway 1925 Coal tar pro- Mice (Strain
ducts ot Undetmed)
450 C,
5bO C, &
1,250 C
distilla-
tion temperature
Stein tunors (higher
rate of carcino-
genesis at higher
temperatures)
38
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TABLE 1I.B-1 (Continued)
COAL TAR
Animal Studies
Dermal Exposure
(continued)
Authors
Year
Substance
lested
Animal &
Strain
Type of Tumor
Response
Watson & 1930 Dermal Appli-
Mellanby cation ot
coal tar
following
dermal
application
of fats,
oils, or
tannic acid
Goal tar
dermal appli-
cation com-
bined with
addition of
butter to
diet
itonser & 1932 Scottish
Manch blast
furnace tar;
tnglisn crude
tar
Mice (Strain
Undefined)
Mice (Strain
Undefined)
Mice (Strain
Ihdetined
Increased tumor
production
Higher incidence of
lung nodules
Papillomas
squamous ceil
carcinomas ot
the skin
GorsKi
Hueper
fcyne
Norton
1959
1961)
1961
Deeiman
Shabad
et ai.
1962
1971
Mice
(tin Strain)
Mice - ElacK
(CSV Strain)
Goal tar
tar
tars,
coal tar mix- (CJM Strain)
ture, benzo(a)
pyrene mixture
(joai tar dis- Mice
tillates (C3M Strain)
Coal
Tar
Coal tar
ointments
Mice (Strain
Undefined)
Mice (C57 CBA
Ifybrid Strain)
SKin tumors (some
malignant)
Skin Cdrcinanas
Skin tutors in 75%
ot eacli group of
animals
Skin tumors
Skin carcinomas
and papillcmas
SKin tumors
39
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TAbLL il.B-1 (Gontinued)
GOAL TAR
Animal Studies
Inhalation Exposure
Authors
Year
Substance
Tested
Strain
'iype ot 'lumor
Response
borton
Horton
et al.
1963
lye &
Stammer
Kinkead;
McGonnell
tc Specht;
MacLwen &
ternot
MaciJ^en
Vernot;
MacEWen
et ai.
1967
1972-
1974
1976
(JOcd tar tunes Mice (CJM
preceedecl by btfain)
inhalation ot
formaldehyde;
coal tar tunes
Ooal tar
aerosol;
Goal tar
aerosol &
gaseous
tormalaehyde
Goal tar;
coal tar
l* phenolic
i< non-pheno-
lic tractions
of coal tar;
non-pi ienol ic
tractions ot
coal tar
*'ierosoiized
coal tar -
light oil &
solid frac-
tion removed
Aerosolized
Goal tar
f-ace (G3h
Strain)
Mice (C3H/HeJ
Strain)
Mice (1CR-CF1)
Mice (JAX—CAF1)
Weanling rats
(bprague-Davley)
Yearling rats
(Sprague-Lfevvley)
Hamsters
(Syrian golden)
Rabbits (New
Zealand white)
Mice (1GR-GF1)
Mice (JAX-CAFi)
Rats (Sprague-
Dewley)
Rabbits (Nfew
Zealand albino)
Monxeys (Macaca
Muliata)
both groups developed
Proiiterative
alveolar neopiasia;
one mouse (group
unspecified) ue-
veloped a squamous
ceil carcinoma
Both groups
developed squamous
cell tunors of lung
and lung adenomas
Adenomas &
carcinomas of the
lung
Mice developed skin
tunors due to
aerosolized
material deposited
on skin; lumor
response was not
reported for
rabbits,
hamsters, or rats
Mice - Alveolargenic
carcinoma and skin
tumors; Rats -
Squamous cell car-
cinomas; No tumor
response was
reported lor rabbits
or monxeys.
40
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TABLE 1I.B-1 (Continued;
CREOSOTE
Human Case Reports
Authors
Mackenzie
u ' Donovan
Ccokson
Year
1896
1920
1924
Substance
and Type
of Exposure
Handling ot
Creosote
Handling
of Creosote
Handling of
Creosote
Occupation
ot Exposed
Individ uai(s)
Vorker who dipped
railway ties in
creosote
Workers who creo-
soted timbers
Creosote factory
worker
Type of Tumor
Response
Vnarty elevation on
arms; Eapillmatous
swellings on scrotun
Skin cancer
Squamous epithelio-
mata on hand;
Henry
Dsnson
1947 Handling of
Creosote
1956 i&inting of
Creosote
37 men of various
occupations
i&ipyard worker
epithelionatous
deposits in liver,
lungs, kidneys and
hearv walls
Cutaneous epithelio-
mata
Malignant cutaneous
tunors of the face
41
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TABLE li.B-1 (Continued)
CKEGSOTL
Animal Studies
Derinai Exposure
Authors
Year
Substance
'ic-steu
Animal
Strain
lype 01 'iumor
tesponse
bail
Shear
Creosote i<
benzio(a)
(Strain A)
Accelerated tunor
ronnation
V\oodliouse
Li]insKy
et ai.
Creosote on
#1 creosote
oil
Mice (/iibino;
Lhdetined strain
- Svviss
Papiiiomas &
carcinomas
Bapiliomas ii
carcincmas
42
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TABLE 1I.B-1 (Continued)
CREOSOTE
Animal Studies
Dermal Exposure
(continued)
Author
Poei. &
Rammer
Boutweil
& bosch
toe
et al.
Substance
Year Tested
1957 Blended
creosote
oils;
Light
creosote
oil
1958 Creosote
(Carbasota)
1958 Creosote oil
( Carbasota)
Animal i»
Strain
Mice (C57L
Strain)
fuce (C57L
Strain)
Mice (Albino -
random bred)
Mice (Strain
Undelined)
Type of Timor
ffcsponse
Papilianas &
carcinomas
metastatic growths
in lungs ana lyuph
nodes
Bapiilanas
Papiiictnas <*
carconcmas
Skin & lung
tumors
43
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TABLE Il.B-l (Continued)
GOAL TAR NEUTRAL OIL
Animal Studies
Dermal Exposure
Authors
Year
Substance
Tested
Animal &
Strain
Type of lumor
Response
Cabot
et al.
1940
Berenblum
i« bchoental
Benzene Mice - albino
Solution "market" mice
of neutral oil
& btnzD(a)
pyrene
5 Coal tar
neutral on
fractions
Mice (Strain
Undefined)
Rabbits (Strains
Undefined)
Inhibitory effect of
tumor response as
compared to tumor
response v*ith benao
(a)pyrene (effect
credited to skin
damage)
All fractions but
oncogenic
Ail tractions but
one v«re oncogenic
Morton
p'l'ABc2
1961 Coal tar Mice (Strain
neutral oils Undciined)
(maleic anhy-
dride extracts)
Produced tumors in
34.1 ana 32.1 weeKs
44
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1925) and rabbits (Yamagiwa and Ichikawa, 1915). Exposure to
coal tar via inhalation produced lung tumors in mice (horton,
1961; MacEwen et jal. , 1976; Horton et _al. , 1963; Tye and
Stemmer, 1967) and fats (MacEwen et £l., 1976). Exposure of
mice to coal tar aerosol also produced sKin tumors (McConneli
and Specht, 1973; MdcEwen et jJl., 1976).
Dose-response relationships for oncogenicity have been found
several times [e.g., skin tumors in mice following dermal
(Horton, 1961) or inhalation (McConneli and bpecht, 1973;
MacEwen and Vernot, 1976) exposure]. Horton (1961) and
McConneli and Specht (1973) also found a aose-response
relationship for the latency period (time until diagnosis of
tumors).
Skin cancer has also been reported in fishermen and others
involved with the repairing and retarring of fishing nets
(Shambaugh, 1935)/ coal tar distillary workers (Mauro, (1951),
and a coal tar barrel filler (Rosmanith, 1953).
iii. Coal Tar Neutral Oil
As with creosote and coal tar, dermal application of coal tar
neutral oil has been shown to produce skin tumors in mice
(Horton, 1961). Berenblum and bchoenthal (1947) found that
several chromatographic fractions of coal tar neutral oil
produced skin tumors when dermaliy applied to mice. Cabot et
al. (1940) found that mixtures of coal tar neutral oil with
45
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benzo(a)pyrene produced fewer tumors than benzo(a)pyrene alone,
but suggested that this inhibiting effect was due to skin damage.
b. Analysis of Specific Rebuttal Comments
Rebuttal Comment 1; Reliability of Old Case Reports of Skin
Cancer (2)
The American Wood Preservers Institute asserts that the case
reports of skin cancer from occupational exposure to creosote
are not sufficient evidence that creosote causes skin cancer in
modern treatment plant workers. This is because many of these
exposures occurred before World War II, before "current hygienic
practices and safety precautions" were in effect. Furthermore,
the rebutter states that the reports are anecdotal in nature and
do not contain enough details to rule out other common causes of
skin cancer.
Agency Response; As with case reports in general, it is
difficult to rule out entirely a role in these skin cancer cases
for factors other than creosote. The Agency believes, however,
that the early case reports suggest creosote has the capability
of causing skin cancers. Although not providing direct evidence
tor a cause-eifect relationship, these studies do provide
supporting evidence for the Agency's concern that long-term
exposure to creosote may pose a skin cancer hazard. The studies
also complement the numerous laboratory animal studies showing
creosote to be an oncogen (see Table 1I.B-1).
46
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The rebutters present neither firm evidence that the current
formulations ot creosote are safer than the formulations used
before World har 11 nor evidence as to the extent or effective-
ness ot "current hygienic practices and safety precautions."
Rebuttal Comment 2: Small Number ot U.S. Case Reports (149)
Allied Chemical Corporation questioned the skin cancer hazard
from creosote manufactured and used in the United States. The
rebutter points out that, of the mere eight reports of skin
cancer among exposed workers cited in PD-1, only two were from
the United States. One of these reports concerns an individual
who was a painter for 41 years prior to a 3-year job working
with creosote. The other report deals with a fisherman working
with tarred nets. The rebutter states that exposures to paint
solvents could have caused the face cancer of the painter, and
that exposure to tarred fishing nets is not relevant to the use
of creosote as a wood preservative. The rebutter recognizes,
however, that most experts agree that long-term dermal exposures
to high levels of creosote poses a possible skin cancer hazard.
The rebutter presented a new survey of Allied plant workers
documenting skin lesions that these workers had incurred. The
dermatologists questioned in the survey concluded that proper
personal hygiene and periodic medical surveillance would prevent
serious skin diseases.
Agency Response: Although the rebutter provides no evidence
showing that paint solvents may have contributed to the cause of
47
-------
the painter's cancer, the Agency acknowledges the possibility
that such may have been the case. Similarly, although the
rebutter has submitted no data,the tar used for the fishing nets
may indeed be qualitatively different from that used for wood
preservation.
Still, the basis for the Agency's concern is not limited to the
eight human case reports cited in PD-1, but also includes the 21
animal studies on coal tar and creosote (see Table 1I.B-1). The
Agency agrees with the rebutter that creosote exposure, if
continued for a long duration at high levels, constitutes a skin
cancer hazard.
Rebuttal Comment 3; Reliability of Henry, 1947 (143)
West European Tar Industries criticizes the case report study of
Henry (1947) which reviewed 3,753 cases of cutaneous epithelio-
mata. The rebutter points out that NIOSH discounted this paper
because Henry "did not describe the bases for his conclusions."
Agency Response: The Agency agrees with NIOSH and the rebut-
ters that the lack of certain information in Henry's report,
such as the number of workers exposed to creosote, makes it
difficult to quantify the relationship between exposure and
cutaneous cancer. However, Henry's paper does provide strong
evidence that the site of cutaneous cancer was associated with
the nature of a worker's occupation, thereby supporting the
occupational basis of these cancers.
48
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Rebuttal Comment 4: Health Records of Creosote-Exposed
Workers (151, 193)
The Association of American Railroads submitted a summary of a
4-year study which reported 971 dermatitis or burn cases caused
by creosote in railroad workers. The rebutter also summarized
the health records of about 90 workers in two railroad tie
treating plants. These records cover a period of about 30
years. The rebutter believes that, although workers exposed to
creosote may develop "initiative dermatitis" or "transient eye
involvement," the studies provide no evidence of an increased
incidence of creosote-related skin cancer.
In another rebuttal comment, bamuei Cabot, Inc. states that,
follovvirig a review of that company's employee tiles, no "report
of any critical or permanent illness linked to employee exposure
to creosote" was found.
Agency Response: The summary reports submitted by the
rebutters do not indicate that the studies were specifically
designed to detect an increased incidence of skin cancer. For
example, they do not provide mortality, morbidity, or exposure
data .
Also, it appears that the studies consist of an examination of
voluntary reports of individuals' medical complaints rather than
systematic surveillance of skin diseases possibly related to
creosote exposure. Iherefore, the information provided by the
49
-------
rebutters is not definitive evidence that creosote is not
associated with induction ot skin cancer.
Rebuttal Comment 5: New Epidemiology Studies (1)
Koppers Company submitted three studies in support ot their
conclusion that workers exposed to creosote are not subject to
an excess risk ot cancer. Two of the studies are epidemiolo-
gicai (proportional mortality), and the third is a summary OL
workers' health examinations.
Agency Response; The Agency does not believe these studies
either support or refute the rebutter's conclusion. The studies
are deficient because in each one a biasing factor exists due to
the method of selection of deaths. For example, it appears that
individuals who spent a period of years working for Koppers and
then left for other employment prior to retirement were not
counted. The Agency assumes that the data included only indi-
viduals who died while employed by Koppers or after retirement
from Koppers. Individuals who left the company because of
illness, and later died from such illness, may not have been
included in the data. The Agency concludes that, as these
studies did not have the proper controls that should be present
in good epidemiological investigations, the studies are incom-
plete and inconclusive.
50
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The third study is merely a summary of healthy workers' health
examinations. Much follow-up work is required before this
information can be of use in detecting serious diseases.
Rebuttal Comment b; Metabolism of Creosote Components (149)
Allied Chemical Corporation states that the polycyclic aromatic
hydrocarbons (PAH's) contained in creosote are metabolized and
excreted in mammals, implying that these biological functions
automatically reduce or eliminate the oncogenicity of these
compounds.
Agency Response; While it is true that mammals do metabolize
both oncogenic and nononcogenic PAH's, it is not true that all
the metabolites of these compounds are innocuous. Some PAH's
are metabolized to active oncogens regardless of the route of
administration or dose level (Dipple, 1976). Also, it remains
possible that some oncogenic PAH's exert their biological
influence before they can be metabolized completely. Thus,
PAH's may pose an oncogenic risk to exposed humans.
Rebuttal Comment 7; "Anticarcinogenic" Activity of Creosote
Components (2)
The American Wood Preservers Institute states that creosote
solutions contain "anticarcinogenic" substances as well as
suspected oncogens. The rebutter suggests that the consequence
51
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of this may be that the potential for any oncogenicity, due to
the presence of "well-established carcinogens," is cancelled out.
Agency Response; The Agency is not aware ot any evidence that
the presence of "anticarcinogenic" substances in creosote
solutions counteracts the oncogenic components. Although
creosote may contain some inhibitory compounds, it also clearly
contains both carcinogenic initiators and promoters, as well as
complete carcinogens. Also, numerous laboratory animal studies
cited in PD-1 adequately demonstrate that whole creosote is
oncogenic (see Table Il.B-i).
Rebuttal Comment 8; Dermal Application of Coal Tar
Kedicinals (191)
The Joint Industry Coal Tar Committee cited the testimony of
P.E. Weary and E.M. Farber before the Food and Drug Adminis-
tration's Antimicrobial Panel II (DHEW, 1977) as evidence that
even coal tar medicinals, which are applied directly to the
sKin, do not cause skin cancer. Dr. Weary concluded (page 11 of
the DHEW document) that in his 21 years ot dermatologic practice,
he had found no solid evidence that coal tar products cause skin
cancer. Dr. Farber sent questionnaires to 91 physicians who had
been using these products for at least 30 years. Again, there
was no indication that these products caused any skin cancers
(page 300 of the DHEW document) .
52
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Agency Response; Although testimony of this type is informa-
tive, these comments do not rebut the oncogenicity presumption
for creosote. In the same symposium transcript (pp. 181-4) it
was concluded that coal tar medicinals contain at least four
agents that cause tumors in laboratory animals: benzo(a)pyrene,
beta-naphthalamine, o-toluidine, and guinoiine. Also, Dr.
Hoffman points out (page 184) chat a review of the literature in
1966 (Greither e_t al., 1966) revealed that "thirteen cases of
skin cancer were reported in patients who used coal tar prepara-
tions. Of these cases two were also treated with arsenicals."
In conclusion, the Agency is unaware of any adequate long-term
studies to characterize the oncogenic effects of the use of coal
tar medicinals in the induction of skin cancer.
Rebuttal Comment 9; Reliability of Mouse Skin-Painting
Studies (19J)
Samuel Cabot, Inc. attacks the utility of mouse skin-painting
studies as a reliable basis of establishing the oncogenicity of
creosote. In the opinion of this rebutter, the studies lack
adequate controls, detailed information on dose levels, route of
administration, sex, strain and species of test animals, and
experimental design. Weisburger (1975) is cited in support of
invalidation of these earlier studies.
Agency Response; The Agency agrees that two of the six
studies had no controls. Nevertheless, the consistent positive
53
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response in these studies cannot be ignored. Older studies
cannot automatically be invalidated due to lack of conformity
to present-day protocols. Also, Dr. Weisburger's article merely
listed several variables which affect the carcinogenic response
in animal experiments. The mere listing of these variables does
not invalidate these specific studies.
Rebuttal Comment 10; Reliability of Horton e_t al. / 1963 (149)
Allied Chemical Corporation suggests that the positive oncogenic
response found by Horton et al. (1963) with coal tar aerosols
may have been due to aggravation by the formaldehyde carrier.
Agency Response; The positive oncogenic response in the mouse
study with coal tar aerosols is not explained by the effect of
formaldehyde because the group treated with coal tar alone gave
a greater response than the group treated with coal tar plus
formaldehyde.
Rebuttal Comment 11; Inappropriateness of Rodents as Models
for Oncogenicity (2)
The American Vvood Preservers Institute questioned the relia-
bility of rodent species as models for oncogenicity in man. The
rebutter states that these species are inappropriate due to
major differences in the metabolic, pharmacokinetic, and biochem-
ical characteristics of rodents and man.
54
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Agency Response; The Agency finds no merit in the rebutter's
comment. It is accepted Agency policy to rely on the results of
ctnimal studies to demonstrate the oncogenic potential of a
chemical agent. This policy, as stated in the Interim Cancer
Guidelines (FR 41:21402-21405, May 25, 1976), is that "a sub-
stance will be considered a presumptive cancer risk when it
causes a statistically significant excess incidence of benign or
malignant tumors in humans or animals."
The scientific rationale for using animal studies for this
purpose is multifaceted. First, very few industrial chemicals
and processes have been subjected to adequate epidemiological
studies to determine whether or not they cause carcinogenic
effects in workers. Second, epidemiological studies are insen-
sitive and little weight can be placed on surveys which do not
show positive results. Third, many industrial chemicals have
not been in production long enough for any effects to be
observable, bearing in mind the long latent periods for chemi-
cally-induced cancers. Fourth, it would be unethical to wait
for evidence of harm in exposed workers when risks can be
established relatively quickly by animal experimentation.
A risk assessment which relies solely on animal data would be
less reliable for humans in a situation where definite metabolic
pathway differences can be shown between animals and humans.
Since the rebutter presented no clearcut evidence of such
differences for the metabolism of creosote, there is no basis
for qualifying the risk assessment oa metabolic grounds.
55
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Rebuttal Comment 12; Lack of Oncogenic Response to
Benzo(a)pyrene (193)
Samuel Cabot, Inc. cites Dr. Weisburger (1975), pointing out
that after 8 to 10 years of skin applications to primates of
some known oncogens, including benzo(a)pyrene, no tumors were
observed. The rebutter submits this as evidence that creosote
is not oncogenic.
Agency Response; The major purpose of this section of
Dr. Vveisburger1 s article was to show the inter-species variation
in response to oncogens, and not to demonstrate that
benzo(a)pyrene is nononcogenic. Moreover, on page 279 (Table
8.4) of her article, Dr. Weisburger lists both coal tar and
creosote as human oncogens.
c. Summary of Rebuttal Comments Concerning Oncogenic Effects:
Conclusion
The rebutters have presented no substantial information which
shows that creosote does not pose an oncogenic risk to humans.
Abundant data from animal experiments (Table 1I.B-1) show that
creosote induces squamous-cell carcinomas and papillomas of the
skin, and adenomas and carcinomas of the lung. These positive
results in laboratory animals are supported by the numerous case
reports of skin cancer in people heavily exposed to creosote.
Thus, the original conclusions presented in PD-1 are still
56
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valid, and the presumption of oncogenicity for creosote is not
rebutted.
57
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3. Analysis ot Rebuttal Comments Concerning Human Exposure
Rebuttal Comment 1; Composition of Coal Tar and Its Effects
on Carcinogenicity (2)
The American Wood Preservers Institute states that the composi-
tion of creosote produced and used in the U.S. today may be
qualitatively different from the test substances used in the
laboratory animal cancer studies cited in PD-1. The rebutter
points out that, although the chemical characteristics of these
test substances were not described in the studies, a number of
the studies were conducted many years ago and/or in foreign
countries where creosote production methods differ from the
methods used in this country. The rebutter believes, therefore,
that these studies are not relevant to the potential
oncogenicity of creosote produced in the U.S.
Agency Response; As discussed earlier (see Section I.C.I.a),
coal tar and creosote are complex mixtures containing hundreds
of identifiable constituents. The duration, temperature, and
nature of the coking operation are likely to have an effect on
the products formed, particularly during secondary reactions.
For example, the higher the temperature during coking (and the
longer the duration of coking), the more complete will be the
formation of secondary products such as polynuclear aromatic
hydrocarbons (PAH's). PAH's are fused ring compounds, some of
vhich have been identified as oncogens.
58
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While the Agency agrees that the various constituents of
creosote derived from different sources and methods may differ
in their quantitative distribution, the classes of chemicals
(including PAH's) will be basically the same in the different
batches of creosote (McNeil, 1952).
Rebuttal Comment 2; Relationship of Animal Inhalation Studies
to Wood Preservative Plant Workers (2)
The American Wood Preservers Institute points out that aeroso-
lized coal tar was used in the laboratory animal inhalation
studies cited in PD-1. The rebutter believes these studies are
not relevant to the evaluation of oncogenic risk to workers
exposed to creosote vapors at wood-treating plants. This is
because aerosolized coal tar contains greater concentrations of
4- and 5-ring PAH's than creosote vapors at these plants.
The rebutter believes that treatment plant workers are exposed
to only "low" levels of benzene-soluble polycyclic parti-culate
organic matter (PPOM). In the opinion of the rebutter, the
organic matter that workers are primarily exposed to is in the
vapor phase, and this fraction contains, according to tht:
rebutter, only lower molecular weight, nononcogenic compounds.
In support of this position, the rebutter submitted the results
ot air monitoring studies conducted at several Koppers and Kerr-
McGee plants. Some of the data from these experiments are
presented in Tables 1I.B-2 and II.B-3.
59
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TABLE Il.B-2
Exposure of Switchman in a Creosote Plant Showing
GC Analysis of Vapors and Filterable Matter
Air Emissions (mg/m )
Benzene0
Toluene
Xylenes/ Ethyl benzene
Napthaiene
Me thylanaphthalenes
Dimethylnaphtaienes
Acenaphthene
Dibenzof uran
Fluorene
Phenanthrene/
Anthracene
Fluoranthene
Pyrene
Unknown 1
Unknown 2
Benzo( a)pyrene
1,2- and/ or
2, 3-Benzof luorene
Benz( a) anthracene
Chrysene
Benzo( k) f luoranthene
3, 4-Benzof 1 uoranthene
Perylene
1,2,3,4- and/or 1,2,5,
Dibenzanthracene
1,12-Benzoperylene
Benzene-Soluble
Particulate
Total Particulate
No.
Rings
1
1
1
2
2
2
3
3
3
3
4
4
-
—
5
4
4
4
5
5
5
6-
5
6
Collected
in Carbon1*
0.012
0.032
6.3
0.47
0.037
<0.01
0.036
<0.01
<0.01
<0.01
— ~_ _
—
Collected,
on Filter
_. _ _
0.0007
0.0008
0.004
0.02
0.001
0.001
0.005
0.002
<0.0003
<0.0003
<0.0003
<0.0003
<0.0003
<0.0003
<0.0003
<0.0003
<0.0003
o.iod
0.21d
a. Based on Sample 4054-180-3A.
b. Based on Sample 4054-181-4, taken on
freshly pulled
tram Cars at
various intervals, 8/16/78 thru 8/18/78, th,en propritioned on the
basis of benzene solubles to the 0.10 mg/M level reported.
These constituents are found in the vapor drying solvent and are
not present in creosote/coal tar solutions.
60
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TABLE II.B-3
Vapor Phase Exposure to Wood Preservative Plant Workers
Operator/Job
Category
Concentration in^Breathing Zone
Number of (mg/m )
Samples naphtha-methylnaphth-acenaph-
Taken lene alene thene
Personal Samples
switchman
test borer
load out man
doorman
treating operator
locomotive opera-
tor
treating engineer
clean up man
Area Samples
doorman platform
dehydrator
ave ranqe ave range
1.02 0.44- <0.1 0.4-
2.1 <0.2
0.97 0.23- 0.23 <0.2-
1.7 0.25
8.95 6.9- 0.99 <0.2-
11.0 1.77
ave range
0.07 0.02-
0.08 0.07-
1
3
1
2
1
1
1.5
1.4
2.2
3.7
1.3
0.6
-
0.92-
1.9
-
1.0-
6.3
-
_
0.32
<0.2 <0.2
0.24
<0.2 <0.2
<0.2
<0.2
0.11
<0.1
0.21
<0.1
<0.1
<0.1
42
4.1
0.31 <0.1-
0.52
1.6
a. Adapted from Koppers, 1978.
b. Samples were analyzed by GC-FID following collection on
charcoal. Only three constituents were identified. Note
particularly the relatively high exposure levels detected in
the area samples.
61
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Agency Response; bulticient data hctve not been collected to
categorically identify the specific constituents present in the
Dreathing zone ot treatment plant workers. The data presented
in 'rable II.B-2 is derived from one, unreplicated air sample
analyzed lor individual PAH compounds. it should be noted,
however, that both pyrene and f luorctnthene, found in the
worker's breathing zone, are 4-ring PAH's. Both 01 these
chemicals hctve boiling points close to 4UU°C. Also, the
presence or absence ot the known oncogen chrysene in the vapor
phase was not examined. in the earner study where specific
cnemicais were also analyzed (labie Il.B-j), the levels ot only
naphthalene, methyinaphthalene, and acenaphthene in the vapor
phase were determined.
Consequently, as both vapor phase and airborne particulate phase
material are present in the creosote workers' breathing zone,
these workers are exposed to some 4-ring PAH's, some of which
may be oncogenic, vie* inhalation. Additionally, the Agency is
concerned that no sampling studies have been reported in which
the vapor phase is analyzed fot lower boiling oncogenic amine
constituents ot creosote, such as toiuidines
-------
those pilings. The rebutter criticizes the Agency for not
considering the possibility that diesei motorboat engines may be
the source ot benzo(a)pyrene. The rebutter cites a National
Academy of Sciences report (NAS, 1972) showing Lhat two-cycle
engines burning an oil and fuel mixture in a ratio of l:jj may
emit as much as 11 mg of benzo(c)pyrene per gallon of fuel
consumed.
Agency Response; The Agency agrees with the rebutter that the
Dunn and Stich papers do not establish tnat creosote-treated
pilings are the source of the benzo(a)pyrene in the mussels.
Rebuttal Comment 4: Reliability of NIOSH, 1977 (14J)
West European Tar Industries criticizes the NIOSH (1977)
monitoring study, cited in PD-1, for using cellulose back-up
pads behind the sampling filter. The rebutter states that
contaminants from the cellulose pads interfere with proper
measurement of PPGM.
Agency Response; The Agency agrees that the results of the
NIOSH (1977) study are dubious due to possible contamination
from the cellulose pads. Consequently, this study will not be
used in the Exposure Analysis (Section II.B.4).
63
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4. Revised Human Exposure Analysis
a. Chemistry
As pointed out in Section I.C.I.a, coal tar is an extremely
complex mixture produced by coking, the high temperature
carbonization of coal. Creosote is a lower boiling distillate
of coal tar. Both mixtures vary in composition, depending on
the temperature of coking and the source of the coal used
(McNeil, 1952; Nestler, 1974). In distilling coal tar to form
creosote, the lower molecular weight compounds are concentra-
ted. The balance of polynuclear aromatic hydrocarbons (PAH's)
in creosote contain one to four rings, although larger PAH's
such as benzo[a]pyrene, benzo[j]fluoranthene, and benzanthracene
have also been positively identified (Lijinsky £t al., 1957).
Lorenz and Gjovik (1972) have identified the major constituents
in creosote. They found that 18 compounds (Table li.B-4)
accounted for about 75-85% of the total volatile creosote
material. They also found variation in the relative percentage
of individual components in different creosote samples. in
addition to aromatic hydrocarbons, creosote also contains
smaller amounts of phenolic constituents as well as nitrogen-,
oxygen-, cmd sulfur-containing heterocyclic ring systems and
aromatic amines.
64
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Component
TABLE II.B-4
Major Components of Creosote'
Approximate
Percentage
Boiling
Point (°C)
Naphthalene
2-Me thy 1 naphthalene
1-Methylnaphthalene
Biphenyl
Dime thylnaph thai enes
Acenaphthene
Dibenzof uran
Fluorene
Methylfluorenes
Phenanthrene
Anthracene
Carbazole
Methylphenanthrenes
Methyl anthracenes
Fluoranthene
Pyrene
Benzofluorenes
Chrysene
3.0
1.2
0.9
0.8
2.0
9.0
5.0
10.0
3.0
21.0
2.0
2.0
3.0
4.0
10.0
8.5
2.0
3.0
218
241.
244.
255.
268
279
287
293-
318
340
340
355
05
64
9
295
354-355
360
382
393
413
448
a. Adapted from Lorenz and Gjovik (1972)
65
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b. Description of Treatment Process
As will be discussed in greater detail in Part III, creosote and
blended creosote/coal tar solutions are applied to wood predomi-
nantly by the pressure treatment process. The entire treatment
system is closed and there is no need for direct worker contact
with the creosote. The material arrives by truck or rail and is
pumped into holding tanks where it is weighed. if the delivered
material is a creosote/coal tar solution, as in treatment of
railroad ties, the solution is premixed, so that no mixing or
manual transfer operations are required at the treatment plant.
After seasoning, the wood is placed on railway tram cars which
are then placed in the pressure chamber. The treatment chambers
vary in size but are generally 85 to 135 feet in length and 6 to
8 feet in diameter. The treatment process itself involves
pressurization ; thus, the chambers are airtight.
Ireatment times vary, but they generally range from 6 to 7 hours
for each charge of material. Following treatment, a vacuum is
generally applied to withdraw excess creosote. The chamber door
is then cracked open for about 15 minutes, while still under
vacuum, prior to withdrawal of the tram cars. The greatest
opportunity for worker exposure appears to occur during the
mechanical withdrawal of the tram cars from the chamber because
air and steam turbulence may result in suspension of particulate
and vaporized material when the cylinder door is opened. The
wood laden cars are coupled to an engine and withdrawn to a
storage area where the wood remains until shipment to the
66
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buyer. Dnppage ot creosote is collected in ditches along the
tracKS anu is pumped to a collecting pond along with creosote
that has arippea trom the pressure chambers at the time the
charge was removed.
Handling of treated wood is performed either mechanically or
with metai utensils, so that direct deimal exposure to the
treated wood is apparently minimal. bore samples ot treated
wood are taKen routinely to determine the extent ol creosott.
penetrotion into the wood. The number oL plant worKers
potentially exposed to creosote will vary Itom plant to plant,
depending on the number ol treatment chambers. The introduction
ot creosote into chambers is pertormed by treatment operators in
a control house near the chambers. The assistant treatment
operator is responsible for opening and closing the pressure
chamber door and otherwise assisting the treatment operator. No
direct contact with creosote treatment solution is necessary,
but in older laciiities leakage 01 creosote trom old pipes and
tittings combined with poor ventilation may result in relatively
high exposure to indoor operators. Roughly 4,000-5,000 workers
are involved in commercial pressure treatment with creosote
(USDA-States-EPA, 1980; McMillan, 1S76).
67
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c. Revised Human Exposure Analysis for Specific Exposure
Situations
i. Pressure Treatment
The bulk of the inhalation exposure data curently available for
creosote treatment workers was collected by a gravimetric
technique. This method involves the collection of suspended
particuiate matter (called polycyclic particulate organic
matter, or PPOM) from the air, extraction of the collected
material with benzene, evaporation of the solvent, and weighing
of the dried extract. The precision of this method has been
estimated at +_ 9%; the accuracy is low because of incomplete
extraction (Koppers, 1977). Insufficient data exist, however,
to properly evaluate the precision and accuracy of this method.
Most important, this method does not identify any constituents
of the airborne particulate fraction.
Potential inhalation exposure of creosote pressure treatment
workers has been measured at 11 commercial treatment plants
using this gravimetric method (Table Il.B-5). The overall
average benzene-soluble particulate air concentration is about
0.07 mg/m . The probable range of ambient air concentrations
of these particulates in these studies is 45 to 95 ug/m ,
since data from several sources indicate that the results of
benzene soluble PPOM analyses may have an uncertainty of as
great as 50% for samples containing 50 ug of material.
68
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TABLE 1I.B-5
Combined Results of Koppers/Kerr-McGee Monitoring Studies
a, b
Operator/Job
Category
Number of Concentration of Benzene-
Samples Soluble Particulates.,in
Taken Breathing Zone (mg/m )
Personal samples
locomotive operator 25
treating operator 44
switchman 35
tie load out 17
oil unloader 7
test borer 8
load out checker 1
crane crewman 5
oil handler 4
effluent man 3
tie roller 1
doorman 6
A & B operator 6
treating helper
A & B truck lift
operator 3
lift operator 1
A & D grapple 3
boiler fireman 4
locomotive helper 4
treating engineer 3
shipping supervisor 1
crane chainer 6
tie leveler 2
clean up 1
Totals 196
Treatment area samples
treated storage yard 2
storage tanks 1
fuel tank platform 1
doorman platform 2
dehydrator 1
Average
0.05
0.06
0.05
0.05
0.07
0.05
0.04
0.09
0.06
0.07
0.08
0.06
0.20
0.07
0.40
0.15
0.17
0.06
0.03
0.06
0.08
0.04
0.02
0.07
0.06
0.06
0.04
0.03
0.10
0.01-0.21
0.02-0.20
0.01-0.21
0.01-0.12
0.01-0.16
0.02-0.10
0.04
0.05-0.17
0.03-0.10
0.04-0.12
0.08
0.01-0.14
0.05-0.61
0.06-0.08
0.40
0.04-0.30
0.04-0.52
0.03-0.13
0.01-0.07
0.06
0.02-0.12
0.02-0.06
0.02
0.01-0.61
0.06
0.06
0.04
0.02-0.04
0.10
a. From AWPI (1979) and Koppers (1978)
b. Several outlyer samples were not included. These include one switchman
sample (suspected contamination) and one tie load out sample (possible
contamination). Samples were taken during day and night shifts over a
several year period at various wood preserving pressure treatment
plants. Analyses were performed by a non-specific gravimetric tech-
niques. Note that some operations involve relatively high levels of
exposure e.g. A & B operator, A & D grapple, lift operator, and boiler
fireman.
69
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buiticient uata are not available to identify specific consti-
tuents present in airborne participates in the breathing zone of
treatment plant workers. One study of exposure to creosote
using a 60/40 creosote/coal tar blend identified several parti-
cuiate phase consituents in a single, unreplicated sample (AWP1,
1980). rihe compounds were collected on a fiber glass and silver
membrane. The results of this study (Table li.B-2) are not
necessarily representative of the other workers at the same
plant or of other wood treatment plants. This area sample
contained naphthalene (0.47 mg/m ), methyl naphthalenes (0.037
nig/m"3), acenaphtherie (0.0007 mg/m ), dibenzoturan (0.0008
uig/m ), tiuorene (0.004 mg/m ), phenanthrene/anthracene
(0.02 mg/m ), tluoranthene (0.001 mg/m ), pyrene (0.001
mg/m ), and two unknowns (0.007 mg/m ). The remaining 0.10
mg/m of collected benzene-soluble particulates was not
characterized. it is important to note that tiouranthene ana
pyrene, two high boiling constituents of creosote/coal tar
(b.p. 3b2 , 3^3 C, respectively), were uetecteu and that
Denzo(a)pyrtne may be present at less than 0.3 ug/mJ (level of
detection). Creosote contains roughly 3.0 +_ 0.7% by weight
chrysene, a known carcinogen (Lorenz and Gjovik, Ib72). it
present, cnrysene Was below the limit or detection in the
particulate phase, as samplea by Hoppers. However, its presence
or absence in the vapor ph^se in the same study was not examined
Vapor phase material is not collected on the silver membrane or
glass fiber filters used in the gravimetric sampling mttnod. in
tne same Hoppers plant in an analysis 01 the vapor phase
70
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material collected in a charcoal tube, naphthalene (0.47 mg/m ),
methyinaphthalenes (0.037 mg/m ), and acenaphthene (0.036
mg/m ) were found (Koppers, 1980). In an earlier attempt to
measure several vapor phase constituents of creosote/coal tar in
pressure treatment plant worker breathing zones, exploratory
studies were performed by Koppers (AWPI, 1979) at two wood
preserving plant sites, Susquehanna and Little Rock. Analyses
were performed by temperature programmed gas chromatography-flame
ionization detection (GC-F1D) following collection with charcoal
tubes and desorption by carbon disulfide. Samples were analyzed
for naphthalene, methylnaphthalene, and acenaphthene. The results
of these analyses are given in Table II.B-3.
Table il.B-5 gives the average values and ranges of PPOM to
which workers are exposed in the course of routine operations.
Nonroutine operations, such as entering the treatment chamber
for cleaning, may occur several times yearly. Workers involved
in according to AWPI these latter operations are apparently
provided with suitable respirators and protective clothing, as
they probably have a greater than ordinary potential for
exposure to creosote.
Adequate vapor phase sampling has not been performed to date to
categorically rule out the presence of such PAH compounds as
benzo(a)pyrene, fluorene, phenanthrene/anthracene, flouranthene,
pyrene or other compounds which might occur at low concentra-
tions (ug/m range). Further, no sampling studies have been
reported in which the vapor phase is analyzed for oncogenic
71
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aromatic amine constituents of creosote such as toluidines ana
xyiidines. it is possible compounds of this type, which have
relatively low boiling points (Nestler, 1974), are present in
the air of creosote treatment plants. Additional studies using
sensitive and selective analytical methods would be required
before definitive conclusions could be drawn regarding the
presence of potentially oncogenic and mutagenic compounds in
worker breathing zones.
There is no quantitative information regarding potential dermal
exposure to creosote. That such exposure may indeed occur,
however, is evidenced by reports of sKin sehsitization ana
burns, conjunctivitis, and eye irritation (McMillan, 1976;
N1OSH, 1977; see also PD-1). In a study of rooters (N10SH,
1977), skin symptoms were observed on the forehead and face. In
some cases workers experienced burning sensations through their
shirts and gloves.
ii. Nonpressure Treatment
Commercial groundline treatment of creosote to poles already in
service is sometimes carried out to control fungal decay.
Approximately 300 people are involved in the application of
about 500 thousand pounds of creosote annually for ground!me
treatment (USDA-States-EPA, 1980). No exposure data are
available for this use.
72
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Noncommercial brush, dip, spray, and soak treatments using
creosote are carried out by homeowners, farmers, and iandscapers
for control of decay. Approximately 50,000 people apply about 2
million pounds of creosote annually (USDA-States-EPA, 1980).
Although no exposure data are available for this use, the Agency
expects that inexperienced persons using these over-the-counter
products have the potential, albeit intermittent, for greater
exposure to creosote and creosote vapors than do commercial
applicators.
iii. End Use
There exists no quantitative inhalation or dermal exposure data
for workers or members of the general population who install,
handle, or come into casual contact with creosote-treated wood.
The major end uses for this wood are railroad ties (USDA-States-
EPA, 1980).
These ties are generally mechanically installed and little
dermal contact is expected. The USDA-States-EPA assessment team
(1980) has made qualitative estimates of worker exposure resul-
ting from end use of creosote-treated wood. These estimates are
cited in Table 1I.B-6. Full discussion of end-use patterns is
found in the USDA-States-EPA report.
73
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5. Qualitative Risk Assessment lor hutagenicity
In bection il.B.I, uhe Agency summarized the stuaies citeu in
Pb-i on the potential mutagenicity of creosote ana creosote/coai
tar blends, ana analyzed the rebuttal comments concerning the
mut&genicity ot creosote and creosote/coai tar blenas. The
Agency concluded that the data presentea in PD-i demonstrated
that different creosote tractions have mutagenic activity for
several strains ol balmonellc typhimurium alter metabolic
activation (bimmon ana Poole, 197U). It vas also concludea that
creosote and creosote/coal tar bienas have mutagenic activity
tor mouse lymphoma cells following metabolic activation
(hiueheii ana Ta;jiri, 1978). btuaies submitted auring the
rebuttal phase ol the KPaK review showea that creosote gave
positive mutagenic responses in b^ typhimunum strains TA IbJV
and TA b>8 (see rebuttal comment 1, Section II.B.l.b). 'ihe
results of other experiments submitted by the rebutter (see
rebuttal comment 2, bection II.B.l.b) demonstrated that creosote
can give rise to unscheduled DNA synthesis in human hl-J&
ceils. Based on these results tor creosote, creosote/coai tar
blends, and particular chemical components ol creosote, the
agency concluded that the data base on mutagenicity met or
exceeded the mutagenicity risk criterion set forth in 40 CFR
162.11 (a) (j) ( ii) (A) .
As noted in bection 11.B.4, creosote is a complex mixture ot
organic chemicals; ot particular importance toxicoiogicaily are
the polynuclear aromatic hydrocarbons (PAH's), aromatic amines,
75
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d phenolic constituents. Different creosote samples can be
expected to contain varying proportions of these three and other
broad classes of chemicals (see Table 1I.B-7).
A qualitative case can be made tor dermal exposure to whole
creosote. however, workers inhaling airborne creosote may be
exposed to somewhat different proportions of creosote
components. The variable nature of the creosote to which
worKets are exposed and the qualitative nature of the exposure
iniormation available to the Agency does not permit the
development of a quantitative risk assessment for mutagenicity.
In addition, the mutagenicity results available Lor creosote and
its components are limited to _in vitro data which do not allow
the quantitative assessment of riSK (FR 45:221, Oct. 30, 1980).
Therefore, the Agency has proceeded on the basis of a qualita-
tive assessment ot mutagenic risk.
The Agency's proposed guidelines tor mutagenicity risk assess-
ments IFR 45:221, October 30, 1980) define a mutagen as "a
chemical substance or mixture of substances that can induce
alterations in the DNA of either somatic or germinal cells of
organisms." This section summarizes evidence for mutagenicity
of creosote and its chemical components and discusses the
implications ot these results for risk of intrinsic (somatic)
and heritable (germinal) mutagenicity.
As summarized above, creosote causes mutagenic effects in cell
cultures (e.g., bolmonella test systems, mouse lymphoma cells,
76
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'1AULL 11.13-7
Classification of Chemicals in Creosote
Compound
Effect
References
1. Unsubstitutea 6-membered aromatic ring systems (fused, unfused
or mixeu)
chrysene
pyrene
ben 20 [a] pyrene
be ii 20 [ a] anthracene
naphthalene
anthracene
acenuphthene
mutagenic
initiator
co-carcinogen
(with f Iuoraiithene)
mutagenic
mutagenic
carcinogenic
mutagenic
carcinogenic
inhibitor
mutagenic
mutagenic
a ,b ,c ,u ,e
i
t
D
ct ,b,c ,d ,n ,o
9
a,b,c
g/h
i
D
D
2. Unsubstituted aromacic ring systems containing 5-numbered rings
QIQ
n
tiouranthenc
benz[j]tluoranthene
co-carcinogenic
carcinogenic
t
g
77
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TAbLE 1I.B-7 (Continued)
3. heterocyclic Nitrogen bases
OJD
quinolinc
carcinoycriie
a
, i'e' inoy elii
i -methyl isoquinoiine:
3-methyl isoquinoiine
5-methyl quinoline
4-methyi quinoline
6-methyi quinoiine
5-methyl isoquinoiine
7 -methyl isoquinoiine
6-methyl isoquinoiine
1 , j-dimethyl isoquinoiine
ec,i:cinoycnie
4. heterocyclic Oxygen and Sulfur compounds
coumarone
thionaphthene
79
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TABLE II.B-7 (Continued)
5. Alkyl substituted compounds
methyl fluoranthene possibly carcinogenic d
1-methyl naphthalene inhibitor i
2-methyl naphthalene " "
ethyl naphthalene " "
2,6-dimethyl naphthalene " "
1,5-dimethyl naphthalene " "
2,3-dimethyl naphthalene accelerator "
2,3,5-trimethyl naphthalene inhibitor "
2,3,6-trimethyl naphthalene accelerator "
methyl.chrysene initiator p,q
6. Hydroxy compounds
phenol promoter f,m
p-cresol promoter m
o-cresol " "
m-cresol " "
80
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TABLE II.B-7 (Continued)
7. Aromatic amines
2-naphthylamine carcinogenic 1
p-toluidine " m
o-toluidine " "
2,4-xylidine " "
2,5-xylidine " "
8. Paraffins and naphthenes
-CH2- (n is large, e.g., greater than 15)
n
* Classes taken from McNeil (1952).
a. McCann e_t al. (1975)
b. Thilly and Liber (1979)
c. Nagao and Sugimura (1978)
d. Hollstein et al. (1979)
e. Sivak (1979)
f. Van Duuren (1976)
g. IARC (1973)
h. CAG (1978b)
i. Schmeltz e_t _al. (1978)
j. Epler et al. (1979)
k. Boutwell and Bosch (1959)
1. IARC (1974)
m. Weisburger et al. (1978)
n. Wyrobek and Bruce (1975)
o. Epstein et. al. (1972)
p. Van Duuren (1966)
q. Van Duuren and Goldschmidt (1976)
81
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ana human lung cells. rlhe conclusion that creosote is a poten-
tial human mutagen is further supported by data from the scienti-
fic literature. Some components of creosote give positive
results in the £_. typhimurium (Ames) test when assayed individ-
ually: anthracene (Epler ejt aJ.. , 1979), benzo la] pyrene (McCann
_et al., 1975; Thiliy e_t ^1., 1979; Hoilstein e_t _al., 1979;
Nagao and bugimura, 1978), chrysene (McCann e_t ^1., 1975;
'ihilly e_t _ai.., 1979; Nagao and Sug imura, 1978) acenaphthene
(Epler e_t ai., 1979), and benz[a] anthracene (McCann e_t al.,
1975, Thiliy e_t al., 1979; Nagao and Sugimura, 1978). Phenan-
threne, pyrene, naphthalene, and fluorene were negative in the
Ames test. However, pyrene was positive in the £>_. typhimurium
forward mutation system (Thiliy and Liber, 1979).
Cell culture test systems using host cells other than
b_^ typhimurium also lend credence to the finding that individual
creosote components have the capacity to induce damage to DNA.
Holistein ejt al. (1979) and Sivak (1979) demonstrated that the
following creosote components were positive in cell culture test
systems: benzo[a]pyrene (baby hamster kidney, mouse C3H 10T1/2,
mouse B/\LB 3T3, hamster lung V-79 cells, Syrian hamster embryo,
and rat embryo), benz[a]anthracene (virus-infected rat embryo,
byrian hamster embryo), chrysene (in vivo sister chromatid
exchange, hamster embryo, virus-infected rat embryo). Chrysene,
phenanthrene, and pyrene were not mutagenic for V-79 cells.
In a recent study, Mortelmans and Riccio (1980) used the E^ coll
WP2 system to test several coal tar products (e.g., flaked coal
82
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tar pitch and some components of coal tar epoxy) for mutageni-
city. Ail these products elicited a reproducible, dose-
dependent mutagenic response, but only in the presence of
metabolic activation.
The interactions in a mixture of different chemical mutagens may
be such as to potentiate, inhibit, or have no effect (depending
on the chemicals involved) on the mutagenic activity of the
mixture (Saffiotti e_t al., 1979a, 1979b; Schmeltz e_t al.,
1978; see also Section ll.B.6.b.v). In the case of creosote,
mutagenic potency is difficult to quantify in test systems due
to the complexity of this particular mixture of chemicals. Some
creosote components are mutagenic, while others are not; some
are also cytotoxic. A mixture of these chemicals will, in
addition to being cytotoxic, compete for metabolic processes.
This is particularly important in this instance since creosote
apparently requires metabolic activation for mutagenic activity
in test systems. Consequently, different batches of creosote
and creosote/coal tar blends may have different mutagenic
potencies.
In summary, direct evidence exists that creosote and many of its
component chemicals give positive test results in the Ames test.
Data from other in vivo mutagenic test systems for creosote and
its purified components support these positive results and the
presumption of somatic mutagenicity.
83
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Whether or not creosote actually reaches the germinal cells of
intact mammals is unknown to the Agency. The oniy evidence that
the Agency has that it does is restricted to benzola]pyrene.
Vvyrobek and Bruce (1975) lound that intrapentoneai injections
of benzol a]pyrene caused abnormalties in sperm morphology in
(C57BL x C3H)F, mice. Benzo[ajpyrene caused an excess
incidence of dominant lethal mutations in ICR/Ha Swiss mice
(Epstein e_t al., 1972). Although Kussell and Kusseii (liT/ti)
found benzo[a]pyrene to be negative for mutagenicity in the
mouse specific locus test, a positive response was obtained in
both the mouse dominant lethal test ana the X-chromosome loss
test. Positive results in either of these latter two tests
indicate heritable mutagenic effects. The Agency does not have
any evidence tnat the other constituents of creosote do not
reach the germinal cells.
In conclusion, the exposure data indicate that applicators of
creosote and creosote/coal tar wood preservatives are subject to
both dermal and inhalation exposure during the application
process and that other individuals who handle or come in contact
with creosote-treated products may likewise experience dermal
and inhalation exposure. About 4,500 workers are involved in
commercial pressure treatment with creosote. The Agency has
determined that the application of creosote wood preservatives
and the use of creosote-containing products poses a significant,
although currently unquantiflable,risk of mutagenicity to the
human population.
84
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6. Qualitative Risk Assessment for Oncogenicity
a. Introduction
Creosote and many of its component chemicals iiave been well
characterized as carcinogens in studies with laboratory animals
(see Table ll.B-1). These studies, along with the several
reports in the literature ot sKin cancer in people exposed to
creosote, suggest that creosote is a human carcinogen ( CAG,
1977), even though no wtil-cond ucted epidemiology studies ot
workers using creosote have been performed.
Although we know that whole creosote is « carcinogen, we have no
definitive data on the identity of airborne chemicals to which
worKers are exposed in wood treatment plants where creosote is
used. Moreover, despite the reports oi creosote burns in
worKers, we have no quantitative data on dermal exposure to
tnese workers. The laboratory Animal assays and the human case
studies substantiate the potential for oncogenic hazard to
worKers engaged in treating wood with creosote. however, the
IctCK 01 1) precise hum^n exposure data, ana 2) Knowledge of the
identity c*nd quantity of airborne chemicals preclude quantita-
tive assessment ot risK of carcinogenicity in humans.
Although creosote contains several known carcinogens, it also
contains an c^rray ol chemicals which may act cts initiators,
promoters, inhibitors, and co-earciriogens . These ctgents ail
afreet the carcinogenic potential ot creosote. Because of
85
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synergism among these components, the carcinogenic potency of
creosote cannot be predicted by assaying samples of the ntixtu:<
tor single carcinogenic components. Early attempts to correlate
carcinogenic potency with quantitative analytical determinations
of individual carcinogens in creosote (Lijinsky e_t _al., 1957)
and petrochemical fractions (Bingham e_t al., 1980) have been
unsuccessful. Therefore, this section will review the qualita-
tive evidence tor carcinogenic risk.
b. Chemical Composition of Creosote and Creosote/Coal Tar
Blends
As noted in Section II.B.4, creosote is a complex mixture
of organic chemicals produced as a by-product of coking. 'ihe
coke oven volatiles are condensed primarily as water and coal
tar, the latter a mixture of liquid and solid hydrocarbons.
Distillation separates creosote from coal tar.
i. Creosote
The chemicals comprising creosote have been characterized by
McNeil (1952) into eight classes. We present these classes here
because they are of interest toxicologically (Table 11.B.7).
Those derived from coal mined from different sources can vary in
the relative proportions of chemicals present. However, McNeil
emphasizes that all creosotes contain essentially the same
classes of chemical compounds, even while the proportion and
distribution of classes varies.
86
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ii. Coal Tar
As discussed in Section II.B.4, coal tar is often blended with
creosote for wood preservative processes. Coal tar comprises
the entire spectrum of non-aqueous coke oven volatiles. Because
the condensate extends to boiling regions higher than those of
the creosote fractions, coal tar contains a large number of 5-
and 6-ring polynuclear aromatic hydrocarbans (PAH's). The
carcinogenicity of many of these larger PAH's has been studied
and reviewed extensively (CAG, 1978b; IARC, 1973). Known PAH
carcinogens in coal tar are benzta]anthracene, benz[a]carbazole,
benzo[b]fluoranthene, benzoli]fluoranthene, benz[c]acridine,
benzola]pyrene, benzole]pyrene, chrysene, dibenz[a,i]anthracene,
dibenz[a,h]anthracene, dibenzo[a,h]pyrene, dibenzo[a,i]pyrene,
and indeno[l,2,3-cd]pyrene.
c. Toxicology
Creosote, coal tar, and many of the individual chemicals
comprising these mixtures have been subjected to animal carcino-
genesis assays and short term mutagenesis assays in the labora-
tory. In addition, because of the presence of co-carcinogens as
well as individual carcinogens in creosote and coal tar, these
mixtures have been examined for synergism among their components
(Schmeltz e_t aj.., 1978; Van Duuren, 1966). Van Duuren (1966)
reviews the phenomena of two-stage carcinogenesis and co-carcino-
genesis in animals and humans. The carcinogenicity of creosote,
87
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coal tar, and certain of their component chemicals has been
reviewed by the 1ARC (1973) and EPA (CAG 1977, 1978a, 1978b).
i. Creosote
Ihe CAG report (1977) summarizes several mouse skin painting
studies (Woodhouse, 1950; Poel and Kramer, 1957; Li]inskyet
al., 1957; Boutwell and Bosch, 1958) in which creosote was
tound to cause SKin papillornas and carcinomas. In one study
(Roe et oil. , 1958), lung adenomas were observed as well as
skin tumors in mice receiving dermal applications of creosote
oil. The CAG report also cites a number of case studies showing
skin cancer in creosote workers. Typically, premalignant
lesions and malignant tumors appeared on the skin of the tace,
hands, forearms, and scrotum. Although no adequate epidemiolo-
gical studies have been performed on creosote workers, the CAG
report cites these case studies as suggesting that creosote is a
human carcinogen.
ii. Coal Tar
Two hundred years ago, scrotdl cancer was observed in English
chimney sweeps (Pott, 1775). Since that time, several reports
have confirmed cases of cancer in humans resulting from
industrial exposure to coal tars (NIObH, 1977). EPA (CAG,
197(ib) has reviewed a mortality study of 5,7b8 roofers (Hammond,
et al., 1976). These workers used pitch and asphalt, both
of which contain benzo[a]pyrene. Alhough smoking histories of
-------
these workers were not available, measurements of typical
worksite concentrations of benzol a]pyrene enabled the authors to
conclude that occupational exposure to this chemical was at
least 100 times greater than the exposure expected from smoKing
alone. Mortality figures for workers with 20 or more years of
membership in the roofing union show deaths in excess of those
expected from cancer of the lung, gastrointestinal tract,
urinary bladder, and skin.
The CAG report also summarizes numerous skin painting studies in
which coal tars produced skin cancer in mice and rabbits. In
addition, tumors of the lung were reported in mice inhaling coal
tar aerosols (Hortf i ej: _al., 1963). The scientific literature
also contains numerous studies of the carcinogenicity of
individual PAH's in coal tar. Comprehensive reviews of many of
these PAH's appear in the IARC (1973) reviews.
iii. Coal Tar Neutral Oils
Coal tar neutral oils have been shown to be oncogenic in
laboratory animals. For example, Berenblum and Schoental (1947)
tested several coal tar neutral oil fractions in mice and
rabbits. Most fractions were found to be oncogenic. In 1961,
Horton showed that extracts (in maleic anhydride) of coal tur
neutral oils produced tumors in mice in about 33 weeks.
Earlier, however, Cabot e_t al. (1940) applied benzene solutions
of ben20[a]pyrene with and without coal tar nuetral oil to the
89
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skin of albino mice. The coal tar neutral oil was found to
inhibit the tumorigenic response of benzoja]pyrene.
iv. Coke Oven Emissions
Substantial epidemiological evidence is available to show that
exposure to coke oven emissions gives rise in workers to an
excess risk of death from lung cancer and cancers of the
bladder, prostate, pancreas, and large intestine (CAG, 1978a).
As noted earlier, the airborne chemicals comprising coke oven
emissions are condensed to form coal tars. The CAG report
emphasizes that studies of risk to coke oven workers cannot be
used directly-to predict the risk from cancer to wood workers.
'ihis is due to the fact that coke oven emissions are produced at
significantly higher temperatures than those used to heat
creosote and creosote/coal tar blends in wood preservative
treatment plants. therefore, coke oven emissions are more
likely to contain carcinogenic substances, particularly high
boiling PAH's, than those to which wood preservative workers are
exposed. Thus, any risk estimates based on coKe oven studies
would have to be considered as providing only upper limits tor
risks to wood preservative worKers exposed to creosote and
creosote/coal tar.
-------
v. Carcinogenicity of Individual Chemical Components of
Creosote
A series of aromatic amines, among them some monocyclic amines
occurring in creosote (Nestler, 1974), were tested for long-term
toxicity by dietary administration to Charles River rats and
HaM/lCR mice (Vveisburger e_t al., 1978). 01 these amines,
ortho- and para-toluidine, 2,4,-xylidine and 2,5,-xylidine led
to tumors in various tissues. Meta-toluidine had questionable
activity. The boiling points of these compounds range from
200°C to 215°C. Chrysene, one of the major components of
creosote, is a 4-ring PAH which boils at 448 C. As reviewed
by the 1ARC (1973), chrysene causes skin tumors in mice. in
addition, it acts as an initiator of skin cancer in mice. (The
oncogenicity ot chrysene is presently under review by EPA's
Carcinogen Assessment Group.)
A number ot chemicals in creosote act as co-carcinogens,
accelerating agents, and inhibitors. Among these are cresols,
which occur as ortho-, para-, and meta-isomers in creosote. In
1959, Boutweli and Bosch reported that cresols administered in
benzene twice weekly to the skin ot mice acted as promoters ot
the carcinogenic response initiated by dimethylbenzanthracene.
No tumors were found in the solvent control group. Boutweil and
Bosch also report that phenol, another chemical in creosote,
acts as a tumor-promoting agent. Pyrene and tluoranthene, two
major components of creosote which are not carcinogenic by
themselves, have been shown to be co-carcinogenic when applied
91
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on mouse sKin together and with'a low dost of benzo[a]pyrene
(Hoffmann and Uynaer, 1963).
bchmeitz et al. (197b) tested the co-carcinogenicity ot
naphthalene ana alkylated naphthalenes, other major components
oi creosote. The chemicals were applied with benzoI a]pyrene to
mouse skin. These investigators continued the inhibiting
effects oi naphthalene, methylnaphthalene, ethylnaphthalene,
2,3,5-trimethyinaphthaiene, 2,6-dimethylnaphthalene, and
1,5,-cUmethylnaphthalene. On the other hand, 2,3-dimethylnaph-
thaiene and 2,3,6-trimethyinaphthalene were tound to be accelera-
tors. These investigators correlated their bioassay results
with incubations ot the naphthalene derivatives and benzola]py-
lene in hepatic mixed function oxidase systems. When the yield
oi benzo[ajpyrene metabolites upon co-incubation was measured,
it was tound that the inhibitors of carcinogenesis aiso retarded
tne progress ot benzofa]pyrene metabolism; conversely, the
accelerators of carcinogenesis led to enhanced yields ot
benzo[a]pyrene metabolites.
d. Conclusion
In addition to the tact that creosote is well-characterized as
an animal carcinogen, the several individual case studies
provide strong evidence of its potential as a human carcinogen.
Along with the case for oncogenicity ot whole creosote, many of
the individual chemicals in creosote have been shown to be
carcinogens.
92
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Exposure to creosote in wood treatment plants can occur dermaily
or by inhalation. Although we have no quantitative data
regarding the extent o£ dermal exposure in these workers, the
large number ol reports ol creosote burns in the literature
demonstrates that this route ol exposure exists.
inhalution exposure to creosote .can occur in a variety o± ways.
Measured values 01 benzene-solublt polycyclic particulute
organic matter (PPOM), as well as continuation ol specitic
constituents in the breathing zones ot workers, bears this out.
In some pressure treatment, processes, creosote is blended with
coal tar, which has a high proportion ol 5- anu 6-nng PAH
carcinogens. in these treatment plants, the greatest inhalation
exposure may occur when the cylinder door is opened and tram
cars are removed irom the chamber. Air turbulence may result in
suspension ol particuiate material as well as creosote vapors.
One analysis (see 'iable ll.B-2) identiiie-d chemicals with two to
lour rings and boiling points tanging Irom 218 C to j^»3 C.
Although we uo not have precise data as to the protile ot
airborne constituents of creosote to which treatment plant
workers are exposed, airbornt chemicals which have been
contirmeci span a boiling point range matched by that ol many ot
the caicinogens and co-carcinogens in creosote and creosote/cod
tar. 'ihe heavier PAH's, such as chrysene or the 5- and 6-ring
PAH carcinogens, may be less concentrated in the air than in
whole creosote. Other carcinogenic components, such as aromatic
amines which have lower boiling points, may bt more concentrated
93
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in airborne (vapor) phases than in whole creosote. Ihe Agency
believes this supports the presumption of carcinogenic risk to
workers inhaling creosote vapors.
In addition to the variable nature of creosote and creosote/coai
tar blends, the complex nature of the material and the toxicoio-
gical synergism of its constituents preclude the use ot a single
component chemical as an index of exposure for use in a quantita-
tive risk assessment. Moreover, without a well-executed epidemi-
ological study of creosote treatment plant workers or without
animal inhalation data along with treatment plant exposure data,
we have no model for estimating the preservative's carcinogenic
potency. The data on excess deaths from cancer of coking oven
workers are not directly applicable to the situation for wood
preservative workers. This is because the temperatures of
coking ovens are much higher than those to which creosote and
its blends are subjected in wood treatment plants, giving rise,
in all probability, to an entirely different profile of airborne
chemicals.
It is clear from the large number of laboratory studies on whole
creosote and its individual components that creosote is an
animal carcinogen. This, along with the realization that some
finite, though presently unquantifiable, exposure to applicators
exists, causes the Agency to have significant concern regarding
the risks to these applicators.
94
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C. Inorganic Arsenicals
1. Analysis of Rebuttal Comments Concerning Interconversion o£
Pentavalent to Trivalent Arsenic
a. Basis of Concern
i. Introduction
'Ihere are two forms, or valence states, of the inorganic arseni-
cal compounds, trivalent and pentavaient. It has long been
recognized that trivalent arsenic is the more acutely toxic of
the two forms. It binds to tissue more readily and inhibits the
action or many enzymes. Pentavalent arsenic is less acutely
toxic than the trivalent form and is the predominant form found
in mammalian (or aerobic) systems.
Interconversion is defined as the oxidation of the more toxic
trivalent arsenic to the less toxic pentavaient form, and the
reduction of the pentavaient form of arsenic to the trivalent
form. The Interconversion concern addresses the chemical conver-
sion (in mammalian systems) of pentavaient arsenic, the less
toxic form, to trivalent arsenic, the more toxic form. Oxida-
tion is the favored reaction in aerobic (mammalian) systems and
reduction is the favored reaction in anaerobic systems. Because
of the differences in the forms' chronic and acute toxicity,
interconversion is important in evaluating the environmental and
health effects of the inorganic arsenical compounds.
95
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The problem of interconversion is addressed by EPA under Section
162.3(L) and (J) ot FIFRA's Rules and Regulations, which detine
the meaning ot "degradation product" as a substance from any
transformation of a pesticide. The implication of the intercon-
version issue and the Agency's definition of degradation product
is that it interconversion is shown to exist, both valence forms
ot arsenic can be regulated as one compound, trivalent arsenic.
li. Studies
Two studies form the basis of the Agency's concern that penta-
valent arsenic (arsenate) can be reduced in mammalian systems to
trivalent arsenic (arsenite). Ginsberg (1965) measured arsenite
in dog kidneys infused with arsenate; Lanz et al. (1950) mea-
sured the urinary excretion of arsenite in rats after injecting
them with arsenate.
Four studies have shown that similar toxic effects of arsenite
and arsenate occured in four separate biological systems. How-
ever in each case arsenite was from two to tive times more
potent. The studies were an acute toxicity rat study (Franke
and Moxon, 1936), a teratology study in Swiss Webster mice
(Hood, 1972), and a chronic feeding study in rats (Byron
jet £l., 1967) and dogs (Byron e_t _al., 1967) which showed
a marKed enlargement of the common bile duct, weight loss, and
high mortality.
96
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Another study indicated that there was a type of equilibrium
concentration ratio between arsenite and arsenate of four1
to one in wine fermentation systems and in commercial wines
(Crecelius 1977a).
The study suggests that an equilibrium concentration between
arsenate and arsenite exists in living systems.
b. Analysis of Specific Rebuttal Comments
Rebuttal Comment 1; Interconversion of arsenate to arsenite
in vivo (1, 2, 156, 165)
Several rebutters state that the references relied upon as
direct evidence of ^n vivo conversion of arsenate to arsenite
are inadequate. Recent work reporting the presence of methyl-
ated organic arsenicals in plasma and urine lead to the
conclusion that Ginsburg was (inadvertently) determining and
reporting pentavalent organic arsenicals and not in vivo
interconversion of pentavalent to trivalent arsenic. Further,
there is not an equilibrium ratio of arsenate to arsenite in
living organisms. While evidence is strong that arsenite is
converted to arsenate ^n vivo, pentavalent arsenic does not
reduce to trivalent arsenic in vivo
Agency Response; The Agency agrees with the rebutters that
the analytical methodology in the studies used in Position
Document #1 (PD-1) to provide direct evidence of interconversion
97
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contained deficiencies. Position Document #1 (pp. 72-73)
acknowledges that the predominant form of arsenic (organic and
inorganic) in mammals is pentavalent, and that when trivalent
arsenite is administered it is oxidized to the less toxic
pentavalent form which is the favored reaction. The Position
Document also concluded that oxidation of trivalent arsenic to
pentavaient arsenic has often been described in the literature.
Conversion of pentavalent arsenic to trivalent arsenic, on the
other hand, has been shown to occur under anaerobic conditions
by Creselius (1977a) (in fermenting wine) and Ferguson and Gavis
(1972) (in oxygen deficient waters). However, the mammalian
body is primarily an oxidizing environment. The primary
sources of evidence which support the mammalian conversion of
pentavalent arsenic to trivalent arsenic are the studies by
Ginsburg and lotspeich (1963) and Ginsberg (1965). These
studies which determine the valence state of arsenic by the
method of Crawford and Storey (1944), contend that pentavalent
arsenic is converted in the mammalian body to trivaient arsenic.
The Agency has determined that the method used in the Ginsburg
studies is valid in the absence of organic arsenic (see comment
by Lombardini, page 80 of PD-1). However, when the method is
applied to biological fluids which may contain organic arsenic a
preliminary extraction step with carbon tetrachloride must be
performed to remove the organic arsenic.
Although the studies by Ginsburg used the method of Crawford and
Storey it was not stated specifically that the carbon tetra-
chloride extraction procedure was performed.
98
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Ihe Crawford and Storey procedure relies on the reaction ot inor-
ganic arsenite with sodium ethyl xanthate under acid conditions,
followed by extraction of the product with carbon tetrachloride.
Arsenate does not react and remains in the aqueous layer; hence,
trivalent arsenic and pentavalent arsenic valence states can be
separated by this procedure. As discussed above, Ginsburg made
no mention of a preliminary extraction step in his studies.
Therefore it appears that organic arsenicals could have inter-
fered with the analytical procedure and been interpreted as
trivalent arsenic. It has been shown recently that dimethyl-
arsinic acid (DMAA), a pentavalent species, is a major meta-
bolite in mammals, including man (Braman and Foreback, 1973;
Creselius, 1977b; Smith £ta_l., 1977; Tarn et al., 1978;
Charbonneau e_t al. / 1979). DMAA reportedly is not soluble in
carbon tetrachloride, and therefore not extracted by, carbon
tetrachloride, but will react with sodium ethyl xanthate to
form trivalent organic arsenicals which are soluble in carbon
tetrachloride (Zingaro, 1979). Zingaro also pointed out that
sodium ethyl xanthate, under the acid conditions used, can
function as a reducing agent and transform inorganic pentavalent
arsenic to trivalent arsenic. Thus it appears reasonable to
conclude that the analytical technique used by Ginsburg probably
did not differentiate between the valence states of arsenic
encountered in his experiments. The Lombardini commentary cited
in PD-1 (page 80) did not address the issue of the inadequacies
of the analytical technique.
99
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Peoples (1964) developed a modified procedure to circumvent the
difficulties discussed above. In his procedure, an alkaline pH
was used for the reaction with xanthate, followed by the carbon
tetrachloride extraction. The trivalent arsenic is removed in
the extraction, leaving pentavalent arsenic in the basic aqueous
fraction.
Peoples reported that, in two cows fed arsenic acid (pentavalent
arsenic), all the arsenic was in the pentavalent state. He
found no evidence that arsenic acid is partially reduced to the
trivaient form. It should be noted that the study by Peoples
used arsenic acid administered in the feed, compared to the
intravenous technique used by Ginsberg. However, Tarn et al.
(1978) also used intravenous administration of arsenic acid, and
found about 90% of the arsenic present in the urine as DMAA
after three days; DMAA was the dominant species in plasma two
hours after dosing. Similar results were found by Charbonneau
et _al. (1979) .
Other references cited in support of the in vivo interconversion
of arsenate to arsenite may also have methodology problems. Ihe
study by Land £_t al. (1950) appears to be deficient in both
sample preparation and analysis procedures. Also, in the study
by Meaiey e_t al. (1959), the arsenate/arsenite ratio may have
been caused by a reducing environment in the analytical
procedure.
100
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The conclusions of the studies by Peoples (19b4) and Lakso and
Peoples (1975) contradict the contention of _in v^ivo conversion
of arsenate to arsenite. Peoples (1964) fed arsenic acid to
cattle and found ail the arsenic in the pentavalent form; he
concluded that "there is no evidence that it is partially
reduced to the trivalent form." Lakso and Peoples (1975) found
that both cattle and dogs produced methylated arsenic when fed
either inorganic arsenate or arsenite. They suggested that
arsenite may be oxidized to arsenate before biomethylation, due
to the rapid appearance of methylated arsenic alter arsenite
feeding .
In a brief experiment designed to test the theory that DMAA
would have been recovered and measured as trivalent arsenic,
Osmose Wood Preserving Company carried out the Crawford and
Storey analytical procedure exactly as described, but used DMAA
(99.93% pure) instead of arsenic acid. After reaction with
sodium ethyl xanthate and extraction with carbon tetrachloride,
they recovered up to 92% of the DMAA in the organic solvent
fraction. Thus DMAA would have been mistaken for trivalent
arsenic by this procedure. Several repetitions of this experi-
ment led to generally lower recoveries of DMAA (less than 25%);
nevertheless it now seems clear that DMAA, when present in bio-
logical fluids, is capable of giving a false positive reaction
for trivalent arsenic when the analytical procedure of Crawford
and Storey is used.
101
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c. Summary of Rebuttal Comments Concerning Interconversion:
Conclusion
Tne Agency agrees with the rebutters that the preponderance of
chemical evidence on the issue of interconversion .of arsenic
species in mammalian systems demonstrates the following:
1. Conversion of arsenite to arsenate is the dominant
pathway _in vivo. No substantial evidence was submitted,
however, which indicated that there-is not an equilibrium
concentration ratio (however small) between arsenate and
arsenite in oxidizing systems.
2. Biomethylation of arsenic species in mammalian systems can
lead to the formation of dimethylarsinic acid (DMAA).
3. DMAA has the potential to interfere in the Crawford and
Storey analytical procedure, leading to possible false
positive determinations of arsenite.
'ihe Agency therefore concludes that, due to uncertainties in the
analytical methodology, the reduction of pentavalent arsenic to
trivaient arsenic ^_n vivo has not been demonstrated with suffi-
cient experimental evidence to be given weight in the arsenic
risk assessment at this time. However, at the same time the
possibility of the interconversion reaction taking place has not
been ruled out.
102
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2. Analysis of Rebuttal Comments Concerning Oncogenicity
a. Basis of Presumption
i. introduction
The Agency has relied primarily on human epidemiology studies to
assess the oncogenicity of the inorganic arsenical compounds.
Epidemioiogical studies in conjunction with confirmatory animal
tests provide the best evidence that an agent is a human carcino-
gen. Albert e_t al. (1977) noted that "of the chemical agents
that are generally accepted to have produced human cancer, ail
but one (arsenic), produced an oncogenic response in rats and/or
mice...in the same organ as in humans when tested by the appro-
priate route of exposure." Arsenic is unique in this respect
(Frost, 1967; NAb, 1977b) as suitable animal models are not
available tor extrapolation of oncogenic responses to humans.
Chronic exposure to arsenic, either both forms (tri- and penta-
valent) together or singly, or an unspecified form, has produced
abnormal pigmentation, keratosis, sKin cancer, and lung cancer,
as well as cancer of the liver and perhaps cancer in other
organs and sites. irivalent inorganic arsenic was tiie predomin-
ant form in most exposure situations. Pentavalent inorganic
arsenic was the predominant form in two exposure situations
where increased lung cancer was observed; these were exposure
during pesticide manufacturing and chronic exposure of orchard
workers to lead arsenate.
103
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ii. Studies
Three comprehensive reviews by Neubauer (1947)/ Stellman and
Kabut (1978), and the National Academy of Sciences (1977)
documented the occurrence of skin cancer in patients treated
with Fowlers Solution (potassium arsenite). Yen et al.
(1968), Yeh (1963), Yeh (1973), Tseng et al. (1968), and
Tseng (1977) described chronic arsenic poisoning and sKin cancer
resulting from arsenic contaminated drinking water in Taiwan.
Osburn (1969) described chronic arsenic poisoning and lung
cancer in patients exposed to arsenic containing mine oust.
Bergoglio (1964), and Neubauer (1947), described skin cancers
and other disorders in Argentine and Siiesian villagers exposed
to arsenic contaminated groundwater. Pinto and Bennett (1963),
Lee and Fraumeni (1969), Milham and Strong (1974), and Pinto £t
al. (1977) in the United States and Kuratsune e_t al. (1974)
and TOkudome and Kuratsune (1976) in Japan documented increased
incidence of lung cancer among smelter workers exposed to
arsenic trioxide. As in most epidemiology studies, the workers
were exposed to more than one chemical agent. The consistency
of the findings, however, left little doubt that arsenic tri-
oxide was at least a major contributor to the incidence of lung
cancer in heavily exposed workers.
Hill and Fanning (1948) reported skin, lung, and liver cancer
in pesticide factory workers exposed to sodium arsenite. Ott
(1974) reported lung cancer in pesticide manufacturing plant
104
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workers exposed to calcium and lead arsenate. Roth (1956,
1957a, 1957b, 1957c, 1958), Denk (1969), Thiers (1967), Braun
(1958), Vbn Pein (1943), Galey et al. (1963), and Petres
(1957), reported skin, lung and liver cancers associated with
the use of calcium arsenate and copper acetoarsenite by German
and French vineyard workers. Finally, NIOSH (1975) re-examined
mortality statistics in apple orchard workers exposed to lead
arsenate and found statistically significant increases in
respiratory cancer.
b. Analysis of Specific Rebuttal Comments
Rebuttal Comment 1; No Animal Studies (1, 165, 188, 213,)
Several rebutters state that no suitable animal experiments have
been performed with exposures to kno.wn arsenic compounds to
support the epidemiology studies, which allegedly show that
inorganic arsenic is a human carcinogen.
Agency Response: At the time PD-1 was written the comment was
largely true. No animal skin cancer models had been developed
showing the skin changes observed in human chronic arsenical
poisoning. Animals had not been adequately tested via inhala-
tion. Only one study (Oswald and Goertier, 1971) resulted in a
positive tumor response but the experiment was inadequate to
establish arsenic as a carcinogen for several reasons: a) it was
designed as a fetal toxicity study, b) the tumor type was not
well described (the single word, "leukoses," translated from
105
-------
German was used), and c) the agent given was only described as a
sodium salt of arsenic.
However, the Agency has taken the position that human exposures
to an agent which results in a carcinogenic response constitutes
firm evidence that a human hazard exists whenever people are
exposed. When such evidence exists, as it certainly does for
arsenic, the value of confirmatory animal studies is that the
specific compound causing the response can be identified. When
this confirmatory animal evidence is lacking, as it was when
the PD-1 was written, the Agency critically examines the expo-
sure evidence tor each of the available epidemiology studies.
As discussed below in comment 2 the Agency reached a conclusion
that the most likely cause tor the responses was inorgnic
arsenic.
The recent study by Ivankovic et al. (1979) in rats has
largely, but not completely, confirmed that inorganic arsenic is
the agent responsible for the orcogenic response. The authors
found lung carcinomas after intratracheal installation of a
mixture of calcium arsenate, calcium oxide, and copper sulfate.
Ihis mixture is an arsenical pesticide preparation used in some
German vineyards during the 1930*3. This experiment strongly
indicates that pentavalent arsenic can induce lung carcinomas,
although the contribution of sulfate, copper, and calcium oxide
cannot be ruled out until further experiments are carried out.
106
-------
Therefore, the comment as stated is still true, i.e., there are
no animal experiments which show unequivocally that inorganic
arsenic is the agent responsible for the lung and skin cancers
that have been observed repeatedly with high human arsenic expo-
sure. However, the epidemiology evidence as summarized does
indicate that a human hazard exists and the Agency position that
inorganic arsenic is the most probable causative agent remains
unchanged.
Rebuttal Comment 2: Uncertainties in the Interpretation of
Epidemiology Studies (1, 2, 145, 165,
166, 188, 213)
A number of rebutters state that several uncertainties in the
interpretation of any epidemiologic study make it difficult
for the Agency to claim that inorganic arsenicals, and specifi-
cally pentavalent arsenic, is responsible for the increased
incidence of cancer observed. These factors include a) the
difficulty of estimating retrospectively the amount and duration
of exposures for each person in the cohort, b) difficulties in
sorting out other chemical agents, environmental factors and
personal habits which could influence the death rates and causes
ot death observed in the studies. In the smelter studies the
SO usually present along with arsenic is a contributing
factor which may be more important than arsenic.
Agency Response: As pointed out in the PD-1, the epidemiologi-
cal data is very clear that chronic exposure to arsenic in
107
-------
various situations has resulted in symptoms of abnormal skin pig-
mentation, keratosis of the skin, squamous cell carcinoma and
basal ceil epitheliomas of the sKin as well as bronchial car-
cinoma and liver angiosarcoma. This overall conclusion remains
valid despite the uncertainties in each individual study.
Trivalent arsenic was known or suspected to be present in ail of
these situations with the one exception that in the ott et al.
(1974) study the arsenic was predominately pentavalent. In ail
ot the smelter studies SO., accompanied trivalent arsenic expo-
sures but in the sheep dip situation, (Hill and Fanning, 1948),
both lung and skin cancer were observed with no SO., exposure.
The latter study indicates that arsenic without SO., exposure
can induce lung cancer. When the risk of air exposures were
analyzed quantitatively, (GAG, 1980) it was found that the Ott
£_t al. (1974) study which was predominately pentavalent
arsenic, had a lung cancer risK which was indistinguishable from
the risk in the smelter studies, where trivalent arsenic and
SO., were present. This comparison indicates that inhaled
pentavalent and trivalent arsenic do not differ appreciably in
their effectiveness in causing lung cancer.
Therefore, although the evidence is not unequivocal, the predomi-
nate theme which is consistant with all of the evidence is that
exposure to trivaient arsenic without SO., can induce lung and
skin cancer when inhaled and skin cancer when ingested. The
same can be said for pentavalent arsenic except that epidemiolo-
108
-------
gic evidence of cancer caused by ingested pentavalent arsenic
does not exist.
Rebuttal Comment 3; No Direct Evidence that Pentavaient
Arsenic Is an Oncogen (12, 39, 156,
165, 166)
Several rebutters state that The Agency does not present con-
vincing biochemical or toxicologic evidence that arsenic in the
pentavalent form is carcinogenic. Although it is known that
trivalent arsenic reacts with sulfhydryl (SH) groups on proteins
and binds to enzymes no such evidence exists for pentavalent
arsenic. Furthermore, there is no direct evidence that penta-
valent arsenic is converted to trivalent arsenic in the body.
Agency Response; In the PD-1 the Agency had the difficult
task of evaluating the hazard to pentavaient inorganic arsenic,
a compound which has not been evaluated well toxicoiogicaliy.
Indirect, but plausabie, arguments were made which suggested
that pentavalent arsenic might exert its toxic action via a tri-
valent arsenic intermediate state. Several urinary excretion
studies which purportedly show that arsenic is mainly in the
trivalent state after pentavalent arsenic is administered were
likely carried out without proper precautions to prevent oxida-
tion after the samples were collected. No further information
was presented in the rebuttal comments on the results of direct
experiments designed to test the possibility of conversion of
pentavalent to trivalent arsenic.
109
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Therefore, the Agency finds the rebuttal comments correct in
stating that there is no direct toxicological or biochemical
evidence for the toxicity of pentavalent arsenic or the conver-
sion of pentavalent to the toxic trivalent form. However, this
does not rebut PD-1 position, since the PD-1 stated that there
is ample indirect evidence to suggest beyond a reasonable doubt
that pentavalent arsenic has the same toxic effects astrivalent
arsenic but is less effective quantitatively.
Rebuttal Comment 4: Arsenic Is a Naturally Occuring Element
(134)
bonide Chemical Co. Inc., states that the natural and ubiquitous
occurence of arsenic in food such as sea foods, and in drinking
water and soils of some regions already causes a large exposure
of people to arsenic. Any attempt to reduce exposure via regula-
tion ot arsenic products would have an insignificant effect on
total exposure .
Agency Response: The Agency agrees that the largest single
source of exposure to arsenic is from food where it predomi-
nately occurs as organically bound arsenic, which is generally
recognized as non-Loxic due to its metabolic pathway. However,
the exposure to the inorganic arsenicals alone in the groups of
people and exposure situations identified in the exposure assess-
ment document (see section 11.C.7 of this document) could be
substantially reduced by the regulation of inorganic arsenic as
a wood preservative.
110
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c. Summary of Rebuttal Comments Concerning Oncogenicity:
Conclusion
In summary, the Agency concludes that chronic exposure to either
trivalent or pentavalent arsenic can induce cancer and that the
risJc criteria tor oncogenicity of inorganic arsenicals as stated
in PD-1 remains unrebutted.
3. Analysis of Rebuttal Comments Concerning Mutagenicity
a. Basis of Presumption
i. Introduction
The Agency issued an RPAR against all inorganic arsenical pesti-
cides on the basis of mutagenicity. The data presented in the
PD-1 and summarized on Table ll.C-1 of this document demon-
strates that both trivaient (arsenite) and pentavalent (arsen-
ate) forms of inorganic arsenic can act as mutagenic agents.
These studies form the basis of the Rebuttable Presumption
Against Registration (RPAR) tor the inorganic arsenical
pesticides based on the mutagenic effects criterion.
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li. Description of Studies
As described in detail on Table II.C-1, the inorganic arsenical
compounds have been evaluated in several different mutagenicity
test systems. Sodium arsenite and sodium arsenate have been
shown to be mutagenic in both in vitro and _in vivo tests. Gene
(point) mutations occur in tests of sodium arsenite with bac-
terial systems #(Escherichia coli) (Nishioka, 1975) and
mammalian (hamster) cells in vitro (Casto, 1977a). Chromosomal
aberrations are caused by sodium arsenite and sodium arsenate,
as seen in _in vitro tests with human cells (Oppenheim and
Fishbein, 1965; Paton and Allison, 1972), and in _in vivo tests
with mice (Sram and Bencko, 1974), and humans with known arsenic
exposure (Petres e_t _al., 1970, 1977). Potassium arsenite
caused DNA damage in human lymphocytes in vitro (Burgdorf
e_t _al., 1977). DNA repair jjn vitro was decreased by sodium
arsenite and sodium arsenate in ultraviolet light-exposed bac-
teria (E. coli) (Rossman et al., 1975, 1977), (Bacillus
subtilis), (Nishioka, 1975), and by sodium arsenate in xenon
lamp-exposed human epidermal cells (Jung e_t al., 1969; Jung
and Trachsel, 1970). In addition, these inorganic arsenical
compounds affected DNA synthesis and mitosis by their metabolic
and cellular toxicity effects as demonstrated by j.n vitro and in
vivo tests in mammalian systems (see Table II.C-1).
117
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b. Analysis of Specific Comments
Ail rebutters' comments were reviewed. Many comments were of a
testimonial nature or expressed opinions without supporting
data. Several rebutters discussed the nutritional value of
arsenic. The American Wood Preservers Institute's (AWPi)
exhibit was the most comprehensive and contained additional
studies not reviewed in PD-i. These studies (while not shown
on the tables) are discussed in the following rebuttal comments,
Rebuttal Comment 1; No Direct, Multi-Test Evidence For
Mutagenicity of Pentavalent Arsenic (2)
The AWPI rebuttal contains an independent analysis by Clement
Associates of trie references listed in Table 23 (Summary of
Studies of Inorganic Arsenic Mutagenicity) PD-1. Clement
Associates presented their opinions in a document entitled
"Review of Evidence for Mutagenicity of Inorganic Arsenical
Compounds," dated December 20, 1978. They presented their
tindings with respect to each study, and made an overall assess-
ment of the extent to which the studies support the Agency's
findings. Clement Associates state that the data presented in
several of the studies provide evidence for the potential muta-
genicity of inorganic arsenical compounds in bacterial and
mammalian ceil test systems. However, Clement Associates also
state that these studies need to be repeated with a more quanti-
tative protocol and that more data would be desirable. The
118
-------
conclusion that the studies need to be repeated provided the
AWPl's basis tor their rebuttal comment.
The AWPI rebuttal states: "In summary, therefore there are no
studies that provide direct evidence of the mutagenicity of
pentavalent arsenic compounds. The studies cited in the PD-i
certainly do not constitute 'multi-test1 evidence of mutageni-
city of pentavalent arsenic compounds." The AWPI rebuttal is in
agreement with the independent analysis presented by Clement
Associates and AWPI "believes that there is no support whatever,
much less any multi-test support, for^ the Agency's rebuttabie
presumption that pentavalent arsenic induces mutagenic effects."
The AWPI report goes on to state, "Even if one presumes the
Agency's conclusions regarding in vivo conversion (of penta-
valent to trivalent arsenic) are correct, a proposition that
clearly is not supportable for the reasons discussed in pages
14-45 of these rebuttal comments, there is still not sufficient
evidence to establish that even trivalent arsenic induces
mutagenic effects ."
Agency Response; The criteria for mutagenicity has been
amply met, as shown by the studies cited in Section li.C.3.a of
this document. The positive dominant lethal test in mice in
vivo, (Sram and Bencko 1974), and the chromosomal aberrations
and aneuploidy which were associated with human exposure to
arsenic in vivo (Petres e_t jal., 1970, 1977), support results
of the the other tests and raise the suspicion that arsenic may
119
-------
pose a mutagenic hazard to humans. The Agency agrees with the
rebutter that more quantitative data are desirable.
Rebuttal Comment 2; Pentavalent Arsenic Is Not a Mutagen (2)
The AWPl rebuttal contains an in vivo cytogenetic study in mice
(Graham, 1979). This study shows that mice fed CCA-treated wood
fibers (pentavalent arsenic) in the diet did not show a muta-
genic response. Groups of three male mice were fed regular
ration, regular ration with 10% wood fiber, or regular ration
with 10% CCA-treated wood fiber. Mice were offered these diets
for 2, 3, 7, 14, or 21 days. Three hours before sacrifice each
mouse was injected intra-peritioneally with colchicine. Bone
marrovv was obtained and prepared for examination (fifty meta-
phase plates per mouse). The level of chromosome damage was the
same tor both the treated and control animals. A slight in-
crease in polyploidy with increased exposure time in the CCA-fed
mice was observed. The AWPl states that "the central fact of
this test is clear: no mutagenic responses were noted."
Agency Response: The Agency has determined that the results
of the experiment are inconclusive; the author states that the
mice ate around their ration treated wih CCA and either lost
weight or failed to gain weight. The tact that treated mice
apparently did not consume part of the diet points out possible
inadequacies in the study.
120
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An accurate measure of food consumption could rule out a low
amount of feeding as a possible cause of weight loss at days
14 and 21 in the CCA-treated mice. On the other hand, the
increased incidence of polyploidy in the CCA-treated mice may
indicate that some arsenic was ingested.
Rebuttal Comment 3: Eftect of pH on Test Reliability (2)
AWPI states a number of general comments in rebuttal of the is-
suance of an KPAR against arsenic, based on multi-test evidence
of mutagenicity. One comment referred to the effect of pH on
test reliability. AWP1 contends that the Agency must consider
the pH effect of chemicals on the reliability of short-term
mutagenesis assays before relying on them to determine whether
to issue an RPAR.
Agency Response: No actual data were offered in support
of this point. However, the Agency agrees that changes in pH
may have a deleterious effect on ceils. However, the rebutter
did not present any information that directly supports a conten-
tion that the results of the mutagenicity tests in the PD-1 were
compromised by changes in pH.
121
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Rebuttal Comment 4; Three-Generation Reproduction Studies (2)
AWP1 claims that the preferred way to assess rautagenic risk is
by three-generation reproduction studies.
Agency Response; The rebutter's argument did not show three-
generation reproductive studies to be preferable to the types of
mutagenicity studies listed in the PD-1 for assessing mutagenic
risk. Further no data or statistical sensitivity discussions
were offered to support this contention The results of the muta-
genicity tests listed in PD-1 led to the Agency's presumption
that arsenic causes several mutagenic effects, i.e., gene
(point) mutations, chromosome aberations, changes in chromosome
number, DNA damage, decreased DNA repair, and probably heritable
genetic defects in mammals. The results of a three-generation
reproduction test would not allow definitive conclusions to be
drawn regarding the several possible mutagenic effects of the
test compound as such a test is not designed to detect mutagenic
events per se and will not detect all mutagenic end points of
concern. Further, if mutagenic effects could be detected, the
sensitivity of the 3-generation reproductive test is inadequate
to assess the several mutagenic effects listed above.
122
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Rebuttal Comment 5: No Mutagenic Response in 3-Generation
Studies of Morris et al. (1938) and
Kojima (1974) (2)
The AWPi notes that the two multi-generation studies of Morris
e_t al. (1938) and Kojima (1974) could be interpreted to
show that no mutagenic responses were noted in either study or
at any generation.
Agency Response; The Morris e_t al. (1938) and Kojima (1974)
studies were designed as reproduction studies, not mutagenicity
studies. The Agency has determined that these studies do not
evaluate mutagenicity and are therefore not reiavent to the
mutagenicity presumption (see discussion of previous Agency
Response) .
Rebuttal Comment 6: Toxic Threshold (2)
The rebutter (AWPI) contends that a "threshold dose" (not
defined) exists before a toxic reaction is noted.
Agency Response: Unless proven otherwise, mutagenic effects
are presumed to have no threshold. The Agency presumes that
single molecules at the "target" site(s) may induce mutagenic
events. This is different than the case for some other toxic
effects, e.g. teratogenicity, where thresholds are currently
believed to exist.
123
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Rebuttal Comment 7; Toxicity Related to Acute Toxicity
Rather Than to Mutagenesis (2)
The AWPI states that the toxic effects noted in Petres et al.
(1974) (see Table II.C-1) are related to acute toxicity rather
than mutagenesis.
Agency Response; No data was submitted by the rebutter in
support of this comment. Mutagenicity tests represent a very
sensitive means of detecting what are, after all, mutagenic
events. Chromosomal damage, aneuploidy, increased point muta-
tions, and other related effects summarized on Table ll.C-1 of
this document are all mutagenic events observed in various tests
with inorganic arsenicals.
Rebuttal Comment 8; Lack of Human Effects (2)
The AWPI states that arsenic is not mutagenic in man.
Agency Response; The Petres £t _al. studies (1970, 1977),
contained evidence that chromosomal damage had occurred in per-
sons exposed to inorganic arsenical pesticides or to arsenical
medications. Based on these findings and the many positive muta-
genicity studies in Table II.C-1 of this document,the Agency
believes that arsenic may induce mutagenic effects in the cells
of humans.
124
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Rebuttal Comment 9; Arsenic Mutagenic in Any Form (2)
AWPI states that the Agency has concluded that arsenic is
mutagenic in any form.
Agency Response; The Agency does not agree that arsenic in
any form is mutagenic. PD-1, page 166, only states "... without
exception a rebuttable presumption against registration exists
for all inorganic arsenical pesticides ...." Inorganic arseni-
cal pesticides includes both pentavalent and trivalent arsenic
but not all forms of arsenic, such as organic arsenical com-
pounds. Organic arsenicals are considered nontoxic due to their
metabolic pathway which differs considerably from the inorganic
arsenical compounds.
Rebuttal Comment 10: Chromosome Damage and Cellular Toxicity
(2)
The rebutter (AVvPI) states that chromosome damage can be
produced by a number of agents and that cellular toxicity must
be clearly established before evaluating mutagenic responses.
The rebutter does not further characterize tnese agents.
Agency Response: The Agency agrees that cytotoxic (cellular
toxicity) effects can interfere with the assessment of the
results of mutagenicity tests. However, the rebutter has not
submitted data that shows that the mutagenicity study results
cited in PD-1 were confounded by cytotoxicity.
125
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Rebuttal Comment 11; Mammalian Mutagenicity Test System (213)
Texas A&M University claims no mammalian studies have suggested
arsenic as a mutagen. Thus they feel some doubt as to whether
any forms of arsenic are mutagenic.
Agency Response; The Agency notes at least two mammalian
tests are significant with regard to the mutagenicity of
arsenic: 1) the dominant lethal test of Sram ana Bencko (1974)
indicating heritable mutagenic effects in mice, and (2) the
studies of Petres e_t al. (1970, 1977), showing that exposure
to arsenic can cause chromosomal aberrations and aneuploidy in
humans.
c. Summary of Rebuttal Comments Concerning Mutagenicity
Conclusion
The inorganic arsenical compounds have been evaluated in several
different tests for mutagenicity. The individual studies upon
which the presumption is based are listed in Table ll.C-1 of
this document. Of particular concern are: 1) the positive
result in the dominant lethal test of Sram and BencKo (1974),
which indicated that inorganic arsenic reached the germ cells
(gonads) and produced heritable mutagenic effects in mammals and
2) the studies by Petres et al. (1970, 1977) that showed that
human exposure to arsenic can cause chromosomal aberrations and
aneuploidy in humans in vivo.
126
-------
The Agency concludes that, based on the evidence of mutagenicity
cited in Table II.C-1, the risk criteria as set forth in 40 CFR
162.11 (a)(3()(ii)(A) have been exceeded for the inorganic
arsenicals and that the mutagenicity presumption has not been
rebutted.
4. Analysis of Rebuttal Comments Concerning Fetotoxic and
Teratogenic Effects
a. Basis of Presumption
i. Introduction
The Agency concluded in PD-1 that a rebuttable presumption
against the registration of all pentavalent and trivalent inor-
ganic arsenical compounds exists. The presumption was based on
these compounds' teratogenic and fetotoxic potential.
By way of introduction to the following discussion of teratogen-
icity and fetotoxicity as possible adverse effects of exposure
to inorganic arsenicals, it will be useful to address some basic
issues of definition. Generally, the term "teratogenic" is
defined as the tendency to produce physical and/or functional
defects in offspring in utero. The term "fetotoxic" has tradi-
tionally been used to describe a wide variety of embryonic
and/or fetal divergences from the normal which cannot be classi-
fied as gross terata (birth defects) — or which are of unknown
or doubtful significance. Types of effects which fall under the
127
-------
very broad category of fetotoxic effects are death, reductions
in fetal weight, enlarged renal pelvis, edema, and increased
incidence of supernumary ribs. It should be emphasized, how-
ever, that the phenomena of terata and fetal toxicity as cur-
rently defined are not separable into precise categories.
Rather, the spectrum of adverse embryonic/fetal effects is con-
tinuous, and all deviations from the normal must be considered
as examples of developmental toxicity. Gross morphological
terata represent but one aspect of this spectrum, and while the
significance of such structural changes is more readily evalu-
ated, such effects are not necessarily more serious than certain
effects which are ordinarily classified as fetotoxic--fetai
death being the most obvious example. The studies, which are
summarized on Table ll.C-2 and described in the following
paragraphs, form the basis of the teratology and fetotoxicity
presumption against the inorganic arsenical compounds.
ii. Studies
There are several studies which show that arsenic administered
by injection causes teratogenic and fetotoxic effects in
animals. Although these studies will not be considered in the
risk assessment due to their inappropriate (for humans) route of
administration, they do demonstrate the teratogenic and teto-
toxic effects of arsenic.
128
-------
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Beaudoin (1974) injected pregnant Wistar rats with varying doses
of sodium arsenate and observed dose dependent fetal resorption
and malformations. Fetal resorption and malformations such as
exencepholy, eye detects, facial clefts, agnathia, etc., in
Wistar rats injected with varying doses of sodium arsenate were
also described by Burk and Beaudoin (1977). Holmberg and Perm
(1969) reported 49% malformed embryos and 35% resorbed embryoes
in golden hamsters injected with varying doses of sodium
„arsenate. Perm et al. (1971) observed dose-dependent terato-
genic effects (embryo resorption, malformations) in golden ham-
sters injected with sodium arsenate. Further a high degree of
resorption and reduced fetal weights that were day and dose
dependent were observed by Hood (1972) in albino Swiss Webster
mice injected with sodium arsenate. Malformations were highest
when doses occured on days 8 to 10. Hood and Bishop (1972)
described dose-dependent fetal malformations in Swiss Webster
mice injected with sodium arsenate and Hood and Pike (1977)
observed an increase fetal mortality, resorptions, and malforma-
tions in Swiss Webster mice with a single dose of sodium
arsenate.
Franke et al. (1936) reported ectopic abnormalities in chicken
embryos injected with a single 0.01 ppm dose of sodium arsenate
(0.01 ppm corresponds to 1.0 mg/kg total arsenic). Ridgeway and
Karnofsky (1952) reported leghorn chicken embryos injected on
the fourth day with sodium arsenate were stunted and had mild
micromeiia and abdominal edema. Puzanova and Doskocil (1976)
139
-------
described teratogenic effects of pentavalent arsenic on Leghorn
chicken embryos.
In the following studies arsenic administered orally caused
teratogenic and fetotoxic effects.
Hood e_t al. (1977, 1978) showed effects on fetal mortality,
weight, and malformations in mice treated with sodium orally and
by intraperitoneal injection. Arsenate was more potent when
administered by injection than by oral means.
Matsumoto e_t _al. (1974) reported no significant increase in
fetal malformations, when pregnant mice were gavaged with 0, 10,
20 or 40 mg/kg/day sodium arsenite on days 9, 10, and 11 of
gestation. Fetotoxicity was evident at all levels tested and
was expressed as reduced fetal body weights and reduced placenta
weights. At 40 mg/kg/day there was a significant increase in
the incident of dead or resorbed fetuses (30.4% compared to 9.8%
tor controls; P _<0.001). In addition Schroeder and Mitchner
(1971) observed an increased ratio of males to females and
reduced litter size in Charles River mice orally ingesting an
arsenite salt solution.
Although maternal toxicity was mentioned in one of the studies,
(Hood, 1978) no data was provided by the author. rihus the
degree of maternal toxicity could not be evaluated.
140
-------
The following four studies showed no teratogenic or fetotoxic
effects in laboratory animals exposed to various inorganic
arsenicals at the dose levels reported.
Kimrnei and Fowler (1977b, letter) reported no teratogenic or
tetotoxic ettects in pregnant rats given 30 or 90 ppm sodium
arsenite and arsenate in the drinking water trom day 1 through
day 21 of gestation. (These levels are equivalent to 4.8 and
14.4 mg/kg/day respectively.) The parameters the authors
measured were fetal weights, number of fetuses per litter,
number of malformations, maternal weights, and food and water
consumption. The arsenic compounds had no effect on these
parameters. The fetuses were examined prenataily in this study,
thus ruling out the possibility of maternal cannibalism of
detective pups, or loss of pups through post-natal mortality due
to undetected visceral or skeletal abnormalities.
James et al. (1966) fed four pregnant yearling ewes potassium
arsenate via gelatin capsule; three ewes produced normal lambs,
the fourth ewe produced a very small lamb. Morris e_t al.
(1938) fed rats varying doses of arsenic trioxide; there were
no significant differences in the number of litters between
treated and control rats.
Rojima (1974) orally administered arsenic trioxide at 10, 50 and
100 ppm (corresponds to 0.5, 2.5, and 5 mg/kg/day) in the food
to Wister rats prior to and during gestation. This treatment
caused no significant effect on the number of litters. It must
141
-------
be noted that this study is a reproduction, not a teratogenicity
study, since effects in the unborn fetuses were not assessed.
lii. Additional Reviews Epidemiologicai Studies
Studies of pregnant women employed at the Ronnskar Smelter in
Sweden provided information with direct bearing on the issue of
human teratogenicity of inorganic arsenicals. The studies were
concerned with variations in birth weights of offspring
(Nordstrom et _al., 1978a; 1979a; Beckman _et al., 1979),
spontaneous abortions (Nordstrom e_t al., 1978b; 1979a; Beckman
et al., 1979) and congenital malformations (Nordstrom
et aJ.., 1979b; Beckman e_t _al., 1979). The Ronnskar smel-
ter produces copper (57,000 tons), lead (38,7000 tons), refined
arsenic (10,500 tons), crude arsenic (900 tons), other metals,
suituric acid (139,000 tons) and liquid sulfur dioxide (29,8000
tons) (1975 figures, Nordstrom e_t al., 1978a) . The studies
discussed here were mainly concerned with copper and arsenic
exposure.
A pilot study examined the relationship between airborne arsenic
exposure and urinary arsenic excretion among employees at the
Ronnskar smelter (Carisson, 1976). A group of employees from
various departments within the facility were tested for urinary
arsenic concentrations following respiratory exposure to ambient
air during a work day. Workers wore special collecting masks
during the work day in order to measure arsenic exposure. A
weighted 8-hour average exposure for each worker was then
142
-------
calculated. Inhalation exposure invariably was accompanied by
presence of urinary arsenic.
Birth weights among offspring of pregnant employees was compared
by employee location at the smelter (factory, laboratory or
administrative employment) (Nordstrom e_t _al., 1978). The
totals were compared with birth weights in the near-by indust-
rial population ana with birth weights in populations at a dis-
tance from smelter. Birth weights of offspring of ail employees
and in two small industrial populations close by were statisti-
cally significantly decreased from normal values. A parity
dependence was also shown, with birth weights decreased in
parous two women and above (Nordstrom ej. al., 1978b; 1979a) .
SmoKing was among parameters considered in birth weight measure-
ment. It was acknowledged that smoking during pregnancy is
associated with decreased birth weights as well as shortness of
gestation and could possibly have an additive effect in the
study discussed (Nordstrom et al., 1979a) .
Frequencies of spontaneous abortion were highest in pregnancies
where the mother was employed during pregnancy (13.9%) or had
been employed before pregnancy and was living near the smelter
(17.0%) (Nordstrom, e_t al., 1979a). The difference between
the two groups was significant (p <0.005), especially in subse-
quent pregancies (P <0.0005). In women occupied in close connec-
tion with smelting, the abortion frequency was higher than in
other employees (P
-------
than if the mother aione was employed (13.5%) . The highest
abortion frequencies were found in women who were employed
during pregnancy and in women who were employed before pregnancy
or were still living close to the smelter.
In a study of congenital malformation frequency in offspring of
female employees at Ronnskar, three groups of offspring were
examined (Nordstrom je_t _al., 1979b) . These were offspring of
parents employed after, during, or before pregnancy. Total mal-
formations, total live born and multiple malformations were
tallied. Statistically significant increases in numbers of con-
genital malformations and multiple malformations were found in
children of mothers who worked during pregnancy. The incidence
of malformations was doubled and the percent of multiple malfor-
mations was quadrupled from that of normal values. (The value
for cogenital malformation for smelter employees was 51.4%; for
normals in a hospital region the value was 28.9%. For multiple
malformations, the value for smelter employees was 19.8%. The
value for normals in a hospital regions was 4.6%.)
Data on the teratogenicity of inorganic arsenicals in humans are
limited to references from epidmiological studies of women
employees exposed to a number of toxic substances in a smelter.
Air sampling analysis of ambient air and urinanalysis of
employees indicated workers were exposed to arsenic (although
test for other sustances were not reported). Birth weights of
offspring born to women employees were significantly decreased
from those in a normal population. Decreased birth weight was
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also found among offspring of individuals who had been employed
or were still living near the smelter. In addition/ decreased
birth weight correlated with the parity of pregnancy; normally,
birth weights of subsequent offspring increase with parity. The
frequency of spontaneous abortions in women employees was
increased above normal. Values were highest for women employed
during pregnancy or employed before pregnancy and living close
to the smelter. The frequency of congenital malformtions among
progeny of female employees was twice that of other women in the
region. The frequency of multiple malformations in offspring of
female employees was four-fold higher.
It is clear that pregnant female employees employed at a smelter
demonstrated effects from exposure to toxic substances, however,
inorganic arsenicals cannot be implicated as the sole cause.
Thus, the Agency will use these epidemiologicval studies as
supporting evidence of fetotoxic and teratogenic effects and not
in the formal risk assessment.
The Agency has considered ail comments submitted in response to
this presumption and those comments are set forth below.
b. Analysis ot Specitic Rebuttal Comments
Rebuttal Comment 1; Inappropriate Koute of Exposure
(1, 2, 134)
Pennwait Corp., the Merican Wood Preservers Institute
(AWPi), and Bonide Chemical Co., express concern that, due to
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the route ot exposure, the studies listed in lable 24 of PD-1
(Summary of Studies on Inorganic Arsenic Teratogenicity in
Animals) and described in 11.4.a of this document do not support
a teratogenic or fetotoxic presumption against the inorganic
arsenicais.
'ihese rebutters state that intravenous ( iv) and intraperitoneai
(ip) injections ot arsenate and arsenite in these studies
cannot be utilized to assess teratogenic risks to humans since
the human exposure to wood preservatives and untreated wood is
either by dermal or inhalation routes.
In addition, the rebutter contends that the magnitude of
exposure to the wood preservatives is much less than the high
dose levels cited in the PD-1 studies.
Agency Response: Inorganic arsenic has been demonstrated to
be both teratogenic and fetotoxic by the oral route (Hood et
al., 1977). The results were statistically significant for
both toxic effects.
The rebutters comment regarding the magnitude ot exposure used
in the PD-1 estimates versus the level of exposure to the wood
preservatives will be discussed in the teratology and
fetotoxicity risk assessment.
The Agency agrees with the rebutters however that extrapolating
teratogenic effects produced in mice, rats, and hamsters by
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administering sublethal doses of arsenate or arsenites by t-he iv
or ip route to risk factors in humans is of limited value in a
quantitative risk assessment. In assessing the type of toxicity
that a chemical possess, the iv and ip routes of exposure are of
value as supporting evidence of teratology and fetotoxicity.
The Agency agrees to reject those studies using injected
materials in quantifying the human risk.
Rebuttal Comment 2: Acute doses of arsenate in the maternal
lethal range may present an embryolethal
hazard but not a teratogenic one (2)
The AWPl states that Hood £t al. (1977) compared the effect of
ip vs. gastric intubation (oral). Several significant points
should be noted in this work. First, the doses given were in
the subiethal range resulting in oral-dosed mice with maternal
death rates averaging 16%. This exceeds the Agency's criteria
of no more than 10% maternal deaths under these circumstances.
Second, even though the oral doses were sublethal, resorption
and embryo death rates were less than half those found in the ip
administered mice. Third, whereas the ip administered mice
shovved high rates of malformation (15-34% at 40 mg/kg and 26-63%
at 56 mg/kg), the orally administered mice showed an
insignificant malformation rate of 1-3%.
Agency Response: The Agency agrees that the Hood e_t al.
(1977) study shows greater teratogenic effects with ip injected
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mice than with orally dosed mice. However, in the Hooa e_t a_l .
(1978) study arsenate administered orally to mice caused signifi-
cant teratogenic etfects. The Agency agrees that Hood et al .
*
(1977) reported a significant maternal death rate. However
Matsumoto e_t al. (1974), who used arsenite rather than
arsenate, reported significant fetotoxicity at 10 mg/kg with no
maternal toxicity. The Agency therefore believes that the level
of maternal toxicity that occurs at arsenic doses which also
cause significant teratogenicity and fetotoxicity effects needs
to befurther investigated.
Rebuttal Comment 3: Arsenic Does Not Produce Teratogenic
Etfects (2)
The AVvPI states that Kojima (1974) investigated ttie effects on
pregnancy, birth1 lactation and growth in which adults and/or
litters were ted 10, 50, or 100 ppm of arsenic trioxide in a
series of experiments. The author concludes that the arsenic
did not produce significant differences from negative controls
in the parameters studied.
Agency Response: The Kojima study was not a teratology or
tetotoxicity study; it was a reproduction study. There was no
pre-natal examination of fetuses. Moreover, the doses Kojima
used were substantially lower than those which Hood et al.
* A further discussion of maternal toxicity appears in the risK
assessment.
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(1977) used (120 rag/Kg); these doses are equivalent to 0.5, 2.5
and 5.0 mg/kg/day, respectively.
Rebuttal Comment 4: No Significant Increases in Fetal
Malformations (2)
The AWPI rebuttal states that Matsumoto et al. (1974) adminis-
tered sodium arsenite to pregnant female mice by gavage for 3 days
at selected times during gestation at dosages of 10/ 20 and 40
mg/kg. And although the author apparently observed some fetal
malformations (teratogenicity), such malformations were not
statistically significant and were not dose-related.
Agency Response: The Agency agrees that no statistically
significant increases in fetal malformations (teratogenicity)
were reported in this study. However, fetotoxicity was evident
at all levels tested, and was expressed as reduced fetal body
weights and reduced placenta weights. At 10 mg/kg of sodium
arsenite, there was a statisically significant increase in feto-
toxicity. Therefore, since a no-effect level has not been demon-
strated in this study, based on finding fetotoxic effects at ail
levels, it may not be used to estimate risk.
Rebuttal Comment 5: No Teratogenic Effects (2)
The AWPI states that five of eight oral dosing studies in the
PD-1 found no adverse effects, including teratogenic effects,
even when trivalent arsenic was used (Schroedoer et al., 1971;
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Kimmel and Fowler, 1977b; James et al., 1966; Morris et al
., 1938; and Kojima, 1974).
Agency Response; The studies of Schroeder, Morris and Ko}ima
were reproduction studies, not teratology studies. In a tera-
tology study, the fetuses are removed from the dam and examined
prior to with, which precludes the possibility of maternal can-
nibalism or early post-natal death which could be due to
malformation. Thus, to infer lack of teratogenicity in a study
from a lack of reproductive effects on fetuses is untenable.
The Agency agrees, however, that no teratogenic events were
reported in the Kimmel and Fowler, and James reports. The doses
used were substantially lower than the oral doses used by Hood
e_t al. Being Kimmel and Fowler, 6.5 (arsenate) and 4.4
*
(arsenite) mg/kg/day , and James, 50 mg/kg/day arsenate,
respectively, as opposed to Hood e_t al. (197b), who used 120
mg/kg/day.
* The relationship between the doses used in these studies'
and arsenic exposure levels in treatment plants will be
addressed in the risK assessment.
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Rebutter Comment b: Pentavaient Arsenic is not a Teratogen
(2)
The AWPI claims that the Matsumoto e_t al. (1974) study is not
directly relevant to pentavalent arsenic wood preservatives
because trivaient sodium arsenite was used.
Agency Response: In the PD-1 both wood and non wood uses of
inorganic arsenic were presumed against. Therefore, both the
trivalent and pentavalent forms of arsenic have been presumed
against. The Agency agrees that Matsumoto study used trivalent
arsenic however, there is ample supporting evidence (see
Table 24 in PD-1 "Summary of Studies on Inorganic Arsenic Terato-
genicity in Animals") and Section ll.C.4.a of this document to
implicate pentavalent arsenic as being fetotoxic and teratogenic.
.Rebuttal Comment 7; No Teratogenic or Fetotoxic Effects from
Dermal Exposure to CCA (2)
The AWPI states that the major route of exposure is dermal, and
rabbit dermal teratology studies show that chromated copper
arsenate (CCA) treated wood, when applied to the skin of
pregnant rabbits does not produce teratogenic effects or other
injury in the offspring.
The AWPI commissioned Dr. Ronald Hood to undertake two tera-
tology studies involving dermal exposure to gravid rabbits and
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oral exposure to gravid mice. This report is submitted by AWPI
as Appendix #4, Vol. III.
In the first study Hood, (unpublished, 1979), treated gravid
rabbits with 26 grains of sawdust made from wood treated with
0.66 CCA Ib./ft. and applied it dermally as an aqueous
paste. The paste was applied on days seven through twenty of
gestation and the arsenic content in the paste was 35%. There
were a number of rabbits which failed to thrive in both treated
and control groups, but this was attributed to handling and
stressing the animals. Blood samples taken upon termination, at
29 days, contained less than 1 ppm arsenic in the CCA-treated
do rabbits. The results were negative for teratogenic and
letotoxic effects.
The level of pentavalent arsenic in treated wood is 0.66 pounds
per ft which in this experiment is equivalent to 8.56 mg of
As^Ot- kg/cubic foot of treated wood. Assuming 100% dermal
exposure, this is equivalent to a dose of 58.4 mg As-Or/kg
body weight/day.
In the second study Hood ted gravid mice diets composed of 90%
standard ration and 10% treated wood sawdust, 90% standard
ration and 10% untreated wood sawdust or 100% standard ration.
The results were negative in all groups for teratogenic or
tetotoxic effects. The dietary exposure/dose in this study was
40 mg As Oe/kg body weight/day.
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Three recent unpublished and contidentiai studies undertaken by
Peoples, and Peoples and ParKer were submitted by AWP1.
These included chromated copper arsenate (CCA) and/or ammoniacal
copper arsenate (ACA) dermal absorption, ingestion, ana excre-
tion studies in dogs. The findings in both studies were essen-
tially negative. There was no dermal absorption as measured by
the amount of arsenic excreted in urine. Virtually all of the
arsenic ingested was recovered in the urine and ieces of dogs as
methylated compounds, 90% of which were dimethylarsenic acid
(DMA). No trivalent arsenic was excreted.
Agency Response; The Agency cannot use these studies tor
risk assessment purposes since the material being tested was CCA-
treated wood particles, not inorganic arsenic per se; hence it
is not possible to make a direct comparison with the other oral
exposure studies evaluated in PD-l.
Ihe Agency agrees with AWP1 that no teratogenic or fetotoxic
signs were demonstrated at the levels tested tor dermal toxi-
city. However, there are two major routes of exposure in the
treatment plant, inhalation and dermal, and a minor route, oral.
In the studies by Peoples, and Peoples and Parker the authors
only address the dermal component of the risk.
The Agency concludes that the above considerations support the
Kebutter1s contention that dermal exposure to CCa-treated
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sawdust will not produce harmful effects in offspring. No
conclusion however can be drawn concerning the effects of oral
and inhalation exposure on teratogenic and fetotoxic events.
Rebuttal Comment 8; Arsenical wood preservatives are fixed
in the wood (2)
The AWPI claims that the absence of arsenic in blood of rabbits
(see comment 7 above) confirms that arsenical wood preservatives
are fixed in wood in a highly insoluble state that allows little
or no dermal absorption.
Agency Response; The study (Hood unpublished 1979) by itself
does not support the rebutter's conclusion. The blood samples
cited were taken on day 29, at termination of the experiment.
However, exposure had ceased on day 20. This could provide
ample time for any arsenic that might have been absorbed across
the skin to be metabolized or excreted from the body.
Rebuttal Comment 9: Lack of Epidemiological Evidence (188)
fooolfolk Chemical Works, Inc., states that mutagenic and repro-
ductive risks to humans are theoretical risks demonstrated only
in laboratory animals. No study, to the rebutter's Knowledge,
has indicated any suspicious effects of the arsenical pesticides
to humans from a mutagenic or reproductive standpoint in more
than 50 years of use.
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Agency Response; The presence of a valid epidemiological
study is always helpful, but does not remove the Agency's
concern that for any demonstrated teratogenicity and fetotox-
icity in animals there exists an adequate margin of safety
between the exposure level of a human population and the dosage
level producing significant adverse effects in the young of
treated animals.
Further, in this section, and in the teratogenicity and fetotox-
icity and mutagenicity, risk assessments contained in Section
ll.C.b of this document, epidemioiogical evidence is presented
that indicates that arsenic causes teratogenic, fetotoxic, and
mutagenic effects in humans. This evidence was not presented in
the PD-i. Therefore it is summarized here, and further dis-
cussed in the risk assessment portion of this document.
Lpidemiologicai studies of the Ronskar smelter in Sweden shows
that the arsenic from the smelter caused decreased birth
weights, spontaneous abortions, and congenital malformations
(teratogenicity) in exposed humans (Nordstrom et jtl., 1978a;
1978b; 1979^; 1979b; BecKman e_t al. , 1979; Carlson e_t al. ,
1976). Persons working and/or living near the smelter showed
stastically significant increaces of fetotoxic and teratogenic
effects and nad significant elevated urinary arsenic levels,
which were related to their inhalation exposure doses as mea-
sured by collecting masks. Although it is clear that pregnant
female smelter employees experienced significant teratogenic and
155
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fetotoxic effects, arsenic cannot be indicated as the sole cause
of the observed effects in these epidemiological studies.
Rebuttal Comment 1U: Relative Toxicity (120, 134, 213 )
Bonide Chemical Co., Prof. R. D. Hood, and Texas A & M University
state that in most ot the reproduction and tetotoxicity studies
undertaken with inorganic arsenicais, the dosage levels utilized
in mammalian systems have shown that arsenic at very high
*
dosages, approaching the LD-5U tor the individual species
has proven to be fetotoxic. For example, the study ot Hood
et al. (1977), showed that administration of as much as 120 mg
sodium arsenate per kg was necessary before teratogenic effects
were observed. The author notes that an equivalent dose
(7.2 gms) for a 60 kg woman would be lethal long before terato-
genic effects would be induced. Further, the rebutters em-
phasize that any toxic or infectious disease condition induced
in a pregnant female, during certain susceptible periods ot
pregnancy, will cause either fetal toxicity, fetal death or
malformations resulting from cytotoxic effects rather than
teratogenic effects.
Agency Response: The Hood £j. jaj.. (1977) study reported
significant maternal deaths at the arsenate dose level that
caused the reported significant fetotoxiic aand teratogenic
* Available LD5Q data is summarized on Table 11 C-ll of this
document.
156
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effects, however, the Matsumoto et al. (1974) study reported
significant fetotoxic effects for arsenite doses of 10 mg/kg
with no reported maternal toxicity. The Agency therefore
believes that the level of maternal toxicity that occurs at
arsenic dosages which cause teratogenic and fetotoxiic effects
need to be further defined.
In addition, there is a significant amount of evidence that
indicates that humans are more sensitive to the toxic effects of
*
arsenic than are rodents .
Rebuttal Comment 11; Beneficial Effects (2, 133, 134 )
AWPI, F.H. Nielsen Ph.D., and Bonide Chemical Co., state that
arsenic is an essential element to the human body e.g., for
n?-. e impulse transmission and the structure of keratin
tissues. The rebutters submitted summaries of studies reporting
the beneficial effects of arsenic in humans and animals.
Agency Response; The fact that a substance is reportedly
beneficial in certain forms or quantities does not directly
effect the hazard from any reported adverse effects which may
pertain to other chemical forms or different concentration
ranges. The Agency is concerned that a sufficient margin of
safety exists (or that an acceptable risk pertain) with respect
* See the Agency Response to rebuttal comment 1, in Section
II.C.5 of this document.
157
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to the level of human exposure relative to the exposure level
producing adverse effects of the material in either animals or
man.
Rebuttal Comment 12: No Teratology Effects Observed from
Oral Administration of Arsenic (1)
Pennwalt Corp., states that no teratogenesis was reported at any
dose level by oral administration of inorganic arsenic. The
comment states that the data of Hood e_t al. (1977), in which
pregnant rats were aa>-~: nistered sodium arsenate by gavage showed
no increase in fetal i&al format ions up to a dose of 100 mg/kg.
In the opinion of the rebutter, even at the highest dose
(120 mg/kg) the data showed no statistically significant
differences compared to natural malformation rates.
Agency Response: The Agency disagrees with the rebutter as
Hood e_t a 1. '1978) observed that 120 mg/kg of arsenate
administered orally to mice significantly increased skeletal
defects and prenatal mortality in the litters.
c. Summary of Rebuttal Comments Concening Fetotoxic and
Teratogenic Effects: Conclusion
Twelve of the studies used by the Agency in the PD-1 presumption
against inorganic arsenical wood preservatives will not be
considered in the risk assessment because the intravenous and
intraperitioneal routes of administration are considered by the
158
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Agency as inappropriate for human exposure. These studies,
however, are still considered to be supportive of the teratology
and fetotoxic presumption. Three of the PD-1 studies will also
not be considered in the risk assessment as the species used was
avian, not mammalian and therefore not relavent to human hazard
evaluation. The Hood ^t al. (1977) study showed unrebutted
evidence of the teratogenicity of inorganic arsenic. Matsumoto
et jil.(1974) reported fetotoxic effects at an arsenic dose of
10 mg/kg in the mouse.
Further, epidemiological studies showed that human exposure at
an arsenic smelter resulted in fetotoxic and teratogenic effects
to the exposed persons.
In summary, the Agency concludes that the risk criteria for tera-
togenicity and fetotoxicity of inorganic arsenicals remains unre-
butted. That is, there is evidence of teratogenic and fetotoxic
effects which remain unrebutted. The issue of how these effects
relate to exposure and hence the thresholds for these effects
(the NOEL) will be addressed in the teratology and fetotoxicity
risk assessment portion of this document.
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5. Other Health and Environmental Concerns: Delayed
Neurotoxicity
a. Basis of Concern
i. Introduction
In PD-1 three studies indicated possible delayed neurotoxic
effects from exposure to the inorganic arsenical compounds.
However, there was and still is insufficient evidence to
initiate an RPAR on the basis of delayed neurotoxicity.
ii. Summary of Studies
ihe first study (Landau e_t al., 1977) attempted to relate
arsenic exposure of workers in a coppe.r smelter to neurological
changes as compared to groups of aluminum smelter and non-
industrial workers. In addition to arsenic, the copper smelter
workers were, also exposed to increased levels of lead, copper,
nickel, zinc as well as numerous other chemicals. The Agency
believes that a similar correlation could have been found tor
lead, copper, cadmium, nickel, as well as for arsenic. The
cause effect relationship in this study is therefore uncertain.
The second study, (Mizuta e_t _al., 1956) reported on 220
patients poisoned by ingestion of roughly 3 mg of arsenic
(probably calcium arsenate in arsenic-contaminated soy sauce)
daily for 2 to 3 weeks. Twenty % of the patients were found to
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have peripheral neuropathy. The patients' other symptoms tended
to diminish after 5 or 6 days despite continued intake of
arsenic; however, neurologic symptoms became prominent as long
as 2 weeks after arsenic ingestion was discontinued. Arsenic
content of urine and hair also remained high.
The third study, Ohira and Aoyama (1973), was an epidemioiogical
study on Japanese babies that drank arsenic-tainted milk. The
authors found that the exposed group had statistically signifi-
cant higher rates of many physical and medical problems when
compared to the two control groups. The victims had lower
intelligence quotients, a higher rate of severe retardation, a
higher prevalence of myopia, abnormal EEC findings, a higher
rate of decayed, missing, or filled teeth, and abnormal x-ray
findings in facial shape. The authors concluded that the
victims were still suffering from many physical and mental
disorders after 17 years.
iii. Additional Reviews
These reviews come almost entirely from clinical reports
resulting from homocidal or accidental injection of arsenic
compounds, non-pesticidal contamination of food, or use of
medication. in these reviews usually the amounts of arsenic
injested or absorbed as well as controls are lacking. In
addition, insufficient data presently exist to allow for
characterization of quantitative dose/response relationships.
161
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Arsenic effects on the peripheral nervous system have been
reported by Reynolds (1901); Silver and Wainman (1952); Mizuta
ejt al. (1956); Heyman e_t al. (1956); Jenkins, (1966); Kara
e_t al. (1968); Chhuttani ejt al. (1967); Ishinishi et al.
(1973); Nakamura £t al. (1973); Nagamatsu and Igata (1975);
O' Shaughness and Kraft (1976); Frank (1976); Garb and Hine
(1977); LeQuesne and McLeod (1977); and are now recognized as
classic clinical symptoms of arsenic poisoning. These symptoms
usually become manifest within one to two weeks post ingestion.
Recovery is slow, ordinarily starting between one and two months
from the onset of symptoms, and the degree of recovery depends
on the severity of the symptoms. Such symptoms include peri-
pheral sensory effects characterized by the appearance of numb-
ness, tingling, or "pins and needles" sensations in the hands
and feet, as well as decreases in touch, pain, and temperature
sensations in a symmetrical "stocking glove" distribution.
These symptoms are often variously accompanied by burning
sensations, sharp or shooting pains, and marked muscle tender-
ness in the extremities. Peripheral neuritis symptoms originate
distally and, over the course of a few weeks, often progres-
sively become more widespread in both lower and upper extremi-
ties, usually appearing first in the feet and later in the hands.
There are two case reports on cutaneous absorption of arsenic
resulting in peripheral neuropathy of the sensimotor type,
tobinson (1975); Garb and Hine (1977). In the latter case
visual symptoms also appeared. This source of arsenic in the
first case was topical application of a caustic paste in which
162
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the form of arsenic was not specified. The other case involved
a worker, who was splashed with arsenic acid in an industrial
accident.
There are few long-term animal feeding studies and those which
are available have limited value for determining neurotoxi-
city. For example, beagle dogs in groups oi 6 were ted diets
containing sodium arsenate or sodium arsenite for two years
(Byron e_t al., 1967). At concentrations of 50 ppm and less no
difference from controls were detected. Unfortunately no histo-
pathology of the nervous system was reported. In these studies
results are generally unsatisfactory in regard to estimating
dosage parameters associated with the arsenic induction of peri-
pheral neuropathies from reports of human exposures. It is
usually not possible to determine the precise dose involved or,
in many cases, the period of exposure.
For subacute or chronic poisoning situations, information has
been provided in only a few studies by which effective- exposure
parameters can be estimated (see Mizuta e_t _aj.., 1956, Part
11.5.a)
Tay and Seath (1975) examined 74 patients who had taken anti-
asthmatic herbal preparations containing up to 107 g/kg inor-
ganic arsenic. The recommended daily dosage resulted in an
intake of 3.3 mg for patients who took one kind of pill which
contained arsenic trioxide, and 10.3 mg for patients who took
another type, which contained arsenic suifide. Arsenic levels
163
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in hair were over 1 mg/kg in 45% of the patients. Cutaneous
manifestations of arsenic contamination were found in 92% of the
patients. Over half of the patients presented neurological
complications, the most common being sensimotor polyneuropathy.
The significance of the findings cannot be evaluated, as no
control group was reported.
Silver and Wainman (1952) described a patient that had ingested
approximately 8.8 mg of arsenic trioxide daily for 28 months as
an asthma treatment. Signs of peripheral neuropathy appeared at
about 2 years, well after the onset of other arsenic-related
effects, e.g., skin changes. Assuming regular ingestion of the
arsenical each day for two years, the neuropathy effects would
appear to be associated with the gradual exposure to a maximum
total dose of up to 650 mg or so of arsenic.
Persistent neurotoxic central nervous system effects in babies
have been reported as well as indications of nervous system
damage in a laboratory animal fetus.
The Moringa milk poisoning incident occurred in 1955-1956. This
resulted in an outbreak of arsenic toxicosis in Japan and was
the result of infants having consumed powered milk contaminated
with As203 at concentrations of 25-29 ppm. A total of
12,083 cases of poisoning were reported with 128 deaths. The
arsenic was introduced into the dried milk as a contaminant of a
sodium phosphate stabilizer.
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Epidemiological follow-up studies, undertaken several years
after the Morinaga milk poisoning incident, have been reported
(Yamashita e_t al., 1972; Ohira and Aoyama, 1972). They
purport to show statistically significant evidence for the
persistence of residual inner ear hearing loss and also sight
impairment. These findings were further supported by the
following animal studies.
Westernhagen (1970) reported pathological and histochemical
changes in the inner ear of guinea pigs exposed to arsenic tri-
oxide ctt 1 mg/kg dose level for 28 days. Effects on the ear
were also reported by Aly e_t al. (1975) in experimental
animals treated with inorganic arsenic. Destruction of the
^
organ of Corti and loss of Reissemer's membrane, causing deaf-
ness, were observed in guinea pigs given sodium arsenate intra-
peritioneally for two months (Aly e_t _a_l., 1975). The dose
reported was 0.2 mg sodium arsenate for each kg of body weight
without closer specifiction. Further investigations by Aly
et al. (1975) gave evidence of diminished acetyi cholinester-
ase activity in the temporal lobe and decreased blood cholineste-
rase levels in the exposed animals.
Choiinesterase inhibition was also observed in rats exposed tor
three months to arsenic trioxide in the form of condensation
aerosols containing 46 ug/m arsenic (Rosenshtein, 1970). Dis-
turbances in the functional state of the central nervous system,
measured as conditioned reflexes and chronaximetry, were evi-
dent. Histopathologicai changes in the brain included pericel-
165
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luiar eaema, plasmatic impregnation of the vascular walls,
neuron piasmolysis and karyolysis. Several of the effects men-
tioned, although less marked, were also observed in a group of
cats exposed to an aerosol containing 3.7 ug/m arsenic.
Osato (1977) gave suckling rats 2 and 10 mg of arsenic trioxide
through a stomach tube tor 40 days. The central nervous system
was affected as indicated by a significantly poorer performance
in the avoidance conditioning test in both groups of exposed
animals. No particular histo-pathological brain changes of note
could be found in these animals.
Perm and Carpenter (19fa8) have reported a high incidence of
exencephaly in golden hamster embryos of mothers given a 20
mg/kg intravenous dose of sodium arsenate on day 8 of gesta-
tion. Perm e_t al. (1971) have subsequently demonstrated that
these anomalies and high incidence of fetal resportions were
dependent on the time of injection during critical stages of
embryogenesis. Exenceohaly and many other malformations have
been reported in offspring of mice given intraperitoneal
injections of arsenate (25 mg/kg) during gestation (Hood and
Bishop, 1972) .
The above studies indicate that there is sufficient reason to
believe that the very young may be more susceptible to central
nervous system damage from arsenic exposure than are adults.
b. Analysis of Specific Rebuttal Comments
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Rebuttal Comment 1; No Evidence of Neurotoxicity (1)
Pennwalt Corporation states that the studies referred to in
the PD-1 contribute nothing significant to whether the
registration of arsenic acid should be continued.
Agency Response; The Agency agrees with the rebutter
(Pennwalt) that the three studies described in PD-1 do not
present an adequate basis for a rebuttable presumption against
the inorganic arsenical pesticides on the basis of delayed
neurotoxicity. The additional delayed neurotoxicity studies
discussed in this document are also not sufficient to support a
rebuttable presumption against arsenic on this basis. The
available studies and other information do not provide adequate
data to define a no-observable-effect level (NOEL) for delayed
neurotoxicity in the species tested or in man. In most of the
experimental studies, the rat was chosen as the test animal,
even though this species is quite insensitive to the effects of
arsenic because of its metabolic treatment of the chemical.
Specifically, the metabolism of arsenic in the rat is unique
because rat hemoglobin has a high affinity for arsenic. This
affinity results in a low rate of distribution of arsenic in the
tissues and hence a high arsenic tolerance. Other problems in
the available data (e.g., the imprecise determination of dose
levels) limit the usefulness and suitability of this information
for predicting the delayed neurotoxicity potential of arsenic in
man. However, particularly in view of the low sensitivity of
the rat, the Agency still retains a concern that arsenic may
167
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have the potential to produce delayed neurotoxic effects in
humans.
c. Summary of Rebuttal comments Concerning Neurotoxic Effects
Conclusion
In conclusion, the Agency has determined that from the above
reviews which represent the currently available information on
arsenic induced neurotoxic effects, insufficient data exist to
allow for characterization of a quantitative human dose/effect
relationship.
Further, there is not sufficient evidence for considering the
use of arsenic in wood preservatives to be an unreasonable
neurotoxic hazard. The Agency has determined that with the
available data, the potential of arsenic to cause delayed
neurotoxic effects cannot be estimated for either adults or
young children.
fa Analysis of Rebuttal Comments About Human Exposure
a. Basis of Analysis
'ihis analysis is based on comments made to rebut the October
1^78 Notice of Rebuttable Presumption and on other information
received since then. In general, these consisted of usually
brief comments from farmers, state agency and industry repre-
sentatives or individuals who have past or present interest in
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the use of inorganic arsenic as a wood preservative. Although
these comments were not usually scientific in nature, they are
welcome as a broad indication of experience with inorganic
arsenic. The majority of views indicated few problems from the
use of inorganic arsenic compounds. However, the chronic
effects, such as cancer, would not likely be observed by these
individuals. Since the nonwood uses of the inorganic arsenical
compounds will be considered in another document, this analysis
covers only those rebuttal comments regarding exposure from the
wood preservative uses of arsenic.
The Agency reviewed a total of 229 rebuttal comments concerning
exposure. Of these, 216 provided subjective information in
support of the continued registration of the inorganic arseni-
cal compounds. The remaining thirteen comments provided
specific information and scientific evidence that attempts to
show these compounds either are or are not a hazard to human
health. One of the thirteen comments, one contended that the
Agency underestimated arsenic residues on treated wood and air
concentrations in treatment plants. No comments were directed
to dietary arsenic exposure from wood treated with the
inorganic arsenical compounds.
169
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b. Analysis of Specific Rebuttal Comments
Rebuttal Comment 1; Arsenic in Nature (10, 38, 50, 52, 60,
61, 75, 90, 97, 111, 113, 124, 121,
122, 123, 124, 132, 135, 145, 185, 187,
191, 203, 223-7)
A number of rebutters stated that arsenic is ubiquitous in
nature and does not biomagnify; therefore, the exposure of the
public to wood treated with inorganic arsenical compounds does
not pose a public health problem.
Agency Response; While it is true that arsenic is ubiquitous
in the environment, biomagnification only concerns exposure
through the food chains. Levels of, this element in the air of
wood treatment plants, wood treatment solutions and in treated
wood far exceed natural background levels. In addition these
natural background levels of arsenic include both organic and
inorganic arsenic. Organic and inorganic arsenic compounds
have different metabolic pathways and different human health
effects, (Underwood, 1971; Frost, 1970).
Rebuttal Comment 2: Lack of Health Effects in Wood Treatment
Workers (10, 38, 50, 52, 60, 61, 76, 90,
97, 111, 113, 120-4, 132, 135, 145,
185, 187, 191, 203, 223-7)
A number of rebutters claim that employees handling chromated
170
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copper arsenate (CCA) solutions and treated wood products have
considerably higher exposure to arsenic than the general
public. Nevertheless, these rebutters report no instances of
employee sickness or ill-health due to handling .these materials
and that no customer complaints have been received. Several
respondents indicate that these observations cover several
decades of wood treatment activities. A number of industrial
health or medical surveys or both have been conducted within
several treatment plants .
A survey of 76 utility companies indicates only one report of
skin irritation due to contact with arsenic-treated poles. No
customer complaints were noted. One utility company which has
used both CCA and ammoniacal copper arsenate (ACA) treated
poles since 1954, reports no cases of oncogenic or mutagenic
effects of handling these products by their employees.
Agency Response; The rebutters claim no cases of employee
sickness and that no consumer complaints have been received.
This is a subjective statement not documented by studies and
does not take into account possible chronic exposure effects.
therefore the Agency rejects this comment.
Rebuttal Comment 3: Identity of Compounds of Concern (2)
AWP1 states that tables 13 and 14 (PD-1, pp. 108-109) are in
error; the arsenic in Table 13 should be listed as As^O,-
(arsenic pentoxide) and in Table 14 for ACA, the As-O
171
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(arsenic trioxide) should be listed as As-Oc* This error
implies the use of trivalent arsenic in the listed wood
preservatives whereas it should be pentavalent arsenic.
Agency Response. The Agency agrees with the rebutter.
Labels frequently express arsenic as the common oxide. This
does not mean, nor did the PD-1 intend to mean, that all the
arsenic in the wood preservative products is trivalent.
However the Agency recognizes that trivalent arsenic arsenic is
occasionally used in ACA formulation that are mixed on site.
Daring the mixing process the trivalent arsenic is oxidized to
pentavalent arsenic.
Rebuttal Comment 4&; Arsenic is Fixed in Wood - Fixation
(2, 10, 38, 50, 52, 60-1, 76, 87, 90,
97, 111, 113, 120-4, 125, 132, 145,
185,87, 191, 203, 223-7)
A number of rebutters contend that when wood is properly
treated, the arsenicals form an insoluble bond with chemicals
in the wood and, therefore, interact minimally with the
environment.
The American Wood Preservers Institute (AWPI) and others claim
that arsenical wood preservative chemicals, once the treated
wood has undergone fixation, are in a highly stable, insoluble
form that resists leaching. AWPI points out that these
chemicals present unique exposure situations and that the
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Occupational Safety and Health Administration (OSHA) exempted.
treated wood from its final arsenic wor*. standard (29 CFR
1910.1018). AWP1 claims that even though the fixation process
is complex and the fixative used (chromic acid or alkali meta'l
dichromate) determines the reactions involved, highly insoluble
arsenate compounds are precipitated in the wood. The fixation
process is detailed for CCA solutions in both AWP1 Vol. I
(p. 230-234) and Vol. Ill (p. 146-149), the latter being
referenced in PD-1. This fixation phenomenon is presented and
documented by AWPI (Vol. 1, ret. 363 and 407; Vol. Ill, ref. 1
and 245).
Agency Response; The Agency agrees with the rebutter that
OSHA did indeed exempt treated wood from its "final work
standard." However, it must be noted that the treated wood was
not exempted on the basis of arsenic exposure concerns but
rather that the wood is treated with a pesticide and treating
wood is a pesticide application process and therefore covered
under FlFRA.
in actciititon, though arsenicals are said to be fixed in
treated wood, leaching tests indicate the arsenical salts can
be leached from the wood; surface residues as high as 24 mg
As/ft (PD-1, Table 21) have been measured for ACA-treated
wood .
The fixation detail presented by AWPI, however, is sketchy, for
ACA ana fluor chrome arsenic phenol (FCAP) solutions.
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Additional data on the fixation of ACA solutions in wood were
submitted by another rebutter (California Department of Health
Services, #212). They found ACA surface residues of 2.7 to
23.1 mg/ft versus 4.5 to 7.5 mg/ft for CCA-treated wood
indicating generally greater loss from the former. This indi-
cates ACA fixation is not as durable as CCA; however, both for-
mulations leach from the wood. The Agency continues to believe
that dermal exposure to either ACA-and-CCA treated wood is a
problem because these values submitted by the California
Department of Health Services are higher than those reported
earlier (PD-1, Table 17). Even though fixation does occur, it
is apparent that surface residues exist and subsequent
leaching, as well as blooming (post treatment migration of
formulation to the surface) of the salts, can provide available
arsenic for dermal exposure.
The review of the complexity of the fixation process and the
reactions involved does show that the products are generally
insoluble, and become physically bound or occluded to wood
components; however, in-service durability reports indicate
that slow leaching from wood products always occurs. Thus,
although AWPI claims fixation holds the arsenic in the wood,
leaching and dermal exposure to suface residues is not pre-
cluded even though most of the arsenic may be fixed chemically
or physically.
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Rebuttal Comment 4b; Arsenic is Fixed in Wood Leaching Tests
(2)
AWPI contends that the Working Group misunderstands the leach-
resistant character of treated wood and the significance of
accelerated leaching tests (AWPI, Vol. 1, pp. 234-239).
AWPI (Vol. Ill, p. 149-151,), objects to the use of accelerated
leaching tests to compare different preservative systems to
indicate the relative efficiency of the fixation mechanism.
AWPI claims that such accelerated leaching tests are not appro-
priate in attempts to extrapolate such short-term data to in-
service products for human exposure.
AWPI (Vol. I, p. 234-239 and Vol. Ill, p. 149-151) claims that
reports by Arsenault (1975), Lumsden (.1964) and Gjovik and
Davidson (1973), which report data from in-service tests, are a
more appropriate measure to compare the fixation of arsenical
preservative systems. Reports by Fahlstrom e_t al. (1967)
and Henry and Jeroski (1967), (cited in AWPI, Vol 1 and III)
indicate the leach resistance of the various preservatives to
be CCA-A and B> CCA Type C> ACA and FCAP .
Agency Response: Accelerated leaching tests measure the
amount of arsenic leached from the treated wood as a result of
* Type A, B, and C refer to the relative amounts of arsenic
chromimum and copper in the CCA formulations.
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repetitive rinsing of the wood with water. The Agency agrees
with the rebutter that use of accelerated leaching tests is an
atypical situation for measuring dermal exposure. Therefore
the Agency has only used the accelerated leaching measurements
for the flooded basement condition discussed under Rebuttal
Comment 4c. The Agency used 0.529 mg/ft of arsenic for its
estimated arsenic surface residue level which could be removed
by a hand, (Dreher 1974). The rebutter's comments are
therefore not applicable to this issue.
Rebuttal Comment 4c; Arsenic is Fixed in Wood - Flood
Leaching from All Weather Wood
Foundations (AWWF)(2)
The rebutter, AWP1, claims that all weather wood foundations
stay dry even during adverse weather conditions and that the
Agency overestimated the amount of arsenic per square foot that
could be leached from the basement's wall surfaces. Also, the
rebutter objects to conditions in which a basement would be
flooded for 7 days, and calls the Agency's example of leaching
after 28 days of flooding "unrealistic."
Agency Response; Although dermal contact with arsenic
leached as a result of basement flooding is infrequent, base-
ment flooding is a potential route of exposure. The Agency
rejects AWPI's claim that surface arsenic levels after flooding
would be 5.67 mg/ft2. Data from the California Department
176
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Health Services rebuttal submission |212 shows that treated *
wood, even without leaching, can have a surface residue ot up
2
to 4.5 mg/ft of arsenic. The value used by the Agency in
PD-1 Table 21 (summary of tables 17 & 18, the amount of arsenic
in splinters, on the surface of treated wood, and the amount of
2
drsenic which can be leached by water) ot 43.2 mg/ft is the
lowest value listed in Table 21. This value of arsenic leached
from the wood is not therefore in the Agency's opinion, unrea-
sonable. Contrary to claims of fixation, it has been shown, as
noted in Table 21, that arsenic is leached and is not perman-
2
entiy bound in treated wood. The use of 5.67 mg/ft of
arsenic removed from scrubbing the treated wood totally
neglects the effects of osmotic pressure which will cause salts
to leach into surrounding waters. Thus the Agency rejects the
rebutter1s comments and the exposure estimate will not be
changed. The Agency does agree, however, that the 28-day
flooding estimate is unreasonable and this estimate will be
deleted.
Rebuttal Comment 5a; Surface Levels and Dermal Exposure
The California Department of Health Services claims that
surface residues of arsenic have been underestimated. The
data supplied by California show total arsenic surface levels
from ACA treated wood ot 2.7 to 23.1 mg/ft2; in fact one
sample reported by the rebutter was 90 mg/ft . CCA treated
2
wood showed residues of 0.76 to 4.5 mg/ft . These values
are considerably higher than the Agency's estimate of
177
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U.529 mg/tt tor CCA treated wood. It appears that surface
residues vary with treatment.
Agency Response; The Agency concludes that the data supplied
by the Caiifornia Department ot Heaith Services are valid. The
higher residue levels (CCA 4.5 mg/tt ; ACA 23.1 mg/tt )
will be used to estimate dermal exposure.
Rebuttaj. Comment 5b; Dermal Exposure - Lack of Dermal
Absorption (2)
AWP1 contends, based on the work of Hood jet al. (1977), (see
AVvPl, Vol. 1 pp. 223-225), that the PD-i dermal exposure
should be negligible since Hood found essentially no arsenic
absorption from CCA-treated sawdust applied, as a paste, to
rabbit sKin. This was confirmed by ah independent laboratory
analysis of rabbit blood which showed levels of less than 1 ppm
of arsenic for both treatment and control animals; one rabbit
haa 2 ppm ot arsenic in its blood (AWPI, Vol 11, Appendix 6).
hood's study (1977) indicated that arsenic-treated wood was not
a skin irritant, nor was there absorption of arsenic.
Agency Response; The rebuttal comment is rejected because
irritation ot the skin has occurred in common practice with
arsenic-treated wood (California Dept. Health Services). The
Agency assumes that irritation may be evidence of skin pene-
tration. Further, the low levels of arsenic in the rabbits
blood does not support the rebutters conclusion. The blood
178
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samples were taken nine days after the asenic exposure had
ceased. This could provide ample time lor any arsenic that
might have been absorbed across the skin to be metabolized out
of the body.
Rebuttal Comment 5c: Dermal Exposure - Short Duration of
Dermal Contact (2)
AWPI (Vol. I, p. 15) contends that, although wetting a worker's
hands with wood preservative solution is not impossible, it is
unreasonable to assume that the worker will fail to wash his or
her hands long before any significant amount of the relatively
dilute brush-on arsenical solution is absorbed (AfcvPi, Vol. 1,
p. 240). Such exposure would be negligible, due to work place
practices (AWP1).
Agency Response: The PD-1 (p. 121) used 20 mi of apreser-
vative solution applied to both hands as the highest estimate
of dermal exposure for intermittent application of arsenicais
to wood, with 10% being absorbed. Because of a study by Dow
*
(Vveaver, 1978) , the Agency believes that 6 ml of solution is
required to wet both hands and should be used in place of 20
ml. The Agency will also revise the 10% dermal absorption of
* It should be noted that this study was done on a woman's
hand. Using 6 ml is, therefore, consistant with using the
woman's 60 kg body weight.
179
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liquids to 0.1% per Dutkiewicz, (Experimental studies on
arsenic absorption routes in rats 1977). Furthermore, the
Agency will revise the value of 10% dermal absorption for dry
dusts to 0.01%. This is based on an extrapolation from the
Dutkiewicz study on the absorption of aquaeous arsenic
solutions.
Rebuttal Comment 6a; Respiratory and Related Exposures -
Air Levels (212)
The California Department of Health Services provides data
showing air levels around a wood preservative mixing site of
1.02 mg/m arsenic. The TWA (time weighted average; from
this data for arsenic in the air is 0.043 to 0.07 mg/m .
The rebutter contends that the exposure is continuous rather
than of short duration because samples were taken 12 feet from
the mixing site.
Agency Response: The Agency agrees that the in-plant levels
(up to 0.07 mg/m ) should be used uniformly to estimate
background inhalation exposure in large industrial situations.
Activities which have higher inhalation exposures will use
arsenic levels specific to the situation.
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Rebuttal Comments bb: Respiratory and Related Exposures -
Breathing Rates (2)
AfoPi claims the breathing rate used" in PD-1 (1.8m /hr) tot-
heavy worK is too high. They cite Altman (1958), who used a
breathing rate ot 0.98 m /inc. lor light to moderate work and
1.47 m /hr. for heavy worjc.
Agency Response: The Agency agrees with the rebutter1s
comment because it is based on measured values. The Agency
will revise its breathing rate estimate to 1.47 m /hr tor
heavy work, and to U.98 m /hr lor light to moderate work and
0.27 m^/hr lor a resting breathing rate per Altman (1958) in
the exposure analysis. These estimates are only for women.
breathing rates for women are being used because inorganic
arsenic compounds have teratology and fetotoxicity concerns.
It should be noted however that in the exposure analysis, a
lower breathing rate and less body weight result in less than
10% difference in arsenic exposure between women and men.
Rebuttal Comment 6c; Respiratory and Related Exposures -
intestinal Absorption ot Nonrespirable
Particles (2)
AWP1 claims that the Agency erred in its initial assumption
that arsenic in particles of wood that pass into the gastro
intestinal (Gi) tract will be absorbed to the extent of 75%.
They cite Peoples (1977) who found that only 40% of arsenic
181
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fixed in CCA-treated sawdust was absorbed, since 60% of the
pentavient arsenic fed to the dogs was excreted in the urine.
Agency Response: The Agency will change its estimate of GI
tract absorption from 75% to 40% because the 40% is based on a
documented study and the 75% was an assumption. This is true
however, only for large particles such as sawdust. The origi-
nal estimates for small particles remains unchanged. Small
particles and vapors reach the deep parts of the lung where
they are absorbed into the blood or lymph and are subsequently
translocated to the other parts of the body. Small particles
can stay suspended in inspired air and are subsequently
exhaled. The percent absorption may range from 10 to 100% of
the amount inhaled. The larger particles (those greater than
10 microns in diameter) are either filtered out by the tur-
binates in the nose or are deposited in the pharynx, trachea,
or larger bronchi. Material deposited in these places is
removed by ciliary action and the material is gradually moved
to the back of the mouth where it is swallowed or spit out. if
it is swallowed, oral exposure occurs in addition to inhalation
exposure.
Rebuttal Comment 6d; Respiratory and Related Exposures -
Inhalation of Arsenic in Wood Particles
U)
The AWP1 comments that PD-1 assumes 1), a router operation
(furrowing and gouging out of wood) presents the same exposure
182
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as any other mechanical cutting operation and, that 2), the
test datt» (PD-i p. 123, Table 1) only establishes 50% of the
potential exposure. Both o£ the above assumptions are
erroneous.
The saving operations data (p. 249, Vol., 1. AVvPl Rebuttal) are
the only realistic and reasonable method to calculate potential
exposure lor making a risk/exposure analysis and subsequent
regulatory decision.
Also, PD-1 incorrectly assumes that 25% of the airborne
particles will be respirable and that 100% of the arsenic
reaching the lung will be absorbed, (Dinman, 1978).
Agency Response; The example in PD-i stated the initial
assumptions for estimating exposure from saving and handling
wood. Using a router, according to the rebutter, is unlikely.
Although wood used for outdoor signs or other outdoor wood uses
may be treated and a router used on these materials, the Agency
recognizes this is not typical of sawing operations. The
Agency also agrees with the rebutter that doubling the wood
particles in the air due to router operations is without
merit.
Furthermore the Agency agrees with the rebutter that sawing
operations should be used to calculate exposure to arsenic-
treated wood, but will use the highest value (0.36 mg/m )
from sawing operations as shown in PD-1 (page 123) Table 16;
183
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(arsenic concentrations in air during cutting and building
operations) for exposure calculation resulting from electric
saw cutting of plywood. The rebutter supplied information
(AWPI Vol. Ill, 236) that only 5.3% of the arsenic-containing
dust from sawing operations was respirable and assumed that a
value of 10% would account for possible variations. The Agency
agrees with this approach at this time and will use a 10%
respirable rate for arsenic-containing particles resulting from
sawing.
The Agency disagrees with the rebutter's claim that only 40% of
the respirable traction will be available for lung absorption.
The work of Dinman (1978) was based on a calculation of dead
space volume in the lungs and does not take into account nasal
passages or turbulent mixing in the respiratory system. The
Agency will continue to use 100% absorption until evidence to
the contrary is presented.
Rebuttal Response 6e; Respiratory and Related Exposures -
Invalid Reliance on "Worst Case"
Assumptions (2)
The AWPI contends that the PD-1 grossly exaggerated the level
of exposure that could reasonably be anticipated on a "worst
case" basis. As a result of the high exposure estimates, PD-1
severely underestimated the true margin of safety.
184
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AWPI claims that inhalation exposure is lower than that
estimated by the Agency in PD-1. In addition negligible
dermal exposure occurs in large scale treating plants. One
of the basic ditferences is the Agency's use of an arsenic air
concentration of 0.22 mg/m , the highest value observed by
Arsenault (1976), as a maximum exposure level for a plywood
stacker. This value, AWPI states, is clearly high when
compared with other similar exposure situations, i.e.,
0.002 mg/m for stacking lumber versus the 0.22 mg/m for
stacking plywood used by the Agency. Additional information
in the same set of data shows a concentration of 0.01 mg/m
for stacking plywood. AWPI points out that a plywood stacker
iiad a urinary excretion level of 94 mg/liter of arsenic. Pinto
e_t al. (197b) found by experiment that the inhaled airborne
arsenic level in ug/m was equal to 0.304 times the urinary
arsenic level in mg/liter. Calculating from a plywood
stacker1s urinary concentration of 94 mg/liter into a theo-
retical air concentration, the arsenic in air would be
0.03 mg/mj.
Agency Response; The Agency agrees that 0.22 mg/m is an
unlikely value. The Agency agrees with another rebutter
(California Department Health Services) who provided data
showing air concentrations ot arsenic of 0.043 to 0.07 mg/m"1
measured in the industrial setting adjacent to mixing of the
treatment solution. The value of 0.07 mg/m is slightly
above the value obtained by Arsenauit (0.05 mg/m ) tor areas
185
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near the mixing of the preservative solutions. The Agency will
use 0.07 mg/m as a general industrial inhalation exposure
value .
Rebuttal Comment 61; Respiratory and Related Exposures -
Inhalation exposure to persons living
and/or working in dwellings containing
arsenic-treated wood (2)
AWP1 contends that using an arsenic air concentration of
3.6 ug/m as reported in the National Concrete Masonry
Association, NCMA, (1976), but not consistent with Sleater
and Berger (National Bureau of Standards, (NBS) 1977) or
Williams (1978), does not represent a fair analysis of
potential exposure in homes with arsenic treated wood. Using
the highest level of 0.031 ug/m of arsenic, as reported in
both the Sieater and Berger (1977) and Williams (1978) studies,
would be more appropriate.
Agency Response; The NCMA (1976) study of two homes indi-
cated interior airborne arsenic levels of 0.6 and 3.6 ug/m
wniie the Sleater and Berger, NBS, (1977) study of 10 homes
gave values ranging from 0.002 to 0.031 ug/m . The latter
study could not explain the 116 to 300-fold higher values found
in the NCMA study. Both studies monitored two of the same
homes; the NCMA study showed a 32 to 300-fold higher level in
one home and a 277 to 1800-fold higher level in the other than
the Sieater and Berger study. The NBS study showed average
186
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outside air arsenic values of 0.002 ug/m as a control. Both
studies sampled for particulates using high volume air samples
with filters and the same analytical methodology. Williams
(1978) monitored 3 homes with CCA-C treated wood and found
values of 0.001 to 0.029 ug/m with an average air level of
U.021 ug/m , which is similar to the NBS study. It is
apparent from Tables 19 (arsenic in air of buildings con-
structed with wood pressure-treated with arsenical wood
preservatives) and 20 (arsenic in dust of homes containing
arsenic-treated wood) of PD-1 that arsenic levels, in general,
were lower in those cases where treated plywood was covered
rather than exposed.
Both PD-i and AWPI (Vol. I) speculate on reasons for the wide
variation in measured arsenic air concentration values reported
in these studies, all of which are possible explanations for
the observed concentration variations, but does not resolve
Uie issue. Such explanations include: 1) thorough cleaning of
the homes; 2) arsenic from exterior soil; 3) home use of
arsenical pesticides; and 4) sample contamination.
'Ihe Agency dismisses the high values from the NCMA (1976) study
as aberrant and will utilize the highest value of Sleater and
Berger (1977) of 0.031 ug/m for exposure calculations
because the data is based on a larger number of homes. The
larger sample of homes (10) provides similar results for each
187
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home and is considered more reliable than results based on only
two homes. Ihe discrepancy in data, however, remains
unresolved.
The AVvPI rebuttal did not discuss the dust sampling data in
the NCMA (1976) and NBS (1977) studies. However, the Agency
has decided that the same rational applies to these samples.
The NBS (1977) study reported levels of 2-1267 ppm ot arsenic
in house dust, with the higher levels reported in houses in
which the treated wood was exposed. Since the NBS (1977) study
reported analytical data tor eleven dust samples, compared to
two samples in the NCMA (1976) study the Agency has determined
that the NBS data are a better measure of actual levels in
household dust. Thus the highest value reported, 1267 ppm,
will be used in the exposure analysis.
In addition to the NCMA and NBS studies, the AWP1 submitted an
additional home air and dust monitoring study. The values
reported in the AWPI study were similar to the lower range of
values reported in the NBS study. Table Ii.C-3 presents a
summary of the arsenic air and dust monitoring data from homes
containing arsenic treated wood.
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Rebuttal Comment 7; Closed Treatment Systems Reduce Exposure
to Negligible Levels (2, 10, 38, 50, 52,
60, 76, 90, 97, 111, 113, 120-4, 132,
135, 145, 185, 187, 191, 203, 223-27)
A number of rebutters contend that most wood treatment uses
of arsenic involve a chromated copper-arsenate (CCA) type
preservative. The treatment process involves a closed system,
largely automated, so that employees have minimal exposure to
toxic chemicals. Employees who may be exposed are provided
with protective work clothing and facilities for maintenance of
personel hygiene. Very little preservative residue is left on
the treated wood because the excess treating solution is drawn
off and pretiltered for return to the treatment storage
system. Employees have little or no physical contact with
freshly treated wood and consumers receive only air or kiln-
dried materials.
Agency Response: The Agency recognizes that CCA treatment in
modern, closed-system plants provides some protection to the
worker from inhalation and dermal exposure. However, use of
ammonia-copper arsenic (ACA) and lluor-chrome-arsenic-phenol
mixtures (FCAP) generally involves batch preparation on site.
This is also true of some CCA treatment plants.
In such cases, dermal and inhalation exposure to workers can
occur during the mixing process. Ihis is shown in 'lable 15 of
the Position Document 1, listing exposures to workers, bub-
190
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sequent handling ot the wood, which is not dry alter treatment,
can result in dermal exposure. The rebuttal comments ciaim
protective ciothing is used where exposure situations occur,
but this is not a documented or required practice.
In a study by Kiemmar ejt al. (1975) arsenic in house dust in
homes ot employees working in the wood preservatives industry
was measured and values up to 1,080 ppm were obtained. From
this information, the Agency concludes that use of arsenic wood
preservatives provides an exposure source tar above background
levels .
Rebuttal Comment 8: Use ot Liquid Formulations Reduces
Exposure to Negligible Levels (2)
rihe AVvPI claims that dry powder lormulatioris are no longer in
significant use and that over 90% of the CCA concentrate used
currently is in liquid torm mostly handled in closed-system
operations.
Agency Response; AWP1 (Vol. Ill, p.y) does indicate that a
powdered CCA formulation is used by a few treaters, but they
mention nothing of the fiuor chrome arsenic phenol (FCAP)
treatment, which is a powder formulation. Also, ACA can be
maue up by powder formulation and with FCAP accounts for 10% of
the wood preservative formulations. AWPI claims insignificant
use ot dust formulations and assumes minimal exposure because.
ot protective clothing, but these claims cannot be substanti-
191
-------
ated from the information provided. The Agency agrees that a
closed system operation, in the case of CCA, greatly reduces
exposure potential. AWPI claims that when potential exposure
to arsenical wood concentrate is present, plant workers are
provided protective equipment, however, AWPI does not state
that this is a required practice. In summary, the rebutter
claims that exposure to treatment solutions is negligible, but
based on the information given, exposure to arsenic-containing
treatment solutions is still considered likely to occur.
Rebuttal Comment 9; Agency Did Not Consider Chronic or
Repeated Exposure or Special Hazards to
Children (212)
The Department of Health Services for the State of California
claims that the Agency failed to consider chronic or repeated
exposures or the special hazard to children from playing on
playground equipment made from treated wood.
Agency Response: The chronic or repeated exposure is taken
into account when estimates of exposure (including length of
exposure) are presented in the oncogenic, mutagenic and terato-
genic human Risk Analysis PD 2/3, Part II.C.8 The rebutter's
point concerning the special hazard to children is well taken.
Children could conceivably be more affected because of their
lower body weight and direct oral and dermal contact with
wood. However, at this time the Agency has determined that
192
-------
wich the dvaiiabie data the exposure of children to the end
uses\oi; the treated wood (playground equipment) cannot be
estimated.
c. Summary of Rebuttal Comments and Revised Assumptions
Many points were raised by rebutters with regard to data used
to determine exposure. in many cases the data were a valuable
aid to the Agency in revising its original assumptions on
exposure. Much of the evidence considered valid will be used
in this position document. In other cases, where the data
contiicted with other evidence, the highest reasonable exposure
data were used. Evidence presented that appeared inadequate or
questionable was rejected.
In the consideration of the revised exposure information
presented in the exposure rebuttal analysis, the Agency has
determined that these comments on exposure do not rebutt tne
human health effects described in Part ll.C-k, 3, and 4 ot this
document.
The following is a summary of changes that the Agency has made
in the exposure estimates.
1. The estimated breathing rate has been lowered from
1.8 m /iir co 1.47 m /hr tor women doing heavy work and
from 1.8 m /hr to 0.98 m /hr lor women doing xight work.
193
-------
2. The resting breathing rate tor women is 0.27 m /hr.
3. The estimate for Gl tract absorption ot arsenic is lowered
from 75% to 40%.
4. Inhalation exposure for plywood stackers and other in-
dustrial situations has been lowered from 0.22 mg/m to
3
0.07 mg/m . in-plant use of arsenic can produce arsenic
air concentrations ot 0.043 to 0.07 mg/m . The higher
value will be used to estimate industrial exposure.
5. The quantity ot liquid used co wet both hands has been
reduced from 20 mi to 6 ml.
6. Surface residue estimates on treated wood are increased
from 0.529 mg/ft2 for CCA and ACA to 4.5 mg/ft2 tor CCA
and 23 mg/ft2 for ACA.
7. The example ot dermal exposure to a person cleaning a
basement made with arsenic-treated wood after a 28-day
flooding occurence, has been deleted .
8. The arsenic air concentration resulting trom sawing
operations is now estimated at 0.36 mg/m . The previous
estimate was 1.4 mg/m .
194
-------
9. The arsenic air concentration in homes constructed with
arsenic-treated wood is now estimated at 0.031 ug/m . The
PD-1 estimates ranged trom 0.002 ug/m"* to 3.6 ug/m .
10. The amount ot respirable arsenic-containing dust trom
sawing operations has been reduced from 25% to 10%.
11. The dermal absorption of a liquid has betn reduced trom
10% to 0.1%. The dermal absorption caused by contact with dry
dust will be 0.01%.
12. No conclusions can be drawn regarding the extent ol
dietary exposure from the use ot inorganic arsenic as a
wood preservative.
7. Revised Human Exposure Analysis
a. Introduction
in view ol comments and other information received by tne Agency
since the publication of the initial prosumption, the Agency lias
revised some ot the initial presumption exposure estimates. It
must be emphasized that a complete data base on which to base
quantitative estimates ot dietary exposure is still lacking.
'Ihe Agency has made a number of assumptions concerning air con-
centrations, dermal absorption, and wood surface residue levels
and human uptaKe ot these residues. ihis analysis presents
195
-------
these revised non-dietary exposure estimates and those original
estimates which remain unchanged.
b. faummary ot Breathing Rate Assumptions
In general, the original exposure estimates for industrial use
practices remain as described in PD-1. However, due to
teratology and tetotoxicity concerns, the breathing rates and
the body weight ot the exposed person used in the calculations
of exposure have been changed to reflect the potential toxic
ettect on women ot child-bearing age; values of 0.98 m /hr tot-
light work and 1.47 m /hr tor moderate or heavy work wu.1 be
used. For men, the corresponding breathing rates are assumed to
be 1.2 m /hr and 1.8 m /hr. The resting breathing rates tor
men and women are 0.5 and 0.27 m /hr respectively, Altman
tit al. (1958). The body weight or a woman of child-bearing
«age is taken to be 60 kg.
c. Discussion of the Data Range of Assumptions
i. inhalation - Industrial Situation
The range ot air concentrations for arsenic in the large scale
industrial setting ranged from 0.001 to 1.02 mg/mJ. The
former value is listed in PD-1 (p. 114} , and the latter value is
from the Lalitornia Department Health Services rebuttal submis-
sion (212). The "time weighted average" (TWA) for the Califor-
nia rebuttal was 0.07 mg/m arsenic in air (corresponding to
196
-------
0.010 mg/kg/dc»y exposure). This estimate was judged to be a
more representative measure of general inhalation exposure
potential lor industrial settings than the one value of
0.22 mg/m found during plywood stacking (listed in PD-1
Table 15 Arsenic in Mr During Treatment and Handling of Wood)
li. Dermal - industrial Situation (dust)
On page 117 of PD-1, the Agency made several assumptions about
dermal exposure to dust formulations. The Agency estimated that
a worker could contact 10 grams of dust per each exposure
incident. Since no experimental data are available, no range of
variation can be given. No rebuttal comments addressed this
point.
lii. Dermal - industrial situation (Concentrate Treatment
Solution)
The Agency originally estimated a worker could contact 20 ml of
arsenical treatment concentrate on two hands. This estimate has
been lowered to 6 ml (see Agency response to rebuttal comment
5c). The amount of arsenic is calculated on the basis of the
arsenic content in this treatment concentrate solutions and is
unchanged. This is the only data point available so no range is
given.
197
-------
iv. Dermal - Industrial Situation (Dilute Treatment Solution)
The Agency originally estimated a worker could contact 20 ml ot
dilute arsenical treatment solution. This was revised to 6 ml
in light ot rebuttal comments (see Agency response to rebuttal
comment 5c). This is the only data point available, so no range
is given.
v. Dermai - Intermittent Application to Wood (Non-Pressure
Application)
'ihe Agency assumes that a worker will contact 6 mi ot treatment
solution. No range is given (see Agency response to rebut-
tal comment 5c). Inhalation exposure was judged to be negli-
gible because this is a sm
-------
(0.529 mg/ft2) . The California Department of Health Services
data indicate values of 0.14 to 4.5 mg/ft tor CCA-and 2.7 to
23.1 mg/£t tor ACA-treated wood. Some values tor ACA
treatment reached 90 mg/ft / and 8 of 20 samples exceeded
14 mg/ft . in case of CCA, 3 of the 7 samples exceeded
2
0.75 mg/tt . Because the Agency estimates are conservatively
predicated toward the higher estimate, the highest residue
levels of 4.5 and 23.1 mg/tt for CCA and ACA respectively
were used in the final exposure assessment. The same assump-
tions (see above discussion) about skin contact are still made,
but the estimate of dermal absorption of dust has been revised
to 0.01% based on an extrapolation or data by Dutkiewicz (1977).
vii. Inhalation - Handling and Sawing Treated hood
In PD-i the Agency assumed that workers involved in related
sawing activities would be exposed to air concentrations of
1.4 mg/m arsenic and that 75% of the arsenic present in
inhaled sawdust would be absorbed into the gastrointestinal
tract. These estimates have been lowered. The air concen-
tration is now assumed to be 0.36 mg/m , based on industrial
exposure measurements, and measurements made during sawing ana
fabrication of arsenic treated wood. The gastrointestinal tract
absorption is assumed to be 40%, based on a study of the
ingestion of arsenic-containing sawdust by dogs. It sawdust
particles are large, and therefore not inhaled, inhalation
exposure is assumed not to occur. Inhalation absorption in the
lungs is still estimated at 100%.
199
-------
A lower value of 0.01 mg/m arsenic in air measured during
handling of treated wood would yield an exposure dose of
0.001 mg/kg/day for combined gastrointestinal tract and inhala-
tion absorption. The Agency dose estimate of 0.037 mg/kg/day
used in the current exposure analysis reflects lowered exposure
estimates based on arsenic air measurements, but still retains
the highest reasonable estimate for this situation.
vin. Inhalation - Residents in Homes with Treated Wood
From two studies (National Concrete Masonry Association, (NCMA),
and the National Bureau of Standards) listed in PD-i and one
study (AWPI) submitted post PD-1, data are available on the air
concentration in homes built with arsenic treated wood. The
Agency chose 0.031 ug/m as tne highest reasonable estimate
tor arsenic air concentrations in homes. Study values as low as
0.002 ug/m were observed by the NBS and AWPI, while the
highest arsenic value reported was 3.6 ug/m (NCMA). This high
value was rejected on the grounds that it was one of only two
samples from the NCMA study and the NCMA data were inconsistent
with the data in the National Bureau of standards ana the AWPI
study, which had a sample size of 10 and 3 respectively. The
resulting range is 0.002 ug/m to 3.6 ug/m arsenic;
0.031 ug/m was selected because it was the highest valut;
of the 10 samples (see Table 1I.C-3).
200
-------
ix. Dermal-Flood Assumptions
For house cleanup after flooding, the Agency used a single
data point ot 43.2 mg/ft ot arsenic leached over a 7-day
period. Ihis is the only data point available and no range is
given.
x. Dermal - Residents in tomes with Treated Vvood (Dust)
in the case 01 exposure to dust containing arsenic in homes
made from arsenic treated wood, the Agency used 1640 ppm in PD-i
as the highest reasonable estimate for arsenic containing
dust. The lowest value obtained was 2 ppm. This is a wide
range, ana use of the higher value was not rebutted.
However, the value ot 1640 ppm was from the NCMA study. The
Agency has decided to use another study by the NBS (see rational
in exposure rebuttal comment 6f) however tor determination of
both arsenic and and dust levels in homes using treated wood.
Thus the highest value reported, 1270 ppm is used in the
exposure analysis.
Table 1I.C-4 summarizes the range of available exposure data
used in the exposure assumptions.
201
-------
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d. Revised Human Exposure Analysis for Specific Exposure
Si tuations
i. Exposure in Large-Scale Industrial Situation
Ihe revised inhalation dose for a treatment plant worker
(assuming 2 hours heavy exercise and 6 hours of light excerise)
calculation is:
(Arsenic Air Cone.) x (breathing rate) x (length of time)
(wt of person) = exposure
0.07 mg/m3 x 1.47 m3/hr x
mg/mj x 0.98 m3hr x 6 hr/day/60 kg = 0.010 mg/kg/day
0.07 mg/m3 x 1.47 m3/hr x 2 hr/day / 60 kg + 0.07
0.07 mg/m = in plant arsenic air concentration
1.47 m /hr = breathing rate moderate exercise
60 Kg = weight of person
0.98 m /hr = breathing rate light work
0.010 mg/kg/day = in plant inhalation exposure
Ihe Agency assumes dermal exposure is probably negligible in
cases where closed systems are used for wood treatment. During
mixing of the concentrate, however, a worker could wet both
hands with the concentrated treatment solution which contains
27% arsenic. The Agency has determined that the volume of
liquid that might come in contact with the skin is 6 ml.
(see rebuttal comment 5c). Therefore the dermal dose for a
203
-------
worker mixing a concentrated arsenical treatment solution has
been recalculated:
O.OS mg/kg/day arsenic reaching the body (PD-l exposure
estimate with corrected revised dermal absorption) x 6/20,
or 0.027 mg/kg/day
O.G9 mg/Kg/day = amount of arsenic reaching the body trom
contact with a 27% arsenical treatment
solution.
fa/20 = correction factor tor the change trom
20 ml to 6 ml
0.027 mg/kg/day = dermal arsenic aose trom mixing concen-
trated treatment solutions
Similarly, the original exposure estimate tor dermal exposure to
the diluted treatment solution containing 1.7% arsenic during
handling ot wet wood has been reduced by the factor 6/20, and
the revised aose is:
0.0057 mg/kg/day arsenic reaching the body x 6/20
= 0.0017 mg/kg/day
204
-------
0.0057 mg/Kg/day = amount of arsenic reaching the body from
contact with a 1.7% arsenical treatment
solution (using revised dermal absorption
rates)
6/20 = correction factor
0.0017 mg/kg/day = dermal arsenic dose Irom mixing dilute
treatment solutions
In addition the Agency estimated the dermal dose from arsenic
powder or dust formulations (bag emptying) and for dusts
containing arsenic as 0.0016 my/kg/day:
959 mg (PD-1 dust exposure estimate) x .0001 (revised
dust dermal absorption) = .0959/60 kg = 0.00159 or 0.0016
mg/kg/day
959 mg = mg of arsenic dust contacting the worker
estimated in PD-1
0.0001 = 0.01% arsenic dermal absorption
0.0016 mg/kg/day = dermal arsenic dose from bag emptying
It should be emphasized that the Agency still has little
information on the magnitude of this dermal exposure. Ihese
-calculations reflect the Agency's judgment that such exposure is
likely to occur; the actual magnitude of this type of exposure
205
-------
clearly could vary widely, depending upon particular work
practices and the care that individual workers exercise.
Another route of exposure to arsenic from the industrial use of
wood preservatives appears to be contamination of household dust
with arsenic. High levels of arsenic have been found in dust in
treatment plant workers homes. These homes did not contain
arsenic-treated wood (Klemmer e_t al., iy?5); no rebuttal com-
ments were received on this issue. Although there is apparently
no way to quantitatively estimate the human exposure from tnis
source, it remains another route which may contribute to the
overall arsenic exposure.
1.1 . brush-On Non Pressure Application of Inorganic
Arsenicals
As discussed in PL)-1 inhalation exposure during tins use
practice is considered to be minimal. Further no rebuttal
comments were received on this point.
Potential dermal dose tor tins use practice is estimated using
the same revised Assumption concerning skin contact (6 ml) as
was usea for tne mixing exposure estimates. Thus the revised
206
-------
dermal dose is 0.6fa gms arsenic (PD-1) x 6/20 x (0.001) (dermal
absorption lor iiquids) = 0.019b mg/60 Kg = 0.003 mg/Kg/day
0.66 gms = amount ot arsenic reaching the body (PD-1
exposure estimate)
6/20 = correction iactor
U.001 = revised dermal absorption for liquids, 0.1%
60 Kg = weight of person
0.003 mg/Kg/day = amount ot dermal arsenic exposure from
brush on or non-pressure treatment
applications
111. Exposure from Handling/Sawing of Arsenic-'lreated hood
The exposure estimates listed in the PD-1 have been revised
downward. The estimated sawdust concentration in the air has
been revised because better data on actual dust concentrations
was provided by the rebuttals (AWPi). Also, the breathing rate
for women has been lowered to 1.47 m /hr tor moderate or heavy
worK and the gastrointestinal absorption rate has been lowered
from 75% to 40% (Peoples, 1977). These revisions are reflected
in the new exposure estimates presented below.
207
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Exposure via Lung Absorption tor Handling and Sawing Treated
Wood is:
O.jb mg/m arsenic air concentration from sawing plywood
x 1.47 m /hr (moderate work) x 8 hr/day x 0.1 (respirable
fraction of sawdust)/60 Kg = 0.007 mg/kg/day
Exposure via gastrointestinal tract for Handling and Sawing
Treated Wood is :
0.36 mg/m3 x 1.47 m3/hr x 8 hr/day x 0.4 (40% GI
absorption factor) x 0.9 (remaining fraction of non-
respirable sawdust) / 60 kg = 0.03 mg/kg/day
The total inhalation dose is the sum of the two above
calculations or 0.037 mg/kg/day
For dermal exposure from handling treated wood, the estimate has
been changed. The estimated surface residue for CCA-treated
2 2
wood is now 4.5 mg/ft and 23 mg/tt for ACA-treated wood.
rihe Agency assumes, a construction worker will typically be
involved in carrying, positioning, and nailing treated plywood
in the construction of dwellings. Further, the Agency assumes
2
the worker will work with 4x8 foot plywood sheets (32 ft ),
position and nail 7 sheets/hr, and will contact 15% of the
suttace area during these activities. If the work day is
2
8 hours, then the worker will contact (32 ft x 7 sheets/hr x
208
-------
8 hr) x 0.15 (15% surface) or 268 tt^/day. Using these
estimates, dermal dose is Cctlculated:
CCA 4.5 mg/tt x 268 x 0.01% (revised dermal absorption
tactor)/60 kg = 0.002 mg/Kg/day
ACA 23 mg/tt2 x 268 ft2 x 0.01% (revised dermal
absorption tactor) / 60 Kg = 0.010 mg/kg/day
Because of lack of data on FCAP residues, wood treated with FCAP
(Fluor-Chrome-Arsenic-Phenol) is assumed to have residues
similar to ACA.
iv. Exposure to Persons Living/forking in Dwellings Containing
Arsenical Treated Wood (All Weather Wood Foundations, AWWF)
The conflicting reporcs by the NCMA (National Concrete Masonry
Assn., 1976) and the MBS (National Bureau of Standards, 1977)
and (AWP1, 1980) presents an unresolved question as to the
quantitative estimate of the arsenic concentration in air in
dwellings containing AWWF basements (basements constructed with
treated wood) . rihe Agency reviewed the wide range of values
33 3
(3.6 ug/m to 0.001 ug/m ) and selected 0.031 ug/m
because it is based on a sampling of a large number of homes and
the variation between the homes samples is low. Using the NBS
nighest value of 0.031 ug/m the following revision in the
inhalation dose estimate is calculated:
209
-------
0.031 ug/m3 x 0.98 m3/hr (light work) x 16 hr + O.C31
ug/m3 x 0.27 m3/hr (resting) x 8 hr / 60 kg = 0.0094
ug/kg/day or 0.000009 mg/kg/day
In PD 1 the Agency estimated the dermal exposure of homeowners
to arsenic-containing house dust. It was ussumed for this
estimate that homeowners can be dermaliy exported to 10 grams of
house dust during sweeping, that the arsenic level in the dust
could be as high as 1640 ppm, and that 10% of all arsenic will
be absorbed through the skin. Based on revisions to these
estimates discussed in the rebuttal analysis, the revised dermal
exposure estimate is as follows:
1,267 ppm X lOg dust X 0.01%/60Kg = 2.1xlO~5 mg/kg/day
Dermal exposure can also occur from the cleanup of flooded
basements constructed with AWWF's. The Agency has determined
that the original assumptions of continuous flooding for 28 days
is unlikely and therefore this exposure estimate has been
deleted. The estimate for 7-day flooding however, has been
retained because dermal exposure can occur from cleaning up such
basements. Thus, the estimated dermal dose for the 7-day
flooding is 26 mg/kg/day arsenic reaching the body x .01%
(revised dermal absorption) = .0026 mg/kg/day.
210
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e. Summary
Table II.C-5 provides summaries of the calculated exposures
and doses, including those that the Agency has revised, and the
unchanged calculated exposures presented in PD-1. The use
patterns discussed, correspond to those presented in the PD-1.
The large scale industrial situations apply to workers treating
utility poles, lumber and timber, pilings, crossarms, posts and
to dermal exposure from handling wet wood.
Ihe brush-on intermittent exposure estimates apply to non-
pressure application of arsenic-containing treatment solutions
on lumber and 'timber, posts, utility poles, crossarms and
pilings. The category for handling treated wood includes
sawing/fabrication tor inhalation exposure; the dermal exposure
includes the estimated residues a to which worker may be exposed
as a result of handling the dry treated wood. The exposure to
persons in dwellings is presented in two parts: 1) the
inhalation and dermal exposure to arsenic containing dust in
homes using the treated wood, 2) estimated dermal exposure-
resulting from cleanup ot a flooded basement (7 day flood) . The
exposure estimates to persons in dwellings apply only to
lumber/timber. Included in the lumber and timber category are
ail weather wood foundations (AWWF's)and treated plywood and
poles used in barn construction.
211
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8. Quantitative and Qualitative Risk Assessments
a. Oncogenic Effects
i. Introduction
In PD-1 the Agency concluded that a rebuttable presumption
against registration (RPAR) had arisen against inorganic
arsenical pesticides based on oncogenicity. Further, the Agency
concluded in the Analysis of Rebuttals to PD-1 (Part II.C.2.C)
that the presumption of oncogenicity was not successfully
rebutted.
li. Quantitative Risk Estimates
Arsenic cancer risk estimates for inhalation and dermal
*
exposure are based on several independent epidemiological
studies.
* These exposures were converted to average lifetime exposures
214
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The risk model for inhalation exposure is explained in the
"Preliminary Report on Population Risk co Arsenic Exposures"
(CAG, lS>78a) . This model is based data from three epidemiol-
ogicai studies, two in copper smelter workers and one in a
pesticide manufacturering plant (see ll.C.2.c). it is:
R = 1 - exp (-X x 2.953 x 1U~J)
where R is the lifetime cancer risk due to a lifetime ol
continuous exposure to air containing X ug/m ot arsenic.
RisK estimates for dermal and oral exposure (gastrointesti-
nal absorption) are from a model explained in another Cancer-
Assessment Group report (CAG, I978b). The model is based upon
data from an epidemiologic study of skin cancer in an area ot
Taiwan which had Arsenic contamination ol drinking water (see
H.C.2.a) .
* The exposures given in rag/kg were converted to ug/m by
assuming a body weight ot 60 kg and a breathing rate ot 1.47
m /hours (3b m /day).
215
-------
The model is:
Risk = 2.41423 x C
2.41423 x C + 6.02793
where the quantity C is the concentration of arsenic
*
(mg/liter) in drinking water .
In the case of the flooded basement, it is assumed here that the
exposure from cleaning out a flooded basement occurs only once
in a person's lifetime (70 years). Therefore, in this case the
average lifetime exposure is only:
as x 10 of the daily exposure.
365 days/yr x 70
The lifetime cancer risks due to exposure to inorganic
arsenicals are shown in Table Il.C-6
* The exposure in mg/kg/day were converted to mg/liter by
assuming a 60 kg body weight and a water consumption of
2 liters/day.
216
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TABLE II.C-6
LIFETIME PROBABILITY OF CANCER (DERMAL, INHALATION, AND
GASTRO-INTESTINAL)
DUE TO INORGANIC ARSENIC EXPOSURE
Use description Dermal Inhalation G.I. Total
I.
II.
Ill
IV.
V.
Large scale
industrial use
a. background
b. bag emptying
(dust)
c. mixer
concentrate
dilute
solution
d. handler
Brush-on
application
non-pressure
. Handling,
sawing ,
fabrication
Resident in
As treated
homes
Flooded
basement
(water)
6.0 x 10"3
9.8 x 10~2
7.0 x 10~"3
7.6 x 10~3
1.2 x 10"2
7.9 x 10~3
to
3.9 x 10"^
4.5 x 10~6
4.0 x 10~7
1.9 x 10 2 — 1.
2.8 x 10~2 3.
1.9 x 10~2 — 1.
1.9 x 10~2 — 2.
1.9 x 10~2 2.
1.
1.
1.4 x 10"2 1.1 x 10"1 1.
4.0 x 10~6 9.
4.
9
4
17
6
6
2
3
6
0
0
x
x
X
X
X
X
X
to
X
X
X
io-2
10~2
io-1
io-2
io-2
10
io-1
io-1
io-6
ID"7
217
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b. Mutagenic Effects
i. Introduction
From the analysis of data presented in Table II.C-1, the
Agency (EPA) concluded that both trivalent (arsenite) and
pentavaient (arsenate) toons ot inorganic arsenic can act as
mutagenic agents. Further as dicussed in Part 11.C.3 of this
document, the Agency concluded that the presumption of
mutagenicity for inorganic arsenicals was not successfully
As described in detail in PD-i, there is strong evidence
supporting the mutagenicity of inorganic arsenic. Arsenic is
mutagenic in several test systems, and in several biological
phyla, bodium arsenite and sodium arsenate have been shown to be
mutagenic in both ir\ vitro ctnd in vivo tests, including the
following types ot tests; Gene (point) mutations occur when
sodium arsenite is tested with bacterial (Escherichia Coli)
(Nishioka, 1975) or mammalian (hamster cells) in vitro
(Casto,1977a). Chromosomal aberrations are caused by sodium
arsenite and sodium arsenate as seen in in vitro tests with
human cells (Oppenheim and Fishbein, 1965; Paton and Allison,
19V2) and in in vivo tests with mice (Sram and Bencko, 1974) and
humans (Petres £t_»l., 1970, 1977).
Potassium arsenite caused DNA damage in human lymphocytes in
vitro (Burgdorf e_t al. , 1977). DNA repair _in vitro was
decreased by sodium arsenite and sodium arsenate in ultraviolet
218
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light exposed bacteria (E.Coli) (Rossman et a1., 1975, 1977)
Bacillus subtilis) (Nishioka, 1975) and by sodium arsenate in
xenon lamp-exposed human epidermal cells (Jung et al., 1969;
Jung and Trachsel, 1970). In addition, these inorganic
arsenical compounds aftected DNA synthesis, and mitosis, by
their metabolic and cellular toxicity effects as seen-in in
vitro and in vivo tests in mammalian systems (see eight
references in PD-1).
ii. Qualitative Risk Assessment
The mechanisms whereby the inorganic arsenicals cause mutations
may include the following: 1) direct incorporation of arsenic
into the RNA and T>NA molecule in place of phosphorous; 2)
indirectly by competitive inhibition of phosphorous insertion
into polynucleotide chains; and 3) indirectly through inhibition
of enzymes (arsenic reacting with SH (sulfhydryl) groups of
polypeptides) involved in DNA and RNA synthesis, regulation, and
repair of damaged DNA.
Table II.C-7 lists summaries of reports discussed in PD-1 and
additional studies reviewed by the Agency since the publication
of the PD-l. These studies form the basis of the inorganic
arsenical compound's mutagenic risk assessment.
2!9
-------
TABLE II.C-7
SUMMARY OF SIGNIFICANT STUDIES FOR INORGANIC ARSENICALS
MUTAGENIC RISK ASSESSMENT
Chromosomal Aberrations
Authors Petres et al., 1970b Petres et al., 1977b
System Human lymphocyte cultures from 1. Human lymphocyte
chronic arsenic exposed patients cultures from chronic
arsenic exposed patients
2. Arsenic, 0.0-100 ug
treated human lymphocyte
cultures from normal
persons.
Agent Arsenic (unspecified) Arsenate
Results Aneuploidy, chromatid breaks, Same as Petres et al., 1970
a centric fragments at greater
frequency than untreated control.
control. Normal arsenic treated
cells had Dose-Response effect
at 0.0 ug-lOOug.
Comments Experimental group (long-term exposure) Same as Petres et al., 1970
were vintners and other patients with
psoriasis, also some excision of arsenic
induced carcinomas. Similar effects
were found in normals lymphocytes after
treatment with arsenic.
Sister chromatid Exchange
(SCE)
Authors Burgdorf et al., 1977b
System Human lymphocyte cultures
from patients
Agent Potassium Arsenite
Results Higher level of SCE in experimentals
than control
Comments The experimental group consisted of six patients treated with
Fowler's solution for 4 to 27 years, for either asthma, psoriasis or
anxiety. All had skin cancer.
220
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TABLE II.C-7 Continued
Chromosomal Aberrations
Authors Beckman et al., 1977
Nordensom et al., 1978
Beckman et al., 1979
System Human lymphocyte cultures from workers exposed to arsenic (and other
unidentified toxic agents)
Agent Arsenic (unspecified)
Results Chromosome gaps, dislocated chromatids, dicentric chromosomes,
rings, acentric fragments and other abnormalities.
Comments All aberrations in chronic (high, medium and low) exposure groups and
newly exposed workers higher than controls (p<0.001) Smoking, exposure
to lead and/or selenium were considered in analysis.
Chromosomal Aberrations
Author Paton and Allison, 1972
System Normal human leucocyte cultures, Normal human leucocyte cultures
human diploid fibroblasts
Agent Sodium Arsenite Sodium Arsenate
Results Chronatid breadage; arsenite
effect>arsenate effect.
Chromosome exchanges and chromosome damage noted.
Comments Arsenite 9.7 times greater effect than arsenate in percent than
arsenate in percent of chromatids with breaks in cultured leucocytes
and 4.8 times higher than control (untreated leucocytes).
Chromosomal Aberrations
Authors Oppenheim and Fishbein, 1965
System Normal human leucocyte cultures
Agent Potassium Arsenite
Results Chromosome gaps, breaks, translocations, rings. Cell division was
suppressed and there was an increased number of broken metaphase
plates, at 1 uM concentration arsenite.
Comments 10 uM arsenite induced 70% damaged cells over control value. This was
higher than urea hydroxyurea or othr chemicals tested at even vastly
higher concentrastions.
221
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TABLE II.C-7 Continued
1
Dominant Lethal
Authors Sram and Bencko, 1974
System ICR-SP mice 4 generation study in vivo
Agent Sodium arsenite chronic 1.6 mg/kg/day, Sodium arsenite 1 acute
9-10 mgAg/day orally, 8 weeks dose, 250 mgAg
Results At the acute dose and the high chronic dose, no effects noted. At the
low dose, overall dominant lethality and and pre-implantation
lethality occurred. At 9-10 mg/kg/day, similar results occurred when
TEPA was injected.
Comments Positive dominant lethal effects at the low dose. Possible co-mutagen
role for TEPA to induce dominant lethal effects after chronic
exposure to arsenite.
Chromosomal Abberations
Authors Sram,•1976
System ICR random bred mice, Bone marrow cells
Agent Sodium Arsenite 1.6 mg/kg/day or 9-10 mg/kg/day orally 8 weeks
Results At 1.6 mgAg/day, 7.6% above normal values, abnormal chromosomes.
At 9-10 mgAg/day 3.2% above normal values. Abnormal chromosomes at 9-
10 mgAg/day plus control mutagen TEPA, 56.4% over normal value.
TEPA (control mutagen) gave 34% abnormal chromosomes over normal
value.
Comments Possible co-mutagen role for TEPA to enhance chromosome aberrations
after chronic exposure to arsenite.
Organ and Tissue Histopathology
Authors Bencko et al., 1968
System Hairless mice
Agent Arsenic trioxide 0.75% mgAg/day or 7.5 mgAg/day for 256 days
Results At 0.75 mgAg/day skin, liver, kidneys and spleen had arsenic
attributable pathology. Testes did not. At 7.5 mgAg/day all above
tissues had increased pathology and testes germinative epithelium
appeared to be heavily deteriorated.
Conments Mouse testicular germnative epithelium is targeted by 7.5 mg/kg/day
administered for 256 days. The mouse strain employed, however, is not
a normal representative of the specie.
222
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TABLE II.C-7 Continued
(a) Other chromosome aberration studies not listed here are found in PD 1 and
discussed elsewhere in this document.
(b) Study listed in PD 1
(c) TEPA = tris (1 aziridinyl) phosphine oxide
223
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One study indicated that trivalent arsenic produces a heritable
mutagenic effect in mice (Sram and Bencko, 1974). The dominant
lethal study (Sram and Bencko, 1974) showed that sodium arsenite
orally administered to mice at 1.6 mg/kg/day over four genera-
tions resulted in overall dominant and preimplanation lethal-
ity, however, a dose level of 9-10 mg/kg/day did not produce
dominant lethality or changes in male fertility. Since a
positive response was observed at the low dose, and a negative
response occurred at the high dose, this study can only be
suggestive of a positive result. However, in related experi-
ments, a known mutagen, TEPA (tris (1-aziridenyl) phosphine
oxide) was administered intrapenitoneally as a single dose of
1.0 mg/kg to three groups of males from the F3 generation. The
three groups included untreated males, 1.6 mg/kg/day arsenite-
treated, and 9-10 mg/kg/day arsenite-treated males. The results
were as follows: TEPA alone gave a higher level of dominant
lethals and related effects than either arsenite treatment.
TEPA plus arsenite at 1.6 mg/kg/day produced no significantly
different effects from arsenite alone. But TEPA administered to
F3 males after chronic exposure to 9-10 mg/kg/day arsenite gave
a distinctly additive effect. This unusual result indicated
that some change must have occurred at the higher arsenite
dosage, which did not produce observable effects until TEPA
administration. One may speculate that TEPA acted as a "co-
mutagen" in this experiment.
A parallel effect may be seen in the chromosome aberration
studies of bone marrow cells (Sram, 1976), (see Table II.C.7).
224
-------
The protocol used was similar to the dominant lethal study,
except that bone marrow of treated and control mice were
examined tor various kinds ot chromosomal aberrations following
ciironic arsenite exposure ot the animals. A further parallel
effect to that seen in the dominant lethal study was the
observed percent of abnormal cells from arsenite-treated mice.
These parallel effects were especially noteworthy when the
tigures for cytogenic analysis and dominant iethals were
compared. Again, an additive affect ot TEPA is seen at the
higher arsenite treatment level for bone marrow cells. The
dominant lethal study in particular provides strong evidence in
support of a heritable mutagenic risk of arsenic for rodent
species, and may permit extrapolation to humans. This is
turther supported by the evidence described in the following
studies.
*
In an experiment with hairless mice , groups ot animals were
exposed to arsenic trioxide in drinking water tor 256 days at
dosages ot 0.75 mg/kg/day and 7.5 mg/Kg/day respectively
(Bencko, 1977, Bencko £t al., 1968). Mouse tissues, including
skin, liver, kidneys, spleen and testes were examined for
pathological changes attributable to arsenic at the termination
of the experiment. buch pathological changes were tound in all
* The hairless mouse however is deficient in immune T cell
(thymocytej function and its thymus deteriorates early in
lite. In addition, the animal has deficienceis in humoral immune
function and abnormalities are also be found in the spleen
(F^SEB, 1979).
225
-------
tissues except tcstes in the low dosage group. In the high
dosage group, more pronounced pathological changes were observed
in the same group of tissues. In addition, heavy deterioration
was found in the germinative epithelium of the testes in the
high dosage group. This experimental data together with the
dominant lethal study of Sram and Bencko (1974) provides
evidence that arsenic is a potential human mutagen.
In another study using white Swiss mice, an arsenic dose of
0.075 mg/kg/day was administered for three weeks to white Swiss
mice in the drinking water. The authors found that the
antibody producing cells (secondary immune response) was
depressed to 55% of the control value (Blakeiey et al.,
1980). Therefore, immunological effects cannot be excluded from
having an impact on other pathological symptoms resulting from
arsenic treatment.
The mutagenic potency of the inorganic arsenical compounds is
shown on Table II.C.8. The relative mutagenic potencies of
trivalent ad pentavalent arsenic in acute and chronic exposures
of cell cultures were studied by Paton and Allison (1972), see
Table II.C-8. Exposing human leucocyte cells in culture, to
_y
sodium arsenite (trivalent) at 5.8 x 10 to for the same time
period for a 48 hour acute resulted in 48% chromosomal
aberrations as compared with sodium arsenate (pentavaient) at
_Q
5.7 x 10 M which gave 5% chromosomal aberrations. Untreatea
226
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human leucocytes gave 1% aberrations as a control value. Both
arsenate and arsenite values tor chromosome aberrations were
statistically different than the controls.
Human exposure to arsenic has also resulted in chromosomal
aberrations. The Study by Petres e_t _al., (1970, 1977) showed
that long-term expposure of vineyard workers (vintners) or
patients (treated for psoriasis) to inorganic arsenicais
resulted in high levels of chromosomal aberrations in their
lymphocytes when compared with lymphocyte chromosomes from
non-exposed persons. This was demonstrated by
collecting blood from arsenic exposed and non-exposed
individuals, separating the lymphocytes, inducing them to
replicate using standard culture techniques ana examining tht-
chromosomes for the various abnormalities (aberrations) see
listing Table 1I.C-7 (Petres et _al., 1970, 1977).
Unfortunately, neither of the two papers reported the dose
levels of arsenic to which the patients had been exposed.
The worK of Burgdorf et al., (1977) employing the lymphocyte
culture technique on patients treated with Fowler's solution (a
potassium arsenite compound) demonstrated that ail six patients
showed a high level of sister chromatic exchange (faCE). The
patient group had a mean level of 14 bCE per mitosis, in winch
44 normal controls had a mean level of 5.8 SCE per mitosis
(Fisher exact test used; P, < 0.01). Chromosome breakage
analysis of lymphocyte chromosomes showed no differences between
the patient group and the normal controls. The patient group
228
-------
ail haa stigmata ot arsenic chronic exposure as well as biopsy
proven skin cancers, arsenic treatment periods ot the patients
ranged irom tour months to 27 years. The authors (Burgdorf e_t
al. , 1977) concluded that the signiiicantiy elevated SCL in
cultured lymphocytes trom arsenic-treated patients may be
relctted to arsenical carcinogenesis.
Thus, these papers present evidence that human exposure to
arsenic can lead to an increased incidence ot chromosomal
structural abnormalities and abnormalities in chromosome number
(aneupioidy) in man.
In addition, epidemioiogical evidence shows that workers at a
smelter where arsenic is produced showed significantly higher
chromosomal abnormalities then control populations.
In another series ot experiments with human lymphocytes in
culture (Beckman e_t al., 1977, Nordenson e_t al., 1978,
Beckman e_t _al., 1979) groups ot worKers employed at the
Ronnskar smelter in northern Sweden were tested tor exposure
to arsenic (see Table Il.C-7). Portions of these studies are
discussed in the teratology and fetotoxicity section of this
document. Vvorkers at the smelter were exposed to a number ot
toxic substances, including arsenic, lead and selenium. Smoking
and exposure to lead and selenium were considered in the
analysis ot the data. Normal controls were a group of healthy
males from Umea, about 100 kilometers trom the Ronnskar smelter.
229
-------
For the experiment, workers were divided into high, medium and
iov, exposure groups by age and years employed at the smelter
(i.e., high exposure: 54 years age, 22 years exposure; medium
exposure: 32.9 years age, 6.5 years exposure; low exposure: 32
years age, 4 years exposure), and new employees (32.5 years age,
less than 4 years exposure). The "new employees" group were
rioted as living close to the smelter before their employment.
The number ot chromosomal aberrations in lymphocytes of all
worKers together was statistically significantly higher than
that ot the controls (P
-------
authors commented that the frequencies or aberrations may show
large variations (trom 0-25 per 100 cells) even Lor similar
exposures, suggesting a speculation cts to the role ol genetic
disposition in response to genotoxic agents like arsenic. The
overall results ol these experiments support the work ol Petres
ejL al. (1970, 1977) .
iii. Summary
'ihe inorganic arsenical compounds have the intrinsic potential
via several possible mechanisms (gene mutation, chromosome
aberration, DNA damage, and effects on DNA repair) to mutate
mammalian cells. Evidence (Petres et al., 1970, 1977,
Burgdorf e_t al., 1977) shows that human exposure to arsenic
can result in chromosome aberrations ana aneupioidy _in vivo .
tpidemioiogical evidence shows tnat workers at a smelter where
arsenic was produced showed significantly higher chromosomal
abnormalities than control populations (Becxman et al., 1977,
1979; Nordenson e_t al. , 1978). The evidence strongly suggests
that arsenic was the sole cause of the chromosomal abnormali-
ties. One study (Sram and BencKo, ly74) suggests thdt arsenic
caused heritable genetic detects in mice. BencKo e_t al.
(1968) showed that chronic exposure to arsenic trioxide caused
deterioration ot the germinative epithelium of the testes in
hairless mice, thus arsenic affected the reproductive tissues.
Ihus, there is ample evidence that occupational exposure
(•although unquantifiea) to arsenic has the potential to produce
231
-------
heritable mutagenic effects in humans, and thac these effects
may indeed be high.
c. Teratology and Fetotoxicity Effects
i. Introduction
In PD-1 the Agency concluded that a rebuttable presumption
against registration (RPAR) had arisen against inorganic
arsenical pesticides based on teratogenicity and fetotoxicity.
Further, in Section II.C.4 of this document the Agency deter-
mined that the presumption of teratogenic and fetotoxic risk was
not successfully rebutted. The studies of Hood ejt al. (1977,
1978) demonstrated evidence of arsenical teratogenicity. The
study of Matsumoto e_t al. (1974) demonstrated evidence of
fetotoxicity. The Agency assessed the study by Hood (1979,
unpublished) submitted by AWPI as Appendix #4, Vol. Ill as being
inadequate for a quantitative risk analysis.
ii. Special Considerations
Acute and Chronic Toxicity of Arsenic to Animals and Humans
The animal studies listed in PD-1 demonstrate the potential
teratogenicity and fetotoxicity of the inorganic arsenicals.
Estimation of the actual human hazard from fetotoxicity and
teratogenicity studies using animals requires consideration of
232
-------
several factors. Thus, predictive uncertainty always results
from differences in metabolic activation or detoxification
between the human and the test animal. Tissue distribution of
the pesticide is another consideration. The Agency is aware,
for example, that the capacity of the rat to sequester arsenic
in hemoglobin significantly exceeds that of man and some other
test animals (Ducoff e_t al., 1948). Such an unusual tissue
distribution of pollutant in a test animal might introduce
additional uncertainity into the extrapolation of toxicity data
for human risk analysis. It appears, in fact, that with several
acute or chronic toxicity parameters for inorganic arsenic, a
risk extrapolation requires qualification, since the human
sensitivity has been shown in many cases to be greater than that
demonstrated in test animals.
To illustrate this comparison of animal and human sensitivities
to the affects of arsenic, Tables II.C-10 through 13 provide,
for both laboratory animals and humans, listings of acute and
chronic toxicity data for inorganic arsenic. After reviewing
the toxicity of arsenic (inorganic) in drinking water, Sagner
(1973) observed that most cases of human poisoning occurred at
lower levels than those observative rats. Human poisoning
occurred when concentrations reached 0.5 to 1.0 mg/liter, which
provides a doseage of about 0.017 to 0.034 mg/kg/day.
233
-------
other Effects
Although the mechanism of action is not Known for any
teratogenic chemical, several observations can be mentioned that
deal with arsenical effects on biological systems.
Fowier et al. (1977) studied structure and function of liver
mitochondria and hepatocytes in male rats given drinking water
containing 20, 40 or. 85 ppm arsenic as arsenate tor 6 weeks.
Significant depression of growth rate occurred only at the 85
ppm (8.5 mg/kg/day) dose level. Mitochondria in hepatocytes
from animals at the upper two dose levels showed extensive
swelling. Mitochonorial respiratory function (tor specified
substrate conditions) exhibited a dose-related depression at 20
ppm (approx. 2.0 mg/kg/day) and 40 ppra arsenate. Uncoupling of
oxidative phosphorylation (depressed P/0 ratios) appeared to be
less "substrate restricted" in mitochondria only trom animals of
the 85 ppm dose group.
For sodium arsenite a dose of 125 ppm (about 13 mg/kg/day)
caused bile duct enlargement when mixed in the feed of rats
(National Research Council, 1976). in the mouse, 5 ppm sodium
arsenite (about 0.75 mg/kg/day), when administered in drinking
water, caused shortened life span and alteration of sex. Sodium
arsenite, however, is reported to be markedly more toxic in the
pig when administered through drinking water rather than in the
feed .
234
-------
ni. Summary of Studies used in the Risk Assessment
Table ll.C-9 presents those studies of either arsenate or
arsenite showing teratogenicity/fetoxicity after dosing by a
route (oral ingestion or gavage) relevant to human production of
(or exposure to) arsenic-treated wood.
Hood e_t al. (1978) reported significant teratogenic effects at
120 mg arsenate/kg oral dose, but gave no maternal toxicity
data. The Agency notes that the teratogenic level listed in
Table ll.C.Ii (120 mg/kg) is in the L-D,-f range for mice. The
only data reviewed by the Agency on maternal toxicity was
reported in the hood ej: al. (1977) study, and maternal
toxicity was estimated at 16% for an oral dose of 120 mg
arsenate/kg. Matsumoto (1974), who used arsenite rather than
arsenate, reported that 10 mg/kg produced significant tetotoxic
effects in mice. He did not observe maternal toxicity. The
Agency has determined that with the available data the level of
maternal toxicity observed at arsenic dosages sufficient to
cause teratogenicity, and/or fetotoxiicity effects cannot be
estimated.
The effects of arsenic on teratogenicity and fetotoxicity can be
summarized as follows: No teratogenic or fetotoxic effects were
seen in the rat at 4.4 (arsenite) and 6.5 (arsenate) mg/kg/day
doses, (Kimmel and Fowler, 1974). Fetotoxicity was observed in
mice at 10, 20 and 40 mg/kg/day (arsenite), but no fetal
malformations were observed at these levels (Matsumoto, 1974).
235
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Thus, the rat study shows 4.4 (arsenite) and 6.5 (arsenate)
mg/kg/day to be non-teratogenic and non-fetotoxic, and the mouse
study demonstrates that up to 40 mg/kg/day is non-teratogenic;
however, the mouse study also shows that 10 mg/kg/day, the
lowest dose tested, is fetotoxic. The study by Ko;j ima (1974)
shows that levels up to 5 mg/kg/day (arsenite) have no effect on
the number of litters in rats (note, however, that teratogenic
effects were not assessed). The Agency will, therefore, use 5
mg/kg/aay arsenite or arsenite as a provisional estimate of a no-
effect level (NOEL) for teratogenicity and fetotoxicity. The
Agency realizes that in the mouse a no-effect level for
fetotoxicity has not been established. This is a serious
data gap. The dose of 5 mg/kg/day for the rat is used for
estimation only and cannot be construed as a no-effect level in
mice.
iv. Quantitative Risk Estimates
Margins of Safety have been calculated for the various exposure
sites where the use of inorganic arsenical wood preservatives is
anticipated, (see Table 1I.C-14).
The Total Body Doses (TBD) were estimated from the dermal and
inhalation exposure estimates (Day, 1980, Exposure Analysis for
Inorganic Arsenic) as presented originally in PD-1 and amended
after rebuttal comments (see Table Il.C-5 in Part II of this
document) .
243
-------
For the exposure and TBD calculations ot the sawing and
fabrication scenarios, the gastrointestinal absorption tactor is
added because it is anticipated that a significant portion ot
the inhaled dust particles will be trapped and ultimately
swallowed.
Risk to teratogenic/fetotoxic effects was calculated using
5 mg/kg/day as the provisional no-effect level.
v. Summary
As shown in Tables II.C-10 through 13/ humans appear to be more
sensitive to arsenic toxicity than are mice and rats. Therefore
a prudent scientist might expect the teratogenic/tetotoxic
margins ot safety to be lower for humans than for rats and mice.
If humans are more sensitive to arsenic toxicity than are
rodents, and it appears that they are, the margins ot safety
could be much lower than those shown in Table ll.C-14. As
discussed in this section there is also epidemiologicai evidence
that humans exposed to arsenic in smelters experienced
teratogenic/tecotoxic effects.
244
-------
TABLE II.C-14
Inorganic Arsenic
Margins of Safety for Teratogenic/Fetotoxic Effects
Total Body
Dose
Use rag/kg/day
I.
II.
III.
IV.
V.
Large Scale
Industrial Use
a. Background
b. Bag Dumping
c. Mixer Con-
centrate
Mixer Dilute
d. Handler
Brush-on
application to
wood
Non-pressure
Handling treated
wood
(e.g. sawing and
( fabrication)
Residents
Clean-up of
0.010
0.017
0.037
0.012
0.012
0.003
0.039 to
0.047
0.00003
0.0026
Margin of
Safety
500
294
135
417
417
1667
128 to
106
128,000
1923
flooded base-
ments
245
-------
D. Pentachiorophenol
1. Analysis of Rebuttal Comments Concerning Fetotoxic and
Teratogenic Effects
a. Basis of Presumption
i. Introduction
In the studies summarized here, fetotoxic and teratogenic
effects were reported in rats exposed to purified and commercial
grade penta. Teratogenic effects were reported in rats exposed
to a mixture of two unspecified isomers of hexachlorodibenzo-p-
dioxin (HxCDD). Specifically, exposure to penta contaminated
with these HxCDD isomers resulted in statistically significant
increases in the incidence of skeletal and soft tissue
anomalies, growth-retarded fetuses, and embryonic resorptions in
the litters of treated dams.
ii. Studies with Penta
Schwetz et_ al. (1974) studied the effects of purified and
commercial grade penta on rat embryonal and fetal development.
Doses of 5, 15, 30, and 50 mg/kg/day of purified penta and 5.8,
15, 34.7, and 50 mg/kg/day of commercial penta were administered
by gavage on gestation days 6 through 15 inclusive. (Note that
5.8 and 34.7 mg/kg/day of commercial penta are equivalent to 5
and 30 mg/kg/day of purified penta.) Both purified and
247
-------
commercial penta caused statistically significant increases in
fetal resorptions at the two higher doses (Table II.D-1). It is
interesting that at 30 and 50 mg/kg/day, purified penta had a
more pronounced effect than the two highest doses of commercial
penta. For example, at 50 mg/kg/day purified penta caused 100%
incidence of fetal resorptions, while commercial penta caused
58% resorptions. At 30 (purified) and 50 (commercial) mg/kg/day,
there were statistically significant differences in the sex ratio
of surviving fetuses: in both cases males were heavily
predominant. These investigators also found that administration
of penta during early organogenesis (days 8 through 11 of
gestation) had a more pronounced effect on fetal resorption than
did its administration during late organogenesis (days 12 through
15).
In this study, the no-observable-effect level (NOEL) for fetal
resorption was 5.8 mg/kg/day of commercial grade penta and 15
mg/kg/day of purified penta. Measurements were also taken on
fetal body weight and crown-rump length, both of which decreased
with increasing dose. The NOEL for these parameters was 15
mg/kg/day for both commercial grade and purified penta.
Schwetz et al. (1974) also investigated the fetal anomalies in
rats caused by penta. They studied the effects produced by oral
adminstration (gavage) of 5.8, 15, 34.7, and 50 mg/kg/day of
commercial grade penta, and 5, 15, and 30 mg/kg/day of purified
penta. In one experiment, they administered these amounts of
penta during days 6 through 15 of gestation; significant
increases in skeletal defects of the ribs, sternebrae, and
248
-------
TABLE II.D-1
Effect of Pentachlorophenol on the Incidence of
Fetal Resorptions and on the Sex Ratio of Survivors
Test Material Resorptions
and Dose Among Fetuses Among Litters
(mg/kg/day) % No. % No.
Vehicle Control
Pentachlorophenol
Commercial
5.8
15
34.7
50
Purified
5
15
30
50
4.
7.
8.
27.
58.
4.
5.
97.
100.
2
1
8
2
1
2
9
5
0
15/358
15/212
d
17/194
64/235d
108/186d
8/189
13/221
d
233/239
229/229d
30.
55.
64.
94.
93.
46.
38.
100.
100.
3
6
7
7
3
7
9
0
0
10/33
10/18
11/17
18/19
14/15
7/15
7/18
20/20
19/19
d
u
d
d
d
d
a. From Schwetz et al. (1974).
b. 2.0 ml/kg body weight corn oil per day.
c. Dosages were administered in corn oil (2.0 ml/kg).
d. Significantly different from control values by the binomial
expansion test, p<0.05.
249
-------
vertebrae were observed in the two highest dose groups of both
purified and commercial penta. The lowest dose of purified
penta (5 mg/kg/day) caused an increase in delayed skull
ossification. In a second experiment, they gave 30.0 (purified)
and 34.7 (commerical) mg/kg/day penta on days 8 through 11 of
gestation to one group of animals, and on days 12 through 15 to
a second group; significant increases in abnormal sternebrae and
skulls were observed in animals treated with purified penta, and
abnormal sternebrae in animals treated with commerical penta.
14
Larsen et al. (1975) fed 60 mg/kg C-penta to pregnant
Charles River rats (CD strain) on day 15 of gestation. They
detected negligible amounts (<0.3% of administered dose) of
14
C-penta in the placentae and fetuses up to 32 hours after
dosing. This indicated that the amount of penta that passes
through the placental barrier on day 15 is negligible. In a
separate experiment reported in the same paper, a single oral
dose of 60 mg/kg of unlabeled penta administered to separate
groups of animals on days 8, 9, 10, 11, 12, or 13 of gestation
had no significant effect on the rate of fetal resorptions in
the test animals as compared with controls. However,
significant reductions in fetal weight, another fetotoxic
effect, were reported on days 9 and 10.
Hinkle (1973) reported on the absence of observed fetotoxic
effects of penta in the Golden Syrian hamster. After doses of
1.25, 2.5, 5, 10, and 20 mg/kg were administered by gavage on
days 6 through 10 of gestation, no differences were reported
250
-------
between control and test animals in these parameters: maternal
body weight, fetal weight, litter size, and number of
resorptions. There was some (unspecified) increase in maternal
toxicity at the two highest doses. The author stated that penta
was found in detectable amounts (unspecified) in the untreated
animals as well as in their diet.
Fahrig (1978) observed decreases in litter size after
intraperitoneal injection of pregnant mice at day 10 of
gestation with 50 to 100 mg/kg penta. Control mice, on the
average, produced more than 6 fetuses/dam, whereas litter sizes
in the treated groups were about 4 fetuses/dam. Penta was
administered in a 10% solution of dimethyIformamide; a vehicle
control was not reported. Litter size calculations included
dams that had no litters.
It is clear from this discussion that the higher doses of penta
can cause fetotoxic effects in experimental animals. Based on
the results of Schwetz £t al. (1974), the Agency, in PD-1, used
5.8 mg/kg/day of commercial penta as the NOEL for fetotoxicity.
iii. Studies with Dioxins
Commercial penta contains several forms of chlorinated dibenzo-p-
dioxins (see Section I.A.3.a). Schwetz e_t a.1. (1973)
administered purified HxCDD (two unspecified isomers) and
octachlorodibenzo-p-dioxin (OCDD) by gavage to pregnant Sprague-
Dawley rats on days 6 through 15 of gestation. Doses were 0.1,
251
-------
1, 10, or 100 ug/kg/day HxCDD and 100 or 500 mg/kg/day OCDD.
In these experiments/ there were significant increases over
controls in fetal resorptions at the 10 and 100 ug/kg/day doses,
as well as decreases in fetal body weight and fetal crown-rump
length. Subcutaneous edema was observed at all doses except 0.1
ug/kg/day, which was considered the no-effect dose. At the two
highest doses, dilated renal pelvis (at 10 and 100 ug/kg/day)
and cleft palate (at 100 ug/kg/day) were also observed. In
contrast, OCDD, at both dose levels (100 and 500 mg/kg/day),
produced no fetal resorptions or other effects except for an
increase in the incidence of subcutaneous edema at the high dose
level.
Significant increases over the controls in all of the
teratogenic parameters were observed at 100 ug/kg. For example,
cleft palate was observed in 47% (8/17) of the fetuses exposed
to HxCDD, compared with none (0/156) in the controls. Of the
treated fetuses, 12% (2/17) had dilated renal pelvis compared
with 0.6% (1/156) in the controls, and 31% (5/16) of the treated
fetuses had abnormal vertebrae, compared with 6% (9/158) in the
controls. In contrast, OCDD did not cause teratogenicity at 100
mg/kg/day; although 500 mg/kg/day caused subcutaneous edema, it
produced no other observable effects. Because of the extremely
high doses of OCDD required to produce an effect, the margins of
safety for this dioxin isomer are much greater than those for
HxCDD.
252
-------
As the fetotoxicity NOEL (0.1 ug/kg/day) for HxCDD is lower than
that for teratogenicity, the Agency will use the NOEL for
fetotoxicity in the quanitative assessment of risk. (Note that
errors on pages 43 and 46 of PD-1 mistakenly expressed this NOEL
as 1.0 ug/kg/day.)
b. Analysis of Specific Rebuttal Comments
This analysis of rebuttals is based on the formal rebuttal
comments and additional information received since the original
publication of PD-1.
Rebuttal Comment 1; Blood Concentrations of Penta After
Dosing (18)
Dow Chemical Company believes that the NOEL of 5.8 mg/kg/day
used in PD-1 is too low. In support of this opinion, the
rebutter provides calculations from a simulation model to show
that the theoretical average daily blood concentration of penta
after a single NOEL-dose of 60 mg/kg (Larsen e_t al. , 1975),
when averaged over 4 days, is very close to the theoretical
average after 4 days of dosing at 15 mg/kg/day. The rebutter
states that:
Based on the similarity of these average blood
concentrations during the 4 critical days of gestation, and
the fact that 60 mg/kg administered singly is a no-effect-
dose, the actual no-effect-dose for repeated administration
253
-------
is probably closer to 15 mg/kg per day than to 5^ mg/kg per
day.
Agency Response; Although the hypothetical calculations
submitted by the rebutter are interesting, the Agency is not
convinced that the results calculated from a simulation model of
a single dose (Larsen e_t al., 1975) can rebut the empirical
results of experiments based on chronic administration. Schwetz
et al. (1974) clearly showed that doses of commercial penta
greater than 5.8 mg/kg/day are capable of producing fetotoxic
effects in rats. In addition to other possibly relevant
variables, the time-course of penta blood concentration (which
is very different in the two experiments) may partially account
for the difference in NOEL values.
Rebuttal Comment 2; Terminology of Fetotoxic and Teratogenic
Effects (1, 18)
The American Wood Preservers Institute and Dow Chemical Company
state that the sole reference (Schwetz e_t al., 1974) cited in
PD-1 as evidence for the teratogenicity of penta in rats does
not, in fact, support the conclusion of teratogenic effects from
this chemical in either humans or rats. The rebutters claim
that the distinctions between teratogenicity, embryotoxicity,
embryolethality, and fetotoxicity are critical in the
interpretation of the effects of penta. They state that 1)
teratogenic effects are typically irreversible changes of a
serious nature, 2) fetotoxic changes are typically reversible
and are of lesser toxicological significance, and 3)
254
-------
embryolethality is a significant toxic end-point, but does not
result in the birth of a malformed infant and is, therefore, not
considered to be evidence of teratogenicity.
Agency Response; Generally, the term "teratogenic" is defined
as the tendency to produce physical and/or functional defects in
offspring in utero. The term "fetotoxic" has traditionally been
used to describe a wide variety of embryonic and/or fetal
divergences from the norm which cannot be classified as gross
terata (birth defects), or which are of unknown or doubtful
significance. Types of effects which fall under the very broad
category of fetotoxic effects are death, reductions in fetal
weight, enlarge renal pelvis edema, and increased incidence of
supernumary ribs. It should be emphasized, however, that the
phenomena of terata and fetal toxicity as currently defined are
not separable into precise categories. Rather, the spectrum of
adverse embryonic/fetal effects is continuous, and all
deviations from the norm must be considered as examples of
development toxicity. Gross morphological terata represent but
one aspect of this spectrum, and while the significance of such
structural changes is more readily evaluated, such effects are
not necessarily more serious than certain effects which are
ordinarly classified as fetotoxic (fetal death being the most
obvious example).
In view of the spectrum of effects at issue, the Agency suggests
that it might be useful to consider development toxicity in
255
-------
terms of three basic subcategories. The first subcategory would
be embryo or fetal lethality. This is, of course, an
irreversible effect and may occur with or without the occurrence
of gross terata. The second subcategory would be teratogenesis
and would encompass those changes (structural and/or functional)
which are induced prenatally, and which are irreversible.
Teratogenesis includes structural defects apparent in the fetus,
functional deficits which may become apparent only after birth,
and any other long-term effects (such as carcinogenicity) which
are attributable to in utero exposure. The third category would
be embryo or fetal toxicity as comprised of those effects which
are potentially reversible. This subcategory would therefore
include such effects as weight reductions, reduction in the
degree of skeletal ossification, and delays in organ maturation.
Two major problems with a definitional scheme of this nature
must be pointed out, however. The first is that the
reversibility of any phenomenon is extremely difficult to
prove. An organ such as the kidney, for example, may be delayed
in development and then appear to "catch up." Unless a series
of specific kidney function tests are performed on the neonate,
however, no conclusion may be drawn concerning permanent organ
function changes. This same uncertainty as to possible long-
lasting aftereffects from developmental deviations is true for
all examples of fetotoxicity. The second problem is that the
reversible nature of an embryonic/fetal effect in one species
might, under a given agent, react in another species in a more
serious and irreversible manner. The Agency must therefore
256
-------
consider all such deviations from normal development in its risk
assessment process, regardless of any appearance of
reversibility.
The Agency agrees that the data of Schwetz e_t al. (1974) should
be cited as evidence for fetotoxic effects, rather than for
teratogenic effects. The Agency recognizes the value of making
distinctions between teratogenicity, embryotoxicity,
embryolethality, and fetotoxicity in order to scientifically
categorize the effects of a toxic chemical. However, from a
regulatory standpoint, a fetotoxic effect may represent as
unacceptable a risk to the human fetus as would a teratogenic
effect. The studies reported in PD-1 describe terata
(malformations), fetal resorptions, and increased incidences of
normal variants over controls. Any of these adverse effects may
engender concern that a sufficient margin of safety may not
exist between the test doses in animals and the exposure levels
in humans.
In the case of technical penta, when the NOEL for the
fetotoxicity of penta is considered in light of the exposure
values, the margins of safety (MOS's) are lower than those
obtained with the respective exposure figures and NOEL for the
fetotoxicity of HxCDD. Consequently, the MOS's for the
fetotoxicity of penta will be used in Part Vto develop the
proposed regulatory decisions.
257
-------
Rebuttal Comment 3; Distinctions between Teratogenicity and
Embryotoxicity (1, 18)
The American Wood Preservers Institute and Dow Chemical Company
state that the Agency is mistaken in using the study of Schwetz
et al. (1973) to establish the teratogenicity of HxCDD because
of the Agency's failure to distinguish between teratogenic
effects and reversible, less severe anomalies. They claim these
anomalies should be characterized only as embryotoxic effects.
These rebutters state that the only finding in this study
indicative of a teratogenic event was the induction of cleft
palate. The rebutters point out that the other findings of
dilated renal pelvis, subcutaneous edema, and abnormal vertebral
development are evidence of embryotoxicity rather than
teratogenicity.
Agency Response; The 1973 paper of Schwetz et al. states
that, "By previously described definitions of teratogenicity and
embryotoxicity, HxCDD is teratogenic in the rat at 100 ug/kg
dose level...." At this dose on days 6 through 15 of gestation,
cleft palate was produced in 47% (8/17) of the rat fetuses. The
rebutters offer no evidence that any of the dose-related fetal
anomalies described are reversible. This study adequately
demonstrates that HxCDD is a potential cause of teratogenicity
and other symptoms of developmental toxicity. Discussions of
the categories of developmental toxicity (teratogenicity,
embryotoxicity, fetotoxicity, etc.) do not diminish the Agency's
concern about a chemical or its contaminants causing symptoms of
developmental toxicity.
258
-------
Rebuttal Comment 4; Relationship of Maternal Toxicity to
Fetotoxicity (1, 18)
The American Wood Preservers Institute and Dow Chemical Company
state that a 90-day toxicity study, a 2-year feeding study, and
a 1-generation reproduction study each show a NOEL of 3 mg/kg/day.
This correspondence of the NOEL values cited for fetotoxicity and
maternal toxicity is presented as evidence for a low hazard of
fetotoxicity from penta. The rebutters suggest that the observed
fetal anomalies result indirectly from toxicity to the mother, and
not from direct toxicity to the fetus. Thus, margins of safety
which would protect the mother against other toxicological
manifestations would also protect the developing embryo and fetus
against adverse effects.
Agency Response; The rebutters have not demonstrated that
maternal toxicity is the cause of the observed fetotoxicity.
The concept that the fetotoxic effects of penta do not occur at
doses lower than those causing maternal toxicity is refuted by
the study'of Schwetz e_t al. (1974). In this study there was a
significant increase in percent of fetal resorptions at 15
mg/kg/day (commercial penta), a level which produced no maternal
toxicity. Maternal toxicity did not appear until a dose of 34.7
mg/kg/day was achieved. In addition, it should be noted that
the duration of exposure required to manifest fetotoxicity in an
animal may be considerably less than the time to demonstrate a
chronic or life-time effect. For this reason, a proper
comparison of hazards involves consideration of the duration and
259
-------
timing of exposure in addition to the NOEL value comparison.
The Agency believes that the analysis of hazard to the fetus
should be considered in terms of an analysis of fetal exposure
vs. fetotoxicity, rather than exclusively in terms of a
comparison of the fetal hazard to that of some other hazard,
such as maternal toxicity.
Rebuttal Comment 5; Interpretation of Reduced Mouse Litter
Size (1, 18)
The American Wood Preservers Institute and Dow Chemical Company
contend that the study of Fahrig e^. al. (1978), reporting
decreases in litter size of female mice after intraperitoneal
injection of 50 and 100 mg/kg penta, cannot be relied upon for
three reasons: 1) evidence of pregnancy was not obtained, i.e.,
the absence of a litter may have been due to lack of pregnancy,
2) a vehicle control was not used, and 3) the route of
administration (intraperitoneal injection) bears no relationship
to the routes of human exposure to penta wood preservatives or
to treated wood.
Agency Response; The Agency agrees that the Fahrig et al.
(1978) study is not primarily concerned with fetotoxic or
teratogenic effects. Indeed, this study is basically an
examination of the mutagenic potency of the chlorophenols and
chlorophenol impurities. The conclusions of the study are based
upon the observed frequencies of various color spots in the
coats of mice. As such, the authors' comment of "decreased
litter size" is unaccompanied by supporting data or procedural
260
-------
information which would normally be essential to a study in
which litter-size observation was part of the formal protocol.
Therefore, the Agency agrees that "decreased litter size" should
be considered an ancillary comment rather than as supporting
data.
The Agency also agrees that the lack of a vehicle control makes
accurate interpretation of the results of this study difficult,
as the toxicity of the vehicle (dimethylformamide) was not
characterized by the authors.
Although the Agency generally does not use the results of
intraperitoneal experiments as the sole basis for an RPAR
notice, studies of this kind (e.g., Fahrig e_t al., 1978) can
provide valuable supporting information.
c. Summary of Rebuttal Comments Concerning Fetotoxic and
Teratogenic Effects: Conclusion
The rebuttal comments do not rebut the presumption of
fetotoxicity for penta, nor the teratogenicity and fetotoxicity
caused by HxCDD. The Agency agrees with the rebutters that pure
penta is not a teratogen.
Although Schwetz e_t al. (1974) reported a NOEL of 5 mg/kg/day
for purified penta, the Agency believes the delayed skull
ossification observed at this level is significant. Thus, as
this study has not been invalidated, fetotoxicity was
261
-------
demonstrated at the lowest dose tested.
Furthermore, the HxCDD teratology data of Schwetz e_t al. (1973)
are still valid and demonstrate the teratogenic and fetotoxic
effects of this chemical at doses above 0.1 ug/kg/day.
Additional studies, received by the Agency since completion of
PD-1, are discussed in Section II.D.5.ii.
262
-------
2. Analysis of Rebuttal Comments Concerning Human Exposure
a. Basis of Analysis
As in the preceeding rebuttal analysis (Section II.D.I),
thisanalysis of rebuttal comments is based on the formal
rebuttals and additional information received since the original
publication of PD-1. The numbers after the title of each
rebuttal comment correspond to the rebutter numbers listed in
Appendix .
In PD-1, the Agency estimated dietary, inhalation, and dermal
exposure to penta and HxCDD on a "worst-case" basis. These
estimates were based on the exposure of a pregnant woman in the
home and at work at major penta work sites (i.e., wood treatment
plants and construction sites). In accordance with the
information available in 1978, the Agency made the following
assumptions:
a) weight of a pregnant woman = 60 kg
b) absorption by the lungs = 100%
c) dermal absorption = 10%
d) area of the hands = 0.25 ft2
e) during brush application, a homeowner may spill enough
solution to cover one hand (= 10 ml)
f) a woman resides an average of 20 hours/day in her home
with a breathing rate of 1.0 m /hr
g) 6 months after pressure treatment, penta will be on the
2
wood's surface at a concentration of 0.5 mg/ft
263
-------
h) a construction worker handles wood 40 times per 8-hour
work shift
i) breathing rate for workers at construction sites and at
treatment plants = 1.8 m /hr
The only data available for PD-1 on the vaporization of penta
from treated wood in an enclosed area was that of Gebefugl et
al. (1976). They found as much as 0.16 mg/m penta in the air
of a test area treated with paint containing penta. (The
concentration of penta in the paint was not reported.)
Consequently, this figure was used to estimate the worst-case
exposure situation at home.
In February, 1976, NIOSH conducted an environmental survey of a
pressure treatment plant in Little Rock, Arkansas. This study
(NIOSH, 1977) included air sampling for penta at various sites
in the plant area. Table II.D-2 shows the results of these
analyses. For a worst-case estimate, it was assumed that the
highest concentration of penta reported, 8 ug/m , was present
throughout the plant. This same figure was used to calculate
the exposure estimate for construction workers.
The exposure estimates for penta and HxCDD in Table li.D-3 are
taken from PD-1.
b. Analysis of Specific Rebuttal Comments
264
-------
TABLE II.D-2
Pentachlorophenol Air Concentrations
at a Pressure Treatment Plant
Sampling Type of.
Operation Period (min) Sample
Hand Mix Oper . A
Hand Mix Oper. B
Sampling Man
Asst. Treater
Laborer A
Laborer B
Treating Oper.
Locomotive Oper.
Hand Mixer
Hand Mix Oper.
112
112
442
445
438
437
339
110
112
GA
GA
EQUIPMENT FAILURE -
P
P
P
P
P
P
GA
Penta Air^
Level (mg/m )
0.004
0.004
VOID
0.001
0.001
0.006
0.001
<0.001
0.008
0.003
a. From NIOSH (1977) .
b. GA = General Area; P = Personal.
265
-------
TABLE II.D-3
Estimates of Human Exposure to Penta and HxCDDc
Site
Penta
(ug/kg/day)
Dermal Inhalation
HxCDD
/kg/d
Dermal Inhalation
Home 833
Construction
Sites 8.33
Pressure Treat-
ment Plants 8.33
53.3
1.92
1.92
0.0033
0.00021
0.000033 0.0000077
0.000033 0.0000077
a. From EPA (1978).
266
-------
Rebuttal Comment 1; Fixation of Penta (1)
The American Wood Preservers Institute suggests that release of
penta into the environment is limited since penta is impregnated
into the wood.
Agency Response; It is well established that penta is not
permanently fixed within treated wood, and that penta depletion
from treated wood is an ongoing process (Walters and Arsenault,
1971). Penta volatilizes from treated wood for some time after
treatment (Thompson ejt al., 1979; Whitney and Gearhart, 1979)
and the available information does not preclude volatilization
for the lifetime of the treated wood. Environmental exposure to
penta is "limited" only in the sense that it is not applied
directly to the environment, as a broadcast pesticide would be
applied. Penta is found in the environment, and available data
demonstrate that penta-treated wood is a source of this
contamination (see Section II.D.3).
Rebuttal Comment 2; Source of Penta Residues in Human
Urine (18, 252)
PD-1 cites monitoring surveys in several U.S. locations which
found measurable penta in the urine of the general population
and in a variety of environmental samples. Dow Chemical Company
and the University of California Cooperative Extension Service
suggest that these residues may not have wood preservative penta
as their source. Instead, they suggest three indirect sources
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and one direct source. According to the rebutters, the most
likely source of penta in environmental samples is an indirect
source, the breakdown of hexachlorobenzene (HCB). Other
compounds, such as pentachloronitrobenzene, lindane, and
pentachlorobenzene, are also known to degrade to penta in the
environment and are thus other indirect sources.
Furthermore, they state lower chlorinated phenols are known to
form penta in water containing chlorine under mild pH conditions
(Smith et al., 1976). This evidence supports the possibility
that penta is formed in effluents from municipal wastewater
treatment as suggested by Detrick (1977). Finally, a direct
source of envirpnmental penta is from the widespread use of
penta in or on common items, such as paint, cordage, textiles,
•wallboard, and other products.
Agency Response; The suggestion that the most likely source
of penta in environmental samples is the breakdown of hexahcloro-
benzene (HCB) or other compounds warrants consideration. HCB
occurs in the environment from its very minor use as a
pesticide, or more probably as a byproduct of several industrial
processes. The appearance of penta in the excreta of
experimental animals following HCB administration is reasonably
well established. Mehendale et al. (1975) found that 7 days
14
after a single oral dose of C-labeled HCB to adult male
rats, about 16% of the dose was excreted unchanged in the feces
and less than 1% in the urine. Trace amounts of
pentachlorobenzene, tetrachlorobenzene, pentachlorophenol, and
four unknown products were detected in the urine. The
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investigators also showed that microsomal preparations from rat
liver were able to produce one or more chlorophenols, including
penta.
Engst e_t al. (1976) administered 3 mg HCB/kg body weight to rats
for 19 days and found penta to be the major metabolite, although
they also found small amounts of 2,3,4/6- and 2,3,5,6-
tetrachlorophenol, 2,4,6-trichlorophenol, and
pentachlorobenzene. Preliminary evidence from Yang et al.
(1975) suggests that intravenously injected HCB may possibly be
converted to penta in the rhesus monkey.
In addition to the mammalian metabolism of HCB to penta, HCB is
reported to slowly convert to penta in model ecosystem
experiments (Lu £t al., 1978). These investigators have
reported that, following addition of radio-labeled HCB added to
their terrestrial-aquatic and aquatic ecosystems, 4.8% and 0.9%,
respectively, of the total radioactivity recovered in water was
present as penta.
In addition to the in vivo production of penta from HCB, other
organic compounds produce penta as an intermediate metabolic
product. Karapally e_t al. (1973) tentatively identified penta
by gas chromotography in urine as a minor metabolite of lindane
in the rabbit. Engst et al. (1976) have reported that lindane
was excreted in a free state in considerable amounts in rat
urine. The major metabolites, which were also identified in
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urine, were penta, 2,3,4,6-tetrachlorophenol, 2,3,5,6-
tetrachlorophenol, and 2,4,6-trichlorophenol.
There is now no compelling evidence that humans synthesize
enough penta from other organic compounds to explain current
monitoring data. It is possible, however, to derive
quantitative estimates of HCB conversion efficiency in the rat.
Based on these estimates, it is then possible to calculate (see
Table II.D-4) the HCB exposure required to yield the prevailing
penta levels in human urine (Kozak, 1980). The Agency believes
it is very unlikely for the general population to be exposed to
these high levels of HCB.
Some portion of the penta contamination reported in both human
and environmental samples can be ascribed to degradation of HCB
and other organic compounds. The Agency feels that it is
unwarranted, however, to assume that all or even a major part of
this contamination results from such processes. It is not
possible, at present, to estimate the quantity of penta which
does result from metabolism of other compounds in the
environment.
The literature contains frequent suggestions that penta may be
synthesized as a result of municipal chlorination of drinking
water or wastewater. Although this has yet to be established,
available data suggest that such a process could be occurring.
Smith £t al. (1976) failed to detect highly chlorinated phenols
following the reaction of 2,4,6-trichloro-phenol with chlorine
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TABLE II.D-4
Caculated Estimates of HCB Needed to Produce
Observed Urinary Levels of Penta
Observed Total Penta HCB Needed (mg/person/day)
Urinary Penta Eliminated in with
Level Urine Conversion Efficiency of:
(ppm) (mg/day) 0 .2% 2 .0%
0.040b 0.056 28 2.8
1.8° 2.5 1200 130
0.0063d 0.0088 4.4 0.44
0.193e 0.27 140 14
a. Average human urinary elimination volume =1.4 liter/day.
b. Average level found by Bevenue ^t al. (1967) in Hawaii.
c. Maximum level found by Bevenue £t al. (1967) in Hawaii.
d. Average level found by Kutz £t al. (1978) in continental U.S.
e. Maximum level found by Kutz et al. (1978) in continental U.S.
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in dilute aqueous solution, although a number of highly
chlorinated nonphenolic products were identified. Chlorination
of 4-nitrophenol in the same system yielded small amounts of
2,3,4,6-tetrachlorophenol and 2,6-dichloro-4-nitrophenol. Penta
was not detected. Chlorination of 2,3,4,6-tetrachlorophenol in
a separate experiment yielded significant quantities of penta.
The combined results of the two experiments suggest that penta
may eventually be produced from Chlorination of 4-nitrophenol;
however, the process was not directly detected by these
investigations.
In more recent research, Smith and Lee (1978) studied the
reaction of dilute aqueous solutions of hypochlorous acid with
2,6-dichloro-, 2,4-dichloro-, and 2,4,5-trs3hlorophenol.
Although extensive Chlorination and oxidation of the phenols
were observed, penta was not detected in the reaction mixtures.
Larson and Rockwell (1979) have demonstrated that a number of
naturally occurring carboxylic acids react in dilute solution
with aqueous hypochlorite to form chlorophenols. The most
highly chlorinated compound detected was 2,4,6-trichlorophenol.
Neither tetrachlorophenol nor penta was detected. A single
report in the literature alleges that penta may be synthesized
from phenol through the Chlorination process. Detrick (1977)
claims to have found that the Chlorination of 1 ppm of phenol in
water by 10 ppm of chlorine leads to the production of about 0.2
ppb of penta. Unfortunately, neither the experimental protocol
nor the analytical method was provided in the Detrick report, so
272
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this report cannot be accepted without further confirmation.
Thus, direct production of penta following chlorination pro-
cesses in the environment has never been demonstrated. In view
of the tenuous nature of the data supporting the hypothesis,
penta production by municipal or commercial chlorination is
unsubstantiated.
Finally, it has been proposed that penta in human urine origi-
nates from non-wood uses of penta. It is difficult to assess
the relative contribution of the nonwood preservative uses of
penta to prevailing environmental levels. Much of the penta
that is not consumed in wood-treating processes is used for
slimicidal purposes in various industrial settings. In these
cases it is applied as the water-soluble salt. Pulp and paper
mills, tanneries and other industrial processes rich in organic
material require such control measures.
Penta is also used in significant amounts as a preservative for
adhesives, rubber, textiles, oils, and other materials. Some of
these uses provide more frequent opportunity for direct contact
with the chemical by the general public. In general, however,
the incorporation of penta as a preservative in these products
should result in exposure potential quantitatively similar to
that of treated wood. The resulting exposure from this group of
sources would be expected to reflect the quantity of penta used
in such applications. Hence, there is not sufficient reason to
273
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assume that non-wood preservative uses contribute a major
portion of the observed environmental penta loads. Such sources
may well account for some portion of the ambient environment
concentrations. However, without data to the contrary, common
sense suggests that these portions are related to the amount of
penta used for such applications; nonwood pesticidal uses of
penta comprise only 10 to 20% of the total penta production.
Rebuttal Comment 3; Air Pollution as Mechanism for Penta
Contamination (221)
Friends of the Earth suggests that air pollution may account for
much of the penta contamination.
Agency Response; No direct data on penta levels in ambient
air are available. Circumstantial evidence was provided by
Revenue et al. (1972) who found levels of penta in rainwater
collected in Hawaii ranging from 2 to 284 ng/liter. The penta
in rainwater likely came from washout of the chemical present in
the atmosphere either as vapor or as an occlusion on dust
particles. Penta volatilizes from the surface of freshly
treated wood (Gebefugl £t al., 1976; Thompson e_t al. , 1979)
and appears to vaporize from treated wood which has been in
service for several years (Whitney and Gearhart, 1979).
Information on the transport and persistence of penta in air is
not available. At the present time, the lack of air monitoring
data precludes definitive conclusions regarding the rebutter's
suggestion, but it does seem likely that some penta
contamination of the air may occur. The extent to which this
274
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process contributes to the prevailing environmental levels
remains speculative.
Rebuttal Comment 4; Analytical Interference (278)
Forshaw Chemical Company claims that measured background levels
of penta may not actually be penta, since naturally occurring
chemicals interfere with penta analysis.
Agency Response; Naturally occurring chlorinated aromatic
organic compounds are produced only rarely in the environment;
when this occurs at all, the compounds are usually fungal anti-
biotics produced by marine species (Siuda and DeBernardis,
1973). Pierce (1978) measured 0.3 ppb penta in water and 3 ppb
penta in sediment from ponds as a control. The presence of
penta was confirmed in these samples by mass spectrographic
analysis. While the rebutter may be correct in implying that
naturally occurring organic compounds may mimic penta in gas
chromatographic analyses, confirmation of penta1s identity by
retention time on two different columns and by mass spectral
analysis gives definite confirmation of the presence of penta at
these low level samples. Although naturally occurring organic
compounds may mimic the retention time on one gas
chromatographic column, it would be less likely to do so on two
different ones, and would definitely not give a mass spectrum
identical to that of penta. Also, the rebuttor did not provide
examples of compounds that would be indistinguishable from penta
on two gas chromatographic columns. For these reasons, the
275
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Agency rejects the rebutter's comment.
Rebuttal Comment 5; Mechanical Handling of Treated Wood (18)
Dow Chemical Company states that dermal exposure is negligible
during pressure treatment because the treated wood is handled
mechanically.
Agency Response; The Agency agrees with this rebuttal com-
ment for the actual treatment process. In plants visited and in
discussions with industry representatives, it is apparent that
for pressure treatment facilities, wood is handled mechanically
(forklift, stackers, etc). For subsequent handling, wood may or
may not be moved mechanically. If moved manually by workers
with gloves, then exposure is negligible, but the rebutter has
not demonstrated that all operations are mechanical, nor that
workers wear gloves at all times during manual operations.
Thus, dermal exposure is still possible.
Rebuttal Comment 6; Protective Gloves and Treated Wood (1,- 18)
The American Wood Preservers Institute and Dow Chemical Company
claim that dermal exposure to construction workers from the
handling of pressure-treated wood is negligible because: 1) the
wood is dry, and 2) the workers wear gloves.
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Agency Response; The Agency believes there are many cases
when gloves are not worn. Also, data from Koppers Chemical
2
Company indicate that as much as 0.5 mg/ft penta is on the
surface of pressure-treated wood 6 months after treatement.
Rebuttal Comment 7; Protective Gloves and Sapstain Control (4)
Chapman Chemical Company claims that exposure to sodium penta
resulting from sapstain treatment is negligible because the wood
is handled mechanically and because gloves are worn.
Agency Response; The Agency agrees that dermal exposure is
not significant if treated wood is handled only mechanically.
In an Agency memorandum about a site visit by Agency personnel
to observe sapstain treatment, it was concluded that treated
wood is generally handled automatically during treatment
(conveyor systems, etc.) and that human contact is slight.
Subsequent stacking and handling is done in most cases by
workers wearing gloves. However, unlike pressure treatment in
which treated wood is generally not handled while it is wet (see
comment 5), sapstain treatment does result in wet wood.
Thus,there is the possibility of exposure while handling the
treated wood even when wearing gloves. The PD-2/3 exposure
analysis provides estimates of dermal exposure to sapstain
workers with or without gloves.
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Rebuttal Comment 8; Dermal Retention (18, 252, 254, 481)
Dow Chemical Company, the University of California, Vulcan
Chemical Company, and the National Forest Products Association
provided comments to refute EPA's estimate for exposure to penta
from application of 5% penta. The Agency assumed that 10 ml of
solution would adhere to the surface of one hand. Dow states
that Weaver (see Dow Chemical Company, 1978) shows water
retention on a women's hand to be 3 ml. Vulcan also estimated 3
ml as a maximum amount. The University of California rebuttal
claims that since penta is a skin irritant, an applicator would
quickly wash it off, and there would be little dermal absorption.
Agency Response; In view of the experimental data supplied by
Dow, the Agency agrees that 3 ml is a reasonable estimate of the
quantity of solution which would adhere to the skin of a human
hand. The Agency does not accept the point that penta would
invariably be removed quickly enough to prevent any absorption.
Rebuttal Comment 9; High Dermal Absorption Rate (278)
Forshaw Chemical Company states that EPA's estimate of 10%
dermal absorption is too high. The rebutter did not supply
evidence to refute this estimate.
Agency Response; From the Agency's Pesticide Incident
Monitoring System data, it is readily apparent that penta can be
absorbed through the skin. Listed incidents detail skin contact
278
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that resulted in a systemic intoxication to the users. Thus.it
is clear that penta is absorbed through the skin. The rate of
absorption is not known. The rebuttal comment, claiming 10%
absorption was too high, did not supply evidence to the
contrary. The absorption estimate of 10%, based on the results
of Maibach and Feldman (1974) with several chlorinated
hydrocarbons, will be retained until evidence is supplied
showing the Agency's estimate to be in error.
Rebuttal Comment 10; Dermal Absorption of Sodium Penta (252)
The University of California comments that sodium penta is more
slowly absorbed than the lipid-soluble penta molecule. (In
aqueous solutions, most of the penta is present as the penta-
chlorophenate ion.) The rebutter believes that, when
calculating the dose of sodium penta absorbed through the skin,
the proper absorption factor would be lower than that used for
calculating penta absorption.
Agency Response; Data on rabbits (Kehoe et al., 1939)
suggest that the hazard from continuous dermal dosing with 1 to
2% aqueous sodium penta is not greatly different from the hazard
of the same treatment with penta in mineral oil. Also, a recent
review of the literature (Kozak et al., 1979) clearly
indicates that cutaneous application of sodium penta is lethal
to test animals. The Agency is not aware of experimental data
which would rebut the use of 10% as a reasonable dermal
279
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absorption factor for calculating dermal absorption from
repeated exposure to sodium penta.
Rebuttal Comment 11; Absorption of Penta by Inhalation (18)
Dow Chemical Company states that the EPA assumption "that a
chemical is 100% absorbed by inhalation exposure is not
supported by the literature." The rebutter believes that 70%
respiratory absorption of penta is a more accurate figure than
100%.
Agency Response; In the absence of adequate quantitative data
on penta inhalation, the Agency continues to believe that 100%
inhalation absorption is a reasonable estimate of a worst-case
situation. Furthermore, the study of Hoben e_t al. (1976)
presents data, albeit incomplete, apparently showing greater
than 70% inhalation absorption in the rat.
Rebuttal Comment 12; Inhalation Exposure During Sapstain
Treatment (4, 252)
Chapman Chemical Company and the University of California claim
that inhalation exposure is negligible during sapstain treatment
operation because evaporation of sodium penta is negligible, and
because spray is not generated.
Agency Response; Inhalation exposure may be significant
during sapstain treatment operations since sapstain preservative
280
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solutions may be applied to lumber by either dip or by spray.
The Agency agrees that volatilization of penta from aqueous
sodium solutions is likely to be extremely small. Since these
solutions are basic, the penta is largely present in the
nonvolatile salt form. Sapstain solutions, however, are often
applied by spray methods and available data indicate that
measurable amounts of airborn penta are detectable in the
vicinity of spray operations. The maximum reported penta air
concentration in close proximity to the spray booth was reported
3 3
as 69 ug/m by Arsenault (1976) and as 4 ug/m by the
National Forest Products Association in their rebuttal to PD-1.
The 69 ug/m air level will be used to derive a maximum
predicted inhalation exposure in the exposure analysis.
•Rebuttal Comment 13: Women's Breathing Rate (1, 18, 481)
The American Wood Preservers Institute, Dow Chemical Company,
and the National Forest Products Association, state that the
respiratory rates for women cited in PD-1, 1.8 m /hr, are un-
realistically high, resulting in an overestimate of human
inhalation exposure. They suggest that a more probable breath-
ing rate for a woman is 1.0 m /hr (Altman et al., 1958).
Agency Response; The Agency acknowledges that the breathing
rates cited in the PD-1 may overestimate inhalation exposure
among the population group at risk (i.e., women of child-bearing
age). Consequently, the following respiratory rates for women
281
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have been abstracted from Altman et al. (1958) and will be used
for development of the PD-2/3 exposure analysis:
resting - 0.27 m3/hr
light work - 0.98 m3/hr
heavy work - 1.47 m /hr
Rebuttal Comment 14; Inappropriate Use of Inhalation
Measurement (18)
Dow Chemical Company claims that to derive an exposure esti-
mate, the Agency simply used the same inhalation exposure figure
calculated for pressure treatment plant workers. That figure
was based on the airborne concentration of penta found next to
the plant hand mixer, as measured by NIOSH in 1976. It is
improper to use an inhalation exposure number found during a
high exposure plant operation, when the wood has been freshly
treated, as an estimate for construction workers. Inhalation
exposure to a construction worker, after the penta has been
impregnated into the wood, would be negligible.
Agency Response: Penta depletion from treated wood has been
recognized for many years (Walters and Arsenault, 1971), but the
precise mechanism for the depletion has not been ascertained.
Available data (Thompson e_t al., 1979; Whitney and Gearhart,
1979) suggest that volatilization of penta from treated wood
occurs for time periods well in excess of 6 months and that such
processes may occur for many years. No information presently
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exists to suggest that penta is permanently bound into treated
wood. Thus construction workers are expected to incur some
degree of penta exposure via inhalation.
The Agency agrees that air levels measured during commercial
wood treatment may not be appropriate for construction workers.
Hence, the air levels used for construction worker exposure in
PD-1 will not be used in PD-2/3. Rather, the penta air levels
reported by Wyllie e^ al. (1975) in the wood storage area of a
small wood treatment plant in Idaho are deemed more appropriate
for the estimate of construction worker inhalation exposure in
most instances. It is believed that occupational exposure to
treated wood may occasionally occur in poorly ventilated set-
tings such as storage sheds, railroad cars, and warehouses. For
these settings, air levels derived in volatilization experiments
(Thompson et al., 1979) with treated wood will be used in the
Exposure Analysis.
Rebuttal Comment 15: Margin of Safety for Inhalation
Exposure (1)
The American Wood Preservers Institute claims that there is
already an ample margin of safety for the application and use of
penta as a wood preservative. This claim is supported by the
OSHA Threshold Limit Value (TLV) for penta, which already
includes a regulatory margin of safety. The air concentration
data used by EPA to assess treatment plant exposure indicate
that air levels rarely approach even the OSHA standard; when
283
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levels do approach the OSHA TLV, it is only under unusual cir-cum-
stances.
Agency Response; The fact that penta air levels in commer-
cial plants rarely exceed the OSHA TLV of 0.5 mg/m does not
necessarily indicate that an adequate margin of safety exists.
The OSHA TLV was promulgated to ensure that inhalation exposure
to penta would not be acutely toxic. The toxic effects in
question for the RPAR of penta are chronic in nature and margins
of safety will be developed by the Agency based on these effects .
Rebuttal Comment 16; Inhalation Exposure to Homeowners and
Farmers (4, 18, 278)
Chapman Chemical Company, Dow Chemical Company, and Forshaw
Chemical Company state that inhalation exposure calculations
should be limited to the time spent during application in a well-
ventilated area. Since homeowners are unlikely to use penta
more than a few times a year, their exposure to penta via
inhalation will be intermittent.
Agency Response; Human inhalation exposure resulting from the
application of over-the-counter penta formulations may take two
forms: inhalation during the application phase, and inhala- tion
of vapors or particulates from the surface of the treated wood
after application. The Agency agrees that most applica- tions
of these products by homeowners and farmers will take place
-------
outdoors during treatment of decks, fenceposts, wood siding, and
other exterior wood structures.
Inhalation exposure to penta vapors or particulates from
exterior surfaces of treated wood following application to
exterior structures is expected to be extremely low. The Agency
agrees that when penta is applied to wood in a well-ventilated
area, and when the treated structure remains outdoors, the human
inhalation exposure will be "intermittent" in nature, since
homeowners or farmers would be expected to apply penta formula-
tions to new or existing wood for a short time once every
several years. An exception to this might be the case of a
farmer who carries out much of his penta application over a
single extended period every few years or engages in an inten-
sive dipping operation for fence posts when a fence is replaced
or installed. If, however, penta formulations are applied on
the inside of wooden structures (barns, storage sheds, homes,
etc.), exposure to vapor or to particulates will occur both
during and following the application phase (see comment 17).
Thus, while it is true that in many situations homeowners' and
farmers' exposure to penta will be intermittent, this is not
always the case.
Rebuttal Comment 17; Homeowners' and Farmers' Inhalation
Exposure in Enclosed Areas (4, 18, 278)
Chapman Chemical Company, Dow Chemical Company, and Forshaw
Chemical Company state that EPA calculated inhalation exposure
285
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based on a study where paint containing penta was used to treat
wood in an enclosed area, and then assumed that a woman could be
exposed for 20 hours a day.
They state that labels on consumer products containing penta
warn against the products on interior wood and direct the user
to ensure adequate ventilation during application. Users that
violate label directions should not be considered to be
practicing "widespread and commonly recognized patterns of use."
Estimates of inhalation exposure should not, therefore, be based
on concentrations in enclosed areas within the home.
They further state that the evidence used for this exposure
estimate is not suitable for quantitative analysis. At most,
one might conclude that penta solutions should only be used on
interior wood that is to be finished with a coating. In addi-
tion, the penta volatilization rate will be markedly reduced
after it dries.
Agency Response: The Agency has information (PIMS, 1978J
indicating that penta formulations and penta-treated wood are
used inside homes, and this may result in continuous exposure
to penta air levels which exceed the levels detected in many
commercial settings (see Section ll,D.3.h - •> ^ -
A point which has been made by several rebuttors is that penta
should not be used on interior wood of homes and that such
practice is a "misuse" or an "imprudent use" and hence not a
286
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concern of the regulatory process. If all over-the-counter
products containing penta possessed labels prohibiting use
inside homes or on structures where constant dermal contact by
humans was likely, the point would have some merit. However,
many currently registered products do not possess labels which
contraindicate such usage. As a consequence, application of
these products in homes cannot be considered a "misuse" from
either a legal or practical standpoint. For instance, in a case
of penta poisoning in California following use of penta in a
home (EPA, 1978), label directions on the formulation used did
not caution against indoor use.
The extent of human exposure from such use depends on the type
of structure (home vs. barn), the degree of ventilation, tempera-
ture, the length of time spent in the structure, and many other
variables. Since many labels of over-the-counter penta formula-
tions sold do not warn against use in enclosed structures (inclu-
ding homes), use of such products according to label instruc-
tions may result in significant penta levels within human habita-
tions. Exposure times as high as 24 hours are reasonable for
worst case analysis of such a situation.
In the worst-case analysis developed in PD-1, 0.16 mg/m was
used as a maximum expected air concentration from volatilization
of penta from treated wood. This penta air level is realistic,
despite the fact that it was taken in an unventilated room at
29°C (84°F). In the absence of air exchange, the
equilibrium vapor density of penta at 25°C would lead to a
predicted air level of 2.2 mg/m3. Laboratory results of
287
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Thompson et al. (1979) conducted in a cylinder with a 2% air
exchange rate per minute at 25°C indicate that penta levels of
0.025 to 0.040 mg/m may occur due to volatilization from
pressure treated lumber. In California incidents where the
interiors of homeswere heavily treated with penta occupants
became ill, the penta air concentrations ranged from 0.5 to 30
ug/m3 (Mengle, 1980).
Many log homes in this country have been constructed with logs
treated with penta. This Agency recently cooperated with the
Center for Disease Control in a study of penta levels in
residents of Madison Couny, Kentucky (see Section II.D.4.b). In
the course of this study two air samples were obtained from a
single log home, the logs of which had been treated with penta.
These air samples contained 0.20 and 0.38 ug/m penta.
So far, this discussion concerns only the level of penta vapor
that may occur in enclosed spaces. If significant blooming of
crystalline penta were to occur, penta dust and particulates
could become airborne as a result of housecleaning and other
activities. The resulting penta inhalation exposure would then
be a combination of vapor and dust exposure. A precise quantita-
tion of the dust exposure in such settings is not possible.
Although human inhalation exposure during indoor application of
penta formulations may be intermittent, exposure following appli-
cation in enclosed spaces may occur for an indefinite period of
288
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time. Hence, a worst-case approach may justifiably assume a
continuous (24 hour), rather than an intermittent, exposure.
There is no evidence to indicate that the penta volatilization
rate will be reduced by the drying of wood treated with over-the-
counter penta formulations. In fact, recent experiments
(Thompson ejt al., 1979) indicate that penta volatilization
from treated wood may occur for an extensive time period
(greater than 6 months) after treatment. Although these
experiments were conducted with pressure-treated wood, the
Agency believps, in the absence of evidence to the contrary,
that penta will volatilize for an extended period of time from
wood surfaces treated with over-the-counter products.
The use of paints or sealants has yet to be adequately addressed,
Preliminary laboratory work by Thompson e_t al. (1979), however,
indicates that oil and water-based paints may reduce (but not
eliminate) penta volatilization from pressure treated wood.
Rebuttal Comment 18; Alternative Exposure Analysis (481)
The National Forest Products Association rebuttal contains an
extensive exposure analysis which differs substantially from the
Agency analysis in PD 1. Dermal, oral, and inhalation exposure
of workers and members of the general population using penta
formulations were estimated for two situations: a "worst-case
analysis," which the rebutter believes represents short-term
worker exposures occurring infrequently, and "average" exposure
289
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values which are believed to exemplify typical day-to-day expo-
sures. Assumptions for the worst-case analysis are:
a) individual's weight = 70 kg
b) absorption by the lungs = 70%
c) dermal absorption = 10%
2
d) average area of the hands = 0.25 ft
e) gloves are not worn
f) an 8-hour work shift consists of 4 hours at heavy
breathing rate (2.52 m /hr) and 4 hours at a moderate
breathing rate (1.0 m /hr)
Also, this exposure analysis uses the maximum reported air
concentration found in the literature.
The assumptions for the average worker exposure which differ
from those for the worst-case analysis are:
a) gloves are worn
b) an eight-hour work shift consists of eight hours at a
o
moderate breathing rate (1.0 m /hr)
For this analysis the average reported air concentrations found
in the literature are employed.
Agency Response; Absorption of penta by the dermal and
inhalation routes is discussed elsewhere in this rebuttal
analysis (see comments 9, 10, and 11). The Agency has decided
that 60 kg is a more typical weight for a female worker. Also,
290
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3 3
the Agency has selected 0.98 m /hr and 1.47 m /hr as the
breathing rates most appropriate for a female worker at light
and heavy work, respectively (Altman et al., 1958). The PD-
2/3 exposure analysis will be developed for a reasonable upper
limit of exposure. Consequently, for the calculations in this
analysis, the Agency makes these assumptions:
a) individual's weight = 60 kg
b) absorption by the lungs = 100%
c) dermal absorption = 10%
2
d) average area of the hands = 0.25 ft
e) gloves are not worn
f) an eight-hour work shift consists of six hours at a
moderate breathing rate (0.98 m /hr) and two hours
at a heavy breathing rate (1.47 m /hr)
Rebuttal Comment 19; Overestimation of Exposure Potential (18)
Dow Chemical Company states that EPA overestimates the
theoretical potential exposure for the general population .by
dividing the total annual penta production by the number of
people in the general population.
Agency Response; The Agency agrees that this method of
exposure estimation is inappropriate. Consequently, this
procedure is not followed in this PD-2/3.
291
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Rebuttal Comment 20; Market Basket Survey Results (252)
The University of California Cooperative Extension Service
claims it is inappropriate for EPA to average the Market Basket
Survey results in food over the entire diet, stating that it is
improper to average the content of a few samples positive for
penta over an entire group of samples in each category.
Agency Response; Table 12 of PD-1 provides an estimate of
dietary penta from several major food categories. The Agency
believes these average and maximum values for penta are entirely
appropriate because the estimates are based on measured residues
in the major food categories, and the average intake estimates
are based on Department of Agriculture studies.
The rebutter points out that some of the food categories may
have had only a few samples positive for penta (e.g., 1 of 20).
The Agency did not intend to state that all samples contained
penta, but rather that these figures are useful in estimating a
possible average of dietary intake. Also, it is theoretically
possible for fetotoxic effects to result from a single exposure
to a fetotoxic agent, if a fetotoxic dose is administered during
the critical time of gestation. Thus, the Agency does not
accept the rebutter's comment as valid.
292
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Rebuttal Comment 21; Misuse (18)
The Dow Chemical Company suggests that abnormally high levels of
penta reported in worker's blood reflects misuse.
Agency Response: In PD-1 (page 10), the Agency cited a paper
by Arsenault, in which blood of wood treatment workers in a
pressure plant was measured for penta. It was found that of the
occupationally exposed workers, the wood treaters (21 people)
had the highest mean level of penta in the blood stream (1.05
ppm). Other workers in pest control occupations had lower
levels of blood penta. The control group had blood plasma
levels of 0.1 ppm penta. This reference indicates that wood
treaters using penta have average blood levels 10 times higher
than a control group.
The claim that misuse is the cause of high levels of penta in
the blood of workers is a moot point because, first, if it is in
fact misuse, then more stringent controls may need to be
implemented to lower exposure and, second, if it is not misuse,
then health standards still have to be strengthened. The Agency
thus rejects the rebuttal comment because more controls for
reducing exposure appear to be needed in any case.
Rebuttal Comment 22; Exposure of Pregnant Women (278)
Forshaw Chemical company claims that use of the term "pregnant
woman" is unnecessary, prejudicial, and discriminatory unless it
293
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can be shown that pregnant women are exposed to significantly
different levels of penta.
Agency Response; Use of the term "pregnant woman" is entire-
ly appropriate in this instance. The RPAR criteria presented in
PD-1 for penta were teratogenicity and fetotoxicity. Conse-
quently, the only members of the human population at risk are
women who are pregnant. It is reasonable to develop an exposure
analysis based on susceptible members of the population at
risk. However, henceforth in this PD-2/3 the phrase "women of
child-bearing age" will be used in place of "pregnant woman."
Rebuttal Comment 23; Penta Residues in Higher Plants (221)
Friends of the Earth criticizes PD-1 for stating that "there are
no data on penta residues in higher plants resulting from its
use as a. pesticide." This rebutter cites a report by Haque et
al. (1978) indicating that rice plants in the laboratory,
following treatment of the soil at an application rate
corresponding to agricultural practice, can absorb penta.
Agency Response; The PD-1 statement mentioned by the rebut-
ter is correct as it stands. There are still no data on penta
residues in higher plants resulting from its use as a pesti-
cide. Laboratory studies which show that penta may be absorbed
by vascular plants are merely indicative that such processes may
occur in the environment. Nevertheless, the report presented by
the rebutter (Haque et al., (1978)) is valuable in that
294
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translocation of penta from the soil to the foliage of rice
plants was demonstrated in the laboratory. Whether such a
process in the environment causes significant residues in edible
portions of vascular plants is not known, nor is it known how
the wood preservative uses of penta might contribute to these
possible residues.
Rebuttal Comment 24; Penta Residues in Human Seminal Fluid (221)
Friends of the Earth criticizes PD-1 for failing to mention that
penta residues have been detected in human seminal fluid by
Dougherty and Piotrowska (1976) .
Agency Response; The results of Dougherty and Piotrowska
(1976) were mentioned in PD-1 on page 11.
295
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3. Revised Human Exposure Analysis
a. Assumptions and Methods
All exposure estimates in this analysis are based on these
assumptions:
a) weight of a woman of cnild-bearing age = 60 kg
b)absorption by the lungs = 100%
c) dermal absorption = 10%
d) breathing rate at rest = 0.27 m /hr
e) breathing rate during light work = 0.98 m /hr
f) breathing rate during heavy work = 1.47 m /hr
Inhalation exposure, which results from absorption of chemicals
across the alveolar respiratory membrane, can be determined from
measurements of the amount of chemical in the air.
Concentrations in air are expressed as either parts per million
(ppm) or weight of chemical per cubic meter (m ) of air. The
amount of air actually entering the lung per minute (minute
alveolar ventilation) is determined, then multiplied by the
number of minutes of exposure and by the air concentration. The
resulting exposure is expressed as weight of chemical per kg of
body weight per day.
There are two major difficulties with this approach. First,
minute alveolar ventilation is not constant. Respiratory rates
and the amount of air per breath (tidal volume) can change
296
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manyfold depending on the level of physical exertion and tissue
oxygen demand. Consequently, assumptions need to be made about
level of physical activity for a particular type of work. The
breathing rates for human females that will be used for this
analysis were taken from Altman et al. (1958).
The second problem is the physical state of the chemical in the
air. If the material is a particulate, that is dust, then the
larger particles (those greater than 10 microns in diameter) are
either filtered out by the turbinates in the nose or are
deposited in the pharynx, trachea, or larger bronchi. Material
deposited in these places is removed by ciliary action and the
material is gradually moved to the back of the mouth where it is
swallowed or spit out. If it is swallowed, oral exposure occurs
in addition to inhalation exposure. Smaller particles and
vapors reach the deep parts of the lung where they are absorbed
into the blood or lymph and are subsequently translocated to the
other parts of the body.
Inhalation exposure estimates can be developed in one of two
ways. The first method uses the published penta air levels for
both occupational and non-occupational settings, assumes a given
exercise level, exposure duration, absorption rate and body
weight, and then a mg/kg body weight exposure estimate is
developed. The second method uses either theoretical penta
vapor levels or data derived from laboratory measurements to
develop similar estimates. The former method is preferable when
enough data are available. Despite the uncertainties inherent
297
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in extrapolating from laboratory data to the environment, the
second approach can provide valuable information in situations
where monitoring data are not available. Both of these methods
will be used in this exposure assessment.
In contrast to the large body of data available on air levels of
penta associated with wood preservation, from which estimates of
inhalation exposure were prepared, very little information is
available on actual levels of dermal exposure. PD-1, in fact,
relied upon the assumption that dermal exposure in pressure-
treatment plants "is at least equal to exposure at construction
sites .*" There were very few rebuttal comments about dermal
exposure from wood preservative uses of penta, even though the
Agency invited registrants to "provide data and information to
confirm, refine, or rebut the information upon which the
exposure estimates are based." Review of the available
literature on dermal exposure measurements for pesticides,
however, yielded additional information which will be used to
extend the original estimates given in PD-1.
Exposure to hexachlorodibenzo-p-dioxin (HxCDD) and
hexachlorobenzene (HCB) are developed using the same assumptions
as for penta. In addition, these assumptions are also made:
first, the HxCDD and HCB content of technical penta and sodium
penta currently in the market place is 15 ppm and 100 ppm,
respectively, and second, exposure to these penta impurities is
proportional to the levels of the compounds in technical penta.
Using these assumptions, exposure to HxCDD is equal to the penta
298
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exposure times the factor 15 x 10 (15 ppm) and exposure to
HCB is equal to penta exposure times the factor 100 x 10
(100 ppm).
Because the vapor pressure of HxCDD is significantly lower than
that of penta (800-fold lower), inhalation exposure to HxCDD has
been estimated only for situations where dust or mist formation
is likely to occur. HCB, on the other hand, is slightly more
volatile than penta. Thus HCB inhalation exposure has been
estimated for all situations where respiratory exposure to penta
is likely.
It is important to recognize that the estimates of dermal
exposure to HxCDD and HCB based on this assumption of
proportionality are most reliable when exposure to penta
formulations or freshly treated wood occurs. These estimates
are less reliable in cases of exposure to treated lumber after
weathering, as volatilization and photochemical processes will
have occurred which may alter the original proportions of the
contaminants.
b. Penta Concentrations Measured in Air
i. Occupational Settings
Penta levels in air have been reported for wood-treated plants
(NIOSH, 1975; NIOSH, 1977; Wyllie et _al. 1975; Rapp, 1978) and
for several nonoccupational settings (Whitney and Gearhart,
1979). These data can be used to estimate respiratory exposures
299
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The penta air levels determined by Wyllie et al. (1975) at a small
wood treatment plant in Idaho are given in Table II.D-5.
Rapp (1978) presented the results of a series of industrial
hygiene surveys conducted by Dow Chemial Company scientists at
28 users' sites. Penta air levels were determined for three
exposure situations: while emptying penta bags, while opening
the pressure cylinder door, and while engaged in routine plant
activities (see Table II.D-5).
NIOSH (1975) has conducted a health hazard evaluation
determination at a major wood-treatment firm in De Queen,
Arkansas. As a part of this evaluation, 24 air samples were
collected on the premises and analyzed for penta (see Table II.D-
5).
Morton and Freed (1973) reported the results of a penta worker
exposure study conducted by the Environmental Health Sciences
Center, Oregon State University. Air samples were taken at 25
companies using penta as a wood preservative. Seven companies
were engaged in dip treatment operations, seven were pressure
treatment firms, and eleven used sodium penta as a spray
treatment for sapstain control (see Table II.D-5).
Table II.D-6 contains estimates of penta inhalation exposure at
various levels of exercise. The assumptions used in the
analysis have been given previously. Inhalation exposures were
calculated on the basis of the penta air levels in industrial
settings previously discussed.
300
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TABLE II.D-5
Penta Air Concentrations at Various Treatment Plant Sites
Penta Air Concentration
Site
(mg/m3)
Average Value Maximum Value
Reported Reported
;a
Pressure treatment room
Office3
Treated wood storage area
Penta storage area3
Dip tank area
Emptying penta bags
r_
Opening cylinder door
General operations
Emptying penta bags0
General operations
Dip treatment: general grounds
d
maximum exposure area
Spray treatment (sapstain): ,
general grounds
d
maximum exposure area
0.006
0.0018
0.00026
0.001
0.0002
0.3
0.13
0.004
0.85
0.00007
0.019
0.019
0.006
0.026
0.015
0.0035
0.0026
0.0039
0.0008
18.5 (65)
13 (150)
0.02
3.83
0.00044
0.003
0.063
0.012
0.069
301
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TABLE II.D-5 (Continued)
Pressure treatment: ,
general grounds 0.014 0.028
maximum exposure area 0.296 1.000
a. From Wyllie e_t _al. (1975).
b. From Rapp (1978); numbers in parentheses are unusually high
values.
c. From NIOSH (1975) .
d. From Morton and Freed (1973).
303
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TABLE II.D-6
Estimates of Penta Exposure at Various Treatment Plant Sites
Estimated Penta Exposure
(ug/kg/8 hr) at:
Sites
Rest Light Work Heavy Work
Pressure treatment
Office3:
Wood storage area :
Penta storage area
Dip tank area :
Emptying penta bags
room :
average
maximum
average
maximum
average
maximum
average
maximum
average
maximum
b.
average
maximum
Opening cylinder door :
average
General operations
maximum
: average
maximum
Emptying penta bags :
average
General operations0
maximum
: average
maximum
0.216
0.54
0.065
0.126
0.0094
0.094
0.036
0.14
0.0072
0.029
10.8
2,340
4.68
5,400
0.144
0.72
30.6
138
0.0025
0.016
0.782
1.96
0.235
0.456
0.034
0.34
0.13
0.51
0.026
0.104
39.1
8,476
17.0
19,560
0.522
2.61
111
499
0.0091
0.057
1.18
2.94
0.353
0.686
0.051
0.51
0.196
0.76
0.039
0.157
58.8
12,740
25.5
29,400
0.784
3.92
167
751
0.014
0.086
304
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TABLE II.D-6 (Continued)
Dip treatment :
general grounds,
maximum exposure
average
maximum
area ,
avearge
maximum
Spray treatment (sapstain) :
general grounds, average
maximum exposure
d
Pressure treatment
general grounds,
cylinder door,
maximum
area ,
average
maximum
•
•
average
maximum
average
maximum
0.684
2.27
0.684
2.27
0.216
0.432
0.94
2.48
0.504
1.01
10.7
36
2.48
8.22
2.48
8.22
0.782
1.56
3.39
8.99
0.83
3.65
387
130
3.72
12.35
3.72
12.35
1.18
2.35
5.10
13.5
2.74
5.49
58.2
196
a. From Wyllie et al. (1975).
b. From Rapp (1978); ..maximum values are calculated using 65 and
150 mg penta/m figures in Table 1.
c. From NIOSH (1975) .
d. From Morton and Freed (1973).
305
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Calculated exposure rates developed in Table II.D-6 range from
0.0025 to 29,400 ug/kg/8-hr. It is important to realize that
exposure levels calculated for a heavy exercise level are
presented for illustrative purposes only. A heavy exercise
level for an entire 8-hour work shift is an unlikely
possibility. A light exercise level for 6 hours and 2 hours of
heavy work will be used to calculate the maximum predicted daily
exposure for a female in an industrial setting. The data
indicate that the greatest respiratory exposure may occur when
the pressure cylinder door is opened or when workers are engaged
in emptying penta bags. The opening of the cylinder door is a
separate occurence which takes place, at most, twice per working
shift per cylinder. Duration of this activity is expected to be
short (less than 20 minutes). The Agency believes it is
unlikely that a worker will be involved in this activity for
more than 1 hour per day. The remaining 6 to 7 hour penta
exposure during a working day would be at the lower background
level for plant employees.
Emptying penta bags is an operation for which exposure for a 4-
hour period during an 8-hour work shift might be expected
(Nicholas, 1980). As a result, the calculated exposure levels
in Table II.D-6 may be multiplied by four in order to
approximate the actual exposure during bag emptying operations.
It must be emphasized that the analysis above considers
inhalation exposure alone. Total human exposure includes dermal
and oral exposure as well, and estimates of these levels will be
306
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included where possible in order to arrive at an estimate of
total daily exposure.
ii. Nonoccupational Settings
Fewer data are available for penta air levels in nonoccupational
settings. Much of this information is derived from case studies
in which penta formulations or penta-treated wood were used
indoors. In a number of cases (California, 1980) where human
illness was associated with the use of penta indoors, reported
penta air concentrations ranged from 0.5 to 30 ug/m .
Whitney and Gearhart (1979) collected and analyzed air samples
for penta in four buildings, ranging in age from 3 to 7 years.
Treated wood in the structures consisted of 6 in. by 6 in.
timbers spaced on 9-ft. centers, with, some buildings having 2
in. x 6 in. boards around the lower periphery to support the
sheet metal skin. The structures were ventilated by open eaves
or louvered gables or both, and air sampling of building #2 was
conducted with its large door open. The investigators noted
that all the structures studied for the project contained mini-
mal treated-surface-to-enclosed-volume ratios and that ambient
temperatures at the time of sampling ranged from 11.5 to 25.0°C.
They detected low penta air concentrations in all of the
buildings. Table II.I>-7 presents their results.
These authors suggest, however, that the penta concentrations
observed in their study may represent a low estimate of the
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TABLE II.D-7
Penta Air Concentrations in Buildings0
Age of
Building
Building (months)
1 8
2 84
3 5
4 36
Ambient Temp.
at Sampling
Time ( C)
11.5
16.0
15.5
25.0
Number of
Samples
1
2
3
5
Average Penta
Concentrations
(ug/m3)
0.43
0.26
0.37
0.51
a. From Whitney and Gearhart (1979).
308
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airborne penta in many treated structures; one would expect-
higher penta levels in structures where treated wood is more
extensively used, where ambient temperatures are higher, o*-
where buildings are more tightly sealed.
c. Penta Residues in Human Urine and Serum
There are considerable data on penta residues in human urine.
This information has been compiled and presented as Tables II.D-
8 and II.D-9. It is clear that penta is prevalent in the urine
of the general population. The results of Kutz e_t al. (1978)
indicate that, among the pesticides detected in the Health and
Nutritional Examination Survey II (HANES II) of the National
Center for Health Statistics, penta was the most ubiquitous
compound encountered; it was found in 85% of the urine samples
analyzed. As would be expected, urinary penta levels among
occupationally exposed persons (Table II.D-8) exceed the'
concentrations found in the general population (Table II.D-9).
As pointed out in the Agency's response to comment 17 (Section
II.D. 2.b) , Lakings et al. (1980) found penta air levels of 0.20
and 0.38 ug/m in a penta-treated log home. The levels of
penta in the urine and serum of the residents of this home are
presented in Table II.D-10.
309
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TABLE II.D-8
Penta in Urine of Occupationally Exposed Populations
Penta Concentration
Population Number of Number of
Description People Analyses
Commercial pest
control operators
a
No description
b
Dip treaters
Dip treaters0
b
Pressure treaters
c
Pressure treaters
d
Pressure treaters
Pressure treatment
plant employees
Sapstain treaters
( spray method)
Carpenter
Boat builder
Sprayman
Sprayman
130 210
121 121
11 136
11 99
e 6
___
1 4
1 4
1 4
1 4
in Urine (ppm)
Min. Max. Mean
0.003 35.7 1.8
0.003 38.6 0.47
2.6
0.12 9.68 2.83
1.6
0.17 5.57 1.24
0.11 1.85 0.49
0.043 0.76 0.164
0.13 2.58 0.98
0.024
0.057
0.133
0.265
a. From Bevenue et al. (1967); location = Hawaii.
b. From Casarett et al. (1969); location = Hawaii.
c. From Morton and Freed (1973); location = Oregon.
d. From NIOSH (1975); location = Arkansas.
e. From Wyllie e_t al. (1975); location = Idaho.
f. From Cranmer and Freal (1970); location = Great Britain.
310
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TABLE II.D-9
Penta in Urine of Nonocupationally Exposed Populations
Number of
People
417(359)a
6b
117C
173C
60d
20e
Number of
Analyses
24
267
173
20
Penta Concentration in Urine (ppm)
Min. Max. Mean
0.002
0.003
0.009
0.010
0.193
0.011
1.84
0.57
0.080
0.050
0.006
0.040
0.044
0.020
a. From Kutz et al. (1978); location = continental U.S. Note
only 359 people had measureable amounts of penta in their
urine.
b. From Cranmer and Freal (1970); location = Great Britain.
c. From Bevenue et al. (1967); Location = Hawaii.
d. From Dougherty (1978); location = Florida.
e. From Akisada (1965); location = Japan.
311
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TABLE II.D-10
a
Penta Residues in Residents of a Log Home
Age
2
4
9
29
34
Sex
Female
Female
Male
Female
Male
Levels (ppb)
1,750
1,680
910
580
710
Levels (ppb)
216
51.2
54.7
50.8
46.8
a. From Lakings £t al. (1980).
b. Value represents unconjugated penta
-------
d. Revised Human Exposure Analysis for Specific Exposure
Situations
In this section, realistic worst-case estimates of human exposure
to penta are developed. For situations where actual measurements
of penta are available, the highest experimental value observed
was used in the exposure calulations when the totality of
information on these situations indicates that this high figure
was not an aberrant value.
i. Pressure Treatment: Usual Exposure
With the exception of two operations in a typical pressure
treatment plant (i.e., opening of the pressure cylinder door and
manually emptying penta bags), the maximum penta air levels re-
ported by various investigators are consistent: 28 ug/m
(Arsenault, 1976), 20 ug/m3 (Rapp, 1978), 15 ug/m3 (Wyllie
et al. 1975), and 8 ug/m (NIOSH, 1977). The maximum penta
air level reported by Arsenault (1976) of 28 ug/m will be
used to estimate the maximum inhalation exposure for a pressure-
treatment worker (excluding those workers engaged in the two
high exposure operations). Assuming 6 hours of light exercise
and 2 hours of heavy exercise, this estimate is obtained:
313
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(28 ug/m3) x (0.98 m3/hr) x (6 hr)
60 kg
(28 ug/m3) x (1.47 m3/hr) x (2 hr)
60 kg
= 4.1 ug/kg/day
During normal operations in a commercial pressure-treatment
facility, there are few opportunities for employee dermal
exposure to penta. Penta treatment formulations are generally
mixed and applied in a closed system. An exception is the
operation which formulates solutions from the bagged form^ of
small penta pellets (also known as "prilled" penta). This
particular exposure setting is dealt with in a subsequent
section.
Most pressure treatment operations are highly mechanized and
automated, and there is only rare, if any, manual handling of
penta or the treated wood. Consequently, in view of the lack of
data to the contrary, the Agency believes that the potential for
dermal exposure in such facilities is considerably smaller than
the potential for inhalation exposure. Hence a dermal exposure
estimate for these workers will not be developed.
ii. Pressure Treatment: High Exposure
The air level data for penta in pressure-treatment plants
indicate that opening of the pressure cylinder door and manually
emptying bags of penta pose an unusually high risk of inhalation
314
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exposure. Although it is recognized that workers involved in
such operations frequently wear respirators, this is not always
the case. Thus, the exposure analysis for a worst-case
situation assumes that a respirator is not worn. Also, Rapp
(1978) noted that "respirators were usually not worn" during bag
emptying operations in 28 wood treatment plants using penta.
The maximum penta air level reported by Arsenault (1976) when
the cylinder door was opened was 1.0 mg/m . Rapp (1978)
reported that airborne penta during opening of cylinders ranged
from essentially 0 to as high as 150 mg/m . Of the 27
samples, 9 exceeded 1.5 mg/m , the OSHA TLV for short-term
excursions of 15 minutes or less. It is recognized that
exposure durations are likely to be short (less than 20 minutes)
and that a single cylinder door would be opened, at most, twice
during an 8-hour shift. Assuming that a female worker were
exposed to penta at the maximum level reported by Rapp (1978) of
150 mg/m for 1 hour at a light exercise level, the resulting
exposure would be:
(150 mg/m3) x (0.98 m3/hr) x (1 hr)
60 kg
= 2.5 mg/kg/hr
The above calculation is primarly illustrative, since the
irritant properties of penta vapor would make unprotected
exposure for long at such high levels unlikely. In the event
that a respirator is not used, however, exposure of 2.5 mg/kg
during that hour is a possibility.
315
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A similar calculation using the maximum penta air level reported
by Arsenault (1976) of 1.0 mg/m yields this maximum predicted
exposure:
(1.0 mg/m3) x (0.98 m3/hr) x (1 hr)
60 kg
16 ug/kg/hr
This theoretical value seems a more likely possibility. Worker
exposure for the remaining 7 hours of the work shift would
probably not exceed the maximum level estimated previously for
pressure-treatment workers in usual exposure situations (i.e.,
4.1 ug/kg/8-hr day or 3.6 ug/kg/7-hr period). Thus a total
daily exposure may be calculated as:
16 ug/kg + 3.6 ug/kg = 19.6 ug/kg/day
Quantitative data on the potential dermal exposure of a worker
engaged in the opening of a pressure cylinder door is not
available. This deficiency, along with the lack of applicable
data for similar situations with other pesticides which might be
extrapolated to penta use situations, precludes the development
of a dermal exposure estimate at the present time.
Manual emptying of penta bags also results in high penta air
levels. The maximum penta air concentration level reported by
NIOSH (1975) during this operation was 3.8 mg/m . Rapp (1978)
reported that "...the airborne pentachlorophenol levels while
316
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dumping bags exceeded the established OSHA guidelines for short-
term exposure (i.e., 1.5 mg/m for 15 minutes) in 14 of the 49
samples. Two unusually high levels of 54 and 65 mg/m were
recorded. Respirators were usually not worn."
Many major wood treating plants, it is recognized, use 1) closed
systems for the delivery of the prilled (granular) form of penta
to mixing tanks, or 2) penta cast in block form. However, many
other operations, especially ones in smaller firms, must empty
the bags of prilled penta manually. The Agency estimates that
workers may reasonably be expected to engage in bag emptying
operations -for a 4-hour period during an 8-hour work shift on a
daily basis (Nicholas, 1980). As airborne penta can cause
general upper respiratory distress, including painful nasal
irritation and violent coughing and sneezing, individuals are
not expected to inhale extremely high concentrations of vapor
dust. Although concentrations greater than 1 mg/m may cause
this distress in unacclimated persons, concentrations as high as
2.4 mg/m can be tolerated by those conditioned to exposure
(American Industrial Hygiene Association, 1970). Since Rapp
(1978) also indicates that respirators may not be worn, despite
the presence of penta air levels exceeding OSHA guidelines, an
estimate has been developed for the maximum predicted inhalation
exposure for the workers. The estimate assumes 2 hours of light
exercise in the mixing area, 2 hours of heavy exercise during
the bag emptying operation, and 4 hours of light exercise in the
plant's general grounds area:
317
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(2.4 mg/m3) x (0.98 m3/hr) x (2 hr)
60 kg
(2.4 mg/m3) x (1.47 m3/hr) x (2 hr)
60 kg
(0.028 mg/m3) x (0.98 m3/hr) x (4 hr)
60 kg
= 0.20 mg/kg/day
The emptying of bagged penta by hand clearly has the potential
for high dermal exposure. The Agency is not aware of any actual
measurements of human dermal exposure during this operation.
However, search of the technical literature revealed several
exposure studies in which dermal exposure was measured during
formulating and bagging operations with pesticide powders and
dusts (Table II.D-11).
In the absence of more immediately relevent data on dermal
exposure during emptying of bagged penta, the Agency believes
that the data in Table II.D-11 can be used to make a rough
estimate of potential dermal exposure. Since the penta
formulation in question is pelleted and thus predominantly
coarse in texture (although some fine material is present), the
lower exposures calculated from the data in Table II.D-11 are
probably more representative of the dermal exposure during this
activity. As the workers involved in this operation are exposed
to the dry, prilled form of penta, the Agency does not expect
dermal absorption to exceed 1%. Thus, the Agency estimates a
318
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TABLE II.D-11
Dermal Exposure During Pesticide Formulating*
Dermal Exposure (mg/hr)
Estimate,
Mean
Range
Formulating disulfoton
as 0. 5% dry mix
fertilizer
2.0
0.1-10.5
for Penta
Mixing and bagging of
4-5% carbaryl dust :
Formulating 25% Guthion
wettable powder :
73.9
10.1
0.8-1209
4.9-20.9
1478
40
400
a. Assumes workers were wearing short-sleeved shirts, no gloves
or hats, and that covered areas of the body were protected
from exposure.
b. Assumes worker is handling bags of pure penta
c. From Comer e_t _al. (1975).
d. From Jegier (1964).
e. From Wolfe et al. (1978).
319
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dermal exposure of 40 to 400 mg/hr x 1% absorption, or 0.4 to 4
mg/hr of emptying activity. Actual exposure could be either
higher or lower, depending on the care taken during the
operation.
As a worker may reasonably be expected to engage in bag emptying
activites for a 4-hour period during an 8-hour work shift, the
daily exposure is calculated as follows:
0.4 to 4 mg/hr x 4 hr
= 0.027 to 0.27 mg/kg/day
60 kg
iii. Dip/Flow Coating Treatment
Based on the penta air levels reported by the Environmental
Health Sciences Center of Oregon State University for dip
treatment operations (Morton and Freed, 1973), the maximum
predicted inhalation exposure for dip treatment workers can be
calculated.
The maximum penta air concentration found "in the area where a
worker spends the majority of his time" was the same as that in
the immediate area of the penta source (i.e., 63 ug/m ). The
resulting maximum inhalation exposure estimated for 6 hours at
light exercise and 2 hours at heavy exercise is:
320
-------
(63 ug/m3) x (0.98 m3/hr) x (6 hr)
,
60 kg
(63 ug/m3) x (1.47 m3/hr) x (2 hr)
60 kg
= 9.3 ug/kg/day
There may be dermal exposure during dip or flow coat treatment,
when the treatment process is not automated. No information is
available on actual dermal contact in such operations, but it is
reasonable to assume that workers' hands are likely to come in
contact with the penta solution during manual operations. If
gloves are not worn by the workers and enough of the 5%
formulation to cover the surface area of both hands (i.e., 6 ml;
see comment 8, Section II.D.2.b) reaches the skin of the worker,
the estimated exposure is:
6 g [6 ml solution] x 0.05 [5% concentration] x 0.1 [10% absorption]
60 kg
= 0.5 mg/kg/day
iv. Sapstain Control Treatment
Sodium penta is commonly used as a commercial sapstain control
agent on freshly sawn lumber. Despite the low vapor pressure of
sodium penta, some mist or vapor is generated during spray
operations. In the worker exposure study conducted by the
Oregon State University (Morton and Freed, 1973), air samples
321
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were taken at eleven companies which used sodium penta as a
spray treatment for sapstain control. The maximum penta air
concentration found in the area where a worker spends the
majority of this time was 12 ug/m . The penta maximum air
level found near the spray booth was reported as 69 ug/m .
Although routine operations would not be expected to require all
workers to spend a full 8-hour work shift in proximity of the
spray operation, it is reasonable to assume that 8-hour
exposures could occasionally occur for some workers. Hence, the
69 ug/m air level will be used to derive an estimate of the
maximum daily inhalation exposure for the sapstain worker.
Assuming a female worker weighs 60 kg, 6 hours of light
exercise, and 2 hours at heavy exercise, the resulting exposure
is:
(69 ug/m3} x (0.98 m3/hr) x (6 hr)
60 kg
(69 ug/m3) x (1.47 m3/hr) x (2 hr)
60 kg
= 10.1 ug/kg/day
Freshly sawn lumber is frequently treated with an aqueous
solution (0.3% to 0.9%) of sodium penta to prevent the
discoloration of the wood by molds, fungi, and bacteria.
Following treatment (usually an automated process), lumber may
be stacked or handled
manually. Assuming workers do not wear gloves, exposure patterns
will likely resemble those of the dip/flow worker. Since a
322
-------
dilute solution is used, the exposure estimate for dip treaters
must be corrected to reflect a reduction in predicted exposure.
As sodium penta concentrations in sapstain solutions average 0.5%
as compared with 5% for dip/flow solutions, the predicted dermal
exposure is:
500 ug/kg/day x 0.1 (correction factor) = 50 ug/kg/day
v. Surface Spray Treatment
Plywood may be dipped or sprayed with a 2.5% solution of penta
in an organic solvent. Since penta has a higher vapor pressure
than its sodium salt, it may be predicted that ambient air
levels during penta spraying would exceed the levels reported
for sapstain operations. However, because there is little
quantitative air level data for these operations, the exposure
estimate will be developed by correcting the air levels recorded
during spray sapstain operations to reflect the difference (2.5%
vs. 0.5% penta concentration:
10 ug/kg/day x 5 (correction factor) = 50 ug/kg/day
Plywood may be either dipped or sprayed with a 2.5% solution of
penta dissolved in an organic solvent. Although the actual
spray operations involve automated processes, the Agency
believes that some manual handling of the treated lumber is
323
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likely to occur after treatment. The resulting exposure is-
expected to resemble that incurred by the dip/flow worker.
Since the penta solutions used for plywood spray operations is
more dilute (2.5% vs 5.0%), the exposure estimates for dip/flow
workers should be reduced by a factor of 2. Assuming that
gloves are not worn by the workers, the predicted exposure is:
500 ug/kg/day
= 250 ug/kg/day
2 [correction factor]
Assuming that gloves are worn, a similar extrapolation from the
data for dip treatment workers yields:
1.1 ug/kg/day
= 0.55 ug/kg/day
vi. Occupational End-Use Activities
Carpenters, construction workers, lumber yard employees, and
others may incur inhalation exposure to penta if they work with
a significant amount of treated wood. This exposure will
usually occur in outside or in well-ventilated indoor areas and,
hence, the available penta air data derived from such settings
will be used in the analysis. Wyllie et al. (1975) measured the
penta air levels in the outside wood storage area of a small
wood treatment plant in Idaho. The maximum penta air
concentration reported by these investigators was 2.6 ug/m .
If a 60-kg female employee were exposed to this air level at a
324
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light exercise level for 6 hours and a heavy exercise level for
2 hours, the resulting estimated exposure would be:
(2.6 ug/m3) x (0.98 m3/hr) x (6 hr)
60 kg
(2.6 ug/m3) x (1.47 m3/hr) x (2 hr)
60 kg
0.38 ug/kg/day
It is probable that occupational exposure to treated wood may
occasionally occur in poorly ventilated settings, such as
storage sheds, railroad cars, warehouses. In such settings
penta air concentrations are expected to be higher than the
value cited above. The laboratory results of Thomspon jejt al.
(1979), indicate that penta air levels as high as 40 ug/m may
occur when freshly treated wood is placed in a test cylinder at
25 C with a 2% air exchange rate per minute (see Table II. D-
12). Using this penta air level to estimate a maximum predicted
inhalation exposure estimate for workers occupationally exposed
to treated wood in a poorly ventilated area gives:
(40 ug/m3) x (0.98 m3/hr) x (6 hr)
60 kg
(40 mg/m3) x (1.47 m3/hr) x (2 hr)
60 kg
= 5.9 ug/kg/day
325
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TABLE II.D-12
Vaporization of Penta from Pressure-Treated Wood
Penta Air Concentration (mg/m )
at:
Treating Solution 25°C 30°C
Cellon® 0.028 0.053
MC 0.040 0.076
Oil 0.025 0.042
a. From Thompson et al. (1979).
326
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It is likely that carpenters, construction workers, and others
who handle penta-treated lumber will incur some dermal exposure,
primarily through their hands if gloves are not worn. There are
very limited data available on penta residues on treated wood
surfaces (e.g., according to Koppers, utility poles have average
2
penta surface residues of 3.9 ug/cm 7 weeks after
treatment). This information, however, is not judged to be
adequate to perform an assessment of human exposure from
occupational contact with treated items. In addition, there is
no information on the quantity of penta which may be transferred
to human skin. Even so, it is reasonable to assume that if
workers who handle penta-treated
lumber wear gloves, their dermal exposure will be extremely low.
Although a quantitative estimate is not possible, the exposure is
expected to be considerably smaller than that predicted for
workers handling the concentrated penta solutions (i.e., 1.1
ug/kg/day) .
vii. Home and Farm Use
Human inhalation exposure resulting from the application of over-
the-counter penta formulations may take two forms: inhalation
during the application phase, and inhalation of vapors or
particulates from the surface of the treated wood following
application.
Most applications of these formulations by homeowners and
farmers will take place outdoors during treatment of decks,
327
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fenceposts, wood siding and other exterior wood structures.
These treatment operations are likely to be in well-ventilated
areas .
If the formulations are applied by dip or brush application,
penta air levels (during the application phase) would probably
not exceed residue levels reported for the general (exterior)
grounds of commercial wood treatment facilities. Wyllie et al.
(1975) measured the penta air levels in the outside wood storage
area of a small wood treatment plant in Idaho. The maximum
penta air concentration reported by these investigators was 2.6
ug/m . If a 60-kg female were exposed to this air level for 6
hours of light exercise and 2 hours of heavy exercise, the
estimated exposure is:
(2.6 ug/m3) x (0.98 m3/hr) x (6 hr)
60 kg
(2.6 ug/m3) x (1.47 m3/hr) x (2 hr)
60 kg
= 0.38 ug/kg/day
The possibility that formulations containing penta may be
sprayed by the user cannot be ignored, since the Pesticide
Incidient Monitoring System (PIMS, 1978) has reports of human
illness resulting from such spraying; in addition, not all
labels caution against this application method. Available penta
air measurement data are all derived from industrial settings
328
-------
where penta is applied in fixed-nozzle spray-booths. The Agency
does not believe that a quantitative estimate of exposure for
the home applicator can be derived from this information. The
Agency does believe, however, that the potential human exposure
arising from the spraying operation is likely to be much higher
than the exposure arising from either the dipping or brushing
operations. This is because typical spray operations with
dilute penta wood preservative formulations involve spraying the
sides of buildings using pesticide or paint sprayers. These
operations can lead to considerable exposure from inhalation of
suspended spray droplets or from spray deposition and splashing
on the skin. Although no actual human exposure data for these
operations are available, inhalation and dermal exposure has
been measured during the use of hand-held pesticide sprayers in
agricultural situations; extensive exposure, chiefly by the
dermal route, was observed (Wolfe ^t al., 1967).
When penta is applied to wood in a well-ventilated area, and the
resulting treated structure remains outdoors, the human
inhalation exposure will be "intermittent" (see comment 16,
Section II.D.2.b). This is because homeowners or farmers would
be expected to apply penta formulations to new or existing wood
only for a short time once every few years. An exception might
be the case of a farmer who applies penta over a single extended
period every few years or who dips fenceposts intensively when
replacing or installing a fence. In addition, treatment of the
exterior siding of a residence is an operation that may
329
-------
reasonably take as long as a week to accomplish, assuming a
homeowner does it several hours per day.
If a homeowner or farmer applies penta formulations to indoor
wood (in barns, storage sheds, or residences) the inhalation
exposure during application will also be intermittent. In such
settings, penta air concentrations are expected to be higher
than the values calculated tor outdoor application. Thompson et
al. (1979) measured penta air levels in a test chamber
containing wood treated with penta in three different carriers:
liquified petroleum gas (Cellon©), methylene chloride (MC), and
oil. Their results (Table II.D-12) indicate that there may be
penta air levels as high as 40 ug/m when freshly treated wood
is placed in a test cylinder at 25 C with a 2% air exchange
rate per minute. This penta air level will be used to estimate
the maximum predicted inhalation exposure for a homeowner or
farmer applying penta indoors.
This value, derived from laboratory experiments, will be used
rather than the maximum reported air level in pressure treatment
plants. The value is more probable because ventilation in
private structures is highly variable and depends on the nature
of the structure (e.g., a barn of loose construction vs. a
nome). Recognizing that such applications may take as much as 4
hours, this following inhalation exposure estimate results:
330
-------
(40 ug/m3) x (0.98 m3/hr) x (2 hr)
60 kg
(40 ug/m3) x (1.47 m3/hr) x (2 hr)
60 kg
= 3.3 ug/kg/aay
No information is available on actual dermal contact during the
application of these products by the general public. The degree
of this contact will be wholly dependent on the care with which
such products are handled by the individual appplicator. The
Agency is not able to estimate precisely the frequency or the
carelessness and misuse ol: these products. The scenarios which
follow illustrate the degree of dermal exposure incurred by an
individual who contacts various volumes of formulations:
a) 1 drop:
0.05 g [0.05 ml solution] x 0.05 [5% cone.] x 0.1 [dermal absorption]
60 kg
= 4.2 ug/kg/day
b) 3 ml (a quantity sufficient to cover surface of one hand):
(3 g) x (0.05) x (0.1)
= 250 ug/kg/day
60 Kg
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c) 6 ml (a quantity sufficient to cover surface of both hands)
(6 g) x (0.05) x (O.I)
= 500 ug/kg/day
60 kg
Inhalation exposure to penta vapors or particulates irom the
surface of the treated wood following application to exterior
structures is expected to be extremely low.
If penta formulations are applied inside wooden structures
(barns, storage sheds, homes, etc.) there will be exposure to
vapor or particulates during application; exposure may be a
significant ongoing process following the application phase as
well.
Ihe extent of human exposure resulting from such use depends on
the type of structure (e.g., home vs. barn), the degree of venti-
lation, temperature, the length of time spent in the structure,
and other variables. Since many labels for over-the-counter
penta formulations do not warn against use in enclosed
structures, including homes, use of such products in accordance
with label instructions may result in the development of
significant penta air levels with subsequent human inhalation
exposure. Exposure times as high as 24 hours are reasonable tor
a maximum predicted exposure in such a situation.
332
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Because recent trends in energy conservation have led to
increasingly "airtight" homes, the likelihood ot high penta air
levels in homes where the chemical has been used is a
significant concern. The Pesticide Incident Monitoring System
(PIMS, 1978) has received numerous reports of human health
effects following the application of penta inside homes. In
several cases the description of the treated wood indicates that
significant blooming of penta had occurred. Also, Thompson ejt
al. (1979) observed blooming of penta in their experiments with
Ceilon®- and MC-treated wood, but not with oil-treated wood. In
the event that blooming does occur, two factors are important.
First, air currents from housecleaning activities such as
dusting, could cause the small crystals to become airborne, thus
generating a dust for respiratory exposure. It has not been
possible to estimate the air penta concentration resulting from
this process although there is a potential for high inhalation
exposure. Second, as a result ot blooming, crystalline penta is
available for vaporization. Under these conditions, it is more
likely that air penta levels in a closea system with a low air
exchange will approach the theoretical vapor density equilibrium
value of 2.2 mg/m . Even without blooming, however,
significant penta air levels are expected.
Although the results of Thompson et al. (1979) cannot be
directly extrapolated to situations in human structures because
of tne number ot potentially contounding variables, they compare
favorably with the results of Gebefugl e_t £.1. (197fa) \.here
concentrations as high as O.ib mg/m were detected in the air
ot a laboratory test area treated with painc containing penta.
333
-------
In addition, the values reported by Thompson et al. fall within
the range of air concentrations reported in commercial wood-
treatment plants (Table II.D-6). In other words, the observed
penta air levels in wood-treatment plants are very similar to
the levels resulting from vaporization from treated wood.
It is interesting to note that eight months of weathering on an
outside test fence reduced the air concentrations of penta
(measured in the laboratory system) from Cellon®- and MC-treated
samples to about 45 to 70%, respectively, of the original
concentrations (Thompson e_t al., 1979). (The concentration of
penta from the oil-treated wood was unaffected by weathering.)
The results of these preliminary experiments are significant,
since they suggset that penta-treated wood may serve as a source
of airborne penta for an extended period of time. The recent
report by Whitney and Gearhart (1979) lends further credence to
this hypothesis and suggests that penta-treated wood may serve
as a source of airborne penta for longer than 7 years.
The Agency believes that the application of penta formulations
or use of penta-treated wood in homes may result in penta air
levels which exceed levels detected in many commercial settings.
Although human inhalation exposure during indoor application of
penta formulations may be intermittent, exposure following
application in enclosed spaces may occur for an indeterminate
period of time. Hence, a worst-case approach would justifiably
assume a continuous (24-hour), rather than an intermittent
exposure. Using the maximum air concentration reported by the
334
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Pesticide Incident Monitoring System (PIMS, 1978; see Section-
Il.D.3.b.ii) and assuming 12 hours at rest, 10 hours of light
exercise, and 2 hours of heavy exercise, a 60-kg woman might
incur the following inhalation exposure:
(30 ug/m3) x (0.27 m3/hr) x (12 hr)
60 kg
(30 ug/m3) x (0.98 m3/hr) x (10 hr)
60 kg
(30 ug/m3) x (1.47 m3/hr) x (2 hr)
60 kg
= 8 ug/kg/day
Since the available data do not suggest a significant difference
between air levels from pressure-treated lumber and those
achieved from brush application of over-the-counter
tormuiations, the estimate also applies to potential exposure
resulting from the use of pressure-treated lumber indoors.
The potential use of paints or sealants to eliminate penta
volatilization from treated wood has not been adequately
addressed in the literature. A preliminary experiment reported
by Thompson ert al. (1979) indicates that paint may reduce, but
not eliminate, penta volatilization from treated wood. Partial
results from this experiment indicated that oil-base paint
reduces penta vaporization to about 16% of uncoated sample
335
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values for Cellon®-treated boards and to 44% for oil-treated
boards. Waterbase paints were less efficient in reducing
vaporization. For MC-treated wood, for example, the values
obtained for water-base paint were 59% of those for uncoated
boards. These highly preliminary results suggest that paint may
reduce penta vaporization rates from treated wood.
e. Summary of Revised Human Non-dietary Exposure Analysis
Table II.D-13 summarizes the revised exposure figures developed
for penta in this Exposure Analysis.
Information available to the Agency indicates that commercial
penta generally contains 15 and 100 ppm of HxCDD and HCB,
respectively. In the absence of specific monitoring data for
these two components of commercial penta, the Agency has
adjusted the appropriate figures in Table II.D-13 in order to
estimate human exposure to HxCDD and HCB. Tables II.D-14 and
II.D-15 present these estimates.
f. Dietary Exposure
Residues of penta have been detected in several types of
foodstuffs. The source of these residues is not clear.
However, the current use of penta is about 50 million pounds per
year, of which about 40 million pounds is used for wood
preservation. As noted previously in this Exposure Analysis,
the total amount of penta present in the environment in treated
wood far exceeds this amount. Therefore, the use of penta as a
336
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TABLE II.D-13
Summary of Estimated Human Exposure to Pentac
Penta Exposure
(ug/kg/day)
Site
Dermal
Inhalation
Pressure Treatment
Manual emptying of penta bags
Opening cylinder door
General operations
Dip/Flow Treatment
Surface Spray Treatment
Sapstain Treatment (Dip)
Sapstain Treatment (Spray)
Occupational End Use
Poorly-ventilated area
Well-ventilated area
Home and Farm Use
During application: indoors
outdoors
After application: indoors
outdoors
27 to 270C
d
e
500
250
50
50
d
d
4.2 to 500
4.2 to 500
d
d
200
20
4.1
9.3
50
f
10
5.9
0.38
3.3
0.38
8.0
g
a. Assumptions: 60-kg individual, 100% respiratory absorption
and 10% dermal absorption.
b. Assumption: respirators are not worn.
c. Assumptions: workers are wearing short-sleeved shirts, they
are not wearing hats or gloves, and covered areas of the
body are protected from exposure.
d. No quantitative estimate is possible based on available data.
e. Exposure is considered negligible due to automated procedures
and/or lack of significant residues.
f. Exposure is considered negligible due to low vapor pressure
of sodium penta.
g- Rxposure is considered negligible due to good ventilation.
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TABLE II.D-14
Summary of Estimated Human Exposure to HxCDDe
HxCDD Exposure
(ug/kg/day)
Site
Dermal
Inhalation
Pressure Treatment
Manual emptying of penta bags
Opening cylinder door
General operations
Dip/ Flow Treatment
Surface Spray Treatment
Sapstain Treatment (Dip)
Sapstain Treatment (Spray)
0.00041 to 0.0041d
e
f
0.0033
0.0038
0.00033
0.00075
0.003
0.0003
g
g
0.00075
g
0.00015
Occupational End Use
Poorly-ventilated area
Well-ventilated area
Home and Farm Use
During application: indoors
outdoors
After application: indoors
outdoors
e
e
0.000063 to 0.0076
0.000063 to 0.0076
e
e
g
g
g
g
g
g
a. Assumptions: 60-kg individual, 100% respiratory absorption
and 10% dermal absorption.
b. Assumption: commercial penta and sodium penta contain
15 ppm HxCDD.
c. Assumption: respirators are not worn.
d. Assumptions: workers are wearing short-sleeved shirts, they
are not wearing hats or gloves, and covered areas of the
body are protected from exposure.
e. No quantitative estimate is possible based on available data.
f. Exposure is considered negligible due to automated procedures
and/or lack of significant residues.
g. Exposure is considered negligible due to low vapor pressure
of HxCDD relative to that of penta.
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TABLE II.D-15
Summary of Estimated Human Exposure to HCBC
HCB Exposure
( ug/kg/day)
Site
Dermal
Inhalation
Pressure Treatment ,
Manual emptying of penta bags 0.0027 to 0.027
Opening cylinder door e
General operations f
Dip/Flow Treatment 0.05
Surface Spray Treatment 0.025
Sapstain Treatment (Dip) 0.005
Sapstain Treatment (Spray) 0.005
Occupational End Use
Poorly-ventilated area e
Well-ventilated area e
Home and Farm Use
During application: indoors 0.00042 to 0.05
outdoors 0.00042 to 0.05
After application: indoors e
outdoors e
0.02
0.002
0.00041
0.00093
0.005
0.000093
0.001
0.00059
0.000038
0.00033
0.000038
0.0008
g
a. Assumptions: 60-kg individual, 100% respiratory absorption
and 10% dermal absorption.
b. Assumption: commercial penta and sodium penta contain 100
ppm HCB.c. Assumption: respirators are not worn.
d. Assumptions: workers are wearing short-sleeved shirts, they
are not wearing hats or gloves, and covered areas of the
body are protected from exposure.
e. No quantitative estimate is possible based on available data.
f. Exposure is considered negligible due to automated procedures
and/or lack of significant residues.
g. Exposure is considered negligible due to good ventilation.
339
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wood preservative
on barns, poultry houses, feed lot bins, food storage bins, etc.,
could lead to residues in food.
In a spot survey of selected food items, Dougherty and
Piotrowska (1976) found penta residues in powdered milk, bread,
soft drinks, candy bars, cereal, noodles, rice, sugar and
wheat. As shown in Table II.D-16, the penta concentrations
ranged from 1 ppb to 1 ppm. The presence of penta residues in
all the grain and sugar products was attributed to the storage
of these products in penta-treated wooden storage containers.
Penta residues in food have been found during total diet studies
by the FDA (1979). In FY 1973, the number of composite samples
that contained penta was 2 out of a total of 360 composite
samples. In Fiscal Year (FY) 1975, the number of composite
samples that contained penta increased to 13 out of a total of
240 composite samples. Penta residues were found in dairy
products, grains and cereals, leafy vegetables, root
vegetables, fruits, and sugar and its adjuncts. Reports of
penta in dairy cattle in Michigan added to the concern about
possible penta residues in the diet.
As part of its compliance Program, FDA (Martin 1979) has
collected 198 of the projected 280 milk samples for FY 1979. Of
the 198 samples analyzed (about 20%), 39 contained penta at or
above Q.005 ppm. The highest value of penta reported, 0.231
ppm, was found in milk from New York State.
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TABLE II.D-16
Spot Survey of Environmental Substrates for Penta
Concentration of
Substrate ' Penta (ppm)
Bond Paper 10.0
Textbook Paper 10.0
Powdered Milk 0.1
Soft Drink (Diet) 0.001
Soft Drink 0.001
City Water 0.0001
Bread 1.0
Candy Bar (2 brands) 0.1
Cereal 0.1
Noodles 0.1
Rice 0.01
Sugar 0.1
Wheat 0.1
a. Derived from Dougherty and Piotrowska, 1976.
341
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From January through September, 1978, the U.S. Department of
Agriculture collected liver samples from beef, swine, and
poultry throughout the United States. Table ll.D-17 summarizes
the percentages of positive findings and concentration ranges
within each species. This survey, although preliminary, showed
that in all instances the percentage of positive findings was
higher than 86%.
The Agency's National Surface Water Monitoring Program for FY
1978 analyzed a total of 600 water samples taken from 153
sampling locations in 43 states. About 5% of all the water
samples were positive for penta. The overall average was about
0.13 ppb. Furthermore, Zitko e_t _al. (1974) surveyed the penta
levels in the aquatic fauna of New Brunswick, Canada. Values in
fish ranged from 0.082 ug/kg in codfish to 3.99 ug/kg in white
flounder.
Although some of the studies reviewed in the preceding pages
were preliminary in nature and sometimes inconclusive, they
suggest that penta is a ubiquitous environmental contaminant.
The contribution of specific uses of penta to the overall
environmental burden is not known.
342
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TABLE II.D-17
Penta Residues in Liver Samples3
Number of Number of Percent Positive
Species Samples States Findings Range (ppm)
Cow
Heifers
Market
Hogs
Sows
Young
Chicken
Mature
Turkeys
Breeder
Turkeys
108
60
102
45
95
83
26
32
18
24
12
20
15
11
86
92
99
100
98
94
92
0.001-0.70
0.001-0.50
0.001-2.00
0.001-1.50
0.001-0.15
0.001-0.70
0.001-0.04
a. From USDA (1978; unpublished).
343
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4. Pentachlorophenol1s Potential Oncogenicity
a. Introduction
The Agency reviewed, in PD-1, three studies concerning penta1s
possible oncogenicity. Innes e_t al. (1969) administered (by
gavage) 46.4 mg/kg penta to mice on days 7 through 28 of age,
followed by 130 ppm (17 mg/kg/day) in the diet for 17 months.
They reported that this regimen caused no significant increase
in tumor incidence in the test animals when compared with
controls .
In 1976, Schwetz e_t al. reported that 1, 3, 10, and 30 mg/kg/day
of purified penta in the diet for 2 years did not increase tumor
incidence over control animals.
Boutwell and Bosch (1959) applied 0.3% dimethylbenzanthracene in
benzene as an initiator to the shaved backs of mice. As a
promoter, a solution of 20% penta in benzene was applied
similarly twice weekly for 15 weeks. The average number of
papillomas per survivor was 0.04 in the test group, slightly
less than the 0.07 observed in the controls. The number of
survivors with papillomas was 4% in the test group and 7 % in the
control group.
These papers were reviewed by the Agency's Carcinogen Assessment
Group and were found to be negative with respect to oncogenic
effects of penta. Since publication of PD-1, however, several
344
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other studies pertinent to the oncogenic potential of commercial
penta and its contaminants have been brought to the Agency's
attention. These are discussed below.
b. Hexachlorodibenzo-p-dioxin
In March 1980, the Agency received from the National Cancer
Institute the final draft reports of two bioassay studies
dealing with the possible carcinogencity of two isomers of
HxCDD. The results of one study, on the dermal application of
HxCDD to mice, were negative. The second study involved oral
administration of HxCDD to both rats and mice. The doses ranged
from 1.25 mg/kg/week to 10 mg/kg/week. Under the conditions of
this study, HxCDD increased the incidence of benign and
neoplastic liver tumors in mice of both sexes and in female
rats. (See Section II.D.S.b for quantitative risk assessment.)
c. Hexachlorobenzene
Testimony before the Environmental Health Advisory Committee of
the Agency's Science Advisory Board (SAB) revealed that HCB was
present in commercial preparations of penta. A subsequent search
of the scientific literature found two studies (Cabral e_t al.,
1977; 1979) demonstrating that HCB is oncogenic.
In the 1977 study, six-week-old Syrian golden hamsters were fed
a diet containing 50, 100 or 200 ppm HCB (99.5% pure) ad libitum
for life. Although no hepatomas were observed in the control
345
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group, the incidence of hepatomas in the treated hamsters
increased from 47% in the 50 ppm female group to 85% in the 200
ppm female group. Similar results were found in the male
hamsters.
Cabral e_t al. (1979) studied the effects of the same dietary
levels in Swiss mice. Again, the treated groups (both male and
female) had significantly greater incidences of hepatomas when
compared to the controls. (See Section II.D.S.b for the
quantitative risk assessment.)
346
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5. Quantitative and Qualitative Risk Assessments
a. Fetotoxic, Teratogenic, and Reproductive Effects
i. Introduction
Since the publication of PD-1, new information has been found
on the fetotoxic and reproductive effects of penta and its
contaminants. These new data are described below in Section
II.D.S.a.ii. Then, in Section II.D.5.a.iii, these new data will
be combined with the toxicological data discussed earlier and
m
with other data on penta exposure to assess quantitatively the
fetotoxic reproductive risk of penta and its contaminants to
humans.
ii. Additional Data Reviews
One-Generation Rat Reproduction Study of Penta
Schwetz e_t al. (1978), in a dietary study, randomly separated 7-
week old Sprague-Dawley (Spartan substrain) SPF-derived rats
into test groups and allowed them to acclimatize for 1 week.
There were 10 male and 20 female rats in each treatment group
and in the control group. The investigators mixed penta
(dissolved in anisole) with Purina Lab Chow to make a 1% premix,
from which test diets were prepared weekly and fed to the
treatment groups. (Table II.0-18 shows the composition of the
penta used in this study.) When adjusted weekly for changing
347
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TABLE II.D-18
Composition of Dowicide® EC-7a
Component Amount
Phenols Percent
Trichlorophenol <0.1
Tetrachlorophenol 10.4 +0.2
Pentachlorophenol 90.4 +1.0
Dibenzo-p-dioxins ppm
2,3,7,8-Tetrachloro- <0.05
Hexachloro- 1.0 +_ 0.1
Heptachloro- 6.5 + 1.0
Octachloro- 15.0 + 3.0
Dibenzofurans
Hexachloro- 3.4 + 0.4
Heptachloro- 1.8 + 0.3
Octachloro- <1
a. From Schwetz et al. (1978).
348
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food consumption and body weights, this diet resulted in doses
of 3 and 30 mg kg/day penta. All rats were observed daily.
Body weights were recorded on days 0, 29, and 62 of the study,
as well as 21 days after parturition. After 62 days on the
test diet, each male was placed with two females from the same
treatment regimen for 15 days, which is three estrus cycles in
normal female rats. After the 15-day period, the males were
returned to individual cages and given the appropriate dose-
level diet. Females were maintained in individual cages with
ground corn-cob litter for nesting. Treatment diets for females
continued throughout parturition and for 21 days following
parturition. After 21 days of lactation, the females and their
young were killed and necropsies were performed. One male and
one female of each litter were prepared for skeletal
examination. The adult male rats were sacrificed and examined
at the end of the study.
Indices of reproduction were evaluated by the Fisher exact
probability test, and body weights were analyzed by Dunnett's
test. The level of significance in all cases was P<0.05.
Statistically significant depression of parental body-weight
gain was reported at the 30 mg/kg/day dose for males at all
measurement periods, and for females at the last (62nd day)
period. At the 3 mg/kg/day dose, there was an apparent trend
toward decreased weights in both sexes at all periods reported.
This trend exists in the absence of significant depression at
any specific period.
349
-------
At the 30 mg/kg/day dose, the neonatal weights of both sexes
compared to controls were significantly lower at all four
periods reported. The data for the 3 mg/kg/day dosage shows a
trend toward decreased weight (consistent with the high dosage)
which continues as the animals age. However, this weight
decrease at 3 mg/kg/day is not statistically significant at any
individual day.
Measured either as absolute weights or as liver-to-body weight
ratios, changes in maternal liver weight at either dosage were
not significant compared to controls. Daily inspection revealed
no treatment-related effects on demeanor or physical appearance
in either adults or young.
Among the reproduction indices reported, neither the fertility
index nor the 24-hour survival index was significantly different
from controls at either dose. By Dunnett's test four indices at
30 mg/kg/day were significantly less than control: gestation
survival, and 7-day, 14-day, and 21-day survival. Average
litter sizes were significantly less than controls on days 7,
14, and 21 at the 30 mg/kg/day dose. Gestation-period length
showed no significant treatment-related effect.
At this 30 mg/kg/day dose there was also a general trend toward
increased frequency of abnormalities in all parameters
reported. Statistically significant increases at! this dose were
t
reported for lumbar spurs and for vertebrae with split centrum.
At the 3 mg/kg/day level there was neither a trend toward
350
-------
increased abnormalities nor any statistically significant
increases in any of the parameters reported.
Schwetz e_t a 1. (1978) is adequate to establish 3 mg/kg/day as
the fetotoxicity NOEL for the penta analyzed. The test material
(see Table II.D-18) was reported to contain 10-fold less
hexachloro-, 30-fold less heptachloro-, 200-fold less octachloro-
dibenzo-p-dioxin, and 6- to 300-fold less of the dibenzofurans
than at least one of the currently manufactured technical pentas.
Eight-Month Rat Feeding Study of Penta
Goldstein et al. (1977) fed female rats 20, 100, or 500 ppm of
either technical or purified penta for 8 months. The technical
penta used for this study was reported to contain only slightly
less HxCDD and hexachlorodibenzofuran than the levels reported
for a currently manufactured commercial penta.
Dosing at 20 ppm (about 1.5 mg/kg/day as interpolated from food
consumption data) resulted in a 15-fold increase over the
control in the activity of aryl hydrocarbon hydroxylase (AHH).
Purified penta, on the other hand, had no significant effect on
AHH induction at any dose tested. Glucuronyl transferase
activity was also significantly elevated at the 20 ppm treatment
level by the technical penta used in this study. The Agency is
not aware of a meaningful toxic state which can be associated,
in this case, with the reported levels of enzyme induction or
elevation. However, elevated AHH activity has been used as a
- 351
-------
"biochemical correlate" (Goldstein, 1980) for the presence in
biological samples of some of the nonphenolic contaminants of
technical penta. At a level of 20 ppm neither technical nor
purified penta in this study affected the excretion of urinary
porphyrins or their precursors. The liver-to-body weight ratio
was not affected significantly at 20 ppm by either grade of
penta.
Chronic and Subchronic Feeding Studies of Penta
Additional assessment of parental chronic toxicity allows
comparison of penta dose levels causing fetotoxicity with those
doses causing significant effects in adult animals. A 2-year
chronic feeding and oncogenicity study in rats (Schwetz et
al., 1978) shows a NOEL of 3 mg/kg/day for body-weight change
and food consumption of the adults. In addition, this study was
unable to demonstrate a significant increase of either benign or
malignant tumors in either sex.
The 8-month rat (male and female) feeding study of Kimbrough and
Linder (1978), using the technical penta of the Goldstein study
(Goldstein et al., 1977), showed only "mild" histological
alterations (unspecified) in the liver at the 20 ppm dietary
concentration.
The results of 90-day feeding studies are also useful for
comparison with fetotoxic effects, which may occur with
relatively short exposure duration. In a 90-day rat feeding
study, Kociba et al. (1973) used doses of 1, 3, 10, and 30
352
-------
mg/kg/day. Several of the adult body-weight gains were
significantly different from controls: males were higher,
females were lower. A comparison of the pooled dose means with
controls, however, failed to show a treatment effect. The
testes-to-body-weight ratios were lower than controls at all
doses and significantly lower at 10 and 1 mg/kg/day. Also,
there was no clearly established NOEL for serum glutamic pyruvic
transaminase or alkaline phosphatase elevations.
The 90-day rat feeding study of Knudsen et. al. (1974), done with
an inadequately described technical penta, showed significantly
elevated alkaline phosphatase levels in females at 1.1 mg/kg/day.
Liver and kidney weights appeared to show a dose-related increasing
trend in both sexes. The liver weight increase in females was
significant at 2.5 and 10 mg/kg/day. Liver histopathology,
specifically centrilobular vacuolization, was present in both sexes
at 10 mg/kg/day. At 2.5 mg/kg/day, this effect was marginally
elevated in females but absent in males.
A third 90-day rat feeding study (Johnson et. al., 1973) also
was done with an incompletely described technical penta. The
NOEL was 3 mg/kg/day, based on increased liver weight at higher
doses.
353
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Fetotoxic, Teratogenic, and Reproductive Effects of HCB
Courtney e_t al. (1976) reported a teratogenic effect caused by
HCB in mice. Oral administration to CD-I mice on days 7 to 16
of gestation showed that HCB at 100 mg/kg/day produced
significantly elevated maternal liver-to-body weight ratios and
decreased fetal body weights. The number of abnormal fetuses
per litter increased significantly. In one of the litters the
abnormalities included some cleft palates.
Khera (1974) reported fetotoxic effects, which were limited to
dose-related sternal defects at doses of 40 mg/kg (days 6 to 21
of gestation) and to a significantly increased incidence of uni-
or bilateral fourteenth ribs. This latter effect was dose- and
duration-dependent and commenced at the lower dose (10 mg/kg/day)
during either days 6 to 16 or days 10 to 13 of gestation. There
were no HCB-related effects on external morphology. Khera did
not observe visceral deformities and histological examination was
negative. The parameters of a concurrent dominant lethal assay
were all within the control range. There was a NOEL of 60 mg/kg/day
for maternal toxicity (weight loss and convulsions) when HCB was
administered on gestation days 6-21 or for shorter periods.
Simon e_t al. (1979) also observed that HCB, when administered at
either 70 or 221 mg/kg/day for 5 days, would not induce dominant-
lethal mutations in the rat. At these two doses, however, HCB
showed a dose-dependent decrease in the number of females
inseminated and impregnated.
354
-------
Grant et al. (1977) / in a four-generation rat reproduction
study, found that pregnancy, viability, lactation indices,
neonatal weight gain, and relative liver weight all had a NOEL
of 1.0 mg/kg/day dietary HCB. At a 4-fold higher dose, several
of the maternal animals died. No gross abnormalities were
observed in the young rats.
In several mammalian species penta is one of the metabolites of
HCB. Koss ej: al. (1978) dosed female rats with HCB on alternate
days at 50 mg/kg. These researchers found a blood ratio of
penta (as a metabolite of HCB) to HCB of about 1:10 at steady-
state. The mean blood concentration of HCB in the general
population is reported to be less than 1 ppb (Strassman-Sundy,
1980) .
iii. Quantitative Human Risk Assessment of Fetotoxic Effects
Margins of Safety for Population Sub-Groups
For the fetotoxicity risk assessment of penta for occupational
sub-groups, the Agency has calculated individual values of the
Margin of Safety (MOS). The MOS value is the ratio of the NOEL
in animal experiments to the appropriate sub-group exposure
value. PD-1 stated that the study of Schwetz e_t al. (1974)
indicates the fetotoxic and teratogenic properties of penta.
The Agency continues to maintain that Schwetz et al. (1974), a
study which has not been invalidated, shows that penta causes
several fetotoxic responses in rats. The Agency notes that the
355
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incidence of delayed skull ossification was significantly
increased at 5 mg/kg/day (purified-grade penta), the lowest dose
tested. Thus, this risk assessment uses the NOEL of 3 mg/kg/day
as shown in the one-generation study of Schwetz e_t al. (1978).
For penta and two of its major contaminants the following NOEL
values are used for MOS calculation:
penta: 3 mg/kg/day (Schwetz ejt _al., 1978
HxCDD: 0.1 ug/kg/day (Schwetz et al., 1973)
HCB: 1.0 mg/kg/day (Grant et _al., 1977)
The calculated MOS values, based on the exposure figures pre
sented in Tables II.D-13 to II.D-15, are listed in Tables II.D-19
to II.D-21.
b. Oncogenicity
As discussed in Section II.D.4, there is reason to believe that
exposure to technical penta poses a finite oncogenic risk. The
quantitative assessment of that risk follows.
The experimental data used as the basis of this risk assessment
is taken from the National Cancer Institute (1980) study in
which Osborne-Mendel Rats and B6C3F1 mice were administered
either a vehicle control (3 groups of 25 per sex per species) or
HxCDD (50 animals per sex per species for each dosage level).
356
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TABLE II.D-19
Margins of Safety for Fetotoxic Effects
Based on Estimates of Human Exposure to Penta
Total Penta Margin .
Site Exposure (ug/kg/day)a of Safety
Pressure Treatment
Manual emptying of penta bags
Opening cylinder door
General operations
Dip/ Flow Treatment
Surface Spray Treatment
Sapstain Treatment (Dip)
Sapstain Treatment (Spray)
Occupational End Use
Poorly-ventilated area
Well-ventilated area
Home and Farm Use
During application: indoors
outdoors
After application: indoors
outdoors
227 to 470
20C
4.1
510
300
51
60
5.9C
0.38C
7.5 to 500
4.6 to 500
8C
d
6.4 to
150
730
5.9
10
59
50
510
7,900
6 to 4
13
00
6 to 650
380
a. Sum of dermal and inhalation exposure estimates from Table 9.
b. NOEL = 3 mg/kg/day = 3,000 ug/kg/day.
c. Due to lack of data, this estimate does not include dermal
exposure.
d. No estimate possible due to lack of dermal exposure data.
357
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TABLE II.D-20
Margins of Safety for Fetotoxic Effects
Based on Estimates of Human Exposure to HxCDD
Site
Total HxCDD
Exposure (ug/kg/day)'
Occupational End Use
Poorly-ventilated area
Well-ventilated area
Home and Farm Use
During application: indoors
outdoors
After application: indoors
outdoors
e
e
0.000063 to 0.0076
0.000063 to 0.0076
e
e
Margin ,
of Safety
Pressure Treatment
Manual emptying of penta bags
Opening cylinder door
General operations
Dip/ Flow Treatment
Surface Spray Treatment
Sapsatin Treatment (Dip)
Sapstain Treatment (Spray)
0.0034 to 0.0071
0.0003C
d
0.0033
0.0046
0.00033
0.0009
14 to 29
330
30
22
300
110
13 to 1,600
13 to 1,600
a. Sum of dermal and inhalation exposure estimates from Table 10.
b. NOEL = 0.1 ug/kg/day.
c. Due to lack of data, this estimate does not include dermal
exposure.
d. Exposure is considered negligible due to automated procedures,
lack of significant residues, and low vapor pressure of HxCDD.
e. No estimate possible due to lack of dermal exposure data.
358
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TABLE II.D-21
Margins of Safety for Fetotoxic/Reproductive Effects
Based on Estimates of Human Exposure to HCB
Site
Total HCB
Exposure (ug/kg/day)'
Margin ,
of Safety
Pressure Treatment
Manual emptying of penta bags
Opening cylinder door
General operations
Dip/Flow Treatment
Surface Spray Treatment
Sapstain Treatment (Dip)
Sapstain Treatment (Spray)
Occupational End Use
Poorly-ventilated area
Well-ventilated area
Home and Farm Use
During application: indoors
outdoors
After application: indoors
outdoors
0.023 to 0.047
0.002C
0.00041
0.051
0.03
0.0051
0.006
0.00059°
0.000038°
0.00075 to 0.05
0.00046 to 0.05
0.0008°
d
>10,000
>10,000
>10,000
>10,000
>10,000
>10,000
>10,000
>10,000
>10,000
>10,000
>10,000
>10,000
a. Sum of dermal and inhalation exposure estimates from Table 9.
b. NOEL = 1 mg/kg/day = 1,000 ug/kg/day.
c. Due to lack of data, this estimate does not include dermal
exposure.
d. No estimate possible due to lack of dermal exposure data.
359
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Fifty additional animals per sex per species were used as
untreated controls.
The study doses were administered by gavage twice a week for 104
weeks. (The dosages shown in Table II.D-22 are the total weekly
dose per animal.) Three or 4 weeks after the dosing period the
surviving animals were sacrificed and necropsied. Moribund
animals were sacrificed and necropsied throughout the study;
thus, histopathology results are available for more than 90
percent of the animals of each study group.
The data shown in Table II.D-22 indicate the number of animals
per sex per species with liver tissue examined (No.) and the
number of animals with liver neoplastic nodules or adenoma
and/or hepatocarcinoma (R). These data suggest a dose-related
increase in the incidence of this condition over the control
frequency in each sex and in each species. The effect appears
to be better defined in the rat, and the female rats seem to be
the most sensitive group. The response of the male mice closely
approximates that of the female rats. Evaluating the
statistical significance of the dose-response relationship
observed in each sex and species, the NCI report states that
there is a statistically significant dose-related trend for this
diagnosis at P = 0.001 to 0.003 in all four sex and species
groups, as calculated by the Cochran-Armitage Test (Armitage,
1973). When the Bonferroni (Dunn, 1961; Miller, 1966)
inequality is used to adjust the nominal P = 0.05 level of test
by dividing by the number of doses, the reference value is P =
0.017. This results in a finding of statistical significance
ding <
360
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TABIE II.D-22
feoplastic Nodi
Cbserved and Risk Est Mates Completed
Incidence of Cbserved Neoplastic Nodules and/or Carcinoma
Dose of Qsborne-Mendel Rat
HxCDD Male Female
(ug/kg/wk) No. Rc No. R
0.00
1.25
2.50
5.00
10.00
74
49
50
48
0
0
0
1
4
—
75 5
50 10
50 12
50 30
0
B6C3F1
Male
ND. R
73 15
50 14
49 14
48 24
0
Mice
Fanale
ND. R
73
0
48
47
47
3
—
4
6
10
a. Data from NCI, 1980.
b. Number of animals in treatment group.
c. Number of neoplastic nodules and/or hepatocellular carcinomas observed.
361
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for the high and mid-dose female rats and high-dose male and
female mice. The rate in the high-dose male rats is not
considered to be statistically significant because P = 0.022 is
larger than 0.017.
As the female rat and male mouse have similar high levels of
statistically significant response, a quantitative assessment of
risk has been performed for each of these two groups. The
slopes calculated from the data in Table II.D-14, using the One-
Hit model are 0.1233 for rats and 0.047 for mice where the dose
is given in ug/kg/wk. The correction factors for conversion to
the appropriate slopes in humans are 7 fold for rats and 12 fold
for mice. These factors are derived from toxicity studies of
anticancer agents reported by Freireich £t al. (1966).
Thus, the appropriate slopes when the dose is in ug/kg/wk in
humans are:
7 x 0.1233 = 0.863 from the rat data
and
12 x 0.047 = 0.564 from the mouse data
These are transformed to the equivalent slopes for dosage in
ug/kg/day by multiplication by 7:
362
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slope » 7 x 0.863 « 6.04 from the rat data
and
7 x 0.564 » 3.95 from the mouse data
to compute the risk to humans based upon a dose in ug/kg/day.
Die slope derived from the rat data is used in this analysis to
estimate risk to humans, as the rat appears to be more sensitive
than the mouse. The total occupational exposures (sum of dermal
and inhalation exposures in Table II.D-14) are adjusted to
average daily exposure for a lifetime by multiplying the total
exposure by 5/7 (fraction of week exposed, assuming a 5-day work
week) and by i/2 (assuming a worker is exposed for 1/2 a
lifetime). [Note that all exposure figures have been derived
using a woman's average weight (60 kg) and breathing rates.
When these figures are derived using the average weight (70 kg)
and breathing rates of a man, the difference in exposure figures
are insignificant.] This average daily exposure for a lifetime
is then multiplied by the slopes given above (6.04 and 3.95) to
obtain the estimates of cancer risk in an individual's
lifetime. These estimates are presented in Table II.D-23.
Technical penta also contains hexachlorobenzene (HCB), another
known oncogen. In this document, however, the quantitative
oncogenic risk for penta is based on the HxCDD contaminant alone
because the HCB slope is so much lower than the HxCDD slope that
including the HCB-related risk would have only a negligible
effect on the total oncogenic risk.
363
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TABLE II.D-23
Individual Oncogenicity Risk Estimated Due to HxCDD Exposure
Estimated Exposure, Estimate,
Site ( in ug/kg/day x 10 ) of Risk
Pressure Treatment _3
Manual emptying of bags 1.2 to 2.5 7.3 x 10~0
1.5 x 10"2 t0
-4
Opening cylinder door 0.11 6.6 x 10
General operations c c
•Dip/Flow Treatment 1.2 7.2 x 10
Surface Spray Treatment 1.6 9.7 x 10~
—4
Sapstain Treatment (Dip) 0.12 7.2 x 10
Sapstain Treatment (Spray) 0.32 1.9 x 10*"
Home and Farm Use
During application: ,
indoors 0.00017 to 0.021 1.0 x 10~T +._
1.3 x 10"4 t0
outdoors 0.00017 to 0.21 1.0 x 10~^ +.
1.3 x 10~4 t0
After application:
indoors d d
outdoors d d
a. Average daily exposure for lifetime.
b. Based on slope of 6 derived from results of NCI (1980) for
female rat.
c. Exposure is considered negligible due to low vapor pressure
of HxCDD.
d. No estimate possible due to lack of exposure data.
364
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The slope for HCB obtained is 0.025, based on the dosing in ppm
in the diet of male hamsters (Cabral e_t al., 1977). This slope
f
was computed using the One-Hit model, the same model that was
used in computing the slopes for HxCDD shown above. The HCB
slope expressed in terms of ug/kg/day for humans is 0.0027.
Even considering the greater amount of HCB for most cases than
HxCDD in technical penta (100 ppm versus 15 ppm), the oncogenic
risk posed by HCB is negligible when compared with that of HxCDD.
There are a few situations where exposure to HxCDD has been
determined to be negligible (see Table II.D-14). The greatest
HCB exposure under these circumstances is 0.00059 ug/kg/day for
occupational end use, poorly ventilated area (see Table
II.D.15). Adjusting this figure to an average daily exposure
for a lifetime yields an estimated exposure of 0.00021.
Multiplying this estimate by the slope for HCB results in an
estimated lifetime cancer risk of about 6 x 10~ .
Consequently, due to the very small influence of HCB on the
total oncogenic risk, the oncogenic risk from technical penta is
based entirely on exposure to HxCDD.
365
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E. Alternatives
1. Introduction
This section provides a brief discussion of the toxicological
characteristics of the available alternatives to the RPAR wood
preservatives. The objective of this section is to present an
overview of toxicology data derived from literature reviews of
representative scientific articles. It is not possible to
provide a comprehensive, validated data review since a
preliminary survey of the data base indicates extensive data
gaps. Since these chemicals may be substituted for one or more
uses of the RPAR chemicals, the Agency's primary concern focuses
on the potential of the alternatives for adverse chronic
effects. Acute toxicology data is provided when chronic data is
lacking.
The chemicals considered possible alternatives are listed below
(Cummings, 1980). The suitability of these chemicals is
discussed on a use-by-use basis in the following Benefit
Analysis (Part III) of this document.
Acid Copper Chromate (ACC)
Chromated Zinc Chloride (CZC)
Bis(tributyltin) oxide (TBTO)
Copper-8-Quinolinolate (Cu-8)
Copper Naphthenate
Zinc Naphthenate
367
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Chromated Zinc Chloride (CZC)
Trichlorophenol (TCP)
Tetrachlorophenol (Tetra)
2. Acid Copper Chromate (ACC) and Chromated Zinc Chloride (CZC)
as Chromium.
The Agency1s data base does not contain toxicology data
specific to CZC and ACC. However, because chromium is a common
component of both CZC and ACC, some discussion of chromium is
applicable inlight of the absence of more relevant data.
Chromium is a suspected oncogenic and mutagen. Chromates,
particularly calcium chromate, have been shown to be mutagenic
by multitest evidence (Venitt e_t al, 1974; Nishioka, 1975;
and Pradkin e_t al., 1975). Additionally, epidemologic studies
indicate chromate is a carcinogen with bronchogenic carcinoma
as the principal lesion (Doull e_t al., 1980). Nettlesheim et
al., (1971) demonstrated the induction of adenocarcinomas and
adenomas in the bronchial tree of mice by exposing them to
calcium chromate dust. Laskin e_t al., (1970) also produced
carcinoma in mice with calcium chromate by intrabronchial
implant.
The Agency recognizes that one cannot extrapolate from data
based on chromium to determine the toxicological effects of
CZC and ACC. However, the Agency does conclude that CZC and
368
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ACC warrant further toxicology testing due to the potential for
adverse chronic effects.
3. Bis(tributyltin) oxide (TBTO)
a. Acute lexicology
Tests involving male rats demonstrated acute oral LD^'s of
194 mg/kg and 148 mg/kg when administered technical TBTO at 10%
v/v in an aqueous suspension and in corn oil, respectively
(Elsea, et al., 1958).
The rabbit dermal LD5Q for technical TBTO was shown to be 11.7
gm/kg. (Elsea, et al., 1958).
Test results showed TBTO to be a skin sensitizer in guinea pigs
when administered as a 0.1% v/v concentration in sesame oil.
(Elsea, 1956).
In a primary skin irritation study, rabbits received a 24 'hour
exposure to pig-skin impregnated with TBTO at concentrations
ranging from 31.25 to 1000 ug per/square inch. At
concentrations of 0.5 ing/per square inch or less, TBTO was not a
primary irritant, but was considered to be corrosive at 1.0
mg/per square inch. (International Research and Development
Corp., 1966).
369
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Extreme eye irritation and corneal damage resulted when 6 New
Zealand strain rabbits were treated with 100 mg of TBTO (Hine
Laboratories, 1976) .
When rats received a one hour mist inhalation exposure to
varying concentrations of TBTO (0.2-2.0 mg/liter), the acute
inhalation LCcQ was determined to be 0.48 mg/liter. (Food and
Drug Research Laboratories, 1976).
The above studies indicate TBTO's potential for acute adverse
effects. At the dosages tested in the oral and inhalation
studies TBTO may not be considered acceptable for domestic use
situations unless classified for restricted use. The eye
irritation study also suggests that the Agency would consider
only a restricted use classification for ail domestic and non-
domestic uses of TBTO.
b. Chronic Toxicology
Data are unavailable in the Agency's files to determine long-
terra effects of TBTO.
370
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4. Copper-8-Quinolinolate (Cu-8)
a. Acute Toxicology
When Sprague-Dawley rats were orally dosed with 90% Cu-8 (as a
20% suspension), LDCQ values for male rats were 4.7 gm/kg;
the LD50 for female rats was 3.9 gm/kg. (Ezumi et al.,
1971) .
The rabbit acute dermal IA-0 was 2.0 gm/kg for a 96% Cu-8
powder (Mouser, 1973a) . Using the same formulation, rabbits
were observed to have slight eye irritation after seven days of
observation (Mouser, 1973b).
Acute inhalation studies utilizing 60 Sprague-Dawley rats,
divided into groups, received 4 hours of exposure to respirable,
technical Cu-8 dust (0.13, 0.69, 0.95, 1.21, 1.27 mg/liter).
After 14 days of observation the inhalation LC5Q was
determined to be 0.82 mg/liter. (Berczy, £t al., 1975).
It is difficult to relate the above data to actual risk
potential due to the high dosage rates used in testing.
However, it is demonstrated that technical and near technical
grade (90.0% and above) Cu-8 is acutely toxic, particularly by
the inhalation route. Dermal exposure appears to be less
hazardous, but may also prove to be unacceptable for general use
at the dosage tested.
371
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b. Chronic Toxicity
Ames tests conducted with 4 tester strains of Salmonella
typhimurium showed some evidence of mutagenic potential,
specifically of the frame-shift type. However, the positive
responses were not dose related (Hossack e_t _al.r (1978b) . A
micronucleus test (chromosomal damage) demonstrated comparable
results between test rats and control rats when dosages of
2.8, 5.6 and 11.2 gm/kg of Cu-8 were administered by oral
gavage (Hossack et a^L., (1978a). However, the NIOSH
Directory of Suspected Carcinogens (197fa) lists Cu-8 as a
suspect carcinogen (Christensen e_t _al., 1976). To date, the
Agency has not validated the study(s) indicating the
carcinogenic potential of Cu-8.
The above information indicates that Cu-8 has the potential for
chronic adverse effects, specifically mutagenicity and
oncogenicity. Further hazard and exposure evaluation is
required prior to a final determination.
5. Copper Naphthenate
a. Acute Toxicology
When rats were dosed with 8.0% copper naphthenate, the acute
oral LDcQjwas determined to be greater than 6.0 gm/kg
(Rockhold, 1955). Rabbit eye irritation studies were negative
for 8.0% copper naphthenate (Moldovan, 1969).
372
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When Charles River rats inhaled 8.0% copper naphthenate for 1
hour, no deaths or overt pathological changes were observed
after 14 days. The inhalation LC5Q is greater than 105
mg/liter (Hathaway, 1971).
Similarily, an inhalation LC50 using 20% copper naphthenate
could not be established for Sherman-Wistar rats. After 14
days, no lethal effects were observed at the highest dosage
(19.1 mg/liter) after 1 hour of inhalation exposure
(Levinson,1971).
Very little data are available with which to make a complete
assessment of the acute effects of copper naphthenate.
However, from the data that is available, inhalation exposure to
20.0% or less of copper naphthlenate does not appear to pose an
unreasonable acute risk. Similarily, the acute oral LD5Q is
not considered to be excessive for 8.0% copper naphthenate.
b. Chronic Toxicology
Data are unavailable in the Agency's files to determine long-
term effects of copper naphthenate.
373
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6. Zinc Naphthenate
a. Acute lexicology
When rats orally received a single dose of 8.0% zinc
naphthenate, no deaths were reported at 6.0 gm/kg (Rockhold,
1955). Similarily an acute oral LDcn could not be established
for Sherman-Wistar rats receiving a dose of 26.4% zinc
naphthenate. The highest dose administrated was 5.0 gm/kg
(Moldovan, 1971a) .
Rabbits demonstrated no eye irritation after 3 days; and
moderate erythema and moderate edema when 26.4% zinc naphthenate
was applied to the eye (Moldovan, 1971c) and skin (Moldovan,
•1971b) respectively.
As with copper naphthenate, the acute data base for zinc
naphthenate is incomplete. From the data available it appears
that formulations containing 26.4% or less zinc naphthenate
may qualify for an unrestricted use classification. A final
determination, however, cannot be made until all acute
toxicology data requirements are fulfilled.
b. Chronic lexicology
Data are unavailable in the Agency's files to determine long
term effects of zinc naphthenate.
374
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7. Trichlorophenol and Tetrachlorophenol
a. Introduction
This discussion will be limited to 2,4,5 and 2,4,6
trichlorophenol and to 2,3,4,6 tetrachlorophenol and their
respective sodium salts. These isomers are the only chemicals
in the tri and tetrachlorophenol group that are of commercial
value as wood preservatives.
b. 2,4,5 Trichlorophenol (2,4,5 TCP)
On August 2, 1978 the Agency issued a Notice of Rebuttable
Presumption Against Registration (RPAR) (43 FR August 2, 1978))
for 2,4,5 TCP and its salts. The notice and corresponding
Position Document defines the risk criteria which have been
exceeded by this pesticide. Specifically, the risks which have
been deemed to be unreasonable are oncogenicity and
fetotoxicity. Of the chlorophenols considered here, Firestone
et jal., (1972) identified 2,4,5 trichlorophenol (2,4,5 TCP),
as containing 2,3,7,8 tetrachlorodibenzo-p-dioxin (2,3,7,8
TCDD). The Agency cannot determine if these effects are solely
related to the TCDD impurity in 2,4,5 TCP, or if 2,4,5 TCP
itself is inherently oncogenic and fetotoxic. Pure,
uncontaminated 2,4,5 TCP is not available. There is
evidence that TCDD has the potential to cause oncogenic and
fetotoxic effects (43 FR August 2, 1978).
375
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c. 2,4,6 Trichlorophenol (2,4,6 TCP)
The U.S. National Cancer Institute (1980) reported that 2,4,6
TCP was carcinogenic in a two year feeding study with F344
rats. Positive results, induction of lymphomas or leukemias,
were only evident in male rats; 2,4,6 TCP did not cause cancer
in the female test rats. However, in a corresponding 2 year
feeding study using B6C3F1 mice, 2,4,6 TCP induced
hepatocellular carcinomas or adenomas in both sexes.
d. 2,3,4,6 Tetrachlorophenol (2,3,4,6 Tetra)
The effect of both commercial and purified grades of 2,3,4,6
Tetra upon rat embryonal and fetal development was evaluated by
-Schwetz e_t al., 1974a) . The authors concluded that the
material at 30 mg/kg/day, is not teratogenic but was embryo
*
and fetotoxic.
As mentioned earlier, Firestone £t jal., (1972) has identified
the presence of hexachlorodibenzo-p-dioxin (HxCDD) impurities in
2,3,4,6 Tetra. Positive NCI studies have demonstrated the
possible carcinogenicity of certain isomers of HxCDD. (see
Sections 1I.D.4.C and II.D.S.b).
8. Summary
As discussed in the introduction, the data base utilized to
define the toxicological characteristics of the alternatives to
376
-------
the RPAR chemicals is preliminary. It does not represent the
entire data base available to the Agency nor do t'.a studies meet
ail of the test methodqlogy criteria considered appropriate.
The data base for the alternative wood preservatives is
so deficient as to disallow a definitive assessment of the
risks associated with use of the alternative wood
preservatives. However, there is suggestive evidence to
indicate that the acute toxicity of TBTO and Cu-8 may be
unacceptable for unrestricted use. bimilarily, the data for
CZC, ACC, Cu-8, 2,4,5 TCP, 2,4,6 TCP and 2,3,4,6 Tetra indicate
potential long term adverse effects. The toxicological
potential of copper naphthenate and zinc naphthenate cannot be
assessed on the basis of a few acute toxicology studies in which
LDcQ values could not be determined. In conclusion, from a
safety point of view, the alternatives do not appear to be
preterrabie to the RPAR wood preservative.
377
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III. BENEFIT ANALYSIS
A. Introduction
Part III contains the economic impact analysis of the wood
preservatives creosote, inorganic arsenicals and penta by use
category. This analysis is based, in large part, on material
from the USDA-States-EPA Assessment Team (1980) . This analysis
evaluates the economic impact of the cancellation of one or more
of the wood preservative agents in terms of the cost of substitu-
tion of the remaining registered wood preservative(s) or alter-
nate materials (e.g., concrete). Based on data from 1977 to
1979, economic impacts are estimated for the wood preservative
industry and projections are given for the resulting commodity
impacts for users of the treated wood. Economic impacts are
estimated on a national basis and, when possible, on a per unit
of wood or per establishment basis. Local community economic
impacts were not investigated due to the Agency's limited
information in this area.
This part considers pressure and non-pressure uses ot the wood
preservative agents on a use-by-use basis. The first portion of
Part III deals with the pressure uses of the wood preservative
agents, namely: 1) railroad ties, 2) lumber, timber and ply-
wood, 3) pilings, 4) posts, 5) crossarms and 6) poles. The
remainding portion of Part III discusses the non-pressure uses
379
-------
of the wood preservatives: 1) poles-groundline, 2) home and
farm, 3) sapstain control, 4) millwork and plywood and 5)
particleboard.
B. Pressure Treatments
1. Profile of the Wood Treatment Industry
a. Introduction
The wood preservative treatment industry is comprised of
establishments that treat wood with preservatives in retorts or
open tanks [the 1972 Standard Industrial Classification (SIC
2491) manual (U.S. Dept. of Commerce, 1972)]. The 1977 Census
of Manufactures (U.S. Dept. of Commerce, 1979), Dun and
Bradstreet (1979), the American Vvobd Preservers Association
(AWPA) survey and the USDA-States-EPA Assessment Report (1980)
are major sources of data on the wood preservative industry.
The pressure treatment use categories include: 1) railroad
ties, 2) lumber, timber and plywood, 3) pilings, 4) posts, 5)
crossarms and 6) poles. Although some plants only have the
capability of treating wood in one or a limited number of these
use categories, often plants have the capability to treat wood
destined tor the full range of uses presented above.
Many of these wood treatment plants are owned by small
businesses which operate only one or two cylinders or treating
380
-------
tanks. However, in 1975 about half of the wood treating
industry was controlled by ten companies (Fuller e_t al.,
1977) .
b. Usage of Wood Preservatives
The usage of creosote, inorganic arsenicals and penta for
pressure wood treatments is summarized in Tables III-l to
III-5 by the volume of chemicals used as well as the volume of
wood treated. Creosote is primarily used for railroad ties,
penta for poles, and inorganic arsenicals for lumber and
timbers.
In recent years, the wood treating industry has been sub-
stituting with either the fixed preservative treatments of
chromated copper arsenate (CCA) or ammonical copper arsenate
(ACA) for the non-fixed preservative treatment of fluor chrome
arsenic phenol (FCAP). The volume of wood treated with FCAP has
declined from 14.02 million cubic feet in 1967 to zero cubic
feet in 1978. The usage of FCAP will likely disappear within a
short period since FCAP is no longer manufactured in the united
States, but is currently registered with EPA (USDA-States-EPA,
1980). Hence, the economic impacts of the cancellation of FCAP
for the use categories lumber, timber and plywood, pilings,
posts, crossarms and poles are considered to be small and was
not subjected to further analysis.
381
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TftBLE 1II-1 Products Treated—All Preservatives'? 1970-1974b
Crossties
Switch ties
Lunnber and
timbers
Plywood0
Piling
Posts
Crossarros
R>les
Other
'iotal
1970
79,384
7,874
52, 105
(1,344)
15,128
15,106
3,454
76,760
5,913
255,724
1971
87,029
6,208
56,303
(1,578)
13,699
16,669
3,075
74,374
6,392
263, 749
1972
Ifififi r»i A-\i r» -fdai
§ UUU CtU 1C Lct^l
85,880
5,971
59,700
(1,923)
14,324
18,175
2,487
74,537
5,667
266,741
1973
67,603
5,006
64,762
(2,079)
12,978
15,168
2,592
75,379
5,243
248,731
1974
75,870
6,051
73,692
(1,766)
13,315
17,304
2,416
73,112
6,833
269,043
a. .Material treated with fire retardants not included. CZC and ACC included.
b. Source: USDk-States-EPA, 1980.
c. Plywood volune included in "other." Volumes shown include retardant
treatments.
MOLE: Columns may not add to totals due to rounding.
382
-------
OABLE 111-1 Products Ireated—-All Preservatives^ 1975-1978b (cont'd)
1975
1976
1977
1978
Crossties
Switchties
lumber and
timbers
Plywood0
Piling
Posts
Crossams
Poles
Other
Total
93,097
7,959
58,135
(1,859)
9,403
15, 311
1,424
49,144
5,995
240, 468
95,320 93,518
5,728 6,708
63,626
(2,848)
8,478
13,769
4,628
53,143
11,231
255, 923
60,396
(2,406)
11,346
10,735
1,347
52, 531
14,770
251, 351
106,085
107, 579
(2,845)
12,114
20,105
1,692
64,179
18,266
330, 020
a. Material treated with fire retardants not included. CZC and ACC included.
b. Source: USm-States-EPA, 1980.
c. Plywood volune included in "other." Volumes shown include retardant
treatments.
NOTE: Oolunns may not add to totals due to rounding.
383
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TfiBLE III-2 Products Ireated with Creosote Solutions^ 1970-1974b
Crossties
Switchties
Lumber and
timbers
Piling
Posts
Crossams
Poles
Other
Ibtal
1970
78,970
7,812
15,190
14,363
7,770
462
37,687
2,612
164,866
1971
86,813
6,144
14, 256
12,809
7,774
351
32, 593
2,417
163,157
1972
Ifinn rM^i r* i'oca
85,680
5,917
12,972
13,562
7,343
373
27,560
2,144
155, 551
1973
t- __-. — __
67,433
4,999
11,863
12,376
5,294
352
26,334
1,940
130,591
1974
75,520
6,453
12,680
12,768
5,570
437
29,071
2,445
144,944
a. Creosote, creosote-ooal tar, creosote-petroleum and creosote-penta.
b. Source: USCA-States-EPA, 1980.
NOTE: Columns may not add to totals due to rounding.
384
-------
OftBIE III-2 Products treated with Creosote Solutions*? 1975-1978b (cont'd)
1975
1976
1977
1978
Crossties
Switchties
lumber and
timbers
Piling
Posts
Crossaons
Poles
Other
lotal
92,658
7,926
13,044
8,529
3,228
93
14,847
3,078
143,403
95,165 91,281
5,718 6,161
9,672
7,473
2,826
78
14,571
3,501
139,004
9,083
9,495
2,526
41
15,634
7,782
142, 003
103,138
10,780
9,993
4,584
41
18,237
7,815
154,587
a. Creosote, creosote-ooal tar, creosote-petroleun and creosote-penta,
b. Source: USEA-States-EPA, 1980.
NOTE: Columns may not add to totals due to rounding.
-------
TABIE IH-3 Products Treated with Pentat 1970-1974b
Crossties
Switch ties
Lumber and
timbers
Piling
Posts
Crossatms
Poles
Other
lOtal
1970
296
51
15,397
674
6,858
2,968
37,259
2,183
65,686
1971
75
52
15,198
710
8,232
2,688
40,162
2,380
69,498
1972
79
50
16,394
239
9,924
2,093
45, 230
1,786
75, 795
1973
53
7
19,663
288
9,055
2,234
47,193
1,528
80,022
1974
321
19, 302
135
9,580
1,947
42,031
2,450
75,766
a. Petroleum-pen ta only, creosote-penta included in Table III-2.
b. Source: USOA-States-EPA, 1980.
NOTE: Golunns may not add to totals due to rounding.
386
-------
1ABIE III-3 Products Treated with Rsnta^ 1975-1978b (oont'd)
Crossties
Switchties
lumber and
timbers
Piling
R>sts
Crossatms
Poles
Other
Ibtal
1975
334
24
15,837
384
9,953
1,301
32, 155
783
60,771
1976
Innn
19
13,837
368
9,096
4,541
36,525
1,208
65,630
1977
43
376
9,931
1,042
6,791
1,299
33,193
2,117
54,789
1978
449
21,209
1,154
10,983
1,615
41,905
2,681
79,996
a. Petroleum-penta only, creosote-penta included in lable III-2.
b. Source: USOV-States-EPA, 1980.
NOTE: Columns may not add to totals due to rounding.
387
-------
1ABLE 111-4 Products Treated vdth inorganic Arsenicals^ 1970-1974
Crossties
Switchties
Lumber and
timbers
Piling
Posts
Crossarms
R)les
Other
'total
1970
116
11
19,635
90
479
24
1,813
1,118
23,286
1971
141
12
24,161
179
660
36
1,619
1,590
28,398
1972
Ififin rM^"\ i r* -f cioi
f UUU CLJJ1C Lccl
121
4
27,503
522
904
21
1,747
1,737
32,559
1973
116
30,146
314
786
6
1,854
1,773
34, 995
1974
29
38,704
412
2,120
29
1,833
1,934
45,061
a. CCA, ACA, FCAP
b. Source: USDA-States-EPA, 1980.
NOTE: Columns may not acid to totals due to rounding.
388
-------
TftBIE III-4 Products treated with Inorganic Arsenicals* 1975-1978
(cont'd)
Cross ties
Switchties
lumber and
timbers
Piling
Posts
Crossarms
Poles
Other
•total
1975
86
9
27,331
484
2,023
30
1,277
2,122
33,362
1976
133
37,354
564
1,837
8
1,423
6,522
47,841
1977
font- _ _ _ .
2,195
171
39,108
785
1,341
3,704
4,718
52, 022
1978
2,498
73, 317
943
4,461
29
4,038
7,616
92,903
a. CCA, ACA, FCAP.
b. Source: USEA-States-EPA, 1980.
NOTE: Columns may not add to totals due to rounding.
389
-------
TftBIE III-5 Products Treated and Preservatives Used 1970-1978a' b
Use Category
1. Railroad ties
crossties ,
switchties
and scape
ties)
2. Lumber &
timbers
3. Piling
4. Posts
Year
1970
1971
1972
1973
1974
1975
1976
1977
1978
1970
1971
1972
1973
1974
1975
1976
1977
1978
1970
1971
1972
1973
1974
1975
1976
1977
1978
1970
1971
1972
1973
1974
1975
1976
1977
1978
Vblune
Treated
i nnn ft-
J.UUU i-u
87,256
93,237
91,851
72,608
82,323
101,037
101,035
100,225
106,085
50,272
53,615
56,869
61,672
70,686
56,212
60,899
58,122
105,305
15,127
13,698
. 14,323
12,978
13,315
9,397
8,405
11,322
12,090
15,107
16,666
18,171
15,135
17,270
15,204
13,759
10,658
20,028
Creosote
Solutions
99.5
99.7
99.7
99.8
99.6
99.6
99.8
97.2
97.2
30.2
26.6
22.8
19.2
17.9
23.2
15.9
15.6
10.2
94.9
93.5
94.7
95.4
95.9
90.8
88.9
83.9
82.7
51.4
46.6
40.4
35.0
32.3
21.2
20.5
23.7
22.9
Preservat
Penta
0.4
0.1
0.1
0.1
0.4
0.4
0.4
0.4
30.6
28.3
28.8
31.9
27.3
28.2
22.8
17.1
20.1
4.5
5.2
1.7
2.2
1.0
4.1
4.4
9.2
9.5
45.4
49.4
54.6
59.8
55.5
65.5
66.1
63.7
54.8
ive Used
Inorganic
Arsenical s
0.1
0.2
0.1
0.2
0.1
0.1
2.4
2.4
39.1
45.1
48.4
48.9
54.8
48.6
61.3
67.3
69.6
0.6
1.3
3.6
2.4
3.1
5.2
6.7
6.9
7.8
3.2
4.0
5.0
5.2
12.3
13.3
13.4
12.6
22.3
390
-------
TABLk; II1-5 Products Ireated and Preservatives Ifeed 1970-1978 (cont'd)
5.
6.
7.
8.
Use Category Year
Crossarms 1970
1971
1972
1973
1974
1975
1976
1977
1978
Poles 1970
1971
1972
1973
1974
1975
1976
1977
1978
Other products 1970
1971
1972
1973
1974
1975
1976
1977
1978
All products 1970
1971
1972
1974
1974
1975
1976
1977
1978
UoLune
Treated
i flfifi ft-
XUUU Lt
3,454
3,075
2,487
2,592
2,413
1,424
4,627
1,340
1,685
76,759
74,374
74,537
75,381
72,935
48,279
52,519
52,531
64,179
5,913
6,387
5,667
5,241
6,829
5,983
11,231
14,617
18,113
253, 838
261,053
263,905
245,608
265, 771
237,536
252, 475
248,814
327,485
Creosote
Solutions
13.4
11.4
15.0
13.6
18.1
6.5
1.7
3.1
2.4
49.1
43.8
37.0
34.9
39.9
30.8
27.7
29.8
28.4
44.2
37.8
37.8
37.0
35.8
51.4
31.2
53.2
43.1
64.9
62.5
58.9
53.2
54.5
60.4
55.1
57,1
47.2
Preservative
Penta
85.9
87.4
84.2
86.2
80.7
91.7
98.1
96.9
95.8
48.5
54.0
60.7
62.6
57.6
66.6
69.5
63.2
65.3
36.9
37.3
31.5
29.2
35.9
13.1
10.8
14.5
14.8
25.9
26.6
28.7
32.6
38.5
25.6
26.0
22.0
24.4
Used
Inorganic
Arsenical s
0.7
1.2
0.8
0.2
1.2
2.1
0.2
1.7
2.4
2.2
2.3
2.5
2.5
2.6
2.7
7.1
6.3
18.9
24.9
30.7
33.8
28.3
35.5
58.1
32.3
42.1
9.2
10.9
12.3
14.2
17.0
14.0
18.9
20.9
28.4
a. Materials treated with creosote solutions, penta, and inorganic
arsenicals only. ACC and CZC not included.
b. Source: USEft-States-EBA, 1980.
391
-------
In 1977, 588 wood pressure treatment plants in the United States
were listed with Dun and Bradstreet. The 1977- Census of
Manufactures (U.S. Dept. of Commerce, 1979) and the 1977 AWPA
survey (Maloney and Pagliai, 1978) identified 458 and 472 wood
treating plants, respectively, in the United States. These
sources may have missed many smaller plants, particularly those
*
plants treating with inorganic arsenicals (Josephson, 1979) .
Pressure treatment predominates in all regions of the country
and accounts for 75% or more of treatment plants in each
region, whereas non-pressure plants are most prevalant in the
Rocky Mountains and Pacific regions and account for about 20% of
ail treatment plants in those regions. In 1976, for example,
about 365 plants- (88%) treated only with pressure, 30 plants
(7%) used only non-pressure treatment, and the remaining 20
plants (5%) used both pressure and non-pressure treatment
(Fuller e_t ail., 1977) .
In 1977, of the total number of pressure treatment plants, about
177 used creosote, 194 used penta, and 181 treated with
inorganic arsenicals; almost one half the wood preserving
pressure treatment plants used more than one preservative
compound (Josephson, 1979).
* Discrepancy in these figures is due to the use of varying
sources. '
392
-------
c. Employment and Revenue
In recent years, approximately 60% of the treatment plants
employed fewer than 20 workers, whereas about 6% of the plants
*
employed 100 or more workers (Dun b Bradstreet, 1979) .
The total employment in the wood treatment industry in 1977 was
12,300 workers of whom 9,600 were employed as production workers
and worked 18.7 million man hours (U.S. Dept. of Commerce,
1979). Production employment increased by 400 workers between
1972 and 1977, but total production man-hours actually decreased
by 100,000 hours due to a reduction in the average annual hours
worked per person. Although plants with 50 or more employees
accounted for only 19% of the total workers, these plants
produced 64% of the total value ot treated wood for 1972.
The total value of treated wood shipments by treatment plants
increased from $475.8 million in 1972 to $950.2 million in 1977
with the cost of materials purchased by the wood treatment indus-
try increasing from $303.6 million in 1972 to $650.4 million in
1977. New capital expenditures in the wood treatment industry
increased from $14.8 million in 1972 to $30.3 million in 1977
* Similarly, in 1972 plants with 100 or more workers employed
over 5% of the total worKers compared with plants with less
than 20 workers which employed 58% of the total workers (U.S.
Dept. of Commerce, 1975).
393
-------
(U.S. Dept. of Commerce, 1975, 1979). Expenditures for capital
investment and non-labor inputs are expanding more rapidly than
the expenditures for labor inputs.
2. Comparative Costs of Wood Preservative Compounds, Their
Future Availability and Price, and the Projected Service
Life of Treated Wood
This section provides a brief survey of the availability of the
three major wood preservatives and expected price trends. The
availability of raw materials, trends in raw material prices,
and manufacturing capacity are important variables influencing
the future availability and price of the wood treatment
chemicals.
a. Introduction
All untreated wood products, regardless of their original
strength, durability or natural resistance, are subject to degra-
dation when placed in end-use situations which are conducive to
attack by fungi, insects, bacteria or marine borers. The appli-
cation of selected chemicals as wood preservatives protects wood
from deterioration and frequently yields a product with signifi-
cant advantages in terms of cost and performance (e.g., more
versatility with wood than non-wood products) over non-wood
alternatives that might be available.
394
-------
The actual service life of treated wood products depends on the
treated wood's inherent resistance to decay as well as on the
environmental conditions of end-use such as marine immersion or
ground contact (USDA-States-EPA, 1980). An increase in life
expectancy of five or more times that of untreated wood is
achieved for most treated wood products.
b. Comparative Costs of Wood Preservatives and Service Life of
Treated Wood
Table 111-6 presents the cost of several different preservative
formulations used for pressure treatments per cubic foot of wood
[derived from the price per pound of the preservative times the
retention rate (pounds cubic foot)]. Table III-7 presents the
chemical retention rates for various wood products and the
projected service lives of these products. This information is
used to derive the comparative costs of the preservative treat-
ment for the several preservative agents on a use-by-use basis.
395
-------
111-6 Price of Preservative Chemicals and Solvents, and Cost of
Formulations per Cubic Foot of Wood Treated, 1979
Product
Retention
(pounds per
cubic foot)
Uiit
Weight
per unit
Price
per unit
Price per
Creosote
8 9 12
9 pounds
_ — _ _ en ft"} _ _ _ _
$ 0.092
Coal Tar
gallon
10 pounds
$ 0.80
$ 0.080
pound of
preservative
Cost of
preservative
per cubic foot
$ 0.738 $ 0.830 $ 1.106
a. Prices of chemical developed by USEA-States-EPA Assessment lean in
consultation with industry representatives, October, 1979.
396
-------
TftBIE II1-6 Price of Preservative Chemicals and Solvents, and Cost of
formulations per Cubic Foot of Wood Ireated, 1979 (continued)
Pcoduct
Re tention
(pounds per
cubic foot)
Uiit
Weight
per unit
Price
per unit
Re ice per
pound of
preservative
Cost of
preservative
per cubic foot
Creosote-Coal Tar
8
12
_ gallon
9.5 pounds
$ 0.815
$ 0.086
$ 0.687 $ 0.772 $ 1.029
Petroleum
P9,
iype A
P9,
Type B
gallon gallon
7.5 pounds 7.1 pounds
$ 0.70
$ 0.82
a. Prices of chemical developed by USDV-States-ERA Assessment learn in
consultation with industry representatives, October, 1979.
b. Creosote-Coal lar is a 50% solution.
397
-------
TAbLi; 111-6 Price ot Preservative Chemicals and Solvents, and Oast of
formulations per Cubic Foot of Wood Ireated, 1979 (continued)
Product Penta
Itetention
(pounds per
cubic toot)
Unit pound
Weight 1 pound
per unit
ftrice $ 0.53
per unit
Price per
Ibund of
Preservative
Cost of
Preservative
per cubic foot
Pt-nta and P9, Type AC
0.3d 0.4d 0.5d
— — — SO ^)Q
_ S I 77d
_ — — _,— — 9 X • / / — — —
$0.530 0.707 0.884
0.6d
1.061
a. Prices of chemical developed by USDA-States-EPA Assessment lean in
consultation with industry representatives, October, 1979.
c. ifenta, Type A is a 7% penta solution.
d. Price is based on pounds of penta in formulation.
398
-------
TftBIE III-6 Price of Preservative Chemicals and Solvents, and Cost of
Formulations per Cubic Foot of Wood Treated, 1979 (continued)
Product
retention
(pounds per
cubic foot)
Uhit
Weight
per unit
Price
per unit
Pr i <••<» r»r-
Panta and
Go solvent
gallon
8.0 pounds
$3.30
Penta and P9, Type C
0.3d 0.4d 0.5d
d
pound of
preservative
Cbst of
preservative
per cubic foot
$1.00
$1.33
$1.66
a. Prices of chemical developed by USIA-States-EPA Assessment lean in
consultation with industry representatives, October, 1979.
d. Price is base on pounds of penta in formulation.
e. Penta and Cb solvent is a 22% penta solution.
f. Penta and P9, Type C is a 5 % penta solution.
399
-------
TftBDE 1II-6 Price of Preservative Chemicals3 and Solvents, and Gbst of
Formulations per Cubic Foot of Wood Treated, 1979 (continued)
Product
Retention 0.25 0.32 0.40 0.60 0.80 2.50
(pounds per
cubic foot)
Unit pound
Weight
per unit 1 pound
Price $1.00
per unit
Price per $1.00
pound of
preservative
Cost ot $0.25 $0.32 $0.40 $0.60 $0.80 $2.50
preservative
per cubic foot
a. Prices of chemical developed by USD\-States-EPA Assessment Team in
consultation with industry representatives, October, 1979.
400
-------
1ABLE I1I-6 Price of Preservative Chemicals and Solvents, and (tost of
formulations per Cubic Boot of Wood Treated, 1979 (continued)
Product
Retention
(pounds per
cubic foot)
IV-i i t-
Uk* ist Kt-
VT/eiynt
per unit
xrt ICc
per unit
Pr i r-fi r*>r-
Copper hlaph-
thenateg
0.451
$n on — — —
Cu Naph and P9, Type A
0.601 0.681 0.751 0.901 1.201
$A 17 ______
______ C10.A11 _______
pound of
preservative
Cost of
preservative
per cubic foot
$5.58 $7.45 $8.44 $9.31 $11.17 $14.89
a. Prices of chemical developed by USCft-States-fiPA Assessment Team in
consultation with industry representatives, October, 1979.
g. Gopper naphthenate is a 8% copper formulation.
h. Cu naph and P9, Type A is a 4% copper formulation.
i. Price is based on pounds of copper in formulations.
401
-------
TABLE II1-6 Price of Preservative Chemicals and Solvents, and Cost of
formulations per Cubic Foot of Kbod Treated, 1979 (continued)
Product
Retention
(pounds per
cubic foot)
IVl l 4-
Lfli.1.
Weight
per tint
£ll.Cc
per unit
ft- i r«o no*-
Cu Naph and P9 , Type Ch
0.451 0.601 0.681 0.751
$A 1Q ________
_ cno.?-?1
pound of
preservative
Cost of $5.75 $7.66 $8.69 $9.58
preservative
per cubic foot
a. Prices of chemical developed by USEA-States-EPA Assessment Kant in
consultation with industry representatives, October, 1979.
i. price is based on pounds of copper in formulation.
402
-------
TABLE III-6 Price of Preservative Chemicals3 and Solvents, and Cost of
Formulations per Cubic Foot of Wood Treated, 1979 (continued)
Product
Retention
(pounds per
cubic foot)
Unit
Weight
per unit
Price
per unit
Cu-8^
pound
1 pound
$18.00
Cu-8 and P9, Type C
0.121 0.161
gallon
7.25 pounds —
$3.32
Price per $23.751
pound of
preservative
Cost of $2.85 $3.79
preservative
per cubic foot
a. Prices of chemical developed by USEA-States-EPA Assessment lean in
consultation with industry representatives, October, 1979.
j. Price is based on a solubilized Cu-8 formulation.
k. Cu-8 and P9, Type C is a 2% Cu-8 formulation.
1. Price is based on pounds of Cu-8 in formulation.
403
-------
TABIE III-6 Price of Preservative Chemicals3 and Solvents, and Cbst of
Formulations per Cubic Foot of Wood Treated, 1979 (continued)
Product
Retention
(pounds per
cubic foot)
Unit
Height
per unit
Price
per unit
1BTO
pound
1 pound
$6.65
TBK) and P9 , Type C™
0.12n 0.16n
gallon
7.25 pounds
$1.73
Price per — $12.33n
pound of
preservative
Cost of $1.48 $1.98
preservative
per cubic foot
a. Prices of chemical developed by USEA-States-EPA Assessment team in
consultation with industry representatives, October, 1979.
m. 1BTO and P9, lype C is a 2% TBTO solution.
n. Price is based on pounds of OBTO in formulation.
404
-------
TftBIE III-6 Price of Preservative Chemicals and Solvents, and Cbst of
formulations per Cubic Fbot of Wood Urea ted, 1979 (continued)
Product
Retention
(pounds per
cubic foot)
Uiit
Weight
per unit
Price
per unit
Price per
pound of
preservative
Cost of
preservative
per cubic foot
CZC
0.45
pound
1 pound
$0.50
$0.225
ACC
0.25
0.50
pound
1 pound
0.62
$0.313 $0.625 $0.775
a. Prices of chemical developed by USEft-States-EPA Assessment learn in
consultation with industry representatives, October, 1979.
405
-------
TABLE I1I-7 Use Category, Recommended Rreservative, Retentions, and
Service Life
Use Category
1. Railroad ties
Crossties and
switchties
Hreservative
Creosote
Creosote/ Coal-Oar
Renta
Cu feph
Retention
(pcf)
8.00
8.00
°-40b
0.60
Service Life
(years)
35
35
25
25
2. Limber, timber and plywood
a. Industrial block
flooring
b. Cooling tower slats
c. Agricultural uses
and nurseries
d. landscape timbers
and decking
e. Containers (boxes,
crates, etc.)
f . Boat hulls and decks
g. Sea walls, wharves,
piers-salt water
h. Bridges, crossing
planks
Creosote
Creosote/ Coal-lar
ACCC
CCA/ACA
ACCC
Cu tfeph
CCA/ACA
ACCC
CCA/ACA
fenta
CZCC
ACCC
Cu-8
1BTO
Cu tfeph
CCA/ACA
lenta
CCA/ACA
Creosote
Creosote/ Coal-I&r
CCA/ACA
Creosote
Creosote/Cbal-Tar
Psnta
CCA/ACA
8.00
8.00
0.50
0.40
0.6^
0.75°
0.50
0.50
0.40
0.50
0.45
0.25
0.12
°'12b
0.45°
0.25
0.30
0.60
25.00
25.00
2.50
12.00
12.00
0.60
0.60
50+
50+
20
20
30
30
30
30
30
30
— —
—
—
—
—
— —
—
20
20
30
35
35
35
35
406
-------
TABIE-7 Use Category, Recommended Preservatives, Retentions and
Service life (cont'd)
Use Category
i. Mines ties and
timbers
j. House foundations,
swimming pools
k. Playground equip-
ment
1. Highway sound
barriers
m. Residential, ccm-
raercial-misc . ,
construction, lumber
and plywood, non-
structural (above
ground only)
n. Farm, industrial
misc., construction
lumber and plywood,
nonstrutural (above
ground only)
3. Piling
a . Marine
Preservative
ACCC
Creosote
Creosote/ Coal-Tar
Penta
CCA/ACA
Cu feph
CCA/ACA
ACCC
CCA/ACA
Penta
CCA/ACA
ACAC
CZC°
Cu-8
TBTO
Penta
CCA/ACA
ACCC
czcc
CCA/ACA
Cu-8
TBTO
Cu feph
Creosote
Creosote/Cbal Tar
Penta
Creosote
Creosote/ Coal-Tar
CCA/ACA
Retention
(pcf)
0.50
10.00
10.00
0.50
0.40^
0^75°
0.60
0.50
0.40
0.60
0.60
0.25
0.45
0.12
0.12
0.30
0.25
0.25
0.45
0.25
0.16
°'16b
0.60
8.00
8.00
0.40
20.00
20.00
2.50
Service Life
(years)
30
30
30
30
30
30
50+
30
30
35
35
50+
50+
50+
30
50+
50+
35
35
50
35
25
50
50
50
50
20
20
30
407
-------
TABLE III-7 Use Category, Recommended Preservatives, Retentions and
Service life (cont'd)
Use
4.
5.
6.
Category
b. Foundation, fresh
water, land
Posts
a. Fence- farm and
highway
b . Fence- res ident ial
and ccranercial
c. Highway-guard rail
and sign
Crossarms
Poles
a. Utility
b. Residential
Preservative
Creosote
Creosote/ Coal-lar
Penta
CCA/ACA
Cu Naph
ACCC
Creosote/ Coal-lar
Creosote
CCA/ACA
Cu Naph
Penta
ACCC
CCA/ACA
Penta
Creosote
Creosote/Coal-Tar
Penta
CCVACA
Cu Naph
ACCC
Penta
CCVACA
Cu Naph
Creosote
Creosote
Panta
CCA/ACA
Cu Ifeph
d
Penta
CCA/ACA
Retention
(pcf)
12.00
12.00
0.60
0.80
1.20
0.50
6.00
6.00
0.40b
0.45°
0.30
0.50
0.40
0.30
12.00
12.00
0.60
0.60K
0.90°
0.50
0.40
0.40
0.60
8.00
9.00
0.45
0.60,
0.60
0.80
0.80
Service Life
(years)
50+
50+
50+
50+
50+
35
25
25
35
35
25
35
35
25
30
30
30
30
30
40
40
40
40
40
35
35
50
35
50+
50+
408
-------
TABLE III-7a Use Category, Reocraraended Rreservatives, Retentions and
Service life (oont'd)
Use Category
c. Farm and industrial
d. Recreational and
commercial
ftreservative
Creosote
Creosote/ (bal-lar
Benta
CCA/ACA
Cu tbph
Penta
CCA/ACA
Retention
(pcf)
9.00
9.00
0.45
0.6CL
0.68
0.60
0.60
Service Life
( years)
35
35
35
50
35
35
50
a. Source: USDA-States-EBA, 1980.
b. Based on copper metal.
c. Due to limited uses of ACC and CZC; they are not being considered as the
most likely substitutes for cancellation. The service life of FCAP-
treated wood is about 5 to 10 years compared to about 30 to 50 years for
ACA- and CCA-treated wood depending on exposure to natural elements.
d. Exterior use only.
409
-------
c. Future Availability and Price of Creosote
In 1978, about 99% of the 124 million gallons of creosote, coal
tar and coal tar neutral oils were used for wood preservation in
the United States (USDA-States-EPA, 1980). An estimated 357.6
million gallons of coal tar were required to produce the creo-
sote used by the wood preservative industry in 1976 (Fuller
et al., 1977). In 1978, about 71 million tons of coal were
carbonized by coke producers and yielded an estimated 540.6
million gallons of coal tar. About 9.9 million gallons of the
estimated 540.6 million gallons of coal tar were burned as fuel
(Energy Information Administration, 1979). In addition, creo-
sote is produced as a by-product of the process for making
pitch. In 1976, 23.9 million gallons of creosote produced from
.pitch were burned as fuel.
Consequently, creosote availability for wooa utv.w.unent could be
increased by diverting the creosote currently burned as fuel.
Current coal tar or creosote supplies appear adequate to permit
creosote consumption to increase 20% to 30%, but the price of
creosote (approximately $0.80 to $0.88 per gallon) will be
directly related to the pricing of #6 fuel oil which has an
equivalent BTU value.
410
-------
d. Future Availability and Price of Inorganic Arsenicals
i. The Supply and Price of CCA and ACA Components
The raw ingredients required for the production of CCA or ACA
include arsenic acid, chromic acid and copper. The wood treat-
ment industry uses about 60% of all arsenic acid produced in the
United States for the production ot CCA or ACA (Toth, 1979).
The Pennwalt Corporation, which produces a large proportion of
the arsenic acid, has currently enlarged its production facili-
ties and could double or triple the present capacity by instal-
ling additional reaction vessels. Thus, there should be suffi-
cient arsenic acid to meet the future needs of the wood treat-
ment industry (Toth, 1979).
The December, 1979 price of arsenic acid sold in truckload lots
(Freight on Board price) was $4.95 per gallon (15.7 pounds), or
about twice the 1976 price. The increase in price of arsenic
acid during this period was due, in part, to the increased
demand for inorganic arsenical wood preservatives, which have
become more competitive with creosote and penta wood preser-
vatives .
About 20% of the estimated 50,000 tons of chromic acid produced
in the United States is used by the wood treatment industry and
the remaining 80% by the metal plating industry, the largest
single user of chromic acid. The market for chromic acid is
shifting to the wood treatment industry due to the recently
411
-------
increasing demand for the inorganic arsenical wood preserva-
tives/ the decline in demand for chromium for use in automo-
biles, and the recycling of chromium associated with pollution
cleanup efforts by the metal plating industry (Gilbert, 1979;
O'Brien, 1979). The Diamond Shamrock Corporation can increase
its chromic acid production capacity by 25% to 30% which will
increase the national production of chromic acid by 10% to 12%.
There appears to be no problem with the future availability of
copper, the third component of CCA and ACA formulations.
However, changes in copper prices would have the largest impact
on the price of ACA. For example, the price of ACA would in-
crease about $0.12 per pound if the price of copper increased
30%.
ii. The Supply and Price of CCA and ACA
The wood treatment industry has been expanding its production
capacity for CCA and ACA in response to the increased use of
inorganic arsenicals for wood treatment. Osmose Wood Preserving
Company of America, Inc., a major producer of CCA, could expand
its production capacity by 20% with a lag time of about six or
seven months (O'Brien, 1979).
The December, 1979 selling price of CCA and ACA treatment solu-
tions, as well as FCAP solutions, was about $1.00 per pound. Of
this figure, about $0.78 represents the cost of raw materials
and the other $0.22 reflects the cost of mixing, transportation,
412
-------
administration and other business costs. However, increases in
preservative prices for ACA and CCA may not result in large
increases in the cost of installed treated wood since preserva-
tive costs represent only a small fraction of the total
installation cost (EPA, 1980).
e. Future Availability and Price of Penta
The penta industry in the United States has a capacity of about
80 million pounds per year with current annual penta production
in the range of 40 and 50 million pounds (Johnson, 1979).
Ihere are no supply problems expected with the basic raw
materials used in the production of penta or of penta1s salt
formulations.
Increased fuel oil prices are especially critical for the
penta wood treatment industry because large amounts of petro-
leum are used as a wood treatment solvent. As an indication of
current trends, the price of penta increased about 13%, from
$0.46 to $0.52 per pound, as a result of fuel price changes
between August 1979 and January 1980.
3. Capital Requirements for Plant Conversion to Alternative
Treatments
When converting from creosote or penta to inorganic arsenicals,
additional capital investment for equipment changes is needed
because of differences in mixing and storage facilities. The
413
-------
necessary equipment changes can be made by (1) either retrofit-
ting existing treatment cylinders or by constructing new cylind-
ers and by (2) constructing the wood drying kilns which are
necessary for treatment with the inorganic arsenicals. A kiln
is necessary for inorganic arsenical treatments because the wood
must be dry before treatment can be carried out. If new cylind-
ers were constructed, the estimated minimum investment (assuming
that the required handling equipment for the treated wood al-
ready exists at the treatment plant) would range between
$275,000 and $325,000 per cylinder (McGill, 1979).
The conversion of existing cylinders for use with other wood
preservatives would be less expensive, require less time, and
cause less employment and community disruption than the construc-
tion of new treatment cylinders (McGill, 1979). The wood treat-
ment industry would most likely convert existing cylinders
rather than install new treatment cylinders. Conversion of a
creosote or a penta cylinder for use with inorganic arsenicals
would involve cleaning the cylinder, installing some piping and
constructing mixing and storage facilities for the inorganic
arsenical salts. A converted cylinder would cost between
$20,000 and $30,000 per cylinder and have an annual capacity of
treating about 600,000 cubic feet of wood, assuming two charges
per day (McGill, 1979).
The additional capital investment for kilns when converting from
creosote and/or penta to inorganic arsenical treatment ranges
between $100,000 and $200,000. The two major types of wood
414
-------
kilns used in the United States are conventional temperature
(71 to 82°C) and high temperature (110°C plus) kilns.
The capacity of these kilns is determined by the time required
for drying, which is dependent upon kiln size, drying tempera-
ture, and the type and volume of wood species being dried. For
example, southern pine lumber can be dried in a high temperature
kiln within 24 hours, whereas a hardwood species, such as oak,
must be dried at conventional temperatures and requires 25 to 30
days. Depending on type and size, each kiln would have an
annual capacity ranging from 204,400 cubic feet of wood (about
10,000 poles) to 1.4 million cubic feet of lumber, as shown in
Table 1II-8.
415
-------
IftBLE III-8 Capital Requirements for Vvbod Drying Kilns3
Item Cost
Kiln A - 26* x 52' Conventional Temperature Kiln
1. Equipment, building and control roan $ 80,500
(equipment alone = $35,000)
2. 100 horsepower boiler 16,000
3. Erection of building and equipment 19,000
installation
4. Site preparation and building slab 9,000
lOtal $124,500
Kiln B - 28' x 30* Conventional Temperature Kiln
1. Equipment, building and control room $ 70,000
2. 60 horsepower boiler 14,000
3. Erection of building and equipment 15,000
installation
4. Site preparation and building slab 9,000
OOtal $108,000
Kiln C - 32' x 54' High Temperature Kiln
1. Equipment, building and control room $108,000
2. 500 horsepower boiler 50,000
3. Erection of buildings and equipment 31,000
installation
4. Site preparation and building slab 12,000
lOtal $200,000
a. Source: James Kilmer, Irvington Mx>re Dry Kiln Cb., Jack-
sonville, Florida (site preparation and building slab cost
estimated by EBft).
416
-------
4. Methods and Assumptions
Scenarios are used throughout Part III to project the economic
impacts of cancelling one, two or all of the three major wood
preservatives. Since the three wood preservatives are, in most
cases, alternatives for each other, the cancellation of one or
two of the wood preservative agents is analyzed in terms of the
increased use of the available alternatives, wherever appropri-
ate, if all three major wood preservatives were cancelled,
economic impacts are analyzed for the most likely alternative
(e.g., concrete, steel, etc.) for that use. In the presentation
of the economic impacts attributable to the various cancellation
scenarios, the range of the cost impacts are presented in the
text and the impacts for each individual scenario are fully
detailed in the accompanying tables. The scenario numbers for
each use pattern are presented in the first reference table for
that use.
There are several factors used throughout Part III as a basis
for the derivation of the projected economic impact resulting
from the cancellation of one, two or all of the three major
wood perservatives. These factors, namely the future avail-
ability of the wood preservative agenta, preservative costs,
service life of the treated wood, capital investment for equip-
ment changes and installation costs, are used to obtain an
ad]usted cost of treated wood compared to the 1978 actual cost
of treated wood. Various assumptions have been made in
estimating the cost of these factors, including the assumption
417
-------
ot a 50% increase in preservative cost resulting from increased
demand for the remaining registered pesticide under certain
cancellation scenarios, the availability of the alternative wood
preservative agents, the growth in the use patterns and the
absence of technological innovations. The assumptions made in
the analyses regarding the impact of possible cancellation
actions are stated in detail in the Preliminary Benefit Analysis
(EPA, 1980); any specific assumptions made for a particular use
category are noted , as appropriate .
'ihe economic impact of cancellation for one or more of the three
wood preservatives would result in changes in the cost of
treated wood or the cost of maintenance of the treated wood
system. These costs are determined for each possible cancella-
tion scenario and compared to the 1978 cost. The difference
between the adjusted cost of treated wood and the 1978 cost of
treated wood is the economic impact on the price of the treated
wood product. The derivation of the adjusted cost of the
treated wood for each scenario requires several steps. The
first step involves determining any differences in current pre-
servative costs for the alternative preservative agents. The
next step in adjusting the determination is factoring in the
additional capital investment tor equipment changes required to
convert the plants to the use of alternative preservatives. In
order to determine the annual cost attributed to this capital
investment, the total capital cost (including 12% interest costs
to borrow the funds) is amortized over a period of ten years.
The final step is to incorporate a factor into the adjusted cost
418
-------
determination a term which reflects the increased demand for
preservatives (when there is increased demand for a product with
a fixed supply, the product price generally increases). The
Agency believes that an increase in preservative prices is
likely to occur if one or more of the wood perservative agents
were cancelled and has selected a 50% increase in preservative
prices as an estimate of the maximum plausible increase for this
effect. To summarize, the adjusted cost of treated wood on a
use-by-use basis for each cancellation scenario results from a
consideration of the change in preservative cost (based on
current prices) as modified by an estimated 50% price increase,
where appropriate, and the annual costs attributable to the
capital investment required to convert the plants to the alter-
native wood preservative treatment process.
For the end-use patterns of treated wood systems with extended
service lives (e.g., railroad ties and utility poles), cost
impacts were estimated in terms of the average annual cost for
maintaining the system, or "annualized cost." The concept of
"annualized cost" has particular relevance for achieving a
comparison of alternatives which impart differing service lives
to the treated wood products. The annualized cost represents
the average amount of money which must be invested each year to
maintain a system over a finite time period. To calculate the
annualized cost for a given scenario, the annual replacement and
maintenance costs are first estimated for each year for each
alternative scenario, assuming that the current system size
remains constant. In order to determine the amount which theo-
419
-------
retically would have to be invested in the first year to allow
the proceeds (principal and interest) to equal the total cost,
the total replacement and maintenance costs are then reduced to
a figure which represents the present value of these future
costs. The formula for determining "present value" is as
follows:
100 C x
Present value = ^
r)n
where C equals cost in year n
and r equals interest rate at 10%
The present value is then amortized over the finite time period
under consideration to determine the "annualized" cost for each
alternative scenario, using the following formula:
Present value x r (1 + r)n
Annualized cost =
(1 -H r)n - 1
It bhould be noted that the annualized cost is not equal to any
actual individual actual cost, but merely represents the
theoretical cost attributable to each year.
420
-------
5. Benefit Analysis by Use Category for Pressure Treatments
a. Railroad Ties
i. Usage and Identification of Use Category
In 1978, 106 million cubic feet of railroad crossties and
switchties were treated with wood preservatives. About 2.5
million cubic feet of these ties were treated with inorganic
arsenicals and were used primarily for landscaping purposes.
The treated ties used as landscape or garden timbers are con-
sidered under the use category of lumber, timber and plywood.
Of the remaining 103.5 million cubic feet of treated ties (about
31 million ties), approximately 99.6% were treated with creosote
(about 103.1 million cubic feet) and 0.4% with penta (about 0.5
million cubic feet) . The high usage of creosote-treated ties
reflects the higher strength and lower cost of the creosote-
treated ties compared with other preservative-treated wood
ties. These creosote- and penta-treated ties are annually used
by the United States railroads for new construction (5%) and
maintenance of existing systems (95%). The Association of
American Railroads expects annual tie replacement to remain at
current levels (Josephson, 1979) .
ii. Assumptions
The estimated average service life for both creosote-treated
ties and concrete ties, and for both penta-treated and copper
421
-------
naphthenate-treated ties is considered to be 35 years and
25 years, respectively (USDA-States-EPA, 1980). The economic
impacts projected in this section are based on the assumption
that there will be adequate production capacity to produce the
concrete or penta-treated tie replacement systems and that these
alternative materials would be available at current prices.
inorganic arsenical treatment is considered to be unacceptable
for railroad tie use because inorganic arsenical-treated ties
are brittle and do not hold fasteners well (USDA-States-EPA,
1980) .
iii. Impacts of Cancellation
Since inorganic arsenical-treated ties are not currently used in
the construction of railroad tracks, the impact of cancellation
ot inorganic arsenicals for this use category is not
considered.
Since a small percentage of railroad ties is treated with penta
(<0.4%), the use of creosote or some other alternative (e.g.,
copper naphthenate, concrete) could easily replace the use of
penta for railroad ties. Hence, the economic impact of the
cancellation of penta for this use is also considered to be very
small and was not sub]ected to further analysis.
The cancellation ot creosote would result in converting the en-
tire railroad tie system to another type of tie system since 99%
ot railroad ties are treated with creosote. The cost impact of
422
-------
cancelling creosote and converting the railroad tie system to
either penta, concrete or copper naphthenate was analyzed in
terms of the "annualized" or average annual cost; the definition
of this concept and the methodology used for the determination
is discussed in Section I1I.B.4, Methods and Assumptions. The
estimated annualized costs of creosote-treated, penta-treated,
copper naphthenate-treated and concrete tie systems for the
300,000 miles of United States railroads are shown in Table
III-9.
The initial, per mile, installed cost of penta-treated ties is
slightly lower than those treated with creosote and the first
year impact would consist of a lower cost for replacement ties.
The annuaiized cost of converting from a creosote-treated tie
system to a penta-treated tie system would be $1.027 billion
(Table III-9), an increase of $40.5 million annually over the
annualized cost of the current primarily creosote-treated tie
system. The difference between the annualized cost of the
creosote- and penta-treated tie systems is due primarily to the
reduced service life of penta-treated ties. This scenario would
require an additional 34.6 million pounds of penta and 61 mil-
lion gallons of oil, thereby doubling the current consumption of
penta. It has been estimated that a lead time of 3 years and an
investment of $14 million would be required to sufficiently
expand penta production to satisfy the demand tor treatment of
ties if creosote were cancelled (Fuller et al., 1977).
423
-------
TABLE III-9 Estimated Costs of Using Treated Wood Ties and Concrete Ties on
United States Railroads
Item
lies — each
Hardware — per tie
Freight — per tie
Installation — per tie
lotal installed cost
Nunber per mile
Service lifec
Bresent value ,
of future costs
Average annual cost
Creosote-Treated
Wood Ties
$14.50a
8.50
1.50
10.00
$34.50
3,033
35 years
$9,865e
986.5
Benta-Treated
Wood Ties
$13.80b
8.50
1.50
10.00
§33.80
3,033
25 years
ry-,1 l=v-c ______
§10,270f
1,027.0
a. From Josephson, 1979.
b. Based on current preservative prices and recorenended retention
(Table III-6).
c. From Table III-7.
d. Of maintaining system with creosote or converting to penta, cu naph, or
concrete; over 100 years at 10%.
e. Based on 26 million ties per year tor 100 years.
f. Based on 26 million ties per year for 25 years, 52 million ties per year
for 10 years, 26 million ties per year for 15 years, 52 million for 10
years, 26 million ties per year for 15 years, etc.
g. Based on 75.24 million ties per year for 10 years, 39.6 million per year
for 1 year, 0 ties for 24 years, 75.24 million per year for 10 years, etc.
h. Average annual cost
Present value x (1 + r) ,where r = 10%
(1 + r)n - 1 and n = 100
424
-------
T/BLE III-9 Estimated Cbsts of Using treated Wood Ties and Concrete lies on
United States Railroads (continued)
Item
Ties — each
Hardware — per tied
Freight — per tie
Installation — per tiea
lotal installed cost
Number per milea
Service life
Bresent value ,
of future costs
Average annual cost
Copper Naphthenate-
Treated Wood Ties
$36.85b
8.50
1.50
10.00
$56.85
3,033
25 years
— _____ Millinn
$17,258f
1,725.8
Concrete
Ties
$32.00a
8.50
4.00
16.00
$60.50
2,640
35 years
$32,8599
3,285.9
a. Fran Josephson, 1979.
b. Based on current preservative prices and recommended retention
(Table I11-6).
c. From Table I1I-7.
d. Of maintaining system with creosote or converting to penta, cu naph, or
concrete; over 100 years at 10%.
e. Based on 26 million ties per year tor 100 years.
f. Based on 26 million ties per year for 25 years, 52 million ties per year
for 10 years, 26 million ties per year for 15 years, 52 million tor 10
years, 26 million ties per year for 15 years, etc.
g. Based on 75.24 million ties per year for 10 years, 39.6 million per year
for 1 year, 0 ties for 24 years, 75.24 million per year for 10 years, etc.
h. Average annual cost =
Present value x (1 + r)n ,where r = 10%
(1 + r)n - 1 and n = 100
425
-------
The use of copper naphthenate as a replacement for creosote
would result in a substantially higher per mile initial in-
stalled cost. The first year impact would consist of a higher
cost for replacement ties or an impact of a $605.7 million. The
annualized cost of converting from creosote-treated tie system
and maintaining a copper naphthenate-treated tie system would be
$1.725 billion (Table III-9), or an average annual cost increase
of $739.3 million over the annualized cost of the current
creosote-treated tie system.
Concrete ties are considered technically feasible substitutes
for treated wood ties on United States railroads, but their
service life has yet to be determined (USDA-States-EPA, 1980).
However, treated wood ties and concrete ties cannot be inter-
*
mixed in a given system and the replacement of creosote-
treated ties with concrete ties would necessitate the
replacement of all the ties in a given section of the railroad
tie system. The replacement of the current 28,500 miles of
track maintained annually with concrete ties would require 2,640
ties per mile or 75,240,000 concrete ties annually. Assuming
that this number of concrete ties could be produced and
* Experience has shown that concrete ties do not preform
satisfactorily when randomly interspersed with treated wood tie
track. Concrete ties settle more slowly, resulting in an
unstable track structure. The greater weight of concrete ties
is also an impediment to their installation by conventional
maintenance methods and equipment. Most equipment would have to
be modified to handle heavier concrete ties (USDA-States-EPA,
1980) .
426
-------
installed annually, the first year cost for this conversion
would be $4.552 billion. This annual cost would continue for
10.5 years until the entire United States railroad system was
converted to concrete ties. The annualized cost of converting
and maintaining the railroad system with concrete ties would be
$3.3 billion, an average annual cost increase of $2.3 billion
over the annuaiized cost of the current primarily creosote tie
system.
iv. Limitations of the Analysis
The above projected enconomic impacts are based on the assump-
tions that the supply of alternative materials is adequate for
substitution at current prices. The adverse economic impacts of
cancelling creosote and/or penta on the wood producing and wood
treating industries have not been quantitatively assessed, but
is projected to be substantial if these preservatives were
cancelled for use on railroad ties.
b. Lumber, Timber and Plywood
i. Usage and Identification of Use Category
Treated lumber is now used in many places formerly served
almost exclusively by cedar and redwood. Shorter supplies and
higher prices of these wood species have resulted in greater
demand for treated wood in a variety of end-uses. Inorganic
arsenical-treated wood, which is suitable for almost all end-
427
-------
uses ot lumber, timber and plywood, has been the primary
replacement material for cedar and redwood.
Accurate data on the volumes of treated lumber, timber and
plywood used tor a specific end-use are lacking and are diffi-
cult to obtain due to the large number of end-uses and users
involved. The USDA-States-EPA Assessment Team (1980) divided
the end-uses of treated lumber, timber and plywood into five
general end-use categories as shown in Table 111-10. The
estimated volumes of treated lumber and timber produced in 1978
for each end-use category are shown in Table 111-11 (plywood
volumes are not included in this table). Approximately 80% of
the plywood is treated with inorganic arsenicals (excluding fire
retardant treatment). Treated plywood is used with treated
lumber and its use patterns are assumed to be similar to those
for treated lumber.
An estimated 105.3 million cubic feet of lumber and timber were
treated with the three wood preservatives with an estimated pre-
servative cost of $66.2 million in 1978. In addition, more than
2 million cubic feet of plywood and a substantial amount of sawn
material (e.g., crossing planks, mine timbers, highway posts and
agricultural wood products) were treated and fall into this use
category.
428
-------
TABLE 111-10 Use of treated lumber, limbers and Plywood0
Lumber, Timber and Plywood Treated with
End-use Area
Creosote
Penta
CCA
ACA
Residential and commercial
construction
Farm and industrial
construction
Recreation
Marine
Transportation
3
12
1
45
40
2 65
40
15
3
40
5
15
10
5
75
10
5
5
5
a. Estimates developed by the USDft-States-EPA Assesanent learn in
consultation with industry representatives, Boston, MA, August 17,
1979.
NOTE: Columns may not add to 100 due to rounding.
429
-------
TABLE III-ll VDlume of Treated Lumber and Timbers, by Bid-use, 1978a
Ehd-use Area Lumber and Timbers Treated with
All
Preservatives Creosote ffenta CCA ACA
1,000 cubic feet
All uses 105,305 10,780 21,209 63,317 10,000
Residential and com-
mercial construction 49,403 323 424 41,156 7,500
Barm and industrial
construction
Recreation
Marine
Transportation
13,994
13,287
12, 265
16,408
1,294
108
4,797
4,258
8,484
3,181
636
8,484
3,166
9,498
6,332
3,166
1,000
500
500
500
a. Based on Tables III-5 and 111-10.
430
-------
In 1978, creosote was used for treating about 10.78 million
cubic feet of lumber and timber, or about 10% o£ the treated
lumber and timber. industrial block flooring accounts for about
700 thousand cubic feet of creosote-treated lumber; the other
10.08 million cubic feet of creosote-treated wood in this use
category are used primarily as timbers for landscape, farm, mine
and marine construction purposes'.
More than 70% of the total treated lumber and timber, about
73.32 million cubic feet, was treated with inorganic arsenicals
and about 20%, or about 21.21 million cubic feet of lumber and
timber, was treated with penta in 1978 (USDA-States-EPA, 1980).
Table III-ll gives the volumes of treated lumber and timber, by
end-use, for 1978.
ii. Efficacy and Suitability of Alternatives
Based on efficacy and other performance characteristics, inor-
ganic arsenical-treated wood is suitable for most end-uses of
lumber, timber and plywood. Inorganic arsenical-treated wood is
clean, odorless, paintable, easy to handle, harmless to plants
and durable compared to either penta- or creosote-treated wood.
Inorganic arsenical wood preservatives are used for treating
wood for uses such as patios, decks, playground equipment,
cooling towers, greenhouses, horticultural nurseries and all
weather wood foundations (AWWF). These uses comprise the bulk
of the market for treated lumber, timber and plywood.
431
-------
Penta- and creosote-treated lumber, timber and plywood have
limited uses due to odor, objectionable vapors and oily, un-
paintable surfaces. Penta in heavy oil and creosote are not
suitable tor treatment of wood used in decks, patios, playground
equipment, stadium seats, agricultural wood uses, greenhouses,
horticultural nurseries, cooling towers and boat hulls. How-
ever, penta in light oil or volatile solvents, such as liquified
®
petroleum gas (Cellon process) or raethylene chloride (Dow
process), is suitable for applications where retention of
natural color and a paintable surface of the wood is necessary.
Although the wood treatment industry has a limited capacity for
utilizing volatile solvents, many plants can treat wood with
penta in light oil solvents.
Creosote-treated wood is used for the interior use of indust-
rial block flooring to protect the wood from mechanical as well
as physical deterioration. Creosote is the only wood preserva-
tive which improves the dimensional stability of the wood block
and reacts with the mastic to help bond the wood block to the
concrete subflooring. Neither penta nor inorganic arsenical-
treated wood is satisfactory for this use.
Creosote applications are also preferred where treated wood is
subjected to a high volume of heavy traffic (e.g., crossing
planks and decking for bridges, loading docks, wharves and
piers) because of the protection from weathering and abrasion
that it imparts to the wood. Penta in P9 oil also has these
protective qualities (except for marine applications) and can be
432
-------
substituted for creosote for these uses; inorganic arsenicais
are also an alternative for these use patterns except under
conditions of high mechanical stress (e.g., mechanical driving),
due to the brittleness imparted by the inorganic arsenical
treatment.
Creosote-treated wood is also preferred for industrial applica-
tions in high acid environments due to creosote's high resist-
ance to acids. Penta in heavy oil ranks second to creosote in
this regard, with inorganic arsenicais having no acid resist-
ance .
lii. Impacts of Cancellation
Due to the complexity of end-uses of treated lumber, timber and
plywood in treated wood products and the wide cost range of the
products (e.g., bridges, picnic tables, pole barns, etc.) in
this use category, the total economic impact of cancellation or
replacement cost of treated wood could not be estimated for the
various scenarios. Economic impacts were determined only on the
basis ot changes in pesticide cost for treating lumber and
timbers and the additional capital investment for equipment
changes needed when converting from one preservative treatment
system to another. These impacts do not reflect the total
cancellation of the three major wood preservatives for this use
category, but merely represents the types of cost attributable
to each cancellation scenario.
433
-------
Most creosote-treated wood in this use category could be re-
placed with either penta- or inorganic arsenical-treated wood
except for industrial block flooring for which there is no sub-
stitute preservative. Table 111-12 shows the economic impact on
the preservative cost of cancelling either creosote, penta or
both. If creosote were cancelled, penta or inorganic arsenicais
would be utilized in the treatment of timbers. The cancellation
of creosote could increase the volume of penta- or inorganic
arsenical-treated timbers to 25.4 million and 79.1 million cubic
feet, respectively. Some 700,000 cubic feet of wood products
presumably would not be treated. The preservative cost would
decline an estimated $11 million in this situation (Scenario
II). If penta were cancelled and the inorganic arsenicais and
creosote became the agents of choice for preservative treat-
ments, the preservative cost would decline to an estimated $5
million (Scenario III) from the 1978 actual situation. However,
if both penta and creosote were cancelled for treatment of
lumber and timber, about 100 million cubic feet of wood would be
treated with inorganic arsenicais and the remaining 700,000
cubic feet of industrial block flooring and 4.2 million cubic
feet of transportation lumber would not be treated. The preser-
vative cost for this situation would decline an estimated $20
million (Scenario IV) from the 1978 actual situation.
434
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TABLE 111-12 Alternative Scenarios for Estimated Consumption of Preservatives
and Cost of Preservatives for lumber and Timbers, 1978
Preservative Volume Quantity of dost of
(cubic feet) Preservatives Preservatives
(pounds) (dollars)
Scenario I: 1978 Actual Situation
Creosote
Penta
CCA/ACA
Obtal
Scenario II: Cancel
Creosote
Penta
CCA/ACA
tot treated '
10,780
21,209
73 ,318
105,307
Creosote and Shift
0
25,467
79,140
700
— i nnn ___ — _ — — —
184,821
9,883
34,985
229,689
to Penta and Arsenicals
0
12,439
36,440
lotal 105,307 48,879
Scenario III: Cancel Penta and Shift to Arsenaicls
Cresote
Penta
CCA/ACA
lOtal
Scenario IV: Cancel
Creosote
Penta
CCA/ACA
tot treated
lotal
10,780
0
94 ,527
105,307
Creosote and Penta
0
0
100,349
4 ,958
105,307
184,821
0
45 ,165
229,986
and Shift to Arsenicals
0
0
46,620
0
46,620
15,340
15,866
34 ,985
66,191
0
18, 576
36,440
55,016
15,340
0
45 ,165
60,505
0
0
46,620
46,620
a. Cost of preservatives based on prices given in lable III-6.
b. Transportation uses shifted to penta, all others to inorganic arsenicals
except industrial block flooring which could not be treated with penta
or inorganic arsenicals.
c. Assumes that 700,000 cubic feet of industrial block flooring and 4,258
cubic feet of transportation lumber that is currently treated with
creosote would not be treated with inorganic arsenicals.
435
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TABLE 111-13 Additional Capital Investment Required for
Alternative Ixrober Treatment Scenarios, 1978
Scenario Equipment Changes Required3 Capital Investment
Required
I
II
None
Convert 17 cylinders from
0
$2,425,000
creosote to penta or arseni-
cals at $25,000 each and build
10 kilns at $200,000 each
III Convert 36 cylinders from penta $5,100,000
to arsenicals at $25,000 each
and build 21 kilns at $200,000
each
IV Convert 45 cylinders from creo- $6,525,000
sote and penta to arsenicals at
$25,000 each and build 27 kilns
at $200,000 each
a. Assumes 600,000 cubic feet per cylinder per year and 1,000,000
cubic feet softwood per high temperature kiln per year.
436
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TABLE 111-14 Cost Effects of Required capital Investments for lunber
Scenario
I
II
III
IV
Cost Effect of
Additional
Investment
-
$ 533,500
1,122,000
1,435,500
Cost Effect of 50%
Increase in Preser-
vative Cbst
-
$27,508,000
22, 582, 500
23,310,000
Combined
Cost Effect
0
$28,041,500
23, 704, 500
24,745,500
a. First year effect are based on amortizing investments over 10
years and 12% interest.
437
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The additional capital investment for equipment changes required
by the cancellation of creosote, penta or both for treatment of
lumber, timber, and plywood are shown in Table IIi-13. The
estimated additional capital investment ranges for a 10 year
time period from $2.43 million (cancellation of creosote,
Scenario II) to $6.53 million (cancellation of creosote and
penta, Scenario IV). The first year cost effect of additional
capital investment ranges from $533,500 (Scenario II) to $1.44
million (Scenario IV) as shown in Table 111-14. Cost increases
ranging from $22.6 million (Scenario III) to $27.5 million
(Scenario II) would result from the 50% preservative price
increase attributable to increased demand. The combined first
year additional capital investment and a 50% price increase in
preservative cost would result in increased costs ranging from
$23.7 million (Scenario III) to $28 million (Scenario II). The
net impact for the cancellation scenario under consideration
ranges from approximately $5 million (Scenario IV) to
approximately $18 million (Scenario III).
The cancellation of either creosote or penta would result in no
expected major adverse economic impacts since inorganic arseni-
cals are the primary wood preservative used for lumber, timber
and plywood. However, cancelling inorganic arsenicals would
result in large adverse economic impacts and significant losses
because penta and creosote are not generally acceptable substi-
tutes and the costs of these alternatives are higher than those
of the inorganic arsenicals. However, the Agency has limited
438
-------
information on the economic impacts of cancellation for some end-
uses of inorganic arsenical-treated lumber used in home construc-
tion.
In a preliminary briefing given by the Mitre Corporation (EPA
contract 68-01-5964, 1980; a final report is expected in
January, 1981), the economic impact of cancelling inorganic
arsenical application to lumber for use in home construction was
analyzed for the end-uses of all weather wood foundation (AWWF),
plates and sills, and structural framing. There are about
10,000 homes built annually with AWWF (about 2,400 board feet of
ACA- and/or CCA-treated lumber per home), about 750,000 homes
with plates and sills (about 220 board feet of ACA- and CCA-
treated lumber per home) and about 8,000 homes with structural
framing (about 10,000 board feet of CCA-treated lumber per
home). Most of the AWWF homes are located in the northern
United States, homes which have treated plates and sills are
found in southern United States on slab foundations and the
structural framing homes are located in Hawaii only. About 1%
of the home foundations used treated wood or masonry and 99%
used concrete.
If AWWF were cancelled, the most likely substitutes would be con-
crete and masonry foundations. The AWWF costs are likely to be
lower than the concrete and masonry foundations in rural, iso-
lated areas in the northern United States, but the concrete and
masonry foundations are likely to be lower or equal in cost to
those for AWWF in urban areas. In 1969, the costs for an AWWF
439
-------
was $1,973 compared to $2/238 for a masonry foundation, or an
increase of about $265 per home (National Association of Home
Builders Foundation, Inc., 1969). However, in 1976 the cost of
an AWWF was $2,533 compared to $2,225 for poured concrete (a
decline of about $308 per home) and $2,428 for masonry, or a
decline of about $105 per home (National Ready Mixed Concrete
Association, 1976).
If inorganic arsenical were cancelled for use of treating wood
plates and sills, the most likely substitute would be steel
plates and sills. The use of steel plates and sills for home
construction instead of treated wood would result in no
additonal cost. If inorganic arsenical were cancelled for use
of treating wood structural framing, the most likely substitutes
would be concrete, masonary and steel framing. The cost of
these substitutes are similar to that of treated wood.
c. Pilings
i. Usage and Identification of Use Category
An estimated 12.09 million cubic feet of pilings (3.7% of all
treated wood) were treated with preservatives in 1978. The
distribution of pilings (including marine and foundation
pilings) according to the type of preservative used was:
creosote, 9,993,000 cubic feet (82.7%); penta, 1,154,000 cubic
feet (9.5%); and inorganic arsenicals, 943,000 cubic feet
440
-------
(7.8%). The estimated 1978 distribution of the 4,352,400 cubic
feet of marine pilings by preservative type was: creosote,
3,977,223 cubic feet; penta, zero cubic feet; and inorganic
arsenicals, 375,177 cubic feet. The estimated 1978 distribution
of the 7,737,600 cubic feet of foundation pilings by preserva-
tive type was: creosote, 6,015,777 cubic feet; penta, 1,154,000
cubic feet; and inorganic arsenicals, 567,823 cubic feet
(USDA-States-EPA, 1980).
While marine pilings accounted for an estimated 36% of treated
pilings in 1978, they consumed more than 49% of the total cost
of preservatives used to treat pilings. The total expenditure
for preservatives to treat pilings in 1978 was estimated as
$16.5 million. The service life (50 years) of the treated wood
for the three wood preservatives is considered to be the same .
ii. Impacts of Cancelling Wood Preservatives
The quantity of preservatives which would be used and the
changes in the estimated cost of treated pilings for different
*
cancellation scenarios are presented in Table 111-15 . Inor-
ganic arsenicals could serve as an alternative for creosote in
* The scenario numbers are not consistent from use category to
use category. For each use pattern, the scenarios are detailed
in the accompanying tables.
441
-------
marine and foundation uses even though the brittleness imparted
to pilings by inorganic arsenicals results in some breakage of
pilings during shipping and mechanical driving. The breakage of
the pilings treated with CCA is not expected to exceed 5%.
The cancellation of creosote would result in the substitution of
CCA-treated marine pilings (penta is not used or recommended for
marine pilings) and would require an additional 9,943,058 pounds
of CCA. This shift to inorganic arsenical treatment would not
increase the price of treated pilings since the price and ser-
vice life of the inorganic arsenical-treated pilings are essen-
tially the same for both types of marine piling. The price of
inorganic arsenical-treated foundation pilings is about $0.30
less per cubic foot than creosote pilings. Such a price differ-
ential would result in a treatment savings of about $1.8 million
annually if foundation pilings were treated with inorganic
arsenicals instead of creosote.
If creosote were cancelled for all piling uses, penta would most
likely be used to treat foundation pilings and inorganic arseni-
cals would replace creosote for the marine pilings use. Under
this scenario, an additional 3,609,466 pounds of penta (plus
152,213 barrels of #2 fuel oil for solvent) and 9,970,000 pounds
of inorganic arsenicals would be required. The preservative
costs would increase from $16.6 million (Scenario I) to $18.9
million (Scenario II), or about a 12% increase.
442
-------
TABIE 111-15 Pilings: Alternative Scenarios tor Estimated Consumption of
Preservatives, Cost of Preservatives, and Cost of Ireated Pilings
by lype of Preservative, 1978
Volume
(cubic feet)
Quantity of Cost of
Preservative Preservative
(Pounds) (Dollars)
Cost of
Pilings
(Dollars)
i nnn
Scenario I:
Creosote
Penta
CCA/ACA
lOtal
Scenario II:
Creosote
Penta
CCA/ACA
Obtal
Scenario III
Creosote
Panta
CCA/ACA
Total
Scenario IV:
Creosote
Penta
CCA/ACA
Octal
Scenario V:
Creosote
Penta
CCA/ACA
lOtal
JL.f \J\J\J
1978 Actual Situation
9,993
1,154
943
12,090
Cancel Creosote and
Arsenicals
0
7,170
4,920
151,733
692
1,392
153,818
Shift Foundation
0
4,302
11 ,335
13,959
1,224
1,392
16,575
to Penta and
0
7,607
11 ,335
12,090 15,637 18,942
: Cancel Creosote and Shift to Arsenicals
0
1,154
10,936
12,090
Cancel Creosote and
0
0
12 ,090
0
692
17,465
18,157
Penta and Shift
0
0
17 ,071
12,090 17,071
Cancel Penta and Shift to Creosote
11,147
0
943
12,090
165,581
0
1,342
166,923
0
1,224
17,465
18,689
to Arsenicals
0
0
17,071
17,071
15,233
0
1,392
16,625
66,130
7,086
6,070
79,286
Marine to
0
44,022
35,263
79,285
0
7,085
70 ,405
77,480
0
0
77 ,134
77,134
73,215
0
6,098
79,313
444
-------
TflBLE Hl-15 Pilings: Alternative Scenarios for Estimated Consumption of
Preservatives, Cost of Preservatives, and Cost of Treated Pilings
by Type of Preservative, 1978 (oont'd)
Vblune
(cubic feet)
Quantity of
Preservative
(founds)
1
Cost of
Preservative
(Dollars)
i . nnn
Cost of
Pilings3
(Dollars)
Scenario VI: Cancel Penta and Shift to Arsenicals
Creosote
Panta
CCA/ACA
Total
9,993
0
2,097
12,090
151,734
0
2,315
154,049
13,959
0
2,315
16,274
66,129
0
12,809
78,938
Marine pilings are $7.43 per cubic foot (Conpton, 1979) and foundation
pilings are $6.14 per cubic foot (Engineering News Ftecord, 1979).
445
-------
On the other hand, if penta were cancelled and inorganic
arsenical treatment substituted for all penta treatment, an
additional 923,000 pounds of inorganic arsenicals would be
required to treat these foundation pilings under this scenario.
The preservative cost would decline from $16.6 (Scenario I)
million to $16.3 million (Scenario VI), or about <1% decline
for this scenario.
The additional capital investment required for the various
scenarios are presented in Table 111-16. The necessary
additional capital investment would range from $50,000
(Scenario V) to $7.45 million (Scenario IV).
The cost effect of the estimated 50% increase in preservative
prices resulting from the increased demand for preservatives
brought about by the various cancellation scenarios is presented
in Table 111-17; this cost ranges from $8.1 million (Scenario
VI) to $9.47 million (Scenario II). The adjusted cost of
treated pilings for these scenarios, which includes the addition-
al capital investment and an estimated 50% increase in preserva-
tive cost varies from $87.3 million (Scenario IV) to $89.4
million (Scenario II) compared to $79.29 million (Scenario I).
This reflects a 10% to 13% increase over the 1978 cost.
446
-------
TABLE 111-16 Additional Capital Investment Required for
Alternative Pilings Ireatment Scenarios, 1978
ra
Scenario Equipment Changes Required Capital Investment
Required
I None 0
II Convert 10 cylinders fron $2,900,000
creosote bo penta at $25,000
each and convert 6 cylinders to
arsenicals at $25,000 and 20 kilns
at $125,000 each
III Convert 16 cylinders from creosote $6,650,000
to arsenicals at $25,000 each
and 50 kilns at $125,000 each
IV Convert 18 cylinders from creosote $7,450,000
and penta to arsenicals at $25,000
each and 56 kilns at $125,000 each
V Convert 2 cylinders from penta to $50,000
creosote at $25,000 each
VI Convert 2 cylinders from penta to $300,000
arsenicals at $25,000 each and 2
kilns at $125,000 each
a. Assumes 200,000 cubic feet per kiln per year (5 days per charge)
447
-------
TABLE IH-17 Pilings: tost Effects of Required Capital Investment and a
50% Increase in Rreservative Rrices, 1978
tost effect of
additional investmentd
tost effect of 50%
50% increase in
preservative prices
Combined cost effect
Adjusted cost of
I 11
0 $ 638,000
0 9,471,195
0 10,109,195
$79,285,132 89,394,327
111
1,463,000
9,344,797
10,807,797
88,288,197
treated piling
after capital
and price
Ratio ot treated 1.000 1.128 1.114
pilings under
alternative scenario
to actual 1978 cost
a. First year cost: amortized over 10 years at 12%.
448
-------
TABLE 111-17 Pilings: Cost Effects of Itequired Capital Investment and a
50% Increase in Preservative Prices, 1978 (continued)
Scenarios
IV V VI
Cost effect of $ 1,639,000 11,000 66,000
additional investment
(tost effect of 50% 8,535,540 8,312,000 8,137,000
50% increase in
preservative prices
Combined O>st effect 10,174,540 8,323,000 8,313,000
Adjusted cost of 87,308,740 87,608,000 88,252,000
treated pilings
after capital
and price
Ratio of treated 1.101 1.105 1.113
pilings under
alternative scenario
to actual 1978 cost
a. First year cost: amortized over 10 years at 12%.
449
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iii. Alternatives to Treated Wood Pilings: Concrete and Steel
Both concrete and steel can provide technically acceptable
alternative materials for pilings in foundation uses. However,
steel would be subject to corrosion in highly acidic soils or in
marine environments (Fuller et al., 1977). The materials
cost of both concrete and steel piles, as well as installation
costs, are higher than treated wood piles on a one for one basis
(iamith, 1980; Andrews, 1980). However, the total cost of
pilings at a given site may not increase significantly when
concrete or steel pilings are substituted for treated wood
pilings, if opportunities exist for assigning heavier loads to
individual piles. in the case of residential and small commer-
cial buildings where loads are relatively low, concrete or steel
will usually be much higher in cost than treated wood piles.
Table 111-18 provides a comparison of the average annual costs
of installed treated wood, concrete and steel pilings. The
total installed average annual cost of pilings is estimated to
be $258.1 million for concrete piles and $322.7 million for
steel piles compared to $193.6 million for treated wood piles.
However, concrete or steel piles may be assigned heavier loads
than those previously assigned to treated wood piles. Assuming
that one concrete or steel pile replaces 1.5 treated piles, the
average annual installed cost of concrete and steel piling would
be $172.1 million tor concrete (about an 11% decline) and $215.1
million for steel (about an 11% increase) compared to the $193.6
million for treated wood pilings.
450
-------
TABLE 111-18 Estimated Cost of Using Ireated Wood Piles, Concrete Piles or
Steel Piles in the Lhited States, 1978
Ireated
Wood
Installed cost per $ 450
pile (50 foot pile)
Service life (years) 50
Number of 50- foot 430,249b
pile equivalents
installed per year
Current total cost
per year (million dollars) 193.6
Present value of 1,935.98
future c<" st stream d
(millions of dollars)
Annualized cost 193.6
(millions ot dollars)
Concrete
A B
$ 600 $ 600
50 50
430,249b 286,832°
258.1 172.1
2,581.31 1,170.87
258.1 172.1
a. Based on estimated installed costs for 50 foot pilings installed on a site
with 400 piles required (Smith, 1980).
b. Assunes 28 cubic feet per average 50 foot pile and 12,090,000 cubic feet
of treated wood piles in the United States.
c. Assumes one concrete or steel pile will replace 1.5 treated wood piles.
d. Present value = lotal cost stream for 100 years discounted at 10%.
e. Average annual cost
Present value x (1 + r) ,where r = 10%
(1 + r)n - 1 and n = 100
451
-------
TABLE 111-18 Estimated Cost of Using Treated Wood Piles, Concrete Piles or
Steel Piles in the liiited States, 1978 (continued)
Treated
Wood
Installed cost per $ 450
pile (50 foot pile)
Service lite (years) 50
h
Number of 50- foot 430,249
pile equivalents
installed per year
Current total cost
per year (million dollars) 193.6
Present value of 1,935.98
uture cost stream ,
(millions of dollars)
Annualized cost 193.6
(millions of dollars)
Steel
A B
$ 750 $ 750
50 50
b c
430,249 286,832
322.7 215.1
3,226.63 2,150.85
322.7 215.1
a. Based on estimated installed costs for 50 foot pilings installed on a site
with 400 piles required (Smith, 1980).
b. Assunes 28 cubic feet per average 50 foot pile and 12,090,000 cubic feet
of treated wood piles in the United States.
c. Assumes one concrete or steel pile will replace 1.5 treated wood piles.
d. Present value = Total cost stream for 100 years discounted at 10%.
e. Average annual cost =
Present value x (1 + r)n ,where r = 10%
(1 + r)n - 1 and n = 100
453
-------
d. Posts.
i. Usage and Identification of Use Category
In 1978, an estimated 20 million cubic feet of posts were
treated with preservatives (USDA-States-EPA, 1980). Treated
wood posts include such uses as fences for farms, yards, patios,
highway guardrails and highway signposts; fa'rm fence posts
account for the largest proportion of treated posts use. The
average service life of untreated fence post is only 3.3 years
compared with 38 years for creosote- or inorganic arsenical-
treated posts (ACA) and 33 years for posts treated with penta
(josephson, 1979).
The distribution of fence posts by type of treatment in 1978 was
creosote, 4,584,000 cubic feet (22.9%); penta, 10,983,000 cubic
feet (54.8%); and inorganic arsenicals, 4,461,000 cubic feet
(22.3%).
The quantity of preservatives used in 1978 to treat fence posts
was 27.5 million pounds of creosote, 3.3 million pounds of
penta, and 1.78 million pounds of inorganic arsenicals with a
total preservative cost of §10.1 million. The total cost of
treated wood posts in 1978 was $66.1 million.
454
-------
ii. Impacts of Cancelling Wood Preservatives
Ihe economic impacts associated with cancelling one or more of
the three wood preservatives for treating wood posts are shown
in Table 111-19 (Scenarios 1 through VIII). The difference in
chemical costs for the various scenarios would range from a
decrease of §2.1 million (Scenario VIII) to an increase of
§700,000 (Scenario VI) from the 1978 cost of §10.1 million
(Scenario I). The estimated cost of treated posts for the scena-
rios under consideration varies from §62.5 million (Scenario
VIII) to §67.6 million (Scenario VI) compared to §66.1 million
(Scenario I) for the 1978 cost of treated posts. Additional
capital investment for equipment changes would vary from
§200,000 (Scenario II) to §10.38 million (Scenario VIII), as
shown in Table 111-20. The potential impacts of additional
capital investment and a 50% increase in preservative prices due
to increased demand for the preservatives remaining on the
market are shown in Table 111-21. The addition of capital in-
vestment costs and the 50% increase in preservative costs (Table
111-21) to the estimated cost of treated posts (Table 111-20),
gives the adjusted cost of treated posts for each scenario. The
adjusted cost of treated posts for these scenarios would range
from §66.6 million (Scenario III) to §72.0 million (Scenario IV)
compared to the 1978 cost for treated wood posts of §66.9
million (Scenario I).
455
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TABLE 111-19
Basts: Alternative Scenarios for Estimated Consumption of
Preservatives, Cost of Preservatives, and Cost of Treated JEbsts
by Type of Perservative, 1978
Volume Quantity of Oost of
(cubic feet) Preservative Preservative3
(Pounds) (Dollars)
Scenario I:
Creosote
Penta
CCA/ACA
Total
Scenario II:
Creosote
Penta
CCA/ACA
Total
Scenario III
Creosote
Penta
CCA/ACA
lotai
Scenario IV:
Creosote
Penta
CCA/ACA
Total
Scenario V:
Creosote
Penta
CCA/ACA
lotal
Scenario VI:
Creosote
Penta
CCA/ACA
lotal
1978 Actual Situation
4,584
10,983
4,461
_ _ _ _ i nnn .
27,504
3,295
1,784
20,028 32,583
Cancel Creosote and Shift to Penta
0
15,567
4,461
0
4,670
1,784
2,530
5,821
1,784
10,135
0
8,251
1,784
20,028 6,454 10,035
: Cancel Creosote and Shift to Arsenicals
0
10,983
9,045
0
3,295
3,618
20,028 6,913
Cancel Penta and Shift to Creosote
15,567
0
4,461
20,028
Cancel Penta and Shitt
4,584
0
15,444
20,028
Cancel Arsenicals and
9,045
10,983
0
20,028
93,402
0
1,784
95,186
to Arsenicals
27,504
0
6,178
0
5,821
3,618
9,439
8,593
0
1,784
10,377
2,530
0
6,178
33,682 8,708
Shift to Creosote
54,207
3,295
0
57,565
4,993
5,821
0
10,814
Cost .
of Posts
(Dollars)
15,815
36,354
13,918
66,087
0
51,527
13,918
65,445
0
36,354
28 ,220
64,574
53,706
. 0
13 ,918
67,624
15,815
0
48,185
64,000
31,205
36,354
0
67,559
456
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TABLE 111-19 Basts: Alternative Scenarios for Estimated Consumption of
Preservatives, Cost of Preservatives, and Cost of Treated Posts
by Type of Preservative, 1978 (cont'd)
\tolune Quantity of Cost of Cost ,
(cubic feet) Preservative Preservative of Posts
(Pounds) (Dollars) (Dollars)
Scenario VII:
Creosote
Penta
CCA/ACA
Total
Scenario VIII:
Creosote
Penta
CCA/ACA
Total
Cancel Arsenicals and
4,584
15,444
0
— — i
Shift to
27,504
4,633
0
20,028 32,137
Cancel Creosote and Penta and
0
0
20 ,028
20,028
0
0
8,011
8,011
ftflo — — — — — — —
Penta
2,530
8,185
0
10,715
Shift to Arsenicals
0
0
8,011
8,011
15,815
51,120
0
66,935
0
0
62,487
62,487
a. Based on retention per cubic foot and cost given in Table III-6 and
Table III-7.
b. Cost per cubic foot f.o.b. at plant: creosote $3.45, penta $3.31, and
CCA $3.12 (Stevens, 1979).
457
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TABLE 111-20 Additional Capital Investment Required for
Alternative lost treatment Scenarios, 1978
Scenario Equipment Changes Required6
Capital Investment
Required
I
II
III
IV
VI
VII
VIII
None
Convert 8 cylinders from
creosote to penta at $25,000
each
Convert 8 cylinders frcra creosote
to arsenicals at $25,000 each
and 23 kilns at $125,000 each
each
Convert 18 cylinders from penta
to creosote at $25,000 each
Convert 18 cylinders from penta
to arsenicals at $25,000 each
and build 55 kilns at $125,000
each
Convert 8 cylinders from
arsenicals to creosote at
$200,000 each
Convert 8 cylinders from
arsenicals to penta at $200,000
each
Convert 25 cylinders from penta
and creosote to arsenicals at
$25,000 each and build 78 kilns
at $125,000 each
$200,000
$3,075,000
$450,000
$7,325,000
$1,600,000
$1,600,000
$10,375,000
a. Assunes 200,000 cubic feet per kiln per year.
458
-------
TABLE 111-21 Basts Cost Effects of Required Capital Investment and a
50% Increase in Rreservative It ices, 1978
I
Cost effect of 0
additional
investment
Gost effect of 0
50% increase in
preservative prices
Combined effect 0
Adjusted cost of $66,935,000
II III
44,000
4,125,255
4,169,225
69,614,255
264, 000
1,809,000
2,073,000
66,647,000
IV
99,000
4,296,000
4,395,000
72,019,000
treated posts
after captial and
price increase
Ratio of cost of 1.000 1.040 0.996 1.076
treated posts
under alternative
scenario to actual
1978 cost
a. First year cost: amortized over 10 years at 12%.
460
-------
TABLE 111-21 Eosts dost Effects of Required Capital Investment and a
50% Increase in Preservative Prices, 1978 (continued)
Scenarios
V VI VII VIII
Oast effect of 594,000 352,000 352,000 825,000
additional
investment
(tost effect of 3,088,800 2,496,000 4,092,660 4,005,600
50% increase in
preservative prices
Qxnbined effect 3,682,800 3,376,000 4,444,660 4,830,600
Adjusted cost of $67,682,800 70,935,000 71,379,660 67,317,600
treated posts
after captial and
price increase
Ratio of cost of 1.011 1.060 1.066 1.006
treated posts
under alternative
scenario to actual
1978 cost
a. First year cost: amortized over 10 years at 12%.
461
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lii. Alternative Fence Post Materials
If all three major wood preservatives were cancelled, steel
or concrete posts would be the most likely alternative
materials for fence post use. T-type steel posts, which serve
as substitutes for wood posts in farm fences, are priced
competitively with treated posts. Thus, substitution of steel
posts in many farm applications would not necessarily lead to
much higher fencing costs. Concrete posts would be more
expensive than steel and probably would not be substituted in
most farm situations.
e. Crossarms
i. Usage and Identification of Use Category
Crossarms are the cross members of assembled utility poles.
An estimated 1,685,000 cubic feet of crossarms (0.5% of total
treated wood) were treated with wood preservatives in 1978.
The distribution of crossarms by preservative treatments was:
creosote, 41,000 cubic feet (2.5%); penta, 1,615,000 cubic feet
(95.8%); and inorganic arsenicals, 29,000 cubic feet (1.7%).
The consumption of preservatives for treating crossarms in 1978
was 389,000 pounds of creosote, 646,000 pounds of penta plus
1,411,267 gallons of petroleum solvent (27,173 barrels of oil),
and 11,600 pounds of inorganic arsenicals with a total estimated
preservative cost of $1.18 million. The 1978 cost of the
462
-------
treated crossarms was estimated as $14.86 million. The service
lives ot crossarms treated with the three major wood preserva-
tives are considered to be equivalent (40 years).
ii. Impacts of Cancellation
Since penta accounts for nearly 96% of treated crossarms, its
cancellation would result in a major economic impact (e.g., for
converting to other preservative treatments) on the crossarm
treatment industry. Table 111-22 shows the changes in preserva-
tive costs for various cancellation scenarios and can be used to
compare the changes in the cost of treated crossarms for each
scenario. A shift from penta to creosote (Scenario II) would
result in a $47,000 annual increase in chemical costs and an
increase of $614,000 in the cost of treated crossarms. If penta
were cancelled and inorganic arsenicals were substituted for
crossarms treatment (Scenario III), the preservative cost would
decline about $496,000 annually resulting in a $791,000 annual
decline in the estimated cost of treated crossarms compared to
the 1978 cost. Although less than 2% of crossarms were treated
with inorganic arsenicals in 1978, inorganic arsenical-treated
crossarms are gaining acceptance among some utility companies
such as Virginia Electric Power Company (VEPCO) in Virginia
(Farmer, 1979) .
463
-------
TABLE 111-22 Crossarms: Alternative Scenarios for Estimated Consumption ot
Preservatives, Cbst of Preservatives, and Cost of Treated
Crossarms by lype of Preservative, 1978
\tolune
(cubic feet)
Quantity of
Preservative
(Pounds)
Cost of
Preservative3
(Dollars)
Cost of b
Crossarms
(Dollars)
i nnn
Scenario I:
Creosote
Penta
CCA/ACA
total
Scenario II:
Creosote
Panta
CCA/ACA
lOtal
Scenario ill
Creosote
Rmta
CCA/ACA
total
Scenario IV:
Creosote
lenta
CCA/ACA
total
Scenario V:
Creosote
Panta
CCA/ACA
total
Scenario VI:
Creosote
fcnta
CCA/ACA
total
1978 Actual Situation
41
1,615
29
398
646
12
1,685 1,056
Cancel Penta and Shift to Creosote
1,656
0
29
13,248
0
12
30
1,142
12
1,184
1,219
0
12
1,685 13,260 1,231
: Cancel Penta and Shift to Arsenicals
41
0
1,644
1,685
Cancel Creosote and
0
1,685
0
328
0
658
986
Arsenicals and
0
674
0
1,685 674
Cancel Creosote and Penta and Shift
0
0
1,685
1,685
Cancel Creosote and
0
1,656
29
1,685
0
0
674
674
Shift to Penta
0
662
12
674
30
0
658
688
Shift to Penta
0
1,191
0
1,191
to Arsenicals
0
0
674
674
0
1,171
12
1,183
377
14,244
242
14,863
15,235
0
242
15,477
377
0
13,695
14,072
0
14,682
0
14,682
0
0
14 ,036
14,036
0
14,606
242
14,848
-------
TABLE 111-22 Crossanns: Alternative Scenarios for Estimated Cbnsunption of
Preservatives, Obst of Preservatives, and Obst of Treated
Crossarms by Type of Preservative, 1978 (oont'd)
Scenario VII:
Creosote
Panta
CCA/ACA
Octal
Vblune
(cubic feet)
Cancel Creosote
0
1,615
70
1,685
Quantity of Cost of
Preservative Preservative
(Pounds) (Dollars)
_______ i nnn _______
and Shift to Arsenicals
0 0
646 1,142
28 49
674 1,191
Cost of .
Crossarms
(Dollars)
0
14, 244
583
14,827
a. Itetention per cubic foot: creosote 8 pounds, penta 0.4 pounds, and
arsenicals 0.4 pounds.
b. Cost per cubic foot f .o.b. at plant: creosote $9.20, penta $8.82, and
CCA $8.33 (Colemen, 1979).
465
-------
TABLE 111-23 Crossarms: Cost Effects of Required Capital Investment and a
50% Increase in Preservative Prices, 1978
Gost effect of
additional investment
Cost effect of 50%
I II
0 $ 16,500b
0 609,500
III
236,500°
328,800
50% increase in
preservative prices
Combined cost effect 0 626,000 565,300
Adjusted cost of $14,863,070 16,103,000 14,637,020
treated crossarms
after increase
Ratfo of treated 1.000 1.083 0.985
crossarms under
alternative scenario
to actual 1978 cost
a. First year cost: amortized over 10 years at 12%.
b. Convert 3 cylinders to creosote at §25/000 each.
c. Convert 3 cylinders to arsenicals and construct 8 drying kilns at $125,000
each.
466
-------
The first year cost effect of additional capital investment
required for plant conversion resulting from the various
cancellation scenarios is given in Table 111-23 and ranges for
the penta cancellation scenarios from $16,500 (Scenario II) to
$236,500 (Scenario III). If preservative prices were to in-
crease 50% as a result of increased demand, the cost effect
would range from $328,800 (Scenario III) to $610,000 (Scenario
II). For each scenario, the combination of the additional
capital investment costs and the 50% increase in preservative
costs (Table 111-23) with the estimated cost of treated cross-
arms (Table 111-22) gives the adjusted cost of treated cross-
arms. The adjusted cost ranges from an increase of $1.24
million (Scenario II) to a decrease of $226,000 (Scenario III).
iii. Non-wood Alternatives
Steel crossarms are used by some utility companies (e.g.,
VEPCO). A distribution steel crossarm that is competi-
tive with treated crossarms has been used by VEPCO, but has
limited usage since steel crossarms are not a complete
substitute for treated wood crossarms (Farmer, 1979).
f. Poles
i. Usage and Identification of Use Category
Treated poles are the principal structural support elements in
the 4.52 million miles of the electric distribution system and
467
-------
the estimated additional 640,000 miles of electrical transmis-
sion lines in the United States. Treated poles are also used to
support telephone lines, as light standards, and for construc-
tion uses in residential and other buildings. The USDA-States-
EPA Assessment Team (1980) estimated that, in 1978, 64.2 million
cubic feet of wood (2.86 million treated poles) were treated and
represented about 19% of all wood treated with preservatives.
The volume distribution of preservatives for treated poles in
1978 was: penta, 65.3%; creosote, 28.4%; and inorganic arseni-
cals, 6.3% of the total treated pole volume. The users of the
125,539,000 treated utility poles currently in service in the
United States are electric utilities (94,139,000 poles), who
purchase about 92.8% of total volume of treated poles produced
annually and telephone, railroads, industry and others such as
farm, commercial and residential (31,400,000 utility poles), who
purchase the remaining 7.2% of treated poles produced annually.
In addition to the treated poles which carry utility lines, an
estimated 2.06 million treated poles are used annually in farm,
commercial, and residential construction. Treated poles used
for construction purposes (e.g., pole barns) are considered to
be similar in use pattern to treated timbers and are included in
the use category of lumber, timber and plywood.
Virtually all of the utility poles are produced in two regions
of the United States that are contiguous with the natural ranges
of the Southern pine and Douglas fir, the tree species which
account for more than 85% of total pole production. Seventy-
468
-------
five percent of annual pole production comes from the Southern
Pine region, which extends from Maryland to East Texas. The
Douglas fir region, which is centered in California, Oregon and
Washington, produces about 10% and is responsible for most of
the treated wood poles used in the United States that are longer
than 70 feet.
ii. Impacts of Cancelling Vvood Preservatives in Terms of
Annual Costs
There are no viable chemical alternatives for the three major
wood preservative agents for pole treatment, with the possible
exception of copper naphthenate for certain limited uses.
However, copper naphthenate is unsuitable for large-scale use in
poles because it imparts a green, greasy surface to the poles,
is unstable in the presence of moisture and causes corrosion of
metals. The service life of inorganic arsenical-treated poles
is assumed to be 50 years in this analysis; tor penta- and
creosote-treated poles, a service life of 35 years is assumed.
However, the expected service life of treated poles varies in
practice with the quality of preservative treatment and with the
severity of the environmental conditions at the point of end-
use. A recent survey of investor-owned electric companies
revealed that all companies recorded an average service lite of
greater than 20 years for the treated poles in their systems
(Electric World, 1979).
469
-------
Table 111-24 shows the changes in preservative costs and in the
estimated cost of treated poles for various cancellation scena-
rios. The change in preservative costs varies from a decrease
of $12.75 million (Scenario IV) where penta and creosote are
cancelled to an increase of $963,000 (Scenario X) for the cancel-
lation of penta and shift to creosote. The estimated treated
pole costs would range from a decrease of $27.7 million
(Scenario IV) to an increase of $10.8 million (Scenario VIII)
under the scenarios considered in this analysis. Table 111-25
presents the cost of the equipment changes required for conver-
sion to the various alternatives. The additional capital
investment for equipment changes required for the changes in
preservative treatments ranges from $750,000 (Scenario II) to
$39.9 millions (Scenario IV). The largest capital investments
are required in those situations where the use of inorganic
arsenicals would be increased.
The cost impact of additional capital investments and increased
demand for preservatives is presented in Table 111-26 for the
various cancellation scenarios. The annual cost effect of a
50% cost increase in preservative prices varies from zero
(Scenarios VI & VII) to $25.8 million (Scenario IX). The
annual combined capital investment and estimated increase in
preservative price ranges from $308,000 (Scenarios VI & VII) to
$28 million (Scenario IV). The resultant adjusted cost of the
treated poles for these scenarios ranges from $276.7 (Scenarios
VI & VII) to $310.2 million (Scenario VIII) compared to the 1978
cost of treated poles of $274.8 million (Scenario 1). Thus, the
470
-------
largest impact on adjusted treated pole cost would be an in-
crease of about 13% ($36.5 million) for the cancellation of
inorganic arsenicals and penta. however, the difference in
installed per pole cost is likely to be relatively small since
the preservative cost represents a small proportion of total
installed pole cost.
iii. Alternatives Other than Wood
Although concrete, steel, aluminum and fiberglass poles have
been suggested as alternatives for treated wood poles, price and
technical considerations indicate that concrete and steel are
the most likely alternatives for treated poles in the near
future. Underground installation provides an additional alter-
native for distribution and transmission lines in urban areas or
in new subdivisions as required by local regulations (e.g.,
municipal ordinance). Over 40% of new distribution lines were
installed underground in 1978 (Electric World, 1979). Actual
inground installation costs may be similar to above ground
installation costs in new subdivisions, but inground installa-
tion may be several times more expensive than above ground
installation in existing housing areas. If all three wood
perservatives were cancelled, the lack of treated wood poles
would probably encourage more underground installation in areas
where such installations could compete with concrete or steel
poles. The use of untreated poles is not feasible since
effective pole life would be only 2 to 4 years.
471
-------
TABI£ 111-24
Poles: Alternative Scenarios for Estimated Consumption of
Preservatives, Cost of Preservatives, and CDst of Treated Poles
by Type of Preservative, 1978
Volune Quantity of Cost of
(cubic feet) Preservative Preservative
(Pounds) (Dollars)
Scenario 1:
Creosote
Penta
CCA/ACA
Ibtal
Scenario II:
Creosote
Banta
CCA/ACA
lotal
Scenario III
Creosote
Penta
CCA/ACA
lotal
Scenario IV:
Creosote
Penta
CCA/ACA
total
Scenario V:
Creosote
Panta
CCA/ACA
lotal
Scenario VI:
Creosote
lenta
CCA/ACA
lotal
1978 Actual Situation
18,237
41,905
4,038
Innn
164,133
18,857
2,423
64,180 185,413
Cancel Creosote and Shift to Penta
0
60,142
4,038
0
27,064
2,423
15,100
33,734
2,423
51,257
0
48,414
2,423
64,180 29,487 50,837
: Cancel Creosote and Shift to Arsenicals
0
41,905
22 ,275
0
18,857
13,365
64,180 32,222
Cancel Creosote and Penta and Shift
0
0
64 ,180
64,180
Cancel Penta and Shift
18,237
0
45,943
64,180
Cancel Arsenicals and
18,237
45,943
0
64,180
0
0
38,507
38,507
to Arsenicals
164,133
0
27 ,566
191,699
Shift to Penta
164,133
20,674
0
184,807
0
33,733
13,365
47,098
to Arsenicals
0
0
38 ,507
38,507
15,100
0
27 ,566
42,666
15,100
36,984
0
52,084
Cost .
of Poles
( Dollars)
81,155
178,096
15,546
274,797
0
255, 603
15,546
271,149
0
178,096
85 ,758
263,855
0
0
247 ,089
247,089
81,154
0
175,881
258,035
81,155
195, 257
0
276,412
472
-------
TABLE 111-24 Bales: Alternative Scenarios for Estimated Consumption of ,
Preservatives, Cbst of Preservatives, and Cost of Treated Poles
by Type of Preservative, 1978 (cont'd)
Volume Quantity of O>st of Cost ,
(cubic feet) Preservative Preservative of Poles
(Pounds) (Dollars) (Dollars)
1,000
Scenario VII; Cancel Arsenicals and Shift to Creosote
Creosote 22,275 200,475 18,444 99,124
Penta 41,905 18,857 33,734 178,096
CCA/ACA 0 0 0 0
Total 64,180 219,332 52,178 277,220
Scenario VIII; Cancel Arsenicals and Penta and Shift to Creosote
Creosote 64,180 557,611 51,300 285,596
Penta 0 00 0
CCA/ACA 0 0 0 0
Total 64,180 557,611 51,300 285,5%"
Scenario IX; Cancel Arsenicals and Creosote and Shift to Penta
Creosote 0 00 0
Panta 64,180 28,881 51,664 272,760
CCA/ACA 0 0 0 0
Total 64,180 28,881 51,664 272,760
Scenario X: Cancel Penta and Shitt to Creosote
Creosote 60,142 541,278 49,797 267,632
Panta 0 00 0
CCA/ACA 4,038 2,423 2,423 15,546
Total 64,180 543,701 52,220 283,178
a. Based on retention per cubic foot and cost given in Table III-6 and
Table III-7.
b. Cost per cubic foot f .o.b. at plant: creosote $4.45, penta $4.25, and
CCA $3.85 (Conpton, 1979).
-------
TABLE 111-25 Additional Capital Investment Required for
Alternative lole Ireatment Scenarios, 1978
facenario Equipment Changes Required1
Capital Investment
Required
I
II
III
IV
VI
VII
VIII
IX
None
Convert 30 cylinders from
creosote to penta at $25,000
each
Convert 30 cylinders from
creosote to arsenicals at
$25,000 each and 91 kilns
at $125,000 each
Convert 97 cylinders from
creosote and penta to arsenicals
at $25,000 each and 300 kilns
at $125,000 each
Convert 68 cylinders frcm penta
to arsenicals at $25,000 each
and 209 kilns at $125,000 each
Convert 7 cylinders from arsenicals
to penta at $200,000 each
Convert 7 cylinders from arsenicals
to creosote at $200,000 each
Convert 7 cylinders from arsenicals
to creosote at $200,000 each and
convert 68 cylinders from penta to
creosote at $25,000 each
Convert 7 cylinders from arsenicals
to penta at $200,000 each and con-
vert 30 cylinders from creosote to
penta at $25,000 each
Convert 68 cylinders frcm penta
to creosote at $25,000 each
$750,000
$12,325,000
$39,925,000
$27,825,000
$1,400,000
$1,400,000
$3,100,000
$2,150,000
$1,700,000
a. Assumes 137 poles per kiln charge or 2,740 cibic feet and 73 kiln
charges per year (5 days per charge).
474
-------
TABLE 111-26 Poles: Cost Effects of Required Capital Investment and a 50%
Increase of Preservative Rrices, 1978
Scenarios
I II III IV V
Oast effect of 0 $ 165,000 2,667,500 8,783,500 6,121,500
additional
investment
Cost effect 0 24,372,155 6,682,500 19,253,700 13,782,900
of 50%
increase in
preservative
cost
Combined 0 24,372,155 9,350,000 28,037,200 19,904,400
cost effect
A3 justed 274,797,200 295,521,955 284,147,200 302,834,400 294,701,600
cost of treated
poles after
capital and .
price increase
Ratio of 1.000 1.075 1.034 1.102 1.07
cost of treated
poj.es under new
scenario to
actual 1978 cost
a. First year effect: Based on amortizing investment over 10 years and 12%.
b. Derived by adding combined cost effect to total cost of treated poles
for each scenario given in lable II1-24.
476
-------
TABLE III-26 Poles: Ctost Effects of Required Capital Investment and a 50%
Increase of Preservative Prices, 1978 (continued)
V
Cost effect of 308,000
additional
investment3
Cbst effect 0C
VI VIII IX
308,000 682,000 473,000
0° 23,970,856 25,832,048
X
374, 000
24,898,000
of 50%
increase in
preservative
cost
Combined 308,000 308,000 24,652,856 26,305,048 25,272,000
cost effect
A3 justed 276,720,400 276,720,400 310,249,406 299,065,798 308,448,000
cost of treated
poles after
capital and ,
price increase
Ratio of 1.010 1.010 1.129 1.088 1.122
cost of treated
poles under new
scenario to
actual 1978 cost
a. First year effect: Based on amortizing investment over 10 years and 12%.
b. Derived by adding combined cost effect to total value of treated poles
for each scenario given in Table 111-24.
c. Snail volune of additional preservative is assumed to have no price effect.
477
-------
The utility industry would probably continue to use treated wood
poles if any one of the three preservatives were retained. If
all three wood preservatives were cancelled, the utility in-
dustry would probably utilize a combination of steel and con-
crete poles and underground installation. The construction
industry would probably switch from pole buildings to foundation
supported buildings.
iv. Annualized Cost Impact on Distribution Pole System
The definition for "annualized" cost and the methodology
employed for this cost determinations are presented in Section
1I1.B.4, Methods and Assumptions. Table 111-27 presents compar-
ative cost estimates for the treated wood distribution pole
system and potential alternative distribution systems based on
1978 use patterns. The 1978 total annualized cost for the
treated pole system is estimated at $1.03 billion. The annual-
ized cost would increase to $1.06 billion (or a $30 million
increase) if all poles were treated with creosote and decline to
$0.99 billion (or a $44 million decrease) if all poles were
treated with inorganic arsenicals.
The use of concrete as an alternative to treated wood distri-
bution wood poles would result in an annualized cost of $2.3
billion (an increase of $1,3 billion). A shift from treated
wood poles to steel poles or towers would result in an annual-
ized cost of $3.1 billion (an increase of $2.0 billion).
478
-------
TABLE III-27 Estimated Costs ot Treated Wood, Concrete, and Steel Bales or
Towers in Utility Distribution Systems, 1978
Item
Current Mix
ot Treated
Rales
Creosote-
Treated
Bales
Benta-
Treated
Bales
Installed cost
per pole (dollars)
Service life (year)
Bales in system
(million)
Average nunber ot
poles installed per
year to maintain
the system
Hresent value of
future cost of main-
taining system .
(million dollars)
Annualized cost
of maintaining
the system
(million dollars)
Annualized cost
per pole (dollars)
350.80
35
118
3,227,777
10,335.45
1,033.54
8.76
355.00
35
118
3,371,428
10,663.45
1,066.34
9.04
350.00
35
118
3,371,428
10,513.26
1,051.33
8.91
a. Weighted average ot data supplied by Edison Electric Institute (1979) and
Rural Electric Administration (1979).
b. Assumes number of poles used per year will expand in equal increments
during next ten years from current 2,418,500 poles to an average number
required to maintain the system. Discount rate is 10%, system
life is 100 years.
n
c. Average annual cost =
Present value x (1 + r) ,where r = 10%
n
(1 + r)" - 1
and n = 100
479
-------
TABLE III-27 Estimated Costs of Treated Wood, Concrete, and Steel Poles or
Towers in Utility Distribution Systems, 1978 (continued)
Item
Installed cost
per pole (dollars)
Service life (year)
Boles in system
Inorganic Arsenical-
Treated Boles
340.00
50
118
Concrete
Boles
770.00
35
118
Steel
Boles
1,050.00
50
118
(million)
Average nunber of
poles installed per
year to maintain
the system
Present value of
future cost of mian-
taining system .
(million dollars)
Annualized cost
of maintaining
the system
(million dollars)
Annualized cost
per pole (dollars)
2,360,000
9,899.99
989.99
3,371,428
23,129.17
2,312.92
8.38
19.60
2,360,000
30,573.50
d
3,057.35
25.90
a. Weighted average of data supplied by Edison Electric Institute (1979) and
Rural Electric Administration (1979).
b. Assumes number of poles used per year will expand in equal increments
during next ten years from current 2,418,500 poles to an average nunber
required to maintain the system. Discount rate is 10%, system life
is 100 years.
c. Average annual cost
Present value x (1 + r) ,where r = 10%
and n = 100
n
(1 + r)" - 1
d. Assumes 3,371,428 poles per year for 35 years and 0 poles for 15 years.
481
-------
v. Annualized Cost Impact on Transmission Pole System
Ihe cost impacts for replacing treated wood poles with steel or
concrete for transmission poles is shown in Table 111-28.
Concrete and steel poles become more competitive with treated
wood poles as the size of the transmission structure increases.
Between 70% and 90% of new transmission lines now being con-
structed are supported by steel towers. For example, in 1978 a
new transmission 161 KV line structure cost about $100,000 per
mile with wood (H-frame) construction and about $135,000 using
steel towers (toilhoirte, 1979). Thus, the cost of a steel sup-
ported line was about 1.35 times the cost of treated pole
supported lines.
The annualized costs of treated wood poles and non-wood
alternatives for transmission lines are summarized in Table
111-28. The use of creosote tor all transmission poles would
result in a annualized cost for the system of $354 million (an
increase of $12 million). if all transmission poles were
treated with inorganic arsenicals, the annualized cost of the
system would be $334 million (a decrease of $8 million).
482
-------
TABI£ 111-28 Estimated Costs of Treated Vvood, Concrete, and Steel Bales or
lowers in Utility Transmission Systems, 1978
Item
Installed cost b
per pole (dollars)
Service life (year)
Poles in system
Current Mix
of Treated
BDles
1,478
3b
8.33
Creosote-
Treated
Poles
1,491
35
8.33
Penta-
Treated
Roles
l,47fa
35
8.33
(million)
Average number of 231,388 238,000 238,000
poles installed per
year to maintain
the system
Present value of 3,420.49 3,549.17 3,513.47
future cost of main-
taining system .
(million dollars)
Annualized cost 342.05 354.92 351.35
of maintaining
the system
(million dollars)
Annualized cost 41.06 42.60 42.18
per pole (dollars)
a. Weighted average of data supplied by Edison Electric Institute (1979) and
Rural Electric Administration (1979).
b. Present value equals the total cost stream for 100 years discounted at 10%.
c. Average annual cost
Present value x (1 + r) ,where r = 10%
(1 + r)n - 1 and n = 100
483
-------
If all three wood preservatives were cancelled and utility
companies utilize concrete transmission poles, the annualized
cost would be $913 million (an increase of $571 million). If
the utility companies substitute steel poles for the wood pole
towers, annualized costs would be $1,093 million (an increase of
$751 million). Other treated pole materials such as aluminum or
fiberglass were not analyzed as alternatives since they have
serious physical limitations and are more costly than either
concrete or steel.
C. Non-pressure Treatments
1. Profile of the Wood Treatment Industry and Applicators
a. Poies-Groundiine
About 350 people are involved in some aspect of poles-groundline
treatment of poles with creosote and penta. The products used
for this application are prepared as a liquid which are applied
with a brush, as a grease-like formulation applied by brush,
paddle, scoop, caulKing gun or other mechanical applicator, or
as impregnants in wrapping or bandages applied around the pole
above and below ground level. Inspection and groundline
treatment of poles are carried out by small crews (2 to 3 men),
with one person usually responsible for the preservative
application (USDA-States-EPA, 1980) .
486
-------
ri^BLE 111-28 Estimated Gosts ot Treated Wood, Concrete, and Steel Boles* or
lowers in Utility Transmission Systems, 1978 (continued)
item Inorganic Arsenical-
Treated Boles
Installed cost 1
per pole (dollars)
bervice life (year)
Poles in system
(million)
Average number of 166
poles installed per
year to maintain
the system
Present value of
,446
50
8.33
,600
3,347.29d
Concrete
Boles
3,838
35
8.33
238,000
9,135.96
Steel Boles
or lowers
4,723
50
8.33
166,600
10,933.10d
future cost of main-
taining system .
(million dollars)
Annualized cost 334.73 913.60 1,093.30
of maintaining
the system
(million dollars)
Annualized cost 40.18 109.68 131.25
per pole (dollars)
a. Weighted average of data supplied by Edison Electric Institute (1979) and
Rural Electric Administration (1979).
b. Present value equals the total cost stream for 100 years discounted at 10%.
c. Average annual cost =
Present value x (1 + r)n ,where r = 10%
(1 + r)n - 1 and n = 100
d. Assumes 238,000 poles per year for 35 years and 0 poles for 15 years.
485
-------
b. Home and Farm
Penta and creosote products (over-the-counter products) are
applied by homeowners, farmers and to some extent by on-the-job
carpenters by brushing, rolling, dipping, soaking or spraying
the wood. An estimated 3 to 6 million people apply about 1.5
million pounds of penta annually and an estimated 50,000 people
apply about 2 million pounds of creosote annually by these
methods. Individual applicators normally use creosote or penta
only once or twice a year (USDA-States-EPA, 1980).
c. Sapstain Control
In 1977, there were nearly 23,000 United States establishments
(e.g., sawmills, planing and logging mills) in the lumber
manufacturing industry (U.S. Dept. of Commerce, 1979a,b). The
number of logging establishments increased from 13,238 in 1972
to 15,504 in 1977, but the sawmill and planing mill establish-
ments have declined from 8,071 to 7,491 during this same time
period. Despite the decline in sawmills and planing mills, the
total value of lumber shipments rose to $17 billion in 1977
compared to $9 billion in 1972.
d. Millwork and Plywood
The 1977 Census of Manufactures preliminary report (SIC 2431)
for millwork presents the most recent information for the
industry (U.S. Dept. ot Commerce, 1979c). The 1977 preliminary
487
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report lists 2,327 millwork establishments of which only 691
establishments employed 20 or more people. Nearly 42% of all
the millwork establishments are located in the Pacific, North-
Central and Gulf states.
According to the 1977 Census of Manufactures preliminary report,
the total value of shipments for millwork establishments was
$3.9 billion in 1977 (U.S. Dept. of Commerce, 1979c). Califor-
nia establishments accounted for the highest value of shipments,
$573.9 million. The 1977 value of shipments tor miliwork in-
creased about 64% from that of the 1972 value of shipments for
miiiwork. The products primarily responsible for the increase
in the value of millwork shipments were wood window units and
wood doors.
Total production of softwood plywood (3/8" basis) increased 3%
from 19.38 billion square feet in 1977 to 19.96 billion square
feet in 1978 (American Plywood Association, 1979). Of the 182
United States mills producing plywood in 1978, 111 mills were
located in the Western region. The percentage share of plywood
*
production of Western and Inland producers has been grad-
* The definition of producing regions are: 1) Western:
California and portions of Washington and Oregon that are west
of the the Cascade mountain range, 2) Southern: states south of
the Mason-Dixon line and from Virginia to Texas, and 3) Inland:
all other areas of the United States not defined in Western and
Southern regions.
-------
ually declining in the last decade while it has been increasing
in the South. The actual volume of plywood increased in all
regions except the Inland regions, where there was no change.
e. Particleboard
There is currently only one known plant producing penta-treated
particieboard. Production of treated particleboara has been
relatively consistent in the 70's with the exception of 1979
when only 29.5 thousand square feet of treated particieboard was
produced compared to 186.6 thousand square feet in 1978. The
average annual value of treated particieboard sold to distribu-
tors in recent years is about $35,000 (NFPA, 1979). In 1978,
about 3.9 billion square feet (3/4" basis) of particieboard were
produced in the United States (NPA, 1979). The National
Particieboard Association (1979) reported a value cf shipments
of $818 million for the total particieboard production in 1978,
almost a 70% increase over 1977.
2. Benefit Analysis by Use Category for Non-pressure
Treatments
a. Poles-Groundline
i. Usage and Identification of Use Category
The poles-groundiine treatment of in-place utility poles is a
small, but increasingly important segment of the wood treatment
489
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industry. In poles-groundline treatment, wood preservatives are
applied to a previously installed pressure treated pole over a
section covering the 6 inches above and 6 inches below the
ground level of the pole. This treatment is carried out to
prolong pole life by giving extra protection to the most
susceptable decay zone of the pole. Decay and subsequent pole
failure can be delayed for 20 or more years if the groundline
area is given supplementary preservative treatments. The normal
poles-groundline treatment cycle involves giving a pole its
first treatment 15 or 20 years after installation and following
this treatment with a subsequent application after 30 and 40
years of service.
The two major formulations of commercial pole-groundline
treatments marketed in the United States both contain creosote
and penta; one of these formulations has a high creosote content
and the other a high penta content (this product also contains
sodium fluoride). Currently, the high creosote formulation is
used for about 66% of all poles-goundline treatments and the
high penta product is used for about 33% of the poles-groundline
treatments.
The number of utility poles receiving poles-groundline treatment
in the United States, in 1978, was estimated to range rrom
yOO,GOO to 1,100,000 poles (for purposes of this analysis, the
number of poles treated annually is considered to be 1 mil-
lion) . In this year, the treatment industry used an estimated
172,000 pounds of penta and 655,000 pounds of creosote to treat
490
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poles for poles-groundiine treatment. The estimated average
cost per treatment varies between $10 and $12 per distribution
pole and between $14 and $16 per transmission pole (Cravens,
1979; Nagel, 1979). Assuming that about 93% of the treated
poles are distribution poles, the total cost in 1978 of poles-
groundiine application for 1 million poles ranged between $10.3
million to $12.3 million.
ii. Assumptions
The assumptions used in calculating the annualized savings are:
1) cancellation of creosote and penta pressure treatment for
poles will not take place, 2) an average of 30 years service
life for a treated pole without poles-groundiine treatment, 3)
an average of 50 years 'service life for treated .poles with
poles-groundiine treatment, 4) a $350 cost to represent the
current average installed replacement cost for a distribution
pole and $1,478 tor the replacement cost of a transmission pole,
5) a $10 cost for single poles-groundiine treatment per pole, 6)
an average of 3 poles-groundiine treatments for each treated
pole, 7) a current interest rate of 10%, and 8) straight line
depreciation for the treated poles.
iii. Impacts of Cancellation
The benefits associated with poles-groundiine treatment can be
estimated by determining the savings in pole replacement costs
resulting from an extension of pole life. The pole life can be
491
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extended 20 years beyond the assumed 30 year service life of a
pole not subject to poles-groundline treatment. The savings
resulting from poles-groundline treatment is presented in terms
of "annualized" costs (see Section I1I.4.B, Methods and
Assumptions, for definition).
The current costs per pole with and without poles-groundline
treatment and the present value of these 'cost savings associated
with poles-groundline treatment are shown in Table 111-29 for
distribution poles. The total savings from poles-groundline
treatment for each treated distribution pole is $203.33 for the
50 year period or $4.07 per year; this is equivalent to a pre-
f
sent value of future savings of $16.78. The annuaiized savings,
calculated from the present value of savings (see Section
III.B.4, Methods and Assumptions, for equation), is $1.67 for a
distribution pole. By a similar calculation, the annualized
savings for poles-groundline treatment of transmission poles is
$7.80. Assuming that 7% of treated poles are transmission poles
and 93% are distribution or telephone poles, the average
annualized savings per pole equals $2.21.
492
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TABLE 111-29 Calculation of Present Value of Savings per Pole Due to In- .
Place Poles-Groundline Treatment for Distribution Poles, 1978C
Current Cost per Pole
Time
Psriod
0
20
30
40
50
Total
Without
Groundline
Treatment
$350.00
0.00
350.00
o.ooh
-116.67
$583.33
With
Qroundline
Treatment
$350
10
10
10
0
$380"
Difference
in Cost
0.00
-10. 00
340.00
-10.00.
-116. 6r
$203.33
Discount Present Value
Factors of Cost Differ-
ence
1.0000
0.1487
0.0573
0. 0221
0.0085
$ 0.000
-1.487
19.482
-0. 221
-0.992
$16.782
a. Stource: USm-States-EEA, 1980.
b. The amount of money recovered frcm the sale of the used treated poles
(e.g., salvage value).
493
-------
It the average annualized savings per pole is multiplied by the
number of treated distribution and transmission poles (16.67
million) subject to poles-groundline treatment, the total
savings from the poles-groundline treatment program would be
$35,340,400 per year. If the current level of poles-groundline
treatment doubles within the next five years as some experts
have predicted, the potential savings will exceed $70 million
per year (Cravens, 1979).
If poles-groundline treatment were cancelled, about 222,300
additional replacement poles would be required each year
starting 10 years after poles-groundline cancellation and the
average installed cost for the these additional treated wood
poles would be about $77.8 million at present price of $350 per
distribution pole. If the current level of poles-groundline
treatment doubles in the next 5 years, the future annual pole
requirements will rise about 450,000 per year and the average
installed cost tor the additional treated poles would be about
$167.5 million at present price of $350 per distribution pole.
b. Home and Farm
i. Usage and Identification of Use Category
Penta and creosote solutions are applied by homeowners, farmers
and to some extent, by on-the-job carpenters, by brushing,
rolling, dipping, soaking or spraying the wood. Typical treated
494
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wood items include decks, siding, millwork, lumber, fences,
shingles, outdoor furniture and other miscellaneous wood
products.
Homeowners and farmers rely heavily on non-pressure applications
of penta and creosote formulations to extend the useful service
life of wood in aboveground applications and to obtain limited
protection for wood in contact with the ground. Because of low
retentions and poor penetration of these non-pressure formula-
tions into the wood, groundline (or below ground) treatment is
less effective for control than aboveground applications (USDA-
States-EPA, 1980).
About 1.6 million pounds of penta and 2.0 million pounds of
creosote are used around homes and farms to protect various wood
structures and products exposed to natural elements. The 1.6
million pounds of penta used for home and farm use represent 48%
of the total non-pressure applications, but only 4.3% of penta's
total usage as a wood preservative. The creosote sold for home
and farm use represents only about 0.1% of creosote sold for
wood preservation (USDA-States-EPA, 1980) .
Representative penta products available for retail sale include:
1) a 5% penta ready-to-use solution in oil, 2) a concentrate
containing 40% penta which is diluted with fuel or diesel oil
(1/10 dilution), 3) a penta water repellent concentrate which is
diluted with oil or mineral spirits (1/5 dilution), and 4) a
ready to use 5% penta water repellent preservative. These
495
-------
products, particularly the ready-to-use solutions, are commonly
sold in 1 quart, 1 gallon or 5 gallon containers; large volume
containers are also available tor the concentrate. Large
volumes (e.g., 55 gallon drums) ot the concentrated products
would most likely be purchased by farmers, who would have a need
for large volumes of wood preservatives and would have the
diesel and fuel oil for dilution readily available.
The ready-to-use water repellent penta formulation is the most
widely used treatment for standing structures (e.g., fences,
sheds, etc.) and is also widely used for building materials such
as window frames. Several water repellent stains containing
penta are available, although the most widely used products are
the clear solutions which can be covered with stain, paint,
varnish or left unfinished. The water repellent material
present in penta formulations prevents the warping, checking,
swelling and shrinking of the wood which is caused by the
changes in moisture content ot the wood.
Creosote and coal tar neutral oil products are available in
various concentrations ot active ingredients ranging from 21.5%
to 99.0%, with the 90-99% range products the most commonly used
(Cummings, i960). These products are generally used by farmers
tor soaking fence posts and lumber and for in-place remedial
treatments (NFPA, i960) .
The non-pressure inorganic arsenicais treatments are not avail-
able to home and farm applicators and are only available to
496
-------
commercial applicators (e.g., pressure treatment plant,
construction companies). About 2,000 to 3,000 gallons of a 3%
inorganic arsenical solution is annually sold to commercial
applicators for field treatment (outdoor applications only) on
cut-ends of inorganic arsenical-treated wood during fabrication
(USDA-States-EPA, 1980).
ii. Availability and Efficacy of Alternatives
Availability of Alternatives
There are several alternative wood preservatives registered for
use at the home and farm level, the most common being copper
naphthenate, copper-8-quinolinolate (Cu-8), zinc naphthenate and
tributyltin oxide (TBTO). Products containing these chemicals
are available for sale at most lumber and hardware stores.
Copper-8-quinolinolate (Cu-8) is registered for application at
concentrations from 0.25% to 0.30% for use on wood items (the
product is usually sold as a concentrate to be diluted with
oil). The retail availability of Cu-8 products is limited
because the high cost in manufacturing and the low demand for
the Cu-8 products by the consumers has made the manufacture of
this preservative uneconomical. One registrant (manufacturer)
has developed a water-based Cu-8 formulation (rather than oil)
which is available for industrial use, but is not currently
"available for home and farm use (Nagel, 1980).
497
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Several copper naphthenate, zinc naphthenate and TBTO preser-
vative products are registered for sale to homeowners and
farmers. The Agency has no information on the volume of these
chemicals actually sold for home and farm application.
Alternatives to non-pressure treatment include leaving the wood
untreated, using non-wood materials (e.g., aluminum, concrete)
or purchasing lumber which has been pressure treated. The only
untreated wood which would be decay resistant are the naturally
resistent wood species and are only available in small supply.
Comparative Efficacy
Non-pressure applications of penta have been effectively used
for nearly 40 years and are primarily effective for aboveground
use, but do provide some control when wood is used in ground
contact. Penta-treated wood is colorless, paintable and
stainable.
Generally, non-pressure applications (e.g., brush, dip and
spray) of creosote to dry, sound untreated wood are effective
for above ground, but are generally ineffective for ground
contact. Properly applied hot and cold soak treatments of
creosote will provide some protection for wood which is used in
ground contact (USDA-States-EPA, 1980). However, creosote formu-
lations discolor wood and leave the wood unpaintable. Penta can
be substituted for creosote, but creosote is only an effective
498
-------
alternative for penta where a paintabie or light colored, odor-
less, clean wood is not required.
Copper naphthenate is effective under certain conditions, but
its overall performance is questionable (NFPA, 1979). The
copper naphthenate solutions contain water repellents and most
of these formulations, including those containing color stains,
are recommended tor aboveground use only. There are, however,
a few "extra strength" products which give use directions for
treating wood which will be used in contact with the soil. In
addition to the questionable effectiveness, copper naphthenate
imparts a green color to the wood, makes a poor base for paint
and leaves the wood difficult to finish naturally. Another
alternative, zinc naphthenate, imparts a colorless finish to
wood, but is considered less effective than copper naphthenate.
The TBTO formulations are colorless in solution and leave the
wood clear and paintabie. This chemical has some known merit
for protecting wood aboveground, but is ineffective for ground
contact use (NFPA, 1979).
Cu-8 formulations (0.25% to 0.30%) have been used in tHe past to
protect wood and are registered for use on wood which will be in
contact with food. Various formulations, in water repellents,
prevent water absorbtion, swelling and checking of the wood, but
apparently have demonstrated less effectiveness 'in controlling
rot and decay than either creosote, inorganic arsenicals and
penta. In fact, the use of Cu-8 by homeowners and farmers has
499
-------
been declining in recent years. Some manufacturers no longer
supply their products to retail stores presumably due to higher
product costs than other preservatives and hence a small demand
for Cu-8 products.
All of the above wood preservatives lack the wide range of
control characteristic of penta, but are partial substitutes for
certain penta uses. For instance, creosote and copper naphthen-
ate can be used where a paintable, light color, odorless or
clean wood is not required. Copper naphthenate can be used when
the desired color of wood is not important. For strictly above
ground use, where paint is to be applied, TBTO will provide
effective control at the registered concentration.
The USDA-States-EPA Assessment Team (1980) recommends Cu-8 and
TBTO as acceptable alternatives for penta only at a 2% concen-
tration (unregistered formulations). At this concentration,
these Cu-8 and TBTO products would protect the wood from decay
and insects better than their registered concentrates.
Aluminum, concrete, plastic or other construction materials can
be substituted only for limited uses of the non-pressure treated
wood; these materials would be expected to have a reasonably
longer service life than the non-pressure treated wood (USDA-
States-EPA, 1980). Untreated wood can be used, but it has a
substantially shorter service life for exterior exposure (except
cedar and redwood) than treated wood.
500
-------
The protection provided by pressure treatment with the inorganic
arsenicais is superior than that provided by non-pressure penta
and creosote treatments for ground contact applications (USDA-
States-EPA, 1980). CCA- or ACA-treated lumber, timber and ply-
wood gives predictable performance in a wide range of exposure
situations and are highly effective for ground contact uses. in
recent years, lumber, plywood and fence posts pressure treated
with CCA or ACA have become more readily available to carpen-
ters, homeowners and farmers. However, the inorganic arsenical-
treated lumber (pressure) can only be considered a partial sub-
stitute for home and farm uses of non-pressure applications of
penta and creosote since treated lumber is not an alternative
for the supplemental treatment of standing structures.
lii. Impacts of Cancellation
The cancellation of non-pressure applications of both creosote
and penta for home and farm uses would lead to the substitution
of alternate wood preservatives, non-wood materials (e.g.,
aluminum) or pressure treated wood (e.g., CCA). Non-wood
materials (e.g., aluminum and steel) can replace wood in some
circumstances and are comparable in price for some uses. The
economic analysis of the cost differental tor non-wood materials
does not, however, take into account the aesthetic value of
wood.
There are several preservative products (e.g., copper naphthe~
nate, zinc naphthenate, Cu-8 or TBTO) currently available to
501
-------
homeowners and farmers as substitutes for penta or creosote
products. None of these chemicals give the overall performance
imparted by penta or creosote, but all are efficacious under
some conditions. However, the prices of these alternative
products are notably higher than the price of the penta or
creosote products.
The average prices for the registered formulations of various
wood preservative products are presented in Table 111-30. Wood
preservative prices vary depending on the type of product or
concentrate. The most commonly used formulation is a ready-to-
use 5% penta solution in mineral spirits which costs about
$9.50 per gallon. The price of a typical 98% creosote coal tar
solution is approximately $7.50 per gallon. Zinc naphthenate
(13.5% solution) costs $12.40 per gallon; copper naphthenate
(20% solution) $13.45 per gallon; and TBTO (0.3% solution)
$14.50 per gallon (no price was obtained for Cu-8 products). If
the TBTO and Cu-8 products were formulated and registered at the
concentration of 2.0% recommended by USDA-States-EPA Assessment
Team, the costs to the consumer would be substantially higher
than the cost for the currently registed TBTO and Cu-8 products.
502
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TABLE 111-30 Bane and Rirm: Average Retail Price of \ferious Wood Preser-
vative Products, 1978-1979
Type of Solution
Ready-to-use in
fuel oil
10-1 concentrate
to be diluted with
fuel or diesel oil
Heady-to-use in more
volatile solvents
(mineral spirits)
with water repellents
(clear, pigmented and
paintable)
Ready-to-use with
water repellents
(green)
Ready-to-use with
water repellents
(clear)
Ready-to-use in
mineral spirits
with water repell-
ents (clear, pig-
mented and paint-
able)
Beady-to-use
Active Ingredient
5% penta
40.0% penta
5% penta
20% copper naphthenate
(2.0% metallic copper)
13.5% zinc naphthenate
(2.0% metallic zinc)
0.3% TBTO (bistributyl-
tin oxide)
Retail Price
(dollars per gallon)
7.40
13.60
9.50
13.45
12.40
14.50
98.5% refined coal tar
creosote
7.50
Based on spot check of several lumber and hardware stores in the Washing-
ton, D.C. area (including parts of Maryland and Northern Virginia) as well
as personal communications with Roberts Cbnsodidated, Darworth Inc.,
Chapman Chemical and Koppers Chemical Company.
503
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instead of dip or brush treating lumber with over-the-counter
wood preservatives, a farmer or homeowner can use lumber that
has been pressure treated. The price of pressure treated lumber
is slightly higher than lumber treated by brush or dip, but the
pressure treated lumber provides better protection. The use of
pressure treated wood does not substitutue for the supplemental
treatment of standing structures or the treatment of cut ends of
pressure treated wood.
Table 111-31 presents the average prices for lumber of various
dimensions for both untreated wood and wood pressure-treated
with CCA. The cost of a 5% ready-to-use penta in mineral
spirits solution for treatment of lumber boards of various
dimensions is presented in Table 111-32. The cost for penta
depends on the dimension of the wood and the coverage afforded
by the penta solution (coverage varies with the surface condi-
tion of the wood). Table 111-33 compares the cost of untreated
lumber and the cost of the brush-on penta solution required to
treat this lumber with lumber pressure treated with CCA,
assuming that one gallon of penta solution ($9.50/gal.) covers
200 square feet ot lumber.
The available data are insufficient to perform a detailed
analysis of cost impacts due to cancellation. The economic
impacts on price and production of alternatives from the in-
creased demand caused by cancellation of penta and/or creosote
are difficult to measure due to the large number of uses
involved in this use category.
504
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OABIE 111-31 Retail Eticesa of Hressure Treated and untreated Dimensional
Lumber, 1980
Size unit of Measure Price of Untreated lumber
(dollars)
2"
2"
2"
2"
x 4" x 8'
x 6" x 12'
x 8" x 12'
x 10" x 12'
per board
per board
per board d
1,000 board feet
per board ,
1,000 board feet
low
$ 1.39
4.39
5.30
330.00
6.95
347.50
high
1.85
6.85
9.00
562. 50
13.30
660.00
c
average
1.69
5.60
7.30
453. 00
10.35
485. 00
a. Source: Based on a spot check of several limber and hardware stores in
the Washington, D.C. area (including parts of Maryland and Northern
Virginia), January, 1980.
b. untreated dimensional lumber is usually #2 grade southern yellow pine.
Other species also used are #1 southern yellow pine, spruce, and DDuglas-
fir. ihe #2 yellow pine is the least costly of the four. Uhtreated lumber
is almost always kiln dried.
c. Ihe average price was calculated using all the prices gathered and is not
the median of the low and high prices presented in this table.
d. Some retails stores offered discounts when lunber is brought in large
quantities (e.g., 1,000 board feet).
505
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1ABLE 111-31 Retail Pricesa of ftressure Treated and Untreated Dimensional
Lunber, 1980 (continued)
Size
2" x 4" x 81
2" x 6" x 12'
2" x 8" x 12'
2" x 10" x 12'
Unit of Measure
per board
per board
per board d
1,000 board feet
per board ,
1,000 board feet
Q
Price ot "treated Dumber
(dollars)
low
$ 2.25
6.00
8.00
448.00
11.10
555.00
high
3.35
7.95
10.60
662. 50
13.25
712.50
c
average
2.60
6.75
9.00
555. 00
12.15
592. 00
a. Source: Based on a spot check of several iunber and hardware stores in
the Washington, D.C. area (including parts of Maryland and NDrthern
Virginia), January, 1980.
c. One average price was calculated using all the prices gathered and is not
the mediun of the low and high prices presented in this table.
d. Some retails stores offered discounts when Iunber is brought in large
quantities (e.g., 1,000 board feet).
e. This is Iunber pressure treated with CCA. Treated dimensional lumber is
normally either #1 or #2 grade southern yellow pine. Lunber pressure
treated with CCA at 0.40 pounds of retention per cubic foot has a longer
expected service life than lumber treated at 0.25 pounds of retention.
Some applicators include a more extensive kiln drying process to lower
moisture content ot the wood. All these factors are partly responsible
tor the varying prices.
507
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TABLE 111-32 Home and Farm: Cbst per Board of Penta Solution Used
to Treat New Lumber by Brush-on or Dip Treatments, 1978
Cbverage per &llon Cost of Penta per Board for Lumber of Various
of Solution Dimensions
2" x 4" x 8' 2" x 6" x 12' 2" x 8" x 12' 2" x 10" x 12'
100
200
300
400
500
0.76
0.38
0.25
0.19
0.15
— — — ml l;
1.52
0.76
0.51
0.38
0.30
1.90
0.95
0.63
0.48
0.38
2.28
1.14
0.76
0.57
0.46
a. Source: USDA-States-EPA, 1980.
b. The costs are based on the following equation
Cost of penta per board = Price of penta solution x square feet per board
Square feet of lumber covered per gallon of
solution
Price of penta is $9.50 per gallon.
Dimension of
the Lumber Cubic Feet Square Feet
2" x 4" x 8' 0.357 8
2" x 6" x 12' 0.80 16
2" x 8" x 12' 1.07 20
2" x 10" x 12' 1.34 24
508
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TABLE I11-33 Comparative Rrices3 of ton-pressure Treated and Hressure
Treated Umber, 1978
Dimension of Average Rrice of. (tost of
the Lumber untreated lumber Itenta Solution
(dollars per board) (dollars per board)
2" x 4" x 81 $ 1.69C $ 0.38
2" x 6" x 8' $ 5.60 $ 0.76
2" x 8" x 12' $ 7.30 § 0.95
2" x 10" x 12' $10.35 $ 1.14
a. Source: USIA-States-EPA, 1980.
b. Cost based from lable 111-31.
c. Assumes a ready-to-use 5% penta in mineral spirits solution containing
water repellents. The price of the solution is $9.50 per gallon. One
gallon covers about 200 square feet.
510
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TABLE 111-33 Comparative Prices of Nan-pressure Treated and Pressure Treated
Lumber, 1978 (continued)
Dimension of Direct Cost of Nan- , Average Price
the Lumber pressure Treated Lumber of Treated Lumber
(dollars per board) (dollars per board)
2" x 4" x 8' $ 2.07 $ 2.60
2" x 6" x 8' $ 6.36 $ 6.75
2" x 8" x 12' $ 8.25 $ 9.00
2" x 10" x 12' $11.49 $12.15
d. This is only the cost of the materials, lunber and preservative, but this
cost does not include such costs as labor involved in applying the
preservative.
e. Lumber pressure treated with CCA.
511
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c. bapstain Control
i. Usage and Identification of Use Category
Although the most serious structural damage to wood is caused by
insects and decay, the discoloration caused by stain iungi is
also a ma3or problem. The most prevalent of the fungus stains
is sapstain, often referred to as "blue stain". Sapstain fungi
penetrate the sapwood of hardwoods and softwoods ana cannot be
easily removed by surface cleaning.
Sapstain infestation has little effect on the strength of the
wood, but can increase the capacity of the wood to absorb mois-
ture which makes the wood more vulnerable to decay. Moreover,
discoloration caused by the sapstain is objectionable to wood
users and reduces the market value of the wood (Nicholas, 1973;
Georgia CES, 1977) .
Currently, sodium pentachlorophenate (Na-penta) is the primary
antimicrobial used to control sapstaining and surface staining
fungi (molds). About 1.15 million pounds (derived from 1.02
million pounds of penta) of Na-penta are used annually for this
purpose (NFPA, 1979). This amount of Na-penta represents nearly
29% of the non-pressure uses of penta, but less than 2.7% of the
total estimated 37 million pounds of penta used as a wood pre-
servative (USDA-States-EPA, 1980). The penta solutions often
include the salts of other chlorinated phenols. About 1.4
512
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million pounds of chlorinated phenates are used annually for
sapstain control (NFPA, 1979).
Na-penta is most frequently applied to green lumber and shaved
round stock (e.g., poles and posts). Freshly peeled poles
and posts are treated with Na-penta to prevent sapstain growth
during air seasoning prior to pressure treatment. Green lumber
is treated with Na-peiffca to provide protection from sapstain
during storage and transportation.
Data on the amount of lumber and shaved round stock treated with
Na-penta to prevent sapstain growth are not available. Assuming
that only lumber (as opposed to poles and posts) was treated
with Na-penta, the volume of lumber treated for sapstain control
in 1978 is estimated to be 3.58 billion board feet. Of this
total, 2.08 billion board feet were domestic lumber and 1.5
billion board feet were lumber for export (EPA, 1980). Vir-
tually all lumber for export (94%) is treated with Na-penta for
sapstain control (NFPA, 1979). The total lumber production in
the Uiited States, in 1978, was estimated to be about 568.5
billion board feet (NFPA, 1979).
ii. Methods of Application
Na-penta for sapstain control is formulated primarily as a
liquid concentrate (generally 28% active ingredient), but is
also available as a dry powder (Nagel, 1980). Sapstain
treatments are typically made with a water-diluted solution.
513
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The concentration of the diluted solution depends on the degree
of control required. In terms of total lumber treated, almost
all lumber for export is treated with a 1:50 solution;
approximately one half of the Na-penta treated domestic lumber
is treated with a 1:60 solution and the remainder is treated
with a 1:100 solution of Na-penta (USDA-States-EPA, 1980). The
Agency does not have any information on the concentration level
of the solution applied to poles and posts.
Na-penta solutions used for sapstain control are usually applied
to green lumber by the "across-chain dip method." In this
procedure, the untreated lumber, which is conveyed through the
sawmill on a chain known as the "green chain", passes through a
tank containing Na-penta solution where the lumber is dipped for
a number of seconds. An alternative procedure, which is not as
prevalent as the across-chain dip method, but is similar to the
dip method, uses a spray tunnel instead of a dip tank. Another
treatment method involves stacking the lumber in bundles and
then dipping the bundles in Na-penta solution. This method is
known as bulk dipping and is infrequently used to apply Na-penta
for sapstain control (NFPA, 1979).
Poles and posts are treated with Na-penta most often by spraying
the poles or posts as soon they emerge from the bark peeler
(NFPA, 1979). The purpose of this treatment is to protect the
poles and posts during air seasoning before they can be kiln
dried and pressure treated.
514
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iii. Use and Efficacy of Alternatives
The alkali salts of tetrachiorophenol (tetra) , like those of
penta, have been used effectively for sapstain control for over
40 years (NFPA, 1979). In recent years, the supply of Na-tetra
in this country has declined and Na-tetra has been replaced by
Na-penta as the primary antimicrobial for sapstain control.
Na-tetra and potassium tetrachiorophenate (K-tetra) have been
typically used in combination with lower concentrations of
sodium trichlorophenate (Ma-TCP) and potassium trichiorophenate
(K-TCP). Even though salts of TCP concentrates are considered
twice as effective as Na-tetra and Na-penta concentrates, the
use of these TCP salts is limited because of cost (Nagel,
1980). No information is available on the volume of tetra and
TCP used for sapstain control.
Cu-8-quinolinolate is also registered with EPA for sapstain
control and is currently used to achieve control of sapstain
fungi (NFPA, 1980). Cu-8 has not been as extensively used as
the chlorinated phenols and information is not available on
the volume of Cu-8 used for sapstain control. The quantity
of Cu-8 used is believed to be considerably smaller than the
amount of the chlorinated phenols applied. There is also
limited information on the effectiveness of Cu-8 under actual
end-use conditions of the treated wood.
Kiln drying can also be used effectively to prevent sapstain
tor most softwoods by reducing the moisture content of the wood
515
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below 20% (the minimum moisture level suitable for sapstain
growth) and is the preferred method, where feasible (Georgia
CES, 1977). However, kiln drying use cannot be utilized in
those situations where freshly-cut lumber cannot be placed in
the kiln within 48 hours, as sapstain growth will begin at or
about this time period (NFPA, 1979). Kiln drying is also not
appropriate for a number of hardwood species which are subject
to warping and honeycombing during kiln drying.
iv. Impacts of Cancellation
In the event of cancellation of Na-penta, Na-penta applicators
most likely will switch to Na-tetra which is equally efficacious
and of equal cost. Although effective, TCP is more costly for a
registrant to formulate and, therefore, its use by applicators
may only increase slightly. Another possible alternative for
sapstain control is Cu-8, although Cu-8's performance under
extreme conditions is not believed to be adequate (NFPA, 1979).
There will be minor changes in treatment cost if an applicator
switches from Na-penta to one of the above chemical alternatives
for sapstain control.
The costs of Na-penta and alternative products are presented in
Table 111-34. The price of a gallon of Na-penta or Na-tetra
concentrate are essentially equivalent and are considerably
lower than the prices of the alternatives concentrates (Cu-8,
Cu-8 and Tetra, and K-tetra and K-TCP) . However, when diluted
516
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in accordance with label recommendations, the diluted alterna-
tive products are competitively priced with the diluted Na-penta
products.
Table 111-35 presents the estimated volume of lumber treated
with Na-penta for sapstain control and the comparative costs of
treating this volume with Na-penta and various alternatives.
The cost of treating 3.58 billion board feet of green lumber
with Na-penta or Na-tetra solutions is $2.77 million.
Cancelling Na-penta as a sapstain control could result in
serious economic losses to the lumber industry without the
availability of alternative preservatives. The extent of
these losses would depend on the level of grade reduction
which results from the lack of control of sapstain fungi (NFPA,
1979). Discloration caused by fungus would not likely be a
major concern of pole and post producers, but the decrease in
permeability of the wood caused by sapstain may lead to decay
during air seasoning and would create substantial economic
losses (NFPA, 1979).
517
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TABLE 111-34 Comparative Oasts of Sodium Pentachlorophenate, Cbpper-8-
Quinolinolate, Cbpper-8-Quinolinolate and letrachorophenol,
and lotassiun Trichlorophenate for Sapstain Control, 1978
Na-Penta
Item
thit
Export Treatment
Domestic Treatment
All Treatments
50 50
percent percent
Gbst per
gallon
?/gaib
5.75
5.75
5.75
concentrate
Percent of
chemical ina
concentrate
Gallons of
concentrate
per gallon _
of solution0
% by weight 28.00
concentrate/
dilution
ratio
0.02
28.00 28.00
0.017 0.01
Cost of
solution
Application
rate of solution
Chemical
cost per MBF
$/gal
gal/MBF
$/MBF
0.12
8.006
0.96
0.10
8.00
0.80
0.06
8.00
0.48
Costs for te-tetra solutions would be equivalent to the Na-Penta solution.
a. Nagel, F., Chapnan Chemical Co., 1980.
b. Market price.
c. Cost of concentrate times concentrate/dilution ratio.
d. Application rate ranges from 8 to 10 gallons of water-diluted solution per
million board feet (MBF).
e. Application rate times cost of solution.
518
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TABLE 111-34 Comparative Costs of Sodium fentachlorophenate, Gbpper-8-
Quinolinolate, Gopper-8-Quinolinolate and Tetrachorophenol,
and lotassiun Trichlorophenate for Sapstain Control, 1978
(cont'd)
Item
Uiit
Cu-8
Export Treatment
All Treatments
Domestic Treatment
50 50
percent percent
Cbst per
gallon
concentrate0
Itercent of
chemical in.
concentrate6
Gallons of
concentrate
per gallon .
of solution0
$/galu 12.50
% by weight 5.40
concentrate/ 0.13
dilution
ratio
12.50 12.50
5.40
5.40
0.10 0.005
Cost of
solution
£ppl ication
rate of solution
Chemical
cost per MBF
$/gal
gal/MBF
$/MBF
0.17
8.00d
1.36
0.13
8.00
1.04
0.06
8.00
0.48
a. Nagel, F., Chapman Chemical Co., 1980.
b. Market price.
c. Cbst ot concentrate times concentrate/dilution ratio.
d. /^plication rate ranges from 8 to 10 gallons of water-diluted solution per
million board feet (MBF).
e. Application rate times cost of solution.
519
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TABLE 111-34 Comparative Costs of Sodium Jentachlorophenate, Gopper-8-
Quinolinolate, Copper-8-Quinolinolate and letrachorophenol,
and lotassiun Trichlorophenate for Sapstain Control, 1978
(cont'd)
Item
Cost per
gallon
concentrate
Efercent of
chemical in
concentrate
Gallons ot
concentrate
per gallon
of solution
Cost ot
solution0
Appl ication
rate of solution
Chemical
cost per MBF
Ihit
$/gaib
% by weight
concentrate/
dilution
ratio
S/gal
gal/MBF
S/MBF
Cu-8
Export Treatment
All Treatments
14.50
5.00 (Cu-8)
16.30 (Ifetra)
0.008
0.12
8.00d
0.96
and Tetra
Domestic
50
percent
14.50
5.00
16.30
0.007
0.10
8.00
0.80
Treatment
50
percent
14.50
5.00
16.30
0.004
0.06
8.00
0.54
a. Nagel, F., Chapnan Chemical Co., 1980.
b. Market price.
c. Cost of concentrate times concentrate/dilution ratio.
d. Application rate ranges from 8 to 10 gallons of water-diluted solution per
million board feet (MBF).
e. Application rate times cost of solution.
520
-------
TA3LE 111-34 Comparative Costs of Sodium Ifentachlorophenate, Copper-8~
Quinolinolate, Copper-8-Quinolinolate and Tetrachorophenol,
and Ebtassiun Trichlorophenate for Sapstain Control, 1978
(cont'd)
K-Tetra and K-TCP
Item
Unit
Export Treatment
All Treatments
concentrate
Ifercent of
chanical in.
concentrate0
Gallons of
concentrate
per gallon
of solution
Cost of
solution
% by weight
concentrate/
dilution
ratio
$/gai
31.40 (K-tetra)
7.30 (K-TCP)
0.01
0.14
Domestic Treatment
50 50
percent percent
Cbst per
gallon
$/galb
13.50
13.50
13.50
31.40
7.30
0.007
31.40
7.30
0.005
0.09 0.07
£ppl ication
rate of solution
Chemical cost
per MBF
gal/MBF
$/MBF
8.00d
1.12
8.00
0.72
8.00
0.56
a. Nagel, P., Chapnan Chemical Co., 1980.
b. Market price.
c. Cost of concentrate times concentrate/dilution ratio.
d. Application rate ranges from 8 to 10 gallons of water-diluted solution per
million (MBF).
e. Application rate times cost of solution.
521
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TABLE 111-35 Vblune of Uhited States Lumber Products and Comparative Costs
of Treatment with tfe-Penta and Alternative formulations, 1978
Product Vblune Percent
(billion
board feet)
Domestic 2.08 100
Dumber (Total
treated)
50% Treatedc 1.04 50
50% Treated0 1.04 50
Lunber for 1.50 100
Export
Hardwood 0.32 21
Softwood 1.18 79
lotal Vood 3.58
Treated
Solution Costs'*
Na-Pentab Cu-8 Cu-8/ K-Tetra/
Tetra K-TCP
1.33 1.33 1.39 1.33
0.83 0.83 0.83 0.75
0.50 0.50 0.50 0.38
1.44 1.55 1.44 1.55
0.31 0.33 0.31 0.33
1.13 1.22 1.13 1.22
2.77 2.88 2.83 2.88
a. Volune treated times cost of solution (Table I1I-6).
b. Costs of hfa-tetra solutions would be equivalent to Na-penta solutions.
c. Assuming the following dilute ratios based on label recommendations:
50% lumber treated 50% lumber treated
Na-penta
Cu-8
Cu-8/Tetra
K-tetra/K-TCP
dilute ratio*
1:60
1:100
1:150
1:150
*Diluted with water
dilute raticr
1:100
1:200
1:250
1:200
522
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d. Millwork and Plywood
i. Usage and Identification of Use Category
Millwork includes wood windows, sash screens, blinds, shutters,
window frames, doors, door frames and mouldings, as well as
machined parts of these products (NFPA, 19.79). All of these
items are manufactured primarily from ponderosa pine and other
softwoods. An estimated 80% of the lumber used for manufac-
turing millwork in 1978 was softwood (NFPA, 1979). Softwoods
have a low natural resistance to decay and must be treated if a
prolonged service is expected.
Penta water-repellent solutions are applied to exterior millwork
products to prevent decay and/or insect infestation. The penta
and water repellents protect the millwork after installation,
primarily for aboveground exposure. Only about 1.6% (600,000
pounds) of total penta used for wood preservation was used by
the millwork industry in 1978 (USDA-States-EPA, 1980). The
600,000 pounds of penta consumed by the industry were used to
treat approximately one-third of the 1 billion board feet of all
millwork manufactured in 1978 (NFPA, 1979).
Penta water-repellent solutions are sometimes applied to
softwood plywood in addition to millwork. Less than 0.1% (15
million square feet) of the more than 19 billion square feet of
softwood plywood (3/8" basis) produced annually is treated with
penta and consumes less than 50,000 pounds of penta (NFPA,
523
-------
1979). The most prevalent plywood use of the penta solution is
as a water repellent and mildewcide for textured plywood siding,
specifically redwood siding (NFPA, 1979) .
ii. Methods of Application
MillworK and plywood are usually treated with a 5% penta solu-
tion in mineral spirits (containing water repellents) which is
applied by spraying, brushing, dipping (cold or hot preservative
treatment) or by the vacuum process (NFPA, 1979). Penta is
applied to millwork primarily by the dipping and vacuum process.
Remachined or cut pieces of wood are often brush treated to
protect exposed edges from decay. Plywood is typically treated
by dipping or spraying.
lii. Availability and Efficacy of Alternatives
Availability of Alternatives
A number of wood preservative products containing 0.3% tri-
butyltin oxide (TBTO) are currently available for retail sale
tor home and farm use for miilwork. The 0.3% TBTO concentration
does not provide the protection required by the millwork
industry and is not approved by the National Wood Manufacturers
Association (NWMA) for this use (Arsenault, 1980). Some
millwork manufacturers have been known to make their own TBTO
solutions from concentrates (amount of TBTO used is not known)
and others have used solutions containing both penta and TBTO
524
-------
(Arsenault, 1980). Within the last year, a 0.75% TBTO solution
has been registered as a preservative for millwork (Arsenault,
1980) .
Copper-8-quinolinolate concentrates for industrial use that are
registered for millwork are diluted with mineral spirits to
obtain a 0.25% Cu-8 ready-to-use solution (Nagel, 1980).
Although these Cu-8 concentrates are approved by NWMA for
millwork preservation, the volume used has been small (Nagel,
1980). A water-based Cu-8 concentrate for general wood preser-
vation has been available tor over five years and is diluted
with water, rather than petroleum oil or mineral spirits, to a
0.5% Cu-8 ready-to-use solution (Nagei, 1980). This water-based
concentrate is registered for millwork preservation, but it is
not approved by the NWMA for this use (Nagel, 1980). No informa-
tion is available regarding the amount of water-based Cu-8
currently used by the millwork industry.
Other structural materials, particularly aluminum, are commonly
used to manufacture some millwork items such as windows and
doors (NFPA, 1979). Information on the total volume of non-wood
millwork products produced is unavailable.
Comparative Efficacy
Penta has been the standard wood preservative used by the
millwork industry for more than 40 years and has proven its
effectiveness against decay as well as several insect species
-------
(NFPA, 1980). Penta is colorless, compatible with paints,-
stains, sealers and primers and does not interfere with the
adhesion of glazing compounds, caulkings or other sealants
(NFPA, 1979). These characteristics are necessary for
preservatives to be used on millwork.
Ihe 0.3% TBTO and the 0.25% and 0.50% Cu-8 products provide
limited protection when applied by brush, dip or spray, but may
not provide the more extensive protection necessary for mill-
work. However, the 0.75% TBTO solution is an effective preser-
vative for exterior millwork, specifically for aboveground use
of millwork which is subsquently painted, varnished or coated
(NFPA, 1980). If millwork is subjected to severe exposure
(e.g., soil contact), the prolonged service life provided by the
0.75% TBTO solution will not equal that of penta (NFPA, 1980).
The Cu-b concentrates when diluted with mineral spi-rits to make
a 0.25% to 0.3% Cu-8 ready-to-use solution are approved by the
NWMA, but not recommended by the National Forest Products
Association for millwork protection (NFPA, 1980; Nagel, 1980).
The NWMA requires that preservatives for millwork should have
petroleum carriers and has not yet approved the water-based Cu-8
product for millwork applications (Nagel, 1980).
iv . Impacts of Cancellation
Penta solutions are sold to millwork manufacturers primarily in
tank trucks or cars (Arsenault, 1980). The price of the ready-
S26
-------
to-use solution of penta based on a bulk rate is about $1.70 per
gallon plus the freight cost. The largest portion of this cost
is the mineral spirits (0.8 pounds per gallon of solution).
Mineral spirits currently cost about $1.20 per gallon and the
price has been rising with the cost of oil (Arsenault, 1980).
The bulk price of the 0.75% ready-to-use solution of TBTO is
approximately the same as the penta.
A 3.75% Cu-8 concentrate for dilution with mineral spirits cost
about $7.00 per gallon in bulk (Nagei, 1980). The cost of the
Cu-8 and the mineral spirits for a gallon of a 0.25% Cu-8 ready-
to-use solution, which is assumed to provide effective protec-
tion tor millwork, is about $1.60. This price would be slightly
higher when adjusted for delivery cost (Nagel, 1980). If a 10%
Cu-8 water based concentrate is used, the estimated cost is
$12.50 per gallon in bulk (Nagel, 1980). Assuming a zero cost
tor water, the price for a 0.5% to 2.0% ready-to-use Cu-8
solutions would range from $0.b5 to $2.50 per gallon.
If penta were cancelled for millwork treatment, applicators
would likely switch to a 0.75% TBTO solution which is similar in
cost to penta and has shown effectiveness tor above ground
exposure when painted (NFPA, 1979). If the water-based Cu-8
i
solution proves its effectiveness, many penta applicators would
switch to Cu-8 products.
Other alternatives for millwork include the use of naturally
resistant wood, untreated wood and non-wood materials. Due to
527
-------
the short supply of naturally resistant wood and the frequent
replacements required for untreated wood, the most likely non-
chemical alternative would be the use of non-wood materials.
There is very little economic data available for treated
softwood plywood and the Agency lacks economic information on
the cost of treated and untreated plywood for the plywood
markets. The cost impact of the cancellation of penta for
treatment of softwood plywood does not appear to be significant
due to the small volume of softwood treatment. TBTO could
replace penta for those uses where the treated plywood could be
painted. The effectiveness of Cu-8 for plywood has not been
proven by actual field use experience (Arsenault, 1980).
e. Particleboard
i. Usage and Identification of Use Category
In some areas of the United States it may be necessary to treat
particleboard to prevent attack by dry-wood termites and other
wood destroying insects. Penta is presently the only effective
preservative used for this specific purpose. There is currently
only one known plant producing penta-treated particleboard.
Annually less than 10,000 pounds (about 1,000 gallons) of
penta are used to treat an average of about 170,000 square feet
(3/4" base) of particleboard (NFPA, 1979). This treated parti-
cleboard makes up less than 1% of the average annual particle-
528
-------
board production at the plant and represents a very small part
(about 0.005%) of the 3.9 billion square feet of particleboard
produced in the United States in 1978 (National Particleboard
Association, 1979).
The penta-treated particleboard can be made in thickness ranging
from 3/8" to 1 3/4" and any size up to 5' x 16'. The finished
penta-treated particleboard is sold to distributors and event-
ually used in cabinets and outside furniture in certains areas
of the United States where there is a high occurrence of termite
attack, specifically Hawaii.
ii. Methods of Application
The individual wood particles in particleboard are bonded
together by the polymerization of urea-formaldehyde resin.
During the manufacturing process, the penta solution (0.65%
penta solids based on oven dry weight of the wood), resin and
wax emulsion are applied to the wood particles at the same
time. After treatment, the wood particles are conveyed to a
forming station where the material is formed into a mat and then
to the press where the mats are consolidated into boards (NFPA,
1979) .
529
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iii. Availability of Alternatives
There are no known chemical alternatives that are registered for
this specific use of penta. One unique characteristic of penta
is its ability to be mixed directly with the resins and wax in
the production of particleboard.
No substitute chemical has been used in the manufacture ot
treated particleboard nor has any substitute been found that is
compatible with the urea-formaldehyde resin or that gives the
level of protection provided by penta (NFPA, 1979; Cheo, 1979).
There are, however, several chemicals registered for controlling
drywood, dampwood or subterranean termites, namely: copper
naphthenate, anthracene oil, chlordane, copper-8-quinolinolate,
copper acetoarsenic, ethylene dibromide, zinc naphthenate and
ortho-dichlorobenzene. Since the termite infestation occurs
during end-use, it may be possible to treat the finished parti-
cleboard with these other pesticides. However, the effective-
ness of these pesticides for preventing termite infestation when
particleboard is treated in service is not known. There are
also no data available comparing the termite resistance of
penta-treated and untreated particleboard.
iv. Impacts of Cancellation
The price of the premixed penta solution purchased for the
manufacture of treated particleboard is approximately $5.65 per
530
-------
gallon (McVey, 1980). Since there are no known alternative
chemicals available for this use, no comparative prices were
derived.
There is currently only one known producer of penta-treated
particleboard. The applicator impacts of cancelling penta for
this use would be limited to this plant.
On average, less than 1% of the total particleboard production
of the plant during the last seven years was devoted to penta-
treated particleboard (McVey, 1980). For the last several
years, a gross annual revenue of about $35,000 was derived from
the sale of the treated particleboard; the costs attributable to
this gross figure are not known. Hence, the economic impacts of
cancelling penta for this use would not be significant.
v. Limitations of Analysis
The Agency does not have data for a detailed analysis of the
economic impacts to the users of penta-treated particleboard
(e.g., cabinets or furniture makers). The Agency also lacks
efficacy data to evaluate the monetary importance of penta-
treated particleboard compared to untreated particleboard.
531
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D. Summary of Wood Preservatives Economic Impacts
1. Introduction
Tables 111-36 through 111-40 summarize the usage and the poten-
tial economic impacts of cancellation of one, two or all three
wood preservatives by use category and chemical for pressure and
non-pressure applications. Table 111-39 summarizes the short-
term (e.g., first year) impacts from cancellation. Table 111-40
summarizes the long-term average annual or annualized impacts
(see Section 111.B.4, Methods and Assumption, for definition).
2. Pressure Treatments
In general, the cancellation of one of the wood preservatives
(e.g., cancel penta and retain all others) would result in few
severe and long lasting economic impacts. Most economic impacts
would generally be short in duration and related to the adjust-
ment of the industry to alternate preservatives. Current trends
in the wood treating industry are toward greater use of inor-
ganic arsenicals since these have the most versatility of the
wood preservative agents and are less dependent on petroleum and
coal than either penta or creosote. The cancellation of two of
the major wood preservatives with the retention of the third
would result in severe economic impacts in certain cases such as
railroad ties (cancellation of creosote and penta). For the
majority of pressure treatment uses, however, the remaining
alternative would be a viable substitute although cost impacts
532
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could be substantial for changing from one treatment process to
another one.
On the other hand, the cancellation of all three wood preserva-
tives would force the use of alternate building materials (e.g.,
concrete or steel) in-place of treated wood and would cause
severe and long lasting economic impacts.
Creosote is the major wood preservative used for the treatment
of railroad ties. The cancellation of creosote for this use
would cause significant adverse long-term impacts. If penta
remains available, the impacts will not be as severe as those
generated if penta and creosote were not available. Copper
naphthenate-treated or concrete ties (which are considerable
more expensive than creosote- or penta-treated wood ties) would
be the most likely alternatives under the penta and creosote
cancellation scenario.
The lumber, timber and plywood uses are dominated by the
inorganic arsenicals. With the exception of industrial block
flooring (a creosote use), the inorganic arsenicals can possibly
be used to treat all of the wood in this use category. There
are many uses, moreover, for which inorganic arsenicals are the
only viable preservative and creosote and penta are unaccept-
able. Thus, if penta and/or creosote were cancelled for lumber,
timber and plywood uses, the economic impacts would not be
severe. However, the cancellation of the inorganic arsenicals
for these uses would cause adverse, large and long lasting,
533
-------
impacts with the substitution of non-wood materials (e.g.,
steel, aluminum, plastic, etc.). The economic impacts resulting
from the cancellation of all three major wood * preservatives
cannot be determined because of the diversity of end-uses of
lumber, timber and plywood, but these non-wood materials would
be higher in cost than treated wood. The alternatives would
also not have the performance (e.g., the ability to be reformed
if needed) of treated wood.
Creosote is the major wood preservative used for the treatment
of pilings. Penta cannot be used for marine pilings and hence
the cancellation of creosote and inorganic arsenicals tor the
use of treating wood pilings would cause adverse impacts and
would result in the use of more expensive concrete or steel
pilings. For foundation pilings, if one or two of the three
wood preservatives were cancelled, the long-term impacts are not
projected to be substantial as long as one preservative remains
available.
Penta is the major wood preservative used for the treatment of
posts. All three of the major wood preservatives and steel
posts can be used satisfactory and have comparable prices. The
cancellation of one or two of the three wood preservatives in
this use category would cause adverse short-term impacts due to
the cost impact of the conversion from one treatment process to
another.
534
-------
TABIE 111-36 Summary of Creosote Usage for Pounds of Active Ingredient
Used and Anount of Vbod Ireated, 1978
Use
1.
2.
3.
4.
5.
6.
7.
8.
9.
Category
Railroad ties
Umber, timber
and plywood
Pilings
Posts
Crossams
Bales
Poles-Groundl ine
Home and farm
Saps tain control
RDinds
(1,000)
825,104
184,821
151,733
27,504
398
164,133
655
2,000
—
Percentage
6G.8
13.6
11.2
2.0
<0.1
12.1
<0.1
0.1
—
Cubic Eeeta
(1,000)
103,138
10,780
9,993
4,584
41
18,237
_„
—
—
Percentage
70.3
7.3
6.8
3.1
0.0
12.3
—
—
— —
10. Miliwork and
plywood
11. Barticleboard
•total 1,356,348 100.0 146,773 100.0
Source: USDA-States-EPA, 1980.
535
-------
TABLE 111-37 Suimary of Inorganic Arsernicals UBage for founds of .Active
Ingredient Used and Mount of Vbod Ireated, 1978
Use
1.
2.
3.
4.
5.
6.
Category
Railroad ties
Lumber, timber
and plywood
Pilings
Posts
Crossarms
Boles
R>undsa
(1,000)
—
34,985
1,392
1,784
12
2,423
Percentage
—
86.2
3.4
4.4
0.0
6.0
Cubic Eeeta
(1,000)
2,498b
73,318
943
4,461
29
4,038
Percentage
2.9
86.0
1.1
5.2
<0.1
4.7
7. Roles-Groundline
8. Hone and farm
9. Sapstain control
10. Millwork and
plywood
11. Barticleboard
lotal 40,596 100.0 85,287 100.0
a. Source: USEA-States-EPA, 1980.
b. inorganic arsenical-treated ties are not used for railroads. However,
inorganic arsenical-treated ties are used for landscaping purposes and
are considered under the use category of lumber, timber and plywood.
536
-------
1PBIE 111-38 Sumiary of Penta Usage for K>unds of Active Ingredient Used
and Mount of Wood Ireated, 1978
Use
1.
2.
3.
4.
5.
6.
7.
8.
9.
Category
Railroad ties
Lumber, timber
and plywood
Pilings
Posts
Crossarms
Poles
Poles-Groundl ine
Home and farm
Sapstain control
Pounds3
(1,000)
180
9,883
692
3,295
646
18,857
172
1,600
1,016
Percentage
0.5
26.7
1.9
8.9
1.7
50.9
0.5
4.3
2.7
Cubic Feet3
(1,000)
449
21,209
1,154
10,983
1,615
41,905
—
—
3,580,000
Percentage
0.14
6.65
0.36
3.44
0.50
13.13
—
—
74. 79
10. MillvorK and
plywood
650
11. Particleboard
10
board feet or
238,667
cubic teet
1.7 33,000 0.98
board feet or
2,200
cubic feet and
15,000
square feet or
937.5
cubic feet
0.1 170 <0.01
square feet or
10.625
cubic feet
lotal
37,001
100.0
319,130.125
100.0
a. fburce: USIA-States-EPA, 1980.
537
-------
TABLE I11-39 First Year Impacts of Cancelling Wood Preservatives
Use Category
Be tent
Economic Mpact
Significance
1. Railroad ties
a. Cancel Creosote
b. Cancel Penta
c. Cancel Creosote
and Fenta
2. Lunber, timber,
and plywood
a. Cancel Inorganic
Arsenicals
b. Cancel Penta
c. Cancel Creosote
d. Cancel Inorganic
Arsenicals and Penta
e. Cancel Inorganic
Arsenicals and
Creosote
f. Cancel Penta and
Creosote
g. Cancel Inorganic
Arsenicals, Penta,
and Creosote
decline in cost minor
of $18.2 million
little or no impact minor
additional cost major
of $581 million.
to $3.7 billion0
significant losses, penta major
and creosote are not alter-
natives for most uses
additional cost of major
$18 million for preserva-
tives and capital invest-
ment
additional cost of minor0
$39 million
significant losses, major
creosote would not be
a substitute in most
uses
significant losses, penta major
is not a substitute for
most uses
additional cost of moderate
$5.2 million
significant losses, major
substitution of
non-wood materials
were possible
538
-------
TABLE 111-39 First Year finpacts of Cancelling Vtood Preservatives (continued)
Use Category
Extent
Economic Impact
Significance
3. Pilings
a. Cancel Creosote
b. Cancel Penta
c. Cancel Inorganic
Arsenicals
d. Cancel Creosote
and Penta
e. Cancel Creosote and
Inorganic Arsenicals
f. Cancel Penta and
Inorganic Arsenicals
g. Cancel Inorganic
Arsenicals, Panta,
and Creosote
4. Posts
a. Cancel Penta
b. Cancel Creosote
c. Cancel Inorganic
Arsenicals
d. Cancel Penta and
Creosote
additional cost of
$9 million to $10
million
additional cost of
$8.3 million to $9.0
million
small impact, creosote
would substitute for
inorganic arsenicals
additional
cost of $8 million
significant losses, 4.3
million cubic feet of
marine pilings would
be replaced with concrete
or steel pilings
additional cost of f
greater than $9 million
additional average annual
cost of $64.5 million to
$129.1 million
additional cost of
$0.75 million to
$5.1 million
additional cost of
$3.3 million
additional cost of
$4.0 million to
$4.5 million
additional cost of
$383,000
major
major
minor
major
major
major
major
moderate
moderate
moderate
minor
539
-------
TABLE 111-39 First Year Impacts of Cancelling Wood Rreservatives (continued)
Use Category
Extent
Economic Mpact
Significance
4. Posts (continued)
e. Cancel Eenta and
Inorganic Arsenicals
f. Cancel Creosote and
Inorganic Arsenicals
g. Cancel Inorganic
Arsenicals, Eenta,
and Creosote
5. Crossanns
a. Cancel Eenta
b. Cancel Creosote
c. Cancel Inorganic
Arsenicals
d. Cancel Psnta and
Creosote
e. Cancel Eenta and
Inorganic Arsenicals
t. Cancel Creosote and
Inorganic Arsenicals
g. Cancel Inorganic
Arsenicals, fenta,
and Creosote
6. Poles
a. Cancel Fenta
b. Cancel Creosote
additional cost of
greater than $5.1
million
additional cost of
greater than $7 million
significant losses,
substitution of steel
fence post were possible
decline in cost of $0.23
million to an additional
cost of $1.2 million
decline in cost of
$15,000 to $30,0009
snail additional cost to
alternate preservatives5
snail decline in cost
additional cost of
$1.2 million
decline in cost
of $0.2 million9
significant losses,
substitution of non-wood
materials (e.g., steel)
were possible
additional cost of $19.9
million to $24.2 million
additional cost of $9.4
million to $20.7 million
moderate
major
major
minor to
moderate
minor
minor
minor
moderate
minor
major
major
major
540
-------
TABLE 111-39 First Year Impacts of Cancelling Vtood Preservatives (continued)
Use Category
Econonic inpact
Extent
Significance
6. foles (continued)
c. Cancel Inorganic
Arsenicals
d. Cancel fenta and
Creosote
e. Cancel Benta and
Inorganic Arsenicals
f. Cancel Creosote and
Inorganic Arsenicals
g. Cancel Inorganic
Arsenicals, Psnta,
and Creosote
7. RDles-Groundline
a. Cancel Creosote
b. Cancel Ifenta
c. Cancel Creosote
and Penta
8. Home and farm
a. Cancel Creosote
b. Cancel Bsnta
c. Cancel Creosote
and Penta
9. Sapstain control
Cancel Na-penta
additional cost of minor
$1.9 million
additional cost of major
$28 million
additional cost of major
$35.5 million
additional cost of major
$24.3 million
significant losses, major
substitution of steel
and concrete at higher
cost
small impact, substitution minor
of penta
small impact, substitution minor
of creosote
decline in cost of $10 minor
million to $12 million
slight additional cost
for preservative
slight additional cost
for alternatives
slight additional cost
for alternatives
minor
minor
minor
cost and efficacy of minor
Na-tetra is equal to
that of tfe-penta
541
-------
TABLE 111-39 First Year Impacts of Cancelling Wood Hreservatives (continued)
Use Category
Extent
Economic Impact
Significance
10. Millwork and plywood
Cancel Ifcnta
11. Eferticleboard
Cancel Ifenta
slight additional cost
for alternatives
$35,000 loss in
revenues
minor'
minor
a. Installation cost are lower for penta ties.
b. Both creosote and penta are cancelled and shifted to a copper naphthenate-
treated or concrete tie system.
c. fbout 700,000 cubic feet of industrial block flooring cannot be treated
with penta and/or inorganic arsenicals.
d. /toout 700,000 cubic feet of industrial block flooring and 4,25b cubic feet
of transportation lumber that is currently treated with creosote cannot
be treated with inorganic arsenicals.
e. Lhder this scenario, the high cost increase for equipment changes is
largely offset by the lower cost of inorganic arsenical-treated pilings.
f. One cancellation of both penta and the inorganic arsenicals results in an
economic impact similar to that of cancelling either penta or the inorganic
arsenicals singly due to the high usage of creosote-treated pilings.
g. Economic impacts are only for current preservative prices and no additional
investment cost for conversion from one preservative treatment process to
another.
h. Ifenta provides better protection than alternatives and is more versatile
than other wood preservatives.
i. Ihe substitution of other alternatives (e.g., Cu-8 and tetra, Cu-8)
would increase cost slightly, but these alternatives may not provide
adequate protection as that of Na-penta for sapstain control.
j. Hawever, the 1BTO will only provide protection for above ground use when
painted and the water-based Cu-8 product does not have the field use
experience as that of penta tor all exposure situations.
k. There are no chemical alternatives that are registered for this use of
penta, but the comparative efficacy between penta-treated and untreated
particleboard or chemioxJv treating the finish particieboard once in
service is unavailable.
542
-------
TABLE 111-40 long-term Impacts of Cancelling Vvbcd Rreservatives
Use Category
Extent
Economic Bnpact
Significance
1. Railroad ties
a. Cancel Creosote
b. Cancel Ifenta
c. Cancel Creosote
and fenta
2. Lumber, timber,
and plywood
a. Cancel Inorganic
Arsenicals
b. Cancel Penta
c. Cancel Creosote
d. Cancel Inorganic
Arsenicals and Psnta
e. Cancel Inorganic
Arsenicals and
Creosote
f. Cancel Ifenta and
Creosote
g. Cancel Inorganic
Arsenicals, Ifenta,
and Creosote
3. Pilings
a. Cancel Creosote
additional average annual
cost of $40.5 million
little or no impact
additional average annual
cost of $2.4 billion
to $0.74 billion
significant losses, penta
and creosote are not alter-
natives for most uses
additional cost of
$18 million for preser-
vatives and capital
investment
additional cost of
$39 million
significant losses,
creosote would not be
a substitute in most
uses
significant losses, penta
is not a substitute for
most uses
additional cost of
$5.2 million
significant losses,
substitution of
non-wood materials
were possible
additional cost of
$9 million to $10
million
manor
minor
major
major
major
b
minor
major
major
moderate
major
major
543
-------
TABLE 111-40 long-lem Mpacts of Cancelling Wood Preservatives (continued)
Use Category
Extent
Economic Impact
Significance
3. Pilings (continued)
b. Cancel Panta
c. Cancel Inorganic
Arsenicals
d. Cancel Creosote
and Panta
e. Cancel Creosote and
Inorganic Arsenicals
f. Cancel Penta and
Inorganic Arsenicals
g. Cancel Inorganic
Arsenicals, Panta,
and Creosote
4. Posts
a. Cancel Penta
b. Cancel Creosote
c. Cancel Inorganic
Arsenicals
d. Cancel Panta and
Creosote
e. Cancel Panta and
Inorganic Arsenicals
additional cost of
$8.3 million to $9.0
million
small impact, creosote
would substitute for
inorganic arsenicals
additional ,
cost of $8 million
significant losses, 4.3
million cubic feet of
marine pilings vould
be replaced with concrete
or steel pilings
additional cost of
greater than $9 million
additional average annual
cost of $64.5 million to
$129.1 million
additional cost of
$0.75 million to
$5.1 million
additional cost of
$3.3 million
additional cost of
$4.0 million to
$4.5 million
additional cost ol
$383,000
additional cost of
greater than $5.1
million
major
minor
major
major
major
moderate
moderate
moderate
minor
moderate
545
-------
TABLE 111-40 Long-lean Impacts of Cancelling Waod Preservatives (continued)
Use Category
Economic Impact
Extent
Significance
4. Posts (continued)
f. Cancel Creosote and
Inorganic Arsenicals
g. Cancel Inorganic
Arsenicals, fenta,
and Creosote
5. Crossarms
a. Cancel ftmta
b. Cancel Creosote
c. Cancel Inorganic
Arsenicals
d. Cancel ffenta and
Creosote
e. Cancel Ifenta and
Inorganic Arsenicals
t. Cancel Creosote and
Inorganic Arsenicals
g. Cancel Inorganic
Arsenicals, lenta,
and Creosote
6. Eoles
a. Cancel Efcnta
b. Cancel Creosote
c. Cancel Inorganic
Arsenicals
additional cost of major
greater than $7 million
significant losses, major
substitution of steel
fence post were possible
decline in cost of $0.23 minor to
million to an additional moderate
cost of $1.2 million
decline in cost of, minor
$15,000 to $30,000
anall additional cost f minor
to alternate preservatives
anall decline in cost minor
additional cost of moderate
$1.2 million
decline in costf minor
of $0.2 million
significant losses, major
substitution of non-wood
materials (e.g., steel)
were possible
decline in the average annual major"
cost of $43.6 million to an
additional cost of $32.8 million
c
decline in the average annual major"
cost of $43.6 million to an
additional cost of $17.8 million
additional average annual cost major
of $17.8 million to $32.8 million
546
-------
TABLE 111-40 Long-lem Impacts of Cancelling Vtood Rreservatives (continued)
Ufee Category
Economic Impact
Be tent
Significance
6. Ibles (continued)
d. Cancel lenta and
Creosote
e. Cancel lenta and
Inorganic Arsenicals
f. Cancel Creosote and
Inorganic Arsenicals
g. Cancel Inorganic
Arsenicals, Eenta,
and Creosote
7. foles-Groundline
a. Cancel Creosote
b. Cancel lenta
c. Cancel Creosote
and Penta
8. Hone and farm
a. Cancel Creosote
b. Cancel lenta
c. Cancel Creosote
and Bsnta
9. Sapstain control
Cancel hfc-penta
10. Millvork and pylwood
Cancel lenta
decline in the average annual
cost of $43.6 million
additional average annual
cost of $32.8 million
additional average annual
cost of $17.8 million
additional average annual
cost of $1.3 billion to
$2.06 billion
small impact, substitution
of penta
small impact, substitution
of creosote
additional average annual
cost of $35.3 million to
$70 million
slight additional cost
for preservative
slight additional cost
for alternatives
slight additional cost
for alternatives
cost and efficacy of
Na-tetra is equal to
that of te-penta
slight additional cost
for alternatives
. g
major
major
major
major
minor
minor
major
minor
h
minor
minor
minor
minorJ
547
-------
TABI£ 111-40 long-lerm Mpacts of Cancelling Wbod ftreservatives (continued)
Economic Impact
Use Category Extent Significance
11. Particleboard
j^
Cancel lenta $35,000 loss in minor
revenues
a. Both creosote and penta are cancelled and shifted to a copper naphthenate
or concrete tie system.
b. tbout 700,000 cubic feet of industrial block flooring cannot be treated
with penta and/or inorganic arrsenicals.
c. About 700,000 cubic feet of industrial block flooring and 4,258 cubic feet
of transportation lumber that is currently treated with creosote cannot
be treated with inorganic arsenicals.
d. Lhder this scenario, the high cost increase for equipment changes is
largely offset by the lower cost of inorganic arsenical-treated pilings.
e. Ihe cancellation of both penta and the inorganic arsenicals results in an
economic impact similar to that of cancelling either penta or the inorganic
arsenicals singly due to the high usage of creosote-treated pilings.
f. Economic impacts are only for current preservative prices and no additional
investment cost for conversion from one preservative treatment process to
another.
g. Even though there is a long-term decline in the average annual cost of
$43.6 million for the users of treated wood poles, the short-term (e.g.,
first year) impact to the applicators is major (an increase cost from
$9.4 million to $28.0 million) for additional capital investment for
conversion from one perservative treatment process to another.
h. ffenta provides better protection than alternatives and is more versatile
than other wood preservatives.
i. Ihe substitution of other alternatives (e.g., Cu-8 and tetra, Cu-8)
would increase cost slightly, but these alternatives may not provide
adequate protection as that of to-penta for sapstain control.
j. Hawever, the TBIO will only provide protection for above ground use when
painted and the water-based Cu-8 product does not have the field use
experience as that of penta for ail exposure situations.
k. Ihere are no chemical alternatives that are registered for this use of
penta, but the comparative efficacy between penta-treated and untreated
particleboard or chemically treating the finish particleboard once in
service is unavailable.
548
-------
Penta is the major wood preservative used for the treatment of
crossarms. Each of the three major wood preservatives is
satisfactory for this use and long-term impacts are not pro-
jected as long as one of the major wood preservatives is
available. If penta were cancelled, major conversion impacts
could be experienced. If all three wood preservatives were
cancelled, there would be adverse impacts cfue to the use of
higher cost of steel crossarms, and there would be adverse
impacts dut to the associated conversion costs for treating
other wood products (e.g., poles, pilings, etc.) with other wood
preservatives.
All three wood preservatives are used for the treatment of poles
and each could substitute for the other for this use. There are
few long-term impacts expected from the cancellation of one or
two of these chemicals. There are, however, significant short-
term adjustment impacts which would be associated with the
conversion from one preservative treatment process to another.
If all three wood preservatives were cancelled, there would be
major impacts resulting from the forced conversion by pole users
to alternate materials (e.g., steel and concrete).
3. Non-pressure Treatments
The cancellation of penta and/or creosote for non-pressure appli-
cations (e.g., home and farm, millwork and plywood, and sapstain
control uses) would generally result in the substitution of
alternate wood preservatives at substantially higher cost to the
549
-------
applicator. Also, most of the alternatives can only be
considered partial substitutes, specifically for penta.
Continuation of poles-groundline treatment is dependent upon
the availability of either creosote or penta. If one of these
preservatives is unavailable, it will be replaced by the other
for this use. Cancelling both creosote and penta for poles-
groundline treatment would result in a shorter useful service
life of the poles; requiring more frequent replacements of
treated poles and increasing the average installed cost for
distribution poles between $77.8 million to $156 million
annually at current prices beginning 5 and 10 years after poles-
groundline cancellation, respectively.
The alternative wood preservatives for home and farm use are
limited to specific conditions of end-use of the treated wood
product. Penta can replace creosote, but creosote can be
considered only a partial substitute for penta. Penta is unique
in its ability to leave a clear finish on wood and provide ex-
cellent protection for the wood used aboveground and limited
protection below ground. Two of the alternatives (e.g., TBTO
and zinc naphthenate) provide a clear, paintable surface, but do
not afford the protection that penta does.
Cancelling Na-penta for sapstain control would result in serious
economic losses to the lumber industry without the use of alter-
native preservatives. If Na-penta were cancelled for sapstain
control, many applicators would most likely switch to Na-tetra
550
-------
which is equally efficacious and of equal cost. Although
effective, TCP is more costly for a registrant to formulate and,
therefore, its use by applicators may only increase slightly.
Another possible alternative for sapstain control is Cu-8,
although Cu-8's performance under extreme conditions is not
believed to be adequate. There would be minor changes in treat-
ment cost if an applicator switches from Na-penta to one of the
above chemical alternatives for sapstain control.
Millwork and plywood require a wood preservative that is
colorless, compatible with paints, stains, sealers and primers,
and does not interfere with the adhesion of glazing compounds
(e.g., caulkings or other sealants). The alternatives do
provide protection for millwork under most conditions, but they
do not equal the protection provided by penta.
If penta were cancelled for millwork and plywood treatments,
applicators would most likely switch to a 0.75% TBTO solution
which is similar in cost to penta and has shown effectiveness
for aboveground exposure when painted, but not for below ground
exposure. It the water-based Cu-8 solution proves its effective-
ness, many applicators would switch from penta to Cu-8.
There are no chemical alternatives for penta used in the
manufacturing of treated particleboard. The quantity of treated
particleboard produced is small and the economic losses would be
small, but a unique product would no longer be available if
penta were cancelled for this use.
551
-------
iV. DEVELOPMENT OF REGULATORY OPTIONS
A. Introduction
In Parts 11 and 111, the Agency identified the risks and bene-
fits of the uses of the wood preservatives under review. As
explained in Part 1, FIFRA requires the Agency to determine if
the use of a pesticide meets the statutory standard for regist-
ration by balancing the risks and the benefits of use. To carry
out this mandate, the Agency has developed a range of regulatory
measures which are intended to reduce the risks of use for the
pesticides under review. This Part discusses the factors which
have been taken into account in developing the regulatory
options for the wood preservatives and describes in detail those
measures selected tor further consideration in Part V.
B. Basis and Rationale for Developing Options and Modifications
There are chree basic options tor regulating all pesticides:
Option 1 - Continuation of Registration without changes
Option 2 - Continuation of Registration with Modifications to
the Terms and Conditions of Registration
Option 3 - Cancellation of registration
The two extreme options, Option 1, Continuation of Registration
without change and Option 3, Cancellation of registration, are
at the opposite ends of the risk/benefit spectrum. Adoption of
553
-------
Option 1 would be appropriate when the Agency has concluded that
the level of risk is acceptable in light ol the pesticide's
benefits and that further risK reduction measures are not
necessary to assure that the use ot the pesticide meets the
statutory standard for continued registration.
Adoption of Option 3, Cancellation, would be appropriate when
the Agency has concluded that the risks from a use outweigh the
benefits of that use, and that these risks cannot be mitigated
to an acceptable level, in light of the benefits, by any other
measures short ot cancellation. Cancellation prohibits the sale
or the distribution of a pesticide for a particular use or
uses. The effect ol cancellation is to entirely eliminate the
risks of a pesticide's use or uses as well as the benefits.
Cancellation may atfecc all uses of a compound, or it may affect
only specific uses (such as, for example, railroad ties, or
posts, or sapstain control), or specific formulations (for
instance powders, liquids, or high concentrations), or specific
application methods (for instance, spray, dip, or brush-on).
Ihe middle option, Option 2, is appropriate when the risks of
a pesticide use can be reduced to an acceptable level, while
preserving the benefits of the use. This risk reduction is
accomplished by modifying the terms and conditions of the
pesticide's registration. These modifications, which are
expressed through the pesticide's labeling are, for the most
part, changes in the way the pesticide is used. These changes
554
-------
are designed to reduce exposure to the pesticide, and thereby
reduce or even eliminate the risk from the pesticide.
C. Discussion of Option 2, Modifications to the Terms and
Conditions of Registration
Various considerations were involved in the selection process
for the Option 2 modifications, namely the effectiveness of the
measures in reducing exposure, the practicality and enforce-
ability of the measures, and the cost impact of their implement-
ation. A number of measures were considered but rejected on the
grounds of limited risk reduction capability, technical
infeasiBility, unenforceability, lack of statutory authority or
impracticality. Appendix 2 lists possible modifications which
Were rejected from further consideration for the reasons given
above.
The specific risk reducing modifications which the Agency has
selected for further consideration are presented in the fol-
lowing section. For each modification, the discussion focuses
on 1) the objective which the modification would accomplish,
2) the specific preservatives and uses to which the modifica-
tion pertains, 3) the particular risks to affected populations
which would be reduced, and 4) the practicality of the
modification.
555
-------
a. Require Protective Clothing: Gloves
This modification would require applicators to wear gloves made
of material resistant to the wood preservative while handling
treated wood. Gloves would also be required when mixing the
wood preservative, and when cleaning and maintaining treatment
equipment, such as pressure cylinders, spray-boxes, soak tanks,
and other equipment in industrial situations. Applicators would
also wear gloves when cleaning equipment, such as brushes. This
protective clothing modification would apply to all use cate-
gories and all applicators. When handling treated lumber or
applying the preservative solutions, the primary site of dermal
exposure is the hands. Although adequate experimental data are
not available on the permeability of gloves to these wood preser-
vatives, the Agency estimates that appropriate gloves will
reduce dermal exposure through the hands by 99% in most situa-
tions. This reduction assumes no pesticide penetration through
the gloves, and a small possibility of some exposure around the
cuff (Kozak, 1980) .
Also, during the mixing of inorganic arsenicals and sodium penta
powder or prilled (penta) formulations, gloves would provide
some reduction of total dermal exposure. The reduction in
dermal exposure, based on the reduction of skin area available
to absorb the pesticide, is about 30% (Kozak, 1980).
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b. Require Protective Clothing: Coveralls
This modification would require applicators who manually empty
bags or mix powder formulations to wear disposable coveralls
(e.g., nitrile or polyethylene) or similar protective clothing
during emptying and mixing operations. Since creosote is not
formulated as a powder, this modification would apply only to
powder formulations of the inorganic arsenical compounds and to
prilled penta and prilled or powder sodium penta. Furthermore,
since such powder formulations are used only in industrial
situations, this modification would apply only to commercial
uses of these wood preservatives.
Commercial applicators would also be required to wear disposable
coveralls during brush-on applications of these pesticides. Home-
owners would be required to wear tightly-woven long sleeved
cotton coveralls during brush-on applications of these pesti-
cides since the homeowners will not have easy access to
disposable coveralls.
This modification would reduce applicators' dermal exposure to
wood preservative dust. The protected areas would be the fore-
arms, neck, and chest. If uncovered skin areas were protected
during these operations (including skin covered by gloves),
reduction in total dermal exposure would be about 80%, based on
the reduced skin area available to absorb the pesticide (Kozak,
1980).
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c. Require Protective Clothing: Neoprene Suit and Respirators
This modification would require that applicators or other per-
sonnel manually cleaning or entering treatment cylinders and
vats, and applicators performing other high exposure tasks wear
neoprene-coated cotton or rubberized overall, jacket, gloves and
boots, and a respirator. For some situations, only the
respirator and gloves would be proposed, since the exposure
involved is not sufficently large to require complete isolation
from the environment. This equipment would, in effect, almost
completely isolate the wearers from an environment where high
exposure can occur.
Proper use of respirators and this type of protective clothing
would be expected to reduce the high dermal and inhalation expo-
sure during the maintenance (e.g., cleaning or repairing) of
treatment equipment, during specific commercial applications
(e.g., spraying of solutions and mixing powder formulations) and
while opening treatment cylinder doors. The use of a rubberized
protective suit consisting of an overall, jacket, gloves and
boots would be expected to reduce potential dermal exposure to
solutions by about 80%, based on the reduced skin area available
to absorb the pesticide. The use of a half-mask canister or
cartridge respirator capable of trapping pesticide particulates
and vapors would reduce potential inhalation exposure by about
90% (Kozak, 1980). Most treatment plants already recommend that
protective clothing and respirators be worn during the mainten-
ance and cleaning of treatment equipment. However, most labels
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do not currently state that protective clothing and equipment
should be used during these operations.
d. Require Protective Clothing: Dust Masks
Ihis moditication would require cipplicacors or other personnel
working outdoors in treatment plants which use the inorganic
arsenical v,ood preservatives to wear a dust mask.
The air concentrations of arsenic are about the same throughout
treatment plants (the only exceptions are in those areas for
which a respirator will be required; see modification 2.c).
This moditication would reduce the inhalation exposure by about
80% tor workers in these industrial situations (Kozak, 1980).
e. Require Cart- of Protective Clothing
This modification would require that applicators and other per-
sonnel leave all protective clothing and equipment (e.g. respira-
tors) as discussed in modifications a through d, at the treat-
ment plant at the end of the worxday. This modification would
also require that work shoes be left at the treatment plant and
that worn out protective clothing be disposed oi by tollov,ing
pesticide container disposal. This modification would apply to
all industrial uses of all three wood preservatives.
If adopted, this modification would greatly reduce or eliminate
a source ot wood preservative exposure in treatment plant
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workers' homes. The exposure to the workers would be reduced to
some extent, and the exposure to the workers' families would be
nearly eliminated. Leaving protective clothing and equipment at
the treatment plant is already an accepted good work practice.
At those treatment plants surveyed, 75% of the workers' work
shoes are already left at the treatment plant on a required or
voluntary basis (Mitre, 1980).
f. Prohibit Eating, Drinking and Smoking During Application
This modification would require that applicators and other
personnel not eat, arink or smoke in the treatment area. It
would also prohibit home and commercial applicators from eating,
drinking or smoking when they are applying these wood preserva-
tives. This modification would apply to all use categories of
all three wood preservatives. If adopted, this modification
would reduce treatment plant workers' and other professional
treaters1 oral exposure to the wood preservatives and would
greatly reduce the opportunity for accidental ingestion of these
pesticides by homeowners.
Many treatment facilities already have designated eating areas.
This amendment is considered to be a standard good work practice
for all plants working with chemicals and is noted, for example,
in the Occupational Safety and Health Standards, 29 CFR
1910.141(g). In addition, it is a standard practice in pesti-
cide labeling to caution against eating, drinking, or smoking
during pesticide application.
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g. Confine Emptying Bags and Mixing of Powder and Prilled
Formulations to Closed Systems.
This modification would reduce air levels of the powder or
prilled formulations by requiring any of numerous technologies
to be used during mixing and emptying of bags or other con-
tainers. In an example of a closed system, powder formulations
are unloaded by pneumatic systems from a hopper truck or rail-
road car directly into the dissolving tank/ which is also a
closed system. This type of system greatly reduces applicators'
exposure. However, in a number of small wood treatment plants,
the applicators open and empty prilled formulations of penta,
prilled and/or powder formulations of sodium penta or, powder
formulations of inorganic arsenicals by hand into the dissolving
'tanks. This open system of handling these formulations poses a
high degree of dermal and inhalation exposure to the applicator.
This modification would limit the amount of airborne pesticide
powder in the mixing room, by one or more of several methods,
and thereby reduce the applicators' exposure. The modification,
if adopted, would affect only prilled and powder formulations
of penta and sodium penta and the inorganic arsenical compounds
for use in industrial situations. (As noted there are no creo-
sote powder formulations.)
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h. Classify for Restricted Use
This modification would restrict all the wood preservative
compounds of concern to use by certified applicators only.
Under F1FRA, hazardous pesticides may be classified for re-
stricted use and be limited to use only by or under the direct
supervision of certified applicators. To become certified, the
applicators must enroll in a certification program, which
teaches the safe use of restricted use pesticides. Upon comple-
tion of these programs, the applicators are certified for a
particular restricted use pesticide or pesticides.
Classification for restricted use would ensure that the wood
preservatives would be available only for use by or under the
direct supervision of t cined applicators. By preventing
untrained or unsupervised applicators from using these pesti-
cides, the risk of human exposure due to misuse or carelessness
would be significantly reduced. The classification of the wood
preservatives as restricted use pesticides would not impose an
undue burden since there are already many certified applicators
and there is relatively little difficulty in obtaining
applicator certification.
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i. Restrict Application of Wood Preservatives to Outdoors and
the Application of Wood Preservatives to Wood Destined for
Interior Uses.
This modification would restrict the use of the wood preser-
vatives to outdoor situations and would restrict the application
of these products to wood destined for specific interior uses.
Outdoor application is defined in FIFRA as any pesticide
application or use that occurs outside enclosed man-made
structures or the consequences of which extend beyond enclosed
man-made structures.
Adoption of this modification would eliminate the applicator's
inhalation exposure during applications of the preservative in
enclosed structures. This modification would also eliminate the
inhalation exposure for those people who build enclosed
structures with treated wood or those individuals who live in
enclosed structures made of treated wood.
j. Prohibit Uses Likely to Result in Direct Exposure to
Domestic Animals or Livestock on in the Contamination of
Food, Feed, or Potable Water
This modification would prohibit the applicator from using any
of the wood preservatives in a manner which is likely to result
in direct exposure to domestic animals or livestock or in the
contamination of food, feed, or potable water. Such sites
include, but are not limited to, vegetable and fruit stakes,
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mushroom flats, feed lot bins, watering and feed troughs, seeo
flats, animal bedding and pens, irrigation flumes, food con-
tainer and similar items. This modification would apply to all
three wood preservatives for all use categories.
Wood preservative residues in food arise from both wood and non-
wood uses of these compounds. It is not known how much each
use contributes to the dietary burden. However, the exposure to
the general population would be reduced if these wood uses were
prohibited.
k. Reduce Arsenic Surface Residues on Treated Wood
This modification would require applicators to use work prac-
tices or technologies which will reduce the arsenic surface
residues on wood treated with the inorganic arsenical compounds.
The modification was developed to deal with the concern that the
inorganic arsenical wood preservatives can be absorbed through
the skin and inhaled as dust or vapors from treated wood. It is
intended to reduce the dermal and inhalation exposure for treat-
ment plant applicators and workers in industrial situations. It
would also reduce the dermal and inhalation exposure to people
who use treated wood for construction purposes; moreover it
would reduce the exposure to the general population from treated
wooden structures such as park benches, playground equipment,
picnic tables, and similar outdoor wooden structures.
-------
There are two stages during the application process when solvent
evaporation can result in arsenic surface residues on the
treated wood. The first begins when the wood is removed from
the treating cylinder and is still covered by a film of preser-
vative solution. The second occurs after the surface film is
dried. From the limited data available, at least several
factors appear to be of critical importance in affecting the
quantity of residues deposited on the surface of treated wood.
These factors include wood surface conditions, fixation con-
ditions, and draining mechanisms.
Although there is no standardized methodology for sampling the
surface residues on arsenically treated wood, there are several
reported process control technologies available to the applica-
tors for reducing the amount of arsenic surface residues on
treated wood. These technologies include starting with clean
wood, maintaining clean treatment facilities, and draining
excess treating solutions from the wood after treatment. Some
specific control technologies capable of lowering the arsenic
surface residues on treated wood are improved purity of copper
in the treatment solutions, filtration of treatment solutions
prior to use in the treatment cylinders, pH control of treatment
solutions, an additional vacuum stage in the treatment process,
sheds or other covers to protect the freshly treated wood from
rainfall (allowing the preservative to become "fixed" in the
wood), and post-treatment washing of each piece of treated wood
(Mitre, 1980a).
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Each of these control technologies has been used in at least one
wood treatment plant. The only widely used control technology
is filtration of the treatment solution. Although the reduction
in arsenic residues achieved by the use of these technologies
cannot be accurately quantified until a standardized sampling
method becomes available, the Agency believes that significant
reduction in residues will result from implementation of these
specific technological measures during the application process.
1. Reduce Contaminants in Penta
This modification would reduce the level of the hexachloro-
dibenzo-p-dioxin (HxCDD) contaminant in all penta products.
The HxCDD contaminant, which has been shown to be teratogenic
and oncogenic in test animals, is formed in technical penta and
sodium penta during the manufacturing process.
Although most technical penta products on the market contain
about 15 ppm HxCDD, technical penta can be produced with as
little as 1 ppm HxCDD (e.g., Dowicide EC-7). To reduce this
source of exposure to the HxCDD contaminant in penta and sodium
penta, the Agency will consider requiring that technical penta
and sodium penta contain no more than 1 ppm HxCDD. By lowering
the amount of HxCDD in technical penta and sodium penta, the
exposure to HxCDD in all situtions would be reduced to about one-
fifteenth of the present exposure. This reduction in exposure
would reduce the risk by about one-fifteenth of the present
risk.
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A registered product, Dowicide EC-7, made by Dow Chemical Co.,
has lower dioxin contaminants than other registered technical
grade penta products on the market. Dioxin levels were reduced
in this product through alterations in the manufacturing
process. Other companies could also presumably develop
manufacturing processes to lower the level of dioxin
contaminants in their products. The requirement for this
reduction in contaminant level may, however, cause these
companies to cease the manufacture of penta because of cost
considerations.
D. Other Relevant Statutory Measures
A number of other statutes, either administered by EPA or other
agencies, have a bearing on the regulation of the wood
preservative agents. The relevant statutes and the authority
they confer on wood preservative regulation are briefly
discussed below.
1. Occupational Safety and Health Act
Under the authority of The Occupational Safety and Health Act,
the Occupational Safety and Health Administration (OSHA) is
responsible for promulgating and enforcing standards which will
assure the occupational safety and health of employees. OSHA
has stated that it will defer to this Agency's workplace
regulation of the use and impregnation/application of wood
preservatives (Whiting, 1979). This deferral will continue as
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long as OSHA has full assurance from this Agency of an active
program to investigate any public or occupational health risks
from these wood preservatives and full assurances that
regulatory action to eliminate any significant risks also will
be forthcoming from this Agency.
2. Toxic Substances Control Act
The Agency expects to propose certain regulatory measures con-
cerning the use and handling of treated wood products under the
authority of the Toxic Substances Control Act (TSCA). Cur-
rently, under the regulations issued pursuant to FIFRA, the
Agency does not regulate end-use products, such as treated wood,
where no pesticidal claims are made for the treated item itself.
TSCA, however, has the authority to fill the regulatory gap and
provide measures to regulate end-use products which contain a
pesticide but which are not themselves pesticides.
Accordingly, the Agency is proceeding to implement regulations
under TSCA to meet the Agency's concerns about exposure to and
the effects of preservative-treated wood products. The Agency
intends to request that the wood treatment industry and
retailers of treated wood comply voluntarily with the proposed
labeling measures which will require TSCA rulemaking. Concur-
rently, the Agency intends to initiate proposed rulemaking
pursuant to Section 6 of the Toxic Substances Control Act (TSCA)
to require adoption of these label measures.
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To regulate under Section 6 of TSCA, the Agency must make a
finding that there is a reasonable basis to conclude that the
manufacturing, processing, distribution in commerce, use or
disposal of a chemcial substance or mixture, or any combination
of such activities, presents or will present an unreasonable
risk of injury to health or the environment.
TCSA Section 6(a)(3) provides that the Agency can require that
the products "be marked with or accompanied by clear and adequ-
ate warnings and instructions with respect to its use, distri-
bution in commerce, or disposal or with respect to any combina-
tion of these activities." TSCA Section 6(a) (2) provides that
the Agency can prohibit the processing or distribution in com-
merce of the product for a particular use. TSCA Section 6(a)(5)
provides that the Agency can prohibit or otherwise regulate any
manner or method of disposal of the product "by its manufac-
turer, processor, or by any other person who uses or disposes of
it for commercial purposes." Under a combination of these
authorities and methods, the Agency could accomplish the
controls it believes are necessary to protect users of these
treated products and the public at large.
At this time, the Agency anticipates that it will be able to
make the findings necessary for the issuance of labeling
information for preservative-treated wood products under Section
6 of TSCA and will be proposing a rule pursuant to TSCA. Such a
rule would meet the purpose of TSCA by filling the gap in
regulation of wood preservatives under FIFRA and allow treated
569
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wood products to be sold with adequate use information. This
approach is consistent with the Agency's concern tor regulatory
flexibility and would preserve the benefits of wood preserva-
tives while protecting the public health from the adverse
effects of preservative-treated products. These TSCA precau-
tionary labels, which would be distributed to the end-users of
the treated, wood would recommend that: 1) All individuals who
handle pesticide-treated wood wear gloves impe-vious to the wood
preservatives, 2) Individuals who saw pesticide treated wood
wear disposable coveralls, 3) Individuals who saw pesticide-
treated wood and fabricate structures with treated wood wear a
dust mask, 4) Treated wood can be used indoors for specific
uses, 5) Treated wood not be used in a manner which may result
in direct exposure to animals or in the contamination of food,
feed, or water, and 6) Treated wood be disposed of by methods,
such as on-site burial, which are in accordance with local and
state laws, and the Resource Conservation and Recovery Act,
rather than by burning.
3. Consumer Product Safety Act
Under the authority of the Consumer Product Safety Act, the
Consumer Product Safety Commission (CPSC) has some regulatory
jurisdiction pertaining to the consumer use of wood treated with
pesticides; the CPSC, however, has not issued any pertinent
regulations to date. If the CPSC promulgates regulations
covering the wood treated with pesticides, TSCA will be pre-
570
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empted to the extent that the CPSC takes sufficient action to
protect against the risk of concern.
4. Resource Conservation and Recovery Act
EPA also has authority under the Resource Conservation and
Recovery Act of 1976 (RCRA) to control the disposal of preser-
vative-treated wood products if the Agency determines that these
wastes may pose a substantial hazard to human health and the
environment, if improperly managed. Under Subtitle C of RCRA, a
"cradle to 'grave" regulatory scheme for the management of
hazardous waste is to be set-up.
According to the hazardous waste regulations promulgated on
May 19, 1980, botton sediment sludge from the treatment of
wastewaters resulting from creosote and/or pentachlorophenol
wood preserving processes has been identified as hazardous. In
addition, wastes which contain arsenical compounds may be
hazardous if these wastes fail the EP toxicity characteristic
test (see 40 CFR 261.24 for details). RCRA regulations specify
general standards and procedures for the handling of hazardous
waste; for the wood preservatives these wastes are generated
from such sources as the manufacture of the wood preservatives,
the expended material used in the wood treatment process, and
the end-use of treated wood or wood products. Disposal for
wastes which are generated in excess of 1,000 kg per month or
wastes which accumulate in excess of 1000 kg over any time
*
period is regulated under Subtitle C of RCRA ; smaller quant-
571
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ities have been exempted. It is likely that the end-use of
these treated wood products will seldom exceed the 1,000 kg
small quantity exemption; thus, RCRA will not control these
wastes when generated in small quantities.
* On November 25, 1980, EPA temporarily excluded from RCRA
control arsenical-treated wood or wood products which are
generated by persons who utilize such treated wood or wood
products for the wood's intended end-use.
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V. REVIEW OF THE IMPACTS OF REGULATORY OPTIONS AND MODIFICATIONS
A. Introduction
In the previous parts of this document, the Agency evaluated the
risks and benefits of the wood preservatives (creosote, the inor-
ganic arsenical compounds, and penta) and considered the regula-
tory means by which the risks might be reduced. The purpose of
this part is to determine the most appropriate regulatory op-
tions and modifications for each use of the three wood preserva-
tives. To accomplish this, the human and environmental risks
of each use are compared with the benefits of the use. If this
comparison shows that there are unreasonable adverse effects to
man or the environment from current use patterns, various regu-
latory actions are developed to reduce the risks of those uses.
The Agency then evaluates the extent to which these regulatory
modifications will change the risks and benefits of each use.
Finally, by comparing the changes in the risks and benefits, the
Agency selects and proposes the most appropriate regulatory
measures for each use.
There are three basic options: Option 1, the Continuation of
Registration; Option 2, the Continuation of Registration with
Modifications to the Terms and Conditions of Registration; and
Option 3, Cancellation. If the Agency determines that a use of
a wood preservative does not pose unreasonable adverse effects
to man or the environment, then Option 1, the Continuation of
Registration, will be the selected option for that use. If the
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Agency determines that a use does cause unreasonable adverse
effects in man or the environment, then the risk and benefit
impacts of various modifications to the terms and conditions of
registration will be considered. if the modifications singly,
or in combination, do reduce the risks of a use to an acceptable
level, then Option 2, the Continuation of Registration with
Modifications to the Terms and Conditions of Registration, will
be the selected option for that use. If these modifications,
which are intended to reduce the risk of a pesticide's use while
preserving benefits, do not reduce the risks to an acceptable
level, then Option 3, Cancellation, will be the selected option
for that use.
The pressure and non-pressure uses for which the wood is treated
at treatment plants (i.e., railroad ties, lumber, timber and ply-
wood, pilings, posts, crossarms, poles, sapstain control, mill-
work and plywood, and particleboard) will be grouped together in
*
the discussions of risks, benefits , and regulatory options.
The risks, benefits, and regulatory options will then be dis-
cussed with regard to those uses for which the pesticides are
applied outside of the treatment plant (i.e., poles-groundline,
home and farm, and brush-on applications of the inorganic
arsenicals) and finally, those uses of the wood after it is
treated and has left the plant.
* A use-by-use summary of the benefits is provided for the wood
treated at plants.
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For each use, or group of uses, this document will 1) summarize
the risks of each pesticide (discussed at length in Part II), 2)
summarize the benefits of each pesticide (developed at length in
Part III), 3) consider the appropriate option by weighing the
risks against the benefits for the use, including the impact of
possible modifications to the terms and conditions of registra-
tion and, as a result of this analysis, 4) select the appropri-
ate option (i.e., the Continuation of Registration, Modification
to the Terms and Conditions of Registration, or Cancellation).
If cancellation or continued registration without changes is not
the selected option, the appropriate modifications to the terms
and conditions of registration will be selected. Section V.E of
this Part summarizes the Agency's selected options.
B. Use Categories: Pesticides Applied At Pressure and Non-
Pressure Treatment Plants
All of the wood products in the use categories discussed in this
section are treated at treatment plants. Railroad ties, lumber,
timber and plywood, pilings, posts, crossarms, and poles are
treated with pressure; sapstain control, millwork and plywood,
and particleboard do not require pressure for treatment. The
equipment for each type of treatment process is similar; pres-
sure treatment processes employ pressure cylinders to apply and
treat the wood with creosote, inorganic arsenicals and/or penta,
while non-pressure treatment processes utilize primarily penta
or sodium penta in open vats or spray operations for treatment.
Therefore, for each specific activity in the treatment process
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with a particular pesticide, the risks to the applicator remain
unchanged regardless of the end-use for which the wood is being
treated. For example, an applicator opening a door of a
cylinder containing creosote has the same health risk whether
the wood being treated in that cylinder will be used as railroad
ties, poles, fence posts, and/or other wood products. There-
fore, to avoid repetition, the risks to a treatment plant worker
will be grouped by treatment plant activities and by each chemi-
cal, rather than discussed on a use-by-use basis.
1. Summary of Risks
About 9,000 to 13,000 workers (10-50 per plant) are involved
in the pressure treatment of wood using the three wood preser-
vatives for the following uses: railroad ties, lumber, timber
and plywood, pilings, posts, crossarms and poles. The number of
workers applying creosote is about 4,000 to 1,400; about 1,400
to 2,000 workers are engaged in applying the inorganic arseni-
cals, and about 4,000 to 5,000 workers apply penta. The uses
requiring the non-pressure treatment of wood involve the fol-
lowing work force in the treatment plant: sapstain control with
sodium penta, about 20,000 workers (10 per plant); millwork and
plywood with penta, 7,000 to 10,000 workers (3-5 per plant); and
particleboard with penta, about 10 workers (only 1 plant
involved).
All of these workers perform some aspect ot pesticide applica-
tion at these plants during the work day. For example, during
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the pressure treatment of wood with penta, one worker might be
mixing the pesticide, while another might be removing the
treated wood from a pressure cylinder. Each of these pesticide
application activities is generally performed by 2 co 4 worKers.
Therefore, the Agency will consider all workers associated with
the treatment process to be applicators regardless of their
individual activities during the work day.
As discussed in Part II of this document, the Agency has esti-
mated the risks to which the workers would be subjected during
their individual activities in the treatment plant. The in-
dividual applicators receive a fixed level of exposure regard-
less of the final use of the treated wood.
The treatment plant activities where potential exists tor high
risk include entering pressure cylinders, opening cylinder doors
following treatment, and emptying bags and mixing powder or
prilled formulations. The other generalized treatment plant
activities which have been considered in evaluating the risks of
these pesticides include exposure to background (ambient) air
levels in the plants, handling treated wood, and specific
spraying and dipping processes. While the individual activities
are similar for the three preservatives, the risks associated
with the use of the individual preservatives in these situations
vary both in the nature and in the magnitude of the health
effects.
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In terras of comparative risks from the application of these
chemicals in the treatment plants, penta has a lower fetotoxlc
margin of safety than the inorganic arsenicals, while the inor-
ganic arsenicals have greater oncogenic risks than penta for the
treatment plant activities. While creosote poses an oncogenic
risk, the magnitude of this risk has not been quantified due to
a lack of data, and hence no direct comparison between creosote
and the other two wood preservatives can be made. However, the
Agency has no information to indicate that the risks from expo-
sure to creosote are less than the risks from penta or inorganic
arsenical exposure. All of the wood preservatives pose high
risks for treatment plant applicators under current labeling and
use patterns. Discussion, by chemical, of the specific expo-
sure situations and their associated risks follows.
a. Creosote
As discussed in Sections II.B.5 and II.B.6, creosote poses onco-
genic and mutagenic risks to humans. These risks have not been
quantified since there are very little data available regarding
treatment plant workers' exposure to all of the specific onco-
genic or mutagenic components of creosote. However, the large
number of animal studies, supported by the human case studies,
indicate that a finite risk to treatment plant workers exists.
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i. Background Creosote Air Levels
The Agency has inadequate information regarding the total onco-
genic or mutagenic components of creosote in the ambient air to
which workers involved in the general operations around a plant
are exposed. Consequently, the risks resulting from this expo-
sure have not been quantified. However, the Agency does expect
these workers will generally be exposed to the more volatile,
lower molecular weight components of creosote.
ii. Bag Emptying
Because creosote is not prepared from a powder formulation,
discussion of this activity is not applicable with regard to
potential risk.
iii. Mixing Concentrated Solutions and Handling Diluted
Solutions
The Agency recognizes that much of the preparation of working
solutions of creosote by dilution from concentrated solutions is
performed automatically in mixing tanks. Because no exposure to
creosote is anticipated during this procedure, discussion of the
potential risk while mixing concentrated solutions and handling
diluted solutions is not applicable.
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iv. Opening Cylinder Door
Although the Agency has no quantitative data demonstrating that
workers involved in the opening of cylinder doors following
treatment are exposed to the oncogenic or the mutagenic compon-
ents of creosote, the Agency believes that there is exposure to
some finite amount of these components as explained in Section
II.B.4, and hence a resultant risk.
v. Handling Treated Wood
Treatment plant workers' dermal exposure to creosote occurs
during the manual handling of the wood that is still wet with
creosote treatment solution. While many plants have automated
or mechanical equipment to handle the freshly treated wood, some
may not have such equipment. Due to a lack of data, the Agency
is unable to determine the lifetime oncogenic risk to the hand-
lers of wood which has been freshly treated with creosote, but
believes that there is some degree of exposure and hence a
resultant risk.
vi. Entering the Cylinders
While entering a cylinder for manual cleaning or for any other
purpose (e.g., releasing a wood jam), the applicator may exper-
ience dermal exposure to the creosote treatment solution through
contact with unprotected areas of skin and through inhalation of
vapors. While the Agency cannot quantitatively estimate the
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exposure to the treatment plant worker resulting from this
activity because of a lack of data, the Agency believes that
there is some degree of risk.
b. inorganic Arsenical Compounds
The Agency has determined that wood treatment plant applicators
face serious health hazards as a result of exposure to the inor-
ganic arsenical compounds or arsenically treated wood. These
health hazards include oncogenic, teratogenic and fetotoxic ef-
fects. Mutagenic damage and possible delayed neurotoxic effects
from arsenic have been demonstrated; however, these effects have
not been quantitatively estimated. The risks to the treatment
plant workers, who are applying the inorganic arsenical pro-
ducts, result from dermal and inhalation exposure during several
pesticide application activities.
i. Background Arsenic Air Levels
The Agency has determined that the "time weighted average" of
the background (ambient) arsenic air levels in treatment plants
is 70 ug/m , which corresponds to 10 ug/kg/day inhalation expo-
sure. The inhalation exposure to dust containing arsenic is
greatly enhanced by the stacks of arsenicaiiy treated wood
drying in the treatment plant yards. Dust is produced when the
treatment solution leaches, dries, and flakes from the surface
of the drying stacks of freshly treated wood. Small particles
are inhaled as dust and are absorbed in the lung, while larger
581
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particles are ingested and are absorbed in the gastrointestinal
tract. Based on these air arsenic levels, the Agency estimates
that the teratogenic/fetotoxic margin of safety (MOS) is 500.
The total lifetime oncogenic risk from the background arsenic
air levels in the plant is estimated to be 1.9 x 10~ . Al-
though the Agency has not quantitatively estimated the treatment
plant workers' risk of mutagenic damage, the Agency believes
that the mutagenic risk potential is high.
ii. Bag Emptying
Treatment plant workers who empty bags containing inorganic
arsenical powder formulations in the preparation of the treat-
ment solutions contact arsenic dust via the skin. The amount of
inhaled arsenic-containg dust is also increased over background
levels as a result of this activity. The Agency assumes that
all ambient dust resulting from bag emptying will be respirable
and will reach the lungs, rather than the gastrointestinal
tract, due to the small particle size. The Agency estimates
that the total daily dose from this activity is 17 ug/kg/day,
resulting in a teratogenic/fetotoxic MOS of 294 and a lifetime
_ 2
oncogenic risk of 3.4 x 10 . This oncogenic risk is composed
of dermal and inhalation components. The risk of skin cancer to
an individual, which is primarily related to the dermal exposure
component, is estimated to be 6.0 x 10~ . The risk of lung
cancer to an individual is primarily related to a combination of
582
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background (ambient) arsenic dust in the plant and the dust
resulting from the bag emptying; this risk is estimated to be
2.8 x 10~2.
iii. Mixing Concentrated Solutions and Handling Diluted
Solutions
Treatment plant workers mixing concentrated (27%) inorganic
arsenical formulations are exposed to arsenic through dermal
contact with the concentrated solution and through inhalation
of the background air arsenic levels in the plant. The Agency
estimates that the combined inhalation and dermal dosage
yields a lifetime oncogenic risk of 1.17 x 10 and a terato-
genic/fetotoxic MOS of 135. The risk of skin cancer, which is
primarily related to the dermal exposure, is estimated to be
_ o
9.8 x 10 . The risk of lung cancer to an individual, which
is primarily related to the inhalation exposure, is estimated to
be 1.9 x 10"2.
The Agency has further determined that treatment plant appli-
cators are also exposed when handling the diluted treatment
solutions (1.7%). The estimated total risk of combined dermal
and inhalation exposure from contact with diluted formulations,
including background air arsenic level doses, yield a life-
_2
time oncogenic risk of 2.6 x 10 and a teratogenic/fetotoxic
MOS of 417. This oncogenic risk is composed of dermal and inha-
lation components. The risk of skin cancer to an individual,
which is primarily related to dermal exposure, is estimated to
583
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be 7.0 x 10~ . The risk ot lung cancer to an individual,
which is related to inhalation exposure, is estimated to be
1.9 x 10~2.
iv. Opening Cylinder Doors
Because inorganic arsencial formulations are water-based solu-
tions which do not typically produce vapors, the Agency has
determined that the air arsenic concentrations while opening the
cylinder door following treatment will not exceed the background
air arsenic dust levels of the plant. However, while the
cylinder door is being opened, it is possible to dermally con-
tact the treatment solutions that have splashed ana dried around
the cylinder door. In addition, immediately after the door is
opened, hooks are manually attached to the charge of wood for
its removal from the cylinder. During this operation, the appli-
cator dermaliy contacts the wet treatment solution. Due to a
lack of data, the Agency has not estimated the combined dermal
(diluted solution) and inhalation (background) exposure in this
situation, but believes that there is some degree of risk.
v. Handling Treated Wood
Treatment plant workers handling treated wood while the wood is
drying are exposed to the inorganic arsenical compounds via
dermal contact (hand) with the liquid on the surface of the wood
and through inhalation of the background arsenic-containing dust
in the plant. The Agency recognizes that most wood stacking and
584
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handling is done mechanically with forklifts, especially in the
larger, more automated plants. However, in smaller plants,
manually handling treated wood is more common. The Agency has
estimated that the total lifetime oncogenic risk to a treatment
_2
plant applicator involved in handling treated wood is 2.6 x 10
This oncogenic risk is composed of dermal and inhalation compon-
ents. The risk of skin cancer to an individual, which is primarily
related to the dermal exposure, is estimated to be 7.0 x 10 .
The risk of lung cancer to an individual, which is primarily
_2
related to inhalation exposure, is estimated to be 1.9 x 10 .
The teratogenic/fetotoxic MOS for handling treated wood is
estimated to be 417.
vi. Entering the Cylinders
While entering the cylinders for manual cleaning or for any
other purpose (e.g., releasing a wood jam), the applicator may
experience dermal exposure to the inorganic arsenical solution
through contact with unprotected areas of the skin. Exposure
also occurs through inhalation of background air arsenic levels
and possibly through arsenic containing water vapors. Due to a
lack of data, the Agency has not estimated the exposure to the
treatment plant worker resulting from this activity but believes
that there is some degree of risk.
585
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c. Penta
The Agency has determined that penta or sodium penta poses a
potential risk of fetotoxicity. Because technical penta and
sodium penta are contaminated with hexachlorobenzene (HCB) and
hexachlorodibenzo-p-dioxin (HxCDD), the use of penta or sodium
penta also poses a potential risk of oncogenicity and teratogen-
*
icity .
i. Background Air Levels of Penta or Sodium Penta
The data indicate that exposure to the background (ambient) air
levels of penta or sodium penta and its contaminanants are not
very great around a treatment plant. The Agency estimates that
the oncogenic risk to an applicator involved in general activi-
ties around the plant is negligible (<10~ ) while the feto-
toxic MOS is 730.
* As the fetotoxicity NOEL (0.1 ug/kg/day) for HxCDD is lower
than that for teratogenicity, the Agency used the NOEL for
fetotoxicity in the quantitative assessment of risk to HxCDD
(see Section II.D.5). In the case of technical penta, when the
NOEL for the fetotoxicity of penta is considered in light of the
exposure values, the margins of safety (MOS's) are lower than
those obtained with the respective exposure values and NOEL for
the fetotoxicity of HxCDD. Consequently, the MOS's for the
fetotoxicity of penta are used in calculating the risk reduction
for proposed modifications to the terms and conditions of
registration.
586
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ii. Bag Emptying
High inhalation and dermal exposure situations occur during the
manual opening and emptying of bags of prilled (granular) or
powder formulations of penta or sodium penta in the preparation
of the treatment solutions. The data indicate that the total
oncogenic risk is estimated to range from 7.3 x 10~ to
_2
1.5 x 10 during this operation, and the fetotoxic margins of
safety range from 6.4 to 13.
iii. Mixing Concentrated Solutions and Handling Diluted
Solutions
The Agency recognizes that the preparation of the working solu-
tions of penta or sodium penta from concentrates is usually done
automatically in mixing tanks or vats. Because the Agency does
not expect exposure to penta or sodium penta to occur during
this activity, discussion of this treatment plant process is not
applicable.
iv. Opening Cylinder Door (Pressure Plants Only)
During the brief time (about 1 hour per day) an applicator may
be opening cylinder doors following treatment, dermal and
inhalation exposure to penta is expected to be significantly
greater than during general activities around the plant. The
Agency has data on the inhalation exposure but lacks information
on the dermal exposure occuring during this activity. The
587
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oncogenic risk resulting from the inhalation component under
— 4
these circumstances is estimated to be 6.4 x 10 ; the MOS for
fetotoxic effects is estimated to be 150 in this situation.
v. Handling Treated Wood
Dermal exposure to the workers in a treatment plant occurs
during the handling of the wood that is still wet with the penta
or sodium penta treatment solution. The Agency has not deter-
mined the exposure to an applicator involved in this activity
due to a lack of data, but believes that there is some finite
risk to the handlers of wood which has been freshly treated with
penta or sodium penta.
vi. Entering Cylinders and Vats
While entering the treatment equipment for manual cleaning of
the dirty cylinders in the pressure treatment plants (penta) and
the vats containing the sodium penta or penta in non-pressure
treatment plants, the applicator may experience dermal exposure
to the treatment solution through contact with unprotected areas
of the skin and through inhalation of vapors. Although the
total exposure has not been quantified due to a lack of data,
the Agency believes that there is some finite risk to the
applicators during this activity.
588
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vii. Dip and Spray Applications (Non-Pressure Plants Only)
To control the growth of sapstain mold on freshly cut wood, 0.5%
sodium penta is used either as a dip or a spray. The spray
treatment provides more inhalation exposure to applicators than
does the dip treatment; this exposure occurs primarily via inha-
lation of aerosolized sodium penta solution. Dermal exposure to
sodium penta is also expected to be high during both application
processes. The fetotoxic MOS has been estimated to be 50 and 59
for spray and dip applicators, respectively. The total onco-
— 3 —4
genie risks are estimated to be 1.9 x 10 and 7.1 x 10
for spray and dip applicators, respectively.
Millwork and plywood are often dipped or sprayed with penta.
The total penta exposure to an applicator at millwork dipping
plants has been calculated to be 510 ug/kg/day, yielding an
estimated fetotoxic MOS of 5.9 and a total oncogenic risk, due
to exposure to HxCDD, of 7.1 x 10~3.
At plants which spray penta on wood which will be used for
millwork and plywood, the concentration of penta used is 2.5%.
The Agency estimates an exposure to penta of 300 ug/kg/day. The
fetotoxic MOS is estimated to be 10 and the total oncogenic risk
is estimated to be 9.8 x 10 .
589
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viii. Other Uses of Penta
The Agency has no data on the amount of penta to which an
applicator in the particleboard treatment plant is exposed.
Therefore, the risks resulting from this process cannot be
quantified. However, the Agency believes that during several
activities (e.g., bag emptying, handling treated particleboard,
and entering treatment equipment for manual cleaning) there is
potential exposure to penta and thus some finite risk to the
applicator.
2. Summary of Benefits
The three wood preservatives, creosote, the inorganic arsenical
compounds, and penta are usually the major substitutes for each
other in the treatment of wood. While there are some minor
alternatives including untreated wood (such as redwood and
western red cedar), other wood preservatives (such as copper
naphthenate) and structural alternatives (such as concrete and
steel), these alternatives are all more expensive and/or in
short supply, or, in the case of the alternative pesticides,
have limited efficacy as wood preservatives. Consequently, if
any one of the major wood preservatives were cancelled, it would
be replaced by the remaining registered wood preservative pesti-
cide(s) for the affected uses. However, severe economic impacts
could result from this cancellation due to the necessary equip-
ment changes that would be required to treat wood with the
remaining registered wood preservatives. Moreover, the cancel-
590
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lation of certain uses, for which the remaining wood preserva-
tives are not viable substitutes, would result in severe
economic impacts.
Creosote application is preferred for the treatment of railroad
ties which are more durable and lower in cost than other preser-
vative-treated wood ties. Creosote and/or penta are preferred
for timber which receives a high volume of heavy traffic because
of the protection from weathering and abrasion that these preser-
vatives impart to the wood. Creosote is preferred for marine
use (pilings) because penta is not as efficacious and inorganic
arsenical-treated pilings result in some breakage during ship-
ping and mechanical driving. For lumber and plywood, inorganic
arsenicals applications are preferred because the treated wood
is clean, ordorless, paintable, easy to handle, harmless to
plants and more durable when compared to either penta- or
creosote-treated wood. Penta is the wood preservative agent of
choice for posts, poles, and crossarms because penta-treated
wood is cheaper in cost than creosote-treated wood and does not
break or splinter as readily as does inorganic arsenical-treated
wood.
If creosote were cancelled for all pressure treatment uses, the
first year economic impact would range from $3.5 million to
$25.8 million. For inorganic arsenicals, the first year impact
of cancellation would be a cost increase ranging from $87.1 mil-
lion to $87.6 million. Penta first year cancellation impacts
would range from a $28.7 million to a $39.5 million cost
591
-------
increase. The annual long-term impacts would be an increase of
$71.6 million for creosote, a cost increase from $79.8 million
to $97.3 million for the inorganic arsenicals, and a decline in
cost of $41 million to an increase of $48.1 million for penta
(depending on which alternative is chosen).
The cancellation of penta or sodium penta for non-pressure
applications (i.e./ sapstain control, raillwork and plywood, and
particleboard uses) would generally result in the substitution
of alternative wood preservatives at substantially higher cost
to the applicator. Moreover, for most use patterns, the alter-
native pesticide chemicals do not provide the same efficacy as
penta treatment.
A summary of the economic effects of cancelling one, two or all
three of the wood preservatives on a use-by-use basis is given
below. The areas of non-substitutability are emphasized.
a. Introduction
The Agency has evaluated the economic impact of the cancellation
of one or more of the wood preservative agents in terms of the
cost of substitution of the remaining registered wood preserva-
tive(s), or alternative materials, for the pressure and non-
pressure treatment plant uses. This evaluation is based on
information submitted by the registrants, material from the USDA-
States-EPA Assessment Report and other information available to
the Agency. The pressure treatment plant uses which were sub-
592
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jected to this benefits analysis include 1) railroad ties, 2)
lumber, timber and plywood, 3) pilings, 4) posts, 5) crossarms,
and 6) poles. The non-pressure treatment plant uses which were
considered include 1) sapstain control, 2) millwork and plywood,
and 3) particleboard.
All untreated wood products, regardless of their original
strength, durability or natural resistance, are subject to degra-
dation when placed in end-use situations whicla are conducive to
attack by fungi, insects, bacteria or marine borers. The appli-
cation of selected chemicals as wood preservatives protects wood
from deterioration and frequently yields a product with signifi-
cant advantages in terms of cost and performance over non-wood
alternatives that might be available. The actual service life
of treated wood products depends on the treated wood's inherent
resistance to decay as well as on the environmental conditions
of end-use, such as marine immersion or ground contact. An
increase in life expectancy of five or more times that of
untreated wood is achieved for most treated wood products.
b. Pressure Treament Plant Uses
i. Railroad Ties
In 1978, about 103.5 million cubic feet of railroad crossties
and switchties were treated with wood preservatives for use in
the railroad tie system in the United States. Approximately
99.6% of these ties were treated with creosote and the remaining
593
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0.4% with penta. The high usage of creosote-treated ties
reflects the greater strength and lower cost of the creosote-
treated ties compared with other preservative-treated wood
ties. Inorganic arsenical treatment is considered to be unac-
ceptable for railroad tie use because inorganic arsenical-
treated ties are brittle and do not hold fasteners well. Con-
crete ties are technically feasible substitutes for treated wood
ties; however, treated wood ties and concrete ties cannot be
intermixed in a given section since concrete ties settle more
slowly than preservative-treated ties, resulting in an unstable
track structure. Thus, the replacement of creosote-treated ties
with concrete ties necessitates the replacement of all the ties
in a given section of the railroad tie system.
The Agency has evaluated the economic benefits of preservative-
treated wood railroad ties and has determined that there would
be a major adverse economic impact of an average annual (annu-
alized) cost increase of $40.5 million if creosote were can-
celled and penta were still available (see Section III.B.4,
Methods and Assumptions, for definition of annualized cost).
The first year impact would result in a decline in cost of
$18.2 million due to lower installation costs for penta-treated
ties compared to creosote-treated ties. There would be little
or no first year or ensuing long-term adverse economic impact if
penta were cancelled and creosote were still available to the
railroad industry. However, if both creosote and penta were
cancelled, the most likely substitutes would be copper naphthe-
nate-treated ties and concrete railroad ties. If copper naph-
594
-------
thenate-treated or concrete ties are used, the average annual
(annualized) costs for the railroad tie system would increase by
$0.74 billion and $2.4 billion, respectively. The first year
economic impacts would be an additional cost of $0.58 billion
for copper naphthenate-treated ties and $3.7 billion for con-
crete ties. These projected adverse major impacts are based on
the assumption that the supply of alternative materials is
adequate for substitution at current prices.
ii. Lumber, Timber and Plywood
Treated lumber is used in a variety of end-uses formerly served
almost exclusively by cedar and redwood. Shorter supplies and
higher prices for the naturally resistant wood species have
resulted in a great demand for treated wood. Inorganic arsen-
ical-treated wood, which is suitable for almost all end-uses of
lumber, timber and plywood, has been the primary replacement
material for cedar and redwood.
An estimated 105.3 million cubic feet of lumber and timber were
treated with the three wood preservatives in 1978. In addition,
more than 2 million cubic feet of plywood and a substantial
amount of sawn material were treated. In 1978, creosote was
used for treating about 10.78 million cubic feet of lumber and
timber. Industrial block flooring accounted for about 700,000
cubic feet of creosote-treated lumber; the other 10.08 million
cubic feet of creosote-treated wood in this use category are
used primarily as timbers for landscape, farm, mine and marine
595
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construction purposes. More than 70% of the total treated
lumber and timber/ about 73.32 million cubic feet, was treated
with inorganic arsenicals and about 20%, or about 21.21 million
cubic feet of lumber and timber, was treated with penta in 1978.
Based on efficacy and other performance characteristics, inor-
ganic arsenical-treated wood is suitable for most end-uses of
lumber, timber and plywood. Inorganic arsenical-treated wood is
clean, odorless, paintable, easy to handle, harmless to plants
and durable compared to either penta- or creosote-treated wood.
Penta- and creosote-treated lumber, timber and plywood have
limited uses'due to odor, objectionable vapors, and oily, un-
paintable surfaces. Inorganic arsenical wood preservatives are
used for treating wood for such uses as patios, decks, play-
ground equipment, cooling towers, greenhouses, horticultural
nurseries and all weather wood foundations; these uses comprise
the bulk of the market for treated lumber, timber, and plywood.
Creosote applications are preferred where treated wood is sub-
ject to a high volume of heavy traffic because of the protection
from weathering and abrasion that it imparts to the wood. Penta
in P9 oil also has these protective qualities (except for marine
applications) and can be substituted for creosote for these
uses; inorganic arsenicals are also an alternative for these use
patterns except under conditions of high mechanical stress, due
to the brittleness imparted by the inorganic arsenical treat-
ment. Creosote-treated wood is also preferred for industrial
applications in high acid environments due to creosote's high
596
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resistance to acids. Penta in heavy oil ranks second to creo-
sote in this regard, with inorganic arsenicals having no acid
resistance.
Since lumber, timber and plywood include a wide variety of
treated wood used for many different end-uses, replacement costs
could not be determined for all treated wood products in this
use category. Thus, the total economic impact of cancellation
of the three wood preservatives could not be estimated for com-
parison to the actual 1978 situation. If inorganic arsenicals
were cancelled for lumber, timber and plywood, there would be
major first year and major annual long-term adverse economic
impacts since penta and creosote are not acceptable alternatives
to the inorganic arsenicals for wood preservative treatment of
lumber, timber and plywood.
If creosote were cancelled, there would be minor first year
and minor annual long-term economic impacts of an additional
cost of $39 million. If penta were cancelled, the first year
estimated impact and subsequent annual impact would be an
increase of $18 million. If penta and creosote were cancelled,
the first year impact and the estimated annual long-term impact
would be an increase of $5.2 million. It is clear that the
economic impact resulting from cancellation of both creosote and
penta is smaller than the impacts of cancellation of either
creosote or penta alone. The inorganic arsenicals, which are
less expensive than either of the other two preservatives, would
be the major substitute if both creosote and penta were can-
597
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celled. However, 4.3 million cubic feet of transportation
timbers that are currently treated with creosote would not be
treated if both penta and creosote were cancelled.
If the inorganic arsenical compounds and penta were cancelled,
there would be major first year and long-term cost impacts since
creosote would not be an acceptable substitute for most uses of
lumber, timber and plywood. If the inorganic arsenicals and
creosote were cancelled, there would be major cost impacts since
penta is not an acceptable substitute for most uses on lumber,
timber, and plywood. If all three wood preservatives were
cancelled, non-wood materials such as plastic, steel, or con-
crete would be substituted for the three wood preservatives.
The economic impact resulting from this cancellation scenario
cannot be determined because of the diversity of end-uses of
lumber, timber, and plywood. However, it is expected that the
non-wood materials would have a higher cost than treated wood
and there may be important aesthetic impacts as well.
The Agency does have preliminary information on the impacts of
the cancellation of inorganic arsenical-treated lumber used for
home construction (e.g., all weather wood foundations, plates
and sills, and structural framing), in a preliminary briefing
given by the Mitre Corporation (EPA contract 68-01-5964, 1980),
the impact of cancelling inorganic arsenical applications for
treating lumber used in home construction was analyzed for the
end-uses of all weather wood foundations (AWWF), plates and
sills, and structural framing. There are about 10,000 homes
598
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built annually with AWWF (about 2,400 board feet of ACA- and/or
CCA-treated lumber per home), about 750,000 homes with treated
plates and sills (about 220 board feet of ACA- and CCA-treated
lumber per home), and about 8,000 homes with treated structural
framing (about 10,000 board feet of CCA-treated lumber per
home). Most of the AWWF homes are located in the northern
United States; homes which have treated plates and sills are
found in the southern United States on slab foundations, and the
structural framing homes are located only in Hawaii. In recent
years, about 1% of the home foundations used treated wood or
masonry and 99% used concrete. However, projections indicate an
increasing market share for AWWF.
If inorganic arsenicals were cancelled for treating AWWF, the
most likely substitutes would be concrete and masonry founda-
tions. In rural, isolated areas in the northern United States,
the use of AWWF results in a savings to the home buyer, but the
concrete and masonry foundations are likely to be lower or equal
in cost to those for AWWF in urban areas. Also, the possible
benefits of AWWF in termiticide control are currently being
reviewed by the Agency.
If the inorganic arsenicals were cancelled for treatment of
plates and sills, the most likely substitute would be steel
plates and sills. The use of steel plates and sills for home
construction instead of treated wood would not result in a cost
increase. If the inorganic asenicals were cancelled for the
treatment of structural framing, the roost likely substitutes
599
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would be concrete, masonry, and steel framing. The cost ot
these substitutes are similar to that ot treated wood.
iii. Pilings
An estimated 12.09 million cubic feet of pilings were treated
with wood preservatives in 1978 for use as marine and foundation
%
pilings. Creosote was used to treat 82.7% of these pilings in
1978, while penta was the wood preservative for 9.5% of the
pilings and the inorganic arsenicals were used for 7.8%. Penta
is not recommended or used for marine pilings because it is not
very efficacious; inorganic arsenicals could serve as an alterna-
tive for creosote in marine and foundation uses even though the
brittleness imparted to pilings by inorganic arsenical results
in some breakage of pilings during shipping and mechanical
driving. Both concrete and steel can provide technically accept-
able alternative materials for pilings in foundation uses.
The Agency has evaluated the economic benefits of treated wood
pilings for the three wood preservatives and has determined that
there would be a major adverse economic impact if penta or
creosote were cancelled. The annual cost impacts would be a
$9-10 million increase for the cancellation of creosote and a
$8.3-9.0 million increase for the cancellation of penta. If the
inorganic arsenicals were cancelled, the extent of the annual
economic impacts would be minor since creosote-treated pilings
could substitute for inorganic arsenical-treated pilings. If
both penta and the inorganic arsenicals were cancelled for use
600
-------
on pilings, there would be a major annual cost increase of
*
greater than $9.0 million .
If both creosote and the inorganic arsenicals were cancelled,
steel or concrete would be used as alternatives for 4.3 million
cubic feet of marine pilings, since penta is not recommended or
used for marine use. If penta and creosote were cancelled for
pilings, the annual impact would be an additional cost of $8
million, for both the first and subsequent years. Under this
scenario, the high cost increase for equipment changes is
largely offset by the lower cost of inorganic arsenical-treated
pilings.
If all three wood preservatives were cancelled, the most likely
substitutes would be concrete for marine uses and concrete and
steel for the foundation uses. However, steel would be subject
to corrosion in highly acidic soils or in marine environments.
The costs of both concrete and steel pilings (including installa-
tion costs) are higher than treated wood piles on a one for one
basis. If concrete or steel pilings are used instead of. treated
wood pilings, the total average annual (annualized) installed
cost (see Section III.B.4, Methods and Assumptions, tor defini-
tion) of pilings would increase by 33.3% ($64.5 million) for
concrete and 67% ($129.1 million) for steel compared to the 1978
* The cancellation of both penta and the inorganic arsenicals
results in an impact similar to that of cancelling penta or the
inorganic arsenicals singly due to the high usage of creosote-
treated ties.
601
-------
annual!zed cost of treated wood pilings (assuming a one to one
replacement for the wood pilings). However, if concrete and
steel piles are assigned heavier loads than those previously
assigned to treated wood piles, the total average annual
installed cost of pilings could decrease by as much as 11% for
concrete and increase by as much as 11% for steel, compared to
the 1978 annualized cost of treated wood pilings. In the use of
foundation pilings in residential and small commercial buildings
where loads are relatively low, concrete or steel pilings will
usually be much higher in cost than treated wood pilings.
iv. Posts
In 1978, an estimated 20 million cubic feet of posts were
treated with preservatives. Treated wood posts include such
uses as fences, highway guardrails and signposts; farm fence
posts account for the largest proportion of treated posts used.
Ihe average service life of untreated fence posts is only 3.3
years, compared with 38 years for creosote- or inorganic
arsenical-treated posts (ACA) and 33 years for posts treated
with penta. The 1978 distribution of fence posts by treatment
chemical was 22.9% for creosote, 54.8% for penta and 22.3% for
the inorganic arsenicals. The total cost of treated wood posts
in 1978 was $66.1 million.
The Agency has evaluated the benefits of the three wood preserva-
tives for posts and has determined the economic impacts if one
or more of the three wood preservatives were cancelled. If
602
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penta were cancelled, there would be a moderate economic impact,
an annual cost increase for the first and subsequent years of
$0.75 million to $5.1 million in treated wood posts, depending
on which alternative (e.g., creosote or inorganic arsenicals) is
chosen. If creosote were cancelled, there would be a moderate
economic impact of a $3.3 million annual cost increase for the
first and subsequent years. If the inorganic arsenicals were
cancelled, the first year and annual long-term impacts would be
a co'st increase of $4.0 million to $4.5 million in treated wood
posts depending on which alternative (e.g., creosote or penta)
is chosen; this impact is viewed as moderate.
If both creosote and the inorganic arsenicals were cancelled,
there would be major adverse economic impacts for both the first
year and subsequent years; the economic impact is estimated to
be an annual cost increase of greater than $7 million for
treated wood fence posts. If both inorganic arsenicals and
penta were cancelled, there would be a moderate adverse economic
impact for both the first and subsequent years (an annual
increase in post cost of greater than $5.1 million). Under this
cancellation scenario, steel posts would probably replace
treated wood posts for suburban uses since creosote-treated
posts are unacceptable replacements. However, if both creosote
and penta were cancelled, there would be minor adverse first
year and annual long-term impacts; this impact is estimated,
based on current levels of usage, to be an annual cost increase
of $383,000.
603
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If all three wood preservatives were cancelled, steel or con-
crete posts would be the most likely alternative materials that
would be used for fence posts. T-type steel posts, which serve
as substitutes for treated wood posts in farm uses, are priced
competitively with treated wood posts. Thus, substitution of
steel posts in many farm uses would not necessarily lead to
higher fencing cost. Concrete posts would be more expensive
than steel and probably would not be substituted in most farm
situations.
v. Crossarms
Crossarms are the cross members of assembled utility poles. An
estimated 1,685,000 cubic feet of crossarms were treated with
wood preservatives in 1978. The distribution of crossarms by
preservative treatments was 2.5% for creosote, 95.8% for penta
and 1.7% tor the inorganic arsenicals. The 1978 cost of treated
crossarms was estimated as §14.86 million. The service lives of
crossarms treated with the three major wood preservatives are
considered to be equivalent (40 years). Steel crossarms can be
used as alternatives for treated wood crossarms in some use
situations.
The Agency has evaluated the benefits of the three wood preser-
vatives for crossarms and has determined the economic impacts if
one, two, or all three wood preservatives were cancelled. If
penta were cancelled for the crossarm use, there would be minor
to moderate adverse economic impacts for both the first and
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subsequent years ranging from a decline in annual cost of $0.23
million to an additional annual cost of $1.2 million, depending
upon which alternative (i.e., creosote or inorganic arsenicals)
is chosen. If creosote were cancelled, there would be minor
adverse first year and annual long-term impacts, ranging from a
decline in cost of $15,000 to $30,000, depending on which alter-
native (i.e., inorganic arsenicals or penta) is chosen. These
economic impacts are based on current preservative prices and do
not include any additional investment costs for conversion from
one treatment process to another. If the inorganic arsenicals
were cancelled, there would be a slight increase in treated
crossarm cost, resulting in minor adverse first year and annual
long-term impacts.
If both the inorganic arsenicals and penta were cancelled, there
would be an additional annual cost of $1.2 million for treated
crossarms, which represents a moderate adverse economic impact.
If both the inorganic arsenicals and creosote were cancelled for
the crossarm use, there would be an annual decline in cost of
$0.2 million. If both penta and creosote were cancelled, there
would be a small decline in the annual cost of treated crossarms.
If all three wood preservatives were cancelled, the most likely
substitute would be steel crossarms. The steel crossarms would
be competitive with treated crossarms for some uses, but, in
most instances, this cancellation scenario would result in
higher crossarm costs and a major adverse economic impact.
605
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vi. Poles
Treated poles are the principal structural support elements in
the 4.52 million miles of the electric distribution system and
the estimated 640,000 miles of electrical transmission lines in
the United States. Treated poles are also used to support tele-
phone lines, as light standards, and for construction uses in
residential and other buildings. In 1978, an estimated 64.2
million cubic feet of wood were treated for pole uses (repre-
senting 2.86 million treated poles). The distribution of the
three preservatives for pole treatment by volume in 1978 was
65.3% for penta, 28.4% for creosote and 6.3% for the inorganic
arsenicals. There are no viable chemical alternatives for the
three major wood preservative agents for pole treatment with the
possible exception of copper naphthenate for certain limited
uses. However, copper naphthenate is unsuitable for large-scale
use on poles because it imparts a green, greasy surface to the
poles, is unstable in the presence of moisture and causes cor-
rosion of metals. Non-wood alternatives for treated poles
include the use of concrete and steel as pole construction
materials, and the installation of underground distribution and
transmission lines in urban areas or in new subdivisions.
The Agency has evaluated the benefits of the three major wood
preservatives for poles and has determined the economic impact
on the distribution and transmission pole system if one, two, or
all of the three wood preservatives were cancelled. if penta
were cancelled for poles, there would be a first year cost in-
606
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crease ranging from $19.9 million to $24.2 million depending
upon which alternative is chosen (i.e., creosote or inorganic
arsenicals). The long-term economic impact for the cancellation
of penta would range from a total annualized cost (see Section
III.B.4, Methods and Assumptions, for definition) decrease of
$43.6 million to an average annual cost increase of $32.8
million. If creosote were cancelled there would be a major
adverse economic impact for the first year with an additional
cost of $9.4 million to $20.7 million. The long-term impact
would range from an average annual decline in cost of $43.6
million to an additional cost of $17.8 million and could cause a
major adverse economic impact. If inorganic arsenicals were
cancelled, there would be a minor adverse impact of an
additional cost of $1.9 million for the first year and a major
adverse economic impact (additional average annual cost of $17.8
million to $32.8 million) for each subsequent year.If penta and
creosote were cancelled, there would be an additional first year
cost of $28 million and an average annual decline in cost of
$43.6 million in subsequent years. If penta and the inorganic
arsenicals were cancelled, there would be major adverse economic
impact with a cost increase of $35.5 million in the first year
and an average annual cost increase of $32.8 million in
subsequent years. The cancellation of creosote and the
* Even though there is a decline in the average annual cost of
$43.6 million for the treated poles (users' savings), the first
year impact to the applicators for conversion is major (an
increase of about $9.4-28.0 million).
607
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inorganic arsenicals would result in an additional first year
cost of $24.3 million and an average annual cost increase of
$17.8 million in subsequent years, or major economic impacts. If
all three major wood preservatives were cancelled for poles, the
most likely substitutes would be concrete and steel. Under this
cancellation scenario there would be a large first year cost
increases and major adverse impacts in subsequent years ranging
from $1.3 billion to $2.06 billion (average annual cost)
depending upon the alternative which is chosen.
c. Non-pressure Treatment Plant Uses
i. Sapstain Control
Although the most serious structural damage to wood is caused by
insects and decay, sapstain fungi infestion increases the capa-
city of the wood to absorb moisture thus making the wood more
vulnerable to decay. Sapstain fungi infestation also causes dis-
coloration which reduces the market value of the wood. Current-
ly, sodium penta is the primary antimicrobial used to control
sapstaining and surface staining fungi in the United States.
About 1.15 million pounds of sodium penta are used annually for
this purpose. The sodium penta solutions often include the
salts of other chlorinated phenols.
608
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The alkali salts of tetrachlorophenol (tetra) have been used
effectively for sapstain control for over 40 years; in recent
years, however, sodium penta has replaced sodium tetra as the
primary antimicrobial for sapstain control. Copper-8-quinolino-
late (Cu-8) is currently registered for sapstain control; infor-
mation is unavailable on the volume of Cu-8 used for sapstain
control and the effectiveness of this chemical for this use.
Kiln drying can be used to prevent sapstain for most softwoods;
however, kiln drying cannot be utilized in those situations
where freshly-cut lumber cannot be placed in the kiln within 48
hours. Kiln drying is also not appropriate for a number of
hardwood species which are subject to warping and honeycombing
during kiln drying.
The Agency has evaluated the benefits of sapstain control and
has determined that there would be a minor adverse economic
impact if sodium penta were cancelled. The most likely sub-
stitutes for controlling sapstain would be the alkali salts of
tetrachlorophenol (e.g., sodium tetra) which are equal in cost
and efficacy to sodium penta. There would be only minor changes
in treatment cost if applicators switched irom sodium penta to
sodium tetra for sapstain control; no adverse economic impacts
in consumer prices for lumber are anticipated it sodium tetra
replaces sodium penta for this use. Other alternatives (e.g.,
Cu-8 and a formulation of Cu-8 and potassium tetra) are avail-
able at a slightly increased cost; these alternatives, however,
may not provide adequate protection for sapstain control.
609
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ii. Millwork and Plywood
Millwork includes wood windows, sash screens, blinds, shutters/
window frames, doors, doorframes and mouldings, as well as
machined parts of these products. All of these items are manu-
factured primarily from ponderosa pine and other softwoods which
have a low natural resistance to decay. Millwork and softwood
plywood are usually treated with a 5% pent^a solution in mineral
spirits (containing water repellents) which is applied by
spraying, brushing, dipping or by the vacuum process. Available
alternatives include tributyltin oxide (TBTO), Cu-8, and non-
wood structural materials such as aluminum. Penta is colorless,
compatible with paints, stains, sealers and primers, and does
not interfere with the adhesion of glazing compounds, caulkings
or other sealants. The 0.75% TBTO formulations are effective
for exterior millwork which is painted, varnished or coated
subsequent to TBTO treatment; however, when the TBTO-treated
wood is subjected to severe exposure, the prolonged service life
provided by 0.75% TBTO will not equal that of penta. The
0.25%-0.3% Cu-8 solutions are approved by the National Wood
Manufacturers Association (NWMA) for use on millwork, but not
recommended by the National Forest Products Association for
millwork protection. A water-based Cu-8 product (0.5%) is
available, but has not been approved for use by the NWMA.
The Agency has evaluated the benefits of millwork and plywood
and has determined that there would be a minor adverse economic
impact to the millwork and plywood industry it penta were
610
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cancelled. The most likely alternatives for penta would be
TBTO, Cu-8 or nonwood structural materials (e.g., aluminum).
If penta is cancelled, millwork and plywood manufacturers would
likely switch to TBTO, which costs about the same as penta and
is effective for above ground exposure if the TBTO-treated wood
is painted. If the water-based Cu-8 solution proves to be
efficacious, many penta users would switch to this formulation.
Other alternatives that could be substituted for penta would be
untreated wood, which would require frequent replacements and
would increase the demand for wood products, naturally resistant
wood, and non-wood materials (e.g., aluminum).
iii. Particleboard
In some areas of the United States it may be necessary to treat
particleboard to prevent attack by dry-wood termites and other
wood destroying insects. Penta is presently the only effective
preservative used for this specific purpose. There is currently
only one known plant in the United States producing penta-
treated particleboard. The penta-treated particleboard consti-
tutes less than 1% (about 170,000 square feet) of the average
annual particleboard production at the plant and represents a
very small part (about 0.005%) of the 3.9 billion square feet of
particleboard produced in the United States in 1978. The produc-
tion of treated particleboard generates an annual revenue of
about $35,000. Thus, even though there are no registered
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alternatives for the particleboard used, the economic impacts
would be minor if penta were cancelled for this use.
3. Risk/Benefit Analysis
a. Consideration of Regulatory Options
The Agency has determined, based on the evaluation of risk and
benefit information, that the treatment plant application of
wood with creosote, the inorganic arsenical compounds, and penta
poses unreasonable adverse effects to treatment plant workers.
Therefore, the registration of these wood preservatives cannot
be simply continued for these uses, i.e., railroad ties, lumber,
timber and plywood, pilings, posts, crossarms, poles, sapstain
control, millwork and plywood, and particleboard. Cancellation
is, however, not a desirable option because the economic
benefits of the wood preservatives are very large, and severe
economic impacts could result if one or more of the three wood
preservatives were cancelled. Moreover, the risks of other
chemical preservatives are unknown, the substitutability of
chemical alternatives is questionable, and the uncertainty
levels surrounding the risks are large. Before considering
cancellation for one or more of the preservatives on one or more
use sites, the Agency will consider Option 2, the Modification
of the Terms and Conditions of Registration, to determine if
risk reduction measures can reduce the risk to acceptable
levels, in the following sections, the Agency will evaluate the
impacts of the modifications under consideration on risk
612
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reduction and on the benefits of use. The Agency examined all-
•risk reduction options which could reduce exposure without
causing major economic impacts. For those situations where the
risk cannot be reduced to acceptable levels the Agency will
select Option 3, Cancellation.
b. Risk/Benefit Impacts of Modifications Under Consideration
for Treatment Plants
i. Gloves
The Agency does not have sufficient data that would allow a
quantitative determination of dermal exposure to workers opening
pressure cylinder-doors. It is clear, however, that residues of
the preservative solution may accumulate on the surface of the
doors. The Agency believes that dermal exposure during this
activity will occur almost entirely via the hands.
During the manual empyting of bags of prilled or powder for-
mulations of penta or sodium penta, or inorganic arsenical
powders, dermal exposure can occur through other parts of the
body besides the hands. However, the Agency estimates that
during this activity, exposure to the hands is significant. It
has also been shown that a potential exists for hand dermal
contact to occur while the inorganic arsenical solutions are
being prepared and mixed for use in the treatment process.
613
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Contact with wood which has been freshly treated with any of the
three wood preservatives provides ample opportunity for hand
dermal exposure, as does the entering of the treatment cylinders
(all three preservatives) and vats (penta or sodium penta) for
any purpose (e.g., manual cleaning). With regard to the spray
and dip operations in the non-pressure treatment of wood with
penta or sodium penta, the Agency has determined that hand
dermal exposure is likely.
To reduce hand dermal exposure to the three wood preservatives
in the treatment plants, the Agency will consider requiring all
wood treatment applicators to wear gloves (e.g., rubber) imper-
vious to the wood treatment solution when coming into hand
contact with these pesticides. Wearing gloves is estimated to
reduce hand dermal exposure by 99% (Kozak, 1980).
Due to insufficient data, the Agency has been unable to quantify
the hand dermal exposure resulting from activities in which
contact with the creosote solution is likely to occur (see
Section V.B.I.a). However, an applicator wearing gloves
resistant to penetration by creosote solutions would have a
significantly reduced (by 99%) exposure to creosote via the
hands.
Due to insufficient data, the Agency has been unable to quantify
the hand dermal exposure resulting from entering cylinders and
opening cylinder doors in which contact with the inorganic
arsenical solution is likely to occur (see Section V.B.l.b).
614
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However/ an applicator wearing gloves (e.g., rubber) resistant
to penetration by the inorganic arsenicals would have a
significantly reduced (by 99%) exposure to inorganic arsenicals
via the hands.
Wearing gloves reduces the total dermal inorganic arsenical
exposure from 17 ug/kg/day to 0.17 ug/kg/day while handling
treated wood and diluted solutions. The total lifetime
oncogenic risk from exposure to the diluted inorganic arsenical
solution or handling treated wood is reduced from 2.6 x 10~
_2
to 1.91 x 10 and the teratogenic/fetotoxic MOS is increased
from 417 to 499. The risk of skin cancer to an individual,
which is primarily related to dermal exposure, may be reduced
from 7.0 x 10 to 1.0 x 10 by wearing gloves.
By wearing gloves, the total oncogenic risk from mixing the
_ I
inorganic arsenical concentrates is reduced from 1.17 x 10
-2
to 2.0 x 10 and the teratogenic/fetotoxic MOS is increased
from 135 to 487. The risk of skin cancer to an individual,
which is primarily related to dermal exposure, may be reduced
from 9.8 x 10~2 to 1.3 x 10~3.
The total dermal exposure is reduced from 1.6 ug/kg/day to
1.12 ug/kg/day when gloves are worn while emptying bags (or
other containers) of inorganic arsenical powder formulations.
Gloves are not especially effective in reducing risks from
emptying bags of powder formulations since hand exposure only
accounts for 30% of the total dermal exposure. The total
615
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lifetime oncogenic risk from bag emptying is reduced from
3.4 x 10~2 to 3.2 x 10~2 and the teratogenic/fetotoxic MOS
is increased from 294 to 310. The risk of skin cancer to an
individual, which is related to dermal exposure, may be reduced
from 6.0 x 10~3 to 4.4 x 10~3.
Although the Agency has .not quantified the hand dermal exposure
to penta or sodium penta for entering cylinders and vats,
opening the cylinder door, and handling treated wood because of
a lack of data, an applicator wearing gloves resistant to pene-
tration by penta or sodium penta solutions would have a signifi-
cantly reduced (by 99%) exposure to penta or sodium penta via
the hands.
Wearing gloves during the emptying of bags (or other containers)
of prilled penta or sodium penta reduces the total dermal expo-
sure from a range of 27 to 270 ug/kg/day to 19 to 190 ug/kg/day.
Gloves are not especially effective in reducing risks from
emptying bags of prilled (granular) formulations. The total
lifetime oncogenic risk from exposure to penta or sodium penta
during this activity is reduced from a range of 7.3 x 10 to
1.5 x 10~2 to a range of 7.1 x 10~3 to 1.3 x 10~2 and the
fetotoxic MOS is increased from a range of 6.4 to 13 to a range
of 7.7 to 14.
Wearing gloves during the spraying or dipping applications of
penta (non-pressure) reduces the total dermal exposure from 500
to 5.0 ug/kg/day (dip) and from 250 to 2.5 ug/kg/day (spray).
616
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The corresponding tetotoxic MOS, after addition of the inhala-
tion exposure, is increased from 5.9 to 210 for dip operations
and from 10 to 57 for spray operations. Dermal exposure to
HxCDD is also reduced by 99%. The total oncogenic risks are
thus reduced from 7.1 x 10 to 7.1 x 10 for dip opera-
tions and from 9.8 x 10~ to 1.7 x 10 for spray operations.
Wearing gloves during the spraying and dipping applications of
sodium penta (non-pressure) reduces total dermal exposure from
50 to 0.5 ug/kg/day. The fetotoxic MOS, after addition of
inhalation exposure, is increased from 59 to 6,000 for dip
operations, and from 50 to 290 for spray operations. The
corresponding oncogenic risks due to exposure to HxCDD are
reduced from 7.1 x 10~ to 7.1 x 10~ for dip operations
and from 1.9 x 10~ to 3.4 x 10 for spray operations.
For the wood preserving industry which uses pressure treatment,
the cost of requiring gloves ranges from $210,000 to $1,100,000
per year (assumes some protective clothing is currently avail-
able to the applicators), or about $3,500-18,000 for large
plants and about $900-4,700 for small plants, depending on the
number of workers in the plant (Mitre, 1980). For the wood
preserving industry which uses non-pressure treatment to pre-
serve wood, the implementation of this modification (assuming
that some protective clothing is already provided to the
applicators) would cost as follows: for sapstain control, $300
to $1,560 annaully per plant with a total cost to the sawmill
industry of $630,000; for millwork and plywood, $300 to $1,560
617
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annually per plant with a total cost to the millwork and plywood
industries of $630,000; and for the one plant involved in
producing penta-treated particleboard, the cost would range from
$60 to $312 per worker (Mitre, 1980; EPA, 1980).
ii. Disposable Coveralls and Gloves
Most arsenical wood treatment formulations are shipped to the
plants as liquids. However, the smaller, less modern plants
still regularly use and mix powder formulations at the plant
several times a week, thus creating a potential for dermal
exposure through the body, arms, and neck, as well as the
hands. During the manual emptying of bags of prilled or powder
formulations of penta or sodium penta, there is also dermal
exposure via routes other than the hands, such as the body, arms
and neck of the applicator.
To reduce this total dermal exposure (hands, body, arms, and
neck), the Agency will consider requiring applicators who empty
bags and other containers and mix powder formulations of the
inorganic arsenical compounds or bags of prilled or powder
formulations of penta or sodium penta to wear disposable
coveralls (e.g., nitrile or polyethylene) or similar protective
clothing and gloves (e.g., rubber) where closed emptying and
mixing systems are not used. This modification will reduce
total dermal exposure by 80% (Kozak, 1980). However, the Agency
estimates that during this activity, exposure to the hands
accounts for about 30% of the total dermal exposure.
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Wearing disposable coveralls and gloves during the bag emptying
and mixing of powder formulations of the inorganic arsenicals
reduces the total dermal exposure from 1.6 to 0.32 ug/kg/day.
Ihe ability of gloves and coveralls to reduce risk is limited,
since the inhalation component of exposure is significant. The
total lifetime oncogenic risk from exposure to the inorganic
_2
arsenicals during this activity is reduced from 3.4 x 10 to
3.0 x 10~ and the teratogenic/fetotoxic MOS is increased from
294 to 326. The risk of skin cancer to an individual, which is
primarily related to dermal exposure, may be reduced from
6.0 x 10"~3 to 2.0 x 10~3.
Wearing disposable coveralls and gloves during the emptying of
bags of prilled penta or sodium penta reduces the total dermal
exposure from a range of 27 to 270 ug/kg/day to a range of 5.4
to 54 ug/kg/day. The total lifetime oncogenic risk from
exposure to penta or sodium penta during this activity is
reduced from a range of 7.3 x 10 to 1.5 x 10 to a range
of 6.6 x 10~3 to 8.2 x 10~3, and the fetotoxic MOS is
increased from a range of 6.4 to 13 to a range of 12 to 15.
The annual cost to the pressure and non-pressure wood preserving
industries for disposable coveralls and gloves ranges from $20
to $40 per worker ($80 to $160 per plant) for coveralls and $60
to $312 per worker ($240 to $1,248 per plant) for rubberized
gloves. The combined cost (gloves and disposable coveralls) of
implementing this modification ranges from $320 to $1,400 per
plant annually (Mitre, 1980; EPA, 1980).
619
-------
iii. Neoprene-Coated Cotton or Rubberized Overall, Jacket,
Gloves and Boots, and a Respirator
There are occasions when it is necessary for a treatment plant
applicator to enter a pressure cylinder (e.g., for manual
cleaning or releasing a wood jam). During such an activity,
there is clearly a great opportunity for both dermal and
inhalation exposure. This potential for high exposure to the
treatment solution exists in all pressure treatment plants,
whether creosote, inorganic arsenicals, or penta is the
preservative being used. A similar potential for high exposure
exists during the cleaning of non-pressure treatment equipment
(e.g., vats for penta or sodium penta).
As with creosote and penta, the risks resulting from exposure
to the inorganic arsenicals have not been quantified for
applicators entering cylinders due to insufficient data.
However, based on the evaluation of total oncogenic risks
resulting from background air arsenic levels in the plant
— 2 — 2
(1.9 x 10 ) and risks from contacting diluted (2.6 x 10 )
and concentrated (1.17 x 10 ) treatment solutions, the Agency
has determined that risks to personnel entering the cylinders
for manual cleaning the insides of arsenical treatment cylinders
or performing other activities inside the cylinder (e.g.,
releasing treated wood jams) would be greater than the risks
from the background inhalation exposure and the dermal exposure
from mixing concentrates and handling the diluted solutions.
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To reduce these risks/ the Agency will consider requiring appli-
cators who enter pressure treatment cylinders or vats (non-
pressure) to wear a neoprene-coated cotton or rubberized
overall, jacket, gloves and boots, and a properly maintained
half-mask canister or cartridge respirator designed for pesti-
cide use. A respirator will also be considered for applicators
*
who are opening cylinder doors for penta and creosote and
during the spraying operations of penta or sodium penta (non-
pressure treatments). Only a few workers (about four per plant)
are involved in these activities and this type of cleaning is
usually done only once or twice a year (Mitre, 1980).
A cartridge respirator will reduce inhalation exposure to these
wood preservatives by about 90% (Kozak, 1980). The use of a
neoprene-coated cotton or rubberized overall, jacket, gloves
and boots will reduce total dermal exposure by about 80% (Kozak,
1980).
Due to insufficient data, the Agency has not quantified the
total exposure to either the pressure or the non-pressure
treatment plant applicator who is involved in these activities
(e.g., entering the cylinders or vats, or opening cylinder doors
* The Agency believes that the air concentrations of arsenic
while opening the cylinder door will not exceed the background
air arsenic dust levels of the plant. The Agency is considering
another modification (i.e., dust mask) in order to reduce this
background (ambient) arsenic exposure (see Section V.B.S.b.iv).
621
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following treatment). However, the Agency believes that an
applicator wearing this protective clothing and a respirator
while perfoming these activities will have a significantly
reduced inhalation (by 90%) and dermal exposure (by 80%),
resulting in significantly reduced risks.
hearing a respirator during the non-pressure spray operations of
penta reduces the total estimated lifetime oncogenic risk from
9.8 x 10 to 8.3 x 10 , and increases the fetotoxic MOS
from 10 to 12. Wearing a respirator while spraying sodium penta
for sapstain control reduces the total estimated lifetime onco-
genic risk from 1.9 x 10 to 1.6 x 10 ; the fetotoxic MOS
is increased from 50 to 590. Although the reduction in risk
with respirators does not appear to be particularly great, the
Agency believes that, at least during the actual spraying
process, there is a potential for significant applicator expo-
sure to airborne droplets or mist containing the preservative if
a. respirator is not worn.
For the wood preserving industry which uses pressure treatment,
the cost of this protective clothing and respirators ranges
from $368,000 to $446,000 per year, or about $2,194 to $3,474
per plant annually. The cost depends on the number of workers
in the plant and assumes that some protective clothing is
already provide to employees (Mitre, 1980).
For the wood preserving industry which uses non-pressure treat-
ment to preserve wood, the implementation of this modification
622
-------
would cost as follows: for sapstain control, $2,194 to $3,475
annually, per plant, with a total cost to the sawmill industry
of $2.56 million to $4.16 million; for raillwork and plywood,
$2,194 to $3,474 annually, per plant, with a total cost to the
millwork and plywood industries of $2.56 million to $4.16
million; and for the one plant, involved in producing penta-
treated particleboard, the cost would range from $2,194 to
$3,474, (Mitre, 1980; EPA, 1980). These cost estimates assume
that some of these protective clothing and equipment are
currently supplied to the applicators by the plant.
iv. Dust Masks
Hie manual opening and emptying of bags (or other containers) ot
prilled or powder formulations of penta or sodium penta, or
powder formulations of the inorganic arsenicals are activities
where inhalation exposure has been shown to be high (see
Sections V.B.l.b.ii and V.B.l.c.ii). The ambient air of plants
treating with the inorganic arsenical compounds contains
microscopic particles of arsenic. The arsenic dust is evenly
distributed throughout the plant, rather than being localized,
and poses an oncogenic risk of 1.9 x 10 to all treatment
workers breathing this ambient air.
To reduce this inhalation exposure, the Agency will consider
requiring applicators and personnel (see discussion under
Section V.B.I for definition of applicator) working outdoors in
arsenical wood treatment plants to wear a disposable dust mask
623
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which traps 80% of 5-micron or greater particulates. This dust
mask will also be considered for applicators who empty bags of
prilled or powder formulations of penta or sodium penta, or
powder formulations of inorganic arsenicals, or who mix these
powder or prilled formulations where closed emptying and
closed mixing systems are not used.
Wearing a dust mask while working outdoors in an arsenical wood
treatment plant reduces the total inhalation exposure from 10 to
2 ug/kg/day. The total lifetime oncogenic risk from exposure to
the inorganic arsenicals during this activity is reduced from
1.9 x 10~^ to 3.8 x 10 , and the teratogenic/fetotoxic MOS
is increased from 500 to 2,500.
Wearing a dust mask during the emptying of bags of inorganic
arsenical powder formulations reduces the total exposure from
17.0 to 4.6 ug/kg/day. The total lifetime oncogenic risk trom
exposure to the inorganic arsenicals during this activity is
— 2 —2
reduced from 3.4 xlO to 1.17 xlO , and the teratogen-
ic/fetotoxic MOS is increased from 294 to greater than 1,000.
The risk of lung cancer, which is primarily related to inhala-
— 2 —3
tion exposure, is reduced from 2.8 x 10 to 5.7 x 10
Wearing a dust mask during the emptying of bags of prilled or
powder penta or sodium penta formulations reduces the lifetime
oncogenic risk due to HxCDD exposure from a range of
7.3 x 10~3 to 1.5 x 10~2 to a range of 1.7 x 10~3 to
624
-------
7.8 x 10 . The fetotoxic MOS is increased from a range of
6.4 to 13 to a range of 8.9 to 57.
For the wood preserving industry which uses pressure treatment,
the cost of a dust mask for an applicator would cost about $120
per year, or about $1,200 to $6,000 per plant annually,
depending on the number workers in the plant. The total
cost to the wood preserving industry ranges from $1.08 million
to $1.56 million annually. This cost estimate assumes that the
plants do not provide dust masks to its employees.
For the wood preserving industry which uses non-pressure
treatment to preserve wood, the implementation of this
modification would cost as follows: for sapstain control,
$1,200 annually per plant with a total cost to the sawmill
industry of $2.4 million for millwork and plywood, $360 to $600
annually per plant with a total cost to the millwork and plywood
industries of $0.72 million to $1.2 million; and for the one
plant involved in producing penta-treated particleboard, the
cost for dust masks would be $1,200 annually. These cost
estimates assume that the plants do not provide employees with
the protective clothing.
v. Require Proper Disposal of Protective Clothing
Although not quantified, there are potential risks from creo-
sote, the inorganic arsenicals and penta containing dust or
solutions which stick to protective clothing and work shoes, and
625
-------
are transported from the treatment plant into the home. This
creates a potential exposure to the workers' families.
To eliminate this potential source of exposure, the Agency will
consider the requirement that wood treatment plant workers leave
all protective clothing and work shoes or boots/ at the plant at
the end of the day. This modification will also require that
worn-out protective clothing be disposed of in accordance with
the instructions for the pesticide container disposal.
The economic impacts to the wood treating industry are minor for
leaving protective clothing at the plant. Currently, 75% of
protective clothing is left at treatment plants (Mitre, 1980).
The cost for this modification entails the purchase price of one
or two pairs of work shoes or boots per year. This cost ranges
from $30 to $80. For the pressure treatment industry, the cost
would range from $1,900-5,000 for large plants and $570-1,500
for small plants (Mitre, 1980)
The cost for work shoes or boots to the non-pressure treatment
industry are: $300 to $800 per plant annually (sapstain
control); $150 to $400 per plant annually for millwork and
plywood; and $300 to $800 for the one plant that treats
particleboard with penta.
626
-------
vi. Prohibit Eating, Drinking, and Smoking During Application
It is not unusual for plant workers to eat their lunches and
smoke in the yard around stacks of treated wood thus creating a
potential for accidental ingestion through contamination of
food and drinks and inhalation by smoking. Although the risks
of accidental contamination with wood preservatives through
eating, drinking and smoking have not been quantified, the
Agency believes there is a potential risk from these activities.
To achieve a reduction in these risks, the Agency will consider
the prohibition of eating, drinking and smoking by applicators
during the application of the wood preservatives or in the
immediate vicinity of application. In the implementation of
this modification, the Agency would require that wood treatment
plants provide designated areas for eating, drinking and
smoking.
The costs of implementing this modification have not been
quantified, but they are not expected to be large.
vii. Confine Bnptying and Mixing Operations to Closed Systems
(Powder and Prilled Formulations)
In a number of small wood treatment plants, the applicators open
bags (or other containers) and empty by hand prilled or powder
formulations of penta or sodium penta, or powder formulations of
the inorganic arsenical compounds into the dissolving tanks
627
-------
(creosote is not formulated as a powder). This open system of
transferring and mixing these formulations with solvents poses
an extremely high degree of dermal and inhalation exposure to
the applicator. As discussed previously in this section, gloves
and coveralls have limited effectiveness in reducing the dermal
exposure; a dust mask provides some reduction in inhalation
exposure.
To reduce this exposure, the Agency will consider requiring
closed systems for the emptying and mixing of powder formula-
tions of the inorganic arsenicals, and prilled or powder formu-
lations of penta and sodium penta. An example of an acceptable
closed emptying and mixing system is one in which powder or
prilled formulations are unloaded by pneumatic equipment from a
hopper truck or railroad car directly into the closed dissolving
(mixing) tanks.
Implementation of this modification is expected to reduce the
applicator exposure to penta, sodium penta, and the inorganic
arsenicals to a level that is comparable to the background
(ambient) air levels in the plant.
Although the exact number of treatment plants which manually
empty or mix prilled and powder formulations of penta and
sodium penta, or the inorganic arsenical powder formulations
is not known, the Agency estimates that the cost of installing
these closed systems would be about $10,000 to $12,000 per plant.
628
-------
viii. Classify for Restricted Use
The Agency believes that education and training regarding
pesticide application would increase the care with which the
wood preservatives are handled and applied, thereby lowering
exposure to these wood preservative chemicals by some finite
amount. Therefore, the Agency will consider ciassifing the wood
preservatives as restricted use pesticides. Classifying the
wood preservatives for restricted use would require a minimum of
one certified applicator per plant. This modification has the
potential to reduce exposure as a result of educational mea-
sures, especially in the small treatment plants where applica-
tors have little or no guidance. The Agency recognizes that
there would probably be only a small impact on exposure to
applicators in the larger automated plants.
The total cost of implementing this modification to the pressure
treatment industry ranges from $12,000 to $24,500 or about $25
to $50 per plant. The costs to the non-pressure treatment
industry is $36,000 to $72,000 each for the sapstain, and
millwork and plywood industries, and $25 to $50 for the one
plant treating particleboard with penta.
ix. Reduce Arsenic Surface Residues on Treated Wood
Workers in treatment plants that apply inorganic arsenical for-
mulations are subject to oncogenic, teratogenic and mutagenic
risks via inhalation of background (ambient) arsenic dust. This
629
-------
dust results from the leaching, drying, and subsequent flaking
off of the inorganic arsenical formulations from the surface of
the treated wood which is drying in the yards. Treatment plant
applicators are also exposed to residues of arsenic via handling
of dry treated wood.
lo reduce this source of inhalation and dermal exposure to the
treatment plant applicator, the Agency will consider requiring
the applicators to filter the treatment solutions prior to use
in the treatment cylinders and to include an additional vacuum
step prior to the removal of the treated wood from the treatment
cylinders. In addition to these requirements, the Agency will
consider recommending the use of wood that is free of heavy
resins ("clean" wood), the post-treatment rinsing of the treated
wood, and the installation of protective sheds or covers over
the drying treated wood.
Reducing surface residues of arsenic on the treated wood is
expected to reduce the inhalation and dermal exposure to an
applicator; and additional risk reductions would also be
achieved by reducing the dermal and inhalation exposure to the
end-users of the treated wood. End-users of the treated wood
include children coming into contact with arsenically treated
playground equipment and workers handling arsenically treated
wood and breathing arsenic dust generated while sawing treated
wood.
630
-------
The costs of the proposed measures will vary. Most treatment
plants already have a filter system in place, and therefore the
cost of this proposed requirement would be miminal. The cost of
requiring an additional vacuum stage varies from $2 to $5 per
1,000 board feet of lumber depending on the type of formulation
used. The costs of the recommended final washing of the treated
wood would range from $7 to $13 per 1,000 board feet of lumber,
and rainfall protection sheds cost approximately $4 per 1,000
board feet of treated lumber. The cost of starting with clean
wood is expected to be negligible (Mitre, 1980a).
x. Reduce Contaminants in Penta and Sodium Penta
Applicators in treatment plants that apply penta or sodium penta
are exposed to hexachlorodibenzo-p-dioxin (HxCDD), a carcino-
genic contaminant found in penta and sodium penta. This contam-
inant is formed in technical penta and sodium penta during the
manufacturing process. Although most technical penta products
on the market contain about 15 ppm HxCDD, technical penta can be
produced with as little as 1 ppm HxCDD (e.g., Dowicide EC-7).
To reduce this source of exposure to the HxCDD contaminant in
penta and sodium penta, the Agency will consider requiring that
technical penta and sodium penta contain no more than 1 ppm
HxCDD. By lowering the amount of HxCDD in technical penta and
sodium penta, the exposure to HxCDD in all situtions would be
about one-fifteenth of the present exposure. This action would
reduce oncogenic risk by a factor of 15 in all situations. The
631
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TABIE V.B-1
Cncogenic Risk Reduction Resulting fron Induction of HxCDD Contamination of
Penta and Sodium Penta Products
Situation
Initial Risk
Final Risk
1. Pressure Ireatment Plants
a. General Operations Negligible
b. Opening cylinder Door
c. Bag Bnptying
6.4 x 10
7.3 x 10'
to
1.5 x 10'
-4
-3
7.1 x 10
9.8 x 10
2. Mill work and Plywood
a. Dipping
b. Spraying
3. Sapstain Control
a. Dipping 7.1 x 10
b. bpraying 1.9 x 10
-3
-3
-4
-3
Negligible
4.3 x 10
.-5
4.9 x 10
to
1.0 x 10
4.7 x 10
6.5 x 10'
4.7 x 10
r4
-3
r4
r4
,-5
1.3 x 10
,-4
632
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resulting estimates of reductions in oncogenic risk are pre-
sented in Table V.B-1 for pressure and non-pressure treatment
plants.
The cost of implementating this modification is based on a
registered product, Dowicide EC-7, made by Dow Chemical Company,
which has lower dioxin contaminants (about 1 ppm HxCDD) than
other registered technical grade products on the market. Dioxin
levels were reduced in this product through alterations in the
manufacturing process. Other companies can also presumably
develop manufacturing processes to lower the level of dioxin
contaminants in their products.
4. Selection of. Regulatory Options and Modifications for
Treatment Plants
This section presents the selected regulatory options for all
uses for which wood is treated at a treatment plant with creo-
sote, the inorganic arsenicals, or penta and sodium penta. When
the Option 2, Modifications of the Terras and Conditions of
Registration, has been selected, this section will present the
modifications to the terms and conditions of registration which
the Agency has determined will reduce the risk of concern to an
acceptable level when considered with the benefits of the
pesticides' use.
Because the risks to the treatment plant workers associated with
the uses of railroad ties, lumber, timber and plywood, pilings,
633
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posts, crossarms, poles, sapstain control, millwork and plywood
and particleboard are unacceptably high, the Agency has not
selected Option 1, Continued Registation without changes. How-
ever, the benefits from the use of wood preservatives on the
large number of treated wood products are extremely high. More-
over, the impacts of the cancellation of the three wood preserva-
tives may have been underestimated since the required technology
changes resulting from this cancellation scenario cannot be
fully assessed. The effects of a cancellation of individual
preservative chemicals would be major for certain uses because
of the non-substitutability of the chemicals for specific use
sites. Moreover, given the uncertainty associated with quanti-
fying the risk for each of these chemicals and exposure situa-
tions, it is not clear whether alternative chemicals are lower
in risk than the chemical of choice for any given use situation.
Based on these considerations, the Agency chose to carefully
identify and implement a range of measures which would reduce
exposure to each of the three wood preservatives for each of its
uses. This approach maximally reduces risk while still pre-
serving the extremely large wood preservative benefits. This
section discusses the specific modifications for each wood
preservative chemical, the rationale for the selection of the
proposed modifications and the overall risk reduction achieved
for each chemical by implementation of each modification.
634
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a. Creosote
The risks associated with creosote have not been quantified due
to the lack of data and human exposure to the individual com-
ponents of creosote and the carcinogenic potential of these
components.
The Agency has determined that applicators who are exposed to
creosote may be subjected to a significant oncogenic risk, in
addition, the Agency has also determined that the benefits of
the chemical are very high (99% of all railroad ties are treated
with creosote). The major alternatives to creosote are penta,
copper naphthenate, and/or concrete. The properties of inor-
ganic arsenical-treated ties make it unsuitable as an alterna-
tive to creosote-treated ties, and concrete and/or other
preservative-treated ties are considerably more expensive.
Hence, if creosote were cancelled, it could be replaced by a
chemical (penta) which has known adverse human health effects;
since the risks to creosote are not quantifiable, it is not
possible to determine if there would be a net gain in risk
reduction from this measure. The Agency has determined,
however, that there would be severe adverse economic impacts on
both the wood treating industry and the railroad industry if
creosote were cancelled.
The Agency has, therefore, selected Option 2, Modifications to
the Terms and Conditions of Registration, for the uses of
635
-------
creosote; the selected modifications are designed to reduce the
risks associated with exposure to creosote and creosote-treated
wood while preserving the benefits.
b. Inorganic Arsenical Compounds
With regard to arsenic, the proposed modifications increase the
teratogenic/fetotoxic margins of safety for various activities
from the 100 to 500 range, which is considered marginal by the
Agency, to 2,000 to 3,000 MOS range during other activities
which the Agency considers acceptable.
In terras of the total oncogenic risk reduction, the initial
— 2 —3
risks are reduced from the 10 range to the 10 range. It
must be noted that this risk represents an absolute worst case
estimate and the Agency believes that the actual risks encounted
by the inorganic arsenical wood preservative applicators (plant
workers) could be at least one order of magnitude lower than
those presented in this document.
Even though there is uncertainty associated with the risk
numbers, the benefits from the use of inorganic arsenicals to
treat wood are extremely high and a low number of applicators
are involved. Based on efficacy and other performance
characteristics, inorganic arsenical-treated wood is suitable
for most end-uses of lumber, timber, and plywood. Inorganic
arsenical-treated wood is clean, odorless, paintable, easy to
handle, harmless to plants and durable compared to either penta-
636
-------
or creosote-treated wood. The number of inorganic arsenical
wood treatment applicators at risk ranges from 1,000 to 2,000
persons; hence 20-40 individual may contract cancer in their
lifetimes (70 years) for the entire industry if no protective
measures are followed. The implementation of the proposed
modifications reduces the total estimated incidence of cancer to
1-2 individuals for the inorganic arsenical industry.
In view of the risk reduction which can be achieved by the
proposed modifications (see Tables V.B-2, 3 and 4), the Agency
has determined that cancellation is not necessary to assure that
the use of the inorganic arsenical compounds will not cause
unreasonable adverse effects on the environment. The Agency has
selected Option 2, Modifications of the Terms and Conditions of
Registration, and the Agency believes that these modifications
will provide adequate protection for the applicator when these
risks are considered in terms of the high benefits of the
chemical.
Penta
The application of penta as a wood preservative poses oncogenic
— 4 — 2
risks that range from 10 to 10 and fetotoxic margins of
safety as low as 6. Although the Agency considers the above
risks unacceptable, the Agency also realizes that these risks
are based on worst case estimates of exposure. However, the
Agency has determined that by implementing the selected modifi-
cations to the terms and conditions of registration, the risks
637
-------
would be reduced to an acceptable level (10 to 10 for
oncogenic risk and margins of safety greater than 400 for feto-
toxicity). Penta is a versatile chemical with high benefits
from its continued use as a wood preservative. The Agency has
determined that the risk reduction resulting from the selected
modifications will provide adequate protection for the appli-
cator when these risks are considered in terms of the high
benefits of the chemical (see Tables V.B-5 and 6).
d. Specific Options Selected
For creosote use on railroad ties, lumber, timber and plywood,
pilings, posts, crossarms, and poles, the Agency proposes
continued registration with the following modifications:
— Require Gloves (when hand dermal contact with
preservatives is possible)
— Require Neoprene Suit and Respirator (when entering
cylinders)
— Require Gloves and Respirator (when opening cylinder
doors following treatment)
— Require Proper Disposal of Protective Clothing
638
-------
— Prohibit Eating, Drinking, and Smoking During
Application (designated areas will be provided in the
treatment plant)
— Classify tor Restricted Use (all uses)
For the inorganic arsenical compounds the following
modifications to the terms and conditions of registration have
been selected:
— Require Gloves (when hand dermal contact with
preservatives is possible)
-- Require Neoprene Suit and Respirator (when entering
cylinders)
— Require Dust Mask (when working within the outside
confines of the treatment plants)
— Require Proper Disposal of Protective Clothing
— Prohibit Eating, Drinking, and Smoking During
Application (desginated areas will be provided in the
treatment plant)
— Confine Emptying and Mixing Operations to Closed
Systems (powder formulations)
639
-------
— Classify for Restricted Use (all uses)
Arsenic Surface Residues on Treated Wood
The Agency has not selected the following modifications:
— Require Coveralls and Gloves (when emptying containers
of or mixing powder formulations).
— Wear dust mask (when emptying bags or containers of
or mixing powder formulations)
Implementation of the selected modification, Confine Emptying
and Mixing Operations to a Closed System, precludes the neces-
sity of wearing coveralls because the selected modification
eliminates this source of dermal exposure. Implementation of
this selected modification also eliminates this source of
potential inhalation exposure; therefore, dust masks will not be
required for bag emptying.
For penta or sodium penta the Agency has selected the following
modifications to the terms and conditions of registration for
use on railroad ties, lumber, timber and plywood, pilings,
posts, crossarms, poles, sapstain control, millwork and plywood,
and particleboard:
— Require Gloves (when hand dermal contact with
preservatives is possible)
640
-------
Require Gloves and Respirator (during spray application
and when opening cylinder doors following treatment)
Require Neoprene Suit and Respirator [when entering
cylinders (pressure treatment plants) and vats
(non-pressure treatment plants)]
— Require Proper Disposal of Protective Clothing
— Prohibit Eating, Drinking, and Smoking During
Application (designated areas will be provided in the
treatment plant)
— Confine Emptying and Mixing Operations to Closed
Systems (powder or prilled formulations of penta or
sodium penta)
— Classify for Restricted Use (all uses)
The Agency has not selected the following modifications:
— Require Coveralls and Gloves (when emptying bags or
containers of or mixing prilled or powder formulations)
— Reduce Contaminants in Penta and Sodium Penta
— Require Neoprene Suit (spray operations)
-------
— Wear dust mask (when emptying bags or containers of
prilled or powder formulations of penta or sodium
penta)
Implementation of the selected modification, Confine Emptying
and Mixing Operations to a Closed System, precludes the neces-
sity of wearing coveralls because the selected modification
eliminates this potential source of dermal exposure. Imple-
mentation of the selected modification also eliminates this
source of potential inhalation exposure; therefore, dust masks
will not be required.
The Agency has not selected the modification, Reduce Contamin-
ants in Penta, primarily because acceptable levels of risk are
achieved with the other modifications that are being proposed.
While companies other than the Dow Chemical Company may have the
technical capability to produce penta with only 1 ppm of HxCDD
in their products, the Agency believes that requiring production
conversion to the purer form of penta would cause these com-
panies to totally cease manufacturing this wood preservative
because of cost considerations.
In addition, the Agency did not select the requirement of
neoprene suits for spray operations for treating wood for
sapstain control and treating millwork and plywood, as the
Agency believes that dermal exposure to these applicators occurs
almost entirely via the hands (see Tables V.B-2 and 3 for
642
-------
reduction of risks provided by the use of rubberized gloves and
a respirator).
The Agency has determined that implementing the modifications
selected above for creosote, the inorganic arsenicals and penta
will reduce the risks to acceptable levels when considered in
light of the benefits of these uses, and that the use of these
wood preservatives for treatment of wood will not cause
unreasonable adverse effects on the environment.
643
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TABLE V.B-2
Lifetime Cancer Risk from Arsenic Exposure
Situation Initial hisk Gloves
1. Pressure Treatment Plants
a. Background (total) 1.9 x 10~2 1.9 x 10~2
b. Bag Emptyping
i. Inhalation 2.8 x 10 2.8 x 10~2
li. Dermal 6.0 x 10~3 4.4 x 10~3
iii. 'iotal 3.4 x 10~2 3.2 x 10~2
c. Mixer (concentrate)
i. Inhalation 1.9 x 10~2 1.9 x 10~2
ii. Dermal 9.B x 10~2 1.3 x 10~3
iii. lotal 1.17 x 10"1 2.0 x 10~2
d. Mixer (dilute)
i. Inhalation 1.9 x 10~2 1.9 x 10~2
ii. Dermal 7.0 x 10~3 1.0 x 10~2
iii. Total 2.6 x 10~2 1.91 x 10~2
e. handler (treated wood)
i. Inhalation 1.9 x 10~2 1.9 x 10~2
ii. Dermal 7.0 x 10~J 1.0 x 10~2
iii. Total 2.6 x 10~2 1.91 x 10~2
644
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TABLE V.B-2 (continued)
Lifetime Cancer Risk from Arsenic Exposure
Situation
Initial Risk
1. Pressure Treatment Plants
a. Background (total) 1.
9
x 10~ 2
Dust Mask
3.
8
x 10~3
Gloves and
Coveralls
1
.y
x 10 2
b. Bag Bnp typing
i.
ii.
iii.
Inhalation
Dermal
Total
2.
6.
3.
8
0
4
x 10"2
x 10~3
x 10~2
5.
6.
1.
7
0
17
x 10~3
x 10~3
x 10~2
2
2
3
.8
.0
.0
x llf2
x l(f 3
x l(f 2
c. Mixer (concentrate)
i.
ii.
iii.
Inhalation
Dermal
•total
1.
9.
1.
9
8
17
x 10~2
x 10~2
x 10"1
3.
9.
1.
8
8
0
x 10~ 3
x 10~2
x 10"1
1
1
2
.9
.0
.0
x ilf ^
x l(f 3
x 10~2
d. Mixer (dilute)
i.
ii.
iii.
Inhalation
Dermal
Total
1.
7.
2.
9
0
6
x 10~2
x 10~3
x l(f 2
3.
7.
1.
b
0
1
x 10" 3
x 10~3
x 10~2
1
6
1
.9
.8
.91
x llf 2
x llf5
x 10~2
e. Handler (treated wood)
i.
ii.
iii.
Inhalation
Dermal
Total
1.
7.
2.
9
0
6
x 10~2
x 10"3
x 10"2
3.
7.
1.
8
0
1
x 10~3
x 10~3
x 10~2
1
6
1
.9
.8
.91
x 10~2
x l(f 5
x llf2
645
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TABLE V.B-2 (continued)
Lifetime Cancer Risk from Aresnic Exposure
Situation
Initial Risk
1. Pressure Treatment Plants
a. Background (total) 1.
b. Bag
i.
ii.
iii.
Bnptyping
Inhalation
Dermal
Total
2.
6.
3.
9 x 10~2
8 x 10~2
0 x 10~3
4 x 10~2
Gloves and
Dust Mask
3
5
4
1
.8
.7
.4
.0
x 10"3
x 10
x 10"3
x 10"2
Gloves, Dust
Mask, and
Coveralls
3
5
1
1
.8
.7
.3
.0
x 10~3
x 10~3
x 10~3
x 10~3
c. Mixer (concentrate)
i.
ii.
iii.
Inhalation
Dermal
Total
1.
9.
1.
9 x 10~2
8 x 10~2
17 x lO'1
3
1
4
.8
.0
.8
x 10"3
x 10"3
x 10"3
3
1
4
.8
.0
.8
x 10~3
x 10~3
x 10~3
d. Mixer (dilute)
i.
ii.
iii.
Inhalation
Dermal
Total
1.
7.
2.
9 x 10 2
0 x 10~3
6 xlO-2
3
6
3
.8
.8
.9
x 10""3
x 10~5
x 10"3
3
6
•3
.8
.8
.9
x 10~3
x 10~5
x 10~3
e. Handler (treated wood)
i.
inhalation
1.
9 x 10~2
3
.8
x 10"3
3
.8
x 10~3
ii. Dermal 7.0 x 10
iii. Total 2.6 x 10
~3
~2
6.8 x 10
"5
3.9 x 10
"3
6.8 x 10
~5
1.91 x 10
~2
646
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TABLE V.B-2 (continued)
Lifetime Cancer Risk tram Arsenic Exposure
Situation
Initial Risk
Neoprene-Coated Cotton or
Rubberized Cverali, Jacket,
Gloves and Boots, and a
Kespirator
1. Pressure Treatment Plants
a. Background (total)
b. Bag Bnptyping
i. Inhalation
ii. Dermal
iii. lotal
c. Mixer (concentrate)
i. Inhalation
ii. Dermal
iii. Total
d. Mixer (dilute)
i. Inhalation
ii. Dermal
iii. Total
1.9 x 10
-2
2.U x 10
-2
6.0 x 10
-3
3.4 x 10
-2
1.9 x 10
-2
9.8 x 10
-2
1.17 x 10
-1
1.9 x 10
-2
7.0 x 10
-3
2.6 x 10
-2
e. Handier (treated wood)
i. Inhalation
ii. Dermal
iii. Total
1.9 x 10
-2
7.0 x 10
-3
2.6 x 10
-2
1.9 x 10
-3
1.9 x 10
-3
2.2 x 10
-3
4.1 x 10
-3
1.9 x 10
,-3
1.0 x 10
-3
2.9 x 10
-3
1.9 x 10
9.0 x 10
2.8 x 10'
1.9 x 10"
9.0 x 10"
2.0 x 10"
-3
-4
-3
647
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TABLE V.B-3
Lifetime Cancer Risk from Arsenic Exposure
Situation
Initial Risk
Gloves
1. Brush-on Non-pressure Application
i . Inhalation
ii . Dermal
iii . lotal
2. Sawing and Fabricating
i . Inhalation
ii . Gastrointestinal
iii. Dermal
iv. lotal
3. Residents in Homes
i. Homes with
Negligible
1.2 x 10~2
1.2 x 10~2
1.4 x 10~2
1.07 x 10'1
7.9 x 10~3
t0 -2
3.9 x 10
1.3 x 10"1
to _!
1.6 x 10
-------
TABLE V.B-3 (continued)
Lifetime Cancer Risk from Arsenic hxposure
situation
1.
2.
Brush-on Non-pressure
i . Inhalation
ii . Dermal
iii. 'ibtal
Sawing and Fabricating
i. inhalation
ii . Gastrointestinal
iii. Dermal
iv. lotal
Initial Risk
Application
Negligible
1.2 x 10~2
1.2 x 10~2
1.4 x 10~2
1.07 x 10"1
7.9 x l(f3
to
3.9 x 10
l.j x 10"1
to -1
1.6 x 10
Dust Mask
Negligible
1.2 x 10~2
1.2 x 10~2
2.6 x 10~J
7.9 x 10~3
t0 -2
3.9 x 10
1.1 x 10~2
t0 -2
4.2 x 10 ^
Gloves and
Coveralls
Negligible
<1.2 x 10~4
<1.2 x 10~4
1.4 x 10~2
1.07 x 10"1
<8.0 x 10~5
10 -4
<4.0 x 10
<1.2 x 10-i
3. Residents in Homes
i. Homes with
ireated Vvood
ii. Flooded Basement <10
-6
-7
Not Applicable Not Applicable
Not Applicable Not Applicable
649
-------
TABLE V.B-3 (continued)
Lifetime Cancer Risk from Arsenic Exposure
Situation
Initial Risk
Gloves and
Dust Mask
Gloves, Dust
Mask, and
Coveralls
1. Brush-on Non-pressure Application
i . Inhalation
ii . Dermal
iii. Ibtal
2. Sawing and Fabricating
i . Inhalation
ii . Gastrointestinal
iii. Dermal
iv. TC>tal
Negligible
1.2 x
1.2 x
1.4 x
lO'2
10"2
1C'2
Neglig ible
1.2
1.2
2.6
x 1C""4
x 10"4
x 10"3
Negligible
<1.2
<1.2
2.6
x 10"4
x 10"4
x 10"3
1.07 x 10"1
7.9 x
to
3.9 x
1.3 x
to
1.6 x
io-3
1C'2
10'1
ID'1
8.0
to
4.0
2.7
to
3.0
x 10~5
x 10~4
x 10~3
x 10"3
<8.0
to
<4.0
<2.7
to
<3.0
x 10"5
x 10~4
x 10"3
x 10"3
3. Residents in Banes
i. Homes with
Treated Wood
ii. Flooded Basement <10
-6
-7
Not Applicable Not /^>plicabie
Not Applicable Not Applicable
650
-------
TABLE V.B-3 (continued)
Lifetime Cancer Risk from Arsenic Exposure
Situation
Initial Risk
Neoprene-Coated Cbtton or
Rubberized Overall, Jacket
Gloves and Boots, and a
Respirator
1. Brush-on Non-pressure Application
i. Inhalation
ii. Dermal
iii. IDtal
2. Sawing and Fabricating
i. Inhalation
iii. Dermal
iv. 'iotal
3. Residents in Homes
i. Homes with
'Ireated Vvood
Negligible
2
1.2 x 10
1.2 x 10
-2
1.4 x 10
-2
ii. Gastrointestinal 1.07 x 10
-1
7.9 x 10
to
3.9 x 10
-3
-2
1.3 x 10
to
1.6 x 10
-1
-1
ii. Flooded Basement <10
-7
Not Applicable
Not Applicable
Not Applicable
Not Applicable
Not Applicable
Not Applicable
Not Applicable
Not Applicable
Not Applicable
-------
TABLE V.B-4
Impact of Modifications on Teratogenic/Fetotoxic Margins of Safety tor Arsenic
Situation Initial Risk
1.
a
b
c
d
e
2.
3.
Pressure Treatment Plants
. Background
. Bag Bnptyping
. Mixer (concentrate)
. Mixer (dilute)
. handler (treated wood)
Brush-on Non-pressure
Application
Sawing and Fabricating
500
294
135
417
417
1,667
106-128
Gloves
500
310
487
499
499
170,000
135
4. Residents in Homes
i. Homes with 128,200
Treated Wood
ii. Flooded Basement 1,923
Not Applicable
Not Applicable
652
-------
TABLE V.B-4 (continued)
Impact of Modifications on Teratogenic/Eetotoxic Margins of Safety for Arsenic
Situation Initial Risk
1.
a
b
c
d
e
2.
3.
Pressure Treatment Plants
. Background
. Bag Bnptyping
. Mixer (concentrate)
. Mixer (dilute)
. Handler (treated wood)
Brush-on Non-pressure
Application
Sawing and fabricating
500
294
135
417
417
1,667
106-128
Dust Mask
2,500
Nat Applicable
Not Applicable
Not Applicable
Not Applicable
Not Applicable
Gloves and
Coveralls
>500
326
>487
>499
>499
>170,000
140
4. Residents in Wanes
i. Homes with 128,200
Treated Vvbod
ii. Flooded Basement 1,923
Not Applicable Not Applicable
Not Applicable Not Applicable
653
-------
TABLE V.B-4 (continued)
Impact of Modifications on leratogenic/Fetotoxic Margins of Safety for Arsenic
Situation Initial Risk
1. Pressure Treatment Plants
a. background
b. bag fcmptyping
c. Mixer (concentrate)
d. Mixer (dilute)
e. Handler (treated wood)
2. brush-on Non-pressure
Application
3. Sawing and Fabricating
500
294
135
417
417
1,667
106-128
Gloves and
Dust MasK
2,500
1,214
2,203
2,479
2,479
Not /Applicable
3,330
Gloves, Dust
MasK, and
Coveralls
Not Applicable
Not Applicable
Not Applicable
Not Applicable
Not Applicable
Not Applicable
3,520
4. Residents in Homes
i. Homes with 128,200
Treated wood
ii. Flooded Basement 1,923
Not Applicable Not Applicable
Not Applicable Not Applicable
654
-------
TABLE V.B-4 (continued)
Mpact of Modifications on Teratogenic/Fetotoxic Margins of Safety tor Arsenic
Situation
Initial Risk
4. Residents in Homes
i. Homes with 128,200
Treated Wood
ii. Flooded Basement 1,923
Neoprene-Coated Cotton or
Rubberized Overall, Jacket
Gloves and Boots, and a
Respirator
1.
a
b
c
d
e
2.
3.
Pressure Treatment Plants
. Background
. Bag Bnptyping
. Mixer (concentrate)
. Mixer (dilute)
. Handler (treated wood)
Brush-on Nan-pressure
Application
Sawing and Fabricating
500
294
135
417
417
1,667
106-128
5,000
2,724
3,937
4,916
4,916
Not Applicable
31,250
to 20,833
Not Applicable
Not Applicable
655
-------
TABLE V.B-5
Lifetime Cancer Risk From HxCDD Exposure
Situation
Initial Risk
Gloves
Gloves
& Coveralls
Pressure Treatment:
General
Operations
Opening
Cylinder
Door
Bag Emptying
Millwork &
Plywood (Dip)
Millwork i*
Plywood
(Spray)
Saps tain
Control (Dip)
Saps tain
Control
(Spray)
home & Farm:
During
Application
Negligible
—4
6.4 x 10 + dermal
7.3 x 10~3
to „
1.5 x 10
7.1 x 10~
9.8 x 10~J
7.1 x 10~4
1.9 x 10~3
_
1.0 x 10~
to a
1.3 x 10
Negligible
6.4 x 10"4
7.1 x 10~3
t0 -2
1.3 x 10
7.1 x 10~5
1.7 x 10~3
7.1 x 10~
3.4 x 10~4
1.0 x 10"
to ,
1.3 x 10
Negligible
6.4 x
6.6 x
to
8.2 x
7.1 x
1.7 x
7.1 x
3.4 x
1.0 x
to
1.3 x
ID'4
io-3
io-3
io-5
io-3
io-6
io-4
10~
10~6
656
-------
TABLE V.B-5 (continued)
Lifetime Cancer Risk from HxCED Exposure
Situation
Initial Risk
Respirators
Gloves & Respirator
Pressure Treatment :
General
Cperations
Cpening
Cylinder
Door
Bag Emptying
^allvvorK &
Plywood (Dip)
Mi 11 work &
Plywood
(Spray)
Saps tain
Control (Dip)
Saps tain
Control
(Spray)
Home & Farm:
During
/^plication
Negligible
6.4
7.3
to
1.5
7.1
9.8
7.1
1.9
1.0
to
1.3
—4
x 10 + dermal
x 10~3
x 10~2
x 10~3
x 10~3
x 10~4
x 10~3
x I0"b
x 10~4
Negligible
6.4 x 10~5 H
1.5 x 10~3
t0 -3
9.4 x 10
7.1 x 10~3
8.3 x 10~3
7.1 x 10~4
1.6 x 10~3
1.0 x 10~6
t0 -4
1.3 x 10
Negligible
K dermal 6.4
1.3
to
6.9
7.1
2.4
7.1
4.B
1.0
to
1.3
x 10 5
x 10~3
x 10~3
x 10~5
x 10~4
x 10~b
x 10~5
x 10"8
x 10~b
S57
-------
TABLE V.B-5 (continued)
Lifetime Cancer Risk from HxCED Exposure
Situation
Initial Risk
Neoprene-Coated
Cotton or Rubber-
ized Overalls,
Jacket, Gloves and
Boots
Neoprene-Coated
Cotton or Rubber-
ized Overalls,
Jacket, Gloves and
Boots, and a
Respirator
Pressure Treatment:
General
Cperations
Opening
Cylinder
Door
Bag Emptying
Millwork &
Plywood (Dip)
Millwork &
Plywood
(Spray)
Saps tain
Control (Dip)
Saps tain
Control
(Spray)
Home & Farm:
During
Application
Negligible
6.4
7.3
to
1.5
7.1
9.8
9.1
1.9
1.0
to
1.3
4
-4
x 10 + dermal
x 10"3
x 10~2
x 10~3
x 10~3
x 10~4
x 10~3
x 10~6
x 10~4
Negligible
i
6.4
6.6
to
8.2
7.1
1.7
7.1
3.4
1.0
to
1.3
x 10~4
x 10~3
x 10~3
x 10~5
x 10~3
x 10~6
x 10~4
x 10~8
x 10"6
Negligible
6.4 x 10~5
8.2 x 10~4
to _
2.4 x 10
7.1 x 10"5
2.4 x 10~4
7.1 x 10~6
4.8 x 10~5
1.0 x 10~8
to ,
1.3 x 10
658
-------
TABLE V.B-6
tetotoxic Margins of Safety for Penta Exposure
Situation
Initial Risk Gloves Gloves & Coveralls
Pressure treatment:
General
Operations
Cpening
Cylinder
Door
Bag Emptying
Millwork &
Plywood (Dip)
Miilvvork &
Plywood
(Spray)
Saps tain
Control (Dip)
baps tain
Control
(Spray)
730 730 730
150 + dermal 150 150
6.4 to 13 7.7 to 14 12 to 15
5.9 210 210
10 57 57
59 6,000 6,000
50 290 290
Home & Farm:
During
Indoor
Application
Home & Farm:
During
Outdoor
Application
6 to 400
6 to 650
360 to 900
560 to 7,100
360 to 900
560 to 7,100
660
-------
TABLE V.B-6 (continued)
Fetotoxic Margins of Safety for Rsnta Exposure
Situation
Initial Risk Respirators Gloves & Respirators
Pressure Treatment:
Cfeneral
Operations
Opening
Cylinder
Door
Bqg Emptying
Millwork &
Plywood (Dip)
Mi 11 work &
Plywood
(Spray)
Sapstain
Control (Dip)
Sapstain
Control
(Spray)
Home & Farm:
During
Indoor
Application
730 7,300 7,300
150 + dermal 1,500*+ dermal 1,500
6.4 to 13 10 to 64 14 to 7b
5.9 6 510
10 12 400
59 60 6,CvO
50 590 2,000
6 to 400 6 to 660 560 to 8,100
Bane & Farm:
During
Outdoor
Application
6 to 650
6 to 710
600 to >10,000
661
-------
TABLE V.B-6 (continued)
Fetotoxic Margins of Safety for Benta Exposure
Situation
Initial Risk
Neoprene-Goated
Cotton or Rubber-
ized Overalls,
Jacket, Gloves
and Boots
Neoprene-Goated
Cbtton or Rubber-
ized Overalls,
Jacket, Gloves
and Boots, and a
Respirator
Pressure Treatment:
General
Operation
Opening
Cylinder
Door
Bag imptying
Millwork &
Plywood (Dip)
Home & Farm:
During
Indoor
Application
Home & Farm:
During
Outdoor
Application
730
150 + dermal
6.4 to 13
5.9
Millwork &
Plywood
(Spray)
baps tain
Control (Dip)
Saps tain
Control
(Spray)
10
59
50
6 to 400
730
150
12 to 15
210
57
6,000
290
360 to 900
6 to 650
560 to 7,100
7,300
1,500
41 to 120
510
400
6,000
2,000
560 to 8,100
600 to >10,000
662
-------
C. Use Categories: Pesticides Applied Outside of Treatment
Plants
The following discussions refer to those uses for which applica-
tion ot the wood preservative does not take place in a treatment
plant. The uses are poles-groundline, home and farm, and com-
mercial brush-on applications of the inorganic arsenicals.
Poles-groundline application refers to the treatment of tele-
phone poles in a small area above and just below the ground-
line. Penta or creosote or a mixture of penta and creosote, are
used for this purpose. The use category of home and farm
includes all applications of penta and creosote to wood by the
homeowner or farmer and by commercial applicators. Commercial
brush-on application refers to the application of the inorganic
arsenicals to the cut-ends of treated wood, an activity which
usually occurs at construction sites; these inorganic arsenical
formulations are not generally available for purchase by the
homeowner or farmer.
1. Summary of Risks
a. Poles-Groundline
i. Creosote
As discussed in Sections II.B.5 and II.B.6, creosote poses
oncogenic and mutagenic risks to humans; however this risk has
663
-------
not been quantified. There are very little data available
regarding a workers' exposure to all of the specific oncogenic
or mutagenic components of creosote. While the level of risk
cannot be quantified with the exposure information available,
there are many reports of incidences of skin cancer among
workers who apply creosote.
ii. Penta
Penta and its contaminants pose a risk of oncogenic and
fetotoxic effects in humans.
Dermal exposure to the workers who apply penta for poles-
groundline use occurs during the handling and application of
the wet paste. Although the Agency is unable to quantify the
exposure to poles-groundline applicators, the Agency believes
this exposure will occur primarily through the hands. Due to
the nature of the operation, however, some splattering of
treatment solution onto other areas of exposed skin may also
occur.
b. Home and Farm
i. Creosote
In addition to the potential risks associated with the applica-
tion processes discussed in the prior sections, there are
occasions when creosote is also sprayed onto the surfaces of
664
-------
wood. While the applicator's exposure during this process has
not been quantified, the Agency believes that exposure during a
spray operation will be greater than that experienced during
brush-on or dip applications.
ii. Penta
Penta and its contaminants pose a risk of oncogenic and feto-
toxic effects in humans.
The amount of dermal exposure to penta during home and farm
applications is dependent upon the care with which the product
is applied. The Agency estimates that homeowners may spill
amounts of penta formulation ranging from 1 drop (0.05 ml) to
6 ml on their skin during one brush-on application period.
These applicators may also be exposed to penta via inhalation.
In addition to the dipping and brushing of these penta products,
these preservatives are occasionally sprayed onto the surfaces
of wood. Although the Agency has not quantified the applicator
exposure during this type of application, data indicate that
this exposure is likely to be much greater than that encoun-
tered during brush-on or dip applications. The Agency has
estimated that the total lifetime oncogenic risks to the home
and farm applicators for penta use ranges from 1.0 x 10~ to
— 4
1.3 x 10 during application. The fetotoxic MOS ranges
from 6 to 400 for indoor application and from 6 to 650 for
outdoor application.
665
-------
c. Brush-On Applications of the Inorganic Arsenicals
The exposure to the inorganic arsenicals by commercial brush-on
treatment applications is caused by spilling or otherwise coming
in contact with the liquid formulations. The dermal exposure in
this situation is estimated to be 3 ug/kg/day, and the lifetime
_ 2
dermal oncogenic risk to brush-on applicators is 1.2 x 10 .
The teratogenic/fetotoxic MOS is estimated to bt 1,667. The
Agency has assumed that inhalation exposure would be negligible,
as brush-on treatments are applied outdoors using very small
volumes of treatment solution.
2. Summary of Benefits
a. Poles-Groundline
The poles-groundline treatment of in-place utility poles is a
small, but an increasingly important segment of the wood treat-
ment industry. In poles-goundline treatment, wood preservatives
are applied to a previously installed pressure treated pole over
a section covering the six inches above and the six inches below
the ground level of the pole. This treatment can delay decay
and subsequent pole failure for 20 years or more.
The two major formulations of commercial poles-groundline
treatments marketed in the United States contain both creosote
and penta; one of these formulations has a high creosote content
and the other a high penta content (this product also contains
166
-------
sodium fluoride). Currently, the high creosote formulation is
used for about 66% of all poles-groundline treatments and the
high penta content product is used for about 33% of the poles-
groundline treatments. The number of utility poles receiving
poles-groundline treatment in the United States was estimated to
be approximately 1 million in 1978.
The Agency has evaluated the benefits of penta and creosote for
poles-groundline treatments and has determined the economic
impacts if penta, creosote, or both were cancelled for this
use. If either penta or creosote were cancelled, there would be
minor adverse first year and annual long-term impacts because
the remaining registered wood preservative would be substituted
for the cancelled one.
If both penta and creosote were cancelled for the groundline
treatment of poles, there would be a first year cost decrease of
$10 million to $12 million, but an average annual ("annualized")
cost increase of about $36.8 million. If the current level of
groundline treatment doubles in the next 5 years, as projected
by some experts, the increase in annualized pole replacement
costs would exceed $70 million. Thus, the cancellation of both
creosote and penta for poles-groundline treatment would result
in a major adverse economic impact.
667
-------
b. Home and Farm
Penta and creosote solutions are applied by homeowners, farmers,
and, to some extent, by on-the-job carpenters by brushing, rol-
ling, dipping, soaking or spraying methods. Typical treated
wood items include decks, siding, millwork, lumber, fences,
shingles, outdoor furniture and other miscellaneous wood pro-
ducts. These non-pressure applications of penta and creosote
extend the useful service life of wood in aboveground applica-
tions and provide limited protection for wood in contact with
the ground. About 1.6 million pounds of penta and 2.0 million
pounds of creosote are used around homes and farms to protect
various wood structures and products exposed to natural elements
There are several alternative wood preservatives registered for
home and farm uses, the most common being copper naphthenate,
copper-8-quinolinolate (Cu-8), zinc naphthenate and tributyltin
oxide (TBTO). Copper naphthenate is effective under certain
conditions but its overall performance is questionable, it
imparts a green color to the wood, makes a poor base for paint
and leaves the wood difficult to finish naturally. Zinc naph-
thenate, which imparts a colorless finish to wood, is considered
less efficacious than copper naphthenate. The TBTO formulations
are colorless in solution and leave the wood clear and paint-
able. This chemical has some known merit for protecting wood
aboveground, but is ineffective for ground contact use.
Registered Cu-8 formulations have demonstrated less effective-
ness in controlling rot and decay than either creosote, the
668
-------
inorganic arsenicals or penta. Alternatives to non-pressure
treatment with chemical agents include leaving the wood un-
treated, using nonwood materials (e.g., aluminum and concrete),
purchasing lumber which has been pressure treated, or using a
naturally resistant wood species; natural wood is, however, in
short supply.
The Agency has evaluated the benefits of the home and farm
uses of penta and creosote and has determined that there would
be a minor economic impact consisting of a slight increase in
preservative cost if creosote or penta were cancelled. The
chemical alternatives (copper naphthenate, copper-8-quinolino-
late, zinc naphthenate and tributyltin oxide) are currently
available to homeowners and farmers, but at prices which are
somewhat higher than the price of penta or creosote. These
alternatives do not have the wide range of control characteris-
tic of penta or creosote. Non-wood materials such as aluminum
and concrete can replace treated wood in some circumstances at
comparable prices; the comparability of cost does not, however,
take into account the aesthetic value of wood. The price of
pressure treated lumber is slightly higher than lumber treated
by brush-on or dip applications, but the pressure treatments
would provide better protection to the wood. However, the
inorganic arsenical-treated lumber can only be considered a
partial substitute for the home and farm uses of penta and
creosote since pressure treated lumber is not an alternative for
all non-pressure home and farm uses.
669
-------
c. Brush-On Applications of the Inorganic Arsenicals
The non-pressure treatments with the inorganic arsenicals are
not generally available to home and farm applicators because of
current marketing practices. About 2,000 to 3,000 gallons of 3%
inorganic arsenical solution is sold annually for field treat-
ment (outdoor applications only) of cut-ends of inorganic arseni-
cal-treated wood. The Agency has determined that due to the
small amounts of the inorganic arsenicals used for commercial
use, there would be a minor adverse economic impact if inorganic
arsenical formulations were cancelled tor commercial brush-on
applications because either penta or creosote are available as
alternatives for this purpose.
3. Risk/Benefit Analysis
a. Consideration of Regulatory Options
The Agency has determined, based on the risk and benefit data,
that the non-pressure treatment of wood for poles-groundline and
home and farm uses with creosote and/or penta, or commercial
brush-on applications of the inorganic arsenicals pose unreason-
able adverse effects on the environment. Therefore, the regis-
tration of these wood preservatives cannot be simply continued
for these uses. Cancellation of these wood preservatives for
each use is, however, not a desirable option because the alter-
natives (e.g., TBTO and Cu-8) have limited efficacy and moderate
economic impacts could result if the three wood preservatives
670
-------
were cancelled. Also, cancellation of one of the three wood
preservatives for a specific use is not likely to appreciably
reduce risks since the risks from the alternatives may be equal
or greater. Therefore, the Agency will consider Option 2,
Modification of the Terms and Conditions of Registration, to
determine if risk reduction measures can reduce the risk to
acceptable levels. In the following sections, the Agency will
evaluate the impacts of the modifications under consideration on
risk reduction and on the benefits of use. For those situations
where the risk cannot be reduced to acceptable levels the Agency
will select Option 3, Cancellation.
b. Risk/Benefit Impacts of Modifications Under Consideration
for Poles-Groundline, Home and Farm, and Brush-On
Applications of the Inoranic Arsenicals
i. Gloves
During the poles-groundline treatment (creosote and penta) , home
and farm applications (creosote and penta) and commercial brush-
on treatments with the inorganic arsenicals, the Agency has
determined that exposure to the three wood preservatives occurs
through the hands. To reduce the risk caused by this route of
exposure, the Agency will consider requiring that all applica-
tors using these pesticides for poles-groundline, home and farm,
and commercial brush-on applications of the inorganic arsenicals
wear gloves impervious to the pesticides (e.g., rubber).
571
-------
While there is no quantitative estimate for the reduction in
risk achieved by the use of gloves for poles-groundline use
situations, the wearing of gloves is expected to reduce the hand
dermal exposure to these chemicals (penta and/or creosote) by
99% (Kozak, 1980).
Implementation of this modification for home and farm applica-
tion will reduce the hand dermal exposure to creosote and penta
by 99%. The oncogenic risk for both indoor and outdoor applica-
tions of penta will thus be reduced from a range of 1.0 x 10
to 1.3 x 10~4 to a range of 1.0 x 10~8 to 1.3 x 10~6. The
MOS for fetotoxicity of penta will be increased from a range of
6 to 400 to .a range of 360 to 900 for indoor application, and
from a range of 6 to 650 to a range of 560 to 7,100 for outdoor
application. No quantitative risks estimates have been obtained
for creosote.
During commerical brush-on treatments of the inorganic arseni-
cals to wood, the exposure to the applicator is through hand
dermal exposure. Wearing gloves will reduce the dermal onco-
— 2 — 4
genie risk from 1.2 x 10 to 1.2 x 10 and increase the
teratogenic/fetotoxic MOS from 1,667 to 170,000.
The annual cost of this option is $60 to $312 per applicator
for poles-groundline and for commercial brush-on inorganic
arsenicals, and would be insignificant for home and farm
applicators who would only apply preservatives sporadically
during the year.
672
-------
ii. Disposable Coveralls and Gloves
it is likely that, during the treatment of poies-groundline and
the brush-on applications of over-the-counter products of creo-
sote or penta on the home or farm, some spillage or splattering
may occur on the arms and legs as well as the hands. Therefore,
the Agency will consider requiring commercial applicators to
wear protective clothing, such as disposable coveralls (e.g.,
nitriie or polyethylene) and gloves (e.g., rubber). Private
applicators (e.g., homeowners) would be required to wear tightly-
woven long sleeved cotton coveralls and gloves (e.g., rubber)
since disposable coveralls are not readily available to them.
While the primariy exposure to the inorganic arsenicals during
the commercial brush-on treatments results from hand dermal expo-
sure, some spillage or splattering may occur on the arms and
legs. Hence, the Agency will also consider requiring brush-on
applicators of the inorganic arsenicals to wear disposable
coveralls (e.g., nitriie or polyethylene) and gloves (e.g.,
rubber). This modification will reduce risks to a greater
degree than the risk reduction resulting from gloves alone.
However, the Agency has not quantified these additional exposure
reductions.
Ihe cost of implementing this modification will be about $20 to
$40 per applicator for coveralls annually for poles-groundiine
and home and farm applicators. The combined annual cost of
coveralls and gloves would range from $28,000 to $123,200 for
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the poles-groundline industry assuming that this protective
clothing is not currently supplied to these applicators.
iii. Require Neoprene-Coated Cotton or Rubberized Overall,
Jacket, Boots and Gloves, and a Respirator
During spray operations of penta and creosote by home and farm
applicators to treat wood, the Agency has determined that
there is a potential for dermal and inhalation exposure. There-
tore, the Agency has determined that some degree of risk exists
during spray applications. However, these risks have not been
quantified.
To reduce the risks resulting from spray applications, the
Agency will consider requiring all applicators spraying penta or
creosote to wear a neoprene-coated cotton or rubberized overall
jacket, gloves and boots, and a properly maintained half-mask
canister or cartridge respirator designed for pesticide use.
The respirator will reduce inhalation exposure by 90% and the
use of the gloves, boots, overalls, and jackets will reduce
total dermal exposure by 80%.
Although the cost of a respirator ranges from $300 to $700 per
applicator and the annual cost of protective clothing ranges
from $70 to $392 per applicator, the Agency believes the
economic impact on commercial applicators will not be great.
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The economic impact of this modification is expected to be
severe, however, for many non-commercial applicators (e.g.,
homeowners).
iv. Require Proper Disposal of Protective Clothing
Although the Agency has not quantified the risks, there are
potential risks from penta, the inorganic arsenicals, and
creosote sticking to clothing and shoes, and being transported
into the home following poles-groundline, home and farm, and
brush-on applications of the inorganic arsenicals by the
commerical applicators. This exposure could pose a risk to the
applicators' families.
To reduce risks from this potential exposure, the Agency will
consider requiring that poies-groundline applicators dispose ot
worn-out protective clothing by following the instructions for
pesticide container disposal. For the home and farm commercial
applicators and commercial brush-on applications of the
inorganic arsenicais, the Agency will also consider requiring
applicators to dispose of worn-out protective clothing in
accordance with pesticide container disposal.
Vvith regard to the commercial home and farm, and brush-on
applications of the inorganic arsenicals, implementation of this
modification is not expected to have a significant cost. The
economic impacts on the poles-groundline applicators ior
disposing of worn-out protective clothing are minor.
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V. Prohibit Eating, Drinking and Smoking During Application
Although the risks due to accidental ingestion of wood preser-
vatives by smoking, drinking, or eating during poles-groundline
treatment, home and farm applications, or commerical brush-on
applications of the inorganic arsenicals have not been quanti-
fied, the Agency has determined that there is a potential for
adverse human health effects in these use situations. To
eliminate risks from this potential exposure, the Agency will
consider the prohibition of eating, drinking, and smoking during
these applications.
The costs of implementing this modification have not been
quantified, but they are not expected to be large.
vi. Classify for Restricted Use
The Agency has no means of quantitatively determining the risk
attributable to improper pesticide handling during poles-
groundline application, home and farm applications, and during
commerical brush-on treatments of the inorganic arsenicals.
However, the Agency believes that education and training would
increase the care with which wood preservatives are handled, and
as a result the total exposure to these pesticides will be
reduced by some finite amount. To assure proper handling of
these chemicals, the Agency will consider classifying all home
and farm formulations of creosote and formulations containing
more than 5% penta as restricted use pesticides. The Agency
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will also consider classifying creosote and penta formulations
for poles-groundline treatment and the inorganic arsenical
formulations for commercial brush-on treatments as restricted
use chemicals. This modification has the potential to reduce
exposure via educational measures.
Hie Agency believes that with proper labeling, penta formula-
tions containing 5% or less penta can be handled safely by
homeowners and farmers. However, the use of concentrated penta
formulations, which must be diluted for use, may result in a
large potential exposure. Thus, while farmers who become
certified applicators may still purchase the concentrates from
which the diluted formulations can be prepared for use on large
amounts of wood, only concentrations of 5% or less penta
(ready-to-use products) will be available to the non-certified
homeowner.
The restricted use classification for creosote products, penta
formulations greater than 5%, and the inorganic arsenicals will
result in a cost per applicator or crew (poles-groundline) which
ranges from $25 to $50 per certification. This modification
would require only one applicator per crew to be certified.
vii. Limit Application of Wood Preservatives to Outdoor Areas
The Agency believes that applying a volatile chemical such as
penta or creosote or using the treated wood in an interior area
will result in inhalation exposure to the applicator. It is a
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common practice for individuals to paint the interior of barns
or other enclosed areas (inside homes) with creosote or penta to
preserve the wood or to prevent horses and farm animals from
chewing on the wood.
To reduce the exposure resulting from interior applications of
the creosote and penta, the Agency will consider limiting the
applications of creosote and penta to the outdoors. Outdoor
application is defined in F1FRA as any pesticide application or
use that occurs outside enclosed man-made structures or the
consequences of which extend beyond enclosed man-made
structures.
The economic impacts resulting from implementation of this
modification have not been quantified, but are not expected to
be large.
viii. Reduce Contaminants in Penta
One of the toxic contaminants of penta is hexachlorodibenzo-p-
dioxin (HxCDD), a potent oncogen. Although most technical penta
products on the market contain about 15 ppm HxCDD, technical
penta can be produced with as little as 1 ppm HxCDD. The Agency
will consider requiring that technical penta contain no more
than 1 ppm HxCDD. The resultant exposure to HxCDD to poles-
groundline and home and farm applicators would be about one-
fifteenth of the present exposure. This modification, there-
fore, would reduce oncogenic risk by a factor of 15. The
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oncogenic risk for both indoor and outdoor applications of penta
for home and farm uses will thus be reduced from range of
1.0 x 10~6 to 1.3 x 10~4 to a range of 6.7 x 10~8 to
8.7 x 10~ . Due to a lack of data, the implementation of this
modification for poles-groundline would reduce the oncogenic
risk of HxCDD by a factor of 15.
A registered product, Dowicide EC-7, made by Dow Chemical
Company, has lower dioxin contaminants than other registered
technical grade penta products on the market. Dioxin levels
were reduced in this product through alterations in the
manufacturing process. Presumably, other companies can also
develop manufacturing processes to lower the level of dioxin
contaminants in their products.
4. Selected Modifications for Poles-Groundline (Creosote and
Penta), Home and Farm (Creosote and Penta), and Brush-on
Applications of the Inorganic Arsenicals
This section presents the selected regulatory options for creo-
sote and penta used in poles-groundline, home and farm, and
in commercial brush-on treatments of the inorganic arsenicals.
When Option 2, Modification of the Terms and Conditions of
Registration, has been selected, this section will present the
modifications to the terms and conditions of registration which
the Agency has determined will reduce the risk of concern to an
acceptable level when considered with the benefits of the pesti-
cide use.
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Because the risks to the applicator associated with poles-
groundline, home and farm, and commercial brush-on treatments
are unacceptably high, the Agency has not selected Option 1,
Continued Registration without changes. In evaluating the risk
reductions which can be achieved through the modification to the
terras and conditions of registration, the Agency believes that
the risks in most cases can be reduced by one to two orders of
magnitude. This reduction results in a situation in which the
benefits, which are high, outweigh the risks. However, the
Agency has determined that the spray application method in the
home and farm use category, Option 3, Cancellation, is the
option of choice. This determination is discussed following the
section which presents the modifications to the terms and
conditions of registration for home and farm use.
a. Poles-Groundline
This section presents the modifications to the terms and
conditions of registration which the Agency has selected for
creosote and penta formulations for poles-groundline application
— Require Gloves (when hand dermal contact with
preservatives is possible)
— Require Disposable Coveralls and Gloves (when dermal
contact with preservatives is possible)
Proper Disposal of Protective Clothing
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— Prohibit Eating, Drinking, and Smoking During
Application
— Classify for Restricted Use
Although most of the exposure reduction from these modifications
has not been quantified, the Agency believes that implementation
of these modifications will reduce risks to the applicators to
acceptable levels when considered in light of the benefits ot
use, and that the poles-groundline use of creosote and penta
will not cause unreasonable adverse effects on the environment.
The Agency has not selected the modification, Reduce Contamin-
ants in Penta, primarily because acceptable levels of risk are
achieved with the other modifications that are being proposed.
While companies other than the Dow Chemical Company may have the
technical capability to produce penta with only 1 ppm of HxCDD
in their products, the Agency believes that requiring production
conversion to the purer form of penta would cause these com-
panies to totally cease manufacturing this wood preservative
because of cost considerations.
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b. Home and Farm
For home and farm use of creosote and penta, the Agency has
selected the following modifications to the terms and conditions
of registration:
— Require Gloves (when hand dermal contact with
preservatives is possible)
— Require Coveralls and Gloves (when dermal contact with
preservative is possible; disposable coveralls for
commercial applicators and tightly-woven long sleeved
cotton coveralls for private applicators)
Neoprene-coated Cotton or Rubberized Overall
Jacket, Gloves and Boots , and Respirator (during
spraying applications, commercial applicators only)
Require Proper Disposal of Protective Clothing -(for
commercial applicators only)
Prohibit Eating, Drinking, and Smoking During
Application
Classify for Restricted Use (except for formulations
containing 5% or less penta)
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— Classify All Creosote Formulations tor Restricted Use
~~ Limit Application to Outdoors
Although most of the exposure reduction from these modifications
have not been quantified, the Agency believes that implemen-
tation of these modifications will reduce risks to the applica-
tors to an acceptable level when considered in light of the
benefits of use, and that the home and farm uses will not cause
unreasonable adverse effects on the environment.
The Agency has not selected the modification, Reduce Contamin-
ants in Penta, primarily because acceptable levels of risk are
achieved with the other modifications that are being proposed.
While companies other than the Dow Chemical Company may have the
technical capability to produce penta with only 1 ppm of HxCDD
in their products, the Agency believes that requiring production
conversion to the purer form of penta would cause these com-
panies to totally cease manufacturing this wood preservative
because of cost considerations.
— Cancellation; Spraying by Homeowner of Concentrations of 5%
or less of Penta
Home and farm products containing creosote or penta are
typically applied by brush, dip, or spray methods. The Agency
has evidence indicating that the spray operation presents, by
far, the greatest opportunity for exposure to the applicator.
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The Agency has selected the modification that all home and farm
products containing greater than 5% penta and products con-
taining creosote be restricted to certified applicators. To
reduce the potential for high exposure to non-certified appli-
cators (homeowners) applying the unrestricted penta products
available for retail sale, the Agency has determined that Option
3, Cancellation, is the option of choice for the spraying method
of applicaton. Therefore, the Agency will propose cancellation
for the spraying of home and farm products containing penta in
concentrations of 5% or less. This cancellation is not expected
to result in a severe burden on applicators of these products
because brush-on and dip methods of application are still
available.
c. Brush-On Applications of the Inorganic Arsenicals
During commercial brush-on applications of the inorganic
arsenicals, the Agency has selected the following modifications
to the terms and conditions of registration:
— Require Gloves (when hand dermal contact with
preservatives is possible)
— Require Disposable Coveralls and Gloves (when dermal
contact with preservatives is possible)
— Require Proper Disposal of Protective Clothing
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-- Prohibit Eating, Drinking, and Smoking During
Application
— Classify for Restricted Use
The Agency has determined that implementing these modifications
will reduce the risk of use of these pesticides to acceptable
levels when considered in light of the benefits and that the use
of the inorganic arsenicals will not cause unreasonable adverse
effects on the environment tor commercial brush-on applications.
D. End-uses of Treated Wood
The previous sections of this part have addressed the potential
exposures to applicators from the application of the wood pre-
servatives creosote, the inorganic arsenicals, and penta. The
end-use risks which are presented in this section arise from
human exposure to the pesticides after they have been applied to
the wood. Because of the vast number of end-uses of treated
wood, there are many opportunities for exposure to these pesti-
cides via the treated wood (e.g., contamination of foodstuffs).
The populations at risk include construction workers, home
repairmen, residents of pesticide-treated dwellings, and the
general public, many of whom probably do not realize that they
are being exposed to a pesticide.
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1. Summary of Risks
a. Creosote
Although the risks have not been quantified, the Agency believes
that potential human exposure to creosote-treated wood may occur
in the following use categories: railroad ties, lumber, timber
and plywood, pilings, posts, crossarms, poles, and wood that has
been treated during home and farm applications. Examples of
populations exposed dermally or through inhalation are the work-
men laying the railroad ties, utility linemen working on utility
poles and crossarms, construction workers installing marine
pilings, and homeowners and farmers installing fence posts, or
contacting creosote-treated barns. Creosote-treated wood tends
to "bleed"; consequently, individuals handling creosote-treated
wood would be exposed to creosote via the hands.
Because creosote has been shown to be oncogenic and mutagenic,
the Agency believes there is a definite, although unquantifi-
able, risk to individuals who dermally contact creosote-treated
wood, breathe creosote fumes in enclosed areas, consume food or
water which has been in contact with creosote-treated wood, or
saw creosote-treated wood.
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b. Inorganic Arsenical Compounds
The potential human exposure to inorganic arsenical-treated wood
may occur in the following use categories: lumber, timber and
plywood, pilings, posts, crossarms, and poles.
Potential dermal exposure and inhalation exposure may occur to
persons involved in handling and sawing pestcide-treated wood,
contacting treated playground equipment or other treated wooden
structures with unprotected skin, breathing arsenic dust in
enclosed areas or consuming food or water which has been in
contact with inorganic arsenical-treated wood.
The Agency has determined that during the sawing operations of
treated wood, preservative-bearing sawdust tends to become
airborne, providing an opportunity for inhalation, gastroin-
testinal, and widespread dermal exposure. During the sawing and
handling of inorganic arsenical-treated wood, the total lifetime
oncogenic risks range from 1.3 x 10~ to 1.6 x 10~ . The
teratogenic/fetotoxic margins of safety for this construction
activity range trom 106 to 128. This oncogenic risk is composed
of dermal, gastrointestinal and inhalation components. The
dermal and gastrointestional exposure component, which is pri-
*
marily related to the incidence of skin cancer risk , is
* Gastrointestinal absorption has been shown to cause abnormal
skin pegmentation and skin tumors.
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estimated to be 1.4 x 10 . The inhalation exposure
component, which is primarily related to the incidence of lung
cancer risk, is estimated to be 1.4 x 10 .
The Agency has estimated the exposure that would result from a
person cleaning a b&sement after seven days of continuous
flooding. Dermal and inhalation exposure would result from the
leaching of arsenic from the lumber, timber and plywood and the
subsequent arsenic dust formed after the flood receeded. The
Agency estimates that the total lifetime oncogenic risk from the
clean up of one flood would be about 10~ . The terato-
genic/fetotoxic MOS for this situation would be 1,923.
The Agency has no monitoring data on exposure to arsenic for
children playing on arsenically treated playground equipment or
persons who inadvertently contact arsenically treated wood
surfaces such as handrails, sun decks, park benches, stadium
seats, and boardwalks.
c. Penta
Potential human exposure to penta-treated wood may occur in the
following use categories: railroad ties, lumber, timber and ply-
wood, pilings, posts, crossarms, poles, sapstain control, mill-
work and plywood, particleboard, and wood that has been treated
following home and farm applications. Examples of populations
exposed, dermally and through inhalation, are persons handling
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and sawing the penta- treated wood, lineman installing and
maintaining utility poles and crossarms, construction workers
installing foundation pilings, and homeowners and farmers
installing fence posts or contacting penta-treated barns. The
general public may also be inadvertantly exposed through contact
with treated park benches, stadium seats, handrails and fences
as well as through food residues of penta from food contact with
penta-treated wood (e.g., packing crates, feed bins, grape
stakes, mushroom flats). Penta-treated particleboard is used in
kitchens, where there may be exposure via inhalation and via
contamination of food.
Following application indoors, inhalation exposure to penta may
continue to occur for a considerable length of time. Based on
measured air levels, the Agency has calculated the inhalation
exposure to a resident of a home treated on the inside with
penta to be about 8 ug/kg/day and is considered negligible
for HxCDD due to its lower vapor pressure relative to that of
penta. This exposure translates into a fetotoxic MOS for about
The Agency was unable to estimate the level of dermal exposure
via the handling of penta-treated wood because of the absence
of data on dermal absorption rates and the limited data on
surface residue levels of penta, its contaminants, and its
breakdown products.
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2. Summary of Benefits
The Agency has evaluated the economic impact of the cancellation
of one or more of the wood preservative agents in terms of the
cost to end-users of substituting creosote-, inorganic arsenical-
or penta-treated wood with wood treated with the remaining
registered preservative(s) or with alternative materials (e.g.,
steel, concrete).
The three wood preservatives, creosote, the inorganic arsenical
compounds, and penta, are usually the major substitutes for each
other in the treatment of wood. While there are some minor
alternatives, including certain species of untreated wood (e.g.,
redwood and western red cedar), other chemical preservatives
(e.g., copper naphthenate), and structural alternatives (e.g.,
concrete and steel), these alternatives are all more expensive
and/or in short supply, or, in the case of the alternative
pesticides, have limited efficacy as wood preservatives. Conse-
quently, if any one of the major wood preservatives were can-
celled, it would be replaced by the remaining registered wood
preservative pesticide(s) for the affected uses. However,
severe economic impacts to the applicators could result from
this cancellation due to the necessary equipment changes that
would be required to treat wood with the remaining registered
wood preservatives. Moreover, the cancellation of certain uses
for which the remaining wood preservatives are not viable sub-
stitutes would result in severe economic impacts. Thus, the
consumer would pay higher prices for the preservative-treated
690
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wood resulting from the severe economic impacts to the
applicators and the higher cost of alternative materials.
If creosote were cancelled for all pressure-treatment uses, the
first year economic impact to the end-users of treated wood
would range from $100.5 million to $106.5 million. For wood
which is pressure treated with the inorganic arsenicals, the
first year cost impact of cancellation would be an increase
ranging from $62 to $68 million; for the pressure treatment
uses of penta, the first year cost increases would range from
$54 million to $60 million.
The cancellation of penta or sodium penta tor non-pressure
applications (i.e., sapstain control, millwork and plywood, and
particleboard uses) would generally result in the use ot alter-
native chemical preservatives at a substantially higher cost to
the applicator and moderate cost increase to the consumers ot
this treated wood. Moreover, for most use patterns, the
alternative chemical preservatives do not provide the same
efficacy as penta.
3. Risk/Benefit Analysis:
a. Consideration of Regulatory options
The Agency has examined the regulatory options which could
reduce the risk from exposure to treated wood products. Only a
fraction of these options can be implemented under FIFRA since
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the regulations issued pursuant to FIFRA exempt treated wood
products per se from regulation. In the following sections, the
Agency will evaluate the modifications which can be implemented
under FIFRA and will disuss the regulatory measures which the
Agency expects to propose pursuant to the Toxic Substances
Control Act (TSCA).
b. Possible Modifications under FIFRA
i. Prohibit Uses Likely to Result in Contamination of Food,
Feed, or Potable Water
The general population may inadvertantly be exposed to the wood
preservatives through the application of pesticides on wood
which is used for vegetable and fruit stakes, mushroom flats and
other greenhouse structures, feed lot bins, seed flats, animal
bedding, pens, watering or feed troughs, irrigation flumes, food
containers or similar wooden articles. The Agency has not deter-
mined the actual dietary exposure to wood preservatives re-
sulting from their application to wood products which may con-
taminate food or water, and has established no tolerances or
exemption from tolerances; the U.S. Food and Drug Administration
has established no action levels for these pesticides in or on
raw agricultural commodities.
To reduce risks to the general public, domestic animals and
livestock from the potential wood preservative residues in food
or drinking water, the Agency will consider prohibiting the
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application ot these pesticides to wood products which may be
used in a manner resulting in direct exposure to domestic
animals or livestock, or in the contamination of food, feed, or
drinking and irrigation water.
To implement this modification the Agency will require regist-
rants to make an appropriate statement of prohibition on the
pesticide labeling. Implementation of this modification will
eliminate residues of these pesticides in foodstuffs.
Because the wood preservatives are not currently registered for
the uses described above, there should be no cost in imple-
menting this modification.
ii. Limit the Application of Pesticides to Wood Destined for
Outdoor and Selected Indoor Uses
The Agency believes that the application of penta, creosote, and
the inorganic arsenicals on wood which is destined for interior
use or enclosed structures will result in inhalation and dermal
exposure to the inhabitants of these dwelling or structures.
The Agency has determined that the oncogenic risk to inhabitants
in such enclosed areas from the interior uses (e.g., AWWF,
plates and sills, and structural framing) of arsenically treated
— 6 —7
wood range from about 10 to 10 . In enclosed areas
treated with penta, inhalation exposures of about 8 ug/kg/day
may occur as a result of the vaporization of penta. This
exposure translates into a fetotoxic MOS of about 380 and the
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exposure to HxCDD is negligible. Sodium penta, used for sap-
stain control, is a salt and thus has a very low vapor pressure.
Consequently, risks from the use of 0.5% sodium penta for
control of sapstain on wood destined for use indoors are not
expected to be great. Although the Agency has not quantified
the risks resulting from inhalation or dermal exposure to
interior wood to which creosote has been applied, the Agency
believes there is some degree of risk to anyone contacting
creosote-treated wood dermally or breathing fumes in enclosed
areas.
To reduce these risks, the Agency will consider limiting the
application of creosote, penta, and the inorganic arsenicals to
wood that will be destined for exterior and specific interior
uses only.
Under this modification the application to wood which would
ultimately be used in the interiors of human and animal
dwellings will be limited to those posing a minimal risk. To
implement this modification the Agency will require the regis-
trant to make appropriate statements of prohibition on the
pesticide labeling. Implementation of this modification will
reduce risk resulting from the use of the treated wood in
interior situations (e.g., paneling, cabinets, interior surfaces
of log homes).
In a few situations the Agency believes risks are sufficiently
low, in light of the benefits, to warrant continuation of use in
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interior settings. These uses are: 1) raillwork treated with
penta which has outdoor surfaces (e.g., doorframes, windows, the
outdoor portion of structural laminated beams used as supports,
patio frames, and similar wooden items) , 2) structures treated
with creosote, the inorganic arsenicals or penta which are in
contact with the soil in barns, stables, and similar sites,
(e.g., foundation timbers, pole supports and the bottom six
inches of stall skirtboards) , 3) structures treated with the
inorganic arsenicals (i.e., all weather wood foundations, plates
and sills, and some structural framing), and 4) wood which has
been treated for sapstain with 0.5% or less sodium penta.
iii. Specific Options Selected
Because the risks to the end-users associated with application
of the wood preservative pesticides to wood destined for in-
terior uses (except for the exemptions discussed in the previous
section) and application of wood preservative pesticides to wood
in contact with foodstuffs are unacceptably high, the Agency has
not selected Option 1, Continued Registration without changes.
The economic impacts of cancellation are sufficiently large that
the Agency has not selected the Option 3, Cancellation. The
Agency has, therefore, selected Option 2, the Modification of
the Terms and Conditions of Registration, as follows:
Application of the Pesticide to Vvood Destined
for Outdoor and Selected Indoor Uses
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— Prohibit Application ot the Pesticide to Wood
Uses Likely to Result in Contamination o£ Food,
Feed, or Potable Water
The Agency has determined that implementing the modifications
described above for creosote, the inorganic arsenicais and penta
will reduce the risks to acceptable levels when considered in
light of the benefits of these uses, and that the use of these
wood preservatives for treatment of wood will not cause unreason-
able adverse effects on the environment.
c. Possible Modifications under TSCA
The Agency does not currently regulate end-use products, such as
treated wood, where no pesticidai claims are made for the
treated item itself under the regulations issued pursuant to
FIFRA. However, these wood products can be regulated under the
authority of the Toxic Substance Control Act (TSCA), which pro-
vides a mechanism for issuing health and safety regulations for
chemical substances and materials. The Agency, therefore, pro-
poses to regulate treated wood products under Section 6 of TSCA
and to issue regulations to reduce the risks from the use of
treated wood in accordance with the rulemaking procedures set
forth in TSCA. The action under TSCA will be taken concurrently
with the issuance of this PD 2/3, and will utilize information
presented in this PD 2/3 in the support document for the pro-
posed TSCA rules. The Agency recognizes that the Consumer
Product Safety Commission (CPSC) has some regulatory jurisdic-
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tion pertaining to the consumer use of wood treated with pesti-
cides. The CPSC, however, has not issued any pertinent regula-
tions to date. If the CPSC, promulgates regulations covering
the wood treated with pesticides, TSCA will be pre-empted to the
extent that the CPSC takes sufficient actions to protect against
the risks of concern.
In essence the Agency has determined that certain labeling
modifications in the use patterns of the treated wood products
may be appropriate to provide health and safety protection to
the exposed population. These labeling changes are considered
below.
i. Distribute Use, Handling, and Disposal Information
with Pesticide-Treated Wood
The Agency believes that the majority of the population exposed
to or using the pesticide-treated wood is not aware that the
wood is treated with a pesticide. To educate and alert the
individual involved in construction activities, including the
homeowner, to the hazards of pesticide-treated wood, the Agency
will consider requiring that procedures for proper use,
handling, and disposal be distributed to the end-user of the
treated wood.
Section 6(a)(3) of TSCA provides that the Agency can require
that the products "be marked with or accompanied by clear ana
adequate warnings and instructions with respect to its use,
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distribution in commerce, or disposal or with respect to any
combination of these activities." Section 6(a)(2) provides that
the Agency can prohibit the processing or distribution in com-
merce of the product tor a particular use. Section 6(a)(5)
provides that EPA can prohibit or otherwise regulate any manner
or method of commercial use of the product. Section 6(a)(6)
provides that the Agency can prohibit or otherwise regulate any
manner or method of disposal of the product "by its manufac-
turer, processor, or by any other person who uses or disposes of
it for commercial purposes." Under a combination of these
authorities and methods, the Agency could achieve the controls
it believes are necessary to protect users of these pesticide-
treated wood products and the public at large.
A rule could be promulgated under the above authorities that
would require that pesticide-treated wood products to be sold
with labels containing use, handling, and disposal information
for users and consumers. This approach is consistent with the
Agency's concern for regulatory flexibility and would preserve
the benefits of wood preservatives while protecting the public
from the adverse effects of these chemicals.
The cost of implementing this measure will depend upon the
number of single purchases of pesticide-treated wood. It is
estimated that labels will cost 3 cents to 31 cents a piece for
each transfer of a single lot of wood.
698
-------
ii. Gloves
As discussed at length in Section V.D.I, dermal exposure can
result trom contact with wood which has been treated with
creosote, penta, or the inorganic arsenicals. To reduce dermal
exposure through the hands, the Agency will consider recom-
mending that all persons who come into hand contact with treated
wood wear gloves impervious to the wood preservatives (e.g.,
rubber). This measure would apply to all construction workers,
individuals installing fence posts, individuals climbing or
working on utility poles, or other occupationally exposed
individuals. Although the dermal exposure to creosote-treated
wood has not been quantified, wearing gloves is estimated to
reduce hand dermal exposure by 99%.
if gloves were worn by workers who handle inorganic arsenical-
treated wood, the risk ot skin cancer to an individual, which is
primarily related to dermal exposure, would be reduced from a
range of 7.9 x 10~3 to 3.9 x 10~2 to a range of 8.0 x 10~5
-4
to 4.0 x 10 ; the tetratogenic/fetotoxic MOS for this
activity is increased from approximately 300 to 500 (this
estimate includes inhalation exposure and does not include the
gastrointestinal exposure which results from sawing inorganic
arsenical-treated wood).
Although the Agency does not have sufficient information
regarding exposure to workers handling penta-treated wood; as
699
-------
noted earlier, gloves are estimated to reduce hand dermal
exposure by 99%.
The annual cost of this modification to a homeowner who is
handling pesticide-treated wood is about $5 to $10. It the
construction industry provided gloves for its workers ($60 to
$312 per worker), the cost of this modification would range
from $3.0 million to $15.6 million annually, assuming that
gloves are not currently supplied to these workers.
li. Coveralls, Gloves, and Dust Mask
The Agency has determined that during sawing operations with
treated wood, preservative-bearing sawdust tends to become
airborne with resultant inhalation, gastrointestinal, and wide
spread dermal exposure. The creosote and penta risks have not
been quantified; however, during the sawing of inorganic arseni-
cal-treated wood, the total oncogenic risk is estimated to be
from a range of 1.6 x 10~ to 1.3 x 10 . The teratogen-
ic/fetotoxic MOS for arsenically treated wood ranges from 106 to
128. To reduce the exposure created from the sawing of pesti-
cide-treated wood, the Agency will consider recommending persons
who saw such wood occupationaily wear gloves (e.g., rubber) and
disposable coveralls (e.g., nitrile or polyethylene; for home-
owners, tightly-woven long sleeved cotton coveralls), und a dust
mask capable of trappi c particulates greater than 5 microns in
size.
700
-------
The Agency has determined that implementation of this modifica-
tion will reduce total dermal exposure to the preservatives creo-
sote and penta by 80% if gloves and coveralls are worn, and inha-
lation exposure of particulates by 80% if a dust mask is worn by
these workers. Wearing these protective clothing while working
with inorganic arsenical-treated wood will reduce the total onco-
genic risk from a range of 1.6 x 10 to 1/3 x 10 to a
— 3 —3
range of 2.7 x 10 to 3.0 x 10 and increase the terato-
genic/fetotoxic MOS from a range of 106 to 128 to greater than
3,000.
The annual cost of implementing this modification to the con-
struction industry for an employee would be about $20 to $40
for disposable coveralls, $60 to $312 for gloves, and $120
for dust masks. The cost to an individual (e.g., homeowner)
would be about $20 for tightly-woven long sleeved cotton
coveralls, $5 to $10 for gloves, and $2.50 for dust masks.
iii. Special Disposal of Treated Wood
When creosote-treated wood is burned, various oncogenic or
mutagenic compounds may be formed. Wood treated with the
inorganic arsenical compounds can produce arsine gas, which is
acutely toxic; and arsenic trioxide ash , a teratogen, muta-
gen and potent oncogen, can be left as a residue. Penta-
treated wood, when burned, is believed to produce HxCDD, a
potent oncogen and teratogen.
701
-------
To reduce exposure to the toxic products that may result from
burning treated wood, the Agency will consider recommending a
prohibition against burning of this wood. Although the Agency
believes there is a finite hazard to human health from this
practice, this hazard has not been quantified. However, imple-
mentation of this modification will eliminate exposure to the
potential risks from burning.pesticide-treated wood.
Acceptable disposal methods include on-site burial or disposal
in accordance with local and state laws. However, if the
pesticide-treated wood waste exceeds 1,000 kg per month, per
site, disposal must comply with the provisions of the Resource
and Recovery Conservation Act (RCRA).
This modification is not expected to have a significant cost in
its implementation.
iv. Selection of Regulatory Actions Under TSCA
The Agency will proceed with the development of a labeling regu-
lation under Section 6 of TSCA. The purpose of the regulation
will be to advise users of procedures tor the proper use,
handling, and disposal of treated wood which are recommended to
mitigate risks. Some of the selected precautions to be included
on the label are listed below:
— Recommend Gloves (in situations where there is hand
dermal contact with preservative-treated wood)
702
-------
— Recommend Coveralls, Gloves, and a Dust Mask (tor
exposed individuals in situations where treated
wood is sawn)
— Recommend Special Disposal of Treated Wood
E. Summary of Proposed Regulatory Actions Under FIFRA
Based upon the determinations set forth above in detail in this
Position Document, the Agency is proposing to initiate the fol-
lowing regulatory actions.
1. Cancellation and denial of registration of the spray
method of application for pentachlorophenol products which
are available for retail sale in concentrations of 5% or less.
2. Cancellation and denial of registration of creosote products
for wood preservative use on railroad ties, lumber, timber and
plywood, pilings, posts, crossarms, and poles unless the
registrants modify the labeling of creosote products to include
the following statements:
a. Restricted Use Pesticide For sale to and use only by
certified applicators or by persons under their direct
supervision and only for those uses covered by the certified
applicators' certification.
703
-------
b. Protective Clothing and Equipment
i. All applicators must wear gloves impervious to the wood
treatment solution (e.g., rubber) in all situations where
dermal contact with creosote is possible (e.g., handling treated
wood and opening cylinder doors).
li. All applicators who open treatment cylinder doors must wear
gloves and a properly maintained halt-mask canister or cartridge
respirator designed for pesticide use.
iii. Applicators who enter pressure treatment cylinders and
other related equipment must wear a neoprene-coated cotton or
rubberized overall, jacket, gloves and boots, and a properly
maintained half-mask canister or cartridge respirator designed
for pesticide use.
c. All applicators must leave all protective clothing, work
shoes or boots, and equipment at the plant at the end of the
day. Vvorn-out protective clothing must be disposed of in
accordance with the instructions for pesticide container
disposal.
d. Eating, drinking and smoking is prohibited during the
application of creosote products.
e. The application of creosote to wood which is intended for
interior use is prohibited, except for those support structures
704
-------
(e.g., foundation timbers, pole supports and the bottom
six inches of stall skirtboards) which are in contact with soil
in barns, stables and similar sites.
f. Do not apply creosote to wooa which will be used in a manner
which may result in direct exposure to domestic animals or
livestock, or in the contamination ot food, feed or drinking and
irrigation water (e.g., food crates, irrigation flumes,
vegetable stakes, feed lot bins and watering troughs).
3. Cancellation and denial or registration ot pentachlorophenoi
products for wood preservative use on railroad ties, lumber,
timber and plywood, pilings, posts, crossarms and poles unless
the registrants modify the labeling or products to include the
following statements:
a. Restricted Use Pesticide For sale to and use only by
certified applicators or by persons under their direct
supervision and only for those uses covered by the certified
applicators' certification.
b. Protective Clothing and Equipment
i. All applicators must wear gloves impervious to the wooa
preservative solution (e.g., rubber) in all situations where
dermal contact with pentachlorophenoi is possible (e.g.,
handling treated wood and opening cylinder doors).
705
-------
ii. All applicators who open treatment cylinder doors must wear
gloves and a properly maintained half-mask canister or cartridge
respirator designed for pesticide use.
iii. Applicators who enter pressure treatment cylinders and
other related equipment must wear a neoprene-coated cotton or
rubberized overall, jacket, gloves and boots, and a properly
maintained half-mask canister or cartridge respirator designed
for pesticide use.
c. A closed emptying and a closed mixing system must be used
for all prilled (granular) formulations of pentachlorophenol.
d. All applicators must leave all protective clothing, work
shoes or boots, and equipment at the plant at the end of the
day. Worn-out protective clothing must be disposed of in
accordance with the instructions for pesticide container
disposal.
e. Eating, drinking and smoking is prohibited during
the application of pentachlorophenol products.
f. The application of pentachlorophenol to wood which is
intended for interior use is prohibited, except for those
support structures (e.g., foundation timbers, pole supports and
the bottom six inches of stall skirtboards) which are in contact
with the soil in barns, stables and similar sites.
?06
-------
g. Do not apply pentachlorophenol to wood which will be used in
a manner which may result in direct exposure to domestic animals
or livestock, or in the contamination of food, feed or drinking
or irrigation water (e.g., food crates, irrigation flumes,
vegetable stakes, feed lot bins and watering troughs).
4. Cancellation and denial of registration of the inorganic
arsenical products for wood preservative use on lumber, timber
and plywood, pilings, posts, crossarms and poles unless the
registrants modify the labeling of the inorganic arsenical
products for these uses to include the following statements:
a. Restricted Use Pesticide For sale to and use only by
certified applicators or by persons under their direct
supervision and only for those uses covered by the certified
applicators' certification.
b. Protective Clothing and Equipment
i. All applicators must wear gloves impervious to the wood
treatment solution (e.g., rubber) in all situations where
dermal contact with the inorganic arsenicals is possible (e.g.,
handling treated wood and opening cylinder doors).
ii. Applicators who enter pressure treatment cylinders and
other related equipment must wear a neoprene-coated cotton or
rubberized overall, jacket, gloves and boots, and a properly
707
-------
maintained half-mask canister or cartridge respirator designed
for pesticide use.
iii. Appiictors who work outdoors in arsenical wood treatment
plants must wear a dust mask capable of trapping 80% of
particulates greater than 5 microns in size.
c. A closed emptying and a closed mixing system must be used
tor ail powder formulations of the inorganic arsenicals.
d. All applicators must leave all protective clothing, work
shoes or boots, and equipment at the plant at the end of the
day. Worn-out protective clothing must be disposed of in
accordance with the instructions for pesticide container
disposal.
e. Eating, drinking, and smoking is prohibited during the
application of inorganic arsenical products.
f. The inorganic arsenical treatment solutions must be filtered
prior to use in the treatment cylinders and an additional
vacuum step must be used prior to the removal of the treated
wood from the treatment cylinders. In addition to these
requirements, recommended control technologies to reduce the
surface levels of arsenic on treated wood include the use of
wood that is free of heavy resins ("clean" wood), the post-
treatment rinsing of the treated wood, and the installation of
protective sheds or covers over the drying treated wood.
708
-------
g. The application of the inorganic arsenicals to wood which
is intended for interior use is prohibited, except for those
support structures (e.g., foundation timbers, pole supports and
the bottom six inches of stall skirtboards) which are in contact
with the soil in barns, stables and similar sites, all weather
wood foundations, sills and plates, and structural framing.
h. Do not apply the inorganic arsenicals to wood which will be
used in a manner which may result in direct exposure to domestic
animals or livestock, or in the contamination of food, feed or
drinking or irrigation water (e.g., food crates, irrigation
flumes, vegetable stakes, feed lot bins and watering troughs).
5. Cancellation and denial of registration of creosote and
pentachlorophenol for wood preservative use for groundline
treatment of poles unless the registrants modify the labeling of
creosote and pentachlorophenol products for the poles-groundline
use to including the following statements:
a. Restricted Use Pesticide For sale to and use only by
certified applicators or by persons under their direct
supervision and only for those uses covered by the certified
applicators' certification.
709
-------
b. Protective Clothing and Equipment
i. All applicators must wear gloves impervious to the
pentachlorophenol and creosote poles-groundline formulations
(e.g., rubber) in all situations where dermal contact is
possible .
ii. All applicators must wear disposable coveralls
(e.g., nitrile or polyethylene) or similar protective clothing
during the application process.
c. All applicators must dispose of worn-out protective
clothing in accordance with the instructions for pesticide
container disposal.
d. Eating, drinking and smoking is prohibited during the
application of creosote and pentachlorophenol products for the
poles-groundline use.
6. Cancellation and denial of registration ot creosote and
pentachlorophenol for wood preservative home and farm use
unless the registrants modify the labeling of creosote and
710
-------
pentachlorophenol products for home and tarm use to including
the following statements:
a. For all creosote products and those pentachlorophenol
products containing a pentachlorophenol concentration greater
than 5%:
Restricted Use Pesticide For retail sale to and use only by
certified applicators or by persons under their direct
supervision and only for those uses covered by the certified
applicators' certification.
b. Protective Clothing and Equipment
i. All applicators must wear gloves impervious to the
pentachlorophenol and creosote treatment solutions (e.g.,
rubber) in all situations when dermal contact is possible
(e.g., handling treated wood).
ii. All non-certified applicators must wear tightly-woven long
sleeved cotton coveralls or similar protective clothing during
the application process.
iii. All certified applicators who apply creosote and penta-
chlorophenol by the spray method must wear a neoprene-coated
cotton or rubberized overall, jacket, gloves and boots, and a
properly maintained half-mask canister or cartridge respirator
designed for pesticide use, and all certified applicators who
711
-------
apply creosote and pentachlorophenol by other application
processes (e.g., brush-on) must wear disposable coveralls (e.g.,
nitrile or polyethylene) or similar protective clothing.
c. All certified applicators applying creosote or penta-
chlorophenol solutions must dispose of worn-out protective
clothing in accordance with the instructions for pesticide
container disposal.
d. Eating, smoking, and drinking is prohibited during the
application of. creosote or pentachlorophenol products.
e. The application of creosote and pentachlorophenol products
indoors is prohibited. The application of creosote and penta-
chlorophenol products to wood intended for interior use is
prohibited, except for those support structures (e.g., founda-
tion timbers, pole supports and the bottom six inches of stall
skirtboards) which are in conact with the soil in barns, stables
and similar sites and millwork (pentachlorophenol only) which
has outdoor surfaces (e.g., doorframes, windows and patio
frames) .
f. Do not use creosote and pentachlorophenol in a manner which
may result in direct exposure to domestic animals or livestock,
or in the contamination of food, teed or drinking or irrigation
water (e.g., food crates, irrigation flumes, vegetable stakes,
feed lot bins and watering troughs) .
712
-------
7. Cancellation and denial of registration of brush-on
treatments of the inorganic arsenicals unless the registrants
modify the labeling of the inorganic arsenical products to
include the following statements:
a. Restricted Use Pesticide For sale to and use only by
certified applicators or by persons under their direct
supervision and only for those uses covered by the certified
applicators' certification.
b. Protective Clothing and Equipment
i. All applicators must wear gloves impervious to the inor-
ganic arsenical solutions (e.g., rubber) in all situations where
dermal contact with the pesticide solution is possible (e.g.,
handling treated wood).
ii. All applicators must wear disposable coveralls (e.g.,
nitrile or polyethylene) or similar protective clothing during
the application process.
c. Eating, drinking, and smoking during the application of
the inorganic arsenical products is prohibited.
d. All applicators applying brush-on inorganic arsenical
solutions must dispose of worn-out protective clothing in
accordance with the instructions tor pesticide container
disposal.
713
-------
e. Do not apply brush-on inorganic arsenical solutions to wood
intended for indoor use, except for those support structures
(e.g., foundation timbers, pole supports and the bottom six
inches ot stall skirtboards) which are in contact with the soil
in barns, stables and similar sites, all weather wood
foundations, sills and plates and structural framing.
f. Do not use the inorganic arsenicals in a manner which may
result in direct exposure to domestic animals or livestock, or
in the contamination of food, feed or drinking or irrigation
v»ater (e.g., food crates, irrigation flumes, vegetable stakes,
feed lot bins and watering troughs).
8. Cancellation and denial of registration of sodium penta-
chlorophenate products for sapstain control unless the
registrants modify the labeling of sodium pentachlorophenate
products to include the following statements:
a. Restricted Use Pesticide For sale to and use only by
certified applicators or by persons under their direct
supervision and only for those uses cove red by the certified
applicators' certification.
b. Protective Clothing and Equipment
i. All applicators applying sodium pentachlorphenate for sap-
stain control must wear gloves impervious to sodium pentachloro-
714
-------
phenate (e.g., rubber) in all situations where dermal contact
with the treatment solutions is possible (e.g., handling treated
wood) .
ii. All applicators applying sodium pentachiorophenate
formulations by the spray method must wear gloves and a properly
maintained half-mask canister or cartridge respirator designed
for pesticide use.
iii. All applicators who enter or clean vats and other related
equipment must wear a neoprene-coated cotton or rubberized
overall, jacket, gloves and boots, and a properly maintained
half-mask canister or cartridge respirator designed for
pesticide use.
c. A closed emptying and a closed mixing system must be used
for all prilled (granular) and powder formulations of sodium
pentachiorophenate.
d. Ail sapstain control applicators must leave all protective
clothing, work shoes or boots, and equipment at the plant. Worn-
out protective clothing must be disposed of in accordance with
the instructions tor pesticide container disposal.
e. Eating, drinking and smoking is prohibited during the
application of sodium pentachiorophenate for sapstain control.
715
-------
f. Do not use sodium pentachlorophenate in a manner which may
result in direct exposure to domestic animals or livestock, or
in the contamination of food, feed or drinking or irrigation
water (e.g., food crates, irrigation flumes, vegetable stakes,
feed lot bins and watering troughs).
9. Cancellation and denial of registration of the wood
preservative use of pentachlorophenol tor millwork and plywood
unless the registrants modify the labeling of pentachlorophenol
for millwork and plywood to include the following statements:
a. Restricted Use Pesticide For sale to and use only by
certified applicators or by persons under their direct
supervision and only for those uses covered by the certified
applicators' certification.
b. Protective Clothing and Equipment
i. All applicators applying pentachlorophenol to the wood must
wear gloves impervious to the wood treatment solutions (e.g.,
rubber) in all situations where dermal contact with the
treatment solutions is possible (e.g., handling treated wood).
ii. All applicators who enter or clean vats, and other related
equipment must wear a neoprene-coated cotton or rubberized
overall, jacket, gloves and boots, and a properly maintained
half-mask canister or cartridge respirator designed for
pesticide use.
716
-------
iii. All applicators who apply pentachlorophenol to millwork
and plywood by the spray method must wear gloves and a properly
maintained half-mask canister or cartridge respirator designed
for pesticide use.
c. A closed emptying and a closed mixing system must be used
for all prilled (granular) formulations of pentachlorophenol.
d. All applicators who apply pentachlorophenol to millwork and
plywood must leave all protective clothing, work shoes or boots,
and equipment at the plant at the end of the day. Worn-out
protective clothing must be disposed of in accordance with
the instructions for pesticide contained disposal.
e. Eating, drinking and smoking is prohibited during
the application of pentachlorophenoi to millwork
and plywood.
f. The application of pentachlorophenol products to wood in-
tended tor interior use is prohibited, except for wood which has
outdoor surfaces (e.g., doorlrames, windows and patio frames).
g. Do not use pentachlorophenol in a manner which may result in
direct exposure to domestic animals or livestocK, or in the
contamination of food, teed or drinking or irrigation water
(e.g., food crates, irrigation flumes, vegetable stakes, teed
lot bins and watering troughs).
717
-------
10. cancellation and denial of registration ot the wood
preservative use of pentachlorophenol on particleboard unless
the registrants modify the labeling of pentachlorophenol
products for the particleboard use to include the following
statements:
a. Restricted Use Pesticide For sale to and use only by
certified applicators or by persons under their direct
supervision and only for those uses covered by the certified
applicators' certification.
b. Protective Clothing and Equipment
i. All applicators who apply pentachlorophenol to
particleboard must wear gloves impervious to pentachloro-
phenol (e.g., rubber) in all situations where dermal contact
with pentachlorophenol is possible (e.g., handling treated
particleboard).
ii. All applicators who clean or enter vats, and other related
equipment must wear a neoprene-coated cotton or rubberized
overall, jacket, gloves and boots and a properly maintained half-
mask canister or cartridge respirator designed fo'«: pesticide use,
c. A closed emptying and a closed mixing system must be used
for ail prilled (granular) formulations of pentachlorophenol.
718
-------
d. Eating, drinking and smoking is prohibited during the
application of pentachlorophenol to particleboard.
e. All applicators who apply pentachlorophenol to particleboard
must leave all protective clothing, work shoes or boots, and
equipment at the plant at the end of the day. Worn-out
protective clothing must be disposed of in accordance with
the instructions for pestcide container disposal.
f. The application of pentachlorophenol to particieboard
intended for any interior use (e.g., kitchen cabinets) is
prohibited.
g. Do not apply pentachlorophenol to particleboard which will
be used in a manner which may result in direct exposure to
domestic animals or livestock, or in the contamination of food,
feed or drinking or irrigation water (e.g., food crates,
irrigation flumes, vegetable stakes, feed lot bins and watering
troughs) .
F. Summary of Projected Regulatory Measures under TSCA
The Agency will also propose regulatory measures for the treated
wood under the authority of the Toxic Substances Control Act
(TSCA). These TSCA labeling measures would be distributed to
719
-------
the end-users of the treated wood. The Agency recommends that
the TSCA labeling include the following statements:
1. All individuals who handle pesticide-treated wood should
wear gloves impervious to the wood preservatives (e.g., rubber).
2. Individuals who saw pesticide-treated wood should wear
disposable coveralls (e.g., nitrile or polyethylene) or similar
protective clothing (for homeowners, tightly-woven long sleeved
cotton coveralls are acceptable).
3. Individuals who saw pesticide-treated wood and fabricate
structures with treated wood should wear a dust mask capable of
trapping 80% of particulates greater than 5 microns in size.
4. Treated wood should not be used indoors except for those
support structures (e.g., foundation timbers, pole supports and
the bottom six inches of stall skirtboards) which are in contact
with the soil in barns, stables and similar sites (all three
wood preservatives); all weather wood foundations, sills and
plates and structural framing (inorganic arsenicals only);
millwork (pentachlorophenol only) which has outdoor sufaces
(e.g., doorframes, windows and patio frames); and wood treated
for sapstain control with 0.5% sodium pentachlorophenoi.
5. Treated wood should not be used in a manner which may result
in direct exposure to domestic animals or livestock, or in the
contamination of food, feed or drinking and irrigation water
720
-------
(e.g., food crates, irrigation flumes, vegetable stakes, feed
lot bins and watering troughs).
6. Treated wood should not be burned but should be disposed of
by methods, such as on-site burial, which are in accordance with
local and state laws and/or the Resource Conservation and
Recovery Act.
721
-------
APPENDIX 1 A-C:
REBUTTAL COMMENTS RECEIVED
-------
LISTING OF REBUTTAL COMMENTS - CREOSOTE
Rebuttal No.
1
1A
IB
1C
ID
IE
IF
1G
1H
U
IK
1L
1M
IN
IP
1Q
1R
Source
Koppers Co.
Monrocvij-iie, Pa.
Koppers Co., inc.
Denver, Colorado
Koppers Co., Inc.
Salem, Va.
Koppers Co., inc.
Guthrie, Ky.
Koppers Co., Inc.
Richmond, Va.
Koppers Co., Inc.
Kansas City, Mo.
Koppers Co., Inc.
Port Newark, N.J.
Koppers Co., Inc.
Superior, Wisconsin
Koppers Co., Inc.
Tie Plant, Ms.
Koppers Co., Inc.
North Little, Ak.
Koppers Co., inc.
Pittsburgh, Pa.
Koppers Co., Inc.
Houston, Ts.
Koppers Co., inc.
Florence, S.C.
Koppers Co., inc.
Oroville, Ca.
Koppers Co., Inc.
Montgomery, Pa.
Koppers Co., Inc.
Orrville, Oh.
Koppers Co., inc.
Pittsburgh, Pa/ (Vy/Ltr,
Tbl lit*;, Rpts 1973 & 76)
Date
of Comment
7/7/78
1/11/79
1/8/79
1/12/79
1/23/79
1/26/79
1/19/79
UNDATED
1/22/79
1/8/79
1/25/79
1/26/79
1/26/79
1/16/79
1/24/79
1/23/79
2/9/79
Date
Received
11/2/78
1/25/79
1/29/79
1/29/79
1/29/79
1/30/79
1/30/79
1/29/79
1/29/79
1/29/79
1/29/79
1/31/79
1/31/79
1/31/79
I/ 31/79
1/31/79
2/12/79
-------
IS
2A
2B
2C
Manual NFPD (ALL THREE
CYS TO GIBBS) KOPPER
CO., INC. (NOCY OF MANUAL
KEPT PITTSBURGH, PA.
W/Encl. Fr. G. G. Kenney)
2/9/79
2/12/79
IT
1U
IV
1W
2
Koppers Co., Inc.
Pittsburgh, Pa.
Koppers Co. , Inc.
Pittsburgh, Pa.
(Review Paper)
A. Lawrence
Koppers Co. , Inc.
Green Spring, West Va.
Koppers Co. , Inc.
Houston, Ts .
Steptoe and Johnson, Atts.
2/12/79
2/9/79
1/12/79
1/30/79
10/23/79
2/12/79
2/12/79
2/12/79
2/ 14/79
11/2/79
Washington, D.C.
(Rep. AWPI)
Steptoe and Johnson, Atts.
Washington, D.C.
(Rep. AWPI)
Steptoe and Johnson, Atts.
Washington, D.C.
(Rep. AWPI)
Steptoe and Johnson, Atts.
Washington, D.C.
(Rep. AWPI)
2/12/79
4/3/79
2/13/79
4/10/79
3
4
5
6
7
8
Cooperative Ext. Service
Fitzgerald, Ga .
Burroughs Wellcome, Co.
Reser. Triangle Park, N.C.
Wool foam Corp.
New York, N.Y.
Department of the Navy
Alex. , Va.
Agro-West, inc.
Wilder, Idaho
Link Noe,
11/3/78
11/15.78
11/17/78
11/9/78
11/10/781
11/10/78
11/13/78
11/20/78
11/20/78
11/20/78
11/20/78
11/20/78
Wilder Bldg. Ctr.
Wilder, Idaho
-------
9
10
11
12
12A
13
14
15
16
16A
16B
17
18
18A
19
Consolidated Companies
Cleveland, Ohio
Baird & McGuire, Inc.
Holbrook, Mass.
Howard Larson
Emmett, Idaho
I.D. McFarland Co.
Sandpoint, Idaho
McFarland Cascade
(C.L. Stoddard)
Sieben Ranch Co.
Helena, Montana
Union Oil Co.
California
Gibson-Homans Co.
Cleveland, Oh.
Dept. of Transportation
and Public Facilities
Juneau, Alaska
Dept. of Transportation
and Public Facilities
Juneau, Alaska
Dept. of Transportation
and Public Facilities
Juneau, Alaska
Johnny L. Crawford
Chula, Ga.
Potomac Electric Power Co.
Washington, D.C.
Potomac Electric Power Co.
Washington, D.C.
Central Hudson Gas &
11/21/78
11/16/78
11/13/78
11/21/78
11/9/78
11/20/78
11/29/78
11/30/78
11/30/78
12/12/78
12/26/78
11/22/78
11/28/78
2/12/78
11/27/78
11/24/8
11/27/78
11/29/78
11/29/78
1/18/78
11/21/78
12/5/78
12/5/78
12/6/78
12/21/78
1/5/79
12/6/78
12/6/78
2/13/78
12/6/78
19A
20
Electric Corp.
Poughkeepsie, N.Y.
Central Hudson Gas
Electric Corp.
Poughkeepsie, M.Y.
Pacific Power &
Light Co.
Portland, Oregon
2/9/78
12/1/78
2/13/79
12/6/78
-------
21
22
24
25
26
Henry J. Ellis 12/4/78
New Hampshire
Florida Power & 11/30/78
Light Co.
Public Service 12/1/78
Electric & Gas Co.
Newark, N.J.
Depart, ot Highways & 12/1/78
Transportation
Ki chmond, Va.
Department of 12/5/78
Agriculture
Atlanta, Ga.
Depart, ot Transportation 12/1/78
Kansas
12/8/78
12/8/78
12/6/78
12/11/78
12/11/78
12/6/78
27
28
29
30
31
32
33
34
Kennecott Copper Corp.
New York, New York
Allegheny Power System
Greensburg, Pa.
Arkansas Power s*
Light Co.
Little Rock, Ak.
University ot ill. at
Urban a- Champaign
Urbana, ill
Dayton Power & Light
Dayton, Ohio
Depart, ot Trans-
portation
Dover, Delaware
Macgiliis & Gibbs Co.
Milwaukee, Wi .
Alabama Power Electric
12/4/78
12/7/78
12/4/78
12/5/78
12/1/78
12/7/78
12/8/78
12/5/78
12/13/78
12/13/78
12/13/78
12/13/78
12/13/78
12/13/78
12/13/78
12/18/78
35
36
System
Birmingham, Ala.
Depart, of Agri-
culture
Saint Paul, Minnesota
Webster Lumber Co.
toayzata, Minn.
12/12/78
12/12/78
12/18/78
12/20/78
-------
37
38
39
40
41
42
50
51
Depart, of Agri-
culture
Annapolis, Md.
Depart, of interior
Washington, D.C.
New Orleans Public
Service Inc.
New Orleans, La.
Depart. Agriculture
(Kent D. Shelhamer)
Commonwealth of Pa.
Atlantic Wood
Industrties
Savannah, Ga.
Atchison, Topeka, and
Santa Fe Railway Co.
Chicago, 111.
12/13/78
12/13/78
12/13/78
12/12/78
12/15/78
12/13/78
Southern Electric System
Gulfport, Ms.
Leonard Guss Associates 12/20/78
Inc. (J.B. Bonney)
Tacoma, Washington
R & M Consultants 12/21/78
(Dennis Nottingham)
Anchorage, Alaska
12/20/78
12/20/78
12/19/78
12/20/78
12/21/78
12/21/78
43
44
45
46
47
48
49
Potomac Edison Co.
Hagerstown, Md .
Idaho Transportation
Boise, Idaho
Depart, of Agriculture
Agana , Guam
Atlantic Wood Industries
Savannah, Ga.
Illinois Depart, of
Transportation
Coltax Creosoting Co.
Pineville, La.
Mississippi Power
12/15/78
12/14/78
12/13/78
12/14/78
12/18/78
12/15/78
12/21/78
12/21/78
12/21/78
12/21/78
12/21/78
12/29/78
12/29/78
12/29/78
12/29/78
12/29/78
-------
52
53
54
55
56
57
59
59A
60
6i
61A
62
63
Depart, of Trans- 12/19/78 12/29/78
portation (US Coast
Guard)
Juneau, Alaska
American Seal MFC, Co. JL2/21/78 12/29/78
Inc.
Troy, N.Y.
Wm. A. smith Contract- 2/20/78 2/29/78
ing Co., Inc.
Shavnee Mission, Kansas
State Depart, of High- 12/14/78 12/29/78
ways (Col. Stdte Patrol)
Denver, Co.
Josh Tiliinghast 12/19/78 12/29/78
Kemah, Texas
United Marine 12/20/78 12/29/78
Publishing, Inc.
Kemah, Texas
Vermont Agency of 12/22/78 12/29/78
Transportation
(Eng. & Consur.)
Montpelier, Vermont
Tri-County Electric 12/22/78 12/29/78
Cooperative
Rushford, Minn.
Tri-County Electric 4/5/79 4/11/V9
Portland, Mich.
Ottur Tail Power Co. 12/22/78 12/29/78
Fergus Falls, Minn.
Southern Wood Piedmont 12/19/78 1/2/79
Co.
Spartanburg, S.C.
Southern Wood Piedmont 2/6/79 2/13/79
Co.
Spartanburg, S.C.
Ohio Depat. of Agri- 12/22/78 l/j/79
culture
Columbus, Ohio
Dept. of the Army 12/22/78 1/3/79
(Engineering Res. Ctr.)
Fort Belvoir, Va.
-------
64
b5
66
67
68
69
70
71
71A
71B
71C
71D
71E
7 IF
Public Service Co. of 12/21/78 1/4/79
New Hampshire
Manchester, N.H.
Coopers Creek Chemical 12/27/78 1/5/79
Corp.
West Conshohocken, Pa.
Indiana State Highway 12/27/78 1/5/79
Commission
Indianapolis, Indiana
»
California Dept. of 12/28/78 1/5/79
Transportation
Sacramento, California
Ohio Dept. of Trans- 12/26/78 1/5/79
portation
Columbus, Ohio
Dept. of Trans- 1/3/79 1/5/79
portation FAA
Washington, D.C.
Maine Dept. of Trans- 12/26/78 1/5/79
portation
Augusta, Maine
Conroe Creosoting Co. 12/28/78 1/5/79
Conroe, Texas
(Henry E. Steitz)
Conroe Creosoting Co. 12/29/78 1/5/79
Conroe, Texas
(Richard Parker)
Conroe Creosoting Co. 12/30/78 1/10/79
Conroe, Texas
(J.A. Ramey)
Conroe Creosoting Co. 1/5/79 1/10/79
Conroe, Texas
(C. Hawthorne)
Conroe Creosoting Co 12/30/78 1/10/79
Conroe, Texas
(Marie Henry)
Conroe Creosoting 12/30/781 1/10/79
Conroe, Texas
(George Brodnax)
Conroe Creosoting 12/30/78 1/10/79
Conroe , Texas
(W.E. Kolbe)
-------
71G
71H
71J
71K
72
73
74
75
76
77
78
79
BO
81
82
83
Conroe Creosoting 12/30/78
Con roe, Texas
(E. Weisinger)
Conroe Creosoting 12/30/78
Conroe, Texas
(J. Lumpkin)
Conroe Creosoting 12/30/78
Conroe, Texas
(Charline Mulier)
Conroe, Creosoting 12/30/78
Conroe, Texas
(V.L. Andrews)
Marine, Inc. General 12/15/78
Contractor
Reman, Tx.
Darvin & Maurine Taylor 12/19/78
Cut 'N Shoot, Tx.
Consumers Power Co. 12/29/71
Jackson, Mich.
Chicago North Western 12/21/78
Transportation Co.
H. M. Monty Hawthorne UNDATED
Conroe, Tx.
Dept. of Transpor- 12/28/78
tation & Development (LA)
Baton Rouge, La.
James Huggins & Sons Inc. 1/5/79
Maiden, Ma.
G. S. McCleilan 12/30/78
Conroe, Texas
Jety Schailer 12/30/78
Conroe, Texas
Lennice Sloan (Timber 12/3U/78
Distributioin)
(Minis, Tx.
City Public Service of 12/29/78
San Antonio
San Antonio, Texas
Ecological & Specialty 12/27/78
Products, inc.
1/10/79
1/10/79
1/10/79
1/11/79
1/5/79
1/5/79
1/5/79
1/5/78
1/10/79
1/10/79
1/10/79
1/10/79
1/10/79
1/10/79
1/10/79
1/10/79
-------
84
85
86
87
88
89
89A
90
91
92
92A
93
94
95
96
Fla. Dept. of Agri-
culture & Consumer
Service
Tallahassee, Fla.
N.C. State University
Raleigh, N.C.
Dept. of Transportation
(Commonwealth of Pa.)
Harrisburg, Pa.
Utah Dept. of Trans-
portation
Salt Lake City, Utah
L & M Lumber Co., Inc.
(McMillin)
Tx.
Elco Manufacturing Co.,
Inc .
Pittsburgh, Pa.
Elco Manufacturing Co.
Inc.
Sharpsburg, Ps .
H. Harwood Loos
Bristol, Pa.
Monogahela Pov^er Co.
Fairmont, West Va.
Stephen F. Austin
State University
Nacogdoches, Texas
Stephen F. Austin
State University
Nacogdoches, Texas
Philadelphia Electric Co.
Philadelphia, Pa.
Pacific Gas and Electric
San Francisco, Ca.
Oregon State University
(Prof. Graham) (W/ Attach.)
Cor vail is, Oregon
Farmers Union Central
Exchange, Inc.
St. Paul, Mn.
12/22/78
12/15/78
1/2/79
1/2/79
12/30/78
12/20/78
1/16/79
12/22/78
1/12/79
1/11/79
1/12/79
1/11/79
1/12/79
1/16/79
1/11/78
1/10/79
12/28/78
1/10/79
1/9/79
1/12/79
12/28/78
1/29/79
12/29/78
1/17/79
1/17/79
1/25/79
1/18/79
1/25/79
1/25/79
1/25/78
-------
97
98
99
100
101
102
103
104
105
106
107
10&
109
110
111
112
113
114
Lake States Wood 1/16/79
Preserving, Inc.
Munising, Michigan
Rexham Corporation 1/10/79
Matthews, N.C.
Yakima County Farm Bureau 1/17/79
Yak ima, Wa sh i ng ton
James Koss Paint and 1/19/79
Vvallpaper Inc.
St. Germain Bros. Inc,. UNDATED
Duluth, Mn.
Fleet Distributing 1/79
Supply
Vvadena, Mn.
Ham Paint Supply 1/19/79
Minnepoiis, Mn.
Fleet Distributing 1/19/79
Supply Co.
Little Falls, Mn.
Haberman Supplies 1/19/79
Owatonna, Mn.
Indiana Farm Bureau 1/15/79
Cooperative Assn., Inc.
Indianapolis, Indiana
Kenneth Strube 1/19/79
Rochester, Mn.
G.F. Nemitzs1 Sons 1/19/79
Hutchinson, Mn.
Peck, C.K. 1/7/79
Lexington, Oregon
Julian Orhrymowych 1/23/79
Burke-Parsons-Bowlby 1/17/79
Corporation
St. Regis Paper Company 1/16/79
St. Louis Park, Mn.
Ohio State Tie And Timber, 1/19/79
Inc., Columbus, Ohio
VEPCO 1/18/79
Richmond, Va.
1/25/79
1/25/79
1/24/79
1/24/79
1/24/79
1/24/79
1/24/79
1/24/79
1/24/79
1/25/79
1/26/79
1/26/79
1/24/79
1/30/79
1/29/79
1/29/79
1/29/79
1/31/79
-------
114A VEPCO
Richmond, Va.
7/12/79
8/10/79
115
116
117
117A
118
119
119A
120
121
122
123
124
125
126
127
12«
Voided
Jan J. Don
Grandview, Washington
Kopper Company Inc.,
Carbondale, 111.
Kopper Company Inc.,
Gales, 111.
David Hibbard
Post Falls, Idaho
Koppers Company Inc.,
Nasuha, N.H.
(John L. Peterson)
Koppers Company Inc.,
Nashua, N.H.
(Charles Fereday)
J.N. Krtssbach
Gillette, N.C.
Harris Teeder buper
Markets Inc.
Charlotte, N.C.
H. J. Haemmerlie
Gainesville, Fla.
Dept. of Public
Instruction
Raleigh, N.C.
Martin Marietta Chemicals
Charlotte, N.C.
F. A. Bartlett Tree
Expert Co.
fatamlord, Ct .
Shoppers Supply famidt
Distr. Inc.
Spencer , Iowa
Andren's Inc.
Duluth, Mn.
Robert *_. bnyder
1/22/79
1/26/79
1/26/79
1/24/79
1/29/79
1/29/79
l/JG/79
1/30/79
1/29/79
1/23/79
1/26/79
1/24/79
1/25/79
1/24/79
1/29/79
2/7/79
2/7/79
2/7/79
2/1/79
2/2/79
2/2/79
2/7/79
2/6/79
2/1/79
2/1/79
2/1/79
2/1/79
2/1/79
2/1/79
2/2/79
Center Lovell, Maine
-------
129
W.J. Smith Wood
Preserving Co.
Denison, Texas
1/26/79
2/5/79
130
131
132
133
134
135
136
137
138
139
140
141
142
143
144
145
Edison Electric Institute
Washington, D.C.
W.T. Harris
Charlotte, N.C.
Richard H. Danielson
Atlanta, Ga.
Southern California
Edison Co.
Rosemead, California
Texas Power & Light Co.
Dallas, Texas
Ace Hardware Corporation
Oak Brook, Illinois
Charlie Reed
Rosalia, Washington
B.H. LeSueur
Gainesville, Florida
Export Leaf Tobacco Co.
Richmond, Virginia
J.A. Jones Construction Co.
Charlotte, N.C.
R.O. Watson
Wilmington, Delaware
Wood Preservers, Inc.
Warsaw, Va.
Jennison-Wright Corp.
Toledo, Ohio
West European Tar Industry
London, England
Texas Forest Service
Lufkin, Texas
Clevland Elecetric
1/31/79
1/27/79
1/24/79
1/29/79
1/26/79
1/29/79
1/26/79
I/ JO/7 9
2/2/79
1/29/79
2/1/79
2/1/79
2/2/79
2/5/79
2/5/79
1/23/79
2/2/79
2/5/79
2/1/79
2/7/79
2/7/79
2/8/79
2/8/79
2/8/79
2/9/79
2/9/79
2/9/79
2/9/79
2/9/79
2/12/79
2/12/79
2/1/79
146
Illuminating Co.
Cleveland, Ohio
Dallas Power & Light Co.
Dallas, Texas
2/6/79
2/12/79
-------
14 6A
147
148
149
150
151
152
153
154
155
156
157
158
159
160
161
Dallas Power & Light Co.
Dallas, Texas
American Electric Power
Service Corporation
New York, N.Y.
Public Service Co. of N.M.,
Albuquerque, N.M.
Allied Chemical
Morristown, N.J.
Department ot Transportation
( Federal RR Admin.)
Washington, D.C.
Assn. of American
Railroads (Law Dept . )
Washington, D.C.
Idaho Power Co.
Boise, Idaho
Public Service Co. of
Oklahoma
Tulsa, Oklahoma
Carolina Power & Light Co.
Raleigh, N.C.
Texas Forestry Association
Lutkin, Texas
Portland General
Electric Co.
Portland, Oregon
Middle South Service Inc.
New Oreleans, La.
Central Vermont Public
Service Corporation
Rutland, Vermont
Texas Electric Service Co.
Fort Worth, Texas
Upper Peninsula Power Co.
houghton, Michigan
Duke Pov,er Co.
8/3/79
2/7/79
2/9/79
2/9/79
2/12/79
2/12/79
2/9/79
2/8/79
2/8/79
2/7/79
2/8/79
2/8/79
2/9/79
2/5/79
2/8/79
2/9/79
8/10/79
2/12/79
2/12/79
2/12/79
2/13/79
2/13/79
2/13/79
2/13/79
2/13/79
2/13/79
2/13/79
2/13/79
2/13/79
2/13/79
2/13/79
k/13/79
(Legal Dept.)
Charlotte. N.C.
-------
161A DuKe Power Co.
(Legal Dept.)
Charlotte, N.C.
3/16/79
3/20/79
162
163
164
165
166
167
168
168A
169
170
171
172
173
174
Union Electric Co.
St. Louis, Mo.
Mark Johnson,
Idaho
M.L. Dale, foayne Floch
Pummer , Idaho
Alfred L. Borchert,
Nampa , Idaho
M.T. Laurmin,
Casper, Vvyoming
Arizona Public Service Co.
Phoenix, Arizona
Georgia Power Co.
(Southern Electric System)
Atlanta, Georgia
Georgia Power Co.
Atlanta, Georgia
Northeast Utilities
Hartford, Connecticut
N.Y. Power Pool
Schenectady, N.Y.
New England Power Service
Vvestborough, Mass.
U.S. Dept. of Commerce
(industry & Trade Admin.)
Washington, D.C.
PA Electric Co.
Johnstown, Pa.
Nixon, Hargrave, Devans,
2/b/79
1/21/79
UNDATED
UNDATED
UNDATED
2/b/79
2/7/79
8/14/79
2/7/79
2/8/79
2/9/79
2/14/79
2/12/79
2/12/79
2/13/79
2/13/79
2/13/79
2/13/79
2/13/79
2/13/79
2/13/79
8/20/79
2/13/79
2/14/79
2/14/79
2/15/79
2/15/79
2/15/79
175
176
& Doyle (Rep: Rochester
Gas & Electric)
Rochester, N.Y.
Indianapolis Power & 2/9/79
Light Co.
Indianapolis, Indiana
111. Power Company 2/9/79
Decatur, 111.
2/15/79
2/15/79
-------
176A Illinois Power Co.
Decatur, 111.
177 Tampa Elec. Co.
Tampa, Fla.
178 Jersey Central Power
& Light Co.
Morristown, N.J.
179 Central & South West
Services, Inc.
Dallas, Texas
180 Mew York State Elec. &
Gas Corporation
Binghamton, N.Y.
184
185
186
187
188
18 8A
18 9
190
3/14/79
2/9/79
2/6/79
2/8/79
2/8/79
Light Co.
Cambridge, Ma.
Iowa Electric Light 2/5/79
& Powe r Co.
Cedar Rapids, Iowa
New Bedford Gas & Edison 2/9/79
Light Co.
New Bedtord, Ma.
Southern States Cooperative 2/5/79
Richmond, Va.
Niagara Mohawk Power
Corporation
Stracuse, N.Y.
2/6/79
Minnesota Power & Light Co. 2/8/79
Duiuth, Mn.
Minnesota Power & Light Co. 2/28/79
Duiuth, Mn.
Boston Edison Co.
Boston, Ma.
2/5/79
3/20/79
2/15/79
2/15/79
2/15/79
2/15/79
181
182
18 J
Pa. Power & Light Co.
All en town, Pa.
Canal Electric Co.
Sandwich, Ma.
Cambridge Electric
2/9/79
2/9/79
2/9/79
2/15/79
2/15/79
2/15/79
Department of Transportation 2/12/79
Raleigh, N.C.
2/15/79
2/15/79
2/15/79
2/15/79
2/15/79
3/7/79
2/15/79
2/15/79
-------
191
192
193
194
195
196
197
198
199
200
201
202
203
204
205
joint industry Coal lar 2/15/79
Committee
Jersey City, N.J.
Kerr-McGee Chemical 2/9/79
Corporation
Oklahoma City, GKlahoma
Samuel Cabot inc. 2nd Itr
Manufacturers (2nd mailing 2/15/79
incl. Itr fr Herrick & 2/6/79
Smith)
boston, Mass.
Kansas Power & Light Co. 2/12/79
Topeka, Ks.
Iowa-Illinois Gas & 2/8/79
Electric Co.
Davenport, Iowa
University of Caliiornia 2/13/79
(Coop. Extension)
Davis, Caliiornia
Lincoln Electric 2/12/79
Cooperative Inc.
Davenporc, Washington
Ron Frei UNDATED
Grangeville, Idaho
Long Island Lighting Co. 2/13/79
hicksville, N.Y.
Public Service Co. of 2/9/79
Colorado
Denver, Colorado
Langley and McDonald 2/9/79
Professional Corp.
Va . beach, Va.
McCormick i. Baxter 2/8/79
Creosoting Co.
Portland , Oregon
National Solvent Corp. 2/11/79
Medina, Ohio
Detroit Edison Elec. Co. 2/5/79
Detroit, Michigan
Gulf States Utilities Co. 2/9/79
beaumont, Texas
2/16/79
2/16/79
2nd Itr
2/23/79
2/16/79
2/22/79
2/22/79
2/22/79
2/22/79
2/22/79
2/22/79
2/23/79
2/23/79
2/23/79
2/23/79
2/23/79
2/23/79
-------
206
207
208
209
210
211
212
213
214
215
216
217
218
219
220
221
222
Atlantic Electric 2/8/79
Atlantic City, N.J.
West Penn Power Co. 2/9/79
Cabin Hill,
Greensburg, Pa.
Childscapes, Inc. 2/12/79
Atlanta, Ga.
Wisconsin Public 2/12/79
Service Corporation
Green Bay, Wi.
Iowa Public Service Co. 2/12/79
Souix City, Iowa
Cincinnati Gas & Electric 2/12/79
Company
Cincinnati, Ohio
Langdale Company 2/7/79
Valdosta, Ga.
Ohio Edison Co. 2/5/79
Akron, Ohio (see 213A)
Baltimore Gas & Electric Co. 2/8/79
Baltimore, Md.
C.H. Abrams
Lilburn, Ga.
Koppers Company Inc,
Salisbury, Md.
2/12/79
2/12/79
Department of Transportation 2/16/79
(Trans Bldg.)
Salem, Oregon
Scharf Family, 1/6/79
Amity, Oregon
Catawba Timber Company 2/22/79
Catawba, South Carolina
Missouri Power & Light Co. 2/21/79
Jefferson City, Missouri
Kaiser Agricultural 2/22/79
Chemicals
Savannah, Ga.
Tucson Gas & Electric Co. 3/5/79
Tuscon, Arizona
2/23/79
2/23/79
2/23/79
2/23/79
2/23/79
2/23/79
2/26/79
2/27/79
2/27/79
2/28/79
2/28/79
2/28/79
2/28/79
3/1/79
3/1/79
3/5/79
3/8/79
-------
223
224
225
226
227
228
229
230
231
232
233
234
235
236
237
Singing River Electric 2/28/79
Power Association
Lucedale, Ms.
Liz Vanleeuwen 2/12/79
Halsey, Oregon
Bowater Carolina Corp. 2/23/79
Catawba, S.C.
Vertac, Inc 2/9/79
Memphis, Tn.
Public Utility District 3/9/79
No. 1 of Klickitat City
Goldendaie, Washington
Port Authority of New York 3/14/79
& New Jersey
New York, N.Y.
Savannah Electric and Power UNDATED
Company
Savannah, Ga.
Columbus and Southern Ohio 3/19/79
Electric Co.
Columbus, Ohio
Poudre Valley Rural 3/23/79
Electric Association
Fort Collins, Colorado
Oregon Wheat Growers League 1/23/79
T.W. Thompson (Oregon)
kEMC, Boone County Rural 4/3/79
Electric Corp.
Lebanon, Indiana
Delaware County Electric UNDATED
Coop.
Delhi, N.Y.
Barkers Island Electric 4/3/79
Corporation
Harkers Island, N.C.
Roanoke Electric Corp. 4/3/79
Rich Square, N.C.
Flint Hills Rural Elec. UNDATED
Coop. Assoc. Inc.
Council Grove, Kansas
3/8/79
3/7/79
3/7/79
3/7/79
3/13/79
3/21/79
3/22/79
3/30/79
3/30/79
4/9/79
4/10/79
4/10/79
4/10/79
4/10/79
4/10/79
-------
237A
238
239
240
241
242
243
244
245
246
247
248
249
250
251
Flint Hills Rural Elec. 4/9/79
Coop. Assoc. Inc.
Council Grove, Kansas
Ohio State University 3/26/79
(forestry Division)
Columbus, Ohio
Farmers Electric Coop. Inc. UNDATED
Greenfield, Iowa
Continental Divide Electric 4/3/79
Coop. Inc.
Grants, New Mexico
McLennan County Electric
Coop. Inc.
McGregor, Texas
4/2/79
Taylor Electric Coop. Inc. UNDATED
Merkel, Texas
Springer Electric Coop. Inc. 4/4/79
Springer, Nevv Mexico
East Ms. Electric Po\*er
Association
Meridian, Ms.
4/4/79
Grundy Electric Coop., Inc. 4/5/79
Trenton, Mo.
Tri-County Electric 4/6/79
Co-Op Inc.
Azle, Texas
Rio Grande Electric 4/5/79
Coop. Inc.
Brackettville, Texas
Snohomish County Public 4/3/79
Utility District No. 1
Everett, Washington
Admas Electric Coop. Inc. 4/5/79
Gettysburg, Pa.
Nebraska Electric Generation 4/4/79
& Transmission Coop., Inc.
Columbus, Nebraska
Southern Pine Electric Coop. 4/9/79
Brewton, Alabama
4/17/79
4/10/79
4/10/79
4/10/79
4/10/79
4/11/79
4/11/79
4/11/79
4/11/79
4/11/79
4/11/79
4/11/79
4/11/79
4/11/79
4/13/79
-------
252
253
254
255
256
257
258
259
260
261
262
263
264
265
266
Midstate Electric Coop., 4/4/79
Inc.
La Pine, Oregon
Guthrie County Rural 4/6/79
Electric Coop.,
Gunthrie Center, Iowa
Norris Public Power UNDATED
District
Beatrice, Nebraska
Twin Valleys Public 4/6/79
Power District
Cambridge, Nebraska
Southeast Electric 4/5/79
Coop., Inc.
Ekalaka, Montana
Halifax Electric 4/6/79
Membership Corp.,
Enfield, N.C.
Logan County Co-Op Power 4/4/79
and Light Assoc., Inc.
beliefontaine, Ohio
K.C. Electric Assoc.
Hugo, Colorado
Tallapoosa River Electric
Coop.,
Lafayette, Alabama
Barney Electric Coop., Inc.
Burns, Oregon
Johnson County Electric
Coop.,
Cleburne, Texas
Kiamichi Electric 4/6/79
Coop., Inc.
Vvilburton, Oklahoma
Tri-County Electric 4/5/79
Membership Corp.,
Goldsboro, N.C.
Dixie Electric Membership 4/9/79
Corporation
Baton Rouge, La.
Midwest Electric Inc. 4/10/79
St. Marys, Ohio
4/13/79
4/13/79
4/13/79
4/13/79
4/13/79
4/13/79
4/13/79
4/4/79
4/5/79
4/6/79
4/6/79
4/13/79
4/13/79
4/13/79
4/13/79
4/13/79
4/13/79
4/13/79
4/13/79
-------
267
268
274
275
276
277
278
279
280
281
Lincoln Electric
Cooperative, inc.
Eureka, Montana
Northeast Missouri
Electric Power Corp.
Palmyra, Mo.
4/9/79
4/4/79
Membership Corp.,
Nahunca, Ga.
Kandiyohi Coop., Elec. 4/9/79
Power Association
toilimar, Mn.
EMC Lumbee River Electric 4/4/79
Membership Corp.,
Red Springs, N.C.
Planters Electric 4/5/79
Membership Corp.,
Millen, Ga.
Golden Valley Electric 4/5/79
Association, Inc.
Fairbanks, AlasKa
Re Sand Mountain Elec. Coop. 4/9/79
Rainesville, Ala.
Lake Region Electric 4/9/79
Coop., Inc.
Hulbert, uk.
Haywood Electric 4/11/79
Membership Corp.,
toaynesville, N.C.
Grand Electric Coop., Inc. 4/9/79
Bison, S.D.
4/13/79
4/13/79
269
270
271
272
27J
RSR Electric Coop., Inc.
Mil nor, N.D.
The Victory Electric Coop.,
Assoc. , Inc .
Dodge City, Kansas
United Electric Corp., inc.
Dubois, Pa.
Howard Electric Coop.,
Fayette, Mo.
Okefenoke Rural Electric
4/9/79
4/9/79
4/10/79
4/9/79
4/9/79
4/17/79
4/17/79
4/17/79
4/17/79
4/17/79
4/17/79
4/17/79
4/17/79
4/17/79
4/17/79
4/17/79
4/17/79
4/17/79
-------
282
283
284
285
286
287
288
289
290
Alger Delta Coop., 4/12/79
Elec. Assoc. (No Atch)
Gladstone, Mi.
C & W Rural Elec. Coop. 4/13/79
Assoc .
Clay Center, Kansas
Slope Elec. Coop., Inc. 4/12/79
New England, N.D.
Moreau-Grand Electric 4/3/79
Coop., Inc.
Timber Lake, S.D.
Valley Electric UNDATED
Membership Corp. ,
Natchitoches , La.
Re York County Rural 4/13/79
Public Power District
York, Nebraska
EMC Carroll 4/12/79
(Electric Membership Corp.)
Carrolton, Ga .
Mitchell Electric 4/11/79
Membership Corp.,
Camilla, Ga .
Flathead Electric Coop., 4/12/79
Inc. Power & Light
Kalispell, Montana
296
Coop . , Inc .
Langdon, N.D.
Wheatland Rural Electric
Association
Wheatland, Wyoming
4/18/79
4/18/79
4/18/79
4/20/79
4/20/79
4/20/79
4/20/79
4/20/79
4/20/79
291
292
293
294
295
East Central Electric Assoc
Braham, Minnesota
North-Central Electric
Coop . , Inc .
Attica, Ohio
Shenadoah Valley Electric
Coop . , Inc .
Dayton, Va .
Sac Osage Electric Coop.
El Dorado Springs, Mo.
Cavalier Rural Electric
. 4/11/79
4/12/79
4/11/79
4/9/79
4/11/79
4/20/79
4/20/79
4/20/79
4/20/79
4/20/79
4/11/79
4/20/79
-------
297
298
299
300
301
302
303
304
305
306
307
308
309
310
311
Beauregard Electric Co-op 4/6/79
Inc.
De Ridder, La.
Beartooth Electric 4/9/79
Co-op Inc.
Red Lodge, Montana
Pickwick Electric Coop., 4/12/79
Selmer, Tennessee
Pea River Electric Coop., 4/18/79
Gzark, Alabama
Peace River Electric 4/17/79
Cooperative, Inc.
Wauchula, Fla.
Plumes-Sierra Rural 4/17/79
Electric Cooperative, Inc.
Portola, California
Covington Electric Coop., 4/lb/79
Inc.
Andalusia, Alabama
Southwest Texas Electric 4/16/79
Coop. , Inc.
Eldorado, Texas
PolK County Rural Public 4/9/79
Power District
Stromsburg, Nebraska
EMC Blue Ridge Electric 4/23/79
Membership Corp.,
Lenoir, N.C.
Kamo Electric Cooperative 4/20/79
inc.
Vinita, Oklahoma
Bruce hunt 3/10/79
balem, Oregon
Verendyre Electric 4/23/79
Cooperative, Inc.
velva, N.D.
Wise Electric Cooperative, 4/18/79
Inc.
Dec
-------
312
313
314
315
316
317
318
319
320
321
322
323
324
325
326
Culiman Electric Cooperative 4/17/79
Cullman, Alabama
JacKson County Rural Elec. 4/18/79
Membership Corp.,
Brownstown, Indiana
Corn Belt Power Cooperative 4/16/79
Humboldt, Iowa
Sumpter Electric
Membership Corp.,
Americus, Ga.
4/19/79
Lower Valley Power & Light, 4/19/79
Inc.
Alton, Wyoming
Shelby Rural Electric 4/20/79
Cooperative Corp.,
Shelbyville, Ky.
Harrison County Rural 4/20/79
Electric Membership Corp.,
Corydon, Indiana
Edgecombe-Martin County 4/26/79
Electric Membership Corp.,
Tarboro, N.C.
Kosciusko County Rural 4/30/79
Electric Membership Corp.,
Warsaw, Indiana
Jackson Electric Membership 4/27/79
Corp.,
Jefferson, Ga.
Fairfield Electric 4/27/79
Cooperative, Inc.
Winnsboro, S.C.
Bare Electric Cooperative 4/30/79
Millboro, Va.
Habersham Electric 4/25/79
Membership Corp.,
Clarksville, Ga.
Western Illinois 4/24/79
Electrical Coop.,
Carthage, Illinois
Hickman-Fulton Counties 4/30/79
Electric Coop. Corp.,
Hickman, Ky.
4/30/79
4/30/79
4/30/79
4/30/79
4/30/79
4/30/79
5/1/79
5/4/79
5/4/79
5/4/79
5/4/79
5/4/79
5/4/79
5/4/79
5/4/79
-------
327
328
329
330
331
332
333
334
335
336
337
338
339
340
341
342
Meriwether Lewis Electric
Cooperatie
Centervj.lle, Tn.
4/27/79
Washington State University 5/3/79
(Coop. Ext. Service)
Pullman, Washington
American Institute of
Timber Construction
Englewood, Colorado
Southern Maryland Electric
Coop., inc.
Hughesvilie, Md.
Oliver B. Vvilbers
Umpqua, Or.
Dairyland Power Coop.
La Crosse, Wisconsin
Oliver-Mercer Elec. Coop.
Hazen, N.D.
Eastern Iowa Light &
Power Corp.,
Wilton, Iowa
Cookson hills Elect.
Coop. Inc.
Stigler, Ok.
Coos Curry Elect. Coop.,
Inc.
Coquille, Oregon
Iversek Research Int'l.
London, England
Green River Elec. Corp.,
Owensboro, Ky.
Concordia Elec. Coop. inc.
Ferriday, La.
Alabama Power Co.,
Birmingham, Ala.
Electric Power Board
Chattanooga, Tn.
U.S. Dept. of Agriculture
Forest Serv, Ashville, N.C.
5/2/79
5/3/79
5/8/79
5/9/79
5/9/79
5/9/79
4/7/79
5/10/79
5/9/79
5/9/79
4/26/79
5/9/79
5/29/79
6/5/79
6/11/79
6/15/79
6/15/79
6/15/79
5/17/79
5/17/79
5/17/79
5/21/79
5/2/79
5/23/79
6/6/79
6/14/79
6/22/79
6/22/79
6/28/79
6/28/79
-------
343
344
345
346
347
348
349
350
351
352
353
354
355
356
Ms. Power Co.
Gultport, Ms.
Public Utility Dist. No.l
Gkanogan, Wa.
lovva Southern Utility Co.
Centerville, Iowa
OASD, DOD (G. Marienthal)
Washington, D.C.
Memphis Light, Gas & Water
Div. ,
Memphis, Tn.
Lincoln Lite. Coop. inc.
EureKa, Montana
Montana state University
Bozeman, Montana
Gull States Utii. Co.
Beaumont, Tx.
McKenze Elec. Co-op, Inc.
Waterford, N.D.
Cleveland Utilities
Cleveland Tn.
Interstate Pov»er Co.
Dubuque, Iowa
TK (international
London, England
National Rural Elec. Coop.,
Washington, D.C.
American Wood Preservers
Institute
Pittsburgh, PA
6/20/79
7/2/79
7/3/79
6/27/79
7/11/79
6/25/79
7/16/79
B/ 2/7 9
7/13/79
7/6/79
8/2/79
7/26/79
8/22/79
2/28/80
6/28/79
7/9/79
7/9/79
7/12/79
7/19/79
7/19/79
8/2/79
8/10/79
8/10/79
8/10/79
8/16/79
8/16/79
8/22/79
2/28/80
-------
LISTING OF REBUTTAL COMMENTS - INORGANIC ARSEN1CALS
Rebuttal No.
1A
2A
Source
Penwalt Corporation
King of Prussia, PA.
Penwalt Corporation
(See frl) (2 Vols)
Philadelphia, PA.
Steptoe & Johnson
(Rep. AWPI)
Washington, D.C.
Steptoe b Johnson
(Rep AWPI)
Washington, D.C.
Date
of Comment
10/25/78
2/12/79
10/23/78
2/14/7y
Date
Received
11/20/78
2/12/79
11/20/78
2/15/7y
2B
2C
3
4
5
6
7
8
9
10
11
12
Steptoe & Johnson
Washington, D.C.
Steptoe & Johnson
Washington, D.C.
Society of American
Wood Preservers, Inc.
University of Ga . Coll.
Fitgerald, GA.
Department of Navy
Alexandria, VA.
Petit Paint Co., Inc.
Borough of Rockaway, N.J.
Agro-west, Inc.
Wilder, Idaho
Wilder Building Center -
Wilder, Idaho
Oregon State University
Corvallis, OR.
Kiry
Silsbee, TX.
National Cotton Council
Memphis, TN.
Howard Larson
4/20/79
1/28/80
9/12/78
11/3/78
11/17/78
11/9/78
11/10/79
11/10/78
11/14/78
11/14/78
12/16/78
11/13/78
4/26/79
1/31/80
11/21/78
11/20/78
11/20/78
11/20/78
11/20/78
11/20/78
11/20/78
11/27/78
11/27/78
11/27/78
Emmett, Idaho
-------
13
14
15
16
16A
17
18
19
20
20A
21
Donald Wallin
Isedor Wallin
Sanpoint, Idaho
L.D. McFarland Co.
Chemicals, Inc.
New Jersey
Chemicals, Inc.
Sewaren, N.J.
Chevron Chemical Co.
Richmond, CA.
Florida Power & Light Co.
Miama, FLA.
Johnny L. Crawlord
Chula, Georgia
Potomac Electric Power Co.
Washington, D.C.
Potomac Electric Power Co.
Washington, D.C.
Central Hudson Gas &
UNDATED
UNDATED
11/21/78
11/30/78
01/29/78
11/21/78
11/30/78
11/22/78
2/13/79
2/13/79
1127/78
11/28/78
11/28/78
11/27/78
12/06/78
2/26/78
12/05/78
12/08/78
12/06/78
2/13/79
2/13/79
12/06/78
21A
22
23
24
25
26
27
Electric Corp.
Poughkeepsie, N.Y.
Central Hudson Gas & 2/9/78
Electric Corp.
Poughkeepsie, N.Y.
Pacific Power & Light Co. 12/1/78
Portland, OR.
R.J. PoKorny
Westport, CONN.
benoret Chemical Co. 12/1/78
Kirkwood, Missouri
Department ot Agriculture 12/5/78
henry J. Ellis 12/4/78
Mancvhester, New Hamshire
Public Service Electric 12/1/78
& Ga s Co .
Newark, N.J.
2/13/78
12/6/78
12/8/78
12/11/78
12/8/78
12/6/78
-------
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
Dept. of Highways & Trans-
portation
Richmond, VA.
Jones Products Co., Inc
Middleton, WI.
United Building Supply, Inc
Anchorage, Alaska
Department of Transp.
Dover, Delaware
Dayton Power and Light
Dayuton, Ohio
University of 111.
Urbana, Illinois
Arkansas Power & Light Co.
Litle Rock, Arkansas
Allegheny Power System
Greensburg, PA.
Alabama Power Electric
System Birmingham, ALA.
Department of Agriculture
Saint Paul, MINN.
Vvest Elizabeth Lumber Co.
West Elizabeth, PA.
J. H. Baxter & Co.
San Mateo, California
Department of Interior
Washington, D.C.
Dept. of Agriculture
(K.D. Shelhamer)
Commonwealth of PA.
Dept. of Agriculture
Annapolis, MD.
Dept. of Transp.
Agana, Guam
Dept. of Transp.
State of Idaho
Potomac Edison Co.
Hagerstown, MD.
12/1/78
12/11/78
12/1/78
.12/8/78
12/7/78
12/1/78
12/5/78
12/4/78
12/7/78
12/5/78
12/12/78
12/13/78
12/14/78
12/13/78
12/12/78
12/13/78
12/13/78
12/14/78
12/15/78
12/13/78
12/13/78
12/13/78
12/13/78
12/13/78
12/13/78
12/13/78
12/18/78
12/18/78
12/18/78
12/20/78
12/20/78
12/18/78
12/20/78
12/21/78
12/21/78
12/21/78
-------
46
47
48
49
50
51
52
53
54
55
56
57
58
59
59A
60
Atchinson, Topeka, & 12/13/78
Santa Fe RR Co.
Chicago, ILL.
Atlantic Wood Industries 12/15/78
(A.G. Labrot)
Savannah, GA.
Thomasson Lumber Co. Inc. 12/15/78
(Hugh Thomason)
Philadelphia, Mississippi
111. Dept. of Transp. 12,18/78
Springfield, ILL.
Colfax Creosoting Co. 12/15/78
Pineville, LA.
Ms. Powder Southern 12/21/78
Electric System
Gulfport, MS.
Leonard Guss Associates, 12/20/78
Inc (J.B. Bonney) Tacoma,
Washington
South Texas Cotton & 12/11/78
Grain Association, Inc
Victoria, Texas
Otter Tail Power Co. 12/22/78
Fergus Falls, MN.
United Marine Publishing, 12/20/78
Inc. Kemah, Texas
Josh Tillinghast 12/19/78
Kemah, Texas
State Department of 12/14/78
Highways Denver, Colorado
Wm. A. Smith Contracting 12/20/78
Co., Inc. Shawnee Mission,
Kansas
Southern Wood Piedmont 12/19/78
co. Spartanburg, S.C.
Southern Wood Piedmont 2/6/79
Co. Spartanburg, S.C.
Arizona Commission of 12/20/78
Horticulture, Phoenix, AZ.
12/21/78
12/20/78
12/20/78
12/29/78
12/29/78
12/29/78
12/29/78
12/19/78
12/29/78
12/29/78
12/29/78
12/29/78
12/29/78
1/2/79
2/13/79
12/27/78
-------
61
62
63
64
65
66
67
68
69
70
70A
71
72
73
Barnes Lumber Corporation
Charlottesvilie , VA .
John F. Knupp
Conroe, Texas
Department of the Army
(Engineering Research Ctr.
Fort Belovoir, VA .
Consumers Power Co.
Jackson, Michigan
Public Service Company
ot N.H. Manchester, N.H.
Dept. of Transportation
FAA, Washington, D.C.
Maine Dept. of Trans-
portation Augusta, Maine
Ohio Dept. ot Trans-
portation Columbus, Ohio
Ca . Dept. of Transporation
Sacramento, California
Conroe, Creosoting Co.
(Jesse Rodriquez)
Conroe, Texas
Conroe, Creosoting Co.
Conroe, Texas
Smith-Evans Lumber
Company Rome, GA.
N.C. State University
Raleigh, N.C.
H.M. Monty Hawthorne
12/21/78
12/21/78
12/22/78
12/29/78
12/21/78
1/3/79
12/26/78
12/26/78
12/28/78
12/30/78
12/30/78
1/4/79
12/15/78
Undated
1/4/78
1/4/78
1/5/79
1/5/79
1/4/79
1/5/79
1/5/79
1/5/79
1/5/79
1/10/79
1/10/79
1/10/79
12/28/78
1/10/79
74
75
76
{ Fencing Supply Store
Conroe, Texas
Fla. Dept ot Agriculture 12/22/78
& Consumer Service
Tallahassee, FLA.
State Lumber & Supply 1/5/79
Co. , Inc .
Baton Rouge, LA.
US Dept of Agriculture 12/20/78
Forest Service
Athens, GA.
1/10/79
1/10/79
1/10/79
-------
77
78
79
80
81
82
83
84
85
86
87
88
89
90
91
•92
G.S. McClellan 12/30/78
Conroe, TX.
Lennice Sloan(Timber 12/30/78
Distr.)
Willis, TX.
Jerry Schaller 12/30/78
Conroe, Texas
Conroe Creosoting Co. 1/5/79
(Charline Hawthorne)
Conroe, TX.
Conroe Creosoting Co. 12/30/78
(Marie Henry)
Conroe, TX.
Conroe Creosoting Co. 12/30/78
(George B. Brodnax)
Conroe, TX.
Conroe Creosoting Co. 12/30/78
(W.E. Kolbe)
Conroe, TX.
Conroe Creosoting Co. 12/30/78
(Elmer Wiesinger)
Conroe, TX.
Conroe Creosoting Co. 12/30/78
(James Lumpkin)
Conroe Creosoting Co. 12/30/78
(Charline Muller)
Conroe, TX.
City Public Service Board 12/29/78
San Antonio, Texas
Dept. of Transp. 1/2/79
Commonwealth of Pa.
Harrisburg, PA.
Dept of Agriculture 12/29/78
Raleigh, N.C.
Apollo Forest Products 12/26/78
J. Zimmerman
Union City, GA.
L&M Lumber Co., Inc. 12/30/78
Willis, TX.
Univ. of Ca., 12/27/78
San Francisco, CA.
1/10/79
1/10/79
1/10/79
1/10/79
1/10/79
1/10/79
1/10/79
1/10/79
1/10/79
1/10/79
1/10/79
1/10/79
1/10/79
1/11/79
1/12/79
1/8/79
-------
93
94
95
96
97
98
99
100
101
102
103
104
105
106
107
108
109
Utah Dept. of Transp. 1/2/79
Salt Lake City, UT.
J.E.B. Ransone Lumber 1/9/79
Co. , Inc.
Metaire, LA.
Conroe Creosoting Co. 12/30/78
Con roe, TX.
Stephen F. Austin State 1/11/79
University
Nacogdoches, TX.
Central Wood Preserving, 1/10/79
Inc. Slaughter, LA.
Philadelphia Elec. Co. 1/11/79
Philadelphia, PA.
McFarland Cascade 1/9/79
C.L. Stoddard
Rexham Corp. 1/10/79
Larl Huston
Matthews, N.C.
Pacific Gas & Elec. Co. 1/12/79
San Francisco, CA.
Stephen F. Austin State 1/12/79
University
Nacogdoches, TX.
Hecla Mining Co. 1/12/79
Wallace, Idaho
Oregon State University 1/16/79
Corvallis, Oregon
Lake States Wood 1/16/79
Preserving, Inc.
Munising, Michigan
Julian Ochrymowych 1/23/79
New Providence, N.J.
Indiana Farm Bureau 1/15/79
Cooperative Assn., Inc.
Indianapolis, Indiana
Koppers Co., Inc. 1/11/79
Denver, Colo. (See #109)
Koppers Co., Inc. 1/16/79
Ontario, California (#108)
1/9/79
1/12/79
1/11/79
1/17/79
1/18/79
1/18/79
1/18/79
1/17/79
1/22/79
1/25/79
1/25/79
1/25/79
1/25/79
1/29/79
1/25/79
1/25/79
1/31/79
-------
110
111
111A
111B
112
11 2A
113
114
115
115A
116
117
118
119
120
121
122
123
Barnes Lumber Corp.
Charlottesville, VA.
Koppers Co., Inc.
Pittsburgh, PAA
Koppers Co., Inc.
(See #111) Pittsburgh,
PA. (Gerald L. Daugherty)
Koppers Company Inc .
Pittsburgh, PA.
Kopper Co., Inc.
Houston, Texas
Koppers Co., Inc.
Houston, Texas
Koppers Co., Inc.
Florence, S.C.
Koppers Co., Inc.
Oroville, California
Vepco
Richmond, VA.
Vepco
Richmond, VA.
A.M. Williams Inspection
Co., Inc. Mobile, Alabama
N.C. State University
Raleigh, N.C.
Merion B & Patty Reynolds
Allen, Texas
Ben L. Scholz
Wylie, Texas
University of Alabama
Tuscaloosa, ALA.
Brulin & Company Inc.
Indianapolis, Indiana
J.N. Kressbach
Gillette, N.J.
Edison Electric Institute
1/24/79
1/25/79
2/12/79
4/23/79
1/26/79
1/30/79
1/26/79
1/16/79
1/18/79
7/12/79
12/7/78
12/15/78
12/19/78
12/13/78
1/31/79
2/2/79
1/30/79
1/31/79
1/31/79
1/30/79
2/12/79
5/9/79
1/31/79
2/14/79
1/31/79
1/31/79
1/31/79
8/10/79
12/13/78
12/28/78
12/30/79
1/30/79
2/7/79
2/7/79
2/7/79
2/2/79
Washington, D.C.
-------
124
125
126
127
128
129
130
131
132
133
134
135
136
137
138
139
140
141
H.J. Haemmerlie
Gainesville, FLA.
Martin Marietta Chemicals
Charlotte, N.C.
F.A. Bartlette Tree Expert
Co., Stamford, CT.
W.T. Harris Charlotte,
N.C.
Richard H. Danielson
Atlanta, GA.
Southern California Edison
Co., Rosemead, California
Texas Powder & Light Co.,
Dallas, Texas
B.H. LeSuer
Gainesville, FLA.
Sumter Wood Preserving
Co., Bill Cox Sumter, S.C.
Dept . of Agriculture
(Science & Educ. Admin)
Grand Forks, N.D.
Bonide Chemical Co., Inc.
Yorkville, N.Y.
Honolulu Wood Training
Co., LTD. Honolulu, Hawaii
Fla. Citrus Mutual
Lakeland, FLA.
Export Leaf Tobacco Co.
Richmond, VA.
J.A. Jones Construction
Co., Charlotte, N.C.
R.O. Watson
Wilmington, Delaware
Cox Wood Preserving Co.,
Orangeburg, S.C.
Chemical Specialties, Inc.
1/29/79
1/26/79
1/24/79
1/27/79
1/24/79
1/29/79
1/26/79
1/30/79
1/24/79
1/30/79
1/30/79
1/31/79
1/31/79
2/2/79
1/29/79
2/1/79
2/5/79
2/6/79
271/79
2/1/79
2/1/79
2/5/79
2/5/79
2/7/79
2/7/79
2/8/79
2/5/79
2/8/79
2/8/79
2/8/79
2/8/79
2/9/79
2/9/79
2/9/79
2/12/79
2/12/79
Valdosta, GA.
-------
141A
142
143
144
145
145A
146
147
147A
148
149
150
151
152
153
154
155
Chemical Specialties, Inc.
Valdosta, GA.
Mansonite Corporation
Jackson, MS.
Texas Forest Service
Lufkin, Texas
Commissioner of Agricul-
ture (R.V. Brown) Austin,
TX.
PPG Industries, inc.
(W.R. Harris) Pittsburgh,
PA.
PPG Industries, Inc.
Pittsburgh, PA.
Cleveland Electric
Illuminating Co.,
Cleveland, Ohio
Dallas Power & Light
Co. , Dallas, TX.
Dallas Power & Light
Co., Dallas, TX.
American Electric Power
Service Corporation
New York, N.Y.
Idaho Power Co.,
Boise, Idaho
Public Service Co.
of Oklahoma Tulsa, OK.
Carolina Power &
Light Co., Raleigh, N.C.
Texas Forestry Assoc.
Lufkin, TX.
Portland General Electric
Co., Portland, Oregon
Middle South Services,
Inc. New Orleans, LA.
Central Vermont Public
3/21/79
1/29/79
2/5/79
1/31/79
2/12/79
2/16/79
1/23/79
2/6/79
8/3/79
2/7/79
2/9/79
2/8/79
2/8/79
2/7/79
2/8/79
2/8/79
2/9/79
•4/3/79
2/12/79
2/12/79
2/12/79
2/12/79
2/28/79
2/1/79
2/12/79
8/10/79
2/12/79
2/13/79
2/13/79
2/13/79
2/13/79
2/13/79
2/3/79
2/13/79
Service Corp., Rutland,
VT.
-------
156
157
158
159
160
161
162
163
164
164A
165
16 5A
166
167
168
169
Osmose
Buffalo, N.Y.
Grant Labs
Oakland, CA.
Texas Electric Service
Co., Forth Worth, TX.
Upper Peninsula Powder
Co., Houghton, Michigan
Duke Power Co., (Legal
Dept.) Charlotte, N.C.
Union Electric Co.,
St. Louis, MO.
M.L. , Dale Wayne ,
Floch, Plummer, Idaho
AZ Public Service Co.,
Phoeniz, AS.
Georgia Power Co.,
(Southern Elec. System
Atlanta, GA.
Georgia Power Co.,
Atlanta, GA.
University of Ca .
(Cooperative Extension)
Davis, California
Univ. of California
Davis, CA.
National Cotton Council
of America Memphis, TENN.
N.Y. Powder Pool
Schenectady, N.Y.
New England Power
Service Westborough, MA.
U.S. Dept. of Commerce
t f 3 * - «i 1- -* -T ------ v
2/9/79
2/5/79
2/5/79
2/8/79
2/9/79
2/8/79
Undated
2/6/79
2/7/79
2/9/79
2/9/79
7/2/79
2/8/79
2/8/79
2/9/79
2/14/79
2/13/79
2/13/79
2/13/79
2/13/79
2/13/79
2/13/79
2/13/79
2/13/79
2/13/79
2/13/79
2/13/79
7/19/79
2/14/79
2/14/79
2/14/79
2/15/79
(Industry & Trade Admin)
Vvashington, D.C.
170
Pa. Electric Co.
Johnstown, PA.
2/13/79
2/15/79
-------
171
172
Nixon, Hargrave, Devans 2/12/79
& Doyle (Rep: Rochester
Gas & Elec. Corp) .
Rochester, N.Y.
Indianapolis Power & 2/9/79
Light Co., Indianapolis,
Indiana
2/15/79
2/15/79
173
174
175
176
177
178
179
180
181
182
183
184
185
186
111. Power Co.,
Decatur, ILL.
Tampa Electric Co.,
Tampa, FLA.
Jersey Central Power
& Light Co., Morristown,
N.J.
Central 7 South West
Services, Inc. Dallas, TX.
New York State Electric
& Gas Corp., Binghanton,
N.Y.
P. A. Power & Light Co.,
Allen town, PA.
Canal Electric Co.,
Sandwich, MA.
Cambridge Electric Co.,
Cambridge, MA.
Iowa Electric & Power
Co., Cedar Rapids, Iowa
New Bedford Gas & Edison
Light Co., New Bedford,
MA.
Southern States Coopera-
tive Richmond, VA.
Niagra Mohawk Power Corp.
Syracuse, N.Y.
Dept. of Transportation
Raleigh, N.C.
Bank & Trust
2/9/79
2/9/79
2/6/79
2/8/79
2/8/79
2/9/79
2/9/79
2/9/79
2/5/79
2/9/79
21/5/79
2/6/79
2/1 2/7 9
1/30/79
2/15/79
2/1 5/7 9
2/15/79
2/15/79
2/15/79
2/15/79
2/15/79
2/15/79
2/1 5/7 9
2/15/79
2/15/79
2/15/79
2/15/79
2/16/79
Corpus Christi, TX.
-------
187
188
189
190
190A
191
Colwood Pressure Treated 2/5/79
Lumber Co. Inc., Columbia,
S.C.
Wool fork Chemical Works, 2/10/79
Inc., Fort Valley, GA.
Dept. of Health, Educ. 2/7/79
& Welfare Atlanta, GA.
National Ready Mixed 2/9/79
Conrete Assoc. Silver
Spring, MD.
National Ready Mixed 3/22/79
Concrete Assoc. (NRMCA)
Silver Spring, Maryland
Submitted by Counselor 2/9/79
Yaroschuk for S.L. Cowley
& Sons Mfg., Hugh, Ok.
2/15/79
2/15/79
2/16/79
2/16/79
4/3/79
2/23/79
192
193
194
195
196
197
198
199
200
201
Kansas Powder & Light
Co., Topeka, Kansas
Iowa-Illinois Gas &
Electric Co., Davenport,
Iowa
Long Island Lighting Co.,
Hicksville, N.Y.
Public Service Co., of
Colorado Denver, Colorado
Langley and McDonald
Professional Corp., Va .
Beach, CA.
Detroit Edison Elec,
Co., Detroit, MI.
Gulf States Utilities
Co., Beaumont, TX.
Atlantic Electric
Atlantic City, N.J.
West Penn Power Co.,
Greensburg , PA.
Childscapes, Inc.
2/12/79
2/8/79
2/13/79
2/9/79
2/9/79
2/5/79
2/9/79
2/8/79
2/9/79
2/1 2/7 9
2/22/79
2/22/79
2/22/79
2/23/79
2/23/79
2/23/79
2/23/79
2/23/79
2/23/79
2/23/79
Atlanta, GA.
-------
202
Wisconsin Public
Service Corp., Greenbay,
WI.
2/12/79
2/23/79
203
204
205
206
207
208
209
210
211
212
213
214
215
216
217
218
Chilton Paint Co.,
College Point, N.Y.
Cincinnati Gas &
Electric Co. ,
Cincinnati Ohio
Langdale Company
Valdosta, GA.
Ohio Edison
Akron, Ohio
Ridge Lumber Industries,
Inc., Lakeland, FLA.
C.H. Abrams
Lilburn, GA.
Koppers Company, Inc.
Salisbury, MD.
Department of Trans .
(Trans. Bldg) faalem, Oregon
Senator John Tower Vv/
Constitutents Ltr,
(Commerical State Bank),
Sinton, TX.
Dept. of Health Services
(health & Welfare Ag . )
Berkeley, CA.
Texas A&M University
College Station, TX.
Kaiser Agricultural
Chemicals Savannah, GA.
Tucson Gas & Electric
Co. , Tucson, AZ
Cities Service Co.,
(Citco) Atlanta, GA.
Minnesota Power &
Light Co., Duluth, MN
Bowater Carolina Corp.,
2/7/79
2/12/79
2/7/79
2/5/79
2/15/79
2/12/79
2/16/79
2/16/79
2/6/79
2/23/79
2/16/79
2/22/79
3/5/79
2/22/79
2/28/79
2/23/79
2/23/79
2/23/79
2/26/79
2/27/79
2/28/79
2/28/79
2/28/79
2/28/79
2/28/79
3/2/79
3/2/79
3/5/79
3/8/79
3/7/79
2/7/79
3/7/79
Catawba, S.C.
-------
219
Port ot Auth. for
New York & New Jersey
New York, N.Y.
3/14/79
3/21/79
220
221
222
223
224
225
226
227
228
229
230
231
232
233
234
Savannah Elec. and Power
Co . , Savannah , Ga .
Columbus and Southern
Ohio Elec. Co., Columbus,
Ohio
Dantzler Lumber and
Export Co., Jacksonville,
FLA.
Desoto Chemical Co.,
Inc., Arcadia, FLA.
Markers Island Elec.
Corp., harkers Island,
N.C.
Roanoke Electric Corp.,
Rich Square, N.C.
Ohio State University
(Div. ol; Forestry)
Columbus, Ohio
Continental Divide Elec.
Coop. Inc. Springer,
New Mexico
Springer Elec. Coop.
Inc., Springer, New Mexico
East Ms . Electric
Power Assoc.
Merdian, Ms .
Rio Grande Electric
Coop. Inc. Bracket tville ,
TX.
Adams Electric Coop. Inc.
Gettysburg, Pa.
Nebraska Electric
Generation Trans. Coop.
Inc., Columbus, Nebraska
Southern Pine Electric
Coop. Brewton, Alabama
Southeast Elec. Corp.
Undated
3/19/79
2/9/79
3/29/79
4/3/79
4/3/79
3/26/79
4/3/79
/4/79
4/5/79
4/5/79
4/5/79
4/4/79
4/9/79
4/5/79
3/22/79
3/30/79
4/3/79
4/6/79
4/10/79
4/10/79
4/10/79
4/10/79
4/11/79
4/11/79
4/11/79
4/11/79
4/11/79
4/13/79
4/13/79
Inc., Ekalaka, Montona
-------
235
236
237
238
239
240
241
242
243
244
245
246
247
Halifax Elec. Membership
Corp. En field, N.C.
Logan Country Co-op Power
and Light Assoc, Inc.
Bellefontaine, Ohio
Tallapoosa River Elec.
Coop. LaFayette,
Alabama
Barney Electric Coop..
Inc . , Burns , Oregon
Tri-Country Elec.
Membership Corp.,
Goldsboro, N.C.
Lincoln Electric Corp.,
Eureka, Montana
Northeast Missouri
Electric Power Coop.
Palmyra, MO.
The Victory Elec.
Coop . , Assoc . , Inc .
Dodge City, Kansas
United Elec. Coop.,
Inc., Dubois, PA.
Okefenoke Rual Elec.
Membership Corp.,
Nahunta, GA.
Golden Valley Elec.
Assoc., Inc., Fairbanks,
Alaska
Re Sand Mountain Elec.
Coop., Rainsville, Ala.
EMC Hay wood Elec.
4/6/79
4/4/79
4/5/79
4/6/79
4/9/79
4/9/79
4/4/79
4/9/79
4/10/79
4/9/79
4/5/79
4/9/79
4/11/79
4/13/79
4/13/79
4/13/79
4/13/79
4/13/79
4/13/79
4/13/79
4/17/79
4/17/79
4/17/79
4/17/79
4/17/79
4/17/79
248
249
Membership Corp.,
Waynesville, N.C.
Flint Hills Rural Elec. 4/9/79
Coop., Assn., Inc.,
Council Grove, KS
Alger Delta Coop., 4/12/79
Elec. Assoc.,
Gladstone, MI
4/17/79
4/18/79
-------
250
251
252
253
Slope Elec. Coop., Inc., 4/12/79
New England, N.D.
York Country Rural 4/13/79
Public Power District
York, Nebraska
Mitchell Elec. 4/11/79
Membership Corp.,
Camilla, GA.
Flathead Elec. Coop., 4/12/79
Inc., Power & Light
Kalispell, Montana
4/18/79
4/20/79
4/20/79
4/20/79
254
255
256
257
258
259
260
261
262
263
264
265
266
North-Central Elec.
Coop., Inc., Attica, Ohio
Shenandoah Valley Elec.
Coop., Inc., Dayton, VA.
Sac Osage Elec. Coop.,
El Dprado Springs, MO.
Cavalier Rural Elec.
Coop., Inc., Langdon, N.D.
Wheatland Rural Elec.
Assoc., Wheatland, Wyoming
Beauregard Elec. Co-op.,
Inc., De Ridder, LA.
Peace River Elec. Coop.,
Inc., Andalusia, Alabama
Covington Elec. Coop.,
Inc., Andalusia, Alabama
EMC Blue Ridge Elec.
Membership Corp.,
Lenoir, N.C.
Verendrye Elec. Coop.,
Inc . , Velva , N. D.
Wise Elec. Coop., Inc.,
Decature , TX.
Sumter Elec. Membership
Corp., Americus, GA.
Lower Valley Power &
4/12/79
4/11/79
4/9/79
4/11/79
4/11/79
4/6/79
4/17/79
4/18/79
4/23/79
4/23/79
4/18/79
4/19/79
4/19/79
4/20/79
4/20/79
4/20/79
4/20/79
4/20/79
4/20/79
4/24/79
4/24/79
4/26/79
4/30/79
4/30/79
4/30/79
4/30/79
Light, Inc., Afton,
Wyoming
-------
267
268
269
270
Shelby Rural Elec. 4/20/79
Coop., Corp.,
Shelbyville, KY
Harricon Country Rural 4/20/79
Elec. Membership Corp.
Corydon, Indiana
Edgecombe-Martin Country 4/26/79
Electric Membership Corp.,
Tarboro, N.C.
Kosciusko Country Rural 4/30/79
Elec. Membership Corp.
Warsaw, Indiana
4/30/79
5/1/75
5/4/79
5/4/79
271
272
273
274
275
276
277
278
279
280
281
282
Jackson Elec. Membership
Corp., Jefferson, GA
Fairfield Elec. Coop.,
Inc., Winnsboro, S.C.
Bare Elec. Coop. ,
Millsboro, VA
Habersham Elec.
Membership Corp.,
Clarkesville, GA
Western Illinois Elec.
Coop., Carthage, IL
Hickman-Fulton Countries
Elec. Coop., Corp.,
Hickman, KY
Washington State Univ.
Pullman, Washington
American Institute of
Timber Construction
Englewood, Colorado
Oliver B. Wiibers
Umpqua, OR.
Oliver-Mercer Elec.
Coop. Inc. Hazen, N.D.
Green River Elec.
Corp., Owensbror KY.
Alabama Power Co.
4/27/79
4/27/79
4/30/79
4/25/79
4/24/79
4/30/79
5/3/79
5/2/79
4/7/79
5/9/79
6/5/79
6/15/79
5/4/79
5/4/79
5/4/79
5/4/79
5/4/79
5/4/79
5/9/79
5/9/79
5/17/79
5/17/79
6/14/79
6/22/79
Birmingham, ALA.
-------
283
284
285
286
287
288
U.S. Dept. of Agricul. 6/15/79
Forest Service Asheville,
N.C.
DOD, OASD (G. Marienthai) 6/27/79
Washington, D.C.
Montana State Univ. 7/16/79
Bozeman, Montanna
McKenzie Elec. Co-op. 7/13/79
Watford, N.D.
Interstate Power Co. 8/2/79
Dubuque, Iowa
National Rural Electric 8/22/79
Coop.
Washington, D.C.
6/28/79
7/12/79
8/2/79
8/10/79
8/16/79
8/22/79
-------
LISTING OF REBUTTAL COMMENTS-PENTACHLOROPHENOL
buttal No.
1
See 1A,
IB
2
3
4
5
6
7
b
y
10
ii
See 11
11A
12
13
14
15
Source
steptoe and Johnson, Atts
(Rep. American Wood Pre-
servers Inst . )
Washington , D.C.
Steptoe ic Johnson
Washington, D.C.
i
Reichhoid Chemicals, Inc.
White Plains, N.Y.
Cooperative Ext. service
Fitzgerald, Ga .
Chapman Chemical Co.
Memphis, 'in.
Emerald Turf grass Farms
Seattle, Washington
Department of the Kavy
Alexandria, Va .
Agro-West, Inc.
Wilder, laaho
Link Noe, Wilder Blag. Ct
Wilder, Idaho
Consolidated Companies
Cleveland, Ohio
George Brown
Idaho Falls, Idaho
Howard Larson
Emmett, Idaho
Howard Larson
Emmett, Idaho
Chas . H. Lilly Co .
Porcland, Oregon
L.A. Tephson
Eaward Hener
Ray S. BukeL
Date
of Comment
. 10/23/78
4/27/79
11/7/78
11/3/78
ll/6/7b
il/lb/7b
ii/i 77 7 a
ll/l(J/7b
r. li/lO/7b
11/21/78
ll/ib/78
11/13/78
1/22/79
ll/lb/78
UNDATED
11/17/78
ii/lb/78
Date
Received
ii/2/78
5/1/7*
11/13/78
11/13/78
11/15/78
11/20/78
11/20/78
11/20/78
11/20/78
11/24/78
11/27/78
11/2SV78
2/lJ/7b«
11/29/78
11/29/78
11/24/78
11/^4/78
Teton, Idaho
-------
16
Ray B. Andrews
Idaho Fails, Idaho
UNDATED
11/24/78
17
18
18B
19
20
21
22
23
24
25
26
27
28
29
30
31
Debbin Johnson
Dow Chemical
(See 18A, 18B , 18C)
Midland, Michigan
Dow Chemical Co. (See 18,
18A, 18C 6 Vols.)
Midland, Michigan
L.D. McFarland Co.
Sandpoint, Idaho
Phil Baker
Teton, Idaho
Reo & George Archibald
Rexburg , Idaho
OM Scott & Sons
Marysville, Ohio
Robert Swanson
Idaho Fails, Idaho
Dean Schwendiman
Newdale, Ohio
Harry Field
Rigby , Idaho
National Chemical
Manufacturers
Atlanta, Georgia
0. Ray Hall
Rexburg, Idaho
Amle Landon
Rigby, Idaho
Kalispell Pole &
Timber Company
Kalispell, Montana
James Siddoway
Teton, Idaho
Commonwealth of Pa .
UNDATED
11/16/78
2/12/79
11/21/78
UNDATED
11/23/78
11/21/78
11/22/78
11/1 7/7 b
11/22/78
11/20/78
UNDATED
UNDATED
11/28/78
UNDATED
11/29/78
11/24/78
11/24/78
2/ 1 2/ 7 9
11/27/78
11/29/78
11/29/78
11/29/78
li/29/78
11/29/78
11/29/78
11/29/78
12/5/78
12/5/78
12/5/78
12/5/78
12/5/78
(Dept. of Environmental
Resources)
Harrisburg, Pa.
-------
32
33
34
35
35A
35B
36
37
Chevron Chemical Co. 11/27/78
Richmond, California
Union Oil Company of 11/29/78
California,
Union Chemicals Division
Gibson-Homans Company 11/30/78
Cleveland, Ohio
Dept. of Transportation 11/30/78
and Public Facilities
Juneau, Alaska
Dept. of Transportation 12/12/78
& Public Facilities
State of Alaska
Dept. of Transportation 12/19/78
& Public Facilities
Juneau, Alaska
(See 35 & 35A)
Johnny L. Crawford 11/22/78
Chula, Georgia
Potomac Electric Power Co. 11/28/78
Washgington, D.C.
12/5/78
12/5/78
12/6/78
12/5/78
12/21/78
12/29/78
12/6/78
12/6/78
See 37
37A
See 3ii
3 LA
38
39
40
41
42
43
Potomac Electric 2/12/79 2/13/79
Co.
Washington, D.C.
Central Hudson Gas & 2/9/79 2/13/79
Electric Corp.
Poughkeepsie, N.Y.
Central Hudson Gas & 11/27/78 12/6/78
Electric Corporation
Poughkeepsie, N.Y.
Louis Shirl UNDATED 12/6/78
John h. brown 11/28/78 12/6/78
Tetonia, Idaho
Jasco Chemical Corp. 11/30/78 12/6/78
Mountain View, California
Pacific Power & Light Co. l2/l/7t> 12/6/78
Portland, Oregon
Allan Ravenscroft 11/29/78 12/t>/78
Tuttle, Idaho
-------
43A
44
45
40
47
48
49
50
51
52
53
54
55
56
57
58
59
Bryan Ravenscroit 11/29/78
Tuttle, Idaho
Vernon Ravenscroft 11/29/78
Tuttle, Idaho
Kansas Department ol 12/1/78
Transportation
Topeka, Kansas
Industrial Water Chemicals 12/4/78
Chattanooga, Tenn.
Public bervice Electric 12/1/78
& Gas Company
Newark, N.J.
Henry J. Ellis
Manchester, N.H.
Fia. Power it Light Co.
Miami, Fla.
Osborne A. Goetz
Idaho Falls, Idaho
Midland Research Labs.
Houston, Texas
Lester Labs., inc.
Atlanta, Georgia
Herman Ratner
Atlantic City, N.J.
Jewel Hansen
Rexburg, Idaho
Tullio Gabos
Vineland, N.J.
Chemical Treatment Co.
Ashland, N.J.
Industrial Maintenance
Corp.,
Charlotte, N.C.
Reliance Brooks Inc. 12/5/78
Cleveland, Ohio
Arkansas State Plant 12/5/78
Board
Little Rock, Arkansas
12/6/78
12/6/78
12/6/78
12/7/78
12/6/78
12/4/78
11/3U/78
UNDATED
12/4/78
12/5/78
12/4/78
UNDATED
12/5/78
12/5/78
12/6/78
12/8/78
12/8/78
12/8/78
12/8/78
12/8/78
12/8/78
12/11/78
12/11/78
12/11/78
12/11/78
12/11/78
12/11/78
-------
bO
61
b2
b4
65
6b
67
68
b'J
70
VI
72
73
74
75
76
Harris Chemical Co., Inc. 12/5/78
Knozville, Term.
Chem-Masters Corp., 12/4/78
Chagrin Falls, Ohio
Water Services, Inc. 12/5/78
Knoxville, Tenn.
Dept. ot Agriculture 12/5/78
Atlanta, Gerogia
Dept. of Highways & 12/1/78
'iransportation
Richamond, Virginia
Kor-Chem 12/8/78
Atlanta, Georgia
Branchemco Inc. 12/5/78
Jacksonville, Fla.
/\.Vv. Vvilliams Inspection 12/7/78
Company
Mobile, Alabama
Allegheny Power System 12/7/78
Greensburg, Pa.
Arkansas Power & 12/4/78
Light Company
Little Rock, Arkansas
University ot Illinois 12/5/78
at Urbana-Champaign
Urbana, Illinois
Dayton Power & Light Co. 12/1/78
Dayton, Ohio
Department of 12/7/78
Transportation
Dover, Delaware
Blumberg Co. 12/8/78
Peabody, Mass.
Watcon, Inc. 12/7/78
South Bend, Indiana
Long Chemical Inc. 12/6/78
Los Angelas, California
Mac Gillis & Gibbs Co. 12/8/78
Milwaukee, Wisconsin
12/11/78
12/11/78
12/11/78
12/11/78
121178
12/13/78
12/13/78
12/13/78
12/13/78
12/13/78
12/13/78
12/13/78
12/13/78
12/13/78
12/13/78
12/13/78
12/13/78
-------
77
78
79
bl
82
83
85
86
87
88
91
92
Brenco Corporation 12/11/78
St. Louis, Missouri
National Chemsearch 12/13/78
Irving, Texas
Alabama Power Electric 12/5/78
System
Birmingnam, Ala.
Dept. ol Agriculture 12/12/78
Saint Paul, Minnesota
Atlantic Chemical & 12/13/78
Equipment. Co.
Atlanta, Georgia
Norman Chemical Co. 12/13/78
St. Paul, Minn.
Unichem International 12/14/78
ilobbs, N.M.
Faultless Pest Control 12/12/78
Inc. (H.L. Coleman)
Kansas City, Kansas
Department of Agriculture 12/13/78
Annapolis, Md.
Department ot Interior 12/13/78
Washington, D.C.
Nevv Orleans Public Service 12/1/78
Inc.
New Orleans, La.
Dept. of Agriculture 12/12/78
(Kenc D. Snelhamer)
Commonwealth of Pa .
Atlantic Wood Industries 12/15/78
Inc. (A.G. LdbrotJ
Savannan, Georgia
Precision Chemicals 12/13/78
(M.W. Fletcher)
Atlanta, Georgia
Atlantic Vvood Industries 12/15/78
(A.G. Labrot)
Savannah, Ga. (See fr89)
Atchison, lopeKa & 12/13/78
Santa Fe RR Co.
Chicago, 111.
12/18/78
12/18/78
12/18/78
12/18/78
12/20/78
12/20/78
12/20/78
12/20/78
12/20/78
12/20/78
12/13/78
12/20/78
12/21/78
12/21/78
12/21/78
12/21/78
-------
93
94
95
96
97
98
99
Potomac Edison Co.
Hagerstown, Md .
Dept . of Transportation
State of Idaho
Dept. of Agriculture
Agana, Guam
Thomasson Lumber Co*. Inc.
(Hugh Thomasson)
Philadelphia, Mississippi
111. Dept of Transportation
(Bureau of Materials &
Physical Res.)
Springfield, 111.
Coif ax Creosoting Co.
Pineville, Louisanna
Miss. Power Southern
12/15/78
12/14/78
12/13/78
12/15/78
12/18/78
12/15/78
12/21/78
12/21/78
12/21/78
12/21/78
12/22/78
12/29/78
12/29/78
12/29/78
100
101
102
103
104
105
106
107
Electric System
Gulfport, Miss.
Leonard Guss Associates, 12/20/78
inc.
Tacoma, Washington.
Vermont Agency of 12/22/78
Transportation (Eng. & Constr)
Montpelier, Vermont
United Marine Publishing, 12/20/78
Inc.
Kemah, Texas
R&M Consultants, Inc. 12/21/78
Anchorage, Alaska
Dept of Transportation 12/19/78
(U.S. Coast Guara)
Juneau, Alaska
American Seal Ktg. Co., 12/21/78
Inc.
Troy, N.Y.
Wm. A. Smith Contracting 12/20/78
Co ., Inc .
Shawnee Mission, Kansas
State Dept. of Highways 12/14/78
(Col. State Patrol)
Denver, Colorado
12/29/78
12/29/78
12/29/78
12/29/78
12/29/78
12/29/78
12/29/78
12/29/78
-------
108
109
110
111
111A
112
113
See 113
113A
114
115
116
117
118
119
120
121
American Water Treatment, 12/19/78
Inc.
St. Louis, Missouri
Bonners Ferry Post Co. 12/19/78
Bonners Ferry, Idaho
Omaha Public Power District 12/19/78
Cmaha, Nebraska
Tri-Copunty Electric 12/22/78
Cooperative
Rushford, Minnesota
Tri-County Electric
Cooperative
Rushford, Minnesota
Otter lail Power Co. 12/22/78
Fergus Falls, Minnesota
Southern Vvood Piedmont Co. 12/19/78
Spartanburg, S.C.
Southern Vvood Piedmont
Co.
Spartanburg, S.C.
2/6/79
Ohio Dept. of Agriculture 12/22/78
Columbus, Ohio
Department of the Army 12/22/78
Engineering Res. Ctr.,
Fort Belvoir, Va.
Public Service Co. of 12/21/78
New Hampshire
Manchester, New Hampshire
Indiana State Highway 12/27/78
Indianapolis, Indiana
Consumers Power Company 12/29/78
Jackson, Michigan
Dept. of Transportation 12/28/78
Sacramento, California
Ohio Department of 12/26/78
Transportation
Columbus, Ohio
Dept. of Iransportation i/3/79
Federal Aviation Administrarton
Washington, D.C.
12/29/78
12/29/78
12/29/78
12/29/78
4/11/79
12/29/78
12/29/78
2/13/79
1/5/79
1/5/79
1/4/79
1/5/79
1/5/79
1/5/79
1/5/79
1/5/79
-------
122
123
123A
123B
123C
123D
123E
123F
123G
124
125
126
127
128
Maine Department ot 12/26/78
Transportation
Augusta, Maine
Conroe Creosoting Company 12/30/79
(j.A. Ramey)
Conroe, Texas
Conroe Creosoting Company 12/30/78
(Charline H. Muiler)
Conroe, Texas
Conroe Creosoting Company 12/30/78
(James P. Lunpkin)
Conroe, Texas
Conroe Creosoting Company 12/30/78
(Elmer Weisinger)
Conroe Creosoting Company 12/30/78
(W.E. Kolbe)
Conroe, Texas
Conroe Creosoting Company 12/30/78
(George B. Brodnax)
Conroe, Texas
Conroe Creosoting Company 12/30/78
(Marie Henry)
Conroe, Texas
Conroe Creosoting Company 12/30/78
(Charline Hawthorne)
Conroe, Texas
Fla. Dept. of Agriculture 12/22/78
& Consumer Services
Tallahassee, Fla.
N.C. Dept. of Agriculture 12/29/78
(Commissioner)
Raleigh, N.C.
Dept. of Transportation 1/2/79
(Pa. Ofc. of Secretary)
Harrishurg, Penna.
City Public Service Board 12/29/78
San Antonio, Texas
G. Carl Baton (C&B Timber) 12/31/78
Ashton, Idaho.
1/5/79
1/10/79
1/10/79
1/10/79
1/10/79
1/10/79
1/10/79
1/10/79
1/10/79
1/10/79
1/10/79
1/10/79
1/10/79
1/10/79
-------
129
130
131
132
133
135
123H
136
137
138
139
140
141
142
N Logs Inc. 12/21/78
(James 1. Vvebb)
faherburne, N.Y.
Jerry Schaller 12/30/78
Conroe, Texas
Lennice Sloan (Timber 12/30/78
Distribution)
Willis, Texas
Hughes Brothers 1/4/79
(S.F. Smith)
Seward, Nebraska
G.S. McClellan 12/30/78
Conroe, Texas
H.M. Monty Hawthorne UNDATED
.(Fencing supply Store)
Conroe, Texas
N.C. State University 12/15/78
Raleigh, N.C.
Conroe Creosoting Company 12/30/78
(V.L. Andrews)
Conroe, Texas
University of California 12/27/78
ban Francisco
San Francisco, California
L&M Lumber Co., Inc. 12/30/78
(Mickey McMillin)
Willis, Texas
Walton, Feed, inc. (Steve) 1/13/79
Montpelier, Idaho
Monogahela Power Co. 1/12/79
Fairmont, West Va.
Stephen F. Austin State 1/11/79
University (Leonard F.
Burkart)
Nacogdoches, Texas
J. Whittaker UNDATED
Leadore, Idaho
McFarland Cascade 1/9/79
Sandpoint, Idaho
1/10/79
1/10/79
1/10/79
1/10/79
1/10/79
1/10/79
12/28/78
1/11/79
1/11/79
1/12/79
1/17/79
1/17/79
1/17/79
1/17/79
1/18/79
-------
143
144
145
14b
147
148
149
ISO
151
152
153
154
155
156
157
158
Philadelphia Electric Co. 1/11/79
Philadelphia, Penna.
bouth jersey Exterminating l/iQ/79
Corporation
Camaen, N.j.
Vvayne Vv. Rounciy 1/10/79
Boise, Idaho
Alien bauscher UNDA'lED
Fairlieid, Idaho
Elco Manufacturing Co. l/ib/79
Inc. (harry Katz)
Pittsburgh, Penna.
Rexham Corporation 1/1U/79
(Industrial Division)
Matthews, N.C.
Pacific G«s ana Electric 1/12/79
Company
ban Francisco, California
YaKima County Farm Bureau 1/17/79
Yakima, Washington
Burton Sav 1/19/79
Minneapolis, Minn.
Ham Paint bupply 1/19/79
Minneapolis, Minn.
Koss Paint and haiipaper 1/19/79
Inc.
Hopkins, Minn.
bt. Germain Bros. inc. UNDA'lED
Duluth, Minn.
Fred Bolt Paint & ballpaper 1/19/79
Co. Inc.
be. Paul, Minn.
Fleet Distributing buppiy 1/79
Vvadena, Minn.
Fleet Distributing bupply 1/19/79
Company
Little Falls, Minn.
Bemidji Fleet Distribution 1/19/79
Bern id j i, Minn .
1/1U/79
1/18/79
l/ib/79
l/ib/79
1/22/79
1/17/79
1/22/79
1/24/79
1/24/79
1/24/79
1/24/79
1/24/79
1/24/79
1/24/79
1/24/79
1/24/79
-------
159
160
161
162
163
164
See 164 A
165
166
16 6A
167
168
169
170
171
172
173
Haberman Supplies
Owatonna, Minn.
Lyle H. Guggishery
St . Cruix , Wi .
Koppers Company inc.
Denver, Col.
John J. Pennington
Eugene, Oregon
Gordon A. MacGregor
Boise, Idaho
Interstate Power Co.
Dubuque , Iowa
Interstate Power Co.,
Dubuque , iowa
Edison Sault Electric Co.
Sault Ste. Marie, Michigan
Oregon State University
(Theodore C. Scheffer)
Corvallis, Oregon
Oregon State University
(R.D. Graham)
Corvallis, Oregon
Indiana Farm Bureau
Cooperative Assn., Inc.
Lake States Wood Preserving
Inc .
Munising, Michigan
C.K. Peck
Lexington, Oregon
Houston Wood Treating Co.,
Inc.
Houston, Missouri
Decorator Supply Inc.
(J.F. Scheliien)
Rice Lake , Wi .
Fleet Distribution Supply
Thief River Falls, Minn.
Anderson Glass Co., Inc.
1/19/79
1/19/79
1/11/79
1/14/79
I/ 15/7 9
1/18/79
8/2/79
1/16/79
1/16/79
1/17/79
1/15/79
1/16/79
1/7/79
1/18/79
UNDATED
1/20/79
1/18/79
1/24/79
1/24/79
1/25/79
1/25/79
1/25/79
1/25/79
8/16/79
1/25/79
1/25/79
1/25/79
1/25/79
1/25/79
1/24/79
1/29/79
1/26/79
1/26/79
1/26/79
Grand Rapids, Minn
-------
174
175
176
177
178
179
17 9 A
t>ec 179
179A
180
G.F. Nemitz1 Sons
Hutchison, Minn.
Kenneth P. Strube
Rochester, Minn.
Gordon A. Peterson
Dresser, Wi .
Jan J. Don
Grandview, Washington
Wayne W. Roundy
Boise, Idaho
Vepco
Richmond , Va .
Vepco
Richmond , Va .
Vepco
Richmond, VA.
Koppers Company Inc. (194)
1/19/79
1/19/79
1/20/79
1/22/79
1/23/79
1/18/79
1/18/79
7/12/79
1/25/79
1/26/79
1/26/79
1/26/79
1/30/79
1/30/79
1/30/79
8/9/79
8/10/79
1/30/79
18 OA
18013
loi
182
183
184
Pittsburgh, Pa. (bee
161, 183, 188, 189, 192,
193 & 194)
Koppers Co. Inc., 2/12/79
(Gerald L. Daugherty)
Pittsburgh, Pa. (See 180)
Koppers Company Inc. (194) 1/25/79
Pittsburgh, Pa. (Sue
161. 1U3, 188, 189, 192,
193 & 194)
Kansas Gas & 1/23/79
Electric Co
Witchita, Kansas
New England Log Homes 1/22/79
Inc.
liamcien, Conn.
Koppers Company Inc. UNDATED
Superior, Wi.(See 161,
180, 188, 189, 192,
11JJ, 194)
Julian Cchrymov/ych 1/23/79
New Providence, N.J.
2/12/79
2/12/79
1/30/79
130/79
1/29/79
1/29/79
-------
18b
187
188
189
190
191
192
193
See 193
193A
194
195
196
197
198
Central Illinois Public 1/22/79
Service Co.
Springfield, ill.
Benjamin h. AdKins 1/23/79
Louisville, Kentucky
toillard Schoenfeiti 1/20/79
Red wood City, Ca.
Koppers Company Inc. 1/8/79
(See Ibl, 180, 183, 189,
192, 193,194)
North Little Rock, Ark.
Koppers Co. Inc. (See 1/22/79
161, 180, 183, 188, 192,
193, 194)
lie Plant, Ms.
VOID
William A. Rich 1/9/79
Minneapolis, Mn.
Koppers Co. Inc. 1/26/79
Florence, S.C. (See 161,
180, 183, 188, 189, 193
& 194)
Koppers Co. Inc. 1/26/79
(See Above)
Koppers Co. Inc. 1/30/79
Houston, Tx.
Koppers Co., Inc. 1/16/31
Oroville, Ca.
F.A. Bartlett Iree Co. 1/24/79
(Robert Bartlet)
Stamford, Ct.
Martin Marietta 1/26/79
Chemicals
Charlotte, N.C.
Dept. of Public 1/23/79
Instruction (C.V. Tart)
Raleigh, N.C.
H.J. Haemmerlie 1/29/79
Gainesville, Fla.
1/29/79
1/29/79
1/29/79
1/29/79
1/29/79
1/31/79
1/31/79
1/31/79
2/14/7 9
1/31/79
2/1/79
2/1/79
2/1/79
2/1/79
-------
199
Shoppers Supply Div.
200
20i
202
2U2A
203
204
205
206
207
208
209
210
211
212
213
214
Schmidt Distr. Inc.
Spencer, Iowa
Andren1 s Inc .
Duluth, Mn.
Edison Electric institute
Washington, D.C.
Koppers Co. Inc.
Nashua, M.H. (Charles
h. Fereday)
Koppers Company inc.
Nashua, N.H. (John L.
Peterson)
Vv.T. Harris
Charlotte, N.C.
J.T. Thornton
Dora , Mo .
Richard H. Danieison
Atlanta, Ga .
J.N. Kressbach
Gillette, N.J.
Louisiana-Pacific Corp.
Escanaba , Michigan
Southern California Edison
Co., Rosemead , California
Simonsen Chemical Co., Inc.
Cabool, Mo.
Texas Power & Light Co .
Dallas, Texas
Ace hardware Corp.,
Oak Brook, 111.
Charlie Keed
Rosalia, Washington
B.H. LeSueur
Gainesville, Fla .
Export Leaf Tobacco Co.
1/25/79
1/24/79
1/31/79
1/29/79
1/29/79
1/27/79
1/22/79
1/24/79
1/30/79
1/31/79
1/29/79
1/15/79
1/26/79
1/29/79
1/26/79
1/30/79
2/2/79
2/1/79
2/1/79
2/2/79
2/2/79
2/2/79
2/5/79
2/5/79
2/5/79
2/7/79
2/7/79
2/7/79
2/7/79
2/7/79
2/8/79
2/8/79
2/8/79
2/9/79
Richmond, Va.
-------
215
216
217
219
220
221
222
22J
224A
bee 224
224 A
225
22b
J.A. jones Construction,
Co.
Charlotte, N.C.
R.O. Watson
Wilmington, Delaware
Avco New Idea (Farm
Equipment Division)
Co id water, Ohio
Rogers Post & Lumber Co.
.teelviile, Missouri
Cleveland Llectric
illuminating Co.
Cleveland, Ohio
Robert K. Hastings
harbor, Oregon
Friends ot the Earth
(EriK Jansson)
Washington, D.C.
lexas Forest Service
LutKin, Tx .
Web & Sons Inc.
Sherburne , N.Y.
Dallas Power & Light Co.
Dallas, Texas
Dallas Power & Light
Dallas, TX.
American Electric Power
service Corp.
Public Service Co.,
ol New Mexico Albuquerque,
1/29/79
2/1/79
2/1/79
1/29/79
1/23/79
1/29/79
2/9/79
2/9/79
2/9/79
2/9/79
2/1/79
2/12/79
2/b/79
UNDATED
2/0/79
b/3/79
2/6/79
2/9/79
N.M.
2/12/79
2/12/79
2/12/79
8/10/79
2/12/79
2/12/79
227
228
229
W.C. Timber Products, 2/8/79
inc. (T.F. Clilten)
Rexburg, Idaho
Idaho Power Co. 2/9/79
Boise, Idaho
Public Service Co. of OK. 2/b/79
Tulsa, OK.
2/13/79
2/13/79
2/13/79
-------
230
231
232
233
234
235
236
237
238
239
240
241
242
243
244
245
246
Carolina Power & Light Co.
Raleigh, N.C.
Roof Surgeon Inc.
Honolulu, Hawaii
Texas Forestry Assoc.
Lufkin, Tx.
Portland General Electric
Co.
Portland, Oregon
Morton Buildings, Inc.
Morton, 111.
Middle South Services
Inc.
New Orleans, La.
Central Vermont Public
Service Corp.
Rutland, Vt .
Texas Electric Service Co.
Fort Worth, Tx .
Upper Peninsula Power Co.
Houghton, Michigan
Duke Power Co. (Legal
Dept.)
Charlotte, N.C.
Union Electric Co.
St. Louis, Mo.
Bill Deveny
Riggins, Idaho
Everett Van Seyke
Wilder, Id.
Mark Johnson,
Idaho
Reuben H. Babcock
Moore , Idaho
Picabo Livestock Co.
Picabo, Idaho
Don Heckman
2/8/79
2/9/7y
2/7/79
2/8/79
2/7/79
2/8/79
2/9/79
2/5/79
2/8/79
2/9/79
2/8/79
1/22/79
UNDATED
1/21/79
2/1/79
1/18/79
UNDATED
2/13/7y
2/13/79
2/13/79
2/13/79
2/13/79
2/13/79
2/13/79
2/13/79
2/13/79
2/13/79
2/13/79
2/13/79
2/13/79
1/13/79
2/13/79
1/13/79
2/13/79
White Bird, Idaho
-------
247
248
249
250
251
251A
bee 251
251 A
252
25 2A
252 B
253
254
255
25b
256A
257
258
M.L., Dale, Wayne Floch
Plummet:, Idaho
North Side Canal Co.
Jerome, Idaho
M.T. Laurmin
Casper, Wy.
Az . Public Service Co.
Phoenix, Az .
Georgia Power Co.
Atlanta, Ga .
Georgia Power Co.
Atlanta, Ga .
Georgia Power Co.,
Atlanta, GA.
Univ. of Calif.
(Cooperative Lxt . )
Davis, Ca .
Univ. of Calif.
(Cooperative Ext.)
Davis, Ca .
Univ. of Calif
Davis, CA.
Northeast Utilities
Hartford, Ct .
Vulcan Materials Co.
Birmingham, Ala.
N.Y. Power Pool
bchenectaay, N.Y.
Iowa Power & Light Co.
Des Moines, Iowa
iowa Electric Light &
Power Co.
Cedar Rapids, iowa
New England Power Service
Westborough, Mass.
U.S. Dept. of Commerce
UNDATED
1/26/79
UNDATED
2/6/79
2/7/79
2/7/79
8/14/79
2/9/79
2/9/79
7/2/79
2/7/79
2/8/79
2/8/79
UNDATED
2/5/79
2/9/79
2/14/79
2/13/79
2/13/79
2/13/79
2/13/79
2/13/79
2/13/79
8/20/79
2/13/79
2/13/79
7/19/79
2/13/79
2/14/79
2/14/79
2/14/79
2/15/79
2/14/79
2/15/79
(Industry & Trade Admin.)
Washington, D.C.
-------
259
260
261
262
26 2A
263
264
265
266
Pa. Electric Co. 2/12/79
Johnstovvn , Pa .
Nixon, Hargrave, Devans & 2/12/79
Doyle (Rep: Rochester Gas &
Elec. Corp.)
Rochester, N.Y.
Indianapolis Power & Light 2/12/79
Company
Indianapolis, Indiana
111. Power Co. 2/9/79
Decatur, 111.
Illinois Power Company 3/14/79
Decatur, 111.
Tampa Electric Co. 2/9/79
Tampa, Fla.
Jersey Central Power & 2/6/79
Light Co.
Morristown, N.J.
Central & South West 2/8/79
services, Inc.
Dallas, Tx.
New York State Electric 2/8/79
& Gas Corporation
Binghamton, N.Y.
273
Corporation
Syracuse, N.Y.
Minnesota Power & Light Co.
Duluth, Mn.
2/15/79
2/15/79
2/15/79
2/15/79
3/20/79
2/15/79
2/15/79
2/15/79
2/15/79
267
268
269
270
271
272
Pa. Power & Light Co.
Allentown, Pa.
Canal Electric Co.
Sandwich, Mass.
Cambridge Electric Light
Cambridge, Mass.
New Bedford Gas & Edison
Light Co.
Duluth, Minn.
Southern States Cooperative
Richmond, Va.
Niagra Mowhawk Power
2/9/79
2/9/79
2/9/79
2/9/79
2/5/79
2/6/79
2/15/79
2/15/79
2/15/79
2/15/79
2/1 5/7 9
2/15/79
2/8/79
2/15/79
-------
27 3A
274
275
27 5A
276
277
278
278A
279
280
281
282
283
284
285
286
Minnesota Power & Light Co.2/28/79
Duiuth, Minn.
Boston Edison Co. 2/5/79
Boston, Mass.
American Paper Institute 2/12/79
Washington, B.C.
Lumber River Elec.
Membership Corp.
2/12/79
2/7/79
2/8/79
2/12/79
2/12/79
287
Dept. of Transportation
Raleigh, N.C.
Delsea Exterminators
Camden, N.J.
Forshaw Chemicals
Charlotte, N.C.
The Washington Water
Power Co.
Spokane, Washington
Kansas Power & Light Co.
Topeka, Ks.
Iowa-Illinois Gas &
Electric Co.
Davenport, Iowa
National Solvent Corp., 2/11/79
Medina, Ohio
Lincoln Electric Coopera- 2/12/79
tive Inc.
Davenport, Washington
Ron Frei UNDATED
Grangeville, Idaho
Long Island lighting Co. 2/13/79
Hicksville, N.Y.
University of Idaho, Coll. 1/31/79
of Agriculture
Dept. of Agri.,
Moscow, Idaho
Public Service Co. 2/9/79
of Colorado
Denver, Colorado
3/7/79
2/15/79
2/15/79
4/17/79
2/15/79
2/16/79
2/16/79
2/22/79
2/22/79
2/22/79
2/22/79
2/22/79
2/22/79
2/22/79
2/23/79
-------
288 Langiey and McDonald
Professional Corp.,
Va. Beach, Va.
289 L.E. Fake
Charlotte, N.C.
29U Detroit Edison Electric
Co .
Detroit, Mi.
291 Gulf States Utilities
Co.
Beaumont, 'i'x .
292 Atlantic Electric
Atlantic City, N.J.
293 hest Penn Power Co.
Greensburg , Pa.
294 Childscapes, Inc.
Atlanta, Ga.
295 Wisconsin Public Service
Corp. ,
Green Bay, Wi.
296 M & & Chemicals Inc.
Kathway, N.J.
297 Iowa Public Service Co.
Sioux City, Iowa
298 Cincinnati Gas & Electric
Co.
Cincinnati, Ohio
See 22 OM Scott & Son (Vol 1
299 only)(VolIl NFPD)
Karyville, Ohio
300 Langdale Co.
Valdosta, Ga
301 Ohio Edison Co.
Akron, Ohio
See 301, Ohio Edison Co.,
301 A Akron, uH
J02 Baltimore Gas & Electric
Co.
Baltimore, Md.
2/9/79
UNDATED
2/5/79
2/9/79
2/23/79
2/23/79
2/23/79
2/23/79
2/8/79
2/9/79
2/12/79
2/12/7*
2/9/79
2/12/79
2/12/79
2/12/79
2/7/79
2/5/79
6/28/79
2/8/79
2/2J/79
2/23/79
2/2^/79
2/23/79
2/23/79
2/23/79
2/23/79
2/23/79
2/26/79
2/27/79
7/9/79
2/27/79
-------
303
304
305
306
307
308
309
310
311
See 312A
312
312A
313
314
315
316
Kootenai Electric 2/16/79
Coeur D'Alene, Idaho
Wisconsin Electric Power 2/15/79
Co.
Milwaukee, Wi.
C.H. Abrams 2/12/79
Lilburn, Ga.
San Diego Gas & Electric 2/15/79
San Diego, Ca .
Department of Transporta- 2/16/79
tion(Trans. Bldg)
Salem, Oregon
Scharf Family 1/6/79
Amity, Oregon
Ventron Corp. (Chemicals 2/12/79
Division)
Beverly, Ma. (Confidential
Atchs. Withdraw A & B)
Missouri Power & Light Co. 2/21/79
Jefferson City, Mo.
Central Electric Power 2/26/79
Cooperative
Jefferson City, Mo.
Benton Rural Rural 2/15/79
Electric Assoc.
Prosser, Washington
Benton Rural Electric 3/1/79
Association
Prosser, Washington
Kaiser Agricultural 2/22/79
Chemicals
Savannah, Ga.
Tucson Gas & Electric Co. 3/5/79
Tucson, Az.
Singing River Electric 2/28/79
Power Association
Lucedale, Ms.
White River Electric 2/27/79
Power Association
Meeker, Colorado
2/28/79
2/28/79
2/28/79
2/28/79
2/28/79
2/28/79
2/28/79
3/1/79
3/5/79
3/2/79
3/7/79
3/5/79
3/8/79
3/8/79
3/7/79
-------
317
318
319
320
321
321A
bee 321, A
321 B
Liz Vanleeuwen 2/12/79
Halsey, Oregon
Bowater Carolina Corp. 2/23/79
Catawba, S.C.
Yampa Valley Electric 3/7/79
Association, Inc.
Steamboat Springs, Col.
Sonford Products Corp., 2/8/79
(Southern Div.)
Jackson, Miss.
Public Utility District 3/9/79
No. 1 of Klickitat Cty
Goldendale, Washington
Public Utility District 3/9/79
No. 1 of Okanogan Cty.
Okanogan, Washington
Public Util. Distr. No. 1 7/2/79
No. 1 Okanogan, WA.
3/7/79
3/7/79
3/13/79
3/13/79
3/13/79
3/13/79
7/9/79
322
323
324
325
326
327
328
329
Wasco Electric Cooperative, 3/12/79 3/20/79
inc.
Dalies, Oregon
Nebraska Public Power 3/12/79 3/2G/79
Columbus, Nebraska
Port Authority ot New York 3/14/79 3/22/79
& New Jersey
New York, N.Y.
Savannah Electric & Power UNDATED 3/22/79
Company
Savannah, Georgia
Orcas Power & Light Company 3/19/79 3/26/79
Eastsound, Washington
Thyrald H. Finn 3/16/79 3/26/79
Rigby, Idaho
Dixie Electric Power ASSOC. 3/19/79 3/29/79
Laurel, Ms.
Memphis Light, Gas and 3/20/79 3/30/79
Water Division
Memphis, Tenn.
-------
330
33i
332
333
334
335
336
Columbus and Southern Ohio 3/19/79
Electric Co.
Columbus, Ohio
Poudre Valley Rural 3/23/79
Electric Association
Fort Collins, Colorado
Public Utility District 3/23/79
No. 1 of Cheian County
Wenatehee, Washington
Carbon Power & Light Inc. 3/21/79
Saratoga, Wyoming
Eugene Water & Electric 3/26/79
Board
Eugene, Oregon
3/30/79
3/30/79
3/30/79
4/3/79
4/3/79
337
338
339
340
341
342
343
344
Dearborn Chemical Chemed 3/30/79
Corp.,
Lake Zurich, 111.
Inter County Rural Eiec. 4/3/79
Coop. Corp.,
Danville, Kentucky
Craig-Cotetourt Elec. Coop. 4/4/79
New Castle, Penna.
Crow Wing Coop. Power & UNDATED
Light Co.
Brainerd, Minn.
Delaware County Electric UNDATED
Coop.
Delhi, New York
Barkers Island Elec. Corp. 4/3/79
Barkers, Island, N.C.
Roanoke Electric Corp. 4/3/79
Rich Square, N.C.
Flint Bills Rural Elec. UNDATED
Coop. Assoc. Inc.
Council Grove, Kansas
4/10/79
4/10/79
4/10/79
4/10/79
4/10/79
4/10/79
4/10/79
4/10/79
-------
34 4A
See 344
Flint Hilis Rural Elec., 4/9/79
Coop., Assn., Inc. Council
Grove, Kansas
3/26/79
4/3/79
4/3/79
4/4/79
4/4/79
345 Ohio State University
(Forestry Division)
Columbus, Ohio
346 Farmers Elec. Coop., Inc.
Greenfield, Iowa
347 Continental Divide Elec.
Coop., Inc.
Grants, New Mexico
348 Springer Electric Coop.,
Inc.
Springer, New Mexico
349 East Ms. Electric Power
Assoc.
Meridian, Ms.
350 Grundy Electric Coop. Inc.
Trenton, Mo.
111A Tri-County Electric Coop.
Portland, Mi.
351 Rio Grande Electric Coop.,
BracKettville, Tx.
352 Snohomish County Public
Utility District No. 1
Everett, Washington
353 Adams Electric Coop., Inc.
Gettysburg, Penna.
354 Nebraska Electric Generation 4/4/79
& Transmission Coop., Inc.
Columbus, Nebraska
355 Public Utility District of 4/4/79
Grant County
Ephrata, Washington
356 Grand Valley Rural Power 4/5/79
Lines, Inc.
Grand Junction, Colorado
357 Southern Pine Electric 4/9/79
brewton, Alabama
4/17/79
4/10/79
4/10/79
4/10/79
4/11/79
4/11/79
4/5/79
4/5/79
4/5/79
4/3/79
4/5/79
4/4/79
4/11/79
4/11/79
4/11/79
4/11/79
4/11/79
4/11/79
4/11/79
4/11/79
4/13/79
-------
359
36U
361
362
363
364
365
366
367
368
369
37U
371
372
Midstate Electric Coop., 4/4/79
Inc.
La Pine, Oregon
Southeast Electric Coop., 4/5/79
Inc.
EKuiaka, Montana
Halitax Electric Membership 4/6/79
Corporation
Enfield, N.C.
Logan County Co-op Power 4/4/79
and Lignt Assoc. inc.
Beilelontaine, Ohio
K.C. Electric Association
hugo, Colorado
Tailapoosa River Electric
Cooperative
Lafayette, Alabama
Barney Electric Coop., Inc.
burns, Oregon
Kiamichi Electric Coop.,
Inc.
Wilbur ton, Ok.
Tri-County Electric 4/5/79
Membership Corp.
Coldsboro, N.C.
Midwest Electric inc. 4/1U/79
St. Marys, Ohio
Lincoln Electric 4/10/79
Cooperative, Inc.
Eureka, Montana
Norhteast Missouri Electric 4/4/79
Power Coop.
Palmyra, Mo.
Public Utility District 4/9/79
No. 1 ot Franklin Cty
Pasco, Washington
Jo-Carroll Electric 4/4/79
Coope rative, inc.
Elizabeth, 111.
Rutherford Electric UNDATED
Membership Corp.
Forest City, N.C.
4/13/79
4/13/79
4/13/79
4/13/79
4/4/79
4/5/79
4/6/79
4/6/79
4/13/79
4/13/79
4/13/79
4/13/79
4/13/79
4/13/79
4/13/79
4/13/79
4/13/79
4/13/79
4/13/79
-------
373
374
375
387
Waynw-White Counties 4/4/79
Electric Cooperative
Farifield, 111.
Douglas Electric Coop., 4/6/79
Inc.
Roseburg, Oregon
Missouri Public Service 3/27/79
Company
Kansas City, Mo.
Coop., Inc., Hulbert,
Oklahoma
EMC Haywood Elec.,
Membership Corp.,
Waynesville, N.C.
4/11/79
4/13/79.
4/13/79
4/13/79
376
377
378
379
380
381
382
383
384
385
386
RSR Elec. Co-op Inc.
Milnor, N.D.
The Victory Elec. Coop.
Assoc . , Inc .
Dodge City, Kansas
United Elec. Coop. Inc.
Dubois, Iowa
Howard Elec. Coop.
Fayette, Mo.
Glacier Elec. Coop., Inc.
Cut Bank, Montana
Okefenoke Rural Elec.,
Membership Corp.,
Nahunta, GA.
Kandiyohi Coop., Elec.,
Power Association Willmar,
MN
Planters Elec., Membership
Corp., Millen, GA.
Golden Valley Elec.,
Assoc., Inc. Fairbanks,
Alaska
Re Sand Mountain Elec.,
Coop., Rainsville, Alabama
Lake Region Elec.,
4/9/79
4/9/79
4/1U/79
4/9/79
4/10/79
4/9/79
4/9/79
4/5/79
4/5/79
4/9/79
4/9/79
4/17/79
4/17/79
4/17/79
4/17/79
4/17/79
4/17/79
4/17/79
4/17/79
4/17/79
4/17/79
4/17/79
4/17/79
-------
388
Grand Elec., Coop.,
Inc., Bison, S.D,
4/9/79
4/17/79
389
Union Rural Elec., 4/10/79
Association, Inc.,Brighton,
Colorado
4/18/79
390
391
392
393
394
395
396
397
398
399
400
401
402
403
404
Kotzebue Elec., Assoc.,
Inc., Kotzebue, Alaska
Alger Delta Coop., ,
Elec., Association Inc.,
Gladstone, Ml
TRI-County Elec., Assoc.,
Inc., Piankinton, S.D.
C&W Rural Elec., Coop.,
Association Clay Center,
Kansas
Slope Eiec., Coop.,
Inc., New England, N.D.
Moreau-Grand Elec., Coop.,
Inc., Timber Lake S.D.
Valley Elec., Membership
Corp., Natchitoches, LA.
4/9/79
4/12/79
4/12/79
4/13/79
4/12/79
4/3/79
Undated
York Country Rural Public 4/13/79
Power District York, Nebraska
Carroll Elec., Membership
Corp., Carroll ton, GA.
San Luis Valley Rural
Elec., Coop., Inc. Monte
Vista, Colorado
Mitchell Elec., Membership
Corp., Camilla, GA.
Flathead Elec., Coop.,
Inc., Power & Light
Kali spell, Montana
East Central Elec.,
Assoc., Braham, MN
North-Centtai Elec.,
Coop., Inc. Attica, Ohio
Wells Rural Elec.,
4/12/79
4/9/79
4/11/79
4/12/79
4/11/79
4/12/79
4/12/79
4/18/79
4/18/79
4/18/79
4/18/79
4/18/79
4/20/79
4/20/79
4/20/79
4/20/79
4/20/79
4/20/79
4/20/79
4/20/79
4/20/79
4/20/79
Co., Wells, Nevada
-------
405
421
Intermountain Rural
Elec ., Assoc.,
Littleton, Colorado
4/12/79
4/20/79
406
407
408
409
410
411
412
413
414
415
416
417
418
419
420
Roseau Elec., Coop.,
Inc . , Roseau , MM.
Mountain View Elec.,
Assoc . , Inc . , Limon ,
Colorado
bhenandoah Valley Elec.,
Coop., Inc., Dayton, VA.
Sac Csage Elec., Coop.,
El Dorado Springs, MO
Cavalier Rural Elec.,
Coop., Inc., Langdon , N.D.
Wheatland, Rural Elec.,
Assoc., Wheatiand, Wyoming
Beauregard Elec., Co-op.,
Inc., De Ridder, LA.
Beartooth Eiec., Co-op.,
Inc., Red Lodge, Montana
Warren Rural Elec.,
Coop., Corp., Bowling
Green, KY.
Maquketa Valley Rural
Elec., Coop., Anamosa, Iowa
Pickwick Elec., Coop.,
Seimer, Tenn .
Pearl River Valley Elec.,
Power Assoc., Columbia, MS.
Pea River Elec., Coop.,
OzarK, Alabama
Peace River Elec., Coop.,
Inc., Wauchula, Fla .
PI umas-Sierra Rural
Undated
4/9/79
4/11/79
4/9/79
4/11/79
4/11/79
4/6/79
4/9/79
4/12/79
4/12/79
4/12/79
4/11/79
4/18/79
4/17/79
4/17/79
4/20/79
4/20/79
4/20/79
4/20/79
4/20/79
4/20/79
4/20/79
4/20/79
4/20/79
4/20/79
4/20/79
4/20/70
4/24/79
4/24/79
4/24/79
Elec., Coop., Inc.,
Portola, California
Covington Elec., Coop.,
Inc., Andalusia, Alabama
4/18/79
4/24/79
-------
422
423
424
425
426
427
428
429
430
431
432
433
434
435
436
437
438
TRI-County Rural Elec., 4/17/79
Coop., Inc., Mansfield, Pa.
Polk Country Rural Public 4/9/79
Power District Stromsburg
Nebraska
Fall River Rural Elec., 4/19/79
Coop., Inc., Ah s ton , Idaho
Blue Ridge Elec., 4/23/79
Membership Corp.,
Lenoir,N.C.
Bruce Hunt 3/20/79
Salem, Oregon
Verendrye Elec., Coop., 4/23/79
Inc., Velva, N.D.
Wise Elec., Coop., Inc., 4/1/79
Decatur, TX
Cumberland Elec., 4/20/79
Membership Corp.,
Clarksville, TN.
Cullman, Elec., Coop., 4/17/79
Cullman, Alabama
Jackson Country Rural 4/18/79
Elec., Membership Corp.,
Brownstown, Indiana
Corn Belt Power Coop., 4/16/79
Humboldt, Iowa
Sumter Electric Membership 4/19/79
Corp., Americus, GA.
Lower Valley Power & 4/19/79
Light, Inc., Afton, Wyoming
Shelby Rural Eiec., Coop., 4/20/79
Shelbyville, KY
Dairyland Power Coop., Undated
La Crosse, WI
Cotton Elec., Coop., Undated
Walters, OK
Sun River Elec., Coop., 4/18/79
Inc., Fairfield, Montana
4/24/79
4/24/79
4/26/79
4/26/79
4/30/79
4/30/79
4/30/79
4/30/79
4/30/79
4/30/79
4/30/79
4/30/79
4/30/79
4/30/79
4/30/79
4/30/79
4/30/79
-------
439
440
441
442
Harrison County Rural 4/20/79
Elec., Membership Corp.,
Corydon, Indiana
Edgecombe-Martin County 4/26/79
Elec./ Membership Corp.,
larboro, N.C.
Kosciusko County Rural 4/30/79
Llec., Membership Corp.,
Warsaw, Indiana
Jackson Electric 4/27/79
Membership Corp.,
Jefferson, GA.
5/1/79
5/4/79
5/4/79
5/4/79
443
444
445
446
447
448
449
450
451
452
453
454
454A
Fairtield Elec., Coop.,
inc., Winnsboro, S.C.
Bare Electric Coop.,
Millsboro, VA.
Habersham Electric
Membership Corp.,
Clarkesville , GA.
Western Illinois Elec.,
Coop., Carthage, 1L
Hickman-Fulton Counties
Electric Coop., Corp.,
Hickman, KY
United Power Association
Elk River, MN.
Blue Grass Recc
Nicholasville, KY.
Rural Elec., Convenience
Coop., Co., Auburn, IL.
Meriwether Lewis Elec.,
Coop., Centerville, TN
Washington btate Univ.
Pullman, Washington
American Institute of
Timber Construction
Englewood, Colorado
National Rural Elec.,
Coop . , Accoc . , Wa sh i ng ton ,
4/27/79
4/30/79
4/24/79
4/24/79
4/30/79
4/23/79
Undated
4/26/79
4/27/79
5/3/79
5/2/79
3/29/79
5/4/79
5/4/79
5/4/79
5/4/79
5/4/79
5/4/79
5/4/79
5/4/79
5/8/79
5/9/79
5/9/79
5/11/7
D.C.
-------
455
471
Joe Wheeier Elec.,
Membership Corp.,
Hartselle, Alabama
4/30/79
5/11/79
456
457
458
459
460
461
462
463
464
465
466
467
468
469
470
Oliver B. Wilbers
Umpqua , OR
Dairyland Power Coop.,
LA Croose , WI
Oliver-Mercer Elec.,
Coop., Inc., Hazen, ND
Petit Jean Elec.,
Clinton, Arkansas
Eastern Iowa Light
& Power Corp., Wilton,
Iowa
Cookson Hills Elec.,
Coop., Inc., Stigler, OK
Coos Curry Elec., Coop.,
Inc., Coquille, Oregon
Navopache Elec., Coop.,
Inc., Lakeside, Arizona
Betz Labs , Inc . ,
Trevose , PA.
Green River Elec., Corp.
Owensboro , KY
Northern Lights, Inc.,
Sandpoint, Idaho
Dow Chemical Co.,
Midland, MI
Concordia Elec., Coop.,
Inc., Ferriday, LA.
Alabama Power Co.,
birmingham, ALA.
U.S. Dept. of Agri.
4/7/79
5/10/79
5/9/79
5/7/79
5/9/79
4/26/79
_./9/79d
Undated
5/9/79
6/5/79
6/7/79
6/5/79
6/11/79
6/15/79
6/15/79
5/17/79
5/17/79
5/17/79
5/17/79
5/21/79
5/2/79
5/23/79
5/24/79
6/5/79
6/14/79
6/15/79
6/22/79
6/22/79
6/22/79
6/28/79
Forest Serv., Asheville,
N.C.
MS. Power Co.,
Gulfpost, MS.
6/20/79
6/28/79
-------
472
473
474
475
476
477
478
479
See 454 A
480
481
481A
482
483
484
485
Iowa Southern Util. Co.,
CentervilJLe, Iowa
DOD, OASD (Marienthal)
Washington, D.C.
Memphis Light, Gas
& Water Div . Memphis,
TN
Lincoln Elec., Coop.,
Inc., Eureka, Montana
Montana State Univ.
Bozeman, Montana
Gulf States Util, Co.
Beaumont, TX.
McKenzie Elec., Coop.,
Watford, N.D.
Cleveland Utilities
Cleveland TN.
National Rural Elec.,
Coop., Washington, D.C.
Ailing House Pest Control
Carmel, CA. Thru Univ, of
CA.
National Forest Products
Assoc .
Friends of the Earth
Washington, D.C.
International Woodworkers
of America, Portland Oregon
International Brotherhood
of Electrical Vvorkers
American Railroads
7/3/79
6/27/79
7/11/79
6/25/79
7/16/79
8/2/79
7/13/79
7/6/79
8/22/79
9/11/79
11/30/79
2/21/80
3/b/80
3/31/80
4/25/80
7/9/79
7/12/79
7/19/79
7/19/79
8/2/79
8/10/79
8/10/79
8/10/79
8/22/79
9/17/79
12/10/79
2/21/80
3/10/80
4/24/80
5/2/80
Washington, D.C.
-------
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-------
BIBLIOGRAPHY
-------
PART I. INTRODUCTION
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-------
Nestler, F.H.M. The Characterization of Mood Preserving -
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-------
PART 1I.B. CREOSOTE
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-------
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-------
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-------
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-------
PART II.C INORGANIC ARSENICALS
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Zingaro, R.A. Texas A & M University, Department of
Chemistry, Letter to R.D. Arsenault, January 26, 1979.
pBibAr
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PART II. D. PENTACHLORGPHLNOL
Akisada, 1. Simultaneous determination of penta and tetra-
chlorophenoi in air and wine. Japan Analyst, 14:101. 1965.
Altman, P.L., J.F. Gibson Jr., and C. Wang. Handbook of
Respiration. W.B. Saunders Co. Philadelphia and London,
41 pp. 1958.
American Industrial Hygiene Association. Pentachiorophtmol
and sodium pentachlorophenol. Arch. Toxicol., 32(4):271-
281. 1970.
American Wood Preservers Association. Wood preservation
statistics, 1977. Proc. American Wood Preservers
Association, 74 pp. 1978.
Armitage, P. Statistical Methods in Medical Research.
John Wiley and Sons.New York, N.Y.1973.
Arsenault, R.D. Pentachlorophenol and contained chlorinated
dibenzodioxins in the environment. A study of environmental
£ate, stability, and significance when used in wood
preservation. Proc. American Wood Preservers Association
25 pp. 1976.
Bevenue, A., J. Wilson, L.J. Casarett, and H.W. Klemmer. A
survey of pentachlorophenoi content in human urine.
Bull, of Environ. Contain, and Toxicol. °(6 ):319-332. 1967.
Bevenue, A., J.N. Ogata, and J.W. Hylin. Organochlorine
pesticides in rainwater, Oahuu, Hawaii, 1971-1972. Bull.
of Environ. Contain, and Toxicol. 8(4):238241. Copyright.
1972.
Bout-well, R.K., and D.K. Bosch. The tumor-promoting action
of phenol and related compounds for mouse skin. Cancer
Res., 19:413-424. 1959.
Cabral, J.R.P., P. Shubik, T. Mollner, and P. Raitano.
Carcinogenic activity of hexachlorobenzene in hamsters.
Nature, 269:510-511. 1977.
Cabral, J.R.P., T. Mollner, P. Raitano, and P. Shubik.
Carcinogenesis of hexachlorobenzene in mice. Int. J.
Can., 23:47-51. 1979.
Comer, S.W., D.C. Staiff, J.P. Armstrong, and H.R. Wolfe.
Exposure of workers to carbaryl. Bull. Environ. Contain.
Toxicol., 13(4):385-391. 1975.
Courtney, K. D., M.F. Copeland, and A. bobbins. The effects of
pentachloronitrobenzene, hexachlorobenzene; and related
compounds on fetal development. Toxicol. Appl.
Pharmacol., 35:239-256. 1976.
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Detrick, R.S. Pentachlorophenol: Possible sources of
human exposure. Forest Products Journal, 27(6):13-16. 1977.
Dougherty, R.C. Human-exposure to pentachlorophenol. In
K.R. Rao, (Ed.), Pentachlorophenol; Chemistry, Pharma
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351-361. 1978.
Dougherty, R.C., and K. Piotrowska. Screening bY negative
chemical ionization mass spectrometry for environmental
contamination with toxic residues: Application to human
urines. Proc. Natl. Acad. Sci., 73(6): 1777-1781. 1976.
Dunn, G.J. Multiple comparisons among means. J. Amer.
btatistical Assoc., 1961.
Engst, R., R.M. Macholz, and M. Kujawa. The metabolism of
hexachlorobenzene (HCB) in rats. Bull. Environ. Contain.
Toxicol., 16:248-252. 1976.
E.P.A. Notice of rebuttable presumption against registration
and continued registration of pesticide products containing
pentachlorophenol. Fed. Reg. 43(202):48443-48477. 1978.
Fahrig, R., C. -Nilsson, and C. Rappe. Genetic activity of
chlorophenols and chiorophenol impurities. In K.R. Rao
(Ed.) , Pentachloro-phenol; Pentachlorophenol Chemistry,
Pharmacology, and Environmental Toxicology, pp. 325-
338.Plenum Press,New York and London.19/8.
F.D.A. Compliance program evaluation FY 75, total diet studies-
adult (7320.08). 1979.
Freireich, E.J. et al. Quantitative comparions of toxicity
of anticancer agents in mouse, rat, hamster, dog, monkey,
and man. Cancer Chemotherapy Reports, 50(4):219-244.
1966.
Gebetugl, I., H. Parlar, and F. Korte. Contributions to
ecological chemistry. CXXVI. Short notice on the analytical
determination of pentachlorophenol in closed areas.
Chemospherfc, 5(4):227-230. 1976.
Goldstein, J.A. Structure-activity relationships for the
biochemical effects of halogenated hydrocarbons and the
relationship to toxicity. In R. Kimbrough (Ed.),
Halogenated Biphenyls, Terphenyls, Naphthalenes, Dibenzo-
dioxins and Related Compounds. Elsevier, Amsterdam, The
Netherlands.(In press.)1980.
Goldstein, J.A., M. Friesen, R.E. Linder, P. Hickman, J.R.
Hass, and H. Bergman. Effects of pentachlorophenol on
hepatic drug-metabolizing enzymes and porphyria related to
contamination with chlorinated dibenzo-p-dioxins and
dibenzofurans. Biochem, Pharmacol., 26:1549-1557. 1977.
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Grant, D.L., W.E.J. Phillips, and G.V. Hatina. Effect of
hexachlorobenzene on reproduction in the rat. Arch.
Environ. Contain. Toxicol., 5(2 ): 207-216. 1977.
Haque, A., 1. Scheuriert, and F. Korte. Contributions to
ecological chemistry. CXL. Isolation and identification ol
a metabolite of pentachiorophenol 14C in rice plants.
Chemosphere, 7(l):65-69. 1978.
HinKie, D.K. Fetotoxic effects ot PCP in the golden Syrian
hamster. Unpublished. 8 pp. Given at the 12th Annual
Meeting of the bociety of Toxicologists. 1973.
Hoben, H.J., S.A. Ching, and L.J. Casarctt. A study ot
inhalation ot pentachiorophenol by rats. Ill Inhalation
toxicity study. Bull. Environ. Contain. Toxicol., 15(4):463-
465. 1976.
Innes, J.R.M., B.M. Uland, M.G. Valerio, L. Petrucelli, L.
Fishbein, E.R. Hart, A.J. Pallota, R.R. Bates, H.L.
Falk, J.J. Gart, M. Klein, I. Mitchell, and J. Peters.
Bioassay ot pesticides and industrial chemicals for tumor
genicity in mice: a Preliminary Note. J. Nat. Cancer Inst,
42:1101-1114. 1969.
64.
Jeiger, 2. Exposure to guthion during spraying and
formulating. Arch, of Environ. Health, 8:565-569. 19
Johnson, R.L., P.J. Gehring, R.J. Kociba, and B.A. Schwetz.
Chlorinated dibenzodioxins and pentachiorophenol. Environ.
Health Perspect., 1973:171-175. 1973
Karapally, J.C., J.G. Saha, and Y.to. Lee. et ai. Metabolism of
lindane 14C in the rabbit: Ether-soluble urinary
metabolites. J. Agric. Food Chem. ,21(5):811-818. 1973.
Kehoe, R.A. , Vv. Deichmann-Gruebler and K.V. Kitzmiller.
Toxic effects upon rabbits of pentachiorophenol and
sodium pentachlorphenate. J. ind. Hyg. and Toxicol.,
21(5):160-172. 1939.
Khera, K.S. Teratogenicity and dominant lethal studies on
hexachlorobenzene in rats. Fd. Cosmet. Toxicol., 12:471-
477. 1974.
Kimbrough, R.D. and R.E. Linder. The effect ot technical
and purified pentachiorophenol on the rat liver. Toxicol.
Appl. Pharmacol., 46:151-162. 1978.
Knudsen, I., H.G. Verschuren, E.M. Den Tonkelar, R. Kroes, and
P.F.W. Hellman. bhort-term toxicity of pentachiorophenol
in rats. Toxicology, 2:141-152. 1974.
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Kociba, R.J., C.G. Humiston, R.W. Li so we, C.E. Vvade, and
B.A. Schwetz. Toxicologicai evaluation of rats maintained
on diets containing pentachlorophenoi sample XD-8108.00LG
for 90 days. Report, Dow Chemical USA. 1973.
Koss, G., S. Seubert, A. Seubert, W. Koransky, and H. Ippen.
Studies on the toxicology of hexachlorobenzene. III.
Observations in a long-term experiment. Arch. Toxicol.,
40:285-294. 1978.
Kozak, V.P., G.V. Simsiman, G. Chesters, D. Stensby, and J.
Harkin. Reviews of the environmental e'ffects of pollutants:
XI Chlorophenols. ORNL/EIS-128 EPA-60011-79-012 prepared tor
Health Effects Research Lab., Office of Res. and Dev., U.S.
Environ. Prot. Agency, Cincinnati, Ohio. 1979.
Kozak, V.P. Memo to Paul A. Cammer regarding metabolic
conversion efficiencies of hexachlorobenzene to
pentachlorophenoi. February 1, 1980. 1980.
Kutz, F.W., R.S. Murphy, and S. C. Strassman, Survey of
pesticide residues and their metabolites in urine from the
general population. In K. R. Rao. (Ed.), Pentachloro-
phenoi; Chemistry, Pharmacology, and Environmental Toxi
cology.Plenum Press, pp. 363-369N.Y.1978.
Lakings, D., W. Subra, and J. Going. Determination of
pentachlorophenoi and hexachlorobenzene residues. Midwest
Research Institute, Project No. 4901-A12. Contract No. 68-01-
5915 for the Environmental Protection Agency. 1980.
Larson, R.A., and A.L. Rockwell. Chloroform and chlorophenol
production by decarboxylation of natural/acids during
aqueous chlorination. Environ. Sci. and Tech., 13(3):325-
329. 1979.
Larson, R.V., G.S. Born, W.V. Kessler, S.M. Shaw, and D.C.
van Sickle. Placental transfer and teratology of
pentachlorophenoi in rats. Environ. Letters, 10(2): 121-
128. 1975.
Lu, Po-Yung, R.L. Metcalf, and L.K. Cole. The environmental
fate of 14C-pentachlorophenol in laboratory model
ecosystems. Enviro. Sci. Rev., 1978:53-65. 1978.
Maibach, H.I. and R.J. Feldman. Systemic absorption of
pesticides through the skin of man. In Milby (Ed.)
Occupational Exposure to Pesticides, pp. 120-127. 1974.
Martin, R.J. PCP in whole fresh milk. Reference Pesticide and
Metals in Foods, Compliance Program, 7305.004 (FY 79). 1979.
Mehendale, H., M. Fields, H.B. Matthews, et al. Metabolism and
effects of hexachlorobenzene on hepatic microsomal enzymes
in the rat. J. Agri. Food Chem., 23(2):261-265. 1975.
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Mengle, D.C. Letter with attachments to Paul A. Cammer,
Special Pesticide Review Division (TS-791), U.S. E.P.A.,
March 4, 1980. 1980.
Miller, R.J. Simultaneous Stastical Inference. John Wiley
and Sons. New York, N.Y.1966.
Morton, W.E., and V.H. Freed. Pentachlorophenol exposure
of workers in wood treatment plants. Summary Progress
Report 1969-1973, Oregon State University, Environmental
Health Sciences Center, pp.289-292. 1973.
National Cancer Institute and National Toxicology Program.
Bioassay of a mixture of 1,2,3,6,7,8 and 1,2,3,7,8,9-
hexachlorodibenzo-p-dioxins for possible carcinogenicity.
Department of Health and Human Services Publication,
(NIH 80-1754). 1980.
National Institute for Occupational Safety and Health. Health
Hazard Evaluation Determination. Report No. 74-117-251,
Weyerhaeuser Treating Plant, DeQueen, Arkansas. 1975.
National Institute tor Occupational Safety and Health. Health
hazard evaluation determination. Report No. 75-117-372.
1977.
Nicholas, D. D. Personal communication to Van Kozak, March
25, 1980. 1980.
Pesticide Incident Monitoring System. Summary for reported
incidents involving pentachlorophenate. Report #151,
Human Effects Monitoring Branch. Office of Pesticide
Programs. EPA. 1978.
Pierce, R.H., Jr. Fate and impact of pentachlorophenol j.n a
freshwater ecosystem. Grant #R-803-82-0010. Contract
#600/3-78-063 for the U.S. E.P.A. 1978.
Rapp, D.E. Industrial hygiene study: pentachlorophenol users
plants. Industrial Hygiene Laboratory, Health and
Environmental Research, Dow Chemical U.S.A., Midland,
Michigan 48640, 13 pp. 1978.
Schwetz, B.A., P.A. Keeier, and P.J. Gehring. The effect
of purified and commercial grade pentachlorophenol on rat
embryonal and fetal development. Toxicol. Appl.
Pharmacol., 28:151-161. 1974.
Schwetz, B.A., P.A. Keeier, and P.J. Gehring. 1974a. Lttect
of purified and commercial grade pentachlorophenol on r<*t
embryonal and fetal development. Tox. Appl. Pharm.,
28:146-150. 1974a.
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Schwetz, B.A., J.M. Morris, G.L. Sparschu, V.K. Rowe,
P.J. Gehring, J.L. Emerson, and C.G. Gerbig. Toxicology
of chlorinated dibenzo-p-dioxins. Environ Health
Petspect., 5:87-99. 1973.
Schwetz, B.A., J.F. Quast, P.A. keeler, C.G. Humiston, and
R.J. Kociba. Results oi two-year toxicity and reproduction
studies on pentachlorophenol in rats. In K.R. Rao (Ed.),
Pentachlorophenol, Chemistry, Pharmacology, and Environmental
Toxicology, Plenum Press, pp.301-309. 1978.
Simon, G.B., R.G. Cardiff, and J.F. Borzellaca. Failure
of hexachlorobenzene to induce dominant lethal mutations in
the rat. Toxicol. Appl. Pharmacol., 47:415-419. 1979.
Siuda, J.F., and J.F. DeBernardis. Naturally occurring
helognated compounds. Lloydia, 36(2):1U7-143. 1973.
Smith, J.G. and S.F. Lee. Model studies in aqueous
chlorination: the chlorination of phenols in dilute aqueous
solution. J. Environ. Sci. Health, A13(i):61-71. 1978.
Smith, J.G., S.F. Lee, and A. Netzer. Model studies in
aqueous chlorination: the chlorination of phenols in dilute
aqueous solutions. Water Research, 10:985-990. 1976.
Strassman-Sundy, S.C., FSB, OP11, EPA, Personal communication to
David Van Ormer, 1980.
Thompson, W.S., G.D. McGinnis, and L.L. Ingram Jr. The
volatiliz-ation of pentachlorophenol from treated wood.
MississippiState University, Forest Products Utilization
Laboratory, 5 pp. 1979.
USDA-States-EPA Preservative Chemical Assessment Team.
Biological and economic assessment of pentachlorophenol,
inorganic arsenicals, and creosote. Unpublished report.
1980.
Von Rumker, R., E.W. Lawless, A.F. Meiners with K.A.
Lawrence, G.L. Kelso and F. Moray. Production,
distribution, use and environmental impact potential of
selected pesticides. For the Environmental Protection
Agency, Office of Pesticide Programs; EPA 540/1-74-001. 1975.
Walters, C.S. and R.D. Arsenault. The concentration and
distribution of pentachlorophenol in pressure-treated
pine pole-stubs after exposure. Proc. American Wood
Preservers Association, 19 pp. 1971.
Whitney, R.W. and H.L. Gearhart. Airborne pentachlorophenol
concentrations within treated structures. Oklahoma State
University, Report Submitted to the Southern Regional
Pesticide Impact Assessment State Liason Coordinators,
17 pp. 1979.
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Wolfe, H.R., D.C. Staiff, J.F. Armstrong, and J.E. Davis.
Exposure of fertilizer mixing plant workers to disultoton.
Bull. Environ. Contain. Toxicol., 20:79-86. 1978.
Wyllie, J.A., J. Gaciba, W.W. Benson, and J. Yoder.
Exposure and contamination of the air and employees of a
pentachlorop'.anol plant, Idaho, 1972. Pesticides Monitoring
Journal, 9(3):150-153. 1975.
Yang, R.S.H., F. Coulston, and L. Golberg. Chromato-
graphic methods for the analysis of hexachlorobenzene and
possible metabolites in monkey fecal samples. J. of the
Asso. Off. Anal. Chem., 58(6j:1197-1201. 1975.
Zitko, V., O. Hutzinger, and P. M. K. Choi. Determination
of pentachlorophenoi and chloribiphenyls in biological
samples., Bull. Environ. Contam. Toxicol., 12(6):649-
654. 1974.
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PART II.E. ALTERNATIVES
Berczy, Z.S., L.M. Cobb, and C.P. Cherry. Acute Inhalation
Toxicity to the Rat of Copper Oxyquinoieate Dust.
(Unpublished study received Feb. 13, 1979 under 42567-1,
accession number 237442; prepared by Huntington Reasearch
Center, Cambridgeshire, England; submitted by La Quinoleine
SA; Paris, France). 1975.
Christensen, H.E., (ed.), E.J. Fairchild, (ed.), and R.J.
Lewis,(Sr. proj. coord.), Suspected Carcinogens, 2nd
Edition. A Subfile of the NIOSH Registry of Toxic Effects of
Chemical Substances. United States Department of Health,
Education and Welfare, Public Health Service, Center for
Disease Control, National Institute for Occupational
Safety and Health, Cincinnati, Ohio, pp. 198. 1976.
Elsea, J.R. and O.E. Paynter. lexicological Studies on
Bis(Tri-n-Butyltin) Oxide. A.M.A. Archives of Industrial
Heal tit, 18: 214-217. 1958.
Elsea, J.R. Guinea Pig Sensitization. Supplement to report
dated January 31, 1956. (Unpublished study received April 4,
1960 under 5204-Q, accession number 107273; prepared by
Hazleton Laboratories, Inc., sponsored by Metal and Thermit
Corp.). 1956.
Ezumi, K. and H. Nakao. Acute Oral Toxicity Study on Rats
of Copper 8-hydroxyquinoline. (Unpublished study received
Feb. 13, 1979 under 42567-1, accession number 237442;
prepared by Nihon Schering K. K.; submitted by La Quinoleine
SA; Paris, France). 1971.
Federal Register. Rebuttable Presumption Against
Registration and Continued Registration of Pesticide Products
Containing 2,4,5-Trichlorophenol and Its Salts. Vol. 43
No. 149. August 2, 1978.
Food and Drug Research Laboratories. Acute Inhalation Toxicity
[Summary] (Unpublished summary received Dec. 30, 1976 under
5204-1, accession number 227311; submitted by M & T Chemicals
Inc.; Rahway, New Jersey).
Hathaway, D. Acute Aerosol Inhalation Toxicity Study with
Copper Naphthenate, 8.0% Copper in Rats. (Unpublished
study received June 8, 1971 under 8898-1, accession number
102427; prepared by Industrial Bio-Test Laboratories, Inc.;
sponsored by Witco Chemical Corp.; Chicago, Illinois). 1971.
Hine Laboratories. Primary Eye Irritation [Summary]
(Unpublished study received Dec. 30, 1976 under 5204-1,
accession number 227311; submitted by M & T Chemicals Inc.;
Rahway, New Jersey). 1976.
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International Research and Development Corp. Acute and
Subacute Dermal Toxicity Studies in the Albino Rabbit.
(Unpublished study received Dec. 30, 1976 under 5204-1,
accession number 227311; submitted by M & T Chemicals Inc.;
Rahway, New Jersey). 1966.
Levinson, T. Inhalation Toxicity Study. (Unpublished study
received May 7, 1971 under 1719-2, accession number 102426;
prepared by Food and Drug Research Laboratories, Inc.;
sponsored by Mobil Paint Manufacturing Co., Inc.; Mobil,
Alabama). 1971.
Mo1dovan, M.T. Rabbit Eye Irritation Study. (Unpublished
study received June 13, 1969 under 1100-7, accession number
050280; prepared by Food and Drug Reasearch Laboratories,
Inc.; sponsored by Tenneco Chemicals, Inc.) 1969.
Moldovan, M. Acute Oral Toxicity Study. (Unpublished study
received April 23, 1971 under 1719-7, accession number
102912; prepared by Food and Drug Reasearch Laboratories,
Inc.; sponsored by Mobil Paint Manufacturing Co., Inc.;
Mobil, Alabama). 1971a.
Moldovan, M. Primary Skin Irritation Study. (Unpublished
study received April 23, 1971 under 1719-7, accession number
102912; prepared by Food and Drug Reasearch Laboratories,
Inc.; sponsored by Mobil Paint Manufacturing Co., Inc.;
Mobil, Alabama). 1971b.
Moldovan, M. Rabbit Eye Irritation Study. (Unpublished
study received April 23» 1971 under 1719-7, accession number
102912; prepared by Food and Drug Reasearch Laboratories,
Inc.; sponsored by Mobil Paint Manufacturing Co., Inc.;
Mobil, Alabama). 1971c.
Mouser. Final Report - Acute Dermal Toxicity - Rabbits.
(Unpublished report received Feb. 13, 1979 under 42567-1,
accession number 237442; prepared by Hazelton Laboratories,
Inc.; sponsored by Kanesho Chemical Co., Ltd.; submitted by
La Quinoleine SA, Paris, France). 1973a.
Mouser. Final Report - Eye Irritation Study - Rabbits.
(Unpublished report received Feb. 13, 1979 under 42567-1,
accession number 237442; prepared by Hazelton Laboratories,
Inc.; sponsored by Kanesho Chemical Co., Ltd.; submitted by
La Quinoleine SA; Paris, France). 1973b.
National Cancer Institute Press Release. Dioxin Compound Found
to Cause Cancer in Animal Tests. HHS News. December 9, 1980.
Rockhold, W.T. Toxicity of Naphthenic Acids and Their
Metal Salts. A.M.A. Archives of Industrial Health,
PP. 477-482.
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PART III. BENEFIT ANALYSIS
American Plywood Association. Regional Production and Distri-
bution Patterns of the Softwood Plywood Industry. E27.
July, 1979.
Andrews, T.H. Personal Communication. Thomas H. Andrews Inc.
Alexandria, Va. Jan., 1980.
Arsenault, R. Personal Communication. Koppers Company, Inc.,
Pittsburg, Pa. March, 1980.
Cheo, Y.C. Personal Communication. Duraflake, Division of
Willamette Industries, Inc., Albany, Oreg. Dec., 1980.
Coleman, J. Personal Communication. American Crossarros,
Jacksonville, Fla. Dec., 1979.
Compton, C. Personal Communication. Atlantic Wood Industries,
Savannah, Ga, Nov., 1979.
Cravens, D. Personal Communication. Osmose Wood Preserving
Company of America, Buffalo, N.Y. April, 1979.
Cummings, W. Personal Communication. Plant Sciences Branch,
Office of Pesticide Programs, U.S. Environmental Protection
Agency. March, 1980.
Dun and Bradstreet. Contract with U.S. EPA, OPP Contract #68-01-
4953. (Data summaries are not privileged information). 1979.
Edison Electric Institute. Environmental and Economic Benefits
of Continued Use of Wood Preservatives in Electrical Utility
Industry. In Response to Rebuttal of RPAR on Coal-Tar
Creosote, Neutral Oils, Pentachlorophenol, and Inorganic
Arsenical Wood Preservatives by the Environ. Prot. Agency.,
N.Y., N.Y. 1979.
Electric World. 14th Annual T&D Construction Survey.
Aug. 15. Vol. 191(15). 1979.
Energy Information Administration. Coke and Coal Chemicals in
1978. DOE/EIA-0120 (78), Dept. of Energy, Washington, D.C.
1979.
Engineering News Record. Materials Prices. 203: (8). 1979.
Environmental Protection Agency. Preliminary Benefit
Analysis of Wood Preservatives. Washington, D.C.
(Unpublished). 1980.
Farmer, J.D. Jr. Personal Communication. Virginia Electric
and Power Company, Richmond, Va. Oct., 1979.
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Fuller, B., Holberger, R., Carstea, D., Cross, J., Berman, R.,
and Walker, P. The Analysis of Existing Wood Preserving
Techniques and Possible Alternatives. Mitre Technical Report
7520. Metrek Division/The Mitre Corporation, McLean, Va.
1977.
Georgia CES. Wood Preservation and Wood Products Treatment.
Cooperative Extension Service, University of Georgia, Athens,
Georgia. June, 1977.
Gilbert, G. Personal Communication. Diamond Shamrock Corp.,
Cleveland, Ohio. Dec., 1979.
Johnson, R.L. Personal Communication. Dow Chemical USA,
Midland, Mich. Jan., 1980.
Josephson, H.R. Economic, Social, and Conservation Benefits
from Use of Wood Preservatives. Unpublished Report to the
American Wood Preservers Institute. Representative to AWPI,
McLean, Va. Dec., 1979.
Maloney and Pagliai. Wood Preservation Statistics. Proc.
Amer. Wood Pres. Assoc., 74: 285-303. 1978.
McGill, T. Personal Communication. Osmose Wood Preserving
Company of America, Inc., Buffalo, N.Y. Oct., 1979.
McVey, D. Personal Communication. Duraflake, Division of
Willamette Industries, Albany, Oreg. Jan., 1980.
The Mitre Corporation. Interim Brief ing-Impact Analysis for
Cancellation of ACA/CCA Preservatives for Treated Wood Used
in Homes. EPA Contract 68-01-5965 Task |7. (Unpublished).
1980.
Nagel, F.J. Personal Communication. Chapman Chemical Co.,
Memphis, Tenn. Oct., 1979.
Nagel, F.J. Personal Communication. Chapman Chemical Co.,
Memphis, Tenn. 1980.
National Association of Home Builders Foundation, Inc. An
Industrial Engineering Study Comparing Cost of Concrete Block
and Treated Wood Foundations. Rockville, Md. 1969.
National Forest Products Association. Discussion and Analysis
of Benefits and Risk Associated with Pentachlorophenol Used
as a Wood Preservative in the Won-Pressure Treatment.
National Forest Products Association Response to Rebuttable
Presumption Against Registration of Pentachlorophenol (OPP
30000/30). 1979.
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National Forest Products Association. An Examination of
Alternative Wood Preservatives for Non-Pressure Treatment.
National Forest Products Association Supplemental Response to
Rebuttable Presumption against Registration of
Pentachlorophenol. 1980.
National Particleboard Assoc. Particleboard and Medium Density
Fiberboard Annual Production and Shipments for 1978. Silver
Spring, Md. Oct., 1979.
National Ready Mixed Concrete Association. Wood Basements Cost
Less? Don't You Believe Itl National Ready Mixed Concrete
Association Memo Number 33. Silver Spring, Md. 1976.
Nicholas, D.D. (ed.). Wood Deterioration and its Prevention by
Preservative Treatments. Vol. I and II. Syracuse Univ.
Press. Syracuse, N.Y. 1973.
O'Brien, W.P. Personal Communication. Osmose Wood Preserving
Company of America, Inc., Buffalo, N.Y. Nov., 1979.
Palmer, J. Personal Communication. Irvington-Moore Dry Kiln
Co., Jacksonville, Fla. Feb., 1980.
Rural Electric Administration. Statement of Rural Electrifi-
cation Administration, USDA, on the Rebuttal Presumption
Against Registration of Wood Preservative Pesticides. Wash.,
D.C. 25p. Dec., 1979.
Smith, K. Personal Communication. Smith Brothers, Inc.,
Galesville, Md. Jan., 1980.
Smith, W.G. Personal Communication. Raymond International
Builders, Westville, N.J. Jan., 1980.
Stevens, G. Personal Communication. Longdale Company, Inc.,
Valdosta, Ga. Dec., 1979.
Toth, R.S. Personal Communication. Pennwalt Corporation,
Fresno, Calif. Dec., 1979.
USDA-States-EPA. Biological and Economic Assessment of Penta-
chlorophenol, Inorganic Arsenicals, and Creosote. Final
Draft Report of the USDA/States/EPA Preservative Chemical
Assessment Team. 1980.
U.S. Dept. of Commerce, Bureau of the Census. 1972 Standard
Industrial Classification Manual. SIC 2491. 1972.
U.S. Dept. of Commerce. Wooden Containers and Miscellaneous
Wood Products. 1972 Census of Manufactures Industry Series,
Preliminary Report. MC 72(2)-24c. Washington, D.C. 31p.
1975.
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U.S. Dept. of Commerce. Wood Preserving. 1977 Census of
Manufactures, Industry Series, Pre-liininary Report. MC 77-1-
24c-4 (P).Washington, D.C.8pl1979.
U.S. Dept. of Commerce. Sawmills and Planning Mills, General.
The 1977 Census of Manufactures, Preliminary Report. SIC
2421.August, 1979a
U.S. Dept. of Commerce. Logging Camps and Logging Contractors.
The 1977 Census of Manufactures, Preliminary Report. SIC
2411.Sept., 1979b.
U.S. Dept. of Commerce. Millwork. The 1977 Census of
Manufactures/ Preliminary Report.SIC 2431.May, 1979c.
Wilhoite, G.M. Personal Communication. Tennessee Valley
Authority, Chattc.ooga, Tenn. Nov., 1979.
Winebrenner, L.J. Personal Communication. Roberts
Consolidated, Kalamazoo, Mich. Jan., 1980.
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PART IV. DEVELOPMENT OF REGULATORY OPTIONS " ""•*? rvip
Kozak, V.P. Degree of-Personal Protection Afforded by Specific
Types of Protective Clothing. Memo to SPRD Project Managers,
Wood Preservative Team. July, 1980.
The Mitre Corporation. Preliminary Impact Analysis of Measures
to Mitigate Worker Exposure to Wood Preservatives. U.S.
Environmental Protection Agency, Contract No.: 68-01-5965.
McLean, Va. 1980.
The Mitre Corporation. Feasibility and Costs of Compliance with
Arsenic Residues Standards for Preserved Wood. U.S.
Environmental Protection Agency, Contract No.: 68-01-5965.
McLean, Va. 1980a.
Whiting, B. Letter from Basil Whiting, Deputy Assistant
Secretary, OSHA, to Paul Halpern, OPM, EPA. Nov. 8, 1979.
Part V. REVIEW OF THE IMPACTS OF REGULATORY OPTIONS AND
MODIFICATIONS
Environmental Protection Agency. Supplement to Analysis of
Wood Preservatives Regulatory Options. Economic Analysis
Branch, Benefits and Field Studies Division, Office of
Pesticide Programs. EPA, Washington, D.C. (Unpublished).
1980.
Kozak, V.P. Degree of Personal Protection Afforded by Specific
Types of Protective Clothing. Memo to SPRD Project Managers,
Wood Preservative Team. July, 1980.
The Mitre Corporation. Preliminary Impact Analysis of Measures
to Mitigate Worker Exposure to Wood Preservatives. U.S.
Environmental Protection Agency, Contract No.: 68-01-5965.
McLean, Va. 1980.
The Mitre Corporation. Feasibility and Costs of Compliance with
Arsenic Residues Standards for Preserved Wood. U.S.
Environmental Protection Agency, Contract No.: 68-01-5965.
McLean, Va. 1980a.
*U S GOVERNMENT PRINTING OFFICE: 1981 341-085/4643
U.S. invironmentai Proiection Agency
Region 5, Library (PL-12J)
77 West Jackson Boulevard, 12th Ftaw
Chicago, !l 60604-3590
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