Great Lakes Binational Toxics Strategy

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Dioxin / Furans

Stakeholders Minutes - July 24, 2002
Draft Workgroup Conference Call Minutes

Workgroup Leaders:
Anita Wong, EC
Erin White, EPA

Introductory Remarks and Announcements

John Menkedick (Battelle) started the meeting off with a brief over-view of dioxin/furan workgroup involvement with the issue of PCP treated wood over the past couple of years. The focus has been on utility poles, since they are currently the most significant use of PCP. John also noted that this meeting was being conducted jointly with the leads of the B(a)P/HCB workgroup due to common concerns over treated-wood issues.

During 2000, workgroup members and sector experts developed and implemented a decision tree process to assess major dioxin/furan source sectors and assigned them a GLBTS priority level for workgroup focus. In Canada, the PCP-treated wood issue was classified as low priority for the BTS dioxin workgroup because it was being addressed under the Treated-Wood Strategic Options Process (SOP). In the United States, on the other hand, the issue was originally considered medium priority because of the need for additional information gathering on the ultimate fate of PCP-treated wood. In response to this informational need, the Utility Solid Waste Activities Group (USWAG) conducted a survey to gather information regarding secondary uses and disposal of PCP-treated utility poles. The results of the survey enabled the workgroup to move disposal of PCP-treated wood poles from a “medium” to a “low” dioxin workgroup priority for information gathering. The issue still remains, however, whether current pole management practices (particularly regarding secondary use and ultimate disposal) in the U.S. are sufficient.

John Menkedick introduced the draft agenda for the meeting and asked for any comments or additions. He explained that the focus of this meeting would be to discuss the draft list of issues related to the management of PCP-treated wood (used utility poles) in the Great Lakes region, which was prepared for the GLBTS Dioxin / Furan Workgroup in January 2002. All of the participants in the meeting had received a copy of these issues / questions and Environment Canada’s draft responses prior to the meeting.

Erin White (U.S. EPA) gave a brief overview of the May 2002 meeting in Windsor, where she and Anita passed out the thank you letter presented from EC and the EPA to USWAG for their efforts in gathering information on secondary uses and disposal of treated wood poles, development of a resource document on utility pole disposal practices, and drafting voluntary disposal guidelines for the electric utility industry. For this call, Erin expressed an interest in further discussion on the topic of getting risk information regarding utility poles to secondary consumers, especially with regards to the Material Safety Data Sheets (MSDS).

Anita Wong (EC) agreed that she would also like to move forward and discuss next steps on the issue of distributing information to secondary users. She explained that in Canada, they have a National Strategy (which has been under development for many years now), addressing information distribution and proper disposal practices for treated wood products and they would be interested in assisting with pilot projects in the Great Lakes Region, which would support their national efforts regarding treated wood. In answering workgroup questions about the Canadian SOP and national treated wood strategy, she informed the workgroup that the goal of the SOP was to address all uses and types of treated wood. A clear time line has not yet been established for the completion of the strategy.

Discussion on the Communication of Risk Information to Secondary Users of PCP Treated Wood Poles

Jim Roewer (USWAG) clarified that when utilities release poles into circulation for secondary use, they do not necessarily distribute MSDS, which is what the draft list of issues prepared for the workgroup implied. Rather, they’ve found that utilities distribute information tailored specifically to address handling, use, and disposal of the wood poles (information that is not necessarily covered in MSDS). Jim noted that USWAG encourages utilities to distribute Consumer Information Sheets (CIS) or Consumer Safety Information Sheets (CSIS) to convey risk information to secondary users.

Jim explained that the information included in CIS/CSIS is much more detailed than MSDS regarding the use and disposal of treated wood products (similar to the type of information that would be distributed by a lumber store). MSDS are typically more industry oriented. He agreed with the EC answers on the draft list of issues that MSDS are not appropriate for communicating risk to the public / secondary consumers.

In response to questions from the workgroup about CIS/CSIS, Jim explained that USWAG found that some utilities are using the CIS/CSIS and then augmenting them with additional information to address specific issues that the public should be aware of before working with treated wood (for example: wear gloves when handling, do not burn, and make sure ultimate disposal is appropriate). In addition to this sort of information, some utilities are including avoidance warnings (for example: avoid contact with livestock). USWAG’s guidance document for voluntary utility action to reduce the risk of secondary use (currently under development) will address much of this augmented information.

Jim also explained that the CIS do not specifically look at dioxins/furans, but rather attempt to look at all treated wood products together. Dwain Winters (U.S. EPA) brought up the point that including details on what people should be concerned about when using a specific treated wood product might be a more effective way to communicate risk (for example: include arsenic hazards when educating people about CCA and talk about dioxins as a carcinogen when educating people about PCP). Thus, there remains some concern that a single approach for all treated wood products would not mention the micro- contaminants, and therefore may not be as effective at educating the consumer as to why treated wood products may require special handling and disposal. Dwain suggested that this point be flagged for further discussion when the EPA reviews the revised guidance document from USWAG.

During further discussion on the CIS/CSIS and their effectiveness, Jim explained that although the forms are distributed on a voluntary basis, USWAG has found that CIS/CSIS (or similar information sheets) are commonly used among member utilities surveyed. Part of the purpose of the USWAG guidance document (currently under development) is simply to increase industry’s awareness of the health risks associated with secondary use of treated wood poles. Increasing awareness makes the utilities realize that it is their responsibility to distribute risk information to their consumers, and that it is in their own best interest to follow USWAG’s suggested guidelines.

Jim noted that USWAG has shared their draft guidance document with other industries, including the railroad industry and telecommunication companies. The reaction from other industries was positive in general, although the rail roads are already doing a lot (applied only to CCA, though, not applied to PCP) and telecommunication companies are only starting to get organized on these types of issues. USWAG believes that the increased distribution of the guidance document has already helped to raise awareness about health risks within those industries too. Increased distribution of information such as the USWAG guidance document and CIS/CSIS has the potential to be very helpful in increasing public awareness on the hazards related to treated wood (just like the California legislation on CCA in playground equipment was helpful in raising public awareness about CCA hazards).

Workgroup discussion continued regarding how widely the suggested guidelines might be followed by industry, in practice, and how well secondary users might understand and follow the risk information and use/disposal recommendations given to them (especially in high-concern circumstances like feed lots and playgrounds).

Anita asked if the workgroup had any information regarding the degree to which toxins leach out of used PCP treated utility poles. Dwain replied that there has been limited work done by the EPA on that topic. He explained that they found newer poles leached some dioxins/furans, but that many different factors affected the amount. He also added that, in general, older poles had a greater potential to leach dioxins/furans because the PCP used 20 years ago generally contained higher levels of dioxin/furan micro contaminants than the PCP today. Thus, Dwain explained that the primary concern was really with potential broad environmental release from the disposal of poles and prolonged direct contact with animals and children (for example, livestock may be exposed by licking / chewing / rubbing against PCP lumber in fences).

There was general agreement among the workgroup members that MSDS are not appropriate for getting risk information on treated utility poles to secondary users. MSDS were created for a completely different purpose (i.e. industrial guidance), and CIS/CSIS are currently being used in practice by utilities to convey risk information to their customers. CIS/CSIS are intended to put MSDS information into a more consumer-friendly context, as well as provide additional guidance on use and disposal. Although CIS/CSIS are older (1987), they have historically been distributed and recently adapted to convey even more information.

Discussion on Next Steps for the Dioxin Workgroup

There was discussion about whether the original draft list of issues could be revived and made more pertinent by just replacing “MSDS” with “CIS/CSIS”. Other possible questions for the issue list raised by the workgroup included:

Are the CIS/CSIS enough?
Are the CIS/CSIS actually getting distributed in practice and are secondary users gaining valuable information from them?
Is the CIS/CSIS information staying with the product throughout the rest of its life cycle (even if the product transfers ownership many times)?
What is happening in terms of the ultimate disposal of these products?

Erin brought up the point that determination of CIS/CSIS effectiveness (i.e. are they actually getting distributed and providing valuable information) may be hard to evaluate and measure objectively.

Options discussed by the workgroup for gathering information related to this issue included:

Designing a specific study to survey how secondary consumers are using the old utility poles.
Using the results of a similar study that has already been conducted (e.g. effectiveness of an analogous product safety outreach campaign) to at least provide a higher level of confidence in the CIS.
Working backwards by looking at secondary uses, determining if there is a high occurrence for secondary uses of concern, and then looking at why the CIS might not have been effective in those circumstances.

Dwain brought up the point that simply surveying secondary uses would still not be helpful in gathering information on the major issue of final disposal, though.

A comment was made that although the workgroup may not be able to accurately measure the effectiveness of information sheets like CIS/CSIS, they could still work to enhance CIS/CSIS effectiveness and encourage their use.

Workgroup suggestions for possible actions to help reduce health risks related to the secondary use of PCP treated wood poles included:

An ongoing public education campaign (e.g. similar to spent motor oil education efforts). It was noted that establishing the infrastructure to support actions advocated in this type of public education effort (e.g appropriate means of disposal) would also be extremely important. Jim stated that USWAG was interested in working with the EPA on a consumer education program to address PCP treated utility poles, and viewed this type of effort extremely important from a public policy perspective.
Education for municipalities on local level PCP issues (e.g. final disposal alternatives). It was added that cogeneration / energy recovery is considered a valid and economical alterative for PCP pole disposal. It was again emphasized that setting up an alternative waste management infrastructure for local municipalities is key (as demonstrated in the Burn Barrel Campaign). Opportunities for outreach to the public at the state, local, and private levels were discussed (for example, electric utilities could distribute educational materials along with their direct mailings to customers).
Encouraging voluntary programs set-up by industry (for example: recycling programs).

Discussion continued regarding the relationships between increased public awareness on the risks of secondary use of treated wood, reductions in secondary use, and as a result, potentially increased need for wood disposal. It was noted that there is more control over what happens to the wood if it is disposed of or recycled than when it is sold in a secondary market.

It was noted that there is a clear need to focus on both:

Controlling what happens to wood that is coming out of service currently.
Controlling the wood that is already out of service and presently in a secondary use (especially since older poles are more likely to have a higher dioxin/furan content).

Clear communication with the public on proper use and disposal is vital for addressing both of these issues.

The workgroup agreed they should look at opportunities for increasing education within the Great Lakes region on the health risks associated with PCP treated wood and proper use and disposal. It was noted that first they must answer the questions of how, where, and who? It was suggested that the workgroup possibly look at the Burn Barrel subgroup efforts as a model, or explore options such as having utilities distribute information to the public or having lumber stores distribute education materials to consumers, since they are the ones who actually sell the wood.

It was noted that education on health risks is an issue for all treated-wood products, not just used PCP treated utility poles, and that the SOP in Canada handles all treated wood together.

Action Item List

Dwain will check on any EPA risk education or outreach activities going on currently for treated wood.
Dale will check on any private / industry education efforts on treated wood and gather any available information.
Anita will check on consumer education information sheets and pilot outreach efforts in Canada to possibly use as models.
Jim Roewer will distribute the revised USWAG guidelines on treated wood as soon as they are ready.
The whole workgroup should submit ideas for next steps.
The workgroup leaders (with Battelle) will prepare the minutes of the meeting, a revised list of key issues, and a draft set of options for next steps for distribution to the workgroup.

Next Meetings

Integration Group Meeting - September 18, 2002 - Chicago
Stakeholder Meeting - December 3-4, 2002 - Chicago
Dioxin / Furan Workgroup conference call tentatively in September or October based on the information gathered in the next few months.

Participant Roster

Keith Christman, Chlorine Chemistry Council
Nicole DiMonte, Battelle
John Estenik, Ohio EPA
Herb Estreicher, Covington & Burling
Douglas Fairchild, Western Lake Superior Sanitary District
Douglas Green, Piper, Marbury, Rodnick and Wolfe LLP
John Menkedick, Battelle
Shawn Michajluk, Environment Canada
Dale Phenicie, Council of Great Lakes Industry
Jim Roewer, Utility Solid Waste Activities Group
Steve Rosenthal, US EPA
Ted Smith, US EPA
Erin White, US EPA
Dwain Winters, US EPA
Anita Wong, Environment Canada
Maureen Wooton, Battelle