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From: Fred Friedman (FRIEDMAN.FRED@EPA.GOV)
Date: Thu Apr 08 1999 - 12:25:51 EDT


Date: Thu, 8 Apr 1999 12:25:51 -0400 (EDT)
From: FRIEDMAN.FRED@EPA.GOV (Fred Friedman)
Subject: Re:  Re: Recycling treated wood (Phil Bradshaw)

April 8, 1999

Dear Phil Bradshaw,

I think that we share many of the same concerns here. I too, when I first learned that it was suddenly all right to recycle chemically preserved wood, had your reaction: but, but, but, what about its potential involvement with:
- food
- children
- sustained interior exposures
- uses in other countries with less tyrannical environmental regulatory environments
- worker health and safety in processing

I was somewhat mollified by the following:

 Current environmental regulations restrict the use of wood preserved with penta and creosote from use in residential, industrial, and commercial interiors, except as laminated beams or building components that are in ground contact and subject to decay or insect infestation and where there are two coats of an approriate sealer applied. In addition, penta-treated wood should not be used where it will be in contact with the skin unless an effective coating has been applied to the wood. Wood that is treated with inorganic arsenicals can be used in building interiors, but not where it can be in contact with food. Thus, options for recycling preservative-treated wood are highly dependent on the type of treatment and use they will receive.

But how are the standards to be enforced?

Well, the Food Drug Administration enforces reported problems of materials such as this coming into contact with food.
The Occupational Health Safety Administration has standards concerning how any pressure treated wood, manufactured or recycled may be handled.
US Dept. of HUD has standards for use in construction and interior spaces.
And concerning export, manifests must show what the materials being exported are, including any environmental problems.

I think that the answer is, recycling is the best treatment option if you are going to have to manage preserved wood when it becomes waste, unless you can come up with an alternative to its manufacture in the first place.

Let me refer you to the document that I think covers available alternatives best:

 Spent Pressure Treated Wood: An Analysis of Management Options by Carter Fahy, Michael Gitten, Dept. of Civil Environmental Enginnering, Tufts Universtiy, published by NEWMOA, (circa 1993).

I confess, that this answer is not the one I'd prefer to give myself or yourself. However, since most environmental rules at the present point to the stuff being 'not hazardous wwaste', it needs to be managed as solid waste, and recycling it is still the best alternative.

- Research Library for RCRA



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