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June 16, 2004
(February 1, 2002)
Supplemental Guidance on Interpretation
of Revised Chromated Copper Arsenate (CCA) Wood Preservative
Label
Introduction
Exporting/Importing of CCA-Treated Wood
Current Label
New Label Language for C-30 (Cooling Towers)
Revised Label Language for C-18 (Marine)
Revised Language for End-Use Products
Revised Language for Manufacturing-Use Products
Examples of Continued CCA Uses
Introduction
The registrations and EPA-approved labels
for CCA wood preservatives were voluntarily amended by each
registrant to state that, effective December 31, 2003, CCA
may be lawfully used only to treat wood or forest products
for uses that fall under the 2001 Edition of the American
Wood Preservers’ Association (AWPA) standards listed on the
new label. Subsequently, in December of 2003 and February
of 2004, the registrants requested that their registrations
and EPA-approved labels be amended to include standard C30
(Lumber, Timbers and Plywood for Cooling Towers-Preservative
Treatment by Pressure Processes) of the 2002 Edition of the
AWPA standards. These amendments were approved by the Agency
and the resulting label language is described below.
To address confusion in the marketplace resulting
from the first round of label changes, the registrants agreed
to limit wood treated for marine construction (C18 standard)
to brackish or saltwater use (immersion), and members out
of water but subject to saltwater (or brackish water) splash.
To accomplish this, the registrants have requested voluntary
deletion of the use under C18 which refers to “members out
of water and not subject to salt water splash and not in soil
use,” along with the necessary label changes, effective December
31, 2004. The Agency will publish a 6(f) notice under FIFRA
and then take appropriate steps to finalize the changes. In
the interim, the registrants have agreed to label new product
with the revised label language (for both end-use products
and manufacturing-use products) to clarify allowable uses.
This guidance is designed to help explain
the revised labeling to wood treaters, building code inspectors,
and others responsible for working with CCA and CCA-treated
wood. It is of utmost importance that the wood or forest products
1) be treated according to the AWPA standards listed on the
new label, and 2) that these treated wood or forest products
be used according to the AWPA standard listed on the new label.
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Exporting/Importing
of CCA-Treated Wood
With respect to the exporting of CCA-treated
wood, the following text from the Federal Register of April
9, 2003 (68 FR 17370) needs to be consulted: “...wood treatment
facilities are only allowed to treat wood products with CCA
that are intended to be used only for those remaining uses
approved on the CCA product label. Wood intended for use in
prohibited residential settings may not be treated with CCA
after December 30, 2003, unless the product being used is
a pre-existing product and such use is permitted by that product
label. (See Unit V: ``Provisions for Disposition of Existing
Stocks'') Because of the method of product manufacture and
distribution used in the wood preservation industry, the Agency
does not expect any more than de minimus stocks to exist as
of December 31, 2003, that do not bear the more restrictive
label language. Hence, beginning December 31, 2003, unless
the label on the affected product provides otherwise, it would
be illegal to treat wood with CCA for any prohibited residential
use, regardless of whether the treated wood is to be used
in the United States or exported for use in other countries.”
With respect to the importing of CCA-treated
wood, CCA-treated wood for which pesticidal claims are being
made must be registered as a pesticide if it does not qualify
for the treated article exemption. In order to qualify for
the treated article exemption, the treated wood must be treated
with a pesticide product registered in the United States for
the treatment of wood for the specific intended use in question.
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Current Label
Following is the new label amendment language,
as cited in the Federal Register: April 9, 2003 (68 FR 17371-72).
Additional language was specified and is shown below in the
respective sections to accomplish the label change for standard
C30 (Lumber, Timbers and Plywood for Cooling Towers-Preservative
Treatment by Pressure Processes), which was included in the
2002 Edition of the American Wood Preservers’ Association
(AWPA) standards, and the pending change for C18 (Wood for
Marine Construction). The additional language is described
below.
The following manufacturing product registrations
were amended to delete certain terminated uses as of May 16,
2003:
3008-66 Arsenic Acid 75%
10465-32 CSI Arsenic Acid 75%
62190-7 Arsenic Acid 75%
For the above identified manufacturing-use
products, the accepted amended labeling reads as follows:
Effective December 31, 2003, this product
may only be used (1) for formulation of the following end-use
wood preservative products: ammoniacal copper zinc arsenate
(ACZA) or chromated copper arsenate (CCA) labeled in accordance
with the Directions for Use shown below, or (2) by persons
other than the registrant, in combination with one or more
other products to make: ACZA wood preservative; or CCA wood
preservative that is used in accordance with the Directions
for Use shown below. Effective December 31, 2003, this product
may only be used for preservative treatment of the following
categories of forest products and in accordance with the respective
cited standard (noted parenthetically) of the 2001 edition
of the American Wood-Preservers Association Standards: Lumber
and Timber for Salt Water Use Only (C2), Piles (C3), Poles
(C4), Plywood (C9), Wood for Highway Construction (C14), Round,
Half Round and Quarter Round Fence Posts (C16), Poles, Piles
and Posts Used as Structural Members on Farms, and Plywood
Used on Farms (C16), Wood for Marine Construction (C18), Lumber
and Plywood for Permanent Wood Foundations (C22), Round Poles
and Posts Used in Building Construction (C23), Sawn Timber
Used To Support Residential and Commercial Structures (C24),
Sawn Crossarms (C25), Structural Glued Laminated Members and
Laminations Before Gluing (C28), Structural Composite Lumber
(C33), and Shakes and Shingles (C34). Forest products treated
with this product may only be sold or distributed for uses
within the AWPA Commodity Standards under which the treatment
occurred.
The following end use product registrations
were amended to delete certain terminated uses as of May 16,
2003:
3008-17 K-33-C (72%) Wood Preservative
3008-21 Special K-33 Preservative
3008-34 K-33 (60%) Wood Preservative
3008-35 K-33 (40%) Type-B Wood Preservative
3008-36 K-33-C (50%) Wood Preservative
3008-42 K-33-A (50%) Wood Preservative
3008-72 Osmose Arsenic Acid 75%
10465-26 CCA Type-C Wood Preservative 50%
10465-28 CCA Type-C Wood Preservative 60%
10465-32 CSI Arsenic Acid 75%
35896-2 Wood-Last Conc. Wood Preservation AQ 50%
Solution CCA-Type A
62190-2 Wolmanac Concentrate 50%
62190-8 Wolmanac Concentrate 72%
62190-14 Wolmanac Concentrate 60%
For the above identified end-use products,
the accepted amended label is to read as follows:
Effective December 31, 2003, this product
may only be used for preservative treatment of the following
categories of forest products and in accordance with the respective
cited standard (noted parenthetically) of the 2001 edition
of the American Wood-Preservers Association Standards: Lumber
and Timber for Salt Water Use Only (C2), Piles (C3), Poles
(C4), Plywood (C9), Wood for Highway Construction (C14), Round,
Half Round and Quarter Round Fence Posts (C16), Poles, Piles
and Posts Used as Structural Members on Farms, and Plywood
Used on Farms (C16), Wood for Marine Construction (C18), Lumber
and Plywood for Permanent Wood Foundations (C22), Round Poles
and Posts Used in Building Construction (C23), Sawn Timber
Used To Support Residential and Commercial Structures (C24),
Sawn Crossarms (C25), Structural Glued Laminated Members and
Laminations Before Gluing (C28), Structural Composite Lumber
(C33), and Shakes and Shingles (C34). Forest products treated
with this product may only be sold or distributed for uses
within the AWPA Commodity Standards under which the treatment
occurred. *
* The referenced
FR notice also included provision for registrants to make
certain additional specified changes to their labels via notification.
The above label for CCA refers to the 2001
Edition of the AWPA standards to specify the categories of
wood products that may be treated as of December 31, 2003.
As noted above, subsequent changes were made to these labels,
which, among other things, added a reference to the 2002 Edition
of the AWPA standards for C30 only. That language as well
as language pertaining to C18 follows.
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New Label Language
for C30
Following is the new label amendment language
which references the AWPA Standard C30 (label revisions were
approved as of December 2003 and February 2004):
(For end-use products [EUP]): “...this product
may only be used for preservative treatment of the following
categories of forest products and in accordance with the respective
cited standard (noted parenthetically) of the ...2002 edition
of the American Wood-Preservers Association Standard: Lumber
and Plywood for Cooling Towers (C30)...”
(For manufacturing-use products [MUP]): The
accepted amended labeling reads as follows:
“Effective December 31, 2003, this product
may only be used (1) for formulation of the following end-use
wood preservative products: ammoniacal copper zinc arsenate
(ACZA) or chromated copper arsenate (CCA) labeled in accordance
with the Directions for Use shown below, or (2) by persons
other than the registrant, in combination with one or more
other products to make: ACZA wood preservative; or CCA wood
preservative that is used in accordance with the Directions
for Use shown below. Effective December 31, 2003, this product
may only be used for preservative treatment of the following
categories of forest products and in accordance with the respective
cited standard (noted parenthetically) of the ...2002 edition
of the American Wood-Preservers Association Standard: Lumbers
and Plywood for Cooling Towers (C30)...”
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Revised Label Language
for C18
For the termination of the use (“members
out of water and not subject to saltwater [or brackish water]
splash [1] and not in soil use”) under AWPA standard C18 (Wood for Marine
Construction) the registrants have agreed to label new product
with the revised label language (for both end-use products
and manufacturing-use products) to clarify allowable uses
(see page 1). The following language has been approved by
the Agency for the expression of uses allowable under the
AWPA C18 Wood for Marine Construction Standard and reflects
the label language that incorporates that change as well as
those described earlier:
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REVISED LANGUAGE (EUP)
This product may only be used for preservative
treatment of the following categories of forest products and
in accordance with the respective cited standard (noted parenthetically)
of the 2001 edition of the American Wood-Preservers' Association
(AWPA) Standards: Lumber and Timber for Salt Water Use Only
(C2), Piles (C3), Poles (C4), Plywood (C9), Wood for Highway
Construction (C14), Round, Half Round and Quarter Round Fence
Posts (C16), Poles, Piles and Posts Used as Structural Members
on Farms, and Plywood Used on Farms (C16), Wood for Marine
Construction (C18), Lumber and Plywood for Permanent Wood
Foundations (C22), Round Poles and Posts Used in Building
Construction (C23), Sawn Timber Used To Support Residential
and Commercial Structures (C24), Sawn Crossarms (C25), Structural
Glued Laminated Members and Laminations Before Gluing (C28),
Structural Composite Lumber (C33), and Shakes and Shingles
(C34); and in accordance with the respective cited standard
(noted parenthetically) of the 2002 edition of the American
Wood-Preservers' Association Standards: Lumber, Timbers and
Plywood for Cooling Towers (C30). Forest products treated
with this product may only be sold or distributed for uses
within the AWPA Commodity Standards under which the treatment
occurred.
Effective December 31, 2004, this product
may only be used for preservative treatment of the following
categories of forest products and in accordance with the respective
cited standard (noted parenthetically) of the 2001 edition
of the American Wood-Preservers' Association (AWPA) Standards:
Lumber and Timber for Salt Water Use (also includes brackish
water) Only (C2), Piles (C3), Poles (C4), Plywood (C9), Wood
for Highway Construction (C14), Round, Half Round and Quarter
Round Fence Posts (C16), Poles, Piles and Posts Used as Structural
Members on Farms, and Plywood Used on Farms (C16), Wood for
Marine Construction for Salt Water Use (also includes brackish
water) (immersion and/or subject to saltwater (or brackish
water) splash ["subject to saltwater (or brackish water)
splash” means any member of a marine structure which is positioned
above mean high tide, but is subject to frequent wetting from
wave action]), [Pilings (sheet, round and square), Timbers,
and Plywood; Walers, Framing, Stringers and Cross Bracing
(2" x 8" and/or 3"x6" and larger nominal
dimensions and treated to a minimum of 0.60 pcf) (C18), Lumber
and Plywood for Permanent Wood Foundations (C22), Round Poles
and Posts Used in Building Construction (C23), Sawn Timber
Used To Support Residential and Commercial Structures (C24),
Sawn Crossarms (C25), Structural Glued Laminated Members and
Laminations Before Gluing (C28), Structural Composite Lumber
(C33), and Shakes and Shingles (C34); and in accordance with
the respective cited standard (noted parenthetically) of the
2002 edition of the American Wood-Preservers' Association
Standards: Lumber, Timbers and Plywood for Cooling Towers
(C30). Forest products treated with this product may only
be sold or distributed for uses within the AWPA Commodity
Standards under which the treatment occurred, except where
otherwise provided above.
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REVISED LANGUAGE (MUP)
This product may only be used (1) for formulation
of the following end-use wood preservative products: ammoniacal
copper zinc arsenate (ACZA) or chromated copper arsenate (CCA)
labeled in accordance with the Directions for Use shown below,
or (2) by persons other than the registrant, in combination
with one or more other products to make: ACZA wood preservative;
or CCA wood preservative that is used in accordance with the
Directions for Use shown below.
This product may only be used for preservative
treatment of the following categories of forest products and
in accordance with the respective cited standard (noted parenthetically)
of the 2001 edition of the American Wood-Preservers' Association
(AWPA) Standards: Lumber and Timber for Salt Water Use Only
(C2), Piles (C3), Poles (C4), Plywood (C9), Wood for Highway
Construction (C14), Round, Half Round and Quarter Round Fence
Posts (C16), Poles, Piles and Posts Used as Structural Members
on Farms, and Plywood Used on Farms (C16), Wood for Marine
Construction (C18), Lumber and Plywood for Permanent Wood
Foundations (C22), Round Poles and Posts Used in Building
Construction (C23), Sawn Timber Used To Support Residential
and Commercial Structures (C24), Sawn Crossarms (C25), Structural
Glued Laminated Members and Laminations Before Gluing (C28),
Structural Composite Lumber (C33), and Shakes and Shingles
(C34); and in accordance with the respective cited standard
(noted parenthetically) of the 2002 edition of the American
Wood-Preservers' Association Standards: Lumber, Timbers and
Plywood for Cooling Towers (C30). Forest products treated
with this product may only be sold or distributed for uses
within the AWPA Commodity Standards under which the treatment
occurred.
Effective December 31, 2004, this product
may only be used for preservative treatment of the following
categories of forest products and in accordance with the respective
cited standard (noted parenthetically) of the 2001 edition
of the American Wood-Preservers' Association (AWPA) Standards:
Lumber and Timber for Salt Water Use (also includes brackish
water) Only (C2), Piles (C3), Poles (C4), Plywood (C9), Wood
for Highway Construction (C14), Round, Half Round and Quarter
Round Fence Posts (C16), Poles, Piles and Posts Used as Structural
Members on Farms, and Plywood Used on Farms (C16), Wood for
Marine Construction for Salt Water Use (also includes brackish
water) (immersion and/or subject to saltwater (or brackish
water) splash ["subject to saltwater (or brackish water)
splash” means any member of a marine structure which is positioned
above mean high tide, but is subject to frequent wetting from
wave action]), [Pilings (sheet, round and square), Timbers,
and Plywood; Walers, Framing, Stringers and Cross Bracing
(2" x 8" and/or 3"x6" and larger nominal
dimensions and treated to a minimum of 0.60 pcf) (C18), Lumber
and Plywood for Permanent Wood Foundations (C22), Round Poles
and Posts Used in Building Construction (C23), Sawn Timber
Used To Support Residential and Commercial Structures (C24),
Sawn Crossarms (C25), Structural Glued Laminated Members and
Laminations Before Gluing (C28), Structural Composite Lumber
(C33), and Shakes and Shingles (C34); and in accordance with
the respective cited standard (noted parenthetically) of the
2002 edition of the American Wood-Preservers' Association
Standards: Lumber, Timbers and Plywood for Cooling Towers
(C30). Forest products treated with this product may only
be sold or distributed for uses within the AWPA Commodity
Standards under which the treatment occurred, except where
otherwise provided above.
Building code inspectors, wood treaters,
and other responsible for working with CCA and CCA-treated
wood need to review the label, along with the 2001 and 2002*
editions of the AWPA standards, to determine whether CCA can
be used to treat the wood for a particular application. If
the use category of wood to be treated is not included within
the AWPA standards listed on the label, CCA is not registered
for that treatment, and CCA may not be used for such treatment.
The new label does not allow the use of CCA
for virtually all wood use at residences, including wood used
in playground structures, decks, picnic tables, landscaping
timbers, residential fencing, patios and walkways/boardwalks.
The label authorizes use of CCA in industrial and commercial
applications specified therein. Most of those applications
are heavy retention treatments of 0.50 or more pounds per
cubic foot. The only standards under which lower retention
treatments may be used are C9, C14, C16, C18 (fish ladders,
lobster traps and oyster farming timbers only), C25, C28,
C30*,C33 and C34. Most dimensional
lumber (defined as lumber that is from 2" up to, but
not including, 5" thick, and that is 2 or more inches
in width) historically treated with CCA to .25 or .40 under
AWPA standard C2 may no longer be treated with CCA and must
now be treated with alternative non-CCA preservatives.
* 2002 Edition
is to be consulted for C30 only.
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Examples of CCA
Uses
The following list is taken from the 2001
Edition of the AWPA standards and, for C30 only, the 2002
Edition of the AWPA standards to illustrate examples of the
types of wood that fall within each standard. While the list
is not exhaustive, it does provide some examples of specific
wood/forest product uses within each AWPA commodity standards
referenced on the label and that may be treated with CCA.
Lumber and Timber for Salt Water Use Only (2001 AWPA Standard
C2)
- Aquaculture timber, in salt water and subject to marine
borer attack
- Boat Building material
- Lumber, timbers, plywood, in salt water and subject
to marine borer attack
- Bulkhead Sheathing
- In salt water and subject to marine borer attack
- Mariculture lumbers and timbers
- In brackish or saltwater use and subject to marine
borer attack
- Marine lumber and timbers
- In brackish or saltwater use and subject to marine
borer attack
- Oyster farming timbers
- Lobster Traps
- Fish Ladders
- Highway Material
- Structural lumber and timbers in salt water use and
subject to marine borer attack
Piles (2001 AWPA Standard C3)
- Highway Material
- Piles, foundation, land and fresh water use
- Piling in salt water use and subject to marine borer
attack
- Piles
- Foundation (round)
- Land and fresh water use (round)
- Marine (round) in salt or brackish and subject to
marine borer attack
- Marine, dual treatment (round)
Poles (2001 AWPA Standard C4)
- Agriculture, Wood used on farms
- Round poles
- As round structural members
- Highway material
- Poles, agriculture
- Poles, building
- Round
- Poles, utility
- Distribution
- Transmission
Plywood (2001 AWPA Standard C9)
- Agriculture, Wood used on farms
- Plywood, not in soil contact
- Plywood, in soil contact
- Boat building material
- Plywood, fresh water
- Lumber, timbers, plywood, in salt water and subject
to marine borer attack
- Building construction material
- Decking, Tongue and Groove
- Flooring, plywood
- Subflooring, plywood
- Decking
- Plywood
- Sub-floor, damp, above ground
- Exterior, above ground
- Soil contact
Wood for Highway Construction (2001 AWPA Standard C14)
- Beams and timbers, glue laminated before or after treatment
- Decking
- Highway material
- Lumber and timber for bridges, structural members,
decking, cribbing, and culverts
- Structural lumber and timbers in salt water use and
subject to marine borer attack
- Piles, foundation, land and fresh water use
- Piling in salt water use and subject to marine borer
attack
- Posts: Round, half-round, quarter round
- Posts: Sawn Poles, lighting
- Glue laminated beams
- Brine Storage buildings
- Posts, guardrail
- Posts, sawn four sides
Poles, Piles and Posts Used as Structural
Members on Farms, and Plywood Used on Farms (2001 AWPA Standard
C16)
- Agriculture, Wood used on farms
- Round poles and posts as round structural members
- Sawn poles and posts
- As structural members
- Plywood, not in soil contact
- Plywood, in soil contact
- Sawn building poles and posts
- Round building poles and posts
- Sawn structural timbers (piles)
- Supporting residential and commercial structures
- Poles, Agricultural
- Round; includes farm-fence rails
- Sawn
- Posts, fence
- Round, half-round, and quarter round
Wood for Marine Construction (2001 AWPA Standard
C18) Except Members Out of Water and Not Subject to Splash
and Not in Soil Use (effective 12/31/04)
- Timber and plywood in salt water use
- Aquaculture timber, in salt water and subject to marine
borer attack
- Mariculture lumber and timbers
- In brackish or saltwater use and subject to marine
borer attack
- Marine lumber and timbers
- In brackish or saltwater use and subject to marine
borer attack
- Oyster farming timbers
- Lobster Traps
- Fish Ladders
- Piles
- Members Out of Water But Subject to Saltwater (or brackish
water) Splash
- Marine (round) in salt or brackish and subject to marine
borer attack
- Marine, dual treatment (round)
Lumber and Plywood for Permanent Wood Foundations (2001 AWPA
Standard C22)
- Lumber and Plywood for Wood Foundations
Round Poles and Posts Used in Building Construction (2001
AWPA Standard C23)
- Round building poles and posts
- Poles, building
Sawn Timber Used to Support Residential and
Commercial Structures (2001 AWPA Standard C24)
- Sawn structural timbers
- Supporting residential and commercial structures
- Piles
Sawn Crossarms (2001 AWPA Standard C25)
Structural Glued-Laminated Members and Laminations
before Gluing (2001 AWPA Standard C28) [2] (nails/mechanical fasteners may be used as laminate
in lieu of, or in combination with, glue)
- Beams and timbers, glue laminated before or after treatment
- Damp environment, above ground
- Dry environment, above ground
- Ground contact
- Highway material
Lumber, Timbers and Plywood for Cooling Towers-Preservative
Treatment by Pressure Processes (2002 AWPA Standard C30)
- Lumber, timber and plywood for Cooling Tower Use Only
Structural Composite Lumber (2001 AWPA Standard C33)
- Highway material
- Structural composite lumber
- Lumber, structural composite
- Above ground
- Soil or fresh water contact
- Highway construction
Shakes and Shingles (2001 AWPA Standard C34)
- Shakes and Shingles
- Siding, commercial, residential, agricultural
- Tile Batts
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[1] See Definitions
for definition of “subject
to saltwater (or brackish water) splash.”
[2] The Agency interprets this to include nailed laminated
members (nails/mechanical fasteners may be used as laminate
in lieu of, or in combination with, glue).
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