RAC proposes to restrict the secondary use of creosote-treated wood!
RAC proposes to restrict the secondary use of creosote-treated wood! – ECHA’s Committee for Risk Assessment (RAC) supports the French proposal to restrict the placing on the market, reuse and secondary use of wood treated with creosote and related substances. The draft opinion of the Socio-Economic Analysis Committee (SEAC) is open for comments until November 7, 2023.
On the recommendation of France, the RAC concluded that an EU-wide restriction is needed to minimize environmental emissions and public exposure. Creosote and related substances are carcinogenic, persistent, bioaccumulative and toxic and can cause harm at very low levels of exposure.
The RAC agrees that all secondary uses should be banned as safer alternatives are available.
Deviation from the French proposal
The RAC felt that one of the nine substances in the French proposal – wood creosote – could be removed from the scope because it does not have the same hazardous properties as the others. The committee also agrees with SEAC’s proposal to allow the reuse of creosote-treated railroad ties and utility poles by all professionals in the same country, not just by “the same original user,” as France proposes. This would have greater environmental benefits than companies purchasing new creosote-treated wood, which is the most likely alternative. Newly treated wood is expected to leach more than older treated wood.
Existing measures are not sufficient
“This is a restriction that will have a direct impact on the market and on our lives. Creosote-treated wood continues to be available to the public despite the existing restriction, which was put in place before REACH. This suggests that existing measures are not sufficient to address the risks, says RAC Chairman Roberto Scazzola in a new episode of the Safer Chemicals Podcast.
Two birds with one stone
SEAC’s draft comments also support the proposed restriction. According to SEAC, the proposal is proportionate. After all, it provides significant health benefits by prohibiting secondary use by the public, and the cost is relatively low.
Reuse by professionals
SEAC analyzed the relative benefits of reuse by professionals other than just the original. The committee supports this option but notes that the benefits of the restriction would only increase if public access to creosote-treated wood were prevented. The potential benefits of the restriction are evaluated based on several factors, such as availability of alternatives, adequate worker protection, and consistency with the Biocidal Products Regulation.
The 60-day consultation on SEAC’s draft position runs through Nov. 7, 2023.
Looking for more information
“We are looking for more information on whether allowing intra-group trade would have a secondary effect on getting creosote-treated wood into the hands of the general public. This is exactly what we want to prevent. We will then also consider the proposed 12-month transition period and whether it is appropriate to implement all steps to comply with the restriction,” said SEAC President María Ottati.
The committee is expected to issue its opinion in December 2023.
Other outcomes of the September meetings:
- SEAC adopted its opinion in support of the proposed restriction on chloroalkanes C14-C17;
- The RAC adopted nine opinions on harmonized classification and labeling;
- The RAC and SEAC adopted an opinion on an application for authorization of chromium trioxide; and
- The RAC adopted the opinion on the scientific evaluation of occupational exposure limits (OELs) for chloroprene.
For more on these topics, see the attachment. Listen to our podcast with new RAC President Roberto Scazzola and SEAC President María Ottati.
This information has been compiled with the greatest possible care, in some cases from different information sources. (Interpretation) errors are not excluded. No legal obligation can therefore be derived from this text. Everyone dealing with this subject has the responsibility to delve into the matter!