<p>Docket ID No. EPA-HQ-OAR-2005-0172</p><p>October 8, 2007</p><p>Deborah Elaine Barrie 4 Catherine Street Smiths Falls, On Canada K7A 3Z8 (613)284-8259 [email protected] [email protected] www.noccawood.ca</p><p>EPA Docket Center, Environmental Protection Agency, Room 3334, 1301 Constitution Avenue, NW, Washington, DC</p><p>Docket ID No. EPA-HQ-OAR-2005-0172</p><p>To Whom it May Concern,</p><p>Thank you for the opportunity to address this important issue.</p><p>I am writing my submission as a victim of the burning of CCA treated wood and other waste. While I am not a scientist I do have first hand knowledge on the dangers to health and the environment that is caused by such burning. The chemicals in CCA wood can cause people to become extremely sensitive1 and to develop severe allergic reactions. These chemicals also pose an increased hazard to those that are already sensitive to triggers in their environment.2 CCA wood waste burning can effect the ozone detrimentally by way of small particulate and dioxin which is a by-product of this burning. I will show that the burning of CCA treated wood by even one individual can cause environmental and health damage on such a scale that the burning of it in waste facilities and by private citizens is a danger that can not be considered a reasonable solution to this growing waste problem.</p><p>To protect health and the environment ground level ozone standards must be strengthened so that the burning of CCA treated wood is not allowed.</p><p>In the case of CCA wood or any chromium containing wood, research from the University of Florida has shown that the chromium converts to the toxic hexavalet form when incinerated. They also found that the arsenic is released in toxic levels into the air in the form of arsine. Arsenic was also found in the bottom ash in it’s inorganic form. This also pertains to fly ash3</p><p>The hexavalent form of chromium is known to be a sensitizer as shown here.</p><p>Exposure Standards(1) Chromium (VI) compounds, (as Cr), water soluble SUBSTANCE NAME:Chromium (VI) compounds, (as Cr), water soluble Synonyms:Chromic acid Chromium trioxide Exposure Standard: TWA: - ppm 0.05 mg/m3 STEL: - ppm - mg/m3 Review notice: Reason for review - respiratory irritation and effects on the kidneys. Sensitiser notice: Some substances can cause a specific immune response in some people. Such substances are called sensitisers and the development of a specific immune response is termed `sensitisation'. Exposure to a sensitiser, once sensitisation has occurred, may</p><p>Submitted by Deborah Elaine Barrie www.noccawood.ca 1 Docket ID No. EPA-HQ-OAR-2005-0172</p><p> manifest itself as a skin rash or inflammation or as an asthmatic condition, and in some individuals this reaction can be extremely severe. See Chapter 12: Guidance Note on the Interpretation of Exposure Standards for Atmospheric Contaminants in the Occupational Environment, published by Worksafe Australia. Documentation notice. American Conference of Governmental Industrial Hygienists (ACGIH), Documentation of Threshold Limit Values and Biological Exposure Indices, 6th Edition, ACGIH, Cincinatti, Ohio, 1991 No standard should be applied without reference to the Guidance Note on the Interpretation of Exposure Standards for Atmospheric Contaminants in the Occupational Environment [NOHSC:3008(1995)], and to the related documentation. Footnotes: Review notice: A review notice indicates that the substance requires further review by the Exposure Standards Expert Working Group. In most cases the ACGIH documentation should be consulted for these substances. Documentation notice Documentation for the majority of substances can be found in the American Conference of Governmental Indistrial Hygienists' (ACGIH) documentation of the threshold limit values and biological exposure indices - users should refer to the ACGIH documentation cited.”2</p><p>Multiple Chemical Sensitivity (MCS) has been recognised by the Canadian Human Rights Commission (CHRC).4</p><p>When CCA wood is burned the arsenic is changed into arsine gas and is emitted into the surrounding environment. As there is no filter that can capture this gas it often goes unnoticed. The tiny particles require sophisticated testing equipment that is capable of picking up this odorless but extremely toxic gas. After my neighbor burned CCA treated wood we had the exterior of our home tested with a Niton Corporation portable X-Ray Fluorescence Analyser. I now quote on the test results by the company.</p><p>“ The exterior tests were done both on painted surfaces which appeared to be in "good" condition and on a couple of areas of "bare" wood next to these areas. 3 tests were done just for lead concentration and the 4 tests were done for multi-elements. The accepted exposure limit for lead in paint is 1.0mgm/cm2( 5000ppm) ( H.U.D). Only one test exceeded this value but the tests indicated that the lead concentration was also "buried" beneath other paint layers. The instrument gives an index which indicates whether the leaded paint is at the surface or 'buried " beneath other nonleaded paint coating. The indication was that the original paint surface was a lead based paint but the outer yellow surface was a zinc based paint. However, on the "bare" wood the 3 tests indicated arsenic concentration levels 198, 242 and 702 ppm. Evidence which could possibly be attributed to arsenic laden smoke/fume from the burning of CCA treated wood being adsorbed onto the unprotected wood surface.”5</p><p>With 12 ppm of arsenic in soil being the Canadian Standard for residential properties before requiring cleanup it is clear that my home was toxic in the extreme. </p><p>Our house was in bad need of painting at the time but we had been concerned about arsenic from my neighbors burning being absorbed by our home. As the windows were “pitted” we assumed the exterior was likely contaminated and sought testing before anyone was endangered by scraping and sanding the wood siding. The wood siding on the exterior of the home which was still covered in paint tested safe while the three areas of bare wood tested toxic for arsenic. The vast difference in the amounts found clearly show it came from an outside source and could not have been in paint or some other coating, which would have showed more consistent results. </p><p>Submitted by Deborah Elaine Barrie www.noccawood.ca 2 Docket ID No. EPA-HQ-OAR-2005-0172</p><p>This shows that the arsenic, which is released in the arsine form when burned, can change back into the arsenic form and contaminate “breathable” surfaces such as the bare wood on our home. Humans, being porous, are in danger from either form of arsenic. This also clearly shows that bare cedar decks and other structures such as wooden picnic tables and playground equipment could become toxic from the burning of CCA treated wood.</p><p>Studies done on sealing children’s playgrounds6, 7 made from CCA wood have shown that coatings help prevent the leaching of arsenic. So it is natural that where our house was coated in paint it was also protected from absorbing the arsenic in its arsine form.</p><p>After the testing of our home was finished and I sent the results to the EPA. A study was done by the National Risk Management Research Laboratory, E305-01, Office of Research and Development, U.S. Environmental Protection Agency, which confirmed what was discovered at our home.8 The results of their open burning CCA study found that “These results indicate that the open burning of CCA-treated wood can lead to significant air emissions of the more toxic trivalent form of As [arsenic] in particle sizes that are most respirable.”</p><p>My family alone has lost several hundred thousand dollars in property and home clean up 9, health costs and missed time from work to date. This does not include private insurance costs or government paid health care. It certainly does not reflect the human costs. There is no end in sight to these repercussions as we continue to experience and suffer new health problems due to the long-term effects of the CCA wood burning. I am presently on steroids as my body is reacting dangerously to chemicals and recently nearly ruptured from the pressure of inflammation 2 in my abdomen. I can not stress enough how CCA treated wood burning has effected us as a family and the social implications involved. How it has torn apart relationships and caused damage that can never be repaired. The medical report I wrote on what happened in my neighborhood was submitted to the EPA in 2001.</p><p>If this has happened to us then the cost of burning CCA wood in waste facilities certainly would bear extreme health, familial, social and environmental costs. How many are now ill and not knowing the source of their problems? The cost of lax ozone laws extends far beyond the costs to health and environment. These costs would be reflected in social services, educational and other areas as well.</p><p>I have included additional reading, at the end of this document, showing not only the dangers to the environment but numerous health problems that occur from ozone particulate pollution associated with CCA treated wood waste burning.</p><p>It is my hope that the suffering my family and neighbors have incurred will serve to warn others so that ozone laws will be tightened to protect others from a similar fate.</p><p>Thank you for your time and consideration.</p><p>Take care and please keep safe.</p><p>Deborah Elaine Barrie</p><p>Submitted by Deborah Elaine Barrie www.noccawood.ca 3 Docket ID No. EPA-HQ-OAR-2005-0172</p><p>References</p><p>1) Building Materials for the Environmentally Sensitive" a Canadian Mortgage and Housing Corporation Publication available for purchase by contacting them at 1-800-668-2642. For those of you not aware this is a Canadian government agency. It was revised in 1997</p><p>2) http://www.nohsc.gov.au/ohsinformation/databases/exposurestandards/az/chromium_vi_compounds_as_ cr_water_soluble.htm</p><p>As the Australians have removed this link from their site the entire information was included above</p><p>3) http://www.ccaresearch.org/projectadmin.htm May 6, 2002</p><p>4) The Canadian Human Rights Commission (CHCR) has released its policy on Environmental Sensitivities, which is available at: http://www.chrc-ccdp.ca/legislation_policies/policy_environ_politique-en.asp?lang_update=1 This is following the reports that were commissioned: The Medical Perspective on Environmental Sensitivities: http://www.chrc-ccdp.ca/pdf/envsensitivity_en.pdf Accommodation for Environmental Sensitivities: Legal Perspective: http://www.chrc-ccdp.ca/pdf/legal_sensitivity_en.pdf You can obtain a copy of these reports at no charge by calling: 1-888-214-1090 then select ‘publications.’ You can email the CHRC at: [email protected]</p><p>5) Letter from scientist who did the testing, note for EPA use only and not for public viewing to protect the identity of the scientist involved attached</p><p>6) http://www.noccawood.ca/docs/STILWELLSAPCOATING2001/index.htm</p><p>7) http://www.safe2play.org/assets/docs/effectivesealants.pdf</p><p>8) Emissions of chromium, copper, arsenic, and PCDDs/Fs from open burning of CCA-treated wood. Wasson SJ, Linak WP, Gullett BK, King CJ, Touati A, Huggins FE, Chen Y, Shah N, Huffman GP. http://www.ncbi.nlm.nih.gov/sites/entrez? cmd=Retrieve&db=pubmed&dopt=AbstractPlus&list_uids=16323788&query_hl=</p><p>9) http://www.noccawood.ca/cgi-scripts/csNewsPro/csNews.cgi?command=viewnews&database=Our %20Property%20Clean%20Up%2edb</p><p>Submitted by Deborah Elaine Barrie www.noccawood.ca 4 Docket ID No. EPA-HQ-OAR-2005-0172</p><p>Additional Reading</p><p>1) Airborne pollutants and the immune system. Albright JF, Goldstein RA. Chemosphere. 2005 Jun;59(10):1497-505. Division of Allergy, Immunology and Transplantation, National Institute of Allergy and Infectious Diseases, National Institutes of Health, Bethesda, MD 20892, USA. http://www.ncbi.nlm.nih.gov/sites/entrez? Db=pubmed&Cmd=ShowDetailView&TermToSearch=15876392&ordinalpos=1&itool=EntrezSystem2. PEntrez.Pubmed.Pubmed_ResultsPanel.Pubmed_RVAbstractPlus</p><p>2) Dynamic change of copper in fly ash during de novo synthesis of dioxins. Takaoka M, Shiono A, Nishimura K, Yamamoto T, Uruga T, Takeda N, Tanaka T, Oshita K, Matsumoto T, Harada H. 1: Environ Sci Technol. 2005 Aug 1;39(15):5878-84.Links http://www.ncbi.nlm.nih.gov/sites/entrez? Db=pubmed&Cmd=ShowDetailView&TermToSearch=16124329&ordinalpos=1&itool=EntrezSystem2. PEntrez.Pubmed.Pubmed_ResultsPanel.Pubmed_RVAbstractPlus</p><p>3) Environmental cardiovascular disease. Mastin JP. National Institute of Environmental Health, Research Triangle Park, NC 27709, USA. [email protected] http://www.ncbi.nlm.nih.gov/sites/entrez? Db=pubmed&Cmd=ShowDetailView&TermToSearch=16046786&ordinalpos=7&itool=EntrezSystem2. PEntrez.Pubmed.Pubmed_ResultsPanel.Pubmed_RVDocSum</p><p>4) Environmental hazard assessment of chemicals and products. Part VI. Abiotic degradation in the troposphere. Klöpffer W. C.A.U. GmbH, Dreieich/Frankfurt am Main, Germany. http://www.ncbi.nlm.nih.gov/sites/entrez? Db=pubmed&Cmd=ShowDetailView&TermToSearch=8784998&ordinalpos=2&itool=EntrezSystem2.P Entrez.Pubmed.Pubmed_ResultsPanel.Pubmed_RVDocSum</p><p>5) Estimation of selected heavy metals and arsenic in PM10 aerosols in the ambient air of the Greater Athens Area, Greece. Vassilakos Ch, Veros D, Michopoulos J, Maggos T, O'Connor CM. Environmental Research Laboratory/INT-RP, National Centre for Scientific Research DEMOKRITOS, Aghia Paraskevi Attikis, P.O.B. 60228, 15310 Athens, Greece. [email protected] http://www.ncbi.nlm.nih.gov/sites/entrez? Db=pubmed&Cmd=ShowDetailView&TermToSearch=17126484&ordinalpos=1&itool=EntrezSystem2. PEntrez.Pubmed.Pubmed_ResultsPanel.Pubmed_RVDocSum</p><p>6) Incinerator toxic emissions: a brief summary of human health effects with a note on regulatory control. Rowat SC. Med Hypotheses. 1999 May;52(5):389-96. Erratum in: Med Hypotheses 2000 Feb;54(2):342. Thought Transfer Research, North Augusta, Ontario, Canada. http://www.ncbi.nlm.nih.gov/sites/entrez? Db=pubmed&Cmd=ShowDetailView&TermToSearch=10416945&ordinalpos=7&itool=EntrezSystem2. PEntrez.Pubmed.Pubmed_ResultsPanel.Pubmed_RVDocSum</p><p>Submitted by Deborah Elaine Barrie www.noccawood.ca 5 Docket ID No. EPA-HQ-OAR-2005-0172</p><p>7) Metal catalyzed formation of chlorinated aromatic compounds: a study of the correlation pattern in incinerator fly ash. Oberg T, Ohrström T, Bergström J. Environ Sci Technol. 2007 May 15;41(10):3741-6. Department of Biology and Environmental Science, University of Kalmar, SE-391 82 Kalmar, Sweden. [email protected] http://www.ncbi.nlm.nih.gov/sites/entrez? Db=pubmed&Cmd=ShowDetailView&TermToSearch=17204302&ordinalpos=1&itool=EntrezSystem2. PEntrez.Pubmed.Pubmed_ResultsPanel.Pubmed_RVAbstractPlus</p><p>8) The effect of copper speciation on the formation of chlorinated aromatics on real municipal solid waste incinerator fly ash. Chemosphere. 2005 Jun;59(10):1497-505 Takaoka M, Yamamoto T, Shiono A, Takeda N, Oshita K, Matsumoto T, Tanaka http://www.ncbi.nlm.nih.gov/sites/entrez? Db=pubmed&Cmd=ShowDetailView&TermToSearch=15876392&ordinalpos=1&itool=EntrezSystem2. PEntrez.Pubmed.Pubmed_ResultsPanel.Pubmed_RVAbstractPlus</p><p>9) Arsenic trioxide, a potent inhibitor of NF-kappaB, abrogates allergen-induced airway hyperresponsiveness and inflammation. Zhou LF, Zhu Y, Cui XF, Xie WP, Hu AH, Yin KS. Department of Respiratory Medicine, The First Affiliated Hospital, Nanjing Medical University, Nanjing, China. [email protected] http://www.ncbi.nlm.nih.gov/sites/entrez? Db=pubmed&Cmd=ShowDetailView&TermToSearch=17178007&ordinalpos=1&itool=EntrezSystem2. PEntrez.Pubmed.Pubmed_ResultsPanel.Pubmed_RVDocSum</p><p>10) Int J Environ Res Public Health. 2006 Mar;3(1):86-97.Links Assessment of public health risks associated with atmospheric exposure to PM2.5 in Washington, DC, USA. Greene NA, Morris VR. Program in Atmospheric Sciences, Howard University, Washington, DC 20059, USA. [email protected] http://www.ncbi.nlm.nih.gov/sites/entrez? Db=pubmed&Cmd=ShowDetailView&TermToSearch=16823080&ordinalpos=2&itool=EntrezSystem2. PEntrez.Pubmed.Pubmed_ResultsPanel.Pubmed_RVDocSum</p><p>11) Industrial Burning of Treated Wood http://www.chej.org/policy.html#Ind%20Burning link down , document attached</p><p>12) Increased PCDD/F formation in the bottom ash from fires of CCA-treated wood. Tame NW, Dlugogorski BZ, Kennedy EM. Process Safety and Environment Protection Group, School of Engineering, The University of Newcastle, Callaghan, NSW 2308, Australia. http://www.ncbi.nlm.nih.gov/entrez/query.fcgi? cmd=Retrieve&db=PubMed&list_uids=12547341&dopt=Abstract</p><p>Submitted by Deborah Elaine Barrie www.noccawood.ca 6</p>