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Banning secondary uses of creosote-treated wood

The Committee for Risk Assessment (RAC) supports France’s proposal to restrict the placing on the market, reuse and banning the secondary use of wood treated with creosote and related substances. The draft opinion of the Committee for Socio-Economic Analysis (SEAC) is open for comments until 7 November 2023.

RAC, which adopted its opinion on France’s proposal, concluded that an EU-wide restriction is needed to minimise environmental emissions and exposure of the public. Creosote and related substances are carcinogenic, persistent, bioaccumulative and toxic, and can cause harm already at very low levels of exposure.

RAC considered that wood creosote, one of the nine substances in France’s proposal, could be removed from scope as it does not share the same hazardous properties as the rest. The committee also agrees with SEAC’s suggestion to allow the reuse of railway sleepers and utility poles treated with creosote by all professionals in the same country and not just by the ‘same original user’ as France proposes. This would lead to higher environmental benefits as opposed to companies buying newly creosote-treated wood, which is the most likely alternative. Newly treated wood is expected to leach more than older treated wood.

RAC agrees that all secondary uses should be banned since safer alternatives are available.

“This is a restriction that will have a direct effect on the market, but also in our lives because creosote-treated wood is still available to the public despite the existing restriction, which was put in place before REACH. This indicates that the current measures are not enough to control the risks”, says Roberto Scazzola, Chair of the RAC.

The SEAC draft opinion also lends support to the proposed restriction. According to SEAC, the proposal is proportionate, as it offers significant health benefits by banning secondary use to the public, and the costs are relatively low.

SEAC has analysed the comparative benefits of allowing reuse by other professionals than just the original one. The committee supports this option but notes that the benefits of the restriction increase only if access to creosote-treated wood by the public is prevented. The potential benefits of the restriction are assessed based on several factors such as the availability of alternatives, adequate worker protection and alignment with the Biocidal Product Regulation.

The 60-day consultation of the SEAC draft opinion is open until 7 November 2023.

“We are looking for more information on whether allowing trade between companies would have a secondary effect on creosote-treated wood getting into the hands of the general public. That's really what we want to prevent. Then, we are also looking into the proposed transition period of 12 months, and whether that is appropriate for all the steps to be implemented to comply with the restriction,” says María Ottati, Chair of the SEAC.