• Learn to Keep Insects Out of your Crops
  • Driving Near Recently Sprayed Fields Exposes People to Pesticides
  • Weeds Can Be Managed Without Chemical Pesticides
  • SNAP Display at Event
  • Learn About Pesticides in Foods
  • SNAP Tour of Organic Vegetable Garden
  • Grow a Lush Garden Organically
  • Learn to Manage Pests Naturally
  • LIving Near Fields Increases Pesticide Exposure
  • Learn To Manage Weeds Without Chemical Pesticides

Treated Wood

CCA treated wood and alternatives

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Alternatives to CCA-Treated Wood (PANNA Green Resource Center)

'Pressure-treated lumber is used in applications where decay and insect damage are of concern, such as for playground equipment, decks, telephone poles, building foundations, picnic tables, landscaping ties, wharfs, retaining walls, and fence posts. Preservative treatment chemicals make the wood inedible for fungi, insects, and other organisms that can destroy wood. Until its use for residential applications was voluntarily restricted by industry in January 2004, copper chromated arsenate (CCA) was the most common wood preservation treatment that a typical homeowner would encounter.' (same timeline in Canada)

Rubbing a cloth on the CCA treated wood in a playground collected toxic levels of arsenic and chromium.

When arsenic treated wood is new, it tends to have a greenish tint. When CCA wood is older, it is harder to tell.


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see also Legal/Litigationtreated wood/disposal 

Creosote-Induced Health Problems Persist from Springfield, MO Production, Now Superfund, Site   (Beyond Pesticides, March 7, 2023) An old Kerr-McGee Wood Treatment Facility is still causing health issues among residents in Springfield, Missouri.    SNAP Comment: so that got me checking. There are still 10 registered creosote pesticides with the PMRA as of 22 March 2023. Then I found out there are Canadian wood treatment facilities with creosote. Wood preservation facilities, creosote: chapter D is part of a Gov. of Canada document. (Jul 28, 2017) so there are likely issues in Canada as well. 

Houston Residents Sue City, Railroad, for Poisoning and Contamination Caused by Creosote Wood Preservative     (Beyond Pesticides, December 2, 2021) 'Thousands of residents in Houston, Texas are suing Union Pacific Railroad Company for contaminating their properties with highly hazardous creosote wood preservatives. One of these lawsuits comes from Latonya Payne, legal guardian of Corinthian Giles, a 13-year-old boy who died of leukemia after a five year battle with the disease. A recent report found that the community is in the midst of a childhood leukemia cancer cluster, with disease rates five times the national average. ...EPA is currently in the process of reauthorizing creosote use for another 15 years with the knowledge that it is virtually impossible to produce and use without causing contamination and poisoning. Creosote was used to treat and extend the life of railroad ties at a location in Houston’s Greater Fifth Ward up until 1984, but since that time a plume of contamination in the soil has slowly worked its way through the low-income, predominantly black community currently living near the old site..... In light of these “unique benefits,” the agency (EPA) did not even consider the viability of alternatives, such as steel, composites, and fiberglass that could replace the hazardous wood preservative process with non or less toxic materials.'

Facility planned for GTH would burn chemically-soaked railway ties to produce electricity. Neighbours concerned about possible environmental effects, says RM of Sherwood (CBC Investigates)  SNAP comment: Creosote is a registered pesticide used in treating wood in Canada. It is toxic and cancer-causing. Proper disposal of treated wood is a huge can of worms around the world as we keep producing more and there is no safe way of re-using, recycling or disposing. smoke is already known to be cancer-causing. When it is laced with additional cancer-causing chemicals, it is even more unacceptable. and upwind from a center of population? even more unacceptable. I don't know if anyone has used the term incinerator for this project, but most recent incinerator projects have been vehemently opposed because of the pollution they cause.

Creosote Health Effects (ATSDR, 2006) Several sections such as How a person can be exposed to creosote, Health Effects (including longer exposure to creosote vapors can irritate the lungs), Whether creosote exposure will make you sick, How creosote can affect children, Potential of creosote to cause cancer, Testing people for creosote exposure.

Creosote on wikipedia. "Health effects: According to the Agency for Toxic Substances and Disease Registry (ATSDR), eating food or drinking water contaminated with high levels of coal tar creosote may cause a burning in the mouth and throat, and stomach pains. ATSDR also states that brief direct contact with large amounts of coal tar creosote may result in a rash or severe irritation of the skin, chemical burns of the surfaces of the eyes, convulsions and mental confusion, kidney or liver problems, unconsciousness, and even death. Longer direct skin contact with low levels of creosote mixtures or their vapours can result in increased light sensitivity, damage to the cornea, and skin damage. Longer exposure to creosote vapours can cause irritation of the respiratory tract."  SNAP Comment: Note that there is no mention of exposure through smoke from burning creosote in this article. Also beware of studies showing no link to cancer in workers working with creosote. Always try to find out who sponsored the study. Also, cancer is now so widespread, it may be harder to detect link to a particular product.

How to use and dispose of wood impregnated with creosote (Finnish Safety and Chemicals Agency (Tukes), 2016) 'The use of creosote-impregnated timber indoors, in contact with food plants or animal feeds and in playgrounds and other outdoor recreational areas where repeated skin contact exposure is possible has been banned since 20 June 1996 (Government decision 1405/1995). The use of creosote-impregnated timber in garden furniture and toys has been prohibited since 30 June 2003 (Government decree 8/2003)...Creosote can cause skin, eye and respiratory irritation. It may also cause allergic skin reactions, particularly in sunlight...Since 2002 discarded creosote-impregnated wood has been regarded as hazardous waste. Therefore it must be taken to a hazardous waste collection point and must not be handed over to consumers. It may not be burned in households either.'

Meanwhile in the Ohio Environmental Protection Agency (2017) 'promotes recycling whenever possible and encourages homeowners with old railroad ties to find someone else that can use them. Railroad ties can be used to make retaining walls, parking lot bumpers, etc. Local organizations such as Habitat for Humanity may be able to utilize the railroad ties.' in Disposing of old railroad ties from my home. SNAP Comment: I believe that recycling is considered a viable option only because the problem of treated wood is so overwhelming that there are no easy solutions or disposal method.

Creosote Oil MSDS (Issue date 08-26-2011)  The product is described as a mixture with several CAS numbers. It also has 1.5% contaminants, many of which are, or suspected to be, cancer-causing. 

9. Creosote Physical & Chemical Properties

  1. Auto-ignition temperature 636.8 °F (336 °C)
  2. Decomposition temperature Not available.
  3. Percent volatile 475 g/l

10. Chemical Stability & Reactivity Information: 

  1. Conditions to avoid Heat, flames and sparks.
  2. Hazardous decomposition products: Aromatic hydrocarbons. Carbon oxides. Nitrogen oxides. Sulfur oxides. 
  3. Possibility of hazardous reactions: Hazardous polymerization does not occur.

13. Disposal Considerations: Dispose of this material and its container at hazardous or special waste collection point. Do not incinerate sealed containers. 

I have been informed that it is possible that turning creosote-treated timber into biochar may remove it but a google search on the topic brought nothing (Feb 2018) What has been said is that the carbon is sequestered in the biochar. However, the form in which it is sequestered has not been discussed, or whether it retains its toxicity in this form. 

Pentachlorophenol background documents

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Alternatives to penta treated poles 

15 November 2016 Power Poles Alternatives

Steel distribution poles poised for market gains The Stockholm Convention, a global environmental treaty, banned the use of pentachlorophenol for member countries in May 2015, giving the chemical a five-year phase-out period. One of the most common uses of the chemical was as a preservative for wooden utility poles.

Fact Sheet on Chemically Treated Wood Utility Poles (Beyond Pesticides, no date, I think 2002) SNAP Comment: Why put this here? Well, SaskPower will keep on installing more treated wood power poles in the coming months. The poles are treated with the cancer causing pesticide pentachlorophenol. Penta is a known persistent organic pollutant  (POP) which will be banned in 3 years because it is so dangerous to human health and the environment. Their line of defense to Radio-Canada is that penta is better than the pesticide (and toxic element) arsenic (PMRA label search-  May 2017-  indicates 10 historical and 10 registered products). The use of cancer-causing treated wood for power poles ignores available alternatives such as cement or steel poles or simply burying power lines.


Pentachlorophenol     Pesticides – Known Carcinogen (IARC 1) (Carex Canada - Surveillance of environmental and occupational exposures or cancer prevention) Pentachlorophenol is extremely toxic to humans from acute (short-term) ingestion and inhalation exposure... Rapid absorption of pentachlorophenol has been reported in rodents, monkeys, & humans following oral, dermal, or inhalation exposure...PCP binds to mitochondrial protein and inhibits mitochondrial ATP-ase activity. Thus, both the formation of ATP and the release of energy to the cell from the breakdown of ATP to ADP are prevented, etc...

PENTACHLOROPHENOL Canadian Soil Quality Guidelines for the Protection of Environmental and Human Health  1997    Recommandations canadiennes
pour la qualité des sols :Environnement et santé humaine PENTACHLOROPHÉNOL

3 March 2017 Canadian Environmental Law Association Pentachlorophenol Re: Comments and Recommendations to inform Canada’s position to the Conferences of the Parties (COP) to the Stockholm and Rotterdam Conventions April 24 – May 5, 2017 in Geneva, Switzerland. The following comments and recommendations focus on the Stockholm Convention on Persistent Organic Pollutants and the Rotterdam Convention on the Prior Informed Consent Procedure for Certain Hazardous Chemicals and Pesticides in International Trade. In 2015, Pentachlorophenol (PCP) was added to Annex A (elimination) with specific exemptions from COP9. However Canada has made no commitment to ratify PCP.

April 21, 2015 NGO Letter on HCBC CNand Pentachlorophenol Canada 'The (POPRC) determined that pentachlorophenol (PCP) meets scientific criteria as a POP for its persistence, bioaccumulation, and adverse effects and that it will, as a result of its long-range environmental transport, “lead to significant adverse human health and environmental effects such that global action is warranted.”'

18 November 2016 Utility Poles and the Threat to our Health by Giampa Law. The International Agency for Research on Cancer, part of the World Health Organization, has classified the chemical as Group 1, carcinogenic to humans. Penta has been linked to an increased risk of certain cancers-such as non-Hodgkin's lymphoma, kidney cancer and multiple myeloma-especially among sawmill and utility workers who have regular exposure to the chemically treated poles. People can be exposed to the chemical if it contaminates the soil, leaches into groundwater or moves through the air. But the risk of exposure is clear. A research paper published in January 2015 in the International Journal of Environment Research and Public Health found that penta had been "detected in air, soil, carpet dust, food, and hand wipes samples collected at U.S. homes and childcare centers" and that nearly all of the children in the study had been exposed to penta daily.

Updated: June 29, 2016 Alaska Arctic Indigenous  by Vi Waghiyi. This letter thanks for a reduction in Persistent Organic Pollutants (which include pentachlorophenol) which accumulate in Arctic and contaminate the food chain. "Persistent organic pollutants are chemicals that persist in the environment and bio-accumulate through the food web. They contaminate our human blood and breast milk without our consent, and are associated with a range of harmful health effects including learning and developmental disabilities, endocrine disorders, and cancers. Accumulation of POPs in northern latitudes is a well-documented phenomenon."

Pentachlorophenol (IPCS InChem)  
4.3 Occupationally exposed populations includes walking with bare feet through areas where PCP was sprayed, addition of PCP to cellulose products, such as starches and adhesives and industrial cooling towers and evaporative condensers. SNAP Comment: the last 2 exposures come from reuse of the treated poles. As skin exposure is so important, just touching a pole is enough for a person to absorb PCP. 9.2.2 Inhalation Virtually all workers exposed to airborne concentrations take up PCP through the lungs and skin. 9.2.3 Skin exposure In addition to airborne concentrations, workers who handle treated lumber or who maintain PCP-contaminated equipment are at risk pf absorption of PCP via the skin. They may absorb from 50% (based on urinary PCP levels) to 70% (based on serum levels) of their total PCP burden through their skin. also lists 7.2.5 Acceptable daily intake (ADI)

Pentachlorophenol (US National Library of Medicine, PubChem Open Chemistry Database)

Pentachlorophenol  RISK PROFILE OF PENTACHLOROPHENOL. Dossier prepared in support of a proposal of pentachlorophenol to be considered as a candidate for inclusion in the Annex I to the Protocol to the1979 Convention on Long-Range Transboundary Air Pollution on Persistent Organic Pollutants (LRTAP Protocol on POPs) (Institute of Environmental Protection) (Institute of Environmental Protection, Warsaw, May 2008)  SNAP Comment: Since then, pentachlorophenol had ben classified as a definite human carcinogen, and is due to be phased out internattionally in 2020 with possible exceptions. Good background document explaining aerial transport, half life, bioaccumulation, previous and current uses, environmental levels and bioavailability (section B.) socio-economic factors (section C.) including regulations, substitutes, 4. Factors relevant for utility line construction and maintenance affecting utility poles selection and 5. Importance of wooden utilty poles in the USA. Although energy-wise, wooden poles require significant less energy to produce, their safe disposal is an issue. The conclusion is "we recommend to include the pentachlorophenol on the POP’s list requiring harmonized international actions with the ultimate goal to ban PCP and its salts production and uses."

Pentachlorophenol poisoning. (Proudfoot AT. Toxicol Rev. 2003;22(1):3-11.)

Chapter E – Pentachlorophenol Pressure (PCPP) Wood Preservation Facilities    Chapitre E - Installations de préservation du bois au pentachlorophénol sous pression (PCPP) look for 3. Environmental Effects.

Treated Wood Disposal- mostly CCA treated

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Industrial Treated wood users Guidance Document (Environment Canada) An appaling document! First stating  "In general, treated wood originally used in industrial applications should not be re-used in the residential market. This includes uses such as landscaping timbers, used railway ties,and garden furniture. Further, the re-use of treated wood should be avoided in products which may become building materials for residential homes where there is potential for exposure of the residents to the treatment chemicals. This caveat excludes the registered use of CCA treated plywood for wood foundations." (7.3 Recommendation 8). Then presenting  7.4 National Strategy for the Management of Post-Use Preservative Treated Industrial Wood (adapted from Konasewich et al., 2001) which describes as good options the exact same things they say should not be done in 7.3: producing landscaping timbers, used railway ties and garden furniture out of pentachlorophenol treated poles and railroad ties, mixing chipped treated wood with other waste wood fibre in order to make a heavy dry felt paper product which is then used as a base for asphalt roofing shingles. The also advocate the option of  burning in industrial boilers and co-generation facilities, and one cement kiln which will not destroy the toxic chemicals and dioxins and help spread the pollutants far and wide. Option 5, Hazardous waste incinerators which used to be the proper way to handle these pollutants now do "not support the concept of sustainable development." Finally option 6:landfilling. During the year 2000, approximately 12% of railway ties and 13% of utility poles that were taken out of service were disposed of in landfills throughout Canada.

Disposal of Treated Wood (Jeffrey J. Morrell, Oregon State University, Corvallis, Oregon 97331, conference presentation). Looking at treated wood use and disposal challenges in the USA. "The chemicals in these products do not biodegrade and large quantities remain in the wood that is disposed. Finally, the user has little knowledge of what constitutes proper disposal." About power poles: "For decades, utilities disposed of used poles in a variety of simple ways including give-aways to adjacent landowners, donations to civic groups and when all else failed, leaving the cutup pole by the side of the road where it mysteriously disappeared."  SNAP Comment: This give away is part of what the treated wood industry calls "recycling".

Can making biochar out of creosote-treated wood destroy its toxicity?

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SNAP Comment: I have been informed that it is possible that turning creosote-treated timber into biochar may remove it but a google search on the topic brought nothing (Feb 2018) What has been said is that the carbon is sequestered in the biochar. However, the form in which it is sequestered has not been discussed, or whether it retains its toxicity in this form. 

It seems that my initial reaction may be correct as per the following. Translation of email from a biochar researcher, Dr (Hani Antoun, Ph. D, Professeur Retraité & Associé, Laval University, Feb. 17. 2018)

Biochar is produced by pyrolysis (a thermochemical decomposition of organic material at elevated temperatures (350 à 700°C) in the absence of oxygen).

Biochars differ in physico-chemical properties and their qualities are very different depending on biomass used, pyrolysis temperature and the speed at which the temperature is raised.

Biochar is used as a source of energy by industry, and the non toxic kinds can be used in agriculture. Testing of biochar toxicity in agriculture uses germination tests.

Whether pyrolysis will destroy pollutants or not depends on several factors:

  1. Is the pollutant organic (containing carbon) or not?
  2. What the decomposition temperature of the pollutant is
  3. At what temperature and speed does the pyrolysis occur
  4. What type of pyrolysis is used

more information on biochar at International Biochar Initiative

A quick (very incomplete) review of the literature quoted on this site indicates that studies have been done in using biochar to adsorb pesticides such as pentachlorophenol, 2,4-D and others. It has not been very effective in adsorbing some heavy metals. I have not yet found studies indicating that the process would destroy pesticides in general, or creosote in particular. However Creosote oil MSDS indicates the product should not be heated or burnt. Also, its decomposition temperature is not available, an important data to determine if the roduct can be broken down by pyrolysis.

Many pesticides are licensed in Canada for treating wood, including pentachlorophenol (utility poles), creosote (railroad ties) and CCA (Chromium Copper Arsenate) which was the most common wood preservative for home use and also used for utility poles. These three pesticides are or contain known cancer-causing agents. Pentachlorophenol is also an endocrine-disruptors. All three have been under review for decades by the US EPA and the PMRA.

As of 10 May 2017, there are still 2 commercial products containing pentachlorophenol registered in Canada, and 5 containing creosote.

Overview of Wood Preservative Chemicals (US EPA, 2022)    This article also lists current alternatives. 'Effective December 31, 2003, chromated arsenical manufacturers voluntarily canceled virtually all residential uses of CCA, and wood products treated with CCA are no longer used in most residential settings, including decks and children’s playsets. EPA has classified chromated arsenicals as restricted use products, for use only by certified pesticide applicators. It can be used to produce commercial wood poles, posts, shakes, shingles, permanent foundation support beams, pilings, and other wood  products permitted by approved labeling. Read more about CCA.'    When did they stop using arsenic in pressure treated wood in Canada?    Until 2004, wood was treated with chromated copper arsenate (CCA), a product containing arsenic. Both the U.S. and Canada banned it for residential use and recommended preventive measures for existing structures.  Since 2004, treated wood has been coated with alkaline copper quaternary (ACQ), copper azole (CA-B) or micronized copper azole (MCA).    Note that the colour (brown or green) of treated wood has no bearing on toxicity: it simply results from dyes added to the coating.  SNAP comment: I had not realized that the ban of CCA treated wood only applied to consumer products but that the commercial use still persists.

EPA Needs to End the Legacy of Toxic Wood Preservatives Now    reviews status and risks of pentachlorophenol, creosote and arsenical wood preservatives and call for action (US)(Beyond Pesticides, February 22, 2022) 'Regulation of toxic chemicals must recognize the reality that, “The cocktail of chemical pollution that pervades the planet now threatens the stability of global ecosystems upon which humanity depends,” as stated by The Guardian.'

EPA Proposes Cancellation of Highly Toxic Wood Preservative Pentachlorophenol (“Penta”)(Beyond Pesticides, March 9, 2021)   Last week, the Environmental Protection Agency (EPA) announced an interim decision to cancel of one of the most hazardous pesticides still used in the United States, pentachlorophenol (penta). Although long overdue, health advocates are hailing the agency’s action, taken due to significant risks to human health, the availability of alternatives, and the uncertain future of penta production. ...Although most uses of penta were eliminated in the 1980s, its application as a wood preservative remained.   Beyond Pesticides has extensive documentation on the history of penta production and regulation.linked to in this article.   SNAP Comment: As of 23 March 2021, there are still 2 commercial pentachlorophol products registered din Canada. SaskPower is still widely using penta-treated power poles and I suspect that penta is the product they use to retreat the poles to ensure a longer life. See Publications May 7, 2017 for Sask Power use and SNAP letter.

As the World Bans Highly Toxic Wood Preservative, Pentachlorophenol, a Low-Income U.S. Community May Be Home to the Last Production Plant  SNAP Comment: What will Canada and Saskatchewan do? Because of penta' s toxicity, we were no longer manufacturing it in Canada, but the quantities imported filled the gap. In 2017, SNAP answered Sask Power's 2017 Wood Pole Maintenance Program blog facebook poston its use of pentachlorophenol treated posts.    'UPDATE: The same day Beyond Pesticides published this piece, Gulbrandsen Chemicals announced it would drop its effort to produce pentachlorophenol in Orangeburg, SC, according to The State newspaper.    (Beyond Pesticides, March 10, 2020) Orangeburg, South Carolina may be the last place in the world to produce one of the most toxic pesticides known to humanity, pentachlorphenol. Despite a global ban on “penta” in 2016, in force in 186 countries, the United States has continued to import and use this hazardous wood preservative on telephone poles and railroad ties throughout the country.

Settlement Reached in Lawsuit Over Dioxin Contamination from Poison Poles in Central California  (Beyond Pesticides, September 14, 2018)   'The utility poles of concern were treated with the chemical pentachlorophenol, which is regulated as a pesticide by the U.S. Environmental Protection Agency (EPA), and is known to produce dioxin as a byproduct of its manufacture.'  SNAP Comment: Last summer, after an organic farmer contacted SNAP, we updated the treated wood page and have a subpage titled pentachlorophenol. A letter to SaskPower about their wide use of pentachlorophenol-treated utility poles resulted in no action on their part except a wide PR campaign on why they use them without mention of the health effects of penta. One of SaskPower's points was that the poles were 'reused/recycled' which they should not be because of their toxic nature. SNAP also posted irresponsble Government of Canada documents indicating the poles are no longer disposed off in incinerators for toxic products (apparently not good environmentally) but are being used for outdoor furniture and as fuel for some industries. They are also regularly given to groups for cuting and delineating parking lots or even to set up bird nesting platforms in water. I never even thought of the dioxin contamination... 

May 5, 2017 Answer to SaskPower's Wood Pole Maintenance Program blog post Sask Power's 2017 Wood Pole Maintenance Program blog post. SaskPower is going on with business as usual by replacing toxic posts with more toxic posts because that is what they have always done. The difference between then and now is that NOW, we KNOW about the health and environmental risks of pentachlorophenol. In 2015, penta was added to Annex A (elimination) of the Stockholm Convention on Persistent Organic Pollutants and, in three years, the chemical will be phased out. Poles are being planted now that are going to be giving off toxic penta for 50, 60 or 70 years to come. Is ths acceptable? Adding the cost of over $8000 of incinerating each post and the health and environmental costs to the purchase cost should make it obvious that new posts that SaskPower installs are either steel or concrete. Thanks to Yvonne for putting this issue on the map. Please tell SaskPower to install posts made of steel or concrete rather than pentachlorophenol treated ones, or bury lines. SNAP correction (10 May 2017): It appears I was wrong about disposal. Now incinerating toxic treated wood at high enough temperatures to destroy at least part of the toxic pollutants is no longer viewed as "support(ing) the concept of sustainable development."  It appears that, after stating that industrially treated wood should not be used in and around homes (1,  7.3 and 7.4), several Canadian companies are licensed to do just that producing garden furniture, fencing and landscape lumber.. Instead we also favour burning  penta (or PCP) treated wood for energy, therefore distributing the pollutants far and wide. It seems to me that sustainable development would require that we replace unsustainable toxic materials with new ones that are not so toxic...

Label Warning on Dangerous PCP-Treated Poles Deemed Unconstitutional (Beyond Pesticides, March 3, 2016) Last month, U.S. District Court Judge Arthur Spatt declared a dangerous wood preservative label ordinance unconstitutional, ending a three year battle between a New York town and Public Service Enterprise Group (PESG)...Because the utility poles are not intended to be sold to the public nor influence consumer behavior, PESG is not required to post “compelled warning signs” on their dangerous utility poles. Pentachlorophenol (PCP) is a recognized cancer-causing wood preservative. As of March 4, 2016, there are still 3 products registered in Canada for commercial use. It is commonly used for railroad ties and utility poles. I have not heard of any efforts to have a mandatory toxicity label in Canada.

International Treaty Bans Pentachlorophenol, U.S. Continues Use on Utility Poles and Railroad Ties (Beyond Pesticides, May 18, 2015) Delegates from more than 90 countries took the unprecedented step of voting last week for a global ban on pentachlorophenol (penta) – a proven toxic pesticide and contaminant found in wildlife and human biomonitoring studies worldwide. There are still 2 pentachlorophenol products registered in Canada as of June 2015. Posted in SNAP's treated wood

Treated Wood EPA and PMRA Reviews (June 17, 2008)  SNAP signed on to the following treated wood comments from Beyond Pesticides to the US EPA. It is relevant to do so as the products are under co-operative re-evaluation, and the US re-evaluations is poorly done. 

Beyond Pesticides comments to the U.S. EPA.  SNAP’s comments to the PMRA as well as an endorsement of the Beyond Pesticide comments to the PMRA.