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Playground
toxins
Take Action!
Making
Schools and Playgrounds Arsenic-Free
There are two major
things you can do to help make a difference in schools and playgrounds.
One is to encourage the officials in charge of those places to adopt a
policy to reduce risks of arsenic exposure (a model policy is included on
this page. With minor modifications, it could be made applicable to
playgrounds and parks not associated with schools). The other measure you
can take is to help make sure that arsenic risk assessments don’t get
ignored by the government (a sample letter is included on this page for
that purpose).
Model Policy for
Pressure-Treated Wood in Schools
POLICY ______:
Elimination of CCA-treated Wood
Because the health and
safety of students is one of our key priorities, and because a healthy
school environment is necessary for proper education and physical
development of children, ________________ School District works to prevent
arsenic exposure via pressure-treated wood structures on campus grounds,
with the ultimate goal being elimination of all structures constructed of
wood that has been treated with chromated copper arsenate (CCA).
WOOD SELECTION
No wood will be
purchased for use in indoor or outdoor structures (including but not
limited to playground equipment, tables and decking) that has been treated
with CCA. Furthermore, any such wood currently in inventory will not be
used for any future construction, and will be disposed of in an
environmentally sound manner at the earliest available opportunity.
WOOD MAINTENANCE
Any existing wooden
structures made of pressure-treated wood will be tested to determine if
they contain and/or are leaching arsenic residue. Any structures known or
subsequently found to contain/secrete CCA will be treated in the following
manner until such time as they can be replaced:
- Any
construction that will create debris or residue from pressure-treated
wood (including but not limited to: sawing, relocation or removal)
will be conducted at times when children are not present, so that
children are neither in the vicinity of exposed arsenic-treated wood
nor its dust. All sawdust and other residue from such activities will
be cleaned up prior to return of students to the area.
- Wooden
structures known to be arsenic-treated will be sealed with a double
coat of nontoxic, nonslippery wood sealant, such as an oil-based
stain. This will be done at least once every year until such time as
those structures are replaced.
- If
sealed CCA-treated wood develops cracks that expose the interior of
the wood, those affected surfaces will be treated immediately with a
double coat of wood sealant.
- Any
pressure-treated wood containing CCA that has visible signs of
crystallization or resin on its exterior will be removed and replaced
immediately.
WOOD REPLACEMENT
Existing structures
that have CCA-treated wood will be replaced as soon as it is possible to
do so, both in terms of budgetary ability and safe removal when children
are not present. Such structures will be replaced with products that do
not contain CCA. This may include non-pressure-treated wood such as
redwood or cedar. Other safe materials that can be used to replace
pressure-treated will include painted metal or recycled plastic.
PARENTAL NOTIFICATION
AND EDUCATIONAL EFFORTS
Parents of children
enrolled in the district’s schools will be notified if CCA-treated wood
in on the campus, and which such wooden structures contain CCA-treated
materials. Furthermore, parents, students and staff will be educated about
ways to avoid exposure/ingestion of arsenic from pressure-treated wood and
ways to identify wood that might pose a danger.
Also, parents will be
notified in advance of any efforts that will cause release of dust or
other debris related to CCA-treated wood, including but not limited to
maintenance work and removal of said structures. Such notification is to
occur at least 48 hours before commencement of such activities, and signs
will be posted in the area warning of the work at least 48 hours in
advance. Signs will remain in place for at least two weeks thereafter to
warn of possible risks of arsenic exposure.
RECORD KEEPING AND
PROGRESS REVIEWS
The district will
maintain complete records of the location of all CCA-treated wood
structures and dates of any maintenance, relocation or removal of such
structures. Such records will be publicly available to all parents of
students in the district. The district will provide, at least annually, a
report on the progress of removing and replacing CCA-treated wooden
structures.
RIGHT TO APPEAL
Parents, staff, and
neighbors may appeal maintenance and removal efforts related to CCA-treated
wooden structures. Notification of this right will be provided at the
beginning of the school year, as well as with any additional notification
of a particular planned activity regarding CCA-treated wood during the
school year. All appeals received up to three days prior to the planned
pesticide application will be considered by the appropriate school or
district committee overseeing such activity. Appeals received within three
days prior to the application will be considered by the superintendent.
IDENTIFICATION AND
NOTIFICATION OF SENSITIVE INDIVIDUALS
The district will
maintain a registry of chemically-sensitive students, staff, or others
requesting special consideration with regard to CCA-treated wood. The
district will provide personal notification to such individuals two weeks
prior to any planned CCA-wood-related activities. In addition, the
district will make any reasonable efforts to address their concerns and
special needs relative to CCA-treated wood, including but not limited to
exemption from activities that would put them in direct contact with CCA-treated
wood.
Ensure That Risk
Assessments Are Not Neglected
A joint effort in
conjunction with Environmental Working Group
and Healthy Building Network yielded 20,000 letters to
retailers—a huge percentage of them from Generation Green members and
supporters. That helped lead to the phase-out plan for CCA-treated wood.
So, your opinions can make a difference with big business and government
officials.
By continuing to make
our opinions felt, we can make sure that the lumber industry and EPA
don’t sweep risk assessments of arsenic-treated wood under the rug in
the midst of good feelings about the phase-out. Arsenic-laden
pressure-treated wood sold before the agreement is still out there, and it
will still be there when the phase-out is complete.
We need to quantify
what kind of risk that wood poses to our families, and we need to know how
best to dispose of CCA-treated materials. So we need a thorough risk
assessment. We need to keep the pressure the EPA to follow through with
these assessments, which Generation Green and allied organizations have
been insisting on for years.
Below is a sample
letter for you to send to EPA Administrator Christine Todd Whitman. Or, if
you prefer, you can write your own. Either way, you can reach Whitman at:
Christine
Todd Whitman, Administrator
U.S.
Environmental Protection Agency
1101A
USEPA
Headquarters
Ariel
Rios Building
1200
Pennsylvania Avenue, N.W.
Washington,
DC 20460
If you would prefer
to send your comments to her via e-mail, you can do so via: Whitman.Christine@epamail.epa.gov
SAMPLE LETTER
Dear Administrator
Whitman:
I am writing for two
reasons. One is to thank you and the efforts of your agency to mandate a
phase out of the use of CCA-treated wood. The nation will be a safer place
for our children without it.
The second reason is
to remind you that with all the contaminated wood that is still out there,
we need a thorough CCA risk assessment by the EPA, so that we know what
threats we still face. Also, we need measures to ensure that
arsenic-treated wood is disposed of safely.
The lumber industry
caught a huge break in 1984 when it was allowed to use arsenic in wood.
Please don’t allow the opportunity to conduct a full risk assessment
slip by in the new millennium..
Sincerely,
Your
Name
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