Tips and Complaints

Tips and complaints related to continued production of wood treated for canceled uses of CCA after December 31, 2003 should be given the highest priority and investigated as soon as possible. In addition, inspections should be targeted at four or five of the largest wood treaters in each state, in order to establish an enforcement presence in the field. Other inspections of wood treatment facilities, lumberyards, and home centers should be incorporated into the normal inspection scheme.


Producer Establishment Inspections

Inspections should be conducted at CCA producing establishments, including distributor registrants, to ensure that the correct labeling is being placed on the product.


Wood Treatment Facility Inspections

Inspections of wood treatment facilities should determine if wood treatment products are being used in accordance with the new labeling reflecting the terms of the cancellation orders. As a general rule, treating dimensional lumber at 0.25 pounds per cubic foot (pcf) minimum retention rate for residential uses after December 31, 2003 is a violation of the cancellation order unless the product used to treat the wood was previously labeled existing stocks of a CCA product. There are a few non-residential uses at the 0.25 pcf rate, plywood (C9), wood for highway construction (C14), wood for marine construction (C18), structural glue laminated members (C28), and structural composite lumber (C33). Inspectors should also examine shipment records to determine what has occurred. The inspector should also examine shipment records to determine from where the wood may have been shipped. For instance, wood treated under C14, Wood for Highway Construction, probably would not be shipped by a wood treater to a home center; just as wood treated for marine use would not be shipped by a wood treater to a landlocked state and if either occurred, it should be investigated.

Dimensional lumber and fenceposts for residential uses treated at higher rates (0.40 pcf and above) are also canceled, however dimensional lumber for other uses treated at the same rates may be allowable depending on the use for which the wood is intended. Refer to the label and the AWPA Commodity Standards table in the OPP [EPA Office of Pesticide Programs] CCA guidance for more information.


Marketplace Inspections

Inspections may also be conducted at lumberyards and home centers to determine if lumber treated with CCA that appears to be for canceled uses (e.g., residential dimension lumber, etc.) is continuing to be delivered. Inspections at facilities that sell treated wood for consumer uses (e.g., lumberyards, home centers) should generally be conducted in conjunction with other pesticide inspections. In other words, with the exception of follow up on tips and complaints, if a routine inspection takes place at a home center, lumber yard or other facility, monitoring for compliance with the CCA provisions should also take place. If CCA treated lumber for cancelled uses is being offered for sale, records and invoices should be reviewed to determine the intended use, the origin of the lumber and any other information that would be useful in determining the compliance status of the wood and its treatment. Appropriate follow up at the wood treating facility or referral should be made.

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