Comments and Reply: Treated Wood

A number of industry and association stakeholders commented on the proposed listing of treated wood in the proposed Regulations. These stakeholders requested that treated wood be removed from Schedule 3 and commented that:

Response: Treated wood destined for disposal or recycling is specifically listed in Schedule III of the current EIHWR. This is consistent with international agreements, as treated wood is listed under the OECD Decision, and can require control under the Basel Convention if it exhibits a hazard. Treated wood typically exhibits secondary hazards, such as environmental hazards (contaminated with listed environmental hazards at concentrations above 100 ppm) and, in some cases, leachate toxicity.

In CGI, Environment Canada proposed to regulate wood treated with a pest-control product registered under the Pest Control Products Act to clarify the current regulatory obligation.

Environment Canada agrees that this listing was broader in scope, and has removed treated wood from Schedule 3 of the proposed Regulations. Treated wood will be controlled under the proposed Regulations when it exhibits a hazardous characteristic as per the general definition of hazardous waste or hazardous recyclable material. This maintains the status quo with regard to the current EIHWR, and will not result in any additional costs.

Environment Canada is working with industry to develop compliance-promotion material to clarify regulatory obligations that may be associated with treated wood.