Section 6: Wood Preservation

• 6.1 Introduction
• 6.2 Reporting Criteria
  • 6.2.1 20 000-hour Employee Threshold
• 6.3 Substances
  • 6.3.1 Schedule 1, Part 1, Substances
  • 6.3.2 Mercury (and its compounds)
  • 6.3.3 PAHs
  • 6.3.4 Dioxins/Furans and HCB
• 6.4 Further Information

Wood preservation refers to the preservation of wood using heat or pressure treatment, or both.

The Issue Table for the Wood Preservation Sector Strategic Options Process requested that reporting criteria agreed upon by industry and Environment Canada in the Strategic Options Process be implemented, using the NPRI as a reporting mechanism. Environment Canada is developing detailed guidance specific to wood-preservation facilities. The document, to be titled Guidance for Wood-Preservation Facilities Reporting to the National Pollutant Release Inventory, will provide a step-by-step methodology for estimating releases and transfers of NPRI substances from wood preservation facilities. The guide will outline how to estimate releases and transfers of several NPRI substances listed at alternate thresholds, including PAHs, dioxins/furans and HCB. The guide will be posted on the NPRI Web site at www.ec.gc.ca/pdb/npri in 2001.

Changes to the NPRI for the 2000 reporting year that are specific to the wood preservation sector are:

• removal of the 20 000-hour employee threshold for the activity of wood preservation (using heat or pressure treatment, or both) for all NPRI-listed substances
• reporting all on-site releases and off-site transfers of PAHs by facilities used for wood preservation using creosote, and
• reporting all on-site releases and off-site transfers of dioxins/furans and HCB by facilities used for wood preservation using pentachlorophenol.

The 20 000-hour employee threshold does not apply to a facility used for wood preservation. The decision to remove the employee threshold was based on the request from the Issue Table for the Wood Preservation Sector Strategic Options Process.

There are no reporting criteria for substances listed in Schedule 1, Part 1, of the 2000 Canada Gazette notice that are specific to the activity of wood preservation. The reporting criteria for these substances are explained in the Guide for Reporting.

There are no reporting criteria for mercury (and its compounds) that are specific to the activity of wood preservation. The reporting criteria for mercury (and its compounds) are explained in Chapter 3.

PAHs can constitute up to 90% of creosote and, for this reason, may be released or transferred from most activities using creosote.

If your facility was used for wood preservation using creosote, you must submit a report for each PAH that was released or transferred, regardless of the number of hours worked by employees and regardless of the quantity of PAHs released on site or transferred off site. This reporting requirement is found in Schedule 2, Part 3, of the 2000 Canada Gazette notice.

Environment Canada has determined that dioxins/furans and HCB are not likely to be incidentally manufactured as part of the activity of wood preservation. However, dioxins/furans and HCB are present as contaminants in pentachlorophenol used in the treatment of wood. For this reason, reporting is required by facilities used for wood preservation using pentachlorophenol.

If your facility was used for wood preservation using pentachlorophenol, you must submit a report for dioxins/furans and HCB, regardless of the number of hours worked by employees and regardless of the quantity of dioxins/furans and HCB released or transferred. This reporting requirement is found in Schedule 2, Part 4, of the 2000 Canada Gazette notice.

Note: If wood treated with pentachlorophenol is incinerated, this is considered hazardous waste incineration and on-site releases and off-site transfers of dioxins/furans and HCB from this activity must be reported.

Documents discussing releases and transfers from the activity of wood preservation are listed below. These documents can be downloaded from the Environment Canada Web site at www.ec.gc.ca/sop/display.cfm?sopID_n=12:

• Strategic Options for the Management of CEPA-Toxic Substances for the Wood-Preservation Sector, Volumes I, II, and III, and
• Recommendations for the Design and Operation of Wood-Preservation Facilities - jointly prepared by Environment Canada and the Canadian Institute of Treated Wood (CITW).

Guidance for Wood-Preservation Facilities Reporting to the National Pollutant Release Inventory will be posted on the NPRI Web site www.ec.gc.ca/pdb/npri when it is available in 2001.