Chapter 5: Facilities, Supplies, Equipment, and Environmental Health
5.2 Quality of the Outdoor and Indoor Environment
5.2.9 Prevention and Management of Toxic Substances
184.108.40.206: Treatment of CCA Pressure-Treated Wood
Two coats of waterproof stain or sealant (e.g., semi-transparent stain, but not paint) should be applied at least once a year if it is oil-based, and twice a year if it is water-based - to all chromated copper arsenate (CCA)-treated surfaces (playground equipment, benches, decks, picnic tables) to which a child may have access. High-traffic areas may require more frequent treatments. Children should not be allowed to eat while playing on the equipment, and should be instructed to wash their hands after playing on CCA-treated surfaces. Cover picnic tables with a plastic coated (non-PVC) tablecloth; avoid contact of food and drink with CCA-treated wood. These precautions should be followed even if a protective coating has been applied to CCA treated wood (1,2).
Care must be used in the handling and maintenance of any CCA-treated wooden structures. For instance, burning CCA-treated wood will release arsenic into the air, and sanding or cutting CCA-treated wood will create toxic dust. Do not power wash or apply harsh cleaning products, such as bleach or acidic cleansers to CCA treated wood. Use a mild soap and water solution and disposable cleaning supplies. When disposing of items made of CCA-treated wood, they should be taken to a hazardous waste facility (1,2).
RATIONALEThe Consumer Product Safety Commission advises that arsenic exposure in children from contact with CCA-treated wood playground structures is estimated to be about 3.5 micrograms each day that includes a playground visit (3).The health effects related to arsenic include irritation of the stomach and intestines, birth or developmental effects, cancer, and infertility and miscarriages in women (1,3). Children can be exposed to the arsenic in CCA-treated wood by touching surfaces made from this material (3). Based on limited data, applying certain penetrating coatings may reduce the amount of arsenic that comes out of the wood (3).
The Safety Data Sheet (SDS) for every chemical product that the facility uses should be checked and available to anyone who uses or who might be exposed to the chemical in the child care facility to be sure that the chemical does not pose a risk to children and adults.
COMMENTSCCA-treated wood is found extensively in outdoor structures, furniture, and play equipment built prior to December 31, 2003 when manufacturers of CCA reached a voluntary agreement with the Environmental Protection Agency (EPA) to end the manufacture of CCA-treated wood for most consumer applications. EPA has indicated that some stocks of wood treated with CCA before this date might have been found on shelves until mid-2004. If a wooden structure was built prior to December 31, 2003 and is not of a rot-resistant type of wood (e.g., redwood, cedar) it is safe to assume it does contain arsenic. If the date the equipment was built is unknown or was built shortly after December 31, 2003, test kits are available from many common retailers.
While available data are very limited, some studies suggest that applying certain penetrating coatings (e.g., oil-based, semi-transparent stains) on a regular basis may reduce the migration of wood preservative chemicals from CCA-treated wood (4). In selecting a finish, caregivers/teachers should be aware that, in some cases, “film-forming” or non-penetrating stains on outdoor surfaces such as decks and fences are not recommended, as subsequent peeling and flaking may ultimately have an impact on durability as well as exposure to the preservatives in the wood.
To eliminate the risk of children’s exposure to arsenic from CCA-treated wood it is recommended it be replaced. If this is not feasible, replacing the components children come in contact with the most (e.g., handrails, retaining walls) will limit their exposure.
TYPE OF FACILITYCenter, Early Head Start, Head Start, Large Family Child Care Home, Small Family Child Care Home
RELATED STANDARDS220.127.116.11 Enclosures for Outdoor Play Areas
18.104.22.168 Play Equipment Requirements
22.214.171.124 Inspection of Indoor and Outdoor Play Areas and Equipment
Children’s Environmental Health Network. (March 2016). Chromated Copper Arsenate (CCA). Retrieved from http://www.cehn.org/our-work/eco-healthy-child-care/ehcc-faqs/cca/.
Gray, S., J. Houlihan. 2002. All hands on deck: Nationwide consumer testing of backyard decks and playsets shows high levels of arsenic on old wood. Washington, DC: Environmental Working Group. http://static.ewg.org/reports/2002/AllHandsOnDeck.pdf?_ga=1.104104071.62695211.145805821.
U.S. Consumer Product Safety Commission (CPSC). Fact sheet: Chromated copper arsenate (CCA)-treated wood used in playground equipment. http://www.cpsc.gov/PageFiles/122137/270.pdf.
U.S. Environmental Protection Agency. 2008. Chromated copper arsenate (CCA): Consumer advice related to CCA-treated wood. https://www.epa.gov/ingredients-used-pesticide-products/chromated-copper-arsenate-cca.
Content in the STANDARD was modified on 8/25/2016.