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PCPs: Crunch time for the timber industry

Terra Nova, August 1992
By Philippa Stevenson

PCP contamination of the Waipa timber mill near Rotorua is likely to be just the tip of a very dirty iceberg that no one wants melting in their back yard.

Mop up costs, it's been suggested, could force a large section of the timber industry to throw in the towel. And the outcome of investigations into this particular pollution problem is likely to impact on industries across New Zealand.

A Government task group inquiry into the results of 40 years' use of the toxic antisapstain chemical pentachlorophenol, PCP, at Waipa is being seen as the trendsetter for all historically contaminated sites, which a recent Ministry for the Environment report estimated number around 7000.

But if it is to be a model of things to come, Terra Nova inquiries into the workings of the task group show there is still much to learn about the process for managing this kind of pollution. There are indications that there have been some glaring omissions from the task group's brief, not the least being the human health effects of toxic chemical use.

The pollution at the Waipa mill, revealed in the National Task Group (NTG) report commissioned by the Ministry for Environment (MfE) and Department of Health, is similar to that found at US Superfund sites, according to environmental scientist Dr Beat Huser and Greenpeace.

Huser, Waikato Regional Council environmental quality senior scientist, says the Waipa site's pollution is definitely comparable with Superfund sites. And while the NTG's study of nearby Lake Rotorua was limited, Huser says the preliminary contamination level revealed in Lake Rotorua is "comparable with the Great Lakes and Manukau Harbour."

Greenpeace New Zealand has been advised by its British laboratory, which analysed the report figures, to call for a "Superfund-type treatment". Greenpeace said a contamination figure of 3.3 parts per million toxic equivalent logged for one part of Waipa was "huge".

Stacked up against some of the most contaminated sites in the world, "don't think yours aren't dirty. They are," advised the Greenpeace lab whose comment on Lake Rotorua was: "It's shocking to see this lake is more contaminated than the Rhine and Lake Ontario."

Superfund is the common name given to the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA), passed in 1980 and the first US federal law to deal with the dangers posed by the nation's abandoned and uncontrolled hazardous waste sites. A Superfund site is one on the National Priorities List (NPL), which qualifies it for long-term clean-up.

The NTG report on Waipa's contamination is damning in its own words. (See panel Report Summary).

Waipa owner, state-owned enterprise Forestry Corporation of New Zealand, in May pledged a $3 million clean up followed by a further $250,000 a year (for an unspecified term). But the clean-up requirements have yet to be determined and overseas information suggests that costs cannot be counted before the ground is broken, no matter how exhaustive preliminary studies. On average each US Superfund site costs $US26 million to clean up.

And several NTG members were angered by what they saw as a premature move by Forest Corp on the basis of the report which, at that stage, was still in draft form. The company's assurances that there was no risk to people consuming trout caught in Lake Rotorua galled some members, particularly as the report was quite unequivocal on that point. Only five fish were sampled and more investigation was needed to confirm PCP concentrations, it said.

Tom Rogers, Forest Corp forestry general manager, said the statement was made on the basis of the company's reading of the report and the pledged figure had been determined by staff in consultation with other experts. The company is in the process of selection qualified consultants to advise on how to clean up the 119ha site, he said.

But scientist and Iwi representative on the NTG, Ivor Te Whaiti believes the $3 million was "pre-conceived in the boardroom. It's based on Forest Corp's balance sheet," he said.

The United States Environmental Protection Agency (USEPA) says of polluted sites that "no matter how exhaustive preliminary studies may be, sampling and site observation simply cannot reveal the full extent of the problem at many sites."

"Uncertainties exist right up until the point where the ground is broken for the clean-up work and throughout the final clean-up process."

The NTG has heard suggestions that wholesale clean up of contaminated timber treatment sites would bankrupt all but the biggest New Zealand timber companies, and that up to 30 per cent of companies will go out of business rather than meet new environmental standards.

Occupational Safety and Health (OSH) scientist David Appleby, a member of the NTG and responsible for developing the new OSH code of practice for the safe use of timber preservatives and antisapstain chemicals in conjunction with industry, unions and other Government agencies, gave his view of the timber industry position in a June 21 memo to NTG members. The information came to Terra Nova via third party. Appleby wrote that the code requirements for the future standards of treatment plant operations were likely to conflict with the requirements that the NTG and regional councils were likely to impose on companies to clean up historical contamination.

"The code has the backing and support of the Timber Industry Federation, even though the code's mainly environmental provisions will be quite costly for many companies to implement over the three-year period provided for in the code. Industry sources acknowledge that between 25 and 30 per cent of treatment companies are expected to go out of business in preference to providing the capital required for compliance.

"It is far from clear whether the industry has the same commitment to the objectives of the NTG. After hearing a figure of $3 million described as probably inadequate to clean up the Waipa site to ANZEC (Australian and New Zealand Environmental Council) standards it would be understandable if industry became circumspect of the NTG goals. It is possible that many companies would be bankrupted by this level of expenditure leaving New Zealand under-represented in a key export industry and the state lumbered with the full responsibility for site remediation."

Te Whaiti said that the NTG had had reports which suggested that "the big companies will survive and the small ones will fall over."

Timber Industry Federation representative on the NTG, Mark de Bazin, however, said that the suggestions were nonsense.

"The results of the Waipa assessment indicate that it is a manageable problem. Waipa had by far the highest use of PCP and was selected to provide an indication of the worst case scenario for any one site. The problems associated with other industry sites will be significantly less.

"Waipa is one of only two sites I am aware of that used PCP in oil permanent preservative treatment on any scale at all. It is reasonable to assume that no other site has anywhere near the level of residual contamination."

On the matter of complying with the code at a cost of the demise of up to 30 per cent of treatment companies de Bazin said: "This suggestion is also nonsense. The industry has adopted a very responsible attitude to this matter, assisting in the development of the code of practice, and I have no doubt that the code has unanimous industry support."

But according to some members, the NTG and its goals have not always enjoyed industry support. The NTG was formed in December 1990 and first met in March 1991. A second meeting was held in April, but then things stalled because industry representatives were apparently unhappy with a newspaper report quoting NTG member and Health Department scientist Chris Shaw.

Wood Industries Union representative Anne Berghan told Terra Nova that the NTG "got off to a slow start because industry tried to get it stopped". The start of the Waipa study, scheduled for June, was delayed until September because the NTG did not meet again until July when industry representatives agreed to attend.

In a June 22, 1992, performance review of the NTG by member Dr Beat Huser, he noted the "unco-operative, at times even destructive attitude of industry hindering the effective initial progress of the task group (no provision so far of funding to support NTG tasks, embargo on proceeding with register)". The register is one for sites potentially contaminated with PCP and associated contaminants.

Though he added that as time went by the industry had become aware of the problems and had shown a more constructive approach, Huser also questioned the lack of funds for the NTG's work coming from the industry responsible for the pollution.

NTG chairman Howard Ellis said that so far the NTG has spent $278,000 on studies - $250,000 for the Waipa study, $16,000 on two DSIR studies and $12,000 on setting up the site register. That money has come from the budgets of MfE and the Health Department. Other costs incurred by NTG government department members have been covered by their own departments.

De Bazin denies the industry has been reluctant to attend NTG meetings or join the group. He said industry had financed the attendance, participation and background time of industry representatives. (Three out of 15 NTG members are from industry.)

"With regard to financial support it should be realised that this is a ministerial task force initiated, organised and controlled by the Ministry for the Environment for the Minister and reporting to the Minister. It was seen as appropriate that it be funded by the Minister and associated government departments," he said.

The industry's response to the "still inconclusive" debate about the environmental impact of PCP was to adopt "a responsible approach in 1988 when it voluntarily withdrew the chemical from use," de Bazin said.

"The action by our industry has placed us at a competitive disadvantage, both in terms of cost and effectiveness" relative to overseas competitors, he said.

However, Terra Nova understands that proposals for the 1992/93 working programme of the NTG indicate a considerable funding component by industry. De Bazin says he recently spent time in the USA to gain background perspective regarding PCP clean-up and Huser said that since the findings of the Waipa study the industry appears to be more committed.

How much more of a worst case the Waipa mill is compared to other sites has not been publicly acknowledged but Appleby's June 21 memo indicates the NTG may have some knowledge on the degree of contamination at other sites, possibly based on the amount of PCP used over the years.

Appleby suggests that, "as a means of achieving the best acceptable compromise between the code, NTG, and the ability of industry to pay" that the NTG "name the 10 to 15 sites (our emphasis) that may be contaminated to a similar degree to Waipa." He suggests concentrating "NTG resources here to develop the best affordable solution."

Carter Holt Harvey Timber Group's giant Kinleith Mill near Tokoroa, which it purchased from New Zealand Forest Products (NZFP), is another site likely to have significant contamination.

Though no longer used as a timber treatment plant Kinleith did use large amounts of PCP over many years (the mill began in 1953) and according to a March 1989 Waikato United Council survey a special waste area primarily "handles pentachlorophenol, and some sludge from timber treatment".

"A record is maintained of quantities disposed and final location," the WUC survey said.

A 1989 study team led by then NZFP environmental manager Dave Campin found levels of the dioxin, PCDD, and its closely related toxic furan cousin, PCDF, which were inconsistent with the effluent discharging from the bleached pulp plant. The study team concluded that PCP "may be a significant source of PCDDs and PCDFs ... and could account for 60 per cent of the NATO TE (toxic equivalent) input to the recipient (effluent) from the site."

NTG member Dr Don Hannah of DSIR (who was part of the Campin study team) said follow up studies were done but these, as Carter Holt Harvey (CHH) property, remain in the possession of the company. NTG chairman Howard Ellis said the studies would be very valuable to the group. Informal approaches had been made to the company, he said.

"We would hope to get to a situation where they could voluntarily provide information that would be helpful to a better understanding of the issue."

De Bazin of CHH Timber Group said apart from the Campin paper "the raw data has not been interpreted by CHH personnel and is therefore not in a form suitable for release. It was not a PCP study and would only be of academic interest to members of the task force with a specialist scientific background."

Waikato Regional Council's Huser said WRC would also like to have the data CHH has amassed on Kinleith.

"In recent years the company has undertaken intensive surveys of both the production process/treatment system and the receiving environment, in order to apply for a discharge permit to replace the current outdated consent. However, very little of this information is at present available to council, which has repeatedly requested this material."

Kinleith's effluent passes through a complex system of ponds to eventually discharge via the Kopakorahi Stream into Lake Maraetai, one of the hydro lakes on the Waikato River.

Little progress has been made by the NTG on identifying other potentially contaminated sites. One of the group's tasks when it began 18 months ago was to create a site register. Accomplished so far has been a report which details the likely sources of information which could pinpoint sawmills using treatment chemicals and the copying of the Timber Preservation Authority's files held by the Ministry of Forestry to a computer data base at the Ministry of Forestry. That makes for a list of about 630 sites which were registered with the TPA between 1955 and 1988 but would not identify all sites or those that had antisapstain dip operations alone (very likely using PCP) as registration was not required for these. Initial estimates put the number of contaminated sites at 800.

Early on the Wood Industries Union said it would make its records available but has never been asked for them, said Anne Berghan. The union maintains records on sawmill sites including their address and information about health and safety issues and chemicals used on site.

Berghan said present and former workers would also be able to identify waste disposal areas, something which appears not to have been addressed at all by the NTG.

Workers as an information resource or their potential to be victims of chemical poisoning have been totally ignored by the NTG, said Berghan.

It is something particularly worrying to Berghan and Te Whaiti. To Berghan because she and other union staff are bearing the brunt of worker concerns and calls for more information which they can only partially satisfy, and to Te Whaiti because the majority of the workers are Maori who, as a statistical group, suffer poor health.

Inquiries by Terra Nova indicate that events have conspired to remove the state of worker health from either the consideration of the NTG or other agencies responsible for human health.

Nine people (most on the NTG) responsible in some way for human health were questioned by Terra Nova about the issue. Of that number only two, Berghan and Te Whaiti, believed that worker health needed to be investigated.

Health Department scientist Chris Shaw said no study of the health of the public in relation to PCPs has been carried out. The reasons included prohibitive cost and the fact that those most likely to be affected, workers, had not been shown to be suffering adverse effects.

"Timber workers you would see as being the most highly exposed group and according to the Department of Labour they have not been able to see any significant adverse affect from the use of PCP. Now, if in the highly exposed group you can't see an effect, you are going to be even less likely to see an effect in a group that could be minimally exposed. So from the advice we have a study would probably tell us very little. It wouldn't confirm or deny any effect of chemical exposure. Also we do have funding limitations."

A similar response was given by de Bazin and Dr Sandy McQuire for the industry, Tom Rogers of Forest Corp and Dr John Gifford of the Ministry of Forestry and the Forest Research Institute. They all referred to OSH and company records which gave little indication of workers complaining of occupational afflictions which could be related to working with chemicals.

Appleby of OSH is largely responsible for the service's progress in pressing for better safety standards in the timber treatment industry. Three years ago he began writing the new code of practice which is expected to be approved and in use from this September. In the course of his work he has checked company and government records for indications of the state of worker health. What he found in those records is largely what other agencies have based their beliefs about worker health on. Company records showed few complaints and a three month old offer to the union to bring forward cases complete with medical records has not drawn a single response, he said.

However, former workers spoken to by Terra Nova who worked in the midst of the acknowledged most highly PCP contaminated area at Waipa, the Rueping plant, admitted to knowing little about the affects of PCP exposure and had seldom related any of a host of health problems they had experienced to working with chemicals. Neither, they said, had their own doctors or the company doctor. Most had preferred to go to their own GP.

They said questions they had raised about different health problems had been "brushed aside". Berghan believes that something else also conspired to keep the workers state of health from the record books. "They would take sick leave for dermatitis and skin diseases, go to the doctor and get some cream - instead of it being recognised and diagnosed as occupational dermatitis. Therefore ACC don't have records of past skin diseases, neither does the Health Department even though there is a requirement under the law that they must be notified.

"We've got to realise too that some of this was 15 years ago and people did not realise the affects of chemicals."

She said the union has cases of people diagnosed with chemical poisoning and is convinced worker health needs to be investigated. When Forest Corp made its May announcement about Waipa it set up a hotline and invited workers to call in if they had any worries. Nobody did. That also went on the official record as a sign that there were few worker health concerns.

Yet 75 workers - past, present, some from Waipa, some from other sites - rang the union in the few days following the announcement.

"They didn't trust the company. They rang us," said Berghan. The union set up a questionnaire to provide some uniformity to the information it received. Berghan said many of the workers were very worried. It was the first time many had spoken of things that distressed them deeply and, pressed for time and resources to deal with the concerns, she frequently felt at a loss.

The union is following up the issue, is getting workers tested and fully intends taking up Appleby's offer. But one worker who started the process has, believes Berghan, been disheartened by the response from OSH. He was written to in April by Appleby.

The letter read in part: I expect you know the main component of PCP antisapstain is sodium pentachlorophenate. This chemical can give rise to the sort of symptoms Anne has described, but since it is eliminated by the body quite rapidly, the symptoms will usually disappear within a week or so of exposure ceasing. Unfortunately the commercial PCP you worked with also contained trace impurities of dioxins and furans. If you were over-exposed to these impurities you could expect to experience long term symptoms similar to sodium pentachlorophenate plus also a very persistent skin rash known as chloracne.

While the appearance of chloracne is specific to dioxin poisoning, you should appreciate that the other feelings of unwellness, can also be caused by many other conditions unrelated to working with PCP. This can make diagnosis difficult.

If you are agreeable, OSH is interested in seeing copies of the blood tests and diagnoses you have received from the hospital and doctors that have examined you. At this stage I would not wish to raise your hopes that we can offer much assistance. This is because there is no known cure for illnesses caused by commercial grades of PCP.

Over a period of years any symptoms associated with the impurities in PCP antisapstain can be expected to gradually diminish as the body naturally eliminates the poisons.

Berghan is not surprised the worker has not proceeded with his case because he would have found its tone discouraging.

Appleby's experiences of the timber industry serve to show that exposure to chemicals was known and frequent.

A former chemical industry employee who "believed in the total containment of chemicals," Appleby said he was "horrified" when he first saw the state of play at timber treatment plants.

"Chemicals dripping on the soil, washed away into a stream. Workers just paddling around in it, smoking cigarettes."

He said he visited Waipa two years ago "when it was apparent there were major problems there". "I found there was no attention given to leaving timber on treatment pads to drip. It was being moved off the treatment pads wet and still dripping.

"They were not wearing equipment as recommended in the code of practice. They were getting the solutions on to their skin because they were wearing shorts and dragging the timber off the green chain across their waists. Although they were wearing gloves it was quite clear their stomachs were damp and there was all sorts of drippage going on their legs. It was clear that this was typical of the worker and management approach and I am sure it was exactly the same when PCP was used. We drew all these things to the management's attention at the time."

Appleby said the state of things was because "they had either been badly advised or the enforcement needed to be stronger".

The plant was then governed by an "old code of practice which did not cover the subject in as much detail as this (the new code). It was not a mandatory code in the sense that it had not been passed under section 51 of the Factory and Commercial Practices Act. It was basically a guidance note. That was in existence from `83.

"We had been concerned in OSH that the document had been largely disregarded and determined that we would produce another document which would have the full authority of law and that is this (new) one."

Tom Rogers of Forest Corp said it was his understanding that workers wear safety gear where required and that he was not aware of people wearing shorts and singlets as had been detailed in the Waipa study and by OSH. He said he was unsure what had been done in the past but people involved with chemicals now were trained and regulations are posted throughout the mill.

Forest Corp, along with the rest of the timber industry, became aware of the extent of problems with PCP with the release of the Cawthron Institute report on timber preservation chemicals in the New Zealand environment commissioned by the MfE and released in August 1990, Rogers said.

As far as worker health was concerned the Forest Service and subsequently Forest Corp was guided by the official health record. "We don't have any recorded instances of PCP-related illness and that type of thing and I guess there is a general lack of knowledge of that. That's our difficulty. We have nothing really to relate to in that area."

De Bazin said in Carter Holt Harvey's case the company regularly monitors employees' health and has not detected any untoward health problems as a result of exposure to timber treatment chemicals or any other aspects of the industry.

We have an ongoing commitment to this process and would obviously take appropriate action if health problems were detected."

Appleby believes former worker health is not good. "It's not wonderful but it is not necessarily all occupational reasons. They live fairly macho lives. They get into things and do things which they shouldn't, but that's their private lives.

"We know that they have had skin rashes or dermatitis through not wearing protective clothing. That was widely reported. It wasn't considered at the time particularly serious because as soon as workers ceased contact with the chemical the rashes improved. I am now beginning to hear from the union that some workers are being more seriously affected; so I have put this offer to the union people."

Berghan believes she is seeing a pattern emerge for timber workers that she has witnessed before. "It's the same pattern we went through for asbestos workers. It's a battle at the beginning to get it recognised that there is a problem, that workers' health has been affected. with PCP there has been very little research done. There's been nil.

"And people say if workers did not drink, smoke, have sex and got plenty of exercise their problems would go away. That's an assumption; They haven't actually looked at it. A lot of timber workers play sport, have good lifestyles."

And several NTG members noted that from an environmental and worker health point of view the issue of the cocktail of chemicals used at treatment plants has not been addressed.

The off-site environmental effects of the Waipa mill pollution have not been thoroughly addressed, nor has the possibility of off-site waste or PCP disposal sites as other areas of potential contamination been examined.

A study, described as a "preliminary, exploratory investigation of the first stage", of Lake Rotorua in which water and sediment samples, five trout and 40 freshwater mussels were examined is reported in the Waipa findings.

"If you look at those few (results) it makes you wonder what is going on in the lake because the levels are reasonably high, in fact the sediments samples are very high," said Conservation Department scientist Dr Chris Pugsley. "My main concern is that those findings get followed up."

PCP was only part of a much larger problem with toxic chemicals, he said. "You've got such a cocktail of chemicals coming out into the environment to actually say this chemical has caused these skin cancers on these fish is just not on."

USEPA notes that "information on the health and environmental effects of hazardous wastes comes mainly from laboratory studies of pure chemicals. There still is much to learn about the nature of the complex mixtures of wastes generally found at these sites, how they affect the environment, and how best to control them.

"Like the sites themselves, possible effects on human and environmental health span a broad spectrum. Adverse effects on people can range from minor physical irritation to serious health disorders. Such effects also can take the form of slowly degenerating health or of sudden serious damage. "Vegetables and livestock may become contaminated and enter the food chain."

Former Waipa workers who detailed their work practices told how, as qualified treatment plant operators, they worked with a range of different chemicals including PCP, copper chrome arsenate (CCA), boron and creosote.

Huser said in a memo to Ellis that a negative aspect of the NTG's work was that "no or insufficient consideration of issues concerning other chemicals used in the past or currently in use in the timber industry (chlordane, TBTO, CCA, creosote, new antisapstain chemicals), and hence justification for focusing on PCP/dioxin (is) somewhat arbitrary."

Also as yet unresolved by the NTG are the issues of who pays for a clean up and how future users of contaminated sites can be protected.

Berghan said the union was aware of some former treatment sites which are already being put to new uses, one as residential housing and another as a fertiliser depot.

Ellis said the MfE had commissioned the Crown Law Office to examine the legislation to see what could and could not be done under the Resource Management Act.

"We won't have that answer for several months. It's a very, very complex area which reaches to the heart of contaminated sites, not only timber treatment sites but anything that might have been contaminated by industrial use or for whatever reason.

"A recent study that the MFE had commissioned indicates that we probably have 7000 sites that are contaminated."

The timber industry would definitely not disappear under an avalanche of costs, Ellis said. "The timber industry is here to stay. They are regarded as an important export industry. It's one of a number of important New Zealand industries.

"New Zealand depends on having that marketing edge and the international perception of that edge is related to a clean and green country. And here we have an issue which is potentially contra-indicating that clean green image and it may well be that industry itself is prepared to bite the bullet of minimising environmental hazards on the basis of investing in a secure future.

"This issue could go two ways. This could either become a extremely tortuous and expensive litigation process in which lawyers will be making heaps and heaps of money or we can collectively work side by side in the process that the task group has initiated in order to ensure that whatever dollars are available actually go to solving the problem not lining lawyers pockets," said Ellis.

"We are aware that in the US the site contamination issue has become a big issue where litigation battles were fought out.

"Government is keen to solve this problem in a way that protects the environment, protects the health of people, protects workers and fixes the problem. I think if the industry and government cooperate that bit by bit, as rapidly as possible, we can solve the technical problems involved at minimum cost.

"I think that the experience we have gained from the risk assessment study at Waipa has been valuable and we are now at a phase of applying that. Both government and industry can learn, learn as we go and share resources."

And for future users of sites Ellis said: "Commonsense would say that if an area is contaminated this should be noted on the title; so that prospective buyers are aware that this particular site has a history. That's the commonsense approach and eventually we will get there."

Ellis said the public wouldn't get a say on the subject of PCP until next year when the issue of general liability for past contamination of sites - from whatever cause - will be considered. So while the heat may be on the timber treatment sites at present, there may be many more skeletons in the New Zealand cupboard yet to be found.

"We will be preparing an issues and options paper. It will be 1993 before we see that paper," he said.

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