What is the GHS and what impact does it have on the South African wood preservative industry?
GHS stands for Globally Harmonised System of Classification and Labelling of Chemicals, which is outlined in the United Nations GHS Purple Book on chemical classification. The World Summit on Sustainable Development has encouraged countries to adopt the GHS as soon as possible.
The South African government is implementing the GHS, as was legislated by the Department of Labour in Regulations to the Occupational Health and Safety Act, which came into effect on 28 September 2022.
These Regulations oblige chemical manufacturers to reclassify their products and submit the new classifications to the Department of Agriculture, Land Reform and Rural Development.
Many within the industry are concerned because CCA is among the chemical products that fall into categories 1A and 1B, which are on the periphery of the GHS and could be phased out by the department on grounds of their alleged toxicity.
However, on August 3, 2022, the Registrar of the department sent a letter to the industry stating that they could allow the continuous use of products should they comply with an ‘exceptional circumstance’.
The research findings shows that Permacure CCA-treated timber should indeed be categorised as non-toxic based on bio-accessibility of the actives, as these falls well below the safety limits prescribed by the GHS criteria.
To shed clarity in the matter, Dolphin Bay asked the highly respected toxicologists and environmental scientists at Infotox to investigate whether timber treated with Permacure CCA should be one of these exceptions. Their research findings show that Permacure CCA-treated timber should indeed be treated as non-toxic, as it falls outside the periphery and well within the safety limits prescribed by the GHS based on its bio accessibility, because of the unique properties of CCA-treated timber.
Dolphin Bay and the industry have made this case in a submission to the department and believe it will not be disputed, as the department has indicated that its conclusions would be made in line with a 2010 policy document stating that sound scientific principles would be used to evaluate products.
The Infotox scientists concluded that CCA fixates and remains bound within the CCA-treated timber. In essence, CCA becomes a different product after fixation and cannot be evaluated according to its individual constituents.
Instead, it needs to be evaluated as a new compound, in combination with the timber.
Customers need to be aware that the fixation process is critical before timber can be dispatched. Dolphin Bay provides a fixation indicator which should be used to ensure that the fixation process has been completed before timber is dispatched.
The research showed that the Permacure CCA-treated wood did not classify as hazardous for any of the health endpoints considered in the GHS, and the scientists recommended that Permacure CCA-treated timber should be treated as an “extraordinary case.”
The scientists also addressed the misconception that CCA has been banned in the US and Europe. In both areas, the use of CCA was limited voluntarily under the “precautionary principle”. CCA-treated timber is commonly used in all parts of residential buildings in both Europe and North America, and the authorities in these areas have not issued instructions to remove CCA-treated wood structures already in residential use.
In addition, the EU’s REACH (Registration, Evaluation, Authorisation and Restriction of Chemicals) clearly states several applications for CCA-treated timber.
“The industry can feel confident that safety of CCA-treated timber has been proven by a substantial body of scientific research, including the study by Infotox,” said Bertus.
“The use of stainless steel is a good comparison. Evaluated by its constituent ingredients, it can be highly toxic. But the manufactured end product is a perfectly safe, acceptable material in homes and buildings, and is even used in medical applications.
“We are glad that these findings are coming to light and are confident that CCA is indeed an ‘exceptional circumstance.’”