Comments to the Consumer Products Safety Commission On Pressure-Treated Wood

My name is Jody Clarke. I am vice president of communications at the Competitive Enterprise Institute in Washington, D.C., but today I am here speaking to you as a mother and a concerned citizen.


I’m not only concerned that the federal government is considering a ban on a product that has been safely used for more than six decades; I think it’s absolutely outrageous. When people hear the word “arsenic,” it conjures up all kinds of images, and I think some groups are trying to use that to their advantage, even though exposure to it in pressure-treated wood, or water for that matter, is extremely small. You, and the Environmental Working Group, are scaring people—and it’s completely unnecessary.


As a mother, I am not worried about my son being exposed to the pressure-treated wood that our deck at home is made of, or the playground equipment in our neighborhood. If anything, I worry about my son falling and hurting himself, not about any phantom risks from a wood preservative.


Science writer Steve Milloy recently wrote a column about this issue, and he pointed out that, “There is not the slightest evidence that any child has ever developed cancer from CCA-treated wood.” He also pointed out that studies don’t show increased health risks for the workers at wood treatment plants and carpenters. If there’s a problem, shouldn’t we be seeing an increase of cancer in those groups of people? 


The increase in the risk of cancer that’s been calculated by the Consumer Products Safety Commission—your group—is incredibly small, so small that I find it unbelievable that any action would be taken to ban the product.


I’m sure you’re probably aware that studies have been done that show for young smokers who kick the habit by early adulthood, their risk of cancer returns to normal within a few years.[i]  It seems to me that would be the same case with children’s exposure to CCA-treated wood, and the exposure to that is far less than with smoking.


Groups that support a ban on pressure-treated wood say children are the victims. The real victims are going to be the families, or anyone, who will end up paying 20 to 30 percent more for decks made out of an alternative—and inferior—product, and the wood processors who will be affected by any ban. You could run some people out of business and I think it’s a shame.


Working at a public policy group, I probably do know more than the average person about this issue. But I am not a public policy analyst or a scientist; I am here simply as a citizen who is very concerned about what you might do regarding this issue. I’d like to end with that old adage that is so true: If it’s not broken, why fix it?


Thank you for listening.

[i] As Dr. Kenneth Brown points out in his comments to CPSC, a key factor in arsenic cancer risk is the long-term exposure. You can’t suggest that short-term exposure would produce the same result. It’s similar to the findings on tobacco smoke. For example, see: International Agency for Research on Cancer, 1986, IARC monographs on the evaluation of the carcinogenic risk of chemicals to man. V. 38, Tobacco Smoking. Lyon, France: IARC Sci. Pub. No. 88, available online at: