AWPA Penta Re-Affirmation Data Package For AWPA Standards P8.1 and P35-08 April 9, 2010 By Mike H. Freeman INDEPENDENT WOOD SCIENTIST Project Sponsor: KMG-Bernuth and KMG Chemicals Houston, TX Executive Summary In 2009, the AWPA Sub-Committee P-3 formed a Task Force for the Re- Affirmation of Pentachlorophenol (Penta or PCP) in the AWPA Book of Standards. This Task Force was chaired by Mike Freeman and contained the following TF membership: Mike Freeman (Chair) Dick Jackson John Falcone Less Lonning Denny Morgan Rick Blesky Darryl Smith Jim Brient John Wilkinson The charge of the TF was to Re-Affirm penta in the AWPA BoS utilizing AWPA Appendix I as a Guideline. The following is a summary of the Task Force findings: Review Existing Standard The Standard for penta in the AWPA BoS has historically been listed as Standard P8 section 1. In 2007, Freeman and Jung re-formatted the wood preservatives into the new Preservative Standard format and issued it for publication to Colin McCown, as AWPA Executive Vice President, which included a DRAFT watermark until final review and re-affirmation. This Standard has been reviewed and is now ready for full publication as AWPA Standard P-35, after removing the DRAFT watermark. AWPA Standard P8.1 is also adequate, but it is the Task Forces understanding, this Standard will soon be retired and archived under the AWPA System, much like the Use Category System replaced the Commodity Standards. The Task Force suggests both standards be re-affirmed until all P-8 Standardized wood preservatives are archived. Efficacy Data and Reports A complete efficacy review is attached to this Data Package and covers over six decades of testing and evaluation of penta as a wood preservative. Additionally, attached as under Appendix I to this Data Package, are the following documents: Freeman, et al, 2005. This study is report on the 53-year exposure of penta treated wood pole stubs in southern Mississippi (AWPA Hazard Zone 5). This report and study indicates that wood treated to 0.30 PCF penta in # 2 Fuel oil has an estimated service life in AWPA Hazard Zone 5 of 74 years. It should be noted that this retention is far below the current AWPA recommendation for wood utility poles in this hazard zone. Nicholas and Freeman, 2000. Is a Summary of over 11 years of laboratory and field testing by the authors, funded by EPRI, of penta in different carrier systems, which was also comparing these systems to penta alternatives. This study indicates that the carrier systems themselves are not particularly effective in ¾ inch stakes, but have some influence on the efficacy of the dissolved biocide in those same carrier oils. Blew, et al, 1957, indicates that from his work at the USDA-FPL, penta is an effective biocide against Formosan Subterranean Termite attack and long term exposure to both native termites and Hazard Zone 4 & 5 decay conditions. Product Performance There have been no widespread failures of penta treated wood products in service, other than Cellon treated wood poles, failing to Soft Rot. Annually, sparse penta pole failures are noted by utilities, but investigation into many of these indicate either poor initial treatment, or a lack of a periodic inspection and maintenance and remedial treatment program. MSDS’s and US EPA Product Labels Currently, only one basic manufacturer is registered by the US EPA to sell and market penta into the USA. This company, KMG-Bernuth, a/k/a KMG Chemicals, maintains multiple EPA Restricted Use Pesticide labels with the US EPA. Penta has just recently undergone an extensive seven-year Re-registration program with the US EPA and Industry and the RED has been issued. Penta will continue to be registered by the US EPA for its intended purposes as a wood preservative. Example US EPA labels and Product MSDS’s are attached under Appendix II. Extension of Exposure Conditions Penta has been widely tested for use in wooden crossties for decades. Formerly, the work by Forintek Scientist Krzyzewski indicated both penta and copper Naphthenate were suitable crosstie preservatives for either creosote or creosote- petroleum solutions. In Fall 2009, the AWPA received specific proposals for penta in specialized petroleum solvent mixtures for the treatment of crossties. This new carrier system met the minimal requirements as established in the AWPA Standard P9-Type A, but also has additional favorable properties to extend wooden crosstie service life. This new system should be contained in the upcoming AWPA BoS. Re-Affirmation Support Letters and comments from wood treaters and wood preserving plants have been received in support of the re-affirmation of penta by the AWPA. Letters of support for the re-affirmation of penta by consumers and users of penta treated wood products have also been received. The TF chair has received no negative comments from any party, Task Force member, treater, or utility, which do not support the re-affirmation of penta in the AWPA Annual Bos. These are attached under Appendix III. Summary and Closing Remarks Currently in the USA, roughly 16.5 millions pound of technical penta is used annually to produce over 2 million wooden utility poles. Penta treated wooden poles make up roughly 53-55 % of the treated wood pole market in N. America according to surveys by Freeman (2009), Vlosky (2006), and Vlosky and Shupe (2007). It is the unanimous recommendation by the current AWPA Penta Task Force that penta be re-affirmed by the AWPA and continued to be listed in the AWPA Annual Book of Standards. PENTACHLOROPHENOL : A Comprehensive Review of Its Efficacy and As A Wood Preservative By Mike. H. Freeman Independent Wood Scientist Memphis, TN Corresponding Author: [email protected] ABSTRACT Pentachlorophenol used since the 1930’s was rated the least expensive of the three major preservatives at least before rising cost of petroleum. Before 1987 penta was registered as a herbicide, defoliant, molluskicide, mossicide, and disinfectant. Depending upon the reporting country, the number of abandoned use patterns for penta ranges from all uses to few uses. This paper reviews the properties of penta, its efficacy compared to that of older preservatives such as creosote and chromated copper arsenates, and newer ones such as copper naphthenate. It also reviews the factors that affect the efficacy of penta and more especially its performance in oil-borne carriers. The performance of penta and the properties of the treated wood are influenced by the properties of the solvent used. Knowledge of the toxicology of penta has contributed to it being the most documented substance in wood preservation. This paper also briefly reviews the EPA reregistration of penta which showed that use in pressure treatment of wood did not pose an unacceptable risk to man or the environment . Today penta remains the main wood preservative used for utility poles in N. America with almost 55% of all poles being produced, utilizing penta in P9-Type A oil as their preservative system. 1 PCP INTRODUCTION Pentachlorophenol, also known as penta or PCP, had its wood preserving properties discovered in the 1930s and the production for wood preserving began on an experimental basis then. Trade names include: Forpen®, Penta®, Pentacon®, Penwar®. Penta is a standardized oil-borne preservative listed in the AWPA Book of Standards under P8-1. Principal use in the United-States and Canada is now the pressure-treatment of railroad ties, posts, cross arms, utility poles, and wharf pilings. Penta extends the functional life of wood by at least eight times (Wilkinson 1995; Fishel 2005). It is dissolved in petroleum or other organic solvents to allow adequate wood penetration. Pure penta exists as colorless crystals with a sharp phenolic smell when hot but little odor at room temperature. Impure penta is dark gray to brown and exists as dust, beads, or flakes. The sodium salt dissolves easily in water, but penta itself does not. The two forms have different physical properties, but are expected have similar toxic effects (ATSDR 2001). Treated wood typically contains about 130-140 (cid:0)g/m3 penta corresponding to concentrations of 0,484 mmol/L in treated wood (Pohleven and Boh 2007). Advantages of penta are that it can be dissolved in oils having a wide range of viscosity, vapor pressure and color, and it is clean and easy to handle and use. It is highly effective against wood destroying organisms. In terms of cost, it is rated the least expensive of the three major preservatives (Hatcher 1980) at least before rising cost of petroleum. Due to continual increase in petroleum costs and possible reduced availability of petroleum in the future there has been need to find treating processes which will keep the industry competitive and profitable in the face of competition from other materials (Hatcher 1980). PHYSICAL AND CHEMICAL PROPERTIES The physical/chemical properties of penta are well characterized (Table 1). It is freely soluble in organic solvents, slightly soluble in cold petroleum ether, carbon tetrachloride and paraffins and is inflammable. Technical penta used in wood preservation contains toxic impurities. Those of regulatory concern penta’s microcontaminants (FAO 1996). 2 Table 1. Physicochemical properties of penta (WHO 1987) Property Value value Physical state Light tan to white needle-like crystals. Crystalline, aromatic compound Water solubility (at 20°C) 14 mg/litre (pH 5), 2 g/litre (pH 7), 8 g/litre (pH 8) Log octanol–water partition 3.56 (pH 6.5) coefficient 3.32 (pH 7.2) Melting point 191ºC (anhydrous), 174ºC (monohydrous). Vapour pressure 2 × 10-6 kPa at 20°C Boiling point 309-310°C (decomposition) Density 1.987 g/cm3 pKa 4.7 at 25°C HISTORY The wood preserving properties of penta were discovered in the 1930s. Water-repellent solutions containing penta in solvents of the mineral spirits type, were first used in commercial dip treatments of wood by the millwork industry in1931. Commercial pressure treatment of poles with penta in heavy petroleum oils began in 1941, and considerable quantities of various products soon were pressure treated. Penta became a restricted-use pesticide in 1987 and is only available to certified applicators. It now has no registered residential uses (Fishel 2005; EPA 2008). Before the 1987 Federal register notice that canceled and restricted certain uses, penta was registered as a herbicide, defoliant, mossicide, and as a disinfectant. It was then one of the most widely used biocides (EPA 2007). In 1947 nearly 3,200 metric tons of penta was reported to have been used in the U.S. by the wood preserving industry. As of 2002, about 11 million pounds of penta was produced. It may not be used in residential, industrial, or commercial interiors except for laminated beams or building components in ground contact and where two coats of sealer are applied. It may not be used in farm buildings where there may be contact with animals or in beehives. 3 Because penta was used for a wide range of domestic, agricultural, and industrial purposes for more than 60 years, the compound is ubiquitously distributed in the environment (Pohleven and Boh 2007). Its occurrence in aquatic and terrestrial food chains has been established (Fishel 2005). Penta continues to be used but depending upon the reporting country, the number of banned uses ranges from all uses to few uses. Most reporting countries banned residential indoor uses. Austria, India, Indonesia, New Zealand, Sweden and Switzerland have reported a total ban (FAO 1996). In 1997 the manufacturers of penta voluntarily removed groundline/remedial treatment applications from the U.S. EPA registered labels for the product. All non-pressure and non- thermal treatment uses (i.e., spray uses) were deleted from the registrants' labels since 2004. This action left only pressure and thermal treatments with penta. Non-pressure/non- thermal treatments generally lead to higher applicator exposures. MODE OF ACTION Penta is toxic to all forms of life because it is an inhibitor of oxidative phosphorylation. Often used in combination with an insecticide, penta/NaPCP at low concentrations causes significant uncoupling of oxidation and phosphorylation cycles in tissues. At high concentrations it inhibits mitochondrial and myosin adenosine triphosphatase, inhibits glycolytic phosphorylation, inactivates respiratory enzymes and causes gross damage to mitochondria (Ozanne 1995). This results in accelerated aerobic metabolism and increasing heat production. It also causes loss of membrane electrical resistance (FAO 1996). PRODUCTION AND USE Penta is produced by the stepwise chlorination of phenol in the presence anhydrous aluminum or ferric chloride catalyst at 191°C. Outside of the United States, it is also produced by the alkaline hydrolysis of hexachlorobenzene. Because the production process is incomplete, commercial grade penta is 84-90% pure. Several contaminants including other polychlorinated phenols, polychlorinated dibenzo-p-dioxins and polychlorinated dibenzofurans are produced too. 4 Production volumes steadily decreased from 45 million pounds in 1983 to 9.1 million pounds in 1996 (IARC 1999). Up to 2004, Vulcan Chemicals, a division of Vulcan Materials Co. was the only domestic manufacturer of penta. Production volumes declined due to restriction in uses. From 1983–1986 it declined as follows: 42 million pounds in 1984; 38 million pounds in 1985; and 32 million pounds in 1986 and about 24 million pounds were manufactured in 1987. In 2004, Vulcan Materials sold the assets of its Vulcan Chemicals, to Basic Chemical Co. LLC, a subsidiary of Occidental Chemical Corporation but decided against entering the penta business (vulcanmaterials.com). In 2005, KMG Chemicals, Inc. a global provider of specialty chemicals acquired assets used in the manufacture and sale of penta from Occidental Chemical Corporation. The equipment was used to back-up KMG's then existing penta plant, thereby assuring security of supply for penta. KMG had acquired the original penta distribution business in 1984 and built a penta manufacturing plant in Matamoros, Mexico in 1986. KMG is currently the only producer of penta in North America. Penta revenues were projected to increase by over $3 million per year. Demand for penta and creosote was near record levels during fiscal 2007, driven by continued strong demand for utility poles and rail ties. KMG’s penta revenues increased 2% to $28.4 million as compared to fiscal 2006. The Railway Tie Association forecasted demand for rail ties to be relatively flat in 2008 and KMG anticipated the same for utility pole demand. The company's penta products include penta blocks, solutions of penta concentrate, and byproduct hydrochloric acid manufactured at its Matamoros, Mexico and Tuscaloosa, Alabama facilities( Alabama is only a formulating plant only). In the U.S., the company sells penta primarily in Alabama, Arkansas, Georgia, Louisiana, Mississippi and Missouri. The penta segment constituted 17% of the company's net sales in fiscal 2008 and the creosote segment constituted 36% of the company's net sales in fiscal 2008. STANDARDS AND SOLVENTS FOR PENTA The standard AWPA P8 defines the properties of penta wood preservative. Penta solutions for wood preservation shall contain not less than 95% chlorinated phenols, as determined by titration of the hydroxyl group and calculated as pentachlorophenol. The performance of penta and the properties of the treated wood are influenced by the properties of the solvent 5 used (Ibach 1999). AWPA P9 standard defines solvents and formulations for organic preservative systems. i. AWPA P9- Hydrocarbon solvent Type A- The heavy petroleum solvent included in P9-A is preferable when the wood is used in ground contact and for bridge applications. The solvents are petroleum oils and hydrocarbon solvents (No. 2 diesel, and blends of diesel oils with auxiliary solvents that are intended to stay in the wood due to the high boiling characteristics. The heavy oils remain in the wood for a long time but do not usually provide a clean or paintable surface. They are designed to provide permanent penta solvency in wood and physical properties that will minimize the depletion rate of penta from wood. ii. AWPA P9- Hydrocarbon solvent Type B- Consists of a highly volatile carrier system such as LPG, isopropyl ether, or butane with sufficient penta solvency. The carrier must be removed in the cylinder or the preservative will migrate to the surface and be lost after treatment. Hence the vapor pressure of the carrier must be extremely high at ambient temperature. Butane leaves a clean surface. A commercial process using penta/LPG was introduced in 1961, but its field performance was found inferior thus it is no longer used. Type D is similar to B. iii. AWPA P9- Hydrocarbon solvent Type C- A system of light naphtha (mineral oils or VMP naphtha) with a high-boiling and non-water soluble high viscousity auxillary solvent with ability to dissolve nearly its own weight of penta. It is used when treating glulam before gluing. These co-solvents must have ability to prevent migration and blooming as the light carrier solvent evaporates and migrates to the surface. The light naphtha may be either recovered in the cylinder by a solvent recovery process or left to evaporate from the wood. iv. AWPA P9- Hydrocarbon solvent Type E-This is an oil dispersion in water. It is only approved for aboveground use in lumber, bridge ties, mine ties, and plywood (Ibach 1999). 6
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