February 3, 2004
RE: Docket ID Number OPP-2003-0248
To Whom It May Concern:
We understand that the Environmental Protection Agency (EPA) is undertaking a review and a risk assessment valuation for the re-registration of creosote and related forms thereof. As our manufacturing company is a competitive product to wood crossties, we want to consider certain things in your study.
As you are well aware, the International Agency for Research on Cancer has determined that coal tar creosote is probably carcinogenic to humans. Various cancers, including but not limited to skin cancer and cancer of the scrotum, has been associated with long term exposure to this product.
The EPA needs to give the exposure to this carcinogenic a more significant review via animal studies or increases in human cancers for those who deal with creosote-soaked products. This last group is not limited to workers at the production facilities, but also, the workers who are members of track gangs who lay the wood ties and installers of wood telephone poles. The EPA needs to determine if these groups have any significant increase in the number of cancer incidents during or after exposure to creosote.
Creosote is primarily used as a wood preservative for wood crossties and telephone poles. With regards to the wood crossties, the EPA needs to realize that there are several alternatives to this product for use in track in the domestic railroads. In today’s environment, re-cycled steel crossties are now readily available to be used on our nation’s railways. Steel ties can perform, as they have in the UK and elsewhere in the world, at the same performance measures of the wood ties. Plus, steel ties can be re-cycled again after their useful life has ended (in 50-75 years), leaving no harmful pollutant residue in the soil to contaminate water sources and invade the food chain in some manner.
We realize that the EPA is only beginning its review. It should, however, move with speed to determine whether this product should be banned or not from use in our society.
Vice President – Finance