2. Thedisadvantagesofcreosote

TheEuropeanCommission,viaECHA,andtheUnitedStates,viatheEPA,haveconductedand sharednumerousstudiesoncreosote.Theirconclusionsconvergeinall respects

2.1. Creosote,ahazardforpeople

Creosote is a mixture of several hundred compounds that belong to various groups of substances:

- polycyclicaromatic hydrocarbons(PAHs), whichcanmakeupto85% ofcreosote.

- phenols.

- heterocyclic compounds.

- aromatic amines

Many of these substances are toxic to humans, especially PAHs, which naturally make up coal, but are also produced by the incomplete combustion of fuels or wood.

The mostimportanttoxic PAHsfoundincreosote are:

- acenaphthene: usedasabasisforherbicides.

- acenaphthylene: usedasabasisforherbicidesandplastics.

- anthracene: used as a basis for insecticides and wood preservatives - classified as "PBT"(persistent, bioaccumulative andtoxic).

- benzanthracene:listedasacarcinogenbytheInternationalAgencyforResearchon Cancer (IARC).

- benzopyrene: persistent air pollutant, bioaccumulated by some marine animalsclassifiedas"VeryPBT".

- benzo[k]fluoranthene:carcinogenic substance highly toxic toaquatic organisms.

- fluoranthene: includedinthe IARClistofcarcinogens - classifiedas"Very PBT".

- fluorene: usedasabasisformanufacturingpesticidesandplastics.

- naphthalene: usedasabasisformanufacturinginsecticidesandresins.

- phenanthrene:oneofthepersistentorganicpollutants(POPs)-classifiedas"VeryPBT".

Due to its complex composition, the available studies on creosote are scientifically insufficienttoproveitseffectsonhumanhealth.Thecurrentliteratureavailableoncreosote ismainlybasedonstudies performedonitsmaincomponents.

The human health impacts proven for the components of creosote are assumed to be the same or similar for creosote. This generalization of the conclusions calls for caution. However, some further epidemiological studies conducted on workers regularly exposed to creosote have confirmedsome ofthe conclusionsreached.

Creosote,a carcinogenic,mutagenic,andreprotoxicproductthat posesrealdangers to humanhealth.

Creosoteisaskin,eye,andrespiratorytractirritant.

This characteristic, regularly seen in workers frequently in contact with creosote, has led, accordingtotheEuropeanCLPregulation,toclassifycreosoteasH315(causesskinirritation) andH319 (causeseye irritation).

Creosotecanbeamutagen.

This toxicity has been demonstrated on animals in proportions that vary depending on the typeofcreosote,theconcentrationlevels,andthefactorsrelatedtotheanimalsthemselves. It is scientifically difficultto reach a conclusion on this issue, butthere isa body of evidence thatleadsustobevery cautiousonthe subject

Creosoteisacarcinogen.

Animal studies have clearly shown an increase in skin cancer in proportions that are highly dependent on exposure. The "general public" literature reports a more extensive risk of cancersinvariousorgans(lungs, prostate, pancreas, throat, etc.)withoutclearevidence.

According to the European CLP regulation, creosote is therefore classified as a class 1B carcinogen (H350 probable carcinogen). This classification is based on a 2A carcinogenic classification by the IARC (limited evidence in humans but sufficient evidence in animals) and on a 1B classification by the EPA (presumption of carcinogenicity in humans based on evidence inanimals)

Creosoteisareproductivetoxicant.

Some studies have shown that creosote may affect early intrauterine fetal development and cause increased fetal deaths. The assessment made on creosote in Europe in 2021 as part of the CLP regulation recommends a classification of H361d (may cause harm to the fetus) asapointofconcern.

In addition, animal studies clearly show the impact of creosote on the offspring of the exposedgenerationwithfertilityproblemsandasignificantlyaffecteddevelopmentoftheir ownoffspring.

This leads to the same assessment as before, consisting in recommending a classification of creosote as H360F (may affect fertility) which points, this time, to impacts deemed to be ahazard.

There are three waysto beexposedtocreosote anditshealthimpacts:

-byingestingcreosote:thisriskisverylimited.Intakeviafoodinvolvesconcentrations toolow tobeconsidereddangerous.

- by breathing in volatile products contained in creosote: this risk exists during the production phases for workers close to the impregnation chambers for hot productionofcreosote-treatedpolesor,worse,close tothe dippingorsprayingareas for cold production.

- bycontactwithcreosote:thisriskexistsatallphasesofthelifeofthepolesandconcerns production agents as well as shippers, installers, and individuals responsible forrecycling

The assessmentmade byEuropein2021 1 concludedthat:

- the exposure of installers and workers brushing creosote-treated wood after it has beencutissufficienttocause concernaboutthe healthhazardsmentionedabove.

- the exposure of workers at impregnation plants is high and not acceptable without specific protective measures, especiallysince creosote has negative effectsonthe three components deemed the most dangerous and unacceptable: reprotoxicity, carcinogenicity, andmutagenicity.

Regulations tend to address public health issues in an increasingly urgent manner: the progressive banning of proven dangerous products such as creosote is a sign of this. This movementisdeveloping, firstandforemost, inthe mostdevelopedcountries

2.2. Creosote,invasivepollutant,ahazardfortheenvironment

Creosote is generally not very soluble in water but, because of its complex composition, it containssubstances thatare verysoluble inwaterandothersthatare veryvolatile

The polluting components of creosote are found in all biotic environments where life develops

The impact of creosote on the environment comes mainly from the polluting power of the PAHsitcontains

Inwater,PAHsincreosoteare,atbest,rapidlyphotolyzed(brokendownbylight).Duetolight attenuation in natural aquatic environments, the time required for photolysis of half the quantities (half-life2) of PAHs varies, depending on the PAHs, between one day and almost twoyears.

We find volatile PAHs in the air. While in the atmosphere, they are subjected to various degradation processes: mainly photolysis, secondarily reactions with the various oxidants presentintheatmosphereinagaseousstate.Underthesevariousinfluences,thehalf-lifeof PAHsinairvaries betweenone andsevenhours

Rainfall can cause PAHs in the air to spread to water and land, leading to traces of them being found on plants and animals, and consequently in our food. Since these compounds are not very hydrophilic, they are also found in sediments. PAHs are therefore pollutants, some ofwhichare persistent, thatcontaminate all environments

1 https://echa.europa.eu/documents/10162/fc41edcf-3732-2ba9-6a14-0fb9b423fd6c

2 The half-lifeisthe timeattheendofwhichonlyhalfoftheinitialproductremains,theotherhalf having disappearedasaresultofvariousdecompositionandtransformationmechanisms

The air emissions of eight PAHs of particular concern are subject to special monitoring; four of them are used in making creosote. Despite special efforts, emissions of these products in France have stagnated since 2010, reflecting our dependence on them

Creosotealsoposeshazardstosoil,water,andair.

Soil pollution is predominantly widespread and comes from deposits of PAHs in the air. It canalsoresultfrompointsource pollution.

Several stages in the life cycle of creosote-treated poles pose a risk of environmental pollution:

- whenapplyingthe producttothe wood.

- when handling treated wood, shipping it, installing it, and removing it by the various professionalsinthe chainofpersonsinvolved.

- whenusingtreatedwood,duetothediffusionofcreosoteinwater,theair,orthesoil.

- aswaste,whenthe userofthe treatedwoodmustdisposeofit.

Creosote, likemostinsecticidesandfungicides, isparticularlytoxic tomarine organisms.

Theregulationstendtobemoreandmorerestrictivewithregardtocontrollingandreducing the release oftoxic components