European Commission – DG Environment

Unit B.3 Creosote Consultation Dr.M.Marmetschke

BU 9 – 06/129 Ulmenweg 1

D – 29386Hankensbüttel

Germany

B – 1049 Brusselstel.: 0049-(0)5832 / 979466

Belgium

06.06.2008

Creosote Stakeholder Consultation on Creosotes

Dear Commission,

dear Sirs,

according to your requested consultation through all stakeholders concerning the use of creosotes in the EU within the Annex I to directive 98/8/EC, I herewith send you my report for a further use and support of creosotes and creosote treated safe commodities. Further data will follow within this month for your evaluation.

Apart from the wide spectrum of use within ground or water contact and for timbers for heavy duty purpose, a final reduction for creosotes and/or creosoted commodities would have an enormous negative impact to industry. Not only job losses all over Europewithin this particular industry as a negative consequence, but also on its technology which would be lost forever. This treatment technology is a valuable industrial resource which can be changed to modify the technology in general.

During the last decade, the use of modern and clean creosote treatment has shown to us, that negative properties can be overcome if the timbers are treated correctly under the adapted circumstances. This means :

the right temperature for treatment,

length of treatment cycle,

use of process and pressure,

correct use of filters

and further technologies to finally seal the surface of creosote treated commodities.

Odour, crud surfaces, leaching and migration for example can successfully be reduced. Negative outcomes for soil and water can be minimised. Modern machinery, processing, temperature and the use of sealing mechanisms as above have shown for period of more than a decade, that clean and acceptable products can be achieved in Europe, if used the correct way in the creosoting business to not cause any negative impacts on soil and/ or water and human beings. This resulted in an overall successful emulsion-technology in Germany over ten years ago which finally ended in a national approval of DIBt-Berlin in the year 2000.The product is now known under the brand name “MICROSOTE®”.

This modern technology is chemically based upon an emulsion made from WEI-C creosote, water and pigments. The formulation is now very stabile during production and use. A quality control system is developed for the technology. The process itself is easy to use for timber treatment plants, the technology is easy to maintain, the final product is reasonable in price and offers a wide perspective in creating more systems of less toxicity within a range of creosotes or in even replacing creosotes. An overall positive aspect in behaviour towards human beings, soil, air and water can be stated and is now proven under the present german regulations. Many customers were satisfied while using the product for years. The technology must be determined as sealing mechanism or fixation during treatment, not as a new chemical composition, because it can only be kept stabile while treating. This has the overall positive aspect, that no creosote out of the emulsion can be extracted from a plant as an extra safety measure. The alternative now is a product made from timber and a sealed creosote treatment system which aims for

clean surfaces

less to no leaching

less odour

safer handling

less toxicity

detoxification while reaching an equilibrium between water and creosote

during theprocess of treatment.

No other toxicants replacing the WEI-C areinvolved !

Creosoted timbers have created a big CO2-catcherover almost 150 years in accordance to the time benefit through high quality and service life between 20 to 40 years for products such as poles, posts, fences, sleepers, bridge timbers, constructions.By the time a product is destroyed through insects or fungus, a new tree has practically grown during service life.

The old products as well as the modern emulsion system are now fully integrated in an energy winning system through filtered and now safe combustion. No heavy metal contents do occur so far in the ashes of burned creosote timbers. The impregnated timbers do create an excellent and uncomplicated resource of energy after a long service life in ground contact. The timbers can easily disposed of through existing services, connected to modern power plants. Therefore a closed ecological cycle exists.

Finally we must understand, that the change of the world climate is leading to more and more destruction through a vast migration on fungus, insects and molluscs into the EU, destroying even during winter times in ground and water contact. Tropical hardwoods are no solution to this scenario without a protection and without tracing their sustainability. An example for migrating insects are Termites (reticulitermes flavipes) within France.

I hope I could help the commission with my personal statement as developer of emulsions for modern timber treatment. My data will follow soon to your address. In case of further questions please contact me via:

Mob.: 0049 /(0)170 / 2989746

e-Mail :

Awaiting your soon response.

Yours sincerely

Dr.M.Marmetschke

-encls.: (will follow concerning the emulsion product)