June 2008 A BAN ON THE USE OF CREOSOTE: Possible consequences for the railway sector

Transcription

1 June 2008 A BAN ON THE USE OF CREOSOTE: Possible consequences for the railway sector

2 A BAN ON THE USE OF CREOSOTE: POSSIBLE CONSEQUENCES FOR THE RAILWAY SECTOR 1. Background Directive 98/8/EC on biocides 1 is now being overhauled. Creosote, a wood preservative for industrial and professional use in applications above soil, in soil and freshwater, and in sea water, is currently included in appendix 1 to the Directive, which means that its application is accepted throughout Europe. However, in October 2007 the Swedish Chemicals Agency (SCA) concluded that Based on the hazard assessment and risk characterisation for human health, an inclusion in Annex I of Directive 98/8/EC cannot be recommended at present for creosote as an active substance in wood preservatives, product type 8 2. This conclusion if followed by the European Commission could lead to a ban on the use of creosote, after a standard transition period of 4 years. In practice, European infrastructure managers would then be forced to discontinue the placing of new creosote impregnated sleepers into their networks. 2. The use of creosote in the railway sector Risks In terms of its effects on the environment, the SCA report states that the effects of the most toxic creosote components rapidly vanish in the atmosphere. The risk is therefore not so much related to creosote impregnated wood already in use but rather to the impregnating activity and impregnating industry. The wooden sleepers that are laid under rails (on a ballast layer) or stored under appropriate conditions therefore pose no major environmental risk. However, a health risk could exist related to fresh creosote and its handling by workers. Rail infrastructure managers agree that no safe use of creosote can be identified when it comes to health risks. To reduce any negative external effects from the use of creosote in wooden sleepers, solutions should be looked for and collectively discussed. This is the path on which European infrastructure managers have embarked on for some years, developing extensive research on potential substitutes to creosote and to wood. Benefits The use of concrete sleepers has rapidly grown in Europe during the last years; however wooden sleepers are still widely used, principally for technical reasons (resiliency, impact resistance, lower weight, etc). Creosote has been used in the rail industry since the early days to protect these wooden sleepers and therefore extend their lifetime by 10 to 30 years, depending on the wood and the degree of impregnation. In addition, given their long life expectancy, creosote wooden sleepers are generally considered cheaper than other type sleepers. As stated before, with the negative external effects in mind most infrastructure managers are progressively replacing creosote impregnated wood by 1 Directive 98/8/EC of 16 February 1998 concerning the placing of biocidal products on the market. 2 Work Programme for Review of Active Substances in Biocidal Products Pursuant to Council Directive 98/8/EC - CREOSOTE (PT8), Swedish Chemicals Agency, October 2007.

3 some other material, when and where this is feasible. In particular, with the present knowledge of alternatives, due to the fragility of some (sub) structures or the nature of the ground, it is not always currently possible to replace wooden by other types of sleepers. The sector therefore continuously seeks for a viable alternative to creosote sleepers. 3. Financial consequences of a creosote ban for the railway sector If a creosote ban would be decided by the European institutions after co-decision procedure, this would not result in the immediate obligation to remove creosote wooden sleepers from European tracks 3. According to the Commission, a standard period of four years applies for Member States to organise the withdrawal from the market. In practice, this would mean that infrastructure managers, until the end of this period, would be allowed to continue placing creosote wooden sleepers. Once the ban becomes effective, they would have to discontinue placing new creosote wooden sleepers into service. Infrastructure managers can thus decide on the process of changing those sleepers that are already placed in the network by alternative sleepers, normally after their lifetime expires. The railway sector recognises its environmental responsibility but wants to avoid the negative consequences of a discontinuation of the use of creosote sleepers, especially where the safety of railway operations is involved! Even if infrastructure managers have to phase out creosote wooden sleepers over a longer time period, in some cases a complete renewal of the track would be necessary instead of ordinary maintenance because sleepers of different types cannot always be mixed on the same section. This problem is particularly acute for less trafficked lines where maintenance ambitions are low (UIC 7 to 9, secondary tracks). Added to this will be the costs of development and implementation of solutions to possible technical problems (e.g. deformation with heat, resistance to gauge widening). Finally, there could be important financial consequences from an obligation to dispose of massive stocks of used wooden sleepers according to European environmental laws. Disposal methods will have to be further analysed by the railway industry prior to the start of a phasing out operation. 4. The use of concrete sleepers In order to prepare for a phasing out operation, alternatives to creosote wooden sleepers have been analysed, tested and already in use in many national networks. Most European infrastructure managers have replaced or are in the process of replacing wooden by concrete sleepers. For instance, in Belgium concrete sleepers are now used predominantly on main lines. 3 Infrastructure managers emphasise that an immediate ban would seriously jeopardise the sustainability of the railway sector. According to estimates by Réseau Ferré de France, the replacement of one km of tracks by concrete sleepers in France costs between Euro and , depending on the ballast under layer, on the number of points and crossings, etc. For France only, a complete renewal would amount to Euro 24 billion.

4 Type of sleepers used in Length in km Belgium Concrete mono-block 2,031 Oak (Creosote type C) 993 Concrete bi-block 609 Concrete old types (FB/RS/SL) 553 Azobe (not impregnated) 490 Other 375 However, there are important limits to the practice of using concrete sleepers: Technical limits: there are a number of situations where concrete sleepers cannot be an option. When the ground is clayey, in old tunnels, on metal structures, in stations, in narrow curves and on sections where there are switches and crossings. Where concrete sleepers are a viable option, the ballast in which they sit has to be re-profiled from that of the previous wooden sleepers due to the differing ballast depths and formation required to safely support them. This clearly adds significantly to the cost and reduces the opportunity of such replacement activities. Economic limits: replacing a wooden sleeper by a concrete one means transforming an ordinary maintenance operation into a renewal operation. This poses an economic problem for secondary tracks and low trafficked lines which are not planned for renewal (UIC 7-9). For instance, in Belgium creosote impregnated wooden sleepers are still used on about 80 % of secondary lines! In Sweden, a huge number of 9 million sleepers, over a distance of 6000 km of secondary tracks and low trafficked lines, is not planned for renewal in decades to come! Finally, in terms of their effect on the environment, Concrete sleepers are considered energy-consuming both in the production and in the transport process. 5. Other alternatives are promising but more research is needed Various alternatives have been analysed in recent years, such as wooden sleepers impregnated with ecological products, (wood polymer) composite sleepers, and steel sleepers. A technical study performed by UIC (Annex I) shows that creosote impregnated wooden sleepers are today the best available solution to some specific technical requirements. Different alternatives are being investigated, but they still need some time to prove reliability. For instance, in some Member States networks the use of creosote impregnated wooden sleepers remains indispensable and should not be banned: 1. Turnouts (the laying of which needs a greater flexibility); 2. Sleepers laid in between these above mentioned turnouts in order to guarantee the homogeneity of the laying; 3. Narrow curves (gauge widening); 4. When the ballast layer is not thick enough and/or the substructure is unstable; 5. Specific supports on metal bridges with direct fastenings, other specific cases.

5 From an environmental point of view, replacing pine or beech by exotic wood (that does not necessarily require any chemical treatment) is more questionable as tropical wood entails long transports. In addition, deforestation would be considered unethical, and production conditions would be uncertain. European infrastructure managers are willing to use alternatives to creosote when these are technically reliable. In order to collect as much reliable information on alternatives to creosote sleepers as possible, infrastructure managers and railway companies have expressed their wish to work together in an extensive research program, coordinated by UIC. 6. Conclusion In the absence of satisfactory substitutes to wood or to creosote, the industry is still relying on creosote impregnated sleepers for its activities. The evaluation report of the Swedish Chemicals Agency reinforces the analysis that sleepers currently in use do not pose major environmental problems. The main concern is related to the handling of fresh creosote and to the subsequent disappearing of this industry in case of a ban. As an indirect result infrastructure managers would not be able to buy new creosote impregnated sleepers, which could trigger a significant rise in maintenance and renewal costs if no suitable alternative to the creosote wooden sleeper is found. These effects should be assessed by a socio-economic cost benefit analysis which the SCA report also calls for. In particular, infrastructure managers ask the Commission for the following: To take into consideration that a ban on the use of creosote, even under phasingout scheme, could have considerable economic consequences for the railway sector: o Ordinary maintenance operations have to be turned into renewal operations; o Substructures of bridges, tunnels and other specific structures have to be replaced or modified; o Large quantities of sleepers that are no longer allowed for have to be disposed of. To apply the proportionality principle to any legislative proposals targeting the use of chemicals, accounting for low risks to human health on railway lines, but also consequences on the safety and economic viability of railways. To acknowledge the SCA s recommendation to carry out a comprehensive socioeconomic cost benefit analysis, including the effects of a ban on the use of creosote in wooden sleepers, before deciding on any course of action. To assist the Commission in carrying out a cost benefit analysis, UIC, EIM and CER propose to start a common investigation based on existing experience, in order to explore further and validate possible alternatives to creosote that could offer similar technical and functional properties as the creosote sleeper and be at the same time economically realistic..