1
CREOSOTE
­
CASE
OVERVIEW
II.
CASE
OVERVIEW
A.
Chemical
Overview
The
following
active
ingredients
are
covered
by
this
Creosote
Reregistration
Eligibility
Decision:

Common
Name:
Creosote
Case
Number:
0139
Chemical
Names:
CAS
Registry
Numbers:
OPP
Chemical
Codes:

Coal
Tar
Creosote
8001­
58­
9
25004
Creosote
Oil
61789­
28­
4
25003
Coal
Tar
8007­
45­
2
22003
Total
Number
of
Basic
Manufacturers:
Primary
Registrants
Registered
Products
Coopers
Creek
Chemical
Corp.
2
KMG­
Bernuth,
Inc.
5
Koppers
Industries,
Inc.
4
Osmose
utilities
Services,
Inc.
1
Railworks
Wood
Products,
Inc.
2
Rutgers
VFT
1
Trenton
Sales,
Inc.
1
B.
Use
Profile
The
following
is
information
on
the
currently
registered
uses
for
Creosote
with
an
overview
of
use
sites
and
application
methods.
A
detailed
table
of
the
uses
can
be
found
in
Appendix
A.

TYPE
OF
PESTICIDE:
Fungicide,
Insecticide,
Miticide,
and
Sporicide
2
USE
SITES:
Creosote
used
for
wood/
wood
structure
protection
treatments
via
pressure
methods
to
utility
poles
and
railroad
ties.
Treated
wood
intended
for
exterior/
outdoor
uses
only.

Terrestrial
Non­
Food
Crop
(
e.
g.,
Utility
Poles/
Crossarms,
Crossties,
Railroad
Ties,
Fenceposts,
Fences,
Foundation
Timbers,
Timbers,
Lumber)

Wood
or
Wood
Structure
Protection
Treatments:

­
Wood
Pressure
Treatment
to
Forest
Products
­
Pesticides
for
Manufacturing,
Reformulating
or
Repackage
Use
­
Pesticide
Products
for
Formulation
of
Other
Products
Aquatic
Non­
Food
Outdoor
(
e.
g.,
Pilings,
Posts)

Wood
or
Wood
Structure
Protection
Treatments:

­
Pressurized
Wood
Protection
Treatment
to
Wooden
Aquatic
Structures
and
Items
TARGET
PESTS:

INVERTEBRATES
(
Insects,
Miscellaneous
Invertebrates,
and
Related
Organisms.)

­
Insects
­
Wood
Destroying
Insects
­
Wood
Boring
Insects
­
Roundheaded
Wood
Borers
­
Marine
Borers
­
Wood
Infesting
Insects
­
Termites
­
Beetles
­
Powderpost
Beetles
­
Bees
­
Carpenter
Bees
­
Carpenter
Ants
PLANT
PATHOGENIC
ORGANISMS
(
Bacteria,
Fungi,
and
Other
Fouling
Organisms.)
3
­
Fungi
­
Dry
Rot
Fungi
­
Wood
Rot/
Decay
Fungi
­
Fungal
Rot/
Decay
Organisms
­
Wood
Rot/
Decay
Organisms
­
Slime
FORMULATION
TYPES
REGISTERED:

At
present
there
are
a
total
of
16
products
registered
with
the
U.
S.
EPA
for
wood
preservation
uses
which
contain
the
Creosote
active
ingredients
in
the
following
formulations:
Total
No.
of
Registered
Manufacturing­
Use
Product
(
MUP):
Percent
A.
I.
Products
Soluble
Concentrate
(
Liquid)
97.00
to
98.50%
1
End­
Use
Product
(
EUP):

Ready­
to­
Use
Compound
(
Grease)
37.00
to
60.00%
1
(
a
Coal
tar/
Creosote
oil
mixture)
Ready­
to­
Use
Solution
(
Liquid)
44.00
to
99.99%
14
TYPES
AND
RATES
OF
APPLICATION:

The
following
covers
only
those
application
rates
which
are
specified
on
the
Creosote
product
labeling:

Terrestrial
Non­
Food
Crop
Wood
Pressure
Treatment
to
Forest
Products:

Wood
Protection
Treatment
by
Pressure
(
Pressure
Treating
Vessel)
­
apply
at
rate
of
12
lbs.
per
cu.
ft..

Aquatic
Non­
Food
Outdoor
Wood
Pressure
Treatment
to
Aquatic
Structures/
Items:

Wood
Protection
Treatment
by
Pressure
(
Pressure
Treating
Vessel)
­
apply
4
at
rate
of
12
lbs.
per
cu.
ft..

Types
of
Treatment:

Pressure
Treatment
Equipment:

Pressure
Treating
Vessel
Timing:

Prior
to
end
use
of
wood.

C.
Regulatory
History
Creosote,
one
of
the
three
"
heavy
duty
wood
preservatives"
(
the
others
being
the
wood
preservatives
containing
arsenic
and/
or
chromium,
and
Pentacholorphenol)
was
first
registered
in
the
United
States
in
1948
as
a
coal
tar
creosote
active
ingredient.
Presently,
16
products
are
registered
for
use
as
industrial
wood
preservatives
for
above
and
below
ground
wood
protection
treatments,
as
well
as
treating
wood
in
marine
environments.
All
16
Creosote
products
are
Restricted
Use
Pesticides;
15
are
Ready­
to­
Use
End­
Use
Products
and
1
is
a
Manufacturing­
Use
Product
for
formulating
industrial
end­
use
wood
preservative
products.
Creosote
wood
preservatives
are
used
primarily
in
the
pressure
treatment
of
railroad
ties/
crossties
(
about
70%
of
all
Creosote
use)
and
utility
poles/
crossarms
(
about
15
­
20%
of
all
Creosote
use).
Assorted
Creosote­
treated
lumber
products
(
e.
g.,
timbers,
poles,
posts
and
ground­
line
support
structures)
account
for
the
remaining
uses
for
this
wood
preservative.
The
industry
refers
to
different
blends
of
Creosote
based
on
the
wood
treatment
standards
set
by
the
American
Wood­
Preservers'Association
(
AWPA).
For
instance,
P1/
P13
and
P2
are
the
predominant
blends
used
by
the
wood
treating
industry.
Typically,
railroad
ties/
crossties
are
treated
with
a
P2
blend
which
is
more
viscous
than
the
P1/
P13
blend
typically
used
for
treating
utility
poles.

In
October
1978,
an
administrative
review
process
was
initiated
to
consider
whether
the
pesticide
registration
of
the
three
heavy
duty
wood
preservative
uses
(
including
Creosote)
should
be
canceled
or
modified.
The
Federal
Register
(
Vol.
49,
No.
139)
of
July
13,
1984
concluded
that
process
and
announced
that
certain
changes
in
the
terms
and
conditions
of
registration
were
required
if
registrants
and
applicants
wished
to
avoid
cancellation.

After
carefully
evaluating
the
risks
to
public
health
posed
by
these
three
heavy
duty
wood
preservative
chemicals
(
including
Creosote)
along
with
the
significant
economic
benefits
resulting
from
their
use,
the
Agency
determined
that
the
use
of
Creosote
as
a
wood
5
preservative
chemical
in
accordance
with
certain
modifications
to
terms
of
registration
would
satisfy
the
statutory
standard
for
registration.
These
modifications
(
classification
as
restricted
use
pesticide,
workers
protection/
protective
clothing
and
equipment
requirements,
restricted
to
non­
residential
uses,
etc.)
are
noted
in
the
Federal
Register
of
January
13,
1986
(
Vol.
51,
No.
7).

The
Agency
has
announced
and
is
currently
processing
a
notice
of
receipt
of
requests
by
registrants
of
pesticide
products
containing
creosote
to
voluntarily
cancel
certain
registrations
and/
or
to
amend
to
terminate
certain
uses
of
affected
products.
Specifically,
the
five
registrants
who
are
members
of
the
Creosote
Council
III
(
Coopers
Creek
Chemical
Corporation,
KMG­
Bernuth,
Inc.,
Koppers,
Inc.,
Railworks
Wood
Products,
and
Rutgers
Chemicals
AG)
have
requested
in
letters
dated
September
5,
2003
to
cancel
the
registrations
for
their
creosote
non­
pressure
treatment
end­
use
products
and/
or
to
amend
to
terminate
all
non­
pressure
treatment
uses
of
other
creosote
products.
These
registrants
are
requesting
that
the
voluntary
product
cancellations
and/
or
use
terminations
become
effective
December
31,
2004.
The
registrants
waived
all
but
30
days
of
the
180­
day
comment
period
and
have
not
requested
any
existing
stocks
provision.
At
the
request
of
a
registrant,
the
Agency
published
an
extension
to
the
public
comment
period
on
November
26,
2003,
for
an
additional
30
days.
Unless
a
request
is
withdrawn
by
December
26,
2003,
the
Agency
intends
to
issue
orders
granting
these
requests
to
cancel
certain
products,
and
to
amend
to
terminate
certain
uses.
