UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

WASHINGTON, D.C. 20460

   OFFICE OF

                                                                        
                                    PREVENTION, PESTICIDES AND 

            TOXIC SUBSTANCES

March 7, 2008

MEMORANDUM

SUBJECT:		Case Overview for Creosote for the Reregistration Eligibility
Decision (RED) Document

			DP Barcode: None	Reregistration Case No.:  0139

FROM:		Norm Cook, Chief

Risk Assessment and Science Support Branch (RASSB)

Antimicrobials Division (7510P)

TO:			Jacqueline Campbell-McFarlane, CRM

Regulatory Management Branch I (RMB-I)

Antimicrobials Division (7510P)

Tim McMahon, PhD, Senior Toxicologist and Risk Assessor

Antimicrobials Division (7510P)

	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.			4

Koppers Industries, Inc.		4

Rutgers VFT				 1

Tangent Rail Products Inc		 2

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

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, Fence posts,
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.)

- 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)		97.00 to 98.50%	11

			 

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 			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, 13 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 13 Creosote products are Restricted Use Pesticides;
12 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/cross-arms (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 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. 

