Page
1
of
3
Summary
of
the
Copper
Pesticides
Risk
Assessments
and
Information
Needs
Phase
3
of
4­
Phase
Process;
January
23,
2006
Background
The
preliminary
human
health
and
ecological
risk
assessments
for
the
copper­
containing
pesticides
include:
the
copper
II
compounds,
copper
sulfates,
copper
and
oxides,
copper
salts,
and
other
unscheduled
coppers.
Copper­
based
pesticides
are
used
as
fungicides,
bactericides,
algaecides,
aquatic
herbicides,
anti­
foulants,
and
wood
preservatives.
They
are
applied
to
a
wide
variety
of
agricultural,
commercial,
and
residential
use
sites,
and
can
be
formulated
as
dusts,
wettable
powders,
liquids
(
including
ready­
to­
use
liquids),
dry
flowables,
water­
soluble
packets,
and
granulars.

Human
Health
Risks
Since
copper
(
Cu)
is
a
naturally
occurring
metal
that
is
efficiently
regulated
in
the
human
system,
and
since
there
is
a
lack
of
systemic
toxicity
associated
with
copper
exposure,
no
toxicological
endpoints
were
identified
for
human
health
risk
assessment
purposes;
therefore,
the
human
health
risk
assessment
was
conducted
qualitatively.
However,
toxicological
endpoints
were
identified
for
ecological
assessment
purposes,
and
a
quantitative
environmental
fate
and
effects
assessment
was
conducted.

Ecological
Risks
In
the
ecological
assessment,
the
Agency
evaluated
various
copper­
containing
products
on
the
basis
of
ionic
copper
(
Cu2+),
regardless
of
the
original
copper
species.
Copper
is
highly
reactive,
especially
in
the
aquatic
environment,
and
may
exist
in
a
number
of
ionic
states,
ionpairs
and
organic
complexes
simultaneously
(
known
as
"
speciation"),
as
well
as
sorbed
to
suspended
particles.
Thus,
the
total
dissolved
concentration
is
not
truly
reflective
of
potential
copper
toxicity.
To
account
for
copper
speciation
in
aquatic
environments,
the
Agency
used
the
Biotic
Ligand
Model
(
BLM)
in
conjunction
with
the
Pesticide
Root
Zone
Model
(
PRZM)/
EXposure
Analysis
Modeling
System
(
EXAMS)
model.
The
BLM,
which
was
reviewed
and
approved
by
the
Scientific
Advisory
Board
(
SAB),
was
developed
and
used
by
the
EPA's
Office
of
Water
to
establish
Draft
Ambient
Water
Quality
Criteria
for
copper
and
was
used
for
the
aquatic
toxicity
assessment.
For
the
terrestrial
assessment,
the
Agency's
standard
methodologies
were
utilized,
including
the
use
of
the
Terrestrial
Exposure
Model
(
TREX)
for
evaluation
of
potential
toxic
effects
to
birds
and
mammals,
and
TerrPlant
for
terrestrial
plants.

The
coppers
ecological
exposure
assessment
considers
the
highest
label
use
rates,
in
accordance
with
the
Agency's
standard
assessment
protocol.
Current
labels
indicate
a
wide
range
of
maximum
use
rates
(
1
to
32
lbs
Cu/
acre),
with
the
highest
rates
generally
used
on
orchard
crops.
Many
current
labels
of
copper
products
do
not
have
complete
or
consistent
use
application
information;
the
labels
are
often
unclear
regarding
the
frequency
of
application
and
total
number
of
applications
permitted
on
a
yearly
basis;
thus,
the
Agency
made
various
assumptions
in
the
risk
assessment
regarding
copper
product
applications.
This
limited
the
Page
2
of
3
Agency's
ability
to
assess
actual
total
copper
loading
on
a
treated
site.
The
difficulty
of
discerning
actual
use
patterns
adds
uncertainty
to
the
ecological
risk
assessment.
Using
the
highest
labeled
use
rates,
the
ecological
risk
assessment
indicates
that
the
copper­
based
pesticide
products
may
pose
risk
concerns
for
all
taxa
evaluated,
except
for
terrestrial
plants.
Aquatic
organisms
are
especially
sensitive
to
copper
concentrations.
In
order
to
assess
what
terrestrial
use
application
rates
would
pose
an
ecological
risk
below
the
Agency's
level
of
concern
(
LOC),
the
Agency
analyzed
a
wide
range
of
use
scenarios
and
found
that
at
an
application
rate
of
approximately
2
lb
Cu/
acre,
less
than
5%
of
the
sites
exceeded
the
acute
LOC
for
aquatic
invertebrates.
At
an
application
rate
of
approximately
20
lb
Cu/
acre,
approximately
50%
of
the
sites
exceeded
the
acute
LOC
for
aquatic
invertebrates.

Information
Needs
In
order
to
address
the
areas
of
uncertainty
in
the
ecological
risk
assessment
stemming
from
incomplete
use
information,
the
Agency
is
requesting
actual
use
pattern
information
from
the
public
to
help
refine
the
risk
assessment.
Specifically,
the
Agency
is
seeking
current
use
rates
for
copper
products
used
on
conventional
crops
and
for
direct
water
treatments,
timing
and
locations
of
applications,
and
application
equipment
used.
Please
see
the
attached
table,
which
can
be
used
to
submit
this
information
to
the
Agency.

In
addition
to
seeking
public
comment
on
use
information,
the
Agency
is
also
seeking
information
on
alternative
pest
control
measures
and
mitigation
proposals
for
risk
estimates
of
concern
identified
in
the
Agency's
ecological
risk
assessment.
Page
3
of
3
COPPERS
USE
INFORMATION
NEEDS
Phase
3
of
4­
Phase
Process,
January
2006
REMIT
YOUR
REPONSE
THROUGH
THE
PUBLIC
DOCKET
AT
www.
regulations.
gov
OR
USE
ONE
OF
THE
METHODS
AS
OUTLINED
IN
THE
FEDERAL
REGISTER
NOTICE.
The
Agency
is
seeking
typical
use
information
of
copper
pesticides
to
agricultural
and
other
conventional
sites,
as
detailed
in
the
template
below.

Information
to
Include:

­
Contact
Information
(
establishment
name,
contact
person,
address,
best
contact
method
via
email
or
phone)

­
Notes
of
any
special
or
atypical
situations
where
different
use
rates
or
other
application
parameters
were
used.

A.
Use
Site1
B.
Typical
Use
Rate
(
lbs
a.
i./
A)
C.
Maximum
Use
Rate
(
lbs
a.
i./
A)
D.
No.
of
Apps.

per
Growing
Season*
E.
Application
Interval
(
days)
F.
Timing
of
Applications
G.
Application
Method
H.
Target
pest(
s)
I.
Comments
1
AQUATIC
USE
SITES:
please
specify
type
of
water
body
(
drinking
water
reservoir,
irrigation
system,
fish
pond),
and
method
of
application
(
pulse
treatment
for
a
given
area;
boat­
drawn
burlap
bag
treatment;
etc.)

A.
Use
Site
 
The
crop
or
type
of
area
(
e.
g.
apples,
farm
pond,
tomato,
etc.)
pesticide
is
applied
on.

B.
Typical
Use
Rate
(
lbs
a.
i./
A)
 
The
typical
use
rate
applied
to
each
crop
expressed
in
pounds
of
active
ingredient
applied
per
acre.

C.
Maximum
Use
Rate
(
lbs
a.
i./
A)
 
The
maximum
or
highest
use
rate
applied
to
each
crop
expressed
in
pounds
of
applied
product
per
acre.

D.
No.
of
Apps.
per
Growing
Season*
 
The
total
number
of
applications
that
are
applied
per
growing
season.
*
If
multiple
growing
seasons
occur
within
the
same
calendar
year,
please
indicate
how
many
growing
seasons
within
one
(
1)
calendar
year.

E.
Application
Interval
(
days)
 
The
typical
number
of
days
between
applications.

F.
Timing
of
Applications
 
month
of
year,
crop
phenology
stage,
etc.

G.
Application
Method
 
type
of
equipment
used
to
apply
product,
i.
e.
aerial
application,
sprayer,
ground
boom,
etc.

H.
Target
Pest(
s)
 
Specify
the
target
pest(
s)
to
be
managed
by
the
product.

I.
Comments
 
Include
any
details
or
unique
information
to
highlight
about
this
type
of
pesticide
application.
