
UNITED
STATES
ENVIRONMENTAL
PROTECTION
AGENCY
WASHINGTON
D.
C.,
20460
OFFICE
OF
PREVENTION,
PESTICIDES
AND
TOXIC
SUBSTANCES
MEMORANDUM
SUBJECT:
Typical
Applications
Information
for
Copper
Products
for
Algaecide,
Aquatic
Herbicide,
Molluscicide,
Leech,
and
Tadpole
Shrimp
Control
(
DP#
324176).

FROM:
William
Phillips,
II,
Ph.
D.,
Agronomist
Nicole
Zinn,
Biologist
Biological
Analysis
Branch
Biological
and
Economic
Analysis
Division
(
7503C)

THRU:
Arnet
Jones,
Chief
Biological
Analysis
Branch
Biological
and
Economic
Analysis
Division
(
7503C)

TO:
Rosanna
Louie,
Chemical
Review
Manager
Reregistration
Branch,
RRB3
Special
Review
and
Reregistration
Division
(
7508C)

PRODUCT
REVIEW
PANEL:
February
15,
2006
SUMMARY
In
support
of
the
continued
re­
registration
process
of
the
copper
hydroxide
and
copper
sulfate
compounds,
BEAD
has
compiled
typical
use
and
application
information
regarding
these
copper
compounds
as
algaecides,
aquatic
herbicides,
molluscicides,
as
well
as
leech,
and
tadpole
shrimp
controls.
This
information
will
be
used
by
the
Environmental
Fate
and
Effect
Division
(
EFED)
to
refine
their
risk
assessment.
In
an
effort
to
maintain
continuity
with
existing
copper
re­
registration
documents,
all
rates
and
concentrations
stated
herein
are
given
as
parts
per
million
(
ppm)
of
copper
element
regardless
of
the
product
stated.
The
analysis
was
conducted
by
BEAD
using
research
articles
as
well
as
other
relevant
authoritative
publications.
BEAD
also
requested
that
Dr.
Kurt
Getsinger1,
of
the
Army
Corp
of
Engineers
(
ACE),
review
the
algaecide
and
herbicide
use
and
application
outlines.
At
the
request
of
Dr.
Getsinger,
Dr.
Mike
Netherland2
of
the
University
of
Florida
conducted
an
additional
review
of
these
sections
of
the
memorandum.
The
resulting
information
in
the
outlines
is
a
culmination
of
this
cooperative
effort.
The
algaecide
and
aquatic
herbicide
uses
of
the
copper
compounds
provided
a
range
of
application
rates
between
0.2
 
1.0
ppm
elemental
copper.
Average
copper
rates
for
algae
control
were
0.5
ppm
for
susceptible
species
and
0.75
­
1.0
ppm
for
those
species
that
are
difficult
to
control
(
Getsinger
and
Netherland
2006).
Average
copper
rates
for
weed
control
were
0.2
­
0.5
ppm
for
susceptible
species
and
up
to
1.0
ppm
for
those
species
that
are
difficult
to
control
(
Getsinger
and
Netherland
2006).
In
addition,
the
average
number
of
annual
applications
to
a
given
water
body
were
found
to
range
between
two
and
four,
with
none
of
these
applications
being
made
to
more
than
25
­
33%
of
a
given
water
body
at
any
one
time.

Information
regarding
the
molluscicide
use,
as
well
as
leech
and
tadpole
shrimp
controls
was
difficult
to
obtain.
As
such,
this
analysis
includes
a
limited
amount
of
information
regarding
these
uses.
BEAD
would
hope
that
during
the
public
comment
phase
of
the
re­
registration
process
that
any
supplemental
information
will
be
provided.
Of
the
information
obtained,
copper
use
was
found
to
have
rates
ranging
from
1.0
ppm
to
as
high
as
2.5
ppm.
Direct
water
application
of
copper
sulfate
pentahydrate
for
snail
control
was
found
to
be
within
the
1.0
to
1.5
ppm
concentration.
Control
of
snails
and
leeches
has
been
demonstrated
to
be
necessary
in
ponds
and
other
associated
quiescent
water
bodies
for
human
as
well
as
agricultural,
aquacultural,
and
environmental
concerns.
Aquaculture
systems
rely
on
direct
water
applications
for
the
control
of
snails
and
tadpole
shrimp
at
rates
of
1.0
to
2.5
ppm
concentration
of
copper.
BEAD
believes
that
the
information
provided
herein
is
the
best
available
at
this
time.

Overall,
this
information
will
provide
the
EFED,
and
the
copper
re­
registration
team,
with
the
best
estimates
of
typical
use
information
for
these
copper
compounds
as
algaecides,
aquatic
herbicides,
molluscicides,
as
well
as
leech,
and
tadpole
shrimp
controls.

1
Environmental
Laboratory,
US
Army
Engineer
Research
and
Development
Station,
Vicksburg,
MS
39180­
6199
2
US
Army
Engineer
Research
and
Development
Center,
Center
for
Aquatic
and
Invasive
Plants,
University
of
Florida,
Gainesville,
FL
32653
ANALYSIS
Algaecide
and
Herbicide
Uses
Due
to
the
detail
and
amount
of
information
compiled
for
the
algaecide
and
herbicide
uses
of
the
copper
compounds
the
information
is
provided
in
a
tabular
format.
This
format
was
derived
from
the
basic
categorical
information
available
in
common
pesticide
labeling.

Algaecide
Applications
are
generally
made
to
areas
where
eutrophication
has
become
a
problem
and
threatens
the
aquatic
environment.

1.
Target
Pests
 
Algae
(
Mat­
forming&
Phytoplankton),
Cyanobacteria
(
Lyngbya&
Anabaena),
and
Charophytes
(
Chara
&
Nitella).

2.
Use
Sites
 
Aquaculture
Facilities,
Drainage
(
Canal,
Ditch,
and
Lateral),
Ponds
(
Farm
and
Industrial),
Fountains,
Lakes,
Reservoirs
(
Crop
and
Non­
Crop
Irrigation,
Potable),
Sewage
Lagoons,
Stocking
(
Tanks,
Water
Troughs,
and
Ponds),
and
Irrigation
Canals
(
mainly
in
17
western
states).

3.
Application
Methods
(
Application
methods
are
site
specific.)
­
Broadcast
Dry,
Broadcast
Spray,
Dragging,
Injection
(
Flowing
Water),
Slug
or
Dump,
and
Spot
Spray
4.
Application
&
Reapplication
Timing
 
Following
the
initial
application
a
second
may
be
made
within
30
days
if
algal
species
remain
a
problem.
The
minimum
waiting
period
between
applications
is
two
weeks.
This
would
be
the
approximate
time
to
determine
if
a
re­
treatment
is
necessary.

5.
Total
Number
of
Applications
Annually
 
Two
to
four;
the
number
of
applications
is
dependant
on
pest
species
and
environmental
factors
that
effect
pest
growth.

6.
Percent
Water
body
Treated
/
Treatment
 
25­
33%
maximum
7.
Target
Concentrations
(
Algaecide
rates
vary
from
species
to
species
as
well
as
between
active
ingredient
types.)
­
0.2
to
1.0
ppm
copper
element;
0.5
ppm
for
susceptible
species
and
0.75
­
1.0
ppm
for
difficult
to
control
species.

8.
Type
of
Copper
Compounds
 
copper­
ethanolamine
complexes,
copper
citrate,
copper
gluconate
chelates,
copper­
triethanolamine
complex,
copper
hydroxide,
copper
sulfate
pentahydrate
9.
Product
Examples
(
For
more
information
see
product
reference
table
on
the
last
page.)
Cutrine
®
Ultra
(
copper­
ethanolamine
complexes)
Algimycin
®
PWF
(
copper
citrate,
copper
gluconate
chelates)
(
This
product
is
also
a
Cyanobacteriocide.)
K­
Tea
®
(
copper­
triethanolamine
complex,
copper
hydroxide)
Triangle
Brand
Copper
Sulfate
Crystal
(
copper
sulfate
pentahydrate)

10.
Potential
Alternatives
 
While
the
list
below
contains
alternatives,
some
of
those
listed
may
only
be
alternatives
for
a
single
species
of
algae.
In
addition,
there
is
no
consideration
given
to
efficacy
in
this
list
of
potential
alternatives.
As
a
result,
care
must
be
exercised
in
making
assumptions
regarding
using
any
one
of
the
active
ingredients
below
as
a
replacement
for
the
copper
compounds
as
an
algaecide.
a.
Dye/
Colorant
b.
endothall
c.
diquat
dibromide
d.
sodium
carbonate
peroxyhydrate
(
hydrogen
peroxide)

Herbicide
Applications
are
generally
made
from
the
shoreline,
then
out
to
the
center
of
the
water
body
to
allow
fish
to
move
away
from
the
treated
area.

1.
Target
Pests
(
Primary)
­
Elodea
spp.,
Hydrilla
verticillata,
Potamogeton
spp.,
Sago
Pondweed
(
Stukenia
pectinatus),
Irrigation
Canal
Weed
(
Zannichellia),
and
Annual
Naiads
(
Najas
sp.)

2.
Use
Sites
 
Aquaculture
Facilities,
Drainage
(
Canal,
Ditch,
and
Lateral),
Ponds
(
Farm
and
Industrial),
Lakes,
Reservoirs
(
Crop
and
Non­
Crop
Irrigation,
Potable),
Sewage
Lagoons,
Stocking
(
Tanks,
Water
Troughs,
and
Ponds),
and
Irrigation
Canals
3.
Application
Methods
 
Broadcast
Dry,
Broadcast
Spray,
Dragging,
Injection
(
Flowing
Water),
Slug
or
Dump,
and
Spot
Spray
4.
Application
&
Reapplication
Timing
 
Following
the
initial
application
a
second
may
be
made
within
30
days
if
weed
species
remain
a
problem.
The
minimum
waiting
period
between
applications
is
approximately
two
weeks.

5.
Total
Number
of
Applications
Annually
 
Two
to
three;
the
number
of
applications
is
dependant
on
pest
species
and
environmental
factors
that
effect
pest
growth.

6.
Percent
Water
Body
Treated
/
Treatment
 
25­
33%
maximum
7.
Target
Concentrations
­
0.2
to
1.0
ppm
copper
element;
0.2
­
0.5
ppm
for
susceptible
species
and
up
to
1.0
ppm
for
difficult
to
control
species.

8.
Type
of
Copper
Compounds
 
copper­
ethanolamine
complexes,
copper
citrate,
copper
gluconate
chelates,
copper
sulfate
pentahydrate,
and
copper
ethylenediamine
9.
Product
Examples
(
For
more
information
see
product
reference
table
on
the
last
page.).

Algimycin
®
­
PWF
(
copper
citrate,
copper
gluconate
chelates)
Cutrine
®
­
Ultra
(
copper­
ethanolamine
complexes)
Triangle
Brand
Copper
Sulfate
Crystal
(
copper
sulfate
pentahydrate)
Komeen
(
copper
ethylenediamine)

10.
Potential
Alternatives
 
While
the
list
below
contains
alternatives,
some
of
those
listed
may
only
be
alternatives
for
a
single
species
of
aquatic
weeds.
In
addition,
there
is
no
consideration
given
to
efficacy
in
this
list
of
potential
alternatives.
As
a
result,
care
must
be
exercised
in
making
assumptions
regarding
using
any
one
of
the
active
ingredients
below
as
a
replacement
for
the
copper
compounds
as
an
herbicide.
a.
2,4­
D
 
Not
effective
on
most
monocots.
b.
Dye/
Colorant
 
Not
effective
in
waters
with
outflow
as
a
result
of
dilution.
c.
diquat
dibromide
 
Hydrilla
control
only
when
copper
co­
mixed.
Irrigation
restrictions
apply.
d.
endothall
 
No
elodea
or
egeria
control.
Irrigation
restrictions
apply.
e.
fluridone
 
Not
for
spot
treatments
due
to
prolonged
exposure
time
requirements.
f.
glyphosate
 
Not
effective
on
submerged
species.
g.
imazapyr
­
Not
effective
on
submerged
species.
h.
triclopyr
­
Not
effective
on
most
monocots.
i.
carfentrazone­
ethyl
 
Undetermined
efficacy
on
submerged
species.
Molluscicide
and
Macro­
invertebrate
Uses
Molluscicide
Snails
can
act
as
an
intermediate
host
of
parasites.
In
the
U.
S.,
these
parasites
can
impact
humans
as
well
as
agricultural
production.
In
swimming
areas,
the
control
of
schistosome­
infected
snails
is
an
important
human
health
concern.
Two
specific
examples
important
to
agricultural
production
are
liver
flukes
in
livestock
and
deer
and
the
trematode
Bolbophorus
sp.,
also
a
fluke,
in
catfish.
While
some
resources
recommend
copper
compounds
for
the
control
of
Zebra
Mussels
(
Dreissena
polymorph)
they
are
not
widely
used.
Overall,
large
scale
outbreaks
of
mollusk
pests
are
not
currently
an
issue;
however,
there
may
be
national
security
concerns
which
should
be
considered
when
determining
the
importance
of
the
following
uses
with
respect
to
human
health.

Human
Health
The
control
of
schistosome­
infected
snails
with
copper
sulfate
is
labeled
at
a
rate
of
1
to
1.5
ppm
copper
element,
for
a
maximum
of
two
applications
per
season.
To
control
these
snails
the
application
of
copper
sulfate
crystals
can
be
applied
to
the
shoreline
or
snail
beds
of
swimming
areas.
Second,
a
direct
water
application
can
be
made
using
broadcast
methods
(
to
include
aerial)
or
by
using
an
under
water
dispenser.
For
potable
water
reservoirs
the
rate
is
not
to
exceed
1.0
ppm
copper
element.

Livestock
Liver
flukes
(
Fascioloides
magna
and
Fasciola
hepatica)
affect
deer,
cattle,
and
sheep.
F.
magna
is
found
in
the
Upper
Great
Lakes
region
whereas
F.
hepatica
primarily
occurs
in
California,
the
Pacific
Northwest
and
the
Gulf
States.
Liver
flukes
may
cause
economic
harm
to
growers
by
affecting
animal
growth,
killing
sheep,
and
the
inability
to
sell
infected
livers
(
MI
DNR,
2002;
Grooms,
2006).

For
liver
fluke
control
in
Michigan,
where
F.
magna
is
the
trematode
of
concern,
white­
tailed
deer,
as
the
natural
host,
are
a
major
source
of
contamination.
The
affect
on
cattle
is
often
the
inability
to
sell
livers,
but
for
sheep
it
can
be
fatal.
Control
of
snails,
the
intermediate
host,
using
copper
sulfate
or
cultural
control
methods
may
be
difficult
to
maintain
or
otherwise
impractical
(
MI
DNR,
2002;
Grooms,
2006).

However,
in
smaller
moist
areas,
it
may
be
feasible
to
use
copper
sulfate.
Other
methods
in
small
areas
include
draining
the
area
or
using
fences
to
keep
the
animals
away
from
the
area
(
Utah,
1999).
For
F.
hepatica,
the
drugs
clorsulon
and
albendazole
are
available
to
treat
infected
animals
(
Grooms,
2006).
Commercial
Catfish
Ponds
In
catfish
ponds,
the
trematode
Bolbophorus
sp.
may
have
significant
impacts
on
production.
The
first
intermediate
host
of
Bolbophorus
is
the
Ram's
Horn
Snail,
and
the
final
host
is
the
American
White
Pelican.
Copper
sulfate
may
be
used
to
control
the
snail
at
the
pond
margin.
Copper
sulfate
is
applied
in
a
6­
foot
band
around
the
perimeter
of
the
pond
at
a
rate
of
10
lb
copper
sulfate
plus
1
lb
citric
acid
per
250
feet
of
pond
margin.
Alternatives
include
hydrated
lime
and
niclosamide.
However,
niclosamide
was
only
available
as
a
Section
18
in
MS
until
2003
(
to
date
there
is
no
section
3
registration)
and
can
only
be
used
in
ponds
with
no
fish.
Biological
controls
include
Black
Carp
and
Redear
Sunfish.
Controlling
aquatic
vegetation
not
only
improves
chemical
treatment
effectiveness,
but
also
eliminates
a
potential
habitat
for
snails.
In
addition,
pelicans
can
be
discouraged
from
feeding
in
ponds,
but
there
is
no
treatment
available
for
affected
fish
(
Terhune,
et
al,
2003).

In
addition
to
treating
at
the
pond
margins,
studies
have
been
conducted
to
show
that
applying
copper
sulfate
at
0.6
to
1.25
ppm
may
be
used
to
kill
snails
throughout
the
aquaculture
ponds
without
harming
healthy
catfish.
By
applying
copper
sulfate
in
the
fall,
dissolved
oxygen
content,
and
thus
catfish,
were
not
affected
because
application
occurred
when
algal
growth
had
diminished
(
Wise,
Mischke,
and
Byars,
2005).

Orchards
The
brown
garden
snail
(
Helix
aspersa)
feeds
on
the
leaves,
fruit,
and
young
bark
of
citrus
trees.
Copper
sulfate
is
recommended
for
use
as
a
band
on
trees,
at
label
rates,
to
repel
snails.
However,
BEAD
has
not
been
able
to
locate
label
information
that
provides
support
or
rates
for
this
use.
Copper
sulfate
is
described
as
a
cultural
control
method
that
is
acceptable
for
organic
production.
There
are
other
cultural
control
methods,
such
as
copper
foil
bands.
The
Decollate
Snail
(
Rumina
decollata)
is
a
biological
control
method
and
chemical
control
methods
include
metaldehyde
and
iron
phosphate
(
UC
IPM
Online,
2005).

Macro­
invertebrate
Control
The
macro­
invertebrates
that
are
controlled
by
copper
sulfate
pentahydrate
are
leeches
and
tadpole
shrimp.
Leeches
are
often
a
problem
in
ponds
and
quiescent
waters
under
drought
conditions.
While
most
leeches
are
a
problem
for
fish,
humans
splashing
in
water
can
become
an
alternate
host.
At
the
current
time,
copper
sulfate
pentahydrate
is
the
only
registered
compound
for
leech
control
in
open
water.
Tadpole
shrimp
are
often
a
problem
in
the
production
of
lowland/
wetland
rice.
These
crustaceans
damage
rice
plants
primarily
through
their
feeding
on
newly
emerging
plants.
The
use
of
copper
sulfate
pentahydrate
as
a
control
for
tadpole
shrimp
is
the
only
control
for
which
some
types
of
fish
can
be
present
in
the
water
at
application.
Leeches
Copper
sulfate
pentahydrate,
the
only
pesticide
registered
for
control
of
leeches
in
ponds,
is
not
registered
in
all
states
(
NCSU,
2006).
Recommendations
for
control
of
leeches
suggest
using
copper
sulfate
pentahydrate
at
a
concentration
of
1.25
ppm
copper
element
(
NCSU,
2006;
IN
DNR).
Other
control
methods
require
draining
the
pond,
and
include
treating
with
quicklime,
powdered
bleach,
powdered
swimming
pool
chlorine,
or
allowing
a
dry
period
or
freeze
to
kill
the
leeches
(
Johnson).
BEAD
was
unable
to
find
label
information
for
the
application
of
quicklime,
powdered
bleach,
or
powdered
swimming
pool
chlorine
for
this
use.

Tadpole
Shrimp
Tadpole
shrimp
(
Triops
longicaudatus)
are
crustaceans
that
damage
wetland
rice
by
feeding
on
the
coleoptile
and
roots
of
newly
emerging
plants.
The
secondary
effect
of
their
digging
to
reach
plant
roots
and
to
lay
eggs
is
the
increased
soil
and
organic
matter
suspended
in
the
water
column.
This
increased
sedimentation
of
the
water
column
lowers
the
amount
of
photosynthetically
active
radiation
reaching
the
newly
emerged
rice
plants
resulting
in
poor
or
no
growth.

Since
tadpole
shrimp
are
not
a
feeding
problem
on
mature
rice
plants,
the
only
cultural
controls
are
to
either
flood
fields
then
drain
them
once
the
tadpole
shrimp
have
emerged,
or
to
plant
rice
immediately
upon
flooding
fields.
There
are
currently
two
means
of
chemical
controls
available,
carbaryl
and
copper
sulfate
pentahydrate.
Copper
sulfate
pentahydrate
applied
at
5­
10
lbs
per
acre,
or
1.25
 
2.5
ppm
(
assuming
a
four
inch
water
depth),
is
the
recommendation
for
the
control
of
tadpole
shrimp
in
rice
production
(
Godfrey,
2005).
REFERENCES
Anonymous.
2005.
Pond
Management
Guide.
Virginia
Department
of
Game
&
Inland
Fisheries
(
VDGIF).
http://
www.
dgif.
state.
va.
us/
fishing/
Pond_
Management/
aqua_
herb.
html.

Getsinger,
K.
2004.
Aquatic
Plant
Management.
Aquatic
Ecosystem
Restoration
Foundation
(
AERF).
http://
www.
aquatics.
org.
Lansing,
Michigan
Getsinger,
K
and
M.
Netherland.
January
26,
2006.
Email
communication
with
William
Phillips,
II.

Godfrey,
L.
2005.
Rice
Tadpole
Shrimp.
University
of
California
IPM
Online.
Accessed
February
2006,
Web
address:
http://
www.
ipm.
ucdavis.
edu/
PMG/
r682500111.
html.

Grooms,
D.,
Michigan
State
University
College
of
Veterinary
Medicine,
Veterinary
Extension,
Accessed
February
2006,
Web
address:
http://
cvm.
msu.
edu/
extension/
docs/
flukes.
htm
Hahn,
J.
and
J.
Fetzer,
2000,
Slugs
in
Home
Gardens,
University
of
Minnesota
Extension
Service,
Web
address:
http://
www.
extension.
umn.
edu/
distribution/
horticulture/
DG7561.
html
Indiana
Department
of
Natural
Resources,
Division
of
Fish
and
Wildlife,
Fisheries
Frequently
Asked
Questions:
Pond
or
Lake
Management,
Accessed
January
2006,
Web
addressed:
http://
www.
in.
gov/
dnr/
fishwild/
fish/
fishing/
faqpond.
htm#
leech
Johnson,
S.
K.,
Leeches
in
Texas
Waters,
Texas
A&
M
University,
Web
address:
http://
wildlife.
tamu.
edu/
publications/
a1101.
pdf
Michigan
Department
of
Natural
Resources,
2002,
Deer
Liver
Fluke,
Web
address:
http://
www.
michigan.
gov/
dnr/
1,1607,7­
153­
10370_
12150_
12220­
26639­­,
00.
html
NCSU,
Accessed
January
2006,
Leeches,
Web
Address:
http://
www.
ces.
ncsu.
edu/
nreos/
wild/
fisheries/
topics/
leeches.
htm
Terhune,
J.,
D.
Wise,
J.
Avery,
L.
Khoo,
and
A.
Goodwin,
2003,
Infestations
of
the
Trematode
Bolbophorus
sp.
in
Channel
Catfish,
Southern
Regional
Aquaculture
Center,
Web
address:
http://
srac.
tamu.
edu/
tmppdfs/
9919857­
1801fs.
pdf
UC
IPM
Online,
Updated
2005,
UC
Pest
Management
Guidelines:
Citrus,
Brown
Garden
Snail,
Web
address:
http://
www.
ipm.
ucdavis.
edu/
PMG/
r107500111.
html
Utah
State
University
Extension,
December
1999,
Beef
Newsletter,
Web
addresss:
http://
extension.
usu.
edu/
files/
agpubs/
dec99nl.
htm
Wise,
D.,
C.
Mischke,
and
T.
Byars,
2005,
Use
of
Elevated
Levels
of
Copper
Sulfate
to
Eliminate
Snails,
Thad
Cochran
National
Warmwater
Aquaculture
Center
News,
Vol
8,
No
1,
Web
address:
http://
msstate.
edu/
dept/
tcnwac/
Vol08No1Apr2005.
pdf
PRODUCT
LABEL
RREFERENCES
Active
Ingredient
Product
Name
EPA
Reg.
No.
acid
blue
9
Aqushade
®
33068­
1
copper
Copper
Sulfate
Crystal
56576­
1
copper
Cutrine
®
Ultra
8959­
53
copper
K­
Tea
 
1812­
307
copper
Triangle
Brand
®
Copper
Sulfate
Crystal
1278­
8
diquat
dibromide
Reglone
®
Dessicant
100­
1061
endothall
Aquathol
®
K
4581­
204
fluridone
Sonar
®
SRP
5P
67690­
3
imazapyr
Habitat
®
241­
426
