UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

WASHINGTON, D.C. 20460

                                                                        
                                             OFFICE OF

                                                                        
                                    PREVENTION, PESTICIDES AND

                                                                        
                                                 TOXIC SUBSTANCES

                                                                        
                                                                        
                        

June 27, 2007

MEMORANDUM

SUBJECT:		Ecological Hazard and Environmental Risk Assessment Chapter
for the Copper 8-Quinolinolate Reregistration Eligibility Decision (RED)
Document (Case No.: 4026)		

FROM:		Genevieve Angle, Biologist

Risk Assessment and Science Support Branch (RASSB)

Antimicrobials Division (7510P)

TO:			Mark Hartman, Branch Chief

Diane Isbell, Team Leader

ShaRon Carlisle, Chemical Review Manager

Sanyvette Williams, Risk Assessor

Regulatory Management Branch II

Antimicrobials Division (7510P)

THRU:		Nader Elkassabany, Team Leader, Team Two

Risk Assessment and Science Support Branch (RASSB)

Antimicrobials Division (7510P)

Norman Cook, Branch Chief

Risk Assessment and Science Support Branch (RASSB)

Antimicrobials Division (7510P)

Chemical Names					PC Codes	CAS Nos.

Copper 8-quinolinolate				024002	10380-28-6

Attached is the Ecological Hazard and Environmental Risk Assessment
chapter for the copper 8-quinolinolate RED Document.



ECOLOGICAL HAZARD AND ENVIRONMENTAL 

RISK ASSESSMENT CHAPTER

Copper 8-Quinolinolate

PC Code 024002

CASE No.: 4026

06/27/07

Genevieve Angle, Biologist

Antimicrobials Division

Office of Pesticide Programs

U.S. Environmental Protection Agency

1200 Pennsylvania Avenue, NW

Washington, DC 20460

Table of Contents

												    Page

Executive Summary
………………………………………………………………
……………… 1

1.  Ecological Toxicity Data . . . . . . . . . . . . . . . . . . . . . .
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .3  

A.  Toxicity to Terrestrial Animals . . . . . . . . . . . . . . . . . .
. . . . . . . . . . . . . . . . . . . . . . . . . . ...3 

1.  Birds, Acute  . . . . . . . . . . . . . . . . . . . . . . . . . . .
. . . . . . . . . . . . . . . . . . . . . . . . . 3

2.  Birds, Subacute. . . . . . . . . . . . . . . . . . . . . . . . . . .
. . . . . . . . . . . . . . . . . . . . . . . . 4 

3.  Mammals, Acute and Chronic . . . . . . . . . . . . . . . . . . . . .
. . . . . . . . . . . . . . . . . . .5  

B.  Toxicity to Aquatic Animals . . . . . . . . . . . . . . . . . . . .
. . . . . . . . . . . . . . . . . . . . . . . . . . .5 

1.  Freshwater Fish, Acute . . . . . . . . . . . . . . . . . . . . . . .
. . . . . . . . . . . . . . . . . . . . . .5  

2.  Freshwater Invertebrates, Acute . . . . . . . . . . . . . . . . . .
. . . . . . . . . . . . . . . . . . . .6 

3.  Estuarine and Marine Organisms, Acute . . . . . . . . . . . . . . .
. . . . . . . . . . . ... . . . . .7 

4.  Aquatic Organisms, Chronic . . . . . . . . . . . . . . . . . . . . .
. . . . . . . . . . . . . . . . . . . .8 

C.  Toxicity to Plants . . . . . . . . . . . . . . . . . . . . . . . . .
. . . . . . . . . . . . . . . . . . . . . . . . . . . . ..8

II.  Risk Assessment and Risk Characterization . . . . . . . . . . . . .
. . . . . . . . . . . . . . . . . . . . . . . . . . . ..9

A.  Environmental Fate Assessment Summary . . . . . . . . . . . . . . .
. . . . . . . . . . . . . . . .. . . . ..10 

B.  Environmental Exposure And Ecological Risk Assessment. . . . . . . .
. . . . . . . . .. . . . . . .10 

C.  Endangered Species Considerations . . . . . . . . . . . . . . . . .
. . . . . . . . . . . . .  . . . . . . . . . . 14

III.  Confirmatory Data Required. . . . . . . . . . . . . . . . . . . .
. . . . . . . . . . . . . . . . . . . .. . . . . . . . . . 15   

IV.  Label Hazard Statements for Terrestrial and Aquatic Organisms. . .
. . . . . . . .  . . . . . . . . . .16

V.  References . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
. . . . . . . . . . . . . . . . . . . . . . . .  . . . . . . . . . . 17

LIST OF TABLES

																			    Page

Table 1 – Acute Oral Toxicity of Copper 8-Quinolinolate to Birds. . .
. . . . . . . . . . .  . . . . . . . . . .3 

				

Table 2 – Subacute Oral Toxicity of Copper 8-Quinolinolate to Birds. .
. . . . . . . . .. . . . . . . . . . . 4

Table 3 – Acute Toxicity of Copper 8-Quinolinolate to Freshwater Fish.
. . . . . . . . . .. . . . . . . . . 4

Table 4 – Acute Toxicity of Copper 8-Quinolinolate to Freshwater
Invertebrates. . . . .. . . . . . . . 5 

Table 5 – Acute Toxicity of Copper 8-Quinolinolate to Estuarine and
Marine Organisms. . . . . . 6

Table 6 – Chronic Toxicity of Copper 8-Quinolinolate to Freshwater
Organisms. . .. . . . . . . . . . 7

Table 7 – Toxicity of Copper 8-Quinolinolate to Aquatic Plants. . . .
. . . . . . .. . . . . . . . . . . . .. . ..8  Ecological Hazard and
Environment Risk Assessment

For Copper 8-Quinolinolate

Executive Summary:

		Copper 8-quinolinolate (copper 8) is currently registered as a
fungicide, algaecide and bacteriocide for materials preservation, wood
preservation and food handling/storage establishments.  Materials
preservative uses include:  industrial textiles, webbing, rope, canvas,
leather, kraft paper, paperboard, adhesives and paint.  Wood
preservative uses include: log homes, shingle roofs, siding, fences,
poles, posts, decks, furniture, playground equipment, sills and
baseboards and structural building lumber.  Food handling/storage
establishment uses include potato processing, storage and transportation
facilities. 

Copper 8-quinolinolate is hydrolytically stable at pH 5, 7 and 9. More
than 80% of it is stable in aerobic and anaerobic soils. In aerobic
soils its half-life is 16 weeks, but it may be over one year in
anaerobic soils.  It does not show any tendency to migrate from top
soil. It is therefore likely to contaminate surface water through
surface water run-off. Its degradation pathway appears to be aqueous
photolysis with a half-life of 60 to 96 hours.  The estimated log Kow
for copper 8-quinolinolate is 2.5, which indicates that it is not likely
to bioaccumulate in aquatic organisms like fish.

The wood treatment uses of copper 8 have high potential for
environmental exposure and thus require an ecological risk assessment. 
Uses in rope, webbing, and roofing shingles are likely to provide for
some environmental exposures as well; however, only the wood treatment
uses have been examined in this assessment.  All other uses are
considered indoor and have minimal to no environmental exposure
potential following use.  

	EPA has performed an environmental risk assessment using estimated
environmental concentrations (EECs) for copper 8 developed by modeling
its release from a dock into water and toxicity values from the tables
in section I to develop risk quotients (RQs) and compare them to levels
of concern (LOCs) for copper 8.  LOCs were not exceeded for fish,
freshwater invertebrates, the eastern oyster or aquatic plants in bodies
of water 6 acre feet in size or greater, whereas risks to endangered
freshwater fish and the eastern oyster as well as risks to aquatic
plants were of concern in bodies of water 1 acre foot in size or less. 
Since it is unlikely that a dock of the size used in the calculations
for EEC will be present on a body of water less than 6 acre feet in
size, the risks to aquatic organisms from copper 8 in this assessment
appear to be small.  There were no acceptable acute toxicity studies for
other estuarine and marine organisms nor were there any acceptable
chronic toxicity studies available for aquatic organisms.  Therefore,
risk to these species could not be assessed.

Data Gaps:  

	Confirmatory Data Required For Wood Treatment Risk Assessment:

      Estuarine/marine fish acute study (850.1075),

      Estuarine/marine shrimp acute study (850.1035),      

      Acute sediment toxicity to freshwater invertebrates (850.1735),

      Acute sediment toxicity to estuarine invertebrates (850.1740),

      Aquatic invertebrate (freshwater) life-cycle study (850.1300),

      Fish early life-stage (freshwater) study (850.1400),1

	Fish early life-stage (estuarine/marine) study (850.1400),1

      Chronic mysid shrimp study (850.1350),1

      Freshwater diatom (850.5400),

Blue-green cyanobacteria (850.5400),

Freshwater green alga (850.5400),

Freshwater floating macrophyte duckweed (850.4400),

Freshwater rooted macrophyte rice seedling emergence (850.4225),

Freshwater rooted macrophyte rice vegetative vigor (850.4250),

Wood leaching study (AWPA E11-06),

Environmental runoff monitoring study (None).  This test can be waived
provided labels are amended as outlined below for wood preservative
labels,

Residues in honey/beeswax and toxicity of treated wood residues to bees
– combination of Guideline 860.1500 and 850.3030 (“Honey Bee
Toxicity of Residues on Foliage.”).  The toxicity portion of this
study is in lieu of the honeybee contact LD50 test 850.3020.  The
residue and toxicity test can be waived provided the label is amended to
prohibit the use of treated wood for beehive construction, with a
statement such as, “Wood treated with copper 8-quinolinolate shall not
be used in the construction of beehives.”

Label Hazard Statements/Use Recommendations:

Copper 8-quinolinolate labels must state:  

“This pesticide is toxic to fish, aquatic invertebrates, oysters, and
shrimp.”

"Do not discharge effluent containing this product into lakes, streams,
ponds, estuaries, oceans, or other waters unless in accordance with the
requirements of a National Pollutant Discharge Elimination System
(NPDES) permit and the permitting authorities are notified in writing
prior to discharge.  Do not discharge effluent containing this product
to sewer systems without previously notifying the local sewage treatment
plant authority.  For guidance contact your State Water Board or
Regional Office of the EPA."

Wood preservative labels must state:  "Treated lumber must be stored
under cover, indoors, or at least 100 feet from any pond, lake, stream,
wetland, or river to prevent possible runoff of the product into the
waterway.  Treated lumber stored within 100 feet of a pond, lake,
stream, wetland, or river must be either covered with plastic or
surrounded by a berm to prevent surface water runoff into the nearby
waterway.  If a berm or curb is used around the site, it should consist
of impermeable material (clay, asphalt, concrete) and be of sufficient
height to prevent runoff during heavy rainfall events.”

The honey bee residue and toxicity test can be waived provided the label
is amended to prohibit the use of treated wood for beehive construction,
with a statement such as, “Wood treated with copper 8-quinolinolate
shall not be used in the construction of beehives.

I.	Ecological Toxicity Data

	The toxicity endpoints presented below are based on the results of
ecotoxicity studies submitted to EPA to meet the Agency’s data
requirements for the uses of copper 8-quinolinolate.

	A.	Toxicity to Terrestrial Animals

(1)	Birds, Acute 

	In order to establish the toxicity of copper 8 to avian species, the
Agency requires an acute oral toxicity study using the technical grade
active ingredient (TGAI).  The preferred test species is either mallard
duck (a waterfowl) or bobwhite quail (an upland game bird).  The results
of two acute oral toxicity studies, submitted for copper 8, are provided
in the following table (Table 1).

Table 1.  Acute Oral Toxicity of Copper 8 to Birds

Species	

Chemical,

% Active Ingredient

(a.i.)

Tested	

Endpoint

(mg/kg)	

Toxicity Category	

Satisfies Guidelines/

Comments	

Reference

(MRID No.)

Bobwhite quail

(Colinus virginianus)	Copper 8 99.5%	LD50 = 618

	Slightly toxic	Yes (core)

- 14-day test duration

- 4-5 months of age	429271-01

Mallard duck

(Anas platyrhynchos)	Copper 8 99.5%	LD50 = >2000

NOAEL = 2000

	Relatively nontoxic	Yes (core)

- 14-day test duration

- 15 months of age	429271-02



	These acceptable acute oral toxicity studies indicate that copper 8 is
slightly toxic to relatively nontoxic to birds on an acute oral basis.
The guideline requirement OPPTS 850.2100/(71-1) is satisfied.  

(2)	Birds, Subacute

	A subacute dietary study using the TGAI may be required on a
case-by-case basis depending on the results of lower-tier ecological
studies and pertinent environmental fate characteristics in order to
establish the toxicity of a chemical to avian species.  This testing was
required for copper 8.  The preferred test species is either the mallard
duck or bobwhite quail.  The results of two subacute dietary toxicity
studies, submitted for copper 8, are provided in the following table
(Table 2).

Table 2.  Subacute Oral Toxicity of Copper 8 to Birds

Species	

Chemical,

% Active Ingredient

(a.i.)

Tested	

Endpoint

(ppm)	

Toxicity Category	

Satisfies Guidelines/

Comments	

Reference

(MRID No.)

Bobwhite quail

(Colinus virginianus)	Copper 8 99.5%	LC50 (diet) = 3248

NOAEC = 1300	Slightly toxic	Yes (core)

-	8-day test duration

-	14 days of age	429271-03

Mallard duck

(Anas platyrhynchos)	Copper 8 99.5%	LC50 (diet) = >5200

NOAEC = 2600	Relatively nontoxic	Yes (core)

-	8-day test duration

-  10 days of age	429271-04



	The results from these acceptable studies indicate that copper 8 is
slightly toxic to relatively nontoxic to avian species through subacute
dietary exposure. These studies fulfill guideline requirements OPPTS
850.2100/ (71-2a – Bobwhite quail and 71-2b – Mallard duck). 

 (3)	Mammals, Acute and Chronic Toxicity

Wild mammal testing is not required by the Agency.  In most cases, rat
toxicity values obtained from studies conducted to support data
requirements for human health risk assessments substitute for wild
mammal testing.  Refer to the human toxicology chapter of this RED for
mammalian toxicity data.

B.	Toxicity to Aquatic Animals

	The Agency requested that aquatic toxicity studies be conducted with
copper 8-quinolinolate since, under typical use conditions, it can be
introduced into the aquatic environment.

(1)	Freshwater Fish, Acute

	In order to establish the acute toxicity of copper 8 to freshwater
fish, the Agency requires freshwater fish toxicity studies using the
TGAI.  The preferred test species are rainbow trout (a coldwater fish)
and bluegill sunfish (a warmwater fish).  The results of four freshwater
fish acute studies submitted for copper 8, 3 coldwater and 1 warmwater,
are presented in Table 3.

Table 3.  Acute Toxicity of Copper 8 to Freshwater Fish 

Species	

Chemical,

% Active Ingredient

(a.i.)

Tested	

Endpoint

(mg/L)	

Toxicity Category	

Satisfies Guidelines/

Comments	

Reference

(MRID No.)

Bluegill Sunfish (Lepomis macrochirus)	Copper 8 100%	LC50 = 0.0216

NOAEC = 0.0108	Very highly toxic	Yes (core)

-	96-hr test duration

-	flow-through test system	428990-03

Rainbow Trout (Oncorhynchus mykiss)	Copper 8 100%	LC50 = 0.0089

NOEC = 0.0062	Very highly toxic	Yes (core)

- 96-hr test duration

- flow-through test system	428990-02

Rainbow Trout (Oncorhynchus mykiss)	Copper 8 80%	LC50 = 0.0097

NOAEC = 0.0071	Very highly toxic	Yes (core)

- 96-hr test duration

- static renewal test system	435637-01

Coho Salmon (Oncorhynchus kisutch)	Copper 8 100%	LC50 = 0.0139

NOAEC = 0.0066	Very highly toxic	Yes (core)

- 96-hr test duration

- flow-through test system	429024-01



	Freshwater acute toxicity tests indicate that copper 8 is very highly
toxic to the coldwater rainbow trout and very highly toxic to the
warmwater bluegill sunfish on an acute basis.  Guideline requirement
OPPTS 850.1075 (72-1a&b) is fulfilled.  Because acute toxicity to fish
is <1.0 mg/L the environmental hazard section of copper 8 labels must
state: “This pesticide is toxic to fish.”

(2)	Freshwater Invertebrates, Acute

	The Agency requires a freshwater aquatic invertebrate study using the
TGAI to establish the acute toxicity to freshwater invertebrates.  The
preferred test species is Daphnia magna.  The results of one study
submitted for copper 8 is provided in the following table (Table 4).

	Table 4.  Acute Toxicity of Copper 8 to Freshwater Invertebrates

 

Species	

Chemical,

% Active Ingredient

(a.i.)

Tested	

Endpoint

(mg/L)	

Toxicity Category	

Satisfies Guidelines/

Comments	

Reference

(MRID No.)

Waterflea (Daphnia magna)	Copper 8 

98%	EC50 = 0.162

NOAEC = < 0.036 	Highly toxic	Yes (core)

-	48-hr test duration

-	flow-through test system 	432284-01



	The results of MRID 432284-01 indicate that copper 8 is highly toxic to
freshwater invertebrates.  This study fulfills guideline requirement
OPPTS 850.1010 (72.2a).  Because the acute aquatic invertebrate toxicity
value is < 1.0 mg/L, the environmental hazard section of copper 8 labels
must state:  “This pesticide is toxic to aquatic invertebrates.”

(3)	Estuarine and Marine Organisms, Acute

	Acute toxicity testing with estuarine and marine organisms using the
TGAI is required when the end-use product is intended for direct
application to the marine/estuarine environment or effluent containing
the active ingredient is expected to reach this environment.  The
preferred fish test species is the sheepshead minnow.  The preferred
invertebrate test species are mysid shrimp and eastern oysters.  This
testing is required for copper 8 based on the chemical’s potential to
reach estuarine and marine environments.  The results of one toxicity
study submitted for copper 8 is presented in Table 5.



Table 5.  Acute Toxicity of Copper 8 to Estuarine and Marine Organisms

Species	

Chemical,

% Active Ingredient

(a.i.)

Tested	

Endpoint

(mg/L)	

Toxicity Category	

Satisfies Guidelines/

Comments	

Reference

(MRID No.)

Eastern oyster (Crassostrea virginica)	Copper 8 

100%	LC50  = 0.0363

EC50 = 0.0111

NOAEC = 0.003	Very highly toxic	Yes (core)

-	48-hr test duration 

-	static test system	428990-04



	The results of the one core study indicate that copper 8 is very highly
toxic to estuarine/marine invertebrates on an acute basis.  The Eastern
oyster study (428990-04) fulfills the guideline requirement OPPTS
850.1025/(72-3b) for an acute estuarine/marine mollusk study. Study MRID
429024-02 for mysid shrimp is INVALID and must be repeated.  The
guideline requirements OPPTS 850.1075/(72-3a) for an acute
estuarine/marine fish study and OPPTS 850.1035/(72-3c) for an
estuarine/marine shrimp study are not fulfilled.  Because
estuarine/marine acute toxicity values are < 1.0 mg/L, the environmental
hazard section of copper 8 labels must state:  “This pesticide is
toxic to oysters and shrimp.”

 (4)	Aquatic Organisms, Chronic

	Chronic toxicity testing (fish early life stage and aquatic
invertebrate life cycle) is required for pesticides when certain
conditions of use and environmental fate apply.  Preferred freshwater
and estuarine/marine fish and invertebrate species include:  fathead
minnow, rainbow trout, Daphnia magna, and mysid shrimp.  Two studies
were submitted for copper 8, but are INVALID and must be repeated.  The
rainbow trout study (429024-03) does not fulfill the guideline
requirement for a fish early life stage toxicity test (72-4a/OPPTS
850.1400) due to the percent RSD of weight in one replicate of the
solvent control being >40%. The study on the waterflea (428990-05) also
does not fulfill the guideline requirement for a chronic aquatic
invertebrate because dissolved oxygen concentrations fell to extremely
low levels during the test and the highest measured concentration in one
exposure solution was greater than twice the lowest measured
concentration at the same level. 

Toxicity to Plants

	Non-target plant phytotoxicity testing is required for pesticides when
certain conditions of use and environmental fate apply.  The use of
copper 8 as a wood treatment may result in chemical leachate from
treated wood into the aquatic environment.  Aquatic plant toxicity data
are necessary for a non-target plant risk assessment.  Testing is
conducted with one species of aquatic vascular plant (Lemna gibba) and
four species of algae:  (1) freshwater green alga, Selenastrum
capricornutum, (2) marine diatom, Skeletonema costatum, (3) freshwater
diatom, Navicula pelliculosa, and (4) bluegreen cyanobacteria, Anabaena
flos-aquae.  The rooted aquatic macrophyte rice (Oryza sativa) is also
tested in seedling emergence and vegetative vigor tests.

	Two marine diatom studies and a saltwater green algae study were
reviewed. Results of these studies are presented in Table 7.

Table 7.  Toxicity of Copper 8 to Aquatic Plants

Species	

Chemical,

% Active Ingredient

(a.i.)

Tested	

Endpoint 

(mg/L)	

Satisfies Guidelines/

Comments	

Reference

(MRID No.)

Marine diatom (Nitzschia punctata)	Copper 8

100%	EC50 = 0.0073	No (supplemental)

- 5-day test duration

-  static test system

-  NOEC not determined	429024-04

Marine diatom (Skeletonema costatum)	Copper 8

98%	EC50 = 0.0019

NOEC = < 0.0007	Yes (core)

- 5-day test duration

- static test system

	430735-01

Saltwater Green alga (Dunaliella tertiolecta)	Copper 8

100%	EC50 = 0.0154

NOEC = 0.009	Yes (core)

- 5-day test duration

- static test system 	429024-05



	The studies above are classified as acceptable and partially fulfill
the guideline requirements for an algae toxicity test (850.5400, 123-2).
 Three additional algal toxicity tests under 850.5400 are outstanding: 
freshwater diatom (Navicula pelliculosa), blue-green cyanobacteria
(Anabeana flos-aquae), and freshwater green alga (Selenastrum
capricornutum).  Other outstanding non-target aquatic plant toxicity
tests are:  floating freshwater aquatic macrophyte duckweed (Lemna
gibba) – 850.4400 and rooted freshwater macrophyte rice (Oryza sativa)
– 850.4225 and 850.4250 (2 tests on seedling emergence and vegetative
vigor).  

II.	Risk Assessment and Characterization

	Copper 8-quinolinolate uses are classified as “indoor” with the
exception of the wood treatment uses.  An ecological risk assessment is
not typically conducted for “indoor” uses.  A risk assessment for
the wood preservative uses is conducted below using the toxicity values
from section I and estimated environmental concentrations (EECs)
calculated by modeling copper 8 leaching into a body of water from a
dock.  These values were used to develop risk quotients (RQs) and
compare them to levels of concern (LOCs) in section B below.

    	A.        Environmental Fate Assessment Summary 

Copper 8-quinolinolate is hydrolytically stable at pH 5, 7 and 9. More
than 80% of it is stable in aerobic and anaerobic soils. In aerobic
soils its half-life is 16 weeks, but it may be over one year in
anaerobic soils.  It does not show any tendency to migrate from top
soil. It is therefore likely to contaminate surface water through
surface water run-off. Its degradation pathway appears to be aqueous
photolysis with a half-life of 60 to 96 hours.  The estimated log Kow
for copper 8-quinolinolate is 2.5, which indicates that it is not likely
to bioaccumulate in aquatic organisms like fish.

B.	Environmental Exposure and Ecological Risk Assessment

Risk assessment integrates the results of the exposure and ecotoxicity
data to evaluate the likelihood of adverse ecological effects. One
method of integrating the results of exposure and ecotoxicity data is
called the quotient method.  For this method, risk quotients (RQs) are
calculated by dividing exposure estimates by ecotoxicity values, both
acute and chronic:  

       

           RQ = EXPOSURE/TOXICITY 

 

RQs are then compared to levels of concern (LOCs).  These LOCs are
criteria used by OPP to indicate potential risk to nontarget organisms
and the need to consider regulatory action.  The criteria indicate that
a pesticide used as directed has the potential to cause adverse effects
on nontarget organisms.  LOCs currently address the following risk
presumption categories: (1) acute - the potential for acute risk is
high, regulatory action may be warranted in addition to restricted use
classification; (2) acute restricted use - the potential for acute risk
is high, but this may be mitigated through restricted use
classification; (3) acute endangered species - the potential for acute
risk to endangered species is high, and regulatory action may be
warranted, and (4) chronic risk - the potential for chronic risk is
high, and regulatory action may be warranted, (5) non-endangered plant
risk – potential for effects in non-target plants, and (6) endangered
plant risk – potential for effects in endangered plants.   Currently,
EPA does not perform assessments for chronic risk to plants, acute or
chronic risks to nontarget insects, or chronic risk from granular/bait
formulations to birds or mammals.

The ecotoxicity test values (measurement endpoints) used in the acute
and chronic risk quotients are derived from required studies.  Examples
of ecotoxicity values derived from short-term laboratory studies that
assess acute effects are: (1) LC50 (fish and birds), (2) LD50 (birds and
mammals), (3) EC50 (aquatic plants and aquatic invertebrates) and (4)
EC25 (terrestrial plants).  Examples of toxicity test effect levels
derived from the results of long-term laboratory studies that assess
chronic effects are: (1) LOAEC (birds, fish, and aquatic invertebrates),
and (2) NOAEC (birds, fish and aquatic invertebrates). For birds and
mammals, the NOAEC generally is used as the ecotoxicity test value in
assessing chronic effects, although other values may be used when
justified. However, the NOAEC is used if the measurement endpoint is
production of offspring or survival.  Risk presumptions, along with the
corresponding RQs and LOCs are tabulated below.





Risk Presumptions for Terrestrial Animals



Risk Presumption	

RQ	

LOC



Birds and Wild Mammals



Acute Risk	

EEC1/LC50 or LD50/sqft2 or LD50/day3	

0.5



Acute Restricted Use	

EEC/LC50 or LD50/sqft or LD50/day (or LD50 < 50 mg/kg)	

0.2



Acute Endangered Species	

EEC/LC50 or LD50/sqft or LD50/day 	

0.1



Chronic Risk	

EEC/NOAEC	

1

 1  abbreviation for Estimated Environmental Concentration (ppm) on
avian/mammalian food items   

 2    mg/ft2             	3  mg of toxicant consumed/day

   LD50 * wt. of bird             	LD50 * wt. of bird  

Risk Presumptions for Aquatic Animals	 



Risk Presumption	

RQ 	

LOC



Acute Risk	

EEC1/LC50 or EC50	

0.5



Acute Restricted Use	

EEC/LC50 or EC50	

0.1



Acute Endangered Species	

EEC/LC50 or EC50	

0.05



Chronic Risk	

EEC/MATC2 or NOAEC	

1



 1  EEC = (ppm or ppb) in water

 2  MATC = maximum allowable toxicant concentration

Risk Presumptions for Plants	

	





Risk Presumption	

RQ	

LOC



Terrestrial and Semi-Aquatic Plants 



Acute Risk	

EEC/EC25	

1



Acute Endangered Species	

EEC/EC05 or NOAEC	

1



Aquatic Plants



Acute Risk	

EEC1/EC50	

1



Acute Endangered Species	

EEC/EC05 or NOAEC 	

1



EEC = (ppb/ppm) in water 



Maximum Expected Environmental Concentrations:

	EPA calculated the leaching of copper 8 from a dock into water.  It was
assumed that 4% of the total applied copper 8 would leach from the wood
into the water.  The retention rate of the wood was assumed to be 22
(g/cm2.  The length and width of the dock was assumed to be 30 meters
and 10 meters, respectively, and the thickness of the wood was assumed
to be 0.1 meters.  The number of poles underneath the dock was assumed
to be 18 and the dimensions of the poles were assumed to be 2 meters
(length) x 0.15 meters (width) x 0.15 meters (height).  The poles were
assumed to be 0.5 meters inserted into the sediment.  Based on these
specifications, copper 8 EECs were calculated for water body sizes
ranging from 1 acre foot to 24 acre feet.  The highest EEC calculated
for the smallest body of water (1 acre foot) was 0.00226 mg copper 8 per
liter of water.  The calculated EEC for a slightly larger body of water
(6 acre feet) is 0.00038 mg copper 8 per liter of water.  For details on
the calculations conducted to arrive at this EEC as well as the
uncertainties and limitations of the calculations, consult Siroos
Mostaghimi’s 4/25/2007 memo “Estimated Environmental Concentrations
for Copper 8-Quinolinolate (Cu8Q) from Treated Wood Used to Build
Docks.”

Maximum Ecotoxicity Values:

From the toxicity tables in section I above, the highest toxicity in an
acceptable fish study was achieved in a study on the rainbow trout
(Oncorhynchus mykiss).  The LC50 value obtained in this study was 0.0089
mg/L (MRID 428990-02).  The EC50 value obtained in the study on the
freshwater invertebrate (Daphnia magna) was 0.162 mg/L (MRID 432284-01).
 The EC50 value obtained in the study on the eastern oyster (Crassostrea
virginica) was 0.0111 mg/L (MRID 428990-04).  There were no acceptable
acute toxicity studies for estuarine and marine fish or shrimp nor were
there any acceptable chronic toxicity studies available for aquatic
organisms.  Therefore, risk to these species cannot be assessed.  The
highest toxicity in an acceptable aquatic plant toxicity study was
achieved in a study on the marine diatom (Skeletonema costatum).  The
EC50 value obtained in this study was 0.0019 mg/L and the NOEC was <
0.0007 (MRID 430735-01).   Due to outstanding plant toxicity studies,
the non-target plant risk assessment is incomplete.

Acute Freshwater Fish LOC’s:

Comparing the maximum calculated EEC (0.00226 mg/L) to the highest
toxicity found in a fish acute study (0.0089 mg/L), an RQ of 0.254 is
obtained.  This is less than the LOCs for acute and chronic risks to
aquatic animals but greater than the LOCs for endangered species and
acute restricted use.  Therefore, there is the potential for copper 8 to
cause adverse effects to endangered freshwater fish and these risks may
need to be mitigated.  The calculated EEC for a slightly larger body of
water (6 acre feet) is 0.00038 mg copper 8 per liter of water.  This EEC
brings the RQ for freshwater fish down to 0.043, therefore the risk to
endangered fish species is no longer considered significant in this size
body of water.  However, as discussed below an endangered species effect
determination will not be made at this time.

Acute Freshwater Aquatic Invertebrate LOC’s:

Comparing the maximum calculated EEC to the toxicity value found in the
study on the freshwater invertebrate (0.162 mg/L), an RQ of 0.014 is
obtained.  This is less than all LOCs for aquatic organisms, therefore
the potential for risks from copper 8 to aquatic invertebrates is not
high.  The calculated EEC for a slightly larger body of water (6 acre
feet) is 0.00038 mg copper 8 per liter of water.  The calculated RQ is
less than 0.00 and therefore no risk is triggered for a larger water
body.  However, as discussed below an endangered species effect
determination will not be made at this time.

Acute Aquatic Estuarine/Marine Species:

For the eastern oyster, the RQ is 0.204.  This is less than the LOCs for
acute and chronic risks to aquatic animals but greater than the LOCs for
endangered species and acute restricted use.  Therefore, there is the
potential for copper 8 to cause adverse effects to endangered estuarine
and marine organisms and these risks may need to be mitigated.  The
calculated EEC for a slightly larger body of water (6 acre feet) is
0.00038 mg copper 8 per liter of water.  This EEC brings the RQ for the
eastern oyster down to 0.034 and the RQ for aquatic plants down to 0.2
so the risks to endangered estuarine/marine organisms and aquatic plants
are no longer considered significant either.  This risk assessment is
incomplete due to outstanding fish and shrimp toxicity studies.

Chronic Aquatic Toxicity Studies:

	Chronic freshwater fish and invertebrate studies are triggered based on
acute toxicity.  No valid studies are available for copper 8. 
Estuarine/marine chronic toxicity studies for fish and invertebrates are
required.  This risk assessment is incomplete.

Plant Toxicity Studies:

Comparing the maximum calculated EEC (0.00226 mg/L) to the highest
toxicity value found for aquatic plants (0.0019 mg/L), an RQ of 1.189 is
obtained.  This is greater than the LOC of >1.0 and therefore there is
the potential for acute risk to aquatic plants, including endangered
species, from copper 8.  The calculated EEC for a slightly larger body
of water (6 acre feet) is 0.00038 mg copper 8 per liter of water.  This
EEC brings the RQ for aquatic plants down to 0.2 so the risks to
endangered estuarine/marine organisms and aquatic plants are no longer
considered significant for the larger body of water.  This risk
assessment is incomplete due to outstanding plant toxicity studies.

Avian and Mammalian Species:

Based on available avian toxicity data for copper 8, the various wood
treatments are not expected to be acutely toxic.

Uncertainties and Limitations:

	Fate and Environmental Modeling:  There are a number of uncertainties
and limitations with this preliminary environmental risk assessment. 
Extrapolating risk conclusions from the pond scenario used in the
environmental modeling may either underestimate or overestimate
potential exposures and risks. Numerous uncertainties exist with the
modeling used since environmental properties are likely to be regionally
specific because of local hydrogeological conditions.  Further, any
alteration in water quality parameters may impact the environmental
behavior of the pesticide.  Additionally, there are pertinent data (wood
leaching) lacking; such data would be useful in refining this
preliminary risk assessment.

	Toxicity Data:  This screening level risk assessment relies on selected
toxicity endpoints from what are believed to be the most sensitive
species tested, but it does not necessarily mean that the selected
toxicity endpoints reflect sensitivity of the most sensitive species
existing in a given environment.  Surrogates were used to predict
potential risks for various species, and data for several species are
lacking.  Submission of additional non-target organism data will refine
this screening level assessment.

	Stakeholder Modeling Efforts:  The American Chemistry Council (ACC)
Biocides Panel Copper Reregistration Task Force is presently developing
modeling pertinent to the wood preservative and roofing uses of various
copper products.  This modeling effort is intended to provide estimated
environmental exposures which can be used by the Agency to refine
environmental assessments.  Such data would be useful in refining this
screening level assessment.

      Endangered Species Considerations

Section 7 of the Endangered Species Act, 16 U.S.C. Section 1536(a)(2),
requires all federal agencies to consult with the National Marine
Fisheries Service (NMFS) for marine and anadromous listed species, or
the United States Fish and Wildlife Services (FWS) for listed wildlife
and freshwater organisms, if they are proposing an "action" that may
affect listed species or their designated habitat.  Each federal agency
is required under the Act to insure that any action they authorize,
fund, or carry out is not likely to jeopardize the continued existence
of a listed species or result in the destruction or adverse modification
of designated critical habitat.  To jeopardize the continued existence
of a listed species means "to engage in an action that reasonably would
be expected, directly or indirectly, to reduce appreciably the
likelihood of both the survival and recovery of a listed species in the
wild by reducing the reproduction, numbers, or distribution of the
species." 50 C.F.R. ( 402.02.

To facilitate compliance with the requirements of the Endangered Species
Act subsection (a)(2) the Environmental Protection Agency, Office of
Pesticide Programs has established procedures to evaluate whether a
proposed registration action may directly or indirectly reduce
appreciably the likelihood of both the survival and recovery of a listed
species in the wild by reducing the reproduction, numbers, or
distribution of any listed species (U.S. EPA 2004).  After the
Agency’s screening-level risk assessment is performed, if any of the
Agency’s Listed Species LOC Criteria are exceeded for either direct or
indirect effects, a determination is made to identify if any listed or
candidate species may co-occur in the area of the proposed pesticide
use.  If determined that listed or candidate species may be present in
the proposed use areas, further biological assessment is undertaken. 
The extent to which listed species may be at risk then determines the
need for the development of a more comprehensive consultation package as
required by the Endangered Species Act.

For certain use categories, the Agency assumes there will be minimal
environmental exposure, and only a minimal toxicity data set is required
(Overview of the Ecological Risk Assessment Process in the Office of
Pesticide Programs U.S. Environmental Protection Agency - Endangered and
Threatened Species Effects Determinations, 1/23/04, Appendix A, Section
IIB, pg.81).  Chemicals in these categories therefore do not undergo a
full screening-level risk assessment, and are considered to fall under a
“No Effect” determination.  The materials preservative uses of
copper 8-quinolinolate fall into this category.

	The preliminary analysis for wood treatment uses indicates that there
is a potential for copper 8 use to overlap with listed species and that
a more refined assessment is warranted, to include direct, indirect and
habitat effects.  The more refined assessment should involve clear
delineation of the action area associated with proposed use of copper 8
and best available information on the temporal and spatial co-location
of listed species with respect to the action area.  This analysis has
not been conducted for this assessment.  An endangered species effect
determination will not be made at this time.  The wood runoff label
statement is expected to provide some level of mitigation until such
time as a full endangered species assessment is possible.

Confirmatory Data Required To Support Wood Treatment Use:

Estuarine/marine fish acute study (850.1075),

Estuarine/marine shrimp acute study (850.1035),      

Acute sediment toxicity to freshwater invertebrates (850.1735),

Acute sediment toxicity to estuarine invertebrates (850.1740),

Aquatic invertebrate (freshwater) life-cycle study (850.1300),

Fish early life-stage (freshwater) study (850.1400),1

Fish early life-stage (estuarine/marine) study (850.1400),1

Chronic mysid shrimp study (850.1350),1

Freshwater diatom (850.5400),

Blue-green cyanobacteria (850.5400),

Freshwater green alga (850.5400),

Freshwater floating macrophyte duckweed (850.4400),

Freshwater rooted macrophyte rice seedling emergence (850.4225),

Freshwater rooted macrophyte rice vegetative vigor (850.4250),

Wood leaching study (AWPA E11-06),

Environmental runoff monitoring study (None).  This test can be waived
provided labels are amended as outlined below for wood preservative
labels,

Residues in honey/beeswax and toxicity of treated wood residues to bees
– combination of Guideline 860.1500 and 850.3030 (“Honey Bee
Toxicity of Residues on Foliage.”).  The toxicity portion of this
study is in lieu of the honeybee contact LD50 test 850.3020.  The
residue and toxicity test can be waived provided the label is amended to
prohibit the use of treated wood for beehive construction, with a
statement such as, “Wood treated with copper 8-quinolinolate shall not
be used in the construction of beehives.”

  

IV.	 Label Hazard Statements for Terrestrial and Aquatic Organisms and
Use                              Recommendations

Copper 8-quinolinolate labels must state:  

“This pesticide is toxic to fish, aquatic invertebrates, oysters, and
shrimp.”

"Do not discharge effluent containing this product into lakes, streams,
ponds, estuaries, oceans, or other waters unless in accordance with the
requirements of a National Pollutant Discharge Elimination System
(NPDES) permit and the permitting authorities are notified in writing
prior to discharge.  Do not discharge effluent containing this product
to sewer systems without previously notifying the local sewage treatment
plant authority.  For guidance contact your State Water Board or
Regional Office of the EPA."

Wood preservative labels must state:  

"Treated lumber must be stored under cover, indoors, or at least 100
feet from any pond, lake, stream, wetland, or river to prevent possible
runoff of the product into the waterway.  Treated lumber stored within
100 feet of a pond, lake, stream, wetland, or river must be either
covered with plastic or surrounded by a berm to prevent surface water
runoff into the nearby waterway.  If a berm or curb is used around the
site, it should consist of impermeable material (clay, asphalt,
concrete) and be of sufficient height to prevent runoff during heavy
rainfall events.”

“Wood treated with copper 8-quinolinolate shall not be used in the
construction of beehives.”  (Note:  If this statement is not added to
wood preservation labels, bee studies are required as noted above.) 

REFERENCES

42899002  Ward, G. (1993) Oxine Copper (Copper 8-Quinolinolate): Acute
Toxicity to Rainbow Trout, Oncorhynchus mykiss, Under Flow-Through Test
Conditions: Lab Project Number: J9006014A.  Unpublished study prepared
by Toxikon Environmental Sciences.  43p.

42899003  Ward, G. (1993) Oxine Copper (Copper 8-Quinolinolate): Acute
Toxicity to Bluegill, Lepomis macrochirus, Under Flow-Through Test
Conditions: Lab Project Number: J9006014B.  Unpublished study prepared
by Toxikon Environmental Sciences.  44p.

42899004  Ward, G.; Davis, J. (1993) Oxine Copper (Copper
8-Quinolinolate): Acute Toxicity to Embryos and Larvae of the Eastern
Oyster, Crassostrea virginica, Under Static Test Conditions: Lab Project
Number: J9006014I.  Unpublished study prepared by Toxikon Environmental
Sciences.  45p.

42899005  Ward, G. (1993) Oxine Copper (Copper 8-Quinolinolate): Chronic
Toxicity to the Water Flea, Daphnia magna, Under Flow-Through Test
Conditions: Lab Project Number: J9006014F.  Unpublished study prepared
by Toxikon Environmental Sciences.  52p.

42902401  Carr, K.; Ward, G. (1993) Oxine Copper (Copper
8-Quinolinolate): Acute Toxicity to Coho Salmon, Oncorhynchus kisutch,
Under Flow-Through Test Conditions: Lab Project Number: J9006014C. 
Unpublished study prepared by Toxikon Environmental Sciences.  44p.

42902402  Ward, G. (1993) Oxine Copper (Copper 8-Quinolinolate): Acute
Toxicity to the Mysid, Mysidopsis bahia, Under Flow-Through Test
Conditions: Lab Project Number: J9006014J.  Unpublished study prepared
by Toxikon Environmental Sciences.  42p.

42902403  Lintott, D.; Ward, G. (1993) Oxine Copper (Copper
8-Quinolinolate): Toxicity to Embryos and Lavae of the Rainbow Trout,
Oncorhynchus mykiss, Under Flow-Through Test Conditions: Lab Project
Number: J9006014E.  Unpublished study prepared by Toxikon Environmental
Sciences.  64p.

42902404  Ward, G. (1993) Oxine Copper (Copper 8-Quinolinolate):
Toxicity to the Saltwater Alga, Nitzschia punctata, Under Static Test
Conditions: Lab Project Number: J9006014M.  Unpublished study prepared
by Toxikon Environmental Sciences.  46p.

42902405  Ward, G. (1993) Oxine Copper (Copper 8-Quinolinolate): Acute
Toxicity to the Saltwater Green Alga, Dunaliella tertiolecta, Under
Static Test Conditions: Lab Project Number: J9006014L.  Unpublished
study prepared by Toxikon Environmental Sciences.  46p.

42927101  Hakin, B.; Rodgers, M.; Grutzner, I. (1991) Ro 17-0099/000
(Copper 8-Quinolinolate): Acute Oral Toxicity (LD50) to the Bobwhite
Quail: Lab Project Number: HLR 184-901854: RCC 284253.  Unpublished
study prepared by Huntingdon Research Centre Ltd.; RCC UMWELTCHEMIE AG.
53p.

42927102  Hakin, B.; Rodgers, M.; Grutzner, I. (1991) Ro 17-0099/000
(Copper 8-Quinolinolate): Acute Oral Toxicity to Mallard Duck: Lab
Project Number: HLR 185-901733: RCC 284264.  Unpublished study prepared
by Huntingdon Research Centre Ltd.; RCC UMWELTCHEMIE AG. 38p.

42927103  Hakin, B.; Rodgers, M.; Grutzner, I. (1991) Ro 17-0099/000
(Copper 8-Quinolinolate): Dietary Toxicity (LC50) to Bobwhite Quail: Lab
Project Number: HLR 187-901685: RCC 279854.  Unpublished study prepared
by Huntingdon Research Centre Ltd.; RCC UMWELTCHEMIE AG. 39p.

42927104  Hakin, B.; Rodgers, M.; Grutzner, I. (1991) Ro 17-0099/000
(Copper 8-Quinolinolate): Dietary Toxicity (LC50) to the Mallard Duck:
Lab Project Number: HLR 186-901684: RCC 274228.  Unpublished study
prepared by Huntingdon Research Centre Ltd.; RCC UMWELTCHEMIE AG. 39p.

43073501  Ward, G. (1993) Oxine Copper (Copper 8-Quinolinolate): Acute
Toxicity to the Freshwater Alga, Skeletonema costatum, Under Static Test
Conditions: Lab Project Number: J9006014K.  Unpublished study prepared
by Toxikon Environmental Sciences.  45p.

43228401  Ward, G. (1994) Oxine Copper (Copper 8-Quinolinolate): Acute
Toxicity to the Water Flea, Daphnia magna, Under Flow-Through Test
Conditions: Lab Project Number: J9006014D.  Unpublished study prepared
by Toxikon Environmental Sciences.  44p.

43563701  Nozaka, T. (1995) Acute Toxicity of Copper 8-Quinolinolate to
Rainbow Trout: English Version: Lab Project Number: 90753:E89-0753. 
Unpublished study prepared by Kurume Research Labs.  12p.

	

  Testing with the more sensitive species (freshwater or
estuarine/marine) based on acute toxicity test results is required.

  Testing with the more sensitive species (freshwater or
estuarine/marine) based on acute toxicity test results is required.

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	D R A F T

