UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

WASHINGTON, DC 20460

			OFFICE OF  PREVENTION, PESTICIDES,  AND TOXIC SUBSTANCES

 

MEMORANDUM							February 20, 2007

SUBJECT: 	DIETARY EXPOSURE ASSESSMENT OF COPPER NAPHTHENATE AS A WOOD
PRESERVATIVE FOR REREGISTRATION ELIGIBILITY DECISION (Case# 3099)

From:	A. Najm Shamim, PhD., Chemist

	Regulatory  Management Branch II

	Antimicrobials Division (7510P)

To:	Tim McMahon,  PhD., Senior Toxicologist and Risk Assessor

	Antimicrobials Division (7510P)

			And

	Kathryn Jakob, CRM for Copper Naphthenate

	Regulatory Management Branch II

	Antimicrobials Division (7510P)

Thru:	Diane Isbell, Acting Team Leader, 

	Regulatory Management Branch II

	Antimicrobials Division (7510P)

			And

	Mark Hartman, Chief

	Regulatory Management Branch II

	Antimicrobials Division (7510P)

DIETARY EXPOSURE ASSESSMENT OF COPPER NAPHTHENATE  FOR REREGISTRATION
ELEIGIBILITY DECISION(Case # 3099)

Executive Summary

In order to conduct the dietary exposure  assessment Antimicrobials does
the label database search and all those applications that involve the
indirect food contact with the pesticidal use of the specific chemical
is assessed for any dietary concerns from indirect migration of the
pesticide into foods, fruits and vegetables. In our foregoing REDs on
antimicrobials we have used with modifications Food and Drug
Administration  (FDA) methodologies. 

Label searches for copper naphthenate (Case # 3099) has resulted in the
following use sites:  1) Copper naphthenate is used as a wood
preservative  when applied  through surface and pressure treatments. It
is used as a surface wrap, for above and below ground contacts  for
poles, posts, pilings, wood seals,  to treat termites, wood eating
insects. Surface treatment is through spray and or brush.

2) Wood boats, shingles, doors, windows, frames, stairs, sills, porches.
For treatments against carpenter ants, rot, fungi, mildew.

3) It is also used for marine pilings.

All the use sites listed are not likely to result in any indirect food
migration of  copper naphthenate into food, fruits or vegetable in
residential scenarios.   No estimated Daily intake (EDI) is likely to
result. AD, therefore has not conducted any dietary exposure assessment
for copper napththenate.

AD has no dietary concerns with the use patterns of copper napththenate
used primarily as a wood preservative.

