![](media/image1.png){width="1.4993055555555554in"
height="1.5416666666666667in"}

**UNITED STATES ENVIRONMENTAL PROTECTION AGENCY**

**WASHINGTON, D.C. 20460**

**OFFICE OF**

**PREVENTION, PESTICIDES AND**

**TOXIC SUBSTANCES**

> March 7, 2008

**[MEMORANDUM]{.underline}**

**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          **OPP Chemical Codes:**
                          Numbers:**              

  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]{.underline} [Registered Products]{.underline}**

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]{.underline}**: Fungicide, Insecticide, Miticide,
and Sporicide

> **[USE SITES]{.underline}:** 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]{.underline}**

> (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]{.underline}**

(e.g., Pilings, Posts)

Wood or Wood Structure Protection Treatments:

> \- Pressurized Wood Protection Treatment to Wooden Aquatic Structures
> and Items

**[TARGET PESTS]{.underline}:**

**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]{.underline}**:

> 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.]{.underline}
[Products]{.underline}**

> 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]{.underline}**:

> The following covers [only]{.underline} those application rates which
> are specified on the Creosote product labeling:

**[Terrestrial Non-Food Crop]{.underline}**

[**Wood Pressure Treatment to Forest Products**:]{.underline}

Wood Protection Treatment by Pressure (Pressure Treating Vessel) - apply
at rate of 12 lbs. per cu. ft..

**[Aquatic Non-Food Outdoor]{.underline}**

[**Wood Pressure Treatment to Aquatic Structures/Items**:]{.underline}

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.