Docket Number: EPA-HQ-OPP-2010-0455 

www.regulations.gov

United States Chemical Safety September 2010 

 Environmental Protection and Pollution Prevention 

 Agency (7510P) 

 

Naphthenate Salts (copper naphthenate 

and zinc naphthenate)Summary 

Document: Registration Review 

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TABLE OF CONTENTS 

Naphthenate Salts (copper naphthenate and zinc naphthenate) 

Registration Review Team ............................................................................................... 4 

I. PRELIMINARY WORK PLAN – Naphthenate Salts ............................................... 5 

II. FACT SHEET ............................................................................................................ 16 

III. GLOSSARY OF TERMS & ABBREVIATIONS ................................................. 23 

IV. APPENDIX A............................................................................................................ 25 
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Naphthenate Salts (copper naphthenate and zinc naphthenate) 

Registration Review Team 

Human Health & Environmental Effects 

Nathan Mottl 

Srinivas Gowda 

Risk Management

Monisha Harris 

Lance Wormell 

Office of General Counsel

Philip Ross 
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I. PRELIMINARY WORK PLAN – Naphthenate Salts (copper naphthenate and 

zinc naphthenate) 

Introduction

The Food Quality Protection Act (FQPA) of 1996 mandated a registration review 

program. All pesticides distributed or sold in the United States generally must be 

registered by the U.S. Environmental Protection Agency (USEPA, EPA, or the Agency), 

based on scientific data showing that they will not cause unreasonable risks to human 

health or the environment when used as directed on product labeling. The registration 

review program is intended to make sure that, as the ability to assess risk evolves and as 

policies and practices change, all registered pesticides continue to meet the statutory 

standard of no unreasonable adverse effects to human health or the environment. Changes 

in science, public policy, and pesticide use practices will occur over time. Through the 

registration review program, the Agency periodically reevaluates pesticides to make sure 

that as change occurs, products in the marketplace can be used safely. Information on 

this program is provided at http://www.epa.gov/oppsrrd1/registration_review/. 

The Agency is implementing the registration review program pursuant to Section 

3(g) of the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) and will review 

each registered pesticide every 15 years to determine whether it continues to meet the 

FIFRA standard for registration. The Agency will consider benefits information and data 

as required by FIFRA. The public phase of registration review begins when the initial 

docket is opened for each case. The docket is the Agency’s opportunity to state what it 

knows about the pesticide and what additional risk analyses and data or information it 

believes are needed to make a registration review decision. After reviewing and 

responding to comments and data received in the docket during this initial comment 

period, the Agency will develop and commit to a final work plan and schedule for the 

registration review of naphthenate salts (copper naphthenate and zinc naphthenate). 

There are two active ingredients in the naphthenate salts case 3099: copper 

naphthenate (PC Code 023102) and zinc naphthenate (PC Code 088301). Although the 

case name groups these chemicals using the term "naphthenate salts," throughout this 

document and the supporting documents for this case the compounds will be named 

individually as "copper naphthenate" and "zinc naphthenate" to avoid potential confusion. 

Copper and zinc naphthenate are both fatty acid salts also known as metal soaps or 

copper and zinc soaps, which are practically insoluble in water, soluble in organic 

solvents, and have no measurable vapor pressures. 

Copper naphthenate was first registered with the Agency in 1951. There are 30 

registered copper naphthenate products. These are registered for use as a material 

preservative (rope, burlap, canvas products including, nets (except fish nets), seines, 

tents, awnings, textiles, particle board, insulation board, and other wood base fiber and 

particle materials tarpaulins) and as a wood preservative (lumber, timbers, posts, poles, 

and other wooden members, all exterior wood exposed to moisture or weather, wooden 

boat hulls, piers). 
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Zinc naphthenate was first registered with the Agency in 1975. There are 10 

registered zinc naphthenate products. Zinc naphthenate products are registered for use as 

a wood preservative (foundations, boats, construction posts, docks & piers, door frames, 

doors, fence posts, fences, fencing, end cuts, foundation timbers greenhouse wood and 

stakes, house siding, landscape logs lawn furniture, millwork, planking, planter boxes, 

plywood, poles, porches, posts, pressure treated wood end cut protection, roofs, shakes, 

shingles, sidings, sills, stairs, structural logs, structural lumber; structural timber, 

subflooring, windows and frames) and a material preservative (non-apparel fabrics, 

ropes, fishnets, twine, canvas, burlap and other non-apparel fabric material). 

A Reregistration Eligibility Decision (RED) for copper and zinc naphthenate salts was 

issued by EPA in September 2007. The RED can be located at 

http://www.epa.gov/pesticides/reregistration/status.htm. 

Risk Assessment Status & Anticipated Data Needs

Human Health Risk Assessment Status and Anticipated Data Needs 

The Agency has reviewed all the available information on toxicology and human 

exposure regarding copper and zinc naphthenate and does not anticipate that additional 

data will be needed for this registration review case. 

Further human health information is available in the document titled “Human 

Health Effects Data for the Copper and Zinc Naphthenate Registration Review 

Decision,” dated July 19, 2010. 

Dietary and Drinking Water Assessment

Dietary Exposure 

 EPA does not anticipate conducting dietary (food) risk assessments because there 

are no registered food use tolerances for the active ingredients, no registered food uses, 

and no indirect food uses. However, a drinking water assessment is expected. 

Drinking Water Exposure 

Copper and zinc naphthenate products are registered for use in treated wood used 

to construct structures that may result in drinking water (e.g., docks and piers). The 

Agency will model environmental concentrations of the wood preservative uses of copper 

and zinc naphthenate in surface water during the registration review risk assessment 

process and will conduct a drinking water assessment. 
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Tolerances

 There are no tolerances or exemptions from tolerances for the copper and zinc 

naphthenate active ingredients and no registered food uses. There are inert exemptions 

from tolerances for copper naphthenate. However, inert exemptions from tolerances are 

not addressed in this registration review. 

Aggregate and Cumulative Exposure

 In examining aggregate exposure, EPA takes into account the available and 

reliable information concerning exposures to pesticide residues in food and drinking 

water, as well as non-occupational pesticide exposures. Food exposures of concern are 

not anticipated based on the fact that copper or zinc naphthenate are not expected to be 

introduced into food, there are no food use tolerances for the active ingredient, no 

registered food uses, and no indirect food uses. The Agency will conduct surface water 

modeling and a drinking water assessment. The Agency expects to conduct a residential 

assessment to examine hand-to-mouth and dermal exposures to children from playsets 

and decks. The Agency will conduct an aggregate assessment that includes both 

residential and drinking water exposure. 

 Section 40(b)(2)(D)(v) of FFDCA requires that, when considering whether to 

establish, modify, or revoke a tolerance, the Agency considers “available information” 

concerning the cumulative effects of a particular pesticide’s residues and “other 

substances that have a common mechanism of toxicity.” EPA has not yet determined 

whether copper and zinc naphthenate has a common mechanism with other compounds; 

consequently a cumulative assessment will not be performed at this time. 

Occupational and Residential Assessment

 An occupational and/or residential exposure assessment is required for an active 

ingredient if (1) certain toxicological criteria are triggered and (2) there is potential 

exposure to handlers (mixers, loaders, applicators, etc.) during use or to persons entering 

treated sites after application is complete. Based on the available use information, the 

Agency believes there is potential exposure for occupational handlers (i.e., from 

applications of wood preservatives and textiles) and residential handlers (e.g., 

homeowner wood treatment applications). In addition, the Agency expects there also will 

be exposure from occupational post-application exposures (i.e., workers exposed to wood 

treatment facilities) and residential post-application exposure concerns for children (i.e., 

contact with treated wood playsets and decks). Depending on the outcome of the review 

of the new data from the copper and zinc naphthenate RED DCI, the Agency anticipates 

the need to conduct new handler and post-application assessments for registration review. 

 The EPA also anticipates that occupational, residential, and aggregate assessments will 

be needed to ensure that copper and zinc naphthenate registration review case meets the 

safety standards established by FFDCA, as amended by FQPA.
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Hander Exposure 

Occupational Handlers 

 The Agency identified potential occupational handler exposures for copper and 

zinc naphthenate previously in the RED. No other new uses were identified during the 

registration review process. The potential occupational handler risk assessments (both 

short-term (1-30 days) and intermediate-term (>30 days)) by scenario that the Agency 

expects to conduct during registration review include: 

• Incorporation into Textiles During Industrial Manufacturing; 

• Handler Exposure to Workers at Non-pressure Treatment Facilities (i.e., diptank 

operator, blender/spray operator, and chemical operator); 

• Handler Exposure to Workers at Pressure Treatment Facilities (i.e., treatment 

operator and treatment assistant); 

• Handler Exposure to Workers at Commercial Wood/Lumber Facilities; and 

• Application to In-service Utility Poles, Pilings, Posts, and Other Standing 

Timbers. 

 The methods of direct application include liquid pour and liquid pump, low 

pressure spray, brush/roller, non-pressure treatment, pressure treatment, brush, trowel or 

grease gun, and pre-manufactured bandage. 

 

Residential Handlers 

 Residential handler exposure can occur through the application of copper and zinc 

naphthenate preservative coatings via paintbrush or sprayer application. The Agency 

expects to conduct residential handler risk assessments for these scenarios and the 

Agency is likely to conduct a risk assessment only of short-term duration. The short term 

duration was chosen to be assessed because the different scenarios (i.e. methods of 

application) are assumed to be episodic, not daily over the course of a year and would not 

typically exceed 30 days per year. 

Postapplication Exposure 

Occupational 

 The Agency identified potential occupational postapplication exposures for 

copper and zinc naphthenate previously in the RED. No other new uses were identified 

during the registration review process. The potential occupational scenarios include: 

 

• Post-application Exposure to Workers at Sawmills/Planer Mills (e.g., grader, trim 

saw operator, millwright, and clean-up); and, 

• Post-application Exposure to Workers at Pressure Treatment Facilities (e.g., tram 

setter, stacker operator, loader operator, supervisor, test borer, and tallyman). 
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Residential 

 

 The Agency expects that it will need to conduct a residential assessment to 

examine hand-to-mouth and dermal exposures to children from playsets and decks. 

Product Chemistry Status and Anticipated Data Needs 

All product chemistry data requirements have been fulfilled for the active 

ingredient naphthenate salts. Therefore, it is anticipated that no additional product 

chemistry data will be needed for copper and zinc naphthenate salts. 

For further information please refer to the Summary of Product Chemistry, 

Environmental Fate, and Ecotoxicity Data for the Copper Naphthenate and Zinc 

Naphthenate Salts Registration Review Decision Document, dated July 26, 2010. 

Environmental Fate and Ecological Risk Assessment Status and Anticipated Data 

Needs

The Agency does not expect to require additional data through the registration 

review process. The data requested as a result of the September 2007 RED for 

naphthenate salts (copper naphthenate and zinc naphthenate), required through a DCI 

issued on June 9, 2010 will be evaluated and used to support the registration review risk 

assessments. 

For further information please refer to the Summary of Product Chemistry, 

Environmental Fate, and Ecotoxicity Data for the Copper Naphthenate and Zinc 

Naphthenate Salts Registration Review Decision Document, dated July 26, 2010. 

Endangered Species 

The Agency has not conducted a risk assessment that supports a complete 

endangered species determination for naphthenate salts (copper naphthenate and zinc 

naphthenate). The ecological risk assessment planned during registration review will 

allow the Agency to determine whether use of naphthenate salts has “no effect” or “may 

affect” federally listed threatened or endangered species (listed species) or their 

designated critical habitats. When an assessment concludes that a pesticide’s use “may 

affect” a listed species or its designated critical habitat, the Agency will consult with the 

U.S. Fish and Wildlife Service and/or National Marine Fisheries Service (the Services), 

as appropriate. 

Incidents:

Ecological 

There are no reported incidents in the Agency’s Ecological Incident Information 

System (EIIS) involving copper naphthenate or zinc naphthenate. The absence of 

documented incidents does not necessarily mean that incidents did not occur. 
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Human Health 

EPA consulted the following sources of information for human poisoning 

incidents related to copper and zinc naphthenate use: (1) OPP Incident Data System 

(IDS) - The Office of Pesticide Programs (OPP) Incident Data System contains reports of 

incidents from various sources, including registrants, other federal and state health and 

environmental agencies and individual consumers, submitted to OPP since 1992; (2) 

California Department of Pesticide Regulation (1982-2004) – The California Department 

of Pesticide Regulation pesticide poisoning surveillance program consists of reports from 

physicians of illness suspected of being related to pesticide exposure since 1982; (3) 

National Pesticide Information Center (NPIC) - NPIC is a toll-free information service 

supported by OPP that provides a ranking of the top 200 active ingredients for which 

telephone calls were received during calendar years 1984-1991; (4) National Poison 

Control Centers (PCC) (1993-1996); and (5) Published Scientific Literature on Incidents. 

The Agency reviewed available sources of human incident data for incidents 

relevant to copper and zinc naphthenate as part of the 2007 RED. No new incidents have 

been reported to the Agency since the completion of the RED. Since 1992, only one 

incident associated with copper or zinc naphthenate alone has been recorded. The 

incident report noted a strong odor and adverse health effects were reported following 

residential application of copper naphthenate containing wood preservative. However, no 

clear symptoms were described in the report. For incidents involving copper or zinc 

naphthenate in conjunction with other chemicals, the most common symptoms reported 

for cases of ocular exposure were eye irritation/burning. Eye pain and swelling of eyes 

also have been reported in some cases. No incidents of oral exposure have been reported. 
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Timeline:

EPA has created the following estimated timeline for the completion of the 

naphthenate salts (copper naphthenate and zinc naphthenate) registration review: 

Anticipated Schedule

Activities Estimated Month/Year

Phase 1: Opening the docket 

Open Public Comment Period for Naphthenate Salts Docket September 2010 

Close Public Comment Period November 2010 

Phase 2: Case Development 

Develop Final Work Plan (FWP) February 2011 

Open Public Comment Period for Preliminary Risk Assessments June 2013 

Close Public Comment Period August 2013 

Phase 3: Registration Review Decision 

Open Public Comment Period for Proposed Reg. Review Decision October 2014 

Close Public Comment Period January 2015 

Final Decision and Begin Post-Decision Follow-up 2015 

Total (years) 5 

Guidance for Respondents:

The public is invited to comment on EPA’s preliminary registration review work 

plan and rationale. The Agency will carefully consider all comments as well as any 

additional information or data provided in a timely manner prior to issuing a final work 

plan for the naphthenate salts registration review case. 
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Trade Irritants 

Through the registration review process, the Agency intends to solicit information 

on trade irritants and, to the extent feasible, take steps toward facilitating irritant 

resolution. Growers and other stakeholders are asked to comment on any trade irritant 

issues resulting from lack of Maximum Residue Limits (MRLs) or disparities between 

U.S. tolerances and MRLs in key export markets, providing as much specificity as 

possible regarding the nature of the concern. 

Water Quality 

Naphthenate salts is not identified as a cause of impairment for any water bodies 

listed as impaired under section 303(d) of the Clean Water Act, based on information 

provided at 

http://iaspub.epa.gov/tmdl_waters10/attains_nation_cy.cause_detail_303d?p_cause_grou

p_id=885. In addition, no Total Maximum Daily Loads (TMDL) have been developed 

for naphthenate salts, based on information provided at 

http://iaspub.epa.gov/tmdl_waters10/attains_nation.tmdl_pollutant_detail?p_pollutant_gr

oup_id=885&p_pollutant_group_name=PESTICIDES. More information on impaired 

water bodies and TMDLs can be found at http://www.epa.gov/owow/tmdl/. The Agency 

invites submission of water quality data for this pesticide. To the extent possible, data 

should conform to the quality standards in Appendix A of the OPP Standard Operating 

Procedure: Inclusion of Impaired Water Body and Other Water Quality Data in OPP’s 

Registration Review Risk Assessment and Management Process (see: 

http://www.epa.gov/oppsrrd1/registration_review/water_quality_sop.htm) in order to 

ensure they can be used quantitatively or qualitatively in pesticide risk assessments. 

Environmental Justice 

EPA seeks to achieve environmental justice, the fair treatment and meaningful 

involvement of all people, regardless of race, color, national origin, or income, in the 

development, implementation, and enforcement of environmental laws, regulations, and 

policies. To help address potential environmental justice issues, the Agency seeks 

information on any groups or segments of the population who, as a result of their 

location, cultural practices, or other factors, may have atypical, unusually high exposure 

to naphthenate salts compared to the general population. Please comment if you are 

aware of any sub-populations that may have atypical, unusually high exposure compared 

to the general population. 

Structure Activity Relationships 

EPA must rely upon information of appropriate quality and reliability for each 

decision made by the Agency. In the Office of Pesticide Programs (OPP), the evaluation 

process for a pesticide chemical traditionally begins with the applicant’s submission of a 

set of studies conducted with the specific pesticide chemical of interest. The use of the 

results of such testing (measured data) is a logical, scientifically rigorous process that 
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identifies the physical, chemical, and environmental fate properties of the pesticide, as 

well as the dose and endpoints at which an adverse effect can occur in various animal 

species. 

Today, there is significant interest in alternative techniques, i.e., techniques other 

than data generation that could significantly inform the Agency’s decision-making 

process. Recently, OPP has made increasing use of structure activity relationship (SAR) 

as part of its regulatory decision-making process. In the SAR process, a chemical's 

molecular structure is compared to that of other chemicals for which data are available. 

These structural similarities are then used to make predictive judgments about a 

chemical’s physical, chemical, and biological properties. Thus, the chemical’s physical, 

chemical, and biological properties are a function of (or directly related to) the chemical’s 

molecular structure. Quantitative SAR is referred to as QSAR. To develop a QSAR, a 

selected set of measured data on a single physical, chemical, or biological property is 

used to derive a model (an equation) to predict the value of that property. 

 Since SAR assessments and QSAR modeling are another set of tools that are 

available to Agency scientists, OPP has begun a process shift that envisions shifting from 

the current study-by-study approach to an approach in which the use of predicted data, 

generated using validated models, is considered along with information from open 

literature and studies specifically generated under Part 161 requirements. All relevant 

information would be considered as part of a weight-of-the-evidence evaluation. 

At this time, EPA believes that for certain endpoints, especially physical/chemical 

and fate properties, that SAR and QSAR might be effectively utilized to fulfill these data 

requirements for many antimicrobial pesticide chemicals. When considering biological 

properties, at this time, EPA believes that SAR and QSAR can be most effectively 

utilized in the evaluation of chemicals that exhibit lower toxicity for human health and/or 

ecotoxicity parameters. This is appropriate because the risk assessment for lower toxicity 

chemicals can be stream-lined, i.e., a screening-level assessment procedure rather than 

multiple tiers of assessments with progressively more data requirements. 

If stakeholders believe that submission of predicted data can fulfill one of the data 

needs for naphthenate salts, then the Agency invites submission of this information. The 

submitter would be expected to supply a rationale describing the utility of the information 

and provide documentation on the scientific validity of the information. The 

determination that the predicted data fulfills the data requirement would be at the sole 

discretion of the Agency. Pre-submission consultation with the Agency is encouraged. 

Endocrine Disruptor Screening Program 

As required under FFDCA section 408(p), EPA has developed the Endocrine 

Disruptor Screening Program (EDSP) to determine whether certain substances (including 

pesticide active and other ingredients) may have an effect in humans or wildlife similar to 

an effect produced by a “naturally occurring estrogen, or other such endocrine effects as 

the Administrator may designate.” The EDSP employs a two-tiered approach to making 
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the statutorily required determinations. Tier 1 consists of a battery of 11 screening assays 

to identify the potential of a chemical substance to interact with the estrogen, androgen, 

or thyroid (E, A, or T) hormonal systems. Chemicals that go through Tier 1 screening 

and are found to have the potential to interact with E, A, or T hormonal systems will 

proceed to the next stage of the EDSP where EPA will determine which, if any, of the 

Tier 2 tests are necessary based on the available data. Tier 2 testing is designed to 

identify any adverse endocrine related effects caused by the substance, and establish a 

dose-response relationship between the dose and the E, A, or T effect. 

Between October 2009 and February 2010, EPA issued test orders/data call-ins 

for the first group of 67 chemicals, which contains 58 pesticide active ingredients and 9 

inert ingredients. This list of chemicals was selected based on the potential for human 

exposure through pathways such as food and water, residential activity, and certain postapplication agricultural scenarios. This list should not be construed as a list of known or 

likely endocrine disruptors. 

Naphthenate salts is not among the group of 58 pesticide active ingredients on the 

initial list to be screened under the EDSP. Under FFDCA sec. 408(p) the Agency must 

screen all pesticide chemicals. Accordingly, EPA anticipates issuing future EDSP test 

orders/data call-ins for Registration Review cases, including those for which EPA has 

already opened a Registration Review docket for a pesticide active ingredient. 

For further information on the status of the EDSP, the policies and procedures, the 

list of 67 chemicals, the test guidelines and the Tier 1 screening battery, please visit our 

website: http://www.epa.gov/endo/. 

Additional Information 

Stakeholders are also specifically asked to provide available information and data 

that will assist the Agency in refining the risk assessments. The Agency is interested in 

receiving the following information. 

1. Confirmation on the following label information: 

a. Sites of application 

b. Formulations 

c. Application methods and equipment 

d. Maximum application rates 

e. Frequency of application, application intervals and maximum 

number of applications 

f. Geographic limitations on use 

2. Use or potential use distribution 

3. Use history 

4. Usage/use information for non-agricultural uses (e.g., materials 

preservation) 

5. Typical application interval 

6. State or local use restrictions 
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7. Ecological incidents (non-target plant damage and avian, fish, 

reptilian, amphibian and mammalian mortalities) not already reported 

to the Agency 

8. Monitoring data 

9. Structure Activity Relationships 

Next Steps: 

After the 60-day comment period closes in November, 2010, the Agency will 

review and respond to any comments received in a timely manner, and then issue a Final 

Work Plan for Naphthenate Salts (copper naphthenate and zinc naphthenate). 
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II. FACT SHEET 

Background Information

• Chemical Name: naphthenate Salts (copper naphthenate and zinc naphthenate) 

• Common Names: copper salts and zinc salts 

• Registration review case number: 3099 

• PC Code: copper naphthenate 023102 and zinc naphthenate 088301 

• CAS#: copper naphthenate 1338-02-9 and zinc naphthenate 12001-85-3 

• Technical Registrants: 

o copper naphthenate - IBC Manufacturing Co, OMG Americas Inc, OMG 

Belleville Limited, Merichem Chemicals & Refinery Services LLC, and 

Osmose Utilities Services, Inc. 

o zinc naphthenate - OMG Americas Inc and OMG Belleville Limited 

• First approved for use in a registered product: copper naphthenate October 29, 

1951 and zinc naphthenate November 26, 1975 

• There are 30 registered products that contain copper naphthenate and 10 

registered products that contain zinc naphthenate. 

• Antimicrobials Division Chemical Review Manager (CRM): Monisha Harris, 

harris.monisha@epa.gov 

• Antimicrobials Division Product Manager (PM): Jacqueline CampbellMcFarlane, campbell-mcfarlane.jacqueline@epa.gov

Chemical Structure:

Copper naphthenate 

Zinc naphthenate 
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Use & Usage Information

Type of Pesticide: Fungicide and Insecticide 

Antimicrobial Use Sites: 

Materials Preservatives

Rope, burlap, canvas products including, nets (except fish nets), seines, tents, 

awnings, textiles, particle board, insulation board, and other wood base fiber and 

particle materials tarpaulins.

Wood Preservatives

(Exterior use only) Lumber, timbers, posts, poles, and other wooden members, all 

exterior wood exposed to moisture or weather. Wooden boat hulls, piers. 

Recent Regulatory Actions

As part of the RED process, the Agency issued a DCI for naphthenate salts 

(copper naphthenate and zinc naphthenate) on June 9, 2010. Also, the RED 

recommended label changes to minimize the dermal risk of concern from zinc 

naphthenate. The Agency expects to receive updated zinc naphthenate labels within 9 

months of the DCI. The Agency intends to use information from the updated labels 

received in response to the RED to conduct the risk assessments for this registration 

review. 

The RED for copper and zinc naphthenate salts was issued by EPA in September 

2007. http://www.epa.gov/pesticides/reregistration/status.htm

Human Health Risk Assessment Status

 The Agency does not anticipate requiring additional human health data for copper 

and zinc naphthenate for registration review. The toxicity and exposure data required 

recently by DCI as a result of the RED are presented in the RED. 

Further human health information is available in the document titled “Human 

Health Effects Data for the Copper and Zinc Naphthenate Registration Review 

Decision,” dated July 19, 2010. 
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Product Chemistry Database Status

The Agency has reviewed the product chemistry database for the naphthenate 

salts (copper naphthenate and zinc naphthenate) registration review case and anticipates 

that no additional product chemistry data will be needed for registration review because 

all product chemistry data requirements have been satisfied. 

Further information is available in the “Summary of Product Chemistry, 

Environmental Fate, and Ecotoxicity Data for the Copper Naphthenate and Zinc 

Naphthenate Salts Registration Review Decision Document,” dated July 26, 2010. 

Environmental Fate & Ecological Risk Assessment Status

The Agency does not expect to require additional data through the registration 

review process. The data requested as a result of the September 2007 RED for 

naphthenate salts (copper naphthenate and zinc naphthenate), required through a DCI 

issued on June 9, 2010, will be evaluated and used to support the registration review risk 

assessments. 

 The Agency anticipates concluding that the registered uses of naphthenate salts 

(copper naphthenate and zinc naphthenate) will have “no effect” (NE) on endangered or 

threatened terrestrial or aquatic species, or their designated critical habitats, as listed by 

the U.S. Fish and Wildlife Service (USFWS) and the National Oceanic and Atmospheric 

Administration's (NOAA) National Marine Fisheries Service (NMFS). EPA anticipates 

conducting no further analysis of potential risks to endangered or threatened species 

unless public comments provide additional information that would alter the Agency's 

current position that naphthenate salts will have "no effect" on such species or their 

designated critical habitat. 

For further information please refer to the Summary of Product Chemistry, 

Environmental Fate, and Ecotoxicity Data for the Copper Naphthenate and Zinc 

Naphthenate Salts Registration Review Decision Document, dated July 26, 2010. 

Tolerances 

There are no tolerances or exemptions from tolerances for the copper and zinc 

naphthenate active ingredients and no registered food uses. There are inert exemptions 

from tolerances for copper naphthenate. However, inert exemptions from tolerances are 

not addressed in this registration review. 

Data Call-In Status

 

• In November of 1993, EPA issued a GDCI (generic data call-in) for copper 

naphthenate for product chemistry data, human toxicity data, ecological effects 

and environmental fate data. EPA also issued a GDCI for zinc naphthenate for 

ecological effects data and environmental fate data. 
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• In January of 1994, EPA issued a GDCI for copper naphthenate for product 

chemistry data, ecological effects data, and human toxicity data. EPA also issued 

a GDCI for zinc naphthenate for product chemistry data, ecological effects data, 

human toxicity data, human exposure data, and environmental fate data. 

• In May of 1994, EPA issued a GDCI for copper naphthenate for product 

chemistry data, ecological effects data, human toxicity data, and environmental 

fate data. 

• In March of 1997, EPA issued a GDCI for zinc naphthenate for product chemistry 

data, ecological effects data, human toxicity data, and environmental fate data. 

• In June of 2010, EPA issued a GDCI for copper naphthenate for ecological effects 

data, human toxicity data, and human exposure data. EPA also issued a GDCI for 

zinc naphthenate for ecological effects data, human toxicity data, and human 

exposure data. 

• In June of 2010, EPA issued a PDCI (product data call-in) for copper naphthenate 

for product chemistry data and human toxicity data. EPA also issued a PDCI for 

zinc naphthenate for product chemistry data and human toxicity data. The 90-day 

due date is scheduled for October 2010. 

Labels 

There are 30 registered products that contain copper naphthenate and 10 

registered products that contain zinc naphthenate. The EPA registration numbers are 

provided in Table 1 and 2 below. For future reference, during registration review a list of 

product registration numbers will be included in the docket. Product registration labels 

may be obtained from the Pesticide Product Label System (PPLS) website at: 

http://oaspub.epa.gov/pestlabl/ppls.home. 
Docket Number: EPA-HQ-OPP-2010-0455 

www.regulations.gov

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Table 1. Registered Active Products of Copper Naphthenate

Registration # Registration Name Company Name Formulation 

type 

% of Active 

Ingredient 

577-541 Cuprinol Wood 

Preservative 

The SherwinWilliams Co. Ready-to-Use 

Solution 22.3 

1022-409 

Copper Naphthenate 

WR Wood Preservative 

Ready To Use 

IBC Manufacturing 

Co. 

Ready-to-Use 

Solution 25 

1022-507 Copper Naphthenate 1% IBC Manufacturing 

Co. 

Ready-to-Use 

Solution 7.5 

1022-518 Cunapsol-1 IBC Manufacturing 

Co. 

Ready-to-Use 

Solution 9.08 

1022-522 Cunapsol-5 IBC Manufacturing 

Co. 

Soluble 

Concentrate 45.4 

1022-523 Cunapsol-2 IBC Manufacturing 

Co. 

Ready-to-Use 

Solution 18.16 

1022-528 Copper Naphthenate 

Concentration 8% 

IBC Manufacturing 

Co. 

Soluble 

Concentrate 68 

1022-536 POL-NU CURAP 20 IBC Manufacturing 

Co. 

Ready-to-Use 

Solution 18.16 

1022-568 CHAPCO CU-NAP 800 

EC 

IBC Manufacturing 

Co. 

Emulsifiable 

Concentrate 80 

1022-571 CHAPCO CU-NAP 400 IBC Manufacturing 

Co. 

Soluble 

Concentrate 40 

1022-579 CURAP 20 PAK IBC Manufacturing 

Co. 

Ready-to-Use 

Solution 18.16 

1719-43 COP-R-TOX Wood 

Preservative 

Mobile Paint 

Manufacturing 

Company Inc. 

Ready-to-Use 

Solution 22.59 

9630-4 6% Copper Nap-All OMG Americas Inc. Formulation 

Intermediate 67 

9630-5 M-GARD S120 OMG Americas Inc. Formulation 

Intermediate 77 

9630-12 M-GARD S520 OMG Americas Inc. Soluble 

Concentrate 80 

43437-4 8% Copper Naphthenate OMG Belleville 

Limited 

Soluble 

Concentrate 89 

60061-16 No. 00 Ready To Use 

Copper Treat Kop-Coat, Inc. Ready-to-Use Solution 21.6 

60061-19 Copper Treat 120 Kop-Coat, Inc. Ready-to-Use 21.6 
Docket Number: EPA-HQ-OPP-2010-0455 

www.regulations.gov

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Registration # Registration Name Company Name Formulation 

type 

% of Active 

Ingredient 

Ready-To-Use Solution 

66591-1 Copper Green Wood 

Preservative Green Products Co. Ready-to-Use Solution 10 

71653-1 Cobra Wrap Genics Inc. Ready-to-Use 

Solution 17.8 

71992-1 CUNAP-8 Wood 

Preservative 

Merichem Chemicals 

& Refinery Services 

LLC 

Soluble 

Concentrate 68 

71992-2 CUNAP-2 

Merichem Chemicals 

& Refinery Services 

LLC 

Soluble 

Concentrate 18 

71992-3 CU NAP-5W Wood 

Preservative 

Merichem Chemicals 

& Refinery Services 

LLC 

Soluble 

Concentrate 42 

75340-3 COP-R-NAP RTU 

Solution 

Osmose Railroad 

Services, Inc. 

Ready-to-Use 

Solution 19.25 

75340-4 Osmose CU-89-RTU II Osmose Railroad 

Services, Inc. 

Ready-to-Use 

Solution 17 

75341-5 COP-R-Plastic Wood 

Preserving Compound 

Osmose Utilities 

Services, Inc. 

Ready-to-Use 

Solution 20 

75341-8 Osmose COP-R-NAP Osmose Utilities 

Services, Inc. 

Soluble 

Concentrate 77 

75341-11 COP-R-NAP Osmose Utilities 

Services, Inc. 

Soluble 

Concentrate 68 

75341-12 Hollow Heart CF Osmose Utilities 

Services, Inc. 

Soluble 

Concentrate 41.27 

75341-13 COP-R-Plastic II Wood 

Preserving Compound 

Osmose Utilities 

Services, Inc. 

Ready-to-Use 

Solution 17.68 

Table 2. Registered Active Products of Zinc Naphthenate 

Registration # Registration Name Company Name Formulation 

Type 

% of Active 

Ingredient 

577-545 Clear Cuprinol Brand 

Wood Preservative No. 20 The Sherwin-Williams Co Ready-to-Use Solution 13.5 

1719-44 Zin-Tox Wood Preservative

Mobile Paint 

Manufacturing Company 

Inc. 

Ready-to-Use 

Solution 16.00 

7424-9 Jasco Termin-8 H2O Clear Jasco Chemical Ready-to-Use 15.75 
Docket Number: EPA-HQ-OPP-2010-0455 

www.regulations.gov

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Registration # Registration Name Company Name Formulation 

Type 

% of Active 

Ingredient 

Wood Preservative Corporation Solution 

9630-6 

8% Zinc Nap-All 

M-GARD S150 Wood 

Preservative 

OMG Americas Inc. Formulation 

Intermediate 63.0 

9630-7 

Zinc Hydro-Nap 

M-GARD W152 Wood 

Preservative 

OMGAmericas Inc. Formulation 

Intermediate 63.0 

9630-10 M-GARD W550 wood 

Preservative OMG Americas Inc. 

Emulsifiable 

Concentrate 

End use Product 

63.0 

9630-21 M-GARD S550 wood 

Preservative OMG Americas Inc. Soluble Concentrate 63.0 

43437-3 8% Zinc Naphthenate OMG Belleville Limited Soluble 

Concentrate 69.0 

60061-9 

Wolman Wood 

Preservative With Water 

Repellent Clear 

Kop-Coat, Inc. Ready-to-Use 

Solution 7.5 

66591-3 Green's Clear Wood 

Preservative Green Products Co Ready-to-Use Solution 23.6 
Docket Number: EPA-HQ-OPP-2010-0455 

www.regulations.gov

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III. GLOSSARY of TERMS & ABBREVIATIONS

ai Active Ingredient 

AR Anticipated Residue 

ASTM American Society for Testing and Materials 

AWPA American Wood Preserver’s Association 

CFR Code of Federal Regulations 

cPAD Chronic Population Adjusted Dose 

CSF Confidential Statement of Formula 

CSFII USDA Continuing Surveys for Food Intake by Individuals 

DCI Data Call-In 

DEEM Dietary Exposure Evaluation Model 

DFR Dislodgeable Foliar Residue 

DNT Developmental Neurotoxicity 

DWLOC Drinking Water Level of Comparison 

EC Emulsifiable Concentrate Formulation 

EDWC Estimated Drinking Water Concentration 

EEC Estimated Environmental Concentration 

EPA Environmental Protection Agency 

EUP End-Use Product 

FDA Food and Drug Administration 

FIFRA Federal Insecticide, Fungicide, and Rodenticide Act 

FFDCA Federal Food, Drug, and Cosmetic Act 

FQPA Food Quality Protection Act 

FOB Functional Observation Battery 

GENEEC Tier I Surface Water Computer Model 

IR Index Reservoir 

LC50 Median Lethal Concentration. A statistically derived concentration of a 

substance that can be expected to cause death in 50% of test animals. It is 

usually expressed as the weight of substance per weight or volume of water, air 

or feed, e.g., mg/l, mg/kg or ppm. 

LD50 Median Lethal Dose. A statistically derived single dose that can be expected to 

cause death in 50% of the test animals when administered by the route indicated 

(oral, dermal, inhalation). It is expressed as a weight of substance per unit 

weight of animal, e.g., mg/kg. 

LOC Level of Concern 

LOAEL Lowest Observed Adverse Effect Level 

μg/g Micrograms Per Gram 

μg/L Micrograms Per Liter 

mg/kg/day Milligram Per Kilogram Per Day 

mg/L Milligrams Per Liter 

MOE Margin of Exposure 

MRID Master Record Identification (number). EPA's system of recording and tracking 

submitted studies. 

MUP Manufacturing-Use Product 

NA Not Applicable 

NAWQA USGS National Ambient Water Quality Assessment 

NPDES National Pollutant Discharge Elimination System 

NR Not Required 

NOAEL No Observed Adverse Effect Level 

OPP EPA Office of Pesticide Programs 

OPPTS EPA Office of Prevention, Pesticides and Toxic Substances 

PAD Population Adjusted Dose 

PAIRA Pure Active Ingredient Radiolabelled 

PCA Percent Crop Area 

PDP USDA Pesticide Data Program 
Docket Number: EPA-HQ-OPP-2010-0455 

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PHED Pesticide Handler's Exposure Data 

PHI Preharvest Interval 

ppb Parts Per Billion 

PPE Personal Protective Equipment 

ppm Parts Per Million 

PRZM/EXAMS Tier II Surface Water Computer Model 

Q1* The Carcinogenic Potential of a Compound, Quantified by the EPA's Cancer 

Risk Model 

RAC Raw Agriculture Commodity 

RED Reregistration Eligibility Decision 

REI Restricted Entry Interval 

RfD Reference Dose 

RQ Risk Quotient 

SCI-GROW Tier I Ground Water Computer Model 

SAP Science Advisory Panel 

SF Safety Factor 

SLN Special Local Need (Registrations Under Section 24©) of FIFRA) 

TGAI Technical Grade Active Ingredient 

TEP Typical End-Use Product 

USDA United States Department of Agriculture 

UF Uncertainty Factor 

WPS Worker Protection Standard 
Docket Number: EPA-HQ-OPP-2010-0455 

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IV. APPENDIX A

Use Patterns for Naphthenate Salts (copper naphthenate and zinc naphthenate) 

Copper Naphthenate 

Use Site Formulation Method of 

Application 

Application Rate/ No. of 

applications 

Use 

Materials preservatives Rope, burlap, canvas including, nets( not including fishing nets), seines, tents, awnings, tarpaulins Textiles 

Ready to use 1022-409 1719-43 43437-4 71992-3 71992-1 

Brush , dip, roller or spray 

Dip or spray until wet. For exterior use only, tr

contact with food, feed 

Particle board, insulation board, and other wood base fiber and particle materials 

Ready to use 1022-522 

Brush, dip, roller, or spray 

Mix with furnish resin or binding agent at 1-3% based on dry weight of wood. 

For exterior use only, trcontact with food, feed 

Wood preservatives (Exterior use only) Lumber, timber’s, posts, poles, and other wooden members, railroad ties 

Ready to use (paste) 1022-579 1022-536 71653-1 75341-5 

Brush ,trowel, caulking gun, or roller, Bandage, Wrap 

Apply to form a 1/16 inch thick layer on the surface to be treated, or by application to “Pol nu Paper” to create a bandage Bandages may be used to cover ground line areas of structures in bands typically 18 to 22 inches in height For railroad ties apply a 1/8 inch thick layer and cover the area with a tie plate the same size as the treated area leaving no -exposed preservative 

For exterior use only, trcontact with food, feed 
Docket Number: EPA-HQ-OPP-2010-0455 

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Use Site Formulation Method of 

Application 

Application Rate/ No. of 

applications 

Use 

(Exterior use only) Lumber, timber’s, posts, poles, and other wooden members, all exterior wood exposed to moisture or weather Wooden boat hulls, piers 

Ready to use 1022-518 1022-522 1022-571 7424-1 1022-523 577-541 1022-507 66591-1 71992-2 75340-4 60061-16 60061-19 

Brush, dip, roller , or spray 

1 minute immersion is adequate for most applications. 12-48 hours immersion time is required for wood placed in contact with the soil or used in construction of boats piers and other large wooden structures Brush, roller or, spray treatments are satisfactory for above ground applications, but should be used for ground contact applications only when dipping is not possible. In such cases, apply at least 2 coats by brush, roller, or spray treatments allowing at least 1 hour between each coat. 

For exterior use only, trcontact with food, feed  Dip treatment is the mo

(Exterior use only) Lumber, timber’s, posts, poles, and other wooden members, wooden boat hulls, piers 

Soluble Concentrate 1719-43 75341-11 75341-12 1022-528 9630-12 9630-11 71992-3 

Brush, dip, roller , spray, or pressure treatment 

Mix 1 gallon of emulsion with 1 to 3 gallons of water. Apply by brushing freely, spraying or dipping in a tank. Is most effective when wood is unpainted, dry and clean Mix to a 17% to 33% by weight solution (17% solution is 4.9 - 6.7 parts solvent per part of product; 33% solution is 2 - 3 parts of solvent per part of product.) Dip treatment is the most 

For exterior use only, trcontact with food, feed 
Docket Number: EPA-HQ-OPP-2010-0455 

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effective. A three minute immersion is adequate for most applications. 12 to 48 hours immersion time is required for wood placed in contact with the soil or used in construction of boats piers and other large wooden structures Brush, roller or, spray treatments are satisfactory for above ground applications, but should be used for ground contact applications only when dipping is not possible. For such, apply at least 2 coats by brush, roller, or spray treatments allowing at least 1 hour between each coat. Dilute with 3 volumes of water to obtain 2% copper metal or 7 volumes of water to obtain 1% copper metal. Above ground contact: For wood used above ground in critical (structural) applications or under more severe exposure conditions where it is subject to extended periods of wetting, extended soaking or pressure treatment in accordance with AWPA Standards* with a solution containing 0.5 to 1.0 percent by weight copper metal to a retention in the wood of 0.4 to 
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1.0 pounds copper metal per cubic foot is recommended Ground contact: For wood uses in ground contact, extended soaking or pressure treatment in accordance with AWPA Standards* with a solution containing .75 to 1.0 percent by weight copper metal to a retention in the wood of .04 to 1.0 pounds copper metal per cubic foot is recommended 

Formulation 1022-568 9630-5 9630-4 

Brush, dip, roller , or spray Pressure treatment 

Dilute with 3 volumes of water to obtain 2% copper metal or 7 volumes of water to obtain 1% copper metal. Above ground contact: For wood used above ground in critical (structural) applications or under more severe exposure conditions where it is subject to extended periods of wetting, extended soaking or pressure treatment in accordance with AWPA Standards* with a solution containing 0.5 to 1.0 percent by weight copper metal to a retention in the wood of 0.4 to 1.0 pounds copper metal per cubic foot is recommended Ground contact: For wood uses in ground contact, extended soaking or 

For exterior use only, trcontact with food, feed, 
Docket Number: EPA-HQ-OPP-2010-0455 

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pressure treatment in accordance with AWPA Standards* with a solution containing .75 to 1.0 percent by weight copper metal to a retention in the wood of .04 to 1.0 pounds copper metal per cubic foot is recommended 

Zinc Naphthenate 

Use Site Formulation Method of 

Application 

Application Rate/ No. of 

applications 

Use 

Materials preservatives Rope, burlap, canvas including, nets( not including fishing nets), seines, tents, awnings, tarpaulins Textiles 

Ready to use 1719-44 1719-38

Brush , dip, roller or spray 

Materials should be dipped or 

sprayed until wet. 

For exterior use only. Tcontact with food, feed, 

Wood preservatives (Exterior use only) Lumber, timber’s, posts, poles, and other wooden members, all exterior wood exposed to moisture or weather Wooden boat hulls, piers 

Ready to use 7424-9 577-545 1719-38 66591-3 60061-9 

Brush, dip, roller , or spray 

Dip treatment is the most effective. 3 minute immersion is adequate for most applications. 12 to 48 hours immersion time is required for wood placed in contact with the soil or used in construction of boats piers and other large wooden structures Brush, roller or, spray treatments are satisfactory for above ground applications, but should be used for ground contact applications only when dipping is not 

For exterior use only. Tcontact with food, feed, 
Docket Number: EPA-HQ-OPP-2010-0455 

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Use Site Formulation Method of 

Application 

Application Rate/ No. of 

applications 

Use 

possible. In such cases, apply at least 2 coats by brush, roller, or spray treatments allowing at least 1 hour between each coat. 

(Exterior use only) Lumber, timber’s, posts, poles, and other wooden members, wooden boat hulls, piers 

Soluble Concentrate 43437-3 9630-10 9630-21 

Brush, dip, roller , spray, or pressure treatment 

Mix 1 gallon of emulsion with 1 to 3 gallons of water. Apply by brushing freely , spraying or dipping in a tank; is most effective when wood is unpainted dry and clean Mix to a 17% to 33% by weight solution (17% solution is 4.9 - 6.7 parts solvent per part of product, 33% solution is 2.0 – 3.0 parts of solvent per part of product). Dip treatment is the most effective. 3 minute immersion is adequate for most applications. 12 to 48 hours immersion time is required for wood placed in contact with the soil or used in construction of boats piers and other large wooden structures Brush, roller or, spray treatments are satisfactory for above ground applications, but should be used for ground contact applications only when dipping is not possible. In such cases, apply at least 2 coats by brush, roller, or spray treatments allowing at 

For exterior use only. Tcontact with food, feed, 
Docket Number: EPA-HQ-OPP-2010-0455 

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Use Site Formulation Method of 

Application 

Application Rate/ No. of 

applications 

Use 

least 1 hour between each coat. Dilute with 3 volumes of water to obtain 2% copper metal or 7 volumes of water to obtain 1% copper metal. Above ground contact: For wood used above ground in critical (structural) applications or under more severe exposure conditions where it is subject to extended periods of wetting, extended soaking or pressure treatment in accordance with AWPA Standards* with a solution containing 0.5 to 1.0 percent by weight copper metal to a retention in the wood of 0.4 to 1.0 pounds copper metal per cubic foot is recommended. Ground contact: For wood uses in ground contact, extended soaking or pressure treatment in accordance with AWPA Standards* with a solution containing .75 to 1.0 percent by weight copper metal to a retention in the wood of .04 to 1.0 pounds copper metal per cubic foot is recommended. 

Formulation Brush, dip, roller , Dilute with 3 volumes of water For exterior use only. T
Docket Number: EPA-HQ-OPP-2010-0455 

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Use Site Formulation Method of 

Application 

Application Rate/ No. of 

applications 

Use 

9630-6 9630-7 

or spray Pressure treatment 

to obtain 2% copper metal or 7 volumes of water to obtain 1% copper metal. Above ground contact: For wood used above ground in critical (structural) applications or under more severe exposure conditions where it is subject to extended periods of wetting, extended soaking or pressure treatment in accordance with AWPA Standards* with a solution containing 0.5 to 1.0 percent by weight copper metal to a retention in the wood of 0.4 to 1.0 pounds copper metal per cubic foot is recommended. Ground contact: For wood uses in ground contact, extended soaking or pressure treatment in accordance with AWPA Standards* with a solution containing .75 to 1.0 percent by weight copper metal to a retention in the wood of .04 to 1.0 pounds copper metal per cubic foot is recommended. 

contact with food, feed,