Docket Number: EPA-HQ-OPP-2010-0212 

www.regulations.gov 

Coppers Summary Document 

Registration Review: Initial Docket 

September 2010 
Coppers Summary Document 

Registration Review: Initial Docket 

September 2010 

Case No. 0636,0649,4025, and 4026 

Approved By: 

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Richard P. Keigwin, Jr. 

Director, Pesticide Re-evaluation Division 

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TABLE OF CONTENTS 

 Page # 

I. Preliminary Work Plan (PWP) 4 

II. Fact Sheet 12 

________________________________________ 

Please Note

This Preliminary Work Plan and Fact Sheet summarize the Environmental Protection Agency's 

current position based on the following documents: 

1. Preliminary Problem Formulation for Ecological Risk, Environmental Fate, and 

Endangered Species Assessments for Coppers. September 13, 2010. 

2. Coppers: Human Health Assessment Scoping Document in Support of Registration 

Review. May 27, 2010. 

3. Copper Compounds: Review of Human Incidents. May 20, 2010. 

4. Copper Sulfate: Review of Human Incidents. May 20, 2010. 

5. Copper Salts: Review of Human Incidents. May 20, 2010. 

6. Revised Reregistration Eligibility Decision for Coppers. May 2009. (Available in the 

coppers RED docket: EPA-HQ-OPP-2005-0558 at http://www.regulations.gov) 

7. Revised Addendum to the 2009 Revised Coppers Reregistration Eligibility Decision 

(RED): Antimicrobial Uses of Copper. August 2010 (Available in the coppers RED 

docket: EPA-HQ-OPP-2005-0558 at http://www.regulations.gov) 

8. Screening Level Usage Analysis (SLUA) for Copper Sulfate Pentahydrate. November 3, 

2009. 

9. Screening Level Usage Analysis (SLUA) for Copper Oxychloride. November 6, 2009. 

10. BEAD Summary Document: Use of Copper Compounds for the Control of Agronomic 

Crop Diseases, Aquatic Algae Weeds, and Some Macro-Invertebrate Pests. March 26, 

2010. 

11. Appendix A: Registered Antimicrobial Uses of Copper 

Additional supporting documents for copper may be found in the registration review docket

EPA-HQ-OPP-2010-0212 located on the internet at www.regulations.gov.
4

I. Preliminary Work Plan – Coppers 

Introduction:

The Food Quality Protection Act of 1996 mandated a registration review program. All pesticides 

sold or distributed in the United States generally must be registered by the Environmental 

Protection Agency (EPA), 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 coppers. 

The registration review of copper pesticides includes four cupric ion case designations: copper 

sulfate (0636), copper group II compounds (0649), copper salts (4026), and copper oxides (4025) 

(for a complete list of copper compounds covered by this registration review see attached table). 

Although there are several forms of copper-containing active ingredients under review, the active 

component of toxicological interest is the cupric ion (elemental copper). Copper 8-quinolinolate 

and copper naphthenate will not be included in this Registration Review because the Agency has 

determined that these compounds are toxicologically unique from elemental copper and, 

therefore, subject to different risk assessments and data needs. The registration review dockets 

for these chemicals are also scheduled to open in September 2010. More information on the 

registration reviews of copper 8-quinolinolate and copper naphthenate can be viewed at 

http://www.regulations.gov in dockets EPA-HQ-OPP-2010-0454 and EPA-HQ-OPP-2010-0455, 

respectively. 

Copper pesticides are registered for use as both conventional pesticides, mainly in agricultural 

settings as fungicides, and direct water applications as aquatic herbicides, algaecides, and 

molluscides, and as antimicrobial pesticides in commercial and residential settings mainly as 

antifoulants, wood preservatives, and material preservatives. Certain copper alloys are also 

registered for production of antimicrobial products such as doorknobs, kickplates, and bedrails. 
5

In addition, copper-containing pesticides are also registered for use to control mollusks, leeches, 

crustaceans, mites and termites, and root growth in sewage and irrigation systems. While human 

and ecological copper exposure occurs from naturally occurring and anthropogenic sources such 

as mining and copper plumbing, this registration review and subsequent risk assessments will 

address exposure to copper from pesticidal uses. Copper-containing compounds with 

conventional uses were the subject of a July 2006 Coppers Reregistration Eligibility Decision 

(RED) and a May 2009 Revised RED. Copper-containing compounds with antimicrobial uses 

were assessed for potential human health risk exposure as part of the 2006 Coppers RED and 

2009 Revised Coppers RED. Environmental exposure to antimicrobial copper pesticides was 

assessed as part of the May 2010 Addendum to the Revised Coppers RED and August 2010 

Revised Addendum to the Revised Coppers RED. Documents associated with the reregistration 

of copper compounds can be viewed at www.regulations.gov in docket EPA-HQ-OPP-2005-

0558. 

Anticipated Risk Assessment and Data Needs:

The Agency anticipates the need to require data to conduct a comprehensive ecological risk 

assessment, including an endangered species risk assessment, for all uses of copper. The Agency 

does not anticipate needing to require additional data to conduct human exposure risk 

assessments, as new dietary, residential, and occupational risk assessments are not planned for 

registration review, due to a lack of systemic copper toxicity to humans. Below is a summary of 

the issues relevant to the registration review of coppers. 

Ecological Risk: 

 The most recent ecological risk assessments for coppers were completed in 2005, in 

support of the Reregistration Eligibility Decision (RED) for conventional uses of coppercontaining pesticides, and in 2010 in support of the Revised Addendum to the Revised 

RED for antimicrobial uses. 

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

species determination for copper. The ecological risk assessment planned during 

registration review will allow the Agency to determine whether copper’s use 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 Services (the 

Services), as appropriate. 

 The Agency anticipates needing to require the following data for conventional copper 

pesticides in order to conduct a complete ecological risk assessment, including an 

endangered species assessment, for copper: 
6

 GDLN 850.2100 – Avian Acute Oral Toxicity Test (Passerine) 

 GDLN 850.4100 – Terrestrial Plant Seedling Emergence (Tier II) 

 Additionally, the following data are anticipated to be needed to be required for copper 

pesticides with antimicrobial uses in order to conduct a complete ecological risk 

assessment, including an endangered species assessment, for copper: 

 GDLN 835.1110 – Activated Sludge Sorption Isotherm 

 GDLN 850.6800 – Modified Activated Sludge Respiration Inhibition 

 NON-GDLN – Aquatic Leaching Study for Wood Preservatives-AWPA E11-

06 

 NON-GDLN – Leachability of Copper from Roofing Shingles 

 The Agency seeks additional use and usage information for antimicrobial copper 

products, as well as approaches for addressing the use and disposal of copper-containing 

pesticides used in pools, spas, fountains, drinking water systems, irrigation canals and 

supply systems, sewage systems, and settling ponds. This information will be useful to 

conduct a complete ecological risk assessment, including an endangered species 

assessment, for copper. See the “Guidance for Commenters” section below. 

 Please refer to Registration Review: Preliminary Problem Formulation for Ecological 

Risk, Environmental Fate, and Endangered Species Assessments for Coppers, located in 

the docket, for a detailed discussion of these anticipated risk assessment and data needs. 

Human Health Risk:

 The most recent risk assessment that evaluated human risk and exposure to coppers was a 

qualitative assessment completed in 2006 to support the 2006 RED and 2009 Revised 

RED for Coppers. 

 The human health exposure database to support the registration review of coppers is 

complete. Previous risk assessments indicate that there are no residential, dietary, 

occupational, or aggregate risks of concern resulting from the use of copper pesticides. 

The Agency anticipates utilizing the conclusions of these assessments for registration 

review. No additional data are anticipated to be needed at this time. 

 If toxicological points of departure are established, other new data are received, 

poisoning incident data indicates a problem, or other parameters are modified, the need 

for residential, dietary, occupational, and aggregate risk assessments would be evaluated 

at that time. 

o The Agency is evaluating recently received information that indicates that certain 

copper-containing products may contain heavy metal impurities. The 

concentrations of these impurities appear to be quite low, but the Agency will 

evaluate available information and any further comments received to formulate a 
7

better understanding of the issue. EPA will consider including potential exposure 

to heavy metals from copper-containing products in its risk assessments if 

consideration of the information indicates further review is warranted. 

 For more information please refer to Coppers: Human Health Assessment Scoping 

Document in Support of Registration Review, located in the docket. 

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 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 quantitative 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 post-application agricultural scenarios. 

This list should not be construed as a list of known or likely endocrine disruptors. 

Copper was 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 orders/data call-ins for all 

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/.
8

Timeline:

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

review. 

Registration Review for Coppers – Projected Registration Review Timeline

Activities Estimated Date 

Opening the Docket 

Open Docket and Public Comment Period 2010 – September 

Close Public Comment 2010 – November 

Case Development 

Final Work Plan 2011 – February 

Issue DCI 2011 – Oct – Dec 

Data Submission 2013 – Oct – Dec 

Open Public Comment Period for Draft Risk Assessments 2015 – April – June 

Close Public Comment Period 2015 – July – Sept 

Registration Review Decision 

Open Public Comment Period for Proposed Registration Review 

Decision 

 2015 – Oct – Dec 

Close Public Comment Period 2016 – Jan – March 

Registration Review Decision and Begin Post-Decision Follow-up 2016 

Total (years) 6 

Guidance for Commenters:

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 coppers. 

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:

Copper is identified as a cause of impairment, as defined under section 303(d) of the Clean 

Water Act, for 885 water bodies in 36 U.S. states and territories, based on information provided 

at 

http://iaspub.epa.gov/tmdl_waters10/attains_nation_cy.cause_detail_303d?p_cause_group_id=70

6. A majority of these sites list other metals in addition to copper as pollutants, either from 
9

mining or other non-agricultural sources. In addition, 342 Total Maximum Daily Loads (TMDL) 

have been developed for copper, including sources in 28 states and territories based on 

information provided at 

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

=706&p_pollutant_group_name=METALS%20(OTHER%20THAN%20MERCURY). 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 coppers, 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 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. 
10

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-theevidence 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 

copper, 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. 

Additional Information:

Stakeholders are also specifically asked to provide information and data that will assist the 

Agency in refining its risk assessments, including any species-specific ecological effects 

determinations. 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 in units related to mass per unit area of treatment 

zone 

e. frequency of application, application intervals and maximum number of 

applications per season 

f. geographic limitations on use 

2. use or potential use distribution (e.g., acreage and geographical distribution of 

relevant crops) 

3. use history 

4. median and 90th percentile reported use rates (lbs. a.i./acre) from usage data – 

national, state, and county 

5. application timing (date of first application and application intervals) by crop – 

national, state and county 
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6. sub-county crop location data 

7. directly acquired county-level usage data (not derived from state level data) 

a. maximum reported use rate (lbs. a.i./acre) from usage data – county 

b. percent crop treated – county 

c. median and 90th percentile number of applications – county 

d. total pounds per year – county 

e. the year the pesticide was last used in the county/sub-county area 

f. the years in which the pesticide was applied in the county/sub-county area 

8. typical interval (days) 

9. state or local use restrictions 

10. ecological incidents (non-target plant damage and avian, fish, reptilian, amphibian 

and mammalian mortalities) not already reported to the Agency 

11. monitoring data 

12. structure activity relationships 

The Agency is also seeking information on the use of copper as a root killer in sewage and 

irrigation systems and any state or local restrictions that may exist for root killer products. 

For antimicrobial uses of copper EPA is seeking (1) use and usage information and (2) input on 

approaches for incorporating the use and disposal of copper-containing pesticides into an 

endangered species assessment, especially those used in pools, spas, fountains, drinking water 

systems, irrigation canals and supply systems, sewage systems, and settling ponds. 

The concurrent evaluation of both antimicrobial and conventional uses of copper will require a 

consideration of how and whether exposure to copper from very different types of applications 

could co-occur. The Agency welcomes any information on locations in the country in which 

both agricultural and antimicrobial uses are more likely to co-occur (e.g., Are copper-treated 

shingles or wood more likely to be used in a region of the country which is also likely to have 

agricultural applications? Are copper antifoulant paints typically used on boat hulls in a region 

more likely to also use direct aquatic applications of copper?). It would also be useful to receive 

information about regions in which certain copper applications are unlikely to occur. 

Next Steps:

After the 60-day comment period closes, the Agency will review and respond to any comments 

received in a timely manner, and then issue a Final Work Plan (FWP) in February 2011 for 

coppers. 
12

II. FACT SHEET 

 

Background Information:

 Copper PC codes, CAS Nos., and registration review case numbers: See attached table. 

 Technical Registrants of Conventional Pesticides: Chem One Ltd., Curpon Inc., Drexel 

Chemical Company, Fabrica De Sulfato El Aquila. SA DE C.V., Ingenieria Industrial SA 

DE CV, Nufarm Americas Inc., Nufarm Limited, Old Bridge Chemical Co., Osmose, 

Inc., Phibro-Tech Inc., United Phosphorus, Inc. 

 Technical Registrants of Antimicrobial Pesticides: Adchem (Australia) Pty Ltd., 

American Chemet Corp., Chemical Specialties Inc., Copper Development Association, 

International Paint LLC, Nordox As, Pennisula Copper Industries, Inc., Phibro-Tech Inc., 

SCM Metal Products, Inc.,William Blythe Limited. 

 The first copper-containing pesticide was registered for use in the U.S. in 1956. 

 A Reregistration Eligibility Decision (RED) was issued in 2006, the Revised RED was 

issued in May 2009, and an Addendum to the Revised RED was issued in May 2010 and 

revised in August 2010. 

 There are currently 550 Section 3 registrations including 495 end-use products and 55 

technical and manufacturing use products registered.

 Tolerance exemptions for residues of copper in/on plant, animal, and processed 

commodities exist under 40 CFR §180.1021. 

 Pesticide Re-evaluation Division Chemical Review Manager: Kaitlin Keller, 

keller.kaitlin@epa.gov 

 Registration Division Contact: Tony Kish, kish.tony@epa.gov 

 Antimicrobials Division Chemical Review Manager: Rebecca von dem Hagen, vondemhagen.rebecca@epa.gov

 Antimicrobials Division Product Manager (PM): Marshall Swindell, 

swindell.marshall@epa.gov

Use & Usage Information: (For additional details, please refer to the BEAD SLUA documents, 

BEAD Document Summary: Use of Copper Compounds for the Control of 

Agronomic Crop Diseases, Aquatic Algae and Weeds, and Some MacroInvertebrate 

Pests, and the Appendix A: Registered Antimicrobial Uses of Copper.) 

 Copper pesticides are extensively used in various agricultural, commercial, and 

residential settings as fungicides, bactericides, slimicides, herbicides, algaecides, 

antifoulants, wood preservatives, and material preservatives. In addition, coppercontaining pesticides are also used to control mollusks, leeches, crustaceans, mites and 

termites. They are also used as root killers in sewage and irrigation systems. 

 Copper compounds are registered as fungicides and bactericides for a variety of 

agricultural uses, specifically row crops and orchards. Approximately 106 million 

pounds of copper were used as a fungicide in 2002. Of this, about 25% was used in rice. 

Citrus and walnut represented the second (23%) and third (10%) most extensive uses for 

copper fungicides, respectively. The rest of the major uses were in grape, tomato, peach, 
13

almond, apple, cherry, and potato. The registered agricultural uses for copper, grouped 

into various crop categories, include the following: 

o Tree fruit – pome fruit (apple, loquat, pear, quince), atemoya, sugar apple 

(annona), avocado, banana, carambola, cherimoya (custard apple), citrus (citron, 

grapefruit, kumquat, lemon, orange, pummelo, tangelo, tangerine, and lime), 

guava, mamey sapote, mango, olive, papaya, persimmon, and stone fruit (apricot, 

cherry, nectarine, peach, plum, and prune); 

o Tree nuts – almond, betel nut (Guam), cacao, chestnut, coffee, filbert, litchi, 

macadamia, nutmeg, pecan, pistachio, and walnut; 

o Field crops – alfalfa, cereal grains (barley, millet, oat, rye, sorghum, and wheat), 

clover, corn (field corn, popcorn, and sweet corn), peanut, potato, soybean, sugar 

beet, sugarcane, and tobacco; 

o Small fruits – brambles (aurora, blackberry, boysen, cascasde, chehalem, 

dewberry, logan, marion, raspberry, santiam, and thornless evergreen), blueberry, 

cranberry, currant, gooseberry (ribes), and strawberry; 

o Vegetables – artichoke, asparagus, bean (dry and green), beet (table beet and beet 

greens), carrot, celery, celeriac, chard, crucifers (broccoli, brussel sprout, 

cabbage, cauliflower, Chinese cabbage, collard greens, kale, kohlrabi, mustard 

greens, and turnip greens) cucurbits (cantaloupe, casaba, chayote, citron melon, 

cucumber, gourd, honeydew, muskmelon, pumpkin, squash (summer and winter), 

watermelon, and waxgourd), eggplant, garlic, leek, lettuce (endive and escarole), 

okra, onion, pea, pepper (bell and chili), radish, rhubarb, rutabaga, shallot, 

spinach, tomato (processing and fresh market), turnip, and watercress; 

o Vines – grape, hops, kiwi, and passion fruit; 

o Miscellaneous – chicory, chives, cinnamon, coriander, dill, ginseng, mint, parsley, 

rosemary, and turfgrass; and 

o Ornamentals – Easter lilies and other ornamentals. 

 Copper-containing compounds are registered for use as lawn treatments (as a fungicide) 

and as root killers for sanitary sewers and irrigation pipes. 

 Coppers are also registered for use in direct applications to water to control algae, 

cyanobacteria, aquatic weeds (Elodea spp., hydrilla, Potamogeton spp., irrigation canal 

weed, and annual naiads), schistosome-infected freshwater snail, algae in aquaculture 

when fish are present, tadpole shrimp in rice fields, and leech. 

 Copper-containing conventional pesticides are formulated as dusts, liquid concentrates, 

dry flowables, wettable powders (including water-soluble packets), granulars, waterdispersible granules, powders, ready-to-use liquids, aerosols, and solids. Copper 

pesticides can be applied by a wide range of application methods, including aerial, 

airblast, groundboom, rights-of-way equipment, mechanical duster, low and highpressure handwand sprayer, handgun sprayer, push-type spreader, dips, drip system, 

hose-end sprayer, and automatic-metering system. Direct aquatic copper applications 

include broadcast dry, broadcast spray, dragging, injection (flowing water), slug or dump, 

or spot spray. 
14

 Registered antimicrobial uses of copper include materials preservatives, wood 

preservatives, antifoulants, and water treatment in water systems, pools and fountains. In 

addition, certain copper alloys are registered for production into antimicrobial products 

such as doorknobs, kickplates, and bedrails. 

 Antimicrobial uses of copper are formulated as soluble concentrate, flowable concentrate, 

ready-to-use solution, granules, powder, impregnated materials, crystalline, pellet/tablet, 

wettable powder, dust, emulsified concentrate, pressurized liquid, and alloys. 

Antimicrobial copper pesticides can be applied by a wide range of application methods 

including brush, roller, spray (conventional or airless), manufacturer specific spray 

equipment, manual or electronic spreader or blower, incorporation, pressure treatment, 

open pour, dip, injection, cartridge, and aircraft. 

Recent and Pending Actions:

 In May 2009, revisions to the 2006 Coppers RED were completed and presented the 

Agency’s response to substantive comments received on the RED that provided 

additional use and usage information for coppers. The Revised RED is available in the 

coppers reregistration docket: EPA-HQ-OPP-2005-0558. 

 In May 2010, the Agency issued an Addendum to the Revised RED, which addressed the 

ecological risks of antimicrobial uses of copper oxides not captured by the 2009 Revised 

RED. This Addendum was revised in August 2010 to incorporate all antimicrobial uses 

of copper except copper 8-quinolinolate and copper naphthenate. EPA completed 

separate REDs for copper 8-quinolinolate and copper naphthenate in September 2007 

because both active ingredients were determined to be toxicologically unique from the 

cupric ion, and therefore, subject to different risk assessments, data needs, and labeling 

changes. The registration review dockets for both of these cases are also scheduled to 

open in September 2010. 

 Products are currently undergoing reregistration to incorporate mitigation measures 

specified in the 2009 Revised Coppers RED on labels. These mitigation measures 

include reduced single application rates, seasonal maximum application rates, minimum 

retreatment intervals, reduced restricted-entry intervals (REI), and spray drift advisory 

language. The Agency anticipates that copper product labels will be amended prior to the 

development of the coppers risk assessments needed for registration review. 

Ecological Risk Assessment Status: 

The following are key findings of the most recent ecological risk assessments for coppers. 

Please refer to Registration Review: Preliminary Problem Formulation for Ecological Risk, 

Environmental Fate, and Endangered Species Assessments for Coppers, and Revised Addendum 

to the 2009 Revised Coppers Reregistration Eligibility Decision (RED): Antimicrobial Uses of 

Copper located in the docket, for a detailed discussion of the ecological risk assessments. 
15

 EPA‘s Office of Pesticide Programs (OPP) used the Biotic-Ligand Model (BLM), which 

was also used by EPA’s Office of Water’s (OW) to establish Ambient Water Quality 

Criteria to assess risk to potentially exposed freshwater organisms from both 

conventional copper pesticides, and the antimicrobial uses of copper as wood 

preservatives and in roofing shingles. OPP utilized this model because it is able to 

account for differences in site water chemistry, especially the alkalinity, pH, and 

dissolved organic carbon (DOC), which determine copper toxicity through speciation of 

dissolved copper. 

 The BLM incorporates 811 water samples collected by the United States Geological 

Survey (USGS) nationwide, to represent a wide range of water chemistries and levels of 

copper toxicity. While the BLM cannot yet be used to assess risk in estuarine/marine 

environments, OPP is coordinating with OW to utilize this model to reflect differing site 

water chemistries and corresponding differences of copper toxicity in estuarine/marine 

environments. 

Summary of Risk: 

Conventional Copper-Containing Pesticides 

The most recent screening-level risk assessments, conducted in support of the Coppers RED, 

indicated exceedances of Agency levels of concern for both terrestrial and aquatic animals and a 

need to further examine and potentially refine estimates of acute and chronic risk. Mitigation 

measures are being implemented as part of the risk-benefit determinations made in the 2009 

Revised Coppers RED that should significantly reduce these risks. While these risks still exceed 

acute and chronic levels of concern for most animals and aquatic plants considered, the benefits 

from the use of copper pesticides, namely the lack of human health risk from copper exposure, 

are substantial. Additionally, for many crops and direct water uses there is a lack of suitable 

alternatives.

Birds and Mammals

 The risk quotients (RQs) for the maximum application rates exceeded nearly all acute and 

chronic LOCs, including the endangered species acute LOC, for all weight classes of 

birds and mammals, including endangered species. However, RQs based on average 

application rates better reflect the lower rates established as mitigation in the Revised 

Coppers RED. These RQs indicated the potential for acute and chronic risk to birds and 

mammals from dietary exposure. 

Non-Target Terrestrial Plants and Non-Target Insects

 Copper toxicity to terrestrial plants was assessed based on the potential risk from spray 

drift of copper pesticides. At the maximum label rates for orchards of 31.8 lbs of metallic 

copper per acre (Cu2+/A), no RQs exceeded the acute endangered species LOC. 
16

 Based on an acute contact study with honey bees, the Agency concluded copper does not 

pose a risk to honey bees. 

Aquatic Animals and Plants

 Copper can rapidly bind and cause damage to the gill membranes and interfere with the 

osmoregulatory processes of aquatic organisms. Copper is, therefore, classified as highly 

toxic to all taxanomic groups of freshwater and marine/estuarine aquatic fish, and 

invertebrates. Potential copper toxicity in natural waters is largely a function of water 

chemistry, so the toxicity to a particular organism will vary from site to site. For a 

number of sites modeled using USGS water chemistry data, acute and chronic risk 

quotients for fish and aquatic invertebrates exceeded the Agency’s LOC. However, these 

exceedances decreased significantly when typical agricultural application rates were 

considered instead of maximum application rates. 

 Based on acute RQs for the green alga, the most sensitive aquatic vascular plant species 

tested, the screening-level risk assessment indicated a risk to freshwater vascular plants 

or estuarine/marine plants. 

 Because the BLM is not parameterized for estuarine/marine scenarios, RQs for 

estuarine/marine animals and plants were calculated using estimates of total dissolved 

copper using PRZM/EXAMS, which overestimates copper exposure to non-target 

organisms. In addition, the water body simulated by PRZM/EXAMS, a static farm pond 

with no outflow, is smaller than most estuarine and marine water bodies, and does not 

take into account the dilutive effect of untreated seawater. 

 Using PRZM/EXAMS, the acute endangered species LOC was exceeded for all 

estuarine/marine fish and invertebrates for agricultural uses of copper at application rates 

of 1.0 lb Cu2+/A and above. Chronic endangered species LOCs were exceeded at 

agricultural application rates of 1.0 lb Cu2+/A and above, and 3.0 lb Cu2+/A and above for 

estuarine/marine fish and invertebrates, respectively. 

 For direct water applications of copper algaecides, >99% of sites modeled exceeded the 

acute endangered species LOC for freshwater invertebrates, fish, and plants at the typical 

application rate of 1 ppm. The chronic risk LOCs for aquatic invertebrates and fish were 

exceeded at >96% of the sites. 

Antimicrobial Copper-Containing Pesticides 

 Screening-level assessments were conducted for exposure from wood preservatives, 

roofing shingles, and antifoulant paints applied to ships, which represent worst-case 

antimicrobial use scenarios of environmental exposure. The Agency utilized the BLM to 

calculate exposure from wood preservatives and roofing shingles and the Marine 

Antifoulant Model to Predict Environmental Concentrations (MAMPEC) version 2 to 
17

develop Estimated Environmental Concentrations (EECs) of copper in water and 

sediments resulting from the use of copper as an antifoulant. 

 OPP utilized the BLM model to calculate exposure as a result of copper leaching from 

roofing shingles and wood preservatives. RQ exceedances were identified for four 

different use scenarios (three shingles and one wood preservative). For the roofing 

shingles scenarios RQ of 0.05 was exceeded at 15 sites in the standard farm pond 

scenario, 111 sites in the edge of the house scenario and 16 sites for the variable volume 

pond scenario. RQ of 0.50 was exceeded at 4 sites in the standard farm pond scenario, 11 

sites in the edge of the house scenario and 5 sites for the variable volume pond scenario. 

For the wood preservative use scenario, RQ>0.05 at 662 sites and RQ>0.50 at 212 sites. 

 The MAMPEC model was developed by the Institute of Environmental Studies/IVM and 

Delft Hydraulics for the European Paint Makers Association and can be used to predict 

EECs of antifoulant products in six generalized “typical” marine environments 

(commercial harbor, estuarine harbor, marina, marina poorly flushed, open sea and 

shipping lane). 

 EECs were generated for a commercial harbor scenario under the assumptions that all 

ships were treated with copper and that copper would leach at the highest possible rate of 

50 μg/cm2

/day. Under this scenario, the Agency found that the total concentrations of 

copper in a commercial harbor ranged from .0667 to 9.76 μg/l with an average 

concentration of 3.12 μg/l. Based on conservative assumptions, the Agency notes that 

the MAMPEC model may have overestimated the potential level of copper in the 

environment. The calculated exposures and risk were within the range of those identified 

in the ecological assessment for the conventional uses of copper. 

Human Health Risk Assessment Status:

The following are key findings of the most recent human health risk assessments for coppers, 

which included potential exposure from both antimicrobial and conventional copper uses. Please 

refer to Coppers: Human Health Assessment Scoping Document in Support of Registration 

Review, located in the docket, for a detailed discussion of the human health risk assessment. 

Hazard Characterization: 

 Copper is an essential trace element, with copper deficiency more common in humans 

than excess, and since the dietary contribution of copper from pesticidal uses to the total 

diet is low, the additional tenfold FQPA safety factor for the protection of infants and 

children was reduced to one. 

 Acute toxicity studies exist for most copper species. 

 Most copper containing formulations have moderate to low toxicity (toxicity category II, 

III, and IV) based on acute oral, dermal, and inhalation studies in animals, except cuprous 
18

oxide which has a dermal toxicity category I. Certain copper formulations are severe eye 

irritants (toxicity categories I and II). 

 The carcinogenic potential of copper (metallic) has been classified as Group D, not 

classifiable as to human carcinogenicity. 

 No endpoints of toxicological concern have been identified for risk assessment purposes. 

Dietary (Food and Water): 

 Copper occurs naturally in many food sources such as nuts, organ meats and grains. 

Almost none of the copper ingested is retained in the body and the accumulation of 

copper in adults is constant, most likely as a result of the body’s ability to metabolize and 

regulate copper levels in healthy adults. 

 Because of the lack of systemic toxicity, the Agency concluded during reregistration that 

dietary exposure to copper did not pose any health risks of concern. 

Residential: 

 There is potential for application exposure to residential homeowners who may apply 

copper-containing products in and around their homes, and potential for post-application 

exposure to adults and children following applications of copper-containing products in 

the residential setting. 

 No dermal or inhalation toxicological points of departure have been identified due to the 

lack of systemic toxicity; therefore, the Agency concluded that residential exposure to 

copper did not pose any health risks of concern. 

Aggregate: 

 Because of the lack of systemic toxicity, the Agency concluded that exposures from 

combined sources did not pose any health risks of concern.

Occupational: 

 There is potential for occupational application exposure to mixers, loaders, applicators, 

and other handlers of copper formulations. There is also potential for post-application 

exposure to workers following applications of copper-containing products in the 

agricultural and commercial settings. 

 Because of the lack of systemic toxicity, the Agency concluded during reregistration that 

occupational exposure to copper did not pose any health risks of concern. 

Cumulative: 
19

 The Food Quality Protection Act (FQPA) requires the Agency to consider the cumulative 

risks of chemicals sharing a common mechanism of toxicity. The Agency has 

determined that there was insufficient evidence to suggest coppers share a common 

mechanism of toxicity with other chemical substances. 

Incidents:

Ecological:

 There are thirteen aquatic or terrestrial ecological incident reports for coppers in the 

Agency’s Ecological Incident Information System (EIIS). Eleven of these thirteen 

incidents reported were associated with kills of aquatic organisms, primarily fish. Of 

these incidents, 9 were classified as probable and 2 were classified as highly probable. A 

total of 9 incidents were reported in the Avian Incident Monitoring System (AIMS). 

Incident reports for non-target plants and animals typically provide information on 

mortality events only. Reports for other adverse effects, such as reduced growth or 

impaired reproduction, are rarely received.

Human Health: 

 The Office of Pesticide Programs Incident Data System (IDS) was consulted for reports 

of copper poisoning incidents. Of the 17 reported incidents since 2002, the majority of 

these reported dermal symptoms, though several cases reported eye or respiratory 

symptoms. Based on the low severity of incident cases that occurred, there does not 

appear to be a concern at this time that would warrant further investigation. 

Tolerances and International Harmonization: 

 No tolerances have been established for copper, and Maximum Residue Levels (MRLs) 

have not been established for coppers by Codex, Canada, or Mexico. For the copper 

registration review, the Agency does not anticipate a need to harmonize usage or 

tolerance exemptions with Codex, unless Codex establishes MRLs for commodities with 

U.S. tolerances. For a discussion of tolerances, see Coppers: Human Health Assessment 

Scoping Document in Support of Registration Review. 

 Tolerance exemptions for residues of copper in/on plant, animal and processed 

commodities are established under 40 CFR §180.1021. However, should any additional 

copper active ingredients be registered for new food uses in the future, the applicability 

of the tolerance exemption for these compounds will be re-evaluated at that time. 

Data Call-In Status

 There are no outstanding generic data call-in (DCI) requirements for coppers from 

reregistration. Product Specific DCIs (PDCI) for copper oxides, as described in the 
20

Revised Coppers RED and Revised Addendum, are scheduled to be issued prior to the 

issuance of the DCI for the registration review of coppers. All other copper PDCIs have 

been issued. 

Labels: 

 

 Coppers Section 3 product labels can be obtained from the Pesticide Product Label 

System (PPLS) website: http://oaspub.epa.gov/pestlabl/ppls.home
Copper Compounds Subject to Registration Review: This table lists the copper pesticides subject to all regist

ongoing product reregistration actions, as well as the chemical properties and uses of these copper compounds. T

updated chemical property information listed in Table 3 and 4 of the Revised RED for Coppers (May 2009). The individual products may vary slightly from those shown depending on manufacturing processes, molecular weigh

calculated. Molecular weights were calculated from atomic weights as stated in the 90th edition of the CRC PresChemistry and Physics. 

Registration Review Case 

Common name EPA PC 

Code 

Formula C.A.S. 

Number 

Molecular weight (g/mol)

Percent Copper 

Con

Copper Basic copper sulfate 008101 3Cu(OH)2 · CuSO4 1344-73-6 452.29 56.2% 

Sulfates 

0636 

Copper sulfate pentahydrate 024401 CuSO4 · 5H2O 7758-99-8 249.68 25.45% 

Basic copper chloride 008001 3 Cu(OH)2 · CuCl2 1332-40-7 427.13 59.5% Basic copper carbonate 022901 Cu(OH)2CuCO3 12069-69-1 221.12 57.5 Copper ammonium carbonate complex 

022703 CuNH3(HCO3)2 33113-08-5 202.61 31.4% 

Copper hydroxide 023401 Cu(OH)2 20427-59-2 97.56 65.1% Copper oxychloride or copper chloride hydroxide

023501 Cu2Cl(OH)3 1332-65-6 213.57 59.5% 

Copper oxychloride sulfate 023503 Cu2Cl(OH)3 + 

3Cu(OH)2 · CuSO4

8012-69-9 665.86 57.3% 

Copper ammonium complex 022702 Cu(NH3)42+ 16828-95-8 131.67 48.3% 

024405 (C6H6O7)-2 · Cu+2 10402-15-0 253.67 25.1% 

Group II 

Copper 

Compounds 

0649 

Chelates of copper citrate Chelates of copper gluconate 024405 2(C6H11O7)-1 · Cu+2 527-09-3 453.838 14.0% 

Cuprous oxide or Copper (I) oxide 

025601 Cu2O 1317-39-1 143.09 88.8% 

Cupric oxide or Copper (II) oxide 

042401 CuO 1317-38-0 79.545 79.9% 

Copper and 

Oxides 

4025 

Copper 022501 Cu 7440-50-8 63.546 100% 

Copper salts of fatty and rosin acids 

023104 Mixture of 

compounds 

9007-39-0 NA 

[depends on acid] 

% Cu; [depends on acid] 

Copper Salts 4026 

Copper ethylenediamine complex 

024407 2(C2H8N2) -1 · Cu+2 13426-91-0 181.74 34.9% 
22

Registration Review Case 

Common name EPA PC 

Code 

Formula C.A.S. 

Number 

Molecular weight (g/mol)

Percent Copper 

Con

Copper triethanolamine complex or Copper, ((2,2',2''-nitrilotris(ethanolato))(2-)-N,O,O',O'') 

024403 (C6H13O3N)-2 · Cu+2 82027-59-6 210.71 30.2%

Copper ethylenediaminetetraacetate (EDTA) 

039105 Cu · EDTA 12276-01-6 353.7 18.0% 

Copper thiocyanate 025602 N≡C–S-1 Cu+1 1111-67-7 121.63 52.2% Copper octanoate 023306 2(C8H15O2) -1 · Cu+2 20543-04-8 349.955 18.2% Copper, bis(acetatoO)diamine or Copper diammonia diacetate complex 

036011 Cu+2 · 2(NH3) · 

2(CH3CO(O-)) 

13822-80-5 215.695 29.5% 

Other Copper 

Compounds Copper ethanolamine 

complex; or Copper, bis(2-aminoethanolato-N,O) 

024409 2(C2H6ON)-1 · Cu+2 14215-52-2 183.696 34.6% 

Copper Compounds with Separate Registration Review Dockets 

Copper HDO 

5106 

Copper HDO; or Copper, bis[1-cyclohexyl-1,2-di(hydroxyl-kappaO)diazeniumato(2-)] 

235500 C12H22CuN4O4 312600-89-8 365.5 17.4% 

Copper naphthenate 023102 naphthoate · Cu+2 · 

naphthoate 

1338-02-9 405.89 15.6% 

Copper 8-quinolinolate 024002 C18H12CuN2O2 10380-28-6 351.846 18.1% 
III. Summary of Data Gaps – Coppers 

The table below summarizes all outstanding data needs for copper in Section I, of this document 

(Preliminary Work Plan), the Registration Review: Preliminary Problem Formulation for 

Ecological Risk, Environmental Fate, and Endangered Species Assessments for Coppers dated 

September 13, 2010, and Coppers: Human Health assessment Scoping Document in Support of 

Registration Review dated May 27, 2010. 

Use Type Guideline 

Number Anticipated Data Requirement Test 

Material 

Estimated 

Timeframe 

850.2100 Avian Acute Oral Toxicity1 Conventional TGAI 12 

850.4100 Tier II terrestrial plant toxicity, seedling emergence TGAI 12 

835.1110 Activated Sludge Sorption Isotherm TGAI 12 

850.6800 Modified Activated Sludge Respiration Inhibition TGAI 12 

NONGDLN Aquatic leaching Study for Wood PreservativesAWPA E11-06 TGAI 12 

Antimicrobial 

NONGDLN Leachability of Copper from Roofing Shingles TGAI 12 

 

1

The anticipated DCI will require a passerine study protocol to be submitted for review and approval by the Agency prior to this

study being initiated.