UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASIUNGTON, DC 20460
OFFICE OF PREVENTION, PESTICIDES AND TOXIC SUBSTANCES
Julv 11.2003
Mr. Kevin J. Archer Product Development and Regulatory Affairs Manager Chemical Specialties, Inc. 200 E. Woodlawn Road Charlotte, NC 28217
Subject: CSI Arsenic Acid 75% EPA Registration No. 10465-32 Letter dated May 15, 2003
Dear Mr. Archer:
The following amendment, submitted in connection with registration under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), as amended, is acceptable with comments:
Proposed Amendment
• Revised labeling
General Comment
1. Add the statement" This product is toxic to fish" at the beginning of the environmental hazards statement.
2. The first aid statement must be revised in accordance with PR Notice 2001-1 by October 1, 2003.
A stamped copy of the accepted labeling is enclosed. Submit three (3) copies of your final printed labeling before distributing or selling the product. 2
Should you have any questions or comments concerning this letter, please contact me at (703) 308-6422, or Lisa McKelvin at (703) 308-7496.
Sinc ely, ~1~I/J am Heyward roduct Manager (34) 1Regulatory Management Branch II Antimicrobials Division (7510C)
Enclosure PRECAUTIONARY STATEMENTS RESTRICTED USE PESTICIDE POST A COPY OF HAZARDS TO HUMANS & DOMESTIC ANIMALS SPECIFIC! DANGER DUE TO ACUTE TOXICITY AND BECAUSE THIS PRODUCT CONTAINS ARSENIC, CSt Arsemc Acid IS an end-use product used SOME TYPES OF WHICH HAVE BEEN ASSOCIATED WITH TUMOR when tank mixed with CSt Copper Sulfate Soil Corrosl"/e Causes irreversible eye damage and sKin burns Fatal ,f swallowed Reg. No, 10465-25) atlhe use site by commerci inhaled. or absorbed through the skin 00 rot get n eyes. on skin or on clothing Do DEVELOPMENT IN HUMANS CSI Arsenic AcId is also used as an end-use pr not breathe dust or spray mist Wear goggies or face shield, protective clothing. and tank-mixed, as described per specific !nstruc For sale to and use only by certified applicators or persons under their direct establishments. rubber gloves Contains inorganic Arsenic Handl~ only In well ventilated areas and These solutions are to be impregnated into Ion use only with adequate ventilated or resplralo!), prctectlon. See respiratory protection supervisions and only for those uses covered by the certified applicator certification vacuum pressure system requirements under SPECIFIC USE INSTRUCTONS. Self contained breathing CC. Using CS1 Copper Sulfate Crystals apparatus should be worn when fighting fire involving this product To 275 gallons of water, add 400 pounds (8.SO ENVIRONMENTAL HAZARDS CSI ARSENIC ACID 75% Sodium Dichromate. The .final component to be Do not discharge effluent containing tris product Into lakes. streams. ponds, estuaries Using CSI Copper Sulfate Solution: FOR USE AS A WOOD PRESERVATIVE IN To 292 gallons of water, add 4,675 gallons of oceans or other waters unless in ac:~ordance with the requirements of a National COMMERCIAL WOOD TREATING PlANTS Arsenic Acid. Pollutant Discharge Elimination System (NPDES) ;)ermlt and the permitting authoflty CC' has been notified in writing prior to discharge. Do not discharge effluent containing Using C51 Copper Sulfate Crystals: ACTIVE INGREDIENTS To 292 gaHons of water, add 400 pounds (8,5C this product to sewer systems without previously notifying the local sewage treatment Arsenic Acid (H,AsO.) ...... 75.0% Sodium Dichromate, The final component to be plant authority For guidance contact your State Water Board or Regional Office of the INERT INGREDIENT ...... 25.0% Using CSI Copper Sulfate Solution: EPA To 2,558 gallons of water, add 4,675 9a1lons TOTAL ...... 100.00% Dichromate Solution, The final step is to add J.< PHYSICAL OR CHEMICAL HAZARDS , Arsenic can react with several metais l:lcluding gal.3nized metals and biack iron Do Total .,.."ic, exp ~ , ,~ Association, as they pertain to type of wood r pOSSIbility of hydrogen liberation and the development of excessive pressure ", Cy~S c,"~ ,., .. -.",. d;~ DISPOSAL treatment method details, Treated wood is pro and while rot ,;: ~'" 3K:iN "" ;~" ·"al'" , '.,' "~5" ." ,~. Pestldde wastes are acutely hazardous. Improper dIsposal of e)((;ess pesllode, spray mixture, Of rinsate is a Use of thIs product may be hazardOUS to you v!oIatlon of Federal Law. If this waste cannot be disposed of hy use according to label instructions, contact your v.tlich have been associated wrth tumor develo State Pesticide or Environmental Control Agency or the Hazardou> Waste Representative at the nearest EPA :. ;N··i:''...::D ~'C;' -,,~. . -"cess." \ o ~r"atn' 'l ,'-. ,~c directions and precautions, and by properly usi Regional Office for guidance Applicators must wear gloves Impervious to thl CONTAINER DISPOSAL ~f expected (e,g" handling freshly treated wood a ACCEP'!:'ED !ndi~duals ~o enter pressure treatment cylinl _ __ .I.tfating solutlOl1 (e.g., cylinders that are !n ope Triple rinse (or equivalent). Then off~ for recyding or recondiliOniflg or puncture and dispose of in a sanitary landfill or incineration, or, if allowed by State and local auihonlles, by burning. If burned, stay our of smoke "~.th C'-,~~,:' '~:'. '7.B i.-.~ ~'.~Ih. ing, includin.g overalls, jacket.. glOve.s, ani SPILLS Manufactured By: .... _..- _ _' .. _ ..-.,,, _1~1':l!duaIS who enter pressure-treatment cy!ln r- EJ.::.t,;.1..l:" •• ,. '[ --".j, ':.tUpirators (MSHAlNI05H--appmved form~ Chemical Specialties, Inc, , or exceeds 10 micrograms per cubic meter of ! _" _.:wer spilled liquid Of neutralize with 10 Ibs. lime per gallon of liqUid Sweep up or vacuum area thoroughly to -- 200 East Woodlawn Road, Suite 250 Protective eqUIpment must be changed v.tlen :.i-: :~;.jove any remaining contaminated lime or soil. Consult federal, $'..3te or local disposal authorities for approved - .. -.. equipment and wor\( shoes or boots and equi < -- -':msposal procedures. "l Char10tle NC 28217 --r .. J. I L I 1 .?Oi f, boots must be left at the plant and disposed 01 DIRECTIONS FOR USE Email: [email protected] V ... ,-,." state and federal regulations Phone 704-522-0825 !n case of emergegcy • ,.. ;:'~r __ - -_ -: , ' ~~~uals in the ~ area of an arsenical 1M Effective December 31, 2003, this product may only be used (1) for formulation of the following end-use wood ~J undeT t, ._- ~ , c '- . etnr;:t«lcy tilter respIrators. MSHAINIOSH-ap preservative products: ammomacal copper zinc arsenate (ACZA) Of chromated copper arsenate (CCA) labeled in EPA Reg No 10465-32 'O.-~.-- A":~' :- :N.eLiilMwn or exceeds 10 micrograms p! accordance with the Directions for Use shown below, or (2) by persons other than the registrant. In combination EPA Est. No. 10465-NC-1 0 f---'-- ~ . ,JotetoUser.Examplesofacceptahiemate with one or more other products to make: ACZA wood preservatiye or CCA wood preservative that IS used 111 ru._:.: ....:-·,' EPA Est No 10465-GA-1 0 erp~:·, ..I.~ --', ...!.. _ '11lq~lred dunng apphcatlon and handhng of inC accordance with the Directions for Use shown below. . . _ ,.._;, .. 0,_.,'._.,", "~'>-' h_' ,~~- ':l~~) rubber and polyethylene EPA Est. No. 10465-TX-1 0 ?e~~,.>' ... ·-~,-- d. - Monitonng; A!r rnomtonng programs, prac Effecllve December 31, 2003, thIS product may only be used for preservatIve treatment of the following categories (I 4./ j .--:.. :.J accordance with the Instructions of the attache of forest products and in accordance with the respective cited standart! (noted parenthetically) of the 2001 edition of I I "" ;74 Appbcators must not eat, dnnk, Of use tobac the American Wood Preserversi Association Standards: lumber and Timber for Salt Water Use Only (C2), Piles expose them to the wood treatment formulatlO . (C3), Poles (C4), Plywood (C9), Wood for Highway Construction (CH). Poles, Piles and Posts Used as Structural Net Contents: lb . cylmders, rT\Jxing chemicals, and handling fresl Members on Farms, and Plywood Used on Farms (CIS), Wood !or Marine Construction (Ct8), Luni:ler and Wash thoroughly alter skin contact, and befon: Plywood for Permanent Wood Foundations (C22), Round Poles and Posts Used in Building Construction (C23), Processes used to apply inorganic arsel1lc f( Sawn Timber Used To Support Residential and Commercial Structl.A'es (C24), Sawn Crossarms (C25), Structural defined by AWPA Standard C-l. (Visible surf; I 31ued laminated Members and Laminations Before GlUing (C28), Str\!ctural Composite Lumber (C33), and Shakes POST A COPY OF THIS lABEL IN THE WORK AREA Small soiated or infrequent spots of chemIcal i ~~.~. Shingles (C34), Forest products treated with this product may only be sold or distributed for uses within the ~PA CommodIty Standards under which the treatment occurred.