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EPA REGISTRATION DIVISION COMPANY NOTICE OF FILING FOR 

PESTICIDE PETITIONS PUBLISHED IN THE FEDERAL REGISTER 

EPA Registration Division contact: W. Cutchin 703-305-7990

INSTRUCTIONS: Please utilize this outline in preparing the pesticide petition. In 

cases where the outline element does not apply, please insert “NA-Remove” and 

maintain the outline. Please do not change the margins, font, or format in your 

pesticide petition. Simply replace the instructions that appear in green, i.e., “[insert 

company name],” with the information specific to your action.

TEMPLATE:

Stepan Company

2E8000

EPA has received a pesticide petition 2E8000 from Stepan Company, 22 West 

Frontage Rd., Northfield Illinois 60093 requesting, pursuant to section 408(d) of the 

Federal Food, Drug, and Cosmetic Act (FFDCA), 21 U.S.C. 346a(d), to amend 40 CFR 

part 180 to establish an exemption from the requirement of a tolerance for α-(ρNonylphenyl)poly(oxypropylene) block polymer with poly(oxyethylene) (CAS No.: 

37251-69-7; Mn = 1889 Daltons) when used as a pesticide inert ingredient as a surfactant 

in pesticide formulations under CFR part 180.960 in or on all raw agricultural 

commodities without limitations. 

EPA has determined that the petition contains data or information regarding the 

elements set forth in section 408 (d)(2) of FDDCA; however, EPA has not fully 

evaluated the sufficiency of the submitted data at this time or whether the data supports 

granting of the petition. Additional data may be needed before EPA rules on the petition.

A. Residue Chemistry

1. Plant metabolism. Stepan Company is petitioning that α-(p -

Nonylphenyl)poly(oxypropylene) block polymer with poly(oxyethylene) (CAS# 37251-

69-7; Mn=1889 Daltons) be exempt from the requirement of a tolerance based upon the 

definition of a low-risk polymer under 40 CFR 723.250. Therefore, plant metabolism in 

treated crops is not relevant.

2. Analytical method. Stepan Company is petitioning that α-(p -

Nonylphenyl)poly(oxypropylene) block polymer with poly(oxyethylene) (CAS# 37251-

69-7; Mn=1889 Daltons) be exempt from the requirement of a tolerance based upon the 

definition of a low-risk polymer under 40 CFR 723.250. Therefore, an analytical method 

to determine residues on treated crops is not relevant.
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3. Magnitude of residues. Stepan Company is petitioning that α-(p -

Nonylphenyl)poly(oxypropylene) block polymer with poly(oxyethylene) (CAS# 37251-

69-7; Mn=1889 Daltons) be exempt from the requirement of a tolerance based upon the 

definition of a low-risk polymer under 40 CFR 723.250. Therefore, magnitude of 

residues on treated crops is not relevant.

B. Toxicological Profile

1. Acute toxicity. No toxicological data is submitted with, or referenced in this 

tolerance exemption petition because α-(p -Nonylphenyl)poly(oxypropylene) block 

polymer with poly(oxyethylene) (CAS# 37251-69-7; Mn=1889 Daltons) meets the 

definition of a low-risk polymer under 40 CFR 723.250.

1a. α-(p -Nonylphenyl)poly(oxypropylene) block polymer with 

poly(oxyethylene); Mn=1889 Daltons; CAS# 37251-69-7 is a polymer molecule as 

defined by 40 CFR 723.250(b). That is, it contains a sequence of at least 3 monomer 

units which are covalently bound to at least one other monomer unit or other reactant.

1b. α-(p -Nonylphenyl)poly(oxypropylene) block polymer with 

poly(oxyethylene); Mn=1889 Daltons; CAS# 37251-69-7 has a number average 

molecular weight of 1889 and contains less than 0.1 percent oligomeric material below 

molecular weight 500 and 1,000 molecular weight.

1c. α-(p -Nonylphenyl)poly(oxypropylene) block polymer with 

poly(oxyethylene); Mn=1889 Daltons; CAS# 37251-69-7 is not a cationic polymer and is 

not anticipated to become a cationic polymer in a natural aquatic environment.

1d. α-(p -Nonylphenyl)poly(oxypropylene) block polymer with 

poly(oxyethylene); Mn=1889 Daltons; CAS# 37251-69-7 only contains the elements 

carbon, hydrogen, and oxygen; therefore, it meets the criteria for elemental composition.

1e. The polymer does not contain as an integral part of its composition, except as 

impurities, any element other than those listed in 40 CFR 723.250(d)(2)(ii).

1f. α-(p -Nonylphenyl)poly(oxypropylene) block polymer with 

poly(oxyethylene); Mn=1889 Daltons; CAS# 37251-69-7 is not designed or reasonably 

anticipated to substantially degrade, decompose, or depolymerize under normal use 

conditions.

1g. Fatty α-(p -Nonylphenyl)poly(oxypropylene) block polymer with 

poly(oxyethylene); Mn=1889 Daltons; CAS# 37251-69-7 is not manufactured or 

imported from monomers and/or other reactants that are not already included on the 

TSCA Chemical Substance Inventory or manufactured under an applicable TSCA section 

5 exemption.

1h. α-(p -Nonylphenyl)poly(oxypropylene) block polymer with 

poly(oxyethylene); Mn=1889 Daltons; CAS# 37251-69-7 is not a water-absorbing 

polymer with a number average molecular weight above 10,000 daltons.

1i. α-(p -Nonylphenyl)poly(oxypropylene) block polymer with poly(oxyethylene); 

Mn=1889 Daltons; CAS# 37251-69-7 contains no reactive functional groups that fail to 

meet the low-risk polymer exemption criteria under 40 CFR 723.250(e).]
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2. Genotoxicty. Not applicable-remove.

3. Reproductive and developmental toxicity. Not applicable-remove.

4. Subchronic toxicity. Not applicable-remove.

5. Chronic toxicity. Not applicable-remove.

6. Animal metabolism. Not applicable-remove.

7. Metabolite toxicology. Not applicable-remove.

8. Endocrine disruption. Not applicable-remove.

C. Aggregate Exposure

1. Dietary exposure. The physical and chemical characteristics of α-(p -

Nonylphenyl)poly(oxypropylene) block polymer with poly(oxyethylene) (CAS# 37251-

69-7; Mn=1889 Daltons) lead to the conclusion that there is a reasonable certainty of no 

harm from exposure to the polymer from food or drinking water.

i. Food. Not applicable-remove.

ii. Drinking water. Not applicable-remove.

2. Non-dietary exposure. The physical and chemical characteristics of α-(p -

Nonylphenyl)poly(oxypropylene) block polymer with poly(oxyethylene) (CAS# 37251-

69-7; Mn=1889 Daltons) lead to the conclusion that there is a reasonable certainty of no 

harm from exposure to the polymer through non-dietary means.

D. Cumulative Effects

α-(p -Nonylphenyl)poly(oxypropylene) block polymer with poly(oxyethylene)

(CAS# 37251-69-7; Mn=1889 Daltons) is a low-risk polymer. There is no information at 

this time to suggest that any toxic effects produced by this inert ingredient would be 

cumulative with any other chemical.

E. Safety Determination

1. U.S. population. α-(p -Nonylphenyl)poly(oxypropylene) block polymer with 

poly(oxyethylene) (CAS# 37251-69-7; Mn=1889 Daltons) meets all the criteria for 

qualification as a low-risk polymer under 40 CFR 723.250. Adverse effects on the U.S. 

population are not expected from the use of this inert ingredient in pesticide formulations.

2. Infants and children. α-(p -Nonylphenyl)poly(oxypropylene) block polymer 

with poly(oxyethylene) (CAS# 37251-69-7; Mn=1889 Daltons) is a low-risk polymer 
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under 40 CFR 723.250. No adverse effects are expected from use of this inert ingredient 

in pesticide formulations. Based on the physical and chemical properties of the molecule, 

there is no reason to believe that infants and children will be disproportionately at risk.

F. International Tolerances

There are no known U.S. or international tolerances for α-(p -

Nonylphenyl)poly(oxypropylene) block polymer with poly(oxyethylene) (CAS# 37251-

69-7; Mn=1889 Daltons).