EPA REGISTRATION DIVISION COMPANY NOTICE OF FILING FOR PESTICIDE 

PETITIONS PUBLISHED IN THE FEDERAL REGISTER 

EPA Registration Division contact: PV Shah, Registration Division (7505P), Office of 

Pesticide Programs, Environmental Protection Agency, 1200 Pennsylvania Ave., NW., 

Washington, DC 20460-001; telephone number: 703-308-1846; email address: 

shah.pv@epa.gov

BASF Corporation

IN-10700

 EPA has received a pesticide petition, IN-10700, from BASF Corporation, 100 

Campus Drive, Florham Park, NJ 07932, proposing, 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 2-Propenoic 

acid, butyl ester, polymer with 1,6-diisocyanatohexane, N-(hydroxymethyl)-2-methyl-2-

propenamide and 2-propenenitrile CASRN: 1469998-09-1, under 40 CFR 180.960 when 

used as an inert ingredient as a binder polymer in a pesticide formulation without 

limitation. 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: N/A

2. Analytical method: N/A

3. Magnitude of residues: N/A

B. Toxicological Profile

The definition of a polymer is given in 40 CFR 723.250(b). The following exclusion 

criteria for identifying these low risk polymers are described in 40 CFR 723.250(d).

1. 2-Propenoic acid, butyl ester, polymer with 1,6-diisocyanatohexane, N-

(hydroxymethyl)-2-methyl-2-propenamide and 2-propenenitrile CASRN: 

1469998-09-1 is a polymer as defined by 40 CFR 723.250(b). In addition, 2-

Propenoic acid, butyl ester, polymer with 1,6-diisocyanatohexane, N-

(hydroxymethyl)-2-methyl-2-propenamide and 2-propenenitrile CASRN: 

1469998-09-1 contains at least 3 monomer units which are covalently bound to 

at least one other monomer unit or other reactant and consists of a simple weight 

majority of the polymer molecules. The monomer sequences form uninterrupted 

strings in the polymer and distribution of the molecular weight of the polymer is 

due largely to the number of monomer units in the individual molecules.

2. 2-Propenoic acid, butyl ester, polymer with 1,6-diisocyanatohexane, N-

(hydroxymethyl)-2-methyl-2-propenamide and 2-propenenitrile CASRN: 

1469998-09-1 consists of a number average molecular weight greater than 

10,000 daltons, 0.6 % of its oligomeric material weighing below 500 daltons and 

1.3 % of its oligomeric material weighing less than 1,000 daltons.
3. 2-Propenoic acid, butyl ester, polymer with 1,6-diisocyanatohexane, N-

(hydroxymethyl)-2-methyl-2-propenamide and 2-propenenitrile CASRN: 

1469998-09-1, is not a cationic polymer nor is it reasonably anticipated to 

become a cationic polymer in a natural aquatic environment. The polymer does 

not contain any functional groups which would dissociate into a cationic moiety in 

water. The polymer does not contain a net positively charged atom(s) or 

associated groups of atoms covalently linked to its polymer molecule.

4. The polymer contains as an integral part of its composition the atomic 

elements carbon, hydrogen, nitrogen and oxygen.

5. 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).

6. The polymer is neither designed nor can it be reasonably anticipated to 

substantially degrade, decompose, or depolymerize. For the purposes of this 

section, degradation, decomposition, or depolymerization mean those types of 

chemical change that convert a polymeric substance into simpler, smaller 

substances, through processes including but not limited to oxidation, hydrolysis, 

attack by solvents, heat, light, or microbial action.

7. The polymer is manufactured or imported from monomers and/or reactants 

that are already included on the TSCA Chemical Substance Inventory or 

manufactured under an applicable TSCA section 5 exemption.

8. The polymer is not a water absorbing polymer with a number average 

molecular weight (MW) greater than or equal to 1,000 daltons. Additionally, the 

polymer, 2-Propenoic acid, butyl ester, polymer with 1,6-diisocyanatohexane, N-

(hydroxymethyl)-2-methyl-2-propenamide and 2-propenenitrile CASRN: 

1469998-09-1, also meets as required the following exemption criteria specified 

in 40 CFR 723.250(e). The polymer is not designed to be a water-absorbing 

polymer that is capable of absorbing its weight of water.

 Thus, 2-Propenoic acid, butyl ester, polymer with 1,6-diisocyanatohexane, N-

(hydroxymethyl)-2-methyl-2-propenamide and 2-propenenitrile CASRN: 1469998-09-1

meets all the criteria for a polymer to be considered low risk under 40 CFR 723.250. 

Based on its conformance to the above criteria, no mammalian toxicity is anticipated 

from dietary, inhalation, or dermal exposure to 2-Propenoic acid, butyl ester, polymer 

with 1,6-diisocyanatohexane, N-(hydroxymethyl)-2-methyl-2-propenamide and 2-

propenenitrile CASRN: 1469998-09-1.

C. Aggregate Exposures

For the purposes of assessing potential exposure under this exemption, 2-Propenoic 

acid, butyl ester, polymer with 1,6-diisocyanatohexane, N-(hydroxymethyl)-2-methyl-2-

propenamide and 2-propenenitrile CASRN: 1469998-09-1 could be present in all raw 

and processed agricultural commodities and drinking water, and that non-occupational 

non-dietary exposure was possible. The number average MW of 2-Propenoic acid, butyl 

ester, polymer with 1,6-diisocyanatohexane, N-(hydroxymethyl)-2-methyl-2-propenamide 
and 2-propenenitrile CASRN: 1469998-09-1 is greater than 10,000 daltons. Generally, a 

polymer of this size would be poorly absorbed through the intact gastrointestinal tract or 

through intact human skin. Since 2-Propenoic acid, butyl ester, polymer with 1,6-

diisocyanatohexane, N-(hydroxymethyl)-2-methyl-2-propenamide and 2-propenenitrile 

CASRN: 1469998-09-1 conforms to the criteria that identify a low risk polymer, there are 

no concerns for risks associated with any potential exposure scenarios that are 

reasonably foreseeable. Therefore a tolerance is not necessary to protect the public 

health.

D. Cumulative Effects

 Section 408 (b)(2)(D)(v) of FFDCA requires that, when considering whether to 

establish, modify, or revoke a tolerance or tolerance exemption, ``available information'' 

concerning the cumulative effects of a particular chemical's residues and ``other 

substances that have a common mechanism of toxicity'', must be considered. At this 

time, available data to determine whether 2-Propenoic acid, butyl ester, polymer with 

1,6-diisocyanatohexane, N-(hydroxymethyl)-2-methyl-2-propenamide and 2-

propenenitrile CASRN: 1469998-09-1 has a common mechanism of toxicity with other 

substances is not available. 

Since 2-Propenoic acid, butyl ester, polymer with 1,6-diisocyanatohexane, N-

(hydroxymethyl)-2-methyl-2-propenamide and 2-propenenitrile CASRN: 1469998-09-1

meets the definition of a low concern polymer, 2-Propenoic acid, butyl ester, polymer 

with 1,6-diisocyanatohexane, N-(hydroxymethyl)-2-methyl-2-propenamide and 2-

propenenitrile CASRN: 1469998-09-1 is not expected to show any cumulative effects. 

E. Determination of Safety

1. U.S. Population: Based on the conformance to the criteria used to identify a 

low risk polymer, there is a reasonable certainty of no harm to the U.S. 

population, including infants and children, from aggregate exposure to residues 

of 2-Propenoic acid, butyl ester, polymer with 1,6-diisocyanatohexane, N-

(hydroxymethyl)-2-methyl-2-propenamide and 2-propenenitrile CASRN: 

1469998-09-1.

2. Infants and children: Section 408 of the FFDCA provides that EPA shall apply 

an additional tenfold margin of safety for infants and children in the case of 

threshold effects to account for prenatal and postnatal toxicity and the 

completeness of the data base unless EPA concludes that a different margin of 

safety will be safe for infants and children. Due to the expected low toxicity of 2-

Propenoic acid, butyl ester, polymer with 1,6-diisocyanatohexane, N-

(hydroxymethyl)-2-methyl-2-propenamide and 2-propenenitrile CASRN: 

1469998-09-1, based on the polymer meeting the definition of a low risk polymer 

under 40 CFR 723.250 a safety factor analysis to assess the risk is not 

necessary. For the same reasons the additional tenfold safety factor is 

unnecessary.

F. International Tolerances
There are no CODEX maximum residue limits established for 2-Propenoic acid, butyl 

ester, polymer with 1,6-diisocyanatohexane, N-(hydroxymethyl)-2-methyl-2-propenamide 

and 2-propenenitrile CASRN: 1469998-09-1 in or on crops or commodities at this time.

G. Other Considerations

1. Endocrine Disruptors: There is no available evidence that 2-Propenoic acid, 

butyl ester, polymer with 1,6-diisocyanatohexane, N-(hydroxymethyl)-2-methyl-2-

propenamide and 2-propenenitrile CASRN: 1469998-09-1 is an endocrine 

disruptor.