I 

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 

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: 

BASF Corporation 

[EPA Petition number: XXXXX] 

EPA has received a pesticide petition ([XXXXX]) from BASF Corporation, 100 

Park Avenue, 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. 

(Options (pick one) 

I. by establishing a tolerance for residues of "NA-Remove" 

2. to establish an exemption from the requirement of a tolerance for 

2-Propenoic acid, polymer with ethenyl acetate, ethenylbenzene, 2-ethylhexyl 2- propenoate and ethyl 2-propenoate CASRN: 85075-52-1 under 40 CFR 180.960 when used 

as an inert ingredient as a coating for seeds and as a dust suppressant in a pesticide 

formulation without limitation. in or on the raw agricultural commodity ["NA-Remove"] 

at ["NA-Remove" ] parts per million (ppm). "NA-Remove". EPA has determined that 

the petition contains data or information regarding the elements set forth in section 40R 

(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. "NA-Remove" 
2 

2. Analytical method. "NA-Remove" 

3. Magnitude o.fresidues. "NA-Remove" 

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, polymer with ethenyl acetate, ethenylbenzene, 2-

ethylhexyl 2-propenoate and ethyl 2-propenoate CASRN: 85075-52-1 is a 

polymer as defined by 40 CFR 723.250(b). In addition, 2-Propenoic acid, 

polymer with ethenyl acetate, ethenylbenzene, 2-ethylhexyl 2-propenoate 

and ethyl 2-propenoate CASRN: 85075-52-1 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, polymer with ethenyl acetate, ethenylbenzene, 2-

ethylhexyl 2-propenoate and ethyl 2-propenoate CASRN: 85075-52-1 

consists of a number average molecular weight greater than 10,000 

daltons, 1.1% of its oligomeric material weighing below 500 daltons and 3.6 

% of its oligomeric material weighing less than 1,000 daltons. 

3. 2-Propenoic acid, polymer with ethenyl acetate, ethenylbenzene, 2-

ethylhexyl 2-propenoate and ethyl 2-propenoate CASRN: 85075-52-1 , 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 cf 

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. 
3 

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, polymer with ethenyl acetate, 

ethenylbenzene, 2-ethylhexyl 2-propenoate and ethyl 2-propenoate CASRN: 

85075-52-1, also meets as required the following exemption criteria 

specified in 40 CFR 723.250(e). The polymer is not designed to be a waterabsorbing polymer that is capable of absorbing its weight of water. 

Thus, 2-Propenoic acid, polymer with ethenyl acetate, ethenylbenzene, 2-

ethylhexy12-propenoate and ethyl 2-propenoate CASRN: 85075-52-1 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, polymer with ethenyl 

acetate, ethenylbenzene, 2-ethylhexyl 2-propenoate and ethyl 2-propenoate 

CASRN: 85075-52-1. 

C. Aggregate Exposure 

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

Propenoic acid, polymer with ethenyl acetate, ethenylbenzene, 2-ethylhexyl 2-

propenoate and ethyl 2-propenoate CASRN: 85075-52-1 could be present in all raw 

and processed agricultural commodities and drinking water, and that nonoccupational non-dietary exposure was possible. The number average MW of 2-

Propenoic acid, polymer with ethenyl acetate, ethenylbenzene, 2-ethylhexyl 2-

propenoate and ethyl 2-propenoate CASRN: 85075-52-1 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, 

polymer with ethenyl acetate, ethenylbenzene, 2-ethylhexyl 2-propenoate and 

ethyl 2-propenoate CASRN: 85075-52-1 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 whethar 

to establish, modify, or revoke a tolerance or tolerance exemption, " available 

information" concerning the cumulative effects of a parti cular chemical's esi t•~s 

and " other substances that have a common mechanism of toxicity" , must be 

considered. At this time, available data to determine whether 2-Propenoic acid, 

polymer with ethenyl acetate, ethenylbenzene, 2-ethylhexyl 2-propenoate and 

ethyl 2-propenoate CASRN: 85075-52-1 has a common mechanism of toxicity witt) 

other substances is not available. 
4 

Since 2-Propenoic acid, polymer with ethenyl acetate, ethenylbenzene, 2-

ethylhexyl 2-propenoate and ethyl 2-propenoate CASRN: 85075-52-1 meets the 

definition of a low concern polymer, 2-Propenoic acid, polymer with ethenyl 

acetate, ethenylbenzene, 2-ethylhexyl 2-propenoate and ethyl 2-propenoate 

CASRN: 85075-52-1 is not expected to show any cumulative effects. 

E. Safety Determination 

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, polymer with ethenyl acetate, 

ethenylbenzene, 2-ethylhexyl 2-propenoate and ethyl 2-propenoate CASRN: 

85075-52-1. 

2.lnfants 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, polymer with ethenyl acetate, 

ethenylbenzene, 2-ethylhexyl 2-propenoate and ethyl 2-propenoate CASRN: 

85075-52-1, 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. lntemational Tolerances 

There are no CODEX maximum residue limits established for 2-Propenoic 

acid, polymer with ethenyl acetate, ethenylbenzene, 2-ethylhexyl 2-propenoate 

and ethyl 2-propenoate CASRN: 85075-52-1 in or on crops or commodities at this 

time. 

G. Other Considerations 

1. Endocrine Disruptors: There is no available evidence that 2-Propenoi~ 

acid, polymer with ethenyl acetate, ethenylbenzene, 2-ethylhexyl 2-

propenoate and ethyl 2-propenoate CASRN: 85075-52-1 is an endocrine 

disruptor.