EPA REGISTRATION DIVISION COMPANY NOTICE OF FILING FOR 

PESTICIDE PETITIONS PUBLISHED IN THE FEDERAL REGISTER 

EPA Registration Division contact: [PV Shah, Branch Chief Inert Assessment 

Branch (IAB) 703-308-1846]

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:

[Lamberti USA, Inc.]

[TBD]

EPA has received a pesticide petition ([TBD]) from [Lamberti USA,

Incorporated, 161 Washington Street Eight Tower Bridge, Suite 1000

Conshohocken, PA 19428] 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 the polymers of 

cellulose carboxymethyl ether, potassium salt CAS No. 54848-04-3 having a 

number-average molecular weight from 1,000 to 10,000 Daltons, used as 

dispersants, emulsifiers, surfactants, and related adjuvants of surfactants in food 

use pesticide formulations in or on raw agricultural commodities. EPA has determined 

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

408 (d)(2) of FFDCA; 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 based on the fact that this information is

not required for the establishment of a tolerance exemption.]

2. Analytical method. [NA-Remove based on the fact that this information is

not required for the establishment of a tolerance exemption.]

3. Magnitude of residues. [NA-Remove based on the fact that this information
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is not required for the establishment of a tolerance exemption.]

B. Toxicological Profile

1. Acute toxicity. [Cellulose carboxymethyl ether, potassium salt conforms to the 

definition of a polymer given in 40 CFR 723.250(b) and meets the following 

40 CFR 723.250 criteria that are used to identify low-risk polymers.

1. The polymer is not a cationic polymer nor is it reasonably anticipated to become a 

cationic polymer in a natural aquatic environment.

2. The polymer does contain as an integral part of its composition the atomic

elements carbon, hydrogen, and oxygen.

3. 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).

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

substantially degrade, decompose, or depolymerize.

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

are already included on the TSCA Chemical Substance Inventory.

6. The polymer is not a water absorbing polymer with a number average molecular 

weight (MWn) greater than or equal to 10,000 Daltons.

7. The polymer does not contain fluorine, so 40CFR 723.250(d)(6) does not apply are 

not acutely toxic by the oral and dermal routes of exposure, or via inhalation under 

normal use conditions. Concentrated materials are generally not corrosive, eye and 

skin irritants and not dermal sensitizers. There is no evidence that these polymers 

based on cellulose carboxymethyl ether, potassium salt are neurotoxic, mutagenic, 

or oncogenic.]

2. Genotoxicty. [NA-Remove based on the fact that this polymer meets the 40

CFR 723.250 criteria that are used to identify low-risk polymers.]

3. Reproductive and developmental toxicity. [NA-Remove based on the fact that 

this polymer meets the 40 CFR 723.250 criteria that are used to identify low-risk 

polymers.]

4. Subchronic toxicity. [NA-Remove based on the fact that this polymer meets 

the 40 CFR 723.250 criteria that are used to identify low-risk polymers.]

5. Chronic toxicity. [[NA-Remove based on the fact that this polymer meets 

the 40 CFR 723.250 criteria that are used to identify low-risk polymers.]

6. Animal Metabolism. .[NA-Remove based on the fact that this polymer meets 

the 40 CFR 723.250 criteria that are used to identify low-risk polymers.]
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7. Metabolite toxicity. [NA-Remove based on the fact that this polymer meets 

the 40 CFR 723.250 criteria that are used to identify low-risk polymers.]

8. Endocrine Disruption. [Not expected based on the fact that this polymer 

meets the 40 CFR 723.250 criteria that are used to identify low-risk polymers.]

C. Aggregate Exposure

1. Dietary exposure. [This polymer meets the 40 CFR 723.250 criteria that are

used to identify low-risk polymers.]

i. Food. [This polymer meets the 40 CFR 723.250 criteria that are used 

to identify low-risk polymers.]

ii. Drinking water. [This polymer meets the 40 CFR 723.250 criteria that 

are used to identify low-risk polymers.]

2. Non-dietary exposure. [This polymer meets the 40 CFR 723.250 

criteria that are used to identify low-risk polymers.]

D. Cumulative Effects

[This polymer meets the 40 CFR 723.250 criteria that are used 

to identify low-risk polymers.]

E. Safety Determination

1. U.S. population. [This polymer meets the 40 CFR 723.250 criteria that 

are used to identify low-risk polymers.]

2. Infants and children. [This polymer meets the 40 CFR 723.250 criteria 

that are used to identify low-risk polymers.]

F. International Tolerances

[There are no known international tolerances for this polymer.]