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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 - 30 5 - 7990 ] INSTRUCTIONS: Please utilize this outline in preparin g 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 g reen , i.e., “ [ insert company name ] ,” with the information specific to your action. TEMPLATE: [ Akzo Nobel Surface Chemistry LLC ] [ 1E7835 ] EPA has received a pesticide petition ( [ 1E7835 ] ) from [ Akzo Nobel Surface Chemistry LLC ] , [ 909 Mueller Avenue, Cha ttanooga, TN 37406 ] 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. 2. to establish an exemption from the requirement of a tolerance for [ Methacrylic acid - 2 - ethylh exyl acrylate - sodium 2 - acrylamido - 2 - methyl propane sulfonate copolymer sodium salt (CAS RN 1260001 - 65 - 7 ) when used as an inert ingredient as a dispersant in pesticide formulations under 40 CFR 180.960. Akzo Nobel is submitting a petition to EPA under the F ederal Food Drug and Cosemetic Act [FFDCA], as amended by the Food Quality Protection Act of 1996 [FQPA] requesting an exemption from the requirements of a tolerance. This petition requests the elimination of the need to establish a maximum permissible le vel for residues of Acrylic acid - benzyl methacrylate - 1 - propanesulfonic acid, 2 - methyl - 2 - [(1 - oxo - 2 - propenyl)amino] - , monosodium salt copolymer acid version ] in or on [all] raw agricultural commodit ies. 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 d a ta at this time or whether the data supports granting of the petition. Additional data may be needed befor e EPA rules on the petition. A. Residue Chemistry 1. Plant metabolism. [ NA - Remove based on fact this information is generally not required when all criteria for polymer exemption per 40 CFR 723.250 are met . ]2 2. Analytical method. [ NA - Remove based on fact this information is generally not required when all criteria for polymer exemption per 40 CFR 723.250 are met. In addition , Akzo Nobel is petitioning for an exemption from the requirement of a tolerance without any numerical limitations. ] 3. Magnitu de of residues. [ NA - Remove based on fact this information is generally not required when all criteria for polymer exemption per 40 CFR 723.250 are met. ] ] B. Toxicological Profile 1. Acute toxicity. [ T he EPA has established a set of criteria which ident ify categories of polymers that present low risk. Th ese criteri a (codi fied in 40 CFR 723.250) identify polymers that are relatively unreactive and stable compared to other chemical substances as well as polymers that are not readily absorbed. These propert ies generally limit a polymer’s ability to cause adverse effects. No mammalian toxicity is anticipated from dietary, inhalation or dermal exposure for chemical substances meeting the requirement for polymers of low risk. Akzo Nobel asserts that polymers me eting th is polymer exemption criteria w ill present minimal or no risk. Therefore, Akzo Nobel believes an exemption from the requirement of a tolerance is justified since in the case of low risk polymers it can be clearly demonstrated that the risks from ag gregate exposure to pesticide chemical residues under reasonably foreseeable circumstances will poses no appreciable risks to human health. Methacrylic acid - 2 - ethylhexyl acrylate - sodium 2 - acrylamido - 2 - methyl propane sulfonate copolymer sodium salt meets the specific criteria per CFR 40 723.250 as described below. • Methacrylic acid - 2 - ethylhexyl acrylate - sodium 2 - acrylamido - 2 - methyl propane sulfonate copolymer sodium salt is not a cationic polymer, nor is it reasonably anticipated to become a cationic polymer in a natural aquatic environment. • Methacrylic acid - 2 - ethylhexyl acrylate - sodium 2 - acrylamido - 2 - methyl propane sulfonate copolymer sodium salt contain s as an integral part of its composition the atomic elements carbon and hydrogen. • Methacrylic acid - 2 - ethylhexyl acrylate - sodium 2 - acrylamido - 2 - methyl propane sulfonate copolymer sodium salt does not contain as an integral part of its composition any elements other than those listed in 40 CFR 723.250. • Methacrylic acid - 2 - ethylhexyl acrylate - sodium 2 - acryla mido - 2 - methyl propane sulfonate copolymer sodium salt is not designed, nor is reasonably anticipated to substantially degrade, decompose, or depolymerize. • Methacrylic acid - 2 - ethylhexyl acrylate - sodium 2 - acrylamido - 2 - methyl propane sulfonate copolymer sodi um salt is manufactured only from monomers and or reactants that are a lready included on the TSCA Chemical Substance Inventory . • Methacrylic acid - 2 - ethylhexyl acrylate - sodium 2 - acrylamido - 2 - methyl propane sulfonate copolymer sodium salt is not a water abs orbing polymer. • Methacrylic acid - 2 - ethylhexyl acrylate - sodium 2 - acrylamido - 2 - methyl propane sulfonate copolymer sodium salt does not contain any group as a reactive functional group.3

• Methacrylic acid - 2 - ethylhexyl acrylate - sodium 2 - acrylamido - 2 - methyl pr opane sulfonate copolymer sodium salt contain s a minimum number average molecular weight of > 1000 Daltons and a maximum number average molecular weight of 10,000 Daltons. • Acrylic acid - benzyl methacrylate - 1 - propanesulfonic acid, 2 - methyl - 2 - [(1 - oxo - 2 - propenyl)amino] - , monosodium salt copolymer acid version c ontain less than 10% oligomeric material below molecular weight of 500 Daltons and less than 25% oligomeric material below molecular weight 1,000 Daltons. ] 2. Genotoxicty. [ N/A

– Remove based u pon Methacrylic acid - 2 - ethylhexyl acrylate - sodium 2 - acrylamido - 2 - methyl propane sulfonate copolymer sodium salt conform ing to all criteria for low risk polymers as codified in 40 CFR 723.250. Substances with molecular weights greater than 1 ,000 Daltons gen erally are not absorbed through intact skin, and substances with molecular weights greater than 1000 Daltons are generally not absorbed through the intact gastrointestinal tract . Chemicals not absorbed through the skin or gastrointestinal tract generally a re incapable of eliciting a toxic response .] 3. Reproductive and developmental toxicity. [ N /A

– Remove based upon Acrylic acid - benzyl methacrylate - 1 - propanesulfonic acid, 2 - methyl - 2 - [(1 - oxo - 2 - p ropenyl)amino] - , monosodium salt copolymer acid version con form ing to all criteria for low risk polymers as codified in 40 CFR 723.250. Substances with molecular weights greater than 1 ,000 Daltons generally are not absorbed through intact skin, and substances with molecular weights greater than 1000 Daltons are g enerally not absorbed through the intact gastrointestinal tract . Chemicals not absorbed through the skin or gastrointestinal tract generally are incapable of eliciting a toxic response .] 4. Subchronic toxicity. [ N /A

– Remove based upon Methacrylic acid - 2 - ethylhexyl acrylate - sodium 2 - acrylamido - 2 - methyl propane sulfonate copolymer sodium salt conform ing to all criteria for low risk polymers as codified in 40 CFR 723.250. Substances with molecular weights greater than 1 ,000 Daltons generally are not absorbe d through intact skin, and substances with molecular weights greater than 1000 Daltons are generally not absorbed through the intact gastrointestinal tract . Chemicals not absorbed through the skin or gastrointestinal tract generally are incapable of elicit ing a toxic response . ] 5. Chronic toxicity. [ N /A

– Remove based upon Methacrylic acid - 2 - ethylhexyl acrylate - sodium 2 - acrylamido - 2 - methyl propane sulfonate copolymer sodium salt conform ing to all criteria for low risk polymers as codified in 40 CFR 723.25 0. Substances with molecular weights greater than 1 ,000 Daltons generally are not absorbed through intact skin, and substances with molecular weights greater than 1000 Daltons are generally not absorbed through the intact gastrointestinal tract . Chemicals not absorbed through the skin or gastrointestinal tract generally are incapable of eliciting a toxic response . ] 6. Animal metabolism. [ Substances with molecular weights greater than 1 ,000 Daltons generally are not absorbed through intact skin, and substa nces with molecular4

weights greater than 1000 Daltons are generally not absorbed through the intact gastrointestinal tract . Chemicals not absorbed through the skin or gastrointestinal tract generally are incapable of eliciting a toxic response. ] 7. Metab olite toxicology . [ N /A

– Remove based upon Methacrylic acid - 2 - ethylhexyl acrylate - sodium 2 - acrylamido - 2 - methyl propane sulfonate copolymer sodium salt conform ing to all criteria for low risk polymers as codified in 40 CFR 723.250. Substances with molecular weights greater than 1 ,000 Daltons generally are not absorbed through intact skin, and substances with molecular weights greater than 1000 Daltons are generally not absorbed through the intact gastrointestinal tract . Chemicals not absorbed through the ski n or gastrointestinal tract generally are incapable of eliciting a toxic response . ] 8. Endocrine disruption . [ There is no evidence that Methacrylic acid - 2 - ethylhexyl acrylate - sodium 2 - acrylamido - 2 - methyl propane sulfonate copolymer sodium salt is an endoc rine disruptor .] C. Aggregate Exposure 1. Dietary exposure. [ N/A

– Remove based upon conforming to low risk polymer criteria identified in 40 CFR 723.250. Substances with molecular weights greater than 1 ,000 Daltons generally are not absorbed through in tact skin, and substances with molecular weights greater than 1000 Daltons are generally not absorbed through the intact gastrointestinal tract . Chemicals not absorbed through the skin or gastrointestinal tract generally are incapable of eliciting a toxic response. ] i. Food. [ N/A

– Remove based upon conforming to low risk polymer criteria identified in 40 CFR 723.250. Substances with molecular weights greater than 1 ,000 Daltons generally are not absorbed through intact skin, and substances with molecular weights greater than 1000 Daltons are generally not absorbed through the intact gastrointestinal tract . Chemicals not absorbed through the skin or gastrointestinal tract generally are incapable of eliciting a toxic response .] ii. Drinking water . [ N/A

– R emove based upon conforming to low risk polymer criteria identified in 40 CFR 723.250. Substances with molecular weights greater than 1 ,000 Daltons generally are not absorbed through intact skin, and substances with molecular weights greater than 1000 Dalt ons are generally not absorbed through the intact gastrointestinal tract . Chemicals not absorbed through the skin or gastrointestinal tract generally are incapable of eliciting a toxic response .] 2. Non - dietary exposure . [ N/A

– Remove based upon conformi ng to low risk polymer criteria identified in 40 CFR 723.250. Substances with molecular weights greater than 1 ,000 Daltons generally are not absorbed through intact skin, and substances with molecular weights greater than 1000 Daltons are generally not abs orbed through the intact gastrointestinal tract . Chemicals not absorbed through the skin or gastrointestinal tract generally are incapable of eliciting a toxic response. ]5

D. Cumulative Effects [ N/A

– Remove based upon conforming to low risk polymer crit eria identified in 40 CFR 723.250. Substances with molecular weights greater than 1 ,000 Daltons generally are not absorbed through intact skin, and substances with molecular weights greater than 1000 Daltons are generally not absorbed through the intact ga strointestinal tract . Chemicals not absorbed through the skin or gastrointestinal tract generally are incapable of eliciting a toxic response .] E. Safety Determination 1. U.S. population. [ Based upon the conformation to the criteria used to identify low risk polymers, Akzo Nobel believes there is a reasonable certainty of no harm to the US population from ag gregate exposure to residues of Acrylic acid - benzyl methacrylate 1 - propanesulfonic acid, 2 - methyl - 2 - [(1 - oxo - 2 - propenyl)amino] - , monosodium salt copol ymer acid version .] 2. Infants and children . [ Due to the expected low toxicity of Methacrylic acid - 2 - ethylhexyl acrylate - sodium 2 - acrylamido - 2 - methyl propane sulfonate copolymer sodium salt upon its conforming to all criteria used to identify a low risk p olymer, Akzo Nobel petitions that a safety factor analysis is not required to assess the risk. For the same reasons Akzo Nobel believes the additional tenfold safety factor is unnecessary .] F. International Tolerances [ Akzo Nobel is not aware of any cou ntry requiring a tolerance for Methacrylic acid - 2 - ethylhexyl acrylate - sodium 2 - acrylamido - 2 - methyl propane sulfonate copolymer sodium salt have any CODEX Maximum Residue Levels (MRLs) have been established for any food crops at this time .]