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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:

[Akzo Nobel Surface Chemistry LLC]

[1E7835]

EPA has received a pesticide petition ([1E7835]) from [Akzo Nobel Surface 

Chemistry LLC], [909 Mueller Avenue, Chattanooga, 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-ethylhexyl 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 Federal 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 

level 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 commodities. 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. [NA-Remove based on fact this information is generally 

not required when all criteria for polymer exemption per 40 CFR 723.250 are met.]
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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. Magnitude 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. [The EPA has established a set of criteria which identify 

categories of polymers that present low risk. These criteria (codified 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 properties 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 meeting this

polymer exemption criteria will 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 aggregate 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 saltmeets 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 saltcontains 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 saltdoes 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-acrylamido-2-methyl propane 

sulfonate copolymer sodium saltis 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 sodium saltis manufactured only from monomers and or 

reactants that are already included on the TSCA Chemical Substance Inventory.

• Methacrylic acid-2-ethylhexyl acrylate-sodium 2-acrylamido-2-methyl propane 

sulfonate copolymer sodium saltis not a water absorbing polymer.

• Methacrylic acid-2-ethylhexyl acrylate-sodium 2-acrylamido-2-methyl propane 

sulfonate copolymer sodium saltdoes not contain any group as a reactive 

functional group.
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• Methacrylic acid-2-ethylhexyl acrylate-sodium 2-acrylamido-2-methyl propane 

sulfonate copolymer sodium saltcontains 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 contain 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 upon Methacrylic acid-2-ethylhexyl 

acrylate-sodium 2-acrylamido-2-methyl propane sulfonate copolymer sodium 

saltconforming 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 skin or gastrointestinal tract generally are 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- 

propenyl)amino]-, monosodium salt copolymer acid version conforming 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 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 

saltconforming 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 skin or gastrointestinal tract generally are incapable of eliciting 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 

saltconforming 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 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 substances with molecular 
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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. Metabolite toxicology. [N/A – Remove based upon Methacrylic acid-2-

ethylhexyl acrylate-sodium 2-acrylamido-2-methyl propane sulfonate copolymer sodium 

saltconforming 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 skin 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 saltis an 

endocrine 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 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.]

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 – 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.]

2. Non-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 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.]
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D. Cumulative Effects

[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.]

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 aggregate exposure to residues of Acrylic acid-benzyl methacrylate1-propanesulfonic acid, 2-methyl-2-[(1-oxo-2-propenyl)amino]-, monosodium salt 

copolymer 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 

saltupon its conforming to all criteria used to identify a low risk polymer, 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 country requiring a tolerance for Methacrylic 

acid-2-ethylhexyl acrylate-sodium 2-acrylamido-2-methyl propane sulfonate copolymer 

sodium salthave any CODEX Maximum Residue Levels (MRLs) have been established 

for any food crops at this time.]