EPA REGISTRATION DIVISION COMPANY NOTICE OF FILING FOR PESTICIDE PETITIONS 

PUBLISHED IN THE FEDERAL REGISTER 

EPA Registration Division contact: [Dr. P.V. Shah, 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

[Joint Inerts Task Force, Cluster Support Team 8 (JITF CST8)]

[2E8087]

EPA has received a pesticide petition [2E8087]

from [Joint Inerts Task Force, Cluster Support Team 8, EPA Company Number 84942], [c/o 

Huntsman Corp., 8600 Gosling Rd., The Woodlands, TX 77381] 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 amend existing exemptions from the requirement of a tolerance [ by adding Chemical 

Abstracts Service Registry Numbers (CASRNs) for pre-harvest use on agricultural crops under 

40 CFR §180.920 and when applied to animals under 40 CFR §180.930 for the following two 

chemistry descriptors that are used as surfactants: 1: dimethylaminopropylamine, 
2

isopropylamine, ethanolamine, and triethanolamine salts of alkyl (C8-C24) benzenesulfonic acid 

(without limits):

CASRN

Dimethylaminopropylamine, isopropylamine, ethanolamine, and 

triethanolamine salts of alkyl (C8-C24) benzenesulfonic acid

12068-12-1

Benzenesulfonic acid, dodecyl-, compd. with N,N-dimethyl-1,3-

propanediamine (1:1)

121617-08-1

Benzenesulfonic acid, 4-C10-13-sec-alkyl derivs., compds. with 

triethanolamine 

193562-36-6 Benzenesulfonic acid, C16-24-alkyl derivs., compds. with ethanolamine (1:1)

26836-07-7 Benzenesulfonic acid, dodecyl-, compd. with 2-aminoethanol (1:1)

3088-30-0

p-dodecylbenzenesulphonic acid, compound with 2,2',2''-nitrilotriethanol 

(1:1)

58089-99-9 Benzenesulfonic acid, 4-dodecyl-, compd. with 2-aminoethanol (1:1)

61886-59-7 Benzenesulfonic acid, tridecyl-, compd. with 2,2',2''-nitrilotris[ethanol] (1:1)

61931-76-8 Benzenesulfonic acid, undecyl-, compd. with 2,2',2''-nitrilotris[ethanol] (1:1)

67924-05-4

Benzenesulfonic acid, 4-dodecyl-, compd. with 2,2',2''-nitrilotris[ethanol] 

homopolymer

68110-32-7 Benzenesulfonic acid, 3-dodecyl-, compd. with 2-aminoethanol (1:1)

68259-35-8 Benzenesulfonic acid, undecyl-, compd. with 2-propanamine (1:1)

68442-72-8 Benzenesulfonic acid, dodecyl-, reaction products with ethanolamine

68567-69-1

Benzenesulfonic acid, 4-sec-dodecyl-, compd. with 2,2',2''-

nitrilotris[ethanol] (1:1)

68815-30-5 Benzenesulfonic acid, decyl-, branched, compds. with triethanolamine

68815-35-0 Benzenesulfonic acid, tetradecyl-, branched, compds. with triethanolamine

68953-98-0 Benzenesulfonic acid, dodecyl-, branched, compds. with ethanolamine

70528-84-6 Benzenesulfonic acid, dodecyl-, branched, compds. with triethanolamine 

72391-21-0

Benzenesulfonic acid, 4-[2,4,4-trimethyl-1-(2-methylpropyl)pentyl]-, compd. 
3

CASRN

Dimethylaminopropylamine, isopropylamine, ethanolamine, and 

triethanolamine salts of alkyl (C8-C24) benzenesulfonic acid

with 2-aminoethanol (1:1)

84961-74-0

Benzenesulfonic acid, 4-C10-13-sec-alkyl derivs., compds. with 2-

propanamine

85480-55-3

Benzenesulfonic acid, mono-C10-13-alkyl derivs., compds. with 

ethanolamine

85480-56-4

Benzenesulfonic acid, mono-C10-13-alkyl derivs., compds. with 

triethanolamine

85995-82-0 Benzenesulfonic acid, 4-C10-14-alkyl derivs., compds. with ethanolamine

90194-54-0

Benzenesulfonic acid, mono-C10-13-branched alkyl derivs., compds. with 2-

propanamine

90194-55-1

Benzenesulfonic acid, mono-C10-13-branched alkyl derivs., compds. with 

triethanolamine 

90218-09-0

Benzenesulfonic acid, mono-C8-24-branched and linear alkyl derivs., 

compds. with ethanolamine

90218-11-4

Benzenesulfonic acid, mono-C16-24-branched and linear alkyl derivs., 

compds. with 2-propanamine 

96687-54-6

tetrapropylenebenzenesulphonic acid, compound with 2,2',2''-

nitrilotriethanol (1:1)

99924-49-9

Benzenesulfonic acid, mono-C10-14-alkyl derivs., compds. with 

ethanolamine

and 2: diethanolamine salts of alkyl (C8-C24) benzenesulfonic acid (Not to exceed 7% of 

pesticide formulation):

CASRN Diethanolamine salts of alkyl (C8-C24) benzenesulfonic acid

67815-95-6 Benzenesulfonic acid, 4-dodecyl-, compd. with 2,2'-iminobis[ethanol] (1:1)

67889-94-5 Benzenesulfonic acid, isoundecyl-, compd. with 2,2'-iminobis[ethanol] (1:1)

67889-95-6 Benzenesulfonic acid, isodecyl-, compd. with 2,2'-iminobis[ethanol] (1:1)
4

CASRN Diethanolamine salts of alkyl (C8-C24) benzenesulfonic acid

68259-34-7 Benzenesulfonic acid, undecyl-, compd. with 2,2'-iminobis[ethanol] (1:1)

68478-47-7 Benzenesulfonic acid, dodecyl-, reaction products with diethanolamine

68567-68-0

Benzenesulfonic acid, 4-sec-dodecyl-, compd. with 2,2'-iminobis[ethanol] 

(1:1)

68815-34-9 Benzenesulfonic acid, tetradecyl-, branched, compds. with diethanolamine

68815-37-2 Benzenesulfonic acid, tridecyl-, branched, compds. with diethanolamine

68891-02-1

Benzenesulfonic acid, mono-C10-16-alkyl derivs., compds. with 

diethanolamine

84989-15-1

Benzenesulfonic acid, 4-C10-13-sec-alkyl derivs., compds. with 

diethanolamine 

85338-09-6 Benzenesulfonic acid, 4-C10-14-alkyl derivs., compds. with diethanolamine 

90194-39-1

Benzenesulfonic acid, mono-C10-13-alkyl derivs., compds. with 

diethanolamine 

90194-40-4

Benzenesulfonic acid, mono-C10-14-alkyl derivs., compds. with 

diethanolamine

90218-08-9

Benzenesulfonic acid, mono-C8-24-branched and linear alkyl derivs., 

compds. with diethanolamine

in or on all the raw agricultural commodities. Prior to the submission of this petition to add 

missing CASRNs, Pesticide Petition 8E7472 (Document ID EPA-HQ-OPP-2008-0889) was 

submitted to the Agency and these CASRNs were missing from the petition. JITF CST8 is 

relying on the information submitted in 8E7472 to support this petition which includes the 

exact same chemistry of Alkylbenzene Sulfonates. JITF CST8 does not expect the addition of 

these CASRNs to result in additional exposure or risk. 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
5

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 is not 

required for the establishment of a tolerance exemption.]

B. Toxicological Profile

1. Acute toxicity. [Published data indicate that the parent acid of Alkylbenzene 

Sulfonates is not highly acutely toxic (EPA Categories III-IV), is irritating to the eye and skin, 

and is a weak-moderate skin sensitizer and that the parent amine counter ions are acute 

toxicity EPA category II-IV. Dermal toxicity EPA Category II.]

2. Genotoxicty. [Both in vitro and in vivo genotoxicity data show that Alkylbenzene 

Sulfonates are not toxic to the gene or the chromosome. The Amine counter ions are also not 

mutagenic.]

3. Reproductive and developmental toxicity. [One representative compound for the 

group of chemicals requested in 8E7472 (and 2E8087) is CASRN 26264-05-1, the 

isopropylamine salt of dodecylbenzenesulfonic acid. OECD 422 testing for CASRN 26264-05-1

indicates no reproductive effects and no evidence of malformations in the developing 

offspring. The NOEL for reproduction and developmental toxicity was 320 mg/kg/day, the 

highest dose tested.]

4. Subchronic toxicity. [No compound specific subchronic toxicology data are available 

for these Alkylbenzene Sulfonates. Additionally, a search of the public literature did not 

reveal any available data. However following repeated oral administration in an OECD 422 

Combined Repeated Dose Toxicity Study with a Reproduction/Developmental Toxicity 

Screening Test (i.e., at least 42 days in male rats and approximately 42-44 days in female rats) 
6

for CASRN 26264-05-1, a systemic NOAEL of 80 mg/kg/day was identified, and a NOEL for 

reproduction and developmental toxicity was 320 mg/kg/day, the highest dose tested.]

5. Chronic toxicity [Data reviewed by EPA for Alkylbenzene Sulfonates indicate that 

they are not likely to be carcinogenic.]

6. Animal metabolism. [The amine salts of alkyl (C8-C24) benzenesulfonic acid rapidly 

dissociate in vivo aqueous solutions to form an alkyl (C8-C24) benzenesulfonic acid and a 

counter ion amine (dimethylaminopropylamine, isopropylamine, mono- , di- , and 

triethanolamine). The two entities would be absorbed and metabolized independently. The 

alkyl (C8-C24) benzenesulfonic acid should be readily conjugated and rapidly excreted with very 

little alkyl aromatic chain degradation (EPA, 2006). The amine counter ions should undergo 

either: primary, secondary, or tertiary amine metabolism, followed by excretion (Bury, 1998).]

7. Metabolite toxicology. [No metabolites of toxicological concern are expected based 

on the proposed animal metabolic pathway.]

8. Endocrine disruption. [The [amine salts of alkyl (C8-C24) benzenesulfonic acid 

(dimethylaminopropylamine, isopropylamine, mono- , di- , and triethanolamine) , additionally 

alkyl (C8-C24) benzene sulfonic acids and the amines supported by CST8, do not belong to a 

class of chemicals known or suspected of having adverse effects on the estrogen receptor or 

endocrine system. An amine salt, CASRN 26264-05-1: Benzenesulfonic acid, dodecyl-, 

compound with 2-propanamine (1:1) of alkyl (C8-C24) benzenesulfonic acid and amines have 

been evaluated in acute, subchronic, developmental and reproductive studies capable of 

detecting effects on endocrine mediated events.]

C. Aggregate Exposure

1. Dietary exposure. [An assessment based on the EPA Inert’s Branch screening-level 

dietary exposure model I-DEEM was provided in the previously submitted Petition PP 8E7472 

(Document ID EPA-HQ-OPP-2008-0889). I-DEEM uses a screening level dietary assessment of 

57 of the most “significant” active ingredients as surrogates for inerts within the Dietary 

Exposure Evaluation Model software with the Food Commodity Intake Database (DEEMFCIDTM, Version 2.14). Exposure from food, animal commodities and drinking water are 
7

covered. Children 1-2 years old are found to be the most highly exposed subpopulation, with 

an estimated exposure of 0.425 mg/kg/day for drinking water and food. Formulated products 

are assumed to consist of 50% inert ingredients, and I-DEEM exposures can be scaled based on 

proposed limits in specific formulations. 

Based on the low acute toxicity, no acute reference dose is established. The JITF recommends 

that the FQPA safety factor can be reduced from 10X to 1X (see below). Based on a NOAEL of 

80 mg/kg bw/day from the OECD 422 study with UF=100, a cRfD of 0.8 mg/kg/day = cPAD 

(chronic population adjusted dose) is proposed. The CST8 supported amine salts of alkyl (C8-

C24) benzenesulfonic acids (dimethylaminopropylamine, isopropylamine, mono- , di- , and 

triethanolamine) are used primarily as surfactants in a variety of pesticide product 

formulations typically used in agriculture, but they are not typically formulated in pesticide 

products intended for use near residences. In agricultural products, these compounds are 

included in formulated products at levels significantly lower than the 50% assumed by the IDEEM screening level default model. Estimated dietary (food plus drinking water) exposures 

account for 15.3% of the proposed chronic reference dose for the general population and 

53.1% for the most exposed population, children aged 1-2 years.

Thus, since less than the full chronic reference dose is used by dietary exposure, there is 

additional room that is deemed adequate to cover any other aggregate exposures from nondietary pre-harvest and animal uses. The JITF CST8 thus asserts that the [amine salts of alkyl 

(C8-C24) benzenesulfonic acid (dimethylaminopropylamine, isopropylamine, mono- , di- , and 

triethanolamine) s, as described in FR Notice Vol. 71 No. 153 p. 45422 § 180.920 [Amended], k 

and p. 45422-3 § 180.930 [Amended], f are supported by the published alkyl (C8-C24) 

benzenesulfonic acid and amines (dimethylaminopropylamine, isopropylamine, mono- , di- , 

and triethanolamine) toxicology, other data and newly conducted CASRN 26264-05-1 OECD 

422 study data and risk assessment.
8

Chronic Dietary Safety Assessment, % cPAD

Study

Chronic 

Systemic 

NOAEL 1

mg/kg 

bw/day

cPAD2

mg/kg 

bw/day

Percent 

cPAD 

Children 1-

2 years of 

age

Percent cPAD 

U.S. Gen 

Population

OECD 422 Combined Repeated 

Dose Toxicity Study with a 

Reproduction/Developmental 

Toxicity Screening Test in Rats -

CASRN 26264-05-1.

80 0.8 53% 15%

Note:

1 NOAEL – No observed adverse effect level

2

cPAD – Chronic population adjusted dose, defined as: chronic NOAEL / (safety factor  FQPA 

factor)]

i. Food. [The dietary (food plus drinking water) exposures for Alkylbenzene Sulfonates

are expressed as a percentage of the proposed cPAD. Chronic Safety Assessment, % cPAD for 

the general U.S. population and children 1-2 years old, the subpopulation with the highest 

potential exposures. Based on I-DEEM screening level calculations, the chronic dietary 

exposures are estimated to be 15% of the proposed cPAD for the general U.S. population and 

53% of the cPAD for children 1-2 years old. These data demonstrate that the I-DEEM 

screening-level chronic dietary (food and drinking water) exposures are below the cPAD and 

are therefore below EPA’s established level of concern for all U.S. subpopulations.]

ii. Drinking water. [Drinking water is included in the I-DEEM exposure assessment.]

2. Non-dietary exposure. [Amine salts of alkyl (C8-C24) benzenesulfonic acid 

(dimethylaminopropylamine, isopropylamine, mono- , di- , and triethanolamine) are used 

primarily as surfactants in pesticide formulations in 40 CFR §180.920 pre- harvest applications 

to raw agricultural commodities and 40 CFR §180.930 animal applications.] 
9

D. Cumulative Effects

[For the compounds included in CST8, EPA has not made a common mechanism 

finding. It is therefore appropriate to consider only the potential risks of the compounds 

included in CST8 in the exposure assessment.] 

E. Safety Determination

1. U.S. population. [The JITF CST8 conducted a risk assessment using current EPA IDEEM methodology. The results of the risk assessment were acceptable exposures for the use 

of CST8 compounds. Based on the chronic dietary exposure assessment, the cPADs calculated 

for the U.S. population were 15% (chronic).]

2. Infants and children. [The FFDCA Section 408 requires an additional tenfold margin 

of safety for the protection of infants and children in case of threshold effects to account for 

prenatal and postnatal toxicity, and an inadequate toxicity database. Where an adequate and 

reliable database is available and there is a lack of evidence for increased susceptibility, the 

FQPA safety factor may be reduced or removed. 

An evaluation of susceptibility and uncertainty issues associated with the use of amine salts of 

alkyl (C8-C24) benzenesulfonic acid (dimethylaminopropylamine, isopropylamine, mono- , di- , 

and triethanolamine) in pesticide formulations has been performed, and the JITF CST8 

recommends that the FQPA safety factor be reduced to 1X for the following reasons: 

 The availability of a substantial and scientifically sound mammalian toxicology 

database that includes acute, subchronic, mutagenicity, reproduction, and 

developmental toxicity data for the amine counter ions comprising CST8 supported 

surfactants.

 OECD 422 testing for CASRN 26264-05-1 indicates no reproductive effects and no 

evidence of malformations in the developing offspring 

 There was no evidence of effects on the nervous system in the acute, subacute or 

reproduction studies for the amine counter ions comprising CST8 supported 

compounds

 There is no evidence of endocrine disruption for CASRN 26264-05-1 and for the amine 

counter ions comprising CST8 supported compounds.]
10

F. International Tolerances

[There are no known international tolerances for amine salts of alkyl (C8-C24) 

benzenesulfonic acid (dimethylaminopropylamine, isopropylamine, mono- , di-, and 

triethanolamine).]