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EPA REGISTRATION DIVISION COMPANY NOTICE OF FILING FOR 

PESTICIDE PETITIONS PUBLISHED IN THE FEDERAL REGISTER 

EPA Registration Division contact: PV 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.

Stepan Company

IN-10791

EPA has received a pesticide petition (IN-10791) from Technology Sciences 

Group (1150 18th St., NW, Suite 1000, Washington, D.C. 20036) on behalf of Stepan 

Company, 22 West Frontage Road, Northfield, Illinois 60093 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

N,N-dimethyl 9-decenamide (CAS# 1356964-77-6) when used as an inert 

surfactant or solvent applied to growing crops or harvested crops under 40 CFR 180.910 

in pesticide formulations. 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 NA remove

1. Plant metabolism.

2. Analytical method. NA remove

3. Magnitude of residues. NA remove

B. Toxicological Profile Toxicity data were evaluated for the petitioned substance when 

they were available. When data were not available, toxicity of a commercial mixture of 
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surrogate compounds with structural and metabolic similarity to N,N-dimethyl 9-

decenamide were assessed. The mixture contains 50–65% N,N-dimethyloctanamide, 37–

50% of N,N-dimethyldecanamide, 0–5% N,N-dimethylhexanamide, and 0–2% N,Ndimethyldodecanamide.

. 

1. Acute toxicity. The acute oral LD50 of N,N-dimethyl 9-decenamide was 

determined to be 550 mg/kg body weight with a 95% confidence interval of 265.4 mg/kg 

to 1520 mg/kg. It was classified as EPA Toxicity Category III for acute oral toxicity. For 

acute dermal and inhalation toxicity, data on a mixture of N,N-dimethyloctanamide, N,Ndimethyldecanamide, N,N-dimethylhexanamide, and N,N-dimethyldodecanamide was 

assessed. The dermal LD50 was determined for males to be approximately 2,000 mg/kg 

and for females, between 400 and 2,000 mg/kg. It was classified as EPA Toxicity

Category II for acute dermal toxicity. The acute inhalation LC50 was determined to be > 

3.550 mg/L in rats exposed in nose/head only chambers. Clinical signs of toxicity were 

reported for the groups exposed to 0.586 mg/L and higher. The surrogate substance 

mixture of N,N-dimethyloctanamide, N,N-dimethyldecanamide, N,Ndimethylhexanamide, and N,N-dimethyldodecanamide is classified as EPA Toxicity

Category IV for acute inhalation toxicity. N,N-dimethyl 9-decenamide is considered a 

skin irritant based on the EpidermTM Skin Model and a moderate eye irritant according to 

the BCOP in vitro assay. Animal testing of the mixture classified the substance into

EPA Category I for dermal and ocular irritation. N,N-dimethyl 9-decenamide was not 

considered a skin sensitizer in the mouse Local Lymph Node assay, and the mixture of 

N,N-dimethyloctanamide, N,N-dimethyldecanamide, N,N-dimethylhexanamide, and 

N,N-dimethyldodecanamide was not sensitizing in guinea pigs according to the Buehler 

method.

2. Genotoxicty. N,N-dimethyl 9-decenamide has been studied in a variety of 

bacterial and mammalian cell genotoxicity studies as well as in vivo genotoxicity studies. 

All of the genotoxicity studies on N,N-dimethyl 9-decenamide the mixture of N,Ndimethyloctanamide, N,N-dimethyldecanamide, N,N-dimethylhexanamide, and N,Ndimethyldodecanamide have been negative. Negative genotoxicity studies of the 

petitioned substance include an Ames assay and an in vivo micronucleus assay in mice. 

Studies garnering negative results for genotoxicity of the surrogate mixture of N,Ndimethyloctanamide, N,N-dimethyldecanamide, N,N-dimethylhexanamide, and N,Ndimethyldodecanamide included a HGPRT assay in Chinese hamster lung cells and an in 

vitro chromosome aberration assay in Chinese hamster ovary cells. All of these results 

indicate that N,N-dimethyl 9-decenamide is not a genotoxic agent. 

3. Reproductive and developmental toxicity. Two developmental toxicity studies 

were carried out on the mixture of N,N-dimethyloctanamide, N,N-dimethyldecanamide, 

N,N-dimethylhexanamide, and N,N-dimethyldodecanamide : one in the rat and one in the 

rabbit. Pregnant female rats received gavage doses of 0, 50, 150, or 450 mg/kg bw/day of 

the mixture on gestation days 6-15. On gestation day 21, dams were sacrificed and 

fetuses were removed by Caesarean section and examined. Dams in the high dose group 

exhibited clinical signs of toxicity, a significant decrease in food consumption, and 
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significantly lower body weight gain on days 18 and 19 of gestation. The corrected 

weight gain in controls throughout gestation was 7.8%, and in the high dose group the 

corrected weight gain was 4.9%. There was also a significant decrease in fetal body

weight in the 450 mg/kg group and an increased incidence of fetuses with common 

skeletal abnormalities and delayed developmental growth. There were no developmental 

abnormalities observed in the absence of maternal toxicity. The maternal NOAEL and 

LOAEL from this study were 150 and 450 mg/kg/day, respectively. The developmental 

NOAEL and LOAEL were the same as the maternal values. .

In an OECD TG 414 study, rabbits received doses of the mixture of N,Ndimethyloctanamide, N,N-dimethyldecanamide, N,N-dimethylhexanamide, and N,Ndimethyldodecanamide on post-coitum days 6-18. Sacrifice took place on day 28 postcoitum. The food consumption of high dose animals was reduced during the dosing 

period (post coitum days 6-19); this difference was statistically significant during postcoitum days 11-15. There was no significant difference from controls on any

reproductive or fetal endpoint for treated fetuses. Study authors concluded that the 

NOAEL for maternal systemic effects was 300 mg/kg bw based on the decrease in food 

consumption during dosing. The NOAEL for reproductive and 

embryotoxicity/teratogenicity was the highest dose of 1000 mg/kg bw.

4. Subchronic toxicity. In a 90-day oral study (OECD TG 406), the surrogate 

substance was administered in the diet of Wistar rats at 0, 400, 2000, or 10,000 ppm for 

13 weeks, and at 0 or 10,000 ppm for 13 weeks followed by a 28-day recovery period.

Body weight gain was impaired in females and males at the highest dose, but this did not 

last into the recovery period. Increases in liver weights of high dose females were not 

accompanied by changes in clinical chemistry, gross pathological or histopathology that 

indicated effects on the function of the liver. The relative spleen weights among females 

were significantly higher even after the recovery period. There were no accompanying 

changes in spleen morphology. High dose males showed an increased incidence of 

basophilic regenerative tubules in the renal cortex as well as a slight increase in the 

amount of protein excreted in the urine. These effects were not significant after the 

recovery period. The NOAEL in this study was 2000 ppm in males based on reversible 

kidney effects, and 10,000 ppm in females, equivalent to approximately 136.8 mg/kg 

bw/day in males and 894.6 mg/kg bw/day in females.

5. Chronic toxicity. The data available suggest that the proposed inert ingredient is 

not carcinogenic. These include a lack of positive results in genotoxicity testing in both 

N,N-dimethyl 9-decenamide itself and the surrogate chemical mixture. 

6. Animal metabolism. N,N-dimethyl 9-decenamide is expected to be metabolized 

via carboxyamide hydrolysis by amidase enzymes, resulting in a carboxylic acid with a 

fatty acid structure and terminal double bond (9-decenoic acid). The double bond of 9-

decenoic acid is located at an odd number carbon, and will therefore be converted from 

cis- to trans- by enoyl-CoA. Fatty acids are metabolized by beta oxidation in the 

mitochondria to produce acetyl-CoA, which can enter the citric acid cycle to produce 
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energy.

7. Metabolite toxicology. N/A Remove

8. Endocrine disruption. Toxicity related to endocrine disruption was not 

observed in the currently available N,N-dimethyl 9-decenamide database, or that of the

surrogate chemical mixure. As the science develops and resources allow, screening of 

additional compounds may be added to the Endocrine Disruptor Screening Program

(EDSP), at which point N,N-dimethyl 9-decenamide may be subjected to additional 

screening and/or testing to better characterize effects related to endocrine disruption.

C. Aggregate Exposure

1. Dietary exposure. The estimated dietary exposure to N,N-dimethyl 9-

decenamide was determined using methods to estimate chronic dietary exposure for a 

generic inert ingredient. This assessment considers drinking water and crop-specific 

residues from pre-harvest applications of agricultural insecticides, herbicides and 

fungicides, assuming the highest established tolerance level residue for each commodity. 

The assessment assumes that the inert ingredient is used on all crops, and that 100% of all 

crops are treated with the inert. The inert ingredient is assumed to be present in all 

commodities treated with 57 of the most significant active ingredients at the maximum 

tolerance level as identified by the U.S. EPA for the default assessment. Chronic dietary

exposure estimates were derived for the general US population and sub-groups of the 

population using the Dietary Exposure Evaluation Model, DEEMTM. The estimated 

chronic exposure for the total US population is 0.189 mg/kg/day, 12.6% of the chronic 

Population Adjusted Dose (cPAD). Children age 1 to 2 years old have the highest 

estimated exposure at 0.706 mg/kg/day, or 47.1% of the cPAD.

i. Food. Dietary exposures of concern are not anticipated for N,N-dimethyl 9-

decenamide due to its ready biodegradation in the environment and low general toxicity.

ii. Drinking water. N,N-dimethyl 9-decenamide exposure via drinking water from 

use as an inert ingredient is not expected to be significant. Based on the physical 

chemical characteristics, the compound is expected to partition primarily to the soil, and 

the comparatively small amounts that enter the water will readily biodegrade. Exposure 

via the drinking water was estimated in the DEEM dietary exposure assessment assuming 

a concentration of 100 ppb

2. Non-dietary exposure. Residential exposures of concern are not anticipated for 

N,N-dimethyl 9-decenamide due to its ready biodegradation in the environment and low 

general toxicity.

D. Cumulative Effects Section 408(b)(2)(D) (9v) of the FFDCA requires that, when 

considering whether to establish, modify, or revoke a tolerance, the Agency consider 

“available information” concerning the cumulative effects of a particular pesticide’s 

residues and “other substances that have a common mechanism of toxicity.” EPA has not 
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made a common mechanism of toxicity finding as to N,N-dimethyl 9-decenamide and 

other compounds. N,N-dimethyl 9-decenamide does not appear to produce toxic 

metabolites in common with other substances. 

E. Safety Determination

1. U.S. population. There is a reasonable certainty that no harm to humans will 

result from the use of N,N-dimethyl 9-decenamide as an inert ingredient in pesticide 

products. A NOAEL of 150 mg/kg/day in a developmental toxicity study of rats exposed 

to the mixture of surrogate chemicals was used to derive the chronic population adjusted 

dose (cPAD). Intraspecies and interspecies uncertainty factors were combined for a total 

uncertainty factor of 100. The resulting cPAD is 1.5 mg/kg/day. For the total US 

population, the estimated chronic dietary exposure from food and drinking water for N,Ndimethyl 9-decenamide, calculated as 50% of all agricultural formulations, is 12.6 % of 

cPAD, well below any level of potential concern. 

2. Infants and children. There is a reasonable certainty that no harm to infants and 

children will result from the use of N,N-dimethyl 9-decenamide as an inert ingredient in 

pesticide products. Mammalian teratology tests in rats and rabbits demonstrate that N,Ndimethyl 9-decenamide does not cause adverse effects on fetal development in the 

absence of maternal toxicity. Thus at this time there is no concern for potential 

sensitivity to infants and children, and therefore the default 10X FQPA safety factor may

be reduced to 1X. 

F. International Tolerances

N/A Remove