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EPA REGISTRATION DIVISION COMPANY NOTICE OF FILING FOR 

PESTICIDE PETITIONS PUBLISHED IN THE FEDERAL REGISTER 

EPA Registration Division contact: [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.

TEMPLATE:

[Akzo Nobel Surface Chemistry LLC]

[1E7834]

EPA has received a pesticide petition ([1E7834]) 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

[2-Propenoic acid, 2-methyl-, phenylmethyl ester, polymer with 2-propenoic 

acid and sodium 2-methyl-2-[(1-oxo-2-propen-1-yl)amino]-1-propanesulfonate (1:1), 

peroxydisulfuric acid ([HO)S(O)2]202) sodium salt (1:2)-initiated] (CAS RN 

1246766-57-3) 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 Cosmetic 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 2-Propenoic acid, 2-methyl-, 

phenylmethyl ester, polymer with 2-propenoic acid and sodium 2-methyl-2-[(1-oxo2-propen-1-yl)amino]-1-propanesulfonate (1:1), peroxydisulfuric acid 

([HO)S(O)2]202) sodium salt (1:2)-initiated] 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.
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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. 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. 2-Propenoic acid, 2-methyl-, phenylmethyl ester, 

polymer with 2-propenoic acid and sodium 2-methyl-2-[(1-oxo-2-propen-1-

yl)amino]-1-propanesulfonate (1:1), peroxydisulfuric acid ([HO)S(O)2]202) sodium 

salt (1:2)-initiated (also referred to as “The Polymer”) meets the specific criteria per 

CFR 40 723.250 as described below.

• The Polymer is not a cationic polymer, nor is it reasonably anticipated to become 

a cationic polymer in a natural aquatic environment.

• The Polymer contains as an integral part of its composition the atomic elements 

carbon and hydrogen. 

• The Polymer does not contain as an integral part of its composition any elements 

other than those listed in 40 CFR 723.250.

• The Polymer is not designed, nor is reasonably anticipated to substantially 

degrade, decompose, or depolymerize.

• The Polymer is manufactured only from monomers and or reactants that are 

already included on the TSCA Chemical Substance Inventory.

• The Polymer Acrylic is not a water absorbing polymer.

• The Polymer Acrylic does not contain any group as a reactive functional group.

• The Polymer contains a minimum number average molecular weight of > 1000 

Daltons and a maximum number average molecular weight of 10,000 Daltons. 
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• The Polymer 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 2-Propenoic acid, 2-methyl-, 

phenylmethyl ester, polymer with 2-propenoic acid and sodium 2-methyl-2-[(1-oxo2-propen-1-yl)amino]-1-propanesulfonate (1:1), peroxydisulfuric acid 

([HO)S(O)2]202) sodium salt (1:2)-initiated 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.]

3. Reproductive and developmental toxicity. [N/A – Remove based upon upon 2-

Propenoic acid, 2-methyl-, phenylmethyl ester, polymer with 2-propenoic acid and 

sodium 2-methyl-2-[(1-oxo-2-propen-1-yl)amino]-1-propanesulfonate (1:1), 

peroxydisulfuric acid ([HO)S(O)2]202) sodium salt (1:2)-initiated 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 2-Propenoic acid, 2-methyl-, 

phenylmethyl ester, polymer with 2-propenoic acid and sodium 2-methyl-2-[(1-oxo2-propen-1-yl)amino]-1-propanesulfonate (1:1), peroxydisulfuric acid 

([HO)S(O)2]202) sodium salt (1:2)-initiated 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.]

5. Chronic toxicity. [N/A – Remove based upon 2-Propenoic acid, 2-methyl-, 

phenylmethyl ester, polymer with 2-propenoic acid and sodium 2-methyl-2-[(1-oxo2-propen-1-yl)amino]-1-propanesulfonate (1:1), peroxydisulfuric acid 

([(HO)S(O)2]202) sodium salt (1:2)-initiated 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.]

6. Animal metabolism. [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 
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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 2-Propenoic acid, 2-

methyl-, phenylmethyl ester, polymer with 2-propenoic acid and sodium 2-methyl-2-

[(1-oxo-2-propen-1-yl)amino]-1-propanesulfonate (1:1), peroxydisulfuric acid 

([(HO)S(O)2]202) sodium salt (1:2)-initiated 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.]

8. Endocrine disruption. [There is no evidence that 2-Propenoic acid, 2-methyl-, 

phenylmethyl ester, polymer with 2-propenoic acid and sodium 2-methyl-2-[(1-oxo2-propen-1-yl)amino]-1-propanesulfonate (1:1), peroxydisulfuric acid 

([(HO)S(O)2]202) sodium salt (1:2)-initiated is 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 2-Propenoic acid, 2-methyl-, 

phenylmethyl ester, polymer with 2-propenoic acid and sodium 2-methyl-2-[(1-oxo2-propen-1-yl)amino]-1-propanesulfonate (1:1), peroxydisulfuric acid 

([(HO)S(O)2]202) sodium salt (1:2)-initiated.

2. Infants and children. [Due to the expected low toxicity of 2-Propenoic acid, 

2-methyl-, phenylmethyl ester, polymer with 2-propenoic acid and sodium 2-methyl2-[(1-oxo-2-propen-1-yl)amino]-1-propanesulfonate (1:1), peroxydisulfuric acid 

([(HO)S(O)2]202) sodium salt (1:2)-initiated upon 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 2-Propenoic 

acid, 2-methyl-, phenylmethyl ester, polymer with 2-propenoic acid and sodium 2-

methyl-2-[(1-oxo-2-propen-1-yl)amino]-1-propanesulfonate (1:1), peroxydisulfuric 

acid ([(HO)S(O)2]202) sodium salt (1:2)-initiated have any CODEX Maximum 

Residue Levels (MRLs) have been established for any food crops at this time.]