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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 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 ] [ 1E7834 ] EPA has received a pesticide petition ( [ 1E7834 ] ) 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 [ 2 - Propenoic acid, 2 - methy l - , 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 re quirements 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 - oxo 2 - 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 commodit ies . EPA has determined that the petition contains data or information regarding the elements set forth in sec tion 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 before EPA rules on the petition.2

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 wh en 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 info rmation 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 identify 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 properties generally limit a polymer’s ability to cause a dverse 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 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 aggregate exposure to pesticide chemical residues un der 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), peroxydi sulfuric 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 contain s 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 a lready 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 contain s a minimum number average molecular weight of > 1000 Daltons and a maximum number ave rage molecular weight of 10,000 Daltons.3

• The Polymer 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 up on 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 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 throug h 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 - m ethyl - , 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 conform ing to all criteria for low risk polymers as co dified 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 gastrointes tinal 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 - propen oic 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 conform ing to all criteria for low risk polymers as codified in 40 CFR 723.250. Substances with molecul ar 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 s kin 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 - oxo 2 - propen - 1 - yl )amino] - 1 - propanesulfonate (1:1), peroxydisulfuric acid ([(HO)S(O)2]202) sodium salt (1:2) - initiated 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 skin or gastrointestinal tract generally are incapab le 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 absor bed through the intact4

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 - , pheny lmethyl 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 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 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 - oxo 2 - 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 trac t

. 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 wit h 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 thro ugh 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 great er 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 gastroint estinal tract generally are incapable of eliciting a toxic response. ]5

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 gener ally 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 f

rom ag gregate exposure to residues of 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) - initi ated . 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 - 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 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 t enfold 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 - y l)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 .]