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EPA REGISTRATION DIVISION COMPANY NOTICE OF FILING FOR PESTICIDE PETITIONS PUBLISHED IN THE FEDERAL REGISTER EPA Registration Division contact: William Cutchin , 703 - 30 5 - 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 Croda Inc. IN - 10690 EPA has received a pesticide petition IN - 10690 from Spring Trading Company, LLC ., 10805 W. Timberwagon Circle, Spring, Texas 77380 on behalf of Croda Inc. , 315 Cherry Lane, New Castle DE, 19720 , 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 existin g exemptions from the requirement of a tolerance by addin g Alkyl Alcohol Alkoxylate Phosphate and Sulfate Derivatives (AAAPD and AAASD respectively), Chemical Abstracts Service Registry Numbers ( CASRNs ) for p ost - harvest use on agricultural crops under 40 CFR §180.9 1 0 and when applied to animals under 40 C FR §180.930 for the following used as surfactants not to exceed 30% of pesticide formulation including: AAAPD Surfactants: 40 CFR §180.910 and §180.930: α - Alkyl (minimum C 6 linear or branched, saturated and or unsaturated) - ω - hydroxypolyoxyethylene polymer with or without polyoxypropylene, mixture of di - and monohydrogen phosphate esters and the corresponding ammonium, calcium, magnesium, monoethanolamine, potassium, sodium, and zinc salts of the phosphate esters; minimum oxyethylene content averages 2 moles; minimum oxypropylene content is 0 moles; used as surfactants not to exceed 30% of pesticide formulation. CASRN AAAPD Chemical Name 37281 - 86 - 0 Poly[oxy(ethyl - 1,2 - ethanediyl)], a - phosphono - w - (decyloxy ) - , disodium salt 51325 - 10 - 1 Poly(oxy - 1,2 - ethanediyl), a - phosphono - w - [(2 - ethylhexyl)oxy] - 52019 - 38 - 2 Poly(oxy - 1,2 - ethanediyl), a - octyl - w - hydroxy - , phosphate 58206 - 38 - 5 Oxirane, 2 - methyl - , polymer with oxirane, monododecyl ether, phosphate,

potassium sal t 58857 - 49 - 1 Poly(oxy - 1,2 - ethanediyl), a - (9Z) - 9 - octadecen - 1 - yl - w - hydroxy - , phosphate,

ammonium salt 62482 - 61 - 5 Poly(oxy - 1,2 - ethanediyl), a - dodecyl - w - hydroxy - , compd. with sodium phosphate 63887 - 54 - 7 Poly(oxy - 1,2 - ethanediyl), a - phosphono - w - (decyloxy) - , potassium salt (1:2) 66020 - 37 - 9 Poly(oxy - 1,2 - ethanediyl), a - octadecyl - w - hydroxy - , phosphate, potassium salt2

CASRN AAAPD Chemical Name 66281 - 20 - 7 Ethanol, 2 - amino - , compd. with a - tridecyl - w - hydroxypoly(oxy - 1,2 - ethanediyl)

phosphate 68332 - 75 - 2 Poly(oxy - 1,2 - ethanediyl), a - dodecyl - w - hydroxy - , 2 - ethylhexyl phosphate,

sodium salt 68400 - 75 - 9 Poly(oxy - 1,2 - ethanediyl), a - phosphono - w - (decyloxy) - , sodium salt (1:?) 70844 - 96 - 1 Poly(oxy - 1,2 - ethanediyl), a - phosphono - w - (decyloxy) - , monosodium salt 78041 - 18 - 6 Poly(oxy - 1,2 - ethanediyl), a - dodecyl - w - hydroxy - , phosphate, magnesium salt 82465 - 25 - 6 Poly(oxy - 1,2 - ethanediyl), a - phosphono - w - (decyloxy) - , disodium salt 84843 - 37 - 8 Poly(oxy - 1,2 - ethanediyl), a - octyl - w - hydroxy - ,phosphate, sodium salt 95014 - 34 - 9 Oxirane, methyl - , polymer with a - trid ecyl - w - hydroxypoly(oxy - 1,2 - ethanediyl)

phosphate 99924 - 51 - 3 Ethanol, 2 - amino - , compds. with polyethylene glycol mono - C10 - 12 - alkyl ethers

phosphates 120913 - 45 - 3 Ethanol, 2 - amino - , compd. with a - octyl - w - hydroxypoly(oxy - 1,2 - ethanediyl)

phosphate 123339 - 53 - 7 Poly(oxy - 1,2 - ethanediyl), α - [bis(1 - phenylethyl)phenyl] - ω - hydroxy - , phosphate 129208 - 04 - 4 Poly(oxy - 1,2 - ethanediyl), a - phosphono - w - (decyloxy) - , potassium salt 144336 - 75 - 4 Poly(oxy - 1,2 - ethanediyl), a - phosphono - w - [(2 - ethylhexyl)oxy] - , potassium s alt 146815 - 57 - 8 Poly(oxy - 1,2 - ethanediyl), a - phosphono - w - [(2 - ethylhexyl)oxy] - , sodium salt 151688 - 56 - 1 Oxirane, 2 - methyl - , polymer with oxirane, monohexadecyl ether, phosphate,

sodium salt 159704 - 69 - 5 Poly(oxy - 1,2 - ethanediyl), a - decyl - w - hydroxy - , phosphate, calcium salt 172027 - 16 - 6 Poly(oxy - 1,2 - ethanediyl), a - phosphono - w - (decyloxy) - , magnesium salt (1:1) 172274 - 69 - 0 Poly(oxy - 1,2 - ethanediyl), a - isooctyl - w - hydroxy - , phosphate, potassium salt 176707 - 42 - 9 Poly(oxy - 1,2 - ethanediyl), a - octyl - w - hydroxy - , phosphate, ion (neg.) 181963 - 82 - 6 Poly(oxy - 1,2 - ethanediyl), a - decyl - w - hydroxy - , phosphate, ammonium salt 188741 - 55 - 1 Poly(oxy - 1,2 - ethanediyl), a - sec - tridecyl - w - hydroxy - , phosphate 191940 - 53 - 1 Oxirane, methyl - , polymer with oxirane, phosphate (2:1), mo nooctadecyl ether 210993 - 53 - 6 Ethanol, 2 - amino - , compd. with a - (2 - ethylhexyl) - w - hydroxypoly(oxy - 1,2 -

ethanediyl) phosphate 290348 - 69 - 5 Poly(oxy - 1,2 - ethanediyl), a - phosphono - w - (decyloxy) - , calcium salt (1:1) 290348 - 70 - 8 Poly(oxy - 1,2 - ethanediyl), a - phosphono - w - (decyloxy) - , zinc salt (1:1) 340681 - 28 - 9 Poly(oxy - 1,2 - ethanediyl), a - phosphono - w - (decyloxy) - , diammonium salt 422563 - 26 - 6 Poly(oxy - 1,2 - ethanediyl), a - octadecyl - w - hydroxy - , phosphate, ammonium salt 522613 - 09 - 8 Poly(oxy - 1,2 - ethanediyl), a - tridecyl - w - hydroxy - , phosphate, ion (neg.) 717140 - 06 - 2 Poly(oxy - 1,2 - ethanediyl), a - dodecyl - w - hydroxy - , phosphate, ammonium salt 717140 - 09 - 5 Poly(oxy - 1,2 - ethanediyl), a - octyl - w - hydroxy - , phosphate, ammonium salt 717827 - 29 - 7 Poly(oxy - 1,2 - ethanediyl), a - isooctyl - w - hydroxy - , phosphate, ammonium salt 762245 - 80 - 7 Poly[oxy(methyl - 1,2 - ethanediyl)], a - phosphono - w - (decyloxy) - , sodium salt 762245 - 81 - 8 Poly[oxy(methyl - 1,2 - ethanediyl)], a - phosphono - w - (decyloxy) - , potassium salt 866538 - 89 - 8 Poly(oxy - 1,2 - ethanediy l), a - isooctyl - w - hydroxy - , phosphate, sodium salt 866538 - 90 - 1 Poly(oxy - 1,2 - ethanediyl), a - isodecyl - w - hydroxy - , phosphate, sodium salt3

CASRN AAAPD Chemical Name 913068 - 96 - 9 Oxirane, 2 - methyl - , polymer with oxirane, mono - C12 - 14 - alkyl ethers, phosphates 1087209 - 87 - 7 Poly(oxy - 1,2 - ethanediyl), a - hydro - w - hydroxy - , mono(C16 - 18 and C18 - unsatd.

alkyl) ethers, phosphates, sodium salts 1174313 - 54 - 2 Oxirane, 2 - methyl - , polymer with oxirane, monododecyl ether, phosphate, block 1205632 - 03 - 6 Poly(oxy - 1,2 - ethanediyl), a - isooctyl - w - hydroxy - , phosphate 1233235 - 49 - 8 Oxirane, 2 - methyl - , polymer with oxirane, monododecyl ether, phosphate,

diblock 1451002 - 50 - 8 Oxirane, 2 - methyl - , polymer with oxirane, mono - C11 - 14 - isoalkyl ethers, C13 -

rich, phosphates 1456802 - 88 - 2 Oxirane, 2 - methyl - , polymer with oxirane, monohexadecyl ether, phosphate,

potassium salt 1456802 - 89 - 3 Oxirane, 2 - methyl - , polymer with oxirane, monohexadecyl ether, phosphate,

ammonium salt 1456803 - 12 - 5 Ethanol, 2 - amino - , compd. with 2 - methyloxirane polymer with oxirane

monohexadecyl ether phosphate AAASD Surfactants: 40CFR 180.910 and 180.930: α - Alkyl(C 6 - C 15 ) - ω - hydroxypoly(oxyethylene) sulfate, and its ammonium, calcium, magnesium, potassium, sodium, and zinc salts, poly(oxyethylene) content averages 2 - 4 moles; used as surfactants not to exceed 30% of pesticide formulation. CASRN AAASD Chemical Name 3694 - 74 - 4 Ethanol, 2 - (tetradecyloxy) - , 1 - (hydrogen sulfate), sodium salt (1:1) 9086 - 52 - 6 Poly(oxy - 1,2 - ethanediyl), α - [bis(1 - phenylethyl)phenyl] - ω - hydroxy 15826 - 16 - 1 Ethanol, 2 - (dodecyloxy) - , 1 - (hydrogen sulfate), sodium salt (1:1) 25446 - 78 - 0 Ethanol, 2 - [2 - [2 - (tridecyloxy)ethoxy]ethoxy] - , 1 - (hydrogen sulfate), sodium salt

(1:1) 27731 - 61 - 9 Poly(oxy - 1,2 - ethanediyl), a - sulfo - w - (tetradecyloxy) - , ammonium salt (1:1) 55901 - 67 - 2 Ethanol, 2 - (decyloxy) - , 1 - (hydrogen sulfate), sodium salt (1:1) 61894 - 66 - 4 Ethanol, 2 - (decyloxy) - , 1 - (hydrogen sulfate) 63428 - 85 - 3 Poly(oxy - 1,2 - ethanediyl), a - sulfo - w - (hexyloxy) - , sodium salt (1:1) 65104 - 74 - 7 Poly(oxy - 1,2 - ethanediyl), a - sulfo - w - (hexadecen - 1 - yloxy) - , sodium salt (1:1) 65122 - 38 - 5 Poly(oxy - 1,2 - ethanediyl), a - sulfo - w - (tetradecen - 1 - yloxy) - , sodium salt (1:1) 67762 - 19 - 0 Poly(oxy - 1,2 - ethanediyl), a - sulfo - w - hydroxy - , C10 - 16 - alkyl ethers, ammonium

salts 67762 - 21 - 4 Poly(oxy - 1,2 - ethanediyl), a - sulfo - w - hydroxy - , C10 - 16 - alkyl ethers, magnesium

salts 67923 - 90 - 4 Ethanol, 2 - [2 - [2 - (decyloxy)ethoxy]ethoxy] - , 1 - (hydrogen sulfate), ammonium

salt (1:1) 68611 - 29 - 0 Poly(oxy - 1,2 - ethanediyl), a - sulfo - w - hydroxy - , C10 - 16 - alkyl ethers 119432 - 41 - 6 Poly(oxy - 1,2 - ethanediyl), α - sulfo - ω - [2,4,6 - tris(1 - phenylethyl)phenoxy] - ,

ammonium salt4

219756 - 63 - 5 Poly(oxy - 1,2 - ethanediyl), a - sulfo - w - (undecyloxy ) - , branched and linear, sodium

salt Prior to the submission of this petition to add missing CASRNs, Petition PP 9E7533 (Document ID EPA - HQ - OPP - 2009 - 0131) was submitted to the Agency , approved and these CASRNs were missing from th at petition. In additi on, JITF CST 2 submitte d a petition number , 2E8092 for additional CASRNs that were not included in the initial approved petition 9E7533 . Croda, Inc. is applying for additional CARNs missing from both of the JITF CST 2 petitions under these chemical descri ptors and is relying on the information submitted in 9E7533 to support this additional petition which includes the exact same chemistr ies as described in the accepted descriptors . Croda Inc. does not expect the addition of these CASRNs to result in additi onal 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 1. Plant metabolism. Not Applicable 2. Analytical method. Not Applicable 3. Magnitude of residues. There is no specific crop residue information available for AAAPD and AAASD and this informat ion is typically not available or required for the establishment of a tolerance exemption for inert ingredients. B. Toxicological Profile 

### 1. Acute toxicity. AAAPD and AAASD are like ly skin/eye irritants in their undiluted forms, but not acutely toxic. The reported oral LD 50 values were higher than 1,600 mg/kg for the alkyl ether phosphates C 13 EO 3,6,12 P, CASRN 9046 - 01 - 9 and alkyl ether sulfates NaC 12 EO 3 S, CASRN 9004 - 82 - 4 (Category III). No effects were found at any of the concentrations tested dermally. 2. Genotoxicity. NaC 12 - 15 EO 2 - 3 S compounds were not mutagenic in bacterial or mammalian in vitro cell systems or in vivo (HERA 2003). Neither IARC, NTP nor OSHA listed as a carcin ogen. 3. Reproductive and developmental toxicity. One representative compound for the group of chemicals requested in 9E7533 (and 2E8092) is CASRN 68891 - 38 - 3 Poly ( oxy - 1,2 - ethanediyl), a - sulfo - w - hydroxy - , C12 - 14 - alkyl ethers, sodium salts . The studies with the sulfate derivatives (AAASD) showed little to no toxicity in the dams or the pups, with the NOEL in a developmental toxicity study in rats with CASRN 68891 - 38 - 3 at the limit dose of 1000 mg/kg/day, and a reproductive NOAEL of 0.3% in dr inking water, equivalent to 300 mg/kg/day, the highest dose tested, in a two - generation reproduction study with CASRN 68891 - 38 - 3).5

CASRN 68891 - 38 - 3 was evaluated for effects on the reproduction and prenatal/postnatal development of the rat when adminis tered orally via the drinking water through two successive generations. No reproductive or developmental effects were observed at any dose, even where corresponding parental toxicity was observed. The NOAEL for reproductive effects was 0.3% in drinking w ater, equivalent to 300 mg/kg/day, the highest dose tested. In studies with the phosphate derivatives (AAAPD), the reproductive/developmental NOEL for the OECD 422 study with CASRN 68130 - 47 - 2 was 800 mg/kg/day, the highest dose tested, and for CASRN 783 30 - 24 - 2 the NOEL was 200 mg/kg/day. 4. Subchronic toxicity. Based on the Federal Register Notice (August 9, 2006, Volume 71, Number 153, pages 45415 - 45424), the Agency stated that the preferred test for repeat dose toxicity is the “Combined Repeated Dos e Toxicity Study with the Reproduction/Developmental Toxicity Screening Test (OECD Test Guideline 422).” AAAPD (CASRN 68130 - 47 - 2 and CASRN 78330 - 24 - 2) have been tested in repeat dose studies (OECD 422 Combined Repeated Dose Toxicity Study with a Reproduct ion/Developmental Toxicity Screening Test). The paternal and maternal NOAEL for CASRN 68130 - 47 - 2 was 200 mg/kg/day. The paternal and maternal no observable - effect - level (NOEL) for CASRN 78330 - 24 - 2 was 200 mg/kg/day. The NOAEL of 200 mg/kg/day was select ed as the toxicology endpoint for the chronic risk assessment for the phosphate derivatives (AAAPD). Subchronic data have been found in the public domain for the AAASD. Subchronic 21 - day repeat dose dietary studies showed low toxicity of compounds with carbon lengths of C 12 - 15 , C 12 - 14 and C 13 - 15 with sodium or ammonium alkyl ethoxylates with POE n=3. One study indicated that C 16 - 18 POE n=18 had comparable low toxicity. No observed - adverse - effect levels (NOAELs) range from 120 to 468 mg/kg/day, similar to a NOAEL from a 90 - day rat gavage study with NaC 12 - 14 POE n=2(CASRN 68891 - 38 - 3), which was reported to be 225 mg/kg/day. In addition, another 90 - day repeat dose dietary study with NaC 12 - 15 POE n=3(CASRN 68424 - 50 - 0) resulted in low toxicity, with a NOAE L of greater than approximately 50 mg/kg/day (calculated based on dose of 1000 ppm in diet). Effects were usually related to hepatic hypertrophy, increased liver weight, and related increases in hematological endpoints related to liver enzyme induction. Henkel KgaA (1994a) evaluated CASRN 68891 - 38 - 3 for systemic toxicity in Wistar (Hsd/Win:WU) rats by gavage at doses of 0, 25, 75, and 225 mg/kg/day for 90 - days. No treatment related symptoms including changes in mean food consumption or water intake, tot al body weight gain, hematological examinations, clinical chemistry, absolute and relative organ weights and macroscopical examinations were observed in any group. According to systemic, behavioral, and clinical abnormalities the NOAEL of 225 mg/kg/day f or sodium lauryl ether sulfate was determined. CASRN 68891 - 38 - 3 was evaluated for effects on the reproduction and prenatal/postnatal development of the rat when administered orally via the drinking water through two successive generations. Based on this study an overall no - observed - adverse effect level (NOAEL) for systemic effects was 0.1%, which was 86.6 mg/kg/day for the F0 generation, and 149.5 mg/kg/day for the F1 generation. The NOAEL of 86.6 mg/kg/day was6

selected as the toxicology endpoint for the chronic risk assessment for the sulfate derivatives (AAASD). 5. Chronic toxicity Based on the Federal Register Notice (August 9, 2006, Volume 71, Number 153, pages 45415 - 45424), the Agency stated that the preferred test for repeat - dose toxicity is the “C ombined Repeated Dose Toxicity Study with the Reproduction/Developmental Toxicity Screening Test (OECD Test Guideline 422).” Chronic dietary studies conducted with rats on AAASDs showed no incidence of cancer and no effects at the concentrations tested (lowest dose tested was ca 75 mg/kg/day). 6. Animal metabolism. The mammalian metabolic pathway for AAASD type surfactants has been published. The mammalian metabolic pathway for AAASD type surfactants has been published (HERA, 2003). For compounds of c omparable C16 carbon chain, the metabolites of the lower molecular weight ethoxylated (POE n=3) AAASD surfactants are readily absorbed and excreted primarily in the urine whereas for the C16 AAASD surfactants with increased ethoxylation (POE n=9) are poorl y absorbed and excreted primarily in the feces (McDermott et al., 1975). There was also no evidence of hydrolysis of the sulfate group from C 16 POE n= 3 and C 16 POE n=9 or of metabolism of the ethoxylate portion of the molecule. With C 11 POE n=3 and C 12 POE n=3 metabolic studies in rats confirmed that the alkyl chain is extensively metabolized by beta - or omega oxidation leaving the ethoxysulfate, which is excreted directly (Taylor et al., (1978) . By analogy to what would generally be expected in the m etabolism for phosphate esters, the AAAPD surfactants may initially undergo metabolism to generate the corresponding AAA and POE (or POE/POP) phosphate glycol. By analogy to the reported metabolism for the CST1 Alkyl Alkoxylate Alcohol (AAA) surfactants, the dephosphorylated metabolite should be hydrolyzed to the POE (or POE/POP) polyalkoxylate glycols and linear branched saturated and unsaturated alkyl alcohol metabolites. The resultant alkyl alcohol metabolites would be oxidized in fatty acid oxidation pathways. The polyal koxylate glycols may either be conjugated or excreted unchanged or hydrolyzed/oxidized to various degraded metabolites before being conjugated and excreted. 7. Metabolite toxicology . No metabolites of toxicological concern are expected based on the prop osed animal metabolic pathway. 

### 8. Endocrine disruption . The AAAPD and AAASD surfactants do not belong to a class of chemicals known or suspected of having adverse effects on the estrogen receptor or endocrine system. AAAPD and AAASD have been evaluated in acute, subchronic, developmental and reproductive studies capable of detecting effects on endocrine mediated events. The results of these studies did not give any indication of a treatment - related effect on the estrogen receptor or endocrine system. C. Aggregate Exposure 1. Dietary exposure. The dietary (food plus drinking water) exposures for AAAPD and AAASD surfactants are expressed as a percentage of the proposed chronic population7

adjusted dose (cPAD) for the general US 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 for the AAAPD are estimated to be 6% of the cPAD for the general U.S. population and 21% of the cPAD for children 1 - 2 years old. Based on I - DEEM screening level calculations, the chronic dietary exposures for the AAASD are estimated to be 14% of the cPAD for the general U.S. population and 49% of the cPAD for children 1 - 2 years old. These data de monstrate that the I - DEEM screening level chronic dietary (food and drinking water) exposures for both the AAAPD and AAASD are well below 100% of the cPAD, and are therefore below EPA’s established level of concern for all U.S. subpopulations. On the bas is of the OECD 422 repeat dose toxicity study and comparison of I DEEM exposures to the proposed cPAD, the JITF CST2 asserts that there is sufficient basis for EPA to grant a tolerance exemption for these additional AAAPD and AAASD surfactant CASRNs. CHR ONIC DIETARY SAFETY ASSESSMENT, % cPAD

Study Chronic

Systemic NOAEL 1 mg/kg bw/day cPAD 2

mg/kg bw/day Percent

cPAD Children 1 - 2 years of age Percent

cPAD U.S. Gen Population AAAPD CASRN 68130 - 47 - 2 and CASRN 78330 - 24 - 2; Repeated Dose Toxicity with Reproduction/ Developmental Toxicity Screening in Rats - (OECD 422) AAASD Sulfate CASRN 68891 - 38 - 3; systemic toxicity endpoint for repeated dose from the two generation rat reproductive drinking water st udy 200

87 2.0

0.87 21%

49% 6%

14%

Note: 1 NOAEL – No observed adverse effect level 2 cPAD – Chronic population adjusted dose, defined as: chronic NOAEL / (safety factor  FQPA factor)8

i. Food. The available data demonstrate that the I - DEEM screening level chronic dietary (food and drinking water) exposures are well below 100% of the cPAD, and are therefore below EPA’s established level of conce rn for all U.S. subpopulations. ii. Drinking water. Drinking water is included in the I - DEEM exposure assessment. Exposure to AAAPD and AAASD via drinking water is expected to be negligible. 2. Non - dietary exposure . AAAPD and AAASD surfactants are used as inert ingredients in agricultural formulati ons as well as in non - pesticidal uses such as, personal care products household cleaning products and laundry detergents. Given the low estimate of dietary exposure, there is ample room in the overall aggregate MOE for non - dietary uses. D. Cumulative Effe cts For the purpose of the tolerance exemption actions cited herein, the JITF CST2 has assumed that the 

### AAAPD and AAASD will not have a common mechanism of toxicity with other surfactant substances. It is therefore appropriate to consider only the potential risks of the compounds included in CST2 in the exposure assessment. E. Safety Determination 1. U.S. population. A dietary exposure assessment using current EPA inert screening level methodology (I - DEEM) was conducted. Based on the conservative I - DEEM dietary exposure estimates, there is a reasonable certainty that no harm will result to the US population from the aggregate exposure to AAAPD and AAASD . 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 increase d susceptibility, the FQPA safety factor may be reduced or removed. An evaluation of susceptibility and uncertainty issues associated with Anionic Alkyl Alkoxylate Derivatives has been performed. Based on the points below, Croda Inc. recommends that the FQPA safety factor be reduced from the default 10X to 1X.  A scientifically sound mammalian toxicology database, which includes acute, subchronic, reproductive, and developmental toxicity data, indicates no adverse effects to sensitive populations.  The AAAPD and AAASD surfactants do not belong to a class of chemicals known or suspected of having adverse effects on the estrogen receptor or endocrine system. These surfactants have been evaluated in acute, subchronic, developmental and reproductive stu dies capable of detecting effects on endocrine mediated events.  The AAASDs have also been evaluated in chronic studies including a two year dietary study (Moore 1983) and a two generation reproduction study with drinking water (Henkel KGaA 1999, MRID 4706 09903, 47112401) .9

 OECD 422 testing and other reproduction and developmental studies available in the literature (HERA, 2003) indicates no reproductive and no developmental effects in offspring at levels that are not maternally toxic.  There was no evidence of effects on the nervous system in the acute, subchronic or reproduction studies. F. International Tolerances There are no known international tolerances for Alkyl Alcohol Alkoxylate Phosphate and Sulfate Derivatives .