1

EPA REGISTRATION DIVISION COMPANY NOTICE OF FILING FOR PESTICIDE 

PETITIONS PUBLISHED IN THE FEDERAL REGISTER 

EPA Registration Division contact: William Cutchin, 703-305-7990

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 existing exemptions 

from the requirement of a tolerance by adding Alkyl Alcohol Alkoxylate Phosphate and 

Sulfate Derivatives (AAAPD and AAASD respectively), Chemical Abstracts Service 

Registry Numbers (CASRNs) for post-harvest use on agricultural crops under 40 CFR 

§180.910 and when applied to animals under 40 CFR §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 C6 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 salt

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 salt
2

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-tridecyl-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 salt

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), monooctadecyl 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-ethanediyl), a-isooctyl-w-hydroxy-, phosphate, sodium salt

866538-90-1 Poly(oxy-1,2-ethanediyl), a-isodecyl-w-hydroxy-, phosphate, sodium salt
3

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(C6-C15)-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-hydroxy15826-16-1 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 salt
4

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 that petition. In addition, JITF CST 2 submitted 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 descriptors and is relying on the information 

submitted in 9E7533 to support this additional petition which includes the exact same 

chemistries as described in the accepted descriptors. Croda Inc. 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

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 information 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 likely skin/eye irritants in their 

undiluted forms, but not acutely toxic. The reported oral LD50 values were higher than 

1,600 mg/kg for the alkyl ether phosphates C13EO3,6,12P, CASRN 9046-01-9 and alkyl ether 

sulfates NaC12EO3S, CASRN 9004-82-4 (Category III). No effects were found at any of the 

concentrations tested dermally.

2. Genotoxicity. NaC12-15EO2-3S 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 carcinogen.

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 drinking water, equivalent to 

300 mg/kg/day, the highest dose tested, in a two-generation reproduction study with 

CASRN 68891-38-3). 
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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. 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 water, 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 78330-24-2 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 repeatdose toxicity is the “Combined Repeated Dose 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 

Reproduction/Developmental Toxicity Screening Test). The paternal and maternal 

NOAEL for CASRN 68130-47-2 was 200 mg/kg/day. The paternal and maternal noobservable-effect-level (NOEL) for CASRN 78330-24-2 was 200 mg/kg/day. The NOAEL 

of 200 mg/kg/day was selected 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 C12-15, C12-14 and C13-15 with sodium or ammonium alkyl ethoxylates with 

POE n=3. One study indicated that C16-18 POE n=18 had comparable low toxicity. Noobserved-adverse-effect levels (NOAELs) range from 120 to 468 mg/kg/day, similar to a 

NOAEL from a 90-day rat gavage study with NaC12-14 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 NaC12-15 POE n=3(CASRN 68424-50-0) resulted in low toxicity, with a NOAEL 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, 

total 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 

for 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-adverseeffect 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 was 
6

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 “Combined 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 comparable 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 poorly absorbed and 

excreted primarily in the feces (McDermott et al., 1975). There was also no evidence of 

hydrolysis of the sulfate group from C16 POE n= 3 and C16 POE n=9 or of metabolism of 

the ethoxylate portion of the molecule. With C11 POE n=3 and C12 POE n=3 metabolic 

studies in rats confirmed that the alkyl chain is extensively metabolized by beta- or omegaoxidation leaving the ethoxysulfate, which is excreted directly (Taylor et al., (1978).

By analogy to what would generally be expected in the metabolism 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 polyalkoxylate 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 proposed 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 population 
7

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 demonstrate 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 basis of the OECD 422 repeat dose toxicity study and comparison of IDEEM 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. 

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

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 study

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 concern 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 formulations 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 Effects

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 increased 

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 

studies 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 470609903, 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.