i

EPA REGISTRATION DIVISION COMPANY NOTICE OF FILING FOR 

PESTICIDE PETITIONS PUBLISHED IN THE FEDERAL REGISTER 

EPA Registration Division contact: Kerry Leifer 703-308-8811

TEMPLATE:

Trinseo LLC

[IN-10907]

EPA has received a pesticide petition (IN-10907) from Trinseo LLC, c/o Keller and 

Heckman LLP, 1001 G Street, NW, Suite 500 West, Washington, DC 20001 requesting, 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 

butanedioic acid, 2-methylene-, polymer with 1,3-butadiene, ethenylbenzene and 2-

hydroxyethyl 2-propenoate with an average molecular weight of greater than 10,000 daltons 

(CAS Reg. No. 36089-06-2) under 40 CFR §180.960 in or on raw agricultural commodities 

when used as a pesticide inert ingredient in pesticide formulations without limitation. 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

1. Plant metabolism. NA-Remove. No specific plant metabolism data is available, nor 

is it required for the establishment of a tolerance exemption.

2. Analytical method. NA-Remove. An analytical method is not required for 

enforcement purposes since the Agency is establishing an exemption from the requirement 

of a tolerance without any numerical limitation. 

3. Magnitude of residues. NA-Remove. Information regarding the nature and 

magnitude of chemical residues resulting from the use of this inert ingredient is not 

required for the establishment of a tolerance exemption.

B. Toxicological Profile

1. Butanedioic acid, 2-methylene-, polymer with 1,3-butadiene, ethenylbenzene and 2-

hydroxyethyl 2-propenoate is a polymer as defined by 40 CFR 723.250(b).

2. Butanedioic acid, 2-methylene-, polymer with 1,3-butadiene, ethenylbenzene and 2-

hydroxyethyl 2-propenoate will not become cationic in an aquatic environment.

3. Butanedioic acid, 2-methylene-, polymer with 1,3-butadiene, ethenylbenzene and 2-

hydroxyethyl 2-propenoate is composed of hydrogen, oxygen, and carbon: therefore, it 

meets the criteria of elemental composition.
2

4. Butanedioic acid, 2-methylene-, polymer with 1,3-butadiene, ethenylbenzene and 2-

hydroxyethyl 2-propenoate does not contain as an integral part of its composition, 

except as impurities, any element other than those listed in 40 CFR 723.250(d)(2)(ii).

5. Butanedioic acid, 2-methylene-, polymer with 1,3-butadiene, ethenylbenzene and 2-

hydroxyethyl 2-propenoate is not designed nor reasonably expected to degrade, 

decompose, or depolymerize under normal conditions of manufacture, use and disposal. 

6. Butanedioic acid, 2-methylene-, polymer with 1,3-butadiene, ethenylbenzene and 2-

hydroxyethyl 2-propenoate is composed of molecules that are listed on the TSCA 

Inventory or manufactured under an applicable TSCA section 5 exemption.

7. Butanedioic acid, 2-methylene-, polymer with 1,3-butadiene, ethenylbenzene and 2-

hydroxyethyl 2-propenoate is not a water absorbing polymer and cannot absorb its own 

weight in water.

8. Butanedioic acid, 2-methylene-, polymer with 1,3-butadiene, ethenylbenzene and 2-

hydroxyethyl 2-propenoate does not contain any perfluoroalkyl moieties consisting of a 

CF3- or longer chain length as specified in 40 CFR 723.250(d)(6). 

9. Butanedioic acid, 2-methylene-, polymer with 1,3-butadiene, ethenylbenzene and 2-

hydroxyethyl 2-propenoate consists of a number average molecular weight of greater 

than 10,000 daltons.

1. Acute toxicity. NA-Remove

2. Genotoxicty. NA-Remove

3. Reproductive and developmental toxicity. NA-Remove

4. Subchronic toxicity. NA-Remove

5. Chronic toxicity. NA-Remove

6. Animal metabolism. NA-Remove

7. Metabolite toxicology. NA-Remove

8. Endocrine disruption. NA-Remove

C. Aggregate Exposure

1. Dietary exposure. The physical-chemical characteristics of butanedioic acid, 2-

methylene-, polymer with 1,3-butadiene, ethenylbenzene and 2-hydroxyethyl 2-propenoate 

leads to the conclusion that there is a reasonably certainty of no harm from exposure to the 

polymer from food or drinking water nor from an aggregate exposure. 

i. Food. NA-Remove

ii. Drinking water. NA-Remove

2. Non-dietary exposure. The physical-chemical characteristics of butanedioic acid, 

2-methylene-, polymer with 1,3-butadiene, ethenylbenzene and 2-hydroxyethyl 2-

propenoate lead to the conclusion that there is a reasonable certainty of no harm from 

exposure to the polymer from non-dietary means. 
3

D. Cumulative Effects

At this time there is no information to indicate that any toxic effects produced by 

butanedioic acid, 2-methylene-, polymer with 1,3-butadiene, ethenylbenzene and 2-

hydroxyethyl 2-propenoate would by cumulative with any other chemical. Given the 

compound’s categorization as a low risk polymer, and its proposed use in pesticide 

formulations, there is no expectation of increased risk due to cumulative exposure.

E. Safety Determination

1. U.S. population. Based on the polymer’s physical-chemical properties, and that it 

meets or exceeds the polymer exemption criteria at 40 CFR 723.250 for low-risk polymers, 

adverse effects are not expected.

2. Infants and children. Based on the polymer’s physical-chemical properties, and 

that it meets or exceeds the polymer exemption criteria at 40 CFR 723.250 for low-risk 

polymers, adverse effects are not expected.

F. International Tolerances

The Codex Alimentarius Commission (Codex) has not established a MRL for 

butanedioic acid, 2-methylene-, polymer with 1,3-butadiene, ethenylbenzene and 2-

hydroxyethyl 2-propenoate and there are no maximum residue limits established for 

butanedioic acid, 2-methylene-, polymer with 1,3-butadiene, ethenylbenzene and 2-

hydroxyethyl 2-propenoate in or on crops or commodities of which the petitioner is aware.

4819-9536-0301, v. 1