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EPA REGISTRATION DIVISION COMPANY NOTICE OF FILING FOR 

PESTICIDE PETITIONS PUBLISHED IN THE FEDERAL REGISTER 

EPA Registration Division contact: W. 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.

TEMPLATE:

Stepan Company

2E7995

EPA has received a pesticide petition 2E7995 from Stepan Company, 22 West 

Frontage Rd., Northfield Illinois 60093 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 fatty acids, 

tall-oil, ethoxylated propoxylated (CAS No.: 67784-86-5; 2009 amu) when used as a 

pesticide inert ingredient as a surfactant without limitations in pesticide formulations 

under CFR part 180.960 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.

A. Residue Chemistry

1. Plant metabolism. Stepan Company is petitioning that fatty acids, tall-oil, 

ethoxylated propoxylated (CAS No.: 67784-86-5; 2009 amu) be exempt from the 

requirement of a tolerance based upon the definition of a low-risk polymer under 40 CFR 

723.250. Therefore, plant metabolism in treated crops is not relevant.

2. Analytical method. Stepan Company is petitioning that fatty acids, tall-oil, 

ethoxylated propoxylated (CAS No.: 67784-86-5; 2009 amu) be exempt from the 

requirement of a tolerance based upon the definition of a low-risk polymer under 40 CFR 

723.250. Therefore, an analytical method to determine residues on treated crops is not 

relevant.
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3. Magnitude of residues. Stepan Company is petitioning that fatty acids, tall-oil, 

ethoxylated propoxylated (CAS No.: 67784-86-5; 2009 amu) be exempt from the 

requirement of a tolerance based upon the definition of a low-risk polymer under 40 CFR 

723.250. Therefore, magnitude of residues on treated crops is not relevant.

B. Toxicological Profile

1. Acute toxicity. No toxicological data is submitted with, or referenced in this 

tolerance exemption petition because fatty acids, tall-oil, ethoxylated propoxylated (CAS 

No.: 67784-86-5; 2009 amu) meets the definition of a low-risk polymer under 40 CFR 

723.250.

1a. Fatty acids, tall-oil, ethoxylated propoxylated (CAS No.: 67784-86-5; 2009 

amu) is a polymer molecule as defined by 40 CFR 723.250(b). That is, it contains a 

sequence of at least 3 monomer units which are covalently bound to at least one other 

monomer unit or other reactant.

1b. Fatty acids, tall-oil, ethoxylated propoxylated (CAS No.: 67784-86-5; 2009 

amu) has a number average molecular weight of 2009 and contains less than 0.1 percent 

oligomeric material below molecular weight 500 and 1,000 molecular weight.

1c. Fatty acids, tall-oil, ethoxylated propoxylated (CAS No.: 67784-86-5; 2009 

amu) is not a cationic polymer and is not anticipated to become a cationic polymer in a 

natural aquatic environment.

1d. Fatty acids, tall-oil, ethoxylated propoxylated (CAS No.: 67784-86-5; 2009 

amu) only contains the elements carbon, hydrogen, and oxygen; therefore, it meets the 

criteria for elemental composition.

1e. The polymer 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).

1f. Fatty acids, tall-oil, ethoxylated propoxylated (CAS No.: 67784-86-5; 2009 

amu) is not designed or reasonably anticipated to substantially degrade, decompose, or 

depolymerize under normal use conditions.

1g. Fatty acids, tall-oil, ethoxylated propoxylated (CAS No.: 67784-86-5; 2009 

amu) is not manufactured or imported from monomers and/or other reactants that are not 

already included on the TSCA Chemical Substance Inventory or manufactured under an 

applicable TSCA section 5 exemption.

1h. Fatty acids, tall-oil, ethoxylated propoxylated (CAS No.: 67784-86-5; 2009 

amu) is not a water-absorbing polymer with a number average molecular weight above 

10,000 daltons.

1i. Fatty acids, tall-oil, ethoxylated propoxylated (CAS No.: 67784-86-5; 2009 

amu) contains no reactive functional groups that fail to meet the low-risk polymer 

exemption criteria under 40 CFR 723.250(e).]

2. Genotoxicty. Not applicable - remove.

3. Reproductive and developmental toxicity. Not applicable - remove.

4. Subchronic toxicity. Not applicable - remove.

5. Chronic toxicity. Not applicable - remove.
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6. Animal metabolism. Not applicable - remove.

7. Metabolite toxicology. Not applicable - remove.

8. Endocrine disruption. Not applicable - remove.

C. Aggregate Exposure

1. Dietary exposure. The physical and chemical characteristics of fatty acids, talloil, ethoxylated propoxylated (CAS No.: 67784-86-5; 2009 amu) lead to the conclusion 

that there is a reasonable certainty of no harm from exposure to the polymer from food or 

drinking water.

i. Food. Not applicable - remove.

ii. Drinking water. Not applicable - remove.

2. Non-dietary exposure. The physical and chemical characteristics of fatty acids, 

tall-oil, ethoxylated propoxylated (CAS No.: 67784-86-5; 2009 amu) lead to the 

conclusion that there is a reasonable certainty of no harm from exposure to the polymer 

from exposure to the polymer through non-dietary means.

D. Cumulative Effects

Fatty acids, tall-oil, ethoxylated propoxylated (CAS No.: 67784-86-5; 2009 amu)

is a low-risk polymer. There is no information at this time to suggest that any toxic 

effects produced by this inert ingredient would be cumulative with any other chemical.

E. Safety Determination

1. U.S. population. Fatty acids, tall-oil, ethoxylated propoxylated (CAS No.: 

67784-86-5; 2009 amu) meets all the criteria for qualification as a low-risk polymer 

under 40 CFR 723.250. Adverse effects on the U.S. population are not expected from the 

use of this inert ingredient in pesticide formulations.

2. Infants and children. Fatty acids, tall-oil, ethoxylated propoxylated (CAS No.: 

67784-86-5; 2009 amu) is a low-risk polymer. No adverse effects are expected from use 

of this inert ingredient in pesticide formulations. Based on the physical and chemical 

properties of the molecule, there is no reason to believe that infants and children will be 

disproportionately at risk.

F. International Tolerances

There are no known U.S. or international tolerances for fatty acids, tall-oil, 

ethoxylated propoxylated (CAS No.: 67784-86-5; 2009 amu).