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EPA REGISTRATION DIVISION COMPANY NOTICE OF FILING FOR 

PESTICIDE PETITIONS PUBLISHED IN THE FEDERAL REGISTER 

EPA Registration Division contact: [insert name and telephone number with area 

code]

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:

[Akzo Nobel Surface Chemistry LLC]

[IN-10705]

EPA has received a pesticide petition (IN-10705) from [Akzo Nobel Surface 

Chemistry LLC], [525 West Van Buren Street, Chicago, IL 60607-3823] 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 by establishing an exemption from the 

requirement of a tolerance for 2-Propenoic acid, 2-methyl-, phenylmethyl ester, polymer 

with 2-propenoic acid, peroxydisulfuric acid ([(HO)S(O)2]2O2) sodium salt (1:2)-

initiated, compds. with diethanolamine; number average molecular weight (in amu) 2000, 

(CAS Reg. No.1574486-33-1) under 40 CFR 180.960 when used as a compatibility agent 

in pesticide formulations. 

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]

2. Analytical method. [NA-Remove]

3. Magnitude of residues. [Akzo Nobel Surface Chemistry LLC is petitioning 

for an exemption from the requirement of a tolerance based upon the polymer’s 

compliance with the Low Risk Polymer criteria per 40 CFR 723.250. Therefore, an 

analytical method to determine residues in raw agricultural commodities has not been 
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proposed. No residue chemistry data or environmental fate data are presented in the 

petition as the Agency does not generally require some or all of the listed studies to 

rule on the exemption from the requirement of a tolerance for a low risk polymer 

inert ingredient.]

B. Toxicological Profile

1. Acute toxicity. [The Agency has established a set of criteria which identifies 

categories of polymers that present low risk. These criteria (described in 40 CFR 

723.250) identify polymers that are relatively unreactive and stable compared to other 

chemical substances as well as polymers that typically are not readily absorbed. Akzo 

Nobel Surface Chemistry LLC believes that acrylic acid benzyl methacrylate 

copolymer diethanolamine salt conforms to the definition of a polymer given in 40 

CFR 723.250 and meets the criteria used to identify a Low Risk Polymer. We also 

believe that based on this substance’s conformance to the above mentioned criteria, 

no mammalian toxicity is anticipated from dietary, inhalation or dermal exposure to 

emulsion polymers and that emulsion polymers will present minimal or no risk.

1. This polymer is not a cationic substance. 

2. It contains as an integral part of its composition the atomic elements carbon, 

hydrogen, and oxygen. 

3. It does not contain as an integral part of its composition, except as 

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

4. This polymer is not designed or reasonably anticipated to substantially 

degrade, decompose, or depolymerize.

5. It is not manufactured or imported from monomers and/or other reactants 

that are not already on the TSCA Chemical Substance Inventory or manufactured 

under an applicable TSCA Section 5 exemption.

6. It is not a water absorbing polymer.

7. The polymer does not contain, as an integral part of its composition, except 

as impurities, any of the following perfluoroalkyl moieties consisting of a CF3- or 

longer chain length: perfluoroalkyl sulfonates (PFAS), perfluoroalkyl carboxylates 

(PFAC), fluorotelomers, or perfluoroalkyl moieties that are covalently bound to 

either a carbon or sulfur atom where the carbon or sulfur atom is an integral part of 

the polymer molecule.

8. The minimum number average molecular weight of the above mentioned 

polymer is greater than 1,000 and less than 10,000. Substances with molecular 

weights greater than 400 are generally not readily absorbed through the intact skin, 

and substances with molecular weights greater than 1,000 are generally not 

absorbed through the intact gastrointestinal (GI) tract. Chemicals not absorbed 

through the GI tract are generally incapable of eliciting a toxic response. This 

polymer has an oligomer content less than 10 percent below MW 500 and less than 

25 percent MW 1,000.

Akzo Nobel Surface Chemistry LLC believes sufficient information was submitted 

in the petition to assess the hazards of 2-Propenoic acid, 2-methyl-, phenylmethyl 
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ester, polymer with 2-propenoic acid, peroxydisulfuric acid ([(HO)S(O)2]2O2) 

sodium salt (1:2)-initiated, compds. with diethanolamine; number average 

molecular weight (in amu) 2000, (CAS Reg. No.1574486-33-1). No toxicology data 

were presented in the petition as the Agency does not generally require some or all 

of the listed studies to rule on the exemption from the requirement of a tolerance for 

an inert ingredient. Based on these polymers conforming to the definition of a 

polymer and meeting the criteria of a low risk polymer under 40 CFR 723.250, Akzo 

Nobel Surface Chemistry LLC believes there are no concerns for risks associated 

with toxicity.]

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. [Some modified acrylic polymers may be used in contact 

with food as components of containers used to manufacture, process, or store food 

when regulated for such use under the Federal Food, Drug, and Cosmetic Act. 

Modified acrylic polymers with a molecular weight greater than 1,000 daltons are not 

readily absorbed through the intact gastrointestinal tract and are considered 

incapable of eliciting a toxic response.]

i. Food. [NA-Remove]

ii. Drinking water. [NA-Remove]

2. Non-dietary exposure. [Typical uses of modified acrylic polymers are in the 

laundry detergents, auto dish wash detergents, and bathroom hard surface cleaners. 

In these uses the primary exposures are dermal; however, modified acrylic polymers 

with a molecular weight significantly greater than 400 are not readily absorbed 

through the intact skin and are considered incapable of eliciting a toxic response.]

D. Cumulative Effects

[There is data to support a conclusion of negligible cumulative risk for 
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modified acrylic polymers. Polymers with molecular weights greater than 400 

generally are not absorbed through the intact skin, and substances with molecular 

weights greater than 1,000 generally are not absorbed through the intact 

gastrointestinal (GI) tract. Chemicals not absorbed through the skin or GI tract 

generally are incapable of eliciting a toxic response. Therefore, there is no reasonable 

expectation of increased risk due to cumulative exposure. Based on this polymer 

conforming to the definition of a polymer and meeting the criteria of a low risk 

polymer under 40 CFR 723.250, Akzo Nobel Surface Chemistry LLC believes there 

are no concerns for risks associated with cumulative effects.]

E. Safety Determination

[Based on the conformance to the criteria used to identify a low risk polymer, 

there is a reasonable certainty of no harm to the U.S. population, including infants 

and children, from aggregate exposure to residues of 2-Propenoic acid, 2-methyl-, 

phenylmethyl ester, polymer with 2-propenoic acid, peroxydisulfuric acid 

([(HO)S(O)2]2O2) sodium salt (1:2)-initiated, compds. with diethanolamine; 

number average molecular weight (in amu) 2000, (CAS Reg. No.1574486-33-1)]

1. U.S. population. [NA-Remove]

2. Infants and children. [NA-Remove]

F. International Tolerances

[To the best of our knowledge there are no international tolerances 

established for 2-Propenoic acid, 2-methyl-, phenylmethyl ester, polymer with 2-

propenoic acid, peroxydisulfuric acid ([(HO)S(O)2]2O2) sodium salt (1:2)-initiated, 

compds. with diethanolamine; number average molecular weight (in amu) 2000, 

(CAS Reg. No.1574486-33-1) nor have any CODEX Maximum Residue Levels 

(MRLs) been established for any food crops at this time.]