i

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 re place 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 establish ing 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

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2. Analytical method. [ NA

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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 agricu ltural commodities has not been2

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 tole rance 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 w ell as polymers that typically are not readily absorbed. Akzo Nobel Surface Chemistry LLC believes that acrylic acid benzyl methacrylate copolymer diethanolamine salt conform s to the definition of a polymer given in 40
CFR 723.250 and meets the criteria u sed 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 polymer s 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 ot her 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: p erfluoroalkyl sulfonates (PFAS), p erfluoroalkyl carboxylates (PFAC), f

luo rotelomers, or p erfluoroalkyl 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 C hemistry LLC believes sufficient information was submitted in the petition to assess the hazards of 2

- Propenoic acid, 2

- methyl

- , phenylmethyl3

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

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- 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

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3. Reproductive and developmental toxicity. [ NA

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4. Subchronic toxicity. [ NA

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5. Chronic toxicity. [ NA

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6. Animal metabolism. [ NA

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7. Metabolite toxicology

. [NA

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8. Endocrine disruption

. [NA

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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

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ii. Drinking water

. [ NA

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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 greate r 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 for4

modified acrylic polymers. Polymers w ith 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 th e 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

- , phenylmethy l 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

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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 h ave any CODEX Maximum Residue Levels (MRLs) been established for any food crops at this time. ]