Notice of Filing

Exponent Inc

. ( 1150 Connecticut Ave., NW, Suite 1100

, Washington, DC 20036 ) on behalf of Plant Impact plc

, [ 1 2 South Preston Office Village, Cuerdan Way, Bamber Bridge, Preston, PR5 6BL United Kingdom ] is submitting in conformance to the definition of a polymer given in 40 CFR 723.250(b) a low risk polymer exemption
req uest for Castor oil , ethoxylated

, dioleate (CAS # 110531

- 96

- 9 ). A rationale has been provided for how C astor oil , ethoxylated, dioleate (CAS # 110531

- 96

- 9 ) meets the criteria used to identify low risk polymers described in 40 CFR 723.250(d)

.

A. Product Name and Proposed Use Practices Plant Impact plc intends to use Castor oil , ethoxylated, dioleate (CAS # 110531

- 96

- 9) (proposed inert ingredient) in formulated pesticide products as an inert ingredient with a surfactant function.

B. Product Identity/

Chemistry Castor oil , ethoxylated, dioleate (CAS # 110531

- 96

- 9 ) conforms to the definition of a polymer given in 40 CFR 723.250(b) and meets the following criteria that are used to i dentify low

- risk polymers described in 40 CFR 723.250(d )

. 1. The polymer is not a cationic polymer nor is it reasonably anticipated to become a cationic polymer in a natural aquatic environment. 2. The polymer does contain as an integral part of its composition the atomic elements carbon, hydrogen, and oxygen. 3. The polymer d oes 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). 4. The polymer is neither designed nor can it be reasonably anticipated to substantially degrade, decompose, or d epolymerize. 5. The polymer is manufactured or imported from monomers and/or reactants that are already included on the TSCA Chemical Substance Inventory or manufactured under an applicable TSCA section 5 exemption. 6. The polymer is not a water absorbing polymer with a number average molecular weight (MW) greater than or equal to 10,000 daltons.

Additionally, the polymer also meets

, as required

, the following exemption criteria specified in 40 CFR 723.250(e).

7. The po lymer's number average MW of 1260 g/ mol (daltons) is greater than 1,000 and less than 10,000 daltons. The polymer contains less than 10% oligomeric material below MW 500 and less than 25% oligomeric material below MW 1, 000, and the polymer does not contain any reactive functional groups.2

C astor oil , ethoxylated, dioleate (CAS # 110531

- 96

- 9 ) meets the criteria for a polymer to be considered low risk under 40 CFR 723.250. Based on its conformance to the criteria in this unit, no mammalian toxicity is anticipated from dietary, inhalation, or d ermal exposure to Castor oil , ethoxylated, dioleate (CAS # 110531

- 96

- 9 )

.

C. Aggregate Exposure

Non

- dietary exposure

. The number average MW of Castor oil , ethoxylated, dioleate (CAS # 110531

- 96

- 9 ) is 1260 g/mol (Daltons). Due to the size, it is expe cted that a polymer of this MW size would be poorly absorbed through the intact gastrointestinal tract or through intact human skin. Since Castor oil , ethoxylated, dioleate (CAS # 110531

- 96

- 9 ) conforms to criteria that identify a low

- risk polymer, there ar e no concerns for risks associated with any potential exposure scenarios that are reasonably foreseeable. It is expected that a tolerance would not be necessary to protect the public health.

D . Cumulative Effects Plant Impact plc has considered all av ailable information that relates to the cumulative effect of pesticide residues of Castor oil , ethoxylated, dioleate (CAS # 110531

- 96

- 9 )

. Plant Impact plc concludes that due to the expected low order of toxicity and lack of reported toxicity associated wit h the use of Castor oil , ethoxylated, dioleate (CAS # 110531

- 96

- 9 ) as a surfactant in e nd

- use pesticide formulations no cumulative effect from the use of Castor oil , ethoxylated, dioleate is expected.

F . Safety Determination Based on the conformance to the criteria used to identify a low risk polymer, it is concluded that there is a reasonable certainty of no harm to the U.S. population, including infants and children, from aggregate exposures to residues of chemistry based on C astor oil, ethoxylated

, di oleate CAS # 11053 1

- 96

- 9

. G. Effects on the Immune and Endocrine Systems To date there is no evidence to suggest that C astor oil, ethoxylated, di oleate ( CAS # 110531

- 96

- 9) functions in a manner similar to any known hormone, or that it acts as an

e ndocrine disrupter

. H. Existing Tolerances There is no current US EPA tolerance for C astor oil, ethoxylated, di oleate (CAS # 110531

- 96

- 9)

I. International Tolerances No known international tolerances are established for C astor oil

, ethoxylated, d i oleate (CAS # 110531

- 96

- 9)

.3