Notice of Filing

Exponent Inc.(1150 Connecticut Ave., NW, Suite 1100 , Washington, DC 20036) on 

behalf of Plant Impact plc, [12 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 

request for Castor oil, ethoxylated, dioleate (CAS # 110531-96-9). A rationale has been 

provided for how Castor 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

identify 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 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).

4. The polymer is neither designed nor can it be reasonably anticipated to 

substantially degrade, decompose, or depolymerize.

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 polymer'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.
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Castor 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 dermal 

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 expected 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 are 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 available 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 with the use of Castor oil, ethoxylated, dioleate (CAS # 

110531-96-9) as a surfactant in end-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 Castor 

oil, ethoxylated, dioleate CAS # 110531-96-9.

G. Effects on the Immune and Endocrine Systems

To date there is no evidence to suggest that Castor oil, ethoxylated, dioleate ( CAS # 

110531-96-9) functions in a manner similar to any known hormone, or that it acts as an 

endocrine disrupter.

H. Existing Tolerances

There is no current US EPA tolerance for Castor oil, ethoxylated, dioleate (CAS # 

110531-96-9)

I.International Tolerances

No known international tolerances are established for Castor oil, ethoxylated, dioleate

(CAS # 110531-96-9).
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