International Specialty Products An Ashland Inc. Business Petition for Exemption from Tolerance Page 3


### SECTION 1. INFORMATIVE SUMMARY OF THE PETITION The informative summary, which may be published in accordance with Section 2 , is provided separately in both hard and electronic copy in the current Notice ofFiling template format. EPA has received a pesticide petition ([insert petition number]) from [International Specialty Products, An Ashland Inc. Business c /o Lewis & Harrison, LLC], [122 C Street NW , Ste. 505 , Washington, DC 20001] proposing, pursuant to section 408(d) ofthe Federal Food, Drug, and Cosmetic Act (FFDCA), 21 U.S.C. 346a(d), to amend 40 CFR part 180. [2,5-Furandione, polymer with methoxyethene, butyl ethyl ester, sodium salt (CAS# 1471342-08-1)] [under 40 CFR 180.960 when used as an inert ingredient 

### 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 ofthe submitted data at this time or whether the data supports granting ofthe petition. Additional data may be needed before EPA rules on the petition. A. Residue Chemistry 1. Plant metabolism [NA

- Remove] 2. Analytical method. [International Specialty Products, An Ashland lnc.Business is petitioning that 2,5-Furandione, polymer with methoxyethene, butyl ethyl ester, sodium salt be exempt from the requirement ofa 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.] 3. Magnitude ofresidues. [International Specialty Products, An Ashland Inc. Business is petitioning that 2,5-Furandione, polymer with methoxyethene, butyl ethyl ester, sodium salt be exempt from the requirement ofa tolerance based upon the definition of a low-risk polymer under 40 CFR 723.250. Therefore, magnitude ofresidues 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 2,5-Furandione, polymer with methoxyethene, butyl ethyl ester, £ccbm salt meets the definition ofa low-risk polymer under 40 CFR 732.250. 1. 2,5-Furandione, polymer with methoxyethene, butyl ethyl ester, sodium salt IS a polymer molecule as defined by 40 CFR 723.25(b). That is, it contains a se-quence of at least 3 monomer units which are covalently bound to at least one other m')nomer unit or other reactant. 2. 2,5-Furandione, polymer with methoxyethene, butyl ethyl ester, sodium salt consists of a number average molecular weight greater than 10 ,000 daltons
. Its

**olig->J~t-r** content is less than 2 percent below molecular weight 500 and less than 5 perrt"t't below molecular weight 1,000**In~ -..tational**  Specia lty Products An Ashland Inc. Business Petition for Exemption from Tolerance Page4 3. 2, 5

-Furandione, polymer with methoxyethene, butyl ethyl ester, sodium salt is not a cationic polymer and is not anticipated to become a cationic polymer in a natural aquatic environment. 4. 2, 5-Furandione, polymer with methoxyethene, butyl ethyl ester, sodium salt contains the elements carbon, hydrogen, and oxygen, with sodium as a monatomic counterion; therefore, it meets the criteria for elemental composition. 5. 2, 5-Furandione, polymer with methoxyethene, butyl ethyl ester, sodium salt is not designed or reasonably anticipated to substantially degrade, decompose, or depolymerize under normal use conditions
. 6. 2,5-Furandione, polymer with methoxyethene, butyl ethyl ester, sodium salt is prepared from molecules that are listed on the TSCA Chemical Substance Inventory or manufactured under an applicable TSCA section 5 exemption. 7. 2,5

-Furandione, polymer with methoxyethene, butyl ethyl ester, sodium sa lt is not a water-absorbing polym er with a number average molecular weight above 10,000 daltons.] 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. [The physical and chemical characteristics of2,5-Furandione, polymer

**., i~h**  methoxyethene, butyl ethyl ester, sodium sa lt lead to the conclusion that there is a reasonable

**..J ~** tainty of no harm from exposure to the polymer from food or drinking water
.] i
. Food. [NA- Remove.] ii. Drinking water. [NA- Remove.] 2. Non-dietary exposure. [The physical and chemical characteristics of2,5-Furandione,

**~0~~'lller** with methoxyethene, butyl ethyl ester, sodium salt lead to the conclusion that there is a reasonable certainty ofno harm from exposure to the polymer from non-dietary means.]D. Cumulative Effects International Specialty Products An Ashland Inc. Business Petition for Exemption from Tolerance Page 5
[2,5

-Furandione, polymer with methoxyethene, butyl ethyl ester, sodium salt 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. [2 ,5-Furandione, polymer with methoxyethene, butyl ethyl ester, sodium salt 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 ofthis inert ingredient in pesticide formulations.] 2. Infants and children. [2,5-Furandione, polymer with methoxyethene, butyl ethyl ester, sodium salt meets all the criteria for qualification as a low-risk polymer under 40 CFR 723.250
. Based on the physical and chemical properties ofthe 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 2,5-Furandione, polymer with methoxyethene, butyl ethyl ester, sodium salt]