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 of Filing 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) of the 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 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. [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 of a 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 of residues. [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 of a tolerance based upon the definition of a low-risk polymer under 40 

CFR 723.250. Therefore, magnitude of residues 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 of a 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 Specialty 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 salt is not a 

water-absorbing polymer 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 salt 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 of 2,5-Furandione, 

~0~~'lller with methoxyethene, butyl ethyl ester, sodium salt lead to the conclusion that there is a 

reasonable certainty of no 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 of this 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 of the 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]