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EPA REGISTRATION DIVISION COMPANY NOTICE OF FILING FOR PESTICIDE PETITIONS 

PUBLISHED IN THE FEDERAL REGISTER 

EPA Registration Division contact: [Mr. Mark Dow, 703-305-5533]

H.B. Fuller Company

2E8033

EPA has received a pesticide petition 2E8033 from H.B. Fuller Company, 1200 Willow 

Lake Boulevard, Saint Paul, MN 55101 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 180.960 to

approve an Inert Ingredient Low Risk Polymer Exemption for 2-Propenoic Acid, 2-Ethylhexyl 

Ester, Polymer with Ethenylbenzene [8900 amu], [CAS # 25153-46-2] as an approved inert 

binder for antimicrobial pesticide formulation. 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. [N/A-REMOVE]

2. Analytical method. [N/A-REMOVE]

3. Magnitude of residues. [N/A-REMOVE]

B. Toxicological Profile
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a. 2-Propenoic Acid, 2-Ethylhexyl Ester, Polymer with Ethenylbenzene is a polymer as 

defined by 40 CFR 723.250(b). It is composed of at least 3 monomer units and two

other reactants. In addition, 2-Propenoic Acid, 2-Ethylhexyl Ester, Polymer with 

Ethenylbenzene comprises the majority of the polymer molecular weight. The 

monomer sequences form uninterrupted strings in the polymer and the molecular 

weight distribution of the polymer is due to the difference in polymer chain lengths.

b. 2-Propenoic Acid, 2-Ethylhexyl Ester, Polymer with Ethenylbenzene consists of a 

number average molecular weight greater than 1000 Da (Daltons).

c. 2-Propenoic Acid, 2-Ethylhexyl Ester, Polymer with Ethenylbenzene is not a cationic 

polymer, nor is it reasonably expected to become a cationic polymer in a natural 

aquatic environment.

d. The polymer does contain as an integral part of its composition the atomic elements 

carbon, hydrogen, and oxygen.

e. The polymer does not contain as an integral part of its composition, except as 

impurities, any elements other than those listed in 40 CFR 273.250(d)(2)(ii).

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

degrade, decompose, or depolymerize.

g. The polymer is manufactured from reactants that are already included in the TSCA 

Chemical Substances Inventory.

h. The polymer is not a water absorbing polymer with a number average molecular 

weight (MW) greater than or equal to 10,000 Dalton. Additional, the polymer 2-

Propenoic Acid, 2-Ethylhexyl Ester, Polymer with Ethenylbenzene, also meets as 

required the following exemption criteria specified in 40 CFR 723.250(b). The 

polymer is not designed to be a water absorbing polymer that is capable of 

absorbing its weight of water.

Thus, 2-Propenoic Acid, 2-Ethylhexyl Ester, Polymer with Ethenylbenzene meets all the 

criteria for a polymer to be considered a low risk under 40 CFR 273.250. Based on its 

conformance to all the above criteria, no mammalian toxicity is anticipated from 

dietary, inhalation, or dermal exposure to 2-Propenoic Acid, 2-Ethylhexyl Ester, Polymer 

with Ethenylbenzene.

C. Aggregate Exposure
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For purposes of assessing potential exposure under this exemption, 2-Propenoic Acid, 2-

Ethylhexyl Ester, Polymer with Ethenylbenzene could be present in all raw and processed 

agricultural commodities and drinking water, and that non-occupational non-dietary exposure 

was possible. The number average MW of 2-Propenoic Acid, 2-Ethylhexyl Ester, Polymer with 

Ethenylbenzene is greater than 1000 Daltons. Generally a polymer of this size would be poorly 

absorbed through the intact gastrointestinal tract or through intact human skin. Since 2-

Propenoic Acid, 2-Ethylhexyl Ester, Polymer with Ethenylbenzene conforms to the criteria that 

identify a low risk polymer there are no concerns with risks associated with any potential 

exposure scenarios that are reasonably foreseeable. Therefore a tolerance is not necessary to 

protect public health.

D. Cumulative Effects

Section 408 (b)(2)(D)(v) of FFDCA requires that, when considering whether to establish, 

modify, or revoke a tolerance or tolerance exemption, “available information” concerning the 

cumulative effects of a particular chemical’s residue and “other substances that have a common 

method of toxicity” must be considered. At this time, available data to determine whether 2-

Propenoic Acid, 2-Ethylhexyl Ester, Polymer with Ethenylbenzene has common methods of 

toxicity with other substances is not available. Since it meets the definition of low concern 

polymer, it is not expected to show any cumulative effects.

E. Safety Determination

1. U.S. population. Based on the conformance to the criteria used to identify a low risk 

polymer, there is a reasonable certainty of no harm to the US population, including infants and 

children, from aggregate exposure to residues of 2-Propenoic Acid, 2-Ethylhexyl Ester, Polymer 

with Ethenylbenzene
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