EPA REGISTRATION DIVISION COMPANY NOTICE OF FILING FOR 

PESTICIDE PETITIONS PUBLISHED IN THE FEDERAL REGISTER 

EPA Registration Division contact: [P.V. Shah, 703-308-1846]

INSTRUCTIONS: Please utilize this outline in preparing the pesticide petition. In 

cases where the outline element does not apply, please insert “NA-Remove” and 

maintain the outline. Please do not change the margins, font, or format in your 

pesticide petition. Simply replace the instructions that appear in green, i.e., “[insert 

company name],” with the information specific to your action.

TEMPLATE: 

 Bayer CropScience

[Insert petition number]

 EPA has received a pesticide petition (PP# 9E7580) from Bayer CropScience, 2 

T.W. Alexander Drive, P.O. Box 12014, Research Triangle Park, NC 27709

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 180.920.

(Options (pick one)

 1. by establishing a tolerance for residues of

 2. to establish an exemption from the requirement of a tolerance for α-isotridecylω-methoxy-poly(oxy-1,2-ethanediyl), CAS# 345642-79-7 when used as a surfactant in 

pesticide formulations in or on all raw agricultural commodities. 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. No plant metabolism studies have been submitted in 

support of this petition since an exemption from the requirement of a tolerance is 

being requested. 

 2. Analytical method. Since the petitioner is requesting a tolerance exemption, 
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an analytical method for residues of the inert in food crops is not required. 

 3. Magnitude of residues. There is no specific crop residue information is 

available for α-isotridecyl-ω-methoxy-poly(oxy-1,2-ethanediyl) and this information 

is typically not available nor required for the establishment of a tolerance exemption 

for inert ingredients.

B. Toxicological Profile

Toxicology data have been generated for α-isotridecyl-ω-methoxy-poly(oxy-1,2-

ethanediyl) and are representative for the commercial product. 

 1. Acute toxicity. α-isotridecyl-ω-methoxy-poly(oxy-1,2-ethanediyl) shows low 

toxicity (Cat. III) via oral and dermal routes of exposure but is considered irritating 

to skin and eyes, and a dermal sensitizer.

 2. Genotoxicty. No evidence of mutagenicity was observed with α-isotridecylω-methoxy-poly(oxy-1,2-ethanediyl) in two independent Ames assays under any of 

the test conditions. 

 3. Reproductive and developmental toxicity. The toxicity of α-isotridecyl-ωmethoxy-poly(oxy-1,2-ethanediyl) was assessed according to the OECD 422 study 

design. Wistar rats were exposed for 40 days to the test material in deionized water 

by oral gavage at 0, 45, 150, or 300 mg/kg/day. Reproductive performance and litter 

parameters were comparable among all dose groups. The reproductive and 

offspring No Observed Adverse Effect Level was 300 mg/kg/day. 

 4. Subchronic toxicity. The toxicity of α-isotridecyl-ω-methoxy-poly(oxy-1,2-

ethanediyl) was assessed according to the OECD 422 study design. Wistar rats were 

exposed for 40 days to the test material in deionized water by oral gavage at 0, 45, 

150, or 300 mg/kg/day. Clinical signs were observed at 150 and 300 mg/kg/day and 

consisted primarily of oral and urine staining and salivation. Body weight gain and 

food consumption were statistically reduced during the first week of treatment only 

for males at 300 mg/kg/day. No treatment-related changes were observed in clinical 

chemistry, hematology, or urinalysis parameters. Neurological evaluations showed 

findings attributable to treatment in females only at 150 and 300 mg/kg/day. In 

addition, females at 300 mg/kg/day exhibited a significantly lower body 

temperature. At necropsy, absolute and relative liver and adrenal weights were 

increased in females at 300 mg/kg/day. However, microscopic changes were not 

observed in either of these organs. Microscopic findings attributable to the test 

material were limited to the non-glandular epithelium of the stomach and consisted 

of epithelial hyperplasia in the majority of males and several females at 300 

mg/kg/day and in one female at 150 mg/kg/day. Other related microscopic findings 

at 300 mg/kg/day in the non-glandular epithelial included acanthosis, edema, 

hyperkeratosis and acute inflammation. The NOAEL for parental systemic toxicity 

was 45 mg/kg/day.

 5. Chronic toxicity. No chronic studies are available. 
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 6. Animal metabolism. All ethers undergo peroxidation via auto-oxidation 

mechanism by the addition of one molecule of oxygen. The normal ether peroxide 

undergoes spontaneous decomposition and the principal products are acid and 

alcohol. The oxidation takes place preferentially at the α-carbon. In the case of 

α-isotridecyl-ω-methoxy-poly(oxy-1,2-ethanediyl), the oxidation is very likely to take 

place preferentially at the methyl group. The methyl carbon is also at the α-position 

to the oxygen. Thus, the major oxidative product is anticipated to be the 

demethylated product. Accordingly, the primary metabolite of α-isotridecyl-ωmethoxy-poly(oxy-1,2-ethanediyl) (CAS# 345642-79-7) is anticipated to be αisotridecyl-ω-hydroxy-poly(oxy-1,2-ethanediyl) (CAS# 9043-30-5). 

in silico evaluation of the predicted mammalian metabolism of α-isotridecylω-methoxy-poly(oxy-1,2-ethanediyl), as provided by the Meteor program (Lhasa 

Ltd, UK) was conducted. Meteor program uses expert knowledge rules in 

metabolism to predict the metabolic fate of chemicals. Formation of α-isotridecyl-ωhydroxy-poly(oxy-1,2-ethanediyl) via oxidative O-demethylation being indicated as 

the first step of the biotransformation scheme. 

 7. Metabolite toxicology. The primary metabolite of α-isotridecyl-ω-methoxypoly(oxy-1,2-ethanediyl) (CAS# 345642-79-7) is anticipated to be α-isotridecyl-ωhydroxy-poly(oxy-1,2-ethanediyl) (CAS# 9043-30-5) which has been reassessed by 

the EPA as a part of the Joint Inerts Task Force Cluster Support Team Number 1 

and exempted from tolerance for pre- and post-harvest uses, application to animals, 

use in anti-microbial formulations (food surface sanitizing solutions) and polymers 

(Federal Register, Vol. 74, No. 149, August 5, 2009, pp. 38935-38944). Thus, the 

EPA has already reached the conclusion that Cluster 1 of alkyl alcohol alkoxylates, 

including α-isotridecyl-ω-hydroxy-poly(oxy-1,2-ethanediyl), will not cause harm to 

human health or the environment. 

 8. Endocrine disruption. Based on the information obtained during an OECD 

422 study with α-isotridecyl-ω-methoxy-poly(oxy-1,2-ethanediyl), there is no 

evidence of endocrine disruption by this compound when used as an inert ingredient 

in pesticide formulations. 

C. Aggregate Exposure

 1. Dietary exposure. The use pattern for α-isotridecyl-ω-methoxy-poly(oxy1,2-ethanediyl) is expected to result in exposure to the general population through 

food and drinking water. The NOAEL of 45 mg/kg/day from the OECD 422 study 

is selected as the point of departure for all risk assessments. Applying a 100X 

uncertainty factor for interspecies extrapolation and intraspecies variability, the 

cRfD is 0.45 mg/kg/day. 

 i. Food. In the absence of actual dietary exposure data, a chronic dietary 

exposure analysis was performed using EPA’s screening model for inert compounds 
4

(DEEM FCID Version 2.0, 1994-1996, 98 CSFII) assuming 100% crop treated for 

over 500 commodities (raw and processed) including livestock, milk and eggs, 

highest residue values used based on 57 active ingredients, and no adjustments for 

percentage of inert in formulations. 

 ii. Drinking water. The model used for assessing dietary exposure includes a 

worst case assumption of 0.1 ppm in water. 

 2. Non-dietary exposure. Residential uses are currently not considered.

D. Cumulative Effects

 No information is available indicating that α-isotridecyl-ω-methoxypoly(oxy-1,2-ethanediyl) has a common mechanism of toxicity with other 

substances. 

E. Safety Determination

 1. U.S. population. Using the assumptions and data described above, it is 

concluded that chronic dietary exposure to α-isotridecyl-ω-methoxy-poly(oxy-1,2-

ethanediyl) uses as inert ingredients in pesticide formulations will utilize at most 27 

% of the chronic PAD for the US Population. The actual exposure is likely to be 

much less as the calculations is based on very conservative assumptions. EPA 

generally has no concern for exposures below 100% of the PAD. Therefore, there is 

a reasonable certainty that no harm will occur to the US Population from aggregate 

exposure (food and drinking water) to residues of α-isotridecyl-ω-methoxypoly(oxy-1,2-ethanediyl) when used as an inert ingredient in pesticide formulations. 

 2. Infants and children. Based on this information obtained in an OECD 422 

study, there is no concern for increased sensitivity to infants and children to αisotridecyl-ω-methoxy-poly(oxy-1,2-ethanediyl). Therefore, an additional safety 

factor for the protection of infants and children is unnecessary. Using the 

assumptions and data described in the exposure section above, the percent of the 

chronic PAD that will be used for exposure to residues of α-isotridecyl-ω-methoxypoly(oxy-1,2-ethanediyl) in food and drinking water for Children 1-2 years old (the 

most highly exposed sub-population) is 94.1 %. Infants utilize 54.7 % of the chronic 

PAD. The actual exposure is likely to be much less as the calculations is based on 

very conservative assumptions. EPA generally has no concern for exposures below 

100% of the PAD. Therefore, there is a reasonable certainty that no harm will 

occur to infants and children from aggregate exposure to residues of α-isotridecylω-methoxy-poly(oxy-1,2-ethanediyl) when used as an inert ingredient in pesticide 

formulations. 

F. International Tolerances

 No international maximum residue limits (MRL) or CODEX tolerances are 

known to have been established for α-isotridecyl-ω-methoxy-poly(oxy-1,2-
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ethanediyl).