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EPA REGISTRATION DIVISION COMPANY NOTICE OF FILING FOR 

PESTICIDE PETITIONS PUBLISHED IN THE FEDERAL REGISTER 

EPA Registration Division contact: W. Cutchin 703-305-7990

TEMPLATE:

Huntsman Corp.

IN-10565

EPA has received a pesticide petition IN-10565 from Huntsman Corp., 8600 

Gosling Rd., The Woodlands, TX 77381 requesting, 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, to establish an exemption from the requirement of a tolerance for 

cumenesulfonic acid and its ammonium, calcium, magnesium, potassium, sodium 

and zinc salts with no limits used as surfactants, related adjuvants of surfactants on 

40 CFR 180.920 and 180.930 including the following with Chemical Abstracts 

Service Registry Numbers (CASRNs): benzenesulfonic acid, 4-(1-methylethyl)-, 

sodium salt (15763-76-5); benzenesulfonic acid, 4-(1-methylethyl)- (16066-35-6); 

benzenesulfonic acid, 4-(1-methylethyl)-, potassium salt (164524-02-1); 

benzenesulfonic acid, (1-methylethyl)-, potassium salt (28085-69-0); benzenesulfonic 

acid, (1-methylethyl)-, sodium salt (1:1) (28348-53-0); benzenesulfonic acid, 2(or 4)-

(1-methylethyl)- (28631-63-2); benzene, (1-methylethyl)-, monosulfo deriv., sodium 

salt (1:1) (32073-22-6); benzenesulfonic acid, (1-methylethyl)-, ammonium salt (1:1)

(37475-88-0); benzenesulfonic acid, (1-methylethyl)- (37953-05-2); benzenesulfonic 

acid, (1-methylethyl)-, magnesium salt (90959-88-9) in or on all the raw agricultural 

commodities. Prior to the submission of this petition to add cumenesulfonate 

CASRNs, the EPA reapproved toluenesulfonate and xylenesulfonate hydrotropes in 

Decision Documents dated 9/14/2006 and 6/30/2006. The combined documents are 

available at http://www.epa.gov/opprd001/inerts/xylenesulfonic.pdf. Huntsman is 

relying on the information in that combined Decision Document to support this 

petition which includes a chemistry that was also in the Screening Information Data 

Set (SIDS) Initial Assessment Report for Hydrotropes. The SIDS Hydrotropes 

category included toluenesulfonates, xylenesulfonates and cumenesulfonates. In 

fact, cumenesulfonate data was used to support the reassessment of the 

toluenesulfonates and xylenesulfonates in the EPA Decision Document. Huntsman

does not expect the addition of these cumenesulfonate CASRNs to result in 

additional exposure or risk, and no new data is being submitted with this petition.

EPA has determined that the petition contains data or information regarding the 

elements set forth in section 408 (d)(2) of FFDCA; however, EPA has not fully 
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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

2. Analytical method. NA

3. Magnitude of residues. NA

B. Toxicological Profile

1. Acute toxicity. Toxicity results are consistent across the toluene, xylene, and 

cumene sulfonates and their various salts. Acute Oral LD50 values in animals 

ranged from 1044 mg/kg bw (calcium xylene sulfonate) to 6500 mg/kg bw (sodium 

xylene sulfonate). The dermal LD50 in rabbits was >624 mg/kg bw (calcium xylene 

sulfonate), and the inhalation LC50 in rats was >557 mg/L (557 g/m

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sodium toluene

sulfonate). In a series of rabbit skin and eye irritation studies, sodium xylene

sulfonate, calcium xylene sulfonate, and sodium cumene sulfonate were not skin 

irritants and both calcium xylene sulfonate and sodium cumene sulfonate caused 

slight but reversible eye irritation. There was no skin sensitization observed in 

animal studies.

2. Genotoxicty. The hydrotropes category was assessed for

mutagenic/genotoxic potential in a variety of assays including the mouse 

micronucleus, Ames, mouse lymphoma, sister chromatid exchange, and

chromosome aberration assays. No positive results were seen in vitro or in vivo in 

any of the studies. For both mice and rats dermally exposed for two years, there 

was no evidence of a carcinogenic potential.

3. Reproductive and developmental toxicity. There are no reproductive toxicity

studies noted for this category of chemicals, however, after examination of the sex 

organs (such as the prostate, testes, and ovaries) from the animals in the 91- and 90-

day oral feeding studies and 90-day and two year dermal studies yielded no evidence 

to suggest that these chemicals would have an adverse effect on the reproductive 

organs. In a developmental toxicity study in rats, calcium xylene sulfonate (31% 

a.i.) was administered via gavage to female rats at 0, 150, 1500, or 3000 mg/kg 

bw/day in water days 6-15 of gestation. No treatment related effects were observed 

and there was no evidence of developmental toxicity. The NOAEL for maternal and 

fetal toxicity was 3000 mg/kg bw/day, corresponding to 936 mg a.i./kg bw/day (the 

highest dose tested).

4. Subchronic toxicity. Thirteen oral and dermal repeat-dose (subchronic and

chronic) studies were conducted in rats or mice. Doses ranged from 6 to 2000 mg/kg 

bw/day dermally and from 1.1 up to 4092 mg/kg bw/day orally. Test durations 

ranged from 17 days to two years. No significant systemic toxicity was noted in the 
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dermal studies with local effects (NOAEL 400 mg/kg bw/day, LOAEL 1300 mg/kg 

bw/day (epidermal hyperplasia)) noted in one of the six studies. In regard to the 

results of the oral studies, it was determined that the most appropriate NOAEL for 

systemic toxicity was 763 mg/kg bw/day based on a reduction in relative spleen 

weight in female rats.

5. Chronic toxicity. Included with Subchronic in B4 above.

6. Animal metabolism. The hydrotrope chemicals do not appear to produce 

toxic metabolites produced by other substances.

7. Metabolite toxicology. The hydrotrope chemicals do not appear to produce 

toxic metabolites produced by other substances.

8. Endocrine disruption. FQPA requires EPA to develop a screening program 

to determine whether certain substances, including all pesticide chemicals (both 

inert and active ingredients), "may have an effect in humans that is similar to an 

effect produced by a naturally occurring estrogen, or such other endocrine effect..." 

EPA has been working with interested stakeholders to develop a screening and 

testing program as well as a priority setting scheme. As the Agency proceeds with 

implementation of this program, further testing of products containing hydrotrope 

chemicals for endocrine effects may be required.

C. Aggregate Exposure

1. Dietary exposure. In examining aggregate exposure, the Federal Food, 

Drug, and Cosmetic Act (FFDCA) section 408 directs EPA to consider available 

information concerning exposures from the pesticide residue in food and all other 

nonoccupational exposures, including drinking water from ground water or surface

water and exposure through pesticide use in gardens, lawns, or buildings 

(residential and other indoor uses). For these chemicals, a qualitative assessment 

for all pathways of human exposure (food, drinking water, and residential) is 

appropriate given the use limitations and lack of human health concerns associated 

with exposure to these substances when used as inert ingredients in pesticide 

formulations.

i. Food. Dietary (food and drinking water) and residential (dermal and 

inhalation) exposures are possible from the use of these chemicals as inert 

ingredients in pesticide products. Based on the SIDS conclusions for the 

hydrotropes category; cumenesulfonic acid and its ammonium, calcium, 

magnesium, potassium, sodium, and zinc salts (as defined above) are also predicted 

to be readily biodegradable according to OECD criteria, which will reduce the 

likelihood of residues on food.

ii. Drinking water. For the same reason, significant contributions to drinking 

water are not anticipated from the use of these chemicals as inert ingredients in 

pesticide products applied to growing crops only or animals. These chemicals have 
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low toxicity, and exposure to residues above toxicity levels of concern is not 

anticipated.

2. Non-dietary exposure. These chemicals have low toxicity, and exposure to 

residues above toxicity levels of concern is not anticipated.

D. Cumulative Effects

Unlike other pesticides for which EPA has followed a cumulative risk 

approach based on a common mechanism of toxicity, EPA has not made a common 

mechanism of toxicity finding as to the chemistries in the SIDS Hydrotrope category 

and any other substances. The hydrotrope chemicals do not appear to produce 

toxic metabolites produced by other substances. For the purposes of the hydrotrope 

decision document tolerance action, therefore, EPA has not assumed that these 

chemicals have a common mechanism of toxicity with other substances.

E. Safety Determination

1. U.S. population. Taking into consideration available toxicity and exposure 

information, the Agency determined in the decision document that there is a 

reasonable certainty that no harm to any population subgroup will result from 

aggregate exposure (dietary and non-occupational sources of exposure) to any of the 

hydrotrope chemistries including cumenesulfonic acid and its ammonium, calcium, 

magnesium, potassium, sodium, and zinc salts (as defined above) when used as inert 

ingredients in pesticide formulations applied to growing crops only or to animals.

2. Infants and children. As covered in the hydrotrope decision document and 

SIDS Assessment, no treatment related effects were observed and there was no 

evidence of developmental toxicity. In a developmental toxicity study in rats, 

calcium xylene sulfonate (31% a.i.) was administered via gavage to female rats at 0, 

150, 1500, or 3000 mg/kg bw/day in water days 6-15 of gestation. The NOAEL for 

maternal and fetal toxicity was 3000 mg/kg bw/day, corresponding to 936 mg a.i./kg 

bw/day (the highest dose tested). Based on this information, there is no concern, at 

this time, for increased sensitivity to infants and children to any of the hydrotrope 

chemistries including cumenesulfonic acid and its ammonium, calcium, magnesium, 

potassium, sodium, and zinc salts when used as inert ingredients applied to growing 

crops only or to animals.

F. International Tolerances

There are no known international tolerances for Cumenesulfonic acid or its 

salts.