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EPA REGISTRATION DIVISION COMPANY NOTICE OF FILING FOR 

PESTICIDE PETITIONS PUBLISHED IN THE FEDERAL REGISTER 

EPA Registration Division contact: [PV 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: 

[Rhodia, Inc.]

[0E7692]

 EPA has received a pesticide petition ([0E7692]) from [Rhodia, Inc. c/o SciReg, 

Inc.], [12733 Director’s Loop, Woodbridge, VA 22192] 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.

(Options (pick one)

 1. by establishing a tolerance for residues of 

 2. to establish an exemption from the requirement of a tolerance for

 [castor oil, ethoxylated, oleate (CAS No. 220037-02-5) with a minimum 

number average molecular weight (in amu) of 1,200 under 40 CFR 180.960 when 

used as an emulsifier and surfactant 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.

 2. Analytical method. [Rhodia is requesting that castor oil, ethoxylated, oleate, 

with a minimum number average molecular weight (in amu) of 1,200 be exempt 

from the requirement of a tolerance based upon the definition of a low-risk polymer 
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under 40 CFR 723.250. Therefore, Rhodia believes that an analytical method to 

determine residues in treated crops is not relevant.]

 3. Magnitude of residues. [Rhodia is requesting that castor oil, ethoxylated, 

oleate, with a minimum number average molecular weight (in amu) of 1,200 be 

exempt from the requirement of a tolerance based upon the definition of a low-risk 

polymer under 40 CFR 723.250. Therefore, Rhodia believes that data on the 

magnitude of residues in 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 castor oil, ethoxylated, oleate, meets the 

definition of a low risk polymer under 40 CFR 723.250. 

1. Castor oil, ethoxylated, oleate is a polymer molecule as defined by 40 CFR 

723.250(b). That is, it contains a sequence of at least 3 monomer units which are 

covalently bound to at least one other monomer unit or other reactant. 

2. Castor oil, ethoxylated, oleate consists of a number average molecular weight 

greater than 1,000 and less than 10,000 daltons. Its oligomer content is less than 10 

percent below molecular weight 500 and less than 25 percent below molecular 

weight 1,000. 

3. Castor oil, ethoxylated, oleate is not a cationic polymer and is not anticipated 

to become a cationic polymer in a natural aquatic environment. As an example, 

there is no amino functionality present which might under certain circumstances 

become a positively charged ammonium ion. The only functional groups present in 

the subject polymer are carboxylic ester and aliphatic ether linkages which will not 

become positively charged. 

4. Castor oil, ethoxylated, oleate has the properties of a nonionic surfactant and 

only contains the elements carbon, hydrogen, and oxygen; therefore, it meets the 

criteria for elemental composition. No compounds which contain prohibited 

elements are used in the manufacture of this polymer. 

5. Castor oil ethoxylates and their derivatives are not readily biodegradable. 

Castor oil, ethoxylated, oleate is not designed to substantially degrade, decompose, 

or depolymerize in the environment. 

6. All monomers and reactants which are used in the production of castor oil, 

ethoxylated, oleate are listed on the TSCA Chemical Substance Inventory. 

7. Castor oil, ethoxylated, oleate is not a water-absorbing polymer with a 

number average molecular weight above 10,000 daltons, but is dispersible in water 
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due to its properties as a nonionic surfactant. 

8. Castor oil, ethoxylated, oleate contains no reactive functional groups that fail 

to meet the low-risk polymer exemption criteria under 40 CFR 723.250(e).]

 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 of castor oil, 

ethoxylated, oleate lead to the conclusion that there is a reasonable certainty 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 castor 

oil, ethoxylated, oleate lead to the conclusion that there is a reasonable certainty of 

no harm from exposure to the polymer through non-dietary means.]

D. Cumulative Effects

 [Castor oil, ethoxylated, oleate 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. [Castor oil, ethoxylated, oleate meets all the criteria for 

qualification of 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.]
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 2. Infants and children. [Castor oil, ethoxylated, oleate is a low-risk polymer. 

No adverse effects are expected from use of this inert ingredient in pesticide 

formulations. 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

 [Castor oil, ethoxylated, oleate, with a minimum number average molecular 

weight (in amu) of 2,000, is currently exempt from the requirement of a tolerance 

(40 CFR 180.960).]