


EPA REGISTRATION DIVISION COMPANY NOTICE OF FILING FOR PESTICIDE PETITIONS PUBLISHED IN THE FEDERAL REGISTER  

EPA Registration Division contact: [Dr. 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

[Joint Inerts Task Force, Cluster Support Team 8 (JITF CST8)]

[2E8087]

	EPA has received a pesticide petition [2E8087]
from [Joint Inerts Task Force, Cluster Support Team 8, EPA Company Number 84942], [c/o Huntsman Corp., 8600 Gosling Rd., The Woodlands, TX  77381] 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.

To amend existing exemptions from the requirement of a tolerance [ by adding Chemical Abstracts Service Registry Numbers (CASRNs) for pre-harvest use on agricultural crops under 40 CFR §180.920 and when applied to animals under 40 CFR §180.930 for the following two chemistry descriptors that are used as surfactants: 1: dimethylaminopropylamine, isopropylamine, ethanolamine, and triethanolamine salts of alkyl (C8-C24) benzenesulfonic acid (without limits): 

                                     CASRN
Dimethylaminopropylamine, isopropylamine, ethanolamine, and triethanolamine salts of alkyl (C8-C24) benzenesulfonic acid
                                  12068-12-1
Benzenesulfonic acid, dodecyl-, compd. with N,N-dimethyl-1,3-propanediamine (1:1)
                                  121617-08-1
Benzenesulfonic acid, 4-C10-13-sec-alkyl derivs., compds. with triethanolamine 
                                  193562-36-6
  Benzenesulfonic acid, C16-24-alkyl derivs., compds. with ethanolamine (1:1)
                                  26836-07-7
       Benzenesulfonic acid, dodecyl-, compd. with 2-aminoethanol (1:1)
                                   3088-30-0
p-dodecylbenzenesulphonic acid, compound with 2,2',2''-nitrilotriethanol (1:1)
                                  58089-99-9
      Benzenesulfonic acid, 4-dodecyl-, compd. with 2-aminoethanol (1:1)
                                  61886-59-7
Benzenesulfonic acid, tridecyl-, compd. with 2,2',2''-nitrilotris[ethanol] (1:1)
                                  61931-76-8
Benzenesulfonic acid, undecyl-, compd. with 2,2',2''-nitrilotris[ethanol] (1:1)
                                  67924-05-4
Benzenesulfonic acid, 4-dodecyl-, compd. with 2,2',2''-nitrilotris[ethanol] homopolymer
                                  68110-32-7
      Benzenesulfonic acid, 3-dodecyl-, compd. with 2-aminoethanol (1:1)
                                  68259-35-8
        Benzenesulfonic acid, undecyl-, compd. with 2-propanamine (1:1)
                                  68442-72-8
      Benzenesulfonic acid, dodecyl-, reaction products with ethanolamine
                                  68567-69-1
Benzenesulfonic acid, 4-sec-dodecyl-, compd. with 2,2',2''-nitrilotris[ethanol] (1:1)
                                  68815-30-5
     Benzenesulfonic acid, decyl-, branched, compds. with triethanolamine
                                  68815-35-0
   Benzenesulfonic acid, tetradecyl-, branched, compds. with triethanolamine
                                  68953-98-0
      Benzenesulfonic acid, dodecyl-, branched, compds. with ethanolamine
                                  70528-84-6
    Benzenesulfonic acid, dodecyl-, branched, compds. with triethanolamine 
                                  72391-21-0
Benzenesulfonic acid, 4-[2,4,4-trimethyl-1-(2-methylpropyl)pentyl]-, compd. with 2-aminoethanol (1:1)
                                  84961-74-0
 Benzenesulfonic acid, 4-C10-13-sec-alkyl derivs., compds. with 2-propanamine
                                  85480-55-3
  Benzenesulfonic acid, mono-C10-13-alkyl derivs., compds. with ethanolamine
                                  85480-56-4
 Benzenesulfonic acid, mono-C10-13-alkyl derivs., compds. with triethanolamine
                                  85995-82-0
    Benzenesulfonic acid, 4-C10-14-alkyl derivs., compds. with ethanolamine
                                  90194-54-0
Benzenesulfonic acid, mono-C10-13-branched alkyl derivs., compds. with 2-propanamine
                                  90194-55-1
Benzenesulfonic acid, mono-C10-13-branched alkyl derivs., compds. with triethanolamine 
                                  90218-09-0
Benzenesulfonic acid, mono-C8-24-branched and linear alkyl derivs., compds. with ethanolamine
                                  90218-11-4
Benzenesulfonic acid, mono-C16-24-branched and linear alkyl derivs., compds. with 2-propanamine 
                                  96687-54-6
tetrapropylenebenzenesulphonic acid, compound with 2,2',2''-nitrilotriethanol (1:1)
                                  99924-49-9
  Benzenesulfonic acid, mono-C10-14-alkyl derivs., compds. with ethanolamine

and 2: diethanolamine salts of alkyl (C8-C24) benzenesulfonic acid (Not to exceed 7% of pesticide formulation): 

                                     CASRN
          Diethanolamine salts of alkyl (C8-C24) benzenesulfonic acid
                                  67815-95-6
  Benzenesulfonic acid, 4-dodecyl-, compd. with 2,2'-iminobis[ethanol] (1:1)
                                  67889-94-5
  Benzenesulfonic acid, isoundecyl-, compd. with 2,2'-iminobis[ethanol] (1:1)
                                  67889-95-6
   Benzenesulfonic acid, isodecyl-, compd. with 2,2'-iminobis[ethanol] (1:1)
                                  68259-34-7
   Benzenesulfonic acid, undecyl-, compd. with 2,2'-iminobis[ethanol] (1:1)
                                  68478-47-7
     Benzenesulfonic acid, dodecyl-, reaction products with diethanolamine
                                  68567-68-0
Benzenesulfonic acid, 4-sec-dodecyl-, compd. with 2,2'-iminobis[ethanol] (1:1)
                                  68815-34-9
   Benzenesulfonic acid, tetradecyl-, branched, compds. with diethanolamine
                                  68815-37-2
    Benzenesulfonic acid, tridecyl-, branched, compds. with diethanolamine
                                  68891-02-1
 Benzenesulfonic acid, mono-C10-16-alkyl derivs., compds. with diethanolamine
                                  84989-15-1
Benzenesulfonic acid, 4-C10-13-sec-alkyl derivs., compds. with diethanolamine 
                                  85338-09-6
  Benzenesulfonic acid, 4-C10-14-alkyl derivs., compds. with diethanolamine 
                                  90194-39-1
 Benzenesulfonic acid, mono-C10-13-alkyl derivs., compds. with diethanolamine 
                                  90194-40-4
 Benzenesulfonic acid, mono-C10-14-alkyl derivs., compds. with diethanolamine
                                  90218-08-9
Benzenesulfonic acid, mono-C8-24-branched and linear alkyl derivs., compds. with diethanolamine

in or on all the raw agricultural commodities.  Prior to the submission of this petition to add missing CASRNs, Pesticide Petition 8E7472 (Document ID EPA-HQ-OPP-2008-0889) was submitted to the Agency and these CASRNs were missing from the petition.  JITF CST8 is relying on the information submitted in 8E7472 to support this petition which includes the exact same chemistry of Alkylbenzene Sulfonates.  JITF CST8 does not expect the addition of these CASRNs to result in additional exposure or risk.  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 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 based on the fact that this information is not required for the establishment of a tolerance exemption.]

	2. Analytical method. [NA-Remove based on the fact that this information is not required for the establishment of a tolerance exemption.]

	3. Magnitude of residues. [NA-Remove based on the fact that this information is not required for the establishment of a tolerance exemption.]

B. Toxicological Profile

      1. Acute toxicity.  [Published data indicate that the parent acid of Alkylbenzene Sulfonates is not highly acutely toxic (EPA Categories III-IV), is irritating to the eye and skin, and is a weak-moderate skin sensitizer and that the parent amine counter ions are acute toxicity EPA category II-IV. Dermal toxicity EPA Category II.]

	2. Genotoxicty. [Both in vitro and in vivo genotoxicity data show that Alkylbenzene Sulfonates are not toxic to the gene or the chromosome. The Amine counter ions are also not mutagenic.]

      3. Reproductive and developmental toxicity. [One representative compound for the group of chemicals requested in 8E7472 (and 2E8087) is CASRN 26264-05-1, the isopropylamine salt of dodecylbenzenesulfonic acid.  OECD 422 testing for CASRN 26264-05-1 indicates no reproductive effects and no evidence of malformations in the developing offspring. The NOEL for reproduction and developmental toxicity was 320 mg/kg/day, the highest dose tested.]
      
      4. Subchronic toxicity. [No compound specific subchronic toxicology data are available for these Alkylbenzene Sulfonates.  Additionally, a search of the public literature did not reveal any available data. However following repeated oral administration in an OECD 422 Combined Repeated Dose Toxicity Study with a Reproduction/Developmental Toxicity Screening Test (i.e., at least 42 days in male rats and approximately 42-44 days in female rats) for CASRN 26264-05-1, a systemic NOAEL of 80 mg/kg/day was identified, and a NOEL for reproduction and developmental toxicity was 320 mg/kg/day, the highest dose tested.]

	5. Chronic toxicity [Data reviewed by EPA for Alkylbenzene Sulfonates indicate that they are not likely to be carcinogenic.]

	6. Animal metabolism. [The amine salts of alkyl (C8-C24) benzenesulfonic acid rapidly dissociate in vivo aqueous solutions to form an alkyl (C8-C24) benzenesulfonic acid and a counter ion amine (dimethylaminopropylamine, isopropylamine, mono- , di- , and triethanolamine). The two entities would be absorbed and metabolized independently. The alkyl (C8-C24) benzenesulfonic acid should be readily conjugated and rapidly excreted with very little alkyl aromatic chain degradation (EPA, 2006). The amine counter ions should undergo either: primary, secondary, or tertiary amine metabolism, followed by excretion (Bury, 1998).]

	7. Metabolite toxicology. [No metabolites of toxicological concern are expected based on the proposed animal metabolic pathway.]

	8. Endocrine disruption. [The [amine salts of alkyl (C8-C24) benzenesulfonic acid (dimethylaminopropylamine, isopropylamine, mono- , di- , and triethanolamine) , additionally alkyl (C8-C24) benzene sulfonic acids and the amines supported by CST8, do not belong to a class of chemicals known or suspected of having adverse effects on the estrogen receptor or endocrine system.  An amine salt, CASRN 26264-05-1: Benzenesulfonic acid, dodecyl-, compound with 2-propanamine (1:1) of alkyl (C8-C24) benzenesulfonic acid and amines have been evaluated in acute, subchronic, developmental and reproductive studies capable of detecting effects on endocrine mediated events.]

C. Aggregate Exposure

	1. Dietary exposure. [An assessment based on the EPA Inert's Branch screening-level dietary exposure model I-DEEM was provided in the previously submitted Petition PP 8E7472 (Document ID EPA-HQ-OPP-2008-0889).  I-DEEM uses a screening level dietary assessment of 57 of the most "significant" active ingredients as surrogates for inerts within the Dietary Exposure Evaluation Model software with the Food Commodity Intake Database (DEEM-FCID(TM), Version 2.14).  Exposure from food, animal commodities and drinking water are covered.  Children 1-2 years old are found to be the most highly exposed subpopulation, with an estimated exposure of 0.425 mg/kg/day for drinking water and food.  Formulated products are assumed to consist of 50% inert ingredients, and I-DEEM exposures can be scaled based on proposed limits in specific formulations.  

Based on the low acute toxicity, no acute reference dose is established.  The JITF recommends that the FQPA safety factor can be reduced from 10X to 1X (see below). Based on a NOAEL of 80 mg/kg bw/day from the OECD 422 study with UF=100, a cRfD of 0.8 mg/kg/day = cPAD (chronic population adjusted dose) is proposed.  The CST8 supported amine salts of alkyl (C8-C24) benzenesulfonic acids (dimethylaminopropylamine, isopropylamine, mono- , di- , and triethanolamine) are used primarily as surfactants in a variety of pesticide product formulations typically used in agriculture, but they are not typically formulated in pesticide products intended for use near residences.  In agricultural products, these compounds are included in formulated products at levels significantly lower than the 50% assumed by the I-DEEM screening level default model.  Estimated dietary (food plus drinking water) exposures account for 15.3% of the proposed chronic reference dose for the general population and 53.1% for the most exposed population, children aged 1-2 years.
Thus, since less than the full chronic reference dose is used by dietary exposure, there is additional room that is deemed adequate to cover any other aggregate exposures from non-dietary pre-harvest and animal uses.  The JITF CST8 thus asserts that the [amine salts of alkyl (C8-C24) benzenesulfonic acid (dimethylaminopropylamine, isopropylamine, mono- , di- , and triethanolamine) s, as described in FR Notice Vol. 71 No. 153 p. 45422 § 180.920 [Amended], k and p. 45422-3 § 180.930 [Amended], f are supported by the published alkyl (C8-C24) benzenesulfonic acid and amines (dimethylaminopropylamine, isopropylamine, mono- , di- , and triethanolamine) toxicology, other data  and newly conducted CASRN 26264-05-1 OECD 422 study data and risk assessment.

CHRONIC DIETARY SAFETY ASSESSMENT, % CPAD

                                     Study
                           Chronic Systemic NOAEL 1
                                 mg/kg bw/day
                                    cPAD 2
                                 mg/kg bw/day 
                                 Percent cPAD 
                           Children 1-2 years of age
                                 Percent cPAD 
                              U.S. Gen Population
OECD 422 Combined Repeated Dose Toxicity Study with a Reproduction/Developmental Toxicity Screening Test in Rats - CASRN 26264-05-1.
                                      80
                                      0.8
                                      53%
                                      15%
 Note:
 [1] NOAEL  -  No observed adverse effect level
 [2] cPAD  -  Chronic population adjusted dose, defined as:  chronic NOAEL / (safety factor  FQPA factor)]

	i. Food. [The dietary (food plus drinking water) exposures for Alkylbenzene Sulfonates are expressed as a percentage of the proposed cPAD. Chronic Safety Assessment, % cPAD for the general U.S. population and children 1-2 years old, the subpopulation with the highest potential exposures.  Based on I-DEEM screening level calculations, the chronic dietary exposures are estimated to be 15% of the proposed cPAD for the general U.S. population and 53% of the cPAD for children 1-2 years old.  These data demonstrate that the I-DEEM screening-level chronic dietary (food and drinking water) exposures are below the cPAD and are therefore below EPA's established level of concern for all U.S. subpopulations.]

	ii. Drinking water. [Drinking water is included in the I-DEEM exposure assessment.]

	2. Non-dietary exposure. [Amine salts of alkyl (C8-C24) benzenesulfonic acid (dimethylaminopropylamine, isopropylamine, mono- , di- , and triethanolamine) are used primarily as surfactants in pesticide formulations in 40 CFR §180.920 pre- harvest applications to raw agricultural commodities and 40 CFR §180.930 animal applications.]  

D. Cumulative Effects 

      [For the compounds included in CST8, EPA has not made a common mechanism finding. It is therefore appropriate to consider only the potential risks of the compounds included in CST8 in the exposure assessment.] 

E. Safety Determination

	1. U.S. population. [The JITF CST8 conducted a risk assessment using current EPA I-DEEM methodology. The results of the risk assessment were acceptable exposures for the use of CST8 compounds.  Based on the chronic dietary exposure assessment, the cPADs calculated for the U.S. population were 15% (chronic).]

	2. Infants and children. [The FFDCA Section 408 requires an additional tenfold margin of safety for the protection of infants and children in case of threshold effects to account for prenatal and postnatal toxicity, and an inadequate toxicity database.  Where an adequate and reliable database is available and there is a lack of evidence for increased susceptibility, the FQPA safety factor may be reduced or removed.  

An evaluation of susceptibility and uncertainty issues associated with the use of amine salts of alkyl (C8-C24) benzenesulfonic acid (dimethylaminopropylamine, isopropylamine, mono- , di- , and triethanolamine) in pesticide formulations has been performed, and the JITF CST8 recommends that the FQPA safety factor be reduced to 1X for the following reasons: 

*       The availability of a substantial and scientifically sound mammalian toxicology database that includes acute, subchronic, mutagenicity, reproduction, and developmental toxicity data for the amine counter ions comprising CST8 supported surfactants.
*       OECD 422 testing for CASRN 26264-05-1 indicates no reproductive effects and no evidence of malformations in the developing offspring 
*       There was no evidence of effects on the nervous system in the acute, subacute or reproduction studies for the amine counter ions comprising CST8 supported compounds
*       There is no evidence of endocrine disruption for CASRN 26264-05-1 and for the amine counter ions comprising CST8 supported compounds.]

F. International Tolerances
	[There are no known international tolerances for amine salts of alkyl (C8-C24) benzenesulfonic acid (dimethylaminopropylamine, isopropylamine, mono- , di-, and triethanolamine).]
