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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:

[Momentive Performance Materials]

[IN-10925]

	EPA has received a pesticide petition ([IN-10925]) from [Momentive
Performance Materials], [headquartered at 260 Hudson River Rd.,
Waterford, NY  12188] 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 180.860 to establish an exemption from the requirement
of a tolerance for [acrylic acid, butyl acrylate, styrene copolymer,
CAS# 25586-20-3, Mn 5200] in or on all raw agricultural commodities when
used as an inert ingredient as a sticker  / adjuvant 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.  [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

Acute toxicity. [EPA has established criteria which identify categories
of polymers that present low risk.  These criteria (listed at 40 CFR
723.250) identify properties which generally limit a polymer’s ability
to cause adverse toxicological effects.  No mammalian toxicity is
anticipated for polymers meeting the polymer exemption criteria.
Therefore we believe that establishment of an exemption from the
requirements of a tolerance is justified.  

Acrylic acid, butyl acrylate, styrene copolymer meets the definition of
a polymer given in 40 CFR 723.250(b) and meets the following criteria
that are used to identify low-risk polymers:

a. The polymer is not a cationic polymer nor is it reasonably
anticipated to become a cationic polymer in a natural aquatic
environment.

b. The polymer does contain as an integral part of its composition the
atomic elements carbon, hydrogen, and oxygen.

c. The polymer does not contain as an integral part of its composition,
except as impurities, any element other than those listed in 40 CFR
723.250(d)(2)(ii).

d. The polymer is neither designed nor can it be reasonably anticipated
to substantially degrade, decompose, or depolymerize.

e. The polymer is manufactured or imported from monomers and/or
reactants that are already included on the TSCA Chemical Substance
Inventory.

f. The polymer is not a water absorbing polymer with a number average
molecular weight (Mn) greater than or equal to 10,000 daltons. 

g. The polymer does not contain fluorine.

h. The polymer’s number average MW of 5200 is greater than 1,000 and
less than 10,000 daltons. The polymer contains less than 10% oligomeric
material below MW 500 and less than 25% oligomeric material below MW
1,000.  ]

	2. Genotoxicty. [NA-Remove based on the fact that this polymer meets
the 40 CFR 723.250 criteria that are used to identify low-risk
polymers.]

	3. Reproductive and developmental toxicity. [NA-Remove based on the
fact that this polymer meets the 40 CFR 723.250 criteria that are used
to identify low-risk polymers.]

	4. Subchronic toxicity. [NA-Remove based on the fact that this polymer
meets the 40 CFR 723.250 criteria that are used to identify low-risk
polymers.]

	5. Chronic toxicity. [NA-Remove based on the fact that this polymer
meets the 40 CFR 723.250 criteria that are used to identify low-risk
polymers.]

	6. Animal metabolism. [NA-Remove based on the fact that this polymer
meets the 40 CFR 723.250 criteria that are used to identify low-risk
polymers.]

	7. Metabolite toxicology. [NA-Remove based on the fact that this
polymer meets the 40 CFR 723.250 criteria that are used to identify
low-risk polymers.]

	8. Endocrine disruption. [NA-Remove based on the fact that this polymer
meets the 40 CFR 723.250 criteria that are used to identify low-risk
polymers.]

C. Aggregate Exposure

	1. Dietary exposure. [NA-Remove based on the fact that this polymer
meets the 40 CFR 723.250 criteria that are used to identify low-risk
polymers.]

	i. Food. [NA-Remove based on the fact that this polymer meets the 40
CFR 723.250 criteria that are used to identify low-risk polymers.]

	ii. Drinking water. [NA-Remove based on the fact that this polymer
meets the 40 CFR 723.250 criteria that are used to identify low-risk
polymers.]

	2. Non-dietary exposure. [NA-Remove based on the fact that this polymer
meets the 40 CFR 723.250 criteria that are used to identify low-risk
polymers.]

D. Cumulative Effects [NA-Remove based on the fact that this polymer
meets the 40 CFR 723.250 criteria that are used to identify low-risk
polymers.]

E. Safety Determination

	1. U.S. population. [NA-Remove based on the fact that this polymer
meets the 40 CFR 723.250 criteria that are used to identify low-risk
polymers.]

	2. Infants and children. [NA-Remove based on the fact that this polymer
meets the 40 CFR 723.250 criteria that are used to identify low-risk
polymers.]

F. International Tolerances

	[Momentive Performance Materials is not aware of any tolerances
assigned by any other countries.]

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