United States Environmental Protection Agency Washington, DC 20460
Section 4 Submission This is an original submission: This is an amendment: CERTIFICATION I hereby certify to the best of my knowledge and belief that (1) all information entered on this form is complete and accurate; and (2) any confidentiality claims are true and correct as to that information for which they have been asserted. Any knowing and willful misinterpretation is subject to criminal penalty pursuant to 18 USC 1001. Signature: Official Title: Customs and Forwarding Manager Contact Person: Jesse E. Garcia Email Address: jesse.garcia@wilhelmsen.com Date Signed: 02/01/2016 PART 1 Contact Information Submission Information Submission Type:

TestRules Form Alias: TestRules-20160112-06:09:12 EST Federal Register Notice: 76 FR 1067 Date Submitted: 02/01/2016 Submitter Information Company Name:

Wilhelmsen Ships Service Address: 9400 New Century Dr. Pasadena, TX, 77507 United States Contact Person: Jesse E. Garcia Phone Number: 2818672050 Email Address: jesse.garcia@wilhelmsen.com Technical Contact Information CBI

Yes: No: Company Name: Wilhelmsen Ships Service Address: 9400 New Century Dr. Pasadena, TX, 77507 United States Contact Person: Mr Harry Muller Phone Number: 4844329326 Email Address: harry.muller@wilhelmsen.com PART 2 Letter Of IntentSEC4 Submission Page 2

Chemical Identification CASRN:

144-62-7 CBI Yes: No:
Chemical Name: Ethanedioic acid Chemical Test Name: A1 Sponsoring Firms CBI

Yes: No: Company Name: wilhelmsen ships service inc. Address: 9400 new century dr. pasadena, TX, 77530 United States Phone Number: 2818672050 Additional Information Document Type:

Exemption Application File Name: N/A Attachment Date: 02/01/2016 Exemption Sought on following Testing requirement(s): Determination of Vapor Pressure. Determination of General Physico-Chemical Properties. Algal Growth Inhibition Test. Chromosome Aberration Test in Human Lympocytes In Vitro. Acute Toxicity to Rainbow Trout.SEC4 Submission Page 3

Provide the basis for the exemption request: Document Control Office (DCO) (7407M), Office of Pollution Prevention and Toxics (OPPT), Environmental Protection Agency, 1200 Pennsylvania Ave., NW., Washington, DC 20460-0001 ATIN: TSCA Section 4--Docket EPA-HQ-OPPT-2007-0531 Re: Application for Exemption, Section 4 Test Rule, Oxalic Acid Dihydrate [CASRN 144-62-7], Testing of Certain High Production Volume Chemicals; Second Group of Chemicals, Federal Register, Vol. 76, No. 5, January 7, 2011, 40 CFR 799 .5087
Dear Sirs: Wilehmsen Ships Services (Wilhelmsen) submits this application for exemption from the requirements of testing Oxalic Acid Dihydrate [CASRN 144-62-7] under the applicable TSCA Section 4 Test Rule noted above. As part of the Wilhelmsen exemption application, the following information is provided: The identity of the test rule, chemical name, and CASRN of the test substances on which the application is based: Testing of Certain High Production Volume Chemicals; Second Group of Chemicals, Federal Register, Vol .76, No. 5, January 7, 2011, 40 CFR 799.5087 Oxalic Acid Dihydrate [CASRN 144-62-7] Wilhelmsen is requesting an exemption from all testing requirements for Oxalic Acid Dihydrate [CASRN 144-62-7] under 40 CFR 799.5087 because Univar USA Inc. and WEGO Chemical and Mineral Corporation have already conducted all of the required testing. Name, address, and phone number of applicant:SEC4 Submission Page 4

Wilhelmsen Ship Services 9400 New Century Drive Pasadena, TX 77507 United States phone 281-867-2000 Name, address, phone number of contact individual: Jesse Garcia Licensed Customs Broker 9400 New Century Drive Pasadena, TX 77507 United States phone	281-867-2050 As per 40 CFR 790.99, Wilhelmsen provides the following statement of financial responsibility per this application for exemption: I, representing Wilhelmsen Ships Service, understand that if this application is granted before the reimbursement period described in section 4(c)(3)(8) of TSCA expires, Wilhelmsen, must pay fair and equitable reimbursement to the person or persons who incurred or shared in the costs of complying with the requirement to submit data and upon whose data the granting of the Wilhelmsen application is based. If you have any further questions, please contact me.
Jesse Garcia Chemicals Paperwork Reduction Act:The Government Paperwork Elimination Act (GPEA) (44 U.S.C. 3501) provides that, when practicable, Federal organizations use electronic forms, electronic filings, and electronic signatures to conduct official business with the public. EPA's Cross-Media Electronic Reporting Regulation (CROMERR) (40 CFR part 3), published in the Federal Register on October 13, 2005 (70 FR 59848) (FRL-7977-1)(Ref. 2), provides that any requirement in title 40 of the Code of Federal Regulations (CFR) to submit a report directly to EPA can be satisfied with an electronic submission that meets certain conditions once the Agency published a notice in the Federal Register announcing that EPA is prepared to receive certain documents in electronic form. For more information about CROMERR, go to http://www.epa.gov/cromerr/

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