July 10, 2014 

By Chemical Information Submission System 

Document Control Office (DCO) (7407M) 

Office of Pollution Prevention and Toxics (OPPT) 

U.S. Environmental Protection Agency (EPA) 

1200 Pennsylvania A venue, NW 

Washington, D.C. 20460-0001 

Attention: TSCA Section 4 

40 C.F.R. § 799.5089 (Docket No. EPA-HQ-OPPT-2009-0112) 

Re: Application for Exemption from Testing 

Test Rule: 40 C.F.R. § 799.5089 (Docket No. EPA-HQ-OPPT -2009-0112) 

Test Substance: Benzene, 1-chloro-4-(trifluoromethyl)-, Chemical Abstracts 

Service Registry Number 98-56-6 

Dear Sir or Madam: 

The Chemical Company ("TCC) hereby requests an exemption from all testing of 

benzene, 1-chloro-4-(trifluoromethyl)-, Chemical Abstracts Service Registry Number 

("CASRN") 98-56-6 ("PCBTF"), under the TSCA § 4 test rule for PCBTF codified at 40 

C.F.R. § 799.5089. The basis for TCC's exemption request is as follows. 

TCC imports PCBTF in small quantities for commercial distribution within the United 

States. TCC projects its imports of PCBTF in 2014 and in future years to be less than 

one percent(< 1 %) of the 28,964,014 pounds of domestic production reported for 

calendar year 2011 under the 2012 Chemical Data Reporting Rule. 1 

By letter dated April18, 2013 from Greenwich Chemical Consulting, Inc., the PCBTF 

Testing Consortium has submitted to EPA all ofthe testing from which ICC seeks an 

Chemical Data Access Tool (CDAT), U.S. ENVTL. PROT. A GENCY, 

http://java.epa.gov/oppt chemical search/ (last visited July 8, 2014) (for CASRN 98-56-6, the "National 

Production Volume for Chemical" is "28,964,014 lb/yr."). 

The Chemical Company • 44 Southwest Ave. Jamestown, RI 02835 • 401.423.3100 

www.thechemco.com 
exemption? Therefore, TCC's submission of the required test data for PCBTF would 

duplicate the data that the PCBTF Testing Consortium already has submitted to EPA 

under 40 C.F.R. § 799.5089. In addition, EPA does not require TCC to demonstrate that 

its imported PCBTF is equivalent to the PCBTF tested by the PCBTF Testing 

Consortium.3 For these reasons, TCC's exemption application satisfies the requirements 

for conditional approval by EP A.4 

Lastly, TCC understands that if this application is granted before the reimbursement 

period described in section 4(c)(3)(B) ofTSCA expires, TCC 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 ofTCC's 

application was based. 

Please address any questions about this exemption application to the undersigned. TCC 

appreciates EPA's consideration of this application. 

I 

\ 

Robert N. Roach, III 

President 

THE CHEMICAL COMPANY 

44 Southwest A venue 

Jamestown, Rhode Island 02835 

Phone: (401) 360-2800 

Email: Robb@thechemco.com 

RR:mb 

See also Toxic Substances Control Act Chemical Testing; Receipt ofTest Data, 78 Fed. Reg. 66,700, 

66,703 (Nov. 6, 201 3), available at http://www.gpo.gov/fdsys/pkg/FR-2013-Il-06/pdf/2013-26644.pdf. 3 Testing of Certain High Production Volume Chemicals; Third Group of Chemicals, 76 Fed. Reg. 

65,385, 65,396 (Oct. 21, 20 11) ("In this final rule, EPA will not require the submission of equivalence data 

(i.e., data demonstrating that the chemical substance is equivalent to the chemical substance actually being 

tested) as a condition for approval of your exemption."), available at http://www.gpo.gov/fdsys/pkg/FR2011- I0-21 /pdf/20 11 -27227.pdf. 4 40 C.F.R. § 790.87(a). 

The Chemical Company • 44 Southwest Ave. Jamestown, RI 02835 • 401.423.3100 

www.thechemco.com