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# ~'r2b~7OS3/ March 2, 2011 

# RECD MAR 11 2011 ' ~~J 1! : /9 Document Control Officer (7407M) U .S. EPA/ OPPT East Building RoomE6428 1201 Constitution Avenue N .W . Washington, DC 20460 Attn: TSCA Section 4/ 40 CFR 799.5087 

# M R . #- 33,3s`q3

Subject: Exemption Request Application for a TSCA Test Rule

EPA Docket : EPA-HQ-OPPT-2007-0531 Test Rule Substance: Benzophenone, CAS RN 119-61-9 

# xNimiiuN0ipiiiuuu~u~r~u~u~ Dear Sir/Madam

: 3M is hereby submitting an exemption application pursuant to a recent TSCAtest rule. On January 7, 2011 EPAannounced final TSCA Section 4test rules for 19 substances. These substances were classified as "HPV" or High Production Volume substances . HPVsubstances are those that have been produced at greater than a million pounds per year based on data available to the Agency. 3M's 2006 IURdata showed no production or import activity for benzophenone. We are currently analyzing our 2010 imports for the IUR, and we expect that relatively minor amounts of the substance were imported last year . 3M continues to purchase most of the benzophenone that we process frommajor US suppliers, and we expect that one or more domestic producers will sponsor testing for this substance, either alone or as part of a manufacturer's consortium . Given 3M's limited involvement as a `producer' of benzophenone (by way of import activities), we are seeking an exemption fromthe testing requirements of the January 7, 2011 rule. The established CFRinformation elements are presented on the following page.



## CONTAINS NOCBI This document does not contain TSCA CBIThe Code of Federal Regulation specifies certain elements of an exemption request, at 40

CFR 790

.82. Those elements are recited and addressed here: (a) Identity of the test rule and the chemical identity for which the application applies: - Test rule ofJanuary 7, 2011, 76 FR 1067-1093 - Chemical name: Benzophenone, CAS RN 119-61-9 (b) The specific testing requirement(s) from which an exemption is sought and the basis for the exemption request: - All required tests listed in the Section 4rule that apply to CAS RN 119-61-9 (c) Name, address, and telephone number of applicant: - Greg McCarney, 3M Center 220-6E-03, St. Paul, MN 55144 ; 651-736-0360 (d) Name, address, and telephone number ofappropriate individual to contact for further information: - As listed in (c) above (e)(1) If required in the test rule to establish equivalence: (i) The chemical identity of the test substance on which the application is based. - Not applicable for this test rule Statement offinancial responsibility: "We understand that if this application is granted before the reimbursement period described in section 4(c)(3)(B) ofTSCAexpires, 3M 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 my application was based." (the preceding statement is required per 40 CFR 799) Please direct any correspondence or inquiries to the undersigned. Thank you.

reg Md ead Regulatory Specialist 3M Medical Dept . 3M Center 220-6E-03 St. Paul, MN 55144-1000 651-736-0360

This document does not contain TSCA CBI