p. 7 

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March 2, 2011 

RECD MAR 11 2011 

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Document Control Officer (7407M) 

U.S. EPA / OPPT 

East Building Room E6428 

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 

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Dear Sir/Madam: 

3M is hereby submitting an exemption application pursuant to a recent TSCA test rule. 

On January 7, 2011 EPA announced final TSCA Section 4 test rules for 19 substances . 

These substances were classified as "HPV" or High Production Volume substances . 

HPV substances are those that have been produced at greater than a million pounds per 

year based on data available to the Agency. 

3M's 2006 IUR data 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 from major 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 from the 

testing requirements of the January 7, 2011 rule . 

The established CFR information elements are presented on the following page. 

CONTAINS NO CBI 

This document does not contain TSCA CBI 
The 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 of January 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 4 rule 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 of appropriate 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 of financial responsibility : 

"We understand that if this application is granted before the reimbursement period 

described in section 4(c)(3)(B) of TSCA expires, 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