### p. 1 U .S. ENVIRONMENTAL PROTECTION AGENCY A



# . ,

~ :1uc1 wc wiai numoer or pages in the Premanufacture Notice

. 

# PREMANUFACTURE NOTICE

your Arm . You must provide all information requested in this formto the extent that it is known to or reasonably ascertainable by you. Make reasonable estimates ifyou do not have actual data. Before you complete this form, you should read the "Instructions Manual for Premanufacture Notification" (the Instructions Manual is available fromthe Toxic Substances Control Act (TSCA) Information Service by calling 202-554-1404, or faxing 202-554-5603). If a user fee has been remitted for this notice (40CFR700 .45), indicate in the boxes above the TS-user fee identification number you have generated. Remember, corresponding fee remittance, which is sent to EPA, HQAccounting Operations Branch (PM-226), P .O . your user fee ID number must also appear onTSCA User fee . 360399M, Pittsburgh, PA 15251-6399, Part I -GENERAL INFORMATION currently confidential . your your your original

correct Chemical Abstracts (CA) Name of the new You must provide the You may authorize chemical substance, even ifyou claimthe identity as submission will another person to submit chemical identity information for you, but not be complete and thereview will not begin until EPAreceives this information . A TS user fee identification submission should reference letter in support of andtwo copies of this notice including all test data. number . You must submit an If you claimed any information as confidential, a single sanitized copy must also be submitted. Part II-HUMANEXPOSURE ANDENVIRONMENTAL RELEASE

manufacture, processing, or use operations to be described in Part II, If there are several sections A

and Bof this notice, reproduce the sections as needed. Part III-LIST OF ATTACHMENTS corresponding Attach additional sheets if there is not enough space to answer a question fully. Label section heading. In Part III, list these each continuation sheet with the attachments, any test data or other data and any optional information included in the notice . OPTIONAL INFORMATION You may include any information that youwant EPA to consider in evaluating the new substance. On page 11 of this form, space has been provided for you to described pollution prevention and recycling information you may have regarding the new substance. your

. . . information So-called "binding" boxes are included throughout this form for you to indicate willingness to be bound to certain statements you make in this section, such as use, production volume, protective equipment This option is intended to reduce delays that routinely accompany the development of consent orders or Significant New Use Rules. Except in the case of exemption applications (such as TMEA, LVE, LOREX) where certain provided in such notification is binding on the submitter when the Agency approves the exemption application, checking a binding box in this notice does not by itself prohibit the submitter fromlater deviating fromthe information (except chemical identity) reported in the form . CONFIDENTIALITY CLAIMS

confidential . , you (including You may claimany information in this notice as confidential . To assert a claimon the form, mark (X) the confidential box next to the information that you claim as

To assert a claimin an attachment, circle or bracket the information you claimas confidential . If you claim information in the notices as confidential must also provide a sanitized version ofthe notice, attachments) . For additional instructions on claiming information as confidential, read the Instructions Manual . ® Mark (x) if any information in this notice is claimed as confidential . 

# S NMZ TEST DATA AND OTHER DATA 

# A ED

they You are required to submit all test data in your possession or control and to provide a description ofall otherdata known to or reasonably ascertainable by you, if these data are related to the health and environmental effects on the manufacture, processing, distribution in commerce, use, or disposal of thenew chemical substance. Standard literature citations may be submitted for data in the open scientific literature. Complete test data (written in English), not summaries of data. do not appear in the open literature. You should clearly must be submitted if identify whether test data is on the substance or on an analog. Also, the chemical composition of the tested material should be characterized. Following are examples of test data and other data. Data should be submitted according to the requirements of §720.50of the Premanufacture Notification Rule (40CFRPart 720) . Test Data (Check Below any included in this notice) " Environmental fate data " Health effects data " Environmental effects data " Physical/Chemical Properties* Yes " Other data ® Yes 0 Yes Risk assessments

Structure/activity 0 Yes relationships ® Yes Test data not in the possession

or control of the submitter * A physical and chemical properties worksheet is located on the last page of this form . TYPE OF NOTICE ® 

# 0 0 0 (Check Only One)

Exposure PMN(Premanufactwe Notice) INTERMEDIATE PMN (submitted in sequence with final product PMN) SNUN (Significant New Use Notice) TMEA (Test Marketing Exemption Application) LVE (Low

Volume Exemption) @

40 CFR723.50(c)(1)~ . LOREX (Low

Release/Low Exemption) @ 40 CFR723.50(c)(2) LVE Modification IS THIS A CONSOLIDATED PMN? # of chemicals a LOREX Modification Yes (Prenotice Communication #required, enter # on page 3) Form EPA FORM

7710-25 (Rev. 5-95) Page 1 Replaces previous editions of EPA 7710-25.

### Public reporting burden for this collection of information is estimated to average I 10 hours per response, including time for reviewing

instructions, searching existing data sources, gathering and maintaining the data needed, and completing and reviewing the collection of information. Send comments regarding the burden estimate or any other aspect ofthis collection of information, including suggestions for reducing this burden, to Chief, Information Policy Branch, PM-223, U .S. Environmental Protection Agency, 401 M . St., S.W ., Washington, D

.C. 20460 ; and to the Office of Management and Budget, Paperwork Reduction Act (2070-0012), Washington, D .C. 20503. 

## CERTIFICATION I certify that to the best of my knowledge and belief: 1 . The company named in Part I, section A, subsection 1a of this notice formintends to manufacture or import for a commercial purpose, other than in small quantities solely for research and development, the substance identified in Part 1, Section B. 2. All information provided in this notice is complete and truthful as ofthe date of submission. 3. 1 am

submitting with this notice all test data in my possession or control and a description ofall other data known to or reasonably ascertainable by me as required by §720.50 ofthe Premanufacture Notification Rule. Additional Certification Statements: Ifyou are submitting a PMN, Intermediate PMN, Consolidated PMN, or SNUN, check the following user fee certification statement that applies: ®The Company named in Part 1, Section Ahas remitted the fee of $2500specified in 40 CFR 700 .45(b), or 0 The Company named in Part 1, Section Ahas remitted the fee of $1000for an Intermediate PMN(defined @ 40 CFR 

### 700.43) in accordance with 40 CFR700.45(b), or Fj The Company named in Part I Section A is a small business concern under 40 CFR700 .43 and has remitted a fee of $100 in accordance with 40 CFR 700 .45(b) . If you are submitting a low volume exemption (LVE) application in accordance with 40 CFR 723.50(c)(1) or a Low release and low exposure exemption (LoRez) application in accordance with 40 CFR 723.50(c)(2), check the following certification statements: 0The manufacturer submitting this notice intends to manufacture or import the new chemical substance for commercial purposes, other than in small quantities solely for research and development, under the terms of 40 CFR723.50. F~ The manufacturer is familiar with the terms ofthis section andwill comply with those terms; and F-1 The new

chemical substance for which the notice is submitted meets all applicable exemption conditions. F~ Ifthis application is for an LVE in accordance with 40 CFR 723.50(c)(1), the manufacturer intends to commence manufacture ofthe exempted substance for commercial purposes within 1 year of the date ofthe expiration of the 30 day reviewperiod. The accuracy of thestatements you make inthis notice should reflect your best prediction of the anticipated facts regarding the chemical substance described herein. An kno w i ngandwillful misinterpretation is subject to criminal penal ty p ursuantto 18 USC1001 . Confidential Signature and title ofAuthorized O ~cial (Original Signature Required) Date 

# -- Signature of agent - (ifapplicable) a Date

EPA FORM

7710-25 (Rev. 5-95) Page 2

### Part I - GENERAL INFORMATION

Section A - SUBbIITTER IDENTIFICATION ConfiMark the "Confidential" box next to an subsection you claimas confidential dential la. Person Name of authorized official Position Submitting 

### Notice (in U.S.) Briana Ha en Product Res p onsibility Sp

ecialist Company 

### 3M Mailing address (number and street) 

### 236-1 B-10 City, State, ZIPCode 

### St . Paul, MN, 55144-1000 b. Agent (if Name ofauthorized official Position applicable) Company

Mailing address (number and street) City, State, ZIP Code Telephone Area Code Number

c. If you are submitting this notice as part ofajoint submission, mark (X) this box. Joint Submitter (if Name ofauthorized official Position applicable) Company

Mailing address (number and street) City, State, ZIP Code Telephone Area Code Number 2. Technical Name ofauthorized official Position Contact (in 

### U.S.) Jeffrey Stolte Product Responsibility Associate

Company 

### 3M Mailing address (number and street) 

### 236-1 B-10 City, State, ZIP Code Telephone Area Code Number 

### St. Paul, MN, 55144-1000 1 651 575-0856 3 . Ifyou have had a prenotice communication (PC) concerning this notice and EPAassigned a PC Number to the notice, enter the number. Mark (X) if none 4 . Ifyoupreviously submitted an exemption application for the chemical substance covered by this notice, enterthe exemption number assigned by Mark (X) EPA . Ifyou previously submitted a PMN forthis substance enter the if none PMN number assigned by EPA (i .e . withdrawn or incompktej---i 5. If you have submitted a notice of Bona fide intent to manufacture or import for the chemical substance covered by this notice, enter the notice number Mark (X) assigned by EPA

. -1 if none

1 . ® Manufacture 2. ~ Import 6. Type of Notice - Mark (X) Only Only 3. ~ Both 0 Binding Option ~ Binding Option Mark (X) Mark (X)

EPA FORM

7710-25 (Rev. 5-95) Page 3

### Part I -- GENERAL INFORMATION - Continued

Section B -- CHEMICAL IDENTITY INFORMATION : You must provide a currently correct Chemical Abstracts (CA) name of the substance based on

the ninth Collective Index 9CI of CA nomenclature rules and conventions. Mark X the "Confidential" box next to any itemyou claimas confidential Complete either item1 (Class 1 or 2 substances) or 2 (Polymers) as appropriate. Complete all other items. If another person will submit chemical identity information for you (for either ItemI or 2), mark (X) the box at the right . ConfiIdenti the name, com

p any, and address of that person in a continuation sheet . ' El dential I . Class I or 2 chemical substances (for definitions ofclass I and class 2 substances, see the Instructions Manual) a. Class ofsubstance - Mark (X) I ® Class I or 2 [ :] Class 2 b. Chemical name (Currently correct Chemical Abstracts (CA) Name that is consistent with TSCA Inventory listings for similar substances. For Class 1 substances a CA Index Name must be provided. For Class 2 substances either a CA Index Name or CA Preferred Name must be provided, which ever is appropriate based on CA 9CI nomenclature rules and conventions) .

c. Please identify which method you used to develop orobtain the specified chemical identity information reported in this notice: (check one) .

Method 1 (CAS Inventory Expert Service - a copy ofthe Identification ®Method 2 ( per STN ) report obtained fromthe CAS Inventory Expert Services must be submitted as an attachment to this notice d. Molecular formula and CAS Registry Number (if a number already exists for the substance) 

### X CAS# 

### X e. For a class I substance, provide a complete and correct chemical structure diagram . For aclass 2 substance - (1) List the immediate precursor substances with their respective CAS Registry Numbers. (2) Describe the nature of the reaction or process . (3) Indicate the range ofcomposition and the typical composition (where appropriate) . (4) Provide a correct representative or partial chemical structure diagram . as complete as can be known. ifone can be reasonablv ascertained . 

# SAHmZE©

~ Mark (X) this box ifyou attach a continuation sheet.

EPAFORM

7710-25 (Rev. 5-95) Page 4

### Part I - GENERAL INFORMATION -- Continued

Section B - CHEMICAL IDENTITI' INFORMATION - Continued 2. Polymers (For a definition of polymer, see the Instructions Manual .) Confidential a. Indicate the number-average weight ofthe lowest molecular weight composition of the polymer you intend to manufacture. Indicate maximum

weight percent of low

molecular weight species (not including residual monomers, reactants, or solvents) below500 and below1,000 absolute molecular weight of that composition. Describe the methods of measurement or the basis for your estimates: GPC 0 Other O : (Specify) i) lowest number average molecular weight : ii) maximum

weight %

below500 molecular weight : iii) maximum

weight %

below 1000 molecular weight : Mark (X) this box ifyou attach a continuation sheet . b. You must make separate confidentiality claims for monomer or other reactant identity, composition information, and residual information. Mark (X) the "Confidential" box next to any itemyou claimas confidential (1) - Provide the specific chemical name and CAS Registry Number (if a number exists) ofeach monomer or other reactant used in the manufacture of

the polymer. (2) - Mark (X) this column if entry in column (1) is confidential . (3) - Indicate the typical weight percent ofeach monomer or other reactant in the polymer . (4) - Mark (X) the identity column ifyou want a monomer or other reactant used at two weight percent or less to be listed as part of the polymer

description on the TSCA Chemical Substance Inventory. (5) - Mark (X) this column ifentries in columns (3) and (4) are confidential . (6) - Indicate the maximum weight percent ofeach monomer or other reactant that may be present as a residual in the polymer as manufactured for commercial purposes. 7 - Mark X this column ifen in column 6 is confidential . Monomer or other reactant and CAS Registry Number Confi- Typical Identity Confi- Maximum Confidential composition Mark (X) dential residual dential 1 2 3 (4 (5 (6 (7 % % % %

% % a Mark (X) this box ifyou attach a continuation sheet . c. Please identify which method you used to develop or obtain the specified chemical identity information reported in this notice (check one) . O Method I (CAS Inventory Expert Service - a copy of the identification report O Method 2 (other source)

obtained fromCAS Inventory Expert Service must be submitted as as attachment to this notice d. The currently correct Chemical Abstracts (CA) name for the polymer that is consistent with TSCA Inventory listings for similar polymers.

e. Provide a correct representative or partial chemical structure diagram, as complete as can be known, if one can be reasonably ascertained.

~ Mark (X) this box ifyou attach a continuation sheet. EPA FORM

7710-25 (Rev. 5-95) Page 5

## Part I -- GENERAL INFORMATION -- Continued

Section B -- CHEMICAL IDENTITY INFORMATION - Continued 3 . Impurities (a) - Identify each impurity that may be reasonably anticipated to be present in the chemical substance as manufactured for commercial purpose.

CAS Registry Number ifavailable. Ifthere are unidentified impurities, enter "unidentified ." % . b - Estimate the maximumwei ght % of each im

puri ty. Ifthere are unidentified im purities, estimate their total wei ght Provide the Impurity and CAS Registry Number

a Maximum percent b Confidential % 

## X X 

# ~N~~ZED x x x x Mark (X) this box if you attach a continuation sheet . 4. Synonyms - Enter any chemical synonyms for the newchemical identified in subsection 1 or 2. Confidential Mark (X) this box ifyou attach a continuation sheet. 

### X

5. Trade identification - List trade names for the new chemical substance identified in subsection 1 or 2.

Mark (X) this box ifyou attach a continuation sheet. 6. Generic chemical name - Ifyou claimchemical identify as confidential, you must provide a generic name for your substance that reveals the specific chemical identity of the new chemical substance to the maximum extent possible. Referto the TSCA Chemical Substance Inventory, 1985 Edition, Appendix Bfor guidance on developing generic names. Aryloxyacrylate

Mark (X) this box ifyou attach a continuation sheet . 7. Byproducts - Describe any byproducts resulting fromthe manufacture, processing, use, or disposal of the newchemical substance. Provide the CAS Registry

Number if available. Byproduct 1 CAS Registry Number 2 Confidential 

## X X X X ® Mark (X) this box ifyou attach a continuation sheet. EPA FORM

7710-25 (Rev. 5-95) Page 67. B

yproducts - Continued. Byproduct 1 CAS Registry Number 2 Confidential X X 

# SANjTjZED

EPA FORM

7710-25 (Rev. 5-95) Page 7

## Part I -- GENERAL INFORMATION -- Continued Section C - PRODUCTION IIVIPORT ANDUSE INFORMATION:

Mark (X the "Confidential" box next to an item you claimas confidential . 1 . Production volume - Estimate the maximum production volume during the first 12 months of production. Also estimate the maximum production volume for any consecutive 12-month period during the first three years of production. Estimates should be on 100%new chemical substance basis. For a Low Volume Exemption application, if you choose to have your notice reviewed at a lower production volume than 10,000 k r, sp

eci fy the volume and mark x in the binding box. If anted, y ou are bound to this volume Maximum

first 12-month production (kg/yr) Maximum12-month production (kg/yr) Confi- Binding (100% new chemical substance basis) (100%new chemical substance basis) dential Mark x 

# NITIZED 2 . Use Information - You must make separate confidentiality claims for the description ofthe category of use, the percent of production volume 

### devoted to each category, the formulation of the new substance, and other use information. Mark (X) the "Confidential" Box next to any item you claimas confidential . a. (1) -- Describe each intended category of use of the new chemical substance by function and application . . (2) -- Mark (X) this column ifentry column (1) is confidential business information (CBI) . (3) -- Indicate your willingness to have the information provided in column (1) binding. (4) -- Estimate the percent oftotal production for the first three years devoted to each category of use. (5) -- Mark (X) this column if entry in column (4) is confidential business information (CBI) . (6) -- Estimate the percent ofthe new substance as formulated in mixtures, suspensions, emulsions, solutions, or gels as manufactured for commercial purposes at sites under your control associated with each category of use. (7) -- Mark (X) this column if entry in column (6) is confidential business information (CBI) . 

### (8) -- Indicate %

ofproduct volume expected for the listed "use" sectors. Mark more than one box if appropriate. Mark (X) to indicate your willingness to have the use type provided in (8) binding. (9) -- Mark X this column ifent ies in column 8 is are confidential business information (CBI ) . Category of use (1) CBI Binding Produc- CBI % in CBI % of substance expected per use CBI Option tion % Form- (by function and application i .e. a dispersive dye Mark(X) ulation Site- Con-* Indus- Com- Binding for finishing pol yester fibers 2 (3) 4 5 6 7 limited sumer trial mercial O 

## ption 9 

### X X X X

°i° °i° ° ° ° ° ° ° ° ° ° ° ° ° * Ifyou have identified a "consumer" use, please provide on a continuation sheet adetailed description ofthe use(s) ofthis chemical substance in consumer products. In addition include estimates ofthe concentration ofthe new chemical substance as expected in consumer products and describe the chemical reactions by which this substance loses its identity in the consumer product. E]Mark (X) this box ifyou attach a continuation sheet . b . Generic If youclaimany category of use description in subsection 2a as confidential, enter a generic description ofthat category. Read the use Instructions Manual for examples ofgeneric use descriptions. description monomer

~ Mark (X) this box ifyou attach a continuation sheet . 3 . Hazard Information - Include in the notice a copy of reasonable facsimile of any hazard warning statement, label, material safety data sheet, or other Binding information which will be provided to any Person who is reasonably likely to be exposed to this substance regarding protective equipment or practices Option Mark 1x1 for the safe handing, transport, use, or disposal of the new substance. List in part III hazard information you include. ®Mark (X) this box ifyou attach hazard information. EPA FORM

7710-25 (Rev. 5-95) Page 8

## Part II-- HUMAN EXPOSURE AND ENVIRONMENTAL RELEASE Section A -- INDUSTRIAL SITES CONTROLLED BY THE SUBMITTER Mark (X) the "Confidential" box next to any itemyou claimas confidential 

### Complete section Afor each type of manufacture, processing, or use operation involving the new chemical substance at industrial sites you control . Importers do not have to complete this section for operations outside the U .S. ; however, you may still have reporting requirements if there are further industrial processing or use op erations after im

port . You must describe these operations. See instructions manual 

### 1 . Operation description Confia . Identi ty -- Enter the identi ty of the site at which the op eration will occur. dential Name 

### 3M Cottage Grove (or) 3M Cordova (or) 3M Center Site address (number and street) 

### 10746 Innovation Road 22614 Route 84 North City, County, State, ZIP code Cottage Grove,Washington,MN 55016 Cordova,Rock Island,IL,61242 St . Paul,Ramsey,MN,55144 Ifthe same operation will occur at more than one site, enter the number ofsites. Identify the additional sites on a continuation sheet, and ifany ofthe sites have significantly different production rates or operations, include all the information requested in this section for those sites as attachments. ® Mark (X) this box if you attach a continuation sheet (See Continuation Sheet, Page 10) . b. Type -- Mark (X) ®Manufacturing ElProcessing DUse c. Amount and Duration -- Com plete 1 or 2 as appropriate Maximum

kg/batch (lo0%

new chemical Hours/batch Batches/year substance) 1 . Batch Maximum kg/batch (100%new chemical Kg/hour %_71"W"-5 ~ ~ - Hours/Year substance) 2. Continuous d. Process description F] Mark (X) to indicate your willingness to have your process description binding. (1) Diagram

the major unit operation steps and chemical conversions. Include interimstorage and transport containers (specify- e.g. 5 gallon pails, 55 gallon drum, rail car, tank truck, etc.) . (2) Provide the identity, the approximate weight (by kg/day or kg/batch on a 100°/n new chemical substance basis), and entry point ofall starting materials and feedstocks (including reactants, solvents, catalysts, etc.), and of all products, recycle streams, and wastes. Include cleaning chemicals (note frequency if not used daily or per batch.) . (3) Identify by number the points of release, including small or intermittent releases, to the environment of the newchemical substance. 

### See Continuation Sheets, Pages 11 and 12 .

®Mark (X) this box ifyou attach a continuation sheet . EPA FORM

7710-25 (Rev. 5-95) Page 9

### p. 10 Continuation sheet (page 10)

1 . Operation description Confia. identi ty - Continued. dential Name 

### 3MDecatur Site address (number and street) 

### State Docks Road City, County, State, ZIP code Decatur, Morgan,AL 35609

EPAFORM

7710-25 (Rev. 5-95) Page 10

### p. 11 Continuation sheet (page 11)



# S^HMZEO

EPA FORM

7710-25 (Rev. 5-95) Page 11 Replaces previous editions of EPA Form7710-25.Continuation sheet (page 12)



# SANVMED

EPA FORM

7710-25 (Rev. 5-95) Page 12

### p. 13



## Part II-- HUIVIAN EXPOSURE AND ENVIRONMENTAL RELEASE -- Continued Section A-- INDUSTRIAL SITES CONTROLLED BY THE SUBMITTER-- Continued 2. Occupational Exposure - You must make separate confidentiality claims for the description ofworker activity, physical formof the new chemical substance, number of works exposed, and duration ofactivity. Mark (X) the "Confidential" box next to any itemyou claimas confidential . (1) --Describe the activities (i .e. bag dumping, tote filling, unloading drums, sampling, cleaning, etc.) in which workers may be exposed to the substance. (2) --Mark (X) this column if entry in column (1) is confidential business information (CBI) . (3) --Describe any protective equipment and engineering controls used to protect workers. (4) and (6) -- Indicate your willingness to have the information provided in column (3) or (5) binding. (5) --Indicate the physical form(s) of the newchemical substance (e.g., solid: crystal, granule, powder, or dust) and % new chemical substance (if part of a mixture) at the time ofexposure. (7) --Mark (X) this column if entry in column (5) is confidential business information (CBI) . (8) -- Estimate the maximum number ofworkers involved in each activity for all sites combined. (9) --Mark (X) this column ifentry in column (8) is confidential business information (CBI) . (10) and (11) -- Estimate the maximum duration of the activity for any worker in hours per day and days per year . (12 -- Mark X this column ifentries in columns 10 and 11 are confidential business information (CBI) . Worker activity CBI Protective Equipment/ Binding Physical forms(s) Binding CBI # of CBI Maximum duration CBI (i .e., bag dumping, filling drums) Engineering Controls Option mark and % new Option Workers Hrs/day Days/yr (X) substance Mark (x) Exposed 1 (2) 3 (4) (5) (6) (7) 8 (9) (10) (II) (IZ)



### X refer to MSDS X X X X refer to MSDS X X X X refer to MSDS X X X Clean up refer to MSDS X X X Sampling/QC Testing refer to MSDS X X X

~ Mark (X) this box ifyou attach a continuation sheet. 3. Environmental Release and Disposal -- You must make separate confidentiality claims for the release number and the amount ofthe new chemical substance released and other release and disposal information. Mark (X) the "Confidential" box next to each itemyou claimas confidential . (1) --Enter the number of each release point identified in the process description, part II, section A, subsection ld(3) . (2) --Estimate the amount ofthe new substance released (a) directly to the environment or (b) into control technology (in kg/day or kg/batch) . i (3) --Mark (X) this column ifentries in columns (1) and (2) are confidential business information (CBI) . I (4) --Identify the media (stack air, fugitive air (optional-see Instruction Manual), surface water, on-site or off -site land or incineration, POTW, or other (specify)) to j which the new

substance will be released fromthat release point. (5) --a. Describe control technology, if any, and control efficiency that will be used to limit the release ofthe new substance to the environment . For releases ' disposed ofon land, characterize the disposal method and state whether it is approved for disposal of RCRA hazardous waste. On a continuation sheet, for each site describe any additional disposal methods that will be used and whether the waste is subject to secondary or tertiary on-site treatment. b . Estimate the amount released to the environment after control technology (in kg/day) . (6) --Mark (X) this column ifentries in columns (4) and (5) are confidential business information (CBI) . (7) --Identify the destination(s) of releases to water . Please supply NPDES (National Pollutant Discharge Elimination System) numbers for direct discharges or NPDES numbers of the POTWPublicl Owned Treatment Works) . Mark X if the POTW name or NPDES # is confidential business information CBI . Release Amount of new substance CBI Media of Control technology and efficiency (you may wish to optionally attach efficiency data) Cst Number released release (1) (2a) (2b) e.g. suckarz Binding 3 (4) (Sa Mark (x) 5b (6 

### 1 X 0 X 2 X 0 X 3 X 0 X ', 4 X 0 X '

(7) Mark (X) the a POTW provide name(s) below : El Navigable E] Other -Specify provide NPDES# CE destination(s) of waterway releases to water.

I~ Mark (X) this box ifyou attach a continuation sheet. EPA FORM

7710-25 (Rev. 5-95) Page 13

## Part II-- HUMAN EXPOSURE AND ENVIRONMENTAL RELEASE Section A-- INDUSTRIAL SITES CONTROLLED BY THE SUBMITTER Mark (X) the "Confidential" box next to any itemyou claimas confidential 

### Complete section Afor each type of manufacture, processing, or use operation involving the new chemical substance at industrial sites you control . Importers do not have to complete this section for operations outside the U .S. ; however, you may still have reporting requirements if there are further industrial p rocessing or use o

perations after im

port. You must describe these op erations. See instructions manual 1 . Operation description Confi

### a . Identi ty -- Enter the identi ty ofthe site at which the o p eration will occur. dential Name 

### 3M Cottage Grove (or) 3M Cordova (or) 3M Center Site address (number and street) 

### 10746 Innovation Road 22614 Route 84 North City, County, State, ZIP code 

### Cottage Grove,Washington,MN 55016 Cordova,Rock Island,IL,61242 St . Paul, Ramsey,MN,55144 Ifthe same operationwill occur at more than one site, enter the number of sites. Identify the ,1 additional sites on a continuation sheet, and if any ofthe sites have significantly different production rates or operations, include all the information requested in this section for those sites as attachments . ® Mark (X) this box ifyou attach a continuation sheet (See Continuation Sheet, Page 15) . b. Type -- Mark (X) ElManufacturing E]Processing ®Use c. Amount and Duration -- Com plete 1 or 2 as appropriate Maximum

kg/batch (1oo^i new

chemical Hours/batch Batches/year 

# X substance) 1 . Batch Maximum kg/day (too^i new

chemical hrs/day days/year substance) 2. Continuous d. Process description 1 :1 Mark (X) to indicate your willingness to have your process description binding. (1) Diagramthe major unit operation steps and chemical conversions. Include interimstorage and transport containers (specify- e.g. 5 gallon pails, 55 gallon drum, rail car, tanktruck, etc.). (2) Provide the identity, the approximate weight (by kg/day or kg/batch on a 100%new chemical substance basis), and entry point ofall starting materials and feedstocks (including reactants, solvents, catalysts, etc.), and ofall products, recycle streams, and wastes. Include cleaning chemicals (note frequency if not used daily or per batch.) . (3) Identify by number the points of release, including small or intermittent releases, to the environment of the new chemical substance. 

# Sp,NITIZED l

See Continuation Sheet, Page 16 .

®Mark (X) this box ifyou attach a continuation sheet. EPA FORM

7710-25 (Rev. 5-95) Page 14

### p. 15 Continuation sheet (page 15)

1 . Operation description Confia. Identi ty - Continued. dential Name 

### 3M Decatur Site address (number and street) State Docks Road City, County, State, ZIPcode Decatur, Morgan,AL 35609

EPA FORM

7710-25 (Rev. 5-95) Page 15

### p. 16 Continuation sheet (page 16) 

### CBI



# SPNMV-O

EPA FORM

7710-25 (Rev. 5-95) Page 16 Replaces previous editions of EPA Form7710-25 .

### p. 17



## Part II-- HUMAN EXPOSURE AND ENVIRONMENTAL RELEASE -- Continued Section A -- INDUSTRIAL SITES CONTROLLED BYTHE SUBMTTTER-- Continued 2. Occupational Exposure - You must make separate confidentiality claims for the description ofworker activity, physical formof the new chemical substance, number of works exposed, and duration of activity. Mark (X) the "Confidential" box next to any itemyou claimas confidential . (1) --Describe the activities (i .e. bag dumping, tote filling, unloading drums, sampling, cleaning, etc.) in which workers may be exposed to the substance. (2) --Mark (X) this column ifentry in column (1) is confidential business information (CBI) . (3) --Describe any protective equipment and engineering controls used to protect workers. (4) and (6) -- Indicate your willingness to have the information provided in column (3) or (5) binding. (5) --Indicate the physical form(s) ofthe new chemical substance (e.g., solid: crystal, granule, powder, or dust) and % new chemical substance (if part ofa mixture) at the time of exposure. (7) --Mark (X) this column ifentry in column (5) is confidential business information (CBI) . (8) --Estimate the maximum number ofworkers involved in each activity for all sites combined. (9) --Mark (X) this column ifentry in column (8) is confidential business information (CBI) . (10) and (11) -- Estimate the maximumduration ofthe activity for any worker in hours per day and days per year. 12 -- Mark X this column ifentries in columns 10 and 11 are confidential business information (CBI) . Worker activity CBI Protective Equipment/ Binding Physical forms(s) Binding CBI # of CBI Maximu m duration CBI (i .e., bag dumping, filling drums) Engineering Controls Option Mark (x) and %

new option

Mark (x) Worker Hrs/day Days/yr (1) (z) (3) (4) substance (5) (6) (7) s Expose 

### (9) (10) (11) (12) d 8 

### X refer to MSDS X X X

a Mark (X) this box ifyou attach a continuation sheet. 3. Environmental Release and Disposal -- You must make separate confidentiality claims for the release number and the amount ofthe newchemical substance released and other release and disposal information. Mark (X) the "Confidential" box next to each itemyou claimas confidential . (1) --Enter the number ofeach release point identified in the process description, part Il, section A, subsection ld(3) . (2) -- Estimate the amount of the new substance released (a) directly to the environment or (b) into control technology (in kg/day or kg/batch) . (3) --Mark (X) this column if entries in columns (1) and (2) are confidential business information (CB1) . (4) --Identify the media (stack air, fugitive air (optional-see Instruction Manual), surface water, on-site or off-site land or incineration, POTW, or other (specify)) to which the new

substance will be released fromthat release point. (5) --a. Describe control technology, ifany, and control efficiency that will be used to limit the release ofthe new substance to the environment . For releases disposed of on land, characterize the disposal method and state whether it is approved for disposal of RCRA hazardous waste. On a continuation sheet, for each site describe any additional disposal methods that will be used and whether the waste is subject to secondary or tertiary on-site treatment . b. Estimate the amount released to the environment after control technology (in kg/day) . (6) --Mark (X) this column ifentries in columns (4) and (5) are confidential business information (CBI) . (7) --Identify the destination(s) of releases to water . Please supply NPDES (National Pollutant Discharge Elimination System) numbers for direct discharges or NPDES numbers of the POTWPublicl Owned Treatment Works) . Mark X if the POTW name or NPDES # is confidential business information CBI . Release Amount of new substance CBI Media of Control technology and efficiency (you may wish to optionally attach efficiency data) CBI Number released release (1) (2,a) (2b) (3 e.g .stack art (4) (5a Binding Mark (X) 5b 6

(7) Mark (X) the a POTW provide name(s) below

: ~ Navigable ~ Other -Specify provide NPDES # CBI destination(s) of waterway releases to water.

Mark (X) this box ifyou attach a continuation sheet . I

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## Part II-- HUMAN EXPOSURE ANDENVIRONMENTAL RELEASE -- Continued Section B -- INDUSTRIAL SITES CONTROLLED BY OTHERS Complete section Bfortypical processing or use operations involving the new chemical substance at sites you do not control . Importers do not have to complete this section for operations outside the U.S. ; however, you must report any processing or use activities after import. See the Instructions Manual . Complete a separate section B for each type ofprocessing, or use operation involving the new chemical substance. Ifthe same operation is performed at more than one site describe the typical op eration common to these sites. Identi fy additional sites on acontinuation sheet. 1 . Operation Description -- To claiminformation in this section as confidential, circle or bracket the specific information that you claimas confidential . (1) -- Diagramthe major unit operation steps and chemical conversions, including interimstorage and transport containers (specify - e.g. 5 gallon pails, 55 gallon drums, rail cars, tank trucks, etc) . Onthe diagram, identify by letter and briefly describe each worker activity. (2) -- Provide the identity, the approximate weight (by kg/day or kg/batch, on an 100%new chemical substance basis), and entry point ofall feedstocks (including reactants, solvents and catalysts, etc) and all products, recycle streams, and wastes. Include cleaning chemicals (note frequency if not used daily or per batch) . (3) -- Identify by number the points of release, including small or intermittent releases, to the environment of the new chemical substance. (4) Please enter the # ofsites (remember to identify the locations of these sites on a continuation sheet) : # of sites

E] Mark (X) this box ifyou attach a continuation sheet . 2 . Worker Exposure/Environmental Release (1) --From

the diagramabove, provide the letter for each worker activity. Complete 2-8 for each worker activity described. (2) -- Estimatethe number ofworkers exposed for all sites combined. (4) -- Estimatethe typical duration of exposure per worker in (a) hours per day and (b) days per year . (6) --Describe physical formofexposure and % newchemical substance (if in mixture), and any protective equipment and engineering controls, if any, used to protect workers. (7) -- Estimate the percent ofthe new substance as formulated when packaged or used as a final product . (9) --From

the process diagramabove, enter the number ofeach release point. Complete 9-13 for each release point identified. (10) -- Estimate the amount of the newsubstance released (a) directly to the environment or (b) into control technology to the environment (in kg/day or kg/batch) . (12) --Describe media of release i .e. stack air, fugitive air (optional-see Instructions Manual), surface water, on-site or off-site land or incineration, POTW, or other (specify) and control technology, if any, that will be used to limit the release of the new substance to the environment . (14) -- Identify byproducts which may result fromthe operation. ( 3) , ( 5) , ( 8), ( 11 ) , 13 and 15 -- Mark X this column ifany ofthe roceedin entries are confidential business information CBI . Letter of Act-ivity #of

Workers Exposed CBI Duration of Exposure CBI Protective Equip . / Engineering Controls/ Physical Formand % new substance %

inFormulation CBI Release

Number Amount of

New Substance Released CBI Media of Release & Control Technology CBI (1) (2) (3) 4a 4b (5) 6 (7) (8) (9) (l 0a) (106) (11) (12) (13)

(14) -- Byproducts : (15) a Mark (X) this box ifyou attach a continuation sheet,

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# OPTIONAL POLLUTION PREVENTION INFORMATION To claiminformation in this section as confidential circle or bracket the specific information that you claim as confidential . 

## In this section you may provide information not reported elsewhere in this formregarding your efforts to reduce or minimize potential risks associated with activities surrounding manufacturing, processing, use and disposal of the PMNsubstance. Please include new information pertinent to pollution prevention, including source reduction, recycling activities and safer processes or products available due to the new chemical substance. Source reduction includes the reduction in the amount or toxicity of chemical wastes by technological modification, process and procedure modification, product reformulation, raw materials 

## substitution, and/or inventory control . Recycling refers to the reclamation of useful chemical components from wastes that would otherwise be treated or released as air emissions or water discharges, or land disposal . Descriptions ofpollution prevention, source reduction and recycling should emphasize potential risk reduction subsequent to compliance with existing regulatory requirements and can be either quantitative or qualitative . The EPA is interested in the information to assess overall net reductions in toxicity or environmental releases and exposures, not the shifting of risks to other environmental media or non-environmental areas (e.g., occupational or consumer exposure) . In addition, information on the relative cost or performance characteristics of the PMNsubstance to potential alternatives may be provided. All information provided in this section will be taken into consideration during the reviewof this substance. See Instructions Manual and Pollution Prevention Guidance manual for guidance and 

## exam ples. Describe the expected net benefits, such as (1) an overall reduction in risk to human health or the environment; (2) a reduction in the volume manufactured ; (3) a reduction in the generation of waste materials through recycling, source reduction or other means; (4) a reduction in potential toxicity or human exposure and/or environmental release; (5) an increase in product performance, a decrease in the cost of production and/or improved operation efficiency ofthe new chemical substance in comparison to existing chemical substances used in similar application; or (6) the extent to which the new chemical substance may be a substitute for an existing substance that poses a g reater overall risk to human health or the environment . CBl 

# X 

# ~H~,rZED l

El Mark (X) this box if you attach a continuation sheet . EPA FORM

7710-25 (Rev. 5-95) Page 19

# Part III -- LIST OF ATTACHMENTS

Attach continuation sheets for sections of the formand test data and other data (including physical/chemical properties and structure/activity information), and optional information after this page. Clearly identify the attachment and the section ofthe form to which it relates, if appropriate. Number consecutively the pages of the attachments . In the column below, enter the inclusive page numbers ofeach attachment . Mark (X) the "Confidential" box next to any attachment name you claimas confidential . Read the Instructions Manual for guidance on how to claimany information in an attachment as confidential . You must include with the sanitized copy ofthe notice form a sanitized version ofany attachment in which you claiminformation as confidential . Attachment name Attachment a e number(s) Confidential 

### Physical and Chemical Properties Worksheet 21 

### X X X 

# X X X Material Safety Data Sheet (MSDS) 33-38 X X X X

- X X X

- X

~ Mark (X) this box ifyou attach a continuation sheet . Enter the attachment name and number .

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7710-25 (Rev. 5-95) Page 20

### PHYSICAL AND CHEMICAL PROPERTIESWORKSHEET

To assist EPA's review

of physical and chemical properties data, please complete the following worksheet for data you provide and include it in the notice. Identify the property measured, the page of the notice on which the property appears, the value ofthe property, the units in which the property is measured (as necessary), and whether or not the property is claimed as confidential . The physical state ofthe neat substance should be provided. These measured properties should be for the neat (100%pure) chemical substance. Properties that are measured for mixtures or formulations should be so noted (%PMNsubstance in _) . You are not required to submit this worksheet; however, EPA strongly recommends that you do so, as it will simplify reviewand ensure that confidential information is properly protected. You should submit this worksheet as a supplement to your submission of test data. This worksheet is not a substitute for submission oftest data. Property (a) Muk (x) if provided Page

number (b) Value C) easured o Estimate or E Confidential Mark (x) 

### Physical state of neat substance X X- s) - (1) _( ) M Vapor pressure Tem p erature °C Torr Densi ty/relative densi ty X ml M X Solubility @

Temperature °C Solvent L Solubili ty in water Tem perature °C X L M X Melting tem

perature X °C M X Boiling/ sublimation tem erature torr p ressure oc S pectra X M X Dissociation constant Particle size distribution Octanol / water partition coefficient X M X Henry's Law

constant Volitalization fromwater Volitalization fromsoil H concentration Flammabili ty X Not flammable M 

### Ex lodabili Adsorption / coefficient Viscosi ty 25 .0°C cP Flash Point

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### p. 23



# Material Safety Data Sheet Copyright, 2008, 3M

Company

. All rights reserved. Copying and/or downloading ofthis information for the purpose of properly utilizing 3M

products is allowed provided that: (1) the information is copied in full with no changes unless prior written agreement is obtained from3M, and (2) neither the copy nor the original is resold or otherwise distributed with the intention of earning a profit thereon. PRODUCT NAME: ARYLOXYACRYLATE MANUFACTURER: 3M 

### ADDRESS: 3M

Center St. Paul, MN 55144-1000 [ EMERGENCY PHONE: 1-800-364-3577 or (651) 737-6501 (24 hours) Issue Date: 06/27/2008 Supercedes Date: 06/23/2008 Product Use

: Intended Use: Intermediate

Ingredient C .A .S. No . %

bv Wt ARYLOXYACRYLATE Trade Secret > 98 ARYLOXYALCOHOL Trade Secret < 2



## 3.1 EMERGENCY OVERVIEW Specific Physical Form : Crystals spaTIZED Odor, Color, Grade: [ ] General Physical Form : Solid Immediate health, physical, and environmental hazards: Maycause severe eye irritation. May cause allergic skin reaction. 

## 3.2 POTENTIAL HEALTH EFFECTS Eye Contact : Severe Eye Irritation: Signs/symptoms may include significant redness, swelling, pain, tearing, cloudy appearance ofthe cornea, and impaired vision.

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### Skin Contact :

Moderate Skin Irritation: Signs/symptoms may include localized redness, swelling, itching, and dryness. Allergic Skin Reaction (non-photo induced) : Signs/symptoms may include redness, swelling, blistering, and itching . Inhalation: No health effects are expected. 

### Ingestion: Gastrointestinal Irritation: Signs/symptoms may include abdominal pain, stomach upset, nausea, vomiting and diarrhea. Target Organ Effects: There is no information which has been developed specifically on this material . Any information which has been presented is based on known properties of individual components and/or professional judgement concerning properties of the material .



## 4 .1 FIRST AID PROCEDURES The following first aid recommendations are based on an assumption that appropriate personal and industrial hygiene practices are followed. Eye Contact : Immediately flush eyes with large amounts ofwater for at least 15 minutes. Get immediate medical attention. 

### Sldn Contact : Remove contaminated clothing and shoes. Immediately flush skin with large amounts ofwater. Get medical attention. Wash contaminated clothing and clean shoes before reuse. Inhalation: No need for first aid is anticipated. If Swallowed: Do not induce vomiting unless instructed to do so by medical personnel . Give victimtwo glasses ofwater. Never give anything by mouth to an unconscious person. Get medical attention. 

## 5 .1 FLAMMABLE PROPERTIES Autoignition temperature Flash Point Flammable Limits - LEL Flammable Limits - UEL No Data Available Not Applicable Not Applicable Not Applicable 

# SANnzE[) 5 .2 EXTINGUISHING MEDIA Non-combustible. Choose material suitable for surrounding fire. 

## 5 .3 PROTECTION OF FIRE FIGHTERS Special Fire Fighting Procedures : Wear full protective equipment (Bunker Gear) and a self-contained breathing apparatus (SCBA) . EPA FORM

7710-25 (Rev. 5-95)

### Unusual Fire and Explosion Hazards: No unusual fire or explosion hazards are anticipated.

Note: See STABILITY ANDREACTIVITY (SECTION 10) for hazardous combustion and thermal decomposition information

.

Accidental Release Measures: Observe precautions fromother sections. Call 3M- HELPS line (1-800-364-3577) for more information on handling and managing the spill . Ventilate the area with fresh air. Collect as much ofthe spilled material as possible. Usewet sweeping compound or water to avoid dusting . Sweep up. Collect the resulting residue containing solution. Place in a closed container approved for transportation by appropriate authorities. Dispose of collected material as soon as possible. In the event ofa release of this material, the user should determine if the release qualifies as reportable according to local, state, and federal regulations.



## 7.1 HANDLING Avoid skin contact. Avoid eye contact with dust or airborne particles. Do not eat, drink or smoke when using this product. Wash exposed areas thoroughly with soap andwater. Decontaminate work surfaces frequently to avoid exposure by contact . 

## 7.2 STORAGE Store under normal warehouse conditions . 

## 8.1 ENGINEERING CONTROLS Provide local exhaust ventilation at transfer points. Provide appropriate local exhaust when product is heated. 

## 8 .2 PERSONAL PROTECTIVE EQUIPMENT (PPE) 8.2.1 Eye/Face Protection Avoid eye contact . 

### The following eye protection(s) are recommended: Indirect Vented Goggles. 8.2.2 Skin Protection Avoid skin contact . 

# SANITIZED

Select and use gloves and/or protective clothing to prevent skin contact based on the results of an exposure assessment . Consult with your glove and/or protective clothing manufacturer for selection of appropriate compatible materials. Gloves made from

the following material(s) are recommended: Butyl Rubber, Nitrile Rubber. 8 .2.3 Respiratory Protection Under normal use conditions, airborne exposures are not expected to be significant enough to require respiratory protection. 8.2.4 Prevention of Swallowing Do not eat, drink or smoke when using this product. Wash exposed areas thoroughly with soap andwater.

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## 8 .3 EXPOSURE GUIDELINES None Established

Specific Physical Form : Odor, Color, Grade: General Physical Form : Autoignition temperature Flash Point Flammable Limits - LEL Flammable Limits - UEL Boiling point Density Vapor Density Crystals Solid No Data Available NotApplicable NotApplicable NotApplicable NotApplicable 

### [ l Not Applicable Vapor Pressure Not Applicable 

### Specific Gravity pH Not Applicable Melting point [ ] Solubility In Water [ ] Kow - Oct/Water partition coef [ ] Viscosity Not Applicable 

# SqNiTIZED

Stability: Stable. Materials and Conditions to Avoid: None known Hazardous Polymerization: Hazardous polymerization will not occur .



## Hazardous Decomposition or By-Products Substance Condition Carbon monoxide During Combustion Carbon dioxide During Combustion Toxic Vapor, Gas, Particulate During Combustion

[Please contact the address listed on the first page of the MSDS for Toxicological Information on this material and/or its components.

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## ECOTOXICOLOGICAL INFORMATION Not determined. 

## CHEMICAL FATE INFORMATION Not determined. 

# cTIoN r3' : .n SANmZED

Waste Disposal Method: Reclaim if feasible. Incinerate in an industrial or commercial facility in the presence ofa combustible material . For quantities <1001bs. (50kg) : dispose ofwaste product in a sanitary landfill . As a disposal alternative, dispose of waste product in a facility permitted to accept chemical waste. EPA Hazardous Waste Number (RCRA) : Not regulated Since regulations vary, consult applicable regulations or authorities before disposal .

Please contact the emergency numbers listed on the first page of the MSDS for Transportation Information for this material . 

## US FEDERAL REGULATIONS Contact 3M

for more information. 311/312 Hazard Categories: Fire Hazard - No Pressure Hazard - No Reactivity Hazard - No Immediate Hazard - Yes Delayed Hazard - No 

## STATE REGULATIONS Contact 3M

for more information. 

## CHEMICAL INVENTORIES This material is not listed on the TSCA inventory and should be used for research and development purposes only under the direct supervision ofa technically qualified individual . Contact 3M

for more information. 

## INTERNATIONAL REGULATIONS Contact 3M

for more information. EPA FORM

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# SANITIZED US LABEL INFORMATION WARNING! Severe eye irritant . Moderate skin irritant. May cause sensitization by skin contact . PRECAUTIONS: See MSDS for suggested first aid and precautions. This MSDS has been prepared to meet the U .S. OSHA Hazard Communication Standard, 29 CFR 1910.1200 .



### NFPAHazard Classification Health: 2 Flammability: 0 Reactivity: 0 Special Hazards: None National Fire Protection Association (NFPA) hazard ratings are designed for use by emergency response personnel to address the hazards that are presented by short-term, acute exposure to a material under conditions offire, spill, or similar emergencies. Hazard ratings are primarily based on the inherent physical and toxic properties of the material but also include the toxic properties ofcombustion or decomposition products that are known to be generated in significant quantities. HMSHazard Classification Health: 2 Flammability: 0 Reactivity: 0 Protection: X- See PPE section. Hazardous Material Identification System(HMIS®) hazard ratings are designed to informemployees ofchemical hazards in the workplace . These ratings are based on the inherent properties ofthe material under expected conditions of normal use and are not intended for use in emergency situations. HMIS® ratings are to be used with a fully implemented HMIS®program . HMIS®

is a registered mark of theNational Paint and Coatings Association (NPCA) . Revision Changes: Section 1 : Initial issue message was modified. DISCLAIMER

: The information in this Material Safety Data Sheet (MSDS) is believed to be correct as of the date issued. 3M MAKES NOWARRANTIES, EXPRESSEDOR IMPLIED, INCLUDING, BUT NOT LIMITEDTO, ANYIMPLIED WARRANTY OF MERCHANTABILITY OR FITNESS FORA PARTICULAR PURPOSE ORCOURSE OF PERFORMANCE OR USAGE OF TRADE. User is responsible for determining whether the 3M product is fit for a particular purpose and suitable for user's method of use or application . Given the variety offactors that can affect the use and application ofa 3M product, some of which are uniquely within the user's knowledge and control, it is essential that the user evaluate the 3M product to determine whether it is fit for a particular purpose and suitable for user's method of use or application. 3M provides information in electronic form as a service to its customers. Due to the remote possibility that electronic transfer may have resulted in errors, omissions or alterations in this information, 3M makes no representations as to its completeness or accuracy. In addition, information obtained froma database may not be as current as the information in the MSDS available directly from3M

.

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