Make sure your risk assessment identifies all of the points from the above posts. You should swab 8 or 10 areas in your facility and include the results with your request (unless they show high levels of pathogens / bacteria). Clarify each in a written document as well as the other factors you feel contribute to your contention. Sent it to the technical dept of your CB and wait for their response. If they accept it, great! If not, they should send a response with the reason for denying the request, you might still get the exemption if you can adequately show their assessment is flawed and why, or it might have just been information you didn't include initially and re-submit that with the exemption request.
We are (still) in the process of requesting the same exemption. We produce paperboard packaging (for over 70 years) and, unfortunately, deterimned in house that the spirit as well as the letter of the code did not apply and we got a major NC as a result. The risk assessment information was contained within our HACCP plan but not separately on a matrix. We have, however, successfully received an exemption from Food Fraud. It is possible but make sure you do your homework.