LEGRA Engineering, Inc. — Hazardous Materials Safety Interpretation

Page 1of Transportatior I.S. Department 400 Seventh St., S.W. Research and Washington, D.C. 20590 pecial Program: administratiol DEC 17 2002 Mr. Mike Stocker 5433 Eagle Industrial Court LEGRA Engineering, Inc. Ref. No. 02-0197 Hazelwood, MO 63042 ....: Dear Mr. Stocker: This responds to your letter, on behalf of Michael Martin with Pacific Rim Polymers PTY LTD - Australia, regarding confirmation of your understanding that a material described as "Aerosols, 2.2, UN1950" containing "Castor" (packaged in 50 mL to 1000 mL metal cans) is not a hazardous material for purposes of transportation. A Material Safety Data Sheet (MSDS) was enclosed. We apologize Your understanding is incorrect. The aerosol described in your letter is subject to the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180): 'As described in your MSDS, "Aerosols, 2.2, UN1950" is specifically listed by name and designated as a hazardous material in the § 172.101 Hazardous Materials Table (§ 172.101 HMT). Therefore, for purposes of transportation,"Aerosols, 2.2, UN1950" must be packaged, marked, labeled and described on shipping papers as specified in the HMR. Packagings authorized for this material are found in §§ 173.306 and 173.307. I hope this satisfies your inquiry. If we can be of further assistance, please contact us Sincerely, Vile Asilis Delmer F. Billings Chief, Standards Development Office of Hazardous Materials Standards 020197 : 172.101#

Page 2LEGRA Engrum ENGINEERING, INC. 3112.101 "'DEWATERING PUMP SPECIALISTS" Applicability MANUFACTURERS OF: LOR ENGINEERING. BLASTHOLE DEWATERING PUMPS 5433 Eagle Industrial Court , INC HIGHWALL PUMPS ".;' PONTOON, SKID & TRAILER :: PHONE (314) 731 4573 Hazelwood, MO 63042 MOUNTED PUMPS Head Office: Po Box 3177 Nth Mackay, Old. Australia 4741 FAX (314) 731 3399 Date: 7/19/02 International Phone No: (61-74) 942 3922; Fax: (61-74) 942 3868 Our Ref: No:099/02 Edward Mazzullo Director of Office of Hazardous Materials Department of Transportation RSPA DHM-10 standards 400 7th street Southwest Washington, D.C. 20590-0001 Dear Sir, I am writing this letter on behalf of Michael Martin, with Pacific Rim Polymers PTY LTD - Australia. With this letter is a Materials Safety Data Sheet for a product desired to be brought in and distributed throughout the United: States. If possible, he would like written confirmation that the products and materials would not be considered as hazardous materials for shipping purposes. If there is any additional information I may provide, please do not hesitate to contact me: At the USA address or phone numbers above. Thank you for your time and assistance. Regards, Mike Stocker Legra Engineering, Inc. USA#

Page 3MATERIALS SAFETY DATA SHEET Pacific Rim Polymers Pty Ltd. A.B.N. 67 055 534 908 A.C.N. 055 534 908 12 Archimedes Street Darra 4076 Brisbane Australia Telephone Number: 61 73375 1034 Facsimile Number:. 61 73375 1039 Emergency Number: 61 7 3375 1034 Issued: June 2002 Supercedes May 2001 "Not Hazardous According to criteria of Worksafe Australia" IDENTIFICATION Product Name: Other Name: Castor. None. Aerosols. Product Code: Worksafe Hazard Assessment: Non hazardous according to criteria of Worksafe UN Number: 1950. Australia. Dangerous Goods Class: Class 2.2. Non flammable, non toxic gas. Hazchem Code: Not scheduled. None allocated. Poisons Schedule: Use: ground decking. Acrosol inflates multilayer bag for below PHYSICAL DESCRIPTION/PROPERTIES Appearance: Clear liquid spray. (Packed in aerosol can with over cap). Boiling/Melting Point: Not determined. Vapour pressure: Complies with AS2278-2000 see ANSTO 'Certificate of Conformity No. 1012' 0.86 - 0.9 @ 20°C (page4 Specific Gravity lashpoint Not determined. Flammability Limits: Non Flammable in accordance with the Australiar Dangerous Goods Code. However, inflated lags contain flammable vapour with limits of (%) 3.4 LEL to 18.0 UEL Solubility in Water: Soluble in water. OTHER PROPERTIES/INGREDIENTS Chemical Name CAS Number Proportion Hydrocarbon Propellant 115-10-6 20-40% Other Ingredients Not determined 80-60% Page 1 of 4#

Page 4MATERIALS SAFETY DATA SHEET Product Name: Castor HEALTH HAZARD INFORMATION Acute Effects. Swallowed: Eye: If swallowed could have intoxicating effect. Skin: Inhaled: Chronic Effects. First Aid Swallowed: Eye: Flush continuously with plenty of clean water for 15 minutes. Drink quantity of water. Skin: Seek medical attention. In case of frostbite, DO NOT remove clothing, rinse with plenty of Inhalation: water. Seek medical attention. Remove affected person to the fresh air. If not breathing, give artificial respiration by mouth to mouth. Seek medical attention. Advice to Doctor: • frostbite. Treat symptomatically. In cases of excessive skin contact, treat as Toxicity Data: Major ingredient - Has LC50 of 164,000ppm. PRECAUTIONS FOR USE Exposure Standards: Worksafe TWQA & STEL: None established PEL (OSHA) & TLV (ACGIH): None established. AEL (Dupont) & WEEL (ATHA): 1000ppm, 8 & 12 Hr TWA Engineering Controls: Not available. Personal Protection: • Not required under normal conditions of use. Wear goggles and gloves if used in a confined space over a prolonged period. Flammability: Not flammable in acrosol container, in accordance with Australian Dangerous Goods Code. Inflated bag contains flammable vapour so keep away from heat , or ignition sources. Page 2 of 4#

Page 5MATERIALS SAFETY DATA SHEET Product Name: Castor SAFE HANDLING INFORMATION Storage & Transport: UN1950 AEROSOLS CLASS 2.2 NON-FLAMMABLE NON-TOXIC Keep in a cool place out of the sun. Do not heat above 65°C GAS, however is still a pressure vessel. Spills & Disposal: Do Not incinerate or puncture can, even when empty. Dispose of empty However, inflated bags should be punctured in a well ventilated area disposal a heart or ignition sources & disposed through normal waste Fire/Explosion Hazard: Aerosol can is non-flammable. Inflated bags however contain flammable vapour. Keep away from heat or ignition source. Ruptured or heated container may become a projectile hazard over a Hazardous decomposition products include carbon dioxide and carbon limited distance up to 50 metres. monoxide. SAFETY PRECAUTIONS Avoid breathing high concentrations of vapours and avoid liquid contact with skin or eyes. Use in well-ventilated area away from possible ignition sources. Whilst the information contained in this document is based on data which, to the best of MSDS is issued in accordance with Worksafe Australia guidelines and the information must not be altered or deleted in any way. Pacific Rim Polymers Pty Ltd will issue new MSDS when there is a change in specifications and/or Worksafe Australia guidelines/regulations. Page 3 of 4#

Page 6MATERIALS SAFETY DATA SHEET Onsto AUSTRALIAN NUCLEAR SCIENCE AND TECHNOLOGY ORGANISATION QUALITY CONTROL UNIT CERTIFICATE OF CONFORMITY No.: 1012 1. Client:. Pacific Rim Polymers Pty Ltd 2. Client Order No.: 00005281 3. Castor Aerosols UN 1950 Class 2.2 Description of items: Steel Aerosol Dispensers 50 mm diameter x 150 mm long b) 3 samples of filled cans a) 5 samples of unfilled cans 4. This is to certify that the above items were tested and have been found to conform to the requirements of: Australian Standard AS 2278 - 2000 "Non - refillable metal aerosol dispensers of capacity 50 mL to 1000 mL inclusive" lection 3. Clause 3.4 Maximum Pressure ection 2. Clause 2.2 Hydraulic Test, Clause 2.3 Bursting tes Try testering horator age a No, New are red as 3 une, 2002 NSW 2234 Australia. 5. Variation to Standard: Nil For and on behalf of Ansto Engineering Quality Control Unit S.. Surelair S.Sinclair NATA Approved Signatory B. Ducker. Manager,, Quality Control Unit Date: 3 June, 2002 EQC F 10 1.1 Contact Point: Pacific Rim Polymers. Tel: 61 7 3375 1034 Page 4 of 4 Mike Martin. Tel: 0408 398 510 = 61 408 398 510 International#