Tecpro Corporation — Hazardous Materials Safety Interpretation

Page 1J.S. Depatmen f Transportation 400 Seventh Street, S.W. Washington, D.C. 20590 Pipeline and Administration Hazardous Materials Safety MAY 10 2005 Mr. Jay Lozier Ref. No. 05-0059 EHS & Q Manager Tecpro Corporation 3555 Atlanta Industrial Parkway Atlanta, GA 30331 Dear Mr. Lozier: This responds to your letter dated March 8, 2005, regarding the applicability of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) to ferrosilicon alloy samples containing 25-73% silicon. Specifically, you request confirmation from this Office that the test reports submitted with your letter provide sufficient verification that the tested materials are not subject to the requirements of the HMR. As provided in § 173.22, it is a shipper's responsibility to properly classify a hazardous material. Such determinations are not: required to be verified by this Office. However, based on the test results you provided, it is our opinion that the ferrosilicon imported by your company does not meet the definition of a Division 4.3 material and, provided it does not meet the criteria for another hazard class, it is not subject. to the HMR. can be of further I trust this satisfies your inquiry. Please contact us if we assistance. Sincerely, Hattie L. Mitchell Chief, office of Hazardous Materials Standards Regulatory Review and Reinvention 173,132 050059#

Page 2tecpro SÜD-CHEMIE Member of the SÜD-CHEMIE Group DOT/REPA/OLMS Creating Performance Technology ... tecpro corporation March 8, 2005 3555 Atlanta Industrial Parkway Atlanta, GA 30331 Associate Administrator for Hazardous Materials Safety Telephone: (404) 691-721: -ax: (404) 691-751: Pipeline and Hazardous Materials Safety Administration U.S. Department of Transportation Stevens 400 7th Street, SW. Washingtor, D.C. 20590-0001 $173.132 Attention: DHM-31 Definitions Re: Exemption for 4 Ferro-Silicon Alloys 05-0059 Ladies and Gentlemen: On behalf and for Tecpro Corporation 3555 Atlanta Industrial Parkway Atlanta, GA 30331 1, Jay Lozier, EHS&Q Manager, Tecpro Corporation, request that the transportation in and 6.1 (UN1408) (49CFR173.123(c) and 49CFR173.132) and the placarding commerce of the following ferrosilicon alloys be exempt from the Hazards Classes 4.3 requirements in 49CFR172.101: Alloy Sizes Currently Imported Tecproloy 75 22 30 mesh Tecprosel Tecprosid B 8 mesh x down ¼" × 32 mesh 6 × 48 mesh 14 mesh x down Tecprosid 20 ¼" × 32 mesh 3¾" × 3" mesh Laboratory testing by Stressau Laboratory of Spooner, WI (copy attached) shows that none of these alloys meet the requirements for Hazard Class 4.3 as set forth in 49CFR173.123(c). The rate of gas evolution by these alloys was significantly below the requirement of greater than 1 l/kg/hr for Hazard Class 4.3. (ISO 9001:2000 FEF Alloys, Inoculants, Cored Wire CORPORATE MEMBER and Refractory Coatings DANU#

Page 3US Department of Transportation teepre Page 2 of 3 March 8, 2005 These alloys are in the form of grains and pieces and do not have a significant fraction n the 10 micron size for inhalation toxicity. The amount that is less than 270 mesh (5. nicron) is less 5% for all these alloys (Typical sieve analysis for each is attached They also are not ingestion or dermal hazards. These alloys do not meet the requirements of 49CFR173.132 for Hazard Class 6.1. These alloys are imported from Japan for resale to US foundries. The manufacturer classifies them as hazardous and when we ship them we use the manufacturer's classification as required. They are normally sold in their original packaging. If repackaged, containers meeting the requirements in the Hazardous Material Table of 49CFR172.101 and referenced sections are used. Note we also import one size of Tecprosid 3 (14 mesh x down) primarily for the manufacture of cored wire powder filler. The cored wire filler is not included in this request. The typical annual amount of each product that we sell per year is: Tecproloy 75 120,000 Ibs Tecprosel 401,000 Ibs Tecprosid B 768,000 Ibs for resale 100,000 Ibs for blending into wire powder filler Tecprosid 20 84,000 Ibs Our monthly shipments are fairly constant, for example we would ship about 64,000 Ibs/month of Tecprosel with a typical maximum of about 70,000 Ibs and typical minimum he average shipment size is about 6,350 Ibs. Shipment size ranges from 500 lbs to of about 60,000 Ibs. There are about 16 - 20 shipments to customers per month anc 41,300 Ibs. There are also about 4 - 5 shipments each month from our Atlanta warehouse to our distribution warehouses, each about 8,000 Ibs. Inbound shipments, in containers, come to either our Atlanta warehouse or directly to our distribution warehouses. We are not aware of any transportation incidents with these materials either when inbound from Japan or during shipment by us or our distribution warehouses. Also, we are aware that other similar ferrosilicon alloys that we purchase are exempted from the hazardous material requirements. We ship these materials by motor vehicle, rail freight, and cargo vessel. The effective date we request is August 1, 2005 and this exemption would be indefinite, subject to renewal as specified 49CFR107.109.#

Page 4US Department of Transportation Page 3 of 3 March 8, 2005 Also, we have enclosed the current Technical Data Sheets for each alloy covering the material for resale. If you need further information or have any question please contact the undersigned. Yours truly, EHS&Q Manager Phone: (404)-691-7213 Email: jlozier@tecprocorp.com Fax (Direct): (404)-691-4794 Enclosures#

Page 5tecpro corporation tecpro 3555 Atlanta Industrial Parkway SÜD-CHEMIE Atlanta, Georgia 30331-1055 Creating Performance Technology Tel. Number: (404) 691-7213 Fax Number: (404) 691-7518 (800) 262-6296 TECPROSEL® A product proven to substantially reduce these inclusions and defects Mg Dross and Exploded Nodules Typical Mg Dross Silicate Slags and Graphite Pockets Silicate Slags and Lamellar Graphite profits of almost every ductile iron foundry. Slag and dross inclusions in castings are eating up the 1" thick wall. in a thin wall is much more serious than it would be in a specifications requiring thinner walls, less machining Today's ductile iron foundries are faced with casting TECPROSEL represents a development for the machinability. A clean melt, free of slag and dross allowance, a clean casting surface and very good slag inclusions or inclusion cavities in castings. metallurgical "cleaning" of iron melts and for diminishing inclusions, is undoubtedly the key to success. since TECPROSEL is a combination of metallurgical TECPROSEL is not to be compared with known fluxes, The small slag and dross particles suspended for some time (approx. 80%) and chemical products. in the melt after magnesium treatment of ductile iron and after post inoculation in the ladle stream are very difficult to surprisingly effective. Very small additions of TECPROSEL to the melt are catch with ladle deslagging and even with elaborate gating casting close to or at the surface, usually in areas which systems and filters. The particles often end up in the Under certain foundry conditions, scrap due to slag and have to be machined with very expensive dross inclusions has been reduced substantially. When it comes to fatigue, the same slag or dross inclusion high-speed tools. July 16, 2004 Issue Number: 6#

Page 63555 Atlanta Industrial Parkway tecpro corporation tecpro Atlanta, Georgia 30331-1055 Creating Performance Technology SÜD-CHEMIE Tel. Number: (404) 691-7213 Fax Number: (404) 691-7518 (800) 262-6296 TECHNICAL INFORMATION TECPROSEL® Nominal Analysis Si 40.0-50.0% Mg 6.0- 9.0% TRE 2.5- 5.0% Ca 12.0-16.0% F Trace Fe Balance Screen Size: 8 mesh-down APPLICATION OF TECPROSEL® DUCTILE IRON (1 Ib for 1,000 lb melt) TECPROSEL, together with the We recommend the addition of approx. 0.1% by weight FEATURES ½ Ib, 1 Ib or 1 kg bags can be used without further Mg treatment alloy. Addition in either the prepackaged (a) Liquidization of reaction products. weighing in mos: cases. (b) Lowering of surface tension of the liquid iron results in an easier release of the MgS dross and treatment ladle to pouring ladle, usually together with the TECPROSEL also can be added during the transfer from (c) The oxide film-forming temperature is lowered. Magnesium-Oxy-Silicate slag to the melt surface. would be 0.05% by weight or approx. 10% by weight of post inoculants. In this case the recommended addition (e) Good nodularizing and inoculation effect. (d) Fluidity of melt is increased. the post inoculant. (f) Slows fading. (9) Substantial reduction of slag build-up in ladles or treatment chambers; for instance, tundish ladles, etc. GENERAL INFORMATION PACKAGING STORAGE 1 kg (2.2 Ib) plastic bag, 300 bags in a steel drum TECPROSEL should be stored in a dry, well- 1 Ib plastic bag, 680 bags in a steel drum ventilated place and protected against water or ½ Ib plastic bag, 1100 bags in a steel drum Custom size packaging available, depending on with acids, acid fumes, acid vapors, and it must dampness. It must not be brought into contact minimum requirements. be kept clear of ignition sources. recommendations or suggestions contained in this bulletin are made without guarantee or representation as to results, since the conditions of use The information and data contained herein are, to the best of our knowledge, true and correct on the basis of thorough test experience. All Corporation disclaims any liability incurred in connection with use of these data or recommendations. None of the information herein should be are beyond our control. We suggest that the user evaluate these recommendations and suggestions in his own application before use. Tecpro whole or in part, only with the express permission of Tecpro Corporation. construed as a recommendation to use any product or process in conflict with existing patents covering any material or its use. Reproduction, in With the issue of this information, all previous publications and information, including brochures, pamphlets, etc., are considered null and void. July 16, 2004 Issue Number: 6#

Page 7teepro corporation tecpro 3555 Atlanta Industrial Parkway Atlanta, Georgia 30331 SÜD-CHEMIE Creating Performance Technology CHEMIE Fax: (404) 891-7313 Customer Service: 1-800-262-6296 MATERIAL SPECIFICATION TECPROSID 20 MATERIAL DESCRIPTION Rare Earth inoculant especially formulated for gray iron inoculation with a strong effect on chill reduction and improved machinability. NOMINAL ANALYSIS Si TRE 25.0 - 35.0% 18.0 - 22.0% Ca (Ce 47 - 52%, La 25 - 30%) 2.0% max. Al 1.0% max. Mn 1.0% max. Fe Balance SIZES 1/4 " - 32 mesh (0.5-6 mm) 6 - 48 mesh (0.3 - 3 mm) PACKAGING 2950 Ib. net super sack on pallet or 500 Ib. net steel drum Tagging on each sack/drum: alloy type size shipping number GENERAL The Tecprosid 20 alloy should be stored in a dry, well-ventilated place and protected against water or dampness. It must not be brought into contact with acid, acid fumes, or acid vapors. Make sure that all employees read and understand the precautionary labels before material is used. RECOMMENDED ADDITION 0.15 - 0.30% by weight ALLOYS, INOCULANTS, CORED WIRE, AND REFRACTORY COATINGSG February 10, 2005 Issue Number: 10#

Page 8tecpro Creating Performance Technology SÜD-CHEMIE el.: (404) 691-721 ax: (404) 691-75• Customer Service: 1-800-262-6296 MATERIAL SPECIFICATION TECPROSID B MATERIAL DESCRIPTION Rare Earth Silicide alloy especially suited for addition to ductile iron melts because of its very low Ti content. Very effective as pre-conditioner for ductile iron when pure Mg or high Mg- containing alloys are used for treatment. NOMINAL ANALYSIS Si 30.0 - 40.0% TRE 30.0 - 33.0% Ca 2.0% max. (Ce 47 - 52%, La 25 - 30%) Al 1.0% max. Mn 0.5% max. Ti 0.5% max. Fe Balance SIZES 3/8 " - 14 mesh (1-10 mm) 3/4" - 3/8" (10 - 19 mm) PACKAGING In 2950 Ib. net super sack on pallet or 500 Ib. net steel drum Tagging on each sack/drurn: alloy type shipping number GENERAL The Tecprosid B alloy should be stored in a dry, well-ventilated place and protected against water or dampness. It must not be brought into contact with acid, acid fumes, or acid vapors. Make sure that all employees read and understand the precautionary labels before material is used. The information and data contained herein are to the best of our knowledge and intended to provice general notes on our the conditics of use are beyond our control. products ard their uses. All recommendations or suggestions are made without guarantee or representation as to results, since own application before use. Tecpro Corporation disclaims any liability incurred in connection with use of these data or We suggest that the user evaluate these recommendations and suggestions in his conflict with existing patents covering any material or its use. recommendations. None of the information herein should be construed as a recommendation to use any product or process in ALLOYS, INOCULANTS, CORED WIRE, AND REFRACTORY COATINGSG March 4, 2005 Issue Number: 7#

Page 9tecpro corporation cecpro 3555 Atlanta Industrial Parkway Atlanta, Georgia 30331 Creating Performance Technology SUD-CHEMIE Tel.: (404) 691-7213 Fax: (404) 691-7518 MATERIAL SPECIFICATION Customer Service: 1-800-262-6296 Tecproloy 75 MATERIAL DESCRIPTION Proprietary inoculant for the inoculation of gray iron and ductile iron (ladle and instream). NOMINAL ANALYSIS Si 68.0 - 73.0% Ca 1.0 - 1.6% 1.0 - 1.8% Al 1.5 - 2.1% Trace Elements Fe Approx. 0.5% Balance SIZE ¼" - 32 mesh (6 mm - 0.5 mm) 32 mesh - 80 resh (0.5 - 0.20 mm) TESTS PERFORMED (a) visual test: foreign elements - none BY PRODUCER slag -- none (b) chemical analysis and screen analysis of each shipment leaving the plant PACKAGING In 1 MT net (2205 lb.) super sacks on pallets or 500 Ib net steel drums Tagging on each sack/drum: alloy type size shipping number GENERAL The Tecproloy 75 alloy should be stored in a dry, well-ventilated place and protected against water or dampness. It must not be brought into contact with acid, acid fumes, or acid vapors. Make sure that all employees read and understand the precautionary labels before material is used. RECOMMENDED 0. 10% (by weight) instream inoculation ADDITION 0.30% (by weight) ladle inoculation products and their uses. All recommendations or suggestions are made without guarantee or representation as to results, since The information and data contained herein are to the best of our knowledge and intended to provide general notes on our the conditiors of use are beyond our control. We suggest that the user evaluate these recommendations and suggestions in his own applicalion before use. Tecpro Corporation disclaims any liability incurred in connection with use of these data or recommendations. conflict with existing patents covering any material or its use. None of the information herein should be construed as a recommendation to use any product or process in ALLOYS, INOCULANTS, CORED WIRE, AND REFRACTORY COATINGSG February 28 2005 Issue Number: 6#

Page 10• STRESAU LABORATORY INC. N8265 Medley Road, Spooner, WI 54801-7819, Tel. 715-635-2777, Fax 715-635-7979 www.stresau.com 1:: February 24, 2005 Mr. Jay Lozier Tecpro Corporation 3555 Atlanta Industrial Parkway Atlanta, GA 30331 Dear Mr. Lozier: Enclosed please find Laboratory Report # 05015-05018 for Water Reactivity testing of your samples. criteria. Full details are in the enclosed report. Your samples appear not to be 4.3 Dangerous When Wet Materials, as defined by the DOT/UN An invcice to cover the cost of the laboratory examinations will be sent to your accounting department under separate cover. Your sample remnants will be returned to you shortly. We appreciate your business. If we may be of further assistance or if you have any questions, please call Tom Basham or myself at (715) 635-2777. Sincerely, Thoms f. Gastam Hazardcus Materials Manager Thomas E. Basham tb(05015-05018) Over Thirty years of Development C Evaluation C Production of Energetic Devices Classification C Packaging C Testing of Hazardous Materials#

Page 11STRESAU LABORATORY INC. N8265 Medley Road, Spooner, WI 54801-7819, Tel. 715-635-2777, Fax 715-635-7979 www.stresau.com LABORATORY REPORT # 05015-05018 "WATER REACTIVITY TESTING" February 24, 2005 for Tecpro Corporation 3555 Atlanta Industrial Parkway Atlanta, GA 30331 Attn: Mr. Jay Lozier Prepared by: Thorn E. Baham Thomas E. Basham Hazardous Materials Manager Reviewed by: Michael J. Pesko Chief Operating Officer Over Thirty years of Development Evaluation .. Production of Energetic Devices Classification C Packaging O Testing of Hazardous Materials#

Page 12• • STRESAU LABORATORY, INC. LABORATORY REPORT NO. 05015-05018 1: 1 February 24, 2005 Page 1 of 4 repared for Tep Corporadiostial Parkway Atlanta, GA 30331 Subject: Water Reactivity Testing • 1.0 OBJECT Four samples identified below were received and subjected to a Water Reactivity test in accordance with the US Code of Federal Regulations, Title 49, paragraph 173.125(d) and the United Nations Transport of Dangerous Goods -Manual of Tests and Criteria - Third revised edition as requested by Jay Lozier, of Tecpro Corp., Purchase Order # 11345. 2.0 IDENTIFCATION AND PHYSICAL APPEARANCE Teepro ID Stresau ID # Appearance Tecprosel 05015 Crushed alloy with gray metallic color Tecproloy 75 05016 Crushed alloy with gray metallic color Tecprosid B 05017 Crushed alloy with gray metallic color Tecprosid 20 05018 Solid chunks with gray metallic color and were tested in the form received The samples were contained in plastic jars. The samples arrived at Stresau at ambient temperature, 3.0 TEST CONDUCTED 3.1 Water Reactivity Test UN test N.5 3.1.1 Gas Evolution tests: Three trials were conducted, with results as follows: Sample # 05015 - Tecprosel a) Sample weight: 25.0 grams Distilled water: 25 mls Room temperature at start of test: 71.9 °F Monitored for: 8 hours Maximum gas evolution rate: 0.48 L/kg/hr (measured in the first hour)#

Page 13STRESAU LABORATORY, INC. LABORATORY REPORT NO. 05015-05018 February 24, 2005 Page 2 of 4 b) Sample weight: 25.0 grams Distilled water: 20 mls Monitored for: 8 hours Room temperature at start of test: 71.9°F Maximum gas evolution rate: 0.56 L/kg/hr (measured in the first hour) c) Sample weight: 25.0 grams Room temperature at start of test: 71.6°F Distilled water: 25 mls Monitored for: 8 hours Maximum gas evolution rate: 0.32 L/kg/hr (measured in the first hour) 3.1.2 Sample # 05016 - Tecproloy 75 a) Sample weight: 25.0 grams Distilled water: 25 mls Room temperature at start of test: 71.6°F Monitored for: 8 hours Maximum gas evolution rate: 0.20 L/kg/hr (measured in the first hour) b) Sample weight: 25.0 grams Distilled water: 20 mls Room temperature at start of test: 73.3°F Monitored for: 8 hours Maximum gas evolution rate: 0.24 L/kg/hr (measured in the first hour) c) Sample weight: 25.0 grams Room temperature at start of test: 73.3°F Distilled water: 25 mls Monitored for: 8 hours Maximum gas evolution rate: 0.20 L/kg/hr (measured in the first hour) 3.1.3 Sample # 05017 - Tecprosid B a) Sample weight: 25.0 grams Distilled water: 25 mls Room temperature at start of test: 72.1°F Monitored for: 8 hours Maximum gas evolution rate: 0.52 L/kg/hr (measured in the first hour)#

Page 14STRESAU LABORATORY, INC. LABORATORY REPORT NO. 05015-05018 February 24, 2005 Page 3 of 4 b) Sample weight: 25.0 grams Distilled water: 22.5 mls Monitored for: 8 hours Room temperature at start of test: 72.1°F Maximum gas evolution rate: 0.54 L/kg/hr (measured in the first hour) Sample weight: 25.0 grams Room temperature at start of test: 71.8ºF Distilled water: 25 mls Monitored for: 8 hours Maximum gas evolution rate: 0.48 L/kg/hr (measured in the first hour) 3.1.2 Sample # 05018 - Tecprosid 20 Sample weight: 25.0 grams Distilled water: 15 mls Room temperature at start of test: 71.8°F Monitored for: 8 hours Maximum gas evolution rate: 0.28 L/kg/hr (measured in the first hour) b) Sample weight: 25.0 grams Distilled water: 15 mls Monitored for: 8 hours Room temperature at start of test: 71.8°F Maximum gas evolution rate: 0.24 L/kg/hr (measured in the first hour) Sample weight: 25.0 grams Distilled water: 15 mls Room temperature at start of test: 72.3°F Monitored for: 8 hours Maximum gas evolution rate: 0.28 L/kg/hr (reasured in the first hour) Criteria: (a) Spontaneous ignition takes place in any step of the test procedure; or (b) If there is an evolution of a flammable gas at a rate greater than 1 litre per kilogram of the substance per hour.#

Page 15STRESAU LABORATORY, INC. LABORATORY REPORT NO. 05015-05018 February 24, 2005 Page 4 of 4 4.0 CONCLUSIONS Based on the above test results it is seen that: 1) The materials represented by samples # 05015-05018 do not appear to be Division 4.3 Dangerous When Wet Materials, as defined by the UN/DOT criteria. This is because the -. samples did not produce a flammable gas at a rate of greater than 1 liter/kilogram/hour. 5.0 DATA STORAGE The field data for this report are contained in Data Book # SLF 2005-1, and filed with Stresau Laboratory's Document Control. No photographic or video documentation was made. 6.0 TEST SERVICES testing services to either expedite or qualify our own testing capabilities. For the benefit of our customers, Stresau Laboratory, Inc., will on occasion, use outside#

Page 16Cummulative Retained 0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100% 25 50 75 125 -Tecprosid 20 Cumulative% -Tecproloy 75 Cumulative % -Tecprosel Cumulative % 150 175 Seive Analysis of Ferro-Silicon Alloys USA Sieve No, Pan = 400 200 225 250 275 300 325 350 375 400#

Page 17Date 3/7/2005 Product Tecprosid 20 Nominal Size 1/4" × 32 mesh Amount Retained on Sieve USA Sieve No. Total Mass Grams Retained % Cumulative % 14 375.65 375.65 85.60% 85.60% 20 417.19 41.54 9.47% 95.07% 30 431.57 14.38 3.28% 98.34% 40 434.03 2.46 0.56% 98.90% 50 435.04 1.01 0.23% 99.13% 70 435.94 0.90 0.21% 99.34% 80 436.26 0.32 0.07% 99.41% 100 436.53 0.27 0.06% 99.47% 140 437.03 0.50 0.11% 99.59% 200 437.43 0.40 0.09% 99.68% 270 437.75 0.32 0.07% 99.75% Pan 438.84 1.09 0.25% 100.00% TOTALS 438.84 100.00% Screened By: JSL#

Page 18Date 317/2005 Product Tecproloy 75 Nominal Size 32 x 80 mesh Amount Retained on Sieve USA Sieve No. Total Mass Grams Retained % Cumulative % 14 0.06 0.06 0.01% 0.01% 20 0.14 0.08 0.02% 0.03% 30 23.54 23.40 5.70% 5.74% 40 275.47 251.93 61.41% 67.15% 50 367.07 91.60 22.33% 89.48% 70 397.35 30.28 7.38% 96.86% 80 403.88 6.53 1.59% 98.45% 100 407.37 3.49 0.85% 99.31% 140 409.32 1.95 0.48% 99.78% 200 409.62 0.30 0.07% 99.85% 270 409.70 0.08 0.02% 99.87% Pan 410.22 0.52 0.13% 100.00% TOTALS 410.22 100.00% Screened By: JSL#

Page 19Date 3/7/2005 Product Tecprosel Nominal Size _8 mesh x down Amount Retained on Sieve USA Sieve No. Total Mass Grams Retained % Cumulative % 14 73.80 73.80 19.82% 19.82% 20 175.27 101.47 27.25% 47.07% 30 246.12 70.85 19.03% 66.10% 40 287.34 41.22 11.07% 77.17% 50 301.85 14.51 3.90% 81.06% 70 342.75 40.90 10.98% 92.05% 80 346.80 4.05 1.09% 93.13% 100 352.08 5.28 1.42% 94.55% 140 359.15 7.07 1.90% 96.45% 200 365.87 6.72 1.80% 98.25% 270 369.84 3.97 1.07% 99.32% Pan 372.37 2.53 0.68% 100.00% TOTALS 372.37 100.00% Screened By: JSL#

Page 20Date 3/7/2005 Product Tecprosid B Nominal Size 14 mesh x down Amount Retained on Sieve USA Sieve No. Total Mass Grams Retained % Cumulative % 14 0.00 0.00 0.00% 0.00% 20 51.32 51.32 9.20% 9.20% 30 185.35 134.03 24.03% 33.24% 40 304.39 119.04 21.35% 54.58% 50 373.90 69.51 12.46% 67.05% 70 440.59 66.69 11.96% 79.01% 80 463.59 23.00 4.12% 83.13% 100 482.28 18.69 3.35% 86.48% 140 509.32 27.04 4.85% 91.33% 200 523.75 14.43 2.59% 93.92% 270 534.92 11.17 2.00% 95.92% Pan 557.66 22.74 4.08% 100.00% TOTALS 557.66 100.00% Screened By: JSL#

Page 21.S. Depanmen f Transportation 400 Seventh Street, S.W. Washington, D.C. 20590 Pipeline and Hazardous Materials Safety Administration MAY 6 2005 Ms. Dianna F. Lee Ref. No. 05-0062 Mali. broad Sitect, Inc. Phillipsturg, NJ 08865 Dear Ms. Lee: This responds to your November 3, 2004 letter and March 18, 2005 fax requesting clarification on the labeling requirements for 'Methanol' when shipped domestically and internationally under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171- with international requirements when shipped domestically only. 180). Specifically, you ask whether it is permissible to label the package in compliance The answer is yes. As your letter notes, the Hazardous Materials Table (HMT) includes two entries for methanol, one for international transportation and one for domestic transportation. The two entries are identical, except that the international entry requires a subsidiary hazard Division 6.1 label, and the domestic entry does not. In accordance with § 172.101(b)(3) and (b)(5), you may use either the international or domestic entry in the HMT for domestic transportation of methanol. I hope this answers your inquiry. Chief, Standards Development Office of Hazardous Materials Standards 172.101 172.414 050062#

Page 22MAR. 18'2005 11:06 9088599411 MALBAKER QUALITY DEPT #0650 P.002/003 Boothe tyco 3172.101 Specialty Products 3M2419 Fax: 908-859-9411 Tel: 908-859-2151 Mallinckrodt Baker abel inc 15-0072 Mr. Edward T. Mazzullo Director, Office of Hazardous Materials Standards U.S. DOT/PHMSA (DHM-10) 400 7th Street S.W. Washington, D.C. 20590-0001 November 3, 2004 Dear Mr. Mazzullo, This letter is a request for a letter of interpretation regarding a hazardous material, methanol. To give you a brief overview of the situation, our company sells methanol as a product, and traditicinally have been packaging and labeling them separately for domestic and The current 49 CFR specifies in the Hazardous Materials Table (172.101) that for a letter "D'"; and one for international (denoted by a letter "'") shipping purposes. The Methanol, IJN1230, PGIl, there exists two entries, namely one for domestic (denoted by two entries are identical except for the labeling codes required. International shipping requires both a flammable label (3) and a toxic label (6.1) in order to meet the requirements for hazard classes. Domestic shipping, however, only requires the flammable label (3), and there is no mention of toxicity hazards associated with the chemical. According to section 172.101(b)(5), "The letter "'" identifies proper shipping names which are appropriate for describing materials in international transportation. An involved." My interpretation of this is that although we may choose to use the domestic proper shipping name may be selected when only domestic transportation is classificatic with only the flammable label and hazard class 3 requirement for methanol, we will not be out of compliance if we choose to disclose the toxicity hazard and classify our product (methanol) as class 3, with a subsidiary hazard class of 6.1, which requires both the flammable and toxic labels for domestic shipping only purposes.#

Page 23MAR. 18'2005 11:06 9088599411 MALBAKER QUALITY DEPT #0650 p. 003/003 I would appreciate it if you can please reply back with an official interpretation from the hazmat administration regarding this issue as to whether or not we would be incorrect and out of compliance to affix both flammable(3) and toxic(6.1) labels on a package of methanol shipped domestically only. The response can be forwarded to the below address, and should you have any questions, please feel free contact me at the number also provided below. Mallinckrodt Baker, Inc. 600N. Broad Street Phillipsburg, NJ 08865 (908)859-2151 ext. 9764 Once again, thank you in advance for you help and clarification in this matter, and I look forward to hearing from you. Sincerely, Di L. Le Dianna F. Lee Quality Information Administrator#