Samax Enterprises — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation 400 Seventh Street, S.W. Washington, D.C. 20590 Pipeline and Administration Hazardous Materials Safety JUL 11 2006 Mr. Perry J. Patton Ref. No.: 06-0136 154 Eastwood Blvd. Samax Enterprises Centereach. NY 11720 Dear Mr. Patton: requirements of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). This is in response to your May 26, 2006 letter regarding the marking and labeling You include a flammable liquid hazard label, an inhalation hazard label, and an (MSDS) for the "Liquid No Wash" product. Specifically, you ask if the labels and orientation arrow marking in your letter. You also provide a Material Safety Data Sheet orientation markings included in your letter are required to be displayed on a 5-gallon container of the product. Under § 173.22, it is the shipper's responsibility to properly class and describe a hazardous material. Marking and labeling requirements are based on the proper shipping description of the hazardous material. The MSDS sheet for your product indicates the PG II." For a material described as such, the "Flammable liquid" label specified in proper shipping description for "Liquid No Wash" is "Paint related material, 3, UN1263, § 172.419 and included in your letter must be displayed on the outer surface of the ackage. An inhalation hazard label may not be displayed on a package containin Liquid No Wash" because the material does not meet the definition of a poiso inhalation hazard. Orientation arrow markings must be displayed on two opposite vertical sides of a combination package having inner packagings containing liquid displayed on the surface of a single package (e.g., a 5-gallon container) or inne: hazardous materials. Although not required by the HMR, orientation arrows may be packaging. I hope this information is helpful. If you have further questions, please do not hesitate to contact this office. Sincerely, Chief, Standards Development Office of Hazardous Materials Standards 172.419 173.22 060136#

Page 2: Eichenlaub §172. • 400,419 §113.22. SAMAX ENTERPRISES labeling 06-0136 May 26, 2006 To: Edward Mazzullo From: Perry J. Patton Dear Sir: We are requesting a review of the enclosed 5-gallon container labels. label. Are we or are we not required to use both? Which label takes precedence over the other? Our biggest concer is the inclusion on the container of the flammable liquid label and inhalation hazard Any assistance you can provide will be greatly appreciated. If you want to speak to us directly, please contact me at the following number. 631-580-2237. Otherwise, I can be reached at the following: Address: 154 Eastwood Bivd. Centereach, NY 11720 Fax: 631-580-2239 E-mail: oshacorp@optonline.net Thank you. Regards,#

Page 3FROM : FAX NO. : Jun. 16 2006 Ø1:16PM P2 MATERIAL SAFETY DATA SHEET LIQUID NO WASH Revised: January 2003 [ Cheniont Product and Company Identification Product Name Synonyms and Trade Names Liquid No Wash Chemical Pamily Proprietary Mixture Formula Not Applicable Organic Solvent Mixturc Telephone (Fmergencies)* Telephone (General Information) 1-800-545-7658 Samax Enterprises 1-800-424-9300 Company Address *In case of an emcrgency involving spills, leaks, fire exposure, or accidents related to this produci call 29-75 Riverside Ave, Newark, N.J. 07104 CHEMTREC - 1-800-424-9300. 12. Composition / Information on Ingredients INGREDIENT Dichloromethano CAS NUMBER FOO2, Koop Away From HAZARD CLASS ACGIH TLV-TWA D001, Flammable Liquid 50 ppm PFI** 100 ppm 1T.V 25 ppm PEL** D001, Flammable Liquid Acetone 67-64-1 D001, Flammable Liquid Poison 1000 ppm PEL ** 50 pm 1LV ** PEL = OSHA Permissible Exposure Limit L3 Physical Data Vapor Pressure @ 20°C. Boiling Point 40°C 104°P Vapor Density @) 1 Atmosphere < 1 atm. PH Specific Gravity NA .98 Appearance Percent Volatile by Volume > 90 < 8.9 Odor Clear to Slighty Cloudy Liguld Physical State Evaporation Rate (ether =i) Solvent, Aromatic Solubility Liquid Flash Point > 40% 47°C 90°F#

Page 4FROM : FAX NO. : Jun. 16 2006 Ø1:16PM P3 24. Health Hizard Data. 2:2203 1202 • Potential effects of a single (Acuto Overexposure) Eye: May cause severe burns and possible irruversible eye damage if contact is made. Skin: May be irritating if confined un the skin by gloves or clothing. May be absorbed slowly hrough the skin into the bloodstream and cause symploms listed below under inhalatior Ingestion: May cause blindness and death. May cause headachc, nausea, vomiting, diarrhca, blood in urine, dizziness and unconsciousioss. Chronic: CM is listed as a possible carcinogen by the ACGIH. Chronic over exposure to Toluer system. lay cause kidney and liver failure. Methanol causos toxic effect to the central nervol ES. First Aid Measures Note: Specialized First Aid and Medical Treatment are Required for all Exposures Eyes: minutes, occasionally lifting the upper and lower lids. Seek medical aid immediately. Remove contact lenses (if applicable). Plush yos with plenty of water for at Icast 15 Skin: removing any contaminated clothing. Do not try to neutralize with chemicals. Seel lush effected area of skin with plunty of soap and water for at least 15 minutes while medical aid immediately. Ingestion: Never give anything by mouth to an unconscious person. Sock medical aid immediately. If conscious, give large amounts of wator to drink and induce vomiting. Inhalation: Remove from exposure to fresh air immediately. Keep the victim quit, lying down and as comfortable as possible. Seck immediately medical attention. If not breathing, give artificial respiration at once. If breathing is difficult, give oxygen. Notes to Physician: Treat symptomatically and supportively. L6. Fire Fighting Measures General Information: Product is highly fammable. Vapors may ignite under certain conditions when bum on top of water. Cool exposed containers. exposed to an ignition source. Product is only partially soluble in water and may float and Extinguishing Media: Extinguish fire using an agent suitable for type of surrounding fire c.f. foam, CO2, or dry chemical. Water may be used as a last resort.#

Page 5FROM : FAX NO. : Jun. 16 2306 Ø1:16PM P4 7-Accidóntil Release Mensures: " 22C Spills/Leaks: Woar suitable Personal Protective Fiquipment (PPE). Vontilalc the area as wel! a vermiculite, dry sand, earth, or similar material and place into a scaled container for proper possible before entering. E'liminate/remove any source of ignition. Absorb liquid witt Hundling: Always wear suitable PPE. Rubher or viny! gloves are recommended, do not wear leathe or cloth. Wash thornughly after handling. Romove contaminated clothing and wash before re sc. , and a duac vinitation. Keep container tighty closed, avold skin and eye 8, Exposire Controls, Personal Protection Eguipment Engineering Controls: Use adequate general or local oxhaust ventilation to keep airborne concentrations below the permissible exposure limit of 25 ppm. Personal Protective Equipment: Eyes: Skln: Wear appropriate protective clothing to provont skin exposure. Clothing: Wear appropriate protective clothing to prevent skin exposure. Respirators: Where required, use an appropriate NIOSH, OSHA, or MSHA respirator as applicable. Some exposures may require a SCBA. Follow the OSHA respirator regulations found in 29 CFR 1910.134 or European Standard EN 149 for approved respirator when necessary. (Stability and Reactivity. Chomical Stahility: Stable under normal tempcrature and pressures. Conditions 1o Avold: Keep away from food products, acids, strong oxidizers, alkali metals, heat and spark or flame producing items. Huzardous Decomposition Products: Nol Applicable. Hazardous Polymerization: Will not occur.#

Page 6FROM : FAX NO. : Jun. 16 2006 Ø1:17PM P5 Eio. Regulatory Information CERLA RQ: 73-09-2-1.000lbs 108-88-3=1,000lbs 7-56-1=5,000 1b 7-64-1=5,0001bs RCRA D Sertes: RCRA F Series: CAS# 108-88-3 - D001, CAS# 67-64-1 - D001, and CAS# 67-56-1 - D00 CRA U Sorles RCRA l' Series: :AS# 75-09-2 - F002 one Liste one Listi US D.O.T. Hazard Class: 3 US D.O.T. Shipping Name: Paint Related Material US D.O.T. Identification Number: UN 1263 Pkg I1 • Health: HMIS & NFPA Information: • Flammability: 3 • Reactivity: • Corrosivity: 2 ISCA: • Health and safety list: None of the chemicals in this product are listed. None of the chemicals in this product are listed. • Chemical test rules: None of the chemicals in this product are under a chemical test rule. SARA: REPORTABLE QUANTITY (RQ): • CAS# 108-88-3 RQ amount: 1000/454 • CAS# 75-09-2 RQ amount: 1000/454 • CAS# 67-64-1 RO amount: 5000/2270 • None of the chomicals in this product have a TPQ. CAS# 67-56-1 RQ amount: 5000/2270 CLEAN AIR AC'I: 75-09-2; clean air rulo -yes • 67-56-1; clcan air rule-yes 108-88-3; clean air rule-yes • This material does not contain any class 2-ozone depletors This material does not contain any class 1-ozone deplotors [11. Toxicological Information 75-09-2 and 67-56-1 are considered toxic by OSHA LC - 200-300 mg/kg orally in rats 12224 CAS# 67-64-1 LCsn - 7.53 g/kg orally in rats L.Cso.. 10.7 ml/kg orally in rats Epidemiology: R, IARC-2E No information available.#

Page 7FROM : FAX NO. : Jun. 16 2006Ø1:17PM PS Teratopenicity: productive orecis No information available. Neurotoxicity: o information available Muta penicity: No information available. No information available. 112 Additional Information vailable to SAMAX Enterprises Inc. However, SAMAX Inc. makes no warranty of merchantabilit The information above is beloved to be accurate and represents the best information currentl say to war re, in to or use users reside on sue eir own in aigions to determine. the suitability of the information for their particular purpose. In no way shall SAMAX Inc. be liable incidental, consequential or exemplary damages, howsoover arising even if SAMAX Inc. bas been for any claims, losses, or damages of any third party or for lost protits or any special, indirect, advisod of the possibility of such damages.#

Page 86-HML-R FLAMMABLE LIQUID eenah, Wisconsin 59957-0368: 1800) 327,6868: ublished by: J.J. KELLER & ASSOCIATES INC 3 INHALATION 198-HML-R HAZARD Published by is me, i SA 0012 C#

Page 931-HML-F Neenah, WI • USA • (800) 327-6868 Published by: J.J. KELLER & ASSOCIATES, INC.#

Page 10surfaces. safety glasses. not transfer Rock Miracle Liquid No Wash Remover is ideal for ornamental afterwash is necessary. Liquid No Wash quickly softens paint, enamel, latex, lacquer, varnish, shellac and urethanes from wood, metal, plaster, and masonry without injury to these surfaces. Do not allow to drip on linoleum, asphalt, rubber tile and synthetics. It may also soften fiberglass and plastic. DIRECTIONS: Wear protective Shake can well. Open slowly with container opening away from your face and close after contents of can to unlabeled bottles or other containers. Always test a small area for removal time. Apply a heavy coat using a polyesther brush or for continuous flow, pour from a glass or metal cup to a confined area of no more than 3 square feet at a time. Allow Liquid No Wash to penetrate for at least 15 minutes. Scrape off softened finish with a scraper or steel wool pad till area is completely cleaned. Use a toothbrush or pointed object for carved areas. Thoroughly wipe area with absorbant cloth to remove residue before proceeding to next area. No further surface preparation is Made in USA Samax Enterprises, Inc. Newark, NJ 07104-4237 use. Do necessary. 1936 POISON! ROCK-MIRACLE FLAMMABLE LIQUID AND VAPOR. MAY BE FATAL OR CAUSE BLINDNESS IF SWALLOWED. VAPOR HARMFUL. MAY CAUSE FLASH FIRE. N CE No Wash- REMOVER No afterwash necessary! DANGER! Removes and varnish. paint, finishes#

Page 11Store in cool place. Do not reuse container. depends on level and duration of exposure. KEEP OUT OF THE REACH OF CHILDREN. unused contents in accordance with local, state and federal regulations. build-up of vapors by opening all windows and doors to achieve good ventilation. surfaces may produce toxic gases. Keep away from heat and flame. Do not smoke. material and remove with inert absorbent. Dispose of contaminated absorbent, container and Swallowing: If swallowed, get medical attention immediately. Spills: If spilled, contain spilled inhaled, remove to fresh air. If not breathing, give artificial respiration: If breathing is difficult, and shoes. Wash clothing before reuse. Thoroughly clean contaminated shoes. Inhalation: If water for at least 15 minutes. Get medical attention immediately. Remove contaminated clothes FIRST AID: Eyes and skin: In case of contact, immediately flush eyes or skin with plenty of electric motors and other sources of ignition during use and until all vapors are gone. Prevent cause flash fire. Do not smoke. Extinguish all flames and pilot lights and turn off stoves, heaters, VAPORS MAY IGNITE EXPLOSIVELY. Keep away from heat, sparks and flame. Vapors may papers and waste promptly. Allow solvent to evaporate, then dispose of in metal containers. protection against vapors. Open containers carefully and close after each use. Clean up rags, additional protection. Obtain professional advice before using. A dust mask does not provide Do not use in basement or other unventilated area. If properly used, a respirator may offer use it indoors, prevent buildup of vapors by opening all windows and doors to achieve good USE ONLY WITH ADEQUATE VENTILATION. Use this product outdoors if possible. If you must concentrating and inhaling the contents may be harmful or fatal. Contact with flame or hot with permanent brain and nervous system damage. Intentional misuse by deliberately Notice: Reports have associated repeated and prolonged occupational overexposure to solvents with eyes, skin and clothing. Causes eye, nose, throat and skin irritation. Risk to your health blood's oxygen-carrying capacity. May be fatal or cause blindness if swallowed. Avoid contact May affect the brain or nervous system causing dizziness, headache for nausea. Reduces the pulmonary disorders and women who are pregnant should consult their physician before using blood's oxygen carrying capacity. People having or suspected of having heart trouble or any CANCER IN CERTAIN LABORATORY ANIMALS. CANNOT BE MADE NON-POISONOUS. Reduces VAPOR HARMFUL. CONTAINS METHYLENE CHLORIDE WHICH HAS BEEN SHOWN TO CAUSE CANNOT BE MADE NON-POISONOUS! HEAT, SPARKS AND OPEN FLAME! DANGER! FLAMMABLE MIXTURE! KEEP AWAY FROM TOLUENE CAS# 108-88-3 PETROLEUM WAX ACETONE CAS# 67-64-1 METHYL ALCOHOL CAS# 67-51-1 Ingredients: Contains METHYLENE CHLORIDE CAS# 75-09-02 implied material safety data sheet. 095555051607 297.5 GRAMS PER LITER MAX VOC further information refer to the regardless of legal theory. For damage to person or property will not be responsible for any The manufacturer and distributor damages to persons or properties. proper use of this product and for full responsibility for the safe and The purchaser and users assume defective product will be replaced. express or implied warranties. Any merchantability and any or all and distributor disclaim the used or misused, the manufacturer warranty under which this product may be Because of the wide conditions efficient when used properly. and Finish Remover is safe and Rock Miracle Liquid No Wash Paint or#