Aris Electronics — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 1200 New Jersey Ave, S.E. Washington, D.C. 20590 MAR 2 7 2013 Mr. A vraham Rahimi Aris Electronics 11740 Wilshire Blvd., #A603 Los Angeles, CA 90025 Reference No.: 13-0001 Dear Mr. Rahimi: This is in response to your December 28, 2013 email requesting confirmation from the Pipeline and Hazardous Materials Safety Administration (PHMSA) that "Crest Whitestrips- Supreme" are not subject to the Hazardous Materials Regulations (HMR; 49 CPR Parts 171- 180). As provided in§ 173.22, it is the shipper's responsibility to properly classify a hazardous material. Such determinations are not required to be verified by this Office. However, based on the Material Safety Data Sheet (MSDS) you provided for the "Crest Whitestrips- Supreme," it is the opinion of this Office that the formulations do not meet the definition of any hazard class and are not subject to the HMR. I trust this satisfies your inquiry. Please contact us if we can be of further assistance. Sincerely, T. Glenn Foster Chief, Regulatory Review and Reinvention Branch Standards and Rulemaking Division#

Page 2Andrell)s ~Iii ,'I '§ 112.1 {01 Drakeford, Carolyn (PHMSA) From: INFOCNTR (PHMSA) Sent: Subject: Friday, December 28, 2012 2:50 PM To: Drakeford, Carolyn {PHMSA) FW: DOT PHMSA Hazmat Center Inquiry Hi Carolyn, This e-mail has additional contact info to add to Avi Rahimi's 12/28 request for an interp letter. The first e-mail contains the attached MSDS. Thanks, Victoria From: avi rahimi [mailto:avirahimi@yahoo.com] Sent: Friday, December 28, 2012 2:47 PM To: INFOCNTR (PHMSA) Subject: Re: DOT PHMSA Hazmat Center Inquiry Dear victoria my name is avi and i spoke to you earlier to reg a request for formal letter. in this e mail i wanted to request a formal letter of interpretation reg an item described as crest whitestrips supreme professional that it is not classified as hazardous item for DOT i am going to attach the MSDS on this product as well . please let me know if you have any questions or concerns my information is below to contact me. thanks and looking forward for your help. avraham rahimi aris electronics 117 40 wilshire blvd # A603 la ca 90025 cell number 2136107431 From: "INFOCNTR.INFOCNTR@dot.gov" <INFOCNTR.INFOCNTR@dot.gov> To: avirahimi@yahoo.com Sent: Friday, December 28, 2012 11 :29 AM Subject: DOT PHMSA Hazmat Center Inquiry Dear A vi Rahimi, We have received your inquiry to the Pipelines and Hazardous Materials Safety Administration's (PHMSA's) Hazardous Materials Information Center (HMIC). The HMIC provides information on the Hazardous Materials Regulations (HMR), 49 CFR Parts 171-180. The HMR establish regulatory requirements pertaining to the safe and secure transportation of hazardous materials by rail, aircraft, motor vehicle, or vessel. If you require information on the HMR, you may contact the HMIC, which is staffed with regulatory specialists who can quickly answer your questions by phone, Monday through Friday, 9 AM- 5 PM EST at 1-800-467-4922 or (202) 366-4488. Based on your inquiry, you may be interested in the following URL(s): 1#

Page 3Letter of Interpretation 09-0271 http://www.phmsa.dot.gov/staticfiles/PHMSA!Interpretations/2009/09027l.pdf Letter of Interpretation 1 0-013 3 http://www.phmsa.dot.gov/staticfi1es/PHMSA/Interpretations/2010/100133.pdf Letter of Interpretation 06-248 http://www.phmsa.dot.gov/portal/site/PHMSA/menuitem.ebdc7a8a7e39f2e55cf2031050248a0c/?vgnextoid=bbd cc0515d54411 OV gn VCMl 000009ed07898RCRD&vgnextchannel=56acd3claf81411 OV gn VCMl 000009ed0789 8RCRD&vgnextfmt=print Interpretation #03-0303 http:/ /www.phmsa.dot.gov /portal/site/PHMSA/menuitem.ebdc 7 a8a 7 e3 9f2e5 5cf2031 050248a0c/?vgnextoid=6aaf 5794ed745110VgnVCM1000009ed07898RCRD&vgnextchannel=aa8cd3claf814110VgnVCM1000009ed07898 RCRD&vgnextfmt=print Sincerely, Victoria, Hazardous Materials Specialist An e-mail response from this office is considered informal guidance. Formal guidance may be requested in accordance with 49 CFR 105.20. http://hazmat.dot.gov/infocent.htm 2#

Page 4Drakeford, Carolyn (PHMSA) From: INFOCNTR (PHMSA) Sent: Friday, December 28, 2012 2:47 PM To: Drakeford, Carolyn (PHMSA) Subject: FW: DOT PHMSA Hazmat Center Inquiry Attachments: Crest_ Whitestrips _-_Supreme. pdf Hi Carolyn, We received the following request for a formal letter of interpretation. Thanks, Victoria From: avi rahimi [mailto:avirahimi@yahoo.com] Sent: Friday, December 28, 2012 2:40 PM To: INFOCNTR (PHMSA) Subject: Re: DOT PHMSA Hazmat Center Inquiry Dear victoria my name is avi and i spoke to you earlier to reg a request for formal letter. in this e mail i wanted to request a formal letter of interpretation reg an item described as crest whitestrips supreme professional that it is not classified as hazardous item for DOT i am going to attach the MSDS on this product as well . please let me know if you have any questions or concerns my name is avraham rahimi and my contact number is 213-610-7431. thanks and looking forward for your help. From: "INFOCNTR.INFOCNTR@dot.gov" <INFOCNTR.INFOCNTR@dot.gov> To: avirahimi@yahoo.com Sent: Friday, December 28, 2012 11:29 AM Subject: DOT PHMSA Hazmat Center Inquiry Dear A vi Rahimi, We have received your inquiry to the Pipelines and Hazardous Materials Safety Administration's (PHMSA's) Hazardous Materials Information Center (HMIC). The HMIC provides information on the Hazardous Materials Regulations (HMR), 49 CFR Parts 171-180. The HMR establish regulatory requirements pertaining to the safe and secure transportation of hazardous materials by rail, aircraft, motor vehicle, or vessel. If you require information on the HMR, you may contact the HMIC, which is staffed with regulatory specialists who can quickly answer your questions by phone, Monday through Friday, 9 AM- 5 PM EST at 1-800-467-4922 or (202) 366-4488. Based on your inquiry, you may be interested in the following URL(s): Letter oflnterpretation 09-0271 http://www.phmsa.dot.gov/staticfiles/PHMSA!Interpretations/2009/09027l.pdf 1#

Page 5Letter oflnterpretation 1 0-013 3 http://www.phmsa.dot.gov/staticfiles/PHMSNinterpretations/2010/100133.pdf Letter of Interpretation 06-248 http://www. phmsa.dot.gov /portal/site/PHMSNmenuitem.ebdc 7 a8a 7 e3 9f2e5 5cf2031 050248a0c/?vgnextoid=bbd cc0515d544110VgnVCM1000009ed07898RCRD&vgnextchannel=56acd3claf814110VgnVCM1000009ed0789 8RCRD&vgnextfmt=print Interpretation #03-0303 http:/ /www.phmsa.dot.gov /portal/site/PHMSNmenuitem.ebdc 7 a8a 7 e3 9f2e5 5cf2031 050248a0c/?vgnextoid=6aaf 5794ed745110VgnVCM1000009ed07898RCRD&vgnextchannel=aa8cd3claf814110VgnVCM1000009ed07898 RCRD&vgnextfmt=print Sincerely, Victoria, Hazardous Materials Specialist An e-mail response from this office is considered informal guidance. Formal guidance may be requested in accordance with 49 CFR 105.20. http://hazmat.dot.gov/infocent.htm 2#

Page 6MATERIAL SAFETY DATA SHEET Page 1 of4 MSDS Identifier Crest Wbitestrips - Supreme SECTION I-CHEMICAL I PRODUCT AND COMPANY IDENTIFICATION THE PROCTER & GAMBLE COMPANY RATING KEY Hazard Rating Health Care Research Center 4=EXTREME Health: l 3=HIGH 8700 Mason-Montgomery Road 2=MODERATE Flammability: 0 Mason, OH 45040-9462 l=SLIGHT Reactivity: 0 EMERGENCY PHONE: Transportation Emergency (24 hour) Telephone Number: Prepared by: Jill Kamer, CIH CHEMTREC: 1-800-424-9300 in the U.S. and Canada; Issue Date: December 3, 2007 1-703-527-3887 for calls originating elsewhere or call Last Reviewed: 10/04/04 the Poison Control Center Material Name: Crest Whitestrips - Supreme SECTION II- COMPOSITION AND INGREDIENTS Hazardous Ingredients as defined by OSHA, 29 CFR 1910.1200, and/or WHMIS under the HPA. These substances are listed because in their pure bulk form, they meet the OSHA definition of hazardous. Any hazards associated with this finiohP.-1 n~ listed in Section m ofthis MSBS. Principal Hazardous Components: CAS Number Cone. 0/o Exposure Limit!LC50/LD50 Hydrogen Peroxide 7722-84-1 14 1ppm (ACGIH) Glycerin 56-81-5 7-13 10 mg!m3 (ACGIH) Sodium Hy_droxide 1310-73-2 0.5-1.5 2 mg!m3 (ACGIH) SECTION III- HAZARDS IDENTIFICATION Emergency Overview: This mixture is a product regulated by the FDA. This clear gel can produce mild to moderate eye irritation. Ingestion of gel can cause nausea, vomiting, and gastrointestinal irritation. Accidental skin exposure can cause skin bleaching and irritation. Eye: Can cause mild to moderate eye irritation. Skin: Exposure can produce skin blanchin_g_ and irritation. Inhalation: Not likely to be inhaled. Ingestion: Ingestion can cause gastrointestinal irritation. Choking/Suffocation: Keep out of reach of young children. --------------#

Page 7PROCTER & GAMBLE . Page 2 of 4 Procter & Gamble MSDS Identifier: I Crest Whitestrips- Supreme SECTION IV- FffiST AID MEASURES Eye: Remove contact lens (if applicable). Flush eyes with water for 15 minutes. Get medical attention if eye irritation persists after water flush. Skin: Inhalation: Ingestion: Wash affected area with soap and water. Not a likely exposure route. Rinse out mouth with water. Get medical attention if more than mild gastrointestinal symptoms are experienced. Additional First Aid Measures: None SECTION V- FIRE FIGHTING MEASURES Flash Point: > 200°F Flash Point test Closed cup method: Auto-ignition [2J Not applicable 0 Not available Flammable Limits LEL % Temperature: D deg. C D deg F. (% by volume in air) UEL 0/o Extin2uishin2 Media: Use water spray, alcohol foam, or carbon dioxide. Explosion Hazards: None known Special Instructions: None SECTION VI- ACCIDENTAL RELEASE MEASURES Personal Safe2uards: Environmental Precautions: Avoid excessive contact and contact with the eyes. This material is not known to possess additional hazards when spilled, beyond those of other non-hazardous solids. Spill Clean-up Procedures: Industrial: Keep from reaching waterways. Household: Product used in household may be disposed of in refuse. SECTION VII- HANDLING AND STORAGE Recommended Storage Temperature: I None Personal Precautions for Safe Avoid contact with eyes. Storage and Handling: Conditions for Safe Storage: None SECTION Vlll- EXPOSURE CONTROLS, PERSONAL PROTECTION This section only applies to the product when used in an industrial settin!!. Ventilation: Goodgeneral ventilation is sufficient for control. Eye Protection: Wear safety glasses with side shields. Respiratory Protection: None Skin Protection: For brief contact normal work attire is sufficient.#

Page 8PROCTER & GAMBLE Page3 of4 Procter & Gamble MSDS Identifier: I Crest Whitestrips- Supreme SECTION IX- PHYSICAL AND CHEMICAL PROPERTIES Appearance I Color: Small plastic strips with Melting Point: Not available clear gel sandwiched between them. Odor: None Odor Threshold: Not Applicable Physical State: Gel Vapor Pressure Vapor Density: Not available pH: 5.0 Boiling Point: Not available Solubility in Water: Moderately soluble (mmHg): Not available Specific Gravity (H20=1): Not available Other Data: Product complies with State and Federal regulations for VOC content SECTION X- STABILITY AND REACTIVITY Stability: I Stable Possibility of Hazardous None known Reaction: Incompatibility: None known (Materials to avoid) Hazardous None known Decomposition Products: SECTION XI- TOXICOLOGICAL INFORMATION Because the gel is difficult to extrude from between the layers of plastic, the finished product can be considered as a non-hazardous material. Chronic Effects: No chronic health effects reported. Target Organs: No target organs reported. Carcinogenicity: This finished consumer product is not carcinogenic. NTP: No IARC: No SECTION XII- ECOLOGICAL INFORMATION Relevant ecotoxicity and fate data for ingredients in this formulation have been reviewed. Under normal and foreseeable consumer uses, there are no concerns for aquatic organisms exposed to product ingredients at the anticipated environmental concentrations. The surfactant(s) used in the formulation biodegrade rapidly and do not accumulate in the environment. The product is compatible with down-the-drain disposal routes, including municipal wastewater treatment processes and septic tank systems. This product is intended for dispersive use and should not be disposed of directly into the environment.#

Page 9PROCTER & GAMBLE Page4of4 Procter & Gamble MSDS Identifier: I Crest Wbitestrips - Supreme SECTION Xill- DISPOSAL CONSIDERATIONS Waste Disposal Method: Disposal is to be performed in compliance with Federal, State/Provincial and Local reg_ulations. Households: Product used in household may be disposed of in refuse. Industrial Setting: Agency Parameter Requirement US EPA This material is not considered a hazardous waste under United States Resource Conservation and Recovery Act when disposed. SECTION XIV- TRANSPORTATION Agency Classification US DOT (transportation by Non-Regulated _g_round) IMDG (transportation by Non-Regulated sea}_ lATA (transportation by Non-Regulated air) SECTION XV- ADDITIONAL REGULATORY INFORMATION The product(s) described in this Material Safety Data Sheet are regulated under the Federal Food, Drug and Cosmetics Act and are safe to use as per directions on container, box or accompanying literature (where applicable). US Federal: TSCA- All intentionally-added components of this product are listed on the US TSCA Inventory. SARA 313/302/304/311/312 chemicals: None US States: California: This product has been evaluated and does not require warning labeling under California Proposition 65. State Right-to-Know and CERCLA: The following ingredients present in the fmished product are listed on state right-to-know lists or state work exposure lists. lngredient(s) (_concentration} CERCLARQ State(s) Hydrogen Peroxide Not Applicable CA, CT, IL, IN, KY, MA, MN, NC, NJ, NY, OR, PA, RI Glycerin Not Applicable CA, IL, IN, KY, MA, MN, NC, OR,PA,RI Sodium Hydroxide 1,000 lbs Below Reporting Threshold SECTION XVI- OTHER INFORMATION DISCLAIMER: This MSDS is intended to provide a brief summary of our knowledge and guidance regarding the use of this material. The information contained here has been compiled from sources considered by Procter & Gamble to be dependable and is accurate to the best of the Company's knowledge. It is not meant to be an all- inclusive document on worldwide hazard communication regulations. This information is offered in good faith. Each user of this material needs to evaluate the conditions of use and design the appropriate protective mechanisms to prevent employee exposures, property damage or release to the environment. Procter & Gamble assumes no responsibility for injury to the recipient or third persons, or for any damage to any property resulting from misuse of the product.#