Air Techniques, Inc. — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation Pipeline and Hazardous Material Safety Administration 1200 New Jersey Ave, S.E. Washington, D.C. 20590 JAN 2 8 2014 Mr. Michael Toole National Sales Manager Air Techniques, Inc. 1295 Walt Whitman Road Melville, NY 11747 Ref. No.: 13-0226 Dear Mr. Toole: This is in response to your email dated November 18, 2013, requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) relating to the hazard classification of a "surface disinfectant and deodorizing spray." You provide a material safety data sheet (MSDS) for the product in question and ask if the manufactures classification as perfumery products, UN 1266, PG II is correct based on the MSDS. In accordance with§ 173.22, it is the shipper's responsibility to properly classify a hazardous material. This Office does not generally perform that function. Please see interpretation 13-013 5 issued by this Office which states; "there is no definition for 'perfumery products' in the HMR. However, perfume is typically defined as a fluid preparation used for scenting, composed of natural essences or synthetics and a fixative." Interpretation 13-013 5 further indicates that the classification as perfumery products is dependent on the primary function of the product. It appears the function of the product in question is not as a perfume, but rather, a product intended to be used as a disinfectant or cleaner, and as such the description "UN1266, Perfumery products" is not appropriate. I trust this information is helpful. If you have further questions, please do not hesitate to contact this office. Sincerely, ~.o\Q_,.Q_ \ &~s:.:x_ ./-fur (,) \ ;.>"" Duane A. Pfund International Standards Coordinator Standards and Rulemaking Division#

Page 2Wednesday, November 13, 2013 To whom it may concern, Re: Monarch Surface Disinfectant Transport of Dangerous Goods Statement Product Purpose: Monarch Surface Disinfectant is meant to deodorize Dental offices while killing bacteria and fungi. It eliminates mold and eugenol smells that predominate the Dental clinic offending clientelle. Chemistry: The product has a complex chemistry of volatile and flammable solvents. These include Ethyl Acetate, Lime solvent, USP Ethanol and some esters. In consideration of the mixed chemistry and the product purpose to improve the smell of a dental clinic, we have classified it as UN 1266. Micrylium has not had a TOG issue in the United States, Canada or Europe in the 6 years we have been using this designation. Yours sincerely, Dean Swift Technical Director 5000-M Dufferin Street, Toronto Canada M3H 5T5 A 16-667-70AO FAX A 16-667-0071 Website www.micrylium.com#

Page 3Drakeford, Carolyn (PHMSA) From: INFOCNTR (PHMSA) Sent: Monday, November 18, 2013 5:14PM To: Drakeford, Carolyn (PHMSA) Subject: FW: Request of Letter of interpretation Attachments: Draft 11-13 Monarch MSDS.docx; Dangerous Goods Statement 2013. pdf Hi Carolyn, This caller requested we submit this e-mail as a formal letter of interpretation. Thanks, Victoria From: Michael Toole [mailto:mtoole@airtechniques.com] Sent: Monday, November 18, 2013 2:10PM To: INFOCNTR (PHMSA) Cc: Nicole Miller Subject: Request of Letter of interpretation To Whom It May Concern: We are looking for interpretation of the MSDS sheet and Manufacturing Letter (See Attached) of a product that we are going to be selling within the US. The manufacture uses the UN1266 classification which we believe is correct however we would like to ensure that this classification is correct based on MSDS sheet. The product is a surface disinfectant and deodorizing spray used within the dental industry. Thank you, 9J£Aaet :%de National Sales Manager- Consumables 1 Air Techniques, Inc. I ALLPRO Imaging 1295 Walt Whitman Road, Melville, NY 11747-3062 I C: 617.849.0084 I P: 516.214.56171 F: 516.433.3831 I metoole@airtechniques.com ISkype: mtoole1918 Follow Us: Air Techniques on Facebook I ALLPRO Imaging on Facebook 1#

Page 4~~i!:HNfauEs MSDS Emergency: CHEMTREC 800-424-9300 Effective Date: Draft 11/13 Ref. Document/Revision: MSDS Monarch 1.1 1. Identification MONARCH Indication Surtace Disintectant & Deodorizing Liquid Distributor Air Techniques, Inc. 1295 Walt Whitman Road, Melville, New York 11747 Contact: 516-433-7676; www.airtechniques.com 2. Hazard Identification Health Hazard Identification Physical Hazard Identification Environmental Hazard Identification No serious Health Hazard Flammable Biodegradable, No Endocrine Disrupters Hazardous Component CAS# UN# R Phrases Concentration TLV Perfumery Product with Flammable Solvents na-Biend 1266 R11 71.5% >1000 ppm 3. Composition Chemical Characterization Deodorizing Lime Solvent, Ethanol, Chlorhexidine Gluconate, Water with Non-Ionic Surfactants, anti-corrosives 4. First Aid Measures General Wash thoroughly with soap and water after handling and before eating, drinking, chewing gum or using tobacco. ~ ~ ~ Inhalation Mild reversible irritation. Ingestion Drink quantities of milk or water to dilute May cause dizziness Skin contact No adverse effects. Slightly drying. ~ ~ t.ye contact Hold eye open and rinse slowly and gently with water for 15-20 minutes. Remove-contact-lenses;if present, after the first 5 minutes, then continue rinsing. 5. Fire Fighting Measures llc:P rln, rhPmical; Alcohol Foam or C02 . lise water spra¥ to dispense vapours and cool items. 6. Accidental Release Measures No specific measures are necessary provided vapours are not permitted to build up. 7. Handling & Storage Store in a cool, dry well ventilated location. Keep away from heat, sparks and flame. DO NOT mix with bleach or Peroxides. 8. Exposure Controls-Personal Protection Avoid contact with eyes or clothing. Wear safety glasses. 9. Physical & Chemical Properties Kinematic Viscosity Form Colour Scent Solidification point Boiling point Flash Point Density pH mm 2/s Liquid Green Lime -20°C 87°C 17°C .866 9.9 16 10. Stability & Reactivity Incompatibility Decomposition products Stable under normal conditions. Strong oxidants, acid chlorides, silver salts co2co 11. Toxicological Data Acute Dermal LDso>5000 mg/kg; Acute Inhalation' rat LCso:2.3mg/l; Not found to be a dermal sensitizer: Acute OraiLDso>5000 mg/kg; Occular irritation 0.0 after 7 Days. Tests performed by product Safety labs, Dayton, NJ Grain derived Ethanol USP. All Ingredients Food or Pharma Grade. Free of Nonyl Phenyl Ethoxylates. Reproductive Hazards Ingestion of large amounts can lead to liver damage Carcino~Zenicitv None u. Ecological information Surfactants are readily biodegradable linear ethanol ethoxylates. All ingredients USP Pharma or Food Grade Soil Readily biodegrades Water Readily biodegrades Air Volatile Disposal Domestic 13. Disposal considerations Domestic No restrictions. Water Dilution 4:1 for flammability considerations 14. Transport Information Land Sea lATA Hazard Class 3 UN1266 Packing Hazard Class 3.2 UN1266 Hazard Class 3 UN1266 Packing Group II Limited QTY 5 L max. Packing Group II Limted Qty 5 L max. Group II Limited QTY 500 ml. Emergency Response Guide #127 Emergency Response Guide #127 Emergency Response Guide #127 lS. Regulatory TSCA-No reporting required all ingredients listed in inventory. R11: Highly flammable. 59: Keep container in well-ventilated place. 516: Keep away from sources of ignition- No smoking. CERCLA- No hazardous pollutants- No Ozone depletion. ll5. Other Information The information and recommendations contained herein are based upon data believed to be correct. However, no guarantee or warranty of any kind expressed or implied, is made with respect to information and recommendations contained herein.#