Dangerous Goods Department — Hazardous Materials Safety Interpretation

Page 1of Transportation U.S. Department Washington, DC 20590 1200 New Jersey Avenue SE Pipeline and Hazardous Administration Materials Safety JUN 1 0 2015 Sergio Bustamante M. CSAV Portacontenedores SPA. Dangerous Goods Department Plaza Sotomayor 50 Valparaiso, Chile- Ref. No. 15-0046 Dear Mr. Bustamante: This is in response to your January 30, 2015 e-mail requesting clarification on the proper classification of your customer's shipment of bone charcoal under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). In your letter, you state it is your understanding that bone charcoal containing 12% carbon is a Division 4.2 pyrophoric solid or self-heating substance when offered for transportation. However, you also provide laboratory test results that indicate your customer's product does not meet the definition of a Division 4.2 (Spontaneously Combustible Material). In addition, you provide documentation required by 3.3.1, Special Provision 925, of the International Maritime Dangerous Goods Code (IMDG Code) that confirms the product is not a self-heating or pyrophoric solid. You request confirmation that your customer's product is not subject to the requirements of the HMR. In accordance with § 173.22 of the HMR, it is the shipper's responsibility to properly classify a hazardous material. This Office generally does not perform this function. However, based on the test data and certification you provided, we agree that your customer's product does not meet the definition of a Division 4.2 material. Therefore, if your customer's product does not meet any other hazard class as defined in part 173 of the HMR, and is not a hazardous substance, hazardous waste, or marine pollutant, it is not subject to the HMR. I hope this information is helpful. Please contact us if we can be of further assistance. Sincerely; Frostar T. Glenn Foster Chief, Regulatory Review and Reinvention Standards and Rulemaking Division#

Page 2seven. 5173,32 Shippers Responsebili 5173.124 Deferitions Dodd, Alice (PHMSA) 15-0046 From: Sent: Ciccarone, Michael CTR (PHMSA) Friday, March 13, 2015 11:37 AM To: Hazmat Interps Subject: FW: Bone Charcoal - request of letter of interpretation, Sorry guys, here's another one I'm not seeing in filemaker -----Original Message--.- From: Ciccarone, Michael CTR (PHMSA) Sent: Friday, January 30, 2015 2:10 PM To: Hazmat Interps Subject: FW: Bone Charcoal - request of letter of interpretation, Shante/Alice, Please submit this for a formal letter of interpretation. Mr. Bustmante's physical address is: Plaza Sotomayor 50 Valparaiso Chile Thanks, Mike ----Original Message---- From: sbustamante@csavgroup.com [mailto:sbustamante@csavgroup.coml Sent: Friday, January 30, 2015 12:34 PM To: PHMSA HM InfoCenter Cc: Geller, Shelby CTR (PHMSA); halvarez@csavgroup.com; pilot@csav.com; cherman@csavagency-na.com; security.global@csavgroup.com Subject: Bone Charcoal - request of letter of interpretation, Dears: i called few minutes ago to +1(202) 366-4488 and i spoke with Isaac. We kindly ask you for a letter of interpretation, we need to know if the DOT as Competent Authority accept the import of this cargo as harmless and the transport inside the country as harmless based on the documentation and description of the manufacturing process received from the customer. Thanks for your cooperation. Best Regards, Sergio Bustamante M. Phone: 56-32-220 3666 1#

Page 3• P Please consider the environment before printing this email. From: <shelby.geller.ctr@dot.gov> To: <sbustamante@csavgroup.com>, Date: 30-01-2015 12:11 Subject: RE: Bone Charcoal Dear Sergio Bustamante M., We have received your inquiry about the hazardous materials regulations (HMR) (49 CFR Parts 171-180). The HMR prescribes the requirements of the Department of Transportation governing the offering and transportation of hazardous materials in interstate, intrastate, and foreign commerce by rail car, aircraft, motor vehicle, and vessel. While we cannot provide an exhaustive list of each applicable requirement, we suggest you review section(s) **173.22 and 173.124(b) for additional information on the shipper's responsibility and the definition of division 4.2 (spontaneously combustible) materials. The hazardous materials regulations are available at the following URL: http://phmsa.dot.gov/regulations If you require additional assistance, you may contact the Hazardous Materials Information Center, which is staffed with regulatory specialists who can quickly answer your questions by phone, Monday through Friday, 9 AM - 5 PM EST at +1(202) 366-4488. Sincerely, Shelby, 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://phmsa.dot.gov/hazmat/regs/interps ---- Forwarded by Sergio Bustamante/Chile/CSAV on 30-01-2015 14:15 ---- From: Sergio Bustamante/Chile/CSAV To: phmsa.hm-infocenter@dot.gov, Cc: Pilot/Chile/CSAV@CSAV_VAP, Hector Alvarez/Chile/CSAV@CSAV_VAP, Security Global/Chile/CSAV@CSAV_VAP Date: 30-01-2015 02:06 2#

Page 4Subject: Bone Charcoal Dears: We belongs to CSAV Portacontenedores SPA (Shipping Company). We have a customer who wants to carry "Bone Charcoal" from Brazil to USA as non dangerous good. When we detected this situation we reject the shipment because in our opinion the cargo is dangerous good: UN1361, CARBON, class The customer says that the cargo is not dangerous good based on: 1) To be considered UN1361 the percentage of carbon must be higher that 88% however in this case the percentage of carbon is around 12% (this is stated in the MSDS) 2) The shipper provided a document where it reads that the cargo passed the tests for self heating substances. We consider that the cargo is dangerous good based on: 1) The cargo is declared by the customer as "bone charcoal", "charcoal" is included in the Index of the IMDG Code as synonym of "carbon". The raw material of this cargo are bones from bovines which passed through process of carbonization (we have attached the description of manufacturing process received from customer: "Carbonization of the bones is carried out at a temperature of about 750°C for 8 hours"), therefore the cargo is Carbon from animal origin which is clearly listed in the IMDG Code as dangerous good. On the other hand in the IMDG Code there is no mention about the percentage of carbon to be classified as UN1361 2) The documents received regarding the tests for self heating substances are not valid to exempt the cargo from the condition of dangerous good because: - There are no laboratories accredited by the Brazilian Competent Authority to do this test. - In the document there is no mention about that "the product to be loaded has been correctly sampled by trained staff from that laboratory and that the sample was correctly tested " as required by the special provision 925 of the IMDG Code. We have attached the documentation received from customer. Please confirm if you agree with our position. Thanks and Best Regards, Sergio Bustamante M. CSAV DG Dept Phone: 56-32-220 3666 (See attached file: MATERIAL SAFETY DATA SHEET - MSDS - EN.pdf) (See attached file: Operation Process of Bone Charcoal (1).doc)(See attached file: CZI E-468 B (1).pdf) (See attached file: Self ignition test for Shipping (1). pdf) 3#

Page 5(See attached file: document2015-01-29-101511.pdf) P Please consider the environment before printing this email. SAFETY DATA S... of Bone Char... MATERIAL Operation Process CZI E-468 B (1).pdf Self ignition test document2015…. for Shippin...#

Page 6OSHER PADRESA B.K.A. Bonechar ISO 9001 MATERIAL SAFETY DATA SHEET - MSDS 1. PRODUCT IDENTIFICATION AND COMPANY Trade Name: Natural Bone Charcoal Synonyms: Bone Char, Animal Bone Char, Bone Black. Chemical Name: Bone Charcoal• Chemical Formula: C + [Cao(P04)s(OH)2] Company Name: Bonechar - Carvão Ativado do Brasil Ltda. Address: 980 Pioneira Maria Cavalcanti Ruy Street - Maringá/PR - Zip Code: 87065-090 Phone Company: (55) 44-3266-1517 Phax: (55) 44-3266-3673 Phone for Emergencies: (55) 44-3266-2014 E-mail: bonechar@bonechar.com.br 2. COMPOSITION AND INFORMATION OF INGREDIENTS CAS No.: 8021-99-6 Reference EINECS: 232-421-2 Customs Tariff Number: 3802.9090 Generic Name: Hydroxyapatite (Сapo(P04) (0H)2] Concentration: C =~12%, Caз(P04)2 = ~88% Number of ONU: The bone charcoal is not listed in ONU number. 3. Physical and Chemical Properties Property Specification Carbon 9 - 11% Acid-soluble Ash < 3% Ash Insoluble 0,7 Tricalcium Phosphate 70 - 76% Calcium Carbonate 7 - 9% Calcium Sulfate D.1 - 0,2% 8.5 - 9,5 Total Specific Surface Area (BET Nº) 200m/g| Surface Area of Carbon Iron 50 m/g| < 0.3% Pore Size 7,5 - 60.000 nm Pore Volume 0.225 cm?/g 1/4#

Page 7Moisture < 5% Apparent Density 0,60 - 0,70 g/cm3 Aspect Granules Odor Odorless 4. FIRST AID Inhalation: If a person inhale large amounts of particulate matter, transfer the person to an area of fresh air and ventilated, open the clothes and if necessary put oxygen mask. Provide medical care. Prolonged Inhalation: The Bone Charcoal absorbs oxygen from the air in work for long periods indoors where it is stored can cause respiratory deficiencies. If present disordered breathing, give artificial respiration. Skin Contact: There is no danger, and should only be washed with soap and water in abundance until its elimination. Eye Contact: Wash immediately with running water in abundance for at least 20 minutes. Ingestion: If swallowed in small doses, does not harm health, if swallowed in excess must give great volume of water and induce vomiting. 5. FIRE FIGHTING MEASURES Explosion: Avoid generating dust; fine dust dispersed in air in sufficient concentrations, and in the presence of an ignition source is a potential dust explosion hazard The bone charcoal does not enter burning (their point of combustion in pure oxygen is above 450 ° C). Extinguishing Media: Use preferably water under pressure in the form of fog, foam extinguisher, dry chemical or carbon dioxide Special methods: In case of fire fighting, position yourself with the wind at his back. Protection of those involved in fire fighting: Stay in dangerous zone only with suitable chemical protection clothing and with an oxygen mask independent of the ambient air. In order to avoid contact with skin, keep a safe distance. 6. EXTENT OF SPILL OR LEAK Personal precautions: Eliminate all sources of ignition, heat and sparks. Environmental precautions: Prevent spilled material reaches waterways and sewers. Procedure for emergency and alarm systems: In case of fire the fire alarm nearest you. Neutralization: Not applicable. Recovery: Collect material in clean and dry packages identified. Using a water jet for cleaning location. Disposition: Dispose of waste in accordance with current legislation. 7. HANDLING AND STORAGE HANDLING Prevention of worker exposure: Use proper personal protective equipment. Guidelines and precautions for safe handling: For safe handling, use personal protective equipment. Hygiene measures: Use when needed adequate ventilation. Immediately change contaminated clothing and shoes. Contaminated clothing should be changed and washed before reuse. Prophylaxis skin. After the end of the work, wash hands and face and also after handling. It is recommended not to smoke, drink, eat or store food in place and is handling the product. STORAGE 2/4#

Page 8Chemical stability in the long term: Bone Charcoal is not dangerous in storage. Proper storage conditions: store in rooms where there are no other chemicals products or vapors in the air. Keep plastic bags or paper always tightly closed. Storage Incompatibilities: The product should be kept away from strong oxidizers. Recommended packaging: plastic or paper packages. To avoid loss of property and contamination, the product should be stored in bags of 25 kg or 50 kg, or super bags of 500 kg to 1000 kg in dry and closed local. It should not be in direct contact with the ground and stacking up to be twenty bags of height, three super sacks or three pallets 8. EXPOSURE CONTROLS AND PERSONAL PROTECTION Appropriate personal protective equipment: Handling the activated carbon in normal conditions does not present any risk to health or satety of persons at the tacility. It is recommended to use equipment as appropriate tor their handling. Protection Eye / Face: Wear safety goggles to chemicals or wide vision. Contact lenses should not be used when working with Skin and body: Wear boots, apron or clothing appropriate for the job. Although not a material irritating to the skin, it is recommended to use gloves scrapes, PVC and / or rubber so as not to dirty their hands. Respiratory Protection: When handling with bone charcoal is recommended to use half-face mask for particulates. When the charcoal is wet and stored in tanks, the person may only enter into these tanks with breathing apparatus and mask with air or oxygen as the activated carbon removes all oxygen from the air indoors. 9. TOXICOLOGICAL INFORMATION Local Effects: Eyes: Irritation to be particulate matter. Lungs: When excessively exposed in an environment with high concentration of dust. Internal mucous membranes: Gauses dryness, when exposed to high concentrations due to high power adsorbent. Sensitization: In contact with the eyes causes irritation due to particulate matter, with the skin there are no records of major side effects, can only dry from dehydration and mucous membranes will absorb and therefore dry. 10. ECOLOGICAL INFORMATION Potential environmental effects: The activated carbon does not cause damage to the environment and may even be incorporated into the land of agriculture, because it keeps the soil aerated and retains moisture. This is because coal is the source of calcium and phosphorus. Ecotuxicity: No ecological problems are expected when the product is handled and used with due care and attention. 11. DISPOSAL CONSIDERATIONS Product: On the disposal of the product, you should look for legislation at the municipal, state and federal. Product residues: In the provision of product residue, must be attentive to the legislation at the municipal, state and federal. Packaging used: In the provision of used packaging of this product should be alert to the legislation at the municipal, state and federal. 12. TRANSPORT INFORMATION 3/4#

Page 9The Bone charcoal is not classified as hazardous for road, rail, sea and air. The Bone Charcoal is not listed in the UN number. The Bone Charcoal is delivered on paper or polypropylene bags containing 25 kg or 50 kg, or in super bags of 500 kg to 1000 kg. Proper Shipping Name: Bone Charcoal. 13. REGUILATIONS This information sheet of chemical safety was based on the following standards: "Products used for treatment of water intended for human consumption - Bone Charcoal."The European Standard BS EN 14456:2004 has the status of a British Standard. "Praducts used for treatment of water intended for human consumption - Inarganic supporting and filtering materials - Methads of test. "The European Standard BS EN 12902:2004 has the status of a British Standard. 14. OTHER INFORMATION The information contained in this MSDS has been compiled from various technical publications taken as true. We do not guarantee the accuracy of the data. The sole purpose of this document is to be a guide for proper handling of the material. It is the responsibility of the user determine the suitability of this information for adoption of necessary safety precautions. 4/4#

Page 10BONECHAR CARVÃO ATIVADO DO BRASIL LTDA. Bonechar Escritório: Rua Pioneira Maria Cavalcanti Ruy 980 - Parque Industrial || iSO 900~ CEP: 87065-090 Fone: 55-44-3266-1517 Fax: 55-44-3266-3673 MARINGÁ - PARANÁ - BRASIL E-mail: bonechar@bonechar.com.br Site: www.bonechar.com.br B.K.A PROCESSO DE PRODUÇÃO DO CARVÃO DE OSSO NATURAL / PRODUCTION PROCESS OF NATURAL BONE CHARCOAL 1. Coleta de matéria-prima (ossos bovinos), provenientes de frigoríficos, abatedouros, açougues bones) from slaughterhouses, butchers controlled by public health, state and federal inspection services. controlados pela saúde pública, serviços de inspeção estadual e federal . / Collect raw material (cattle 2. A matéria-prima é transportada para a fábrica unidade Paiçandu (I) em caminhões apropriados. / The raw 3. Na fábrica os caminhões são descarregados na recepção, na plataforma da máquina esmagadora. / In material is transported to the factory in Paiçandu unit in suitable trucks the factory the trucks are unloaded, in the overwhelming machine platform 4. Transporte de ossos e descarregamento no pátio para o início do processo de cura- no mínimo 90 dias. / Transport the raw material and discharge them in the courtyard to the beginning of the cure process - minimum 90 days. 5. Os ossos são classificados em uma peneira vibratória onde são removidos os ossos moles que não são usados para carvão. / The bones are classified on a vibrating screen which are removed the soft bones that are not used for bone charcoal. 6. A moagem dos ossos são feitos transportados em uma rosca elicoidal. / The grinding of the bones are made through a mill where after • através de um moinho onde após a moagem os ossos são grinding the bones are transported in a elicoidal thread. 2nd grinding through elicoidal thread 7. Transportar os ossos secos para 2º moagem através de rosca elicoidal. / Transporting the dry bones to crushed bones before going to the second mill to remove trace residue. 8. Peneirar os ossos triturados antes de ir para 2º moinho para remoção de restos de resíduo. / Sieve the ready for feed the kiln. 9. Ossos moídos são armazenados prontos para alimentação dos forno. /The ground bones are stored bones are transported via a bucket elevator. 10. Alimentação do forno, os ossos são transportados através de um elevador de canecas. / Kiln feed, box on the Kiln. 11. Os ossos são depositados em uma caixa de metal sobre o forno. / The bones are deposited in a metal processo intermitente e a cada 1,5 horas são retirados em torno 10 kg de carvão em cada tubo. / 12. A carbonização dos ossos é feita a uma temperatura em torno de 750 C° por 8 horas, isto é, em Carbonization of the bones is carried out at a temperature of about 750°C for 8 hours, i.e. intermittent process and the time taken every 1.5 hs to about 10 kg of bone charcoal in each pipe. 13. O carvão semi-acabado é resfriado em uma peneira vibratória para ensaque, onde o mesmo fica no screen for bagging, where it is in stock to be transported to Maringa (II). estoque para ser transportado para unidade Maringá (II). / The semi-finished product is cooled in a vibrating The semi-finished coal is transported to Maringa unit (II) to be processed, i.e. ground. 14. O carvão semi-acabado é transportado para unidade Maringá (II) para ser processado, isto é moído. / 15. O carvão é moído de acordo com a especificação do cliente, em peneira vibratória e ensacado em is ground according to customer specification, in vibrating screen and bagged in bags of 25 kg or in big bags sacos de 25 kg ou em big bag de 1000 kg e posto em pallets, prontos para embarque. / The bone charcoal of 1000 kg and put on pallets ready for shipment.#

Page 11ORIGINAL AGRICIA COLAE DO AS TE Од MINISTE SVA/MARIN: i VIGAGRO REPÚBLICA FEDERATIVA DO BRASIL MINISTÉRIO DA AGRICULTURA, PECUÁRIA E DO ABASTECIMENTO - MAPA CERTIFICADO ZOOSSANITÁRIO PARA EXPORTAÇÃO DE CARVÃO DE OSSOS DO BRASIL PARA OS ESTADOS UNIDOS DA AMÉRICA ANIMAL HEALTH CERTIFICATE FOR BONE CHAR EXPORTATION FROM BRAZIL TO UNITED STATES OF AMERICA ORIGEM / ORIGIN CERTIFICADO NÚMERO CERTIECATE NIMBERLAJ 2AIG) origem/ Name and address of tire Nome e endereço do estabelecimento de Paiçandu -PR-Brasil Bonechar-Carvão ativado do Brasil Lida. Estrada para Curizona, lote 6-C-13. stablishment of oripin Nome do exportador/ Name of consignee Bonechat-Carvão ativado do Brasil Lida consginee lindereço do exportador! Address of Rua Pioneira Maria Cavalcanti Rey. 980 Maringá-PR• Brasil Il. DESTINO / DESTINATION Nome e endereço do estabelecimento de establishment of destination destino! Name and address of the Pismou Technology, INC. 2925 Waterien Drive. Rochester Itil - M1 - 183049. Nome do importador/ Name of consignor Plymouth Technology, INC consignor Endereço do importador/ Address of the 2925 Waterview Drive, Rochester Hills - MI - 48309 - USA II. IDENTIFICAÇÃO E TRANSPORTE / IDENTIFICATIONAND TRANSPORTATION Quantidade : Quantir Meio de transporte/ Means of transportation Identificação/ Identfication Tamina 005N Maritimo IV. INFORMAÇÕES SANITÁRIAS / SANITARY INFORMATION: Eu, abaixo assinado, Veterinário Oficial, certifico que: I. the undersigned Official Veterinarian. certify that: 1. O carvão de osso foi derivado de bovinos: The hone char wus derived from bovine. ' 2. Durante o processamento o carvão de osso foi aquecido a uma temperatura minima de 800 graus C/ During processing the hone char was heated to a minimum of $00 degrees C Local / Place: meningé - PR-Man bara: Date: 06C1. 2015 Veterinário Oficial/ Official Veterinarian Nome/Name: Janismer Pous Cit go Carimbo e Assinatura do Veterinário Oficial Stamp and Signature of Official Teterinarian FRANCISHA •ERES ORTEGA S00: C21#

Page 12MTD MINTON, TREHARNE & DAVIES LIMITED Consulting Scientists, Mariners " Sagineers Analytical & Testing Laborafories Our ref: PS/ajr Public Auntys/s Certificate No: R13- 08585 24# June 2013 heating. The sample was received from 18th June 2013 and tested as detailed below. Sample identified as:- We hereby certify that we have analysed the undermentioned sample of Material for propensity towards self JERET W2060 PRODUCT Test Method: Transport of Dangerous Goods United Nations Recommendations on the Section 33.3 Division 4.2 Manual of Tests and Criteria - Sth revised edition Date of testing 21.6.2013 Section 33.3 1.3.1 Pyrophoric Solids The Sample failed to ignite in air within 5 minutes Section 33.3 1.3.3. Self heating substances temperature monitored for 24 hours. The sample was heated in air at 140°C in a 100mm test cube and its The sample temperature did not exceed 200°C. Conclusion: The sample is not a pyrophoric solid of Division 42. The sample is not a self heating substance of Division 4.2. MINTON, TREHARNE & DAVIES LTD Allomon J. Robinson BSc, MSc, MChemA, CSci, CChem, FRSC, MAPA, MIFST Jeret Ltd For the attention of: Jerry Elvin 4 Birchgrove, Houston Pentrewshire PA6 7DF Ene: Neill Clerk & Murray cover letter & UPS Consignment Note: HEAD OFFICE MERTON HOUSE, CROESCADARN CLOSt; CARDIFF CF23 8HF UK ALSO OFFICES AT LONDON, HOUSTON, SINGAPORE, CARMARTHEN TEL +44(0)2920540000 FAX EAX (0)29 20540111 EMAIL. mtd@minton.co.uk WEBSITE: www.minton.co.uk REGISTRATION NUMBER: ENGLAND 435262#

Page 13DGR Page 16 of 40 test report, are given in the current edition of the UN Manual of Tests and Criteria, Part II. The statement of approval Dangerous Goods. The applicable classification procedures, test methods and criteria, and an example of a suitable must contain the classification and the relevant transport conditions. 3.4.1.2.5 Transport of Samples Samples of self-reactive substances not listed in Appendix C.1, for which a complete set of test results is not avalas for d which are us traces type pruthed se following contions are assigned to one of the appropriate (a) the available data indicate that the sample would be no more dangerous than self-reactive substances type B: the available data indicate that the control temperature, if any, is sufficiently low to prevent any dangerous decomposition and sufficiently high to prevent any dangerous phase separation. 3.4.1.2.6 Temperature Control Requirements self-reactive substances, which require temperature control during transport are forbidden for transport by air unless With the exception of self-reactive solids of type B which are forbidden for transport by air under any circumstance, exempted (see 2.1.2). Self-reactive substances must be subject to temperature control if their self-accelerating 3.4.1.2.7 Desensitization of Self-reactive Substances iluent. When a diluent is used, the self-reactive substance must be tested with the diluent present in the 4.1.2.7.1 In order to ensure safety in transport, self-reactive substances may be desensitized by the use of: concentration and form to be used in transport. leakage from the package must not be used. 3.4.1.2.7.2 Diluents which may allow a self-reactive substance to concentrate to a dangerous extent in the event of those solids or liquids which have no detrimental influence on the thermal stability and hazard type of the self- 3.4.1.2.7.3 The diluent must be compatible with the self-reactive substance. In this regard, compatible diluents are reactive substance. be protected from direct sunlight and all sources of heat and be placed in adequately ventilated areas. During the course of transport, packages or unit load devices containing self-reactive substances of Division 4.1 must 3.4.1.3 Solid Desensitized Explosives 3.4.1.3.1 Solid desensitized explosives are explosive substances which are wetted with water or alcohols or are Subsection 4.2-List of Dangerous Goods for solid desensitized explosives are UN 1310, 1320, 1321, 1322, 1336, diluted with other substances to form a homogeneous solid mixture to suppress their explosive properties. Entries in 3344, 3364, 3365, 3366, 3367, 3368, 3369, 3370, 3376, 3380 and 3474. 1337, 1344, 1347, 1348, 1349, 1354, 1355, 1356, 1357, 1517, 1571, 2555, 2556, 2557, 2852, 2907, 3317, 3319, 3.4.1.3.2 Substances that: (a) Saves een provisionally accepted into Class 1 according to Test Series 1 and 2 but exempted from Test (b) are not self-reactive substances of Division 4.1; (c) are not substances of Class 5: are also assigned to Division 4.1. UN 2956, UN 3241, UN 3242 and UN 3251 are such entries. 3.4.2 Division 4.2-Substances Liable to Spontaneous Combustion 3.4.2.1 Definition under normal conditions encountered in transport, or to heating up in contact with air, and being then liable to catch Division 4.2—Substances liable to spontaneous combustion. Substances, which are liable to spontaneous heating about:blank 23/01/2015#

Page 14DGR Page 17 of 40 fire. The following types of substances are classified in Division 4.2: • pyrophoric substances; and • self-heating substances. 3.4.2.2 Properties generates heat. If the rate of heat production exceeds the rate of heat loss, then the temperature of the substance Selt-heating of a substance is a process where the gradual reaction of that substance with oxygen (in the air) will rise which, after an induction time, may lead to self-ignition and combustion. Two types of substances can be distinguished with spontaneous combustion properties. 3.4.2.2.1 Pyrophoric Substances quantities, ignite within 5 minutes of coming in contact with air. These substances are the most liable to spontaneous Pyrophoric substances (liquid or solid) including mixtures and solutions are substances which, even in small combustion. 3.4.2.2.2 Self-heating Substances Self-heating substances are substances, which in contact with air without an additional energy supply are liable to self-heating. These substances will ignite only in large amounts (kilograms) and after long periods of time (hours or days). 3.4.2.3 Classification 3.4.2.3.1 Pyrophoric Solids ith the test methods and criteria of in the current edition of the UN Manual of Tests and Criteria, Part Ill, subsectio olids are considered pyrophoric solids which must be classified in Division 4.2 if, in tests performed in accordanc 33.3.1, the sample ignites in one of the tests. lAUDO 3.4.2.3.2 Pyrophoric Liquids with the test methods and criteria of the current edition of the UN Manual of Tests and Criteria, Part III, subsection Liquids are considered pyrophoric liquids which must be classified in Division 4.2 if, in tests performed in accordance 33.3.1, the liquid ignites in the first part of the test, or if it ignites or chars the filter paper. 3.4.2.3.3 Self-heating Substances 3.4.2.3.3.1 A substance must be classified as a self-heating substance of Division 4.2 if, in tests performed ir subsection 33.3.1: accordance with the test method and criteria in the current edition of the UN Manual of Tests and Criteria, Part I!! (a) a positive result is obtained in a test using a 25mm sample cube at 140°C; (b) a positive result is obtained in a test using a 100mm sample cube at 140°C and a negative result is obtained in of more than 3 m°: a test using a 100mm cube sample at 120°C and the substance is to be transported in packages with a volume (0) a positiven a m m cued sampit at g° and the subslance t0 0 c apored in pace rages it a voidine of more than 450 L; and 1) a test sing a 15 medie sample it 1000 mm sample cube at 140°C and a posive resul is oblained in 312d must not Be classied in Dis, on 4-2 but ty Division 4.1 (so 34 21ive resul according to this test 3.4.2.3.3.3 A substance must not be classified in Division 4.2 if: (a) a negative result is obtained in the test using a 100mm sample cube at at.140°C; about blank 23/01/2015#

Page 15DGR Page 18 of 40 (c) a positive result is obtained in the test using a 100mm sample cube at 140°C and a negative result is obtained in the test using a 25 mm cube sample at 140°C, a negative result is obtained in the test using a 100mm cube sample at 100°C and the substance is to be transported in packagings with a volume not more than 450 L 3.4.2.4 Packing Group Criteria 3.4.2.4.1 Pyrophoric Substances Pyrophoric liquids and solids of Division 4.2 must be assigned to Packing Group I. 3.4.2.4.2 Self-heating Substances Self-heating substances must be allocated to packing groups in accordance with the following criteria: 3.4.2.4.2.1 Packing Group I| 140°C. Packing Group I! must be assigned if the substance gives a positive result in the test using a 25mm cube sample at 3.4.2.4.2.2 Packing Group II! Packing Group III must be assigned to the substance if: (a) a positive result is obtained in the test using a 100mm sample cube at 140°C and a negative result is obtained volume of more than 3 m*; in the test using a 25 mm cube sample at 140°C and the substance is to be transported in packagings with a (b) a positive result is obtained in a test using a 100mm sample cube at 140°C and a negative result is obtained in he test using a 25 mm cube sample at 140°C, a positive result is obtained in the test using a 100mm cub ample at 120°C and the substance is to be transported in packagings with a volume of more than 450 L; c c) a positive result is obtained in the test using a 100 mm sample cube at 140°C and a negative result is obtainer sample at 100°C. n the test using a 25 mm cube sample at 140°C and a positive result is obtained in a test using a 100 mm cubi 3.4.3 Division 4.3—Substances Which, in Contact with Water, Emit Flammable Gases 3.4.3.1 Definition which, by interaction with water, are liable to become spontaneously flammable or to give off flammable gases in Division 4.3-Substances, which, in contact with water, emit flammable gases (Dangerous when wet). Substances dangerous quantities. emits flammable gas. Where the term "Water-reactive" is used in these Regulations, it refers to a substance, which in contact with water 3.4.3.2 Properties Certain substances in contact with water, emit flammable gases which can form explosive mixtures with air. Such unprotected gil is the restored is ae and Tames may endanger people and the environmen. The test. 3.4.3.3 Classification Suborned is aco dance lace wie meted an antena in the mut be on of ile anua rests and Crieria. Part Ill, subsection 33.4.1: (a) spontaneous ignition takes place in any step of the test procedure; or (b) there is an evolution of a flammable gas at a rate greater than 1 L/kg of the substance per hour. 3.4.3.3.1 Principle of the Method about:blank 23/01/2015#

Page 16(NTD) MINTON, TREHARNE & DAVIES LIMITED Inayared: desting laboratories Our ref: PS/ajr Certificate No: R13- 08585 24" June 2013 heating. The sample was received from 18 June 2013 and tested as detailed below, Sample identified as:- We hereby certify that we have analysed the undermentioned sample of Material for propensity towards solf JERET W2060 PRODUCT Test Method: Transport of Dangerous Goods United Nations Recommendations on the Section 33.3 Division 4.2 Manual of Tests and Criteria - Sth revised edition Date of testing 21.6.2013 Section 33.3 1.3.1 Pyrophoric Solids The Sample failed to ignite in air within 5 minutes Section 33.3 1.3.3. Self heating substances temperature monitored for 24 hours. The sample was heated in air at 140°C in a 100mm test cube and its The sample temperature did not exceed 200°C. Conclusion: The sample is not a pyrophoric solid of Division 4.2. The sample is not a self heating substance of Division 4.2. MINTON, TREHARNE & DAVIES LTI MAlloman BSc, MSc, MChemA, CSci, CChem, FRSC, MAPA, MIFST J. Robinson Jeret Lid For the attention of: Jerry Elvin Ilouston 4 Birchgrove, Pentrewshire PAG 7DF Ene: Neill Clerk & Murray cover letter & UPS Consignment Note: HEAl OFFICE ALSO OFFICES AT LONDON, HOUSTON, SINGAPORE, CAKMAKTHEN MERTON HOUSE, CROESCAUARN CIOS, CAKE C123 SHE UK TEL 1++ (0)29205-10000 Eat +41(0)29 20540111 intd@minton.co.uk WEBSITE www.winton.co.nk REGISTRATION ATMASK: FRGLAND 195262#

Page 17MINTON, TREHARNE & DAVIES LTD. CONSULTING SCIENTISTS & ENGINEERS ANALYTICAL & TESTING LABORATORIES Telephone: Head Olice Rapiscratica No.: England 495262 fax: (91222)5-003 Head Office and Laborzaries Alter Hours: Tel4x: 7103 MINTON 01227) 5401 MERTON HOUSE, CROESCADARN CLOSE, PENTWYN, COPIES TE CARDIFF, CF2 7HE. N. MCMILLAN C. DAVIDSON! J.R. ELVIN Certificale/Coal No. C3178:001/96 Our ref CRM/AJD J. RusSEL 6 August 1996 We hereby certify that we have analysed the undermentioned sample in accordance with the seit-heating test for Charcoal as specified by IMO Code of Safe Practice for Solid Bulk Cargoes Augus: 199. Sample identific ed The sample was received by us via Tate & Lyie Process Technology on the 2nc - "8 X 24 BONE CHARCOAL" Test Method The test sample was heated at 140°C for 12 hours in a 100mm side stainless steel mesh ..man so., cage and its temperature monitored. - : Test Results The sample did not undergo spontaneous ignition during the lest period. The temperature of the sample did not reach 200°C during the rest period. Cote The temperature indicated by the thermocouple in the middle of the sample indicated maximum temperature of 142° MINTON, TREHARNE & DAVIES LTD C.R. Mullins lor the attention of Mr A. Newto faersk Line UT 1 Canada Square London Canary Wharf E14 5DP Page 1 of l#