Transport Corp. of America — Hazardous Materials Safety Interpretation

Page 1U.S. Department 1200 New Jersey Avenue SE of Transportation Washington, DC 20590 Pipeline and Hazardous Materials Safety Administration AUG 1 2 2015 Mr. Greg Payne Support Center Manger/ Field Support Specialist Transport Corp. of America 2875 West Penn St. North Liberty, IA 52317 Reference No. 15-0085 Dear Mr. Payne: This is in response to your May 1, 2015 e-mail request and subsequent telephone conversation with a member of my staff regarding requirements under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to hazardous substances. You state that you received a violation for not indicating the letters RQ on the shipping paper for a shipment of UN 1760, Corrosive liquid, n.o.s (Phosphoric Acid, Hydrofluoric Acid) 8, PG II, 2 Drums, 1096 LBS. You ask if there is an HMR requirement for the shipper to include the weight or concentration range of each hazardous component of a mixture on shipping papers. The answer to your question is no. There is no requirement for a shipper to indicate weights or concentration ranges for hazardous components of a mixture or solution. Section 172.203(c) prescribes the documentation requirements for materials that are hazardous substances. Based on the information provided, since the weight of the hydrofluoric acid in the mixture is below the 100 pound limit indicated in Appendix A to § 172.101, the letters "RQ" on the shipping paper would not be required for this hazardous material. I trust this information is helpful. If you have further questions, please do not hesitate to contact this office. Sincerely, - 1 Duane Pfund International Standards Coordinator Standards and Rulemaking Division#

Page 2Webb 112 203(C)(2) Goodall, Shante CTR (PHMSA) HAzardous Substan. From: 15-0085 Sent: Geller, Shelby CTR (PHMSA) Friday, May 01, 2015 4:14 PM To: Hazmat Interps Subject: Attachments: FW: Transport America Interpretation letter for RQ 81111071.pdf RQ.pdf; FW: 30030624 / TCAM 6142485 Material Info; BARDA MEX BOL # Hi Shante and Alice, Attached is a formal letter of interpretation. Thanks, Shelby From: Greg Payne [mailto:Greg.Payne@transportamerica.com] To: PHMSA HM InfoCenter Sent: Friday, May 01, 2015 9:56 AM Subject: FW: Transport America Interpretation letter for RQ May 1, 2015 Office of Hazardous Materials Standards Pipeline and Hazardous Materials Safety Administration Attn: PHH-10 U.S Department of Transportation East Building 1200 New Jersey Avenue S.E. Washington DC 20590-0001 RE: Request for Interpretation regarding determining a Hazardous Substance RQ Listing on the bill of lading, Regulation 172.203 (c) (2). To Whom it May Concern: Transport America is requesting guidance in determining if a shipper needs to include on the bills the formula for a finished good to determine if the mixture is required to include an RQ on the bill of lading. We received a violation from the DOT For: RQ NOT ON SHIPPING PAPER (FMCSR 172.203 (c) (2) - UN1760 Corrosive liquid, n.o.s (Phosphoric Acid, Hydrofluoric Acid) 8, PGlI, 2 Drums, 1096 LBS. (548 Ibs. per drum) According to the Hazardous Substance table Phosphoric Acid would need a RQ if it is 5,000 Ibs. or more per container and Hydrofluoric Acid if it is 100 Ibs. or more per container. Is there a HMR that states shippers have to include the weight of each Hazardous Substance in a mixture per container? Or is the officer incorrect when it comes to interpreting the HMR for RQ? included in the recipe for a Finished good? Is this correct? According to the shipper, Chemetall, they are not required to include the total weight, of each hazardous Raw Material 1#

Page 3Transport America Data Qu with the state DOT and included interpretation letter 12-0181 Q3 A3: . Please see the attached document RQ.pdf. The DOT came back with regulation 177.817 (a) General requirements. A person may not accept a hazardous material for transportation or transport a hazardous material by highway unless that person has received a shipping paper prepared in accordance with part 172 of this subchapter or the material is excepted from shipping paper requirements under this subchapter. A subsequent carrier may not transport a hazardous material unless it is accompanied by a shipping paper prepared in accordance with part 172 of this subchapter, except for $172.204, which is not required. After this Data Qu was denied by the state we received the formula from the shipper: According to them there is only 10 Ibs. 1.8% of Hydrofluoric Acid in the mixture. Please see the attached E-mail which includes the MSDS. Also included the actual Bill of Lading. How do we find a resolution to this violation so it doesn't happen in this particular state again? Thank you, Greg Payne GREG PAYNE Hazmat Specialist Support Center Manager/ Field Support Specialist N. Liberty, IA. TRANSPORT CORP. OF AMERICA 651-688-4429 651-994-5781 FAX Greg.Payne@Transportamerica.com VALUE DRIVEN 2#

Page 4Goodall, Shante CTR (PHMSA) From: Sent: Greg Payne <Greg.Payne@transportamerica.com> To: Thursday, April 30, 2015 2:07 PM Greg Payne Subject: FW: 30030624 / TCAM 6142485 Material Info Attachments: CRYSCOAT 747.pdf From: Tom Allen [mailto:Tom.Allen@chemetail.com] To: Michelle Solheid Sent: Thursday, April 23, 2015 12:06 PM Cc: Wayne Williams Subject: 30030624 / TCAM 6142485 Material Info MSDS Packaging Material HDPE High-density polyethylene Material Volume = 55 gallons HF = 1.8% of composition Weight of Finished Good in Drum = 525##

Page 5Object Material 000000000003838000 CrysCoat 747 (Buk) Class Type 001 Material dass Assignments Class Description Sta S LIC Lom EINAL COMP Finai Composition LEP PROP Typical Properties Entry Values for Class FINAL COMP - Object 000000000003838000 General Characteristic Description Vaue Weight % 10 5.0000 Chemical Name 10 NONYL PHENOL POLY ETHOXY ETHA. CAS # 10 9016-45-9 Final Composition Raw M.. R1193 Weight % 11 1.8000 Chemical Name 11 HYDROFLUORIC ACID CAS # 11 7664-39-3 Final Composition Raw M Chemetall expect more • Ar ALBEMARLE Company Please consider the environment before printing the email and/or any related attachments. [attachment "MEX BOL # 81111071.pdf" deleted by Wayne Williams/Chemetall US Inc./Chemetall] [attachment "BARDA TX DataQ 1302748 6A04 results.pdf" deleted by Wayne Williams/Chemetall US Inc./Chemetall] Chemetall expect more + A* ALBEMARLE Company 2#

Page 6Please consider the environment before printing the email and/or any related attachments. 3#

Page 7PICK LIST Paga 1/15 26.02.2015 81111071 42274981 Scheduled Ship Date From: Chemetall US, Inc. Shipper's No. 30030624/19.02.2015 Consignee P.O. No. - Release No. Order No. / Date 1100 Technology Drive Ship VIA TRANSPORT AMERICA 4 JACKSON MI 49201 EMERGENCY CONTACT / 24 HOUR NUMBER: CHEMTREC - (300) 424-9300 Freigh READ CONTRACT# 16160 Consigned To: 78681 Send Freight Bill To: FOR FREIGHT COLLECT SHIPMENTS: Chemetall Mexicana - Monterrey if this shipment is to be delivered to the consignee, ithout recourse to the consignor, the consig Fraccionamiento Industrial Lincoln all sign the following statement; The carrier n Nueva York 4037 CareFreliver, Notes: 64310 MONTERREY VIA LAREDO TEXAS, FOR CUSTOMS CLEARANCE AND BORDER CROSSING CONTACT: VOWGROUP/14414 IMPORT ROAD, LAKEDU, ITC - PHONE 956-724-6950, FAX (956) 724 4237 *** 3 COPIES (FREIGHT, DRIVER TX 78045 USA (INTERNATIONAL TRADE CENTER) FILE) OF SAP BOL REQ'D WITH EVERY ORDER. Pcs. Product Name Product Code Weight Lbe. Batch No. - Bin No. 4 Batches: 881125141 = 4 Gardobond Additive H 7204 (5 GAL/19 6649006 176 PKGS. Hal Kind of Pkg. Description of Articles, Special Marks and Exceptions Lba. 8 PATI CLEANING COMPOUND, NOIBN LIQUID OR POWDER NMFC 48581 OR 48580 $3 CLASS 55 360 4 BA1993, COMBUSTIBLE LIQUID, B.D.S., (HYDROTREATED LIGHT DISTILATE), III, FP ≥ 141° F 135 18 NMFC 155250 S2 CLEANING COMPOUND, NOIBN LIQUID OR POWDER NMFC 48581 OR 48580 S3 CLASS 55 PROTECT FROM 988 6 * PAIL FREEZING -32 UN3264, CORROSIVE LIQUID, ACIDIC, INORGANIC, N.D.S., 8, II - HMFC 44155 $3 (FERRIC SULFATE, NITRIC ACID) 306 136 < TOTAL PACKAGES IF DAMAGE OR DELAYS OCCUR, CONTACT: TOTAL WEIGHT 42188 WITH SHIPMENT FOR ARDROX 2865 & 2871 ONLY. FAX/EMAIL PROFORMA TO JACARANDA SUCHIL. KEEP ONE COPY FOR SCANNING. SEND C/A SHIPPERS CERTIFICATION: This ta to cartly that the bove named materiate are property classified, deechbed, packaged, marked and labeled, and van Cull. The consignment is offered by Chemedal US, Inc. 675 Central Ave. Now Providence, NJ 07974, USA - Telephone 908) 464-690 + In proper condition for transportation according to the applicable regulatione of the Department of Tranaportation. Chematall US, Inc., Shipper pe anto has contrasted for the emergenty contant informetion hown above between the named origin and deetinedion only. • CofA • SPCL REQMTS OK. _Date_ PLACARDS.#

Page 8PICK LIST 2/15 Page Scheduled Ship Date 26.02.2015 81111071 42274981 Shipper's No. From: Chemetall US, Inc. Consignee P.O. No. - Release No. 30030624/19.02.2015 1100 Technology Drive EMERGENCY CONTACT / 24 HOUR NUMBER: Ship VIA TRANSPORT AMERICA 4 Order No. / Date JACKSON MI 49201 CHEMTREC - (800) 424-9300 Fret READ CONTRACT# 16160 Consigned To: 78681 Send Freight Bill To: FOR FREIGHT COLLECT SHIPMENTS: Chemetall Mexicana - Monterrey If this shipment is to be delivered to the consignee Nueva York 4037 Fraccionamiento Industrial Lincoln 64310 MONTERREY x (Signatura of Consignor) VIA LAREDO TEXAS, FDR CUSTOMS CLEARANCE AND BORDER CROSSING CONTACT: NOWGROVP/14414 IMPORT ROAD, LAREDO, IX 78045 USA (INTERNATIONAL TRADE CENTER) FILE) OF SAP BOL REQ'D WITH EVERY ORDER. ITC - PHONE 956-724-6950, FAX (956) 724 4237 *** 3 COPIES (FREIGHT, DRIVER, Pcs. Product Name Product Code Weight Lba. Batch No. - Bin No. 4 TECH DRAW 9240 (5 Gal/17 Ltr Pail) 4 Batches: 880220151 = 4 76347009 135 Batches: 881201141 = 4 Gardobond Additive H 7271 * (5-gal p 10295006 176 PKGS. HM Kind of Pkg. Description of Articles, Special Marks and Exceptions Lta. 2 PAIL METAL CUTTING, DRAWING COMPOUND - NMFC 50455 PROTECT FROM 90 21 PAIL CLEANING COMPOUND, NOIBN POWDER FREEZING -32 NMFC 48581 PROTECT FROM 1071 29 DRUM FREEZING -32 9371 1 DRUM METAL CUTTING, DRAWING COMPOUND - NMFC 50455 478 See Pag TOTAL PACKAGES F DAMAGE OR DELAY OCCUR, CONTACT TOTAL WEIGHT D SHIPPERS CERTIFICATION: Thie is to carly that the aboys named materials are property cheemed, decribed, packaged, marked and labeled, and Ryan Cull. This conaignment la offered by Chemetall us, Inc. 675 Central Ave, New Providenca, NJ 07974, USA - Telephone (308) 464-6900, are in proper conditton for traneportation according to the applicable regulatione of the Departmert of Tranaportation. Chemetall US, Inc., Shipper per, who hae contracted for the emergency contact information shown above between the named origin and destination only. • CofA • SPCL REQMTS OK Date. _PLACARDS#

Page 9PICK LIST Page 3/15 26.02.2015 81111071 42274981 30030624/19.02.2015 Scheduled Ship Date Chemetall US, Shipper's No. Fo1100 Technology Drive Inc. Consignee P.O. No. - Release No. Ship VIA TRANSPORT AMERICA 4 Order No. / Date JACKSON MI 49201 EMERGENCY CONTACT / 24 HOUR NUMBER: CHEMTREC - (800) 424-9300 Freighters: CONTRACT# 16160 78681 Send Freight Bill To: FOR FREIGHT COLLECT SHIPMENTS: Cogienetali Mexicana - Monterrey Fraccionamiento Industrial Lincoln 64310 MONTERREY Nueva York 4037 decline to make delivery of this shipment withou payment of freight and all other lawful charges x (Signalure of Consignor) VIA LAREDO TEXAS, FDR CUSTOMS CLEARANCE AND BORDER CROSSING CONTACT: ITC - PHONE 956-724-6950, FAX (956) 724 4237 *** 3 COPIES (FREIGHT, DRIVER, HOWGRDUP/14414 IMPORT ROAD, LAREDO, IX 78045 USA (INTERNATIONAL TRADE CENTER) FILE) OF SAP BOL REO'D WITH EVERY ORDER. Pcs. Product Name Product Code Weight Lbe. Batch No. - Bin No. 6 Deoxidizer LNC (4 GAL / 19 LITRE PA 2 Batches: 880219151 = 6 3850006 306 Batches: 880115151 = 2 PROTEXO 1125* (5 Gal/19 Itr Pail) 76186006 90 PKGS. Kind of Pkg. Description of Articles, Special Marks and Exceptions Lba. I DRUM UN1760, CORROSIVE LIQUID, N.O.S., 481 (NITRIC ACID,) 6 X DRUM :UN1805, PHOSPHORIC ACID, SOLUTION, B, III 8, II - NMFC 44155 53 NMFC 44155 S4 3318 8 X DRUM UN1805, PHOSPHORIC ACID, SLUTION, 8, III NMFC 44155 S4 PROTECT FROM 4200 15 FREEZING -32 * DRUM NA1993, COMBUSTIBLE LIQUID, N.D.S., (ETHYL ALCOHOL, ) 7275 III - NMFC 155250 S2 See Page 1 < TOTAL PACKAGES IF DAMAGE OR DELAYS OCCUR, CONTACT: TOTAL WEIGHT C are in proper condition for transportation according to the applicable regulatione of the Department of Transportation. Chemetall US, Inc, Shipper per, SHIPPERS CERTIFICATION: Thie la to cartily that the above named materlata are property claballed, deecrbed, packaged, marked and labeled, and Ryan Cull. Thta conalgnment ta ofered by Chemetal US, Inc. 675 Contrai Ava., Now Providence, NJ 07974, USA - Telephone (908) 464-6500. who has contracted for the emergency contaot information shown above between the nemed origin and dootination onty. • CofA • SPCL REQMTS OK. Date PLACARDS#

Page 10PICK LIST Page 4/15 Scheduled Ship Date 26.02.2015 81111071 Shipper's No. 42274981 Consignee P.O. No. - Release No. 30030624/19.02.2015 From: Chemetall US, Inc. 1100 Technology Drive Ship VIA TRANSPORT AMERICA 4 Order No. / Date JACKSON MI 49201 EMERGENCY CONTACT / 24 HOUR NUMBER: CHEMTREC - (800) 424-9300 CONTRACT# 16160 Consigned To: : 78681 FOR FREIGHT COLLECT SHIPMENTS: Chemetall Mexicana - Monterrey Send Freight Bill To: if this shipment is to be delivered to the consignee, without recourse to the consignor, the consigno Fraccionamiento Industrial Lincoln shali sign the following statement; The carrier ma Nueva York 4037 lecline to make delivery of this shipment withol ayment of freight and all other lawful charges 64310 MONTERREY Carliotes: x (Signature of Consignor) VIA LAREDO TEXAS, FOR CUSTOMS CLEARANCE AND BORDER CROSSING CONTACT: 9OWGROUP/14414 IMPORT ROAD, LAREDO, TX 78045 VSA (INTERNATIONAL TRADE CENTER FILE) OF SAP BOL REQ'D WITH EVERY ORDER. C - PHONE 956-724-6950, FAX (956) 724 4237 *** 3 COPIES (FREIGHT, DRIVER Pcs. Product Name Product Code Weight Lbe. Batch No. - Bin No. 21 Chem Strip 5311 * (5 GAL/19 LTR PAI 14 Enprox 8416 * (5 gal / 19 Itr) Batches: 020129151 = 21 201020015 1071 Batches: 10061413 = 14 207037006 812 PKGS. HM Kind of Pkg. Description of Articles, Special Marks and Exceptions Lba. 5 DRUM PETROLEUM OIL, NOIBN - NMFC 155150 2331 2 * DRUM V81760, CORROSIVE LIQUID, N.O.S. (PHOSPHORIC ACID, HYDROFLUORIC ACID) 1096 4 X DRUM 8, II - NMFC 44155 S3 UN3266, CORROSIVE LIQUID, BASIC, INORGANIC, N.O.S., (SODIUM METASILICATE,) 2327 4 DRUM RUST REMOVING OR PREVENTING COMPOUND 8, III - NMPC 44155 S4 PROTECT PROM FREEZING -32 D/T PETROLEUM - NMFC 50234 S3 1993 See Page I TOTAL PACKAGES IF DAMAGE OR DELAYS OCCUR, CONTACT: TOTAL WEIGHT E SHIPPERS CERTIFICATION: This is to cority that the above named materists are property clabalfed, decribed, packaged, marked and labeled, and Ryan Cull. The conaignment te offered by Chemedal US, Inc. 675 Central Ave., Now Providence, NJ 07974, USA - Telephone 908) 464-6900. are in proper condition for tranaportation according to the applicable regulatione of the Department of Traneportation. Chemetall US, Inc., Shipper per. who hae contracted for the emergency contact information atown above between the named origin and deetination onty. • cotA • SPCL REQMTS OK. Date _ PLACARDS#

Page 11PICK LIST 5/15 Page 26.02.2015 81111071 42274981 30030624/19.02.2015 Scheduled Ship Date Chemetall US, Shipper's No Fo1100 Technology Drive Inc. Consignee P.O. No. - Release No. Ship VIA TRANSPORT AMERICA 4 Order No. / Date JACKSON MI 49201 EMERGENCY CONTACT / 24 HOUR NUMBER: CHEMTREC - (800) 424-9300 CONTRACT# 16160 78681 FOR FREIGHT COLLECT SHIPMENTS: Cognemetall Mexicana - Monterrey Send Freight Bill To: Fraccionamiento Industrial Lincoln 64310 MONTERREY Nueva York 4037 CaLlotes: x VIA LAREDO TEXAS, FOR CUSTOMS CLEARANCE AND BORDER CROSSING CONTACT: TC - PHONE 956-724-6950, FAX (956) 724 4237 *** 3 COPIES (FREIGHT, DRIVER YOWGROUP/14414 IMPORT ROAD, LAREDO, TX 78045 USA (INTERNATIONAL TRADE CENTER FILE) OF SAP BOL REQ'D WITH EVERY ORDER. Pcs. Product Name Product Code Weight Loa. Batch No. - Bin No. 4 Liqui-Det (5 Gal/19 Itr Pail) 16 Batches: 880209151 = 4 4540006 184 Batches: 880220151 = 16 GardoClean VP 4628 (20 Gal Drum) 6933008 2832 PKGS. Description of Articles, Special Marks and Exceptions Lbe. I X BIN UN1805, PHOSPHORIC ACID, SOLUTION, B, III NMFC 44155 S4 2923 1 X BIN UN3264, CORROSIVE LIQUID, ACIDIC, INORGANIC, N.O.S., (FERRIC SULFATE, NITRIC ACID) 3445 8, II, RO - NMFC 44155 S3 See Page T < TOTAL PACKAGES F DAMAGE OR DELAY CCUR, CONTACT TOTAL WEIGHT → are in proper condition for transportation according to the applicable regulations of the Department of Transportation. Chemetal Us, Inc., Shipper per. SHIPPERS CERTIFICATION: Thie le to cartify that the above named materlate are properly classifled, described, packaged, marked and labeled, and Ryan Cull. Thie conaignment to offered by Chemetall Us. Inc. 675 Central Ave., New Providence, AJ 07974, USA - Telephone (308) 464-6900. wto has contracted for the emergenoy contact Information shown above between the named origin and deettnation only. • CofA • SPCL REQMTS OK _Date PLACARDS#

Page 12PICK LIST Page 6/15 Scheduled Ship Date 26.02.2015 81111071 Shipper's No. 42274981 From: Chemetall US, Inc. Consignee P.O. No. - Release No. 30030624/19.02.2015 Order No. / Date 1100 Technology Drive Ship VIA TRANSPORT AMERICA 4 JACKSON MI 49201 EMERGENCY CONTACT / 24 HOUR NUMBER: CHEMTREC - (800) 424-9300 CONTRACT# 16160 Consigned To: 78681 FOR FREIGHT COLLECT SHIPMENTS: Chemetall Mexicana - Monterrey Send Freight Bill To: Nueva York 4037 Fraccionamiento Industrial Lincoln CaneDelec.[Notes: 64310 MONTERREY x VIA LAREDO TEXAS, FOR CUSTOMS CLEARANCE AND BORDER CROSSING CONTACT: FILE) DF SAP BOL REQ'D WITH EVERY ORDER. Pcs. Product Name Product Code Weight Lts. Batch No. - Bin No. 5 Gardoclean A 5549 (55 Gal/208 It dr 1 Tech Cool 35035NB (55 GAL/208 LTR) Batches: 880220151 = 5 4406002 2465 Batches: 880116151 = 1 11770002 478 PKGS. Description of Articles, Special Marks and Exceptions Lbe. See Pagg TOTAL PACKAGES IF DAMAGE OR DELAYS OCCUR, CONTACT: TOTAL WEIGHT 4* SHIPPERS CERTIFICATION: This is to cerity that the above named materiate are property claarned, deecribed, packaged, marked and labeled, and Ryan Cull. Thia conaignment la offered by Chemetal US, Inc. 675 Contral Avo., New Providence, NJ 07574, USA - Telephone (306) 464-6300, are in proper condition for tranaportation according to the appitcable regulattone of the Department of Transportation. Chemetall US, Inc., Shipper per. who hao contracted for the emergency contact information shown above between the named origin and deedination onty. • COtA • SPCL REQMTS OK. Date PLACARDS#

Page 13PICK LIST Page 7/15 26.02.2015 81111071 42274981 30030624/19.02.2015 Fot100 Technology Drive Inc. Consignee P.O. No. - Release No. Ship VIA TRANSPORT AMERICA 4 Order No. / Date JACKSON MI 49201 EMERGENCY CONTACT / 24 HOUR NUMBER: CHEMTREC - (800) 424-9300 CONTRACT# 16160 78681 FOR FREIGHT COLLECT SHIPMENTS: Connemetall Mexicana - Monterrey Send Freight Bill To: if this shipment is to be delivered to the consignee, without recourse to the consignor, the consigno Fraccionamiento Industrial Lincoln shall sign the following statement; The carrier may 64310 MONTERREY Nueva York 4037 Cartoon Notes: (Signature of Consignor) VIA LAREDO TEXAS, FOR CUSTOMS CLEARANCE AND BORDER CROSSING CONTACT: PORT ROAD, LAREDO, ITC - PHONE 956-724-6950, FAX (956) 724 4237 *** 3 COPIES (FREIGHT, DRIVER, IX 78045 USA (INTERNATIONAL TRADE CENTER) FILE) OF SAP BOL REQ'D WITH EVERY ORDER. Pcs. Product Name Product Code Weight Lte. Batch No. - Bin No. 1 Oxsilan 9810/2 (55 GAL/208 LTR) 4 DA-246N (55 Gal/208 Itr Drum) Batches: 020204151 = 1 11402002 481 Batches: 020205151 = 4 76065002 1922 PKGS. Description of Articles, Special Marks and Exceptions Lba. See Page TOTAL PACKAGES IF DAMAGE OR DELAYS OCCUR, CONTACT TOTAL WEIGHT • are in proper condition for traneportation according to the applicable regutattona of the Department of Transportation. Chemetail US, Inc., Shipper per, SHIPPERS CERTIFICATION: Thie le to certity that the above named materiate are properly classifled, deecribed, packaged, marked and labeled, and who here sontracted for the emergery contact information shoem above betwoon the named origin and deetnator only. Ryan Cull. Thia conelgnment to offered by Chemetall US, Inc. 675 Central Avo., How Providence, NJ 07974, USA - Telephone (908) 464-6900, • CofA • SPCL REQMTS OK _ Date. PLACARDS#

Page 14PICK LIST 8/15 Page Scheduled Ship Date 26.02.2015 81111071 Shipper's No. 42274981 From: Chemetall US, Inc. Consignee P.O. No. - Release No. 30030624/19.02.2015 Ship VIA TRANSPORT AMERICA 4 Order No. / Date 1100 Technology Drive JACKSON MI 49201 EMERGENCY CONTACT / 24 HOUR NUMBER: CHEMTREC - (800) 424-9300 Freigh reas CONTRACT# 16160 Consigned To: 78681 Send Freight Bill To: FOR FREIGHT COLLECT SHIPMENTS: Chemetall Mexicana - Monterrey Praccionamiento Industrial Lincoln 64310 MONTERREY Nueva York 4037 CarMe/Notes: x (Signature of Consignor) VIA LAREDO TEXAS, FOR CUSTOMS CLEARANCE AND BORDER CROSSING CONTACT: 1C - PHONE 956-724-6950 OWGROUP/14414 IMPORT BRAVAX (956) 724 4237 *** 3 COPIES (FREIGHT, DRIVER, TX 78045 USA (INTERNATIONAL TRADE CENTER) FILE) DE SAP BOL REQ'D WITH EVERY ORDER. Pcs. Product Name Product Code Weight Lot. Batch No. - Bin No. 2 CrysCoat 2707 FF (55Gal/208 Itr Dru 8 Chem Cote 3406 * (55 Batches: 880209151 = 2 11349002 1082 Batches: 880218151 = 8 gal / 208 ltr 200956002 4200 PKGS. Description of Articles, Special Marks and Exceptions Lba. see Page ToTAL PACKAGES IF DAMAGE OR DELAYS OCCUR, CONTACT TOTAL WEIGHT SHIPPERS CERTIFICATION: Thia te to cortily that the above named materiale are property claparted, described, packaged, marked and labeled, and Ryan Cull. Thie coneignment te offered by Chemetall US. Inc. 675 Certal Aya., New Providence, NJ 07974, USA - Telephone 908) 464-6900. are in proper condition for tranaportation according to the applicable regulatione of the Department of Traneportation. Chemetall US, Inc., Shipper per, who haa contracted for the omergency contact information shown above between the named origin and deetnation only. • CofA • SPCL REQMTS OK Date PLACARDS#

Page 15PICK LIST 9/15 Page 26.02.2015 81111071 42274981 30030624/19.02.2015 Scheduled Ship Date Chemetall US, Shipper's No. F°1100 Technology Drive Inc. Consignee P.O. No. - Release No. Ship VIA TRANSPORT AMERICA 4 Order No. / Date JACKSON MI 49201 EMERGENCY CONTACT / 24 HOUR NUMBER: CHEMTREC - (800) 424-9300 Freigh Reass pre CONTRACT# 16160 CoChemetall Mexicana - Monterrey 78681 Send Freight Bill To: Nueva York 4037 Fraccionamiento Industrial Lincoln Loatine to make dane of this ali an ea 64310 MONTERREY CarLotes: (Signature ol Consigner) VIA LAREDO TEXAS, FOR CUSTOMS CLEARANCE AND BORDER CROSSING CONTACT: BOWGR0/14414 IMPORT READ, LAREDO, TX 78045 USA (INTERNATIONAL TRADE CENTER) FILE) DF SAP BOL REQ'D WITH EVERY ORDER. ITC - PHONE 956-724-6950, FAX (956) 724 4237 *** 3 COPIES (FREIGHT, DRIVER, Pcs. Product Name Product Code Weight Los. Batch No. - Bin No. 12 Gardolene D 6871 (55 Gal / 208 Ltr 1 Batches: 880219151 = 12 10232002 5820 Oakite 98 (55Gal/208 Ltr Drum Batches: 39012915 = 1 10585007 454 PKGS. Description of Articles, Special Marks and Exceptions Lbe. See Page 1 & TOTAL PACKAGES F DAMAGE OR DELAY CCUR, CONTACT TOTAL WEIGHT SHIPPERS CERTIFICATION: Thie ta to carty that the above named materiate are property clained, described, packaged, marked and labeled, and Ryan Cull. The coneignment to offered by Chemetall US, InC. 675 Central Avo, New Providenca, HJ 07974, USA - Telephone (908) 464-6900, are in propar condition for transportation according to the appllcable regulatione of the Department of Traneportation. Chemetall US, Inc., Shipper per, who hae contracted for the emergency contact information hown ebove between the named origin and destination ontr • CofA • SPCL REQMTS OK _Date. PLACARDS#

Page 16PICK LIST 10/15 Page Scheduled Ship Date 26.02.2015 81111071 Shipper's No. Consignee P.O. No. - Release No. 42274981 30030624/19.02.2015 From: Chemetall VS, Inc. Order No. / Date 1100 Technology Drive Ship VIA TRANSPORT AMERICA 4 JACKSON MI 49201 EMERGENCY CONTACT / 24 HOUR NUMBER: Frei REAT CHEMTREC - (800) 424-9300 CONTRACT# 16160 Consigned To: 7B681 Chemetall Mexicana - Monterrey Send Freight Bill To: Nueva York 4037 Fraccionamiento Industrial Lincoln 64310 MONTERREY (Signature of Consignor) VIA LAREDO TEXAS, FOR CUSTOMS CLEARANCE AND BORDER CROSSING CONTACT: ITC - PHONE 956-724-6950, dOWGROVe/ 14914 IMPORI ROAD, LAREDO, TX 78045 USA (INTERNATIONAL TRADE CENTER) FILE) OF SAP BOL REQ'D WITH EVERY ORDER. FAX (956) 724 4237 *** 3 COPIES (FREIGHT, DRIVER, Pcs. Product Name Product Code Walght Lbe. Batch No. - Bin No. 2 CrysCoat 747 (55Gal/208 Ltr Drum) 1 Batches: 880122151 = 2 3838002 1096 Rust Preventive 1 (55Gal/208Ltr Dr) Batches: 880218151 = 1 5000002 458 PKGS. Description of Articles, Special Marks and Exceptions Lbe. See Page TOTAL PACKAGES IF DAMAGE OR DELAYS OCCUR, CONTACT: TOTAL WEIGHT C are in proper condition for tranaportation according to the appilcable regulatione of the Department of Tranaportation. Chemetall US, Inc., Shipper per, SHIPPERS CERTIFICATION: This la to carity that the above named materiate are property casted, described, packaged, marked and labeled, and who ha contracted for the emergency contaci information ahowm above between the named origin and deetination onty. Rya Cull. Thia conaignment to ofered by Chemetall Us, Inc. 675 Central Ava, Now Providence, NJ 07974, USA - Telaphone (308) 464-5900. C of A • SPCL REQMTS OK Date _PLACARDS,#

Page 17PICK LIST Page 11/15 26.02.2015 81111071 42274981 30030624/19.02.2015 Scheduled Ship Date Shipper's No. From: 1100 Technology Drive Chemetall US, Inc. Consignee P.O. No. - Release No. Ship VIA TRANSPORT AMERICA 4 Order No. / Date JACKSON MI 49201 EMERGENCY CONTACT / 24 HOUR NUMBER: CHEMTREC - (800) 424-9300 FreighteR RE CONTRACT# 16160 Consheetall Mexicana - Monterrey Send Freight Bill To: OR FREIGHT COLLECT SHIPMENT his shipment is to be delivered to the consign Nueva York 4037 Fraccionamiento Industrial Lincoln 2222 64310 MONTERREY (Signature cf Consignor) VIA LAREDO TEXAS, FOR CUSTOMS CLEARANCE AND BORDER CROSSING CONTACT: TX 78045 USA (INTERNATIONAL TRADE CENTER) FILE) DF SAP BOL REQ'D WITH EVERY ORDER. Pcs. Product Name Product Code Weight Lbe. Batch No. - Bin No. 3 Gardobond AP 9809 (55-gal/208-1tr D 4 GEO-GUARD 4021* (55 Gal/206 Ltr Dru Batches: 880203151 = 3 11147002 1455 76106002 2327 Batches: 881105141 = 2, 881219141 = PKGS. HAH KING Description of Articles, Special Marks and Exceptions Lbe. See Page 1 < TOTAL PACKAGES IF DAMAGE OR DELAY: OCCUR, CONTACT: TOTAL WEIGHT SHIPPERS CERTIFICATION: Thie la to cortily that the above named matertata are property clatted, decribed, packaged, marked and labeled, and Ryan Cull. Thia conaignment le ofered by Chemetal US, Inc. 675 Contral Ave, Now Providenco, NJ 07974, USA - Telephone (908) 464-6300, are in proper condition tor tranaportation according to the applicable regulations of the Department of Tranaportation. Chemetall US, Inc., Shipper per. airo has contracted for the emergency contact information shown above between the named origin and destination only. • CofA • SPCL REQMTS ок_ _Date PLACARDS#

Page 18PICK LIST Page 12/15 26.02.2015 81111071 42274981 Scheduled Ship Date Shipper's No. Consignee P.O. No. - Release No. 30030624/19.02.2015 From: Chemetall US, Inc. Ship VIA TRANSPORT AMERICA 4 Order No. / Date JACKSON MI 49201 1100 Technology Drive EMERGENCY CONTACT / 24 HOUR NUMBER: eight Charges al CHEMTREC - (800) 424-9300 REPAI CONTRACT# 16160 Consigned To: 78681 Chemetall Mexicana - Monterrey Send Freight Bill To: FOR FREIGHT COLLECT SHIPMENTS this shipment is to be delivered to the consigne Nueva York 4037 Fraccionamiento Industrial Lincoln 2222 64310 MONTERREY (Signature of Consignor) VIA LAREDO TEXAS, FOR CUSTOMS CLEARANCE AND BORDER CROSSING CONTACT: 00 PEN 6-720-600 AX 1936) 1249235 SA COPIES TRADER IX 78045 USA (INTERNATIONAL TRADE CENTER' FILE) DE SAP BOL REQ'D WITH EVERY ORDER. Pcs. Product Name Product Code Weight Lba. Batch No. - Bin No. 4 Gardoclean S 5679 (54 GAL/204 LTR D 3 Batches: 880205151 = 4 70135002 2152 TECH DRAW 9663 (55 Gal/208 Ltr Drum 76351024 Batches: 83021115 = 3 1419 PKGS. HM KIS: Description of Articles, Special Marks and Exceptions Lba. See PagG TOTAL PACKAGES IF DAMAGE OR DELAY CCUR, CONTACT TOTAL WEIGHT → SHIPPERS CERTIFICATION: Thie to to cerity that the above named materlate are property classied, described, packaged, marked and labeled, and «to haa contracted for the emergency contact informatten anowm abova betasen the namad engin and coatination ony. • CofA • SPCL REQMTS OK _Date PLACARDS#

Page 19PICK LIST Page 13/15 26.02.2015 81111071 42274981 30030624/19.02.2015 Scheduled Ship Date Chenetal S910 Fo1100 Technology Drive Inc. Consignee P.O. No. - Release No. Ship VIA TRANSPORT AMERICA 4 Order No. / Date JACKSON MI 49201 EMERGENCY CONTACT / 24 HOUR NUMBER: CHEMTREC - (800) 424-9300 Freigh REPRES CONTRACT# 16160 78681 OR FREIGHT COLLECT SHIPMENT: Connemetall Mexicana - Monterrey Send Freight Bill To: ithout recourse to the consignor, the consign this shipment is to be delivered to the consign Fraccionamiento Industrial Lincoln ecline to make delivery of this shipment witho all sign the following statement; The carrierm Nueva York 4037 ayment of freight and all other lawful charge CanNotes: 64310 MONTERREY x (Signature of Consignor) VIA LAREDO TEXAS, FOR CUSTOMS CLEARANCE AND BORDER CROSSING CONTACT: FILE) OF SAP BOL REQ'D WITH EVERY ORDER. ITC - PHONE 956-724-6950, FAX (956) 724 4237 *** 3 COPIES (FREIGHT, DRIVER, 90WGR0VP/14414 IMPORT ROAD, LAREDO, Ix 78045 VSA (IBTERNATIONAL TRADE CENTER) Pcs. Product Name Product Code Weight Los. Batch No. - Bin No. 2 CrysCoat 2147 (55Gal/208 Ltr Drum) 4 PROTECH 1999LC (55 Gal/208 Ltr Drum Batches: 880217151 = 2 3812002 1156 Batches: 880204151 = 4 76180002 1993 PKGS. Description of Articles, Special Marks and Exceptions LDĐ. See Page 1 ] TOTAL PACKAGES IF DAMAGE OR DELAYS OCCUR, CONTACT: TOTAL WEIGHT E> SHIPPERS CERTIFICATION: Thie la to carly that the above named materlate are property cleathed, doecribed, packaged, marked and labeled, and Ryan Cull. Thia consignment ta offered by Chemetail US, Inc. 675 Central Ave. Mew Providence, NJ 07374, USA - Telephone (306) 464-6900. are in proper condition for tranaportation according to the applicable regulatione of the Department of Trataportation. Chemetall US, Inc., Shipper per, who hae contracted for the emergency contact information shown above between the named origin and deetination only. • COfA • SPCL REQMTS OK. _Date PLACARDS#

Page 20PICK LIST 14/15 Page Scheduled Ship Date 26.02.2015 81111071 Shipper's No. 42274981 From: Chemetall US, Inc. Consignee P.O. No. - Release No. 30030624/19.02.2015 1100 Technology Drive Ship VIA TRANSPORT AMERICA 4 Order No. / Date JACKSON MI 49201 EMERGENCY CONTACT / 24 HOUR NUMBER: CHEMTREC - (800) 424-9300 CONTRACT# 16160 Consigned To: 78681 Fraccionamiento Industrial Lincoln Chemetall Mexicana - Monterrey Send Freight Bill To: FOR FREIGHT COLLECT SHIPMENTS: If this shipment is to be delivered to the consignee hall sign the following statement; The carrier ma vithout recourse to the consignor, the consignc Nueva York 4037 iscline to make delivery of this shipment withou ayment of freight and all other lawful charges 64310 MONTERREY (Signature of Consignor) VIA LAREDO TEXAS, FOR CUSTOMS CLEARANCE AND BORDER CROSSING CONTACT: HOWGROUP/ 14414 IMPORT ROAD, LAREDO, TX 78045 USA (INTERNATIONAL TRADE CENTER; FILE) OF SAP BOL REQ'D WITH EVERY ORDER. ITC - PHONE 956-724-6950, FAX (956) 724 4237 *** 3 COPIES (FREIGHT, DRIVER, Pcs. Product Name Product Code Weight LDe. Batch No. - Bin No. 2 CrysCoat 2707 (55Gal/208 Ltr Drum) 1 CrysCoat 2147 (275 gal/1040 Itr Bin batches: 880211151 = 2 11083002 1080 Batches: 880217151 = 1 3812010 2923 PKGS. He Kind of Pkg. Description of Articles, Special Marks and Exceptions Lba. See Page TOTAL PACKAGES IF DAMAGE OR DELAYS OCCUR, CONTACT: TOTAL WEIGHT SHIPPERS CERTIFICATION: This la to carly that the above named materiate are property claalled, described, packaged, marked and labeled, and Ryan Cull. Thia consignment to otered by Chemetal US, Inc. 675 Central Ave. How Providence, MJ 07974, USA - Telephone (908) 464 6.900, are in proper condition for traneportation according to the applicable regulatione of the Department of Transportation. Chemetal US, Inc., Shipper per, atto hao contracted for the emergency contact information shown above betron the named origin and deetnation only. • CofA • SPCL REQMTS OK _Date PLACARDS#

Page 21PICK LIST 15/15 Page 26.02.2015 81111071 42274981 30030624/19.02.2015 Scheduled Ship Date Chemetall US, Shipper's No. FoT100 Technology Drive Inc. Consignee P.O. No. - Release No. Ship VIA TRANSPORT AMERICA 4 Order No. / Date JACKSON MI 49201 Freight pers EMERGENCY CONTACT / 24 HOUR NUMBER: CHEMTREC - (000) 424-9300 CONTRACT# 16160 78681 FOR FREIGHT COLLECT SHIPMENTS: Chemetali Mexicana - Monterrey Send Freight Bill To: Nueva York 4037 Fraccionamiento Industrial Lincoln 64310 MONTERREY (Signature of Consignor) VIA LAREDO TEXAS, FOR CUSTOMS CLEARANCE AND BORDER CROSSING CONTACT: NDWGKDVP/14414 IMPORT ROAD, LAREDO, TX 78045 USA (INTERNATIONAL TRADE CENTER! FILE) DE SAP BOL REQ'D WITH EVERY ORDER. ITC - PHONE 956-724-6950, FAX (956) 724 4237 *** 3 COPIES (FREIGHT, DRIVER, Pcs. Product Name Product Code Weight Lbs. Batch No. - Bin No. 1 Batches: 880128151 = 1 Deoxidizer LNC (275 gal Bin) 3850010 3445 PKGS. Description of Articles, Special Marks and Exceptions Lba. See Pad TOTAL PACKAGES F DAMAGE OR DELAY OCCUR, CONTACT TOTAL WEIGHT → SHIPPERS CERTIFICATION: Thie la to carily that the above named materlata are properly claathed, deecribed, packaged, marked and lateled, and are in proper condition for tranaportation according to the appilcable regulatione of the Department of Transportation. Chemetall US, Inc., Shipper per, atio hee contracted for the emergenay contact information show above between the named origin and destination ontr Ryan Cull. Thie consignment to ofered by Chemetal US, Inc. 675 Central Ave, Now Providence, NJ 07974, USA - Telephone (906) 464-6900. CofA • SPCL REQMTS OK. Date PLACARDS#

Page 22U.S. Department of Transportation 1200 New Jersey Avenue SE Washington. DC 20590 Materials Safety Pipeline and Hazardous Administration DEC 1 1 2012 Mr. Raymond Kasey Railroad Regulatory Safety Services 7500 Masonville Drive Falls Church, VA 22042-3520 Ref. No.: 12-0181 Dear Mr. Kasey: This responds to your August 1, 2012 letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the proper classification of a marine pollutant, in addition to carrier verification requirements. In your letter, you state that your client, a class one and three railroad carrier, recently accepted a shipping paper for a bulk package identified as "p-Dodecylphenol" with no other description listed on the shipping paper. As an attachment, you provide a material safety data sheet (MSDS) for a product called "Lubrizol 9222R" which lists its hazardous ingredient as "p-Dodecylphenol, CAS No. 74499-35-7, Percentage (by wt.) from 1 to 4.9 percent." You further indicate that Dodecylphenol is listed in Appendix B to § 172.101 with a "PP" identifying the material as a severe marine pollutant. Your questions are paraphrased and answered below. Q1: You ask whether "Lubrizol 9222R," according to the attached MSDS, meets the definition of a (severe) marine pollutant? Additionally, you ask if a material is considered a listed marine pollutant if the technical name of the material does not synonym does? specifically appear in the table of marine pollutants (§ 172.101, Appendix B) but a A1: In accordance with § 173.22, it is the shipper's responsibility to properly classify and describe a hazardous material. This Office does not perform that function. Under the HMR, a material is considered a listed marine pollutant if either its technical name or a synonym appears in the table of marine pollutants. Furthermore, if the listed marine pollutant is in a mixture or solution, the shipper should consult the definition of a marine pollutant in § 171.8. In order to be considered a marine pollutant, the listed substance must be in a concentration of ten percent by weight, or if a severe marine pollutant, be in a concentration of one percent by weight.#

Page 23Therefore, if: (1) p-Dodecylphenol is a synonym to Dodecylphenol; and (2) the concentration of Dodecylphenol in the solution is at least one percent by weight, then the answer would be yes and "Lubrizol 9222R" would appear to be a marine pollutant. However, as stated above, it is the shipper's responsibility to properly classify and describe a hazardous material. Q2: You ask what is the required shipping name when a product shipped under a trade name is offered for transportation and contains the chemical p-Dodecylphenol in a bulk package at or above the concentration specified in Appendix B of the Hazardous Materials Table (HMT)? A2: Please note that marine pollutants listed in Appendix B are not necessarily listed by name in the § 172.101 HMT. If a marine pollutant not listed by name or by synonym in the § 172.101 HMT meets the definition of any hazard Class 1 through 8, you must determine the class and division of the material in accordance with § 173.2a of the HMR. Furthermore, you must also select the most appropriate hazardous material description and proper shipping name. If a marine pollutant not listed by name or by synonym in the § 172.101 HMT does not meet the definition of any Class 1 through 8, you must offer it for transportation under the most appropriate of the following two Class 9 entries: "Environmentally hazardous substances, liquid, n.o.s.," UN3082, or "Environmentally hazardous substances, solid, n.o.s." UN3077. In this specific case, it would appear that the former (along with a technical name) is the appropriate proper shipping name. Q3: You ask whether a carrier may rely on information provided by the manufacturer (or previous offeror) and in good faith rely on that information when transporting those hazardous materials? A3: The answer is yes. Although the HMR place primary responsibility on the shipper, or "person who offers," to properly class and communicate the hazard of a hazardous material, a carrier may be held responsible for non-compliance with applicable requirements to the extent that the carrier knows, or should have known, that a material offered for transportation is hazardous. A carrier may rely on information provided by the shipper, unless the carrier knows, or a reasonable person, acting in the circumstances and exercising reasonable care, would have knowledge that the information provided is incorrect. 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 24Raílroad Regulatory Safety Services 7500 Masonbille Dribe Falls Church, Virginia 22042-3520 Nickels Telephone 202-230-9563 $/71.1 or 703-560-0229 §172.101. §173.22 August 1, 2012 Applicablite Mr. Charles Betts, Director, Standards and Rulemaking Division 12-0181 Pipeline and Hazardous Materials Safety Administration 1200 New Jersey Avenue, S.E. Washington, D.C. 20590 Dear Mr. Betts: I represent a class one and three railroad and need clarification concerning the obligations of carriers when presented with a shipping paper listing a chemical that is not readily identifiable in the hazardous materials table. Recently, carriers accepted a shipping paper for a bulk package identified as p-dodecylphenol. There was no other description listed on the shipping paper offered or accompanying the shipment. Neither "p" nor plain dodecylphenol is listed in the Haz Mat Table in 49 CFR 172.101. I have several questions as follows. While it is incumbent on the shipper to know what the constituents are of the product being shipped, would the requirement of 49 CFR 172.101(c)(14) apply to an "m" (meta), "o" (ortho), or "p" (para), preceding the chemical name exclude it from being a marine pollutant (MP) or further include it as well if not listed in the Appendix B along with the MP chem cal? My second question is, "when an offeror provides a carrier with a shipping descr. ption that is not readily identifiable as a regulated hazardous material, what obligation, if any, does a carrier have other than transport the bulk package from origin to destination?" When I read further, however, I now find that according to Appendix B of the HMT, dodecylphenol is listed as a severe marine pollutant in certain concentrations, though I reiterate again that it is not listed in the HMT. My third question is, "In the absence of an additional description on the shipping paper, which list the concentration of p-dodecylphenol, can I, as a carrier reasonably assume that the bulk received from the offeror?" package does not contain a marine pollutant and transport it in accordance with the description I My fourth question is, "When a product shipped under a trade name is offered for transportation and contains the chemical p-dodecylphenol in a bulk package at or above the concentration#

Page 25specified in Appendix B of the Hazardous Materials Table, what is the required proper shipping name if any?" I have enclosed the MSDS for this product for your edification of the specific product to which I am referring. As you can see, the shipper offered an MSDS that indicates p-dodecylphenol as being between 1 to 4.9% by weight of the product. You will also note in your reading that block 14 lists the product as non-regulated in all countries. My fifth question concerns a carriers' good faith determination in assessing whether a product offered by a shipper can always be accepted in good faith, just as offered, or does acceptance of any material incur other obligations not listed in the HMR? Your assistance in this matter is appreciated. Sincerely, Caperley Raymond Kasey 3 enclosures#

Page 26LUBRIZOL® 9222R Lubrizol Material Safety Data Sheet LUBRIZOL® 9222R Prepared according to 29CFR 1910.1200. [Chemical Product and Company Identification 400 Lakeland Bouleva he Lubrizol Corporatic Wickliffe, Ohio 44092 Tel: (440) 943-4200 Product Trade Name CAS Number LUBRIZOL® 9222R Synonymıs Not applicable for mixtures. Product Type Generic Chemical Name Nonc. Mixture. Transportation Emergency Phone Preparation/Revision Date 25 May 2012 Multipurpose. FOR TRANSPORT EMERGENCY call CHEMTREC: (+1) 703-527-3887 (outside the U.S.) 1-800-424-9300 (in the MSDS No. U.S.) 31663020-3022415-4032271-102103 Hazards Identification Appearance Principal Hazards Odor Dark brown liquid. Mild Warning. • Causes respiratory tract initation. • May cause eye irritation. • Repeated swallowing of this material may cause adverse reproductive effects based on ani nal data. See Section 11 for complete health hazard information. 3 Composition/Information on Ingredients Hazardous Ingredients 15 Cong 74499-35-7 CAS NO. Percentage (hy wt.) From 1 to 4.9 percent Carcinogen p-Dodecylphenol N/E (N/E) - None established i4 First Aid Measures Eyes Rinse cautiousiy with water for several minutes. Remove contact lenses, if present and easy to do. Continue rinsing. If eye Inhalation Skin irritation persists, get medical attention. Wash with soap and water. Get medical attention if irritation develops. Launder contaminated clothing before reuse. Oral Remove victim to fresh air and keep at rest in a position comfortable for breathing. Call a poison center or doctor. Additional Information DO NOT INDUCE YOMITING. Get immediate medical attention. If exposed or concerned: Get medical attention. Fire Fighting Measures Flash Point Firefighting Procedures Extinguishing Media 164 °C, 327.2 °F PMCC (Typical) Co2, dry chemical, or foam. Water can be used to cool and protect exposed material. Unusual Fire & Explosion Hazards See section 10 for aciditional information. Recommend wearing self-contained breathing apparatus. Water may cause splattering. 6 /Aecidental Release Measures Spill Procedures Personal Protective Equipment must be worn, see Personal Protection Section for PPE recomme idations. Ventilate area it spilled in confined space or other poorly ventilated areas. Prevent entry into swers and waterwa's. Pick up free liquid for Page 1/5#

Page 27LUBRIZOL® 9222R recycle and/or disposal. Residual liquid can be absorbed on inert material. Handling and Storage Pumping Temperature Handling Procedures Maximum Handling Temperature 85 °C, 185 °F 75 °C, 167 °F Keep containers closed when not in use. Avoid breathing dust, fume, gas, mist, vapors or spray. Ise only outdoors or in a pot verse Way toughly te brings. Diapon ried doting bets nec ene onuine conting Storage Procedures Maximum Storage Temperature 45°C, 113°F regional, national and intemational regulations. Maximum Loading Temperature Not determined. Store locked up. See section 10 for incompatible materials. 18 Exposure Controls/Personal Protection Exposure Limits Other Exposure Limits Contains mineral oil. Under conditions which may generate mists, observe the OSHA PEL of 5 rig per cubic meter, ACGIH None established Engineering Controls TWA of 5 mg per cubic meter. Use local exhaust ventilation to control mists or vapors. Additional ventilation or exhaust may be required to maintain air Eye Protection Gloves Procedures Use nitrile or neoprene gloves. concentrations below recommended exposure limits. Respiratory Protection Use NIOSHIMSHA approved full face respirator with a combiuation organic vapor and high efficiency filter cartridge if the Safety Glasses. recommended exposure limit is exceeded. Use self-contained breathing apparatus for entry into confined space, for other poorly ventilated areas and for large spill clean-up sites. Consult with an industrial hygienist to der ermine the appropriate Clothing Recommendation Gloves, coveralls, apron, boots as necessary to minimize contact. Launder contaminated clothing before reuse. Plysical and Chemical Properties Flash Point Lower Flammable Limit Upper Flammable Limit Not determined. 164 °C, 327.2 °F PMCC (Typical) Explosion Data Autoignition Point Not determined. Not determined. pH Vapor Pressure Not determined. Material does not have explosive properties. Specific Gravity 1.13 (15.6 °C) Not determined. Bulk Density Percent Solid Water Solubility Insoluble. 9.42 Lb/gal, 1.13 Kg/L Percent Volatile Not determined. Vapor Density Volatile Organic Compound Not determined. Not determincd. Evaporation Rate Not determined. Appearance Odor Mild Not determined. Viscosity Dark brown liquid. 13553 Centipoise (25 °C) 22565.2 Centipoise (20 °C) 300 Centistokes (100 °C) 5000 Centistokes (40 °C) Boiling Point Odor Threshold Not determined. 50 Centipoise (169 °C) Melting / Freezing Point Pour Point Temperature Not determined. Not derermined. The above data are typical values and do not constitute a specification. Vapor pressure lata are calculate unless otherwise noted 10 Stability and Reactivity Decomposition Temperature Stability Material is normally stable at moderately elevated temperatures and pressures. Not determined. Page 2/5#

Page 28LUBRIZOL® 9222R Incompatibility Thermal Decomposition Polymerization Will not occur. Oxidizing agents. Smoke, carbon monoxide, carbon dioxide, aldchydes and other products of incomplete combustion. Under combustion Conditions to Avoid Not determined. conditions, oxides of the following elements will be fonned: calcium, sulfur. Toxicological Information Eye Irritation May cause eye irritation. Does not meet Canadian D2B or EU R36 criteria. Based on data from romponents or similar - ACUTE EXPOSURE - Skin Irritation Dermal Toxicity Respiratory Irritation cracking of the skin The LDSO in rabbits is > 2000 mg/Kg. Based on data from components or similar materials Vose, throat and lung imitan. Based on data from components or similar maierials Inhalation Toxicity Dermal Sensitization Oral Toxicity The LDSO in rats is > 10,000 mg/Kg. Bascá on data from components or similar materials. No data available to indicate product or components may be a toxic inhalation hazard. Inhalation Sensitization No data available to indicate product or components may be respiratory sensitizers. No data available to indicate product or components may be a skin sensitizer. Chronic Toxicity This product contains para-dodecylphenol. Rats given high, repeated daily doses of para-dodecy phenol by oral intubation - CHRONIC EXPOSURE - formation. The relevance of these effects to humans is uncertain. experienced effects on a number of organs including adrenal, thyroid, liver, ovary, testes, bone marrow and blood cell Carcinogenicity RC. All of the oils in this product have been demonstrated to contain less than 3% extractable; by the IP 3461 is product contains mincral oils which are considered to be severely refined and not considerer. to be carcinogenic un Mntagenicity Reproductive Toxicity No data available to indicate product or any components present at greater than 0.1% are mutag nic or genotoxic. experienced adverse reproductive effccts. The relevance of these effects to humans is uncertain This product contains para-dodecylphenol. Rats given high, repeated daily doses of para-dodecy phenol by oral intubatio Teratogenicity This product contains para-dodecylphenol. Pregnant rats given high, repeated daily doses of para-dodecylphenol by or uncertain. atubation gave birth to pups with cleft palate and skeletal malformations. The relevance of these ‹ ffects to humans: Other No other health hazards known. - ADDITIONAL INFORMATION - /12 Ecological Information Freshwater Invertebrates Toxicity Freshwater Fish Toxicity The acute LCS0 is > 1000 mg/L based on component data. - ENVIRONMENTAL TOXICITY - data. The acute EC50 is > 1000 mg/L based on component data. Chronic effects expected at < 1 mg/- based on component Saltwater Fish Toxicity Algal Inhibition Not determined. Not determined. Bacteria Toxicity Saltwater Invertebrates Toxicity Not determined. Miscellaneous Toxicity Not determined. The acute ECSO is 100 - 1000 ppm based on component data. Biodegradation At least 25% of the components in this product show limited biodegradation based on OECD 301-type test data. At leas - ENVIRONMENTAL FATE - Bioaccumulation 25% or greater of the components display no potential to bioconcentrate. 5% of the components in this product show moderate biodegradation based on OECD 302-tyf e test data Soil Mobility Not determined. 13 Disposal Considerations Waste Disposal This material, if discarded, is not a hazardous waste under RCRA Regulation 40 CFR 261. Trcalment, storage ransportation, and disposal must be in accordance with applicable Federal, State/Provincial, and Local regulations /14 (Transpor Information ICAO/ATA II ICAO/ATAI Not regulated. Not regulated. Page 3/5#

Page 29LUBRIZOL® 9222R IMDG IMDG EMS Spill IMDG EMS Fire Not applicable. Not regulated. IMD MEAG Not applicable. USCG Compatibility MARPOL. Annex Il Not applicable. Not determined. DOT NAERG U.S. DOT Bulk Not regulated. Not determined. U.S. DOT (Intermediate) Not applicable. U.S. DOT Non-Bulk U.S. DOT Intermediate NAERG Not applicable. Not regulated. Canada U.S. DOT Non-Bulk NAERG Not applicable. Not regulated. Bulk Quantity Mexico Not regulated. Not regulated. Intermediate Quantity 11000 KG, 24251 Ibs. 85000 KG, 187391 1bs. Non-Bulk Quantity 400 KG, 882 Ibs. Review classification requirements before shipping materials at elevated temperatures. /15 Regulatory Information USA All components of this material are on the US TSCA Inventory or are exempt. - Global Chemical Inventories - EU Other TSCA Reg. Nonc known. Japan All components are in compliance with the EC Seventh amendment Directive 92 /32/EEC. Australia All components are in compliance with chemical notification requirements in Australia. All components are in compliance with the Chemical Substances Control Law of Japan. Canada New Zealand All components are in compliance with the Canadian Environmental Protection Act and are present on the Domestic All components are in compliance with chemical notification roquirements in New Zcaland. Korea Switzerland Substances List, All components are in compliance in Korea. All components are in compliance with the Environmentally Hazardous Substances Ordinance in wizzcrland. Philippines 1990 (R.A. 6969). All components are in compliance with the Philippines Toxic Substances and Hazardous and Nu lear Wastes Control Act of Taiwan China All components of this product are listed on the Taiwan inventory. All components of this product are listed on the Inventory of Existing Chemical Substances in China. SARA Ext. Haz. Subst. This product does not contain greater than 1.0% of any chemical substance on the SARA Extren cly Hazardous Substances - Other U.S. Federal Regulations - SARA Section 313 listed under SARA Section 313. This product does not contain greater than 1.0% (greater than 0.1% for carcinogenic substance) of any chemical substances SARA 311 Classifications Chronic Hazard Acute Hazard Yes Reactivity Hazard Fire Hazard Yes No CERCLA Hazardous Substances No Nonc known. Cal. Prop. 65 This product contains the following chemicals) known to the state of California to cause cancer und/or birth defects based - State Regulations - 10. 91-20-3 < 0.5 ppm cadmium <0.5 ppm arsenic < 0.5 ppm lca on maximum impurity levels of components: < 0.01 ppm Ethyl benzene, CAS no. 100-41-4<0.01 ppm Naphthalene, CA: Finnish Registration Number U.S. Fuel Registration Not applicable. - Product Registrations - Swedish Registration Number Not Registcred Not Registered Danish Registration Number Norwegian Registration Number Not Registeredl Not Registered Italian Registration Number Swiss Registration Number Not Registered Not Registered - Other / International - Page 4/5#

Page 30LUBRIZOL® 9222R Miscellaneous Regulatory Information Not determined. 16 Other Information US NFPA Codes Health (N/E) - None established 2 Fire Special N/E HMIS Codes Health 2* Reactivity Precautionary Labels Warning. • Causes respiratory tract irritation. • May cause eye irritation. • Repeated swallowing of this material may cause adverse reproductive effects based on ani nal data. Revision Indicators Section: 12 Saltwater invertebrate toxicity. Section: 12 Accumulation. Changed: 25 May 2012 Changed: 25 Ma / 2012 As the conditions or methods of use are beyond our control, we do not ussume any responsibility and expressly disclaim any liability for any use of this product. Information hazards connected with the use of the material or the results to be obtained from the use thereof. Compliance with all applicable federal, state, and local regulations remains the contained herein is helieved to he true and accurate but all statements or suggestions are made without warranty, expressed or implied, regarding uccur icy of the information, the responsibility of the user. Page 5 / 5#

Page 31Material Safety Data Sheet Chemetall CrysCoat® 747 Version 1.9 Revision Date 07/22/2014 Print Date 04/23/2015 SECTION 1. PRODUCT AND COMPANY IDENTIFICATION MSDS Number Product name REL 3838 CrysCoat® 747 Company :Chemetall US, Inc. 675 Central Avenue Telephone +18005264473 New Providence, NJ 07974 Telefax Emergency telephone no CHEMTRE- 800-4249300 +19084644658 SECTION 2. HAZARDOUS COMPONENTS INFORMATION Component CAS-No. Weight percent Phosphoric acid 7664-38-2 5.00 - 10.00 Trade Secret Registry 735517-5097P 1.00 - 5.00 Diethylene Glycol Butyl Ether 112-34-5 1.00 - 5.00 Hydrofluoric Acid 7664-39-3 1.00 - 5.00 Trade Secret Registry 735517-5001P 1.00 - 5.00 Trade Secret Registry 735517-5011P 1.00 - 5.00 Standard (29CFR 1910.1200). Unidentified ingredients are considered not hazardous under Federal Hazard Communication SECTION 3. HAZARDS IDENTIFICATION Emergency Overview Colour Form Hazard Summary Odour : yellow Causes severe burn. Liquid or vapor causes burns which may be delayed. Harmful by inhalation and if swallowed. Route(s) of Entry Inhalation Skin Ingestion yes yes yes Carcinogenicity: NTP No substance in this product is listed by NTP as a carcinogen lARC No substance in this product is listed by IARC as a carcinogen OSHA No substance in this product is regulated by OSHA as a carcinogen N.D. - Not Determined 1/6 N.A. - Not Applicable#

Page 32Material Safety Data Sheet Chemetall CrysCoat® 747 Version 1.9 Revision Date 07/22/2014 Print Date 04/23/2015 SECTION 4. FIRST AID MEASURES Inhalation : If inhaled, remove to fresh air. If symptoms persist, call a physician. If breathing is irregular or stopped, administer artificial respiration. Skin contact : Wash off immediately with plenty of water for at least 15 minutes. Pay particular attention to skin under nails. Take off Contain cleate pase emerica ters rement immediately if irritation develops and persists Eye contact : Rinse immediately with plenty of water for at least 15 attention immediately minutes. Keep eye wide open while rinsing. Get medical Ingestion : Rinse mouth.Give several glasses of water to drink followed by milk of magnesia. Never give anything by mouth to an unconscious person. Get medical attention immediately SECTION 5. FIREFIGHTING MEASURES Flash point : Note: does not flash Lower explosion limit : Note: Not applicable. Upper explosion limit : Note: Not applicable. TDG Flammability Class : NONE Suitable extinguishing media : Dry chemical Foam Carbon dioxide (CO2) Water spray equipment for firefighters Special protective : In the event of fire, wear self-contained breathing apparatus. Further information : Use water spray to cool unopened containers. SECTION 6. ACCIDENTAL RELEASE MEASURES Personal precautions : Ensure adequate ventilation. Methods for cleaning up : Ventilate area. Neutralize with lime milk or soda and flush with plenty of water. N.D. - Not Determined 2/6 N.A. - Not Applicable#

Page 33Material Safety Data Sheet Chemetall CrysCoat® 747 Version 1.9 Revision Date 07/22/2014 Print Date 04/23/2015 Clean up with inert absorbant material. Keep in suitable, closed containers for disposal. Flush with plenty of water. Additional advice : Never return spills in original containers for re-use. SECTION 7. HANDLING AND STORAGE Handling Handling : Use only with adequate ventilation. Add this product to surface of solution slowly to avoid time. Do not add large amounts of product to solution at any one Storage areas and containers Requirements for storage : Keep containers dry and tightly closed to avoid moisture absorption and contamination. Store indoors in a cool, well-ventilated place SECTION 8. EXPOSURE CONTROLS/PERSONAL PROTECTION Component ACGIH OSHA (TWA) TLV (TWA) PEL Phosphoric acid 1.000000 mg/m3 1.000000 mg/m3 Trade Secret Registry NONE NONE Diethylene Glycol Butyl Ether NONE NONE Hydrofluoric Acid 3 ppm 3 ppm Trade Secret Registry NONE ceiling NONE Trade Secret Registry soluble compounds as Mo | soluble compounds as Mo 5.000000 mg/m3 5.000000 mg/m3 Eye protection : Chemical resistant goggles must be worn. Face-shield Hand protection : Impervious gloves Skin and body protection : Complete suit protecting against chemicals Respiratory protection : If the occupational exposure limits cannot be met, suitable respirator equipment shall be worn. Hygiene measures : Avoid contact with skin, eyes and clothing. N.D. - Not Determined 3/6 N.A. - Not Applicable#

Page 34Material Safety Data Sheet Chemetall CrysCoat® 7477 Version 1.9 Revision Date 07/22/2014 Print Date 04/23/2015 Wear suitable protective clothing. Wear suitable gloves and eye/face protection. Wash hands before breaks and immediately after handling the Provide adequate ventilation. Do not inhale fumes. Keep away from food and drink SECTION 9. PHYSICAL AND CHEMICAL PROPERTIES pH : 2.5 - 3.5 Freezing point : -1.11 °C (30.00 °F) Boiling point/boiling range : Note: no data available Vapour pressure : Note: no data available Bulk density : 9.5500 Ib/gal Water solubility : Note: completely soluble Relative density : 1.146 Evaporation rate : 1 Note: (Water =1) Less than 1 SECTION 10. STABILITY AND REACTIVITY Conditions to avoid :Direct sources of heat. Materials to avoid :Bases release dangerous gases (chlorine). Warning! Do not use together with other products. May Avoid prolonged contact of concentrate with glass, ceramic, or concrete. products Hazardous decomposition : Carbon dioxide (CO2) Nitrogen oxides (NOX) Carbon monoxide Hydrogen, by reaction with metals Traces of Fluorides Oxides of phosphorus SECTION 11. TOXICOLOGICAL INFORMATION N.D. - Not Determined 4/6 N.A. - Not Applicable#

Page 35Material Safety Data Sheet Chemetall CrysCoat® 7477 Version 1.9 Revision Date 07/22/2014 Print Date 04/23/2015 Toxicity: : Mixture; Not Determined Phosphoric acid Acute oral toxicity : LD50, rat Dose: 1,530.000000 mg/kg Ether Diethylene Glycol Butyl : LD50, rat Dose: 6,560.000000 mg/kg Hydrofluoric Acid Acute toxicity (other routes of administration) : LD50, rat, Intraperitoneal Dose: 25.000000 mg/kg SECTION 12. ECOLOGICAL INFORMATION No data available SECTION 13. DISPOSAL CONSIDERATIONS Advice on Disposal : Refer to all federal, provincial, state and local regulation prior to or disposal. disposition of container and unused contents by reuse, recycle SECTION 14. TRANSPORT INFORMATION Refer to Bill of Lading. SECTION 15. REGULATORY INFORMATION TSCA Status : All components of this material comply with US TSCA requirements. SARA 313 Components : Diethylene Glycol Butyl CAS-No. 112-34-5 :Hydrofluoric Acid Ether CAS-No. 7664-39-3 CERCLA Reportable Quantity Phosphoric acid Hydrofluoric Acid 5,000 Pounds 100 Pounds California Prop. 65 :N.D NFPA : 300 Corrosive Acid HMIS : 300H N.D. - Not Determined 5/6 N.A. - Not Applicable#

Page 36Material Safety Data Sheet Chemetall CrysCoat® 747 Revision Date 07/22/2014 Version 1.9 Print Date 04/23/2015 SECTION 16. OTHER INFORMATION Further information Chemetall US, Inc. warrants that the products described herein will conform with its published specifications. MERCHANTABILITY AND FITNESS FOR ANY PARTICULAR PURPOSE IN CONNECTION WITH THE USE OF ITS N.D. - Not Determined 6/6 N.A. - Not Applicable#