Hazmateam, Inc — Hazardous Materials Safety Interpretation

Page 1U.S. Department 1200 New Jersey Avenue SE of Transportation Washington. DC 20590 Materials Safety Pipeline and Hazardous Administration SEP 3. 0 2015 Paul Dambek Hazmateam, Inc. 12 Kimball Hill Road Hudson, NH 03051-3915 Ref. No.: 15-0122 Dear Mr. Dambek: This is a response to your June 15, 2015 letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the classification of an aerosol that may meet the definition of a poisonous material (Division 6.1) as a subsidiary hazard. In your letter, you state that you have an aerosol mixture that consists of six individual components of varying percentages (toluene 20-35%, silver 15-25%, dichloromethane 15-25%, propane 10-20%, isobutane 10-15%, and asbestos free talc 1-3%) and varying LCso and LD50 values. According to the information in your letter and the safety data sheet (SDS) you provided, you have identified your material as CHO-SHIELD® 4900, manufactured by Parker Hannifin Corporation with an SDS number of PHC-205 and product codes of: 52-01-4900- 0000; 52-02-4900-0000; 52-02-4900-0000E; 52-03-4900-0000. Further, the SDS indicates that the material has been classified as "UN1950, Aerosols, 2.1 (6.1)" when offered for in Division 6.1, Packing Group III, 2.1 (6.1)" when offered for transportation under the transportation under the HMR, and "UN1950, Aerosols, flammable, containing substances International Civil Aviation Organization's Technical Instructions for the Safe Transport of Dangerous Goods by Air (ICAO TI). You question the accuracy of the aerosol mixture CHO-SHIELD® 4900 being classified as having a subsidiary hazard of poisonous material (Division 6.1), and therefore, disagree with the manufacturer's classification of this material. Your questions are paraphrased and answered as follows: Q1. Based on the LCso and LDso values of the six individual components listed in the SDS, does the aerosol mixture CHO-SHIELD® 4900 meet the definition of a poisonous material (Division 6.1) as a subsidiary hazard based on 49 CFR § 173.132(a)(1)? Al. In accordance with § 173.22, it is the shipper's responsibility to ensure that the material is properly classed and described in accordance with the HMR. We cannot make this determination based on the information you provided. Please work with Parker Hannifin Corporation to review its determination of what the LCso and LD50 values are for the final aerosol mixture CHO-SHIELD® 4900. 1#

Page 2A poisonous material (Division 6.1), as defined in § 173.132 means (emphasis added) a material, other than a gas, which is known to be so toxic to humans as to afford a hazard to health during transportation, or which, in the absence of adequate data on human toxicity: (1) Is presumed to be toxic to humans because it falls within any one of the following categories when tested on laboratory animals (whenever possible, animal test data that has been reported in the chemical literature should be used): (i) Oral Toxicity. A liquid or solid with an LDso for acute oral toxicity of not more than 300 mg/kg. (ii) Dermal Toxicity. A material with an LDso for acute dermal toxicity of not more than 1000 mg/kg. (ili) Inhalation Toxicity. (A) A dust or mist with an LCso for acute toxicity on inhalation of not more than 4 mg/L; or (B) A material with a saturated vapor concentration in air at 20 °C (68 °F) greater than or equal to one-fifth of the LCso for inhalation of vapors of not more than 5000 mL/m?. acute toxicity on inhalation of vapors and with an LCso for acute toxicity on If the final aerosol mixture meets either of these criteria, it meets the definition of a Division 6.1 material. Q2. The criteria described in 49 CFR § 173.132(a)(2) is somewhat subjective: "... is an irritating material, with properties similar to tear gas, which causes extreme irritation, especially in confined spaces." Given that the aerosol only contains 25% (maximum) of dichloromethane in small (6 fluid ounce) cans, and there is no (+) sign listed in column (1) of the § 172.101 Hazardous Materials Table (HMT) for dichloromethane, does CHO-SHIELD® 4900 meet the definition of a poisonous material (Division 6.1) as a subsidiary hazard based on 49 CFR § 173.132(a)(2)? A2. This Office cannot determine the answer to this question. Please see Al. Q3. Do you agree that the shipping description for CHO-SHIELD® 4900 should be "UN1950, Aerosols, 2.1" for all modes of transportation under both the HMR and the ICAO TI? A3. This Office cannot determine the answer to this question. Please see A1. I hope this information is helpful. If you have any more questions, please do not hesitate to contact this office. Sincerely, T. Glenn Foster Chief, Regulatory Review and Reinvention Branch Standards and Rulemaking Division 2#

Page 3Nickels $173.132 Definitions 15 - 0122 HAZMATEAM 12 Kimball Hill Road Hudson, NH 03051-3915 Telephone: (603) 882-1112 Fax: (603) 882-6512 Web site: www.hazmateam.com June 15, 2015 Mr. Charles Betts Office of Hazardous Materials Standards Attn: PHH-10 Pipeline and Hazardous Materials Safety Administration U.S. Department of Transportation 1200 New Jersey Avenue, SE. East Building, 2nd Floor Washington, DC 20590-0001 Dear Mr. Betts: I am requesting a letter of interpretation on classification of an aerosol that contains Dichloromethane. This aerosol is currently conservatively classified as having a Division 6.1 subsidiary hazard and we are reconsidering this classification. Before my specific questions, please consider the following aerosol formula (and corresponding acute toxicity data): Chemical % INH RAT, LC50, 4HR ORAL RAT, LD50 Toluene 7585 ppm DERMAL RABBIT, LD50 20-35 (28.1 mg/L) (vapor) 5580 mg/kg 12125 mg/kg Silver 15-25 N/AV > 2000 mg/kg > 2000 mg/kg Dichloromethane 15-25 22170 ppm 1400 mg/kg (77.01 mg/L)(vapor) > 2000 mg/kg Propane 10-20 N/AV N/Ap (gas) N/Ap (gas) Isobutane 10-15 368000 ppm (mouse) N/Ap (gas) N/Ap (gas) Talc 1-3 N/AV (asbestos free) N/AV N/AV N/Av = not available; N/Ap = not applicable; Ref: Cho-Shield 4900 SDS, attached#

Page 4Next, consider the Division 6.1 classification criteria: §173.132 Class 6, Division 6.1—Definitions. gas, which is known to be so toxic to humans as to afford a hazard to health during transportation, or which, (a) For the purpose of this subchapter, poisonous material (Division 6.1) means a material, other than a in the absence of adequate data on human toxicity: tested on laboratory animals (whenever possible, animal test data that has been reported in the chemical (1) Is presumed to be toxic to humans because it falls within any one of the following categories when (i) Oral Toxicity. A liquid or solid with an LDe for acute oral toxicity of not more than 300 mg/kg. (ii) Dermal Toxicity. A material with an LDso for acute dermal toxicity of not more than 1000 mg/kg. mg/L; or (iii) Inhalation Toxicity. (A) A dust or mist with an LGs for acute toxicity on inhalation of not more than 4 ifth of the LCsfor acute toxicity on inhalation of vapors and with an LCso for acute toxicity on inhalation o (B) A material with a saturated vapor concentration in air at 20 °C (68 °F) greater than or equal to one- rapors of not more than 5000 mL/m*; o especially in confined spaces. (2) Is an irritating material, with properties similar to tear gas, which causes extreme irritation, Question 1. Each component of the formula has a LC50 or LD50 above the respective regulatory threshold described in 49 CFR 173.132 (a). Do you agree that based on the lowest LD50 and LC50 for any of the components above, the material would not be classified as Division 6.1? • Each component's oral and dermal LD50 values are well above 300 mg/kg & 1000 mg/kg, respectively. • The vapor LC50 for toluene, dichloromethane and isobutane are all well above 5000 ml/M3, the criteria for 173.132 (a)(1)(B).#

Page 5Question 2. The criteria described in 49 CFR 173.132 (a)(2) is somewhat subjective: "... is an irritating material, with properties similar to tear gas, which causes extreme irritation....". Dichloromethane, the only component in the formulation classified as a Division 6.1 material is diluted to a maximum of 25% in the formula. Each aerosol can is 6 fluid ounces. We believe the diluted Dichloromethane in such a small receptacle would not cause extreme irritation. Given that this formula only contains 25% (max) of dichloromethane in small (6 fluid ounce) cans, and there is no (t) sign listed in column (1) of the 172.101 table for Dichloromethane, do you agree that this formula would not be classified as a Division 6.1 material based on 49 CFR 173.132 (a)(2)? Question 3. If you agree with our conclusions described in Questions 1 and 2, do you agree the shipping description for this aerosol formula should be: UN 1950, Aerosols, 2.1 for all modes of transportation. Rather than: UN 1950, Aerosols, 2.1 (6.1) - 49 CFR UN 1950, Aerosols, Flammable, Containing Substances in Division 6.1, Packing Group III, 2.1(6.1) - IATA The Safety Data Sheet for this material is attached. If you have questions, do not hesitate to send e-mail to paul@hazmateam.com or call 401-595-8395. Your assistance is greatly appreciated. Sincerely, Fanly Smal Paul Dambek, CDGP Hazardous Materials Trainer and Consultant#

Page 6SAFETY DATA SHEET -Parker Chamerics 1. Identification Product identifier CHO-SHIELD® 4900 Other means of identification SDS number Recommended use Product code PHC-205 52-01-4900-0000; 52-02-4900-0000; 52-02-4900-0000E; 52-03-4900-0000 Recommended restrictions Conductive, silver-filled acrylic coating. Chemical family No restrictions on use known. Manufacturer Mixture. Company name Address Parker Hannifin Corp. 77 Dragon Court Chomerics Division Woburn, MA, USA Telephone 01888 Website (781) 935 4580 E-Mail www.chomerics.com Supplier information chomailbox@parker.com Refer to Manufacturer Emergency phone number INFOTRAC - (800) 535-5053 (Within Continental US): (352) 323-3500 (Outside US) 2. Hazard(s) Identification This material is classified as hazardous under OSHA regulations (29CFR 1910.1200) (Hazcom 2012). Physical hazards Flammable aerosol - Category • Health hazards Gases under pressure See damagenion Get 22 Reproductive toxicity - Category 2 Carcinogenicity - Category 2 Stretic target organ toxicity - single exposure - Category a (Respiratory iritation; Narcotic Environmental hazards Specific target organ toxicity - repeated exposure - Category 2 OSHA defined hazards Not currently regulated by OSHA, refer to Section 12 for additional information. This mixture does not meet the classification criteria according to OSHA Hazcom 2012. Label elements Signal Word Hazard statements) DANGER! Extremely flammable aerosol. Causes skin irritation. Contains gas under pressure; may explode if heated. Causes serious eye irritation. Suspected of damaging the unborn child. Suspected of causing cancer. May cause respiratory irritation. May cause drowsiness and dizziness May cause damage to organs through prolonged or repeated exposure Material name: CHO-SHIELD® 4900 SDS US SDS No. PHC-205 Version#: 1 Issue date: 04-21-2015 Page 11077413#

Page 7SAFETY DATA SHEET Parker Chomerics Precautionary statements) Prevention read and understood. Keep away from heat, sparks and open flame. - No smoking. Do not Obtain special instructions before use. Do not handle until all safety precautions have been Response IF exposed or concerned: Get medical attention/advice. IF ON SKIN: Wash with plenty of soap and water. If skin irritation occurs, get medical IF INHALED: Remove person to fresh air and keep comfortable for breathing. Call a advice/attention. Take off contaminated clothing and wash before re-use. POISON CENTER or doctor/physician if you feel unwell. present and easy to do. Continue rinsing. If eye irritation persists, get medical IF IN EYES: Rinse cautiously with water for several minutes. Remove contact lenses, if advice/attention. Storage Store in a well-ventilated place. Keep container tightly closed. Disposal Protect from sunlight. Do not expose to temperatures. exceeding 50°C/122°F. Dispose of contents/container in accordance with local regulation. Classified (HNOC) Hazard(s) not otherwise No OSHA defined hazard classes Other hazards which do not result in classification: Toxic fumes, gases or vapors may evolve on burning. Inhalation of fumes may result in Supplemental Information contact with skin, and argyrosis in case of inhalation. Avoid contact with eyes, skin and clothing. Keep away from incompatibles. 3. Composition/information on ingredients Mixture Chemical name Toluene Methylbenzene Common name and synonyms CAS number 108-88-3 Concentration (%) Silver Phenylmethane 20.0-35.0 Silver metal Methylene chloride Argentum 7440-22-4 15.0-25.0 Dichloromethane DCM 75-09-2 15.0-25.0 Propane Dimethylmethane buta Propyl hydride 74-98-6 10.0 - 20.0 -Methylpropane rimethylmethan 75-28-5 10.0-15.0 Talc (containing no asbestos fibers Hydrous magnesium silicate Soapstone 14807-96-6 1.0 - 3.0 The exact concentrations of the above listed chemicals are being withheld as a trade secret. Talcum 4. First-aid measures Inhalation IF INHALED: Remove person to fresh air and keep comfortable for breathing. If breathing is espiration. Call a POISON CENTER or doctor/physician if you feel unwel lifficult, give oxygen by qualified medical personnel only. If breathing stopped, begin artifici Skin contact IF ON SKIN: Wash with plenty of soap and water. If skin irritation occurs, get medica Eye contact IF IN EYES: Rinse cautiously with water for several minutes. Remove contact lenses, i advice/attention. Take off contaminated clothing and wash it before reuse. resent and easy to do. Continue rinsing. If eye irritation persists, get medica Ingestion Do NOT induce vomiting. Never give anything by mouth to an unconscious person. Get advice/attention. medical attention. SDS No. PHC-205 Version#: 1 Issue date: 04-21-2015 Material name: CHO-SHIELD® 4900 SDS US Page 120f2413#

Page 8SAFETY DATA SHEET Parker homeriss effects, both acute and delayed Most important symptoms and Causes serious eye irritation. Symptoms may include redness, pain, tearing and Causes skin irritation. Contact may cause redness, swelling and a painful sensation. conjunctivitis. Suspected of causing cancer. Symptoms may include persistent coughing, shortness of breath, coughing up blood and wheezing. weight, behavioral effects, delayed skeletal formation and hearing loss. Suspected of damaging the unborn child. Symptoms in offspring may include reduced fetal May cause respiratory irritation. Symptoms may include upper respiratory irritation, coughing May. cause drowsiness or dizziness. Symptoms may include pain, headache, nausea, and breathing difficulties. vomiting, dizziness, drowsiness and other central nervous system effects. May cause damage to the liver, nervous system or lungs through prolonged or repeated exposure. Symptoms may include memory loss, sleep disturbances, incoordination or loss Ingestion may cause gastrointestinal irritation, nausea, vomiting and diarrhea. of ability to concentrate. Additional symptoms may include liver damage and emphysema Inhalation of fumes may result in metal fume fever, a flu-like illness. Symptoms of metal fume fever may include fever, fatigue, vomiting, muscle aches and shortness of breath. Silver in the form of a finely divided dust may cause discoloration in contact with skin, and rolonged overexposure may cause slight kidney effects, such as increased organ weigh irgyrosis in case of inhalatior Indication of any immediate treatment needed medical attention and special Provide general supportive measures and treat symptomatically. General Information protect themselves. Show this safety data sheet to the doctor in attendance. Ensure that medical personnel are aware of the material(s) involved, and take precautions to 5. Fire-fighting measures Suitable extinguishing media Carbon dioxide (CO2); Dry chemical; Alcohol-resistant foam; water fog . media Unsuitable extinguishing Do not use a solid water stream as it may scatter and spread fire. the chemical Specific hazards arising from re-ignited at the water's surface. This product is contained under pressure, and coul Vapours are heavier than air and may spread along floors. Product may float, and be special protective equipment and Firefighters must use standard protective equipment including flame retardant coat, helme wear proper protective equipment and self-contained breathing apparatus with full face vith face shield, gloves, rubber boots, and in enclosed spaces, SCA. Firefighters should piece operated in positive pressure mode. Fire-fighting equipment/instructions Specific methods Use standard firefighting procedures and consider the hazards of other involved materials. General fire hazards Hazardous combustion products Flammable aerosol. This material may be ignited by heat, sparks and direct flame. Aldehydes; Metal oxides; Other unidentified organic compounds Carbon oxides; Chlorine; Phosgene; Hydrogen chloride gas; Reactive hydrocarbons; 6. Accidental release measures Personal precautions, emergency procedures protective equipment and Keep people away from and upwind of spill/leak. Restrict access to area until completion of sections 7 and 8. clean-up. Wear appropriate protective equipment. Refer to protective measures listed ir Material name: CHO-SHIELD® 4900 SDS US SDS No. PHC-205 Version #: 1 Issue date: 04-21-2015 Page 130f3413#

Page 9SAFETY DATA SHEET Parker Chomerics Methods and materials for containment and cleaning up Environmental precautions 7. Handling and storage Precautions for safe handling Obtain special instructions before use. Do not handle until all safety precautions have been read and understood. handling. Wear protective gloves/clothing and eye/face protection. Do not breathe vapour Use only outdoors or in a well-ventilated area. Wear suitable protective equipment during including any incompatibilities Conditions for safe storage, Store in cool/well- ventilated place. Store locked up. Storage area should be clearly 8. Exposure controls/personal protection Occupational exposure limits • U.S. OSHA Exposure Limits (29 CFR 1910) Toluene Type (CAS 108-88-3) TWA Value 200 ppm (CAS 7440-22-4) Silver TWA 0.01 mg/ma (CAS 75-09-2) Methylene chloride STEL 125 ppm TWA 25 ppm (CAS 74-98-6) TWA 1000 ppm (1800 mg/m*) Talc (containing no asbestos fibers) (CAS 14807-96-6) TWA 20 mppcf US. ACGIH Threshold Limit Values Type Value Toluene (CAS 108-88-3) TWA 20 ppm (CAS 7440-22-4) Silver TWA 0.1 mg/m° (dust and fume) (CAS 75-09-2) Methylene chioride TWA 50 ppm (CAS 75-28-5) Isobutane TWA 1000 ppm (as 'Butane, all isomers") (CAS 14807-96-6) Talc (containing no asbestos fibers) TWA 2 mg/m° (respirable) Material name: CHO-SHIELD® 4900 SDS US SDS No. PHC-205 Version#: 1 Issue date: 04-21-2015 Page 140f 7913#

Page 10SAFETY DATA SHEET -Parker Chomeriss US. NIOSH: Pocket Guide to Chemical Hazards Type Value (CAS 108-88-3) Toluene STEL 150 ppm (560 mg/m°) TWA 100 ppm (375 mg/m*) (CAS 7440-22-4) Silver TWA 0.01 mg/m° (dust) (CAS 74-98-6) Propane TWA 1000 ppm (1800 mg/m*) Isobutane (CAS 75-28-5) TWA 800 ppm (1900 mg/m*) (CAS 14807-96-6) Talc (containing no asbestos fibers) TWA 2 mg/m* (respirable dust) Biological limit values Toluene (CAS 108-88-3) 0.02 mg/L; Medium: Blood; Parameter: Toluene 0.3 mg/g Creatinine; Medium: Urine; Parameter: o-Cresol with hydrolysis .03 mg/L; Medium: Urine; Parameter: Toluen Methylene chloride (CAS 75-09-2) 0.3 mg/L; Medium: Urine; Parameter: Dichloromethane (semi-quantitative) controls Appropriate engineering Use only outdoors or in a well-ventilated area. Apply technical measures to comply with the use of local exhaust ventilation and good general extraction. In case of insufficient occupational exposure limits. Where reasonably practicable this should be achieved by the Individual protection measures, such as personal protective equipment ventilation wear suitable respiratory equipment. Eye/ face protection Wear eye/face protection. Wear as appropriate: Tightly fitting safety goggles; Safety glasses Skin protection with side-shields. A full face shield may also be necessary. Hand protection Wear protective gloves/clothing. The suitability for a specific workplace should be discussed Other with the producers of the protective gloves. Ether equipment may be required defer sign wore place so the workstation location. Respiratory protection airbourne concentrations are above the permissible exposure limit or are not known, us concentration of contaminants in air, and in accordance with OSHA (29 CFR 1910.134) or IOSH-approved respirators. Respirators should be selected based on the form an CSA Z94.4-02. Advice should be sought from respiratory protection specialists. General hygiene Thermal hazards Wear appropriate thermal protective clothing, when necessary. considerations Do not breathe vapors or spray mist. Avoid contact with skin, eyes and clothing. Do not eat contaminated clothing before re-use. Handle in accordance with good industrial hygiene and drink or smoke when using this product. Wash thoroughly after handling. Remove and wash safety practice. 9. Physical and chemical properties Appearance Physical state Form Liquid aerosol. Color Silver liquid contained in pressurized aerosol can. Odor Solvent odor. silver Odor threshold N/AV pH Melting point /freezing point N/Av N/Av Initial boiling point and boiling range Flash point N/AV closed cup 4°C (39°F) (concentrate) (based on ingredients) Evaporation rate N/AV Material name: CHO-SHIELD® 4900 SDS US SDS No. PHC-205 Version#: 1 Issue date: 04-21-2015 Page 150f3413#

Page 11SAFETY DATA SHEET Parker Chomerics Flammability (solid, gas) Not applicable. Lower flammability/explosive limitN/Av Upper flammability/explosive limit N/Av Vapor pressure Relative density Vapor density N/AV > 1 (Air = 1) Solubility(ies) > 1 Other solubility(ies) N/AV Solubility (water) (n-octanol/water) Partition coefficient Insoluble. N/AV Auto-ignition temperature Decomposition temperature N/AV Other information Viscosity N/AV N/AV Explosive properties Aerosols are sensitive to mechanical impact. Closed containers are contained under Specific gravity Oxidizing properties None known. pressure and may explode if exposed to excess heat for a prolonged period of time. Critical temperature > 1 VOC N/AV Volatilities% N/AV Flame projection length 73% (approximately) N/AV Flashback observed container Absolute pressure of N/AV N/AV data Other physical/chemical Chemical heat of combustion: N/Av 10. Stability and reactivity Reactivity ot normally reactiv Chemical stability reactions Possibility of hazardous Stable under normal conditions. Hazardous polymerization does not occur. Conditions to avoid incompatible materials. Protect from sunlight and do not expose to temperatures exceedin Direct sources of heat. Do not use in areas without adequate ventilation. Avoid contact witt Incompatible materials 50 °C/122 °F. Strong oxidizing agents; Strong acids; Strong bases; Reducing agents; Alkali metals. Hazardous decomposition products None known, refer to hazardous combustion products in Section 5. 11. Toxicological information Information on likely routes of exposure Routes of entry inhalation May cause irritation of the nose, throat, mucous membranes, and respiratory tract. Routes of entry skin & eye Causes skin irritation. Causes serious eye irritation. Routes of entry Ingestion May cause gastrointestinal irritation. Material name: CHO-SHIELD® 4900 SDS US SDS No. PHC-205 Version #: 1 Issue date: 04-21-2015 Page 160f 3413#

Page 12SAFETY DATA SHEET Parker homerics absorption Routes of exposure skin May be absorbed through the skin. Most important delayed symptoms/effects, acute and May cause respiratory irritation. May cause coughing and breathing difficulties. Symptoms nervous system effects. may include pain, headache, nausea, vomiting, dizziness, drowsiness and other central auses serious eye irritation. Symptoms may include redness, pain, tearing ar uses skin irritation. Contact may cause redness, swelling and a painful sensatic Suspected of causing cancer. Symptoms may include persistent coughing, shortness of conjunctivitis breath, coughing up blood and wheezing. weight, behavioral effects, delayed skeletal formation and hearing loss. Suspected of damaging the unborn child. Symptoms in offspring may include reduced fetal coughing and breathing difficulties. May cause respiratory irritation. Symptoms may include upper respiratory irritation, May cause drowsiness or dizziness. Symptoms may include pain, headache, nausea, May cause damage to the liver, nervous system or lungs through prolonged or repeated vomiting, dizziness, drowsiness and other central nervous system effects of ability to concentrate. Additional symptoms may include liver damage and emphysema. exposure. Symptoms may include memory loss, sleep disturbances, incoordination or loss Inhalation of fumes may result in metal fume fever, a flu-like illness. Symptoms of metal Ingestion may cause gastrointestinal irritation, nausea, vomiting and diarrhea. Silver in the form of a finely divided dust may cause discoloration in contact with skin, and fume fever may include fever, fatigue, vomiting, muscle aches and shortness of breath. argyrosis in case of inhalation. Prolonged overexposure may cause slight kidney effects, such as increased organ weight. Information on toxicological effects Acute toxicity Not expected to be hazardous by OSHA criteria. The calculated ATE values for this mixture are: ATE oral = 7000 mg/kg See below for toxicological data on the substance. LC50(4hr) LD50 Chemical name inh, rat (Oral, rat) (Rabbit, dermal) Toluene 7585 ppm (28.1 mg/L) (vapor) 5580 mg/kg Silver > 2000 mg/kg 12 125 mg/kg Methylene chloride 22 170 ppm (77.01 mg/L) (vapor) 1400 mg/kg > 2000 mg/kg > 2000 mg/kg Propane NAV NiAp (gas) NAp (gas) Isobutane 368 000 pm (mouse) NIAp (gas) fibers) Talc (containing no asbestos N/AV N/Ap (gas) N/AV Skin Corrosion/Irritation Hazardous by OSHA criteria. Classification: Serious eye damage/Irritation Skin corrosion/irritation - Category 2. Causes skin irritation. Hazardous by OSHA criteria. Classification: sensitization Respiratory or skin Eye damage/irritation - Category 2A. Causes serious eye irritation. Vo data available to indicate product or components may be respiratory sensitizers Vo data available to indicate product or components may be skin sensitizers Germ cell mutagenicity No data available to indicate product or any components present at greater than 0.1% are mutagenic or genotoxic. Material name: CHO-SHIELD® 4900 SDS US SDS No. PHC-205 Version #: 1 Issue date: 04-21-2015 Page 17 0f2413#

Page 13SAFETY DATA SHEET Parker Chomerics Carcinogenicity This material is classified as hazardous under OSHA regulations (29CFR 1910.1200) (Hazcom 2012). Classification: o other components are classified as carcinogenic by IARC, ACGIH, OSHA or NT arcinogenicity - Category 2. Suspected of causing cancer. Contains: Methylene chlorid See below for ingredients present on regulatory lists. IARC Monographs. Overall Evaluation of Carcinogenicity Toluene(CAS 108-88-3) Group 3 (Not Classifiable) Methylene chloride(CAS 75-09-2) Group 2A (Probably Carcinogenic to Humans) Talc (containing no asbestos fibers)(CAS 14807-96-6) Group 3 (Not Classifiable) OSHA Specifically Regulated Substances (29 CFR 1910.1001-1050) Methylene chloride(CAS 75-09-2) Present US National Toxicology Program(NTP) Report on Carcinogens Methylene chloride(CAS 75-09-2) Group 2 Reproductive toxicity This material is classified as hazardous under U.S. OSHA regulations (29CFR 1910.1200) Hazcom 2012) and Canadian WHMIS regulations (Hazardous Products Regulations Reproductive toxicant - Category 2. Suspected of damaging the unborn child. Contains Toluene. Toluene may cause fetotoxic effects at doses which are not maternally Specific target organ toxicity - single exposure Hazardous by OSHA criteria. Classification: Specific target organ toxicity - single exposure; Category 3. May cause respiratory irritation. repeated exposure Specific target organ toxicity - May cause drowsiness or dizziness. Hazardous by OSHA Criteria. Classification: Specific target organ toxicity - repeated exposure; Category 2. May cause damage to the Methylene chloride; Talc (Mg3H2(SiO3)4). iver, nervous system or lungs through prolonged or repeated exposure. Contains: Toluene Chronic effects Prolonged overexposure may cause slight kidney effects, such as increased organ weight. Aspiration toxicity Not expected to be hazardous by OSHA criteria. Further information Silver in the form of a finely divided dust may cause discoloration in contact with skin, and argyrosis in case of inhalation. 12. Ecological information Ecotoxicity No data is available on the product itself. Should not be released into the environment. Contains: Silver. The acute toxicity of silver to aquatic species varies drastically by the variable not only by organism but with physical and chemical characteristics of the water chemical form and correlates with the availability of free ionic silver. Aquatic toxicity is highly See the following tables for individual ingredient ecotoxicity data. Ecotoxicity data: Ingredients CAS No Toxicity to Fish LC50 / 96h NOEC / 21 day M Factor Toluene 108-88-3 5.4 mg/L (pink salmon) 1.4 - 4 mg/L None. Methylene chioride 75-09-2 193 mg/L (Fathead minnow) 83 mg/L/28-day (Fathead fibers) Talc (containing no asbestos 14807-96-6 > 100 mg/L/24hr (Zebra minnow) None fish) N/AV None. Material name: CHO-SHIELD® 4900 SDS US SDS No. PHC-205 Version#: 1 Issue date: 04-21-2015 Page 18 of 34 13#

Page 14SAFETY DATA SHEET Parker Chomerics Ingredients CAS No Toxicity to Daphnia EC50 / 48h NOEC / 21 day M Factor Toluene 108-88-3 3.78 mg/L (Water flea) 0.53 - 1 mg/L Methylene chloride None. 75-09-2 27 mg/L (Daphnia magna) 6.2 - 13.3 mg/L None. fibers) Taic (containing no asbestos 14807-96-6 N/AV N/Av None Ingredients CAS No Toxicity to Algae EC50 / 96h or 72h NOEC / 96h or 72h M Factor • Toluene 108-88-3 "Methylene chioride" N/Av 10 mg/L/72hr (Green algae) 75-09-2 None. 662 mg/L96hr (Green Talc (containing no asbestos Persistence and degradability fibers) 14807-96-6 algae) 56 mg/L/96hr None. N/AV N/AV None. The product itself has not been tested. The following ingredients are considered to be readily biodegradable: Toluene. Contains the following chemicals which are considered to be inherentiv biodegradable: Contains the following chemicals which are not readily biodegradable: Talc (Mg3H2(S103)4). Bioaccumulation potential The product itself has not been tested. See the following data for ingredient information. Components Partition coefficent n-octanol/ater (log Kow) Bioconcentration factor (BCF) Toluene (CAS 108-88-3) 2.65 Methylene chioride (CAS 75-09-2) 90 1.25 6.4 - 40 Talc (containing no asbestos Mobility in soil fibers) (CAS 14807-96-6) - 1.5 (estimated) N/AV Other adverse effects The product itself has not been tested. None known. 13. Disposal consideration Disposal instructions Collect and reclaim or dispose in sealed containers at licensed waste disposal site. This material to drain into sewers/water supplies. Do not contaminate ponds, waterways or material and its container must be disposed of as hazardous waste. Do not allow this ditches with chemical or used container. Dispose of in accordance with local regulations. Local disposal regulations Hazardous waste code Dispose in accordance with all applicable federal, state, territory and local regulations. a hazardous waste as defined under RCRA, Title 40 CFR 261. It is the responsibility of the If this product, as supplied, becomes a waste in the United States, it may meet the criteria of waste generator to determine the proper waste identification and disposal method. For agencies. disposal of unused or waste material, check with local, state and federal environmental US RCRA Hazardous Waste U List: Reference Components RORA Waste Number Toluene (CAS 108-88-3) U220 Methylene chloride (CAS 75-09-2) U080 SDS No. PHC-205 Version #: 1 Issue date: 04-21-2015 Material name: CHO-SHIELD® 4900 SDS US Page 19 0f 34 13#

Page 15SAFETY DATA SHEET Parker Chomerics Waste from residues / unused products Dispose of contents/container in accordance with local regulation. Empty containers should Contaminated packaging be disposed of in accordance with the requirements of the following legislation: Empty containers should be taken for local recycling or waste disposal. Since emptied containers may retain product residue, follow label warnings even after container is emptied 14. Transport information 49CFR/DOT UN proper shipping name UN Number UN1950 Transport hazard classes) Aerosols Subsidiary ris Class 2.1 6.1 Packaging group Special precautions for user Read safety instructions, SDS and emergency procedures before handling. Special Provisions N82 ICAO/IATA UN proper shipping name UN Number UN1950 Transport hazard classes) Aerosols, flammable, containing substances in Division 6.1, Packing Group Ill Subsidiary ris Class 6.1 2.1 Environmental hazards Packaging group None No ERG Code 10P Special precautions for user Read safety instructions, SDS and emergency procedures before handling Operator Variations, prior to shipping this material. Refer to the appropriate Packing Instruction, prior to shipping this material. Review all State ano Special Provisions Other information aircraft Passenger and cargo Allowed Cargo aircraft only Allowed IMDG UN Number UN1950 • Material name: CHO-SHIELD® 4900 SDS US SDS No. PHC-205 Version #: 1 Issue date: 04-21-2015 Page 20 0f8413#

Page 16SAFETY DATA SHEET Parker Chomerics UN proper shipping name AEROSOLS Transport hazard classes) Subsidiary ris Class 2.1 6.1 Environmental hazards Packaging group None Ems Marine pollutant No F-D, S-U Special precautions for user Read safety instructions, SDS and emergency procedures before handling General information and open flame. - No smoking. Appropriate advice on safety must accompany the package. Keep away from heat, sparks Annex Il of MARPOL 73/78 and Transport in bulk according to Not applicable. the IBC Code 15. Regulatory information US Federal Information: Components listed below are present on the following U.S. Federal chemical lists: CERCLA SARA TITLE II: Extremely Sec. 302, SARA TITLE II: Sec. 313, 40 CFR 372, Ingredients CAS # Inventory Quantity(RQ) (40 TSCA Reportable Specific Toxic Chemical CFR 117.302): Substance, 40 Hazardous CFR 355: Toxic Chemical Concentratior de minimus :Toluene 108-88-3 Yes 1000 ib/ 454 kg None. Yes 1% Silver 7440-22-4 Yes 1000 ib final RQ/454 kg 1000 ib/ 454 kg final RQ None. Yes 1% Methylene chloride 75-09-2 Propane 74-98-6 Yes None. Yes *0.1% Yes "None. None. No "NAP isobutane 75-28-5 Yes None. None "NAP asbestos fibers) Talc (containing no 14807-96-6 Yes None. -None. No Superfund Amendments and Reauthorization Act of 1986 (SARA) Hazard categories Immediate Hazard - Yes Delayed Hazard - Yes Fire Hazard - Yes Pressure Hazard - Yes Reactivity Hazard - NO US state regulations The following chemicals are specifically listed by individual States: Material name: CHO-SHIELD® 4900 SDS US SDS No. PHC-205 Version#: 1 Issue date: 04-21-2015 Page 21097413#

Page 17SAFETY DATA SHEET Parker Chomerics Ingredients CAS # California Proposition 65 State "Right to Know" Lists Listed Type of Toxicity CA MA MN NJ PA RI Toluene 108-88-3 No Developmental Yes Yes Yes Silver 7440-22-4 No N/Ap Yes Yes Methylene chloride 75-09-2 Yes Cancer Yes Propane 74-98-6 No Isobutane 75-28-5 No N/Ap No Talc (containing no asbestos N/Ap No Yes Yes No fibers) 14807-96-6 No N/Ap Yes Yes Yes Yes Yes Canadian Information: (DSL). Canadian Environmental Protection Act (CEPA) information: All ingredients listed appear on the Domestic Substances List International Inventories Components listed below are present on the following International Inventory lists: Ingredients CAS # European EINECS lustrali; AICS Philippines PICCS Japan ENCS KECIKECL ECSC China NewZealand Toluene 108-88-3 Silver 7440-22-4 231-131-3 203-625-9 Present Present 75-09-2 200-838-9 Present Present Not listed (3)-2 KE-33936 KE-31261 Present Present HSR003077 HSR001227 Methylene chloride Present Present (2)-36 KE-23893 Present HSROO1540 Propane 74-98-6 200-827-9 Isobutane Present Present (27-3 KE-29258 Present HSR001010 Taic (containing no 75-28-5 200-857-2 Present Presen asbestos fibers) 14807-96-6 238-877-9 (2)-4 KE-24865 KE-32773 Present HSR001003 Present Present (1)-468; (1)-468 Present May be used component as a single under an chemical appropriate standard group 16. Other information, including date of preparation or last revision Issue date Version # 041212015 Legend ACGIH: American Conference of Governmental Industrial Hygienists AICS: Australian Inventory of Chemical Substances ECSC: Inventory of Existing Chemical Substances MDG: International Maritime Dangerous Goods Material name: CHO-SHIELD® 4900 SDS US SDS No. PHC-205 Version#: 1 Issue date: 04-21-2015 Page 220{2413#

Page 18SAFETY DATA SHEET Parker homerics IOC: Inventory of Chemicals VOEC: Nevssevable effect concentration OECD: Organisation for Economic Co-operation and Development TP: National Toxicology Program PA A sylvational Safety and Health Administration RI: Rhode Island TECS: Registry of Toxic Effects of Chemical Substance SDS: Safety Data Sheet ARA: Superfund Amendments and Reauthorization Ac TDG: Canadian Transportation of Dangerous Goods Act & Regulations STEL: Short Term Exposure Limit TSCA: Toxic Substance Control Act TLV: Threshold Limit Values WHMIS: Workplace Hazardous Materials Identification System TWA: Time Weighted Average Other special considerations for handling Disclaimer : Provide adequate information, instruction and training for operators. http://www.thecompliancecenter.com Prepared by: ICC The Compliance Center Inc. This Safety Data Sheet was prepared by ICC The Compliance Center Inc. using information exposed to this product. ICC The Compliance Center Inc and Parker Hannifin Corporation expressly disclaim all expressed or implied warranties and assume no responsibilities for the accuracy or completeness of the data contained herein. The data in this SDS does not apply This Safety Data Sheet may not be changed, or altered in any way without the expressed to use with any other product or in any other process. Corporation. knowledge and permission of ICC The Compliance Center Inc. and Parker Hannifin Bibliography 1. ACGIH, Threshold Limit Values for Chemical Substances and Physical Agents & 5. US EPA is I L is 0 ber 2012 version. 7. OECD - The Global Portal to Information on Chemical Substances - eChemPortal, 2015. Material name: CHO-SHIELD® 4900 SDS US SDS No. PHC-205 Version #: 1 Issue date: 04-21-2015 Page 230{3913#

Page 19Dodd, Alice (PHMSA) From: Geller, Shelby CTR (PHMSA) Sent: Thursday, June 18, 2015 4:00 PM To: Hazmat Interps Subject: FW: Request for Letter of Interpretation Attachments: HAZMATEAM June 15 2015 Request for Interpretation.pdf Dear Shante and Alice, Forwarded is a request for a formal letter of interpretation. Thanks, Shelby From: paul@hazmateam.com [mailto:paul@hazmateam.com] To: PHMSA HM InfoCenter Sent: Wednesday, June 17, 2015 5:12 PM Cc: leo@hazmateam.com; SDeary@parker.com Subject: Request for Letter of Interpretation Dear PHMSA: Please find attached a request for a letter of interpretation. Please send a receipt that is letter was received If you have questions, please send reply e-mail or call my cell, 401-595-8395. Thank you, HAZMATEAM, INC. Paul Dambek, CDGP 1#