Naval Station Everett — Hazardous Materials Safety Interpretation

Page 1Public Works Naval Station Everett 2000 W Marine View Drive Everett, WA 98207 Reference No. 17-0067 Dear Mr. Roley: This letter is in response to your June 14, 2017, e-mail requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to classification. Specifically, you ask whether the products listed in the Material Safety Data Sheets (MSDS) you provided would be considered hazardous materials under the HMR. In accordance with § 173.22 of the HMR, it is the shipper's responsibility to classify a hazardous material. This Office does not normally perform this function. However, based on the information provided in your e-mail, it is the opinion of this Office that both the "All Purpose SAE 10W-40 Four Stroke Engine Oil" and "TGMO SN 5W-30" oil have flash points above 200 °F and are not considered to be a flammable or combustible liquid under the HMR. Therefore, provided these oils do not meet any other hazard classes, they would not be subject to the requirements of the HMR. I hope this information is helpful. 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 2Hi Shante/Alice, Please submit this as a letter of interpretation. Mr. Roley spoke with Eamonn. Please let me know if you have any questions. Thanks, Jordan -----Original Message---- From: Roley, Andrew BLT NAVFAC NW, PRE2 [mailto:andrew.roley@navy.mil] Sent: Wednesday, June 14, 2017 2:27 PM To: INFOCNTR (PHMSA) < INFOCNTR.INFOCNTR@dot.gov> Subject: Request for Interpretation [resending attachments] Good morning, PHMSA. I was speaking with Eamonn in your office earlier today, who assisted with some informal guidance over the phone. He suggested sending this request via email for formal guidance when I requested a written response. Background: 1 am in the United States Navy and recently moved from Naval Station Guantanamo Bay, Cuba, to Everett, WA. As part of my orders, I am entitled to movement of household goods. This excludes any hazardous material. I had attempted to "offer" two types of motor oil for shipment, and classified them as being non-hazardous based on their SDSs (attached). The Naval Supply Systems Command (NAVSUP), who utilized a contractor to pack and move my goods, overrode my classification, saying it was flammable, specifically a "petroleum product" (The Defense Transportation Regulation lists "Petroleum products" as an example of prohibited flammable materials). They made this determination without viewing the SDSs and did not change it after I provided the SDSs (I do not believe they were read, though). I then mailed it through the military postal service agency (which NAVSUP manages a portion of) with the SDSs attached with no issues, and submitted for reimbursement. NAVSUP again said it was a hazardous material not allowable to be reimbursed for shipment. Questions: 1) Are either of these materials classifiable as petroleum products? 2) Are either of these materials classifiable as a flammable or combustible liquid? 3) Would these materials be regulated in any other way under Hazardous Material Regulations? I apologize if these seem to be very easy and straight forward questions based on the SDS contents. However, I believe your expert formal opinion may be needed to convince NAVSUP of the answers and to receive reimbursement. 1#

Page 3425-304-3637#

Page 4Product Name: Yama lube Performance All Purpose SAE 10W-40 Four Stroke Engine Oil "Distributed by Yamaha Motor Corporation, U.S.A." Identification of the J Nippon Oil & Energy USA Inc. supplier: Address: 20 N. Martingale., Suite 325, Schaumburg, IL 60173 Charge section: (TEL: +1-847-413-2188) 2. Hazards identification hazard category Category Flammable liquids No Classification Acute toxicity (oral) No Classification Acute toxicity (dermal) No Classification Specific target organ systemic toxicity No Classification following single exposure Specific target organ systemic toxicity No Classification Aspiration hazard following repeated exposure No Classification LABEL ELEMENTS Precautionary pictograms: Not applicable Signal word: Not applicable Hazard Statement Not applicable recautionary Statements Prevention Do not handle until all safety precautions have been read and understood. Wear protective gloves/protective clothing/eye protection/face protection. Do not allow the eyes to become exposed to the product. Do not swallow the product. Wash hands thoroughly after handling. Do no eat, drink or smoke when using this product. Response IF SWALLOWED: Immediately call a POISON CENTER or doctor/physician. IF SWALLOWED: rinse mouth. Do NOT induce vomiting. If the eyes are exposed to the product: Rinse the eyes with IF ON SKIN: Wash with plenty of soap and water. ON SKIN: Wash with plenty water and immediately contact a physician. Storage The product must be stored in a cool, well-ventilated locatior here it will not be exposed to direct sunlight Containers that have been opened must be tightly sealed. Disposal Dispose of contents/container in accordance with local/regional/national/international regulations. If there are any doubts about proper methods of handling the product, contact the point of purchase before proceeding with usage.#

Page 5Substance/Mixture: Mixture Ingredients and Concentration Ingredient Name Concentrationwt. % Base Oil (s) 80-90 Additives K20 4. First-aid measures Inhalation: IF INHALED: Remove victim to fresh air and keep at rest in a position comfortable for breathing. Cover the body with blankets to keep warm and quiet. If you feel lersathi keep warm and quiet. If you feel unwell, seek medical advice. Skin Contact: Immediately flush skin with large amounts of water. Wash contaminated clothing before reuse. If skin irritation occurs: Get medical advice/attention. Eye Contact: Rinse with clean water carefully for several minutes. contact lenses if present and if removal rinsinto inse for 15 minutes zt a mininun and seek medical Ingestion: control Do not induce vomiting. Drink water. Call a physician or poison center immediately. 5. Fire-fighting measures Suitable Extinguishing Media: Mist of loaded liquid, dry chemicals, carbon dioxide, fire foam, and dry sand are effective. Extinguishing Media to Avoid: Use of straight steam of water can cause a risk of spreading fire. Specific hazards arising from the In some cases of fire, may release irritant gases. chemical: When burnt, may generate carbon monoxide and other toxic gases. Fire Fighting: Spray water to the surrounding facilities for cooling. leep unauthorized persons off the site of occurrence of fire and Even after extinction, cool containers thoroughly with plenty of the surroundings water. pecial protective equipment an Wear fire/flame resistant/retardant clothing. recautions for fire fighters Fight fire from windward direction while wearing protective equipment. If contact with skin is expected, wear impervious Use air-breathing apparatus and protective clothing whenever protective equipment and gloves. necessary.#

Page 6Personal precautions, protective Wear protective equipment when working. equipment and emergency procedures: Remove nearby potential ignition sources immediately. When mist is generated, use respiratory equipment to prevent inhalation of mist. Do not touch or walk through spillage. Pay attention to the site of spillage, which is slippery. Environmental precautions: Prevent spreading of oil spill with earth and sand, sandbags, other proper materials and use care not to allow the oil spill to all on the oil spill to flow to street drains, sewer systems, and rivers. At sea, install oil spill containment booms to prevent spreading of spills and absorb with absorption mat or other proper one arg spreading materials. Methods and materials for In case of spillage in small quantity, collect spillage by containment and cleaning up: absorbing with earth, sand, sawdust, waste, or other proper materials. In case of spillage in large quantity, enclose with to prevent spreading of spillage and collect spillage in empty embankment containers to the extent possible. Prevention of second accident: In case of spillage, immediately inform the organizations concerned of the spillage to prevent possible accidents and spreading of spillage. Remove nearby potential ignition sources immediately and make and ventilate and clean the site and the surroundings. fire-extinguishing agents available. Remove spillage completely, 7. Handling and storage Handling Technical Measures: Keep away from any possible contact with sparks, open flames, and high-temperature materials, and do not allow release of vapor without justification. Use pumps or other proper equipment for taking out from containers. Do not siphon with your mouth using a tube. Do not drink. When mist is generated, use respiratory equipment to prevent inhalation of mist. In case of vapor/mist dispersion, install a closed system, local ventilation system, and/or other proper equipment for the sources of vapor/mist generation. Avoid rough handling of containers such as falling, dropping, Ventilation exposing to shock, and dragging. Maintain adequate ventilation when handling indoors. requirements: Precautions: Wash hands and face thoroughly after handling. Be careful with fire. andling recautions for saf Avoid falling, dropping, exposing to shock, or dragging of containers.#

Page 7Storage Storage Conditions: Store in a well ventilated, cool, dry, dark place, protecting from direct sunlight and keeping away from any potential ignition sources and high-temperature materials. Store tightly stopped after use to prevent possible referably store locked up in a proper storage area ontamination with dust and moisture Safety adequate Use spill-proof containers that are free of damage/corrosion. container materials: 8. Exposure controls/personal protection Appropriate engineering controls: In case of mist generation, enclose the source of mist generation, or install a ventilation system. Install eye cleaning and body cleaning equipment near the handling site. Control parameters Japan Society for Ingredient Name Occupational ACGIH Occupational Exposure Limits TLV-STEL TLV-TWA Base Oil (s) None established None established None established 3mg/m3 (Mineral Oil None ppm, ppm, ppm, Mist) 5mg/m3 (Mineral Oil establishedmg/m3 (Mist) Personal Protective Equipment Respiratory Protection: Not needed under normal conditions, but wear a gas mask (against organic gases) whenever required Hand protection: In case of prolonged or repeated exposure, wear oil-resistant Eye/face protection: Skin Protection: In case of exposure to splashes, wear ordinary type goggles. In case of handling over a prolonged period of time or in case Ple of co tell eat ol red at loraler torte rouse. Hygiene Measures: Wash hands thoroughly after handling. 9. Physical and chemical properties Product Physical state: Liquid Form: Liquid Color: Yellow Slight odor#

Page 8Flash point: 224 (°C) Cleveland Open Cup Auto-ignition Estimate200-410 (°C) temperature: Vapour density: No data. Density (g/cm3) : 0. 86(15°C) Solubility: water: Insoluble. Partition coefficient: n-No data. octanol/water: Decomposition No data. temperature: 10. Stability and reactivity Chemical stability: Stable when stored or preserved in a dark place at room temperature. Possibility of hazardous Keep away from any possible contact with strong oxidizing agents. reactions: Conditions to avoid: Contact with incompatible hazard substances Prolonged heating, open flames, and ignition sources Incompatible materials: Ise care to keep away from any possible contact with halogens, strong Hazardous decomposition When burnt, may release carbon monoxide and other gases. products: 11. Toxicological information Product Acute toxicity (oral): For mixtures, hazard category was identified based on the classification criteria for mixtures. Acute toxicity (dermal): For mixtures, hazard category was identified based on the classification criteria for mixtures. Acute toxicity (inhalation): For mixtures, hazard category was identified based on the classification criteria for mixtures. Skin corrosion/irritation: the classification criteria for mixtures. For mixtures, hazard category was identified based Serious eye damage/irritation: For mixtures, hazard category was identified based on the classification criteria for mixtures. Respiratory sensitization: For mixtures, hazard category was identified based on the classification criteria for mixtures. Skin sensitization: For mixtures, hazard category was identified based on the classification criteria for mixtures. Mutagenicity: For mixtures, hazard category was identified based on the classification criteria for mixtures. Carcinogenicity: For mixtures, hazard category was identified based on the classification criteria for mixtures. Reproductive toxicity: For mixtures, hazard category was identified based on the classification criteria for mixtures. Target organ effect/Single For mixtures, hazard category was identified based on exposure: the classification criteria for mixtures.#

Page 9Respiratory toxic: For mixtures, hazard category was identified based on the classification criteria for mixtures. Ingredient Base Oil (s) Acute toxicity (oral): LD50: ≥ 5000 mg/kg[rat] Acute toxicity (dermal): LD50: ≥ 5000 mg/kg[rat] Serious eye damage/irritation: Practically None [rabbit] Skin sensitization: None Buehler method [guinea pig] Mutagenicity: Ames Test: Negative Carcinogenicity: EU: Category 2 : R45 need not apply. (NOTE L is Applicable), IARC:3 12. Ecological information Product Ecotoxicity Fish acute toxicity: For mixtures, hazard category was identified based on Algae acute toxicity: the classification criteria for mixtures. For mixtures, hazard category was identified based on Fish chronic toxicity: the classification criteria for mixtures. For mixtures, hazard category was identified based on Algae chronic toxicity: classification criteria for mixtures. For mixtures, hazard category was identified based on the classification criteria for mixtures. Ingredient Base Oil(s) Ecotoxicity Fish acute toxicity: 96hLC50: > 5000 mg/L[Oncorhynchus mykiss] Daphnia acute toxicity: 48hEC50: > 1000 mg/L[Daphnia magna] 13. Disposal considerations Disposal Dispose of contents/container in accordance with local/regional/national/international methods: regulations. Every customer/user of the product should dispose of industrial waste on its own responsibility, otherwise it must rely on a company authorized by prefectural governor for treating industrial waste or a local public body involved in the disposal of industrial waste for proper disposal. Before disposal of used container, remove contents completely. 14. Transport information IMDG UN classification: Not applicable#

Page 1015. Regulatory information Korea (KECL) : All components are listed or exempted. Australia (AICS) : Canada (DSL) : All components are listed or exempted. All components are listed or exempted China (IECSC) : All components are listed or exempted. EU (REACH) : listed, in the case In the case where one or more components are not listed or, even if application or notification is required. of importing to the country or area concerned, an New Zealand (NZIoC) : All components are USA (TSCA): listed or exempted. Philippines (PICCS): All components are listed or exempted. All components are listed or exempted Taiwan: In the case where one or more components are not listed or, even if application or notification is required. listed, in the case of importing to the country or area concerned, an 16. Other information Disclaimer Ne at JX Nippon Oil & Energy Corporation have prepared the copyrighter Safety Data Sheet to provide reference information on the hazardous chemical product of interest for our customers/users to ensure secure and se would like every customer/user of the product to refer to the information and understand the necessity of taking appropriate measures for the actual handling conditions on their own responsibilities for optimum practical application of the product of interest. Consequently, the Safety Data Sheet is not intended to guarantee the of the product referenced to herein.#

Page 11PRODUCT Product Name: TGMO SN 5W-30 Product Description: Base Oil and Additives Product Code: 20201030C056, 477547-00, 97Z831 Engine oil COMPANY IDENTIFICATION Supplier: EXXON MOBIL CORPORATION 22777 Springwoods Village Parkway Spring, TX. 77389 USA 24 Hour Health Emergency 609-737-4411 800-424-9300 or 703-527-3887 CHEMTREC 800-662-4525 http://www.exxon.com, http://www.mobil.com [SECTION 2 HAZARDS IDENTIFICATION This material is not hazardous according to regulatory guidelines (see (M)SDS Section 15). Other hazard information: HAZARD NOT OTHERWISE CLASSIFIED (HNOC): None as defined under 29 CFR 1910.1200. PHYSICAL / CHEMICAL HAZARDS No significant hazards. HEALTH HAZARDS or ies pirats erition under skin may cause serious damage. Excessive exposure may result in eye, skin, ENVIRONMENTAL HAZARDS No significant hazards. NFPA Hazard ID: Health: Flammability: Reactivity: HMIS Hazard ID: Health: Flammability: Reactivity: NOTE: This material should not be used for any other purpose than the intended use in Section 1 without expert from person to person. advice. Health studies have shown that chemical exposure may cause potential human health risks which may vary#

Page 12Hazardous Substances or complex substance s) required for disclosure Name CAS# Concentration* GHS Hazard Codes SEVERELY HYDROTREATED HEAVY PARAFFINIC 64742-54-7 1 - < 5% H304 DISTILLATE SOLVENT DEWAXED HEAVY PARAFFINIC DISTILLATE 64742-65-0 1 - < 5% H304 * All concentrations are percent by weight unless material is a gas. Gas concentrations are in percent by volume. As per paragraph (i) of 29 CFR 1910.1200, formulation is considered a trade secret and specific chemical identity and exact percentage (concentration) of composition may have been withheld. Specific chemical identity and exact percentage composition will be provided to health professionals, employees, or designated representatives in accordance with applicable provisions of paragraph (i). SECTION 4 FIRST AID MEASURES INHALATION Remove from further exposure. For those providing assistance, avoid exposure to yourself or others. Use adequate respiratory protection. It respiratory irritation, dizziness, nausea, or unconsciousness occurs, seek immediate medical assistance. If breathing has stopped, assist ventilation with a mechanical device or use mouth-to-mouth resuscitation. SKIN CONTACT Wash contact areas with soap and water. If product is injected into or under the skin, or into any part of the a physician as a surgical emergency. Even though initial symptoms from high pressure injection may be body, regardless of the appearance of the wound or its size, the individual should be evaluated immediately by minimal or absent, early surgical treatment within the first few hours may significantly reduce the ultimate extent EYE CONTACT Flush thoroughly with water. If irritation occurs, get medical assistance. INGESTION First aid is normally not required. Seek medical attention if discomfort occurs. SECTION 5 FIRE FIGHTING MEASURES EXTINGUISHING MEDIA Aamepriate Extinguishing Media: Use water fog, foam, dry chemical or carbon dioxide (CO2) to extinguish Inappropriate Extinguishing Media: Straight Streams of Water FIRE FIGHTING#

Page 13oxides, Oxides of carbon FLAMMABILITY PROPERTIES Flash Point [Method]: >200°C (392°F) [ASTM D-92] Flammable Limits (Approximate volume % in air): LEL: 0.9 UEL: 7.0 Autoignition Temperature: N/D SECTION 6 ACCIDENTAL RELEASE MEASURES NOTIFICATION PROCEDURES In the event of a spill or accidental release, notify relevant authorities in accordance with all applicable regulations. Us regulations require reporting releases of this material to the environment which exceed the applicable reportable quantity or oil spills which could reach any waterway including intermittent dry creeks. The National Response Center can be reached at (800)424-8802. PROTECTIVE MEASURES Avoid contact with spilled material. See Section 5 for fire fighting information. See the Hazard Identification Section for Significant Hazards. See Section 4 for First Aid Advice. See Section 8 for advice on the minimum requirements for personal protective equipment. Additional protective measures may be necessary, depending on the specific circumstances and/or the expert judgment of the emergency responders. For emergency responders: Respiratory protection: respiratory protection will be necessary only in special cases, e.g., formation of mists. Half-face or full-face respirator with filters) for dust/organic vapor or Self burganic apor or sel Contained Breathing Apparatus (SCBA) can be used depending on the size of spill and potential level of exposure. If the exposure cannot be completely characterized or an oxygen deficient atmosphere is possible or anticipated, SCBA is recommended. Work gloves that are resistant to hydrocarbons are recommended. Gloves made of polyvinyl acetate (PVA) are not water-resistant and are not suitable for emergency use. Chemical goggles are recommended if splashes or contact with eyes is possible. Small spills: normal antistatic work clothes are usually adequate. Large spills: full body suit of chemical resistant, antistatic material is recommended SPILL MANAGEMENT Land Spill: Stop leak if you can do it without risk. Recover by pumping or with suitable absorbent. Water Spill: Stop leak if you can do it without risk. Confine the spill immediately with booms. Warn other shipping. Remove from the surface by skimming or with suitable absorbents. Seek the advice of a specialist before using dispersants. Water spill and land spill recommendations are based on the most likely spill scenario for this material; however, geographic conditions, wind, temperature, (and in the case of a water spill) wave and current direction and speed may greatly influence the appropriate action to be taken. For this reason, local experts should be consulted. Note: Local regulations may prescribe or limit action to be taken. ENVIRONMENTAL PRECAUTIONS Large Spills: Dike far ahead of liquid spill for later recovery and disposal. Prevent entry into waterways,#

Page 14HANDLING Avoid contact with used product. Prevent small spills and leakage to avoid slip hazard. accumulate static charges which may cause an electrical spark (ignition source). When the material is handlec in bulk, an electrical spark could ignite any flammable vapors from liquids or residues that may be present (e.g., during switch-loading operations). grounds may not eliminate the hazard from static accumulation. Consult local applicable standards for guidance. Additional references include American Petroleum Institute 2003 (Protection Against Ignitions Arising out of Static, Lightning and Stray Currents) or National Fire Protection Agency 77 (Recommended Practice on Static Electricity) or CENELEC CLC/TR 50404 (Electrostatics - Code of practice for the avoidance of hazards due to static electricity. Static Accumulator: This material is a static accumulator. The container choice, for example storage vessel, may effect static accumulation and dissipation. Do not store in open or unlabelled containers. SECTION 8 EXPOSURE CONTROLS / PERSONAL PROTECTION EXPOSURE LIMIT VALUES Exposure limits/standards (Note: Exposure limits are not additive) Substance Name Form Limit / Standard NOTE Source SEVERELY HYDROTREATED HEAVY Inhalable TWA 15 mg/m3 N/A ACGIH PARAFFINIC DISTILLATE fraction SEVERELY HYDROTREATED HEAVY Mist. TWA 5 mg/m3 N/A ACGIH PARAFFINIC DISTILLATE SOLVENT DEWAXED HEAVY TWA PARAFFINIC DISTILLATE Mist. 5 mg/m3 N/A OSHA Z1 SOLVENT DEWAXED HEAVY TWA PARAFFINIC DISTILLATE 2000 500 ppm N/A OSHA Z1 mg/m3 SOLVENT DEWAXED HEAVY Mist. TWA 15 mg/m3 N/A ACGIH PARAFFINIC DISTILLATE Exposure limits/standards for materials that can be formed when handling this product: When mists/aerosols can occur the following are recommended: 5 mg/m - ACGIH TLV (inhalable fraction), 5 mg/m - OSHA PEL. NOTE: Limits/standards shown for guidance only. Follow applicable regulations. No biological limits allocated. ENGINEERING CONTROLS The level of protection and types of controls necessary will vary depending upon potential exposure conditions. Control measures to consider:#

Page 15with this material, as provided below, is based upon intended, normal usage. Babul re select protective equipment for use Respiratory Protection: If engineering controls do not maintain airborne contaminant concentrations at a level which is adequate to protect worker health, an approved respirator may be appropriate. Respirator selection, use, and maintenance must be in accordance with regulatory requirements, if applicable. Types of respirators to be considered for this material include: No special requirements under ordinary conditions of use and with adequate ventilation. For high airborne concentrations, use an approved supplied-air respirator, operated in positive pressure mode. Supplied air respirators with an escape bottle may be appropriate when oxygen levels are inadequate, gas/vapor warning properties are poor, or if air purifying filter capacity/rating may be exceeded Hand Protection: Any specific glove information provided is based on published literature and glove manufacturer data. Glove suitability and breakthrough time will differ depending on the specific use conditions. Contact the glove manufacturer for specific advice on glove selection and breakthrough times for your use conditions. Inspect and replace worn or damaged gloves. The types of gloves to be considered for this material include: No protection is ordinarily required under normal conditions of use. Eye Protection: If contact is likely, safety glasses with side shields are recommended. Skin and Body Protection: manufacturer data. Any specific clothing information provided is based on published literature or The types of clothing to be considered for this material include: No skin protection is ordinarily required under normal conditions of use. In accordance with good industrial hygiene practices, precautions should be taken to avoid skin contact. Specific Hygiene Measures: Always observe good personal hygiene measures, such as washing after handling the material and before eating, drinking, and/or smoking. Routinely wash work clothing and protective equipment to remove contaminants. Discard contaminated clothing and footwear that cannot be cleaned. Practice good housekeeping. ENVIRONMENTAL CONTROLS Comply with applicable environmental regulations limiting discharge to air, water and soil. Protect the environment by applying appropriate control measures to prevent or limit emissions. SECTION 9 PHYSICAL AND CHEMICAL PROPERTIES Note: Physical and chemical properties are provided for safety, health and environmental considerations only and may not fully represent product specifications. Contact the Supplier for additional information. GENERAL INFORMATION Physical State: Liquid Color: Amber Odor: Characteristic#

Page 16Flammable Limits (Approximate volume % in air): LEL: 0.9 UEL: 7.0 Autoignition Temperature: N/D Boiling Point / Range: > 316°C (600°F) Decomposition Temperature: N/D Vapor Density (Air = 1): > 2 at 101 kPa Vapor Pressure: < 0.013 kPa (0.1 mm Hg) at 20 °C Evaporation Rate (n-butyl acetate = 1): N/D Log Pow (n-Octanol/Water Partition Coefficient): > 3.5 Solubility in Water: Negligible Viscosity: 61.9 cSt (61.9 mm2/sec) at 40 °C | 10.5 cSt (10.5 mm2/sec) at 100°C Oxidizing Properties: See Hazards Identification Section. OTHER INFORMATION Freezing Point: N/D Melting Point: N/A Pour Point: -27°C (-17°F) DMSO Extract (mineral oil only), IP-346: < 3 %wt SECTION 10 STABILITY AND REACTIVITY REACTIVITY: See sub-sections below. STABILITY: Material is stable under normal conditions. CONDITIONS TO AVOID: Excessive heat. High energy sources of ignition. MATERIALS TO AVOID: Strong oxidizers HAZARDOUS DECOMPOSITION PRODUCTS: Material does not decompose at ambient temperatures. POSSIBILITY OF HAZARDOUS REACTIONS: Hazardous polymerization will not occur. SECTION 11 TOXICOLOGICAL INFORMATION INFORMATION ON TOXICOLOGICAL EFFECTS Hazard Class Conclusion / Remarks Inhalation Acute Toxicity: No end point data for material. Minimally Toxic. Based on assessment of the components. Irritation: No end point data for material. Negligible hazard at ambient/normal handling temperatures. Ingestion Acute Toxicity: No end point data for material. Minimally Toxic. Based on assessment of the components.#

Page 17Serious Eye Damage/Irritation: No end point May cause mild, short-lasting discomfort to eyes. Based on data for material. assessment of the components. Sensitization for material. Respiratory Sensitization: No end point data Not expected to be a respiratory sensitizer. Skin Sensitization: No end point data for Not expected to be a skin sensitizer. Based on assessment of the material. components. Aspiration: Data available. Not expected to be an aspiration hazard. Based on Germ Cell Mutagenicity: No end point data physico-chemical properties of the material. for material. Not expected to be a germ cell mutagen. Based on assessment of Carcinogenicity: No end point data for Not expected to cause cancer. Based on assessment of the Reproductive Toxicity: No end point data Not expected to be a reproductive toxicant. Based on assessment Lactation: No end point data for material. of the components. Not expected to cause harm to breast-fed children. Specific Target Organ Toxicity (STOT) Single Exposure: No end point data for Not expected to cause organ damage from a single exposure. Not expected to cause organ damage from prolonged or repeated exposure. Based on assessment of the components. OTHER INFORMATION For the product itself: Diesel engine oils: Not carcinogenic in animals tests. Used and unused diesel engine oils did not produce any carcinogenic effects in chronic mouse skin painting studies. Oils that are used in gasoline engines may become hazardous and display the following properties: Carcinogenic in animal tests. Caused mutations in vitro. Possible allergen and photoallergen. Contains polycyclic aromatic compounds (PAC) from combustion products of gasoline and/or thermal degradation products. Base oil severely refined: Not carcinogenic in animal studies. Representative material passes IP-346, Modified Ames test, and/or other screening tests. Dermal and inhalation studies showed minimal effects; lung non-specific infiltration of immune cells, oil deposition and minimal granuloma formation. Not sensitizing in test animals The following ingredients are cited on the lists below: None. -REGULATORY LISTS SEARCHED-- 1 = NTP CARC 3 = IARC 1 2 = NTP SUS 5 = IARC 2B 4 = IARC 2A 6 = OSHA CARC#

Page 18Material -- Not expected to be harmful to aquatic organisms. MOBILITY Expected to partition to sediment and wastewater solids. Base oil component - Low solubility and floats and is expected to migrate from water to the land. PERSISTENCE AND DEGRADABILITY Biodegradation: Base oil component -- Expected to be inherently biodegradable BIOACCUMULATION POTENTIAL Base oil component -- Has the potential to bioaccumulate, however metabolism or physical properties may reduce the bioconcentration or limit bioavailability. SECTION 13 DISPOSAL CONSIDERATIONS Disposal recommendations based on material as supplied. Disposal must be in accordance with current applicable laws and regulations, and material characteristics at time of disposal. DISPOSAL RECOMMENDATIONS Product is suitable for burning in an enclosed controlled burner for fuel value or disposal by supervised incineration at very high temperatures to prevent formation of undesirable combustion products. Protect the brake fluids or coolants. environment. Dispose of used oil at designated sites. Minimize skin contact. Do not mix used oils with solvents, REGULATORY DISPOSAL INFORMATION RCRA Information: The unused product, in our opinion, is not specifically listed by the EPA as a hazardous waste (40 CFR, Part 261D), nor is it formulated to contain materials which are listed as hazardous wastes. It does not exhibit the hazardous characteristics of ignitability, corrositivity or reactivity and is not formulated with contaminants as determined by the Toxicity Characteristic Leaching Procedure (TCLP). However, used product may be regulated Empty Container Warning Empty Container Warning (where applicable): Empty containers may contain residue and can be dangerous. Do not attempt to refill or clean containers without proper instructions. Empty drums should be completely drained and safely stored until appropriately reconditioned or disposed. Empty containers should be taken for recycling, recovery, or disposal through suitably qualified or licensed contractor and in accordance with governmental regulations. DO NOT PRESSURISE, CUT, WELD, BRAZE, SOLDER, DRILL, GRIND, OR EXPOSE SUCH CONTAINERS TO HEAT, FLAME, SPARKS, STATIC ELECTRICITY, OR OTHER SOURCES OF IGNITION THEY MAY EXPLODE AND CAUSE INJURY OR DEATH.#

Page 19LAND (TDG): Not Regulated for Land Transport SEA (IMDG): Not Regulated for Sea Transport according to IMDG-Code Marine Pollutant: No AIR (IATA): Not Regulated for Air Transport SECTION 15 REGULATORY INFORMATION OSHA HAZARD COMMUNICATION STANDARD: This material is not considered hazardous in accordance with OSHA HazCom 2012, 29 CFR 1910.1200. Listed or exempt from listing/notification on the following chemical inventories: DSL, KECI, PICCS, TSCA EPCRA SECTION 302: This material contains no extremely hazardous substances. SARA (311/312) REPORTABLE HAZARD CATEGORIES: None. SARA (313) TOXIC RELEASE INVENTORY: This material contains no chemicals subject to the supplier notification requirements of the SARA 313 Toxic Release Program. The following ingredients are cited on the lists below: Chemical Name CAS Number List Citations DIPHENYLAMINE 122-39-4 ZINC ALKYLDITHIOPHOSPHATE 18 68649-42-3 ZINC DITHIOPHOSPHATE 15,19 68649-42-3 I 15, 19 -REGULATORY LISTS SEARCHED.- 1 = ACGIH ALL 6 = TSCA 5a2 11 = CA P65 REPRO 16 = MN RTK 2 = ACGIH A1 7 = TSCA 5e 12 = CA RTK 3 = ACGIH A2 17 = NJ RTK 8 = TSCA 6 13 = IL RTK 18 = PA RTK 4 = OSHA Z 9 = TSCA 12b 14 = LA RTK 19 = RI RTK 5 = TSCA 4 10 = CA P65 CARC 15 = MI 293#

Page 20ND No termed, NA - Not applicable KEY TO THE H-CODES CONTAINED IN SECTION 3 OF THIS DOCUMENT (for information only): H304: May be fatal if swallowed and enters airways; Aspiration, Cat 1 THIS SAFETY DATA SHEET CONTAINS THE FOLLOWING REVISIONS: Updates made in accordance with implementation of GHS requirements. The information and recommendations contained herein are, to the best of ExxonMobil's knowledge and belief, accurate and reliable as of the date issued. available from ExxonMobil. The information and recommendations are offered for the user's consideration and examination. It is the user's responsibility to satisfy itself that the product is suitable for the intended use. repackages this product, it is the user's responsibility to insure proper health, safety and other necessary information is included with and/or on the container. Appropriate warnings and safe-handling procedures should be provided to handlers and users. Alteration of this document is strictly prohibited. Except to the extent required by law, re-publication or retransmission of this document, in whole or in part, is not permitted. The term, "ExxonMobil" is used for convenience, and may include any one or more of ExxonMobil Chemical Company, Exxon Mobil Corporation, or any affiliates in which they directly or indirectly hold any interest. Internal Use Only МНС: ов, Ов, 0, 0, 0, 0 PPEC: A DGN: 7010885XUS (1018590) Copyright 2002 Exxon Mobil Corporation, All rights reserved#