VFP Inc. — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation Washington, D.C. 400 Seventh Street, S.W. 20590 Special Programs Research and Administration SEP 1 8 1998 Mr. David Brammer VEP Inc. Ref. No. 98-0267 P.O. Box 11927 Roanoke, VA 24022-1927 Dear Mr. Brammer: This is in response to your letter dated September 3, 1998, regarding the shipment of electric storage batteries under Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). the Electric storage batteries meeting the criteria specified in $ 173.159 (e) (1) through (e) (4) are not subject to the hazardous materials regulations. The batteries must: (1) be the only hazardous material on the vehicle; and (2) be loaded or braced so material loaded in the vehicle must be blocked and braced to as to prevent damage and short circuits. In addition, any other prevent contact with or damage to the batteries and the vehicle may not carry material shipped by any person other than the shipper of the batteries. Therefore, under the scenario described in your letter, the batteries your company ships would not be subject to the hazardous materials regulations. I hope this satisfies your request. Sincerely Office of Hazardous Materials Standards#

Page 2109/03/98 THU 10:55 FAX 5409775555 VFP, INC. C001 BAH VEP, INC. $173.159 PO BOX 11927 ROANOKE, VA 24022-1927 198-0267 Fax Cover Sheet DATE: SEPTEMBER 3, 1998 TO: EDWARD MAZZULLO PHONE: US DOT HAZARDOUS MATERIAL FAX: 202 366-3012 INFORMATION CENTER FROM: DAVID BRAMMER PHONE: FAX: 540 977-0500 540 977-5555 RE: INTERPERTATION REGARDING THE SHIPPING OF ELECTRIC STORAGE BATTERIES (UN 2794 & UN 2800) Number of pages including cover sheer: 15 MR. MAZZULLO MY COMPANY MANUFACTURES/BUILDS FIBERGLASS, METAL & CONCRETE BUILDING PRIMARLY USED IN THE COMMUNICATION INDUSTRY TO HOUSE TELECOMMUNICATION SWITCHING EQUIPMENT. THE BUILDINGS SHIP ASSEMBLED, A TYPICAL BUILDING IS 20' LONG × 12' WIDE × 10'10" HIGH. BUILDINGS OFTEN SHIP CONTAINING ELECTRIC STORAGE BATTERIES. THE BATTERIES ARE PERMANENTLY MOUNTED TO THE FLOOR AND FOR SHIPPING ARE BRACED INTO THE WALLS ON THE SIDES AND INTO THE CEILING. CABLES ARE UNHOOKED AND PROPERLY SECURED, ALL POST ARE PROTECTED USING PROTECTIVE DEVICES SUPPLIED BY THE BATTERY MANUFACTUER. IN THE PAST WE HAVE SHIPPED BUILDING CONTAINING BATTERIES WITH A GROSS WEIGHT EXCEEDING 1001 LB. AND HAVE NOT DOCUMENTED SHIPPING PAPERS OR PUT PLACARDS ON THE LOAD. IT IS MY INTERPRETATION THAT WE ARE EXCEMPTED FROM THE REQUIREMENTS OF 172 SUBPART C - SHIPPING PAPERS AND SUBPART F - PLACARDING BECAUSE WE MEET THE REQUIREMENTS OF 173.159 SECTION E. • NO OTHER HAZARDOUS MATERIALS ARE TRANSPORTED IN THE BUILDING OR ON THE VEHICLE: • BATTERIES ARE LOADED AND BRACED SO AS TO PREVENT DAMAGE AND SHORT CIRCUITS IN TRANSIT:#

Page 3:09/03/98 THU 10:55 FAX 5409775555 VFP, INC. 124002 • ALL OTHER MATERIAL IN THE BUILDING IS BLOCKED, BRACED OR OTHERWISE SECURED TO PREVENT CONTACT WITH OR DAMAGE TO THE BATTERIES: • THE TRANSPORI VEHICLE DOES NOT CARRY MATERIAL SHIPPED BY ANY PERSON OTHER THAN THE SHIPPER OF THE BATTERIES. I WOULD LIKE TO GET AN INTERPRETATION ON THIS MATTER SO THAT WE ARE SAFELY AND CORRECTLY SHIPPING OUR PRODUCT AND SO WE HAVE SOMETHING TO KEEP ON FILE. I AM INCLUDING THE MSDS SHEETS FOR THE TWO TYPES OF BATTERIES. IF YOU HAVE ANY QUESTIONS OR NEED ADDITIONAL INFORMATION PLEASE CONTACT ME AT 540 977-0500, YOUR RESPONSE CAN BE FAXED TO MY ATTENTION AI 540 977-5555. THANK YOU FOR YOUR HELP IN THIS MATTER.#

Page 4.:09/03/98 THU 10:55 FAX 5409775555 VFP, INC. 4003 BATTERIES, WET, FILLED WITH ACID 8, PG III GROSS WEIGHT = 1314 LB.#

Page 5*09/03/98 08/28/98 THU 10:56 FAX 5409775555 09:28 FAX 88795751 VEP, INC. - AUG 28 98 В8E1A 7777977777997977 ENGINEERING #004 → VEP 1002 P.2/B • .: EXIDE INc. MATERIAL SAFETY DATA SHEEI Page : of 7 Ravisad 11/93 PRODUCT ICENTIFICATION Chemical/Trade Name los usad en labell Sherical Family/Clasziticarien Lead-Acid Battory Elecale Storaga Rectary Manufacturer's NepwAsdress Isleptong Yuaza-Exide, Ine. 645 Penn Street • • For information and amargencies, sontact Yuas#-Exide., Reading, P'A 18601 Environmental Resourees Depr. (215) 371-0400, 24-hour Emergency Response Contact: SHEMTREG (80D) $24-9300 1. HAZAADRYS INGREDIENTSADENTITY INFORMATION Approximate • SAS Number or Val 36 by Ws. Air Exposure Link lus/all OSHA AÇGIM NIgSH Inorganic lead compound: • Antimany Lead 7439-92-1 2 50 0,2 0.2 500 160 100• Arsenio 7440-36-0 Til Caldlum 7440-38-2 10 • 500 7440-70-2 200 7440-31-5 0,2 2000 2000 Electrolyte (sulturie acidi 7884.93-9 10-50 1000 1000 1000 Case Marerial: Polystyrana Palypropylene 9003-07-0 5-10 • NIA N/A NIA 9003-83-6 Styrane Acrylonitrile...... 9003-54-7 Styrene Butadiene Aorylonitrile Butadiana Bryrene 9003-56-9 Polyvinylchioride 9002-86-2 9002-55-8 Hard Rubber Palycarbonars • Polyethylene Other • (eel tell batterles only; Siliaor. dioxide B0876-86-0 NIA N/A N/A • (glaze-reinforced poly&ster) Shee: Molding Compound 10 NIA N/A N/A NOTEi Inorgania load and electrolyte faullurie acid are sha primary components of avary bussary manufaczured by Yussa- representativa for additional information. Other ingradients may be present depondent upon battery type. Contact your Yuaas-Exide 665 Pann Stradi Handing, PA 19601 • P.O. Bax 14145 Moading, PA 19819-1115 •#

Page 609/03/98 THU 10:56 FAX 540977555 #AX 99795751 ENGINEERING • VFP, INC. 4005 -AUG2898 B8:D2AM 777777777777777777 → VPP 21003 P.3/8 • • • Page 2 ot 7 Ill. PHYSICAL DATA Falling Fains: 203°F Spacils Gravity (H,0=1) 1.215 to 1.350 : Meline Polat: Not Applicable Vaner Fracture (men Hal: 10 Salubilly In Warer: 100% Yapor Densisy (ATA = 1): Greater shan: EvaRgration RaTE (Buryl acerara T) Lass Than 1 % Valagiles by Welght: Not Appllcable APESANER and Oder: Manufantured aricle: no apparene adar. Electrolyre is a dinar liquid with a sharp, • penetrating, pungent adar. FIRE AND EXFLOSION HAZARD PATA Flash Point: No: Applesble Flammable Linim: LEL = 4.1% (Hydrogen Gas) WEL * 74.2% Essinsulshing medle: COn: foam; dry chamical breathing apparatur. Warar applled to elactrolyre generates heat and couses it to spaiter. Wear acid-resistant Special Fre Fishting Prosedures: It batteries are on charge, shut ait pawer. Lisa positive pressure, self-containnd clothing. ynyaval Fire and Eyelaslen hazards: Highly flammablo hydrogen pas is generated during charaing and operatlon of batterian. To avoid risk of fire or explosion, keep sparks or other sources of ignition away from batteries. Do manufaciurer's Instrustiona for installation and service. nos allow metallic materials to simultaneously contact nagatiye and positive terminals of calls and baiteries. Follar BEASTIVITY DATA Stabilisy: Unstable Stable X →.. Sendilant to Avaid: Prolanged overcharge; sources at Ignition. ! Incomparill: (matarlals to avoid) Sulturie said: Contact with combustibles and orgarle materials may fause fee and explosion. Also reaets vicently wish strong reducing agents, metals, sullur trioxide gas, strong oxidizers and water. Contes: with metals may produce roxis sulfur dioxide tumes and may rolaasa flammable hydrogen gos. Load compaunds: Avold conter with strong acids, boras, Aslidas, halogenates, potassium nitrato, permanganare, peroxidas, nascent hydraden and reducing agents. i Hazardous Dodompossion Products: Sulfurle aeld: Sulfur trioxide, narbon monoxide, sulluric acid mist, sulfur dioxide, hydrogen. or base o: presence of nascent hydrogen may generase highly soxle aruino nas. Lead compounds: High emperatures likely to produce toxic matal furte, vapor or dust; contass with strong arid •#

Page 7* 09/03/98 08/28/98 THU 10:56 FAX 5409775555 VEP, INC. AUG 28 ENGINEERING → YEP @004 71006 • •• Page 3 of 7 ". YL HEALTH HAZARD DATA •.. •-=. Sulfuric acid: Harmful by all raures of entry. Load campounds: Hazardous exposure can occur only when product la heased, oxidized or otherwise processed ar samaged to cesata dust, vapor or tuma. Inhalation: Sulfuria aeld: Breathina of sulfurle arid vapers or mists may cause cevere resplrstory intatian. •.: Lead compounes: inhalarion of lead dust or fumes may cause irrierian of upper rasicatory tract and tungs. Ingesian: • Sulfurle aeld: May cause sovers irriation of maush, throaz, arophagua and stomach. Lead campounda: Acure ingeatian may cause abdominal pain, nauses, vomiting, diarhea and sovera siampino. This may lead rapidly to systemic toxicity and must be treated by a physlclar.. Skin Contacs: Sulfurle acid: Severe irritarion, durns and Ulcoration. • Lead compounds: Nat absarbed thraugh the skin. Exa Contat: Sulfuric acid: Severe irritazion, burns, cornea damage, blindness. Load Fampounds: May cause eye irritation. • Effert at Averazaasure • Acute: Suifurle acid: Savere skin irritation, damago so corned, unper respiratory irritation. Lasd compounds: Symptoms of raxlehy includa headeche, fatigus, abdominal pain, lass of zonstre, muncular achas and weakness, slamp disturbances and irability. Effects of Overexpasure • Chronis: • Sulfuric acla: Possible erosion of tooth anamel; inflammatian of nase, throat and bronchlai subes. reproductive changes in both males and famales. Lead comfounds: Anemia; neurapathy, particularly of the motor nerves, with wrist drop; Kidney damage; Careines snielty: containing aulfurla acid" as a Category 1 carcinogon, a substanco thar is carcinogenic to humans. This classification Sulfuric acid: The Insarnational Agenoy for Research on Cancer (lARC) has classifled "strong inorganic acid mist mist (sulfurle acid mist) Is not gongrated under normal use of this product. Misuse of the product, sush da dees not apply to liquld forms of sulfurle acid or sulfurie acid solutions contained within a battary. "Inorganic acid overcharging, may casult in the generation of sullurle acid mist. in humans is incking as preneat. Lead tompounds: Lead Is listed ax a 28 carcinogen, likely in arimals at extreme doses. Proof of carcingenicity Arsenle. Listed by Nazional Toxinslogy Program INTPI. International Agency for Research on Cancer (IARCI, OSHA#

Page 8• 09/03/98 08/28/98 THU 10:57 FAX 5409775555 VFP, INC. HUG 28 j0:03AM 77777777778? 8878570. ENGINEERING → VEP 4005 0007 P.5/B Pape 4 or y •. • VI HEALTH HAZARD DATA (Continues) Medical Conditions Generally ArRavated by ExAgrUra: acid with skin may aggrayase skin diseases such as eazama und contaos dermatitis. Lead and its dampounds car Overexposura to sulfurle seid mist may cause lung damage and aggravate pulmonary conditions. Contacs of sulfurle aggravase same fora of kidney, liver and neuralogic diseases. Emersoney and Fist Aid Frareduces: Inhalazlen: • Sulurle acid: Remove to fresh air immedately. If braishing Le difficult, sive oxygen, Lead: Remove frent exgosure, garglo, wash nose and ilps; consult physician. Ingestian: Sulfurio fali: Give large quanties of waier: ge nes induce vomiting; consult physician. Lead: Consult physiclan Immedlately Scin: including shoes. Sulfuric acid: Fiush with large amounts of water for at least 15 minuses; remove contaminated clothing completely, Lead: Wash. immediataly with seap and water. Sulfuric acid and lead: Flush immadierely with large amounts of water for at lezst 15 minutes; corwult physician. VIL. PRECAUTIONS FOR SAFE HANDLING, AND USE Still er Leak Procedures: mad, do - • Stap flow of risterial, contaln/absorb small spills with dry sand, earth, varmiculio. Do not use sambustible • acid-resistant diothing, boots, gloves, and face shield. Do not allow discharge ef unneutralized asle ta rawer. materials. it possible, caretully neutrallze splllad electrolyse with soda ash, sodium bicarbonate, Ilme, etc. Wear Waste Disnesal Methods: Spent batteries: Send to secondary lead ameer for recycling. Place neutralized slurry into sealed containers and dispose of as hazardous waste, as applicable. Largo water-dilured : equirements. Consult atate environmentet agency and/or faderal EPA. spills, after neutrallzation and iesting, should be managad in accordance with approved local, state and federal Handling and Storens: Store batteries in cool, dry. well-ventilated areas with impervious Burlaces and adaquata concalmant in the event trom incompetible materials. Stare and handle only in areas with adequate water supply and spill contral. Avoic it spills. Batteres shauld aiso be storad under raof lol protection against adverse weather conditlans. Separate damage to containers. Keep away from fire, sparks and heat.#

Page 9.09/03/98 THU 10:57 FAX 5409775555 08/28/98 • AUG 28 09:28 FAX 99795751 ENGINFERING VFP, INC. 0008 → YEP 42006 - P-Б/E • - • Page 5 o1 7 • VIl. PRESAUTIONS FOR SAFE HANDLING AND USE (Continued Pressurionary Labelling: • . POISON . CAUSES SEVERE SUANS • • DANGER - CONTAINS SULFURIC ACID VIl. CONTROL MEASURES Ensineerine, Contrals: Stare and handle in well-verillared area. If machenlal ventlation is usad, components must ba acid-resissens, Work Prassinga: components. Wear proteczive clothirig when fillng or handling batteries. Mandle bamarles cauriously to avoid spills. Make cerrain vent capa dro on sacurely. Avoid contac; with internel Respiratory Proteoring: NIOSH or MshA-approved respiratory protadtinn. Nore required under normal conditions. When concentrations of sulfuric acid mist are known to exceed PEL, Use Proractive alovas: Rubber bi plastic acid-resistant glovea with elbow-length pauntier, Exe Protestion: Chemical goggles or faca shiald. • • Siber Protestion: Acid-resistanz waran. Under severe exposure or emergency conditions, wear asid-resistant clothing and boots. Emergency Fluabing: .... Inareas where sulture acid is handled in concantrations graster than 1%, emargency eyewash stations and showers should be provided, with untimited water supply. OTHER REGULATORY INEQRMATION NEPA Hazard Rating for sulfurie acid: Flammabilty (Red) Hazith (Blue) = • Reactivity (Yellaw) 2 • Sulfuric acid is watar-rective if concentrated. 145. 08I: Wet (filled with alectralyte) bateries are rosulased by U.S. DOT as hazardous materlal, Proper Shipping Name: Battesles, wat, filled with acid ID Number: Hazard Class/Divisions UN2794 •. Lapal Raquiend: Packing Graup: Corrosive • •#

Page 10•09/03/98 THU 10:57 FAX 5409775555 08/28/98 09:29 FAX 89785761 VFP, INC. → VFP 4007 41009 P.7/8 • Pago & af 7 _OTHER REGULATORY INEOAMATION (Cortinuedl 35, POT (Continued) as provided in 49 CFR 173.159(d). are non-regulated by DOt whin protected against shart circuits and securely Verg: Yuasg-Exida batterles which have mes the test requirements for "nan-apillable wet electre atarage batteries", Dackaged. Contact yaur Yuasa-Exide representative to determine which non-apillable barteries have maz theso al nonspillable wes electric storago bateries have net met these requisements, the following information would • Hazard Class/Division: Proper Shipping Name: Baterias, wer, nan spillable ID Number! - UNZBOO Label Requirea: Packing Group: Corrasive .:• RCRA: Spent lead-acld battaries are not regulated an hazardous waste when recycled. Spilled gulfurle acld is a • • characteristle hazardous waste: FPA hazardaus wasze number DOQZ, (corresivity). GERCLA (Supertundl and EPCRA: (8) Reportable Quantiy (HQ) for spilled 100% sulturic acid under CERCLA (Superfund) and EPCAA (Emergen=y sulfuric acid may vary. Planning and Community Rightto Know Act) Is 1,000 Ibe. Stare and lacal reportable quantities far spilled (b) Sulturic acid is a listed "Extrembly Hazardous Substance" under EPCRA, with a Threshold Manning Quanticy (TPQ) af 1,000 Ibs. EPCRA Section 302 notification Is requirad if 1,000 Ibs, or more of sulfurle acld is present at ene sire. The information. quanty of sulfurie aeid Will vary by battery type. Conzact your Yuasa-Exide representativa for modisionai (cl • EPCRA Section 312 Tier 2 raparting is required for batteries if sulfuric acid is present in quantities of 500 Ibs. or more ador if lead is presenz in quantitles of 10,000 lbs ar more. {el Supoller Natitsarion: This product contains toxic chemicals which may be reportable ufider ENCRA Saction 13 Taxis Chemical Rolsase Inventory (Farm R) requiramants. If yau ura a manufacturing facilty under St : ocies 20 through IS, the following information is provided to enable you to complete the required reports Toxis Chemiçal SAS Number • Approximate 3 be Wajshi Lear • 7439-92-1 80 Sulfurla daid 7664÷93-9 10-30 • Antimony 7440-36-0 - Argenie 7440-28.2 0.2 11 you distribute this product to other manufacturers in SIC Codes 20 thraugh 39, this informazian must be pravided with the first shipment of each calendar year. products. Note: Tro Secsion 313 supplier nosification reaulremont does not apply to barterles which are "consumes то. • Not present in all battery types. Contacs your Yunss Exide rearezenariva for additional informarian,#

Page 11-09/03/98 THU 10:57 FAX 5409775555 08/28/98 • AUG 28 09:28 FAX 99795751 ENGINEERING VFP, INC. #010 .. * VEP 11008 F.BrE • • • in. Page 7 of 7 OTHER RRGULATORY INFORMATION Gearinuel ISCA Ingredients in Yuasa-Exid's batteries are load in the BCA epistry as follows: - Electrolyse 5AS NEL BCA Status Sulturic Acid (H,sO,) 7664-93.9 Listad Inorganie bead Compound Load iPb Land Oxide (Poo) • 7439-92-1 Antimany (st) Lead Sulfare IbXO.! 7445-75-2 1317-36-8 Listed Listed Calcium (Ca) Arsenic (As) 7940-32-2 7440-36-0 Listed Usted 7440-31-5 7440-70-2 Listed Listed Listed SAA Yuasa-Exida, Inc, suppora preyentative actlens concerning ozone deplesian In the atmosphers due to emissiens a! CFC's and other ozone deplating chemicals (ODC's), dellned hy the USEPA as Class I subarances. Pursuane to establisted a policy to eliminate the use of Class I ODC's prlor ta the May 15. 1993 deadlino. Section 611 of the Clean Air Aes Amendments (CALA) of 1950, finalized on January 19. 1993, Yuasa-Exida, inc -... .. • .-#

Page 12, 09/03/98 THU 10:58 FAX 5409775555 VFP, INC. Ø011 BATTERIES, WET, NON-SPILLABLE 8, PG III • GROSS WEIGHT = 1572 LB.#

Page 13-09/03/98 THU 10:58 FAX 5409775555 VFP, INC. 01012 SENT BY: GNB TECHNOLOGIES T/PC: 1-16-98: 11:42 :LOMBARD 690. 629. 2695- 540 977 3069:# 2/ 5 GNB BATTERY TECHNOLOGIES MATERIAL SAFETY DATA SHEET I. Product Identification Chemical/Trade Name (Identity used on label) Chemical Family/Classification ABSOLYTE-XL- V/O-Sealed Lead Acid Battery Electric Storage Battery Company Name Address: Division or Deparment GNB Battory Tochnologics 829 Parkview Boulevard Lombard, IL 60148-3249 Industrial Batary Company - Stationary Contact Telephone Number Contact Environmental Assurance Department Questions concerning MSDS Day: 770-673-2470 Steve Emmons Transportation Emergencios: 800-424-9300 24 hours: CHEMTREC II. Hazardous Ingredients % by Weight CAS OSHA Exposure Limits MATERIAL NUMBER ACGIH Electrolyte: Load 67-77 7439-92-1 .05 mg/ma 115 mg/m (Sulfuric Acid 18-24 7664-93-9 1 mg/m? 1 mg/m3 : Case Materisl: Antimony Oxide Polypropylene 2-5 7440-36-0 9003-07-0 0.5 mg/m 3 N/A <0.6 0,5 mg/m3 N/A Separasor 2-3 7440-50-8 N/A 1 mg/m3 N/A Copper N/A Tin 7440-93-9 N/A 2 mg/m3 N/A Antimony Cadraium <0.2 0.2-0.3 7440-36-0 0.05 mg/m? N/A 0.2-0.4 0.5 mg/m 3 0.05 mg/m3 0.5 mg/m? I. Physical Data Materials (at normal temperatures) Appearance and Odor : Electrolyic benetrating, pungent odor lectrolyre is a clear liquid with a sharp. 203°F Boiling Point (at 760 MM Hg) N/A Specide Gravlry (H20=1) Vapor Pressure (mom Hig at 20°C) : 1.230-1.350 Vapor Density (ATR=1) Greater than 1 Solubiliry in Water 100% % Volatiles by Weight Evaporation Rare (Buryl Acetate= 1) N/A Less chan 1 ABSOLYTE-XL. 12/22/97#

Page 14SE BY CAN 1190751-16-98: :20BARD 630.629. 2635-+ 540 977 9069:# 3/ 5 2013 IV. Health Fazard Information ROUTES AND METHODS OF ENTRY Inhalation: Suit r acid vapors or mist may cause sever respiratory ination. Lead dust or fumes may cause intorion of upper respiratory Sicin Contact: Sulfuric Acid may cause severe imitation, burns and ulceradon. Lead Compounds are not absorbed through the skin. Skin Absarption: Eye Contact: Sulfuric Acid is nor readily absorbed through the skin. Lead Compounds are not absorbed through the skin. sulley i apons or mist ran euse sever iritatian, bums, come damage and possible blindness. Lead Compounds may Ingestion: Sulfuric Acid may cause seveto irritation of mauth, throat, csophagus and stomach. Lead Compounds may cause abdominal pain, nausea, vomiting, diarrhea and severe cramping. Acute ingestion should be treated by physician. SIGNS AND SYMPTOMS OF OVEREXPOSURE Acuto Effects: Lead Compounds may cause abdominal pain, nausea, headaches, vomíing, diarhea, severe cramping and ditticulty in sleeping. Sulfuric Acid may cause severe skin irritation, bums, damage to come and possible blindness and upper respiratory irritation. Chronic Effocts: Sulfuric Acid may lead to scarring of the coraca, inflatamation of the ruse, throat and bronchial rubes and possible erosion of cooth -cad Compounds may cause anemia, damage to the kidneys and nervous system. May cause reproductive changes in bath males and females. POTENTIAL TO CAUSE CANCER cannot cause cancer. Lead has been reared for ability to cause cancer. The results showed that thero is insufficient evidence to show char lead can or EMERGENCY AND FIRST AID PROCEDURES Inhalation: Sulfuric Acid - Remove to fresh air immediately. If breathing is difficult, give oxygen. Skin: Lead Compounds - Remove fOm exposure; gangle, wash nose and eyes and consult physiolan. Sulfuric Acid - flush with large amounts of water for at least 15 minutes, remove any contaminared clothing and do not wear again until clesned. If acid is splashed on shoes, removo and discard if they contain leather. Lead Compounds nre not absorbed through' Sulfuric Acid - flush immediately with cool water for at least 15 minutes, then consult physician. Lead Compounds - flush immediately with cool water for at least 15 minues, then consult physician. Ingestion: Load Compounds - consult a physician. Sulfuric Acid - zive large quantities of water; DO NOT induce vamiting. then consult physician. 12/22/97 -#

Page 15-09/03/98 THU 10:59 FAX 5409775555 VFP, INC. 4014 SENT BY: GNB TECHNOLOGIES T/PC ; 1-16-98 ; 11:44 ¡LOMBARD 630. 629. 2635- 540 977 3069;# 4/ 5 V. Fire and Explosion Data Not applicablo. Flash Point: Flammable Limits: Lower 4.1% (Hydragen gus) Upper 74.1% Extinguishing Modia: COz; foam; dry chemical. Special Fire Fighting Procedures: If batteries on charge, turn off power. Usc positive pressuro, self-contained breathing apparatus. Water applied to eloctrolyro generates heat and causes it to splatter. Wear acid resistant clothing. Unusual Fire and Explosion Hazard: Hydrogen and Oxygen gasts are produced in the cells during normal banery operarion or when on charge (Hydrogon is highly keep sparks and other sources of ignition away from the battery. Do not allow metallic matorial to simultaneously contact both the farmable and Oxygen supports combustion). These gases enter the air through the vent caps. To avoid risk of fire or explosion, positive and negative terminal of batteries. Follow manufacturers' instructions for installation. VI. Reactivity Data Stability: Conditions to Avoid: • = Unstable • = Stable Sparks and other sources of ignition. Prolonged over charge. Incompatibility (Material to Avoid): Combination of sulfuric Acid with combustibles, and organic materials may oause fire and explasion. Also avoid strung reducing agchts, most metals, carbides, chlorates, mitratos, picrate. Lead Compound: Potassium, carbides, sulfides, pcroxides, phosphonis and sulfur. Hazardous Decoraposition Products: Hazardous Polymerization: Sulfuric Acid: Hydrogen sulfur dioxido, sulfur urioxide • = May Occur M= Will Not Occur and sulfuric acid mist. VII: Control Measures Engineering Controls: Store and bandle lead acid batteries in well ventilated areas. Make certain vent caps are on tightly. Place a minimum of two layers of cardboard between layers of batterics. Do not stack more Work Practices: batteries. Use a battery carrier to lift a battery or place hands at opposite corers to avoid spilling acid through tha veno. Avoid than three layers high. Do not allow motallic motorials to simultaneously contact boch the positive and negative carminals of the contact with intertal componeous of the batteries. PERSONAL PROTECTIVE EQUIPMENT Respiratory Protection: None are required under nonnal conditions. If concentrations of sulfuric acid mist are known to exceed PEL, use NIOSH or MSHA approved respiratory protection. Chemical splash goggles or face shield. Eyes and Face: Hands, Arm, Body: Rubber or plastic acid resistant gloyes with elbow length gauntler. Other Special Clothing and Equipment: Acid resistant apron. Under severe exposure or emergency conditions, wear acid resistant clothing and boots. 12/22/97#

Page 16•09/03/98 THU 10:59 FAX 5409775555 VFP. INC. 4015 SENT BY: ONB TECHNOLOGIES T/PC: 1-16-98; 11:45 :LOMBARD 690. 629. 2635~ 540 977 3069:# 5/ 5 Hygiene Practices: Wash hands thoroughly before eating, drinking or smoking after handling batteries. VIII. Safe Handling Precautions Protective Measures to be taken during non-routine tasks including equipment raintenance: Not applicable. SPILL OR LEAK PROCEDURES Remove combustible materials and all sources of ignition. Stop flow of material and contain spill by diking with soda ash (3od/um Protective measures to be taken if material is released or spilled: collect residue and place in a drum or other suitable container with a label specifying "contains hazardous waste" or (if uncertain carbonate) or quick lime (calcium oxide). Carefully neutralize spill with soda ash, etc. Make certain mixture is neutral then DO NOT RELEASE UNNEUTRALIZED ACID. Waste Disposal Methods: ulfuric Acid: Ncumalize as described aboye for a spill, collect residuc and place in a container labeled as containing hazardor aste, Dispose of as a hazardous waste. If uncertain about labeling procedures, call your local battery dirtributar or contact liste at beginning. DO NOT FLUSH LEAD CONTAMINATED ACID TO SEWER. Batteries: Send to load smelter following applicable federal, state and local regularions. IX Other REGULATORY INFORMATION: Flarumability (Red) = 0 NFPA Hazard rating for Sulfuric Acid: Health (Bluc) = 3 Reactivity (Yellow) = 2 Batteries, wet, non-spillable, Electric Storage US DOT identification and description for this battery is: 8, UN 2800, PG III, Label: Corrosive (Exceptions 173.159, paragraph (d), C.F.R 49) Fur air shipments, reference Internacional Air Transportation Associntion (LATA) Dangerous Goods Regulations Manual, refer to 8121, Amendment #27-94. special provisions A-48 and A-67. For ocean shipments, reference Interational Maritime Dangerous Gouds Regulations. Page a temperature of 55°C, the electrolyte will not flow from a ruprured or cracked case. The batteries have been protected against This is to certify that the "Non-Spillable" batteries are capable of withstanding the Vibration and Pressure Differential Test and at short circuits and securely packaged. The batteries and outer packeging must be plainly markcd "Non-Spillable" or "Non-Spillable Battery". If you have any questions, please conract che Environmental Assurance Depurtment of GNB Techhologies at 770-673-2470. Sulfuric Acid is water reactive if concentrated. Batteries are regulated under applicable US DOT, RCRA, CERCLA and EPCRA. The International Agency for Research on Cancer (LARC) has classified "strong inorganic acid mist containing sulfuric acid" as a acid or sulfuric acid solutions contained within a battery. Inorganic acid mist (sulfuric acid mist) is not generated under normal use Category 1 carcinogen, a substance that is carcinogenic to humans. This classification does not apply lo liquid forms of sulfuric of this producr. Misuse of the product, such as overcharging, may however result in the generation of sulfurio acid mist. A battery is manufactured using lead, CAS No. 7439-92-1 and sulfuric acid. CAS No. 7664-93-9 which are subject to the reparting requiremenes of EPCRA Section 313 (40 CFR 372). 12/22/97#