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ft E A ~ United States ,.,..,,.., Environmental Protectior , Agency Region 6 - Enforcement & Compliance Assurance Division INSPECTION REPORT Inspection Date(s): Media Program: Regulatory Program(s) 03/05/2026 RCRA Generator Company Name: Facility Name: Facility Physical Location: (city, state, zip code) Mailing address: (city, state, zip code) County/Parish: Facility Phone Number Facility Contact: Image Set Image Set 6611 Portwest Dr. Houston, TX, 77024 Same Same Harris (713) 869-7700 Rachel Shepherd I I Title: COO Email: rshepherd@imageset.com FRS Number: Identification/Permit Number: Media Identifier Number: NAICS: SIC: None TXR000085239 None None None Personnel participating in inspection: Bill Mansfield US EPA Region 6 Rachel Shepherd Image Set Jared Sande Image Set Inspector COO Operations Manager EPA Lead Inspector Signature/Date Supervisor Signature/Date WILLIAM MANSFIELD Date: 2026.04.16 08:04:30 -05'00' Digitally signed by WILLIAM MANSFIELD Bill Mansfield Date DEB RA PAN DA KDigitally signed by DEBRA PANDAK Date: 2026.04.16 08:14:21 -05'00' Debra Pandak Date 6ENFORM-019-R9 (02/27/2025) 1 Image Set 6611 Portwest Dr. Inspection Date 03/05/2026 Section I - INTRODUCTION PURPOSE OF THE INSPECTION I, Bill Mansfield, EPA Region 6 inspector arrived at Image Set at 9:04AM on 03/05/2026 for an announced inspection. I met with Rachel Shepherd the Corporate Operations Officer (COO) and Jared Sande the Operations Manager. I presented my credentials to Rachel and Jared, and informed them that this was an EPA inspection to determine the facility's compliance with the Resource Conservation and Recovery Act (RCRA). The scope of the inspection is a Compliance Evaluation Inspection (CEI) and includes evaluation of the facility's hazardous waste management activities. FACILITY DESCRIPTION Image Set's 6611 Portwest Dr location is a digital and commercial printing facility. The EPA ID TXR000085239 associated with the address of 6611 Portwest Dr was assigned to the facility by EPA in February of 2020 and indicates that Image Set is operating as a Very Small Quantity Generator (VSQG). Section II - OBSERVATIONS During the opening conference I requested hazardous waste determinations and the processes at the facility. The processes that generate waste are printing processes and come from the operation of two large commercial printing machines. Waste Imaging Oil Storage Area: In the waste imaging oil storage area, I observed three 55-gallon drums used for storing waste imaging oil (Appendix 1, Photo 1). Jared said they ship out the waste once or twice a year. I also observed an imaging oil washing station that is used to wash ink reservoirs used in the printing machine and, containers of partially used imaging oil that can still be used in the printing process (Appendix 1, Photos 2 and 3). Production Area: Walking in the first room of the production area I observed a large commercial HP printer. The printer uses imaging oil that is the main contributor to the facility's waste generated. Entering a second room in the production area, I observed a large commercial printing machine that applies a UV coating on prints. The excess UV material is discarded into five-gallon containers and accounts for the remaining waste generated at the facility (Appendix 1, Photo 4). Documents provided: The facility provided the following documents: 1) Waste management procedures 2) SDS for UV coating 3) SDS for Imaging Oil 2 Image Set 6611 Portwest Dr. Inspection Date 03/05/2026 Section III - AREAS OF CONCERN The closing meeting was attended by me, Bill Mansfield (EPA Inspector), Rachel Shepherd (COO) and Jared Sande (Operations Manager). During the closing conference, I fielded questions from facility personnel and provided information about the next steps in the inspection process. No areas of concern were observed during the inspection. Section IV - FOLLOW UP EPA is waiting for the following information requested from the facility. 1. Hazardous waste determinations for the two waste streams. Section V - LIST OF APPENDICES Appendix 1 - Photograph Log - 4 photos taken 03/05/2026 Appendix 2 - Documents provided on-site 03/05/2026 3 Image Set 6611 Portwest Dr. Inspection Date(s) 03/05/2026 Appendix 1 Photograph Log UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Appendix 1 Photo No. 1 Facility/Location: I Image Set 6611 Portwest Dr. City: Houston County: I Harris Filename: TWC_0871.JPG Photo Date: Photographer: Bill Mansfield I State: I TX 03/05/2026 I I Direction: I W Time: l 10:10:32 Witness Name: I NA Pka-,(: l..np lidfr. 1: lo\l.'cl at "" Ii,t~l' S. I I Description: Waste imagining oil storage areas. Three oil waste collection drums. Latitude: N/A Longitude: N/A UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Appendix 1 Facility/Location: Photo No. 2 Image Set 6611 Portwest Dr. City: Houston County: Harris Filename: TWC_0872.JPG Photo Date: Photographer: Bill Mansfield State: TX 03/05/2026 Witness Name: Direction: S Time: 10:10:40 NA Description: Imaging oil wash station. Latitude: N/A Longitude: N/A UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Appendix 1 Facility/Location: Photo No. 3 Image Set 6611 Portwest Dr. City: Houston County: Harris Filename: TWC_0873.JPG Photo Date: Photographer: Bill Mansfield State: TX 03/05/2026 Witness Name: Direction: E Time: 10:11:21 NA Description: Imaging oil that can still be used. Latitude: N/A Longitude: N/A UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Appendix 1 Facility/Location: Photo No. 4 Image Set 6611 Portwest Dr. City: Houston County: Harris Filename: TWC_0874.JPG Photo Date: Photographer: Bill Mansfield State: TX 03/05/2026 Witness Name: Direction: S Time: 10:15:09 NA Description: UV waste containers in Production Area. Latitude: N/A Longitude: N/A UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Documents provided on-site Appendix 2 Appendix 2 Documents provided on-site SAFETY DATA SHEET lj V COA I 11.Jtr TEC:: Lightirog, ln,c:,_ Version 1.1 Revision Date 06/15/2020 Print Date 11/17/2020 P332 + P313 If skin irritation occurs: Get medical advice/ attention. P337 + P313 If eye irritation persists: Get medical advice/ attention . P362 Take off contaminated cloth ing and wash before reuse. Other hazards The following percentage of the mixture consists of ingredient(s) with unknown acute toxicity: 65 % SECTION 3. COMPOSITION/INFORMATION ON INGREDIENTS Hazardous components Component CAS-No. Oligomer Acrylate Concentration(%) >= 10 - < 30 SECTION 4. FIRST AID MEASURES General advice Get medical attention immediately if symptoms occur. Treat symptomatically. If inhaled If inhaled, remove to fresh air. If breathing is difficult, give oxygen. Ifnot breathing, give artificial respiration. In case of skin contact Remove contaminated clothing. Wash thoroughly with soap and water for at least 20 min. or until material is removed. Wash contaminated clothing before re-use. Get medical attention if irritation develops and persists. In case of eye contact If easy to do, remove contact lens, if worn. Rinse immediately with plenty of water, also under the eyelids , for at least 15 minutes. Seek medical advice. If swallowed Do NOT induce vomiting. Gently wipe or rinse the inside of the mouth with water. Obtain medical attention . SECTION 5. FIREFIGHTING MEASURES Suitable extinguishing media Unsuitable extinguishing media ABC powder Carbon dioxide (CO2) Water SAFETY DATA SHEET Version 1.1 Specific hazards during firefighting Further information Special protective equipment for firefighters Revision Date 06/15/2020 Print Date 11/17/2020 Do not use a solid water stream as it may scatter and spread fire. Use water spray to cool unopened containers. In the event of fire, wear self-contained breathing apparatus. Use personal protective equipment. SECTION 6. ACCIDENTAL RELEASE MEASURES Personal precautions, Ensure adequate ventllatlon. protective equipment and Use personal protective equipment. emergency procedures Environmental precautions Methods and materials for containment and cleaning up Prevent spilled material from entering the ground, water and/or air by using appropriate containment methods. Soak up with inert absorbent material. SECTION 7. HANDLING AND STORAGE Advice on safe handling Use only in accordance with our recommendations. Conditions for safe storage Keep container tightly closed in a dry and well-ventilated _place. Materials to avoid Keep away from oxidising agents and strongly acid or alkaline materials . SECTION 8. EXPOSURE CONTROLS/PERSONAL PROTECTION Components with workplace control parameters Contains no substances with occupational exposure limit values. Engineering measures Handle only in a place equipped with local exhaust (or other appropriate exhaust). Personal protective equipment Hand protection Material Eye protection Impervious gloves Safety glasses with side-shields Safety goggles SAFETY DATA SHEET Version#: 22 Issue date : 18-Jul-2014 Revision date: 23-Jun-2023 Supersedes date: 23-Jun-2023 SECTION 1: Identification of the substance/mixture and of the company/undertaking Important information *** This Safety Data Sheet is only authorised for use by HP for HP Original products. Any unauthorised use of this Safety Data Sheet is strictly prohibited and may result in legal action being taken by HP. *** 1.1. Product identifier Trade name or designation of the mixture HP Indigo Imaging Oil or use with HP Indigo Digital Press WS6000 series , Vl/7200 series , 7000 enes an 000 Q4345A Registration number UFI: 761 E-FV5M-830J-0WFM Synonyms Part Number Q4345A 1.2. Relevant identified uses of the substance or mixture and uses advised against Identified uses HP product for use with HP Indigo Digital Presses WS6000 series, Vl/7200 series , 7000 series and 8000. Uses advised against None known . 1.3. Details of the supplier of the safety data sheet HP Belgium BVBA Hermeslaan 1B, Floor B1 Diegem Telephone Belgium 1831 +32 2 620 1600 HP Inc. health effects line (Toll-free within the US} (Direct} HP Inc. Customer Care Line (Toll-free within the US} (Direct} Email: 1.4 Emergency telephone number 1-800-457-4209 1-760-710-0048 1-800-474-6836 1-208-323-2551 sustainability@hp.com +32 070 245 245 SECTION 2: Hazards identification 2.1 . Classification of the substance or mixture Classification accord in g to Regulation (EC} No 1272/2008 as amended Health hazards Aspiration hazard Category 1 2.2. Label elements Label according to Regulation (EC} No. 1272/2008 as amended Contains: Alkanes C11 -15 iso , White Mineral Oil Hazard pictograms H304 - May be fatal if swallowed and enters airways. Signal word Danger Material name: Q4345A 13479 Version#: 22 Re vision date : 23-Jun-2023 Issue date: 18-Jul-2014 SDS BELGIUM 1/ 8 Hazard statements H304 Precautionary statements Prevention P210 P280 Response P301 + P330 + P331 P301 + P310 Storage P405 May be fatal if swallowed and enters airways. Keep away from heat/sparks/open flames/hot surfaces. - No smoking . Wear personal protective equipment/face protection. If swallowed: Rinse mouth. Do NOT induce vomiting. If swallowed: Immediately call a poison center/doctor. Store locked up. Disposal P501 Supplemental label information 2.3. Other hazards Dispose of contents/container in accordance with local/regional/national/international regulations . EUH066 - Repeated exposure may cause skin dryness or cracking. Endocrine disrupting properties (Toxicity/Ecotoxicity): This mixture does not contain substances considered to have endocrine disrupting properties according to REACH Article 57(f) or Commission Delegated regulation (EU) 2017/2100 or Commission Regulation (EU) 2018/605 at levels of 0.1 % or higher. SECTION 3: Composition/information on ingredients 3.2. Mixtures General information Chemical name % CAS-No. / EC No. Alkanes C11-15 iso <100 90622-58-5 920-901-0 Classification: Asp. Tox. 1;H304 Supplemental Hazard EUH066 Statement(s}: REACH Registration No. 01-2119456810-40-XXXX Index No. Notes White Mineral Oil <1 8042-47-5 232-455-8 Classification: Asp. Tox. 1;H304 SECTION 4: First aid measures General information Not available. 4.1. Description of first aid measures Inhalation If overcome by vapor, remove person from exposure to fresh air. If breathing is difficult, give oxygen. If symptoms persist, get medical attention. Skin contact Wash affected areas thoroughly with mild soap and water. Immediately take off all contaminated clothing. Wash clothing separately before reuse . Get medical attention if irritation develops or persists. Eye contact Do not rub eyes. Immediately flush with large amounts of clean , warm water (low pressure) for at least 15 minutes or until particles are removed. If irritation persists get medical attention. Do not apply neutralizing agents. Ingestion Do not induce vomiting . Never give anything by mouth to an unconscious person. If ingestion of a large amount does occur, seek medical attention. 4.2. Most important symptoms and effects, both acute and delayed Not available. 4.3. Indication of any immediate medical attention and special treatment needed Not available. SECTION 5: Firefighting measures General fire hazards Not available. 5.1. Extinguishing media Suitable extinguishing media Suitable extinguishing media: Dry chemical, CO2 , water spray or regular foam. Unsuitable extinguishing media None known . Material name : Q4345A 13479 Version#: 22 Revision date: 23-Jun-2023 Issue date: 18-Jul-2014 SDS BELGIUM 2 / 8 5.2. Special hazards arising from the substance or mixture 5.3. Advice for firefighters Special protective equipment for firefighters Special fire fighting procedures None known. Not available. Move containers from fire area if you can do it without risk. Evacuate area and fight fire from a safe distance. SECTION 6: Accidental release measures 6.1. Personal precautions, protective equipment and emergency procedures For non-emergency personnel Wear appropriate personal protective equipment. For emergency responders Not available. 6.2 . Environmental precautions Do not let product enter drains. Do not flush into surface water or sanitary sewer system . 6.3. Methods and material for containment and cleaning up Not available. 6.4. Reference to other sections See Section 8 of the SOS for Personal Protective Equipment. SECTION 7: Handling and storage 7.1. Precautions for safe handling Avoid prolonged or repeated skin contact with this material. Avoid contact with skin , eyes and clothing . Keep away from open flames, hot surfaces and sources of ignition. Do not reuse the empty container. Take precautionary measures against static discharges . 7.2. Conditions for safe storage, including any incompatibilities 7.3. Specific end use(s) Keep away from excessive heat or cold. Store in a cool and shaded area. Do not store in direct sunlight. Not available. SECTION 8: Exposure controls/personal protection 8.1. Control parameters Occupational exposure limits Biological limit values Recommended monitoring procedures No exposure limits noted for ingredient(s) . No biological exposure limits noted for the ingredient(s). Not available . Derived no effect levels (ONE Ls) Not available. Predicted no effect concentrations (PNECs) Exposure guidelines 8.2. Exposure controls Appropriate engineering controls Not available. Manufacturer recommended exposure limit based on petroleum hydrocarbon at> 95% . TWA= 171 ppm (1200 mg/m3). Use in a well ventilated area. Individual protection measures , such as personal protective equipment General information Use personal protecti ve equipment to minimize exposure to skin and eye . Eye/face protection Not available . Skin protection - Hand protection Wear Latex-free 100% nitrile , minimum 0 .38 mm thick, powder free gloves. - Other Chemical resistant gloves. Respiratory protection Thermal hazards Hygiene measures Not available. Not available. Handle in accordance with good industrial hygiene and safety practice. Environmental exposure controls Use personal protective equipment to minimize exposure to skin and eye . Not available. SECTION 9: Physical and chemical properties 9.1. Information on basic physical and chemical properties Physical state Liquid. Material name: Q4345A 13479 Version#: 22 Revision date : 23-Jun-2023 Issue date: 18-Jul-2014 SDS BELGIUM 3 / 8 Form Liquid . Color Colorless . Odor mild hydrocarbon-like Melting point/freezing point Not available. Boiling point or initial boiling point and boiling range 370.4 F (188 C) (based on petroleum hydrocarbon) Flammability Not ava ilable . Flash point 147.2 F (64.0 C) Pensky-Martens Closed Cup (based on Petrol eum Hydrocarbon) Auto-ignition temperature Not available. Decomposition temperature Not available . pH Not available . Kinematic viscosity Not available . Solubility Solubility (water) Not soluble Partition coefficient (n-octanol/water) (log value) Not available. Vapor pressure Not available. Density and/or relative density Density 0.77 g/cm3 Relative density 0.771 g/c m3 Relative vapor density Not avail able. Particle characteristics Not available . Explosive properties Not available. Oxidizing properties Not applicable . 9.2. Other information 9.2.1. Information with regard to physical hazard classes No relevant additional information available. 9.2.2 . Other safety characteristics Specific gravity 0.771 voe 770 g/L (6.3 4 lbs/gal.US) (Ca lculated ) 9.2. Other information Density 0.77 g/cm3 SECTION 10: Stability and reactivity 10.1. Reactivity Not available. 10.2. Chemical stability Stable under recommended storage conditions. 10.3. Possibility of hazardous reactions Will not occur. 10.4. Conditions to avoid Not available . 10.5. Incompatible materials This product may react with strong oxidizing agents . 10.6. Hazardous decomposition products Upon decomposition , this product emits carbon monoxide , carbon dioxide and/or low molecular we ight hydrocarbons. SECTION 11: Toxicological information General information Refer to Section 2 for potential health effects and Section 4 for first aid measures. Information on likely routes of exposure Inhalation Under normal conditions of intended use, this material is not expecte d to be an inhalation hazard . Skin contact Contact with skin may result in mild irritation. Eye contact Contact with eyes may result in mild irritation. Ingestion Health injuries are not known or exp ected under normal use . Ingestion is not a likely route of exposure . Symptoms Not available. 11.1. Information on hazard classes as defined in Regulation (EC) No 1272/2008 Acute toxicity Harmful if swallowed . Materia l na me: 04345A 13479 Versio n#: 22 Re vision date: 23-J un-2023 Issue date: 18-Jul-2014 SOS BELGIUM 4/8 Components White Mineral Oil (CAS 8042-47-5) Acute Dermal LD50 Oral LD50 Species Rat Rat Test Results >= 5000 mg/kg >= 5000 mg/kg Skin corrosion/irritation Serious eye damage/eye irritation Respiratory sensitization Skin sensitization Germ cell mutagenicity Carcinogenicity Reproductive toxicity Specific target organ toxicity single exposure Not classified. Not classified. Not classified. Mildly irritating to the skin with prolonged exposure. Not classified. Not classified. Not classified. Not classified. Specific target organ toxicity repeated exposure Not classified. Aspiration hazard May be harmful if swallowed and enters airways. Mixture versus substance information Not available. 11.2. Information on other hazards Endocrine disrupting properties (Toxicity): This mixture does not contain substances considered to have endocrine disrupting properties according to REACH Article 57(f) or Commission Delegated regulation (EU) 2017/2100 or Commission Regulation (EU) 2018/605 at levels of 0.1 % or higher. Other information No data is available on the product itself. SECTION 12: Ecological information 12.1. Toxicity No toxicity data noted for the ingredient(s). Aquatic toxicity This product has not been tested for ecological effects. 12.2. Persistence and degradability 12.3. Bioaccumulative potential Partition coefficient n-octanol/water (log Kow} Bioconcentration factor (BCF} 12.4. Mobility in soil 12.5. Results of PBT and vPvB assessment 12.6. Endocrine disrupting properties 12.7. Other adverse effects Not available. Not available. Not available. Not available. Not available. Not a PBT or vPvB substance or mixture. (Ecotoxicity): This mixture does not contain substances considered to have endocrine disrupting properties according to REACH Article 57(f) or Commission Delegated regulation (EU) 2017/21 00 or Commission Regulation (EU) 2018/605 at levels of 0.1 % or higher. Not available. SECTION 13: Disposal considerations 13.1. Waste treatment methods Residual waste Contaminated packaging Not available. Do not re-use empty containers. Empty containers should be taken to an approved waste handling site for recycling or disposal. EU waste code Disposal methods/information 08 03 13 - waste ink other than those mentioned in 08 03 12 Do not dispose of together with general office waste . Do not allow this material to drain into sewers/water supplies. Dispose of waste material according to Local, State , Federal, and Provincial Environmental Regulations. Ensure collection and disposal w ith an appropriately licensed waste contractor. Material name: Q4345A 13479 Version#: 22 Re vision date: 23-Jun-2023 Issue date: 18-Jul-2014 SOS BELGIUM 5 / 8 SECTION 14: Transport information ADR 14.1. UN number Not regulated as dangerous goods. 14.2. UN proper shipping Not Regulated. name 14.3. Transport hazard class(es} Class Subsidiary risk Hazard No. (ADR} Tunnel restriction code 14.4. Packing group 14.5. Environmental hazards 14.6. Special precautions for user IATA Not assigned. Not assigned. Not assigned. Not assigned. No. Not assigned . 14.1. UN number Not regulated as dangerous goods. 14.2. UN proper shipping Not Regulated . name 14.3. Transport hazard class(es} Class Subsidiary risk 14.4. Packing group 14.5. Environmental hazards 14.6. Special precautions for user IMDG Not assigned. Not assigned . No. Not assigned. 14.1. UN number Not regulated as dangerous goods. 14.2. UN proper shipping Not Regulated. name 14.3. Transport hazard class(es} Class Subsidiary risk 14.4. Packing group 14.5. Environmental hazards Not assigned. Not assigned . Marine pollutant Ems 14.6. Special precautions for user 14.7. Maritime transport in bulk according to IMO instruments No. Not assigned . Not assigned . Not available. Further information Transport in bulk according to Annex II of MARPOL73/78 and the IBC code: Not applicable. Not a dangerous good under DOT, IATA, ADR , IMDG, or RID . SECTION 15: Regulatory information 15 .1. Safety, health and environmental regulations/legislation specific for the substance or mixture EU regulations Regulation (EC} No. 1005/2009 on substances that deplete the ozone layer, Annex I and II, as amended Not listed. Regulation (EU) 2019/1021 On persistent organic pollutants (recast), as amended Not listed. Regulation (EU) No. 649/2012 concerning the export and import of dangerous chemicals, Annex I, Part 1 as amended Not listed. Regulation (EU) No. 649/2012 concerning the export and import of dangerous chemicals, Annex I, Part 2 as amended Not listed. Regulation (EU) No. 649/2012 concerning the export and import of dangerous chemicals, Annex I, Part 3 as amended Not listed. Regulation (EU) No. 649/2012 concerning the export and import of dangerous chemicals , Annex Vas amended Not listed. Regulation (EC) No. 166/2006 Annex II Pollutant Release and Transfer Registry, as amended Not listed. Regulation (EC) No. 1907/2006, REACH Article 59(10) Candidate List as currently published by ECHA Not listed. Material name: Q4345A 13479 Version#: 22 Revision date: 23-Jun-2023 Issue date: 18-Jul-2014 SOS BELGIUM 6/8 Authorizations Regulation (EC) No. 1907/2006, REACH Annex XIV Substances subject to authorization, as amended Not listed. Restrictions on use Regulation (EC) No. 1907/2006, REACH Annex XVII Substances subject to restriction on marketing and use as amended Not listed. Directive 2004/37/EC: on the protection of workers from the risks related to exposure to carcinogens and mutagens at work, as amended Not listed. Other EU regulations Directive 2012/18/EU on major accident hazards involving dangerous substances, as amended Not listed. Other regulations HP complies with chemical regulatory requirements in chemical substance notification laws, where applicable. All chemical substances are notified or exempt from notification or listed in the inventory as existing substances in the following countries: US (TSCA), Canada (DSUNDSL), Australia (AICIS), Japan (ISHL, ENCS), Philippines (PICCS), New Zealand (NZloC) and China (IECSC). For guidance on importation and/or additional requirements for registration schemes such as EAEU , EU, South Korea , Turkey, UK, India and Taiwan , please contact the Sustainability and Compliance Center (sustainability@hp.com). Other information This Safety Data Sheet complies with the requirements of Regulation (EU) 2015/830. Classification according to Regulation (EC) No 1272/2008 as amended . National regulations 15.2. Chemical safety assessment Not available. See attached SUMI or GEIS document, if applicable. SECTION 16: Other information References Regulation (EC) No. 1907/2006 of December 18, 2006 concerning the Registration , Evaluation , Authorization and Restriction of Chemicals (REACH) and establishing a European Chemicals Agency (REACH). Regulation (EC) No. 1272/2008 of December 16, 2008 on classification , labeling and packaging of substances and mixtures, and amendments (CLP). The information in this document is based on the present state of our knowledge , including but not limited to the data present in the registrations of the ingredients, it does not purport to be all-inclusive and shall be used only as a guide. Information on evaluation method leading to the classification of mixture Full text of any statements, which are not written out in full under sections 2 to 15 Revision information Training information Disclaimer This Safety Data Sheet is in compliance with Commission Regulation (EU ) 2020/878 of 18 June 2020 amending REACH Annex II . The classification for health and environmental hazards is derived by a combination of calculation methods and test data , if available . H304 May be fatal if swallowed and enters airways. None . Follow training instructions when handling this material. This Safety Data Sheet document is provided without charge to customers of HP. Data is the most current known to HP at the time of preparation of this document and is believed to be accurate. It should not be construed as guaranteeing specific properties of the products as described or suitability for a particular application . This document was prepared to the requirements of the jurisdiction specified in Section 1 above and may not meet regulatory requirements in other countries. Material name : Q4345A 13479 Version#: 22 Re vision date : 23-Jun-2023 Issue date : 18-Jul-2014 SDS BELGIUM 7/8 Explanation of abbreviations ACGIH Acute Tox. Aquatic Acute Aquatic Chronic Asp. Tox. Care. GAS CERCLA CFR COG DOT EPCRA Eye Dam. Eye lrrit Flam. Liq. Flam. Sol. Lact. Muta. IARC NIOSH NTP OSHA Ox. Liq. Ozone PEL Press. Gas RCRA REC REL Repr. Resp. Sens. SARA Skin Corr. Skin lrrit. Skin Sens. STEL STOT RE STOT SE TCLP TLV TSCA American Conference of Governmental Industrial Hygienists Acute toxicity Short-term (acute) aquatic hazard Long-term (chronic) aquatic hazard Aspiration hazard Carcinogenicity Chemical Abstracts Service Comprehensive Environmental Response Compensation and Liability Act Code of Federal Regulations Cleveland Open Cup Department of Transportation Emergency Planning and Community Right-to-Know Act (aka SARA) Serious eye damage Eye Irritation Flammable liquids Flammable solids Effects on or via lactation Germ cell mutagenicity International Agency for Research on Cancer National Institute for Occupational Safety and Health National To xicology Program Occupational Safety and Health Administration Oxidisi ng liquids Hazardous to the ozone layer Permissible Exposure Limit Gases under pressure Resource Conservation and Recovery Act Recommended Recommended Exposure Limit Reproductive toxicity Respiratory sensitization Superfund Amendments and Reauthorization Act of 1986 Skin corrosion Skin irritation Skin sensitization Short-Term Exposure Limit Specific target organ toxicity - repeated exposure Specific target organ toxicity - single exposure Toxicity Characteristics Leaching Procedure Threshold Limit Value Toxic Substances Control Act Material name: Q4345A 13479 Version#: 22 Re vision date : 23-Jun-2023 Issue date: 18-Jul-2014 SOS BELGIUM 8/ 8 Waste Management Procedure ImageSet Purpose The procedures outlined in this document ensures that facility's waste is characterized, labeled and shipped according to State and Federal regulations. Things You Should Know Wastes that exhibit certain characteristics such as flammability, corrosivity, reactivity, or TCLP Toxicity are classified as hazardous . Wastes that contain certain chemicals, some in specified concentrations, are classified as hazardous. Certain hazardous wastes such as batteries and mercury containing bulbs and thermostats that are reclaimed are classified as Universal Wastes and do not have to be handled and disposed as a Hazardous Waste. Waste oil in the State of Texas is classified as non-hazardous waste. Waste that is stored in containers (typically 55-gallon drums) are: Imaging Oil Typical Hazardous Wastes Generated None Codes Typical Nonhazardous Wastes Generated Imaging Oil - Non-regulated liquid Codes No Code Waste Characterization Stage 1 Description Determine the type of waste: EPA Hazardous Waste Texas Regulated Hazardous Waste Universal Waste Non-hazardous Waste Responsibility Executive Management Rev date 2/0 I/20 Waste Management Procedure ImageSet 2 To determine if the waste is hazardous refer to Executive the list of typical hazardous wastes in the "Things Management You Should Know" section above. If the waste is not listed follow one of the following methods: Is it listed in the regulations (310 CMR 30.131) Does it exhibit a hazardous characteristic: Ignitable - Easily catches fire, flash point at or Below 140 F Corrosive - Very acidic or alkaline, pH below 2 or greater than 12.5 Reactive - Explosive, produces toxic gases When mixed with water or acid Toxic - Leaches toxic chemicals as determined by TCLP laboratory test For more information, refer to the attached Hazardous Waste Identification Flowchart 3 To determine if the waste is a Universal Waste, Executive refer to the following list if Universal Wastes: Management Batteries Pesticides Mercury Thermostats (non-leaking) Mercury-containing devices (non-leaking) Mercury-containing lamps (non-leaking) 4 Wastes that do not meet the definition of Executive Hazardous or Universal are not regulated. Refer Management to the list of typical non-hazardous wastes listed in the "Things You Should Know" section above. Drum and Container Selection Stage 1 2 ,., .) Description Empty containers: Confirm empty per 310 CMR 30.010 (See Attached Definition) Empty drums are stored room in the waste storage room. Plastic Drums, if free from any residue, can be used as trash barrels. Drums and other containers used for waste accumulation are to be drawn from empty input material drums and containers. Verify that the container is empty, clean, and in good condition prior to using for waste storage. Responsibility Pressroom Supervisor Pressroom Supervisor Pressroom Supervisor Rev date 2/01/20 Waste Management Procedure ImageSet 4 Verify that the waste is compatible with the Pressroom container's material of construction. Current Supervisor wastes are all stored in metal containers but, as a rule, corrosive materials are stored in plastic containers. 5 All containers used for waste storage must have Pressroom lids that fit securely. Supervisor 6 Remove existing product labels and apply Pressroom appropriate waste label (see below) provided by Supervisor Safety-Kleen, the waste disposal company. Waste Container Labeling Stage 1 2 ') .) Description Containers should be labeled prior to accumulating any waste. Label non-hazardous wastes with an appropriate nonhazardous waste label. Label should be dated on the day that the waste is first added to the container. Drum labels are located in a plastic sleeve by the drums. Responsibility Pressroom Supervisor Pressroom Supervisor Pressroom Supervisor Waste Container Storage Stage 1 2 ') .) 4 5 6 Description Verify that container is sealed at all times during waste storage unless draining or filling. Verify that the top of the container is completely free of debris and waste materials. For liquid waste containers, verify that the top of the container has an absorbent pad to collect spilled waste material. Containers are to be inspected weekly according to the Facility Inspections SOP. Transport containers using proper container handling equipment. Send container off site for proper disposal using an approved disposal vendor (Safety-Kleen) Responsibility Pressroom Supervisor Pressroom Supervisor Pressroom Supervisor Pressroom Supervisor Pressroom Supervisor Pressroom Supervisor Rev date 2/0 I/20 Waste Management Procedure ImageSet Manifesting Stage 1 2 ,.., .) 4 Description All non-hazardous waste sent off-site must be accompanied by a manifest and signed by a member of Executive Management. The Non-Hazardous Waste Manifest will be completed by Safety-Kleen and brought when picking up the waste. The generator copy, and return copy of the manifest, and any other accompany forms from the disposal company (Safety-Kleen) must be kept on file in the Accounting Office. Executive Management must receive the TSDFreturned copy of the manifest (Copy 1) from the disposal facility within 35 days. If the return copy is not received, the TSDF (disposal) facility must be contacted. Responsibility Executive Management Executive Management Executive Management Executive Management Supporting Documents Hazardous Waste Identification Flowchart NOTE: ImageSet does not currently generate hazardous waste. This flowchart, along with the Safety Data Sheet of the product, can be used when assessing any new waste stream generated by the company. Imaging Oil SDS Waste Profile for Imaging Oil Rev date 2/01 /20 Waste Management Procedure ImageSet EMPTY CONTAINER DEFINITION (a) A container or an inner liner removed from a lined container that has held any hazardous material or hazardous waste, except a waste that is a compressed gas or that is listed in 310 CMR 30.136, is empty if: 1. all wastes have been removed that can be removed using the practices commonly employed to remove materials from that type of container, e.g., pouring, pumping, and aspirating; and 2. no more than 2.5 centimeters (one inch) ofresidue remain on the bottom of the container or inner liner. (b) A container that has held a hazardous material or hazardous waste that is a compressed gas is empty when the pressure in the container is substantially at atmospheric pressure. ~Cc) A container or inner liner removed from a lined container that has held a hazardous waste identified in 310 CMR 30.136 is empty if: 1. the container or inner liner has been triple rinsed using a solvent capable of removing the commercial chemical product or manufacturing intermediate; or 2. the container or inner liner has been cleaned by another method that has been shown in the scientific literature, or by tests conducted by the person doing the cleaning, to achieve equivalent removal; or, 3. in the case of a lined container, the liner that prevented contact of the commercial chemical product or manufacturing intermediate with the container has been removed. 4. in the case of a container having held acutely hazardous wastes, the container is labeled "safe for disposal", "triple rinsed", or "processed to meet the definition of empty," once the container is empty as defined within the definition of empty container. (d) A paper bag which: 1. has contained a hazardous material or a hazardous waste, except for a waste listed in 310 CMR 30.136, is empty if all wastes have been removed that can be removed by shaking or using equivalent means to ensure that all wastes have been removed to the extent feasible. 2. has contained a hazardous material or a hazardous waste listed in 310 CMR 30.136 shall never be deemed an "empty container". Rev date 2/01 /20 Waste Management Procedure ImageSet Hazardous Waste Identification Procedure Yes Is the waste excluded? The waste is a used material (spent) The waste is an unused material Is the waste described on the FList or the K- List? No Yes Yes l l EPA Listed Hazardous Waste Is the waste described on the UList or the P-List No Is the waste ignitable, D001 Is the waste corrosive, D002 Is the waste reactive, D003 Is the waste TCLP Toxic, D004 - D043 Yes l Yes EPA Characteristic Hazardous Waste (Use all applicable Dnumbers) Yes Yes No Is the waste a Texas regulated hazardous waste? Yes State Regulated Hazardous Waste Rev date 2/01 /20 Imaging Oil Waste Safety-Kleen is the service that picks up imaging oil waste from our HP Indigo press. Their number is 281-208-6500 Our customer number is IM12291 All barrels that contain the imaging oil waste must have a green Non-Hazardous sticker affixed to them. It should be filled out with our company information and the contents of the barrel (imaging oil). The label should also include the date that we started filling the barrel. When the barrels are picked up, the driver will leave a copy of the Non-Hazardous Waste Manifest completed by Safety-Kleen . The driver and an approved lmageSet employee will sign the manifest. Inspect the manifest to make sure there is a "no classification " code (NOS). Rachel, Mitch and Daileon are approved to accept the manifest. Later we will be mailed a copy of the manifest indicating that the waste has been properly disposed of. Accounting will store both copies of the manifest. An inspection of the disposal containers should be made weekly by a press operator. A form is posted in the room where the barrels are stored.