Document GN9XMpBvJ3RyBvB1773nVQ84

f t E A ~ United States ..~ . Environmental Protection ~, Agency EPA REGION 6 Enforcement Division INSPECTION REPORT Inspection Entry 4/24/2025 09:30 AM (CT) Date/Time Inspection Exit Date/Time 4/24/2025 10:48 AM (CT) Regulatory Program Type of Inspection RCRA Compliance Evaluation Inspection (CEI) Announced: No (tenants and related facilities) Access: Granted Facility or Site Name Facility/Site Identifier Facility/Site Physical Address City, State, Zip Code County/Borough Generator Status NAICS Type of Operation Geographic Coordinates BWC Harvey, LLC LAD043426006 1805 4th St. Harvey, LA 70058 Jefferson Large Quantity Generator (LQG) 493190 BWC Harvey, LLC (BWC) is a bulk liquid storage terminal where barges, vessels, trucks, and railcars transport products in and out of the facility. 29.9089, -90.0786 Additional Persons Participating in Inspection: Name Title Organization Email Sandesh Thapa Inspector EPA REGION 6 Thapa.Sandesh@epa.gov Joseph Watson Contractor Eastern Research Joe.Watson@erg.com Group (ERG) Lead Inspector: Vince Damiano ERG Vincent Damiano Digitally signed by Vincent Damiano Date: 2025.06.06 15:26:30 -04'00' Vince.Damiano@erg.com I Page 1 of 4 BWC Harvey, LLC Inspection Date: 4/25/2025 SECTION I - INTRODUCTION Site Entry and Purpose of the Inspection The Port of New Orleans and surrounding facilities were selected for inspection based on a Regional initiative to evaluate facilities at ports receiving or transporting Resource Conservation and Recovery Act (RCRA)-regulated hazardous wastes, and/or have an International Convention for the Prevention of Pollution from Ships (MARPOL) Annex V Certificate of Adequacy (COA) issued by the U.S. Coast Guard (USCG). This report is based on information supplied by the facility representatives, inspector observations, portrelated facilities, and other records, including photographs taken, verbal or written statements made during or after the on-site inspection, and/or materials shown, demonstrated, or submitted to the Environmental Protection Agency (EPA) during or after the on-site inspection. In addition, information gathered prior to or after the inspection from a review of EPA, State, and public records may be included in this report. Attendees Title/Organization Lead Inspector/ Contractor/ERG Inspector/Enforcement Officer/EPA Region 6 RCRA Inspector/ Contractor/ERG HSEQ Manager/BWC Operations Manager/BWC Name Vince Damiano Sandesh Thapa Joseph Watson Walter Pertuit Josh Chapman Email Vince.Damiano@erg.com Thapa.Sandesh@epa.gov Joe.Watson@erg.com Wpertuit@bwcterminals.com Jchapman@bwcterminals.com Opening Closing Conf. Conf. Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Page 2 of 4 BWC Harvey, LLC Inspection Date: 4/25/2025 Facility General Description Tenant/Area BWC Harvey, LLC Inspection Date Process Description 4/24/25 BWC is a bulk liquid storage terminal where barges, vessels, trucks, and railcars transport products in and out of the facility. Area of Concern Yes SECTION II - OBSERVATIONS Facility: BWC Harvey, LLC Section: 2.1 Date: 4/24/25, 09:30 AM Contains AOC: Yes Contains CBI: No I I Lead Inspector: Vince Damiano Attendees: Walter Pertuit (HSEQ Manager) and Josh Chapman (Operations Manager) BWC is located in Harvey, LA, and operates as a bulk liquid storage terminal on the Mississippi River. The facility stores and handles products such as asphalt, caustic soda, vacuum gas oil, vegetable oils, specialty chemicals, and distillates. BWC has 53 storage tanks ranging in capacity from 1,500 barrels to 100,000 barrels. BWC can load and unload products via trucks, railcars, and marine barges at its two dock berths. The facility also performs tank-to-tank transfers as needed. Tank cleaning and maintenance activities, such as painting, are conducted by third-party contractors who are responsible for managing any waste generated from those operations. According to Mr. Chapman, no waste is allowed to be transferred across the dock space. BWC is registered with the EPA as a LQG of hazardous waste under EPA ID LAD043426006. After the opening conference, the inspection team observed BWC's hazardous waste accumulation area and the dock space. In the hazardous waste accumulation area, the inspection team observed a full 55-gallon drum labeled as EDTA Tetrasodium (see Appendix 1 - Photo 1). The facility representatives were not sure if this was considered a waste or a product at the time of the inspection [AOC #1 - BWC did not make a waste determination - 40 CFR 262.11]. Next, the inspection team observed a half-full 55-gallon drum of waste paint, simply labeled as "PAINT" with a facility identification number. At the time of the inspection, the facility representatives did not know if the waste was classified as hazardous or non-hazardous (see Appendix 1 - Photo 2) [AOC #1]. The inspection team also observed two full 55-gallon drums labeled as caustic, but the facility representatives were uncertain if these drums were considered waste or product at the time of the inspection (see Appendix 1 - Photos 3 and 4) [AOC #1]. The inspection team observed a half-full 55-gallon drum labeled as Morlife 5000, an amine product. The facility representatives were uncertain on the status of the material in the drum (see Appendix 1 - Photo 5) [AOC #1]. Next, the inspection team observed two full 55gallon drums storing non-hazardous asphalt from a cleanup (see Appendix 1 - Photos 6 and 7). The inspection team then observed the dock space. No areas of concern (AOCs) were noted at the dock. The inspection team did not observe other AOCs at the time of the inspection. However, further EPA review may change or add to their potential AOCs. A closing conference was conducted at approximately 11:30 AM with BWC personnel. The AOCs were communicated during the closing. Following the inspection on 4/29/2025, Mr. Dustin Scheidt sent a follow-up email in response to the AOCs observed during the inspection, including: An SDS of the latex paint and a waste determination of non-hazardous for the paint drum (Appendix Page 3 of 4 BWC Harvey, LLC Inspection Date: 4/25/2025 2). The tetrasodium drum will be picked up for reuse by the chemical supplier; see the SDS in Appendix 3. The Morlife 5000 drum is non-hazardous and is 99% water; an SDS of the raw material was included (Appendix 4). The drums labeled as caustic will be reused as a product in the process and added back into caustic storage tanks once sampled for quality (Appendix 5). Photos of updated labels and organization were included in the full email response (Appendix 6). SECTION III - RECORDS REVIEW No RCRA-regulated records were reviewed during this focused onsite inspection. SECTION IV - AREAS OF CONCERN The presentation of Area(s) of Concern does not constitute a formal compliance determination or violation. Facility: BWC Harvey, LLC AOC #1 - BWC did not make a waste determination. Citation: 40 CFR 262.11 Section: 2.1 SECTION V - FOLLOW UP Any facility follow-up items are as discussed in the observations in Section II. Documents or files provided by the facility were transmitted via email and included responses to AOCs or provision of documents requested. Communication Log During and after the inspection, additional information was emailed to EPA including: 1. 4/29/25 BWC email - Mr. Dustin Scheidt provided the inspection team with photos and waste determinations. SECTION VI - LIST OF APPENDICES Appendix 1. Photograph Log Appendix 2. Latex Paint SDS Appendix 3. Tetrasodium SDS Appendix 4. Morlife 5000 SDS Appendix 5. Caustic SDS Appendix 6. BWC Harvey 4/29/2025 Response Page 4 of 4 APPENDIX 1. PHOTOGRAPH LOG UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: BWC Harvey, LLC City: Harvey County/Parish: Jefferson State: Louisiana Photo No. 1 Photo File Name: DSCN7974 Date of Photo: 4/24/2025 Time of Photo: 1005 hrs. Photographer: Vince Damiano Description: View of full 55-gallon drum of tetrasodium found in the hazardous waste storage area. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: BWC Harvey, LLC City: Harvey County/Parish: Jefferson State: Louisiana Photo No. 2 Photo File Name: DSCN7975 Date of Photo: 4/24/2025 Time of Photo: 1007 hrs. Photographer: Vince Damiano Description: View of a half-full 55-gallon drum of waste paint found in the hazardous waste storage area. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: BWC Harvey, LLC City: Harvey County/Parish: Jefferson State: Louisiana Photo No. 3 Photo File Name: DSCN7976 Date of Photo: 4/24/2025 Time of Photo: 1008 hrs. Photographer: Vince Damiano Description: View of two full 55-gallon drums of caustic material found inside the hazardous waste storage area. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: BWC Harvey, LLC City: Harvey County/Parish: Jefferson State: Louisiana Photo No. 4 Photo File Name: DSCN7977 Date of Photo: 4/24/2025 Time of Photo: 1008 hrs. Photographer: Vince Damiano Description: View of two full 55-gallon drums of caustic material found inside the hazardous waste storage area. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: BWC Harvey, LLC City: Harvey County/Parish: Jefferson State: Louisiana Photo No. 5 Photo File Name: DSCN7978 Date of Photo: 4/24/2025 Time of Photo: 1010 hrs. Photographer: Vince Damiano Description: View of a half-full 55-gallon drum of an amine product, Morlife 5000, inside the hazardous waste storage area. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: BWC Harvey, LLC City: Harvey County/Parish: Jefferson I State: Louisiana I 10 : 11 Photo No. 6 Photo File Name: DSCN7979 Date of Photo: 4/24/2025 Time of Photo: 1011 hrs. Photographer: Vince Damiano Description: View of two full 55-gallon drums, which were unlabeled, but determined to be nonhazardous waste asphalt. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: BWC Harvey, LLC City: Harvey County/Parish: Jefferson I State: Louisiana I 10 14 Photo No. 7 Photo File Name: DSCN7980 Date of Photo: 4/24/2025 Time of Photo: 1014 hrs. Photographer: Vince Damiano Description: View inside of one of the 55-gallon drums storing waste asphalt in the hazardous waste storage area. APPENDIX 2. LATEX PAINT SDS ~ Benjami'n Moore(I Paints SAFETY DATA SHEET Revision Date: 24-May-2019 Revision Number: 4 1. PRODUCT AND COMPANY IDENTIFICATION Product Name Product Code Alternate Product Code Product Class Color Recommended use Restrictions on use ben PREMIUM INTERIOR LATEX PAINT & PRIMER, SEMI-GLOSS FINISH BASE 3 W6273X W6273X Water thinned paint All Paint No information available Manufacturer Benjamin Moore & Co. 101 Paragon Drive Montvale, NJ 07645 Phone: 1-866-708-9180 www.benjaminmoore.com Emergency Telephone CHEMTREC (US): 800-424-9300 CHEMTREC (outside US): (703)-527-3887 2. HAZARDS IDENTIFICATION Classification This chemical is not considered hazardous by the 2012 OSHA Hazard Communication Standard (29 CFR 1910.1200) Label elements Not a hazardous substance or mixture according to the Globally Harmonized System (GHS) Appearance liquid Odor little or no odor Hazards not otherwise classified (HNOC) Not applicable Other information No information available _____________________________________________________________________________________________ Page 1 / 9 W6273X - ben PREMIUM INTERIOR LATEX PAINT & Revision Date: 24-May-2019 PRIMER, SEMI-GLOSS FINISH BASE 3 _____________________________________________________________________________________________ 3. COMPOSITION INFORMATION ON COMPONENTS Chemical name Kaolin Titanium dioxide CAS No. 1332-58-7 13463-67-7 Weight-% 5 - 10 1-5 General Advice Eye Contact Skin Contact Inhalation Ingestion 4. FIRST AID MEASURES No hazards which require special first aid measures. Rinse thoroughly with plenty of water for at least 15 minutes and consult a physician. Wash off immediately with soap and plenty of water while removing all contaminated clothes and shoes. Move to fresh air. If symptoms persist, call a physician. Clean mouth with water and afterwards drink plenty of water. Consult a physician if necessary. Most Important Symptoms/Effects Notes To Physician None known. Treat symptomatically. 5. FIRE-FIGHTING MEASURES Suitable Extinguishing Media Use extinguishing measures that are appropriate to local circumstances and the surrounding environment. Protective equipment and precautions for firefighters As in any fire, wear self-contained breathing apparatus pressure-demand, MSHA/NIOSH (approved or equivalent) and full protective gear. Specific Hazards Arising From The Chemical Closed containers may rupture if exposed to fire or extreme heat. Sensitivity to mechanical impact No Sensitivity to static discharge No Flash Point Data Flash point (F) Flash Point (C) Method Not applicable Not applicable Not applicable Flammability Limits In Air Lower flammability limit: Upper flammability limit: Not applicable Not applicable _____________________________________________________________________________________________ Page 2 / 9 W6273X - ben PREMIUM INTERIOR LATEX PAINT & Revision Date: 24-May-2019 PRIMER, SEMI-GLOSS FINISH BASE 3 _____________________________________________________________________________________________ NFPA Health: 1 Flammability: 0 Instability: 0 Special: Not Applicable NFPA Legend 0 - Not Hazardous 1 - Slightly 2 - Moderate 3 - High 4 - Severe The ratings assigned are only suggested ratings, the contractor/employer has ultimate responsibilities for NFPA ratings where this system is used. Additional information regarding the NFPA rating system is available from the National Fire Protection Agency (NFPA) at www.nfpa.org. 6. ACCIDENTAL RELEASE MEASURES Personal Precautions Other Information Environmental precautions Methods for Cleaning Up Avoid contact with skin, eyes and clothing. Ensure adequate ventilation. Prevent further leakage or spillage if safe to do so. See Section 12 for additional Ecological Information. Soak up with inert absorbent material. Sweep up and shovel into suitable containers for disposal. 7. HANDLING AND STORAGE Handling Storage Incompatible Materials Avoid contact with skin, eyes and clothing. Avoid breathing vapors, spray mists or sanding dust. In case of insufficient ventilation, wear suitable respiratory equipment. Keep container tightly closed. Keep out of the reach of children. No information available 8. EXPOSURE CONTROLS/PERSONAL PROTECTION Exposure Limits Chemical name Kaolin ACGIH TLV 2 mg/m3 - TWA Titanium dioxide 10 mg/m3 - TWA Legend ACGIH - American Conference of Governmental Industrial Hygienists Exposure Limits OSHA - Occupational Safety & Health Administration Exposure Limits N/E - Not Established OSHA PEL 15 mg/m3 - TWA 5 mg/m3 - TWA 15 mg/m3 - TWA Engineering Measures Ensure adequate ventilation, especially in confined areas. Personal Protective Equipment Eye/Face Protection Safety glasses with side-shields. _____________________________________________________________________________________________ Page 3 / 9 W6273X - ben PREMIUM INTERIOR LATEX PAINT & Revision Date: 24-May-2019 PRIMER, SEMI-GLOSS FINISH BASE 3 _____________________________________________________________________________________________ Skin Protection Respiratory Protection Protective gloves and impervious clothing. In case of insufficient ventilation wear suitable respiratory equipment. Hygiene Measures Avoid contact with skin, eyes and clothing. Remove and wash contaminated clothing before re-use. Wash thoroughly after handling. 9. PHYSICAL AND CHEMICAL PROPERTIES Appearance Odor Odor Threshold Density (lbs/gal) Specific Gravity pH Viscosity (cps) Solubility(ies) Water solubility Evaporation Rate Vapor pressure Vapor density Wt. % Solids Vol. % Solids Wt. % Volatiles Vol. % Volatiles VOC Regulatory Limit (g/L) Boiling Point (F) Boiling Point (C) Freezing point (F) Freezing Point (C) Flash point (F) Flash Point (C) Method Flammability (solid, gas) Upper flammability limit: Lower flammability limit: Autoignition Temperature (F) Autoignition Temperature (C) Decomposition Temperature (F) Decomposition Temperature (C) Partition coefficient liquid little or no odor No information available 9.55 - 9.65 1.15 - 1.17 No information available No information available No information available No information available No information available No information available No information available 40 - 50 35 - 45 50 - 60 55 - 65 0 212 100 32 0 Not applicable Not applicable Not applicable Not applicable Not applicable Not applicable No information available No information available No information available No information available No information available 10. STABILITY AND REACTIVITY Reactivity Chemical Stability Conditions to avoid Incompatible Materials Hazardous Decomposition Products Not Applicable Stable under normal conditions. Prevent from freezing. No materials to be especially mentioned. None under normal use. _____________________________________________________________________________________________ Page 4 / 9 W6273X - ben PREMIUM INTERIOR LATEX PAINT & Revision Date: 24-May-2019 PRIMER, SEMI-GLOSS FINISH BASE 3 _____________________________________________________________________________________________ Possibility of hazardous reactions None under normal conditions of use. 11. TOXICOLOGICAL INFORMATION Product Information Information on likely routes of exposure Principal Routes of Exposure Eye contact, skin contact and inhalation. Acute Toxicity Product Information No information available Symptoms related to the physical, chemical and toxicological characteristics Symptoms No information available Delayed and immediate effects as well as chronic effects from short and long-term exposure Eye contact Skin contact Inhalation Ingestion Sensitization Neurological Effects Mutagenic Effects Reproductive Effects Developmental Effects Target organ effects STOT - single exposure STOT - repeated exposure Other adverse effects Aspiration Hazard May cause slight irritation. Substance may cause slight skin irritation. Prolonged or repeated contact may dry skin and cause irritation. May cause irritation of respiratory tract. Ingestion may cause gastrointestinal irritation, nausea, vomiting and diarrhea. No information available No information available. No information available. No information available. No information available. No information available. No information available. No information available. No information available. No information available Numerical measures of toxicity The following values are calculated based on chapter 3.1 of the GHS document ATEmix (oral) 218537 mg/kg Component Information Chemical name Titanium dioxide 13463-67-7 Oral LD50 > 10000 mg/kg ( Rat ) Dermal LD50 - Inhalation LC50 - Carcinogenicity The information below indicates whether each agency has listed any ingredient as a carcinogen:. Chemical name Titanium dioxide IARC 2B - Possible Human Carcinogen NTP OSHA Listed _____________________________________________________________________________________________ Page 5 / 9 W6273X - ben PREMIUM INTERIOR LATEX PAINT & Revision Date: 24-May-2019 PRIMER, SEMI-GLOSS FINISH BASE 3 _____________________________________________________________________________________________ Although IARC has classified titanium dioxide as possibly carcinogenic to humans (28), their summary concludes: "No significant exposure to titanium dioxide is thought to occur during the use of products in which titanium dioxide is bound to other materials, such as paint." Legend IARC - International Agency for Research on Cancer NTP - National Toxicity Program OSHA - Occupational Safety & Health Administration 12. ECOLOGICAL INFORMATION Ecotoxicity Effects The environmental impact of this product has not been fully investigated. Product Information Acute Toxicity to Fish No information available Acute Toxicity to Aquatic Invertebrates No information available Acute Toxicity to Aquatic Plants No information available Persistence / Degradability No information available. Bioaccumulation No information available. Mobility in Environmental Media No information available. Ozone No information available Component Information Acute Toxicity to Fish Titanium dioxide LC50: > 1000 mg/L (Fathead Minnow - 96 hr.) Acute Toxicity to Aquatic Invertebrates No information available Acute Toxicity to Aquatic Plants No information available 13. DISPOSAL CONSIDERATIONS _____________________________________________________________________________________________ Page 6 / 9 W6273X - ben PREMIUM INTERIOR LATEX PAINT & Revision Date: 24-May-2019 PRIMER, SEMI-GLOSS FINISH BASE 3 _____________________________________________________________________________________________ Waste Disposal Method DOT Dispose of in accordance with federal, state, and local regulations. Local requirements may vary, consult your sanitation department or state-designated environmental protection agency for more disposal options. 14. TRANSPORT INFORMATION Not regulated ICAO / IATA IMDG / IMO Not regulated Not regulated 15. REGULATORY INFORMATION International Inventories TSCA: United States DSL: Canada Yes - All components are listed or exempt. Yes - All components are listed or exempt. Federal Regulations SARA 311/312 hazardous categorization Acute health hazard No Chronic Health Hazard No Fire hazard No Sudden release of pressure hazard No Reactive Hazard No SARA 313 Section 313 of Title III of the Superfund Amendments and Reauthorization Act of 1986 (SARA). This product contains a chemical or chemicals which are subject to the reporting requirements of the Act and Title 40 of the Code of Federal Regulations, Part 372: None Clean Air Act, Section 112 Hazardous Air Pollutants (HAPs) (see 40 CFR 61) This product contains the following HAPs: None US State Regulations California Proposition 65 WARNING: Cancer and Reproductive Harm- www.P65warnings.ca.gov _____________________________________________________________________________________________ Page 7 / 9 W6273X - ben PREMIUM INTERIOR LATEX PAINT & Revision Date: 24-May-2019 PRIMER, SEMI-GLOSS FINISH BASE 3 _____________________________________________________________________________________________ State Right-to-Know Chemical name Kaolin Titanium dioxide Massachusetts X X New Jersey X X Pennsylvania X X Legend X - Listed 16. OTHER INFORMATION HMIS - Health: 1 Flammability: 0 Reactivity: 0 PPE: - HMIS Legend 0 - Minimal Hazard 1 - Slight Hazard 2 - Moderate Hazard 3 - Serious Hazard 4 - Severe Hazard * - Chronic Hazard X - Consult your supervisor or S.O.P. for "Special" handling instructions. Note: The PPE rating has intentionally been left blank. Choose appropriate PPE that will protect employees from the hazards the material will present under the actual normal conditions of use. Caution: HMIS ratings are based on a 0-4 rating scale, with 0 representing minimal hazards or risks, and 4 representing significant hazards or risks. Although HMIS ratings are not required on MSDSs under 29 CFR 1910.1200, the preparer, has chosen to provide them. HMIS ratings are to be used only in conjunction with a fully implemented HMIS program by workers who have received appropriate HMIS training. HMIS is a registered trade and service mark of the NPCA. HMIS materials may be purchased exclusively from J. J. Keller (800) 327-6868. WARNING! If you scrape, sand, or remove old paint, you may release lead dust. LEAD IS TOXIC. EXPOSURE TO LEAD DUST CAN CAUSE SERIOUS ILLNESS, SUCH AS BRAIN DAMAGE, ESPECIALLY IN CHILDREN. PREGNANT WOMEN SHOULD ALSO AVOID EXPOSURE. Wear a NIOSH approved respirator to control lead exposure. Clean up carefully with a HEPA vacuum and a wet mop. Before you start, find out how to protect yourself and your family by contacting the National Lead Information Hotline at 1-800-424-LEAD or log on to www.epa.gov/lead. Prepared By Revision Date: Revision Summary Product Stewardship Department Benjamin Moore & Co. 101 Paragon Drive Montvale, NJ 07645 800-225-5554 24-May-2019 Not available Disclaimer The information contained herein is presented in good faith and believed to be accurate as of the effective date shown above. This information is furnished without warranty of any kind. Employers should use this information only as a supplement to other information gathered by them and must make independent determination of suitability and completeness of information from all sources to assure proper use of these materials and the safety and health of employees. Any use of this data and information must be determined by the user to be in accordance with applicable federal, provincial, and local laws and regulations. _____________________________________________________________________________________________ Page 8 / 9 W6273X - ben PREMIUM INTERIOR LATEX PAINT & Revision Date: 24-May-2019 PRIMER, SEMI-GLOSS FINISH BASE 3 _____________________________________________________________________________________________ End of Safety Data Sheet _____________________________________________________________________________________________ Page 9 / 9 APPENDIX 3. TETRASODIUM SDS Ce, parchem fine & specialty chemicals Safety Data Sheet (Tetrasodium EDTA) DATE PREPARED: 4/18/2017 Section 1. Product and Company Identification Product Name CAS Number Tetrasodium EDTA 194491-31-1 Parchem - fine & specialty chemicals 415 Huguenot Street New Rochelle, NY 10801 (914) 654-6800 (914) 654-6899 parchem.com info@parchem.com EMERGENCY RESPONSE NUMBER CHEMTEL Toll Free US & Canada: 1 (800) 255-3924 All other Origins: 1 (813) 248-0585 Collect Calls Accepted Section 2. Hazards Identification Classification of the substance or mixture GHS Classification in accordance with 29 CFR 1910 (OSHA HCS) Acute toxicity, Oral (Category 4), H302 Serious eye damage (Category 1), H318 GHS Label Elements Pictograms: Signal word: DANGER Hazard and precautionary statements Hazard Statements H302 Harmful if swallowed. H318 Causes serious eye damage. Precautionary Statements P264 Wash skin thoroughly after handling. P270 Do not eat, drink, or smoke when using this product. P280 Wear eye protection/face protection. P301 + P312 + P330 IF SWALLOWED: Call a POISON CENTER or doctor/physician if you feel unwell. Rinse mouth. P305 + P351 + P338 + P310 IF IN EYES: Rinse cautiously with water for several minutes. Remove contact lenses, if present and easy to do. Continue rinsing. Immediately call a POISON CENTER or doctor/physician. P501 Dispose of contents/container to an approved waste disposal plant. Page 1 of 7 Ce, parchem fine & specialty chemicals Safety Data Sheet (Tetrasodium EDTA) DATE PREPARED: 4/18/2017 Hazards not otherwise classified (HNOC) or not covered by GHS: None Section 3. Composition / Information on Ingredients Common Name Synonym(s) Formula CAS Number Tetrasodium EDTA Ethylenediaminetetraacetic acid tetrasodium salt hydrate; Tetrasodium ethylenediaminetetraacetatehydrate; EDTA tetrasodium salt; Edathamil C10H12N2Na4O8 xH2O 194491-31-1 COMPONENT Tetrasodium EDTA CAS NUMBER 194491-31-1 CONCENTRATION <= 100% Section 4. First Aid Measures Description of first-aid measures General advice: Consult a physician. Show this safety data sheet to the doctor in attendance. Move out of dangerous area. Inhalation: If breathed in, move person into fresh air. If not breathing, give artificial respiration. Consult a physician. Skin contact: Wash off with soap and plenty of water. Consult a physician. Eye contact: Rinse thoroughly with plenty of water for at least 15 minutes and consult a physician. Ingestion: Never give anything by mouth to an unconscious person. Rinse mouth with water. Consult a physician. Most important symptoms and effects, both acute and delayed: The most important known symptoms and effects are described in the labelling (see section 2) and/or in section 11. Indication of any immediate medical attention and special treatment needed: No data available Section 5. Firefighting Measures Extinguishing media Suitable extinguishing media: Use water spray, alcohol-resistant foam, dry chemical, or carbon dioxide. Special hazards arising from the substance or mixture: Carbon oxides, Nitrogen oxides (NOx), Sodium oxides Advice for firefighters: Wear self-contained breathing apparatus for firefighting if necessary. Further information: No data available Page 2 of 7 Ce, parchem fine & specialty chemicals Safety Data Sheet (Tetrasodium EDTA) DATE PREPARED: 4/18/2017 Section 6. Accidental Release Measures Personal precautions, protective equipment, and emergency procedures: Use personal protective equipment. Avoid dust formation. Avoid breathing vapors, mist, or gas. Ensure adequate ventilation. Evacuate personnel to safe areas. Avoid breathing dust. For personal protection see section 8. Environmental precautions: Do not let product enter drains. Methods and materials for containment and cleaning up: Pick up and arrange disposal without creating dust. Sweep up and shovel. Keep in suitable, closed containers for disposal. Reference to other sections: For disposal see section 13. Section 7. Handling and Storage Precautions for safe handling: Avoid contact with skin and eyes. Avoid formation of dust and aerosols. Further processing of solid materials may result in the formation of combustible dusts. The potential for combustible dust formation should be taken into consideration before additional processing occurs. Provide appropriate exhaust ventilation at places where dust is formed. For precautions see section 2. Conditions for safe storage, including any incompatibilities Keep container tightly closed in a dry and well-ventilated place. Storage class (TRGS 510): Non Combustible Solids Section 8. Exposure Controls / Personal Protection Control parameters Components with workplace control parameters: Contains no substances with occupational exposure limit values. Exposure controls Appropriate engineering controls: Handle in accordance with good industrial hygiene and safety practice. Wash hands before breaks and at the end of workday. Personal protective equipment Eye/face protection: Face shield and safety glasses Use equipment for eye protection tested and approved under appropriate government standards such as NIOSH (US) or EN 166(EU). Skin protection: Handle with gloves. Gloves must be inspected prior to use. Use proper glove removal technique (without touching glove's outer surface) to avoid skin contact with this product. Dispose of contaminated gloves after use in accordance with applicable laws and good laboratory practices. Wash and dry hands. Body Protection: Complete suit protecting against chemicals, The type of protective equipment must be selected according to the concentration and amount of the dangerous substance at the specific workplace. Page 3 of 7 Ce, parchem fine & specialty chemicals Safety Data Sheet (Tetrasodium EDTA) DATE PREPARED: 4/18/2017 Respiratory protection: Where risk assessment shows air-purifying respirators are appropriate use a full-face particle respirator type N100 (US) or type P3 (EN 143) respirator cartridges as a backup to engineering controls. If the respirator is the sole means of protection, use a full-face supplied air respirator. Use respirators and components tested and approved under appropriate government standards such as NIOSH (US) or CEN (EU). Control of environmental exposure: Do not let product enter drains. Section 9. Physical and Chemical Properties Information on basic physical and chemical properties Appearance: Solid Odor: No data available Odor Threshold: No data available pH: No data available Melting point/freezing point: No data available Initial boiling point and boiling range: No data available Flash point: No data available Evaporation rate: No data available Flammability (solid, gas): No data available Upper/lower flammability or explosive limits: No data available Vapor pressure: No data available Vapor density: No data available Relative density: No data available Water solubility: 38 g/l at 20C (68F) - soluble, clear Partition coefficient (n-Octanol/water): No data available Auto-ignition temperature: No data available Decomposition temperature: No data available Viscosity: No data available Explosive properties: No data available Oxidizing properties: No data available Other safety information: No data available Section 10. Stability and Reactivity Reactivity: No data available Chemical stability: Stable under recommended storage conditions. Possibility of hazardous reactions: No data available Conditions to avoid: No data available Incompatible materials: Strong oxidizing agents Hazardous decomposition products Other decomposition products: No data available In the event of fire: see section 5 Page 4 of 7 Ce, parchem fine & specialty chemicals Safety Data Sheet (Tetrasodium EDTA) DATE PREPARED: 4/18/2017 Section 11. Toxicological Information Information on toxicological effects Acute toxicity LD50 Oral - Rat: 630 - 1,260 mg/kg Inhalation: No data available Dermal: No data available Skin corrosion/irritation: No data available Serious eye damage/eye irritation: No data available Respiratory or skin sensitization: No data available Germ cell mutagenicity: No data available Carcinogenicity IARC: No component of this product, present at levels greater than or equal to 0.1%, is identified as probable, possible or confirmed human carcinogen by IARC. ACGIH: No component of this product, present at levels greater than or equal to 0.1%, is identified as a carcinogen or potential carcinogen by ACGIH. NTP: No component of this product, present at levels greater than or equal to 0.1%, is identified as a known or anticipated carcinogen by NTP. OSHA: No component of this product, present at levels greater than or equal to 0.1%, is identified as a carcinogen or potential carcinogen by OSHA. Reproductive toxicity: No data available Specific target organ toxicity - single exposure: No data available Specific target organ toxicity - repeated exposure: No data available Aspiration hazard: No data available Additional Information RTECS: Not available To the best of our knowledge, the chemical, physical, and toxicological properties have not been thoroughly investigated. Section 12. Ecological Information Toxicity: No data available Persistence and degradability: No data available Bioaccumulative potential: No data available Mobility in soil: No data available Results of PBT and vPvB assessment: PBT/vPvB assessment not available as chemical safety assessment not required/not conducted Other adverse effects: No data available Page 5 of 7 Ce, parchem fine & specialty chemicals Safety Data Sheet (Tetrasodium EDTA) DATE PREPARED: 4/18/2017 Section 13. Disposal Considerations Waste Treatment Methods: Dispose of product and contaminated packaging in accordance with all local, state, and federal environmental control regulations. Section 14. Transport Information DOT (US): Not dangerous goods IMDG: Not dangerous goods IATA: Not dangerous goods Section 15. Regulatory Information SARA 302 Components: No chemicals in this material are subject to the reporting requirements of SARA Title III, Section 302. SARA 313 Components: This material does not contain any chemical components with known CAS numbers that exceed the threshold (De Minimis) reporting levels established by SARA Title III, Section 313. SARA 311/312 Hazards: Acute Health Hazard Massachusetts Right to Know Components No components are subject to the Massachusetts Right to Know Act. Pennsylvania Right to Know Components Ethylenediaminetetraacetic acid tetrasodium salt hydrate (CAS-No. 194491-31-1) New Jersey Right to Know Components Ethylenediaminetetraacetic acid tetrasodium salt hydrate (CAS-No. 194491-31-1) California Prop. 65 Components: This product does not contain any chemicals known to State of California to cause cancer, birth defects, or any other reproductive harm. HMIS Rating Health: 1 Flammability: 0 Reactivity: 0 NFPA Rating Health: 1 Flammability: 0 Reactivity: 0 Page 6 of 7 Ce, parchem fine & specialty chemicals Safety Data Sheet (Tetrasodium EDTA) DATE PREPARED: 4/18/2017 Section 16. Other Information Disclaimer: The above information is believed to be correct but does not purport to be all inclusive and shall be used only as a guide. The information in this document is based on the present state of our knowledge and is applicable to the product with regard to appropriate safety precautions. It does not represent any guarantee of the properties of the product. REVISION DATE: 4/18/2017 Page 7 of 7 APPENDIX 4. MORLIFE 5000 SDS ngev1ty SAFETY DATA SHEET MORLIFE 5000 ISection 1. Identification GHS product identifier Other means of identification MORLIFE 5000 Not available. Material uses Chemical intermediate. Supplier's details lngevity Corporation 5255 Virginia Avenue North Charleston South Carolina USA 29406-3615 www.ingevity.com email: sds@ingevity.com Tel: +1 843 740 2300, +1 800 458 4034 (0800 - 1700 EST) RESPONSIBLE CARE" OUR COMM ITMENT TO SUSTAJNARIUTY In case of emergency +1 800 424 9300 (USA) CHEMTREC Section 2. Hazards identification OSHA/HCS status Classification of the substance or mixture This material is considered hazardous by the OSHA Hazard Communication Standard (29 CFR 1910.1200). ACUTE TOXICITY (inhalation) - Category 3 SKIN CORROSION - Category 1B SERIOUS EYE DAMAGE - Category 1 SKIN SENSITIZATION - Category 1 SPECIFIC TARGET ORGAN TOXICITY (SINGLE EXPOSURE) (Respiratory tract irritation) - Category 3 SPECIFIC TARGET ORGAN TOXICITY (REPEATED EXPOSURE) (central nervous system (CNS)) - Category 2 GHS label elements Hazard pictograms Signal word Hazard statements Precautionary statements Prevention Danger Toxic if inhaled . Causes severe skin burns and eye damage. May cause an allergic skin reaction . May cause respiratory irritation. May cause damage to organs through prolonged or repeated exposure. (central nervous system (CNS)) Wear protective gloves: > 8 hours (breakthrough time): PVC. Wear eye or face protection : Recommended: Safety glasses with side shields, goggles and/or face shield. Wear protective clothing : Recommended : Lab coat, apron or coveralls. Use only outdoors or in a well-ventilated area. Do not breathe vapor. Wash hands thoroughly after handling . Contaminated work clothing must not be allowed out of the workplace. Validated on 9/7/2018. Version: 2.06 ngev1ty. MORLIFE 5000 Page: 2/13 Section 2. Hazards identification Response Get medical attention if you feel unwell. IF INHALED: Remove person to fresh air and keep comfortable for breathing. Immediately call a POISON CENTER or physician. IF SWALLOWED: Immediately call a POISON CENTER or physician. Rinse mouth . Do NOT induce vomiting. IF ON SKIN (or hair): Take off immediately all contaminated clothing. Rinse skin with water or shower. Wash contaminated clothing before reuse. Immediately call a POISON CENTER or physician . IF ON SKIN: Wash with plenty of soap and water. Wash contaminated clothing before reuse. If skin irritation or rash occurs: Get medical attention. IF IN EYES: Rinse cautiously with water for several minutes. Remove contact lenses, if present and easy to do. Continue rinsing. Immediately call a POISON CENTER or physician . Storage Store locked up. Disposal Dispose of contents and container in accordance with all local, regional, national and international regulations. Hazards not otherwise classified None known. !Section 3. Composition/information on ingredients Substance/mixture : Substance Ingredient name Polyethylene polyamines % CAS number 100 Proprietary Any concentration shown as a range is to protect confidentiality or is due to batch variation. There are no additional ingredients present which, within the current knowledge of the supplier and in the concentrations applicable, are classified as hazardous to health and hence require reporting in this section. Occupational exposure limits, if available, are listed in Section 8. Isection 4. First aid measures Description of necessary first aid measures Eye contact Inhalation Skin contact Get medical attention immediately. Call a poison center or physician. Immediately flush eyes with plenty of water, occasionally lifting the upper and lower eyelids. Check for and remove any contact lenses. Continue to rinse for at least 15 minutes. Chemical burns must be treated promptly by a physician. Get medical attention immediately. Call a poison center or physician. Remove victim to fresh air and keep at rest in a position comfortable for breathing. If it is suspected that fumes are still present, the rescuer should wear an appropriate mask or self-contained breathing apparatus. If not breathing, if breathing is irregular or if respiratory arrest occurs, provide artificial respiration or oxygen by trained personnel. It may be dangerous to the person providing aid to give mouth-to-mouth resuscitation. If unconscious, place in recovery position and get medical attention immediately. Maintain an open airway. Loosen tight clothing such as a collar, tie, belt or waistband . In case of inhalation of decomposition products in a fire, symptoms may be delayed. The exposed person may need to be kept under medical surveillance for 48 hours. Get medical attention immediately. Call a poison center or physician. Wash with plenty of soap and water. Remove contaminated clothing and shoes. Wash contaminated clothing thoroughly with water before removing it, or wear gloves. Continue to rinse for at least 15 minutes. Chemical burns must be treated promptly by a physician. In the event of any complaints or symptoms, avoid further exposure. Wash clothing before reuse. Clean shoes thoroughly before reuse. Validated on 9/7/2018. Version: 2.06 ngev1ty. MORLIFE 5000 Page: 3/13 Isection 4. First aid measures Ingestion Get medical attention immediately. Call a poison center or physician. Wash out mouth with water. Remove dentures if any. Remove victim to fresh air and keep at rest in a position comfortable for breathing . If material has been swallowed and the exposed person is conscious, give small quantities of water to drink. Stop if the exposed person feels sick as vomiting may be dangerous. Do not induce vomiting unless directed to do so by medical personnel. If vomiting occurs, the head should be kept low so that vomit does not enter the lungs. Chemical burns must be treated promptly by a physician. Never give anything by mouth to an unconscious person. If unconscious, place in recovery position and get medical attention immediately. Maintain an open airway. Loosen tight clothing such as a collar, tie, belt or waistband . Most important symptoms/effects, acute and delayed Potential acute health effects Eye contact Causes serious eye damage. Inhalation Toxic if inhaled . May cause respiratory irritation. Skin contact Causes severe burns. May cause an allergic skin reaction . Ingestion No known significant effects or critical hazards. Over-exposure signs/symptoms Eye contact Adverse symptoms may include the following: pain watering redness Inhalation Adverse symptoms may include the following: respiratory tract irritation coughing Skin contact Adverse symptoms may include the following: pain or irritation redness blistering may occur Ingestion Adverse symptoms may include the following : stomach pains Indication of immediate medical attention and special treatment needed, if necessary Notes to physician In case of inhalation of decomposition products in a fire, symptoms may be delayed . The exposed person may need to be kept under medical surveillance for 48 hours. Specific treatments No specific treatment. Protection of first-aiders No action shall be taken involving any personal risk or without suitable training. If it is suspected that fumes are still present, the rescuer should wear an appropriate mask or self-contained breathing apparatus. It may be dangerous to the person providing aid to give mouth-to-mouth resuscitation. Wash contaminated clothing thoroughly with water before removing it, or wear gloves. See toxicological information (Section 11) Validated on 9/7/2018. Version: 2.06 ngev1ty. MORLIFE 5000 Page: 4/13 !section 5. Fire-fighting measures Extinguishing media Suitable extinguishing media Unsuitable extinguishing media Use an extinguishing agent suitable for the surrounding fire. None known. Specific hazards arising from the chemical Hazardous thermal decomposition products In a fire or if heated, a pressure increase will occur and the container may burst. Decomposition products may include the following materials: carbon dioxide carbon monoxide nitrogen oxides Special protective actions for fire-fighters Special protective equipment for fire-fighters Remark Promptly isolate the scene by removing all persons from the vicinity of the incident if there is a fire. No action shall be taken involving any personal risk or without suitable training . Fire-fighters should wear appropriate protective equipment and self-contained breathing apparatus (SCBA) with a full face-piece operated in positive pressure mode. Work upwind of fire. ISection 6. Accidental release measures Personal precautions, protective equipment and emergency procedures For non-emergency personnel No action shall be taken involving any personal risk or without suitable training. Evacuate surrounding areas. Keep unnecessary and unprotected personnel from entering. Do not touch or walk through spilled material. Do not breathe vapor or mist. Provide adequate ventilation. Wear appropriate respirator when ventilation is inadequate. Put on appropriate personal protective equipment. For emergency responders If specialized clothing is required to deal with the spillage, take note of any information in Section 8 on suitable and unsuitable materials. See also the information in "For nonemergency personnel". Environmental precautions Avoid dispersal of spilled material and runoff and contact with soil, waterways, drains and sewers. Inform the relevant authorities if the product has caused environmental pollution (sewers, waterways, soil or air). Methods and materials for containment and cleaning up Small spill Stop leak if without risk. Move containers from spill area. Dilute with water and mop up if water-soluble. Alternatively, or if water-insoluble, absorb with an inert dry material and place in an appropriate waste disposal container. Dispose of via a licensed waste disposal contractor. Large spill Stop leak if without risk. Move containers from spill area. Approach release from upwind. Prevent entry into sewers, water courses, basements or confined areas. Wash spillages into an effluent treatment plant or proceed as follows. Contain and collect spillage with non-combustible, absorbent material e.g. sand, earth, vermiculite or diatomaceous earth and place in container for disposal according to local regulations (see Section 13). Dispose of via a licensed waste disposal contractor. Contaminated absorbent material may pose the same hazard as the spilled product. Note: see Section 1 for emergency contact information and Section 13 for waste disposal. Validated on 9/7/2018. Version: 2.06 ngev1ty. MORLIFE 5000 Page: 5/13 !section 7. Handling and storage Precautions for safe handling Protective measures Advice on general occupational hygiene Put on appropriate personal protective equipment (see Section 8). Persons with a history of skin sensitization problems should not be employed in any process in which this product is used. Do not get in eyes or on skin or clothing. Do not breathe vapor or mist. Do not ingest. Use only with adequate ventilation. Wear appropriate respirator when ventilation is inadequate. Keep in the original container or an approved alternative made from a compatible material, kept tightly closed when not in use. Keep away from acids. Empty containers retain product residue and can be hazardous. Do not reuse container. Eating, drinking and smoking should be prohibited in areas where this material is handled, stored and processed. Workers should wash hands and face before eating, drinking and smoking . Remove contaminated clothing and protective equipment before entering eating areas. See also Section 8 for additional information on hygiene measures. Conditions for safe storage, including any incompatibilities Store in accordance with local regulations. Store in original container protected from direct sunlight in a dry, cool and well-ventilated area, away from incompatible materials (see Section 10) and food and drink. Store locked up. Separate from acids. Keep container tightly closed and sealed until ready for use. Containers that have been opened must be carefully resealed and kept upright to prevent leakage. Do not store in unlabeled containers. Use appropriate containment to avoid environmental contamination. See Section 10 for incompatible materials before handling or use. ISection 8. Exposure controls/personal protection Control parameters Occupational exposure limits None. Appropriate engineering controls Environmental exposure controls Use only with adequate ventilation. Use process enclosures, local exhaust ventilation or other engineering controls to keep worker exposure to airborne contaminants below any recommended or statutory limits. Emissions from ventilation or work process equipment should be checked to ensure they comply with the requirements of environmental protection legislation. In some cases, fume scrubbers, filters or engineering modifications to the process equipment will be necessary to reduce emissions to acceptable levels. Individual protection measures Hygiene measures Wash hands, forearms and face thoroughly after handling chemical products, before eating, smoking and using the lavatory and at the end of the working period . Appropriate techniques should be used to remove potentially contaminated clothing. Contaminated work clothing should not be allowed out of the workplace. Wash contaminated clothing before reusing . Ensure that eyewash stations and safety showers are close to the workstation location. Eye/face protection Safety eyewear complying with an approved standard should be used when a risk assessment indicates this is necessary to avoid exposure to liquid splashes, mists, gases or dusts. If contact is possible, the following protection should be worn, unless the assessment indicates a higher degree of protection : chemical splash goggles and/ or face shield. If inhalation hazards exist, a full-face respirator may be required instead. Recommended: Safety glasses with side shields, goggles and/or face shield Skin protection Validated on 9/7/2018. Version: 2.06 ngev1ty. MORLIFE 5000 Page: 6/13 ISection 8. Exposure controls/personal protection Hand protection Body protection Other skin protection Respiratory protection Chemical-resistant, impervious gloves complying with an approved standard should be worn at all times when handling chemical products if a risk assessment indicates this is necessary. Considering the parameters specified by the glove manufacturer, check during use that the gloves are still retaining their protective properties. It should be noted that the time to breakthrough for any glove material may be different for different glove manufacturers. In the case of mixtures, consisting of several substances, the protection time of the gloves cannot be accurately estimated. > 8 hours (breakthrough time): PVC Personal protective equipment for the body should be selected based on the task being performed and the risks involved and should be approved by a specialist before handling this product. Recommended : Lab coat, apron or coveralls Appropriate footwear and any additional skin protection measures should be selected based on the task being performed and the risks involved and should be approved by a specialist before handling this product. Based on the hazard and potential for exposure, select a respirator that meets the appropriate standard or certification . Respirators must be used according to a respiratory protection program to ensure proper fitting, training, and other important aspects of use. ISection 9. Physical and chemical properties Appearance Physical state Color Odor Odor threshold pH Melting point Boiling point Flash point Burning time Liquid . Brown . [Dark] Fishy Not available. 11 .9 [Cone. (% w/w): 15%] -72C (-97.6F) 199.?C (391 .5F) Closed cup: 130C (266F) [Pensky-Martens.] Not applicable. Burning rate Evaporation rate Flammability (solid, gas) Lower and upper explosive (flammable) limits Vapor pressure Vapor density Relative density Solubility Solubility in water Partition coefficient: noctanol/water Auto-ignition temperature Not applicable. <0.01 (ether (anhydrous)= 1) Not applicable. Not available. 0.61 kPa (4.58 mm Hg) [room temperature] 2.8 kPa (20.78 mm Hg) [S0C] 4.6 [Air= 1] 1.09 [Water= 1] Easily soluble in the following materials: cold water and hot water. Not available. -3.16 to -1.46 357C (674.6F) Decomposition temperature SADT Viscosity Not available. Not available. Kinematic (room temperature): 0.4 cm2/s (40 cSt) Kinematic (40C (104F)): 0.4 cm2/s (40 cSt) Validated on 9/7/2018. Version: 2.06 ngev1ty. MORLIFE 5000 Page: 7/13 ISection 9. Physical and chemical properties Aerosol product ISection 10. Stability and reactivity Reactivity No specific test data related to reactivity available for this product or its ingredients. Chemical stability The product is stable. Possibility of hazardous reactions Under normal conditions of storage and use, hazardous reactions will not occur. Conditions to avoid No specific data. Incompatible materials Reactive or incompatible with the following materials: oxidizing materials and acids. Incompatibility: Aldehyde., Ketone., halides, Acrylates, Alkali metal, epoxides. Hazardous decomposition products Under normal conditions of storage and use, hazardous decomposition products should not be produced. !Section 11. Toxicological information Information on toxicological effects Acute toxicity Product/ingredient name Result Polyethylene polyamines LCS0 Inhalation Dusts and mists LCS0 Inhalation Dusts and mists lrritation/Corrosion LDS0 Dermal LD50 Oral Species Rat- Male, Female Rat- Male, Female Rat Rat Dose 2.48 to 4.56 mg/I Exposure 1 hours 0.62 to 1.14 mg/I 4 hours 16000 mg/kg - 2810 mg/kg - Product/ingredient name Polyethylene polyamines Sensitization Not available. Result Eyes - Cornea opacity Species Rabbit Score 2.55 Exposure 72 hours 0. 1ml / 100% Observation 72 hours Conclusion/Summary Skin Mutagenicity Product/ingredient name Polyethylene polyamines carcjnogeoicitv Not available. The sensitization expected is based on similar products. Product specific data not available. Test OECD 471 471 Bacterial Reverse Mutation Test Experiment Result Experiment: In vitro Positive Subject: Bacteria Metabolic activation : with and without Reproductive toxicity Validated on 9/7/2018. Version: 2.06 ngev1ty. MORLIFE 5000 Page: 8/13 !section 11. Toxicological information Not available. Teratogenicity Not available. Specific target organ toxicity (single exposure) Name Category Polyethylene polyamines Category 3 Specific target organ toxicity (repeated exposure) Name Category Polyethylene polyamines Category 2 Aspiration hazard Not available. Route of exposure Not applicable. Target organs Respiratory tract irritation Route of exposure Not determined Target organs central nervous system (CNS) Information on the likely routes of exposure Potential acute health effects Eye contact Inhalation Skin contact Ingestion Routes of entry anticipated: Oral, Dermal, Inhalation. Causes serious eye damage. Toxic if inhaled . May cause respiratory irritation. Causes severe burns. May cause an allergic skin reaction. No known significant effects or critical hazards. Symptoms related to the physical, chemical and toxicological characteristics Eye contact Adverse symptoms may include the following : pain watering redness Inhalation Adverse symptoms may include the following : respiratory tract irritation coughing Skin contact Adverse symptoms may include the following : pain or irritation redness blistering may occur Ingestion Adverse symptoms may include the following : stomach pains Delayed and immediate effects and also chronic effects from short and long term exposure Short term exposure Potential immediate effects Not available. Potential delayed effects Not available. Long term exposure Validated on 9/7/2018. Version: 2.06 ngev1ty. MORLIFE 5000 Page: 9/13 !section 11. Toxicological information Potential immediate effects Not available. Potential delayed effects Not available. Potential chronic health effects Not available. General Carcinogenicity Mutagenicity Teratogenicity Developmental effects Fertility effects May cause damage to organs through prolonged or repeated exposure. Once sensitized, a severe allergic reaction may occur when subsequently exposed to very low levels. No known significant effects or critical hazards. No known significant effects or critical hazards. No known significant effects or critical hazards. No known significant effects or critical hazards. No known significant effects or critical hazards. Numerical measures of toxicity Acute toxicity estimates Not available. ISection 12. Ecological information Toxicity Product/ingredient name Result Polyethylene polyamines Acute ECS0 <100 mg/I Acute ECS0 64 mg/I Acute LCS0 >100 mg/I Chronic NOEC 2 mg/I Species Algae Daphnia Fish Fish Persistence and degradabmty Product/ingredient name Test Polyethylene polyamines - Product/ingredient name Polyethylene polyamines Aquatic half-life - Result 50 to 70 % - 28 days Photolysis - Dose - Exposure 72 hours 48 hours 96 hours 96 hours lnoculum - Biodegradability Inherent Bioaccumulative potential Product/ingredient name Polyethylene polyamines LogPow -3.16 to -1.46 BCF - Potential low Mobility in soil Soil/water partition coefficient (Koc) Other adverse effects Not available. No known significant effects or critical hazards. Validated on 9/7/2018. Version: 2.06 ngev1ty. MORLIFE 5000 Page: 10/13 ISection 13. Disposal considerations Disposal methods The generation of waste should be avoided or minimized wherever possible. Disposal of this product, solutions and any by-products should at all times comply with the requirements of environmental protection and waste disposal legislation and any regional local authority requ irements. Dispose of surplus and non-recyclable products via a licensed waste disposal contractor. Waste should not be disposed of untreated to the sewer unless fully compliant with the requirements of all authorities with jurisdiction. Waste packaging should be recycled . Incineration or landfill should only be considered when recycling is not feasible. This material and its container must be disposed of in a safe way. Care should be taken when handling emptied containers that have not been cleaned or rinsed out. Empty containers or liners may retain some product residues. Avoid dispersal of spilled material and runoff and contact with soil, waterways, drains and sewers. ISection 14. Transport information DOT Classification IMDG IATA UN number UN2735 UN2735 UN2735 UN proper shipping name Amines, liquid, corrosive, n.o.s. (Polyethylene polyamines). Marine pollutant (Polyethylene polyamines) AMINES, LIQUID, CORROSIVE, N.O.S. (Polyethylene polyamines). Marine pollutant (Polyethylene polyamines) Amines, liquid, corrosive, n.o.s. (Polyethylene polyamines) Transport hazard class(es) Packing group 8 ~ 111 8 ~ 111 8 111 Environmental hazards Yes. Yes. Yes. The environmentally hazardous substance mark is not required. Additional information This product is not regulated as a marine pollutant when transported on inland waterways in sizes of s5 L or s;5 kg or by road , rail , or inland air in nonbulk sizes, provided the packagings meet the general provisions of 173.24 and 173. 24a. Limit1d gy51ntib'. Yes. Packaging instruction Exceptions: 154. Non-bulk: 203. Bulk: 241 . Quantit)l limitatiQn Passenger aircraft/rail: 5 L. Cargo aircraft: 60 L. Special provisions 183, T7, TP1, TP28 The marine pollutant mark is not requ ired when transported in sizes of S5 Lor S5 kg . Em1rg1n~ll ~h!dYIH F-A, S-8 Special provisions 223, 274 The environmentally hazardous substance mark may appear if required by other transportation regulations. Quantitll limitation Passenger and Cargo Aircraft: 5 L. Packaging instructions: 852. Cargo Aircraft Only: 60 L. Packaging instructions: 856. Limited Quantities - Passenger Aircraft: 1 L. Packaging instructions: Y841 . Special provisions A3, A803 Validated on 9/7/2018. Version: 2.06 ngev1ty. MORLIFE 5000 Page: 11/13 ISection 14. Transport information Special precautions for user : Transport within user's premises: always transport in closed containers that are upright and secure. Ensure that persons transporting the product know what to do in the event of an accident or spillage. Transport in bulk according to Annex II of MARPOL and the IBC Code Not available. ISection 15. Regulatory information U.S. Federal regulations TSCA 8(a) CDR Exempt/Partial exemption: Not determined United States inventory (TSCA Sb): This material is listed or exempted. Clean Air Act Section 112 (b) Hazardous Air Pollutants (HAPs) Not listed Clean Air Act Section 602 Class I Substances Not listed Clean Air Act Section 602 Class II Substances Not listed DEA List I Chemicals (Precursor Chemicals) Not listed DEA List II Chemicals (Essential Chemicals) Not listed SARA 302/304 Composition/information on ingredients No products were found . SARA304 RQ Not applicable. SARA 311/312 Classification ACUTE TOXICITY (inhalation) - Category 3 SKIN CORROSION - Category 1B SERIOUS EYE DAMAGE - Category 1 SKIN SENSITIZATION - Category 1 SPECIFIC TARGET ORGAN TOXICITY (SINGLE EXPOSURE) (Respiratory tract irritation) - Category 3 SPECIFIC TARGET ORGAN TOXICITY (REPEATED EXPOSURE) (central nervous system (CNS)) - Category 2 Composition/information on ingredients Name Polyethylene polyamines % Proprietary Classification ACUTE TOXICITY (inhalation) - Category 3 SKIN CORROSION - Category 1B SERIOUS EYE DAMAGE - Category 1 SKIN SENSITIZATION - Category 1 SPECIFIC TARGET ORGAN TOXICITY (SINGLE EXPOSURE) (Respiratory tract irritation) - Category 3 SPECIFIC TARGET ORGAN TOXICITY (REPEATED EXPOSURE) (central nervous system (CNS)) - Category 2 State regulations Validated on 9/7/2018. Version: 2.06 ngev1ty. MORLIFE 5000 ISection 15. Regulatory information Massachusetts This material is not listed. New York This material is not listed. New Jersey This material is not listed. Pennsylvania This material is not listed. California Prop. 65 Not listed. International regulations Chemical Weapon Convention List Schedules I, II & Ill Chemicals Not listed. Montreal Protocol (Annexes A, B, C, El Not listed. Stockholm Convention on Persistent Organic PoHutants Not listed. Rotterdam Convention on Prior Informed Consent (PIC) Not listed. UNECE Aarhus Protocol on POPs and Heavy Metals Not listed. International lists National inventory Australia This material is listed or exempted. Canada This material is not listed in DSL but is listed in NDSL. China This material is listed or exempted. Japan Japan inventory (ENCS): Not determined. Japan inventory (ISHL): Not determined. New Zealand This material is listed or exempted . Philippines Not determined. Republic of Korea Taiwan Not determined. This material is listed or exempted . United States This material is listed or exempted . ISection 16. Other information Hazardous Material Information System (U.S.A.) * 3 Page: 12/13 Caution: HMIS ratings are based on a 0-4 rating scale, with Orepresenting minimal hazards or risks, and 4 representing significant hazards or risks. Although HMIS ratings and the associated label are not required on SDSs or products leaving a facility under 29 CFR 1910.1200, the preparer may choose to provide them. HMIS ratings are to be used with a fully implemented HMIS program. HMIS is a registered trademark and service mark of the American Coatings Association, Inc. Validated on 9/7/2018. Version: 2.06 ngev1ty. MORLIFE 5000 Page: 13/13 ISection 16. Other information The customer is responsible for determining the PPE code for this material. For more information on HMIS Personal Protective Equipment (PPE) codes, consult the HMIS Implementation Manual. National Fire Protection Association (U.S.A.) Health Flammability 0 Instability/Reactivity Special Reprinted with permission from NFPA 704-2001, Identification of the Hazards of Materials for Emergency Response Copyright 1997, National Fire Protection Association, Quincy, MA 02269. This reprinted material is not the complete and official position of the National Fire Protection Association, on the referenced subject which is represented only by the standard in its entirety. Copyright 2001, National Fire Protection Association, Quincy, MA 02269. This warning system is intended to be interpreted and applied only by properly trained individuals to identify fire, health and reactivity hazards of chemicals. The user is referred to certain limited number of chemicals with recommended classifications in NFPA 49 and NFPA 325, which would be used as a guideline only. Whether the chemicals are classified by NFPA or not, anyone using the 704 systems to classify chemicals does so at their own risk. History Date of printing 2018-09-07 . Date of issue/Date of revision 2018-09-07 Date of previous issue 2018-08-30 . Version 2.06 Key to abbreviations ATE= Acute Toxicity Estimate BCF = Bioconcentration Factor GHS = Globally Harmonized System of Classification and Labelling IATA = International Air Transport Association IBC = Intermediate Bulk Container IMDG = International Maritime Dangerous Goods Log Pow= logarithm of the octanol/water partition coefficient MARPOL = International Convention for the Prevention of Pollution as modified by the Protocol of 1978. ("Marpol" = marine pollution) UN = United Nations of Chemicals From Ships, 1973 References Not available. !7 Indicates information that has changed from previously issued version. Notice to reader To the best of our knowledge, the information contained herein is accurate. However, neither the above-named supplier, nor any of its subsidiaries, assumes any liability whatsoever for the accuracy or completeness of the information contained herein. Final determination of suitability of any material is the sole responsibility of the user. All materials may present unknown hazards and should be used with caution. Although certain hazards are described herein, we cannot guarantee that these are the only hazards that exist. Validated on 9/7/2018. Version: 2.06 APPENDIX 5. CAUSTIC SDS SAFETY DATA SHEET OxyChem _________________________________________________________________________________________________ CAUSTIC SODA LIQUID (ALL GRADES) North America EN SDS No.: M32415 Rev. Date: 21-Jun-2024 Rev. Num. 12 _________________________________________________________________________________________________ SECTION 1. CHEMICAL PRODUCT / COMPANY IDENTIFICATION _________________________________________________________________________________________________ Company Identification: Occidental Chemical Corporation 14555 Dallas Parkway, Suite 400 Dallas, Texas 75254-4300 24-Hour Emergency Telephone Number: 1-800-733-3665 (USA); CANUTEC (Canada): 1-613-996-6666; CHEMTREC (within USA and Canada): 1-800-424-9300; CHEMTREC (outside USA and Canada): +1 703-527-3887; CHEMTREC Contract No: CCN16186 To Request an SDS: MSDS@oxy.com or 1-972-404-3245 Customer Service: 1-800-752-5151 or 1-972-404-3700 Product Identifier: CAUSTIC SODA LIQUID (ALL GRADES) Trade Name: Caustic Soda Diaphragm Grade 7%, 10%, 15%, 18%, 18.5%, 20%, 25%, 30%, 35%, 40%, 50%, Caustic Soda Membrane 6%, 7%, 18%, 20%, 25%, 30%, 48%, 50%, 50% Caustic Soda Membrane OS, 50% Caustic Soda Diaphragm OS, Membrane Blended, Membrane Cell Liquor, Diaphragm Cell Liquor, Caustic Soda Food Grade Synonyms: Sodium hydroxide solution; Liquid Caustic; Lye Solution; Caustic; Lye; Soda Lye; Secondary Caustic Soda Liquids Product Use: Caustic soda has a wide variety of applications in many industries, including pulp and paper, aluminum, soaps and detergents, textiles, petrochemicals and chemical processing, food processing Uses Advised Against: Produced in a non-mercury cell process. Meets ANSI/AWWA B511-10 and Food Chemical Codex (FCC) test requirements; however, Caustic Soda is not produced under all cGMP requirements as defined by the FDA. Customers should evaluate food grade requirements for cGMP based upon their particular requirements. Other Global Restrictions on Use: Other restrictions on use based on local, regional, state, or national regulations may exist and must be determined on a case-by-case basis. _________________________________________________________________________________________________ Print date: 21-Jun-2024 1 of 21 North America EN CAUSTIC SODA LIQUID (ALL GRADES) SDS No.: M32415 Rev. Date: 21-Jun-2024 Supersedes Date: 2022-14-March Rev. Num. 12 _________________________________________________________________________________________________ Chemical Family: Alkali Metal Hydroxide Solutions Note: All OxyChem's caustic soda meets the test requirements specified in the Food Chemicals Codex (FCC). Not all OxyChem's caustic soda is produced following all cGMP (current Good Manufacturing Practices) requirements as defined by the FDA (Food and Drug Administration). OxyChem does produce a food grade caustic soda, which is produced following cGMP requirements as defined by the FDA. OxyChem does not represent or warrant general compliance of this product for food use. Each prospective use of a product in a food or food related application must be carefully assessed against appropriate regulations by the user and it cannot be assumed that products meeting FCC test requirements are satisfactory for all uses without such assessment. _________________________________________________________________________________________________ SECTION 2. HAZARDS IDENTIFICATION _________________________________________________________________________________________________ OSHA REGULATORY STATUS: This material is considered hazardous by the OSHA Hazard Communication Standard (29 CFR 1910.1200). HEALTH CANADA HPR REGULATORY STATUS: This material is considered hazardous by the Health Canada Hazardous Products Act's Hazardous Products Regulations (HPR) (SOR/2015-17). Color: Physical State: Appearance: Odor: Signal Word: EMERGENCY OVERVIEW: Colorless to slightly colored Liquid Clear to opaque Odorless DANGER MAJOR HEALTH HAZARDS: CAUSES SERIOUS EYE DAMAGE. CAUSES SEVERE SKIN BURNS AND EYE DAMAGE. Toxicity may be delayed and may not be readily visible. PHYSICAL HAZARDS: MAY BE CORROSIVE TO METALS. Mixing with water, acid or incompatible materials may cause splattering and release of heat. Do not store in aluminum container or use aluminum fittings or transfer lines, as flammable hydrogen gas may be generated. ECOLOGICAL HAZARDS: Keep out of water supplies and sewers. This material is alkaline and may raise the pH of surface waters. PRECAUTIONARY STATEMENTS: Do not breathe mist, vapors, or spray. Wash skin and contaminated clothing _________________________________________________________________________________________________ Print date: 21-Jun-2024 2 of 21 North America EN CAUSTIC SODA LIQUID (ALL GRADES) SDS No.: M32415 Rev. Date: 21-Jun-2024 Supersedes Date: 2022-14-March Rev. Num. 12 _________________________________________________________________________________________________ thoroughly after handling. Wash thoroughly after handling- exposure can cause burns which are not immediately painful or visible. Wear protective gloves, protective clothing, eye, and face protection. Keep only in original container or container compatible with product (see Section 7 - Safe Storage Conditions). Avoid release to the environment. ADDITIONAL HAZARD INFORMATION: This material is corrosive. It may cause severe burns and permanent damage to any tissue with which it comes into contact. Toxicity may be delayed and may not be readily visible. To treat contacted tissue, flush with water to dilute. There is no specific antidote. Significant exposures must be referred for medical attention immediately. HAZARD CLASSIFICATION: GHS: PHYSICAL HAZARDS: GHS: CONTACT HAZARD - SKIN: GHS: CONTACT HAZARD - EYE: HAZARDS NOT OTHERWISE CLASSIFIED (HNOC): UNKNOWN ACUTE TOXICITY: Not applicable. GHS SYMBOL: Corrosive Category 1 - May be corrosive to metals Category 1A - Causes severe skin burns and eye damage Category 1 - Causes serious eye damage -Aquatic Acute: Cateqorv 3 (Harmful to aquatic life) GHS SIGNAL WORD: DANGER GHS HAZARD STATEMENTS: GHS - Physical Hazard Statement(s) May be corrosive to metals GHS - Health Hazard Statement(s) Causes severe skin burns and eye damage Additional Hazards - GHS Hazards Not Otherwise Classified (HNOC): ACUTE AQUATIC HAZARD - CATEGORY 3: Harmful to aquatic life GHS - Precautionary Statement(s) - Prevention Keep only in original container or container compatible with product (see Section 7 - Safe Storage Conditions) Do not breathe dust/fume/gas/mist/vapors/spray Wash hands and exposed skin and clothing thoroughly after handling. Do not touch eyes Wear protective gloves, protective clothing, eye, and face protection Avoid release to the environment GHS - Precautionary Statement(s) - Response IF SWALLOWED: Rinse mouth. Do NOT induce vomiting _________________________________________________________________________________________________ Print date: 21-Jun-2024 3 of 21 North America EN CAUSTIC SODA LIQUID (ALL GRADES) SDS No.: M32415 Rev. Date: 21-Jun-2024 Supersedes Date: 2022-14-March Rev. Num. 12 _________________________________________________________________________________________________ IF INHALED: Remove person to fresh air and keep comfortable for breathing IF ON SKIN: Take off immediately all contaminated clothing. Immediately rinse with water for several minutes Wash contaminated clothing before reuse IF ON SKIN: Get medical help immediately Specific treatment (see "Notes to Physician" in Section 4 of the SDS) IF IN EYES: Immediately rinse with water for several minutes. Remove contact lenses, if present and easy to do. Continue rinsing IF IN EYES: Get medical help Absorb spillage to prevent material damage GHS - Precautionary Statement(s) - Storage Store locked up Store in corrosive resistant and NON-ALUMINUM container with a resistant inner liner (NOTE: gas may be generated if aluminum container and/or aluminum fittings are used) flammable hydrogen GHS - Precautionary Statement(s) - Disposal Dispose of contents and container in accordance with applicable local, regional, national, and/or international regulations Physical Hazards of Significance Not Mentioned in GHS Classification Mixing with water may cause splattering and release of heat MAYBE CORROSIVE TO METALS Health Hazards of Significance Not Mentioned in GHS Classification Acute exposure may cause delayed chemical burns Additional Hazard Information Contact may cause delayed chemical burns PBT and vPvB assessment: This product does not fulfill the criteria for persistence, bioaccumulation, and toxicity. Therefore, this substance is not considered a PBT or a vPvB substance Component Sodium Hydroxide Sodium Chloride U.S. - CERCLA/SARA - Section 313 - PBT Chemical Listing Not listed Not listed EU - PBT / vPvB Status PBT/PvBT assessment does not apply Considered NOT to be an EU PBT PBT/PvBT assessment does not apply Considered NOT to be an EU PBT Endocrine Disruptor Assessment: This product nor any of its ingredients which may be present at a concentration equal to or greater than 0.1 wt.% by weight are included in the lists established in accordance with Article 59(1) of Regulation (EU) 2020/878 [as having endocrine disrupting properties]; therefore, this substance shall not be identified as having endocrine disrupting properties. _________________________________________________________________________________________________ Print date: 21-Jun-2024 4 of 21 North America EN CAUSTIC SODA LIQUID (ALL GRADES) SDS No.: M32415 Rev. Date: 21-Jun-2024 Supersedes Date: 2022-14-March Rev. Num. 12 _________________________________________________________________________________________________ See Section 11: TOXICOLOGICAL INFORMATION _________________________________________________________________________________________________ SECTION 3. COMPOSITION/INFORMATION ON INGREDIENTS _________________________________________________________________________________________________ Component Systematic Chemical Common name CAS Number Name Water Dihydrogen monoxide Water 7732-18-5 7732-18-5 (H2O) Sodium Hydroxide Sodium hydroxide Sodium hydroxide 1310-73-2 1310-73-2 Sodium Chloride Sodium Chloride (NaCl) Sodium Chloride (Salt) 7647-14-5 7647-14-5 Notes: All hazardous and non-hazardous components of product composition are listed. Percent [%] 48.5 - 94.5 5.5 - 51.5 0 - 15 _________________________________________________________________________________________________ SECTION 4. FIRST AID MEASURES _________________________________________________________________________________________________ General Advice: Corrosive. This material may be corrosive to any tissue it comes in contact with. It can cause serious burns and extensive tissue destruction resulting in liquefaction, necrosis, and/or perforation. Immediate medical attention is required. EYE CONTACT: IF IN EYES: Immediately rinse with water for several minutes. Remove contact lenses, if present and easy to do. Continue rinsing. IF IN EYES: Get medical help. Washing eyes within several seconds of exposure is essential to achieve maximum effectiveness. Immediate decontamination of the eyes is essential. Irrigate for at least 30 minutes, continuing until the pH is between 7 and 8. Examine the eye with fluorescein stain and slit-lamp microscope. All patients should be reviewed the following day. Any evidence of injury requires specialist ophthalmological assessment. Follow standard protocols for the management of corrosive eye injury. SKIN CONTACT: IF ON SKIN: Take off immediately all contaminated clothing. Immediately rinse with water for several minutes. Wash contaminated clothing before reuse. IF ON SKIN: Get medical help immediately. Specific treatment (see "Notes to Physician" in Section 4 of the SDS below). Treat skin burns following standard protocols for thermal burns. Thoroughly clean and dry contaminated clothing before reuse. Discard contaminated leather goods. INHALATION: IF INHALED: Remove person to fresh air and keep comfortable for breathing. IF INHALED: Get medical help. There is no specific antidote, treat symptomatically. Monitor symptomatic patients for increasing upper airway obstruction. Administer humidified oxygen to all patients with respiratory symptoms and manage bronchospasm and chemical pneumonitis according to standard recommendations. In severe cases, early intubation and positive end expiratory pressure ventilation or other mechanical support can be required, or tracheostomy if intubation is unsuccessful or delayed. INGESTION: IF SWALLOWED: Rinse mouth. Do NOT induce vomiting. IF SWALLOWED: Get medical help. For definite or probable ingestion, do not administer oral fluids. If vomiting occurs spontaneously, keep airway clear. Monitor airway. Volume resuscitation (IV fluids) and circulatory support (CPR) may be required. Never give anything _________________________________________________________________________________________________ Print date: 21-Jun-2024 5 of 21 North America EN CAUSTIC SODA LIQUID (ALL GRADES) SDS No.: M32415 Rev. Date: 21-Jun-2024 Supersedes Date: 2022-14-March Rev. Num. 12 _________________________________________________________________________________________________ by mouth to an unconscious or convulsive person. Most Important Symptoms/Effects (Acute and Chronic [Delayed]): Corrosive. This material may be corrosive to any tissue it comes in contact with. It can cause serious burns and extensive tissue destruction resulting in liquefaction, necrosis, and/or perforation. Acute Symptoms/Effects: Eye: Serious Eye Damage. Eye exposures may cause eyelid burns, conjunctivitis, corneal edema, corneal burn, corneal perforation, damage to internal contents of the eye, permanent visual defects, and blindness and/or loss of the eye. Skin: Skin Corrosion. Exposure to skin may cause redness, itching, irritation, swelling, burns (first, second, or third degree), liquefaction of skin, and damage to underlying tissues (deep and painful wounds). Inhalation (Breathing): Respiratory System Effects: Exposure to airborne material may cause irritation, redness of upper and lower airways, coughing, laryngeospasm, shortness of breath, bronchoconstriction, and possible pulmonary edema. Severe and permanent scarring may occur. Pulmonary edema may develop several hours after a severe acute exposure. Aspiration of this material may cause the same conditions. Ingestion (Swallowing): Gastrointestinal System Effects: Exposure by ingestion may cause irritation, swelling, and perforation of upper and lower gastrointestinal tissues. Permanent scarring may occur. Chronic (Delayed) Symptoms/Effects: Skin: Repeated and prolonged skin contact may cause a chronic dermatitis. Target Organ Effects: Eyes. Skin. Protection of First-Aid Responders: Protect yourself by avoiding contact with this material. Avoid contact with skin and eyes. Do not breathe vapors or spray mist. Do not ingest. Use personal protective equipment (PPE). Refer to Section 8 for specific PPE recommendations. At minimum, treating personnel should utilize PPE sufficient for prevention of bloodborne pathogen transmission. Notes to Physician: Medical observation and assessment is recommended for all ingestions, all eye exposures, and symptomatic inhalation and dermal exposures. For symptomatic ingestion, do not administer oral fluids and consider investigation by endoscopy, X-ray, or CT scan. Esophageal perforation, airway compromise, hypotension, and shock are possible. For prolonged exposures and significant exposures, consider delayed injury to exposed tissues. There is no antidote. Treatment is supportive care. Follow normal parameters for airway, breathing, and circulation. Surgical intervention may be required. Interaction with Other Chemicals Which Enhance Toxicity: No interaction with other chemicals which enhance toxicity are known. Medical Conditions Aggravated by Exposure: May aggravate preexisting conditions such as eye disorders that decrease tear production or have reduced integrity of the eye; skin disorders that compromise the integrity of the skin; and respiratory conditions including asthma and other breathing disorders. _________________________________________________________________________________________________ SECTION 5. FIRE FIGHTING MEASURES _________________________________________________________________________________________________ _________________________________________________________________________________________________ Print date: 21-Jun-2024 6 of 21 North America EN CAUSTIC SODA LIQUID (ALL GRADES) SDS No.: M32415 Rev. Date: 21-Jun-2024 Supersedes Date: 2022-14-March Rev. Num. 12 _________________________________________________________________________________________________ Explosive properties: This product is not combustible or explosive. Extinguishing Media: Use extinguishing agents appropriate for surrounding fire. Use "alcohol" foam, dry chemical or carbon dioxide. Unsuitable Extinguishing Media: Do not use water, will create an exothermic reaction. Water may create an alkaline solution which could impact waterways and aquatic species. Specific Hazards: Sodium hydroxide in contact with water may generate enough heat to ignite adjacent combustible materials. Non-combustible, substance itself does not burn but may decompose upon heating to produce corrosive and/or toxic fumes. May react with chemically reactive metals such as aluminum, zinc, magnesium, copper, etc. to release hydrogen gas which can form explosive mixtures in air. Unusual Hazards: Violent steam generation or eruption may occur upon application of direct water stream to hot liquids. Fire Fighting: Move container from fire area if it can be done without risk. Cool containers with water. Do not apply water directly on this product. Heat is generated when mixed with water. Wear NIOSH approved positive-pressure self contained breathing apparatus operated in pressure demand mode. Avoid contact with skin. Keep water runoff out of water supplies and sewers (see Section 6 of the SDS). Advice for Firefighters: As in any fire, wear self-contained breathing apparatus pressure-demand, MSHA/NIOSH (approved or equivalent) and full protective gear. Avoid contact with skin and eyes. Component Immediately Dangerous to Life/ Health (IDLH) Sodium Hydroxide 10 mg/m3 IDLH 1310-73-2 Above are IDLHs (immediately dangerous to life or health concentrations) for those substances designated by United States (US) National Institute of Occupational Safety and Health (NIOSH). The IDLH is considered a maximum concentration above which only a highly reliable breathing apparatus providing maximum worker protection should be permitted. Hazardous Combustion Products: Sodium hydroxide fumes can be generated by thermal decomposition at elevated temperatures Sensitivity to Mechanical Impact: Not sensitive. Sensitivity to Static Discharge: Not sensitive. Lower Flammability Level (air): Not flammable Upper Flammability Level (air): Not flammable Flash point: Not flammable Auto-ignition Temperature: Not applicable GHS: PHYSICAL HAZARDS: - Category 1 - May be corrosive to metals Physical Hazards of Significance Not Mentioned in GHS Classification - Mixing with water may cause splattering and release of heat - MAY BE CORROSIVE TO METALS _________________________________________________________________________________________________ Print date: 21-Jun-2024 7 of 21 North America EN CAUSTIC SODA LIQUID (ALL GRADES) SDS No.: M32415 Rev. Date: 21-Jun-2024 Supersedes Date: 2022-14-March Rev. Num. 12 _________________________________________________________________________________________________ _________________________________________________________________________________________________ SECTION 6. ACCIDENTAL RELEASE MEASURES _________________________________________________________________________________________________ Personal Precautions: Avoid contact with skin, eyes and clothing. Do not breathe vapors, mist, or spray. Wash skin and contaminated clothing thoroughly after handling. Wash thoroughly after handling- exposure can cause burns which are not immediately painful or visible. Isolate area. Keep unnecessary and unprotected personnel from entering the area. Use appropriate safety equipment. For additional information, refer to Section 8, Exposure Controls and Personal Protection. Refer to Section 7, Handling, for additional precautionary measures. Take any precaution to avoid mixing with combustibles or incompatible materials. Ensure adequate ventilation, especially in confined areas. Personal Protective Equipment: Wear protective gloves, footwear, clothing, eye, and face protection. Emergency Procedures: All transfer facilities should have a documented spill prevention and containment program for all hazardous materials. Consideration must be given to the containment of caustic spills and leaks to comply with applicable federal, state, and local regulations. Environmental Precautions: Keep out of water supplies and sewers. Do not flush into surface water or sanitary sewer system. This material is alkaline and may raise the pH of surface waters with low buffering capacity. Releases should be reported, if required, to appropriate agencies. Methods and Materials for Containment, Confinement, and/or Abatement: Ventilate and contain spill to prevent spread. Completely contain spilled materials with dikes, sandbags, etc. After containment, collect the spilled material and transfer to a chemical waste area. Take any precaution to avoid mixing with combustibles or incompatible materials. Methods and Materials for Clean-up Recovery: In case of spill or leak, stop the leak as soon as possible. Small and large spills: Contain spilled material if possible. After containment, collect the spilled material and transfer to a chemical waste area. Liquid material may be removed with a properly rated vacuum truck. The recovered product must be transferred to an appropriate and compatible container (carbon steel, stainless steel, PVC, Fiberglass or similar). Seal and label container. Neutralization: Neutralize residue with dilute acid and follow with a liberal covering of sodium bicarbonate or other acceptable drying agent. See Section 13, Disposal considerations, for additional information. Final Disposal: Shovel dry material into suitable container. Recycle or dispose according to regulations. Additional Disaster Prevention Measures: Use caution when selecting spill absorbents. Liquids with this reactive group classification have been known to react with the absorbents such as cellulose-based absorbents and mineral-based and clay-based absorbents. All storage tanks should be diked to contain the tank contents in the event of a spill or tank rupture. They should be large enough to contain the tank's volume, and an additional appropriate volume as a safety factor. Review regulations prior to construction. _________________________________________________________________________________________________ SECTION 7. HANDLING AND STORAGE _________________________________________________________________________________________________ _________________________________________________________________________________________________ Print date: 21-Jun-2024 8 of 21 North America EN CAUSTIC SODA LIQUID (ALL GRADES) SDS No.: M32415 Rev. Date: 21-Jun-2024 Supersedes Date: 2022-14-March Rev. Num. 12 _________________________________________________________________________________________________ Handling: Precautions for Safe Handling: In handling caustic soda solutions, care must be taken to avoid solidification which will plug pipelines and equipment. Refer to manufacturer's Caustic Soda Handbook for more information on freezing points for solutions of caustic soda at various concentrations. Should a caustic soda solution become frozen in process equipment or piping, care must be taken when thawing the material. The use of atmospheric pressure steam is suggested. Accelerated corrosion can occur in areas where equipment is subjected to extremely high temperatures. Running steam through unlined steel piping systems can result in increased corrosion and iron pickup in the product. Never put water or steam directly into the product. Technical measures/precautions: Weld pipelines where practical. Use flanged joints with gaskets made of caustic soda resistant material such as rubber, PTFE, or EPDM rubber. If a screwed fitting is used, apply Teflon tape to the threads. Shield the seal area of pumps to prevent spraying of caustic solutions in the event of a leak. Unloading lines should be insulated and heated when used to transfer liquid caustic soda to storage in cold climates. The preferred method of heating is to provide electric or steam heat tracing around the unloading line, under the insulation. Other precautions: When disconnecting equipment for repairs, first verify that there is no internal pressure on the equipment and the equipment has been drained and washed. When releasing air pressure from a pressurized system, take every precaution to avoid spurts or sprays of caustic solution. Prevention of contact: Residues that dry on equipment can cause irritation. Keep equipment clean by washing off any accumulation. NEVER add water to product. When mixing, slowly add to water to minimize heat generation and spattering. Do not breathe mist, vapor, or spray. Wash skin and contaminated clothing thoroughly after handling. Wear protective gloves, footwear, clothing, eye, and face protection. See Section 8, Exposure Controls and Personal Protection, for additional information. Storage: Safe Storage Conditions: Store and handle in accordance with all current regulations and standards. Keep container tightly closed and properly labeled. Do not store in aluminum container, or use aluminum fittings or transfer lines, as flammable hydrogen gas may be generated. Keep separated from incompatible substances (see below or Section 10 of the Safety Data Sheet). Technical measures: Provide storage tanks with suitable overflow pipes. Overflow pipes should be directed to a protected overflow area away from operations. Prior to unloading shipment of caustic soda, make certain the storage tank has sufficient room available for the contents of the entire rail or tank car. Incompatible Substances: Acids and halogenated compounds, Prolonged contact with aluminum, brass, bronze, copper, lead, tin, zinc or other alkali sensitive metals or alloys, Releases heat when diluted in water or other solvents. Packaging or Materials of Construction: Recommended: High density polyethylene; fiberglass, steel lined internally with PVC, FRP or other similar and supported. Other corrosion resistant materials are titanium, tantalum and FRP. In addition, container should be equipped with adequate pressure release device. Materials not recommended: low density polyethylene; Brass, zinc, bronze, copper, aluminum, iron, and alloys of these metals. Additional Information: GHS: PHYSICAL HAZARDS: - Category 1 - May be corrosive to metals Physical Hazards of Significance Not Mentioned in GHS Classification - Mixing with water may cause splattering and release of heat - MAY BE CORROSIVE TO METALS _________________________________________________________________________________________________ Print date: 21-Jun-2024 9 of 21 North America EN CAUSTIC SODA LIQUID (ALL GRADES) SDS No.: M32415 Rev. Date: 21-Jun-2024 Supersedes Date: 2022-14-March Rev. Num. 12 _________________________________________________________________________________________________ _________________________________________________________________________________________________ SECTION 8. EXPOSURE CONTROLS / PERSONAL PROTECTION _________________________________________________________________________________________________ REGULATORY EXPOSURE LIMIT(S): Listed below for the product components that have regulatory occupational exposure limits (OEL's). Component OSHA Final PEL OSHA Final PEL OSHA Final PEL Ceiling TWA STEL Sodium Hydroxide 2 mg/m3 (TWA) mg/m3 1310-73-2 (5.5 - 51.5 %) OEL: Occupational Exposure Limit; OSHA: United States Occupational Safety and Health Administration; PEL: Permissible Exposure Limit; TWA: Time Weighted Average; STEL: Short Term Exposure Limit Component Sodium Hydroxide 1310-73-2 (5.5 - 51.5 %) Canada - TWAs Canada - STELs Canada - Ceilings Ontario 2 mg/m3 (Ceiling) NON-REGULATORY EXPOSURE LIMIT(S): One component of this product has ACGIH TLV value(s) recommended as advisory exposure limit(s). Component ACGIH ACGIH ACGIH Skin NIOSH AIHA OSHA OSHA OSHA TWA STEL Ceiling Absorptio RELs WEELs TWA STEL Ceiling n - ACGIH (Vacated) (Vacated) (Vacated) Sodium 2 mg/m3 2 mg/m3 2 mg/m3 Hydroxide (Ceiling) (Ceiling) 1310-73-2 (5.5 - 51.5 %) The Non-Regulatory United States Occupational Safety and Health Administration (OSHA) limits, if shown, are the Vacated 1989 PEL's (vacated by 58 FR 35338, June 30, 1993). OSHA Ceiling values indicate the exposure limit, which at no time shall be exceeded. Instantaneous monitoring is the preferred method to determine compliance with OSHA Ceiling values. If instantaneous monitoring is not feasible, then the ceiling shall be assessed as a 15-minute time weighted average exposure which shall not be exceeded at any time during the working day [29CFR1910.1000(a)(1)] The American Conference of Governmental Industrial Hygienists (ACGIH) is a voluntary organization of professional industrial hygiene personnel in government or educational institutions in the United States. The ACGIH develops and publishes recommended occupational exposure limits each year called Threshold Limit Values (TLVs) for hundreds of chemicals, physical agents, and biological exposure indices. ACGIH TLV Ceiling (C) limits are airborne concentrations that should not be exceeded in the workplace under any circumstances. Ceiling limits can supplement other limits or stand alone. ENGINEERING CONTROLS: Use closed systems when possible. Provide local exhaust ventilation where dust or mist may be generated. Ensure compliance with applicable exposure limits. PERSONAL PROTECTIVE EQUIPMENT: _________________________________________________________________________________________________ Print date: 21-Jun-2024 10 of 21 North America EN CAUSTIC SODA LIQUID (ALL GRADES) SDS No.: M32415 Rev. Date: 21-Jun-2024 Supersedes Date: 2022-14-March Rev. Num. 12 _________________________________________________________________________________________________ Eye Protection: Wear chemical safety goggles with a face shield to protect against eye and skin contact when appropriate. Provide an emergency eyewash fountain and quick drench shower in the immediate work area. Skin and Body Protection: Wear protective clothing to minimize skin contact. Wear chemical resistant clothing and rubber boots when potential for contact with the material exists. Always place pants legs over boots. Contaminated clothing should be removed, then discarded or laundered. Discard contaminated leather goods. Hand Protection: Wear appropriate chemical resistant gloves. If contact with forearms is likely, wear gauntlet style gloves. Consult a glove supplier for assistance in selecting an appropriate chemical resistant glove. Protective Material Types: Natural rubber, Neoprene, Nitrile, Polyvinyl chloride (PVC), Tyvek, Tychem. Respiratory Protection: Where risk assessment shows air-purifying respirators are appropriate, use a NIOSH approved full-facepiece respirator with an N100, R100, or P100 filter. For an emergency or planned entry into unknown concentrations or IDLH conditions, use any self-contained breathing apparatus (SCBA) that has a full facepiece and is operated in a pressure-demand or other positive-pressure mode OR any supplied-air respirator that has a full facepiece and is operated in a pressure-demand or other positive-pressure mode in combination with an auxiliary self-contained positive-pressure breathing apparatus (e.g. airline with auxiliary escape pack). A respiratory protection program that meets 29 CFR 1910.134 must be followed whenever workplace conditions warrant use of a respirator. Component Immediately Dangerous to Life/ Health (IDLH) Sodium Hydroxide 10 mg/m3 IDLH 1310-73-2 (5.5 - 51.5 %) Above are IDLHs (immediately dangerous to life or health concentrations) for those substances designated by United States (US) National Institute of Occupational Safety and Health (NIOSH). The IDLH is considered a maximum concentration above which only a highly reliable breathing apparatus providing maximum worker protection should be permitted. Other Protective Equipment: Provide an emergency eyewash fountain and quick drench shower in the immediate work area. HYGIENE MEASURES: Do not breathe mist, vapors, or spray. Do not get in eyes, on skin, or on clothing. Wear protective gloves, protective clothing, eye, and face protection. For environmental protection remove and wash all contaminated protective equipment before re-use. Use outdoors or in a well-ventilated area. Keep separated from incompatible substances. _________________________________________________________________________________________________ SECTION 9. PHYSICAL AND CHEMICAL PROPERTIES _________________________________________________________________________________________________ Appearance: Physical State: Color: Odor: Odor Threshold [ppm]: Melting Point/Range: Freezing Point/Range: Boiling point / boiling range Clear to opaque Liquid Colorless to slightly colored Odorless No data available No data available -32 to 15C (-26 to 59F) [50% solution] 102 - 144C (215 - 291F) [50% solution] _________________________________________________________________________________________________ Print date: 21-Jun-2024 11 of 21 North America EN CAUSTIC SODA LIQUID (ALL GRADES) SDS No.: M32415 Rev. Date: 21-Jun-2024 Supersedes Date: 2022-14-March Rev. Num. 12 _________________________________________________________________________________________________ Evaporation Rate (ether=1): Flammability (solid, gas): Lower Flammability Level (air): Upper Flammability Level (air): Explosion limits: Flash point: Auto-ignition Temperature: Decomposition Temperature: pH: Viscosity: Kinematic viscosity Water Solubility: Partition Coefficient (n-octanol/water): Vapor Pressure: Density: Relative Density/Specific Gravity (water=1): Vapor Density (air=1): Particle Size Distribution: Other Information Molecular Formula: Chemical Family: Molecular Weight: Explosive properties: Oxidizing properties: VOC Content (%): Volatility: No information available. Not applicable Not flammable Not flammable Not applicable Not flammable Not applicable No information available. 14.0 (7.5% solution) About 24cp for 50% solution at 40 C (104 F) No data available Water: 100% No information available. 13 - 135 mmHg @ 60 C 8.8 - 13.0 lbs/gal @ 15.6 C 1.05-1.56@ 15.6 c No data available Not applicable NaOH Alkali Metal Hydroxide Solutions 40.01 Not applicable. Not applicable. 0% Not available Refer to manufacturer's Caustic Soda Handbook for more information on physical and chemical properties for solutions of caustic soda at various concentrations and temperatures. _________________________________________________________________________________________________ SECTION 10. STABILITY AND REACTIVITY _________________________________________________________________________________________________ Chemical Stability: Stable at normal temperatures and pressures. Reactivity: Soluble in water, releasing heat sufficient to ignite combustibles. Reacts with metals and may form hydrogen gas. Reacts with acids, giving off heat. Possibility of Hazardous Reactions: May react with chemically reactive metals such as aluminum, zinc, magnesium, copper, etc. to release hydrogen gas which can form explosive mixtures in air. Mixing with water, acid, or incompatible materials may cause splattering and release of large amounts of heat. Will react with some metals forming flammable hydrogen gas. Carbon monoxide gas may form upon contact with reducing sugars, food and beverage products in enclosed spaces. Accidental contact of 50% sodium hydroxide solution with residual trichloroethanol in a pump caused an explosion. This was confirmed in laboratory experiments. Chlorohydroxyacetylene, the isomeric chloroketene or chlorooxirene, may have been formed by elimination of hydrogen chloride. In addition, reacts to form explosive products with ammonia + silver nitrate (forms silver nitride); N,N'-bis(trinitroethyl)urea (in storage). _________________________________________________________________________________________________ Print date: 21-Jun-2024 12 of 21 North America EN CAUSTIC SODA LIQUID (ALL GRADES) SDS No.: M32415 Rev. Date: 21-Jun-2024 Supersedes Date: 2022-14-March Rev. Num. 12 _________________________________________________________________________________________________ Conditions to Avoid (e.g., static discharge, shock, or vibration): No information available. Incompatible Substances: Acids and halogenated compounds, Prolonged contact with aluminum, brass, bronze, copper, lead, tin, zinc or other alkali sensitive metals or alloys, Releases heat when diluted in water or other solvents. Hazardous Decomposition Products: Toxic fumes of sodium oxide. Hazardous Polymerization: Will not occur. _________________________________________________________________________________________________ SECTION 11. TOXICOLOGICAL INFORMATION _________________________________________________________________________________________________ POTENTIAL HEALTH EFFECTS: TOXICITY: When in solution, this material will affect all tissues with which it comes in contact. The severity of the tissue damage is a function of its concentration, the length of tissue contact time, and local tissue conditions. After exposure, there may be a time delay before irritation and other effects occur. This material is a strong irritant and is corrosive to the skin, eyes, and mucus membranes. This material may cause severe burns and permanent damage to any tissue with which it comes into contact. ACUTE TOXICITY: Eye contact: This material is corrosive to the eye. Causes serious eye damage, which can result in severe irritation, pain and burns, and permanent damage including blindness. Skin contact: This material is corrosive to the skin. Causes severe skin burns. Prolonged or repeat skin exposures can result in dermatitis. Inhalation: This material can be extremely destructive to the tissue of the mucus membranes and respiratory system. Inhalation injury may result from ingestion and/or aspiration of this material. May cause severe irritation of the respiratory tract with potential airway compromise, coughing, choking, pain, and burns of the mucous membrane and respiratory system. Aspiration may cause chemical pneumonitis, pulmonary edema, damage to lung tissue, death. Ingestion: Following ingestion, onset of gastrointestinal symptoms is usually rapid and related to local mucosal irritation and development of corrosive injury. If swallowed, may cause severe oral and esophageal, mucus membrane, and gastrointestinal burns and possible perforation. If swallowed, may pose a lung aspiration hazard during vomiting. CHRONIC TOXICITY: Chronic Effects: Repeated or prolonged skin contact may result in dermatitis. SIGNS AND SYMPTOMS OF EXPOSURE: This material may cause severe burns and permanent damage to any tissue with which it comes into contact. It can cause serious burns and extensive tissue destruction resulting in liquefaction, necrosis and/or perforation. Signs and symptoms of exposure vary, and are dependent on the route of exposure, degree of exposure, and duration of exposure. Inhalation (Breathing): Respiratory System Effects: Exposure to airborne material may cause irritation, redness _________________________________________________________________________________________________ Print date: 21-Jun-2024 13 of 21 North America EN CAUSTIC SODA LIQUID (ALL GRADES) SDS No.: M32415 Rev. Date: 21-Jun-2024 Supersedes Date: 2022-14-March Rev. Num. 12 _________________________________________________________________________________________________ of upper and lower airways, coughing, laryngeospasm, shortness of breath, bronchoconstriction, and possible pulmonary edema. Severe and permanent scarring may occur. Pulmonary edema may develop several hours after a severe acute exposure. Aspiration of this material may cause the same conditions. Skin: Skin Corrosion. Exposure to skin may cause redness, itching, irritation, swelling, burns (first, second, or third degree), liquefaction of skin, and damage to underlying tissues (deep and painful wounds). Eye: Serious Eye Damage. Eye exposures may cause eyelid burns, conjunctivitis, corneal edema, corneal burn, corneal perforation, damage to internal contents of the eye, permanent visual defects, and blindness and/or loss of the eye. Ingestion (Swallowing): Gastrointestinal System Effects: Exposure by ingestion may cause irritation, swelling, and perforation of upper and lower gastrointestinal tissues. Permanent scarring may occur. Interaction with Other Chemicals Which Enhance Toxicity: No interaction with other chemicals which enhance toxicity are known. GHS HEALTH HAZARDS: GHS: CONTACT HAZARD - SKIN: Category 1A - Causes severe skin burns and eye damage GHS: CONTACT HAZARD - EYE: Category 1 - Causes serious eye damage TOXICITY DATA: PRODUCT TOXICITY DATA: There is no product level data available at this time LD50 Oral: LD50 Dermal: No reliable data available No reliable data available LC50 Inhalation: No data available COMPONENT TOXICITY DATA: The data are from public databases sources Component Sodium Hydroxide 1310-73-2 Sodium Chloride 7647-14-5 Oral LD50 325 mg/kg (Rat) 3 g/kg (Rat) Dermal LD50 1350 mg/kg (Rabbit) >10000 mg/kg (Rabbit) Inhalation LC50 No data available >42 mg/L (1-h Rat) EYE IRRITATION/CORROSION: Corrosive to the eyes and may cause severe damage including blindness. Standard Draize (Eye): PRIMARY EYE IRRITATION: Severe Irritation, Corrosive (rabbit, 24 hr). SKIN IRRITATION/CORROSION: This product is classified as causing severe skin burns (Category 1, H314), according to GHS classification criteria. Standard Draize (Skin): PRIMARY SKIN IRRITATION: Severe Irritation, Corrosive (rabbit, 24 hr) SKIN ABSORBENT/DERMAL ROUTE: NO. Material is corrosive to the skin and will produce damage to the skin prior to systemic effects being observed. RESPIRATORY OR SKIN SENSITIZATION: Not Known. No evidence of skin sensitization was seen in either human or laboratory animal exposure studies to sodium hydroxide. _________________________________________________________________________________________________ Print date: 21-Jun-2024 14 of 21 North America EN CAUSTIC SODA LIQUID (ALL GRADES) SDS No.: M32415 Rev. Date: 21-Jun-2024 Supersedes Date: 2022-14-March Rev. Num. 12 _________________________________________________________________________________________________ CARCINOGENICITY: This product is not classified as a carcinogen by NTP, IARC or OSHA. Systemic carcinogenicity is not expected to occur because in water and other biological matrices, sodium hydroxide (NaOH) will hydrolyze to the sodium and hydrogen ions. NaOH is not systemically available under normal conditions. SPECIFIC TARGET ORGAN TOXICITY (Single Exposure): Although there is a case report of a worker who developed irreversible obstructive lung disease after exposure to 5% sodium hydroxide (NaOH) aerosols in a poorly ventilated room, this is a single case report. The effects observed are related to the corrosivity and not specifically to an effect of NaOH. SPECIFIC TARGET ORGAN TOXICITY (Repeated or Prolonged Exposure): Sodium hydroxide may cause irreversible obstructive airway disease after long term (for 20 years) regular unprotected exposure (no respiratory protective equipment); however, this outcome is due to a bronchial inflammatory reaction caused by the corrosive effects of sodium hydroxide and is not considered a systemic health outcome. Systemic health effects are not expected under normal handling and use conditions (non-irritating) because the concentration of sodium in the blood nor the pH of the blood will be increased. INHALATION HAZARD: Exposure to airborne material may cause irritation, redness of upper and lower airways, coughing, laryngeal spasm and edema, shortness of breath, bronchio-constriction, and possible pulmonary edema. The pulmonary edema may develop several hours after a severe acute exposure. INGESTION HAZARD: The existing animal and human data on acute toxicity show that NaOH has a local effect and that systemic effects are not to be expected. The corrosivity classification represents sufficient warning. If humans are exposed to a low concentration (e.g., one that is non-irritating, or non-corrosive), via the oral route it is expected that the hydroxide will be neutralized in the stomach by gastric juice, which already has a very low pH. GERM CELL/IN-VITRO MUTAGENICITY: Sodium hydroxide was negative in an in vitro Ames reversion assay without metabolic activation. In another in vitro study, exposure of Chinese hamster ovary cells to Sodium hydroxide with metabolic activation resulted in chromosomal aberrations in 7.8% of the 400 cells scored. The chromosome aberration frequency increased to 17% along the S9 concentration, but excessive cell toxicity was not seen, and the authors concluded that the mutagenic response was due to the combined effects of pH and metabolic activation, and not to the mutagenicity of Sodium hydroxide.The available data do not meet the classification criteria for Germ Cell Mutagenicity. REPRODUCTIVE TOXICITY: Sodium Hydroxide is not expected to be systematically available in the body under normal handling and use conditions and for this reason it can be stated that the substance will not reach the fetus nor male or female reproductive organs. DEVELOPMENTAL TOXICITY: Not classified as a developmental or reproductive toxin per GHS criteria. ASPIRATION HAZARD: The product is not classified as an inhalation hazard, according to criteria of the GHS. TOXICOKINETICS: Not available. METABOLISM: Not available. BIOLOGICAL DISTRIBUTION: No information available. PATHOGENICITY AND ACUTE INFECTIOUSNESS (ORAL, DERMAL, AND INHALATION): Not applicable. ENDOCRINE DISRUPTOR: This product does not contain any known or suspected endocrine disruptors. _________________________________________________________________________________________________ Print date: 21-Jun-2024 15 of 21 North America EN CAUSTIC SODA LIQUID (ALL GRADES) SDS No.: M32415 Rev. Date: 21-Jun-2024 Supersedes Date: 2022-14-March Rev. Num. 12 _________________________________________________________________________________________________ NEUROTOXICITY: Not Available. IMMUNOTOXICITY: Not available. Health Hazards of Significance Not Mentioned in GHS Classification Acute exposure may cause delayed chemical burns _________________________________________________________________________________________________ SECTION 12. ECOLOGICAL INFORMATION _________________________________________________________________________________________________ ECOTOXICITY (EC, IC, and LC): Component: Freshwater Fish: Invertebrate Algae Toxicity: Other Toxicity: Toxicitv: Sodium Hydroxide *LC50 Oncorhynchus No data available No data available No data available 1310-73-2 (5.5 - 51.5 %) mykiss: 45.4 mg/L 96h static Sodium Chloride *LC50 Oncorhynchus *EC50 Daphnia No data available *LC50 Eisenia foetida 7647-14-5 (0 - 15 %) mykiss: 4747 - 7824 magna: 340.7 - 469.2 (48 h filter paper) 0.1 mg/L 96h mg/L 48h *EC50 -1 mg/cm2 flow-through *LC50 Daphnia magna: 1000 Lepomis macrochirus: 5560 - 6080 mg/L 96h flow-through *LC50 mg/L 48h Pimephales promelas: 6020 - 7070 mg/L 96h static *LC50 Pimephales promelas: 6420 - 6700 mg/L 96h static *LC50 Lepomis macrochirus: 12946 mg/L 96h static *LC50 Pimephales promelas: 7050 mg/L 96h semi-static Aquatic Toxicity: In water, Sodium Hydroxide (NaOH) will hydrolyze to the sodium and hydrogen ions and do not represent a specific hazard. The buffering capability of the environmental compartment will determine the extent of the toxicological response Data provided are for sodium hydroxide Fish Toxicity: LC50 Brook trout: 25 ppm/24 hr LC50 King salmon: 48 ppm Invertebrate Toxicity: EC50 Daphnia magna: 100 ppm EC50 Shrimp: 33 - 100 ppm/48 hr. _________________________________________________________________________________________________ Print date: 21-Jun-2024 16 of 21 North America EN CAUSTIC SODA LIQUID (ALL GRADES) SDS No.: M32415 Rev. Date: 21-Jun-2024 Supersedes Date: 2022-14-March Rev. Num. 12 _________________________________________________________________________________________________ EC50 Cockle: 330 - 1000 ppm/48 hr. FATE AND TRANSPORT: PERSISTENCE: This material is alkaline and may raise the pH of surface waters with low buffering capacity. This material is believed to exist in the disassociated state in the environment. BIODEGRADATION: This material is inorganic and not subject to biodegradation. BIOCONCENTRATION: This material is not expected to bioconcentrate in organisms. BIOACCUMULATIVE POTENTIAL: Does not bioaccumulate. MOBILITY IN SOIL: NaOH is a strong alkaline substance that dissociates completely in water to Na+ and OH-. High water solubility and low vapor pressure indicate that NaOH will be found predominantly in aquatic environment. This implies that it will not adsorb on particulate matter or surfaces. Atmospheric emissions as aerosols are rapidly neutralized by carbon dioxide and the salts will be washed out by rain. ADDITIONAL ECOLOGICAL INFORMATION: This material has exhibited slight toxicity to terrestrial organisms. This material has exhibited moderate toxicity to aquatic organisms. PBT and vPvB assessment: This product does not fulfill the criteria for persistence, bioaccumulation, and toxicity. Therefore, this substance is not considered a PBT or a vPvB substance. _________________________________________________________________________________________________ SECTION 13. DISPOSAL CONSIDERATIONS _________________________________________________________________________________________________ Waste from material: Reuse or reprocess, if possible. Keep out of water supplies and sewers. May be subject to disposal regulations. Dispose in accordance with all applicable regulations. Container Management: Dispose of container in accordance with applicable local, regional, national, and/or international regulations. Container rinsate must be disposed of in compliance with applicable regulations. Contaminated Material: Contaminated packaging should be disposed of as unused product. _________________________________________________________________________________________________ SECTION 14. TRANSPORT INFORMATION _________________________________________________________________________________________________ LAND TRANSPORT _________________________________________________________________________________________________ Print date: 21-Jun-2024 17 of 21 North America EN CAUSTIC SODA LIQUID (ALL GRADES) SDS No.: M32415 Rev. Date: 21-Jun-2024 Supersedes Date: 2022-14-March Rev. Num. 12 _________________________________________________________________________________________________ U.S. DOT 49 CFR 172.101: UN NUMBER: UN1824 PROPER SHIPPING NAME: Sodium Hydroxide Solution HAZARD CLASS/ DIVISION: 8 PACKING GROUP: II LABELING REQUIREMENTS: 8 RQ (Lbs.): RQ 1000 lbs. (Sodium Hydroxide) Special provisions for Always transport in closed containers that are upright and secure. Make sure transport: people transporting the product know what to do in case of an accident or spill. CANADIAN TRANSPORTATION OF DANGEROUS GOODS: UN NUMBER: UN1824 SHIPPING NAME: Sodium hydroxide solution CLASS OR DIVISION: 8 PACKING/RISK GROUP: II LABELING REQUIREMENTS: 8 MARITIME TRANSPORT (IMO / IMDG) UN NUMBER: UN1824 PROPER SHIPPING NAME: Sodium hydroxide solution HAZARD CLASS / DIVISION: Class 8: Corrosive Substance Packing Group: II LABELING REQUIREMENTS: 8 AIR TRANSPORT (ICAO / IATA) UN Number: UN1824 Proper shipping name: Sodium hydroxide solution Hazard Class: Class 8: Corrosive Substance Packing group: II Special Instructions CAO: IATA Certificate for shipping personnel is required Transport in bulk according to Annex II of MARPOL 73/78 and the IBC Code: The substance poses risks from the point of view of safety (S) and contamination (P). Classified as "Y", presents a danger to marine resources or human health. _________________________________________________________________________________________________ SECTION 15. REGULATORY INFORMATION _________________________________________________________________________________________________ U.S. REGULATIONS OSHA REGULATORY STATUS: This material is considered hazardous by the OSHA Hazard Communication Standard (29 CFR 1910.1200). CERCLA SECTIONS 102a/103 HAZARDOUS SUBSTANCES (40 CFR 302.4): If a release is reportable under CERCLA section 103, notify the state emergency response commission and local emergency planning committee. In addition, notify the National Response Center at (800) 424-8802 or (202) 426-2675. Component U.S. DOT Hazardous CERCLA Hazardous CERCLA Section 302 Section 302 Threshold _________________________________________________________________________________________________ Print date: 21-Jun-2024 18 of 21 North America EN CAUSTIC SODA LIQUID (ALL GRADES) SDS No.: M32415 Rev. Date: 21-Jun-2024 Supersedes Date: 2022-14-March Rev. Num. 12 _________________________________________________________________________________________________ Substances/ RQs Sodium Hydroxide 1000 lbs(RQ) 1310-73-2 (5.5 - 51.5 %) SARA EHS Chemical (40 CFR 355.30) No components are listed. Substances / RQs 1000 EHS EPCRA RQs Not listed Planning Quantity (TPQ) Not Listed SARA HAZARD CATEGORIES ALIGNED WITH GHS (2018): Physical Hazard - Corrosive to Metal Health Hazard - Skin Corrosion or Irritation Health Hazard - Serious eye damage or eye irritation EPCRA SECTION 313 (40 CFR 372.65): No components are listed. DEPARTMENT OF HOMELAND SECURITY (DHS)- Chemical Facility Anti-Terrorism Standards (6 CFR 27): No components in this material are regulated under DHS OSHA PROCESS SAFETY (PSM) (29 CFR 1910.119): Not regulated. FDA: This material has Generally Recognized As Safe (GRAS) status under specific U.S. Food and Drug Administration (FDA) regulations. Additional information is available from the Code of Federal Regulations, which is accessible on the FDA's website. Only food grade product is guaranteed to be produced under all current Good Manufacturing Practices (cGMP) requirements as defined by the FDA. Food grade product is produced in a facility that is accredited as a Safe Quality Food (SQF) Level 2 Facility, certified under the Global Food Safety Initiative (GFSI), and meets the Food Chemical Codex (FCC) requirements EPA'S CLEAN WATER AND CLEAN AIR ACTS: Component(s) not listed on impacted regulatory lists. NATIONAL INVENTORY STATUS U.S. INVENTORY STATUS: Toxic Substance Control Act (TSCA): Component Sodium Hydroxide 1310-73-2 (5.5 - 51.5 %) Sodium Chloride 7647-14-5 (0 - 15 %) TSCA Inventory TSCA ACTIVE LIST Listed ACTIVE Listed ACTIVE TSCA 12(b) TSCA/Section 4 TSCA/Section 5 TSCA/Section 6 TSCA/Section 8 Not Listed Not listed Not Listed Not Listed Not listed Not Listed Not listed Not Listed Not Listed Not listed Canadian Chemical Inventory: All components of this product are listed on either the DSL or the NDSL. Component Sodium Hydroxide 1310-73-2 (5.5 - 51.5) Sodium Chloride 7647-14-5 (0 - 15) DSL Listed Listed NDSL Not Listed Not Listed STATE REGULATIONS California Proposition 65: _________________________________________________________________________________________________ Print date: 21-Jun-2024 19 of 21 North America EN CAUSTIC SODA LIQUID (ALL GRADES) SDS No.: M32415 Rev. Date: 21-Jun-2024 Supersedes Date: 2022-14-March Rev. Num. 12 _________________________________________________________________________________________________ This product is not listed on the California Governor's current list of Carcinogens, Reproductive Toxicants, and/or Candidate Carcinogens (Proposition 65), but it may contain trace amounts of impurities that are listed. For additional information, contact Occidental Chemical Corporation Customer Service (1-800-752-5151 or 1-972-404-3700). Component U.S. - California Proposition 65 Carcinogens List CA. Prop. 65 Teratogen Sodium Hydroxide 1310-73-2 (5.5 - 51.5 %) Sodium Chloride 7647-14-5 (0 - 15 %) Not listed Not listed Not listed Not listed California Proposition 65 CRT List - Male reproductive toxin: Not Listed California Proposition 65 CRT List - Female reproductive toxin: Not Listed Massachusetts Right to Know Hazardous Substance List Listed Not Listed Not Listed Not Listed Rhode Island Right to Know Hazardous Substance List Listed Not Listed Component Sodium Hydroxide Sodium Chloride New Jersey Right to Know Hazardous Substance List 1706 Not Listed New Jersey Special Health Hazards Substance List corrosive Not Listed New Jersey Environmental Hazardous Substance List Not Listed Not Listed Pennsylvania Right to Know Hazardous Substance List Listed Not Listed Pennsylvania Pennsylvania Right to Know Right to Know Special Hazardous Environmental Substances Hazard List Not Listed Present Not Listed Not Listed CANADIAN REGULATIONS This product has been classified in accordance with the hazard criteria of the Workplace Hazardous Materials Information System (WHMIS 2015) which includes the amended Hazardous Products Act (HPA) and the Hazardous Product Regulations (HPR). Component Canada - CEPA - Canada - NPRI Canada - CEPA - Canadian Chemical NDSL Schedule I - List of Greenhouse Gases Inventory: Toxic Substances (GHG) Subject to Mandatory Reporting Sodium Hydroxide Not listed Not Listed Not Listed Listed Not Listed 1310-73-2 (5.5 - 51.5) Sodium Chloride Not listed Not Listed Not Listed Listed Not Listed 7647-14-5 (0 - 15) _________________________________________________________________________________________________ SECTION 16. OTHER INFORMATION _________________________________________________________________________________________________ Prepared by: Occidental Chemical Corporation - HES&S Product Stewardship Department Rev. Date: 21-Jun-2024 Reason for Revision: Corrected GHS by removing "Exclamation Symbol" SOS format adopts revisions to the Hazardous Products Regulations (HPR) to include revisions to "Section 9: Physical and chemical properties" and ensures classification with at a minimum the seventh revised edition of GHS and certain elements from the eighth revised edition (Revision 8) IMPORTANT: Important: The information presented herein, while not guaranteed, was prepared by technical personnel and is true _________________________________________________________________________________________________ Print date: 21-Jun-2024 20 of 21 North America EN CAUSTIC SODA LIQUID (ALL GRADES) SDS No.: M32415 Rev. Date: 21-Jun-2024 Supersedes Date: 2022-14-March Rev. Num. 12 _________________________________________________________________________________________________ and accurate to the best of our current knowledge. NO WARRANTY OF MERCHANTABILITY OR OF FITNESS FOR A PARTICULAR PURPOSE, OR WARRANTY OR GUARANTY OF ANY OTHER KIND, EXPRESS OR IMPLIED, IS MADE REGARDING PERFORMANCE, SAFETY, SUITABILITY, STABILITY OR OTHERWISE. This information is not intended to be all-inclusive as to the manner and conditions of use, handling, storage, disposal, and other factors that may involve other or additional legal, environmental, safety or performance considerations, and Occidental Chemical Corporation assumes no liability whatsoever for the use of or reliance upon this information. Appropriate handling and use of the product remains the responsibility of the customer. No suggestions for use are intended as, and nothing herein shall be construed as, a recommendation to infringe any existing patents or to violate any Federal, State, local or foreign laws. OSHA Standard 29 CFR 1910.1200 requires that information be provided to employees regarding the hazards of chemicals by means of a hazard communication program including labeling, safety data sheets, training and access to written records. We request that you, and it is your legal duty to, make all information in this Safety Data Sheet available to your employees. _________________________________________________________________________________________________ End of Safety Data Sheet _________________________________________________________________________________________________ Print date: 21-Jun-2024 21 of 21 APPENDIX 6. BWC HARVEY 4/29/2025 RESPONSE  Outlook BWC Terminals 1805 4th street Harvey LA Follow up from EPA visit 4/24/2025 From Scheidt, Dustin (Harvey) <dscheidt@bwcterminals.com> Date Tue 4/29/2025 11 :27 AM To Vince Damiano <Vince.Damiano@erg.com>; Thapa.Sandesh@epa.gov <Thapa.Sandesh@epa.gov>; Joe Watson <Joe.Watson@erg.com > Cc Pertuit, Walter (Harvey) <WPertuit@bwcterminals.com>; Chapman, Joshua (Harvey) <jchapman@bwcterminals.com > @ 19 attachments (12 MB) SDS Morelife.PDF; SDS Caustic.PDF; ghs tetrasodium edta msds.pdf; W6273X_SDS_EN_0S-24-2019.pdf; inside paint drumJpg; Paint drumJpg; pro-00vr3BswJpeg; pro-eC6biQGdJpeg; pro-Sn1O7ueYJpeg; pro-lFCbrUSPJpeg; pro-R9Y3QxfkJpeg; projmbaFMvqJpeg; pro-yqB1 eZrlJpeg; pro-7tl8bPBXJpeg; pro-DGRhwwh4Jpeg; IMG_7879Jpg; IMG_7885Jpg; IMG_7882Jpg; IMG_7881Jpg; CAUTION : Don 't open links or attachments unless you recognize the sender and know they are safe. Good Morning, My name is Dustin Scheidt, I am the terminal manager at our Harvey location that you visited on 4/24/2025. I would like to start off by apologizing for missing your visit, I was assisting another terminal that day. After discussing your visit with my operations manager i would like to give you information you requested. (Paint) This drum is full of old latex interior paint (See SOS) that was solidified with absorbent to turn into a solid. This paint drum will go out as a Non Haz solid when shipped. (Trtrasodium) This product is used for our boiler treatment to help fight rust build up, this drum is empty with salt on the bottom, these drums are usually picked up by the chemical company for drum reuse when they bring new drums of boiler chemical. This one must have been missed since we changed distributers. (this drum will be put with the reclaim drums until it is picked up) (Morlife/Amine) this drum is a Non Haz waste that will go out with the Non Haz shipment(drum is 99% water 1% product) (See SOS attached for raw material) The 2 drums "not" labeled were Asphalt/sand drums that were taken from the satellite area and put in the building the day before, drums have been labeled and staged appropriately. The Sodium Hydroxide (Caustic) drums are reclaim/Reuse drums, they are stored in the building (Reason is for wind and rain purpose we don't keep them in the yard) we add the drippings from truck loading into the drums from 5 gallon buckets, later we put the Caustic back into the system once the drums are sampled for quality and %. Please see pictures of updated labels, storage organization and painted lines to prevent future confusion. Please let me know if there is anything else we can assist with in the future. Thank You! Appendix 6. Page 1 of 16 DUSTIN SCHIIIDT Terminal Manager BWC Terminals 1805 4th Street, Harvey, LA 70058 Office (504)267-1669 Cell (513)504-2998 Dscheidt@Bwcterminals.com I www.Bwcterminals.com BWC Terminals (a) BULK LIQUID STORAGE NOTICE: This message is confidential and intended for the sole use of the intended recipient and may contain proprietary information, trade secrets or information that is covered or protected by legal or professional privileges, immunities or rules. If you have received this e-mail in error, please notify us by e-mail (it@bwcterminals.com) or by telephone (832.699.5730); destroy all copies (electronic and physical); and be advised that you are strictly prohibited from using, disclosing or distributing the information in this e-mail or its attachment(s) or taking or forbearing of any action in reliance upon such information. The sender's name and other information in this e-mail are for information purposes only and are not digital or electronic signatures. 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