Table of Contents EXECUTIVE SUMMARY...2 PROJECT PERSONNEL...4 INTRODUCTION...4 SAMPLING AND ANALYTICAL METHODS...5

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2 Table of Contents EXECUTIVE SUMMARY...2 PROJECT PERSONNEL...4 INTRODUCTION...4 SAMPLING AND ANALYTICAL METHODS...5 TDI AND H 12 MDI EXPOSURES--SAMPLING RESULTS...6 2,4 AND 2,6-TDI SAMPLING RESULTS APPLICATION OF PRIMER H 12 MDI SAMPLING RESULTS APPLICATION OF SPEEDLINER RESPIRATORY PROTECTION AND CARTRIDGE CHANGE-OUT SCHEDULES...8 LISTING OF APPENDICES...13 HAGEMEYER, N.A.

3 EXECUTIVE SUMMARY Exposure Sampling for Toluene Diisocyanate (TDI) and Hydrogenated MDI (H 12 MDI) in the spray application of Speedliner 1000 Urethane Coating Hagemeyer North America was requested by Industrial Polymers, Inc. of Houston, Texas to measure hygiene exposures to diisocyanate compounds during the application process of Speedliner 1000 urethane coating. The diisocyanate compounds consisted of toluene diisocyanate (2,4-TDI and 2,6-TDI) and methylene bis(4-cyclohexylisocyanate) a.k.a. hydrogenated MDI or H 12 MDI. On June 26 th, 2006, Hagemeyer N.A. sampled for these compounds while Primer 450 and Speedliner 1000 was applied onto a plywood board of dimensions of 4 ft. x 8 ft. Both personal and area samples were obtained during the application process. The process first involved mixing and applying Primer 450 onto the plywood board using an eight-inch roller. After a 30-minute drying period, the top coat, Speedliner 1000, was mixed and applied with a pneumatic hopper spray gun assembly. Four gallons of Speedliner were applied in a 30-minute period. The hygiene sampling session was performed in the shop of Industrial Polymers, Inc., 3250 South Sam Houston Pkwy., Houston, TX Personal samples were taken from the breathing zone of the applicator who applied the primer and top urethane coat. Area sampling was performed for an 8-hour period which included the application process as well as drying. During the sampling session, shop ambient conditions were 85 F and 50% relative humidity. Shop bay doors were closed. No local exhaust ventilation or blower systems were provided at the application site. Ceiling height of the shop is approximately 25 ft. Findings and conclusions from the hygiene sampling are as follows: Both personal and area samples for 2,4 and 2,6-TDI were less than the laboratory limits of quantification, i.e. TDI was at non-detectable levels. TDI is only in Primer 450 and not in Speedliner Personal sampling for TDI was only performed during the application of Primer 450. Actual application time for the primer was 4 minutes. During mixing and spray application of Speedliner 1000, average H 12 MDI concentration in the breathing zone of the applicator was ppm. Four gallons of Speedliner were mixed and spray applied in a twenty-nine minute period. OSHA 1 does not enforce permissible exposure limits (PELs) for H 12 MDI. However, the ACGIH 2 publishes a threshold limit value (TLV ) for H 12 MDI of ppm time-weighted average for 8 hours of exposure (TWA). If the applicator would continue to apply Speedliner at an average 1 OSHA = Occupational Safety and Health Administration of the U.S. Department of Labor. OSHA is the federal agency who enforces occupational safety and health regulations in the United States. 2 ACGIH: American Conference of Governmental Industrial Hygienists. The ACGIH is comprised of professional practitioners in industrial hygiene, occupational health, environmental health and safety. The ACGIH researches, develops, and publishes the TLVs (threshold limit values) and BEIs (biological exposure indices). HAGEMEYER, N.A.

4 Industrial Polymers, Inc., Houston, TX. 07/18/06 Exposure Sampling Results for TDI and H 12 MDI Application of Speedliner 1000 exposure of ppm, the applicator s exposure would exceed the TLV after 3.5 hours in a given work shift. In accordance to good hygiene practices, respiratory protection is recommended at 50% of the exposure limit, called action level, or after 1.75 hours of spray application time. Respiratory protection should consist either of 1) full-face respirators fitted with organic vapor (OV) cartridges and N95 pre-filters, or 2) full-face, supplied-air respirators. To use OV cartridges, the employer must calculate the service life of the cartridges based on measured H 12 MDI exposure levels. Based on the average measured exposure of ppm, service life estimates were calculated for 3M, North Safety Products, and AOSafety organic vapor cartridges. Service life calculations exceed 40 hours of use. Nonetheless, it is recommended that service life of the organic vapor cartridges be limited to no more than 40 hours or 5 workshifts due to possible absorption of other organic vapors. In addition to respiratory protection for the applicator, a person standing at the perimeter of the application site should don full-face respiratory protection after incurring exposure to one coating session or 40 minutes of spray application. During the application process and drying, area samples were continuously obtained 2 to 3 feet from the northeast and southwest corners of the plywood board. Highest area measurement was ppm, obtained at the southwest corner. This measurement was made in the first 3.4 hours and includes application of Primer 450, Speedliner and initial drying. If it would be assumed that most of the H 12 MDI exposure occurred during the 30-minute spray application process, then actual concentration during application at the southwest corner would be ppm. A person standing at this corner would exceed the TLV of ppm TWA after 1.4 hours of exposure. The action level is expected at 50% of 1.4 hours or 0.7 hours or 42 minutes. Area samples taken in the drying phase from 2.5 hours through 6.5 hours after spray application had no detectable levels of H 12 MDI or TDI, i.e. measurements were less than the laboratory limits of quantification. Sampling and laboratory analysis for this sampling session adhered to OSHA Method #42 for 2,4 and 2,6 TDI and OSHA Method #PV2092 for H 12 MDI. Laboratory analysis was performed by Galson Laboratories, an AIHA (American Industrial Hygiene Association) accredited laboratory for chemical analysis of hygiene samples. Onsite sampling, evaluation of analytical data, and writing of this survey report was performed by Mr. Tim Krill, CIH, CSP 3 of Hagemeyer N.A. Hagemeyer N.A. thanks Mr. Carl Boddie, Technical Director of Industrial Polymers, for coordinating and participating in the above hygiene sampling sessions. 3 CIH = Certified Industrial Hygienist by the American Board of Industrial Hygiene (ABIH ). CSP = Certified Safety Professional by the Board of Certified Safety Professionals (BCSP). Page 3 HAGEMEYER, N.A.

5 Industrial Polymers, Inc., Houston, Texas 07/18/06 Exposure Sampling for TDI and H 12 MDI Application of Speedliner 1000 PROJECT PERSONNEL Mr. Carl Boddie, Technical Director of Industrial Polymers, Inc., arranged the hygiene survey and supplied information regarding the chemical content of Speedliner 1000 urethane coating and Primer 450. Mr. Boddie also participated in the hygiene sampling sessions by wearing a personal sampling pump while mixing and applying the primer and urethane coating. Mr. Tim Krill, CIH, CSP, safety and industrial hygiene specialist of Hagemeyer, N.A. of Houston, Texas, performed the onsite, hygiene sampling at Industrial Polymers. An application site was setup within the shop of Industrial Polymers, 3250 South Sam Houston Pkwy., Houston, Texas and sampling was performed on Monday, June 26 th, Mr. Krill selected the hygiene sampling methods, evaluated all analytical data and wrote the survey report. INTRODUCTION The objective of this hygiene survey was to measure personal and area exposures to toluene diisocyanate (TDI) and hydrogenated MDI (H 12 MDI, CAS # ) while applying Speedliner 1000 urethane coating and its primer, Primer 450. The primer contains both 2,4-TDI and 2,6-TDI, and Speedliner 1000 contains H 12 MDI. The exposure measurements will then be compared to OSHA permissible exposure limits (PEL) and ACGIH threshold limit values (TLV ), enabling assessment of safety and health risks. The application process involves first applying Primer 450 and then Speedliner urethane coating. Before applying Primer 450, it is mixed from a two part system consisting of resin (350 ml of Part A) and catalyst (350 ml of Part B). Speedliner is mixed from a 3-part system consisting of resin (Part A), catalyst (Part B) and pigment. Primer 450 is brush applied using an eight inch (length) paint roller. Speedliner is sprayed applied using a pneumatic hopper gun. For this sampling session, pneumatic pressure to the hopper gun was 65 psig. On June 26 th, 2006, an application site was setup at the northwest section of the Industrial Polymers shop, 3250 South Sam Houston Parkway, Houston, Texas Personal exposures to TDI and H 12 MDI were measured while mixing and applying Primer 450 and Speedliner onto a plywood board of dimensions 4 x 8 x ¼ or 32 sq. ft (see photos in Appendix E). The primer was mixed and applied within a 4-minute period, and Speedliner was mixed and sprayed applied within a 29-minute session. A total of 4 gallons of Speedliner was spray applied during the spray application session. This application process is considered to be equivalent to the Speedliner kit application process for a pickup truck bed. The hygiene sampling strategy consisted of both personal and area sampling. Using personal sampling pumps with chemically-coated filter cassettes, hygiene samples were obtained from the breathing zone of the person applying both Primer 450 and Speedliner. Also, area samples were taken at the perimeter of the application site. Details of the sampling and analytical methods are given in the next section. Personal protective equipment (PPE) consisted of safety glasses, latex disposable gloves, leather safety boots covered with Tyvek booties, and a NIOSH-approved half-mask air-purifying respirator (Aearo/AOSafety model # large) fitted with two, organic vapor cartridges (AOSafety R51A). Page 4 HAGEMEYER, N.A.

6 Industrial Polymers, Inc., Houston, Texas 07/18/06 Exposure Sampling for TDI and H 12 MDI Application of Speedliner 1000 SAMPLING AND ANALYTICAL METHODS The hygiene sampling strategy consisted of personal sampling in the breathing zone of the applicator who mixed and applied Primer 450 and Speedliner 1000 urethane coating. In addition to personal sampling, area samples were obtained for an 8-hour period which included the application process as well as drying time. All hygiene samples were obtained using personal sampling pumps connected to filter cassette assemblies via Tygon tubing. A pump was attached to the applicator s belt, and a filter cassette assembly was clipped to the applicator s collar, enabling air sampling in the breathing zone. See photos #3 and #4 in Appendix E. Personal (breathing zone) samples were collected for three, 15-minute periods (STEL 4 sampling). The first, 15-minute period sample (i.e. first STEL sample) measured exposures to 2,4 and 2,6-TDI during mixing and applying Primer 450. The second STEL sample measured H 12 MDI exposures during mixing and spraying of the first two gallons of Speedliner, and the third STEL sample was obtained during spraying of the third and fourth gallons of Speedliner. Area sampling was performed at the perimeter of the application site and included the application process and drying phase. Area samples were obtained 2 to 3 ft from the southwest and northeast corners of the plywood board the application site. The southwest corner sample was positioned 3'-6 above the board, and the northeast sample was 4'-9 above the plywood board. Total sampling time for area sampling was 8 hours. The area samples are shown in photos #6, #7 and #8 in Appendix E. Samples were collected and analyzed in accordance to OSHA Methods #42 for TDI and #PV2092 for H 12 MDI. These methods employ a chemically-coated filter to collect TDI and H 12 MDI. The filter is a glass fiber filter (37 mm diameter) treated with 2 mg of 1-(2-pyridyl) piperazine [1-2 PP]. This chemical is a derivatizing agent that changes collected diisocyanates to a more stable form. The coated filters were installed in plastic cassettes which were tested by the manufacturer (SKC, Inc.) to be leak-free. Details of OSHA Methods #42 and #PV2092 are given in Table 1 on the following page. Details of field sampling procedures including pump calibration data, sampling times, total air volume sampled, pump and sampling media identification, and field observations are documented in the Environmental and Industrial Hygiene Data Sheets, attached in Appendix A. Log of sampling pump calibrations is attached in Appendix C. Analytical testing of all samples was performed by Galson Laboratories, an AIHA (American Industrial Hygiene Association) accredited laboratory for chemical analysis of industrial hygiene samples. The analysis report of Galson Laboratories is attached in Appendix B. Also attached in Appendix B is 1) signed chain of custody records for sample submission to Galson Laboratories, and 2) AIHA Laboratory accreditation certificates for Galson Laboratories. 4 STEL = Short-term exposure limit for 15-minute exposure period. Page 5 HAGEMEYER, N.A.

7 Industrial Polymers, Inc., Houston, Texas 07/18/06 Exposure Sampling for TDI and H 12 MDI Application of Speedliner 1000 Table 1 OSHA Referenced Sampling & Analytical Methods Hygiene Sampling at Industrial Polymers, Inc., Houston, TX June 26 th, 2006 Contaminant Exposure Source Referenced Sampling and Analytical Method Collection Media & Flowrate Analytical Technique 2,4-toluene diisocyanate (2,4-TDI) 2,6-toluene diisocyanate (2,6-TDI) Resin (Part A) of Primer 450 (roll applied) OSHA Method # 42 Glass fiber filters (37 mm diam.) coated with 2 mg of 1-(2-pyridyl) piperazine. SKC # liter per minute STEL and 4 hr. sampling rate. HPLC-UV Hydrogenated MDI (H 12 MDI) Methylene bis(4-cyclohexylisocyanate) CAS # Resin (Part A) of Speedliner 1000 urethane coating (spray applied) OSHA Method # PV2092 Glass fiber filters (37 mm diam.) coated with 2 mg of 1-(2-pyridyl) piperazine. SKC # HPLC-UV 1.0 liter per minute STEL and 4 hr. sampling rate. HPLC-UV = High Performance Liquid Chromatography with Ultraviolet Detector. TDI AND H 12 MDI EXPOSURES--SAMPLING RESULTS Hygiene sampling consisted of personal and area sampling for 2,4 and 2,6-TDI and hydrogenated MDI (H 12 MDI). Samples were obtained during mixing, applying and drying of Primer 450 and Speedliner 1000 urethane coating. Personal samples were obtained from the breathing zone of the applicator who mixed and applied these products. Area sampling was performed at the perimeter of the application site. The application process involved applying Primer 450 and four gallons of Speedliner 1000 to a plywood board of 32 sq. ft. (4' x 8'). No local exhaust ventilation or blower systems were provided at the application site. Shop bay doors were closed during the sampling session. Shop ambient conditions during sampling were 85.3 F and 50% relative humidity. Ceiling height of the shop is approximately 25 ft. 2,4 and 2,6-TDI Sampling Results Application of Primer 450 Both personal and area samples for 2,4 and 2,6-TDI were less than the laboratory limits of quantification, i.e. TDI was at non-detectable levels. TDI is only in Primer 450 and not in Speedliner Therefore, personal sampling for TDI was only performed during the application of Primer 450. Application time for the primer was 4 minutes. Page 6 HAGEMEYER, N.A.

8 Industrial Polymers, Inc., Houston, Texas 07/18/06 Exposure Sampling for TDI and H 12 MDI Application of Speedliner 1000 H 12 MDI Sampling Results Application of Speedliner 1000 Personal Exposures to Applicator: During the mixing and application of Speedliner 1000, average H 12 MDI concentration in the breathing zone of the applicator was ppm. Four gallons of Speedliner were mixed and sprayed in a twentynine minute period. The average exposure measurement of ppm was obtained from two, 15- minute STEL samples. The first STEL sampling session (sample PS-02) resulted in a measured exposure of ppm, and the second STEL session (sample PS-03) had a measured exposure of ppm. In the first STEL session, the first two gallons of Speedliner were applied. The third gallon was mixed and poured into the hopper of the spray gun assembly. In the second STEL session, the third gallon was applied, followed by mixing and spraying of the fourth gallon. OSHA does not enforce permissible exposure limits (PELs) for H 12 MDI. However, the ACGIH publishes a threshold limit value (TLV ) for H 12 MDI of ppm time-weighted average for 8 hours of exposure (TWA). If the applicator would continue to apply Speedliner at an average exposure of ppm, the applicator s exposure would exceed the TLV after 3.5 hours in a given work shift. In accordance to good hygiene practices, respiratory protection is recommended at 50% of the exposure limit, called action level. Based on measured exposure data from these sampling sessions, the action level is expected to occur after 1.75 hours of spray application time, i.e. 50% of 3.5 hrs for the TLV. For additional criteria on respiratory protection, see section below titled, Respiratory Protection and Cartridge Change-out Schedules. Personal sampling results and comparisons to exposure limits of OSHA and ACGIH are summarized in Table 2 on page 10. Also given in Table 2 is a description of each sample, i.e. job position, job activities/procedures and time of measurement. Area Concentrations of H 12 MDI at Perimeter of Application Site: During the application process and drying, area samples were continuously obtained 2 to 3 feet from the northeast and southwest corners of the plywood board. Highest area measurement was ppm, obtained at the southwest corner (sample AR-01). This measurement was made in the first 3.4 hours and includes application of Primer 450, Speedliner and initial drying. If it would be assumed that most of the H 12 MDI exposure occurred during the thirty minute spray application process, then actual concentration during application at the southwest corner would be ppm. A person standing at this corner would exceed the TLV of ppm TWA after 1.4 hours of exposure. The action level is expected at 50% of 1.4 hours for the TLV or 0.7 hours or 42 minutes. Therefore, a person standing at the perimeter of the application site should don respiratory protection at the action level or after 42 minutes of exposure. For respiratory protection criteria, see section below titled, Respiratory Protection and Cartridge Change-out Schedules. At the northeast corner, the sample taken during the first 3.2 hours (sample AR-02) had a measured concentration of ppm H 12 MDI. This sample includes application of Primer 450, Speedliner and initial drying. It is believed that the concentration of the northeast sample is much less than the southwest sample due to direction of spraying. During the entire Speedliner application process, the applicator directed the spray to the west, working backwards to the east. See photo #5 in Appendix E. Page 7 HAGEMEYER, N.A.

9 Industrial Polymers, Inc., Houston, Texas 07/18/06 Exposure Sampling for TDI and H 12 MDI Application of Speedliner 1000 The need for respiratory protection at the perimeter is dictated by the highest exposure measurement or worst case measurement that was from the southwest corner (sample AR-01). Area samples obtained 2.5 hours through 6.5 after the spray application of Speedliner (samples AR-03 and AR-04) had no detectable levels of H 12 MDI or TDI, i.e. measurements were less than the laboratory limits of quantification. Therefore, no TDI or H 12 MDI exposures were detected in the drying phase, starting 2.5 hours after the spray application of Speedliner. Area sampling results and comparisons to exposure limits of OSHA and ACGIH are summarized in Table 3 on page 11. Also given in Table 3 are descriptions of the area samples including sample location, activities during measurement, and time of measurement. Respiratory Protection and Cartridge Change-out Schedules Respiratory protection is recommended at the action levels stated above. Respiratory protection may consist of either NIOSH-approved 1) full-face respirator fitted with organic vapor (OV) cartridges and N95 pre-filters, or 2) full-face supplied-air respirator. If oil aerosols (mist) are present in the work environment, replace the N95 pre-filters with P95 filters. 5 Full-face masks are recommended due to 1) improved fit-factors around the circumference of the face versus the nose bridging for half-masks, and 2) vapors of diisocyanate compounds are corrosive and severely damaging to the eyes; eye contact may cause permanent eye damage. If a half-mask respirator is used, the employer would also be required under 29 Code of Federal Regulations (CFR) Part (d) to ensure the employee uses appropriate eye or face protection. 6 In using air-purifying respirator with organic vapor cartridges, the employer must calculate the service life of the OV cartridge based on several variables including measured H 12 MDI exposure levels. 6 Using the software of leading respirator manufacturers, service life or change-out schedules were calculated for the measured average exposure of ppm MDI similar in physical properties to H 12 MDI. 7 Service life calculations exceed 40 hours of use for OV cartridges from 3M, North Safety Products and AOSafety. Table 4 on page 12 summarizes service life calculations for the listed OV cartridges. Nonetheless, it is recommended that service life of the listed OV cartridges be limited to no more than 40 5 Particulate filters or pre-filters having the rating of N are not resistant to oil aerosols. If oil aerosols are present, particulate filters should have the rating of P for oil proof. 6 OSHA s Standard of Interpretation, 7/18/00 Selection of Air-Purifying Respirators for Gases and Vapors with Poor Warning Properties (Diisocyanates), sub-paragraph c, attached in Appendix D. 7 Service life software from respirator manufacturers does not list H 12 MDI. MDI has similar physical properties to that of H 12 MDI, e.g. molecular weight, boiling point and vapor pressure. Absorption characteristics in the OV cartridge and service life are expected to be similar for both compounds. Page 8 HAGEMEYER, N.A.

10 Industrial Polymers, Inc., Houston, Texas 07/18/06 Exposure Sampling for TDI and H 12 MDI Application of Speedliner 1000 hours or five work-shifts due to possible affects from other organic vapors in the work environment. Print-outs of the calculations from manufacturers software are attached in Appendix D. In addition to cartridge service life calculations, OSHA requires employers to have written respiratory protection programs, conduct medical evaluations of respirator users (before respirator fit testing), perform annual fit testing, and conduct respirator training. Respirator fit testing is only valid for a mask of specific make, model and size. See OSHA 29 CFR Part , Respiratory Protection, available at click on Standards in right-side margin. Page 9 HAGEMEYER, N.A.

11 Industrial Polymers, Inc., Houston, Texas 07/18/06 Exposure Sampling for TDI and Hydrogenated MDI Application of Speedliner 1000 Urethane Coating Table 2 Personal Exposure Measurements for TDI and Hydrogenated MDI (H 12 MDI) Application of Primer 450 and Speedliner 1000 Urethane Coating June 26 th, 2006 Sample I.D. Time Period Sample Description Contaminant Analytical Results Measured Exposure OSHA Permissible Exposure Limit (PEL)* ACGIH Threshold Limit Value (TLV)* PS hrs. Personal breathing zone STEL sample on Carl Boddie, while mixing and roll-applying Primer 450 on 4 ft. x 8ft. plywood board. Applied primer with 8-inch paint roller. Primer mixed and applied within a 4 minute period. Remained at application site till end of STEL sampling session at 0928 hr. 2,4-TDI 2,6-TDI < ppm < ppm 0.02 ppm ceiling No OSHA limits 0.02 ppm STEL 0.02 ppm STEL PS hrs. Personal breathing zone STEL sample on Carl Boddie, during mixing and spraying Speedliner 1000 urethane top coat on 4 ft. x 8 ft. plywood board. Mixed and spray applied two gallons of Speedliner. Applied with pneumatic hopper gun using 65 psig of pneumatic pressure. At 1001 hr. mixed & poured 3 rd gallon and began to spray apply. Hydrogenated MDI (H 12 MDI) ppm No OSHA STEL or TWA limits No STEL limit ppm TWA PS hrs Personal breathing zone STEL sample on Carl Boddie, during mixing and spraying Speedliner 1000 on 4 ft. x 8 ft. plywood board. Spray applied third and fourth gallon of Speedliner. Spray application finished at 1017 hour. Hydrogenated MDI (H 12 MDI) ppm No OSHA STEL or TWA limits No STEL limit ppm TWA STEL=short-term exposure limit for 15 minutes exposure. ppm = parts of contaminant per million parts of air. Ceiling = concentration that should not be exceeded during any given instant during the work shift. In practice, ceiling limits are evaluated using 15-minute STEL measurements. TWA = Time-weighted average for 8 hours of exposure. < = less than the laboratory limit of quantification, i.e. contaminant/chemical not detected on sample. Ambient conditions in shop during application: At 1024 hr., T = 85.3ºF and R.H. = 50%. Page 10 HAGEMEYER, N.A.

12 Industrial Polymers, Inc., Houston, Texas 07/18/06 Exposure Sampling for TDI and Hydrogenated MDI Application of Speedliner 1000 Urethane Coating Table 3 Area Measurements for TDI and Hydrogenated MDI (H 12 MDI) Application of Primer 450 and Speedliner 1000 Urethane Coating June 26 th, 2006 Sample I.D. Time Period Sample Description Contaminant Analytical Results Measured Exposure OSHA Permissible Exposure Limit (PEL)* ACGIH Threshold Limit Value (TLV)* AR hrs. Area sample 3 ft. from southwest corner of plywood board. Sample taken 3.5' above floor. Plywood board positioned on floor. Mixed and applied Primer 450 and Speedliner 1000 from 0913 hr. to 1017 hr. Drying from hrs. 2,4-TDI 2,6-TDI Hydrogenated MDI < ppm < ppm ppm 0.02 ppm ceiling No OSHA limits No OSHA limits ppm TWA ppm TWA ppm TWA AR hrs. Area sample 2 ft. from NE corner of plywood board and 6 NW of mixing area. Sample taken 4' 9 above floor. Plywood board positioned on floor. Mixed and applied Primer 450 and Speedliner from 0913 hr. to 1017 hr. Drying from hrs. 2,4-TDI 2,6-TDI Hydrogenated MDI < ppm < ppm ppm 0.02 ppm ceiling No OSHA limits No OSHA limits ppm TWA ppm TWA ppm TWA AR hrs. Area sample 3 ft. from southwest corner of plywood board. Sample taken 3.5' above floor. Plywood board positioned on floor. Sample taken during drying period. Spray application finished 2.5 hrs. ago. 2,4-TDI 2,6-TDI Hydrogenated MDI < ppm < ppm < ppm 0.02 ppm ceiling No OSHA limits No OSHA limits ppm TWA ppm TWA ppm TWA AR hrs. Area sample 2 ft. from NE corner of plywood board. Sample taken 4' 9 above floor. Plywood board positioned on floor. Sample taken during drying period. Spray application finished 2.3 hrs. ago. 2,4-TDI 2,6-TDI Hydrogenated MDI < ppm < ppm < ppm 0.02 ppm ceiling No OSHA limits No OSHA limits ppm TWA ppm TWA ppm TWA ppm = parts of contaminant per million parts of air. TWA = Time-weighted average for 8 hours of exposure. Ceiling = concentration that should not be exceeded during any given instant during the work shift. In practice, ceiling limits are evaluated using 15-minute STEL measurements. < = less than the laboratory limit of quantification, i.e. contaminant/chemical not detected on sample. Ambient conditions in shop at application site: At 1024 hr., T = 85.3ºF and R.H. = 50% At 1650 hr., T = 90.3ºF and R.H. = 32%. Page 11 HAGEMEYER N.A.

13 Industrial Polymers, Inc., Houston, Texas 07/18/06 Exposure Sampling for TDI and Hydrogenated MDI Application of Speedliner 1000 Urethane Coating Table 4 Service Life Calculations for Organic Vapor Cartridges Against Methylene Bisphenyl Isocyanate (MDI) 1 Cartridge Manufacture and Model No. Exposure Concentration of MDI 2 Temperature and Relative Humidity Work Rate (Breathing Rate) Breakthrough at 10% of TLV 3 Safety Factor Calculated Service Life North Safety 75SC-P100 North Safety 7581-P100 North Safety 7583-P100 AO Safety 8000 Series OV Cartridge 3M 5000 Series OV Cartridge 3M 6000 Series OV Cartridge 3M 6001 OV Cartridge 3M 6006 Multi-gas/vapor cartridge 3M 7251 OV Cartridge ppm 90º F and R.H. > 80% 50 liter/min ppm 50% > 40 hrs ppm 90º F and R.H. > 80% 50 liter/min ppm 50% > 40 hrs ppm 90º F and R.H. > 80% 50 liter/min ppm 50% > 40 hrs ppm 90 F and R.H % Medium Rate ppm 50% > 40 hrs ppm 122º F and R.H. 90% 40 liter/min ppm 50% > 40 hrs ppm 122º F and R.H. 90% 40 liter/min ppm 50% > 40 hrs ppm 122º F and R.H. 90% 40 liter/min ppm 50% > 40 hrs ppm 122º F and R.H. 90% 40 liter/min ppm 50% > 40 hrs ppm 122º F and R.H. 90% 40 liter/min ppm 50% > 40 hrs. ppm = parts of contaminant per million parts of air. 3 TLV for MDI and H 12 MDI = ppm TWA OV Cartridge = organic vapor cartridge 1 Respirator manufacturers service life software does not list H 12 MDI. MDI has similar molecular weight, boiling point and vapor pressure to that of H 12 MDI. Absorption characteristics in organic vapor cartridges and service life are expected to be similar for both compounds. 2 Exposure concentrations acquired from hygiene sampling session on June 26 th, 2006 with Speedliner Measured average concentration of H 12 MDI was ppm. Page 12 HAGEMEYER N.A.

14 Industrial Polymers Inc., Houston, TX 07/18/06 Exposure Sampling for TDI and H 12 MDI--Application of Speedliner 1000 APPENDICES Appendix A Environmental and Industrial Hygiene Survey Data Sheet Toluene Diisocyanate (2,4-TDI and 2,6-TDI) Personal Samples, 1 page. Environmental and Industrial Hygiene Survey Data Sheet Hydrogenated MDI (H 12 MDI) Personal Samples, 1 page. Environmental and Industrial Hygiene Survey Data Sheets 2,4-TDI, 2,6-TDI and Hydrogenated MDI (H 12 MDI) Area Samples, 2 pages. Appendix B Galson Laboratories Analysis Report, 3 pages. Signed Chain of Custody Records for sample submission to Galson Laboratories, 1 page. AIHA Laboratory Accreditation Certificates for Galson Laboratories Appendix C Appendix D Calibration Log of GilAir 5 Sampling Pumps, 1 page. OSHA s Letter of Standard Interpretations, Selection of Air-Purifying Respirators for Gases and Vapors with Poor Warning Properties (Diisocyanates), July 18 th, Calculations of service life for organic vapor cartridges of 3M, North Safety Products and AOSafety. Appendix E Photos of hygiene sampling session during application of Primer 450 and Speedliner 1000, June 26 th, 2006, 2 pages. Page 13 HAGEMEYER N.A.

15 Industrial Polymers Inc., Houston, TX 07/18/06 Exposure Sampling for TDI and H 12 MDI Application of Speedliner 1000 APPENDIX A Environmental and Industrial Hygiene Survey Data Sheet Toluene Diisocyanate (2,4-TDI and 2,6- TDI) Personal Samples, 1 page. Environmental and Industrial Hygiene Survey Data Sheet Hydrogenated MDI (H 12 MDI) Personal Samples, 1 page. Environmental and Industrial Hygiene Survey Data Sheets 2,4-TDI, 2,6-TDI and Hydrogenated MDI (H 12 MDI) Area Samples, 2 pages. HAGEMEYER, N.A.

16 Environmental and Industrial Hygiene Survey Data Sheet Toluene Diisocyanate (2,4-TDI and 2,6-TDI) CLIENT: Hagemeyer Technical Services Industrial Polymers, Inc. Page 1 Of 1 Environmental and Industrial Hygiene Services LOCATION: 6825 West Sam Houston Pkwy. N South Sam Houston Pkwy., Houston, TX DATE OF SURVEY: Houston, TX ADDRESS: June 26 th, South Sam Houston Pkwy., Houston, TX JOB: Measure exposure to toluene diisocyanate (2,4-TDI and 2,6-TDI) during application of Primer 450 with 8-inch paint roller. INSTRUMENT(S): Gilian GilAir5 personal sampling pump with treated glass fiber filter cassette, 37 mm diameter. Filter coated with 2 mg of 1-(2-pyridyl) piperazine [1-2 PP] for derivatizing the TDI isomers into a more stable state SKC filter cassette assembly # OSHA Sampling and Analytical Methods #42. TELEPHONE # FAX # PRIORITY = NORMAL xxx RUSH IF RUSH - DATE NEEDED: INSTRUMENT NO. CALIBRATOR REASON FOR SAMPLING - INCLUDE PROCESS OR OPERATION DESCRIPTION & CONTROLS S/N Gilibrator-2 Determine area and personal exposure to 2,4-TDI and 2,6-TDI while applying Industrial Polymers Primer 450. Product is a S/N S/N part system consisting of resin (Part A) and catalyst (Part B), mixed in the ratio of 350 ml : 350 ml. After mixing, Primer 450 S/N applied with paint roller of 8-inches in length. Total application time on 4 x 8 plywood board was 4 minutes. Person applying S/N Primer 450 wore NIOSH-approved half-mask respirator fitted with organic vapor cartridges, latex gloves and safety glasses. S/N COLLECTION (SAMPLING) MEDIA: Glass fiber filters coated w/ 2mg of 1-(2-pyridyl) piperazine. SKC # COMMENTS: At 1024 hr., T = 85.3 F and 50% relative humidity. SAMPLING LOCATION, TYPE OF SAMPLING TIME TOTAL FLOW RATES (LPM) TOTAL SHIFT ANALYTE(S) SAMPLE PUMP SAMPLE & EMPLOYEE MINS. VOLUME LENGTH NUMBER NO. INFORMATION START STOP SAMPLED PRE POST AVG (LITERS) MINS. PS Breathing zone STEL sample Anaylze for 2,4-TDI and 2,6-TDI. on applicator, Carl Boddie. Referenced method: OSHA Sampling and Applied Primer 450 with 8-inch Analytical Method #42. roller onto 4 x 8 plywood Analysis by high performance liquid chromaboard. Total mixing and roll time tography with ultraviolet detector (HPLC-UV) was 4 minutes 0913 through 0917 hrs. No local exhaust Personal sample is STEL sample, i.e. ventilation provided at applica- short-term exposure limit sample for 15-min. tion site. exposure (sampling) period. PS Field blank Field blank for 2,4-TDI and 2,6-TDI. CONSULTANT: SIGNATURE: DATE OF SAMPLING: DATE SIGNED: Tim Krill, CIH, CSP June 26 th, 2006 July 17 th, 2006

17 Environmental and Industrial Hygiene Survey Data Sheet Hydrogenated MDI (H 12 MDI) CLIENT: Hagemeyer Technical Services Industrial Polymers, Inc. Page 1 Of 1 Environmental and Industrial Hygiene Services LOCATION: 6825 West Sam Houston Pkwy. N South Sam Houston Pkwy., Houston, TX DATE OF SURVEY: Houston, TX ADDRESS: June 26 th, South Sam Houston Pkwy., Houston, TX JOB: Measure exposure to hydrogenated MDI (H 12 MDI, a.k.a. methylene bis(4-cyclohexylisocyanate) during mixing and spray application of Speedliner 1000 urethane coating. INSTRUMENT(S): Gilian GilAir5 personal sampling pumps with treated glass fiber filter cassettes, 37 mm diameter. Filter coated with 2 mg of 1-(2-pyridyl) piperazine [1-2 PP] for derivatizing the H 12 MDI into more stable state SKC filter cassette assembly # OSHA Sampling and Analytical Methods # PV TELEPHONE # FAX # PRIORITY = NORMAL xxx RUSH IF RUSH - DATE NEEDED: INSTRUMENT NO. CALIBRATOR REASON FOR SAMPLING - INCLUDE PROCESS OR OPERATION DESCRIPTION & CONTROLS S/N Gilibrator-2 Determine personal exposure to H 12 MDI while applying Industrial Polymers Speedliner 1000 urethane coating. Product is a S/N S/N part system consisting of resin (Part A), catalyst (Part B) and pigment. Speedliner 1000 applied with hopper spray gun S/N assembly using 65 psig of pneumatic pressure. Sampling session involved mixing Speedliner components and spray application S/N to 4' x 8' plywood board laying on shop floor. Total of 4 gallons of Speedliner applied to plywood sheet. Total mixing and spray S/N application time was 29 minutes. Applicator wore NIOSH-approved half-mask respirator fitted with organic vapor cartridges, latex gloves, and safety glasses. Two STEL samples (short-term limit for 15 minutes) were taken in the breathing zone of applicator. COLLECTION (SAMPLING) MEDIA: COMMENTS: Glass fiber filters coated with 2 mg of 1-(2-pyridyl) piperazine. SKC # At 1024 hr., T = 85.3 F and relative humidity = 50%. SAMPLING LOCATION, TYPE OF SAMPLING TIME TOTAL FLOW RATES (LPM) TOTAL SHIFT ANALYTE(S) SAMPLE PUMP SAMPLE & EMPLOYEE MINS. VOLUME LENGTH NUMBER NO. INFORMATION START STOP SAMPLED PRE POST AVG (LITERS) MINS. PS Breathing zone STEL sample Anaylze for hydrogenated MDI (H 12 MDI). on applicator, Carl Boddie. Referenced method: OSHA Sampling and Mixed and spray applied two Analytical Method # PV2092. gallons of Speedliner Analysis by high performance liquid chroma- Mixed third gallon & poured into tography with ultraviolet detector (HPLC-UV) hopper of spray gun assembly. PS Breathing zone STEL sample Personal samples are STEL samples, i.e. on applicator, Carl Boddie. short-term exposure limit samples for 15-min. Spray applied third gallon. Mixed exposure (sampling) period. and spray applied fourth gallon of Speedliner PS Field Blank Field blank for H 12 MDI CONSULTANT: SIGNATURE: DATE OF SAMPLING: DATE SIGNED: Tim Krill, CIH, CSP June 26 th, 2006 July 17 th, 2006

18 Environmental and Industrial Hygiene Survey Data Sheet 2,4-TDI, 2,6-TDI and Hydrogenated MDI (H 12 MDI) CLIENT: Hagemeyer Technical Services Industrial Polymers, Inc. Page 1 Of 2 Environmental and Industrial Hygiene Services LOCATION: 6825 West Sam Houston Pkwy. N South Sam Houston Pkwy., Houston, TX DATE OF SURVEY: Houston, TX ADDRESS: June 26 th, South Sam Houston Pkwy., Houston, TX JOB: Measure area cocentrations to toluene diisocyanate (2,4-TDI and 2,6-TDI) during application of Industrial Polymer s Primer 450. Also measure area concentrations to hydrogenated MDI (H 12 MDI, a.k.a. methylene bis(4-cyclohexylisocyanate) during mixing and spray application of Speedliner 1000 urethane coating. INSTRUMENT(S): Gilian GilAir5 personal sampling pumps with treated glass fiber filter cassettes, 37 mm diameter. Filter coated with 2 mg of 1-(2-pyridyl) piperazine [1-2 PP] for derivatizing the H 12 MDI into more stable state SKC filter cassette assembly # OSHA Sampling and Analytical Methods # PV-2092 and # 42 TELEPHONE # FAX # PRIORITY = NORMAL xxx RUSH IF RUSH - DATE NEEDED: INSTRUMENT NO. CALIBRATOR REASON FOR SAMPLING - INCLUDE PROCESS OR OPERATION DESCRIPTION & CONTROLS S/N Gilibrator-2 Measure area concentrations to 2,4-TDI and 2,6-TDI while applying Primer 450. Also, measure area concentration to H 12 MDI S/N S/N while applying Industrial Polymers Speedliner 1000 urethane coating. The application site is a 4 x 8 plywood board laying on S/N shop floor. Primer 450 was mixed and applied with 8-inch paint roller. Speedliner 1000 applied with hopper spray gun using 65 S/N psig of pneumatic pressure. Total of 4 gallons of Speedliner applied to plywood board. Total time of mixing and application for S/N Primer 450 was 4 minutes. Total mixing and application time for Speedliner 1000 was 29 minutes. Area measurements made 2 to 3 ft. from northeast and southwest corners of plywood board. Two sets of area measurements were made. First set during application and drying up till 2.4 hrs after application. A second set was taken during drying, starting 2.5 hrs. and ending 6.5 hrs. after spray application of Speedliner COLLECTION (SAMPLING) MEDIA: COMMENTS: Glass fiber filters coated with 2 mg of 1-(2-pyridyl) piperazine. SKC # At 1024 hr., T = 85.3 F and relative humidity = 50%. At 1650 hr., T = 90.3 F and relative humidity = 32%. SAMPLING LOCATION, TYPE OF SAMPLING TIME TOTAL FLOW RATES (LPM) TOTAL SHIFT ANALYTE(S) SAMPLE PUMP SAMPLE & EMPLOYEE MINS. VOLUME LENGTH NUMBER NO. INFORMATION START STOP SAMPLED PRE POST AVG (LITERS) MINS. AR Area TWA sample at 3 feet from Anaylze for hydrogenated MDI (H 12 MDI) and southwest corner of plywood toluene diisocyanate (2,4-TDI and 2,6-TDI). board. 3.5' above board. Mixed Referenced methods: OSHA Sampling and and applied Primer 450 and 4 Analytical Methods #42 for TDI and # PV2092 gallons of Speedliner for H 12 MDI. Application finished at 1017 hr. Analysis by high performance liquid chromatography with ultraviolet detector (HPLC-UV) AR Area TWA sample at 3 feet from southwest corner of plywood board. 3.5' above board. Sample during drying, starting 2.5 hrs. and ending 6.5 hrs. after application. CONSULTANT: SIGNATURE: DATE OF SAMPLING: DATE SIGNED: Tim Krill, CIH, CSP June 26 th, 2006 July 17 th, 2006

19 Environmental and Industrial Hygiene Survey Data Sheet 2,4-TDI, 2,6-TDI and Hydrogenated MDI (H 12 MDI) CLIENT: Hagemeyer Technical Services Industrial Polymers, Inc. Page 2 Of 2 Environmental and Industrial Hygiene Services LOCATION: 6825 West Sam Houston Pkwy. N South Sam Houston Pkwy., Houston, TX DATE OF SURVEY: Houston, TX ADDRESS: June 26 th, South Sam Houston Pkwy., Houston, TX JOB: Measure area cocentrations to toluene diisocyanate (2,4-TDI and 2,6-TDI) during application of Industrial Polymer s Primer 450. Also measure area concentrations to hydrogenated MDI (H 12 MDI, a.k.a. methylene bis(4-cyclohexylisocyanate) during mixing and spray application of Speedliner 1000 urethane coating. INSTRUMENT(S): Gilian GilAir5 personal sampling pumps with treated glass fiber filter cassettes, 37 mm diameter. Filter coated with 2 mg of 1-(2-pyridyl) piperazine [1-2 PP] for derivatizing the H 12 MDI into more stable state SKC filter cassette assembly # OSHA Sampling and Analytical Methods # PV-2092 and # 42. TELEPHONE # FAX # PRIORITY = NORMAL xxx RUSH IF RUSH - DATE NEEDED: INSTRUMENT NO. CALIBRATOR REASON FOR SAMPLING - INCLUDE PROCESS OR OPERATION DESCRIPTION & CONTROLS S/N Gilibrator-2 Measure area concentrations to 2,4-TDI and 2,6-TDI while applying Primer 450. Also, measure area concentration to H 12 MDI S/N S/N while applying Industrial Polymers Speedliner 1000 urethane coating. The application site is a 4 x 8 plywood board laying on S/N shop floor. Primer 450 was mixed and applied with 8-inch paint roller. Speedliner 1000 applied with hopper spray gun using 65 S/N psig of pneumatic pressure. Total of 4 gallons of Speedliner applied to plywood board. Total time of mixing and application for S/N Primer 450 was 4 minutes. Total mixing and application time for Speedliner 1000 was 29 minutes. Area measurements made 2 to 3 ft. from northeast and southwest corners of plywood board. Two sets of area measurements were made. First set during application and drying up till 2.4 hrs after application. A second set was taken during drying, starting 2.5 hrs. and ending 6.5 hrs. after application. COLLECTION (SAMPLING) MEDIA: COMMENTS: Glass fiber filters coated with 2 mg of 1-(2-pyridyl) piperazine. SKC # At 1024 hr., T = 85.3 F and relative humidity = 50%. At 1650 hr., T = 90.3 F and relative humidity = 32%. SAMPLING LOCATION, TYPE OF SAMPLING TIME TOTAL FLOW RATES (LPM) TOTAL SHIFT ANALYTE(S) SAMPLE PUMP SAMPLE & EMPLOYEE MINS. VOLUME LENGTH NUMBER NO. INFORMATION START STOP SAMPLED PRE POST AVG (LITERS) MINS. AR Area TWA sample at 2 feet from Anaylze for hydrogenated MDI (H 12 MDI) and northeast corner of plywood toluene diisocyanate (2,4-TDI and 2,6-TDI). board. 4' 9" above board. Mixed Referenced methods: OSHA Sampling and and applied Primer 450 and 4 Analytical Methods #42 for TDI and # PV2092 gallons of Speedliner for H 12 MDI. Application finished at 1017 hr. Analysis by high performance liquid chroma- AR Area TWA sample at 2 feet from tography with ultraviolet detector (HPLC-UV) northeast corner of plywood board. 4' 9" above board. Sampled during drying, starting 2.5 hrs. and ending 6.5 hrs. after application. PS Field Blank Field blank for H 12 MDI, 2,4-TDI and 2,6-TDI. CONSULTANT: SIGNATURE: DATE OF SAMPLING: DATE SIGNED: Tim Krill, CIH, CSP June 26 th, 2006 July 17 th, 2006

20 Industrial Polymers Inc., Houston, TX 07/18/06 Exposure Sampling for TDI and H 12 MDI Application of Speedliner 1000 APPENDIX B Galson Laboratories Analysis Report, 3 pages. Signed Chain of Custody Records for sample submission to Galson Laboratories, 1 page. AIHA Laboratory Accreditation Certificates for Galson Laboratories HAGEMEYER, N.A.

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28 Industrial Polymers Inc., Houston, TX 07/18/06 Exposure Sampling for TDI and H 12 MDI Application of Speedliner 1000 APPENDIX C Calibration Log of GilAir 5 Sampling Pumps, 1 page. HAGEMEYER, N.A.

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30 Industrial Polymers Inc., Houston, TX 07/18/06 Exposure Sampling for TDI and H 12 MDI Application of Speedliner 1000 APPENDIX D OSHA s Letter of Standard Interpretations, Selection of Air-Purifying Respirators for Gases and Vapors with Poor Warning Properties (Diisocyanates), July 18 th, Calculations of service life for organic vapor cartridges of 3M, North Safety Products and AOSafety. HAGEMEYER, N.A.

31 07/18/ Selection of air purifying respirators for gases and vapors with poor warning properties (dii... navigational links] Search Page 1 of 3 7/17/2006 U.S. Department of Labor Occupational Safety & Health Administration MyOSHA [skip Advanced Search A-Z Index Standard Interpretations 07/18/ Selection of air purifying respirators for gases and vapors with poor warning properties (diisocyanates). Standard Interpretations - Table of Contents Standard Number: (d)(3)(iii); (d)(1)(i) July 18, 2000 Mr. Larry Janssen, CIH Technical Service Specialist 3M Occupational Health and Environmental Safety Division 3M Center Building 260-3B-09 St. Paul, MN Dear Mr. Janssen: Thank you for your December 10, 1999 letter to the Occupational Safety and Health Administration's (OSHA's) Directorate of Compliance Programs (DCP). You requested clarification regarding OSHA's position on the selection of air purifying respirators (APRs) for gases and vapors with poor warning properties, particularly the common diisocyanates such as Toluene-2,4-diisocyanate (TDI), Hexamethylene-1,6-diisocyanate (HDI) and Methylene bisphenyl isocyanate (MDI). We apologize for the delay in this response. The Preamble to the revised standard points out that there is a great variation between individuals in their sensory detection of chemicals and most toxic substances do not have appropriate sensory warning properties. The standard no longer permits the use of warning properties as the sole basis for determining that an air-purifying respirator affords adequate protection against exposures to vapors and gases. For atmospheres which are not Immediately Dangerous to Life or Health (IDLH), APRs are now considered acceptable as long as appropriate precautions and change out schedules are in place, even for use against substances with poor warning properties. Paragraph (d)(1)(i) of the revised Respiratory Protection Standard states "the employer shall select and provide an appropriate respirator based on the respiratory hazard(s) to which the worker is exposed and the workplace and user factors that affect respirator performance and reliability." Paragraph(d)(3)(iii) further states that for protection against gases and vapors an air-purifying respirator may be used provided that: (1) The respirator is equipped with an end-of-service life indicator (ESLI) certified by NIOSH for the contaminant; or

32 07/18/ Selection of air purifying respirators for gases and vapors with poor warning properties (dii... Page 2 of 3 7/17/2006 (2) If there is no ESLI appropriate for conditions in the workplace, the employer implements a change schedule for canisters and cartridges that is based on objective data that will ensure that canisters and cartridges are changed before the end of their service life. The employer shall describe in the respirator program the information and data relied upon and the basis for the change schedule and the basis for reliance on the data. Currently, there are few respirators available on the market with end-of-service life indicators (ESLI), and none for MDI. An employer must select a cartridge or canister recommended for that chemical by the manufacturer. The employer must then implement a change schedule for the canister or cartridges that is based on objective information or data that will ensure that the canister and cartridges are changed before the end of their service life. The data relied upon and the information forming the basis of the determination must be included in the written respirator program. If more information becomes available, an employer would be expected to review and if necessary, revise the change out schedule. The employer is required to select the appropriate respirator for each situation. Some factors that should be included in the evaluation by the employer are: a. The concentration of contaminant in the air to which employees will be exposed. Most substances which have permissible exposure limits, have 8-hour time-weightedaverages. Other substances (including TDI and MDI) have Ceiling Limits. For these substances, employee exposure may at no time exceed the exposure limit for the substance. 29 CFR (d)(3)(i) requires the employer to "provide a respirator that is adequate to protect the health of the employee and ensure compliance with all other OSHA statutory and regulatory requirements under routine and reasonably foreseeable emergency situations." Therefore, when selecting a respirator for protection against substances that have Ceiling Limits, the employer must not only consider if exposure levels may be reached or exceeded during routine operations but also if they may be exceeded during reasonably foreseeable emergency situations. The employer must then select a respirator that would provide adequate protection against these levels. b. Negative pressure respirators carry a greater risk of leakage than positive pressure respirators. If the face-to-facepiece seal is compromised, more contaminated air is likely to leak in than would be the case with positive pressure respirators. c. Vapors of diisocyanates are corrosive and severely damaging to the eyes. Contact may cause permanent eye damage. If a half mask respirator is selected, an employer would also be required under 29 CFR (a)(1) to ensure that the employee uses appropriate eye or face protection. d. Vapors of isocyanates may cause skin irritation and sensitization. The employer is required under 29 CFR (d) to assess the workplace and select appropriate personal protective equipment. Additional personal protective equipment to protect the skin of the face and neck may be required if an employer elects respirators which leave these areas exposed. e. Exposure to diisocyanates can cause various respiratory ailments. If an employee using an APR reports any medical signs or symptoms which could be attributed to isocyanate exposure, the employer must take appropriate action. If the symptoms may affect an employee's ability to use a respirator, (e)(7)(i) requires additional medical monitoring. We anticipate that some employers who perform the required evaluation will determine that

33 07/18/ Selection of air purifying respirators for gases and vapors with poor warning properties (dii... Page 3 of 3 7/17/2006 APRs are appropriate for their circumstances. Others may prefer to provide powered-air purifying respirators (PAPRs). Under some circumstances, other employers may determine that SARs may be the only appropriate type of respirator for these hazards. As with any other situation requiring the use of respirators, an effective written respiratory protection program must be developed and implemented. Key provisions include fit testing, medical evaluations, proper use of respirators, training and information (including the need for a user seal check each time the respirator is donned), maintenance and care of respirators, program evaluation and recordkeeping. You also noted that the OSHA website contains six letters of interpretation which predate the revision to the respiratory protection standard as well as statements on the "Isocyanates" Technical Links page which reflect that diisocyanates have poor warning properties, are sensitizers, or are too hazardous to allow air purifying respirators. OSHA is currently reviewing all letters on our website for inconsistencies with OSHA policy and appropriate action for these letters will be taken. Thank you for your interest in occupational safety and health. We hope you find this information helpful. Please be aware that OSHA's enforcement guidance is subject to periodic review and clarification, amplification, or correction. Such guidance could also be affected by subsequent rulemaking. In the future, should you wish to verify that the guidance provided herein remains current, you may consult OSHA's website at If you have further questions please feel free to call OSHA's Office of Health Compliance Assistance at (202) Sincerely, Richard E. Fairfax, Director Directorate of Compliance Programs Standard Interpretations - Table of Contents Back to Top Occupational Safety & Health Administration 200 Constitution Avenue, NW Washington, DC Contact Us Freedom of Information Act Customer Survey Privacy and Security Statement Disclaimers

34 Cartridge Service Life Estimation Report Page 1 of 2 7/14/2006 eslife Service Life Estimation Program Name: EIN: Department: Occupational Category: Exposure Group: Task Description: Tim Krill, CIH, CSP Hagemeyer North America Spray Applicators of Speedliner 1000 Spray application of Speedliner Concentration of ppm measured over a spray application session of 30 minutes using 4 gallons of Speedliner 1000 urethane coating. Estimated Cartridge Service Life: Cartridge Description Minutes Hours 8-Hr. Shifts 75SC 75SCP N P N P Input Parameters for Exposure Conditions: Contaminant [CAS #]: METHYLENE BISPHENYL ISOCYANATE [ ] 8-hr TWA: ppm STEL: ppm Ceiling: 0.2 ppm IDLH: 7 ppm User Specified OEL: ppm Worksite Concentration: ppm Breathing Rate: Moderate - maximum pace for continuous working (50 lpm) Temperature: 90 F Humidity: Greater than 80% Breakthrough: Results calculated at 10% breakthrough Safety Factor: Final results times 0.5 Cautions and Warnings One of more selected contaminants have poor Warning Properties. Disclaimer of Warranty The algorithm and database included in this program incorporate the best information currently available to North Safety Products, and are derived from published sources generally believed to be reliable. North makes no warranty or representation as to the accuracy, completeness or reliability

35 Cartridge Service Life Estimation Report Page 2 of 2 7/14/2006 of either the source material or the information resulting from the use of this program, and disclaims the implied warranties of merchantability and fitness for particular purpose, and all other warranties, express or implied. The user assumes all risks, if any, arising out of the use of this program, and North assumes no liability for any direct, indirect, incidental or consequential damages arising out of the use or inability to use the program. North reserves the right to change design, construction or formulation of its chemical cartridges or any of their components without notice to cartridge users of the effect of any such changes on service life or any cartridge change schedule derived from the use of this program. North Safety Products 2000 Plainfield Pike Cranston, RI USA Customer Service North Safety Products ezguide is a trademark of NorthSafetyProducts

36 Organic Vapor 8000 Series Cartridge Service Life Merlin 8000 Ver. 1.0 Search for Chemical by: Chemical Name (Alphabetical) CAS# (First digit) Chemical Name CAS# Methylene bisphenyl isocyanate Exposure Limit= ppm ACGIH TLV Exposure Level 1 ppm Temperature 90 F 32 C Relative Humidity 80-90% Concentration Units ppm mg/m3 Work Rate Light Medium Heavy AOSafety Respirator Quicklatch 8000 EZDrop 8000 Full Face 8300 Full Face 8400 AOSafety Cartridge AOSafety 8051 & 8051-P100 Organic Vapor Cartridge AOSafety 8053 & 8053-P100 Organic Vapor/Acid Gas Cartridge AOSafety 8061 & 8061-P100 Multi-Contaminant Cartridge Breakthrough Concentration 1.0 X Exposure Limit 0.5 X Exposure Limit 0.1 X Exposure Level Results Estimated Service Time >1000 hrs Press "Enter" to Calculate Messages: 7/17/2006

37 Organic Vapor 8000 Series Cartridge Service Life Merlin 8000 Ver. 1.0 Search for Chemical by: Chemical Name (Alphabetical) CAS# (First digit) Chemical Name CAS# Methylene bisphenyl isocyanate Exposure Limit= ppm ACGIH TLV Exposure Level 1 ppm Temperature 90 F 32 C Relative Humidity 80-90% Concentration Units ppm mg/m3 Work Rate Light Medium Heavy AOSafety Respirator Quicklatch 8000 EZDrop 8000 Full Face 8300 Full Face 8400 AOSafety Cartridge AOSafety 8051 & 8051-P100 Organic Vapor Cartridge AOSafety 8053 & 8053-P100 Organic Vapor/Acid Gas Cartridge AOSafety 8061 & 8061-P100 Multi-Contaminant Cartridge Breakthrough Concentration 1.0 X Exposure Limit 0.5 X Exposure Limit 0.1 X Exposure Level Results Estimated Service Time >1000 hrs Press "Enter" to Calculate Messages: 7/17/2006

38 3M Service Life Solution Page 1 of 1 7/14/2006 Current Selection 1. Contaminants 2. Exposures 3. Cartridges 4. Environment 5. Solution Help Home Page About Service Life Solution WARNING: These results are estimates only and must be used with caution. User Information Name: American Guest Account Solution Estimated Service Life = 999 Hours Want more individualized help? Check out our new 3M Health and Safety Services Notice! Service life calculation based on Methylenebisphenyl isocyanate at an Exposure = ppm Contaminants and Exposures Methylenebisphenyl isocyanate CAS#: Exposure: ppm Correction Factor: 2 Exposure Limit: ppm IDLH: WARNING: Relative humidity > 65% can dramatically reduce organic vapor chemica cartridge service life. An appropriate correction factor for reducing the service life estimate must be selected to account for the affect of high relative humidity. See the Relative Humidity Help screen for more information. Cartridge Selection [07192] 5000 Series Paint Spray Packout(OV/P95 Medium) Environment Information Relative Humidity: >65% Atmospheric Pressure (ATM): 1.0 Temperature: 122 F Work Rate: Medium Work Breakthrough Level:.1 x Exposure <- Previous Step Text Version Copyright (C) M. All rights reserved.

39 3M Service Life Solution Page 1 of 1 7/14/2006 Current Selection 1. Contaminants 2. Exposures 3. Cartridges 4. Environment 5. Solution Help Home Page About Service Life Solution WARNING: These results are estimates only and must be used with caution. User Information Name: American Guest Account Solution Estimated Service Life = 999 Hours Want more individualized help? Check out our new 3M Health and Safety Services Notice! Service life calculation based on Methylenebisphenyl isocyanate at an Exposure = ppm Contaminants and Exposures Methylenebisphenyl isocyanate CAS#: Exposure: ppm Correction Factor: 2 Exposure Limit: ppm IDLH: WARNING: Relative humidity > 65% can dramatically reduce organic vapor chemica cartridge service life. An appropriate correction factor for reducing the service life estimate must be selected to account for the affect of high relative humidity. See the Relative Humidity Help screen for more information. Cartridge Selection [07193] 5000 Series Paint Spray Packout(OV/P95 Large) Environment Information Relative Humidity: >65% Atmospheric Pressure (ATM): 1.0 Temperature: 122 F Work Rate: Medium Work Breakthrough Level:.1 x Exposure <- Previous Step Text Version Copyright (C) M. All rights reserved.

40 3M Service Life Solution Page 1 of 1 7/14/2006 Current Selection 1. Contaminants 2. Exposures 3. Cartridges 4. Environment 5. Solution Help Home Page About Service Life Solution WARNING: These results are estimates only and must be used with caution. User Information Name: American Guest Account Solution Estimated Service Life = 999 Hours Want more individualized help? Check out our new 3M Health and Safety Services Notice! Service life calculation based on Methylenebisphenyl isocyanate at an Exposure = ppm Contaminants and Exposures Methylenebisphenyl isocyanate CAS#: Exposure: ppm Correction Factor: 2 Exposure Limit: ppm IDLH: WARNING: Relative humidity > 65% can dramatically reduce organic vapor chemica cartridge service life. An appropriate correction factor for reducing the service life estimate must be selected to account for the affect of high relative humidity. See the Relative Humidity Help screen for more information. Cartridge Selection [07046] 6000 Series Organic Vapor Cartridge Environment Information Relative Humidity: >65% Atmospheric Pressure (ATM): 1.0 Temperature: 122 F Work Rate: Medium Work Breakthrough Level:.1 x Exposure <- Previous Step Text Version Copyright (C) M. All rights reserved.

41 3M Service Life Solution Page 1 of 1 7/14/2006 Current Selection 1. Contaminants 2. Exposures 3. Cartridges 4. Environment 5. Solution Help Home Page About Service Life Solution WARNING: These results are estimates only and must be used with caution. User Information Name: American Guest Account Solution Estimated Service Life = 999 Hours Want more individualized help? Check out our new 3M Health and Safety Services Notice! Service life calculation based on Methylenebisphenyl isocyanate at an Exposure = ppm Contaminants and Exposures Methylenebisphenyl isocyanate CAS#: Exposure: ppm Correction Factor: 2 Exposure Limit: ppm IDLH: WARNING: Relative humidity > 65% can dramatically reduce organic vapor chemica cartridge service life. An appropriate correction factor for reducing the service life estimate must be selected to account for the affect of high relative humidity. See the Relative Humidity Help screen for more information. Cartridge Selection [6001] Organic Vapor Cartridge Environment Information Relative Humidity: >65% Atmospheric Pressure (ATM): 1.0 Temperature: 122 F Work Rate: Medium Work Breakthrough Level:.1 x Exposure <- Previous Step Text Version Copyright (C) M. All rights reserved.

42 3M Service Life Solution Page 1 of 1 7/14/2006 Current Selection 1. Contaminants 2. Exposures 3. Cartridges 4. Environment 5. Solution Help Home Page About Service Life Solution WARNING: These results are estimates only and must be used with caution. User Information Name: American Guest Account Solution Estimated Service Life = 999 Hours Want more individualized help? Check out our new 3M Health and Safety Services Notice! Service life calculation based on Methylenebisphenyl isocyanate at an Exposure = ppm Contaminants and Exposures Methylenebisphenyl isocyanate CAS#: Exposure: ppm Correction Factor: 2 Exposure Limit: ppm IDLH: WARNING: Relative humidity > 65% can dramatically reduce organic vapor chemica cartridge service life. An appropriate correction factor for reducing the service life estimate must be selected to account for the affect of high relative humidity. See the Relative Humidity Help screen for more information. Cartridge Selection [6006] Multi Gas & Vapor Cartridge Environment Information Relative Humidity: >65% Atmospheric Pressure (ATM): 1.0 Temperature: 122 F Work Rate: Medium Work Breakthrough Level:.1 x Exposure <- Previous Step Text Version Copyright (C) M. All rights reserved.

43 3M Service Life Solution Page 1 of 1 7/14/2006 Current Selection 1. Contaminants 2. Exposures 3. Cartridges 4. Environment 5. Solution Help Home Page About Service Life Solution WARNING: These results are estimates only and must be used with caution. User Information Name: American Guest Account Solution Estimated Service Life = 999 Hours Want more individualized help? Check out our new 3M Health and Safety Services Notice! Service life calculation based on Methylenebisphenyl isocyanate at an Exposure = ppm Contaminants and Exposures Methylenebisphenyl isocyanate CAS#: Exposure: ppm Correction Factor: 2 Exposure Limit: ppm IDLH: WARNING: Relative humidity > 65% can dramatically reduce organic vapor chemica cartridge service life. An appropriate correction factor for reducing the service life estimate must be selected to account for the affect of high relative humidity. See the Relative Humidity Help screen for more information. Cartridge Selection [7251] Organic Vapor Cartridge Environment Information Relative Humidity: >65% Atmospheric Pressure (ATM): 1.0 Temperature: 122 F Work Rate: Medium Work Breakthrough Level:.1 x Exposure <- Previous Step Text Version Copyright (C) M. All rights reserved.

44 Industrial Polymers Inc., Houston, TX 07/18/06 Exposure Sampling for TDI and H 12 MDI Application of Speedliner 1000 APPENDIX E Photos of hygiene sampling session during application of Primer 450 and Speedliner 1000 urethane coating on June 26 th, 2006, 2 pages. HAGEMEYER, N.A.

45 Industrial Polymers Inc., Houston, TX 07/18/06 Exposure Sampling for TDI and H 12 MDI Application of Speedliner 1000 Urethane Coating Personal sampling pump Photo #1: A and B components of Primer 450 at the northeast corner of application site. June 26 th, 2006 at 0921 hr. Photo #2: Applying Primer 450 with 8-inch paint roller onto 4 ft x 8 ft plywood board. Personal sampling pump attached to applicator s belt. June 26 th, 2006 at 0914 hr. Filter cassette clipped to collar in breathing zone Filter sampling cassette in breathing zone Photo #3: Mixing Speedliner 1000 with pneumatic powered drill and stirrer rod. June 26 th, 2006 at 0948 hr. Photo #4: Pouring Speedliner 1000 into hopper of spray gun assembly. Filter cassette clipped on collar for sampling in breathing zone. June 26 th, 2006 at 0948 hr. Page 1 of 2 HAGEMEYER, N.A.

46 Industrial Polymers, Inc., Houston, TX 07/18/06 Exposure Sampling for TDI and H 12 MDI Application of Speedliner 1000 Urethane Coating Sample at southwest corner Spraying directed to west Personal sampling pump Filter cassette at northeast corner Photo #5: Spray application of Speedliner 1000 to 4 ft. x 8 ft. plywood board. Total of four gallons of Speedliner 1000 applied via spray gun. June 26 th, 2006 at 0950 hr. Photo #6: Area sampling stations at northeast corner (foreground) and southwest corner (background) of plywood board. Filter cassettes clipped to top of step ladders. June 26 th, 2006 at 1641 hr. Filter cassette 4.75 ft. above application site. Filter cassette 3.5 ft. above application site. Photo #7: Area sampling pump at northeast corner, i.e. 2 ft. from northeast corner of plywood board. Filter cassette is 4.75 ft. above board the application site. June 26 th, 2006 at 1641 hr. Photo #8: Area sampling pump at southwest corner, i.e. 3 ft. from southwest corner of plywood board. Filter cassette is 3.5 ft. above board the application site. June 26 th, 2006 at 1641 hr. Page 2 of 2 HAGEMEYER, N.A.