Ms Cait Gleeson Limerick County Council County Hall Dooradoyle County Limerick

02 April 2007

Re Reg No: POS18-01

Dear Ms Gleeson

I Environmental Protection Agency An Ghniornhoireocht urn Chaarnhnd Cornhshaoil

Headquarters, PO Box 3000 Johnstown Castle Estate County Wexford, Ireland

Ceanncheathru, Bosca Polst 3000 Eastat Chaislean Bhaile Sheain Contae Loch Garman. tire

T: +353 53 916 0600 F: +353 53 916 0699 E: info@epa.ie W: www.epa.ie

LoCall: 1890 33 55 99

Further to recent consultation, the attached additional information, received from Johnson & Johnson Vision Care (Ireland) Limited should be considered in conjunction with the information issued to you on 21 February 2007.

Please do not hesitate to contact me should you have any query.

Yours sincerely

Office of Licensing & Guidance

27 March 2007

Environmental Protection PO Box 3000, Johnstown Castle Estate, Co. Wexford.

Johnson & Johnson Vision Care (Ireland) Ltd, Reg. Nr: PO818-01, Additional Info rec'd 28/03/2007

- - G R O U P

Killakee House Belgard Square Tallaght Dublin 24 Ireland

Attention: Office of Licensing & Guidance

Re: Vistakon Ireland - Reg. No. PO81 8-01

To Whom It May Concern:

T+35314040700 F+35314599785

Following a meeting with Limerick County Council on Tuesday 20 March 2007, it was agreed that Vistakon Ireland would provide some supplementary information to Limerick County Council via-the Environmental Protection Agency regarding anticipated future effluent discharges.

BACKGROUND

In Oct 2006, Vistakon identified the potential for substantial increase in wastewater organic loads associated with proposed plant upgrades. These related to the introduction of an Isopropanol (IPA) cleaning process onto the site during quarter two 2007. The use of IPA is inherent to the latest generation of disposable contact lenses and presents the future for the Limerick site.

Our initial wastewater estimates were based on the introduction of an interim solution which would require higher IPA cleaning volumes. This would have resulted in an increase in the licensed discharge load. We therefore, after negotiations with Limerick County Council, requested and were granted a revised Trade Effluent Discharge Licence (TEDL) with headline numbers of 1,400 mg/l COD and 700 mg/l BOD at 800 m3/day.

It has subsequently been decided to replace this interim solution and to install the permanent lines. At the time it was agreed with the Council, that the revised licence would cover the interim solution and the longer-term discharges would require further detailed investigation including a study of treatment options. It was on the above numbers that our IPPC application was made to the EPA in January this year.

Project Management Limited Va PM Group. Company Registration No. 043789

Directors D Godson (Chairman), P McGmth (CEO), J Egan, D Flinter. B Gallagher, K Kelly, S Kelly, D Murphy, M Shelly, E Tanant. L Westman. J Winter (British) Secretary J Sheehan Associate Directors H Bendali, P Byme, P Coghlan, D Comgan. P Daly. R Doyle, F Dunphy, K Elliott, M Farrelly, G Fitzgerald, L Foley. J French, C Gill. P Hallam, J Hamilton. JJ Hayes, P Heade, A Hennessy, T Hickey, F Kennedy, K Kenny, M Law C Leddy, E Lee J Leonard. M Lynam. M McAree, T McGrath. P McHugh. J McNelis, B Madden, L Manley. S Moloney. C Moran, 8 Murphy, C Murphy, Niall Murphy, Niamh Murphy, D Nash. D Nugnet, P OBrien, J C OConnell, D ODwyer. N OLoughlin, B ONeill. P OReilly, A ORourke. B OToole. J Phelan, L Phelan. A Rayner, A Redmond. 8 Roe. P Ryan, B Shelly, G Shelly, A Sweeney, P Swords. P Treacher, T Water;, T 'White.

I .

- 2 -

RECENT CHANGES

Since then there has been progress on the design of the permanent process and four lines will be converted directly to the permanent solution. It is anticipated that this will happen over June, July, August and September 2007 with one line coming on-stream every month. This permanent solution has substantially lower emissions than the proposed interim process. In addition, some characterisation has been completed for a similar process in the USA and this also suggests a significantly lower IPA residual in the wastewater stream.

QUANTlFlA6LE CHANGES

It was originally expected that the cumulative current and future wastewater load would have increased to 5,500 population equivalent (p.e.) (or a COD load of 630 kg/day). This equated to an effluent COD of 800 mg/l average and 1,230 mg/l maximum, hence the request for a 1,400 mg/l limit for the revised TEDL.

It is now proposed to forgo this option and move directly to the permanent solution (as discussed above) with a lower wastewater concentration of IPA. The total predicted additional COD load from four lines for commissioning in 2007 equates to a total of 145 kg/day COD in comparison to the current baseline of 238 kg/day. This additional load of 145 kg/day will come on stream over the four months from June to September at a rate of approximately 25% per month to the total of 145 kg by September 2007.

Current baseline = 238 kg/day COD

June 2007 +36 = 274 kg/day COD

July 2007 +36 = 310 kg/day COD

August 2007 +36 = 346 kg/day COD

September 2007 +36 = 382 kg/day COD

In summary, the cumulative load will increase to a p.e. of approximately 3,050 in 2007 increasing to 4,450 p.e. by 2008 if four additional lines are converted (total of 8 as detailed in the IPPC licence application).

The above revised projections will result in a combined effluent discharge COD concentration of 495 mg/l (during max flow of 775 m3/day) and 750 mg/l (during average flow of 500 m3/day).

Based on laboratory testing it is believed that current baseline C0D:BOD ratio is approximately 2.2:l. Literature research suggests the IPA C0D:BOD ratio to be lower at 1.6: 1 i.e. a more biodegradable stream. The p.e. calculated above has made use of both of these figures proportionately i.e. current non-IPA effluent calculations are based on a ratio of 2.2:l and future predicted effluent calculations are based on a ratio of 1.6:l. Actual BOD ratios will be calculated during commissioning and operation of the lines.

K \Prqscls\Ol1418 VISTAKON IRELAND LTD'3GT IPA PROJECR22 ENVIRONMENTALIOSO INTEGRATED WLLUTION CONTROL\LlmenckCC-EPA EMuent Reylonre\EPA EMuent ResponreEPA Lsiier 23 3.07 Final dac Tswlale 162.TP.015 Issue 2,ZM11,Q5

- 3 -

PROPOSALS - THE WAY FORWARD

Limerick CC has tabled concerns regarding capacity of Castletroy Waste Water Treatment Plant (WWTP) to receive further substantial organic loads. The treatment plant is already believed to be working at or near to capacity. We accept that the precautionary principle should be applied and an evaluation of that capacity is to be determined. Therefore we propose as previously discussed and agreed to undertake pilot testing on site at the WWTP.

As you are aware the pilot plant supplier/operator has already visited site to determine installation requirements and any other local issues relating to the commissioning of the pilot plant. The resultant modifications are being implemented and the treatment plant is scheduled for commissioning in early April 2007. At the time of writing the pilot plant has already been located to site and will be commissioned during the first two weeks of April. Formal trials are expected to begin week commencing 16 April 2007.

The programme of treatment is as follows:

Week 1 Commissioning

Week 1 & 2 Acclimatisation - we anticipate that this should be achieved reasonably quickly as we will be using sludge directly from Castletroy WWTP

Operate at 33% anticipated IPA load - it is proposed to commence the acclimation of IPA at a relatively low concentration level (to be discussed and agreed with Limerick CC). This approach is considered appropriate due to planned staged addition of lines.

Operate at 66% anticipated IPA load

Operate at 100% anticipated IPA load

Interim report

Week 3 & 4

Week 5 & 6

Week 7 & 8

Week 9 & 10

Week 11 & 12

Week 13 & 14

Draft report with recommendations for discussion with LCC

Final report

Note: The above breakdown may change following interpretation of the results of each step and following discussion with Limerick County Council

The scope of the pilot plant treatment testing will also consider the following factors:

0 Organic treatment capacity

0 Hydraulic capacity

Oxygenation capacity

0

0 Flora identification

0

Sludge growth and removal rates

Macro and micro nutrient balance

K iPrqedslol1418 VISTAKON IRELAND LTDCGT IPA PROJECM? ENVIRONMENTAL\OW INTEGRATED WLLUTION CONTROClLirnmckCC EPA Emuen1 ResponselEPA Emuen1 ResponselEPA Lener 23 3 07 Rnal doc Ternplale 1BZTP 015 Issue 2 26101105

- 4 -

It is anticipated that the trial will be complete by end June 2007 with report finalised in August 2007.

ISOPROPYL ALCOHOL - WASTEWATER TREATMENT

We are continuing to investigate the instances of co-treatment of IPA wastewater in temperate climates at municipal wastewater treatment plants. However, we are finding it difficult to find examples of this specific combination.

We are aware of a wealth of operating experience globally of the treatment of brewing and distilling wastewaters (including alcohol and its precursors), both on-site and at co-located off-site plants. Indeed, EPA BAT Reference Guidance' recommends biological treatment for wastewaters containing low levels of organics.

Specifically, very little has been reported on the treatment of wastewater containing isopropyl alcohol (or IPA), although a number of references* indicate that this is a highly biodegradable substance.

Environmental Characteristics of IPA

Other characteristics of IPA are detailed below with sources of information:

German Water Hazard Class3 WGK 1 Low hazard to waters

Environmental Fate & Toxicity4

The LC50/96-hour values for fish are over 100 mg/l. This material is not expected to be toxic to aquatic life.

A Material Safety Data Sheet for IPA is provided in Attachment 1.

Inhibition Threshold Levels to Activated Sludge EPA Wastewater Treatment Manual5 details reported inhibition threshold levels for activated sludges. IPA is not specifically included in Table 3. However, ethylbenzene has the same WGK Hazard to Waters Classification i.e. WGKI and has a Risk Phrase of R11 which is also assigned to IPA. The inhibition level for activated sludge is detailed as 200 mg/l. Calculations of the anticipated IPA concentrations in the Vistakon effluent and mixed with the other streams entering Castletroy estimate an approximate IPA concentration of 32 mg/l which is less than 20% of the inhibition threshold.

Draft BAT Guidance Note on Best Available Techniques for the Brewing, Malting & Distilling Sector. Final

Karel Verschueren, Handbook of Environmental Data on Organic Chemicals, 2"d edition, 1983

I

Draft. October 2006

' Classification according to the Administrative Regulation of Substances Hazardous to Water (VwVwS) http://www. hvbg.de/e/bidwunlindex.html 4 Mallinckrodt Baker Inc. http://www.jtbal<er.com/msds/e1i~lishhtnil/i8840.l~

2

EPA Wastewater Treatment Manual - Characterisation of Industrial Wastewater 1998 5

K \ProleQslfli 1418 VISTAKON IRELAND LTO.3GT IPA PROJECW? ENVIRONMENTAL\flSO INTEGRATED POLLUTION CONTROLlLimenckCC EPA Effluent RewnseiEPA Emuent RerponseEPA Lener 23 3 07 Final doc T ~ W I ~ ~ P ~ T P o i 5 1 ~ 8 226101105

- 5 -

Following discussions with Limerick County Council, additional testing such as respirometry analysis may be conducted where it is felt supplementary analysis is required for the pilot plant project.

Similar IPA Wastewater Experience

We are familiar with a number of aerobic biological treatment plants in Dublin that are treating an IPA rich influent. These are BMS Cruiserath and Swords Laboratory. The treated effluent from these plants are subsequently directed to municipal wastewater treatment plants. These sites have had no problems treating influent rich in IPA. In addition, the limits provided in BMS Cruiserath’s IPPC licence allows concentrations of up to 1,250 mg/l COD to be discharged to the municipal wastewater treatment plant. These concentrations are significantly higher than those anticipated to be generated by Vistakon, particularly, when dilution by other Castletroy wastewater contributors is considered.

It has been shown that IPA can be beneficial to the operation of a biological wastewater treatment plant. In fact, during the annual scheduled shutdown of the above mentioned sites, IPA is used to maintain a healthy biological population in the absence of normal influent flow.

PM are more than happy to facilitate a discussion and if required a site tour to the BMS Cruiserath Biological Wastewater Treatment Plant.

Input Comparison

Based on an overall total flow of 5,000 m3/day to Castletroy Wastewater Treatment Plant, the volume of IPA predicted will constitute less than 0.01% of the overall volume. Material Safety Data Sheets state that “At very low concentrations in water, this product is biodegradable in a biological wastewater treatment plant”.

SUM MARY

I trust the discussion and program detailed above provides adequate information on the decrease in anticipated loads, properties of the proposed effhient and the pilot testing programme and that this will assist you in a favourable consideration of our proposals.

The pilot plant trials and respirometry testing results will be forwarded to the Environmental Protection Agency as soon as possible.

Union Carbide Corporation http://www.m idsuneroup.corn/MSDS-PDF/Isopropanol.pdf and Decon 6

Laboratories, Inc. h t t p : l / w w w . d e c o n l a b s . c o m l m s d s i C i ~ e l i o l % 2 d f

K 1PTo~~siOl1418 VISTAKON IREIAND LTD-XIT IPA PROJECTV2 ENVIRONMENTAL\OSO INTEGRATED POLLUTION CONTROLiLlmenckCC-EPA Emuenl ResponseIEPA EfRuenl R-nseiEPA leaer 23 3 07 Rnal mC Template 1 ~ ~ ~ ~ o i s i s s u e t 2 6 m i m 5

- 6 -

We underst d that this will conclude agreed additional information requests from last Tuesday’s meeting with Limerick County Council. Please however do not hesitate to call or email with any other queries. We have provided one original, two hard copies and two copies on CD.

Yours sincerely,

Niall O’Loughlin

PM Group - EHS Manager

cc. Mr Pearse Moroney - Vistakon Ireland

Mr Robin Evans - Vistakon Ireland

Mr Tom White - PM Group

Ms Eileen Lee - PM Group

Mr Stephen Clune - PM Group

K \Pq&s!fIlt418 VISTAKON IRELAND LTD_X;T IPA PROJECWZ ENVtRONMENTAL\OW INTEGRATED WLLUTION CONTROLlLimentkCC EP4 Emuent ResponseIEPA Emuenl Rewse\EPA Letter 23 3 07 Rml da Template 162TP015lssue 226101105

- 7 -

ATTACHMENT 1

MATERIAL SAFETY DATA SHEET FOR ISOPROPYL ALCOHOL (IPA)

K IPm~eC1sW11418 VISTAKON IRELAND LTD.?GT IPA PROJECTVZ ENVIRONMENTAL\Q50 INTEGRATED WLLUnON CONTR(K\LimwckCC EPA ERluenl ResponseIEPA €fluent ReSpMselEPA Leller 23 3 07 Final mC Ternpiale 162TP015 lws226101D5

P.O. Box 864 135 Redstone Street Southington, CT 06489 U.S.A

Toll Free: (800)-4-midsun (U.S.A. only) (860) 378-0100 (860) 378-0103 (Fax) www .midsungroup.com

Product Name Chemical Name Chemical Family Formula Synonyms

Isopropanol An hydrous, USP Material Safety Data Sheet (MSDS) +. t

Isopropanol Anhydrous, USP Isopropyl Alcohol Alcohols (CH3)2 CHOH Isopropanol Anhydrous, USP, Isopropanol, Anhydrous Semi-Conductor grade, dimethyl carbinol, 2-Propanol.

MANUFACTURER'S CONTACT INFORMATION: Union Carbide Corporation

39 Old Ridgebury Road Danbury, CT 06817-0001

INFORMATION: (304) 744-3487 Non-Emergency: (732) 563-5522 Union Carbide Customer Service:

(800) 588-4000

Components Isopropanol

Union Carbide urges each customer or recipient of this MSDS to study it carefully to become aware of and understand the hazards associated with the product. The reader should consider consulting reference works or individuals who are experts in ventilation, toxicology and fire prevention, as necessary or appropriate to use and understand the data contained in this MSDS. To promote safe handling, each customer or recipient should: 1) Notify its employees, agents, contractors and others whom it knows or believes will use this material or the information in this MSDS and any other information regarding hazards or safety; 2) Furnish this same information to each of its customers for the product; and 3) Request its customers to notify their employees, customers and other users of the product of this information.

% (WT) CAS No. <= 100 67-63-0

Appearance & Odor Boiling Point (760 mmHg) Freezing Point

Transparent, colorless liquid - Slight ethanol/acetone-like 160.1"F (82.3" C) -127" F (-89" C)

D

Vapor Pressure ( 33 mmHg@20" C) Liauid Densitv (@20" C)

Melting Point 1 Not Applicable Specific Gravity (H20 = 1) I 0.787 20" C / 20" C

0 ----- .. _.

4.4 kPa 6.5475 dcm3

I EvaDoration Rate (Butvl Acetate = 1) 1 2.9 I

Vapor Density (Air = 1) Solubility in Water (By weight) Reactivity in Water Percent Volatiles PH

I Molecular Weight I 60.10 e/mol I

2.1 20" c 100% Not Readily Hydrolyzed 100% Not currently available

1sopropanol.doc Page I of 1 Rev. 414106

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Isopropanol Anhydrous, USP Material Safety Data Sheet (MSDS) 4 *

IV. Fire and Explosion Data Flash Point - Closed Cup I (Tag Closed Cup ASTM D-56) 53” F 12” C Flash Point - Open Cup I (Tag Open Cup ASTM D-1310) 63” F 17” C

Flammable Limits in Air (% By Volume) Lower

Unusual Fire & Explosion Hazards

fi Fire Extinguishing Media

Special Protective Equipment for Firefighters

2.0% (V) 12.7% (V) 200” F Not currently available Vapors form from this product and may travel or be moved by air currents and ignited by pilot lights, other flames, smoking, sparks, heaters, electrical equipment, static discharges or other ignition sources at locations distant from product handling point. Vapors from this material may settle in low or confined areas or travel a long distance to an ignition source and flash back explosively. Static ignition hazard can result from handling and use. Electrically bond and ground all containers, personnel and equipment before transfer or use of material. Use proper bonding and grounding during product transfer as described in National Fire Protection document NFPA 77. (See Below: Engineering Controls.) Warning: This material may produce a floating fire hazard. Flame may be invisible. Approach fire with caution. Extinguish fires with water spray or apply alcohol-type or all-purpose-type foam by manufacturer’s recommended techniques for large fires. Use carbon dioxide or drv chemical media for small fires. No information currently available. Use water spray to cool fire-exposed containers and structures. Use water spray to disperse vapors; reignition is possible. Use self-contained breathing apparatus and protective clothing.

Burning can produce the following products: Carbon dioxide and/or carbon monoxide. Carbon monoxide is highly toxic if inhaled; carbon dioxide in sufficient concentrations can act as an asphyxiant. Process Hazard: Sudden release of hot organic chemical vapors or mists from process equipment operating at elevated temperature and pressure, or sudden ingress of air into hot equipment under a vacuum may result in ignitions without the presence of obvious ignition sources. Published “auto ignition” or “ignition” temperature values cannot be treated as safe operating temperatures in chemical processes with out analysis of the actual process conditions. Any use of this product in elevated temperature procedures should be thoroughly evaluated to establish and maintain safe operating procedures. Further information is available in a technical bulletin entitled “Ignition Hazards of Organic Chemical Vapors.”

V. Reactivity Data Stability I Stable I Incompatibility Strong oxidizing agents. Halogens. Strong inorganic acids. Aldehydes. Halogen

communds. Inhibitors/Stabilizers I Not Applicable Hazardous Polymerization I Will not occur

1sopropanol.doc Page 2 of 2 Rev. 414106

Isopropanol Anhydrous, USP Material Safety Data Sheet (MSDS)

Exposure

Skin

VI. Health Hazard and Toxicological Data Hazards of Product: Warning! Flammable. Causes eye irritation. May cause dizziness and drowsiness.

Effects of Single Acute Overexposure Causes irritation, experienced as stinging and discomfort or pain. Corneal injury may occur. May cause minor irritation with itching and possible slight local redness. Prolonged or

Skin Absorption

Exposure Skin Other Medical Conditions Aggravated by Exposure

repeated contact may cause defatting and drying of skin. High concentrations of vapor may cause central nervous system depression, with weakness, drowsiness and loss of consciousness. Vapor causes irritation of the respiratory tract, with coughing and chest discomfort. Slightly toxic. May cause dizziness, faintness, drowsiness, decreased awareness and responsiveness, lack of coordination, abdominal discomfort, nausea, vomiting and diarrhea. Exposure to small quantities is not expected to cause adverse health effects. Widespread or prolonged exposure may result in the absorption of harmful amounts or material, particularly in infants, leading to signs and symptoms as described for swallowing.

Effects of Repeated Overexposure Prolonged or repeated skin overexposure may cause defatting of the skin. None currentlv known. Skin contact may aggravate an existing dermatitis. I

Acute Toxicity Peroral: Rat LD50 6.48 (4.80 - 8.76) ml/kg Major Signs: Unsteady gait, prostration, heavy breathing. Gross Pathology: Lungs and abdominal viscera discolored. Percutaneous: Rabbit LD50 24 hr occluded 8.0 (4.9 - 13.1) mlkg Gross Pathology: Lungs, liver, stomach discolored. Inhalation: Rabbit Static generation of vapor. Exposure Time: 2 hr. Room Temperature. Mortality: 4/6 Major Signs: Lacrimation, loss of coordination, prostration. Gross Pathology: Lungs discolored. Inhalation: Rabbit Dynamic generation of vapor. Exposure Time: 4 hr. 12,000 ppm. Mortality: 0/12 Major Signs: Prostration. Gross Pathology: Lungs, kidneys and liver discolored. Inhalation: Rabbit Dynamic generation of vapor. Exposure Time: 8 hr. 12,000 ppm. Mortality: 8/12 Major Signs: Prostration. Gross Pathology: Lungs, kidneys and liver discolored. Inhalation: Rabbit Dynamic generation of vapor. Exposure Time: 8 hr. 8,000 ppm. Mortality: 0/12 Major Signs: Prostration. Gross Pathology: Lungs, kidneys and liver discolored. Inhalation: Rabbit Static generation of vapor. Exposure Time: 4 hr. Room Temperature. Mortality: 6/6 Major Signs: Lacrimation, loss of coordination, prostration. Gross Pathology: Lungs discolored. Inhalation: Rabbit Static generation of vapor. Exposure Time: 1 hr. Room Temperature. Mortality: 0/6 Major Signs: Lacrimation, loss of coordination, prostration. Gross Pathology: Lungs discolored.

Irritation Skin: Rabbit 24 hours uncovered. No irritation. Eve: Rabbit 0.02 ml. Moderate corneal iniurv. I

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Isopropanol Anhydrous, USP Material Safety Data Sheet (MSDS)

Continued on Next Page

VI. Health Hazard and Toxicological Data (Continued) Eco toxici ty

Toxicity to Micro-organisms: BacteridNA IC50 5000 mg/l Toxicity to Aquatic Invertebrates: Daphnia LC50 48h 7550 mg/l Toxicity to Fish: Fathead Minnow LCSO 96 h 8300 mg/l

THOD (measured) 2.30 mg/mg THOD (calculated) 2.40 mg/mg OctanoYWater Partition Coefficient (measured) 0.14

Significant Data with Possible Relevance to Humans The following is a summary of TSCA Section 4 Test Rule results: Large doses (>800 mg/kg/day) of isopropanol given

Further Information

orally to pregnant rats during the critical period of gestation produced slight decreases in fetal weight. These doses also caused evidence of toxicity in the mothers. Oral doses as high as 480 mg/kg/day caused evidence of toxicity in pregnant rabbits but did not produce evidence of embryo or fetal toxicity. Isopropanol did not produce an increased incidence of malformations (teratogenicity) in either species. An indication of reduced mating performance in 2"d generation male rats was noted at oral doses of 1,000 mg/kg/day in a two-generation reproductive study. Increased neonatal mortality was also seen at doses of 500 mg/kg/day and greater in this study. No evidence of neurotoxic effects was observed in studies specifically designed to assess neurobehaviorial functions in neonatal rats after oral dosing of mothers during gestation and lactation. In an acute vapor inhalation study, high concentrations of isopropanol (1,500 ppm and greater) caused a spectrum of transient effects indicative of narcosis. In repeated inhalation exposure studies, high vapor concentrations (5,000 ppm) produced an increase in motor activity in rats first noted after 4 weeks of exposure. The effect was reversible completely resolving within 14 days after 13 weeks of exposure. No evidence of damage to nerve tissue was seen in this study. Lifetime exposure of laboratory animals to high concentrations of isopropanol vapor (greater than 1,500 ppm) exacerbated chronic progressive nephropathy, commonly seen in aged animals. The relevance of this finding to human health hazard evaluation is unknown. No evidence suggestive of carcinogenic activity was noted in chronic vaDor inhalation studies with isoDroDano1 in rats and mice.

route, including mucous membranes and the eyes, either by contact with vapors or by direct skin contact with the substance. A "Blank" in the Skin column indicates that exposure by the cutaneous (skin) route is not a potential significant contributor to overall exDosure.

1sopropanol.doc Page 4 of 4 Rev. 5/4/06

1 - *

Inhalation

Eye Contact

Skin Contact

Isopropanol Anhydrous, USP Material Safety Data Sheet (MSDS)

Remove to fresh air. Give artificial respiration if not breathing. If breathing is difficult, oxygen may be given by qualified personnel. Obtain medical attention. Immediately flush eyes with water and continue washing for several minutes. Remove contact lenses, if worn. Obtain medical attention. Remove contaminated clothing. Wash skin with soap and water. If irritation persists or if contact has been Drolonned. obtain medical attention.

Respiratory Protection Eyemace Protection Clothing/Gloves Other Protective Equipment Ventilation

I Ingestion 1 If patient is fully conscious, give two glasses of water. Induce vomiting. This should be done only by 1

Use self-contained breathing apparatus in high vapor concentrations. Monogoggles Rubber, Plastic gloves Eye bath and safety shower.

General (mechanical) room ventilation is expected to be satisfactory where this product is stored and handled in closed equipment. Special, local ventilation is needed at points where vapors can be expected to escape to the workplace air. Other Precautions: Vapor may settle in low or confined areas or travel a long distance to an ignition source and flash back explosively.

I medical or experienced first aid personnel. Obtain medical attention. Note to Physician: There is no specific antidote. Treatment of overexposure should be directed at the control of

Storage Conditions Handling Procedure

I symptoms and the clinical condition of the patient.

No information currently available. Keep away from heat, sparks and flame. Avoid contact with eyes. Keep containers closed. Use

I distant from product handling point and may flash back explosively. C. ENVIRONMENTAL PROTECTION Spill and Leak Procedure

Waste Disposal I Considerations

k------ Environmental Fate

Extinguish and do not turn on any ignition source until the area is determined to be free from fire or explosion hazard. Small spills can be flushed with large amounts of water; larger spills should be collected for disposal. Personal Precautions: Avoid contact with eyes. Wear suitable protective equipment. Incinerate in a furnace where permitted under federal, state and local regulations. Dispose in accordance with all applicable federal, sate and local environmental regulations. Empty containers should be recycled or disposed of through an approved waste management facility. At very low concentrations in water, this product is biodegradable in a biological wastewater treatment plant. NOTE: Disposal methods identified are f o r the product as sold. For proper disposal of used material,

an assessment must be completed to determine the proper and permissible waste management . .

options permissible under applicable rules, regulations undlor laws governing your location. BOD (% Oxygen consumption) Day 5: 28% Day 10: 77% Day 20: 78%

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Isopropanol Anhydrous, USP Material Safety Data Sheet (MSDS)

D. TRANSPORTATION INFORMATION U.S. D.O.T. Proper Shipping Name ID No. Hazard Class I Packing Group

Non-Bulk Isopropanol UN1219 Bulk Isopropanol UN1219 3 PGII I This informal

Continued on Next Page

SARA

VIII. Preventive Measures Continued

in 40 CFR 302.4 (unlisted hazardous substances are not identified) and are present at levels that could require reporting: None. SARA Title III Sections 302 and 304: The following components of this product are listed as extremely hazardous substances in 40 CFR Part 355 and are present at levels

3

SARA

PG I1

which could require reporting and emergency planning: None. SARA Title I11 Section 313: The following components of this product are listed as toxic

SARA

fion is not intended to convey all specific regulatory or operational requirementslinformation relating to I

contain toxic chemicals at levels which require reporting under the statute. SARA Title I11 Sections 31 1 and 312: Delayed Hazard: Yes Fire Hazard: Yes Immediate Health Hazard: Yes Reactive Hazard: No

this product. Additional transportation system information can be obtained through an authorized sales or customer service representative. It is the responsibility of the transporting organization to follow all applicable laws, regulations and rules relating to the transportation of the material.

TSCA

IX. Regulatory InformatiodClassif ications CERCLA I The following components of this product are specifically listed as hazardous substances

Sudden Release of Pressure Hazard: No All components of this product are on the TSCA inventory or are exempt from TSCA

EINECS CEPA (DSL) Pennsylvania

Massachusetts

inventory requirements. The component of this product is on the EINECS inventory The component of this product is on the DSL. Worker and Community Right-to-Know Act: This product is subject to the Worker and Community Right-to-Know Act. The following components of this product are at levels which could require identification in the MSDS: Component: Isopropanol CAS# 67-63-0 Amount:<=100.0000% Hazardous Substances Disclosure by Employers: The following components of this

chemicals in 40 CFR 372.65 and are present at levels which could require reporting and customer notification under Section 313 and 40 CFR Part 372: This product does not

California Component: Isopropanol CAS# 67-63-0 Amount:<=100.0000% Proposition 65 - Safe Drinking Water and Toxic Enforcement Act of 1986: This product

California

contains no listed substances known to the State of California to cause cancer, birth defects or other reproductive harm, at levels which would require a warning under the statute. South Coast Air Quality Management District Rule 443.1 (Labeling of Materials Containing Organic Solvents) VOC: 785 g/l Vapor Pressure 33 mmHg 020" C.

product appear on the Massachusetts Substance List and are present at levels which could require identification in the MSDS:

1sopropanol.doc Page 6 o f 6 Rev. 4/4/06

1 '

HMIS ratings for this product are

4 * Isopropanol Anhydrous, USP Material Safety Data Sheet (MSDS)

H - 2 F - 3 s - 0

~

laws relating to the product being used.

NFPA ratings for this product are H - 2 F - 3 s-0

- You should be familiar with the hazard communication applicable to your workplace.

Recommended Uses and Restrictions: For Industrial Use Only. Available Literature and Brochures: There may be additional product safety information on this product, which may be obtained by calling your Union Carbide Corporation Sales or Customer Service Contact.

The opinions expressed herein are those of qualified experts within Union Carbide. We believe that the information contained herein is current as of the date of this Material Safety Data Sheet. Since the use of this information and the conditions of the use of theproduct are not under the control of Union Carbide, it is the user's

obligation to determine conditions of safe use of the product.

Isopropanol.doc Page I of 7 Rev. 4/4/06