651 Colby Drive, Waterloo, Ontario, N2V 1C2 Telephone: (519) 884-0510 Fax: (519) 884-0525 www.CRAworld.com July 10, 2014 Reference No. 087078-10 Mr. Jeffrey V. Peister, P.Geo. Environmental Officer – Eastern Canada Canadian Pacific General Yard Office 2025 McCowan Road Toronto, Ontario M1S 5K3 Dear Mr. Peister: Re: 1.0 CP Cavers Cove Plastic Pellet Release January 21, 2008 Nipigon Sub Derailment Cavers, Ontario Introduction Conestoga-Rovers and Associates (CRA) has prepared this letter for Canadian Pacific Railway (CP) to provide a professional opinion as to the potential for toxicity and risks to human and ecological receptors associated with residual presence of plastic pellets released into Covers Bay, Lake Superior, Ontario (Latitude 48⁰53’52.59”N Longitude 87⁰40’22.29”W). The January 21, 2008 derailment involved fourteen railcars, with the majority of affected cars remaining in the vicinity of the track. However, four railcars slid down the embankment towards Cavers Cove and released some of their plastic pellets cargo. Cleanup commenced immediately and included the vicinity of the derailment, as well as other shoreline locations and nearby islands. The collection of the plastic pellets was conducted to remove as much of the product as possible. However, residual quantities of plastic pellets can still be found at a few locations. Our current opinion is designed to assess any risks associated with the most likely exposure scenario of the incidental contact of receptors to the residual pellets. Worldwide Engineering, Environmental, Construction, and IT Services July 10, 2014 Reference No. 087078-10 -2- 2.0 Product Identity Plastic pellets are made from non-coloured or odorous translucent polyethylene. Their final application includes the thermoplastic production of film, sheet, pipe, containers, and other consumer and industrial goods. The product is neither hazardous, nor controlled, nor regulated under Canadian or United States regulations. The pellets are stable under ambient conditions. Additional information is contained in the attached Material Safety Data Sheet (MSDS) for NOVAPOL® Polyethylene (MSDS ID: NOVA-0029). 3.0 Toxicity and Risks to Receptors The plastic pellets are made exclusively of polyethylene, which is a well-recognized inert polymer that has many critical and sensitive applications, including direct contact with food and in surgical devices1. As such, the material making up the pellets, by itself, will not have direct toxic effects should the pellets be ingested or touched by human or ecological receptors. However, although toxicologically inert, the pellets may impart physical effects under certain exposure conditions. The overall potential for risks to each receptor group is discussed below. Potential for Risks to Human Health According to the MSDS from NOVA Chemicals, the product may contain up to 1 percent (by weight) of diatomaceous earth or talc as antiblock agents. These additives may be associated with inhalation hazards (and skin irritation) due to the presence of crystalline silica2. However, given the washing effect once submerged in water for extended periods of time, the antiblock additives are not expected to remain on the pellets that may wash ashore. Moreover, the pellets themselves are too large to mobilize into air to be potentially inhaled by recreational and residential users (i.e., polyethylene pellets are not respirable). Also, any additives entrained into the polymer matrix are expected to remain there inextricably bound. Therefore, any inhalation hazards associated with the leftover pellets are considered nil. While shoreline users may come into direct dermal contact with the few remaining pellets while swimming, walking, playing in sand, or beachcombing, hazards are also unlikely since the 1 2 http://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfcfr/CFRSearch.cfm?CFRPart=177 https://www.osha.gov/dsg/topics/silicacrystalline/ Worldwide Engineering, Environmental, Construction, and IT Services July 10, 2014 Reference No. 087078-10 -3- additives would have washed off and polyethylene is biologically inert (i.e., it does not react or enter the skin) and is considered nontoxic. In the unlikely events of intentional, accidental, or incidental pellet ingestion, adverse effects are highly unlikely given the inert nature of the leftover pellets in the environment (their limited potential for direct product toxicity, polyethylene is not soluble, and it is not absorbed into the gastrointestinal tract). Oral toxicity estimates are in the grams per kilogram range. Therefore, any ingested pellets (very unlikely in the grams per kilograms range) should pass though the digestive system without injury. Potential for Risks to Ecological Health Similar to the human receptors, direct toxicological effects on biota in contact with residual plastic pellets is very unlikely. Direct toxicity data are measured in the grams per liter range. Since polyethylene does not solubilize in water and is not taken up via integument or gastrointestinal track, bioaccumulation, and subsequent food chain transfer is not possible. Although not directly toxic, once released into the aquatic and terrestrial environment, the pellets will persist. There may be degradation (embrittlement) after prolonged exposure to sun, but not full degradation. As such, there is a potential for biota to ingest the pellets (intentionally or unintentionally), leading to gastrointestinal impaction and/or starvation. Lighter than water, the plastic pellets will float, thereby reducing the availability for ingestion by bottom-feeding fish and sediment-dwelling biota. However, any floating pellets may be attractive to pelagic fish feeding at the water surface and shore/aquatic birds dabbling in/on shallow water/beaches. Nevertheless, the remaining concentrations of pellets in the foraging areas of biota are unlikely to be high enough to adversely affect the receptors via impaction/starvation. Worldwide Engineering, Environmental, Construction, and IT Services July 10, 2014 Reference No. 087078-10 -4- 4.0 Conclusions Based on the inert toxicological and physical properties of the polyethylene pellets, combined with the diminishing presence on shorelines and in shallow water, it is CRA’s opinion that the remaining pellets are associated with little or no risks to human and ecological receptors. If you have any questions or wish to discuss further, please contact me at 972-679-7872. Sincerely, CONESTOGA-ROVERS & ASSOCIATES Andrew Pawlisz, D.A.B.T, E.R.T. (UK) AP/cjg/1 Encl. cc: Ryan Shepherd (CRA) Worldwide Engineering, Environmental, Construction, and IT Services A NOVA Chemicals? Material Safety Data Sheet Material Name: Polyethylene - Not Coloured(All Grades) ?"395 "31 ll Section 1 - Product and Company Identification Synonyms: HDPE. LDPE. LLDPE, LMDPE. MDPE Polyethylene resins. ethylene polymers Chemical Name: Polyethylene Chemical Family: Polymer Material Use: Thermoplastic resin extruded into film. sheet or pipe. or moulded into containers and other shapes. Chemical Formula: Not applicable NOVA Chemicals EMERGENCY Telephone Numbers: PO. Box 2518. Station North America (Canada and US): Calgary. Alberta. Canada T2P 506 1300?5515682. 1-403-314-8767 (NOVA Chemicals) (24 hours) 1?800?424?9300 (CHEMTRECWUSA) (24 hours) MSDS Information: 1-412-490-4063 1?613?996?6666 (Canutec?Canada) (24 hours) MSDS Email: msdsemail@novachem.com Latin/South America: +44 (0) 1235 239 670 (NCEC) (24 hours) Mexico: +52 555 004 8763 (NCEC) (24 hours) Section 2 - Hazards Identification HMIS Ratings: Health: 0* Fire: 1 Physical Hazard: 0 Personal Protection: safety glasses. gloves, respirator Hazard Scale: 0 Minimal 'l Slight 2 Moderate 3 Serious 4 Severe Chronic hazard Ratings: Health: 0 Fire: 1 Reactivity: 0 Hazard Scale: 0 Minimal ?l Slight 2 Moderate 3 Serious 4 Severe Emergency Overview Product is a translucent to white. non-toxic solid pellet or granular powder having minimal odour. Ducts and heat-released air emissions may be irritating to the eyes. skin. and respiratory system. Accumulated fine dusts may form explosive air-dust mixtures. Spilled product may create a dangerous slipping hazard. Keep released pellets away from storm sewers and from entry into other aquatic systems. Under fire conditions. product will readily burn and emit irritating smoke. Contact with molten material may cause serious thermal burns. Potential Health Effects: Contact with powder or fines may cause mechanical irritation. Contact with hot or molten material may cause severe injury, including possible blindness. Potential Health Effects: Skin Contact with powder or fines may cause mechanical irritation which is increased by rubbing or if skin is dry. Contact with hot or molten material may cause severe thermal burns. The silica/talc is inextricably bound or coated in the polyethylene; this would minimize the potential for skin irritation from the additive(s). Potential Health Effects: Ingestion Ingestion may produce mild gastrointestinal irritation and disturbances. Potential Health Effects: Inhalation Inhalation of fine particles may cause respiratory irritation. Thermal processing fumes may cause irritation, pulmonary oedema and a possible asthma-like response. The silica/talc is inextricably bound or coated in the polyethylene; this would preclude an inhalation hazard. ll Section 3 - on Ingredients II CAS Component Percent by Wt. 9002684 Polyethylene (Ethane homopolymer) e98 68855-54-9 andlor Flux-calcined diatomaceous earth and/or 0-1 14307-9643 Talc (Hydrated Magnesium Silicate) Not Available Additives 0-1 Additional Information This product may also be described as 1?Butene. polymer with ethane (CAS 25087-34-7) or as 1-Hexene. polymer with ethane (CAS 25213028). Ethane and ethylene are interchangeable. This is 'antiblock'. It is added to some NOVAPOL resin grades (eg. film resins). Flux-calcined diatomacaous earth may contain up to 75% silica. Other chemical additives including antioxidants. UV stabilizers, processing aids and slip agents may be formulated into various polyethylene resin grades in a total concentration of less than 1% WM. Page 1 of 9 Issue Date: July 8. 2013 Revision: 5.1 Print Date: 26-Aug-13 Material Safety Data Sheet Material Name: Polyethylene - Not Coloured (All Grades) ?"393 "33 This product is NOT hazardous under 29 CFR 1910.1200 (Hazard Communication). This material is NOT a controlled product under Canadian regulations. This material is NOT REGULATED as a hazardous material dangerous goods for transportation. See Section 8 for applicable exposure limits. See Section 11 for applicable toxicity data. Section 4 - First Aid Measures First Aid: Eyes Remove contact lenses, if it can be done safely. Immediately flush eyes with water for at least 15 minutes, while holding eyelids open. Seek medical attention if develop or persist. First Aid: Skin Remove dusty or contaminated clothing and shoes. Wash affected area with soap and water. Seek medical attention if develop or persist. In case of contact with molten product, cool rapidly with water and seek immediate medical attention. Do not attempt to remove molten product, or molten product that has cooled, from skin without medical assistance. First Aid: inhalation Move affected individual to non?contaminated air. Loosen tight clothing such as a collar, tie, belt or waistband to facilitate breathing. Seek immediate medical attention if the individual is not breathing, is unconscious or if any other persist. inhalation of smoke following a fire may result in delayed pulmonary oedema; seek immediate medical attention. First Aid: ingestion Material is not expected to be absorbed from the gastrointestinal tract. DO NOT INDUCE VOMITING. Loosen tight clothing such as a collar, tie, belt or waistband. Seek immediate medical attention. First Aid: Notes to Physician After adequate first aid, no further treatment is necessary, unless reappear. For more detailed medical emergency support information call 1-800?561-6682 or 1-403-314-8767 (24 hours, NOVA Chemicals Emergency Response). Burns should be treated as thermal bums. Molten resin will come off as healing occurs; therefore, immediate removal from the skin is not necessary. Treatment should be directed at the control of and the clinical condition of the patient. ingested material should pass through the digestive system without injury. The silica/talc (if present) is inextricably bound or coated in the polyethylene; this would minimize the potential for skin irritation and preclude an inhalation hazard from the add itive(s). ll Section 5 Fire Fighting Measures See Section 9: Physical Properties for flammability limits, flash point and auto-ignition information. General Fire Hazards Solid resins support combustion but do not meet combustible definition. Product will burn at high temperatures but is not considered flammable. Under fire conditions, product will readily burn and emit irritating smoke. A high concentration of airborne powders or dust may form an explosive mixture with air. Explosion Hazards Accumulated fine dusts may form an explosive mixture with air. Risk of dust-air explosion is increased if flammable vapours are also present. May accumulate hazardous static charge. Hazardous Combustion Products Upon heating, polyethylene may emit various oligomers, waxes and oxygenated hydrocarbons as well as carbon dioxide, carbon monoxide and small amounts of other organic vapours aldehydes, acrolein). inhalation of these decomposition products may be hazardous. Extinguishing Media Water fog or water spray. In the case of small fires, dry chemical or carbon dioxide or foam can be used. Avoid high pressure, direct water stream that may spread molten or burning resins. Fire Fighting Equipment/instructions Position upwind. Keep unnecessary personnel away. Move containers from fire area if you can do so without risk. Fight fire from maximum distance or use unmanned holders or monitor nozzles. Fire fighters should wear full- face, self-contained breathing apparatus and thermal protective clothing. Avoid inhaling any smoke and combustion materials. Remove and clean or destroy any contaminated clothing. Cool containers with flooding quantities of water until well after the fire is out. Control runoff waters to prevent entry into sewers, drains, ditches, underground or confines spaces and waterways. Page 2 of 9 issue Date: July 8, 2013 Revision: 5.1 Print Date: 26-Aug-13 Material Safety Data Sheet Material Name: Polyethylene - Not Coloured (All Grades) ?"303 ?33 NOVA-0029 ll Section 6 - Accidental Release Measures Evacuation Procedures Isolate area. Keep unnecessary personnel away. Alert stand-by emergency and fire fighting personnel. Spills Stop leak, isolate and contain spill. Prevent entry into sewers, drains, ditches, underground or confined spaces, water intakes and waterways. Spilled product may create a dangerous slipping hazard. Use appropriate tools to put the spilled solid in an appropriate disposal or recovery container. Reuse or recycle where possible. Special Procedures Contact local police/emergency services and appropriate emergency telephone numbers provided in Section 1. Ensure that statutory and regulatory reporting requirements in the applicable jurisdiction are met. Wear appropriate protective equipment and clothing during cleanup. Individuals without appropriate protective equipment should be excluded from area of spill until cleanup has been completed. See Section 8 for recommended Personal Protective Equipment and see Section 13 for waste disposal considerations. II Section 7 - Handling and Storage Handling Procedures Handle in contained and properly designed equipment systems. Use with adequate ventilation. Avoid ingestion and inhalation. Keep away from uncontrolled heat and incompatible materials. Ground all material handling and transfer equipment to dissipate buildup of static electricity. Keep handling areas free of loose pellets, powders and dust buildup. Every effort should be made to prevent the accumulation of powders or fine dusts around material handling systems. Accumulated powders or fine dusts may form explosive air-dust mixtures. For additional information on control of static and minimizing potential dust and fire hazards, refer to NFPA-654, "Standard for the Prevention of Fire and Dust Explosions from the Manufacturing, Processing, and Handling of Combustible Particulate Solids, 2013 Edition". Spilled product may create a dangerous slipping hazard. Storage Procedures Storage area should be clearly identified, well illuminated, clear of obstruction and accessible only to trained and authorized personnel. Store in closed, grounded and properly designed vessels, away from uncontrolled heat and incompatible materials. Outdoor storage of product in bags requires protection from ultra-violet sunlight by use of a UV stabilized bag or alternate means. Avoid accumulation of dust by frequent cleaning and suitable construction of storage and handling areas. Keep shovels and vacuum systems readily available for cleanup of loose material. DO NOT enter filled bulk containers and attempt to walk over product, due to risk of slipping and possible suffocation. Use a fall arrest system when working near open bulk containers. See Section 8 for appropriate Personal Protective Equipment, and see Section 10 for information on lncompatibilities. ll Section 8 - Exposure Controls Personal Protection Exposure Guidelines A: General Product Information Refer to published exposure limits - use effective control measures and PPE to maintain worker exposure to concentrations that are below these limits. Ensure that eyewash stations and safety showers are in close proximity to work locations. Note: In this product, any silica/talc content is inextricably bound or coated in the polyethylene. This would preclude an inhalation hazard. B: Component Exposure Limits ACGIH, OSHA, NIOSH, EPA, Alberta, and Ontario exposure limit lists have been checked for components listed with CAS registry numbers. Other exposure limits may apply, check with proper authorities. *Note: The Vacated OSHA Permissible Exposure Limits (PELs) are those provided in the 1989 update to OSHA's Air Contaminants Standard 29 CFR 1910.1000. These limits were vacated by the US. Court of Appeals, Eleventh Circuit but may be enforceable in some states. Page 3 of 9 Issue Date: July 8, 2013 Revision: 5.1 Print Date: 26~Aug~13 Material Safety Data Sheet Material Name: Polyethylene - Not Coloured (All Grades) ?"505 "31 NOVA-0029 Polyethylene (Ethene homopolymer) (9002-88-4) ACGIH: 10 mg/m3 TWA (inhalable particles, recommended); 3 mg/m3 TWA (respirable particles, recommended) (related to Particle (insoluble or poorly soluble) not otherwise specified OSHA (Vacated)*: 15 mg/m3 TWA (total dust); 5 mg/m3 TWA (respirable fraction) (related to Nuisance particulates) OSHA (Final): 15 mg/m3 TWA (total dust); 5 mg/m3 TWA (respirable fraction) (related to Nuisance particulates) Alberta: 10 mg/m3 MA (total); 3 mg/m3 TWA (respirable) (related to Particulate Not Otherwise Regulated) Ontario: 10 mg/m3 TWA (inhalable fraction); 3 mg/m3 TTNA (respirable fraction) (related to Particles (Insoluble or Poorly Soluble) Not Otherwise Specified Flux-calcined diatomaceous earth (68855-54-9) ACGIH: 0.025 mg/m3 TWA (respirable fraction) (related to Silica, cur?quartz) OSHA (Vacated)*: 0.1 mg/m3 TWA (respirable dust) (related to Quartz) NIOSH: 0.05 mg/m3 TTNA (respirable dust) (related to Silica, 50 mg/m3 IDLH (related to quartz) Alberta: 0.025 mg/m3 TWA (respirable particulate) (related to Silica Quartz? Ontario: 0.025 mg/m3 TWA (respirable fraction) (designated substances regulation) (related to Silica, d?Quartz) Mexico: 0.05 mg/m3 TWA (related to silica, cristobalite); 0.1 mg/m3 TWA (related to silica, quartz) Talc (Hydrated Magnesium Silicate) (14807-96-6) 2 mg/m3 TWA (particulate matter containing no asbestos and silica, respirable fraction) OSHA (Vacated)*: 2 mg/m3 TWA (less than 1% silica, containing no asbestos, respirable dust) OSHA (Final): 20 (million particles/cubic foot)TWA (less than 1% silica, containing no asbestos) NIOSH: 2 mg/m3 TWA (containing no asbestos and less than 1% quartz, respirable) 1000 mg/m3 IDLH Alberta: 2 mg/m3 TWA (respirable particulate containing no asbestos fibres) Ontario: 2 mg/m3 TTNA (containing no asbestos, respirable fraction, particulate matter containing no asbestos and 1% silica) 2 fibres/cc (should not exceed 2 mg/m3 respirable particulate mass) Mexico: 2 fibers/cm3 TWA ENGINEERING CONTROLS Engineering methods to reduce hazardous exposure are preferred controls. Methods include mechanical ventilation (dilution and local exhaust) process or personal enclosure, remote and automated operation, control of process conditions, leak detection and repair systems, and other process modifications. Ensure all exhaust ventilation systems are discharged to outdoors, away from air intakes and ignition sources. Supply sufficient replacement air to make up for air removed by exhaust systems. Administrative (procedure) controls and use of personal protective equipment may also be required. PERSONAL PROTECTIVE EQUIPMENT Personal Protective Equipment: Eyes/Face Wear safety glasses during normal handling. Wear full?face shield during thermal processing it contact with molten material is likely. Personal Protective Equipment: Wear thermal insulating gloves and other protective clothing (such as long sleeved shirts and long pants) whenever molten material is present. Safety footwear with good traction is recommended to help prevent slipping. Static Dissipative (SD) rated footwear is also recommended. Personal Protective Equipment: Respiratory If engineering controls and ventilation are not sufficient to prevent buildup of aerosols, vapours or dusts, appropriate NIOSH approved air?purifying respirators or self-contained breathing apparatus (SCBA) appropriate for exposure potential should be used. Air-supplied breathing apparatus must be used when oxygen concentrations are low or if airborne concentrations exceed the limits of the air?purifying respirators. Personal Protective Equipment: General Personal protective equipment (PPE) should not be considered a long?term solution to exposure control. Employer programs to properly select, fit, maintain, and train employees to use equipment must accompany PPE. Consult a competent industrial hygiene resource, the PPE manufacturer's recommendation, and/or applicable regulations to determine hazard potential and ensure adequate protection. Page 4 of 9 Issue Date: July 8, 2013 Revision: 5.1 Print Date: 26?Aug-13 Material Safety Data Sheet Material Name: Polyethylene Not Coloured (All Grades) ?"393 "31 NOVA-0029 II Section 9 - Physical Chemical Properties Physical State and Appearance: Solid, pellets, or granular Colour: Translucent to white powder Odour: Minimal, sweet pH: Not applicable Vapour Density at (Air=1): Not applicable Melting Point: Range: to to Specific Gravity (Water=1): Range: 0.905 to 0.965 OctanollH20 Coeff.: Not applicable Vapour Pressure: Not applicable Boiling Point: Not applicable Solubility (H20): Insoluble Evaporation Rate (n-Butyl Not applicable Acetate=1): Decomposition Temperature: Varies; Softening Point: Range: to to Flash Point: Not applicable Auto Ignition: Range: to to Flash Point Method: Not applicable Lower Flammable Limit (LFL): Not applicable Upper Flammable Limit (UFL): Not applicable Flammability Classification: Not flammable II Section 10 - Stability Reactivity Information Chemical Stability This product is stable under normal use conditions for shock, vibration, pressure, or temperature. Chemical Stability: Conditions to Avoid Avoid strong oxidizing agents. Avoid processing material over Incompatibility May react with strong oxidizing agents. Organic solvents, ether, gasoline, lubricating oils, chlorinated hydrocarbons and aromatic hydrocarbons may react with and degrade polyethylene. Powders or dusts may form an explosive mixture with air. Risk of dust-air explosion is increased if flammable vapours are also present. Possibility of Hazardous Reactions or Hazardous Polymerization Hazardous polymerization not likely to occur. Corrosivity Not corrosive to the common metals. Hazardous Decomposition Upon heating, polyethylene may emit various oligomers, waxes and oxygenated hydrocarbons as well as carbon dioxide, carbon monoxide and small amounts of other organic vapours (eg. aldehydes, acrolein). Inhalation of these decomposition products may be hazardous. Section 11 - Toxicological Information A: Acute Toxicity - General Product Information Material is considered essentially inert and non?toxic. Exposures to high levels of dust or heated fumes may cause irritation and possible pulmonary oedema. Contact with molten material may cause severe thermal burns. The following additional information has been found for its components: Flux-calcined diatomaceous silica I Talc (Hydrated Magnesium Silicate) - Inhalation may cause discomfort or irritation to the respiratory tract and nasal passages. May be irritating to eyes and skin. The silica/talc is inextricably bound or coated in the polyethylene; this would minimize the potential for skin irritation and preclude an inhalation hazard from the additive(s). B: Acute Toxicity - Polyethylene (Ethane homopolymer) (9002-88-4) or Polyethylene (1-Butene, polymer with ethene) (25087-34-7) or Polyethylene (1-Hexene, polymer with ethene) (25213-02-9) Oral LD50 Rat: 2 g/kg Flux-calcined diatomaceous earth (68855-54-9) Oral LD50 Rat: 500 mg/kg (related to Quartz) C: Chronic Toxicity - General Product Information Product has minimal chronic toxicity. Most polyethylene dust particles are large and non-respirable. There are no known or reported reproductive or genetic effects. The following additional information has been found for its components: Page 5 of 9 Issue Date: July 8, 2013 Revision: 5.1 Print Date: 26?Aug~13 Material Safety Data Sheet Material Name: Polyethylene - Not Coloured (All Grades) ?"505 '91 NOVA-0029 Flux-calcined diatomaceous earth/custalline silica - target organ is the lung and respiratory system. IARC has classified silica as a Group 1 (carcinogenic to humans). However, the silica is inextricably bound in the polyethylene; this would minimize the potential for skin irritation and preclude an inhalation hazard from the additive. Talc (Hydrated Maqnesium Silicate) Inhalation of dust causes respiratory irritation and difficulty breathing. Long?term inhalation may cause chronic lung disease or talc pneumoconiosis. The talc is inextricably bound or coated in the polyethylene; this would minimize the potential for skin irritation and preclude an inhalation hazard from the additive. D: Chronic Toxicity Carcinogenic Effects ACGIH, EPA, IARC, OSHA, and NTP carcinogen lists have been checked for those components with CAS registry numbers. Polyethylene (Ethene homopolymer) (9002-88-4) IARC: Supplement 7 [1987], Monograph 19 [1979] (Group 3 (not classifiable? Flux-calcined diatomaceous earth (68855-54-9) ACGIH: A2 Suspected Human Carcinogen (related to Quartz) IARC: Monograph 68 [1997'] (listed under silica inhaled in the form ofquartz or cristobalite from occupational sources) (related to Quartz) (Group 1 (carcinogenic to humans? NTP: Known Human Carcinogen (related to Quartz) Talc (Hydrated Magnesium Silicate) (14807-96-6) ACGIH: A4 - Not Classlfiable as a Human Carcinogen (containing no asbestos fibers) IARC: Monograph 93, Supplement 7 [1987], Monograph 42 [1987] (Group 3 (not classifiable? II Section 12 - Ecological Information Ecotoxicity A: General Product Information Polyethylene is an essentially biologically inert solid and considered non-toxic to the aquatic environment. It is stable (does not decompose) in landfills or in aquatic systems. B: Component Analysis Ecotoxicity - Aquatic/Terrestrial Toxicity Talc (Hydrated Magnesium Silicate) (14807-96-6) 96 Hr LC50 Brachydanio rerio: >100 g/L [semi-static] Environmental Fate/Mobility If released into watercourses, most polyethylene pellets float. Pellets are persistent in aquatic and terrestrial systems. Product should be recovered from water and land following spills. This product has not been found to migrate through soils. Persistence/Degradability Product does not readily degrade. Under optimal oxidation conditions, >99% of polyethylene will remain intact after exposure to microbial actions. Product will slowly change (embrittle) in the presence of sunlight, but will not fully breakdown. Product buried in landfill has been found to be stable over time. No toxic degradation products are known to be produced. BioaccumulationIAccumulation Pellets may accumulate in the digestive systems of birds and aquatic life, causing injury and possible death due to starvation. ll Section 13 - Disposal Considerations U.S./Canadian Waste Information A: General Product Information This product is not known to contain or generate hazardous wastes according to US and Canadian regulations. The use, mixing or processing of this product with other materials may alter its properties or hazards. Check federal, provincial/state and local environmental regulations prior to disposal. Preferred disposal methods for polyethylene in order of preference are: 1) clean and reuse if possible, 2) recover and resell through plastic recyclers or resin brokers, 3) incinerate with waste heat recovery and 4) landfill. Reuse, recycling, storing, transportation and disposal must be in accordance with applicable federal, provincial/state and local regulations. DO NOT ATTEMPT TO DISPOSE OF BY UNCONTROLLED INCINERATION. Open burning of plastics at landfills should not be undertaken. Page 6 of 9 Issue Date: July 8, 2013 Revision: 5.1 Print Date: 26?Aug-13 Material Safety Data Sheet Material Name: Polyethylene - Not Coloured (All Grades) ?"393 ?33 NOVA-0029 See Section 7: Handling and Storage and Section 8: Exposure Controls/Personal Protection for additional handling information that may be applicable for safe handling and the protection of employees. Waste generator is advised to carefully consider hazardous properties and control measures needed for other materials that may be found in the waste. B: Component Waste Numbers No EPA Waste Numbers are applicable for this product's components. Ii Section 14 - Transportation Information US DOT information Shipping Name: NOT REGULATED as a Hazardous Material for Transportation. Canadian TDG information Shipping Name: NOT REGULATED as Dangerous Goods for Transportation. international Air Transport Association (IATA) and International Civil Aviation Organization (ICAO) Information Shipping Name: NOT REGULATED as Dangerous Goods for Transportation. international Maritime Dangerous Goods Code Shipping Name: NOT REGULATED as Dangerous Goods for Transportation. Section 15 - Regulatory information A: international Regulations This product is not dangerous according to Mexican, Latin American and South American regulations. Component Analysis - international Inventory Status Component CAS US - TSCA CANADA - DSL Polyethylene (Ethene homopolymer) 9002-88-4 Yes Yes Flux-calcined diatomaceous earth 68855?54?9 Yes Yes Talc (Hydrated Magnesium Silicate) 14807~96~6 Yes Yes Polyethylene (1-Butene, polymer with ethane) 25087-34?7 Yes Yes Polyethylene (1-Hexene, polymer with ethene) 25213?02?9 Yes Yes This product complies with the registration requirements of the REACH Regulation (EC) No 1907/2006. The component substances have been duly preregistered, registered or are exempt from registration. This covers those EU importers included in NOVA Chemicals? Only Representative scheme. B: USA Federal State Regulations Ongoing occupational hygiene, medical surveillance programs, site emission or spill reporting may be required by Federal or State regulations. Check for applicable regulations. The EPA Storm Water Regulations classify resin pellets as "significant materials". Prevent pellets from entering drains, ditches or waterways. Site emission reporting may be required. Check applicable regulations. USA OSHA Hazard Communication Class According to 29 CFR 1910.1200 (Hazard Communication), polyethylene polymer product is not hazardous. USA Right-to-Know - Federal None of this product?s components are listed under SARA Section 302 (40 CFR 355 Appendix A), SARA Section 313 (40 CFR 372.65), or CERCLA (40 CFR 302.4). USA Rig ht-to-Know - State The following components appear on one or more of the following state hazardous substances lists. Some components (including those present only in trace quantities, and therefore not listed in this document) may be included on the Right-To?Know lists of other US. states. The reader is therefore cautioned to contact his or her NOVA Chemicals' representative or NOVA Chemicals' Product Integrity group for further US. State Right?To? Know information. Component CAS NJ PA Flux?calcined diatomaceous earth (1related to Silica, Quartz) 68855-549 Yes1 Yes: (Zrelated to Quartz) Talc (Hydrated Magnesium Silicate) 14807-966 Yes Yes C: Canadian Regulations - Federal and Provincial Canadian Environmental Protection Act (CEPA): All components of this product are on the Domestic Substances List (DSL) and are acceptable for use under the provisions of CEPA. Page 7 of 9 issue Date: July 8, 2013 Revision: 5.1 Print Date: 26-Aug-13 Material Safety Data Sheet Material Name: Polyethylene - Not Coloured (All Grades) M303 "31 NOVA-0029 Ingredient Disclosure List (IDL) The following components are identified under the Canadian Hazardous Products Act - Ingredient Disclosure List Component CAS Minimum Concentration Flux-calcined diatomaceous earth 68855-54-9 1 (related to Silica, amorphous, diatomaceous earth) WHMIS Classification Workplace Hazardous Materials Information System (WHMIS): This product has been classified in accordance with the hazard criteria of the CPR (Controlled Products Regulations) and the MSDS contains all the information required by the CPR. NOT CONTROLLED under WHMIS. Other Regulations Ongoing occupational hygiene, medical surveillance programs, site emission or spill reporting may be required by Federal or Provincial regulations. Check for applicable regulations. II Section 16 - Other information Label Information Product is a translucent to white, non-toxic solid pellet or granular powder having minimal odour. Dusts and heat- released air emissions may be irritating to the eyes, skin, and respiratory system. Accumulated fine dusts may form explosive air?dust mixtures. Spilled product may create a dangerous slipping hazard. Keep released pellets away from storm sewers and from entry into other aquatic systems. Under fire conditions, product will readily burn and emit irritating smoke. Contact with molten material may cause serious thermal burns. FIRST AID: SKIN: Remove dusty or contaminated clothing and shoes. Wash affected area with soap and water. Seek medical attention if develop or persist. In case of contact with molten product, cool rapidly with water and seek immediate medical attention. Do not attempt to remove molten product, or molten product that has cooled, from skin without medical assistance. EYES: Remove contact lenses, if it can be done safely. Immediately flush eyes with water for at least 15 minutes, while holding eyelids open. Seek medical attention if develop or persist. INHALATION: Move affected individual to non?contaminated air. Loosen tight clothing such as a collar, tie, belt or waistband to facilitate breathing. Seek immediate medical attention ifthe individual is not breathing, is unconscious or if any other persist. Inhalation of smoke following a ?re may result in delayed pulmonary oedema; seek immediate medical attention. INGESTION: Material is not expected to be absorbed from the gastrointestinal tract. DO NOT INDUCE VOMITING. Loosen tight clothing such as a collar, tie, belt or waistband. Seek immediate medical attention. IN CASE OF A SPILL: Stop leak, isolate and contain spill. Prevent entry into sewers, drains, ditches, underground or con?ned spaces, water intakes and watenNays. Spilled product may create a slipping hazard. Use appropriate tools to put the spilled solid in an appropriate disposal or recovery container. Reuse or recycle where possible. References Available on request. Special Considerations Exposure to the Hazardous Combustion and Decomposition Products as described in the MSDS, Sections 5 and 10 may be linked with various acute and chronic health effects. These effects include irritation of eyes and upper respiratory tract primarily from the aldehydes; breathing difficulties, systemic toxicity such as liver, kidney, and central nervous system effects. NOVA Chemicals has monitored worker exposures to emissions during commercial?scale processing of polyethylene. Concentrations of hazardous decomposition products were determined to be well below established exposure limits in the workplace. "Quantitation of Employee Exposure to Emission Products Generated By Commercial-Scale Processing of Polyethylene" is available in the Am. Ind. Hyg. Assoc. J. 56:809-814 (1995) and ?Quantification of Emission Compounds Generated During Commercial?Scale Processing of Advanced SCLAIRTECHTM Polyethylene? is available in the Journal of Plastic Film Sheeting Volume 26 Issue 2, April 2010. For information on ventilation considerations for the control of volatile air contaminants from polyethylene, please request a c0py of NOVA Chemicals? publication, ?Ventilation Guidelines for Heat-?Processing Polyethylene Resins?. For additional information on unloading hopper cars containing plastic resins, refer to NOVA Chemicals' publication, ?Hopper Car Unloading Guide?. Page 8 of 9 Issue Date: July 8, 2013 Revision: 5.1 Print Date: 26?Aug~13 Material Safety Data Sheet Material Name: Polyethylene - Not Coloured (All Grades) M303 For information on processing properties, selection of NOVAPOL resin grades, refer to the NOVAPOL Product Data Sheets available on our web site, under Products at Applications: For additional information on preventing pellet loss, refer to published plastic industry publications and resources under 'Operation Clean Sweep'; now downloadable from the web at Polyethylene fines and dust particles are listed as a Class I combustible dust by the National Fire Protection Association (see NFPA-SS, Table F.t For additional information on control of static and minimizing potential dust and fire hazards, refer to NFPA-654, "Standard for the Prevention of Fire and Dust Explosions from the Manufacturing, Processing and Handling of Combustible Particulate Solids, 2013 Edition". For NOVAPOL resin grade specific information including food contact compliance statements, please contact your sales representative or refer to NOVA Chemicals' polyethylene Product Data Sheets. KeylLegend ACGIH American Conference of Governmental Industrial Hygienists; ADR Transport of Dangerous Goods by Road: ADRTRID European Agreement of Dangerous Goods by Roaleail: BOD Biochemical Oxygen Demand; CAS Chemical Abstracts Service; CEPA Canadian Environmental Protection Act; CERCLA Comprehensive Environmental Response. Compensation. and Liability Act; CFR Code of Federal REQUIBIIOHS: CPR Cantrelled Products Regulations; DFG Deutsche Forschungsgemeinschaft; DOT Department of Transportation; DSL Domestic Substances List; EC50 Effective Concentration 50%; EEC European Economic Community; EINECS European Inventory of Existing Commercial Chemical Substances: ELINCS European List of Notified Chemical Substances; EPA Environmental Protection Agency: EU European Union; FDA Food and Drug Administration; GHS Globally Harmonized System for the Classification and Labelling of Chemicals; HCS Hazard Communication Standard: HMIS Hazardous Materials Identification System; IARC international AgenCy for Research on Cancer; IATA International Air Transport Association; ICAO international Civil Aviation Organization; IDL Ingredient Disclosure List; IDLI-I Immediater Dangerous to Life or Health; International Maritime Dangerous Goods: IMO International Maritime Organization; ISHL industrial Safety and Health Law; New Octanolrwater partition coef?cient; LC50 a Lethal Concentration 50%; L050 Lethal Dose 50%; LEL Lower Explosive Limit; LFL Lower Flammable Limit; LLV Level Limit Ceiling Limit (Sweden dust); MAK Maximum Concentration Value in the Workplace; MiTi Ministry of international Trade and industry; MSDS Material Safety Data Sheet: NAB Threshold Values (lndonesia): NCEC National Chemical Emergency Centre; NDSL Non-Domestic Substances List; NFPA National Fire Protection Association; NIOSH National Institute for Occupational Safety and Health; New Jersey Trade Secret Registry; NTP National Toxicology Program; OEL Occupational Exposure Limit; OSHA Occupational Safety and Health Administration; PEL I Permissible Exposure Limit; PNOC Particulaies Not Otherwise Classi?ed; PPE Personal Protective Equipment; PRTR Designated Chemical Substance Law (Japan): PSD Short Term Exposure Limit (Indonesia); RCRA Resource Conservation and Recovery Act: REACH Registration. Evaluation. Authorisation and Restriction of Chemical Substances; REL Recommended Exposure Limit; RID Transport of Dangerous Goods by Rail; SARA Superfund Amendments and Reauthcrization Act; SCBA Self Contained Breathing Apparatus; SDS Safety Data Sheet; SEPA State Environmental Protection Administration; STEL Short Term Exposure Limit; TDG Transportation 01? Dangerous (30005; TLV Threshold Limit Value; TSCA Toxic Substances Control Act: TWA Time Weighted Average; UEL Upper Explosive Limit; UFL Upper Flammable Limit; VLA-ED Valor Iimite Ambiental de Exposicidn Diaria (Environmental Exposure Daily Limit Value): VME valeur Iimite d'exposition (Occupational Exposure Limits); WHMIS Workplace Hazardous Materials Information Systems MSDS Prepared by: NOVA Chemicals MSDS Information Phone Number: 1?412?490-4063 Other Information Notice to Reader: ALTHOUGH THE INFORMATION CONTAINED IN THIS DOCUMENT IS PRESENTED IN GOOD FAITH, BASED ON AVAILABLE INFORMATION BELIEVED TO BE RELIABLE AT THE TIME OF PREPARATION OF THIS DOCUMENT, NOVA CHEMICALS MAKES NO WARRANTIES OR REPRESENTATIONS WITH RESPECT TO THE INFORMATION OR THE PRODUCTIMATERIALS DESCRIBED HEREIN, AND EXPRESSLY DISCLAIMS ALL IMPLIED WARRANTIES AND CONDITIONS (INCLUDING ALL WARRANTIES AND CONDITIONS OF MERCHANTABILITY OR FITNESS FOR A PARTICULAR PURPOSE). NO FREEDOM FROM INFRINGEMENT OF ANY PATENT OWNED BY NOVA CHEMICALS OR OTHERS IS TO BE INFERRED. THIS INFORMATION IS SUBJECT TO CHANGE WITHOUT NOTICE. PLEASE CONTACT NOVA CHEMICALS FOR THE MOST CURRENT VERSION OF THIS MSDS. NOVA CHEMICALS DOES NOT ASSUME RESPONSIBILITY FOR MSDS OBTAINED FROM THIRD PARTY SOURCES. UNLESS SPECIFICALLY AGREED OTHERWISE, NOVA CHEMICALS DOES NOT TAKE RESPONSIBILITY FOR USE, TRANSPORTATION, STORAGE, HANDLING OR DISPOSAL OF THE PRODUCTIMATERIALS DESCRIBED HEREIN. - A Is a registered trademark of NOVA Brands Ltd; authorized use! utilisation autorisee. is a registered trademark of NOVA Brands Ltd.; authorized useiutiliaation autoriacc. SCLAIRTECHTM Is a trademark of NOVA Chemicals. This is the end of MSDS Page 9 of 9 lacue Date: July 8, 2013 Revision: 5.1 Print Date: 26-Aug-13