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AICL <br /> \Performance Where needs take us <br /> Products <br /> April 29, 2015 <br /> Mrs. Sandra Eskridge McHargue <br /> Safety Manager, Hunot Retardant Company <br /> P.O. Box 478 <br /> Goleta, CA 93116 <br /> Dear Mrs. McHargue, <br /> Thank you for asking for the reason for the change in the language used to describe the Disposal <br /> Considerations on the MSDS for the product named Phos-Chek,LC95A. The MSDS for this product dated <br /> January 28, 2013 states: "This product when discarded is a hazardous waste due to one or more <br /> hazardous characteristics (D004, D006, D007) as the term is defined by the Resource,Conservation and <br /> Recovery Act(RCRA),40 CFR 261. Certain recycling activities may qualify for an exemption from RCRA. <br /> Consult your attorney or appropriate regulatory official for information on disposal and on the recycling <br /> exemption. Recycle or dispose of in accordance with local, state, provincial, and federal regulations". <br /> The updated language used to describe the Disposal Considerations on the MSDS for this product dated <br /> July 18, 2014 states: "Consult your attorney or appropriate regulatory official for information on disposal <br /> and on the recycling exemption. Recycle or dispose of in accordance with local, state, provincial, and <br /> federal regulations". <br /> According to 22 CCR 66262.11 Hazardous Waste Determination paragraph (a) "A person who generates <br /> a waste,as defined in section 66261.2, shall determine if that waste is a hazardous waste using ...". <br /> ICL's management decided that the statement as it was written in the Disposal Considerations section of <br /> the MSDS dated January 28, 2013 may not be consistent with the requirements of 22 CCR 66262.11 <br /> which requires the generator of the waste to make the determination and not the manufacturer of the <br /> product. ICL's management decided that the statement under the Disposal Considerations section on <br /> the updated version of the MSDS dated July 18, 2014 provides better environmental guidance for the <br /> customer and consumer of this product. <br /> We hope that this information answers your questions regarding our product MSDS. If you require <br /> further information or have any questions, please do not hesitate to contact us at(909) 983-0772. <br /> Thank you so much for your question and for using our fire retardant product. <br /> Respectfully, <br /> Alfredo Aviles <br /> ESH Manager <br /> ICL <br /> 10667 Jersey Blvd. <br /> Rancho Cucamonga, CA 91730 USA <br />