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RoHS The EU Directive 2002/95/EC "Restriction on the Use of Certain Hazardous Substances" (RoHS) requires all Member States (per Article 4(1) of the Directive) to ensure that materials and components of electrical and electronic equipment put on the market after July 1, 2006 do not contain the following specific hazardous substances: lead, mercury, cadmium, hexavalent chromium, polybrominated biphenyls (PBBs) or polybrominated diphenyl ethers (PBDEs) at levels greater than the tolerated maximum concentration values established by the EU Commission Decision 2005/618/EC. The value for lead, mercury, hexavalent chromium, PBBs and PBDEs is 0.1% or 1000 ppm and the value for cadmium is 0.01% or 100 ppm. This directive impacts coated electrical parts and products exported to Europe, though similar rules are being developed in other areas of the world. The PPG Refinish website offers a list of"PPG Products Containing Restricted Metals" which indicates which PPG Refinish products contain intentionally added lead, hexavalent chromium, cadmium and/or selenium - coatings regulated under RoHS. Alternative products that do not contain these substances are listed and available through your PPG jobber. TCLP Waste Characterization Facilities that use refinish coatings will generate waste streams that must be managed and disposed of following all federal, state and local regulations. Waste streams, including used booth filters, must be handled properly. Regulations typically require that these waste streams be characterized prior to disposal. If a waste stream is known to contain leachable/soluble heavy metal pigments/additives (e.g. lead, hexavalent chromium, cadmium, barium, selenium and mercury), specific methods of disposal are required. The composition of these waste streams would likely be classified as a hazardous waste due to the characteristic of toxicity, using the Toxicity Characteristic Leaching Procedure (TCLP), test Method 1311 (40CFR 260.11). Some waste streams are specifically identified as a hazardous waste ("listed" hazardous wastes). Reference, however, should be made to the Resource Conservation and Recovery Act regulations located at 40 CFR 260, to determine whether a waste stream should be managed as a hazardous waste. The generator of the waste stream is responsible for characterizing the waste and determining whether the waste generated must be managed as a hazardous waste. It is also possible that waste disposal for specific content may be restricted or even banned for certain processes. The PPG Refinish website offers a list of"PPG Products Containing Restricted Metals"which indicates which PPG Refinish products contain intentionally added lead, hexavalent chromium, cadmium and selenium. Coatings processes that utilize these products may generate waste streams where there is a potential concern. If the generator wishes to reduce the characteristic toxicity there are alternative products available that do not contain the heavy metals of concern. HMRules.doc Page 3 of 4