Update SAFETY HEALTH. June 1 Deadline to Implement New Changes to OSHA s Hazard Communication Standard

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1 SAFETY HEALTH ENVIRONMENTAL SERVI C E S Grain and Feed Association of Illinois Update The latest environmental and safety information for the grain and feed industry May 12, 2015 Vol. 27 No. 3 Visit to view their HCS guidance document Upcoming Events June 9, 10 Arc Flash Seminar Agricenter, Bloomington June 16, 17 Safe Grain Handling Training Agricenter, Bloomington, IL July 7, 8 Safe Grain Handling Training Agricenter, Bloomington, IL July 21, 22 Safe Grain Handling Training Agricenter, Bloomington, IL June 1 Deadline to Implement New Changes to OSHA s Hazard Communication Standard On March 2012, Occupational Safety and Health Administration s (OSHA) Hazard Communication Standard (HCS) are bringing the United States into alignment with the Globally Harmonized System of Classification and Labeling of Chemicals (GHS). The Hazard Communication Standard in 1983 gave the workers the right to know, but the new Globally Harmonized System gives workers the right to understand. The basic idea of the hazard communication standard has not changed. HCS requires chemical manufacturers and importers to evaluate the chemicals they produce or import and provide hazard information to employers and workers by putting labels on containers and preparing Safety Data Sheets (SDS), formerly known as MSDS. The modified standard provides a single set of harmonized criteria for classifying chemicals according to their health and physical hazards and specifies hazard communication elements for labeling and safety data sheets. How does this impact the membership? Grain handling facilities are now considered manufacturers of a hazardous chemical. The hazardous chemical is grain dust. So for grain, feed and processing industries that ship to downstream customers you will need to provide a Safety Data Sheet. This requirement begins June 1, See the chart on the following page for other important dates. John Lee Kris Richardson p: f: Grain and Feed Association of Illinois, 3521 Hollis Drive, Springfield, IL 62711

2 An Update of GFAI s Safety Health Environmental Services Program Effective Completion Date Requirement(s) Who December 1, 2013 Train employees on the new label elements and SDS format. Employers June 1, 2015 Comply with all modified provisions of this final rule, except distributor extension Chemical manufacturers, importers, distributors and employers December 1, 2015 Distributors may ship products labeled by manufacturers under the old system until December 1, June 1, 2016 Update alternative workplace labeling and hazard communication program as necessary, and provide additional employee training for newly identified physical or health hazards. Employers Transition Period Comply with either 29 CFR (this final standard), or the current standard, or both. All chemical manufacturers, importers, distributors and employers The NGFA has put out a very good guidance document titled Guidance: Hazard Communication Program at Grain Handling, Feed, Ingredient & Processing Facilities. On page 34 they have included a sample SDS for grain. Also they have included a FAQ section on pages which will be very helpful to understand your requirements. Click here to access the guidance document. Which is Distributed with the permission of the National Grain and Feed Association, the American Feed Industry Association, the Corn Refiners Association and the North American Millers Association. (The document Guidance: Hazard Communication Program at Grain Handling, Feed, Ingredient & Processing Facilities was originally published in May 2015 ). Major changes to the Hazard Communication Standard: Hazard classification: Chemical manufacturers and importers are required to determine the hazards of the chemicals. Hazard classification under the new, updated standard provides specific criteria to address health and physical hazards as well as classification of chemical mixtures. Labels: Chemical manufacturers and importers must provide labels that include signal words, pictograms, hazard statements, and precautionary statements for each hazard class and category. Safety Data Sheets: The new format requires 16 specific sections. Information and training: To facilitate understanding of the new system, the new standard requires that workers be trained by December 1, 2013 on the new label elements and safety data sheet format, in addition to the current training requirements. The new system is being implemented throughout the world. Countries include Canada, EU, Japan, China and Japan. The new components will bring a uniform format to the SDS as the MSDS could be written in any order the company wanted. Below is the new required format. Hazard Communication Safety Data Sheets The Hazard Communication Standard (HCS) requires chemical manufacturers, distributors, or importers to provide Safety Data Sheets (SDSs) (formerly known as Material Safety Data Sheets or MSDSs) to communicate the hazards of hazardous chemical products. As of June 1, 2015, the HCS will require new SDSs to be in a uniform Grain and Feed Association of Illinois, 3521 Hollis Drive, Springfield, IL 62711

3 An Update of GFAI s Safety Health Environmental Services Program format, and include the section numbers, the headings, and associated information under the headings below: Section 1, Identification includes product identifier; manufacturer or distributor name, address, phone number; emergency phone number; recommended use; restrictions on use. Section 2, Hazard(s) identification includes all hazards regarding the chemical; required label elements. Section 3, Composition/information on ingredients includes information on chemical ingredients; trade secret claims. Section 4, First-aid measures includes important symptoms/ effects, acute, delayed; required treatment. Section 5, Fire-fighting measures lists suitable extinguishing techniques, equipment; chemical hazards from fire. Section 6, Accidental release measures lists emergency procedures; protective equipment; proper methods of containment and cleanup. Section 7, Handling and storage lists precautions for safe handling and storage, including incompatibilities. Section 8, Exposure controls/personal protection lists OSHA s Permissible Exposure Limits (PELs); Threshold Limit Values (TLVs); appropriate engineering controls; personal protective equipment (PPE). Section 9, Physical and chemical properties lists the chemical s characteristics. Section 10, Stability and reactivity lists chemical stability and possibility of hazardous reactions. Section 11, Toxicological information includes routes of exposure; related symptoms, acute and chronic effects; numerical measures of toxicity. Section 12, Ecological information* Section 13, Disposal considerations* Section 14, Transport information* Section 15, Regulatory information* Section 16, Other information, includes the date of preparation or last revision. *Note: Since other Agencies regulate this information, OSHA will not be enforcing Sections 12 through 15(29 CFR (g)(2)). Employers must ensure that SDSs are readily accessible to employees. See Appendix D of for a detailed description of SDS contents. Hazard Communication Standard Labels & Pictograms OSHA has updated the requirements for labeling of hazardous chemicals under its Hazard Communication Standard (HCS). As of June 1, 2015, all labels will be required to have pictograms, a signal word, hazard and precautionary statements, the product identifier, and supplier identification chemical hazard classification. Grain and Feed Association of Illinois, 3521 Hollis Drive, Springfield, IL 62711

4 An Update of GFAI s Safety Health Environmental Services Program Danger and Warning. These signal words are used to communicate the level of hazard on both the label and the SDS. The appropriate signal word to use is set by the classification system. For example, the signal word for Self-heating substances and mixtures, Category 1, is Danger while Warning is used for the less serious Category 2. There are categories where no signal word is used. Differences Between Labels and SDS Labels have always been a required under the HCS, but chemicals are exempt if they are subject to the labeling requirements of the Federal Food, Drug and Cosmetic Act (FFDCA). So grain, feed and ingredients that are subject to FDA labeling requirements are still exempt from the label requirements. Below is sample label. To summarize, grain handling and feed facilities are now considered manufacturers of a hazardous chemical. The hazardous chemical that you manufacture is grain dust. So grain, feed and processing industries will need to provide a Safety Data Sheet (SDS) to downstream customers. This requirement begins June 1, A Hazard Communication Standard Label will not be required if the products are subject to the labeling requirements of the Federal Food, Drug and Cosmetic Act (FFDCA). Grain and Feed Association of Illinois, 3521 Hollis Drive, Springfield, IL 62711

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6 Safety Data Sheet for Feed SECTION 1: IDENTIFICATION PRODUCT NAME: SDS NUMBER: FEEDS FEED SYNONYMS/OTHER MEANS OF IDENTIFICATION: INTENDED USE: FEED AND OTHER MANUFACTURER: (company name) EMERGENCY HEALTH AND SAFETY NUMBER: PHONE: SDS INFORMATION: URL: SDS DATE OF PREPARATION: SECTION 2: HAZARD(S) IDENTIFICATION CLASSIFICATION: ORGANIC DUST LABEL ELEMENTS: N/A DUE TO FDA LABELING EXEMPTION SIGNAL WORD: N/A DUE TO FDA LABELING EXEMPTION HAZARD STATEMENT(S): CLASS 2B EYE IRRITANT. MAY CAUSE BREATHING DIFFICULTIES IF INHALED. MAY CREATE A FLASH FIRE OR EXPLOSION HAZARD IF DUST OF CERTAIN PARTICLE SIZE IS SUSPENDED IN AIR AT SUFFICIENT CONCENTRATION IN A CONFINED SPACE AND EXPOSED TO AN IGNITION SOURCE. PRECAUTIONARY STATEMENT(S): MAY BE A MECHANICAL EYE IRRITANT. RINSE EYES WITH WATER FOR SEVERAL MINUTES. AVOID BREATHING DUST. EXCESSIVE INHALATION MAY AFFECT NOSE, THROAT AND LUNGS. FEED DUST MAY BURN IF SUSPENDED IN AIR AND MAY CREATE A FLASH FIRE/EXPLOSION HAZARD. AVOID IGNITION SOURCES. EMERGENCY OVERVIEW: MAY BE MECHANICAL IRRITANT TO EYES. EXCESSIVE INHALATION OF GRAIN DUSTS MAY AFFECT NOSE THROAT, AND LUNGS. MAY FORM COMBUSTIBLE DUST CONCENTRATION IN AIR; SEE EXPLOSION HAZARD BELOW. EXPLOSION HAZARD: FEED IS GENERALLY CONSIDERED NOT HAZARDOUS, BUT DUST GENERATED THROUGH DOWNSTREAM ACTIVITIES THAT MAY REDUCE ITS PARTICLE SIZE (E.G., SHIPPING, HANDLING, TRANSFER TO BINS, ETC.) MAY CREATE A HAZARDOUS CONDITION. IF EXPOSED TO AN IGNITION SOURCE, FEED DUST MAY BURN. AIRBORNE DUST IN SUFFICIENT CONCENTRATIONS WHEN EXPOSED TO AN IGNITION SOURCE MAY FLASH OR, IN A CONFINED SITUATION, MAY FUEL AN EXPLOSION. SECTION 3: COMPOSITION/INFORMATION ON INGREDIENTS COMPONENT DUST FROM PREPARED ANIMAL FEEDS (GRAINS, PLANT AND/OR ANIMAL PROTEINS, VITAMINS AND MINERALS) CASRN CONCENTRATION 100%

7 SECTION 4: FIRST AID MEASURES INHALATION: REMOVE PERSON FROM EXPOSURE. SEEK MEDICAL ATTENTION FOR ANY BREATHING DIFFICULTY. INGESTION: IF SWALLOWED, GIVE SEVERAL GLASSES OF WATER TO DILUTE. NEVER GIVE ANYTHING BY MOUTH TO AN UNCONSCIOUS PERSON. SKIN CONTACT: WASH AFFECTED SKIN WITH SOAP AND WATER. EYE CONTACT: FLUSH EYES WITH WATER. SEEK MEDICAL ATTENTION AS NEEDED. SECTION 5: FIREFIGHTING MEASURES HAZARDOUS COMBUSTION PRODUCTS: OXIDES OF CARBON SPECIAL FIREFIGHTING PROCEDURES: EXTINGUISH WITH WATER FOG, DRY CHEMICAL POWDERS OR FOAM. DO NOT USE STRONG STREAMS OF WATER OR DRY CHEMICAL IF DUST CAN BE DISPERSED INTO THE AIR. DUST PLACED IN SUSPENSION WITH AN IGNITION SOURCE PRESENT MAY FLASH OR EXPLODE. UNUSUAL FIRE AND EXPLOSION HAZARDS: EXPLOSION HAZARD MAY EXIST FOR COMBUSTIBLE DUSTS OF CERTAIN PARTICLE SIZE AND MOISTURE CONTENT WHEN SUSPENDED IN AIR AT CERTAIN CONCENTRATIONS AND SUBJECTED TO AN IGNITION SOURCE. SECTION 6: ACCIDENTAL RELEASE MEASURES CLEAN UP WITH SOFT BRISTLE BROOM(S) OR A VACUUM APPROVED FOR A CLASS II HAZARDOUS LOCATION. DUST DEPOSITS SHOULD BE MAINTAINED TO A MINIMUM ON SURFACES, AS THESE COULD FORM AN EXPLOSIVE MIXTURE IF THEY ARE RELEASED INTO THE ATMOSPHERE IN SUFFICIENT CONCENTRATION. AVOID DISPERSAL OF DUST IN THE AIR (I.E. CLEANING DUST SURFACES WITH COMPRESSED AIR IN THE PRESENCE OF IGNITION SOURCE SHOULD NOT BE ALLOWED.) NON-SPARKING TOOLS SHOULD BE USED. SECTION7: HANDLING AND STORAGE AVOID DISPENSING DUST IN AIR AND EXPOSURE TO POTENTIAL IGNITION SOURCES. REMOVE FEED DUST FROM AREA/PROCESSING EQUIPMENT PRIOR TO USING ANY HEAT PRODUCING EQUIPMENT SUCH AS ARC WELDERS, CUTTING TORCHES AND SPARK/HEAT PRODUCING TOOLS SUCH AS PORTABLE SURFACE GRINDERS. SECTION 8: EXPOSURE CONTROLS/PERSONAL PROTECTION RESPIRATORY PROTECTION: MAY CAUSE IRRITATION OF THE NASAL MEMBRANES OR THE UPPER RESPIRATORY TRACT IF DUST EXCEEDS THE NUISANCE LEVEL. WEAR AN APPROVED NIOSH DUST RESPIRATOR WHENEVER DUST CONCENTRATIONS IN THE WORK AREA ARE ABOVE ACGIH TLV/OSHA PELS. VENTILATION: LOCAL EXHAUST: IF NEEDED MECHANICAL (GENERAL): IF NEEDED ENSURE THAT DUST HANDLING SYSTEMS (SUCH AS EXHAUST DUCTS, DUST COLLECTORS, VESSELS, AND PROCESSING EQUIPMENT) ARE DESIGNED IN A MANNER TO PREVENT THE ESCAPE OF DUST INTO THE WORK AREAS. USE ONLY APPROPRIATELY CLASSIFIED ELECTRICAL EQUIPMENT AND POWERED INDUSTRIAL TRUCKS. PROTECTIVE GLOVES: N/A Safety Data Sheet for Feed - Page 2 of 4

8 EYE PROTECTION: SAFETY GLASSES / GOGGLES SUGGESTED IN DUSTY CONDITIONS WORK/ HYGIENIC PRACTICES: GOOD PERSONAL HYGIENE PRACTICES SHOULD BE FOLLOWED. WASH HANDS AND FACE BEFORE EATING, DRINKING, ETC. AVOID DUST ACCUMULATION AND CONTROL IGNITION SOURCES. WHERE APPROPRIATE, EMPLOY GROUNDING, VENTING, AND EXPLOSION RELIEF PROVISIONS IN ACCORDANCE WITH ACCEPTED ENGINEERING PRACTICES IN PROCESSES CAPABLE OF GENERATING DUST AND/OR STATIC ELECTRICITY. AVOID ACCUMULATION OF DUST ON SURFACES TO PREVENT SECONDARY DUST EXPLOSIONS. REFER TO APPROPRIATE OSHA, NFPA AND APPLICABLE STANDARDS. SECTION 9: PHYSICAL AND CHEMICAL PROPERTIES FLASH POINT (METHOD): N/A FLAMMABLE LIMITS: LEL: VARIABLE UEL: UNKNOWN AUTOIGNITION TEMPERATURE: UNKNOWN APPEARANCE: TAN TO DARK BROWN IN APPEARANCE WITH PERHAPS A SWEET ODOR SOLID CONTENTS: 100% SECTION 10: STABILITY AND REACTIVITY STABILITY: UNSTABLE: CONDITION TO AVOID: N/A STABLE: X INCOMPATIBILITY (MATERIALS TO AVOID): NONE KNOWN HAZARDOUS DECOMPOSITION OR BYPRODUCTS: NONE KNOWN HAZARDOUS POLYMERIZATION: MAY OCCUR: CONDITION TO AVOID: N/A WILL NOT OCCUR: X SECTION 11: TOXICOLOGICAL INFORMATION ROUTES OF ENTRY: INHALATION: X SKIN: X EYES: X INGESTION: UNLIKELY CARCINOGENICITY: NTP: NO ARC MONOGRAPHS: NO OSHA REGULATED: NO ACUTE: MAY BE MECHANICAL IRRITANT TO SKIN AND EYES. EXCESSIVE INHALATION OF FEED DUSTS MAY AFFECT THE NOSE, THROAT, AND LUNGS. CHRONIC: REPEATED AND PROLONGED INHALATION OF FEED DUSTS MAY AFFECT THE RESPIRATORY SYSTEM. SMOKERS HAVE AN INCREASED RISK OF REPIRATORY EFFECTS. SIGNS AND SYMPTOMS OF EXPOSURE: IRRITATION TO THE SKIN, EYES, NOSE OR THROAT MAY OCCUR. SOME PEOPLE MAY OCCASIONALLY EXPERIENCE COUGHING. MEDICAL CONDITIONS GENERALLY AGGRAVATED BY EXPOSURE: ALLERGIES AND RESPIRATORY AILMENTS. SECTION 12: ECOLOGICAL INFORMATION: (NON-MANDATORY) SECTION 13: DISPOSAL CONSIDERATIONS: (NON-MANDATORY) SECTION 14: TRANSPORT INFORMATION: (NON-MANDATORY) Safety Data Sheet for Feed - Page 3 of 4

9 SECTION 15: REGULATORY INFORMATION: (NON-MANDATORY) SECTION (B)(5)(III) OF THE HCS (CFR ) EXEMPTS FOOD, INCLUDING FEED AND THEREFORE ANY ASSOCIATED FEED DUST, FROM THE LABELING REQUIREMENTS OF THE HCS SINCE THE FOOD/FEED IS SUBJECT TO THE LABELING REQUIREMENTS OF THE FOOD & DRUG ADMINISTRATION. SECTION 16: OTHER INFORMATION ANIMAL FEED IS COMPRISED OF WHOLE AND PROCESSED GRAINS AND MAY CONTAIN ADDED VITAMINS AND MINERALS. FEED COMPONENTS GENERALLY PRODUCE A LIMITED AMOUNT OF DUST IN MANUFACTURING AND HANDLING OF THE MATERIAL. THIS SDS IS GENERIC AND MAY NOT APPLY TO ALL FEED FORMULATIONS. FOR EXAMPLE, FEED WITH CERTAIN ADDED MEDICATIONS PREMIXES, VITAMIN AND MINERAL SUPPLEMENTS MAY CONTAIN INGREDIENTS THAT RESULT IN DIFFERENT OR ADDITIONAL HAZARDS, MAY REQUIRE ADDITIONAL ACCIDENTAL RELEASE MEASURES, MAY HAVE DIFFERING TOXICOLOGICAL EXPOSURES AND/OR MAY REQUIRE ADDITIONAL EXPOSURE CONTROLS AND PERSONAL PROTECTION. THE MANUFACTURER IS ENCOURAGED TO EVALUATE EACH FEED FORMULATION TO DETERMINE IF THIS GENERIC SDS IS APPROPRIATE. THIS GENERIC SDS IS NOT INTENDED TO SUGGEST THAT A SDS IS REQUIRED FOR ALL FEED DUST IN ALL CIRCUMSTANCES. THE MANUFACTURER OR IMPORTER SHOULD MAKE ITS OWN INTERPRETATION OF OSHA'S HCS, INCLUDING THE EXEMPTIONS IN THE STANDARD, FOR ITS SPECIFIC PRODUCT. SOME MANUFACTURERS OR IMPORTERS MAY ALSO PRODUCE A SDS FOR FEED DUST EVEN IF SUCH A SDS IS NOT REQUIRED BY OSHA'S HCS. THIS GENERIC SDS MAY BE USEFUL FOR THOSE MANUFACTURERS OR IMPORTERS. IN ACCORDANCE WITH OSHA'S HAZARD COMMUNICATION STANDARD (HCS) ALL MATERIALS: 1) WHICH CONSTITUTE 1% OR MORE OF THIS PRODUCT AND MEET THE STANDARD'S DEFINITION OF HAZARDOUS MATERIALS, 2) THAT CONSTITUTE 0.1% OR MORE AND MEET THE STANDARD'S DEFINITION OF CARCINOGENS, AND OR 3) THAT COULD BE RELEASED FROM THE PRODUCT IN EXCESS OF ESTABLISHED LIMITS SHOULD BE LISTED AND MAY REQUIRE A SPECIFIC SDS. Safety Data Sheet for Feed - Page 4 of 4

10 SECTION 1: IDENTIFICATION Safety Data Sheet for Whole Grain PRODUCT NAME: SDS NUMBER: WHOLE GRAIN GRAIN SYNONYMS/OTHER MEANS OF IDENTIFICATION: INTENDED USE: FOOD MANUFACTURER: (company name) EMERGENCY HEALTH AND SAFETY NUMBER: PHONE: SDS INFORMATION: URL: SDS DATE OF PREPARATION: SECTION 2: HAZARD(S) IDENTIFICATION CLASSIFICATION: COMBUSTIBLE DUST/RESPIRATORY HAZARD IF SMALL PARTICLES ARE GENERATED DURING FURTHER PROCESSING, HANDLING OR BY OTHER MEANS. LABEL ELEMENTS: SIGNAL WORD: WARNING HAZARD STATEMENT(S): CLASS 2B EYE IRRITANT. MAY CAUSE BREATHING DIFFICULTIES IF INHALED. IF SMALL PARTICLES ARE GENERATED DURING FURTHER PROCESSING, HANDLING OR BY OTHER MEANS, MAY FORM COMBUSTIBLE DUST CONCENTRATIONS IN AIR. PRECAUTIONARY STATEMENT(S): DUST FROM PARTICULATES MAY BE A MECHANICAL EYE IRRITANT. RINSE EYES WITH WATER FOR SEVERAL MINUTES. AVOID BREATHING DUST. EXCESSIVE INHALATION MAY AFFECT NOSE, THROAT AND LUNGS. AVOID IGNITION SOURCES: GRAIN DUST MAY BURN IF SUSPENDED IN AIR AND MAY CREATE A FLASH FIRE/EXPLOSION HAZARD. EMERGENCY OVERVIEW: DUST FROM PARTICULATES MAY BE MECHANICAL IRRITANT TO EYES. EXCESSIVE INHALATION OF GRAIN DUSTS MAY AFFECT NOSE THROAT, AND LUNGS. MAY FORM COMBUSTIBLE DUST CONCENTRATION IN AIR; SEE EXPLOSION HAZARD BELOW. EXPLOSION HAZARD: GRAIN IS GENERALLY CONSIDERED NOT HAZARDOUS BUT DUST GENERATED THROUGH DOWNSTREAM ACTIVITIES THAT MAY REDUCE ITS PARTICLE SIZE (E.G., SHIPPING, HANDLING, TRANSFER TO BINS, ETC.) MAY CREATE A HAZARDOUS CONDITION. IF EXPOSED TO AN IGNITION SOURCE, DUST MAY BURN. AIRBORNE DUST IN SUFFICIENT CONCENTRATIONS WHEN EXPOSED TO AN IGNITION SOURCE MAY FLASH OR, IN A CONFINED SITUATION, MAY FUEL AN EXPLOSION.

11 SECTION 3: COMPOSITION/INFORMATION ON INGREDIENTS COMPONENT CASRN CONCENTRATION WHOLE GRAINS FOREIGN MATERIAL (SUCH AS ORGANIC PLANT MATERIAL) GRAIN DUST UP TO 100% 0-5% 0-5% SECTION 4: FIRST AID MEASURES INHALATION: REMOVE PERSON FROM EXPOSURE. SEEK MEDICAL ATTENTION FOR ANY BREATHING DIFFICULTY. INGESTION: IF SWALLOWED, GIVE SEVERAL GLASSES OF WATER TO DILUTE. NEVER GIVE ANYTHING BY MOUTH TO AN UNCONSCIOUS PERSON. SKIN CONTACT: WASH AFFECTED SKIN WITH SOAP AND WATER. EYE CONTACT: FLUSH EYES WITH WATER. SEEK MEDICAL ATTENTION AS NEEDED. SECTION 5: FIREFIGHTING MEASURES FLASH POINT (METHOD): N/A FLAMMABLE LIMITS: LEL: UNKNOWN UEL: UNKNOWN AUTOIGNITION TEMPERATURE: UNKNOWN HAZARDOUS COMBUSTION PRODUCTS: OXIDES OF CARBON SPECIAL FIREFIGHTING PROCEDURES: EXTINGUISH WITH WATER FOG, DRY CHEMICAL POWDERS OR FOAM. DO NOT USE STRONG STREAMS OF WATER OR DRY CHEMICAL IF DUST CAN BE DISPERSED INTO THE AIR. DUST PLACED IN SUSPENSION WITH AN IGNITION SOURCE PRESENT MAY FLASH OR EXPLODE. UNUSUAL FIRE AND EXPLOSION HAZARDS: WHOLE GRAIN IS NOT EXPLOSIVE. FINE DUST DISPERSED IN AIR AT A SUFFICIENT CONCENTRATION MAY IGNITE IF EXPOSED TO AN IGNITION SOURCE. SECTION 6: ACCIDENTAL RELEASE MEASURES CLEAN UP WITH SOFT BRISTLE BROOM(S) OR A VACUUM APPROVED FOR A CLASS II HAZARDOUS LOCATION. DUST DEPOSITS SHOULD BE MAINTAINED TO A MINIMUM ON SURFACES, AS THESE COULD FORM AN EXPLOSIVE MIXTURE IF THEY ARE RELEASED INTO THE ATMOSPHERE IN SUFFICIENT CONCENTRATION. AVOID DISPERSAL OF DUST IN THE AIR (I.E. CLEANING DUST SURFACES WITH COMPRESSED AIR IN THE PRESENCE OF IGNITION SOURCE SHOULD NOT BE ALLOWED.) SECTION7: HANDLING AND STORAGE FINE DUST DISPERSED IN AIR AT A SUFFICIENT CONCENTRATION MAY IGNITE IF EXPOSED TO AN IGNITION SOURCE. REMOVE GRAIN DUST FROM AREA/PROCESSING EQUIPMENT PRIOR TO USING ANY HEAT PRODUCING EQUIPMENT SUCH AS ARC WELDERS, CUTTING TORCHES AND SPARK/HEAT PRODUCING TOOLS SUCH AS PORTABLE SURFACE GRINDERS. ACCORDING TO 29 CFR (F) A HOT WORK PERMIT IS REQUIRED. Safety Data Sheet for Whole Grain - Page 2 of 5

12 SECTION 8: EXPOSURE CONTROLS/PERSONAL PROTECTION RESPIRATORY PROTECTION: WEAR AN APPROVED NIOSH DUST RESPIRATOR WHENEVER DUST CONCENTRATIONS IN THE WORK AREA ARE ABOVE ACGIH TLV/OSHA PELS GRAIN DUST (WHEAT, OAT AND BARLEY) OSHA PEL ACGIH TLV 10 MG/M3 4MG/M3* OTHER GRAINS OSHA PEL ACGIH TLV 15 MG/M3 (TOTAL) 10 MG/M3* 5 MG/M3 (RESPIRABLE) * THIS TLV APPLIES TO NUISANCE PARTICULATES. THE GRAIN INDUSTRY BELIEVES THERE IS CURRENTLY INADEQUATE DATA TO SUPPORT THIS TLV. VENTILATION: LOCAL EXHAUST: IF NEEDED MECHANICAL (GENERAL): IF NEEDED ENSURE THAT DUST HANDLING SYSTEMS (SUCH AS EXHAUST DUCTS, DUST COLLECTORS, VESSELS, AND PROCESSING EQUIPMENT) ARE DESIGNED IN A MANNER TO PREVENT THE ESCAPE OF DUST INTO THE WORK AREAS. USE ONLY APPROPRIATELY CLASSIFIED ELECTRICAL EQUIPMENT AND POWERED INDUSTRIAL TRUCKS. PROTECTIVE GLOVES: N/A EYE PROTECTION: SAFETY GLASSES / GOGGLES SUGGESTED IN DUSTY CONDITIONS WORK/HYGIENIC PRACTICES: GOOD PERSONAL HYGIENE PRACTICES SHOULD BE FOLLOWED. AVOID EXCESSIVE DUST ACCUMULATION AND CONTROL IGNITION SOURCES. WHERE APPROPRIATE, EMPLOY GROUNDING, VENTING, AND EXPLOSION RELIEF PROVISIONS IN ACCORDANCE WITH ACCEPTED ENGINEERING PRACTICES IN PROCESSES CAPABLE OF GENERATING DUST AND/OR STATIC ELECTRICITY. SECTION 9: PHYSICAL AND CHEMICAL PROPERTIES FLASH POINT (METHOD): N/A FLAMMABLE LIMITS: LEL: UNKNOWN UEL: UNKNOWN AUTOIGNITION TEMPERATURE: UNKNOWN APPEARANCE: NATURAL GRAIN COLOR - WHOLE GRAIN GRAIN DUST - LIGHT, GRAYISH OR BROWN POWDER UPPER/LOWER FLAMMABILITY OR EXPLOSIVE LIMITS: WHEN DISPERSED INTO THE AIR IN SUFFICIENT CONCENTRATIONS GRAIN DUST CAN EXPLODE IN THE PRESENCE OF AN IGNITION SOURCE. DO NOT ALLOW DUST TO BECOME DISPERSED INTO THE AIR, EVEN BY THE EXTINGUISHING AGENT. MINIMUM EXPLOSIVE CONCENTRATION IS 55 G/M3. HOWEVER, MOISTURE CONTENT, PARTICLE SIZE, CALORIC PROPERTIES, AND SPECIFIC INGREDIENTS ALSO AFFECT THE EXPLOSIVENESS OF GRAIN DUST. THE FLASH POINT AND FLAMMABLE LIMITS ARE ACCURATE BECAUSE GRAIN DUST HAS NO FLASH POINT, LEL, OR UEL DUE TO ITS PROPERTIES. THE FIREFIGHTING MEASURES LISTED ARE IN ACCORD WITH OTHER SIMILAR SDS. Safety Data Sheet for Whole Grain - Page 3 of 5

13 FOR AN EXPLOSION TO OCCUR, FOUR CONDITIONS MUST EXIST: FIRST, OXYGEN MUST BE PRESENT. SECOND, THERE MUST BE AN IGNITION SOURCE (E.G. ELECTRICAL SHORT, SPARKS, ETC.). THIRD, THERE MUST BE FUEL (E.G. GRAIN DUST IN SUSPENSION). FOURTH, THERE MUST BE CONTAINMENT OF SUSPENDED GRAIN DUST (I.E. SILO, VESSEL, ETC.). ALTHOUGH AN EXPLOSION WILL NOT OCCUR IF THERE IS NO CONTAINMENT, THE DUST CAN STILL IGNITE, RESULTING IN A FIRE. AS NOTED, EXPLOSIONS ARE DEPENDENT UPON THE CONCENTRATION OF THE FUEL (E.G. GRAIN DUST) SUSPENDED IN THE AIR. THE MINIMUM EXPLOSIVE CONCENTRATION (MEC) FOR GRAIN DUST IS AROUND 55G/M3. THE MEC VARIES ACCORDING TO THE PARTICLE SIZE AND CALORIC PROPERTIES OF THE PRODUCT. IN ADDITION, THE SPECIFIC INGREDIENTS OF THE GRAIN DUST WILL AFFECT THE MEC. THEREFORE, THE LISTED MEC RANGE WOULD BE APPROPRIATE. THE FOLLOWING INSERT TAKEN FROM "PREVENTING GRAIN DUST EXPLOSIONS" EXPLAINS EXPLOSIVE LIMITS FOR GRAIN DUST: "A TEXAS A&M UNIVERSITY DUST CONTROL SCIENTIST SUGGESTS THAT THE MEC RANGE IS ABOUT 50 TO 150 GRAMS PER CUBIC METER, DEPENDING ON THE TYPE OF DUST AND THE SIZE OF PARTICLES (PARNELL, 1998). THIS EQUATES TO THE SAME MEC LEVEL USED BY THE NATIONAL GRAIN AND FEED ASSOCIATION (NGFA). NGFA STATES THAT THE BROAD, GENERALLY ACCEPTED MEC FOR GRAIN DUST EXPLOSIONS IS ABOUT 0.05 OUNCES PER CUBIC FOOT OF VOLUME. IT SAYS THAT THE OPTIMUM EXPLOSIVE CONCENTRATION (DEC) IS ABOUT 0.5 TO 1.0 OUNCES PER CUBIC FOOT - ABOUT 10 TIMES THE MEC (GILLIS, 1985, P. 43)." ODOR: NO DISTINCT ODOR (OUT-OF-CONDITION PRODUCTS MAY BE SOUR OR MUSTY) VAPOR PRESSURE: N/A ODOR THRESHHOLD: N/A VAPOR DENSITY: N/A PH: N/A SOLUBILITY (IES): N/A EVAPORATION RATE: N/A MELTING POINT/FREEZING POINT: N/A PARTITION COEFFICIENT N-OCTANOL/WATER: N/A FLASH POINT: N/A DECOMPOSITION TEMPERATURE: N/A SECTION 10: STABILITY AND REACTIVITY INITIAL BOILING POINT AND BOILING RANGE: N/A AUTO-IGNITION TEMPERATURE: N/A STABILITY: CONDITION TO AVOID: DISPERSING DUST IN AIR, ABOVE MEC, AND EXPOSURE TO POTENTIAL IGNITION SOURCES STABLE: X INCOMPATIBILITY (MATERIALS TO AVOID): NONE KNOWN HAZARDOUS DECOMPOSITION OR BYPRODUCTS: CO2 H2S AND OXYGEN DEFICIENT ATMOSPHERE UNDER IMPROPER STORAGE CONDITIONS HAZARDOUS POLYMERIZATION: CONDITION TO AVOID: N/A WILL NOT OCCUR: X REACTIVITY: SECTION 11: TOXICOLOGICAL INFORMATION ROUTES OF EXPOSURE: INHALATION: X SKIN: X EYES: X INGESTION: UNLIKELY CARCINOGENICITY: NTP: NO ARC MONOGRAPHS: NO OSHA REGULATED: NO ACUTE: MAY BE MECHANICAL IRRITANT TO SKIN AND EYES. EXCESSIVE INHALATION OF GRAIN DUSTS MAY AFFECT THE NOSE, THROAT, AND LUNGS. CHRONIC: REPEATED AND PROLONGED EXPOSURE TO GRAIN DUSTS MAY AFFECT THE RESPIRATORY SYSTEM OR CAUSE SENSITIZATION. SMOKERS HAVE AN INCREASED RISK OF REPIRATORY EFFECTS. SIGNS AND SYMPTOMS OF EXPOSURE: IRRITATION TO THE SKIN, EYES, NOSE OR THROAT MAY OCCUR. SOME PEOPLE MAY OCCASIONALLY EXPERIENCE COUGHING. MEDICAL CONDITIONS GENERALLY AGGRAVATED BY EXPOSURE: ALLERGIES AND RESPIRATORY AILMENTS. Safety Data Sheet for Whole Grain - Page 4 of 5

14 SECTION 12: ECOLOGICAL INFORMATION: (NON-MANDATORY) SECTION 13: DISPOSAL CONSIDERATIONS: (NON-MANDATORY) SECTION 14: TRANSPORT INFORMATION: (NON-MANDATORY) SECTION 15: REGULATORY INFORMATION: (NON-MANDATORY) ALL ELECTRICAL EQUIPMENT MUST BE SUITABLE FOR USE IN HAZARDOUS ATMOSPHERES INVOLVING COMBUSTIBLE DUST IN ACCORDANCE WITH 29 CFR THE NATIONAL ELECTRICAL CODE, NFPA 70, CONTAINS GUIDELINES FOR DETERMINING THE TYPE AND DESIGN OF EQUIPMENT AND INSTALLATION, WHICH WILL MEET THIS REQUIREMENT. COMBUSTIBLE DUST IS A "HAZARD, OTHER THAN CHEMICAL" AS DEFINED BY THE OSHA HAZARD COMMUNICATION STANDARD, 29 CFR SECTION 16: OTHER INFORMATION THIS SAFETY DATA SHEET COVERS GRAIN IN ITS NATURAL STATE AND DOES NOT INCLUDE CHEMICALS THAT MAY BE APPLIED BY SUBSEQUENT HANDLERS AND/OR DISTRIBUTORS OF THIS PRODUCT. THE INFORMATION IN THIS SDS WAS OBTAINED FROM SOURCES THAT WE BELIEVE ARE RELIABLE; HOWEVER, THE INFORMATION IS PROVIDED WITHOUT ANY REPRESENTATION OR WARRANTY, EXPRESSED OR IMPLIED, REGARDING THE ACCURACY OR CORRECTNESS. THE CONDITIONS OR METHODS OF HANDLING, STORAGE, USE AND DISPOSAL OF THE PRODUCT ARE BEYOND OUR CONTROL AND MAY BE BEYOND OUR KNOWLEDGE. FOR THIS AND OTHER REASONS, WE DO NOT ASSUME RESPONSIBILITY AND EXPRESSLY DISCLAIM LIABILITY FOR LOSS, DAMAGE, OR EXPENSE ARISING OUT OF OR IN ANY WAY CONNECTED WITH THE HANDLING, STORAGE, USE, OR DISPOSAL OF THIS PRODUCT. Safety Data Sheet for Whole Grain - Page 5 of 5