1. Implementation of US GHS SDSs and Labels –Sartomer’s Experience Lisa Caruso February, 2015

2. Sartomer – Our Experience Sartomer transitioned all of their MSDSs to the new GHS SDS format in the middle of a business transition to SAP ●What were we thinking? ●Didn’t manage the change with customers well ●Some customers were happy we transitioned early ●Some weren’t because they didn’t want to implement until June 1st We were the first business unit at Arkema to convert to GHS We were learning as we were writing…

3. Impacts SDS/label hazard classifications changed significantly for many products ●Some products had new, more restrictive hazards based on lower (<1%) cut-off’s for CMRs and Skin sensitizers –Had to consider impact of impurities, additives, residual raw materials for the first time - Reformulated some products to avoid labeling - Components previously not listed had to be disclosed ●Labeling required for new hazards: –Genotoxicity –Acute and Chronic Ecotoxicity - Many products were re-classified from non-haz to Class 9 for DOT - Increased transportation costs, lack of hazmat drivers

4. Impacts Implemented a new labeling system to handle GHS ●Learning the new software as we were designing label formats ●Sometimes finished labels the day product was scheduled to ship Purchased new printers for all plants and warehouses to be able to print labels with red borders on pictograms Products with pre-printed labels were prioritized so we had enough lead time for the new labels Tried to manage inventory to reduce re-labeling obligations

5. Lessons learned GHS WILL NOT result in Harmonization of SDSs/labels across regions and competitors ●GHS harmonizes methodology of assessing hazards but does not harmonize outcomes Classifications will differ between countries: ●We see differences between SR US and SR EU for the same products ●Not all mixture cutoff levels are the same - Ex. Repro Tox: EU cutoff 0.3%; US cutoff 0.1% Classification may be different than competitors: ●We classify based on the data available to us ●They may be classifying based on internal study results only available to them Need a robust SDS system to handle GHS rules and formats