Summary of Ethyl Corporation’s Product Risk Characterization & Management Process

Ethyl Corporation takes a very proactive approach toward characterizing and managing risks associated with the company’s products. This process consists of the following steps as illustrated by this flow schematic, and explained below:

Product Identification

For the purpose of product risk characterization and management, we define our products to be purchased raw materials and produced components, which are sold or blended into Ethyl products. All relevant data on the product are collected from various internal and external sources. These data include, but are not limited to, product use, chemical composition, purity, physico-chemical properties, etc.

Hazard Assessment

Once a product and its properties have been identified, its hazard potential is determined through a multi-pronged approach. This includes gathering physical, toxicological and environmental data. Sources for these data may be suppliers’ MSDSs, in-house analytical data, testing, and published scientific literature. The information is used to assess the hazard potential in compliance with OSHA Hazard Communication Standard (29 CFR 1910.1200), EU Directives, Canadian WHMIS regulations, as well as an Ethyl Hazard Rating System. Products are then classified according to the regulations of the applicable world regions in which they are being manufactured in and supplied to.
The hazard classification for all our products is published on the MSDSs which are supplied to all customers irrespective of whether or not the product is classified as hazardous.

Exposure Assessment

Exposure assessment is a key component in Ethyl’s risk characterization process. The factors that go into the exposure assessment include, but are not limited to, product end-use, exposure potential, exposure routes, nature of anticipated exposure, and amount of material involved in potential exposure. Based on these factors, a determination is made as to how much of the material a person or population may be exposed to, were an exposure to occur.
Based on this process, we assign appropriate exposure ratings for our products.

Risk Characterization

Risk characterization is a function of the hazard of a substance and exposure to it (Risk = Hazard x Exposure). Risk characterization for our products is done in relationship to applicable stakeholders, such as consumers, neighbors, and the environment.

Risk Management

Once a product is characterized, a specific risk management strategy for the product is developed commensurate with that risk.

Re-evaluation

Re-evaluation of a product’s risk characterization and management could be done in a number of scenarios:

• Availability of new information through research, analytical or other sources
• Changes to Ethyl’s internal production process
• Changes to ingredients
• Changes to applicable regulations or standards, etc.

Emergency Service/Response During Transportation

Ethyl Corporation’s emergency response telephone number is:
(800) 424-9300 CHEMTREC number used on most of Ethyl’s U.S. bulk shipping containers and shipping documents

This telephone number is published on Ethyl MSDSs, literature, and some shipping documents. CHEMTREC, CANUTEC and others use these numbers to inform Ethyl of an incident involving Ethyl products. Ethyl has emergency response coverage 24 hours a day, 7 days a week. A trained Emergency Coordinator is on call to respond to any emergency.

Ethyl’s response will vary according to the requirements of the emergency. In most cases, the response will consist of providing information on characteristics, personal safety equipment, safe handling, and packaging of Ethyl products. Ethyl will provide information to first responders at the scene of an accident and arrange for a qualified firm to clean up a spill.