November 15, 2004



To Whom It May Concern:



The OSHA Hazard Communication Standard, 29 CFR 1910.1200 effective 25 November 1985, requires the manufacturers or importers

of certain hazardous chemicals or products to assess their products as to their hazard potential. Shurtape Technologies, LLC has

assessed the impact of the standard of ALL of our finished pressure sensitive tapes. The conclusion, after a comprehensive review that

included consultation with independent consultants, is that ALL of Shurtape’s pressure sensitive tapes are exempt from this standard.

This exemption is based upon the premise that ALL of Shurtape’s pressure sensitive tapes are considered “ARTICLES� as defined in 29

CFR 1910.1200 (b) (6) (v). An “ARTICLE,� as defined in 29 CFR 1910.1200 (c), “means a manufactured item, other than a fluid or

particle:



          (i)       which is formed to a specific shape or design manufacture;

          (ii)      which has end use function (s) dependent in whole or in part upon its shape or design during end use; and

          (iii)     which under normal conditions of use does not release more than very small quantities, e.g. minute or trace amounts

                    of a hazardous chemical (as determined under paragraph (d)1 of this section) and does not pose a physical hazard

                    or health risk to the employee.�



Therefore, based on the above determination, Material Safety Data Sheets (MSDS) are not required for any pressure sensitive tapes

manufactured or sold by Shurtape Technologies, LLC.



The raw material formulations and processes used in the manufacture of our pressure sensitive tapes are considered proprietary. This

standard provides for both the need to protect against potential exposure and the need to maintain confidentiality of proprietary

information. The standard provides for the limited disclosure of certain proprietary information upon official request, either in a medical

emergency or a non-emergency to a qualified health professional2 under specific conditions of need and confidentiality. These health

professionals would be furnished medical or other occupational health services in cases involving potential exposures. Since our

pressure sensitive tapes do not release or otherwise result in exposure to a hazardous chemical under normal recommended conditions of

use, disclosure of proprietary materials and processes is available as described in the trade secret section of the standard.



While Shurtape Technologies, LLC believes the information contained herein is accurate, it is not to be taken as a warranty of

representation for which Shurtape Technologies, LLC, assumes any legal responsibility for product liability. This information is offered

solely for our customers� consideration, investigation, and any necessary verification. Any use of this information or of the pressure

sensitive tapes provided by Shurtape Technologies, LLC must be determined by the user to be acceptable for their intended purpose(s)

and in accordance with the appropriate federal, state or local laws and regulations including 29 CFR in its entirety.



Sincerely,





Mark E. Hawes, P.E.

Director � Environment and Safety

__________________________________________

1

 Paragraph d, “Hazard Determination.� is found in 29CFR 1910.1200 (d).

2

  Health professionals would be defined as physicians, industrial hygienists, toxicologists, epidemiologists, or occupational health nurses.

These issues are specified in 29 CFR 1910.1200 (i) “Trade Secrets.�









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