REGULATORY TIMELINE

MARCH 2007(Chocolate Bayou)
Passed inspection by DRMS (Defense Reutilization and Marketing Service), a division of DLA (Defense Logistics Agency)

2007 (Chocolate Bayou)
Launched ChemStewards® Management System

AUGUST 2006 (Chocolate Bayou)
Made improvements based on OSHCON’s recommendations

JULY 2006 (Chocolate Bayou)
Passed TCEQ Storm Water Division inspection

JANUARY 2006 (Tucson)
Passed inspection by ADOSH

OCTOBER 2005 (Chocolate Bayou)
Passed U.S. government inspection

FEBRUARY 2005 (Chocolate Bayou)
Passed U.S. government inspection regarding supply of products to the U.S. military

DECEMBER 2004 (Chocolate Bayou)
Passed TCEQ Solid Waste Division inspection

AUGUST 2004 (Tucson)
Passed inspection by the City of Tucson Stormwater Division

JUNE 2004 (Tucson)
Passed inspection by Pima County Industrial Wastewater Management

Regulatory Excellence

Tucson Facility

Programs

Regulated by ADEQ (Arizona Department of Environmental Quality).

OSHA (Occupational Safety & Health Administration) recording responsibilities.

EPCRA (Emergency Planning Community Right-to-Know Act) Tier II reporting.


Inspections

Passed inspection by ADOSH (Arizona Division of Occupational Safety and Health) in January 2006.

Passed inspection by the City of Tucson Stormwater Division in August 2004.

Passed inspection by Pima County Industrial Wastewater Management in June 2004.


Permits

AZPDES (Arizona Pollutant Discharge Elimination System) Stormwater General-Multi Sector Permit

SW3P (Stormwater Pollution Prevention Plan)

Hazardous Waste Generator Registration



Chocolate Bayou Facility

Programs

Launched the ChemStewards® Management System in 2007.

Regular reports to SOCMA (Synthetic Organic Chemical Manufacturers Association) and OSHA (Occupational Safety and Health Administration).

Environmental, Health & Safety and Security programs are constantly monitored, with immediate steps taken to resolve any problems that may occur.


TCEQ (Texas Commission on Environmental Quality) Inspections

Passed inspection by TCEQ’s Storm Water Division in July 2006.

Passed inspections by TCEQ’s Solid Waste Division in December 2004 and December 2006.


Military Inspections

Passed inspection by DRMS (Defense Reutilization and Marketing Service), a division of DLA (Defense Logistics Agency), in March 2007.

Passed inspection in October 2005.

Passed inspection by the U.S. government in February 2005, regarding our supply of products to the U.S. military.


OSHCON (Occupational Safety and Health Consultation Program) Inspection

Inspected by OSHCON in August 2006 and made improvements based on their recommendations.


Permits

TCEQ Industrial Waste Permit.

TCEQ No Exposure Certification Permit.

DOT (Department of Transportation) Hazardous Materials Shipper Registration.

PCI is also well within the legal limit for air pollutants and VOCs (Volatile Organic Compounds).