Registration & Product Labeling Manual

September 2013

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September 6, 2011 Dear CuVerro Customer,

Olin Brass has prepared this Registration and Product Labeling Manual to assist companies manufacturing and marketing products made with CuVerro® bactericidal copper alloy surfaces in complying with federal and state statutes, regulations, and rules.

CuVerro is the registered trademark brand of copper alloy products manufactured by GBC Metals, LLC d.b.a Olin Brass, a subsidiary of Global Brass and Copper, Inc. CuVerro copper alloys are registered with the U.S Environmental Protection Agency (U.S. EPA), allowing public health claims that CuVerro products kill bacteria1.

CuVerro’s bactericidal properties are unique for solid surfaces. CuVerro is the most effective class of solid material that can claim an inherent ability to kill bacteria; and it was the first class of solid surface material to be registered with the U.S. EPA to make public health claims.

Accordingly, this manual will help guide your company with U.S. EPA compliance issues as you manufacture and market products made from CuVerro alloys.2 As you review the prepared information, please consider the following:

 The U.S. EPA mandates adherence to these requirements in order to make public health claims associated with CuVerro alloys.

 The information in this manual is provided as a supplement to the complete product labeling and registration requirements found at www.epa.gov.

Among the benefits of being a registered CuVerro alloy customer are the breadth of product offerings from alloys and forms (including sheet, strip, tube, castable ingot) to the umbrella U.S. EPA registration available through Olin Brass--negating the need for your company to maintain annual U.S EPA and individual state registrations for each bactericidal product that you offer.

Finally, we are committed to supporting the growth of our strategic partners and their products in this developing healthcare marketplace.

Sincerely,

Thomas J. Werner VP Sales and Marketing, Olin Brass

1 Testing demonstrates effective antibacterial activity against Staphylococcus aureus, Enterobacter aerogenes, Methicillin-Resistant Staphylococcus aureus (MRSA), Escherichia coli O157:H7, Pseudomonas aeruginosa, and Vancomycin-Resistant Enterococcus faecalis (VRE). The use of CuVerro® bactericidal copper products is a supplement to and not a substitute for standard infection control practices; users must continue to follow all current infection control practices, including those practices related to cleaning and disinfection of environmental surfaces. This surface has been shown to reduce microbial contamination, but it does not necessarily prevent cross contamination. It should not be interpreted that CuVerro is making claims to solely prevent bacterial infections nor should it be implied that CuVerro products make such claims.

2 Olin Brass has prepared this Registration and Product Labeling Manual as a courtesy to its customers and to outline the information needed to be provided by customers to meet Olin Brass’ obligations under federal and state statutes, regulations and rules. This is not meant to replace, and may not be interpreted as replacing, guidance and opinions from a licensed attorney. We strongly advise you to seek advice from your own attorney before offering any bactericidal products for sale. Furthermore, the information contained in this Manual is current to the best of our knowledge in the date it is published, but is subject to change with any changes issued by any governmental or regulatory agencies having jurisdiction. You are responsible for keeping abreast of all laws affecting the manufacturing, sale and distribution of items you manufacture using CuVerro® bactericidal copper surfaces.

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CuVerro® Registration & Product Labeling Manual Background and Overview ...... 4 U.S. EPA Registration...... 4 What is Registration? Why do Fabricators Using CuVerro Alloys Need to Register? What Is Olin Brass’ Role in the Registration and Compliance Process? What Does the Registration Process Require? Steps In Obtaining U.S. EPA Registration ...... 5 STEP 1: Use U.S. EPA Registered Materials ...... 6 STEP 2: Obtain an U.S. EPA Company Number ...... 7 STEP 3: Obtain an U.S. EPA Establishment Number...... 8 STEP 4: File an Initial U.S. EPA Production Report ...... 9 Initial Report Annual Reports STEP 5: Obtain California Broker’s License ...... 10 STEP 6: Maintain Manufacturing Records ...... 10 STEP 7: Maintain Reporting Records ...... 13 Reporting to U.S. EPA Reporting to California Reporting to Olin Brass STEP 8: Recreate U.S. EPA-Registered Label for CuVerro Fabricated Products . . 14 STEP 9: Develop Appropriate Marketing Collateral ...... 17 Fabricated Product Packaging Marketing Claims Description of Fabricated Products Permission and Usage of Trademarks STEP 10: Sign CuVerro Bactericidal Copper Alloy Supply Agreement . . . . 22 Finalize Registration Continued Activities with Olin Brass Appendix I: California DPR Quarterly Mill Assessment Instructions ...... 24

Appendix II: CuVerro Fabricated Product Labels ...... 27

Appendix III: CuVerro Graphic Standards ...... 32 Appendix IV: Representative Copy of CuVerro Supply Agreement ...... 39

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Background and Overview

In offering copper-based bactericidal materials, Olin Brass provides a broad range of alloys, forms and support services that can help suppliers of healthcare equipment and furnishings develop products with inherent abilities to kill harmful bacteria that are claimed to be responsible for two million hospital acquired infections each year, resulting in a hundred thousand deaths. It is Olin Brass’ goal to assist companies in the development of a suite of products with these built-in bactericidal properties that can enhance current cleaning and disinfecting practices, and benefit a broad range of healthcare, educational, hospitality and institutional applications.

In order for companies to market products with these bactericidal properties, they must be registered with the U.S. Environmental Protection Agency (U.S. EPA) and conform to prescriptive rules for marketing and distribution. This manual addresses these issues.

U.S. EPA Registration

What is Registration?

Olin Brass’ CuVerro® bactericidal surfaces have been registered with the U.S. EPA to legally make claims that these materials kill infectious bacteria. In particular, this Public Health Claim states that registered CuVerro surfaces kill specific bacteria tested according to U.S. EPA protocols:

“Testing demonstrates effective antibacterial activity against Staphylococcus aureus, Enterobacter aerogenes, Methicillin-Resistant Staphylococcus aureus (MRSA), Escherichia coli O157:H7, Pseudomonas aeruginosa, and Vancomycin-Resistant Enterococcus faecalis (VRE).”

The U.S. EPA examines the ingredients of materials that make public health claims to insure that they will not have “unreasonable adverse effects on humans, the environment and non-target species” (i.e. species other than the infectious bacteria identified above.)3

Why do Fabricators Using CuVerro Alloys Need to Register?

In order for manufacturers of furnishings, equipment and/or components using CuVerro materials (i.e. CuVerro Partners) to legally market products that include these claims, companies need to:

a) Register company information with the U.S. EPA b) Obtain an Establishment Number from the U.S. EPA c) File initial and annual production reports with the U.S. EPA, and d) Insure that future use of products under these claims is consistent with the directions- for-use listed on the U.S. EPA-approved product labels.

3 Source: http://www.epa.gov/pesticides/regulating/registering/index.htm

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What Is Olin Brass’ Role in the Registration and Compliance Process?

U.S. EPA requires that if public health claims are made for touch-surfaces on healthcare equipment and furnishings, it is the responsibility of THE ORIGINAL METALS SUPPLIER (i.e. Olin Brass) to oversee that all labeling and marketing materials meet specific U.S. EPA guidelines.

Olin Brass is required to insure that any downstream manufacturer using CuVerro® metals follows proper registration requirements, packaging and labeling formats, and guidelines for acceptable marketing collateral. Olin Brass is required to review and approve the CuVerro partners’ marketing materials, and retained copies of approved materials in our files.

What Does Registration Process Require?

Global Brass and Copper, Inc. has obtained a primary product registration for CuVerro alloys with both the U.S. EPA and all state regulatory agencies. This registration permits customers of Olin Brass to make human health claims on items containing CuVerro copper touch surfaces. As Federal and State registration (and filing costs) must be maintained on an annual basis, Olin Brass allows CuVerro customers to market and sell bactericidal products with minimal cost and administration as outlined below.

STEPS IN OBTAINING U.S. EPA REGISTRATION

CuVerro partners need to follow 10 easy steps in complying with the U.S. EPA’s registration process and the CuVerro Supply Agreement terms as summarized in Table 1, and outlined in the detail below.

Table 1: Registration Process

STEP Frequency Detail 1: Select U.S. EPA Registered Material. Continually Fabricated products making public health claims must utilize material from a U.S. EPA registered supplier.

2: Obtain U.S. EPA Company Number. One time Submit request on company letterhead.(2-4 weeks processing time)

3: Obtain U.S. EPA Establishment One time Submit U.S. EPA form 3540-8 to a regional U.S. Number. EPA office. (2-4 weeks processing time)

4: File Initial U.S. EPA Production Report One time File U.S. EPA form 3540-16 within 30 days of receiving Establishment Number.

5: Obtain California Broker’s License One time Companies with sales into or within California must obtain a Broker’s License.

6: Maintain Manufacturing Records Ongoing U.S. EPA requires tracking of material from Olin Brass to end customer. 7: Production Reporting Annually & Regular production reports must be filed with Quarterly U.S. EPA, California and Olin Brass.

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Table 1 (continued): Registration Process STEP Frequency Detail

8: Recreate U.S. EPA-Registered Labels Once U.S. EPA-registered labels must appear on for CuVerro® Fabricated Products every fabricated product and require approval from Olin Brass prior to first sale. 9: Develop Marketing Collateral As needed Frequency to be determined by CuVerro Partner. All collateral must be reviewed and approved by Olin Brass. 10: Sign CuVerro Supply Agreement and Once, then Sign CuVerro Supply Agreement and submit ongoing supporting documentation. Maintain ongoing Submit Registration Documents activities with Olin Brass.

STEP 1: Use U.S. EPA-Registered Materials

The initial offerings in the CuVerro® alloy product line include C706 (CuVerro Rose) and C710 (CuVerro White Bronze). These materials, along with their associated U.S. EPA product (and label) groups are included below. The following products have been registered for use as bactericidal touch surfaces and may be manufactured into a wide variety of products with public health claims: Table 2: CuVerro Group Alloys

Product EPA CuVerro Product Name Sample Color Nominal Group Reg. # Alloy %Copper*

CuVerro Nickel CuVerro® I 85353-1 C752 65.0 Bronze

CuVerro® II 85353-2 CuVerro Brass C260 70.0

CuVerro White C710 Bronze CuVerro® III 85353-3 77.5 Castable – CuVerro C963 White Bronze

CuVerro® IV 85353-4 CuVerro Copper C110 99.9

CuVerro Rose C706 CuVerro® V 85353-5 88.6 Castable – CuVerro C962 Rose

* Active Ingredient, nominal percent copper for alloys in Group. Consult Olin Brass product literature for composition of each CuVerro alloy.

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The U.S. EPA registration structure used for CuVerro® bactericidal copper alloys eliminates the requirements for CuVerro customers to register on either the federal and state levels. This ability of CuVerro partners to ‘piggy-back’ onto the CuVerro registration not only avoids the burden of registering in all 50 states, but also removes the need to have each specific item (i.e. component, model, SKU etc.) registered separately with the U.S. EPA. While the registration process has been greatly simplified, the following sections outline the registration activities required for companies to lawfully manufacture and sell product made with CuVerro bactericidal copper surfaces.

STEP 2: Obtain a U.S. EPA Company Number Each company planning to manufacture and subsequently sell an item using CuVerro copper surfaces will be required to obtain a “company number” from the U.S. EPA. The company number is a unique identifier that needs to be assigned to firms intending to make public health claims. A written request for a company number must be submitted to the U.S. EPA office on company letterhead. An example of this letter is shown in Figure 1. Requests should be submitted using one of the following methods:

 By Email: Send signed letter on company letterhead as an attachment to [email protected]  By Fax: Fax signed letter on company letterhead to (703) 305-7670, Attn: Adrienne Turner  By Regular Mail: Send signed letter on company letterhead to the address below U.S. Environmental Protection Agency Document Processing Desk (NEWCO) Office of Pesticide Programs, Mail Code 7504P 1200 Pennsylvania Avenue, N.W. Washington, DC 20460

[The EPA only accepts applications sent via USPS; do not use private carriers such as FedEx or UPS. Failure to send request via USPS will result in the application being returned to the sender.]

Allow a minimum of 2-4 weeks for the EPA to respond with an assigned number. Complete information regarding how to obtain a company number can also be found at:

http://www.epa.gov/opprd001/registrationmanual/chapter14.html

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Figure 1: Letter to Request Company Number

A company number is required to obtain an establishment number (see Step 3). This is needed in order to manufacture components or products that incorporate CuVerro® materials. Manufacturing includes fabricating, packaging, repackaging, labeling, relabeling or otherwise changing the product or container.

Submission of a signed letter on company letterhead requesting a company number will establish an official address with U.S. EPA. The U.S. EPA will direct all future correspondence to the official address filed with this request. The registrant must keep this official address record up-to- date.

STEP 3: Obtain a U.S. EPA Establishment Number

For CuVerro partners working with CuVerro, the U.S. EPA defines an “establishment” as any site where the active ingredient (i.e. CuVerro) is produced (including formulation, packaging repackaging, labeling and relabeling) regardless of whether the site is:

• Independently owned or operated; • Located in the United States and is producing the device only for export; or • Located in a foreign country and is producing the device for importation into the U.S.

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Once the U.S. EPA provides a company number, each facility or location within a company’s supply chain that manufactures, assembles, packages, repackages, labels, relabels, distributes or handles an item containing CuVerro copper surfaces must maintain an establishment number with the U.S. EPA

U.S. EPA form 3540-8 must be filed with the U.S. EPA to request establishment numbers. This form must be submitted to the unique U.S. EPA regional office for each establishment. Allow a minimum of 2-4 weeks for the regional office to assign the U.S. EPA establishment number for each facility. Additional information for completing U.S. EPA form 3540-8 and the establishment registration process, including U.S. EPA regional office locations, can be found at the U.S. EPA links listed below.

http://www.epa.gov/compliance/monitoring/programs/fifra/establishments.html

Registering your establishment is only required once. Registration of CuVerro® bactericidal materials falls under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) and is regulated by the U.S. EPA pesticide office (i.e. the surfaces have an inherent ability to kill bacteria, thus are considered a pesticide). The U.S. EPA assigns a unique number to each establishment that produces any pesticide or active ingredient. FIFRA requires that each producing establishment must place its U.S. EPA establishment number on the label or immediate container of each pesticide or active ingredient. Including the last establishment number where the product was produced or packaged on the final label provides traceability to the U.S. EPA for every product made with CuVerro. Application for the registration of an establishment requires the following information:

• Name and address of the company. • EPA company number. • Type of ownership (individual, partnership, cooperative association, corporation, or any organized group of people whether incorporated or not. • Name(s) of new producing establishment(s). • Site address and the mailing address of the new producing establishments, and • Name of the company official or authorized agent, a signature, date of signature, and phone number.

STEP 4: File Initial U.S. EPA Production Report

Initial Report: Following receipt of a unique establishment number from the U.S. EPA an initial production report must be submitted to the U.S. EPA within 30 days of notification of establishment registration. Form 3540-16 must be submitted for this purpose. The link below offers additional information on the reporting process. http://www.epa.gov/compliance/resources/publications/monitoring/fifra/estabreportinst.pdf

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Annual Reports: Thereafter, each facility that produces components or devices made with CuVerro must submit a report to the U.S. EPA annually, by March 1. The report includes: • Name and address of the producing establishment • Product registration number and name • Amounts of product produced and distributed (with CuVerro) for the previous year • Amounts of anticipated (CuVerro) production and distribution for the next calendar year. An annual report is required, even when no products are produced or distributed. All establishments, including foreign establishments, must submit a report to the U.S. EPA. For foreign establishments, the amount reported should only be that amount which is produced for import into the United States, not to other countries. Additional information on annual reporting requirements can be found at the below link.

http://www.epa.gov/compliance/monitoring/programs/fifra/establishments.html#report

STEP 5: Obtain California Broker’s License (if selling within California)

Companies selling fabricated products bearing U.S. EPA approved CuVerro® alloys labels into or within California must submit to additional registration requirements specific to the state of California. California requires that companies making such sales obtain a Broker’s License from the California Department of Pesticide Regulation (CA DPR). Information on Broker’s Licenses and how to apply for a license from the California Department of Pesticide Regulation (CA DPR) can be found on www.cdpr.ca.gov under the “Registration - Mill Assessment” tab or at the link listed below.

http://www.cdpr.ca.gov/docs/license/broker.htm

STEP 6: Maintain Manufacturing Records

Companies and individual establishments registered with the U.S. EPA and state of California are required to maintain detailed records of manufacturing activities and report specific production details on a regular basis. These records are required to ensure proper documentation and traceability of all products throughout the manufacturing supply chain. Olin Brass also requires specific reporting details that are required to maintain the primary CuVerro registration with the U.S. EPA and California. Details of these requirements are listed below.

Manufacturing Records

U.S EPA: In accordance with mandatory U.S. EPA reporting requirements, each customer must maintain detailed records regarding the receipt, manufacturing, shipment and disposal of CuVerro alloys within or from any U.S. EPA registered establishment. Specifics of each U.S. EPA requirement can be found in Title 40 Code of Federal Regulations Section 169. A summary of the U.S. EPA requirements along with brief comments is provided in Table 3 for additional reference.

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California: Companies licensed as Brokers in the state of California are required to maintain records beyond U.S. EPA requirements. Licensed Brokers are required to keep records of all purchases, sales and distributions of labeled product into and within California. These records must be kept for four years at the principal place of business.

Olin Brass: Companies manufacturing with CuVerro are also required, by Olin Brass, to develop a standard operating procedure (SOP) for compliance with U.S. EPA and state regulatory requirements. As a condition of the CuVerro supply agreement Olin Brass may at any time request a copy of this SOP and/or request to audit any U.S. EPA establishment manufacturing with CuVerro to ensure compliance with regulatory requirements.

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Table 3: EPA Establishment Manufacturing Records Checklist

Records & Documentation Retention Maintained Detail 1. Pesticide Production - 40 CFR 169.2(a) 2 Years a) Product name  CuVerro I, CuVerro II, CuVerro III, CuVerro IV or CuVerro V b) EPA Reg. No  85353-1, 85353-2, 85353-3, 85353-4, 85353-5 c) Amount Per Batch & Batch Tracked at each establishment as material is fabricated into finished identification number components.

2. Device Production - 40 CFR 169.2(b) 2 Years n/a CuVerro surfaces are not classified as EPA Devices

3. Receiving - 40 CFR 169.2(c) 2 Years a) Brand name of pesticide b) Name & address of shipper Receiving documents such as invoices, freight bills, receiving tickets, c) Name of delivering carrier ect. which provide the required information for material received d) Date received from Global Brass and Copper, Inc. will be considered satisfactory. e) Quantities Received

4. Shipping - 40 CFR 169.2(d) 2 Years a) Brand name of pesticide b) Name & address of consignee Records are required regardless of whether shipment or receipt of shipments is between plants owned or otherwise controlled by the c) Where product is produced same company. Shipping documents such as invoices, freight bills, d) Name of originating carrier receiving tickets, etc. which provide the required information will be e) Date of shipped or delivered considered satisfactory. f) Quantities shipped or delivered

5. Inventory - 40 CFR 169.2(e) Current a) Types & amounts of pesticides b) Quantities of device stock n/a CuVerro surfaces are not EPA Devices

6. Advertising - 40 CFR 169.2(f) 2 Years Copies of all domestic advertising for registered products. Including any advertising produced by producer or customer fabricators. Documents may include: brochures, product sheets, packaging, fliers, print advertising, radio, TV or other scripts.

7. FIFRA Guarantees - 40 CFR 169.2(g) 1 Year after expiration Copies of all guarantees given to customers stating that their product utilizes material that is a registered product under FIFRA

8. Export - 40 CFR 169.2(h) 2 Years Please consult Olin Brass prior to exporting any CuVerro products a) Copies of the specification or directions of the foreign purchaser for production of pesticide b) Copies of product labels and labeling c) Copies of signed foreign purchase acknowledgment d) Copies of instruction provided to foreign purchasers e) Copies of exporter certification f) Identity of coded research product

9) Disposal - 40 CFR 169.2(i) 20 Years a) Method of disposal Records of disposal for all scrap CuVerro product generated during b) Dates of disposal the manufacturing process must be maintain. For containers c) Location of disposal sites accumulated during production a statement from a company official d) Types and amounts of pesticides attesting to general methods and location of disposal will be e) Pesticide container statement considered satisfactory. Records may be forwarded to the EPA Regional Administrator for maintenance after 3 years. f) Deviation form normal practice

10) Tests on Humans - 40 CFR 169.2(j) 20 Years n/a CuVerro products are not intended for direct application on humans. Direct human testing is not anticipated. EPA memo on toxicity of bactericidal copper alloys can also be referenced.

11) Research Data - 40 CFR 169.2(k) Permanent  Primary efficacy data related to the registration of CuVerro alloys is on file with Copper Development Association.

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STEP 7: Production Reporting

Report to U.S. EPA

U.S. EPA establishments are required to file, annually, with the U.S. EPA a Pesticide Report for Pesticide-Producing and Device-Producing Establishments (U.S. EPA Form 3540-16). One report for each establishment number must be submitted to the U.S. EPA regional office unique to that facility no later than March 1st of the following year. Additional details on reporting instructions and reporting forms can be found at http://www.epa.gov/compliance/monitoring/programs/fifra/establishments.html or at the below U.S. EPA links.

“Instructions for Completing EPA Form 3540-16 Pesticide Report for Pesticide-Producing and Device-Producing Establishments”

http://www.epa.gov/compliance/resources/publications/monitoring/fifra/estabreportinst.pdf

“Pesticide Report for Pesticide-Producing and Device-Producing Establishments”

http://www.epa.gov/compliance/resources/publications/monitoring/fifra/estabreport.pdf

Report to California (Companies with sales into or within California)

Licensed Brokers in the state of California are required to submit quarterly reports for the first sale of each U.S. EPA registered product into and within California. Once licensed as a Broker the CA DPR will mail a reporting form for each product prior to the close of the calendar quarter. Information required for reporting includes registrant name, brand name, total sales dollars, total pounds of CuVerro® alloys sold and California registration number. Reports must be submitted no later than 30 days after the close of each quarter and must be submitted even if no sales are recorded.

In concert with quarterly reporting requirements California requires that licensed Brokers pay a “mill assessment” fee on all registered product sold into or within California. This fee is based on sales reported on the quarterly brokers report. The assessment rate is currently 2.1 cents on each dollar of sales for registered product. As a condition of the registration for CuVerro in California, Olin Brass has agreed to pay this mill assessment on behalf the Licensed Brokers. Although Olin Brass pays the mill assessment fee, brokers must still complete the quarterly report and submit it to the state of California within the required time period. To ensure that quarterly reports are properly accepted under this agreement Brokers should include a cover letter detailing the special agreement between Olin Brass and California. An example of the cover letter and instructions for completing the quarterly brokers report form can be found in Appendix I.

Report to Olin Brass

As a condition of the CuVerro product registration, Global Brass and Copper, Inc. is responsible for complying with U.S. EPA and State reporting requirements: associated product registrations, and renewal fees. Accordingly, Olin Brass requires that any company producing items made

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with CuVerro alloys submit copies of production reports, shipment summaries and procedural documents to Olin Brass as a condition of the CuVerro Supply Agreement.

This is detailed in Step 10, but includes the following:  Copies of all initial Pesticide Report for Pesticide-Producing and Device-Producing Establishments (EPA From 3540-16) submitted to the U.S. EPA.  A copy of the Pesticide Report for Pesticide-Producing and Device-Producing Establishments (U.S. EPA Form 3540-16) for each establishment. This must be submitted annually, by March 1st.  Licensed Brokers in California must submit quarterly, no later than 30 days after end of quarter, a copy of the Report of Pesticide Sales in California.  Upon request, companies must submit a copy of standard operating procedures for complying with record keeping and report requirements set forth by the U.S EPA and state regulatory agencies.

STEP 8: Recreate U.S. EPA-Registered Labels for CuVerro® Fabricated Products

As a registered product with the U.S. EPA, CuVerro alloys and components made with CuVerro alloys must meet certain labeling requirement. At a minimum each component must bear a U.S. EPA fabricated product label, including both a front label as shown in Figure 2 and the corresponding label insert, for the appropriate CuVerro group. This labeling is required by federal and state law to appear on the fabricated product packaging to inform the end consumer that the product contains an U.S. EPA registered product. Failure to include this label may result in enforcement actions, including stop sale orders and fines.

Copies of each U.S. EPA approved CuVerro fabricated product labels can be found in Appendix II. Digital copies of these labels are available upon request. If the provided versions cannot be utilized, CuVerro alloy customers may re-create the label to the best of their ability. The following sections provide guidelines for creation and use of registered labels. Approval from Olin Brass is required prior to the first use of any label and following any changes to the labels provided and not noted below.

Companies must submit a copy of their final label with appropriate establishment number to Olin Brass for review and approval via email to [email protected].

Touch surface made from ® CuVerro I Antimicrobial Copper Surface Active Ingredient: Copper………………………………………………… 66.5% Other: ………………………………………………………………………………………………… 33.5% Total…………………………………………………………………………………………………… 100.0% EPA Reg No.85353-1 EPA Est No. XXXXX-XX-XXX Net Weight: XXX lbs XXX oz of CuVerro® I See Insert for Directions for Use

Figure 2: Front CuVerro Fabricated Product Label

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Re-creation of U.S. EPA REGISTERED LABEL:

 Label text must be re-created using a font style that is clearly legible. Arial Mono-spaced or Mono-spaced Bold is recommended if available.

 Final label font size as it appears on the package must be no smaller than 6 point.

 The color of text and background cannot be modified from the standard black text on white background.

 The label layout cannot be altered or changed from the current format. No lines can be combined, deleted or relocated from the current position.

 English is the only language that can be used when recreating the approved labels.

Labeling requirements for PRODUCT DURING MANUFACTURING:

 Each facility within the fabricated product supply chain that handles CuVerro® alloys must be able to recreate the registered label including the U.S. EPA establishment number for that location.  Registered labels must be used on bulk shipments, transfers of product, final product shipments or whenever product is leaving registered facilities within the manufacture supply chain.  The front label on each package must include the total net weight of CuVerro included within that package, crate, pallet or container. This can be hand written on the label if necessary.  If individually labeled items are repackaged or wrapped for the purpose of transport or distribution such that the U.S. EPA label is not clearly legible, a label must be attached to the outside of the wrapper or container. A label for each CuVerro group contained within each package must be visible on the outside for mixed shipments. These labels need only identify the U.S. EPA registered product within and not the net weight. (Further review with Olin Brass should be conducted for unique situations.)

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Labeling requirements for FINAL PRODUCT DISTRIBUTION:

 Final products that are individually labeled and repackaged or wrapped, for the primary purpose of distribution or sells to the end user, such that the U.S. EPA label is not clearly legible, must bear a U.S. EPA approved label attached to the outside of the wrapper or container. A U.S. EPA label for each of the CuVerro® alloy groups contained within a wrapper or container intended for distribution or sells to and end user must be visible on the outside of the package.  Shipping packages (including mixed shipments with non-CuVerro product) used for distribution of individually labeled products do not need to bear the full product label if the individually labeled products are customarily removed from the shipping package and sold or distributed to the end user. The EPA does however recommend that large shipping containers be labeled with enough information for emergency personnel to identify the material.  If an individually labeled product is repackaged as part of another product by which the label is not clearly visible on the final product customarily sold or distributed to an end user, then a U.S. EPA approved label must be attached to the outside of the wrapper or container of the final product (i.e. cabinet pull installed on a finished cabinet).  Private courier packages such as UPS or FedEx do not need to bear the full product label if used to ship individually labeled products that are customarily removed prior to being sold or used by an end user.

Labeling requirement for FINAL PRODUCT PACKAGING:

 The front of the product package must bear the U.S. EPA registered CuVerro front label. This label must be for the correct CuVerro group and be clearly visible to the end user. Additional details on labeling requirements can be found in the prior labeling section.  The fabricated product label insert must be included on the back panel of the product packaging or included as an insert within the product packaging.  The net weight of the CuVerro alloy contained within the final product must be listed on the front label in units of pounds (lbs) and ounces (oz). This can be hand written on the label if necessary.  The EPA establishment number for the location performing the final packaging must be included on the front and back label. Those areas highlighted in red on the example labels in Appendix II must be updated for each unique establishment.

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STEP 9: Develop Appropriate Marketing Collateral

Collateral used in association with the marketing or sales of components made with CuVerro® bactericidal copper surfaces must meet the guidelines noted in the following sections. Such collateral may include but is not limited to press releases, product fact sheets, sell sheets, white papers, print advertising, store signage, web pages, emails and digital marketing. Final component packaging is also considered in this section as many of the same guidelines apply to claim language and positioning of this language with respect to other product information.

All claims made in association with CuVerro must be used in their entirety and cannot be paraphrased, combined or altered from the original form found in Section I of the below box.

I. Approved public health claims for product packaging, marketing literature and product information o This product is made from a copper surface that continuously kills bacteria* left behind by dirty hands, killing more than 99.9% of bacteria* within 2 hours.

Laboratory testing has shown that when cleaned regularly this surface: o Kills more than 99.9% of bacteria* within 2 hours, and continues to kill 99% of bacteria* even after repeated contamination o Delivers continuous and ongoing antibacterial* action, remaining effective in killing greater than 99.9% of bacteria* within 2 hours. o Helps inhibit buildup and growth of bacteria* within 2 hours of exposure between routine cleaning and sanitizing steps. o Kills greater than 99.9% of Gram-negative and Gram-positive bacteria* within 2 hours of exposure. o Continuously reduces bacterial* contamination, achieving 99.9% reduction within 2 hours of exposure.

II. Approved U.S. EPA asterisk language for claims referencing “Bacteria*” “*Laboratory testing shows that, when cleaned regularly, CuVerro surfaces kill greater than 99.9% of the following bacteria within 2 hours of exposure: Methicillin-Resistant Staphylococcus aureus, Staphylococcus aureus, Entrerobacter aerogenes,Pseudomonas aeruginosa, E. coli O157:H7, and Vancomycin-Resistant Enterococcus faecalis (VRE).

The use of CuVerro® bactericidal copper products is a supplement to and not a substitute for standard infection control practices; users must continue to follow all current infection control practices, including those practices related to cleaning and disinfection of environmental surfaces. This surface has been shown to reduce microbial contamination, but it does not necessarily prevent cross contamination. It should not be interpreted that CuVerro is making claims to solely prevent bacterial infections nor should it be implied that CuVerro products make such claims”

If claims are made in reference to “bacteria” an asterisk must be used, i.e. “bacteria*” and reference the approved U.S. EPA label language shown in Section II of the box above. This language must appear at the bottom of the page or on the outside of the component packaging where the claim is made.

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Fabricated Product Packaging

Claims referencing CuVerro® copper alloy surfaces on component packaging must be located in a section that does not include item performance or warranty claims. This is required to further emphasize that any public health claims listed in association with the product are for the CuVerro surfaces only. This is exemplified in Figures 3 & 4.

www.xyzhandle.com

Introducing Copper Handle from XYZ

 Mounting hardware included for retrofit  Handle and trim plate made with CuVerro® I bactericidal surface.  Ergonomic design allows ease of use  Kills+ more than 99.9% of bacteria* within 2 hours, and continues to kill 99% of bacteria* even after  Lifetime mechanical guarantee repeated contamination.  Laboratory tested and EPA registered.  Appealing warm copper color *Laboratory testing shows that, when cleaned regularly, CuVerro surfaces kill greater than 99.9% of the following bacteria within 2 hours of exposure: Methicillin-Resistant ® Staphylococcus aureus, Staphylococcus aureus, Entrerobacter aerogenes,Pseudomonas  Made with CuVerro I bactericidal surfaces aeruginosa, E. coli O157:H7, and Vancomycin-Resistant Enterococcus faecalis (VRE). The use of CuVerro® bactericidal copper products is a supplement to and not a substitute for standard infection control practices; users must continue to follow all current infection Life time guarantee is for the handle body and covers from fracture, rust, and other common defects that the result control practices, including those practices related to cleaning and disinfection of of common use defects that are the direct result of the manufacturing process. The guarantee does not cover those environmental surfaces. This surface has been shown to reduce microbial contamination, damages that are the result of neglect or misuse of the product. All claims must be filed in accordance with the but it does not necessarily prevent cross contamination. It should not be interpreted that claims procedure found on the inside cover of the product. Those claims not filed in a accordance with the CuVerro is making claims to solely prevent bacterial infections nor should it be implied that approved procedure will be denied without notice. CuVerro products make such claims.

1234 Handle St. 1-888-555-5555 XYZ Handle Hardware, Inc Handleville, XY Figure 3: Acceptable Packaging Format

www.xyzhandle.com

Introducing Copper Handle from XYZ

®  Mounting hardware included for easy  Handle and trim plate made with CuVerro I retrofit antimicrobial surface.

 Ergonomic design allows easy of use  Appealing warm copper color

 Kills more than 99.9% of bacteria* within 2  Lifetime mechanical guarantee hours, and continues to kill 99% of bacteria* even after repeated contamination. Life time guarantee is for the handle body and covers from fracture, rust, and other common defects that the result of common use defects that are the direct result of the manufacturing process. The guarantee does not cover those damages that are the result of neglect or misuse of the product. All claims must be filed in accordance with the claims procedure found on the inside cover of the product. Those claims not filed in accordance with the approved procedure will be denied without notice. *Laboratory testing shows that, when cleaned regularly, CuVerro surfaces kill greater than 99.9% of the following bacteria within 2 hours of exposure: Methicillin-Resistant Staphylococcus aureus, Staphylococcus aureus, Entrerobacter aerogenes,Pseudomonas aeruginosa, E. coli O157:H7, and Vancomycin-Resistant Enterococcus faecalis (VRE). The use of CuVerro® bactericidal copper products is a supplement to and not a substitute for standard infection control practices; users must continue to follow all current infection control practices, including those practices related to cleaning and disinfection of environmental surfaces. This surface has been shown to reduce microbial contamination, but it does not necessarily prevent cross contamination. It should not be interpreted that CuVerro is making claims to solely prevent bacterial infections nor should it be implied that CuVerro products make such claims.

1234 Handle St. 1-888-555-5555 XYZ Handle Hardware, Inc Handleville, XY Figure 4: Unacceptable Packaging Format

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Additional product packaging requirements include:  A statement must be made on the component packaging to indicate the specific part of the final component that utilizes CuVerro® surfaces.  Any human health claim or reference to CuVerro products must be made in English. Any additional references or claims made in languages other than English must be translated by a certified translator and approved by Olin Brass and the U.S. EPA prior to use.  When making claims it is important to remember that CuVerro is the registered product and NOT THE FINAL FABRICATED COMPONENT. All public health claims must be made in reference to CuVerro bactericidal copper.

Marketing Claims

Marketing claims can often be misleading and inaccurately interrupted. To help expedite the review and approval of marketing collateral commonly misused marketing claims have been listed in Table 4 along with acceptable alternatives.

Table 4: Marketing Claims for CuVerro

Unacceptable: Comment: Acceptable: Kills germs Six specific bacteria were tested for EPA Kills bacteria* Kills viruses registration of CuVerro-type surfaces. (Staphylococcus aureus, Enterobacter Kills mold and mildew Although other research papers show that aerogenes, Methicillin-Resistant copper alloys effectively kill viruses, mold Staphylococcus aureus (MRSA), and a broad range of bacteria, only these 6 Escherichia coli O157:H7, Vancomycin- bacteria can be cited in marketing and Resistant enterococci (VRE), and package claims. Pseudomonas aeruginosa).

“Widget” kills bacteria The product itself (i.e. widget) is not “Widget” is manufactured from CuVerro registered with the EPA… only the CuVerro Bactericidal Copper Surfaces that kill surface material that has been integrated bacteria*. into the product.

CuVerro prevents Although recent clinical trials indicate that CuVerro surfaces kill bacteria* that causes (reduces, stops, inhibits copper surfaces have a positive effect on infections. etc.) infections reducing life threatening infections, these claims or claims that CuVerro saves lives are not allowed by the EPA. Saves Lives CuVerro sufaces kill bacteria* that cause life threatening infections.

CuVerro is EPA-approved EPA does not want implications that they CuVerro is EPA-registered or Laboratory endorse any specific products. tested and EPA registered.

Kills bacteria all the time Claim must be specific and reference Kills+ more than 99.9% of bacteria* within 2 approved U.S. EPA claims. hours, and continues to kill 99% of bacteria* even after repeated contamination.

CuVerro provided a safer Safe or safer is a general and far reaching CuVerro provides a cleaner environment. environment claim and can imply certain performance claims that are not approved. CuVerro is all natural While copper is a naturally existing element CuVerro is 100% recyclable and made from the EPA is particular with regard to how this post and pre-consumer materials. term can be used.

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Marketing collateral and fabricated product packaging must be submitted for review and approval to Olin Brass prior to distribution. Documents shall be submitted via email to [email protected] unless otherwise noted. Once a document has been approved; a unique document number will be issues by Olin Brass and must appear on the document at all times. Approved documents may be reprinted or republished without subsequent approval from Olin Brass so long as there are no revisions or edits.

Clinical Trial & Infection Control Claims

A variety of studies and peer reviewed articles have recently been published examining the performance of bactericidal copper surfaces against a range of bacteria and viruses, most previously not tested under the U.S. EPA test protocol. Among these are several comprehensive studies that also aim to examine the possibility of using bactericidal copper surfaces to control Hospital Acquired Infection (HAIs). The information and findings shared in these studies often goes beyond the scope of the original U.S. EPA registration data, further expanding the evidence base to promote bactericidal copper products.

While published studies and peer reviewed papers are invaluable in communicating the power and benefits of bactericidal copper, limits are placed on how these studies can be used. This information may be discussed or reviewed in an education setting, such as a professional organization or learning seminar, but may not be used in formal marketing of U.S. EPA registered product. Marketing claims and human health claims for registered products are limited to those specifically tested and validated for that product with the U.S. EPA. Since the majority of these study provide findings that are outside the scope of the support data for the registration of bactericidal copper surfaces the claims and findings of these studies cannot be used in formal marketing. The six specific claims listed in the previous section should only be used for formal product marketing. Further examples of unacceptable claims and suggested alternative language can be found in Table 5.

Table 5: Clinical Trial Claims for CuVerro

Unacceptable: Comment: Acceptable: Helps/Proven to Reduce Helps/Proven to supplement/improve HAI’s While initial published results from select infection control practices. clinical trials are encouraging, any claims Clinical trial have shown that copper surfaces reduce infection CuVerro is an effective supplement to rates are outside the scope of the EPA existing infection control practices. copper can reduce HAI by registration and approved claims. 58%. CuVerro prevents spread of Cross contamination or disease control CuVerro surfaces kill 99.9% of bacteria* infection bacteria/ disease claims are not permitted and specifically within 2 hours reducing the potential risk of excluded by the EPA. exposure to infectious bacteria*.

Description of product

Special precautions should be taken when naming or describing a product made from or with CuVerro® copper surfaces. A final fabricated product name or description may not include any claims such as “bactericidal”, “antimicrobial” or “antibacterial”. The registered and controlled product is CuVerro, and all claims must be made in reference to CuVerro and not the final fabricated product. In addition, the item name or description may not include the word CuVerro.

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Table 6 provides several examples of how products should not be named and acceptable alternatives.

Table 6: Description of Product for CuVerro

Unacceptable: Comment: Acceptable: Bactericidal “Product Bactericidal claims can only reference a “Product XYZ” made with CuVerro XYZ” U.S. EPA registered product. bactericidal surfaces

Bactericidal “Widget” The product itself (i.e. widget) is not “Widget” made with CuVerro bactericidal registered with the EPA - only the CuVerro surfaces surface material that has been integrated into the product. CuVerro “Product X” Individual products cannot be described as “Product X” made with CuVerro bactericidal CuVerro branded products. This would surfaces. require further EPA registration for each product.

Permission and Usage of Trademarks Companies manufacturing finished fabricated product, that utilizes CuVerro copper surfaces with the intent to sell or distribute and by signing the CuVerro Supply Agreement, have a limited right to use the CuVerro® trademark and logo design on the fabricated product, fabricated product packaging and any related marketing/product literature. This right is limited and must meet the guidelines found in the CuVerro Supply Agreement, CuVerro Graphic Standards and listed below.

1. The first most prominent use of the word CuVerro in a body of text or page of a document must be listed as “CuVerro® bactericidal copper surface”. Subsequent usage of the word can be used without the registered trademark symbol and utilize alternative descriptors including but not limited to alloy(s), surface(s), material(s), antimicrobial alloy(s), antimicrobial surface(s), bactericidal alloy(s), bactericidal surface(s), bactericidal material(s), antimicrobial material(s), copper alloy(s), copper surface(s) and copper surface(s). 2. CuVerro cannot be used as a plural or possessive noun at any time. 3. Any document that utilizes the name CuVerro, CuVerro® or the approved CuVerro logo must include the statement that “CuVerro® is a registered trademark of GBC Metals, LLC and is used with permission”. 4. Only the CuVerro design marks (logos) set forth in the CuVerro Graphic Standards found in Appendix III may be used in connection with items manufactured using CuVerro alloys. The use of the CuVerro marks (either the word mark or any of the design marks) must be approved by Olin Brass prior to use. Digital files for design marks will be provided to customers upon written request submitted to [email protected]. The design marks may be resized as long as the proportions are constrained to maintain the original size ratio and the TM or ® designator is clearly readable. Any design marks reproduced in color must use Pantone 139 C or CMYK: C=5 M=46 Y=100 K=21. 5. Fabricated product cannot be branded as CuVerro item, but may include statements such as “Made with/from CuVerro® Bactericidal Copper Surface”.

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6. Olin Brass reserves the right to revoke this permission at any time, for any reason, upon notice to the customer. Upon notice from Olin Brass, unless otherwise agreed upon in writing, the customer must immediately cease any further use of the marks. 7. Customer agrees and acknowledges that they acquire no rights or interest in or to any of the CuVerro trademarks or trade names, including CuVerro® and the CuVerro design mark.

Any good will, equity or value embodied in or related to any of the trademarks or trade names are the sole and exclusive property of Olin Brass.

STEP 10: Sign CuVerro Bactericidal Copper Alloy Supply Agreement

As the final step in the registration process Olin Brass requires that all CuVerro partners pursuing the above registration steps and planning to use CuVerro alloys in their finished fabricated product complete a CuVerro Supply Agreement. The agreement includes ongoing regulatory obligations and conditions of use for the CuVerro Trademark. A signed agreement, returned to Olin Brass is necessary before any shipments of CuVerro materials will be made.

The following sections cover the requirements necessary to finalize the registration and details specific ongoing activities required to comply with the CuVerro Supply Agreement. Failure to comply with the requirements noted below and the terms of the CuVerro Supply Agreement may result in cancellation of open orders, stop sale orders, termination of Trademark Use Agreement and/or notification of noncompliance to regulatory agencies.

Finalize Registration

Prior to Olin Brass acknowledging the first CuVerro order, the registration process must be completed for each CuVerro partner as detailed in the following steps:

1. Submit proof of ability to accurately reproduce registered CuVerro fabricated product labels and correctly position on label on final product packaging. Copy of product packaging and/or copy of reproduced label shall be sufficient for this purpose. 2. Submit supporting regulatory documentation: a. Copy of initial Pesticide Report for Pesticide-Producing and Device Producing Establishments (EPA Form 3540-16) for every establishment registered your companies supply chain. b. Copy of confirmation from California DPR that the company is a Licensed Broker. (Only required for those companies selling product into or within California) 3. Submit for review and approval copies of all marketing collateral to be used for initial product promotion or launch. 4. Sign and return to Olin Brass the CuVerro Supply Agreement. A representative copy of this agreement is provided in Appendix IV.

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Continued Activities with Olin Brass

Recurring Activities: Following completion of the initial registration process, CuVerro® bactericidal copper partners are required to complete routine activities such as reporting of production activities and submission of marketing collateral for review and approval. Listed in Table 7 are the specific reporting activities required on a reoccurring basis and corresponding deadlines for which documents must be submitted to Olin Brass.

Table 7: Reporting to Olin Brass

Annual Deadline Activity Reporting Form

st Pesticide Report for Pesticide- March 1 Submit copy of U.S. EPA production report. Producing and Device Producing Establishments (EPA Form 3540-16) th April 30 Submit copy of California shipment and Report of Pesticide Sales in July 30th sales report. (Only required for those California October 30th companies selling product into or within California.) January 30th

All routine reporting documentation shall be submitted by the dates indicated above via parcel service to the following address:

GBC Metals, LLC d.b.a Olin Brass Attn: CuVerro Desk 4801 Olympia Park Plaza, Suite 3500 Louisville, KY 40241

As-Needed Activities: Beyond the routine activities noted above additional activities must be completed by CuVerro partners on an as-needed or requested basis and include the following:  Companies shall submit to an audit of and/or provide a prepared description of the standard operating procedures followed to ensure compliance with U.S. EPA and state regulatory requirements at each establishment to Olin Brass.  All documents including but not limited to product names, labels, packaging and marketing collateral which bear the CuVerro® trademark or trade name must be submitted for review and approval before introduction of product in commerce.

Marketing collateral shall be submitted to the following email address:

[email protected]

Congratulations! The registration process is complete.

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Appendix I

California Department of Pesticide Regulation Quarterly Mill Assessment

Instructions for completing Quarterly Report of Pesticide Sales for California Brokers:

1. Complete Page 2 of the Report of Pesticide Sales in California as instructed on

the form provided by California. (Note: Unique forms are mailed to each Broker

prior to the end of the calendar quarter, only use the form received by your firm).

2. Complete lines 1 - 4 on page 1 of the Report of Pesticide Sales in California as

instructed. On line 5 write “ref. cover letter” (see example in Figure A) in place

the instructed report values.

3. Use template below (Figure B) to compose a cover letter to the California

Department of Pesticide Regulation.

4. Submit report with cover letter to this address:

Cashier Department of Pesticide Regulation P.O. Box 4015, Mail Stop 4A Sacrament, CA 95812-4015

5. Submit a copy of your report and cover letter to Olin Brass:

Mail: GBC Metals, LLC Attn: CuVerro Desk 4801 Olympia Park Plaza, Suite 3500 Louisville, KY 40241

E-mail: [email protected]

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Figure A

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Figure B

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Appendix II EPA Registered CuVerro® Fabricated Product Labels

I. CuVerro I Label Touch surface made from

® CuVerro I Antimicrobial Copper Surface Active Ingredient: Copper………………………………… 66.5% Other: ………………………………………………………………………………. 33.5% Total……………………………………………………………………………………. 100.0% EPA Reg No.85353-1 EPA Est No. XXXXX-XX-XXX Net Weight: XXX lbs XXX oz of CuVerro® I See Insert for Directions for Use

Figure 1: CuVerro I Fabricated Product Label – Front

® This product is made out of a copper surface that continuously kills bacteria left behind by dirty hands, CuVerro I killing more than 99.9% of bacteria* within 2 hours. Antimicrobial Copper Surface

Laboratory testing has shown that when cleaned regularly this surface:

. Kills greater than 99.9% of bacteria* within two hours, and continues to kill 99% of bacteria* even after repeated contamination . Delivers continuous and ongoing antibacterial* action, remaining effective in killing greater than 99.9% of bacteria* within 2 hours. . Helps inhibit buildup and growth of bacteria* within 2 hours of exposure between

routine cleaning and sanitizing steps. . Kills greater than 99.9% of Gram-negative and Gram-positive bacteria* within 2 hours of exposure. . Continuously reduces bacterial* contamination, achieving 99.9% reduction within 2 hours of exposure.

*Staphylococcus aureus, Enterobacter aerogenes, Methicillin-Resistant

Staphylococcus aureus (MRSA), Escherichia coli O157:H7, Pseudomonas aeruginosa, and Vancomycin-Resistant Enterococcus faecalis (VRE).

DIRECTIONS FOR USE: It is violation of Federal Law to use this product in a manner inconsistent with its labeling.

PROPER CARE AND USE: Clean and sanitize according to standard practice. Healthcare

facilities must maintain the product in accordance with infection control guidelines. The use of this surface is a supplement to and not a substitute for standard infection control practices; users must continue to follow all current infection control practices, including those practices relatedFigure to 2: cleaning CuVerro and I Fabricateddisinfection Productof environmental Label - surfaces.Insert This surface has been shown to reduce microbial contamination, but does not necessarily prevent cross contamination.

This surface may be subject to recontamination and the level of active bacteria at any particular time will depend on the frequency and timing of recontamination and cleanliness of the surface (among other factors). In order to have proper antimicrobial effect, this product must be cleaned and maintained according to the directions for use.

DO NOT WAX, PAINT, LACQUER, VARNISH, OR OTHERWISE COAT THIS PRODUCT.

Routine cleaning to remove dirt and filth is necessary for good sanitation and to assure the effective antibacterial performance of this surface. Cleaning agents typically used for traditional hard, non-porous touch surfaces are permissible. The appropriate cleaning agent depends on the type of soiling and the measure of sanitization required. Normal tarnishing or wear of this product will not impair the antimicrobial effectiveness.

NOT APPROVED FOR DIRECT FOOD CONTACT OR FOOD PACKAGING USES.

Items exposed to outdoor environmental conditions are not representative of indoor laboratory test conditions, and therefore, may impart reduced efficacy if not cleaned when visibly soiled.

STORAGE AND DISPOSAL: Dispose of by recycling or put in trash.

WARRANTY STATEMENT: If used as intended this product is wear-resistant and the durable antibacterial properties will remain effective for as long as the product remains in place and is used as directed. Global Brass and Copper, Inc Manufactured by: OB-0001-1104 427 N. Shamrock St. [Product Manufacturer] East Alton, IL 62024 [Name Address] www.CUVERRO.com 1-877-311-CUVERRO(2883) EPA Reg No 85353-1 EPA Est No. XXXXX-XX-XXX

Figure 2: CuVerro I Fabricated Product Label - Insert

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II. CuVerro II Label

Touch surface made from

CuVerro II Antimicrobial Copper Surface Active Ingredient: Copper………………………………… 73.0% Other: …………………………………………………………………………….… 27.0% Total…………………………………………………………………………………… 100.0% EPA Reg No.85353-2 EPA Est No. XXXXX-XX-XXX Net Weight: XXX lbs XXX oz of CuVerro® II See Insert for Directions for Use

Figure 3: CuVerro II Fabricated Product Label - Front

® This product is made out of a copper surface that continuously kills bacteria left behind by dirty hands, CuVerro II Antimicrobial Copper Surface killing more than 99.9% of bacteria* within 2 hours.

Laboratory testing has shown that when cleaned regularly this surface:

. Kills greater than 99.9% of bacteria* within two hours, and continues to kill 99% of

bacteria* even after repeated contamination . Delivers continuous and ongoing antibacterial* action, remaining effective in killing greater than 99.9% of bacteria* within 2 hours. . Helps inhibit buildup and growth of bacteria* within 2 hours of exposure between routine cleaning and sanitizing steps. . Kills greater than 99.9% of Gram-negative and Gram-positive bacteria* within 2 hours of

exposure. . Continuously reduces bacterial* contamination, achieving 99.9% reduction within 2 hours of exposure.

*Staphylococcus aureus, Enterobacter aerogenes, Methicillin-Resistant Staphylococcus aureus (MRSA), Escherichia coli O157:H7, Pseudomonas aeruginosa, and Vancomycin-Resistant Enterococcus faecalis (VRE).

DIRECTIONS FOR USE: It is violation of Federal Law to use this product in a manner inconsistent with its labeling.

practices; users must continue to follow all current infection control practices, including those practices related to cleaning and disinfection of environmental surfaces. This surface has been shown to reduce microbial contamination, but does not necessarily prevent cross contamination.

This surface may be subject to recontamination and the level of active bacteria at any

particular time will depend on the frequency and timing of recontamination and cleanliness of the surface (among other factors). In order to have proper antimicrobial effect, this product must be cleaned and maintained according to the directions for use.

DO NOT WAX, PAINT, LACQUER, VARNISH, OR OTHERWISE COAT THIS PRODUCT.

NOT APPROVED FOR DIRECT FOOD CONTACT OR FOOD PACKAGING USES.

Items exposed to outdoor environmental conditions are not representative of indoor laboratory test conditions, and therefore, may impart reduced efficacy if not cleaned when visibly soiled.

STORAGE AND DISPOSAL: Dispose of by recycling or put in trash.

WARRANTY STATEMENT: If used as intended this product is wear-resistant and the durable antibacterial properties will remain effective for as long as the product remains in place and is used as directed. Global Brass and Copper, Inc Manufactured by: OB-0002-1104 427 N. Shamrock St. [Product Manufacturer] East Alton, IL 62024 [Name Address] www.CUVERRO.com 1-877-311-CUVERRO(2883) EPA Reg No 85353-2 EPA Est No. XXXXX-XX-XXX

Figure 4: CuVerro II Fabricated Product Label - Insert

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III. CuVerro III Label

Touch surface made from

® CuVerro III Antimicrobial Copper Surface Active Ingredient: Copper………………………… 82.6% Other: …………………………………………………………….………… 17.4% Total……………………………………………………………………….…… 100.0% EPA Reg No.85353-3 EPA Est No. XXXXX-XX-XXX Net Weight: XXX lbs XXX oz of CuVerro® III See Insert for Directions for Use

Figure 5: CuVerro III Fabricated Product Label – Front

® This product is made out of a copper surface that continuously kills bacteria left behind by dirty hands, CuVerro III Antimicrobial Copper Surface killing more than 99.9% of bacteria* within 2 hours.