DEA Form

Dear Customer:

As you may already know, in 1988, the United States Congress passed the Chemical Diversion and Trafficking Act. It has been supplemented by the Comprehensive Methamphetamine Control Act of 1996. These Acts impose requirements on companies that manufacture, import, export, and/or sell domestically certain chemicals that could be diverted to make illegal drugs. The acts were passed in response to Drug Enforcement Administration concerns that these chemicals, which of course have many legitimate uses, are being diverted to the illegal manufacture of drugs such as cocaine, heroin, speed, and PCP. DEA has the authority to add more chemicals to the list at any time. We are sending this letter to you because our records indicate that you purchase one or more of the listed chemicals from us.

Among the requirements imposed by the Act on sellers of the listed chemicals are the following: 1) The seller must keep records of the buyer to verify that this is a viable business operation. The seller must also keep records of the date, quantity, and method of transfer. 2) The seller must report to the DEA any suspicious purchases and/or unusual or excessive losses of listed chemicals. 3) Importers and exporters of the listed chemicals are required to keep certain records and make certain reports.

In connection with the first requirement above, GFS Chemicals, Inc. must have on file a list of your personnel authorized to place an order for the chemicals listed. The regulation requires that the list be updated annually. We will not be able to sell any of the listed chemicals unless we have the list, nor will we be able to accept orders from any of your employees who are not on the list or who are not otherwise officially identified to us in writing as your authorized purchasing agent.

List I Chemicals,Name* Item Number
Ethylamine 2743
Hydriodic acid 623, 2399
Benzaldehyde 1070
Hypophosphorus Acid 933
Calcium hypophosphite A1488
Sodium hypophosphite 1194
Iodine and solutions
containing iodine
723, 2748, 3568, 1163, 2073,
1600, 1601, 1603, 1604,
1616, 1620
List II Chemicals, Name Item Number
Acetic anhydride 714
Acetone 828, 829, 1232, 2481
Benzyl chloride 5389
Ethyl Ether 916, 917, 1238, 2496
Potassium permanganate 556 ,1693, 1931, 3645
Methyl ethyl ketone (2-Butanone) 959, 1980
4-Methyl-2-pentanone (MIBK) 960
Sodium permanganate 5219
Toluene 1052, 1245, 2347,
2493

* Chemicals included in the GFS Chemicals’ DEA Registration. This is not the entirety of List I Chemicals.

Accordingly, we ask that you provide the list to us at your earliest convenience, either by fax or to the address listed in the letterhead, but in any case no later than 30 days from now.

We apologize for any inconvenience this annual requirement may cause you; however, DEA has indicated that it is requiring the lists to be compiled for all customers regardless of how long a relationship we have enjoyed with you. The penalties for violation of these requirements are substantial. GFS Chemicals, Inc. thanks you in advance for your anticipated cooperation in this matter. Should you have any questions regarding the new law and regulations, please contact the DEA at (202) 307-7297. Should you have any questions regarding the list that you are submitting to us, please feel free to contact the undersigned at (740) 881-5501 or (800) 858-9682.

Best regards,

Mark D. Mellum Regulatory Compliance Manager

Return to GFS Chemicals, Inc.: email [email protected]; fax 740-881-5989; mail: P.O. Box 245, Powell, OH 43065

SUBJECT : DEA LETTER OF COMPLIANCE

Dear GFS Chemicals:

In response to your recent DEA letter, listed below are our personnel authorized to purchase DEA listed chemicals for our company.