Keith Roberts 

Roberts Proprietaries, Inc. 

180 West SO'^ St. 

New York, NY 10024 : ;C-,Xl' ^ENT OF 

917-441-8642 keithofrpi@earthrmk.net ;'''^v$,8.TAJI0N oFtmms 

/';i M ?2 P 2-- lU 

Junes, 2011 

Hearing Docket Clerk 

FAA, AGC-430, Suite 2W1000 

Wilbur Wright Building 

800 Independence Ave., SW 

Washington DC 20591 

Re: FAA Case No. 2010SO700318 /PblY) S ^^ l I "0^6 0 

Enclosed please find the original and one copy of Respondent's Motion for 

Decision pursuant to §13.218(f)(5) of CFR Title 14, part 13, subpart C, or in the 

alternative Respondent's Answer. Respondent Covermark USA is the tradenanne 

of Nouveau Laboratories LLC, a wholly owned subsidiary of Roberts 

Proprietaries, Inc. It is domiciled and does business in Northvale, New Jersey. I 

am the President of Roberts Proprietaries, Inc. and am also an attorney. I 

represent the Defendant in this matter. My office is as above, in New York City. 

I therefore request that the hearing, if held, be held in the New York City area. I 

agree that the duration should be one day. Please address all communication in 

this matter to me at the above address. 

Sincen 

Keith Roberts 

President 

Roberts Proprietaries, Inc. 

917-441-8642 

cc: Mr. Gerald Ellis 

DECEIVED 

JUN 2 0 20n 

HEARING DOCKET 
FEDERAL AVIATION ADMINISTRATION, 

Complainant 

V. 

COVERMARK USA 

Respondent 

FAA Docket No. 

MOTION FOR DECISION OR, IN THE ALTERNATIVE, ANSWER 

1. Respondent admits that one shipment consisting of 8 ounces of skin cleansing 

lotion inadvertently violated the various provisions described in paragraphs 1 

through 19 of the Complaint. 

2. The proposed penalty of $10,000 is disproportionate to the violation, ignores 

mitigating circumstances, and would render Respondent's ability to continue in 

business difficult or impossible. Moreover, Respondent has agreed to terminate 

shipment of the product in question, and has taken a suggested course in the 

Shipment of Hazardous Material. Pursuant to 14 CFR §13.218 (f)(5) Respondent 

therefore requests a Decision to find that the shipment, although in violation of 

the Hazardous Substance Act, does not require a civil penalty beyond the actions 

already volunteered and taken. 

A. The violation was inadvertent, and occurred despite Respondent's 

efforts to fit within the exceptions provided under 49 CFR 173.15. 
3. Respondent shipped the bottle of skin cleanser in the good faith mistaken 

belief that it was exempt from the hazardous material regulation by virtue of 

exemption under 49 CFR 173.15. Whereas this good faith mistake does not 

excuse the violation of the regulation, it bears upon the size of the penalty 

proposed. 

4. The Material Safety Data Sheet for the skin cleanser, provided by the contract 

manufacturer of the product, stated that it was classified as a #3 flammable liquid. 

See Exhibit A: Material Safety Data Sheet. 

5. In communication to the FAA, the Respondent stated and provided evidence 

that the percent of SD alcohol 40B was 23.8%. See Exhibit B: Percent of Alcohol. 

6. 49 CFR 173.150 (e)(2) provides that an aqueous solution with less than 24% 

alcohol and 50% or more of water is not subject to the requirements of 49 CFR 

172. In communication to the FAA, the Respondent stated and provided 

evidence that the percent of water by volume in the aqueous solution was greater 

than 50%. See Exhibit C: Percent of Water. 

7. Respondent therefore operated under the belief that the product shipped was 

complaint with FAA regulations by virtue of being excepted under 49 CFR 173.15. 

B. Extremely few shipments of this product travel by air, Respondent has 

offered to terminate the production and shipment of the product, and 

Respondent has at the staff attorney's suggestion taken and completed a 

course in the handling and shipping of hazardous substances. 
8. The skin cleanser is the only product that Respondent ships that constitutes a 

hazardous substance. It is produced and shipped for the benefit of a handful of 

longstanding customers, with total annual shipments in 2010 amounting to 453 

pieces in 2008, 434 in 2009, and 384 in 2010. Only 30 pieces were shipped by 

air in 2010, all to Hawaii where one of these longstanding customers and her 

clients live. See Exhibit D: Sales of CM Beauty Super Clean Toner 

9. Respondent, during the informal hearing, offered to terminate all production 

and shipping of the skin cleanser. See Affidavit 

10. As of April 5, 2011, subsequent to suggestions made by the Regional 

Counsel for the FAA during the informal hearing, Respondent took a course 

recommended by UPS from Lion Technology Inc. and received the HMT-S30 

Hazardous Materials Transportation Certification. This was immediately 

transmitted to the attorney who held the informal hearing. See Exhibit E: 

Certificate 

C. Financially Burdensome 

11. The sales of Covermark USA for the last four years have declined in each 

year, from $942,000 in 2007 to $887,000 in 2010. Sales continue to decline in 

2011. The company's profit in 2009 was a loss of $104,509 and in 2010 it was a 

loss of $18,554. See Exhibit F: Financial Statements 
12. In light of the marginality of the company's operations during this period of 

national economic downturn, the proposed fine of $10,000 renders the possibility 

of profit in 2011 extremely dubious, and jeopardizes the firm's ability to survive. 

THEREFORE, Respondent asks that a finding of violation be issued, but the 

proposed penalty be waived in view of Respondent's completion of the 

Hazardous Materials course and, if desired, on condition that Respondent cease 

production and delivery of CM Beauty Super Clean Toner. 

Respectfully submitted, 

Keith Roberts 

Attorney for Respondent 

LIST OF EXHIBITS 

Exhibit A: Material Safety Data Sheet 

Exhibit B: Percent of Alcohol 

Exhibit C: Percent of Water 

Exhibit D: Sales of CM Beauty Super Clean Toner 

Exhibit E: Certificate 

Exhibit F: Financial Statements 

Affidavit 
FAA Docket No. 

FEDERAL AVIATION ADMINISTRATION, ) 

Complainant 

V. 

COVERMARK USA 

Respondent 

AFFIDAVIT OF KEITH ROBERTS 

1. I am President of the parent company of Covermark Cosmetics, and an 

attorney licensed in the State of New York, and I represent the Respondent in 

this matter. 

2. In February, 2011 I met in Atlanta with Mr. Gerald Ellis, Office of the Regional 

Counsel, for an informal hearing in this matter. 

3. At the meeting, or by mail prior to the meeting, I presented to Mr. Ellis 

documents that showed that only a few hundred pieces of the product in question 

are produced and sold each year, and stated that this was done as an 

accommodation to very long-standing customers. I offered to terminate 

production and sale of the product in question. 
4.1 also represented, and do represent, that the CM Beauty Super Clean Toner 

product is the only one of Covermark's products that is a hazardous substance of 

any sort. 

5. Mr. Ellis strongly suggested that despite our intent to terminate production of 

this product, Covermark should send an executive to a course on the shipment of 

hazardous materials as provided by a qualified supplier whom we could contact 

through shippers that we use like UPS or Federal Express. 

6. As a result, the firm did indeed have its CEO take such a course, for which she 

received a Certificate of Completion in April, and trained the employees of the 

company in such procedures. 

I hereby certify that the above statements are true and correct, to the best of my 

knowledge. 

Date: ^//;rA / 

Keith Roberts 
EXHIBITS A, B&C, D, E, F 
' £^!»/)jfe't~" H I (venerated by l-oxit PUK Creator © l-oxit bottware 

u a- ^ http.V/www.foxitsoftware.com For evaluation only. 

\^'r 

MATERIAL SAFETY DATA SHEET 

SECTION 1 - M>\NUFACTURER 

LECHLER L/BS INC. EMERGENCY TELEPHONE: 

100 RED SCHOOLHOUSE RD. 845-426-6800 

CHES7MUT RID6E, NY 10977 

SECTION 2 - PRODUCT IDENTIFICATION AND COAAPONENTS 

CAS NUMBER: NOT APPLICABLE 

PRODUCT DESIGNATION - "COVERMARK LOL TONERPRODUCT DESCRIPTION - LIQUID SKIN REFRESHER 

MOLECULAR FORMULA - NOT APPLICABLE 

COMPOSITION: WATER, SD ALCOHOL 40B (DENAT.), PROPYLENE GLYCOL, WLTCH 

HAZEL, PANTHENOL, POLYSORBATE 80, TETRASODIUM EDTA, CITRIC ACTD, DMDM 

HYDANTOIN, PROPYLPARABEN. METHYLPARABEN, FRAGRANCE. MAY CONTAIN: FDAC 

BLUE #1 (CI 42090), DAC RED 33 LAKE (CI 17200). 

SECTION 3 - POSSIBLE HAZARDS 

PRIMARY ENTRY ROUTES: SKIN CONTACT 

TARGET ORGANS: NONE 

ACUTE EFFECTS: NONE 

INHALATION: MAY CAUSE IRRITATCON. 

EYE: LIQUID AND VAPOR MAY CAUSE IRRITATION .SPLASHES MAY CAUSE 

TEMPORARY PAIN AND BLURRED VISION. 

SKIN: MAY CAUSE IRRITATION ON PROLONGED CONTACT. 

INGESTION: IN LARGE AMOUNTS, MAY CAUSE DEPRESSION OF THE CENTRAL 

NERVOUS SYSTEM, NAUSEA. 

SECTION 4 - FIRST AID MEASURES 

INHALATION: REMOVE TO FRESH AIR. GET MEDICAL ATTENTION IF BREATHING IS 

DIFFICULT 

SKIN CONTACT: IF IRRITATION OCCURS. SEEK MEDICAL ATTENTION. 

INGESTION: IF SWALLOWED. DRINK COPIOUS AMOUNTS OF WATER. DO NOT 

INDUCE VOMITING. GET PROMPT MEDICAL ATTENTION 

EYE CONTACT: FLUSH WITH LARGE AMOUNTS OF WATER OR MILK. GET MEDICAL 

ATTENTION. 

AFTER FIRST AZO. 6ET APPROPRIATE IN-PLANT, PARAMEDIC, OR COMMUNTT/ 

MEOICAL SUPPORT. 

<//x/'i 
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SECTION 5 - FIRE-FIGHTING MEASURES 

BOIUNG POINT: 190*F 

FLASH POINT: 97*F 

FUSH POINT METHOD: CLOSED CUP 

AUTO IGNITION: N/A 

LEL: N/A 

UEL: N/A 

FLAMMABILTTY CLASSIFICATION: #3 FLAMMABLE LIQUID 

EXTINGUISHING MEDIA: DRY CHEMICAL, ALCOHOL FOAM, C02. WATER MAY BE 

INEFFECTEVE BUT SHOULD BE USED TO KEEP FIRE-EXPOSED CONTAINER COOL. 

UNUSUAL FIRE OR EXPLOSION HAZARDS: ABOVE FLASH POINT, VAPOR-AIR 

MIXTURES ARE EXPLOSIVE. 

HAZARDOUS COMBUSTION: N/A 

FIRE-FIGHTING INSTRUCTIONS: IF LEAK/SPILL HASNT IGNITED, USE WATER 

SPRAY TO DISPERSE VAPOR AND PROTECT PEOPLE ATTEMPTING TO STOP SPILL. IN 

THE EVENT OF FIRE, WEAR FULL PROTECTIVE CLOTHING AND NOISH-APPROVED 

SELF-CONTAINER BREATHING APPARATUS. 

SECTION 6 - ACaDENTAL RELEASE MEASURES 

SPILL/LEAK PROCEDURES: VENTELATE AREA OF LEAK OR SPILL. REMOVE ALL 

SOURCES OF IGNITION. WEAR APPROPRIATE PERSONAL PROTECTIVE EQUIPMENT. 

ISOLATE HAZARD AREA. CONTAIN AND RECOVE LIQUID WHEN POSSIBLE. USE 

NON-SPARKING TOOLS AND EQUIPMENT. COLLECT LIQUID IN AN APPROPRIATE 

CONTAINER OR ABSORB WITH INERT MATERIAL AND PLACE IN CHEMICAL WATER 

CONTAINER. DO NOT FLUSH TO SEWER. 

CONTAINMENT/CLEANUP: FOR LARGE SPILLS, DIKE FAR AHEAD OF LIQUID FOR 

LATER DISPOSAL. DO NOT RELEASE INTO SEWERS OR WATERWAYS. 

REGULATORY REQUIREMENTS: FOLLOW APPLICABLE OSHA REGULATIONS (29 CFR 

1910.120) 

SECTION 7 - HANDLING AND STORAGE 

HANDLING ADVICE: PROTECT AGAINST PHYSICAL DAMAGE. STORE IN A COOL. DRY, 

VENTILATED LOCATCON. KEEP AWAY FROM SPARKS AND FLAME. AVOID CONTACT 

WITH EYES. KEEP CONTAINERS CLOSED. 

STORAGE CONDITIONS: DO NOT STORE WITH STRONG OXIDIZING AGENTS. 

STORE IN PLASTIC. PLASTEC-UNED OR STAINLESS STEEL. DO NOT STORE IN 

HEAT. 
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SECTION a - EXPOSURE CONTROLS AND PERSONAL PROTECTION 

IF HANDLING BULK QUANTCTIES, USE NIOSHA/MSHA APPROVED RESPIRATORY 

PROTECTION, WEAR GLOVES AND PROTECTIVE CLOTHING. 

IF HANDLING PACKAGED PRODUCTS, NORMAL HANDLING PRECAUTIONS AND 

STORAGE SHOULD BE FOLLOWED; NO SPECIAL SAFET/ WEAR SHOULD BE 

NECESSARY. 

SECTION 9 - PHYSICAL AND CHEMICAL PROPERTIES 

PHYSICAL STATE: PIGMENTED SOLUTION 

FLASH POINT: 97*'F 

SPEaFIC GRAVITY 1.0150-1.0250 

pH: 7.9 

SOLUBILITY I N WATER: SOLUBLE 

APPEARANCE: PIGMENTED CLEAR LIQUID 

SECTION 10 - STABILITY AND REACTIVITY 

POLYMERIZATION: HAZARDOUS POLYMERIZATION CANNOT OCCUR. 

CHEMICAL INCOMPATIBILITIES: STRONG OXIDANTS, SILVER SALTS, ACID 

CHLORIDES, ALKALI METALS. METAL HYDRIDES 

HAZARDOUS DECOMPOSmON PRODUCTS: CARBON DIOXIDE. CARBON MONOXIDE 

SECTEON 11 - TOXICOLOGICAL INFORMATION 

THIS PRODUCT HAS NOT BEEN TESTED FOR CHRONIC EFFECTS; IT IS JUDGED AS 

HAVING A LOW ORDER OF TOXICITY BASED ON COMPONENT INFORMATION. USE 

OF GOOD INDUSTRIAL HYGIENE PRACTICES IS RECOMMENDED. 

SECTION 12 - ECOLOGICAL INFORMATION 

ECOTOXICITY: NOT DETERMINED 

ENVIRONMENTAL FATE: NOT DETERMINED 

ENVIRONMENTAL DEGREDATION: READILY BIODEGRADES. EVAPORATES INTO 

MODERATE EXTENT, DOES NOT BIOACCUMALATE. 

SOIL ABSORPTION/MOBILITY: READILY BIODEGRADES, QUICKLY EVAPORATES, 

LEACHES INTO GROUND WATER. 
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SECTION 13 - DISPOSAL CONSIDERATIONS 

DISPOSAL: CONTACT YOUR SUPPLIER OR A LICENSED CONTRACTOR FOR DETAILED 

RECOMMENDATIONS. FOLLOW APPLICABLE FEDERAL, STATE AND LOCAL 

REGULATIONS. 

SECTION 14 - TRANSPORT INFORMATION 

DOT TRANSPORTATION DATA (49 CFR 172.101): 

SHIPPING NAAAE: (ETHANOL SOLUTION) 

HAZARD CLASS: 3 FLAMMABLE LIQUID 

IDJSK3. UN1170 

PACKING GROUP: I I 

LABEL: 3 FLAMMABLE LIQUID 

SPECIAL PROVISIONS (172.102): 

PACKING AUTHORIZATIONS: 

A) EXCEPTIONS: 173.00 

B) NON-BULK PACKAGING: 173.00 

C) BUU PACKAGING: 173.00 

SECTION 15 - REGULATORY INFORMATION 

TSCA: THIS PRODUCT CONTAINS INGREDIENTS LISTED IN THE TSCA INVENTORY 

OF CHEMICAL SUBSTANCES. 

THE INFORMATION GIVEN AND RECOMMENDATIONS MADE HEREIN APPLY TO OUR 

PRODUCT ALONE, NOT COMBINED WITH OTHER PRODUCTS. THIS DATA IS 

BELIEVED TO BE ACCURATE; HOWEVER, IT IS THE PURCHASER'S RESPONSIBILITY 

BEFORE USING THE PRODUCT TO VERIFY THIS DATA UNDER THEIR OWN 

OPERATING CONDITIONS AND TO DETERMINE WHETHER THE PRODUCT IS 

SUITABLE FOR THEIR PURPOSES. 

SECTION 16 - OTHER INFORMATION 

PRODUCT USE: COSMETIC 

AASDS DATE: 1/15/10 
http://us.nig2.mail.yahoo.corrv'clc/laiinch?.g)c=l&.rand=4clqqvosjnK): 

From: Jimmy Varghese (jvarghese@Iechlerlabs.com) 

To: covermark@yahoo.com; 

Date: Mon, August 30,2010 4:02:14 PM 

Cc: 

Subject: RE: LOL MSDS 

Hi Rachel, 

The percentage of water s 59.03%. 

^immu \/argnese 

Research & Development Director 

LECHLER LAB S / MEHRO N INC. 

100 Red Schoolhouse Rd. 

Chestnut Ridge, NY 10977 

ivarahese&iechlerlabs. com 

(845)-426-6800 

(845)-426-1515 (Fax) 

www.mehron.com 

www. lechlerlabs. com 

From: rachele-covemiark cosmetics [mallto:oovennar1(@yahoo.com] 

Sent: Monday, August 30, 2010 3:39 PM 

To: Jimmy Varghese 

Subject: Re: LOL MSDS 

Hi Jimmy, 

Now I need the % of water by volimie. 

Sorry arid thanks again... 

Rachele 

From: Jimmy Varghese <jvarghese@lechlerlabs.com> 

To: rachele-covermark cosmetics <covermark@yahoo.com> 

Sent: Mon, August 30, 2010 2:22:58 PM 

Subject: RE: LOL MSDS 

Hi Rachel, 

The percentage is 23.8% of SD Alcohol 40B in the formulation. Thanks. 

^immif ^argnese 

Research & Development Director 

LECHLER LAB S y MEHRO N INC . 

100 Red Schoolhouse Rd. 

Chestnut Ridge, NY 10977 

ivarahese0jechlerlabs. com 

(845)-426-6800 

(845)'426-1515 (Fax) 

www.mehron.com 

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