Dykema

April 7, 2016
By e-mail (pdf): [email protected]

Associate Administrator for Enforcement
National Highway Traffic Safety Administration
Attn: Early Warning Division (NVS-217)

1200 New Jersey Ave., SE 20590

Dykema Gossett PLLC

Franklin Square, Third Floor West
1300 | Street N.W.

Washington, DC 20005
WWW.DYKEMA.COM

Tel: (202) 906-8600
Fax: (202) 906-8669

Paul M. Laurenza
Direct Dial: (202) 906-8646
Email: [email protected]

Re: — Pennzoil-Quaker State Company dba SOPUS Products

Dear Administrator:

On behalf of Pennzoil-Quaker State Company dba SOPUS Products, please see attached

documents pursuant to 49 CFR 579.5.

Very truly yours,

__DYKEMA GOSSETT Piic

Paul M. Laurenza

Enclosures

California | Illinois | Michigan | Minnesota | Texas | Washington, D.C.
From: Barrett, Courtneye D SLUBE-DIU/82

Sent: Friday, March 25, 2016 3:36 PM

To: Americas Lubricants News Desk

Cc: Moser, Don D SLUBE-DIU/824; Barrett, Courtneye D SLUBE-DIU/82
Subject: PLEASE READ: Shell ROTELLA Ultra ELC 50/50 Pre-diluted Antifreeze/Engine Coolant Product Return Program

Dear SOPUS Products Customer or Distributor:

SOPUS Products places great importance on providing quality products that meet all federal and state regulations. As
such, SOPUS Products is requesting the return of all batches of one gallon bottles and 55-gallon drums of Shell
ROTELLA Ultra ELC 50/50 Pre-diluted Antifreeze/Engine Coolant and one batch (B2811293U063/30Sept15) of 55-
gallon drums of Shell ROTELLA Ultra ELC Antifreeze/Coolant Concentrate currently in the marketplace because these
products were undertreated with bitterant, an additive used to render the product unpalatable. Both of these products
are formulated to be extended-life antifreeze/coolants in the heavy-duty engines found in on- and off-highway vehicles,
and in marine, farm, mining and construction equipment. You have received this email because our records indicate that
you have purchased one or both of the affected products.

After reviewing the details in the attached letter, please locate and remove any affected products from your inventory
and segregate them from saleable products, marking them for return/recycle to prevent unintended sale. (Please note:
if any of these products are already installed in a cooling system, they do not need to be drained or replaced; it is
important to note that the lack of bitterant has no impact on product performance. The Shell ROTELLA Ultra ELC 50/50
Pre-diluted Antifreeze/Coolant does have warnings on the label and child-resistant closures.)

Also attached is a letter template for notifying your customers of this issue. For customers that sell Shell ROTELLA Ultra
ELC 50/50 Pre-diluted Antifreeze/Engine Coolant at retail locations, we have attached a notice that can be printed and
posted near the cash register or on-shelf to help reach consumers. Later today, we will reach out to relevant trade
media in a further effort to reach end-users. We have also set up a website to manage customer and consumer inquiries
around this issue: http://rotella.shell.com/products/shell-rotella-ultra-elc-product-return.html.

We regret any inconvenience this request may cause you, and we appreciate your help in locating and quarantining the
affected product. We recognize that this is a holiday weekend, so to ensure that you receive this information, we will re-
send it to you on Monday morning.

If you have any questions, please contact your SOPUS Products account manager.

Kind regards,

Courtneye Barrett
Courtneye D. Barrett
Network Communications Consultant
Shell Lubricants Americas

One Shell Plaza, Houston, Texas
office: 713-241-5895

mobile: 832-205-6386
courtneye.barrett@shell.com
SOPUS Products
910 Louisiana St.
Houston, TX 77002

Internet http://www. shell.com

Match 25, 2016

Dear SOPUS Products Customer:

SOPUS Products is initiating a product return program for the following products currently in the
marketplace because these products were undertreated with bitterant, an additive used to render the product
unpalatable. The Shell ROTELLA Ultra ELC 50/50 Pre-diluted Antifreeze/Coolant does have warnings on

the label and child-resistant closures.

© One gallon bottles of Shell ROTELLA Ultra ELC 50/50 Pre-diluted Antifreeze/Engine Coolant ---
ALL BATCHES

e 55-gallon drums of Shell ROTELLA Ultra ELC 50/50 Pre-diluted Antifreeze/Engine Coolant ---
ALL BATCHES

e Shell ROTELLA Ultra ELC Antifreeze/Coolant Concentrate sold in 55-gallon drums -Batch
Number B2811293U063/30Sept15 (SOPUS Products Material # is 550022381)

This issue is not related to the performance of any of these products. If any of these products have already
been installed in a cooling system, they will provide the intended performance benefits and do not need to be
drained or replaced.

As part of the product return process, our customer operation team has created a return policy for a return of
product. Full details are available by visiting www.totella.com/productreturn or product return can be started
by following the steps below.

1. Contact SOPUS Products Customer Service Center (CSC) to submit a return order.

2. Specify the SKUs and quantities to be returned as well as the Account Number for the location
where the product will need to be picked up from.

3. Inform the CSC representative that the return is due to the issue with:

a. One gallon bottles of Shell ROTELLA Ultra ELC 50/50 Pre-diluted Antifreeze/Engine
Coolant - ALL BATCHES; and/or

b. 55-gallon drums of Shell ROTELLA Ultra ELC 50/50 Pre-diluted Antifreeze/Engine
Coolant - ALL BATCHES; and/or

c. Shell ROTELLA Ultra ELC Antifreeze/Coolant Concentrate sold in 55-gallon drums -
Batch Number B2811293U063/30Sept15 (SOPUS Products Material # is 550022381)

4. The CSC Representative will then provide details for product pick-up or recycle, and return credit.

In the meantime, we ask that you locate and remove these specific products from your inventory and
segregate them from saleable products marking it for return/recycle to prevent unintended sale.
SOPUS Products Customers
Match 25, 2016

We regret any inconvenience this request may cause you, and we appreciate your help in locating and

quarantining the affected product.

If you have any questions about this situation, please contact your SOPUS Products account manager.

Sincerely,

1 for

Rusty Barron

Vice President, North America Marketing
SOPUS Products

Page 2 of 2
Shell ROTELLA Ultra ELC Extended Life Engine Coolant/Antifreeze Product Return Program

Letter Template for Alerting Customers’/Distributors’ Customers

March 25, 2016

Dear Customer:

SOPUS Products is initiating a product return program for the following products currently in the
marketplace because these products were undertreated with bitterant, an additive used to render the product
unpalatable. The Shell ROTELLA Ultra ELC 50/50 Pre-diluted Antifreeze/Coolant does have warnings on
the label and child-resistant closures.

e One gallon bottles of Shell ROTELLA Ultra ELC 50/50 Pre-diluted Antifreeze/Engine Coolant -
ALL BATCHES

e 55-gallon drums of Shell ROTELLA Ultra ELC 50/50 Pre-diluted Antifreeze/Engine Coolant - ALL
BATCHES

e Shell ROTELLA Ultra ELC Antifreeze/Coolant Concentrate sold in 55-gallon drums- Batch
Number B2811293U063/30Sept15 (SOPUS Products Material # is 550022381)

This issue is not related to the performance of any of these products. If any of these products have already
been installed in a cooling system, they will provide the intended performance benefits and do not need to be
drained or replaced.

As part of the product return process, we ask that you locate and remove these specific products from your
inventory and segregate them from saleable products marking it for return/recycle to prevent unintended
sale.

[If the customer purchased the product from a distributor, they should follow the distributor's return process.
Please insert the Distributor return instructions here]

We regret any inconvenience this request may cause you, and we appreciate your help in locating and
quarantining the affected product.

If you have any questions about this situation, please contact at

Sincerely,

Shell

ROTELLA ULTRA EC
EXTENDED LIFE

Have you purchased any one gallon bottles of Shell
ROTELLA Ultra ELC 50/50 Pre-diluted
Antifreeze/Coolant recently?

If so, please call 1-855-302-4572 or visit
www.shellrotella.com for important product
information because the product was undertreated
with bitterant. Bitterant is an additive intended to
make the product unpalatable. The Shell ROTELLA
Ultra ELC 50/50 Pre-diluted Antifreeze/Coolant does
have warnings on the label and child-resistant
closures.

If the product is already installed in a cooling system,
it is important to note that the lack of bitterant has
no impact on product performance, and the product
does not need to be drained or replaced.
Shell Rotella Facebook

March 25, 2016

DIOP ES Prodacs is pequesiing fete of all balches of one Galen Dotoes
and So-qaten Grurms of Shell ROTELLA Uira ELC Boue> Presiced
Anitreqie Engine Ooclant art one batch (2S 1129S UGE aoSeptio) of
2-daen drums of She SOTELLA ere ELC Anttresze Cookin!
COOH e CNTehy if ie (ialne place Dik use Wiese products were
undertrested wih bileranl an ec@ilive used to render the produc!
unpalatable

ee
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The groducts are Tontwiaied to be extended-ite ae
hemey-culy eqcines tout in oe ane ot neiety
farm. mime apd cornsyucbes egupment

Baby of hese products ate aiready Weta in a COORG svete, ey de
Ag: feed to be rained OF renlaced: 1G eodrian Io note [hal Hee lace af
Gitenant has no erp! on product performance The Shel ROTELLA
Ulva ELC DOS0 Pred iuted Aitrerre Coolan! does have wanungs on ihe
late and chd-resetant Closures.

Here 18 aw remaining of whuned IeGduc!, we are Pec oramendiig hal
thie produc be Mentied and moved lo 4 sale, ampentree me alion m
precaration for petarn or recycle

ieee ss whe hove produc! mh Thel Goaseseian Ghoul wide

Ween ROTELLA Com pntur ein 19 Degen a Clam process. Open
producti should Then be Laken to leew local fecyc ing Taciey Of auto pars
siore to be recycled Additional meiructions around recycling can be found
al ww ie e t ee figies

Me Cle i

Shell ROTELLA® Ultra ELC Product Return

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Shell Rotella Twitter

March 25, 2016

Shell
ROTELLA

Shell Rotella ©

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Tweets Tweets & replies Photes & videos

Shell Rotella e000 tat 2

Shell Rotella® engine ols help hard forme Product return of all ROTELLA Ultra ELC 50/50 Coolant gallon bottles
working peaple keep their trucks and : No harm to coolant systems Details bit iy tL Nconp
" equipment operating propery For more

Information vise (otek coer

Wow summary
Shell ROTELLA Ultra ELC Extended Life Antifreeze/Coolant Product Return
Information Sheet
March 31, 2016

SOPUS Products is initiating a product return for all batches of one gallon bottles and 55-gallon drums of Shell ROTELLA
Ultra ELC 50/50 Pre-diluted Antifreeze/Engine Coolant and one batch (B2811293U063/30Sept15) of 55-gallon drums of
Shell ROTELLA Ultra ELC Antifreeze/Coolant Concentrate currently in the marketplace because these products were
undertreated with bitterant, an additive used to render the product unpalatable.

Shell ROTELLA Ultra ELC 50/50 Pre-diluted and Shell ROTELLA Ultra ELC Concentrate Antifreeze/Engine Coolants are
formulated to be extended-life antifreeze/coolants in the heavy-duty engine cooling systems found in on- and off-highway
vehicles, and in marine, farm, mining and construction equipment.

Q&As:
What does the affected product bottle look like?

What is the issue with these products?
These products were undertreated with bitterant, an additive used to render the product unpalatable.

What is bitterant?
Bitterant is a chemical compound added to anti-freeze/coolant to make the product unpalatable (make it taste bad).

What should we do with the Shell ROTELLA Ultra ELC 50/50 Pre-Diluted Antifreeze in our possession?
e Return kit(s) (boxes and return labels) will be sent to each location for the affected product.

If you do not receive a return kit by April 16, 2016 call +1-855-302-4572 to have a return kit shipped to your location. Have
the following information ready:
e Full Business name and address
® Contact information for your location
® Quantity of unopened product in your possession
e Any open product should then be taken to their local recycling facility or auto parts store to be recycled. Additional
instructions around recycling can be found at www.earth911.com/recycling-guide/how-to-recycle-automotive-

fluids/.

*** Affected product should be pulled off the shelf and quarantined until the return kit is received.***

e Once the return kit is received:
@ Pack unopened product (6) to a box
e Securely seal each box with packing tape
e Securely affix a postage paid UPS return label to each box (to be provided to you)
e Send the closed boxes via UPS to the address on the UPS label. Call your local UPS office to arrange pick up.

¢ If you have any questions about this process, please call +1-855-302-4572

Thank you for your cooperation.