Appendix IIa: Guidance Document

Section 1.0 General 1.a This section gathers basic information on the facility being audited, including contact information and NAICS (North American Industry Classification System) codes, which may be obtained from the North American Industry Classification System Manual. The manual is a classification system used by government and industry covering the entire field of economic activities and defines industries by classification. The last publication of this manual was in 1997. It is sold by the National Technical Information Services, 5285 Port Royal Road, Springfield, VA 22161, USA. Order No. PB87-100012. If no classification code is available for the principle products manufactured by the factories being audited, auditors could refer to the information listed in provision 1e of Appendix II Auditor Checklist. 1.b 1.c This section requests an organizational chart for the facility being audited. This section determines the maximum and minimum number of personnel in the facility being audited within a calendar year. 1.d This section provides information as to what language(s) are spoken at the facility being audited for purposes of proper staffing of the audit team. 1.e 1.f This section determines the type of production processes in the facility being audited. This section requests a schematic layout of the floor plan of the facility being audited.

Section 2.0 Working Hours 2.1 The facility should have access to the local laws on the subject of working hours for the respective country/region The facility should have a written policy and/or procedure on the subject of working hours and overtime. Record the date of issue. Compare the working hours allowed by the policy to the working hours allowed by the local law to determine if the standard legal requirement is met. Record both for reference purposes. The dates of the law and written policy should be compared to make certain that current policy is appropriate. 2.2 The legal working hours and the facility working hours should be posted and/or made available to all employees. 2.3 Time worked for each non-supervisory employee should be documented through the use of a time card or other mutually worker/management verified documentation. 2.4 Overtime should be worked on a voluntary basis. For example, this may be accomplished by worker acknowledgement and agreement of overtime expectations during the hiring process. Document overtime procedures. 2.5 Determine what the maximum number of working hours is per day and per week. The number of working hours per day and per week should be within legal requirements and the companys written

policy. In the absence of a legal standard, a factory worker should not work in excess of 66 hours per week. 2.6 Determine what the maximum number of working hours is per month. The number of overtime hours worked per month should be within legal requirements and the companys written policy. In the absence of a legal maximum for hours worked per month, this section is not applicable. 2.7 Workers are entitled to one day off in seven. If local law allows, this does not prohibit a worker from voluntarily working overtime on a rest day(s). 2.8 Employees should be permitted time off if they are sick. It is reasonable for employees to provide evidence of illness by producing a doctors note justifying the absence. 2.9 It is expected that workers are permitted to take one main meal break per shift. Normally, 30 minutes would be considered adequate for a main meal break. Less than 30 minutes requires further explanation. It is expected that workers be permitted to take personal breaks for the use of the toilet and for drinking water.

Section 3.0 Wages and Compensation 3.1 The facility should have access to the local laws on the subject of minimum wages and compensation requirements for work. The minimum legal wage as per the local regulations should be followed at a minimum. Record the minimum legal wage for the respective country/region. The facility should have a written policy and/or procedure on the subject of wages and compensation. Record the date of issue. Compare the wages and compensation allowed by the policy to the wages and compensation required by the local law to determine if the standard legal requirement is met. Record both for reference purposes. The dates of the law and written policy should be compared to make certain that current policy is appropriate. 3.2 The company policy and/or procedure on wages and compensation, in the local language, should be posted and/or made available to all employees. 3.3 The wages and compensation being paid by the facility should meet legal requirements for normal and overtime work. The dates of the law and written policy should be compared to wage and compensation payment records to make certain that information being recorded is current. If paid piece rate, employees wages, at a minimum, must be equivalent to minimum wage rates. Include hourly, daily, weekly or monthly rate, as applicable. Determine if overtime is part of normal workweek or on which days overtime is worked. Record details. Calculation Example (using hypothetical number (in bold) of holidays, non-work days, etc.; auditor should use correct number based on location of factory.) Step 1- Determine the legal monthly minimum wage. In our example we will use currency Z 400 as the legal monthly minimum wage.

Step 2- Subtract the number of annual holidays (10) and the number of non-work days weekend days (104) from the total number of days in the year. In our case it would be 365-10 holidays-104 non-work days= 251 work days. (365-10-104=251) Step 3- Divide the number of workdays by the number of months. 251/12= 20.92 average workdays of 8 hours in each month. Step 4- Multiply 20.92 days by 8 hours = 167.35 hours per month. Step 5- Divide the legal monthly minimum wage (Z 400) by the total hours per month (167.35) = Z 2.39. Overtime calculation: a. b. c. Minimum legal monthly wage divided by 167.35 = normal time hourly rate. Multiply normal time hourly rate by 1.5 = normal overtime hourly rate. Multiply this number by 1.333 = double time hourly rate for normal Saturday and Sunday overtime work. d. Multiply this number by 1.5 = hourly rate for holidays

3.4

Legally required withholdings should be made. Withholdings should be correct and properly paid to the respective agency(s). For example, these could include taxes, retirement, social security, pension, etc.

3.5

Employees should be made aware of withholdings and other deductions from wages prior to employment. This can be evidenced by employee contracts and verification of receipt and/or knowledge of the facilitys policy, which should subscribe to local law requirements as a minimum standard.

3.6

Deductions made from wages for food and housing must be legally allowable and reasonable. In the absence of a law, charges for food and housing in excess of 50% of minimum wage (excluding overtime and bonuses), should be thoroughly investigated.

3.7

Deposits for company provided items such as security deposits for personal protective equipment (PPE), uniforms, and identification cards are not allowable. However, the cost of replacement items, if lost by the employee, as well as any lost identification card or lost uniform, may be charged to the employee at no more than cost.

3.8

Legally required benefits should be provided to the employees. These benefits may include medical insurance, bonus, vacation time, etc. Document details of findings.

3.9

The facility should provide pay stubs to the employees, which clearly shows gross wages, regular hours worked, overtime hours worked, withholdings, and deductions made. In the case of piece rate system, it is recommended that the legal minimum wage equivalent is shown along with the piece rate details.

3.10

Employees should be paid in a timely manner, which is considered to be not more than 30 days following

the work period. 3.11 Wages should be made readily available to employees in the form of cash, check from a local bank, or directly deposited to the employees account.

Section 4.0 Underage Labor 4.1 For informational purposes, determine if there is a compulsory age for schooling. Record what the compulsory age for school attendance is in the respective country/region 4.2 The facility should have access to the local laws on the subject of legal minimum working age, which should be in accordance with C138 Minimum Age Convention of the International Labour Organization. Check that no one under the minimum legal age for work or mandatory schooling is employed. Where local minimum age law is set at 14 years of age, the conditions for developing country exceptions of ILO Convention C138 will apply. The facility should have a written policy on the subject of minimum age to work. Compare the age allowed by the policy to the age allowed by the local laws to determine if the standard requirement is met. Record both for reference purposes. The dates of the laws and written policy should be compared to make certain that current policy is appropriate. 4.3 If there is no legal minimum age, the ICTI Code of Business Practices has established 14 as the minimum age, when in accordance with ILO Convention C138. 4.4 Determine if the law and/or policy has been communicated and generally understood by all employees. Acceptable means of communications include verbally (prior and/or on commencement of employment) and visibly displayed to workers, e.g. on notice boards or in libraries. 4.5 Select a minimum of three of the workers youngest in appearance. Review their identification cards for their age. Record this information. 4.6 A young worker is defined as one above the minimum age, and typically below the age of 18. If there are legal work restrictions for employees of certain ages, they should be followed. There may be restrictions, for example, working on heavy machinery, night work, overtime, etc. 4.7 Ages of employees should be on file. Review the employee files and support documentation. Compare the employee records on file to worker identification cards. Record what types of information are kept on file to verify age of employee.

Section 5.0 5a. Forced Labor 5.1 The facility should have access to the local laws on the subject of forced labor for the respective country/region. Record the date of the local law on file. The facility should have a written policy that supports the ICTI codes position that no forced labor shall be used. Record the date of issue.

5.2

Workers should be voluntarily employed. Check that no forced labor is employed Determine if there are unreasonable restrictions placed on the employees relating to their freedom of movement. Check that workers are free to leave the factory site once their shift ends. Determine if the employees are permitted to take their meal breaks and/or rest breaks as scheduled. Determine if the employees are permitted to freely enter and exit from their housing facilities during their non-work hours and within curfew hours Check that guards are posted only for normal security reasons. Check that workers are not required to lodge unreasonable deposits or ID papers and may leave after giving reasonable notice. Check if the factory holds any identity cards. Determine if these are given on a voluntary basis and are returned to workers on request. Randomly select a minimum of three workers. Review their identification cards and employee files to determine if they are present voluntarily. Record this information.

5.3

The facility should not use bonded labor. Determine if there are unreasonable contracts based on indebtedness of worker families or contracts with significant financial repercussions or paybacks, which force the individual to work against their will to repay their debts.

5.4

Reasonable notice is that defined by law or, in the absence of local law, the length of interval between payments to the worker. For example, if workers are paid every 30 days, 30 days would constitute reasonable notice.

5.5

Security personnel and supervisors should not force or coerce workers. Normally, security staff should be present for the purpose of preventing unauthorized persons and vehicles from entering and exiting the site and to guard against theft at the site. Security staff should not be used to restrict movement or force employees to work.

Section 5.0 5b. Prison Labor 5.6 The facility should have a written policy and/or procedure on the subject of prison labor, both in their facility and subcontracting to prisons or facilities where prison labor is used. The dates of the law and written policy should be compared to make certain that current policy is appropriate. Record the date of issue. Compare the subcontracting policy to the facilitys own on the subject of prison labor requirements. Record details. . 5.7 Neither the facility nor its subcontractor sites should use prison labor. Determine if the facility uses prison labor.

Section 6.0 Disciplinary Practices 6.1 The facility should have access to any local laws on the subject of disciplinary practices for the respective country/region. The facility must have a written procedure, which includes freedom from mental and physical abuse. The procedure should address, at a minimum, fines, formal warning procedures, grounds for contract termination, guidance on unacceptable behavior, appropriate disciplinary actions for

unacceptable behavior, and complaint procedure including method of investigation and resultant actions. 6.2 Determine if the procedure has been communicated and generally understood by all employees. Acceptable means of communication include verbal (prior and/or on commencement of employment) and readily available to workers, e.g. on notice boards, in libraries, or in an employee handbook. 6.3 Corporal punishment and physical coercion should not be used. Any verbal or visual indication of injury should be corroborated /investigated through the use of records or other objective evidence. 6.4 The facility should not allow threatening behavior of any kind. Examples of unacceptable behavior would be gestures, abusive language, and physical contact, that is threatening, abusive, or exploitative. Observe interaction between management and subordinates and between fellow workers. 6.5 Disciplinary measures should be taken through normal management practices. The security staff should not be used to issue discipline to workers. Check security staff contracts for assigned duties and responsibilities. Interview security staff regarding their duties. Determine who is responsible for administering discipline and the extent of their responsibilities. 6.6 Disciplinary fines must be legally allowable, in line with the facilitys policy, and reasonable. Where fines have been used, the auditor should record the amount of the fine and the corresponding offence. Any fines that exceed the legal maximum should be explained.

Section 7.0 Discrimination

(Explanatory Note for this Section: Regarding the discrimination in the facility, special attention should be paid to the current situation and business environment in the countries where factories would be audited. Employees from overseas, say the United States, working in these countries carrying out the same level of work are paid in different wage levels and welfare when comparing with the employees from these countries. It is not a matter of discrimination but truly reflect the difference between their living standards of home country.)
7.1 The facility should have access to the local laws on the subject of discrimination in the workplace. The facility should have a written policy and/or procedure on the subject of discrimination and be posted and/or made available to all employees in the local language. Record the date of issue. The policy should comply with the local laws, covering, for instance, discrimination in hiring, compensation, access to training, promotion, termination, or retirement, or any other aspect of employment based on race, caste, national origin, religion, age, disability, gender, marital status, pregnancy, sexual orientation, union membership or political affiliation. 7.2 Facilities should follow local and national laws regarding discriminatory employment practices. There should be no evidence of discrimination in recruitment practices. Through interviews with the recruitment personnel, and checks on recruitment documentation, there should be no indication of patterns of discriminatory practices. Check wage records for evidence of discrimination; e.g. differing wage levels or fines for different groups carrying out the same level of work (this does not include wage

differences for expatriate workers). Check promotion/demotion records. Check to ensure workers are able to observe legal religious holidays. Check for evidence of harassment (including sexual harassment), coercion or threatening behaviour towards specific groups of workers. Check that there is a mechanism for filing of complaints about discrimination. Check that records exist and that these complaints have been effectively addressed. There should be no discrimination in termination. Check termination records for patterns of discriminatory dismissal. Reasons for dismissal should be documented.

Section 8.0 Employee Representation 8.1 Employees should have the ability to approach management on issues of concern without fear of retribution. Various ways in which employees could approach management include trade unions, employee committees (grievance, safety, etc.), or employee selected representatives, regular meetings, etc. 8.2 There should be representative(s) of the employees, who are freely selected and participate voluntarily and communicate with management on related issues. Employee representations should be representative of the plant population including workers. 8.3 There should be management representative(s) designated to interface and communicate with the employee representative(s) on related issues. Management representation should be the same personnel or same identified authority. 8.4 Meetings should be scheduled between management and employee representative(s) on a regular basis, at least quarterly. Meeting minutes should be on file. 8.5 Employee representative(s) should be aware of the ICTI Code of Business Practices and its supporting documents. This may be accomplished through the facility issuing its own policies and/or procedures to be in compliance with the ICTI Code, in which case this would be considered the facilitys equivalent documentation. 8.6 Management should review and consider issues of employee concerns relating to the ICTI Code of Business Practices, when brought to their attention. Some examples of systems, which would accomplish this, would be an employee grievance procedure or suggestion system. There should be objective evidence that management takes appropriate action on such matters. 8.7 Employee representatives should be treated equally with all other employees. Assessment may include information obtained from employment records (e.g., disciplinary notices, termination, fines, type of work assigned) and employee interviews

Section 9.0 Facilities 9.1 The facility should have access to, and a system to remain current with the local laws and have

developed a policy statement on the subjects of health, safety, environmental, and working conditions, indicating managements commitment to following local laws at a minimum. The policy statement should be signed by the senior manager of the facility. 9.2 There should be a senior management representative(s) responsible for matters of health, safety, welfare, and general facilities. 9.3 All areas should appear generally clean and in good condition. General housekeeping conditions of a facility are a good indicator as to how the facility is operating as it relates to keeping areas safe for its employees. Dust, shavings, and scrap material generated during operations should be collected in appropriate receptacles and disposed of in a timely manner. Engineering controls such as dust collection systems or automatic scrap collection systems should be provided where practicable at the source. Walkways should be kept clear of stored materials, tools and equipment. Walkways should be free of tripping hazards such as debris, scrap, cables, hoses, rope, chains, etc. Walkways should be free of slipping hazards such as oil, grease, water, papers, granular materials, etc. Pay particular attention to slipping and tripping hazards in the area at the top of stairs. Manufacturing, storage, and yard areas should be free of debris, scrap, refuse, garbage and other foreign matter. 9.4 Facility housekeeping inspections should be conducted for all areas on a periodic basis. Alternatively, written housekeeping procedures and schedules would satisfy this requirement. 9.5 The facility should have an appropriate number of trained personnel assigned to the responsibility of maintaining and/or repairing in the event of machinery breakdowns or emergencies. For safety purposes, the facility should only permit the trained personnel to maintain and repair the machinery. The desired number of personnel will be dependent upon the size of the facility and type of machinery present, with appropriate training to be provided for such maintenance personnel. Machinery safety equipment should be well maintained, which would include a regular daily inspection to ensure it functions correctly. Safety check record should be kept. 9.6 Good communications are necessary as a means of alerting occupants of an emergency, and as a way to mobilize emergency services such as a fire department or brigade, police, ambulance, etc. Means of communication should be available throughout the facility in accessible locations, and employees should be trained in the proper method of using the communication systems available in the facility. For instance, all employees/workers should know how to raise the alarm internally, and designated employees trained in further communications. It is recommended that emergency telephone numbers be posted along with directions for use of the communications system in the event of an emergency. 9.7 Safe ambient air temperatures should be provided in occupied areas of the facility. Determine if there are local laws relating to heat and cold temperatures limits for a facility. If so, those local laws should be followed. Temperatures within the limits of the chart below would be deemed to be safe. When temperatures are outside these limits, management should establish a formal process for adjusting the thermal environment to prevent temperature stress. Engineering controls such as fans, air movers, and air conditioning should be considered first. Administrative controls should also be considered. Modification of work-rest schedules and the number and/or duration of tasks are examples of administrative controls, which can reduce worker temperature exposures. Another administrative control is the postponing of non-critical tasks until the work environment heat stress level has improved. Work practice controls such as special personal protective equipment and clothing may also be used to reduce temperature stress but should be considered as the least effective control means.

Cold Stress Limit Functional Area (Dry Bulb Temperature)

Heat Stress Limit* (Wet Bulb Globe Temperature)

Manufacturing - Sedentary (e.g., sewing, rooting, assembly) Manufacturing - Light (e.g., VUM, molding, die casting) Manufacturing - Moderate (e.g., rotomolding) Warehouse

16C (61F)

30C (86F)

4C (39F)

30C (86F)

4C (39F) 4C (39F)

30C (86F) 29C (84F) 31C (88F)

Office

16C (61F)

*If the person is determined by medical personnel to be more tolerant to work in heat than an average worker, then you may add 1C (2F) to the limit. 9.8 Ventilation should be provided in work areas. Ventilation may be in the form of general ventilation or local exhaust ventilation. Where airborne contaminants are being generated, local exhaust ventilation should be provided to capture and remove the contaminant before it is released into the work environment. Airborne contaminants include dusts, vapors, gases, fumes, etc. When airborne contaminants are not being generated, general dilution ventilation should be provided to provide fresh air from outside. You should have sufficient outside air per occupant or you could measure the contaminants of concern. If there is any concern that ventilation is not adequate, measurements can be taken if necessary to ensure that the ventilation and concentrations are meeting one of the following two limits a) or b): a) For Air Conditioned or Forced Air Heated Premises - Outside Air Per Occupant FUNCTIONAL AREA MINIMUM Cubic Feet Per Minute (CFM) per PERSON General Office General Factory Restrooms Warehouse Cafeteria Kitchen / Food Preparation 20 cfm (10 L/s) 14 cfm (8 L/s) 40 cfm (24 L/s) per w/c or urinal 14 cfm (8 L/s) 14 cfm (8 L/s) 14 cfm (8 L/s)

b)

Indoor Air Quality Monitoring Measurements are taken annually in the course of a normal working day to ensure that the concentrations of specific contaminants are below threshold limits in the general office, general factory, restrooms, warehouse, cafeteria, and kitchen/food preparation: CONTAMINANT MAXIMUM CONCENTRATION Carbon dioxide (CO2) Carbon monoxide (CO) 1000 ppm 9 ppm

9.9

Lighting should be adequate for all areas where work is conducted. The greater the detail of work, the more light that is generally needed. Where the general lighting is not adequate for the work being performed, task lighting should be provided at the workstation. In addition, lighting in hallways, aisles, and exit lights should be provided, should an emergency arise.

9.10

Refuse should be collected and removed from the facility on a regular basis and sent to an appropriate location for disposal. The type and amount of refuse generated will determine the appropriate amount of time between collections. Refuse should be collected and held in an area where odors will not migrate into work areas until it can be removed from the facility. Also, refuse collection areas should be located in areas that will not attract pests into the facility. Auditors should note the date of last collection from facility records.

9.11

The physical and structural integrity of all buildings should be assessed by a professional to ensure that the buildings are capable of housing the machinery and people within it. Local, regional or national regulations should be consulted to determine the qualifications or licensing needed to carry out such an assessment. If there has been a significant change in the use of building, reassessment is required. The physical condition of buildings and surrounding property such as walls, floors, driveways, sidewalks, etc. should be maintained free of damage which can cause personal injury. Holes, uneven surfaces, and cracks can cause hazards if left in disrepair. A copy of assessment results should be maintained on file by site management. Record the date of issue.

9.12

The boilers, unfired pressure vessels, and furnaces should have been assessed annually by a professional to ensure that they are being maintained in proper working condition. A copy of assessment results should be maintained on file by site management. Record the date of issue. In the absence of a local professional, a professional from another jurisdiction may do the assessment.

9.13

Floors should be designed to carry anticipated loads safely. The weight of materials, machinery, equipment, forklifts, people, etc. needs to be analyzed to determine the structural needs. A professional should have assessed floor-loading requirements. Once assessed, signage should be in place indicating the allowable floor loading. Determine if the facility is adhering to its floor loading weight limits as outlined above. Review the last periodic review to ensure floor-loading weight limits have been adhered to. Also, compare the area to see if there have been any significant changes to its use since the last periodic review, which could indicate that a reevaluation could be necessary.

9.14

Records of any violations, penalties, or citations of the facility not being in compliance with local laws should show objective evidence that they have been corrected within the required time established by the citing authority. Auditor should record instances where the same violation has occurred repeatedly.

Periodic follow-up by management should be made to ensure that violation has not reoccurred. 9.15 Employees should have access to potable water for drinking purposes. Potable water should meet the local drinking water standards for the area that the factory is located (Testing for the chemical detection levels according to the local standards can be done by the local water authorities). In the absence of a local standard, the factory should comply with the standards found in Exhibit A. Certification should be available based on annual sampling and testing of not less than one drinking water spigot per production facility and dormitory, if any. Potable drinking water dispensers should be designed, constructed, and serviced so that sanitary conditions are maintained. Containers which are uncovered and can be left open are not acceptable as they may become contaminated. Water should be within a reasonable distance for employee access. This applies to facilities and, where provided, dormitories. (Note: It is anticipated that priority should be given to the local standards over any other standards. Reference to any particular laboratory should not be part of the Guidance Document.) 9.16 Toilet facilities should be provided with an adequate quantity for each gender based on the number of employees of each gender. An adequate quantity relates to the number of employees. For instance, certain regional regulations indicate one toilet for every 24 persons up to 100 persons employed, with an additional one for each additional 40 persons employed over 100 persons. This should suffice as a guideline in determining adequate quantities. However, where regulations are more specific, the regulations should be followed at a minimum. The sewage disposal method should not endanger the health of employees. Toilet facilities should be maintained in a functional, clean condition, and be free of foul odor. No food or beverage should be stored in toilet rooms. This applies to facilities and where provided, dormitories. 9.17 Hand washing facilities should be provided. Hand washing facilities should be maintained in a functional and sanitary condition, and located around the toilet facilities area in facilities and dormitories. Provision of cleansing materials for washing and drying of hands should be considered in the toilet/washroom of production areas. The production of toys for children must be conducted with good hygiene. 9.18 Security personnel should be trained in their roles and responsibilities and these should be recorded. Training should include emergency response and protecting facilities from unauthorized entry. Care should be taken in training security personnel in handling situations appropriately without any unnecessary aggression. This may include fights, smoking in non-smoking areas, or excessive noise. Where security personnel are used to monitor dormitory safety, further care should be taken to ensure there is no abuse of residents privacy or free access and use of facilities. 9.19 If local regulations and/or facility management prohibit smoking in the workplace, management should ensure this is communicated to all personnel and enforced. If local regulations permit smoking, designated areas should be established for smoking. These designated areas must be located away from flammable and/or combustible materials, and be formally posted Designated Smoking Area. All use and storage locations of flammable and combustible materials and wherever danger could be caused by ignition must be identified and posted with appropriate NO SMOKING signs. Management must ensure that all personnel adhere to the posted safety warnings. Note whether or not there is any evidence of smoking in areas where it is not permitted.

Section 10.0 Fire Protection 10.1 Management should establish an overall written program to address fire hazard and preparedness for emergencies. Emergency actions should include a written plan listing, in detail, the procedures to be taken in the event of a fire. An example program can be seen in the ICTI Industrial Fire Protection and Emergency Preparedness Survey Guide. Emergency Plan Contents: a) Facility information describes key elements of the facility. This is useful for new employees and response agencies, such as local fire departments. b) Information so that employees know how to report an emergency. This may include the activation of pull alarms or notifying the facility security center. Consideration should be given to methods of notifying local agencies such as the fire department. c) Alarms and signals to alert employees should be identified; this may include audio alarms, highly visible lights, and/or a public address system. Consideration should be given to the potential for loss of electrical power in the event of a fire and alternatives and back-up to mains powered alarms should be in place. Management and employees should know what actions to take when an emergency alarm is activated. d) All emergency phone numbers should be identified, listed in the emergency preparedness plan, and posted. All employees should know how to report an emergency. Emergency phone numbers should include any facility numbers, local agencies, and any emergency-facility personnel. e) All responsibilities should be clearly defined for management and employees. Management should determine its strategy for responding to fire emergencies. f) A chain of command should be established to minimize any confusion. Personnel should be identified to coordinate the emergency-response actions. g) Detection and alarm systems should be identified and described. Testing and preventative maintenance procedures should be included. h) Diagrams should be developed for critical information. Evacuation routes, exit doors, fire extinguishers, and other critical elements should be visually displayed for all employees. If the fire sprinkler system or standpipe system is used, all critical controls/valves should be clearly identified. i) Assembly areas should be established for all employees. Accounting for employees can be performed at assembly areas. All assembly areas should be established at safe distances from fire hazards and clear of emergency vehicle traffic and activities. j) Search and rescue procedures should be established. Only trained and authorized personnel should attempt search and rescue. k) Procedures for shutting down equipment during emergencies should be established. Equipment operators should know the proper actions to take during an emergency. 10.2 Managers, supervisors, and employees should be knowledgeable and informed of fire prevention procedures. Fire protection procedures should include hot work permits, storage and handling of

combustible materials, housekeeping, fire extinguisher, and fire hazard identification. All employees should understand basic emergency action plans including alarm signals, emergency shutdown, primary/secondary exit routes, and assembly areas pertaining to their work assignments. All employees should know how to safely evacuate from their work areas during emergencies. 10.3 A coordinator should be designated to assist management in assuring that all elements of the fire protection and emergency preparedness program are in place and working. The coordinator should have recognized training of emergency preparedness planning and all elements of the facility's fire protection plan. 10.4 The alarm system to notify employees of emergencies and evacuations should be clearly recognizable during emergency conditions. Horns, sirens, public announcement systems, or other alarm devices should alert employees of an emergency. Consideration should be given to the potential for loss of electrical power in the event of a fire and therefore back-up alarms should be in place. All alarm systems and fire protection systems should be maintained and tested on a regular basis. 10.5 Emergency lights should be available to illuminate emergency exit paths. All emergency lighting should be maintained and tested at least monthly. 10.6 Exit paths should be illuminated to assist people in traveling to the emergency exit doors. All illumination should be reliable during an emergency. Exit paths should be clearly identifiable and clearly marked with visible signs if the path is not immediately apparent. Floor markings and arrows are often used to direct people to the emergency exit doors. Exit paths should be clear and consideration should be given to adequate path width for occupancy. Exit paths should not be routed through boiler rooms and other high hazard areas. Exit paths and exit doors should be distinguishable during emergency conditions. Exit doors should be marked and illuminated to provide a visible sign during emergencies. Exit doors leading to streets or other areas where vehicles are present should be posted to alert employees of hazard. If possible, barriers or guards should be placed on the exit discharge to protect the employee from vehicles. Guardrails are often used to direct the employees out of danger. Weekly inspections should be conducted to ensure the area is free of obstructions on the exit paths, exit door, and discharge area. The exit doors, path, and discharge should be kept clear of obstructions. 10.7 Emergency routes and exit doors should be clearly posted on a wall diagram to show employees the primary and secondary emergency routes for evacuating the building. The diagram should show the employees current position, emergency routes and assembly area unless the factory can provide an alternative way to ensure that workers know where to assemble. Each major area should display this diagram in a highly visible area. 10.8 As a minimum requirement, two exits should be provided for each floor. This provides an alternate exit in the event that the other exit is blocked by fire. The recommended distance to the exit should be no more than 200 feet in an un-sprinklered industrial or general office building, or follow local fire safety regulations, whichever is more stringent. This does not apply to small offices. The number and distance to an emergency exit will vary by the type of hazards in the facility. 10.9 Doors and paths to be used for exiting during an emergency should be clearly marked as an exit or escape route and workers should be trained to follow the appropriate sign during an emergency. Doors not leading to an emergency exit should not be marked in any way that would cause workers to use them during an emergency. If a door between departments is being used as an exit or it could be

mistaken for an exit, consider (but only if it makes sense) marking it appropriately to prevent employees from entering during an emergency. However, training to follow one exit route is an alternative to such NOT AN EXIT markings. 10.10 10.10 All exit doors should be free to open. Exit doors should open and swing in the direction of exit travel and employees should be able to open the door without any special knowledge or hardware such as keys. Exit doors should be side-hinged. Revolving doors are prohibited from serving as emergency exit doors as they will not allow adequate and safe discharge from a building. Sliding doors and overhead gates are not encouraged, but if they exist, they should be kept in an open position, such that unintentional closing cannot occur whenever the premises are occupied. 10.11 Emergency evacuation drills should be conducted to ensure employees are knowledgeable and trained on emergency plans. Emergency drills test the effectiveness of the emergency preparedness plan. Management and employees, on all shifts, should rehearse their emergency action plans. Management should set goals for timely exit during emergency exit drills. At a minimum, an annual drill should be conducted during the peak season starting approximately from June through October, or more frequent if management goals are not met. Also, an additional emergency exit drill should be considered outside the peak period where there is a significant number of employees who have not participated in an emergency exit drill. This is to be scheduled when more than 30% of the employees are new OR at such time as may be determined by the management in conjunction with the EHS coordinator and is to be conducted in the first half of the year. 10.12 To minimize fire hazards, trash (rubbish) removal should be done regularly and in accordance with the rate of generation. Dedicated and non-combustible containers for trash (rubbish) removal should be provided and in place. 10.13 Management should ensure that precautions, such as the availability of suitable covered metal receptacles are provided for combustible industrial scraps, waste (e.g. oily rags) and other debris and promptly and properly emptied and disposed of. 10.14 10.15 Excessive combustible materials should be removed from the workplace to reduce the potential for fire. Spills and loose materials (for example, parts, waste items, etc.) should be promptly removed from all floor areas. Spilled and loose materials can contribute to fires starting and/or spreading and also can create slip, trip, and fall hazards, particularly during fire emergencies. 10.16 Storage containers of flammable and combustible materials should be labeled with their contents and hazard warnings in the local language so that employees could understand the hazards and proper handling procedures. Primary containers of flammable materials should not be combustible [a one-day supply in closable plastic bottles is acceptable at work stations where no naked flame is present]. Glass is not to be used unless materials involved is corrosive. When not in use, storage containers of flammable liquids should be closed to prevent ignition and the creation of hazardous atmospheres, and stored in suitable cabinets, containers, or buildings. 10.17 All use and storage locations of flammable and combustible materials, and wherever danger could be caused by ignition, should be identified and posted with appropriate NO SMOKING signage. Management should ensure that all personnel including contractors adhere to the posted safety warnings. If smoking is permitted on site, designated areas should be established. These areas should be located away from flammable and/or combustible materials. NO SMOKING signs should be posted in

hazardous areas where paint containing flammable/combustible materials are used. 10.18 Heat-producing equipment such as portable heaters, motors, ovens, etc., should be kept clear of combustible materials (including dust, grease, oil, and fibers). Hazardous accumulations of dust, grease, oil, or fibers can be ignited by electrical sources, such as arcs. 10.19 Empty pallets can pose several hazards. In addition to being combustible, pallets can be hazardous if improperly stored on their edge or side as they may fall or tip over and strike personnel or equipment. Pallets should be stored in safe and stable stacks in a dedicated location without interference with sprinkler [it is recommended that stacks over 6 feet or 2 metre in height should be avoided as they may defeat the sprinklers installed for that area]. Pallets should not be left blocking aisle ways, exit points, emergency equipment, etc. Damaged pallets should be removed from use promptly and properly discarded. Combustible materials (e.g. packaging) should be stored to ensure adequate access for fire fighting. Storage practices should include proper stacking and placement of cartons and un-cartoned goods. 10.20 All electrical wiring should be properly located, supported, and protected, so as not to create a tripping or overhead hazard, or be struck by equipment during normal operations. All electrical leads on factory equipment should be three-prong grounded or double insulated. Frayed and worn cords should not be used. [Note: It is recommended that suitable written procedures and documentation should be kept to ensure that all electrical wiring is of proper wire size, adequately insulated, properly connected, and free of hazards. Electrical equipment and protective devices should receive regularly scheduled maintenance. A competent electrician should be available to monitor the electrical system and provide maintenance.] 10.21 Only fixtures, plugs, circuit breakers, and other equipment which comply with recognized standards should be used. Improper temporary wiring (e.g. bare wires in socket, without plug) should not be permitted. 10.22 All junction boxes, outlets, and panel boards should be guarded with secured enclosures or covers. Electrical panels, junction boxes and outlets should be readily accessible and free from obstruction. 10.23 A lightning-protection system can provide protection for circuits and electrical equipment and prevent fires. 10.24 Only proper piping, containers, tanks, and approved rooms designed, safeguarded, and constructed specifically for the storage and handling of flammable and combustible liquids, including waste solvents, should be allowed for use. When not in use, containers of flammable liquids should be closed to prevent ignition and the creation of hazardous atmospheres, and stored in proper cabinets, containers, and buildings. All electrical fixtures, switches, and circuits inside a flammable and combustible liquid storage room should be appropriate for hazardous locations (i.e. explosion-proof). 10.25 Flammable liquid storage drums should be grounded and dispensing containers should be electrically bonded during dispensing or transfer of the flammable liquid to prevent the build-up of an electrical charge. 10.26 Site procedures should include a written hot-work permit procedure. Hot-work is defined as the use, outside of normal work areas, of flames (e.g. cutting torch, brazing) or spark-producing activities (e.g. welding, grinding metal) which are capable of igniting combustible materials. A survey of the facility to identify hazardous areas for hot-work activity should be completed. Hot-work in hazardous areas can

result in explosions and fires. Hazardous areas generally include areas with flammable liquids and/or gases. Hazardous areas for hot-work activities should be posted with appropriate warning signage such as Hot-work is not allowed without proper authorization. Flammable and combustible mat erial should be removed and/or protected from the hot-work. Special precautions, such as using fire-resistant covers, to cover areas/equipment that cannot be removed from the hot-work area, and controlling potential migration of hot sparks and slag to other floors/areas, should be taken prior to the commencement of hot-work. The fire watch person(s) should be posted in the area to assure that the hot-work does not initiate a fire. This often includes person(s) posted below the area where the hot-work is performed. Depending on the hazards present, a fire watch should stay at the hot-work area for 30 to 60 minutes following completion of the hot-work. A fire can be initiated several hours after the hot-work is completed, if the area is not protected during the hot-work. Fire extinguishing equipment suitable for potential hazards present should be maintained in a state of readiness for immediate use. In many companies, outside contractors are used for hot-work activities and require full training to prevent any risk of fire or explosion. Welding equipment should be properly used and all cables maintained in good condition. 10.27 Cylinders with unprotected valves can pose a serious hazard when the valve is impacted. Cylinders have been known to break through concrete walls when their valves are broken. Content labels (e.g. propane, oxygen, etc.) should be legible, written in the appropriate language(s), and prominently displayed on containers of hazardous chemicals, including all compressed gas cylinders. Personnel training should include an explanation of the labeling system. All flammable gas cylinders should be stored at least 25 feet [7.5 metre] from open flames or possible sources of ignition, in temperatures below 125oF [51?], and away from contact with electrical apparatus. All storage locations of cylinders should be properly selected, constructed, identified, marked with appropriate warning signs, and secured. Cylinders should be stored in an upright position, and be properly stored to prevent tipping and/or falling. Cylinders should be moved by a means of a suitable handcart (or equivalent) with a chain or belt for securing the cylinder. Cylinders should be transported in a vertical position. It is important that the Liquid Petroleum Gas cylinders be stored or transported in a position so that the safety relief device is always in direct contact with the vapor space in the cylinder. This is generally a vertical position. The valve should be closed when not in use, being transported, or when empty. Periodic inspection of compressed gas cylinders should be part of the site's compressed-gas written policies/procedures. The inspection should focus on corrosion, general distortion, cracks, deep rust, leakage, or other defects. Unapproved or makeshift compressed gas apparatuses should not be used. Under no circumstances, should cylinders be used as rollers/supporters or other devices. Stored oxygen cylinders should be separated from fuel sources and combustible materials. It is recommended that oxygen cylinders be separated from fuel gas cylinders by a minimum distance of 20 feet [6 metre] or by a non-combustible barrier at least five feet [1.5 metre] high, having a fire resistance of at least one-half hour. Employees working with compressed gas should be trained on proper handling and use. (Note: Local laws should be referred to where applicable) 10.28 Combustible dust and particulate should be properly removed from operation areas to prevent the creation of a hazardous atmosphere. Sweeping of materials is acceptable only for the minor amounts of dust or particulate created by leakage from the vacuum collection equipment. Blowing with an air-line is not a proper method of removal and is unacceptable. 10.29 Solvent spray areas should be kept free of ignition sources such as open flames and sparks. All spray

areas should be kept free of the accumulation of spray residue. All spray booths should be constructed of non-combustible materials to prevent the spread of fire. This includes spray booth floors and baffles. Belts, pulleys, and other power transmission devices should be constructed in such a way to prevent accumulation of spray residue. Where adequate ventilation is not provided, the followings apply. Electrical equipment (lights, switches, outlets, motors, etc.) designed and approved for the specific use in hazardous environments and atmospheres should be used (i.e., explosion-proof and properly located when installed). [Note: Monthly cleaning is recommended. Spray residue can be a potential explosive and/or fire hazard. Ducts and filters should be scheduled for inspection and, if necessary, cleaning at least quarterly. Adequate ventilation and design of drying spaces is essential to control heat accumulation and contact with ignition sources.] 10.30 All inside flammable and combustible liquid storage rooms should be equipped with either a gravity or a mechanical exhaust ventilation system designed to provide at least six air changes per hour. This prevents the build-up of an explosive atmosphere. However, if the local fire regulations are more stringent, those should be followed. All spraying areas should be provided with ventilation that adequately removes flammable vapors, mists, or powders and also provides adequate volumes of quality make-up air in enclosed areas. Spray booths using exhaust air filters should maintain an average air velocity of 100 feet per minute [30 metre per minute] at the position of work-pieces and be measured annually. It is recommended that filters be cleaned or changed at least quarterly. Contaminated air should not be circulated or allowed to re-enter into another makeup air unit intake. 10.31 Only personnel trained in chemical safety, bonding, grounding, and fire prevention should transfer or withdraw flammable and combustible liquids. Where employees are employed in areas in which flammable and/or combustible materials are to be found, they must understand the proper handling procedures and the hazards such materials may represent. 10.32 10.33 All alarm systems should be maintained and tested at least monthly. Local law requirements should be checked and followed. In the absence of the local law requirements, the following guidelines should be used: Portable fire extinguishers should be available for the use of emergency response employee. The fire extinguishers should be selected and distributed in accordance with the size and degree of hazard affecting their use and expected class of workplace fire. Generally, the distance to a fire extinguisher should not exceed 75 feet [23 metre]. Portable fire extinguishers are to be located, mounted in an upright position up to 1.4 metre to the top of the extinguishers, and identified to be readily accessible and not subject employees to possible injury. Standpipes and hose cabinets should also be readily identifiable and used only for fire equipment purposes. Fire extinguishers should be located high enough above floor level to avoid obstruction. Areas protected by fixed extinguishing systems that use extinguishing agents in concentrations known to be hazardous to worker safety and health, should be posted with appropriate hazard warning or caution signage at the hazard entrance exterior and interior of location. 10.34 A system of inspecting, maintaining, and recharging of all portable fire extinguishers should be in place. Portable extinguishers should be visually inspected each month and recorded on a tag attached to each extinguisher. Annually, all portable fire extinguishers should be given a thorough and documented maintenance check only by a qualified technician(s). 10.35 Annual fire extinguisher training and education for emergency response employees who are expected to use fire extinguishers should be provided and documented. Employees who operate fixed extinguishing

systems should also be trained annually. 10.36 All fires should be investigated in order to identify root causes and a strategy for preventing recurrence should be in place. 10.37 All other fire-fighting equipment such as hoses, standpipes, emergency generators etc., where installed, should be inspected periodically and maintained to provide effective use, at least on an annual basis. Fire doors should be in good working condition.

Section 11a. General Environmental Health and Safety (EHS) 11.1 Management should establish an overall written EHS process. The process should include site-specific policies and procedures for identifying, evaluating, controlling and documenting environmental, health, safety (EHS), and working condition risks. 11.2 Determine if the written EHS policy has been posted and/or made available to all employees in the local language and the program to applicable employees. 11.3 To facilitate the EHS process, a designated EHS coordinator should be appointed, who should be suitably trained with evidence of a local government certificate if available or if not, other evidence such as training courses or seminars. Consideration should be given to a system of proportionally increasing the number of support staff for the EHS coordinator based on the number of workers. 11.4 EHS committee(s)/team(s) should be established and comprised of members representing a variety of shifts, functions, and personnel levels. EHS committees should meet on a regularly scheduled basis at least once in every 60 days and a plant manager is to attend at least three times a year. Minutes of all meetings should be kept. 11.5 Employees should be made aware of EHS rules, safe operating procedures, EHS activities, and other EHS-related information pertinent to their job. Workplace EHS awareness can be achieved through effective communications such as EHS meetings, newsletters, bulletin board postings, EHS training, etc. 11.6 Job specific EHS training/education should be provided to all workers prior to starting a NEW job. Training should include operating machinery in a safe manner, proper use of personal protective equipment, disposal of wastes, operating spray equipment, etc. 11.7 Employees should be given the opportunity to voice EHS opinions and concerns. This opportunity can be via suggestion boxes, meetings, surveys, and personal communications. Recommendations received by the facility management should be reviewed, considered, properly addressed, and feedback provided through the EHS committee. 11.8 EHS coordinators should identify new potentially hazardous materials and/or processes prior to the use of the materials concerned and put in place adequate safety controls. 11.9 All containers of chemicals coming into the facility should have a label attached with the name of the chemical and an indication of the potential hazard and any specific handling and storage instructions, either with symbols or in the local language.

11.10

Contractor personnel should receive an orientation prior to commencing with work. The contractors should be informed of any potential hazards at the facility to which they may be exposed. The orientation should include a review of the site EHS rules, which contractors must obey. Contractors should receive the EHS rules in written format.

11.11

A written chemical EHS policy and/or procedure in the local language must be provided to all employees who have the responsibilities within the chemical EHS program for the storage, labeling, handling and safe usage of all chemicals which are introduced into the facility. Responsibilities for personnel within the chemical EHS program should be clearly defined and documented. All employees who use or work in areas where chemicals are used or stored should be trained by a person experienced in chemical safety.

11.12

Material Safety Data Sheets (MSDS) must be available in the local language to employees for each hazardous chemical. Employees should be informed that the MSDS are available and where they can be found. Employees should have an understanding of how to interpret the key safety, labeling, and handling points illustrated by the MSDS. [Note: It is recommended that obsolete MSDS should be removed from the current MSDS file but retained elsewhere for 5 years.]

11.13

A list of all hazardous chemicals currently being used or stored at the facility including the relevant MSDS should be maintained and available through the EHS coordinator or factory manager.

11.14

Emergency eyewash equipment should be present in all hazardous chemical use areas. Shower unit should be added to the eyewash equipment if corrosive and toxic chemicals are used. Location of eyewash equipment should be within 100 feet (30 metre) travel distance of the hazardous chemical use areas. It is important for these eyewash units to be inspected and their operation checked monthly. Documentation of these inspections is required. Signs identifying the emergency eyewash equipment locations and shower unit locations should be conspicuously posted. This requirement applies to both process operation and laboratory facilities. Refer to 11.8.

11.15

Storage and process tanks, piping used to transfer hazardous substances, and valves used to control the flow of hazardous chemicals should be labeled or color-coded to communicate which substances are present in the system. Color-coding and identification is an important aspect for operations and maintenance. The color-coding system should be consistent throughout the facility and communicated by posting of the color code and what each color identifies. In addition to color-coding, labeling should also be used to identify valves, connections, bleeds, and other critical parts.

Section 11b. Health and Safety 11.16 Each accident or near miss requires some degree of investigation including fires, spills, injuries, overexposure to hazardous chemicals, property damage and incidents, which did not result in injury or loss but had the potential to do so under different circumstances. A consistent format should be used to ensure that the proper information is collected and the immediate causes, root causes and necessary system improvements are identified and an action plan has been put in place. Forms should be filled out in their entirety prior to filing. Employees should be reminded of the need to report all incidents. This can

be accomplished by posting bulletins, safety meeting reminders, memoranda, etc. Safety meetings are held on a regular basis (60 days. Refer to 11.4). Corrective actions should be tracked on a corrective action log and the status of items should be reviewed periodically to ensure timely completion. 11.17 All accidents should be reported. Employees should be encouraged to promptly report any accidents, and should not be discriminated against, reprimanded, or discouraged for reporting accidents. 11.18 The facility should prohibit persons from working at or near moving machinery while wearing loose clothing, jewelry, or long hair. Gloves, loose shirts, baggy pants, etc. which could become entangled in machinery should not be permitted. Jewelry includes rings, bracelets, necklaces, etc. and should not be permitted. Hair hanging loosely below the neckline should not be permitted. [Note: Even the most elaborated safeguarding system cannot offer effective protection unless the operator and all affected employees know how to use it and why it is necessary. All employees should be informed of any machine guarding which impacts safety. Training should include: identification of hazards; demonstration of safeguards; discussion of safeguard limitations; proper methods for cleaning and clearing jams; required tools, fixtures, and personal protective equipment; activities requiring lockout/tag out; (see description at 11.25) and safe work practices.] 11.19 11.20 Employees should be trained on machine safe guarding. Machine safeguarding should be provided on all machinery to prevent employees from coming into contact with any machine part, function, or process that may cause injury. The point of operation is the location on the machine where work is performed on material such as cutting, shaping, molding, trimming, drilling, punching, or shaping. These areas should be safeguarded. Power transmission apparatus are the components of the mechanical system, which transmit energy to the part of the machine performing the work. These components include flywheels, pulleys, belts, connecting rods, couplings, cams, spindles, chains, cranks and gears. These components should be safeguarded. Other hazardous moving parts are the parts of the machine, which move while the machine is in operation. These can include reciprocating, rotating, and transverse moving parts, as well as feed mechanisms and auxiliary parts. These parts should be safeguarded. Drive mechanisms such as pulleys and belts that are within seven (7) feet (2.1 metre) from the floor or working surface should be guarded. Fan blades should be protected against accidental contact. A guard should be provided with openings no larger than inch (12.5 mm). 11.21 Starting/stopping controls should be accessible to the operator. If there is more than one operator, separate controls should be provided for each operators station. Start buttons should be protected against accidental startup by a ring guard. All starting/stopping controls should be labeled as to its function and appropriately colored. Green should be used for start controls and red for stop controls. Emergency stop buttons should be of a palm/mushroom type for easy and quick activation in an emergency. Emergency stop buttons should also be colored red to differentiate the emergency stop button from other controls. 11.22 Areas requiring frequent inspection are cords, plugs, rotating parts and guards. All hand tools and portable power tools should be free of defects. Defective tools are to be removed from the work place and repaired or replaced. [Note: Machinery and equipment should be free of excessive dirt, grease, or oil that could present a hazard. Machinery and equipment can only be safe and effective if it is maintained in proper working condition free of recognizable defects. Preventive maintenance programs that ensure safe operation by checking safety latches, sensors, start and stop controls are recommended.]

11.23

Suitable local mechanical exhaust ventilation is essential to prevent a buildup of vapors, which could result in a fire or health hazard wherever flammable liquids such as solvent based paints are stored, used or mixed. . In addition to ventilation, control is best achieved through the proper training of employees and confinement of liquids and associated vapors to selected areas, control of potential ignition sources, and protection of the area with an extinguisher system. No-smoking policy should be strictly enforced. Other operations such as soldering, plating and paint mixing may require local ventilation using exhaust air filters which must maintain an average air velocity of 100 feet (30 metre) per minute. Determine whether immediate actions are taken by the facility when average readings are less than 100 feet (30 metre) per minute. Air velocity should be measured when changes are made to the system, or when production conditions significantly increase, and at least annually. Contaminated air should not be circulated or re-entrained into another air unit intake. Adequate ventilation and design of drying areas is also essential to control heat accumulation and contact with ignition sources. [Note: Flammable liquids such as solvent based paints which are used or mixed for an operation must be closely controlled during all storage, handling, and usage of these liquids. This is the responsibility of the management.]

11.24

All employee exposures to hazardous substances should be maintained at or below regulatory standards established in the country where the factory is located where such regulatory standards do not exist, reference may be made to the ACGIH (American Conference of Governmental Industrial Hygienists) exposure limits for relevant chemicals present in the facility processes (see below in this section). If not set out in the countrys regulatory standard, a respected sampling and testing method such as those approved by NIOSH or OSHA in the United States or an equivalent standard in a major European Union country should be used. Exposures should be controlled through the use of engineering controls, administrative controls, or personal protective equipment. Periodic monitoring should be conducted to determine if exposures are in fact below established standards. This requirement applies to all areas including production, chemical use areas, laboratories, warehouse, and maintenance. Where practicable, engineering controls should be implemented to reduce employee exposures to hazardous substances below established standards. An example of engineering controls is mechanical exhaust ventilation. Where engineering controls have been determined to be impracticable, administrative controls should be implemented. Administrative controls include job rotation, preventative maintenance programs, regularly scheduled rest breaks, changes to production schedules, etc. Where engineering controls and administrative controls are determined to be impracticable, personal protective equipment (PPE) should be provided and used. PPE should be suitable for the person using it and appropriate for the substance it is designed to protect against.

Chemical Acetone Aluminum (Al) welding fume Butyl Cellosolve (2-Butoxyethanol) Cadmium (Cd) welding fume Chromium (Cr) welding fume Copper (Cu) Cyclohexanone

Source of Chemical Vacuum Metalizing, Paint Welding Paint* Welding Welding Welding Paint*

(ACGIH TLV) in ppm *500 (Short Term 750) 5 mg/m3 25 0.01 mg./m3 0.5 mg/m3 1 mg/m3 25

Ethyl Acetate Formaldehyde

Paint* Plating (silver nitrate solution) and Injection Molding (by-product for acetyl resin)

400 Ceiling 0.3

Hydrochloric Acid Iron (Fe) welding fume Isocyanate (MDI) Isocyanate (TDI) Isopropyl Alcohol Lead (Pb) welding fume Manganese (Mn) welding fume Methylene Chloride (MC) Methyl Ethyl Ketone (MEK) Methyl Isobutyl Ketone (MIBK) Mineral Spirits/Stoddard Solvent (Kerosene) Nickel (Ni) welding fume Nitric Acid Nuisance Dusts Phosphoric Acid Respirable Dust Sodium Hydroxide Styrene Sulfuric Acid Trichloroethylene (TCE) Toluene Total Hydrocarbons (as N-Hexane) Vanandium (V) welding fume Welding Fumes Xylene Zinc (Zn)

Injection Molding and Rotocast (byproduct of PVC), Plating Welding Mold Casting Mold Casting Paint*, Cleaning, Hair Gel Welding, Soldering Welding Paint*, Solvent Bonding, Cleaning, Vacuum Metalizing Paint*, Solvent Bonding, Cleaning Paint*, Cleaning Paint*, Cleaning, Vacuum Metalizing Welding Plating Regrind, Plastisol Powder Mixing Plating Color Mixing Plating, Vacuum Metalizing, Spindle Stripping Injection Molding (by-product of ABS resin) Plating Solvent Bonding, Paint* Paint*, Cleaning, Vacuum Metalizing Paint*, Vacuum Metalizing Welding Welding Paint*, Cleaning, Vacuum Metalizing Die cast

5 5 mg/m3 0.005 0.005 400 (Short Term 500) 0.05 mg/m3 0.2 mg/m3 50 (Short Term 125) 200 (Short Term 300) 50 (Short Term 75) 100 1 mg/m3 2 (Short Term 4) 10 mg/m3 0.25 (Short Term 0.75) 3 mg/m3 Ceiling 2 mg/m3 20 (Short Term 40) 0.25 (Short Term 0.75) 50 (Short Term 100) 50 50 0.05 mg/m3 5.0 mg/m3 100 (Short Term 150) 5 mg/m3

11.25

The facility should have a written procedure on the subject of hazardous energy control. Record date of issue. This procedure should be developed for purposes of protecting employees during machine and equipment servicing and maintenance where the unexpected energization, start-up or release of stored energy could occur and cause injury. Hazards being guarded against include being caught in, being crushed by, being struck by, being thrown from, or contacting live electrical circuits/parts. Energy sources include electrical, mechanical, pneumatic (compressed air), hydraulic, chemical, and thermal. All energy sources should be de-energized and where possible, locks should be placed on switches and valves to ensure that they are not inadvertently switched on during shutdown, and tags used to make clear to all why energy source is locked out (off).

11.26

Employees who perform maintenance and servicing activities (authorized employees) should receive training from a competent person in lock/tag/try procedures and practices prior to conducting any work. Persons who normally operate machines and equipment being services (affected employees) and persons who may be in the area of locked/tagged equipment (other employees) should also receive training. All employees should receive an overview of the relevant lockout/tag out program for their areas so that they are able to recognize when energy controls are being implemented, understand the purpose of the procedures and the importance of not attempting to start up or use the machine/equipment that has been locked out. Check training records of authorized employees on file to verify that training is current and not more than 1 year ago. Determine if they have been adequately trained by a competent person on the subject of lockout/tag out.

11.27

A sufficient number of isolation devices should be made available to persons performing lockout/tag out. The type of equipment that should be provided includes such items as locks, tags, group lock box, circuit breaker lockouts, valve lockouts, and lock hasps. This equipment should be maintained in a readily available location. Each maintenance employee working on a piece of equipment should have their own personal lock for locking out that equipment.

11.28

Select three (3) to five (5) maintenance workers. Ask for a demonstration and / or explanation of how they go about servicing equipment. Determine if they lockout energy of equipment prior to servicing, maintenance, and repair.

11.29

A hazard assessment should be conducted of each operation and the correct Personal protective equipment (PPE) for each operation should be listed. Personal protective equipment should be selected based on the hazard assessment of each operation.

11.30

Personal protective equipment should be provided where necessary. The following provides some examples of what conditions warrant that use of various types of personal protective equipment: Eye/Face Protection: Eye/face protection should be provided where there is a potential for injury from flying objects, liquids, injurious radiation, or a combination of these hazards. The type of eye protection will depend upon the hazard. Types of eye protection include safety glasses, goggles, face shields, and shaded lenses for injurious radiation. Foot Protection: Foot protection (safety shoes) should be provided where foot injuries could occur from impact of falling or rolling objects, objects piercing the sole. Protective boots should be provided where feet are exposed to liquids, other contaminants, hazardous chemicals, or where employees f eet are exposed to electrical hazards.

Hearing Protection: Hearing protection should be provided where hearing loss from high noise exposures could occur. Hearing protection when properly used should reduce the employee's noise exposure to less than 85 decibels (dBA). Types of hearing protection include earmuffs and earplugs. Hand Protection: Appropriately rated gloves should be provided for their applicable use to adequately protect employees against contact with chemicals, lacerations, burns, punctures, and extreme hot or cold temperatures. Head Protection: Head protection (hardhats) should be provided to protect against injury from impact and penetration from falling and flying objects and limited electric shock burn. Protective Clothing: Protective clothing should be provided to employees to prevent exposures to chemicals, lacerations, punctures, cold, and burns. Respiratory Protection: Respiratory protection should be provided where the potential for inhalation exposure to harmful types or quantities of airborne contaminants could occur. Airborne contaminants include particulates (dusts), vapors, gases, aerosols, and fumes (metal particles). Types of respirators include air purifying and air-supplying. Proper selection of a respirator should include the identification and evaluation of the contaminant, and the determination of the appropriate respirator. All respiratory protection should be approved by the regulatory or research testing authority for the type of contaminant exposure. Employees with any type of respiratory conditions should not be required to work with respirators. PPE Provided to Visitors: Visitors should also be provided with appropriate personal protective equipment when entering or working in areas where signage indicates that PPE is required. Employees should be observed to ensure that personal protective equipment is being properly used in accordance with the facilitys procedures. Determine if employees are utilizing personal protective equipment in areas of the facility where it is specifically required. If employees are observed not wearing PPE where they should be required to, determine if they have access to personal protective equipment and/or if supervisors or managers are not enforcing use of personal protective equipment. 11.31 Employees should be trained on the proper storage, cleaning and use of the personal protective equipment that is provided. The types of personal protective equipment that should be evaluated and used where appropriate include eye/face protection, foot protection, hearing protection, hand protection, head protection, protective clothing, and respiratory protection. Training should include proper fitting of all equipment. Annual PPE refresher training should be conducted to ensure continued awareness on the subject. Training records should be available to verify all training that has been conducted. Refer to 11.6. [Note: Employees who wear respirators should be encouraged to undergo medical evaluation in the use, care and fit testing and have hearing test annually for those on a conservation program.] 11.32 Signage should be visible in the general area and/or at workstations indicating where and what type of personal protective equipment is required for that area. 11.33 Only trained and authorized employees should operate cranes or hoists. A qualified person should provide training and it should include a review of the general crane, sling, and hoist operating rules.

11.34

Prior to initial use, all new and altered cranes and hoists should be inspected by a competent person to ensure they are in safe operating condition. Periodic inspection should be made of external and / or internal components for signs of defects, wear, or abuse as well as cleaning and lubrication of gears and motors, etc. Cranes, slings and hoists, which are damaged or defective, should be removed from service and marked so that they will not be used until repaired or replaced. [Note: Each day before being used, the sling and all fastenings and attachments should be visually inspected for damage and defects. Additional inspections should be performed as conditions warrant.]

11.35

The maximum load limits should be conspicuously marked on all cranes, slings, and hoists and the facility should ensure that those maximum loads are followed. Hoist hooks should be equipped with a safety latch to prevent the accidental release of the load. [Note: Marking is required on all crane beams as it is possible to have more than one moving rail in the system in the same section of the traverse rail effectively loading the section of the rails with the sum of the two cranes and their loads.]

11.36

Every open-sided flight of stairs in excess of 3 feet (one metre) should be equipped with adequate stair railings, which comply with local laws. Such railings may consist of a top rail, intermediate rail, and adequate support.

11.37

Every open-sided floor or platform three (3) feet (one metre) or more above adjacent floor or ground level should be guarded by adequate railing on all open sides except where there is entrance to a ramp, stairway, or fixed ladder. Open sides of all platforms, stairs, and floors require adequate railings. Loading ramps when not in use and above three (3) feet (one metre) in height should have a barrier (chain) to prevent falls from the loading dock.

11.38

Only safe elevated work platforms should be used to raise personnel. Safe platforms including adequate handrails, midrails, and toeboards should be provided on such platforms. "Temporary" platforms such as pallets, wooden boxes, and parts storage bins should not be used. Work platforms appropriate for the region should be used as designed, and within the platform manufacturer's guidelines, including inspection before use. Platforms should be designed to be mechanically secured to the lifting device. Refer to Section 11.8

11.39

Prior to elevating personnel in a work platform, the platform (i.e., baskets) should be secured to the lifting mechanism (forklift, raymond lift) so that the platform cannot become free of the lifting mechanism and fall to the floor. A chain or locking mechanism should be used. Adherence to forklift lifting capacities based on load weights and working heights should be followed. [Note: Work platforms should be lowered to floor level before the forklift travels. Additionally, mechanical-lifting devices should be inspected by a competent maintenance person at least annually.]

11.40

Ladders should be visually inspected prior to use for any damage or defects. Ladders that are either damaged or defective should be removed from service. The damaged or defective ladder should be marked or tagged so that it will not be used until it has been repaired or replaced.

11.41

Skylight floor openings should be guarded by a skylight screen or fixed railing on all exposed sides. Manhole floor openings should be guarded by a cover of sufficient strength and construction.

11.42

The facility should have a written policy and/or procedure on the subject of confined space entry. Record the date of issue. Examples of confined spaces are: compressed air tanks, fuel or solvent storage tanks, silos, catch basins. A written permit should be issued by the EHS person responsible for the confined space program. The entry procedures should include provisions for energy and hazardous materials

source isolation, testing of confined space atmosphere (oxygen, LEL, toxic air contaminants), ventilation, communications, entry and egress, and emergency rescue. [Note: Every effort should be made to avoid placing workers in confined spaces. Where work is required, a procedure for the specific area should be developed.] 11.43 Only trained employees should be permitted to enter confined space areas, or to assist another employee with work in a confined space area. Training records should be available to verify all training that has been conducted. 11.44 Recognized safety practices provide that a confined space entry process be followed to assure the safety of employees who must work in these spaces. All confined spaces must be identified by a posted sign stating Confined Spaces - Follow established entry procedure, in local language and also secured or locked to prevent unauthorized entry. Types of confined spaces include storage tanks, process vessels, diked tank farms, boilers, ovens, silos, underground trenches, and enclosed conveyors. Where possible, work inside confined spaces should be avoided. 11.45 Only trained employees should be authorized to operate a forklift or other powered industrial vehicle. Training records should be available to verify all training that has been conducted. Where there is a government requirement for operators to be certified, the operator should possess a certification card. 11.46 A daily visual and functional inspection of each forklift must be carried out and documentation of these inspections should be available. A mechanical inspection program should be implemented and forklifts should be inspected at least annually and record kept. [Note: Equipment defects should be corrected to ensure safe operation. Defective equipment should be removed from operations until fault is rectified.] 11.47 Stop signs, mirrors, and speed limit signs should be posted in forklift operation areas where pedestrians may be present. 11.48 Prior to entering trailers, the trailers must have their wheels chocked to prevent movement away from the dock. Dock-locks may be used to restrain trailers.

Section 11c. Environmental 11.49 Hazardous waste should be properly contained and stored. Review existing hazardous waste storage area to ensure drums of waste are stored with lids, rings, and / or bungs in place. Making sure that lids, rings, and / or bungs in place will protect against spills if the drum is tipped over. In the case of organic solvents, it prevents evaporation. It also prevents rain from entering drums. Inspections of drums should be conducted and drums should be free of leaks and major dents. All waste drums should have hazardous waste label in addition to appropriate hazard warning label(s). Inspections should be conducted weekly of the waste storage area. The storage area should also have appropriate clean-up equipment, a fire extinguisher, and the area should be labeled. Wastes should be stored to ensure that incompatible materials are not stored together. 11.50 Local laws may require certain types of hazardous wastes to be disposed of at special facilities. If that is the case, hazardous and toxic industrial wastes should be properly disposed of at government licensed

facilities where available. If such government licensed facilities are not available, hazardous wastes should be disposed of in accordance with the local laws. Check for evidence of current business license and operators license. Check to ensure contractor who removes and disposes of hazardous waste has the appropriate permits to do so. Documentation (manifests) for all shipments of hazardous waste is kept onsite in accordance with the local regulations. Check for waste manifests. It is recommended but not required that the generator inspects the facility where their waste is disposed. [Note: If the factory fails to comply with all major provisions of this section, the factory will have a reasonable period of time to develop a plan to comply with this section as part of the corrective action plan (Appendix III) and a reasonable period of time to implement this corrective action plan.] 11.51 Local laws may require a discharge permit or certificate for certain types of factory processes. If the facility discharges any industrial process waste water, they should have evaluated whether or not a water discharge permit or certificate is required. If they have a permit, they should ensure that they are in compliance with the requirements of the permit. [Note: If the factory fails to comply with major provisions of this section, the factory will have a reasonable period of time to develop a plan to comply with this section as part of the corrective action plan (Appendix III) and a reasonable period of time to implement this corrective action plan. It is acknowledged that significant actions and expenditures may be required in connection with this section that will take longer to implement than other aspects of a corrective action plan.] 11.52 Facilities that emit chemical vapors to the atmosphere should evaluate those discharge points and determine if they meet the requirements of the local laws and should have obtained an annual test report. If local laws require proper permits, these permits should be available. It is suggested that each location maintains a record of all openings and that the openings are numbered. The facility should understand the amount of emissions, which are sent through the stack or vent. [Note: If the factory fails to comply with all major provisions of this section, the factory will have a reasonable period of time to develop a plan to comply with this section as part of the corrective action plan (Appendix III) and a reasonable period of time to implement this corrective action plan. It is acknowledged that significant actions and expenditures may be required in connection with this section that will take longer to implement than other aspects of a corrective action plan.] 11.53 In connection with the discharge of sewage, facilities should clean out any septic system as frequently as appropriate consistent with the number of employees and the size of the septic system. If current sewage disposal practice does not comply with local law, a corrective action plan should be developed and implemented when community infrastructure is available to deal with the factorys sewage disposal. [Note: The facilities should have a regularly scheduled maintenance program for cleaning any septic system.]

Section 12a. Welfare-Dormitories

This section applies to facilities with dormitories only

12.1 Record the number of employees per room for informational purposes. It is recommended but not mandatory that the targeted number of persons per room should not exceed 12. It is recognized that

current facilities may not comply with this requirement. All new facilities should endeavour to have no more than 12 people to a room but must at a minimum comply with the requirements of 12.2. 12.2 Dormitory rooms should not be overcrowded. Determine how many persons are living in one room. The minimum amount of square footage allocated per employee should be 20 square feet (1.8 square metre) per person, which includes sleeping area, storage, and available floor space. 12.3 Toilet and shower or bath facilities should be provided with an adequate quantity for the dormitory facilities. A minimum of one (1) shower or bath stall and one (1) toilet per 12 employees should be available. For dormitories built prior to November 2000, the bath and toilet ratio can be up to 20 workers per one (1) shower or bath stall and one (1) toilet. Toilets, and whenever possible showers, should be on the same floor as that of the dormitory room. 12.4 Dormitory rooms, common areas, toilet, bath and shower facilities should all be maintained in a functional, clean condition, and be free of foul odor. Dormitory rooms should have a bed and personal storage area for each occupant. A secure storage area for items of value should be available. Adequate ventilation, including fans or heating as appropriate for the conditions should be available. There should be a program which ensures regular cleaning of the dormitory rooms, toilets, and shower areas. Employees should be provided some means of privacy while showering and using the toilet. The shower areas should have running water. Hot water should be available in a reasonable distance from the shower/bath areas. An effective flushing system (mechanical or manual) should be available. 12.5 12.6 Provisions should be made for residents to launder clothes in accordance with local expectations. Some provision for recreation, adequate for the number of residents, should be available. For example, this may include table tennis, video, library, television, etc. 12.7 The physical and structural integrity of all buildings should be assessed by a professional to ensure that the buildings are capable of and/or suitable for housing people within it. Local, regional or national regulations should be consulted to determine the qualifications or licensing needed to carry out such an assessment. The physical condition of buildings and surrounding property such as walls, floors, sidewalks, etc. should be maintained free of damage which can cause personal injury. Holes, uneven surfaces, and cracks can cause hazards if left in disrepair. A copy of assessment results should be maintained on file by site management. Record the date of issue. 12.8 Dormitories should have general rules for its residents and/or guests to follow. These rules may pertain to hours for recreation and use of common areas, etc., and also for the safety of residents. Determine if the dormitory has general resident and/or guest rules, including appropriate safety rules. Determine if the rules are posted, and if they are in the local language. 12.9 Determine if general dormitory rules indicate appropriate actions to take when rules are not properly followed. Actions should be consistent with Section 6.0-Disciplinary Practices. 12.10 Determine if the residents are permitted to enter and exit freely from their housing facilities during nonworking hours. It is recognized that curfew times may be in place for the safety and consideration of the residents. Record any curfew times if they exist. 12.11 Dormitory rooms, toilets, and showers should be separate for men and women. Management should recognize and provide for gender privacy in providing maintenance and supervision of dormitory areas.

12.12

Security provisions should be made to prevent unauthorized persons and vehicles from entering and exiting the dormitory area and to guard against theft at the site. Procedures should be in place for security personnel to conduct periodic rounds of the dormitory areas to ensure rules are being followed, potential fire hazards are eliminated, etc. Determine if dormitory rooms and storage space are kept locked for protection from theft, and determine who has access with key(s) to the area(s).

12.13

The dormitory should follow all fire emergency and emergency and preparedness in accordance with Section 10.0 Fire Protection.

Section 12b. Welfare - Canteen/Cafeteria Services 12.14 Facility should be aware of and determine what laws cover the preparation and service of food in commercial establishments. Inspection should be carried out annually at a minimum. Auditors should determine what laws are available covering food services and record the date of issue. All food service areas, equipment, and activities should meet the applicable laws, ordinances, and regulations of the jurisdiction in which they are located. A copy of the license, if applicable, should be present and of current date. Record license number and/or date of last government or agency inspection. 12.15 All food service areas and activities should be carried out in accordance with sound hygienic principles. The food dispensed should be wholesome, free from spoilage, and should be processed, prepared, handled, and stored in such a manner as to be protected against contamination. Food service personnel should ensure that multi-use food preparation, serving equipment and utensils are properly cleaned before they are reused. Food should be properly cooked. Food service personnel should effectively clean their hands before handling any food in order to prevent contamination. 12.16 Food service personnel should be trained in proper food handling and storage practices. Management should designate a person / persons in charge and ensure that such person is present at the food service area during hours of operation. 12.17 There should be a system in place that assures that personnel that handle, prepare, and/or serve food are in good health so as not to contaminate food with communicable diseases. Check if the health record is current. At a minimum, an annual physical exam record should be on file for all such employees. Employees who are found to have communicable diseases such as Hepatitis B or tuberculosis, must not be allowed to work in the food service area. 12.18 Food scraps and debris should be kept in containers and cleared of floor areas to prevent the likelihood of insects and vermin being attracted to the food preparation and storage areas. 12.19 Perishable food should be stored in appropriately temperature-controlled storage areas. Check the sign of spoilage and the expiry dates of the food if available to ensure that it is not expired. Care should be taken not to store cooked and uncooked food together.

Section 12c. Medical Services 12.20 The facility should have a written procedure on the subject of handling medical emergencies in compliance with local laws or where local laws do not exist, based on the advice of local medical authorities. The procedure should include provisions for providing emergency medical treatment, training for first-aid personnel, management and location of first-aid supplies. Record the date of issue. 12.21 Emergency medical treatment must be available to the facility. The medical service available can be an in-house or, at a nearby hospital, medical center, or clinic, located within a reasonable distance. The time to safely travel such distance in a medical emergency situation should be known, and ideally should not exceed 15-minutes. Where it is not possible due to the lack of such facilities, the location, time and distance to the nearest facility should be known and posted to ensure that the shortest time for a transfer is effected. If the medical service available to the facility is in-house, it should be staffed by medical personnel trained for common industrial emergencies and operated in accordance with local laws and standards. 12.22 The facility should maintain injury and illness records. Records should include date of injury, name of injured person and a description of the injury and its causes. Effort should be taken to identify the root cause as well as any other conditions. It is preferable that an injury and illness log be maintained so as to evaluate for trends, and for calculating injury/illness statistics. These logs should be analyzed periodically to identify occurrences or trends and for corrective action determination and evaluations. 12.23 Each shift should be adequately staffed if the facility is relying upon in-house personnel to handle medical emergencies. Medical staff members or selected employee(s) should have current first aid and / or cardiopulmonary resuscitation (CPR) training. At a minimum, in smaller facilities, two (2) persons per shift should have current first aid and / or CPR training. Larger facilities would require proportionally more first aid and / or CPR trained personnel, 1 percent. 12.24 First aid supplies should be available at the facility. At a minimum, these should consist of a standard first aid kit to include the followings (Note: No prescription medication intended to be taken by mouth is to be found in the first aid box). For locations with less than 50 employees, please refer to Column One. For locations with over 50 employees and for each 100 employees, please refer to Column Two. Suggested Components Copy of first aid hints Booklet in local language Sterile un-medicated dressings - small size for injured fingers - medium size for injured hands or feet Adhesive wound dressings of assorted sizes Triangular bandages of unbleached calico with the longest side not less than 1.3 metres and each of the other sides not less than 0.9 metres Roll of adhesive plaster (zinc oxide) at least 4.5 metres (long) x 25 mm (wide) 1 1 2 4 6 3 12 12 6 24 1 1 Column One Column Two

Packets of absorbent cotton wool each of 30 g Pressure bandage Safety Pins Dressing Scissors Disposable Gloves

3 1 a sufficient quantity 1 pr a sufficient quantity

6 1

1 pr

First aid stations should be posted with a first aid sign. First aid supplies should be located such that they are reasonably available in the facility and dormitories. In cases where first aid supplies are locked for security reasons, the supplies must be accessible to the first aid and CPR staff within 3 minutes. At a minimum, one first-aid kit per production floor is required. 12.25 The facility should have a documented process to prevent the potential transmission of communicable diseases from contact with body fluids. The documented process should include the identification of job classifications, which may have exposure to blood borne pathogens, (i.e., nurses, first aid personnel, janitorial staff), medical and first aid staff training, handling and disposal of blood contaminated waste, needles, or other biohazardous waste, to prevent a potential transmission of communicable diseases through contact with blood. 12.26 The facility should be segregating all medical waste from other waste, and disposing of it in a manner that prevents accidental contact or contamination. This could be accomplished by labeling and disposing of such medical waste through incineration at local hospital. The disposal of needles should be into containers labeled to indicate that it contains sharp objects. Blood-contaminated waste disposal should be in accordance with local regulations.

Exhibit A (see 9.15) NOTE : "*" "**" The MCL (Maximum Contaminant Level) or an established guideline has been exceeded for this contaminant. Bacteria results may be invalid due to lack of collective information or because the sample has exceeded the 30-hour holding time. "ND" "NBS" "P" "A" "EP" "EA" This contaminant was not detected at or above our stated detection level. No bacteria submitted = Presence = Absence = Ecoli Presence = Ecoli Absence

MCL Analysis Performed Total coliform Inorganic chemicals - metals : Aluminum Arsenic Barium Cadmium Chromium Copper Iron Lead Manganese Mecury Nickel Selenium Silver Sodium Zinc Inorganic chemicals and physical factors : Alkalinity (Total as CaCO3 Chloride Fluoride Nitrate as N Nitrite as N Sulfate Hardness (suggested limit = 100) pH (standard Units) Total Dissolved Solids Turbidity (Turbidity Units) Organic Chemicals - trihalomethanes : Bromoform 0.080 250 4 10 1 250 6.5-8.5 500 1.0 0.2 0.05 2 0.005 0.1 1.3 0.3 0.015 0.05 0.002 0.1 0.05 0.1 5 (mg/l) P

Detection Level P

0.1 0.01 0.3 0.002 0.01 0.004 0.02 0.002 0.004 0.001 0.02 0.02 0.002 1.0 0.001

20.0 5.0 0.5 0.5 0.5 5.0 20.0 0.1

0.004

Bromodichloromethane Chloroform Dibromochloromethane Total THM's (sum of four above)

0.080 0.080 0.080 0.080

0.002 0.002 0.004 0.002

MCL Analysis Performed Benzene Vinyl Chloride Carbon Tetrachloride 1.2-Dichloroethane Trichloroethene (TCE) 1.4-Dichlorobenzene 1.1-Dichloroethane 1.1.1-Trichloroethane Bromobenzene Bromomethane Chlorobenzene Chloroethane Chloromethane 2-Chlorotoluene 4-Chlorotoluene Dibromochloropropane (DBCP) Dibromomethane 1.2-Dichlorobenzene 1.3-Dichlorobenzene Dichlorofluoromethane 1.1-Dichloroethane Trans-1.2-Dichloroethane Cis-1.2-Dichloroethane Dichloromethane 1.2-Dichloropropane Trans-1.3-Dichloropropane (mg/l) 0.005 0.002 0.005 0.005 0.005 0.075 0.007 0.2 0.1 0.6 0.6 0.1 0.07 0.005 0.005 -

Detection Level 0.001 0.001 0.001 0.001 0.001 0.001 0.001 0.001 0.002 0.002 0.001 0.002 0.002 0.001 0.001 0.001 0.002 0.001 0.001 0.002 0.002 0.002 0.002 0.002 0.002 0.002

Cis-1.3-Dichloropropane 2.2-Dichloropropane 1.1-Dichloropropane 1.3-Dichloropropane Ethrylbenzene Ethrylenedibromide (EDB) Styrene 1.1.1.2-Tetrachloroethane 1.1.2.2-Tetrachloroethane Tetrachloroethane (PCE) 1.2.3-Trichlorobenzene 1.2.4-Trichlorobenzene 1.1.2-Trichloroethane Trichlorofluoromethane 1.2.3-Trichloropropane Toluene Xylene Methyl-Tert-Butyl-Ether

0.7 0.1 0.005 0.07 0.005 1 10 -

0.002 0.002 0.002 0.002 0.001 0.001 0.001 0.002 0.002 0.002 0.002 0.002 0.002 0.002 0.002 0.001 0.001 0.004

Organic Chemicals - pesticides, herbicides and PCB's Alachlor Atrazine Chlordane Aldrin Dichloran Dielldrin Endrin Heptachior Heptachior Epoxide Hexachlorobenzene Hexachlorocyclopentadiene Lindane Methoxychlor PCB's 0.002 0.003 0.002 0.002 0.0004 0.0002 0.001 0.05 0.0002 0.04 0.0005 0.001 0.002 0.001 0.002 0.002 0.001 0.0001 0.0004 0.0001 0.0005 0.001 0.0002 0.002 0.0005

Pentachloronitrobenzene Silvex (2.4.5-TP) Simazine Toxaphene Trifluralin 2.4-D

0.05 0.004 0.003 0.07

0.002 0.005 0.002 0.001 0.002 0.010

These test results are intended to be used for informational purposes only and must not be used for regulatory compliance.

Appendix - Notes for Factories The following notes are recommendations for factories being audited to follow, but not part of the guidelines for auditors. The factories should read these notes in conjunction with the corresponding provisions in Appendix II Guidance Document. Provision 9.5 Note Preventive maintenance is the orderly, uniform, continuous and scheduled action to prevent breakdown and prolong the safe and useful life of machinery, equipment, and facilities systems. A maintenance services schedule should be provided for each piece of equipment and a record kept of all repairs carried out itemizing parts used or repaired and the name of person who did the work. 10.1 Contracting companies are likely to require a recovery strategy as well as emergency safety strategy. A recovery strategy should include plans to restore the operations. This should include a list of contractors who can provide equipment and services for operations. Additional consideration should be given to temporary contractors who can provide manufacturing services. 11.2 An E.H.S. policy could include some or all of the followings: General Note----Environmental Health and Safety-(E.H.S.) policy Implementation of an effective E.H.S. program should lead to a reduction of workplace illness and injury, minimizing the costs associated with workplace accidents. The success of an E.H.S. program depends on commitment from all levels and functions within the organization to:

Develop an E.H.S. policy

Implement program to support policy

Measure effectiveness of program

Review results and the corrective actions, strive for continual improvement.

The object of an E.H.S. program is to develop and implement control actions which, whenever possible, eliminate hazards or isolate people from the hazard. Where this is not possible, work activities should be planned and controlled through administrative means to an extent necessary to prevent injury and illness. (Insert Company Name) is committed to establishing through a process of continual improvement a safe, healthy and environmentally responsible workplace for our employees and to the community. We will

provide a continuous improvement strategy to drive the company toward achieving safety and environmental excellence.

progressively comply with all relevant regulatory standards.

integrate environmental, health and safety standards into our facilities to reduce risks, and strive to create an incident free workplace.

appoint an E.H.S. coordinator to manage these policies objectives.

engage in dialogue with our employees to address their environmental, health and safety concerns relating to our facility.

assess environmental, health and safety performance with regularly scheduled audits of our facilities.

11.3

The EHS coordinator assists facility management in establishing, developing, and administering the environmental, health, and safety process.

11.4

EHS team members provide guidance, encourage EHS awareness and interest, and actively promote employee involvement to assist the facility management in implementing, evaluating, and improving the workplace EHS system.

11.6

Understanding the steps, hazards, and controls of a new job can prevent a worker from potentially injuring themselves or others.)

11.12

MSDS example is provided hereinafter for reference purpose. MSDS are intended to outline the characteristics, chemical components, the potential risks associated with the exposure and the precautions which are necessary in the use, handling and storage of hazardous chemicals. The availability and accessibility of the MSDS implies the availability and accessibility of information that will be understandable to the employee.

11.13

The elements of the inventory should include chemical trade name, ingredients, percentage of

ingredient, CAS number (Chemical Abstract Service Registry Number) or national equivalent, where used or stored, potential hazard, date of MSDS. This information would be used in evaluating hazards, training employees, hazardous waste disposals, air and water permitting, spill assessment and cleaned-up. 11.16 An example of an accident/near miss investigation report is provided hereinafter for reference purpose.

MATERIAL SAFETY DATA SHEET 11W7553 PRODUCT NAME: WATERBASE WHITE #43401602 PRODUCT CODE: 11W7553 Page 1 HMIS CODEES: H F R P 100G

================== SECTION I - MANUFACTURER IDENTIFICATION ==================== MANUFACTURERS NAME: COATINGS RESOURCE CORPORATION ADDRESS : 15541 COMMERCE LANE HUNTINGDON BEACH, CA 92649 EMERGENCY PHONE: (800) 535-5053 INFORMATION PHONE: (714) 894-5252 DATE PRINTED: 05/03/99 NAME OF PREPARER:

============ SECTION II - HAZARDOUS INGREDIENTS/SARA III INFORMATION ============= VAPOUR PRESSURE HAZARDOUS COMPONENTS *ETHYLENE GLYCOL MONOBUYTL ETHER OSHA PEL: 50ppm, ACGIH TLV: 25ppm, OTHER: 75ppm *N-METHYL-2-PYRROLIDONE 872-50 0.3 68f 0-5% CAS NUMBER 111762 mm .6 WEIGHT Hg @ TEMP 68f PERCENT 5-10%

*Indicates toxic chemical(s) subject to the reporting requirements of section 313 of Title III and of 40 CFR 372

=============== SECTION III - PHYSICAL/CHEMICAL CHARACTERISTICS ================= BOILING RANGE: 212-338 Deg F VAPOUR DENSITY: LIGHTER THAN AIR COATING V.O.C.: 2.40lb/gl SOLUBILITY IN WATER: SOLUBLE APPEARANCE AND ODOR: VISCOUS LIQUID WITH SLIGHT AMMONIA ODOR SPECIFIC GRAVITY (H20=1): 1.21 EVAPORATION RATE: SLOWER THAN ETHER MATERIAL V.O.C.: 1.04 lb/gl

================ SECTION IV - FIRE AND EXPLOSION HAZARD DATA ================== FLASH POINT: N/A METHOD USED:

FLAMMABLE LIMITS IN AIR BY VOLUME-LOWER 1.3

UPPER: 9.5

EXTINGUISHING MEDIA: FOAM, CO2, DRY CHEMICAL, WATER FOG, OTHER

SPECIAL FIREFIGHTING PROCEDURES WEAR SELF-CONTAINED BREATHING APPARATUS WITH FULL FACEPEICE WATER CAN BE USED TO COOL CONTAINERS.

UNUSUAL FIRE AND EXPLOSION HAZARDS THIS PRODUCT WILL NOT SUPPORT COMBUSTION UNLESS ALL THE WATER HAS EVAPORATED

======================= SECTION V - REACTIVITY DATA ========================= STABILITY: STABLE CONDITIONS TO AVOID AVOID FREEZING, STORE IN LINED OR PLASTIC CONTAINERS, DO NOT MIX WITH SOLVENT BASED MATERIAL

INCOMPATIBILITY (MATERIALS TO AVOID) AVOID CONTACT WITH STRONG OXIDIZING AGENTS

HAZARDOUS DECOMPOSITION OR BYPRODUCTS NORMAL COMBUSTION PRODUCTS INCLUDING CARBON DIOXIDE, CARSON MONOXIDE, AND OF NITROGEN

HAZARDOUS POLYMERIZATION: WILL NOT OCCUR

===================== SECTION VI - HEALTH HAZARD DATA ======================= INHALATION HEALTH RISKS AND SYMPTONS OF EXPOSURE VAPORS MAY BE IRRITATING TO THE NOSE, THROAT, AND RESPIRATORY TRACT, HIGH VAP CONCENTRATIONS MAY CAUSE CENTRAL NERVOUS SYSTEM DEPRESSION SUCH AS HEADA DIZZINESS, FATIGUE NAUSEA, POSSIBLE UNCONSCIOUSNESS, EVEN ASPHYXIATION.

SKIN AND EYE CONTACT HEALTH RISKS AND SYMPTONS OF EXPOSURE EYES - CAN CAUSE SEVERE IRRITATION, REDDNESS, TEARING, BLURRED VISION SKIN-PROLONGED OR REPEATED EXPOSURE CAN CAUSE MODERATE IRRITATION OR MAY CAUSE SKIN.

SKIN ABSORPTION HEALTH RISKS AND SYMPTONS OF EXPOSURE PROLONGED OR REPEATED EXPOSURE CAN CAUSE IRRITATION, DRY SKIN THROUGH THE DEFATTING ACTION OF THE MATERIAL, OR POSSIBLY DERMATITIS.

INGESTION HEALTH RISKS AND SUMPTONS OF EXPOSURE CAN CAUSE GASTROINTESTINAL IRRITATION, NAUSEA, VOMITING, OR DIARRHEA. VOMITING CAN CAUSE ASPIRATION OF INGESTED FLUID, SMALL QUANTITIES OF WHICH MAY RESULT IN ASPIRATION PNUEMONITIS.

HEALTH HAZARDS (ACUTE AND CHRONIC) ACUTE MAY CAUSE EYE, NOSE, RESPIRATORY TRACT & SKIN IRRITATION. HEADACHE AND NAUSEA ARE ALSO SYMPTOMS OF OVER EXPOSURE CHRONIC-SOLVENT CAN BE TOXIC B ABSORBTION OVEREXPOSURE IN SOME LABORATORY ANIMALS HAS CAUSED DAMAGE

TO K LIVER & RED BLOOD CELLS.

CARCINOGENICITY: NTP CARCINOGEN: No IARC MONOGRAPHS: No OSHA REGULATED N NOT CARCINOGENIC

MEDICAL CONDITIONS GENERALLY AGGRAVATED BY EXPOSURE RESPIRATORY CONDITIONS, PRE-EXISTING SKIN DISORDERS, LIVER OR KIDNEY DISEASE.

EMERGENCY AND FIRST AID PROCEDURES EYE CONTACT-FLUSH WITH LARGE AMOUNTS OF WATER, IF IRRITATION PERSISTS GET IMMEDIATE MEDICAL ATTENTION. SKIN CONTACT - WASH EXPOSED AREA. REMOVE CONTAMINATED CLOTHING. IF IRRITATION PERSISTS GET PROMPT MEDICAL ATTENTION. INGESTION - DO NOT INDUCE VOMITING; IF VOMITING OCCURS SPONTANEOUSLY, KEEP HEAD LOWER THAN HIPS TO AVOID ASPIRATION OF FLUID INTO LUNGS. GET IMMEDIATE MEDICAL ATTENTION, INHALATION - REMOVE TO FRESH AIR, RESTORE BREATHING IF NECESSARY. TREAT SYMPTONS. GET IMMEDIATE MEDICAL ATTENTION.

=========== SECTION VII - PRECAUTIONS FOR SAFE HANDLING AND USE ============ STEPS TO BE TAKEN IN CASE MATERIAL IS RELEASED OR SPILLED REMOVE ALL SOURCES OF IGNITION, DIKE SPILL AREA, PUMPOUT LIQUID OR ADD ASBORBANT AND DISPOSE OF MATERIAL PROPERLY (SEE BELOW). VENTILATE AREA WELL. INFORM AUTHORITES IF MATERIAL ENTERS SEWERS, WATERCOUSES, OR LAND AREAS.

WASTE DISPOSAL METHOD DISPOSE OF MATERIAL IN A MANNER APPROVED BY LOCAL, STATE, AMD FEDERAL REGULATION. BEFORE ATTEMPTING CLEAN-UP, REFER TO HAZARD CAUTION INFORMATION OTHER SECTIONS OF THIS SHEET.

PRECAUTIONS TO BE TAKEN IN HANDLING AND STORING USE PROPER STORAGE TECHNIQUES AND STORE AWAY FROM HIGH TEMPERATURES, SPA OPEN FLAME. KEEP CLOSURE TIGHT AND UPRIGHT TO PREVENT LEAKAGE, CONTAINERS, EVEN THOSE THAT HAVE BEEN EMPTIED, CAN CONTAIN EXPLOSIVE VAPORS. DO NOT CUT, DRILL, WELD, GRIND, ON OR NEAR CONTAINERS.

OTHER PRECAUTIONS WARNING - DETECTABLE AMOUTS OF CHEMICALS KNOWN TO THE STATE OF CALIFONIA TO CAUSE CANCER, BIRTH DEFECTS, OR REPRODUCTIVE HARM MAY BE FOUND IN THIS PRODUCT PROPOSTITION 65 OF THE CALIFORNIA HEALTH & SAFETY CODE (SECTION 25249). THIS MATERIAL SHOULD BE USED AFTER ALL SAFETY PRECAUTIONS ARE READ AND UNDERSTOOD EVERYONE HANDLING THE MATERIAL. DO NOT WEL OR FLAME CUT EMPTY CONTAINERS. KEEP AWAY FROM CHILDREN.

==================== SECTION VIII - CONTROL MEASURES =================== RESPIRATORY PROTECTION IF THE TLV OF THE PRODUCT OR ANY COMPONENT IS EXCEEDED, A NIOSH/MSHA APPROVE AIR SUPPLIED RESPIRATOR IS ADVISED IN THE ABSENCE OF PROPER ENVIRONMENTAL CONTROL. ENGINEERING OR ADMINISTRATIVE CONTROLS SHOULD BE IMPLEMENTED TO RE EXPOSURE. OTHERWISE AN APPROVED CHEMICAL.MECHANICAL FILTER RESPIRATORY MAY BE USED.

VENTILATION PROVIDE SUFFICIENT MECHANICAL, VENTILATION (GENERAL AND/OR LOCAL EXHAUST) TO MAINTAIN EXPOSURE BELOW THRESHOLD LIMIT VALUES.

PROTECTIVE GLOVES NON-SOLUBLE PLASTIC; RECOMMENDED FOR PROLONGED EXPOSURE

EYE PROTECTION CHEMICAL SPLASH GOGGLES IN COMPLIANCE WITH OSHA STANDARDS ARE ADVISED

OTHER PROTECTIVE CLOTHING OR EQUIPMENT OTHER PROTECTIVE EQUIPMENT THAT MAY BE NECESSARY TO PREVENT REPEATED OR PROLONGED EXPOSURE SHOULD COMPLY WITH OSHA STANDARDS

WORK/HYGIENIC PRACTICES WASH HANDS BEFORE EATING OR USING THE RESTROOM, SMOKE IN DESIGNATED AREAS, SAFETY SHOWER SHOULD BE AVAILABLE.

=========================== SECTION IX - DISCLAIMER ============================ THE INFORMATION CONTAINED HEREIN IS BASED ON THE DATA AVAILABLE TO US AND IS BELIEVED TO BE CORRECT, COATINGS RESOURCE CORP MAKES NO WARRANTY, EXPRESS IMPLIED, REGARDING THE ACCURACY OF THIS DATA OR THE RESULTS TO BE OBTAINED FROM THE USE THEREOF. COATINGS RESOURCE CORP. ASSUMES NO RESPONSIBILTY FOR INJURY FROM THE USE OF THIS PRODUCT.

ACCIDENT/NEAR MISS INVESTIGATION REPORT [ ] Injury/Illness A d m i n i s t r a t i o n M e d i c Disposition: [ ] Return to Work [ ] Sent Home [ ] Sent to Hospital Injury Classification: [ ] Fatality [ ] Medical Treatment [ ] Days Away from Work [ ] First Aid [ ] Restricted Work Witness Name (s) : _______________________________________________________________ Occupation : __________________ Years with Company : _______ Years in Present Occup : ______ Sex : M F Age : _____________ Employees Supervisor : ___________________________ Name of Person(s) involved : __________________ SSN : ____________ Employee ID # : _______ Day Accident Occurred : M Tu W Th F Sa Su Occurred During Overtime: Yes No Accident location : ____________________ Accident Date : _______ Time of Accident : _________ [ ] Property Damage [ ] Near Miss [ ] Other

Plant : ____________________ Department : ___________________ Shift : __________________

[ ] Sent to Outside Medical

a l Description of Injury/Illness : ____________________________________________________________________________

Body Part(s) Affected : _________________________________________________________________________________

Medical Treatment Applied : _____________________________________________________________________________ P r o p e r t y D e s c r i p t i o n MARK ALL APPLICABLE BOXES Immediate Causes Unsafe Practices [ ] Hurrying to save time [ ] Operating without Authority [ ] Failure to warn [ ] Failure to secure [ ] Improper speed [ ] Making safety device inoperative [ ] Using defective equip./tools [ ] Using equip./tools improperly [ ] Failure to use PPE [ ] Inadequate PPE used [ ] Servicing equip. in Unsafe Conditions [ ] Poor ergonomic design [ ] Inadequate guards [ ] Poorly designed equip./tools [ ] Faulty/damaged equipment [ ] Energized equipment [ ] Congestion [ ] Poor arrangement [ ] Inadequate warning system [ ] Inadequate ventilation [ ] Hazardous atmosphere [ ] Poor illumination [ ] Poor housekeeping [ ] Slip-fall hazard [ ] Other Root Causes [ ] Procedure not established [ ] Procedure not known or understood [ ] Procedure not followed [ ] Procedure inadequate [ ] Lack of training [ ] Lack of supervision [ ] Inadequate communication [ ] Insufficient planning [ ] Lack of knowledge [ ] Lack of skill [ ] Lack of enforcement [ ] Workload too heavy [ ] Avoiding discomfort [ ] Avoiding effort System Improvements [ ] Management responsibility and accountability [ ] Management training [ ] Planned inspections [ ] Job safety analysis [ ] Accident/near miss investigation [ ] Job safety observations [ ] Emergency preparedness [ ] Safe work practices [ ] Accident analysis [ ] Employee training [ ] Personal protective equipment [ ] Health control programme Description of Damage: _________________________________________________________________________________ _____________________________________________________________________________________________________ _____________________________________________________________________________________________________ _____________________________________________________________________________________________________ Description of Accident: _________________________________________________________________________________ _____________________________________________________________________________________________________ _____________________________________________________________________________________________________ _____________________________________________________________________________________________________ _____________________________________________________________________________________________________ _____________________________________________________________________________________________________ _____________________________________________________________________________________________________ _____________________________________________________________________________________________________ _____________________________________________________________________________________________________ _____________________________________________________________________________________________________ Type of Damage: [ ] Building [ ] Tools [ ] Fixed Equipment [ ] Materials [ ] Motor Vehicle [ ] Product

[ ] Material Handling Equipment

C a u s e

A n a l y s e s

operation [ ] Failure to lockout [ ] Horseplay [ ] Overexertion while lifting, pulling, pushing or reaching [ ] Changing position suddenly [ ] Positioned body in striking area of hazard [ ] Other

[ ] Physically impaired [ ] Influence of emotions [ ] Influence of fatigue [ ] Influence of illness [ ] Influence of drugs or alcohol [ ] Other

[ ] Evaluation & Measurement [ ] Engineering controls [ ] Communications [ ] Group meetings [ ] Hiring & placement [ ] Rule enforcement [ ] Housekeeping [ ] Other

Immediate Causes (explain) : ____________________________________________________________________________ _____________________________________________________________________________________________________ _____________________________________________________________________________________________________

Root Causes (explain) : _________________________________________________________________________________ _____________________________________________________________________________________________________ _____________________________________________________________________________________________________

System Improvements (explain) : _________________________________________________________________________ _____________________________________________________________________________________________________ _____________________________________________________________________________________________________

Corrective Actions : ____________________________________________________________________________________ _____________________________________________________________________________________________________ _____________________________________________________________________________________________________

Target Completion Date : ________________ C o s t s A p p r o v a l Direct Costs [ ] Medical Expenses [ ] Building damage [ ] Material damage [ ] Other [ ] Legal expenses

Completion Date : ________________ Indirect Costs [ ] Production delay [ ] Training replacement [ ] Clerical [ ] Co-workers time (Print) (Sign) [ ] Investigation time [ ] Repairs [ ]Injured workers time [ ]Other (Date)

[ ] Equipment/Tool damage [ ] Product damage

Investigator/Supervisor: : ________________________________________________________________________________

Department Manager approval : ___________________________________________________________________________

Safety Manager/Coordinator Approval : _____________________________________________________________________

ATTACH ADDTIONAL DOCUMENTATION AS REQUIRED