DATE : January 15, 2018

TO : CORPORATE HRAD

SIR:

In connection with the Notice to Explain served to me through email by Mr. Nigel Sean
Marcelino last January 9, 2018, which pertains to the 4th Quarter Safety Audit Findings dated
November 21, 2017 vis-à-vis with 3rd Quarter Safety Audit last July 7, 2017.

First and foremost, taking the additional remarks of the 3rd Quarter Safety Audit which
were stated at the recommendation were:

 Faded Sign of MCC Area

 Additional Safety Sign at the Storage Tank Area.

The faded sign was already rectified as seen in the picture attached below. However,
additional safety signs were verbally requested to the TSD-NLO personnel who exclusively
layouts those but until now they were not able to prioritize it due to amass maintenance work.

Second, as to the 4th Quarter Safety Audit Findings, my respective positions on these
findings are as follows:

a. Health and Safety Committee and Fire Brigade Team not updated.

I understand that I overlooked this because of the minor changes of personnel affected
by the manpower arrangement initiated by NLO-HRAD and due to large volume of customers
that we were accommodating in this last quarter. So in this regard, I did not fix yet the final
organizational structure of Health and Safety Committee and Fire Brigade Team as well, to
members who are temporarily assign in this plant.

b. No evacuation map plan and location map of fire extinguishers.

“No evacuation map plan” this finding was not expressly stated on the last 4th Quarter
Safety Audit report nor I was inform with this.

As to the “location map of fire extinguishers”, I do not think that this was not complied
because it was apparently located near the guardhouse even before I assumed the supervisory
in this plant. See the actual picture below for orientation.
 c. Fire extinguishers are not regularly updated.

I would like to dissent on this matter because I and my checker/inspectors personally

inspected it and there is a month which I skipped to record on it’s tagged for the reason that I
was on leave during this days (October 22 to November 20, 2017). However, there are fire
extinguishers which are not labeled anymore because it was already depressurized and subject
for refill.

d. No marking symbol at the BFG grounding.

I did not indicate yet the marking symbol at the BFG grounding because the grounding
itself was non-existent. Nevertheless, I already request to the TSD-NLO personnel to install
grounding to places that the same should be necessarily installed for purposes of safety.

e. No operating procedure of fire pump.

This finding was erroneously alleged because there was no installed fire pump in this
plant.

In light of the above respective positions on the findings, I think I already rest my case.
Nevertheless, for purposes of safety which is our primordial concern, I myself as a safety officer
of this plant duty bound to implement such with strict and utmost observance on the safety
policies of the company pursuant to the Rules of Occupational Safety and Health Standards set
forth by the Department of Labor and Employment.

Respectfully,

MARK ARTEM APALLA

Operation Supervisor
Sta.barbara Plant