Recycling Services in Health and Safety Manual

Access to Medical Records

PURPOSE

All employers who maintain medical records and/or exposures records which document that employee’s
are or were exposed to toxic substances and/or harmful physical agents must comply with OSHA
Standard 29 CFR 1910.1020, which requires the establishment of procedures to ensure right of access
to relevant exposure and medical records to employees, their designated representatives, and/or
representatives of the OSHA.

This section applies to all employee exposure and medical record, and analysis thereof, made or
maintained in any manner, including on an in-house or contractual (e.g., fee-for-service) basis.
Each employer shall assure that the preservation and access requirements of this section are
complied with regardless of the manner in which records are made or maintained.

RESPONSIBILITIES

The Management Representative has the responsibility to ensure conformance with this program.

DEFINITIONS

A. Access

Access means the right and opportunity to examine and copy.

B. Analysis using exposure or medical records

Analysis using exposure or medical records means any compilation of data or any statistical study
based, at least in part, on information collected from individual employee exposure or medical
records or information collected from health insurance claim records, provided that either the
analysis has been reported to the employer or no further work is currently being done by the person
responsible for preparing the analysis.

C. Designated representative

Designated representative means any individual or organization to whom an employee gives written
authorization to exercise a right of access. For the purposes of access to employee exposure records
and analyses using exposure or medical records, a recognized or certified collective bargaining
agent shall be treated automatically as a designated representative without regard to written
employee authorization.

D. Employee

Employee means a current employee, a former employee, or an employee being assigned or transferred to
work where there will be exposure to toxic substances or harmful physical agents. In the case of a
deceased or legally incapacitated employee, the employee’s legal representative may directly
exercise all the employee’s rights under this section.

E. Employee exposure record

Employee exposure record means a record containing any of the following kinds of information:

1. Environmental (workplace) monitoring or measuring of a toxic substance or harmful physical
   agent, including personal, area, grab, wipe, or other form of sampling, as well as related
   collection and analytical methodologies, calculations, and other background data relevant to
   interpretation of the results obtained;
2. Biological monitoring results which directly assess the absorption of a toxic substance or
   harmful physical agent by body systems (e.g., the level of a chemical in the blood, urine,
   breath, hair, fingernails, etc.) but not including results which assess the biological effect of
   a substance or agent or which assess an employee’s use of alcohol or drugs;
3. Safety Data Sheets indicating that the material may pose a hazard to human health, or
4. In the absence of the above, a chemical inventory or any other record which reveals where and
   when used and the identity (e.g., chemical, common, or trade name) of a toxic substance or
   harmful physical agent.

F. Employee medical record

Employee medical record means a record concerning the health status of an employee which is made or
maintained by a physician, nurse, or other health care professional or technician, including:

1. Medical and employment questionnaires or histories (including job description and occupational
   exposures),
2. The results of medical examinations (pre-employment, pre-assignment, periodic, or episodic) and
   laboratory tests (including chest and other X-ray examinations taken for the purpose of
   establishing a base-line or detecting occupational illnesses and all biological monitoring not
   defined as an “employee exposure record”),
3. Medical opinions, diagnosis, progress notes and recommendations,
4. First aid records,
5. Description of treatments and prescriptions, and
6. Employee medical complaints.

ACCESS TO RECORDS

The Management Representative will maintain applicable medical and exposure records for all
employees. All requests to access medical and exposure records and analysis based on those records
must be submitted to the Human Resources Department using the forms provided for that purpose.

• The Management Representative will assure access of each employee and/or their designated
  representative, to all exposure and medical records concerning the employee’s work conditions or
  workplace within 15 working days from the day request is made.
• Employees, their representatives, or recognized collective bargaining agents will be provided
  with one copy of the records at no cost.
• The employee is entitled access to his or her medical records except when a physician determines
  that this knowledge would be detrimental to the employee’s health.

RECORD RETENTION

Employee medical records shall be preserved and maintained for at least the duration of employment
plus thirty (30) years.

Employee exposure records shall be preserved and maintained for at least thirty (30) years.

Permit Required Confined Space Program

I. Purpose

The comprehensive Permit Required Confined Space Program is developed to protect personnel entering a
confined space. Interco Trading Company employees will not enter a confined space. If work is
required in a confined space, a subcontractor will be hired, who will employ necessary procedures to
enter permit-required confined spaces during the course of their work.

The program is intended to fulfill the requirements of the permit required confined space standard
set forth by the Occupational Safety and Health Administration (OSHA) in 29 CFR 1910.146.

II. Scope and Application

This program includes certain aspects of a permit required confined space entry program as described
in 29 CFR 1910.146, including: identification and classification of spaces, posting or
identification of spaces, responsibilities and duties, contractor requirements, and review of
program.

III. Definitions

Acceptable entry conditions

The conditions that must exist in a permit space to allow entry and to ensure that employees involved
with a permit-required confined space entry can safely enter into and work within the space.

Confined space

A space that meets all three of the following criteria:

• It is large enough and so configured that an employee can bodily enter and perform assigned
  work; and
• Has limited or restricted means for entry or exit; and
• Is not designed for continuous occupancy.

Permit-required confined space

A confined space that has one or more of the following characteristics:

• Contains or has a potential to contain a hazardous atmosphere.
• Contains a material that has the potential for engulfing an entrant;
• Has an internal configuration such that an entrant could be trapped or asphyxiated by inwardly
  converging walls or by a floor which slopes downward and tapers to a smaller cross-sections; or
• Contains any other recognized serious safety or health hazard.

IV. Types of Confined Spaces

Permit Required Confined Spaces

Examples of Permit Required Confined Spaces at Interco Trading Company include:

As of July 18, 2013, the bailer is the only Permit Required Confined Space identified at Interco
Trading Company.

Non-Permit Required Confined Spaces

A Non-Permit Confined Space contains only secondary hazards which are not anticipated to cause death
or other serious physical harm under normal operating conditions.

V. Roles and Responsibilities

The Warehouse Manager shall be responsible for training all employees that entry into permit-required
confined spaces is not allowed.

The Warehouse Manager shall also notify any contractors working in permit-required confined spaces of
Interco Trading Company.

Emergency Action & Fire Prevention

PURPOSE

This plan is intended to meet the requirement of OSHA Standard 29 CFR 1910.1038, 1039 and 151, which
requires employers to develop an Emergency Action and Fire Prevention Plan and ensure the
availability of medical and first aid. The plan shall be in writing, kept in the workplace, and
available to employees for review.

RESPONSIBILITIES

The Management Representative has the responsibility to ensure conformance with this program.

EMERGENCY ACTION AND FIRE PREVENTION PLAN

The Interco Emergency Action and Fire Prevention Plan includes:

• Medical Emergency Response Procedures
• Fire Response Procedures
• Spill Response Procedures
• Severe Weather Response Procedures

MEDICAL SERVICES AND FIRST AID

Interco shall ensure the ready availability of medical personnel for advice and consultation on
matters of warehouse health.

Interco uses Anderson Hospital: Emergency Room for medical emergencies. Anderson Hospital: Emergency
Room is approximately nine miles from Interco Trading Company in Edwardsville, IL.

Adequate first aid supplies, including first aid kit and eyewash shall be readily available. The
First Aid Kit is available outside the E-scrap supervisors Office (east end of bldg.).

FIRE HAZARDS

1. Electrical Fire Hazards

To prevent electrical fires, employees shall:

• Make sure that worn wires are replaced.
• Use only appropriately rated fuses.
• Never use extension cords as substitutes for wiring improvements.
• Use only approved extension cords (UL or FM label).
• Check wiring in hazardous locations where the risk of fire is especially high.
• Check electrical equipment to ensure that it is either properly grounded or double insulated.

2. Heat Producing Equipment

All heating equipment will be maintained per the manufactures recommendations and industry practices.

All portable heaters shall be approved by the Warehouse Manager. Portable electric heaters shall have
tip-over protection that automatically shuts off the unit when it is tipped over.

3. Flammable and Combustible Materials

Class A combustibles: Common combustible materials (wood, paper, cloth, rubber, and
plastics). Water, multi-purpose dry chemical (ABC) are approved fire extinguishing agents.

Class B combustibles: Flammable and combustible liquids (oils, greases, tars,
oil-based paints, and lacquers), flammable gases, and flammable aerosols. Approved agents: carbon
dioxide, multi-purpose dry chemical (ABC), halon 1301, and halon 1211.

4. Smoking

Smoking is prohibited in the Interco building and while operating equipment.

TRAINING

All new hires shall receive Health & Safety training, which includes Emergency Action and Fire
Prevention Plan training and records shall be maintained.

All employees shall receive annual refresher Health & Safety training with includes Emergency Action
and Fire Prevention Plan training and records shall be maintained.

Portable Fire Extinguisher Program

Policy

It is our policy that only employees who have had training in the operation of fire extinguishers use
them. The use of a fire extinguisher is at the choice of those that have had training. It is only
recommended to fight incipient stage fires. That is, those fire that are no larger than a waste
basket or trash can.

Purpose

This procedure provides for training those employees who may use a portable fire extinguisher to
fight an incipient stage fire.

Definitions

Agent Types

• Water and water based foam
• Ordinary dry chemical (sodium bicarbonate base) and Purple K (potassium bicarbonate base)
• Multi-purpose dry chemical (monoammonium phosphate base)
• Inert gas (carbon dioxide)
• Halon
• Halon Replacement
• Dry Powder – various dry compounds for fighting combustible metal fires

Class of Fire

• Class A: Ordinary combustibles (wood, paper, etc.)
• Class B: Flammable and combustible liquids and gasses
• Class C: Energized electrical equipment
• Class D: Combustible metals
• Class K: Cooking oils and fats

APASS

An acronym that describes the main steps in fire extinguisher operation: Alert, Pull, Aim, Squeeze,
Sweep.

Fire Extinguisher Selection Guide

Placement Guide

Fire Extinguisher Use – APASS Method

A = Alert

Upon discovering fire, immediately notify the nearest person

P = Pull

The safety pin is usually held in place by a plastic seal, it will pull off. Do not push down on the
operating lever while pulling the pin, it won’t come out.

A = Aim

Aim at the base of the fire, the lowest flame closest to you. The base of the fire will recede from
you as you use the extinguisher, so you must adjust your aim.

S = Squeeze

The operating lever is above the carrying handle. The operating lever opens the valve when you
squeeze it down. When you let go, the valve closes and the discharge stops.

S = Sweep

Sweep the nozzle by moving your arm at the elbow. Direct the discharge to cover the entire width of
the base of the fire.

Training

Training will be conducted at the time that the employee is authorized to use fire extinguishers and
repeated annually for all authorized personnel.

Training will consist of:

1. General principles of a fire.
2. Hazards employed with an incipient stage fire(s).
3. When to “back off” (evacuate) of an incipient stage fire(s).
4. General fire principles of a fire extinguisher.
5. Hazards employed with the use a fire extinguisher.
6. Use of a fire extinguisher (hands-on).

Emergency Procedures

MEDICAL EMERGENCY RESPONSE PROCEDURES

Always exercise caution as you approach an accident scene. Inspect the scene before entering. Is it
safe? If so, assess status of victim. Designate someone to notify the Warehouse Manager or Front
Office. Remain with the victim and provide comfort, reassurance and any emergency aid you are able
to give until emergency medical technician (EMT) personnel arrive.

Give the Warehouse Manager/Front Office the following information:

• Location of incident.
• Type of emergency: illness or injury
• Gender of victim.
• Approximate age of victim.

The Warehouse Manager/Front Office is responsible for calling 911 if the emergency merits it. If
someone is not breathing or they have no pulse, and the Warehouse Manager or Front Office is not
available to call 911 immediately, YOU must call 911 immediately. Employees may use their cell
phones for this call.

If the medical emergency does not warrant immediate outside assistance, the first aid kit is located
outside E-scrap supervisors office. Directions to the nearest clinic/hospital are located in the
Break Area.

Once the emergency has been responded to, the Warehouse Manager/Front Office must complete an
Incident Report.

Blood Borne Pathogen

Interco Trading EHS Specialist is a certified first-aid responder. Any incidents that result in blood
exposure are to report to the EHS Specialist for first-aid treatment.

It is the policy of our company to protect employees who assist fellow employees as a “Good
Samaritan”. Any employee who is inadvertently exposed to blood or other potentially infectious
materials while assisting an injured fellow employee will be offered the opportunity to receive the
Hepatitis B vaccination series, at no cost to the employee.

Employees who wish to receive the vaccination are responsible for notifying their supervisor within
24 hours of the exposure.

Respiratory Protection Program

Pursuant to 29 CFR 1910.134, Interco Trading job activities that require the use of respiratory
protection include north end of building 2 when baling Nickel-Cobalt material (cathodes). Also
required in EV Plant during hammermill process. There are some jobs, that from time to time generate
some dust and respirators are worn voluntarily by employees.

Per 29 CFR 1910.134

(c)(2)(i) An employer may provide respirators at the request of employees or permit employees to use
their own respirators, if the employer determines that such respirator use will not in itself create
a hazard. If the employer determines that any voluntary respirator use is permissible, the employer
shall provide the respirator users with the information contained in Appendix D to this section
(“Information for Employees Using Respirators When Not Required Under the Standard”);

Information for Employees Using Respirators When Not Required

Respirators are an effective method of protection against designated hazards when properly selected
and worn. Respirator use is encouraged, even when exposures are below the exposure limit, to provide
an additional level of comfort and protection for workers. However, if a respirator is used
improperly or not kept clean, the respirator itself can become a hazard to the worker.

You should do the following:

1. Read and heed all instructions provided by the manufacturer on use, maintenance, cleaning and
   care, and warnings regarding the respirators limitations.
2. Choose respirators certified for use to protect against the contaminant of concern. NIOSH
   certifies respirators.
3. Do not wear your respirator into atmospheres containing contaminants for which your respirator
   is not designed to protect against.
4. Keep track of your respirator so that you do not mistakenly use someone else’s respirator.

LockOut/TagOut Program

I. Purpose & Scope

Effective hazardous energy control procedures will protect employees during machine and equipment
servicing and maintenance where the unexpected energization, start up or release of stored energy
could occur and cause injury, as well as while working on or near exposed deenergized electrical
conductors and parts of electrical equipment.

The procedure herein established will ensure that machines and equipment are properly isolated from
hazardous or potentially hazardous energy sources during servicing and maintenance and properly
protect against reenergization as required by 29 CFR 1910.147.

II. Definitions

Affected Employee

An employee who is required to use machines or equipment on which servicing is performed under the
Lockout/Tagout standard, or who performs other job responsibilities in an area where such servicing
is performed.

Authorized Employee

An employee who locks or tags machines, equipment, or systems in order to perform servicing or
maintenance activities.

Energized

Connected to an energy source or containing residual or stored energy.

Energy Isolating Device

A mechanical device that physically prevents the transmission or release of energy such as: manually
operated electrical circuit breaker; a disconnect switch; a line valve; a block; and any similar
device used to block or isolate energy.

Lockout

The placement of a lock and, if necessary, a lockout device on an energy isolating device in
accordance with the General Lockout Procedure ensuring that the energy isolating device and the
equipment being controlled cannot be operated until the lock and lockout device are removed.

III. Responsibilities

The EHS Manager as well as shift Managers shall be responsible for LOTO Policy/Program
implementation, including:

1. Train Interco employees who may perform LOTO procedures on the Policy, provide awareness
   training that they may recognize when equipment is locked or tagged out and not to attempt to
   use equipment that is locked or tagged out.
2. Ensure all contractors performing repairs and maintenance at Interco implement Lockout/Tagout
   procedures.

IV. Rules

• Locks, chains, wedges, or other hardware which meet OSHA requirements shall be provided by the
  company.
• Lockout devices shall be singularly identified and shall not be used for other purposes.
• The lockout devices shall indicate the identity of the employee applying the devices.
• All machines/equipment shall be locked out to protect against accidental or inadvertent
  operation when such operation could cause injury to personnel.
• No employee shall attempt to operate any switch, valve, or other energy-isolating device which
  is locked out.
• Each lockout device shall only be removed by the employee who applied the device.

V. Lockout Procedures and Techniques

A. Preparation for Shutdown

1. An initial survey must be made to locate and identify all energy isolating devices to be certain
   which switch, valve, or other energy isolating devices apply to the machine/equipment to be
   locked out.
2. Before an authorized or affected employee turns off a machine or piece of equipment, the
   authorized employee must have knowledge of the type and magnitude of the energy to be
   controlled, and the methods or means to control the energy.

B. Machine or Equipment Shutdown

1. All affected employees shall be notified that a lockout system is to be utilized and the reason
   for it before the controls are applied.
2. If the machine or equipment is operating, shut it down by normal stopping procedure.

C. Machine or Equipment Isolation

Physically locate and operate the switch, valve, or other energy isolating devices so that the
equipment is isolated from its energy sources and apply adequate hardware.

D. Lockout Device Application

1. Authorized employees shall lockout the energy isolating devices with assigned individual locks.
2. Lockout devices shall be applied so that they will hold the energy isolating devices in a
   “Neutral” or “Off” position.

E. Stored Energy

All stored or residual energy in rams, flywheels, springs, pneumatic, or hydraulic systems, etc.
shall be blocked or dissipated. If there is a possibility of re-accumulation of stored energy,
verification of isolation must be continued until servicing or maintenance is completed.

F. Verification of Isolation

Prior to starting work on machines or equipment that have been locked and after ensuring that no
personnel are exposed, the authorized employee shall operate the push button or normal operating
controls to verify that the appropriate equipment or machine has been deenergized and make certain
it will not operate.

VI. Removal of Lockout Devices

After the servicing and/or maintenance is completed and before the lockout devices are removed and
energy is restored, the authorized employee(s) shall:

• Clear the machine or equipment of tools and materials.
• Remove employees from the machine or equipment.
• Remove the lockout device.
• Energize and proceed with testing or positioning.

Emergency Action and Fire Response Procedures

In the event you discover a small fire (waste-basket size), notify people in the area and send
someone to notify the Warehouse Manager or Front Office. If comfortable, use a fire extinguisher to
extinguish the fire. Fire extinguishers are located throughout the building as listed on the
facility map.

1. The Warehouse Manager/Front Office will obtain the following information about the fire:
   • Location
   • Size
   • Are there are any injuries?

If larger than a waste basket, the Warehouse Manager/Front Office will call “911” to notify the Fire
Department.

Evacuation Procedures

Use the closest, but safest exits to evacuate the building. Facility maps are posted throughout the
building.

Employees need to assist in ensuring everyone in their area is notified to evacuate, including
contractors and visitors. EVERY EMPLOYEE, CONTRACTOR AND VISITOR MUST LEAVE THE BUILDING IMMEDIATELY
UPON NOTICE TO EVACUATE.

Employees must report to the assigned safety zone. Exit pathways will differ, but everyone’s safety
zone is parking lot at the south end of Building #7.

Spill Response Procedures

1. In the event you discover a spill, notify the people in the area and send someone to notify the
   Warehouse Manager.
2. Remember the 3 C’s of handling any accidental spills: Control, Contain, and Clean
   Up.
3. The Warehouse Manager or trained employee shall determine the specific substance of the spill.
4. Based on the type of spill, clean up appropriately with the items provided in the spill kit
   bucket.
5. Wear the following personal protective equipment:
   • Eye protection
   • Gloves – Chemical or Cut Resistant depending on material
   • Safety goggles or glasses
   • If splash potential exists wear protective apron
6. All spill waste and spill cleanup supplies shall be disposed of properly based on the type of
   spill.
7. After cleanup of the spill has been completed, notify the Warehouse Manager who will complete
   the Incident Report.

Broken CRT Cleanup Procedure

CRTs in computer monitors and televisions contain lead and cadmium, which are toxic to human health
and the environment.

Cleanup Procedure

1. Employees shall wear the following safety equipment:
   • Dust Mask
   • Safety goggles or glasses with side shields or full face shield
   • Cut resistant gloves
   • Safety toed shoes or boots
2. Use a broom and dustpan to sweep the broken glass and materials. Deposit into a sealable 5
   gallon bucket or drum. (Never place broken or intact CRT’s in the garbage.)
3. The container shall be labeled “Broken CRT Glass – Universal Waste – contains lead”.
4. The container shall be shipped to the approved vendor.

Broken Fluorescent Tube Cleanup Procedure

Fluorescent tubes contain mercury which is toxic to human health and the environment. Mercury is the
only heavy metal that is liquid at room temperature. It is actually more harmful to inhale the vapor
from a bead of mercury than to ingest the same bead.

Cleanup Procedure

1. Employees shall wear the following safety equipment:
   • Dust Mask
   • Safety goggles or glasses with side shields or full face shield
   • Cut resistant gloves
   • Safety toed shoes or boots
2. Use a broom and dustpan to sweep the broken glass and materials. Deposit into a sealable 5
   gallon bucket or drum. (Never place broken tubes in the garbage.)
3. The container shall be labeled “Broken fluorescent tubes – Universal Waste for recycling”
4. The container shall be shipped to the approved vendor.

Used Oil Cleanup Procedure

Oil spills are dangerous to the health of people and to the environment. The hazards include fumes,
ignitions, asphyxiation, burns, water contamination, soil contamination and fire. Oil spills should
be addressed immediately, contained properly and cleaned up to reduce exposure and contamination.

Cleanup Procedure

1. Employees shall wear the following safety equipment:
   • Safety goggles or glasses with side shields, or full-face shield
   • Chemical resistant gloves
   • Safety toed shoes or boots
   • Stand by fire extinguishers
2. Control the spill. Attempt to stop the cause or source of oil or slow down the
   rate of release of oil.
3. Contain the oil spill by preventing the spill from spreading to other areas
   with the use of absorbent pads, absorbent rolls or containment socks.
4. To cleanup, place the absorbent pads or oil-dry material directly on to the oil
   spill.
5. Continue placing and replacing absorbent pads or add oil-dry until the last drop of liquid is
   absorbed
6. Place all the soiled oil-dry, absorbent pads and socks inside a plastic bag. Re-bag soiled
   absorbents to prevent leakage.
7. Once you have finished bagging everything, place the bags inside a drum or a sealed container (5
   gallon bucket).
8. The container shall be labeled “Used Oil Rags and Absorbent Materials”.
9. The container shall be shipped to the approved vendor.

Severe Weather Response Procedures

If an employee is made aware of, or is concerned about the local weather condition, they should
immediately contact the Warehouse Manager/Front Office. The employee will inform the Front Office
of:

• Any Severe Weather Alerts they are aware of.
• The source of the information. (i.e. National Weather Service, customer, truck driver, personal
  phone call)

If the National Weather Service issues a warning, or if the community’s sirens are heard, the Front
Office will begin to monitor the weather using spotters and the weather on local radio and TV
stations as needed.

If severe weather develops in the area, the Warehouse Manager/Front Office will notify by verbal
communication everyone to proceed to the severe weather/tornado shelter room, 1st Floor under Black
Stairwell (West).

Employees/contractors/visitors are to proceed to the designated Tornado Shelter room immediately in
an orderly manner. Stay away from all outside windows.

Once inside the Tornado Shelter room, the Warehouse Manager and Front Office will ensure all
personnel are present or accounted for.

The Warehouse Manager/Front Office will give the “All Clear” once severe weather has left the
vicinity.

Forklift Safety Program

Purpose

The purpose of this program is to protect employee’s safety when using powered industrial forklift
equipment. This program is intended to meet OSHA’s Powered Industrial Truck – 29 CFR 1910.178
requirements.

Program

Forklift operator responsibilities

The Facility equipment operator shall be responsible for:

1. Inspecting forklifts once per shift and reporting unsafe conditions
2. Following OSHA and facility forklift operating rules
3. Consistently demonstrating safe driving habits
4. Immediate reporting of all accidents and near misses to designated staff
5. Removing unsafe forklifts from operation
6. Being aware of pedestrian hazards
7. Constantly being aware of other forklift traffic hazards

Maintenance Procedures

Each forklift shall be inspected by the first operator prior to starting a new shift and by the
warehouse manager monthly during monthly safety inspections.

Forklift maintenance and operation practices shall include:

• Storing, refilling and handling of liquid propane fuel by qualified or trained personnel.
• Refueling or exchanging removable propane cylinders outdoors or in well ventilated areas, away
  from sources of ignition.
• The refueling area shall be equipped with a fire extinguisher.
• All liquid propane fueled tanks, full or empty, must be stored in designated propane cage.

Forklift operations

Only trained, authorized persons are allowed to operate forklifts. Forklift operating guidelines
include:

• No riders are allowed
• When left unattended, the forks shall be lowered, the power shall be shut off, and the parking
  brakes shall be engaged
• Operating at speeds that will permit a quick and safe stop
• Driving slowly while turning
• Maintaining a safe distance between forklift and other moving objects
• Operating under control at all times
• Driving slowly and sounding horn when passing through areas with an obstructed view
• Looking in the direction of travel
• Traversing ramps slowly and with caution

Employee Training

The Warehouse Manager is the designated staff responsible for coordinating all forklift training.
Only trained staff shall be authorized to operate forklifts and shall be trained with the following:

• Forklift-related topics (characteristics, operation, limitations, vehicle capacity and
  stability)
• Workplace-related topics or hazards
• Instructions specific to each piece of equipment

Refresher Training and Evaluation

Refresher training shall be provided to the operator when:

1. The operator has been observed to operate the vehicle in an unsafe manner
2. The operator has been involved in an accident or near-miss incident
3. The operator has received an evaluation that reveals that the operator is not operating the
   truck safely
4. The operator is assigned to drive a different type of truck
5. A condition in the workplace changes in a manner that could affect safe operation of the truck

General Facility Safety Rules

It is the intent of management to provide a safe and healthful work environment for all employees.
Your cooperation in adhering to the safety rules listed below will assist all of us in meeting this
important goal.

1. Immediately inform your supervisor of any apparent unsafe conditions or procedures.
2. Immediately report to your supervisor all work-related accidents or injuries no matter how
   slight or insignificant they may seem.
3. Always request and wait for assistance when handling heavy material or objects.
4. Safety shoes are required for all employees working in the warehouse.
5. Personal protective wear must always be worn in designated areas.
6. Only properly trained and authorized personnel may operate equipment.
7. All machinery must be “shut off” and an electrical lock-out tag attached before servicing.
8. Do not operate machinery or equipment unless all guards are in place.
9. Designated aisles and exits must not be blocked or used for storage.
10. Tools and equipment must be used only for their intended purpose.
11. Eating and drinking is permitted only in the lunchroom or office areas.
12. Willful acts of horseplay, fighting, or ignoring established safety rules will constitute
    grounds for discipline up to and including termination of employment.

Hearing Conservation

Purpose

The purpose of this program is to protect employee’s health in the area of hearing and noise related
stress. An effective hearing conservation program can prevent hearing loss, improve employee morale
and a general feeling of well-being, increase quality of production, and reduce the incidence of
stress-related disease.

This program is intended to meet OSHA Occupational Noise Exposure – 29 CFR 1910.95 requirements
whereby an employer must administer a continuing, effective hearing conservation program whenever
employee noise exposures are at or above an eight hour time-weighted average (TWA) of 85 dBA.

Monitoring Program

Based on audiometric testing, Interco has identified the following areas for inclusion in the hearing
conservation program: Baling

All employees working in the identified areas shall:

1. Within 6 months of an employee’s first exposure in the identified process area, the employer
   shall establish a valid baseline audiogram.
2. Testing to establish a baseline audiogram shall be preceded by at least 14 hours without
   exposure to workplace noise.
3. At least annually after obtaining the baseline audiogram, Interco shall obtain a new audiogram
   for each employee exposed at or above an 8-hour time-weighted average of 85 decibels.
4. Each employee’s annual audiogram shall be compared to that employee’s baseline audiogram to
   determine if a standard threshold shift has occurred.

HEARING PROTECTION DEVICES

1. Employees in the identified areas shall wear hearing protection provided by Interco.
2. Interco shall provide training in the use and care of all hearing protectors provided to
   employees.
3. Interco shall ensure proper initial fitting and supervise the correct use of all hearing
   protectors.

EMPLOYEE TRAINING

Interco shall train each employee who is exposed to noise at or above an 8-hour time weighted average
of 85 decibels. The training program shall be repeated annually.

Interco shall ensure that each employee is informed of the following:

• The effects of noise on hearing;
• The purpose of hearing protectors, advantages, disadvantages, attenuation of various types, and
  instructions on selection, fitting, use, and care;
• The purpose of audiometric testing, and an explanation of the test procedures.

Hot Work Program

Purpose

The purpose of this program is to prevent fires that may result from hot work processes. “Hot work”
is defined as use of portable grinders as well as any temporary operation involving cutting,
brazing, soldering, heating, or welding by gas torch, arc, plasma, or other welding type equipment.

Scope and Application

Hot work anywhere on the premises, other than designated hot work areas, shall be performed by permit
only. Designated hot work areas that do not require permits are limited to grinding samples for
analysis in scale areas of Buildings 1, 2, and 3. This program shall apply to all employees
authorized by Interco to perform hot work as well as contractors.

Responsibilities

Managers and supervisors are responsible for ensuring that employees and/or contractors working under
their direction are trained and understand the necessary aspects of this program. They are also
responsible for ensuring that all requirements of hot work permits are fulfilled, and the permit is
issued before work is performed.

Reference

OSHA 29 CFR 1910 Subpart Q (Welding, cutting, and brazing)
NFPA 51B (Fire Prevention During Welding, Cutting and Other Hot Work)

If all requirements of a hot work permit cannot be fulfilled, the work may not be performed.

Procedures

Prior to Hot Work

1. Inspect the area to identify potential fire hazards.
2. Remove all fire hazards within 35 feet of the hot work.
3. If all combustibles cannot be removed from the area, they must be shielded from flames, sparks,
   and slag by fire resistant material.
4. Sweep the floor of all loose, combustible debris.
5. Place flame resistant shields or screens as necessary to protect nearby workers.
6. Shut down or protect conveyors and ductwork which may carry sparks or slag to other areas.
7. Mark the appropriate sections of the hot work permit and post it in an easily visible location.

During Hot Work

1. Ensure that a portable fire extinguisher is nearby the hot work area and readily accessible for
   the entire duration plus 30 minutes.
2. Acetylene and other fuel cylinders must be upright and secured.
3. Place hoses and/or leads so that they will not be crushed or damaged.
4. Wear the proper welding PPE for the type of operation performed.

After Hot Work

1. A fire watch must be maintained for at least 30 minutes after completions of the hot work.
2. A fire extinguisher must remain readily accessible in the area until the fire watch is over.
3. Complete the appropriate sections of the hot work permit and return it to the Safety Coordinator
   for record retention.

Prohibited Hot Work Areas

Hot work must never be performed in the following areas:

1. On tanks, drums, or other objects potentially containing flammable liquids, solids, or vapors.
2. Areas, including confined spaces, which may contain explosive gases, vapors, or dust.
3. On pipes or other metal material contacting combustible walls, ceilings, roofs, or other
   partitions that may ignite due to heat conduction.

Hazard Communication Program

1. Company Policy

To ensure that information about the dangers of all hazardous chemicals used by Interco Trading
Company is known by all affected employees, the following hazardous information program has been
established.

All work units of the company will participate in the hazard communication program. This written
program will be available in Bill Cassiday’s Office for review by any interested employee.

2. Introduction

The hazard communication standards were designed to enhance employer and employee awareness of
safety and health hazards associated with chemicals. The Hazard Communication Standard is found
in the Occupational Safety and Health Administration under 29 Code of Federal Regulations
1910.1200, Hazard Communication. Requirements of the regulations include, but are not limited
to, the following:

• Labels and other forms of warning
• Material Safety Data Sheets
• Training
• List of hazardous chemicals
• Hazards of non-routine tasks
• On-site contractors

3. Container Labeling

A. Labeling of Containers Received from Suppliers and Manufacturers

The Warehouse Manager will verify that all containers received for use will be clearly labeled as
to the contents, note the appropriate hazard warning and list the name and address of the
manufacturer. In addition, all individuals responsible for receiving and distributing containers
of hazardous chemicals shall check with the person in charge of container labeling to ensure the
labeling program is implemented and uniform.

The Warehouse Manager will ensure that all secondary containers are labeled with either an extra
copy of the original manufacturer’s label or with labels that have the identity and the
appropriate hazard warning. For help with labeling, see the Warehouse Manager.

B. Labeling of Shipped Containers

Interco Trading Company does not ship any hazardous materials. Labeling will be applied, as
necessary.

C. Labeling Systems

The intent of the in-warehouse labeling system is to provide immediate visual warning about the
hazards of the material in the container, as well as an identity of the material contained
therein. The identity shall likewise be indicated on the MSDS or SDS for that particular
material. Labeling of in-warehouse containers shall be in accordance with the Hazardous
Materials Identification System (HMIS).

In addition to the above described labeling system, additional labels may be provided by the
manufacturer or supplier in accordance within their responsibilities under the regulations.
Additional labeling may include the following:

• Expanded product and safety information
• Emergency telephone numbers
• Directions for mixing
• Recommended use
• Storage considerations
• Container disposal
• Dangers
• DOT shipping labels (Flammable liquid, Flammable gas, Corrosive, Oxidizer, Poison, etc.)
• Other labels such as the National Fire Protection Association Label (NFPA)

D. Alternatives to Individual Container Labeling

Alternatives may include the following:

• Placarding
• Process sheets
• Batch tickets
• Operating procedures

Such methods shall comply with requirements under 29 CFR 1910.1200 (i.e. containers shall be
identified respective to the specific material contained in them; specific hazards shall be
listed for each chemical). This information shall be readily accessible to the employees in
their work area throughout each shift.

E. Procedures to Review and Update Label Information When Necessary

The Warehouse Manager will review the company labeling procedures every six months and update as
required.

All Material Safety Data Sheets and Safety Data sheets will be reviewed for adequacy and
assignment of HMIS coding. Where appropriate, existing labeling protocol for a material will be
revised to accommodate additional knowledge regarding hazards of that specific chemical.

In addition, any new information regarding a chemical brought to the attention of the Warehouse
Manager will be reviewed respective to the existing labeling system. Should the review warrant,
appropriate revision of the labeling system will proceed within three (3) months.

4. MATERIAL SAFETY DATA SHEETS (MSDS) or SAFETY DATA SHEETS (SDS)

A. Person Responsible for Establishing and Monitoring the Company MSDS or SDS Filing System

The Warehouse Manager is responsible for establishing and monitoring the company MSDS or SDS.
They will make sure procedures are developed to obtain the necessary MSDSs or SDSs and will
review incoming MSDSs or SDSs for new or significant health and safety information. They will
see that any new information is passed on to affected employees.

The following procedure will be followed when a MSDSs or SDSs is not received by mail or at the
time of initial shipment. The MSDS or SDS shall be filed in the book for that purpose in the
Warehouse Manager’s Office. When a MSDS or SDS is not received, the purchasing agent or person
ordering the product shall immediately contact the supplier and obtain a MSDS or SDS. Fax copies
are acceptable.

Copies of MSDSs and SDSs for all hazardous chemicals in use will be kept in the Receiving desk.

MSDSs or SDSs are readily available to all employees during each work shift. If an MSDS or SDS is
not available, immediately contact the Warehouse Manager. To ensure MSDSs or SDSs are readily
available in each work area the following format will be used: Hard copies of current MSDSs or
SDSs for all hazardous chemicals in use will be kept in alphabetical order in a ring binder.

B. Material Safety Data Sheet or Safety Data Sheet Maintenance Program

1. Obtaining MSDS or SDS

When revised MSDSs or SDSs are received, the following procedures will be followed to replace old
MSDSs or SDSs:

The Warehouse Manager will check each incoming shipment of chemicals for the MSDSs or SDS sheet.
The purchasing department will forward pre-mailed MSDSs or SDSs to the Warehouse Manager. The
sheet will be compared to the sheet on file in the master MSDS or SDS binder. If the MSDS or SDS
has been revised, replace in master list.

2. Old MSDS and SDS

The old MSDS and SDS shall be kept in a superseded file. This is a regulatory requirement and can
prove useful for dealing with old chemicals found in the future.

5. EMPLOYEE TRAINING AND INFORMATION

The Warehouse Manager is responsible for the company employee training program. They will ensure
that all program elements specified below are carried out.

Prior to starting work, each new employee of Interco Trading Company will attend a health and
safety orientation that includes the following information and training:

• An overview of the requirements contained in the Hazard Communications Standard
• Hazardous chemical present at his/her workplace
• Physical and health risks of the hazardous chemicals
• The symptoms of over exposure
• How to determine the presence or release of hazardous chemicals in his/her work area
• How to reduce or prevent exposure to hazardous chemicals through use of control procedures,
  work practices and personal protective equipment
• Steps the company has taken to reduce or prevent exposure to hazardous chemicals
• How to read labels and review MSDSs or SDS to obtain hazard information
• Location of the MSDS or SDS file and written hazard communication program

Prior to introducing a new chemical hazard into any section of this company, each employee in
that section will be given information and training as outlined above for the new chemical
hazard. This training format will be audiovisuals and or classroom instruction.

6. HAZARDOUS NON-ROUTINE TASKS

Periodically, employees are required to perform hazardous non-routine tasks. Some examples of
non-routine tasks are: equipment maintenance, confined space entry, tank cleaning, and painting.

Prior to starting work on such projects, each affected employee will be given information by
Warehouse Manager about the hazardous chemicals he or she may encounter during such activity.
This information will include specific chemical hazards, protection and safety measures the
employee can use, and steps the company is using to reduce the hazards, including ventilation,
respirators, presence of another employee and emergency procedures.

7. INFORMING OTHER EMPLOYERS

It is the responsibility of the Warehouse Manager to provide other employers with information
about hazardous chemicals their employees may be exposed to on a job site and suggested
precautions for the employees. It is the responsibility of the Warehouse Manager to obtain
information about hazardous chemicals used by other employers to which employees of this company
may be exposed.

Other employers will be contacted before work is started to gather and distribute information
concerning any chemical hazard that may be brought into the workplace.

The following methods will be used to inform other employers who have employees who may be
exposed to hazardous chemicals used by employees of this company:

• A) Material safety data sheets or Safety Data Sheets will be provided to other employers by
  presenting the Program/MSDS – SDS Manual compiled for presentation to the contractor
• B) Appropriate precautionary methods will be related to other employers to safeguard their
  employees
• C) Other employers will be informed of the labeling system in use

8. COPIES OF THIS PROGRAM

A copy of this program will be made available, upon written request, to employees and their
representatives.

9. List of Duties by Person/Title

• Warehouse Manager is responsible for ensuring that all incoming hazardous materials are
  checked for proper labels and data sheets are forwarded to the person responsible for MSDSs
  or SDSs
• Warehouse Manager is responsible for ensuring that all secondary containers are labeled with
  either an extra copy of the original manufacturer’s label or with labels that have the
  identity and the appropriate hazard warning
• Warehouse Manager is responsible for establishing and monitoring the company MSDS or SDS
  Program. They will make sure procedures are developed to obtain the necessary MSDSs or SDSs
  and will review incoming MSDSs or SDSs for new or significant health and safety information.
  They will see that any new information is passed on to affected employees. Check with
  receiving personnel on each incoming shipment of chemicals for the MSDSs or SDSs and follow
  the established procedure when an MSDSs or SDSs is not received at the time of initial
  shipment. The MSDS or SDS sheet will be compared to the sheet on file in the master MSDS or
  SDS binder. If the MSDS or SDS on file has been revised, make copies of the sheets and
  replace in the other master lists and the departments where the chemical is used
• Warehouse Manager is responsible for training employees for non-routine tasks
• Warehouse Manager is responsible for the company employee training program. They will ensure
  that all program elements specified below are carried out
• Warehouse Manager is responsible for providing other employers with information about
  hazardous chemicals their employees may be exposed to on a job site and suggested
  precautions for the employees. It is the responsibility of Warehouse Manager to obtain
  information about hazardous chemicals used by other employers to which employees of COMPANY
  may be exposed
• Warehouse Manager is responsible for gathering and disseminating information on unlabeled
  pipes regarding: The chemical in the pipes, Potential hazards and Safety precautions which
  should be taken. Interco Trading Company has no unlabeled chemical containing pipes