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CONTRACTOR SAFETY Welcome to ECR International. ECR International values a safe workplace for its employees, contractors, suppliers and visitors. Safety is everyone’s responsibility. Everyone is expected to participate in the safety process and comply with the prescribed safety rules and policies. The following pages contain the basic safety requirements necessary when performing work on ECR International’s premises. Just as important as following the prescribed rules and policies is communicating hazards or unsafe conditions recognized by you as you perform your work at our facility. Please direct any concerns or findings to your ECR International Project Manager or contact. ECR International thanks you for your participation and compliance. Revision 2 05/08/09 1

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CONTRACTOR SAFETY

Welcome to ECR International. ECR International values a safe workplace for its employees, contractors, suppliers and visitors. Safety is everyone’s responsibility. Everyone is expected to participate in the safety process and comply with the prescribed safety rules and policies.

The following pages contain the basic safety requirements necessary when performing work on ECR International’s premises. Just as important as following the prescribed rules and policies is communicating hazards or unsafe conditions recognized by you as you perform your work at our facility. Please direct any concerns or findings to your ECR International Project Manager or contact.

ECR International thanks you for your participation and compliance.

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ECR International, Inc.Outside Contractor & Sub-Contractor Safety Rules

THE FOLLOWING SAFETY RULES ARE TO BE FOLLOWED BY ALL CONTRACTORSEMPLOYED BY ECR International, Inc.

1. ECR will not loan or allow the utilization of any equipment or tools owned by ECR, except for items agreed upon prior to work schedule.

2. Safety glasses must be worn in all required areas.

3. Hearing protection must be used in all required areas.

4. Safety shoes must be worn at all times in the manufacturing and warehouse areas.

5. Hard hats must be worn by employees working in the area when overhead work is being done, including roof work.

6. All outside contractors must meet with Facility Safety Coordinator or Facility Contact prior to any work done on ECR’s property.

7. Posted signs must be observed.

8. Notify ECR supervision or ECR contact immediately in case of a spill of any nature.

9. Only contractor employees are allowed in ECR’s facilities.

10. All contractors are responsible to supply their own personal protective equipment.

11. All contractors must comply with all applicable OSHA, ECR, and site State specific safety regulations.

12. All trucks must have their wheels chocked when they are unloaded or loaded. If not, they will not be loaded or unloaded.

13. Unauthorized tampering or operating of any ECR equipment is prohibited. This does not apply to items agreed upon prior to work schedule.

14. Horseplay is also prohibited.

15. All injuries and accidents – no matter how slight – must be reported to the plant supervisor and/or the Safety Coordinator.

16. Persons under the influence of alcohol, intoxicants or narcotics are prohibited on ECR property. Smoking is allowed outside the building only in designated areas.

17. Any questions concerning these rules or regulations can be directed to the Plant Manager or the Facility Safety Coordinator.

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General Requirements

Contractor Insurance RequirementsThe required liability insurance and workers’ compensation insurance certificates must be presented to and will be reviewed by the Purchasing Dept.

Work Area ExposuresBefore beginning work at ECR International, the Contractor will meet with the Plant Manager, Maintenance Supervisor and or the designated contact person to discuss work area hazards and possible hazardous material exposures. They will discuss any safety hazards that might be encountered while working in a specific area. The Contractor will instruct his employees in the proper procedures concerning any hazardous materials with which they will come in contact. Material Safety Data Sheets (MSDS) must be submitted and approved by the Plant Manager before any chemicals are allowed in our facilities.

Security RequirementsThe Contractor and his/her employees are required to sign in and out with the Maintenance Supervisor or Plant Manager when entering and exiting the premises. The Contractor and his/her employees will be issued a “Contractor Identification Pass”, which must be displayed on the person at all times. The pass or passes will be returned to the Maintenance Supervisor or Plant Manger at the end of the workday, and the Contractor will sign out.

Medical CareAll workplace injuries must be reported to the Plant Manager, Maintenance Supervisor and or the designated contact person. The incident must be reported immediately. The contractor must make notification to his/her employer immediately as well. Proper Medical Treatment will be provided, and an Incident Investigation Report will be completed.

HousekeepingContractors will be responsible for keeping their work area clean and organized. All stored tools, equipment and supplies must be secured in an area where they will not interfere with the flow of materials, traffic, pedestrians or moving machinery. Flammable chemicals and gases must be properly stored in labeled flameproof containers in a safe area away from heat, sparks and flame, and moving equipment or processes which could create a hazard. The containers must also be stored away from pedestrian and truck traffic. Gas, oxygen and other compressed cylinders must be securely lashed to transport carts or secure structures to prevent them from tipping over. Cylinders must be stored away from moving equipment.

Electrical Safety GFCIGround Fault Circuit Interrupter (GFCI) interrupts electrical power when current leakage to ground is detected. New or repaired equipment requires an inspection prior to being put into service. GFCI are required for portable electric tools/equipment 50 Volts or higher when performing any of the following:

All construction activities All exterior maintenance or manufacturing activities Work in manufacturing activities when subject to or likely to encounter wet or damp conditions

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Hot Work PermitsContractors must follow the ECR International Hot Work Program. Any cutting or welding or any other type of work that can generate dangerous heat and sparks must be performed under the provisions of the Program. All electric welding in the inhabited work areas must have flash curtains in use to provide employee protection from flash and arc exposure. Permits can be obtained from the Maintenance Supervisor or the Plant Manger.

Confined Space AreasA list of confined spaces requiring permits can be obtained from the Maintenance Supervisor or Plant Manager. All entrance and work performed in these areas must be done in accordance with the provisions of the Confined Space Entry Program. Permits are available from the Maintenance Supervisor or Plant Manager.

Lockout/TagoutContractors are required to comply with the energy control requirements outlined in the Lockout/Tagout Program. A list of lockout points and specialty control devices are available in the Maintenance Department. Otherwise, contractors must provide their own control devices.

Working Around Cranes and TransformersPowered overhead cranes and transformers contain exposed, energized electrical components. Contractors cannot work in the immediate vicinity of these units, unless they are properly locked out. Exceptions to this are servicing or troubleshooting of the units by trained and authorized personnel.

Fall ProtectionContractors must comply with the OSHA fall protection requirements. All safety lanyards and harnesses must be provided by the contractor and be in good condition. Ladders, man lifts and other equipment used must comply with OSHA/ANSI requirements.

Fork Trucks/Powered Machinery/Powered Hand ToolsContractor supplied equipment must be in safe operating condition (i.e. adequate braking systems, warning lights and alarms, horn, etc.) All safety devices and guards must be in operating condition. Equipment with gasoline or diesel powered combustion engines must be free from fuel and acid leaks. Ventilation to the outside of the building must be provided when using gasoline or diesel powered equipment in employee work areas. Powered hand tools must be in safe working condition. All manufacturers’ guards must be functional and cords must be free from electrical hazards.

Machine GuardingA guard is a piece of equipment installed to physically prevent entry into the danger zone. Guards may be fixed, adjustable, self-adjusting, or interlocked. Employees shall not disable machine/equipment guarding while operating under normal conditions. Employees shall not operate the machine until the guarding is in place. If an employee recognized that a machine guard has been disabled, they have an obligation to inform their Supervisor and must not operate the machine until the guard has been repaired or reengaged.

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Fork Truck Operation – Contractor supplied truck operators must be certified and licensed by the contractor. A certified ECR International employee will operate any ECR International owned/leased equipment being used. Exceptions to this are contractors who have been certified on ECR International supplied equipment and have demonstrated competency.

Personal Protective Equipment RequirementsThe Contractor performing the work must supply all PPE. Fit testing, inspection and wearing compliance are the responsibility of the Contractor and must meet the minimum requirements of the facility that you are working in.

Eyewear – safety glasses with OSHA approved side shields are required in all areas, excluding; restrooms, break areas, office areas, meeting rooms and lobby area. Face shields are required when grinding or working with harsh chemicals. Approved welding helmets are required when welding operations are being performed.Hearing Protection – OSHA approved hearing protection is required when working in the Hearing Conservation Areas, running air hammers or contractor created noise levels exceeding 85db/twa. Respirators – Contractor supplied and fit tested respirators are required when welding on known hazardous metals (i.e. galvanized, chromium, nickel etc.) Respirators are required when working on ventilation filtering units. All respirators must be the appropriate respirator for the job being performed.

Footwear – all persons working in and around the work areas must wear ANSI approved safety shoes (steel or composite capped toes). Shoelaces must remain tied.

Clothing Requirements – shirts covering the entire torso are required (from waist to collar). Long pants must be worn. Loose shirttails and sleeves must be secured to prevent entanglement into machinery. Hair exceeding shoulder length must be restrained by either tucking under a hat, hair net or inside the collar. Loose necklaces and neckties must be tucked inside the person’s shirt.

Contractor ToolsContractor power tools must be secured during storage. ECR International is not responsible for missing or damaged contractor supplied tools and equipment. ECR International reserves the right to inspect any tools leaving ECR International property.

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HAZARD COMMUNICATION PROGRAM

BackgroundThis written hazard communication program not only complies with the Occupational Safety and Health Administration’s requirements, but also ensures that ECR employees are effectively informed concerning potential and existing chemical hazards. Hazard communication is only one of the many important aspects of ECR’s occupational safety and health program, which includes:

A. Management, commitment and active supportB. Engineering controls for safety and health purposesC. Effective education and training programsD. Enforcement of safety rules and proceduresE. Recognition, evaluation, and control of occupational safety and health hazardsF. Medical surveillanceG. Assigned safety and health responsibility and accountability.

PurposeThe purpose of this hazard communication program is to effectively inform our employees of all potential or existing chemical hazards.

ApproachThe methods used to effectively inform employees include:

A. Container labeling and other forms of warningB. Material Safety Data Sheets-MSDSC. Employee education and trainingD. Written “Hazard Communication Program”

ApplicationThis hazard communication program applies to:

A. Known occupational safety and health hazards.B. Chemicals known to be present in the workplace in such a manner that employees may be

exposed under normal conditions of use or in a foreseeable emergency.

Determining Chemical Hazards ECR is responsible for identifying chemical hazards from material safety data sheets provided by our chemical manufacturers and/or distributors.

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Material Safety Data Sheet (MSDS)MSDSs are prepared and distributed by manufacturers and distributors of hazardous materials. All chemical manufacturers and distributors must obtain or develop a MSDS for each hazardous material they produce or import. A hazardous material is one that is either a physical hazard (ex. Flammable, oxidizer, etc.) or a health hazard (causes acute or chronic health effects). MSDS books for each facility will be maintained in the following locations:

Dunkirk Facility:

A. Master Copy in Corporate Safety OfficeB. Main Building on the table in Press/Test areaC. Stamping Plant in the Supervisor’s office.D. On all PC’s by February 2009

Utica Facility:

A. Master Copy outside of Human ResourcesB. On all PC’s

Rome Facility:

A. Master Copy in Plant ManagerB. CafeteriaC. On all PC’s

ECR will review and update MSDS’s on an ongoing basis to ensure completeness and accuracy.

MSDS’s are in English and contain:

A. The identity of the chemicalB. The physical and chemical characteristicsC. The physical and health hazardsD. Primary routes of entryE. Exposure limitsF. Precautions for safe handlingG. Controls to limit exposureH. Emergency and first aid proceduresI. Name of manufacturer or distributorJ. Handling of waste and environmental concerns

MSDS AvailabilityECR maintains copies of all MSDS’s for each hazardous material in the workplace and makes them readily accessible during each work shift to employees when they are in their work area. Employees may review the MSDS for the materials they work with by contacting their immediate supervisor. They may also request a copy of any MSDS if they wish.

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On this date, I certify that ECR International has reviewed its outside contractor safety rules and practices as well as its written Hazardous Communication Program, which concerns the following:

The Hazards that my employees and I may be exposed to;

Where information concerning these hazards can be found;

Precautions that may need to be taken;

Container labeling;

Emergency notification and house rules.

I also certify that I have provided ECR International with the following Certificates of Insurance naming ECR International as an additional insured:

Worker’s compensation Liability

Business Automobile Liability

Commercial General Liability

Commercial Umbrella Liability

Name

Company

Date

ECR Plant Manager Date

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PERMIT REQUIRED CONFINED SPACE ENTRY PROCEDURE

Purpose:

The purpose of this procedure is to ensure workers safety in situations where ECR employees enter into confined or enclosed spaces for the purposes of maintenance, repair, or construction.

A Permit Required Confined Space (PRCS) has the following characteristics:

1. Adequate size and configuration for employee entry2. Limited means of access or egress3. Not designed for continuous employee occupancy4. One or more of the following characteristics;

a. Contains or has the potential to contain a hazardous atmosphereb. Contains a material that has the potential for engulfing an entrantc. Has an internal configuration that could trap an entrant or cause asphyxiation by

inwardly converging wallsd. Contains any other recognized serious safety or health hazard

The PRCS inventory will be reviewed annually to up-date any design or process changes. These permit-required procedures will make every entry safe.

Responsibilities:

It is the responsibility of all employees to be familiar with the potential hazards of, and the proper procedure for dealing with, confined space work. It is the responsibility of the person authorizing confined space work to see that all necessary precautions are taken.

Entry Procedure:

A confined space entry permit must be filled out completely for each confined space entry. A separate permit must be completed daily for any job lasting more than one (1) day. The entry permit must be posted outside of the space for the duration of the entry. Lockout-tagout procedures are attached to the permit to aid in necessary lockout-tagout procedures. Also, refer to the lockout-tagout manual for that facility to answer any questions about lockout locations for each particular piece of equipment. A hot work permit must be completed daily for any hot work done in a confined space.

Safety Equipment:

Confined space personal protective and rescue equipment will be maintained in good working order in each facility. Equipment will be inspected on a regular basis to verify condition.

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Training:

All affected and new employees will receive training on the “PRCS entry procedures”. The entrant, attendant, and entry supervisor roles will be reviewed at this time.

Emergency/Rescue:

If an emergency occurs, the attendant stationed outside of the space must follow this procedure:

1. Notify appropriate personnel (supervisors, etc.), but do not leave site.

2. The attendant should always attempt to rescue the entrant without entering the space, by use of a full body harness and retrieval system if available. Entering the space is only permitted by trained authorized rescue personal.

3. No entry for rescue purposes should be attempted without knowing that appropriate personnel have been notified. The proper personal protective equipment should also be worn.

Contractors/Outside Employers:

This procedure must be provided to and reviewed with all outside contractors prior to any confined space work. All outside employers must comply with our PRCS company procedures.

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Confined Space Evaluation Form

Date of Survey Confined Space # Permit Required Yes NoIf yes, space must be labeled.

Location of Space

Description of Space

Possible atmospheric hazards

Possible content hazards

Configuration of space

Unusual hazards

1. Space can be bodily entered? Yes No2. Limited or restricted entry? Yes No3. Not designed for continuous human occupancy? Yes No

4. Hazardous atmosphere? Yes No5. Potential for engulfment? Yes No6. Internal configuration hazard? Yes No7. Other serious safety hazards? Yes No

Reasons for entering space & typical activities

Who usually enters spaceFrequency of entryNumber of entry pointsExternal connections to space

Survey completed by: (print & sign)

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Confined Space Entry Permit

Confined Space #

Hot Works Permit #

Permit Expires Date/Time Began Date/Time Finished

Location Job Description

EntrantsPrint nameSignature

AttendantsPrint NameSignature

Supervisor Safety Approval by:

Atmospheric Testing & MonitoringLimits Time/Results Time/Results Time/Results

Oxygen (19.5% - 23.5%)Flammables (< 10%)Explosive Gases (< LEL)Chemicals (list) (< PEL) Add initial column

Instrument: Calibration:Hazards in Space

Contents: Flammable Irritant Corrosive Toxic Dust Asbestos Solid Liquid Gas

Configuration: Slippery or sharp surfaces vertical drop low overhead High or Low temperature Sloped

Nature of Work: Welding Cutting Grinding Chipping Scraping Spray cleaning

Previous Content:

Other:

Isolation of SpaceElectrical: Lockout Tagout

Mechanical: Block linkage Disconnect

Piping: Lockout Tagout Blank Block & Bleed

Other:

Hydraulic: Lockout Tagout Disconnect Lines Lock Pump & Bleed

Pneumatic: Lockout Tagout Disconnect Lines Lock Comp & Bleed

Equipment RequiredRespiratory SCBA Sup. Air. ABA Power. AirProtection Cartridge respirator: Full Half

Cartridge Organic vapor Acid Gas Ammonia Organic vapor/acid gas HEPA Dust/Mist

PPE Coveralls Hard-hat Safety goggles Safety shoes Leather gloves Ear plugs/muffs Welding hood Welding jacket Splash suit Chemical gloves Face shieldLighting Flashlight Hand light Light sticks Cord lights Cords Portable lights GeneratorVentilation Ventilator 10’ sections of duct 20’ sections of duct Saddle vent CFM RequiredFor Entry Body Harness Retrieval device Tripod Anchor point Access ladder Emergency Signal Communications Personal alert deviceFor Rescue Body Harness Retrieval device Tripod Anchor point Access ladder Alarm horn Emergency signal Communications Personal alert device SCBA ABA Rescue harness Escape mask WristletsOtherSupervisor Signature:

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LOCKOUT/TAGOUT POLICY ENERGY CONTROL PROCEDURE

PURPOSE

This procedure establishes the minimum requirements for the lockout or tagout of potential hazardous energy sources. It shall be used to ensure that the machine or equipment is isolated from all potentially hazardous energy, and is locked and/or tagged out before employees perform any production, servicing or maintenance activities where the unexpected energization, start-up or release of stored energy could cause injury.

PREPARATION

A survey of all machines and equipment has been conducted to identify those with potential hazardous energy sources and the types of hazardous energy. These items are identified on the attached list.

Remember! More than one energy source may exist. All isolating devices shall be clearly identified and it will be indicated how the equipment is to be locked or tagged out, where it will be locked or tagged out and whether it will be locked out or tagged out.

LOCKOUT SEQUENCE

1. Notify all effected employees that a lockout/tagout is going to be utilized. This is clearly important when more than one employee is working in the area.

2. Shut down the machine or equipment by the normal stopping procedure (stop button, toggle switch, etc.).

3. Isolate the unit from its energy course through the energy isolating device(s) identified in the survey by attaching your lockout device.

4. All potentially hazardous stored or residual energy shall be relieved, disconnected, restrained and otherwise rendered safe.

5. After ensuring that no personnel are exposed, verify that isolation and de-energization has been accomplished by activating the normal start-up control. CAUTION: Return operating control to “neutral” or “off” position after this test.

6. Work may now be performed on this equipment.

TESTING AND POSITIONING OF EQUIPMENT

1. When occasional energization of equipment is necessary for the purpose of positioning, rotating, etc., for cleaning purposes, all normal lockout procedures must be followed.

RELEASE SEQUENCE

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1. Inspect the work area to ensure that non-essentials are removed, machine or equipment components are operationally intact and that no effected employees are exposed.

2. Notify effected employees the lockout or tagout is going to be removed.

3. Remove the lockout or tagout device and operate the energy isolating device to restore energy.

EXCEPTION

When the authorized employee who applied the lockout or tagout device is not available to remove it, the supervisor may remove the device if the following elements are met:

A. Verification is made that the authorized employee is not at the facility.

B. A reasonable effort is made to contact the authorized employee to inform him of the device removal and inquire as to any abnormal circumstances.

C. The operator who is about to begin work on the equipment is present when the supervisor reviews the status of the equipment prior to removal of the lockout.

D. The RELEASE SEQUENCE is followed for removal of the device.

NOTE: Any employee other than the supervisor who removes a lockout/tagout device will be subject to severe disciplinary action up to and including termination.

MAINTENANCE LOCKOUT/TAGOUT

Maintenance personnel will have their own individual locks, clearly labeled and color coded for easy identification.

All lockout/tagout procedures apply with the following exemptions:

1. A general lockout may be utilized by the maintenance staff for an instance where no individual is working on a piece of equipment but it is in a state of repair and must remain fully isolated. When a mechanic works on this equipment, he will also be required to affix his/her personal lock.

2. As part of the maintenance/repair process, it may be necessary to test or adjust equipment while it is energized. This is only to be done by experienced maintenance personnel and only when appropriate and adequate additional safety precautions have been taken.

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INTRODUCTION

When utilizing machines in industry, employees using this equipment, as well as those in the immediate area, are exposed to several hazards.

However, when performing maintenance or servicing machinery, additional hazards are exposed. Included in these hazards are exposures to energy which can be reduced and/or completely eliminated by the use of this lockout program.

The program will outline procedures for locking and tagging out machinery, removal of locks and tags for normal start-up, emergency lock removal, training requirements, and control forms to provide documentation whenever lockout/tagout procedures are implemented.

LOCKOUT

Lockout is a way of keeping equipment from being set in motion while it is being serviced or maintained.

All authorized persons will be provided with their own lockout devices. There will be only one key for each lock unless spare keys are kept by the company, in a secure location, for emergency use only.

Never borrow someone else’s key!!

Locks are only to be removed by the people who place them unless there is an emergency situation.

Two examples of lockout devices are:

Padlocks: Multiple Lockout Devices:

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TAGOUT

This is a written warning that is attached to a lockout device to alert others that the equipment has some type of maintenance or service being performed on it.

The warnings on these tags should include some type of legend such as:

Do not start Do not openDo not operate

Some examples of tags are:

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WHEN TO USE LOCKOUT/TAGOUT

Lockout/tagout shall be used whenever an employee is performing maintenance on any machine where that employee or other employees could be injured by:

Unexpected start-up of the equipment; or

Release of stored energy.

The two most common situations needing lockout/tagout are:

Whenever a machine guard or other safety device must be removed or bypassed;

Whenever an employee must place any part of his or her body where it could be caught by moving machinery.

Other examples of when lockout/tagout must be used:

Cleaning or oiling machinery with moving parts; Clearing jammed mechanisms;

Repairing electrical circuits.

TRAINING REQUIREMENTS

Training requirements differ for each classification of employee.

All employees in the three categories listed below will receive training in lockout/tagout procedures. Training and retraining will be documented according to OSHA regulations.

Retraining will be provided to all authorized and affected employees whenever there is a change in their job assignments, a change in machines, equipment or processes that present a new hazard or when there is a change in the energy control procedures.

Retraining will reestablish employee proficiency and introduce new or revised control methods and procedures as necessary.

Additional retraining will be conducted whenever an employer has reason to believe that there are deviations from or inadequacies in the employee’s knowledge or use of the energy control procedures.

1. AUTHORIZED EMPLOYEES are the people who actually utilize the lockout/tagout system to perform maintenance and/or servicing on equipment.

Authorized employees will receive training in the recognition of applicable hazardous energy sources, the type and magnitude of the energy available in the work place and the methods and means necessary for energy isolation and control.

2. AFFECTED EMPLOYEES are the people whose job requires that they work in an area when servicing and/or maintenance is being performed.

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Each affected employee will be instructed in the purpose and use of the energy control procedure.

3. OTHER EMPLOYEES are the people whose work operations are, or may be in an area where energy control procedures may be utilized.

All other employees whose work operations are or may be in an area where energy control procedures may be utilized, shall be instructed about the procedure and about the prohibition relating to attempts to restart or re-energize machines or equipment which are locked and tagged out.

GENERAL PROCEDURES FOR DISTRIBUTION

OF LOCKOUT / TAGOUT DEVICES

1. All authorized personnel will be assigned locks, tags and lock adaptor devices.

2. Locks will be assigned to specific employees. Each lock will have only one key. Locks and keys are never, under any circumstances, to be used by an employee other than the employee to whom they are assigned.

3. The maintenance supervisor will be assigned spare locking devices and spare tags. These can be used in situations where additional locking is required. The extra equipment is to be kept in a secure location and distributed by the supervisor as needed. A distribution control sheet is to be used to record use of the additional devices.

4. There may be situations when supervisors do not have the required devices or there are too few devices for the job at hand. Additional equipment and devices will be kept in a secure location, and be available under the same control procedures.

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UTILIZING THE LOCKOUT / TAGOUT SYSTEM

To properly utilize the lockout/tagout system, you must:

A. PREPARE: 1. Know the types and amounts of energy that power the machine or equipment to be shut down;

2. Know the hazards of that energy;

3. Know how the energy can be controlled;

4. Locate all switches, valves and energy sources that pertain to this machine or piece of equipment. Use the check sheet posted at each machine to ensure that all sources have been identified.

B. USE THE LOCKOUT/TAGOUT PROCEDURE: 1. Notify all affected employees that the lockout/tagout system is being utilized;

2. Shut down the machine as you normally do;

3. Operate all energy isolating devices so that the equipment is isolated from its energy sources. Be sure to isolate all energy sources including any secondary power supplies as well as the main power source;

4. Stored or residual energy (such as that in capacitors, springs, elevated machine members, rotating flywheels, hydraulic system, and air, gas, steam or water pressure, etc.) must be dissipated or restrained by grounding, repositioning, blocking, bleeding down, etc.;

5. Apply lockout/tagout devices to the machinery or equipment;

6. Retrace your steps to make sure all switches, valves and energy sources are isolated and locked out;

7. Ensure that the equipment is disconnected from the energy source(s). First check that no personnel are exposed, and then verify the isolation of the equipment by operating the push button or other normal operating control(s).

CAUTION: RETURN OPERATING CONTROL(S) TO NEUTRAL OR ‘OFF’ POSITION AFTER VERIFYING THE ISOLATION OF THE EQUIPMENT.

The machine or equipment is now locked out.

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RETURN TO NORMAL OPERATIONS

To return to normal operations:

1. Make sure the machine or equipment and immediate area around the machine or equipment have been cleared of all nonessential items and that the machine or equipment components are operationally intact.

2. Check the work area to be sure that all employees have been safely positioned or removed from the area.

3. Verify that the controls are in neutral.

4. Replace all guards.

5. Remove the lockout devices and energize the machine or equipment.

Note: the removal of some forms of blocking may require re-energizing of the machine before safe removal.

6. Notify affected employees that the servicing or maintenance is completed, and the machine or equipment is ready for use.

LOCK REMOVAL IN SPECIAL SITUATIONS

When contractors or other out-side workers are performing service or maintenance:

1. The outside contractor and the on-site employer must exchange lockout/tagout information. Employees on the site need to understand rules used by the other company’s energy control program;

2. Be alert for new types of lockout/tagout devices.

If the machine or equipment must temporarily be re-activated:

1. Remove unnecessary tools from the work area, and make sure everyone is clear of the equipment.

2. Remove the lockout/tagout devices and re-energize the system.

3. As soon as the energy is no longer needed, isolate the equipment and re-apply lockout/tagout devices using the 6-step process outlined in this program.

If servicing lasts more than one work shift:

1. Lockout/tagout protection must not be interrupted.

2. Employees leaving work do not remove their locks until the next shift workers are present and ready to replace those locks with their own.

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EMERGENCY REMOVAL PROCEDURES

There may be situations when an authorized employee’s lock must be removed and that employee is not available to remove it, as required in the general lockout/tagout policy. [e.g. when the employee locking out equipment must leave work and does not have the opportunity to exchange his lock with the employee on the next shift.] Procedures for emergency lock removal will be strict and strictly adhered to in order to fully protect employees authorized to perform lockout/tagout.

If the employee who has locked out a machine cannot be located and his lock must be removed, the following procedures must be followed: 1. Attempts must be made to locate the employee who has locked out the equipment. If he cannot be located

in the building [e.g. time keeping records can be checked], an attempt must be made to reach him at home and to explain the circumstances requiring the removal of his lock.

If the employee cannot be reached, he cannot be allowed to return to work until informed that the lock has been removed.

2. Locks can only be removed by persons authorized to perform emergency lock removal.

3. If necessary, the Supervisor on duty may authorize emergency lock removal. The authorizing Supervisor must sign out the spare key located at the Maintenance Supervisor’s office by completing the Emergency Lock Removal Control Log.

4. Before a lock is physically removed from a machine, the machinery and surrounding equipment must be thoroughly searched to verify that all employees have been safely positioned or removed from the area.

* Note: If machinery has areas that would allow an employee to be inside or hidden from view, these areas must be checked before the locking devices are removed.

5. After removal, the removed lock and spare key must be returned to the Maintenance Supervisor’s office, and logged on the Emergency Lock Removal Control Log.

6. A completed Emergency Lockout/Tagout Removal Report shall be sent to the Safety Department, and a copy sent to the Director of Manufacturing.

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EMERGENCY LOCK REMOVAL CONTROL LOG

Name of Employee whose lock is being removed

Lock/Key Serial Number

Date and Time Key Obtained

Date and Time Key Returned

Initials When Returned

Name and Signature of person performing emergency removal

Name:

Date: Date: Name:

Time: Time: Signature:

Name of Employee whose lock is being removed

Lock/Key Serial Number

Date and Time Key Obtained

Date and Time Key Returned

Initials When Returned

Name and Signature of person performing emergency removal

Name:

Date: Date: Name:

Time: Time: Signature:

Name of Employee whose lock is being removed

Lock/Key Serial Number

Date and Time Key Obtained

Date and Time Key Returned

Initials When Returned

Name and Signature of person performing emergency removal

Name:

Date: Date: Name:

Time: Time: Signature:

Name of Employee whose lock is being removed

Lock/Key Serial Number

Date and Time Key Obtained

Date and Time Key Returned

Initials When Returned

Name and Signature of person performing emergency removal

Name:

Date: Date: Name:

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Time: Time: Signature:

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EMERGENCY LOCKOUT/TAGOUT REMOVAL REPORT

INSTRUCTIONS: This form is to be completed only by persons authorized to perform emergency lock removal. The report is to be fully completed for each instance of emergency lock removal and sent to the Safety Office, a copy is to be sent to the Director of Manufacturing.

Please print:

Person performing emergency lock removal: _______________________________ Employee #: _________________________________________________________Date of Removal: _____________________________________________________ Time of Removal: _____________________________________________ a.m./p.m.

Name and # of equipment/machine requiring Emergency lock removal: ____________________

Reason for removal: _____________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

The person originally locking out this equipment had been notified of the emergency lock removal. YES NO

If answer to above question is NO, complete the following:

1. Attempts were made to locate the employee in the building. YES NO

2. Attempts were made to contact the employee at home. YES NO How many? _________

3. Employee’s Supervisor has been advised that employee has not been contacted and may not return to work until he has been notified of the lock removal. YES NO

4. The equipment/machinery has been thoroughly checked to confirm that all personnel are safely positioned or removed from the area. YES NO

Signature __________________________________________________

Original: Safety DepartmentCopy: Director of Manufacturing

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ENFORCEMENT

No lockout/tagout program can be successful without fair, uniform enforcement of safety standards. A good safety enforcement program includes:

A clear lockout/tagout policy that states procedures and responsibilities.

Disciplinary measures for failure to follow the policy.

100% enforcement of penalties for safety violations.

The company policy for lockout/tagout is available to all employees, and each employee is held individually accountable for following the safety standards in it. Contractors or other outside personnel performing any work in the plant that calls for lockout or tagout that will be controlled by the maintenance supervisor or assigned individual.

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OUTSIDE CONTRACTOR WELDING-HOT WORK PERMIT

Location and Description of Work Site _____________________________________Department__________________________________________Date____________ Start Work________________________ Finish Work ______________________ Job_________________________________________________________________

GENERAL REQUIREMENTS

1. All welding cable and equipment must be kept clear of passageways, ladders, and stairways.

2. Appropriate fire extinguishers must be readily accessible to work site.3. All combustibles must be relocated at least 50 feet from work area and a fire

watch must be maintained. Non-combustible curtains must be used between the operation and combustible materials when adequate separation cannot be maintained.

4. All hollow spaces, cavities or containers shall be vented before preheating, cutting or welding.

5. Any welder or helper working on platforms, scaffolds, or runways shall be protected against falling by railings, safety belts, or lifelines.

6. A new hot work-welding permit must be obtained everyday and for each new job to be performed.

7. All welding equipment must comply with OSHA specifications.8. Immediate work area and areas on floors above and below, must be inspected

prior to and after completion of any operation.

PERSONAL PROTECTIVE EQUIPMENT

1. Helmets or hand shields must be worn during all arc welding or arc cutting operations. Helpers shall have eye protection.

2. Appropriate eye protection shall be worn during all gas welding or oxygen cutting operations.

CONFINED SSPACE REQUIREMENTS

1. Gas cylinders and welders must be left outside of the space.2. Heavy wheel mounted equipment must be blocked to prevent accidental

movement.3. Safety belts, harnesses, lifelines, etc., shall be used to quickly remove workers.4. Attendant must be stationed outside of space at all times to assist entrants.5. All electrodes must be removed whenever arc welding will be suspended for any

substantial amount of time. Also machine must be disconnected from power source.

6. Torch valves and fuel-gas and oxygen supply must be closed whenever torch will not be used for a substantial amount of time.

Supervisor Authorizing All Above Conditions__________________________________

Plant Manager ____________________________________

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TO:

FROM: ECR International

DATE:

SUBJECT: Confidentiality of Proprietary Information

In the course of discussions regarding a possible business relationship between our companies or in furtherance of an existing business relationship our two companies may exchange or have access to proprietary and confidential information and want to ensure that it be kept confidential and not disclosed to any third parties. This letter, when countersigned by you, will constitute a binding agreement between us to maintain the confidentiality of all proprietary information exchanged by our two companies.

The term “Proprietary Information”, whenever used in this agreement, shall mean all information and data furnished by one party (the “Disclosing Party”) to the other (the “Recipient”) or its employees or agents, whether in oral, written, graphic or machine readable form, including but not limited to, designs, procedures, product formulations, engineering methods, manufacturing techniques, samples processes, product and customer information, financial information, discoveries, improvements, inventions, concepts, and ideas. Information shall only be considered Proprietary Information if, when disclosed in tangible form, it is marked as Confidential or Proprietary or, when disclosed orally or visually; it is identified as Proprietary Information at the time of disclosure and is confirmed in writing as Proprietary Information within 10 business days after the date of disclosure. Information made available by a party shall not be considered to be Proprietary Information if it is in the public domain, was already known to Recipient prior to receiving it from the Disclosing Party as demonstrated by the Recipient’s written records, or was disclosed to the Recipient by a third party under no obligation to maintain its confidentiality.

In consideration for entering into or for continuing our business relationship and other valuable consideration, which is hereby acknowledged, the parties agree and accept the following terms and conditions:

1. Each party agrees that it shall not at any time, either during or after the termination of any discussions or business relationship with the other party, copy or in any way make available to others any Proprietary Information of the other party without the prior written consent of the other party. However, a Recipient may disclose the same to its affiliated companies, including its parent company, if any (collectively, “Affiliates”), for the limited purpose of assisting Recipient in satisfying any obligations it owes to the Disclosing Party. In the event of any such disclosure to its Affiliates, the Recipient shall be responsible for any prohibited disclosure or use of the Proprietary Information by its Affiliates. The Recipient shall hold all Proprietary Information in strict confidence and shall use reasonable means to protect and safeguard the Proprietary Information, which shall be at least the equivalent of action taken to protect the Recipient’s own proprietary information.

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2. Each party agrees to limit the use of, and access to, the Proprietary Information to its employees whose use or access is necessary to determine whether to enter into a business relationship with the other party or to affect the purposes of an existing business relationship between the parties. Each employee to whom disclosure is made shall be told in writing that such information is proprietary and confidential and must be kept confidential. Each party shall be responsible for any use or disclosure of Proprietary Information by its employees or agents.

3. Proprietary Information divulged to a party shall be used only for the purpose of determining whether to enter a business relationship with the other party or in furtherance of an existing business relationship between the parties.

4. Each party agrees to return all written documents containing Proprietary Information, including any copies, to the Disclosing Party upon the Disclosing Party’s request or the termination of any discussions or business relationship between the parties, whichever is earlier. All Proprietary Information shall remain confidential even after the termination of any such discussions or business relationship, and the provisions of this agreement shall survive the termination of such discussions or business relationship for a period of seven years from the date of such termination.

5. Each party acknowledges that a Disclosing Party will be irreparably harmed if obligations in this agreement are not specifically enforced and that a Disclosing Party would not have an adequate remedy at law in the event of an actual or threatened breach by the Recipient of its obligations. Therefore, each party agrees that the Disclosing Party shall be entitled to injunctive relief for any actual or threatened violations or breaches by the Recipient, its employees, or agents without the necessity of the Disclosing Party showing actual damages or the monetary damages would not afford an adequate remedy.

6. Each party will use its best efforts to assist a Disclosing Party in identifying and preventing any unauthorized use or disclosure of Proprietary Information, and shall advise the Disclosing Party immediately in the event it learns or has reason to believe anyone may or has made unauthorized use or disclosure of Proprietary Information.

7. Each party agrees that all Proprietary Information and any derivative works or improvements on or to the Proprietary Information is and shall be the sole property of the Disclosing Party and shall make no claims to the ownership of such Proprietary Information.

8. The parties hereto agree that this letter agreement is for the purposes of protecting Proprietary Information only. It does not create a joint venture or any other business arrangement or rights, nor does it impose upon a party any obligation to disclose Proprietary Information to the other. Any agreement between the parties to enter into or continue a business relationship will be set forth in one or more separate written instruments.

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If you agree to the foregoing terms and conditions, please sign the enclosed copy of this letter agreement in the space provided below and return the executed copy to the undersigned.

Accepted and Agreed to by:

Company (Please Print)

Signature of Company Representative

Print Name

Title

Date

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By ECR International, Inc.

Signature of Company Representative

Print Name

Title

Date

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INDEMNIFICATION / INSURANCE

1. __________________________(Contractor), shall be responsible for and shall defend, indemnify, exonerate and save harmless ECR International, Inc. (Owner), its officers, agents and employees, from and against:

(A) Any and all liability or penalty which might be imposed by reason of actual or asserted violation of laws, regulations, ordinances or other rules of any government or quasi-governmental body, including actual or asserted failure to pay taxes as herein provided:

(B) Any and all liability, damage, loss, cost, expense (including fees and disbursements of counsel), claims, demands, suits, actions, judgments, or recoveries for or on account of any injury to or death of persons or damage to property, including, but not by way of limitation, damage to property of Contractor, Owner or others, or injury, death of, or damage to property of Owner’s or Contractor’s officers, agents, employees, servants or representatives, arising out of, or in any way occurring directly or indirectly in connect ion with the work, including without limitation, delegable or non-delegable duties imposed on Contractor or Owner by law, whether or not any such injury, death, or damage may have been caused, alleged to have been caused, by the negligence (whether classified as active, passive or otherwise) of Owner, or the Condition of the premises or otherwise;

And Contractor shall at its own expense defend any and all actions based thereon. Any loss, damage, cost or expense (including fees and disbursements of counsel) incurred by Owner in connection with the foregoing may be deducted from Contractor’s compensation then due or thereafter to become due, in addition to any other remedy that Owner may have.

2. The Contractor, at no cost to the Owner, shall maintain insurance of the types and with the terms and minimum coverage and amounts indicated below and shall furnish certificates of same endorsed to ECR International, Inc:

WORKER’S COMPENSATION, statutory limits including all states coverage:

Employers Bodily Injury Liability Limits: $500,000 (each accident)$500,000 (policy limit, disease); and$500,000 (each employee limit, disease).

BUSINESS AUTOMOBILE LIBILITY, including Owned, Hired, and Non-Owned vehicles:

Combined Single Limit of $1,000,000 -OR- Bodily Injury (per person) $ 500,000Bodily Injury (per accident): $1,000,000Property Damage: $ 100,000

COMMERCIAL GENERAL LIABILITY:

General Aggregate (other than Products/Completed Operations) $2,000,000Products and Completed Operations Aggregate: $2,000,000Advertising and Personal Injury Aggregate: $2,000,000Each Occurrence (BI, PD, Personal & Advertising Injury): $1,000,000Fire Damage Legal Liability $ 50,000Medical Payments: $ 5,000

COMMERCIAL UMBRELLA LIABILITY:

Aggregate $2,000,000Each Occurrence $2,000,000

Your GL policy must be endorsed to include ECR International, Inc. as an ADDITIONAL INSURED andprovide for thirty (30) days notice to ECR International, Inc. upon cancellation. ECR reserves the right to request either a copy of the additional insurance endorsement or a copy of the insurance policy.

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Your policies must conform to, and your CERTIFICATE OF INSURANCE must state, the following:

GENERAL LIABILITY AGGREGATE LIMITS APPLY ON A ‘PER PROJECT’ BASIS. NO COVERAGES INCLUDED ON THE STANDARD ISO COMMERCIAL GENERAL LIABILITY POLICY AND ISO BUSINESS AUTO POLICY HAS BEEN DELETED OR SIGNIFICANTLY MODIFIED.

Agreed to this ______________date of_______________________, 20____.

By Outside Contractor:

Company Name (Please Print) By ECR International, Inc.

Name/Signature Name/Signature

Print Name Print Name

Title Title

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By signing below you certified that you have been given a copy of the “ECR Contractor Safety Handbook” and that you agree with and will abide to all policies.

Agreed to this ______________date of_______________________, 20____.

By Outside Contractor:

Company Name (Please Print) By ECR International, Inc.

Name/Signature Name/Signature

Print Name Print Name

Title Title

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