SNAP-ON INCORPORATED STANDARD ON EMPLOYEE TRAINING PROGRAM

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1 SNAP-ON INCORPORATED STANDARD ON EMPLOYEE TRAINING PROGRAM Issued By:.DOC Approval: Page 1 of 9

2 1.0 SCOPE It is Snap-on Incorporated's policy to have in place a management system that drives all operating units to continual improvement in environmental quality and protection of employee health and safety through the application of best management practice. Best management practice is the minimization of impacts from operations and production by optimizing all of the following: Inputs Processes, Procedures, Practices Prevention and Beneficial Reuse of Waste Minimization of Air Emissions, Wastewater Discharges and Disposal of Waste From Processes and Packaging Safe and Healthy Work Environs This standard applies to all semiautonomous business units, manufacturing plants, distribution centers and repair or service centers worldwide. 2.0 PRACTICE 2.1 General Requirements Each employee actively involved in the operation and implementation of the Environmental, Hygiene and Safety Management System and employees exposed to hazardous conditions or substances must receive on an annual basis the training required to maintain their knowledge and skills at an acceptable competence level per. Training programs must include the following as appropriate: (1) Each employee potentially exposed to hazardous materials shall be trained in the proper identification and quantification of exposures. (2) Each employee potentially exposed shall be familiar with the necessary protective equipment and how it is to be properly maintained. (3) Each employee potentially exposed to hazardous material during release response shall be familiar with the Spill Prevention Control and Countermeasure Plan (SPCC) and their role in plan implementation. (4) Employees potentially exposed to unsafe conditions or agents, including ergonomic stressors, shall be given adequate and periodic training with regard to the recognition and elimination of safety hazards. (5) Employees directly involved in EH&S Management System operation and implementation will receive annual skill-enhancement training. (6) Certified facilities shall provide quarterly training updates, i.e., percent of allocated task completed to the lead auditor of the SEQ Group). Page 2 of 9

3 2.2 Hazard Communication Requirements: Section requires that employees be provided with information and training on hazardous chemicals in their work area at the time of their initial assignment and whenever a new hazard is introduced into their work area. Additionally, annual updates are required. Information and training shall include: (1) Information. Employees shall be informed of: i. The requirements of Hazard Communication are outlined in and ; ii. Any operations in their work area where materials deemed hazardous are present; and iii. The location and availability of the written hazard communication program, including required list(s) of hazardous chemicals, and Material Safety Data Sheets. (2) Hazard Communication Training. Employee training shall include at least: i. Methods and observations that may be used to detect the presence or release of a hazardous chemical in the work area (such as monitoring conducted by Snap-on, continuous monitoring devices, visual appearance or odor of hazardous chemicals when being released, etc.); ii. The physical and health hazards of the chemicals in the work area; iii. The measures employees can take to protect themselves from these hazards, including specific procedures the plant has implemented to protect employees from exposure to hazardous chemicals, such as engineering controls, appropriate work practices, emergency procedures, and personal protective equipment to be used; and iv. The details of the hazard communication program developed by the plant, including an explanation of the labeling system and the Material Safety Data Sheet, and how employees can obtain and use the appropriate hazard information. The Facility Management shall use the methodologies of and, Chemical Hygiene and Safety Plan, for establishing the hazard communication program. Employee Exposure and Hazard Communication and Training Standard records shall be kept for a period of five years. 2.3 Hazardous Waste Training: Each plant will provide hazardous waste management training to those employees designated as responsible for or are engaged in activities or operations involving hazardous waste. State and federal law considerations require that all persons engaged in these hazardous waste activities complete classroom and/or on the job training. This requirement is for both large and small quantity generators. Essential elements of hazardous waste training shall include at least the following: (1) Federal and state hazardous waste regulations as appropriate for the jurisdiction. Page 3 of 9

4 (2) Procedures and practices for using, inspecting, repairing and replacing emergency and monitoring equipment if required. (3) Contingency plans, including emergency response implementation. (4) Hazardous waste management training will be conducted by the facility for each employee assigned to hazard waste operations as follows: i. Within six months of initial assignment. ii Reinforcement training annually. (5) Hazardous waste training records on currently assigned personnel must be retained indefinitely. Records on former employees must be kept for a minimum of thirty years from the date of last assignment. Retained records will contain an explanation of the training which each employee received and will be of a format approved by the Safety, Environment and Quality Group, and reflect prevailing requirements of state and federal enforcement agencies. 2.4 Emergency Response Requirements: Within the production and distribution centers, emergency response can be characterized as "Responses to incidental releases of hazardous substances where the substance can be absorbed, neutralized or otherwise controlled at the time of release by employees in the immediate release area or by maintenance personnel." As a bare minimum, each employee required to respond to incidental releases shall have, on an annual basis, training courses designed to address the following training concerns: (1) Understanding what hazardous materials are used in their work area and the risks associated with an incidental release. (2) Ability to recognize the presence of such releases. (3) Understanding the role of all participants engaged in a release response (SPCC). (4) Understanding the various steps involved in implementing the facility Spill Prevention Control and Countermeasure Plan (SPCC) and the Stormwater Pollution Prevention Plan (SPPP). (5) Knowledge of what is proper personal protection equipment and how to select it. (6) Decontamination techniques where required. (7) Understanding of relevant standard operating procedures and operation termination procedures. 2.5 Laboratory Personnel Standard: Snap-on will provide employee information and training for laboratory workers exposed to hazardous chemicals: (1) Employee information and training. The employer shall provide employees with information and training to ensure that they are apprised of the hazards of chemicals present in their work area. (2) Such information shall be provided at the time of an employee's initial assignment to a work area where hazardous chemicals are present and prior to assignments involving new exposure situations. The frequency of refresher information and training shall be annually. Page 4 of 9

5 (3) Information. Employees shall be informed of: i. The contents of this standard operating procedure and Procedure Chemical Hygiene and Safety Plan shall be made available to employees; ii. The location and availability of the Chemical Hygiene and Safety Plan ; iii. The permissible exposure limits for regulated substances or recommended exposure limits for other hazardous chemicals where there is no applicable national standard; iv. Signs and symptoms associated with exposures to hazardous chemicals used in the laboratory; and v. The location and availability of known reference material on the hazards, safe handling, storage and disposal of hazardous chemicals found in the laboratory including, but not limited to, Material Safety Data Sheets received from the chemical supplier. (4) Training: Basic requirements of employee proficiency. i. Employee training shall guarantee proficiency in: A. Methods and observations that may be used to detect the presence or release of a hazardous chemical (such as monitoring conducted by Snap-on, continuous monitoring devices, visual appearances or odor of hazardous chemicals when being released, etc.); B. The physical and health hazards of chemicals in the work area; and, C. The measures employees can take to protect themselves from these hazards, including specific procedures the employer has implemented to protect employees from exposure to hazardous chemicals, such as appropriate work practices, emergency procedures, and personal protective equipment to be used. (5) Facilities where chemical labs are adjunct to a production process, shall include laboratory safety and hygiene training as a part of the facility written hazard communication program in lieu of Subsections (1) - (4) of this section. 2.6 Stormwater Training Stormwater training under 40 CFR shall be performed biennially per the instructions of the local control authority for affected employees. 2.7 General Safety and Hazard Elimination Each operating facility will conduct periodic worker safety training as indicated by Schedule A. Additionally, members of ergonomics teams and safety committees shall receive at a minimum eight hours training annually, such as the two (4 hour) primers on ergonomics and safety. Page 5 of 9

6 2.8 Implementation It is the responsibility of Facility Management to maintain within his plant a training agenda consistent with the requirements of this standard. It is the responsibility of the Director, Safety, Environment and Quality Group to provide to the plants the support necessary to accomplish the goals and objectives of this standard. Such support may include the following: i. Conducting EH&S training for plant personnel responsible for training at the plant level on an annual basis (the annual EH&S Conference). ii. Assisting facility personnel in developing, maintaining and auditing hazardous materials training programs for compliance with federal and state regulations. iii. Assisting plants in meeting safety training requirements as mandated by various governmental agencies worldwide. Page 6 of 9

7 SCHEDULE A SAFETY TRAINING FOR LINE EMPLOYEES (U.S. OPERATIONS) TYPE REFERENCE* EMPLOYEE GROUP 1. Emergency Response Plan 29 CFR , 2. Fire Prevention 29 CFR , 3. Hazard Communication 29 CFR , 4. Hearing Conservation 29 CFR , SEQ Confined Space 29 CFR , 6. Personal Protective Equipment 29 CFR (f), 7. Laboratory Safety 29 CFR Lockout/Tagout 29 CFR , SEQ Powered Indus. Trucks 29 CFR Electrical Safety 29 CFR , SEQ Fire Extinguishers 29 CFR Welding-Cutting 29 CFR Blood-borne Pathogens 29 CFR SEQ Process Safety 29 CFR , 15. Hazardous Materials Transportation 49 CFR 172(H), SEQ Lead Exposure 29 CFR Machine Safety 29 CFR CFR SEQ 64.01, SEQ64.71 Exposed at 85 dba or Higher Fork Drivers (Covered Under 3. Above) UPDATE - ESTIMATED TIME Annually, 1 Hr. Biennially, 15 Mins. Biennially, 1 Hr. Annually, 30 Mins. 18. Ergonomics Biennially, 15 Mins. 19. Stormwater 40 CFR Part , SEQ EH&S MS Awareness ISO14001, RCRA Hazardous Waste 40 CFR 261 & 262 SEQ64.61 * Applies to U.S. Operations. Annually, 30 Mins. Page 7 of 9

8 SCHEDULE A-1 (NON U.S. OPERATIONS) ANNUAL SAFETY TRAINING FOR LINE EMPLOYEES TYPE REFERENCE* EMPLOYEE GROUP RISK ASSESSMENT 1 HR. OTHER SAFETY 1 HR. ENVIRON- MENTAL 1 HR. OTHER ½ HR. 1. Emergency Response Plan 2. Fire Prevention 3. Hazard Communication 4. Hearing Conservation SEQ64.56 Exposed at 85dBA or Higher 5. Confined Space SEQ Personal Protective Equipment 7. Laboratory Safety 8. Lockout/Tagout SEQ Powered Indus. Trucks Fork Drivers 10. Electrical Safety SEQ Fire Extinguishers 12. Welding-Cutting 13. Blood-borne Pathogens SEQ64.54 Non- Applicable 14. Process Safety 15. Hazardous Materials Transportation SEQ64.61 (Covered Under 3. Above) 16. Lead Exposure 17. Machine Safety SEQ SEQ Ergonomics 19. Stormwater SEQ EH&S MS Awareness ISO14001, Industrial Hygiene OHSAS 18001, * Applies to non U.S. Operations. ** Facility management has the option to complete an annual certification to satisfy A-1 recordkeeping. *** Blood-borne Pathogens training does not apply to non U.S. Operations. Page 8 of 9

9 Date REVISION LOG Revision Statement 12/01/95 Initial issue. 02/03/97 Annual review and revisions to expand scope of the EH&S Management System to Non U.S. entities. 12/21/98 Annual review. 12/13/99 Annual review. 03/06/00 Reconciliation with external audit recommendations. 05/15/00 Update after initial audits for certification. 01/15/01 Annual review and revision. Added element (6) to Section 2.1. Revised training requirements on Schedule A. 12/28/01 Annual review and revision with changes from MTS to SEQ due to Corporate realignment. Minor administrative changes, including training references. 07/01/02 Periodic review. Changes to 2.6, 2.7, 2.8, Schedule A and Schedule A-1. 01/01/03 Annual review and revision. 01/01/04 Annual review no changes. 09/01/05 Annual review and revision to reflect organizational and system changes. pages affected. Page 9 of 9

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