ENVIRONMENTAL, HEALTH & SAFETY MANAGEMENT SYSTEMS MANUAL

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1 September 7, General Requirements (ISO ; OHSAS ).. Alcoa Fastening Systems Republic Operations (AFS Republic) has established, documented, implemented, maintains, and continuously improves an EH&S management system that meets the requirements of the international standard ISO 400:2004 and OHSAS 800: This policy shall be communicated to all persons working under the control of the organization with the intent that they are made aware of their individual EHS obligations. This includes all contractors, visitors, suppliers working for or on behalf of AFS Republic. 2. EH&S Policy (ISO ; OHSAS ) 2.. EHS Policy Statement 2.2. Vision AFS Republic operates in a safe, responsible manner, which respects the environment, focuses on prevention of pollution, and the health of our employees, our customers, and the community where we operate. We will not compromise the EHS values for profit or production. We will continually work towards the elimination of EH&S hazards, control of unsafe acts/behaviors, exposures that may cause ill health and ensuring compliance with AFS Republic policies and local, state, and federal regulations as well as continual improvement in EHS management and EHS performance. AFS Republic s management is committed to conducting business in a safe and healthful manner, which includes the prevention of injuries and illnesses, the control of hazardous materials, and the protection of the environment. This will be accomplished through leadership and sustained commitment, and utilizing the best available technology, when possible Mission 2.4. Goals AFS Republic will continually work towards the elimination of hazards and unsafe acts/behaviors, in order to reduce the number of accidents, EHS incidents, and job related injuries/illnesses. We will work safely in a manner that promotes the health and well-being of the individual and the environment. Identify the actual and potential effects our operation has on the environment. Commit to the prevention of pollution and the continual improvement of company programs by reviewing stated EHS objectives. Develop internal methods that meet all relevant regulations, laws and other requirements. Invest in appropriate technologies that are designed to conserve natural resources and provide positive benefits to the environment and society. Provide on-going documented education to raise the awareness and abilities of all employees. Foster a spirit of interaction throughout the community by making this statement available to the public. Page of 4

2 September 7, EHS Principles We value human life above all else and manage risks accordingly. We relentlessly pursue an EHS incident free workplace. AFS - Republic works to prevent incidents or adverse impacts, in addition to responding to them after an occurrence. EHS Incidents, including environmental spills, excursions and other impacts, whether immediate, latent or cumulative, can be prevented. Our goal is a work place that is incident free. Line management is accountable for assuring the means to accomplish this goal and employees must contribute to this goal. Training to equip employees with the skills necessary to recognize and prevent potential incidents will be provided. We comply with all laws and set higher standards for our suppliers and ourselves where unacceptable risks are identified. We support sustainable development by incorporating social responsibility, economic success and EHS excellence in our decision making process. AFS - Republic integrates EHS management with business and operating management to ensure that EHS issues are considered in conjunction with financial aspects, when decisions are made regarding new and existing facilities, processes, products, services, acquisitions and divestitures. We measure and assess our performance and are open and transparent in our communications. AFS - Republic in cooperation with Alcoa, audits its manufacturing operations EHS performance on a regular basis to evaluate EHS Policy conformance, strengths/weaknesses in environmental, health and safety management processes and plans; and to identify actions that need to be taken to prevent incidents or correct deficiencies. Appropriate AFS - Republic Directors and Senior Managers will periodically be informed of the audit findings. AFS - Republic will communicate promptly and openly with individuals, concerned parties and communities who request information regarding our EHS policy and the significant environmental, health and safety potentials or impacts of our operations. We supply and use safe and reliable products and services. AFS - Republic takes reasonable and practical precautions to assure that the products and services that AFS - Republic supplies to its customers are consistent with the EHS Policy. Customers are provided complete and accurate product information. We use our EHS knowledge to enhance the safety and well being of our communities. AFS - Republic periodically sponsors internal or external activities that reduce or minimize potential EHS impacts of our operations, our products or that advance EHS in the communities where we are located. We are all accountable for conforming with and deploying our EHS Value, Policy, and Principles. AFS Republic Employees, including contractor employees, are responsible for working in a manner that respects the health and safety of the individual and the environment. Such behavior is a requirement of the workplace. Line management is accountable for assuring compliance with the EHS Policy and responding to environmental, health and safety issues or concerns. Page 2 of 4

3 September 7, Planning (ISO ; OHSAS ) 3.. Environmental, Health & Safety Aspects and Risks (ISO ; OHSAS ) a. Includes a commitment to prevention of injury and ill health and continual improvement in management and performance: i. The management team is required to identify the EHS aspects and risks of its activities, products and services to determine which have or can have significant EHS aspects and/or risks, in accordance with EHS , "EHS Aspects and Impacts. Department Managers will provide assistance and guidance to assist the EHS group to identify the EHS aspects within their respective departments. AFS Republic s EHS aspects and risks are documented in a log that is updated in response to changing circumstances. i EHS aspects and/or risks are subjected to a systematic evaluation of their significance, using a disciplined and documented method. Evaluation criteria and method, and final selection of significant aspects/risks are documented. b. EHS Aspect and Risk Identification i. The Core (C4) Four, consisting of two executive coordinators, four primary coordinators and four back-up coordinators, representing various departments and functions, identifies initial EHS aspects and/or risks. On an annual basis, or as needed, the management team manages changes in activities, products, and services that create new EHS aspects / risks, or in-validate previously identified aspects/risks. New aspects and/or risks may also be identified through the management review or by internal or external audits of the EHS. i EHS aspects are documented and maintained by the EHS Manager. c. Determination of Significant EHS Aspects and/or Risks i. The Managers evaluate significance of initial EHS aspects and/or risks. On an ongoing basis, the management carries out evaluation of significance as necessary. Significance of EHS aspects and/or risks is evaluated using a systematic risk analysis methodology. Aspects and/or risks are rated with regard to the severity of associated impacts/risks and probability of occurrence. The combined significance rating is calculated using a formula by which an average of individual input by the group is taken. These aspects/risks are taken into account in establishing, implementing, and maintaining the AFS Republic EHS management system. i Selected significant EHS aspects and/or risks are reviewed and are recorded. Page 3 of 4

4 September 7, Legal and Other Requirements (ISO ; OHSAS ) i. The management team is responsible for identifying the applicable regulatory and other requirements, or for coordinating, the internal or external experts engaged to identify these requirements in accordance with EHS , "EHS Legal and Other Requirements. i Based on the recommendations of the ISO Management Representative, the Management team is responsible for deciding whether in-house resources and expertise are sufficient to identify the legal, regulatory, and other requirements that apply, or whether the outside assistance of an attorney, consultant, or other expert is required. iv. v. AFS Republic identifies and has access to legal, regulatory, and other requirements to which the company subscribes. b. The process of identifying legal, regulatory and other requirements is developed in the following phases i. Identification of current compliance programs, and preliminary research of activities and products that could potentially be subject to EHS regulations; i Management review to determine whether in-house expertise and resources are sufficient to identify all applicable requirements; iv. v. Initial identification and documentation of specific laws, regulations, and other requirements that apply to the facility; vi. v Ongoing identification of new or modified activities that could potentially be subject to EHS regulations; and vi ix. Ongoing review of new EHS regulations and changes in legal and other requirements that may apply to the facility. c. Legal, regulatory, and other requirements are documented Objectives, Targets and Programs (ISO ; OHSAS ) i. Establishing relevant objectives and targets for attaining the goals of the EHS policy begins with the commitment of senior management within each department. Each operating department is required to adhere to the objectives and targets to attain the goals of AFS Republic s EHS policy. Based on regular review of significant aspects, goals and objectives are determined by the management team and reviewed by upper management. Page 4 of 4

5 September 7, AFS Republic establishes EHS objectives and targets to fulfill the EHS policy and improve EHS performance in areas related to significant EHS aspects, legal and other requirements, and views of interested parties. i Objectives, targets, and/or programs are maintained in areas pertaining to prevention of pollution. iv. Objectives, targets, and programs shall be measurable, committed to continual improvement, and consistent with legal and other requirements. 4. Implementation and Operation (ISO ; OHSAS ) AFS Republic shall take into account planning, performance, measurement results, audit checking, and corrective action during the implementation and operation of the EH&S. 4.. Structure and Responsibility (ISO ; OHSAS ) i. The Director of Operations provides guidance to the organization with regards to positions and reporting structure, and is responsible for ensuring that the EHS is properly established, resourced, implemented, and maintained. The Director of Operations provides the EHS organizational structure, including identification of the ISO Management Representative, in accordance with the organizational chart. All departments and functions in the company are responsible for implementing, maintaining, and supporting the EHS. b. ISO Management Representative i. AFS Republic appoints the EHS Manager (or designee) as the ISO Management Representative for EHS. The ISO Management Representative has the authority and responsibility to ensure that the EHS is established, implemented, and maintained in accordance with the requirements of ISO 400 and OHSAS 800. c. Organization and Responsibilities i. Interrelation of personnel who manage, perform, and verify activities comprising EHS is defined in the organizational chart Training, Awareness and Competence (ISO ; OHSAS ) i. Personnel (including contractors and person's not directly employed by AFS Republic) performing tasks that can cause significant EHS impacts and/or present Health and Safety hazards are required to be evaluated for competence on the basis of appropriate education, training, and/or experience, in accordance with Human Resources. Page 5 of 4

6 September 7, Employees shall be made aware of: The importance of conformance with the EHS policy and procedures and with the requirements of EHS. The significant EHS impacts and/or hazards, actual or potential, of their work activities and the EHS benefits of improved personal performance. Their roles and responsibilities in achieving conformance with the EHS policy and procedures and with the requirements of EHS, including emergency preparedness and response requirements. The potential consequences of departure from specified operating procedures i The Training and Information Coordinator (TIC), Department Managers, and Human Resources will establish the framework per Human Resources, for a training program, which meets the above requirements. The TIC, Human Resources, and Department Managers are responsible for providing employee training. iv. AFS Republic identifies training needs and provides EHS awareness and EHS training to all personnel. b. The EHS Awareness Program is comprised of EHS new hire orientation training, ongoing employee training, communication of the EHS policy and other information about EHS (EHS Bulletin Board), distribution, and instruction in the use of, procedures and work instructions; and training in emergency response. c. Personnel whose work can cause a significant EHS impact or expose them to significant risks will be provided with the appropriate EHS competence and skill training. d. Training programs are reviewed and amended to address new developments and changes, and response to nonconformances identified through the system of corrective and preventive actions and internal audits of EHS. e. All EHS training is recorded Communication (ISO ; OHSAS ) i. The Managers and the rest of the senior team are responsible for maintaining appropriate communications regarding EHS, its effectiveness, and performance in accordance with EHS Consultation and Communication, which includes but is not limited to: Internal communication between various functions and levels of the organization. Receiving, documenting, and responding to relevant communication from external interested parties. External communication regarding AFS Republic s significant EHS aspects and/or risks. Page 6 of 4

7 September 7, The ISO Management Representative and/or the Core (C 4 ) Four are responsible for reviewing relevant communications from external interested parties and determining the appropriate responses and actions. i AFS Republic maintains systems for internal communication concerning EHS and EHS issues. AFS Republic also maintains a procedure for communicating with external interested parties, including instructions for receiving, documenting, and responding to relevant communication. b. Internal Communication i. The leadership team communicates to the organization significant EHS aspects, risks, the EHS policy, objectives, targets, and management programs; EHS procedures and work instructions; major events and achievements, and recognition of individual employees and groups. The organization communicates to the leadership team information and data regarding new EHS aspects, risks, status of EHS performance; progress in achieving objectives and targets, status of implementation effectiveness of EHS, specific concerns regarding the environment; and suggestions on how to improve EHS and its performance. i Information is communicated through: distribution of EHS documentation, EHS alerts EHS reports EHS Committee Monthly all-hands facility meeting Monthly Business Review c. External Communication regarding EHS issues i. All incoming external communication regarding EHS issues is forwarded to the EHS Manager and is recorded in the external communications log. The EHS Manager forwards the communication to the Core (C 4 ) Four for review. The ISO Management Representative and the Core (C 4 ) Four determine which other functions should be informed or involved, what response should be given to the originator, and whether any internal actions should be considered to address issues raised in the communication. i However, if a copy of the significant EHS aspects is requested by external parties in writing, the Core (C 4 ) Four will evaluate the request and decide if it should be granted. The decision will be recorded in the meeting minutes. If the request is approved, the requested material will be provided to the requestor by the EHS Manager. iv. The EHS policy is available to the public. The policy is posted in the main lobby, employee area in the entrance, and on the EHS Bulletin Board within the company. A copy of the policy is available to interested parties upon request. Page 7 of 4

8 September 7, EHS Management System Documentation (ISO ; OHSAS ) i. EHS, standard operating procedures, work instructions, and other related documentation, are documented in accordance with EHS "Control of Documents. Departmental management and the management team is responsible for identifying specific documents that need to be controlled by the EHS and to: Describe the core elements of management system and their interaction. Provide direction to related documentation. b. Documents pertaining to the EHS include: i. EHS Manual and standard operating procedures; Documentation defining significant EHS aspects, risks, objectives and targets, legal and regulatory requirements, and management programs for reaching objectives and for monitoring EHS performance and compliance i Laws, regulations, standards, codes of practice, and other such documents defining applicable requirements iv. Training programs and materials v. Emergency preparedness and response procedures vi. Work instructions, operational data sheets, and other written instructions for personnel whose work can create a significant EHS impact and/or risk v Documentation defining equipment and other operational controls, and instructions for their use and maintenance 4.5. Document Control (ISO ; OHSAS ) i. Departmental management and the Core (C 4 ) Four are responsible for identifying specific documents that need to be controlled. The Document Control Coordinator is responsible for coordinating all activities to control documents, so that: documents can be located; documents are periodically reviewed, revised as necessary, and approved for adequacy by authorized personnel; Page 8 of 4

9 September 7, current versions of relevant documents are available through the document control system; obsolete documents are promptly removed from all points of issue and points of use or otherwise treated to prevent unwanted access; obsolete documents that are retained for legal and/or historical purposes are suitably identified. AFS Republic controls all documents related to the EHS to ensure that they are reviewed and approved by authorized personnel, that current versions of documents are available where they are required, that obsolete documents are promptly removed, and to ensure the integrity of documents. b. As applicable, documents are identified by their title, procedure number, and revision number. c. Prior to issue and release, documents are reviewed for adequacy, correctness, and conformity with the EHS policy. d. Changes to documents are reviewed and approved by the same function or department that approved the initial document, unless specified otherwise. Revised documents are distributed with a change brief summarizing the changes. e. Obsolete documents are removed from points of use and are retained for historical purposes in a manner such that they are accessible only to authorized personnel. f. Where documents are controlled in hardcopy form, master copies of obsolete documents are stamped OBSOLETE and are stored separate from active documents. g. Documents may be issued to personnel and outside parties who are not affected by the document, but need a copy for information only. These documents are stamped or printed with a statement declaring that the document is UNCONTROLLED Operational Control (ISO ; OHSAS ) i. The management team is responsible for identifying operations and activities that are associated with significant EHS aspects in accordance with EHS Health & Safety Management Programs so that: AFS Republic Newbury s EHS policy, objectives and targets are met; Procedures are established, maintained and implemented to: o Identify activities, products, and services which may have significant EHS impacts and/or risks; o Address situations in which deviations from the EH&S policy, objectives, or targets could occur o Communicate relevant requirements to suppliers and subcontractors. Page 9 of 4

10 September 7, Managers conducting operations and activities associated with significant EHS aspects and identified risks are responsible for planning these operations and for ensuring that they are carried out under specified and controlled conditions. i AFS Republic communicates EHS requirements to any suppliers and/or subcontractors working for or on behalf of AFS Republic. b. Operational Controls i. Operational controls are methods, systems, processes, equipment to safeguard the environment, and eliminate, reduce or control risks. This includes operational criteria and procedures, work instructions, and inspection and preventive maintenance programs. c. Purchasing and Subcontractor Control i. Purchasing is controlled by specifying and communicating EHS requirements, and by monitoring of supplier performance. The following categories of purchased products and subcontractors are controlled by the EHS: Hazardous materials, substances and chemicals, equipment for processing, storing and handling hazardous wastes, hazardous waste haulers, treatment, and disposal facilities Personal protective equipment and equipment to be used for emergency response Measuring and test equipment intended for monitoring EHS performance and regulatory compliance (including calibration) Subcontractors performing services at the facility, who bring in hazardous materials or chemicals, or generate hazardous waste Additional products and services that may be identified by the department because of their association with significant EHS aspects, identified risks, objectives or targets 4.7. Emergency Preparedness and Response (ISO , OHSAS ) i. The relevant Department Managers are responsible for inventorying materials, wastes and other substances, which, because of their characteristics, quantities, and other aspects, create a potential hazard and can, cause an emergency, in accordance with Emergency Preparedness and Response. The management team, with input from relevant departments, is also responsible for identifying and evaluating potential emergencies and for developing appropriate response plans and procedures. i AFS Republic identifies potential accidents and emergency situations, and develops appropriate response plans for preventing and mitigating associated EHS impacts. Emergency response procedures are tested where practicable, and are reviewed, in particular, after occurrence of accidents or emergency situations. Page 0 of 4

11 September 7, The facility and other relevant departments identify potential hazards that can cause accidents and emergency situations, to include hazardous materials and substances, dangerous activities, and potential hazards created by outside forces and natural disasters. Each potential hazard is evaluated to determine whether emergency response plans are warranted and, where relevant, appropriate emergency plans and procedures are developed. Emergency preparedness and response procedures are documented. Relevant personnel are made aware of the procedures and where they are located. Where practicable, emergency procedures are periodically tested. The management team is responsible for reviewing and, as necessary, revising emergency procedures after each occurrence of accidents and emergencies. 5. Checking and Corrective Action (ISO ; OHSAS ) AFS Republic shall take into account implementation and operation, performance measurement results audits and management review when implementing its policy via the relevant procedures. 5.. Monitoring and Measurement (ISO ; OHSAS ) i. The management team is responsible for reviewing relevant data and information on activities, products, and services that are associated with significant EHS aspects and/or risks, in accordance with stated significant aspects. The Management team is also responsible for reviewing data and information relevant to EHS and/or compliance. The EHS Manager is responsible for reporting incidents and the general compliance evaluation. Departmental management is responsible for the identification, calibration, and maintenance of measuring and test equipment, in accordance with stated calibration protocol. i AFS Republic monitors and measures the performance of operations and activities that have the potential for a significant EHS impact and evaluates its compliance with applicable laws and regulations. b. For each monitored or measured characteristic, the management team determines the measurement or test method, frequency, acceptance criteria, responsibility, and the manner for recording results. c. When EHS performance falls below desirable level, the management team determines corrective/preventive actions, or establishes appropriate objectives and targets to improve performance. If there is a possibility of a noncompliance against laws or regulations, the EHS Page of 4

12 September 7, Manager initiates corrective/preventive actions, or refers this decision to the ISO Management Representative Evaluation of Compliance (ISO ) AFS Republic will periodically evaluate compliance with relevant EHS legislation and regulations including other requirements as necessary Nonconformance and Corrective and Preventive Action (ISO ; OHSAS ) i. Corrective or preventive actions taken to eliminate the causes of actual or potential nonconformance situations shall be appropriate to the magnitude of the problems and commensurate with the potential EHS impact and/or risk, in accordance with, EHS Nonconformance and Corrective and Preventative Action. Each operating department is required to assist in maintaining procedures and processes for identifying, investigating, and correcting actual or potential nonconformance situations. Each operating department shall implement these procedures for its operations, utilizing its monitoring and measurement system to assess compliance with applicable requirements and the EHS policy. i The Corrective Action Coordinator will provide guidance to the operating departments in identifying, investigating, and correcting nonconformance and will periodically assess the adequacy of each department s nonconformance process. iv. AFS Republic maintains corrective and preventive action procedures for handling and investigating nonconformances, and for eliminating their causes. Corrective and preventive actions are followed up to verify their implementation and effectiveness. b. Corrective/Preventive Action Requests (CARs) are initiated and implemented to address EHS nonconformances. Nonconformance is a deviation from a policy, procedure, standard, instruction, specification, legal or regulatory, or from any other requirement, which the company established, or to which it subscribes. c. CARs assign the responsibility for handling and investigating the nonconformance, for mitigating any impacts caused, and for implementing measures to prevent recurrence of the nonconformance. d. CARs may be issued to internal departments of the company as well as to its suppliers and subcontractors. e. Upon implementation of corrective or preventive action, CARs are followed up to verify that the action was indeed implemented and that it is effective. f. CARs are initiated, documented, processed, and monitored. Page 2 of 4

13 September 7, Records (ISO ; OHSAS ) i. AFS Republic maintains EHS records in accordance with Control of Records to demonstrate conformance with legal, regulatory, and other requirements. The Document Control Coordinator, with the assistance of the management team, is responsible for defining which specific records need to be established and maintained and for coordinating related activities. b. Storage locations and retention times for records are specified in, EHS "EHS Records Internal EH&S Audit (ISO ; OHSAS ) i. AFS Republic periodically conducts internal audits of the EH&S in accordance with, EHS "EHS Management System Audits. Internal audits shall: determine whether the EHS management system conforms to the stated policy determine whether the EHS management system conforms to the stated standard determine whether the EHS management system has been properly implemented and maintained provide information on the audit results to management. b. All elements and activities of the EHS are audited at least once a year. The actual frequency depends on the status, importance, and past conformance history of the element of activity. c. Internal audits are conducted in accordance with a documented internal audit plan established by the Internal Audit Coordinator. d. Personnel assigned to carry out internal audits shall have freedom from bias or other influences that could affect their objectivity and are appropriately trained and, if possible, are independent from those responsible for the audited activities. The selected auditors shall ensure objectivity and impartiality during the audit process. e. Results from internal audits are reported using a corrective action. The form is used to document identified nonconformances and for initiating and processing related corrective actions. f. Results of internal audits are reported to the Core (C 4 ) Four and are discussed within the framework of management reviews. Page 3 of 4

14 September 7, Management Review (ISO ; OHSAS ) Periodically management reviews of the EHS management system will be conducted in accordance with EHS EHS Management Review. Director of Operations and senior management team conduct annual management review meetings and evaluates EHS results and performance of the EHS management system, and considers changes to policy, objectives, and other elements of the system. The purpose is to ensure the continuing suitability, adequacy, and effectiveness. The review is documented Fatality Prevention (Alcoa ASAT.6) Risk Significance Matrix has been developed to identify fatality risks, rate them and plans are developed to correct them. A fatality team is in place to identify new risks as well. The Alcoa fatality database has been populated with fatality risks that been identified and closed. Page 4 of 4

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