SNAP-ON INCORPORATED ENVIRONMENTAL, HEALTH & SAFETY SYSTEM MANUAL OF PRACTICE

Transcription

1 ENVIRONMENTAL, HEALTH & SAFETY SYSTEM MANUAL OF PRACTICE Approval: Date: 03/21/06 EHSSystem.doc

2 TABLE OF CONTENTS Section Page No. Snap-on Incorporated Safety Philosophy...For display purposes Environmental, Health and Safety Policy...For display purposes 0.0 Introduction and overview of the Manual of Practice Scope Standard and documents incorporated by reference Definitions Environmental, health and safety management system General requirements Policy Statement Planning EH&S aspects and impacts Legal and other requirements Objectives, targets and program(s) Implementation and operation Resources, roles, responsibility and authority Competence, training and awareness Communication Documentation Control of documents Operational control Emergency preparedness and response Checking Monitoring and measurement Evaluation of legal compliance Non-conformity and preventive and corrective action Control of records Internal audit Management review...21 Rev. 09/01/05

3 Safety Philosophy THE SNAP-ON INCORPORATED SAFETY PHILOSOPHY is based on the belief that each associate must: Work safely as a condition of hire and continued employment, Accept personal responsibility for every associate s safety, Successfully complete mandatory safety training, Be certain all unsafe acts and conditions are eliminated or safeguarded, and Believe that work related injuries are preventable and therefore unacceptable. Management is responsible for ensuring that all associates work in a safe company. Rev. 09/01/05

4 ENVIRONMENTAL, HEALTH & SAFETY POLICY We are committed to the goal of providing a safe and healthy workplace. We strive to protect environmental quality and public welfare in our communities and to implement environmentally sound policies designed to prevent, mitigate and, where appropriate, remedy impacts on the environment of the community. We believe in the importance of safeguarding natural resources and that environmental goals can and should be consistent with economic health. We will: 1. Vigorously support the Snap-on Incorporated Safety Philosophy; 2. Manage all operations to meet or exceed applicable requirements with regard to environment, safety, and health; 3. Design, operate and monitor our facilities, to the extent reasonably feasible and cost effective, in a manner consistent with the protection of the environment and the health and safety of our associates and neighbors; 4. Conserve energy and natural resources through prudent use and reuse; Strive to eliminate or minimize waste and pollution at its source; Properly dispose of or effectively treat any waste not economically recycled; 5. Make health, safety and the environment a priority in developing new products and processes; 6. Recognize, anticipate and communicate significant environmental aspects/impacts to associates, emergency response and regulatory authorities and the public regarding our products and operations; 7. Periodically audit our performance against stated goals and the principles of our EH&S Management System in order to ensure its proper implementation and maintenance; 8. Hold all associates accountable for compliance with this Policy and implementing procedures within their areas of responsibility. Jack Michaels Chairman, President & CEO Rev. 09/01/05

5 0.0 Introduction and overview of the Manual of Practice Snap-on Incorporated, based in Kenosha, Wisconsin, is a global company and leading developer, manufacturer and distributor of hand and power tools, diagnostic and shop equipment and tool storage products. Our customers are professional automotive technicians, shop owners and industrial tool users worldwide. Snap-on has three distinct customer-focused business segments to align with the various needs of the markets it serves around the globe. Those segments are Snap-on Transportation, Snap-on Diagnostics and Snap-on Commercial and Industrial. The Corporation has developed this management system for environmental stewardship and associate safety and health with two things in mind; continuous improvement and compliance with all laws and internal standards. 1.0 Scope The purpose of the Environmental, Health and Safety Management System (EH&SMS) is: a) To specify a commitment of Snap-on worldwide to continual improvement and meeting or exceeding our stakeholders expectations with regard to environmental, health and safety concerns. b) To use ISO and OHSAS as a framework, and our internal systems as tools in meeting regulatory requirements and stakeholder expectations. All Snap-on entities worldwide shall adhere to the system requirements as appropriate. c) To communicate the aspects of our EH&SMS to customers, partners and stakeholders worldwide. 2.0 Standards and documents incorporated by reference a) ISO Environmental Management Systems Specification b) ISO Environmental Management System Guidance Document c) ISO Guidelines for Quality and/or Environmental Management Systems Auditing d) ISO Goals and Principles of All Environmental Labeling e) ISO Terms and Definitions for Self-Declarations of Environmental Claims f) ISO Evaluation of the Environmental Performance of the Management System g) OHSAS Occupational Health and Safety Management Systems Specification h) OHSAS Occupational Health and Safety Management Systems Guidance for the Implementation of OHSAS18001 i) SEQ 64-series Standards EHSSystem.doc Page 1 of 23 Rev. 03/21/06

6 3.0 Definitions EH&SMS Snap-on s established Corporate Environmental, Health and Safety Management System. SEQ Safety, Environment and Quality Group. Business Segment The three primary entities within Snap-on Incorporated. They include Transportation, Commercial and Industrial, and Diagnostics. Business Unit Distinct groups within the business segments. Operating Unit A facility or group of facilities within a business unit. Tier I Highest level of EH&S management system documentation, establishes corporate conformance with the international ISO standard. Prepared by SEQ. Tier II Next level of EH&S management system documentation, includes standards that establish specific facility level requirements, as well as other documentation that provide information for the facilities use. Also includes internal auditing procedures. Prepared by SEQ. Tier III Documentation written by the operating unit or facility specific to their operations. 4.0 Environmental, health and safety management system requirements 4.1 General requirements Snap-on Incorporated has established and maintains an environmental, health and safety management system that is based upon regulatory compliance and continual improvement. The core elements are described in the remainder of Section 4.0 of this document. 4.2 Policy statement Snap-on Incorporated commits itself to as its number one objective. Snap-on s Quality Policy is located in this document immediately following the table of contents. 4.3 Planning EH&S aspects and impacts The inherent hazards associated with a process are mitigated through established operational controls (SEQ Standards). By following these controls the Business Unit reduces the incident rating, and therefore minimizes the overall risk. Listed below are the relative hazard ratings. The incident rating is determined considering existing operational controls and company experience. High (H): The activity has substantial potential (Relative Hazard) for adverse impacts or consequences and/or a high probability of occurrence (Incident). Moderate (M): The activity has moderate potential (Relative Hazard) for adverse impacts or consequences and/or a moderate probability of occurrence (Incident). EHSSystem.doc Page 2 of 23 Rev. 03/21/06

7 Low (L): The activity has negligible potential (Relative Hazard) for having adverse impacts or consequences on the environment or safety and health and/or low probability of occurrence (Incident). Activities with a low hazard rating are not listed. Examples of these activities include: most clerical tasks, housekeeping tasks, order picking in DC s, etc. Taking into account the relative hazard and incident ratings, and the company s activities, products and services, the following tables list the processes that are covered by the EH&S management system. It is the responsibility of each facility and/or business unit to determine and document which of the following EH&S aspects and impacts apply to their location(s). EH&S aspects Protection of associate safety & health Control and enhancement of atmospheric air Protection of surface and ground water supplies Management of solid and hazardous wastes Hazardous materials transportation Environmental releases and response to releases Miscellaneous control of hazardous substances Pollution prevention Environmental impacts Global warming Ozone depletion Acid rain Toxic releases Ambient air quality Ground water contamination Surface water contamination POTW impacts Ground water contamination Surface water contamination Drinking water contamination Environmental releases to the land, air and water Contamination of land, air and water Ecological damage Contamination of land, air and water Ecological damage Reducing ecological and environmental impacts Summary of EH&S Aspects/Impacts Health & safety impacts (hazards/risks) Employee exposure Physical hazards Ergonomics Operational controls (SEQ standards) 64.01, 64.02, 64.51, 64.52, 64.54, 65.56, Community exposures 64.04, 64.21, Impaired drinking water supplies Direct exposures Drinking water contamination Community exposure Personnel exposure Exposure to medical and emergency response 64.02, 64.04, 64.21, , 64.04, 64.21, 64.31, 64.51, , 64.51, Personal exposures 64.02, 64.51, Personal exposure to PCBs, asbestos, etc. Reduced personal exposures 64.02, 64.31, 64.51, , Monitoring/ measurement required IH monitoring Instrument calibration Ergonomic evaluation Employee exams (where applicable) Chromium Emission Standard Air permit monitoring and recordkeeping Wastewater effluent Storm water monitoring Pollution control Hazard waste analysis Waste profiles TSD audits Remediation monitoring TCLP analysis Waste profiles Waste Minimization Plan or activities EHSSystem.doc Page 3 of 23 Rev. 03/21/06

8 The processes of concern in the categories below have been determined to have EH&S impacts and are regulated through national, state and/or local authorities. Category: Key management issues: Protection of associate health and safety Exposure to toxic chemicals and other workplace stressors For Individual Facility Use Applies ( ) Significance Decision Criteria Relative Hazard Incident Processes of concern Electroplating lines H L Vibratory mass finishing M L Polishing/grinding M M Machining/coolants M M Electrocoating and painting H L Chemical storage M L Conversion Coating M L Process laboratories M L Spill response M L Forging & forming M L Powder coating M L Welding & cutting H M Plastic injection molding M M Materials handling and distribution M L Powered industrial trucks H L Soldering M L Laser etching M L Category: Key management issues: Control and enhancement of atmospheric air Control of all emissions that are perceived to be injurious to public health and the environment Significance Decision Criteria For Individual Facility Use Applies ( ) Relative Hazard Incident Processes of concern Electroplating lines H L Heat treating M L Conversion coating H L Polishing/grinding M L Electrocoating and painting H L Powder Coating M L Storage, handling and use of chemicals H L EHSSystem.doc Page 4 of 23 Rev. 03/21/06

9 Category: Key management issues: Protection of surface and ground water supplies Control of all sources of pollution that may reach the national waterways or ground water supplies, including storm water runoff Significance Decision Criteria For Individual Facility Use Applies ( ) Relative Hazard Incident Processes of concern Electroplating lines H L Vibratory mass finishing H L Conversion coating H L Electrocoating and painting H L Waste oil and coolants H L Wet grinding M L Materials handling and storage H L Stormwater management M L Category: Key management issues: Management of solid and hazardous waste Waste minimization and the proper management, treatment, shipment and storage of hazardous and non-hazardous waste, including emergency response Significance Decision Criteria For Individual Facility Use Applies ( ) Relative Hazard Incident Processes of concern Electroplating waste H L Vibratory mass finishing waste M L Electrocoating/painting waste M L Grinding and polishing dust M L Waste oil and coolants M L Waste powder paint and other paint related waste M L Wastewater treatment residues H L Recycling of packaging, waste oil, metals and other waste M L Category: Key management issues: Processes of concern All off-site shipments of waste products and chemical shipments from and between manufacturing plants and distribution centers to the dealer network Hazardous materials transportation Shipments of all materials deemed hazardous by their chemical or physical properties Significance Decision Criteria For Individual Facility Use Applies ( ) Relative Hazard H Incident L EHSSystem.doc Page 5 of 23 Rev. 03/21/06

10 Category: Key management issues: Environmental releases and response to releases Liability associated with off-site disposal and treatment and community right-to-know laws concerning activities involving hazardous materials Successor liability associated with the acquisition of contaminated properties Significance Decision Criteria For Individual Facility Use Applies ( ) Relative Hazard Incident Processes of concern Plating chemicals H L Wastewater sludges M M Conversion coating chemicals H L Electrocoating/painting chemicals H L TSD activities H L Waste recycling H L Acquisition of real estate and assets of potentially liable parties H M Category: Key management issues: Miscellaneous control of hazardous substances Miscellaneous control of chemicals not controlled elsewhere For Individual Facility Use Applies ( ) Significance Decision Criteria Relative Hazard Incident Processes of concern Asbestos containing materials, i.e., seals for heat treating furnaces M L PCB's, i.e., machine capacitors and lighting ballast H L Heavy metals in light bulbs M L Management of rechargeable batteries M L Ozone depleting chemicals as defined under the Montreal Protocol Global warming gases as defined by the Kyoto Protocol M M L L Category: Key management issues: Pollution prevention Source reduction, recycling, treatment and disposal Significance Decision Criteria Processes of concern For Individual Facility Use Applies ( ) Relative Hazard Incident All processes that generate waste M L All energy expending processes, conservation efforts and the use of M L natural resources (water) and materials Determined per discussion in Section Non-significant aspects / impacts also addressed in this section. As changes to facilities, processes and materials occur, the Corporate SEQ Group with the Business Unit SEQ Coordinators as a resource will review these events to determine the environmental, health and safety significance. EHSSystem.doc Page 6 of 23 Rev. 03/21/06

11 4.3.2 Legal and other requirements The Snap-on Environmental, Health and Safety Management System shall comply with ISO and OHSAS and meet the legal requirements as established by the operating units national and state regulations. Each operating unit will be required to maintain either in hard copy or electronic format access to their appropriate legal requirements. In some cases, this information is available through links in the SEQ Group website. Additional requirements of the EH&S management system are established by the SEQ standards, accessible through the SEQ Group website Objectives, targets and program(s) The goals of the EH&SMS shall address the identified EH&S aspects and impacts and be consistent with the EH&S Policy Statement set forth in Section 4.2 of this document. Objectives and targets shall be determined by the Business Unit and their individual facilities in support of these goals and continual improvement. Objectives and targets shall be documented, including the designation of responsibility and the means and time frame by which they are to be achieved. At a minimum these documented objectives and targets shall include the reduction/elimination of workplace injuries and pollution prevention/waste minimization. Targets should be set at levels that are achievable and will provide meaningful improvements. Objectives shall be reviewed and updated as needed. Targets shall be established at least annually. Progress toward established targets shall be reviewed at appropriate intervals. 1. Workplace injuries shall be reported through the established injury and illness recordkeeping process. Injury and illness statistics will be communicated to the business units as needed. 2. EH&S costs and pollution prevention/waste minimization efforts and progress shall be maintained and monitored by each individual facility and/or business unit. 4.4 Implementation and operation Resources, roles, responsibility and authority Though defined roles exist within the EH&S management system, associates at every level must be made aware of the EH&S Policy and how it relates to the scope, responsibility, and authority of their function. Senior management holds business unit management accountable for the EH&S performance of the business unit. In turn, business unit management holds facility management accountable for the facility s EH&S performance. The resources employed to implement and maintain the EH&S management system include personnel to function in the roles outlined in this section. Also see the SEQ organizational table on the SEQ website. Roles and responsibilities within the EH&S management system must be documented. EHSSystem.doc Page 7 of 23 Rev. 03/21/06

12 Specific signatory responsibilities related to the ongoing activities in the EH&S management system are as follows: Facility Manager Environmental discharge permit applications for air, water and solid/hazardous waste; Annual environmental reporting and certifications (i.e. hazardous waste generator reports; air emission inventory reports; Toxic Release Inventory; emergency response planning submittals); Environmental noncompliance reports and environmental release notifications; Health and safety noncompliance agreements or program certifications. Director, Safety, Environment and Quality Group - All instruments, inquiries and certifications with corporate wide impact. Other documents, presentations and representation required on behalf of a facility with various authorities with local control and jurisdiction. Environmental Coordinators - Internal document authority only. Industrial Hygiene Coordinators - Internal document authority only. Safety, Environment and Quality Staff - Internal document authority only Corporate SEQ Group The designated management representative responsible for the quality management system is the Director of Safety, Environment and Quality (SEQ). The Director of SEQ reports to senior management on overall EH&S system matters and provides senior management with recommendations for improvements to the EH&SMS.. The Corporate SEQ Group shall function as a central coordination and oversight point for the Business Unit SEQ Coordinators and as their link to senior management. The Corporate SEQ Group will contract with and manage the relationship with the certification registrar. Duties of the SEQ Group: a) Serve as the consultant, educator, coordinator, planner and monitor of the legal and general administrative aspects of the Corporation s EH&S program. b) Assist in the development of the Business Unit SEQ Coordinator competencies. c) Require and oversee annual internal audits of certified facilities for purposes of ISO 14001, OHSAS and ISO 9001 certification. d) Require and oversee internal audits of non-certified facilities for purposes of compliance with SEQ management systems. e) Coordinate external certification audits and communicate results to the Business Unit SEQ Coordinators and others as appropriate. f) Develop and issue the Corporate EH&S management system policies and associated Tier II SEQ Standards. g) Review information generated by business units. Analyze and promote root cause activities where EH&S objectives are not being met. h) Maintain the EH&S system documentation on the Snap-on SEQ website so that worldwide business units will have immediate access to the system. EHSSystem.doc Page 8 of 23 Rev. 03/21/06

13 i) Support worldwide business units as they develop Tier III documentation. j) Provide to senior management periodic reports that document the Corporation's performance toward our stated goals. k) Provide annual updates to senior management and others as needed. (See Section 4.6 of this document) Managerial Budgets Performance tracking Acquisition Due diligence Special projects Product certifications Public relations with control authorities and trade groups Risk assessments and risk management in the EH&S area of Snap-on s business Engineering Design of systems: Wastewater Air pollution Solids handling Materials handlings Chemical handling and processing Ventilation systems Recovery systems Energy conservation and efficiencies Compliance Assurance Codifications of statutes Serve as Corporate expert on regulatory issues Maintain EH&SMS and implementation at the operating unit level Administrative tasks Coordination/ negotiating of: Permits Plans Reports Required recordkeeping Industrial Hygiene Monitoring Recognition and evaluation of stressors Recommend solutions Design of solutions Implementing of control measures for: Workplace exposures of toxic chemicals Indoor Air quality Heat stress Ergonomics Radiation Safety Chemistry Planning Machine guarding Safety procedures Safe processes Safe facility design Fire safety (Life Safety Code) NFPA National Electric Code requirements Monitoring of workplace exposures to safety hazards Analytical Compliance and environmental reporting of releases Chemical process safety programs Chemical process development Chemistry substitutions Authority on MSDS criteria and acceptability Long range plans for continued compliance for all corporate entities Tracking and benchmarking of performance EH&S, including cost Training and personal development Noise Lighting Business Unit SEQ Coordinator The duties of the Business Unit SEQ Coordinators include: a) Being the primary liaison between the Corporate SEQ Group and the business unit facilities on EH&S issues. They will be the primary contact for their business unit s facilities and contribute to the management review process outlined in Section 4.6 of this document. b) Coordinating and/or performing required internal system audits at all facilities within the business unit. The Business Unit SEQ Coordinator is responsible for ensuring that the internal audits are conducted by a person or team independent of the function being audited. EHSSystem.doc Page 9 of 23 Rev. 03/21/06

14 i. Summarize and communicate internal audit findings on a timely basis to the Corporate SEQ Group. ii. Follow-up on and review objective evidence of the correction of the findings. iii. Create and maintain all required business unit level SEQ system documentation (internal audit records, related corrective actions, etc.). c) Send formal corrective action requests for external audit findings related to audited facilities. i. Follow-up on and review objective evidence of the correction of these findings. ii. Communicate corrective actions and objective evidence back to the Corporate SEQ Group for closure of external audit findings. iii. Communicate external audit findings to all business unit facilities to avoid similar audit findings in the future. iv. Create and maintain all required business unit level required SEQ system documentation (internal audit records, related corrective actions, etc.). d) Other business unit management system requirements (must meet external auditor/iso standard requirements): i. Determine and track business unit metrics. ii. Set goals and associated action plans to meet EH&S objectives. iii. Possess a working knowledge of the EH&S management system and applicable EH&S regulations in order to ensure that their facilities remain in compliance with all federal, state and local regulatory requirements. iv. Ensure that industrial hygiene assessments are conducted within their facilities as follows: a) Annually for facilities with significant potential chemical and/or physical workplace exposures b) Biennially for all other facilities. v. Other duties related to implementing and maintaining the EH&S management system Facility personnel specific duties a) The Facility Manager has overall responsibility to manage their facility consistent with the requirements of the Environmental, Health and Safety Management System. Snap-on senior management has authorized resources in the form of the Environmental Coordinators and Health and Safety Coordinators as support in meeting responsibilities as set forth in the EH&S Management System. b) Duties of the Facility Environmental and Health & Safety Coordinators: i. Manage all aspects of the facility s EH&S programs. EHSSystem.doc Page 10 of 23 Rev. 03/21/06

15 ii. Assist facility management in meeting their responsibility for assuring that the facility complies with all EH&S management system and regulatory requirements. iii. Possess a working knowledge of the EH&S management system, the facility environmental health and safety policies and procedures, and applicable federal, state and local regulatory requirements. iv. Receive annual training required to establish and maintain competence and proficiency as appropriate for fulfilling their duties. v. Provide specialized environmental health and safety training to line personnel and facility management as required by the system Competence, training and awareness The SEQ Group shall identify the appropriate training levels required to meet the objectives and goals of the corporate Environmental, Health and Safety program. While specific training requirements for facility associates are set forth in Standard SEQ64.02 the following general requirements apply. All facility training shall be scheduled and training records maintained by the facility. Additionally, the following training schedule applies to Snap-on personnel with responsibility for management of the EH&S Management System: Position Facility Health and Safety Coordinators Facility Environmental Coordinators Business Unit SEQ Coordinators Corporate SEQ Group Members Minimum Acceptable Number Training Hours Annually Training plans Each Health & Safety and Environmental Coordinator shall prepare a facility training schedule to be executed the following calendar year. The Facility Manager will provide the necessary personnel time and financial resources to accomplish a training plan consistent with environmental health and safety demands and conditions that may exist at the facility. Each Business Unit SEQ Coordinator shall be responsible for ensuring that their facilities are performing their required training according to their established schedule. Personnel of the Safety, Environment and Quality Group may provide training, primarily to the Business Unit SEQ Coordinators, on regulatory issues including evolving technology, administrative program efficiencies, regulatory trends and theory, waste minimization, compliance know-how and the like. The overall goal of the training program is to support continual improvement of the Environmental, Health and Safety Program and create an awareness of the following for all affected associates. EHSSystem.doc Page 11 of 23 Rev. 03/21/06

16 a) The importance of conformance with the EH&S policy and procedures and with the requirements of the environmental management system. Their roles and responsibilities in achieving conformance with the EH&S policy and procedures and with the requirements of the management system. b) The significant EH&S impacts, actual and potential, of their work activities and the benefits of improved personal performance. Annual awareness training for all associates shall include the impacts and consequences an individual s actions may have on the environment and employee health and safety when establish policies and procedures are not followed. c) Outside contractors/suppliers shall be informed of relevant procedures and requirements impacting environmental protection and employee health and safety through an appropriate documented contractor/supplier safety declaration This may include any applicable required training. (See SEQ64.51) Communication Each operating unit has a responsibility to keep the lines of communication open with regard to the regulatory compliance status of the Corporation. Therefore, the following notification requirements are set forth: Each regulated facility shall promptly notify their Business Unit SEQ Coordinator and the Corporate SEQ Group of notices of violation, proposed noncompliance reports (e.g., exceeding wastewater discharge limits), external inquiries, adverse publicity, impending enforcement actions, superfund claims, other environmental claims or complaints that may have significant legal or public relations consequences, releases of pollutants that may be reportable to the government (e.g., above CERCLA RQ's), and regulatory agency inspections and/or requests. They shall also submit monthly accident experience results by the 15 th of the following month and the inventory of conservation effort report. The Safety, Environment and Quality Group will communicate to the various Business Unit Coordinators concerning their requirements with regard to government regulatory issues, information on emerging technology, and ways to improve performance and evaluations of their operating performance against stated corporate EH&S goals. The group will do this through: a) Annual accident and illness results. b) Wastewater discharge reports. c) Assessment of environmental and industrial hygiene assessment results (at least biennially). d) Periodic advisory reports and other special assessments on EH&S issues as warranted by policy changes. e) Training of the Business Unit SEQ Coordinators. f) Modifications to the Manual of Practice General communications with regard to building associate awareness of Snap-on's commitment and performance in the EH&S Management Program is accomplished through the internal associate communication programs such as newsletters and through the SEQ website. Associates may communicate to management on these issues through the appropriate local mechanism or the Corporate or business unit SEQ personnel. EHSSystem.doc Page 12 of 23 Rev. 03/21/06

17 Additionally, associates should be involved in the development of health and safety programs at the operational level. (Ref. SEQ64.01 and SEQ64.51) Responsibilities for receiving, documenting and responding to request and inquiries from external interested parties regarding EH&S impacts and the EH&S management system lies with the Director, Safety, Environment and Quality Group. A log of communications with interested external parties will be maintained by the SEQ Group. In North America, facilities must consult the SEQ Group to determine whether the facility or the SEQ Group will respond to the external party s inquiry Documentation The primary purpose for the maintenance of Environmental, Health and Safety documents and records is to document Snap-on's compliance with relevant regulations and/or laws and for tracking overall program performance. Recordkeeping requirements and document maintenance will apply to each operating facility. The documentation program will also aid in determining the scope, nature and objectives of the overall corporate policy and assist management personnel in meeting obligations under this EH&S Management System. This section is to provide guidance and direction to meet the general needs of those individuals who are involved in EH&S management within the Corporation with regard to recordkeeping and documentation. The Director, Safety, Environment and Quality Group will be responsible for oversight and administration of this program. Documentation under the EH&S Management System refers to both documents and records as defined herein. A document is a policy, instruction or plan containing rules and information on how the Environmental, Health and Safety System functions, how activities and tasks are to be carried out and how to evaluate and assess performance. A record, on the other hand, is a written statement of facts pertaining to a specific event, person, process or outcome at a given time. A document will change over time, but not a record. Environmental, Health and Safety Program documentation may include, but is not limited to, all of the following records and documents. EHSSystem.doc Page 13 of 23 Rev. 03/21/06

18 N.R. - NOT REQUIRED * DISCARD WHEN SUPERSEDED Record Document Review Period Retention Period EH&S Manual of Practice X Annual Permanent* Facility audits X N.R. 5 Years Remedial action plans X N.R. 10 Years Preacquisition audits X N.R. Permanent Misc. government correspondence X N.R. 5 Years Environmental site investigation reports X N.R. Permanent Five Quarters Reports X N.R. 5 Years Accident Investigation/prevention Results X N.R. 5 Years Industrial Hygiene Assessments X N.R. Permanent Ergonomic Assessments X N.R. 5 Years Wastewater Discharge Results X N.R. 5 Years Waste Manifest X N.R. Permanent Operating Permits (Air, Water, Waste) X N.R. 10 Years* Self-Monitoring Reports X N.R. 5 Years Air Emissions Inventory X N.R. 5 Years Toxic Release Inventory X Annual 5 Years Hazardous Materials (Tier II) Inventory and Supporting Records X Annual 5 Years OSH Logs X Monthly 5 Years OSH Supplemental Records X Monthly 5 Years Hazardous Waste Disposal Contracts X N.R. Permanent Enforcement Action Records X N.R. Permanent Regulations - State, Federal, Local X N.R. Permanent* Operating Permit Applications X N.R. 10 Years Air Emission Sampling Reports X 5 Years 10 Years Wastewater Operator Certificates X 5 Years* Material Safety Data Sheets X Annual Permanent TSD Audits X Biennial 5 Years Written Operational Compliance Plans X Biennial Permanent* Maintenance Performance (SEQ64.21) X Biennial 5 Years Laboratory Quality Assurance (SEQ64.41) X Biennial 5 Years EHSSystem.doc Page 14 of 23 Rev. 03/21/06

19 N.R. - NOT REQUIRED * DISCARD WHEN SUPERSEDED Record Document Review Period Retention Period Training Records (SEQ64.02) X Biennial 5 Years Worksite Assessments Inspections Accident Investigations X N.R. 5 Years Plant Daily Operating Logs (SEQ64.21) X N.R. 5 Years Monthly Performance Reports (SEQ64.31) X N.R. 5 Years Waste Minimization Worksheets (SEQ64.31) X N.R 5 Years PPE Assessments X Annual 5 Years Inventory of Conservation Efforts X Annual 5 Years Log for External Communication X Annual 3 Years Senior Management Review Acceptance Form X Annual 3 Years EH&S program structure Snap-on Corporate personnel have prepared the EH&S Manual of Practice that establishes policy in all environmental and health and safety areas. The first part of this manual defines the scope of Snap-on s operations, details environmental and safety aspects and impacts, and generally addresses all elements of ISO14001 and OHSAS This portion of the manual is the highest level document in the EH&S management system and is analogous to a quality manual in an ISO9000 management system. Since it applies to all locations within Snap-on Incorporated, business units and facilities do not have to prepare this level of documentation. The next level of documentation is the SEQ standards. These standards detail the regulatory and other internal Snap-on requirements for environmental and health and safety practices. All Snap-on Incorporated locations must comply with the standards that apply to them. Each operating facility is then responsible for implementing applicable SEQ requirements. Written programs are prepared to document these requirements at the facility level.. (See table in Section ) Records are maintained as previously specified Control of documents Purpose It is the purpose of this section to establish Snap-on Incorporated's policy with regard to the creation, use and control of environmental, health and safety documentation as identified in Section of this manual. Documentation identified in Section is important to the overall EH&S Management System performance because it: EHSSystem.doc Page 15 of 23 Rev. 03/21/06

20 a) Serves as reference in making control equipment acquisition decisions. b) Documents system performance. c) Verifies that the Corporation is meeting its ethical and legal obligations with regard to protection of associate health, public health and the environment. d) Establishes a means to achieving the Corporate EH&S policy Document preparation Documents/records, including a Master List of Documents, must be prepared by appropriate business unit or facility personnel. The SEQ Group and Business Unit Coordinator shall serve as a resource to the operating units Review, approval and control of documentation Documents and records must be reviewed and approved by appropriate business unit or facility personnel as needed to ensure continued suitability, including compliance with legal and regulatory requirements and any other internal requirements. Moreover, this review must take place at least biennially and must be documented. Obsolete documentation must be removed from use Documents and records of the Safety, Environment and Quality Group The Director, Safety, Environment and Quality Group has the Issue and Approval Authority for the Environmental, Health and Safety Management System Manual of Practice Operational control The SEQ Group has performed an assessment and has identified all processes and activities that need to be evaluated and controlled within the framework of this management system (Section 4.3). The Corporation has gained operational control through the issuance, execution and strict adherence to SEQ Standards which are a significant part of the management scheme. Additionally, each operating unit exercises control over its activities by adhering to process work instructions as appropriate. Operational units are audited periodically to document their conformance to the principles of conduct, the SEQ Standards and the stated goals of this management system. Snap-on Incorporated, as part of its pollution prevention program, takes every opportunity to purchase goods and services which environmental friendly. It conveys its policy with regard to these issues to both suppliers and contractors alike. It does not, however, support the philosophy that it should police suppliers and contractors in an effort to impose our value system upon their organization. However, we will not do business with a known polluter or an organization that is insensitive to associate safety and health. Notwithstanding this non-intrusive policy in dealing with our suppliers, Snap-on does have in place a mentoring and community outreach program on EH&S matters (SEQ64.81 & 64.82). Snap-on regards the following as essential components of it s EH&S Program. a) Management commitment and associate participation EHSSystem.doc Page 16 of 23 Rev. 03/21/06

21 i. A clearly stated policy so that all associates understand the priority of environmental, safety and health concerns. ii. Goal and objectives for the program are clearly defined. iii. Visible top management involvement in environmental, safety and health issues. iv. Assignment and communication of responsibility so that all managers, supervisors and associates in all parts of the organization know what performance is expected of them. v. Adequate authority and resources to carry our assigned responsibilities. vi. Accountability for all managers, supervisors and associates in meeting their assigned responsibilities. vii. Review of program operations at least annually to evaluate our success in meeting the goal and objectives of the overall program. b) Worksite analysis i. Identification of all EH&S risks and hazards through comprehensive surveys, analysis of changes to facilities equipment, materials and processes and routine hazard analysis. ii. Regular environmental, safety and health site inspections. iii. Reliable channels for associates to report nonconforming conditions. iv. Investigation of accidents, including JHA on all loss time accidents, and nonconforming conditions. v. Analysis of the patterns of injuries and illnesses and nonconforming environmental conditions. vi. Snap-on has clearly identified implementation measures in SEQ64.01, SEQ64.02, SEQ64.51, SEQ64.54, SEQ64.56 and SEQ64.71 to establish controls on occupational health & safety risk at their source. c) Hazard prevention and control of environmental nonconforming conditions i. Use of engineering controls, work practices, personal protective equipment and administrative controls. ii. Preventive maintenance. iii. Planning and preparation for emergencies. d) Environmental, safety and health training i. Ensuring that all associates understand hazards and how to prevent harm to the environment, to themselves and to others. ii. Ensuring that supervisors understand their environmental, safety and health responsibilities to identify previously unrecognized hazards, maintain physical protections and reinforce associate training through feedback on performance and enforcement when necessary. EHSSystem.doc Page 17 of 23 Rev. 03/21/06

22 iii. Ensuring that managers understand their environmental, safety and health responsibilities. iv. Ensuring that personnel have the appropriate competence level to prevent environmentally damaging conditions Emergency preparedness and response Where appropriate, in handling of environmental damaging materials, each operating facility must have a site emergency response plan as prescribed in SEQ64.51 Chemical Hygiene and Safety Plan. The plan must include at least the following elements and any other elements that may be deemed appropriate by Environmental Coordinator or Industrial Hygiene Coordinator. a) A list of emergency numbers for team members, fire departments, medical and rescue services and police. b) Site evacuation routes and procedures, both primary and secondary. c) Location, type and availability of both site and community emergency response equipment. d) A plot plan designating hazardous materials locations and operations. e) Material safety data sheets on all hazardous materials at or near the location. f) Plan coordination, minutes, recommendations and contacts of site and community officials and emergency responders. g) Training records, including responsibilities and training of site personnel and responders. h) Testing dates and procedures, including site exercise results and recommendations. Periodic testing specifically means biennially for the purpose of this standard. The Emergency Response Plan as part of the Chemical Hygiene and Safety Standard SEQ64.51 must be reviewed at least biennially. 4.5 Checking Monitoring and measurement Snap-on Incorporated has established monitoring and measurement programs that are aimed at preventing, identifying, quantifying, investigating, reporting to senior management, and ultimately abating and or remediating processes, conditions or activities which may have an impact on human health and safety or the environment. These ongoing programs are set forth in the EH&S Management System with appropriate reporting. SEQ Ergonomics Intervention Program - Periodic Ergonomic Assessment Reports. SEQ Environmental Impact Review Quarterly Reporting of "Five Quarters reports on Industrial Discharges." Calibration records for pollution control equipment are maintained at individual operational facilities per facility work practices. EHSSystem.doc Page 18 of 23 Rev. 03/21/06

23 SEQ Pollution Prevention Programs Reporting. (The Inventory of Conservation Efforts and the Environmental Achievement Program.) SEQ Chemical Hygiene and Safety - Annual Industrial Hygiene Surveys by SEQ Group. Corporate industrial hygiene monitoring equipment calibration records will be documented and maintained by the SEQ Group. Primary calibration standards will be calibrated annually through certified external sources traceable to the National Institute of Standards and Technology (NIST). Primary calibration equipment will be used to internally calibrate secondary calibration standards and other equipment. SEQ Standards on Machine Safety. SEQ64.61 & Appendix C - TSD audits by internal resources of the SEQ Group, internal facility EH&S system audit reports to management and third party audits to verify ISO conformance of the EH&S system. Typically a facility is considered substantially in conformance if it meets or exceeds 85% compliance with applicable requirements of the Corporate EH&S Management System. SEQ Annual report to stakeholders on environmental performance fashioned after the USEPA Environmental Leadership Program (ELP) requirement Evaluation of legal compliance The internal audit process and associated guidelines and checklists shall be used for the evaluation of legal compliance Non-conformity and preventive and corrective action Snap-on Incorporated documents nonconformance and needed corrective/preventive actions in several ways including corrective action requests, audit reports, etc. Operating facilities must formally respond to these corrective actions. Adherence to the preventive and corrective action requirements is normally assessed during annual management system audits. To maintain the effectiveness of the corrective and preventive action process, the System audit findings shall be communicated to all facilities for appropriate action, if necessary, and prevention of reoccurrences Control of Records See Section of this document Internal audit The purpose of performing internal EH&S Management System Audits is to verify that operating units are carrying out activities and processes consistent with the EH&S Manual of Practice and are compliant with applicable legal requirements. Conformance with the EH&S Management System is assessed using an audit cycle consisting of an on-site internal audit and a follow-up on corrective actions taken. Dependent upon the results of these activities, and considering the auditor s judgment as to the overall EH&S circumstances at the facility, a conformance and certification decision is made. Facility EH&S Management System internal audits shall be conducted by or under the direction of the Business Unit SEQ Coordinator on an annual basis. EHSSystem.doc Page 19 of 23 Rev. 03/21/06

24 The following table is meant to assist the internal auditor in determining what Standards or portion of a Standard may apply to a particular category of facility. Diagnostics and Information Standard Section Elements Hand tools Misc. metal products Distribution SEQ General requirements Commitment and involvement Workplace analysis Prevention and control General industry standards SEQ General training Hazard communication Hazardous waste Emergency response * Laboratory safety Schedule A SEQ64.04 All Permit review SEQ New sources Existing sources Chromium NESHAPS Pollution control systems SEQ Scope/general Inventory of conservation efforts Stratospheric ozone protection Packaging & labeling Product life cycle Battery (recycling) Climate change SEQ Chemical process safety Chemical hygiene Hazard communication Industrial hygiene assessments Confined spaces Personal protective equipment Emergency evacuation Fire prevention plans SEQ64.54 All Biological exposures SEQ64.56 All Hearing conservation SEQ Hazardous waste management EH&S audits TSD audits Waste oil management SEQ Point of operation Control of hazardous energy Electrical safety work practice Service centers EHSSystem.doc Page 20 of 23 Rev. 03/21/06

25 Standard Section Elements Hand tools Misc. metal products Diagnostics and Information Distribution Service centers SEQ64.81 All Community outreach SEQ64.82 All Mentoring programs = Generally Applies * Does not require spill - = Generally Does Not Apply response drills with 0 = May Apply exception of Olive Branch 4.6 Management review The Director of the SEQ Group shall prepare a status report at least annually that summarizes the performance of business units with regard to the EH&S Management System, identifies areas in need of change or improvement and evaluates compliance. This review will be communicated to senior management and business unit management, as appropriate. Senior management, i.e., the CEO, President of Diagnostics and Information, President of Commercial and Industrial, President of the Snap-on Dealer Group and Vice President - General Counsel will discuss the annual review topics with the Corporate SEQ Group and the Business Unit SEQ Coordinator. The results of this review shall be documented. EHSSystem.doc Page 21 of 23 Rev. 03/21/06