INJURY & ILLNESS RECORDKEEPING POLICY

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1 INJURY & ILLNESS RECORDKEEPING POLICY 1

2 Contents 1 PURPOSE SCOPE RESPONSIBILITIES INJURY AND ILLNESS RECORDING PROCEDURE POSTING REQUIREMENTS RECORD RETENTION REQUIREMENTS

3 1 PURPOSE The purpose of this policy is to define the requirements for recording work-related injuries and illness for Tetra Pak Inc. 2 SCOPE This policy shall cover all Tetra Pak Inc. locations within the United States. Specific guidelines are available at the following website link: 3 RESPONSIBILITIES 3.1 Location OHS Driver Ensure all work-related injuries and illnesses are recorded onto OSHA 300 Logs Ensure all required postings are conducted in accordance with this policy Maintain all records required for this policy Ensure reporting of OHS Incidents, such as Fatality, Permanent disability accident, Lost time accident (LTA), Restricted work (RW) cases, Medical Treatment (MT) cases, and Serious Near miss (SNM) to Corp OHS. Specific Tetra Pak guidelines for reporting are available at the following link: https://teamsite.tetrapak.com/sites/001879/group%20ohs%20procedures/tetr a%20pak%20group%20ohs%20procedures/4.5.3%20incident%20investigatio n,non%20conformity%20and%20corrective%20actions/ %20%20ohs%2 0Incident%20reporting/Reporting%20OHS%20Incidents%20Procedure.pdf 3.2 OHS Officer Determine the proper classification of work-related injuries and illnesses based on OSHA recordkeeping guidelines (29 CFR ) Advise Location OHS Drivers of injuries and illnesses that must be recorded on the OSHA 300 Logs. 3.3 Supervisors and Line Managers Ensure that all actual or suspected work-related injuries and illnesses are promptly reported to the OHS Officer. 3.4 Employees Promptly report actual or suspected work-related injury and illnesses to their supervisor or the OHS Officer. 4 INJURY AND ILLNESS RECORDING PROCEDURE 4.1 Tetra Pak Inc. locations are required to keep records of fatalities, injuries, and illnesses it must record each fatality, injury and illness that: Is work-related; and Is a new case; and 3

4 4.1.3 Meets one or more of the general recording criteria 4.2 Tetra Pak Inc. locations must enter each recordable injury or illness on an OSHA 300 Log of Work-Related Injuries and Illnesses ( OSHA 300 Log ) and OSHA 301 Injuries and Illnesses Incident Report ( OSHA 301 Report ), or other equivalent form, within seven (7) calendar days of receiving information that a recordable injury or illness has occurred. 4.3 The OSHA 300 Log for each Tetra Pak Inc. locations Injuries and illnesses shall include work-related injuries and illness that that occur off-site, such as at customer sites or remote office location or during work-related travel. 4.4 A Tetra Pak Inc. executive at each location must certify on the OSHA 300A Summary of work-related Injuries and Illnesses ( OSHA 300A Summary ) that they have examined the OSHA 300 Log and that they reasonably believe, based on their knowledge of the process by which the information was recorded, that the annual summary is correct and complete. 4.5 For work-related injuries or illnesses that involve exposure to potentially infectious materials, the employee s name shall not be recorded on the OSHA 300 Log and shall be maintained on a separate Privacy Case Log. For these instances, the employee shall be identified as Privacy Case on the OSHA 300 Log. 5 POSTING REQUIREMENTS 5.1 Tetra Pak Inc. locations must post a copy of the OSHA 300A Summary in a conspicuous location or locations where notices to employees are customarily posted. The posted OSHA 300A Summary must not be altered, defaced, or covered by any other material. 5.2 The OSHA 300A Summary must be posted no later than February 1 st of the year following the year covered by the records and the posting shall be kept in place until April 30 th. 6 RECORD RETENTION REQUIREMENTS 6.1 Tetra Pak Inc. locations must maintain the OSHA 300 Log, the Privacy Case Log (if one exists), the OSHA 300A Summary, and OSHA 301 Report for five (5) years following the end of the calendar year that these records cover. 6.2 The Privacy Case Log (if one exists) and any other injury and illness records that contain personal information that is protected by the Health Insurance Portability and Accountability Act (HIPAA) shall be maintained in a secure location in accordance with Tetra Pak Inc. s recordkeeping policies. 4

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