Sentry Equipment Corp.

Sentry Equipment Corp. QUALITY MANAGEMENT SYSTEM MANUAL QA 100.04 Revision 16 January 23,2015 966 Blue Ribbon Circle North Oconomowoc, Wisconsin 53066 Phone: 262-567-7256 Fax: 262-567-4523 References: ISO 9001:2008 For products manufactured in accordance with ASME Boiler and Pressure Vessel Code Section Vlll, Division 1, for Vessels Stamped with "U" Construction Code Designator APPROVALS ISSUED TO: Person: Quality nager Date Èz>f.4t President & CEO l-zs- ls /-zs-d Date Company: Date: Copy is: Uncontrolled ACCEPTED BY A^^r^- '1'lJ-r-,t -- )-2 3 - /5 U\ulhorized ln(pector Date

1.0 Control of the Quality Management System (QMS) Manual (Manual) The Sentry Equipment Corp. (Sentry Equipment / Sentry Equip. / Sentry) Quality Management System (QMS) Manual (Manual) shall document the quality practices used to assure that items manufactured by Sentry Equipment Corp. conform to standards of quality that meet the requirements of the Contract specifications. As applicable, this includes the ASME Code. This Manual provides for and describes the procedures used to assure that: 1. Activities affecting quality are accomplished and documented in accordance with written instructions, procedures and drawings. 2. Activities affecting quality are accomplished under suitably controlled conditions, including the use of appropriate equipment, suitable environmental conditions, and with assurance that prerequisites for the given activity have been satisfied. 3. Special controls, processes, test equipment, tools and skills are employed as appropriate to attain the required quality. 4. The required quality level is verified by inspection and test. 5. Nonconforming materials and items are readily detected and that timely and positive corrective actions are instituted. 6. Qualitative and quantitative acceptance criteria shall be enforced to assure that prescribed activities are satisfactorily completed. MANUAL REVISIONS Revisions to this Manual shall be made for the entire Manual and listed in revision history. All revisions of the Manual shall be approved by the Quality Manager, the President and accepted by Authorized Inspector. The Quality Manager will review this Manual as appropriate and be held responsible for updating and maintaining the Manual prior to the mandatory effective date of the new ASME Code Edition. Upon accepting the new ASME Code Edition, the Summary of Changes page of will be initialed and dated. MANUAL DISTRIBUTION The Quality Manager shall assure that controlled read only copies of the Manual are maintained in electronic format and placed onto the company s Internet and Intranet. The Quality Manager will provide access to the company s Intranet to the Authorized Inspector and Sentry personnel who are responsible for the implementation of this program. The company s Internet address will be provided to organizations that request controlled Copies of the Manual. Individuals that require a hard copy of the Manual will receive an uncontrolled for reference only version of the Manual. The Quality Manager will notify organizations requesting notification of Manual changes by correspondence using the Notification Letter Quality Manual Control (see Exhibit 1 in Appendix). This correspondence shall state that in order to maintain notification status, acknowledgment of the notification must occur within 10 days. Revision 16 page 1 of 394

TABLE OF CONTENTS SECTION START PAGE GENERAL 1.0 Control of the Quality Management System (QMS) 1 Table of Contents 2 Revision History 3 Cross Reference of QMS to ISO 9001:2008 Requirements 4 SCOPE and Responsibility and Authority 2.0 6 QUALITY POLICY 3.0 7 QUALITY MANAGEMENT SYSTEM 4.0 8 General Requirements 8 Documentation Requirements 9 MANAGEMENT RESPONSIBILITY 5.0 11 Management Commitment 11 Customer Focus 12 Quality Policy 12 Planning 12 Responsibility, Authority and Communication 13 Management Review 13 RESOURCE MANAGEMENT 6.0 17 Provision of Resources 17 Overall Awareness of the QMS 17 Competence and Training Responsibility and Records 17 Infrastructure 18 Work Environment 18 PRODUCT REALIZATION 7.0 19 Overview of product Planning Controls 19 Customer-Related Processes 19 Design and Development 20 Purchasing and Materials Control 24 Production and Service Provision General Requirements 25 Identification and Traceability, including Customer Property 26 Examination and Inspection 27 Welding Control 28 Nondestructive Examination (NDE) 29 Calibration of Measurement and Test Equipment 29 Handling, Storage and Shipping 30 Servicing 30 MEASUREMENT, ANALYSIS & IMPROVEMENT 8.0 31 General 31 Revision 16 page 2 of 394

Monitoring and Measurement 31 Control of Nonconforming Product 32 Corrective Action 33 Preventive Action 33 Appendix 9.0 Exhibit 1 Quality Manual Notification Letter 34 Exhibit 2 - QMS Customer Procedure Reference Table 35 1.3 REVISION HISTORY 0. 2/17/95: initial issue. 1. 10/10/97: compare to revision 0. 2. 6/30/98: compare to revision 1. 3. 3/26/01: added Revision History to Table of Contents, updated Section 1A, changes to Sections 1 and 3; titles of employees changed throughout the manual to conform to the Organizational Chart (Section 1A). 4. 3/17/03: updated Section 1A; revised Section 2, revised Section 4, revised Section 12, added Section 15, Training ; added Section 16 Customer Supplied Products and/or Services ; revised and added to Exhibit Forms, Section 17 ( Exhibit Forms was Section 15 in revision 3 of manual). 5. 6/15/06: added CAR requirement at customer s request. 6. 6/15/07: revisions to sections 1.0, 1A, 2.0, 3.0, 4.0, 5.0, 6.0, 10.0, 11.0, 17.0, and table of contents. Eliminated section revisions and replaced with total document revision. Section 5 totally revised to comply with new nonconformance system. Exhibits revised to comply with new nonconformance system. Rename Quality Assurance department to Quality department. 7. 3/9/2009: revise to include requirements of ISO 9001:2000. Where appropriate, combine requirements for ASME Code and ISO 9001:2000. Remove ASME procedures to separate procedures where required. 8. 3/14/2009: revise and include additional references within manual. Replace ISO 9001:2000 with ISO 9001:2008. Clerical corrections where needed. 9. 8/10/2009: revise section 6.1.4 remove training period has elapsed replace with after training and training will be repeated as necessary. Added Authorized Inspector (A.I.) duties sections (7.3.9.1 7.3.9.11). Added reference procedure 22-09208A for ASME design and development. 10. 7/22/2010: Updated organizational chart, corrected table of contents and cross reference table to reflect correct page location within quality manual. Added additional information to ISO cross reference table. Added Customer/QMS reference table to appendix. 11. 1/21/2011: Updated organizational chart. 12. 9/22/2011 Update delegate additions sec 7.8.3 & 7.8.4, update Org. Chart, update Process Flow Diagram (Figure 2.0) 13. 1/11/2012 Editorial updates throughout manual. 14. 1/26/2012 Editorial updates throughout manual. 15. 1/9/15 Under U designation replaced symbol with Construction Code Designator throughout manual, removed UM Symbol reference throughout manual, updated QMS and Manual references throughout, removed gender specific references throughout, updated sec. 1.0 to include Upon accepting the new Revision 16 page 3 of 394

ASME Code Edition, the Summary of Changes page of will be initialed and dated, updated President and CEO, updated Org. Chart, replaced Shop Supervisor with Production Manager throughout manual, updated Business Unit Manager definition in sec. 7.2.1, updated sec. 7.2.5 to VP Power or Process or designee from Customer Service, updated sec. 7.2.6 to remove Administrator, removed second paragraph from sec. 7.3.9.2 because it is already stated in sec. 7.3.9.3, replaced Inside Sales Manager with Applications Engineer in sec. 7.2.6.4 and 7.2.6.5, replaced Manufacturing Services Manager with Materials Manager in sec. 7.4.2.3, removed sec. 7.7.1.1 and 7.7.1.2 because they specifically pertained to UM Vessels, updated sec. 7.7.4.2 and 7.7.4.3 to more clearly state inspections by Assembly and Quality, updated sec. 7.7 to change Quality Inspector to QA Inspector, updated sec. 7.7.2 and 7.8.2 to clarify Engineering titles, replaced Business Unit Manager to VP Power or VP Process throughout manual, added Chief Technology Officer title to section 7.3, minimized the use of or designee throughout the manual. 16. 1/23/15: Added reference to Section 5 in section 4.1.1, updated second sentence in section 4.1.8 so it s grammatically correct, added of this manual to section 5.3.1, updated Org. Chart, replace associate with employee in section 6.3.3, replaced ERP with Materials Requirements Planning (MRP) in section 7.2.6, replaced project lead, or designee with Engineer (Product Engineer, Design Engineer or designee) in section 7.3.4.2, added (7.12 of this Manual) to section 7.3.7.2, added Return Materials Authorization to section 7.6.4.1, added QA to section 7.7.3, replaced supervisor with Weld Supervisor (Weld Team Leader or Work Cell Team Leader) in section 7.8.3, replaced Parts and Service Manager with Director Aftermarket Parts & Service or Product Support Supervisor in section 7.12.3, replaced Servicing personnel with Service Technicians in section 7.12.3.1, replaced quality function with Quality Manager in section 8.4.4. Revision 16 page 4 of 394

1.4 Cross Reference: Sentry Equipment Corp. s Quality Management System Manual and Documented Procedures to Comply with Requirements of ISO 9001:2008 and ASME Boiler and Pressure Vessel Code Section VIII, Division 1 Procedures Reference Table Sentry Equipment Corp. ISO 9001:2008 Cross- Reference Description Manual Section 4 Quality Management system 4.0 4.1 General Requirements 4.1 4.2 Documentation Requirements 4.2 ISO 9001:2008 Procedure Reference ASME Procedure Reference 4.2.1 General 4.2 4.2.2 Quality Manual 4.2 4.2.3 Control of Documents 4.2 18-09209A 22-09206A 4.2.4 Control of Records 4.2 18-09210A 22-09206A 5 Management Responsibilities 5.0 5.1 Management Commitment 5.1 5.2 Customer Focus 5.2 5.3 Quality Policy 5.3 5.4 Planning 5.4 5.4.1 Quality Objectives 5.4 5.4.2 Quality Mgmt. System Planning 5.4 5.5 Responsibility, Authority, and 5.5 Communication 5.5.1 Responsibility and Authority 5.5 5.5.2 Management Representative 5.5 5.5.3 Internal Communication 5.5 5.6 Management Review 5.6 5.6.1 General 5.6 5.6.2 Review Input 5.6 5.6.3 Review Output 5.6 6 Resource Management 6.0 6.1 Provisions of Resources 6.1 6.2 Awareness of QMS 6.2 6.2.1 Employee communication 6.2 6.2.2 Competency, Awareness and Training 6.3 6.3 Infrastructure 6.4 6.4 Work Environment 6.4.1 7 Product Realization 7.0 7.1 Planning of Product Realization 7.1 7.2 Customer-Related Processes 7.2 7.2.1 Determination of Requirements related to the Product 7.2 Revision 16 page 5 of 394

7.2.2 Review of Requirements Related to 7.2 the Product 7.2.3 Customer Communication 7.2 7.3 Design and Development 7.3 18-09007A 22-09208A 7.3.1 Design and Development Overview 7.3 7.3.2 Design and Development Planning 7.3 7.3.3 Design and Development Inputs 7.3 7.3.4 Design and Development Review 7.3 7.3.5 Design and Development Verification 7.3 7.3.6 Design and Development Validation 7.3 7.3.7 Design and Development Changes 7.3 7.3.8 Design and Development Outputs 7.3 7.3.9 Inspection by 3 rd Party 7.3 7.3.10 Release to Manufacture 7.3 7.4 Purchasing and Materials Control 7.4 22-09207A 7.4.1 Purchasing Process 7.4 7.4.2 Purchasing Information 7.4 7.4.3 Verification of Purchased Product 7.4 7.5 Product and Service Provisions 7.5 7.5.1 Control of Production and Service 7.5 Provision 7.5.2 Validation of Processes for Production 7.5 and Service 7.5.3 Identification and Traceablity 7.6 Welding 7.8 22-09201A Heat Treatment 7.4 22-09203A Examination and Inspection Program 7.7 22-09205A 7.5.4 Customer Property 7.6 7.5.5 Preservation of Product 7.6 7.6 Control of Monitoring and Measuring 7.10 22-09204A Devices 7.7 Examination and Inspection 7.9 8 Measurement, Analysis and 8.1 Improvement 8.1 General 8.1 8.2 Monitoring and Measurement 8.2 8.2.1 Customer Satisfaction 8.2 8.2.2 Internal Audit 8.3 18-09208A 8.2.3 Monitoring and Measurement of 8.1 Processes 8.2.4 Monitoring and Measurement of 8.1 Product 8.3 Control and Correction of 8.4 18-09207A 22-09202A Nonconforming Product 8.4 Analysis of Data 8.4 8.5 Improvement 8.5 8.5.1 Continual Improvement 8.5 8.5.2 Corrective Action 8.5 18-09207A 8.5.3 Preventive Action 8.6 18-09207A Revision 16 page 6 of 394

2.0 SCOPE, RESPONSIBILITY and AUTHORITY The management of Sentry Equipment Corp. has implemented and uses a quality management system (OMS) to help the company manage the processes that are used to provide products to our customers. The QMS complies with the international standard ANSI/lSO/ASQ Q9001-2008 and portions of the ASME Code (see (2)). There are two purposes for this Manual: (1) to document Sentry Equipment's quality management system for all employees whose actions affect product and process quality; all customers who want to understand the quality management system and the controls which are used to assure product quality; and all suppliers who provide materials and services for the manufacture of product. Sentry Equipment complies with all requirements of ANSI/lSO/ASQ Q9001-2008, there are no exclusions. (2) to provide documentation for a quality program and system for items subject to the ASME Code, Section Vlll, Division I (hereafter referred to as Code), and stamped with the "U" Construction Code Designator. The content of this Manual provides a single source of information regarding policies at Sentry Equipment for assuring and controlling product and service quality, the continual improvement of the quality management system (OMS) and compliance to requirements defined within ISO Standard 9001:2008. Further, to ensure compliance to the programs needed for compliance to the applicable ASME Code, the President of Sentry Equipment Corp. has authorized the Quality Manager to: 1) ldentify quality problems; 2) lnitiate, recommend and provide solutions; 3) Verify implementation of solutions; and 4) Control further processing or delivery of a nonconforming item, until proper disposition of the deficiency or unsatisfactory condition has occurred. The Quality Manager reports directly to the President and is sufficiently independent from the considerations of cost and scheduling. He has the authority to implement all requirements contained in this Manual and the Code. The Quality Manager is responsible for defining and measuring the overall effectiveness of the Quality Program. ln the event of an interdepartmental conflict involving the Quality Manager, it shall be the responsibility of the President to resolve the matter within the requirements of the Code, Customer Specifications and this Manual. Sections in this Manual describe why Sentry Equipment is undertaking certain activities, describe what objectives will be measured and will reference appropriate procedures. Procedures exists as a separate set of documents to compliment this Manual by providing additional explanation of principles, structure, procedures, and resources that will be used to maintain the quality management system. Brian T. Baker President and CEO Sentry Equipment Corp Date Revision 16 page 7 of 39

3.0 QUALITY POLICY Sentry Equipment Corp. is dedicated to meeting or exceeding customer's requirements by working closely with them to assure that the highest quality product is provided, delivered on time and to their satisfaction. To accomplish these goals Sentry monitors itself with the use of metrics and incorporates improvements to its Quality System by the use of dedicated resources. Sentry Equipment Corp. encourages its employee owner s to strive for continual improvement by sharing new ideas at any time that will improve the product or processes of Sentry. Every Employee an Owner, Every Customer a Commitment This Quality Policy documents Sentry Equipment s commitment to quality and was developed by the top management team. It reflects the purpose of the organization, and defines commitment to meet customer requirements. The Quality Manager will oversee the maintenance of the QMS, and will work with top management to find ways to improve the effectiveness of the quality management system. The Quality Manager will ensure that the suitability, appropriateness, and effectiveness of the quality policy is reviewed as necessary. This policy creates a framework from which quality objectives can be determined and shared with the employees. The policy has been explained to all employees. The policy is also posted in conspicuous locations throughout the company. All employees understand the intent of the policy and know their role in helping Sentry Equipment maintain its commitment to this policy. Revision 16 page 8 of 394

4.0 Quality Management System Sentry Equipment has established, documented, and implemented a quality management system (QMS) that satisfies the requirements of ANSI/ISO/ASQ Q9001-2008 and ASME Code, Section VIII, Division 1, and stamped with the U Construction Code Designator. The QMS will be maintained through review for effectiveness and will be adapted during improvement activities. The Manual section regarding Management Review Meetings provides the details of reviews and how improvement activities are begun. Procedures for Corrective Action and Preventive Action further outline the ways in which continual improvement actions are undertaken and reported to management. 4.1 General Requirements of the QMS 4.1.1 Sentry Equipment has established, documented, and implemented a quality management system (QMS) based on the international standard ANSI/ISO/ASQ Q9001:2008. This QMS is maintained and its effectiveness improved in accordance with the requirements of this international standard. 4.1.2 QMS processes and their interactions are mapped in Section 5, Figure 2.0 of this Manual. 4.1.3 Work instructions and Procedures that are separate from this Manual explain the applications of the processes. 4.1.4 Management has developed techniques and maintains proper monitoring, measurement and analysis of the QMS processes. Reviews of the measurements are held during regularly scheduled management meetings. 4.1.5 Sentry Equipment has developed a corrective and preventive action processes to determine and implement any actions needed to achieve planned results and to provide for a method of continual improvement of QMS processes. 4.1.6 If a process that affects product conformity is outsourced, Sentry Equipment places appropriate controls over that outsourced process. Requirements are identified within Sentry Equipment s QMS and provided to the outsourcing company. Work instructions and records are used. 4.1.7 Procedures, work instructions and work records are used to define the criteria and methods needed to ensure that operation and control of processes are effective and will meet the requirements of the products being produced. 4.1.8 Various employees have been assigned responsibility for operating and monitoring the QMS processes. Specific job functions are described in the responsibility sections of procedures, detailed in job descriptions and/or detailed in work instructions. Revision 16 page 9 of 394

4.2 Documentation Requirements 4.2.1 The QMS documentation includes: 4.2.1.1 a documented quality policy, 4.2.1.2 documented quality objectives, 4.2.1.3 Quality Policies Manual, 4.2.1.4 documented procedures required by the ANSI/ISO/ASQ Q9001-2008 standard, ASME Code and as determined by Sentry Equipment s management, 4.2.1.5 documents needed to ensure effective planning, operation and control of processes (work instructions, specifications, engineering documentation, user s manuals), and 4.2.1.6 Records required by the ANSI/ISO/ASQ Q9001-2008 standard. 4.2.1.7 Records required by the ASME Code. 4.2.2 The Sentry Equipment Quality Manual has been established to define: 4.2.2.1 the scope of the QMS, 4.2.2.2 the basic policies of the Sentry Equipment Corp. with regards to quality and the management of process that affect quality, 4.2.2.3 reference to documented QMS procedures, 4.2.2.4 the description of the interaction between the processes of the Sentry Equipment QMS. 4.2.3 Control of documents 4.2.3.1 Sentry Equipment has established and maintains various types of controlled documents for its QMS. The Control of Documents Procedure defines the controls for: 4.2.4 Control of records 4.2.3.1.1 Approving documents for adequacy prior to issue; 4.2.3.1.2 Reviewing, updating and re-approving documents; 4.2.3.1.3 Ensuring changes and current revision of documents are identified; 4.2.3.1.4 Ensuring relevant versions of documents are available at points of use; 4.2.3.1.5 Ensuring documents remain legible and identifiable; 4.2.3.1.6 Ensuring external origin documents are identified and have their distribution controlled; 4.2.3.1.7 Preventing the unintended use of obsolete documents 4.2.3.1.8 Identifying and segregating of obsolete documents if they are retained for any purpose. 4.2.4.1 Records are established and maintained to provide evidence of process and product conformity. 4.2.4.2 The Control of Quality Management System Records Procedure Revision 16 page 10 of 394

outlines the requirements for identification, storage, protection, retrieval, retention time and disposition. All efforts are made by Sentry Equipment to keep records so they remain legible, readily identifiable and retrievable. Revision 16 page 11 of 394

5.0 MANAGEMENT RESPONSIBILITY The senior management team is ultimately responsible for establishing, implementing and maintaining the quality system. The Sentry Equipment president chooses the management team representatives. Specific responsibilities comprise: defining management s commitment to the QMS, formulating the quality policy, defining organizational authorities and responsibilities, defining communication channels, determining quality objectives and QMS planning, appointing the management representative, periodically reviewing the quality system, and determining the methods used to ensure that customer requirements and customer satisfaction are known. 5.1 Management Commitment 5.1.1 Sentry Equipment s senior management believes that the assurance of quality is fundamental to the work undertaken by all employees. 5.1.2 It is accepted that consistent high quality can only be achieved by working in a systematic way to predefined, formalized procedures and instructions. 5.1.3 The Sentry Equipment senior management, with assistance of the entire management team, will determine and implement the quality management system (QMS) policies and procedures that will be used to control, assure, and manage quality and quality sub-systems at the company. 5.1.4 Individual departmental managers will be responsible to initiate, document, implement and maintain work instructions for their departments. They will ensure that instructions are fully integrated into Sentry Equipment s quality management system. 5.1.5 Senior management will communicate the importance of meeting customer, statutory and regulatory requirements to all Sentry Equipment employees by these actions: 5.1.5.1 Establishing and communicating the Quality Policy; 5.1.5.2 Establishing and communicating quality objectives that help drive business improvements; 5.1.5.3 Reviewing the effectiveness of the QMS at least once per calendar year using a management review process and communicating the results of this review to employees; 5.1.5.4 Using the process of continual improvement as defined in Sentry Equipment procedures to provide assurance to employees and other stakeholders that the QMS is appropriately implemented and is effective for controlling, assuring and managing quality. 5.1.5.5 Identifying the requirements for resources and acquiring those resources as needed. This will include the appropriate assignment of competent and qualified personnel to complete product realization activities or to complete verification activities, such as internal quality audits. Revision 16 page 12 of 394

5.2 Customer Focus 5.2.1 Senior management recognizes that success of the organization depends upon its relationships with its own employees and its external customers. The strategic planning process is designed to determine customer expectations and to help the company develop a balanced approach to responding to expectations. A strategic review takes place annually. 5.2.2 Sentry Equipment s management has developed methods to ensure that external customers requirements are properly determined and communicated during the processes used to make products. Section 7.2 of this Manual provides additional detail. 5.2.3 Sentry Equipment also recognizes the important role that its suppliers play in providing satisfaction to customers. Section 7.4 of this Manual addresses supplier management and the connection to achieving satisfied customers. 5.2.4 Sentry Equipment ensures customer requirements are met and reviewed with the aim to enhance overall customer satisfaction. Section 8.2 provides additional detail regarding the measurement of customer satisfaction and its use to drive quality management system improvements. 5.3 Quality Policy 5.3.1 It is Sentry Equipment s goal to provide our customers with products that meet or exceed their requirements for product quality, delivery (service) and customer satisfaction. See Section 3.0 of this Manual for the company s quality policy. 5.3.2 In support of this policy, Sentry Equipment management is committed to continually improving the effectiveness of our quality management system and to ensure an adequate framework for the establishment and review of the quality objectives as defined under Section 5.4 5.3.3 Sentry Equipment will ensure that this policy is communicated and understood by all levels within the organization by providing training sessions and by conducting internal quality audits. 5.3.4 The quality policy is considered appropriate and consistent with Sentry Equipment s overall business plans. The policy will be reviewed annually at a management review meeting. 5.4 Quality Planning 5.4.1 Sentry Equipment management uses an annual strategic planning process to determine quality performance measures and quality objectives for the company. These measures and objectives are communicated to all employees through the objectives and regular updates of the measures. Updates may be monthly or quarterly, and will be posted for employees. 5.4.2 Quality planning will include these aspects, and additional detail can be found in various work instructions: a) The processes of the quality management system; b) The resources needed to achieve quality objectives; and c) The continual improvement of the quality management system. Revision 16 page 13 of 394

5.4.4 Quality planning also ensures that required changes are conducted in a controlled manner and that the integrity of the quality management system is maintained during the change. 5.4.5 The methods to be used and the personnel responsible for quality planning are further defined in individual job descriptions. 5.5 Responsibility, Authority and Communication 5.5.1 The departmental functions at Sentry Equipment are defined in the organization chart in this section of the Manual. The Process Flow Diagram for the entire company in Figure 2.0 defines the basic flow of work done to meet customer requirements. 5.5.2 The job responsibilities and authorities of employees at Sentry Equipment are explained in job descriptions. Individual managers are tasked with preparing training plans and for assuring that employees understand how their work affects quality and their specific roles within the quality management system. 5.5.3 The Sentry Equipment Quality Manager will serve as the ISO Management Representative for all internal and external inquiries. In addition to other job responsibilities, the Quality Manager is responsible for: 5.5.3.1 Ensuring that the requirements of this Quality System Manual and those of ISO 9001:2008 (ANSI/ASQC Q9001:2008) are implemented and maintained. 5.5.3.2 Reporting to top management on the performance of the quality management system and need for improvement through the QMS Management Review (see Section 5.6). 5.5.3.3 Communicating the results of customer satisfaction surveys, management reviews, third-party assessments to Sentry Equipment employees in order to promote the awareness of meeting customer requirements. 5.5.4 Senior management will ensure that communications about the QMS take place within the company using these basic practices: 5.5.4.1 Reviewing the effectiveness of the QMS at an employee meeting on at least an annual basis; 5.5.4.2 Sharing results of performance measures on a monthly, quarterly or annual basis. 5.6 Management Review 5.6.1 The senior management team and management representative review the QMS at least once per year. The purpose of the review is to assess the effectiveness, adequacy and continuing suitability of the quality system as it is integrated within the business. 5.6.2 The management representative will be responsible for scheduling and conducting the reviews. 5.6.3 An agenda for the review meetings will include data gathered regarding the QMS. This review will include assessment by senior management of Revision 16 page 14 of 394

opportunities for improvement and a need to make changes to the QMS, quality policy and/or quality objectives. Specific inputs to management review will include: 5.6.3.1 Results of audits; 5.6.3.2 Customer satisfaction feedback; 5.6.3.3 Process and product performance and conformity; 5.6.3.4 Status of preventive and corrective actions; 5.6.3.5 Follow-up actions from previous management reviews; 5.6.3.6 Changes that could affect the QMS; 5.6.3.7 Recommendations for improvement. 5.6.4 Meetings minutes will be taken and any decisions and actions related to these topics will be recorded as management review output: 5.6.4.1 Improvement of the effectiveness of the QMS and its processes; 5.6.4.2 Improvement of product related to customer requirements; 5.6.4.3 Resource needs. 5.6.5 Minutes of the review meetings will be recorded and maintained according to instructions for QMS records. Revision 16 page 15 of 394

5.6.6 Organization Chart (Figure 1.0) Note: Throughout this Manual described actions and functions are assigned to individuals whose titles appear above. These individuals may delegate the actual work performed by other qualified individuals under their direct line of authority, as indicated by the lines of direction on the Organizational Chart provided the work performed by others is the responsibility of the individual stipulated in the QA Manual. Revision 16 page 16 of 394

5.6.7 Process Flow Diagram (Figure 2.0) Revision 16 page 17 of 394

6.0 RESOURCE MANAGEMENT Sentry Equipment Corp. recognizes the need to assure that products of our manufacture are designed, assembled, tested and serviced in accordance with practices that result in consistent high quality. Sentry uses written procedures and work instructions for employees (at all levels) to follow through out the company. To ensure that employees through out the company are able to complete their work training is provided to them to ensure that they have the competency to carry out their work. 6.1 Provision of Resources 6.1.1 Senior management has determined resources necessary to enhance customer satisfaction by meeting customer requirements, to implement and maintain the Quality Management System (QMS), and to continually improve the effectiveness of the QMS. These resources are referenced throughout this Manual. 6.1.2 Resource needs at all levels will be determined on an on-going basis by senior management and may or may not be part of the corrective action, preventive action, continual improvement, or management review records. 6.1.3 Jobs at Sentry Equipment are defined by job descriptions, and personnel are evaluated against those job descriptions prior to hire or promotion. Where gaps are identified in skills, training is provided. 6.1.4 Competency is evaluated after training and training will be repeated as necessary. Also see the section titled Competence and Training. 6.2 Overall Awareness of the QMS 6.2.1 It is the responsibility of the Quality Manager to communicate with Sentry Equipment s associates to help them see how the work that they do affects product quality and how their work activities impact the achievement of quality objectives for the company. 6.2.1.1 Communication will take place via regularly updated postings of results against quality objectives/goals and via meetings and planning sessions that will be initiated by the Quality Manager. 6.3 Competence and Training Responsibility and Records 6.3.1 Sentry Equipment s functional area managers and the Quality Manager have determined the necessary training and competency evaluation methods needed for personnel performing work affecting product quality. The goal of evaluation is to ensure actions taken in training have been effective, and that the associate is prepared to properly do the work on a regular basis. 6.3.2 Training responsibility for work affecting product quality and the ability to meet customer requirements: 6.3.2.1 The Quality Manager has the responsibility to ensure that employees exercising procedures, which affect the safe operation of products, are deemed competent to complete these procedures. Procedures which meet this criterion are Weld Examination, Liquid (Dye) Penetrant Examination, Leak & Hydrostatic Testing, electrical Revision 16 page 18 of 394

Continuity and Dielectric (hi-pot) Strength. 6.3.2.2 The Production Manager has the responsibility to ensure that Machinists, Welders, and Assemblers are suitably trained in assembly/test techniques for products to which they are assigned. 6.3.3 After training, competency will be determined for each employee, (including managerial function) using testing, observation and oversight. Records will be maintained as indicated in this Manual. 6.3.3.1 Training conducted by, or at the direction of the Quality Manager, will be documented and recorded, which identifies the title of the training, the instructor, the date of instruction, and grade on a written examination. Certification of employees is maintained in a training database. 6.3.3.2 Training conducted by, or at the direction of the Production Manager, may be based on observation and oversight. Once the employee has demonstrated skills sufficient to produce product per requirements, he/she is deemed competent to assemble and test that product. A list of employees and their training records are available in the training database. 6.4 Infrastructure and Work Environment 6.4.1 Sentry Equipment provides adequate buildings, workspace, environmental controls, work environment, process equipment and supporting services in order to achieve product conformance requirements. Work instructions and procedures for work processes address the details of infrastructure and work environment needs. Management oversees the creation of these procedures and instructions, and the Quality Manager ensures requirements are met through the use of quality management systems audits and the achievement of quality objectives. Also see the section on Internal Audits for details regarding this process. 6.4.2 Sentry is committed to managing the work environment to provide safe and healthful working conditions for its associates. The safety committee and management work together to achieve both. Revision 16 page 19 of 394

7.0 PRODUCT REALIZATION Sentry Equipment management has identified all pertinent processes for product realization and has controlled these processes with procedures and work instructions. Sentry Equipment associates know the importance of following established methods and the value of keeping appropriate records for all activities that support the selling, design, manufacture and shipping of products. Regularly scheduled internal audits verify the proper use of the system and allow for continual improvement activities. 7.1 Overview of Product Planning Controls 7.1.1 Sentry Equipment designs and manufactures products for a variety of industries. Regardless of product type, the same process steps are used to provide a product that meets the customer s requirements. These process steps are controlled through detailed procedures and work instructions. 7.1.2 Sentry works closely with its customers to design products to meet or exceed requirements. Sales and Engineering have primary responsibility for learning the voice of the customer and communicating needs throughout the company. 7.1.3 Engineering, Quality, and Manufacturing establish the processes and documentation needed to support design and manufacture of the Sentry products. Senior management provides resources needed to support product realization efforts. 7.1.4 Engineering determines the required verification, validation, monitoring, inspection and test activities for products and the criteria for product acceptance. Documentation is controlled via the Documents Control Procedure. 7.1.5 Engineering determines what records are needed to provide evidence that processes have been carried out according to documented instructions and that products meet the requirements. Records are controlled via the Records Control Procedure. 7.2 Customer-related Processes 7.2.1 The VP Power or VP Process works with the customer to determine requirements related to the product. Requirements to be determined before an order can be accepted include: 7.2.1.1 customer-specific product requirements; 7.2.1.2 requirements for delivery and post-delivery (service) activities 7.2.1.3 product requirements not specified by the customer but essential for intended or specified use; 7.2.1.4 statutory and regulatory requirements; and 7.2.1.5 any additional requirement determined relevant by Sentry Equipment. 7.2.2 The VP Power or VP Process will administer all contracts for custom engineered products, including initiating customer correspondence and maintaining contract-related correspondence. The VP Power or VP Process shall transmit all contract modifications to engineering. All contract communications with the customer are documented per written procedures. Revision 16 page 20 of 394

7.2.3 In limited cases where the customer does not provide a documented requirement, The VP Power or VP Process will contact the customer to verify requirements prior to acceptance of the contract. 7.2.4 The VP Power or VP Process, or designee from Customer Service, is responsible for the order entry process and those written procedures that affect the order entry process. 7.2.5 The VP Power or VP Process is responsible to resolve all contract discrepancies with the customer and to assure that all affected internal and external parties are informed of contract modifications. 7.2.6 Customer Service will receive and review all new customer purchase orders (contracts). See sub-points below. At the completion of the review by the appropriate individual, Customer Service will enter the order within Sentry s Materials Requirements Planning (MRP) system and will electronically signify (enter) who completed the order review before being allowed to complete the order entry. Records of contract/order reviews and modifications are maintained in files or within the MRP system. 7.2.6.4 If required, Customer Service will route orders for custom engineered and made to order products to the appropriate Applications Engineer who shall perform an initial review to determine general acceptability. 7.2.6.5 The Applications Engineer will deliver all orders for custom engineered products with all accompanying drawings and specifications to the Product Engineer for engineering review. The engineering review shall cover the specifications and drawings, as appropriate; to assure that the order can be accepted. 7.2.7 In general, the VP Power or VP Process is tasked with communication arrangement decisions related to the customer. These persons are the customers primary contact for new business or order changes to products. 7.2.7.4 Customer Service may assist customers with open order communication, such as amendments to the order. 7.2.7.5 Quality management will be involved with customer feedback, which may include both customer kudos and complaints. 7.3 Design and Development 7.3.1 Sentry Equipment plans and controls the design and development activities for all new, and revised products as well as application of existing products. Activities include planning, design review, design inputs, design verification, design validation, design changes, and design outputs. Detailed requirements for each activity can be found in the Design Procedure. 7.3.2 Design and development planning includes: 7.3.2.1 The VP Power, VP Process or Chief Technology Officer, assigning Revision 16 page 21 of 394

an Engineer (Product Engineer, Design Engineer or designee) to the engineered product and defining all appropriate interfaces. 7.3.2.2 Determining each design and development stage; 7.3.2.3 Determining the appropriate review, verification and validation activities for each design and development stage; 7.3.2.4 Defining the responsibilities and authorities for design and development activities; 7.3.3 Design and development review: at suitable stages of the new product design process, Sentry Equipment Engineering performs systematic reviews as described in the Design Procedure. These reviews will evaluate the ability of design and development to meet requirements, identify any problems, and propose necessary actions to address the problems. 7.3.3.1 Participants in reviews will be those representatives from Sentry Equipment, its suppliers or customers whose presence is pertinent. 7.3.3.2 Results of these reviews and resultant necessary actions are recorded and maintained in the job folder. 7.3.4 Design inputs are reviewed by designated individuals comparing them to the project specifications to assure that the inputs are not incomplete, ambiguous or in conflict with each other and that they are documented. 7.3.4.1 Design Inputs shall be functional and meet performance requirements 7.3.4.2 Detailed requirements of design inputs can be found in the Sentry s Design Procedure. 7.3.5 Design and development outputs will be in a form that allows for verification against the design and development input. The Engineer (Product Engineer, Design Engineer or designee) will coordinate the completion of design output activity: 7.3.5.1 Meet the design and development input requirements 7.3.5.2 Provide appropriate information for purchasing and production 7.3.6 Design and development verification at Sentry Equipment is based on the complexity of the work and the product being developed. Verification is done to ensure that the design and development outputs meet the design and development input requirements. 7.3.6.1 Verification of documents are reviewed and approved based on the product type as defined in the design procedure. 7.3.7 Sentry Equipment relies on its customers to complete design and development validation activities for engineered products, in order to ensure that the resulting product meets the requirements for the intended use. Revision 16 page 22 of 394

7.3.7.1 Partial validation activities may be completed by Sentry Equipment. 7.3.7.2 Sentry Equipment also provides field servicing activities. See the section (7.12 of this Manual) on Servicing for additional details of controls. 7.3.7.3 Records of validation activities for new products are typically maintained by the customer. When these results are shared, they will be filed with the appropriate job information by Sentry. 7.3.8 Control of design and development changes: The VP Power, VP Process or Chief Technology Officer has responsibility for coordinating all design changes per the Design Procedure. 7.3.9 The Quality Manager or designee may review the Production Department ( Shop ) copies of drawings, specifications, procedures and bills of material for items requiring inspection and shall make them available for third party inspectors. 7.3.9.1 ASME further requires a relationship between Sentry Equipment Corp. and an Authorized Inspector (A.I.). 7.3.9.2 RESPONSIBILITY: The Quality Manager shall assure that the Authorized Inspector is kept sufficiently informed of all work in progress and that all nondestructive examination procedures, personnel qualifications, and procedure qualifications are made available for him to perform his prescribed duties in accordance with the requirements of the Code. 7.3.9.3 The Quality Manager shall assure that the Authorized Inspector is given the opportunity to witness nondestructive examinations performed on ASME Code material or subassemblies and to provide suitable examination facilities for the evaluation of radiographs. 7.3.9.4 GENERAL: The Authorized Inspector is an inspector regularly employed by an ASME/National Board accredited authorized inspection agency. The Authorized Inspector shall possess a National Board New Construction Commission with the A endorsement on his commission card. 7.3.9.5 QMS MANUAL: A controlled copy of this Manual shall be provided for the Authorized Inspector's use within Sentry Equipment Corp. The Authorized Inspector shall review and accept all revisions to this Manual prior to implementation or inclusion. The Authorized Inspector shall provide evidence of this acceptance, which is shown on the cover page. 7.3.9.6 LIAISON: The Quality Manager, or designee, shall provide all liaisons Revision 16 page 23 of 394

with the Authorized Inspector. 7.3.9.7 ACCESS TO INSPECTOR: The Authorized Inspector shall have free access to all locations where Code activities are being performed on an item and to review all documentation related to Code work. The Quality Manager shall assign personnel to assist and accompany the Authorized Inspector. Free access shall also be given to the Authorized Inspector's Supervisor during the Supervisor's audits and as requested by the Authorized Inspector. 7.3.9.8 INSPECTIONS: Prior to start of fabrication the Certified Performance Record (CPR) (Procedure 22-09205A Exhibit 1.) for the item/assembly shall be presented to the Authorized Inspector for designation of his required inspection points. Provisions shall be made in the CPR for the Authorized Inspector to establish a hold point for his internal inspection prior to closure or through an inspection opening. The Quality Manager shall notify the Authorized Inspector with sufficient advance notice (as agreed by the Inspector) of all impending inspection points. 7.3.9.9 QUALIFICATIONS/REQUALIFICATIONS: The Authorized Inspector shall be notified of pending qualifications tests for welding procedures, welders and welding operators. He shall have the opportunity to witness the welding performed and the mechanical testing of the weld sample. The Authorized Inspector may require requalification of any welding procedure specification or any welder/welding operator whenever he has specific reason to question the suitability of the procedure or the qualification of the welder/welding operator. The Authorized Inspector may require requalification of NDE procedures or personnel whenever he has specific reason to question the suitability of the procedure or the qualification of the NDE personnel. 7.3.9.10 NONCONFORMITIES: The Authorized Inspector is notified of all nonconformities which affect Code requirements and their disposition (including scrap) by copies of the Nonconformity Reports. Nonconforming materials' dispositions involving weld repairs to a pressure retaining Code item shall be accepted by the Authorized Inspector prior to the repairs beginning. Copies of all nonconformity documentation are retained by Quality Assurance and are available to the Authorized Inspector. 7.3.9.11 AUDITS: The Quality Manager shall provide assistance to the Authorized Inspector's Supervisor on his audits. Revision 16 page 24 of 394

7.3.10 The Engineer, or designee, shall release for manufacture only items and assemblies which have all required engineering activities completed per the Design Procedure. 7.4 Purchasing and Materials Control 7.4.1 Sentry Equipment purchases raw materials, components and equipment from outside suppliers in order to make products for its customers. Sentry Equipment provides all pertinent information to its suppliers by use of a Suppliers Manual to ensure that purchased product conforms to Sentry Equipment requirements. Various types of controls are placed on suppliers, depending on the effect the supplied item has on the Sentry Equipment final product. 7.4.2 Several different functional areas within Sentry have responsibility toward materials control. Additional details outlining specific activities can be found in applicable work instructions. 7.4.2.1 The VP Power or VP Process is responsible for the complete and accurate preparation of all internal material definition documents and for compliance of such material definition documents with all technical aspects required by the customer contract. 7.4.2.2 Design Engineers or Product Engineers are responsible for defining all pressure boundary materials, attachment materials, and structural supports under the jurisdiction of the Contract. 7.4.2.3 The Materials Manager is responsible for preparation, distribution and control of purchase orders. 7.4.2.4 The Production Manager is responsible to assure that production personnel comply with this section and that material is properly stored and handled. 7.4.2.5 The Quality Manager is responsible to assure all items and materials are properly received and inspected. 7.4.2.6 The Quality Manager is responsible to approve all suppliers of calibration and nondestructive examination services. Records of these approvals are maintained by Quality. 7.4.3 Suppliers of materials and services are selected and evaluated as an ongoing process. Evaluation will be conducted by the Quality Department at the direction of the Quality Manager. Results of the evaluations will be documented. 7.4.3.1 When discrepant materials or services are provided by a supplier, see the Nonconforming Materials Process procedure for details about the escalation of actions needed by the supplier to resolve and correct the situation. 7.4.3.2 Sentry s Quality Manager shall have sole responsibility as to whether the supplier will be allowed to receive future purchase orders. Future purchase orders to suppliers that have unresolved Corrective Action Revision 16 page 25 of 394