Revised: 02.2018 Doc ID: CORSAF.118

Table of Contents

Safety Manual Policy Statement .......................................................................................................................................... 1

Purpose ............................................................................................................................................................................... 1

Responsibilities .................................................................................................................................................................... 1

Corporate Safety .............................................................................................................................................................. 1

Management .................................................................................................................................................................... 1

Supervision ...................................................................................................................................................................... 1

Safety Committee ............................................................................................................................................................ 1

Associates ........................................................................................................................................................................ 1

Operating Rules & Regulations ........................................................................................................................................... 2

Safety Orientation ................................................................................................................................................................ 2

Conducting Orientation .................................................................................................................................................... 2

New Associates: Before Beginning Work ........................................................................................................................ 2

Annual Updates ............................................................................................................................................................... 2

Safety Rules ........................................................................................................................................................................ 2

New Associates ............................................................................................................................................................... 3

All Associates ................................................................................................................................................................... 3

General Safety Rules .......................................................................................................................................................... 3

Housekeeping .................................................................................................................................................................. 4

Personal Conduct ............................................................................................................................................................ 4

Maintenance .................................................................................................................................................................... 5

Warehouse and Shipping................................................................................................................................................. 6

Power Machinery ............................................................................................................................................................. 6

Hand Tools ....................................................................................................................................................................... 6

Electrical........................................................................................................................................................................... 6

Ladders ............................................................................................................................................................................ 7

General Operations .......................................................................................................................................................... 7

Accessory Installation ...................................................................................................................................................... 7

Driving Operations ........................................................................................................................................................... 7

Body Shop Operations ..................................................................................................................................................... 8

Rail Loading & Unloading Operations .............................................................................................................................. 8

Office Safety .................................................................................................................................................................... 9

Safety Committee Policy .................................................................................................................................................... 10

Organization ...................................................................................................................................................................... 10

Extent of Authority ............................................................................................................................................................. 10

Recommendations ............................................................................................................................................................. 10

Plan of Action..................................................................................................................................................................... 10

Meeting Schedule .......................................................................................................................................................... 10

Revised: 02.2018 Doc ID: CORSAF.118

Order of Business .......................................................................................................................................................... 10

Safety Committee Functions with Objectives and Duties .................................................................................................. 11

Objectives & Duties ........................................................................................................................................................ 11

Safety & Health Committee Member Duties ...................................................................................................................... 11

Chairperson ................................................................................................................................................................... 11

Secretary/Recorder ........................................................................................................................................................ 12

Members ........................................................................................................................................................................ 12

Canadian Facilities ............................................................................................................................................................ 12

Objectives & Duties ........................................................................................................................................................ 12

Injuries............................................................................................................................................................................ 13

Work Refusal ................................................................................................................................................................. 13

Claims Management ........................................................................................................................................................... 14

Accident Investigations ...................................................................................................................................................... 14

Step 1: Gathering the Facts ........................................................................................................................................... 14

Step 2: Analyzing the Facts ........................................................................................................................................... 14

Step 3: The Recommendation ....................................................................................................................................... 15

Step 4: Management Follow-Up .................................................................................................................................... 15

When an Injury Occurs ...................................................................................................................................................... 15

Implement Incident Plan ................................................................................................................................................ 16

Vehicular Accidents ........................................................................................................................................................... 17

Non-Accident: Damaged Vehicle Procedures ................................................................................................................... 18

Completing Forms .......................................................................................................................................................... 18

The Decision Makers (Facility Management) ................................................................................................................ 18

Occupational Safety and Health Act (OSHA) .................................................................................................................... 19

Recording Injuries .......................................................................................................................................................... 19

Displaying Previous Year’s Incidents ............................................................................................................................. 19

OSHA Inspection ............................................................................................................................................................... 19

Before the OSHA Inspector’s Arrival ............................................................................................................................. 19

Canadian Facilities ............................................................................................................................................................ 19

Occupational Health & Safety Act – Ontario .................................................................................................................. 19

WSIB Forms ................................................................................................................................................................... 20

Hazard Communication (HazCom) Program .................................................................................................................... 21

Hazardous Chemicals ....................................................................................................................................................... 21

Container Labeling ......................................................................................................................................................... 21

Safety Data Sheets (SDS) ............................................................................................................................................. 22

Associate Information and Training ................................................................................................................................... 23

Hazardous Non-routine Tasks ........................................................................................................................................... 23

Chemicals in Pipes ............................................................................................................................................................ 24

Contractors ........................................................................................................................................................................ 24

Canadian Facilities ............................................................................................................................................................ 24

Revised: 02.2018 Doc ID: CORSAF.118

Personal Protective Equipment (PPE) Program .............................................................................................................. 25

Electronic Hazard Assessment.......................................................................................................................................... 25

Education and Training Program ....................................................................................................................................... 25

Replacement of Defective or Damaged Equipment .......................................................................................................... 25

Terms ................................................................................................................................................................................. 26

Respiratory Protection Program ........................................................................................................................................ 26

Use of Respirator/Availability ......................................................................................................................................... 26

Responsibilities .............................................................................................................................................................. 27

Program Administration ................................................................................................................................................. 27

Work Place Monitoring and Assessment ....................................................................................................................... 28

Medical Evaluations ....................................................................................................................................................... 28

Respirator Fitting ............................................................................................................................................................ 28

Respirator Equipment Selection .................................................................................................................................... 29

Respirator Use ............................................................................................................................................................... 29

Respirator Maintenance & Care .................................................................................................................................... 30

Associate Training ......................................................................................................................................................... 31

Respirator Program Evaluation ...................................................................................................................................... 31

Fall Protection Program ..................................................................................................................................................... 32

Identification of Fall Hazards ......................................................................................................................................... 32

Outside Contractors ....................................................................................................................................................... 33

Fall Protection Equipment Inspection & Maintenance Procedures ............................................................................... 34

Confined Space Entry ........................................................................................................................................................ 36

Hazardous Work Permit for Hot Work ............................................................................................................................... 36

Permit System ................................................................................................................................................................ 36

Lockout/Tagout Program ................................................................................................................................................... 37

Lockout/Tagout Procedures .............................................................................................................................................. 37

Preparation for Lockout .................................................................................................................................................. 37

Lockout/Tagout .............................................................................................................................................................. 37

Electrical Lockout/Tagout Procedures ............................................................................................................................... 39

Type "A" Lockout/Tagout ............................................................................................................................................... 40

Type "B" Lockout/Tagout ............................................................................................................................................... 40

Additional Lockout/Tagout Precautions ......................................................................................................................... 41

Training .............................................................................................................................................................................. 41

Tagout Devices .............................................................................................................................................................. 41

Retraining ....................................................................................................................................................................... 41

Inspections......................................................................................................................................................................... 42

Bloodborne Pathogens ....................................................................................................................................................... 43

Exposure Determination .................................................................................................................................................... 43

Method of Compliance ....................................................................................................................................................... 44

Engineering/Work Practice Controls .............................................................................................................................. 44

Revised: 02.2018 Doc ID: CORSAF.118

Personal Protective Equipment (PPE) .............................................................................................................................. 44

Housekeeping .................................................................................................................................................................... 44

Hepatitis B (HBV) Vaccination ........................................................................................................................................... 44

Vaccination Records and Forms .................................................................................................................................... 45

Vaccination Decline ....................................................................................................................................................... 45

Booster Shots ................................................................................................................................................................ 45

Post Exposure Evaluation and Follow Up ...................................................................................................................... 45

Healthcare Professional's Written Opinion .................................................................................................................... 46

Information and Training ................................................................................................................................................ 46

Record Keeping ............................................................................................................................................................. 46

Evaluation and Review .................................................................................................................................................. 46

Emergency Response Plan ................................................................................................................................................ 47

Evacuation Maps ............................................................................................................................................................... 47

First Aid & Emergency Medical Services .......................................................................................................................... 47

Responsibilities .................................................................................................................................................................. 47

Terminal and Human Resource Manager ...................................................................................................................... 47

Operations Managers/Designated Safety Representative ............................................................................................ 48

Associates ...................................................................................................................................................................... 48

Salvage Operations ........................................................................................................................................................... 48

Communications Plan ........................................................................................................................................................ 48

Training Requirements ...................................................................................................................................................... 48

Emergency Response Team ......................................................................................................................................... 49

Eye Wash and Shower .................................................................................................................................................. 49

Facility Alarm System ........................................................................................................................................................ 49

Incident Plan ...................................................................................................................................................................... 49

Procedure for Medical Emergency ................................................................................................................................ 49

Earthquake, Fire, Explosion, Chemical Spill/Leak Plan .................................................................................................... 50

Evacuation Plan ................................................................................................................................................................. 50

Other Emergency Plans .................................................................................................................................................... 51

Occupational Ergonomics .................................................................................................................................................. 52

Definitions .......................................................................................................................................................................... 52

Summary of Ergonomic Program Elements ...................................................................................................................... 52

Management Commitment and Associate Involvement .................................................................................................... 52

Associate Involvement ....................................................................................................................................................... 53

Program Review and Evaluation ....................................................................................................................................... 53

Ergonomic Hazard Recognition ......................................................................................................................................... 53

Worksite Analysis ........................................................................................................................................................... 53

Hazard Prevention and Control ......................................................................................................................................... 54

Engineering Controls ..................................................................................................................................................... 55

Work Practice Controls .................................................................................................................................................. 55

Revised: 02.2018 Doc ID: CORSAF.118

Personal Protective Equipment (PPE) ........................................................................................................................... 56

Administrative Controls .................................................................................................................................................. 56

Exercise/Wellness Programs ............................................................................................................................................. 57

Training and Education .................................................................................................................................................. 57

Work Station Design/Operation ......................................................................................................................................... 58

Job Design ..................................................................................................................................................................... 58

Body Movements ........................................................................................................................................................... 58

Manual Handling Tasks ................................................................................................................................................. 59

Excessive Loads ............................................................................................................................................................ 59

Work Postures Principles ............................................................................................................................................... 59

Video Display Terminal (VDT) ........................................................................................................................................... 59

Fleet Loss Control Program ............................................................................................................................................... 61

AWC Statement of Fleet Loss Control Policy .................................................................................................................... 61

Driver Selection ................................................................................................................................................................. 61

Driver Performance ........................................................................................................................................................... 61

Drug Testing ...................................................................................................................................................................... 62

Accident Recordkeeping, Reporting and Analysis ............................................................................................................ 63

Driver Responsibility ...................................................................................................................................................... 63

Management Responsibility ........................................................................................................................................... 63

Preventable vs. Non-Preventable Accidents ..................................................................................................................... 63

Vehicle Selection, Inspection, and Maintenance ............................................................................................................... 64

Vehicle Selection ........................................................................................................................................................... 64

Vehicle Inspection .......................................................................................................................................................... 64

Transportation of Hazardous Materials ............................................................................................................................. 64

Driver Training ................................................................................................................................................................... 65

Driver Training ............................................................................................................................................................... 65

Fleet Loss Control Program Audit ..................................................................................................................................... 66

AWC Automobile Policy ..................................................................................................................................................... 67

Maintenance Responsibilities ............................................................................................................................................ 67

Driver Safety Rules ............................................................................................................................................................ 67

Selection of Company Drivers ........................................................................................................................................... 68

Violations ........................................................................................................................................................................... 68

Environmental ..................................................................................................................................................................... 69

Environmental Manual ....................................................................................................................................................... 69

Health & Safety Training ..................................................................................................................................................... 70

Company Required Training .............................................................................................................................................. 70

Training Requirements ...................................................................................................................................................... 70

General Orientation ........................................................................................................................................................... 70

Revised: 02.2018 Doc ID: CORSAF.118

Introduction to Safety ..................................................................................................................................................... 70

Product ........................................................................................................................................................................... 70

Equipment ...................................................................................................................................................................... 70

Environment ................................................................................................................................................................... 71

Company Training Topics .................................................................................................................................................. 71

3-Points of Contact ........................................................................................................................................................ 71

AAR ................................................................................................................................................................................ 71

Confined Spaces ............................................................................................................................................................ 71

Driver Safety .................................................................................................................................................................. 71

Emergency Preparedness ............................................................................................................................................. 71

Environmental ................................................................................................................................................................ 71

Equipment ...................................................................................................................................................................... 71

First Aid and CPR .......................................................................................................................................................... 72

Hazardous Communication (HazCom/WHMIS)............................................................................................................. 72

Hot Work ........................................................................................................................................................................ 72

Injury & Illness Prevention ............................................................................................................................................. 72

Rail Safety ...................................................................................................................................................................... 72

Site Specific ................................................................................................................................................................... 72

Training Videos .............................................................................................................................................................. 72

Forms ................................................................................................................................................................................... 73

Form Index ......................................................................................................................................................................... 73

Section 1 Page 1

Revised: 02.2018 Doc ID: CORSAF.118

Safety Manual Policy Statement

Purpose The Auto Warehousing Company’s (AWC) Safety Manual is to provide all associates with written health and safety policies and procedures for promoting a safe workplace for our associates, and to promote safety consciousness. The safety and health program has been established to integrate safety and health measures into every task. It is the policy of AWC to operate in a manner which protects all associates from injuries or illnesses.

Responsibilities

Corporate Safety The Corporate Safety Department will review each facility's goals and objectives on a periodic basis to ensure implementation of the Safety Program. They will provide consultation, facility auditing, training, document/policy/procedure development, and team participation.

Management Management's responsibility is the prevention of injury and illness accidents for all issues under their span of control. Management will provide direction and full support to supervision and associates regarding all safety and health procedures, job training and hazard elimination practices. Management will keep fully informed on safety and health issues throughout the company.

Supervision Supervisors are directly responsible for supervising their workers, and for developing proper attitudes toward safety and health in themselves and in those they supervise. This will include training on safe procedures and safe work practices to ensure that all operations are performed with the utmost regard for the safety and health of all personnel involved, including themselves. They will enforce company rules and take immediate corrective action to eliminate hazardous conditions and practices, as safety cannot be sacrificed for any reason. Supervisors will be held accountable for safety and health issues.

Safety Committee The committee's purpose is to bring workers and management together to promote safety and health in the workplace in a non-adversarial, cooperative effort. It consists of management and associate representatives who have an interest in safety and health. The committee is responsible for making recommendations on how to improve safety and health in the workplace. They have the responsibility to define problems; identify hazards and recommend corrective actions; and to help identify associate safety training needs.

Associates Each associate, regardless of their position in the company, will cooperate with all aspects of AWC's safety and health program. Including, but not limited to:

1. Accidents or injuries must be reported immediately to your supervisor.

2. Required personal protective equipment (PPE) must be worn by all associates, no exceptions.

3. Report hazardous conditions & safety and health concerns to your supervisor immediately.

4. Associates support the safety committee, who will accept any suggestions.

If all parties do their part to ensure work place safety and health, we all benefit. No job is so important that we cannot take time to complete it safely.

Section 2 Page 2

Revised: 02.2018 Doc ID: CORSAF.118

Operating Rules & Regulations

Safety Orientation

Conducting Orientation All individuals who are conducting New Hire Orientation at each facility must complete a New Hire Safety Requirements sign off form. This form outlines the requirements of each item that needs to be addressed for all newly hired associates.

New Associates: Before Beginning Work Before a new associate starts work, supervisors must distribute a copy of Auto Warehousing Company Safety Policies which includes: Safe Work Rules, Right to Know Informational Packet, and have all new associates watch the Hazardous Communication video. After receipt of information and completion of video associates must complete the Right to Know Acknowledgment Form. All associates must also be trained on the proper use, location, and posters of Personal Protective Equipment (PPE) pertinent to their position and sign the PPE Acknowledgment Form.

AWC provides an online video on Hazardous Communication to be used for this training along with the HazCom trainer packet. All associates are required to complete the Hazardous Communications training prior to working at any facility. After the training and video, associates must complete the Right to Know Acknowledgment Form. The forms are filed in the associate's personnel file at the facility. Verbal training, instruction, and handout, if available, must accompany all training videos.

All associates must watch the Driver Safety video and complete the accompanying video quiz with a score of 80 percent or higher. Associates hired for positions in rail must also watch the Rail Safety video and complete the accompanying video quiz with a score of 80 percent or higher. Individuals will not be able to begin working if an 80 percent is not achieved on the video quizzes.

At the time of hiring, in addition to the HazCom training, associates must be trained in all other job specific safety training as established for the position e.g. Affected Lockout Tagout, Evacuation Procedures, Emergency Preparedness, 3-Point of Contact, etc.

Annual Updates On an annual basis: all required training must take place. A list of required training is located on the Safety SharePoint. A training sign off sheet must be signed by all associates with the forms filed in the associates’ personnel files and a copy submitted online to the Safety SharePoint training library.1

Please call the Corporate Safety Department if you have questions regarding the required material.

Safety Rules AWC reserves the right to change, amend, or delete any and all rules listed here at any time, at AWC’s discretion.

We all share the responsibility for encouraging a culture of safety dedicated to improving behaviors and performance in the workplace. We all share accountability to encourage our team members to value safe practices and programs. Associate cooperation and active participation in the company safety effort is mandatory if reasonable success is to be achieved. Not every situation is covered -- we believe your common sense will guide you correctly in

1 To expedite these procedures it is acceptable to update the handout, distribute, instruct, and have all associates sign

one training sign in sheet. The sheet must attest to the training completed.

Section 2 Page 3

Revised: 02.2018 Doc ID: CORSAF.118

many instances. Your manager may post additional rules of conduct which may be site specific.

A moment of carelessness can result in a lifetime disability. Don’t permit familiarity to let a speedup of production cause you to ignore safe work practices.

New Associates

1. Follow established operating procedures. Discuss any and all variances with your supervisor before making a change.

2. Orient yourself to your new surroundings.

3. Cooperate with the experienced associates.

4. Obtain the proper protective equipment for the job and wear it.

5. Report all unsafe conditions and unsafe acts for they are the cause of most injuries.

6. The slightest injury should be reported immediately.

7. When in doubt about a procedure, don't hesitate - ASK your supervisor.

All Associates The best protection from exposure to injury is the recognition of accident producing hazards. Knowledge and application of safe work practices provide protection for you and your fellow workers.

General Safety Rules

1. You are expected to follow your supervisor's instructions.

A. If you are unhappy about something you have been asked to do, you may ask for an explanation.

2. Injuries or accidents must be reported to a supervisor or manager immediately, regardless of severity.

A. If you are able, your supervisor/manager will have you immediately write down the circumstances of the event.

B. Failure to report any such incident immediately may result in disciplinary action because this could put other associates at risk because a hazard may be left unidentified.

3. Associate shift briefings will be attended daily. Associates will be instructed on safety issues, accident prevention, and current developments in safety. All associates and managers are encouraged to take an active role in these meetings.

4. Learn the right way. Ask questions. Do not learn by trial and error.

5. Hazardous or unsafe conditions or practices

A. Communicate your suggestions either verbally or use the Hazardous Condition Reporting Form found on the Safety SharePoint on better and safer methods to your manager. Always be conscious of the safety of others.

B. Report all hazardous or unsafe working conditions, tools, or equipment to your manager immediately. Be alert to those conditions always.

C. Observe all company safety and health rules and apply the principles of accident prevention in all daily duties and activities.

6. All associates must have a valid driver's license and be able to present it at any time.

Section 2 Page 4

Revised: 02.2018 Doc ID: CORSAF.118

7. No fast or reckless driving. Damaging a vehicle through careless handling is an extremely serious matter and one which could result disciplinary action.

Housekeeping

1. Keep work areas clean. A clean work area improves working conditions and reduces accident causing hazards. Work areas are not limited to buildings, but include vehicles, yards, etc.

2. Use the waste cans and not the floor or grounds for disposing of litter. If you see the chance to clean up an area -- don't wait to be asked. All refuse must be placed in appropriate trash containers.

3. Keep the floors, isles, walkways, ramps, stairways, and work areas clear of hazards.

4. Keep equipment, tools, material, and work areas clean and orderly.

5. Keep work areas as free of debris, floor storage, and hoses, as possible. Any necessary air lines, hoses, or cords running across the floor must be placed so as to minimize any trip and fall hazards.

6. Clean up all spilled materials or liquids immediately. Use warning cones or some other means to identify the hazard until it has been corrected.2

7. Do not leave combustible materials such as rags or paper on heaters, boilers, or other objects which can become hot.

8. All compressors and electrical equipment must be turned off at the end of the work day.

9. All parts hanging on overhead wall hooks shall be securely fastened to prevent them from falling.

10. Dispose of empty drink containers in the places that are provided; never leave them in the work area.

11. Store materials in the proper manner and place. Provide an adequate foundation for heavy loads and make sure there is no over-hanging or irregular stacking of materials.

12. Projecting nails shall be removed from all packing cases, barrels, boxes and boards.

13. Use "Dry Sweep' or other similar product to clean up oil or grease spills. Oil dry must be swept up within 15 minutes. Spill procedures.2

14. Follow the proper spill cleanup procedures for hazardous chemicals found in the SDS and Spill Procedures. 2

Personal Conduct

1. Fighting on company premises is not permitted.

2. Horseplay is prohibited. An act in jest may end in disaster.

3. Observe all company safety & health rules and apply the principles of accident prevention in day to day duties.

4. Know your job and its responsibilities. Do not take chances or use unsafe methods, tools, or equipment.

5. Follow proper lifting procedures and ergonomics at all times

6. The use or possession of intoxicating beverages on the premises is prohibited.

2 See your facility’s Spill Prevention Plan or SPPC.

Section 2 Page 5

Revised: 02.2018 Doc ID: CORSAF.118

7. Drugs, pills, tranquilizers, etc., are not to be taken on the job unless written authorization is obtained from a physician.

8. AWC and/or customers' tools and equipment are reserved for use on customers' vehicles. No work on private cars is permitted in the facility.

9. Smoking or eating is prohibited in customer vehicles.

A. Smoking is allowed in designated areas only.

B. Observe all hazard warning and no smoking signs.

10. Wear proper and accepted clothing for the work to be done

A. Do not wear frayed, torn. loose clothing or jewelry, or long unrestrained hair near moving machinery, or around electrical equipment

B. If uniforms are issued they are expected to be clean and in good repair

C. Associates issued personal protective equipment (PPE) must wear the equipment when performing work requiring that protection. Notify management if the equipment does not fit properly or needs repair/replacement.

D. Wear appropriate footwear in accordance with terminal or corporate appearance policy.

E. No open toed footwear is acceptable in any work area.

F. Wear only low or medium heeled shoes of sturdy construction.

G. Wear safety toed shoes where required.

11. Know the location of fire/safety exits, fire extinguishers, and emergency/evacuation procedures.

12. Operate only the equipment for which you have been authorized and trained to operate. Observe the safe operating procedures for all equipment

13. When riding in the van, ride as a passenger. Do not hang off any outer part of the vehicle or disrupt the concentration of the driver.

14. Drive in a safe and proper manner always while driving vehicles in the care and custody of AWC. Drive defensively!

Maintenance

1. Do not leave a repair job until all guards are replaced and follow applicable lockout/tagout procedures.

2. Wear proper eye protection when cutting, welding, grinding, chipping, or while exposed to such work.

3. Screen electric welding to protect others wear possible.

4. Do not stand on forks of industrial lift trucks for high work.

5. Do not use broken or unsafe ladders.

6. Keep tools clean and in good repair.

7. Use caution when welding near combustible materials.

8. Wet down plant area before cutting or welding. Have the fire extinguisher handy.

9. Have foreman notify watchmen to check the area every hour for the following two shifts.

10. Pick up all left-over materials and return them to shop for disposal or storage.

Section 2 Page 6

Revised: 02.2018 Doc ID: CORSAF.118

Warehouse and Shipping

1. Check all wheeled equipment for condition and serviceability-hand trucks, carts, conveyors, etc.

2. Power tools shall be used by authorized personnel only.

3. Operate forklifts with caution - keep forks low when traveling.

4. Use extreme caution when working boxcars and open doors.

Power Machinery

1. Never operate a machine unless you are qualified and authorized to do so.

2. All machinery, shafting, gears, flywheels, belts, grinders, and other moving parts shall be guarded.

3. Machinery “out of service” for lubrication, repair and adjustment shall have the power switch "locked out" and tagged to prevent activation of equipment

4. Any machine malfunction should be brought to the supervisor's attention

5. All portable power tools shall not be damaged or modified in anyway.

6. Never attempt to make an adjustment or to "free a jam" without first stopping the machine.

Hand Tools

1. Defective hand tools shall not be used.

2. Use hand tools for the purpose intended-The right tool for the right job.

3. Do not carry sharp tools in pockets.

4. Inspect handles of tools for cracks, slivers, or other defects.

5. Return all tools to their proper storage place when you have finished using them.

Electrical

1. Respect electricity. A little can kill.

2. Use proper lockout/tagout procedures.

3. Whenever possible, an electrical line should be de-energized before work is done on or near it, no matter how low the voltage. Only qualified persons should do electrical work.

4. Keep switch panel areas clear at all times. Minimum of 3 feet.

5. Lock out and tag all machine control switches before servicing or making repairs.

6. Only authorized personnel shall work on electrical equipment and/or lock/tag it out.

7. All power equipment, stationary or portable, shall have a third wire ground if designed with one. All extension cords shall be three wire grounded.

8. Use wooden or fiberglass ladders for all electrical repairs.

9. Do not leave electrical cords where cars or trucks will run over them. If electrical cords must cross a traffic path, use protective crossover devices.

10. Never attempt to repair electrical equipment. Disconnect the power source and report the defect immediately.

Section 2 Page 7

Revised: 02.2018 Doc ID: CORSAF.118

Ladders

1. Use a ladder when reaching for high objects. Do not stand on chairs, boxes, or other things that may slip or slide out from under you.

2. Inspect ladders before use. Broken or damaged ladders must not be used and must be reported to management. They need to be tagged "DEFECTIVE" and immediately removed from service.

3. Make sure ladders are securely placed. Have someone hold the base of the ladder if additional stability is needed.

4. Face the ladder and use 3 points of contact while climbing or descending.

5. Do not place the ladder in front of doorways unless the door has been secured.

6. Do not stand on the top 2 steps of the ladder.

7. Read and obey the warning instructions posted on the ladder.

8. Ladders are not allowed to be used for purposes other than they are designed.

9. Only one person on the ladder at a time.

10. Return the ladder to its storage place when not in use.

11. Be sure shoes are free of grease or oil before climbing.

12. Extension ladders must have non-skid safety feet.

General Operations

1. Care must be exercised while opening or closing vehicle hoods and doors to avoid hitting or being hit by the opening panel or catching someone's fingers, head, or hand.

2. Caution must be exercised when moving around any forklift, front-end loader, shuttle vans, or rail loader while these pieces of equipment are in use.

3. Blue flags protection must be used at all time when working on a track.

4. All shuttle and yard vehicles should be equipped with flashing lights and back-up warning beepers.

5. Only trained and authorized Associates are to handle batteries.

6. Protective rubber gloves, aprons, and safety goggles must be worn during removal replacement or other handling of vehicle batteries.

Accessory Installation

1. Installers are required to wear safety goggles/full face shield while using a drill or grinder.

2. Proper ergonomics must be followed when performing work.

3. All tools must be properly maintained and good condition.

4. No backing without a spotter.

Driving Operations

1. Manual Transmission vehicles (Stick shift) must be placed in neutral gear before starting engines.

2. Automatic transmissions should be placed in park before starting engines.

Section 2 Page 8

Revised: 02.2018 Doc ID: CORSAF.118

3. Before proceeding in reverse gear, drivers must be certain that no other vehicles or pedestrians are crossing behind them. Backing up should not be performed without a spotter.

4. Drivers must stay in wide aisles when driving against the normal traffic pattern, and must use extreme caution when crossing driving aisles.

5. Always be aware of other drivers (use defensive driving).

6. Following the designated speed for each location is mandatory: speeding and tailgating are strictly prohibited.

7. The emergency (hand) brake should be set on every vehicle after parking.

8. Before exiting from a parked vehicle, drivers must check to be certain no other traffic may be approaching along that side.

Body Shop Operations

1. Approved respirators must be worn during spray painting operations (See: Respirator Fit Test).

2. Safety goggles/face shields are required while drilling, grinding, or welding.

3. Paints are to be returned to paint storage room after use.

4. Wiping cloths must be stowed in an approved, lidded container after use with thinners, solvents, and other flammable materials.

5. No flammable liquids are to be stored in unmarked containers.

6. Jack stands must be used whenever jacks are being used.

7. Always follow manufacturer's instructions on safe use of the paint booth.

Rail Loading & Unloading Operations

1. Rail crews must be sure to check deck heights before loading or unloading: serious injury could result on impact of a vehicle roof and railcar.

2. Rail crews should check to see that proper hand brakes are set on railcars.

3. Rail crews must notify the lead person whenever ratchets, railcar doors, or other rail equipment is not operating properly in order that the railroad can be notified of malfunctioning equipment.

4. Three points on contact should be used always when entering/exiting railcars and ladders. Three points of contact must also be maintained when entering/exiting vehicles, using equipment, crossing junctions, etc.

5. Running on railcars is prohibited, as is jumping from one railcar to the next: when going up or down railcar ladders, rail crews must have both hands free for handholds.

6. Bridge plates will always be handed down and never thrown to the ground.

7. Except for those equipped with a hand release, railcar doors must be opened with the proper tools only, not one's hands.

8. Railcars must not be moved with anything other than the proper railroad-provided equipment.

9. Rail crews must be alert to and stay clear of the rail loading ramp while it is being operated.

10. Ramp operator should be trained & qualified to drive ramp.

Section 2 Page 9

Revised: 02.2018 Doc ID: CORSAF.118

11. When applying, or removing chocks, rail crews should wear the gloves provided by AWC.

Office Safety

1. Report any slippery floor surfaces. Be cautious right after floors have been reconditioned.

2. Maintain good housekeeping habits. Keep all foreign objects (Le. pencils, paper clips. etc.), off the floor.

3. Report any uneven or damaged floor surfaces so they can be repaired.

4. Keep electrical extension cords at a minimum. If they must be used, locate them so they do not become tripping hazards. Never scuff electrical cords with your feet.

5. If exposed conduit is necessary, be sure it is plainly marked to increase awareness.

6. Do not enter dark halls or rooms without adequate lighting Poor visibility conceals hazards.

7. Report all electrical "shocks" from any electrical equipment. All electrical equipment should be properly grounded.

8. Only maintenance associates should adjust or replace fluorescent light bulbs.

9. Report any frayed electrical cords or broken plus receptacles.

10. Office Equipment

A. Never attempt to repair a piece of defective electrical equipment. Switch off power, disconnect the plug if possible, and report the defect to your supervisor.

B. Keep desk and file drawers closed when not in use. Only open one drawer on a file cabinet at a time.

C. Use handles or knobs on drawers.

D. Keep desks, tables, aisles, etc., neat, clean, and orderly.

E. Check office equipment and furniture for hazards/malfunctions; report any unsafe conditions immediately.

F. Do not operate any office equipment unless authorized and given proper instruction. Report any malfunction or damage immediately.

G. Always unplug office machines before cleaning.

11. Use sharp or pointed tools correctly and be sure they are stored properly.

12. If portable fans or heaters are necessary:

A. Keep them out of the way of foot traffic and away from the work level.

B. Never move an appliance unless they are turned off or disconnected.

13. Flammable liquids should not be stored in your desk. Dispose of waste or rags used with cleaning solvents in a proper manner.

Section 3 Page 10

Revised: 02.2018 Doc ID: CORSAF.118

Safety Committee Policy The purpose of our safety committee is to bring workers and management together in a non-adversarial, cooperative effort to promote safety and health in the workplace. The safety committee will assist management and make recommendations for change.

Organization The membership shall vary from site to site. A good ratio is 1 management and 3 associate representatives- If the workforce is less than ten (10), it should include everyone in the Safety meeting. Associate representatives shall be volunteers or elected by their peers. If no associates volunteer or are elected, they may be appointed by management. Employer representatives will be appointed. Membership appointments will be staggered so that at least one experienced member is always serving on the committee.

Extent of Authority It must be clearly understood that the safety committee advises management on issues that will promote safety and health in the workplace. Written recommendations from the safety committee will be submitted to management. In turn, management will give serious consideration to the recommendations submitted, and will respond in writing to the committee within a reasonable time.

Recommendations All recommendations submitted to management should be written and will be: clear, concise, provide reasons for implementation show implementation costs, recommend completion dates, and list the benefits to be gained.

Plan of Action The committee’s plan of action are procedures by which the committee will successfully fulfill its role.

Meeting Schedule The Safety Committee must determine a set time to meet each time every month (e.g. the first Monday of the month). Setting of the meeting time should be completed at the beginning of each year. The committee must meet at least once each month ending the year with a minimum of twelve (12) meetings.

Order of Business

1. The chairperson(s) will call the meeting to order

2. Roll call of members is taken

3. Introduction of any visitors is made

4. Old business will be addressed; closed or updated

5. New Business will be discussed

A. New and outstanding recommendations submitted by outside agencies, e.g. insurance carrier, fire department, OSHA, etc. will be presented

6. Monthly Facility Safety Inspections will be distributed as appropriate

7. Any injuries will be discussed

A. No names will be given while discussing the injuries; only the circumstances surrounding the injury and how prevention of such events is to be discussed

8. Adjournment of the meeting

Section 3 Page 11

Revised: 02.2018 Doc ID: CORSAF.118

9. Copies of the minutes and suggestions (if any) will be made and uploaded to the Safety SharePoint

Safety Committee Functions with Objectives and Duties

Objectives & Duties

Safety Committee’s Management Commitment to Workplace Safety/Health

Establish procedures for review of management's response to minutes.

Submit written recommendation for safety/health improvements/changes and response time desired. Review corrective action taken by management.

Evaluate employer's safety/health policies/procedures.

Unless a Capital Expenditure Request is needed, local management will have the authority to approve actions and recommendations made by the Committee.

Committee Meetings and Associate Involvement

Include associate input on agenda for safety committee meeting.

Hold monthly meetings.

Keep meeting minutes for a minimum of three (3) years. Post committee minutes on the Safety SharePoint and associate safety board.

Include in the meeting minutes all recommendations.

Hazard Assessment and Control

Establish procedures for workplace inspections to identify safety and health hazards. Assist employer in evaluating the accident and illness prevention program.

Appoint an inspection team of at least one (1) associate representative and one (1) employer representative.

Conduct monthly safety inspections of their areas.

Use Document ID CORSAF.038 when performing the monthly inspection.3

Review corrective measures for adequacy. Make written recommendation to correct hazard and submit form. Management will be notified electronically once form is submitted.

Safety & Health Committee Member Duties

Chairperson

1. Prepare agenda for next meeting

2. Arrange for meeting place

3. Notify members of meeting Arrange program

4. Set time schedule for meeting Arrange all seating for members

5. Review previous minutes and materials for meeting

6. Conduct meeting

3 Unless your facility has been enabled with the tablet based inspection forms.

Section 3 Page 12

Revised: 02.2018 Doc ID: CORSAF.118

Secretary/Recorder

1. Record minutes of meeting

2. Distribute minutes

3. Post minutes for other associates

4. Report status of recommendations

5. Assume chairperson's duties if required

Members

1. Report unsafe conditions & practices

2. Attend all safety meetings

3. Report all accidents or near-misses

4. Review all incidents

5. Act as a work area representative in matters pertaining to Safety & Health

6. Contribute ideas and suggestions for improvement of safety

7. Work safely

8. Influence others to work safely

9. Complete assignment given by the Chairperson

10. Others as determined by the Company Safety & Health needs

Canadian Facilities In Canada, the Safety Committee is referred to as the Joint health and safety committee (JHSC). The JHSC is comprised of at least two persons, who represent the workers and the employer at a workplace. Their primary role is to identify workplace health and safety concerns and bring them to the attention of the employer.

Committees must be co-chaired by two members. One of the co-chairs will be chosen by the members who represent workers, the other by members who exercise managerial functions. The names and work locations of the members will be posted in the workplace.

The JHSC must have at least one worker and one management person serve as certified members of a workplace Joint Health and Safety Committee (JHSC). This certification involves training in health and safety law, and the identification, assessment and control of hazards.

Objectives & Duties The JHSC has various duties, including:

1. Identifying actual and potential hazards in the workplace

2. Obtaining information from the company relating to health and safety in the workplace

3. Inspecting the workplace monthly

A. Worker committee members must select an Associate member in their group to inspect the workplace

B. The member should be a certified if possible.

4. Being consulted about and having a member representing workers be present at the beginning of any health and safety-related testing in the workplace

Section 3 Page 13

Revised: 02.2018 Doc ID: CORSAF.118

Injuries The company must notify the JHSC of lost time injuries caused by accident, explosion, fire or incident of workplace violence at the workplace, and must report any occupational illnesses of which he/she has knowledge. Where a person is killed or critically injured from any cause at a workplace the employer must immediately notify the Ministry and the JHSC.

Members, who represent workers, must designate one or more worker members to investigate incidents in which a worker is killed or critically injured4. Following the investigation, all findings must be reported to the committee. They can inspect:

1. Where the incident occurred

2. Relevant machine, device or thing

3. But not disturb the scene pending a Ministry of Labour investigation.

Work Refusal A committee member, who represents workers, must be present during the employer or supervisor’s investigation of a work refusal. If the issue is not resolved the Ministry of Labour must be notified.

The Ministry of Labour has published: A Guide for Joint Health and Safety Committees and Representatives in the Workplace.

4 A person is “critically injured” for the purposes of the Act if he or she has an injury of a serious nature that places life

in jeopardy, produces unconsciousness, results in substantial loss of blood, involves the fracture of a leg or arm but not a finger or toe, involves the amputation of a leg, arm, hand or foot but not a finger or toe, consists of burns to a major portion of the body, or causes the loss of sight in an eye.

Section 4 Page 14

Revised: 02.2018 Doc ID: CORSAF.118

Claims Management Injury and illness losses due to hazards are needless, costly, and preventable. Managers must instruct associates to report all on-the-job injuries and accidents to their supervisor immediately after they occur.

Accident Investigations Accident investigations are fact finding exercises to identify necessary changes for the prevention of future incidents. Properly conducted accident investigations are also a positive associate morale booster because it reinforces management's safety commitment. Accident investigation preparation and questions can be found on the Safety SharePoint.

As part of the planning process, determine who will be responsible for accident investigations (managers or supervisors). Make this selection before you have an incident. The individual assigned needs to be trained in accident investigating.

Conduct investigations on all accidents and near misses.

1. Identify the Who, What, When, Where, Why, and How.

2. Identify the two types of causes. The first type is the most readily available reason for the accident (sometimes there is more than one). It is what some refer to as the surface cause. The second type and potentially more dangerous is the root cause.

Step 1: Gathering the Facts

1. Identify what happened and who was involved.

A. Interview the worker and any other witnesses as soon as reasonably possible. It may be that your first interviews will be with witnesses other than the injured worker. However, interview the injured worker as soon as possible and, if possible, at the accident site. You will want to collect the facts while memories are fresh and the evidence is still available. The more witnesses discuss the matter among themselves the cloudier the memories become.

2. Conducting the Interview:

A. The interview should be private and non-threatening.5

B. Put the witness at ease by explaining the purpose of the interview and the value of their input.

i. Listen. Let the witness talk. Ask open ended questions and always ask "why- as a follow-up question

ii. Take detailed notes.

iii. Restate the facts and events to clarify your understanding.

Step 2: Analyzing the Facts

1. Pictures should be taken before vehicles are moved.

2. For more instructions you can refer to the Photography Guidelines page on the Safety SharePoint

3. List the events as they occurred with the causation factors.

4. Determine if this type of incident has happened in the past. Evaluate why past corrections were inadequate to prevent a recurrence.

5 Watch for factors involving fatigue or home problems that may have carried over to work. Also be alert for problems

in supervision, management attitudes, and ask "Was safety compromised for the sake of production?"

Section 4 Page 15

Revised: 02.2018 Doc ID: CORSAF.118

5. Consider all factors. Be sure you have found the root cause(s) as well as the surface cause(s).

A. Surface Cause(s) of an accident are the hazardous Practices or Conditions that clearly allowed the event to take place. They are readily apparent and appear early in the investigation. If post-accident hazard corrections reduce or eliminate only surface causes, similar accidents will most likely continue to plague the workplace.

B. Root Cause(s) of an accident are not so easily uncovered. They are the Underlying contributing factor(s) that nurture hazardous conditions or practices. Only by correcting root causes will long-term solutions happen.

Step 3: The Recommendation

1. The recommendation should identify the hazard(s) and ways to eliminate the hazard or, if elimination is not possible, reduce the exposure. There are three methods of addressing these concerns:

A. Engineering Controls: Eliminating or reducing the existing hazards through equipment redesign. Clearly the most desirable choice.

B. Administrative Controls: Changing practices, procedures, or policies to eliminate or reduce exposure to the hazard. This is less desirable because the hazard still exists, and you are dealing only with the human factor.

C. Personal Protective Equipment: Should be used in conjunction with administrative controls when exposure to a hazard cannot be eliminated or adequately reduced.

2. The recommendation should also contain the following elements:

A. Identify what actions have been taken

B. Identify if disciplinary action is required

C. Offer options in your recommendation

D. Identify how your suggestions will improve overall operations

E. Identify the costs associated with each option

F. Prioritize the recommendations

G. Identify the benefits associated with each option

H. Suggest corrections for addressing root causes and the obvious surface causes.

I. Compare the direct/indirect cost for each associated accident with the cost of correction

Step 4: Management Follow-Up

1. All process corrective actions are followed up on the safety call, all changes are documented, and audited to ensure the procedures are still in place.

A. Management and Corporate Safety will determine if the corrective action was appropriate and if it solved the problem.

When an Injury Occurs A 601 injury report must be uploaded to the Safety SharePoint within 24 hours.

1. The Terminal Manager is required to notify OSHA when an associate is killed on the job or suffers a work-related overnight hospitalization, amputation, or loss of an eye.

A. A fatality must be reported within 8 hours.

Section 4 Page 16

Revised: 02.2018 Doc ID: CORSAF.118

B. An in-patient hospitalization overnight, amputation, or eye loss must be reported within 24 hours.

Implement Incident Plan Manager or designated supervisor will immediately investigate the incident to determine the cause. Use the following technique.

1. Gather the information

A. Secure the scene: Place barriers or post a guard.

i. Document the scene: Take initial statements, record observations, take photographs, review records, take measurements, and draw sketches.

An AWC 601 Report must be filled out the same day as the injury.

Witness statements can be taken immediately on the company Statement of Incident.

2. Analyze the Facts

A. Reconstruct the Accident: Numbered step-by-step format.

B. Conduct cause Analysis: Determine surface and root causes.

C. Develop Recommendations: Engineering controls, work practice controls, administrative controls, personal protective equipment (PPE).

3. Write the Report (601 Report and any local forms)

A. Background: Answer (who, what, when, why, where)

B. Description: Use as much detail as possible and only the facts.

C. Findings: List surface and root causes.

D. Corrective Actions: Include short and long term fixes.

E. Summary: Contrast costs of fix and accident costs; list human & economic benefits of fix.

Injuries are reported on the electronic 601 Report, located on the Safety SharePoint or on your facility’s Safety Tablet, "First Report of Injury Form" (if a doctor/hospital visit was required). Turn reports into the Terminal Manager with all supporting documents collected.

The facility completes the 601 report on the Safety SharePoint or on your facility’s Safety Tablet and submits it. Do not wait for one or two items of additional information, you may add any extra information later.

In addition to filing a 601 Report, managers are required to file any state/provincial forms (e.g. First Report of Injury), if the associate receives medical treatment or has time off from work. These documents should also be attached to the 601 Report.

Corporate Safety will generate a safety alert to be distributed electronically to all locations.

Further Instructions for Supervisor and Associate:

1. In case of serious injury or illness an EMS service should be called. If none are available associate should be taken immediately for treatment by the Supervisor or Manager (with a First Aid trained person to assist).

2. Less serious injuries can be evaluated by the supervisor that is First Aid trained and taken for medical treatment by a supervisor.

Section 4 Page 17

Revised: 02.2018 Doc ID: CORSAF.118

3. Time Loss: In the case of time loss, an injured/ill associate is expected to return to work on the date indicated by the attending physician. Procedures are set forth in the Return to Work plan and should be followed.

4. If the original time loss is extended the associate must give notification to the company of the estimated time loss and expected return to work date. Notification should be given immediately upon the associate learning of the estimated date(s), and the doctor's written extension should be brought or sent to the Terminal Manager.

5. The associate must contact the Terminal Manager at least one day prior to reporting for work, so they can be added to the day’s work schedule.

6. Upon return to work, an injured/ill associate must provide a medical release signed by the attending physician. At the lime of treatment, the attending physician may recommend or require certain work-related restrictions. Based on the extent and nature of the physicians recommended restrictions the company will make every

7. Accommodation possible to allow the associate to continue to work, either at their regular job or a modified job.

8. All discussions and correspondence must be documented and kept on the Workers Comp Calendar and in the associate’s personnel file.

Vehicular Accidents All vehicular accidents, regardless of the severity, must have a 600 Report completed on the Safety SharePoint. The report must be start within 24 hours of the incident.

The management or designated safety representative will immediately investigate the accident to determine the cause using the following technique.

1. Gather the information

A. Secure the scene: Place barriers or post a guard, do not move the vehicle.

B. Document the scene: Take initial statements, record observations, take photographs, review records, take measurements, and draw sketches.

2. Analyze the Facts

A. Reconstruct the Accident: Numbered step-by-step format.

B. Conduct cause Analysis: Determine surface and root causes.

C. Develop Recommendations: Engineering controls, work practice controls, administrative controls, personal protective equipment (PPE).

3. Complete the 600 Report

A. Background: Answer (who, what, when, why, where)

B. Description: Use a narrative format

C. Findings: List surface and root causes

D. Recommendations: Include short and long term fixes

E. Summary: Contrast costs of fix and accident costs; list human & economic benefits of fix.

All supporting documents collected are turned into the Terminal Manager. Accidents are reported, within 24 hours on the (600 Report), which is located on the Safety SharePoint or on your facility’s Safety Tablet.

Section 4 Page 18

Revised: 02.2018 Doc ID: CORSAF.118

Do not wait for one or two items of additional information before completing a report. All reports can be updated when additional information is received.

Non-Accident: Damaged Vehicle Procedures When vehicles are picked up for delivery, truckers occasionally find damage when they are doing their pre-load inspection. It is required that this damage be reported to an AWC manager or supervisor. The damage is then initialed or signed by the AWC inspector to indicate he/she noted the damage before the trucker loads the vehicle on his/her truck.

When a claim is received at the corporate office with the supervisor’s initials/signature next to specific damage it will shorten the processing time for claims payment.

Completing Forms

1. AWC 601 Report. "Workers Compensation Claim" (located on the Safety SharePoint or on your facility’s Safety Tablet): Complete all sections, using as much detail as possible.

A. Follow directions stated within the 601 Report or view directions for completing incident reports.

B. Hover over fields to see more detail/ instructions

2. AWC 600 Report. "Vehicle Accident Claim" (located on the Safety SharePoint or on your facility’s Safety Tablet): Complete all sections, using as much detail as possible. If vehicle repair costs are not readily available, give an estimate only; the amount will be adjusted when the claim is received from the customer.

A. Follow directions stated within the 600 Report or view directions for completing incident reports.

B. Hover over fields to see more detail/instructions

The Decision Makers (Facility Management)

1. Take Corrective Actions

A. Management: Appoint a responsible person; establish correction dates.

B. Surface Causes: Correct hazardous conditions; correct hazardous work practices; use PPE.

C. Root Causes: Write/revise policies, procedures, rules: conduct local management/associate training; ensure supervision & enforcement; change language, perception, or reality.

2. Follow-up

A. Monitoring: Appoint responsible person; use a tracking log; Safety Committee reports on results.

B. Immediate Corrections (surface causes): Were hazardous conditions corrected? Were hazardous practices corrected?

C. Long-term Corrections (root causes): Were underlying hazardous conditions practices corrected? Were the underlying hazardous practices corrected?

3. Critical Review (Facility & Corporate management)

A. Quality: Are root causes addressed?

B. Analysis: Identify trends.

Section 4 Page 19

Revised: 02.2018 Doc ID: CORSAF.118

Occupational Safety and Health Act (OSHA) The Occupational Safety and Health ACT (OSHA) established laws that set standards for the maintenance of safe and healthful working conditions. Specific standards must be observed, and it requires Auto Warehousing Company to keep records and file reports of work-related deaths, illnesses, injuries, and hazards

Recording Injuries An important part of OSHA's record keeping process is workers compensation injuries. The company is required by law to record all workers compensation injuries on OSHA's Form 300. The company is required to provide injury and illness data to OSHA annually. All reporting must be done electronically. The required forms and dates are as follows:

1. Prior years OSHA Forms 300, 300A and 301 or comparable AWC form(s)

2. Must be submitted by March 2 for the prior year.

3. The Form 300 (Bureau of labor Statistics Log and Summary of Occupational Injuries and Illnesses) can be found on the Safety SharePoint under OSHA 300 Logs.

Displaying Previous Year’s Incidents The law requires that from February 1 to April 30, of each year, the summary side (only) of Form 300A be posted, displaying the previous year's incidents. It must be signed, dated and totaled. It must be posted in a conspicuous place for the entire month. OSHA can fine AWC if these procedures are not strictly followed.

Other OSHA health and safety regulations and/or information is available through your Workers Compensation Insurance Carrier, the local OSHA office, and Corporate Safety.

OSHA Inspection

Before the OSHA Inspector’s Arrival Auto Warehousing Company does not require OSHA inspectors to get a warrant, however if the Manager or an authorized representative is not at the facility we may request them to wait a reasonable length of time until the Manager arrives (1 hour is reasonable).

1. Refer to the “In Case of OSHA” guide located on the Safety SharePoint for more detailed instructions

2. Keep a positive, personable, and professional manner.

Gate guard(s) and receptionist(s) need to be informed as to whom to contact if an OSHA inspector arrives. They will introduce themselves and expect to be escorted to the initial representative so the proceedings can be started. Inspectors come out for several reasons including it is your turn for a random inspection or a complaint was made.

Canadian Facilities

Occupational Health & Safety Act – Ontario The Occupational Health and Safety Act (OHSA) is Ontario's cornerstone legislation for workplace health and safety. Other contributing legislation includes the Workplace Safety and Insurance Act (WSIA), Part II of which deals with the prevention of occupational injury and disease and the Human Rights Code, which often has to be considered in dealing with OHS issues. Both OHSA and WSIA are available along with all of Ontario's other Acts and regulations at the e-Laws website.

The main purpose of the Act is to protect workers from health and safety hazards on the job. It sets out duties for all workplace parties and rights for workers. It establishes procedures for dealing with workplace hazards and provides for enforcement of law where compliance has not been achieved voluntarily. Fundamental to the successful working of OHSA is the workplace Internal Responsibility System (IRS).

Section 4 Page 20

Revised: 02.2018 Doc ID: CORSAF.118

WSIB Forms All required injury reporting forms can be located on the WSIB website. Any associate injured must be provided with copies of all forms after their completion.

Worker's Report of Injury/Disease (Form 6)

The associate completes and returns the Worker's Report of Injury/Disease (Form 6) to their employer. The employer will then submit the Form 6 to the WSIB.

Employer’s Report of Injury/Disease (Form 7)

Within three (3) days of the date of the injury, the employer must complete the Employer’s Report of Injury/Disease (Form 7). The Form 7 will provide the details of the incident, wages, and contact information. This form can be submitted via email or e-filed.

Functional Abilities Form (FAF)

The employer provides the associate the Functional Abilities Form (FAF) to give to a medical professional for completion. The medical professional will provide a list of restrictions or functional abilities clearing the associate to modified or full duty return to work. This form should be completed at least bi-weekly or when essential for an associate to return to work.

Health Professional’s Report (Form 8)

A medical professional will complete the Health Professional’s Report (Form 8) during the initial visit of the injured associate. Functional abilities can be listed on this form as well. The medical professional submits the form to the WSIB and the employer receives a copy of the Form 8. Injured associates must also bring the job description of the easiest job to the treating physician.

Section 5 Page 21

Revised: 02.2018 Doc ID: CORSAF.118

Hazard Communication (HazCom) Program Auto Warehousing Company’s management is committed to the prevention of occurrence or happenings which result in injury and/or illnesses; and to complying with all applicable federal and state/provincial health and safety rules.

The HazCom program consists of two sections:

1. Written Hazard Communication Program that includes container labeling and Safety Data

Sheets (SDS).

2. Associate Information & Training Program.

The written Hazard Communication Program is designed to outline the manner in which AWC will meet its obligations under the law. The associate training program is designed to educate each associate about chemical hazards that they might be exposed to in the workplace. This written program will be available to all associates on the Safety SharePoint.

AWC has created policies, materials, training, SDS’s, and a HazCom video accessible online through the Safety SharePoint.

Hazardous Chemicals For the purposes of the Hazard Communication Program "hazardous chemicals" are any chemicals that pose a physical hazard or a health hazard to our associates through ingestion, inhalation or absorption. Physical hazards are reactions that could occur if chemicals are handled or stored improperly. This could result in a fire, explosion, and/or toxic gas release. Health hazards are health effects caused directly by the chemicals themselves, not an injury resulting from a reaction. All chemical materials can cause health problems under the wrong conditions.

Hazards will be controlled by the following actions:

1. Elimination/Substitution: Eliminate or substitute chemicals you currently use with less harmful ones

2. Engineering Controls: Ventilation or containment

3. Administrative Controls: Administrative controls are any procedure that significantly limits daily exposure by control or manipulation of the work schedule or manner in which work is performed. Administrative controls are not as effective as engineering controls but many are quick and inexpensive to implement.

4. Training and information

5. Signage

6. Maintain equipment to prevent leaks and releases

7. Standard Operating Procedures (SOPs)

8. Worker rotation

9. Scheduling tasks when chemical use is low

10. PPE (last resort)

Container Labeling The department at the facility receiving any hazardous chemicals or products will verify that all containers received for use have the following information clearly marked and visible before us:

1. Product identifier.

Section 5 Page 22

Revised: 02.2018 Doc ID: CORSAF.118

2. Signal Words

3. Hazard Statements.

4. First Aid Statement

5. Precautionary Statements and Pictograms, and

6. Supplier Information.

It is the policy of Auto Warehousing Company that no container will be released for use until the above information is verified, present, and adequate. This will be monitored and audited during Corporate Safety Site Visits.

The supervisor in each section will ensure that all secondary containers (such as a pail, can, or spray bottle) are labeled with either the original manufacturer's label or with a GHS compliant labels which identify the chemical and list appropriate hazard warning.

GHS compliant labels can be obtained from the Corporate Safety Department by following the GHS label request process:

1. A Terminal Manager or individual designated by the Terminal Manager will request a GHS label through the Safety SharePoint utilizing the GHS Label Request form.

A. The chemical/product name and manufacturer are required.

B. Only products that have been submitted through SharePoint as being present at the facility through the Chemical Update forms will be eligible for GHS label creation.

C. A maximum of 25 labels per product during 1 week will be issued at a time.

2. Corporate Safety receives a daily summary of all GHS label requests.

A. All GHS labels are processed within 1 week of receipt.

B. GHS labels are shipped to requesting facilities with the next scheduled overnight shipment to the facility.

It should be noted that:

1. Consumer products are exempt from labeling: (e.g. cleansers. hand soap, air freshener, etc.)

2. Portable containers are exempt from labeling if the person who fills it has direct contact with it the entire time

Safety Data Sheets (SDS) Safety Data Sheets (SDS) are supplied by manufacturers and distributors of hazardous chemicals. The SDS will contain detailed information about a product's hazardous constituents, health hazard, safety precautions and use restrictions. AWC will have all SDS for each hazardous chemical an associate will use at the facility. Copies of the SDS will be kept online. The online SDS database will be accessible on most office and shop computers. Every facility will have signs posted with a web address for associates to have the opportunity to access the library via the Internet or on a mobile device.

Whenever the employer receives a new or revised SDS that could impact an associate’s health, the employer must inform associates within 30 days after receipt. OSHA requires: “Such information shall be provided to associates on a timely basis, not to exceed 30 days after receipt, if the new information indicates significantly increased risks to, or measures necessary to protect, associate health as compared to those stated on a material safety data sheet previously provided.”

Section 5 Page 23

Revised: 02.2018 Doc ID: CORSAF.118

Management at the facility is responsible for notifying Corporate Safety of any new chemicals and/or products brought onto AWC property for any associate of AWC to utilize by following this process:

1. A new chemical/product must be added to the SharePoint utilizing the Chemical Updating form located on the SharePoint library.

A. The individual adding a chemical must include all details listed on the form.

B. An updated SDS obtained directly from the manufacturer or distributor (an SDS achieved from a Google search will not be accepted)

C. A direct link to the website where the SDS can be located, the phone number called to request the SDS, or an email address the SDS was requested from.

D. A picture of the product/chemical or UPC/barcode may be requested if not included and details of the product/chemical are insufficient.

SDS will be readily available to all associates in their work area for review at any time during a work shift. Hazardous chemicals will not be used until an SDS or appropriate SDS information is available and associates are trained. If an SDS is not available or a new chemical arrives without an SDS for a hazardous chemical, immediately contact your supervisor.

Associate Information and Training Prior to starting work, each new company associate will receive a Right to Know Informational Packet and watch the HazCom Video to include the following:

1. Overview of hazard communication program requirements.

2. Hazardous chemicals present in the workplace.

3. Location and availability of the written hazard communication program, posters, and SDS’s.

4. Physical and health effects of hazardous chemicals.

5. Methods and observation techniques used to determine the presence or release of hazardous chemicals in the work area.

6. How to reduce or prevent exposure to these hazardous chemicals through use of control/work practices and personal protective equipment

7. Steps the company has taken to reduce or prevent exposure to these chemicals.

8. Safety emergency procedures to follow if the associate is exposed to these chemicals.

9. How to read labels and review SDS to obtain appropriate hazard information.

Each associate will be required to read the Right to Know Informational Packet, sign the Right to Know Acknowledgment Form, and at the end of training sign the New Hire Safety Training Requirements Form. The associate will indicate that they understand the information and will comply with appropriate safe work practices, and that they understand that doing so is a condition of employment.

Each department manager will be responsible for answering any questions which might arise as a result of the training, and be responsible for training current associates whenever a new hazard is introduced into the workplace.

Hazardous Non-routine Tasks The Company's associates are not assigned foreseeable non-routine tasks which would expose them to hazardous chemicals. Certain associates (such as maintenance) might be assigned such non-routine tasks. Prior to starting work on such non-routine tasks, each

Section 5 Page 24

Revised: 02.2018 Doc ID: CORSAF.118

department manager shall provide affected associates with information about the hazards involved to include:

1. Specific chemical hazards.

2. Protective/safety measures the associate must take

3. Measures the company has taken to reduce the hazards, including ventilation, respirators, presence of coworkers, and emergency procedures.

Chemicals in Pipes The company does not have any pipes which contain hazardous chemicals other than:

1. The natural gas system.

2. Fuel tanks for vehicles.

The piping systems have been labeled. If not labeled, prior to beginning any work in areas that contain unlabeled pipes, the associate shall contact his/her supervisor for information regarding the chemicals in the pipes, potential hazards and safety precautions which should be taken.

Contractors It is the responsibility of the supervising manager to provide contractors the following information:

1. The existence and location of the written Hazard Communication Program.

2. Hazardous chemicals to which they may be exposed while on the job site, and the location of SDS.

3. Precautions associates may take to lessen the possibility of exposure, by using appropriate protective measures, and an explanation of the labeling system used.

4. Reminder to train their associates in the potential hazards, and supply SDS for their hazardous chemicals.

It is the responsibility of the Contractor to:

1. Identify and obtain SDS for the chemicals the contractor is bringing into the workplace.

2. All chemicals must be properly labeled with a GHS compliant label.

3. Train their associates regarding the potential hazards.

4. Remind all contractors that they must inform management if they bring any hazardous chemicals on site.

Canadian Facilities In Canada the Hazard Communication program is called WHMIS 2015/GHS (Workplace Hazardous Materials Information System and Globally Harmonized System of Classifications and in Canada it is federally legislated. The training is identical to the HazCom training except for name and government legislation.

Section 6 Page 25

Revised: 02.2018 Doc ID: CORSAF.118

Personal Protective Equipment (PPE) Program Auto Warehousing Company is committed to the prevention of incidence or happenings which result in injury and/or illnesses: and to complying with all applicable federal and state/provincial health and safety rules.

PPE is designed to protect the worker from injury or harm. However, it is not designed to prevent the occurrence of an incident which might cause harm or injury. For that reason, simply wearing PPE is not considered the single or most desirable solution to a possible occupational safety hazard.

Where there is a reasonable probability of injury, illness, or disease to the worker that cannot be controlled by other methods, PPE will be required. Once the decision to use PPE is made, care will be taken to make sure that the equipment is appropriate for the hazard.

The program consists of two sections:

1. Written assessment of the workplace.

2. Associate Training Program.

Electronic Hazard Assessment An electronic workplace assessment will be performed to determine whether hazards are present, or likely to be present, that necessitates the use of personal protective equipment. If such hazards exist, or are likely to exist, Auto Warehousing Company will select appropriate protective equipment.

All electronic hazard assessments will be completed by facility management and stored in a PPE - Certification of Assessment document library on the Safety SharePoint.

Education and Training Program All new associates will be trained on PPE, physically shown the location of PPE posters, where PPE is located, how to obtain PPE, and required to sign a PPE Acknowledgment Form. All associates who are required to wear personal protective equipment will be trained as follows:

1. When PPE is necessary.

2. What PPE is necessary?

3. How to put on, remove, adjust and wear PPE.

4. How to properly care for and maintain PPE, as well as equipment life expectancy and when to discard deteriorating or defective equipment.

5. Limitations on PPE's ability to protect against hazards.

6. There responsibilities and where to get information on all the above listed items.

Associates will be retrained annually and when PPE is replaced or brought new into Auto Warehousing Company. It will be communicated to each affected associate the selection decision and how to properly fit or use each selected item.

Replacement of Defective or Damaged Equipment Supervisors or managers will immediately replace any defective PPE that they know of. It is the associate’s responsibility to inform management if their PPE becomes damage, worn-out or defective.

Section 6 Page 26

Revised: 02.2018 Doc ID: CORSAF.118

Terms

1. Eye Protection: Eye, face, and extremities, protection requirements cover exposure to flying particles, molten metal, liquid chemicals, acids, chemical gases and light radiation.

A. For operations with Gas metal arc welding and flux cored arc welding in the Body Shop with an arc current of 60-160 a minimum protective shade of 10 will be worn.

2. Head protection requirements cover exposure to falling objects and low ceiling heights.

3. Foot protection required must protect workers from exposure to falling objects or objects that can pierce the sole of a shoe.

4. Hand protection is required in a number of instances, including when a worker's hands may be exposed to skin absorption of harmful substances, severe cuts, severe abrasions, punctures, chemical burns, thermal bums and harmful temperature extremes.

5. Respiratory Protection identifies where lung protection is needed and methods of protecting associates from potential hazards.

6. Fall Protection identifies fall hazards and methods of protecting associates.

For training procedures in proper use of personal protective equipment please refer to training documents and more detailed information on PPE and how to determine what equipment should be used you can be located on the OSHA website:

https://www.osha.gov/dte/library/ppe_assessment/ppe_assessment.html

Respiratory Protection Program The AWC respirator protection program provides guidelines and procedures to safeguard associates from potential exposure to vapors, fumes, mists, dusts and oxygen deficiency in the workplace. This is generally accomplished using effective engineering controls (e.g., ventilation, instrumentation, controls, etc.) and safe work practices to the extent feasible. Respiratory protective equipment must be used to prevent associate exposure under the following conditions:

1. During the time required to install, service or maintain engineering controls

2. Where engineering controls and safe work practices fail to achieve full compliance

The program will be reviewed annually and updated, as necessary, to reflect any changes in workplace conditions or job assignments that might affect respirator use by the utilization of the PPE Certification of Assessment.

Use of Respirator/Availability Each associate that requires a respirator shall wear an approved respirator, properly fitted at all times while performing an operation defined as Hazardous or in the immediate area (within 10 feet) for an extended period of time (more than 5 minutes) where another associate is performing a hazardous operation. The operations considered hazardous at this time are: Paint and Body Shop processes

Each associate that needs or is required to wear a respirator will be issued one along with replacement parts, cartridges and filters as needed. The selected types of respirators are available from the paint shop leadsperson or supervisor.

Associates will not be assigned to tasks requiring use of respirators unless it has been determined that they are physically able to perform the work and use the equipment. The local physician shall determine this at their initial physical. The respirator user's medical status will be reviewed annually.

Section 6 Page 27

Revised: 02.2018 Doc ID: CORSAF.118

Responsibilities The following responsibilities have been assigned to the following designated personnel to ensure the effectiveness of the Respirator Protection program in safeguarding the health and safety of all associates.

Program Administration The Safety Department is responsible for the administration and technical oversight of the respiratory protection program. The responsibilities include:

1. Identification of those work areas that require respirator use, including an assessment of the potential hazards

2. If applicable: air sampling, measurement and laboratory analysis of contaminants, vapors or particulates in the identified work area(s)

3. Implement the medical surveillance and evaluation of associates required to use respirators, including follow-up examinations, where necessary

4. Arrange or conduct appropriate training of associates to instruct them on the storage, use and maintenance of respirators in the workplace

5. Record keeping and documentation of updates to the respirator protection program

Supervisors

Area Supervisors are responsible for ensuring that the respirator protection program is properly implemented for associates under their supervision and that equipment is made available to each worker assigned a job task requiring a respirator. Their responsibilities include:

Ensure that personnel are knowledgeable in the storage, use and maintenance of respiratory equipment

Enforcement of the use of respirators by associates under their supervision

Selection of respiratory equipment including fit testing of associates

Verify that the correct respirator and canister is used for the job(s) performed

Ensure that all respirator equipment is properly stored, cleaned and maintained

Identify any faulty equipment or changes to workplace conditions that might affect the work environment or respirator usage and report it to the safety department

Remove any defective or damaged respirators from service and replace (see maintenance section)

Associates

Associates are required to wear their respirator at all times while working in area(s) that mandate the use of respiratory equipment. Changes or modifications to supplied respirators by associates are strictly prohibited. Their responsibilities include:

Wearing of respirators at all times, where required

­ Spray booth

­ Sanding, buffing and grinding

­ Mixing chemicals

­ Cleaning spray equipment

Storage, cleaning and maintenance of respirator equipment

Reporting of any defective or faulty respirator to the Supervisor

Section 6 Page 28

Revised: 02.2018 Doc ID: CORSAF.118

Reporting of any illness, symptoms, change in medical condition or other health concerns to the Supervisor and Safety Coordinator

Attend training courses on the use, care and maintenance of respirators

Associate will not work in IDLH atmospheres or use a respirator in an emergency situation

In the case of an emergency all associates must evacuate the area immediately

Work Place Monitoring and Assessment Respirators will be selected based on the hazards to which associates are exposed during their assigned work tasks. Evaluations will be conducted for each work area where airborne contaminants, vapors, fumes and particulates may be present in the workplace environment to assess any hazards. The evaluation should include:

1. Listing of all hazardous materials or chemicals in the work area

2. Review of work procedures

3. Assessment of engineering controls in place, e.g., exhaust ventilation, sensors, instrumentation, etc.

4. If Applicable, air sampling of the workplace environment or personal air sampling of associates in representative areas of the workplace during operations.

Medical Evaluations Auto Warehousing Company’s designated medical services provider will perform a medical evaluation (annually) on each associate whose job assignment requires the use of a tight fitting or fresh-air supplied respirator. The associate will receive a medical questionnaire on line. This will ensure that the associate is physically and psychologically able to perform his/her assigned job duties while wearing respiratory protective equipment. A respirator fit test will be conducted after satisfactory completion of the medical examination. Follow-up evaluations may be administered should the associate report any change in their medical condition or other health concerns. If associate is medically unable to use a negative pressure respirator the company needs to provide a powered air purifying respirator (PAPR).

Respirator Fitting Upon successful completion of the medical examination, associates required to wear a tight fitting respirator will be given a fit test prior to commencing their job duties in a contaminated area. Respirators are generally available in several sizes to provide a comfortable fit for the associate. Fit testing will not be conducted on associates with facial hair that passes between the respirator seal and the face or interferes with valve operation. This includes beards, stubble and long sideburns. Fit testing of associates will be performed annually or whenever a different respirator face piece type is to be used by the associate.

Additional fit tests shall be conducted whenever the associate reports or the employer, supervisor, or program administrator makes visual observations of, changes in the associate's physical condition that could affect respirator fit. Such conditions include, but are not limited to, facial scarring, dental changes, cosmetic surgery, or an obvious change in body weight.

The facility should retain fit test records for respirator users. Refer to the OSHA website for detailed information on respirator fit testing procedures as mandated by OSHA 1910.134.

The employer shall establish a record of the qualitative and quantitative fit tests administered to an associate including:

1. The name or identification of the associate tested;

Section 6 Page 29

Revised: 02.2018 Doc ID: CORSAF.118

2. Type of fit test performed;

3. Specific make, model, style, and size of respirator tested;

4. Date of test; and

5. The pass/fail results for QLFTs or the fit factor and strip chart recording or other recording of the test results for QNFTs.

Fit test records shall be retained for respirator users until the next fit test is administered.

Respirator Equipment Selection Selection of respirators should be based on the physical and chemical properties of airborne contaminants, vapors or fumes in the work area(s) and their reported concentration levels. The appropriate respirators, cartridges and filters will be provided to medically approved associates who are assigned to job duties that require respirator equipment. All respirators should be NIOSH (National Institute for Occupational Safety and Health) approved. Area Supervisors will supply replacement cartridges and filters, as needed. The following types of respirators are approved for use:

Auto Preparation and Sanding Areas

Model 3M 7503 with particulate cartridge or equivalent

Paint Mix Room and Vehicle Spray Painting

3M 7503 respirator, half-mask, or equivalent

3M 07046 organic vapor cartridge or equivalent

Vision 2000, SATA, PAPR or equivalent

Only NIOSH/MSHA approved respirators have been chosen. The choice between these respirators is dependent upon the airborne contaminant present, the hazardous operation performed, and on the basis of comfort and ease of obtaining a proper fit. The company will provide the respirators. Currently only respirators that protect against particulates (dusts. fumes, mists, or fogs) created by sanding, welding or painting vehicles are needed.

The useful life of each respirator will vary depending on the job duties, the actual time in use, and individual storage procedures. Each respirator will have some limitations. Refer to respirator instructions. Air purifying types (disposable, half-mask cartridge) must only be used in 19.5 percent oxygen or better. No work will be performed in areas less than 19.5 percent oxygen.

Respirator Use Respirators should be used in accordance with the manufacturer’s instructions and safe work practices established by the Area Supervisor. Do not share your assigned respirator with any other associates. Eyeglasses or goggles must be worn in a manner that does not interfere with the seal of the face piece. Each associate should check the respirator seal each time it is worn, prior to commencing any work activity by performing the following:

1. Positive Pressure Check: Close off the exhalation valve and exhale gently into the face piece. The face fit is considered satisfactory if a slight positive pressure can be built up inside the face piece without any evidence of outward leakage of air at the seal. For most respirators this method of leak testing requires the wearer to first remove the exhalation valve cover before closing off the exhalation valve and then carefully replacing it after the test.

2. Negative Pressure Check: Close off the inlet opening of the canister or cartridge(s) by covering with the palm of the hand(s) or by replacing the filter seal(s), inhale gently so that the face piece collapses slightly, and hold the breath for ten seconds. The design of the inlet opening of some cartridges cannot be effectively covered with the

Section 6 Page 30

Revised: 02.2018 Doc ID: CORSAF.118

palm of the hand. The test can be performed by covering the inlet opening of the cartridge with a thin latex or nitrile glove. If the face piece remains in its slightly collapsed condition and no inward leakage of air is detected, the tightness of the respirator is considered satisfactory.

A. The respirator manufacturer's recommended procedures for performing a user seal check may be used instead of the positive and/or negative pressure check procedures provided that the employer demonstrates that the manufacturer's procedures are equally effective.

Supervisors should monitor work area conditions wherever respirators are used to determine any changes in the workplace environment or the condition of ventilation equipment. Associates should exit the work area for any of the following reasons:

1. Malfunction of the respirator or leakage of the face piece

2. To replace cartridges and filters or clean face piece

3. Increased breathing resistance or discomfort in wearing the respirator

4. To wash face to prevent eye or skin irritation

5. Associate illness due to dizziness, nausea, weakness, breathing difficulty, coughing, sneezing, vomiting or other warning symptoms

Respirator Maintenance & Care Respirators must be properly inspected, cleaned and stored to retain their effectiveness and ensure protection of the associate. Cartridges should be changed at a minimum of once a week.

Inspection

Each associate assigned a respirator should inspect the unit daily prior to use and during cleaning for the following (See: Daily Respirator Inspection Log):

Face piece cleanliness and proper fit

Straps for proper fit

Tube connections

Replacement of filters and/or cartridges in accordance with filter use time limits

Evidence of cracked, soiled or damaged seals

Proper operation of fresh air supply compressor (where used)

If a defective condition is observed during respirator inspection, the unit should be tagged and immediately removed from service. The Area Supervisor will issue replacement respirators to associates, if needed. Associates are not permitted to repair, alter or modify respirators other than routine replacement of filters and canisters. All respirator repairs must be performed by 3M or an approved contractor in accordance with the manufacturer’s recommendations.

Respirators assigned for emergency use should be inspected monthly and inspected for proper operation before each use.

Cleaning

Respirators should be cleaned and disinfected daily (or after each use) by the assigned associate in accordance with the manufacturer’s recommendations to maintain equipment in a sanitary condition. Clean face piece with 3M 07065 respirator wipes or equivalent. Allow to air dry in a non-contaminated environment.

Section 6 Page 31

Revised: 02.2018 Doc ID: CORSAF.118

Storage

Install cleaned respirator in a sealed polyethylene bag to prevent distortion of the face piece and exhalation valve. Do not hang the face piece by the headbands or place in any position that may cause distortion or damage to the seals. Store respirators in a location away from sunlight, dust, extreme temperatures, moisture, chemicals or contamination. Respirators should be identified or marked with the wearer’s name to ensure its use by the assigned associate only.

Record Keeping

The Safety Coordinator/Supervisor at each facility should maintain records for the following:

Associates assigned to respirators

Associate medical evaluations

Respirator fit testing

Associate training and orientation

Weekly respirator inspection reports

Annual respirator program evaluation

If Applicable -Air quality sampling of work area(s)

Associate Training Training of all associates and supervisors who are required to use a respirator in the performance of their assigned job duties, will be conducted prior to respirator use by the 3M manufacturer’s representative or other qualified instructor. Users will be instructed and trained in the proper use of respirators and their limitations when they initially select a respirator. Associates should demonstrate knowledge of, but not limited to:

1. Why the respirator is necessary and how improper fit, usage, or maintenance can compromise the protective effect of the respirator

2. What the limitations and capabilities of the respirator are

3. How to inspect, put on and remove, use, and check the seals of the respirator

4. What the procedures are for maintenance and storage of the respirator

5. How to recognize medical signs and symptoms that may limit or prevent the effective use of respirators

Retraining shall be administered annually, and when the following situations occur:

1. Changes in the workplace or the type of respirator render previous training obsolete;

2. Inadequacies in the associate's knowledge or use of the respirator indicate that the associate has not retained the requisite understanding or skill; or

3. Any other situation arises in which retraining appears necessary to ensure safe respirator use.

Respirator Program Evaluation The site Safety Coordinator and Area Supervisors should evaluate each work area on an annual basis or as needed to verify that the provisions of the respirator protection program are being properly implemented and to review pertinent records documenting respirator use and training. This assessment shall include discussions with associates required to use respirators to identify any areas of concern. Corrective actions should be implemented, where necessary, to address any noted problems or deficiencies.

Section 6 Page 32

Revised: 02.2018 Doc ID: CORSAF.118

Fall Protection Program We believe that in order for the fall protection program to be effective, it will take the cooperation and support of all our associates. We are adopting the following program to help protect our people from falls while working in elevated areas of four feet or more in height.

The AWC Fall Protection Program has seven primary components:

1. Identifies all fall hazards in the work area.

2. Describes the method of fall arrest and fall restraint to be provided.

3. Describes the correct procedures for the assembly, maintenance, inspection and disassembly of the fall protection system to be used.

4. Describes the correct procedures for handling, storage and securing of tools and materials.

5. Describes the methods of providing overhead protection for associates who may be in or pass through the work area.

6. Describe the methods AWC will inform contractors of this program.

7. Describes the method for prompt, safe removal of injured workers from the jobsite.

We will be continually reviewing the Fall Protection Program to ensure its effectiveness. We know we can count on your full cooperation in the successful promotion of this program.

Identification of Fall Hazards Fall hazards in the work area are located at the edge of the roofline, working on ladders, railcars, and Mezzanine.

Method of fall arrest or fall restraint to be provided:

1. If working over a roofline, an American National Standard (ANSI) Class III full body harness with a shock absorbing lanyard will be used as a fall restraint. Only one shock absorbing lanyard may be used with a Class III full body harness.

2. While working on a ladder or in railcars, harnesses and lanyard will not be required.

3. Harnesses must have an ANSI tag, including the name of the manufacturer and date (anything over 5 years old must not be used).

Assembly, maintenance, inspection and disassembly of the fall protective system to be used:

1. Fall Arrest equipment including Class III full body harnesses, shock absorbing lanyards and all rigging devices will be inspected by the associate using the equipment prior to the commencement of operations (See section entitled "Fall Protection Equipment Inspection & Maintenance Procedures).

2. Any defective equipment will be taken to the supervisor for further evaluation and turned in for repair or destroyed as appropriate.

3. Raised platforms are built into the machinery and comply with all government requirements for fall protection.

Correct procedures for handling, storage and securing of tools and materials:

1. All fall protection equipment must be stored in the maintenance department. Fall protection equipment will be picked up from the maintenance department by the using associate, inspected and returned to the maintenance department after the work or shift is over. Associates will immediately advise the supervisor if any damage to the equipment has occurred.

Section 6 Page 33

Revised: 02.2018 Doc ID: CORSAF.118

2. Tools will be secured as follows:

A. Tool belts will be used to carry hand tools to the elevated work surface.

B. Tools too large for the tool-belt will either be hand carried or raised by rope, pulley or handed up by another worker to the elevated work surface if the work surface is more than six feet above the floor.

C. When working at or over the edge of the roofline, and/or platform where there may be danger to other workers or the general public from falling of dropped tools or material, the tool or the material must be secured to prevent them from falling to lower elevations.

D. Large tools, such as skill-saws, will be secured to guardrails when these tools are used on scaffolding platforms.

Method of providing overhead protection for anyone who may be in or pass through, the area below the work area.

Warning signs or tapes must be used at ground level when there may be a possibility that associates, other workers, or the general public may be in or pass through, the area below in the hoisting or work area.

Method of prompt, safe removal of injured workers:

1. If an associate is injured, evaluation of the condition will be made by the supervisor.

2. If the injured worker's condition appears to be serious or if professional help is needed (fire department rescue or paramedic), the supervisor or a designated person will call and request immediate assistance.

3. Supervisor will conduct an accident investigation as soon as possible and provide appropriate action to prevent reoccurrence of the accident. Should the accident involve the failure of any fall protection device, or equipment, the supervisor will immediately remove the damaged equipment from service and retain the equipment in the supervisor's possession until further evaluation of the equipment can be done.

Supervisors will conduct all fall protection training:

1. New associates will be oriented to the AWC Fall Protection Program as part of the new associate orientation program.

2. All maintenance associates will be trained in the Fall Protection Program on an annual basis.

3. Maintenance associates will sign off on all safety training related to fall protection.

4. Any associate who has not received appropriate training in the AWC Fall Protection Program will not be allowed to work above grade level until the associate has been trained and understands the program.

5. The Fall Protection Program is based on published standards concerning this matter. These standards are considered to be a minimum program and the AWC Fall Protection Program has been designed to exceed the minimum.

Outside Contractors A designated AWC associate will review the AWC Fall Protection Program with the contractor(s) prior to performing work involving a potential fall hazard as defined by this program (Identification of Fall Hazards in the Work Area) and/or related to the contractor's work. The contractor and their associates designated to perform work must show competence in (e.g. documented training, etc.) using fall protection devices. (AWC designated associate) will also inform contractors of any applicable safety rules and

Section 6 Page 34

Revised: 02.2018 Doc ID: CORSAF.118

provisions of the emergency action plan. The contract employer will assure that each of their associates follow all applicable work practices and safety rules.

Fall Protection Equipment Inspection & Maintenance Procedures

Harness Inspection

Harnesses are made to perform to standards set by the Occupational Safety and Health Administration (OSHA) and the American National Standard Institute (ANSI). The standards provide for strength, durability, and dependability while satisfying a wide range of job requirements.

To maintain service life-approximately five years of service-all harnesses should be inspected frequently.

Fall protection equipment must be inspected daily and replaced immediately if any of the defective conditions explained below are found during routine inspection.

Inspection Procedures

Beginning at one end, holding the body side of the harness toward you, grasp one area of the harness with your hands six to eight inches apart. Bend the strap in an inverted "U". The surface tension resulting makes damaged fibers or cuts easier to see.

Follow this procedure the entire length of the harness. Watch for frayed edges, broken fibers, pulled stitches, cuts or chemical damage.

Special attention should be given to the attachment of buckles and Dee Rings to webbing. Note any unusual wear, frayed or cut fibers, or distortion of the buckles or dee rings.

Inspect for frayed or broken strands. Broken webbing strands generally appear as tufts on the webbing surface. Any broken, cut, or burned stitches will be readily seen.

Rivets should be tight and unmovable with fingers. Body side rivet base and outside rivet burr should be flat against the material. Bent rivets will fail under stress.

Especially note condition of Dee Ring rivets and Dee Ring metal wear pads (if any). Discolored, pitted, or cracked rivets indicate chemical corrosion.

The tongue or billet of bolts receives heavy wear from repeated buckling and unbuckling. Inspect for loose, distorted, or broken grommets. Harnesses using punched holes without grommets should be checked for torn or elongated holes causing slippage of the tongue buckle.

­ Tongue Buckle: Buckle tongues should be free of distortion in shape and motion. They should overlap the buckle frame and move freely back and forth in their socket. Roller should turn freely on frame. Check for distortion or sharp edges.

­ Friction Buckle: Inspect the buckle for distortion. The outer bars and center bars must be straight. Pay special attention to corners and attachment points of the center bar.

­ Sliding Bar Buckle: Inspect buckle frame and sliding bar for cracks, distortion, or sharp edges. The sliding bar should move freely. Knurled edge will slip if worn smooth. Pay special attention to corners and ends of sliding bar.

Section 6 Page 35

Revised: 02.2018 Doc ID: CORSAF.118

­ Dee Ring: Inspect closely the forged steel Dee Ring for cracks or other defects. Inspect the assembly of the Dee Ring to the body pad or Dee saddle. If the Dee Ring can be moved vertically independent of the body pad or Dee saddle, the harness should be replaced.

­ Waist Strap: Inspect assembly of buckle to waist strap. Check threads closely and tongue buckle holes for excessive elongation. Check waist strap for cuts or other deteriorating conditions. Never cut or punch additional holes in waist strap or strength members.

A close inspection should be given to tool loops and belt sewing because broken or stretched loops can drop tools. Check bag rings and knife snaps to see that they are secure and working properly and check tool loop rivets. Make sure tools are not adversely affecting the waist strap. Check for thread separation or rotting both inside and outside of body pad belt.

Inch-by-inch visual inspection for fiber laceration or stitch damage is done by flexing the strap in an inverted "U". Not cuts, frayed areas, or corrosive damage.

Straps with friction buckles should be checked for slippage and sharp buckle edges. Those equipped with tongue buckle holes should be examined for excessive wear or elongation of the hole.

Snap hooks should be checked for distortion of hook or frame attachment to belt. Cracks, corrosion or pitted surfaces indicate an unsafe condition. The keeper (latch) should seat into snap nose without binding or obstruction and the keeper spring should have sufficient force to close the keeper firmly. All rivets should be tight, free of wear or distortion, and without cracks, sharp edges or corrosion.

Lanyard and Hardware Inspection

When inspecting lanyards, begin at one end and work to the opposite end. Slowly rotate the lanyard so the entire circumference is checked. Spliced ends require particular attention. Hardware should be examined under procedures also detailed below:

Steel: While rotating the steel lanyard watch for cuts, frayed areas, or unusual wearing patterns on the wire. Broken strands will separate from the body of the lanyard.

Webbing: While bending webbing over a pile or mandrel, observe each side of the webbed lanyard. This will reveal any cuts or breaks. Swelling, discoloration, cracks, and charring are obvious signs of chemical or heat damage. Observe closely for any breaks in the stitching.

Rope: Rotation of the rope lanyard while inspecting from end to end will bring to light any fuzzy, worn, broken, or cut fibers. Weakened areas from extreme loads will appear as a noticeable change in original diameter. The rope diameter should be uniform throughout, following a short break-in-period. Strands should be separated and inspected since the rope may wear on the inside if grit or moisture becomes embedded.

Snaps: Inspect closely for hook and eve distortions, cracks, corrosion, or pitted surfaces. The keeper (latch) should seal into the nose without binding and should not be distorted or obstructed. The keeper spring should exert sufficient force to firmly close the keeper

Dee Rings: Check Dee Rings and Dee Ring metal wear pad (if any) for distortion, cracks, breaks, and rough or sharp edges. The Dee Ring bar should be at a 90 degree angle with the long axis of the belt and should pivot freely.

Section 6 Page 36

Revised: 02.2018 Doc ID: CORSAF.118

Thimbles: The thimble must be unmovable in the eyes of the splice, and the splice should have no loose or cut strands. The edges must be free of sharp edges, distortion, or cracks.

Cleaning: Basic care of all fall protection equipment will prolong the durable life of the unit and contribute toward its performance. Proper storage and maintenance after use is as important as cleansing the equipment of dirt, corrosive& or contaminants. Storage areas should be clean, dry, and free of exposure to fumes or corrosive elements.

­ Wipe off all surface dirt with a sponge dampened in plain water Squeeze the sponge dry Dip the sponge in a mild solution of water and commercial soap or detergent. Work up a thick lather with a vigorous back and forth motion.

­ Wipe the belt dry with a clean cloth. Hang freely to dry but away from excessive heat.

­ Bolts and other equipment should dry thoroughly without close exposure to heat, steam, or long periods of sunlight.

­ Mildly dirty cotton may be cleaned like nylon. For heavy dirt or grease, soak belts in a solution of one tablespoon of grease cutter to one gallon of water. Do not use a stronger solution.

­ After soaking, rinse again, then hang to dry.

Confined Space Entry A confined space is an enclosed area with limited space and accessibility. An example is the interior of a storage tank, pit, or manhole, which may be occasionally entered by workers for maintenance but is otherwise not a habitable space.

At no time is any AWC associate or manager allowed to enter a confined space for any reason.

Hazardous Work Permit for Hot Work A permit is necessary because either the nature of the job or use of hazardous chemicals indicate special precautions must be taken to ensure the work is performed safely.

A permit is required for the following jobs:

1. Maintenance welding in locations outside the shop near hazards (e.g. near chemical storage, combustibles, etc.).

2. Non-Routine operations with unique hazards.

Permit System A permit system is required for the following AWC associate activities:

1. Checklist to ensure proper preparation of the work area.

2. Expiration time and date which prevents the permit from being used through a change of shift.

3. The signature of the responsible supervisor and associates who will perform the work.

Section 7 Page 37

Revised: 02.2018 Doc ID: CORSAF.118

Lockout/Tagout Program Auto Warehousing Company established the lockout/tagout program to provide maximum safety protection to our associates whenever they must service or perform maintenance on company machinery and equipment. These procedures must be used by all associates authorized to service or maintain our equipment to ensure that machines or equipment are completely isolated from all potentially hazardous energy sources. All associates affected in any way by servicing and maintenance activities must also be knowledgeable of lockout/tagout procedures.

These procedures must be followed whenever unexpected energization, start-up or release of stored energy could cause injury. These procedures do not apply when servicing or maintenance of equipment is dining normal production operations unless:

1. Guards, or other safety devices, must be removed or bypassed: or

2. An associate places himself/herself in an area where work on materials, etc. is actually

being performed (e.g. inside wash line): or

3. An associate places himself/herself in any area considered dangerous during the normal

operating cycle (e.g. inside wash line).

The manufacturer's instructions will be followed or if none exist specific operating procedures will be written for equipment considered potentially hazardous from energy sources. (Energy sources to include: electrical, pneumatic, steam, hydraulic. pressurized fluids/gases, mechanical, gravity, chemical and radiation.)

All supervisors are responsible and accountable for the use of safe lockout/tagout procedures by all associates under their supervision. Compliance with lockout/tagout procedures is mandatory. Non-compliance with these procedures is considered a violation of an associate’s condition of employment and will result in the initiation of progressive disciplinary procedures including termination.

Associates, who are properly trained on equipment maintenance and lockout/tagout procedures, and approved by the Terminal Manager, are authorized to implement lockout/tagout procedures as appropriate.

Lockout/Tagout Procedures

Preparation for Lockout Prior to lockout, the authorized associate(s) will review the manufactures instructions, or the specific lockout procedures for each machine or piece of equipment.

1. Types and magnitudes of energy.

2. Hazards posed by that energy.

3. Methods to effectively control the energy.

Particularly close attention must be given to energies (such as gravity, electrical. high pressure) that can be stored or re-accumulated after shutdown.

Prior to shut down all affected associates will be notified to clear their work area and/or any other area that might be hazardous due to the shutdown.

Lockout/Tagout

1. Shutdown: Machinery and equipment will be shut down in an orderly manner using the shutdown procedures. If more than one authorized associate is involved in shutdown, the maintenance team leader will make sure everyone has accomplished their tasks and are aware that shutdown will occur. The team leader will insure that everyone is clear and no shortcuts are taken.

Section 7 Page 38

Revised: 02.2018 Doc ID: CORSAF.118

2. Isolation: All energy isolation devices will be located and operated to completely de-energize and isolate the equipment. The authorized associate, or team leader will verify operation of each energy isolation device.

3. Applying Lockout/Tagout Devices:

A. Lockout devices will be used to secure energy isolating devices unless the machinery or equipment is not capable of being locked out. Only authorized associates will affix lockout/tagout devices. Lockout devices must be able to hold energy isolation devices in a "safe" or "off' position.

B. Tagout devices will be used only if machinery or equipment is not capable of being locked out Tags will clearly state that removing energy isolating devices from the "safe" or "off' position is strictly prohibited. If the tag cannot be affixed to the energy isolating device, it will be located as close as safely possible to the device so that the tag is obvious to anyone attempting to operate the device.

C. Lockout/Tagout Materials and Hardware: Lockout/Tagout devices will be furnished by the company and located in the proximity of the equipment needing them and/or in the maintenance department, depending on the nature of the device required.

Lockout devices will have the following characteristics:

1. Capable of withstanding harsh environments.

2. Standardized within the facility. Same color, shape, size. etc.

3. Cannot be removed without excessive force.

4. Singularly identify the user.

5. Uniquely keyed.

Tagout devices will have the following characteristics:

1. Non-reusable.

2. Attachable by hand.

3. Self-locking.

4. Non-releasable with not less than 50 lb. locking strength.

5. Design/characteristics at least equivalent to a one-piece, all environment-tolerant nylon cable tie.

Stored Energy: Immediately after applying lockout or tagout devices, the authorized associate will ensure all potentially hazardous stored or residual energy is relieved, disconnected, restrained, and otherwise rendered safe.

If stored energy can be re-accumulated, the authorized associate will verify that the energy is isolated until maintenance is complete or the energy no longer exists.

Verification of Isolation: Before starting work on a machine or equipment that is locked or tagged out, the authorized associate will verify that the machinery or equipment is actually isolated and de-energized.

Release from Lockout or Tagout

The authorized associate will follow the procedures below prior to removing lockout or tagout devices and restoring energy:

Equipment. Make sure machinery or equipment is properly reassembled. Inspect machinery or equipment to make sure nonessential items have been removed.

Section 7 Page 39

Revised: 02.2018 Doc ID: CORSAF.118

Associates. Make sure all associates are safely positioned outside danger zones. Notify affected associates that lockout/tagout devices have been removed and that energy is going to be reapplied.

Removing lockout/tagout devices. Only the authorized associate who applied the lockout/tagout device may remove that device. Exception. When the authorized associate is not at the facility and all reasonable efforts have been made to inform him/her that his/her lockout tagout device has been removed:

­ His supervisor is authorized and will remove the device following procedures in this section.

­ Each maintenance supervisor will be trained in proper lockout/tagout procedures.

­ The supervisor will ensure the authorized associate has this knowledge before he/she resumes work.

Testing/Positioning Machines or Equipment. Whenever lockout/tagout devices are removed to test or position machines and equipment, or their components, the authorized associate will complete the following procedures in the sequence presented:

­ Clear the machine or equipment of tools and materials.

­ Make sure all associates are away from danger zones.

­ The authorized associate will remove the lockout/tagout device.

­ Energize and proceed testing or positioning.

­ De-energize all systems and reapply lockout/tagout devices following sequence for initial lockout/tagout.

Outside Personnel (Contractors, etc.)

­ Outside servicing personnel contracted to perform maintenance or other services covered by these lockout/tagout procedures, will not begin work until the maintenance supervisor is satisfied that their lockout/tagout procedures arc at least equivalent to company procedures.

­ The maintenance supervisor will also ensure company associates understand and comply with contracted personnel lockout/tagout procedures.

Shift/Personnel Changes: When a shift change occurs the following lockout/tagout procedures will be followed:

­ The off-going maintenance supervisor will attach a lockout/tagout device at each required location;

­ The off-going authorized associate(s) will detach lockout/tagout devices:

­ The on-coming authorized associates(s) will receive a comprehensive briefing on the maintenance being performed;

­ The oncoming authorized associate(s) will attach lockout/tagout devices and verify complete isolation: and

­ The off-going supervisor will detach his/her lockout/tagout device.

Electrical Lockout/Tagout Procedures The purpose of this program is to provide protection to all associates while working on electrical and electrically driven equipment. The lockout/tagout procedure has been divided into two types: A (fixed) and B (portable).

Section 7 Page 40

Revised: 02.2018 Doc ID: CORSAF.118

Type "A" Lockout/Tagout

1. Relocating electrically powered or heated equipment not wired for portability.

2. Replacing or removing drive belts.

3. Freeing or adjusting a parts and guards.

4. Changing centrifugal pumps.

5. Freeing or changing parts.

6. Making adjustments where it is necessary to run the equipment between adjustments to determine accuracy.

7. Lights and switches

8. All fixed power equipment

9. Lube/grease moving parts

Action before commencing work:

1. It is the responsibility of the department supervisor to stop the equipment.

2. Each person who is going to work on the equipment must install a padlock on the local disconnect switch or plug end so that it will be mechanically restricted from operating (in the case of pad locking an electrical cord plug end, a lock box will also be used). Then verify that all potential stored energy sources are lockout before proceeding with the work. (e.g. attempting to start-stop)

3. Also, attach a red "WARNING" tag to the padlock. The tag is to be signed on the backside by the person or persons working on the equipment.

When the work is completed, the procedure to follow will be.

1. Each worker will notify the department supervisor that the job is completed.

2. Each worker will then remove their padlock.

3. The department supervisor will then verify that the work is completed and remove and destroy the tag.

Type "B" Lockout/Tagout Maintenance work on portable equipment (Often 110-volt power):

1. Office machines, clearing jams, changing or adjusting parts.

2. Power tools.

3. All movable power equipment.

4. All power hand tools.

Action before commencing work.

1. Turn off the electrical equipment and then unplug it.

2. Place the plug immediately adjacent to the equipment being worked on so there will be no confusion as to whether or not the equipment being serviced is unplugged.

3. The end of the electrical cord is to then be padlocked with a lock box.

4. A red "WARNING" tag is then attached to the padlock that is securing the lock box.

5. The person working on the equipment is to then also sign their name on the backside of the tag.

Section 7 Page 41

Revised: 02.2018 Doc ID: CORSAF.118

When the work is completed, the procedure to follow will be.

1. Each worker will notify the department supervisor that the work is completed.

2. The worker will then remove their padlock and the lock box.

3. The department supervisor will then verify that the work is completed and remove and destroy the tag.

Additional Lockout/Tagout Precautions

1. If the person who has the equipment locked out is on the terminal site, they must personally remove the lock.

2. If they have left the terminal site, an effort to contact the person must be made, for purposes of asking for permission to remove the lock.

3. If the person who has locked out the equipment cannot be contacted, than their supervisor and a qualified associate must be contacted to review and observe the situation in order to determine whether or not the equipment that is tagged and locked out is safe to operate.

4. When changing shift procedure Sec. 6e, II, 7 will be followed.

5. No person is to touch any equipment that is tagged or pad locked, unless authorized to do so.

Training Training in lockout/tagout will be provided to all associates who may be in an area where energy control procedures are used. This training will make sure that the purpose and function of the energy control program are understood and that associates gain the needed knowledge and skills to safely apply, use, and remove energy controls.

1. Authorized associates will be able to recognize hazardous energy sources, type and magnitude of energy in the workplace, and methods and means necessary to isolate and control the energy.

2. Affected associates will be able to recognize purpose and use of the energy control procedures.

3. Other associates will be able to recognize procedures and prohibitions of the energy control program.

Tagout Devices Further training on tagout systems need to emphasize that:

1. Tags are warning devices only and do not provide a physical restraint that lockout devices provide.

2. Tags must not be removed without the authorized associates’ approval and should never be bypassed, ignored, or otherwise defeated.

3. Tags must be legible, and understandable to all associates.

4. Tags must be able to withstand the environmental conditions of the workplace.

5. Tags must not give associates a false sense of security.

6. Tags must be securely attached to prevent being accidentally detached during use.

Retraining Associates will be retrained at the following times:

1. Initial Assignment.

Section 7 Page 42

Revised: 02.2018 Doc ID: CORSAF.118

2. Change in job assignment

3. Change in machinery or equipment.

4. Change in operating procedures.

5. Annually

Inspections

1. Annual inspections on lockout/tagout procedures will be conducted by an authorized associate other than the one(s) using the energy control procedures being inspected.

2. The purpose of the inspection is to correct any deviations or inadequacies in the procedure.

3. The inspector and authorized associate must review responsibilities under the energy control procedures.

4. The maintenance supervisor will certify that the inspection was conducted. Elements of the certification include:

A. Identification of equipment or machinery.

B. Date of inspection.

C. Associates included in the inspection.

D. Person performing inspection.

Section 8 Page 43

Revised: 02.2018 Doc ID: CORSAF.118

Bloodborne Pathogens Auto Warehousing Company is committed to the prevention of incidents or happenings which result in associate injury and illness; and to complying with the OSHA Bloodborne Pathogens Standard. Through this written exposure control plan, share responsibility to ensure performance under that responsibility; and hereby adopt this exposure control plan as an element of the Safety and Health Program.

The purpose of this exposure control plan is to:

1. Eliminate or minimize associate occupational exposure to human blood or other body

fluids;

2. Identify associates occupationally exposed to blood or other potentially infectious

materials (OPIM) while performing their regular job duties;

3. To provide associates exposed to blood and OPIM information and training. A copy of this

plan is available to all associates during normal work hours in the office Safety Manual.

4. To comply with the OSHA Bloodborne Pathogen Standard.

Exposure Determination Blood borne Pathogens are pathogenic microorganisms that are present in human blood and can cause disease in humans. These pathogens include, but are not limited to, hepatitis B virus (HBV) and human immunodeficiency virus (HIV). Occupational exposure means reasonably anticipated skin, mucous membrane or parenteral contact with bodily or other potentially infectious materials that may result from performance of an associate’s duties.

Auto Warehousing Company has performed an exposure determination for all common job classifications which may be expected to incur occupational exposures to blood or OPIM. This exposure determination is made without regard to the use of Personal Protective Equipment (PPE). The following is a list of those job classifications in this category:

Who at Auto Warehousing Company is at risk?

1. CPR CERTIFIED (Designated First Responders)

2. 1ST AID CERTIFIED (Designated First Responders)

3. Janitorial Staff

Tasks/Procedures in which occupational exposure occurs:

1. Performing rescue breathing

2. Exposure to blood while dressing an injury

3. Puncture wound when removing foreign body

4. Handling a contaminated specimen container

5. Irrigating wounds

6. Cleaning up spill or incident that involved glass or other material contaminated with blood or other human body fluid

A Hepatitis B Vaccination Status Record is filled out by the Terminal Manger listing associates at the facility who are at risk because of their job responsibilities. Whether or not an associate has the vaccination, their name is listed, and the record is kept on file at the facility.

Section 8 Page 44

Revised: 02.2018 Doc ID: CORSAF.118

Method of Compliance Universal precautions shall be observed to prevent contact with blood and potentially infectious materials. All blood and human body fluids are to be treated as if known to be infectious.

Engineering/Work Practice Controls

1. Hand washing facilities are available.

2. Associates are to wash hands immediately after removal of gloves and/or other personal protective equipment.

3. Associates shall wash hands and any other skin with soap and water or flush mucous membranes with water immediately or as soon as feasible following contact with blood or other potentially infectious materials.

A. Food and drink shall not be kept in the first aid/medical care cabinets.

B. Associates shall remove garments immediately or as soon as possible when they are penetrated by blood or OPIM.

Personal Protective Equipment (PPE)

1. Disposable (single use) gloves shall be worn when it is reasonably anticipated that the associate may have contact with blood or other bodily fluids.

2. Mask and eye goggles are to be worn whenever blood or bodily fluid spray or droplets may be generated and eye, nose, or mouth contamination can be reasonably anticipated.

Housekeeping

1. All equipment, environmental and working surfaces shall be cleaned and decontaminated after contact with blood or other potentially infectious materials.

2. Contaminated work surfaces shall be decontaminated with bleach 1:100 solution or 70% isopropyl alcohol after completion of procedure.

3. Trash cans and similar receptacles shall be inspected and cleaned of blood or other potentially infectious materials immediately.

4. Any broken glass that may be contaminated shall not be picked up directly with the hands. It shall be cleaned up using a brush and dust pan. It shall then be disposed of in an appropriate disposal container.

5. Contaminated instruments shall be washed in soap and water and soaked in Wavicide-01 full strength for 10 hours.

6. Puddles of blood or human body fluids are to be treated with a solidifier, picked up using gloves and a scoop and placed in a plastic bag.

7. Materials contaminated with blood (dressings, gloves, disposable PPE clothing) are to be bagged in plastic then placed in specifically marked infectious waste disposal bags.

A. For information on where to place properly marked bags and who is responsible for the disposal arrangements see the facility’s Bloodborne Pathogens (BBP) Disposal Instructions located near/in every Bloodborne Pathogens kit.

Hepatitis B (HBV) Vaccination Vaccination for the hepatitis B virus (HBV) shall be made available at no cost to all associates covered under the exposure control plan after the associate has received the required training and within 10 working days of initial job assignment. Associates that have previously received the vaccination series who have antibody testing that revealed they are immune to HBV or the

Section 8 Page 45

Revised: 02.2018 Doc ID: CORSAF.118

vaccine is contraindicated for medical reasons are not expected to have the vaccination series. The Terminal Manager is in charge of the HBV vaccination program.

The Terminal Manager will ensure that all medical evaluations and procedures including the HBV vaccine and vaccination series and post exposure follow-up, including prophylaxis are:

1. Made available at no charge to the associate, at a reasonable place and time.

2. Performed or supervised by a licensed healthcare professional according to the recommendations of the CDC.

Vaccination Records and Forms When an associate has an exposure incident, it must be reported to the Terminal Manager.

When the associate goes to the medical facility for the vaccination, they must take a form to be signed by the professional administering the vaccination, showing the series of three vaccinations. This form is returned to the Terminal Manager and is filed in a separate medical file at the facility.6

Vaccination Decline If the associate initially declines the Hepatitis B vaccination but at a later date while still covered under the standard decides to accept the vaccination, the employer shall make available the Hepatitis B vaccination at that time.

Participation in a prescreening program is not a prerequisite for receiving Hepatitis B vaccination.

Associates that decline to accept the Hepatitis B vaccination offered by Auto Warehousing Company shall indicate their declination on the Hepatitis B Vaccination form.

Booster Shots If a routine booster dose(s) of Hepatitis B vaccine is recommended by the U.S. Public Health Service at a future date, such booster dose(s) shall be made available at no charge to those covered under the exposure determination of this policy at that time.

Post Exposure Evaluation and Follow Up

1. Any exposure must be reported to your supervisor immediately.

2. Proper first aid care is to be followed. If the injury requires medical attention, normal referral to a physician is to be followed. (To Occupational Clinic during normal business hours and to the Hospital Emergency Department at all other times).

3. Upon completion of the Blood and Bodily Fluid Incident Exposure Report, the manager will counsel the exposed associate and direct them to proper medical evaluation and follow up at no cost to the associate.

The Following Forms are to be completed:

1. Blood or Bodily Fluid Exposure Report (Attach to the 601 Injury Report for the BBP Exposure).

2. If associate is seen by physician for treatment of injury and/or treatment or counseling for exposure, a 601 Injury Report is to be filled out and submitted.

3. First report of injury.

Information to be provided to the Associate's Healthcare Provider:

6 Medical records are confidential and may be accessed only by qualified medical or legal personnel.

Section 8 Page 46

Revised: 02.2018 Doc ID: CORSAF.118

1. A copy of the Federal Bloodborne Pathogens Standard and any state/provincial Bloodborne Pathogens Standards.

2. A description of the exposed associate's duties as they relate to the exposure incident.

3. Documentation of the route(s) of exposure and circumstances under which exposure occurred.

4. Results of the source individual's blood testing if available.

5. All medical records7 relevant to the appropriate treatment of the associate including vaccination status.

Healthcare Professional's Written Opinion

1. Manager shall obtain and provide the associate with a copy of the evaluating professional's written opinion within 15 days of the completion of the evaluation.

2. The healthcare professional's written opinion for HBV vaccination will be limited to whether HBV is indicated for an associate, and if the associate has received such vaccination.

Information and Training All infectious waste materials will be in marked containers or plastic bags specifically marked infectious waste.

Response Team Members will receive training within 90 days of the effective date of the standard. Thereafter, all those covered will receive training initially upon assignment or acceptance on the Emergency Response Team and annually thereafter.

Training records shall be maintained for three years from the date on which the training occurred and shall include the following:

1. Dates of the training sessions.

2. Contents or summary of the training session.

3. Names and qualifications of the person(s) conducting the training.

4. Names and job titles of all persons attending the training session.

Record Keeping The confidential medical record on each associate with occupation exposure will be retained by the LOCAL FACILITY for the duration of employment plus 30 years.

Evaluation and Review Corporate Safety is responsible for annual or as needed review of this program and its effectiveness and for updating as needed.

7 Medical records are confidential and may be accessed only by qualified medical or legal personnel.

Section 9 Page 47

Revised: 02.2018 Doc ID: CORSAF.118

Emergency Response Plan Major disasters must be anticipated and procedures must be developed and mastered if the well-being of our associates is to be protected and if we are to be ready to serve our community. Examples of emergencies that can happen in our work facility include chemical spills, fires, explosions, and personal injury, tornadoes, earthquakes, etc.

The effectiveness of response during emergencies depends on the amount of planning and training performed. Remember, your conduct and actions in the first few minutes of an emergency may not only save your life, but the lives of your co-workers and other members of the community. It is the Terminal Manager's responsibility to see that this program is frequently reviewed and updated. The input and support of all associates is requested to ensure an effective program.

Evaluate facility potential hazards and injury types and have the appropriate First Aid supplies available in a quantity sufficient for the number of associates at the facility. The supplies must be readily accessible for all shifts and include directions for requesting emergency assistance.

Evacuation Maps Evacuation Maps (See: Evacuation Maps) will be posted in conspicuous places throughout the building to assist if there is an emergency. The maps will have:

1. Arrows pointing to exits,

2. Red Crosses depicting the location of first aid kits

3. Fire extinguisher icons indicating the location of fire extinguishers,

4. Eye wash icons indicating where emergency showers/eye wash stands are located.

5. The emergency medical assistance/ambulance phone number will be written out. (E.g. push 9 and then 911).

6. In case of a building evacuation the location that associates are to meet will be written out

First Aid & Emergency Medical Services

1. Consult the facility’s Emergency Response Plan

2. Consult the facility’s Emergency Contact List

3. Review the First Aid & Emergency Medical Services signage posted at the facility

Responsibilities

Terminal and Human Resource Manager

1. Facilitate the Emergency Response Plans, be knowledgeable of the Emergency Preparedness Manual, and ensure that all Emergency Preparedness signage is posted at the facility.

2. Keep constant check on all personnel to confirm that they are completely familiar with all phases of the plan which they are required to know.

3. See that all personnel participate in all fire, tornado, or other practice drills.

4. Correct any deficiencies noted on the Evacuation Record form.

5. Establish a command post to coordinate activities after the disaster.

6. Act as liaison with Emergency Service Personnel and media

Section 9 Page 48

Revised: 02.2018 Doc ID: CORSAF.118

Operations Managers/Designated Safety Representative

1. Coordinate the Emergency Response Plans throughout the facility.

2. Ensure new associates are oriented promptly and the plans are familiar to all associates.

3. Arrange and execute practice drills within the facility.

4. Stay with their associates and act as liaison with the command post.

5. Assist the Terminal and Human Resource Managers in coordinating efforts to reestablish normal operations after the disaster.

Associates

1. Be completely familiar with the Emergency Response Plans, Emergency Preparedness Posters, and what is expected of associates.

2. Participate in all practice drills.

3. The location and how to use fire extinguisher.

A. Associates are to only use fire extinguisher in life threatening situations where a fire extinguisher providers the associate a safe evacuation route.

4. Report all fire and/or safety hazards located on the company's premises.

Salvage Operations

1. Will begin as soon as the emergency is over. Temporary storage/office facilities will be arranged if required.

2. Associates will be used as much as possible to restore the area to normal.

Communications Plan During a major emergency involving a fire or explosion it may be necessary' to evacuate all areas of the facility. Also, normal services, such as electricity, water, and telephones may be nonexistent. Under these conditions it is necessary to have an alternate area where associates can report or that can act as a focal point for incoming and outgoing calls.

1. The Terminal Manager will designate a Point of Contact and/or an associate to contact the following if necessary:

A. The company insurance agent,

B. Customers and associates.

C. Other AWC facilities if it affects their operations.

D. Companies for debris removal, and other salvage or repair operations.

2. A designated person will also be appointed as a liaison with the news media if any arrive on the scene or call for information.

3. A designated person will video tape and take pictures of major events for an accurate record of what happened.

Training Requirements Training is important to the effectiveness of an emergency plan. All associates will be trained on emergency plans at their initial orientation and annually thereafter. It will cover actions to be taken in the event of fire, earthquake, explosion, chemical spill, building evacuation, or other disaster as outlined in the facility’s Emergency Response Plan and Emergency Preparedness Manual training.

Section 9 Page 49

Revised: 02.2018 Doc ID: CORSAF.118

1. First Aid and CPR will be offered to all associates based on facility size. The workers qualified in First Aid/CPR will be listed on the bulletin boards in the work areas for quick reference. A listing will also be available in the facility’s Emergency Response Plan.

A. These lists will be reviewed and updated annually.

2. All personnel will receive training during orientation and refresher training annually in the proper procedures to follow in the case of fire, earthquake, explosion, chemical spill, building evacuation, etc.

Emergency Response Team This training is for those individuals appointed to the team or as fire marshals. In the event of a disaster, these individuals will have the responsibility to direct the evacuation of associates in certain areas of the facility, and to aid the Emergency Response process. Training will cover:

1. Evacuation Procedures

2. Firefighting techniques for life threatening evacuation routes only

3. Notification of Emergency Medical Services (EMS) (911)

4. Basic first aid

5. CPR

6. AED (if site has one)

7. Emergency Preparedness Manual

8. Emergency Response Plan

Eye Wash and Shower Where the eyes or body of any associate may be exposed to injurious or corrosive materials eye washes or suitable equipment for quick drenching or flushing will be provided in the work area for immediate emergency use.

AWC associates will be informed as to the purpose and location of the eye wash/deluge shower facilities. The maintenance and function of these units will be checked weekly/monthly by the supervisors or his/her representative. (See: Facility Inspection)

Facility Alarm System

1. Smoke detectors are installed and should sound in their areas in case of fire.

2. To notify on a company wide basis the following alarm system will be used. A Companywide alarm will be sounded (See: Emergency Preparedness Manual)

Incident Plan Medical emergencies, both minor and critical, occur every day and can happen in any workplace. Since time is a critical factor in many medical emergencies, the first person to arrive at the scene of an accident has a key role in the rescue of a victim. With a knowledge of some common medical procedures and emergency actions this "first responder can make a positive contribution to the welfare of the accident victim. In some cases, this contribution can make a difference between life and death.

Upon order of management or other person(s) in charge to totally evacuate the facility, the following action will be taken:

1. See: Emergency Response Plan and Emergency Preparedness Manual

Procedure for Medical Emergency

1. Evaluate the condition of the injured.

Section 9 Page 50

Revised: 02.2018 Doc ID: CORSAF.118

2. Call for assistance.

3. One person stays with the injured person and the other goes for the first aid kit, notifies a supervisor who will call for professional help if necessary.

4. Keep the injured person quiet, give reassurance, and perform any immediate first aid that is required to stabilize the person until the ambulance arrives.

5. Manager or designated supervisor will take charge of the scene and immediately start an accident investigation.

6. The emergency number for ambulance, doctor, fire department, and police assistance is 911.

7. For non-emergencies associates should seek treatment from our local Industrial Clinic. (See: Emergency Contact List)

8. For emergencies tell the ambulance driver your facility’s clinic name.

Earthquake, Fire, Explosion, Chemical Spill/Leak Plan

See: Emergency Preparedness Manual, Emergency Response Plan, and site specific Spill Prevention Plans (SPP)/Spill Prevention, Control, and Countermeasure (SPCC) Plan.

Evacuation Plan

1. The Terminal Manager will decide if a building evacuation is necessary.

A. Will be responsible for seeing that associates are evacuated to a safe area outside the building and clear of overhead electrical lines, utility posts, block walls, etc., which might fall during aftershocks.

B. Be alert for fallen high tension lines which may be touching metal objects on the ground

C. Have all areas of the building inspected for damage before allowing associates to return to the building(s).

D. Have gas, electrical, water, and fuel systems checked for damage before allowing associates to return to building(s).

E. Drinking water should be checked to determine that it is not contaminated.

i. Water contained in toilet tanks can be boiled and used if absolutely necessary for drinking or treating injuries.

2. On the order to evacuate the building all associates will leave promptly in an orderly fashion and meet at the designated evacuation point.

A. If the meeting area is blocked proceed to the nearest open exit.

3. On reaching the designated evacuation point:

A. Wait there until further instructions are given.

B. All associates will report to their supervisor.

C. All supervisors

i. Will take an immediate headcount of all associates working for them

ii. Ensure that all those working for them are present.

iii. Turn the information into the Terminal Manager.

4. The Terminal Manager or designated replacement will give further instructions depending on the nature of the evacuation.

Section 9 Page 51

Revised: 02.2018 Doc ID: CORSAF.118

A. Once the all clear is given follow their instructions.

Other Emergency Plans All additional plans that are required by the state or province the facility is located in should also be included in the facility’s Emergency Response Plan.

Section 10 Page 52

Revised: 02.2018 Doc ID: CORSAF.118

Occupational Ergonomics The policy provides procedures for developing occupational ergonomic programs at all of the AWC facilities. The main goal is to prevent back injuries and cumulative trauma disorders through the institution of an ergonomic program which focuses on the interaction between people and their work, the tools they use, the tasks they perform, and the physical environment in which they perform their jobs.

Definitions

Ergonomics is the study of human characteristics for the appropriate design of the living and working environment. Ergonomics attempts to fit the job to the person.

Ergonomic Risk Factors refer to any workplace conditions that pose a biomechanical stress to the worker. Four factors that account for cumulative trauma disorders (CTDs) are force, repetition, posture, and no rest. Poor workplace conditions such as slippery floors, crowded areas, poor illumination, and excessive heat, cold, or humidity can contribute to CTDs.

Cumulative Trauma Disorders (CTDs) refer to a category of physical signs and symptoms due to chronic musculoskeletal injuries where the causes appear to be related to some aspect of repetitive work. CTDs are a class of musculoskeletal disorders involving damage to the tendons, tendon sheaths, and the related bones, muscles, and nerves of the hands, wrists, elbows, shoulders, neck, and back. The more frequent types of CTDs include low back pain, carpal tunnel syndrome, epicondylitis (tennis elbow), tendonitis, and tenosynovitis.

A cycle is a time interval during which a regularly recurring sequence of events is completed. It can be the time to complete a task with many elements or the time to complete a single operation in a repetitive task.

Summary of Ergonomic Program Elements The goal of an effective ergonomics program is to prevent illnesses and injuries by eliminating ergonomic risk factors. To accomplish this goal, the following four major program elements should be included in comprehensive ergonomics programs at AWC facilities.

1. Management Commitment and Associate Involvement

2. Ergonomic Hazard Recognition

3. Training and Education

4. Medical Management

Management Commitment and Associate Involvement The implementation of an effective ergonomics program includes a commitment by AWC to provide the visible involvement of management so that all associates, from management to hourly, fully understand that management has a serious commitment to the program. An effective program should have a team approach, with management serving as a team champion, and should include the following:

1. Affirm that the ergonomics program is an integral part of the company's overall health and safety efforts to prevent injuries and illnesses in the workplace.

2. Implementation of this plan requires management to integrate production processes and safety and health protection to assure that this protection is part of the daily production activity within each facility.

3. Delegate authority and provide resources needed to carry out assigned responsibilities.

4. Solicit questions and encourage associates to voice concerns and complaints.

5. Provide the opportunity for participative involvement in the development and implementation of solutions to ergonomic related problems.

Section 10 Page 53

Revised: 02.2018 Doc ID: CORSAF.118

6. Set-up procedures to encourage associates to report signs and symptoms of cumulative trauma disorders (CTDs) promptly and accurately.

7. Promote ergonomics as part of the overall quality process.

8. Provide a system of positive recognition for individuals making significant contributions to the ergonomics program or to the prevention of ergonomic problems.

Associate Involvement Associates must play an active role in the ergonomic program and in the decisions that affect worker safety. This involvement includes taking responsibility for their own safety and the safety of others by:

1. Participating on ergonomic projects and teams.

2. Training in the recognition of ergonomic hazards and health effects which might be associated with ergonomic stresses.

3. Voicing concerns or complaints which may lead to the early detection of conditions that may lead to ergonomic-related problems.

4. Suggesting solutions to ergonomic hazards and assisting in their implementation.

5. Encouraging prompt and accurate reporting of signs and symptoms of CTDs by associates so that they can be evaluated and, if warranted, treated.

6. Following up on ergonomic improvements which have been mutually agreed upon by management and teams to ensure they have been effectively implemented.

Program Review and Evaluation Procedures should be developed to evaluate the implementation of the ergonomic program and to monitor progress accomplished. Management should review the program regularly - to evaluate success in meeting its goals and objectives.

Evaluation techniques include methods such as the following:

1. Analysis of trends in injury/illness rates.

2. Reduction of workers compensations and other costs related to the injury/illness.

3. Associate surveys.

4. Improvements in product quality and productivity where measurable.

5. Before and after surveys/evaluations of job/worksite changes.

6. Observed improvement in associate work habits and behaviors.

7. Up-to-date records or logs of job improvements tried or implemented.

A periodic review by management is suggested.

Ergonomic Hazard Recognition

Worksite Analysis Every Job Safety Analysis (JSA) should include a systematic search for potential hazards which might be associated with ergonomic-related injuries and illnesses. The ergonomic hazard analysis may be conducted as a routine part of an overall JSA, or a specific job may be studied because of an increased incidence or perceived risk factors.

An ergonomic hazard recognition program identifies existing hazards and conditions, operations that create hazards, and areas where hazards may develop. This also includes scrutiny and tracking of injury and illness records to identify patterns of trauma or strains that may indicate the development of CTDs.

Section 10 Page 54

Revised: 02.2018 Doc ID: CORSAF.118

The objectives of worksite analysis are to recognize, identify, and correct ergonomic hazards.

1. The first step in implementing the analysis program of injury and illness records is to accomplish the following:

A. Analyze medical, safety, and insurance records, including the OSHA 300 log and information compiled through the medical management program, for evidence of cumulative trauma disorders.8

B. Identify and analyze any apparent trends relating to particular department, process units, job titles, operations, or workstations.

2. The second step of the hazard recognition program is to evaluate existing material handling tasks to identify and evaluate workplace conditions such as posture, force, repetitions, and weights of materials that are associated with CTDs. This analysis should do the following:

A. Conduct comprehensive baseline screening surveys to identify jobs that put associates at risk of developing CTDs. If the job places associates at risk of developing CTDs, than a more detailed ergonomic job hazard analysis will be completed. The baseline surveys should include components such as posture, material handling, and upper extremity factors.

B. Identify those work positions that put workers at risk of developing CTDs.

C. Verify low risk factors for alternate duty or restricted activity work positions.

D. Assure risk factors for a work position have been reduced or eliminated to the extent feasible.

E. Job hazard analyses shall be completed on all planned, new, and modified facilities, processes, materials, and equipment to ensure that workplace changes contribute to reducing or eliminating ergonomic hazards.

3. The job hazard analysis of ergonomic hazards should be performed and documented by a qualified person (trained personnel, ergonomic team, or ergonomist). Associates should also contribute to the process.

4. Periodic surveys of the worksite should be conducted - at least annually, or whenever operations change - to identify new or previously unnoticed risk factors and deficiencies or failures in work practices or engineering controls, and to assess the effects of changes in the work process.

A reliable system for associates to notify management about conditions that appear to be ergonomic hazards should be established. Associate insight can be used to determine appropriate work practices and engineering controls. This could be initiated by the JSA on ergonomic problems and issues, maintained through active safety committees and/or continuous improvement teams.

Hazard Prevention and Control Once the baseline screening survey and ergonomic job hazard analyses have been assessed, a priority system should be established to implement design measures to prevent or control the hazards. Ergonomic hazards are prevented primarily by effective design of the workstation, tools, and job. To be effective, the AWC program will use appropriate engineering and work practice controls, personal protective equipment, and administrative controls to correct or control ergonomic hazards.

8 Medical records are confidential and may be accessed only by qualified medical or legal personnel.

Section 10 Page 55

Revised: 02.2018 Doc ID: CORSAF.118

Exercise, stretching, and other types of wellness programs are not acceptable methods of controlling existing ergonomic problems. However, they can be considered as a form of prevention since they encourage a healthful lifestyle and build strength and endurance, both of which are desirable attributes in preventing ergonomic injuries and illnesses.

Engineering Controls Engineering techniques, where feasible, are the preferred method of control. The mission of an ergonomics program is to make the job fit the person, not to force the person to fit the job. This is accomplished by designing workstations and equipment that eliminate the need for excessive exertion and awkward postures and to reduce repetitive motion.

Workstation Design

Workstations must be designed to accommodate a worker population with a broad range of physical sizes, strengths, flexibility, and endurance. They must provide comfort and adequate space for a full range of motion. In some cases, this will require adjustability.

Design of Work Methods

Work methods should be designed to reduce static, extreme, and awkward postures; repetitive motion; and excessive force. Work method design addresses the content of tasks performed by the workers. It requires analysis of the production system to design or modify tasks to eliminate stressors.

Tool and Handle Design

Tools and handles, if well-designed, reduce the risk of CTDs. A variety of tools should be available to achieve a proper fit and reduce ergonomic risk. The appropriate tool should be used to do a specific job. Tools and handles should be selected to eliminate or minimize the following stressors:

Chronic muscle contraction or steady force.

Extreme or awkward finger/hand/arm position.

Repetitive, forceful motions.

Tool vibration.

Excessive gripping, pinching, pressing with the hand and fingers.

Work Practice Controls Key elements of a good work practice program for ergonomics include proper work techniques, associate conditioning, regular monitoring, feedback, maintenance, adjustments and modifications, and enforcement.

Proper Work Techniques

A program for proper work techniques, such as the following, includes appropriate training and practice time for associates.

Following procedures for properly using materials handling equipment and hand tools.

Using proper body mechanics that avoid extreme or awkward postures when lifting, lowering, pushing, pulling, or carrying objects.

Minimize bending, twisting, stopping, static loading, or other stressors."

Properly adjust and position tools, furniture, and equipment to reduce ergonomic risk factors.

Physical Conditioning (Work Hardening)

Physical conditioning of new associates and current associates following a period of absences should be considered whenever the job requires repetitive motion and/or

Section 10 Page 56

Revised: 02.2018 Doc ID: CORSAF.118

physical strength. These associates should be gradually integrated into a full workload, as appropriate for specific jobs and individuals. Associates should be assigned to an experienced trainer for job training and evaluation during the break-in period. Associates reassigned to new jobs should also have a break-in period.

Monitoring

Regular monitoring at all levels of operation helps to ensure that associates continue to use proper work practices. This monitoring should include a periodic review of the techniques in use and their effectiveness, including a determination of whether the procedures in use are those specified; if not, then it would be determined why changes have occurred and whether corrective action is necessary.

Adjustments and Modifications

Modify work practice controls when the dynamics of the workplace change. Such adjustments include changes in the following:

Line speed.

Staffing at position.

Type, size, or weight of the product handled.

Personal Protective Equipment (PPE) PPE should be selected with ergonomic stressors in mind. Appropriate PPE should be provided in a variety of sizes, should accommodate the physical requirements of workers and the job, and should not contribute to extreme postures and excessive forces. The following factors should be considered when selecting PPE:

1. Proper fit is essential.

2. Braces, splints, back belts, and other similar devices are not PPE.

Administrative Controls The following types of administrative controls should be implemented, as appropriate, to reduce the duration, frequency, and severity of exposures to ergonomic stresses. These types of controls are not the preferred method when more permanent engineering controls can be implemented; however, when properly monitored they can be effective in reducing ergonomic hazards. Examples:

1. Reducing the total number of repetitions per associate by such means as decreasing production rates and limiting overtime worked.

2. More frequent or proper scheduling of rest periods.

3. Increase the number of associates assigned to a task to alleviate severe conditions, especially heavy lifting.

4. Using job rotation, used with caution and as a preventive measure, not as a response to symptoms. The principle of job rotation is to alleviate physical fatigue and stress of a particular set of muscles and tendons by rotating associates among other jobs that use different muscle/tendon groups. If rotation is used, the job analysis must be reviewed by a qualified person to ensure that the same muscle/tendon groups are not used.

5. Provide sufficient numbers of standby/relief personnel to compensate for foreseeable upset conditions on the lines.

6. Preventive maintenance program for mechanical and power tools and equipment.

7. Perform maintenance regularly and whenever workers report suspected problems.

8. Effective housekeeping program.

Section 10 Page 57

Revised: 02.2018 Doc ID: CORSAF.118

Exercise/Wellness Programs The physical and mental well-being of associates is an important factor in the prevention of ergonomic-related injuries and illnesses. Associates who are physically and mentally healthy and maintain their bodies in good physical condition through proper diet and exercise are less likely to develop the classical ergonomic problems associated with strenuous and repetitive work.

Participation in stretching and exercise programs are encouraged because they promote on-the-job habits, behaviors, and lifestyles that are beneficial to associate health.

Exercise and stretching programs should, however, be strictly limited to associates who are not experiencing symptoms of pain or discomfort and are otherwise considered to be "healthy". Under no circumstances should stretching or exercise be used as treatment for an ergonomic injury or illness except under the specific direction of a health care provider.

Some examples of exercise/wellness programs for consideration are:

1. Company-organized stretching programs to lessen tight muscles before beginning work.

2. Job-specific exercise breaks with a trained leader.

3. Company-sponsored programs, such as health back programs, aimed at strengthening specific body parts.

4. Classes in stress management.

5. Off-the-job stretching and exercise programs.

Training and Education Appropriate training and education is needed to ensure that associates are sufficiently informed about the ergonomic hazards to which they may be exposed and thus are able to participate actively in their own protection. Associates should be adequately informed of the procedures and program elements included in this policy.

The initial training should occur at the manager and supervisor level and then be extended to all associates. Training, especially at the manager and supervisor levels, should be designed by person(s) with proven qualifications. The program should consist of both classroom training covering the various elements of the ergonomic program and on-the-job training in the recognition and control of ergonomic hazards in the workplace. The following types of training are recommended on (at least) an annual basis:

General Training

Associates who are potentially exposed to ergonomic hazards should be given formal instruction regarding the following:

Ergonomic risk factors associated with their jobs.

Varieties and causes of CTDs and methods of prevention.

How to recognize early symptoms of CTDs and the importance of early reporting of symptoms. Federal law requires that associates report all injuries and illnesses immediately for prompt medical attention. It is extremely important that symptoms of potential materials handling injuries and illness, including back injuries and cumulative trauma disorders of the hands and wrists, be reported at the earliest possible time. This allows for timely and appropriate medical evaluation and treatment before conditions become sever.

Materials handling procedures, good work practices, proper equipment, and appropriate personal protective equipment (gloves and footwear) to help prevent materials handling CTDs.

Section 10 Page 58

Revised: 02.2018 Doc ID: CORSAF.118

Job-Specific Training

New associates and reassigned workers must receive an initial orientation and hands-on training prior to being placed in a full-time production job. This training should include:

Work practice orientation, including instructions on posture, lifting, use of tools, proper use of regular exercise/stretching breaks, etc.

Workstation orientation, including arrangement and adjustment of chairs, equipment, machinery, and other elements of the workstation.

Identification of workstation, tool, and task-related ergonomic hazards.

Protocols and procedures for reporting ergonomic hazards and for suggesting and implementing changes in their new environment.

Managers and Supervisors

In addition to the general training, training must focus on how to recognize and implement basic engineering, work practice, and administrative ergonomic controls. It is helpful for associates at these levels to receive specialized training in preparation for the role of educating and training other associates.

Engineers and Maintenance Personnel

Training must include the prevention and control of ergonomic hazards in the workplace through proper design and maintenance of work systems.

Ergonomic Coordinator

To whatever extent possible, the ergonomic coordinator must be provided full and comprehensive training. The coordinator should attend off-site training courses, when available through a reputable source, to become familiar with all facets of the ergonomic program, including recognition of the various types of ergonomic injuries. They should also develop expertise in the recognition and control of ergonomic hazards. The ergonomic coordinator should be able to communicate this information to management and associates relative to the specific needs at that site.

Work Station Design/Operation Some basic principles of ergonomics are to identify problems with the work task and to make modifications. The following are four areas to review:

1. Work Station Design

2. Material Handling Methods

3. Repetitive Job Tasks

4. Work Posture Recommendations

Job Design The best way to avoid injury is to plan the job ahead of time. Whenever possible, cut down on the number of times that material has to be handled. Consider the amount of weight and bulk to be moved, the route it has to travel, the condition of the floor surface, and the best possible mechanical aids for the job.

Body Movements Jobs with significant non-neutral posture demands should be redesigned to eliminate the causes of postural stress. Reduce excessive reach requirements (maximum reach limit can be determined by an arc that is located at the shoulder center-of-rotation without bending the trunk.

1. Task related trunk flexion can usually be attributed to one of two causes:

Section 10 Page 59

Revised: 02.2018 Doc ID: CORSAF.118

A. Reaching for an object that is lower than the height of the hands when standing with the arms fully relaxed (hanging vertically at the side of the body), or

B. Reaching for an object that is too far in front of the body.

2. Tilting benches or bins should be used to reposition work closer to operators' reach limit.

3. Standing work stations should have floor mats to reduce discomfort for those required to stand all day. It is also desirable to provide high stools to allow for sitting postures during part of the work shift.

Manual Handling Tasks

Studies have shown that more than half of all compensable low back pain has been related to the manual handling of objects.

1. When practical use devices such as benches, conveyors, lift tables, and hoists to deliver objects to the worker at a comfortable height. (Approximately 28" above the floor.)

2. Provide foot space under benches to allow workers to get closer to objects that must be grasped. Eliminate any barriers which unnecessarily restrict horizontal reaches.

3. Discourage axial twisting of the spine through improved work station layout. Eliminate situations where workers must turn the body 180 degrees to perform sequential operations. If the work station layout cannot be improved, train workers to turn their bodies by moving their feet instead of twisting the spine.

Excessive Loads Handling heavy loads is related to an increased incidence of low back pain. Studies have concluded the incidence is increased when the lifting is greater than 35 pounds. The basic principles involve:

1. Containerizing the objects so that mechanical devices can be used to carry or transport the material.

2. Reduce the number of times each piece has to be moved.

3. Reduce weights where possible.

4. Reduce the distance moved.

Work Postures Principles

1. Avoid any kind of bent or unnatural postures. Bending the trunk or head sideways is more harmful than bending forward.

2. Avoid keeping an arm outreached either forward or sideways. Such posture not only leads to rapid fatigue, but also reduces the precision in general level of skill.

3. Arm movement should be either in the opposition to each other or otherwise symmetrical. Moving one arm by itself sets up static loads on the trunk muscles.

4. The most favorable working heights for hand work while standing is 2 to 4 inches below the elbow. If heavy work is being done then the working surface needs to be lower in the range of 6 to 8 inches below the elbow.

5. It is often desirable to be able to adjust the working height of tables to suit individuals because of the potential great differences between people's heights and work needs.

Video Display Terminal (VDT) Determine associate's knowledge for need of stretch/exercise breaks and types of exercises appropriate for the workstation.

Section 10 Page 60

Revised: 02.2018 Doc ID: CORSAF.118

Possible Corrective Measures:

1. Follow the procedure for a VDT Workstation Assessment and education the need for periodic breaks from working at a VDT terminal.

2. Conduct a Workstation Assessment

3. Demonstrate exercises appropriate for the workstation.

4. Provide with a copy of workstation stretches/exercises.

Section 11 Page 61

Revised: 02.2018 Doc ID: CORSAF.118

Fleet Loss Control Program Loss control is a management priority. Management must rely largely on vehicle operators to supervise their own actions behind the wheel. Management must communicate a strong fleet safety policy and support it with emphasis on driver selection, testing, training and the development of defensive driving techniques.

Loss control is a management responsibility, which includes the development and implementation of an effective program suited to specific operational needs.

AWC Statement of Fleet Loss Control Policy Motor vehicle accidents can be prevented. Through such prevention, injury can be avoided and costs can be reduced with a resulting increase in the well-being of our company.

It is the policy of AWC that every effort be made to prevent motor vehicle accidents. It is the responsibility of all personnel (managers, supervisors and drivers), to comply with this policy.

The fleet loss control program, under the direction of the Terminal Manager consists of:

1. Driver selection procedures

2. Ongoing defensive driving training

3. Vehicle selection, inspection and maintenance procedures

4. Accident investigation and analysis procedures

5. Accident review board (safety committee)

6. Evaluation of individual and facility safety performance

The effective integration of fleet loss control into the daily conduct of business will contribute significantly to the continued success and prosperity of our company and its associates.

Driver Selection When associates are allowed to drive a company vehicle, or to drive any vehicle for the company, they are entrusted not only with the operation and care of the vehicle, but also, the company's reputation.

Associates shall be evaluated and selected as to their driving ability if they are to drive on company business.

To evaluate associates as drivers, management shall:

1. Ascertain that the associate has a valid driver's license, including a Commercial Driver License (CDL) where warranted.

2. Ensure that the associate is qualified to operate the specific type of vehicle.

3. Review the associates' knowledge of vehicle operation and safe driving techniques by conducting a written examination and driving test.

4. Review the associate's Motor Vehicle Record (MVR) annually (more frequently if reasons warrant) to evaluate the individual's driving experience and observance of traffic laws.

5. Review past driving performance and work experience through previous employers' reference checks.

Driver Performance A review of the driver's over-the road performance is a critical component of this company's fleet loss control program. Performance shall be monitored during the selection/screening

Section 11 Page 62

Revised: 02.2018 Doc ID: CORSAF.118

process as well as at periodic intervals throughout the driver's career using information obtained from motor vehicle records and accident file data.

A formal review of the driver's motor vehicle record (MVR) shall be conducted on an annual basis (more frequently where warranted). The purpose of the review is to determine whether remedial driver training is warranted. The review is conducted with the driver, and becomes part of their file, as referenced above.

The following criteria, is used to measure driver performance based on accident/violation information obtained from MVRs and accident files:

A driver is unacceptable if the driver's accident/violation history in the past three years:

1. Includes one or more of the following violation convictions:

A. Driving under the influence of alcohol or drugs

B. Hit and run

C. Failure to report an accident

D. Negligent homicide arising out of the use of a motor vehicle

E. Operating during a period of suspension or revocation

F. Using a motor vehicle for the commission of a felony

G. Operating a motor vehicle without the owner's authority

H. Permitting an unlicensed person to drive

I. Reckless driving

J. Speed contest

2. Consists of any combination of preventable accidents and moving violation convictions which total four.

Drug Testing AWC's drug testing procedures have been developed and implemented in compliance with Federal Highway Administration (FHWA) regulations promulgated through the Department of Transportation (DOT). It is understood that local facilities will modify the corporate program based on applicable state/local drug testing regulations. For additional information see Corporate Drug Testing Policy.

The drug testing program is composed of the following elements:

1. Testing

A. Pre-employment

B. Reasonable Cause

C. Post-accident

D. Random

2. Record Retention

3. Associate Assistance Program

4. Medical Review Officer

Section 11 Page 63

Revised: 02.2018 Doc ID: CORSAF.118

Accident Recordkeeping, Reporting and Analysis AWC considers the elimination of all motor vehicle accidents as a major goal. To accomplish this task, it is paramount that all accidents be recorded and investigated. The investigation is used to identify needs for:

1. More intensive driver training and/or refresher training.

2. Improved driver selection procedures.

3. Improved vehicle inspection and/or maintenance activities.

4. Changes in traffic routes.

Motor vehicle accident recordkeeping procedures consist of the following components:

1. Documentation of causes and corrective action.

2. Management review to expedite corrective action.

3. Analysis of accidents to determine trends, recurring problems and the need for further control measures.

4. Compliance with DOT requirements where necessary.

Implementation of these procedures remains the responsibility of both the driver and manager.

Driver Responsibility Since the driver is the first person at the accident scene, it is important that they initiate the information-gathering process as quickly and thoroughly as is feasible.

Management Responsibility Management is responsible for obtaining the accident data from the driver through the reporting kit, information form, and/or by verbal communication. It is important for management to determine the extent of the accident, especially if it involves injury or death to the driver, passengers, or other parties.

Management should proceed with a formal investigation as soon as possible to determine the underlying causes as well as what can be done to prevent a similar occurrence in the future. The resulting accident report would be forwarded to the insurance claims office along with any additional support data (e.g., witness statements, photographs, police reports, etc.) and a copy sent to the Department of Transportation where warranted.

Preventable vs. Non-Preventable Accidents ANSI D15.1 provides the following important definitions relating to motor vehicle accidents:

1. A motor vehicle accident is defined as "any occurrence involving a motor vehicle which results in death, injury or property damage, unless such vehicle is properly parked. Who was injured, what property was damaged and to what extent, where the accident occurred, or who was responsible, are not relative factors."

2. A preventable accident is defined as "any accident involving the vehicle, unless properly parked, which results in property damage or personal injury and in which the driver failed to do everything they reasonably could have done to prevent or avoid the accident."

A properly parked motor vehicle is one that is completely stopped and parked where it is legal and prudent to park such a vehicle or to stop for the purpose of loading or unloading property. Cars stopped for the purpose of loading or unloading passengers are not considered parked.

Parking on private property shall be governed by the same regulations as apply on public streets and highways. A vehicle stopped in traffic in response to a sign, traffic signal or the police is not considered parked.

Section 11 Page 64

Revised: 02.2018 Doc ID: CORSAF.118

The determination of preventability of an accident is the function of AWC's accident review board, which is comprised of (at least three) representatives of management and the drivers.

The purpose of the accident review board is to:

1. Evaluate the circumstances surrounding an accident and the action to be taken by the driver

2. Determine if the accident was "preventable" or "non-preventable" in accordance with standard criteria

3. Provide a means for enforcing management and driver responsibilities

Vehicle Selection, Inspection, and Maintenance Proper selection and maintenance of equipment are an important aspect of this fleet loss control program. Reduced operational costs, reduced accidents from vehicle defects and improved public opinion are the direct results of a well implemented maintenance policy.

Vehicle Selection AWC's fleet maintenance program starts with the selection of vehicles with the understanding that the wrong equipment can result in excessive breakdowns, hazards to personnel, costly delays, poor service, or customer complaints. It is essential that AWC purchase vehicles which are designed for the specific job for which they are going to be used.

Fleet management must analyze transportation needs and determine what is expected of the vehicles in the fleet. An over-designed vehicle will involve too much of an initial cost as well as anticipated additional maintenance costs. An under-designed vehicle can involve a shorter life, more breakdowns, and higher overall maintenance cost.

Vehicle Inspection A documented program of pre-trip vehicle inspection is a critical component of the vehicle maintenance and loss control process. Detection and correction of a vehicle defect or deficiency reduces the risk of a mechanical condition contributing to an accident or vehicle breakdown which can result in death, injury and property damage, as well as missed deliveries, bad publicity, customer dissatisfaction, or on-the-road repair problems.

Documentation of the inspection process is maintained using a daily Company Vehicle Inspection Log conducted by the vehicle driver and a Maintenance Company Vehicle Inspection Log conducted by maintenance personnel. The report is designed for both pre-trip inspection purposes, and can also be used for periodic inspections while in transit. By keeping a copy of the vehicle condition report on the vehicle, the driver, mechanic or other interested parties can ascertain at a glance the known mechanical condition of the vehicle.

Driver training in proper vehicle inspection techniques is important, since it is the drivers who spend the most time with the vehicle, and are held accountable for its proper inspection.

The Federal Motor Carrier Safety Administration (FMCSR) also require an annual inspection, by a qualified inspector, of all vehicles covered by these regulations including trucks, buses, tractors, full and semi-trailers, converter dollies, etc. Each piece of equipment is verified, through the vehicle condition report, that the inspection was performed.

AWC adopts the vehicle inspection requirements of the FMCSR for its entire fleet.

Transportation of Hazardous Materials Interstate transportation of hazardous materials is governed through the Federal Regulations promulgated by the Federal Highway Administration of the Department of Transportation (DOT). Most states/provinces and localities have either adopted the federal regulations as local law or promulgated their own regulations based on DOT requirements.

Section 11 Page 65

Revised: 02.2018 Doc ID: CORSAF.118

AWC does not transport any hazardous materials,

Driver Training The drivers hired by this company to operate a motor vehicle will have the basic skills and credentials necessary to perform this function as confirmed through the driver selection process. The purpose of the driver training program is to increase these skills and orient the drivers to this company's fleet safety policy, equipment and procedures.

Driver training include:

1. Training and indoctrination into the company safety policy and programs

2. Refresher training on defensive, incident-free driving

Driver Training AWC's company driver training program is divided into several levels: Initial, Refresher, & Remedial

1. Drivers must have had initial driver training. Company orientation will be conducted which will address specialized tasks associated with AWC work.

2. Refresher training is useful for regular drivers to update information on operational changes, new routes, cargo, equipment, government regulations, etc.

3. Remedial training covers problems of substandard performance which can be alleviated through corrective training. The need for remedial training is identified through customer complaints, accident involvement, MVR reviews, and/or evidence of vehicle abuse.

AWC uses several approaches to driver training:

1. Classroom training

2. In-vehicle training

3. Driver safety meetings

Topic-specific programs, usually are supported by videos, and are presented either on a one-to-one or self-study basis or in a driver safety meeting environment.

In-vehicle training is most effective for equipment familiarization, cargo handling, pre-trip inspection training, etc., and is recommended for conditions and situations that warrant closely controlled supervision.

AWC's driver training program includes (but is not limited to) the following areas:

1. Identification of driver trainers

2. Company rules and policies

3. Equipment familiarization

4. Routes

5. Defensive driving techniques

6. Government regulations

7. Cargo handling

8. Emergency procedures (See: Emergency Response Plan, Emergency Preparedness Posters, & Emergency Preparedness Manual)

9. Emergency warning devices

10. Specific trend-identified exposures

Section 11 Page 66

Revised: 02.2018 Doc ID: CORSAF.118

Fleet Loss Control Program Audit A fleet loss control program audit is necessary to ensure that each element of AWC's program is functioning properly.

The audit program also provides information on areas where the program needs to be updated due to changes in operations, regulations and/or exposures. The audit program results are essential to the accountability system which underlies the management approach to the overall program.

AWC's Fleet Loss Control Program Audit covers the following general areas:

1. Driver Qualification

2. Driver Training

3. Driver supervision

4. Vehicle Selection, Inspection, and Maintenance

5. Routing and Scheduling

6. Accident Reporting, Recording, and Analysis

Section 12 Page 67

Revised: 02.2018 Doc ID: CORSAF.118

AWC Automobile Policy Company-owned vehicles are to be used for Company business only.

Vehicles have been purchased to be used by authorized associates for the purpose of getting equipment to and from our facilities and transporting drivers on site during normal business hours.

Use of company vehicles for any clearly personal use is NOT authorized, unless prior case-by-case approval is specifically granted by the manager. If vehicles are knowingly used for unauthorized purposes, or by other than AWC associates, the offending associate (or driver assigned to the vehicle used) will be personally responsible for paying the entire amount of insurance deductible for any vehicle damage, and may be subject to corrective action up to and including termination.

The manager will have an annual "Motor Vehicle Report" (MVR) completed by the Department of Motor Vehicles for each person who may drive a company or customer vehicle on a regular basis. If the MVR reveals any of the violations listed under the heading "Selection of Company Drivers," or if actual observed driving performance is such that a driver will put the company at undue risk for safety or insurance reasons, that person will not be allowed to drive a company or customer vehicle.

All drivers of AWC must comply with the rules outlined in the Driver Safety Rules.

Maintenance Responsibilities Terminal Managers shall be responsible for appointing an individual to properly inspect company vehicles using a regular schedule. A maintenance log will be kept for all maintenance performed.

Driver Safety Rules

1. AWC endorses as company rules all applicable state/provincial motor vehicle regulations in relation to driver responsibility.

2. All accidents, regardless of severity, must be reported.

3. At no time are unauthorized riders, hitch-hikers, etc. allowed to ride in company vehicles.

4. Under no circumstances is a company vehicle to be driven by a non-associate except in emergencies or in case of repair testing by a mechanic.

5. Any driver who has a driver's license revoked or suspended shall immediately notify their supervisor or manager, and discontinue operation of the company or customer vehicles.9

6. Drivers must promptly report all summonses received for moving violations during or after business hours to their supervisor.

7. No driver shall operate a company or customer vehicle when their ability to do so safely has been impaired, affected or influenced by alcohol, drugs, medication, illness, fatigue, or injury.

8. Each driver is responsible to ensure that their vehicle is in safe operating condition and is not allowed to operate the vehicle with defective steering or brakes, worn tires, or any other defect that would inhibit safe operation during current and foreseeable weather and light conditions.

9 Operating any company vehicle while under a driver's license suspension, will result in loss of use of driving privileges

and consequently dismissal.

Section 12 Page 68

Revised: 02.2018 Doc ID: CORSAF.118

9. Drivers are responsible to ensure the security of company vehicles. The vehicle engine must be shut off, ignition keys removed, transmission in park, reverse or low gear, and parking brake applied.

10. While driving in the yard or on public roads drivers must honor posted speed limits. In the event of adverse driving conditions, drivers are required to reduce speed to a safe operating speed that is consistent with the conditions of the road, weather, light, and traffic.

11. While driving in the yard or on public roads drivers are required to maintain a safe following distance at all times. Drivers should keep a two-second interval between their vehicle and the vehicle immediately ahead. During slippery road conditions, the following distance should be increased to at least 4 seconds.

12. While driving in the yard or on public roads drivers must yield the right of way at all traffic controls, signals and signs requiring them to do so. Drivers should also be prepared to yield for safety's sake, at any time. Pedestrians and bicycles in the roadway always have the right of way.

13. While driving in the yard or on public roads drivers are required to stay to the right at all times, except when passing in a legal passing zone or preparing for a left-hand turn (foreign locations may be different).

14. While driving in the yard or on public roads all drivers and passengers, operating or riding in company vehicles, must wear seat belts and shoulder straps if provided.

Selection of Company Drivers Prior to assignment of a company vehicle to an associate, hiring an individual who will drive a company or customer vehicle, the following rules must apply:

1. The prospective driver must have a valid driver's license in the state/province where the vehicle will be assigned, or in the case of other associate drivers -- their state/province of residence.

2. Managers will obtain a motor vehicle report (MVR) on all new associates and annually thereafter.

A. Should the MVR reveal any of the violations listed below within the prior 12-month period:

i. The prospective associate shall not be hired.

B. Should the MVR reveal any moving violations for a current AWC driver which had not previously been submitted:

i. The drivers’ record shall be reviewed, and they may be subject to disciplinary action.

ii. Also, the assignment of a company vehicle or driving of a customer vehicle must be discontinued.

Violations

1. Two or more moving violations and/or preventable accidents.

2. Driving under the influence of alcohol (company policy states no more than a 0.04% blood alcohol).

3. Being at fault in a fatal accident.

Please direct any questions to the Corporate Human Resources.

Section 13 Page 69

Revised: 02.2018 Doc ID: CORSAF.118

Environmental Auto Warehousing Company has established environmental operating standards that are directed towards minimizing risk to associates, public, and environment. Implementing methods and tools to audit, continuously improving the processes to further minimize the impact on the environment. Holding the management at each facility accountable for his/her facility.

Environmental Manual For more information on the Environmental Program at AWC, please review the Environmental Manual.

Section 14 Page 70

Revised: 02.2018 Doc ID: CORSAF.118

Health & Safety Training Instruction on the safe way to perform duties should be done at the time of hire, when job assignment changes, when process or procedures change, when protective equipment use changes, when a new hazard is identified or introduced into the assignment. All annual training must be conducted within one year from the previous year’s training (See: Safety Training Submission Matrix and Completed Annual Training by Location).

Company Required Training Consequences of Ignoring Safety Rules: Associates need to be advised of the consequences of their actions, e.g. warning, suspension, discharge.

Expectations: Explain what standards the associate needs to meet or exceed to be a quality AWC worker.

Overview of Company's Policies: All personnel policies should be covered with the associate and preferably issued in the form of a handbook.

Supervisory and Management Training: The corporate philosophy needs to be taught to the management and supervisory staff to ensure top management goals are being achieved. This also includes educating this group on company policies and disciplinary procedures.

Training Requirements If you need assistance with training materials contact Corporate Safety.

1. Associates sign an acknowledgment that training was received on a specific subject on a certain date.

A. Sign in rosters can be used; have a separate sheet for each training topic with the date of the training listed and the trainer/supervisor (See: Training Sign Off).

2. The training can be done formally or informally. Explain to the worker what you are doing and why, particularly when the training is informal. In a formal training setting make sure the room is comfortable, has appropriate lighting and is properly ventilated.

General Orientation

Introduction to Safety Associate safety is a major concern to the company and we make every effort to provide safe working conditions for all of our associates. It is our policy to adhere to all local, state, provincial, and federal laws and accepted safety rules and procedures that pertain to the safety of our associates and our operation. No associate is ever knowingly required to work in any unsafe manner or condition.

Product Auto Warehousing Company is an auto processing company. We prepare cars for transport according to customer specifications. This can include: accessorizing, repairing, and washing cars. Mostly the cars are driven from one place to another. When a car arrives it is processed as requested and placed in a parking area for shipment. Trainers are provided for each type of work performed. The trainers, leads, and supervisors are always available for questions. Do NOT attempt a job if you do not understand how to perform it safely.

Equipment Everyone is expected to be familiar with the safe operation of the equipment and tools required for specific jobs before they start that job. Personal protective equipment (PPE) is to be worn at all times when required. For drivers, the ability to operate vehicles safely is essential. General knowledge of automotive and construction tools will be necessary in shop areas. Do NOT work with equipment that you cannot use safely; request further training.

Section 14 Page 71

Revised: 02.2018 Doc ID: CORSAF.118

Environment Environmental knowledge covers everything around you. Hazards can appear at any time. Areas that were completely safe one moment can become unsafe. Machines can break, or get worn. Gases can be released into the air that can be potentially harmful if inhaled. Spills can cause falls or exposure problems for those that come into contact with the liquid. Individuals using unsafe procedures can bring harm to you. Hazards and hazardous materials are a part of all environments, stay alert and become familiar with the company's Hazard Communication Program.

Company Training Topics Listed below are the company training topics included, but not limited to (See specific training for additional information):

3-Points of Contact

1. Climbing Ladders

2. Crossing Junctions

3. Exiting/Entering Railcars

4. Exiting/Entering Vehicles

AAR

1. AAR Website: Training & Videos

2. Post Loading Test

3. Quality Training

Confined Spaces

1. It is AWC’s policy that at no time should any associate, including maintenance personnel, enter a confined space.

Driver Safety

1. Backing Up

2. Defensive Driving

3. General Driver Safety

4. Pulling Out of Bays

Emergency Preparedness

1. Emergency Response Plan – Site Specific (Emergency Evacuation Drills & Procedures)

2. Emergency Preparedness Manual

3. Evacuation Maps – Site Specific

A. All associates must know evacuation routes, locations of safety equipment (First Aid stations, Eye Wash, Fire Extinguishers, etc.), fire alarm pull station location, and who/where to report to for safety concerns.

4. Fire Extinguisher

Environmental

1. Spill Prevention, Control, & Countermeasure (SPPCC)

2. Spill Prevention Program (SPP)

3. Storm Water Pollution Prevention (SWPP)

Equipment

1. Automotive Lifts

2. Forklift

Section 14 Page 72

Revised: 02.2018 Doc ID: CORSAF.118

3. Hand Tool Safety

4. Hoists

5. Lockout/Tagout – Affected

6. Lockout/Tagout – Authorized

7. Machine Guarding

First Aid and CPR

1. Bloodborne Pathogens (BBP) – Affected

2. First Aid & CPR/Bloodborne Pathogens (BBP) - Authorized (Bi-Annual Training Class)

A. AWC desires all managers, supervisors and leads to have formal First Aid and CPR training. It is desirable that other associates be certified, also. To encourage this AWC will pay the costs of CPR and First Aid training for associates.

Hazardous Communication (HazCom/WHMIS)

1. HazCom Training Packet

2. Hazardous Material Business Plan

Hot Work

Injury & Illness Prevention

1. Accident Prevention Program (APP) – WA State

2. Ergonomics

3. Injury & Illness Prevention Program (IIPP) – All Other States

4. Materials Handling

5. Personal Protective Equipment (PPE)

6. Reporting Accidents & Injuries

7. Safety & Health Program (SHP) – OR State

8. Slips/Trips/Falls

Rail Safety

1. Blue Flag Protection

2. Bridge Plate Handling

3. Buck Ramps

4. Deck Lids, Bridge Plates, & Ratcheting

5. Railcar Door Opening & Closing

6. Walking In Front or Behind Units on Rail

Site Specific

1. Manual Door Release – Corvette

2. Manual Transmission – Vehicle Specific

Training Videos

Section 15 Page 73

Revised: 02.2018 Doc ID: CORSAF.118

Forms All Corporate Safety required and developed forms can be located on the Safety SharePoint. Permissions and accessibility to forms located on the Safety SharePoint for associates is determined by the Corporate Safety Department. These forms are either hosted on the Auto Warehousing Company SharePoint or located in the Safety File Center for downloading.

Form Index

Associate Involvement

Hazardous Condition Reporting Form

Damage/Injury

600 Accident Report

601 Injury Report

603 Theft Report

604 Temp Injury Report

Associate Statement of Incident

Damage Points

Near Miss Accident

Near Miss Injury Tracking Report

OSHA 300 Log

Temp Associate Statement of Incident

Witness Statement of Incident

Inspection/Observations

Aboveground Storage Tank Inspection

Automotive Lifts (Daily Inspection)

Bay/Rail Audits

Buck Ramp (Daily Inspection)

Company Vehicle - Maintenance (Daily Inspection)

Company Vehicle - Van Driver (Daily Inspection)

Facility Inspection

Forklift (Daily Inspection)

Front End Loader (Daily Inspection)

LOTO Procedure Inspection

Observation Documentation

Respirator (Daily Inspection)

Safety Observations

Spill Kit Monthly Inspection Log

Sweeper (Daily Inspection)

Emergency Response

Emergency Response Plans (Blank)

Evacuation Drill Record

Requesting Emergency Assistance

Environmental

Annual Spill Drills

Best Management Practices (BMP) Table

Chemical Storage Log

Hazardous Materials Business Plan (HMBP)

Section 15 Page 74

Revised: 02.2018 Doc ID: CORSAF.118

Industrial Hygiene Air Sampling Report

Spill Prevention Plan (SPP)

Spill Reporting

Storm Water Prevention Program - SWPP (Blank)

Ergonomics

Job Safety Analysis (JSA)

VDT Workstation Assessment

First Aid

Blood & Bodily Fluid Incident Exposure Report

First Aid Kit Inventory Checklist

Hepatitis B Vaccination Schedule Record

Hepatitis B Vaccination Form

Hepatitis B Vaccination Status Record

Maintenance

Automotive Lift (Maintenance Log)

Buck Ramp (Maintenance Log)

Company Vehicle (Maintenance Log)

Forklift (Maintenance Log)

Front End Loader (Maintenance Log)

Sweeper (Maintenance Log)

Miscellaneous

Coaching Logs

Hazardous Work Permit

LOTO Authorized Employee List

New Model Evaluation

Safety Committee Minutes

Safety Signage Request

Training Submission

Van Suggestions

New Hire Orientation

New Hire Safety Training Requirements

PPE Acknowledgment Form

Right to Know Acknowledgment Form

Personal Protection Equipment (PPE)

PPE – Certification of Assessment

Respirator Fit Test

Sign-In/Sign-Off

Safety Committee Sign-In

Shift Briefing Records

Shift Briefing Sign Off

Training Sign Off

Visitors/Contractors

Customer, Vendor, & Visitor Briefing Checklist