CONTRACTOR / SUPPLIER ENVIRONMENTAL, SAFETY & HEALTH REQUIREMENTS GUIDE GKN Aerospace – St. Louis recognizes the importance of conducting its business in a socially responsible manner designed to: provide safe and healthful operations for its employees and customers as well as the general public; ensuring compliance with environmental requirements; and preserving company assets. It is the responsibility of each Contractor / Supplier to ensure that each Contractor / Supplier employee conducts himself / herself safely, adheres to environmental, safety and health requirements, and informs GKN when potentially unsafe conditions or environmental risks are observed. he Contractor / Supplier must assure that this guide is reviewed by its employees. GKN will provide additional copies of this guide to the Contractor / Supplier upon request. This booklet serves only as a guide. Nothing herein shall be construed to relieve the Contractor / Supplier of its responsibility to comply with federal, state, and local environmental, health and safety laws, rules, regulations and GKN contract requirements. Contractor / Supplier employees violating any of these rules or requirements are subject to removal from the site immediately. Note: The GKN Project Manager or GKN Sponsor is the focal contact point for a Contractor / Supplier. The GKN Project Manager / Sponsor must be kept fully informed of safety / environmental issues along with other issues that could impact GKN. The GKN Project Manager / Sponsor will resolve unsafe and inappropriate conditions by direct communications with the on-site supervision of a Contractor / Supplier. MI 7.1-66 (a) Rev B Page 1 of 12 Table Of Contents 1.0 Emergency Procedures 1.1 Emergency Numbers 1.2 First Aid / Medical 1.3 Accident Reporting 1.4 Alarms 1.5 Chemical Spills 2.0 General Information 2.1 Site Rules of Personnel Conduct 2.2 Site Rules for Contractor / Supplier Equipment 2.3 Additional Telephone Numbers for Routine Business 3.0 ISO 14001 Environmental Management System 3.1 EMS System Awareness / GKN –STL EMS Policy 3.2 EMS-related Training 4.0 Safety / Industrial Hygiene 4.1 Barricades 4.2 Overhead Work 4.3 Housekeeping 4.4 Ladders / Scaffolds / Work Platforms 4.5 Fall Protection 4.6 Hoisting 4.7 Welding, Cutting, Brazing 4.8 Personal Protective Equipment (PPE) and Dress Code 4.9 Hazard Communication 4.10 Confined Spaces 4.11 Lockout / Tagout 4.12 Asbestos 4.13 Lead Based Paint 4.14 Excavation 4.15 Roof Access 4.16 Pre-job Safety Meeting 5.0 Environmental Protection 5.1 General 5.2 Air Emissions 5.3 Waste Management 5.4 Wastewater Discharges 5.5 Potable Water 6.0 Fire Prevention 6.1 General 7.0 Security / Site Access 7.1 Badging 7.2 Searches 7.3 Confidentiality MI 7.1-66 (a) Rev B Page 2 of 12 1.0 Emergency Procedures 1.1 Emergency Numbers 1.1.1 For all emergencies dial 911 from an internal GKN Telephone. Dial 314-264-3911 when using a mobile telephone or other external telephone. These telephone numbers contact GKN Security which is available 24 hours per day, 7 days per week. GKN Security will be responsible for contacting Municipal Emergency Response (Fire, Police, or Ambulance) as required. 1.1.2 Be prepared to provide the following information: 1.1.3 1.1.2.1 Your name and your employer’s name 1.1.2.2 Phone number from which you are calling 1.1.2.3 Building, level, and column location 1.1.2.4 Location of incident 1.1.2.5 Nature of incident Don’t hang up the telephone until instructed to do so! You are a vital line in the emergency and you must relay changes in the status of the emergency. 1.2 First Aid / Medical 1.2.1 GKN will not be responsible for providing any medical treatment or hospital services to employees of Contractors / Suppliers. 1.2.2 For serious medical emergencies, dial 911 from an internal GKN Telephone. Dial 314-264-3911 or 314-264-3819 when using a mobile telephone or other external telephone for assistance. It is important that GKN Security is the first contact for all emergencies such that GKN Security can request the proper Municipal Emergency Response (Fire, Police, or Ambulance). 1.3 Accident Reporting 1.3.1 All incidents that had the potential to or resulted in either property damage or injury to any Contractor / Supplier employee on GKN premises must be promptly reported to the GKN Project Manager / Sponsor. If the GKN Project Manager / Sponsor is not available, notify any available member of GKN management. 1.3.2 Contractor/Supplier employees involved in incidents that had the potential or resulted in property damage or personal may at GKN discretion be asked to submit to alcohol or drug screening at the cost of the contractor/supplier. 1.4 Alarms 1.4.1 Two distinctive alarms are used at GKN to warn of a tornado or to initiate a building evacuation. Consult the current GKN-STL facility site maps (available from Project Manager) for the applicable Evacuation Rally Points and Tornado Shelters for each building. 1.4.2 In the event of imminent tornado activity, a warbling/whooping tone will sound, indicating that all personnel should seek shelter. 1.4.3 A buzzing alarm is used in the event of fire or other incident that requires personnel to evacuate the building. 1.4.4 Dial 314-264-4500 for an Audio Demonstration of the above tones. 1.5 Chemical Spills 1.5.1 If chemicals are to be used near sewers and/or drains, these sewers and/or drains will be protected to prevent an accidental discharge. 1.5.2 All spills must be immediately reported by dialing 911 using an internal GKN Telephone. Dial 314264-3911 or 314-264-3819 when using a mobile telephone or other external telephone. A Spill of chemicals, fuels, oils, and other polluting substances must be contained and kept away from all sewers, drains, and ignition sources. Containment activities should be ceased if they cannot be MI 7.1-66 (a) Rev B Page 3 of 12 performed in a safe manner. 2.0 General Information 2.1 Site Rules of Personnel Conduct 2.1.1 Contractor / Supplier personnel shall not run in the plant or on any company premises. This includes parking lots and roadways. Horseplay of any type on company property will not be tolerated. 2.1.2 GKN-STL requires safety glasses to be worn in all areas of the building except for office areas, or areas clearly marked as “safety glasses exclusion zones”. 2.1.3 Contractor / Supplier personnel are prohibited from engaging in the following activities: 2.1.3.1 Smoking within the secured perimeter of company property except for smoking in the designated smoking shelters. 2.1.3.2 Possessing weapons, explosives, cameras, radios, cassette players/recorders, or other electronic devices for recording or transmitting images and / or sound. Use of cellular telephones is allowed unless the area is posted otherwise. Cellular phone use is prohibited when operating vehicles or equipment. 2.1.3.3 Violating GKN Affirmative Action and Equal Opportunity Policies, which prohibit discrimination, retaliation or harassment (including slurs, banter, writings, pictures, etc.). 2.1.3.4 Violating rules, procedures or warning signs pertaining to employee safety, fire prevention and environmental protection. 2.1.3.5 Failing to immediately report personal injuries incurred at the job site to the GKN Project Manager / Sponsor. 2.1.3.6 Violating GKN parking plans and traffic rules. This includes violating public laws while engaged in activities on company property. 2.1.3.7 Conducting activities detrimental to the interests of GKN. 2.1.3.8 Concealing or failing to report an error in the work performed. 2.1.3.9 Distracting the attention of others from the work being performed, including but not limited to job classification or collective bargaining labor issues. An employee of a Contractor / Supplier must report labor disputes directly to the Contractor’s / Supplier’s Site Supervisor. The Supervisor will then notify the GKN Project Manager / Sponsor of the issue. 2.1.3.10 Distributing literature (illustrated, written, printed, electronic files, or audio/video taped material) on company property or engaging in commercial solicitations on company property which does not directly pertain to GKN business operations or to the best interest of GKN. 2.1.3.11 Performing careless and/or reckless work that could result in danger to other Contractor personnel or GKN personnel, poor quality, delay to work in process, or damage / destruction to company property or the property of others. 2.1.3.12 Entering GKN premises or entering restricted areas on company property without the proper authorization and identification badge. 2.1.3.13 Possessing, dispensing, selling, drinking, using or being under the influence of alcoholic beverages, narcotics, drugs (except when taken as directed by a competent medical professional), or similar harmful substances on company property at any time. 2.1.3.14 Permitting others to wear one’s identification badge, wearing another person’s badge, repeatedly forgetting one’s identification badge, or failure to prominently display one’s identification badge at all times. 2.1.3.15 Using one’s identification badge to allow the unauthorized entry of another person into restricted areas of company property. MI 7.1-66 (a) Rev B Page 4 of 12 2.1.3.16 Operating a motorized vehicle without using the appropriate seat and / or appropriate harnesses / lanyards. 2.1.3.17 Operating a motorized vehicle with a passenger that is not using an appropriate seat and / or appropriate harnesses / lanyards. 2.2 Site Rules for Contractor / Supplier Equipment 2.2.1 Contract work, equipment, and materials must meet all Federal, State, and Local specifications. Equipment shall not be modified in such a way that it may become hazardous to either the Contractor / Supplier personnel or GKN personnel. 2.2.2 Contractors may not use any GKN owned/leased vehicles unless specifically authorized to do so; this includes, but is not limited to, forktrucks, scooters, golf carts, hand trucks, emergency carts, sideloaders, scissors lifts or boom trucks. 2.2.3 Vehicles and materials may not be left unattended in main aisles by Contractor / Supplier personnel. 2.2.4 Prolonged or unnecessary running of vehicles and/or equipment inside the building is prohibited. 2.2.5 Contractor / Supplier mobile equipment shall not exceed five miles per hour in the buildings or fifteen miles per hour outside of the buildings. 2.2.6 Contractor / Supplier mobile equipment shall be parked in areas designated by the GKN Project Manager / Sponsor. Mobile equipment shall not be parked in any active areas of the complex which have not been approved by the GKN Project Manager / Sponsor. An active area is defined as any area that has not been properly identified as a construction area. 2.2.7 Contractor / Supplier mobile equipment on company property shall be identified with the name of the Contractor / Supplier in a conspicuous location. If a rental unit is being utilized, the equipment must be identified by temporary means. 2.2.8 Contractor / Supplier vehicles must stop and sound horn before proceeding through blind intersections, entrances and exits. Pedestrians have the right-of-way at all times. Contractor / Supplier personnel shall observe all vehicle traffic rules and signs and possess a valid license for operating vehicles. Stunt driving and horseplay will not be tolerated at GKN Aerospace and will be grounds for dismissal from property. 2.2.9 Contractor / Supplier personnel operating vehicle-mounted lift platforms (e.g. Mark lifts, Condors, etc.) must be properly trained and qualified in their operation by the Contractor / Supplier. Contractor / Supplier personnel riding in self-propelled articulating boom work platforms shall wear the required fall protection equipment. Use of belts is strictly prohibited. Standing on railings of lift platforms is also prohibited. 2.2.10 Within the secured perimeter of the GKN Complex, Contractor / Supplier personnel must park in the designated Contractor / Supplier parking areas unless otherwise determined by GKN Project Manager / Sponsor. No emergency lanes may be blocked at any time. Contractor / Supplier parking outside of the secured perimeter is detailed in section 6.3.1 of this document. 2.2.11 Vehicles that require backup alarms and vehicle operator checklists shall be properly operated and maintained by the Contractor / Supplier. 2.2.12 Truck brakes must be set and wheel chocks placed under the rear wheels while loading and unloading trailers. 2.2.13 Use portable jack stands on dropped trailers when loading and unloading trailers. 2.2.14 Any Contractor / Supplier vehicle subject to DOT regulations shall be maintained as such by the Contractor / Supplier, ensuring proper qualification of drivers, log books, etc. 2.2.15 Tools and equipment shall be used only by those trained and qualified to use that tool or equipment. Contractor / Supplier must ensure the following: 2.2.15.1 All tools and equipment must be in good condition and inspected daily. 2.2.15.2 Altering tools or removing guards is not permitted. MI 7.1-66 (a) Rev B Page 5 of 12 2.2.15.3 Use tools only for their designated purpose. DO NOT IMPROVISE! Use the correct tool or equipment. 2.2.16 Compressors & Generators 2.2.16.1 The use of all compressors and generators on site must comply with all manufacturers recommendations and be appropriate for the environment in which they are operating. 2.2.16.2 Contractors / Suppliers must be aware of Carbon Monoxide Concentrations indoors when using equipment that produces Carbon Monoxide. Ensure adequate ventilation while operating this equipment indoors. Use of two cycle engines indoors is strictly prohibited. 2.2.17 Electrical Equipment 2.2.17.1 Use of extension cords shall be for temporary wiring only. GFCI, Ground fault circuit interrupters, shall be used on receptacle outlets for construction activity. 2.3 Additional Telephone Numbers for Routine Business 2.3.1 Facilities Services (314) 264-4000 2.3.2 Fire Services (314) 264-3071 2.3.3 Safety & Health (314) 264-3667 2.3.4 Environmental (314) 264-3665 2.3.5 Security Services (314) 264-3819 3.0 Management Systems Awareness 3.1 OHS Management System Awareness 3.1.1 Contractor/Supplier personnel shall be aware that GKN-STL has established an Occupational Health and Safety Management System that requires all contractors/suppliers to comply with all applicable safety and health regulations while onsite at GKN-STL. 3.2 EMS System Awareness 3.2.1 Contractor/Supplier personnel shall be aware that GKN-STL has established and maintains an ISO 14001 Environmental Management System (EMS) that requires all personnel, including contractor/suppliers to comply with all applicable environmental regulations and EMS policy and procedures. 4.0 Safety / Industrial Hygiene 4.1 Barricades 4.1.1 Contractor / Supplier shall provide signs, barricades, flashing light barricades, and/or flagging as required to keep unauthorized personnel out of the construction areas and provide warning of any potential hazard at the job site. 4.2 Overhead Work 4.2.1 Barriers must be provided by Contractor / Supplier to block off areas where GKN personnel could likely walk beneath overhead work. Signs supplied by Contractor / Supplier must be posted to indicate overhead work in progress. 4.2.2 Where Contractor / Supplier personnel must work beneath overhead work activities, Contractor / Supplier shall designate a hardhat area. 4.2.3 Contractor / Supplier must be aware of overhead electrical hazards, chemical lines, and other utility lines when raising and lowering equipment. 4.3 Housekeeping 4.3.1 MI 7.1-66 (a) Rev B Contractor / Supplier personnel shall keep work areas clean, neat and orderly at all times. Page 6 of 12 4.3.2 The Contractor / Supplier must keep all equipment and supplies in designated staging areas. Contractor / Supplier acknowledges that GKN is not responsible for any Contractor / Supplier equipment on GKN premises. 4.4 Ladders / Scaffolds / Work Platforms 4.4.1 Industrial stepladders shall not exceed 20 feet. Single ladders or individual rails for extension ladders shall not exceed 30 feet. 4.4.2 Portable metal ladders may not be used for electrical work. 4.4.3 No Contractor / Supplier personnel is allowed to access the roof of any building without prior authorization from the GKN Project Manager / Sponsor. 4.4.4 Ladders shall not be used in front of doorways without posting the area and providing a barricade. 4.4.5 Ladders, scaffolds and work platforms must be visually inspected for defects before they are used. 4.4.6 Ladders must be placed at a proper angle of 4/1 ratios to ensure proper ascending and descending. 4.4.7 Straight ladders must be secured from sliding by securing the top of the ladder to an adequate structure. 4.4.8 Barriers must be used to warn others of overhead work. 4.4.9 Do not use the top two steps of a stepladder. Do not climb higher than the third rung from the top of a ladder. 4.4.10 Job built ladders must meet and conform to OSHA regulations. 4.4.11 The Contractor / Supplier must identify their “competent employee” when the use of scaffolds are required. 4.5 Fall Protection 4.5.1 Scaffolds must be erected soundly. They should be rigid and capable of carrying the maximum intended load without settling or displacement. 4.5.2 Guardrails and toeboards shall be installed on all open sides and ends of a scaffold or platform with an elevation greater than 10 feet above the ground / floor. 4.5.3 Planks for working surface shall be the complete width (overhand where appropriate) of the scaffold. 4.5.4 Safety harnesses, lifelines and lanyards that comply with 29 CFR 1926.104 shall be supplied by the Contractor / Supplier. 4.5.5 Fall protection is required to be used when working on elevated and open platforms where fall hazards exceed 6 feet. USE OF BELTS ARE STRICTLY PROHIBITED on GKN property 4.5.6 When applicable, fall restraint is preferred over fall arrest. 4.5.7 All projects requiring working at heights are to have the appropriate Working at Height permit completed by Project Manager. Form is found in MI 6.1-67 (A). 4.6 Hoisting 4.6.1 Hoisting of suspended loads over any personnel is prohibited. 4.6.2 GKN overhead hoists shall not be used by Contractor / Supplier without permission from the GKN Project Manager / Sponsor and the Manufacturing Area Manager. 4.6.3 Overhead cranes must be de-energized whenever Contractor / Suppliers must work in close proximity of crane power busses. If the work being performed is in the travel path of cranes, but not close to the power busses, the crane may either be de-energized or isolated by rail stops. 4.7 Welding, Cutting, Brazing MI 7.1-66 (a) Rev B Page 7 of 12 4.7.1 All welding, cutting, brazing, and other open flame operations performed by the Contractor / Supplier must be approved by the GKN Project Manager / Sponsor. A GKN Hot Work Permit is required prior to commencement of these activities. 4.7.2 Screens or barriers must be set where necessary to protect personnel in surrounding areas from both welding flash and sparks. 4.8 Personal Protective Equipment (PPE) and Dress Code 4.8.1 All Contractor / Supplier personnel PPE will be appropriate for the job and supplied by the Contractor / Supplier. 4.8.2 Contractor / Supplier personnel assigned to or entering eye protection areas must wear industrial safety glasses with industrial safety lenses and side shields. GKN requires safety glasses to be worn in all areas of the buildings except for office areas. Contractor / Supplier personnel must use eye protection while performing operations using tools or equipment in office areas. Where chemical splash hazards exist; goggles, full-face shield, and /or a full face respirator must be worn as required. 4.8.3 Ordinary sunglasses or light-sensitive lenses are not allowed in eye protection areas unless authorized by the GKN Project Manager / Sponsor. 4.8.4 Ear plugs and/or muffs must be worn in accordance with ESH-STL-004, Hearing Conservation. 4.8.5 Contractor / Supplier personnel assigned to work in the shop, manufacturing, or maintenance areas 1 shall wear sturdy low-heeled (1 /4 inches max) shoes with a closed steel toe and a closed heel. 4.8.6 Contractor / Supplier personnel assigned to work in the shop, manufacturing, or maintenance areas shall wear ankle-length pants and tops that cover the body from the waist up and over the shoulders. 4.8.7 Contractor / Supplier personnel directly involved with or exposed to moving machinery / tools shall not wear loose-fitting clothing or jewelry. 4.8.8 Contractor / Supplier personnel working with all electrical equipment shall conduct follow all guidelines as specified by OSHA, NEC, and NFPA standards. This includes but is not limited to the PPE requirements for Electric Arc and Flash protection. 4.8.9 In addition to PPE, Contractors / Suppliers working with chemicals should know the location of the nearest eyewash, safety shower, and decontamination areas on company property. 4.9 Hazard Communication 4.9.1 Each Contractor / Supplier shall make available to GKN and other Contractors / Suppliers at the work site, a copy of its Hazard Communication Program and list of hazardous chemicals, explosives, x-ray or laser equipment that is intended to be used at the site. Each Contractor / Supplier must comply with all aspects of the OSHA Hazard Communication Standard. 4.9.2 Contractors / Suppliers shall supply GKN with copies of the Material Safety Data Sheets (MSDSs) for any chemicals requiring an MSDS that they bring on site. GKN will maintain a file of MSDS’s for chemicals used at GKN-St. Louis. MSDS’s are available for review by contacting the GKN Project Manager. / Sponsor. GKN’s written Hazard Communication Program and Hazardous Materials List can be provided by the GKN Project Manager / Sponsor upon request. 4.9.3 Contractors / Suppliers may bring onto GKN premises only the minimum amount of hazardous materials necessary to do the job. Chemicals and gases must be properly labeled and stored according to OSHA requirements and in compatible, sturdy, closed containers. All chemical containers belonging to the Contractor / Supplier that remains on site must be labeled with the Contractor’s / Supplier’s name, a contact phone number, and a contact name. 4.9.4 Flammables and combustibles, including fuels, must be kept in closed metal containers and away from possible ignition sources. 4.9.5 All gas cylinders must be staged in the upright position, secured by a chain to prevent falling, with the valve guard in place (if so equipped). 4.9.6 Contractors / Suppliers must remove all raw chemicals / products from company property after the work is completed. 4.10 Confined Spaces MI 7.1-66 (a) Rev B Page 8 of 12 4.10.1 If a Contractor / Supplier will be performing work in a confined space, the GKN Project Manager / Sponsor must be contacted 48 hours in advance of the entry to obtain any available information regarding the confined space. Compliance with confined space entry requirements is the responsibility of the Contractor / Supplier and must meet all OSHA standards for confined space entry, including properly trained personnel, as well as all requirements outlined in MI 6.1-29, Confined Space Entry. 4.10.2 Monitoring and ventilation equipment appropriate for the conditions in the confined space must be provided by the Contractor / Supplier. 4.10.3 A confined space standby person must be provided by the Contractor / Supplier in accordance with the Confined Space Regulation 29 CFR 1910.146. 4.11 Lockout / Tagout 4.11.1 All energized equipment or sources, which would present a hazard from inadvertent activation during maintenance or servicing, must have all sources of energy locked and tagged out except where power is needed to troubleshoot or service equipment. This includes electrically powered equipment as well as non-electrical energy sources such as hydraulic, steam, pneumatic, mechanical and chemical. 4.11.2 Contractors / Suppliers are responsible for supplying their own locks, tags, and other proper lockout/tagout equipment and training. 4.11.3 A High Voltage Permit must be issued to a Contractor / Supplier by GKN Facilities before any employee of the Contractor / Supplier performs any work on an Electric “Load Center Unit Substation”. This includes all 4160V primary components as well as all 480V secondary components of the “LCUS”. All scheduled outages must be coordinated through GKN Facilities Engineering with a minimum of 24 hours advance notice. 4.12 Asbestos 4.12.1 GKN considers all insulation on thermal barriers, troweled on or sprayed-on surfacing and asphalt or vinyl flooring manufactured prior to 1980 to contain Asbestos. When activities require either damaging or incidental contact with these Presumed Asbestos Containing Materials (PACM) or other known or suspect asbestos material, contact the GKN Project Manager / Sponsor for specific instruction regarding these materials before proceeding. 4.12.2 If unanticipated PACM is found and incidental contact becomes apparent, the Contractor / Supplier shall cease work and contact the GKN Project Manager / Sponsor. 4.12.3 In the event of an emergency situation involving a release or unanticipated discovery of asbestos fibers, the Contractor / Supplier shall immediately vacate the areas, dial 911 from an internal phone, and provide the dispatcher with any information the Contractor / Supplier may have. The Contractor / Supplier shall then contact the GKN Project Manager / Sponsor. 4.12.4 For work, which involves ceiling and the ceiling space, the Contractor / Supplier shall contact the GKN Project Manager / Sponsor for any additional safety requirements. 4.12.5 Asbestos projects require appropriate regulatory notification and issuance of a permit before such work can begin. Work practices to be used and any deviations from standard work practices must be approved by GKN before this notification form is submitted. Contact the GKN Project Manager / Sponsor to coordinate the work. 4.12.6 A Certified Asbestos Inspector must perform collection of samples to determine the presence of Asbestos. Contact the GKN Project Manager / Sponsor for assistance in sample collecting. 4.13 If Asbestos waste is generated, disposal will be in accordance with all applicable local and federal regulations. Responsibility for disposal of asbestos containing material (ACM), will follow contractual agreements entered into by the contractor/supplier and GKN. 4.14 Lead Based Paint 4.14.1 A collection of samples to determine the presence of Lead will be performed before work can begin. 4.14.2 If Lead is found and incidental contact becomes apparent, the Contractor / Supplier shall cease work and contact the GKN Project Manager / Sponsor. MI 7.1-66 (a) Rev B Page 9 of 12 4.14.3 For any project, which can generate Lead waste, GKN will arrange/provide for proper disposal, containers, labels, or technical assistance. 4.15 Excavation 4.15.1 Contractor / Supplier must contact the GKN Project Manager / Sponsor prior to any excavation work. 4.15.2 All excavations must be protected by barricades or barricade type. 4.15.3 All excavation activities must comply with OSHA 1926.650 Subpart P. 4.15.4 No soils can be removed from GKN Property without prior approval from the GKN Project Manager / Sponsor. See MI 6.1-34, Management of Excavated Soils. 4.15.5 Prior to personnel entering an excavation of 5 feet or more in depth, personnel must be protected by protective support systems, such as sloping, shoring and/or bracing. 4.15.6 All excavation waste must be pre-screened prior to off site disposal. Samples to be collected by GKN environmental engineer. 4.16 Roof Access 4.16.1 No Contractor / Supplier personnel is allowed to access the roof of any building without authorization from the GKN Project Manager / Sponsor. 4.17 Pre-job Safety Meeting 4.17.1 Before the Contractor / Supplier begins any work, it is important that the Contractor / Supplier be familiar with the hazards of the job and how to avoid injury. A mandatory safety meeting with the GKN Project Manager / Sponsor is required prior to the start of any job to discuss rules and procedures, special work permits, job hazards, and the documentation of the required certification and training. 5.0 Environmental Protection 5.1 General 5.1.1 All contact with environmental regulatory agencies will coordinated through GKN Environmental Services. 5.1.2 All hazardous materials (including fuels/oils) will be stored/contained in a manner to prevent accidental discharge/release. Incompatible materials will be stored/contained at a safe distance from each other. 5.1.3 Disconnecting or interruption of environmental controls and equipment (pH/ORP probes, tank monitoring systems, flow measurement) must be coordinated with GKN. Contact the GKN Project Manager / Sponsor to coordinate with Environmental Services. 5.2 Air Emissions 5.2.1 Any project, which will result in the release of dusts, vapors, fumes or other emissions, shall be approved by the GKN Project Manager / Sponsor prior to commencement. 5.3 Waste Management 5.3.1 5.3.2 MI 7.1-66 (a) Rev B General 5.3.1.1 Contractor / Supplier shall not bring any waste onto company property. 5.3.1.2 Contractor / Supplier shall not abandon waste or place it in or near GKN storage facilities without following the proper GKN procedures. Hazardous Waste 5.3.2.1 Disposal of hazardous wastes shall be the responsibility of the Contractor / Supplier. Hazardous waste generated by the Contractor / Supplier shall not be placed in any GKN container unless prior approval is obtained from the GKN Project Manager. 5.3.2.2 Contractor / Supplier is responsible for ensuring that no project generated hazardous Page 10 of 12 waste is placed in any GKN container. Such waste shall be removed from the site by the Contractor / Supplier. 5.3.3 Non-Hazardous Solid Waste 5.3.3.1 Disposal of non-hazardous solid wastes and demolition debris shall be the responsibility of the Contractor / Supplier. Solid waste generated by the Contractor / Supplier shall not be placed in any GKN container. 5.3.3.2 Non-Hazardous waste generated by the Contractor / Supplier shall not be left on site at the conclusion of a project and shall be removed from the site by the Contractor / Supplier. 5.4 Wastewater Discharges 5.4.1 Contractor / Supplier shall not discharge any material to GKN sewers and / or drains. The GKN Project Manager / Sponsor will define exception(s) prior to commencement of the project. This includes, but is not limited to, wastewater generated from motorized floor scrubbing equipment. 5.5 Potable Water 5.5.1 Contractor / Supplier shall not engage in activities which would result in cross contamination or other degradation of the drinking / potable water supply. 5.5.2 Contractor / Supplier shall use backflow prevention devices as necessary. 6.0 Fire Prevention 6.1 General 6.1.1 Good housekeeping is an important part of fire prevention. Contractor / Supplier shall keep work areas clean and dispose of smoking material only in approved containers. Trash will not be allowed to remain in any building overnight. 6.1.2 Contractor / Supplier shall not store materials and equipment where they obstruct access to firefighting equipment, electrical control panels, ladders, safety showers, or emergency stop devices. 6.1.3 Contractor / Supplier shall keep aisles, fire lanes, and exits clear at all times. Contractor / Supplier shall become familiar with emergency exits in the area in which Contractor / Supplier is working. 6.1.4 Contractor / Supplier shall not remove or tamper with fire extinguishers or alarms unless authorized by the GKN Project Manager / Sponsor. 6.1.5 Only proper explosion rated or intrinsically safe electrical equipment may be used in areas such as paint booths where explosion proof electrical systems are required. 6.1.6 Sprinkler and Fire Main Impairments: 6.1.6.1 Work resulting in the impairment of Sprinkler Systems and the GKN Private Fire Main require the approval of GKN Fire Services. Twenty-four hour advance notification during the conventional work week is required for scheduling purposes. Work should be planned and scheduled to minimize the length of such impairments. 6.1.6.2 No work shall be performed that will interrupt the water supply to the GKN Private Fire Main or individual sprinkler systems, without first notifying GKN Fire Services for approval. 6.1.6.3 Only a GKN Fire Services representative can authorize the operation of Fire Main and Sprinkler control valves. During an Emergency situation, a Contractor / Supplier is authorized to operate such valves when acting in the best interest of the company with the intention to minimize damage to GKN property. 6.1.7 Shoes, which are equipped with metal toe and/or heel plates, shall not be worn in flammable vapor areas (paint booths, mix-rooms, etc.) and are to be restricted to the appropriate work areas, restrooms and cafeterias. 6.1.8 Should it become necessary to block or restrict access to any gates, fire lanes, and roadways, the GKN MI 7.1-66 (a) Rev B Page 11 of 12 Project Manager / Sponsor as well as GKN Security shall be notified prior to the start of the task. 7.0 Security / Site Access 7.1 Badging 7.1.1 The Contractor / Supplier will use GKN Gate 2 to access a job site located within the secured perimeter of the Complex. Gate 2 will be utilized unless instructed otherwise by the GKN Project Manager / Sponsor. Contractor / Supplier personnel shall be required to obtain GKN security identification badges and wear them while on GKN premises. Badges will be furnished by the GKN Security Department. Contractor / Supplier personnel shall be restricted to the appropriate work areas, restrooms, and cafeterias. 7.1.2 Contractor / Supplier personnel are responsible for returning GKN identification badges to GKN Security Departments upon completion of the contract. There is a fee for lost or non-returned badges. Contractors / Suppliers will be held accountable for immediately notifying GKN Security Department in the event of the dismissal and/or termination of any personnel possessing a GKN identification badge prior to the completion of the job. 7.1.3 Contractor / Supplier personnel shall park only in Parking Lot 6 at the eastern most section of the GKN Complex. Contractor / Supplier personnel are only allowed access to the secured perimeter of the Complex at GKN Gate 2. 7.2 Searches 7.2.1 All vehicles and/or equipment are subject to search by GKN Security at any time. 7.3 Confidentiality 7.3.1 MI 7.1-66 (a) Rev B It is the responsibility of all Contractors / Suppliers and their personnel to take measures to protect confidential information and material, which, if disclosed, could be detrimental to company interests. Generally all information that is not public knowledge shall be treated as confidential and shall not be released or removed from GKN property. This may include, but is not limited to, prep sheets, process sheets, planning information, marketing information, technical reports, or any other potentially sensitive information that Contractors / Suppliers or their employees may have access to while working at GKN sites. Any violation of this confidentiality obligation is a serious offense and may result in prosecution. Page 12 of 12