Appendix IIa

8/13/2019 Appendix IIa

1/43

Appendix IIa: Guidance Document

Section 1.0

General

1.a This section gathers basic information on the facility being audited, including contact information and

NAICS (North American Industry Classification System) codes, which may be obtained from the NorthAmerican Industry Classification System Manual. The manual is a classification system used by

government and industry covering the entire field of economic activities and defines industries by

classification. The last publication of this manual was in 1997. It is sold by the National Technical

Information Services, 5285 Port Royal Road, Springfield, VA 22161, USA. Order No. PB87-100012. If no

classification code is available for the principle products manufactured by the factories being audited,

auditors could refer to the information listed in provision 1e of Appendix II Auditor Checklist.

1.b This section requests an organizational chart for the facility being audited.

1.c This section determines the maximum and minimum number of personnel in the facility being audited

within a calendar year.

1.d This section provides information as to what language(s) are spoken at the facility being audited for

purposes of proper staffing of the audit team.

1.e This section determines the type of production processes in the facility being audited.

1.f This section requests a schematic layout of the floor plan of the facility being audited.

Section 2.0

Working Hours

2.1 The facility should have access to the local laws on the subject of working hours for the respective

country/region The facility should have a written policy and/or procedure on the subject of working

hours and overtime. Record the date of issue. Compare the working hours allowed by the policy to the

working hours allowed by the local law to determine if the standard legal requirement is met. Record

both for reference purposes. The dates of the law and written policy should be compared to make

certain that current policy is appropriate.

2.2 The legal working hours and the facility working hours should be posted and/or made available to all

employees.

2.3 Time worked for each non-supervisory employee should be documented through the use of a time card

or other mutually worker/management verified documentation.

2.4 Overtime should be worked on a voluntary basis. For example, this may be accomplished by worker

acknowledgement and agreement of overtime expectations during the hiring process. Document

overtime procedures.

2.5 Determine what the maximum number of working hours is per day and per week. The number of

working hours per day and per week should be within legal requirements and the companys written


2/43

policy. In the absence of a legal standard, a factory worker should not work in excess of 66 hours per

week.

2.6 Determine what the maximum number of working hours is per month. The number of overtime hours

worked per month should be within legal requirements and the companys written policy. In the absence

of a legal maximum for hours worked per month, this section is not applicable.

2.7 Workers are entitled to one day off in seven. If local law allows, this does not prohibit a worker from

voluntarily working overtime on a rest day(s).

2.8 Employees should be permitted time off if they are sick. It is reasonable for employees to provide

evidence of illness by producing a doctors note justifying the absence.

2.9 It is expected that workers are permitted to take one main meal break per shift. Normally, 30 minutes

would be considered adequate for a main meal break. Less than 30 minutes requires further explanation.

It is expected that workers be permitted to take personal breaks for the use of the toilet and for drinking

water.

Section 3.0

Wages and Compensation

3.1 The facility should have access to the local laws on the subject of minimum wages and compensation

requirements for work. The minimum legal wage as per the local regulations should be followed at a

minimum. Record the minimum legal wage for the respective country/region. The facility should have a

written policy and/or procedure on the subject of wages and compensation. Record the date of issue.

Compare the wages and compensation allowed by the policy to the wages and compensation required by

the local law to determine if the standard legal requirement is met. Record both for reference purposes.The dates of the law and written policy should be compared to make certain that current policy is

appropriate.

3.2 The company policy and/or procedure on wages and compensation, in the local language, should be

posted and/or made available to all employees.

3.3 The wages and compensation being paid by the facility should meet legal requirements for normal and

overtime work. The dates of the law and written policy should be compared to wage and compensation

payment records to make certain that information being recorded is current. If paid piece rate,

employees wages, at a minimum, must be equivalent to minimum wage rates. Include hourly, daily,

weekly or monthly rate, as applicable. Determine if overtime is part of normal workweek or on which

days overtime is worked. Record details.

Calculation Example (using hypothetical number (in bold) of holidays, non-work days, etc.; auditor

should use correct number based on location of factory.)

Step 1- Determine the legal monthly minimum wage. In our example we will use currency Z 400 as the

legal monthly minimum wage.


3/43

Step 2- Subtract the number of annual holidays (10) and the number of non-work days weekend days

(104) from the total number of days in the year. In our case it would be 365-10holidays-104non-work

days= 251 work days. (365-10-104=251)

Step 3- Divide the number of workdays by the number of months. 251/12= 20.92 average workdays of 8

hours in each month.

Step 4- Multiply 20.92 days by 8 hours = 167.35 hours per month.

Step 5- Divide the legal monthly minimum wage (Z 400) by the total hours per month (167.35) = Z

2.39.

Overtime calculation:

a. Minimum legal monthly wage divided by 167.35 = normal time hourly rate.b. Multiply normal time hourly rate by 1.5 = normal overtime hourly rate.c. Multiply this number by 1.333 = double time hourly rate for normal Saturday and Sunday

overtime work.

d. Multiply this number by 1.5 = hourly rate for holidays

3.4 Legally required withholdings should be made. Withholdings should be correct and properly paid to the

respective agency(s). For example, these could include taxes, retirement, social security, pension, etc.

3.5 Employees should be made aware of withholdings and other deductions from wages prior to

employment. This can be evidenced by employee contracts and verification of receipt and/or knowledge

of the facilitys policy, which should subscribe to local law requirements as a minimum standard.

3.6 Deductions made from wages for food and housing must be legally allowable and reasonable. In the

absence of a law, charges for food and housing in excess of 50% of minimum wage (excluding overtime

and bonuses), should be thoroughly investigated.

3.7 Deposits for company provided items such as security deposits for personal protective equipment (PPE),

uniforms, and identification cards are not allowable. However, the cost of replacement items, if lost by

the employee, as well as any lost identification card or lost uniform, may be charged to the employee at

no more than cost.

3.8 Legally required benefits should be provided to the employees. These benefits may include medical

insurance, bonus, vacation time, etc. Document details of findings.

3.9 The facility should provide pay stubs to the employees, which clearly shows gross wages, regular hours

worked, overtime hours worked, withholdings, and deductions made. In the case of piece rate system, it

is recommended that the legal minimum wage equivalent is shown along with the piece rate details.

3.10 Employees should be paid in a timely manner, which is considered to be not more than 30 days following


4/43

the work period.

3.11 Wages should be made readily available to employees in the form of cash, check from a local bank, or

directly deposited to the employees account.

Section 4.0

Underage Labor

4.1 For informational purposes, determine if there is a compulsory age for schooling. Record what the

compulsory age for school attendance is in the respective country/region

4.2 The facility should have access to the local laws on the subject of legal minimum working age, which

should be in accordance with C138 Minimum Age Convention of the International Labour Organization.

Check that no one under the minimum legal age for work or mandatory schooling is employed. Where

local minimum age law is set at 14 years of age, the conditions for developing country exceptions of ILO

Convention C138 will apply. The facility should have a written policy on the subject of minimum age to

work. Compare the age allowed by the policy to the age allowed by the local laws to determine if the

standard requirement is met. Record both for reference purposes. The dates of the laws and written

policy should be compared to make certain that current policy is appropriate.

4.3 If there is no legal minimum age, the ICTI Code of Business Practices has established 14 as the

minimum age, when in accordance with ILO Convention C138.

4.4 Determine if the law and/or policy has been communicated and generally understood by all employees.

Acceptable means of communications include verbally (prior and/or on commencement of employment)

and visibly displayed to workers, e.g. on notice boards or in libraries.

4.5 Select a minimum of three of the workers youngest in appearance. Review their identification cards for

their age. Record this information.

4.6 A young worker is defined as one above the minimum age, and typically below the age of 18. If there

are legal work restrictions for employees of certain ages, they should be followed. There may be

restrictions, for example, working on heavy machinery, night work, overtime, etc.

4.7 Ages of employees should be on file. Review the employee files and support documentation. Compare

the employee records on file to worker identification cards. Record what types of information are kept on

file to verify age of employee.

Section 5.0

5a. Forced Labor

5.1 The facility should have access to the local laws on the subject of forced labor for the respective

country/region. Record the date of the local law on file. The facility should have a written policy that

supports the ICTI codes position that no forced labor shall be used. Record the date of issue.


5/43

5.2 Workers should be voluntarily employed. Check that no forced labor is employed Determine if there are

unreasonable restrictions placed on the employees relating to their freedom of movement. Check that

workers are free to leave the factory site once their shift ends. Determine if the employees are permitted

to take their meal breaks and/or rest breaks as scheduled. Determine if the employees are permitted to

freely enter and exit from their housing facilities during their non-work hours and within curfew hours

Check that guards are posted only for normal security reasons. Check that workers are not required to

lodge unreasonable deposits or ID papers and may leave after giving reasonable notice. Check if the

factory holds any identity cards. Determine if these are given on a voluntary basis and are returned to

workers on request. Randomly select a minimum of three workers. Review their identification cards and

employee files to determine if they are present voluntarily. Record this information.

5.3 The facility should not use bonded labor. Determine if there are unreasonable contracts based on

indebtedness of worker families or contracts with significant financial repercussions or paybacks, which

force the individual to work against their will to repay their debts.

5.4 Reasonable notice is that defined by law or, in the absence of local law, the length of interval between

payments to the worker. For example, if workers are paid every 30 days, 30 days would constitute

reasonable notice.

5.5 Security personnel and supervisors should not force or coerce workers. Normally, security staff should be

present for the purpose of preventing unauthorized persons and vehicles from entering and exiting the

site and to guard against theft at the site. Security staff should not be used to restrict movement or

force employees to work.

Section 5.0

5b. Prison Labor

5.6 The facility should have a written policy and/or procedure on the subject of prison labor, both in their

facility and subcontracting to prisons or facilities where prison labor is used. The dates of the law and

written policy should be compared to make certain that current policy is appropriate. Record the date of

issue. Compare the subcontracting policy to the facilitys own on the subject of prison labor

requirements. Record details. .

5.7 Neither the facility nor its subcontractor sites should use prison labor. Determine if the facility uses

prison labor.

Section 6.0

Disciplinary Practices

6.1 The facility should have access to any local laws on the subject of disciplinary practices for the respective

country/region. The facility must have a written procedure, which includes freedom from mental and

physical abuse. The procedure should address, at a minimum, fines, formal warning procedures, grounds

for contract termination, guidance on unacceptable behavior, appropriate disciplinary actions for


6/43

unacceptable behavior, and complaint procedure including method of investigation and resultant actions.

6.2 Determine if the procedure has been communicated and generally understood by all employees.

Acceptable means of communication include verbal (prior and/or on commencement of employment)

and readily available to workers, e.g. on notice boards, in libraries, or in an employee handbook.

6.3 Corporal punishment and physical coercion should not be used. Any verbal or visual indication of injury

should be corroborated /investigated through the use of records or other objective evidence.

6.4 The facility should not allow threatening behavior of any kind. Examples of unacceptable behavior would

be gestures, abusive language, and physical contact, that is threatening, abusive, or exploitative.

Observe interaction between management and subordinates and between fellow workers.

6.5 Disciplinary measures should be taken through normal management practices. The security staff should

not be used to issue discipline to workers. Check security staff contracts for assigned duties and

responsibilities. Interview security staff regarding their duties. Determine who is responsible for

administering discipline and the extent of their responsibilities.

6.6 Disciplinary fines must be legally allowable, in line with the facilitys policy, and reasonable. Where fineshave been used, the auditor should record the amount of the fine and the corresponding offence. Any

fines that exceed the legal maximum should be explained.

Section 7.0

Discrimination

(Explanatory Note for this Section: Regarding the discrimination in the facility, special attention should be paid to the

current situation and business environment in the countries where factories would be audited.

Employees from overseas, say the United States, working in these countries carrying out the same level of work are

paid in different wage levels and welfare when comparing with the employees from these countries.

It is not a matter of discrimination but truly reflect the difference between their living standards of home country.)

7.1 The facility should have access to the local laws on the subject of discrimination in the workplace. The

facility should have a written policy and/or procedure on the subject of discrimination and be posted

and/or made available to all employees in the local language. Record the date of issue. The policy should

comply with the local laws, covering, for instance, discrimination in hiring, compensation, access to

training, promotion, termination, or retirement, or any other aspect of employment based on race, caste,

national origin, religion, age, disability, gender, marital status, pregnancy, sexual orientation, union

membership or political affiliation.

7.2 Facilities should follow local and national laws regarding discriminatory employment practices. There

should be no evidence of discrimination in recruitment practices. Through interviews with the

recruitment personnel, and checks on recruitment documentation, there should be no indication of

patterns of discriminatory practices. Check wage records for evidence of discrimination; e.g. differing

wage levels or fines for different groups carrying out the same level of work (this does not include wage


7/43

differences for expatriate workers). Check promotion/demotion records. Check to ensure workers are

able to observe legal religious holidays. Check for evidence of harassment (including sexual harassment),

coercion or threatening behaviour towards specific groups of workers. Check that there is a mechanism

for filing of complaints about discrimination. Check that records exist and that these complaints have

been effectively addressed. There should be no discrimination in termination. Check termination records

for patterns of discriminatory dismissal. Reasons for dismissal should be documented.

Section 8.0

Employee Representation

8.1 Employees should have the ability to approach management on issues of concern without fear of

retribution. Various ways in which employees could approach management include trade unions,

employee committees (grievance, safety, etc.), or employee selected representatives, regular meetings,

etc.

8.2 There should be representative(s) of the employees, who are freely selected and participate voluntarily

and communicate with management on related issues. Employee representations should be

representative of the plant population including workers.

8.3 There should be management representative(s) designated to interface and communicate with the

employee representative(s) on related issues. Management representation should be the same personnel

or same identified authority.

8.4 Meetings should be scheduled between management and employee representative(s) on a regular basis,

at least quarterly. Meeting minutes should be on file.

8.5 Employee representative(s) should be aware of the ICTI Code of Business Practices and its supportingdocuments. This may be accomplished through the facility issuing its own policies and/or procedures to

be in compliance with the ICTI Code, in which case this would be considered the facilitys equivalent

documentation.

8.6 Management should review and consider issues of employee concerns relating to the ICTI Code of

Business Practices, when brought to their attention. Some examples of systems, which would accomplish

this, would be an employee grievance procedure or suggestion system. There should be objective

evidence that management takes appropriate action on such matters.

8.7 Employee representatives should be treated equally with all other employees. Assessment may include

information obtained from employment records (e.g., disciplinary notices, termination, fines, type of

work assigned) and employee interviews

Section 9.0

Facilities

9.1 The facility should have access to, and a system to remain current with the local laws and have


8/43

developed a policy statement on the subjects of health, safety, environmental, and working conditions,

indicating managements commitment to following local laws at a minimum. The policy statement should

be signed by the senior manager of the facility.

9.2 There should be a senior management representative(s) responsible for matters of health, safety,

welfare, and general facilities.

9.3 All areas should appear generally clean and in good condition. General housekeeping conditions of a

facility are a good indicator as to how the facility is operating as it relates to keeping areas safe for its

employees. Dust, shavings, and scrap material generated during operations should be collected in

appropriate receptacles and disposed of in a timely manner. Engineering controls such as dust collection

systems or automatic scrap collection systems should be provided where practicable at the source.

Walkways should be kept clear of stored materials, tools and equipment. Walkways should be free of

tripping hazards such as debris, scrap, cables, hoses, rope, chains, etc. Walkways should be free of

slipping hazards such as oil, grease, water, papers, granular materials, etc. Pay particular attention to

slipping and tripping hazards in the area at the top of stairs. Manufacturing, storage, and yard areas

should be free of debris, scrap, refuse, garbage and other foreign matter.

9.4 Facility housekeeping inspections should be conducted for all areas on a periodic basis. Alternatively,

written housekeeping procedures and schedules would satisfy this requirement.

9.5 The facility should have an appropriate number of trained personnel assigned to the responsibility of

maintaining and/or repairing in the event of machinery breakdowns or emergencies. For safety purposes,

the facility should only permit the trained personnel to maintain and repair the machinery. The desired

number of personnel will be dependent upon the size of the facility and type of machinery present, with

appropriate training to be provided for such maintenance personnel. Machinery safety equipment should

be well maintained, which would include a regular daily inspection to ensure it functions correctly. Safety

check record should be kept.

9.6 Good communications are necessary as a means of alerting occupants of an emergency, and as a way to

mobilize emergency services such as a fire department or brigade, police, ambulance, etc. Means of

communication should be available throughout the facility in accessible locations, and employees should

be trained in the proper method of using the communication systems available in the facility. For

instance, all employees/workers should know how to raise the alarm internally, and designated

employees trained in further communications. It is recommended that emergency telephone numbers be

posted along with directions for use of the communications system in the event of an emergency.

9.7 Safe ambient air temperatures should be provided in occupied areas of the facility. Determine if there

are local laws relating to heat and cold temperatures limits for a facility. If so, those local laws should be

followed. Temperatures within the limits of the chart below would be deemed to be safe. When

temperatures are outside these limits, management should establish a formal process for adjusting thethermal environment to prevent temperature stress. Engineering controls such as fans, air movers, and

air conditioning should be considered first. Administrative controls should also be considered.

Modification of work-rest schedules and the number and/or duration of tasks are examples of

administrative controls, which can reduce worker temperature exposures. Another administrative control

is the postponing of non-critical tasks until the work environment heat stress level has improved. Work

practice controls such as special personal protective equipment and clothing may also be used to reduce

temperature stress but should be considered as the least effective control means.


9/43

Functional Area

Cold Stress Limit

(Dry Bulb Temperature)

Heat Stress Limit*

(Wet Bulb Globe

Temperature)

Manufacturing - Sedentary 16C 30C

(e.g., sewing, rooting,

assembly)

(61F) (86F)

Manufacturing - Light 4C 30C

(e.g., VUM, molding, die

casting)

(39F) (86F)

Manufacturing - Moderate 4C 30C

(e.g., rotomolding) (39F) (86F)

Warehouse 4C 29C

(39F) (84F)

Office 16C 31C

(61F) (88F)

*If the person is determined by medical personnel to be more tolerant to work in heat than an

average worker, then you may add 1C (2F) to the limit.

9.8 Ventilation should be provided in work areas. Ventilation may be in the form of general ventilation or

local exhaust ventilation. Where airborne contaminants are being generated, local exhaust ventilationshould be provided to capture and remove the contaminant before it is released into the work

environment. Airborne contaminants include dusts, vapors, gases, fumes, etc. When airborne

contaminants are not being generated, general dilution ventilation should be provided to provide fresh

air from outside. You should have sufficient outside air per occupant or you could measure the

contaminants of concern. If there is any concern that ventilation is not adequate, measurements can be

taken if necessary to ensure that the ventilation and concentrations are meeting one of the following two

limits a) or b):

a) For Air Conditioned or Forced Air Heated Premises - Outside Air Per Occupant

FUNCTIONAL AREA MINIMUM Cubic Feet Per Minute (CFM) per PERSON

General Office

General Factory

Restrooms

Warehouse

Cafeteria

Kitchen / Food Preparation

20 cfm (10 L/s)

14 cfm (8 L/s)

40 cfm (24 L/s) per w/c or urinal

14 cfm (8 L/s)

14 cfm (8 L/s)

14 cfm (8 L/s)


10/43

b) Indoor Air Quality Monitoring

Measurements are taken annually in the course of a normal working day to ensure that the

concentrations of specific contaminants are below threshold limits in the general office, general factory,

restrooms, warehouse, cafeteria, and kitchen/food preparation:

CONTAMINANT MAXIMUM CONCENTRATION

Carbon dioxide (CO2)

Carbon monoxide (CO)

1000 ppm

9 ppm

9.9 Lighting should be adequate for all areas where work is conducted. The greater the detail of work, the

more light that is generally needed. Where the general lighting is not adequate for the work being

performed, task lighting should be provided at the workstation. In addition, lighting in hallways, aisles,

and exit lights should be provided, should an emergency arise.

9.10 Refuse should be collected and removed from the facility on a regular basis and sent to an appropriate

location for disposal. The type and amount of refuse generated will determine the appropriate amount of

time between collections. Refuse should be collected and held in an area where odors will not migrate

into work areas until it can be removed from the facility. Also, refuse collection areas should be located

in areas that will not attract pests into the facility. Auditors should note the date of last collection from

facility records.

9.11 The physical and structural integrity of all buildings should be assessed by a professional to ensure that

the buildings are capable of housing the machinery and people within it. Local, regional or national

regulations should be consulted to determine the qualifications or licensing needed to carry out such an

assessment. If there has been a significant change in the use of building, reassessment is required. The

physical condition of buildings and surrounding property such as walls, floors, driveways, sidewalks, etc.

should be maintained free of damage which can cause personal injury. Holes, uneven surfaces, andcracks can cause hazards if left in disrepair. A copy of assessment results should be maintained on file by

site management. Record the date of issue.

9.12 The boilers, unfired pressure vessels, and furnaces should have been assessed annually by a professional

to ensure that they are being maintained in proper working condition. A copy of assessment results

should be maintained on file by site management. Record the date of issue. In the absence of a local

professional, a professional from another jurisdiction may do the assessment.

9.13 Floors should be designed to carry anticipated loads safely. The weight of materials, machinery,

equipment, forklifts, people, etc. needs to be analyzed to determine the structural needs. A professional

should have assessed floor-loading requirements. Once assessed, signage should be in place indicating

the allowable floor loading. Determine if the facility is adhering to its floor loading weight limits as

outlined above. Review the last periodic review to ensure floor-loading weight limits have been adhered

to. Also, compare the area to see if there have been any significant changes to its use since the last

periodic review, which could indicate that a reevaluation could be necessary.

9.14 Records of any violations, penalties, or citations of the facility not being in compliance with local laws

should show objective evidence that they have been corrected within the required time established by

the citing authority. Auditor should record instances where the same violation has occurred repeatedly.


11/43

Periodic follow-up by management should be made to ensure that violation has not reoccurred.

9.15 Employees should have access to potable water for drinking purposes. Potable water should meet the

local drinking water standards for the area that the factory is located (Testing for the chemical detection

levels according to the local standards can be done by the local water authorities). In the absence of a

local standard, the factory should comply with the standards found in Exhibit A. Certification should beavailable based on annual sampling and testing of not less than one drinking water spigot per production

facility and dormitory, if any. Potable drinking water dispensers should be designed, constructed, and

serviced so that sanitary conditions are maintained. Containers which are uncovered and can be left

open are not acceptable as they may become contaminated. Water should be within a reasonable

distance for employee access. This applies to facilities and, where provided, dormitories. (Note: It is

anticipated that priority should be given to the local standards over any other standards. Reference to

any particular laboratory should not be part of the Guidance Document.)

9.16 Toilet facilities should be provided with an adequate quantity for each gender based on the number of

employees of each gender. An adequate quantity relates to the number of employees. For instance,

certain regional regulations indicate one toilet for every 24 persons up to 100 persons employed, with an

additional one for each additional 40 persons employed over 100 persons. This should suffice as a

guideline in determining adequate quantities. However, where regulations are more specific, the

regulations should be followed at a minimum. The sewage disposal method should not endanger the

health of employees. Toilet facilities should be maintained in a functional, clean condition, and be free of

foul odor. No food or beverage should be stored in toilet rooms. This applies to facilities and where

provided, dormitories.

9.17 Hand washing facilities should be provided. Hand washing facilities should be maintained in a functional

and sanitary condition, and located around the toilet facilities area in facilities and dormitories. Provision

of cleansing materials for washing and drying of hands should be considered in the toilet/washroom of

production areas. The production of toys for children must be conducted with good hygiene.

9.18 Security personnel should be trained in their roles and responsibilities and these should be recorded.

Training should include emergency response and protecting facilities from unauthorized entry. Care

should be taken in training security personnel in handling situations appropriately without any

unnecessary aggression. This may include fights, smoking in non-smoking areas, or excessive noise.

Where security personnel are used to monitor dormitory safety, further care should be taken to ensure

there is no abuse of residents privacy or free access and use of facilities.

9.19 If local regulations and/or facility management prohibit smoking in the workplace, management should

ensure this is communicated to all personnel and enforced. If local regulations permit smoking,

designated areas should be established for smoking. These designated areas must be located away from

flammable and/or combustible materials, and be formally posted Designated Smoking Area. All use and

storage locations of flammable and combustible materials and wherever danger could be caused by

ignition must be identified and posted with appropriate NO SMOKING signs. Management must ensure

that all personnel adhere to the posted safety warnings. Note whether or not there is any evidence of

smoking in areas where it is not permitted.


12/43

Section 10.0

Fire Protection

10.1 Management should establish an overall written program to address fire hazard and preparedness for

emergencies. Emergency actions should include a written plan listing, in detail, the procedures to be

taken in the event of a fire. An example program can be seen in the ICTI Industrial Fire Protection andEmergency Preparedness Survey Guide.

Emergency Plan Contents:

a) Facility information describes key elements of the facility. This is useful for new employees and response

agencies, such as local fire departments.

b) Information so that employees know how to report an emergency. This may include the activation of pull

alarms or notifying the facility security center. Consideration should be given to methods of notifying

local agencies such as the fire department.

c) Alarms and signals to alert employees should be identified; this may include audio alarms, highly visible

lights, and/or a public address system. Consideration should be given to the potential for loss ofelectrical power in the event of a fire and alternatives and back-up to mains powered alarms should be

in place. Management and employees should know what actions to take when an emergency alarm is

activated.

d) All emergency phone numbers should be identified, listed in the emergency preparedness plan, and

posted. All employees should know how to report an emergency. Emergency phone numbers should

include any facility numbers, local agencies, and any emergency-facility personnel.

e) All responsibilities should be clearly defined for management and employees. Management should

determine its strategy for responding to fire emergencies.

f) A chain of command should be established to minimize any confusion. Personnel should be identified to

coordinate the emergency-response actions.

g) Detection and alarm systems should be identified and described. Testing and preventative maintenance

procedures should be included.

h) Diagrams should be developed for critical information. Evacuation routes, exit doors, fire extinguishers,

and other critical elements should be visually displayed for all employees. If the fire sprinkler system or

standpipe system is used, all critical controls/valves should be clearly identified.

i) Assembly areas should be established for all employees. Accounting for employees can be performed at

assembly areas. All assembly areas should be established at safe distances from fire hazards and clear of

emergency vehicle traffic and activities.

j) Search and rescue procedures should be established. Only trained and authorized personnel should

attempt search and rescue.

k) Procedures for shutting down equipment during emergencies should be established. Equipment

operators should know the proper actions to take during an emergency.

10.2 Managers, supervisors, and employees should be knowledgeable and informed of fire prevention

procedures. Fire protection procedures should include hot work permits, storage and handling of


13/43

combustible materials, housekeeping, fire extinguisher, and fire hazard identification. All employees

should understand basic emergency action plans including alarm signals, emergency shutdown,

primary/secondary exit routes, and assembly areas pertaining to their work assignments. All employees

should know how to safely evacuate from their work areas during emergencies.

10.3 A coordinator should be designated to assist management in assuring that all elements of the fireprotection and emergency preparedness program are in place and working. The coordinator should have

recognized training of emergency preparedness planning and all elements of the facility's fire protection

plan.

10.4 The alarm system to notify employees of emergencies and evacuations should be clearly recognizable

during emergency conditions. Horns, sirens, public announcement systems, or other alarm devices

should alert employees of an emergency. Consideration should be given to the potential for loss of

electrical power in the event of a fire and therefore back-up alarms should be in place. All alarm

systems and fire protection systems should be maintained and tested on a regular basis.

10.5 Emergency lights should be available to illuminate emergency exit paths. All emergency lighting should

be maintained and tested at least monthly.

10.6 Exit paths should be illuminated to assist people in traveling to the emergency exit doors. All illumination

should be reliable during an emergency. Exit paths should be clearly identifiable and clearly marked with

visible signs if the path is not immediately apparent. Floor markings and arrows are often used to direct

people to the emergency exit doors. Exit paths should be clear and consideration should be given to

adequate path width for occupancy. Exit paths should not be routed through boiler rooms and other high

hazard areas. Exit paths and exit doors should be distinguishable during emergency conditions. Exit

doors should be marked and illuminated to provide a visible sign during emergencies. Exit doors leading

to streets or other areas where vehicles are present should be posted to alert employees of hazard. If

possible, barriers or guards should be placed on the exit discharge to protect the employee from

vehicles. Guardrails are often used to direct the employees out of danger. Weekly inspections should be

conducted to ensure the area is free of obstructions on the exit paths, exit door, and discharge area. The

exit doors, path, and discharge should be kept clear of obstructions.

10.7 Emergency routes and exit doors should be clearly posted on a wall diagram to show employees the

primary and secondary emergency routes for evacuating the building. The diagram should show the

employees current position, emergency routes and assembly area unless the factorycan provide an

alternative way to ensure that workers know where to assemble. Each major area should display this

diagram in a highly visible area.

10.8 As a minimum requirement, two exits should be provided for each floor. This provides an alternate exit

in the event that the other exit is blocked by fire. The recommended distance to the exit should be no

more than 200 feet in an un-sprinklered industrial or general office building, or follow local fire safetyregulations, whichever is more stringent. This does not apply to small offices. The number and distance

to an emergency exit will vary by the type of hazards in the facility.

10.9 Doors and paths to be used for exiting during an emergency should be clearly marked as an exit or

escape route and workers should be trained to follow the appropriate sign during an emergency. Doors

not leading to an emergency exit should not be marked in any way that would cause workers to use

them during an emergency. If a door between departments is being used as an exit or it could be


14/43

mistaken for an exit, consider (but only if it makes sense) marking it appropriately to prevent employees

from entering during an emergency. However, training to follow one exit route is an alternative to such

NOT AN EXIT markings.

10.10 10.10 All exit doors should be free to open. Exit doors should open and swing in the direction of exit

travel and employees should be able to open the door without any special knowledge or hardware suchas keys. Exit doors should be side-hinged. Revolving doors are prohibited from serving as emergency

exit doors as they will not allow adequate and safe discharge from a building. Sliding doors and

overhead gates are not encouraged, but if they exist, they should be kept in an open position, such

that unintentional closing cannot occur whenever the premises are occupied.

10.11 Emergency evacuation drills should be conducted to ensure employees are knowledgeable and trained

on emergency plans. Emergency drills test the effectiveness of the emergency preparedness plan.

Management and employees, on all shifts, should rehearse their emergency action plans. Management

should set goals for timely exit during emergency exit drills. At a minimum, an annual drill should be

conducted during the peak season starting approximately from June through October, or more frequent

if management goals are not met. Also, an additional emergency exit drill should be considered outside

the peak period where there is a significant number of employees who have not participated in an

emergency exit drill. This is to be scheduled when more than 30% of the employees are new OR at such

time as may be determined by the management in conjunction with the EHS coordinator and is to be

conducted in the first half of the year.

10.12 To minimize fire hazards, trash (rubbish) removal should be done regularly and in accordance with the

rate of generation. Dedicated and non-combustible containers for trash (rubbish) removal should be

provided and in place.

10.13 Management should ensure that precautions, such as the availability of suitable covered metal

receptacles are provided for combustible industrial scraps, waste (e.g. oily rags) and other debris and

promptly and properly emptied and disposed of.

10.14 Excessive combustible materials should be removed from the workplace to reduce the potential for fire.

10.15 Spills and loose materials (for example, parts, waste items, etc.) should be promptly removed from all

floor areas. Spilled and loose materials can contribute to fires starting and/or spreading and also can

create slip, trip, and fall hazards, particularly during fire emergencies.

10.16 Storage containers of flammable and combustible materials should be labeled with their contents and

hazard warnings in the local language so that employees could understand the hazards and proper

handling procedures. Primary containers of flammable materials should not be combustible [a one-day

supply in closable plastic bottles is acceptable at work stations where no naked flame is present]. Glass

is not to be used unless materials involved is corrosive. When not in use, storage containers of

flammable liquids should be closed to prevent ignition and the creation of hazardous atmospheres, and

stored in suitable cabinets, containers, or buildings.

10.17 All use and storage locations of flammable and combustible materials, and wherever danger could be

caused by ignition, should be identified and posted with appropriate NO SMOKING signage.

Management should ensure that all personnel including contractors adhere to the posted safety

warnings. If smoking is permitted on site, designated areas should be established. These areas should

be located away from flammable and/or combustible materials. NO SMOKING signs should be posted in


15/43

hazardous areas where paint containing flammable/combustible materials are used.

10.18 Heat-producing equipment such as portable heaters, motors, ovens, etc., should be kept clear of

combustible materials (including dust, grease, oil, and fibers). Hazardous accumulations of dust, grease,

oil, or fibers can be ignited by electrical sources, such as arcs.

10.19 Empty pallets can pose several hazards. In addition to being combustible, pallets can be hazardous if

improperly stored on their edge or side as they may fall or tip over and strike personnel or equipment.

Pallets should be stored in safe and stable stacks in a dedicated location without interference with

sprinkler [it is recommended that stacks over 6 feet or 2 metre in height should be avoided as they may

defeat the sprinklers installed for that area]. Pallets should not be left blocking aisle ways, exit points,

emergency equipment, etc. Damaged pallets should be removed from use promptly and properly

discarded. Combustible materials (e.g. packaging) should be stored to ensure adequate access for fire

fighting. Storage practices should include proper stacking and placement of cartons and un-cartoned

goods.

10.20 All electrical wiring should be properly located, supported, and protected, so as not to create a tripping

or overhead hazard, or be struck by equipment during normal operations. All electrical leads on factoryequipment should be three-prong grounded or double insulated. Frayed and worn cords should not be

used. [Note: It is recommended that suitable written procedures and documentation should be kept to

ensure that all electrical wiring is of proper wire size, adequately insulated, properly connected, and free

of hazards. Electrical equipment and protective devices should receive regularly scheduled maintenance.

A competent electrician should be available to monitor the electrical system and provide maintenance.]

10.21 Only fixtures, plugs, circuit breakers, and other equipment which comply with recognized standards

should be used. Improper temporary wiring (e.g. bare wires in socket, without plug) should not be

permitted.

10.22 All junction boxes, outlets, and panel boards should be guarded with secured enclosures or covers.

Electrical panels, junction boxes and outlets should be readily accessible and free from obstruction.

10.23 A lightning-protection system can provide protection for circuits and electrical equipment and prevent

fires.

10.24 Only proper piping, containers, tanks, and approved rooms designed, safeguarded, and constructed

specifically for the storage and handling of flammable and combustible liquids, including waste solvents,

should be allowed for use. When not in use, containers of flammable liquids should be closed to prevent

ignition and the creation of hazardous atmospheres, and stored in proper cabinets, containers, and

buildings. All electrical fixtures, switches, and circuits inside a flammable and combustible l iquid storage

room should be appropriate for hazardous locations (i.e. explosion-proof).

10.25 Flammable liquid storage drums should be grounded and dispensing containers should be electricallybonded during dispensing or transfer of the flammable liquid to prevent the build-up of an electrical

charge.

10.26 Site procedures should include a written hot-work permit procedure. Hot-work is defined as the use,

outside of normal work areas, of flames (e.g. cutting torch, brazing) or spark-producing activities (e.g.

welding, grinding metal) which are capable of igniting combustible materials. A survey of the facility to

identify hazardous areas for hot-work activity should be completed. Hot-work in hazardous areas can


16/43

result in explosions and fires. Hazardous areas generally include areas with flammable liquids and/or

gases. Hazardous areas for hot-work activities should be posted with appropriate warning signage such

as Hot-work is not allowed without proper authorization. Flammable and combustible material should

be removed and/or protected from the hot-work. Special precautions, such as using fire-resistant covers,

to cover areas/equipment that cannot be removed from the hot-work area, and controlling potential

migration of hot sparks and slag to other floors/areas, should be taken prior to the commencement of

hot-work. The fire watch person(s) should be posted in the area to assure that the hot-work does not

initiate a fire. This often includes person(s) posted below the area where the hot-work is performed.

Depending on the hazards present, a fire watch should stay at the hot-work area for 30 to 60 minutes

following completion of the hot-work. A fire can be initiated several hours after the hot-work is

completed, if the area is not protected during the hot-work. Fire extinguishing equipment suitable for

potential hazards present should be maintained in a state of readiness for immediate use. In many

companies, outside contractors are used for hot-work activities and require full training to prevent any

risk of fire or explosion. Welding equipment should be properly used and all cables maintained in good

condition.

10.27 Cylinders with unprotected valves can pose a serious hazard when the valve is impacted. Cylinders havebeen known to break through concrete walls when their valves are broken. Content labels (e.g. propane,

oxygen, etc.) should be legible, written in the appropriate language(s), and prominently displayed on

containers of hazardous chemicals, including all compressed gas cylinders. Personnel training should

include an explanation of the labeling system. All flammable gas cylinders should be stored at least 25

feet [7.5 metre] from open flames or possible sources of ignition, in temperatures below 125oF [51?],

and away from contact with electrical apparatus. All storage locations of cylinders should be properly

selected, constructed, identified, marked with appropriate warning signs, and secured. Cylinders should

be stored in an upright position, and be properly stored to prevent tipping and/or falling. Cylinders

should be moved by a means of a suitable handcart (or equivalent) with a chain or belt for securing the

cylinder. Cylinders should be transported in a vertical position. It is important that the Liquid Petroleum

Gas cylinders be stored or transported in a position so that the safety relief device is always in direct

contact with the vapor space in the cylinder. This is generally a vertical position. The valve should be

closed when not in use, being transported, or when empty. Periodic inspection of compressed gas

cylinders should be part of the site's compressed-gas written policies/procedures. The inspection should

focus on corrosion, general distortion, cracks, deep rust, leakage, or other defects. Unapproved or

makeshift compressed gas apparatuses should not be used. Under no circumstances, should cylinders be

used as rollers/supporters or other devices. Stored oxygen cylinders should be separated from fuel

sources and combustible materials. It is recommended that oxygen cylinders be separated from fuel gas

cylinders by a minimum distance of 20 feet [6 metre] or by a non-combustible barrier at least five feet

[1.5 metre] high, having a fire resistance of at least one-half hour. Employees working with compressed

gas should be trained on proper handling and use. (Note: Local laws should be referred to where

applicable)

10.28 Combustible dust and particulate should be properly removed from operation areas to prevent the

creation of a hazardous atmosphere. Sweeping of materials is acceptable only for the minor amounts of

dust or particulate created by leakage from the vacuum collection equipment. Blowing with an air-line is

not a proper method of removal and is unacceptable.

10.29 Solvent spray areas should be kept free of ignition sources such as open flames and sparks. All spray


17/43

areas should be kept free of the accumulation of spray residue. All spray booths should be constructed of

non-combustible materials to prevent the spread of fire. This includes spray booth floors and baffles.

Belts, pulleys, and other power transmission devices should be constructed in such a way to prevent

accumulation of spray residue. Where adequate ventilation is not provided, the followings apply.

Electrical equipment (lights, switches, outlets, motors, etc.) designed and approved for the specific use

in hazardous environments and atmospheres should be used (i.e., explosion-proof and properly located

when installed). [Note: Monthly cleaning is recommended. Spray residue can be a potential explosive

and/or fire hazard. Ducts and filters should be scheduled for inspection and, if necessary, cleaning at

least quarterly. Adequate ventilation and design of drying spaces is essential to control heat

accumulation and contact with ignition sources.]

10.30 All inside flammable and combustible liquid storage rooms should be equipped with either a gravity or a

mechanical exhaust ventilation system designed to provide at least six air changes per hour. This

prevents the build-up of an explosive atmosphere. However, if the local fire regulations are more

stringent, those should be followed. All spraying areas should be provided with ventilation that

adequately removes flammable vapors, mists, or powders and also provides adequate volumes of quality

make-up air in enclosed areas. Spray booths using exhaust air filters should maintain an average airvelocity of 100 feet per minute [30 metre per minute] at the position of work-pieces and be measured

annually. It is recommended that filters be cleaned or changed at least quarterly. Contaminated air

should not be circulated or allowed to re-enter into another makeup air unit intake.

10.31 Only personnel trained in chemical safety, bonding, grounding, and fire prevention should transfer or

withdraw flammable and combustible liquids. Where employees are employed in areas in which

flammable and/or combustible materials are to be found, they must understand the proper handling

procedures and the hazards such materials may represent.

10.32 All alarm systems should be maintained and tested at least monthly.

10.33 Local law requirements should be checked and followed. In the absence of the local law requirements,

the following guidelines should be used: Portable fire extinguishers should be available for the use of

emergency response employee. The fire extinguishers should be selected and distributed in accordance

with the size and degree of hazard affecting their use and expected class of workplace fire. Generally,

the distance to a fire extinguisher should not exceed 75 feet [23 metre]. Portable fire extinguishers are

to be located, mounted in an upright position up to 1.4 metre to the top of the extinguishers, and

identified to be readily accessible and not subject employees to possible injury. Standpipes and hose

cabinets should also be readily identifiable and used only for fire equipment purposes. Fire extinguishers

should be located high enough above floor level to avoid obstruction. Areas protected by fixed

extinguishing systems that use extinguishing agents in concentrations known to be hazardous to worker

safety and health, should be posted with appropriate hazard warning or caution signage at the hazard

entrance exterior and interior of location.

10.34 A system of inspecting, maintaining, and recharging of all portable fire extinguishers should be in place.

Portable extinguishers should be visually inspected each month and recorded on a tag attached to each

extinguisher. Annually, all portable fire extinguishers should be given a thorough and documented

maintenance check only by a qualified technician(s).

10.35 Annual fire extinguisher training and education for emergency response employees who are expected to

use fire extinguishers should be provided and documented. Employees who operate fixed extinguishing


18/43

systems should also be trained annually.

10.36 All fires should be investigated in order to identify root causes and a strategy for preventing recurrence

should be in place.

10.37 All other fire-fighting equipment such as hoses, standpipes, emergency generators etc., where installed,

should be inspected periodically and maintained to provide effective use, at least on an annual basis. Fire

doors should be in good working condition.

Section 11a.

General Environmental Health and Safety (EHS)

11.1 Management should establish an overall written EHS process. The process should include site-specific

policies and procedures for identifying, evaluating, controlling and documenting environmental, health,

safety (EHS), and working condition risks.

11.2 Determine if the written EHS policy has been posted and/or made available to all employees in the local

language and the program to applicable employees.

11.3 To facilitate the EHS process, a designated EHS coordinator should be appointed, who should be suitably

trained with evidence of a local government certificate if available or if not, other evidence such as

training courses or seminars. Consideration should be given to a system of proportionally increasing the

number of support staff for the EHS coordinator based on the number of workers.

11.4 EHS committee(s)/team(s) should be established and comprised of members representing a variety of

shifts, functions, and personnel levels. EHS committees should meet on a regularly scheduled basis at

least once in every 60 days and a plant manager is to attend at least three times a year. Minutes of all

meetings should be kept.

11.5 Employees should be made aware of EHS rules, safe operating procedures, EHS activities, and other

EHS-related information pertinent to their job. Workplace EHS awareness can be achieved through

effective communications such as EHS meetings, newsletters, bulletin board postings, EHS training, etc.

11.6 Job specific EHS training/education should be provided to all workers prior to starting a NEW job.

Training should include operating machinery in a safe manner, proper use of personal protective

equipment, disposal of wastes, operating spray equipment, etc.

11.7 Employees should be given the opportunity to voice EHS opinions and concerns. This opportunity can be

via suggestion boxes, meetings, surveys, and personal communications. Recommendations received by

the facility management should be reviewed, considered, properly addressed, and feedback providedthrough the EHS committee.

11.8 EHS coordinators should identify new potentially hazardous materials and/or processes prior to the use

of the materials concerned and put in place adequate safety controls.

11.9 All containers of chemicals coming into the facility should have a label attached with the name of the

chemical and an indication of the potential hazard and any specific handling and storage instructions,

either with symbols or in the local language.


19/43

11.10 Contractor personnel should receive an orientation prior to commencing with work. The contractors

should be informed of any potential hazards at the facility to which they may be exposed. The

orientation should include a review of the site EHS rules, which contractors must obey. Contractors

should receive the EHS rules in written format.

11.11 A written chemical EHS policy and/or procedure in the local language must be provided to all employeeswho have the responsibilities within the chemical EHS program for the storage, labeling, handling and

safe usage of all chemicals which are introduced into the facility. Responsibilities for personnel within the

chemical EHS program should be clearly defined and documented. All employees who use or work in

areas where chemicals are used or stored should be trained by a person experienced in chemical

safety.

11.12 Material Safety Data Sheets (MSDS) must be available in the local language to employees for each

hazardous chemical. Employees should be informed that the MSDS are available and where they can be

found. Employees should have an understanding of how to interpret the key safety, labeling, and

handling points illustrated by the MSDS. [Note: It is recommended that obsolete MSDS should be

removed from the current MSDS file but retained elsewhere for 5 years.]

11.13 A list of all hazardous chemicals currently being used or stored at the facility including the relevant MSDS

should be maintained and available through the EHS coordinator or factory manager.

11.14 Emergency eyewash equipment should be present in all hazardous chemical use areas. Shower unit

should be added to the eyewash equipment if corrosive and toxic chemicals are used. Location of

eyewash equipment should be within 100 feet (30 metre) travel distance of the hazardous chemical use

areas. It is important for these eyewash units to be inspected and their operation checked monthly.

Documentation of these inspections is required. Signs identifying the emergency eyewash equipment

locations and shower unit locations should be conspicuously posted. This requirement applies to both

process operation and laboratory facilities. Refer to 11.8.

11.15 Storage and process tanks, piping used to transfer hazardous substances, and valves used to control the

flow of hazardous chemicals should be labeled or color-coded to communicate which substances are

present in the system. Color-coding and identification is an important aspect for operations and

maintenance. The color-coding system should be consistent throughout the facility and communicated by

posting of the color code and what each color identifies. In addition to color-coding, labeling should also

be used to identify valves, connections, bleeds, and other critical parts.

Section 11b.

Health and Safety

11.16 Each accident or near miss requires some degree of investigation including fires, spills, injuries,

overexposure to hazardous chemicals, property damage and incidents, which did not result in injury or

loss but had the potential to do so under different circumstances. A consistent format should be used to

ensure that the proper information is collected and the immediate causes, root causes and necessary

system improvements are identified and an action plan has been put in place. Forms should be filled out

in their entirety prior to filing. Employees should be reminded of the need to report all incidents. This can


20/43

be accomplished by posting bulletins, safety meeting reminders, memoranda, etc. Safety meetings are

held on a regular basis (60 days. Refer to 11.4). Corrective actions should be tracked on a corrective

action log and the status of items should be reviewed periodically to ensure timely completion.

11.17 All accidents should be reported. Employees should be encouraged to promptly report any accidents, and

should not be discriminated against, reprimanded, or discouraged for reporting accidents.

11.18 The facility should prohibit persons from working at or near moving machinery while wearing loose

clothing, jewelry, or long hair. Gloves, loose shirts, baggy pants, etc. which could become entangled in

machinery should not be permitted. Jewelry includes rings, bracelets, necklaces, etc. and should not be

permitted. Hair hanging loosely below the neckline should not be permitted. [Note: Even the most

elaborated safeguarding system cannot offer effective protection unless the operator and all affected

employees know how to use it and why it is necessary. All employees should be informed of any

machine guarding which impacts safety. Training should include: identification of hazards; demonstration

of safeguards; discussion of safeguard limitations; proper methods for cleaning and clearing jams;

required tools, fixtures, and personal protective equipment; activities requiring lockout/tag out; (see

description at 11.25) and safe work practices.]

11.19 Employees should be trained on machine safe guarding.

11.20 Machine safeguarding should be provided on all machinery to prevent employees from coming into

contact with any machine part, function, or process that may cause injury. The point of operation is the

location on the machine where work is performed on material such as cutting, shaping, molding,

trimming, drilling, punching, or shaping. These areas should be safeguarded. Power transmission

apparatus are the components of the mechanical system, which transmit energy to the part of the

machine performing the work. These components include flywheels, pulleys, belts, connecting rods,

couplings, cams, spindles, chains, cranks and gears. These components should be safeguarded. Other

hazardous moving parts are the parts of the machine, which move while the machine is in operation.

These can include reciprocating, rotating, and transverse moving parts, as well as feed mechanisms and

auxiliary parts. These parts should be safeguarded. Drive mechanisms such as pulleys and belts that are

within seven (7) feet (2.1 metre) from the floor or working surface should be guarded. Fan blades

should be protected against accidental contact. A guard should be provided with openings no larger than

inch (12.5 mm).

11.21 Starting/stopping controls should be accessible to the operator. If there is more than one operator,

separate controls should be provided for each operators station. Start buttons should be protected

against accidental startup by a ring guard. All starting/stopping controls should be labeled as to its

function and appropriately colored. Green should be used for start controls and red for stop controls.

Emergency stop buttons should be of a palm/mushroom type for easy and quick activation in an

emergency. Emergency stop buttons should also be colored red to differentiate the emergency stop

button from other controls.

11.22 Areas requiring frequent inspection are cords, plugs, rotating parts and guards. All hand tools and

portable power tools should be free of defects. Defective tools are to be removed from the work place

and repaired or replaced. [Note: Machinery and equipment should be free of excessive dirt, grease, or oil

that could present a hazard. Machinery and equipment can only be safe and effective if it is maintained

in proper working condition free of recognizable defects. Preventive maintenance programs that ensure

safe operation by checking safety latches, sensors, start and stop controls are recommended.]


21/43

11.23 Suitable local mechanical exhaust ventilation is essential to prevent a buildup of vapors, which could

result in a fire or health hazard wherever flammable liquids such as solvent based paints are stored, used

or mixed. . In addition to ventilation, control is best achieved through the proper training of employees

and confinement of liquids and associated vapors to selected areas, control of potential ignition sources,

and protection of the area with an extinguisher system. No-smoking policy should be strictly enforced.

Other operations such as soldering, plating and paint mixing may require local ventilation using exhaust

air filters which must maintain an average air velocity of 100 feet (30 metre) per minute. Determine

whether immediate actions are taken by the facility when average readings are less than 100 feet (30

metre) per minute. Air velocity should be measured when changes are made to the system, or when

production conditions significantly increase, and at least annually. Contaminated air should not be

circulated or re-entrained into another air unit intake. Adequate ventilation and design of drying areas is

also essential to control heat accumulation and contact with ignition sources. [Note: Flammable liquids

such as solvent based paints which are used or mixed for an operation must be closely controlled during

all storage, handling, and usage of these liquids. This is the responsibility of the management.]

11.24 All employee exposures to hazardous substances should be maintained at or below regulatory standards

established in the country where the factory is located where such regulatory standards do not exist,reference may be made to the ACGIH (American Conference of Governmental Industrial Hygienists)

exposure limits for relevant chemicals present in the facility processes (see below in this section). If not

set out in the countrys regulatory standard, a respected sampling and testing method such as those

approved by NIOSH or OSHA in the United States or an equivalent standard in a major European Union

country should be used. Exposures should be controlled through the use of engineering controls,

administrative controls, or personal protective equipment. Periodic monitoring should be conducted to

determine if exposures are in fact below established standards. This requirement applies to all areas

including production, chemical use areas, laboratories, warehouse, and maintenance. Where practicable,

engineering controls should be implemented to reduce employee exposures to hazardous substances

below established standards. An example of engineering controls is mechanical exhaust ventilation.

Where engineering controls have been determined to be impracticable, administrative controls should be

implemented. Administrative controls include job rotation, preventative maintenance programs, regularly

scheduled rest breaks, changes to production schedules, etc. Where engineering controls and

administrative controls are determined to be impracticable, personal protective equipment (PPE) should

be provided and used. PPE should be suitable for the person using it and appropriate for the substance it

is designed to protect against.

Chemical Source of Chemical (ACGIH TLV) in ppm

Acetone Vacuum Metalizing, Paint *500 (Short Term 750)

Aluminum (Al) welding fume Welding 5 mg/m3

Butyl Cellosolve (2-Butoxyethanol) Paint* 25

Cadmium (Cd) welding fume Welding 0.01 mg./m3

Chromium (Cr) welding fume Welding 0.5 mg/m3

Copper (Cu) Welding 1 mg/m3

Cyclohexanone Paint* 25


22/43

Ethyl Acetate Paint* 400

Formaldehyde Plating (silver nitrate solution) and

Injection Molding (by-product for

acetyl resin)

Ceiling 0.3

Hydrochloric Acid Injection Molding and Rotocast (by-product of PVC), Plating

5

Iron (Fe) welding fume Welding 5 mg/m3

Isocyanate (MDI) Mold Casting 0.005

Isocyanate (TDI) Mold Casting 0.005

Isopropyl Alcohol Paint*, Cleaning, Hair Gel 400 (Short Term 500)

Lead (Pb) welding fume Welding, Soldering 0.05 mg/m3

Manganese (Mn) welding fume Welding 0.2 mg/m3

Methylene Chloride (MC) Paint*, Solvent Bonding, Cleaning,

Vacuum Metalizing

50 (Short Term 125)

Methyl Ethyl Ketone (MEK) Paint*, Solvent Bonding, Cleaning 200 (Short Term 300)

Methyl Isobutyl Ketone (MIBK) Paint*, Cleaning 50 (Short Term 75)

Mineral Spirits/Stoddard Solvent

(Kerosene)

Paint*, Cleaning, Vacuum Metalizing 100

Nickel (Ni) welding fume Welding 1 mg/m3

Nitric Acid Plating 2 (Short Term 4)

Nuisance Dusts Regrind, Plastisol Powder Mixing 10 mg/m3

Phosphoric Acid Plating 0.25 (Short Term 0.75)

Respirable Dust Color Mixing 3 mg/m3

Sodium Hydroxide Plating, Vacuum Metalizing, Spindle

Stripping

Ceiling 2 mg/m3

Styrene Injection Molding (by-product of ABS

resin)

20 (Short Term 40)

Sulfuric Acid Plating 0.25 (Short Term 0.75)

Trichloroethylene (TCE) Solvent Bonding, Paint* 50 (Short Term 100)

Toluene Paint*, Cleaning, Vacuum Metalizing 50

Total Hydrocarbons (as N-Hexane) Paint*, Vacuum Metalizing 50

Vanandium (V) welding fume Welding 0.05 mg/m3

Welding Fumes Welding 5.0 mg/m3

Xylene Paint*, Cleaning, Vacuum Metalizing 100 (Short Term 150)

Zinc (Zn) Die cast 5 mg/m3


23/43

11.25 The facility should have a written procedure on the subject of hazardous energy control. Record date of

issue. This procedure should be developed for purposes of protecting employees during machine and

equipment servicing and maintenance where the unexpected energization, start-up or release of stored

energy could occur and cause injury. Hazards being guarded against include being caught in, being

crushed by, being struck by, being thrown from, or contacting live electrical circuits/parts. Energy

sources include electrical, mechanical, pneumatic (compressed air), hydraulic, chemical, and thermal. All

energy sources should be de-energized and where possible, locks should be placed on switches and

valves to ensure that they are not inadvertently switched on during shutdown, and tags used to make

clear to all why energy source is locked out (off).

11.26 Employees who perform maintenance and servicing activities (authorized employees) should receive

training from a competent person in lock/tag/try procedures and practices prior to conducting any work.

Persons who normally operate machines and equipment being services (affected employees) and

persons who may be in the area of locked/tagged equipment (other employees) should also receive

training. All employees should receive an overview of the relevant lockout/tag out program for their

areas so that they are able to recognize when energy controls are being implemented, understand the

purpose of the procedures and the importance of not attempting to start up or use themachine/equipment that has been locked out. Check training records of authorized employees on file to

verify that training is current and not more than 1 year ago. Determine if they have been adequately

trained by a competent person on the subject of lockout/tag out.

11.27 A sufficient number of isolation devices should be made available to persons performing lockout/tag out.

The type of equipment that should be provided includes such items as locks, tags, group lock box, circuit

breaker lockouts, valve lockouts, and lock hasps. This equipment should be maintained in a readily

available location. Each maintenance employee working on a piece of equipment should have their own

personal lock for locking out that equipment.

11.28 Select three (3) to five (5) maintenance workers. Ask for a demonstration and / or explanation of how

they go about servicing equipment. Determine if they lockout energy of equipment prior to servicing,

maintenance, and repair.

11.29 A hazard assessment should be conducted of each operation and the correct Personal protective

equipment (PPE) for each operation should be listed. Personal protective equipment should be selected

based on the hazard assessment of each operation.

11.30 Personal protective equipment should be provided where necessary. The following provides some

examples of what conditions warrant that use of various types of personal protective equipment:

Eye/Face Protection: Eye/face protection should be provided where there is a potential for injury from

flying objects, liquids, injurious radiation, or a combination of these hazards. The type of eye protection

will depend upon the hazard. Types of eye protection include safety glasses, goggles, face shields, and

shaded lenses for injurious radiation.

Foot Protection: Foot protection (safety shoes) should be provided where foot injuries could occur from

impact of falling or rolling objects, objects piercing the sole. Protective boots should be provided where

feet are exposed to liquids, other contaminants, hazardous chemicals, or where employees feet are

exposed to electrical hazards.


24/43

Hearing Protection: Hearing protection should be provided where hearing loss from high noise exposures

could occur. Hearing protection when properly used should reduce the employee's noise exposure to less

than 85 decibels (dBA). Types of hearing protection include earmuffs and earplugs.

Hand Protection: Appropriately rated gloves should be provided for their applicable use to adequately

protect employees against contact with chemicals, lacerations, burns, punctures, and extreme hot or

cold temperatures.

Head Protection: Head protection (hardhats) should be provided to protect against injury from impact

and penetration from falling and flying objects and limited electric shock burn.

Protective Clothing: Protective clothing should be provided to employees to prevent exposures to

chemicals, lacerations, punctures, cold, and burns.

Respiratory Protection: Respiratory protection should be provided where the potential for inhalation

exposure to harmful types or quantities of airborne contaminants could occur. Airborne contaminants

include particulates (dusts), vapors, gases, aerosols, and fumes (metal particles). Types of respirators

include air purifying and air-supplying. Proper selection of a respirator should include the identification

and evaluation of the contaminant, and the determination of the appropriate respirator. All respiratory

protection should be approved by the regulatory or research testing authority for the type of

contaminant exposure. Employees with any type of respiratory conditions should not be required to work

with respirators.

PPE Provided to Visitors: Visitors should also be provided with appropriate personal protective equipment

when entering or working in areas where signage indicates that PPE is required.

Employees should be observed to ensure that personal protective equipment is being properly used inaccordance with the facilitys procedures. Determine if employees are utilizing personal protective

equipment in areas of the facility where it is specifically required. If employees are observed not wearing

PPE where they should be required to, determine if they have access to personal protective equipment

and/or if supervisors or managers are not enforcing use of personal protective equipment.

11.31 Employees should be trained on the proper storage, cleaning and use of the personal protective

equipment that is provided. The types of personal protective equipment that should be evaluated and

used where appropriate include eye/face protection, foot protection, hearing protection, hand protection,

head protection, protective clothing, and respiratory protection. Training should include proper fitting of

all equipment. Annual PPE refresher training should be conducted to ensure continued awareness on the

subject. Training records should be available to verify all training that has been conducted. Refer to 11.6.

[Note: Employees who wear respirators should be encouraged to undergo medical evaluation in the use,

care and fit testing and have hearing test annually for those on a conservation program.]

11.32 Signage should be visible in the general area and/or at workstations indicating where and what type of

personal protective equipment is required for that area.

11.33 Only trained and authorized employees should operate cranes or hoists. A qualified person should

provide training and it should include a review of the general crane, sling, and hoist operating rules.


25/43

11.34 Prior to initial use, all new and altered cranes and hoists should be inspected by a competent person to

ensure they are in safe operating condition. Periodic inspection should be made of external and / or

internal components for signs of defects, wear, or abuse as well as cleaning and lubrication of gears and

motors, etc. Cranes, slings and hoists, which are damaged or defective, should be removed from service

and marked so that they will not be used until repaired or replaced. [Note: Each day before being used,

the sling and all fastenings and attachments should be visually inspected for damage and defects.

Additional inspections should be performed as conditions warrant.]

11.35 The maximum load limits should be conspicuously marked on all cranes, slings, and hoists and the

facility should ensure that those maximum loads are followed. Hoist hooks should be equipped with a

safety latch to prevent the accidental release of the load. [Note: Marking is required on all crane beams

as it is possible to have more than one moving rail in the system in the same section of the traverse rail

effectively loading the section of the rails with the sum of the two cranes and their loads.]

11.36 Every open-sided flight of stairs in excess of 3 feet (one metre) should be equipped with adequate stair

railings, which comply with local laws. Such railings may consist of a top rail, intermediate rail, and

adequate support.

11.37 Every open-sided floor or platform three (3) feet (one metre) or more above adjacent floor or ground

level should be guarded by adequate railing on all open sides except where there is entrance to a ramp,

stairway, or fixed ladder. Open sides of all platforms, stairs, and floors require adequate railings. Loading

ramps when not in use and above three (3) feet (one metre) in height should have a barrier (chain) to

prevent falls from the loading dock.

11.38 Only safe elevated work platforms should be used to raise personnel. Safe platforms including adequate

handrails, midrails, and toeboards should be provided on such platforms. "Temporary" platforms such as

pallets, wooden boxes, and parts storage bins should not be used. Work platforms appropriate for the

region should be used as designed, and within the platform manufacturer's guidelines, including

inspection before use. Platforms should be designed to be mechanically secured to the lifting device.

Refer to Section 11.8

11.39 Prior to elevating personnel in a work platform, the platform (i.e., baskets) should be secured to the

lifting mechanism (forklift, raymond lift) so that the platform cannot become free of the lifting

mechanism and fall to the floor. A chain or locking mechanism should be used. Adherence to forklift

lifting capacities based on load weights and working heights should be followed. [Note: Work platforms

should be lowered to floor level before the forklift travels. Additionally, mechanical-lifting devices should

be inspected by a competent maintenance person at least annually.]

11.40 Ladders should be visually inspected prior to use for any damage or defects. Ladders that are either

damaged or defective should be removed from service. The damaged or defective ladder should be

marked or tagged so that it will not be used until it has been repaired or replaced.

11.41 Skylight floor openings should be guarded by a skylight screen or fixed railing on all exposed sides.

Manhole floor openings should be guarded by a cover of sufficient strength and construction.

11.42 The facility should have a written policy and/or procedure on the subject of confined space entry. Record

the date of issue. Examples of confined spaces are: compressed air tanks, fuel or solvent storage tanks,

silos, catch basins. A written permit should be issued by the EHS person responsible for the confined

space program. The entry procedures should include provisions for energy and hazardous materials


26/43

source isolation, testing of confined space atmosphere (oxygen, LEL, toxic air contaminants), ventilation,

communications, entry and egress, and emergency rescue. [Note: Every effort should be made to avoid

placing workers in confined spaces. Where work is required, a procedure for the specific area should be

developed.]

11.43 Only trained employees should be permitted to enter confined space areas, or to assist anotheremployee with work in a confined space area. Training records should be available to verify all training

that has been conducted.

11.44 Recognized safety practices provide that a confined space entry process be followed to assure the safety

of employees who must work in these spaces. All confined spaces must be identified by a posted sign

stating Confined Spaces - Follow established entry procedure, in local language and also secured or

locked to prevent unauthorized entry. Types of confined spaces include storage tanks, process vessels,

diked tank farms, boilers, ovens, silos, underground trenches, and enclosed conveyors. Where possible,

work inside confined spaces should be avoided.

11.45 Only trained employees should be authorized to operate a forklift or other powered industrial vehicle.

Training records should be available to verify all training that has been conducted. Where there is agovernment requirement for operators to be certified, the operator should possess a certification card.

11.46 A daily visual and functional inspection of each forklift must be carried out and documentation of these

inspections should be available. A mechanical inspection program should be implemented and forklifts

should be inspected a

Documents

Appendix IIa