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Environmental Health and Safety Supplier

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    1. 11/17/2011 Environmental Health and Safety Supplier/Contractor and Visitor Training

    2. Introduction - EHS Expectations This EHS Orientation for contractors contains an overview of selected health and safety good practices and regulatory requirements that may be applicable to their work at Accuride. It should be considered as an introduction and not a substitute for a thorough understanding of the subjects.

    3. Introduction - EHS Expectations Furthermore, it is for informational purposes only. This orientation does not relieve the Contractor of its obligations to (1) control the manner and means by which it and its employees, subcontractors and agents perform work or services at Accuride, and (2) independently ascertain what health and safety practices are appropriate and necessary for the performance of such work or services.

    4. Introduction - EHS Expectations Contractors are expected to be familiar with and follow appropriate health and safety practices, including those required by the federal Occupational Health and Safety Act (“OSH Act”), and those set forth in applicable Occupational Safety and Health Administration (OSHA) regulations, as well as any applicable state or local code.

    5. Introduction - EHS Expectations This training module includes a basic Environmental Health and Safety Orientation. This information is not intended to be all inclusive and other training may be necessary depending on your job. If you have any questions regarding any facet of this training, please contact your Accuride Host, or EHS Manager Dane Fuller at 827-6808.

    6. Introduction - Definitions Contractor: - any person, contracted by Accuride, entering Accuride property to perform work at the facility. Visitor: - any person entering Accuride’s property for the purpose of observing, meeting, or performing non-work (hands-off) activities, including Accuride employees from other sites.

    7. Introduction – Contractor Responsibility Training Contractors have the responsibility to ensure that all employees are properly trained. Safety orientation will include a review of Accuride best work practices and issues that contractors need to be aware of while on site. This safety orientation will raise the level of safety awareness while at Accuride.

    8. Introduction 1.0 Sign-In and Sign-Out Procedures 2.0 Personal Protective Equipment 3.0 Emergency Action Plans 4.0 Hazard Communication

    9. Introduction 5.0 Lockout/Tagout – Control of Hazardous Energy 6.0 Confined Space Entry 7.0 Hot Work Permitting 8.0 Environmental Issues

    10. Introduction 9.0 Aerial Lifts and Fall Protection 10.0 Entry into R&D and Met Labs 11.0 General Safety Rules

    11. Introduction 12.0 Maintenance Guidelines 13.0 Policy Statements

    12. 1.0 Sign In and Sign Out Procedures

    13. 1.0 Sign-In and Sign-Out Sign-In and Sign-Out each time you enter the facility Upon signing in to the facility and receiving the proper training you will get a Red Contractor Pass from security – This pass needs to be worn and visible at all times while on plant property. These passes need to be turned in to security upon leaving for the day. We do not issue passes beyond the period of one day.

    14. 2.0 Personal Protective Equipment

    15. 2.0 Personal Protective Equipment Personal protective equipment (PPE) is used to increase individual safety while performing potentially hazardous tasks, and may include safety glasses, hard hats, gloves, respirators, or any equipment or clothing used to protect against injury or illness. Contractors should ensure that the proper types of PPE are available for and used by their employees. OSHA's requirements are found in 29 CFR 1910 Subpart I - Personal Protective Equipment.

    16. 2.0 Personal Protective Equipment Contractors should use safety glasses with side shields to protect against flying particles (e.g., saw dust, nails, metal shavings, etc.) Goggles should be used to protect against molten metal, liquid chemicals, acids and caustic liquids, chemical gases and vapors. Shaded eyewear should be used to protect against potentially injurious light radiation (e.g., cutting and welding, lasers).

    17. 2.0 Personal Protective Equipment Contractors should wear protective footwear (e.g., steel toe boots, leather work boots, etc.) in areas where there is the potential for foot injuries from falling or rolling objects, from objects piercing the sole, or from exposed energized electrical conductors that could contact the feet.

    18. 2.0 Personal Protective Equipment Contractors should wear hand protection (e.g., leather work gloves, welder's gloves, appropriate chemical protective gloves, etc.) to protect against hazards of skin absorption of harmful substances, severe cuts or lacerations, severe abrasions, punctures, chemical burns, thermal burns, or harmful temperature extremes.

    19. 2.0 Personal Protective Equipment Contractors may use respiratory protection to protect against inhalation hazards when engineering and administrative controls are not feasible or adequate.

    20. 2.0 Personal Protective Equipment Basic PPE Requirements at Accuride Include: ANSI Approved Safety Glasses with Side Shields Hearing Protection (When Plant is in Operation) Steel Toe Safety Shoes

    21. 3.0 Emergency Procedures

    22. 3.0 Emergency Procedures Emergency Action Plan At Accuride we have 4 distinct alarm sounds Fire Severe Weather Evacuation All Clear

    23. 3.0 Emergency Procedures Alarm Sounds If you hear an alarm sound, you need to contact the nearest Accuride employee in your area for instructions. If this is not possible, or, if you are not sure how to proceed, evacuate the building until further notice.

    24. 3.0 Emergency Procedures Report the Emergency Accuride Security at ext. 7699 Seek Assistance From Accuride Personnel; i.e. plant contact

    25. 3.0 Emergency Procedures In an emergency situation, always err to the safe side and evacuate the building if you are not sure what to do. Gather at one of the emergency gathering areas shown on the next slide. These evacuation maps are also posted throughout the plant.

    27. 4.0 Hazard Communication

    28. 4.0 Hazard Communication OSHA’s Haz Com Standard gives you the RIGHT TO KNOW about the chemicals in your workplace. As host employer, we provide an MSDS to every chemical that you may be exposed to on-site. Access is available from facility EHS Personnel or your plant host.

    29. 4.0 Hazard Communication Chemicals used by Accuride: Chemicals are used extensively throughout the entire process at Accuride. According to the requirements of 29 CFR 1910 Subpart Z, when the Contractor works in area(s) where chemicals are stored or used, the Contractor may request from their Accuride Host the following information:

    30. 4.0 Hazard Communication Special precautions and/or safety procedures for the work area. Method of obtaining MSDSs for hazardous chemicals present in the Contractor’s work area. Special procedures to follow in the event of an accidental release or exposure to the hazardous chemicals.

    31. 4.0 Hazard Communication Chemicals Stored or Used by the Contractor: The Contractor must take all necessary precautions to protect Accuride personnel, other contractors and visitors from exposure to the chemicals. The Contractor should maintain material safety data sheets (MSDSs) on-site for all hazardous chemicals used or stored at the job site.

    32. 4.0 Hazard Communication The Contractor is responsible for cleaning up any spills created or caused by the Contractor. Contractors must alert Accuride Security at 7699 immediately upon discovering a spill.

    33. 4.0 Hazard Communication The Contractor must dispose of all hazardous chemicals in accordance with federal and state regulations. All hazardous waste brought on-site and generated by the Contractor must be disposed of by that Contractor. Disposal of Contractor generated hazardous waste on-site is prohibited.

    34. 4.0 Hazard Communication Labeling and other forms of warning: ALL containers must be labeled; If during the course of your job you ever have to use a temporary container, that container must also have a label and that label should be similar to the original label and reflect all appropriate information. An example of hazardous materials classification appears on the next slide.

    35. 4.0 Hazard Communication

    36. 5.0 Lockout Tagout (Control of Hazardous Energy)

    37. 5.0 Lockout/Tagout Lockout/tagout procedures are designed to prevent accidental startup of machines or equipment, and to prevent the release of stored energy. Through the application of locks and/or tags as direct controls, equipment is isolated from energy sources and injuries to workers are prevented. When work affects or is done in association with Accuride personnel, Contractors should submit their lockout/tagout procedures to the Accuride’s Safety Manager.

    38. 5.0 Lockout/Tagout Contractors should, at a minimum, adhere to the following procedures found in 29 CFR 1910.147 – Control of Hazardous Energy. Controls: Controls that are to be deactivated during the course of work on equipment or circuits should be locked or tagged. Equipment and circuits: Equipment or circuits that are de-energized should be rendered inoperative and should have tags attached at all points where the equipment or circuits could be re-energized. Tags: Tags should be placed to identify plainly the equipment or circuits being worked on.

    39. 5.0 Lockout/Tagout Contractors have a responsibility to inform Accuride personnel of their respective Lockout/Tagout Procedures. Contractors must notify Accuride personnel of all potential Lockout/Tagout activity before starting the job so that coordination of procedures can take place. These procedures are located in the Safety Office and the Maintenance Office.

    40. 5.0 Lockout/Tagout Additional Lockout/Tagout training may be required depending on your job scope. If your job requires you to perform tasks where you have to shut down Accuride Equipment and shut down hazardous energy, then additional training is required. Please contact Accuride EHS personnel, or facility host to schedule additional training.

    41. 5.0 Lockout/Tagout Because of the serious nature of hazardous energy control, if contractors are observed working on equipment requiring Lockout/Tagout and the procedures are not followed, then you will be asked to leave the facility and all future work opportunities will be jeopardized.

    42. 6.0 Confined Space Entry

    43. 6.0 Confined Space Permitting A confined space is defined as any space that that is large enough to enter and perform work, has a limited means of entry or egress (exit), and is not designed for continuous employee occupancy. Examples of confined spaces include pits, tanks, certain tunnels, and underground vaults.

    44. 6.0 Confined Space Permitting Contractors should be familiar with relevant portions of 29 CFR 1910.146 – Permit Required Confined Spaces and use appropriate entry procedures when working in confined spaces, including the following:

    45. 6.0 Confined Space Permitting Before entry occurs, test the confined space's atmosphere using a direct reading instrument for oxygen content, combustible gases, and toxic air contaminants. If entry is permissible, ensure ventilation is continuous, appropriate and adequate. When required, assign a trained attendant to observe those working in the confined space.

    46. 6.0 Confined Space Permitting When a confined space entry includes hot work (welding or cutting), the following additional procedures from 29 CFR 1910 Subpart Q – Welding, Cutting and Brazing should be followed:

    47. 6.0 Confined Space Permitting Gas cylinders and welding machines should be left outside the space when work is performed in such spaces as tanks, boilers, or pressure vessels. Heavy portable equipment mounted on wheels should be securely blocked to prevent movement.

    48. 6.0 Confined Space Permitting Whenever workers must enter the confined space through a manhole or other restricted opening, some means for his or her quick removal should be provided. This could include a body harness and lifeline attached to mechanical retrieval equipment. An attendant with a preplanned rescue procedure should be available to observe the welder and to initiate rescue should it become necessary.

    49. 6.0 Confined Space Permitting When operations are suspended for any substantial period of time, such as lunch or overnight, electrodes should be remove from their holders and arc-welding machines should be disconnected from their power source. If gas welding or cutting is in use, fuel gas and oxygen supply should be shut off with the torch valves and at some point outside the confined space. Where possible hoses and torches should be removed from the space.

    50. 6.0 Confined Space Permitting The following slide shows a copy of our Confined Space Permit. This needs to filled out for every entry. Permits are only good for one day. Permits need to be turned in to Accuride host or safety manager immediately after use.

    51. 6.0 Confined Space Permit

    52. 7.0 Hot Work Permitting

    53. 7.0 Hot Work Cutting and welding operations (referred to as hot work) are commonly associated with maintenance activities. Hot work equipment, which may produce high voltages or utilize compressed gases, requires special awareness and training on the part of the worker to be used safely. Contractors should control the hazards associated with hot work through the implementation of effective programs required under 29 CFR 1910 Subpart Q – Welding, Cutting and Brazing.

    54. 7.0 Hot Work Hot Work Permits: Though not specifically required by federal, state, or local laws, the use of hot work permits at Accuride is required. Hot work permits serve as a checklist for operators and those performing fire watch duties. The Contractor is responsible for obtaining permits for any Hot Work done on-site.

    55. 7.0 Hot Work General Cutting and Welding Controls: Areas where hot work is done should be properly prepared. Combustible and flammable materials within the work area should be protected against fire hazards and the operation should not pose a hazard to others in nearby areas. To help achieve this, the following controls should be used:

    56. 7.0 Hot Work Cutting and welding operations restricted to authorized, properly trained individuals. Combustible materials should be moved at least 35 feet from the work site. If this is not possible, protect combustible materials with metal guards or by flameproof curtains or covers (other than ordinary tarpaulins).

    57. 7.0 Hot Work Floor and wall openings within 35 feet of the work site should be covered to prevent hot sparks from entering walls or falling beneath floors or to a lower level. Fire resistant curtains and/or tinted shields should be used to prevent fire, burns to workers, and ultra-violet light exposure.

    58. 7.0 Hot Work Fire Watch: A person other than the operator should perform fire watch duties and remain at the work site for at least 30 minutes after hot work operations have ended. Additionally, the following steps should be taken:

    59. 7.0 Hot Work A fire extinguisher should be in the area and attached to all portable cutting and welding carts. If a building or area is equipped with a sprinkler system, then that system should be operational when hot work is performed.

    60. 8.0 Environmental Issues (Including ISO 14001 and Waste Disposal Guidelines)

    61. 8.0 Environmental Issues – ISO 14001 Aspects and Impacts We are currently an ISO 14001 certified company. All contractors and visitors are required to assist us in ensuring that we maintain environmental compliance.

    62. 8.0 Environmental Issues – ISO 14001 Aspects and Impacts ISO 14001 is that part of the overall management system which includes the organizational structure, planning activities, responsibilities, practices, procedures, processes, and resources for developing, implementing, and maintaining the environmental policy.

    63. 8.0 Environmental Issues – ISO 14001 Aspects and Impacts The following few slides define aspects and impacts of an ISO 14001 system:

    64. 8.0 Environmental Issues – ISO 14001 Aspects and Impacts Environmental Aspect Element of an organization’s activities, products or services that can interact with the environment. Examples Air emissions Electricity use Natural resource consumption Spills of chemicals Recycling of paper

    65. 8.0 Environmental Issues – ISO 14001 Aspects and Impacts Environmental Impact Any change to the environment, whether adverse or beneficial, wholly or partially resulting from an organization’s activities, products and services. Examples Contamination of water Loss of habitat Depletion of natural resources Conservation of natural resources

    66. 8.0 Environmental Issues – ISO 14001 Aspects and Impacts All contractors are responsible for understanding the aspects and impacts of the process you are working with or any that you may affect while at Accuride. Contact your plant host and/or Accuride EHS personnel for more information.

    67. 8.0 Environmental Issues – Waste Disposal Guidelines All contractors must take precautions to ensure hazardous chemicals or materials are disposed of in accordance with federal and state regulations. Materials which may not be disposed in regular trash include, but are not limited to, used solvents or oils, all batteries, any fluorescent light bulbs and any unwanted paints and stains.

    68. 8.0 Environmental Issues – Waste Disposal Guidelines All batteries, lightbulbs, aerosol cans, solvents, paints, or any other type of regulated waste disposal is strictly prohibited unless there is prior approval to do so from Accuride personnel. If any liquid or other materials are released on the plant site, notify security immediately at 7699.

    69. 8.0 Environmental Issues – Waste Disposal Guidelines Each project will be treated individually. If it is determined that the waste to be disposed of is harmless, then it may be OK to dispose of here. Shall the contractor fail to remove any waste, Accuride will have it removed at the contractor’s expense.

    70. 9.0 Aerial Lifts and Fall Protection

    71. 9.0 Aerial Lifts and Fall Protection Aerial boom platforms, scissor lifts, JLG Boom lifts and other types of aerial lifts are often used to provide a safe, mobile alternative to scaffolding and ladders. Contractors who use aerial lifting equipment should be familiar with and follow the requirements found in 29 CFR 1910 Subpart F – Powered Platforms, Manlifts, and Vehicle Mounted Work Platforms. The following are general rules and procedures should be followed whenever an aerial lift is used:

    72. 9.0 Aerial Lifts and Fall Protection General Requirements: Only trained persons should operate lifts. Contractors shall be trained prior to coming on-site. Accuride is not responsible for that training. Lift controls should be tested daily before first use.

    73. 9.0 Aerial Lifts and Fall Protection Fall Protection: Occupants should stand firmly on the floor of the basket at all times. A body belt (or harness) and lanyard attached to boom or basket should be worn at all times. Occupants should not belt off to adjacent structures.

    74. 9.0 Aerial Lifts and Fall Protection Use and Operation: If so equipped, brakes and outriggers should be set before the boom is raised. Lift should not be moved while extended, unless designed to do so. Manufacturer’s load limits shall not be exceeded. When appropriate, contractors should use warning signs (e.g., “Work Overhead”, etc.) or barricades to alert pedestrians.

    75. 9.0 Aerial Lifts and Fall Protection Overhead Electrical Hazards: Only insulated aerial devices should be used for work on overhead power lines. In all other cases, at least 10 feet should be maintained between the boom and energized electrical lines.

    76. 10.0 Entry into Research & Development and Metallurgical labs

    77. 10.0 Entry into Research & Development and Metallurgical labs Located on-site is our corporations Research and Development and Metallurgical labs. The Research & Development lab is a restricted access area and prior training is mandatory for all contractors.

    78. 10.0 Entry into Research & Development and Metallurgical labs All other Accuride Environmental Health and Safety guidelines apply in these areas. However, also keep the following in mind:

    79. 10.0 Entry into Research & Development and Metallurgical labs Never approach a drum test machine while in the test lab, always use the viewing windows if possible. It is recommended to always stay in pedestrian aisle way (outlined in yellow) when passing through the drum test room.

    80. 10.0 Entry into Research & Development and Metallurgical labs Entry into these areas may need extra training as needed to be determined by personnel in that area. Please check with your facility host. Never enter the corner or INSTRON test rooms without prior authorization from personnel in those areas. Always observe the test machines through the viewing windows.

    81. 11.0 General Safety Rules

    82. 11.0 General Safety Rules All injuries, near misses and/or close calls must be reported to your Accuride Contract Representative immediately. Horseplay, scuffling, or any other acts which tend to endanger the safety and well being of employees is prohibited. Only authorized contractors (designated by a purchase agreement) may operate machines and equipment for which they are qualified.

    83. 11.0 General Safety Rules Only authorized contractors (as designated by purchase agreement) may operate machines and equipment for which they are trained and qualified. All contractors are responsible for housekeeping in their area. Keep flammable liquids only in proper designated containers

    84. 11.0 General Safety Rules Guards or safety devices are not to be removed, except by authorized personnel, for purpose of making repairs or cleaning and must be replaced immediately thereafter. Smoking in areas designated NO SMOKING is prohibited Use of cell phones while working on the plant floor is prohibited

    85. 12.0 Maintenance Guidelines

    86. 12.0 Maintenance Guidelines Do not use electrical tools or equipment that is not properly grounded or double insulated. All electrical extension cords used must also be equipped with a proper third wire guard. You are responsible for the condition and proper use of all hand tools used in the performance of your job duties

    87. 12.0 Maintenance Guidelines Lockout and Tagout all energy sources on machinery before cleaning, repairing or adjusting. Guards or safety devices are not to be removed except for the purpose of making repairs or cleaning and must be replaced immediately thereafter.

    88. 12.0 Maintenance Guidelines Safety harnesses and a lanyard must be worn with the lanyard attached to the cage/basket of the elevated equipment you would be working from (in excess of 6 feet).

    89. 12.0 Maintenance Guidelines Cylinders of compressed gas, such as oxygen, acetylene, and propane shall be chained or otherwise secured in an upright position, and valve caps must be held securely in place. Oxygen and fuel cylinders shall not be stored together. They shall be seperated by at least 20 feet or a 5 foot wall with at least a ˝ hour fire resistance rating.

    90. 12.0 Maintenance Guidelines Ladders shall be maintained in good condition. Never use compressed gas for blowing of your body or clothing. To use compressed air for blowing off anything else, you must have an approved nozzle that reduces air pressure to 30 PSI. Defective slings shall not be used. These include nylon web, chain, or wire rope.

    91. 12.0 Maintenance Guidelines Only ladders or stands in good condition shall be used for overhead work. When cutting or welding a fire extinguisher must be present. If in a designated hot work permit area a fire watch must be present. Flash shields or curtains must be set up, if feasible, in the surrounding area.

    92. 12.0 Maintenance Guidelines When gas cylinders are in use they must be secured to a cart with a chain. Regulators must be installed between the cylinder and hose. A check valve shall be installed between the hose and the torch. Keep flammable liquids in the original container designed for this purpose. Open containers of flammables are prohibited. Storage must be in a proper designated area.

    93. 12.0 Maintenance Guidelines When doing any grinding, face shields are required along with safety glasses. Extension cords may not be tied up or used as permanent wiring. When working on electrical boxes all covers must be replaced when work is completed or when it is to be left for a long period of time.

    94. 12.0 Maintenance Guidelines Powered carts should be used as designed and not carry more than 2 people. Also, always sound horn at intersections and give lift trucks the right of way.

    95. 13.0 Policy Statements

    96. Policy Statements At Accuride we have different policies to help us manage our process. The following statements help us support our policies and are very important to our overall vision… Please take the time to read and understand…

    97. Quality Policy Accuride Corporation will maintain an environment that involves all employees, suppliers and customers in the pursuit of never-ending improvement in the quality of our people, processes, products, and services, and Quality Management System, thereby ensuring our commitment to continually meet and/or exceed our customers’ requirements and expectations.

    98. Environmental Policy Accuride Henderson manufactures and supplies wheels to OEM and trailer manufacturers and the aftermarket industry. Accuride Henderson is committed to conducting operations in an environmentally responsible manner. Our strategy is to: Continually improve our environmental management system; Minimize our impact on the environment through pollution prevention and waste reduction; and, Conduct business in accordance with applicable government and corporate requirements. We will establish, implement and review environmentawl goals and objectives as a means of achieving our overall strategy. Employees, contractors, suppliers and visitors are required to adhere to Accuride Henderson’s environmental management system that supports this policy.

    99. Health and Safety Policy Accuride Henderson is committed to becoming the safest wheel manufacturer in the world. This is a considerable responsibility we hold to our employees, our contractors and our corporation. This goal will be realized through the ongoing reduction and eventual elimination of personal injuries and unsafe conditions. Recognizing that safety is a condition of employment, together we will need to build; A culture where safety is a value, not a priority that is subject to change. An environment where employees look out for one another and actively participate in improving the safety of all work processes. A culture rooted in mutual trust and respect, where employees are encouraged to identify safety concerns and assist in their resolution. An environment where employees are empowered and are joint owners of the safety process.

    100. Other Contractor Guidelines If a contractor has any doubt about any environmental health or safety issue concerning the project/job, they should immediately contact their Accuride host or facility EHS Personnel for advice.

    101. Other Contractor Guidelines This training module includes a basic Environmental Health and Safety Orientation. Again, this information is not intended to be all inclusive and other training may be necessary depending on your job. This is also not meant to take the place of the contractor who has the responsibility to ensure that all of their employees has received all applicable, mandated training.

    102. Other Contractor Guidelines If you have any questions regarding any facet of this training, please contact your Accuride Host, or EHS Manager Dane Fuller at 827-6808.

    103. Accuride Contacts Environmental - Jim McKinney – 827-6856 or jmckinne@accuridecorp.com Safety - Dane Fuller – 827-6808 or dfuller@accuridecorp.com Purchasing – Jim Hamilton – 827-6817 or jhamilto@accuridecorp.com Maintenance – Roger Daugherty – 827-6859 or rdaugher@accuridecorp.com Research and Development and Met Lab – Ashley Alexander – 7659 or aalexand@accuridecorp.com General Information – Kathy Satterfield – 827-6801 or ksatterf@accuridecorp.com