APPENDIX II ISO14000/OHSAS 18000 Audit Program Outlineaddresses all elements of ISO14001 and OHSAS...

Any hard copy of this document is uncontrolled and potentially obsolete. Consult the Corporate SEQ website for the latest revision. APPENDIX 2 (5767IAMZ.DOC) Revised 01/01/05

APPENDIX II

ISO14000/OHSAS 18000 Audit Program Outline

Any hard copy of this document is uncontrolled and potentially obsolete. Consult the Corporate SEQ website for the latest revision. APPENDIX 2 (5767IAMZ.DOC) Page 1 of 68 Revised 01/01/05

SNAP-ON INCORPORATED

ENVIRONMENTAL, HYGIENE AND SAFETY MANAGEMENT SYSTEM ISO14000 AUDIT PROGRAM OUTLINE

INTRODUCTION The following information is presented here to inform and/or remind all current and future auditees of their general responsibilities under Snap-on Incorporated’s EH&S Management System. This summary briefly outlines EH&S requirements from an auditing perspective. Therefore, it is not meant to supercede or replace any other responsibilities that may be assigned by the Corporate SEQ staff. Questions or comments about this general information can be directed to any member of the SEQ Group at the Corporate Offices in Kenosha, Wisconsin.


GENERAL INFORMATION

In order to facilitate the auditee’s understanding of Snap-on’s environmental and industrial hygiene management system, the following information is presented. 1. Snap-on SEQ personnel have prepared the EH&S Manual of Practice that establishes worldwide

policy in all environmental and safety areas. The first part of this manual defines the scope of Snap-on’s operations, details environmental and safety aspects and impacts, and generally addresses all elements of ISO14001 and OHSAS 18001. This portion of the manual is the highest level document in the EH&S management system and is analogous to a quality manual in an ISO9000 management system. Since it applies to all locations within Snap-on Incorporated, auditees do not have to prepare this level of documentation. However, now that the Snap-on EH&S management system is externally certified under a Corporate umbrella program, it is more important then ever that each auditee be very familiar with this part of the Manual of Practice.

2. The next level of documentation is the SEQ standards found in Appendix A of the Manual of

Practice. These standards detail the regulatory and other internal Snap-on requirements for environmental and safety practices. All Snap-on Incorporated locations must comply with all of the standards or parts of standards that apply to them. Since these standards apply worldwide, auditees do not have to prepare this level of documentation.

3. Each facility within the Snap-on family must be familiar with the EH&S Manual of Practice’s

requirements and then do the following:

• Decide what applies; what programs are needed at each facility. • Prepare written programs (controlled documents) that satisfy regulatory and Corporate

requirements and are appropriate for the scope of the facility in question. These programs or policies will define the operational practices in place at the facility level. (See existing program examples. Contact SEQ personnel for advice as needed).

• Conduct your programs as written as part of your normal operations. This includes performing all required training as outlined in the Manual of Practice (SEQ64.02, Schedule A or A-1).

• Provide for proper record keeping so that all critical records demonstrating the performance of EH&S practices are identified and safeguarded in designated locations for the mandated retention times.


4. Documented programs must be physically maintained with the following in mind.

• All programs/policies must show evidence of an biennial review. As needed, evidence must also exist for any revisions done. These requirements can be shown in a Review/Revision Log that is part of each program document. Information that can be included is the date of the review or revision as well as a brief statement as to what changed. Approval signatures must be included either in the logs or elsewhere in the documents.

• Biennial reviews must be carefully done by the person responsible for that plan, and take into account the Corporate SEQ Standards, applicable regulations and the current procedures actually established and functioning at the facility.

5. Many needed programs have associated training requirements. All training should be

documented in a consistent manner. Training documentation must include:

• A written annual schedule of all required training. • A mechanism to identify the training needs of each employee. The exact method used for

this is up to the auditee, but a spreadsheet-based record with employees down one column and training topics across the top is one simple method that could be chosen. An “x” in a cell would indicate that the training is not applicable for the employee, a blank cell would indicate that the training is needed but not yet received and a date would indicate when the training was actually received.

• Each training course should be conducted according to a written agenda. • Employees receiving training should sign in to prove attendance. • Documentation should readily provide the answer to who has received a specific training

course AND what any given individual has been trained in. Dates on which training was obtained would be entered into the spreadsheet noted above. This would be input from the sign-in sheets. The spreadsheet would then clearly show who missed certain training; that is, the need (blank cell) would still be shown on the spreadsheet instead of a training received date.

• Make-up training, or an acceptable alternative, must be documented for any employee who missed a scheduled training event.


SNAP-ON INCORPORATED

ENVIRONMENTAL, HYGIENE AND SAFETY MANAGEMENT SYSTEM ISO14000 AUDIT PROGRAM OUTLINE

NOTE: All audit procedures were conducted at during the week of . GENERAL As desired, use this space for notations made during the audit. 1. During an opening meeting, provide auditee(s) with an overview

of the audit procedures and the details of this audit program, including audit purpose, approach and reporting process. The published Audit Protocol is the primary document describing the ISO14000 audit process.

2. Obtain an overview of on-site activities from the facility

manager. Document your understanding of the following: a. Individual(s) responsible for overall management of the

facility; b. Individual(s) responsible for environmental industrial

hygiene and safety activities throughout the facility; c. Role the Plant Environmental and Industrial Hygiene

Coordinator's play in facilities environmental compliance program;

d. Management organization, responsibilities, and

accountabilities; e. Description of activities conducted at the facility; f. Size of the facility; g. Number of personnel employed by the facility; h. General environmental management activities (e.g.,

number of air sources, types of wastes generated, hazardous materials stored, etc.);

i. Any unique or particular facility environmental concerns. 3. Tour the facility to gain a general understanding of the processes and areas of environmental concern.


As desired, use this space for notations made during the audit. 4. Review any previously completed audit. Verify that nonconformities

noted have been properly corrected. Also review latest Corporate Industrial Hygiene Survey.

5. Verify that all current state and local regulations are available

at the facility. 6. Determine if any "episodes of permit noncompliance" have

occurred since previous audit. "Significant noncompliance excursions," as defined in SEQ64.21, must be reported to Corporate and resolved according to that standard.

a. Review procedures used and reports generated. 7. Review any completed environmental questionnaires sent out

with initial contact letters. 8. EC and IHC's job descriptions should be current and reflect

their duties in these areas. 9. Confirm that the auditee has reported all external requests for

information about the company’s EH&S issues or the EH&S Management System to Corporate so that it can be properly logged.

10. Confirm that the facility has responded in a timely manner to

the routine quarterly EH&S training follow-ups sent out by SEQ. (Certified facilities only.)

11. Confirm that all facilities have responded with appropriate care

and detail to the most recent set of DNV audit findings and observations using the document sent out by SEQ.

• Throughout SEQ internal audit, appropriate audit

attention must be given to all applicable DNV audit findings and observations made since the last internal audit.


HYGIENE AND SAFETY


GENERAL STANDARD ON EMPLOYEE SAFETY AND HEALTH (SEQ64.01)

As desired, use this space for I. GENERAL REQUIREMENTS notations made during the audit.

NOTE: These are the same as in SEQ64.02.

II. MANAGEMENT LEADERSHIP, COMMITMENT AND EMPLOYEE INVOLVEMENT In implementing Snap-on’s safety and health program, there are various forms of commitment and support by management and employees. Some actions are described briefly as follows: 1. A clearly stated worksite policy on safe and healthful work

and working conditions. 2. Establish and communicate a clear goal for the safety and

health program at each site and define objectives for meeting that goal.

3. Convey visible top management involvement in

implementing the program. 4. Arrange for and encourage employee involvement in the

structure and operation of the program and in decisions that affect their safety and health.

5. Assign and communicate responsibility for all aspects of the

program. 6. Provide adequate authority and financial resources to site

management. 7. Hold managers, supervisors and employees accountable for

meeting their responsibilities. 8. Review program operations at least annually to evaluate their

success in meeting the goals and objectives.


As desired, use this space for III. WORKSITE ANALYSIS notations made during the audit.

In order that all hazards and potential hazards are identified, the following measures are required: 1. Conduct comprehensive baseline worksite surveys for safety

and health and periodic comprehensive update surveys. 2. Analyze planned and new facilities, processes, materials and

equipment. 3. Perform routine job hazard analyses on all jobs involved in

lost time accidents. 4. Conduct regular site safety and health inspections so that new

or previously missed hazards and failures in hazard controls are identified. Safety and health inspections are to be conducted and documented through ELMERI.

See Annex B and assess implementation of the ELMERI

safety and health monitoring tool. 5. Provide a reliable system for employees to notify local

management about conditions that appear hazardous and to receive timely and appropriate responses and encourage employees to use the system without fear or reprisal.

6. Investigate accidents so that their causes and means for their

prevention can be identified. 7. Analyze injury and illness trends over time so that patterns

with common causes can be identified and prevented. 8. Each workstation shall have warning signs (pictorials) that

continually remind employees of the hazards present at any particular workstation.

See Worksheet A, Annex A and Annex B in the SEQ and on

the EH&S website.


As desired, use this space for IV. ERGONOMIC INTERVENTION notations made during the audit.

Review site specific ergonomic intervention program. The plan at a minimum should include the following: 1. A workplace assessment to identify MSD problem jobs.

(See Table W-1 Basic Screening Tool.) This assessment will normally be performed by the Corporate SEQ Group.

a. Review makeup and meeting notes of any existing

Ergonomic Task Force/Team. (For facilities with a documented MSD problem.)

Duties of the task force or other responsible personnel

may include: (1) Track injury statistics. (2) Investigate workplace injuries and recommend

problem resolution. (3) Follow through on Ergonomic Assessment

Recommendations of the SEQ Group. (4) Review all proposed workstations and work

procedures for consistency to ergonomic principles during the planning stages of the CEC process.

(5) Documented activity must be shown at least

quarterly. 2. Medical/Rehabilitation Management - review medical case

management program. Program will incorporate at least the following:

a. Document all work-related injuries and illnesses. (1) OSHA record keeping requirement or national

equivalent. Verify OSHA300 Log is current and that the prior year’s log has been certified. (OSHA Form 300A [Summary] signed by facility manager.)

(2) Maintain a case management log tracking the

employee's treatment and rehabilitation progression including weekly follow-ups with the employee's health care provider and the employee.

(3) Provide quality medical care as expeditiously as

possible.


As desired, use this space for notations made during the audit. (4) The facility shall provide whenever possible light

or restricted duty assignments for employees undergoing rehabilitation.

3. Employee Training and Education - the Ergonomic Task

Force shall coordinate a plantwide annual training program which targets topics identified by injury surveillance activities.

Additionally, task force and/or team members should have an

annual minimum of eight hours training in safety and/or ergonomics.

NOTE: Intervention Hierarchy The plant, in carrying out its ergonomic intervention

program, shall apply the following priorities: 1. Eliminate the hazard and/or risk by engineering

control. 2. Apply appropriate safeguarding, including

administrative controls.

3. Train and instruct in ergonomics.

4. Finally, provide personal protection equipment as a last resort.

4. The SEQ Group and the facility ergonomic team/taskforce

will use the following Snap-on Checklist to document ergonomic stressors.

5. Checking and Monitoring. The SEQ Group will validate each facility’s ergonomic

program through periodic ergonomic program assessment visits and the ISO auditing program.


6. At the facility level, each workplace musculoskeletal disorder

injury, including lost time, will be considered a triggering event requiring the evaluation process described on Worksheet B.

WORKSHEET B ERGONOMICS INTERVENTION PLANS

(Mandatory) WORKPLACE ASSESSMENT TO IDENTIFY PROBLEM JOBS PROCEDURE/PRACTICE 1. The SEQ Group and the ergonomic taskforce will use the following protocol in

addressing its duties with regard to identifying problem jobs. a. Complete the Job Analysis Checklist for all MSD problem jobs in the

facility. b. Jobs that require lifting should be evaluated using the criteria covered in the

revised NIOSH Lifting Equation. In cases where the lifting index (weight lifted/recommended weight limit) exceed 3.0 (LI >3.0) the job should be considered of high risk and further assessment to reduce and/or control exposure shall be initiated.

2. Based upon the hazard ranking developed under 1(a) and 1(b) the ergonomics

taskforce should set the action agenda for a particular location. NOTE: The SEQ standard includes the Basic Screening Tool

and a Job Analysis Checklist for identifying problem jobs and lifting criteria equations.


As desired, use this space for V. HAZARD PREVENTION AND CONTROL notations made during the audit.

Where feasible, workplace hazards are prevented by effective design of the job site or job. Where it is not feasible to eliminate such hazards, they must be controlled to prevent unsafe and unhealthful exposure. These procedures should include measures such as the following: 1. Using engineering techniques where feasible and appropriate. 2. Establishing, at the earliest time, safe work practices and

procedures that are understood and followed by all affected parties.

3. Providing personal protective equipment when engineering

controls are not feasible. 4. Using administrative controls. 5. Maintaining the facility and equipment to prevent equipment

breakdowns. 6. Planning and preparing for emergencies, and conducting

training and emergency drills, as needed. 7. Establishing a medical program that includes first aid on-site

as well as nearby physician and emergency medical care to reduce the risk of any injury or illness that occurs.


As desired, use this space for VI. GENERAL INDUSTRY STANDARDS notations made during the audit.

Snap-on Incorporated believes that the nations in which it maintains “international” operations have time-proven occupational safety and health standards and it does not propose that any part of this internal generic standard contravene any political, legal, social, cultural or economic requirements imposed. In jurisdictions where competent authorities have prescribed standards that conflict with these generic standards then the national standards obviously preempt these internal generic standards. In jurisdictions where competent authorities have not addressed specific conditions covered by these generic standards, then the operating units are to include them in their occupational safety and health management system. 1. Abrasive Blasting 2. Abrasive Grinding 3. Injury and Illness Record Keeping Requirements 4. Aisles and Passageways 5. Asbestos 6. Belt Sanding Machines 7. Boilers 8. Chains, Cables, Ropes, Hooks, Etc. 9. Chipguards 10. Compressed Air, Use of 11. Compressed Gases 12. Control of Hazardous Energy 13. Cranes (Overhead and Mobile) and Hoists 14. Cylinders, Compressed Gas, Used in Welding 15. Dip Tanks Containing Flammable or Combustible Liquid 16. Dockboards


As desired, use this space for notations made during the audit. 17. Electrical Safety-Related Work Practices 18. Electrical Utilization Equipment 19. Emergency Action Plans 20. Emergency Flushing, Eyes and Body 21. Exits 22. Eye and Face Protection 23. Fan Blades 24. Fire Doors 25. Fire Protection 26. Flammable Liquids Incidental to Principal Business 27. Floors, General Conditions 28. Floor Loading Limit 29. Floor Openings and Open Sides 30. Foot Protection 31. Forklift Trucks (Powered Industrial Trucks) 32. Guards, Construction of (Annex I) 33. Hazard Communication 34. Hand Tools 35. Head Protection 36. Housekeeping 37. Ladders 38. Ladders, Portable


As desired, use this space for notations made during the audit. 39. Lighting (General) 40. Lunchrooms 41. Mechanical Power Presses 42. Machine Guarding (Annex I) 43. Machinery, Fixed 44. Mats, Insulating 45. Medical Services and First Aid 46. Noise Exposure 47. Personal Protective Equipment 48. Portable Abrasive Wheels 49. Portable Powered Tools (Pneumatic) 50. Power Transmission Equipment Guarding (Annex I) 51. Revolving Drums 52. Saws, Band 53. Saws, Portable Circular 54. Saws, Radial 55. Saws, Swing or Sliding Cut-Off 56. Saws, Table 57. Scaffolds 58. Spray Finishing Operations 59. Stairs, Fixed Industrial 60. Storage


As desired, use this space for notations made during the audit. 61. Tanks, Open-Surface 62. Toeboards 63. Toilets 64. Trash 65. Washing Facilities 66. Welding - General (see also Welding in Confined Spaces) 67. Welding in Confined Spaces 68. Woodworking Machinery 69. Radiation 70. Railings 71. Respiratory Protection NOTE: See SEQ64.01 for extensive detail on each of the above

requirements.


CHEMICAL HYGIENE & SAFETY (SEQ64.51)

As desired, use this space for I. CHEMICAL PROCESS SAFETY MANAGEMENT notations made during the audit.

NOTE: Applicability: The standard applies to all chemical

processes employing chemicals listed in the three areas noted in the standard document itself.

1. The process chemical safety program shall contain the

following elements: a. Employee participation - a written plan of action covering

consultation with employees on conduct and development of process hazard analyses.

b. Process Safety Information - this pertains to the hazards

of the chemicals used, the technology used and the equipment used; It shall be conveyed in a written format.

c. Operating procedures - developed covering each step or

operating phase, operating limits, safety and health considerations and descriptions of any safeguards available for each process. Procedures to be reviewed and approved by Corporate.

d. Process Hazard Analysis (PHA) - analyzed to identify,

evaluate and devise appropriate control schemes for process hazards. (Flowchart in SEQ standard.)

e. Training - employees working with regulated chemicals

shall be given overview training in chemical process safety and specific hazardous materials training as required in SEQ64.02.

f. Contractors - when selecting a contractor, Snap-on

entities will give due consideration to the contractor's safety performance. The contractor will be advised of all hazards to which his employees may be exposed. The contractor will certify to Snap-on that his employees have received appropriate safety training. A contract employee injury and illness log will be maintained.


As desired, use this space for notations made during the audit. g. Prestart-up Review - each new and modified system start-

up will be preceded by a safety review which will include, as appropriate, adequacy of design and construction; safety, operating, maintenance and emergency procedures; training of employees/operators and completion or updating of PHA.

h. Mechanical Integrity - each facility maintain written

procedures for maintaining ongoing integrity of process equipment, training of maintenance employees, inspection and testing consistent with good management practice. All preventive maintenance inspection and work is to be documented.

i. Hot Work Permit - where appropriate (flammable

materials) a Hot Work Permit Program will be initiated. j. Management of Change - anytime a significant process

change occurs, all process safety information and operating procedures must be updated and then certified by Corporate personnel.

k. Incident Investigation - within 48 hours of each incident

of "noncontinuous release," the facility must conduct an investigation to identify, resolve or correct any conditions or situations which may have facilitated the release.

l. Emergency Planning and Response - each facility using a

listed chemical shall have an emergency action plan certified by Corporate personnel and meeting 29 CFR 1910.38. See SEQ64.51 for elements to be included in the plan.


As desired, use this space for

II. CHEMICAL HYGIENE (Driven by SEQ64.01 Risk Assessments) notations made during the audit. 1. Review chemical hygiene plan/site safety and health plan. The plan should include the following: a. A description of the safety, health and other hazards

associated with the use of regulated chemicals. (See Risk Assessments required under SEQ64.01.)

b. Identification of the areas within the plant where

regulated chemicals may be used or stored. c. Names of personnel and alternates responsible for plant

safety and health. d. Identification of all personal protective equipment that

may be required. e. Work practices by which employees can minimize risks

from chemical hazards and accidents involving such hazards.

f. Safe use of engineering controls, equipment and work

practices limiting employee exposure to below the permissible exposure limits (P.E.L.) of such substances.

g. Compliance assurance monitoring plan for stack and

fugitive emissions of hazardous materials. The SEQ Group shall coordinate the monitoring required of this standard.

h. Any health surveillance monitoring techniques such as

symptoms and signs which might be used to detect overexposure to the listed hazardous chemicals.

i. SPCC procedures to be implemented in the event of an

accidental release. j. Examine the Emergency Evacuation Procedure and make

sure it is adequate regarding fire drills, fire extinguisher use, tornado drills, earthquake procedures, etc.

k. A written confined space entry program, where

appropriate.


As desired, use this space for notations made during the audit. l. A Hazardous Emergency Control Program. m. Is a respirator policy in effect. Document its existence

and related training. Is equipment maintenance performed as needed.

2. A hazard communication program which meets all of the

following criteria as required by 29 CFR 1910.1200 (worldwide application, as driven by SEQ64.01 Risk Assessments):

a. Hazard Communication Program: (1) The program is in writing. (2) Describes how hazards will be evaluated and

identified. (Employers may rely on the chemical manufacturer or importer.)

(3) Tests all hazardous materials in the workplace.

(Employers may rely on the chemical manufacturer or importers.)

(4) Describes our labeling system. (5) Provides a list of hazardous chemicals (inventory)

referenced on MSDS for all hazardous materials used in the workplace.

List is updated and filed annually. (6) Describes employee education and training

program (SEQ64.02). (7) Describes hazards of nonroutine tasks. (8) Describe how hazards of nonlabeled pipes will be

handled. (9) Includes procedures for informing on-site

contractors/suppliers of the hazardous substances, procedures and/or processes in the workplace to which their employees may be exposed or that may have environmentally damaging consequences. This can be covered in the contractor sign-off requirement.

(10) Is available to employees, their designated

representatives, assistant secretary of labor for OSHA, and the director of NIOSH.


As desired, use this space for notations made during the audit. b. List of Hazardous Materials in the workplace: The inventory lists contain all hazardous chemicals,

including, but not limited to: (1) Raw materials. (2) Cleaning and maintenance chemicals other than

ordinary housekeeping items. (3) Laboratory chemicals for which MSDS

information has been received. c. Hazardous Materials Labeling System: (1) All products containing hazardous materials in the

workplace are labeled. (2) Stationary containers are labeled. (3) Temporary containers used between work shifts or

by different workers are labeled. (4) A method has been established to insure that all

labels are correct and up to date. d. Contents of Hazardous Material Label: An acceptable label contains: (1) A chemical name that coincides with name on

MSDS. (2) The identity of hazards with words (in English),

picture or symbols. (3) Hazards of immediate and direct consequences of

mishandling are included. (4) The name and address of a responsible party (or

parties).


As desired, use this space for notations made during the audit. e. Material Safety Data Sheets: (1) An MSDS is available for every hazardous

chemical which an employer uses. (2) MSDS are readily accessible to exposed

employees in the work area throughout each work shift.

f. Procedures have been established for: (1) Updating MSDS (or for receiving updated copies

from suppliers). (2) Getting new and updated MSDS to employees

handling materials. g. Hazards of Nonroutine Tasks: Procedures have been established assessing the hazards of

nonroutine tasks (unusual or unscheduled) as follows: (1) All nonroutine tasks involving the use or exposure

to hazardous materials are identified. (2) The hazards involved in the performance of

nonroutine tasks are described in writing. (3) An MSDS is prepared or obtained for the

hazardous materials involved in these nonroutine tasks.

(4) A labeling system or written operating procedure

has been established to identify the hazardous substances and their hazards involved in nonroutine tasks.

(5) Special training has been established for the

performance of nonroutine tasks, including written operating procedures.

(6) A written confined space entry program, if

appropriate. h. Employee Education and Training: (1) See SEQ64.02.


As desired, use this space for III. PERMIT REQUIRED CONFINED SPACES (Driven by SEQ64.01 notations made during the audit.

Risk Assessments) 1. Note if facility has determined whether it has any permit

required confined spaces. Was this determination documented. a. Space contains or could contain a hazardous atmosphere. b. Space contains a material that has potential for engulfing

an entrant. c. Space has an internal configuration (floors, walls) such

that an entrant could be trapped or asphyxiated. d. Space contains other recognized serious safety or health

hazard. 2. If such a space exists, a. Inform exposed employees. b. Warning sign posted. c. Provisions exist to inform outside contractors of potential

hazards. 3. Training - All employees that will work in confined spaces are

to be trained. This should include: a. Knowledge of hazards, symptoms, and consequences. b. Proper use of protective, rescue, communication, etc.,

techniques and equipment. - Is equipment inspected and calibrated periodically so it is functioning at full capacity. c. Duties of attendants and supervisors. d. Communication during operation of confined space

activities. e. Rescue services (for designated rescuers) and or the use

of local emergency rescue service. f. Permit system – paperwork (for party responsible to

obtain the permit).


As desired, use this space for notations made during the audit. 4. Confined Space Entry Permit a. It is issued by a supervisor and safety coordinator after a

comprehensive review of all circumstances of entry. b. Addresses air monitoring, PPE, safety related materials

required, time of exposure limit (always less than or equal to 1 shift).

c. Original permits kept in a safety file; copies taken to the

worksite by employees involved. d. At completion of activity, questionnaire on permit

completed and returned to supervisor. e. Entry permits retained for at least one year. NOTE: The SEQ standard contains examples of: Confined Space Entry Permit Instrument Calibration Log Confined Space Listing Confined Space Survey


As desired, use this space for IV. PERSONAL PROTECTIVE EQUIPMENT PLAN notations made during the audit.

1. Each operating facility must have in place a written PPE Plan

and must review the contents of the plan at least annually. Plan requirements are driven by SEQ64.01 Risk Assessments.

General Requirements 29 CFR 1910 (U.S. Standard) General requirements of the revised PPE standard include: a. A hazard assessment, designed to identify hazards that

require PPE use, must be conducted/certified in writing. b. Based on the assessment, appropriate PPE must be

selected and properly fitted for each affected employee. c. Defective or damaged PPE must not be used. d. Employees required to use PPE must be trained (and

retrained as applicable) in PPE selection and use. e. Employees must demonstrate understanding of training.

The employer must “certify,” in writing, that the training was delivered and understood.

2. Assessment Requirements - A survey should assess the

likelihood of injury or illness that may occur in the following situations:

a. Work areas where eye, face, head, foot or hand protection

may be necessary to prevent injury from any of the following hazard sources:

(1) Machinery or processes where injury could be

caused by motion of tools, machine elements or particles, or where movement of personnel could cause collisions or tripping hazards;

(2) Temperature extremes that could cause burns or

eye injury, or could ignite PPE; (3) Chemical exposures; (4) Harmful dust that could accumulate or become

airborne, posing inhalation or physical hazards;


As desired, use this space for notations made during the audit. (5) Light radiation exposures that could occur during

operations that involve welding, brazing, cutting, furnaces, heat treating and high-intensity lights;

(6) Falling objects or potential for dropping objects; (7) Sharp objects that might cut feet or hands; (8) Rolling or pinching objects that could crush hands

or feet; (9) Facility layout and co-worker position and/or

location; (10) Electrical hazards. b. Once collected, data should be organized in order to

estimate injury potential. This helps employers determine the kind of hazard(s) involved in their operations, risk level and severity of potential injury.

c. Appropriate levels of PPE are then selected based on

hazard determination and PPE availability. d. Users must be properly fitted for specified PPE, which

must be comfortable to wear. e. Hazard reassessments must be conducted as necessary

(i.e., when processes or equipment change, or based on accident experience) in order to ensure continued suitability of selected PPE.

3. Training Requirements - Each employee affected must be

trained in: a. When PPE is necessary and what equipment must be

worn; b. How to properly don, adjust, wear and remove PPE; c. PPE limitations; d. Proper care, maintenance and useful life and disposal.



V. EMERGENCY ACTION PLANS notations made during the audit.

1. A written plan must exist that satisfies 29 CFR 1910.38. 2. The emergency action plan shall cover those designated

actions employers and employees must take to ensure employee safety from fire and other emergencies.

3. The following elements, at a minimum, shall be included in

the plan: a. Emergency escape procedures and emergency escape

route assignments; b. Procedures to be followed by employees who remain to

operate critical plant operations before they evacuate. c. Procedures to account for all employees after emergency

evacuation has been completed; d. Rescue and medical duties for those employees who are

to perform them; e. The preferred means of reporting fires and other

emergencies; and f. Names or regular job titles of persons or departments

who can be contacted for further information or explanation of duties under the plan.

g. The employer shall establish an employee alarm system

which complies with §1910.165. h. If the employee alarm system is used for alerting fire

brigade members, or for other purposes, a distinctive signal for each purpose shall be used.

i. The employer shall establish in the emergency action

plan the types of evacuation to be used in emergency circumstances.

j. Before implementing the emergency action plan, the

employer shall designate and train a sufficient number of persons to assist in the safe and orderly emergency evacuation of employees. Retrain as changes occur.

4. Consider the timing, nature and extent of a test scenario in

order to test the effectiveness of emergency response plans.



VI. FIRE PREVENTION PLANS notations made during the audit.

1. A written plan must exist that satisfies 29 CFR 1910.39. 2. Written and Oral Fire Prevention Plans. A fire prevention

plan must be in writing, be kept in the workplace and be made available to employees for review. However, an employer with 10 or fewer employees may communicate the plan orally to employees.

3. Minimum Elements of a Fire Prevention Plan. A fire

prevention plan must include: a. A list of the major fire hazards, proper handling and

storage procedures for hazardous materials, potential ignition sources and their control, and the type of fire protection equipment necessary to control each major hazard;

b. Procedures to control accumulations of flammable and

combustible waste materials; c. Procedures for regular maintenance of safeguards

installed on heat-producing equipment to prevent the accidental ignition of combustible materials;

d. The name or job title of employees responsible for

maintaining equipment to prevent or control sources of ignition or fires; and

e. The name or job title of employees responsible for the

control of fuel source hazards. 4. Employee Information. An employer must inform employees

upon initial assignment to a job of the fire hazards to which they are exposed. An employer must also review with each employee those parts of the fire prevention plan necessary for self-protection.


BIOLOGICAL EXPOSURES STANDARD (SEQ64.54) (Driven by SEQ 64.01 Risk Assessments)

As desired, use this space for notations made during the audit. 1. The facility written biological exposure program will meet

federal and/or applicable state standards with regard to occupational exposure to blood borne pathogens (29 CFR 1910.1030). The plan will contain all of the following elements:

a. Statement of Purpose. b. Exposure Determination - identify both task and

employees who may be exposed and therefore are covered by this standard.

c. Exposure Control Plan (1) Methods used for compliance. (2) Methods used for handling and disposal of

infectious or pathogen containing waste. (3) Methods for control of sharps. (4) Provision for personal protective equipment

(availability and accessibility, proper use, cleaning and disposal).

(5) Area restriction for nonengaged employees. (6) Description of any housekeeping methods and

standards that apply. (7) Description, if any, of preventative inoculation

program for Hepatitis B control. d. Provisions for post exposure evaluation, follow-up and

counseling. As part of this element, each exposed employee shall be provided with a copy of the post exposure evaluation prepared by health care professionals.

e. Provisions for communication by labels and signs. Each

facility shall have in place a program to properly identify biohazards subject to this standard.


As desired, use this space for notations made during the audit. f. Provisions for training and instruction. Each employee

identified under paragraph b of this standard shall receive an appropriate level of training prior to initial assignment and per SEQ64.02 thereafter.

Appropriate training will contain the following

attributes: (1) Copy of the standard and a summary explanation

of contents. (2) Epidemiology and symptoms of blood borne

diseases discussions. (3) Recognition of modes of disease transmission. (4) A discussion of the provisions of this standard. (5) Identification and rational of considerations

considered in determining tasks covered by this standard.

(6) Communication of the appropriateness of personal

protective equipment under this standard, including selection and proper care instructions.

(7) Information concerning the preventive benefit,

efficiency and risk of Hepatitis B vaccinations. (8) Instruction concerning notification and emergency

response procedures required during an exposure incident.

(9) Instructions concerning the standards post

exposure evaluation, review and notification procedures.

(10) Discussions on the sign and labeling warning

system used in this program. g. Record Keeping Requirements - All medical and

employee exposure records require a 30 year retention period (29 CFR 1910.20).

Training records shall be kept for a period of 3 years

including a syllabus of all training concepts presented to employees.

h. Employee Access to Records - each employee or his

designated representative may gain access to any documents pertaining to this standard.

i. Plan Review and Evaluation - each facility shall review

its program at least biennially and make appropriate changes because of personnel reassignment or other factors.


HEARING CONSERVATION PROGRAM (SEQ64.56)

(Driven by SEQ 64.01 Risk Assessments) NOTE: This standard applies when workplace noise levels exceed

85 dBA AL (83 dBA in practice) on a time weighted As desired, use this space for average basis. notations made during the audit. 1. General - employees exposed above 85 dBA AL must have

hearing protection provided at no cost to the employee. Additionally, employees exposed above 90 dBA or those who have been documented to have experienced a standard threshold shift are mandated to wear hearing protection.

2. Noise Monitoring - corporate or designee shall monitor

representative noise levels at each facility annually. Noise monitoring should include personal exposures as well as area exposures. Results of such monitoring will be reported to the Facility Manager as part of the annual industrial hygiene appraisal. (See SEQ64.56 for noise levels and required action.)

3. Audiometric Exams - should be performed by appropriate

personnel. (See SEQ standard for test condition and frequency). Record keeping of audiograms must include all of the following:

a. Name and job classification of employee. b. Date of audiogram. c. Examiner's name and credentials. d. Date of last acoustic or exhaustive calibration of the

audiometer. e. Employee's most recent noise exposure measurement. f. Measurements of background sound pressure levels in

test room. (See SEQ standard for details on the timing of exams and on

the actions to be taken depending on the test results.) 4. Personal Protection Equipment - each facility shall have at

least three hearing protectors as part of the hearing conservation program.


As desired, use this space for notations made during the audit. 5. Education & Training - each facility shall provide training for

all employees exposed to and above the eight hour TWA AL. The training shall be updated and documented per SEQ64.02. Training shall include the following:

a. Care and proper use of hearing protectors. b. Proper fit techniques of protectors. Advantage and

disadvantage and attenuation ratings of supplied protectors.

c. Effects of noise on hearing. d. Purpose of audiometric testing and an explanation of the

test procedure. e. Each facility shall have available and post a copy of 29

CFR 1910.95 in a conspicuous place where employees/representative may gain access for informational purposes.

6. Record Keeping Requirements - all employee exposure

records shall be kept for 30 years. All employee audiograms shall be retained for 40 years and

include items listed in 3a-f.


MACHINE SAFETY (SEQ64.71)

As desired, use this space for I. POINT OF OPERATION SAFETY notations made during the audit.

1. Point of Operation Guarding - each facility shall have in

place a point of operation guard program containing the following essential elements:

a. Employee operator training and responsibility/safety role

indoctrination. b. Inspection, maintenance and modification procedures. c. Die setting instruction and performance criteria.

NOTE: Power machine safety applies as follows: • All power brakes shall be operated and managed in

accordance with 29 CFR 1910.217. • All power shears shall be operated and managed in

accordance with ANSI Draft B11.4-19XX or its successor document.

• All other power machines shall be operated and

managed in accordance with 29 CFR 1910.212 General Machine Guarding as summarized in SEQ64.01.

See SEQ64.71 for detailed M&T Guidelines on

Power Machine Safety.



II. CONTROL OF HAZARDOUS ENERGY notations made during the audit. 1. Appropriate employees will be instructed in the purpose of this

lockout/tagout standard by a trainer designated by the facility manager. Only authorized employees can lockout/tagout machinery or equipment. The authorized employee will be identified on each hazardous energy control procedure form. Also, affected employees will be identified on the same form.

2. Each employee who will use a lock or tagout system procedure

on machines or equipment must receive training in the recognition of applicable hazardous energy sources, the type and magnitude of the energy which exists, and methods and means necessary for isolation and control. Each facility must certify this training or retraining and have documentation on file containing employees names, position and date of training.

3. Employees, other than authorized employees, only need to be

able to: a. Recognize when control procedures are being

implemented. b. Understand the purpose of the procedure and the

importance of not attempting to start up or use equipment that has been locked or tagged out.

4. Employees will be retrained if there is a change in their job

assignment to an area which will involve use of energy control procedures.

Retraining will also occur if there is a change in machines,

equipment or processes that present a new hazard, or when there is a change in the energy control procedures.

5. Lockout/Tagout Practice Refer to the Corporate Standard for detailed procedural

requirements, exceptions, special OSHA requirements, supervisor responsibility, disciplinary action, and removing equipment from service.


As desired, use this space for notations made during the audit. 6. Documentation/Record Keeping Authorized employees who perform lockout or tagout

procedures will need to document what they do on a tag. Entries on the log must include: - Date lockout was performed. - Time applied. - Time released. - Machine or equipment involved. - Employees signature to verify the entries. Upon removal of the lockout, all tags shall be turned in to the

Maintenance Supervisor. 7. Periodic Inspections At least once a year an inspection shall be held to ensure that

proper procedures are being followed. Tags which have been turned in will be reviewed to ascertain that the program is being utilized.

Employees who utilize the lockout system shall have their

responsibilities reviewed with them and documented at least annually.

8. Also note the Corporate Standard's requirements regarding

special circumstances, group lockout/tagout, information for general production workers, and cautions.


As desired, use this space for III. ELECTRICAL SAFETY - RELATED WORK PRACTICE notations made during the audit.

1. Has any formal identification of personnel to which this standard applies been carried out. 2. Has an electrical safety-related work practices program been

established and documented that encompasses training requirements consistent with the provisions of this standard.

a. Appropriate personnel trained. b. Adequate number trained in CPR. c. Training includes use of warning sign, guards, other

protective devices, and safe operating procedures. d. Training in emergency situations is to be included. NOTE: A list of potential training subjects appears in the

standard.


ENVIRONMENTAL


MAINTENANCE OF ENVIRONMENTAL PROGRAM RECORDS As desired, use this space for notations made during the audit. 1. Verify environmental records are current and up to date.

(Review records since previous audit.) a. Environmental permits - federal, state and local. b. Laboratory test reports - internal and external. c. Process control records, permits and annual reports to

control authorities - federal, state and local.

d. Review annual filing requirements and whether required calculations were made (Tier II, SARA, Form R).

e. Manifests and shipping papers for hazardous wastes. f. Site inspection reports. g. Annual facility environmental reports. h. Administrative actions, sanction or orders. i. Exemptions or variances. j. Facility procedural manuals. k. Environmental training manuals. l. Employee training records - environmental. m. Audit reports and activities. n. Any required solvent management plan. 2. Facility manager or designee is responsible for: a. Receiving, reviewing, filing, and distributing, as

required, all environmental records. b. Send copies of these records to Corporate. c. Review records for accuracy and completeness once

annually. NOTE: All records are to be retained in accordance with the

Manual of Practice, Section 4.4.4. NOTE: Corporate personnel are to assist in the

accomplishment of these objectives.


ENVIRONMENTAL PERMIT REVIEW (SEQ64.04) As desired, use this space for notations made during the audit. 1. Determine extent of permits required under the following: a. Hazardous waste management (RCRA). b. Discharge of industrial effluents and stormwaters, if

appropriate. c. Other state, local and federal act, statute or regulation

pertaining to the environment. d. Stormwater Pollution Prevention Plan - Does both a plan

document and a permit exist. 2. An environmental permit review will be conducted for every

new or existing Environmental Permit required for an emission source.

a. Copy of the completed Environmental Permit

Application will be submitted to Corporate for review and approval.

b. Copy of actual permits should be forwarded to Corporate

within 14 days of receipt from the issuing agency. 3. The SEQ standard specifies the responsibilities of facility and

of Corporate personnel within the permit acquisition and maintenance process.


POLLUTION CONTROL DEVICES (SEQ64.21) MAINTENANCE, PERFORMANCE MONITORING AND EVALUATION As desired, use this space for

I. NEW OR PROPOSED DISCHARGE SOURCES notations made during the audit.

Environmental Impact Review - Review plant additions since previous audit. Review environmental impact reviews for the following items: 1. Description of emission source or discharge source. 2. Assessment of emissions and discharges - qualitative and

quantitative measurements. 3. Determination of compliance or application of appropriate

environmental regulations. 4. Information on required construction and/or operating permits. 5. Engineering design data. 6. Description of compliance action, if required. 7. Description of the surveillance program necessary to show

compliance with local, state or federal environmental regulations.


As desired, use this space for II. EXISTING DISCHARGE SOURCES notations made during the audit. 1. Plant Daily Records - a daily operating log shall be

maintained for each piece/system of pollution control equipment. Daily inspections as well as any unusual incident such as a spill, system upset, noncompliance episode or unplanned maintenance shall be recorded.

2. Monthly Performance Reports - These shall be forwarded to

Corporate by the 15th day of each month for the previous calendar month. The report will include the following information. (A standardized format for this report, as well as a “Chemical Usage Form,” exists in SEQ64.21.)

a. Facilities regulated as Metal Finishing will monitor

wastewater monthly for all 40 CFR 433 parameters with the exception of T.T.O.

Also, on a quarterly basis, provide an influent/effluent

analysis (at minimum four control parameters - COD, TSS, CRT, NIT and total phenols).

Also, facilities outside the U.S. will monitor their

discharges against the appropriate limits included in their permit/authorization.

b. Facilities not regulated under 40 CFR 433 will monitor

their wastewater biweekly for pH, TSS, F.O.G. and COD, and provide an influent/effluent analysis quarterly.

NOTE: Analytical Procedures:

• U.S. facilities are to use the appropriate Test America lab facility

• Non-U.S. facilities will use local certified

laboratories. c. The Report shall establish the chemical unit cost, based

on gallons processed and treatment chemical usage, and the disposal cost for each waste stream, including the solids from air pollution control equipment.

d. Reports should also include (if applicable) results of

monitoring sludge dewatering systems. Required monitoring includes percent solids in, percent solids out and percent reduction due to dewatering.


As desired, use this space for notations made during the audit. 3. Maintenance Record Keeping and Preventive Maintenance

Schedules - Operator in charge shall develop a record keeping and preventive maintenance system which will inventory and detail each component of the pollution control system. Minimum requirements are as follows:

a. Name and location of the equipment or structure (i.e.,

pumps, tanks, mixers, etc.). b. Name and address of manufacturer, supplier or builder. c. Cost and installation date. d. Type, style, model. e. Capacity, size or rating. f. Serial number. g. Nature and frequency of routine preventive maintenance. h. Proper lubricants, and schedule of attention. i. Any unusual repair and replacement of any component

part. NOTE: This requirement may be fulfilled in

conjunction with a facility-wide PM program.


III. EXISTING EMISSION SOURCES/AREA SOURCES (Under The MACT Standard For Decorative Chromium As desired, use this space for

[NESHAPS], 40 CFR 63 Subpart N) notations made during the audit. 1. All decorative chromium plating operations using a chromic acid

solution must meet a NESHAPS emission limit of 0.01 mg./dscm. USEPA has determined that an acceptable alternative compliance means is demonstrated by maintaining a bath surface tension of less than 45 dynes/cm (40 CFR 63.342(d)(2)).

All affected facilities must demonstrate conformance on

chromium emissions by instituting a surface tension monitoring program for decorative chromium plating baths. The monitoring program must include at least the following:

a. Monitoring Frequency (1) Once every four hours of operation (2) If all measurements are below 45 dynes/cm after

40 hours of operation, can reduce frequency to (3) Once every eight hours of operation (4) If all measurements are below 45 dynes/cm after

40 hours of operation, can reduce frequency to (5) Once every 40 hours of operation (6) Must start over at monitoring once every four

hours if any measurements greater than 45 dynes/cm

b. Record Keeping/Log Book (1) Record following information: ⎯ Surface tension measurements ⎯ Fume suppressant (wetting agent) additions ⎯ Sample temperature/specific gravity (if using

stalagmometer) (2) Log book must also include: ⎯ Manufacturer’s instructions


As desired, use this space for notations made during the audit. 2. Additionally, air scrubbers and other air emission control

devices including ductwork are subject to the inspection maintenance and record keeping requirements under Section 3.(3) of this standard.


As desired, use this space for IV. POLLUTION CONTROL SYSTEM MAY UPSET PLAN OF ACTION notations made during the audit.

It is a foregone conclusion that a given pollution abatement system from time to time experiences upsets and falls out of compliance with regard to both regulatory requirements and Corporate policy. It is the purpose of this section to define a “significant noncompliance excursion,” prescribe plant reporting requirements to Corporate concerning such excursions and detail the procedural mechanism by which a generating waste stream source may be taken off line until the abatement system upset has been remediated to the point that a compliant discharge or emission results. 1. “Significant noncompliance excursion” is an episode of permit

noncompliance which exceeds three (3) hours in duration or an event which results in a spill or release into the environment of materials which have published RQ quantities under CERCLA.

2. All episodes of “significant noncompliance excursion” are to

be reported to the SEQ Group by the facility manager or his designee as soon as an affirmative determination has been made that the event is significant per Paragraph 1.

3. The Director, SEQ Group or his designee will respond by

lending any assistance required for the timely and effective remediation of the episode.

4. Should the episode of “significant noncompliance excursion”

concern the upset of a pollution abatement system, and should the episode be likely to continue for an extended period of time, i.e., eight (8) hours or more, a determination to cease the source operation of the waste stream shall be made as follows:

a. By a consensus of the facility manager and the Director,

SEQ Group or his designee. b. Should no consensus be reached under the deliberation of

4(a), the matter shall be referred to the appropriate Division Manager by the Director, SEQ Group or his designee.


As desired, use this space for V. STORMWATER POLLUTION PREVENTION notations made during the audit.

Detailed requirements are now outlined in Section 6.0 of SEQ64.21 concerning stormwater pollution prevention plans and their administration.


POLLUTION PREVENTION PRACTICE (SEQ64.31) As desired, use this space for

I. WASTE MINIMIZATION AND RESOURCE CONSERVATION notations made during the audit. 1. Review the facility's waste minimization and resource

conservation efforts. a. Are such efforts and results documented. b. Have the following points been considered. (1) Conserve energy, raw materials and natural

resources through wise use and reuse. (2) Strive to eliminate pollution at its source. (3) Recycle or sell nonhazardous waste where

possible. (4) Minimize the generation of all hazardous waste. (5) Operate, inspect and design facilities in a manner

protective of human health and environment. (6) Recognize and respond to raised concerns by

employees and the public about products and operations.

c. Do responsible personnel periodically audit the plant for

conformance with this operating procedure. 2. Has facility prepared their annual Waste Minimization

Worksheet and submitted it to Corporate by February 15 of each year?

3. Review facility’s activities regarding the pursuit of the Snap-on

Environmental Achievement Award. a. Determine if all performance measures (metrics for

continuous improvements) are being properly tracked, recorded and reported to Corporate.

(Six categories – Energy conservation, wastewater

performance, waste volume, waste management, recycling volume, environmental innovations.)


As desired, use this space for II. STRATOSPHERIC OZONE PROTECTION notations made during the audit. 1. Review and document whether the facility has controls in place

regarding the following requirements of this standard (for us or companies/contractors used by us).

NOTE: If outside sources are used to service air conditioning

and refrigeration equipment, the facility may demonstrate compliance with these requirements by having on-site documentation that services are performed by certified technicians.

a. Requires service practices that maximize recycling of

ozone-depleting CFC's and HCFC's during the service and disposal of air conditioning and refrigeration equipment.

b. Sets certification requirements for recycling and

recovery equipment, technicians and reclaimers. c. Requires persons servicing or disposing of air

conditioning or refrigeration equipment to certify that they have acquired recycling or recovery equipment and are complying with the requirements of the rule.

d. Requires the repair of substantial leaks in air

conditioning and refrigeration equipment with a charge greater than 50 pounds.

e. Establishes safe disposal requirements to ensure the

removal of refrigerants from goods that enter the waste stream with the charge intact.

f. Requires record of refrigerant release, charging and

HVAC/R maintenance to be kept. g. Failure of any operating facility to manage its ODC's in

accordance with 40 CFR Part 82 may result in fines of up to $25,000 per day of violation. (U.S. only)

NOTE: The Corporate Standard provides substantial detail

under each of the above points. NOTE: The use of all nonessential ozone depleting chemicals

in the manufacturing and packaging of the Corporation’s products is prohibited.



III. CONSERVATION ON PACKAGING AND LABELING notations made during the audit. Determine the facility's policy on using environmentally sound packaging (crates, trays, wrappers, bags or tubes) and packaging components (labels, blocking, bracing, cushioning, weatherproofing, strapping, coating, inks, dyes, pigments, adhesives, and glues). Consider the content of heavy metals, the use of ozone depleting chemicals in their production, and their amount of recyclable content. The SEQ standard provides specific restrictions in these areas. NOTE: These items maybe outside the control of the facility and be

determined by Corporate personnel. NOTE: Only Director, SEQ Group can grant an exemption from

this policy requirement based on vendor representations.


IV. PRODUCT LIFE CYCLE - COLLECTION AND DISPOSITION As desired, use this space for OF RETURNED PRODUCT (North America only) notations made during the audit.

1. The Replacement Processing Center (RPC) in Nashville is used for this purpose.

a. Note procedures regarding the collection and disposition

of replaced products. Is this done in a secure, cost effective and

environmentally sound manner.


V. BATTERY RECYCLING (Under the Mercury Containing Rechargeable As desired, use this space for Battery Management Act [HR2024] (U.S. and Canada only) notations made during the audit.

1. Note facility’s procedures regarding collection, shipping and recycling of nickel cadmium batteries. Hazardous waste manifests may have to be used when shipping to INMETCO. Other specific documentation requirements also exist. See details in SEQ64.31.

Small quantities of Ni-Cd’s can be disposed of at certain

commercial establishments. Call 1-800-8BATTERY for the nearest location.


As desired, use this space for VI. CLIMATE CHANGE PREVENTION notations made during the audit.

1. Note extent of facility’s efforts to limit and/or reduce CO2 emissions.

2. Have efforts been included within the annual Waste

Minimization Worksheet to be submitted to Corporate personnel.

3. Note any specific initiatives taken by the facility in the

following areas: a. Greenlights upgrades b. Improve Equipment and Processes • Optimize boiler efficiency. • Improve the design and performance of compressed

air systems. • Use and maintain steam traps. • Submeter utility services to learn where and how

energy and water are not economically used. • Replace “once through” cooling systems with

“closed loop” cooling systems. c. Use Best Management Practices • Switch to less polluting fuels, cogenerate and use

renewable energy resources when feasible. • Recover waste heat for productive uses. • Reduce trips by fleet vehicles and employees. • Reduce wasted materials by improving inventory

management procedures. • Compare your company’s energy and environmental

performance with that of competitors. d. Integrate Efficiency in Product Design and Manufacturing • Engineer energy-efficient production processes. • Recycle waste streams as feedstock. • Design products that are energy efficient and can

be reused or recycled.


As desired, use this space for notations made during the audit.

• Include pollution prevention and energy efficiency

objectives in quality assurance, productivity enhancement and re-engineering programs.

4. Has facility assigned specific personnel to suggest, study and

implement improvements in energy usage, fuel usage, water conservation, waste reduction, material substitutions or any other change which may have a positive effect on the environment and the bottom line.

5. Facilities assessing options under this standard may use the

attached Option Screening Matrix and instructions and submit this document along with a narrative on all projects that are implemented under this section with the inventory of conservation effort report.

NOTE: Corporate SEQ Group personnel shall serve as a resources

to all facilities in meeting the reporting and other requirements of this section.


HAZARDOUS AND NONHAZARDOUS WASTE MANAGEMENT (SEQ64.61)

As desired, use this space for I. HAZARDOUS WASTE MANAGEMENT notations made during the audit.

1. Note details of the facility’s procedures under each of the

following headings. (NOTE: Substantial detail is available in SEQ 64.61.)

a. Hazardous Waste Determination and Periodic (biennial)

Validation (TCLP tests) - of waste oil, light bulbs and RCRA solid waste streams and possibly ballasts containing PCB’s.

b. Manifest Requirements - review information

completeness, proper distribution and execution. c. Pre-Transport Requirements - regarding packaging,

labeling, marking, placarding and accumulation time. d. Record Keeping - regarding manifests, annual and

biennial reports, pertinent lab reports and exception reports.

e. Preparedness and Prevention – regarding general

operations/facility management, equipment requirements, equipment testing and maintenance, communication and alarm systems, adequate aisle spacing and required arrangements with local authorities.

f. Contingency Plan and Emergency Procedures -

regarding SPCC plan – regarding purpose and implementation, SPCC plan contents, distribution of SPCC plan copies, amendment requirements for SPCC plans, emergency coordinator designation and duties and emergency procedures to be followed in case of release, fire and/or expolosion.

2. Note any plant level hazardous waste management audits

(self-audits) conducted to ensure compliance with SEQ64.61 and their results.


As desired, use this space for II. TREATMENT, STORAGE AND DISPOSAL FACILITY AUDITS notations made during the audit.

1. Review facility’s procedure for and documentation received

during review of TSD facility. The review should include the following: a. Contact the local regulatory agency of the state in which

hauler and/or TSD facility is licensed or the Regional Administrator for the region.

(1) Confirm the licensing status of the transporter

and/or TSD facility. (2) Whether or not the source is presently facing

enforcement action or has in the past. (3) Any plans to curtail or restrict regulated activity at

the facility in the future. b. An initial visit to the proposed TSD facility should assess

the following: (1) Security at the facility. (2) Facility and equipment are professionally

managed. (3) Question the TSD facility management concerning

their record keeping requirements as follows: daily inspections, training, operating records (disposal and treatment) and emergency contingency procedures.

c. Review final approvals as granted by Corporate. d. Biennial Validation - Additionally, at least on a biennial

basis, the Facility Environmental Coordinator shall review the status of each TSD facility with appropriate regulatory control authorities and for U.S. facilities request that the SEQ Group provide a record search using the VISTA TSDF Monitor Information System.


As desired, use this space for III. WASTE OIL MANAGEMENT PRACTICE notations made during the audit.

1. Note facility’s procedures and requirements relative to waste

oil management. Each operating facility generating waste oil must prepare and

implement a waste oil management plan that meets the requirements of national or local laws (e.g., in U.S., 40 CFR 279).


EH&S PROGRAM DOCUMENTATION

Determine the facility’s compliance with the detailed document and record retention requirements as set forth in the following table.

N.R. - NOT REQUIRED

* - DISCARD WHEN SUPERSEDED

Record

Document

Review Period

Retention Period

1. Company Newsletters X N.R. N.R.

2. EH&S Manual X Annual Permanent*

3. Facility Audits X N.R. 5 Years

4. Remedial Action Plans X N.R. 10 Years

5. Preacquisition Audits X N.R. Permanent

6. Misc. Govt. Correspondence X N.R. 5 Years

7. Site Investigation Reports X N.R. 10 Years

8. Five Quarters Reports X N.R. 5 Years

9. Accident Prevention Results X N.R. 5 Years

10. Industrial Hygiene Assessments X N.R. Permanent

11. Ergonomic Assessments X N.R. 5 Years

12 Wastewater Discharge Results X N.R. 5 Years

13. Waste Manifest X N.R. Permanent

14. Air Permits X N.R. Permanent*

15. Wastewater Permits X N.R. 5 Years*

16. Stormwater Permits X N.R. 5 Years*

17. Self-Monitoring Reports X N.R. 5 Years

18. Air Emissions Inventory X N.R. 5 Years

19. Form R Reports X Annual 5 Years

20. Tier II Inventory and Supporting Records X Annual 5 Years

21. OSH Logs X Monthly 5 Years

22. OSH Supplemental Records X Monthly 5 Years

23. TSD Contracts X N.R. Permanent

24. Enforcement Action Records X N.R. Permanent

25. Regulations - State, Federal, Local

X N.R. Permanent*

26. Air, Water Permit Application X N.R. 10 Years


N.R. - NOT REQUIRED

* - DISCARD WHEN SUPERSEDED

Record

Document

Review Period

Retention Period

27. Stack Sampling Reports * 5 Years 10 Years

28. Wastewater Operator Certificates X 5 Years*

29. Material Safety Data Sheets X Annual Permanent

30. M & T Standards X Annual Permanent*

31. TSD Audits X Biennial 5 Years

32. Chemical Hygiene Plans (SEQ64.51) X Biennial Permanent*

33. Ergonomic Intervention Plan (SEQ64.52) X Biennial Permanent*

34. Chemical Process Safety (SEQ64.51) X Biennial Permanent*

35. Biological Exposure Control Plan (SEQ64.54) X Biennial Permanent*

36. Point of Operation Plan (SEQ64.71) X Biennial Permanent*

37. Hearing Conservation Plan (SEQ64.51) X Biennial Permanent*

38. Confined Space Plan (SEQ64.51) X Biennial Permanent*

39. Hazardous Energy Control Plan (SEQ64.71) X Biennial Permanent*

40. Maintenance Performance (SEQ64.21) X Biennial 5 Years

41. Laboratory Quality Assurance (SEQ64.41) X Biennial 5 Years

42. Training Records (SEQ64.02) X Biennial 5 Years

43. Worksite Assessments Inspections Accident Investigations

X N.R. 5 Years

44. SPCC Plans X Annual Permanent*

45. Emergency Evacuation Plans (SEQ64.51) X Biennial Permanent*

46. Stormwater Pollution Prevention Plan X Biennial Permanent*

47. Pollution Prevention Plans (SEQ64.31) X Biennial Permanent*

48. Plant Daily Operating Logs (SEQ64.21) X N.R. 5 Years

49. Monthly Performance Reports (SEQ64.31) X N.R. 5 Years

50. Waste Minimization Worksheets (SEQ64.31) X N.R 5 Years

51. PPE Assessments X Annual 5 Years

52. Inventory of Conservation Efforts X Annual 5 Years

53. Log for External Communication X Annual 3 Years

54. Senior Management Review Acceptance Form X Annual 3 Years

55. Current Action Plan X Annual 3 Years


EMPLOYEE TRAINING PROGRAM (SEQ64.02)

As desired, use this space for I. GENERAL REQUIREMENTS notations made during the audit.

1. Each employee actively involved in the operation and

implementation of the Environmental, Hygiene and Safety Management System and employees exposed to hazardous conditions or substances must receive on an annual basis the training required to maintain their knowledge and skills at an acceptable competence level.

Training programs must include the following as appropriate: a. General Requirements (1) Each employee potentially exposed to hazardous

materials shall be trained in the proper identification and quantification of exposures.

(2) Employees potentially exposed shall be familiar

with the necessary personal protective equipment and its proper use and maintenance.

(3) Employees potentially exposed shall be familiar

with the SPCC and their role in plan implementation.

(4) Employees potentially exposed to unsafe

conditions or agents shall be given adequate and periodic training with regard to the recognition and elimination of safety hazards.

(5) Employees involved in EH&S Management

System operation and implementation will receive annual skill-enhancement training.

(6) Certified facilities shall provide quarterly training

updates, i.e., percent of allocated task completed, to the lead auditor of the SEQ Group.

b. Hazard Communication Requirements (29 CFR 1910:1200) (Follow SEQ64.51 in preparing the HCP) (1) Each employee shall be informed of the following

information: (a) Requirements of the Hazard Communication

Standard.



notations made during the audit. (b) Operations in their work area where

materials deemed hazardous are present. (c) The location and availability of the written

hazard communication program, including required list(s) of hazardous chemicals and MSDS's.

(2) Employee training shall include at least the

following: (a) Methods and observations that may be used

to detect the presence or release of a hazardous chemical in the work area.

(b) The physical and health hazards of the

chemicals in the work area. (c) The measures employees can take to protect

themselves from these hazards. (d) The details of the hazard communication

program developed by the plant, including the labeling systems, MSDS and how employees can obtain and use the appropriate hazard information.

NOTE: Exposure and training records are

to be maintained permanently. c. Hazardous Waste Training - essential elements of

hazardous waste training shall include at least the following (for those employees responsible for or engaged in activities or operations involving hazardous waste):

(1) Federal and state hazardous waste regulation as

appropriate for the jurisdiction. (2) Procedures and practices for using, inspecting,

repairing and replacing emergency and monitoring equipment.

(3) Contingency plans, including emergency response

implementation.



(4) Hazardous waste training (within 6 months of

initial assignment and reinforcement training annually).

NOTE: Retain training records indefinitely or at

least 30 years after date of last employment/assignment.

d. Has the facility implemented the required provisions of

Hazardous Materials 181 (HM-181). Are those who handle hazardous materials at any point in the plant trained in the appropriate handling procedures (including dock workers)?

e. Emergency Response Requirements - At a bare

minimum, each employee required to respond to incidental releases shall have, on an annual basis, training courses designed to address the following:

(1) Understanding what hazardous materials are used

in their workplace and the risks associated with an incidental release.

(2) Ability to recognize the presence of such releases. (3) Understanding the role of all participants engaged

in a release response. (SPCC) (4) Understanding the various steps involved in

implementing the SPCC plan and the Stormwater Pollution Prevention Plan (SPPP).

(5) Knowledge of what is proper personal protection

equipment and how to select it. (6) Decontamination techniques where required. (7) Understanding the relevant standard operating

procedures and operation termination procedures. f. Laboratory Personnel Standard (1) Inquire and document any special or more in-depth

information and/or training provided to laboratory workers exposed to hazardous chemicals. Divisional responsibilities in this area per 29 CFR 1910.1450(f) are:

(a) Employee information and training. The

employer shall provide employees with information and training to ensure that they are apprised of the hazards of chemicals present in their work area.



(b) Such information shall be provided at the time

of an employee’s initial assignment to a work area where hazardous chemicals are present and prior to assignments involving new exposure situations.

The frequency of refresher information and

training shall be annually. (c) Information. Employees shall be informed of: i. The contents of this standard operating

procedure and Procedure SEQ64.51 Chemical Hygiene and Safety Plan shall be made available to employees;

ii. The location and availability of the

Chemical Hygiene and Safety Plan SEQ64.51;

iii. The permissible exposure limits for

regulated substances or recommended exposure limits for other hazardous chemicals where there is no applicable national standard;

iv. Signs and symptoms associated with

exposures to hazardous chemicals used in the laboratory; and

v.The location and availability of known

reference material on the hazards, safe handling, storage and disposal of hazardous chemicals found in the laboratory including, but not limited to, Material Safety Data Sheets received from the chemical supplier.

(d) Training (basic requirements of employee

proficiency). i. Employee training shall guarantee

proficiency in:



A. Methods and observations that may

be used to detect the presence or release of a hazardous chemical (such as monitoring conducted by the employer, continuous monitoring devices, visual appearances or odor of hazardous chemicals when being released, etc.);

B. The physical and health hazards of

chemicals in the work area; and C. The measures employees can take to

protect themselves from these hazards, including specific procedures the employer has implemented to protect employees from exposure to hazardous chemicals, such as appropriate work practices, emergency procedures and personal protective equipment to be used.

(e) Plants that are determined to be exempt from

29 CFR 1910:1450(f), as a laboratory adjunct to a production process, shall include laboratory safety and hygiene training as a part of the facility written hazard communication program.

g. General Safety and Hazard Elimination

Each plant and operating facility will conduct periodic worker safety training as indicated by Schedule A. (Table follows.)

Additionally, members of ergonomic teams and safety

committees shall receive a minimum of eight hours training annually (such as two four-hour primers on ergonomics and safety).

h. Implementation

It is the responsibility of each Facility Manager to maintain within his plant a training schedule consistent with the requirements of this standard.



i. Tests of Emergency Procedures (Drills) Both emergency evacuation as well as environmentally-

oriented (spill response) drills are to be conducted (at least one drill per year). (NOTE: Relative to D.C.’s, only the Olive Branch D.C. is required to have a spill response drill given its unique set of exposures compared to other D.C.’s.) Be sure to document and evaluate drills and act on improvements needed.


SCHEDULE A SAFETY TRAINING FOR LINE EMPLOYEES (U.S. OPERATIONS)

TYPE

REFERENCE*

EMPLOYEE GROUP

UPDATE - ESTIMATED TIME

1. Emergency Response Plan

29 CFR 1910.38 SEQ64.01, SEQ64.51

All Annually, 15 Mins.

2. Fire Prevention 29 CFR 1910.39 SEQ64.01, SEQ64.51

All Annually, 15 Mins.

3. Hazard Communication 29 CFR 1910.1200 SEQ64.01, SEQ64.51

Affected Employees Annually, 1 Hr.

4. Hearing Conservation 29 CFR 1910.95 SEQ64.01, SEQ64.56

Exposed at 85 dBA or Higher Annually, 15 Mins.

5. Confined Space 29 CFR 1910.146 SEQ64.01, SEQ64.51

Affected Employees Biennially, 30 Mins.

6. Personal Protective Equipment

29 CFR 1910.132 (f) SEQ64.01, SEQ64.51

Affected Employees Annually, 15 Mins.

7. Laboratory Safety 29 CFR 1910.1450 SEQ64.01


8. Lockout/Tagout 29 CFR 1910.147 SEQ64.01, SEQ64.71


9. Powered Indus. Trucks 29 CFR 1910.178 SEQ64.01

Fork Drivers Biennially, 30 Mins.

10. Electrical Safety 29 CFR 1910.332 SEQ64.01, SEQ64.71


11. Fire Extinguishers 29 CFR 1910.157 SEQ64.01


12. Welding-Cutting 29 CFR 1910.252 SEQ64.01


13. Blood-borne Pathogens 29 CFR 1910.1030 SEQ64.54


14. Process Safety 29 CFR 1910.119 SEQ64.01, SEQ64.51

(Covered Under 3. Above)

15. Hazardous Materials Transportation

49 CFR 172(H) SEQ64.01, SEQ64.61

Affected Employees Biennially, 1 Hr.

16. Lead Exposure 29 CFR 1910.1025 SEQ64.01


17. Machine Safety 29 CFR 1910.217 29 CFR 1910.212

SEQ 64.01, SEQ64.71


18. Ergonomics SEQ64.01 Affected Employees Biennially, 15 Mins.

19. Stormwater 40 CFR Part 122.26 SEQ64.02, SEQ64.04


20. EH&S MS Awareness ISO14001, 4.4.2 All Annually, 15 Mins.

21. RCRA Hazardous Waste 40 CFR 261 & 262 SEQ64.61


* Applies to U.S. Operations.


SCHEDULE A-1 (NON U.S. OPERATIONS) ANNUAL SAFETY TRAINING FOR LINE EMPLOYEES

TYPE

REFERENCE*

EMPLOYEE

GROUP

RISK ASSESSMENT

1 HR.

OTHER SAFETY

1 HR.

ENVIRON- MENTAL

1 HR.

OTHER ½ HR.

1. Emergency Response Plan

SEQ64.01 SEQ64.51

All √

2. Fire Prevention SEQ64.01 SEQ64.51

All √

3. Hazard Communication SEQ64.01 SEQ64.51

Affected √

4. Hearing Conservation SEQ64.56 Exposed at 85dBA or

Higher

√

5. Confined Space SEQ64.01 SEQ64.71

Affected √

6. Personal Protective Equipment

SEQ64.01 SEQ64.51

Affected √

7. Laboratory Safety SEQ64.01 Affected √

8. Lockout/Tagout SEQ64.01 SEQ64.71

Affected √

9. Powered Indus. Trucks SEQ64.01 Fork Drivers √

10. Electrical Safety SEQ64.01 SEQ64.71

Affected √

11. Fire Extinguishers SEQ64.01 Affected √

12. Welding-Cutting SEQ64.01 Affected √

13. Blood-borne Pathogens SEQ64.54 Non-Applicable

14. Process Safety SEQ64.01 SEQ64.51

(Covered Under 3. Above)

√

15. Hazardous Materials Transportation

SEQ64.01 SEQ64.61

Affected √

16. Lead Exposure SEQ64.01 Affected √

17. Machine Safety SEQ 64.01 SEQ64.71

Affected √

18. Ergonomics SEQ64.01 Affected √

19. Stormwater SEQ64.02 SEQ64.04

Affected √

20. EH&S MS Awareness ISO14001, 4.4.2

All √

21. Industrial Hygiene OHSAS 18001, 4.4.2

√

* Applies to non U.S. Operations. ** Facility management has the option to complete an annual certification to satisfy A-1 recordkeeping. *** Blood-borne Pathogens training does not apply to non U.S. Operations.


COMMUNITY OUTREACH AND EMPLOYEE INVOLVEMENT (SEQ64.81)


1. Determine the nature and extent of any community outreach

program in place at the facility. 2. Have the following elements, as set forth in detail in

SEQ64.81, been incorporated into the outreach efforts. a. Written facility description and identification of

communities. b. Identification of community concerns. c. Solicitation of employee environmental input and

concerns. d. Imparting of an environmental message or contribution,

including the education of the community on the facility’s environmental impacts.

e. Obtaining feedback from the community regarding

facility environmental issues. f. Providing training or information for employees to

ensure that the employees know about the facility’s position on environmental and health issues and environmental policies and plans. (EH&S Awareness Training.)

3. EPA Performance Track facilities – the Snap-on Performance

Track facilities shall demonstrate a willingness for identifying and interacting with affected communities, identifying community needs and a plan of action for addressing those community needs by addressing the following components (see SEQ standard).


MENTORING PROGRAMS (SEQ64.82)


1. Determine the nature and extent of the efforts to mentor

facility’s smaller suppliers. 2. Have the following elements, as detailed in SEQ64.82, been

included in any mentoring efforts. a. Project assessment. b. Long-term focus. c. Establishment of commitments and expectations of all

parties involved. d. Establishment of an effective time frame. e. Solicitation of program feedback. 3. Note involvement of Corporate personnel.

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APPENDIX II ISO14000/OHSAS 18000 Audit Program Outlineaddresses all elements of ISO14001 and OHSAS...

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