Emergency Action/ Fire Prevention Plan

CONTENTS Introduction and Purpose 3 Definitions 4 Roles and Responsibilities 5 Plan Location 8 Potential Fire and Other Emergency Situations 8 Types of Emergency Evacuations 11 Fire Prevention Performance Standards 11 Fire Extinguishers 12 Fire Emergency Procedures 13 Bomb Threat Procedures 14 Emergency Evacuation Procedures and Escape Route Assignments 15 Essential Facility Equipment/Machine Shutdown 17 Contractors and Visitors 18 Headcounting Procedure 18 Rescue 18 First Aid/Medical Duties 18 Training 19 Evacuation Drill 19 Post-Emergency Procedures 20 Plan Updating 21 Recordkeeping 21

EMERGENCY ACTION/ FIRE PREVENTION PLAN FIGURES HAZARD FIRE EXTINGUISHER LOCATION AND EVACUATION ROUTES MAPS Figure 1: Fire Hazard Location Map Figure 2: Fire Extinguisher Location Map Main Manufacturing Building Figure 3: Fire Extinguisher Location Map Warehouse Building Figure 4: Evacuation Route Map Cafeteria Figure 5: Evacuation Route Map Crusher Area Figure 6: Evacuation Route Map Finishing Map 1 Figure 7: Evacuation Route Map Finishing Map 2 Figure 8: Evacuation Route Map Lower Warehouse Shipping Area North Figure 9: Evacuation Route Map Lower Warehouse Tunnel Area Figure 10: Evacuation Route Map Lower Warehouse Shipping Area South Figure 11: Evacuation Route Map Lower Warehouse Stairway Area Figure 12: Evacuation Route Map Machine Shop Figure 13: Evacuation Route Map Main Office Figure 14: Evacuation Route Map Molding Southeast Figure 15: Evacuation Route Map Pattern Shop Figure 16: Evacuation Route Map Sputtercoat Figure 17: Evacuation Route Map Tunnel Area Figure 18: Evacuation Route Map Upper Warehouse 2 Lift Area Figure 19: Evacuation Route Map Upper Warehouse North/West Figure 20: Evacuation Route Map Upper Warehouse Shipping Area Figure 21: Evacuation Route Map Upper Warehouse South APPENDICES Appendix A: Emergency Contact Numbers and Employees Trained in First Aid/CPR Appendix B: Emergency Event Report Appendix C: Fire Extinguisher Monthly Inspection Testing Records and Protocol Appendix D: Training Program and Fire/Evacuation Drill Log Appendix E: Maintenance Procedures for Heat Producing Equipment/Machines 2

Introduction and Purpose This Emergency Action and (EAP) has been developed and implemented by ABC Co. located at 123 Green St. Rochester, NY 14607 ( Facility ) as part of meeting the Occupational Safety and Health Administration's (OSHA) General Industry Standard for Employee Emergency and s [29 CFR 1910.38 and.39], and requirements for Portable Fire Extinguishers [29 CFR 1910.157]. Further, this EAP has been developed and implemented to provide procedures for safe evacuation of Facility employees during emergency situations, including response to fires, explosions, chemical and petroleum releases, terrorist attacks (eg, bomb threats) and related hazards. Other related OSHA regulations for fire notification, detection, extinguishing and suppression systems [29 CFR 1910.155 through.165], and electrical systems [29 CFR 301 through.399] are evaluated with the assistance of qualified fire protection consultants and building code inspectors. This EAP presents designated actions that the Facility will take in the event of an emergency, including ensuring that resources (eg, equipment, materials, external emergency response services, etc.) are available and accessible. In addition, the implementation of this EAP is meant to facilitate and ensure that the following Facility emergency and fire prevention policies and procedures are followed: The Facility is a 911 Facility. Employees are prohibited from responding to Facility emergencies, with the exception of administering first aid and/or CRR on a voluntary basis and that is within the scope of their training. Employees are only to use portable fire extinguishers for the purposes of extinguishing an incipient fire. Employees must not use fire extinguishers unless they have been trained on how and when to use them. Employees will follow regulatory and Facility requirements identified in this EAP during emergencies. EHS management will train employees to recognize and understand emergency and fire hazards, the elements of this EAP (eg, roles and responsibilities, emergency procedures, etc.). Appropriate Facility employees will be made aware of pertinent elements of the regulations at 29 CFR 1910.38..39 and.157 as they relate to the oversight of outside contractors (eg, communication of Facility procedures and potential hazards, etc.). 3

Definitions Exit marking: (1) Exit markings are visible signs and/or passages that permit direct and complete exit from a building. (2) Any door, passage or stairway identification sign, which indicates the way is not an Exit way, such as To Basement or Not an Exit. Extinguisher rating: The numerical rating given to an extinguisher that indicates the extinguishing potential of the unit based on standardized tests. Means of egress: A continuous and unobstructed way of exit travel from any point in a building or structure to a public way and consists of three separate and distinct parts: the way of exit access, the exit, and the way of exit discharge. A means of egress comprises the vertical and horizontal ways of travel and shall include intervening room spaces, doorways, hallways, corridors, passageways, balconies, ramps stairs, enclosures, lobbies, escalators, horizontal exits, courts and yards. Exit access: That portion of a means of egress that leads to an entrance or exit. Exit: That portion of a means of egress that is separated from all other spaces of the building or structure by construction or equipment as required to provide a protected way of travel to the exit discharge. Exit discharge: The portion of the means of egress between the termination of an exit and a public way. Emergency action plan: A plan for the workplace, or parts thereof, describing what procedures the employer and employees must take to ensure safety from fires or other emergencies. Emergency escape route: The route that employees are directed to follow in the event they are required to evacuate the workplace or seek a designated refuge area. Incipient stage fire: A fire in the initial or beginning stage that can be controlled or extinguished by portable fire extinguishers, standpipes or small hose systems, and without the need for protective clothing or breathing apparatus. Inspection: A visual check of fire extinguishers to ensure that they are in place, charged and ready for use. Low-hazard contents: Hazards of such low combustibility that no self-propagating fire therein can occur and that consequently the only probable danger requiring the use of emergency exits will be from panic, fumes, smoke or fire from some external source. High-hazard contents: Hazards that are liable to burn with extreme rapidity or from which poisonous fumes or explosions are to be feared during a fire. Ordinary-hazard contents: Hazards which are liable to burn with moderate rapidity and to give off a considerable volume of smoke but from which neither poisonous fumes nor explosions are to be feared in the event of a fire. 4

Roles and Responsibilities The Safety Coordinator is responsible for the overall development and implementation of this EAP, including designating employees and external resources to perform specific safety functions and for delegating responsibility and authority to perform those functions. The following roles and responsibilities have been clearly communicated to appropriate employees (eg, through written job descriptions and/or training) in order to promote employee involvement, accountability and the implementation of response actions during Facility emergencies. Table 1 below contains a list of key personnel responsible for maintenance and implementation of the EAP. Facility operations are conducted during 3 shifts (ie, Monday through Friday) as follows: Finishing and Warehouse Operations 1 st Shift 7:00 AM 3:00 PM Molding Operations 1 st Shift 7:00 AM 3:00 PM 2 nd Shift 3:00 AM 11:00 PM 3 rd Shift 11:00 PM 7:00 AM Names and telephone numbers for key personnel identified in Table 1 below, employees trained in first aid and/or CPR, and other employees and entities involved with the maintenance and implementation of this EPA are listed Appendix A. Table 1. Roles and Responsibilities Key Personnel Role Overall EAP Development and Implementation PERC 1 st Shift Title Safety Coordinator Engineering Services Manager SERC 1 st Shift VP Human Resources Line Supervisor 1 st Shift Maintenance Supervisor 1 st Shift PERC 2 nd Shift SERC 2 nd Shift Maintenance Supervisor 2 nd Shift PERC 3 rd Shift SERC 3 rd Shift Maintenance Supervisor 3 rd Shift Production Manager Maintenance Supervisor Molding Supervisor Molding Supervisor Molding Supervisor Molding Supervisor Molding Supervisor Maintenance Supervisor 5

The general responsibilities of the individuals responsible for emergency response are described below. Primary Emergency Response Coordinator (PERC) The PERC shall be the principal contact with the Rochester ( FD ) and other 911 designated emergency response agencies listed in Appendix A. Responsibilities include the following: Understanding potential hazards of Facility processes and resources (eg, fire extinguishers and FD) needed for appropriate emergency response actions; Communicating resource needs to management for procurement; Ensuring that outside emergency services are designated, such as medical and first aid services, HAZMAT teams and the FD; Assessing the Facility and determining whether an emergency exists that requires emergency response procedures; Providing direction, including evacuating personnel and taking a final roll call of all evacuated personnel; Directing the shutdown of Facility operations when necessary and/or possible; Ensuring that employees know the identity of the individuals to contact in the event of an emergency; Conducting compliance reviews and final review of plan updates; Documenting the events of the emergency using the emergency event report in Appendix B; and Participating in conducting fire drills and documenting them in the fire -evacuation log in Appendix D. Secondary Emergency Response Coordinator (SERC) The SERC shall be available to serve as the PERC in the event that the PERC is absent and unable to fulfill the responsibilities set forth above. Otherwise, the SERC shall assist the PERC during emergencies as required and described in this EAP. Safety Coordinator The Safety Coordinator is in charge of the development, implementation and updating of this EAP, including ensuring that: The EAP is updated annually; The EAP has been coordinated internally and approved by management (eg, President); Information about the EAP (eg, roles and responsibilities) is communicated to employees, contracted employees and visitors; Initial and annual training is conducted; 6

Drills are conducted and documented twice per year, including with external resources (eg, Rochester ) where feasible; Outside emergency services have Facility-specific information regarding potential emergencies (eg, chemical spills); Outside emergency services have access to the Facility in the event of an emergency; Required fire notification, detection, extinguishing and suppression systems are identified, maintained, inspected and tested; Good housekeeping procedures are implemented; Heat producing equipment/machines and systems are properly maintained, and combustible or flammable materials are not stored in close proximity to such equipment/machines and systems (see Maintenance Procedures for Heat Producing Equipment in Appendix E); Other specific responsibilities as noted in the EAP (eg, follow-up report completion after emergencies, notifying appropriate regulatory agencies during emergencies, if necessary, etc.) are addressed and implemented. Coordinating the evacuation of employees and visitors, as well as addressing and implementing other specific responsibilities noted in the EAP (eg, accounting for staff who remain behind to shut down critical Facility utilities); Assisting in the safe and orderly emergency evacuation of employees; Participating with head counting (eg, to account for visitors or contractors) with the PERC/SERC; Knowing the location of fire extinguishers at the Facility; Understanding the hazards of processes at the Facility that can result in an emergency; Promoting safe operations, maintenance and good housekeeping procedures to prevent fires at the Facility; Making employees aware of the location of designated primary and/or secondary emergency assembly areas (ie, Upper Parking Lot or other designated areas); and Communicating to all employees that they are responsible for exercising and improving safety in the workplace. Line Supervisors and Maintenance Supervisors The Line Supervisors and Maintenance Supervisors are responsible for the following: The control, maintenance and inspection of fuel source hazards (eg, flammable liquids and welding gases); The control, maintenance and inspection of bulk chemical and petroleum storage and containers; 7

Maintenance, inspection and testing of fire extinguishers; Maintenance of equipment and systems installed on heat producing equipment to prevent accidental ignition of combustible materials; and Ensuring that hazardous chemicals, including compressed gas cylinders and flammable liquids, are stored properly according to applicable standards (eg, in a secure fashion and in locations that are free from contact hazards, in flammable storage cabinets, etc.). First Aid/CPR It is the policy of the Facility that employees are not permitted to participate in administering emergency medical response procedures. However, employees can voluntarily administer first aid and/or CPR, provided that such employees maintain current training and can demonstrate their ability to respond within the scope of their training. Individuals trained and certified in first aid and/or CPR, including telephone numbers are included in Appendix A. For more specific information regarding medical and first aid procedures and resources, see the Facility s Medical and First Aid Program in the Facility Health and Safety Program Manual. Plan Location The Safety Coordinator will provide this EAP to employees, contractors, visitors and agency representatives (eg, OSHA) upon request or as needed. This EAP is available at the following location in the Facility: Safety Coordinator s Office. Evacuation routes, the location of fire extinguishers and Facility hazards (ie, identified in Table 2, Section, Potential Fire and Other Emergency Situations), and emergency contact information have been posted throughout the Facility. Potential Fire and Other Emergency Situations An evaluation of the Facility has been completed to determine potential fire and emergency hazards, and appropriate controls. Table 2 indicates the preventative mechanisms and controls that are in place. 8

Table 2. Potential Hazards and Controls Hazard/ Location Potential Hazard / Ignition Sources Controls Equipment or Procedure Bulk Paints & Solvents (eg, Paint Room) Explosion, Fire, Spark/Flame Store in fire and explosion proof cabinets/proper containers Ansul System Spill procedures Gas Cylinders (eg, Welding Gases, etc.) Explosion, Fire, Proper storage (eg, securing cylinders with chains and storage at required distances) Paint Booths (Paints and Solvent Mixtures) Explosion, Fire, Proper storage, Ventilation Bulk Hydraulic Oil (New and Used, totes and tanks) Fire/sparks, flame Proper Storage Spill procedures Propane Tanks Explosion, Fire, Proper storage containers Shut-Off Valves Oily Rags, Antique or Paint/Solvent Soiled Rags Fire, Storage in proper Containers Boilers Explosion, Fire, Maintenance Shut-off valves Gas Lines Explosion, Fire, Maintenance Shut-off valves Diesel Fuel Tanks (For Boiler 200 and 250 Gallons) Fire, Maintenance Flammable Liquids (Solvent Cleaners, etc.) Fire, Proper storage containers and cabinets Spill procedures 9

Table 2. Potential Hazards and Controls (Contd.) Hazard/ Location Molding Machines (Hydraulic Oil Reservoirs) Hazardous Waste Storage Battery Charging Station (Fork Lifts) Part Cleaners Cans Cryogenic Liquid Nitrogen Transformers Potential Hazard / Ignition Sources Fire Explosion, Fire, Explosion, Fire, Fire, Explosion Explosion, Fire, Controls Maintenance Proper storage containers and container labeling Maintenance Proper storage containers Proper storage containers Equipment or Procedure Spill procedures Spill procedures Spill procedures Spill procedures Spill procedures Spill procedures MSDSs Material safety data sheets ( MSDSs ) are available in work areas where hazardous chemicals and petroleum products are used or stored. A complete MSDS book and Chemical Inventory is maintained in the Safety Coordinator s Office. A copy of the Chemical Inventory is within the HAZCOM Program in the Facility Health and Safety Program Manual. The MSDSs indicate proper handling and storage procedures for appropriate materials identified above or other chemicals used at the Facility. Locations of potential hazards that may result in emergency evacuation are identified in Figure 1 that is attached to this Program. The PERC or SERC or other designated employees are responsible for retrieving MSDSs during an emergency response, if necessary. 10

Types of Emergency Evacuations The following types of emergencies have been identified as potentially requiring evacuation: Explosions; Fires; Chemical releases; and Bomb threats. Specific employer and employee responsibilities and procedures for each type of emergency are discussed below. Fire Prevention Performance Standards The following procedures have been implemented at the Facility: Checking areas for the identification of all potential fire hazards and putting measures in place to reduce the risk (eg, implementing ignition source controls, making sure that solid waste (eg, combustible materials) containers are not overflowing, etc.); Inspection of or arranging for inspection of, the Facility fire notification system (ie, audible alarm and PA system) to ensure that it is operational in the event of an emergency; Inspecting emergency lighting on a routine basis (eg, monthly); Inspecting all fire extinguishers monthly to make sure they are marked, spaced properly and maintained as specified by the manufacturer and the Fire Extinguisher Standard [29 CFR 1910.157]; Inspecting Facility fire doors to make sure they are operational and maintained as specified by manufacturers instructions; Inspecting and maintaining Facility exits, approaches and ways of travel to designated emergency primary and secondary assembly areas to ensure that they are free from obstructions and/or impediments; Ensuring that all designated employees receive required fire extinguisher training; Ensuring that employees understand that fire extinguishers are to be used solely for the purposes of incipient stage fires and that they are not to use them unless they have received proper training; Ensuring that all Facility gas lines are inspected on a periodic basis by Niagara Mohawk Power Corporation; Ensuring that gas cylinders and bulk storage tanks/containers are inspected and maintained according to applicable regulations; 11

Ensuring that the hazard waste storage and paint room are inspected, including the fire prevention/suppression system (ie, Ansul System) for the paint room; Ensuring that used oily rags, waste oil and other flammable/combustible wastes are stored in appropriate containers and away from potential ignition sources; and Ensuring that electrical systems are installed and maintained according to applicable electrical codes and standards. Fire Extinguishers OSHA s Portable Fire Extinguisher Standard for General Industry [29 CFR 1910.157] requires monthly inspection, maintenance and testing of fire extinguishers and training for employees who may operate a portable fire extinguisher when responding to an incipient stage fire at the Facility. Fire Extinguisher Types and Locations Table 3 below indicates the basis types of fire extinguishers used and maintained at the Facility. Table 3. Classes of Fire Extinguishers Fire Extinguisher Class A B C D Fire Extinguisher Maintenance Fire Types Combustible materials (eg, wood, paper, cloth, etc) Flammable liquids Electrical Metals The Facility has placed combination ABC and D-type fire extinguishers throughout the Facility, including on Facility Powered Industrial Trucks for extinguishing incipient fires. The locations of Facility fire extinguishers are shown in Figures 2 and 3 attached to this Program. All portable fire extinguishers are inspected monthly, tested and maintained according to the testing protocol (ie, Table L-1 of the Fire Extinguisher Standard [29 CFR 1910.157] included in Appendix C. A list of all fire extinguishers at the Facility and monthly inspection and testing records are also included in Appendix C. Monthly fire extinguisher inspections are performed by Facility maintenance personnel and testing (eg, yearly) is performed by Jerome Fire Equipment who also supplies and replaces fire extinguishers as needed. 12

Fire Emergency Procedures Incipient Fires The following response actions must be taken in the event of an incipient fire at the Facility: Employees authorized and trained to use fire extinguishers must be familiar with general principles of fire extinguisher use and the hazards involved with incipient stage fire fighting; If the fire is determined to be in its incipient stage, an authorized employee who has received fire extinguisher training and training under this EAP can attempt to extinguish the fire; Incipient fires must be reported to the PERC or SERC. 911 must be called if a fire is determined as non-incipient; and All incipient fire incidents will be documented by the PERC or SERC using methods similar to those noted in the Emergency Event Report in Appendix B. Note: The PERC or SERC will make the decision whether or not the area needs to be evacuated. Non-Incipient Fires If it is unknown whether the fire is incipient, the following procedures for response to non-incipient fires must be followed: Employees that discover a fire must notify the PERC or SERC; Any employee may activate the Facility notification system (ie, audible alarm and/or 911) when necessary; Based on the size of the fire and/or the potential for harm to personnel, the PERC or SERC will make a determination regarding the need for partial or full Facility evacuation; The type of fire emergency situation (eg, low-hazard contents, high-hazard contents or ordinary hazard-contents) will be the basis for determining the most appropriate evacuation action to be taken. The PERC or SERC will make this determination; All evacuations will take place in accordance with the procedures identified in the Section of this EAP titled Emergency Evacuation Procedures and Escape Route Assignments ; Non-incipient fires must be reported to the PERC or SERC; and All non-incipient fire incidents will be documented by the PERC or SERC using methods similar to those noted in the Emergency Event Report in Appendix B. 13

Bomb Threat Procedures Understanding the Facility s potential exposure to bomb threats, preventative measures and reporting procedures can minimize dangers to employees in the event of a bomb threat. This section provides guidelines for preventing bomb threats and identifies procedures to follow should one occur. Bomb Threat Preventive Measures The most effective program for prevention of bomb threats is to ensure that the Facility is protected against unauthorized entry, trespass or sabotage. Although every attempt is made to secure the Facility, it is the responsibility of all employees to be aware of the following: Visitors, contractors and other non-facility employees are not allowed in the Facility or on Facility property without approval/escort; All visitors/contractors must report and sign-in at the Main Office Front Desk if they will be at the Facility for a prolonged period of time (eg, 1 hour or more); Persons working outside the main office must be accompanied by a representative from the Facility and/or must have appropriate identification as a visitor/contractor; Unidentified packages (eg, that have no return address or security tag) must be treated as suspicious; and Doors to the Facility are never propped open unless a Facility representative is present. Procedures for Verbal Bomb Threats All personnel, especially those at the main telephone or reception desk must be trained regarding what to do in the event of a bomb threat. If a verbal bomb threat is received, the following procedures must be followed: An effort must be made to have more than 1 person listen in on the call; An attempt must be made to keep the caller on the line for as long as possible; Ask the caller where the bomb is located and for the estimated detonation time; Inform the caller that the building is occupied and that if the bomb is detonated it could result in death or injury for many people; Report the information immediately to the Police Department and the Fire Department (ie, dial 911); and Evacuate the building when instructed to do so. 14

Procedures for Written Threats The following procedures will be followed if a written threat is received: Save all materials including any envelopes or containers that the threat came in; Notify proper authorities using the 911 system; and Evacuate the building when instructed to do so. Emergency Evacuation Procedures and Escape Route Assignments The signal for evacuation will be an audible alarm and/or PA system. The primary assembly area has been designated as the Upper Parking Lot or other areas that will be designated by the PERC or SERC. If the use of the audible alarm system is not possible, verbal communications, including by telephone/cell phone between the PERC and SERC must be made to indicate evacuation procedures and escape routes. Figures 4 through 21 attached to this Program indicate emergency evacuation routes throughout the Facility. The following procedures must be followed by Facility employees in the event of an evacuation: Partial Evacuation All communication lines must be cleared. No unauthorized personnel may use the telephone; The PERC or SERC determines whether only a partial evacuation is necessary; If possible, operators of machines, equipment and trucks, and building systems (eg, main electric and gas) should turn off such where feasible (ie, if employee safety is not compromised), evacuate the area and proceed to designated safe areas; Individuals who are responsible for shutting down specific equipment or Facility utilities prior to evacuating are identified in the Section below entitled Essential Facility Equipment/Machine Shutdown; Other affected personnel, including contractors, will be moved to a safe area in or outside the Facility according to evacuation routes identified in Figures 4 through 21 attached to this Program; All personnel that are moved to the safe areas will gather there for a head count by the PERC or SERC or other designated personnel; and The PERC or SERC or other designated personnel conducting head counting procedures will report the results of the attendance to the PERC or SERC. 15

Full Evacuation All communication lines are to be cleared. No unauthorized personnel shall use the telephone; The PERC, SERC or authorized personnel will make an announcement to alert employees of an emergency situation; Announcement: Attention all employees. There is an emergency situation in the building. Please go to the nearest available exit and evacuate the building. This is not a drill. (Repeat this announcement twice); All personnel will evacuate the building via the routes designated on the Facility Evacuation Maps (ie, Figures 4 through 21 attached to this Program); If possible, operators of machines, equipment and trucks, and building systems (eg, main electric and gas) should turn off such where feasible (ie, if employee safety is not compromised) and evacuate the area; Individuals who are responsible for shutting down specific equipment or Facility utilities prior to evacuating are identified in the Section below entitled Essential Facility Equipment/Machine Shutdown; Once shutdown procedures are complete, these individuals will proceed to the designated area and immediately check in with the PERC or SERC; The PERC or SERC, or other designated personnel, must attempt to assist those personnel with impaired mobility in evacuating the building. This can be accomplished by using the buddy system ; The PERC or SERC or other designated personnel (eg, office receptionist) must retrieve the Contractor/Visitor Sign-In Sheet to account for such individuals; The PERC or SERC or other designated personnel must check rooms and other enclosed spaces for personnel that may be trapped or otherwise unable to evacuate, provided that employee safety is not compromised; All personnel will gather outside at the designated Primary Assembly Area (ie, Upper Parking Lot); Other assembly areas will be designated by the PERC or SERC when deemed necessary; The PERC or SERC will gather all personnel from their respective work areas and begin the head counting process; The PERC will verify the Facility wide roll call. If personnel are unaccounted for, the PERC will identify individuals to re-enter the building (ie, if appropriate) to determine the employee s whereabouts. Individuals designated to re-enter the building must be those who are most familiar with the employee s most recent location and/or work habits; 16

Prior to re-entering the building, the specific location of the search must be designated and a time schedule for reporting back to the PERC must be established and implemented accordingly; All other employees will not re enter the Facility until the PERC has given the allclear signal; and After the all clear has been given, Facility employees may re-enter the building and resume work activities. Essential Facility Equipment/Machine Shutdown A review of Facility operations and discussions with Facility personnel have indicated that there are no essential machines, equipment, systems, vehicles or utilities that would require emergency shut down. However, the PERC, SERC or other designated personnel (eg, Maintenance Supervisor) will be responsible for shutdown of Facility operations and utilities, if feasible and if employee safety is not compromised. Emergency shutdown procedures include the following: ABC Co. Finishing Department Shut off glass machine; Turn off air make-up units; and Turn off all ovens. ABC Co. Sputter Coat Machine Put machine in manual mode; Turn off D.C. drive power; Turn off source power; Turn off outside conveyor; Turn of kilowatt hours; and Turn of argon. ABC Co. Molding Department Be certain that all presses are shut down in the open position to prevent mold damage; Shut down all chillers and cock off mold cooling water to prevent mold damage; Shut off all rotovent units and all floor fans; Be certain that all colorant supplies are shut off; and Shut off all resin transfer equipment. 17

General Turn off electric main; Outside behind Boiler Room Turn off gas main; Outside behind Boiler Room and Warehouse Northeast corner-upper; and Turn off water main; Behind boiler room Once essential Facility operations are shut down, such personnel will immediately exit the building and proceed to the primary and/or secondary assembly area. Upon exiting the building, such employees will immediately notify the PERC or SERC of his/her presence, and that the Facility operations and utilities have been shut down. Contractors and Visitors All contractors and visitors must sign in at the front desk upon Facility entry if they will be present at the Facility for a prolonged period of time (eg, 1 hour or more). Prior to initial entry into the main building, the Safety Coordinator or authorized employee will communicate work place hazards and emergency evacuation procedures to contract employees and visitors. The PERC or SERC will check for contracted employees and visitors during an emergency evacuation and include these individuals as part of performing headcounting. Headcounting Procedure When the Facility is evacuated, the PERC or SERC will count employees, contracted employees and visitors and immediately report their findings to emergency response entities (eg,, Police and emergency medical response entities). If contractors and/or visitors are reported to have been in the Facility, the PERC or SERC will check with the Facility contact person indicated by the contractor/visitor on the signin sheet located at the front desk. Rescue Rescue duties, including confined space rescue, will be the responsibility of the Rochester. Facility personnel will not re-enter the building unless approved to do so by the, PERC or SERC. First Aid/Medical Duties Emergency first aid and medical response will be the responsibility of the Rochester Fire Department and Greater Rochester Ambulance Corps. The and Ambulance can be summoned by dialing 911 or by contacting the PERC or SERC who will dial 911. 18

Any employee administering first aid and/or CPR will only do so on a voluntary basis and as covered during their training. Additional information is provided in the Facility s First Aid and Medical Program. The hospital designated as nearest to the Facility is St Joseph s Hospital (see Emergency Contact Numbers in Appendix A for additional information). Training All employees, including contracted employees, must be informed of potential hazards at the Facility that may result in emergency evacuation. All Facility employees must be trained: Initially upon employment/assignment; When an employee s roles/responsibilities change; Whenever hazards at the Facility or the Facility s Fire Prevention Plan has changed; and When emergency evacuation is not performed satisfactorily according to procedures and policies identified in this EAP. EAP roles and responsibilities, resources and procedures are included in the Facility health and safety awareness training program that gets administered on an annual basis (see Facility Health and Safety Awareness Training Program in the Facility Health and Safety Program Manual). The PERC, SERC or other designated employee immediately in charge of contracted employees or visitor s, is responsible for communicating information about the Facility and the EAP to the contractor or visitor. Training must include a description of the components of this Plan and the roles/responsibilities of all employees, including contracted employees. Evacuation Drill Evacuation/fire drills must be conducted a minimum of twice per year and all employees must participate. In addition, external emergency response entities (eg, Rochester Fire Department) will be contacted to participate in the drills, where feasible. The PERC or SERC must contact the local emergency agencies to coordinate the drills. The drills must be documented by the PERC or SERC in a report that includes the following information, at a minimum: Time and date; Weather conditions; Shift number; Type of simulated emergency; Time taken to evacuate; 19

Number of unaccounted for employees/visitors; Other observations; and Recommendations. A copy of the report must be issued to the Safety Coordinator for review. Comments, recommendations or other information pertinent to the evacuation drill must be submitted to the PERC or SERC so that recommendations can be incorporated into updates to the EAP and the Facility Health and Safety Awareness Training Program. Drills and Maintaining Facility Operations The PERC or SERC will advise designated personnel when a drill is being conducted to assure that core Facility operations and safety are maintained. Before fire drills, the PERC or SERC will assign a Facility representative to remain at the Reception Desk to answer the telephone in order to maintain operations, where feasible. Unless an employee has been assigned this task during drill procedures, all employees are to immediately evacuate the building if an evacuation signal is given (eg, audible alarm and/or PA system). Post-Emergency Procedures Emergency Event Report Upon termination of any emergency situation, it is the responsibility of the PERC, SERC or designated employee to document the events of the emergency. The report must be prepared using an emergency event report (see Appendix B) and must include the following: Date and time of event; Weather conditions; Description of emergency event; Description of implementation/adequacy of EAP; Responsiveness of local emergency agencies; Casualties; Damages; and/or Recommended corrective actions. The report must include information collected by interviewing key facility personnel involved in the emergency event. A copy of the report must be submitted to Safety Coordinator for review. The report must also be submitted to the PERC so that recommendations can be incorporated into updates to the EAP and the Facility Health and Safety Awareness Training Program. Reporting of fires and other emergencies to proper authorities will be made by the PERC or SERC. 20

Decontamination/Cleanup Upon termination of an emergency situation, decontamination or cleanup of the Facility may be required. An approved and certified contractor, chosen by the Facility must complete any required cleanup or decontamination resulting from a HAZMAT incident. HAZMAT Companies designated as qualified are indicated in the emergency contact list posted in various places in the Facility and attached to this Program in Appendix A. Plan Updating This plan must be revised as necessary based on the results of the evacuation/fire drills, emergencies and comments from employees (eg, obtained during training sessions). It is the responsibility of the Safety Coordinator, together with Facility PERCs and SERCs to review the Plan on an annual basis. This update process will include a review of the following, at a minimum: Adequacy of personnel assignments and resources; Accuracy of emergency contact information; Review of potential fire and other emergency situations; Incorporation of recommendations from evacuation drills, emergency reports and employee comments; and Review of applicable regulatory standards. Recordkeeping It is the responsibility of the Safety Coordinator to maintain all records generated as a part of this EAP. These records include the following: Emergency event reports; Evacuation drill reports; Monthly fire extinguisher inspection and testing records; Emergency notification system (ie, alarm and PA) inspection and testing records; Electrical, fire detection and suppression system (eg, sprinkler system and Ansul System for paint room) inspection and testing records; Maintenance records for heat producing equipment/machines and systems; and Personnel training records. Official records pertaining to the Facility s EAP, training or other recordkeeping is maintained by the Facility Safety Coordinator and can be obtained by contacting the Safety Coordinator, PERC or SERC. 21