14641 E. Don Julian Rd. City of Industry, CA CONTRACTOR/VENDOR SAFETY, HEALTH & FIRE PROTECTION PROCEDURES

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1 SCOPE CONTRACTOR/VENDOR SAFETY, HEALTH & FIRE PROTECTION PROCEDURES This procedure applies to Contractors and Vendors performing work at Bentley Mills, Inc. s facility. Its purpose is to define responsibility of outside Contractors and Vendors while working on Bentley Mills, Inc. s property. It provides the minimum guidelines which are expected to be understood and followed. BMI recognizes that many environmental and safety hazards are inherent in both industrial-related work or services and construction activities. These hazards can result in injuries, property damage and chemical releases that may affect the well-being of our associates and the environment, or have a negative financial impact. Therefore, BMI requires that all Contractors and Vendors follow applicable Company and Regulatory requirements in order to minimize any such impact on our associates, the environment or facility operations. This procedure shall be binding under terms of the contract including all standards, such as, but not limited to those noted. APPLICABILITY This policy and associated procedures apply to all Vendors and Contractors who perform work at Bentley Mills, Inc. s facility and to applicable Bentley Mills, Inc s employees who retain Contractors, Subcontractors or Vendors. RESPONSIBILITIES/PROCEDURES It is the responsibility of the Bentley Mills, Inc. to contact and inform all Contractors and Vendors of this policy and applicable procedures prior to issuance of purchase order or services rendered. Contractors and Vendors must sign and verify their acceptance and understanding of these conditions and return the original form to Purchasing. Bentley Mills, Inc. s safety representatives or any member of management has the right (but not obligated) to determine if the Contractor/Vendor is performing in accordance with the regulations set forth in this standard. At any time during the Contractor s/vendor s contract, continued unsatisfactory practices, evaluation, or injury experience may serve to disqualify the Contractor/Vendor from further work. 5

2 CONTRACTOR/VENDOR RESPONSIBILITIES (cont) ALL COMPANY ENVIRONMENTAL AND SAFETY PROCEDURES SHALL BE APPLICABLE TO ALL CONTRACTORS/VENDORS WHILE IN THE FACILITY Contractor/Vendor visiting the facility must review with project manager the safety, fire, and other related information. (Including Chemical Spills.) All company representatives (including Sub-Contractor drivers) have been informed and agree to abide by Bentley Mills, Inc. s Procedures and Responsibilities. Federal, State and Local Requirements The Contractor/Vendor must comply with all applicable provisions of federal, state, and local environmental, safety and health laws and building codes. The most stringent of these shall serve as the minimum standard unless the provisions contained in applicable Company Standards are more stringent, in which case the Company s Standards will govern. Nothing in this, or any other, Company Standards relieves the Contractor/Vendor from fully understanding and complying with the Federal Occupation Safety and Health Act (OSHA), California Occupational Safety and Health Act (Cal/OSHA), the Federal Mine Safety and Health Act (MSHA), and all other applicable laws, regulations and standards. Chemical delivery requirements - The following is required for all Contractor/Vendors delivering chemicals to Bentley Mills, Inc.. Please check yes or no for each item. Yes No N/A Completed Health, Safety, & Environment Training Yes No N/A Spills kits on trucks Yes No N/A Drivers responsible for spill clean-ups Yes No N/A Drivers trained for spills Yes No N/A Drivers carry spill instructions and copy of MSDS Conduct of Contractor s/vendor s Employees While on the Company s property, the Contractor/Vendor shall not: o Use or be under the influence of alcohol or any controlled substance 6

3 CONTRACTOR/VENDOR RESPONSIBILITIES (cont) o Fight or gamble o Abuse, steal, destroy, or use property of the Company s or Company s employees o Bring firearms or other such weapons onto Company property, including parking areas. Personal Injury and Property Damage When an accident results in injury or property damage a copy of the OSHA form or equivalent detailing the accident shall be submitted by the Contractor/Vendor to the Company s safety representative within 24 hours. The reporting of serious injuries (OSHA recordable) shall be made immediately to the Company s safety representative. Fire Regulations The Contractor/Vendor shall observe the Company s existing fire prevention and protection regulations at the location where the work is being performed. Storage of Flammable Liquids Flammable liquids shall not be stored inside buildings unless approved by the Company s safety representative. Portable Fire Extinguishers The Contractor/Vendor shall provide portable fire extinguishers for their own equipment and work activities suitable for the potential hazard unless specified otherwise in writing. Solvents and Other Agents that Emit Fumes/Odors The Contractor/Vendor will discontinue using solvents or other agents, including equipment fumes, if requested by a member of the Company s management. Personal Protective Equipment Protective devices and personal protective equipment shall be furnished by the Contractor/ Vendor. Contractor/Vendor personnel shall conform to all plant safety regulations. 7

4 CONTRACTOR/VENDOR RESPONSIBILITIES (cont) o Head Protection The wearing of approved nonconductive safety hats as required. o Eye and Face Protection Eye protection must be worn at all times. Face Protection must be worn when required. o Fall Protection Life lines and safety harnesses shall be used in all applications as required. o Respiratory Protection In emergencies, or when controls required by OSHA fail or are inadequate to prevent harmful exposure to employees, the appropriate respiratory protection devices shall be provided and used by all Contractor/Vendor personnel. o Hearing Protection Where it is not feasible to reduce the noise levels or duration of exposures to acceptable limits, ear protection shall be provided and used by the Contractor/Vendor. o Wearing Apparel Appropriate clothing shall be worn while working on the property to minimize hazards from work and to comply with all applicable rules and regulations. o Appropriate shirts shall be worn at all times. No tank tops, shorts or cutoffs may be worn. Substantial leather, flat-soled work shoes with enclosed toes and heels shall be worn. Long hair shall be tied in a manner which would prevent the hair from being caught in machinery or equipment. Electrical or Machine Repairs on Company s Equipment No repairs or adjustments of any type will be allowed by Contractors / Vendors on the Company s equipment, unless authorized by management. Motor Vehicle Requirements Safe vehicle speed must be maintained at all times. Speed limit on Company property is 5 M.P.H. unless posted otherwise. o Obey all warning signs. 8

5 CONTRACTOR/VENDOR RESPONSIBILITIES (cont) o All vehicles on the Company s property are subject to a safety inspection. Unsafe vehicles will be removed from property. Hazardous Substance Notification and Requirements Based on the age of the Bentley Mills, Inc. s buildings, all building components for E. Don Julian Road and 315 S. 7th St., City of Industry, CA may contain asbestos or other hazardous substances regulated by applicable law ( collectively Hazardous Substances ). A detailed list of materials that may contain asbestos is provided below. Before these materials can be disturbed, written notice must be provided to Bentley Mills, Inc. so that the required tests can be performed to determine if asbestos abatement is required. Bentley Mills, Inc. will determine, before work is begun, the presence, location, and quantity of any Hazardous Substances that would be impacted by the work specified in Vendor s contract. Bentley Mills, Inc. s Project Manager will provide a specific audit report for those work areas where disturbance of presumed Hazardous Substances may be found. The Vendor shall not disturb, damage, or otherwise handle any Hazardous Substances unless such activities are part of the contracted work and Vendor is specifically authorized in writing by Bentley Mills, Inc. to do so, and Vendor certifies that it is appropriately trained in Hazardous Substance abatement, management, disposal, and remediation in accordance with applicable law. The following materials shall be presumed to contain Hazardous Substances unless specific data shows otherwise: 9

6 Cement pipes Cement wallboard Flooring backing Construction Mastics Acoustical plaster Decorative plaster Textured paints/coatings Ceiling tiles & lay-in Spray-applied insulation Blow-in insulation Fireproofing materials Taping compounds Packing materials (wall/floor penetrations) High temperature gaskets Lab hoods/benches/gloves Fire blankets/curtains/doors Elevator Equipment panels Elevator brake shoes HVAC duet insulation Boiler insulation Breaching insulation Cooling towers Electrical cloth Heating & Electrical ducts Electrical panel partitions Ductwork flexible fabric connectors Electrical wiring insulation Chalkboards Roofing shingles & felt Base flashing Thermal paper products Caulking/putties Adhesives Wall board Joint compound panels Vinyl sheet flooring Asphalt floor tile Vinyl sheet flooring Vinyl floor tile Spackling compounds Vendor shall not sweep, dust, vacuum or mop dust or debris that is the product of disturbed presumed Hazardous Substance containing material. Vendor shall also not pick up or throw away any waste generated from the disturbance of presumed asbestos containing materials. Vendor shall immediately notify the Project Manager upon discovery of any disturbed (crushed, ripped, broken or in any way damaged) presumed Hazardous Substance containing materials. If it is part of the Vendor s work, stripping of floor finishes shall be done using low abrasion pads at speeds lower than 300 rpm and wet methods shall be used. Vendor shall take care not to over strip floors and shall stop stripping immediately upon removal of the old surface coat. Sanding of flooring material is strictly prohibited unless it is part of your contracted work and Vendor is specifically trained to do so. 10

7 CONTRACTOR/VENDOR RESPONSIBILITIES (cont) Asbestos Notification and Requirements (cont) Asbestos abatement Contractors will coordinate with both the Project Manager and Bentley Mills, Inc. s Environmental and Safety Department for specific requirements for asbestos abatement work and handling of asbestos waste including disposal off site. Bentley Mills, Inc. is the generator of this waste and the Environmental Manager must approve all shipping and disposal arrangements. Lead Paint Notification and Requirements No lead-based paint is to be used on any project for Bentley Mills, Inc.. Contractor shall provide documentation to the Project Manager to document that all paint used does not contain lead. Contractors should assume that any existing painted surface they come in contact with is coated with lead-based paint. Therefore, Contractors should not perform any intrusive, dust-generating work on painted surfaces (e.g., drilling, cutting, brazing, scraping, and demolition), unless the surface has been confirmed to be non-lead or unless such work is part of your contracted work, you are authorized by Bentley Mills, Inc. for that scope, and you are appropriately trained in lead abatement and waste handling laws and regulations. Any painted surfaces that have loose, flaking, and chipping or otherwise non-intact paint should not be impacted by the Contractor and should be reported to the Project Manager immediately. Lead footings under tufting machines are to be removed intact without any intrusive activities that would generate dust. Lead Paint Abatement Contractors must coordinate with the Project Manager and Bentley Mills, Inc. Environmental and Safety Department for specific requirements for lead abatement work and handling of lead containing paint waste including disposal off site. Bentley Mills, Inc. is the generator of this waste and the Environmental Manager must approve all shipping and disposal arrangements. 11

8 Waste, Chemical and Environmental Management Requirements Materials shall be piled so that safe clearances are maintained and toppling is prevented. All loose overhead material must be removed. Oil and water spillage must be promptly and properly removed and disposed of. Garbage must be disposed of daily. Nails protruding from lumber shall be removed or bent over immediately. Clean-Up to the Company s satisfaction is required. All applicable Environmental, Safety and Health Standards shall be followed. Containers shall be located in the work areas by the Contractors/Vendors to collect their own trash. Collection shall be at Contractors/Vendors expense unless otherwise specified. All construction, demolition and renovation waste must be diverted from landfill at the minimum of 50% of total weight removed from the facility. Vendor/Contractor must provide weight tickets from certified waste haulers. During site construction where soil is unearthed Contractors/Vendors shall follow all of Bentley Mills, Inc. s erosion and storm water pollution prevention measures as outlined in our Erosion and Sediment Control Policy. Contractors performing work upon the roof of the facility must remove from the roof their combustible debris and materials. All materials must be stacked, stored, or tied down to prevent the materials from being blown off the roof. No combustible materials may be stored or kept on the roof. Drums or any types of containers which may have contained toxic or flammable materials shall be disposed of daily. Contractor/Vendor shall promptly furnish BMI, upon request, a complete list specifying all ingredients in the composition of goods, and materials incorporated into services, and the amounts and percentages thereof. Thereafter, Contractor/Vendor shall promptly advise BMI in writing of all proposed or anticipated changes in such composition and shall provide at least thirty (30) days prior written notice of actual changes in such composition, in each case for BMI s approval. Contractor/Vendor will ensure that the Purchase Order and any related invoices, bills of lading and other documents related to the purchase of chemicals reflect the name of the chemicals or products in any related material safety data sheet (MSDS). 12

9 Company Rules, Contractor Safety and Environmental Guidelines This safety guideline is not all inclusive, but is specific information that is required for all contractors who perform assignments at Bentley Mills, Inc. to be knowledgeable of. The purpose of these guidelines is to identify such practices and procedures which we think will enhance the safety of you and your associates and also our associates while you are in our facility as well as environmental concerns that will be communicated to you by the project manager. 1) No smoking is allowed on our property. 2) Appropriate clothing should be worn while working on the premises. No tank tops, shorts or cut-offs may be worn. Flat-soled shoes with enclosed toes and heels should be worn for your safety. 3) Proper PPE must be worn while performing a job at Bentley Mills, Inc.. 4) Cameras are not permitted in the manufacturing area. 5) You are required to sign in at one of the Guard Stations to obtain a temporary Visitor Badge, you must sign out and return the badge before leaving the property. Visitor Badge must be worn and visible at all time while on the facility. 6) In the event the facility needs to be evacuated, you must proceed to evacuate following the group from the area you are working at, and then notify your location to a Management team member. 7) Please be aware that Bentley Mills, Inc. has a very stringent recycling program. Make sure that any material being disposed is placed in the proper container. 8) All chemicals must be approved by Bentley Mills, Inc. BEFORE being brought on site including but not limited to architectural coatings (paints, sealants or other coatings) and adhesives. 9) Submittal of current MSDS to Project Manager is required for starting review and approval process. 10) Total amount of materials used must be reported to Bentley Mills, Inc. Environmental Manager. 11) Management and disposal of any regulated waste generated by work performed by you must be discussed and approved by the Project Manager, and the Environmental and Safety Department. 12) Your company is responsible to clean up any material that is spilled on our property. Should there be any material spilled, the Bentley Mills, Inc. representative must be alerted immediately. 13) All applicable provisions of federal, state, and local environmental, safety and health laws local safety and health laws and building codes shall be followed. 14) Housekeeping is very important for our environmental and safety success. Please keep your work area as clean as possible while working and make sure it is clean (and covered if outside) before leaving. 15) Bentley Mills, Inc., Inc strives to be environmentally responsible in all work areas. Any aspect of work with the potential for impacting the environment (such as chemicals used, waste generation, etc.) must be discussed and approved by the Project Manager before work can be started. Any spills or other types of incidents must be reported immediately to the project manager. 13

10 Quality Policy Bentley Mills, Inc. is committed to meet or exceed our customers requirements and to provide continuous improvement to our processes. At Bentley Mills, Inc., Quality is paramount in all we do. Environmental Policy Bentley Mills, Inc. is committed to environmental excellence and to become a restorative company. Bentley Mills, Inc. will continually: Improve our Environmental Management System Promote waste elimination and pollution prevention Meet or exceed applicable environmental laws and regulations Establish environmental goals and objectives to support our sustainability mission Communicate our environmental policy to our internal & external communities Energy Policy Bentley Mills, Inc. is committed to the comprehensive management of energy within our manufacturing facility. We will strive to continuously improve our performance and work towards energy-efficient best practices where cost-effective. We believe that managing energy gives us a competitive advantage, improves our bottom line, and supports our sustainability mission. To achieve these goals, it is Bentley Mills, Inc. s policy to: Continuously improve our energy efficiency performance Increase our use of renewable energy when feasible Integrate energy management into our core business strategy and operational goals including quality, customer satisfaction, cost, safety, and environmental goals Create a company culture of responsible energy management and accountability, developing awareness by educating, involving, and motivating our associates Ensure that purchases meet energy efficiency requirements Review energy efficiency performance with company management quarterly and update energy goals and objectives as needed Review the Energy Policy with company management annually, revising objectives and targets and providing the information and resources necessary to ensure continuous improvement Meet or exceed all applicable legal and other requirements 14