List of All Substances for which Toxic Substance Reduction Plans Have Been Prepared at the Facility

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1 TOXIC SUBSTANCE REDUCTION PLAN SUMMARY This Toxic Substance Reduction Plan Summary has been prepared in accordance with Section 8(2) of the Toxics Reduction Act and satisfies the minimum Plan Summary content requirements stipulated in Section 24 of Ontario Regulation 455/09. This plan summary accurately reflects the content of the plans for Zinc. Basic Facility Information Mandatory Basic Facility Information Item Substance Name and Chemical Abstracts Service (CAS) Registry Number, if any NPRI and O.Reg.127/01 Identification Numbers The legal and trade names of the owner and the operator of the facility, the street address of the facility and the mailing address of the facility, if different The number of full time employee equivalents at the facility NAICS codes and the six-digit NAICS Canada code Public contact The spatial coordinates of the facility expressed in Universal Transverse Mercator (UTM) within a North American Datum 83 (NAD83) datum Parent Company Information Details This Plan Summary applies to the following prescribed toxic substances: Zinc [Per O.Reg. 455/09; no single CAS numbers apply to these substances ] NPRI ID: O.Reg. 127/01 ID: N/A 610 Industrial Drive Milton, ON L9T 5C Manufacturing 3353 Electrical Equipment Manufacturing Switchgear and Switchboard, Relay and Industrial Control Apparatus Manufacturing Andreea Arangio, EHS Manager 610 Industrial Drive Milton, ON L9T 5C UTM Zone 17T E, N Eaton Corporation 1111 Superior Avenue, Cleveland, Ohio, USA, List of All Substances for which Toxic Substance Reduction Plans Have Been Prepared at the Facility The Facility has prepared an additional Toxic Substance Reduction Plan for the following prescribed Toxic Substance as first time reporting was completed in 2013: Zinc* This is in addition the previously prepared plans for: Copper* Chromium* 1 of 3

2 Manganese* Nickel* *Per O.Reg. 455/09, no single CAS numbers apply to these substances Statement of Intent As required by s.4(1) of the TRA, a Plan must include either a statement of the Facility s intent to reduce the use and/or creation of the Toxic Substance at the Facility, or the reasons for not including this statement. (Eaton) strives to become the most admired company in its markets as measured by customers, shareholders, suppliers and employees. It is understood that environmental, health and safety (EHS) is an integral part of this process by adding value and enhancing Eaton s competitive advantage in the marketplace. The objectives of the Toxics Reduction Act (TRA) align well with Eaton s commitment to minimize the impact of operations and products on the environment. Eaton s EHS efforts focus on the prevention of injuries and illnesses, protection of the environment, conservation of resources and pollution prevention. More information pertaining to Eaton s commitments to EHS are available on Eaton s corporate website: All of the toxic substances for which the Facility is required to report on are contained in metal raw materialsthat form the structure and components of final products manufactured at the Facility. The raw materials containing toxic substances are commodity materials that are widely used and accepted for many different manufacturing and construction applications. The Facility does not create any of the toxic substances or use any of the toxic substances as intermediate process materials. There is a high volume of raw metal materials containing toxic substances that passes through the facility and is manufactured into finished products each year. The vast majority of toxic substances are contained in finished products and wholly recycled scrap, with only a very small amount released to air; however, the Facility is in compliance with all current Ministry of Environment regulations regarding emissions and waste management. The Facility also operates in compliance with the variety of standards and requirements that govern the electrical equipment manufacturing industry, including standards issued by the Canadian Standards Association, UL, and the Association of the Electrical Sector. Eaton has minimized waste generation and maximized its recycling of valuable raw material scrap containing toxic substances as a result of these compliance initiatives and economic drivers. Eaton, as part of its continuous improvement process, will continue to seek to minimize scrap generation. However, as outlined in the TRA process, the only way to reduce use of the Toxic Substance is to reduce production and, for this reason, Eaton is unable to make a statement of intent under the regulation to reduce the use of the Toxic Substances. Objectives of the Toxic Substance Reduction Plan The Objectives of the Plans are as follows: To outline the Facility s position that no toxic substance reduction options can be identified for the Toxic Substances; and, Document how the Facility has fulfilled the applicable requirements under the TRA and O. Reg. 455/09 with respect to each Toxic Substance covered. Description of Why the Toxic Substance Is Used or Created Sheet steel (including galvanized steel) and aluminum are used at the facility to form the structural and protective housings of electrical switchboards. Electrical switchboard internal components are 2 of 3

3 manufactured from tin-plated aluminum and copper bars and wire. These feedstock materials each contain certain weight percentages of chromium, copper, manganese and/or nickel, which are the prescribed toxic substances for which reporting and planning are required. No toxic substances are created or destroyed at the Facility, or used as intermediate process materials. Steel and aluminum alloys are the materials of choice for electrical switchgear enclosures, and tin-plated and un-plated aluminum and copper bars and wire are materials of choice for switchgear components due to their physical properties. Select elements listed as toxic materials under TRA Regulations contribute to the physical properties of these materials and are foundational components of the materials. Steel and aluminum alloys are specified for use in the electrical industry, particularly in the construction of enclosures for electrical equipment, as stipulated in a number of national and regional standards issued by the Canadian Standards Association (CSA), UL, and the Electrical Safety Authority. Similarly, the composition and specifications for materials forming conductor buses and other switchgear components are highly regulated by the same bodies. All metal that is not included in final products manufactured at the Facility (i.e. scrap) is sold to a third party recycler for repurposing at an off-site location. There are no disposals of metal from the Facility s operations, since there is value in scrap material. Rationale for Not Implementing Toxic Substance Reduction Options As required by s.18(4) of O. Reg. 455/09 (as amended by s.9(3) of O. Reg. 214/11), a Plan must contain an explanation of why no toxic substance reduction options will be implemented. Facility personnel have considered each of the seven categories for toxic substance reduction options, and, in light of the information provided in the Statement of Intent section of this Plan, the Facility feels that no toxic substance reduction options can be identified in any of the seven toxic substance reduction categories. This result is due mainly to the proactive approach employed by Facility personnel to material use efficiency, scrap reduction, and process optimization which has resulted in any potential reductions of toxic substance use and subsequent savings having been realized prior to this exercise. Therefore, the rationale for not implementing toxic substance reduction options is that no toxic substance reduction options could be identified. Facility personnel will continue to evaluate and assess future potential reduction options as they become available through the advancement of materials technology, manufacturing process and management. Planner License Number As required by s.18(2) of O. Reg. 455/09 (as amended by s. 9(2) of O. Reg. 214/11), the Licensed Toxic Substance Reduction Planner responsible for providing Planner Recommendations on and certification of this Plan is as follows: Jonathan Michael Fabro Golder Associates Ltd. Toxic Substance Reduction Planner License Number TSRP0189 Copies of the Certification Certification statements are provided in the following page. 3 of 3

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5 September 10, 2014 Project No Andreea Arangio LICENSED TOXIC SUBSTANCE REDUCTION PLANNER CERTIFICATION STATEMENT FOR A PHASE I TOXIC SUBSTANCE REDUCTION PLAN FOR EATON INDUSTRIES (CANADA) COMPANY 610 INDUSTRIAL DRIVE, MILTON, ONTARIO Dear Ms. Arangio: Golder Associates Ltd. (Golder) was retained by the (Eaton) facility located at 610 Industrial Drive in Milton, Ontario (the Facility) to provide various services pertaining to a Phase I Toxic Substance Reduction Plan preparation under the Toxic Reduction Act (TRA), including Toxic Substance Reduction Planner (Planner) certification of a Phase I Toxic Substance Reduction Plan (the Plan). The following Planner Certification Statement which is made under s.19.1(4) of Ontario Regulation (O.Reg.) 455/09 (as amended by s.11 of O.Reg.214/11) satisfies the Planner Certification requirements for the Plan that is assembled as of the date of this Certification Statement. Furthermore, the following Certification Statement is limited to the respective version of the Plan which is dated as indicated in the Certification Statement: As of September 10, 2014 I, Jonathan Michael Fabro certify that I am familiar with the processes at the facility located at 610 Industrial Drive in Milton, Ontario that use or create the toxic substance referred to below, that I agree with the estimates referred to in subparagraphs 7 iii, iv and v of subsection 4 (1) of the Toxics Reduction Act, 2009 that are set out in the toxic substance reduction plan referred to below for the toxic substance and that the plan comply with that Act and Ontario Regulation 455/09 (General) made under that Act. Zinc Version 1.0 (September 10, 2014) J. Michael Fabro Date Toxic Substance Reduction Planner License No. TSRP0189 September 10, 2014 JMF/SC/sll/ng Golder Associates Ltd. 309 Exeter Road, Unit #1, London, Ontario, Canada N6L 1C1 Tel: +1 (519) Fax: +1 (519) Golder Associates: Operations in Africa, Asia, Australasia, Europe, North America and South America Golder, Golder Associates and the GA globe design are trademarks of Golder Associates Corporation.