REFERENCE SYSTEM PRODUCT HSE: Clauses HSE Technological purchase Reference : 83570258-HSE-ITA-EN Revision : 001 Date of revision : 05 Nov 2012 Group revision Page 1 / 13 APPLICABILITY COUNTRY - SITE COMPANY BUSINESS ACTIVITY CONTEXT PROCESS CATEGORY PRODUCT TYPE ITALY THALES ITALIA SPA ALL ALL ALL ALL Abstract This document lists the HSE Product s standard requirement that a supplier must respect and apply in the context of its industrial production and subsequent supply against TIT. These requirements are the standard of those currently in place for technology purchases. They apply to equipment meant for the European market or moving thru Europe. VALIDATION BY THE CERTIFYING BODY DATE 05 Nov 2012 WARNING: If this document is printed, check its validity by consulting the latest version in force on Chorus 2.
Date of revision : 05 Nov 2012 Group revision Page 2 / 13 INDEX INDEX...2 1 Scope...3 2 Applicability...3 3 Acronyms and Terminology...3 4 General Requirements...3 4.1 REGULATORY COMPLIANCE...4 4.2 PACKAGING...4 4.3 TRANSPORT...4 5 Specific Requirements...4 5.1 ASBESTOS...4 5.2 IONIZING RADIATION...5 5.3 ODS: OZONE DEPLETING SUBSTANCES...5 5.4 REACH...5 5.4.1 Annex XVII...6 5.4.2 Article 33...6 5.4.3 Article 7...7 5.5 ROHS...7 5.6 RAEE...7 5.7 NANOPARTICLES...8 5.8 ENERGY...8 5.9 DECOMMISSIONING...8 5.10 HSE RISK ANALYSIS...9 5.11 CONSUMABLES...9 6 Special Administrative Terms and Conditions...9 6.1 CERTIFICATE OF CONFORMITY...9 6.2 COMPLIANCE WITH ENVIROMENTAL REQUIREMENTS...9 ANNEX A: Supplier REACH Material Declaration Form...11 ANNEX B: Product HSE Purchase Term and Conditions...12
Date of revision : 05 Nov 2012 Group revision Page 3 / 13 1 Scope The aim of this document is to describe and list all the requirements, prescriptions, rules and regulations, in HSE of Product, ensure that suppliers are required to comply with in relation to the production and supplies required by TIT. 2 Applicability The document is applicable to all cases where it is required to a service provider a technology buying. This document should also be attached as an appendix to the SOW (Statement of Work). It will be reviewed with the vendor before signing a contract and confirmed by both parties. The set of requirements must be provided to suppliers in an official manner, keeping the evidence of the transmission. 3 Acronyms and Terminology HSE: Health Safety and Enviromental TIT: THALES ITALIA SPA Holder = Supplier CE: European Community REACH: Registration, Evaluation, Authorization of CHemicals RoHS: Restrictions Of the uses of certain Hazardous Substances MDF: Material Declaration Form CL: Candidate List UE: European Union WEEE: Waste Electrical and Electronic Equipment 4 General Requirements The holder agrees to comply with all the obligations in this section and to ensure that its own subcontractors and suppliers comply with them too.
Date of revision : 05 Nov 2012 Group revision Page 4 / 13 4.1 REGULATORY COMPLIANCE Both the holder and the supplies should comply with the regulations applicable at local, national, European and international levels and with the mandatory standards in force regarding hygiene, safety, health and the environment, including but not limited to: a) hazardous substances and preparations including the transportation of hazardous materials (ADR/IATA), b) packaging, c) Waste (packaging, boxes, wood, plastics, electrical and electronic equipment, etc.). The holder agrees to comply with the applicable regulations on its duty to take back equipment (electrical and electronic equipment, radioactive sources, etc.), d) electrical protection, fire protection, explosion protection, vibration protection, noise protection, etc., e) electromagnetic radiation, ionizing radiation, optical radiation, f) energy consumption, g) rules for personal safety. The holder agrees to inform TIT (by means of a supporting note) of any non-compliance with the regulations; it will compensate TIT for any consequence resulting from its non-compliance with the duty described in this article. Specific recommendations/instructions related to this possible noncompliance should be given to TIT so that the Product is safely used and scrapped throughout its life cycle, including end of service life. If the holder is located outside the EU, it is nevertheless responsible for ensuring that its supplies comply with these rules and instructions, and for producing the required accompanying documents, UNLESS OTHERWISE specified by TIT. 4.2 PACKAGING The holder will indicate the measures taken to optimize the packaging of the delivered supplies: recycled materials, recyclable packaging, limit on the number of materials used, way the packaging is closed, easy to transport and to grip, etc. The use of reusable packaging will be encouraged. 4.3 TRANSPORT The holder will indicate the measures taken to optimize and/or reduce the CO2 emissions caused by the transportation of the supplies (optimized procurement logistics, transport policy, optimization of the stacking pattern, order grouping, etc.). 5 Specific Requirements 5.1 ASBESTOS
Date of revision : 05 Nov 2012 Group revision Page 5 / 13 The delivered supplies should contain NO TRACES of asbestos. 5.2 IONIZING RADIATION The delivered supplies should contain NO TRACES of radioactive sources or electrical appliances emitting ionizing radiation. If it is absolutely necessary to use such sources or appliances, the holder will request a waiver from TIT upon presentation of supporting documents. If TIT accepts this waiver, the holder will then specify its authorization number for the supply of radioactive sources or equipment containing asbestos, issued by the supervisory authorities in its country in compliance with the applicable regulations. Once TIT has agreed to the presence of radioactive sources or electrical appliances emitting ionizing radiation, the supplier will produce the following for each delivery: o the technical data sheet for the product containing a radioactive element, stating whether the source is sealed or not, the product reference, its serial number, the radioelement and the activity, o the safety record, o the certificate of conformity, together with the commitments to guarantee that the source is sealed, guarantee that the source is not contaminated, o the commitment to take back the radioactive element or the equipment containing it when it is out-of-date, faulty or no longer used without an expiry date. o regarding electric generators, the holder will state: the dose rate in µs at a distance of 0.1 m from its accessible surface under normal operating conditions, Maximum strain and intensity. The national and international design and production standards taken into account, and compliance with these standards. 5.3 ODS: Ozone Depleting Substances As far as ozone is concerned, the holder must apply European regulation EC no. 1005/2009 of 16th September 2009 on substances that deplete the ozone layer and its amending acts. 5.4 REACH The holder agrees to: o comply with the REACH regulation no. 1907/2006 and with subsequent developments and other statutory instruments related to it, concerning but not limited to the following:
Date of revision : 05 Nov 2012 Group revision Page 6 / 13 o substance registration, authorization requests and notifications of hazardous substances to the ECHA (European Chemicals Agency), set up an obsolescence management system in order to guarantee continued procurement. 5.4.1 Annex XVII The holder agrees to comply with the restrictions set out in annex XVII. 5.4.2 Article 33 The holder must take special care to forward the necessary elements to TIT in compliance with the requirements of the REACH regulation: o Duty to provide information about the substances in articles when the Product is an article as per REACH: the holder will forward the Candidate List of substances, as shown on the ECHA website on the date on which articles are shipped to TIT, contained in the article above 0.1 weight/weight percent, specifying the actual weight/weight percent (substance/article) of these substances and the information needed to use them safely and the article s weight. These data will be included in an MDF (Material Data Form) identical to the one attached when the article is delivered for the first time. The Certificate of Conformity will specify the presence of the MDF. If this is not the case, supply of the certificate of conformity will suffice. o For subsequent deliveries: - with no information in the certificate of conformity, the MDF which has already been provided is considered to remain valid, or the Product is considered as containing no CL substance > 0.1%, - supply of an MDF, with information in the certificate of conformity, for any for at least one Candidate List substance following: a change to the Product, a change to the Candidate List, a new piece of information, held by the holder, relating to a substance which did not previously exceed the threshold. When the Product is made up of several articles, the holder will provide the same information as above for each article. Duty to provide information about the substances or preparations when the Product is a Substance or a Preparation as per REACH: the holder will forward the safety data sheet compliant with the REACH regulation each time this sheet changes, or will provide the information required by the regulation if it is not bound to provide a safety data sheet in compliance with the REACH regulation each time the information changes.
Date of revision : 05 Nov 2012 Group revision Page 7 / 13 In the particular case of development operations outsourced by TIT, the holder will do its utmost to not use supplies which may become obsolete in its development (article or preparation using substances in annex XIV and in compliance with annex XVII). The holder agrees to inform TIT of the potential risks of obsolescence, so that the measures needed to replace such supplies can be arranged together with TIT. The holder will provide an MDF whenever the threshold of 0.1 weight/weight percent is exceeded for at least one Candidate List substance during the CDR (Critical Design Review). 5.4.3 Article 7 Any supplier located outside the EU must provide its client TIT with all the necessary information and ensure that the delivered products are compliant, so that they can be supplied to the EU and/or moved thru the EU, and so that TIT units located within the EU can fulfill their statutory requirements. With this aim in mind, this clause stipulates that the REACH requirements which would have been officially fulfilled by a supplier located within the EU must be contractually fulfilled. This clause shall apply by default, unless otherwise specified in the special terms and conditions of the contract. The compliance checking of the imported articles and the information to be provided under the terms of this clause are the same as that required for: - registration (REACH art. 7.1) - notification (REACH art. 7.2). Unless otherwise agreed, the criterion of concentration in the article (> 0.1% weight compared to the weight of the article) is the only one to apply when deciding which information to provide TIT with. For example, the following articles may be concerned (including but not limited to): - cleaning or maintenance kits (including solvents, materials, etc.), - tanks of liquids for the utilities, - hard copy documentation, - packaging items (always considered separately), - some components, particularly those which can be delivered as consumables (light bulbs, batteries and storage cells, ink cartridges and special paper for printers, etc.). 5.5 RoHS The holder agrees to comply with the RoHS directive (Directive 2002/95/EC) when it is applicable and with its amending acts. Otherwise, the holder should justify the reasons for using each concerned RoHS substance. In all cases, the holder should justify that it complies with technical requirements, and particularly with reliability and security requirements. 5.6 RAEE
Date of revision : 05 Nov 2012 Group revision Page 8 / 13 The holder agrees to fulfil its obligations with regard to the European directive 2002/96/CE, WEEE, and its subsequent amendments and other statutory instruments related to it (especially national transcriptions, for example, Code de l Environnement in France), with the following specifications: o The producer* is responsible for disposing of the equipment at the end of service life: as this duty may require clarification of the producer, it is considered to be the holder by default (unless another contractual agreement is expressly specified) when the supplies are an assembly (and not a component) marked with the holder s name, o Marking of products (identification of the producer*, date of manufacture and crossed-out bin): applicable if necessary in consistency with the first point above, o Quantified recycling and recovery objectives: the holder will consider that the delivered products must help in reaching the values required by the reprocessing lines and that their recyclability potential should therefore reach the specified values as a minimum, o Information of the reprocessing lines (location and removal of some substances and subassemblies): this requirement will lead to the supply of decommissioning procedure documentation (see below), o Information of the authorities (amounts of equipment supplied and treated): if necessary, the holder will take full responsibility for this requirement and will make the required declarations directly to the authorities in question. * As per the 2002/96/CE directive 5.7 NANOPARTICLES To the best of its knowledge, the holder will indicate the presence of nanoparticles in the delivered supplies and will specify their features and location. 5.8 ENERGY The holder will take steps to reduce the energy consumption of the delivered supplies, and will specify, upon request, their consumption when used in normal mode, in standby mode and in degraded mode. 5.9 DECOMMISSIONING a) The holder will make sure that its supplies are designed to make decommissioning at the end of service life easy (for example: modular design, reduced number of links, marking of important plastic parts, etc.). b) The holder will also provide any element needed for the correct decommissioning of the supplies with a view to optimum recycling at the end of service life. On this account, it will indicate the location of the substances, preparations and components which require specific treatment or which may be recovered. The holder will specify any information needed to guarantee personal safety during decommissioning operations (for example: residual voltage, hydraulic aspects under pressure, weight, ODS, batteries, lamps). The holder (i) will provide the decommissioning procedure for its supplies.
Date of revision : 05 Nov 2012 Group revision Page 9 / 13 Unless otherwise agreed in the contract, the holder (ii) agrees to take back its supplies at the end of service life with a view to decommissioning and recovering them. 5.10 HSE RISK ANALYSIS The holder agrees to: a) identify the risks and impacts on hygiene, safety and the environment for the supplies (energy, natural resources, greenhouse gas, waste, hazardous substances, etc.) during packaging, transportation, handling, storage, use including maintenance and end of service life, b) take all the measures needed to reduce these health and environmental risks and impacts especially during packaging, transportation, handling, storage, use, maintenance and end of service life, c) inform TIT of specific conditions of labeling, storage, handling, packaging, transportation, use and end of service life of the supplies, d) draw up an HSE manual listing these risks and impacts, and the measures to be implemented. 5.11 CONSUMABLES The list of consumables will be provided, including estimated consumption, so that the supplies can be used in compliance with the baseline scenario. 6 Special Administrative Terms and Conditions 6.1 Certificate of Conformity The Certificate of Conformity incurs the liability of the holder regarding compliance with the Hygiene, Safety and Environmental requirements of its supplies. A Certificate of Compliance must be attached to the supplies. 6.2 Compliance with enviromental requirements The holder declares and guarantees that the information forwarded to the purchaser is complete and accurate, and agrees to notify TIT of any change in the applicable regulations or any change having an effect on the supply's above-defined data, in writing as soon as it takes notice of such changes and the first time the supply is delivered following this notice. TIT reserves the right to either partially or fully terminate the Order or make the purchase conditional upon supply by the holder at its expense, if the above conditions are not fulfilled. In the event of a breach in the application of the above requirements by the holder, TIT may terminate the Order and/or the Contract for default in accordance with the provisions of Article 2 of the General Conditions of Purchase.
Date of revision : 05 Nov 2012 Group revision Page 10 / 13 The holder will protect and hold harmless the purchaser and its clients from any responsibility and any harmful consequences resulting from the failure on the part of the holder to abide by any of the obligations described in the above requirements. In the event of operations on a TIT site, the contractor will comply with the requirements applicable to the site of operations.
Date of revision : 05 Nov 2012 Group revision Page 11 / 13 ANNEX A: Supplier REACH Material Declaration Form
Date of revision : 05 Nov 2012 Group revision Page 12 / 13 ANNEX B: Product HSE Purchase Term and Conditions 16.1 - The Holder and the Supplies should comply with the regulations applicable at local, national, European and international levels and with the mandatory standards in force regarding hygiene, safety, health and the environment, including but not limited to: hazardous substances and preparations (REACH, RoHS, Asbestos...) including the transportation of hazardous materials (ADR/IATA), packaging, waste (packaging, boxes, wood, plastics, electrical and electronic equipment (WEEE), etc.), the holder agrees to comply with the applicable regulations on its duty to take back equipment (electrical and electronic equipment, radioactive sources, etc.), electrical protection, fire protection, explosion protection, vibration protection, noise protection, etc., electromagnetic, ionizing and optical radiation, energy consumption, rules for personal safety and any other nuisance. It will be the same for carrying out the activities of the Supplier. 16.2 - The holder agrees to inform THALES (by means of a supporting note) of any noncompliance with the regulations; it will compensate THALES for any consequence resulting from its non-compliance with the duty described in this article. Specific recommendations/instructions related to this possible non-compliance should be given to THALES so that the Product is safely used and scrapped throughout its life cycle, including end of service life. 16. 3 - If the holder is located outside the EU, it is nevertheless responsible for ensuring that its supplies comply with these rules and instructions, and for producing the required accompanying documents, UNLESS OTHERWISE specified by THALES. 16.4 - The Holder undertakes to impose on its own suppliers and subcontractors the same obligations as those described above. 16.5 - The holder will indicate the measures taken to optimize and/or reduce the CO2 emissions caused by the transportation of the supplies (optimized procurement logistics, transport policy, optimization of the stacking pattern, order grouping, etc.).
Date of revision : 05 Nov 2012 Group revision Page 13 / 13 Manage HSE Impact Manage Acquisition PROCESS ASSOCIATION Analyse HSE risks and impacts Products and Services Signing the purchase contract LOG OF CHANGES REVISIONS DESCRIPTION DATE 001 First issue 05 Nov 2012 002 003 APPROVAL ACTORS NAME AND ROLE SIGNATURE DATE Written by D.Chilà/HSE Product Coordinator 05 Nov 2012 Verified by A.Magnatta/Quality 05 Nov 2012 M.Schena/ Facility & HSE Manager 05 Nov 2012 Approved by A.Sansarella Purchasing Director 05 Nov 2012 All remarks and change proposals relating to the content of this document should be sent via the Chorus portal, heading "SUPPORT"