Environmental, Health & Safety Policy

Version 20180620

Management Leadership and Employee Involvement

Management commits the necessary resources of staff, money, and time to ensure that all persons on the worksite are protected from environmental, injury and illness hazards. In addition, management visibly leads in the design, implementation, and continuous improvement of the site’s environmental, safety and health activities. Specifically, the highest-level management establishes and reviews annually the site’s Environmental Health and Safety Policy and ensures that all employees know, understand, and support that policy. All management levels, with input from hourly employees, develop an annual environmental health and safety goal with objectives and action plans to reach that goal. At the end of each year all management levels, with input from hourly employees, evaluate progress in accomplishing the action plans, achieving all objectives, and meeting the annual goal. This evaluation, which also includes an

evaluation of the overall environmental health and safety program, results in a written report that includes the next year’s goal, objectives, and action plans, including any remaining action needed to accomplish the current year’s goal.

Management ensures that all employees, including themselves, have clearly written environmental health and safety responsibilities included within their job description, with appropriate authority to carry out those responsibilities.

Management ensures that all visitors to the site, including contract and temporary labor, co-op students, interns, vendors, and salespeople, have knowledge of site hazards applicable to them and how to protect themselves against those hazards, including emergency alarms and procedures. Management also ensures that these visitors do not introduce to the site hazards that can be prevented or that are not properly controlled.

Management ensures that at least several avenues exist for employee involvement in environmental health and safety decision making and problem solving. These avenues may include serving on committees and ad hoc problem-solving groups, acting as safety observers, assisting in training other employees, analyzing hazards inherent in site jobs and how to protect against those hazards (writing hazard assessment), and planning activities to heighten safety and health awareness. Management encourages

employees’ involvement and devises appropriate recognition for outstanding employee participation.

Environmental

The company’s commitment to this policy is to maintain and continually improve it policies to prevent the pollution and outline worker safety.

The company will comply with all applicable legal requirements and the requirements as well as all requirements to which the organization subscribes related to environmental aspects and improvements to be procedures.

Any employee may submit suggestions for improvement to Management for consideration of inclusion into this policy.

Any changes to this policy shall be communicated via memo distributed through department heads.

This policy shall be available to any individual or organization outside the company when submitted in writing 24 hours in advance.

The company’s policy shall adhere to the R2 Practices for all hazardous e-Waste through final disposition.

Currently, all materials are recycled through only approved downstream recyclers listed in Appendix A of the organizations EHSMS.

Materials including:

• Cell Phones
• Batteries
• Plastics
• Other electronics

Batteries shall be sorted according to battery type and shipped to an R2 Certified Recycler approved in Appendix A of the EHSMS for downstream disposition.

Worksite Analysis

Management hires outside consultants as necessary but no more than every three years to conduct baseline surveys that identify all health and safety hazards at the site at the time of the survey. All hazards found during these surveys are eliminated whenever possible or controlled. All employees who may encounter the controlled hazards are trained in appropriate job procedures to follow to protect themselves from these hazards.

Management establishes change procedures to follow whenever the site experiences changes in equipment, material, or processes. To ensure employee protection, these change procedures include consideration of environmental health and safety in the selection of the change, equipment and process shut down procedures, startup procedures, and phase hazard analysis. Appropriate employees are trained to follow these procedures.

Management and employees work together to analyze environmental health and safety hazards inherent in each job site and to find means to eliminate those hazards whenever possible, and otherwise to protect persons against those hazards. These Hazard Assessments are revised as appropriate, for example, following a change in the job, the reappearance of a hazard, or an accident at this job.

All employees at this site are trained to recognize hazards and to report any hazard they find to the appropriate person so that the hazard can be corrected as soon as possible. In addition to taking immediate action to report a hazard orally and to provide interim protection, if necessary, including stopping the work causing the hazard, employees may submit a safety suggestion form. Safety work orders take priority over any other work order. Safety suggestions will be considered each month during the site inspection by the site inspection team. All employee reports of hazards must be eventually written, with the correction date recorded. These reports are posted in the lunchroom until the hazard is corrected and then are kept on file in the VP of Finance’s office for three years. During that time, they are available for employee review.

Site management, with input from an hourly employee chosen by lot, organizes the monthly site inspection team. Membership on these teams rotates each month with the goal that all site employees serve one month each year. Teams consist of four people, two managers or supervisors and two hourly employees. Each month, on the first Wednesday morning of the month, the team inspects the entire worksite, in writing describing all hazards found, including their location. The team assigns appropriate persons responsible for seeing that the hazard is corrected and documenting the date of the correction. These inspection reports are posted in the tech room and in the VP of Finance’s office. A hazard remains on the monthly report until it is corrected.

Hazard Prevention and Control

Management ensures that this priority is followed to protect persons at this site: (1) Hazards will be eliminated when economically feasible, such as replacing a more hazardous chemical with a less hazardous one; (2) Barriers will protect persons from the hazard, such as machine guards and personal protective equipment (PPE); (3) Exposure to hazards will be controlled through administrative procedures, such as more frequent breaks and job rotation.

Management ensures that the worksite and all machinery are cared for properly so that the environment remains safe and healthy. If maintenance needs exceed the capability of the worksite employees, contract employees are hired to do the work and are screened and supervised to ensure they work according to the site’s environmental health and safety procedures.

All employees, including all levels of management, are held accountable for obeying site environmental health and safety rules. The following four step disciplinary policy will be applied to everyone by the appropriate level of supervisor:

• oral warning;
• written reprimand;
• three days away from work;

Visitors, including contractors who violate environmental health and safety rules and procedures, will be escorted from the site. Should the disciplined person request a review of the disciplinary action, an ad hoc committee of six people, three managers and three hourly workers, chosen by their respective colleagues,

will review the situation and make a recommendation to the owner, who reserves the right for final decision. If his decision differs from the committee, he may, within confidentially strictures, make public his reasons.

The site works with appropriate outside agencies, such as the fire department, the police department, and the hospital to write emergency plans for all potential emergencies, including fire, explosion, accident, severe weather, loss of power and/or water, and violence from an outside source. Desk top drills are conducted annually so that all employees experience a drill on each type of emergency once a year. A total site evacuation drill focusing on one emergency type, with all work shut down, and coordinated with the appropriate agency, is conducted once a year.

Persons needing emergency care are transported by company van or community ambulance to the hospital, located five miles from the site. Usually that trip can be made in less than ten minutes.

Appropriate personal protective equipment (PPE) is provided for the different types of accidents possible at the site.

Through consultants, management has assessed all work at this site and determined that the following OSHA standards apply to the site’s work. Individual safety and health programs for each of these standards have been written and implemented. Employees affected by these standards have been trained to understand them and to follow the programs’ directions. These standards are:

Emergency Action Plan	Facility Security Policy
Elite PPE Matrix

Training

Management believes that employee involvement in the site’s environmental health and safety program can only be successful when everyone on the site receives sufficient training to understand what their environmental health and safety responsibilities and opportunities are and how to fulfill them. Therefore, training is a high priority to ensure a safe and healthy workplace. Finding time and knowledgeable personnel to do effective training is vital. Each year management pays special attention to the evaluation of the year’s training efforts to look for methods of improvement.

Currently, all new employees receive one hour of health and safety orientation. When they have learned this material, they begin their assigned job with a trained buddy. For the first six months on the job a new employee is considered a probationer and may not work beyond the line of vision of another employee. Supervisors are strictly charged to ensure that this training process is followed for all new employees and for any employee beginning a new job at the worksite.

Each employee is responsible for ensuring that he/she masters the year’s training topics. Completing the year’s training is a significant portion of each employee’s performance evaluation, including all levels of management. Training records are kept by the personnel manager and are available for employee review, upon request.

All employees are encouraged to suggest qualified trainers, including themselves. Management is responsible for ensuring that all training offered at the site is conducted by qualified persons.

• List of yearly training topics with name of trainer and his/her qualifications;
• Yearly training class schedule with attendance lists;
• Individual employee training records with evidence of subject

Any suggestions on new appropriate Environmental Health and Safety Procedures shall be made to Management in the form of an email to aj@elitecell.com. The email must contain “POLICY

SUGGESTION” in the subject line of the email. Employee safety is the responsibility of every individual in the company and all suggestions shall be reviewed and given the appropriate consideration for inclusion into the Environmental Management System.