3 - P2 InfoHouse by yaofenjin

VIEWS: 0 PAGES: 508

									    0
    0




3
                                                    January 29, 1993


    To: GE Business EHS Managers

    From our discussion at the CEP IEHS Managers meeting on January 13, enclosed
    please find a copy of €&&le    For                                     . Also, per
    your request, I have enclosed copies of the charts that I presented to you at that
    time.
    Thisguide is divided into three main sections: i) Understanding The Need for
              -
    Change understanding the importance of establishing a process approach to
    managing chemicals within the plant; ii) "HowTo" Package Overview- an ovewiew
    of how the package works and the format in which the material is presented; and iii)
                             -
    The "How To" P m g " the steps for implementing Chemical Management which
    includes the assessment checklist, solution menus and the various sections on
    implementing the required controls for an effective Chemical Management
    Program.
    In addition to the package, on the inside flap of the binder you will find a computer
    diskette. This diskette replicates all the information found in the package and is
    laid out in precisely the same order that the material is presented in the binder.
    The diskette requires a Macintosh system with MS-Word and MacDraw Pro
    software. Please feel free to make any required adjustments, or to customize
    particular documents, in order to facilitate the implementation of this program at
    your basiness.
    As you begin to implement a Chemical Management program at your business, I
    urge you to utilize those individuals who have previously been involved in
    Chemical Management reviews. A listing of these individuals is included in the
    Introduction section of the guide.
    On behalf of the many individuals who have been involved in getting this package
    to this point, I hope you find it useful in improving, modifying or establishing a more
    compliant Chemical Management process in your business.




    Corporate Audit Staff
3
                                                   ......




                               ~~t~si
D ' . t 3 ' ' : A s ~ g e . . ~Overview       '9K MacDraw Pro doc.:.          he;: May 25, 1993 4:38 PM




D 21 Tab A - Gline NPI/C...               '   15K Microsoft Word d... Tue, Jan 26, 1993         9:22 AM
0 22 EHS NPI Ch,ecklist                        9K Microsoft Word d...         Mon. Jan, 25, 1993 1:43 PM
0   23 Change Review Chea. ..                 5K Microsoft Word d...          Mon, Jan .25, 1993 9:13 AM




                                      . >*......
                                      v . :rx
                                                      .,..   ........
                                                                    .;.                                                              ..,   ,
                                                                          1                         .   :

                                                                                                            ... .
                                                                                                                    ..   ,   .. ..   . ,:;
I
                                                Guide to CM          - Vers.   2
                                                                                              -      -
                                                                    LaseModifkd
     ,
    - 35.2 Int Sup Cost Ben 2
     0                                10K MacDraw Pro doc ... Tue, Dec 15, 1992           11:13 PM
    10 35.3 Int sup cost Ben 3        10K MacDraw Pro doc   ...      Tue, Dec 15, 1992    11:17 PM
     0 35.4 Int Supplier Checklist    13K MacDraw Pro doc ... Mon, Jan 25, 1993 1244 PM
     0 36 Int Supplier Flow Chart     15K MacDraw Pro doc ... Tue, Jan 12. 1993           10:08 AM
     0 38 Tab F - 1 For 1              9K MacDraw Pro doc ... Tue. May 25, 1993 4:48 PM
       0 38.5 One-For-One              4K Microsoft Word d...        Tue, May 25, 1993 4:50 PM
       0 38.8One For One Map          13K MacDraw Pro doc   ...      Tue, May 25, 1993 5:OO PM
       0 39 Tab 0 Chemical Own...      8K MacDraw Pro doc ... Wed, Jan 27, 1993 3:35 PM
       0 40 Creating Ownership         4K Microsoft Word d...        Wed, Jan 27, 1993 3 3 7 PM
       0 41 EHS/AE R&R                16K MacDraw Pro doc ... Wed, Dec 16, 1992 2 4 8 PM
       0 43 Training                   7K Microsoft Word d...        Wed, Jan 27, 1993 1 2 1 6 AM
       0 50 Terms Glossary            10K Microsoft Word d...        Wed, Jan 27, 1993 4:13 PM
       0 51 Additional Best Prac...    4K Microsoft Word d...        Fri, Aug 27, 1993    1:40 PM
      0 Plant sweep                    --   folder                   Fri, Aug 20,. 1993   4:06 PM




                                                                2
Guide For Improving Chemical Management                                                        Table Of Contents
1.lntroduction                                                  8. Iab A -New Pro
          GE’s Goals - For Environmental Health 8 Safety                         -
                                                                    NPI I Technical a                          _ ,
          Goals & Objectives - Of Chemical Management               EHSChecMlsb ( E x a h )
                                                                     9




     -    Package Overvle~- What This Padcage Is...
          Key C6ntacts - To Use As A Referem-                   9.            -            Procurement Policy
                                                                         Chemical Procurement Policy (Example)
                                                                         General Instructions To Contractors (Example)
                                                                         Receiving Procedure (Example)
                             -70
          pr&ess o~enrkm Chemical Management                             Material Approval Form (Example)
     --   Road Map - EstablishingA Process Ap oach
          Common Issues - From Not Having A eknpliant Process                     -                           &
                                                                10. Iat,C PhvsicaI lnventorv & ADDroved Chem. I




     -
          The Costs - Of Being Out Of Compliance                     Conducting A Physical Inventory
                                                                     Creating An Approved Chemical List
      -
                  1
                  .
3.                             !~
              To P a c b ~Overview                                   Physical Inventory Form (Example)
          Overview - How To Use The Package                          Chemical Definition And YSDS Guidelines
      -   How To Use - Assessment Cheddist
          How To Use - Solution Menu Section                    11. Jab D Che     -
                                                                     ImMementatmmple)
                                                                                             I’ Process
4.                                                                   Process Map (Example)
          Assessment Checklist - Overview                            Handler‘s Duties (Example)
     -    Assessment Checklist - To Be Filled Out
          Prioritizatron Guidelines                                               -
                                                                12. Jab E lntearated S
                                                                     Conced
                                                                                               liw
5. Solution Menus                                                    ServiCeS mered & Selection Criteria
    New Product Design                                               Cost I Benefit Analysis (Worksheet)
     -.
   -Technical Changes
    Ordering
    Receiving
                                                                     Aerospace Case Study
                                                                           ”      -      n
                                                                13. Tab F One For One ReDlacsment Process
      -
    Storage & Distribution
    Usage
    Waste, Accumulation & Disposal
                                                                     Concent
                                                                     Implementation& Process Flowchart

6. Measurements
                                                                     @
                                                                14. I G
                                                                     Overview
                                                                                  -
                                                                                dle To Grave” OwnershiD & Training
                                                                                      I.



    Overview                                                         Employee Training Tracking System
      -
    Measuring Plant EHS Performance (Example)
    Roles & Responsibilities (Pyramid)                          15. slnssarv Of Ter   m
                                                                     DefinitionI Explanation Of Terms Used In The Binder
7.
          Assessment Chemical Management
Guide For Improving Chemical Management                                                            Table O Contt nts
                                                                                                         f       -
16. &st P r a c t h
Tab 1New Product I Technical Changes                           Tab 4 Integrated Supplier
                                                -
      New Product Introduction Procedure (GEIPS PDO)                  IntegratedChemical Supplier - Getting Started
      EHS Evaluation for New and Modified Processes and               Product Quality Policy/Pmedure/lnstruction
                           -
         Equipment (GEIPS ASD)                                             (GE Medical Systems)

Tab 2 Chemical Procurement Policy & Receiving Procedure        Tab 5 Cradle-to-Grave Ownership
                                                                     Training
      Receipt of Chemical Material (GEIPS - Greenville)              Measurement
      Communications: New Chemical Ordering (GEAE - Lynn)            CM Roles & Responsibilities
      Blanket Purchase Orders (GEIPS)
      Chemical Review Request Form (GE Motors - Broadway)             GE Best Practice:Regulatory-Required EHS Training(C
      GE Power Gen. Chemical Material Procurement Policy                  (including needs assessment and tracking)
      Chemical Appraisal Procurement Process Training Manual          Measurements: Progress Summary (CAS, CEP)
         to be used by Requestors and Buyers                          EHS Measurement Process (GEAE)
                                                                      Chemical Management Fundions and Responsibilities
                                                                          IGEIPS)
                                                                      Key Roles and Responsibilities
                                                                      GETS Chemical Control Process


Tab 3 Chemical Handling Process                                                                           -
                                                               Tab 6 Conducting a Plant Chemical Sweep A Guidebook
      One-for-One Replenishment Process                              For GE Motors

      Requirements for Use of Personal Protective Equipment           Overview
      One-for-One Replacement (CAS)                                   Guidebook
                                                                      Pre-Plant Sweep Evaluation Checklist
                                                                      Sweep Pre-Work Checklist
                                                                      Sample Press Releases
   c                                 ii                                    i)
Chemical Management                                                      GE's G




    GE's Environmental, Health, and Safety (EHS) Goals...
                 100% Compliance With The Laws
                 Continued Progress Toward Minimization
                 And Elimination Of:
                      --
                      Waste, Emissions And Discharges
                      Workplace Injuries And Illness
                 Cost Effective Cleanup Of Remedial Sites
                 Good EnvironmentalCitizen


           "Every single person in GE has to be an environmentalist."
                                                            J.F. Welch
Chemical Management                                          Goals & Objec -
                                                                           'wes



   Chemical Manaaement Process



           Goal: To Have A Chemical Management Process That Guarantees
                   100% Compliance With All Legal Requirements




     Objectives: Identify, Establish And Implement:
                        --
                        Routines And Controls
                        Measurements
                         -
                        Responsibility
Cqemical Management                                                                                          Key Contacts
...( Additional Assistance I Available
   And                     s


                            Plant Manager - Wiremill 8'380-4467     ' HerbCoulter        GM - EHS                  8'892-3981 '
      'ke Dupont                 -
                            EHS Taylor St. Plant           -4023     Stan Fresman        Manuf. Eng. - Evendale    8'332-4951
  nice Evey                           -
                            Plant Mgr. Taylor St.          -4595     Keith Harshman                -
                                                                                         Mgr. EHS Evendale         8.332-9702
  utch GouM                 Mgr. EHS - Motors              -3223     Ray Hennessy        Sourcing - Rutland        8'560-1316
  enver Sarver              Environmental Specialist       -4005     Rita Schenck        Mgr. EHS - Rutland        8'560-1 506
  I                                                                  Marc Singleton           -
                                                                                         EHS Evendale              8'892-3989




                             Engineering              8'334-7963    Ron Cotman             GEL Manager, EHS        8'346-8297 '
                             Dired MRO                      -7238   Barry Hallock          Cirdeville EHS Coord.   8'574-6307
                             GM - EHS                       -3772   Rufus May              Cirdeville Plant Mgr.   8'574-6221
                             Group EHS                      -4662   Walt Nyzio             Kentucky Plant Mgr.     8'589-3220
                             Group EHS                      -7140   Fred Rial              Kentucky EHS Coord.     8'589-3226
                             EHS Systems                    -7988   lvette Feliciano-Muniz EHS Systems Support     8'346-2738
                             Plant EHS     3                -4657   Gay Baumgartner        Engineering Design      8'346-251 4 ,
                                                                d




                            Mgr. EHS - GEMS           8'320-3022    Bruce Adler          Gorporate Envir erog      8'229-2726
         a Hassan       '   Electric Ave Plant Mgr.   8'767-9796    Vince Giordano       CEP                             -2053
                            Electric Ave EHS Spec     8'767-4152    Tom Taka             CEP                             -3021
                            Chemicals Buyer           8'320-4752
                            Florence Plant Mgr.       8'284-1 600
                            Florence EHS Spec         8'284-1 633


                    I       Leverage Others Who Have Gone Through The Process
                                                                    P m                                                 3
    -
C
hemical Management
                                                                                           ---.



                                                                                  Package Overview




                  A Starting Point For Chemical Management Self-assessment
                  A "How To" Guide For Identifying And Implementing Routines
                  And Controls For Improved Chemical Management
                  A Tool To Identify proactive Opportunities To Increase Compliance
                  Sample Documents To Use And Customize For Your Plant
                       ,I




        Requires Leadership From EHS To Move Forward
        Requires Commitment And Discipline From Operations To
                            -
        Ensure Success Compliance Responsibility Lies With Operations
    c;                                                                                                  3
Chemical Management                                                   Why Chemical Managemen

                          ...
  Multiple Reasons Multiple Benefits

                                                                  Effective Chemical Management Processes
                                                                  Move GE to 1ooO/o Compliance with the Law
                                                                   No Vilatiin of 90-day Rule
                                                                  No Missing Material Safety Data Sheet (MSDS]
                                                                  No lack of Employee Hazard Training
                                                                  No Labeling and Tradcing Violations
                                                                  No Unpermitted Discharges
                                                                  No Improper Storage
                                                                  No Missed FligM to Know Reporting
                                                                      -
                                                                     EtC.

                    Pmductivitv
                                                             I Compliance With The Law A Necessity I



                                                             -
                 Productiwitv / Cost                                           Ethics
            Lower Total Volume Of Chemicals On-site               Controlling Excess Vobme of On-site Chemicals
            -reduces inventory & potential liability costs        Reduces Risk Of Exposure To Workers And The
                                                                  Community
            Fewer Chemicals Being Ordered Means
            Lower Waste Removal Costs
                                                                  EHS Involvement In Product And Process Chans
        -   Centralized Handling Process Allows                                                     u f
                                                                  Phase Keeps Unwanted Chemicals Ot O The
            Operations To Focus On Production                     Plant


         Smart EHS Decisions Help
       Drive Bottom Line Productivity                             I        Reduced Worker 81
                                                                          Community Exposure        I
                                                                            -
Chemical Management                                                                       Process Overv

Need To Incorporate Basic Routines And Controls To Ensure 100% Compliance

                                                                Involve EHS In Product And Process Design Efforts
                                                 Controls       Establish Approved Chemicals Listing
                                                                Prioritize Chemicals To Be Removed
                                                                Complete Chemical List To Insure Hazcom Compliz
                                                    I
                4   -   l
                I   Ordering     1
                                                                Control Approved Chemicals And Purchasers
                                                                        I
                                                                Control A Venues of Chemical Purchased




                                                                Control Non-purchase Entrance Of Chemicals
                                                                Control Chemical Movement And Use On Shop Flol
                                                                Minimize Employee Touch Time & Dispensing




                                                                Manage Waste Stream Certifications
                Accumulation &                                  Manage Waste Stream Storage
                   Disposal                                     Manage Employee Health Risk
                                                                Integrate With Supplier Process


                                 Make EHS Compliance A Part Of The Process
     on
GE R p '                                                                                                  d
~s,,",~?u€al-                                           L   d
        c,
Chemical Management                                                                                               Road 1
 Assess Effectiveness Of Current Chemical Management Activities
              Design
            Specification
                                      ordering
                                                            Receiving/
                                                             *rage                                                      1
                      Technical Experti 81Guidance
                        Ions Involvement & Responsibility




       1
           .../n order to est8Mish 8 better process going forward                                                       I




                              Perform Assessment Checklist                        Implement Required Solutions
                               Determine missing controls                          See specific Tab in package
                               Prioritize areas to address                         Ensure Operations responsibility
                            -  Get required operations involvement                 Educate everyone on new procedures   .
                                                        Monitor The Process
                                                         Ensure controls are used and working
                                                         Annual inventory to identify potential breakdown


GE Pmp&a~~
                  Develop A Compliant Chemical Management Process For The Plant
F S l ~ U p t ~ u S
                                                                                                                            I
Chemical Management                                                            Common lssc
Lack Of Controls Has Resulted In Numerous Compliance Issues              ...
                 To date, Aimaft Ewines, Motors, wiatms,Aeras3paae and
                 L@hthghavebeeninvoklinChemkalMamgementreviens



                  Excluded EHS from approval cycle on product and process changes




                 Multiple avenues for chemicals to enter facility without EHS knowledge
    Controls     No checkpoint to prevent employees, vendors or contractors from bringing
                 in unapproved chemicals
                 No EHS review and approval on new chemicals
       1
n   In-plant
    Controls
                 Chemicals borrowed from one approved operation used in
                 unapproved operations
                 Discovered unknown and unlabeled chemicals
                 Low employee awareness and training
                 Missing substantial number of MSDS

  Waste Stream    Unlabeled waste drums and unmarked accumulation areas
  Management      Violation of 90 day rule
                  Improper disposal of chemicals
                  Large volume of obsolete chemicals requiring disposal

                     I Issues Common To All GE Businesses I
         L                                                U                                          d
Chemical Management                                                                              The Co
                                             As of August 1992
                                Penalties          AssessedlPend ina Fines Paid or Settled
                    Resolved in prior 12 Months           $26.7MM              $5.6 MM
                    Ongoing matters not resolved          $9.6 MM              Unknown
                    New matters under Investigation       Unknown              Unknown



         Basic Compliance Issues:

                        Labeling, improper           Housekeeping,              PCB labeling,
                         storage, record            HAZCOM ($65 M)            improper storage,
                         keeping ($50 M)                                    record keeping ($59 M)




         Lifestyle Implications For Plant Managers:
               -                                      ~




                         Unpermitted storage, disposal           Improper Disposal of

                            -
                         of hazardous waste ($1.4 MM )+
                             Criminal investigation
                                  dismissed
                                                                -
                                                              Hazardous waste ($325 M)
                                                                Criminal investigation
                                                                     terminated
      M-Thousands

GE proptietaty                  Must Raise The Bar To Meet GE Standards
     L                                                                               LJ
Chklcal Management                                     -
                                            Overview How To Use This Packag




                                                            l"e      ntation Guldellnes




 I
                     t
                     I



                         c)MecthrcHi.
                           Understa;ldproMemsand
                           assodated risks
                                                             The "How to. of
                                                             implementing control
                                                             procedures (See Tabs A-G)




                                                           Qbiedjves:
                                                                                           I




                                                             Detailed execution instructions
                                                           " copies d f o r m d ~ m e n l to
                                                                                          s
                           Prwidesokrtionallematives         be used - please plagiarize
                                                             and/or modity for your own use
Chemical Mana aement                                       How To Use -Assessment Checklist




                  L
Main Control Points
                        t
                                                                               Solution Menu
                                                                               to address and improve
                                                                               the control deficiency




                      Specific questions for each subsection to pinpoint
                      specific control breakdowns



                            Answer All Questions on Checklist
                            If Answer = No, Refer To Solution Menu         I
Chemical Management                                                 -
                                                        Overview How To Use This Packa!




                                   -
 This Package Is Divided Into 3 Sections


      Assessment Checklist                 Solution Menu                Implementation Guidelines



                                                                          The “How to“ of
                                                                          implementing control
                                                                          procedures (See Tabs A-G)




  m:                               Wctives:                             Wctives:
                                                                         Detailed execution instructions
   Identify potential compliance    Understand problems and
   exposure                         associated risks                     Copies of formddocuments to
   Pinpoint routine &control        Provide solution alternatives        be used - please plagiarize
   breakdowns                                                            and/or modify for your own use
      c
Chemical Management                                                                  -
                                                                     How To Use Solution Meflu
                                                                                                       I
Solution Menu Is A Standard Form For All Control Areas                                                 I
                                                                                                       ,
Problems:                                                                  Control Area;
  Re-states the problem(s) which resulted                                   Topic for the page: exampb;
 from answering 'No' on the Assessment                                      Ordering, Storage, or Use, etc.
 Checklist



                                        Aunemd nbb

                                                                            Comdiance EXDOSU :   re
                                                                             The reoccurring theme
Assoclated Risks:                                                            Represents the takeaway from
 Lists the risks which result from                                           the Associated Risk section
 the above problem@)
 By fixing the problem,
 compliance is improved


                       /                                               \
               Solutions:                                          Reference:
                Represents corrective action@)                      Provides examples of tools,
                Process improvements to decrease compliance risk    documents and procedures that have
                                                                    been actually used


                 Understand Problems & Associated Risks
           ~     Review Solutions And See Tabs For Implementation Guidelines
                                                                                          I

Chemical Management                                                           Using The Tabs

In implementing a Chemical Management Process, we recommend that.                  ..
 1. All steps in Tabs A, B, and C be executed as completely as possible. The
    routines and controls identied represent "must do" requirements for ensuring a
    compliant chemical management process. The up-front controls will prevent
    many downstream compliance issues from ever occumng.
 2. Tabs D and E represent conceptual solutions for managing and controlling the
    movement of chemicals within the plant. Establishing a chemical handling team
    is one way of controlling chemical movement. Utilizingan integrated supplier is
    another. Within your facility you may not be able to establish a dedicated leam"
    or an integrated supplier. Regardless of the type of process you put in place, the
    objective remains the same, controlling chemical movement and use on the
    shop floor.
 3. Tabs F and G can be used to accentuate the controlled chemical movement and
    use process. "One for One" and "Cradle to Grave" can be added to help
    minimize quantities of chemicals both on the shop floor and in inventory, and to
    ensure responsibilityfor compliance remains with operations.

The ultimate goal is to implement solutions which will enable you to answer "Yes"
to d l the control questions on the Assessment Checklist
                                                                                          I
         c/                                     Lj                                       dl
 Chemical Management                                                              -
                                                          Assessment Checklist Overvi&



         The Assessment Checklist Is    ...
             A tool used to identify potential compliance exposures
             A questionaire to pinpoint routine and control breakdowns


         How To Use The Checklist?
             For each question, there are 3 potential answers:
               High -    Implies that controls do not exist or are infrequently used
               Medium - Implies that controls exist and are used in most cases
                Low -    Implies that controls work in all cases, or question does not
                         apply to this site

          How To Get The Best Results?
             Be realistic and candid - Every plant has opportunities to improve
             Get others involved in the assessment and implementation
               - Plant Manager
               - Local engineers
               - Supervisors
               - Employees

GE Proprietary
FSlsE chm M g m * u m m   ch**Lt-up
Chemical Management                                                                        Assessment Checklist
                                                                                                 Risk Level
                Marketincr
                Is theft?a process to ensure upfront integration of EHS aspects of proposals?

                Product Desian & Process Chanaee


            1
                Areallnewprodoctsandprodudchangesproactively~~wedand~~ved
                by EHS?
                Are all in-plant ptvces changes proactive& reviewed and appnwed by EHS?
                Does Engineeringptmcthely implement aorpwate EHS o b j d e s and
                inilhiives?
                        *POWER, Chemical reductiodeliminationobjectives, etc.


LiLI
 Pmcuremenl

. ... ...
                Orderincr
                Are all new chemical purchases and imported chemicals reviewed by EHS prior
                to procurement?
                Does Sourcing have a process for updating and maintaining MSDS database


            I
                and approved chemical list?
           Receiving
           Are all chemicals received at (a minimum number of) controlled receiving
           points?
           Do Receivers ensure that only EHS approved chemicals enter the facility?
           Are chemicals stored properly after recebt?
                                                                                                       .. . .   .
For items where risk level was assessed as low, please explain why:
         L
Chemical Management                                                                            Assessment Checklist
                                                                                                          Risk Level
                                                                                                           (H, M, L)     M&':
                        Storacre
                        Are chemical storage areas clearly defined and segregated within the facility?
                        Is access to stored chemicals limited and controlled?

                        l 2 i " n
                        Is there a procedure to limit and control chemical distribution?
                        Are employees responsible for moving chemicals adequately trained?
                        &
                        !e
                        Do all employees receive ongoing, job-specific chemical training?
                        Does Operations maintain an approved chemical listing and MSDS file by area?
                        Has a complete physical inventoty been taken in the past year?
                                   ccumulation & DISDO$ a     1
  Managemem
                                          established to track waste accumulation and disposal?
                        Is there full identification and ownership of all waste streams?

 For items where risk level was assessed as low, please explain why:




                  If You Have Answered H Or M To More Than One Of These Questions,
                       Please See Next Page For Assistance In Establishing Priorities
                                                                                               SM = Solution Menu
                                                                                                                     I
GE Proprietary                                                                                Refer to Solution Menus tab in package
F S l mC h mY p m " M    U*aladow
Chemical Manaaement                                       Prioritization Guidelines


        ImplementingThese Process Steps Will Improve Compliance

                       Process Steps                     Prioritv

            Perform a physical inventory                     1
            Create an approved chemical list                 2
            Implement a procurement policy                   3
            Establish guidelines for EHS review              4
             f
            o all new products and process changes
            Establish in-plant distribution network to       5
            control movement and use of chemicals
            Implement a waste management process             6


              These Steps Represent The "Must DO'S' For Establishing An
                       Effective Chemical Management System               I
DE Propfl
F%"la
           c
Chemical Management
                                                   b                                     d
                                                                           New Product Uedign

           Issue:
                      No formal procedures to ensure proactive EHS review & approval
                      of all new product designs

           Associated Risks:
                      Product liability - new product contains potentially hazardous chemicals
                      Missing or inadequate permits for chemical release and/or disposal
                      Occupational Safety and Health Act (OSHA) violations
                      lnsufficient employee trainindprotection
                      Rework and redesign costs


                                    L   Compliance Exposure          I

                 Establish new product introduction guidelines with EHS         TAB A
                 required approval

                                                   SM-1
GE Proprietary
FSl-Ygm;    P
           Nl-
Chemical Management                                                      Technical Changes
   Issues:
           No formal procedures to ensure proactive EHS review & approval of all
           process changes
           No clear definition for types of process changes and level
           of EHS involvement required

   Associated Risks:
          Product liability - new product contains potentially hazardous chemicals
          Missing or inadequate permits for chemical release and/or disposal
         OSHA safety violations
          Insufficient employee training/protection
          Rework and redesign costs

                          m o m p l i a n c e Exposure        I

       Establish technical change guidelines with EHS approval                TAB A
       required
  c Management
Chemical
                                             u                                   3
                                                                              Ofdefihg
     Issues:
            New chemicals not approved by EHS prior to procurement
            MSDSs not obtained prior to procurement of new chemicals
            MSDSs not used as the tool for approving new chemicals

     A ssociafed Risks:
            New chemicals used without adequate training and protection
            Missing MSDSs lead to regulatory reporting inaccuracies and OSHA violations
            Permit requirements unknown without adequate chemical knowledge

                                I Compliance Exposure I

          Develop chemical procurement and receiving policy that            TAB B
          ensures EHS approval of all new chemicals
          Conduct plant physical inventory and establish an Approved        TAB C
          Chemical List
                                           SM-3
 ld n "
Pl u p
Chemical Management                                                          Receiving
Issues:
          Chemicals not screenedreviewed against Approved Chemical List
          Chemicals are received at non-controlled points in the plant

Associated Risks:
          Employees exposed to chemicals without adequate training or documentation
          Missing MSDSs lead to regulatory reporting inaccuracies & OSHA violations
          Absence of chemical verification routines heightens chance of permit violations
          Receipt of unapproved chemicals may lead to generation of unknown waste

                               Compliance Exposure



   Develop chemical procurement and receiving policy                         TAB B

   Conduct plant physical inventory and establish an Approved                TAB C
   Chemical List
                                                                                                                          L,
Chemical Management                                                       Storage & Distritrdtion

          Issues:
                 No procedure for limiting access to chemicals
                 Chemical storage areas not segregated
                 No proceduresfor controlling chemical distribution
                 Employees not properly trained in chemical handling
          Associated Risks:
                      Employee safety - Chemicals distributed tohy untrained employees
                      Failure to report when stored quantities exceed reportable limits
                      Storage does not meet OSHA guidelines
                      Chemicals distributed to wrong area
                                         I Compliance Exposure
                                                                               .... .... . ... . ....   ..   .   . . ..




                 Establish a chemical handling process                                 TAB D
                 Investigate using an integrated chemical supplier                      TAB E
                 Use "One-For-One" chemical replenishment                              TAB F
GE Proprietary
                                                      SM-5
T   mS w C w m "
Chemical Management                                                              Usage

    Issues:
              Employees may be unaware of potential chemical risks
              No approved chemical listing by area
    Associated Risks:
          Employee exposure exceeds Personal Exposure Limit (PEL)
          Chemicals used for unauthorized processes / purposes
          Operating permit and OSHA statute violation(s)
          Employees unknowingly generate / dispose hazardous waste
          Failure to meet product specifications

                             I Compliance Exposure I


       Assign "Cradle-to-Grave" chemical ownership                   TABG    -

       Train operators on usage requirements                         TAB G

                                         SM-6
                                          J
Chemical Management                                              Waste Accumulation & Disposal

                 Issues:
                       No process to ensure compliant waste accumulation and disposal
                       Lack of ownership drives incomplete understanding of waste streams
                 Associated Risks:
                      Waste stored improperly and in unclassified containers
                      Waste disposal violates govemment regulations
                      Permit violation(s)
                      Exceed 90day storage limit
                      Potential criminal / civil penalties


                                         Solutions                              ..


                    Establish a chemical handling process                            TAB D
                    Use "OneFor-One" chemical replenishment                          TAB F
                    Investigate integrated suppliers / waste handlers                TAB E
                    Ensure employees are properly trained                            TAB G
                    Assign "Cradle To Grave" ownership                               TAB G
GE Proprietary
l*: w 1
 p.    m
                                                                                             !
3
3
Chemical Manaaement                                                Measurements




  Overview


       A sustainable Chemical Management Process will only occur
       when plant performance is measured on a regular basis.
       The following pages provide examples of some EH&S
       measurements which may be used in your plant or business.
'3
                               r

    L                         LJ                            L,
I       Environmental, Health and Safety Progress Summary
                                  EHS Pro res8 Summary
                                                  B
                                    Comp etion Guide
     1. Self Assessment
3       This indicator includes, but is not limited to, activities that the plant conducts such
        as the following:
         .                               of machinery guarding, weekly PH probe check,
         .HAZCOM labeling, air pollution control equipment, etc.
                                                  -
                                             Evaluation of Hearing Conservation Program,
         .Emergency Response, selected EHS Work Plan activities, etc.
                                              -
                                (JHA'd Thorough evaluation of a job or operation targeted
          toward identifying all EHS aspects and developing Standard Operating
          Procedures (SPOs).
                         -
     2. EHS Tralnlng Reported as person hours per quarter
                                          -
     3. EHS Committee Meetings Reported as number of meetings per quarter
                                                      -
     4. OSHA Assessment Report Score This indicator is calculated based upon
        ratings submitted monthly
                                                          -
     5. OSHA Recordable Injury Or Illnesses This indicator is reported monthly.
                                  -
     6. Emergency Incidents This includes events typically due t procedural,
        personnel, and/or equipment failure. (e.g. SO2 leak resulting from a "faulty" valve).

-9                                -
     7. Permit Exceedences This includes "elevations" typically due to inadequate
        equipment, processes and/or controls (e.g. elevated waste water levels in excess
        of permit limits).
         These types of "elevations" could potentially occur in the following media:
            Air                  Waste
            Water                Industrial Hygiene
                                                  -
     8. Worker's Compensation Costs Average costs in dollars per employee per
        year.
                -
     9. Fines Total number of dollars in regulatory fines.
                         -
     10. Waste Costs Waste costs in dollars.

                                      -
     11. SARA Reduction Index The numerical difference between the number of
         pounds of SARA chemicals for the previous year and the number of pounds of
         SARA chemicals for the current year.
     Calculation:            # of pounds of chemical X for 1992
                          I                          X for 1999
                                  SARA Reduction Index

3
                              EHS Pro ress Summary
                                          B
                                  Comp etion Guide



 Here are some additional "indicators" you may want to incorporate:
. 1.   Injury 81 Illness Index
                                      +#A-
                              Person Hours Worked

 2.    Compliance Index
       The actual number of "violation items" (each individual citation, exceedence
       result, etc.) identified in any formal Regulatory Citation, Notice of Violation,
       Finding and Orders or Notice of Deficiency.
       c                                              ,

                                                     \L/
                                                          ,P



                                                                                                L,
Chemical Management                                                           EHS Responsibility Pyramid
 Shifting Chemical Management Responsibility From EHS To Manufacturing




                                           Creates accountability



                                       Creates safe work environment
                            Communicates objectives & measures petforman
                                          Educates &trains
                                      Provides technical expertise
                                     Performs administrative duties
                                 Assumes proactive role on production floor



                         Trains employees in chemical usage, storage, and disposal
                       Manages day-today operations to assure safety and compliance
                     Assumes complete area ownership - "cradleto grave" responsibility




DE Proprietary
FSlFhrnkWsHs grnid
                     Ensures Compliance & Creates Sustainability
                                                                                          I
Chemical Management                                                 Key Roles & Responsibilities

Roles & ResponsibilitiesThat Drive Ownership
                                                                              Plant EHS    Area ~ p e r v l s o ~
               Meagyrementg                                                   Specialist   Process Engineers

                Review impact of NPllprocess changes on chemical management       J                J
    Up Front    Translate Best Practices thru plant/Business
    Chemical    Permits current and fully compliant                               J                J
    Controls    Approved chemical list in place                                   J
                Monitoring of approved chemical list                              J                J


                                                                                                   J
                                                                                  J
                                                                                                   J
                                                                                                   J



                 OSHA recordabledtost time accidents minimized                    J                J
    In Plant     Chemical inventory for area accurate                             J                J
    Controls         -chemical inventory minimumized
                    - chemical usage in area tracked
                                                                                  J
                                                                                  4                J

                                                                                  J
                                                                                  J                J
                                                                                  J                J
                                                                                                   J

    C                                             v                                                 d'
3                                   Assessment
                               ch e m i c a l a


    Chemical Management is a process which ensures the complete control of customer
    chemical pr@uct specification, purchasing, receiving, use and disposal of all chemicals
    in your plan). This assessment is designed to guide the user as to those controls and
    links within your existing processes which need to be strengthened. Strengthening your
    chemical management system will (1) reduce worker and community exposure (2)
    ensure compliance with the laws and (3) contribute to productivity.

    For the purpose of this assessment the following definitions apply:
                                      -
                 PDDrOVed chemical A liquid, gas, solid or powder which in normal
                 use has the potential to cause a health and/or physical hazard, or the
                 release of toxins into the environment. This definition also includes any
                 new materials that will be created during the manufacturing process, either
                 as intermediates, by-?roducts, or wastes. Examples of chemicals include
                 paints, oils, coolants, adhesives etc. When in doubt, assume it is a
                 chemical.
                                             (MSDSI- A technical bulletin required by
                 OSHA which contains information about a chemical material regarding its
                 identity, chemical and physical characteristics, health and safety data,
                 and precautions necessary for safe handling and use.

    During the risk assessment phase of performing a chemical management review two
    tools shculd be utilized. A chemical physical inventory should be performed as
    one of the first steps in understanding where your business stands regarding chemical
    management. The inventory will provide your business with a current chemical
    approved list and will substantiate where routines and controls have broken down in
    the chemical management process.
    This assessment should be used to assess where routines and controls need to be
    strengthened. This tool will coach participants as to what questions should be asked
    when assessing the current chemical management processes. By answering yes or no
    to these questions one can ascertain where breakdowns have occurred within the
    process. 'A Guide for Improving Chemical Management' should then be utilized to
    assist in implementation.


3
      Chemical Management is divided into two main areas: Up front Controls and In pl-
      Controls.
      Up front controls ensure proper EHS approval is obtained prior to customer
      specification of products, changes in the use of a chemical, the ordering of a chemical,
      or the release of a chemical from receiving to the shop floor. These controls consist of
      Marketing and Sales Proposals, Engineering and Design Controls, and
      Procurement and Receiving Controls.
      In-plant Controls ensure that chemicals are properly handled in the facility. In-plant
      controls are divided into five areas: Storage, Distribution, Usage, Waste
      4ccumulation and Disposal.




Y/N       Reviewed
         Bv

                     1.   Marketing and Sales Proposals ensures only approved
                          chemicals are negotiated into contracts with customers.

                          a. Do negotiated proposals include information regarding
                             EHS requirements (use of only approved chemicals)?

                          b. Is a customer permitted to specify chemical use requirements?
                             (1) Do you negotiate the use or restricted use of chemicals as
                                 part of the marketing operation?
                             (2) Is an approved chemical list utilized by the Sales
                                 Organization when negotiating with customers?
                             (3) Does a procedure exist whereby Sales and the customer are
                                 notified of chemicals which may not be negotiated into the
                                 final contract?

                          c. How do you obtain EHS review of the proposal prior to
                             ratification?

                             (1) Does the Proposal contract review include EHS approval
                                 on proposed contents of productlpans?
3-
\
          d. What type of training do sales representatives receive on
             chemical management, what it is, new processes and
             procedures?




     2.   Engineering and Design Controls ensure proper EHS
          approval is obtained prior to the implementation of any New Product
          Introduction (NPI) or any product/process changes.


          a. Process map the business' NPI and technical change process.
             Using the process map, answer the following questions relating
             to NPI and technical changes.

             (1) Who and which functions are involved in each process?
                  How is EHS involved? i.e. one EHS person formally
                  coordinates all reviewdapprovals, a plant EHS
                  representative oversees these activities for the plant.
             (2) Are meetings conducted to review activitiedstatus? Are
                  EHS concerns evaluated during these discussions?

             (3) Does the business have an EHS checklist to assess
                 potential exposure? If yes, is the use of a checklist required
                 in the m.      Dlannlna and    e     '  stages of a process
                 change or product introduction, and has everyone involved
                 in the process been trained to use the checklist?

             (4) How are potential issues addressed and resolved?

             (5) How does the business document NPI and technical
                 changes?

             (6) How is EHS approval obtained prior to finalizing a project?
                  Are formal approvals (signoffs) required before new
                  products are introduced or technical changes occur?


          b. How could a chemical be specified within a product's design
             without EHS approval? How do you ensure that the specified
             substances are permitted for use in your facility?

             (1) Does engineering utilize an approved chemical listing
                  when designing products?

             (2) Is engineering aware of those products which are restricted
                 for use in the plant?
          (3) Does Engineering utilize the EHS organization for chen,
              expertise regarding product specification?
                                                                               '?
          (4) What routines exist to ensure that new chemicals specified
               for a disposition change are approved by EHS?
          c.   Do procesdproduct changes include changes in the
               specification of chemicals used?
          d.   Does Engineering actively seek out waste minimization
               opportunities?



3.   Procurement and Receiving Controls ensure EHS approval of
     all new chemicals (includes vendor changes) prior to being ordered
     and received.
     a. Does the business have (and use) a chemical procurement
        policy for all points of entry? Have the details of this policy been
        communicated to all buyers and requesters?
     b. How many ways can a chemical be procured? i.e. standing
        purchase order (PO),   blanket PO, expense account, petty cas, ,, )
        etc. Are all of these channels controlled?
     c. How many people are authorized to order chemicals? Have all
        these people been trained in the proper procurement of
        chemicals?
     d. Does EHS approve all new chemicals prior to procurement? If
        yes, what process and controls exist?
     e. Does the business have an 'Approved Chemical List" (Le. A list
        of chemicals approved for use in the facility)?
     f.   If yes to (e), how and when is the Approved Chemical List used?


          (1) Is the Approved Chemical List used by the requester or
              purchaser to ascertain if a chemical may be purchased? If
              the chemical has not been approved, what is the process to
              obtain approval? Are MSDS's needed for approval?

               s
          (2) I it used to screen chemicals as they are received? Is there
              a quarantine area for chemicals received which are not en
              the approved chemical list?                               )
 3         g. If your business uses a integrated chemical supplier, what types
              of services do they provide?
                   Do they review chemical purchases to ensure that only
                   approved chemicals are purchased?
                   Do they maintain and distribute MSDS sheets for the
                   business?
                   Do they ensure that no chemical substitutions are made
                   by vendors?
                   Do they communicate consistently with the business to
                   ensure that all information is current?
                   How are GE's chemical management requirements
                   communicated?


       h. Where can chemicals be received, and what are the routines
              and controls to prevent unauthorized receipt of chemicals?

L -
           i. Are those individuals who receive chemicals trained as
              authorized receivers according to OSHA and DOT
              requirements?

       j.     Does the business have a Chemical Use Policy for contractors?
              Does it require EHS approval of chemicals used by contractors?
       k. Do vendors andlor contractors bring in chemical samples? If so,
          how are they tracked and controlled?
       1.     Does the business maintain excess chemical inventories?
       m. Are purchased quantities of chemicals tracked? Can annual and
              year to date data be gathered for use by EHS professionals for
              Power Program development and reporting?
       In-plant Controls
      4.      Storage & Distribution Controls ensure that all chemicals
              have been segregated and stored properly; that access to
              chemicals is limited; that employees transporting chemicals have
              received chemical handling training; and that chemicals are only
              distributed for authorized usage.

c)     a. Does the business have an 'Approved Chemical List' (Le. A list
          of chemicals approved for use in the facility)? Who developed it?
          How and when was it developed?
    (1) Was a complete physical inventory taken to determine
         which chemicals needed to be approved? When was the
         last chemical inventory taken?

    (2) Were MSDS's used to approve the chemicals? Is the
        MSDS file complete?

   (3) Is the approved list kept current? Who is responsible? What
       process is used?

   (4)    s
         I an area approved chemical listing available in each work
         area?

   (5) Are area specific MSDS's available to employees on
         the shop floor?

   (6) Is a process in existence for ensuring that area specific
       MSDS's are maintained?

b. How does the business manage the flow of chemicals from
   receiving to disposal? Focus on hazardous chemicals and
   production chemicals.
c. Have segregated chemical storage areas been established I,.
   the facility? Are these storage areas appropriate for the storage
   of chemicals?

   (1) Are flammable materials stored in flammable containers
         and flammable cabinets?

c. How does the business control access to storage areas? Are
   these areas secured?
d. How does the business ensure that chemicals have been
   approved for use at the area in which they are delivered? Are
   restricted chemicals accessible to non approved work areas?
   i.e., 1,1,1 approved in one process and used in other processes.

e. Have predetermined release quantities been established for all
   chemicals? (i.e. is a one for one replenishment process used?)

f. Are specific people responsible for distributing and collecting
   chemicals?

   (1) How are chemicals distributed from storage to the point ui
                                                                     1
       usage? How many people distribute chemicals?
3           (2) Does the business have a specific team of chemical
                handlers? What training have they received?



    5.   Usage Controls ensure (1) employees handling
         chemicals have been trained in the use of those
         chemicals (2) MSDS sheets are available to employees
         in their work area (3) employees are physically protected
         when using chemicals (personal protective equipment)

         a. Is an approved chemical listing available by area for employee
            use?
         b. Do employees know where to obtain an MSDS? Are MSDS's
            available at each work area?
         c. Do employees only use chemicals that are approved for their
            area?
         d. Do area specific MSDS's accurately reflect those chemicals
            being used by employees ?
         e. Are all chemical containers properly labeled? Do employees
            understand labeling requirements?
         1. Does the business have a labeling procedure in place? If yes,
            has the procedure been communicated to production, and is it
            used?
         g. Are unapproved secondary containers used (Example: milk
            carton, coffee can, etc.)? Are flammables stored in flammable
            containers? Are they labeled properly?

         h. Have employees been properly trained to safely handle and use
            the chemicals required for their production duties? Have they
            received HAZCOM training? Are training records available?

            (1) List all current health and safety training programs. (This list
                must include emergency response, HAZCOM, and
                respiratory, sight and hearing protection training)

            (2) How does the business ensure that all employees are
                trained?
3           (3) What type of training records are maintained by
                 employee?
        (4) What is the procedure for ensuring that all salaried
             employees receive, at a minimum, HAZCOM training?            1
    i. Do employees use protective equipment when required?

        (1) Is the proper safety equipment maintained and used?

        (2) Are employees trained in the proper use of equipment?
        (3) How often is training reviewed?

6. Waste Accumulation 81 Disposal Controls
   a. How is waste collected?
   b. How much waste is generated by the plant?
   c. Who collects chemical waste?
        (1) Are these employees properly trained in RCRA waste
             handling?

        (2) How are training records maintained?
   d. How is waste stored?

        (1) How do we ensure hazardous waste is not stored longer
             than the limit set by state and federal regulatory agents?
             Are required records maintained?

        (2) How is stored waste labeled and separated? What is the
            process for maintaining records?

        (3) Do personnel responsible for marking and reporting waste
            understand the regulationdrequirements?
   e. Storage in containers
        (1) Are procedures in place to check the integrity of containers?

        (2) Are clean up materials available?

        (3) Are containers marked properly with EPA labels, DOT
            name, date as appropriate?
   f.   Have satellite accumulation areas been identified?

        (1) Are approved containers used for waste accumulation?
             Does the business use a one for one replenishment
             process for waste accumulation containers?
          (2) Is waste accumulated at the point of waste generation?

     g. How does the business differentiate between hazardous and
        non-hazardous waste? Review records to ensure that
        hazardous waste has not been shipped as non-hazardous.
        Chemical analysis should be performed and records kept of any
        questionable waste.

          (1) Who is involved in this process?

          (2) How are these individuals trained?

          (3) Have training records been maintained?
          (4) Are permits maintained?
          (5) How is waste tested, and is the lab approved? ( if required)
     h. Describe the component's hazardous waste disposal
        documentation routines, including the following:

          (1) Manifest routines for shipment of hazardous waste

          (2) Storage of hazardous waste at facility

          (3) Condition of hazardous waste containers, including
              labeling
          (4) Use of CEP approved waste transporters and disposal
               centers
     i. If hazardous waste is not disposed of in 90 days does the
        component have a ACRA Treatment, Storage, and Disposal
        (TSD) Part B permit to store waste on site? Does the business
        perform inspections as specified in the permit? Visually inspect
        the storage facility to ensure that the area is secure, clearly
        identified, and in good condition.


     j.   How does the business dispose of non-hazardous waste? Does
          the business have the necessary local, state, and federal permits
          that authorize its disposal routines? Review records to verify that
          required tests are being performed.
     k. Are employees who work directly with hazardous waste using
        safety equipment?
L)   1.   Are these employees trained on hazardous waste materials, and
          are the MSDS's available in the area?
3




3
L

Component /Shop:                                       Manager: " e
            Unit:                                Unit Manager(@: "e
                                                               "e



                                    # of            Location of         Date        Mgr.
           Audit Control Point   Non-Compliant   Non-Complying Items   Corrected   Initials
                                     Items
Ensure sample of 5 is random and not first 5 items observed
3           New Product Introduction & Technical Changes

    Purpose:
    To ensure that EHS review and approval occurs ndpc to introduction of all new products and
    the implementation of all technical changes

    Definitions:
     A.   New P-Introduction                       of a product that has substantially different
          physical characteristics and/or functionality than other models or products
     B.                       -
                              Changes that impact product quality, performance, dimensions, or
          material composition. Technical changes can be categorized as either "Major" or
          "Minor
          1. Major Change:
                   Change that affects product functionality, performance or quality
                   Change requiring business analysis and/or potential testing prior to approval
                   Change outside engineering specifications
                 Examples:
                    Material consumption rawchange
                     Production rate increase
                     Direct material suppliers change
                     Exhaust systems, pump & flush equipment change
          2. Minor Change:
                   Change that supports manufactucing process, but has no direct impact on
                    product (Used to provide chronology of changes for cause-effect analysis if
                    product problem occurs)
                   ,Change vvithin engineering specifications
                     Examples:
                         Material handling equipment change: alley rollers, forming, buttons,
                         rail material, conveyor chains, Kevlar belts, etc.
                        Product gaging equipment
                        Product cosmetics, dimensions or glass composition within
                         specifications
        New Product Introduction & Technical Changes

Implementation Guidelines (In Order Of Prlorlty):

    -
    r
Bew P
1.      EHS must first understand the current process used to introduce new products:
             Who is involved from which functions?
             When and where do they meet?
             What issues do they discuss?
             Is EHS part of the process?
2.      Develop EHS checklists for the concept, planning, and execution phases of a new
        product introduction (See Exhibit A1 for example)
3.      Ensure that all members of the product development team are cognizant of potential
        EHS concerns, and apply an EHS checklist throughout the product development
        cycle. All potential EHS Issues must be reviewed wlth program managers
        anQ Plant EHS Coordinators for all Impacted plants prior tn Introduction
        of the new product.

          Chaw
1.       EHS must understand the current process used to make technical changes:                )
            Who is involved from which functions?
            When and where do they meet?
            What issues do they discuss?
             Is EHS part of the process?
2.      Establish formal process to ensure approval of all technical changes
3.                                                                              -
        Train engineers to accurately define and recognize technical change types if there
        is aoy doubt about whether a change is "Major" or "Minor", the change ism.
4.      Develop EHS checklists for concept, planning, and execution phases of a technical
        change (See Exhibit A1 or A2 for examples)
5.      Ensure that all personnel responsible for initiating a technical change are cognizant
        of potential EHS concerns, and apply an EHS checklist throughout technical change
        process. All potential EHS issues must be reviewed with Plant EHS Coordinators for
        all impacted plants pdprtp implementation of the technical change.
6.      "Major" technical changes require closer scrutiny by Plant EHS Coordinators and
        involved engineers than "Minor" changes. The general level of Plant EHS review will
        vary based on volume of changes and resources available, but at the very mini",
        every "Major change should be thoroughly reviewed by the impacted Plant EHS
        managers prior to implementation.
    7             New Product Introduction & Technical Changes

             How To Implement
        1.       Distribute policy to all plant engineers and plant EHS coordinator for review.

        2.       Conduct a training session with all engineers (and any others) that impact or initiate
                 new products or technical changes. Key points to discuss include:
                      The need for a new product introduction and technical change policy
                       Critical definitions
                       Roles and responsibilities
                      Attached exhibits
        3.       Assign responsibility to plant engineers and the plant EHS coordinator for execution
                 of this policy.

             Critlcal Success Factors:
               Need to provide thorough EHS sensitivity training for all product development team
               members and plant engineers

~   1          Introduction of proposed new product or technical change must mt occur until all
               impacted Plant EHS Coordinators have reviewed and approved EHS implications
               Strong business leadership is necessary to drive EHS sensitivity and documentation
               accuracy
'2
i
                                              Exhibit A1
     Example: EHS Checkllst For New Product lntroductlon & Technical Changes
3    1.   Concept Detlnltlon Stage
          In this stage, the concept is being evaluated for feasibility and producibility.
          The purpose of the following checklist is to function as a "Red Flag" for identifying
          items or issues of EHS impact or regulatory concem. Any issues identified via this
          checklist should be raised in any feasibility or producibility reviews.
     Check if the project will involve, use, generate or require any of the following:
                    1.     Radioactive Materials
                    2.     Chemicals Restricted or Targeted for Elimination
                                 Solvents
                                 Acute Toxins
                                 Explosive or Reactive Materials
                                 Oils/Petroleum Products
                                 Hazardous Wastes
                    3.     Chemicals or Processes subject to the Toxic Substance Control
                           Act (TSCA)
                                  Manufacturedllmported Chemicals
                                  New Uses of Chemicals
                                  Significant RisWNew Exposures

 -
p3                  4.     Preliminary Industrial Hygiene Assessment
                                   Airborne Contaminants
                    5.     Fire Risk Potential
                                   Fire-Risk EauiDment
                                   Explosion-disk Equipment or Processes

                    6.     Materials /Processes subject to the Hazard Communication Reqs.
                                   MSDS requirements
                                   Employee Training
                    7.     New, Additional, or Changed Air Emissions
                                  Source
                                  Threshold Consideration
                                  Fuel Buming/Combustion

                    8.     Water Use / Discharge
     -              9.     Geographical Specific Considerations
                                 Unique, Local Regulations
                                 Wetlands, Soil Erosion, Endangered Species
              .     10.    Product Life-Cycle
 \                                 End-of-Life Product Disposition
LJ
                    11.    Production of New Solid Waste
                                                    of
                                             Page 1 3
                                       Exhibit A i
Example: EHS Checklist For New Product introduction & Technical Changes

                                                                                               I


I
1      Planning Stage
    In this stage, plans for implementation are being developed.
    Use this checklist to evaluate the potential EHS impact and to understand any EHS
    requirements of a product or process alternative. All identified issues must be resolved
    before implementing any plans.

              1.     Environmental Control Options
                            Air pollution control strategies & equipment
                            Fuel consewation & efficiency maximization
                            Water pollution control strategies & equipment
                            Chemical & oil storage
                            By-product & waste management
              2.    Toxic Substance Control Act (TSCA)
                            Specific material@) identification
                            Final TSCA review
              3.     Hazard Communication Planning
                            MSDS(s) development plan for materials produced
                            Label@)development plan for materials produced                     i

              4.     Community Right-to-Know
                          Quantification and reporting
                          Potential emergency planning activities
              5.     EHS Requirements
                           Permits, licenses & notification
                                  -
                                 Construction permit
                                  -
                                 Air emissionhater discharge
                                  -
                                 Hazardous waste generation notification/changes
                                  -
                                 Underground tank registration
                                  -
                                 NRC radioactive materials license
                           Chemical inventory review & update
                           Operation:
                                  -
                                 Environmentally sound operating procedures
                                  -
                                 Employee safety procedures
                                  --
                                 Operation and maintenance pian for pollution control
                                 Waste management procedures
                           Monitoring, Analysis, Inspections & Regulatory Reporting
                                  -
                                 Air / water I hazardous waste I industrial hygiene

              6.     Training plan



                                         Page 2 of 3
                                          Exhibit A1

Example: EHS Checklist For New Product Introduction EL Technical Changes
-               7.     Supplier EHS Compliance
                               Prevention of business interruption
                               Partnership / ownership potential liabilities
                8.     Contractor EHS Compliance Assurance
111    Execution Stage
      In this stage, the project is being implemented.
      Use this checklist to ensure all EHS considerations have been addressed prior to the
      start of production.
                1.     Process Design EHS Considerations
                              Air emission/water/waste/employee exposure minimization
                              Raw material storage
                              Chemical storage vessels
                2.     EHS EqUipment
                             Ventilation system
                             Air/water pollution control equipment
                             Hazardous waste storage & handling facility
                             Safety and emergency response equipment
                3.     EHS Administration & Programs
                             Air / Water Permits Obtained
                             Other Licenses Obtained (NRC, Tank Registrations)
                             TSCA Review Findings Implemented
                             Hazard Communication (MSDS(s) received for all materials)
                             Regulatory Reporting Requirements (Right -to-Know)
                             Emergency Response Requirements
                4.     Final Training Planned & Scheduled (Topics and Participants)
                5.     Complete Analysis of Actual EHS Impact During Test Runs
                            Industrial Hygiene Survey & Analysis
                            Noise Survey & Analysis
                            Air Emission Testing
                            Water Discharge Testing
                            Waste Characterization
                            Final Permits & License Review & Verification




                                           Page 3 of 3
3
    EXAMPLE:                                                                                  Exhibit A2



3   GE                                             Chanae Review Form
    Does the proposed change require or modify any of the following:

           Air permit (Volume, chemicalcharacteristics)?-
           Pollutbn control equipment (Capacity 8 treatment type)?   -
           Plant compriance with emission limitations?-


           Permit (Volume, chemical characteristics)?-
           Storm water discharge (Outdoor storage, spill potential)? -
           Pollutioncontrol equipment (Capacity and treatment type)? -


           Character of waste? -
           Generation of new or increasedvolume of waste?
                                              -
                                                            _.


           Opportunitiesfor recycle/re-use?


           Noise - New hearingconservatbn program requirements?-
                   Are engineering controlstudies required?
                               -
           Employee exposure Potential heathkxposure concerns or monitoring practices? -

    Satetv:
                -
           Fire New/modlfiedfire protecilon equipmeWdesign?-
                          -
           Physical safety New/modifiedguards, controls or practices?-
                                          -
           Personal protective equipment New/Wiied employee personal protective equipment? -
           Electrical - New/Wified electrical controkkirin@'design?  -

           Type or quantity of chemicalused in a manner affecting:
                                                      -
                   a: Chemical inventory/use repotting?
                   b Chemical handling/storage/use?   -
    Trelnlna:
           New or additionaltraining (legally required a d o r "Best Practice"?) -

    If the answer to any of the above questions is "YES".has a management action plan been developedto
    address the issue?-
     ll "YES", please attach the management action plan
     If 'NO'. deveb a manamment action plan




3
3
                      '   Chemical Material Procurement & Receiving Policy
 3       Reference B l is an example of a chemical procurement and receiving policy. The policy
         is developed to ensure that:
                 All new chemicals are reviewed and approved by the plant EHS
                 Coordinator prior to procurement
                 All chemical deliveries are screened by receiving against an Approved
                 Chemical List (See Tab C of "How To" Package)

         Getting Started
         Prior to implementing a policy, obtaining a         understanding of in-plant
         procurement and receiving processes is critical. Examples of some key questions to ask
         are :
         Procurement:
                How are chemicals ordered in your plant? (See next page for examples)
                Who orders, and who approves of chemicals ordered?
                What controls exist to ensure EHS approval of new chemicals?
         Receiving:

-.   >           How many ways can chemicals enter your plant? (See next page for examples)
                 Who are the designated receivers? (are they properly trained)
                 When are chemicals delivered and how are they received?
         Once the understanding of current procurement and receiving routines is established; and
         after reviewing sample policy B1,a plant specific policy can be developed and
         implemented.

         How to Implement
         1. Distribute policy to all chemical requesters, receivers and plant EHS coordinator for
            review.
         2. Conduct a training session with all chemical requesters, receivers, and the plant EHS
            coordinator. Key points to discuss include:
                 The need for a chemical procurement policy (EPA I OSHA compliance)
                 Critical definitions
                 Roles and responsibilities
                 Attached exhibits
         3. Assign responsibility to chemical requesters, receivers and the plant EHS coordinator
            for execution of this policy.

3
Critical Success Factors
This policy must be:
         Strongly supported by plant management
         Clearly communicated to all requesters, receivers, & plant EHS
         Simple enough to understand and implement
        Actively used

Lessons Learned I Observations
        A physical inventory will expose numerous unidentified chemicals.

        There are a number of ways chemicals may be procured, including:
            -- Blanket POs
           '   --
               Standing POs
               --
               Petty Cash System
               --
               Personal Credit Cards
               --
               Outside contractors
               --
               Free Samples
               --
               Etc.
        Chemicals may be received through numerous areas, including:
               --
              Designated receiving area@)
               --
              Front entrance of the plant
               --
              Reception area
               --
              Vehicles of outside contractors
               --
              Personal vehicles
               --
              Visitors from other plants
               --
              Any door or entrance in the plant
It is essential that controls exist in both the procurement process and the receiving
process to minimize the risks of chemicals to employees.
1   Reference B1
    Example: Chemical Material Procurement I Receiving Policy
    1. Purpose
       To define a chemical materialprocurement 8 receivingpolicy.
    II. General
       The General EklrIc Company is commltledto complying with all applicable EHS laws and
       regulatbns. This policy ls designed to ensure that 1)All new chemical materials are reviewed
       and approved prior to procurementand to 2) Ensure a safe work environment.
    111. Definitions
       For the purposes of this policy the folbwing definitbns apply:
        --
       A.                        A liquid, gas, s o l i or powder whch in normal use has the potentialto cause a
            health and I or phvsil hazard, or the release of toxics into the environment. This definition also
            Includes any new materials that will be created during the manufacturingprocess, either as
            intermedaes, by-products. or wastes.
            Each chemical must be reviewed by the EHS coordinatorto ensure full compliancewith all regulations
            and guidelines.
       6.                                        - A technical bulletin required by OSHA which contains Information
            about a chemical material reearding its identity, chemical and physical characteristics, health and safety
            data, and precautions necessary for safe handling and use.
            For all chemicals used in day-to-dayproductbn, a Material Safety Data Sheet                      !

       C.
             -
            C e                          e u se B v
                           i a R a e t orl u e -
               h m c lAn empbyee who requestsrbuys a chemical:r
             Procurement of a chemical (newor currently used)
                 New use of an existlrg chemical material
                 Trial samples for testing purposes
                 Outside contractor services
           h m c l An c i e -
                    e ev r
       D. C e i a R employee authorizedto receive chemical shipments entering the plant.
       E.                             -
                                      A listing of approved chemicals authorizedfor use in a plant (See Tab C) -to
            be used as a control reference prior to chemical procurement and receiving. All chemicals on the
            approved list must be found on the TSCA chemicallist.
       F.              - The 'new use" of a chemical material inchdes the folbwing:
            1) Introducing a chemicalmaterial Into a work area which is not on the Approved Chenkal Ust.

            2) lmodudng a dfflerent use of a chemical material in an approved work area using quantilies
               laFger than quantitiesoriginally approved.
       0.                   -
                            QE Goods and Sewices codes used throughout the company to provide useful
            pridng and trend data. The correct GEGS code ( 6 8 mor QGxx)<)O(x) m t be used when
                                                                                 s
            ordering chemicals (contact purchasingdepartmentfor more details)
IV. Responslbliltles


A. Chemical RequesterBuyermust:
    1) Reference the Approved Chemical List to verify that the chemical material being requested is
       approved for the plant.
   2) Complete a Material Approval Form for any new chemical (see 81.A) and submit it along with the
      chemical material MSDS to plant EHS Coordinatorsprbr to prowremenl.
    3) Requester must ensure that area operators are trained in the proper use and handling of the chemical
       procured.
   4) Ensure that when outside contractors are engaged to work in the plant, the Local Engineer provides a
                                                                      m&
      copy of “General Instructionto Contractors”(see 81 .B) for review       arrival at the plant. The
      contractor checklist (see B1 .C) must be reviewed with the wntrador and filled out pripcip the start of
      work. This checklist must be submitted to the plant EHS Coordinator, along with any MSDSs supplied
      by the contractor.

  The requester is responsible for ensuring that new chemlcais are
  ordered with EHS review and approval!
  To minimize your risk, order chemicals In quantities that you need. Do
  not accumulate a year’s worth of Inventory.

E. Plant EHS Manager must:
    1 ) Execute the materialapproval process and communicate approval or rejeclionof the chemical
        Request for Material (RFM) I purchase mquisitbn.
   2) Add newly approvedchemical materialsl the Approved Chemical List and distribute updates as
                                           o
      necessaryto requestersand receivers.
   3) Advise requesters and receivers on newly approvedchemical handling and disposal requirements.
   4) Maintainthe MSDS Master Flle and verily that work area MSDS binders are kept current.

   5) Review all RFMs I purchase requisitions (optional, based on plant volume).


c. Chemical Receiversmust:
    1) Receive all chemical shipmentsto verily that they are on the Approved Chemical Ust, properly
       labeled, and securely packaged.
   2) Quarantine all unapproved shlpmenb - Chemicals not on the Approved Chemical List and execute
      disposition routines (see B1.D)

  Receivers must screen all chemical deliveries agalnst the Approved
  Chemical List
      V. Restrlcted Procurement Methods

        A. Chemical material purchases are      to be made using credit cards for reimbursementon expense
           accounts.
        8. Chemicalmaterialsa r e m t o be routinely purchased using petty cash or confirmingpurchase orders.
           In the event that an emergency situation requires purchase using petty cash or confirming PO, the
           purchaser m t pmvide a copy of the MSDS to plant EHS Coordinator for review and approval prior to
                         s
           procurement.
      Vi. Other Related Chemical Materlal Requlrements

        A. Suppliers are prohibitedfrom bringing chemicals on-site for trial purposeswithout prior approvalfrom
                                                    ra
           the plant EHS Coordinator. Redpiefts of til materials should submit MaterialApproval Forms and
           appmpriate MSDSs to plant EHS Coordinator.


        B. Contractors are prohibitedfrom bringing chemicals on-site without receivingprior approval from plant
           EHS Coordinator. Engineers requestingcontractor sewices m t verify that MSDSs have been
                                                                           s
           furnished ptior to work start up. Additionally, arrangements rmst be made for the removal of chemicals
           brought on-site by contractors.

-3,     C. GE employees, lnduding those from other plants, are not permittedto bring chemical materials on-site
           unless they are on the Approved Chemical Ust. Plant EHS Coordinatorapproval must be obtained via
          the Material Approval Form and an MSDS prior to bringingthe chemicalon-site.

        D. MSDSs must also be pmvidedfor free chemical samples.




‘3
         B1.A Example
-3                                     Material Approval Form
                                 The folkwing information must be provided prior to the
                                    procurementof new materials in your work area
                                Obtain MSDS, attach to this form and submit to EHS
     ~




         Date
         Product Manufacturer
     Product. Name
     Supplier
     Product Use
     Quantity to be used (ie Ibs., gals.,)                          1 month               IYr
     Maximum quantity on site at any time
     How will it be used Istored?
     Where will it be used Istored?

-)   Does the operation already use a chemical that can perform this function?
     Will this replace existing material?                  Yes                   No
           If yes, what material is being replaced?
           Will replaced material need to be disposed of?                      Yes              No




     EHS Approval Given?                  Yes                  No

     Hazardous I Toxic Material?
     Environmental, Health 81 Safety Requirements


     EHS Approval Signature                                                Date
     Added to Approved Chemical List?                               Yes      Date
B1.B
                          s to Discuss

       These instructions apply to all contractors who perform work on General
Electric Company premises. Contractors are required to comply with these
instructions as a condition of the contracts placed with them.

1. All OSHA and EPA standards are applicable and shall be complied with when
   working on GE property.

2. All contractors and subcontractors must have valid Workman Compensation and
   Certificates of Insurance prior to starting work.
3. Contractors must furnish an MSDS for each chemicalkompoundkubstance
   brought into the plant to the contracting engineer.
4. Prior to the start of work, safety precautions shall be discussed with and approved
   by the Plant Engineer who contracted the work and the plant EHS manager.
5. Appropriate safety protection must be wom at all times when working on GE
   property
6. When work is performed in confined spaces, OSHA's confined space procedures
   will be followed. Safety equipment and training are mandatory.
7. Contractors will provide all necessary training, Personal Protection Equipment,
   monitoring devices, safety equipment and attendant(s). Additionally, contractors
   will supply documentation on training of its employees prior to bringing them on
   site.
8. Contractors must handle any wastes or residues in accordance with
   environmental regulations. Coordination with the EHS specialist is required.
9. Contractors may not use GE tools, moving equipment, or stock room supplies to
   perform work without prior approval of the Project Engineer.
10. "No smoking" areas are clearly marked by signs. Smoking is restricted to
   designated areas only.



Having read and understanding the above instructions, I                t

representing                         , agree to comply with the requirements
stated.
Date
      B1.C Example
7                                 v
      GE Project Engineers overseeing work efforts must review the questions below
      with the contractor and answer "Yes" prior to the start of work.


      Contractor has:
              1.    Reviewed General Instructionsto Contractors and informed
                    employees assigned to the work-site of requirements.

              2.    Provided applicable MSDSs for products or processes contractor
                    will use during the project.

              3.    Received copies of applicable MSDSs for chemicals that
                    contractor's employees are likely to encounter at the work-site.

              4.    Been informed of protective equipment & safety precaution
                    requirements.

 -1
c -
              5.    Been informed of daily storage practices to be observed (clean-up,
                    proper storage of equipment, proper removal of waste and
                    materials).




                         Contractor
      Signature:

      Date:
B1.D
                                Receiving Procedure

   Chemicals should be received through a limited number of controlled points
(designated receiving areas). When a chemical arrives on-site, receivers must verify that
the chemical is an approved chemical (ie. cross-check with Approved Chemical List).
This screen ensures that no unauthorized chemicals enter the plant.
    In the event an unauthorized chemical material (one not on the Approved Chemical
List) is delivered, the following steps will be taken:
   1) .The chemical will be received and quarantined temporarily in a designated
     storage area.
   2) The receiver will determine who ordered the chemical and notify of arrival.
   3) The requester must call the supplier and obtain an MSDS. Additionally, this
     individual must review the MSDS with plant EHS Coordinator prior to moving the
     chemical into the plant.
   4) The requester will show the receiver a copy of the MSDS and also the completed        }
     Material Approval Form. The receiver can then deliver the chemical.
3                         Conductin A Physical lnvento
                                          1
                       And Creating n Approved Chemica List            r
            Two of the first steps needed to improve chemical management are conducting a
    physical inventory and developing an Approved Chemical List. The physical inventory is a
    'sweep' of the entire plant, recording every chemical on the premises. The inventory
    provides valuable insight into the effectiveness of the current chemical management routines
    & controls by identifying issues which are the result of breakdowns in the chemical
    management process.
            The three end products of a successful inventory are a list of issues in the plant, a list
    of potential process breakdowns and an approved chemical list.
           The list of issues will help the plant become compliant for a point in time. For example,
    labeling all unlabeled containers in a plant will bring that plant into compliance for only that
    moment. Developing a process to ensure that unlabeled containers are consistently labeled
    will keep the plant in compliance.
            Listing potential process breakdowns will help keep the plant in compliance on an
    ongoing basis. Issues such as missing MSDS's and unlabeled containers may be used to
    identify potential breakdowns. For example, if many chemical samples in the plant are
    missing MSDS's, a vendor policy prohibiting chemical samples on site without prior EHS
    approval probably needs strengthening.
           The information compiled during the physical inventory is used to construct an
    Approved Chemical List. The Approved Chemical List is used to prevent unapproved
    chemicals from entering the plant and is the primary control for the chemical procurement
    and receiving areas (See Chemical Procurement & Receiving Policy Tab B).-
             The physical inventory is very useful if done thoroughly. Performing an inventory of
    chemicals requires a number of resources and a substantial time commitment, usually taking
    5 - 10 hours to complete, depending on plant size, plant complexity and staffing. This section
    of the binder will be helpful in planning and performing a physical inventory.

    A.    Conducting A Physical Inventory
         Purpose
         A physical inventory provides an opportunity to ensure:
                            MSDS file is complete
                            Secondary containers are properly labeled
                            Accurate SARA 312/313 reporting
                            Heightened employee awareness of chemical management
                            Elimination of unnecessary/obsolete chemicals
                            Accurate baseline for Approved Chemical List
               Conductin A Physical lnvento
                               1
            And Creating n Approved Chemica List           7
Getting Started
1.    Discuss the inventory process with EHS Manager and Plant Manager
      a. Decide who will help with the inventory
      b. Discuss how many people will participate and how the teams will be
         broken up (5 Team members for every lOOK sq. ft of manufacturing
         floor space is a good benchmark)
      c. Decide who will review which areas
      d. Decide what consistent format will be used to record chemicals found
           in the plant
      e. Agree on who will oversee the overall effort

2.    Communicate to the individuals participating in the inventory
      a. Ensure their supervisors understand the time commitment involved
      b. Explain the intent and timing of the inventory to the participants
3.    Create a standard inventory form. (See Exhibit C1 for an example)
4.    Leverage any existing chemical inventory lists or a list of purchased
      chemicals as a starting point for each area
5.    Gather materials needed to conduct the inventory
      a. Ensure that clipboards, radios (walkie talkies), blank chemical lists and
         plant layouts, with areas responsible, are available
      b. Order extra secondary container labels, you may need preprinted
         labels for common items (Le. oils and lubricants)
      c. Obtain carts or boxes to collect unwanted and/or obsolete chemicals
         (see item #7)
6.    Make arrangements for a pre-inventory meeting, a status update and a
      debrief session
      a. Set up a pre-inventory and lunch time meeting place (For team
          meetings)
      b. Arrange for refreshments to be brought in for the pre-inventory andlor
         lunch time meetings
      c. Make arrangements with the EHS manager and the Plant Manager to
         have a debrief session after the inventory
7.    Establish a procedure to collect unwanted and/or obsolete chemicals
      a. Set aside a place in each shop to collect chemicals for disposal
      b. Explain the process to individuals helping with the inventory
      c. Notify supervisors of the process and review chemicals with them prior
         to disposal
3                   Conductin A Physical lnvento
                                   1
                 And Creating n Approved Chemfca List          r
    Getting Started (Cont.)

    8.     Arrange for characterization(1dentification)of unknown chemicals prior to
           disposal
    9.     Plan for disposal costs of unwanted and obsolete chemicals that are
           identified during the physical inventory (Lab-packing)
    10.    Ensure that all inventory participants have sufficient HAZCOM and Health
           & Safety training

    11.    Arrange for plant-wide communications
           a. Explain the objective of the inventory
           b. Describe the work involved and timing of the inventory
           c. Consider special communications and meetings in unionized plants
3
                      Conductin A Physical lnvento
                                      1
                   And Creating n Approved Chemica List           7
    Pre-Inventory Meetlng Steps
         Champion and owners of the inventory process must establish inventory
         procedures and review them with the participants:
    1.       Define a chemical for participants (See Exhibit C2 for an example)
             a Walk through the plant with the team or bring chemicals to the
                 meeting room to ensure that the participants understand which items
                 need MSDS's and which items do not (Le. rolled steel, grinding wheels
                 and adhesives are usually required to have MSDS's)
    2.       Explain to participants that they must "sweep" through the plant (look in
             basements, corners, file cabinets, outside grounds etc....)
             a. Ensure tha? participants use discretion and seek permission before
                 searching through personal tool boxes (Seek guidance of Plant
                 Management on how to handle)
             b. Identify janitorial closets, outside storage sheds and other obscure
                areas for the participants
    3.       Show participants how to properly label any unlabeled secondary
             containers
             a. Participants should not label chemicals which they cannot identify with
                 certainty
             b. Instruct the participants to seek the advice of inventory champions
                when questions arise
    4.       Indicate guidelines for identifying improper container usage (Le. flammable
             items stored in coffee cans instead of a flammable container)
    5.       Describe the process for bringing unknown/obsolete chemicals to the
             predetermined location for disposal




3
               Conductin A Physical lnvento
                              1
            And Creating n Approved Chemica List          7
Pre-Inventory Meeting Steps (Cont.)

6.    Explain how the inventory forms should be filled out.
      a. Describe the necessary fields to be filled out (i.e. trade name,
         manufacturer, location)
      b. Break down the plant into areas for recording chemical locations on the
         inventory forms and make sure the areas are consistent with the
         MSDS area listings
      c. Bring a box of chemicals into the conference room or walk the group
         through the plant and point out chemical manufacturer names and
         trade names to ensure that data is recorded in a consistent manner
                         ..
      d.
                               r          e          c            o       p

7.    Ask team members to record issues identified on the inventory forms so
      they may be resolved quickly (Le. unlabeled containers, Hazardous Waste
      issues)
8.    Agree on a place to meet for lunch and to have the 'status update' session
      with the inventory team                                                      i
               Conductln A Physical lnvento
                               B
            And Creating n Approved Chemica List           7
Inventory Execution Steps
1.    Do a 'walk-through' of each area before letting team members go on their
      own
      a Help the team members develop an approach for covering their area
      b. Ensure that each team member knows their area's boundaries

2.    During the inventory, walk from area to area, answering questions and
      ensuring that things are moving along smoothly
3.    Have a status update with the team at lunchtime to discuss how the
      inventory is coming along
4.    Check each area as it is completed
      a. Do a walk-through and ensure that the entire area was covered
         properly
      b. Review the completed inventory forms, make sure each sheet has
          the participant's name and the writing is legible
      c. Quickly review issues and chemicals listed on inventory forms to seek
         clarification where needed
      d. Redeploy team members to unfinished areas

5.    After all areas are complete, do a walk-through and debrief session with
      the EHS Manager and the Plant Manager
6.    Ensure that the person responsible for putting the data into a usable format
      understands the necessary steps and timing (See "Steps In Creating An
      Approved Chemical List")
                  Conductin A Physical lnvento
                                 1
               And Creating n Approved Chemica List           7
B. Steps In Creating An Approved Chemical List


  1.     Compare the list of chemicals purchased to the inventory list and
         investigate discrepancies
         a. Chemicals on the purchased list, but not on the inventory list may
             indicate that an area was not covered in the physical inventory
         b. Chemicals on the inventory list which cannot be found on the
             purchased list may indicate that the chemicals are no longer used or
             the chemicals are entering the plant "outside the purchasing system"
  2.     Divide the inventory data into: Issues (Le. unlabeled containers, safety
         issues), Chemicals no longer needed to be disposed of, and Chemicals
         being used by the plant
         a. Issues should be reviewed, used for root cause analysis and
             resolved
         b. Unwanted chemicals should be collected and lab-packed for disposal;
             These chemicals must be completely eliminated from the plant and
             MSDS's must be archived
         c. The remaining chemicals will be used as the starting point for the
             Approved Chemical List
  3.     Ensure that all items in the plant which are required to have MSDS's were
         covered in the inventory (i.e. process intermediates)
  4.     Reconcile the results of the above chemical list against the MSDS list
  5.     Obtain all missing MSDS's to update chemical records
  6.     Determine whether material should be "approved"
         a. Review chemicals against all regulations (EPCRA, TSCA, SARA ...)
         b. Review chemicals against a business restricted chemical list (if
             available)
  7.     Develop the Approved Chemical List
  8.     Provide copies of this list to all requesters, buyers, design engineers,
         receiving personnel and other pertinent individuals to create awareness
         ane prevent unapproved chemicals from entering the plant
  9.     Establish methods to update and communicate changes
El
21
11
01
6
e




3
‘3
         Chemical Definition and MSDS Guidelines

-A                          : a liquid, gas, solid or powder which in normal use has
the potential to cause a health and or physical hazard, or the release of toxics into the
environment. This definition also includes any new materials that will be created
during the manufacturing process, either as intermediates, by-products, or wastes.
As a general "rule of thumb", an MSDS is required for any chemical used directly or
indirectly in the production or support processes.
This would typically include:
        Raw materials
        Production supplies (oils)
        Maintenance supplies (welding rods, pipe dopes)
        Janitorial supplies
An MSDS is opt required for:
      "Consumer" or "household products" whose packaging and
      concentrations are similar to that used by the general public
      Chemicals used in the same manner as a normal consumer
      and have a duration/frequency of exposure not greater than
      exposures experienced by a consumer.
      Items that will not undergo any type of modification (Le. Toner).

For all products that are of different concentrations, or packaged in substantially larger
containers (Le.. 55 gallon drums), an MSDS is required.
 I always better to err on the slde of caution. When In doubt, obtaln an
Its
MSDSl
If there are any questions on definition or requirements, please contact your EHS
specialist.

Lessons Learned:
 Many people when asked, cannot clearly define a chemical - Ail employees must
 clearly understand this definition
 There are many more chemicals in your plant than you would anticipate
 Communication of this chemical definition, and up-front planning of the inventory are
 critical to SUCCBSS
     c
Chemlcal Management                                                     Chemical Handling Team Over view          -      W




What I A Chemical Handling Team? *
     s
     A group of employees trained in the movement of all chemicals used in the plant


 A Chemical Handling Team Reduces Exposure By:
    Minimizing number of employees handling chemicals.
    Ensuring spill clean up and reporting
    Preventing chemical distribution to "unauthorized people"
    Ensuring chemicals are distributed in approved, labeled containers

                                          s
    Implementing A Chemical Handling Team I A Three Step Process
     1) Determine the current process
     2) Evaluate the alternatives
     3) Select the team

.    A "Chemical Handling Team" is one possible method to confrol the in-plant distribution of chemic&. It is not your only
     option...many options exist to control chemical flow. You may not choose to implement a "Chemical Handling Team",
     but you must ensum tha! the control concepts described here are implemented in some fashion.
Chemical Manaaement                                           Team Implementation


 Step 1. Determine The Current Process

    Answer The Following Questions For Common Chemicals:
        How do chemicals move from receiving to usage and to final disposal?
        Where are the primary chemical storage areas?
       *Are there any interim storage or holding areas? Where?
        Who is responsible for chemical movements?
        Where are the chemicals currently used (in relation to storage area)?
        What is the volume of chemicals used in a typical day?
        How much is currently on hand?
        How are chemical wastes captured?
        How are chemical wastes stored?
    Use These Tools To Help Answer The Above Questions:
        Process mapping
        Physical plant map
        Interview people in process (i.e. operators)
        Current chemical handlers
        Visu-alfloor review/walk through
        Existing chemical inventory
       c                                       /I.
                                               'u-
                                               '     i




Chemical Management                                          Team lmp/ementation ICont'd)

Step 2. Evaluate The Optimal Alternative
   An Integrated Chemical Supplier (See Tab E):
     - Minimizes inventory on hand
     - Eliminates need for multiple storage areas
     - Tracks chemical usage
     - Eliminates excess chemical movement

  Or

   A Chemical Handling Team
    - Dedicates a limited number of trained employees chemical and waste movement
    - Allows for centralized and consolidated chemical and waste storage areas
    - Eliminates the need for all interim storage and holding areas
    - Prevents distribution of chemicals to unauthorized areas
  Or

   Any other altemative that allows you to answer 'Yes" to in-plant control questions
   on the assessment checklist
Chemical Management                                     Team Implementation (Cont'd)



 Step 3. Select The Team
  Individuals who have demonstrated initiative and ability to follow procedures
  Keep number of handlers to a minimum
  Individuals who are comfortable with use of protective equipment




 Elements Of A Successful Chemical Handling Team
   Team mission is communicated to all personnel
   Complete employee understanding of the process
   Minimum number of handlers
   Well trained individuals
   Chemical handling is the team members primary responsibility
       (3,                                                                      u
Chemical Handling                                                                                         Process Map

  Example Of How Process Mapping Can Identify Opportunities
                                                                                                        Legend




                                                                   4I       Process
                                                                            Staging
                                                                             Area
                                                                                       I----
                                                                                       I
                                                                                               1'
                                                                                                I

                                                                                                I



          I
          I                             I
                                        I
                Receiver                I
                                        I
          I
          I
                                 ,,,;,.
                                o....,*I
                                nwwirwi I                      I



                                                                   ..
          I                             I                  I                                                     1   1
           I                            I              I                    0                                    1   1
           I                            I          I                   00            From                        1   1
           I                            I         8
                                                                   0                Process                      1   1




                                                                                           Designated
                      Designated                                                            Handlers
                       Handler

                               Process Mapping Will Help Identify:
                                   Where chemicals are being moved
                                   Number of people currently moving chemicals
                                   Where transferso chemicals are occurring
                                                   f
                                   Whether handlers are trained
                                   Whether there are excess chemical inventories on floor
                                   Whether there are obsolete chemicals present on shop floor
GE Pmprietaty
F S l a r n ~     Hndw T   m
Chemical Management                                                       Duties Example


 Example Of A Chemical Handler's Duties

                    OIderlna                            ReDlenishmentlDistribution
   Assesses quantities on hand                Receives chemical request(cards and/or phone)
   Develops order report                      Logs out quantity of chemicals
   Orders chemicals                           Delivers chemicals
   Logs POs from order reports                Picks up used chemicals and containers
                                              Brings used chemicals and containers to storage
                                              Dispense chemicals and labels



                RecehrinalStoraae                            Diswsal
   Receives chemicals from vendor truck       Logs waste in
   Verifies quantity and accuracy             Segregates and stores wastes accordingly
   Unloads vendor truck to storage location   Checks for leaks
   Log in chemicals                           Moves barrels to staging area for shipment
   Insures compliance with DOT Requirements   Ensure proper truck placarding
   Inspect storage areas                      Loads truck with barrels
   Maintain spill containment systems         Insure compliance with DOT Requirement
                                              Signs shipping papers
                                              Logs out waste barrels/ remove from log
                                              Sends documentation to EHS
    c                                                                                     L)
Chemical Management                                                  Integrated Supplier Concept

        Currently Deal With Many Suppliers For Chemicals                   ...


                                  $                       Supplier

                                                          Supplier

                                                          Supplier




        Integrated Supplier Reduces Number Of Supplier Contacts To One



                         MATERIALS 6
                         INFORYATlON
                                                                     k@
                                                                     t$
                                                                                 Supplier


                                                                                 Supplier
                                                                                            1
                                           Integrated Supplier   I           I              i

                                                                 p4
                                                                  -              Supplier   I
                                       I                                     u
                                                                                 Supplier
,
                            Integrated Chemical Supplier
3   Deflnltlon
    A supplier dedicated to providing complete Chemical Management services from
    cradle to grave.

    Advantages:
              Reducedtotal c sot
              Improved cycle time
              Consistent quality standard
              Reduced potential for compliance exposure
              Improvedemployee safety
              Facilitates regulatory reporting
              Reduced number of chemical suppliers


    Services Offered Include:
          .       -   Purchasing, receiving, issuing of all chemicals
                  -   Just-In-Time inventory control
          .       -   On-site technical expertise
                  -   Research for safer chemicals, processes and procedures
          .       -   Inspection for proper product, labeling, and packaging
                  -   Evaluation of specification changes
          .       -- Waste disposal capabilities
                     Data tracking facilitates government reporting process
                   - Maintenance of Material Safety Data Sheets
                  -   Employee chemical training
              Integrated Chemical Supplier (Continued)

Selection Crlteria:
     .      -
            SR
             - MSDS maintenance system
             - Utilizes available new technology
             - Assists in auditing procedures
             - Assists in training
     .       - Strong financials
             - Cost effective supplier
     .       - Meets quality standards of GE (Government if Applicable)
             - Maintains material certification for a Deriod of time
             - Uses only GE approved suppliers
     .      - Capabilities to track and maintain a database of GE products
     - Inventory control system for usage reporting
            - Vendors which have electronic purchasing (EDI) capabilities
     .       - Capabilities to furnish labor, equipment, and material in order to    1
         perform necessary work
             - Authorized to work on military contracts and fulfill all government
                regulations


  Quantification:

    Quantify the current process for potential savings
             -What chemicals are purchased?
             -What is the total volume, dollars and weight?
             -Where are the chemicals stored (warehouse costs)?
             --
              How much is spent in waste disposal?
               How many people are involved in govemment reporting?
              -How much was paid in regulatory fines?

     Understand the "soft" savings such as improved moral, less employee health
      risk, and so on.
    L                                                                    d
Chemical Management                                Integrated Supplier Checklist

            Criteria For Selectina An lntearated SuDplier
                                               Cost / Benefit Analvsis:
                                           Integrated Supplier Worksheet
  Element           AssumDtions I Notes I Questions                                                   Quantification
EHS Reporting     How much time is spent doing regulatory reporting?
                  How much time on SARA reporting?
                  What are the reporting thresholds for each chemical? (volume)
                  Would reducing inventories to a two week supply put any chemicals below the
                  reporting threshold?
                  How much time is spent tracking chemicals on site?
                  What is an average EHS salary to use for the quantification?
                  Attach person-hours spent to each of these items and calculate the amount of time
                  saved by eliminating the work.

Material          How much time is being spent on recertifying chemicals due to expired shelf life?
qecertification   What is an average salary?
                  How much can be saved in recertification?


Regulation /      How much time is being spent to maintain the MSDS system?
rracking          Are they keeping paper copies? How many people are involved and how much of
                  their time do they spend doing this?
                  How much time do they spend scanning or inputting MSDSs?
                  What is an average salary?
                  How much will be saved by having an integrated supplier maintain the system?


Floor Space       Where are chemicals wrrently being stored? How much is in each location?
                  (both volume and dollars)
                  Ask the finance person what is the rate to appty per square foot
                  Using an integrated supplier should reduce inventory so most of this cost will go
                  away.
     '
     c                                                                                                  d
                                 Integrated Supplier Quantification

 Element           hWQ!Dt ions / Notes I Question3                                                auantification
Waste          What is the total $ volume of labpack waste that they disposed of in 1991?
               Include here the amount of waste that gets disposed due to:
               - Expiration of self life
               - Excessive order quantity due to order size
                                                             -
               Not all o this will go away so take a percentage 50% savings seems standard
                       f

Inventory I    Ask the finance person for the material overhead rate
Sourcing I.    Ask purchasing for the dollar volume of chemical expenses in 1991
Inspection
Stocking       How many people are there in the stocking function? How many of hem stock
               chemicals? Determine how much of their time they think they sper a stocking
               chemicals.
               What is the average salary?

               Ask purchasing what was the total $ of chemicals purchased in 1991
               You can only use an estimated volume discount percentage of 10% (make sure you
               footnott) that this is based on experience in other GE businesses)


Repackaging    Determine if any chemicals are shipped overseas. How are these chemicals handled
for Overseas   before they are shipped? How many people are involved and how mdch of their time
               do they spend here.
               What is an average salary?
                                            Integrated Supplier Quantification

   Element              AssumDtions I Notes I Questiong                                                      Quantification
I
Sourcing How many people in sourcing spend time ordering chemicals?
         What is the percentage of their time they spend doing this? And all related activities ...
         What is an average salary?




                                                                                           TOTAL SAVINGS =



                       . . For Qa .. .
                       idelines u-
                    * Always be realistic

                      Footnote any assumptions
                      There may be more categories than on this list, and all of these many not apply
                      Take a first pass at some of this - don't spend alot of time - and then get a cross
                      functional team together and let them hash it out. Assign people to different
                      elements of the quantification and let them get the numbers.
                I     Ask the team to come up with new elements to the quantification.
                      Document the soR costs that you find. E.g. suppliers shipping chemicals on-site but
                      we don't take ownership of them until we use them.
                                                                       L/                                                 Li
         (i
 GEA ,emical Management                                                                                       CMS Case Study
   Why Integrated Supplier?                         ...
            :tnemnorivnE-                             Long cyde, Highly Regulated. Government Business


                     :-                         Shrinking Business, Aerospace RestWuring

                                                     EHS a da patt of the business, Operations manager with a Mgh degree of
                                                            "
                                                        focus on EHS




                                ..
                        w            e           r chemicals and chemical handling processes
                        I                                               -
                                 Tried disitibutors twice beforeand falted Too much too quickly, Non-chemical expertise
                                 EHS Workout session in 1990 concluded to try integrated supplier concept for chemicals




                                Right Players In The Right Environment Set The Stage
                            ~




GEA:CMS Case Study
 GEA Chemical Management                                                                                CMS Case Study

               Historv 81Status:
                     1991: Hired EHS Buyer To Investigate Options
                           Generate Vision And Statement Of Work
                           Detailed Request For Proposal Sent To 2 Companies
                     1992:Awarded Contract To Chemical Management Systems, Inc. (CMS)
                     Current: CMS Handling Approximately 200 Chemicals
                     By 8 9 : CMS Handling Approximately 4,000 Chemicals
                         /2
                     Going Forward: Bring Other GEAerospace Businesses Into The Process
                           Roll Integrated Supplier Concept For Chemicals Out To Other GE Businesses



               OnaOina SaVinaS: (Syracuse, Binghamton,
                     EHS                                                           $20 1,000
                     Material Recerlifications                                      $1 8,200
                     Regulatioflracking                                            $553,000
                     Floor Space                                                    $15,600
                     Waste Reduction                                               $323.800
                                                                                   $21 6,000
                     Stocking    ‘                       1 head
                                                         4 sites, (see calc.)
                                                                                    $30.000
                                                                                   $207,000
                     Volume Discounts
                 ’   Repackaging for Overseas            2 heads                   $134,000
                 f


                                                                TOTAL           $1,698,600     (less CMS costs)
                                          .              .
                                                         :

               Other Savinas:        i   Re;ducediiabliry ( c a t ami&”
                                         Reduced Workstation Stock



                           Significant Dollar Savings - Both Hard And Soft

                                                                     v
                                                                                                                  d
GEA.CMS CakStudy 2
 GEA Chemical Management                                                            Integrated Supplier Savings
   Current Priclng Under CMS Resulting From Decreased Supplier Chain and Volume Discounts
                                             -
            Top 15 most widely used chemicals represents appmx. 50% of total 1991 dollars
            Very conservative estimate
            Amounts are doNan3 per pwnd


             MATERlAL
             Genesohr D
                                                 S PRICING
                                              4.01
                                                                  v      3.45                  14
             Genesdv DE                       4.01                       3.45                  14
             Genesohr DM                      2.74                                             10
             Genesohr DMS                     3.96                                             15
             111 Ttkhlor                      1.77                                             33
             Mineral S i is
                      prt                     2.24                                                5
             Anti Foam Emulsion               6.05                       5.75                     5
             Acetone                          3.82                       3.63                     5
             Citric Add                                                  1.06                     5
             Isopropyl Alcohol                                           3.46                     5
             Hydrofluoric Add                                            1.05                     5
             Fluoboric Add                    1.32                       1.25                     5
             Toluene               I          2.53                       2.40                     5
             VM & P Naptha                    2.31                       2.20                     5
             MEK    8                         4.55                       4.32                     5
                    I



                                                     AVERAGE % SAVINGS ON THESE PARTS: 9%


    If savings am extrapolated across total 1991 orders of $2.3MM (4 sites) ==>             $207,000 SaVhgS



                                                                                              I
                                                                                      ~




                                Savings Potentially Increase Further
                            With New Businesses Being Added To Process
GEA:CMS Saulngs by Chem
   L                                   I

                                       'b                                 d
Chemical Management                                     One-For-One Replacement


         s
    What I A "One-For-One" Chemical / Waste Replacement Process?

          A chemical must be exhausted before it is replaced
           (exchange an empty container for a full container)

    "One-For-One" Replacement Ensures That:
            Chemical inventory on plant floor is minimized
            Usage and disposal is tracked
            Containers are approved and properly labeled
            Fixed order / release quantities are used
            Temperature / Pressure sensitive risk is minimized
            Hazardous containers are properly disposed

    Critical Success Factors
             Chemicals must be delivered on same day that they are promised
             Should be implemented concurrently with chemical handling team
             Define maximum / minimum use quantities
               "One-For-One" Replacement Guideline

Getting Started
  Prior to implementing a "One-For-One" replacement system, it is important to
  understand the current manufacturing and chemical distribution processes. Questions
  to heighten process awareness include:
   Has chemical usage been quantified for all production stations?
   How are chemical inventory levels currently monitored or controlled?
   How many people are involved in the chemical distribution process?
  Once these questions have been answered, implementation can begin...

How to Implement
  Step 1.   Determine which operations a "One-For-One" replacement system will
            apply. The first candidates for "One-For-One" replacement should be
            hazardous chemicals.
  Step 2.   For the operations targeted, understand current usage requirements,
            and which employees are involved in the processes.
  Step 3.   Analyze inventory on hand and required order quantities. Need to
            ensure that appropriate inventory levels are maintained.
  Step 4.   Educate and train all employees who will use "One-For-One"
            replacement routines. Clearly establish roles and responsibilities, and
            communicate the benefits of this system.
  Step 5.   Remove all excess inventory off the floor. Chemicals must be
            distributed out of a central area.
  Step 6.   Implement "One-For-One" replacement routines
            .
       6                                               7


   LJ
Chemical Handling
                                                       LL)
                                                                                          d
                                                             Example: One-For-One Replac ment



 Here Is How A Typical "One-For-One" Replacement Works                  ...

   I   --   No replenishment required   p- - - - ,No
                                         -
                                                 I
   I
   '
                        Request
                        Chemical




  Elements Of A Successful "One-For-One" Replacement Process:
                      Chemicals must be delivered on the same day they are requested
                      Should be implemented concurrently with chemical handling process
c




     "Cradle To Grave" Ownership & Training

    Ownership Overview
    Employee Training Tracking System (Example)
   L                                     1
                                          1
                                          u                                      LI
Chemical Manaaement                                                        Ownership

  What is Cradle to Grave Ownership?
     Accountability for every chemical in the plant from receiving to disposal


  Ownership Ensures That:
        Chemicals are tracked from receiving to disposal
        All chemicals properly enter the plant
        Employees are trained to handle chemicals
        Waste and obsolete chemicals are disposed correctly



  Who has Ownership?
       Individuals with overall accountability for specific processes or areas
       Everyone who handles a chemical




                        Ownership Will Drive Compliance!          I
3




'3
3                    Cradle to Grave Ownership

    Steps in Establishing Ownership:
    1. Communicate the need for ownership and the associated benefits
    2. Select individuals with responsibility / accountability for s ecific
                                                                   8
       processes or areas in the facility (examples might inclu e MSOs,
       area or process engineers, floor supervisors etc...)
    3. Select and then train owners on their specific responsibilities (i.e.):
            Ensure all chemicals are tracked
            Ensure chemicals are fully documented (MSDS)
            Ensure all employees are trained
            Ensure distribution and disposal procedures are established
    4. Develop and communicate specific measurements
    5. Reinforce measurements on an ongoing basis (hold owners
       accountable)
    6. For any issues that arise ensure that owners are responsible for
       taking appropriate corrective action
               Employee Training "Tracking" System


General
  A great deal of training is required for employees to work in a safe environment.
  This training includes hazardous communication (HAZCOM), job related (forklift,
  drill press, etc.), compliance, and testing (physicals, exposure, etc.) training. Not
  many employees will need to have all the training offered, but it is important to have
  all employees properly trained in both their specific job responsibilities, and work
  areas.

Purpose
  The purpose of this section is to offer some help in establishing an employee
  training tracking system. The system should be designed to:
   Document training requirements for each job classification
                                    -
   Track employee training history both initial and refresher training
   Provide flagging mechanism for employees who require specific training before
   working in certain areas

Benefits
    Comply with OSHA requirement to manage employee training
    Improve employee safety
    Provide a safe environment
    Reduce workman's compensation claims & premiums
    Reduce number of OSHA recordables
                     Employee Training "Tracking" System

 -)    HOW TO   implement
         Step 1.   Ensure complete documentation for each job classification
         Step 2.   Complete safety analysis for each job classification to assess employee
                   training requirements
         Step 3.   Complete work area safety analysis for each plant area to assess special
                   training requirements
         Step 4.   Establish a database of all employees, and the training they have
                            -
                   received Include information such as the type, frequency, and recency
                   of training received
         Step 5.   Reconale each employee's training history with current training
                   requirements
         Step 6.   Obtain or create the course materials for all levels of training required
         Step 7.   Communicate to all employees training requirements for each specific
                   job and work area
         Step 8.   Establish a training schedule to include all necessary courses
 :Is
.-       Step 9.   Establish a goal (date) by which all employees must have taken training
                   specific to their work area
         Step 10. Update training database as employees take courses
         Step 11. Develop training database ability to flag training requirements when
                  employees switch jobs or move to a different work area
         Step 12. Communicate new training requirements to these employees as
                  appropriate

       Critical Success Factors
         1.        New hires and temporary employees must take all applicable training
                   bafpre commencing their assigned duties in the plant

         2.        Key aspects of training must be reinforced on a regular basis.

         3.        Training responsibilities must not rest alone with the EHS coordinator.
                   Plant leaders (Plant Mgr, MSO, shift leaders) must be actively involved!
         4.        Keep the training as simple and interesting as possible.
3
3
     Larm                     Detinltion
7    Approved Chemical List   A listing of approved chemicals authorized for use the
                              plant. It is to be used as a control reference prior to
                              chemical procurement and receiving.
     Assessment Checklist     A tool used to identify potential compliance exposures
                               Questions to pinpoint routine and control breakdowns
     CEP                      Corporate Environmental Programs (Steve Ramsey's
                              Organization)
     CAS                      Corporate Audit Staff
     CERCLA                   Comprehensive Environmental Response,
                                                            -
                              Compensation, & Liability Act Act to create corporate
                              liability for Superfund site cleanup
     Chemical                 A liquid, gas, solid or powder which in normal use has
                              the potential to cause a health and/or physical hazard,
                              or the release of toxics into the environment. This
                              definition also includes any new materials that will be
                              created during the manufacturing process, either as
                              intermediates, by-products, or wastes.
1)   Chemical Handling Team   A group of employees trained and responsible for
                              chemical movement in the plant.
     Contractor               External supplier engaged to provide various plant
                              services
     Cradle To Grave          Accountability for every chemical in the plant from
                              receiving to disposal
     EHS                      Environmental Health & Safety
     EHS Checklist            Tool to use to function as a "Red Flag" for identifying
                              items or issues of EHS impact or regulatory concern.
                              Any issues identified via the checklist should be raised
                              in feasibility and producibility reviews before approval.
     GEGS Codes               GE Goods & Services Codes used throughout the
                              company to provide useful pricing and trend data
     HAZCOM                   Hazardous Communication; OSHA's most
                              comprehensive worker protection regulation providing
                              training for workers encountering chemicals in the
                              workplace.


                                    Pagelof4
                            Glossarv 0f Termg

Larm
Hazardous Waste
                            [)efinitlon
                            Any chemical waste which poses a physical or health
                                                                                         >
                            hazard. Includes chemicals that cause an acute or
                            chronic health problem, such as carcinogens, toxic
                            agents, reproductive toxins, irritants, corrosives, etc.
                            Also includes combustible liquids, compressed gas,
                            explosive, flammable and other unstable chemicals
                            which cause physical harm.
Implementation Guidelines   Guidelines to be used in the execution of suggested
                            actions
In-Plant Controls           Controls in place at a plant to ensure the proper
                            storage, distribution and usage of chemicals
Integrated Supplier         A supplier dedicated to providing Chemical
                            Management services from cradle to grave
Major Technical Change       Change affects product functionality, performance or
                             quality
                             Change requires analysis and/or testing prior to
                             approval
                             Change outside engineering specifications
Minor Technical Change       Change that supports manufacturing process, but has
                             no direct impact on product (Used to provide
                             chronology of changes for cause-effect analysis if
                             product problem occurs)
                             Change within engineering specifications

MSDS                                                     -
                            Material Safety Data Sheet A technical bulletin
                            required by OSHA which contains information about a
                            chemical material regarding its identity, chemical and
                            physical characteristics, health and safety data, and
                            precautions necessary for safe handling and use
New Product Introduction    Introduction of a product that has substantially different
                            physical characteristics andlor functionality than other
                            models or products

New Use                     The "New Use" of a chemical material includes the
                            following:
                              Introducing a chemical material into a work area
                              which is not on the Approved Chemical List
                              Introducing a different use of a chemical material in
                              an approved work area using quantities larger than
                              quantities originally approved


                                  Page2of4
                        Glossarv 0f Terms

IQLul
Non-Controlled Points   Points within the plant where chemicals can be
                        received or enter without being reviewed against an
                        Approved Chemical List
NRC                     Nuclear Regulatory Commission
Obsolete Chemical       Chemical which is no longer used in the production
                        process and has no use in the foreseeable future.
One-For-One             Concept whereby a chemical container must be
                        exhausted before it is replaced (i.e. Exchanging an
                        empty container for a full one)
OSHA                    Occupational Safety & Work Act requires employers to
                        furnish places of employment free from recognized
                        hazards that may cause death ar serious physical
                        harm to employers.
PEL                                               -
                        Personal Exposure Limit OSHA imposed limits for
                        worker exposure to various substances that may be
                        harmful.
Physical Inventory      Structured effort to completely document the identity,
                        quantity, type, and location of all chemicals in a plant
Process Map             Equivalent to a flow chart. Flow chart is a pictorial
                        representation showing all of the steps of a process.
Procurement Controls    Controls in place to ensure that no unapproved
                        chemicals enter the plant

SARA                    Superfund Amendments & Reauthorization Act of 1986
                        (Community Right-To-Know) requires annual
                        disclosure of the storage and usage of hazardous
                        chemicals
Secondary Containers    Any container other than an original container
Solution Menu (SM)      Section in package that highlights issues, associated
                        risks, & solutions for "No" answers on assessment
                        checklist

Subcontractor           External supplier engaged to provide various plant
                                 -
                        services working as secondary contractor to the
                        general contractor (See Contractor)



                              Page 3 of4
                          Glossarv 0f Terms
Iarm                      Detinitian
Technical Changes         Changes that impact product quality, performance,
                          dimensions, or material composition. Technical
                          changes can be categorized as either "Major" or
                          "Minor"
TSCA                      Toxic Substance Control Act regulates the
                          development, manufacture, distribution, use, and
                          disposal of over 60,000 chemicals. Chemicals cannot
                          be manufactured or distributed in the United States
                          unless they have been included on the TSCA
                          Chemical Inventory.
Unapproved Chemical       Chemical which is not on the Approved Chemical List,
                          and should not be present in the facility (See
                          Approved Chemical List)
Unclassified Container    Unlabeled secondary container which is unapproved
                          for chemical storage and use
Unidentified Chemical     Chemical stored in an unlabeled container

Up-Front Controls         Controls in place at a plant to ensure that EHS
                          concems are raised and addressed before new
                          products and technical changes are approved
Waste Stream Management   Controls in place at a plant to ensure that waste
                          accumulation routines are adequate, and that waste
                          streams have been properly identified and are
                          controlled
90 Day Rule               A waste generator must not accumulate hazardous
                          waste on site for more than 90 days.
      L

                                          Additional Best Practices


Tab 1 New Product I Technical Changes                          Tab 4 Integrated Supplier
      New Product Introduction Procedure (GEIPS - PDO)                                             -
                                                                      Integrated Chemical Supplier Getting Started
      EHS Evaluation for New and Modified Processes and               Product Quality Policy/Procedure/lnstnrction
                           -
        Equipment (GEIPS ASD)                                              (GE Medical Systems)

Tab 2 Chemical Procurement Policy & Receiving Procedure        Tab 5 Cradle-to-Grave Ownership
                                                                     Training
      Receipt of Chemical Material (GEIPS - Greenville)              Measurement
      Communications: New Chemical Ordering (GEAE - Lynn)            CM Roles & Responsibilities
      Blanket Purchase Orders (GEIPS)
      Chemical Review Request Form (GE Motors - Broadway)             GE Best Practice:Regulatory-RequiredEHS Training(CEP)
      GE Power Gen. Chemical Material Procurement Policy                  (including needs assessment and tracking)
      Chemical Appraisal Procurement Process Training Manual          Measurements: Progress Summary (CAS, CEP)
         to be used by Requestors and Buyers                          EHS Measurement Process (GEAE)
                                                                      Chemical Management Functions and Responsibilities
                                                                          (GEIPS)
                                                                      Key Roles and Responsibilities
                                                                      GETS Chemical Control Process

Tab 3 Chemical Handling Process
      One-for-One Replenishment Process
                                                                                                         -
                                                               Tab 6 Conducting a Plant Chemical Sweep A Guidebook
                                                                     For GE Motors
     Requirements for Use of Personal Protective Equipment            Overview
     One-for-One Replacement (CAS)                                    Guidebook
                                                                      Pre-Plant Sweep Evaluation Checklist
                                                                      Sweep Pre-Work Checklist
                                                                      Sample Press Releases
    3   NPI core Team                  Power Generation Engineering
3




                        Executive Summary

                New Product Introduction
                      Guidelines
                              Rev. 2




                                                       Paul D Oei 4/22/93
What is NPI?


New Product Introduction (NPI) is a process by which new products are introduced into the GE Power
Generation product portfolio. It enables those working on new products (or a redesign of existing ones) to
more easily and effectively manage the introduction of those products into the marketplace. “Time to
market” and technology leadership are the major drivers of programs. Setting and meting schedules is
the the priority.

The NPI process provides an important opportunity for GEPG. For our business it offers:
        - maintenance of a strong technology and market share leadership role in the
        marketplace.
        * improved business profitability, driven by
             - design processes that strive for lower cost products
             - design processes which incoporate EHS considerations
             - cost reduction efforts while the competition is trying to match initial releases
             - optimized use of limited personnel and financial resources
        -    - receipt of potential price premiums due to technology leadership
          less risk exposure from changing markets and technology

For our customers it offers:                                        *
        -
        *
             faster access to more innovative products
             increased responsivenessto their needs             I




        -    rapid correctionslimprovements
             prompt considerationof their feedback on the product

For our employees, the process offers:
        --the ability to produce quality products using proven technology
          effectiveleflicient framework for new product introduction
        * greater involvement in a teamwork environment and satisfaction of being part of a
        successful team
        * multifunctionalteams provide greater exposure to overall business and helps create a
          boundaryless environment.
     Process Overview

3    NPI is divided into five phases:
              .   product planning and technology development
                  concept development
             -    system integration
                  detailed design
                  manufacturing. test. delivery and installation

     %duct Planning and Technology Development
     It is in this phase that a product idea comes into being and
     project plans are devebped. In the generation of product ideas,
     new technohies are reviewed and product opportunities are
     identified. Directioncomes from the business's multi-generation
     product plans (MGPP),which drive "offline" technology
     development. A new concept emerges and the definition
     process begins.
     The pcoiect plans are developed during projectlproductdefinition.
     It is the quality of information in this phase that will help
     implementation go as quickly as possible. Inputs from the MGPP
     are refined to validate project feasibility. Inputs from design,
     materials and processes. manufacturing. technology, EHS, '
     distributbn and suppliers, marketing and sales are received.
     MOST IMPORTANTLY, EHS ISSUES ARE IDENTIFIED AND
     RESOLVED. MATERIAL 8 PROCESS TECHNOLOGY AND
     DESIGN TECHNOLOGY READINESS IS ACHIEVED. This
     minimizes delays as the NPI process proceeds.
-3   Concept Development
     During this phase, the conceptual design is developed and
     reviewedby management and all functions. The key here is to
     insure that technological risk is minimized and no fundamental
     design flaws exist prior to implementationof detailed design and
     product manufacture. Design 8 Manufacturing, Materials 8
     Processes. Product and EHS Reviews are requirements in this
     ahase IT I IMPORTANT THAT MATERIALS. PROCESSES
              .. S                 ......
     AND DESIGN SPECIFICATION FREEZE IS AGREED UPON AT
     THE END OF THIS PHASE.
     System Integration
     During t i phase, the teams seek verification that the design is
             hs
     sound from a systems integration standpoint, and completes the
     preliminary design for functionality, reliability and EHS reviews.
     Detailed Design
     During this phase, the design of the product is completed and the
     prototype unit construdion commences.
     Manufacturing. Test, Delivery and Installation
     During this phase, the prototype unit is manufactured. Factory
     and field testing of the prototype unit is completed and the unit is
     delivered with associated drawings and fieid support to an initial
     customer for installation and performance demonstration. In
     addition, pricing, advertising, promotion, merchandising,
     introduction, training, and inventory transition plans are initiated.
Product Planning and
Technology Development

The first phase of NPI is Product Planning and Technology
Development. There are three parts to this phase:                     Product Planning

        ---
                                                                        &Technology
              Product and Technology Planning                           Development
              Material & Process, EHS and Technology Definition
              Material 8 Process, EHS and Technology Review
                                                                              I

Product &Technology Planning
  Develop an integrated Product and Technology Plan that
  provides a three to five year programfunding strategy for
  development of new products, technologies, materials, and
  processes.
  Establish product and technology development priorities with
  specitic programs and goals clearly defined.
- Identify EHS issues and develop plan to resolve them.
  Commit to multiyear funding of programs included in the plan.
  Provide clearer focus on aftermarket opportunities by
  leveraging new unit technologies and designs.

Material & Process, EHS, and Technology Definition
  Identify “owner of program and establish integrated steering,
- team..
   .
  . -. ..
  Deline cost, operational & perlormance criteria (i.e., unit cost,
  efficiencv. etc.)
-
* Define customer needs.
  Specify desired program schedule and development cost.
* Establish and prioritize criteria for evaluation of alternative                        1
  designs.
Material & Process, EHS,and Technology Review
 ldentdy review team and agree on review process.
 Determine whether technology, materials, processes,
 facilities. design tools and methods required are sufficiently
 developed to support the product specification. If not,
 development and qualification are required.
 Identify and resolve any EHS issues (e.g. production of solid
 waste, emissions and discharges, use of restricted chemicals,
 end-of-life product disposition)
 Identify potential barriers.
 Assess the complexity and risk associatedwith the proposed
-program.
 Define capability and boundary conditions 01 required
 manufacturing processes in the world market.
     Concept Development

     The second phase of NPI is Concept Development. There are five
     parts to this phase:
              -    Concept Design and Evaluation
                   Design, Materials and Process Engineering (MPE)&
                   Manufacturing Process Review
                   Product Review
                   EHSReview


     -
                   Productspecification Freeze
     Concept Design and Evaluation
         Develop successful concept@)(i.e., with no fundamental
         design flaws).
         Demonstrate potential of concept(s)to meet requirementsof
         the product specificationthrough computer simulations and
         analyses tools.
         Establish the producibility of the design@).
                                                                           0Concept
                                                                           Development



                                                                             System
                                                                           Integration
     Design, MPE &Manufacturing Product Review
         Review the proposed concept(s) and verly that:
              - the concept meets the requirements of product
              -    specifiiation.
                   it can be designed to cost.                         I
                                                                            Detailed
              --   1can be made, serviced, and repaired.
                   we are ready to freeze the product specification?
                                                                            Design

     Product Review
         Review the rationale for selection of recommended design.
     *   Determine:
              - does business want to proceed given estimated
                program economics and product attributes?                  Installation
              - is the investment plan approved?
              - are we ready to freeze the specMalion?
         Review is a cross-functionalbusiness review.

     -
     EHS Review
         Determine EHS risk of each alternative design.
         Review proposed use of hazardous materials and chemicals

     .   subject to Toxic Substance Control Act (TSCA).
         Review preliminaty Industrial Hygiene Assessment
         Evaluationof fire risk potential
         Review materialdpmesses subject to HazCom requirements.
         Review air emissions, water use/discharge, geographical
         specific considerations, end-of-life disposition, solid waste
         disposal plans.
         Determine are we ready to lreeze the product specification?

     Product Specification Freeze
         Document the agreements reached at Design, MPE, EHS and
         Product Reviews.
         Revise and distribute Product Specification.
         Eliminate alternatives from further consideration.
         Set stage for intensive and focused effort lor remainder of NPI
         process.

'3
System Integration

m e third phase of NPI is System Integration. There are two
parts to this phase:

         -   System & Mechanical Integration (Preliminary Design)
             Functionality, Reliability, & Product Quality Review
             EHS Review

System & Mechanical Integration (Preliminary Design)
                                                                       Concept
    Verify that the selected concept is sound from the standpoint     Development
    of system and mechanical integration.
    Generate preliminary drawings and BOM.
Functionality, Reliability, & Product Quality Review
-   Verify (from an integrated multifunctional standpoint) that the
    design will:
         - function as required.
         - meet reliability goals.
         - meet product quality goals.
EHS Review
                                                                 I
                                                                      A
                                                                      Detailed
-   Make sure that the complete system is evaluated for:
        - Environmental Control Options
                                                                         Design

        - TSCA
        - Hazard Communication Planning
        - Community Right-to-Know                                     Manufacturing,
                                                                                         1
        - EHS Requirements (Permits, licenses and                     Test, Delivery &
           notification; Chemical inventory review and update;          Installation
           Operation; Monitoring, analysis, Inspections &
           regulatory reporting)
        - Training Plan
    Detailed Design
3
    me fourth phase of NPI is Detailed Design.
    Detailed Design
           -   Complete detailed engineering (layouts, schematics,
               etc.)
               Define all infonation needed for production (Le.,
               EOM, drawings, toolings, etc.)
               Design to cost.
               Continue concurrent designfprocess development.
               Design for reduced order to remittance cycle.
               Design for reuse
               Produce prototype hardware.




                                                                     Manufacturing,
                                                                     Test, Delivery 81
Manufacturing,Test, Delivery & Installation

The fifth phase of NPI is Test, Delivery & Installation. There are
three parts to this phase:
         .
         -    Manufacture Prototype Unit
              Define Test Expectations and Design of Experiments
              Factory Tests & Field Tests
              Final Product and EHS Review

Manufacture Prototype Unit
     Prototype is manufactured using rapid
         prototyping (SLA) techniques.

-
Define Test Specifications
    Define:
         -    test expectations.
         -    test instrumentation
         -    data acquisition and analysis methods
         -    acceptance criteria
         -    procedures for retest
         -    manufacturingsupport requirements
         -    field supporl requirements

-
                                                                I
Factory Tests & Field Tests
  Demonstrate ability of components, systems and product to
  meet requirements of product specification.
Final Product and EHS Review
-   Final formal review of actual vs. expected performance of
    product relative to product specification and EHS
-   requirements.
    Provide feedback for use in multigeneration product
    planning.
Best Practices Summary

This section provides a compilation of Best Practices applicable to all NPI efforts.

h2tIii

Product Planning
                                          -.     Establish mission and goals.
                                                 Clear prioritization of projects to permit resource
                                                 dedication and promote rapid completion.
                                               . Focus on life cycle impact, including aftermarket
                                                 planning

Development Teams                         .     Multiiunctionalteams.

                                          -     Dedicatedteams.
                                                Collocated teams.
                                                Integration of suppliers, partners and customers on
                                                teams at the outset.

Leveraging Proven Designs                 -     Development risk should be reduced by
                                                    - leveraging proven designs
                                                    - isolating high risk areas
                                                    - develop contingency plans
Product Definition                        -     Product definition should incorporate clear
                                                understandingof:
                                                     - customer needs and values (customer needs
                                                         mapping)
                                                      - competiior dynamics
                                                Rigorous adherence to the specificationfreeze
                                                discipline is critically important to rapid development.

Design Tools and Methods                    Product and process design must be integratedto
                                            achieve full businesswide benefit (Le.. Integrated
                                            Producl and Process Design).
                                          * Product design must focus on:
                                                 - manufacturability
                                                 - assembly
                                                 - product simplicity
                                                 - maintainability (service and repair)
                                                 - disposal and EHS issues
                                                 - lowest installed cost
                                                 - short order-to-installation cycle
Manufacturing Planning                          CpK focus drives manufaduring qually and
                                                productivity.

Project Management                              Performance to plan rigorously tracked.
                                                Performance includes time dimension.
                                                Post-projectevaluations conducted and results
                                                documented.
                                                Senior leadership role supports empowered,
                                                multilunctional, dedicated team approach.
                                                      - sponsor provides air cover.
                                                      - senior management gives project appropriate
                                                        priority.

Product Commercialization                       Commercialization included in product plan.
3




---
i
..
Environment, Health & Safety
         Evaluation
             for
      New and Modified
  Processes and Equipment



    Issued: September 1991, Revised: December 1992


                                                     Attachment L,
‘3
       cj

EHS Evaluation for New and Modified Processes and Equipment
Purpose of ProcesslEquipmenl Review
Assure compliance with all applicable Federal. state and local regulations and corpaatc policies dating to the selection. installation
and operation of mwlmodificd processes and equipment within ASD facilities.

Key Areas of Concem
    Air. water. hazardous waste and non-hazardous wastes generated from the pnocess/equipment. Emphasis on the minimization of waste
    streams. proper treatment systems are provided. and handling proccdures are in place. .
    Safety and health aspects of equipmnt operation... including chemical handling, guarding, etc.
    Required permits for air emissions and discharges to drain SyStGIIIS (wastewater treatment plant and surface water) arc secured prior to
    operation. Emphasis on waste stream reduction and recycle.

General Review Procedure
    For new equipment purchases:
      I. Manufacturing Engineering and service center EHS contact prepam the attached process review form and attach to PAR.
         Discuss evaluation with Region EHS Specialist and Headquarten EHS staff as required.
     2. Incorporate requirements from the evaluation into the procurement. installation and operation of equipment.
      3. Obtain any permits required to operate equipment with suppon from Region and Headquarters EHS staff.
     4. EHS contact along with support from Region EHS Specialist to assure adequate training on the safe operation of thc equipment
         is provided. Training can be in thc form of inhouse on-the-job training. provided by the equipment manufacturer, a video tape or
         other training sources.
    For modifications to existing pnms~cs cquipmcnk
                                              and
    The major concern is that a modifcation may.change the amount or typc of waste strcams or introduce additional safetyhealth hazards.
      1. ME and service center EHS contact prepare the attached p m s s review form and attach to PAR. Discuss evaluation with
         Region EHS Specialist and Headquarters EHS staff as required.
      2. Secure any air o water permits Equired for p m s s changes.
                          r
      3. Incorporate changes in equipment operation into operating proccdures and hain personnel on modifications. Include safety.
         personnel protective equipment and waste handling requirements.
EHS Evaluation for New and Modified Processes and Equipment




0 G m e d sarcly

   .
   -S;rlcly equipment nquind

   -Signsrequired
    SpuxdTraininy ryuircd__    -

L                              v                              4
 TCUStuion                            v       fl       v
.w d
 l     Dip T     d   v   v        v   v
                                      v   v




* Roto-Tiisher           v   I,   v   v
* S k m Clening      v       v    v   v            v
3
                         RECEIPT OF CHEMICAL MATERIAL

'3                                               --
                                DELIVERY GREENVILLE,
                    (SOURCE:POWER                 SC)


     1     PURPOSE
           This procedure defines guidelines for the receipt of chemical materials.
           supplementing those guidelines outlined in GTMP M5.20, for receipt of
           material, and ensures receiving integration between organizations in the
           control of chemical material. Procedure applies also to contractors
           working on site.


     II.   GENERAL
           A.    For receiving purposes, a chemical is a liquid, gas, solid or powder,
                 whether hazardous or not.
           B.    Procedure pertains to bringing any chemical including limited
                 quantities, samples, process chemicals, fluids within machinery and
                 D.O.T. non-regulated chemicals.
           C.    All deliveries for chemical products should be directed to the
                 Materials Distribution Center receiving office with any exceptions
                 approved by EHS. The receiving office will route the chemical
                 products to the responsible parties.
           D.    Alternative receiving points for departmental receipts are permitted
                 into the following areas.
                        Bulk Shipment Points
                               Waste Treatment Facillty
                               Test
                          -    East Platform (Tool Crib)
                               Compressed Gas Areas
                        Contractor Receiving Areas
                        Less than $ 1.000 Orders
           E.    All chemicals being received will have proper EHS approval and will
                 have been on an approved chemical list prior to being received.
           F.    If a chemical product is not on the approved chemical list, chemical
                 products will be quarantined andlor returned.



                                           -1-
111.   RESPONSIBILITIES
       A.   Receiving Operator Responsibility
            1.    Receive all chemical shipments to verify that they are on the
                  Approved Chemical List, properly labeled, and securely
                  packaged.
            2.    Quarantine all unapproved shipments, chemicals not on an
                  Approved Chemical List, and execute disposition routines.
            3.    Refuse receipt of chemical materials displaying broken seals
                  or leaking packages. Call EHS or 2911 (Emergency
                  number) for disposition concerning spill release and
                  reporting requirements.

       B.   Manager of Receiving Control Point
            1.    Arrange the disposition of quarantined receipts by
                  undertaking the following steps:

                  a)     Receive and quarantine temporarily in a designated
                         storage area.
                  b)     Determine who ordered the chemical, and notify the
                         requester and EHS of arrival.                             i
                  c)     Release once approval is issued from EHS, or after
                         24 hours, arrange for return of material.

            2.    Ensure the training of receivers and that only authorized
                  receivers accept chemical shipment. Authorization to
                  receive chemical items requires training and testing in the
                  following areas:
                  a)     HAZCOM Instruction.

                  b)     Awareness training in accordance with HMT-181
                         regulation. Training will be provided by certified
                         instructors within the MDC office.

                  c)     Specific function training (e.g., marking packages) for
                         limited hazardous material responsibilities.

                  d)     Receivers with greater hazardous material
                         responsibilities will attend Corporate's 49CFR basic
                         course.



                                    -2-
     3.    MDC provides instruction for identified receivers.

     4.    Testing and tracking of personnel completing training will be
           provided by EHS.
     5.    Establish receiving areas which are equipped to handle
           chemicals.

C.   Sourcing Responsibility
     1.    Ensure that an additional MSDS, besides the one forwarded
           to EHS,is shipped for all required materials and that the
           MSDS is included in the QC file folder.

D.   Bulk Shipments
     1.    All chemical bulk truck shipments are to be checked against
           the Approved Chemical List and routed through the MDC
           receiving office to the proper unloading dock.
     2.    Designated, trained operators at each bulk storage will
           ensure that the bulk material is dispensed into the proper
           storage unit, sign the bill of lading and forward to the MDC
           receiving office.

E.   Requester's Responsibility
     1.    For purchases less than $1,OOO, it is the requester's
           responsibility to ensure that chemicals are ordered with EHS
           approval. Any unapproved chemicals, received by the
           requester, result in immediate disposition through the EHS
           department.
     2.    Before a requester receives any samples, samples require a
           Material Approval fofm,appropriate MSDS and EHS
           approval.
     3.    To communicate this responsibility. non-production items
           unloaded by the MDC will be labeled indicating the
           appropriate actions to undertake if a chemical is contained in
           the package.




                               -3-
F.   Other Related Chemical Receiving Requirements
     1.    GE employees are not permitted to bring chemical materials
           on site unless they are on the Approved Chemical List.
     2.    For the receipt of new machines, requires the requester to
           obtain MSDSs and approval from EHS before entry onto site
           (Reference chemical approval procedure)

G.   EHS
     1.    Add newly approved chemical materials to the Approved
           Chemical List and distribute updates as necessary to
           receivers.
     2.    Advise receivers on newly approved chemical handling and
           disposal requirements.
     3.    Maintain the MSDS Master file and verify that work area
           MSDS binders are current.




                             -4-
e         lw ”   m   L   H U M 6 J.h*

HAZARDOUS WASTE HANDJ.lING
     ENVIRONMENTAL SERIES




                                                              lvna Envimnmwnul. H d t h 6 Salrtv

                                        PERSONAL PROTECTIVE EQUIPMENT
                                                   INDUSTRIAL HYGIENE SERIES
                                        Purpose: Parronal Proteawe Eaulpment (PPEI IS
                                                 worn 10 protea workers from contact wltn
                                                 chamial Or PhySlOl hazarda in lhe
                                                 workplacm. Such hazards includa cham,.
                                                 a l a . dust, m i n fumaa. n o m . matal chaps
                                                 and falling obpms.
                                           Panom1 ho(.criv*                       Availabla




                                         Face Shields
                                                                     Shop Support TOOI        cross

                                         Moaring Protamion           SW E M WICO then
                                                                                 1-64.
                                                                      Shoo Suppon Tool Crib
                                         Sofen, Glasmr
                                           Non-orarcription          Shop Support Tool Crtbs
                                           Prescription              Optomatrial 2.96 ana W.Lynn
                                         Safew Shoaa                 Shoemobile visits.
                                         Hard Hats iLPSI             Su~.rvl.or
                                         Reroiratora


                                                           GE provider stloend
    Procedure for Ordering New Chemicals




            ’   I   one copy t o your Lab
                     MSDS Coordinator.


                                             HMlS  Coding
                                                  and
                                            Unit inventom




                                                      non-shaded
                                                        areas
                                                     Review wltn
                                                     Marsna Rader



          Take “-meted forms to
               Ross Nicholas.




4
    L
Chemical Management                                                     Blanket Purchase Orders

                                                                         CHAMPIONS

   Control Chemical Blanket Oders Via the Following Mechanisms:
                                                                        Chudc Harris,Ben Nadeau.Kim Bradshaw
       - Identify Current Vendor Base Utilized for all Blanket Po's
       - to be Utilized for Future Chemical Blanket PO'Sie Air
         Establish a ReducedQuality Supplier List
                                                                        Chuck Harris,Ben Nadeau,Kim Bradshaw


           Products,Abmsives, Oils etc.
       -   Limit Number of RequestorsWho are Approved for
           Blanket Purchases  -
                                                                        TBD

                -Work with GM/MF to Identify Requestors by Plant
               - Approved Requestor List                                Kristen Pulling To Write
       -   Communicate to Approved Requestors that Chemical
           Blanket PO ' Will Only be Approved For the Above
                        s
                                                                        Letter

           Qualiy Supplier List
                                           -
           ( Letter from Craig Kipp,J. Cote to be sent with

       - - paych=W
           Send out Letter to Identified Quality Suppliers
                 Communicate GE Requirements For All
                                                                        Kristen Pulling to Write Letter


                  Purchases Which Require an MSDS                       TBD
               -  Establish Routine Whereby Vendor Supplies
                  Inventory List of All Chemical Purchases by Quarter
               -  Vendor to Utilize Approved Chemical Listing Before
                  Shipping Material                                     Paula Zilka
       -   Change Contracts at Time of Renewal For EHS
            Requirements
   - Send out Letter to Those Vendors Not Specified for           Kristen Pulling
    Chemical Blanket Po's ( Craig Kipp, J. Cote Signature)
         -
        No Chemicals to be Purchased on Blanket PO
         -
        State Strongly the Implications of Not Following the
         Above Guidelines
   - Blanket Forms to Spell out By Line Items What Chemicals      Kim Bradshaw
    are to be Purchased
         - Requestor Education
         - System Enhancement to Incorporate into COPlCS
                                                                  Kim Bradshaw
   - Need to Identify ReceivingPoint for IncreasedVolume
   - System Fix so That Chemicals can be Received in
    COPICS
                                                                  Dave, Kim, Paula, Kristen
    - Meet With Craig Kipp & Direct Material Managers to          Ben, Chuck
     Ensure Above Strategy is Feasible

Control <$io00 Purchases Via the Following Mechanisms             Dave, Kim, Paula, Kristen
    - Eliminate1
    - Draft Plan and Strategy on Elimination
    - Present Plan and Strategy to Ron Collins and Ed
     Clemmings
Control Credit Card Purchases Via the Following Mechanisms
                                                                  Kim Bradshaw
    - MRO Meeting to Be Held 4/28-4/30 - Credit Card Issue
      to be Discussed - Best Practices Identified and Leveraged
                                                                                  GE Motors
3
                       CHEMICAL REVIEW REQUEST
    This authorization will be completed prior to the initial purchase of
    any chemical used in the production of motors, or in support of the
    production of motors, at the Broadway Plant.
    Once granted, this approval remains in effect unless the chemical formula
    or the manufacturer of the chemical changes.


       Product Name:

       Manufacturer:


       QTY to be placed in Oil House inventory:                Minimum QTY   to trigger re-order:   -
       Material Replaces:

       Requestor:                                 Extension:

4      Date Submitted:                            Date Approval Needed

       Process & Location:
                    MSDS SUEET MUST BE AmACHED FOR APPROVAU

                ENGINEERING                         ENVIRONMENTAL,. HEALTH AND SAFE-
                  REVIEW                                         REVIEW
    )mments:                                       Comments:




    proving Engineer:                               0 Assessment form complete?

    turned to Requester:


    S
    I FORM MUST BE ATTACHED TO YOUR REQUEST FOR MATERIALS ON ANY
    EMICAL PURCHASE REQUESTS. IT IS AGAINST GE MOTORS POLICY TO PURC-;                                        :-
    EMICALS WITH HANDWRITTEN PURCHASE ORDERS (BOOS).
                                                                                               cl€Y.m:.   ~




                                                                                                              --.




                                                                              c
                            GE Power Generation
                     Chemical Material Procurement Policy

 1. General
    The General Eledric Company is w mn d to conplying with all applicable Environmental. Health and
                                       m ie
    Safely (EHS) laws and regulations. This policy is designed to ensure that 1) All new chemical materials
    are reviewed and approved prior to procurement and to 2) Ensure a process is in place whereby chemical
    usagehandling requirements are available to all employees

Ii. Definitions
    For the purposes of this policy the following definitions apply:
    A.
                              '
                                  -
                                 An EHS approved liquid, gas. sold or powder which in normal use has the
         potentiilto c a w a health and / or physical hazard, or the release of toxins into the environment. T i
                                                                                                              hs
         definition also includes any new materials that will be created during the manufactwingprocess, either
         as intermediites, by-products. or wastes. Exanples of chemicals include: paints, oils, fuels. coolants.
         adhedies, compressed gases. lubricants. solder. cleaning agents. WD-40 etc. When in doubt,
         conlacl your site specifc EHS Manager' for chemical clarifiition.
         Each chemical must be reviewed by the Plant Specific                   EHS Manager' to ensure              full
         compllanco wlth all regulatlonr and guidelines.
    B.                                           - A technical bulletin required by OSHA which contains information
         about a chemical matelialregarding its identity. chemical and physical characteristics. health and safely
         data. and precautions necessaly for safe handling and use.
         For all chemicals used In the facility. a Material Safety Data Sheet
         layrl
    c.                               -An employee who requests, buys or othetwise acquires a chemical:
            Pmcuremrd of a chemical (new or currently used)
            New w of an cnisling chemical material
            Trial samples obtained for testing purposes
            Chemicals used by outside contractor services on GE premises
                          '
    0.                            -An employee authorized to receive chemical shipments entering the plant

    E.
                                   .
                                  - A l i i n g of approved chemicals authorized for use in a plant   - used as a
         control reference prior I chemical procurement and receiving.
                                 o
    F.             - The 'new use' of a chemical material includesthe following:
         1) Introducing the use o a chemical material into a work area which is not on the Approved Chemical
                                f
            List
         2) Introducing, in an cipproved work area, a different use of a chemical material requiring quantities
            larger than originally approved.


* See Material Approval Request Form
111. Responsibitlties
A. Chemical Requester mud:
    1) Reference the Approved Chemical List to verify that the chemical material being requested is
       approved for use in the plant in which it will be used.

    2) Complete a Materhl Approval Request Form (Attachment 1) lor any new chemical and
       submit it with the MSDS to the site specific EHS Manager' prior to procurement.
    3) Request chemicals by using chemical mrdrol ID from Approved Chemical Listing.
    4) Order chemicals in quantitidrequencies which are pradical.

      The requester is responsible for ensuring that EHS review and approval
     is obtained for new chemicals.

8. Plant EHS Manager must:
    1) Administer the material approval process and communicate approval or rejection of the chemical
      Requesl for Material (RFM)/purchase requisition.
    2) Assign chemical control ID number to newly approved chemicals.

   3) Add newly approved chemical materials to the Approved Chemical L-alabase        and distribute
      updates as necessary to requesters, buyers and receivers.
   4) Maintain the MSDS Master File and verify that workarea MSDS binders are kept current.

   5) Forward newly approved Material Approval   - quest Fonn along with RFM to Sourcing
   6) Advise requesters and receivers on newly approved chemical handling and waste disposal
      requirements.
   7) Make any necessary modifitions to envirmmenlal penits at the time of new material review and
      approval.


C. chemical Receivers must:

   1) Receive all chemical shipments, verify that they are on the Approved Chemical List. propedy labeled.
      and securely packaged.
   2) Quarantine all unapproved shipments (Chemicals not on the Approved Chemical List) and execute
      disposition routines
   3 Contacl Requester that chemical will be returned to sender unless otherwise approved.
    )

  Receivers must screen all chemical deliveries against the Approved
  Chemical List
D. Manager Shop Operations'Supenrisors must:
   1) Ensure that all chemicals in use have been approved

   2) Educatdadvise employees on this procedure and the requirements for ordering chemicals.

   3)Ensure that an MSDS is maintainedfor each chemical used in their work area i and avaibbke for all
       enpbyeed
   4) Permit only authorized employees to use or handle potentiilly hazardous materials.

   5) Ensure that each employee has received HAZCOM training for each chemical hashe uses.




E. Sourcing ManagarByen must:
   1) Verify that all chemical pwchasas are on the Approved Chemical List for the site(s) of intended use.

   2) Ensure that new chemical purchases have been approved by EHS at all sites of intended use prior
       to procurenwnt.
   3) Return all requests for materials that do not appear on the Chemical Approved List. In the case of
       e
      nw    apprared chemicels. an EHS approved Material Approval Form,for each site of intended use.
       should acconpanytheRFM.
  4) Require that all purchase orden for new chemicals o chemicals alreaw in use have a statement
                                                       r
     requiringthat an MSDS be sent with the order and to the plant spacific EHS manager

    Buyers are responsible for ensuring that no unapproved chemicals are
    purchased
IV. Restricted Procurement Methods
  A. Chemical material purchases are llpt to be made using credl cards for reimbursement.

  8. Chemical meterials are      to be routinely purchased using <$lo00 methods or blanket purchase
     orders. I the event that an emergency situation requires purchase using the above methods, the
              n
    purchaser must provide a ccpy of the MSDS to plant W S Coordinator for review and approval prior to
    procuremant.
V. Other Related Chemical Material Requirements

  A. Suppliers are prohibited f bringing chemicals on-site for trial purposes without prior approval from
                              m
     the plant EHS Coordinator. Recipients of trial materials should subml Material Approval Forms and
     appropriate MSDSs to plant EHS Coordinator.
B. Contractors are prohibited from bringing chemicals on-site withoul receiving prior approval from plant
   EHS Coordinator. Engineersrequestingcontractor services must verify that MSDSs have been
   fumished prior to work start up. Additionally, arrangements must be made for the remval of chemicals
   brought on-silo by contractors.


C. GE employees. including thobe from other plants. are not permitted to bring chemiml materials on-site
   unless they are on the Approved Chemical List. Plant EHS Coordinator approval must be obtained via
   the Material Approval Form and an MSDS prior to bringing the chemical on-sile.

0. MSDSs must also be provided for free chemical samples.
3     @                             GE Power Generation
                                 Material Approval Request Form
                                    l l l e k k w f l g u d ~ ~ b P w d n d ~ b ~
                                      pocuemsldnmivmal&kI~~am
                                     Ottan MSDS alkh b Ius lam da&rrtbW S

     Date                                            Site

     Product Name
     Product Manufacturer
     Supplier
             s
     Produd u e
     Quantity to be used ge Ibs., gals..)                           /month          Ivr

     PlannedStorage?
     Does the operation already use a chemical that can perform this function?
     Will this replace existing material?          Yes      -No
        ll yes, what matetial is being replaced?
        Will replaced material need to be disposed of?              YeS             No

     Requester Name
-4

     EHS Approval Given?              Yes             No

     Chemical Control ID #
     Hazardous 1 Toxlc Material?
     Environmental, Health & Safety Requirements
                       . .

     EHS Approval Slgnalure                                       Date
     Added to Approved Chemical List?                       Yes    Date
     Fax Form and MSDS sheet@)to:
                               FAX                 PHONE           CONTACT

     Greenville            8'2884780           8.288-2355         Thad Lelster
     Schenectady           8'235-8599          8'235-9184         Don Huckabay
     MchtnJrg              8'234-1 459         8.234-1766         Paul Waterman
     Bangor                8.560-2529          8'560-2558         Jim Crawford
     Lynn                  8'263-9457          8'263-3315         Dale Ashley
3
                                                 LJ




                            Chemical Approval Procurement Process
                                       Training Manual
                                 To Be Used By Requesters And Buyers




GE Proprietary
FS~Mto(:PuIlnp:Ch.molCaer
                                  Corporate Environmentalism



                       "Every Single Person In GE Has To Be An Environmentalist.

                      Our Products Have To Be Thought Of In Those Terms. Our

                      Processes, Too. Everybody Has A Role To Play. And The

                       Companies That Don't Understand This And Don't Do It,

                       Won't Recruit The Best, Won't Sell Their Products, Won't

                       Be A Viable, Positive Enterprise In The 1990's''


                                                                   Jack Welch




GE Proprieta
FS*Auor.P".npLul   SlsPap. I
                           ..............




                                                i




GE Proprietary
F S l A d l o r . P u M g . C h o d 618 Paw 2
                                                      Chemical Guidelines
                           A Chemical Is:

                               A liquid, gas, solid or powder which in normal use has the
                          potential to cause health and / or physical hazards, or the release of
                          toxins to the environment.


                           Examples:
                                    A table is not considered a chemical material. It's normal use
                                    does not cause health and / or physical hazards, or the release of
                                    toxins to the environment.

                                    Solder       chemical material - when used, it gives off fumes.

                                    Paint     chemical material - when used, it gives off fumes.

                                    Fiberglass      chemical material - when used in manufacturing
                                    processes

                                    A casing is not a chemical unless an operation (i.e., cutting or
                                    filing) is performed.

                                    A bolt is not a chemical material
GE Propns
FS2 Aditor Pull-mica   619 Page 3
                                                                   -4'
                                           \lj
..........


                         Chemical Guidelines

             Examples:

               Welding rods are chemical materials


               1, 1, 1 - trichloroethane         chemical


               WD-40       chemical


               Acetone       chemical

                Fuels / oils / coolants are chemical materials


                Compressed gases are chemicals
          cn
          +
          t
          a,
     t    >
          -
    i=    0
          m    \
    \
          +    cn
               +
          .-
           t    t
               .-
          a    a
          a    a




          a
     cn   .-
           t
    -
    .-    t
          a         -
                    cn
    a
    x     a,        a,
                    3
    zi    9         u,
e    e         e
3
    v)
    v)
    Q)
    0
    0
    k




         I
         v)
         v)
         9)
         0

         3
         9)

         6
                   E
              v)
               t
              I ?
                   --
                   m

              w e
                   0
                     Procurement Tools

a   Approved Chemical Listing
       A listing of approved chemicals authorized for use in a
       specific plant

       * Maintained and distributed by EHS

0   Material Safety Data Sheet (MSDS)
       A technical bulletin required by OSHA which contains
       information about a chemical material regarding its identity,
       chemical and physical characteristics, health and safety
       data, and precautions necessary for safe handling and use.
        A material safL.j data sheet is required by law.

0   Material Approval Request Form
       Form submitted to EHS by a requester petitioning for
       approval of a new chemical material.
3
    Chemical Approval / Procurement Process




I        Fon       A                  I
I             m
         wilh I
I
I




I
I
I
I
I
I
I
I
I
1
I         I v.
                                   Chemical Approval / Procurement Process
                                     All chemicals must be approved prior to procurement
        How?


        -
        EHS                           Provide all requesters and buyers with an approved chemical list
                                      detailing chemicals authorized for use in a specific plant

                                      Review each Material Approval Request Form within 24 hours of receipt
                                      for approval.
                                      Assign chemical control id#to newly approved chemicals.



         ReQUeSter:                    Reference the Approved Chemical List to verify that the chemical material being
                                       requested is approved for use in the plant in which it will be used.
                                       Complete a Material Approval Request Form for gnv new chemical purchase
                                       and send to the site specific EHS manager prior to Drocurement.

                                       Obtain a Material Safety Data Sheet (MSDS) from the chemical supplier and
                                       submit to EHS with the Material Approval Request Form.

                                       Request a chemical by placing the chemical control id# (by plant code)
                                       in the description field of the RFM.



GE Proprietary
FSZAudtar:PulmpCChamal6gPaga I t
         Chemical Approval / Procurement Process




Buver:     Must review all chemical Request for Materials (manuaVautomatic) against the
           Approved Chemical Listing.
           Unapproved chemicals must be rejected and sent back to requester.

           Each chemical purchase order must be identified as hazardous material within
           COPlCS using the BMPD & POTX screens in order for suppliers to provide the
           required MSDS’s.
           Chemical materials to be shipped to Bangor, Lynn, Fitchburg & Greenville
           must be coded with correct destination code. This code must be input at the
           POTX screen at the individual requisition level so that MSDS will be routed to
           the proper ship-to address
                             Lynn      HZ04               Bangor     HZ05
                             Fitchburg HZ03               Greenville HZ02
Chemical Materials Are Not To Be Routinelv
 Purchased Using The Following Methods:

    < $1000 purchases


    Blanket purchase orders

     Credit cards



 In an emergency, ensure that the site specific EHS manager
 has reviewed for approval prior to procurement
                Samples


Must be pre-approved by EHS



Follow same approval process



Incoming samples must have a copy of Material Approval
Request form and MSDS as they enter plant



Arrangements must be made for the removal of non-
approved chemical samples
                                               To Facilitate the Chemical Approval Process
                                               Please send your Material Approval Form with
                                                the Material Safety Data Sheet (MSDS) to the
                                                           following individuals:

            Chemicals purchased for: Schenectady           Phone                                  -
                                                                                                  Fax
                        Contact:     Don Huckabay        8*235-9184                            8*235-0627
                                     Bldg. 41 - Room 105
                                     Schenectady, NY 12345


             Chemicals purchased for: Greenville
                         Contact:     Thad Leister         8*288-2355                          8*288-2780
                                      300 Garlington Road
                                      Greenville, SC 29607


             Chemicals purchased for: Fitchburg
                         Contact:     Paul Waterman       8*234- 1766                          8*234-1459
                                      166 Boulder Drive
                                      Fitchburg, MA 01420


GE Proprietary
                                          .
F S 2 A u d l o r : p w k g C ~ I b D p q 14
           Chemicals purchased for: Bangor                          Phone         -
                                                                                  Fax
                                      Contact:   Jim Crawford       8*560-2558    8*560-2529
                                                 534 Griffon Road
                                                 Bangor, ME 04401


           Chemicals purchased for: Lvnn
                       Contact:     Dale Ashley                      8*263-3315   8*263-9457
                                    GPBll
                                    1100 Western Ave
                                    Lynn, MA 01910



           * All Requests For Approval Will Be Reviewed Within 24 Hours of Receipt




GE Propriet
F*2*d,c+   P   L   .   . 'Pap.   IS
GE Proprietary
F S Z A G ~ ~ W P ~ Y ~ wwq. ~ e
                        ~CC I
3




;3
 ._
GE Proprietary
Fgtludbx:Pumw.Ck~&aI m P -   LI
'3
13.   INaREDlENT INFORMATION                                          1
                                             OTHER UMITS
COUFe4ENT        OYUPEL        ACOIH   nv   RECOMMENDED    CASU   %RANGE




IS.   FIRE AND EXPLOSION HAZARD DATA                                  I
3
18.    HEALTH HAURD DATA
                       Nwuwwwd by ACalH or OSHA
                                                  1
Tkmhddum)IrJur




19.    SPECIAL PROTECTION INFORMATION             1




110.   SPECIAL PRECAUTIONS                        I
3
                              GE Power Generation
                           Material Approval Request Form
                              mcmnprramubonm.dbpwb-
                                p"srdnavt"nl%n)W-
                              ob(an MSOs a&il b ta k nddd b M S
                                                    n


Date   a           &               &                     Slte Schenectadv
PmductName AutomatedB
Pmduct Manufacturer P v l a m w t s
Suppller   lndustrialsuDnlv Inc.
Product use
                                    ,@ $
                                      Q-
Ouantlty to be used QeIbs., gals.,) % L&                       /month-      IY   r   L
Area of Use?
Does the operation already use a chemical that can perform this f u n c t i o n ? A
Will this replace edsUng matedal?             Yes    X     N     o
   ll yes, what material I being replaced?
                         s
   Will replaced material need to be disposed 017              Yes          No

Requester Name          NeM
                      I. e d




EHS Approval Glven?            Yes              No
Chemical Control ID t
Hazardous I Todc Material?
Environmental, Health (L Safety Requirements


EHS Approval Slgnature                                     Date
Added to Approved Chemical List?                     Yes    Date
Fax Form and MSDS sheet@)to:
                        FAX                  PHONE          CONTACT
Greenville          8'288-2780             8'288-2355      mad Leister
Schenectady         8'2354627              8'2359184       Don Huckabay
FitchbUrg           8'234-1459             8'234-1766      Paul Waterman
Bangor              8'560-2529             8'560-2558      Jim Crawford
Lynn                8'263-9457             8'263-3315      Dale Ashley
3
'3
'3
                                                                                                                          I
                                                                                                                          P O NUMBER
           L       REQUEST FOR MATERIAL
                                                          PAGEL
                                                            v




                                                                  VALUE   OTMR APPROVAL             MANAGER'S APpllDyAL
        @
             NON-
                     0
             PRODUCTION              0 REPARSN t                  s
                                                                          X                         X
        0 PRODUCTION 0 CONSIGNMENT   0 BIANKET,UMlT   t                   IEQUlSIIlDN
                                                                          SlANS
                                                                                        1 ~=~      o:%EST            0AMENOMEW 0WNCEUATION*
                   CLuen,LU\   rvrrkul
   ~ l U L l l E M D E S ~




SLHXESIEDVENDOR                                 M N W R PHONE                      vuloon C W E                                  nuom VAUO m
                                                                                                                                           m
                                                                                                                                                           DAYS
MNWUSM M S S                                     VENDOR CONTACT                    PAVMENT lERMS                                 SHIPPING CODE


YKUL Nons                                                                          1 CODE
                                                                                    U                                            llECOVUlG L o U l l O N


                                                                                   BUYER                            BUYER AUTH   BUYER LO


                                                                                   BROKER AGENT                                  BROKER'S PHONE
"3
.
                                  GE Power Generation
7)                         Chemical Material Procurement Policy

     1. General
        The c3ened Writ Conpeny is omm mined to conpfying with all applicable Environmental. Health and
        Safely (EHS) law and regulations. This policy is designed to ensure that 1) All new chemical materials
        are reviewedand epprwed prior to procurement and to 2) Ensure a process is in place whereby chemical
        usagelhandling requirements ere available to all employees

     II. Definitions
        For the purposes of this poky the following definitions apply:
        A.
                                 '
                                     -
                                    An EHS approved liquid, gas. sld or powder which in normal use has the
                                                                     oi
             potential lo c8u.s~a heath and I or physical hazard. or the release of toxins into the environment. This
             definition also includes any new materials that will be created during the manufacturing process, either
             as intatmediites, by-products. or wastes. Examples of chemicals include: paints, oils, fuels, coolants,
             adhesives. conrpressed gases,lubricants, solder, cleaning agents, WD-40 etc. When in doubt,
             contact your site specific EHS Manager' for chemical darifiitbn.
             Each chemical must be reviewed by the Plant Specific EHS Manager' to ensure full
             compliance with a11 regulations and guldellnes.
        8. p                                   - A technical bulletin required by OSHA which contains information
           aboul a chemical material regarding its identity, chemical and physics1characteristics. heath and safetv
          data, and precautions necessary for safe handling and use.

             For all chamicals used In the facility, a Material Safety Data Sheet
             l
             k
        c.                                   -
                                          An employee who requests, buys or otherwise acquires a chemical:
                Procurement of a chemical (new or currently used)
                New use of an existing chemical material
                Trial samples obtained for testing purposes
                Chemicals used by outside contractor services on GE premises

       D.    Chemical.Recelver-An employee authorized to receive chemical shipments entering the plant.
                             '



       E. &                        '     -
                p v e d C w A listing of approved chemicals authorized for use in a plant           - used as a
             control reference prior to chemical procurement and receiving.

                       -
       F. New Uw The 'new use' of a chemical material includes the following:

             1) Introducing the use of a chemical material into a work area which is not on the Approved Chemical
               List.
            2) Introducing. in an approved work area, a different use of a chemical material requiring quantities
               larger than originally approved.


     See Material Approval Request Form
 111. Responslbiiitles
A. Chemical Requester must:
    1) Reference the Approved Chemical List to veriJy that the chemical material being requested is
       approved for use in the plant in which it will be used.

    2) Complete a Material Approval Request Form (Attachment 1) for any new chemical and
       submit it with the MSDS to the site specific EHS Manager' prior to procurement.
    3) Request chemicals by using chemical control ID from A p w e d Chemical Listing.
    4) Order chemicals in quantitidrequencies which are practical.

      The requester is responsible for ensuring that EHS review and approval
     is obtained for new chemicals.

E. Plant EHS Manager must:
    1) Administer the materialapproval process and communicate approval or rejection of the chemical
       Request for Material (RFM)/purchasequidtion.

                        oto D
    2) Assign chemical c n r l I number to newly appraved chemicals.

    3) Add newly approved chemical materials to the Approved Chemical LisVDatabase and distribute
       updates as necessary to requesters. buyers and receivers.

    4) Maintain the MSDS Master File and verify that work area MSDS binders are kept current.

    5) Forward newly approved Material Approval Request Form along with RFM to Sourcing
   6) Advise requesten and receivers on newly approved chemical handling and waste disposal
      requirements.

   7) Make any necessary modifications to environmentalpermits at the time of new material review and
      approval.



C. Chemical Receivers must:
   1) Receive all chemical shipments, verifv that they are on the Approved Chemical List. properly labeled,
      and securely packaged.

   2) Quarantine all unapproved shipments (Chemicals not on the Approved Chemical List) and execute
      disposition routines

   3) Contact Requesterthat chemical will be returned to sender unless otherwise approved.

  Receivers must screen all chemical deliveries against the Approved
  Chemical List
3   D. Maneger Shop OperationdSupervisors must:




           -
       1) Ensure that all chemicals in use have been approved.

       2) Educatdedvii employees on this procedure and the requirementsfor ordering chemicals.

       3) Ensurethat an MSDS is maintained for each chemical used i their work ama iSnd avaibbke for all
                                                                  n

       4) Pennit only authorized empkyees to use or handle potentially hazardous materials.

       5) Ensure that each employee has received HAZCOM training for each chemical hdshe uses.




    E. Sourcing ManagerBuyers must:
       1) Verify that all chemical purchases are on the Approved Chemical List for the site@)of intended use.

       2) Ensure that new chemical purchases have been approved by EHS at all sites of intended use prior
          to procuremant.

       3) Retum all requests for materials that do not appear on the Chemical Approved List. In the case of
          newly approved chemicals, an EHS approved MatetialApproval Form, for each site of intended use,
          shc& a a " y t h e R F M .
       4) Require that all purchase orders for new chemicals o chemicals already in use have a statement
                                                             r
          requiring that an MSDS be sent with the order and to the plant specific EHS manager

        Buyers are responsible for ensuring that no unapproved chemicals are
        purchased

    IV. Restricted Procurement Methods
      A. Chemical material purchases are       to be made using credit cards for reimbursement.

      8. Chemical materials are      to be routineiy purchased using ~$1000methods or blanket purchase
        orders. In the event that an emergency situation requires purchase using the above methods, the
        purchaser must provide a copy of the MSDS to plant EHS Coordinator for review and approval prior to
        procurement.

    V. Other Related Chemical Material Requirements

      A. Suppliers are prohibitedfrom bringing chemicals on-site for trial purposes without prior approval from
         the plant EHS Coordinator. Recipients of trial materials should submit Material Approval Forms and
         appropriate MSDSs to plant EHS Coordinator.
B.    Contractors are prohbied from bringing chemicals on-site Withoul receiving prior approval from plant
     EHS Coordinator. Engineers requesting contractor services must verify that MSDSs have been
     fumished prior to work start up. Additionally, arrangements must be made for the remval of chemic,
     brought on-site by contractors.
                                                                                                              >
C.    GE employees. including those from other plants, are not permittedto bring chemical materials on-site
     unless they are on the Approved Chemical List. Plant EHS Coordinator approval must be obtained vie
     the Material Appwal Form and an MSDS prior to bringing the chemicalon-sile.


D. MSDSs must also be providedfor free chemical samples.
                               GE Power Generation
                            Material Approval Request Form
                               mhrmwhpn-rmhpwrtow
                                p"mwdn.rmUfdahyov~W
                               OblllinMSD$aWhbthlllUdMbWS


 Date                                           Site
Product Name
ProductManuiacturer
Supplier
Pmdud Use
                  l(
OuanUty to be usede Ibs., gals.,)                             /month         /vr
-Ofuse
Does the operallon already use a chemical that can perform thls function?-
Will this replace existing material?          Yes      -No
   ll yes, what material is being replaced?
   Will replaced material need to be disposed of?            Yes             No
Requester Name


To be completed by EHS (Review EHS Checkllst)
EHS Appmval Given?              Yes             No
Chemical Control ID t
Hazardous / Toxic Material?
Envimmentai. Health 6 Safety Requirements


EHS Appmval Signature                                      Date
Added to Approved Chemical Lis17                     Yes    Date
Fax Form and MSDS sheet@)to:
                         FAX                  PHONE         CONTACT
Greenville           8'288-2780         8'286-2355         Thad Leister
Schenectady          8'235.0627         8'2359184          Don Huckabay
ntchhrg              8'234-1459         8'234-1766         Paul Waterman
Bangor               8'580-2529         8'560-2558         Jim Crawlord
Lynn                 8'263-9457         8'263-3315         Dale Ashley
'3
              c
              0
              e
              0
              e
              e
              n
I   *%   Ix   t
              0
              e
              (0
              0
              E
              5
              I
              X




                      -
                      ul
                      &I

                      5
                      2
              c
              .-
               0
                      .
                      0
                      2
                      ul
                      m
              e       C
              m       ti
                      .
              0
              E
              E       P
                      m
              E       C
              8
              2 a
              - 0
               m
              .- 2
               c
               0 0
              c  0
              a       2
              0
              a
                  I
                      z"
                       I
              m       0
3
                                     L
Chemical Management                                     One-For-One Replacement


         s
    What I A "One-For-One" Chemical / Waste Replacement Process?

          A chemical must be exhausted before it is replaced
          (exchange an empty container for a full container)

    "One-For-One" Replacement Ensures That:
            Chemical inventory on plant floor is minimized
            Usage and disposal is tracked
            Containers are approved and properly labeled
            Fixed order / release quantities are used
            Temperature / Pressure sensitive risk is minimized

    Critical Success Factors
             Chemicals must be delivered on same day that they are promised
             Should be implemented concurrently with chemical handling team
             Define maximum / minimum .use quantities
               "One-For-One" Replacement Guideline

Getting Started
  Prior to implementing a "One-For-One" replacement system, it is important to
  understand the current manufacturing and chemical distribution processes. Queaions
  to heighten process awareness include:
   Has chemical usage been quantified for all production stations?
   How are chemical inventory levels currently monitored or controlled?
   How many people are involved in the chemical distribution process?
  Once these questions have been answered, implementation can begin       ...
How to Implemnt
  Step 1.   Determine which operations a 'One-For-One' replacement system will
            apply. The first candidates for 'One-For-One' replacement should be
            hazardous chemicals.
  Step 2.   For the operations targeted, understand current usage requirements,
            and which employees are involved in the processes.                         \
                                                                                       I


  Step 3.   Analyze inventory on hand and required order quantities. Need to
            ensure that appropriate inventory levels are maintained.
  Step 4.   Educate and train all employees who will use 'One-For-One'
            replacement routines. Clearly establish roles and responsibilities, and
            communicate the benefits of this system.
  Step 5.   Remove all excess inventory off the floor. Chemicals must be
            distributed out of a central area.
  Step 6.   Implement 'One-For-One' replacement routines
   G                                  b
Chemlcal Handling                             Example: One-For-One Replacement



 Here Is How A Typical "One-For-One" Replacement Works     ...

                         .---




  Elements Of A Successful "One-For-One: Replacement Process:
           Chemicals must be delivered on the same day they are requested
           Should be implemented concurrently with chemical handling process
3
             lntegrated Chemical Supplier
3                      Getting Started


    Approved Chemical Listing for each facility
    Understanding the process of how chemicals enter the facility
                  --
        (Order Delivery Cycle)
    Chemical Sweeps completed
    Procurement policy for chemicals


    Form a Cross-functional core team with representation from:
                 - EHS'
                 - Sourcing'
                 - Finance
                 - Manufacturing
                 - Engineering
                 - Legal
                 - Labor Relations
        Sourcing & EHS are Co-leaders for Project Management
    Determine Chemicals to be handled through the supplier

        -   Information required: Listing of chemicals purchased,
             annual quantities, annual expense, & vendor name
        -   Phased Approach suggested focusing on Indirect
            chemicals initially and then transition to direct chemicals

    Decide upon services to be provided by an lntegrated
    Chemical Supplier as a team
        See Attachment for Services

    Determine Pilot location for implementation
        -   A Pilot location is suggested because of the magnitude
            of the effort as well as the ability to take lessons learned
            and transfer for smooth transition at other facilities
What worked well:
      Top Management buy-in to program
      GE employee on-site at vendor to coordinate issues on
      both sides
      Effective cross-functionalteam - Sourcing & EHS
      are key players
      Sourcing resource-- dotted line to EHS
      Focus first on Indirect Costs
      IntegratedSupplier initiative tied to businessobjectives
      Effectively teamed Integrated Supplier with 2nd tier chemical
      suppliers during planning
      Cost savings are being felt - especially in procurement cost
      reductions
      Supplier is a partner - "open-book" mentality
What should have been done differently:
      EstablishChemical Management Process prior to Implementation
      More defined statement of work - Avoid "dumping" on supplier.
      Dedicated GE Project Manager during development &
         implementation
      Evaluationof internal systems &what is neededto support
      the process before you begin
                           GEhWldsyrtrmr

           PRODUCT QUALITY POUCY I PROCEDUREI l"RUCn0N

SURIECT: SUPPUER APPRAISAL AND APPROVAL

                       Supplior EHS Evrlurtlon Form                    ExbibU

     1.

                                                      YES NO     N/A
     2
                                                      YES NO     NIA
    .
    3
                                                      YES NO     NIA
    4.
                                                      YES NO     NIA
    5.
                                                      YES NO     NIA
    6.
                                                      YES   NO   NIA
    7.
                                                      YES NO     NIA
    a
                                                      YES NO     NIA
    9.
                                                      YES NO     NIA
    IO.
                                                      YE8 NO     NIA
    11.
                                                      YES NO     NIA
    12.
                                                      YES NO     NIA
    13.
                                                      YES NO     NIA

    14.
                                                      YES NO     NIA
                                                                            1
              PRODUCT OUAUrV POLICY I PROCEDUREI I ~ U C T I O N
DATEPISUED: -1                           NUMBER: 320W        PAQE: 11
  SUBJECT: SUPPLIER APPRAISAL AND APPROVAL
                                                                            I
        15.
                                                        YES NO   MA
       16.
                                                        YES NO   NIA
       17.
                                                        YES NO   NIA
       18.
                                                        YES NO   NIA
       19.

                                                        YES NO   NIA
       20.                                              YES NO   NIA
       21.
                                                        YES NO   NIA
       22.
                                                        YES NO   NIA
       23.
                                                        YES NO   NIA
      24.




                                                                        I
                  PRACTICES
            GE BEST      DOCUMENT
          REGULATORY-REQUIRED
                         EHS TRAINING

                                    INTRODUCTION

This Best Practices document provides guidance to GEs plant management, training
professionals, and attomeys as well as Environmental, Health, and Safety (EHS)
Professionals in identifjmg employee training required by environmental, health, and
safety regulations. The information contained in this document will help the EHS
professional identify the regulatory-required training needs geared to the individual w r
                                                                                       ok
place and workforce.

It is a laborious task to sift through the lengthy and complex environmental, health, and
safety   standards to identify all the training requirements for your facility. This document
will assist you in that effort. T a n n requirements identified in the following federal
                                  riig
regulations are collected in this document and arranged in a fonnat so you can identify
those which apply to employees at your facility:
-
          Occupational Safety and Health Administration (OSHA)
                                                             Standards
          Environmental Protection Agency (EPA) Regulations
          Department of Transportation (DOT) Regulations

The EHS training requirements identified in this document are regulatory-required
activities. U e of this Best Practices document will assist GE businesses in complying
             s
with the regulations. It is important to note that this document does not address training
that falls outside regulatory requirements but is called for by company policy or Best
Ractices such as the POWER (pOllution Naste and Emission Reduction), Ergonomics,
and PEP (Illant Emergency “aredness)        programs.

A successful strategy includes effective training presentations and thorough
documentation of training activities. The first part of this document contains suggested


                                                     MI1993
                                                   Page 1
procedures for identifying the employees who require training, selecting training
materials, and keeping records of training activities.

The second part of this document begins with a table listing typical work activities and
the associated training requirements. The table is arranged so that the users can quickly
select those work activities pertaining to pertinent business operations. The h q h g
requirements associated with each work activity are briefly outlined in the table. The
table provides a cross reference for specific training requirements. Details are provided in
subsequent pages in Appendix A.
     Many environmental, health, and safety regulations issued by federal, state, and local
     agencies incllide provisions for employee training. Some regulations are quite detailed,
     specifying the number of classroom and on-the-job training hours required for initial and
     refiesher training, while others reference only "qualified personnel".

     OSHA
     The Occupational Safety and Health Administration (OSHA) issues regulations dealing
     with employee occupational safety. The bulk of the EHS regulatory training
     requirements are contained in OSHA's standards. The OSHA training requirements
                                          SAs
     included in Appendix A are found in O H ' General lndustry Standards. If activities at
     your facility are covered by OSHA's Maritime, Construction, or Agricultural Industry
     Standards,you will need to review these regulations for additional training requirements.
     In addition to regulations, OSHA also issues guidelines containing u s 4 information for
     training course content. These guidelines are referenced in Appendix B.
i>
     As a general rule, you may note that the older OSHA standards have vague requirements
     for training content and timefnunes. The newly-promulgated o newly-revised OSHA
                                                                  r
     standards are more specific. sometimes giving definite timefimes and training topics to
     be covered. As OSHA continues to review and revise its older standards, such
     performance-oriented training requirements will become the norm.

     EPA
     The Environmental Protection Agency (EPA) issues regulations specifying procedures
     and standards t protect the environment and the public's safety. Included in these
                     o
     regulations are training requirements for employees whose work responsibilities include
     handling hazardous materials, solid and hazardous wastes, or operating systems that may
     result in emissions to the environment.

     The regulations issued by the EPA as a result of the Resource Conservation and Recovery
     Act (RCRA)    contain training requirements for employees who handle hazardous wastes.
     The type and amount of training required depends on the type of waste management
     practices at your facility.



                                                       Am1 I993
                                                      Page 3
         DOT
         The Department of Transportation (DOT) issues regulations addressing the safe
         packaging, handling, and m s p o r r of hazardous materials. These regulations are
         applicable to transporters and shippers who offer hazardous materials for transport.
         Training requirements contained in DOT regulations applicable to many GE facilities are
         those which address employees involved in hazardous materials transportation safety.
         The DOT training requirements apply to anyone who is employed by a hazardous
         materials shipper, carrier, or package manufacturer and who directly affects hazardous
         materials transportation safety during employment.

         State and Local Regulations
         In addition to the federal regulations identified in Table 1, numerous state and local EHS
         regulations also contain similar training requirements for employees. It is beyond the
         scope of this Best Practices document to identlfy all the state and local EHS training
         requirements. If you are uncertain of training requirements contained in state and local
         EHS regulations, contact the individual regulatory agencies for assistance.

         EHS personnel at othm GE facilities located in the same state may also be a good source
         of information about state regulations. Use the GE EHS Directory to identify these
         individuals. GE State Environets, organized by GE Government Relations, are already          i
         established in approximately 20 states to provide a network through which GE facilities
         located in the same state can exchange environmental information. Call your state
         government relations contact or Susan Walter, Vice President-State Government
         Relations, (202) 637-4450/8*272-4450, for information on the GE State Environet
         program.

         OSHA encourages states to develop and operate their own workplace health and safety
         programs. These programs must be "at least as effective" as the federal program, and in
         many cases are more stringent. Any health and safety program must comply with the
         requirements of the state program in which the facility is located. Compliance is not
.   ..   dependent on the location of corporate headquarters, state of incorpOration, etc., but on
         the physical location of the facility i question.
                                                n




         Remlalav-Rmumd EHS &
                            T                               -1993                    ornarlElmric
                                                          Page 4
3   For your reference, there are OSHA state plans covering businesses in the private sector
     in effect in the following states and commonwealths:

                 Alaska                     Arizona                     California
                 Hawaii                     Indiana                     Iowa
                 Kentucky                   Maryland                    Michigan
                 Minnesota                  Nevada                      New Mexico
                 North Carolina             Oregon                      Puerto Rico
                 south Carolina             Tennessee                   Utah
                 Vermont                    Virgin Islands              Virginia
                 Washington                 Wyoming


    CE Best Practices
    Training needed to safely perform work and protect the environment is not always
    specified directly in EHS regulations. You should consult GE Company Policy 20.3,
    Health, Safety, and Environmental Protection; the Procedure for Implementation of
    Health, Safety, and Environmental Protection Policy; and several GE Best Practices
    documents to understand the degree of training GE believes should take place. The
    Policy, Procedure, and Best Practices documents are a d a b l e through Corporate
    Environmental Programs (CEP). Several Best Practices documents are included in the
    list of useful references in Appendix B.

    Sources of Information
    Thew are several useful sources of information on EHS training requirements besides
    reading through the regulations. One source of information is Training Requirements in
    OSHA Standards and Training Guidelines, 1992. Single copies are available at no charge
    from your local OSHA office. State regulatory agencies may also be able to provide
    summaries of mining requirements contained in their regulations.

    Many GE facilities are using the Enflex Info@ system, a computer database containing
    federal and state environmental, health, and safety regulations. Information contained in
    the Enflex Info@ system can be retrieved using a key word search. The Enflex Info@
    system can identify regulatory training requirements by searching for the key words
    " r i , "training," "competent," "qualified," etc. The output will need to be reviewed to
     tan"
    determine those requirements applicable to your facility. Combining the key words
    "train"or "training" with words that describe certain job activities such as "mechanical
    power press," or "respiratory protection" will help to focus the output on operations
    applicable to your facility. For more information on Enflex Info@, contact ERM

                      . .                                                               c
Information Services, Inc., 855 Springdale Dr.,Exton, Pennsylvania, 19341, (800) 544-
                                                                                          1
3 1 18. GE has an agreement with ERM Information Services to provide Enflex Info@
systems to GE businesses at a discount.

Table 1 contains a list of training requirements grouped according to type of work
activity. The table is armnged so that the EHS Professional and other users can quickly
identie those work activities pertaining to facility operations.

Additional EHS regulatory training references are provided in Appendix B
               SUCCESSFUL " I N G               PROGRAM STRATEGY


A successful EHS-training program includes a plan to address all the identified training
needs for a facility on a continuing basis. Establishing a trahhg plan'allows the EHS
and business training professionals the opportunity to schedule and manage the training
program in an efficient manner. In addition, a written EHS-training program can be used
to present training requirements to upper management so that the training program,
including the program budget, can be a part of the facility's business plan.

Determine the Training Requirements
When developing an EHS-training program, start by identifying the training required for
employees at your facility. Many regulatory training requirements applicable to GE
facilities arc listed in Table 1. Other training requirements are found in state and local
regulations, in GE Best Practices documents, and in policies established for your facility.

Consider the following when developing a list of training requirements for your facility:

          Work activities currently in place at your facility that have training
          requirements

          Anticipated changes in the workforce responsibilities that will alter training
          requirements

          New equipment or processes that may mgger additional training requirements

          Modified work methods or job responsibilities that will require new or modified
         training

         Seasonal or non-routine work assignments subject to regulatory training
         requirements

         Training programs that may help to reduce or eliminate workplace injuries

Determine the type and frequency of training needed to meet the identified training
requirements. A few regulations are very specific as to the type of training, such as
classroom or hands-on, minimum number of training hours, and training frequency.
However, many training requirements, particularly those contained in older OSHA

                    . .
                                                   Page 7
standards, do not specify trairiing program content or frequency.
                                                                                              ?
Five OSHA Regional offices were contacted to determine how OSHA evaluates the
adequacy of training programs when regulations do not specify content or frequency.
OSHA responded that training should be performance oriented, relative to the hazard
level of a particular activity. With this guidance in mind, the content and frequency of
mining when none is specified will often be up to the best judgment of the EHS or
training professional, who must analyze the hazards involved in a particular activity and
determine what training is appropriate to mitigate the hazard. Table 1 and Appendix A
contain recommended training fkequency and content when none is specified in the
regulation. These recommendations should be considered "Best Practices" to assist you
in developing your training program.

Once the training requirements have been identified, identify the type and number of
employees that must be trained. include new hires or transferred employees subject to
initial training requirements and those employees subject to review training requirements.

The form shown in Figure 1 is used by several GE businesses and may help you to
identify the training requirements and develop a training program budget for your facility.
The budget must include hours employees will spend away fkom the job to receive
training. This can represent a significant investment for a facility. Plant management        1
should understand and approve of the time commitment needed to comply with EHS
regulatory training requirements.




Repul.lorv-Rmurrad EHS Tnuvn~                      hDnl15'93                Gsrnl E l m e
                                                 Page 8
3,
                                                          Figure 1

                                              EHS Training Needs Analysis

                                   Training                  . ,
     Trainiog   Numberof           coune                                           course    Total
      Topic     EmIoveu            Mated        initial    Annual                  HoUn      Hours




            R r a v d EHS TRvlmn                                      r\olil1993       (n lEltnnC
                                                                                        i m
                                                                     Page 9
         Training Materials
         The next step in developing an EHS-training program is to select the materials, course
         content, and instructors that will provide the required degree of training. You may design
         and conduct your own training course or take advantage of several training resources
         available to assist EHS and training professionals. The GE HazCom Training Program
         and the DrakeComputer-Based Environmental, Health, and Safety Training Systems are
         available through CEP. The Drake System, which has been purchased by GE for use m
         its operations, is an application of computer-based, self-paced instruction in the
         environmental, health, and safety areas. Additional GE guidance documents and mining
         programs available through CEP are listed in Appendix B.

         Your business group's employee training organization can be a great resource during the
         development and implementation of EHS training programs. They may have instructors
         on staff that can assist you in identifying and conducting effective training programs.
         They may also be able to provide classrooms complete with audio/visual equipment.

         Commercially-prepared training programs can be rented or purchased in video format.
         Training programs are sometimes available through the community fire, emergency
         response, and medical organizations or your local safety council. T o or equipment
                                                                              ol
         specific training, such as tools activated by explosive devices and self-contained           i
         breathing apparatus, can often be obtained through the vendors of these products.
         Training consultants are also available to develop and conduct training programs. Local
         colleges and universities are another potential source of training courses. Additionally,
         OSHA, through NTIS and GPO, offers training materials on many of the OSHA
         standards. A copy of the publication "OSHA Publications and Audiovisual Programs"
         (OSHA 2019), 1989 revised, is available free of charge fiom your local OSHA office.

         Evaluate the curriculum of several training courses to find those which best meet your
                                     os
         facility's training needs: D e the course meet the training requirements for content
         frequency, and duration? Is the material presented in an interesting and'effective
         manner? You may have to augment commercially-prepared training programs to include
-.   -   site-specific instructions and guidelines. Select the training courses which fulfill the
         training requirements and are compatible with your facility's culture and environment.
    I

    I
            I

            I            --
                              I
                              Awareness
                              I
                               -
                              Executlve
                              Management
I
    I
    I   I
            II   -??Re            -...

1 1 1 1                       IProduCt Life Cycle
                               _ _
                              IEHS Finance
                                       - _.
1 1 1 1                       1”Green”Marketing
                                            - -
                              I ween ratR3iTba
                                              e-
                               Lonrracr6FS h v n
                               New Employee
                               otners....


                              Skl11
                              Regulatory
                              Regulred




                                                    c
'3
3
                   Employee Training 'Tracking" System


3   Gonoral
      A great deal of training is required for employees to work in a Safe environment.
      This training includes hazardous communication (HUCOM), job related (forklift,
      drill press, etc.), compliance, and testing (physicals, exposure, etc.) training. Not
      many employees will need to have all the training offered, but it is important to have
      all employees properly trained in both their specific job responsibilities, and work
      areas.

    Putposo
      The purpose of this section is to offer some help in establishing an employee
      training tracking system. The system should be designed to:
       Document training requirements for each job classification
                                          -
       Tradc employee training history both initial and refresher training
       Provide flagging mechanism for employees who require specific training before
       working in certain areas

    Bonoflts
       Comply with OSHA requirement to manage employee training
       Improve employee safety
       Provide a safe environment     '



       Reduce workman's compensfition claims 8 premiums
       Reduce number of OSHA recordables
                    Employee Training "Tracking" System

    How To Implomont
3      Step 1,   Ensure complete documentation for each job classification
       Step 2.   Complete safety analysis for each job classification to assess employee
                 training requirements
      Step 3.    Complete work area safety analysis for each plant area to assess special
                 training requirements
      Step 4.    Establish a database of all employees, and the training they have
                          -
                 received Include information such as the type,frequency, and recency
                 of training received
      Step 5.    Reconale each employee's training history with current training
                 requirements
      Step 6 Obtain or create the course materials for all levels of training required
            .
      Step 7.    Communicate to all employees training requirements for each specific
                 job and work area
      Step 8.    Establish a training schedule to include all necessary courses
      Step 9.    Establish a goal (date) by which all employees must have taken training
                 specific to their work area
      Step IO. Update traininp database as employees take courses
      Step 11. Develop training database ability to flag training requirements when
               employees switch jobs or move to a different work area
      Step 12. Communicate new training requirements to these employees as
               appropriate

    Critical Succou Factors
      1.         New hires and temporary employees must take all applicable training
                       commencing their assigned duties in the plant
      2.         Key aspects of training must be reinforced on a regular basis.
      3.         Training responsibiliies must not rest alone with the EHS coordinator.
                 Plant leaden (Plant Mgr, MSO, shift leaden) must be,actively involved!
      4.         Keep the training as simple and interesting as possible.

3
3
   L                                   I

                                       'b                                 d
Chemical Management                                     One-For-One Replacement


         s
    What I A "One-For-One" Chemical / Waste Replacement Process?

          A chemical must be exhausted before it is replaced
           (exchange an empty container for a full container)

    "One-For-One" Replacement Ensures That:
            Chemical inventory on plant floor is minimized
            Usage and disposal is tracked
            Containers are approved and properly labeled
            Fixed order / release quantities are used
            Temperature / Pressure sensitive risk is minimized
            Hazardous containers are properly disposed

    Critical Success Factors
             Chemicals must be delivered on same day that they are promised
             Should be implemented concurrently with chemical handling team
             Define maximum / minimum use quantities
               "One-For-One" Replacement Guideline

Getting Started
  Prior to implementing a "One-For-One" replacement system, it is important to
  understand the current manufacturing and chemical distribution processes. Questions
  to heighten process awareness include:
   Has chemical usage been quantified for all production stations?
   How are chemical inventory levels currently monitored or controlled?
   How many people are involved in the chemical distribution process?
  Once these questions have been answered, implementation can begin...

How to Implement
  Step 1.   Determine which operations a "One-For-One" replacement system will
            apply. The first candidates for "One-For-One" replacement should be
            hazardous chemicals.
  Step 2.   For the operations targeted, understand current usage requirements,
            and which employees are involved in the processes.
  Step 3.   Analyze inventory on hand and required order quantities. Need to
            ensure that appropriate inventory levels are maintained.
  Step 4.   Educate and train all employees who will use "One-For-One"
            replacement routines. Clearly establish roles and responsibilities, and
            communicate the benefits of this system.
  Step 5.   Remove all excess inventory off the floor. Chemicals must be
            distributed out of a central area.
  Step 6.   Implement "One-For-One" replacement routines
            .
       6                                               7


   LJ
Chemical Handling
                                                       LL)
                                                                                          d
                                                             Example: One-For-One Replac ment



 Here Is How A Typical "One-For-One" Replacement Works                  ...

   I   --   No replenishment required   p- - - - ,No
                                         -
                                                 I
   I
   '
                        Request
                        Chemical




  Elements Of A Successful "One-For-One" Replacement Process:
                      Chemicals must be delivered on the same day they are requested
                      Should be implemented concurrently with chemical handling process
c




     "Cradle To Grave" Ownership & Training

    Ownership Overview
    Employee Training Tracking System (Example)
   L                                     1
                                          1
                                          u                                      LI
Chemical Manaaement                                                        Ownership

  What is Cradle to Grave Ownership?
     Accountability for every chemical in the plant from receiving to disposal


  Ownership Ensures That:
        Chemicals are tracked from receiving to disposal
        All chemicals properly enter the plant
        Employees are trained to handle chemicals
        Waste and obsolete chemicals are disposed correctly



  Who has Ownership?
       Individuals with overall accountability for specific processes or areas
       Everyone who handles a chemical




                        Ownership Will Drive Compliance!          I
3




'3
3                    Cradle to Grave Ownership

    Steps in Establishing Ownership:
    1. Communicate the need for ownership and the associated benefits
    2. Select individuals with responsibility / accountability for s ecific
                                                                   8
       processes or areas in the facility (examples might inclu e MSOs,
       area or process engineers, floor supervisors etc...)
    3. Select and then train owners on their specific responsibilities (i.e.):
            Ensure all chemicals are tracked
            Ensure chemicals are fully documented (MSDS)
            Ensure all employees are trained
            Ensure distribution and disposal procedures are established
    4. Develop and communicate specific measurements
    5. Reinforce measurements on an ongoing basis (hold owners
       accountable)
    6. For any issues that arise ensure that owners are responsible for
       taking appropriate corrective action
               Employee Training "Tracking" System


General
  A great deal of training is required for employees to work in a safe environment.
  This training includes hazardous communication (HAZCOM), job related (forklift,
  drill press, etc.), compliance, and testing (physicals, exposure, etc.) training. Not
  many employees will need to have all the training offered, but it is important to have
  all employees properly trained in both their specific job responsibilities, and work
  areas.

Purpose
  The purpose of this section is to offer some help in establishing an employee
  training tracking system. The system should be designed to:
   Document training requirements for each job classification
                                    -
   Track employee training history both initial and refresher training
   Provide flagging mechanism for employees who require specific training before
   working in certain areas

Benefits
    Comply with OSHA requirement to manage employee training
    Improve employee safety
    Provide a safe environment
    Reduce workman's compensation claims & premiums
    Reduce number of OSHA recordables
                     Employee Training "Tracking" System

 -)    HOW TO   implement
         Step 1.   Ensure complete documentation for each job classification
         Step 2.   Complete safety analysis for each job classification to assess employee
                   training requirements
         Step 3.   Complete work area safety analysis for each plant area to assess special
                   training requirements
         Step 4.   Establish a database of all employees, and the training they have
                            -
                   received Include information such as the type, frequency, and recency
                   of training received
         Step 5.   Reconale each employee's training history with current training
                   requirements
         Step 6.   Obtain or create the course materials for all levels of training required
         Step 7.   Communicate to all employees training requirements for each specific
                   job and work area
         Step 8.   Establish a training schedule to include all necessary courses
 :Is
.-       Step 9.   Establish a goal (date) by which all employees must have taken training
                   specific to their work area
         Step 10. Update training database as employees take courses
         Step 11. Develop training database ability to flag training requirements when
                  employees switch jobs or move to a different work area
         Step 12. Communicate new training requirements to these employees as
                  appropriate

       Critical Success Factors
         1.        New hires and temporary employees must take all applicable training
                   bafpre commencing their assigned duties in the plant

         2.        Key aspects of training must be reinforced on a regular basis.

         3.        Training responsibilities must not rest alone with the EHS coordinator.
                   Plant leaders (Plant Mgr, MSO, shift leaders) must be actively involved!
         4.        Keep the training as simple and interesting as possible.
3
3
     Larm                     Detinltion
7    Approved Chemical List   A listing of approved chemicals authorized for use the
                              plant. It is to be used as a control reference prior to
                              chemical procurement and receiving.
     Assessment Checklist     A tool used to identify potential compliance exposures
                               Questions to pinpoint routine and control breakdowns
     CEP                      Corporate Environmental Programs (Steve Ramsey's
                              Organization)
     CAS                      Corporate Audit Staff
     CERCLA                   Comprehensive Environmental Response,
                                                            -
                              Compensation, & Liability Act Act to create corporate
                              liability for Superfund site cleanup
     Chemical                 A liquid, gas, solid or powder which in normal use has
                              the potential to cause a health and/or physical hazard,
                              or the release of toxics into the environment. This
                              definition also includes any new materials that will be
                              created during the manufacturing process, either as
                              intermediates, by-products, or wastes.
1)   Chemical Handling Team   A group of employees trained and responsible for
                              chemical movement in the plant.
     Contractor               External supplier engaged to provide various plant
                              services
     Cradle To Grave          Accountability for every chemical in the plant from
                              receiving to disposal
     EHS                      Environmental Health & Safety
     EHS Checklist            Tool to use to function as a "Red Flag" for identifying
                              items or issues of EHS impact or regulatory concern.
                              Any issues identified via the checklist should be raised
                              in feasibility and producibility reviews before approval.
     GEGS Codes               GE Goods & Services Codes used throughout the
                              company to provide useful pricing and trend data
     HAZCOM                   Hazardous Communication; OSHA's most
                              comprehensive worker protection regulation providing
                              training for workers encountering chemicals in the
                              workplace.


                                    Pagelof4
                            Glossarv 0f Termg

Larm
Hazardous Waste
                            [)efinitlon
                            Any chemical waste which poses a physical or health
                                                                                         >
                            hazard. Includes chemicals that cause an acute or
                            chronic health problem, such as carcinogens, toxic
                            agents, reproductive toxins, irritants, corrosives, etc.
                            Also includes combustible liquids, compressed gas,
                            explosive, flammable and other unstable chemicals
                            which cause physical harm.
Implementation Guidelines   Guidelines to be used in the execution of suggested
                            actions
In-Plant Controls           Controls in place at a plant to ensure the proper
                            storage, distribution and usage of chemicals
Integrated Supplier         A supplier dedicated to providing Chemical
                            Management services from cradle to grave
Major Technical Change       Change affects product functionality, performance or
                             quality
                             Change requires analysis and/or testing prior to
                             approval
                             Change outside engineering specifications
Minor Technical Change       Change that supports manufacturing process, but has
                             no direct impact on product (Used to provide
                             chronology of changes for cause-effect analysis if
                             product problem occurs)
                             Change within engineering specifications

MSDS                                                     -
                            Material Safety Data Sheet A technical bulletin
                            required by OSHA which contains information about a
                            chemical material regarding its identity, chemical and
                            physical characteristics, health and safety data, and
                            precautions necessary for safe handling and use
New Product Introduction    Introduction of a product that has substantially different
                            physical characteristics andlor functionality than other
                            models or products

New Use                     The "New Use" of a chemical material includes the
                            following:
                              Introducing a chemical material into a work area
                              which is not on the Approved Chemical List
                              Introducing a different use of a chemical material in
                              an approved work area using quantities larger than
                              quantities originally approved


                                  Page2of4
                        Glossarv 0f Terms

IQLul
Non-Controlled Points   Points within the plant where chemicals can be
                        received or enter without being reviewed against an
                        Approved Chemical List
NRC                     Nuclear Regulatory Commission
Obsolete Chemical       Chemical which is no longer used in the production
                        process and has no use in the foreseeable future.
One-For-One             Concept whereby a chemical container must be
                        exhausted before it is replaced (i.e. Exchanging an
                        empty container for a full one)
OSHA                    Occupational Safety & Work Act requires employers to
                        furnish places of employment free from recognized
                        hazards that may cause death ar serious physical
                        harm to employers.
PEL                                               -
                        Personal Exposure Limit OSHA imposed limits for
                        worker exposure to various substances that may be
                        harmful.
Physical Inventory      Structured effort to completely document the identity,
                        quantity, type, and location of all chemicals in a plant
Process Map             Equivalent to a flow chart. Flow chart is a pictorial
                        representation showing all of the steps of a process.
Procurement Controls    Controls in place to ensure that no unapproved
                        chemicals enter the plant

SARA                    Superfund Amendments & Reauthorization Act of 1986
                        (Community Right-To-Know) requires annual
                        disclosure of the storage and usage of hazardous
                        chemicals
Secondary Containers    Any container other than an original container
Solution Menu (SM)      Section in package that highlights issues, associated
                        risks, & solutions for "No" answers on assessment
                        checklist

Subcontractor           External supplier engaged to provide various plant
                                 -
                        services working as secondary contractor to the
                        general contractor (See Contractor)



                              Page 3 of4
                          Glossarv 0f Terms
Iarm                      Detinitian
Technical Changes         Changes that impact product quality, performance,
                          dimensions, or material composition. Technical
                          changes can be categorized as either "Major" or
                          "Minor"
TSCA                      Toxic Substance Control Act regulates the
                          development, manufacture, distribution, use, and
                          disposal of over 60,000 chemicals. Chemicals cannot
                          be manufactured or distributed in the United States
                          unless they have been included on the TSCA
                          Chemical Inventory.
Unapproved Chemical       Chemical which is not on the Approved Chemical List,
                          and should not be present in the facility (See
                          Approved Chemical List)
Unclassified Container    Unlabeled secondary container which is unapproved
                          for chemical storage and use
Unidentified Chemical     Chemical stored in an unlabeled container

Up-Front Controls         Controls in place at a plant to ensure that EHS
                          concems are raised and addressed before new
                          products and technical changes are approved
Waste Stream Management   Controls in place at a plant to ensure that waste
                          accumulation routines are adequate, and that waste
                          streams have been properly identified and are
                          controlled
90 Day Rule               A waste generator must not accumulate hazardous
                          waste on site for more than 90 days.
      L

                                          Additional Best Practices


Tab 1 New Product I Technical Changes                          Tab 4 Integrated Supplier
      New Product Introduction Procedure (GEIPS - PDO)                                             -
                                                                      Integrated Chemical Supplier Getting Started
      EHS Evaluation for New and Modified Processes and               Product Quality Policy/Procedure/lnstnrction
                           -
        Equipment (GEIPS ASD)                                              (GE Medical Systems)

Tab 2 Chemical Procurement Policy & Receiving Procedure        Tab 5 Cradle-to-Grave Ownership
                                                                     Training
      Receipt of Chemical Material (GEIPS - Greenville)              Measurement
      Communications: New Chemical Ordering (GEAE - Lynn)            CM Roles & Responsibilities
      Blanket Purchase Orders (GEIPS)
      Chemical Review Request Form (GE Motors - Broadway)             GE Best Practice:Regulatory-RequiredEHS Training(CEP)
      GE Power Gen. Chemical Material Procurement Policy                  (including needs assessment and tracking)
      Chemical Appraisal Procurement Process Training Manual          Measurements: Progress Summary (CAS, CEP)
         to be used by Requestors and Buyers                          EHS Measurement Process (GEAE)
                                                                      Chemical Management Functions and Responsibilities
                                                                          (GEIPS)
                                                                      Key Roles and Responsibilities
                                                                      GETS Chemical Control Process

Tab 3 Chemical Handling Process
      One-for-One Replenishment Process
                                                                                                         -
                                                               Tab 6 Conducting a Plant Chemical Sweep A Guidebook
                                                                     For GE Motors
     Requirements for Use of Personal Protective Equipment            Overview
     One-for-One Replacement (CAS)                                    Guidebook
                                                                      Pre-Plant Sweep Evaluation Checklist
                                                                      Sweep Pre-Work Checklist
                                                                      Sample Press Releases
    3   NPI core Team                  Power Generation Engineering
3




                        Executive Summary

                New Product Introduction
                      Guidelines
                              Rev. 2




                                                       Paul D Oei 4/22/93
What is NPI?


New Product Introduction (NPI) is a process by which new products are introduced into the GE Power
Generation product portfolio. It enables those working on new products (or a redesign of existing ones) to
more easily and effectively manage the introduction of those products into the marketplace. “Time to
market” and technology leadership are the major drivers of programs. Setting and meting schedules is
the the priority.

The NPI process provides an important opportunity for GEPG. For our business it offers:
        - maintenance of a strong technology and market share leadership role in the
        marketplace.
        * improved business profitability, driven by
             - design processes that strive for lower cost products
             - design processes which incoporate EHS considerations
             - cost reduction efforts while the competition is trying to match initial releases
             - optimized use of limited personnel and financial resources
        -    - receipt of potential price premiums due to technology leadership
          less risk exposure from changing markets and technology

For our customers it offers:                                        *
        -
        *
             faster access to more innovative products
             increased responsivenessto their needs             I




        -    rapid correctionslimprovements
             prompt considerationof their feedback on the product

For our employees, the process offers:
        --the ability to produce quality products using proven technology
          effectiveleflicient framework for new product introduction
        * greater involvement in a teamwork environment and satisfaction of being part of a
        successful team
        * multifunctionalteams provide greater exposure to overall business and helps create a
          boundaryless environment.
     Process Overview

3    NPI is divided into five phases:
              .   product planning and technology development
                  concept development
             -    system integration
                  detailed design
                  manufacturing. test. delivery and installation

     %duct Planning and Technology Development
     It is in this phase that a product idea comes into being and
     project plans are devebped. In the generation of product ideas,
     new technohies are reviewed and product opportunities are
     identified. Directioncomes from the business's multi-generation
     product plans (MGPP),which drive "offline" technology
     development. A new concept emerges and the definition
     process begins.
     The pcoiect plans are developed during projectlproductdefinition.
     It is the quality of information in this phase that will help
     implementation go as quickly as possible. Inputs from the MGPP
     are refined to validate project feasibility. Inputs from design,
     materials and processes. manufacturing. technology, EHS, '
     distributbn and suppliers, marketing and sales are received.
     MOST IMPORTANTLY, EHS ISSUES ARE IDENTIFIED AND
     RESOLVED. MATERIAL 8 PROCESS TECHNOLOGY AND
     DESIGN TECHNOLOGY READINESS IS ACHIEVED. This
     minimizes delays as the NPI process proceeds.
-3   Concept Development
     During this phase, the conceptual design is developed and
     reviewedby management and all functions. The key here is to
     insure that technological risk is minimized and no fundamental
     design flaws exist prior to implementationof detailed design and
     product manufacture. Design 8 Manufacturing, Materials 8
     Processes. Product and EHS Reviews are requirements in this
     ahase IT I IMPORTANT THAT MATERIALS. PROCESSES
              .. S                 ......
     AND DESIGN SPECIFICATION FREEZE IS AGREED UPON AT
     THE END OF THIS PHASE.
     System Integration
     During t i phase, the teams seek verification that the design is
             hs
     sound from a systems integration standpoint, and completes the
     preliminary design for functionality, reliability and EHS reviews.
     Detailed Design
     During this phase, the design of the product is completed and the
     prototype unit construdion commences.
     Manufacturing. Test, Delivery and Installation
     During this phase, the prototype unit is manufactured. Factory
     and field testing of the prototype unit is completed and the unit is
     delivered with associated drawings and fieid support to an initial
     customer for installation and performance demonstration. In
     addition, pricing, advertising, promotion, merchandising,
     introduction, training, and inventory transition plans are initiated.
Product Planning and
Technology Development

The first phase of NPI is Product Planning and Technology
Development. There are three parts to this phase:                     Product Planning

        ---
                                                                        &Technology
              Product and Technology Planning                           Development
              Material & Process, EHS and Technology Definition
              Material 8 Process, EHS and Technology Review
                                                                              I

Product &Technology Planning
  Develop an integrated Product and Technology Plan that
  provides a three to five year programfunding strategy for
  development of new products, technologies, materials, and
  processes.
  Establish product and technology development priorities with
  specitic programs and goals clearly defined.
- Identify EHS issues and develop plan to resolve them.
  Commit to multiyear funding of programs included in the plan.
  Provide clearer focus on aftermarket opportunities by
  leveraging new unit technologies and designs.

Material & Process, EHS, and Technology Definition
  Identify “owner of program and establish integrated steering,
- team..
   .
  . -. ..
  Deline cost, operational & perlormance criteria (i.e., unit cost,
  efficiencv. etc.)
-
* Define customer needs.
  Specify desired program schedule and development cost.
* Establish and prioritize criteria for evaluation of alternative                        1
  designs.
Material & Process, EHS,and Technology Review
 ldentdy review team and agree on review process.
 Determine whether technology, materials, processes,
 facilities. design tools and methods required are sufficiently
 developed to support the product specification. If not,
 development and qualification are required.
 Identify and resolve any EHS issues (e.g. production of solid
 waste, emissions and discharges, use of restricted chemicals,
 end-of-life product disposition)
 Identify potential barriers.
 Assess the complexity and risk associatedwith the proposed
-program.
 Define capability and boundary conditions 01 required
 manufacturing processes in the world market.
     Concept Development

     The second phase of NPI is Concept Development. There are five
     parts to this phase:
              -    Concept Design and Evaluation
                   Design, Materials and Process Engineering (MPE)&
                   Manufacturing Process Review
                   Product Review
                   EHSReview


     -
                   Productspecification Freeze
     Concept Design and Evaluation
         Develop successful concept@)(i.e., with no fundamental
         design flaws).
         Demonstrate potential of concept(s)to meet requirementsof
         the product specificationthrough computer simulations and
         analyses tools.
         Establish the producibility of the design@).
                                                                           0Concept
                                                                           Development



                                                                             System
                                                                           Integration
     Design, MPE &Manufacturing Product Review
         Review the proposed concept(s) and verly that:
              - the concept meets the requirements of product
              -    specifiiation.
                   it can be designed to cost.                         I
                                                                            Detailed
              --   1can be made, serviced, and repaired.
                   we are ready to freeze the product specification?
                                                                            Design

     Product Review
         Review the rationale for selection of recommended design.
     *   Determine:
              - does business want to proceed given estimated
                program economics and product attributes?                  Installation
              - is the investment plan approved?
              - are we ready to freeze the specMalion?
         Review is a cross-functionalbusiness review.

     -
     EHS Review
         Determine EHS risk of each alternative design.
         Review proposed use of hazardous materials and chemicals

     .   subject to Toxic Substance Control Act (TSCA).
         Review preliminaty Industrial Hygiene Assessment
         Evaluationof fire risk potential
         Review materialdpmesses subject to HazCom requirements.
         Review air emissions, water use/discharge, geographical
         specific considerations, end-of-life disposition, solid waste
         disposal plans.
         Determine are we ready to lreeze the product specification?

     Product Specification Freeze
         Document the agreements reached at Design, MPE, EHS and
         Product Reviews.
         Revise and distribute Product Specification.
         Eliminate alternatives from further consideration.
         Set stage for intensive and focused effort lor remainder of NPI
         process.

'3
System Integration

m e third phase of NPI is System Integration. There are two
parts to this phase:

         -   System & Mechanical Integration (Preliminary Design)
             Functionality, Reliability, & Product Quality Review
             EHS Review

System & Mechanical Integration (Preliminary Design)
                                                                       Concept
    Verify that the selected concept is sound from the standpoint     Development
    of system and mechanical integration.
    Generate preliminary drawings and BOM.
Functionality, Reliability, & Product Quality Review
-   Verify (from an integrated multifunctional standpoint) that the
    design will:
         - function as required.
         - meet reliability goals.
         - meet product quality goals.
EHS Review
                                                                 I
                                                                      A
                                                                      Detailed
-   Make sure that the complete system is evaluated for:
        - Environmental Control Options
                                                                         Design

        - TSCA
        - Hazard Communication Planning
        - Community Right-to-Know                                     Manufacturing,
                                                                                         1
        - EHS Requirements (Permits, licenses and                     Test, Delivery &
           notification; Chemical inventory review and update;          Installation
           Operation; Monitoring, analysis, Inspections &
           regulatory reporting)
        - Training Plan
    Detailed Design
3
    me fourth phase of NPI is Detailed Design.
    Detailed Design
           -   Complete detailed engineering (layouts, schematics,
               etc.)
               Define all infonation needed for production (Le.,
               EOM, drawings, toolings, etc.)
               Design to cost.
               Continue concurrent designfprocess development.
               Design for reduced order to remittance cycle.
               Design for reuse
               Produce prototype hardware.




                                                                     Manufacturing,
                                                                     Test, Delivery 81
Manufacturing,Test, Delivery & Installation

The fifth phase of NPI is Test, Delivery & Installation. There are
three parts to this phase:
         .
         -    Manufacture Prototype Unit
              Define Test Expectations and Design of Experiments
              Factory Tests & Field Tests
              Final Product and EHS Review

Manufacture Prototype Unit
     Prototype is manufactured using rapid
         prototyping (SLA) techniques.

-
Define Test Specifications
    Define:
         -    test expectations.
         -    test instrumentation
         -    data acquisition and analysis methods
         -    acceptance criteria
         -    procedures for retest
         -    manufacturingsupport requirements
         -    field supporl requirements

-
                                                                I
Factory Tests & Field Tests
  Demonstrate ability of components, systems and product to
  meet requirements of product specification.
Final Product and EHS Review
-   Final formal review of actual vs. expected performance of
    product relative to product specification and EHS
-   requirements.
    Provide feedback for use in multigeneration product
    planning.
Best Practices Summary

This section provides a compilation of Best Practices applicable to all NPI efforts.

h2tIii

Product Planning
                                          -.     Establish mission and goals.
                                                 Clear prioritization of projects to permit resource
                                                 dedication and promote rapid completion.
                                               . Focus on life cycle impact, including aftermarket
                                                 planning

Development Teams                         .     Multiiunctionalteams.

                                          -     Dedicatedteams.
                                                Collocated teams.
                                                Integration of suppliers, partners and customers on
                                                teams at the outset.

Leveraging Proven Designs                 -     Development risk should be reduced by
                                                    - leveraging proven designs
                                                    - isolating high risk areas
                                                    - develop contingency plans
Product Definition                        -     Product definition should incorporate clear
                                                understandingof:
                                                     - customer needs and values (customer needs
                                                         mapping)
                                                      - competiior dynamics
                                                Rigorous adherence to the specificationfreeze
                                                discipline is critically important to rapid development.

Design Tools and Methods                    Product and process design must be integratedto
                                            achieve full businesswide benefit (Le.. Integrated
                                            Producl and Process Design).
                                          * Product design must focus on:
                                                 - manufacturability
                                                 - assembly
                                                 - product simplicity
                                                 - maintainability (service and repair)
                                                 - disposal and EHS issues
                                                 - lowest installed cost
                                                 - short order-to-installation cycle
Manufacturing Planning                          CpK focus drives manufaduring qually and
                                                productivity.

Project Management                              Performance to plan rigorously tracked.
                                                Performance includes time dimension.
                                                Post-projectevaluations conducted and results
                                                documented.
                                                Senior leadership role supports empowered,
                                                multilunctional, dedicated team approach.
                                                      - sponsor provides air cover.
                                                      - senior management gives project appropriate
                                                        priority.

Product Commercialization                       Commercialization included in product plan.
3




---
i
..
Environment, Health & Safety
         Evaluation
             for
      New and Modified
  Processes and Equipment



    Issued: September 1991, Revised: December 1992


                                                     Attachment L,
‘3
       cj

EHS Evaluation for New and Modified Processes and Equipment
Purpose of ProcesslEquipmenl Review
Assure compliance with all applicable Federal. state and local regulations and corpaatc policies dating to the selection. installation
and operation of mwlmodificd processes and equipment within ASD facilities.

Key Areas of Concem
    Air. water. hazardous waste and non-hazardous wastes generated from the pnocess/equipment. Emphasis on the minimization of waste
    streams. proper treatment systems are provided. and handling proccdures are in place. .
    Safety and health aspects of equipmnt operation... including chemical handling, guarding, etc.
    Required permits for air emissions and discharges to drain SyStGIIIS (wastewater treatment plant and surface water) arc secured prior to
    operation. Emphasis on waste stream reduction and recycle.

General Review Procedure
    For new equipment purchases:
      I. Manufacturing Engineering and service center EHS contact prepam the attached process review form and attach to PAR.
         Discuss evaluation with Region EHS Specialist and Headquarten EHS staff as required.
     2. Incorporate requirements from the evaluation into the procurement. installation and operation of equipment.
      3. Obtain any permits required to operate equipment with suppon from Region and Headquarters EHS staff.
     4. EHS contact along with support from Region EHS Specialist to assure adequate training on the safe operation of thc equipment
         is provided. Training can be in thc form of inhouse on-the-job training. provided by the equipment manufacturer, a video tape or
         other training sources.
    For modifications to existing pnms~cs cquipmcnk
                                              and
    The major concern is that a modifcation may.change the amount or typc of waste strcams or introduce additional safetyhealth hazards.
      1. ME and service center EHS contact prepare the attached p m s s review form and attach to PAR. Discuss evaluation with
         Region EHS Specialist and Headquarters EHS staff as required.
      2. Secure any air o water permits Equired for p m s s changes.
                          r
      3. Incorporate changes in equipment operation into operating proccdures and hain personnel on modifications. Include safety.
         personnel protective equipment and waste handling requirements.
EHS Evaluation for New and Modified Processes and Equipment




0 G m e d sarcly

   .
   -S;rlcly equipment nquind

   -Signsrequired
    SpuxdTraininy ryuircd__    -

L                              v                              4
 TCUStuion                            v       fl       v
.w d
 l     Dip T     d   v   v        v   v
                                      v   v




* Roto-Tiisher           v   I,   v   v
* S k m Clening      v       v    v   v            v
3
                         RECEIPT OF CHEMICAL MATERIAL

'3                                               --
                                DELIVERY GREENVILLE,
                    (SOURCE:POWER                 SC)


     1     PURPOSE
           This procedure defines guidelines for the receipt of chemical materials.
           supplementing those guidelines outlined in GTMP M5.20, for receipt of
           material, and ensures receiving integration between organizations in the
           control of chemical material. Procedure applies also to contractors
           working on site.


     II.   GENERAL
           A.    For receiving purposes, a chemical is a liquid, gas, solid or powder,
                 whether hazardous or not.
           B.    Procedure pertains to bringing any chemical including limited
                 quantities, samples, process chemicals, fluids within machinery and
                 D.O.T. non-regulated chemicals.
           C.    All deliveries for chemical products should be directed to the
                 Materials Distribution Center receiving office with any exceptions
                 approved by EHS. The receiving office will route the chemical
                 products to the responsible parties.
           D.    Alternative receiving points for departmental receipts are permitted
                 into the following areas.
                        Bulk Shipment Points
                               Waste Treatment Facillty
                               Test
                          -    East Platform (Tool Crib)
                               Compressed Gas Areas
                        Contractor Receiving Areas
                        Less than $ 1.000 Orders
           E.    All chemicals being received will have proper EHS approval and will
                 have been on an approved chemical list prior to being received.
           F.    If a chemical product is not on the approved chemical list, chemical
                 products will be quarantined andlor returned.



                                           -1-
111.   RESPONSIBILITIES
       A.   Receiving Operator Responsibility
            1.    Receive all chemical shipments to verify that they are on the
                  Approved Chemical List, properly labeled, and securely
                  packaged.
            2.    Quarantine all unapproved shipments, chemicals not on an
                  Approved Chemical List, and execute disposition routines.
            3.    Refuse receipt of chemical materials displaying broken seals
                  or leaking packages. Call EHS or 2911 (Emergency
                  number) for disposition concerning spill release and
                  reporting requirements.

       B.   Manager of Receiving Control Point
            1.    Arrange the disposition of quarantined receipts by
                  undertaking the following steps:

                  a)     Receive and quarantine temporarily in a designated
                         storage area.
                  b)     Determine who ordered the chemical, and notify the
                         requester and EHS of arrival.                             i
                  c)     Release once approval is issued from EHS, or after
                         24 hours, arrange for return of material.

            2.    Ensure the training of receivers and that only authorized
                  receivers accept chemical shipment. Authorization to
                  receive chemical items requires training and testing in the
                  following areas:
                  a)     HAZCOM Instruction.

                  b)     Awareness training in accordance with HMT-181
                         regulation. Training will be provided by certified
                         instructors within the MDC office.

                  c)     Specific function training (e.g., marking packages) for
                         limited hazardous material responsibilities.

                  d)     Receivers with greater hazardous material
                         responsibilities will attend Corporate's 49CFR basic
                         course.



                                    -2-
     3.    MDC provides instruction for identified receivers.

     4.    Testing and tracking of personnel completing training will be
           provided by EHS.
     5.    Establish receiving areas which are equipped to handle
           chemicals.

C.   Sourcing Responsibility
     1.    Ensure that an additional MSDS, besides the one forwarded
           to EHS,is shipped for all required materials and that the
           MSDS is included in the QC file folder.

D.   Bulk Shipments
     1.    All chemical bulk truck shipments are to be checked against
           the Approved Chemical List and routed through the MDC
           receiving office to the proper unloading dock.
     2.    Designated, trained operators at each bulk storage will
           ensure that the bulk material is dispensed into the proper
           storage unit, sign the bill of lading and forward to the MDC
           receiving office.

E.   Requester's Responsibility
     1.    For purchases less than $1,OOO, it is the requester's
           responsibility to ensure that chemicals are ordered with EHS
           approval. Any unapproved chemicals, received by the
           requester, result in immediate disposition through the EHS
           department.
     2.    Before a requester receives any samples, samples require a
           Material Approval fofm,appropriate MSDS and EHS
           approval.
     3.    To communicate this responsibility. non-production items
           unloaded by the MDC will be labeled indicating the
           appropriate actions to undertake if a chemical is contained in
           the package.




                               -3-
F.   Other Related Chemical Receiving Requirements
     1.    GE employees are not permitted to bring chemical materials
           on site unless they are on the Approved Chemical List.
     2.    For the receipt of new machines, requires the requester to
           obtain MSDSs and approval from EHS before entry onto site
           (Reference chemical approval procedure)

G.   EHS
     1.    Add newly approved chemical materials to the Approved
           Chemical List and distribute updates as necessary to
           receivers.
     2.    Advise receivers on newly approved chemical handling and
           disposal requirements.
     3.    Maintain the MSDS Master file and verify that work area
           MSDS binders are current.




                             -4-
e         lw ”   m   L   H U M 6 J.h*

HAZARDOUS WASTE HANDJ.lING
     ENVIRONMENTAL SERIES




                                                              lvna Envimnmwnul. H d t h 6 Salrtv

                                        PERSONAL PROTECTIVE EQUIPMENT
                                                   INDUSTRIAL HYGIENE SERIES
                                        Purpose: Parronal Proteawe Eaulpment (PPEI IS
                                                 worn 10 protea workers from contact wltn
                                                 chamial Or PhySlOl hazarda in lhe
                                                 workplacm. Such hazards includa cham,.
                                                 a l a . dust, m i n fumaa. n o m . matal chaps
                                                 and falling obpms.
                                           Panom1 ho(.criv*                       Availabla




                                         Face Shields
                                                                     Shop Support TOOI        cross

                                         Moaring Protamion           SW E M WICO then
                                                                                 1-64.
                                                                      Shoo Suppon Tool Crib
                                         Sofen, Glasmr
                                           Non-orarcription          Shop Support Tool Crtbs
                                           Prescription              Optomatrial 2.96 ana W.Lynn
                                         Safew Shoaa                 Shoemobile visits.
                                         Hard Hats iLPSI             Su~.rvl.or
                                         Reroiratora


                                                           GE provider stloend
    Procedure for Ordering New Chemicals




            ’   I   one copy t o your Lab
                     MSDS Coordinator.


                                             HMlS  Coding
                                                  and
                                            Unit inventom




                                                      non-shaded
                                                        areas
                                                     Review wltn
                                                     Marsna Rader



          Take “-meted forms to
               Ross Nicholas.




4
    L
Chemical Management                                                     Blanket Purchase Orders

                                                                         CHAMPIONS

   Control Chemical Blanket Oders Via the Following Mechanisms:
                                                                        Chudc Harris,Ben Nadeau.Kim Bradshaw
       - Identify Current Vendor Base Utilized for all Blanket Po's
       - to be Utilized for Future Chemical Blanket PO'Sie Air
         Establish a ReducedQuality Supplier List
                                                                        Chuck Harris,Ben Nadeau,Kim Bradshaw


           Products,Abmsives, Oils etc.
       -   Limit Number of RequestorsWho are Approved for
           Blanket Purchases  -
                                                                        TBD

                -Work with GM/MF to Identify Requestors by Plant
               - Approved Requestor List                                Kristen Pulling To Write
       -   Communicate to Approved Requestors that Chemical
           Blanket PO ' Will Only be Approved For the Above
                        s
                                                                        Letter

           Qualiy Supplier List
                                           -
           ( Letter from Craig Kipp,J. Cote to be sent with

       - - paych=W
           Send out Letter to Identified Quality Suppliers
                 Communicate GE Requirements For All
                                                                        Kristen Pulling to Write Letter


                  Purchases Which Require an MSDS                       TBD
               -  Establish Routine Whereby Vendor Supplies
                  Inventory List of All Chemical Purchases by Quarter
               -  Vendor to Utilize Approved Chemical Listing Before
                  Shipping Material                                     Paula Zilka
       -   Change Contracts at Time of Renewal For EHS
            Requirements
   - Send out Letter to Those Vendors Not Specified for           Kristen Pulling
    Chemical Blanket Po's ( Craig Kipp, J. Cote Signature)
         -
        No Chemicals to be Purchased on Blanket PO
         -
        State Strongly the Implications of Not Following the
         Above Guidelines
   - Blanket Forms to Spell out By Line Items What Chemicals      Kim Bradshaw
    are to be Purchased
         - Requestor Education
         - System Enhancement to Incorporate into COPlCS
                                                                  Kim Bradshaw
   - Need to Identify ReceivingPoint for IncreasedVolume
   - System Fix so That Chemicals can be Received in
    COPICS
                                                                  Dave, Kim, Paula, Kristen
    - Meet With Craig Kipp & Direct Material Managers to          Ben, Chuck
     Ensure Above Strategy is Feasible

Control <$io00 Purchases Via the Following Mechanisms             Dave, Kim, Paula, Kristen
    - Eliminate1
    - Draft Plan and Strategy on Elimination
    - Present Plan and Strategy to Ron Collins and Ed
     Clemmings
Control Credit Card Purchases Via the Following Mechanisms
                                                                  Kim Bradshaw
    - MRO Meeting to Be Held 4/28-4/30 - Credit Card Issue
      to be Discussed - Best Practices Identified and Leveraged
                                                                                  GE Motors
3
                       CHEMICAL REVIEW REQUEST
    This authorization will be completed prior to the initial purchase of
    any chemical used in the production of motors, or in support of the
    production of motors, at the Broadway Plant.
    Once granted, this approval remains in effect unless the chemical formula
    or the manufacturer of the chemical changes.


       Product Name:

       Manufacturer:


       QTY to be placed in Oil House inventory:                Minimum QTY   to trigger re-order:   -
       Material Replaces:

       Requestor:                                 Extension:

4      Date Submitted:                            Date Approval Needed

       Process & Location:
                    MSDS SUEET MUST BE AmACHED FOR APPROVAU

                ENGINEERING                         ENVIRONMENTAL,. HEALTH AND SAFE-
                  REVIEW                                         REVIEW
    )mments:                                       Comments:




    proving Engineer:                               0 Assessment form complete?

    turned to Requester:


    S
    I FORM MUST BE ATTACHED TO YOUR REQUEST FOR MATERIALS ON ANY
    EMICAL PURCHASE REQUESTS. IT IS AGAINST GE MOTORS POLICY TO PURC-;                                        :-
    EMICALS WITH HANDWRITTEN PURCHASE ORDERS (BOOS).
                                                                                               cl€Y.m:.   ~




                                                                                                              --.




                                                                              c
                            GE Power Generation
                     Chemical Material Procurement Policy

 1. General
    The General Eledric Company is w mn d to conplying with all applicable Environmental. Health and
                                       m ie
    Safely (EHS) laws and regulations. This policy is designed to ensure that 1) All new chemical materials
    are reviewed and approved prior to procurement and to 2) Ensure a process is in place whereby chemical
    usagehandling requirements are available to all employees

Ii. Definitions
    For the purposes of this policy the following definitions apply:
    A.
                              '
                                  -
                                 An EHS approved liquid, gas. sold or powder which in normal use has the
         potentiilto c a w a health and / or physical hazard, or the release of toxins into the environment. T i
                                                                                                              hs
         definition also includes any new materials that will be created during the manufactwingprocess, either
         as intermediites, by-products. or wastes. Exanples of chemicals include: paints, oils, fuels. coolants.
         adhedies, compressed gases. lubricants. solder. cleaning agents. WD-40 etc. When in doubt,
         conlacl your site specifc EHS Manager' for chemical clarifiition.
         Each chemical must be reviewed by the Plant Specific                   EHS Manager' to ensure              full
         compllanco wlth all regulatlonr and guidelines.
    B.                                           - A technical bulletin required by OSHA which contains information
         about a chemical matelialregarding its identity. chemical and physical characteristics. health and safely
         data. and precautions necessaly for safe handling and use.
         For all chemicals used In the facility. a Material Safety Data Sheet
         layrl
    c.                               -An employee who requests, buys or othetwise acquires a chemical:
            Pmcuremrd of a chemical (new or currently used)
            New w of an cnisling chemical material
            Trial samples obtained for testing purposes
            Chemicals used by outside contractor services on GE premises
                          '
    0.                            -An employee authorized to receive chemical shipments entering the plant

    E.
                                   .
                                  - A l i i n g of approved chemicals authorized for use in a plant   - used as a
         control reference prior I chemical procurement and receiving.
                                 o
    F.             - The 'new use' of a chemical material includesthe following:
         1) Introducing the use o a chemical material into a work area which is not on the Approved Chemical
                                f
            List
         2) Introducing, in an cipproved work area, a different use of a chemical material requiring quantities
            larger than originally approved.


* See Material Approval Request Form
111. Responsibitlties
A. Chemical Requester mud:
    1) Reference the Approved Chemical List to verify that the chemical material being requested is
       approved for use in the plant in which it will be used.

    2) Complete a Materhl Approval Request Form (Attachment 1) lor any new chemical and
       submit it with the MSDS to the site specific EHS Manager' prior to procurement.
    3) Request chemicals by using chemical mrdrol ID from Approved Chemical Listing.
    4) Order chemicals in quantitidrequencies which are pradical.

      The requester is responsible for ensuring that EHS review and approval
     is obtained for new chemicals.

8. Plant EHS Manager must:
    1) Administer the material approval process and communicate approval or rejection of the chemical
      Requesl for Material (RFM)/purchase requisition.
    2) Assign chemical control ID number to newly approved chemicals.

   3) Add newly approved chemical materials to the Approved Chemical L-alabase        and distribute
      updates as necessary to requesters, buyers and receivers.
   4) Maintain the MSDS Master File and verify that workarea MSDS binders are kept current.

   5) Forward newly approved Material Approval   - quest Fonn along with RFM to Sourcing
   6) Advise requesters and receivers on newly approved chemical handling and waste disposal
      requirements.
   7) Make any necessary modifitions to envirmmenlal penits at the time of new material review and
      approval.


C. chemical Receivers must:

   1) Receive all chemical shipments, verify that they are on the Approved Chemical List. propedy labeled.
      and securely packaged.
   2) Quarantine all unapproved shipments (Chemicals not on the Approved Chemical List) and execute
      disposition routines
   3 Contacl Requester that chemical will be returned to sender unless otherwise approved.
    )

  Receivers must screen all chemical deliveries against the Approved
  Chemical List
D. Manager Shop Operations'Supenrisors must:
   1) Ensure that all chemicals in use have been approved

   2) Educatdadvise employees on this procedure and the requirements for ordering chemicals.

   3)Ensure that an MSDS is maintainedfor each chemical used in their work area i and avaibbke for all
       enpbyeed
   4) Permit only authorized employees to use or handle potentiilly hazardous materials.

   5) Ensure that each employee has received HAZCOM training for each chemical hashe uses.




E. Sourcing ManagarByen must:
   1) Verify that all chemical pwchasas are on the Approved Chemical List for the site(s) of intended use.

   2) Ensure that new chemical purchases have been approved by EHS at all sites of intended use prior
       to procurenwnt.
   3) Return all requests for materials that do not appear on the Chemical Approved List. In the case of
       e
      nw    apprared chemicels. an EHS approved Material Approval Form,for each site of intended use.
       should acconpanytheRFM.
  4) Require that all purchase orden for new chemicals o chemicals alreaw in use have a statement
                                                       r
     requiringthat an MSDS be sent with the order and to the plant spacific EHS manager

    Buyers are responsible for ensuring that no unapproved chemicals are
    purchased
IV. Restricted Procurement Methods
  A. Chemical material purchases are llpt to be made using credl cards for reimbursement.

  8. Chemical meterials are      to be routinely purchased using <$lo00 methods or blanket purchase
     orders. I the event that an emergency situation requires purchase using the above methods, the
              n
    purchaser must provide a ccpy of the MSDS to plant W S Coordinator for review and approval prior to
    procuremant.
V. Other Related Chemical Material Requirements

  A. Suppliers are prohibited f bringing chemicals on-site for trial purposes without prior approval from
                              m
     the plant EHS Coordinator. Recipients of trial materials should subml Material Approval Forms and
     appropriate MSDSs to plant EHS Coordinator.
B. Contractors are prohibited from bringing chemicals on-site withoul receiving prior approval from plant
   EHS Coordinator. Engineersrequestingcontractor services must verify that MSDSs have been
   fumished prior to work start up. Additionally, arrangements must be made for the remval of chemicals
   brought on-silo by contractors.


C. GE employees. including thobe from other plants. are not permitted to bring chemiml materials on-site
   unless they are on the Approved Chemical List. Plant EHS Coordinator approval must be obtained via
   the Material Approval Form and an MSDS prior to bringing the chemical on-sile.

0. MSDSs must also be provided for free chemical samples.
3     @                             GE Power Generation
                                 Material Approval Request Form
                                    l l l e k k w f l g u d ~ ~ b P w d n d ~ b ~
                                      pocuemsldnmivmal&kI~~am
                                     Ottan MSDS alkh b Ius lam da&rrtbW S

     Date                                            Site

     Product Name
     Product Manufacturer
     Supplier
             s
     Produd u e
     Quantity to be used ge Ibs., gals..)                           /month          Ivr

     PlannedStorage?
     Does the operation already use a chemical that can perform this function?
     Will this replace existing material?          Yes      -No
        ll yes, what matetial is being replaced?
        Will replaced material need to be disposed of?              YeS             No

     Requester Name
-4

     EHS Approval Given?              Yes             No

     Chemical Control ID #
     Hazardous 1 Toxlc Material?
     Environmental, Health & Safety Requirements
                       . .

     EHS Approval Slgnalure                                       Date
     Added to Approved Chemical List?                       Yes    Date
     Fax Form and MSDS sheet@)to:
                               FAX                 PHONE           CONTACT

     Greenville            8'2884780           8.288-2355         Thad Lelster
     Schenectady           8'235-8599          8'235-9184         Don Huckabay
     MchtnJrg              8'234-1 459         8.234-1766         Paul Waterman
     Bangor                8.560-2529          8'560-2558         Jim Crawford
     Lynn                  8'263-9457          8'263-3315         Dale Ashley
3
                                                 LJ




                            Chemical Approval Procurement Process
                                       Training Manual
                                 To Be Used By Requesters And Buyers




GE Proprietary
FS~Mto(:PuIlnp:Ch.molCaer
                                  Corporate Environmentalism



                       "Every Single Person In GE Has To Be An Environmentalist.

                      Our Products Have To Be Thought Of In Those Terms. Our

                      Processes, Too. Everybody Has A Role To Play. And The

                       Companies That Don't Understand This And Don't Do It,

                       Won't Recruit The Best, Won't Sell Their Products, Won't

                       Be A Viable, Positive Enterprise In The 1990's''


                                                                   Jack Welch




GE Proprieta
FS*Auor.P".npLul   SlsPap. I
                           ..............




                                                i




GE Proprietary
F S l A d l o r . P u M g . C h o d 618 Paw 2
                                                      Chemical Guidelines
                           A Chemical Is:

                               A liquid, gas, solid or powder which in normal use has the
                          potential to cause health and / or physical hazards, or the release of
                          toxins to the environment.


                           Examples:
                                    A table is not considered a chemical material. It's normal use
                                    does not cause health and / or physical hazards, or the release of
                                    toxins to the environment.

                                    Solder       chemical material - when used, it gives off fumes.

                                    Paint     chemical material - when used, it gives off fumes.

                                    Fiberglass      chemical material - when used in manufacturing
                                    processes

                                    A casing is not a chemical unless an operation (i.e., cutting or
                                    filing) is performed.

                                    A bolt is not a chemical material
GE Propns
FS2 Aditor Pull-mica   619 Page 3
                                                                   -4'
                                           \lj
..........


                         Chemical Guidelines

             Examples:

               Welding rods are chemical materials


               1, 1, 1 - trichloroethane         chemical


               WD-40       chemical


               Acetone       chemical

                Fuels / oils / coolants are chemical materials


                Compressed gases are chemicals
          cn
          +
          t
          a,
     t    >
          -
    i=    0
          m    \
    \
          +    cn
               +
          .-
           t    t
               .-
          a    a
          a    a




          a
     cn   .-
           t
    -
    .-    t
          a         -
                    cn
    a
    x     a,        a,
                    3
    zi    9         u,
e    e         e
3
    v)
    v)
    Q)
    0
    0
    k




         I
         v)
         v)
         9)
         0

         3
         9)

         6
                   E
              v)
               t
              I ?
                   --
                   m

              w e
                   0
                     Procurement Tools

a   Approved Chemical Listing
       A listing of approved chemicals authorized for use in a
       specific plant

       * Maintained and distributed by EHS

0   Material Safety Data Sheet (MSDS)
       A technical bulletin required by OSHA which contains
       information about a chemical material regarding its identity,
       chemical and physical characteristics, health and safety
       data, and precautions necessary for safe handling and use.
        A material safL.j data sheet is required by law.

0   Material Approval Request Form
       Form submitted to EHS by a requester petitioning for
       approval of a new chemical material.
3
    Chemical Approval / Procurement Process




I        Fon       A                  I
I             m
         wilh I
I
I




I
I
I
I
I
I
I
I
I
1
I         I v.
                                   Chemical Approval / Procurement Process
                                     All chemicals must be approved prior to procurement
        How?


        -
        EHS                           Provide all requesters and buyers with an approved chemical list
                                      detailing chemicals authorized for use in a specific plant

                                      Review each Material Approval Request Form within 24 hours of receipt
                                      for approval.
                                      Assign chemical control id#to newly approved chemicals.



         ReQUeSter:                    Reference the Approved Chemical List to verify that the chemical material being
                                       requested is approved for use in the plant in which it will be used.
                                       Complete a Material Approval Request Form for gnv new chemical purchase
                                       and send to the site specific EHS manager prior to Drocurement.

                                       Obtain a Material Safety Data Sheet (MSDS) from the chemical supplier and
                                       submit to EHS with the Material Approval Request Form.

                                       Request a chemical by placing the chemical control id# (by plant code)
                                       in the description field of the RFM.



GE Proprietary
FSZAudtar:PulmpCChamal6gPaga I t
         Chemical Approval / Procurement Process




Buver:     Must review all chemical Request for Materials (manuaVautomatic) against the
           Approved Chemical Listing.
           Unapproved chemicals must be rejected and sent back to requester.

           Each chemical purchase order must be identified as hazardous material within
           COPlCS using the BMPD & POTX screens in order for suppliers to provide the
           required MSDS’s.
           Chemical materials to be shipped to Bangor, Lynn, Fitchburg & Greenville
           must be coded with correct destination code. This code must be input at the
           POTX screen at the individual requisition level so that MSDS will be routed to
           the proper ship-to address
                             Lynn      HZ04               Bangor     HZ05
                             Fitchburg HZ03               Greenville HZ02
Chemical Materials Are Not To Be Routinelv
 Purchased Using The Following Methods:

    < $1000 purchases


    Blanket purchase orders

     Credit cards



 In an emergency, ensure that the site specific EHS manager
 has reviewed for approval prior to procurement
                Samples


Must be pre-approved by EHS



Follow same approval process



Incoming samples must have a copy of Material Approval
Request form and MSDS as they enter plant



Arrangements must be made for the removal of non-
approved chemical samples
                                               To Facilitate the Chemical Approval Process
                                               Please send your Material Approval Form with
                                                the Material Safety Data Sheet (MSDS) to the
                                                           following individuals:

            Chemicals purchased for: Schenectady           Phone                                  -
                                                                                                  Fax
                        Contact:     Don Huckabay        8*235-9184                            8*235-0627
                                     Bldg. 41 - Room 105
                                     Schenectady, NY 12345


             Chemicals purchased for: Greenville
                         Contact:     Thad Leister         8*288-2355                          8*288-2780
                                      300 Garlington Road
                                      Greenville, SC 29607


             Chemicals purchased for: Fitchburg
                         Contact:     Paul Waterman       8*234- 1766                          8*234-1459
                                      166 Boulder Drive
                                      Fitchburg, MA 01420


GE Proprietary
                                          .
F S 2 A u d l o r : p w k g C ~ I b D p q 14
           Chemicals purchased for: Bangor                          Phone         -
                                                                                  Fax
                                      Contact:   Jim Crawford       8*560-2558    8*560-2529
                                                 534 Griffon Road
                                                 Bangor, ME 04401


           Chemicals purchased for: Lvnn
                       Contact:     Dale Ashley                      8*263-3315   8*263-9457
                                    GPBll
                                    1100 Western Ave
                                    Lynn, MA 01910



           * All Requests For Approval Will Be Reviewed Within 24 Hours of Receipt




GE Propriet
F*2*d,c+   P   L   .   . 'Pap.   IS
GE Proprietary
F S Z A G ~ ~ W P ~ Y ~ wwq. ~ e
                        ~CC I
3




;3
 ._
GE Proprietary
Fgtludbx:Pumw.Ck~&aI m P -   LI
'3
13.   INaREDlENT INFORMATION                                          1
                                             OTHER UMITS
COUFe4ENT        OYUPEL        ACOIH   nv   RECOMMENDED    CASU   %RANGE




IS.   FIRE AND EXPLOSION HAZARD DATA                                  I
3
18.    HEALTH HAURD DATA
                       Nwuwwwd by ACalH or OSHA
                                                  1
Tkmhddum)IrJur




19.    SPECIAL PROTECTION INFORMATION             1




110.   SPECIAL PRECAUTIONS                        I
3
                              GE Power Generation
                           Material Approval Request Form
                              mcmnprramubonm.dbpwb-
                                p"srdnavt"nl%n)W-
                              ob(an MSOs a&il b ta k nddd b M S
                                                    n


Date   a           &               &                     Slte Schenectadv
PmductName AutomatedB
Pmduct Manufacturer P v l a m w t s
Suppller   lndustrialsuDnlv Inc.
Product use
                                    ,@ $
                                      Q-
Ouantlty to be used QeIbs., gals.,) % L&                       /month-      IY   r   L
Area of Use?
Does the operation already use a chemical that can perform this f u n c t i o n ? A
Will this replace edsUng matedal?             Yes    X     N     o
   ll yes, what material I being replaced?
                         s
   Will replaced material need to be disposed 017              Yes          No

Requester Name          NeM
                      I. e d




EHS Approval Glven?            Yes              No
Chemical Control ID t
Hazardous I Todc Material?
Environmental, Health (L Safety Requirements


EHS Approval Slgnature                                     Date
Added to Approved Chemical List?                     Yes    Date
Fax Form and MSDS sheet@)to:
                        FAX                  PHONE          CONTACT
Greenville          8'288-2780             8'288-2355      mad Leister
Schenectady         8'2354627              8'2359184       Don Huckabay
FitchbUrg           8'234-1459             8'234-1766      Paul Waterman
Bangor              8'560-2529             8'560-2558      Jim Crawford
Lynn                8'263-9457             8'263-3315      Dale Ashley
3
'3
'3
                                                                                                                          I
                                                                                                                          P O NUMBER
           L       REQUEST FOR MATERIAL
                                                          PAGEL
                                                            v




                                                                  VALUE   OTMR APPROVAL             MANAGER'S APpllDyAL
        @
             NON-
                     0
             PRODUCTION              0 REPARSN t                  s
                                                                          X                         X
        0 PRODUCTION 0 CONSIGNMENT   0 BIANKET,UMlT   t                   IEQUlSIIlDN
                                                                          SlANS
                                                                                        1 ~=~      o:%EST            0AMENOMEW 0WNCEUATION*
                   CLuen,LU\   rvrrkul
   ~ l U L l l E M D E S ~




SLHXESIEDVENDOR                                 M N W R PHONE                      vuloon C W E                                  nuom VAUO m
                                                                                                                                           m
                                                                                                                                                           DAYS
MNWUSM M S S                                     VENDOR CONTACT                    PAVMENT lERMS                                 SHIPPING CODE


YKUL Nons                                                                          1 CODE
                                                                                    U                                            llECOVUlG L o U l l O N


                                                                                   BUYER                            BUYER AUTH   BUYER LO


                                                                                   BROKER AGENT                                  BROKER'S PHONE
"3
.
                                  GE Power Generation
7)                         Chemical Material Procurement Policy

     1. General
        The c3ened Writ Conpeny is omm mined to conpfying with all applicable Environmental. Health and
        Safely (EHS) law and regulations. This policy is designed to ensure that 1) All new chemical materials
        are reviewedand epprwed prior to procurement and to 2) Ensure a process is in place whereby chemical
        usagelhandling requirements ere available to all employees

     II. Definitions
        For the purposes of this poky the following definitions apply:
        A.
                                 '
                                     -
                                    An EHS approved liquid, gas. sld or powder which in normal use has the
                                                                     oi
             potential lo c8u.s~a heath and I or physical hazard. or the release of toxins into the environment. This
             definition also includes any new materials that will be created during the manufacturing process, either
             as intatmediites, by-products. or wastes. Examples of chemicals include: paints, oils, fuels, coolants,
             adhesives. conrpressed gases,lubricants, solder, cleaning agents, WD-40 etc. When in doubt,
             contact your site specific EHS Manager' for chemical darifiitbn.
             Each chemical must be reviewed by the Plant Specific EHS Manager' to ensure full
             compliance with a11 regulations and guldellnes.
        8. p                                   - A technical bulletin required by OSHA which contains information
           aboul a chemical material regarding its identity, chemical and physics1characteristics. heath and safetv
          data, and precautions necessary for safe handling and use.

             For all chamicals used In the facility, a Material Safety Data Sheet
             l
             k
        c.                                   -
                                          An employee who requests, buys or otherwise acquires a chemical:
                Procurement of a chemical (new or currently used)
                New use of an existing chemical material
                Trial samples obtained for testing purposes
                Chemicals used by outside contractor services on GE premises

       D.    Chemical.Recelver-An employee authorized to receive chemical shipments entering the plant.
                             '



       E. &                        '     -
                p v e d C w A listing of approved chemicals authorized for use in a plant           - used as a
             control reference prior to chemical procurement and receiving.

                       -
       F. New Uw The 'new use' of a chemical material includes the following:

             1) Introducing the use of a chemical material into a work area which is not on the Approved Chemical
               List.
            2) Introducing. in an approved work area, a different use of a chemical material requiring quantities
               larger than originally approved.


     See Material Approval Request Form
 111. Responslbiiitles
A. Chemical Requester must:
    1) Reference the Approved Chemical List to veriJy that the chemical material being requested is
       approved for use in the plant in which it will be used.

    2) Complete a Material Approval Request Form (Attachment 1) for any new chemical and
       submit it with the MSDS to the site specific EHS Manager' prior to procurement.
    3) Request chemicals by using chemical control ID from A p w e d Chemical Listing.
    4) Order chemicals in quantitidrequencies which are practical.

      The requester is responsible for ensuring that EHS review and approval
     is obtained for new chemicals.

E. Plant EHS Manager must:
    1) Administer the materialapproval process and communicate approval or rejection of the chemical
       Request for Material (RFM)/purchasequidtion.

                        oto D
    2) Assign chemical c n r l I number to newly appraved chemicals.

    3) Add newly approved chemical materials to the Approved Chemical LisVDatabase and distribute
       updates as necessary to requesters. buyers and receivers.

    4) Maintain the MSDS Master File and verify that work area MSDS binders are kept current.

    5) Forward newly approved Material Approval Request Form along with RFM to Sourcing
   6) Advise requesten and receivers on newly approved chemical handling and waste disposal
      requirements.

   7) Make any necessary modifications to environmentalpermits at the time of new material review and
      approval.



C. Chemical Receivers must:
   1) Receive all chemical shipments, verifv that they are on the Approved Chemical List. properly labeled,
      and securely packaged.

   2) Quarantine all unapproved shipments (Chemicals not on the Approved Chemical List) and execute
      disposition routines

   3) Contact Requesterthat chemical will be returned to sender unless otherwise approved.

  Receivers must screen all chemical deliveries against the Approved
  Chemical List
3   D. Maneger Shop OperationdSupervisors must:




           -
       1) Ensure that all chemicals in use have been approved.

       2) Educatdedvii employees on this procedure and the requirementsfor ordering chemicals.

       3) Ensurethat an MSDS is maintained for each chemical used i their work ama iSnd avaibbke for all
                                                                  n

       4) Pennit only authorized empkyees to use or handle potentially hazardous materials.

       5) Ensure that each employee has received HAZCOM training for each chemical hdshe uses.




    E. Sourcing ManagerBuyers must:
       1) Verify that all chemical purchases are on the Approved Chemical List for the site@)of intended use.

       2) Ensure that new chemical purchases have been approved by EHS at all sites of intended use prior
          to procuremant.

       3) Retum all requests for materials that do not appear on the Chemical Approved List. In the case of
          newly approved chemicals, an EHS approved MatetialApproval Form, for each site of intended use,
          shc& a a " y t h e R F M .
       4) Require that all purchase orders for new chemicals o chemicals already in use have a statement
                                                             r
          requiring that an MSDS be sent with the order and to the plant specific EHS manager

        Buyers are responsible for ensuring that no unapproved chemicals are
        purchased

    IV. Restricted Procurement Methods
      A. Chemical material purchases are       to be made using credit cards for reimbursement.

      8. Chemical materials are      to be routineiy purchased using ~$1000methods or blanket purchase
        orders. In the event that an emergency situation requires purchase using the above methods, the
        purchaser must provide a copy of the MSDS to plant EHS Coordinator for review and approval prior to
        procurement.

    V. Other Related Chemical Material Requirements

      A. Suppliers are prohibitedfrom bringing chemicals on-site for trial purposes without prior approval from
         the plant EHS Coordinator. Recipients of trial materials should submit Material Approval Forms and
         appropriate MSDSs to plant EHS Coordinator.
B.    Contractors are prohbied from bringing chemicals on-site Withoul receiving prior approval from plant
     EHS Coordinator. Engineers requesting contractor services must verify that MSDSs have been
     fumished prior to work start up. Additionally, arrangements must be made for the remval of chemic,
     brought on-site by contractors.
                                                                                                              >
C.    GE employees. including those from other plants, are not permittedto bring chemical materials on-site
     unless they are on the Approved Chemical List. Plant EHS Coordinator approval must be obtained vie
     the Material Appwal Form and an MSDS prior to bringing the chemicalon-sile.


D. MSDSs must also be providedfor free chemical samples.
                               GE Power Generation
                            Material Approval Request Form
                               mhrmwhpn-rmhpwrtow
                                p"mwdn.rmUfdahyov~W
                               OblllinMSD$aWhbthlllUdMbWS


 Date                                           Site
Product Name
ProductManuiacturer
Supplier
Pmdud Use
                  l(
OuanUty to be usede Ibs., gals.,)                             /month         /vr
-Ofuse
Does the operallon already use a chemical that can perform thls function?-
Will this replace existing material?          Yes      -No
   ll yes, what material is being replaced?
   Will replaced material need to be disposed of?            Yes             No
Requester Name


To be completed by EHS (Review EHS Checkllst)
EHS Appmval Given?              Yes             No
Chemical Control ID t
Hazardous / Toxic Material?
Envimmentai. Health 6 Safety Requirements


EHS Appmval Signature                                      Date
Added to Approved Chemical Lis17                     Yes    Date
Fax Form and MSDS sheet@)to:
                         FAX                  PHONE         CONTACT
Greenville           8'288-2780         8'286-2355         Thad Leister
Schenectady          8'235.0627         8'2359184          Don Huckabay
ntchhrg              8'234-1459         8'234-1766         Paul Waterman
Bangor               8'580-2529         8'560-2558         Jim Crawlord
Lynn                 8'263-9457         8'263-3315         Dale Ashley
'3
              c
              0
              e
              0
              e
              e
              n
I   *%   Ix   t
              0
              e
              (0
              0
              E
              5
              I
              X




                      -
                      ul
                      &I

                      5
                      2
              c
              .-
               0
                      .
                      0
                      2
                      ul
                      m
              e       C
              m       ti
                      .
              0
              E
              E       P
                      m
              E       C
              8
              2 a
              - 0
               m
              .- 2
               c
               0 0
              c  0
              a       2
              0
              a
                  I
                      z"
                       I
              m       0
3
                                     L
Chemical Management                                     One-For-One Replacement


         s
    What I A "One-For-One" Chemical / Waste Replacement Process?

          A chemical must be exhausted before it is replaced
          (exchange an empty container for a full container)

    "One-For-One" Replacement Ensures That:
            Chemical inventory on plant floor is minimized
            Usage and disposal is tracked
            Containers are approved and properly labeled
            Fixed order / release quantities are used
            Temperature / Pressure sensitive risk is minimized

    Critical Success Factors
             Chemicals must be delivered on same day that they are promised
             Should be implemented concurrently with chemical handling team
             Define maximum / minimum .use quantities
               "One-For-One" Replacement Guideline

Getting Started
  Prior to implementing a "One-For-One" replacement system, it is important to
  understand the current manufacturing and chemical distribution processes. Queaions
  to heighten process awareness include:
   Has chemical usage been quantified for all production stations?
   How are chemical inventory levels currently monitored or controlled?
   How many people are involved in the chemical distribution process?
  Once these questions have been answered, implementation can begin       ...
How to Implemnt
  Step 1.   Determine which operations a 'One-For-One' replacement system will
            apply. The first candidates for 'One-For-One' replacement should be
            hazardous chemicals.
  Step 2.   For the operations targeted, understand current usage requirements,
            and which employees are involved in the processes.                         \
                                                                                       I


  Step 3.   Analyze inventory on hand and required order quantities. Need to
            ensure that appropriate inventory levels are maintained.
  Step 4.   Educate and train all employees who will use 'One-For-One'
            replacement routines. Clearly establish roles and responsibilities, and
            communicate the benefits of this system.
  Step 5.   Remove all excess inventory off the floor. Chemicals must be
            distributed out of a central area.
  Step 6.   Implement 'One-For-One' replacement routines
   G                                  b
Chemlcal Handling                             Example: One-For-One Replacement



 Here Is How A Typical "One-For-One" Replacement Works     ...

                         .---




  Elements Of A Successful "One-For-One: Replacement Process:
           Chemicals must be delivered on the same day they are requested
           Should be implemented concurrently with chemical handling process
3
             lntegrated Chemical Supplier
3                      Getting Started


    Approved Chemical Listing for each facility
    Understanding the process of how chemicals enter the facility
                  --
        (Order Delivery Cycle)
    Chemical Sweeps completed
    Procurement policy for chemicals


    Form a Cross-functional core team with representation from:
                 - EHS'
                 - Sourcing'
                 - Finance
                 - Manufacturing
                 - Engineering
                 - Legal
                 - Labor Relations
        Sourcing & EHS are Co-leaders for Project Management
    Determine Chemicals to be handled through the supplier

        -   Information required: Listing of chemicals purchased,
             annual quantities, annual expense, & vendor name
        -   Phased Approach suggested focusing on Indirect
            chemicals initially and then transition to direct chemicals

    Decide upon services to be provided by an lntegrated
    Chemical Supplier as a team
        See Attachment for Services

    Determine Pilot location for implementation
        -   A Pilot location is suggested because of the magnitude
            of the effort as well as the ability to take lessons learned
            and transfer for smooth transition at other facilities
What worked well:
      Top Management buy-in to program
      GE employee on-site at vendor to coordinate issues on
      both sides
      Effective cross-functionalteam - Sourcing & EHS
      are key players
      Sourcing resource-- dotted line to EHS
      Focus first on Indirect Costs
      IntegratedSupplier initiative tied to businessobjectives
      Effectively teamed Integrated Supplier with 2nd tier chemical
      suppliers during planning
      Cost savings are being felt - especially in procurement cost
      reductions
      Supplier is a partner - "open-book" mentality
What should have been done differently:
      EstablishChemical Management Process prior to Implementation
      More defined statement of work - Avoid "dumping" on supplier.
      Dedicated GE Project Manager during development &
         implementation
      Evaluationof internal systems &what is neededto support
      the process before you begin
                           GEhWldsyrtrmr

           PRODUCT QUALITY POUCY I PROCEDUREI l"RUCn0N

SURIECT: SUPPUER APPRAISAL AND APPROVAL

                       Supplior EHS Evrlurtlon Form                    ExbibU

     1.

                                                      YES NO     N/A
     2
                                                      YES NO     NIA
    .
    3
                                                      YES NO     NIA
    4.
                                                      YES NO     NIA
    5.
                                                      YES NO     NIA
    6.
                                                      YES   NO   NIA
    7.
                                                      YES NO     NIA
    a
                                                      YES NO     NIA
    9.
                                                      YES NO     NIA
    IO.
                                                      YE8 NO     NIA
    11.
                                                      YES NO     NIA
    12.
                                                      YES NO     NIA
    13.
                                                      YES NO     NIA

    14.
                                                      YES NO     NIA
                                                                            1
              PRODUCT OUAUrV POLICY I PROCEDUREI I ~ U C T I O N
DATEPISUED: -1                           NUMBER: 320W        PAQE: 11
  SUBJECT: SUPPLIER APPRAISAL AND APPROVAL
                                                                            I
        15.
                                                        YES NO   MA
       16.
                                                        YES NO   NIA
       17.
                                                        YES NO   NIA
       18.
                                                        YES NO   NIA
       19.

                                                        YES NO   NIA
       20.                                              YES NO   NIA
       21.
                                                        YES NO   NIA
       22.
                                                        YES NO   NIA
       23.
                                                        YES NO   NIA
      24.




                                                                        I
                  PRACTICES
            GE BEST      DOCUMENT
          REGULATORY-REQUIRED
                         EHS TRAINING

                                    INTRODUCTION

This Best Practices document provides guidance to GEs plant management, training
professionals, and attomeys as well as Environmental, Health, and Safety (EHS)
Professionals in identifjmg employee training required by environmental, health, and
safety regulations. The information contained in this document will help the EHS
professional identify the regulatory-required training needs geared to the individual w r
                                                                                       ok
place and workforce.

It is a laborious task to sift through the lengthy and complex environmental, health, and
safety   standards to identify all the training requirements for your facility. This document
will assist you in that effort. T a n n requirements identified in the following federal
                                  riig
regulations are collected in this document and arranged in a fonnat so you can identify
those which apply to employees at your facility:
-
          Occupational Safety and Health Administration (OSHA)
                                                             Standards
          Environmental Protection Agency (EPA) Regulations
          Department of Transportation (DOT) Regulations

The EHS training requirements identified in this document are regulatory-required
activities. U e of this Best Practices document will assist GE businesses in complying
             s
with the regulations. It is important to note that this document does not address training
that falls outside regulatory requirements but is called for by company policy or Best
Ractices such as the POWER (pOllution Naste and Emission Reduction), Ergonomics,
and PEP (Illant Emergency “aredness)        programs.

A successful strategy includes effective training presentations and thorough
documentation of training activities. The first part of this document contains suggested


                                                     MI1993
                                                   Page 1
procedures for identifying the employees who require training, selecting training
materials, and keeping records of training activities.

The second part of this document begins with a table listing typical work activities and
the associated training requirements. The table is arranged so that the users can quickly
select those work activities pertaining to pertinent business operations. The h q h g
requirements associated with each work activity are briefly outlined in the table. The
table provides a cross reference for specific training requirements. Details are provided in
subsequent pages in Appendix A.
     Many environmental, health, and safety regulations issued by federal, state, and local
     agencies incllide provisions for employee training. Some regulations are quite detailed,
     specifying the number of classroom and on-the-job training hours required for initial and
     refiesher training, while others reference only "qualified personnel".

     OSHA
     The Occupational Safety and Health Administration (OSHA) issues regulations dealing
     with employee occupational safety. The bulk of the EHS regulatory training
     requirements are contained in OSHA's standards. The OSHA training requirements
                                          SAs
     included in Appendix A are found in O H ' General lndustry Standards. If activities at
     your facility are covered by OSHA's Maritime, Construction, or Agricultural Industry
     Standards,you will need to review these regulations for additional training requirements.
     In addition to regulations, OSHA also issues guidelines containing u s 4 information for
     training course content. These guidelines are referenced in Appendix B.
i>
     As a general rule, you may note that the older OSHA standards have vague requirements
     for training content and timefnunes. The newly-promulgated o newly-revised OSHA
                                                                  r
     standards are more specific. sometimes giving definite timefimes and training topics to
     be covered. As OSHA continues to review and revise its older standards, such
     performance-oriented training requirements will become the norm.

     EPA
     The Environmental Protection Agency (EPA) issues regulations specifying procedures
     and standards t protect the environment and the public's safety. Included in these
                     o
     regulations are training requirements for employees whose work responsibilities include
     handling hazardous materials, solid and hazardous wastes, or operating systems that may
     result in emissions to the environment.

     The regulations issued by the EPA as a result of the Resource Conservation and Recovery
     Act (RCRA)    contain training requirements for employees who handle hazardous wastes.
     The type and amount of training required depends on the type of waste management
     practices at your facility.



                                                       Am1 I993
                                                      Page 3
         DOT
         The Department of Transportation (DOT) issues regulations addressing the safe
         packaging, handling, and m s p o r r of hazardous materials. These regulations are
         applicable to transporters and shippers who offer hazardous materials for transport.
         Training requirements contained in DOT regulations applicable to many GE facilities are
         those which address employees involved in hazardous materials transportation safety.
         The DOT training requirements apply to anyone who is employed by a hazardous
         materials shipper, carrier, or package manufacturer and who directly affects hazardous
         materials transportation safety during employment.

         State and Local Regulations
         In addition to the federal regulations identified in Table 1, numerous state and local EHS
         regulations also contain similar training requirements for employees. It is beyond the
         scope of this Best Practices document to identlfy all the state and local EHS training
         requirements. If you are uncertain of training requirements contained in state and local
         EHS regulations, contact the individual regulatory agencies for assistance.

         EHS personnel at othm GE facilities located in the same state may also be a good source
         of information about state regulations. Use the GE EHS Directory to identify these
         individuals. GE State Environets, organized by GE Government Relations, are already          i
         established in approximately 20 states to provide a network through which GE facilities
         located in the same state can exchange environmental information. Call your state
         government relations contact or Susan Walter, Vice President-State Government
         Relations, (202) 637-4450/8*272-4450, for information on the GE State Environet
         program.

         OSHA encourages states to develop and operate their own workplace health and safety
         programs. These programs must be "at least as effective" as the federal program, and in
         many cases are more stringent. Any health and safety program must comply with the
         requirements of the state program in which the facility is located. Compliance is not
.   ..   dependent on the location of corporate headquarters, state of incorpOration, etc., but on
         the physical location of the facility i question.
                                                n




         Remlalav-Rmumd EHS &
                            T                               -1993                    ornarlElmric
                                                          Page 4
3   For your reference, there are OSHA state plans covering businesses in the private sector
     in effect in the following states and commonwealths:

                 Alaska                     Arizona                     California
                 Hawaii                     Indiana                     Iowa
                 Kentucky                   Maryland                    Michigan
                 Minnesota                  Nevada                      New Mexico
                 North Carolina             Oregon                      Puerto Rico
                 south Carolina             Tennessee                   Utah
                 Vermont                    Virgin Islands              Virginia
                 Washington                 Wyoming


    CE Best Practices
    Training needed to safely perform work and protect the environment is not always
    specified directly in EHS regulations. You should consult GE Company Policy 20.3,
    Health, Safety, and Environmental Protection; the Procedure for Implementation of
    Health, Safety, and Environmental Protection Policy; and several GE Best Practices
    documents to understand the degree of training GE believes should take place. The
    Policy, Procedure, and Best Practices documents are a d a b l e through Corporate
    Environmental Programs (CEP). Several Best Practices documents are included in the
    list of useful references in Appendix B.

    Sources of Information
    Thew are several useful sources of information on EHS training requirements besides
    reading through the regulations. One source of information is Training Requirements in
    OSHA Standards and Training Guidelines, 1992. Single copies are available at no charge
    from your local OSHA office. State regulatory agencies may also be able to provide
    summaries of mining requirements contained in their regulations.

    Many GE facilities are using the Enflex Info@ system, a computer database containing
    federal and state environmental, health, and safety regulations. Information contained in
    the Enflex Info@ system can be retrieved using a key word search. The Enflex Info@
    system can identify regulatory training requirements by searching for the key words
    " r i , "training," "competent," "qualified," etc. The output will need to be reviewed to
     tan"
    determine those requirements applicable to your facility. Combining the key words
    "train"or "training" with words that describe certain job activities such as "mechanical
    power press," or "respiratory protection" will help to focus the output on operations
    applicable to your facility. For more information on Enflex Info@, contact ERM

                      . .                                                               c
Information Services, Inc., 855 Springdale Dr.,Exton, Pennsylvania, 19341, (800) 544-
                                                                                          1
3 1 18. GE has an agreement with ERM Information Services to provide Enflex Info@
systems to GE businesses at a discount.

Table 1 contains a list of training requirements grouped according to type of work
activity. The table is armnged so that the EHS Professional and other users can quickly
identie those work activities pertaining to facility operations.

Additional EHS regulatory training references are provided in Appendix B
               SUCCESSFUL " I N G               PROGRAM STRATEGY


A successful EHS-training program includes a plan to address all the identified training
needs for a facility on a continuing basis. Establishing a trahhg plan'allows the EHS
and business training professionals the opportunity to schedule and manage the training
program in an efficient manner. In addition, a written EHS-training program can be used
to present training requirements to upper management so that the training program,
including the program budget, can be a part of the facility's business plan.

Determine the Training Requirements
When developing an EHS-training program, start by identifying the training required for
employees at your facility. Many regulatory training requirements applicable to GE
facilities arc listed in Table 1. Other training requirements are found in state and local
regulations, in GE Best Practices documents, and in policies established for your facility.

Consider the following when developing a list of training requirements for your facility:

          Work activities currently in place at your facility that have training
          requirements

          Anticipated changes in the workforce responsibilities that will alter training
          requirements

          New equipment or processes that may mgger additional training requirements

          Modified work methods or job responsibilities that will require new or modified
         training

         Seasonal or non-routine work assignments subject to regulatory training
         requirements

         Training programs that may help to reduce or eliminate workplace injuries

Determine the type and frequency of training needed to meet the identified training
requirements. A few regulations are very specific as to the type of training, such as
classroom or hands-on, minimum number of training hours, and training frequency.
However, many training requirements, particularly those contained in older OSHA

                    . .
                                                   Page 7
standards, do not specify trairiing program content or frequency.
                                                                                              ?
Five OSHA Regional offices were contacted to determine how OSHA evaluates the
adequacy of training programs when regulations do not specify content or frequency.
OSHA responded that training should be performance oriented, relative to the hazard
level of a particular activity. With this guidance in mind, the content and frequency of
mining when none is specified will often be up to the best judgment of the EHS or
training professional, who must analyze the hazards involved in a particular activity and
determine what training is appropriate to mitigate the hazard. Table 1 and Appendix A
contain recommended training fkequency and content when none is specified in the
regulation. These recommendations should be considered "Best Practices" to assist you
in developing your training program.

Once the training requirements have been identified, identify the type and number of
employees that must be trained. include new hires or transferred employees subject to
initial training requirements and those employees subject to review training requirements.

The form shown in Figure 1 is used by several GE businesses and may help you to
identify the training requirements and develop a training program budget for your facility.
The budget must include hours employees will spend away fkom the job to receive
training. This can represent a significant investment for a facility. Plant management        1
should understand and approve of the time commitment needed to comply with EHS
regulatory training requirements.




Repul.lorv-Rmurrad EHS Tnuvn~                      hDnl15'93                Gsrnl E l m e
                                                 Page 8
3,
                                                          Figure 1

                                              EHS Training Needs Analysis

                                   Training                  . ,
     Trainiog   Numberof           coune                                           course    Total
      Topic     EmIoveu            Mated        initial    Annual                  HoUn      Hours




            R r a v d EHS TRvlmn                                      r\olil1993       (n lEltnnC
                                                                                        i m
                                                                     Page 9
         Training Materials
         The next step in developing an EHS-training program is to select the materials, course
         content, and instructors that will provide the required degree of training. You may design
         and conduct your own training course or take advantage of several training resources
         available to assist EHS and training professionals. The GE HazCom Training Program
         and the DrakeComputer-Based Environmental, Health, and Safety Training Systems are
         available through CEP. The Drake System, which has been purchased by GE for use m
         its operations, is an application of computer-based, self-paced instruction in the
         environmental, health, and safety areas. Additional GE guidance documents and mining
         programs available through CEP are listed in Appendix B.

         Your business group's employee training organization can be a great resource during the
         development and implementation of EHS training programs. They may have instructors
         on staff that can assist you in identifying and conducting effective training programs.
         They may also be able to provide classrooms complete with audio/visual equipment.

         Commercially-prepared training programs can be rented or purchased in video format.
         Training programs are sometimes available through the community fire, emergency
         response, and medical organizations or your local safety council. T o or equipment
                                                                              ol
         specific training, such as tools activated by explosive devices and self-contained           i
         breathing apparatus, can often be obtained through the vendors of these products.
         Training consultants are also available to develop and conduct training programs. Local
         colleges and universities are another potential source of training courses. Additionally,
         OSHA, through NTIS and GPO, offers training materials on many of the OSHA
         standards. A copy of the publication "OSHA Publications and Audiovisual Programs"
         (OSHA 2019), 1989 revised, is available free of charge fiom your local OSHA office.

         Evaluate the curriculum of several training courses to find those which best meet your
                                     os
         facility's training needs: D e the course meet the training requirements for content
         frequency, and duration? Is the material presented in an interesting and'effective
         manner? You may have to augment commercially-prepared training programs to include
-.   -   site-specific instructions and guidelines. Select the training courses which fulfill the
         training requirements and are compatible with your facility's culture and environment.
    I

    I
            I

            I            --
                              I
                              Awareness
                              I
                               -
                              Executlve
                              Management
I
    I
    I   I
            II   -??Re            -...

1 1 1 1                       IProduCt Life Cycle
                               _ _
                              IEHS Finance
                                       - _.
1 1 1 1                       1”Green”Marketing
                                            - -
                              I ween ratR3iTba
                                              e-
                               Lonrracr6FS h v n
                               New Employee
                               otners....


                              Skl11
                              Regulatory
                              Regulred




                                                    c
'3
3
                   Employee Training 'Tracking" System


3   Gonoral
      A great deal of training is required for employees to work in a Safe environment.
      This training includes hazardous communication (HUCOM), job related (forklift,
      drill press, etc.), compliance, and testing (physicals, exposure, etc.) training. Not
      many employees will need to have all the training offered, but it is important to have
      all employees properly trained in both their specific job responsibilities, and work
      areas.

    Putposo
      The purpose of this section is to offer some help in establishing an employee
      training tracking system. The system should be designed to:
       Document training requirements for each job classification
                                          -
       Tradc employee training history both initial and refresher training
       Provide flagging mechanism for employees who require specific training before
       working in certain areas

    Bonoflts
       Comply with OSHA requirement to manage employee training
       Improve employee safety
       Provide a safe environment     '



       Reduce workman's compensfition claims 8 premiums
       Reduce number of OSHA recordables
                    Employee Training "Tracking" System

    How To Implomont
3      Step 1,   Ensure complete documentation for each job classification
       Step 2.   Complete safety analysis for each job classification to assess employee
                 training requirements
      Step 3.    Complete work area safety analysis for each plant area to assess special
                 training requirements
      Step 4.    Establish a database of all employees, and the training they have
                          -
                 received Include information such as the type,frequency, and recency
                 of training received
      Step 5.    Reconale each employee's training history with current training
                 requirements
      Step 6 Obtain or create the course materials for all levels of training required
            .
      Step 7.    Communicate to all employees training requirements for each specific
                 job and work area
      Step 8.    Establish a training schedule to include all necessary courses
      Step 9.    Establish a goal (date) by which all employees must have taken training
                 specific to their work area
      Step IO. Update traininp database as employees take courses
      Step 11. Develop training database ability to flag training requirements when
               employees switch jobs or move to a different work area
      Step 12. Communicate new training requirements to these employees as
               appropriate

    Critical Succou Factors
      1.         New hires and temporary employees must take all applicable training
                       commencing their assigned duties in the plant
      2.         Key aspects of training must be reinforced on a regular basis.
      3.         Training responsibiliies must not rest alone with the EHS coordinator.
                 Plant leaden (Plant Mgr, MSO, shift leaden) must be,actively involved!
      4.         Keep the training as simple and interesting as possible.

3
3
  G                                  LJ                                  d
Chemical Management                                                 Measurements




  Overview

        A sustainable Chemical Management Process will only occur
        when plant performance is measured on a regular basis.
        The following pages provide examples of some EH&S
        measurements which may be used in your plant or business.
c                        Li                             d
    Environmental, Health and Safety Progress Summary




                                          J<evActions



                            I                               I
'3
                                   EHS Pro ress Summary
                                                   P
                                     COmp etion Guide
      1. Solf Assossmont

         This indicator includes, but iS not limited to, activities that the plant conducts such
3 ,      as the following:
          .                                of machinery guarding, weekly PH probe check,
          . HAZCOM labeling, air pollution control equipment, etc.
                                                   -
                                               Evaluation of Hearing Conservation Program,
          . Emergency Response, selected EHS Work Plan activities, etc.
           pa
           -e
                                               -
                                    ' Thorough evaluation of a job or operation targeted
                                              and developing Standard Operating
            Procedures (SPOs).
                          -
      2. EHS Tralnlng Reported as person hours per quarter
                                           -
      3. EHS Commlttm Uootlngs Reported as number of meetings per quarter
      4. OSHA Assosmnwnt Roport                Scon - This indicator is calculated based upon
         ratings submitted monthly
                                                          -
      5. OSHA Rocordablo Injury Or ill no^ This indicator is reported monthly.
                                   -
      6. Enwrgoncy Incldonts This includes events typically due t procedural,
         personnel, and/or equipment failure. (e.g. SO2 leak resulting from a VauW valve).
                                   -
      7. Permit ex coo don^ This includes 'elevations' typically due to inadequate
         equipment, processes and/or controls (e.g. elevated waste water levels in excess
         of permit limits).
          These types of "elevations" could potentially o a r in the following media:
             Air                  Waste
             Water                Industrial Hygiene
                                                   -
      8 . Workor's C o m p m u t l o n Costs Average costs in dollars per employee per
          year.
                  -
      9. Flnes Total number of dollars in regulatory fines.
                          -
      10. Waste Costs Waste costs in dollars.
                                       -
      11. SARA Roductlon Indox The numerical difference between the number of
          pounds of SARA chemicals for the previous year and the number of pounds of
          SARA chemicals for the current year.
      Calculation:
                           .# of pounds of chomlcal XX for 1992
                                        of -1           for 19U
                              W R o d u c t l o n Index
3
                      EHS Progress Summary Completion Guide

Here are some additional "indicators" you may want to incorporate:

1.      Injury and Illness Index
               '   (# Actual lniuriesl + I# Actual Illnesses)
                           Person Hours Worked

2.      "Sate"'Unite P r o d u d Ratio
     L Inits Produced) - (# Units Produced durina shift when will or accident occurredl
                                         # Units Produced


3.      Waste Mlnimlzation Index
                        Pounds of Waste Generatd
                            X Units Produced

4.      Compliance Index
        The actual number of "violation items" (each individual citation, exceedence
        result. etc.) identiied in any formal Regulatory Citation, Notice of Violation,
        Finding and Orders or Notice of Deficiency.


5.      Audit "Fkw"Index
        The number of audit findings or deficiencies that have been remedied.


6.      Training Ratio         _.

        Use training needs assessment to determine denominator:
                                     Number Of M O Dle trained
                                      People needing training
                                                     or
                               Hours of reauired trainina ComDleted
                                     Training hours needed
3
    ELJNES GIVEN TO PldblyT MANA-


    MEASURE YOUR ORGANIZATIONSEHS                               AND             :I
                                                                                \
                                                                                 I



    ESTABLISH I M P R O l ' ~ G 0 A I . S TERMS OF MEASUREABLERESULTS
                                          IN
    -  % reduction in hazardous and solid wastes
    -  % reduction in OSHA recordabk and lost workday cases
    -- % reduction in emissions
       Zero discharge of contaminated waewater from specific processes


    --
    SJ%T-GOALS
        Measure non-compliiance 2 number, frequency, amount of penalties, etc
.
.
     -                           -
        Measured or permitted proeesscs
                                            -
        Compliance requirements self audits specifications

    lDENTlFY THE SPECIFIC ACTIONS YOU WILL TAKE TO ACHIEVE YOUR IMPROVEMENT
    ANDCOJUPL1AN(=E GOALS
EHS STAFF          PLANT MANAGERS                     BUSINESS MANAGERS




 PerfonnanlcData
                   \     Sef Plant Gods
                                                                      I
                                                                      t




   PrOgtrmRogmJ




                   L




                                          ICDetmnhtion
   Timing                                 Performance
                                           Appniaal
        CHEMICAL MANAGEMENT FUNCTIONS AND RESPONSIBILITIES

                                         FROM GEIPS WORKOUT, 4/93



 PROCESS ENGINEERNG(MANUFACTURING
                                ENGINEERING)                         PROMJCT/PROCE8S m S G N ENGINEERS

I. Identify potential EHS requirements in new and         1. Ensure EHS design review (new, changed designs)
     modified processes                                   2. Identify potential EHS requirements to include only
2 Specify and use approved material                            approved chemicals
3. Ensure appropriate storage and handling --Job Hazard   3. Identify critical chemicals
     Analysis, Personal Protective Equipment              4. Ensure receipt of MSDS
4. Productlprocess life cycle                             5. Identify transportation issues
5. Comply with HazCom Standards                           6. Participate in awareness of corporate EHS objectives
                                                          7. Product life cycle (POWER)

                        RECEWNG                                             PURCHASING 1SOIJRCING

1. Accept only approved materials                         1. Purchase only EHS-approved materials
2. Deliver approved materials to designated area          2. Assure EHS review of new materials
3. Control and limit receiving points                     3 Notify EHS prior to import
                                                           .
4. Ensure proper storage                                  4.   Maintain approved chemical list
5. Meet DOT requirements                                  5.   Obtain and maintain new MSDS
6. Comply with HazCom standards                           6.   Conduct vendor approval
7. Collect RigM-To-Know data                              7.   Collect RigM-To-Know data
3
Chen,,cal Management                                                               Key Roles & Responsibilities

Roles & Responsibilities That Drive Ownership


                          Aevlew impad of NPllprocess changes on chemical management      4
       Up Front           Translate Best Practices thru plant/Eusiness
                          Pennits current and t b compliant
                                              u                                           J
       Controls       0   Appmed chemical list in place                                   J
                          Monitoring of epproved chemical list                            J


                          EHS approval obleln for    ch~miCalS                                         I
                                                                                                       .
      Procurem1           MSDS lib complete and accessible                                J
       Controls           Designated chemkal mcdvefs trained                                           J
                          chemicals propedy stored and labeled                                         .I


          V               OSHA recordaMeslksl time acddents minimized                     J            J
        n
       I PInt             Chemical Inventov for area accurate                             J            .I
       Controlr               -  chemical inventory minimumized
                              -  chemical usage in area tracked
                          Training cunent end comprehensive                               J
           I
                      0

                          Fully understand chemical usage in process                      J            J



  I     Waste
       Stream
      Mnnag8mt
                  I       P e d s cunent and fully compliant
                          Identify opportunities t switch from hazardous
                                                  o
                          chemicals into equivalent non-hazardous chemicals
                          Wastes property handed, stored, and d i m d of
                          ~ully understand waste generation and discharge points
                                                                                          J
                                                                                          J
                                                                                          J
                                                                                                       J
                                                                                                       J
                                                                                                       4
3
CJ                             Li


GElS Chemikal Control Process
                                        Dwdhtod to cUrt0m.v s a .
                                                             u#.



                         DISTRIBUTION




     System Records:
         whatused
         Where Used
         How Much Used
3
GElS Chemical Conltol Process
                                           D8dbtodtocwtomwsua#..


                          DISPOSAL




    Tracking By Process and Work Station
3
P / a k sweep                              W'               Inventory Decisionqath




  chemical                        Talk 70
                                 Operators !                         Record on
                                                                  Inventory Form
                                                                              A

                                                                                     On
  It Is?             Area?




                     f-l
                                                                              1
                     OBSOLETE                               Get Operator to         Note as
                                        Note as
                                       "Improper            Label                    "Not
   Removal Label     Removal Label                                                 Approved
   Removal Log       Removal Log       Container"
                                           on                Note as                  on
   LEAVE IT!         MOVE or LEAVE                          "Improper              Inventory
     (note on log)    (note on log)    inventory
                                         Form               Label" on                Form
                                                            inventory Form             1

                                                    I   I                     1


                                                                                    DONE
''I
                                   4.0 Plant Sweep



Most of the information you need for the plant sweep is outlined in the "Plant Sweep
Guidebook" (Appendix G ). There are a few points that need to be stressed. The points
below are also covered in the "PrePlant Sweep Assessment" Checklist, attached to this
section.

Please Review the Plant Sweep Guidebook (Appendix G) Thoroughly! The
Guidebook and Checklists (Appendices B E ) will help answer most of your
questions and help you prepare for a successful plant sweep and chemical
inventory.


4.1   Safety
      Having the Chemical Awareness Team on the floor looking for and handling
      chemicals can be a recipe for danger if the team is not adequately trained and
      safety precautions are not in place. Some training will be covered during the pre-
      sweep session. Make sure your HazCom training is up to date and all HazMat
      personnel have been adequately trained. Make sure your Contingency Plan and
      Emergency Response Plan are current.
      Safety equipment for the team should be on hand. (See Pre-Plant Sweep
      Assessment Checklist, page 4-3 below, for more detail.)


4 2 Communication

      Advance communication to plant personnel is critical. When the CAT teams hit
      the floor, there can be confusion and apprehension unless the purpose and
      logistics of the sweep have been communicated to evelyone. Plant newsletters.
      posters. electronic messages are all useful vehicles for this type of communication.


                                                        -
                        See 'Sample m s s Releass " Appendix F-
                                   for More Information.




                                      Dam 4- 1
3
3
-
    4.3   Staging Area
          Chemicals that are to be removed must be collected in a central point. This area
          should be:
             Remote
             Secure
             Staffed at all times
             Phone and emergency response equipment in place
                           -
             Expandable minimum sire is 3'x 50'
                                              0
             Set up to allow segregation of incompatible materials

                     Motors' Business EHS Staff will work with each site to ensure
                       the adequacy of the staging area and staging personnel.



    4.4   Waste Management
          Lab packing and removal of obsolete and unknown chemicals found during the
          sweep must be accomplished as quickly as possible a t r the sweep.
                                                             fe



                 I   Motors' Business EHS Staff will work with each site to ensum
                        the adequacy of tab packing and waste removal plans.         I
3
3

    CONDUCTING A PLANT CHEMICAL SWEEP
          A GUIDEBOOK FOR GE MOTORS




           PREPARED FOR GENERAL ELECTRIC BY:

         GLOVER-STAPLETON ASSOCIATES, INC.
                  55 SCUDDERROAD
                 NEWTOWN, CT 06470
                   Tal:    (203) 426-0163
                   Fax:   (203) 426-4426




                    APRIL 27, 1993
'3
        GUIDEBOOK ON PLANT CHEMICAL SWEEPS
                             GE MOTORS


TABLE OF CONTENTS


Introduction                                      Page 1

How to Use This Guldebook                         Page 2

Section 1: Preparing for the Physical inventory   Page4

Section 2: Conducting the Physical inventory      Page 10
     Chemical Inventory Day Agenda                Page 11
     Instructions for Team Leaders                Page 12
     Procedures for Physical Inventory            Page 13
     Procedures for Staging Area Personnel        Page 17

Section 3: Supportlng Documents                   Page 18
     Training Plan Outline                        Page 19
     Health & Safety Plan Outline                 Page 20
     Sample Newsletter Article                    Page 21

Appendix                                          Page 22
     Plant Sweep Inventory Form
     Chemical Removal Label
     Chemical Inventory Removal Form
3




'3.
 ..
             GUIDEBOOK ON PLANT CHEMICAL SWEEPS
                         GE MOTORS


INTRODUCTION

This guidebook contains step-by-step procedures for planning and conducting
chemical sweeps at GE Motors manufacturing locations. The chemical sweep is
a key tool for improving the management of chemicals within GE Motors and is
an integral part of the overall Chemical Management Program.
The term "plant sweep" is used broadly to include all of the planning,
preparation, physical inventory of chemicals, and follow-up activities discussed
in this guidebook. The term "physical inventory" refers to the actual identification
and recording of chemicals used at the plant, along with associated labelling,
repackaging, and collection of obsolete chemicals for subsequent disposal.
A chemical sweep can provide many benefits, including:
        help plant staff to develop an accurate baseline of information for an
        approved chemical list
        eliminate unnecessary or obsolete chemicals from the plant
        allow the plant to assess and improve chemical storage and
        handling,
        help the plant to improve compliance with EHS regulations, and
        provide a starting point for reducing chemical use and waste
Perhaps most importantly, the plant sweep can help to raise employee
awareness on chemical risks, proper procedures to reduce those risks, and the
need for all employees to actively participate in chemical management.
The guidebook is divided into several sections.
        Section 1 discusses the planning efforts that must be carried out prior
        to the actual physical inventory ("Pre-work Phase").
        Section 2 provides recommended procedures and practices for
        conducting the physical inventory of chemicals in the plant.
        Section 3 provides recommended elements for plans that support the
        chemical sweep, such as a health & safety plan and a training plan.
3
                                                                                         2

    The Appendix contains sample inventory forms and labels that you can use
3   during the physical inventory at your plant.
    This guidebook is most effective if the sample plans and procedures are tailored
    to the circumstances of each individual site. If you have comments or
    suggestions for improving the usefulness of this document, please provide them
    to the Manager of Environmental Programsfor GE Motors.


    HOW TO USE THIS GUIDEBOOK

    A chemical sweep of your plant to assess chemical usage can be a very
    worthwhile undertaking. However, it is a time-consuming activity and requires
    commitment from many individuals.
    Before initiating a chemical sweep at you plant, read through this guidebook to
    get an idea of the activities and level of effort involved. Consider whether there
    might be a good time for certain activities to take place at your plant. For
    example, you may want to combine the chemical sweep with a more general
    plant clean-up activity.
    Review the "pre-work" steps in Section 1 to see how much lead time you need
    to conduct the sweep. Some of the pre-work activities may require ordering of
    supplies (such as pre-printed labels and containers), or negotiating for certain
    services (such as lab-Packing and disDosal of obsolete chemicals). You will
    also need time to seleit and Train the members of the inventory teams. Allow
    yourself sufficient time to complete these activities prior to the actual physical
    inventory.
    While this guidebook describes a series of activities that should result in a
    successful chemical sweep, this activity will be more effective if you tailor the
    program to the specific needs and circumstances of your plant. Working with
    your site management and EHS Committee will help to ensure that the
    chemical sweep will accomplish jts objectives without significant disruption of
    the production process.

    The following are a few helpful hints, based on experiences of other plants in
    conducting chemical sweeps:
    Communicate with employees early and often. Make sure they
    understand the "why, when, who, where, how" of the physical inventory before
    the inventory team shows up.
    The physical inventory will probably take more time than you
    anticipate. Make sure you have ample time and resources for inventory
    teams to do a thorough job.
                                                                                    3


Don't hire an outside contractor to perform the physical inventory.
Two of the primary benefits of this activity are to raise employee awareness and
ownership of chemical management. Using plant teams to plan, conduct, and
follow-up on the plant sweep will help to establish continuity. However, you may
want to hire contractors for some specific activities, such as lab-packing and
disposal of obsolete chemicals.
Review the information collection procedures and forms to make sure
you will end up with the information that you want. Train inventory teams on how
to conduct the inventory and what the plant hopes to achieve. Pay particular
attention to defining the categories of the information you will be collecting.
                                                                          '
Have a pian for what the plant will do with the information
collected. Objectives might include updating or preparing an approved
chemical list, preparing a target list of chemicals for elimination, or reviewing
chemical use for possible consolidation or substitution.
Maximize the value of time spent on the floor by using tools such as
pre-printed labels, a chemical "short form" and an MSDS index.
                                                                                  4


      SECTION 1 PREPARING FOR THE PHYSICAL INVENTORY
                        ("PRE-WORK")

This section describes a series of activities for planning and preparing for an
effective plant chemical sweep. These activities include:

          defining the objectives of the chemical sweep
          communicating with employees on the purpose of the chemical
          sweep and how it will be carried out
      -   planning the physical inventory and developing detailed
          procedures
          getting commitment and buy-in from site management and
          support functions,
          obtaining supplies
          training the inventory teams
The activities are presented as a sequence of events (that is, what should be
done at least a month before the inventory, what should be done three weeks
before the inventory, and so on). The sequence of plant sweep activities may be
slightly different at each plant.
3
                                                                                       5


3                           PLANT CHEMICAL SWEEP
                      PRE-WORK REQUIRED AT EACH PLANT
    ADDroxlmatelv One Month Before the Inventorv:

    1. Meet with the Plant Manager to discuss the objectives of the chemical
    sweep and the potential costs (in terms of manpower, supplies, and disposal)
    and obtain management commitment.
    2. Determine who will be the champion for this activity at the plant. This could
                                                                    f
    be the EHS Manager, the Facilities Manager, or the Manager o Shop
    Operations, for example.
    3. Define the objectives of the plant sweep. Objectives could include:

              developing information for an approved chemical list,
          -   ensuring that all chemicals are properly labelled and containerized,
              eliminating obsolete chemicals,
              improving compliance with OSHA, RCRA and other laws,
              heightening employee awareness of chemical management.
    Decide whether the plant sweep be a one-time event or an on-going activity.
    Also, determine whether the chemical inventory should be combined with a
    more general plant clean-up day or an overall chemical awareness week.
    4. Begin communicating with employees early in the process. Explain the
    "WHO, WHAT, WHEN, WHERE, WHY" of the chemical sweep. Emphasize with
    them that if everyone is adequately informed and prepared, the chemical sweep
    will go more smoothly and the results will be better. Also, communicate that the
    chemical sweep is part of an on-going chemical management process, and not
    simply a one-time event. Communication tools could include:
            Posters, articles in the plant newsletter, meetings with employees and
          staff members. (See section 3 for a sample newsletter article).
            Prepare talking points for section or area supervisors that they can use
          in employee meetings. Emphasize that everyone has responsibility for
          chemical management.
           If the chemical sweep will be part of an overall chemical awareness
          week, integrate communications on the sweep with the broader chemical
          awareness message.
3
                                                                                       6


3   5. Get the plant's EHS Committee involved in the planning of the chemical
    sweep early in the process. Review initial plans with the the EHS Committee
    and develop an action plan. As part of the action plan, consider what training
    might be required for employees involved in the physical inventory. Training
    should cover: what "chemicals" are, how to conduct the inventory, labelling
    requirements, MSDS, and health & safety issues. Also work with the EHS
    Committee on how to sustain the interest and ownership of chemical
    management after the sweep is done.

    ADDroxlmatelv Three Weeks Before the Inventorv:
    6.Collect and review existing data on chemical usage at the plant. This
    could include:
               EPCRA reports
               MSDS files or index
               RCRA waste generator reports
           -   Records of chemical purchases
               Chemical inventory developed for HAZCOM
    7. Use the existing data on chemical usage to prepare a "short list" of
    chemicals that you expect to find frequently in the plant (such as various oils,
    coolants, varnishes, solvents, and paints). On the "short list", include the
    manufacturers name and code number, and whether or not an MSDS is
    available. (If you do not have MSDS for all "short list"chemicals, request one
    from the supplier). You may also want to prepare a list of chemicals that the
    plant has eliminated or is trying to eliminate.
    8. If the plant does not already have an index of MSDS for chemicals in active
    use, you should consider preparing one prior to the physical inventory.
    9. Line up disposal contractors for collected materials. You may also want
    to negotiate with contractors to perform any lab-packing that may be necessary.
    10. Prepare preprinted labels for each of the chemicals on the "short list" to
    be used during the physical inventory. These labels will be used during the
    physical inventory when unlabeled containers are found. Also, obtain blank
    labels to be used for other chemical containers found without labels during the
    inventory. At a minimum, labels should provide the chemical name,
    manufacturer, target organ(s), and hazard(s) posed.
    11. Order containers, labels (pre-printed and blank), T-shirts for Inventory
    Teams, and other supplies as needed. Make sure that other supplies are readily
3
                                                                                        7

    available, such as carts, gloves, spill clean-up kits, radios, etc. Make sure you
3   have on-hand small (five-gallon or smaller) safety cans. These should be used
    for repackaging flammable materials that may currently be stored in
    inappropriate containers (such as coffee cans) on the shop floor.

    ADDroxlmateiv Two Weeks Before the inventorv:

    12. Develop a health & safety plan for the physical inventory. (See Section 3
    for guidance). The plant may already have a suitable plan that could be used. At
    a minimum, the plan should address:
               fire hazards
           -   spills
               chemical compatibility
               personal protective equipment
               emergency response procedures
    Depending on your plant, the plan may also need to address handling of gas
    cylinders, confined spaces, or other topics.

3   13. Working with the EHS Committee, delineate shop areas and assign
    responsibilities for conducting the inventory. Use maps to delineate the
    areas, including tool cribs, maintenance shops, and shippinglreceiving
    areas.& sure to include "outdoor" areas of the plant where chemicals may be
    stored or used, such as loading docks, tanks, chemical and waste storage
    buildings. Support areas, such as power plant and wastewater treatment
    buildings, should be included in the inventory. If contractors on-site are using
    chemicals, these areas should be considered in the inventory.
    In order to facilitate inventory planning, take a plant tour with the EHS
    Committee. This will help to understand the magnitude of the effort and may
    help to identify other chemical management issues.
    14. Select inventory Teams and Team Leaders. It is recommended that
    the Team Leaders have at least several years of experience at the plant. In
    addition, it would be helpful if the Team Leaders have worked in or are
    otherwise familiar with different areas of the plant.
    Consider forming Inventory Teams with "cross shop" experience: that is, have
    one team member from outside the area assigned to the Team for the inventory.
    This will give each Team a "fresh set of eyes" when conducting the inventory.
    Teams can be composed of two to three individuals, depending on the size and
    complexity of the assigned area.
3
                                                                                        8

    15. Define the information you want to gain from the physical inventory and
3   develop an approach for collecting and recording the information. A sample
    inventory form is provided at the end of this section. Minimizing the amount of
    writing that Inventory Teams must do will provide more time for other activities,
    such as discussing chemical management with employees. One "short cut"
    might be to assign code numbers to each chemical on the short list. This would
    allow team members to record a short code number rather than writing the
    same information on the Inventory form many times.
    16. Consider how you will deal with any "unknown" chemicals that may be
    encountered during the Inventory. These "unknowns" could pose significant
    hazards and should be handled with care. It is recommended that unknown
    chemicals be moved to the staging area rather than left on the shop floor where
    employee exposure may be an issue. Consider using trained material handlers
    to move chemicals to the staging area to minimize the potential for injuries,
    chemical spills or similar incidents.
    17. Meet with the Plant Manager, MSO(s), and Shop Supervisors to
    discuss inventory plans so that disruptions to plant operations can be
    minimized. Meet with managers of any support functions (such as Maintenance
    and Material Handling) to line up any necessary support.
    18. Discuss Inventory plans with Human Resources Manager and, if
    appropriate, with Shop Steward(s) to minimize any problems related to looking
    through personal items, such as lockers, tool boxes, etc..
    19. Review potential staging areas for chemicals that may be collected
    during the Inventory. Areas that may be suitable include hazardous waste
    accumulation areas and chemical storage buildings, among others. In
    evaluating staging areas, consider:
              area capacity
              secondary containment
              area security
                                __
          -   fire protection

              ease of access on the day of the Inventory
              availability of telephone, eyewash, and other safety equipment
              any regulatory, insurance, permit, or similar constraints
3




3
                                                                                       9

    Aimroximateiv One Week Before the inventorv:
3   20. Meet with Team Leaders to review inventory procedures, inventory
    forms and recordkeeping, health and safety, and other key issues. Stress the
    need for thoroughness and what to do if "unknowns" are found. Also, explain
    how to dispose of rags, gloves or other wastes generated during the Inventory.
    Make sure Team Leaders understand the definition of different Inventory
    information categories. There may be confusion about the differences between
    "chemical names" and "trade names", for example. Try to make the Inventory
    procedures as simple as possible.
    21. Designate at least one person (with a back-up for relief) to work in the
    staging area on the day of the Inventory. The staging area should be manned
    whenever Inventory teams bring collected chemicals to the staging area.

    Prepare procedures for receiving chemicals, segregation of incompatibles, and
    recordkeeping at the staging area. Consider RCRA impacts on this activity, such
    as when a material becomes a "waste" and potentially subject to hazardous
    waste management requirements. (See sample procedures in Section
    2.).

    22. Designate an inventory Coordinator who will monitor progress, redeploy
    teams as necessary and call on experts.

3   23. Plan some type of recognltion for Team members and other employees
    after the Chemical Sweep is completed. Prepare an article for the plant
    newsletter thanking everyone and discussing the results.
    24. Conduct training for inventory Team members to ensure that they
    understand the Inventory procedures and their specific responsibilities.Refer to
    Section 3 for guidance.
'3
                                                                               10


3          SECTION 2 CONDUCTING THE PHYSICAL INVENTORY

    This section discusses how a physical inventory of chemical usage can be
    conducted. This section contains:
            a sample agenda for the day of the Inventory
            sample instructions for team leaders
            sample procedures for conducting the Inventory

    The sample procedures for conducting the Inventory cover:
            Inventory teams

            staging area personnel.

    These documents should be tailored as necessary to reflect plant
    conditions and circumstances.
3
                                                                      11

                           CHEMICAL INVENTORY DAY

                                   AGENDA



     7 5 0 A.M.   EHS SPECIALIST, INVENTORY COORDINATOR AND OTHER
                  FACILITATORS MEET WITH TEAM LEADERS TO REVIEW
                  PLANS AND PROCEDURES



     8:OO A.M.    TEAM LEADERS ORGANIZE/MEET WITH INDIVIDUAL TEAMS.
                  REVIEW PROCEDURES, AREAS OF COVERAGE.



     8:30 AM.     BEGIN PLANT INVENTORY



.3   12:oo        AT LUNCH, TEAM MEMBERS MEET WITH EHS SPECIALIST,
     NOON         INVENTORY COORDINATOR AND FACILITATORS TO
                  DISCUSS PROGRESS



     12:30 P.M.   CONTINUE INVENTORY AFTER LUNCH

                             __
     4:30 P.M.    MEET AT END OF DAY TO DISCUSS RESULTS
                  -   WAS INVENTORY COMPLETED?
                      HOW COULD PROCESS BE IMPROVED?
                                     S
                      WHAT FOLLOW-UP I NEEDED?
                                                                     12

                        CHEMICAL INVENTORY
                   INSTRUCTIONS FOR TEAM LEADERS

     PRIOR TO MEETING WITH YOUR TEAM:
     1. MAKE SURE THAT TEAM HAS APPROPRIATE PERSONAL PROTECTIVE
     EQUIPMENT (INCLUDING GLOVES, SAFETY GLASSES) ADEQUATE
     LABELS, COPIES OF MSDS, CONTAINERS, IDENTIFYING T-SHIRTS AND
     CARTS.

     AT START OF DAY:
     1. REVIEW MAP OF AREA TO BE COVERED WITH TEAM. MAKE SURE EACH
     TEAM MEMBER UNDERSTANDS HISMER ASSIGNMENTS.
     2. REVIEW INVENTORY FORM AND CHEMICAL REMOVAL FORM WITH
     TEAM. MAKE SURE EVERYONE UNDERSTANDS THE INFORMATION TO BE
     COLLECTED AND WHY IT IS IMPORTANT.
     3. REVIEW WITH TEAM HOW TO HANDLE UNLABELED CHEMICALS

     4. REVIEW PROCEDURES FOR COLLECTING OBSOLETE CHEMICALS

     5. REVIEW PROCEDURES FOR HANDLING "UNKNOWN" CHEMICALS.

     6.REVIEW COMMUNICATIONS AND HEALTH AND SAFETY PROCEDURES.

     DURING COURSE OF THE INVENTORY:
     1 . ACCOMPANY TEAM MEMBERS TO ENSURE THEY UNDERSTAND
     PROCEDURES AND TO ANSWER QUESTIONS.
     2. CHECK IN REGULARLY WITH EHS SPECIALIST AND INVENTORY
     COORDINATOR WITH ANY QUESTIONS.

     AT END OF DAY:
     1. COLLECT ALL UNUSED LABELS, MSDS, CONTAINERS AND RETURN TO
     INVENTORY COORDINATOR.
     2. LOOK OVER AREA TO ENSURE THAT OBSOLETE CHEMICALS HAVE
     BEEN MOVED TO STAGING AREA.
     3.RETURN CARTS AND ANY OTHER SURPLUS MATERIALS.
     4. THANK TEAM MEMBERS FOR THEIR HELP.
'd
3
                                                                                            13

        DETAILED PROCEDURES FOR PHYSICAL INVENTORY
3                                (INVENTORY TEAMS)


    BEFORE STARTING:
    1. Meet with Team Leader to review Team's area of responsibility and individual
    assignments
    2. Obtain labels, MSDS, Inventory forms, labels, magic markers, and other
    supplies. Verify location of other supplies (containers, carts, etc.)
    3.Review these procedures and ask Team Leader if you have any questions.
    Make sure you understand the information to be collected, wherelhow to find it,
    and how to record it.
    4. Review the Health & Safety Plan. If any health or safety issues arise, check
    with your Team Leader or the EHS Specialist.
    5. It is essential that vou have and use the DroDer Dersonal Drotective
    eaubment while conducting the inventory. At a minimum, you should wear long
    pants, a long-sleeved shirt, safety glasses with side shields, gloves, and an
    apron. Check with the EHS Specialist for specific requirements.

    CONDUCTING THE INVENTORY:
    THESE PROCEDURES COVER SEARCHING FOR CHEMICALS,
    RECORDING THE REQUIRED INFORMATION, COLLECTING
    OBSOLETE OR UNNECESSARY CHEMICALS, MATERIAL
    HANDLINGAlOVEMENT, AND WASTE ACCUMULATION

    1. Look over the area you will be covering and lay out a logical plan for
    agsessing chemical use and storage in the area. Take your time and be
    thorough. Depending on the area to be inventoried, you may want to work your
    way across the shop floor (looking in all potential locations) or you may choose
    to inventory the area based on type of location (that is, look in all cabinets first,
    then on all shelves, then around all tools, etc.) Keep notes of what areas have
    been inventoried. Mark each chemical container that you record with an
    indelible marker to keep track of containers that you have already inventoried
    2. Make sure to check In all of the following locatlons (if they exist in your
    area):
           ALL TOOLSEQUIPMENT                     WORK BENCHES
           (ON, UNDER, AROUND)                    (ON, UNDER, AROUND)

             IN FIRE CABINETS                           IN LOCKERS, ON SHELVES

             IN TOOL BOXES                              IN CORNERS/AISLES
                                                                                        14


3   Your inventory should also cover areas above and below the shop floor (such
    as in basements and on catwalks, as appropriate).
    3. Keep records of all chemicals found on the Inventory form. Remember that
    the term "chemical" includes materials essential to the operation of a tool or
    piece of equipment (such as oils and lubricants), materials that may become
    part of the product (such as glues, paints, varnishes, and solder), and other
    materials used for maintenance, cleaning or that are otherwise associated with
    the process (such as solvents or other degreasers). Your co-workers may not
    think of all these items as "chemicals" when you ask them what they use. WHEN
    IN DOUBT, WRITE IT DOWNI! (You may want to have one team member record
    the information in the morning while the other@) label, collect obsolete
    chemicals, etc., and then switch tasks in the afternoon.)
    Many chemicals have names and numbers that are very similar. Take your time
    and record the information carefully.
    4. Ask people working in the area what chemicals and raw materials they work
    with (both on a daily basis and occasionally). Key questions include:
            How do you obtain chemicals,oils, etc.?
            How are these materials used in your operation(s)?

J           Where and how are these materials stored in your area? For how long?

            What do you do with empty containers?
            How are wastes managed?
    5. UNLABELED CHEMICALS- You may locate a chemical container that
    has no labels or other markings to identify its contents. If this happens, try to
    identify the container's contents by asking workers in the area. If the material
    can be accurately identified, label the container, using either a pre-printed or
    blank label. Make sure that the label is firmly attached to the container. Verify
    that the type of container used is suitable for the chemical in question.
    6. OBSOLETE CHEMICALS- You may find a chemical that is no longer
    used in the area, that has never been used in the area, or that is beyond its
    shelf-life. This chemical should be collected and transferred to the chemical
    staging area designated for the Inventory. Before moving any chemical
    containers, complete the "removal form" and place a "removal label" firmly on
    the container. it is important that all removed containers have a unique
    identification code so that the container can be properly characterized for later
    disposal. (See Procedure 11 for guidance on unique identification codes.) Refer
    to the health & safety plan for precautions on moving and consolidating
    chemicals.
                                                                                          15

    7. "UNKNOWN" CHEMICALS- You may also come across containers that
    are not labelled and that personnel in the area cannot identify. In these cases,
    contact your Team Leader or the EHS Specialist for assistance. Determine if the
    chemical is still being used in the area, and if so,for what purpose.If the
    chemical is obsolete, put the container on a cart for transfer to the staging area.
    Be sure to mark these containers as "unknowns" using the provided labels.
    Also, record the container on the "removal form", noting the location where the
    container was found and describing the contents if possible (by color and
    consistency, for example).

    It Is very Important that any unknown Containers be handled
    carefully. If there is any Indication of leakage or If you have any
    other concerns, call the EHS Specialist.


    8. IMPROPER CONTAINERS- Some chemicals may be stored in containers
    that are unsafe. One example is open coffee cans used for volatile or flammable
    chemicals. Containers that are leaking, rusty or otherwise in bad condition are
    also unsuitable. If you find such a container, obtain an appropriate replacement
    container and assist operators in repackaging the chemical. Affix an appropriate
    label on the new container, removing the old label if necessary. On the
    Inventory form, note that the chemical was repackaged.
    9. EMPTY CONTAINERS- If you find an empty chemical container that is no
    longer in use, place the container on a cart for transfer to the staging area. If
    possible, identify what chemical was held in the container.
    10. Keep accurate records on all chemicals you find during the Inventory.
    The "Plant Sweep Inventory Form" should be completed for each chemical
    container. A copy of this form is provided with these procedures. The form
    includes space to record the following information:
            Chemical identity (including the chemical name, the trade or common
           name(s), manufacturer and/or vendor
             How the chemical is packaged (container type and size and whether it
           is labeled) and,
            How the chemical is managed (where it is located, where it is obtained,
           how it is used).
    11. For any chemical that la removed from the shop floor (or any other
    location where it is found), some additional recordkeeping is needed. First,
    attach a "removal label" to the container (see sample). This label will facilitate
    tracking of individual containers, their sources, and their contents. Any container
    removed from the shop floor should also be noted on the "removal form" (see
    sample). Both the removal label and the removal form should indicate a unique
    identification number for each removed container, so that the container and the
3
'3
                                                                               16

information on the form can be matched up at a later time.The identification
number could be, for example, a combination of the team member’sinitials and
a sequential number for each removed container (such as PSOl, PS02 and so
forth).




                               .
                             . ..
                                                                                        17

                             PHYSICAL INVENTORY
3             PROCEDURES FOR STAGING AREA PERSONNEL

    Introduction
    One or more staging areas will be designated prior to the day of the Inventory.
    Any chemicals removed from the shop floor (or other location) will be
    transferred to the staging area. Once chemicals are brought to the staging area,
    they will be reviewed to determine if they can be reused or must be disposed of.
    It is recommended that at least one person be present in the staging area
    whenever chemicals are being transferred there by the Inventory Teams.
    Procedures

    1. Accurate records should be maintained for all chemicals and empty
    containers brought to the staging area. When chemicalslcontainers are brought
    to the staging area, verify the contents, the source of the containers, and the
    condition of the containers.
    2 All chemicalslcontainersbrought to the staging area should be evaluated for
    compatibility with other materials stored there. Incompatible materials should be
    segregated from each other. Refer to the label, the MSDS, or the Health &
    Safety Plan for guidance on material compatibility.

    Any "unknown" chemicals brought to the staging area should be
    handled wlth the utmost care. If there is any doubt as to how a
    material should be stored, contact the EHS Manager.


    3.Chemicals and containers brought to the staging area must be adequately
    characterized in order to determine if they can be usedlreused or must be
    disposed of. This determination should be made by the EHS Manager, based
    on knowledge of plant processes and chemical use, MSDS, chemical
    analysis, or other appropriate information.
    4. Personnel working in the staging area should familiarize themselves with the
    Health & Safety Plan for the Inventory and should know the locations of safety
    equipment found at the staging area (such as eyewashlshower, telephone,
    personal protective equipment, and spill clean-up supplies).




3
3
                                                                                       18


                 SECTION 3 SUPPORTING DOCUMENTS

Prior to conducting the Inventory, it is recommended that a Health & Safety Pian
and a training pian be devdioped. It is possible that the site's existing plans will
be adequate for this purpose. Once the procedures for the inventory have been
tailored to any specific site considerations, the EHS Specialist and EHS
Committee should evaluate whether any additional health & safety training
might be needed for the inventory Teams and staging area personnel.
This section provides sample outlines for a Health & Safety Plan and a
training program. In addition, a sample newsletter article announcing the Plant
Sweep is provided.
'3
                                                  19

                          TRAINING PLAN
                      FOR CHEMICAL INVENTORY

                          SAMPLE OUTLINE


    1. PURPOSWGOALS OF PLANT SWEEP

    2. WHAT IS A "CHEMICAL"?

    3. INVENTORY ROLES AND RESPONSIBILITIES

    4. REVIEW OF INVENTORY PROCEDURES

        DEALING WITH UNKNOWN CHEMICALS
        RECORDING FINDINGS
        CHEMICAL MOVEMENT, STAGING AND DISPOSAL
    5. HEALTH 8 SAFETY CONSIDERATIONS
        REQUIRED PERSONAL PROTECTIVE EQUIPMENT
        FIRE SAFETY
        SPILL RESPONSE
        SEGREGATION OF INCOMPATIBLES
        SECONDARY CONTAlNMENT

        LABELLING OF CONTAINERS
        SELECTING PROPER CONTAINERS/REPACKAGING
    6. SPECIAL CONSIDERATIONS

        CONFINED SPACES
        RESPIRATOR USE
        HANDLING OF GAS CYLINDERS AND DRUMS
    7. READING LABELS AND MSDS




3
3
                                                          20

                            HEALTH 81 SAFETY PLAN
     3                     FOR CHEMICAL INVENTORY
                                SAMPLE OUTLINE


         1. PURPOSE OF PLAN


         2. CHEMICAL HAZARDS (FOR EXAMPLE)

                   FLAMMABLES
                   CORROSIVES
                   OXIDIZERS
                   TOXINS/CARCINOGENS
                   IRRITANTS
                   SENSITIZERS


!,   J
     -   3. CHEMICAL LABELLING/MSDS CONSIDERATIONS


         4. USE OF PERSONAL PROTECTIVE EQUIPMENT


         5. HANDLING OF UNKNOWN AND HIGHLY HAZARDOUS
         CHEMICALS


         6. STAGING AREA CONSIDERATIONS


         7. ADDITIONAL CONCERNS (CONFINED SPACES, ETC.)


         8. SPILL CLEAN-UP PROCEDURES


         9. EMERGENCY RESPONSE PLAN AND COMMUNICATION

             Emergency Coordinator
             TelephoneBeeper numbers
:3
                                                                                         21



     SAMPLE NEWSLETTER ARTICLE ON PLANT SWEEP
THEMICAL        INVENTOR^       OF PLANT SLATED FOR (DATE)"

As part of Chemical Awareness Week (dates), a physical inventory of all
chemicals at the plant will take place on (date). This Inventory is a critical part of
the plant's on-going effort to improve chemical management.
The Inventory will be a complete "wall to wall" search for all chemicals. A
"chemical" is any liquid, solid (including powders), or confined gas that has the
potential to cause a health hazard or that may release toxics to the environment
There may be many materials that we work with (such as oils and paints) that
we don't usually think of as chemicals, but these will all be covered by the
Inventory.

The EHS Committee is preparing a detailed plan for conducting the Inventory,
but we need everyone's help for it to be successful. Teams will be formed to
search through each area of the shop and record their findings. In addition to
collecting the information needed to improve our chemical management
process, the Inventory teams will be looking for unlabeled containers, improper
containers, and chemicals that are no longer needed in the plant. These
obsolete chemicals will be removed for disposal.
How can you help? First, look through your work area for chemicals. Are the
containers labeled? (if not, and you know what the material is, put an approved
label on it). Are there chemicals that we don't need or no longer use in the work
area? If so,these containers can be removed now by (whatever proper
procedure is) or you can tell the Inventory Team when they come through.
Better chemical management means a better workplace for all of us. Your help
and preparation can make the difference.
3
                                  22



          APPENDIX


  Plant Sweep Inventory Form

Chemical Removal Inventory Form


    Chemical Removal Label
‘3
              CHEMICAL INVENTORY REMOVAL FORM                               Page   - of __
    Container ID Number                               Chemical or Trade Name (if known)
    Euilding/Column No.                                                                     -
    MachinelArea-                                     Manufacturer Nendor (if known)
    Contact                                           Container Type/Size

    If chemical name unknown, provide characteristics (color, odor, consistency)



    Reason for Removal (circle)
           A. ObsoleteMo Longer In Use                 E. Unknown Chemical

             C. Stray ChemicaVNot Used in Area         D. Excess Quantity

             E. Other (describe)
    Waste Stream Classification (to be completed by EHS Speaalist)
     .***
       **
    **....            ...................................................................

    Container ID Number                               Chemical or Trade Name (if known)
    Euilding/Column No.
    MachinelArea                                      Manufacturer Nendor (if known)
    Contact                                           Container TypelSize

    If chemical name unknown, provide characteristics (color. odor, consistency)



4   Reason for Removal (circle)
           A. ObsoleteMo Longer In Use                 E. Unknown Chemical

             C. Stray ChemicalMot Used in Area        D. Excess Quantity

             E. Other (describe)
    Waste Stream Classification (to be completed by EHS Specialist)
     .*
    **.       ....**t........"*"****~"*~***~""**~~
             tt..."*ltt...*.."~**************".~**

    Container ID Number                               Chemical or Trade Name (if known)
    EuildinglColumn No.
    MachinelArea                                      Manufacturer Nendor (if known)
    Contact                                           Container TypelSize

    If chemical name unknown, provide characteristics (color. odor, consistency)



    Reason for Removal (circle)
           A. ObsoleteMo Longer In Use                 B. Unknown Chemical

             C. Stray ChemicaVNot Used in Area         D. Excess Quantity

             E. Other (describe)

    Waste Stream Classification (to be completed by EHS Specialist)
3




3
I
7   I
                PLANT SWEEP

         CHEMICAL REMOVAL LABEL
                                                           PLANT SWEEP

                                                   CHEMICAL REMOVAL LABEL


    1. CONTAINER IDENTIFICATION NUMBER:        1 CONTAINER IDENTIFICATION NUMBER:
                                                .



    2. WHERE FOUND:                            2. WHERE FOUND:
       (BUILDINGIARWCOLUMN NUMBER)                (BUILDINGIARWCOLUMN NUMBER)




    3 IF UNLABELED, DESCRIPTION OF CONTENTS:
    .                                          3. IF UNLABELED, DESCRIPTION OF CONTENTS:
     (CHEMICAL ID OR TRADE NAME)                 (CHEMICAL ID OR TRADE NAME)




    INITIALS                  DATE:            INITIALS:                 DATE:


    1
               PLANT SWEEP                                  PLANT SWEEP
        CHEMICAL REMOVAL LABEL                       CHEMICAL REMOVAL LABEL

    1 CONTAINER IDENTIFICATION NUMBER:
     .                                         1 CONTAINER IDENTIFICATION NUMBER:
                                                .


I

I
 2. WHERE FOUND:                               2. WHERE FOUND:
    (BUILDINWARWCOLUMN NUMBER)        --          (BUILDINGIARWCOLUMN NUMBER)




I
I3 IF UNLABELED, DESCRIPTION OF CONTENTS:
  .                                            3. IF UNLABELED, DESCRIPTION OF CONTENTS:
  (CHEMICAL ID OR TRADE NAME)                    (CHEMICAL ID OR TRADE NAME)


I
I
r'
 INITIALS                    DATE:             INITIALS:                 DATE:
3
                    Conducting A Physical Inventory
                 And Creating An Approved Chemical List
   Execution Steps
        Champion and owners must establish inventory procedures and review them with
        the participants:
   1.       Define a chemical for participants (See Exhibit C2 for an example)
  2.        Explain to participants that that they must "sweep" through the plant (look in
            basements, corners, file cabinets, tool boxes, outside grounds etc...)
  3.        Show participants how to properly label any unlabeled secondary containers
  4.        Indicate guidelines for identifying improper container usage (Le.flammable
            items stored in coffee can instead of a flammable container)
  5.        Explain that any unknown/obsolete chemicals must be brought to a
            predetermined location for disposal
  6.         Establish how participants will train production employees on proper usage,
            'handling, labeling and disposal of chemicals


8. Steps In Creating An Approved Chemical List
  The EHS manager must develop an Approved Chemical List using the inventory data:
  1.        Review the list of purchased chemicals with the list of chemicals identified
            during the physical inventory, to assure that the two lists agree. If not,
            reconcile the list. Or, summarize the lists generated to develop a complete list
            of chemicals found in the plant
  2.        Review process intermediates to determine if MSDS is required

  3.        Reconcile the results of the above comparison against the current MSDS file

  4.        Obtain all missing MSDSs to update chemical records

  5.        Determine whether material should be "approved"
             Review chemicals against all regulations (EPCRA, TSCA, SARA ...)
             Review chemicals against a business restricted chemical list (if available)

  6.        Develop the Approved Chemical List

  7.        Provide copies of this list to all procurement and receiving personnel

  8.        Review and update Approved Chemical List as required.




                                             2
3
  L
        I   PLANT
                SWEEP     FORM
                    INVENTORY
                                     I
Name:         Date:          Area:
'3
   c     Li
              PLANT         FORM
                      INVENTORY
                  SWEEP




Name          Cateaow Code             Container Code
Alea
Date          1 = Oils I Lubricants    A = Bottle or Can (c5 gal )
Notes:        2 =Coatings              B = Safety Can ( 5 gal)
              3 =Adhesives             C=
              4 = Solvents I Cleanen   D =Cylinder
              5=                       E =Tank
              6 = Othler               F = Other
3
I   I   I   I   I
3
                   p                                                    L    p
3       GE Motom (Ft. Wayne) EHS Staff Will Review This Checklist With Each Site

     GeneraI

     -            Is the site's Contingency PlardEmergency Response Plan current?
     -            Has the plant sweep been communicated to site personnel?
     Sweep Teams

     -            Have teams been formed and plant areas assigned?

     -            Does each team include personnel from within and outside the
                  assigned area?

     -            Have Team Leaders been designated?

     -            Have all team members completed HazCom training?

     -            Have all team members received training on plant sweep
                  procedures?
.I   Sweep Team Supplies: Are the following supplies available for each team?
     -            Safety Glasses?
     -            Gloves?

     -            Inventory Forms? (Ft Wayne wi//provide)

     -            Removal Labels? Logs? (Ft. Wayne will provide)
     -            Clipboards?

     -            Large Ziplock baggies? (for holding and labeling small items for
                  removal)

     -            Paper towels? (or other means to clean the surface of containers
                  for labeling)

     -            Secondary containers? (e.g, safety cans)

     -            Carts? (for moving small containers to the staging area)

     -            Radios?
3
                                        page 4-3
-I   Material HandlerWTruckers
                  Are all material handlers certifiednicensed in forklift safety?
     .__.


     -            Have all material handlers completed HazCom training?

     Staging Area Personnel

     -            Does the site have one or more individuals with HAZWOPER
                  training (40hours) to manage the staging area?

     -            If the site does not have HAZWOPER-trainedpersonnel, can the
                  site obtain the services of such an individual for the day of the
                  plant sweep?

     Staging Area: Is the designated area:
     -            Secure from public access?
     -            Isolated from plant personnel?

     -            Enclosed and provided with secondary containment?
3,   -            Adequate in size for the amount of material that will be collected?

     -            Equipped with a telephone or other means of communication?
     -            Equippedwith firefighting equipment

     -            Equipped with spill response equipment and PPE?

     -            Set up to allow segregationof incompatible materials?

     Waste Management

     -            Does the site have lab-packing c a p a b l i

     -            If the site does not have labpacking capability, can the site obtain
                  such senrices?

     -            Is the site preparedto properly classify and dispose of all wastes
                  generated during the pian! sweep?




                                          page 4-4
.-,




3

      Appendix D
ri

 i


3
                                     Appendix D

                                 PLANT SWEEP
                CHEMICAL MANAGEMENT PROCESS TRAINING
                         PRF-WORK C H E W J S I


     PCTIVlTY                                     BY APPROXIMATELY;
     Meet with Plant Manager, discuss             Four weeks prior
     objectives and costs
     Identify champion for Plant Sweep            Four weeks prior
     Define objectives of Plant Sweep             Four weeks prior
     Initiate communication program               Four weeks prior
     Get plant EHS Committee involved             Four weeks prior
     in planning process
1)
     Collect and review existing data             Three weeks prior
     on chemical usage
     Prepare "short list" of chemicals            Three weeks prior
     Prepare MSDS index (if not already           Three weeks prior
     in existence)
     Line up disposal contractors                 Three weeks prior
                                 .
     Prepare preprinted labels for                Three weeks prior
     'short list' chemicals
     Order containers, T-shirts, other supplles   Three weeks prior

     Prepare Health 6 Safety plan                 Two weeks prior

     Delineate shop areas for inventoty and       Two weeks prior
     assign responsibilities
     Select Inventory Teams and Team Leaders      Two weeks prior

'9   Define information collection needs          Two weeks prior
i


3
t

    3   Develop procedure for handling                   Two weeks prior
        'unknown" chemicals
        Meet with Plant Manager, MSO. supervisors        Two weeks prior
        to discuss specific plans for inventory
        Discuss inventory plans with Human               Two weeks prior
        Resources manager and Union reps.
        Select staging area(s) for collected chemicals   Two weeks prior

        Meet with Team Leaders to review procedures      One week prior

        Designate staging area personnel                 One week prior

        Designate Inventory Coordinator                  One week prior

        Plan recognition for Team Members and            One week prior
        other employees
        Train Inventory Teams                            One week prior




        Note: Logistical arrangements for Chemical Sweep are discussed
        in detail in "Conducting a Plant Chemical Sweep- A Guidebook for
        GE Motors"
 !

 '4

'3
    Appendix F



         RELEASES
     PRESS
SAMPLE
3
                   Sample Press Release for Site
                 EHS / Chemical Management Training
                        ' and Plant Sweep



  [This press release povides information needed to communicate the basics of
 the Chemical Management initiative t the plant. You should feel free to tailor it
                                       o
                o
               t meet the specific ConaFbiOns or needs of your p l a w



                        CHEMICAL MANAGEMENT WEEK



Coming Soon       ...
An important part of this site's commitment to protecting your health and safety
and the environment is proper management of chemicals from the time they
come into the plant until they are disposed of. GE Motors is kicking off a major
program at each of our plants to help us improve the way we manage chemicals.
Many of us use chemicals every day and may not even know it. Of course,
chemicals include solvents and [use site spedfic examples peop'e would
recognize, such as varnish or paints]. But what about machine oils? And [use
site example of substances people might not think of as chemicals, such as
cleaning agents, fuels, gas cylinders] ? Yes, these are "chemicals" too, and must
be properly managed.
To make sure that we're meeting our goal of 100% Compliance with all the laws
governing chemical use, we all need to get involved. If any of us makes a wrong
decision about handling or getting rid of a chemical, we can put the plant out of
compliance. And, more importantly, we may unknowingly put ourselves or our
friends at risk.


Training
Over the next couple of months, you'll see some more activity around here a wes
put new chemical management systems in place. The first event will be a 2-day
training program for the plant s a f and representatives of our area teams [or use
                                tf
the approPriate tennindogy for your facil&]. The purpose of the training will be
to enhance our awareness of the many environmental, health and safety
requirements the plant must comply with. Part of the training will be a WorkOut
to identify the roles each of us must play to meet those requirements. A special
segment will concentrate on a GE-wide best practice for a Systematic way to
select, manage and dispose of chemicals.

                                                                           more ...
P


3
    SAMPLE PRESS RELEASE       - PAGE 2

    Plant Sweep
    One event that we'll all be involved with will be a l d a y "wall-to-wall" inspection of
    the plant, when we will all be asked to help inventory the chemicals that are
    already in the plant. Each area will identify and label all the chemicals in the
    area, and help prepare obsolete and unneeded chemicals for disposal. There
    will be a team leader for each area to make sure that the sweep is complete,
    coordinated, and that all containers are properly marked and accounted for.
    More details on this plant sweep will be provided as the date gets closer. If you
    have any ideas on this project, or would like to get involved, please contact /site
    EHS Specialist or other approPrate contact].


    Next Steps
    Once the Plant Sweep has established a baseline of chemicals in the plant, we'll
    be able to put some of the systems in place to make sure we stay in compliance
    with all the legal requirements. This means we will need to make sure we control
                                                                                e
    which chemicals come into the plant, conduct the appropriate training, and s t up
    systems for properly disposing of chemicals. As these systems are implemented,
    you'll hear more about how you can get invoked.


    WATCH THIS SPACE FOR MORE NEWS!




                                             end




3
c


3
           SAMPLE NEWSLETTER ARTICLE ON PLANT SWEEP




"CHEMICAL INVENTORY OF PLANT SLATED FOR (DATE)"

As part of Chemical Awareness Week (dates), a physical inventory of all chemicals at
the plant will take place on (date). This Inventory is a criiical part of the plant's on-going
effort to improve chemical management.
The Inventory will be a complete "wall to wall" search for all chemicals. A "chemical" is
any liquid, solid (including powders), or confined gas that has the potential to cause a
health hazard or that may release toxics to the environment. There may be many
materials that we work with (such as oils and paints) that we don't usually think of as
chemicals, but these will all be covered by the Inventory.
The EHS Committee is preparing a detailed plan for conducting the Inventory, but we
need everyone's help for it to be Successtul. Teams will be formed to search through
each area of the shop and record their findings. In addition to collecting the information
needed to improve our chemical management process, the Inventory teams will be
looking for unlabeled containers, improper containers, and chemicals that are no longer
needed in the plant. These obsolete chemicals will be removed for disposal.
How can you help? First, look through your work area for chemicals. Are the containers
labeled? (if not, and you know what the material is, put an approved label on it). Are
there chemicals that we don't need or no longer use in the work area? If so,these
containers can be removed now by (whatever proper procedure is) or you can tell the
Inventory Team when they come through.
Better chemical management means a better workplace for all of us. Your help and
preparation can make the difference.
i




                          Sample Press Release Following CAT
                                 Training and Sweep
                      <




                            CHEMICAL AWARENESS TEAM
                                 HITS HOME RUN!

         As you may.have noticed last week, about thirty of our employees dedicated
         three days of their time to help us understand and improve the ways that we
         handle chemicals around the plant. After some awareness training on
         Wednesday, the group broke up into five teams on Thursday to inventory all the
         chemicals in the plant, and remove any obsolete or unknown chemicals. On
         Friday, the group reviewed the plant's existing chemical management practices
         and then pafticipated in a Workout aimed a! improving chemical management
         at Tell City.
         Don McCracken and Cheryl Capps kicked off the first day of Chemical
         Awareness Training by stressing the importance of EHS in Tell Ci. Don
         reviewed the plant's EHS accomplishments, including significant reductions in
         wastes. He encouraged the group to be candid and to look for ways to improve
         Tell City's EHS performance. Cheryl Capps added: "If we don't perform well on
         EHS.we won't be in business in the future.. Cheryl also reminded the group of
         Motors' commitment to EHS excellence.
         Thursday's chemical "sweep" was very successful in identifying the chemicals
         in the plant and how they are used. Among the obsolete chemicals found and
         removed from the plant:
     -
               [ provide examples of the "odd, strange, and curious" found
                 during the sweep, along with the total # of containers, total
                 poundslgallons of material, or other statistics]
         In the W O W on Friday, the group developed solutions to some of Tell City's
         chemical management challenges. Some of the key recommendations include:
               [add key findingdsolutions coming out of WorkOut,
                            s
                     such a : special forms for ordering chemicals, policies on
                     sample chemicals, floor plan of chemical storage areas,
                     CAT coordinators for recycling]

         The results of these three days? We made an immediate improvement by
         removing some old and potentially dangerous materials from the shop. We will
'3       also be able to update our approved chemicals list and obtain MSDSs for some
         materials. In addition, we w/ll be able to implement a better system for labeling
         chemical containers in the shop and maintaining compliance with other
         requirements.
Sample Newsletter                                                         -2-




At the end of the Workout, Cheryl noted that chemical management is a very
important issue to Tell Ci. She assured the members of the Chemical
Awareness Team that they would continue to get the support they need to work
on the improvements. The team plans to keep on working together, so if you
are interested in participating with the team, please contact Gene Hook or
Renee Graves.
As one participant summarized at the end of the three-day activii:
       I realize the impact I could have on the environment now. I handle
      a lot of different chemicals on my job, some very hazardous and
      some not. Isee how it can affect all of us. Proper disposal and
      use is very important. I care and hope to continue to pass the
      information [that I]learned on to others.
Continuing work on the solutions identified by the group will help us to ensure
that we are in compliance, managing chemicals in a cost effective way, and
minimizing chemical hazards in the workplace. There will be many
opportunities for all of us to take part in the improvements resulting from the
Chemical Awareness Team's work.
Thanks to all who participated.
0




0

								
To top