Ehs Management 4.4.6. - PDF by zkp76225

VIEWS: 117 PAGES: 16

More Info
									                             LAPORTE
                   ENVIRONMENTAL, HEALTH & SAFETY
                              POLICY
                                                                                                 Originator: K. Gutyan
 PROPRIETARY INFORMATION - INFORMATION CONTAINED HEREIN IS THE PROPERTY OF
 THE HOWMET CORPORATION. REPRODUCTION DISCLOSURE OR USE THEREOF IS
 PERMISSIBLE ONLY AS PROVIDED BY CONTRACT OR AS EXPRESSLY AUTHORIZED IN Approved                             by: S. Sanders
 WRITING BY HOWMET CASTINGS.
 Date of Issuance:     3/10/03      Revision No.     0                  Revision Date:
 Policy No: EHS - 401                                                                                            Page 1 of 16
 SUBJECT:                     CONTRACTOR ENVIRONMENTAL, HEALTH & SAFETY PROGRAM

1.0       Purpose

      1.1. Howmet Castings, LaPorte IN (Howmet LaPorte) utilizes Contractors, Subcontractors and Contracted
           Services, including Engineering, Procurement and Construction Management firms (EPCM's) for the
           construction, renovation and maintenance of facilities and other required on-site services. All contractors
           and their employees are expected to understand, promote and assist in the implementation of Howmet
           LaPorte's Environmental, Health and Safety (EHS) Values, Policies and Principles, and to comply with all
           applicable EHS rules and regulations.

2.0       Scope

      2.1. This document describes the requirements of Howmet personnel, Contractors, Subcontractors and
           Contracted Services to ensure the appropriate EHS Values, Policies and Principles are maintained
           during all phases of work or other contracted services as per the ALCOA mandatory standard 33.051
           “Contractor, Subcontractor and Contracted Services Environment, Health & Safety Process as well as
           the requirements in 33.055.1 titled “Contracted Services Safety Pre-qualification”.

3.0       Definitions

      3.1. Construction - an activity performed by Contractors that is generally the construction of new facilities or
           the maintenance, renovation, modification or relocation of existing facilities.

      3.2. Contractor - describes entities or employees of entities that perform work governed by a contractual
           arrangement between Howmet and the entity and who are not directly controlled or supervised by
           Howmet employees. Contractor’s does not include Contracted Services employees.

      3.3. Contractor Responsible Person(s) – individual who has been appointed by the Contractor, Subcontractor
           or Contracted Service and who possesses the detailed knowledge to fulfill the Contractor, Subcontractor
           or Contracted Services EHS obligations under the contract which applies to the scope of work. The
           Contractor Responsible Person(s) could be appointed from the Contractor, Subcontractor or Contracted
           Service management group, superintendents, foremen, working crews or from a third party.

      3.4. Contracted Services - describes entities or employees of entities that generally perform on site support
           activities such as manufacturing (temporary employees) millwrights, electricians, plumbers, janitors,
           engineers, or other professional or non- professional services directly controlled or supervised by
           Howmet personnel.

      3.5. Hazard Assessment - the identification of all existing or potential risks, hazards and environmental
           pollution control issues associated with the location and/or the work, which may need to be abated or
           controlled through the implementation of the Job Specific EHS Plan to ensure the safe completion of the
           scope of work.




      NOTE: Controlled EHSMS Documents are maintained electronically on the “EHS” Drive. Printed versions of EHSMS Documents are
                           UNCONTROLLED. Prior to relying on a printed document, verify that it is current.
                                             This document was printed on 03/21/03
                                                                                                                 Page 2 of 16
 SUBJECT:                      CONTRACTOR ENVIRONMENTAL, HEALTH & SAFETY PROGRAM


      3.6. Howmet Responsible Person(s) - individual who has a working knowledge of those Howmet and
           regulatory standards, which are normally applicable to the type of contracted work, has successfully
           completed the Contractor Safety Process Training Course and has working knowledge of the contract,
           which applies to the work. Another name for the Howmet Responsible Person could be the Single Point
           of Accountability (SPA). A Plant Manager, Procurement Manager, EHS Manager, Engineer or
           Maintenance personnel could all be a Howmet Responsible Person.

      3.7. Howmet Property - means any location or facility, or portion thereof, which is controlled by Howmet and
           on which Howmet operates.

      3.8. Incident – Any event resulting in an injury, illness, major injury-free event or environmental release.

      3.9. Job Specific EHS Plan – a plan that details the abatement or control procedures or steps for the hazards
           identified in the Hazard Assessment.

      3.10. Pre-Job Site Visits - meetings with the potential Contractors, Subcontractors or Contracted Services to
           discuss the Scope of Work, Site Conditions, and other aspects of the project.

      3.11. Project Environment, Health and Safety Review (PEHSR) – is a process directed at integrating EHS into
            project management, engineering and research & development. Refer To EHS – 402, Project
            Environmental, Safety and Health Review Written Policy.

      3.12. Scope of Work - is a documented, legal description of the project. The scope of work should be concise
           with adequate information to explain the sequential steps of the project in enough detail to ensure that
           the contractor understands the work. The Scope of Work becomes part of the contract specifications.

      3.13. Site Conditions - are the specific rules, regulations, procedures, and administrative requirements for the
           location. This document must be detailed and specific about what is required to meet EHS expectations.
           Site Conditions are to be provided to the Contractor as a legal attachment to the Purchase Order.
           Contractor employees should be expected to know and understand all aspects of the Site Conditions
           (See related Attachments).

      3.14. Subcontractor - describes entities or employees of entities that perform activities or services governed
           by a contractual arrangement between a Contractor and the entity, who performs work for the Contractor
           and who is not directly controlled or supervised by Howmet employees. Subcontractors must comply with
           the same requirements as Contractors.

4.0       Responsibilities

      4.1. Howmet Management Supervision

          4.1.1.   Ensure compliance with this policy and their location-specific Site Conditions.

          4.1.2.   Identify resources to comply with this policy.

          4.1.3.   Designate the Howmet Responsible Person(s) or SPA’s as accountable for Contractors
                   compliance to location-specific EHS Site Conditions.

          4.1.4.   Designate Procurement as accountable for purchasing control.




      NOTE: Controlled EHSMS Documents are maintained electronically on the “EHS” Drive. Printed versions of EHSMS Documents are
                           UNCONTROLLED. Prior to relying on a printed document, verify that it is current.
                                             This document was printed on 03/21/03
                                                                                                            Page 3 of 16
SUBJECT:                  CONTRACTOR ENVIRONMENTAL, HEALTH & SAFETY PROGRAM

 4.2. Procurement/Purchasing

     4.2.1.   Select Contractors, Subcontractors and Contracted Services who can demonstrate the capability
              to meet EHS criteria in accordance with the Pre-Qualification Process per document 33.055-titled
              "Foreword to Contracted Services Pre-qualification Questionnaire" and document 33.055.1 titled
              "Contracted Services Safety Pre-qualification Questionnaire".

     4.2.2.   Communicate the Scope of Work, Site Conditions and other expectations to the Contractor,
              Subcontractor and Contracted Services.

     4.2.3.   Ensure the Scope of Work and Site Conditions are included in Purchase Orders.

 4.3. Project Leader

     4.3.1.   Initiates and coordinates the project

     4.3.2.   Prepares all project approval documentation.

     4.3.3. Coordinates the detailed engineering and design including cost estimates.

     4.3.4.   Coordinate preparation of the Scope of Work.

     4.3.5.   Coordinate the project including schedules and communications.

     4.3.6.   Initiate the Project Environmental Health and Safety Review (PEHSR) / Job Safety Analysis
              (JSA) for all project / contracted services work.

     4.3.7.   Maintain documents demonstrating compliance with Section 5.0, Pre-Contract Procedure.

     4.3.8.   Enforce Location’s EH&S Requirements

 4.4. Contractor, Subcontractor And Contracted Service Management

     4.4.1.   Comply with all applicable laws, regulations and codes.

     4.4.2.   Comply with Howmet/Alcoa EHS Values, Policies and Principles.

     4.4.3.   Comply with Site Conditions and other expectations as defined in the Scope of Work and
              purchase order.

     4.4.4.   Develop and implement a Company Contractor Safety Program.

     4.4.5.   Develop and implement a Howmet Contractor EHS Plan (or JSA as required) for each project.

     4.4.6.   Ensure employees have the appropriate skills for the job.

     4.4.7.   Provide employees with the appropriate EHS training.


 NOTE: Controlled EHSMS Documents are maintained electronically on the “EHS” Drive. Printed versions of EHSMS Documents are
                      UNCONTROLLED. Prior to relying on a printed document, verify that it is current.
                                        This document was printed on 03/21/03
                                                                                                            Page 4 of 16
SUBJECT:                  CONTRACTOR ENVIRONMENTAL, HEALTH & SAFETY PROGRAM



     4.4.8.   Provide the appropriate Personal Protective Equipment (PPE), tools and equipment.

     4.4.9.   Inspect workplace and correct deficiencies.

     4.4.10. Maintain a safe and healthy work environment.

 4.5. Howmet Responsible Person and Project SPA

     4.5.1.   Ensure the mandatory requirements of this program and the JSA are met.

     4.5.2.   Assist Procurement in identifying potentially qualified Contractors, Subcontractors and Contracted
              Services.

     4.5.3.   Assist Procurement in completing and analyzing the Contractor, Subcontractor or Contracted
              Services Pre-qualification Questionnaire per ALCOA document 33.055 titled "Foreword to
              Contracted Services Pre- qualification Questionnaire" and document 33.055.1 titled "Contracted
              Services Safety Pre-qualification Questionnaire".

     4.5.4.   Assist Howmet Engineers/Contractors, Subcontractors or Contracted Services with the JSA
              review and EHS hazard assessments.

     4.5.5.   Review Company Contractor Safety Program.

     4.5.6.   Review Howmet Contractor EHS Plans with the Project Leader. Any changes in scope,
              conditions, hazards, etc., impacting the Contractor EHS Plan shall be communicated immediately
              to the Contractor, Subcontractor or Contracted Service and the Howmet Responsible Person(s).
              Work may need to stop until the Contractor EHS Plan has been appropriately reviewed and
              modified.

     4.5.7.   Ensure the necessary EHS orientation and training is provided to Contractor employees.

     4.5.8.   Complete routine EHS periodic monitoring of the Work Site and communicate results to
              Contractor, Subcontractor and Contracted Services management.

     4.5.9.   With Location Management, Project Leader, Contractor, Subcontractor or Contracted Services
              Management, enforce applicable rules and regulations.

     4.5.10. Attend Site Visits for major projects.

     4.5.11. Attend Pre-job Meetings for major projects.

 4.6. Contractor Responsible Person(s)

     4.6.1.   Ensure all EHS obligations under the contract that applies to the work are fulfilled.

     4.6.2.   Assist with EHS hazard risk assessments.


 NOTE: Controlled EHSMS Documents are maintained electronically on the “EHS” Drive. Printed versions of EHSMS Documents are
                      UNCONTROLLED. Prior to relying on a printed document, verify that it is current.
                                        This document was printed on 03/21/03
                                                                                                                 Page 5 of 16
 SUBJECT:                      CONTRACTOR ENVIRONMENTAL, HEALTH & SAFETY PROGRAM



          4.6.3.   Develop and implement a Company Contractor Safety Program.

          4.6.4.   Prepare Contractor EHS Plan or JSA for each project. Any changes observed in scope,
                   conditions, hazards, etc., impacting the Contractor EHS Job Plan shall be communicated
                   immediately to the Howmet Responsible Person(s). Work may need to stop until the Contractor
                   EHS Job Plan has been appropriately reviewed and modified.

          4.6.5.   Ensure the necessary EHS orientation and training is provided to employees. Complete routine
                   EHS periodic monitoring of the Work Site and communicate results to Howmet.

          4.6.6.   With Contractor, Subcontractor or Contracted Services Management, enforce applicable rules
                   and regulations.

          4.6.7.   Attend all Site Visits.

          4.6.8.   Attend all Pre-job Meetings.

5.0       Pre-Contract Procedure

      5.1. Contractor Pre-Qualification Questionnaire

          5.1.1.   Prior to entering into contractual agreement, the contractor shall be evaluated to determine if their
                   EHS program is acceptable.

          5.1.2.   The Contractor shall agree to complete in full, Alcoa Mandatory Standard document 33.055 and
                   33.055.1 titled Contracted Services Safety Pre-qualification Questionnaire, and return by a
                   specified time frame set by the location in order for their bid to be considered.

          5.1.3.   The Contractor shall be required to update and resubmit the Prequalification Questionnaire
                   annually.

          5.1.4.   The Pre-qualification questionnaire shall be reviewed and evaluated for acceptance by the
                   Howmet Responsible Person.

      5.2. Preliminary EHS Plan

          5.2.1.   The contractor shall submit a Preliminary EHS Plan or JSA for the Scope of Work to be
                   performed. At a minimum, the Preliminary EHS Plan or JSA shall include the following
                   information:

               5.2.1.1. Nature and description of the Scope of Work to be performed by the contractor. Contractor
                        shall include a list of the work process or short description of work to be performed by job
                        type (e.g. foundation or excavating, electrical installations, roof work, plumbing, duct work,
                        etc.)

               5.2.1.2. Information relative to the Contractor Responsible Person.

               5.2.1.3. Identification of any major potential hazard/risk (e.g. fall hazards, fire hazards, environmental
                        contamination and liabilities). Determine potential EHS permit requirements.

               5.2.1.4. Contractors’ general precautions to eliminate or mitigate the risks and liabilities.

      NOTE: Controlled EHSMS Documents are maintained electronically on the “EHS” Drive. Printed versions of EHSMS Documents are
                           UNCONTROLLED. Prior to relying on a printed document, verify that it is current.
                                             This document was printed on 03/21/03
                                                                                                                 Page 6 of 16
 SUBJECT:                      CONTRACTOR ENVIRONMENTAL, HEALTH & SAFETY PROGRAM

               5.2.1.5. Type of materials and equipment to be used on site.

               5.2.1.6. Safe Job Procedures (if available). These procedures may be used in preparation of the
                        Detailed EHS Plan.

               5.2.1.7. Anticipated quantity and description of waste to be generated.

          5.2.2.   Minor or repetitive jobs may be covered by a boilerplate Job Specific EHS Plan or JSA that may
                   reference the specific task or tasks performed.

      5.3. Preliminary Site Visit

          5.3.1.   Prior to submitting a bid, the Contractor shall visit the site along with the Howmet Project Leader
                   or their delegate, and review the EHS requirements, conditions, site conditions and scope of
                   work.

          5.3.2.   General and specific EHS expectations and risks at the site shall be explained or provided to the
                   Contractor. Each contractor/visitor shall receive the Visitor and Contractor EHS Guidelines.
                   (Refer to Appendix A).

          5.3.3.   The Contractor shall also be provided with the locations applicable EHS procedures and program
                   requirements (Refer to Section 9.0 for the location’s Site Conditions). Locations will not provide
                   contractor with their site specific written EHS programs until after the bid has been accepted.

          5.3.4.   The Contractor shall be provided with MSDS’s for the materials involved in the Scope of Work.

          5.3.5.   The Contractor shall also provide Howmet with MSDS’s for materials they expect to use on the
                   job with the bid package.

          5.3.6.   The above information shall be used by the Contractor in preparation of submitting a bid package
                   to Howmet.

6.0       Post-Contract Procedure

      6.1. Job Specific EHS Plan And Pre-Work EHS Meeting

          6.1.1.   Upon awarding the contract and prior to beginning the work, the Contractor shall prepare and
                   submit a Job Specific EHS Plan to the Howmet Responsible Person. Refer to Appendix B for the
                   Risk Assessment Form to be used in preparation of the Job Specific EHS Plan.

          6.1.2.   The Job Specific EHS Plan shall then be discussed at a Pre-Work EHS Meeting. Meeting
                   attendance shall be documented.

          6.1.3.   Depending on the Scope of Work, the following people should attend the Pre-Work EHS Meeting:

               6.1.3.1.   Howmet Project Leader
               6.1.3.2.   Contractor Responsible Person
               6.1.3.3.   Howmet Responsible Person
               6.1.3.4.   EHS Representative
               6.1.3.5.   Maintenance Manager/Supervisor
               6.1.3.6.   Facilities Manager/Coordinator
               6.1.3.7.   Other Technical Personnel.

          6.1.4.   The contents of the Job Specific EHS Plan or JSA shall be communicated to the Contractor and
                   Subcontractor employees.

      NOTE: Controlled EHSMS Documents are maintained electronically on the “EHS” Drive. Printed versions of EHSMS Documents are
                           UNCONTROLLED. Prior to relying on a printed document, verify that it is current.
                                             This document was printed on 03/21/03
                                                                                                                 Page 7 of 16
 SUBJECT:                      CONTRACTOR ENVIRONMENTAL, HEALTH & SAFETY PROGRAM

          6.1.5.   Contractor shall designate and provide a Job Site Responsible Person to be on site during the
                   duration of job. The responsible person will direct the job in accordance with the Job Specific
                   EHS Plan.

      6.2. Audits, Enforcement and Incident Reporting

          6.2.1.   The designated Howmet Responsible Person and Contractor Responsible Person or Job Site
                   Responsible Person shall perform documented periodic audits during the duration of the job to
                   ensure compliance with the Job Specific EHS plan.

               6.2.1.1. Incidents or observances of non-compliance shall be documented and corrective action(s)
                        taken shall be noted. A copy of which will be forwarded to the Howmet Responsible person or
                        designated SPA. This information will be incorporated into the yearly contractor evaluation
                        spreadsheet.

          6.2.2.   Throughout the duration of the job and as conditions dictate, the plan must be reviewed, updated,
                   and revised to reflect changes in the project scope, and/or operating conditions.

          6.2.3.   Any modifications made to the Detailed EHS Plan shall be communicated to all Contractor
                   employees, Howmet Responsible Person and to other stakeholders as affected by the change.

          6.2.4.   The Howmet Responsible Person shall verify that applicable training was provided for each
                   individual participating in the project by reviewing documentation and interviewing the contractor
                   employees. The documentation can be provided at the Pre-Work EHS Meeting.

          6.2.5.   During the auditing of the job, interviews shall be conducted with contractor employees to
                   determine their level of understanding with regards to applicable required programs (e.g. Critical
                   4 Programs, Mobile Equipment, Confined Space, Fall Protection and Lock Out Tag Out) and
                   environmental rules and regulations.

          6.2.6.   The Contractor, Subcontractor shall report, record and investigate all incidents in accordance with
                   the locations specific guidelines, located in the General Site Conditions.

7.0       Training Requirements

      7.1. Contractors

          7.1.1.   Contractor’s and Subcontractors are required to provide applicable and required regulatory
                   training to their employees.

          7.1.2.   Contractors are required to provide evidence that proves job specific training has been conducted
                   where required by governmental regulations. (Some disciplines include, but are not limited to:
                   Electrician, Asbestos, Mechanical / Sheet Metal Fabrication, Forklift / Mobile Equipment,
                   Scaffolding, Boom Lift, Hilti Gun, etc.)

          7.1.3.   Contractor employees involved with the job shall attend an EHS orientation course or meeting to
                   be conducted by the location. The Contractor Responsible person shall inform Contractor



      NOTE: Controlled EHSMS Documents are maintained electronically on the “EHS” Drive. Printed versions of EHSMS Documents are
                           UNCONTROLLED. Prior to relying on a printed document, verify that it is current.
                                             This document was printed on 03/21/03
                                                                                                                 Page 8 of 16
 SUBJECT:                      CONTRACTOR ENVIRONMENTAL, HEALTH & SAFETY PROGRAM

                   employees arriving after the course/meeting stated in section 7.1 of the location’s rules, polices,
                   and procedures.

          7.1.4.   At a minimum, the orientation course/meeting shall include the following:

               7.1.4.1. Critical 4 Requirements (Fall Protection, Confined Space, Lock-out/Tag-out, Mobile Equip.)
               7.1.4.2. Location’s General EHS Rules
               7.1.4.3. Mandatory Plant PPE requirements
               7.1.4.4. Emergency Preparedness, Response and Contingency Procedures
               7.1.4.5. General Environmental Rules and Regulations
               7.1.4.6. Fire Prevention Rules

      7.2. Howmet Employees

          7.2.1.   Howmet employees involved with coordinating, scheduling, researching, purchasing and contract
                   administration shall be trained in accordance with the contents of this program and the location
                   specific Site Conditions.

          7.2.2.   The Howmet Responsible Person shall conduct the training annually or as deemed necessary.

8.0       General Requirements

      8.1. Contractors shall be prohibited from using Howmet tools and equipment.

      8.2. Contractors shall limit mobile equipment to the extent of what is prescribed in the Job Specific EHS Plan.
           Under no circumstances can this be circumvented without first notifying and consulting with Purchasing
           and the Howmet Responsible Person. A Howmet Hold Harmless Agreement must be completed and
           approved by the location’s General Manager, or his designee prior to the loaning of equipment.

      8.3. Egregious violations of location Site Conditions or applicable regulatory requirements should result in the
           immediate cessation of work, removal from the location of the affected Contractor employee and review
           of possible expulsion of Contractor from the project.

9.0       Howmet LaPorte Specific Site-Conditions

      9.1. Purchasing shall send out Howmet LaPorte Site Conditions with each bid package and Purchase Order
           or Contract that is sent to a Contractor.

      9.2. The LaPorte Site Condition package shall include specific details relative to the following items:

          9.2.1.   Work Permits:

               9.2.1.1. Safety Permits-Hot work, Excavating, Trenching, Confined Space Entry, Electrical, Roof
                        Access

               9.2.1.2. Environmental Permits-Wastewater Discharge and Ground Water Diversion, Air Pollution,
                        Solid Waste, Storm water, Wetlands, etc.




      NOTE: Controlled EHSMS Documents are maintained electronically on the “EHS” Drive. Printed versions of EHSMS Documents are
                           UNCONTROLLED. Prior to relying on a printed document, verify that it is current.
                                             This document was printed on 03/21/03
                                                                                                              Page 9 of 16
 SUBJECT:                     CONTRACTOR ENVIRONMENTAL, HEALTH & SAFETY PROGRAM

       9.2.2.   Emergency Preparedness and Contingency Plan, including locations emergency telephone
                number and specific telephone numbers and contacts of internal and external emergency
                response personnel.

       9.2.3.   Emergency Medical Response and Incident Reporting Procedure.

       9.2.4.   Rules, policies and procedures relative to high risk programs including, but not limited to the
                following, which can be obtained through the EHS department:

                          •    Fall Control
                          •    Mobile Equipment
                          •    Lock-out / Tag-out / Verify
                          •    Confined Space Entry
                          •    Personal Protective Equipment
                          •    Electrical Safety
                          •    Fire Prevention and Hot Work
                          •    Respiratory Protection
                          •    Hazard Communication
                          •    Hearing Conservation
                          •    Industrial Hygiene and Health Hazard Controls
                          •    Ergonomics
                          •    Radiation Safety

       9.2.5.   Excavating and trenching procedures

       9.2.6.   Housekeeping expectations

       9.2.7.   Incident Investigation procedures

       9.2.8.   Location specific environmental rules, policies, procedures and regulations not limited to and
                including the following:

                          •    Solid Waste Management
                          •    Air And Water Pollution Control Technologies And Procedures
                          •    Water Discharge and/or Usage Permits and Procedures
                          •    Release, Pollution, Control, Countermeasure and Containment
                          •    Wetlands Permits and Mitigation
                          •    Memorandum of Agreements or Administrative Consent Orders
                          •    Contaminated Site Cleanup Technical Standards

       9.2.9.   Local traffic safety rules and procedures.

10.0   Interpretation

   10.1. Any questions concerning this policy shall be directed to the EHS Department.

11.0   Records Retention

   11.1. Pre-Qualification Packages And Spreadsheet

       11.1.1. Pre-qualification packages and spreadsheets will be retained for the minimum length of time set
               forth in Howmet Standard Policy Instruction S1604.00 entitled “Record Retention”.


   NOTE: Controlled EHSMS Documents are maintained electronically on the “EHS” Drive. Printed versions of EHSMS Documents are
                        UNCONTROLLED. Prior to relying on a printed document, verify that it is current.
                                          This document was printed on 03/21/03
                                                                                                              Page 10 of 16
 SUBJECT:                   CONTRACTOR ENVIRONMENTAL, HEALTH & SAFETY PROGRAM

   11.2. Certificates Of Liability

       11.2.1. Certificates of Liability will be retained for the minimum length of time set forth in Standard Policy
               Instruction S1604.00 entitled “Record Retention”

   11.3.        Tax Documentation

       11.3.1. All Tax Documentation will be retained for the minimum length of time set forth in Standard Policy
               Instruction S1604.00 entitled “Record Retention”.

12.0   Use of labor under the age of 18

       12.1 Howmet, it’s contractors, consultants, ECPM’s, and subcontractors will abide by Federal Statute,
            Title 29, Part 570 – Child labor regulations, orders and statements of Interpretation, Subpart C –
            Employment of Minors between 14 and 16 Years of age (Child Labor Reg.3, and Indiana Sec.
            20:8.1-4-1 et seq.), the Indiana Child Labor Act. Which states that No minors under the age of 18
            will be permitted to work in an “Operation of ore reduction works, smelters, hot rolling mills,
            furnaces, foundries, forging shops, or any other place in which the heating, melting or heat treatment
            of metals is carried on.”

13.0   Citizenship

       13.1.1. Due to the nature of Howmet’s business we are required to allow only citizens and resident aliens
             (Those with valid Green Cards), access to all areas of the facility.

       13.1.2. In order to affect this policy, the “Resident Alien Verification” Form 5.6.1 is sent to all Contractors
             and Contracted Services in the Bid Package.

       13.1.3. Completed copies of this form are kept with the pre-qualification packages filled out and supplied
             by the contractor.

       13.1.4. Any resident alien is required to supply a copy of their green card. This is filed with the Pre-
             qualification package filled out and supplied by the contractor.

       13.1.5. Any non-resident alien who is needed to work on site must adhere to the instructions set forth in
             the Activity Instruction “Plant Technology Controls for Visitors” (current version) or have in writing,
             prior approval to do so, by the site General Manager. There must also be a written plan on travel
             restrictions within the site.

       13.1.6. Prior to any foreign national, being allowed access to the site, procurement will screen the alien
             against the “Denied Party Listing”.

       13.1.7. The sites Alcoa Responsible Person will be given the name/names of the party or parties to be
             screened by the procurement department.

14.0   Revision History

REV. DATE          NATURE OF REVISION                                     NAME(S) OF DOCUMENT REVIEW
                                                                          PARTICIPANTS
3/10/03            Incorp. Revised General Site Conditions                Kristina M. Gutyan / Bob Bahus
3/10/03            Incorp. Revised Visitor Guidelines                     Kristina M. Gutyan / Bob Bahus
3/10/03            Added Section 12.0 Use of Minors                       Kristina M. Gutyan / Bob Bahus
3/10/03            Added Section 13.0 Citizenship                         Kristina M. Gutyan / Bob Bahus


   NOTE: Controlled EHSMS Documents are maintained electronically on the “EHS” Drive. Printed versions of EHSMS Documents are
                        UNCONTROLLED. Prior to relying on a printed document, verify that it is current.
                                          This document was printed on 03/21/03
                                                                                                                Page 11 of 16
 SUBJECT:                     CONTRACTOR ENVIRONMENTAL, HEALTH & SAFETY PROGRAM




APPENDIX A

CONTRACTOR EHS
                                                                                                                  HOWMET LAPORTE
GUIDELINES PAMPHLET                                                                                                  CASTINGS




                                                                                                      Contractor Environmental,
                                                                                                          Health and Safety
                                                                                                             Guidelines




NOTE: Controlled EHSMS Documents are maintained electronically on the “EHS” Drive. Printed versions of EHSMS Documents are UNCONTROLLED. Prior to relying on a printed document, verify that
                                                                                         it is current.
                                                                           This document was printed on 03/21/03
                                                                                                               Page 12 of 16
 SUBJECT:                    CONTRACTOR ENVIRONMENTAL, HEALTH & SAFETY PROGRAM

General                                                                                In addition, certain forms of hearing protection and protective
                                                                                       clothing may be required depending on the operation. Please
Howmet Castings values the health and safety of people                                 check with the Department Supervisor for these specific
and the protection of our environment. The requirements                                requirements prior to beginning work.
to comply with all current OSHA, EPA, National Electric
Code Standards and any applicable Federal, State or                                                                   Emergencies
Local regulations, and company environmental health and
safety rules while you are on the premises must be taken                               All fires, spills of hazardous materials, medical emergencies or
seriously. Violations of these rules will result in your                               other incidents requiring emergency intervention must be
removal from the premises and the banning of future                                    reported immediately to the security office by dialing 439 from
business with the company you represent.                                               any plant telephone.

For your reference, this pamphlet lists a summary of safety,                                                   Emergency Evacuation
health and environmental protection rules you will be required
to follow while visiting Howmet Castings LaPorte Site. You                             When the horns and/or strobes are signaled, the building is to
should be familiar with the contents of this pamphlet and with                         be immediately evacuated. All occupants shall leave the
more comprehensive rules and procedures as required.                                   building immediately by the nearest emergency exit and
Contact your facility representative for more information.                             proceed to the appropriate rally point. Visitors shall reference
                                                                                       the evacuation map located in the area you will be visiting.
                           Plant Security                                              Each area has an assigned emergency evacuation
                                                                                       representative. For easy identification, they don blue or white
All Visitors and Contractors will be required to report to the                         hard hats. You must remain at the rally point until the area
security office to obtain a badge and sign the registration log.                       emergency evacuation representative has given the all clear.
When leaving the facility, the badge is to be returned and all
personal property is subject to inspection.                                                               Prohibited Materials/Equipment

                 Personal Protective Equipment                                         The possession of alcoholic beverages, illegal/illicit drugs,
                                                                                       explosives, firearms, or weapons are prohibited on the
Howmet Castings requires Personal Protective Equipment                                 premises. Any visitor suspected of being under the influence
(PPE) in certain areas of the plant. Safety glasses with side                          of drugs or alcohol will not be permitted access. Cameras of
shields and metatarsal safety shoes are required throughout                            all types are prohibited on the premises. All vehicles entering
the site with the exception of cafeterias and offices areas.                           the premises are subject to search.

Hard hats are required for all Maintenance and Construction
type work at Howmet LaPorte Castings.


NOTE: Controlled EHSMS Documents are maintained electronically on the “EHS” Drive. Printed versions of EHSMS Documents are UNCONTROLLED. Prior to relying on a printed
                                                                    document, verify that it is current.
                                                                 This document was printed on 03/21/03
                                                                                                               Page 13 of 16
 SUBJECT:                    CONTRACTOR ENVIRONMENTAL, HEALTH & SAFETY PROGRAM

                         Tobacco Use                                                   Materials Used by the Contractor:

Tobacco use is prohibited inside any of the Howmet Castings                            1. When the work performed by the contractor / subcontractor
LaPorte Site buildings except in designated areas.                                        requires the use of chemicals, the following information
                                                                                          must be submitted to the EHS Department with copies of
                         Harassment                                                       the Material Safety Data Sheets prior to the start of the
                                                                                          work.
Howmet Castings does not tolerate harassment of any kind.
Violators of Howmet’s Workplace Harassment Policy will be                                  a. Project Description
removed from the premises and will not be allowed to return.                               b. Location of Work Performed
A copy of the Workplace Harassment Policy is available upon                                c. Howmet Contact Person
request from our Human Resources department.                                               d. Contractor Contact Person
                                                                                           e. Project Start Date
                  Hazard Communication                                                     f. Anticipated Completion Date
                                                                                           g. Personal     Protective  Equipment  Required   for
Materials Used by Howmet Castings:                                                            Contractor’s Employees
                                                                                           h. Personal Protective Equipment Required for Howmet
1. Material Safety Data Sheets                                                                Employees

Howmet Castings has Material Safety Data Sheets (MSDS) on                              2. Contractor employees must be trained in Hazard
file for each chemical used in the workplace. There is a MSDS                             Communication and have access to Material Safety Data
information center located in the Medical Services. These                                 Sheets for the products they will use as required by OSHA
MSDS sheets are available to any Howmet employee or                                       Standard 29 CFR 1910.1200.
Contractor’s employee. Contact the EHS Department to
obtain printed copies.                                                                                                Insurance

2. Labeling System                                                                     Contractors are required to supply an up-to-date certificate of
                                                                                       insurance with the proper coverage designed. This certificate
All incoming containers will maintain their original labeling. Any                     must be on file in the Purchasing Dept. prior to
label that is replaced will only be replaced by one that provides                      commencement of work.
the same warnings, hazards, and / or information.
                                                                                                             Pre-Job Safety Meetings
All secondary containers, tanks or vessels are labeled with the
contents and hazard warnings.                                                          Howmet management and contractors must meet prior to
                                                                                       working on site to insure all safety procedures and specific site
                                                                                       conditions are discussed.

NOTE: Controlled EHSMS Documents are maintained electronically on the “EHS” Drive. Printed versions of EHSMS Documents are UNCONTROLLED. Prior to relying on a printed
                                                                    document, verify that it is current.
                                                                 This document was printed on 03/21/03
                                                                                                               Page 14 of 16
 SUBJECT:                    CONTRACTOR ENVIRONMENTAL, HEALTH & SAFETY PROGRAM

Howmet Castings will ensure that:                                                           4) Contractor will report any accidents or near misses to
                                                                                               the Security office and Purchasing.
    1) Person responsible for coordinating the scope of work
       shall insure that copies of the Visitors Safety Pamphlet                                             Equipment Use & Condition
       are available to all visitors and contractor personnel.
                                                                                       Any equipment used by the contractor must be maintained in a
    2) Depending on the scope of work, provide the                                     safe manner. All safety devices must be in working order.
       contractor/visitor with a copy of the applicable Howmet
       Corporation written program (i.e. Lock-out / Tag-out,                           Contractors shall provide all necessary equipment (ladders,
       Confined Space Entry, Respiratory Protection, and                               forklifts, etc.) and are not allowed to use Howmet equipment.
       Waste Management).
                                                                                                                   Overhead Work
    3) Shall verify that all contractors were given general Site
       Conditions as part of their bid package.                                        If the scope of the work requires work overhead, the contractor
                                                                                       must provide adequate measures to prevent falling debris.
    4) Contracted workers are informed of the appropriate
       evacuation routes and rallying points.                                                                Barricades for Work Areas

    5) Howmet supervision shall be available to periodically                           Work areas are to be barricaded to prevent unauthorized /
       monitor contractors work activity to verify compliance                          unsafe access. This is particularly important for overhead
       with the applicable safety programs, policies,                                  work.
       procedures and precautions
                                                                                       Hot Work (Welding, Torch Cutting, Brazing, etc.)
Contractor will ensure that:
                                                                                       In any application where cutting or welding is required, the
    1) Contractor provides certification, verification and/or                          following rules apply:
       documentation of all applicable training needed to
       perform contracted activity.                                                    •    An approved Hot Work Permit must be obtained from the
                                                                                            Maintenance Supervisor.
    2) Contractor is responsible for clean up and removal of                           •    Castings and materials must be relocated and protected if
       generated excess materials, debris and work area is                                  necessary to prevent damage.
       restored to original condition.                                                 •    All combustible materials must be removed from the area.
                                                                                       •    Appropriate screens are required to protect passersby from
    3) Contractor Management or designee Safety Rep. shall                                  visual injury and sparks.
       periodically monitor work activity to verify compliance.                        •    A fire watch must be assigned to monitor the activity to
                                                                                            prevent a fire.
NOTE: Controlled EHSMS Documents are maintained electronically on the “EHS” Drive. Printed versions of EHSMS Documents are UNCONTROLLED. Prior to relying on a printed
                                                                    document, verify that it is current.
                                                                 This document was printed on 03/21/03
                                                                                                               Page 15 of 16
    SUBJECT:                 CONTRACTOR ENVIRONMENTAL, HEALTH & SAFETY PROGRAM

THE FOLLOWING CRITICAL 4 SAFETY PROTOCOLS                                                                     Lock-out/Tag-out/Verify
HAVE   DETAILED   POLICIES AND  PROCEDURES
AVAILABLE IN EH&S FOR REVIEW. THE FOLLOWING                                            Before anyone performs any servicing or maintenance where
COMMENTS ARE MEANT TO PROVIDE A GENERAL                                                unexpected start-up or release of energy could cause injury,
OVERVIEW.    EVERYONE MUST ADHERE TO THE                                               the equipment must be locked out, tagged out & verified
COMPLETE POLICIES AND PROCEDURES WHEN ON
SITE.

Mobile Equipment and Pedestrian Separation

Contractor employees and vehicles shall adhere to the vehicle
and pedestrian separation requirements as indicated by
barriers, signs, etc.

A pedestrian watch shall accompany all mobile equipment
while traveling the outside roadways.

Operation of Mobile Equipment requires trained operators.

                Fall Protection/Prevention

A Roof Access Permit is required in all instances.

Fall Prevention/Protection is required when 6 feet or higher off
the ground. No one is allowed on the roofs during inclement
weather, or at night.

                  Confined Space Entry

Permits are required to enter Confined Spaces. A confined
space is defined as any space that:

•    Is large enough for someone to enter
•    Has limited or restricted means for entry or exit &
•    Is not designated for continuous occupancy


NOTE: Controlled EHSMS Documents are maintained electronically on the “EHS” Drive. Printed versions of EHSMS Documents are UNCONTROLLED. Prior to relying on a printed
                                                                    document, verify that it is current.
                                                                 This document was printed on 03/21/03
                                                                                                              Page 16 of 16
SUBJECT:                    CONTRACTOR ENVIRONMENTAL, HEALTH & SAFETY PROGRAM




                                                                                                  Howmet Castings
                                                                                                  an Alcoa business


                                   RESIDENT ALIEN VERIFICATION

Company:

Location:

Project / P.O.#:



Are All Employees that will work on Howmet’s site U.S. Citizens?
                                                                                                  Yes                     No

If No, Please supply the information below and a copy of your employees Green Card.


                                                                              Citizenship
Name                                                Title                     Status              Denied Party List




*Note - Citizenship Status should be either
Resident Alien or Foreign National.




   NOTE: Controlled EHSMS Documents are maintained electronically on the “EHS” Drive. Printed versions of EHSMS Documents are
                        UNCONTROLLED. Prior to relying on a printed document, verify that it is current.
                                          This document was printed on 03/21/03

								
To top