1_PURPOSE

Precision Strip, Inc.Safety Policies and Procedures

Title: Hazard Communication Program SPP 5.0

Issue Date: 7/24/06 Revision: 1Page: 2 of 7

Controlled By: Doug StueveApproved: Joe WolfApproved: Brian Roby

PURPOSE

This written, Hazard Communication Program, has been prepared to inform all associates of the known potential hazardous chemicals and materials that they may come in contact with during their employment. This program is also designed to satisfy the requirements of the Federal OSHA Hazard Communication Standard.

The following items are included in the program, and can be found in the sections indicated.

SECTION.............. SUBJECT

I. Training which will: A. Explain how this program works and how to obtain and use available information. B. Explain the use of labels, tags, and markings found on hazardous materials containers. C. Demonstrate how to use and understand Safety Data Sheets. D. Explain what protective measures can, and are to be used. II. A summary of label requirements. III. Requirements for "On-Site" contractors. IV. Using Safety Data Sheets and a glossary of terms used on them; followed by copies of the latest available Safety Data Sheets. V. Index listing of Safety Data Sheets by both manufacturer and common name.

This Hazard Communication Program will be reviewed annually by the Safety Director, to assure continued compliance with Federal OSHA Hazard Communication Standards. All new associates will receive training on the Hazard Communication Program during orientation; other associates will receive retraining as required. All associates are expected to know and follow established safety and health guidelines when working with hazardous materials. Anyone having questions about this program should contact the Safety Director, who has overall responsibility for this program.

I. TRAINING

Required Training for Associates: Under the Hazard Communication Standard, all employers are required to establish a training and information program for associates who work with hazardous chemicals and materials. This training must be conducted when an associate is initially hired, assigned to a new area, or a new chemical is introduced into a work area. The responsibility for training will be the Plant Safety/HR Manager, or an individual designated by the Safety/HR Manager. At a minimum, the Hazard Communication Program shall be reviewed with all newly hired associates on their first day of work, and all other associates as deemed necessary.

Objectives of the Training Program: Plant Safety Managers or their designated representative will conduct training. The objectives of the training will be to:1. Inform associates of the potential risks of hazardous chemicals and materials in their work area.2. Inform associates about our written Hazard Communication Program, where it is located, and where they will find Safety Data Sheets in their work area.3. Explain the proper methods and required safety equipment for handling hazardous materials.4. Make associates aware of labeling requirements in accordance with the standard, and their involvement to assure that all containers are properly labeled.

Format for Training Sessions: The following training objectives will be achieved by using classroom instruction and audiovisual aids.1. Associates will be informed of the existence of the Federal OSHA Hazard Communication Standard, the general requirements of this standard, and the objectives of the Precision Strip, Inc., Hazard Communication Program.2. Associates will be provided an overview of the materials to be covered.3. The trainer will disclose the location and availability of:a. Copies of the Hazard Communication Program.b. Where to find copies of the chemical lists.c. Where to find copies of Safety Data Sheets.1. The trainer will explain what a Safety Data Sheet is, and how to read and use the information it provides. 2. The trainer will instruct associates on labeling requirements, how to read and understand labels, and actions required when a hazardous chemical is transferred from a labeled container, to an unlabeled container. 3. The trainer will inform associates of any operations that involve hazardous chemicals or materials in their work area, and instruct them in the use of safety equipment relevant to the chemicals found there.4. The trainer will conduct a question & answer session, and administer a test to ensure that associates understand the materials presented.

Performance of Non-routine Tasks: Employees shall be instructed on potential hazards associated with non-routine, or infrequent tasks, such as a one-time cleaning operation, before conducting the task.1. Training shall be conducted and documented, and explain special work procedures, precautions and potential PPE which must be followed to protect employees from foreseeable hazards.

Training New Associates: Plant Safety Managers, or a designated representative, shall have overall responsibility for training new associates on the Hazard Communication Program.

Introduction of New Chemicals to the Workplace: Before a new chemical is purchased and supplied to a facility, the Plant Safety Manager will review the SDS to assess the relative hazard. All chemicals with a hazard rating greater than two (2) must be reviewed by the Safety Director to determine the hazard to associates, and if additional training or safety equipment is required to properly handle the new chemical. If additional training and/or PPE are required, the Safety Director will work with the Plant Safety Manager to see that it is provided.

II. LABELING

Required Labeling on Containers of Hazardous Chemicals: The Federal OSHA Hazard Communication Standard requires that chemical manufacturers, importers, and distributors properly label, tag, or mark, all hazardous chemicals. Identification must include the chemical content, and the name and address of the manufacturer or other responsible party.The Department of Transportation (DOT) prohibits the removal of any hazardous materials labels or warnings, from any package or container used to transport hazardous materials. Associates are not permitted to remove any chemical labels or markings.

Review of Labeling Upon Receipt: In the workplace, each container must:1. Be labeled, tagged, or marked, with the identity of the hazardous chemicals contained within.2. Show hazard warnings appropriate for associate protection.

The hazard warning may be any type of message, word, symbol, or picture; that conveys the hazards of the chemical(s) in the container, and must be:1. In English.2. Legible.3. Prominently displayed.

Review and Update of Label Information: If updated labeling information is received, the Safety Director will immediately review the information and forward it to the the plant Safety Managers for action. Plant Safety Managers will review this information with the supervisor(s) whose area(s) work with that hazardous chemical. Associates that work in the area(s) where the chemical is used will be informed of the change, the updated information will be placed on file, and all containers of that chemical in the workplace, and an updated SDS will be filed.

Labeling of Portable Containers: Each container of hazardous chemicals in the workplace is labeled, tagged or marked with:1. Product identifier and words, pictures, symbols, or combination thereof, which provide at least general information regarding the hazards of the chemicals, and which, in conjunction with the other information immediately available to employees under the hazard communication program, will provide employees with the specific information regarding the physical and health hazards of the hazardous chemical.2. The employer is not required to label portable containers into which hazardous chemicals are transferred from labeled containers, and which are intended only for the immediate use of the employee who performs the transfer.

III. ON-SITE CONTRACTORS

All on-site contractors shall be notified of any hazard(s) that they may be expected to encounter in their assigned work area. The associate responsible for hiring the contractor will provide this notification. In the event that the associate is not sure what hazards exist, the Maintenance Supervisor or the plant Safety Manager shall be asked to discuss this with the on-site contractor.

If on-site contractors are required to work in an area where hazardous materials are present, the on-site contractor will be notified of the chemical(s) present, their related dangers, and the nearest location to obtain copies of safety data sheets. Also at that time, an offer will be made to meet with the contractors on-site employees to explain the hazards in the area.

Any associate that becomes aware of a contractor working in the immediate vicinity of hazardous materials should ensure that they have been informed of the hazard(s).

IV. USING MATERIAL SAFETY DATA SHEETS

Information on Safety Data SheetsThe Purchasing Manager will be responsible for obtaining a copy of all SDS's for each hazardous chemical or material purchased for use by Precision Strip. These sheets are prepared by the product manufacturer, and all information including the hazard rating is accepted as being correct. Precision Strip, Inc. does not make hazard determinations. The Plant Safety Manager will ensure that copies of all required SDSs are current and readily available to all associates. At a minimum, a SDS book will be maintained and available from the Plant Safety Manager, with one additional centrally located Right-to-Know station located in the production area of each facility. Each Plant Safety Manager will determine the necessary number of Right-to-Know stations, and all associates shall be given immediate access to safety data sheets on request. SDS's in the Workplace SDSs are a source of detailed information on hazards, and are required to:1. Have all information in English.2. Have specific chemical and common names of hazardous materials.3. Explain known acute and chronic health effects, along with related health information.4. Give safe exposure limits and if the chemical is thought to cause cancer.5. List necessary precautionary measures and give emergency first aid procedures. Updating SDS's If a new SDS, or new and significant health information on a chemical used in the workplace is received, the Plant Safety Manager shall take immediate action to replace all SDS's and notify the supervisor(s) and associates in the effected work area(s) of the update.

Reviewing an SDS: All associates have the right to review the Safety Data Sheet, of any hazardous chemical(s) with which they work or could come into contact, while at Precision Strip, Inc. If you need help reviewing a Safety Data Sheet, contact your supervisor or Plant Safety Manager for assistance. Copies of Safety Data Sheets are available for review from the Plant Safety Manager or at any Right-to-Know station. Glossary of Terms Used in the SDS The following terms have the meanings defined, and are used in the development and preparation of Safety Data Sheets. For additional information or definitions regarding a specific SDS, contact the Plant Safety Manager.

ACUTE: A short term period of action measured in seconds, minutes, hours, or days.

ACUTE EFFECTS OF OVEREXPOSURE: The adverse effects that normally are evident immediately, or shortly after, the exposure to a hazardous material, without implying a degree of severity.

ASPHYXIANT: A vapor or gas that can cause injury or death by reducing the amount of oxygen available for breathing.

CARCINOGEN: A chemical which has been demonstrated to cause cancer in humans, or to cause cancer in animals, and therefore, is considered capable of causing cancer in humans.

CHRONIC: A long time period of action in weeks, months, or years.

CHRONIC EFFECTS OF OVEREXPOSURE: The adverse effects that develop slowly over a long period of time, or upon repeated, prolonged exposure, to a hazardous material without implying a degree of severity.

COMBUSTIBLE LIQUID: A liquid having a flash point at or above 100 deg. Fahrenheit, but under 200 deg. Fahrenheit.COMPRESSED GAS: A gas or mixture of gases in a container, having an absolute pressure exceeding 40 pounds per square inch at 70 deg. Fahrenheit, or a mixture of gases in a container having an absolute pressure exceeding 104 pounds per square inch at 130 deg. Fahrenheit.

CORROSIVE MATERIAL: A chemical liquid or solid that causes visible destruction or irreversible alteration in human skin tissue at the site of contact, or a liquid that has a severe corrosion rate on steel.

EXPLOSIVE: A chemical that causes a sudden, almost instantaneous release of pressure, gas, and heat, when subjected to sudden shock, pressure, or high temperature.

EXPOSURE: An employee that is subjected to a hazardous chemical in the course of employment, through any route of entry (such as inhalation, ingestion, skin contact or absorption, ect.), and includes potential accidental or possible exposure.

FLAMMABLE MATERIAL: A chemical substance that falls within any of the following categories:1. FLAMMABLE AEROSOL - a chemical substance or mixture dispensed from its container as a mist, spray, or foam, by a propellant under pressure which yields a flame projection exceeding 18 inches at full valve opening.2. FLAMMABLE GAS - a gas which forms a flammable mixture with air, when present at a concentration of 13 percent or less by volume. 3. FLAMMABLE LIQUID - a liquid having a flash point below 100 deg. Fahrenheit.4. FLAMMABLE SOLID - a solid, other than an explosive, that can cause fire through friction, absorption of mixture, spontaneous chemical change, or retained heat from manufacturing or processing. A material that can be readily ignited, and when ignited, will continue to burn or be consumed, after removal of the source of ignition.

FLASH POINT: The minimum temperature at which a liquid gives off a vapor in sufficient concentration to ignite.

HAZARDOUS CHEMICAL, SUBSTANCE, OR MIXTURE: A substance that is toxic, corrosive, an irritant, dangerously reactive, extremely flammable, a combustible liquid, a strong oxidizer, a pressure generating material, or a compressed gas.

HEALTH HAZARD: A chemical for which there is statistically significant evidence based on at least one study conducted in accordance with established scientific principles that acute or chronic health effects may occur in exposed employees. The term "health hazard" includes chemicals which are toxic, carcinogenic, corrosive, irritants, sensitizers, neurotoxins, agents which affect the hematopoietic system and agents which damage the lungs, eyes, skin, or mucous membranes.

HIGHLY TOXIC: A chemical with which contact, or aspiration, may cause death or serious permanent injury.

IRRITANT: A chemical substance or mixture, but not a corrosive, that induces a local inflammatory response in the skin, eyes, or mucous membranes, after prolonged or repeated contact with normal living tissues.

LABEL: A written, printed, or graphic matter displayed or affixed to the container of a hazardous product.

SAFETY DATA SHEET (MSDS): A document that contains information and instructions on the chemical and physical characteristics of a substance, its hazards and risks, the safe handling requirements, and actions to be taken in the event of fire, spill, over-exposure, ect.

MUTAGEN: Those chemical or physical effects, which can alter genetic material in a organism, and results in physical or functional changes in all subsequent generations.

OXIDIZER: A chemical, other than a blasting agent or explosive, that initiates or promotes combustion in other materials, there-by causing a fire either of itself or through the release of oxygen or other gases.

PHYSICAL HAZARD: A chemical for which there is valid evidence that it is a combustible liquid, a compressed gas, an explosive, flammable, an oxidizer, pyrophoric, unstable, or water reactive.

PYROPHORIC MATERIAL: A chemical substance or mixture that will ignite spontaneously in dry or moist air, at or below 130 deg. Fahrenheit.

REACTIVE MATERIAL: A chemical substance or mixture that will vigorously polymerize, decompose, condense, or become self-reactive under conditions of shock, pressure, or temperature, and includes a chemical substance or mixture that falls within any of the following categories:1. Explosive Material - a chemical substance or mixture that causes sudden, almost instantaneous release of pressure, gas, and heat, when subjected to sudden shock, pressure, or high temperatures.2. Organic Peroxide - an organic compound which may be considered a derivative of hydrogen peroxide, in which one or both of the hydrogen atoms have been replaced by an organic radical.3. Pressure Generating Material - a chemical substance or mixture which may spontaneously polymerize, with an increase in pressure, unless protected by the addition of an inhibitor, or thermal control.4. Water Reactive Material - A chemical substance or mixture, that reacts with water to release heat or gas, which is flammable or toxic.

RE-LABEL: To remove the precautionary product warning from the container of a hazardous product, or to cover such a label, and affix another label to the same container while it contains the same product.

SENSITIZER: A chemical substance or mixture that causes a substantial number of persons to develop a hypersensitive reaction in normal tissue, upon reapplication of the chemical substance or mixture, through an allergic or photodynamic reaction.

STRONG OXIDIZER: A chemical substance or mixture that initiates or promotes combustion in other materials, there-by causing fire either of itself, or through the release of oxygen or other gases.

THRESHOLD LIMIT VALUES: The airborne concentration of a substance, to which nearly all workers may be repeatedly exposed, day after day without any adverse effects.

UNSTABLE: A chemical which in the pure state, or as it is produced or transported, will vigorously polymerize, decompose, condense, or will become self-reactive under conditions of shock, pressure, or temperature.

WATER REACTIVE: A chemical, solid, or liquid, that reacts with water, sometimes violently, to release a gas that is either flammable or presents a health hazard.

V. INDEX OF SAFETY DATA SHEETS

A chemical listing or index of all safety data sheets will be arranged in two parts and placed in the front of the SDS binder. Part one contains an alphabetical listing of manufacturers with the specific name of the product they are supplying to Precision Strip. Part two is an alphabetical listing by the common name of the material or chemical, along with the manufacturer.

Both listings will reference a Precision Strip, Inc., Safety Data Sheet Number (PSI SDS #). All SDS's will be listed alphabetically by both manufacturer and product, and then issued a PSI SDS #.

To locate a specific Safety Data sheet, look up the PSI SDS # in either list and find the sheet in numerical order following the index.

SAFETY DATA SHEETS

AND

YOUR RIGHT TO KNOW

THIS BOOK or SDS ONLINE CONTAINS THREE ITEMS: 1. A COPY OF OUR WRITTEN HAZARD COMMUNICATION PROGRAM. 2. A CHEMICAL LIST BY PRODUCT NAME AND MANUFACTURER WHICH REFERENCES THE PROPER SAFETY DATA SHEET (SDS). 3. COPIES OF ALL SAFETY DATA SHEETS TO LOOK-UP A COPY OF AN SDS, FIND THE PRODUCT IN EITHER THE INDEX BY MANUFACTURER, OR INDEX BY PRODUCT (BOTH LISTS ARE IN ALPHABETICAL ORDER). TO THE RIGHT OF THE INDEX LISTING WILL BE A NUMBER IN THE PSI SDS # COLUMN. ALL SDS ARE IN NUMERICAL ORDER BY THE PSI SDS # FOLLOWING THE INDEX LISTS. SDS ONLINE YOU CAN TYPE IN THE PRODUCT NAME INTO THE SEARCH ENGINE AND THE PRODUCT AND SDS SHEET WILL COME UP

IF YOU NEED HELP FINDING A SAFETY DATA SHEET, ASK YOUR SUPERVISOR, THE SAFETY DIRECTOR, OR THE GENERAL MANAGER.