SAFETY POLICY AND PROCEDURE MANUAL All Euramax Subsidiaries. Number F-1.0 Hazard Communication and Chemical Safety Program (GHS)

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1 Number F-1.0 Issued: 1/2009 Revised: 6/2015 Page 1 of PURPOSE: To provide a hazard free work place and to ensure that all employees who work with, are exposed to, or are potentially exposed to hazardous chemicals and substances are informed and trained in the proper use and handling of such chemicals. This program is the primary tool for providing hazard communications to our employees. It contains policy, guidelines and procedures which determine how every aspect of the program is achieved. 2.0 POLICY: All Euramax facilities will comply with OSHA Standard 29 CFR : The Hazard Communication Standard. Each facility will ensure that its employees receive the information and training they need so they may work safely with hazardous chemicals found in the workplace. 3.0 RESPONSIBILITIES: A. It is the responsibility of the Facility Leader to ensure compliance with this procedure in its entirety. B. It is the responsibility of all Employees to follow the requirements of this procedure. 4.0 UPDATED TERMINOLOGY: There are some technical terminology changes in the revised OSHA Standard. A. Previously, a liquid with a flashpoint less than 100º F was called a flammable, and a liquid with a flashpoint between 100 and ~ 200º F was called a combustible, but the updated OSHA Standard considers anything with a flashpoint of less than or equal to 200ºF a flammable. B. Compressed gases are now called gases under pressure. C. Self-reactive substances are thermally unstable liquids or solids liable to undergo a strong decomposition even without oxygen (air) being present. D. Pyrophoric liquids or solids refer to those that are liable to ignite spontaneously within 5 minutes of coming into contact with air.

2 Number F-1.0 Issued: 1/2009 Revised: 6/2015 Page 2 of PROCEDURE A. Each chemical used in the workplace must be properly labeled by the manufacturer using the GHS standard. Each chemical must list both health hazards and physical hazards. The manufacturer will classify the severity as category 1, 2, 3, or 4 (category 1 being the most severe; category 4 being the least severe). Health Hazards Health hazards refer to any of the following hazardous effects that a chemical might exhibit: Acute toxicity, through any route of exposure Skin corrosion or irritation Serious eye damage or irritation Respiratory or skin sensitization Germ cell mutagenicity Carcinogenicity Reproductive toxicity Specific target organ toxicity through either single or repeated exposure Aspiration Criteria for determining whether or not a chemical be classified as a health hazard are presented in detail in Appendix A of the OSHA Hazard Communication Standard entitled Health Hazard Criteria (see 29 CFR ). Physical Hazards Physical hazards refer to any of the following: Explosives Flammables (gases, aerosols, liquids, or solids) Oxidizers (liquid, solid, or gas) Gases under pressure - Compressed, liquefied, refrigerated liquefied, dissolved Self-reactives Pyrophorics (liquid, solid, or gas) Self-heating chemicals Organic peroxides

3 Number F-1.0 Issued: 1/2009 Revised: 6/2015 Page 3 of 8 Corrosive to metal Chemical which, when in contact with water, emit a flammable gas. Physical hazard criteria are presented in detail in Appendix B of the OSHA Standard (see 29 CFR ). B. It is the responsibility of the Facility Leader to ensure that each chemical contains proper labels. C. Pictograms In addition to the other label requirements, OSHA has adopted Globally Harmonized System (GHS) pictograms shown below. Pictograms are simple graphics used on all labels and Safety Data Sheets (SDS) to communicate specific hazards. A detail explanation of each can be found in the attachment to this procedure (see Pictogram Definitions).

4 Number F-1.0 Issued: 1/2009 Revised: 6/2015 Page 4 of 8 D. All Safety Data Sheets (SDS) will be maintained and kept current by the Facility Leader. A binder containing all SDS sheets must be placed in a designated area that is easily accessible by all employees. Alternatively, an on-line system can be used by the facility as long as every employee has access to such system and individual SDS can be printed for an employee upon request. SDS sheets will be obtained from the manufacturer or importer for each chemical in the work place. It is the responsibility of the Facility Leader to ensure that this information is obtained and properly filed. As of June 15, 2015, all SDS must follow a uniform format to involve section numbers and headings as follows: Section 1, Identification includes product identifier, manufacturer or distributor name, address, phone number, emergency phone number, recommended use, restrictions on use. Section 2, Hazard(s) identification includes all hazards regarding the chemical and required label elements. Section 3, Composition/information on ingredients includes information on chemical ingredients and any trade secret claims Section 4, First-aid measures includes important symptoms/effects, whether acute or delayed, and any required treatment. Section 5, Fire-fighting measures lists suitable extinguishing techniques, equipment, and any chemical hazards from fire. Section 6, Accidental release measures lists emergency procedures, protective equipment, and proper methods of containment and cleanup. Section 7, Handling and storage lists precautions for safe handling and storage, including any incompatibilities. Section 8, Exposure controls/personal protection lists OSHA s Permissible Exposure Limits (PELs), Threshold Limit Values (TLVs), appropriate engineering controls, and Person Protective Equipment (PPE).

5 Number F-1.0 Issued: 1/2009 Revised: 6/2015 Page 5 of 8 Section 9, Physical and chemical properties lists, as the section name indicates, the chemical s physical and chemical characteristics. Section 10, Stability and reactivity lists chemical stability and possibility of hazardous reactions. Section 11, Toxicological information includes routes of exposure, related symptoms, acute and chronic effects; and any numerical measure of toxicity. Section 12, Ecological information. Section 13, Disposal considerations. Section 14, Transport information. Section 15, Regulatory information. Section 16, Other information, includes the date of preparation or last revision. E. There are some exemptions to the requirements of the Hazard Communication Standard for certain types of products. One such exemption is for consumer products, provided such consumer products are used for the: Same purpose; Same duration of time; and Same frequency of use as that of general consumers. Consumer products are products that can be purchased in a retail store for general consumers. To construct a hypothetical scenario, consider a consumer product such as Bic Wite-Out, a product originally made for the purpose of whiting-out errors on typed documents, allowing a typist to then type over the mistake. But suppose the typist found that he or she could also use the product for sealing envelopes. When used for sealing envelopes, the product would no longer be applied for the same purpose that general consumers would use it. Therefore, the product would require a Safety Data Sheet to be readily available in the work area.

6 Number F-1.0 Issued: 1/2009 Revised: 6/2015 Page 6 of 8 Similarly, Wite-Out is a product designed for the occasional typing error that might occur while typing a document. But suppose someone had a job where she used Wite-Out not just occasionally, but throughout her particular work shift. Such an employee would no longer be using the product for the same duration of time or at the same frequency of use for which a general consumer of the product would use it. The employer in such a case, therefore, would be required to make a Safety Data Sheet readily available in the work area, even though Wite-Out is a consumer product. It is not a violation to have a Safety Data Sheet on hand for a consumer product, even if the Hazard Communication Standard does not technically require such an SDS. F. The facility leader must prepare a Master List of Hazardous Chemicals that lists all potentially hazardous chemicals and substances. This summary sheet must be located in front of the binder that contains the SDS sheets. G. A poster outlining the SDS program must be predominantly displayed in the same area as the SDS binder (or computer) to serve as a quick reference guide. H. Employees are entitled to their own copy of a SDS sheet if requested. I. Each container of hazardous chemicals and substances must be labeled, tagged or marked to indicate the product name, manufacturer s name, address and emergency phone number, hazard warning, health hazards, emergency instructions and easily identifiable cross reference to SDS. J. Under provisions of the Hazard Communications Standard, the importers, manufacturers and distributors are responsible to see that all materials are properly labeled. However, it is the responsibility of the facility leader to ensure proper labeling in the event that the original label is omitted, removed, defaced or otherwise unusable, or in the event that the substance is removed from the original container.

7 Number F-1.0 Issued: 1/2009 Revised: 6/2015 Page 7 of 8 K. Each container of hazardous chemicals leaving the facility must be labeled, tagged or marked in a manner which does not conflict with the requirements of the Hazardous Materials Transportation Act (18 U.S.C et seq.) and regulations issued under the Act by the Department of Transportation. If the hazardous chemical is regulated by OSHA in a substance-specific health standard, the labels or other forms of warning must be used in accordance with the requirement of that standard. L. The facility shall not remove or deface existing labels on incoming containers of hazardous chemicals. M. The facility will ensure that labels or other forms of warning are legible, in English, and prominently displayed on the container. Facilities having employees who speak other languages may add the information in their language to the materials presented, as long as the information is presented in English as well. N. First-time use of hazardous chemicals will not commence until an SDS has been received, approved and filed in the SDS binder. Approved updates of SDS must replace outdated SDS within five (5) working days of receipt. O. The Company shall provide its employees with education and training in hazardous chemicals and substances in their work area when they are hired and before they begin their assignment (see Procedure D-1.0: New Hire Safety Orientation). P. An annual training session will be conducted for all employees. This annual training session will be conducted during a weekly safety meeting (see Procedure D-4.0: Weekly Safety Meeting Program). In addition, if conditions or operations change or new chemicals are introduced, employees in those areas must be properly informed and trained. Q. Employees failing to comply with this procedure will be disciplined in accordance with normal progressive disciplinary procedures for the facility.

8 Number F-1.0 Issued: 1/2009 Revised: 6/2015 Page 8 of ATTACHMENT / FORMS: Pictogram Definitions 7.0 PROCEDURE HISTORY: Original Issue 1/2009 Reviewed and Updated 7/2010 Reviewed and Updated 6/2015

This pictogram is used to indicate hazardous chemicals are: Carcinogens; Respiratory sensitizers; Toxic to the reproductive system; Toxic to a target organ; Cause mutations in sperm or egg cells, or

9 Pictogram and Hazards Definitions Number F-1.0 Issued: 1/2009 Revised: 6/2015 Page 1 of 5 1. HEALTH HAZARD PICTOGRAM: The health hazard pictogram shows a black silhouette of a human form with a white area in the chest region. This pictogram is used to indicate hazardous chemicals are: Carcinogens; Respiratory sensitizers; Toxic to the reproductive system; Toxic to a target organ; Cause mutations in sperm or egg cells, or that; Present a hazard of being aspirated through the oral or nasal cavities. Chemicals that are toxic to specific organ systems might be toxic as the result of a single exposure or through repeated or prolonged exposure. 2. FLAME PICTOGRAM: The flame pictogram might be used with flammable gases or aerosols, flammable liquids, and/or flammable solids. Flammable, refers to things that can burn. Flammable Gas: A flammable gas is one having a flammable range in air at 68ºF and a standard pressure of 14.7 psi; An aerosol is a gas that is compressed, liquefied, or dissolved under pressure in a container with a release valve that ejects it in the form of gas, foam, paste, powder, or liquid particles Aerosols are considered flammable if they have any component that is a flammable gas, a flammable liquid, or a flammable solid. Flammable Liquid/Solid: A flammable liquid is basically one that has a flash point under 200ºF;

10 Pictogram and Hazards Definitions Number F-1.0 Issued: 1/2009 Revised: 6/2015 Page 2 of 5 There are four categories of flammable liquids: - Liquids with a flash point below 73.4ºF and an initial boiling point equal to or less than 95ºF are Category 1 or most flammable and, therefore, most hazardous; - Liquids with a flash point below 73.4ºF and an initial boiling point about 95ºF are Category 2; - Liquids with a flash point equal to or greater than 73.4ºF and equal to or less than 140ºF are Category 3; - Liquids with a flash point greater than 140ºF and less than or equal to 199.4º are Category 4. A flammable solid means a solid that is a readily combustible solid, or a solid that can cause or contribute to fire through friction; Readily combustible solids are powdered, granular, or pasty chemicals that are dangerous if they can be easily ignited by brief contact with an ignition source such as a burning match and if the flame spreads rapidly. In addition to flammables, the Flame pictogram can be used with: Pyrophorics; Self-heating substances; Substances that emit flammable gas; Self-reactive; and Organic peroxides.

11 Pictogram and Hazards Definitions Number F-1.0 Issued: 1/2009 Revised: 6/2015 Page 3 of 5 3. EXCLAMATION MARK OR SENSITIZER PICTORGRAM The exclamation mark pictogram covers a wide variety of health hazards: Corrosive reactions that might be ulcers, bleeding, running scabs or discoloration due to blanching of the skin, and which include: - Skin corrosion that is the product of irreversible damage to the skin for up to four hours following the application of a chemical - Skin irritation that is the production of reversible damage to the skin for up to four hours following the application of a chemical Dermal chemicals that cause a substantial proportion of exposed people or animals to develop an allergic reaction in normal dermal tissue after contact; Acute toxicity refers to those adverse effects that occur following oral administration of a single dose of a substance, or multiple doses given within 24 hours, or an inhalation exposure of four hours. Acute toxicity, depending on severity, can also be communicated by the skull and crossbones pictogram that will be discussed further below. Narcotic effects have to do with chemicals that cause dulling of the senses, alteration of mood or behavior, or that cause drowsiness or sleep; A respiratory tract sensitizer or irritant means a chemical that will lead to hypersensitivity of the airways following inhalation; An exclamation mark pictogram can be used for any chemical that causes any of the above health hazards. It can also be used with chemicals that are hazardous to the ozone layer, although that particular hazard is actually regulated by the Environmental Protection Agency rather than OSHA.

12 Pictogram and Hazards Definitions Number F-1.0 Issued: 1/2009 Revised: 6/2015 Page 4 of 5 4. GAS CYLINDER OR GASES UNDER PRESSURE PICTORGRAM The gas cylinder pictogram is used for gases under pressure. Gases under pressure refer to gases that are contained in a receptacle having pressure equal to or greater than 29 pounds per square inch, or gases, a liquefied gas, a refrigerated liquefied gas, or a dissolved gas. Gases under pressure can explode if heated, or if they are refrigerated gases, they can cause cryogenic burns or injuries. 5. CORROSION PICTORGRAM The corrosion pictogram is used for chemicals that can cause severe skin burns and eye damage or for chemicals that can be corrosive to metals. 6. EXPLODING BOMB PICTORGRAM The exploding bomb pictogram is used with chemicals that can cause an explosion or fire, with self-reactives, or with organic peroxides. An explosive chemical refers to a solid or liquid chemical that is, in itself, capable, by chemical reaction, of producing gas at such a temperature and pressure and at such a speed as to cause damage to the surroundings; A pyrothechnic chemical is a chemical designed to produce an effect by heat, light, sound, gas, or smoke, or by a combination of these, as a result of nondetonative, self-sustaining, exothermic, chemical reactions; Pyrotechnic chemicals are included in this classification even when they do not evolve gases; An unstable explosive is an explosive that is thermally unstable and/or too sensitive for normal handling, transport, or use; An intentional explosive is a chemical or item that is manufactured with the intent to produce a practical explosive or pyrotechnic effect;

13 Pictogram and Hazards Definitions Number F-1.0 Issued: 1/2009 Revised: 6/2015 Page 5 of 5 Organic peroxide means a liquid or solid organic chemical that is considered a derivative of hydrogen peroxide; Organic peroxides are liable to: - Explosive composition; - Burn rapidly; - Be sensitive to impact or friction; - React dangerously with other substances. 7. FLAME OVER CIRCLE OR OXIDIZER PICTORGRAM The flame over circle pictogram is used for oxidizers. Oxidizing solids or gases can cause fire or explosion or can intensify fires caused by other means. 8. ENVIRONMENT PICTORGRAM In the United Nations Globally Harmonized System, the Environment pictogram is used to refer to chemicals that are hazardous to the aquatic environment. In the United States, however, it is the Environmental Protection Agency, rather than OSHA that regulates environmental concerns. For that reason, OSHA has not itself adopted the Environment pictogram. You might, however, still see it on labels. 9. SKULL AND CROSSBONES OR ACUTE TOXICITY PICTORGRAM The skull and crossbones pictogram refers to acute toxicity, meaning those adverse effects that might occur following oral or general administration of a single dose of a substance, or multiple doses given within 24 hours, or from an inhalation exposure of four hours. Acute toxicity might occur through swallowing, contact with the skin, or through inhalation of gases, vapors, dusts, or mists.

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