WILL NOT DISTURB ASBESTOS CONTAINING MATERIAL!

Title: Asbestos Awareness and Safety Effective Date: 11/17/2014 Control Number: THG_0036 Revision Number: 2 Date: 6/23/2015 Annual Review Completed: 5/13/2015 Asbestos Safety NOTE: Currently The Hillis Group, LLC, DOES NOT conduct any work with asbestos. The Hillis Group, LLC employees, WILL NOT DISTURB ASBESTOS CONTAINING MATERIAL! If we should enter into a situation where we need to work with or remove asbestos we will sub-contract that portion of the job. If in the event The Hillis Group, LLC encounters a situation with asbestos on any worksite, we will adhere to the following program. I. PURPOSE II. SCOPE III. ENGINEERING CONTROLS IV. CLASSIFICATION OF ACTIVITIES V. MONITORING VI. REGULATED AREAS VII. COMMUNICATION OF ACM LOCATIONS VIII. WORK PRACTICES IX. PROHIBITED WORK PRACTICES X. RESPRIATORY PROTECTION XI. PERSONAL PROTECTIVE EQUIPMENT XII. HYGIENE PRACTICES AND FACILITIES XIII. HOUSE KEEPING XIV. MEDICAL SURVEILLANCE PROGRAM XV. DEFINITIONS ATTACHMENT A Respiratory Protection For Asbestos Fibers Page 1 of 9

I. PURPOSE 1. The purpose of this program is to establish guidelines and procedures in the operations and maintenance of asbestos containing materials to protect all employees, contractors, visitors and vendors from potential health hazards of asbestos related diseases. II. III. IV. SCOPE 1. This Program applies to all buildings and structures owned by The Hillis Group, LLC to all employees and sub-contractors of The Hillis Group, LLC, to occupants of The Hillis Group, LLC buildings and to external organizations who may come into contact with or disturb asbestos-containing material in The Hillis Group, LLC buildings. 2. The Program applies to routine work during which an employee might encounter asbestos as well as work undertaken to repair or remove asbestos-containing material on our site or at any host facilities sites. ENGINEERING CONTROLS 1. If the TWA or Excursion limit is exceeded, The Hillis Group, LLC will implement a written program to reduce employee exposure. i. This will be accomplished by using engineering controls, work practices, and/or the use of respiratory protection. 2. Engineering controls and work practices will be evaluated to reduce or maintain an exposure below the TWA. 3. Engineering controls will be used if their use is feasible. If it is not feasible to use engineering controls appropriate Personal Protective Equipment suitable for the working conditions will be evaluated and selected. 4. All Abrasive Blasting operators are required to be fully qualified and competent in the operation of each piece of equipment they are required to operate. CLASSIFICATION OF ACTIVITIES ASSOCAIATED WITH ACM/PALM 1. All employees of The Hillis Group, LLC regardless of classification, must be supervised by a competent person. If you are not sure which Class the activities fall under, consult Attachment A for assistance. 2. Competent Person - Must be capable of identifying existing and predictable hazards in the work area, which are unsanitary, hazardous, or dangerous to employees and who has the authorization to take prompt corrective measures to eliminate them. This person must have the 40 hour contractor/ supervisor training course and annual 8 hour refresher training. 3. Class I: i. Activities that involve the removal of Thermal System Insulation (TSI) and Surfacing ACM and PALM. (Removal of small amounts of TSI (no more than an amount which can be contained in one glove bag) may be classified as a Class III activity). ii. *NOTE: Due to the amount of required training, specialized equipment, physical examination requirements, etc., all Class I activities are to be conducted by a qualified contractor. 4. Class II i. Activities involving the removal of ACM, which is not TSI or surfacing material. This includes but, is not limited to the removal of asbestos containing wallboard, floor tile and sheeting, roofing, and siding shingles, and construction mastics. ii. Training requirements - Training for class II operations must be equivalent in curriculum, training methods and length to the EPA Accreditation Plan (40 CFR 763, Subpart E, Appendix C). Page 2 of 9

1. When performing Class II Activities that require critical barriers or negative pressure enclosures, 32 hour initial training is required in addition to an 8 hour annual refresher training. 2. Workers conducting Class II activities that do not require the use of critical barriers or negative pressure enclosures must have an 8-hour approved training course including specific training on each type of material and an annual 4 hour refresher course. 5. Class III i. Activities involving repair and maintenance operations, where ACM including TSI and surfacing ACM and PALM, is likely to be disturbed. ii. Training Requirements - Training must be consistent with EPA requirements for training as set forth in 40 CFR 763.92 (a)(2) unless the competent person determines that the EPA curriculum does not cover the training needed to perform the activity. 1. Workers must have a 16-hour approved training course and, 2. Annual 4 hour refresher training. 3. All training will be provided prior to or at the time of initial assignment. 4. Refresher training will also be provided for all employees with potential to work with asbestos. This training program will consist of the appropriate levels as mentioned above for the different classes of asbestos work. 5. The training program will assure that each Hillis Group, LLC employee understands the health effects associated with exposure to asbestos. 6. This training program will also include information about the relationship between smoking and exposure to asbestos producing lung cancer. 7. This above training will be provided by contract services, or qualified company personnel 8. All written materials relating to the employee s training will be available upon request. V. MONITORING 1. Monitoring will be conducted at the worksite to ensure that no employees are exposed to airborne concentrations of asbestos in excess of 1.0 fiber per cubic centimeter of air (1f/cc) in 30 minutes. 2. The air quality must be monitored from the employees immediate work area. 3. The monitoring should include an 8 hour TWA and 30-min. short term exposures. 4. This should be documented and maintained at the job site. VI. REGULATED AREAS 1. All Class I, II, and III asbestos work must be conducted within a regulated area. 2. In addition, any other asbestos work which may result in airborne concentrations of asbestos exceeding 1.0 fiber per cubic centimeter of air must also be conducted in a regulated area. 3. Each regulated area must be in compliance with the following items: i. Proper signage that will protect persons outside the regulated area from asbestos exposure. ii. Limit access to regulated areas to authorized personnel only. iii. Ensure that all work is supervised by a competent person. iv. Prohibit employees from eating, drinking, smoking, chewing, or applying cosmetics in the area. v. Require appropriate respirator in accordance with Attachment A. Page 3 of 9

VII. COMMUNICATION OF ACM LOCATIONS 1. All Hillis Group, LLC Employees, perspective contractors, sub-contractors that can reasonably be expected to work in or adjacent to areas containing ACM or PACM must be notified of the presence, location, and quantity of ACM or PACM at the worksite. The host facility will make this information available prior to the start of any job. 2. In regulated areas where Class II or III activities are being conducted the following signs will be posted: DANGER ASBESTOS CANCER AND LUNG DISEASE HAZARD AUTHORIZED PERSONNEL ONLY RESPIRATORS AND PROTECTIVE CLOTHING ARE REQUIRED IN THIS AREA 3. In areas with products that contain asbestos the following signs must be posted: DANGER CONTAINS ASBESTOS FIBERS AVOID CREATING DUST CANCER AND LUNG DISEASE HAZARD VIII. IX. WORK PRACTICES 1. The following work practices must be implemented for each asbestos job: i. Vacuum cleaners equipped with HEPA filters to collect debris and dust containing ACM and PACM. ii. Wet methods or wetting agents to control employee exposure during asbestos handling, removal, cutting, and cleanup except where wet methods are not feasible (i.e. the creation of an electrical hazard). iii. Local exhaust ventilation equipped with HEPA filter dust collection systems. iv. Prompt clean-up of wastes and debris contaminated with asbestos in leak tight containers. v. Enclosure or isolation of processes producing asbestos dust. vi. Ventilation of work area to move contaminated air from the breathing zone and toward a filtration or collection device equipped with a HEPA filter. PROHIBITED WORK PRACTICES 1. The following work practices are prohibited for any work involving ACM or PACM due to the apparent hazards they would create: i. High speed abrasive disk saws that are not equipped with "point of cut" ventilator or enclosures with HEPA Filtered exhaust air. ii. Compressed air to remove ACM, unless it is used in conjunction with an enclosed ventilation system designed to capture the dust cloud created by the air. iii. Dry sweeping or other dry clean-up of dust and debris containing ACM or PACM. iv. Employee rotations as a means of reducing employee exposure to asbestos. X. RESPRIATORY PROTECTION 1. All Hillis Group, LLC employees will use a half face air purifying respirator with HEPA cartridges for any Class II or III activities for which air monitoring has indicated exposures in Page 4 of 9

excess of 1 f/cc. If air monitoring has resulted in concentrations in excess of 1 f/cc consult Attachment A. 2. Respirators will be worn in the following four circumstances: i. Work practice controls, ii. Work operations, iii. To reduce exposure, and iv. In emergencies. 3. If necessary respiratory protection will be provided at no cost to employees, and will adhere to the guidelines set forth in The Hillis Group, LLC THG_0040 Respiratory Protection Program. 4. Powered air purifying respirators will be made available when employees choose this type, provided they provide adequate protection. 5. Fit tests will be conducted in accordance with the Respiratory Protection Program. These fit tests will be conducted prior to the employee wearing the respirator and at least annually thereafter. The Safety Manager is responsible for ensuring that the fit testing is completed. This will be documented and kept on file at the corporate office. (2100 Wood Avenue, Easton PA, 18042) 6. The Competent Person is responsible for the enforcement of the use of respirators when required. XI. XII. PERSONAL PROTECTIVE EQUIPMENT 1. Protective clothing will be provided for all Hillis Group, LLC employees that are required to perform work in regulated areas. This protective clothing will consist of the following: i. Disposable coveralls, ii. Gloves, iii. Head coverings, iv. Foot coverings, v. Face shields, and vi. Vented goggles. 2. This protective clothing should be inspected prior to the start of work, and during the course of work for any damage. Damaged clothing should be repaired immediately. If repair is not feasible the protective clothing must be replaced immediately. 3. Training will be provided in accordance with The Hillis Group, LLC THG_0010 Personal Protective Equipment. This will include, but not be limited to: i. Information on respirators, ii. Protective clothing, iii. Their use, iv. Limitations, and v. All other information required. 4. This training will be documented and kept on file in the Corporate Office. 5. All protective clothing must be disposed of as asbestos contaminated waste in accordance with The Hillis Group, LLC THG_0015 Waste Management. HYGIENE PRACTICES AND FACILITIES 1. All asbestos work operations where exposures exceed a PEL the following practices will be followed: i. Room or area adjacent to regulated area for the decontamination of employees and equipment that is contaminated with asbestos shall consist of an area covered by an impermeable drop cloth on the floor or horizontal working surface. Page 5 of 9

ii. The decontamination area must be sufficient size to accommodate cleaning of equipment and removing PPE without spreading contamination beyond the area. iii. Work clothing must be cleaned with a HEPA vacuum before it is removed. iv. All equipment and surfaces of containers with ACM must be cleaned prior to removing them from the decontamination area. v. Ensure that employees enter and exit the regulated area through this decontamination area. vi. Smoking in these areas is prohibited. XIII. XIV. XV. HOUSEKEEPING 1. Vacuuming- where vacuuming methods are selected, HEPA filtered vacuuming equipment must be used. The equipment shall be used and emptied in a manner that minimizes the reentry of asbestos into the workplace. 2. Waste Disposal - Asbestos waste, scrap, debris, bags, containers, equipment, and contaminated clothing consigned for disposal shall be collected and disposed of in sealed, labeled, impermeable bags or other closed, labeled, impermeable containers. 3. Dry sweeping is prohibited due to the hazards it creates. MEDICAL SURVEILLANCE PROGRAM 1. Employees who, for a combined total of 30 or more days per year, are engaged in Class II, or III work or are exposed at or above the PEL for a combined 30 days or more per year must be included in a prescribed Medical Surveillance Program. 2. Employees that on any day perform Class II, or III work for one hour or more, must be counted as an exposure day. Contact the Safety Manager for detailed requirements. 3. Non-compliance by any Hillis Group, LLC. employee with any part of this prescribed program will result in disciplinary action as outlined in The Hillis Group, LLC THG_0030 Disciplinary Program DEFINITIONS 1. Asbestos - includes chrysotile, amosite, crocidolite, tremolite asbestos, anthophyllite asbestos, actinolite asbestos, and any of these minerals that have been chemically treated and/or altered. 2. Asbestos-containing material (ACM) - means any material containing more than 1% asbestos. 3. Assistant Secretary - means the Assistant Secretary of Labor for Occupational Safety and Health, U.S. Department of Labor, or designee. 4. Authorized person - means any person authorized by the employer and required by work duties to be present in regulated areas. 5. Building/facility owner - is the legal entity, including a lessee, which exercises control over management and record keeping functions relating to a building and/or facility in which activities covered by this standard take place. 6. Certified Industrial Hygienist (CIH) - means one certified in the practice of industrial hygiene by the American Board of Industrial Hygiene. 7. Director - means the Director of the National Institute for Occupational Safety and Health, U.S. Department of Health and Human Services, or designee. 8. Employee exposure - means that exposure to airborne asbestos that would occur if the employee were not using respiratory protective equipment. 9. Fiber - means a particulate form of asbestos 5 micrometers or longer, with a length-todiameter ratio of at least 3 to 1. Page 6 of 9

10. High-efficiency particulate air (HEPA) filter - means a filter capable of trapping and retaining at least 99.97 percent of 0.3 micrometer diameter mono-disperse particles. 11. Homogeneous area means an area of surfacing material or thermal system insulation that is uniform in color and texture. 12. Industrial hygienist - means a professional qualified by education, training, and experience to anticipate, recognize, evaluate and develop controls for occupational health hazards. 13. PACM - means presumed asbestos containing material. 14. Presumed asbestos containing material - means thermal system insulation and surfacing material found in buildings constructed no later than 1980. The designation of a material as "PACM" may be rebutted pursuant to paragraph 0) (8) of this section. 15. Regulated area - means an area established by the employer to demarcate areas where airborne concentrations of asbestos exceed, or there is a reasonable possibility they may exceed, the permissible exposure limits. 16. Surfacing ACM - means surfacing material which contains more than 1 percent asbestos. 17. Surfacing material - means material that is sprayed, troweled-on or otherwise applied to surfaces (such as acoustical plaster on ceilings and fireproofing materials on structural members, or other materials on surfaces for acoustical, fireproofing, and other purposes). 18. Thermal System Insulation (TSI) - means ACM applied to pipes, fittings, boilers, breeching, tanks, ducts or other structural components to prevent heat loss or gain. 19. Thermal System Insulation (ACM) - means thermal system insulation which contains more than 1 percent asbestos. Attachment A - Respiratory Protection For Asbestos Fibers Airborne concentrations of asbestos or conditions of use Required Respirator Not in excess of 1 f/cc (10 X PEL), or otherwise as required Half-mask air purifying respirator other than a disposable independent of exposure pursuant to (h)(2)(iv) of this respirator, equipped with a high efficiency Page 7 of 9

section. Not in excess of 5 f/cc (50 X PEL) Not in excess of 10 f/cc (100 X PEL) Not in excess of 100 f/cc (1,000 X PEL) Greater than 100 f/cc (1,000 X PEL) or unknown concentration HEPA filter. Full face piece air-purifying respirator equipped with high efficiency HEPA Filters. Any Powered air-purifying respirator equipped with high efficiency HEPA filters or any SAR operated in continuous flow mode. Full face supplied air respirator operated in positive pressure mode. Full face supplied air respirator operated in positive pressure mode, equipped with an auxiliary positive pressure SCBA, or escape pack. Note: Respirators assigned for high environmental conditions may be used at lower concentrations, or when required respirator use is independent of concentration. A high efficiency HEPA filter means a filter that is 99.7% efficient against mono-dispersed particles of 0.3 micrometers in diameter or larger. Controlled Document Review and Approval Procedure Number THG_0036 Revision 2 Effective Date: 11/17/2014 Page 8 of 9

Originator: S.C. Brockman Signature Date Safety Committee Review Date: Chairman: History Revision Number Effective Date Pages Revised Reason for Revision 1 5/13/2015 All Revised Procedure Format 2 6/23/2015 3 Added Section IV. Health Hazards Page 9 of 9