H&H Industrial Maintenance, Inc . Lincoln Welding and Machine, Inc .

1. H&H Industrial Maintenance, Inc.Lincoln Welding and Machine, Inc. Lincolnton, Georgia 30817 Safety Policy and Procedures

2. Safety Policy and Procedures • Statement of Safety Policy • Lock Out Tag Out Guidelines • Written Hazard of Communication Program • Substance Abuse Policy • OSHA Do’s and Don’ts • Dress Code Policy • Training Meetings and Topics

3. Statement of Safety Policy In fulfilling our responsibility to each of you, we have developed and implemented a written SAFETY PROGRAM. There are many reasons for implementing such a program. 1. Responsibility to comply with local, state, and federal laws. 2. The need to reduce the financial burden accidents place on each of us. 3. The needs to provide a safe working environment that is secured by the use of practices that protect life and limb. 4. Our sincere concern for the health, safety and welfare of each of you, our valued employee. 5. All accidents and injuries are preventable, and it is the responsibility of each of use to support and participate actively in this safety program. The safety program is not inflexible, is subject to revision, and welcomes input form each of you. 6. It is the policy of this company to provide safe equipment, safe work practices, and a safe environment for its employees to the extent it is possible to do so within the limitations of human error. It is our belief that accidents and injuries can be prevented. TO AFFECT THIS POLICY: It is the responsibility of each employee to prevent injury to himself / herself and to others, not only at work, but also off the job, and to assist fellow employees in achieving the same goal. It is the responsibility of each department manager to provide the on site safety support and enforcement of rules to those employees working under his/her supervision and for the effective administration of the company’s safety program in his/ her area of authority. It is the responsibility of the company’s safety representative (assigned by management) to coordinate, update and enforce the companies safety program as well as to assist each participant in achieving their safety accountability. It is the responsibility of all employees to support this safety policy and to participate actively in the safety program.

4. Lock Out / Tag Out Guidelines I. Purpose and Scope Failure to properly lock out and tag equipment before starting to work on it can expose employees to needless hazards. Maintenance people, particularly, can be subjected to injury unless certain steps are taken to prevent accidental or unauthorized operation of the equipment. Maintenance work follows no definite pattern, as each job may be different from any other job. Each employee may work under a different supervisor and what constitutes safe practices may vary in different sections of a department, operation, or facility. Operations’ employees may also be required to lock and tag switches and valves in the course of their work during cleaning and preparation of reactors, vessels, or other equipment. It is essential that one basic safety policy, requiring the use of safety locks and danger tags, be followed to eliminate conflicting practices and needless exposure to danger. This guide establishes the requirements necessary for locking out and tagging machines and equipment. II. Lockout – Tag out Procedures Effective May 5, 1999 Safety locks and danger tags will be furnished to every employee required to work on machinery; utility lines such as electrical, air or steam; and lines containing flammable gasses or liquids, hydraulic fluids, corrosives, acids, or other toxic materials. The safety locks and danger tags will be used to lockout and tag equipment when making repairs, adjustments, lubricating, cleaning or doing any work where there is danger of being injured should the equipment be started or put into operation while such work is being done, This may require that both electrical switches and isolation valves be locked and tagged at the same time.

5. Danger tags should never be used in place of a lock. 1. All maintenance personnel will be required to carry (3) safety locks, lockout device and danger tags during working hours. All other personnel will be required to check out these items from their immediate supervisor prior to working on equipment that falls into the lockout, tag out guidelines. 2. The safety lock and danger tag will be placed on equipment controls prior to any work being done on the equipment. 3. No one except the employee whom placed the safety lock on the equipment shall remove it. The only exception will be made when the person who placed the lock and tag is not on the plant property and cannot be reached. However, in such cases, the supervisor responsible for the work must personally survey and evaluate the entire work area to determine if the lock and tag may be removed safely. 4. All other personnel who may be exposed to the possibility of injury should add their locks and tags. Automatic equipment has a built-in memory and in many instances may cycle or be activated in some manner when power is restored in equipment. Operating supervision of the department normally responsible for the equipment must take responsibility for proper shutdown of the equipment where work is to be performed. After the main switch has been pulled and/or control valve closed, equipment must be tried to be sure it will not operate. A safety lock must then be placed on the equipment to prevent power or utilities being put into operation while the equipment is being worked on. Danger tags must accompany safety locks. All switches, valves or control points between the one locked out and the equipment must be in “OFF” mode position so that when power or utility is restored, no damage can be done by auxiliary control points being in an “ON” position. When locking out hydraulically and /or pneumatically activated equipment, these additional precautions must be taken: 1. Check the hydraulic unit to make certain that the pump is not in operation. At the same time, make a visual check of the pressure gauge. 2. Before breaking or opening any airlines, bleed the pressure from all lines and units. 3. Check the hydraulic system to see if it has an accumulator. If it does, open the discharge valve and discharge the pressure back to the tank. F. After the necessary work has been completed, operating supervision of the department responsible will be notified and then the safety locks and danger tags can be removed. NOTE: These rules are established by management for the protection of the employees involved and are subject to change at the discretion of management. Certification of the above training including the employee’s names and the dates of training, An adequate supply of durable lockout and tag out devices which have been standardized in at lease one of the following criteria; Color Shape Size Print and format An annual review of the energy control program.

6. III. Employee Training Refresher Training will be provided during the monthly meetimgs to ensure that the purpose and function of the energy control program are understood by all employees. The training program will include: 1. The recognition of hazardous energy sources. a. Electrical b. Steam c. Pneumatic d. Hydraulic e. Lines containing flammable gasses 2. The type and magnitude of energy sources. a. Electrical consists of the following: -440volt 3-phase AC -220/277 volt 1 phase AC -115volt 1 phase AC -DC controls -36 volt 935 amp DC batteries -12 volt 100 amp DC batteries b. Steam consists of the following: -Steam generators -Steam manifold, lines and traps at all corrugators and paste c. Pneumatic consists of the following: -Compressors -Vacuum pumps -Air receiver -Plant airline system -Accumulators d. Hydraulics consists of the following: -All forming hydraulic systems -Lift truck hydraulics e. Lines containing Flammable gasses are as follows: -Natural gas to heaters -Natural gas to steam generator -LP gas for lift trucks

7. 3. The methods used for energy control. a. Electrical -Breakers -Switches -Panel lockout switches -Solenoids b. Steam -Valves -Rotary joints c. Pneumatic -Valves, gate -Solenoids -Pop off valves d. Hydraulics -Actuators -Valves -Pumps e. Flammable gasses -City Line pressure valves -Heater valves -LP Tank pump 4. The limitations of “DANGER” tags and the reasons why a. As a pre-warning only b. To be accompanied by lock c. Retaining will be provided whenever there is a change in job assignments; a change in machines, equipment, or processes that present a new hazard; or when there is a change in the energy control procedures. d. Training shall be documented for each training session by maintaining records of attendance and dates when the specific training was conducted.

8. Written Hazard Communication Program • INTRODUCTION:H&H Industrial Maintenance has developed a Hazard Communication Program to enhance our employees’ health and safety. • As a company, we intend to provide information about chemical hazards and other hazardous substances, and the control of hazards via our comprehensive Hazard Communication Program, which includes container labeling, Material Safety Data Sheets (MSDS) and training. • The following program outlines how we will accomplish this objective: • 1. Container Labeling • It is the policy of H&H Industrial Maintenance that no container of hazardous substances will be released for use until the following label information is verified: • Containers are clearly labeled as to the contents • Appropriate hazard warnings are noted. • The name and address of the manufacturer are listed. • This responsibility has been assigned to the Supervisors. To further ensure that employees are aware of the hazards of materials used in their work areas, it is our policy to label all in-house containers. • The supervisor in each section will ensure that all in-house containers are labeled with either an extra copy of the original manufacturer’s label, or with generic labels, which have a blank space for identity and for the hazard warning.

9. 2. Material Safety Data Sheets (MSDS) • Copies of MSDS for all hazardous substances to which employees of H&H Industrial Maintenance may be exposed are kept in the front office. The safety department will be responsible for obtaining and maintaining the data sheet system. • The Safety Director will review incoming data sheets for new and significant health / safety information. He will see that any new information is passed on to the affected employees. • The Safety Director will review MSDS for completeness. If an MSDS is missing or obviously incomplete, anew MSDS will be requested from the manufacturer. OSHA will be notified if a complete MSDS is not received. • MSDS’s are available to all employees in the work area for review during each work shift. If MSDS are not available or new hazardous substance(s) in use do not have MSDS, please contact the Safety Director immediately.

10. 3. Employee Information and training • Employees are to attend a health and safety orientation set up by their supervisor, prior to starting work for information and training on the following: • An overview of the requirements contained in the Hazard Communication Regulation, including their rights under the Regulation. • Inform employees of any operations in their work area where hazardous substances are present. • Location and availability of the written hazard communication program. • Physical and health effects of the hazardous substances. • Methods and observation techniques used to determine the presence or release of hazardous substances in the work area. • How to lessen or prevent exposure to these hazardous substances through usage of engineering controls, work practices, and/or the use of personal protective equipment. • Steps H&H Industrial Maintenance has taken to lessen or prevent exposure to these substances. • Emergency and first aid procedures to follow if employees are expose to hazardous substance(s). • How to read labels and review MSDS to obtain appropriate hazard information.

11. NOTE: It is critically important that all of our employees understand the training. IF YOU HAVE ANY ADDITIONAL QUESTIONS< PLEASE CONTACT THE SAFETY DIRECTOR. • When new hazardous substances are introduced, your supervisor will review the above items as they are related to the new material in your work area safety meeting. • 4. List of Hazardous Substances • The following is a list of all known hazardous substances present. Specific information on each noted hazardous substance(s) can be obtained by reviewing the Material Safety Data Sheets (MSDS). • List chemicals used in each department. • 5. Hazardous NON-Routine Tasks • Periodically, employees are required to perform hazardous nonroutine tasks. Prior to starting work on such projects, each affected employee will be given information by their supervisor about hazards to which they may be exposed during such an activity. • This information will include: • Specific hazards, • Protective/safety measures which must be utilized. • Measures H&H Industrial Maintenance has taken to lessen the hazards including ventilation, respirators, presence of another employee and emergency products.

12. 6. HAZARDOUS SUBSTANCES IN UNLABELED PIPESTo ensure that our employees who work on unlabeled pipes have been informed as to the hazardous substances contained within the following policy has been established: • Prior to starting work on unlabeled pipes, our employees are to contact their supervisor for the following information: • The hazardous substance in the pipe • Potential Hazards • Safety precautions which shall be taken • 7. Informing Contactors • To ensure that we work safely in the plants, it is the responsibility of your immediate supervisor to provide employees with the following information: • Hazardous substances to which they may be exposed while on the jobsite. • Precautions the employees may take to lessen the possibility of exposure by usage of appropriate protective measures. • If anyone has questions about a facility, contact your Supervisor or Safety Director. Our facility will be monitored by this individual to ensure that the policies are carried out and that the plan is effective.

13. SUBSTANCE ABUSE POLICY H&H Industrial Maintenance is committed to providing a safe work environment and to fostering the well-being and health of its employees. That commitment is jeopardized when any employee illegally uses drugs on the job, coming to work under the influence, possesses, distributes, or sells drugs in the workplace, or abuses alcohol on the job. Therefore, H&H Industrial Maintenance has established the following policy: • It is violation of company policy for any employee to use, possess, sell, trade, offer for sale, or offer to buy illegal drugs or otherwise engage in the illegal use of drugs on the job. • It is a violation of company policy for anyone to report to work under the influence of illegal drugs and / or alcohol. • It is a violation of company policy for anyone to use prescription drugs illegally. However, nothing in this policy precludes the appropriate use of legally prescribed medications. • Violations of this policy are subject to disciplinary action up to and including termination. It is the responsibility of the company’s manager’s and supervisors to counsel employee and implement corrective actions whenever they see change in performance or behavior that suggests an employee has a drug problem. Although it is not the manager or supervisor’s job to diagnose personal problems, the manager or supervisor should encourage such employees to seek help and advise them about any available resources for getting help.

14. The goal of this policy is to balance our respect for individuals with the need to maintain a safe, productive, and drug-free environment. The intent of this policy is to send a clear message that the illegal use of drugs and the abuse of alcohol are incompatible with employment at H&H Industrial Maintenance. CONFIDENTAILITY • The confidentiality of any information received by the employer through this substance abuse testing program shall be maintained, except as other wise by law. GENERAL PROCEDURES • An employee reposting for work visibly impaired will be deemed unable to properly perform required duties and will not be allowed to work. If possible, the employee’s manager or supervisor will first seek another manager or supervisor’s opinion to confirm the employee’s status. Next, the manager or supervisor will consult privately with the employee to determine the cause of the observation, including whether substance abuse has occurred. If, in the opinion of the manager or supervisor, the employee is considered impaired, if possible, the employee will be sent home or to a medical facility by taxi of other safe transportation alternative, depending on the determination of the observed impairment – and accompanied by the manager or supervisor or another employee if necessary. A drug test may be in order.

15. An impaired employee will not be allowed to drive. In cases where no person is available to transport an impaired employee and that employee insists on driving, the police will be called. • H&H Industrial Maintenance will not discriminate against applicants for employment because of a past history of drug abuse. It is the current abuse of drugs, preventing employees from performing their jobs properly, that H&H Industrial Maintenance will not tolerate. EMPLOYEE TESTING • H&H Industrial Maintenance has implemented testing practices to identify employees whom use illegal drugs on the job or who abuse alcohol on the job. It shall be a condition of employment for all employees to submit to drug testing under the following circumstances: 1. When there is reasonable suspicion to believe that an employee is using illegal drugs or abusing alcohol. “Reasonable suspicion” is based on but not limited to the following: • Direct observation of substance abuse or of the physical symptoms or manifestations of being impaired due to substance abuse • Abnormal conduct or erratic behavior while at work or a significant deterioration in work performance • A report of substance abuse provided by a reliable and credible source • Evidence that an individual has tampered with any substance abuse test during his or her employment with the current employer • Information that an employee has caused or contributed to an accident while at work • Evidence that an employee has used, possessed, sold, solicited, or transferred drugs while working on the employer’s premises or while operating the employer’s vehicle, machinery or equipment

16. 2. When employees have caused or contributed to an on-the-job injury that resulted in a loss of work time, which means any period of time during which an employee stops performing the normal duties of employment and leaves the place of employment to seek care from a licensed medical provider. An employee may be sent for a substance abuse test if they are involved in on-the-job accidents where personal injury or damage to company property occurs. 3. A part of a follow up program of treatment for drug abuse. 4. When a substance abuse test is conducted as part of a routinely scheduled employee fitness for duty medical examination that is part of the employer’s established policy or that is scheduled routinely for all members of an employment classification or group. 5. Employee names will be pulled at random to submit to drug testing. • Employees with a confirmed positive test result may, at their option and expense, have a second confirmation test made on the same specimen. An employee will not be allowed to submit another specimen for testing. • If the physician, official, or lab personnel have reasonable suspicion to believe that the employee has tampered with the specimen, the employee is subject to disciplinary action up to and including termination. ALCOHOL ABUSE • An employee who is under the influence of alcohol at any time while on company business or at any time during the hours between the beginning and ending of the employee’s work day, whether on duty or not and whether on H&H Industrial Maintenance business or property or not, shall be guilty of misconduct and is subject to discipline up to and including termination. • An employee shall be determined to be under the influence of alcohol if… • 1. The employee’s normal faculties are impaired due to the consumption of alcohol, or • 2. The employee’s blood alcohol level test is .05 or higher.

17. ALCOHOL ABUSE • An employee who is under the influence of alcohol at any time while on company business or at any time during the hours between the beginning and ending of the employee’s work day, whether on duty or not and whether on H&H Industrial Maintenance business or property or not, shall be guilty of misconduct and is subject to discipline up to and including termination. • An employee shall be determined to be under the influence of alcohol if… • 1. The employee’s normal faculties are impaired due to the consumption of alcohol, or • 2. The employee’s blood alcohol level test is .05 or higher.

18. OSHA Do’s and Don’ts • Inspect extension cords and power cords daily for any exposed wire and make sure ground spade is on male end. Repair if necessary before use. • Inspect welding leads daily for nicks or exposed cable. Repair before use. • Never remove safety guards from power tools. • When using bench grinder, make sure there is a safety shield, wheel guide is no further than ¼” from blade, and tongue guard is no more that 1/8” from blade. • Never store full oxygen bottles with flammable gasses. Must be at least 35’ away. • Wear seatbelts when operating any H&H Industrial Equipment or Vehicles. • Always wear the appropriate person protective equipment. Including but not limited to safety glasses, hear plugs, hard hat, steel toed shoes, safety harness, etc. • THESE ARE NOT ONLY OSHA STANDARDS, BUT ALSO H&H INDUSTRIAL MAINTENANCE POLICY. FAILURE TO FOLLOW THES REGULATIONS WILL RESULT IN DISIPLINARY ACTION.

19. Dress Code Policy • All machinists must wear proper clothing such as Industrial type pants (jeans) and company logo t – shirts or company logo button up shirts. • All Shirts must be tucked in appropriately. • You may wear a hat, preferably with company logo on it. • Hair can not be more than ½’’ below hat. • Employee must be clean shaven with little to no facial hair, if you do have facial hair you will be asked to keep it neat, no long beards are accepted. • Employee must have good hygiene. • Steel toed boots are needed, at the time of hire if you do not have them you will be allowed 30 days to invest in some. • Employee must make sure a long sleeve shirt is available to him / her at all times for welding. • If you should have any questions about any items that are listed above please feel free to ask the Safety Coordinator.

20. Safety Training Program H&H Industrial Maintenance, Inc. and Lincoln Welding and Machine, Inc. conduct monthly safety meetings administering to their employees training classes such as Personal Protective Equipment, Confined Space Entry, Lock Out Tag Out, Excavations and Trenching, Fall Protection, Fork Lift Safety, Crane-Boom and Scissor Lift Safety, etc. During the conduction of these safety meeting H&H Industrial also