Environmental Health and Safety Committee 4-30 Health & SAFETY Update Lee Wilmot TTM Technologies April 2009

Health & SAFETY Update 2007 BLS Injury Rate Data Review OSHA Citations for PCB & PCBA Latest Inspections Regulatory Agenda Actions

Health & SAFETY Update BLS Injury Data While injury rates are prime focus, the BLS database contains average employment data by industry Industry Goods Producing M22.897M M23.501M 334 Computer & electronic products 1.315M1.311M1.305M1.294M PCB Manufacturing 63.1K60.5K57.9K55.5K PCBA Assembly K56.4K

Health & SAFETY Update BLS Injury Rates

Health & SAFETY Update OSHA Citations Oct’07 to Sept’08 SIC 3672 Printed Circuit Boards  17 inspections  down from 12, 13, 18 & 21 in prior years  86 citations  down from 65, 63, 88 & 123 in prior years  $24,262 in penalties  Down from $21.6K, $145K, $26,5K & $69K SIC 3679 Electronic Components  32 inspections  172 citations  $91,213 in penalties

Health & SAFETY Update OSHA Citations Oct’07-Sept’08 SIC 3672 Top Standards Cited  (Inspections/ Citations/ $ Penalties)  Hazard Communication  8 / 14 / $5720 >> Compares to 8/19/$ and 5/9/$  Respiratory Protection  4 / 13 / $1990 >> Compares to 7/23/$ and 2/5/$  Spraying Flammable Liquids  2 / 5 / $1670 – 1 st time in top five  Lead  5 / 5/ $338 >> Down from 6 / 11/ $3660 in but about same as 3/5/$1750 in 05-06

Health & SAFETY Update OSHA Citations Oct’07-Sept’08 SIC 3679 Top Standards Cited  Inspections/Citations/$Penalty  Wiring  12/ 20/ $7213 >> New to top 5  Respiratory Protection  6 / 18/ $6385 v 6 / 12/ $4206 in  LockOut / TagOut  10/16/$8099 v 6/12/$$6825 in  Machine General Req’ts  8 / 12 / $7085 >> New to top 5  Wiring General Req’ts  10 / 11 / $6508

Health & SAFETY Update OSHA Inspections of 3672 plants OSHA inspections of PCB industry during CY total, versus 25 in ’07, 48 in ‘06 & 46 in ‘05 23 complaints – versus 13 in ’07 & 26 in ‘06 18 planned inspections, versus 6 in ’07 & 17 in ‘06 1 referral, versus 4 in ‘07; only 1 accident 14 complete inspections; 21 partial and 1 records 146 violations, versus 65 in ’07, 189 in 2006 and 107 in 2005 violations

Health & SAFETY Update OSHA Inspections Notable OSHA inspections of 3672 shops in CY violations at CA plant (complaint, partial) in Sept 11 violations at GA plant (complaint, complete) Feb 11 violations at CA plant (complaint, partial) in Mar. 11 violations at MN plant (planned, complete) in Oct 9 violation at WI plant (complaint, partial) in April 7 violations at CO plant (planned, complete) in Jan. 7 violations at OK plant (complaint, partial) in March

Health & SAFETY Update OSHA Inspections plants OSHA inspections of PCBA industry during CY total, versus 9 in ’07, 14 in ‘06 and 17 in ‘05 23 complaints v 6 in ’07, 7 in ‘06 and 5 in ‘05 30 planned inspects v 2 in ’07, 4 in ‘06 & 8 in ‘05 1 accident v 1 in ’07, 0 in ‘06 and 1 in ‘05 14 complete inspections v 1 in ’07, 5 in ‘06 and 7 in ‘ violations, versus 27 in ’07, 14 in ‘06 & 26 in ‘05

Health & SAFETY Update OSHA Inspections OSHA inspections of plants in violations at IL plant (referral, partial) in March 7 violations at PA plant (planned, complete) in Nov 5 violations at OR plant (planned, complete) in Dec 4 violations at FL plant (referral, partial) in Sept 3 violations at MA plant (complaint, partial) in Feb.

Health & SAFETY Update OSHA Semiannual Regulatory Agenda Agenda Published 11/24/2008 Completed Rules  Employer Provided PPE & Training Employees  Adopt Nat’l Consensus Stds for C2H4 & PPE Proposed Rule Stage  Abbreviated Portacount Quantitative Fit Testing  Haz Com >> Global Harmonization System  Walking Working Surfaces & Fall Protection Prerule Stage  Emergency Response & Prepardness  Update Standard for Power Presses  Methylene Chloride

Health & SAFETY Update OSHA Regulatory Completed Rules Clarify Employer Duties to Provide PPE and Train Employees Clarifies OSHA’s ability to issue per instance violations for each employee not provided required PPE or train employees in proper PPE use. Final Rule published December 2008

Health & SAFETY Update OSHA Semiannual Regulatory Agenda Completed Actions Adopt Consensus National Standards OSHA plans direct final rule (DFR) covering updates to nat’l standards for Referenced for acetylene PPE Final Rule planned December 2008 Abbreviated Quantitative Fit Testing Adopts current fit testing technology Test reduced 8 to 6 and 60 sec to 40 sec Proposed rule published 1/21/2009

Health & SAFETY Update OSHA Semiannual Regulatory Agenda Proposed items Update of Walking Working Surfaces and Fall Protection Standards Current standards do not include available technologies & procedures to protect EEs from slip, trip & fall hazards NPRM and hearing in Re-opened record in Comment period ended 7/31/2003. Second NPRM projected in March 2009 Hazard Communication Adopt Global Harmonization System

Health & SAFETY Update OSHA Semiannual Regulatory Agenda Pre-Rule Stage Update Standards for Power Presses Expands rule to cover hydraulic and pneumatic presses Emergency Response & Prepardness Current stds do not include updates adopted by NFPA and ANSI Methylene Chloride ( ) Began review 12/01/06. Stakeholder meetings projected April Request for comments on 7/10/07

Health & SAFETY Update Keep in Touch with EHS Issues  Visit the Website at under “Legislative and Regulatory Affairs”  Subscribe to the EHS Update  Join Compliance Net forum Contact: Fern Abrams, IPC Director of Environmental Policy (703) , Or Lee Wilmot, EHS Committee Chairman (860) , Or Kelly White, EHS Committee Vice-Chairman (727) ,