EHS/HR Best Practices Teleconference Hunter Douglas Inc. March 13, 2014

EHS/HR Practices Quarterly Teleconference Agenda  Regulatory Updates  Revisions to the HazCom Standard  OSHA Risk Reduction Initiatives  Employer Coalition Against OSHA’s Electronic Recordkeeping Rule  2014 OSHA Regulatory Review of Standards  Cal/OSHA under Pressure from Federal OSHA - Revise Repeat Criteria  OSHA’s 2015 Budget Request  Leading Metrics Best Practices - Mike Dodge  Open Discussion  Next Meeting Schedule and End

EHS/HR Best Practices Quarterly Teleconference  Revision to the HazCom Standard 29CFR The revision to the HazCom Standard is a memorandum classifying Combustible Dust. It includes a revised definition for “hazardous chemical.” The new definition is: “... Any chemical which is classified as a physical hazard or a health hazard, a simply asphyxiant, combustible dust, pyrophoric gas, or hazard not otherwise classified.” What this means is that all manufacturers and importers (classifiers) will now need to determine and appropriately classify their products as combustible dust.  OSHA’s Risk Reduction Initiatives OSHA will undertake a review of the Bloodborne Pathogen Standard under the Regulatory Flexibility Act. The review considers if there is a continued need for the rule - does it conflict with other Federal, State or local regulations; and the degree to which technology, economic conditions, or other factors may have changed since implementation. They are also looking at the Permissible Exposure Limits (PEL’s) which were adopted in 1971 and have not been updated since that time. They will seek input from the public to help the Agency identify effective ways to address occupational exposure to chemicals.

EHS/HR Best Practices Quarterly Teleconference  Employer Coalition Against OSHA’s Electronic Recordkeeping Rule An industry coalition has asked OSHA “in the strongest possible terms” to withdraw the recordkeeping and reporting rule. The US Chamber of Commerce and the Coalition for Workplace Safety cited that the disclosure of company location & incident specific information will trigger malicious users because they are already occurring without easy access to such specific information. The request for the information was part of a wish list made to the Obama transition team by the AFL-CIO - “unions are known for taking company injury reports out of context when they are trying to organize an employer or pressure one during contract negotiations.” Additionally, there are a host of privacy concerns and confidential information giving insight into processes can open up companies to hostile takeover by competitors or reveal proprietary information.

EHS/HR Best Practices Quarterly Teleconference  Cal/OSHA Under Pressure from Federal OSHA to Revise Repeat Criteria Federal OSHA has become increasingly active with “policing” state approved plans. Recently, Cal/OSHA has come under fire for how it classified a repeat citation. Currently, a repeat violation is when an employer has corrected an earlier violation where a citation was issued, and commits the same violation again with a period of three years. Cal/OSHA limits a repeat citation to a violation occurring only at that establishment. Federal OSHA treats a repeat citation if an employer has been cited previously for the same or similar hazard anywhere within federal jurisdiction. Federal OSHA is pressuring Cal/OSHA to align with the federal repeat criteria and base a repeat classification off prior violations statewide. Cal/OSHA has yet to propose regulatory language. To be continued...

EHS/HR Best Practices Quarterly Teleconference  OSHA’s 2015 Budget Request As part of the budget request to Congress for fiscal year 2015, OSHA is seeking a total budget of $565 million, which is an increase of $12.7 million from the enacted 2014 budget. OSHA is also requesting an additional $3 million for federal enforcement of the health and safety standards of the OSHAct, as well as an additional $4 million and 27 FTE’s to increase the resources needed to investigate and administer 22 whistleblower statutes under the Whistleblower Protection Programs. The budget also requests an additional $400,000 for the State Programs budget in order to fund the recently approved public employee State plan in Maine and an additional $3.5 million for the State programs budget to ensure that the states have the resources to run programs that are as effective as OSHA’s Federal enforcement. One proposed amendment of note is one that allows targeted inspections of small establishments that may have potential for catastrophic incidents (those subject to Process Safety management or the EPA’s Risk management Program).

EHS/HR Best Practices Quarterly Teleconference Leading Indicators Mike Dodge

EHS/HR Best Practices Quarterly Teleconference Thank you for your participation today Next Teleconference is scheduled for: June 26, :00 PM End