Environment, Health And Safety Handbook

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Levi Strauss & Co.Environment,Health and SafetyHandbook

For questions, e-mail: ehshandbook@levi.comPrinted on Recycled Paper

Table of ContentsPurpose of Handbook . 3TOE Ratings Defined . 4SECTION I: SAFETY GUIDELINESA. Safety Committee . 6B. Risk Assessment . 8C. Emergency Preparedness . 10D. Aisles and Exits . 13E. Lighting . 16F. Housekeeping . 19G. Electrical Safety . 22H. Control of Hazardous Energy / Lock-Out Tag-Out . 25I. Machine Guarding . 28J. Powered Industrial Trucks . 31K. Noise Management . 34L. Personal Protective Equipment . 36M. Ventilation. 40N. Chemical Storage . 41O. Extreme Temperatures. 44P. Asbestos Management . 47APPENDIX III1. Safety Committees . 512. Emergency Preparedness . 533. Aisles and Exits Checklist . 604. Housekeeping Checklist . 615. Electrical Safety Inspection Checklist. 626. Lock-Out/Tag-Out . 637. Machine Guarding . 658. Noise Management . 749. Chemical Storage . 7510. Extreme Temperatures . 7711. Asbestos Management. 80SECTION II: FINISHING GUIDELINESA: Finishing Safety Guidelines. 841. Hand work . 852. Laser Etching . 873. Resin / Curing . 894. Sand Blasting. 915. Screen Print . 936. Spraying . 94LEVI STRAUSS & CO.1

SECTION III: HEALTH GUIDELINESA. First Aid . 98B. Preventing Communicable Disease . 101APPENDIX III1. Factory Injuries and First Aid Log . 1052. Communicable Disease–Avian Flu . 106SECTION IV: ENVIRONMENT GUIDELINESA. Domestic Sewage and Biosolids Management . 110B. Transporting Hazardous Materials . 113C. Hazardous Waste . 115D. Solid Waste Management . 118E. Preventing Storm Water Pollution . 121F. Aboveground/ Underground Storage . 124APPENDIX IV1. Solid Waste . 1272. Storm Water: Best Management Practices . 1293. Aboveground and Underground Storage Tanks: Best Management Practices. 136SECTION V: GLOBAL EFFLUENT GUIDELINESA. Global Effluent Guidelines . 144APPENDIX V1. LS&C0. GEG Parameter Limits . 1492. Tolerance Limits . 1503. Scope . 1514. Sampling Points and Sampling . 1525. In-situ Measurements . 1546. Analytical Methods . 1557. Analytical Laboratories: List . 1578. Analytical Laboratories: Choosing a Laboratory. 1619. Submitting the Laboratory Report: Laboratory Guidelines . 16310. Submitting the Laboratory Report: Factory Guidelines . 16411. TOE Assessment and the POTW Facilities . 16512. Factories that Recycle Process Water . 16613. Factories that Use Treated Effluents for Irrigation. 16714. Domestic Sewage . 16815. Standard Letters and Forms: In-situ Measurements . 16916. Standard Letters and Forms: Domestic Sewage . 17117. Standard Letters and Forms: Publicly Owned Treatment Works (POTW) /Municipal Wastewater Treatment Facilities . 17218. Glossary . 1762ENVIRONMENT, HEALTH, AND SAFETY HANDBOOK v2.0 April 2007

Purpose of HandbookLevi Strauss & Co. has prepared this Environment, Health and Safety (EHS)Handbook to help our business partners meet the EHS requirements listedin Chapters 11 and 12 of our Terms of Engagement Guidebook. As thefollowing example demonstrates, meeting our TOE requirements is no lessimportant than meeting our quality standards or delivery time.Importance of meeting TOE RequirementsOne of our TOE requirements for Health and Safety focuses on emergencypreparedness. Several years ago, one of our factories in central Mexico installedadditional emergency exits and conducted evacuation drills to comply with thisrequirement. Four months later, a massive earthquake occurred. The factory’srecent efforts to fulfill TOE requirements ensured that its 800 employees wereable to evacuate quickly and safely. As you can see, careful attention to meetingour requirements is critical to providing a safe and health working environmentfor your employees.Using the HandbookWe have prepared this Handbook to help youmeet Levi Strauss & Co.’s EHS requirements, butwe do not herein identify all circumstances whichmight constitute “findings” in a TOE Assessment.Rather, we address topics which are of particularimportance. Each business partner must make acareful assessment of each of its workplaces todetermine what measures it needs to put in placeto meet our requirements, and, of course, therequirements of the countries where it operates. Tohelp our partners with this site-specific analysis,we not only include specific information in thisHandbook, but we also identify where additionalinformation may be found regarding each TOErequirement.preparedness, electrical safety, etc. This strategywill help business partners integrate their EHSprograms into an EHS management system.Finally, we encourage our business partners to payclose attention to the documentation and recordkeeping requirements. LS&CO. TOE Assessorsrely on written records to verify that businesspartners meet TOE requirements such as: havingestablished EHS procedures, conducting regularinspections, and training workers.Each of the EHS topics in the Handbook isorganized into 4 sections: Application, Purpose,TOE Requirements, and Implementation ofTOE Requirements. Please note that LS&CO.will hold its business partners accountable forthose items identified as “TOE Requirements”only. The sections labeled “Implementation ofTOE Requirements” provide examples of waysto comply with the TOE requirements. Thesesections close with a “Plan-Do-Check-Act” cycle,illustrating a sample strategy for implementing aspecific EHS program—for example, emergencyLEVI STRAUSS & CO.3

TOE Ratings DefinedZero Tolerance ViolationSerious breach of Terms of Engagement that results in severe impact to individual rights, life safety and/orLS&CO.’s corporate reputation. Production cannot be placed in proposed suppliers with ZT violationsconfirmed by more than one source of information. For existing suppliers with a ZT confirmed by morethan one source of information, LS&CO.’s approach is to work with existing suppliers to remediate ZTviolations immediately and endeavor to limit exit to circumstances when a supplier is unwilling toremediate or does not have the capability to remediate.Examples of ZT violations include underage workers, forced labor, corporal punishment, violation of ethicalstandards (falsification of records, unauthorized subcontracting, or failure to provide access to records orworkers), and failure to complete ZT or IA corrective actions within the agreed upon time frame.Immediate Action ItemBreach of Terms of Engagement that results in negative impact to individual rights and life safety and/orLS&CO.’s corporate reputation. Production cannot be placed in proposed suppliers with IA violations. Forexisting suppliers with an IA, the violation must be remediated fully (e.g. underpaid wages must be repaid)and within a maximum period of 2 months, or the issue becomes a ZT. Some IA violations may require aremediation period of less than 2 months.Examples of IA items include excessive working hours, non-payment of overtime premiums or contractedwages, non-provision of required government benefits, documentation on important labor issues such asage, hours, wages; proper disciplinary processes, discrimination, infringements on freedom of association,violations of local law, non-functioning water treatment facility and life safety violations (emergency exits,fire prevention).Continuous Improvement ItemLabor, health & safety, and environmental issues that can be improved in the factory for the well beingof workers and/or betterment of the factory’s reputation or management practice. Production can be placedin proposed suppliers with CI issues. For proposed and existing suppliers with CI issues, a reasonablecorrective action plan can be proposed over a 6 month period.Examples of CI items include operating permits (if company has already applied for them), establishment ofcompany policies on hiring practices, etc., records documentation, establishment of safety committees, andreview of purchases of new building materials to ensure they don’t contain asbestos.4ENVIRONMENT, HEALTH, AND SAFETY HANDBOOK v2.0 April 2007

SECTION I:Safety Guidelines

SECTION I: SAFETY GUIDELINESA. SAFETY COMMITTEEApplicationThis information applies to all factories covered by Terms of Engagement (TOE) for Levi Strauss & Co.PurposeSafety committees can identify and correct factory health and safety issues,increase safety awareness, and improve workers’ job satisfaction. The purposeof this section is to describe the requirements for having a well-run and effectivesafety committee.TOE Requirements1.Factories must have active safetycommittees.2.Safety committees must meet at least onceper month, and more often if needed.3.Safety committees must includemanagement representatives, workers fromvarious factory operations, and unionrepresentatives (if the factory has a union).4.A written record of the safety committeemeetings must be agreed upon by thecommittee leaders, posted in a workplacelocation for factory workers to read, and kepton file for a minimum of five (5) years.Implementation of TOE REQUIREMENTSTraining, Rules, and Record Keeping Safety committee members should be trained to: Investigate accidents and other health andsafety events at the factory. Conduct inspections and recognize hazards(see Risk Assessment section). Identify and evaluate health and safety trends. Use health and safety resources within thefactory or community. Safety committees should thoroughly inspect thefactory once per month and record the results.(See Risk Assessment, Aisles and Exits, andHousekeeping sections.) A management representative and a factoryworker should be chosen as leaders. The leadersshould plan the agenda prior to the meeting.Hazard Controls Once they have identified hazards in a factoryinspection, safety committees should prioritizeactions to correct these hazards as soon aspossible. Safety committees should followup on the corrective actions until they havebeen completed. The safety committee should agree on rules torun the meetings effectively.Hazard Assessment A safety committee member should be involvedin all accident and event investigations. Safety committees should review accident orevent reports to make sure actions are takento correct hazards and to avoid a similarevent in the future. (Note: the privacy of theperson(s) involved in the accident or eventshould be respected.)6ENVIRONMENT, HEALTH, AND SAFETY HANDBOOK v2.0 April 2007 Safety committees should be able to use factoryhealth and safety data to analyze accident andevent trends. This will help safety committeesfocus on activities to better control hazards. Health and safety resources should be madeavailable to safety committees, including: Website link for EU: http://europe.osha.eu.int/info Website link for U.S. OSHA: http://www.osha.gov/ The LS&CO. Environmental, Safety andHealth Handbook

SECTION I: SAFETY GUIDELINESA. SAFETY COMMITTEESProgram Strategy for Safety Committee Factory management drafts SafetyCommittee Mission Statement. Safety Committee approves MissionStatement, appoints Leaders. Leaders prepare meeting agendas. Safety Committee meets at least once amonth to discuss factory safety issues. Committee provides written record ofmeetings to management & posts acopy that worker population can easilyaccess. Keep records of safety committeemeetings for at least five years. Safety Committee changesprocedures, adopts new tools,etc. to respond to management’sfeedback and improve itsperformance. Members are trained to inspect factoryareas, conduct incident investigations,prioritize and follow-up on correctiveactions. Safety Committee conductsthe activities described in its MissionStatement and reports to factorymanagement regularly. Management reviews Safety Committeeactivities and performance andrecommends changes, as necessary.Further Information See AppendixLEVI STRAUSS & CO.7

SECTION I: SAFETY GUIDELINESB. RISK ASSESSMENTApplicationThis information applies to all factories that manufacture and finish products for Levi Strauss & Co.PurposeThe purpose of this section is to identify all hazards within the workplacewhich could reasonably be expected to cause harm and to assess the riskspresented by those hazards. Hazards include, but are not limited to, thosewhich are the subject of the other sections of the EHS Handbook.TOE Requirements1.Factories must have a procedure foridentifying workplace hazards and assessingtheir risks.Implementation of TOE RequirementsTraining, Rules, and Record Keeping Individuals or teams should be trained toidentify hazards, assess their risks, and evaluatethe effectiveness of control measures. Risk assessments should be recorded in writingand made available to factory workers.Hazard Assessment Individuals responsible for risk assessmentshould tour the entire factory, looking foroperations or work practices that could harmworkers or the environment. The EHSHandbook sections should be used as a guidefor the types of hazards to look for, but thosetouring the factory should look for hazards thatmay not be covered by the Handbook, as well. Before the tour, review Material Safety DataSheet

(Note: the privacy of the person(s) involved in the accident or event should be respected.) Safety committees should thoroughly inspect the factory once per month and record the results. (See Risk Assessment, Aisles and Exits, and Housekeeping sections.) Safety committees should be able to use factory health and safety data .

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