Stanley Business SystemEHS Road Map -- Management System

   1.0  Management System      1.01  EHS Management System Plan and Policy          1.  The facility has a facility-specific EHS Management System Plan as the cornerstone for daily EHS activities. The plan includes all criteria required by the corporate EHS Management System Plan. The facility has developed an EHS Policy which reflects the commitment to the overall plan and continuous improvement.         2.  All associates, including new and transferred, are trained on the EHS Management System Plan and policy. The EHS Policy is communicated to all persons working for or on behalf of the facility. The policy is made available to the public and interested parties.         3.  The EHS Policy is posted within the facility. All associates including those individuals who work on behalf of the facility understand the EHS Management System Plan and Policy. Evidence from internal audits confirms knowledge and understanding of the EHS Management System Plan and Policy.         4.  The management team annually reviews the EHS Management System Plan for deficiencies and improvement opportunities. The EHS Policy is reviewed periodically to ensure relevance. The review includes a quantitative assessment of facility EHS performance versus goals and objectives. The facility formally self certifies to the ISO 14001 and OHSAS 18001 Management System Standards.         5.  The facility has a mature EHS Management System Plan which leads to continually improvement. The facility meets and/or exceeds the corporate EHS goals. The facility has been recognized for its EHS achievements through awards, certificates, etc. A licensed registrar body certifies the facility to the ISO 14001 and OHSAS 18001 Management System Standards.       1.02  Environmental Aspects and Impacts and Safety Hazards and Risks          1.  The facility has established, implemented and maintains a procedure to identify the environmental aspects and impacts & safety hazards and risks. Facility considers all elements of its activities, products, and services that can interact with the environment as part of the aspects and impacts analysis, and defines the scope, characteristics, and timing of the health and safety hazard identification to ensure a proactive rather than reactive methodology.         2.  Training needs associated with environmental impacts and health and safety hazards are identified. Associates who work in an area with a significant environmental impact have received the necessary training. Training on the hazards of the work area has occurred and associates are aware of the controls in place to help mitigate or eliminate those hazards.         3.  The facility has completed an environmental aspect-impact and health safety hazard-risk registers. All operating levels of the facility have worked to develop the registers. Facility characterizes environmental impacts with respect to significance and risks with respect to necessary control measures. The facility uses the environmental aspect-impact and health safety hazard-risk registers in formulating their EHS objectives and targets, and completes formal job safety analyses (JSA) for all health safety hazards that require control.         4.  Through workplace inspections, informal self audits, or other means, the facility continually reviews and improves their environmental aspect-impact and health safety hazard-risk registers to mitigate impacts and eliminate risks. The registers are updated as new aspects and hazards are identified. These reviews are documented.         5.  The facility has been recognized for its EHS achievements as evidenced by awards, certificates, etc. A licensed registrar body certifies the facility to the ISO 14001 and OHSAS 18001 Management System Standards.       1.03  Legal Requirements and Compliance          1.  The facility has established, implemented and maintains a procedure to identify and access applicable EHS legal and other requirements and for evaluating compliance with those requirements. The procedure describes how the facility accesses federal, regional, state and local requirements. The

facility evaluates there EHS compliance through a third party compliance audit.         2.  The facility communications all relevant legal requirements to person working for or on behalf of the facility and other interested parties. Legal and other requirements can be linked to the facilities environmental aspects and safety hazards & risks. The facility takes necessary actions to address all findings associated with the third party compliance audit and solicits a corporate or regional EHS manager to close all findings. The facilities Plant Manager signs and submits the annual Compliance Certification Letter.         3.  Recurring compliance findings or trends are analyzed for proper root cause. Corrective actions are put in place to prevent and/or eliminate recurrence. Facility populates and makes routine use of the compliance calendar, effectively enabling seamless transition of EHS resources at the facility. Compliance calendar includes any and all EHS training and regulatory events for a two-year-future horizon, and enables each event with necessary electronic-mail notifications.         4.  The facility has developed a comprehensive list of legal and other requirements. This list is evaluated prior to management review to ensure any changes or developments in legal and other requirements are considered.         5.  Facility maintains a clean compliance record for the past 24 months, meaning the facility hasn’t been served any written citation or notice of violation.       1.04  Objectives, Targets, and Programs          1.  The facility has established, implemented and maintains documented EHS objectives and targets, at relevant functions and levels within the organization. Goals are consistent with the Corporate EHS goals and strategic plans. The Plant Manager includes EHS goals on his/her annual operating plan deployment (OPR) work goals. Associates are involved in the development and review of EHS policies and objectives. The facility has a roadmap action plan as a means to track performance to goal.         2.  The objectives and targets take into account the facilities significant environmental aspects and health and safety risks. The facility also considers technological options, its financial, operational and business requirements; and the views of interested parties. The facility trains all associates, including new and transferred ones, to understand and accept responsibility for the facility EHS goals, as well as on hazard/noncompliance recognition. Such training includes a review of the Stanley EHS Scorecards and how they reflect progress towards the facility EHS goals and objectives.         3.  The facility has established, implemented and maintains a program(s) for achieving its objectives and targets. Program(s) shall include a) designation of responsibility for achieving objectives and targets at relevant functions and levels of the organization; and b) the means and time-frame by which they are to be achieved. Facility management team conducts monthly meetings on road map activities and summaries results on the action plan.         4.  Program(s) are reviewed at regular and planned intervals. Program(s) are adjusted as necessary. Facility shall have in place formal program(s) for achieving national government EHS recognitions (e.g., U.S. OSHA Voluntary Protection Program, U.S. EPA Performance Track, Mexico PROFEPA Clean Industries Award, etc.), and can demonstrate that they remain on track with program(s) elements.         5.  The facility meets and/or exceeds the corporate EHS goals. The facility has been recognized for its EHS achievements through awards, certificates, etc. A licensed registrar body certifies the facility to the ISO 14001 and OHSAS 18001 Management System Standards.       1.05  Resources, Roles, Responsibilities, and Authority          1.  The facility has established, implemented and maintains a procedure on resources, roles and responsibilities. The facility communicates roles and responsibilities at the various levels within the facility including responsibilities of the Operations/Plant Manager, EHS Coordinator, Supervisors, Associates, and EHS Committee. Top management is ultimately responsible for EHS and the EHS Management System Plan. Resources essential to the implementation of the EHS Management System Plan have been identified and implemented.         2.  The facility trains applicable associates so they understand their specific EHS roles and responsibilities. Those associates comply with all provisions of their respective roles and responsibilities. All associates take responsibility for aspects of EHS over which they have control. This includes adherence to the facilities EHS Management System Plan requirements.

         3.  Resource commitment is demonstrated through enhancements in human, technology and financial resources. The facility continues to makes expense capital money available for EHS needs as evident though Fixed Asset Requests, budgeting or capital request documents. Evidence from internal audits confirms associate knowledge and understanding of the roles and responsibilities.         4.  Documented roles, responsibilities and resources are reviewed annually. Management continues to demonstrate their commitment to continual improvement and EHS performance.         5.  The facility has not been served any written citation or notice of violation related to EHS deficiencies which occurred due to lack of resources or undefined responsibilities. Management continues to demonstrate their commitment to the continual improvement of EHS performance.       1.06  Competence, Training, and Awareness          1.  The facility has established, implemented and maintains a procedure that outlines the EHS benefits of improved personal performance through training. The facility ensures associates or individuals working on its behalf, are competent on the basis of appropriate education, training and experience. The facility has an EHS Management System Plan which includes a matrix of necessary EHS training based on facility operations and national, state and/or local regulation. The training matrix specifies training frequency and associates, and considers new hires, transfers, temporary workers, contractors, and visitors.         2.  Facility administers annual EHS General Awareness training to all associates and individuals working on behalf of the facility. Training includes Stanley Black & Decker specific initiatives such as the facility EHS Management System Plan , Guiding Principles, and Business Conduct Guidelines. Associates and individuals working on behalf of the facility are aware of their EHS responsibilities and the consequences of departure from procedures. The facility evaluates the effectiveness of the training through written tests, hands on demonstration’s, etc. Associates who demonstrate a need for additional training are re-trained.         3.  Training presentations and facility specific procedures are analyzed to ensure they are appropriate for all applicable languages, abilities, and cover the necessary impacts and hazards. Training is updated based on associate feedback, changes in facility operations, changes in regulation, etc.         4.  The facility Compliance Calendar includes all EHS Training events, including e-mail notifications. The facility keeps easily accessible documentation on all EHS training events that take place either on or off facility.         5.  a) Facility maintains a system under which identification badges or visitor passes are not granted unless EHS Training has been completed and effectiveness demonstrated. Evidence from internal and external audits confirms all EHS training has been conducted and individuals are competent. b) Evidence from internal and external audits confirms associates are involved with hazard identification, risk assessments and the determination of proper controls. The facility has received no notices of violation or compliance findings related to deficiencies in training.       1.07  Communication, Participation, and Consultation          1.  The facility has established, implemented and maintains a procedure on how to manage internal communication and communication with external parties. Communication with external parties includes regulatory agencies, local community members, contractors, customers or any other third party. Internal communication occurs among various levels and functions within the organization. A program to enhance internal EHS communications between facility leadership team and associates, such as a “Safety Dialogues” program, have been established (see Guidance Document).         2.  The facility trains all associates, including new and transfers, to understand the communication plans. The facility evaluates the effectiveness of the training through written tests, hands on demonstration’s, etc.         3.  Associates and individuals working on behalf of the facility are aware of any changes that affect their health and safety. The facility has an established and documented a method to communicate externally significant environmental aspects and/or pertinent health and safety matters.         4.  The internal and external communication procedure is reviewed annually. Updates to the procedure are made based on associate feedback, changes in facility operations, changes in regulation, etc.

         5.  Evidence from internal and external audits confirms associates are involved with hazard identification, risk assessments and the determination of proper controls. The facility has received no notices of violation or compliance findings related to deficiencies within the communication procedure.       1.08  Documents and Records          1.  The facility has established, implemented and maintains a procedure for the identification, storage, protection, retention and disposal of documents and records. EHS documents are controlled through review, update and re-approval provisions. Documents contain clear revision status and log of modification history. Facility EHS documents and records shall be and remain legible, identifiable, and traceable.         2.  The facility trains applicable associates on the document change process. Associates understand how a new document is created and approved, current documents are updated and obsolete documents are removed. Documents of external origin are controlled through the document change process.         3.  Facility has developed a records retention list. This list identifies the record name, storage location, retention period, type of protection and disposal method. Evidence from internal audits demonstrates that no obsolete records are stored past the retention timeframe. Evidence also demonstrates associates are able to access all relevant documents and records at the point of use.         4.  The facility has developed a master list of documents. At a minimum the list identifies the document name, document number, revision, location and owner. All document changes are reviewed to ensure accuracy.         5.  Evidence from internal and external audits confirms there are no obsolete documents and records being used. The master list of documents is consistent with the documents reviewed during the audit. The facility has received no notices of violation or compliance findings related to absent records.       1.09  Operational Control          1.  The facility has established, implemented and maintains a procedure to control situations where their absence could lead to deviation from the EHS Management System Plan, objectives and targets. Activities that are associated with identified hazards and environmental aspects have implemented controls to manage risk.         2.  The facility trains applicable associates, contractors, visitors, and any others who work on behalf of the facility, to understand the procedures and consequences related to deviation from the procedure. Training effectiveness is evaluated through the use of written tests, hands on demonstration’s, etc.         3.  Procedures or Standard Work Instructions (SOPs) have been created to manage operations and/or activities that have identified hazards and significant environmental aspects. These documents outline the proper controls necessary to protect the associate and the environment.         4.  Evidence from internal and external audits confirms associates and any others who work on behalf of the organization are following the necessary procedures.         5.  The facility has not been served any written citation or notice of violation related to EHS process deficiencies within the past 24 months. Facility has been recognized for its EHS achievements as evidenced by awards, certificates, etc. A licensed registrar body certifies the facility to the ISO 14001 and OHSAS 18001 Management System Standards.       1.1  Emergency Preparedness and Incident Investigation          1.  The facility has established, implemented, and maintains a procedure to record, measure, investigate and analyze incidents and potential emergency situations. At a minimum, incident investigations are being performed for all EHS incidents as required under applicable laws and regulations and those involving spills or unpermitted releases of hazardous substances, injuries to associates, temporary associates, individuals working on behalf of the organization, or incidents requiring notification to regulatory agencies. Additionally, near-misses deemed by management to be potentially serious, are also investigated. The Emergency Response Plan is comprehensive and robust considering all relevant regulations.         2.  Facility annually trains all associates, contractors, visitors, and any others who work on behalf

of the facility on the facility Emergency Response Plan. Training sessions with associates include discussions of “what-if” and “worst-case” scenarios. Facility conducts emergency response drills twice per year. The results of the drill are recorded and results discussed with associates. Facility engages community emergency responders in testing the Emergency Response Plan. The facility trains applicable associates on the incident investigation process. Those associates understand how to determine underlying EHS deficiencies that cause or contribute to incidents.         3.  Facility formulates findings from real or simulated emergency responses drills and implements corrective actions to facilitate findings closure. Facility annually invites local emergency response agencies to review their Emergency Response Plan and to inspect the facility for emergency response preparedness. Facility analyzes incident data to determine similar root causes and looks for opportunities for preventative action.         4.  The facility periodically reviews and when necessary revises its Emergency Response Plan. A review of the plan occurs after an incident or emergency situation. The facility periodically tests its emergency procedures to ensure plan effectiveness. Facility reviews process and layout changes with respect to impact on emergency response procedures. The incident investigation process is reviewed annually and the facility identifies opportunities for continual improvement.         5.  Facility participates in joint community emergency response exercises. The facility has not been served any written citation or notice of violation within the past 24 months, related to defects within the emergency response or incident investigation plan.       1.11  Monitoring and Measurement          1.  The facility has established, implemented and maintains a procedure to monitor and measure the key characteristics of its operations that can impact EHS performance including activities that could result in significant environmental impacts. The procedure includes the documenting of monitoring performance, operational controls and conformity with the facilities EHS objectives.         2.  The facility trains applicable associates, contractors, visitors, and any others who work on behalf of the facility, to understand the procedures related to the monitoring and measurement of equipment. Applicable associates are trained on the proper use of monitoring equipment. Training effectiveness is evaluated through the use of written tests, hands on demonstration’s, etc.         3.  The facility continues to monitor the effectiveness of their operational controls. Proactive and reactive measurements of performance are reviewed to ensure the necessary controls have been implemented. Records of calibration and maintenance activities for monitoring and measuring equipment are evaluated to ensure there is no reoccurring defect.         4.  Evidence from internal and external audits confirms monitoring and measurement equipment are being calibrated per regulation and/or equipment specification. All associated records are retained per the facilities records retention list.         5.  The facility has not been served any written citation or notice of violation related to defected monitoring and measurement equipment including violations related to wastewater discharge or air emissions exceedances. The facility has maintained a “clean” compliance record for the past 24 months.       1.12  Nonconformity, Corrective and Preventive Action          1.  The facility has established, implemented and maintains a procedure for dealing with actual and potential nonconformities and for taking corrective and preventative action. Nonconformities are identified through audits, inspections, associate observations, agency interactions, etc. Nonconformities are investigated to allow for discovery of the root cause and implementation of corrective action to prevent future recurrence.         2.  Results of corrective and preventative actions taken are communicated. The management team reviews the effectiveness of the actions taken to avoid recurrences. When corrective and/or preventative action identifies new or changed hazards or the need for new controls, the facility performs a risk assessment.         3.  The facility has developed a process for which it records and tracks nonconformities. The facility identifies and corrects nonconformities to mitigate environmental impacts and health and safety incidents.         4.  The Nonconformity, Corrective and Preventative Action procedure is reviewed annually. The

facility performs a gap analysis of all open and closed nonconformities to identify trends. Evidence from internal and external audits confirms corrective actions from nonconformities are being effectively implemented.         5.  Facility maintains a “clean” compliance record for the past 24 months, meaning that they have not been served any written citation or notice of violation. The facility has no compliance audit findings open greater than 60 days.       1.13  Audits and Inspections          1.  a) The facility has a written program establishing an audit and inspection standard to ensure that all regulatory and corporate requirements are met. b) The written program specifies the type, frequency and person(s) or party responsible for performing the inspections and audits. c) The written program requires the use of standardized checklists, report summaries and an Audit Blueprint document to ensure consistency in the process. d) The written program requires a thorough assessment of all activities to ensure that all potential audits and inspections are included on their specific Audit Blueprint document. e) The written program requires that inspection and audit findings be uploaded in a timely fashion to the facility specific Corrective Action Register. (CAR)         2.  a) The facility has trained all persons performing inspection and audit functions. b) The facility has a process in place to ensure that all inspections and audits are scheduled and completed on time. c) The program has a mechanism for quickly reporting, recording, and tracking to closure all findings. Findings that are considered to be Immediately Dangerous to Life and Health (IDLH) will be dealt with immediately up to and including a work stoppage if required. d) Facility findings reports at a minimum include: description, corrective action, person(s) responsible for closure and targets dates of all findings. e) The facility completes its annual 3rd Party Regulatory Compliance Audit.         3.  a) An analysis of Year over Year (YOY) trends in recurring findings, number and types of recurrences, hazard severity and location/work group is performed at least annually. b) Recurring trends are analyzed for root cause and corrective actions are put in place to prevent and/or eliminate recurrence.         4.  a) The facility includes considerations for new/additional, revised or increased frequency of inspections and audits for new/modified equipment, processes and chemicals in their Change Management Program. b) The facility can document that they have completed all required inspections and audits for 12 consecutive months based on the frequency listed on the Audit Blueprint document.         5.  a) The program and all supporting documentation is reviewed by the EHS Coordinator and facility management on an annual basis to ensure that all components are still valid and/or if additions/revisions are required. b) The facility trains all persons performing inspection and audit functions on an annual basis and the training is on their compliance calendar.       1.14  Management Review and Program Evaluation          1.  The facility has established planned intervals to review its EHS Management System Plan. This review ensures the continued suitability, adequacy and effectiveness of the plan. The management review process covers all inputs and outputs per the ISO 14001 and OHSAS 18001 standard. The facility management team continues to assess opportunities for improvement and potential changes to the EHS Management System Plan. Records of management review are retained.         2.  The facility management team understands their responsibilities and the expected outcome from management review sessions. Facility specific programs, forms and standard operating procedures (SOP’s) and/or work instructions are evaluated during regular and planned intervals. Programs are adjusted as necessary to ensure that the goals and objectives are achieved.         3.  Evidence from internal and external audits confirms management review is being held during planned intervals. All required inputs and outputs have been evaluated. Relevant outputs from management review are discussed with facility associates.         4.  The management procedure is reviewed annually. Updates to the procedure are made based on feedback from management review representatives, changes in facility operations, changes in regulation, etc.         5.  The facility has a mature EHS Management System Plan which leads to continually improvement. The facility has been recognized for its EHS achievements through awards, certificates, etc. A licensed registrar body certifies the facility to the ISO 14001 and OHSAS 18001 Management

System Standards.       1.15  Management of Change          1.  The facility has established, implemented and maintains a Management of Change Procedure. Facility specific requirements are written into the procedure The facility has identified and listed all persons that are responsible within the content of the program. The facility has developed a checklist or form which they use to outline the facility changes. Major changes in facility layout, equipment, storage, new additions, fire protection systems, fire/smoke alarm and detection systems, roof coverings, introduction of flammable/combustible liquids, gases, combustible dusts, etc, are to be reported to the Corporate EHS Manager and Stanley Black and Decker Corporate Risk Department.         2.  Applicable associates, including new associates, are trained on the Management of Change Procedure and applicable forms annually. The facility conducts detailed training to all associates who play a major role or are responsible for specific tasks/program requirements under the Management of Change Procedure. Associates understand their specific EHS roles and responsibilities within the procedure. The facility evaluates the effectiveness of the training through a written test.         3.  Evidence from internal and external audits confirms associates are complying with the Management of Change Procedure. The facility analyzes historical data to ensure old findings are closed. Findings from real or simulated events have been evaluated and corrective actions completed.         4.  The facility reviews the Change Management Procedure annually. In addition, the procedure is updated as items change or if a deviation of the current procedure occurs. The facility provides updated training on all changes which occur within the facility. The facility’s management team attends annual training.         5.  The facility has not been received any compliance audit findings, written citations or notice of violation related to a management of change deficiency. The facility reviews all process and changes that are related to the procedure. The findings are then reviewed and incorporated into the existing Management of Change Procedure.       1.16  EHS Committee          1.  The facility has established and implemented a written EHS committee program and vision statement. The EHS committee has established goals and action plans to achieve their goals. The committee meets on a regular basis and documents a meeting agenda and action items. Associates from all shifts participate on the EHS committee.         2.  EHS committee members receive advance EHS awareness training. Committee members understand their specific EHS roles and responsibilities. The facility evaluates the effectiveness of the training through written tests.         3.  The EHS Committee effectively communicates their activities with the entire facility through multiple channels such as bulletin board postings, newsletters, meetings, etc. Activities conducted by the EHS Committee are an integral part of the organizations operating procedures and culture.         4.  The facility reviews its EHS committee vision statement annually. The EHS committee continues to develop methods to increase and maintain EHS awareness throughout the facility. Special sub-committees are developed to help address specific issues or projects.         5.  The EHS Committee has helped to reduce injuries and ensure compliance with EHS standards. The EHS Committee engages over 80% of the facility workforce in committee initiatives. The team has an outlined path of work towards achieving national recognition for its EHS performance.       1.17  Lean EHS          1.  The facility has an EHS Lean program designed for continual improvement to eliminate waste and/or non- value added steps as measured by the Corporate EHS KPI’s (land, water, air, and injuries), reference SBDK Lean EHS Application Guidance Document. Program considers and incorporates the following lean application tools as appropriate A) Work station specific Shadow Boards for the consolidation and storage of tools (Associated EHS KPI- Injury rate) B) Department Huddle Boards for communication of critical to quality EHS results (Associated EHS KPI- all) C) Work station specific waste containers assigned to and measured by individual associates at work station (Associated KPI-

environmental) D) Work cells designed to eliminate motion (Associated KPI- Associated KPI- Injury rate) E) 5S program that measures to department and shift (Associated KPI- Associated KPI- Injury rate & all environmental) F) Minimum monthly EHS Kaizen events scheduled on the facility EHS Calendar with associate participation (Associated EHS KPI- all) G) Daily “Gemba” walks with facility management and associates focused on EHS (Associated EHS KPI- all) H) Visual Training Matrix by person by requirement at department (Associated EHS KPI- all) I) Other Lean techniques as appropriate for the operation The program emphasizes a continuous improvement culture based on strong leadership and associate empowerment/involvement.         2.  The facility has a defined EHS lean communication/implementation program for the elements deemed applicable from level 1 that is focused on both management and associates. The program includes a path of work, communications (training), objectives, and scope of implementation.         3.  The facility Level 2 program is implemented, associates and management are trained and the facility is measuring itself against established goals and objectives.         4.  The facility senior leadership team performs an annual review of the program with associates. Data based improvements are suggested and implemented         5.  The facility meets and/or exceeds the corporate EHS goals, and has exceed business specific EHS facility goals.       1.18  Rules and Discipline          1.  The Facility has a defined and documented set of EHS rules that apply to all associates, visitors and customers. A written policy documents how the facility communicates, enforces, and revises these rules.         2.  a) All facility associates are trained annually on EHS rules and sign-off on a copy of the rules. b) All visitors are given a copy of the facility EHS rules upon entry and sign a statement that they understand and will comply with all requirements. c) New associates are trained on the facility EHS rules during Orientation.         3.  a) Past years' accidents/incidents are reviewed to determine if EHS rule non-compliance has resulted in workplace incidents. b) Appropriate data analysis is used to identify problem areas. c) Departmental deficiencies are documented and reported to facility management. d) The Facility has responded to the additional question associated with this Road Map Work Element.         4.  The annual program review (including root causes/corrective action) is documented and includes a workplace inspection of every department to confirm compliance with facility EHS rules.         5.  a) The number of negative facility EHS rule findings tracked from year to year is decreasing. b) Disciplinary actions have decreased year-over-year.