SAFETY POLICY AND PROCEDURE MANUAL

All Euramax Subsidiaries

Number I-4.0 – OSHA 300/300A Log Forms Number I-3.0 Issued: 2/2012 Revised: 12/2014 Page 1 of 3 1.0 PURPOSE:

To comply with OSHA recordkeeping and posting requirements as it relates to OSHA 300/300A Log forms (29CFR 1904.32).

2.0 POLICY:

Each U.S. Euramax facility will retain and post OSHA 300/300A Log forms in accordance with this policy.

3.0 RESPONSIBILITIES: A. It is the responsibility of the Facility Leader to ensure compliance with this

procedure in its entirety.

B. It is the responsibility of all Employees to follow the requirements of this procedure.

4.0 PROCEDURE

A. Each Euramax facility is required to maintain a record of work-related injuries on two separate forms: OSHA 300 - Log of Occupation Injuries and Illnesses, and OSHA 300A - Summary of Occupational Injuries and Illnesses (see attached forms).

B. Each Euramax facility must record all new cases of work-related fatalities, injuries, and illnesses on the OSHA 300 Log if they involve: 1. Death 2. Days away from work 3. Restricted work or transfer to another job 4. Medical treatment beyond first aid 5. Loss of consciousness 6. Significant injury or illness diagnosed by a physician or other licensed health

care professional

SAFETY POLICY AND PROCEDURE MANUAL

All Euramax Subsidiaries

Number I-4.0 – OSHA 300/300A Log Forms Number I-3.0 Issued: 2/2012 Revised: 12/2014 Page 2 of 3

C. When reporting an injury or illness that qualifies as a privacy case, the employee’s

name should not be recorded on the OSHA 300 Log form. Instead, refer to the employee as “Privacy Case” and log the employee’s identity elsewhere in a confidential file. Examples of privacy cases are the injury or illness occurred to an intimate body part or the reproductive system; sexual assaults; mental illnesses; HIV infection, hepatitis, or tuberculosis; and needle-stick injuries and cuts from sharps where the objects are contaminated with another person’s blood.

D. If an employee has a minor injury that needs only first aid, such as a bandage or ice

pack, the injury does not need to be reported on the OSHA 300 Log form. This applies to first aid that takes place at the work site or a medical facility. All injuries that happen to employees who are under the supervision of the employer, which includes temporary and contract workers, must be entered on OSHA 300 Log form within seven days of the fatality, injury, or illness.

E. The following is a list of treatments recognized as first aid by OSHA. You can find a complete list by visiting www.osha.gov and typing “1904.7” in the search area.

1. Hot or cold therapy 2. Use of bandages, elastic bandages, or finger guards during first visit 3. Treatment of first-degree burns 4. Need for hot or cold therapy 5. Use of nonprescription medications 6. Easy removal of splinter or other foreign matters 7. Negative X-ray diagnosis 8. Physician observation of minor injury

F. Certain employee incidents are considered not reportable by OSHA, even if it occurs

on company property or while the employee is on the clock. Here are examples: 1. An injury that occurs while on property as a customer or visitor during

nonwork hours 2. Involvement in a vehicle accident on the way to or from work, including those

that take place in the company parking lot 3. Injuries or illnesses that result during personal functions such as eating, taking

medications, or grooming 4. Delayed symptoms from nonwork-related injuries or illnesses that happened

earlier in the day or week 5. Injuries or illnesses that occur while an employee is clocked out for lunch

during the workday

SAFETY POLICY AND PROCEDURE MANUAL

All Euramax Subsidiaries

Number I-4.0 – OSHA 300/300A Log Forms Number I-3.0 Issued: 2/2012 Revised: 12/2014 Page 3 of 3

G. All work-related fatalities must be reported to OSHA and Euramax safety department

within eight (8) hours. All work-related inpatient hospitalization, all amputations and losses of an eye must be reported within 24 hours. You can report to OSHA by calling (800)321-OSHA (6742) or by calling your closest area office during normal business hours. You must give OSHA the following information for each fatality, in=patient hospitalization, amputation, or loss of an eye:

1. The establishment name 2. The location of the work-related incident 3. The time of the work-related incident 4. The type of reportable even (i.e. fatality, in-patient hospitalization, amputation

or loss of an eye) 5. The number of employees who suffered a fatality, in=patient hospitalization,

amputation, or loss of an eye 6. Your contact person and his or her phone number 7. A brief description of the work-related incident

H. Posting Requirements: After the end of year, review the OSHA 300 Log and OSHA

300A form for completeness and transfer the information to the 300A Summary Form (see attached form). This log must be posted on the safety bulletin board from February 1 through April 30 of the following year (e.g., the OSHA 300A Form for the year ended December 31, 2014 must be posted from February 1, 2015 through April 30, 2015). Once the summary is removed from the posting area, it must be kept on file at the facility for five years.

I. Employees failing to comply with this procedure will be disciplined in accordance with normal progressive disciplinary procedures for the facility.

5.0 ATTACHMENT / FORMS: A. OSHA 300 Form B. OSHA 300A Form

6.0 PROCEDURE HISTORY:

Original Issue: 2/2012 Reviewed and Updated 12/2014