Contractor Minimum HSE Performance Requirements for Rochester Sites

HSE Performance Goals on Kodak Rochester Sites

• Zero incidents
• 100% compliance

Contractor HSE Performance Criteria

• EMR 1, or below
• Company OSHA Rate 5, or below
• HSE Violations = no significant violations
• DOT Safety Rating = Satisfactory
• Written HSE Program = Certified by Company Signature
• Service Supplier HSE History Report (PDF)

1. Contractors that fall below these requirements will be notified by Rochester Site Contracting Office (RSCO) and asked to develop an improvement plan.
2. Regular updates with the RSCO will be conducted to monitor progress.
3. There will be joint HSE audits by the contractor and RSCO.
4. Contractors that do not meet the established HSE performance criteria and/or refuse to develop an HSE improvement plan will be prohibited from bidding on future jobs/projects and/or removed from the site for a period of time determined by the commodity manager.
5. RSCO HSE will provide status reports to purchasing on the improvement plan and measures.

Please contact the site contracting office for specific information on your company's HSE performance.

Environmental Management System & ISO Guidelines

The Environmental Management System provides common direction to organizations at Kodak to help ensure compliance with corporate and regulatory requirements as well as the requirements of ISO 14001. Excellence in health, safety and environmental performance is a key objective of all operations at Kodak sites, including those involving contractors.

Environmental Requirements

Each contractor and tenant must comply and shall ensure compliance by its employees and subcontractors with applicable governmental regulations, permits, orders, consent agreements and decrees. This includes, without limitation, regulations promulgated or administered by the Environmental Protection Agency (EPA) and the New York State Department of Environmental Conservation (NYSDEC) and Kodak health, safety and environment requirements.

Specific environmental requirements will be incorporated in the project specific health, safety and environmental plan.

Note: all spills or releases must be reported immediately to Kodak Communications Center by dialing 911 or 22121 from an inside phone or 722-9911 from a cell phone or tenant phone that is not tied in to the Kodak phone system. Contractors and tenants will be responsible for cleaning up their routine spills and arranging for the disposal of the residues. Kodak will provide assistance in the case of significant spills and/or emergency situations providing imminent danger to human health or the environment.

Title V Air Permit

In 2002, Eastman Business Park became subject to a new site-wide Title V Air Permit issued by the New York State Department of Environmental Conservation (NYSDEC). This permit includes many special rules about air emissions at Eastman Business Park, and contractors must comply with them the same as Kodak, or suffer the consequences. What this means to you is that vapors, dusts, or chemicals caused by your work will need to be pre-approved in the HSE Plan or by your Kodak representative. Contractors will be subject to fines for non-compliances the same as Kodak under this permit.

The examples noted below are situations where contractors could be impacted by the permit:

• Setting up a temporary welding booth by tying into existing ductwork or a fan exhausting out the side of the building may be regulated under the air permit.
• Any activity that blocks a ventilation system or shuts off a pollution control device could put that unit out of compliance with the permit.

Waste Management and Disposal

Eastman Business Park manages, treats, stores and disposes hazardous wastes and operates under various governmental regulations, permits, and orders promulgated or administered by the Environmental Protection Agency (EPA) and the New York State Department of Environmental Conservation (NYSDEC). Each contractor must ensure compliance by all its employees and subcontractors with all applicable federal, state and local laws and regulations.

Contractors are prohibited from disposing materials into sewers (includes drains/sinks) or luggers without specific approval of the Kodak representative. Contractors may not use Kodak waste or recycling processes to dispose of their non-Kodak wastes or recyclables.

Contractors on Kodak sites may be required to manage hazardous wastes as defined in the Resource Conservation and Recovery Act (RCRA). However, Kodak is responsible to characterize, and designate disposal sites for, all hazardous wastes generated at its facility.

Conditions for management and disposal of waste material will be specified in the contract or the health, safety and environmental plan for the project.

There are environmental requirements for the handling (transport, disposal, etc.) of contractor equipment that may become contaminated with Kodak's hazardous wastes. Contractors must contact the Kodak representative prior to handling contaminated equipment.