Company Name: Ward Mfg/HMAC (L)
City: Blossburg, PA
Number of Employees: 850

Nomination Essay:

Dear SafetyXChange,

I respectfully submit my nomination of WARD/HMAC(L) for the prestigious Henshaw Award. Following is a complete copy of the VPP application, VPP Ceremony announcement and approval letters from OSHA.

This company has made a tremendous commitment to the safety and health of their employees and community. OSHA has recognized their efforts by awarding them the VPP certification. This is a huge accomplishment considering both companies are foundries, an industry associated to safety and environmental concerns and issues. If you have any additional questions please do not hesitate to contact me.

A. General Information

1. Site/Company Name: Ward Manufacturing, Inc.
(WMI/ACP)
Site Address: 117 Gulick Street
Blossburg, PA 16912
Site Manager: Arthur (Pete) Guidi, President/CEO
Site VPP Contact: Craig Johnson, Health & Safety
Manager
Phone Number: 570-638-2131 Ext. 252

2. Agency Name: Ward Manufacturing, Inc.
Agency VPP Contact: Craig Johnson, Health & Safety Mgr.
Address: 117 Gulick Street
Blossburg, PA 16912
Phone Number: 570-638-2131 Ext. 252

3. Collective Bargaining Agents

Union Name and Local #: Glass, Molders, Pottery, Plastics and
Allied Workers International Union
(AFL - CIO - CLC)
Local Union #304B
Name of Union Contact: David Crocco, President
Union Address: 117 Gulick Street
Blossburg, PA 16912
Union Phone Number: 570-638-2131

4. Number of Employees (as of 07/01/07)

Ward Manufacturing, Inc. Employees: 630
ACP Manufacturing Company, LLC Employees: 227
Temporary Employees Routinely on the Site: 10
Contract Employees Routinely on the Site: 20

5. Type of Work Performed and Products Produced

Ward Manufacturing, Inc. was founded in Blossburg, Pennsylvania by Mr. Joseph P. Ward in 1924. Beginning in a modest fashion with approximately thirty employees, a small line of cast iron steam and drainage fittings were manufactured along with cast iron plugs and bushings.

In the following four years, the demand for Ward products increased rapidly. In 1928 the manufacturing facilities doubled in size, and the product line was expanded to include the 4" size fittings. At the same time, Class 150 malleable iron fittings were introduced in sizes ranging from 1/8" to 4".

During the next decade Ward continued to grow in size and stature to become an increasingly important factor in the American pipe fittings industry. Further expansion was completed in 1938 with the addition of a facility to produce malleable iron pipe unions.

Continued growth and the increasing demand for competitively priced products called for higher volume and more efficient molding facilities. To satisfy this business pressure, a totally new, automated foundry was erected in 1955. To this day, through careful maintenance, continued improvement and reinvestment, this facility continues to produce fittings.

May 1980 marked another major milestone in Ward's history. Beginning with Class 300 malleable fittings, a series of new products offerings were introduced into the Ward line. The new products included: Class 300 brass-to-brass seated unions, beam clamps, C-clamps, Wardlox plain-end fittings, and Couplox grooved end fittings. In 1990 the Teelox mechanical branch connector, meter swivels and ferrules, connecting nuts and a revolutionary new product called WARDFLEX were added to Ward's product offering.

WARDFLEX Corrugated Stainless Steel Tubing for piping of fuel gases was originally introduced into the U.S. in 1986 under the name of SOFLEX. At that time Hitachi Metals America (Piping Components Division) was actively working on developing standards for this product with the American Gas Association and the Gas Research Institute.

Although SOFLEX had been used in Japan for a number of years, it was virtually unheard of in the U.S. This required a substantial effort to be made in promoting the concept of using "flexible" gas tubing versus conventional steel pipe particularly in multi-family housing projects.

In 1989 Ward Manufacturing became part of the Hitachi family and was assigned the responsibility of promoting this new technology. Also at this time the product name was changed to "WARDFLEX". The product was to be distributed from the Ward plant in Blossburg, PA. Soon after the American Gas Association certified the WARDFLEX system for use in the U.S., Ward Manufacturing immediately set out to market the product all across the United States. Since that time, WARDFLEX has gained recognition in the four major model codes in the U.S. and has Code recognition of one type or another in all 50 states.

WARDFLEX is typically distributed through Plumbing and Heating or HVAC wholesalers. This is also a large part of the Ward customer base, so the network was already established for promoting this new product. In late 1990, Ward Manufacturing signed on its first distributor in Indiana. At the end of 1996, Ward had established a distributor network that maintains inventories in over 300 locations across the United States or Canada. Today the number of WARDFLEX distributors has grown to nearly 600. Demand by both the contractors and distributors continues to be strong and the outlook for the future is very optimistic.

Ward Manufacturing announced in July 1994 that a production facility for WARDFLEX would be located in Blossburg, PA. In 1998 production was relocated to the new, state of the art manufacturing facility in Lawrenceville, PA. This manufacturing facility was doubled in size during the summer of 2000 to satisfy the growing demand for WARDFLEX.

The Ward Manufacturing leadership realized the need for growth and diversification. This vision led to the creation of a new company, ACP Manufacturing LLC. Construction of this facility began in 1996, also at the Lawrenceville campus. The 385,000 sq.ft. facility was opened in 1997 and utilizes state of the art equipment to manufacture automotive cast components.

The Ward Manufacturing, Inc. leadership continues to envision growth opportunities. They are continually looking at opportunities to diversify into different product lines for each facility. In 2006, Wisconsin Pipe & Nipple was purchased and placed under the Ward Manufacturing umbrella.

The local economy benefits from the opportunities generated by Ward Manufacturing, Inc. Ward employees participate in numerous community service activities, both through financial contributions and hands on involvement. Ward is also involved in educational outreach through equipment donation to schools and organizations throughout the community.

6. North American Industrial Classification System (NAICS)

331511 Iron Foundries.

7. Injury Incident Rates

Ward Manufacturing, Inc.
Year Hours Worked Recorded Injuries Rate

2004 1,788,311 87 9.7
2005 1,553,019 48 6.18
2006 1,469,723 42 5.72

Site 3-year Average 7.2

BLS Industry Average (2005) 17.1

ACP Manufacturing, LLC
Year Hours Worked Recorded Injuries Rate

2004 508,121 44 17.3
2005 687,548 32 9.3
2006 677,450 16 4.7

Site 3-year Average 10.4

BLS Industry Average (2005) 17.1

8. Lost Workday Injury Case Rates

Ward Manufacturing, Inc.
Year Hours Worked Lost Workday Injuries Rate

2004 1,788,311 40 4.5
2005 1,553,019 30 3.9
2006 1,469,723 26 3.5

Site 3-year Average 4.0

BLS Industry Average (2005) 7.5

ACP Manufacturing, LLC
Year Hours Worked Lost Workday Injuries Rate

2004 508,121 12 4.8
2005 687,548 10 2.9
2006 677,450 5 1.2

Site 3-year Average 3.0

BLS Industry Average (2005) 7.5

Attachment A - Incident Rate Chart
Attachment B - Recordable Incident Rate Chart

B. Management Leadership and Employee Involvement

1. Commitment

The management of Ward Manufacturing, Inc. is committed to providing all employees a safe and healthful workplace. This commitment is shown both through management's personal involvement in the safety program and through the significant resources, both monetary and manpower, provided to the safety program. The primary means of personal involvement is through management participation as members of the Core Safety Team and its plant safety teams. Facility management is also involved in the hazard analysis process, accident investigations and safety awareness activities. Resources include a staff of full-time safety and health professionals, an on-site clinic and a significant commitment of money to correct identified hazards.

As further evidence of Ward management's health and safety commitment, the programs such as SAFESTART, the 6 S's, LEAN, and TPM have been instituted. We also have instituted wellness programs which include items such as; Health Risk Assessments, Ten Thousand Steps Programs, Smoking Cessation classes and various weight loss programs.

As part of Ward's effort to continuously improve its safety program, both management and the union are committed to participation in the Voluntary Protection Program. Their commitment statements are provided in Section F of this application.

Communication of Health and Safety policies are accomplished through an orientation program for new hires before employment begins. The process involves the following; Human Resources, Health and Safety and Supervision.

We have as part of our communication system, monthly talks with the exception of July which involves a shutdown period, and December which involves a number of days off. The talks encompass a number of issues which may pertain to the employees' safety or health both at home and at work. Topics are generated by the Health and Safety personnel and then are conveyed at the beginning of the month to supervisors, who in turn hold meetings to convey the information. We also have multiple information centers throughout each plant to convey any safety information and wellness programs.

Attachment C - Safety Talk Structure

We employ a variety of systems for setting goals and objectives. Safety Teams establish goals for their respective plants. The Core Safety Team establishes company-wide goals with the assistance of the Safety Teams. The Health and Safety Department establishes additional goals to further the mission of a zero accident culture and the Executive Management sets goals with respect to injuries company-wide. Goals are communicated in several ways: safety meetings, use of information boards, etc.

The involvement of the management team for the health and safety programs is evident. Listed are a number of examples of their commitment to the health and safety process.

• Semi-annual meetings held by the President/CEO in which he discusses and shows through charts the recordable and lost time comparison to previous years. He also highlights activities that are in process within the organization.
• Recognition and reward for the facilities reaching safety goals, such as working a million man-hours without a lost time accident milestone, was done via newspaper articles along with each employee receiving a lined jacket.
• Safety awareness signs and banners are placed in facilities.
• Health, safety and wellness boards are utilized in all facilities.
• Dedication to upgrade equipment and facilities through the yearly budget to provide a safe and healthy place of employment.

Attachment D - Safety and Health Mission Statement
Attachment E - Current Safety Goals

2. Organization

The Health and Safety Manager reports directly to the Vice President of Human Resources. The Vice President of Human Resources reports directly to the President / CEO of the Company. The Health and Safety Manager has a staff which consists of two Safety Technicians, an Occupational Health Nurse and a clerk.

The Core Safety Team, which oversees Ward Safety Teams, is chaired by the Health and Safety Personnel and consists of representatives from both management and union. The Core Safety Team is responsible to direct the plant Safety Teams toward a zero accident culture by minimizing accidents and incidents.

A copy of the Ward Safety Program Structure is provided. A chart showing the relationship between the Health and Safety Department and the various personnel and organizations involved in safety program implementation is provided.

Attachment F - Safety Program Structure
Attachment G - Organization Charts

3. Responsibility

At Ward Manufacturing Inc., the primary responsibility for safety rests with line organization management beginning with the Plant Managers. Responsibility for the implementation of the safety program belongs to the Health and Safety Manager. Major safety policy for the Company is established by the Health and Safety Department, Executive Management Team, Core Safety Team and its various committees. Day to day implementation of the safety program has been delegated to the Health and Safety Office. The professional safety and health staff of Ward assists managers, supervisors and safety teams with effective implementation of the safety program throughout their organizations and with identification and abatement of hazards in their facilities.

Authority and responsibility for employee safety and health is integrated within the overall management system of the organization as demonstrated below.

CEO / President / Vice-Presidents

• Provide leadership, resources and commitment to all employees for an active and continuously improving safety system.

Managers

• Provide support, leadership and commitment to safety and health excellence. Management leadership includes setting priorities through policy, goals and objectives, assignment of responsibility, accountability, and program evaluation.
• Provide supervisors and employees with a clear understanding of safety and health expectations.
• Managers are actively involved in the process and encourage employees to actively participate in the safety and health program.
• Managers are responsible to allocate the needed resources to accomplish all aspects of Ward Manufacturing Inc.'s Safety and Health Program.

Supervisors

• Supervisors are responsible to take the lead and actively support the safety process.
• Safety discussion and reminders are a part of their responsibilities.
• Employees are to notify their supervisor of any hazard or safety concern for investigation or resolution.
• Supervisors must be actively involved in the process and seek employee involvement into safety issues and processes.
• Supervisors must demonstrate their commitment to continuous safety improvement through their example.

Employees

• The responsibility of each employee shall be to follow all applicable safety and health practices and to be actively involved in the safety and health process.
• Each employee must not only identify and report deficiencies, but also take an active role in identifying solutions to safety problems and corrective deficiencies.
• Employees shall demonstrate the knowledge, skill and ideas necessary to directly and positively impact continuous safety performance.
• Employee involvement is paramount if safety and health excellence is to be achieved.

4. Accountability

Working safely is considered a condition of employment at Ward Manufacturing, Inc. Managers and supervisors are held accountable for maintaining a safe workplace through the annual performance appraisal system. All employees are held accountable for maintaining a safe workplace. All managers and supervisors have safety and health as a job element in their performance appraisals. Low ratings in this area will negatively affect raises given to supervisors and managers. The safety rating is qualitative and is based on mishap experience, recordable accidents, compliance with safety requirements, support of safety-related activities and cooperation with health and safety personnel. The Health and Safety Department is asked to provide input on supervisors' performance in the area of health and safety on an annual basis.

Employees are accountable to their supervisors to work safely and to report any accident or hazard immediately. Both employees and supervisors are held accountable through the discipline system, which includes penalties for safety violations and failure to report mishaps and hazardous situations. The discipline system is documented in the union contract for union represented employees.

5. Resources

Ward Manufacturing Inc. has a staff of five dedicated to the Health and Safety System. Along with the staff, the corporation has five Safety Teams that are certified by the state of Pennsylvania. Supervisors and hourly employees have completed a number of courses related to safety. Supervision has completed the National Safety Council's Safety Leadership for Supervisors. Safety Teams have completed the OSHA 501 10-hour Course. These are just a few examples of the training provided to the staff and employees of Ward Manufacturing Inc. The Health and Safety Manager and the Safety Technician are both OSHA General Industry Outreach Trainers. To compliment the training, a number of checklists and procedures are utilized to operate our Safety System. Some of these are: JSA's, One Point Lessons, PPE Hazard Analysis, and Machine Check Off.

Equipment such as Automatic External Defibrillators (AED), 11 total, spill containment equipment, PPE, training facilities with adjunct equipment, plus other items are available and utilized.

Our Corporate philosophy is for continuous improvement in all aspects of our business plan. Health and safety is thought of as part of our system. As such, capital expenditures are budgeted yearly for health and safety programs. Things that would be budgeted are items such as awards, personal protective equipment, upgrade of equipment, etc.

6. Planning

As stated, safety is part of the process at Ward Manufacturing Inc. Weekly staff meetings begin with an update of health and safety issues. Manning requirements are taken into consideration, as is the demand set on the employee with regard to overtime. Design and implementation of new equipment and process lines are reviewed with regard to total process, safety, quality and production. New and repaired equipment must be approved by maintenance, engineering, health and safety, and supervision. Capital expenditure requests must also be reviewed by health and safety, and approved as required.

Workers who are new to the Company or who are transferred to a different department are trained on safe operating procedures prior to commencement of work. The employee's supervisor or Health and Safety personnel will complete and sign an orientation checklist. We also have developed training matrices for monthly safety talks and other common tasks.

7. Contract Workers

At our facilities, we utilize services of various contractors on a periodical or continual basis. We have for a number of years required contractors to acquire training from the Health and Safety Department. With the ISO 14001 certification, a two-year time frame was developed for retraining. A Contractor Approval List, along with training records, is maintained by the Health and Safety Department. An updated Contractor and Subcontractor Policy was adopted mid-2006 and requires information to be given to our Company from any contractor or subcontractor performing work on-site. It incorporates health, safety and environmental information. Contractors are required to submit OSHA rates/logs for the previous 3 years and a certificate of insurance. Safety records are reviewed prior to coming on-site.

Attachment H - Contractor Approval Flowchart
Attachment I - Contractor Approval Information Packet
Attachment J - Contractor Orientation Checklist

During our orientation process a number of factors are reviewed. We discuss the scope of their work, safety procedures directly related to that scope, accident and incident requirements, on-site inspections by Health and Safety personnel, location for meeting in case of emergencies, registration by contractor personnel with guard service prior to daily work and consequences of health, safety or environmental violations.

The number of contractors on-site varies. We do have contracts with Forklifts Inc., U.S. Security Associates and Keystone Scales, to name a few, to perform specific work throughout the year. We require assistance from contractors to perform different tasks. On an average project we may have ten employees from a contractor on-site. The exception to this is our July shutdown period. During this timeframe we have a number of projects that may be ongoing and, depending on the scope of work to be performed, we may require multiple contractors on-site with a possibility of twenty-five or more contract employees.

8. Employee Involvement

Employee involvement occurs through a number of methods. We utilize the Safety Core Team as the steering committee for our safety teams and system. The Core Safety Team is comprised of chairpersons from each Safety Team, five total. The members include hourly and management with Health and Safety overseeing. The Team is tasked to assist in program development and implementation and help Safety Teams in resolving difficult issues. The Team meets monthly and members can, and do, consult with Health and Safety personnel whenever the need arises. This Team periodically performs plant inspections in addition to each facility's Safety Team inspection.

Plant Safety Teams, of which there are five, are comprised of both union and management. Our teams meet the criteria and are certified by Pennsylvania. The teams meet monthly and conduct monthly inspections. Health and Safety will identify and provide information to the teams for specific inspection criteria such as; walking/working surfaces, machine guarding, etc. along with a general inspection. Teams are provided training such as OSHA 501 for general industry. Annually, the Teams set safety goals for items they feel need addressed. The Team also assists in accident investigations.

LEAN and the 6 S's programs are being utilized in our plants. These programs look at all aspects of the process flow including the safety aspect. Ideas for improvement can be generated through an individual or through a committee.

We have employees involved in special projects and training such as authorized lift truck and aerial lift trainers. We have both hourly and management involved in ergonomic committees. These committees assist in identifying and correcting issues. Teams meet as required to handle issues. Many of these employees have attended an eight-hour class on ergonomics that was conducted by a certified industrial hygienist from Zurich Insurance. Employees are also involved in JSA's, JDA's and One Point Lessons.

Attachment K - Job Safety Analysis (JSA)
Attachment L - Job Demand Analysis (JDA)
Attachment M - One Point Lesson

The Safety and Health Committees (Five Safety Teams) were developed 15 years ago and were initially certified on April 1, 1997. They are recertified annually. The members of these committees, which we refer to as Safety Teams, are selected on a volunteer basis. Length of service is determined by the individual with no time limit imposed. We do however limit the size of the Safety Teams to a maximum of sixteen. The teams meet monthly with minutes taken. The minutes are posted in each plant and on our Company intranet. As stated, team members have been trained in different programs such as OSHA 10-hour for general industry and specific topics such as machine guarding, accident investigation, etc. The teams consist of both hourly and management personnel.

Attachment N - Safety Team Certification
Attachment O - Safety Team Bylaws
Attachment P - Core Team Bylaws
Attachment Q - Meeting Minutes (samples)

9. Safety and Health Program Evaluation

Program evaluation is performed in a number of ways. Health and Safety personnel review and update policies as required. Review of incident and accident information may generate a need to revise a procedure. Some safety and health programs are outlined in Section C. Industrial hygiene sampling that has been performed again is reviewed and if action is required, Health and Safety personnel will give direction. The Core Safety Team may bring items of concern forward to Health and Safety Personnel that the safety teams have identified. Also, program evaluation is performed as part of the ISO 14001 internal and external audit process. A number of policies are incorporated into the ISO 14001 Environmental Management System. Deficiencies are also identified through non-conformance reports. All findings are reviewed with corrective action plans formulated and acted upon. As demonstrated in Section A - 7 & 8, our injury incidence and lost workday case rates are below the BL S average.

The effectiveness of the safety and health program is evaluated on a monthly and annual basis. Each month the safety teams (management and hourly) perform facility inspections. This information is compiled through Health and Safety personnel. The results, and any required specific actions, are communicated through monthly safety committee meetings. Issues that require further action are referred to the Core Safety Team. In addition to this, Health and Safety personnel may issue a Non-Conformance Report.

We conducted an informal OSHA audit with a representative from our insurance broker, Thillman Filippini, to evaluate our readiness for VPP status. The results and recommendations of the audit were addressed and corrected.

10. Employee Notification

When the idea of entering the VPP program came about, the first thing we did was have a meeting with our management team to explain the program and to get their input. It was unanimous that we should try to apply with all members of our management team. We invited Fred Bartrol, OSHA compliance officer from Wilkes-Barre, Pennsylvania office to give a presentation to the union and management teams. After the presentation and the views of management were expressed, the floor was opened to any employee to give an opinion on the program to express their approval or disapproval for the application process to begin. We have communicated through a number of methods such as safety talks, information boards, safety teams and the Company newsletter.

Any employee may file a complaint with OSHA at any time. We first encourage our employees to discuss any safety problems with our management, safety committee members, and/or use the suggestion box or the employee safety concerns forms. We actively ask our employees if they have any safety concerns and correct these concerns as quickly as we can. We have an open-door policy with all employees (hourly/management) and encourage issues to be brought up and resolved in a timely manner. If an employee requests information on how to contact OSHA that information will be furnished directly by his/her immediate supervisor or can be viewed on the company bulletin board where we have posted the OSHA Publication for Pennsylvania Employee Rights posters. These posters have the OSHA standards and rights listed on them. The OSHA website address is also clearly listed on the poster, should any employee want to go online to seek information or assistance.

The results of all formal inspections are available in the Health and Safety Office for all employees to review at their leisure. As for accident reports or findings, this information is only available to those employees who are the principle parties involved as well as the management team.

C. Worksite Analysis

1. Pre-Use Analysis

The process we utilize for new equipment begins at the design stage. Working with the manufacturer, we incorporate into the contract that the equipment must meet all applicable OSHA standards. The flow process is reviewed by Engineering, supervision, applicable employees, and Health and Safety. As the new equipment is being built, visits to the manufacturer are made if necessary. Questions pertaining to health and safety are discussed and analyzed. When the equipment is delivered, each phase of installation is monitored by different groups. Prior to the equipment being placed into production, an equipment check form is filled out. This form addresses items such as "Are all electrical connections installed properly; Is all guarding properly installed; Is there a lockout/tagout procedure; etc" (12 items in all). The form requires four signatures to be released for production. Those signatures are engineering, maintenance, supervisor, and health and safety.

For equipment that is modified, the process is similar. The equipment that is being modified may involve outside contractors. For this equipment we would follow what has been discussed for new equipment. For equipment that we are modifying with our staff, we would also follow the same format. In either case the equipment check form must be completed.

Attachment R - Equipment Checklist

2. Self-Inspections

Several different types of self-inspections are performed on all areas of Ward Manufacturing Inc. on a regular basis. We track all inspection findings by the NCR and JMR systems. Types of self-inspections include, but are not limited to:

Employee Self-Inspections: Every employee is required to continually assess their work and work environment for potential hazards to determine if unsafe conditions exist. Employees are required to eliminate identified hazards if possible and to report any hazards they are unable to eliminate to their supervisor. They are encouraged to submit a Job Maintenance Request (JMR) to correct unsafe conditions.

Safety Audits: All facilities are inspected monthly by Safety Teams, Health and Safety, or loss prevention persons from insurance/brokerage agencies.

Attachment S - Safety Tour Form

Fire Audits: All fire extinguishers are inspected monthly by the Safety Teams and quarterly by a fire extinguisher company. Insurance agencies perform audits and inspections pertaining to property and product loss that may cause business interruption.

Attachment T - Fire Extinguisher Checklist

Industrial Hygiene Audits: All facilities are audited by a Certified Industrial Hygienist in cooperation with Health and Safety personnel. All areas of industrial hygiene are addressed. Frequency is based on the potential hazard level of each facility. High hazard facilities are audited annually, and other facilities are audited at a minimum of every three years.

Construction Audits: Construction audits are conducted by Health and Safety personnel. The frequency of audits is determined based on the potential risk with high-risk operations being audited on a daily basis. All findings are documented and required corrective actions are tracked to completion.

Environmental Audits: Internal environmental audits are scheduled by a management representative or the ISO 14001 Lead Auditor. Annual external audits are conducted by the Registrar at the time of renewal.

AED / First Aid Audits: AED's are audited daily by the security service with documentation placed on a checklist. They are also thoroughly checked monthly and annually by Health and Safety staff.

Attachment U - AED Daily Inspection
Attachment V - AED Monthly Inspection
Attachment W - AED Yearly Inspection

3. Comprehensive Surveys

There are a variety of air sampling methods used for the determination of safety and health hazards. We perform a number of industrial hygiene surveys. We acquire the services of a certified Industrial Hygienist from Zurich Insurance to perform a number of air samples yearly, or more frequently if necessary. Air samples are taken for silica, formaldehyde, phenols, iron oxide, metal working fluids and TEA gas. Results and recommendations are reviewed and distributed with action plans. We hold a consultation with the hygienist in which methods to correct issues are discussed, with follow up sampling as required. Sound level mapping and dosimeter sampling are taken by Health and Safety personnel. Sampling data is reviewed and corrective measures are taken if warranted. Auditing processes are performed by the Safety Team, Health and Safety and internal auditors performing audits in accordance with ISO 14001 or relevant processes. Grade D breathing air is checked semi-ann ually to ensure it meets or exceeds Grade D breathing air requirements. Confined spaces are identified and evaluated by Health and Safety personnel. The Hazard Communication Program is a living document and is under constant change. New products that are to be sampled or replaced must be reviewed by the Environmental and Health and Safety Departments. A sample of MSDS's that are in use are reviewed annually to assure that they are current.

Attachment X - Material Review Form

4. Routine Hazard Analysis

We look at our equipment and processes constantly. Reviews may be formalized utilizing:

• JSA's
• One Point Lessons
• Safe Work Procedures

We also review informally with observation and based on an incident occurring or based on an ergonomic issue or concern. After the analysis has been completed and an action plan instituted, employees are made aware through items such as the JSA's and/or through the supervisor.

Attachment Y - WMI Safe Work Procedures
Attachment Z - ACP Safe Work Procedures

5. Employee Reports of Hazards

Employees are instructed upon hire at their new employee orientation to report any condition that they feel is unsafe. They are encouraged to report unsafe conditions. They are provided with an Employee Safety Manual that encompasses this concept. Collective Bargaining Agreement (CBA) language encourages employees to report unsafe conditions and affords them job protection for refusal to perform work that they deem to be unsafe. Article XIX of the CBA addresses Health and Safety responsibilities of the Company and Union workforce. Ward/ACP Manufacturing's code of conduct also addresses unsafe work conditions.

Employees may report unsafe conditions and hazards in several ways:

• Report this hazard immediately to their first line supervisor.
• Report the hazard/unsafe condition to their safety team representative.
• Inform Health and Safety personnel directly since there is an "open door policy" within the Health and Safety Department.
• If the hazard is not an immediate danger, employees may make use of the safety suggestion boxes to make improvements and/or eliminate hazards.
• All employees are permitted to complete a Job Maintenance Request (JMR) to correct an unsafe condition.
• All plants are subjected to monthly safety tours/inspections by safety team members and any other worker they choose to accompany them. There is a monthly tour inspection form that identifies any unsafe conditions/hazards.

All unsafe conditions and hazards are corrected immediately. As mentioned above, all employees are first encouraged to report safety concerns/issues to their first line supervisor. In the rare event that an employee is concerned about reprisal/retaliation, they are allowed to report directly to the Health and Safety office personnel any safety concern. All safety concerns reported to Health and Safety are kept in strict confidence. At that point, there is a two-prong investigation. One portion deals with the safety issue and is performed by Health and Safety personnel. The hazard is reviewed, corrective action decided upon and then fixed. The second part deals with the fear of reprisal and is conducted primarily by Human Resources personnel.

Ward/ACP Manufacturing is committed to a "zero accident culture" and we believe all injuries/accidents are preventable. In order to achieve this goal we all must be responsible, to both ourselves and our fellow employees, to avoid unsafe practices and conditions. Every employee is further responsible for the immediate correction of any unsafe act by any other employee or unsafe condition that is observed.

Attachment AA - Labor Agreement (CBA)
Attachment BB - Employee Safety Manual
Attachment CC - Code of Conduct
Attachment DD - Harassment Policy

When a condition is deemed to have a high potential for loss of life, limb or serious injury, the hazard is immediately shut down, employees are removed from harms way, the hazard is blocked off and an investigation commences immediately. In all cases such as these, Health and Safety personnel are involved in every step of the investigative process. Only when the hazards/unsafe conditions have been eliminated, and the approval from Health and Safety personnel is given, is work in that area or at that machine resumed. Any employee can notify Health and Safety of an imminent danger situation. Employees can also notify OSHA by using the information, which includes the telephone number of the area office, posted on all informational boards.

All unsafe conditions/hazards are corrected and tracked in two ways: 1) JMR system and 2) Health and Safety Non-Conformance Report (NCR). After the investigation is completed, root cause determined and corrective actions identified, a JMR is written by the employee, supervisor, safety team member or Health and Safety personnel. The JMR will describe the necessary correction to eliminate the hazard. These JMR's are submitted to the maintenance department who will schedule their employees time to correct these issues. JMR's with a safety priority are usually performed on an immediate basis. The originator of the JMR will keep a copy for his/her records. A copy goes to the maintenance department employee performing the work and when completed is sent back to the originator. The originator will review the work for completeness, removal of hazard and then sign off on work performed.

Health and Safety also has a Non-Conformance Report that can track unsafe conditions and follow up to corrective actions, since not all hazardous conditions require a maintenance fix. If unsafe conditions, deviations from OSHA standards or other regulatory standards are noted by an employee, safety team member or Health and Safety department personnel, it is documented and reported to Health and Safety. If Health and Safety deems the issue to be a deviation from company policy or compliance issue, then a NCR is generated and forwarded to the appropriate department for corrective actions. The monthly Safety Team tours/inspections are also reviewed by Health and Safety personnel for potential non-conformances. All non-conformances are logged into a tracking system and monitored weekly for completion by the Health and Safety Manager and/or Safety Technician. When the corrective action/recommendation is completed, it is then noted on the log and the item is closed out and si gned off by Health and Safety and Supervisor of the appropriate department.

Attachment EE - Non-Conformance Report (NCR)
Attachment FF - Non-Conformance Log (sample)
Attachment GG - Job Maintenance Request (JMR)

6. Accident Investigation

All accidents are investigated in a timely manner. Usually within the first 24 hours an initial accident investigation has been performed with preliminary findings sent to the Health and Safety Office via e-mail or written reports. All supervisors and Accident Investigation Team members have received accident investigation training by Zurich-NA Loss Prevention Group. They are equipped with accident investigation tools (i.e. cameras, clipboards, tape measures, etc.) to help facilitate the investigation.

When an accident occurs, Health and Safety Department personnel are to be notified. Notification takes place either via telephone or radio during work hours. During off hour shifts, notification is done by telephone calls to Health and Safety personnel's home or mobile phone and if no answer, then a paging system is used. Health and Safety personnel will decide on how complex/formal an investigation needs to take place.

If the accident resulted in injury, the occupational health personnel are notified and are sent immediately to treat the injured worker; or the employee will be sent to the Health and Safety Office or may be triaged to the appropriate outside medical personnel. The area may be blocked/roped off until deemed safe and the initial investigation has taken place, for example, taking pictures, obtaining measurements, etc. If the accident involves a piece of equipment, hand tool, etc then it is immediately locked out until what caused the injury can be determined. All employees are removed. Witnesses are identified and are interviewed separately by a member of the Accident Investigation Team. Health and Safety personnel are the only employees to authorize the re-energization of equipment post accident. The formal report of the accident, root cause determination, findings and recommendations are typically completed within one week. The report is sent to the appropriate departm ent heads for review and comment.

As a result of an accident/injury investigation, all corrective actions are followed up via the use of the Non-Conformance Report and or the JMR system as mentioned previously. When the action is complete the department head and Health and Safety personnel review and verify adequacy of correction and then sign off. The results are disseminated to all affected employees including union representatives.

Attachment HH - Accident Report
Attachment II - Incident Report

7. Pattern Analysis

Ward/ACP Manufacturing currently input all safety and health program data into the software program call "Occupational Health Manager". This software allows us to generate reports and analyze data in any manner that is necessary. By putting in certain parameters (dates, departments, types of injuries, mechanism of injuries, etc), the Health and Safety personnel are able to retrieve and analyze data that is meaningful to the end user. We also track injury information by utilizing our workers compensation loss runs provided to us by Zurich-North America.

These reports are distributed to end users such as company physicians, supervisors, safety team/core team members, plant managers and executive staff. The information generated from these reports are used for supervisor evaluations, year to year comparisons of injury reduction, weekly monitoring of injuries by department, ergonomic analysis, hazard analysis, etc. Monthly departmental reports are provided to supervisors at the monthly safety talks which in turn are relayed to the hourly workforce during their safety talks.

D. Hazard Prevention and Control

1. Professional Expertise

Health and Safety expertise is provided by an on-site staff consisting of a departmental manager who has obtained the Advanced Safety Certificate. He is supported by two (2) safety technicians (one of which is also a registered nurse). The Manager and the technicians have varying degrees of certified training such as; fall protection, OSHA 501, NIOSH-approved Spirometry (Approval #101), National Safety Council courses, 14001 Auditors, Ergonomic training, etc. Along with the safety technicians, there is a registered nurse on staff to help identify workplace injuries, ergonomic risk factors, treat workplace injuries and help serve as a consultant on the various plant ergonomic committees.

There is also an abundance of outside personnel that Ward/ACP Manufacturing request to come on-site on a frequent basis to conduct workplace inspections to identify possible hazards that are present. Zurich-NA performs loss prevention tours/inspections of all facilities annually and more often if necessary. A certified industrial hygienist is consulted to come on-site and perform annual samplings of environmental hazards and compare to the recommended standards. We currently attempt to adhere to the ACGIH TLV's. Zurich also supplies us with a Certified Ergonomist who will help identify potential hazards and make recommendations for control measures that should be implemented. Auditors from insurance companies representing Hitachi review policies and procedures. They also review facilities for potential loss of business due to items such as fire and security.

We have certified job evaluators, who are employees of Laurel Health Systems and/or Susquehanna Health System, who come on-site and perform Job Demand Analyses (JDA's) to determine physical requirements of the job. Their report indicates any physical hazards that might be present and recommends methods to eliminate or reduce those hazards. We also have physician offices located approximately 1-2 miles from all of our production facilities to help treat, triage any worker. Local Emergency Medical Services (EMS) groups are less than 3 miles away to help control any environment hazards/spills we may have along with our on-site teams.

2. Safety and Health Rules

All employees and contractors receive a copy of the safety rules, codes of conduct, and disciplinary policy during their orientation phase. We have several Health and Safety, and emergency preparedness documents that are reviewed periodically. If any changes are necessary, these changes are communicated to all employees via their monthly safety talks. The policies are prepared by Health and Safety/Human Resources Department personnel, then reviewed at the Executive level and approved by signature. All Safety and Health policies meet or exceed current regulatory requirements.

Any violation of a Health and Safety rule usually follows a course of progressive discipline that entails verbal warning, written warning, then suspension/termination. Ward/ACP Manufacturing has placed such an emphasis on safety that it is written into the CBA that safety violations can result in immediate termination.

We also believe in recognizing our employees for safe behaviors/suggestions. If an individual or group of employees recognizes an existing hazard and helps develop, implement and evaluate that control they will be rewarded with a small token (shirt, hat, coffee mug) from our Company store. We also have a more formalized safety incentive plan that rewards employees if their plant can go 30 days without a recordable injury. If this occurs, they are provided with a lunch/dinner in their department. Prizes of greater value for milestones are outlined in the Safety Incentive Matrix.

Attachment JJ - Safety Incentive Matrix

3. Personal Protective Equipment
The requirements for the use of personal protective equipment are identified through a hazard analysis performed by safety teams, reviewed by supervisors and certified by Health and Safety personnel. PPE requirements are documented in several different documents: JSA's, Safe work procedures, accompanying matrix to PPE policy, One Point Lessons, etc. The formalized personal protective equipment program is documented in Ward policy number 02.810.21 and ACP policy number 02.471.21. PPE requirements are also documented in the Hearing Conservation program (02.810.09 / 02.471.09), Respiratory program (02.810.23 / 02.471.32) and prescription Safety Glass Program (02.810.31 / 02.471.31). Employees are instructed annually by Health and Safety personnel, supervisors and outside testing groups (Mid State Occupational Health, MOST Healthcare).

Ward Manufacturing, Inc and ACP Manufacturing Company, LLC provide all necessary protective equipment for the safe completion of the employee's job tasks. We provide a subsidy for the purchase of safety shoes. Enforcement of the proper use, maintenance, and care of PPE is primarily the responsibility of the supervisor.

Any/All contractors or subcontractors are required to comply with the personal protective equipment requirements of Ward/ACP Manufacturing.

Respirators are used in various parts of the operations. The maintenance, care use and training elements are covered under our Respiratory Protection Program. The written program is attached to the application.

4. Emergency Preparedness

Ward Manufacturing, Inc/ACP Manufacturing Company LLC's Facility Evacuation Plan (02.810.03 / 02.471.03) identifies all foreseeable contingencies that could occur including:

• Severe weather
• Bomb threat
• Fire
• Hazardous material spill

Attachment KK - Facility Evacuation Plans

The equipment necessary to respond to each of these emergencies is located either on-site or at the local Fire Department, which is located approximately 1 mile from the plant. The local fire department provides fire suppression, rescue and advanced life support capability. All guard posts/offices are equipped with a NOAA weather radio and are monitoring any weather related warnings that are broadcast. The emergency evacuation plan lists the steps that need to be taken and the notifications that are required to be made in the event of an emergency.

We have had the opportunity to conduct actual evacuation as the result of a bomb threat and these are documented in the Health and Safety office. Supervisors do conduct department drills when time permits. Evacuation maps are posted throughout the facilities and are listed on the intranet for employee access. All employees are trained on the Emergency Evacuation Plan annually. We have also conducted on-site fire extinguisher training for salaried employees. In training our Spill Team members, mock spill drills have been performed to help prepare for an actual emergency.

5. Preventative Maintenance

Our safety team members conduct monthly inspections of fire extinguishers and fire blankets, and replace them as needed. Industrial trucks are inspected daily by each operator prior to the start of his/her shift. The operator completes a daily checklist and, if a defect is noted, a job maintenance request (JMR) is submitted. These checklists are submitted to the Health and Safety Department daily and follow up is performed on whether the defect was corrected or not. Preventative maintenance on our manufacturing machines is performed at various intervals (daily, weekly, monthly, annually, etc) dependent upon machine usage. The PM system is scheduled and tracked via a software-based system called I-Maintenance. When a JMR is submitted, the submitter must identify the category of maintenance problem i.e. safety, production, miscellaneous, etc. and each has a numerical rating that would indicate the priority. Rating used is a 1 - 10 scale, the higher the number, the grea ter the priority that this needs to be fixed immediately.

6. Medical Programs

Ward/ACP Manufacturing recognizes the need for prompt treatment of both work and non-work related injuries and emergencies. We have employees trained as first responders and/or Emergency Medical Technicians (EMT's) which are available on all 3 shifts at their respective locations. We currently have three American Red Cross certified instructors who have trained all supervisors in CPR/AED at all five plants. We have 11 AED's located throughout the five plants and office complexes.

Ward/ACP has an on-site clinic in which all injuries are treated and triaged accordingly. We staff the clinics with two RN's and an MD who is available on an as needed emergency basis. There are physician offices within 1 - 2 miles of all of our facilities if the need arises for injured workers to be evaluated. Our clinic is staffed from 8:00a.m. - 4:30p.m., Monday through Friday. All Health and Safety personnel carry pagers so that they can be accessed at all times.

Our Occupational Health Nurses are located within the same building as the Safety Professionals which allows for a good deal of information sharing. In conjunction with Safety Inspections, Industrial Hygiene (IH) Surveys, Audits conducted by safety team members, the Health group has input on any health concerns, medical surveillance programs and control methods that may be necessary.

Any employee who is injured at work is immediately evaluated by the on-site occupational health personnel, who promptly notify the safety personnel of any concerns. Injured employees are required to submit to an accident investigation and complete an illness/injury report. This report is reviewed by the occupational health employee who inputs the data into our tracking software (OHM). They will analyze this data and notify the Health and Safety Manager of any trends.

In 2005, Ward/ACP recognized the benefits of a formalized wellness program and opened the programs to all employees. The wellness programs consist of Weight Watchers, Health Risk Assessments (HRA's), reduced fitness center memberships, smoking cessation, walking programs, etc. These programs are the responsibility of the Health and Safety Department.

Specific programs implemented to protect employee health include:

• Hearing Conservation Program: Ward/ACP Manufacturing has implemented a noise control and hearing conservation program which complies with OSHA 29 CFR 1910.95. The program includes noise hazard evaluations by internal and external personnel, use of noise control methods (sound dampening, curtains, lining metal bins, etc), evaluation of effectiveness of Hearing conservation methods via annual testing and review of the annual data.
• Respiratory Program: The program's primary objective is to prevent atmospheric contamination caused by breathing air contaminated with harmful dusts, fogs, mists, gases, smokes, sprays, or vapors. This objective shall be accomplished by accepted engineering control measures where possible. The alternate protection measures shall be by the use of personal protective equipment.
• Pulmonary Function: Testing is conducted on employees in the metal castings facilities as a prophylactic measure.
• Hazard Communication: Our parent company Hitachi LTD is deeply involved in environmental concerns. We are constantly reviewing products that are environmental and user friendly. The goal of Hitachi LTD is to use as many "green" products as possible.
• Lockout / Tagout: The purpose of this program is to ensure that before an employee performs any servicing or maintenance on machinery or equipment, where the unexpected energizing, start up or release of any type of energy could occur and cause injury, the machinery or equipment will be rendered safe to work on by being locked out or tagged out.
• Ergonomics: Each of our five plants have their own ergonomic teams that meet as needed to address issues that result from repetitious job tasks. These committees are comprised of hourly employees, Health and Safety consultants, and engineers to address issues that have been recognized by individual employees, Occupational Health personnel, outside personnel, etc.
• Bloodborne Pathogens: Ward/ACP has implemented a bloodborne pathogen protection program in accordance with 29 CFR 1910.1030. This program applies primarily to our first responder team members and our on-site medical personnel since they are the most likely to be exposed to the hazard.
• The Ward/ACP Manufacturing Health and Safety Manual covers the Company's occupational safety and health programs in detail.

E. Safety and Health Training

Training is an integral part of our system. It begins with new employees receiving an orientation class. Prior to the new employee beginning work they are required to attend an orientation at Health and Safety. Items discussed are such things as lockout/tagout, hazard communication, facility evacuation, personal protective equipment, hearing protection, accident and incident reporting, etc. Each attendant receives a safety handbook, which is his/hers to keep. The employee receives specific training by their respective supervisor once they report to their department. Each employee is required to attend monthly safety talks, except for July and December. The talks are developed by the Health and Safety personnel and topics include facility evacuation, lockout/tagout, hazard communication, personal protective equipment, fire emergencies, hearing conservation plus other topics including wellness, environmental and home safety. Specialized training include programs pertaini ng to spill containment/cleanup, confined spaces, lift truck and aerial lift operations, electrical hazards, and SAFESTART, which is a behavior based program.

To maintain interest and assure that topics are current, courses are constantly updated. We also utilize outside trainers with specific specialties to present programs. An example of this type of training would be the electrical safety program. We utilize an instructor from Penn State University to present training. He instructs on items such as NFPA 70E, understanding voltage and amps, circuitry, PLC's, etc. Other examples of contracted training are spill training, which is based on 29CFR 1910.120, and confined spaces training. We also train our safety teams to understand the safety system by utilizing the OSHA 10 hour course, accident investigation and ergonomics to name a few. The records for training activities are maintained in Health and Safety. In order to assure that the employee understands topics presented, we use a number of methods to demonstrate retention. Many topics are presented with written tests required, practical applications such as lift truck op eration, or through auditing of the work area. If, through the auditing process, an incident or a process is changed employees will be retrained or updated.

Our supervisors and managers receive training on a number of topics. They have attended classes by the National Safety Council Safety Leadership for Supervisors. They are involved in monthly safety talks and specialized training programs such as the electrical program. They also receive training on how to manage and cope with employees. This training, although it is not directly related to safety, is vital in our safety system. The training allows the supervisors to understand and lead employees in safety issues. Some of these programs are coaching skill for leaders, techniques for problem-solving and decision making.

F. Statements of Commitment

Hitachi Metals Automotive Components USA LLC's (HMAC) Statement of Management Commitment to Participation in the Voluntary Protection Program

The HMAC management is committed to providing a safe and healthful work environment for all of our employees. As part of our ongoing safety and health effort, HMAC are committed to complying with the goals, objectives and requirements of the OSHA Voluntary Protection Program and ultimately achieving and maintaining Star Worksite designation.

We, the management of HMAC, agree that:

• All employees, including newly hired employees and contractor employees when they reach the site, will have the VPP explained to them, including employee rights under the program and under the OSHA Act;
• All hazards discovered by employee notification, self-inspections, an OSHA on-site review, accident investigations, process hazard reviews, annual evaluations, or any other means of reporting, investigation, or analysis will be corrected in a timely manner, with interim protection provided as necessary;
• If employees are given health and safety duties as part of our safety and health program, we will ensure that those employees will be protected from discriminatory actions resulting from their carrying out such duties;
• Employees will have access to the results of self-inspections and accident investigations upon request.

We agree to provide the following information for OSHA review on-site:

• Written safety and health programs;
• Any agreements between management and collective bargaining agent(s) concerning the functions of any joint labor-management safety and health committee and its organization and any other employee involvement in the safety and health program;
• Any other data necessary to evaluate the achievement of VPP goals.

We will retain these records until OSHA communicates its decision regarding initial VPP participation. We will also retain comparable records for the period of VPP participation to be covered by each subsequent evaluation until OSHA communicates its decision regarding continued approval.

We will provide OSHA each year by February 15th our injury incidence and lost workday case numbers and rates, hours worked, and estimated average employment for the past full fiscal year. We will also provide a copy of the most recent annual evaluation of the site's safety and health programs.

We understand that we may withdraw our participation at any time or for any reason should we so desire.

Osamu Daimoto
President / CEO

Attachment LL - Union Statement of Commitment

For more information contact:
Pete Guidi
President & CEO
Ward Manufacturing
117 Gulick Street
Blossburg, PA 16912-0009
570-638-2131 (v)
570-638-3358 (f)

WARD MANUFACTURING AND HMAC(L) RECEIVE RECOGNITION FOR SAFETY

Blossburg, PA (November 2008)... More than 40 dignitaries, local officials and invited guests attended the ceremonies recognizing Ward Manufacturing and Hitachi Metals Automotive Components, USA, LLC (HMAC- Lawrenceville) achievement of OSHA's VPP Star Site award.

The Voluntary Protection Program (VPP) promotes effective worksite-based safety and health. Approval into VPP is OSHA's official recognition of the outstanding efforts of employers and employees who have achieved exemplary occupational safety and health. It is the most prestigious level OSHA can bestow upon a company.

Of the more than 7.5 million registered companies nationwide, OSHA has designated just over 2,000 as VPP Star Sites, making Ward and HMAC(L) two foundries in a very exclusive program to receive this honorable recognition.

"This award is truly a testament to the dedication and commitment of our employees who adhere to the strict guidelines established by OSHA's safety council," stated Bill Williams, Vice President of Human Resources for Ward Manufacturing and HMAC, Lawrenceville. "While it is a monumental achievement for our organization, we will continue to lead the foundry industry in safety expectations."

Ward Manufacturing, located in Blossburg, PA, manufactures and distributes a wide range of malleable and cast iron pipe fittings, and the newly introduced "WARDFLEX" system. HMAC, located in Lawrenceville, PA, is a state-of-the-art metal casting facility producing world-class quality ductile iron. Both Ward Manufacturing and HMAC(L) fall under the Hitachi Metals America corporate umbrella.

For more information about Ward Manufacturing or HMAC, visit their websites at www.wardmfg.com or www.acpmfg.com.

I am sending copies of the VPP award letters under separate cover to Catherine. [Note from Catherine: Please contact me if you wish to see these award letters.]