CONTENTS

1. - Presentation and Objectives ......................................................... 3

2. - General outline of the approach ................................................... 4

3. - Frame of reference for Environment, Hygiene and Safety

(E/H/S) ........................................................................................... 5

3.1. - General principles .......................................................................................................... 5

3.2. - Environment, Hygiene and Safety (E/H/S) Policy ........................................................... 6

3.3. - Identification and planning ............................................................................................. 7

3.3.1. - Identification of environmental aspects , hazards and evaluation of risks ....................... 7
3.3.2.- Legal Requirements......................................................................................................... 8
3.3.3. - Internal Requirements ..................................................................................................... 8
3.3.4. - Objectives ........................................................................................................................ 8
3.3.5. - Environment, Hygiene and Safety (E/H/S) management programme .............................. 8

3.4. - Implementation and Functioning ..................................................................................... 9

3.4.1. - Structure and responsibility.............................................................................................. 9
3.4.2. - Awareness, Training and Competency ............................................................................ 9
3.4.3. - Information..................................................................................................................... 10
3.4.4. - Documentation and data management .......................................................................... 10
3.4.5. - Operational management .............................................................................................. 10
3.4.6. - Participation of the collaborators ................................................................................... 11
3.4.7. - Prevention of potential anomalies .................................................................................. 12
3.4.8. - Communication .............................................................................................................. 12
3.4.9. - Prevention of emergencies situations and reaction capability ........................................ 12

3.5 - Assessment and control ................................................................................................ 13

3.5.1. - Assessment and measurements .................................................................................... 13
3.5.2. - Handling anomalies ....................................................................................................... 14
3.5.3. - Records ......................................................................................................................... 14
3.5.4. - Self-diagnostic ............................................................................................................... 14
3.5.5. - Internal audits, crossed audits ....................................................................................... 14

3.6.- Reaction and adjustment actions ................................................................................... 15

3.6.1. - Management Review .................................................................................................... 15
3.6.2. - Continuous improvement of the E/H/S culture .............................................................. 15
1. - Presentation and Objectives

The Environment, Industrial Hygiene and Safety (E/H/S) Policy of the SAINT-GOBAIN Group is
founded on respect for people and the environment, which is an integral part of good economic
results.

The Group has set itself the following objectives :

• The continuation and expansion of its activities (production, distribution, trade) along with
a still more stringent control of its environmental impacts while supplying markets with
products having always improved performances.

• Moving towards zero accident, zero occupational disease, zero non-recovered waste and
keeping up to it.

• Tending to an integrated E/H/S approach as evidence of reinforced global comprehension

and better efficiency.

Hygiene and Safety objectives are backed up by the control of all unsafe situations and the obligation
to take into account the short, medium and long-term health and safety effects of activities
linked to processes and products.

In environmental terms, objectives are based, on the one hand, on reduced consumption of
natural resources (raw materials, energies …), reduction of waste, of dumping in natural
environments (air, water, ground), and of any other nuisance such as noise, odor … and on the
other hand, on the development of energy saving products and/or processes.

This document constitutes the frame of reference for Environment, Industrial Hygiene and
Safety (E/H/S) of the SAINT-GOBAIN Group.

Management* has been previously trained in E/H/S policy.

This frame of reference explains how to reach those objectives. In order to implement this frame of
reference, systems have to be drawn up and implemented with the participation of all the
collaborators, according to current situations and specific decisions in each Branch or Company. The
implementation of a continuous improvement process thus contributes to meet the requirements of the
frame of reference.

The frame of reference takes into account:

• set objectives;
• current practices in E/H/S matters;
• systems already enforced;
• international management standards in these three fields.

It specifies results to be reached and allows to acquire the E/H/S culture of the SAINT-GOBAIN
Group.

*
NB: Italics refer to definitions in the appendix.
2. - General outline of the approach

Group

Group Management
Branch Management

Division Management
Company Management
Site Management
 3. - Frame of reference for Environment,
Hygiene and Safety (E/H/S)

3.1. - General principles

Environment, Hygiene and Safety policy

Identification of environmental aspects

Improving
the E/H/S culture Identification of hazards and evaluation
of risks

Legal requirements
Management Internal requirements
review Objectives
E/H/S Management Programme

Structure and responsibility

Intern Audit, Awareness, Training and
Crossed audit Competency
Information
Self-diagnostic Documentation and data
management
Records Operational management
Participation of staff
Handling anomalies
Prevention of potential anomalies
Assessment and measurements Communication
Prevention of emergencies situations and reaction capability
3.2. - Environment, Hygiene and Safety (E/H/S) Policy

The management defines and draws up its policy, objectives and commitment regarding environment,
industrial hygiene and safety.

It fashions its own policy on the basis of the Group policy.

Site Management ensures that this policy is totally applicable and compatible with local requirements
and that, in addition :

• it is appropriate to the nature and extent of environmental impacts and risks regarding
safety and industrial hygiene on site ;

• it is understood, documented , implemented and maintained at every site level;

• it is communicated to all the collaborators;

• it is available to concerned parties ;

• it includes a commitment to continuous improvement in order to achieve sustainable

development while respecting the environment and in order to aim at and maintain
zero accident , zero occupational disease and zero non-recovered waste ;

• It allows, at all level, the appropriation of the E/H/S/ culture of the SAINT-GOBAIN Group ;

• it is periodically reviewed in order to ascertain that it is still relevant and appropriate to the
activities of the site.

The implementation of the EHS Policy and Process is declined by the delegation, division,
company, entity... this according to the level of responsibilities defined in each organization.
Thus the term ”site” employed in this frame of reference refers in most of the cases to an entity of the
"lowest organizational level " (ex: a plant factory, a distribution agency...), but in certain cases it must
be taken in the broad sense to hold account of the specificities of each organizations.
3.3. - Identification and planning
3.3.1. - Identification of environmental aspects , hazards and evaluation of risks

The site identifies the environmental aspects of its activities, products and services in order to
appraise which are likely to have significant environmental impacts.

The site assesses the risks concerning the collaborators, service providers, visitors, the
neighbourhood and the environment. To this end, the site :

• draws up the inventory of potential hazards and nuisances,

• makes a qualitative and quantitative assessment of exposures and risks,
• prioritizes risks using a reproducible method,
• determines a plan of action including objectives, time limits and means of control.
The site examines the possibility of eliminating hazards and risks, lessening risks and dealing with
residual risks, while privileging collective rather than individual protection.

The site draws up means of prevention and protection, through the implementation of a set of
coherent actions integrating technique, work organization and training.

The collaborators of the site have well-documented and updated risk analyses dealing with:

• phases of activity during normal, transitional or downgraded operation ,

• servicing and maintenance operations,
• occasional operations,
• outside site phases (operating at the customer’s facilities, sales areas…),
• production phases using products supplied by the customer,
• elimination phases of products,
• additional operations linked to the activities,
• environmental risks which must be considered within context, natural cycles and events
(low water, flood, earthquake…).
Indicators of management and operational performance are drawn up and set up.

During design studies (buildings, equipments, products), all parties operating in the lifetime of the
product or project are taken into account. A multidisciplinary team defines and validates E/H/S
requirements which are then integrated into the specifications. Before the beginning of operation, it is
verified that:

• all means of prevention and protection anticipated during study are effective and
sufficient ;
• E/H/S procedures are drawn up, circulated and explained.
E/H/S procedures are updated and implemented properly.
The management provides and sets up a permanent E/H/S watch, particularly in the scientific field in
order to identify hazards as soon as possible and take effective and appropriate measures.

The site management identifies concerned parties which are sent relevant information on the E/H/S
performances of the site.

3.3.2.- Legal Requirements

The site identifies EHS legal requirements applicable to its operation.

This information is up to date, and taken into account in the setting of the EHS management system
of the site.

The communication of legal requirements is organized by the site.

3.3.3. - Internal Requirements

The site identifies other applicable E/H/S requirements (best practices, Branch agreements, internal
regulations of the Group, etc.).

This information is up to date, and taken into account in the setting of the EHS management system
of the site.

The site communicates relevant information on those internal requirements to the collaborators and
concerned parties.

3.3.4. - Objectives

The site sets E/H/S objectives at all appropriate functions and levels.

The objectives are documented and consistent with the site policy, legal requirements and the
analyses of environmental aspects and risks.

Achievement of these objectives is measured with indicators defined beforehand.

3.3.5. - Environment, Hygiene and Safety (E/H/S) management programme

The site draws up an E/H/S management programme to reach previously defined objectives.

This programme appoints a person in charge of each concerned mission and level, and specifies the
resources committed and the time limits to meet the objectives.
3.4. - Implementation and Functioning
3.4.1. - Structure and responsibility

Roles, responsibilities, authority and relationships in E/H/S matters concerning all the collaborators
are defined, documented, distributed and circulated.

The site appoints one (or several) member(s) of Management to ensure that the implementation of the
E/H/S management system is in accordance with requirements and that it is in line with a continuous
improvement process and that the practices comply with it.

Prevention, Occupational Health and Environment functions are defined and their collaborators are
properly trained.

Responsibilities are formally shared between those services and hierarchical setup.

Staff representatives take part in the implementation of the E/H/S policy of the site.

The site management must bring into play all (human and financial) resources necessary to the
proper operation of the E/H/S Management System.

3.4.2. - Awareness, Training and Competency

The site identifies E/H/S awareness and training needs for all the collaborators. The training is an
essential part of an overall common E/H/S culture and must develop their involvement and their self-
evaluation capabilities in these fields. It is specially followed up and mainly deals with:

• training of managerial staff on E/H/S management system.

• training for identification of hazards, assessment and prioritization of risks, auditing of the
effectiveness of developed actions (process of risk management);

• awareness regarding detection and communication of anomalies;

• global E/H/S training of all the collaborators ;

• training at work place;

• specific training (accreditations, authorizations);

• training in the event of technological change;

• training for prevention of emergencies situations and reaction capability;

The collaborators are made aware of occupational risks and means of prevention and protection.

The collaborators training takes into account the different levels of responsibility, competency and
understanding.

Training is suited to the collaborators who are led to hold several jobs and functions in turn.

Knowledge checking systems are set up. Retraining periods are provided for. Permanent records are
kept.
Moreover, collaborators are made aware of E/H/S consequences of its activity and of beneficial effects
achieved through the improvement of their personal commitment ; specifically the acquisition and the
maintenance of the E/H/S/ culture are obtained through a daily and permanent training approach.

3.4.3. - Information

The site informs the collaborators about the risks and hazards linked to their activities and specifies
means of prevention and protection implemented and provided for.

All E/H/S documents and data intended for work places are available, accessible and understandable
to everyone.

They are updated when necessary.

This information must contribute to the development of the E/H/S culture.

3.4.4. - Documentation and data management

The E/H/S system is documented.

The site draws up and updates management procedures for all documents and data.

Documents and data are regularly reviewed, updated when necessary and approved by authorized
collaborators.

Updated versions are available at useful locations to ensure an efficient operation of the E/H/S
system.

Out-of-date versions are removed to avoid their being used.

Archived documents and data are properly identified.

An identified person within each site submitted to the Group Reporting fills out at defined frequency
the questionnaires his/her entity must fill.

3.4.5. - Operational management

Design – Modification

Files on design, plans for new installations and significant modifications are formally approved at
E/H/S level by a multidisciplinary team.

For any kind of project, an identification and assessment of E/H/S risks linked to processes, products,
and activities from cradle to grave is carried out in order to decide on proper equipment, organization
and use, along with associated operating instructions.

For any kind of modification made to existing activities, processes, installations or products, safety and
health protection levels are improved at work places along with environmental impacts.

Purchasing
Purchasing of hazardous substances and products goes through a specific procedure.
Before ordering products, materials and services, E/H/S requirements are defined and integrated into
the specifications.

The suppliers’ capacity to meet E/H/S requirements is verified.

Specific instructions are given for acceptance of purchases to check conformity to specifications.

Process management
It is verified that all due means of prevention and protection are efficient and adequate and that
working procedures are implemented.

Inventory of risks linked to traffic in the site, handling, storage, loading and conveyance is compiled
and corresponding means of prevention and protection are set up.

Maintenance, Servicing and Cleaning

Maintenance, servicing and clearing operations, defined and documented beforehand, are safely
implemented without leading to additional risks, especially for the collaborators, customers, suppliers,
visitors.

Those operations take into account environmental aspects, proper procedures being carried out.

Building sites / outside contractors

Before an operation is carried out, both sites and outside contractors provide reciprocal written
information on occupational and environmental risks linked to their joint activity, their interference and
on measures taken or to be taken.

The level of formality is in accordance with assessed risks.

Outside contractors contractually conform to the E/H/S rules of the site and operate in accordance
with regulation in force.

Their capacity to conform to the E/H/S policy and rules of the Group is checked.

Before the beginning of work on building site:

• specific working procedures are drawn up at E/H/S level,

• collaborators working on building site are trained,

• collaborators entering building site are informed of E/H/S risks and existing means of
controlling them.

During the work, existing procedures are regularly verified.

3.4.6. - Participation of the collaborators

All the collaborators integrates the E/H/S/ culture in their daily work activities.

Within the continuous improvement process, proposals and initiatives of collaborators are promoted
and taken into account ; the management reaction considers the risks nature and the achievement
delays.

Management audits are implemented by the whole management.

Self-audits are used by the collaborators.

3.4.7. - Prevention of potential anomalies

The prevention of potential anomalies is a priority.

Potential anomalies are detected by risk analysis, audit, management audit, self-audit and self-
diagnostic ; they are analyzed and corrected.

Statistics on potential anomalies are kept and used within continuous improvement programmes.

3.4.8. - Communication

The site Management is responsible for the contents, addresses and circulation procedures of E/H/S
information.

Communication within the site is organized to spread and develop daily work spirit at EHS level.

The site provides concerned parties with appropriate E/H/S/ information.

The management is trained for communication during crises.

In the event of accidents, communication is set up with concerned parties.

3.4.9. - Prevention of emergencies situations and reaction capability

Potential accident situation (collective risk) or emergencies cases are duly considered.

After an emergency, causes are analyzed and preventive actions are provided for.

The crisis management is duly considered and controlled. It is the same for the communication in
crisis management.

Their consequences in terms of E/H/S risks are assessed regarding the collaborators, concerned
population and environment.

Emergency plans are set up, circulated, explained and updated.

Training sessions are planned and set up. Lessons drawn from those sessions help to review the
emergency plans.
3.5 - Assessment and control

3.5.1. - Assessment and measurements

Technical and/or regulatory controls

The site identifies technical controls, in accordance with regulations and/or analyses of risks to be
enforced. It carries them out or has them carried out and keeps an account thereof.

The site identifies all necessary means and qualified collaborators to carry out controls and
maintenance. Control equipment is identified, controlled, calibrated, tested and maintained in order to
ensure its reliability.

The results of technical controls are properly reported and recorded. Corrective actions are initiated
when necessary. People in charge of the follow-up are duly appointed.

Assessment and follow-up of safety issues

The assessment and follow-up of accidents, incidents and unsafe situations are carried out to:

• analyze their immediate and remote causes,

• appraise the relevance and effectiveness of actions implemented to reduce risks.

Assessment and follow-up of health issues

The assessment and follow-up of the level of the collaborators exposure regarding all work constraints
and the effects on health and occupational diseases likely to occur are carried out to:

• analyze their immediate and remote causes,

• appraise the relevance and effectiveness of actions implemented to reduce risks.

A medical follow-up of consequences of exposure is drawn up. Indicators are chosen to assess the
conformity and effectiveness of medical follow-up.

Assessment and follow-up of environmental issues

The assessment and follow-up of the level of environmental impacts and hazardous situations as
regards environment are carried out to:

• analyze their immediate and remote causes,

• appraise the relevance and effectiveness of actions implemented to reduce risks.

Indicators of means

Indicators of means are drawn up to check the conformity of the system with E/H/S management
programme and requirements in force.
3.5.2. - Handling anomalies

Anomalies (accidents, incidents, unsafe situations and non-conformities) are dealt with in accordance
with specific procedures.

Risks brought about by such events are reported, recorded, analyzed and all previously designated
concerned people are informed of them.

Their analysis leads to the establishment of corrective and preventive actions for all identical
situations.

A competent person is appointed to set up corrective actions within a time limit set beforehand. The
effectiveness of corrective actions is checked.

3.5.3. - Records

The site draws up procedures of identification, filing and destruction of records linked to E/H/S
matters.

The specificities of the procedures of each domain are taken into account, especially with regard to
Health and industrial hygiene.

3.5.4. - Self-diagnostic

The site sets up audits to appraise the implementation and effectiveness of the E/H/S management
system.

The results of the self-diagnostic confirm, complete or correct initiated actions.

The site preserves the results of these self-diagnostics.

3.5.5. - Internal audits, crossed audits

The site sets up audits to appraise the implementation and effectiveness of the E/H/S management
system.

Those audits are pre-established, programmed and documented.

Auditors are trained, objective, impartial and remain independent from the audited service.

The results of the audit confirm, complete or correct initiated actions.

The detection of unsafe situations for collaborators and situations likely to cause environmental risks is
part and parcel of audits.

An audit report is drawn up for the site management who decide on actions to be taken. The site
management keeps a copy of this report.
3.6.- Reaction and adjustment actions

3.6.1. - Management Review

The existing E/H/S system with its performance and means indicators is examined at suitable intervals
(at least once a year ) by site management who make sure it remains continuously effective and
allows to acquire the E/H/S/ culture of the SAINT-GOBAIN Group.

E/H/S objectives, along with the EHS policy if necessary, are drawn up within an overall strategy of
continuous improvement. These objectives also deal with behaviour along with judgements and
decisions.

3.6.2. - Continuous improvement of the E/H/S culture

The site management defines and sets up indicators to follow up behaviours/judgements and
decisions.

Under the impetus of the E/H/S function, the analysis of anomalies comprises the
behaviour/judgements and decisions dimension.

Safety trainings systematically integrates behaviour/judgements and decisions aspects ; in particular,

management staff is competent for observing and assessing behaviours.