8.5 - EH & S System Document

SCOPE

The requirements established by this specification apply, as per the date of implementation, to all new parts, new sub assemblies and new products supplied to any member of the Tenneco EU organisation, unless explicitly specified by the engineering requirements and drawings. This exception will only be valid if signed for approval by the EH&S responsible for engineering and each manufacturing site's EH&S Coordinator.

This specification replaces all existing documents until this day and is understood to be valid for all companies and sites owned by or under the direction of Tenneco EU.

The scope of this specification is to inform suppliers to the Tenneco Europe Organisation (hereinafter referred as Tenneco EU), its personnel or contractors, of restrictions pertaining to certain substances which, by regulation or by Tenneco EU's directives, shall be restricted in or excluded from parts, products, chemicals, materials, equipment, machinery and/or toolings, hereinafter referred to as "materiel", supplied to Tenneco EU. It supplements, but does not supersede the responsibility of each supplier to comply with laws and regulations for the receiving Tenneco EU locations.

PURPOSE

The Tenneco EU organisation insists upon it's personnel, subcontractors and suppliers to eliminate or at least strongly minimise any possible harm or negative effect caused by the use of materiel to it's employees, the community , the environment and its production system.

All materiel specified in this procedure are to be banned from production systems and products or materiel delivered to Tenneco Europe as they cause nuisance, risk and/or damage to people, manufacturing processes and the environment. The aim for this procedure is to both eliminate or strongly reduce the health & safety risk and the environmental impact caused by the use of these products.

As this procedure will not cover all possible situations, it is expected from all EH&S site coordinators to evaluate the situation and take the appropriate decision in regard with the spirit of this procedure. Each derogation from this procedure will have to investigated, approved in writing and filed within the EH&S department (using the document as attached in section "Additional Information")

DEFINITIONS USED WITHIN THE DOCUMENT

"Non dimensional" materiel = materiel whose shape is determined by their packaging, such as liquids or sludges) are submitted to an approval by the site EH&S organisation prior to first delivery. This also includes any sample or trial run.

"Dimensional" materials = materials having a pre-formed shape, such as a tube or a plate) are basically considered as "articles" and, in general, exempted from detailed toxicology clearance requirements if it can be reasonably anticipated to release substances hazardous to health or the environment during processing activities, in normal use or eventual disposal.

An exception on the dimensional parts however relates to products applied, for any reason , on or in the product itself and which are supposed to only have a temporary function ( ie. anti-corrosion oil, draw bench soap on tubes ...). These products will also be submitted to the EH&S department for approval prior to the first supply and as such be submitted to the "non-dimensional" materiel specification.

RESPONSIBILITY

Responsible for Implementation
EH&S Coordinator

Responsible for Application
EH&S Coordinator

Responsible for Disciplinary Actions
EH&S Business Unit

SUPPLIERS RESPONSIBILITY

Prior to making any change in the properties, composition, construction, colour, processing or labelling of the materiel originally approved under this specification, the supplier shall notify his / her contact person within the Tenneco EU organisation which will assist the supplier in submitting the new product for approval by the EH&S department and notify all relevant internal contacts of this change.

Supplier, upon request, shall provide the composition (chemical identification of each constituent and its proportion by weight) of material supplied or proposed to be supplied and all EH&S data or guidance to the requesting Tenneco EU EH&S department.

Supplier, upon request, shall disclose information for assessment of disposal, internal or external treatment, if the materiel constituents are anticipated to be released into air, water or soil, or require special / additional operations or notifications to personnel or government

All materiel shall be supplied in compliance with the regulations on substance registration, notification of new chemicals, packaging, labelling and transport requirements which are in place in the Tenneco EU locations where the materiel are supplied.

Materiel containing substances which have been identified as having any carcinogenic, mutagenic, reproductive toxicity, ecotoxicity or sensitising properties (see definitions) by testing or human experience, shall not be supplied nor submitted without prior notification to and written acknowledgement of the site's EH&S department who will also inform the Tenneco EU EH&S responsible.

Biocides or herbicides shall never be supplied nor used without prior notification to and written acknowledgement of the site's EH&S department

"APPROVAL FOR USE" REQUESTER

Every person, intending to use, order, prescribe the use of or intending to introduce any materiel , product or chemical into any area or operation in the site, has to check if he/she complies with this Standard. Whether or not any classified (= materiel that can be reasonably estimated to cause nuisance to the user or the environment) material is listed within this Standard, the "Approval Document" (see Section "Additional Information") shall be completed by the responsible person prior to the introduction, and the document shall submitted to the EH&S department for evaluation .

Whenever a materiel is accepted under "Restricted Use" the requester shall assure that all indicate preventive measures will be installed, applied and maintained during the time period this product will be used on the site.

PROHIBITED PRODUCTS

Prohibited Products version 2003.pdf

POTENTIAL EXCEPTIONS

(C) Use is submitted to this procedure as from a percent weight in materiel (always submit MSDS to both plant doctor and EH&S coordinator)
(B) Use is restricted in all materiel applications and only valid if written approval is obtained from local EH&S department
(A) Use is restricted or prohibited in all materiel applications and only valid if written approval is obtained from both the Tenneco EU EH&S department and the local EH&S department  

Substance

Restriction Class

Biocides

B

Bis (chloromethyl) ether forming substances

A

Cadmium and Cadmium compounds

B

Carcinogens

C 

Chlorofluorocarbons (CFC's) and other ozone depleting agents

A 

Chromium and Chromium compounds Chromium (+VI)

A

Ecotoxicants

C

Endangered species (products of )

B

Halogenated Aliphatic Hydrocarbons

A

Halons

A 

Lead and Lead compounds

B 

Materiel containing, manufactured or treated with HCFC's

A 

Materiel containing, manufactured or treated with CHC's

A 

Methyl Bromide

B 

Mercury and Mercury compounds

A 

Mixtures of nitrites,amines and/or amides

B 

Mutagens

A 

Nickel and Nickel compounds

A 

Reproductive toxicants

C 

Tributyl Tin compounds

C 

Tris (2,3) dibromopropyl) phosphate

A 

Tris (aziridinyl) phosphinoxide

A 

Vinyl chloride monomer

B