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DocuSign Envelope ID:813A5323-29B6-4DDD-A2B8-22B7F4A4A68C <br /> County of Orange, NC RFP#5183 <br /> Towards this end,the company is pursuing OSHA Voluntary Protection Program(VPP) status at <br /> several operating locations as well as researching the EPA's National Environmental <br /> Achievement Track Program for possible implementation at selected facilities in the United <br /> States. Our Reidsville,NC facility has one of the first facilities to obtain it VPP status. <br /> Regulatory Communications <br /> The company proactively reviews,researches, and manages regulatory developments. Specific <br /> sources of information include things such as the Bureau of National Affairs, RegScan,and <br /> CCOHS. Proactive compliance is also achieved through review of state,provincial, and federal <br /> environmental compliance web sites. The process includes information gathering, regulatory <br /> analysis,determining the potential impact on the company's business and facilities, <br /> communication to the field personnel(e.g., compliance,operations,sales/marketing),providing <br /> feedback to the agencies, implementing new programs to meet any new requirements, and <br /> providing interpretive guidance on new regulations. Communication mechanisms include: <br /> Regulatory Alerts(summary analysis of proposed and fmaI rules);Newsletters("Readers <br /> Digest"version of regulatory initiatives);and communication from the field on state, provincial, <br /> and local issues. <br /> Internal Compliance Communications <br /> The senior managers of the Environmental Health&Safety Department conduct weekly <br /> conference calls with the functional managers and the corporate support staff. In addition to this, <br /> each health,safety, and compliance manager submits weekly status reports detailing significant <br /> issues. The company also utilizes an Incident Notification Program. With this program, <br /> significant incidents are communicated to the Vice President of Compliance via telephone or <br /> email within 15 minutes of occurrence. Follow-up reports are submitted within 48 hours. This <br /> information is then communicated to the senior management of the company including the <br /> General Counsel. <br /> On a monthly basis, a Regulatory Compliance Report is issued. This report,which includes data <br /> on Health&Safety incidents as well as key performance parameters within the environmental <br /> compliance group, is distributed to all senior managers of the company and provides a regular <br /> update on the company's performance in these critical areas. We are continuously evaluating <br /> new parameters for designation as key performance indicators. <br /> Internal Audit Program <br /> Striving for continuous improvement,the Corporate Environmental Health&Safety Audit <br /> Program also provides facility, functional, and senior management with current information on <br /> the compliance status of each Clean Harbors facility. Environmental Health&Safety staff <br /> members conduct the audits, and the objective is for each auditor to not audit a facility for which <br /> he/she is assigned and directly responsible. The scope of the audits includes evaluation of <br /> regulations (e.g.,RCRA,TSCA, CAA, CWA,OSHA, among others),Clean Harbors' operating <br /> permits, and company policies and procedures. Any deficiencies are captured in a Corrective <br /> Action Plan(CAP) and all items are tracked until each is completed. <br /> Company Confidential 18 www.cleanharbors.com <br /> 1 <br />