Responsible Care®

Safety Concerns – Dust Explosion Hazards

Durez HES Policy

Product Risk Assessment

Responsible Care®

Durez Corporation, as a member of the American Chemistry Council, is committed to the tenets of Responsible Care®. As a member of the American Chemistry Council, we have embraced Responsible Care as a company-wide program. It is actively practiced across all areas of our organization, and it is the responsibility of every Durez employee. As a part of this commitment, the initiative, Responsible Care Management System (RCMS) or our Health, Environment and Safety Management System (HESMS) is being implemented in our US manufacturing operations. With this implementation, eventually it becomes ingrained into the every-day functions and activities of the Corporation. This initiative, replacing the old Codes of Management Practices will become a process of our management system for environment, health and safety. This process ensures continuous improvement in our environmental, health, and safety programs that will yield overall successful HES performance in the Corporation. The elements of the Health, Environment and Safety (HES) Management System and how they will benefit HES performance are:

Policy & Leadership

Planning

Durez Corporation has implemented a plan that fulfills the HES policy. This plan consists of the identification and assessment of all relevant regulations; evaluate the product, process and distribution for risks and the identification and assessment of employee and community concerns about HES. From this evaluation, Durez has set priorities and goals for performance improvement and identifying resource needs associated with these programs.

Implementation, Operations & Accountability

Durez Corporation has established and is maintaining a documented HES Management System. As a part of the implementation, operations and accountability of the HESMS, Durez continues to manage operations and products under the Responsible Care® Guiding Principles. Also, establish, document, and communicate responsibilities and accountabilities to meet initiative requirements. In conjunction with responsibilities and accountabilities, training needs have been identified and completed. To fulfill a key aspect of the HESMS, Durez has communicate to all stakeholders relevant risks and impacts consisting of human health, safety, security and the environment and plans for improving performance. Last, Durez will establish and maintain employee involvement in the development, communication and implementation of the HESMS.

Performance Measurement, Corrective and Preventative Action

Durez Corporation is using performance measurement, corrective and preventative actions to demonstrate our commitment to improving HES and evaluate our overall performance in HES meeting goals, objectives and targets. These measurements are being used to evaluate the organizations compliance with regulatory standards in the area of HES. Additionally, these results are periodically presented to senior management to determine whether HESMS has been properly implemented. Results from these measurements are communicated to all stakeholders relative to this information and post results on the American Chemistry Council’s, Responsible Care® metrics website for public access.

Management Review and Reporting

The Durez Corporation, at appropriate intervals, conducts reviews of the HESMS to ensure its continuing suitability. This review will be broad enough in scope to address the Responsible Care® dimensions of its activities, products or services.

In addition to the implementation of HESMS, Durez Corporation continues to participate and perform activities instilled by the Code of Management Practices consisting of:

Responsible Care at Work

Durez Manufacturing

Durez manufacturing sites actively participates in programs within our communities to educate and develop awareness of our role as environmental, health, and safety stewards.

Some of the programs that we are proud to have participated in:

• Plant open house and school tours
• Emergency Response drills with community agencies
• Member of local safety councils and Emergency Response Planning Committees
• Sponsorship of the Niagara Community Foundation - a group participating in environmental improvement projects

Product Development

Our Product Development process considers how new products or technologies can be designed and commercialized to remove or reduce risks to the environment, and the health and safety of the people who use or handle our products. The evaluation of raw materials and our products hazards and risks are evaluated every 3 years to ensure safety of our employees, our customers and the environment.

This initiative has resulted in a number of product "success stories":

• Lower volatile materials
• Lower dust containing products
• Water borne materials to replace solvent systems
• Manufacturing processes which reduce waste and/or consume less energy

Product Risk Assessment

Durez has established and implemented a system to characterize and manage product risk. Procedures have been implemented to identify and characterize risks for existing products, new products, and product changes. A summary of this process is outlined below:

Characterization and Managing Product Risk

• Each product has been evaluated to identify any physiochemical, ecological, or health effects.
• Using these criteria, we have screened our entire product line and prioritized it according to the highest risk ranking (handling and/or health).
• Based on this prioritization, a risk assessment of the entire Durez product line has been completed.
• These results have been reviewed for improvements or replacement of the products of most concern.
• Programs are in place to upgrade these products where possible and practical.

Each new product or product change will be evaluated under the same characterization process. This process will be repeated every three years; or upon the availability of new information, emerging health or environmental concerns, or regulatory policies.