Document 06xNNvr9qyyNRz7ER09Qe2XRn

UNION CARBIDE PRODUCT SAFETY PROGRAM ^ U {r-j X4I9397 1 PLAINTIFF'S EXHIBIT 12/11/81 UC-4900 UNION CARBIDE CORPORATE POLICY PRODUCT SAFETY ISSUED 9/30/81 1. FURNISH CUSTOMERS AND USERS WITH RELIABLE PRODUCTS THAT IF USED, UTILIZING UNION CARBIDE'S PRODUCT SAFETY COMMUNICATIONS DO NOT INVOLVE UNREASONABLE RISK. 2. FURNISH CUSTOMERS WITH APPROPRIATE PRODUCT SAFETY COMMUNICATIONS. 3. REGULARLY REVIEW PRODUCT SAFETY INFORMATION AND, IF NECESSARY, EXPAND THE PRODUCT SAFETY INFORMATION AND, IF APPROPRIATE, MODIFY THE PRODUCT, MODIFY THE PRO DUCT DESIGN, AND/OR MODIFY THE PRODUCT SAFETY COMMUN ICATIONS. 4. COMPLY WITH ALL APPLICABLE GOVERNMENTAL LAWS, REGU LATIONS. 5. DOCUMENT IMPLEMENTATION OF ITEMS ONE THROUGH FOUR. 6. ESTABLISH AND MAKE KNOWN TO GOVERNMENTS, THE PUBLIC AND UNION CARBIDE PERSONNEL RESPONSIBLE POSITIONS ON PRODUCT SAFETY ISSUES. 7. SPEAK WITH ONE CONSISTENT VOICE. *Uu C0 7 2 12/11/81 DUTIES AND ROLES OF UNITED STATES COMPONENTS 1. END RESULT ACCOUNTABILITY FOR PRODUCT SAFETY. 2. LINE DUTY TO COMMUNICATE PRODUCT SAFETY IN FORMATION TO OTHER U.S. COMPONENTS AND AREA COMPANIES. 3. DUTY TO DEVELOP INTERNAL CONTROL SYSTEM TO ACHIEVE OBJECTIVES OF CORPORATE PRODUCT SAFETY POLICY. m '" u' ' 0p OJ Go X 419399 2A 12/11/81 DUTIES AND ROLES OF HS&EA RELATED TO U.S. COMPONENTS 1. LINE ROLE TO INFORM COMPONENTS OF THEIR DUTIES UNDER CORPORATE PRODUCT SAFETY POLICY, 2. COORDINATING ROLE TO ISSUE POLICIES a. TO IMPLEMENT CORPORATE PRODUCT SAFETY POLICY b. FOR RESPONSES OF COMPONENTS TO PRODUCT LIABILITY CLAIMS INCLUDING THE AUTHORITY TO APPROVE RESPONSES BEFORE THE FACT c. FOR INTERNAL CONTROL SYSTEMS OF COMPONENTS INCLUDING THE AUTHORITY TO APPROVE THE ADEQUACY OF THE COMPONENT INTERNAL CONTROL SYSTEM, | 3. DUTY AND AUTHORITY TO CONDUCT AUDITS FOR: a. ADEQUACY OF INTERNAL CONTROL SYSTEM. b. COMPLIANCE WITH CORPORATE PRODUCT SAFETY POLICIES I AND II c. COMPLIANCE WITH APPLICABLE LAWS, M ^ i> C 0 X 4 1 94 00 2B 12/11/81 DUTIES AND ROLES OF AREA COMPANIES 1. END RESULT ACCOUNTABILITY FOR PRODUCT SAFETY. 2. LINE DUTY TO COMMUNICATE PRODUCT SAFETY IN FORMATION TO U.S. COMPONENTS AND OTHER AREA COMPANIES. 3. DUTY TO DEVELOP MANAGEMENT SYSTEM. INCLUDING POLICIES AND AUDITS AND ACHIEVING OBJECTIVES OF CORPORATE PRODUCT SAFETY POLICY PATTERNED AFTER UCC SYSTEM. X 419^01 2C 12/11/81 DUTIES AND ROLES OF HS&EA RELATED TO AREA COMPANIES 1. COORDINATING ROLE WITH DUTY TO ISSUE POLICIES WHICH DEFINE THE REQUIREMENTS FOR AREA COMPANY MANAGEMENT SYSTEMS INCLUDING AUTHORITY TO APPROVE SYSTEMS. FOR ADEQUACY. 2. DUTY AND AUTHORITY TO CONDUCT AUDITS. .'A ^ u 7 U : X4m32 2D 12/11/81 CORPORATE PRODUCT SAFETY 1981 - 82 CATEGORY 1 PRODUCT SAFETY POLICY ESTABLISHED BY UCC MANAGEMENT COMMITTEE. FIRST DRAFT CORPORATE PRODUCT SAFETY MANUAL ISSUED. CORPORATE PRODUCT SAFETY MANUAL ISSUED 11 POLICIES AND A DRAFT POLICIES. CORPORATION ISSUED CATEGORY I PRODUCT SAFETY POLICY. INFORMAL INITIAL DIVISION REVIEWS STARTED. INFORMAL INITIAL REVIEWS SCHEDULED FOR COMPLETION. 7/81 A/81 8/81 9/81 9/81 8/82 X419403 1 i_> 7 U1 3 12/11/81 WHY PUSH PRODUCT SAFETY?? NEED 1. CORPORATION NEED TO COMPLY WITH LEGIS- LATED LAWS AND REGULATIONS. 2. CORPORATION DESIRE TO MINIMIZE DAMAGES OF INCREASING PRODUCT SAFETY LITIGATION. RESPONSE BY LEVEL I PRODUCT SAFETY POLICY ITEMS 4, 5, 6 S 7 ITEMS 1, 2, 3 ft 5 A w ;7G 4 2/26/82 PRODUCT SAFETY DEPARTMENT ORGANIZATION CATEGORY I POLICY LEGAL REouifperr HSSEA mm DIVISION IffUT GROUP PRODUCT SAFETY OmjNICATION "DUTY ID WARN" L. A. CRISORIO, ESQ. CORPORATE PRODUCT SAFETY GWUNICATION CCmiTTE REGULARLY REVIEW PRODUCT SAFETY INFORMATION "DUTY TO TEST" DR. R. H. HILTON AD HOC CORPORATE COmiTTEES COfPLY WITH LAWS AND REGULATIONS COMPLY DR. D. L. KEYWOCD CORPORATE PRODUCT SAFETY REGULATORY COmiTTEE ESTABLISH POSITIONS AND SPEAK WITH ONE VOICE NOTE DR. D. L. HEYVCOD CORPORATE PRODUCT SAFETY REGULATORY QJfllTTEE 70 X4I9405 5 12/11/81 PRODUCT SAFETY FWAG00JT POLICY amen lead responsible for developing ato maintaining management system to DO TIE FOLLOWING: 1. ASSIGN END-RESULT ACOOLNIABILITY. 2. PRCVIIE CRGANIZATICNAL OF COORDINATING. 3. DESIGNATE AN IfBIVIDUAL TO REPRESENT CCfTONT TO CORPORATE PRODUCT SAFETY OOWITTEE. A. IBCLOP CCPPGNENT POUCIES. 5. EDUCATE PERSONNEL TO DUTIES UNDER APPLICABLE LAWS AND CORPORATE PRO DUCT SAFETY POUCIES. 6. PRCV1EE FOR A REGULAR AIDIT. 7. CORRECT DEFICIENCIES. 8. DEVELOP PRODUCT SAFETY AfUUAL PLAN/BUDGET. 9. REPORT PROGRESS. 10. REPORT PRODUCT SAFETY EVENTS. 11. MANAGE PUBLIC RELATIONS FOR PRODUCT SAFETY ETERGENCIES. h 6 67 0 >'41 94 06 e 12/11/81 PRODUCT SAFETY amnicATioNS policies 1. precautionary labeling 2. MSDS 3. EXFBWENTAL MSDS A. SAFE PRACTICE AND SAFE USE LITERATURE 5. CBSEFVATION OF QUESTIONABLE PRACTICE IN NCN-UCC FACILITIES 6. CUSTOER REQUEST FOR WORKPLACE AIR MONITORING 7. OfONIC TEALTH HAZARDS LABELING - CARCINOGENS - DRAFT O/ X4 f 9^07 7 12/11/81 PRODUCT SAFETY INFORMATION REVIEW AND ACQUISITION 1. MAINTAIN FILES ON REQUIRED PRODUCT SAFETY INFORMATION a. ACUTE TOXICITY AND IRRITANCY B. SIGNIFICANT END-USE APPLICATIONS c. HEALTH HAZARDS FROM PRODUCT COMBUSTION, RE ACTION, ETC. D. HEALTH HAZARDS FROM PRODUCT FAILURE E. PRODUCT PARTITIONING BETWEEN AIR, WATER, SOIL, AND BIOTA F. SUMMARY OF INCIDENCES OF DAMAGE TO HEALTH OR ENVIRONMENT 2. EVERY A YEARS, FOR SIGNIFICANT RISK PRODUCTS, EVALUATE AND DOCUMENT THE NEED FOR ADDITIONAL INFORMATION SUCH AS: a. EPIDEMIOLOGY B. REPEATED DOSE TOXICITY SHORT AND LONG TERM (TERATOGENIC, CARCINOGENIC, REPRODUCTIVE, ETC.) c. PERSISTENCE, BIOACCUMULATION AND TOXICITY IN THE ENVIRONMENT >'<19408 8 TWC 1/26/82 PRODUCT SAFETY REGULATORY POUCTES 1. TSCA 8b - INVENTORY 2. TSCA 8e - SUBSTANTIAL RISK 3. TSCA 5a - FW /419409 ^U 9 12/11/81