Policy


POLICY - ENVIRONMENTAL, HEALTH AND SAFETY
	L-3 Communications Corporate Headquarters
	Corporate Policy No. 005 Issued: April 19, 2004 Revision No. 2
	1.0	Policy
	L-3 Communications Corporation is committed to conducting operations and activities in a manner that provides and maintains safe and healthful working conditions, protects the environment and conserves natural resources. In meeting this commitment it is L-3 Communications’ policy that no employee shall engage in any conduct that violates any environmental, health or safety law or is otherwise inconsistent with the highest levels of corporate responsibility to the health and safety needs of our employees and the environmental needs of our communities. L-3 Communications Corporation is also committed to the continual improvement of its environmental management systems, its environmental, health and safety programs and to the prevention of pollution.
	2.0	Implementation
	Compliance with this Policy requires particular attention to the following:
			2.1	All L-3 Communications operations will be managed and operated in compliance with all applicable environmental, health and safety laws and regulations.
			2.2	L-3 Communications will not create unacceptable risks to the environment or to our employees and will minimize risk to the Company, its employees and the environment from previous existing and potential conditions.
			2.3	L-3 Communications will pursue opportunities to prevent pollution by minimizing the quantity and degree of hazard from chemicals used in or wastes resulting from its operations.
			2.4	L-3 Communications will incorporate environmental, health and safety considerations into its business decisions. Specifically, L-3 Communications will formally evaluate any new assembly or production processes to ensure that, to the extent feasible, such processes and the chemicals utilized therein minimize any environmental, health and safety risks. L-3 will evaluate the proposed acquisition or lease of any new facilities to ensure that, to the extent economically feasible, such facilities are free from environmental contamination. At a minimum, proposed new facilities where chemicals are expected to be used shall be the subject of a Phase I site assessment. L-3 Communications will explore, to the extent economically feasible, the use of Pollution Legal Liability insurance to mitigate the financial risks from site contamination of new and existing properties.
	3.0	Responsibilities
			3.1 Corporate
				3.1.1	Corporate EH&S will coordinate the availability of appropriate and effective environmental, health and safety training and awareness programs and shall arrange for the periodic audit of environmental, health and safety programs at each division. Corporate EH&S shall also approve any environmental, health or safety consultants or contractors proposed to be hired by any operating unit or by the Corporation. L-3 Communications will not lease or purchase any new real property without the approval of Corporate EH&S.
			3.2 Division Presidents
				3.2.1	Develop and implement environmental, health and safety programs to comply with this Policy.
				3.2.2	Designate a qualified Environmental, Health and Safety Coordinator to manage its environmental, health and safety programs. Each Coordinator will be responsible for designating an appropriately trained individual, located on-site at each of the division’s facilities, who will be responsible for ensuring compliance with the Policy.
				3.2.3	Assure the availability of adequate funds and time for training of relevant personnel.
				3.2.4	Incident Investigation: (a) Determine the facts regarding generation and release of pollutants from Division facilities and responsibly manage division affairs to minimize any adverse environmental impact; (b) Determine the facts and root cause regarding injuries, accidents, and employee chemical and radiation exposure at Division facilities and responsibly manage Division affairs to minimize any adverse health and safety impact.
				3.2.5	Prepare and implement action plans addressing each finding contained in any corporate environmental, health and safety audit.
				3.2.6	Comply with the requirements of the attached Environmental, Health and Safety Incident Reporting Matrix.
				3.2.7	Where customer requirements or national security needs poise unique problems, work with the customer to find solutions that will meet both the customer’s needs and the objectives of this Policy. However, customer requirements shall never justify the violation of any applicable environmental, health or safety law.
				3.2.8	Compliance with this Policy is to be well documented. A copy of this Policy shall be communicated to all employees.
			3.3 Environmental, Health and Safety Coordinators
				3.3.1	Each Environmental, Health and Safety Coordinator will be responsible for ensuring compliance with the Policy at their specific location(s).
				3.3.2	Environmental, Health and Safety Coordinators shall:
					3.3.2.1	Ensure that they receive adequate training and resources to remain fully informed of the laws, regulations and best practices applicable to their operations.
					3.3.2.2	Provide, or arrange for the provisions of all required environmental, health and safety training at each of their operating location(s).
					3.3.2.3	In connection with division management, including Human Resources management, enforce all environmental health and safety policies, practices and work rules.
					3.3.2.4	Formally approve, deny or conditionally approve any new chemical or process equipment proposed for purchase by their operating location(s).
					3.3.2.5	Investigate the root cause of any injury, accident, illness or near miss arising in the course of business operations.
					3.3.2.6	Ensure that the need for any capital or other improvements are promptly brought to the attention of the Division President, and, if positive response is not received, to the attention of the Corporate Vice President, Environmental, Health and Safety.
			3.4 Employees
				3.4.1	Compliance with this Policy is the responsibility of every employee and particularly those with supervisory responsibilities.
	David Sweet
	Vice President, Vice President, Environmental, Health and Safety

ENVIRONMENTAL, HEALTH AND SAFETY INCIDENT REPORTING MATRIX

Reportable Event	Time Frame	Reportable Method *
Advanced notice of a regulatory inspection	Same Day	T, E
Regulatory Inspection for which no notice was provided	24 Hours	T, E
Notice of violation, liability, penalty, directive or compliance requirement	4 Hours	E, F
Accidental spill or release with a reasonable potential of reaching soil or water (any amount), any accidental release of a volatile organic substance or highly toxic compound in excess of one gallon, or any other accidental spill or release of a liquid in excess of five gallons.	Immediate	T, E, Written Memorandum follow-up within 48 hours
Request for information from any governmental agency or third party about past disposal practices	24 Hours	E, F
Any event requiring reporting to a regulatory agency	Immediate	E, F
Complaint from a neighbor regarding odors, noise or environmental impairment	72 Hours	E, F
Any fatality on the premises (including visitors, contractors, employees, etc.)	Immediate	T, E
Any off-site employee fatality which may be work-related	Immediate	T, E
Any other injury or illness required to be reported to OSHA or to a State OSHA	6 Hours	T, E
Other serious incidents and near misses that had the potential to result in serious injury/illness (e.g., death, dismemberment, incapacitation, lost time, unconsciousness, hospitalization) or significant property damage (> $5,000 or requiring shut down of an operation for longer than 24 hours) including but not limited to: failure of a safety-related monitoring device or of a supplied air breathing apparatus; electrical shock, structural fire, explosions, failure of cranes, hoists and associated fixtures or slings, incidents involving forklifts that could have caused serious injury or property damage; incidents involving aerial /scissor lifts; Collapse of building, floor, wall, mezzanine scaffold or similar construction; or accidental generation of a high ionizing or non ionizing radiation field in an uncontrolled area where employees may have been exposed.	24 Hours	E, F
Any violation of work rules or safety policies resulting in the termination of an employee or the suspension without pay of an employee for a period of three days or more	4 Hours	T, E
* T= Telephone, E=Email, F=Fax

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