1 SCOPE
1.1 Applicability
This Global Manufacturing Principles policy addresses the emergency planning requirements for facilities making Mattel branded products.
1.2 Purpose
It is the purpose of this document to establish policy, provide instructions, and set forth the basic principles to be followed to assure all components manufactured, assembled, packaged, or distributed by a facility owned and operated by Mattel, a vendor or a subcontractor has labor management systems for emergency planning that are acceptable to Mattel Global Manufacturing Principles
1.3 Definitions (Words that are defined as italicized and bolded once per section)
Combustible – Classification of substances that will burn. The classification is based on flash point, and liquids with a flash point at or above 37.8C (100F) are considered combustible.
Fit Test – A test to assess the adequacy of respirator fit
Flammable Liquid – A liquid with a flash point below 37.8C (100F).
Lock- A lock is one with one unique key issued to the authorized employee only. No master key shall be made. Lost keys will require the lock to be removed with a bolt cutter with EHS authorization using Appendix C for documentation.
Spill – The release or discharge of a substance into the environment which can cause or is likely to cause an adverse effect (e.g. pollution).
2 PERFORMANCE REQUIREMENTS
2.1 Fire Prevention
2.1.1 The facility has a written Fire Safety Prevention Program, which addresses the following elements:
2.1.1.1 A list of the major workplace fire hazards, a description of the potential ignition sources, and a description of the control equipment or processes, such as the proper handling and storage procedures that are followed to prevent fires;
2.1.1.2 Names or job titles of personnel responsible for maintenance of fire protection equipment (e.g., fire extinguishers, hoses, inspection control valves, etc.);
2.1.1.3 A list of personnel who are trained in the use of fire extinguishers and fire hoses;
2.1.1.4 A documented schedule for the maintenance department to regularly and properly maintain fire protection equipment; and
2.1.1.5 A housekeeping procedure that describes the way the facility manages the storage of combustible materials and the way that aisles and exit ways are maintained clear and free of obstructions.
2.1.2 If the facility requires any employee to use fire extinguishers and hoses, those personnel receive annual training.
2.1.2.1 The training includes the general principles of fire extinguisher and hose use and the hazards involved in incipient stage fire fighting.
2.1.3 The facility has a Fire Protection Impairment Procedure.
2.1.3.1 The facility utilizes a Fire Protection Impairment Notification Form and retains the completed form for a minimum of one year.
2.1.3.2 The facility provides a fire watch (e.g., guard patrol) for the area when a fire protection system is out of service.
2.1.4 If a facility has a fire brigade, the following elements are required:
2.1.4.1 There is a documented basic organizational structure outlining the functions of the members.
2.1.4.2 Fire brigade members are initially provided 24 hours of training on the following topics with refresher training provided annually.
2.1.4.2.1 Basic chemistry of fire;
2.1.4.2.2 Personal Protective Equipment;
2.1.4.2.3 Extinguishing agents that will be used at the facility;
2.1.4.2.4 Tools and equipment to fight the fire; and
2.1.4.2.5 Special hazards at the facility, such as storage and use of flammable liquids to which they may be exposed during the fire.
2.1.4.3 On-going training for fire brigade members is required at least quarterly (two hours each quarter) and may include, but is not limited to, drills and refresher subjects of initial training.
2.1.4.4 The fire brigade has appropriate PPE for at least ten members that includes the following:
2.1.4.4.1 Foot and leg protection;
2.1.4.4.2 Body protection;
2.1.4.4.3 Hand protection;
2.1.4.4.4 Head, eye, and face protection; and
2.1.4.4.5 Respiratory protection devices.
2.1.4.4.5.1 Approved pressure demand self-contained breathing apparatus (SCBA) with full-facepiece, or with approved helmet, is provided to and worn by members while fighting the fire or in the vicinity of smoke.
2.1.4.4.5.2 The facility follows the requirements under the Respiratory Protection standard regarding: a written program, training, medical evaluation, fit testing, and inspection, maintenance, and care.
2.1.5 Fire Prevention Systems are inspected and documented according to the frequency provided in Table V.
2.1.5.1 Documentation of the inspections and testing are maintained for a minimum of one year.
2.1.5.2 Documentation for specific system includes:
2.1.5.2.1 A list of sprinkler control valves including: valve location, area controlled, whether it is open, shut, locked, or sealed; and
2.1.5.2.2 A list of fire extinguishers, fire hoses, and emergency lighting.
2.1.5.2.2.1 For fire extinguishers, the list includes: location, type, maintenance date, and hydrostatic testing date.
2.1.5.2.2.2 For fire hoses, the list includes: location and maintenance date.
2.1.5.2.2.3 For emergency lighting, the list includes: location, type of energy source, date of installation, and maintenance date.
2.1.6 Electrical Systems are inspected and documented according to the frequency provided in Table VI.
2.1.6.1 Documentation of inspections and testing is maintained for a minimum of one year.
2.1.7 Smoking areas are designated and marked.
2.1.7.1 "No Smoking" signs are required in all areas that have flammable materials, in the battery changing and charging area, and in storage and use locations of gas cylinders.
2.1.8 Fire extinguishers are adequately installed and easily accessible.
2.1.8.1 In areas of flammable liquids, extinguishers are mounted not more than 15 meters (50 feet) apart;
2.1.8.2 In areas of non-flammable liquids, such as office areas, extinguishers are mounted not more than 23 meters (75 feet) apart;
2.1.8.3 Extinguishers are appropriate for the intended material;
2.1.8.4 Extinguishers are installed not less than 1 meter (3.2 feet) high from the working ground but not more than 1.4 meters (4.5 feet); and
2.1.8.5 Extinguishers do not weigh more than 11.3 kg (25 pounds), unless on a trolley.
2.1.9 Material is not stacked closer than 45 centimeters (18 inches) to fire sprinklers.
2.2 Emergency Response Plan
2.2.1 The facility has a written emergency response plan that addresses building evacuation, fire and explosion, natural disasters, a chemical release, and medical treatment.
2.2.1.1 For all emergencies, the plan includes the following elements:
2.2.1.1.1 The roles and responsibilities for persons involved in the evacuation process;
2.2.1.1.2 The method for reporting an evacuation;
2.2.1.1.3 Names of persons to be contacted for information; and
2.2.1.1.4 Training for all persons who have a role in the process.
2.2.1.2 For evacuation, the plan includes the following additional elements:
2.2.1.2.1 Escape procedures and route assignments;
2.2.1.2.2 Procedures for employees who remain to operate critical facility operations; and
2.2.1.2.3 Employee accounting system following an emergency evacuation.
2.2.1.3 For chemical releases, the plan includes the following additional elements:
2.2.1.3.1 An evaluation for spill potential in all areas where chemicals are stored or used;
2.2.1.3.2 The procedure for dealing with the spill and the necessary spill cleanup material; and
2.2.1.3.3 Training for personnel based on the level of chemical exposure.
2.2.2 Awareness training is conducted annually for all employees. Emergency Response Team leaders receive specific training relating to their roles and responsibilities once every six months.
2.2.3 A fire alarm is installed in the facility.
2.2.3.1 The fire alarm can be heard throughout the facility.
2.2.3.2 The system may be manual.
2.2.4 Evacuation drills are conducted and documented once every 12 months on each shift at all facilities, including the dormitories.
2.2.4.1 At locations where annual turnover is greater than 30%, two drills are conducted every 12 months per shift.
2.2.4.2 All employees evacuate the building within five minutes for buildings without sprinklers and 10 minutes for buildings with sprinklers.
2.2.5 Diagrams showing directions of evacuation are posted within working areas, dormitories, and canteens.
2.2.6 Emergency phone numbers are posted and accessible in all areas of the facility.
2.3 Aisles and Exits
2.3.1 Emergency egress routes are unobstructed and at least 91 cm (36 inches) wide.
2.3.2 Aisles are clear and free from obstruction.
2.3.3 Nothing is stored against or under fire doors at any time.
2.3.4 Emergency exit doors are posted with a sign that can be read at 31 meters (100 feet) at any time.
2.3.5 Emergency exit doors are free from locks, hasps, chains, dead bolts or other locking device, even if a key is provided to use for unlocking the exit door.
2.3.6 Emergency exit doors can be opened from the direction of travel, without the use of any special knowledge or effort.
2.3.7 Emergency exits are located 76 meters (250 feet) or less in a building with sprinklers or 60 meters (200 feet) or less in a building without sprinklers from any point in the facility.
2.3.8 Exit signs have an arrow indicating the direction of the exit door in situations where more than one door is present.
2.3.9 All doors that have the appearance of being an exit have a sign that reads "Not An Exit" or other identification.
3 PRODUCT INTEGRITY ALIGNMENT
3.1 Please refer to related GQMPs for Product Integrity to ensure adherence to corporate responsibility policy between GMP and Product Integrity. The GQMPs are designed to mutually influence and reinforce each other and take into account the different levels of policy content.
4 REFERENCES
4.1 REFERENCED DOCUMENTS
4.1.1 GMP Standards: Management Systems
4.1.2 ICTI Care Code of Business Practices (2009 Edition