Corporate Procedure Master

Corporate Procedure Master

Mohawk Industries, Inc.

Corporate Environmental

Title:New Chemical/Material Acquisition PolicyNo.10.5

Department:Environmental ServicesEffective:2/2018

Approved:Denise A. Wood, V.P.Corporate EnvironmentalPage:1of3

I.Purpose:

The purpose of this policy is to provide Mohawk Industries facilities and subsidiaries with the requirements regarding acquisition of new chemicals or materials.

II.Background:

The proper management of chemicals, whether as samples, raw materials, mixtures, or products involves numerous legal and regulatory issues for the facility and Mohawk Industries. Mohawk Industries is responsible for the proper management of all chemicals on its properties and ensuring compliance with the various regulations.

III.Scope:

This policy shall apply to all Mohawk Industries operations, which are subject to safety (OSHA), environmental (EPA), importation or transportation (DOT/Customs) regulations of the United States. This includes materials shipped from Mohawk Industries operations outside the United States to any U.S. location.

This policy shall apply to all chemicals (mixtures, liquids, solids, or gases), whether purchased or offered to Mohawk without charge, including samples.

This policy outlines the minimum requirements, which shall be implemented within each business unit and facility of Mohawk to ensure continued compliance with State and Federal regulatory requirements for the products, which are used or sold. This policy specifically applies to purchasing, research and development (R&D), manufacturing, maintenance, engineering, sales & marketing and transportation and logistics personnel at covered facilities.

IV.Policy:

All materials products imported, purchased or obtained as a sample by any person at a facility covered in Section III above, for use internally, as a sample/trial, for R&D and/or for resale, even if for direct resale, in the United States, shall comply with the following:

  1. Prior to import, purchase/contract or request for sample, a safety data sheet (SDS)in English and meeting the OSHA/GHS requirements shall be obtained and submitted in electronic format to Corporate Environmental, or their designee, for review and written approval. The SDSor supplemental documents from the manufacturer must clearly indicate the concentration of any SARA 313 chemicals, extremely hazardous substances (EHS), VOCs, hazardous air pollutants (HAPs) as defined by US EPA or other regulatory authority, or the presence of formaldehyde above 1 ppm. The necessary form to request approval for all new chemicals/materials can be found on the employee links tab on the MyMohawk home page under Environmental. Figure 1 provides the intended flow of this process.
  2. The requisitioner is responsible for maintaining copies of approved requests.
  3. For all chemicals to be used in those processes related to the production of any product, it is required that requester havethe manufacturer/supplier complete the additional Chemicals of Concern Evaluation Sheet.
  1. If the material is imported from outside the United States, Corporate Environmental shall verify that all components of the material are included in the Toxic Substance Control Act (TSCA) inventory list. Therefore, a complete (100%) ingredient listing will be required or a statement from the manufacturer that 100% of the ingredients are listed on the EPA’s TSCA inventory list.
  1. The manufacturer/supplier shall complete the TSCA Inventory form for the material for which approval is being requested or provide other evidence that 100% of the components are listed on the TSCA inventory.
  1. Corporate Environmental will review the data provided and approve or reject. A completed TSCA Letter will be issued by Corporate Environmental for the records of the requisitioner and/or for use with the importation documents.
  1. Upon approval of a new material, it shall be the responsibility of the requester to ensure that a copy of the SDS is provided to the site safety contact at the physical location where the material will be handled or used. Corporate Environmental shall input the safety data sheet into the MSDSonline SDS Management System, linking it to the site for which it has been approved.
  1. If additional sites desire to use an approved material, Corporate Environmental shall be contacted to link the facility with the material on the MSDSonline system.
  1. All labels of distributed products (commonly called sundry products) must be reviewed and approved for regulatory completeness prior to the shipment of the first sample, lot, batch or order. This review shall be facilitated by the Corporate Environmental.
  1. Any time a label changes, it shall be submitted for review.
  1. This is intended to ensure that specific labeling requirements are addressed and that all claims made on labels are substantiated with data.
  1. A copy of the SDS, in English and meeting the OSHA/GHS requirements for a safety data sheet shall accompany the first shipment in the U.S. annually to all customers of all chemical products sold or distributed by Mohawk, including 3rd party manufactured consumer goods.
  1. Copies of SDS’s for all hazardous materials (as defined by US DOT), including materials classified as ORM-D, must accompany all (100%) shipments, whether by Mohawk transportation or by common carrier. This is the responsibility of the shipping entity.
  1. It is the responsibility of the organization shipping materials classified by DOT as hazardous to obtain all training and certifications required by the Department of Transportation.

b. Corporate Environmental, in cooperation with the Corporate Safety team, will maintain a “master list” of all materials approved for purchase and use. This list will be the basis for determining if a material has been approved for purchase/use within Mohawk Industries U.S. locations, including but not limited to manufacturing, warehouse, office and R&D locations.

V.Compliance:

This policy shall be followed by all employees, including temporary or contract employees, at locations subject to the policy. Failure to comply with this policy can result in personnel action, up to and including termination.

This policy shall apply, until amended or replaced, in its entirety at Mohawk Industries Management’s discretion.

Form: FMSDSSPEC Revision: 10.5 Date: February 14, 2018

Figure 1

New Chemical/Material Acquisition Approval Flow Diagram

Form: FMSDSSPEC Revision: 10.5 Date: February 14, 2018

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