Grindwell Norton Ltd ENVIRONMENT, HEALTH & SAFETY GUIDELINE

EHS Requirements for New Products Revision Date Page No R0

9th August 06

Page 1 of 3

1. Objective: It is important to address the EHS impacts associated with the goods and products that a site manufactures and sells. It is essential that EHS aspects are taken in to account at the time of design of the product itself to have a better control on EHS impacts. This procedure provides broad guidelines about the EHS responsibilities and obligations of the GNO sites to address the EHS issues related to:a. Introduction of a new product b. Changing or modifying the product composition The guideline constitutes a part of the Management of Change (MOC) process for verifying the EHS impacts of the proposed change. 2. Scope This procedure is applicable to all the Grindwell Norton Sites. 3. Responsibilities The Concerned Divisional Head through his business manager / Plant manager of the entity aided by EHS Manager / Officer is responsible for implementing & maintaining this procedure. The procedure comes in to effect immediately. 1. It is the responsibility of the entity EHS Manager / Officer to assess the EHS impacts associated with the new products (or modifications to the products) being introduced. 2. The person proposing to modify the product composition or introduce a new product will initiate a Management of Change Form and send the same to the EHS manager / Officer for assessment and EHS clearance. 3. The EHS Manager / Officer will assess the EHS impacts associated with the proposal. For recommending the control measures, etc., the EHS Manager / Officer will seek information related to the composition of the product, its usage, handling, packing conditions, life cycle etc., all the observations and information will be recorded. The records will be maintained by the EHS Manager / Officer. 4. For carrying out the EHS Risk impact, the attached checklist will be used by the EHS Manager / Officer. This checklist outlines the minimum requirements to be complied with, which can be extended further by the EHS manager / Officer based on local specificities. 5. Additionally, the EHS impacts associated with the manufacture of the product, either inhouse or at any outsourced manufacturing location shall be carried out by the EHS Manager. 6. After completing the EHS assessment, the EHS Manager / officer will send the MOC form duly completed in all respects back to the originator. A copy of the same shall also be marked to the concerned divisional head, business manager & plant manager for information. 7. In case the proposed product contains substances that are detrimental to the EHS at any stage during its life cycle, the EHS Manager will notify the same in his remarks and recommends appropriate corrective measures / seek for substitution of the constituents substances. 8. It is mandatory for the entity to get the EHS clearance from its EHS Manager prior to the introduction of the product.

Grindwell Norton Ltd ENVIRONMENT, HEALTH & SAFETY GUIDELINE

EHS Requirements for New Products Revision Date Page No R0
9th August 06

Page 2 of 3

MANAGEMENT OF CHANGE - PRODUCTS

DATE PLANT SECTION MOC APPROVAL SOUGHT FOR DETAILS OF THE PRODUCT ORIGINATOR

NEW PRODUCT / MODIFICATION

RAW MATERIAL COMPOSITION

LIKELY END USAGE OF PRODUCT

PACKING MATERIALS USED

LIST OUT ANTICIPATED EHS ISSUES (IF ANY)

SIGNATURE OF THE ORGINATOR REMARKS OF EHS ASSESSMENT

SIGNATURE OF THE EHS MANAGER / OFFICER

Grindwell Norton Ltd ENVIRONMENT, HEALTH & SAFETY GUIDELINE

EHS Requirements for New Products Revision Date Page No R0
9th August 06

Page 3 of 3

Checklist for EHS Impact Assessment (This list outlines the minimum requirements. The individual site can extend the list further based on local specificities): S No 1 2 3 4 5 6 7 8 9 10 11 12 Particulars of EHS Assessment Whether the raw materials used for manufacture of the product contain CMR (Carcinogen, Mutagen & Toxic to reproduction) substances What is the nature of the CMR substance in the final product at the time of dispatch whether risk is still present What are the applications for the product What Environmental aspects impacts are associated with its usage What are the Health hazards and risks associated with the usage of the product What are the safety risks associated with the usage of the product What are the EHS impacts associated with the transport of the product from one place to another Potential emergency situations need to be anticipated for this query Handling of the products while loading / unloading any specific precautions need to be taken What are the environmental hazards associated with the disposal of the product after its life What kind of material is used for packing, How to dispose the packing material at the point of usage Whether any specific EHS instructions are necessary for the customers who use these products. Whether MSDS is required for the product Assessment