OEM Supplier Quality Bulletin 2011

OEM SUPPLIER QUALITY BULLETIN 2011 PPG Industries ______TABLE OF CONTENTS: Page

1. BACKGROUND 2

2. BULLETIN DISTRIBUTION AND COMMUNICATION – PPG’S EXPECTATIONS 2

3. CONTAMINATION AND CRATERS 3

4. MATERIALS REGISTRATION PROCESS 4

5. SILICONE-FREE OPERATIONS AND MAINTENANCE 5

6. EQUIPMENT CLEANING (DE-BUG PROCEDURE) 5

7. CONTAINER CLEANLINESS STANDARDS 5

8. TANK WAGON REQUIREMENTS 6

9. CHANGE NOTIFICATION AND APPROVAL PROCESS (CNAP) 7

10. PPG ON-SITE ASSESSMENTS 8

11. RAW MATERIAL CERTIFICATE OF ANALYSIS REQUIREMENTS 8

12. CONTACT INFORMATION 8

APPENDIX I – ATTACHMENTS 9

APPENDIX II – SUPPLIER QUALITY BULLETIN REVISION HISTORY 10

PPG 0c336c0344ccfb44bb88eac08dca01a6.doc Revision Date: Aug 4, 2011 Page 1 of 10 OEM SUPPLIER QUALITY BULLETIN 2011 PPG Industries ______1. BACKGROUND PPG Industries, Inc., a global and diversified producer of Coatings, Chemicals and Glass, is committed to providing products and services to our customers that fully meet their present and future requirements. PPG’s suppliers are a critical strategic resource in meeting this customer commitment. PPG requires suppliers to have an effective Quality System. The basis for PPG’s quality system requirements is the Quality System Requirements ISO/TS16949 developed in coordination with the Automotive Industry Action Group (AIAG). This standard is based upon the ISO 9000 series standard. PPG has adopted ISO/TS16949 as the framework for the basic quality systems required for all suppliers of products and services. PPG requires the following: Suppliers to PPG’s ISO/TS 16949 registered facilities are encouraged to achieve ISO/TS 16949, but must achieve third party registration to ISO 9001:2000.

Supplier assessments to ISO/TS 16949 by the OEM Customer, an OEM Customer-approved second party or an accredited third party registrar will be recognized by PPG as supplier quality audits.

2. Bulletin Distribution and Communication – PPG’s Expectations This communication is intended to highlight and reinforce specific quality requirements applicable to all suppliers of raw materials to PPG coatings manufacturing facilities.

Recipients of this package must disseminate this information within their organization to the appropriate managers in Maintenance, Production and Quality Control. If there are any barriers to ensuring full compliance, these must be communicated to PPG.

Suppliers to PPG coatings facilities must also educate and manage their employees, suppliers, container suppliers, contractors, sub-contractors, toll manufacturers, etc. in the subject matter at hand. Annual training is recommended.

PPG has training materials available to support initiatives in this area, posted on our Supplier Portal, https://buyat.ppg.com/suppliernetwork/frmSNWebPortal.asp.

The requirements outlined in this document relate to controlling potential contaminants from entering PPG’s processes and products and to managing change. It is crucial that you understand the integral role you play in preventing the potential causes of failures. PPG requires all suppliers to not use (1) any silicone or silicone containing materials, supplies or products, and (2) any materials, supplies or products rated as “FAIL or “NOT ACCEPTABLE” on the PPG Materials Registration List (MRL).

PPG 0c336c0344ccfb44bb88eac08dca01a6.doc Revision Date: Aug 4, 2011 Page 2 of 10 OEM SUPPLIER QUALITY BULLETIN 2011 PPG Industries ______3. CONTAMINANTS & CRATERS Keeping contaminants out of PPG’s coatings processes and products is one of the toughest challenges we face. One of the most costly failures of contaminated paint is the formation of craters. Formed and observed during the application process, craters are small bowl- shaped depressions in the paint film, often having raised rims. They are typically caused by low surface tension contaminants, such as silicone. Most craters are caused by liquids, either of a very viscous nature or adsorbed on a solid.

Common causes of craters include: ❑ Tank wagons, totes or drums that are contaminated due to prohibited prior contents or contaminated in the cleaning process. ❑ Foreign materials that contact the surface of the wet paint  oil droplets (from air lines, machinery), oven aerosols and drips, chain lubricants, overspray, dirt, fibers ❑ Substrate properties or contamination  oil, dirt, mold release agents ❑ Paint components or contamination additives (especially when poorly dissolved or dispersed), gel particles, contaminated raw materials, contaminated containers ❑ Personal Care products – almost all hand lotions contain silicone

The most aggressive contaminants are Silicones – e.g. Poly Di Methyl Siloxane (PDMS) Fluoro compounds – e.g. Teflon sealants Sulfonates – detergents and surfactants

Silicone represents the highest concern because silicone based compounds have increased in popularity due to the benefits in many products – lubricants, plastics, creams, lotions, etc.

It is important to understand that extremely minute quantities of crater-causing substances can be devastating. Air-borne concentrations of certain contaminants, such as silicone, in the low parts-per- million range have resulted in cratering!

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4. MATERIALS REGISTRATION LIST (MRL) One of PPG’s controls against the host of materials that can cause craters is our Materials Registration process. PPG’s coatings facilities have inventoried and crater-tested virtually all MRO (Maintenance, Repairs & Operations) materials that may come into contact with our manufacturing processes. The collective results of these tests are published on the Crater Materials Registration List (MRL). Items known to cause craters are either banned, or if no alternatives exist, strictly controlled in their use. New items entering our facilities are tested and then the results are added to the MRL. See Appendix I for copies of the Crater MRL for Suppliers and the Sample Testing Request form.

PPG requires that suppliers: ❑ Make all appropriate persons in their organization aware of PPG’s material registration process and ensure that they have access to PPG’s MRL. ❑ Implement a materials registration process and develop an internal list of approved materials that the organization is permitted to purchase. ❑ Avoid using materials that fail, or if no alternative exists, strictly control the use of, any items appearing as failures in PPG’s MRL. Almost all hand lotions contain silicone and should be banned from production. Silicone-free lotion should be made available for personnel in these areas. ❑ Identify materials used in their processes that do not appear on PPG’s MRL and arrange for the submission of a sample of said materials to PPG for crater testing. PPG will then advise the supplier of the results and coordinate any further actions deemed necessary. o Suppliers should contact their PPG Purchasing representative who will advise who and where samples should be forwarded for crater testing by PPG.

❑ Register new items entering their manufacturing facilities per the above requirements.

❑ Educate and manage their contractors, sub-contractors, etc. in the subject of potential crater-causing agents and material registration.

5. SILICONE FREE OPERATIONS AND MAINTENANCE It is important to conduct a self assessment of your site to check for any potential contamination of PPG’s raw material or container. This self assessment would include the review of maintenance materials, cleanliness of processing and cleaning equipment and all containers that could potentially touch PPG’s raw material.

New pre-lubricated valves have been the source of significant crater events. We recommend the purchase of only “dry” valves to prevent this kind of issue in the future. It is important to establish a maintenance purchasing policy that specifies that all valves purchased MUST be Silicone/Lubricant free. See Appendix I for the Silicone Free Valve Letter as an example of how to formalize compliance with your valve vendor(s).

6. EQUIPMENT CLEANING (DE-BUG PROCEDURE) Even if your vendor supplies “dry” valves that are free of silicone, it is important to ensure that new or modified equipment are properly cleaned before being placed into service. This applies to transfer lines, hoses, piping, manifolds, pumps, mixing blades, in-process containers/vessels and basically any equipment that directly or indirectly ‘touches your product’ throughout your process.

It is critical to clean all equipment and vessels appropriately to ensure that contaminants are removed. We refer to PPG’s recommended cleaning process as a ‘De-bug Procedure’. See Appendix I for a copy of our Equipment Cleaning and De-bug Procedure.

7. CONTAINER CLEANLINESS STANDARDS All containers and vessels used in our suppliers’ processes, not just those used for packaging and delivery to PPG, have been known to introduce crater-causing contaminants into our processes. These include drums, pails, tank wagons for shipping large bulk quantities, intermediary size containers such as totes and universal bin containers, blend hoppers, reaction tanks, bulk storage tanks or any container used for storage or transfer of materials used in the finished product that is shipped to PPG. Suppliers must ensure the cleanliness of all such containers prior to use.

Cleanliness controls, inspections and/or cleaning procedures, including standards of acceptable cleanliness, must be clearly defined and documented within the supplier’s organization and must also include appropriate consideration of error-proofing against crater-causing contaminants. Experience has taught us that certain previous contents, despite stringent cleaning of containers and transport vessels, will still pose a significant risk. PPG recommends the following methods to control contamination. ❑ Use new drums, pails etc. ❑ Use “Product Dedicated” tank wagons and totes

PPG 0c336c0344ccfb44bb88eac08dca01a6.doc Revision Date: Aug 4, 2011 Page 5 of 10 OEM SUPPLIER QUALITY BULLETIN 2011 PPG Industries ______❑ Control tank wagon and tote prior contents with an approved list of materials. PPG does NOT permit the use of re-conditioned and re-manufactured drums/pails. PPG’s drum/pail suppliers must test for cleanliness and report results for each shipment to ensure the cleanliness and integrity of their containers. As raw material suppliers to PPG OEM, we ask that you adopt the same approach with your container suppliers, regardless of the container being new or re-conditioned/re- manufactured. It is critical that you make your container suppliers aware of potential crater-causing concerns and materials.

Suppliers should have a process for identifying prior contents in tank wagons or in re-usable containers (e.g. totes). This information should be available to PPG and provided to us with each shipment. All suppliers of raw materials in tank wagons or in re-usable containers must ensure that the previous contents were not a prohibited material appearing on Prohibited Prior Contents Requirements list. In- process containers and vessels of all types should be controlled for previous contents as well. See Appendix I for a copy of our Prohibited Prior Contents Requirements.

8. TANK WAGON REQUIREMENTS Numerous crater and other contamination events have been traced to tank wagon deliveries where there were inadequate controls:

 Prohibited materials as prior loads

 Insufficient cleaning  New tank wagon put in service contaminated from fabrication process

Dedicated tank wagons are strongly recommended for bulk transport of solvents to PPG. It is very difficult to adequately clean a tank wagon for a solvent load that had prior contents of resin or any other viscous material. Despite stringent cleaning, the solvent will typically “re-wet” and strip small amounts of dried residue from the inside surface of the tank wagon. The re-wetted residue will then appear as gel particles throughout the entire load of solvent, resulting in a rejected load.

When a dedicated tank wagon is not possible for a PPG solvent shipment, the supplier must ensure that the prior contents are strictly controlled using PPG’s approved list of materials, Bulk Solvent Contents Requirements. Suppliers of ANY bulk raw material must ensure that the previous contents were not one of those appearing on PPG’s Prohibited Prior Contents Requirements list. See Appendix I for copies of our Bulk Solvent Prior Contents Requirements and Prohibited Prior Contents Requirements.

As stated in the previous section, suppliers should develop a process whereby the identification of prior contents is completely traceable and available to PPG. This information should be provided to us with each shipment. It follows naturally that controls also need to be applied to transfer lines, hoses, manifolds, pumps – any related equipment that ‘touches’ our product.

9. CHANGE NOTIFICATION AND APPROVAL PROCESS (CNAP) In addition to controlling contaminants, suppliers must have a system for controlling and managing change. A critical process within the supplier’s system of managing change is a mechanism for notifying PPG of any proposed changes no less than ninety days prior to the planned date of change in production. The typical quality clause in PPG’s standard Material Purchase Agreement reads similar to the following:

SELLER shall not change the composition, manufacturing location, or process used to produce the Material from that present when the Material was originally approved by BUYER, without BUYER's prior written consent.

The supplier must notify PPG if an intended change involves any of the following: ❑ Change in source of raw material from new or existing supplier

❑ Change in containers, such as from dedicated to non-dedicated tanks

❑ Revised parameters in the same process (e.g. changes to testing procedures, in-process or final product specifications, packaging, sequence of operations, processing equipment, etc.)

❑ Change in product composition or ingredient levels of the approved product

❑ Change from previously approved manufacturing site location

❑ Process or product technology new to the organization

❑ Change in filling such as new containers or a toll filling operation.

Suppliers should seek clarification from PPG if they are uncertain as to whether a planned change requires notification to and approval by PPG. These changes could potentially be expected to have an effect on the product characteristics, manufacturing process, appearance, processability, durability or regulatory compliance of our product.

Suppliers must complete the PPG Raw Material CNAP (Change Notification and Approval Process) Form and submit to their PPG Purchasing contact no less than ninety days prior to the planned change. Changes must not be implemented without written approval from PPG and approved changes must not affect PPG production.

See Appendix I for copies of our CNAP Instructions and CNAP form.

10. PPG ON-SITE ASSESSMENTS PPG may require suppliers to accommodate an on-site assessment of their manufacturing processes and quality management system. Such assessments serve as confirmation of a potential new or existing supplier’s conformance to PPG’s requirements. Suppliers must also be aware that some of PPG’s customers may decide to accompany PPG during an on-site supplier assessment.

PPG’s on-site quality assessment process typically involves a pre-assessment meeting with the supplier during which PPG requirements are reviewed and clarified. Prior to the pre-assessment meeting, suppliers are provided a copy of PPG’s Supplier Development Process (SDP) Audit Rating form and asked to rate their operations. This self-assessment, along with statistical data, specifications and performance issues are reviewed during pre-assessment meetings. Date(s) for the on-site assessment are then determined and coordinated as best as possible by the supplier such that PPG has an opportunity to observe the manufacturing (or portions thereof) of an actual PPG order.

PPG provides a rating at the end of the on-site assessment prior to departing, and shortly thereafter provides a detailed written report specifying any corrective action required by PPG. Written responses from the supplier are required for any corrective actions cited in the assessment report. For corrective actions deemed critical and difficult to assess remotely, PPG may elect to arrange a follow-up on-site visit to confirm implementation.

Suppliers must be aware of and strive to comply with all requirements as outlined in the SDP Audit Rating document.

PPG may also elect to conduct an on-site visit specifically to assess the supplier’s process for any potential contamination risks to PPG. In order to be proactive in this area, it is recommended that all suppliers should conduct a self- assessment using the Supplier Contamination Self Assessment Form. See Appendix I for copies of our SDP Audit Rating and Supplier Contamination Self Assessment Form.

11. RAW MATERIAL CERTIFICATE OF ANALYSIS (COA) REQUIREMENTS PPG requires COA's 24 hours in advance of the material receipt. This allows time to enter the COA into our system and resolve any issues before the material arrives. (We prefer email, but a FAX can also be accepted.) See Appendix I for a copy of our Raw Material Certificate of Analysis (COA) Requirements.

12. CONTACT INFORMATION If there are any questions or concerns regarding the implementation of the controls in this document, please contact Laurie Duffy in PPG Cleveland, email [email protected]

APPENDIX I – ATTACHMENTS

PPG - Crater Materials Registration List (MRL) PPG Crater Materials Registration List Aug 2011.xls

PPG Sample Testing Request Form PPG Sample Testing Request Form.doc

Silicone Free Valve Silicone Free Valve Letter (for maintenance purchasing) Letter.doc

PPG Equipment PPG Equipment Cleaning and De-Bug Procedure Cleaning and De-Bug Procedure.doc

PPG Bulk Solvent Prior Contents Requirements PPG Bulk Solvent Prior Contents Requirements.doc

PPG Prohibited Prior Prohibited- PPG Bulk Prior Contents Requirements Contents Requirements.doc

PPG CNAP (Change Notification and Approval Process) PPG CNAP Instructions Instructions.doc

PPG CNAP form.doc PPG CNAP (Change Notification and Approval Process) Form

PPG SDP (Supplier Development Process) Audit Rating – quality PPG SDP Quality assessment Audit Rating.doc

PPG Supplier PPG Supplier Contamination Self Assessment Contamination Self Assessment 1.doc

PPG Certificate of Analysis (COA) Requirements PPG Certificate of Analysis (COA) Requirements.doc

APPENDIX II – SUPPLIER BULLETIN REVISION HISTORY

2011 Updated attachments and added Sample Testing Request Form Edited wording, revised silicone and personal care product warnings Format changes, creation of Table of Contents, Appendix I for attachments and Appendix I for revision history Aug 4, 2011 Updated Material Registration list 2010 Updated the Maintenance Material Registration list Contact Information 2007-8 Additional silicone warnings Added additional recommendations for tank wagon “Prior content” control Added the solvent tank wagon prior contents requirements Added Raw Material COA requirements/Contacts Included a separate crater training presentation for employees and sub-suppliers

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