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l , OSHA - POST HEARING COMMENTS SPEAKER: Hoy Bohanon technician which fan-belt to take, because it saves a "double trip" from the maintenance shop to the area being maintained if the fan belt needs replacing. This type of "working smarter" and operational efficiency is typical in industry, however, a discrete audit trail would have to be created that breaks out tasks that only deal with Indoor Air Quality from the rest of maintenance work in order to prove that we operate our HVAC systems in a responsible manner to regulators and litigators. RJR will develop a separate "audit system" rather than submit` E,:isting documentation for review for two reasons. First, the current format is not easy for regulators to use. Second, we do not wish to provide information about non- HVAC maintenance operations to regulators: As our economy barrels from the industrial age to the information age, where employees are responsible for their own work and performance, the real burden of enforcement falls on the individual worker. In the case of RJR, all the empowered maintenance and operations workers know that the paper work required by this regulation is meaningless and that it is just another piece of the regulatory burden that is crushing our national economy and driving down their real wages. They understand that employers, who are not currently providing good indoor air quality, will probably not change their ways and that employers like RJR who do the right thing will continue to struggle in the world market-place under the crushing US burden of regulation. G17421REG•AFFlIAQI0SHA1PHG3.DOC/ BGL 10 of 10 8/30/95 4:35 PM

OSHA - POST HEARING COMMENTS APPENDIX A SPEAKER: Hoy Bohanon INTRODUCTION During RJR's testimony, there were numerous questions about Business Paper #6, "Bstimated Cost of Compliance with OSHA Proposed Regulations ". The following appendix include the text of Business Paper #6, followed by a detailed explanation of assumptions. G{7/7JiEGAFFW0105HA1PHGAPP.DGCI BGL I of 13 8/30/95 3:37 PM

OSHA Proposed Rule on Indoor Air Quality fL J. RPynolds Toba<xo Company CpMPUANOE TASKS .T~A.SK COMMENTS . ~- w_lReg&txu5~D4p•16o9e by au employees (LRFCQRDKEEPtNG Investigate new computer programs 1. Matntain mahntenanoe reoords. a. Retain reoord of inediation measures , 2. Maintain written ptan and reoords 8. Mairttaln writben feooafs of oomplaints and resolution 4. Retain reoords for at least8 years . 5. Reconis to be available to empioyees to examine ~ RJR FAGLRIES PUWNING 917991BARRY106HA-1JClS 814104 4:10 PM

, OSHA - POST HEARING COMMENTS SPEAKER: Hoy Bohanon ( Among other things, the OSHA proposed rule falls to consider several important issues: • The proposed regulation simply does not recognize the differences between company-owned and leased facilities. • OSHA's cost analysis fails to consider the number of leased facilities this proposed regulation will impact nationwide. • When considering multi-tenant office buildings with the vast number of distinct leases between landlords and tenants, administrative costs of the proposed rule will be greater than OSHA's estimate. • Other than litigation, there Is no prescribed means for settling disputes between landlords and tenants regarding administration and responsibility for indoor air quality programs under current leases. • There is no way for tenants, in non-industrial, multi-tenant buildings, to address indoor air quality problems caused by other tenants. The lack of consideration of the regulation on leased facilities clearly shows that regulators have not considered the full implications of their recommendations. This proposed OSHA regulation is a classic example of why regulation adds cost without value to American business, thereby compromising national competitiveness in the world-wide marketplace. 3. OSHA's analysis of productivity Improvements that would result from IAQ improvements Is seriously flawed. Evidence Indicates that productivity would decrease, rather than Increase, If the proposed rule takes effect. I • Studies have shown no connection between Improved air quality and Increased productivity. Dr. Ralph Goldman showed there is no correlation between improved comfort and productivity improvement in his paper "Productivity in the United States: A question of Capacity or Motivation?" published in the ASHRAE Transactions 1994. In his paper he stated, "In the 1970's (ASHRAE) supported a series of studies on the effects of climate control on productivity In a variety of settings. The results showed little relationship between improved comfort and increased productivity." G17421REG-AFFUA0IGSHAV'HC3.DOCf BGL 3 of 10 8/30/95 4:35 PM

OSHA - POST HEARING COMMENTS SPEAKER: Hoy Bohanon These post-hearing comments are submitted by Mr. Hoy Bohanon to (1) address questions that were raised during his testimony from January 17 through 19, 1995, and (2) to address a number of other issues that are raised by the proposed rule. During R.J. Reynolds efforts to answer these questions, a number of important points that OSHA should carefully consider became clear: 1. The proposed rule is unnecessary because good indoor air quality can be provided through market forces, rather than through regulation. 2. OSHA fails to consider the impact of the proposed rule on leased facilities. Among other things, the proposed rule puts employers In the untenable position of having responsibility for IAQ without having authority to control it. 3. OSHA's analysis of productivity improvements that would result from IAQ improvements is seriously flawed. Evidence indicates that productivity would decrease, rather than Increase, if the proposed rule takes effect. 4. OSHA and the Private Sector assess productivity in markedly different ways. As a result, the proposed rule raises serious questions about whether the "benefits" are actually worth the "cost." 5. IAQ regulation will increase "lost time" and "lost work-days" due to employee complaints for which the cause will not always be clear and observable to, or correctable by, the employer. 6. It will be extremely difficult to fairly enforce the proposed rule. IAQ complaints will undoubtedly generate costs to employers for paperwork-related citations, where IAQ problems might not actually exist. In addition, these post-hearing comments answer some specific questions about R.J. Reynolds testimony and provide a detailed look at RJR's operations that elucidates a number of points that have relevance -- in terms of operational problems and economic impact --- to other companies and industries. Specifically, these comments discuss: A. RJR's continuing commitment to good indoor air quality. B. The detailed impact of the proposed rule on companies, such as R.J. Reynolds Tobacco Company, that have employees working in a variety of facility types and diverse work settings. C. The potential difficulties and costs involved in providing an adequate audit trail for compliance with the proposed rule for companies with computerized maintenance systems. G:1742UtEG-AFF1IA0105HAWHC.3.DOG BGL I of 10 8/30N5 4:35 PM

OSHA - POST HEARING COMMENTS SPEAKER: Hoy Bohanon dioxide levels return to normal. The employee is still dis-satisfied because their symptoms have not diminished. It could be that psycho-social factors are influencing the employee. The employee is screaming that the air is preventing them from doing their job. What should the employer do? The second illustration is exactly the same as the first, except all tests show that the indoor air is in compliance with all specifications. The individual who instigated the investigations is not satisfied. Soon other employees begin complaining of the same symptoms. Keeping in mind that Dr. Gots stated that 70 percent of the IAQ cases he investigated involved a "non-problem" or non- identifiable problem, what should an employer to do? 6. It will be extremely difficult to fairly enforce the proposed rule. IAQ complaints will undoubtedly generate costs to employers for paperwork-reiated citations, where IAQ problems might not actually exist. On-the-job injuries are readily recognizable by hourly workers, corporate staff, medical and safety staff, regulators and so on. Poor indoor air quality effects each employee differently. Where indoor air quality differs from other OSHA regulations is that, each employee has a different perception of the quality of the air, and perceptions are influenced by factors like job stress, job satisfaction, ergonomics and work area lighting.. (list provided by Dr. Ronald E. Gots, M.D. Ph.D. and Edward Sowinski, Ph.D. in the article "Putting lndoorAir Quality In Its Place" published In Occupational Hazards, October 1992. A cure for poor Indoor air quality on the job is to send the employee home. IAQ regulation will no doubt increase productive time lost from work, . One person sifting next to another, with same air quality will have different reactions to the air. The Building Owners and Managers Association (BOMA) number one tenant complaint is that the air is too hot or cold. With IAQ regulation, one person will go home because of a headache. How will that affect LTA ? . How many excused absences does OSHA project under the proposed rule? How will work absences due to poor IAQ be tabulated? . What will be the impact of lost work time, due to IAQ, on productivity? Has this been factored into the appropriate cost/ benefit analysis? Dr. Ronald Gots, in the aforementioned article says in 70 percent of IAQ cases he has investigated, the indoor air concerns involved either a "non-problem" or "nonidentifiabie" problem.. Gots went on to state that people dissatisfied with their jobs or suffering from stress, perceive that there is something wrong with G:V421REG-AFFUAQIGSHAPHC3.DOG BGL 7 of 10 8/30/95 4:35 PM

OSHA - POST HEARING COMMENTS SPEAKER: Hoy Bohanon the air. So there you have it. We have a regulation requiring massive record keeping for indoor air, where major symptoms are lethargy or headaches, and even though a national expert finds either a non-problem or a non-identifiable problem, we as facility managers will be required to "fix the problem", send employees home with full pay, or no doubt face fines. INFORMATION AFsdUT R.J. REYNOLDS' OPERATIONS A. RJR's continuing commitment to good Indoor air quality. Over the years, RJR has shown a continued commitment to providing a good work environment for employees, starting with the Reynolds Building, which was named "Building of the Year" by the National Association of Architects in 1929. In fact, RJR has received seven architectural and engineering awards for various renovations of the Reynolds Building. RJR's commitment to providing a good work environment extends to indoor air quality. RJR has always complied with, or exceeded, ASHRAE standards that applied during design or construction of our facilities. Our qualified personnel have always provided adequate ventilation, maintained our operating systems and have been respectful of occupant needs during renovations. RJR engineers have been leaders in the field of indoor air quality, publishing many articles in professional publications, as well as speaking to various professional groups across the nation. One article "Operations and Maintenance Procedures and Resultant Air Quality for One 630,000-ft2 Office Building" by H.R. Bohanon, P.E. and S. C. Curl, P.E., and published in the conference proceedings of IAQ 93, organized by American Society of Heating, Refrigerating and Air-Conditioning Engineers is one example of a publication by company employees. This article was submitted as part of RJR's Comments addressing the proposed rules. During RJR's testimony, an assumption of parameters of the test of the 630,000 ft2 office building, was not fully understood by OSHA's staff. RJR would like to clarify that the slab to slab height of the building in question is 14'-0". B. The detailed impact of the proposed rule on companies, such as R.J. Reynolds Tobacco Company, that have employees working in a variety of facility types and diverse work settings. R. J. Reynolds Tobacco Company (RJR) owns and operates manufacturing, processing, storage, distribution and office buildings in North Carolina. There are also regional and local sales offices throughout the country, which are wholly leased. The 372 RJR-owned facilities plus the 171 Field Sales facilities represent a total of 543 facilities operated in the United States. All Field Sales G1742YtEG-AFFUAG1oSHA+PHG9.DGG BGL 8 of 10 8/30/95 4:35 PM

OSHA - POST HEARING COMMENTS SPEAKER: Hoy Bohanon GENERAL ISSUES 1. The proposed rule is unnecessary because good indoor air quality can be provided through market forces, rather than through regulation. Good Indoor Air Quality is good facility management. Companies who do not provide good IAQ, risk losing workers or tenants, as IAQ is factored into an individual's assessment of a total compensation. Companies in leased space have the free market to aid them in obtaining good indoor air'y`uaiity. HVAC service levels typically have been spelled out in leases. If a tenant does not like the product, he or she can relocate to a new, leased facility. In the recent buyers market, that featured free rent of a year or more, along with developers buying out previous leases, a tenant could relocate virtually at will. Now that IAQ is an issue, lease provisions can fairly address the issue to the market place. The free market works. Burdensome indoor air quality regulations are not needed. a recent IFMA survey showed 75% of facility manager listed indoor air quality as a major concern. RJR and many facility managers are already providing good indoor air quality. Good indoor air quality can be provided through market forces rather than through regulation. 2. OSHA faiis to consider the Impact of the proposed rule on leased facilities. Among other things, the proposed rule puts employers In the untenable position of having responsibility for IAQ without having authority to control it. In RJR's Business Paper # 6 - "Estimated Cost of Compliance with OSHA Proposed Regulations" the initial and on-going financial impact of the proposed rule on RJR's operations was shown. Cost impact of compliance, implementation, smoking lounge construction , employee Information, record keeping and other procedures was noted. In Business Paper # 6, which is attached to this document in Appendix A, the analysis considers only costs associated with the 372 company-owned facilities in North Carolina. Programs to address the proposed OSHA Indoor Air Quality requirements at Field Sales facilities are excluded, because each of the 171 Field Sales managers would have to negotiate program administrative accountability with his or her specific landlord. Existing leases do not mention indoor air quality. Property owners typically feel indoor air quality should be the responsibility of the tenant. As, a tenant, RJR feels that indoor air quality should be the responsibility of the landlord, because tenants have no access to, or control of, building ventilation equipment. A lease is a contract. between a building owner and a tenant. Usable space, cleaning, ventilation, security and other services are provided by the landlord in exchange for rent. No where, in RJR contracts with landlords, is a level of indoor air quality stipulated. G174YIREG•AFnIA010SHAWHF8A0G 8GL 2 of 10 8/30/95 4:35 PM

OSHA - POST HEARING COMMENTS SPEAKER: Hoy Bohanon • Regulation of indoor Air Quality will result in decreased productivity At RJR, good IAQ is assured by providing ventilation as prescribed in the ASHRAE 62-1989 standard and executed through sound maintenance procedures. Regulation will not improve the air quality or productivity at RJR. In fact, for RJR and all companies that already provide good IAQ to their employees, regulation will have a negative impact on productivity due to the increased, non-value-added paperwork required for compliance. This cost for RJR is shown in Business Paper #6. A recent survey conducted by the International Facility Managers Association, "Environmental Issues in the Workplace" (5,997 surveys mailed, 1,794 responses) showed that air quality was a high priority for respondents (75%). 72% used various methods to monitor or reduce indoor air poilution. For the majority of facility managers, who provide good indoor air quality, regulation will only increase paper work and will have a negative impact on productivity. They will spend less time providing good indoor air quality, and more time filling out the paperwork to prove to the government that they are indeed providing good indoor air quality. There is no way to prove that good indoor air quality will decrease building operating cost or increase corporate output. It might improve an individual's perceived job performance, but there is no way to translate that perception to the bottom iine. . Productivity In knowledge (professionals, scientists , managers) and service work (i.e. the office environment effected by the proposed OSHA regulations) Is different from productivity in the industriai environment where workers move and make things. In the industrial environment, for example, a worker shoveling sand can move more sand, while working in an air conditioned building, than in the hot sun. Additionally, productivity can be increased by substituting capital for labor. A back hoe, for example, can dig a ditch faster and cheaper than a.man with a shovel. Additive productivity math similar to the above industrial example does not work in knowledge and service work. Elimination of thousands of headaches per year, due to better air quality, might enable some clerical workers doing repetitive work to file more folders or type more letters each year. However, if corporations don't lay off a number of workers corresponding to this increased ability to file and type, then there is no true gain in productivity because there is no corresponding decrease in cost. For the majority of workers in the service and knowledge sector, real gains in productivity come from working smarter - that is rethinking and reworking how work is accomplished so &V74zFtDc•nrFUnrnosw,wHC3.oocr BcL 4 of 10 s/3o/95 4:35 PM

f OSHA - POST HEARING COMMENTS SPEAKER: Hoy Bohanon that significantly fewer people can accomplish the primary objective of a task or process. Gains in US corporate productivity today are coming through "Re-engineering" a popular description for the process of re-inventing how work is accomplished, which usually results in the need for far fewer people (and results in the continual waves of high- profile and continuing corporate down-sizings). 4. OSHA and the Private Sector assess productivity In markedly different ways. As a result, the proposed rule raises serious questions about whether the "benefits" are actually worth the "cost." OSHA and the Private Sector have vastly different perspectives on productivity, leading to significantly different assumptions about the impact of good indoor air quality and program administration on worker productivity. Different assumptions about productivity will lead to different assumptions about cost savings, which might then lead to different conclusions about the cost versus benefit of the proposed regulation. Measuring overall productivity - output versus input - for manufacturing operations is fairly straight-forward because the American accounting system is set up to support industrial management. All costs like labor, materials, depreciation and overhead can be allocated to each widget to calculate unit cost, one measure of product productivity. While overall system productivity is relatively easy to calculate for industrial operations, the same cannot be said for service jobs. Does the addition of a corporate staff person, focusing on long- rage planning, increase or decrease productivity? When measured in the short term for individual product line productivity, the answer will be different than when viewed in the long-term, using corporate earnings growth as a measure. Experts from many fields will agree on one thing - its relatively easy to measure productivity gains, however, its difficult to accurately attribute those gains to any particular action. The Hawthorne experiments (1924-1932) at a Chicago General Electric plant showed rising rates of production due to unwanted influences of the experimental operations team. Since that time, American business has been skeptical of productivity improvement claims that are attributed to any particular factor. Workplace leadership, small group influences, social reinforcement, cooperation, individual attitude and motivation all play a factor in individual and group productivity. Attributing productivity gains of office workers due to good indoor air quality is like attributing increased sales of soap to the shade of red on the wrapper. Many factors go into a purchase decision, and its hard to measure the influence the of each, but more straight-forward to measure overall results - i.e. increased sales. G1742UtEG-AFPUA010SHAtPHG3.DOG BGL 5 of 10 8/30/95 4:35 PM

( OSHA - POST HEARING COMMENTS SPEAKER: Hoy Bohanon One of the possible causes of differing views on productivity of the public and private sector is the use of the word "productivity", which has a definite quantitative, business meaning and vague non-quantitative meanings. A recent article in a facilities management magazine headlined "97% of bosses and employees agree: happy workers are indeed the most productive." What this article was actually reporting was the "feelings" of bosses and workers about the impact of behavior on job performance - not the overall company performance. If a claim is made that a factor - like happy worJcers or good indoor air quality, increases productivity, then a direct cause and result must be shown in order for the productivity claim to be valid. If improved indoor air quality is provided at all government offices, and productivity improves, then the individual agencies should be able to cut their budgets, because fewer people would be able to do the same work. That's how it works in the corporate world. 5. IAQ regulation will increase "lost time" and "lost work-days" due to employee complaints for which the cause will not always be clear and observable to, or correctable by, the employer. OSHA reform is currently being debated in congress. It seems that some employers feel that being cited for paper-work violations or violations of the "general duty clause" are counterproductive to the central mission of OSHA, which they feel, is fostering a safe work environment. Under existing OSHA regulations, there are clear and consistent workplace standards that protect all employees. With the proposed IAQ regulation, one employee may complain of headaches, lethargy etc. and attribute them to poor indoor air quality, while surrounding employees are unaffected. The air will no doubt be tested, and quite possibly, be found acceptable. If this happens, then the next step in investigating the problem is checking the employer's HVAC records. Due to many factors, some employers will not have good record-keeping habits. They might not be able to prove that they have continuously provided acceptable indoor air quality (even if they have). This could result in a citation. You then have a situation where one or several employees can generate a penalty against their employer for a violation of workplace safety, based solely on poor record- keeping. In an industrial setting, an emphasis on fall protection safety usually results in fewer accidents. In the service sector, IAQ regulation could possibly result in more complaints, and lost work days with little or no improvement in IAQ. Two examples will illustrate this point. Let's say an employee complains about poor IAQ. After much testing, by both the employer and building owner, it is determined that carbon dioxide levels are too high. The building owner opens the dampers on the air intakes, and carbon G:1747,REG-AFFVAG\OSHAWHC3,DOC! BGL 6 Of 10 - 8/30195 4:35 PM

OSHA - POST HEARING COMMENTS APPENDIX A SPEAKER: Hoy Bohanon A. Organization of Business Paper #6 The "Financial Impact Spreadsheet" in Business Paper #6, quantifies the financial impact of the proposed OSHA role on company-owned manufacturing, processing, storage, distribution and office buildings in North Carolina. The impact of the proposed rule on leased, field sales facilities is not know and cannot be quantified because the details of a program at each facility will be the result of landlord/ tenant negotiations. For clarity in communication and respect of time constraints of reviewers, the six sections (A-F) of the spreadsheet in Business Paper #6 correspond to the sections and titles listed in the proposed rule as published in the April 4 1994 Federal Register. Only known items impacting the company operating budget are included on the Financial Impact spread sheet. The three pages titled "Compliance Tasks" that follow the "Financial Impact" spread sheet in Business Paper #6 define the scope of compliance work, as we interpret the proposed rule, impacting our business. The first column of the Compliance Tasks list is labeled "Task" and defines a discrete work item that will be required by the regulation. The next column, labeled "Comments" assigns internal responsibility for a task and defines additional work to be done. This portion of business paper #6 was added to show that the financial impact of the proposed regulation might have been greater if a creative approach to dealing with the problem was not developed by the company. This approach is similar to efforts of all US businesses to increase productivity of workers, that is working smarter by having existing workers do more. The additional paper work and record keeping imposed upon our facilities, that already provide good indoor air quality, is a negative drag on the productivity of our employees and will further erode the competitive position of our company and all US companies in emerging global marketplace. Additional comments about productivity follow later in this section. B. General Assumptions - "Business Paper #6" There are several assumptions that shape the RJR approach to developing a compliance driven program (which are quite frankly very different from how RJR and many other efficient, non-unionized, businesses ' approach developing a solution to a real or imagined problem): • Compliance will be the responsibility of each site or building facility manager. • Current staff will gather data at each facility.. • A company-wide program manager and administrative assistant will be hired to coordinate internal activities with federal regulatory requirements. This program manager will be the company contact for the regulatory agency. • Construction of smoking lounges will be performed by a small core team including a project manager, designer, and construction personnel, who will move from facility to facility over the course of a year or more. • Wherever possible, computer support will be used to track and manage the detailed information for each facility. We anticipate the record keeping requirements to generate a small library of data which will be updated constantly. For example every time a wall is moved in one of our facilities, the HVAC system will be impacted and the system plan will have to be updated and sent to central record-keeping. All records of maintenance activities will have to be cataloged and filed (this is currently performed electronically). • Testing of air samples will be carried out by a contract fum. • RJR will develop an in-house training program for both employee information and training detailing how to provide adequate ventilation during cleaning and maintenance and how to use and dispose of chemicals. Training will be delivered by the RJR Compliance Training Department. G:V42UtEGAFFVAGIOSHAWHGMP.DOG aGt 7 of 13 8/30/95 3:37 PM

OSHA - POST HEARING COMMENTS APPENDIX A SPEAKER: Hoy Bohanon New class/video on ventilation during maintenance . Again, RJR has a combination of in-house and contract maintenance employees. We have many contract employees performing work for numerous firms in many parts of the company. As an owner and operator of the HVAC system, we feel that we would have to reach all contract and company employees with proper training specific to our company. Even though we are not responsible for training contract employees, they work side by side with our company employees, and we are actually in a better position to provide the training because we know more about the work performed by contract employees than their employers. The cost for this line item includes writing, filming and editing a video, using contract employees, managed by our in-house video producer. Development of the class and content would be by our Compliance Training Dept. staff. New class/video on use/ disposal of chemicals • We have over 9,000 MSDS sheets on file in our company. We train industrial workers routinely on the handling and proper disposal of chemicals. We even provide a "Safe Day" program for non-industrial employees, where office workers receive training on accident prevention, identifying hazardous material, who to call for help with safety or environmental issues and so on. Existing training would be combined with new indoor air quality training for a new class or video. Development of the class and content would be by our Compliance Training Dept. staff Lost time (RJR employee training 6,000 people ® S30Ihr • The reason that the cost of $180,000 per year is not increased annually, is because industrial corporations typically become more productive each year - that is they require fewer people to do the same amount of work. We assume that any increase in employee wages would be offset by decreases in the number of employees for no incremental effect on the cost to the company. • In an industrial setting, missing employees often cause the entire process to stop. Consequently, training is sometimes conducted immediately before or after a shift, necessitating the payment of additional wages to employees receiving training at an overtime rate. When training is conducted during a shift, sometimes their work or process stops, resulting in lost production. The cost of this greatly exceeds $30 per hour. The average of overtime and pay for lost production time, is estimated to average at $30 per hour including fringe. F. RECORD KEEPING Initial retention - premise system reports @ Records Storage • RJR maintains a Record Storage facility for the retention of documents for tax or other regulatory purposes. There would be no incremental cost to the company for this work, as we do not plan to lease more space or hire more people to do the work. The existing people performing this function will have more work to do. Future retention - Computer System ( Ref. section A) • Retention of records is planned to be accomplished with a new computer system, however, we will most likely have storage of printed documents at the Record Center. One last comment about cost RJR has benchmarked facilities "best practices" with other Fortune 500 companies. Even large corporations rarely have sites larger than 2 million square feet. RJR has 17.78 million square feet within a 30 mile radius. We know of only one other, non-automotive company with as much as 10 million square feet in a 60 mile radius. The cost impact of this proposed rule on RJR represent the absolute minimum impact that can be expected on business. We have formulated a compliance plan with efficiency and cost effectiveness as major goals. For large corporations, with many "small" sites of I million square feet or less , compliance costs will probably be several times more than RJR costs. For small businesses, compliance costs will proportionately much higher than RJR. N OD G.V4MEG-AFFlIAQIe5HA1PHCAPP.fX)G aGL 13 of 13 8/30/95 3:37 PM w

OSHA - POST HEARING COMMENTS SPEAKER: Hoy Bohanon facilities are non-industrial, and 29 of the 372 North Carolina buildings are non- industrial. The total of non-industrial buildings, operated or leased by the company, is 200 facilities (171 + 29 = 200). Roughly one-third of all RJR employees (Field Sales plus North Carolina facilities) work in a non-industrial setting. Almost all employees are full-time. Over half of the total workforce, which numbers almost 10,000, are production workers. A significant portion of RJR employees, mostly in Field Sales, work in multi-tenant, leased facilities, a class of buildings that were overlooked in OSHA's proposed rule. R. J. Reynolds Tobacco Company respects the privacy of individual employees. RJR does not keeps records for smokers versus non-smokers for either absenteeism, health insurance or anything else. C. The potential difficulties and costs involved in providing an adequate audit trail for compliance with the proposed rule for companies with computerized maintenance systems. IAQ regulations will increase the workload of all maintenance organizations. While organizations that do not provide good indoor air quality will have more maintenance and paper work to perform, organizations that provide good indoor air quality will also have to do more paper work. Corporations are continually striving to increase productivity In all areas of their business and building operations are no exception. An illustrative example of the impact of this regulation at RJR is the negative effect on working smarter that the rules will have on the 93 complex, a group of office facilities. In Business Paper #6 "Compliance Tasks" (which immediately follows the "Financial Impact" spread sheet) under "Section A. - Compliance Program ; number 2-"Compile and submit Compliance Plan", part e-"Wiitten maintenance program for HVAC system" shows that at RJR preventive maintenance activities are not documented in a book, but are planned and managed by in-house maintenance software called "Premis" which tracks all periodic, preventive and predictive maintenance work activities for all building operating systems, for most company-owned building. This system, works extremely well from an operations perspective, but doesn't provide an overview of a maintenance program that would be useful to a regulatory agency because its hard to separate the regulated from non-regulated work items. The "Premis" system software was developed after each building was constructed or renovated and initially incorporated manufacturer's recommendations with industry best practices. Over time, procedures were improved as a result of work-saving ideas. For example, in Building 93-7, maintenance personnel are instructed by "Premis" system work orders to check a hydraulic system in a certain portion of the building, then check the fan belts on an air handler in the same area. The "Premis" system work order also instructs the maintenance G17421REG-AFniA010SHAWHC3.DOG BGL 9 of 10 8/30/95 4:35 PM

, Business Paper 6 (7stimated Cost of Compliance with OSHA Proposed Regulations The Occupational Safety and Health Administration's (OSHA) proposed "no smoking" rule is part of a broader Indoor Air Quality (IAQ) regulation. While the "no smoking" portion of the proposed regulation has received widespread attention, both at RJR and in the media, the IAQ requirements will have a greater potential to impact U.S. business operations because they would extend the regulatory presence of OSHA beyond the industrial environment to every work place. All employers will be required to measure and ensure acceptable Indoor Air Quality for employees. What is unique about the proposed regulation is that employers, not building owners, will be held accountable for providing good indoor air quality - even in leased space where the employer has no control of the building's mechanical system. Employers will be expected to comply in the following manner. A. Compliance - Employers will be required to designate a person responsible for implementation. RJR cost will be almost $1 million in the first year for data gathering and system set-up. Cost will be approximately $150,000 annually after start-up for a program manager and clerical support. B. Implementation - Employers will be expected to keep "as-built" construction drawings, detailed operating procedures, descriptions of systems and the building as well as a detailed record of complaints and responses. HVAC systems will be required to operate during all times when the building is occupied. For example, in RJR's Plaza building, the system must run whether there are 200 Wachovia Bank & Trust employees on a floor or 2 contract cleaners. t RJR cost will be approximately $330,000 during the first year for computer system modification and increased HVAC system operation. Additional HVAC system operation will average $300,000 per year after year one. C. Smoking Rootns - Employers will be required to provide smoking rooms or prohibit smoking in the work place. Cost to RJR to establish smoking rooms in all facilities will be approximately $4 million during the first year. No smoking would be permitted except in the smoking rooms. D. Other Procedures - Employers must clean duct work, relocate air intakes, mitigate renovation efforts and monitor and test carbon dioxide. RJR cost for the above will be $1.4 million during the first year and approximately $700,000 per year in the ensuing years. E. Employee Information and Record Keeping - Posting information regarding the IAQ regulations will be mandatory, as will record keeping and retention. There will be no incremental RJR cost for these activities. I've enclosed a financial impact summary and outline work plan for compliance activities. Total cost in year one will be almost $7 million. The cost for ensuing years will average $1.5 million. Costs may vary depending upon scope changes of the final regulation and changes in RJR's compliance strategy. 2rry Lynch, AIA R. J. Reynolds Tobacco Company G: V 95aartyOs ha-sum.doc

. OSHA - POST HEARING COMMENTS APPENDIX A SPEAKER: Hoy Bohanon and burdensome federal regulation is proposed to make the rules at each workplace the same and to regulate the 1% who are not regulating smoking or the others who are not "regulating properly". Carbon Dioxide Testing 372 bldgs. @$1,500/yr • We currently have an indoor air quality program. We test our facilities when employees complain, and we occasionally test to set baseline parameters to measure future employee complaints against. At RJR, there is a mood of cooperation between management and employees. There is not the adversarial relationship between employees and supervisor that is found in governmental and union work environments. If an employee has a problem, we fix it. It's been that way as long as anyone can remember. Now, the federal government is telling us that because some government buildings have a history of poor indoor air quality, every employer, even if they can show that they have had a program and good results, will be required to conduct business exactly as specified by the federal government. There will be no latitude for working smarter, or using professional judgment, • With this as a background, our industrial hygienists have recommended that we test all buildings at least quarterly for the proposed regulation. They felt that quarterly tests would "prove" to regulators and/ or litigators that we are showing due care because we would be testing at least once per season. We currently employ three full time industrial hygienists (plus contract staff as required) in addition to health and safety technicians and professionals at all sites. One of their jobs is to ensure that everyone is provided a safe, productive working environment, This includes good lighting, proper noise levels, safe conditions, an accessible workplace and good indoor air quality. For the 17 Million square feet of space owned by RJR, company industrial hygienists respond to two or three indoor air quality complaints each year. They resolve each problem and retain documentation. Our interpretation is that the $381,000 cost of testing would be mandated by the proposed regulation. This would be an additional cost for the company. The end result will be the same, with or without regulation - that is we are committed to providing good indoor air quality. The difference is that we would be $381,000 poorer and some consultant would be $381,000 richer under the proposed rule. Again, this and other burdensome government regulations continue to erode the competitiveness of RJR ad other U. S. companies. • 254 buildings were identified as requiring testing. It is assumed that each building would require 4 tests at an average cost of $375 each. It would take a consultant approximately 8 hours for travel, testing, report writing, meetings with RJR personnel and record-keeping for each $375 test for each building. This works out to an average hourly rate of $46.87 for the contractor. We don't know what the actual pay rate of the employee would be, but estimate that the employee would be paid $40,000 to $45,000 per year. E. EMPLOYEE INFORMATION New class/ video on ventilation during renovation • RJR has an extensive Compliance Training Program that is managed and run by the Compliance Training Department. All Safety, DOT, Environmental and other training is administered in a coordinated manner for the least disruption to normal work activities. Many times, a video is produced to dramatically show points that cannot be made in a classroom and also to keep the interest level high. We anticipate having to educate our in-house facilities and maintenance staff as well as all construction employees (through the contractor). We lease a small portion of one of our office buildings. In real life, tenants often decide to renovate a space (i.e. add a few offices), hire a contractor and proceed without notifying the landlord. The return air is usually left open, and the result is a potential indoor air quality problem of unknown origin. This chain of events is different from construction in an industrial setting, because, the tenant is often missing - that is the contractor works for the employer who operates the building. The cost for this line item includes writing, filming and editing a video, using contract employees, managed by our in-house video producer. Development of the class and content would be by our Compliance Training Dept. staff. G:V/NtEGAFFVAU05HAWHGAPP.eOG BOL 12 of 13 8/30/95 3:37 PM

OSHA - POST HEARING COMMENTS APPENDIX A SPEAKER: Hoy Bohanon a system for a facility that is virtually vacant except for a few persons. C. SMOKING LOUNGES • Constructing smoking lounges will be performed by teams that will move from facility to facility over the course of a year or more. Construction and design work will be performed on a time and materials basis. In this manner, the team can develop a teaming curve as they proceed, and will be able to incorporate feed back from the operation of their first systems into the design and construction of subsequent systems. Using this method of organizational leaming, we expect to decrease the unit cost of smoking lounge construction over the course of a year. • Construction cost estimates for Business Paper #6 were developed specifically for RJR smoking lounge construction by the RJR Faceless Planning Department. Note, these costs are different than those used in Business Paper #7: •. Costs in Business Paper #7 were developed for "hypothetical" smoking lounges. In Business Paper #7, the source of the multipliers used in the table titled "Developing a Smoking Lounge" were generated from surveys of cities performed by the Human Resources Department of Raytheon's construction division, Hargbert-Yeargin. • The database of costs used by Raytheon in Business Paper #7 derives partially from a service for estimating construction (Mclunkin) and partially from the professional engineering and construction experience of Harbert-Yeargin, Raytheon's construction division • The data on the range of smoking lounge cost in Business Paper #7 used by the Washington Consulting Group is based on an article that appeared in the New York Post, on June 6, 1994, authored by the head of the New York City Restaurant Association. D. OTHER PROCEDURES Relocate air intakes • According to the proposed regulation, air intakes located near truck docks would have to be re- located. We currently have one air intake in a mid-rise office building located near a truck dock. Current procedures to mitigate potential indoor air quality problems include a company regulation that all trucks using the dock shut off their engines while at the dock or waiting on the street. This regulation is enforced by a security guard, who is stationed full time at the dock. The security guard's duties include ensuring that the regulation is enforce. Our current procedure provides good indoor air quality, and meets the intent of the regulation at far less cost than mandated by the regulation. People are human, and occasionally, a truck is left running near the air intake. When this happens, building occupants either call the dock or building facilities office to voice their complaint. To the best of our knowledge, every time this situation has occurred, the situation has been resolved to the satisfaction of the building tenant. This situation reinforces the point that author Philip Howard makes in The Death oJCommon Sense, that is, that any regulator making rules on a prescriptive basis cannot possibly anticipate all circumstances. Because a rule is a rule, there is no latitude of either the people effected or those enforcing the law, to inject some common sense into the equation. We know that we are already providing good indoor air quality in the building, because we have tested the air and systematically questioned the building occupants. Even though the indoor air quality is good, we are out of compliance according to the new. regulation. In our interpretation of the proposed rule, its just like any other federal regulation, there is no latitude for common sense, Clean Ducts - Reynolds/ BGTC • There are two facilities that we are aware of that have carbon particles in some of the air supply ducts. The facilities are old and we don't know where the carbon came from or how long it has been there. We suspect it came from manufacturing facilities that were located next to the buildings at one time. We've had the material tested and have consulted with experts, who advised us to leave the material in place because it would cause more problems if we tried to remove it, than if we left it in place. According to our consultants, the carbon poses no health risks to the G:4T4JiEGAFNAQ105HA1PHCAPP.BOp BGL 10 of 13 8/30195 3:37 PM

OSHA - POST HEARING COMMENTS APPENDIX A SPEAKER: Hoy Bohanon C. Detail Assumptions -f°Business Paper #6" Because so many questions were asked regarding the "Financial Impact Spread Sheet" in "Business Paper # 6", a detailed listing of assumptions and an explanation of what factors contributed to the bottom-line impact are explained on a line-by-line basis. Table 2 Assumptions behind Financial Impact Spread Sheet. ReL Business Paper #6 A. COMPLIANCE OSHA Contact/ Program Manager • As mentioned in the general assumptions, RJR will hire a senior, professional-level, proglam manager to coordinate and administer the program. This employee would earn approximately $64,000 per year. Fringe plus facilities rearrangement costs, telecommunications connection fees, purchasing a new phone, computer and software as well as computer training, professional registration and fees and professional training/conferences will bring the total cost to the company for this position to $98,520. Clerical Support . The administrative assistant for the program manager will earn approximately $32,000 per year. Fringe plus facilities rearrangement costs, telecommunications connection fees, purchasing a new phone, computer and software as well as computer training, will bring the total cost to the company to $48, 860. Facility Staff-Data Gathering (Overtime <<D, each site) . RJR buildings are clustered at various sites. Each building does not always have a facility manager There is usually a facility maintenance organization at each site that is charged with maintaining the buildings. Technicians, CADD operators and maintenance personnel at each site would be charged with updating drawings for each facility. Because the data gatherers are hourly employees and their work load is high, this activity would have to be performed on an overtime basis. RJR has 17.78 million square feet of company owned buildings. The cost of updating drawings will be approximately $0.005 per square foot. Consulting Eng. (254 Buildings. ® $1,500 ea.) • Many of RJR's company-owned buildings are either used for storage (and are not conditioned - that is they do not have air conditioning or forced air movement) or are surplus and currently unused. A detailed analysis of the OSHA proposed IAQ rule, identified only 254 buildings that would be required to comply. A consulting engineer would be hired to assist RJR In evaluating impacted facilities, then recommend a computer compliance system and assist in establishing a compliance database. This would occur after the staff had collected data at each site. Legal Interpretation • RJR will require the assistance of outside legal counsel in setting up and administering a compliance program that is based upon "junk science" and the "perceptions" of contractors, vendors, tourists, employees, visitors, salesmen and contract employees. Technologistl Engineer - System Documentation/set-up • RJR is anticipating that some type of computer program will be available for purchase (see above). RJR also anticipates that this program will be network based. A full time, contract systems engineer will be hired for a one year period to coordinate the implementation, integration and roll- out of a new server-based system, within RJR's current WAN (Wide Area Network). There is considerable work involved in purchasing a server, establishing communication links to various sites, installing the software, testing, loading, then scaling up the model to a full working system B. IMPLEMENTATION Centralized phone line for IAQ complaints Gl74NtECrAFFYAOIOSHANHGAPPd10C/ aGl 8 of 13 8/30/95 3:37 PM

OSHA - POST HEARING COMMENTS APPENDIX A SPEAKER: Hoy Bohanon • RJR currently has a company phone line where employees can anonymously report safety infractions to corporate staff without fear of reprisal from their direct supervisor. A similar phone line would be set up for IAQ complaints. The cost will be less than $1,000 to purchase a special phone and answering machine for this purpose. The IAQ phone would be managed by the same group that managers the safety line. • The safety line is one of the many innovative management practices that RJR has implemented in the last five years. The result of making safety a number one priority at RJR has been a 50% reduction in the company's OSHA incident rate. In benchmarking with other large companies, RJR has noted similar reductions in other industries. it's interesting to note that the OSHA incident raiL, for industry as a whole has remained flat in the same period. When a company decides that an issue, like safety, is important, and makes good business sense, then management and workers strive to solve the problem. In observing what it takes to make improvements in the area of safety, we at RJR have noted that there is little to no correlation to regulatory efforts and a high correlation with motivation to change, Premis system modifications - temporary • RJR will hire a contract, Information Resource Specialist to modify the Premis system to produce reports on maintenance activities associated with IAQ. The actual coding of activities will be done by the facility managers. The contract specialist will be hired for approximately 3 months to write the code and assist facility managers in their changes at the operational level. New Computer System Maintenance/Compliance-Software • RJR assumes that software developers will make available a computer system that combines maintenance, scheduling and recordkeeping with the new burdensome regulatory reporting and record keeping requirements of this proposed regulation. • The bottom line of IAQ regulation is that it will trigger lawsuits against employers. At RJR we plan to separate our Indoor Air Quality Compliance activities from other maintenance activities because we see no value in the government and lawyers poking their nose in yverv aspect of our business. • Because this type of software should contain some level of artificial intelligence and will have to be distributed on the network, we are assuming that the system will cost about $10,000. New Computer System Maintenance/Compliance • Data Input • Once we have a new file server and new software, we would hire a contract information resources specialist to transfer the appropriate maintenance data from the Premis system to the new compliance system. Please note: the total of $70,000 computer expense is incurred only to transfer existing procedures to a new system that can "prove" we are doing what we have been doing all along to regulators in a format that they want. HVAC system operation during cleaning & off-hours • Our buildings are occupied at all times. We're not like the Federal Government where everyone leaves at 5 P.M. everyday. Office workers often work late or arrive early. There are always security guards, fire watch patrols, process service employees checking cooling tower water, contractors performing work that can't be done during working hours and people coming in to work at oddball hours. A recent survey of the sign-in sheet at office building 93-7, revealed that several office employees came to work at 3 or 4 AM. , and contractors were working in our computer room from midnight to 7 A.M. on Sunday morning. • The way we interpret the regulation will cause us to operate our HVAC systems for the full 8,760 hours each year. A standard work year is approximately 2,000 hours. We operate our HVAC systems in office and support facilities so that design conditions are reached well before the majority of employees come to work and for several hours after the close of business to accommodate overtime workers. We operate our fans and chillers (chillers are required all year in North Carolina) in the evening for the comfort of cleaning crews or contractors working overtime because we recognize that they will perform better with proper climactic conditions. The additional cost noted was the additional electricity and steam cost (we run environmentally friendly absorption chillers) required to run our systems during the approximate 6,000 hours when the system is not currently operated. The calculation included the decreased occupant load of running G:V42JiEGAFNA4`ASHAWHCAPP.DGp aGl 9 of 13 -8l30/95 3:37 PM

. OSHA - POST HEARING COMMENTS APPENDIX A SPEAKER: Hoy Bohanon building occupants. Our interpretation of the proposed rule is that even if the material in the ducts poses no health risk, we would be considered negligent if an indoor air complaint was filed - because we knew about the material and did nothing - even though doing nothing was the best option. Construction Compliance (Similar to asbestos abatement) • The way we interpret the proposed regulation is that construction or renovation areas in occupied buildings would be required to be separated from building occupants by a negative pressure enclosure similar to those used in asbestos abatement. What is the definition of construction or renovation? • Construction means different things to different people. In anothdr'-.?mpany, tearing down 10 workstations and building 6 offices out of steel studs and dry-wall might be considered construction. There would be dust, noise, VOC's from paint, possible VOC emissions from carpet, wall paper adhesives or new furniture. For similar projects at RJR, construction of the same offices would produce few indoor pollutants. Instead of using steel studs and drywall, we use moveable wall panels. These panels are made out of gypsum board and are anchored with metal channels at the top and bottom. Installation is relatively quiet and produces only minor amounts of dust when compared to gypsum dry-wall installed over steel studs. RJR's wall vinyl is attached at the dealer and each panel can be re-used many times. Most wall surfaces are vinyl covered moveable panels. Where walls are required to be painted, we use latex paint (We have experimented with low-VOC paints and have found that the increased price d,oes not produce results that are apparent to employees in effected areas). If there are occupants nearby, our in- house construction coordinator informs them of the construction (a permit is also posted and management is always informed of construction) and its implications. If fumes from the paint or other materials, bother tenants, we cease painting and continue after hours. We only use Milliken carpets with inert backing and special adhesive, because there are few if any fumes from the adhesive, and the old carpet adhesive does not need to be removed. If we are installing a large area of carpet, we typically wait until after hours for installation, or vacate an entire floor, cut off the return air, and open a window, which provides negative pressure in relationship to the rest of the building. For jobs that require a lot of painting, carpet Installation and so on, we usually vacate a floor. When a portion of a floor requires some renovation or construction, we typically section off the area with black vinyl that is hung from ceiling to floor, and move adjacent occupants away from the construction. • At RJR, providing good indoor air quality during renovation or construction has been a priority for years. Its part of good customer service for our tenants, and keeps our work force productive. Using the same interior contractors year after year also aids in providing quality work, while not disturbing those working nearby. This just makes common sense. We have benchmarked with other Fortune 500 companies and have found that they have a similar customer oriented orientation in their construction projects. Our fear is that once the details of a sweeping final rule are promulgated (with one-size-fits-all, assuming that all employers are bad guys), our gains in construction quality and productivity will be wiped out because the government will be defining how we will accomplish construction, rather than the results that are expected. • The International Facilities Management Association (IFMA) periodically conducts a benchmark survey regarding many facility-related issues. In the Benchmarks 11 report issued in 1994 (survey administered in 1993), the average chum rate, which is the number of people moved within a facility each year divided by the total seated population, was 41%. 25% of the respondents had a chum rate of 56% or higher. What this means is that there is a tremendous amount of corporate facility space being reconfigured each year. As this space is reconfigured, office space becomes a construction site. For certain parts of the year, a large percentage of office space in this country is a construction site. People are sitting nearby and might be exposed to elevated levels of VOC's and particulates. Maintaining good indoor air quality is part of the facility manager's job, and they are doing quite well without government intervention. A recent IFMA survey found that 99% of workplaces restricted smoking, had a smoking policy or banned smoking. Industry has clearly addressed the problem and is managing quite well without government intervention, yet massive, GM174MECrAFFVA010SNA%PHGAPP.00C! BGL t 1 of 13 8/30/95 3:37 PM

R. J. Reyrrolds Tobacco Company ~ FINANCU'' VlPACT AR do8ars !n thousands $ 000 Year 1 Year 2 Year 3 Year 4 Year 5 Year 6 Year 7 Year 8 Year 9 Year 10 A. COMPLIANCE OSHA Contact/ Program Manager (100) (104) (108) (112) (117) (122) (127) (132) (137) (142) Clerical Support (50) (52) (54) (56) (58) (61) (63) (66) (68) (71) Facility Staff Data Gathering (Overtime @ each site) (100) Consulting Eng. (254 Btdgs. @ $1,500 ea.) (381) Legat Interpretation (50) Technologisv Engineer - System Documentation/set-up (75) B.IMPLEMENTATiON CentraCized phone line for tAO complaints (1) Premis system modifications - temporary (20) New Computer System Maintenance/Comptiance - Software (10) New Computer System Maintenance/Comptiance- Data Input (50) HVAC system operation during cteaning & off-hours (250) (260) (270) (281) (292) (304) (316) (329) (342) (356) C. SMOKING LOUNGES Construct Smoking Lounges (4,000) D. OTHER PROCEDURES Relocate Air Intakes (750) Clean Ducts - Reynofds/ BGTC (50) Construction Compliance (Similar to asbestos abatement) (100) (104) (108) (112) (117) (122) (127) (132) (137) (142) Carbon Dioxide Testing 254 bldgs. @ 51,500ryr (381) (381) (396) (412) (429) (446) (464) (482) (501) (521) E. EMPLOYEE INFORMATION New ctass/ video on ventilation during renovation (25) New dasslvideo on ventilation during maintenance (25) New classMdeo on use/ disposal of chemicals (25) Lost time (RJR employee trairing 6,000 people @ S30fir (180) (180) (180) (180) (180) (180) (180) (180) (180) (180) F. RECORD KEEPING initiat retention - premise system reports @ Records Storage 0 Future retention - Computer System ( Ref. section A) 0 Annual Total (6,623) (1,081) (1,117) (1,155) (1,194) (1,234) (1,276) (1,320) (1,3¢6) (1,413) CumutativeTotal (6,623) (7,704) (8,821) (9,976) (11,169) (12,403) (13,679) (14,999) (16,365) (17,778 ) NPV @ 11% Discount Rate ($10,976.88) Notes 1. Expenses inflated at a 4% annual rate . RJR ENVtRONMENTALANO SUPPORT SERVICES G'.1799ieARRYIOSNA-2XLS Wb94 4:11 PM E L8Z L99ZS

OSHA Proposed Rule on Indoor Air Quality R. J. Reynolds Tobacoo Company ODMPLIANCE TASKS TASK WRsp$ier4S94p. 16036 ~1 i-,,erate VAC system dunng all shifts except during emergency HVAC system repairs 4. Implement use of general orlooat exhaust where housekeeping or maintenance will produce hazardous chemicals or particulate exposure to employees working In other areas of the building. 5. Mainfain relative humidity below 60% 6. Monitor carbon dioxide levels When level exceeds 800 ppm check system. correct If necessary. 7. Assure that buildings without natural ventilation have operable natural ventilation system 6. Keep HVAC equipment rooms, ducts and plenums dean. 9. Assure that Inspections and maintenance of buikJing systems are pedormed under the supervision of the "designated" person 10. Estabiish a written record of building system Inspections and maintenance required in this section (B). 11. Assure that employees performing work on building systems use f)SHA approved equipment 12. Evaluate whether to modify building systems based upon employee complaints of building related illnesses. Take remedial actions as necessary. "„SMOKING LOUNGES t. in summary smoking will permitted only in smoking lounges No work will be permitted in lounges. ~L/ 'R REQUIRED PROCEDURES ; Relocate Intake ducts away from vehicular fumes !. Mitigate point source emissions I. Control microbial contamination • Routine inspections ' Dry or replace damp materials • Remove visuai microbial contamination In ductwork as found in routine Visual inspection Use of chemicais, pesticides etc. ' Inform employees 24 hrs before application Air quality during remodeling a. Proir to construdion, develop a compliance plan to include ' OSHA requirements ' Perform mitigation measures during construction • Isolate or contain work areas under negative pressure • Suppress contaminants our use auxiliary filters ' Prevent contaminants from entering distribution system ' Notify employees 24 hrs. in advance of Construction EMPLOYEE INFORMATION AND TRAINING Provide training for building maintenance workers COMMENTS - ~ Run system when deaning ~ Facility Maaager- coordinate with deaning contractor Facility Manager - consolidate information Coordinate with building automation system - possibly use sensors Not Applicable except portions of Bldg. 50.1 Facility Manager- consolidate information Program Manager Existing Compliance activity Program Manager/ Facility Manager Facility Manager Plaza - Relocate Facility Manager Facility Manager Facility Managerl Track on-going activities Faai'dy ManagerlTradc on-going activities Facility ManagerlTradc on-going activities Program manager coordinate with contractors Requirement similar to asbestos removal a. Training in the use of personnel protective equipment Current Compliance activity b. Training on how to provide adequate ventilation during New Class/ Program cleaning and maintenance c. Training on how to use and/or dispose of chemicals Program manager coordinate with contractors Inf^rm empioyees of: Program Manager .. Contents of OSHA regulations ~ b. Signs and symptoms of building related illness c. Copies of regulations shall be available for Inspection RJR FAGLIrIES PLANNING , g1799SBARRI1OSHA•t.XrS 814194 4:10 PM

OSHA Proposed Rule on Indoor Air Quality ,R. J. Reynolds Tobacco Company COMPUANCE TASKS ;TASK COMMENTS L -~ dReglsfar4P.+91P• 160.96 A. COMPLIANCE PROGRAM 1. Designate OSHA Contact klentify responsible person 2. Compile and Submit Compliance Plan Identify responsibte person , a. Written narrative of Building systems Coordinate for each building b. Singte-Line Schematics or"As-Buitts" Information varies by buiiding -consoi'idate c. Compile description of normal operating procedures Information varies by building - consolidate ' P+andand operating procedures Information varies by building - consolidate ' Spedal Procedures (i.e. seasonal start-up) Information varies by building - consolidate • Ust of Operating Performance Criteria Information varies by building - consordate Outside air ventilation rates Information varies by building - consolidate Potabte hot water storage and delivery temperatures Information varies by building - consolidate Range of space relative humidities Information varies by buldng - consolidate Space pressurization requirements Information varies by building - consolidate d. General description of the building Including: • Work activity Facility Manager-consoiidate information ' Number of employees Facility Manager- consolidate Information • Number of visitors Security • consolidate Information • Hours of Operation Facility Manager- consolidate information • Week end use Security - consoiidate information • Tenant requirements (Data Center etc.) Facility Manager- consolidate Information • Known air containments released into space Facility Manager-consolidate information e. Written maintenance program for system • Preventive in scope Currently Premis - investigate new system • reflect manufacturer's recommendations { • reflect "good industry practices" • At minimum describe equipment, procedures Currently Premis • Investigate new system and frequency ' Checklist for the visual inspection of building systems Develop generic list 3. If available, the following should be assembled to assist in potential IAO evaluations: • As-built construction documents Facility Manager- consolidate information • HVAC system commissioning reports Completed, but no one saved • HVAC system testing, adjusting and balancing reports Completed, but no one saved • Operations and maintenance manuals Varies by building • Water Treatment logs Process Services - consolidate Information > ' Operator training materials No system specific training , 4 Written log of complaints of signs or symptoms that Need to establish a centralized phone number „ may be related to building related illness to Include: and database, then generate work orders • Nature of illness reported ' Number of employees affected • Date of employee complaint ' Remedial action • Action taken to correct the source of problem t COMPLIANCE PROGRAM IMPLEMENTATION :mpioyers shall assure compliance through the following: . Maintain and operate the HVAC System to assure that: ' Operates to originai design specifications Facility Manager - consolidate information • Continues to provide at least minimum outside air Facility Manager - consolidate Information ventilation rate defined by code at time of construction, renovation or remodel, whichever Is most recent . Conduct building systems inspections and maintenance in Facility Manager - consolidate information compliance with Section A RJR FACIUTIES PLPNNING g179916ARRYrOSF1A•iXIS 8/4/94 4:10 PM