ARISTECH SURFACES QUALITY MANUAL BETH CALIFF [2/25/2014] ARISTECH SUFRACES LLC 7350 EMPIRE DRIVE, FLORENCE KY 41042 USA TABLE OF CONTENTS 1. Table of Contents 2. General Information 2.1 Aristech Quality Manual 2.2 Product Description 2.3 Manufacturer’s Information 3. Incoming Materials 4. Manufacturing Process 4.1 Production Flowchart 4.2 Formulation Specifications 4.3 Description of Production Methods and Controls 4.4 Quality Control During Manufacturing 5. Finished Products 5.1 Finished Products Specifications 5.2 Quality Control of Finished Products 5.3 Packaging and Storage of Finished Products 6. Disposition of Non-Conforming Materials 6.1 Policy and Procedure 6.2 Definition of Major and Minor Defects 6.3 Complaints Procedure 6.4 Non-Conformance Form and Example 7. Measuring and Test Equipment 7.1 Standardization of Quality Control Equipment 7.2 Equipment and Production Lines 8. Labeling, Traceability, and Records 8.1 Policy and Description of Traceable Label/Records 9. Policies and Instruction for Third-Party Inspections 9.1 Third-Party Testing & Authorized Listing Mark 9.2 Quality Control Manual Revisions & Inspections 9.3 Reviews and Updates LAST PAGE 1 3 13 14 15 16 17 18 19 20 22 23 29 30 37 38 40 41 42 49 50 56 58 59 60 61 62 63 64 1|Page 2.0 General Information 2|Page 2.1 Quality Manual 3|Page Purpose: The purpose of this Quality Manual is to introduce Aristech Surfaces LLC (ASLLC), its organization and its quality management approach. Scope: This manual applies to the Florence, KY ASLLC Operation: • Florence, Kentucky, which produces continuous cast acrylic sheets for the o Bath Market o Hot Tub Market o Sign Market o Custom Thermoforming Market o Solid Surface Market Lovelace Women’s Hospital 4|Page Quality Policy: At ASLLC we collaborate with our customers on both product and process improvements in both our own and our customers’ operations. These improvements include cost reductions and new product developments that delight our customers and give them a leading edge in the marketplace. This customer focus is integral to our quality culture. Quality Objectives: It is the objective of ASLLC to continue to be the leader in our markets by consistently providing products and services that meet or exceed the requirements and desires of our customers and regulatory agencies. The effectiveness of our quality management system is the responsibility of all ASLLC employees. It is not a static process; it is continuously reviewed and improved with the goal of creating value for both the customer and ASLLC. Quality System: At the base of our Quality System are the department-specific technical procedures, which detail the steps necessary to create a high-quality, cost-effective product within the framework of our operations. In addition to the procedures, batch data is logged throughout the process, tests are conducted and recorded, and material is placed on hold for additional testing or scrapped if it does not meet our rigorous specifications. These responsibilities lie in the hands of our highly-trained Operations Team, who execute upon and address any issues that may occur during the process. QMS Processes: In addition to the responsibilities of the Operations Team, our QMS system includes additional functional areas and compliance to many of the ISO 9001:2008(E) standards such as the Purchasing Process, Control of Documents and Records, Product Realization, Management Responsibilities, Control of Non-Conforming Product, Customer-related Processes, Subcontractor Management, Analysis of Data and Improvement, Identification and Traceability of Production Materials, Calibrations and Customer Satisfaction, to name a few. Our Quality Manual defines the elements of our QMS processes. Quality Measures: At the beginning of every fiscal year new objectives are deployed throughout the organization. Progress on these objectives are reviewed throughout the year. We measure our quality with customers on several different levels from customer scorecards to customer sku-specific satisfaction levels. These interactions with our customers allow us to more quickly respond to their needs. Our corrective and preventative practices result in continuous improvement of our processes and products. 5|Page Certifications: Underwriters Laboratory (UL): Altair Plus®, Quarite Plus®, Quarite Select Plus®, Quarite®, Quarite Select®, Acrysteel®, General Purpose Acrylic, I300 National Science Foundation (NSF): http://info.nsf.org/Certified/food/Listings.asp?TradeName=solid+surface&CompanyName=Aristech&St andard=051& Solid Surface for Food Zone (check for color specificity): Acrylic Solid Surface MB, Acrylic Solid Surface MF, Acrystone MG Acrystone MH, Acrystone MN, Acrystone NE, Acrystone NG Acrystone NI, Acrystone TF, Acrystone TG, Avonite® Foundations™ FI-8699 Formstone F1 French VOC Regulations per ISO 16000 for Acrylic Solid Surface (Solids (MF), Minerals (MG), and Pediments (MH)) NSF Product and Service Listings can be found for ASLLC at: http://info.nsf.org/Certified/food/Listings.asp?Standard=051&Company=02930& 6|Page 7|Page 8|Page 9|Page ISO: ASLLC has chosen not to seek ISO certification. However, we are compliant with over 90% of the ISO 9001:2008(E) standards. From the executive team who develops, communicates and measures the attainment of the annual corporate goals to the most recently hired employee. Communication, data collection and training are the key elements of our success. Below is a summary of how ASLLC addresses the ISO standards and has done so for over a decade. ISO 9001:2008(E) compliant to the following standards: 1.1 General – Demonstrating ASLLC’s ability to consistently provide product that meets customer and applicable statutory and regulatory requirements and aims to enhance customer satisfaction through the effective application of the system. 1.2 Application – no exclusions 2.0 Normative reference – ISO: 9001:2008(E) 3.0 Terms and Conditions – “Product” and “Service” are both applicable at ASLLC. 4.1 General Requirements – ASLLC determines the processes needed for the quality management system and their applicability throughout the organization, the sequence and interaction of these processes, the criteria and methods needed to ensure that both the operation and control of these processes are effective, and ensures the availability of resources and information necessary to support the operation and monitoring of these processes. ASLLC monitors, measures and analyzes these processes and implements actions necessary to achieve planned results and continual improvement of these processes. 4.2 Documentation Requirements 4.2.1 – Quality Policy and Quality Objectives - ASLLC practices Continuous Improvement activities both internally in our facilities and externally with tolling partners and customers to provide customerfocused, cost-effective, timely and relevant solutions. 4.2.2 Quality Manual – A Quality Manual has been created. 4.2.3 Control of Documents – SJOPs (Safe Job Operating Procedures) are under a controlled and managed process, with established review timetables, authorized reviewers and easy access. 4.2.4 Control of Records – We have controlled (physical) records pertinent to our products and processes, which are kept for a period of 6 years (off-site) as well as electronic records in our system. Additionally, we maintain a physical sample from every batch for a period of at least 8 months. Within the HR function, there is a record of education, training skills and experience for employees as well as Functional Descriptions for each position within the Company. Purchasing records (i.e., conformity to specification, results of testing, etc.) are maintained in hard copy format for an entire calendar year. Each year the previous year’s copies are sent off-site for an additional 6 years of storage. Order confirmations, packing lists and invoices are stored electronically. 5.1 Management Commitment – Top management provides evidence of its commitment to the development and implementation of the quality management system by communicating to the organization the importance of meeting customer expectations as well as statutory and regulatory requirements, establishing the quality policy, establishing quality objectives and conducting management review. 10 | P a g e 5.2 Customer Focus – ASLLC engages with regular communications and audits with customers to work jointly on Continuous Improvement activities, customer complaint resolution, as well as new product developments. 5.3 Quality Policy - Our customer focus at ASLLC is based on collaboration with our customers on product/process improvements in both our and our customers’ operations, cost reductions, and new product developments that delight our customers and provide them a leading edge in the marketplace. This customer focus is integral to our quality culture. 5.4.1 Quality Objectives – Are an element of the overall Annual Goal Deployment throughout the organization. Progress toward completion of the goals is reviewed at least twice per year with all employees and their supervisor, and is communicated frequently by Upper Management. 5.4.2 Quality Management System Planning – The planning of our quality management system is designed to meet the requirements in 4.1. When changes are made to the quality management system they are planned and implemented. 5.5.1 Responsibility and Authority – Top management ensures that responsibilities and authorities are defined and communicated within the organization. 5.5.2 Management – Top management appoints a member of the organization who has the responsibility and authority to ensure reviewed processes are established, implemented, and maintained. Reports are made to top management focusing on the performance of the quality management system, needs for improvement and the promotion of awareness of customer requirements throughout the organization. 5.5.3 Internal Communication – performance of the quality management system is reported monthly within the top leadership review, and monthly to the manufacturing team and sales/marketing team. 5.6.1 Management Review – Top Management reviews the organization’s quality management system at planned intervals to gauge its continuing suitability, adequacy and effectiveness. 5.6.2 Review Input –Input to management includes results of audits and customer scorecards, status of current corrective and preventative actions, and new recommendations for improvement. 5.6.3 Review Output – Output includes a review of the quality management system processes, as well as improvements related to customer requirements and any resource needs. 6.1 Provision of Resources – the organization has provided resources to implement maintain and continually improve the quality management system’s effectiveness. 6.2.2 Competence, training and awareness – Production employees are trained for a new position by 1) working with a qualified trainer on all tasks relevant to the job, 2) reviewing SJOPs (Safe Job Operating Procedures), and 3) taking a qualification test. Once qualified, all Production Employees are required to review a percentage of their department’s procedures monthly as well as taking a requalification test on an annual basis. Corrections and additions to the SJOPs recommended by employees are made by the Supervisor and changed in the system by a designated individual (currently, the executive assistant). 6.3 Infrastructure – compliant 6.4 Work Environment – compliant 7.1 Planning of product realization – we use the Stage Gate methodology for new product development activities in addition to our Engineering documentation for process improvements. 7.2.1 Determination of requirements related to the product – This is managed through customer specific contracts as well as technical specifications. All sales contract proposals begin with standard terms and conditions, which have been approved by legal counsel. Customer-specific deviations to the 11 | P a g e standard terms and clauses are generated and reviewed by the VP of Sales & Marketing with legal counsel. 7.2.2 Review of requirements related to the product – A component of our contract negotiations with customers. 7.2.3 Customer Communications - Communications with customers occur during regularly scheduled conference calls, customer visits, negotiations, and customer requests, whether through customer service or sales calls. 7.3 Design and Development – All elements of this part of the standard are handled completely in 4.2.3 and 5.2. 7.4.3 Verification of purchased product –Raw material qualification is conducted at incoming inspection. Depending on the material, it may be placed on “hold” until it can be tested and released to production. 7.5.1 Control of production and service provision – As referenced above in 6.2.2, employees are trained and tested on procedural knowledge on an annual basis, and procedural documents are readily available. Measurement equipment is calibrated on a scheduled basis. An effective sheet inspection system is in operation. Product traceability is inherent in the process based on the time of production. Lot traceability is assigned at the end of the line and integrity maintained until it reaches the customer. This lot number provides the exact time the material was made, who made it at various parts of the process, what raw materials were used, as well as which process conditions it underwent, and what the quality characteristics of the finished product were as it came off of the line. 7.5.2 Validation of processes for production – see 4.2.3, 6.2.2, and 7.5.1 7.6 Control of monitoring and measuring equipment – An internal calibration program is managed within the Maintenance Department by Maintenance Technicians. Instrumentation/gauges and frequencies of inspections are defined. 8.2.1 Customer Satisfaction – An output of 5.2 is a series of “scorecards” developed by, for, and with customers to identify areas of focus for CI and co-operative initiatives (Kaizen, trainings, etc.) 8.2.2 Internal Audits – Monthly review of Quality Return performance by markets are shared with Manufacturing and Sales. Monthly review of quality performance by Market and Key Customers (scorecard) using 6 month Moving Average (MA), 12 month MA and current month. 8.3 Control of Non-conforming product – Non-conforming sheet is either marked with a sticker via the sheet inspection system or placed on Hold in the system due to non-conformance in one or more qualitative/quantitative tests performed on the product as it is produced. The material that is placed on Hold in production will either be tested more thoroughly in our analytical lab or scrapped. While on Hold, the material cannot be shipped. 8.4 Analysis of data – inherent in 8.2.1 and 5.2. 8.5.2 Corrective Action - inherent in 8.2.1 8.5.3 Preventative Action – in addition to SJOPs, there are a group of documents titled “Critical Success Factors” (CSF) that specifically address product/process specific issues identified through a Continuous Improvement activity. During the production of these products, the CSF is reviewed by the supervisor and the employee responsible for the production of the product. These CSF are audited for compliance. 12 | P a g e 2.2 Product Description, Florence, KY Site ASLLC is located in Florence, Kentucky, and produces a number of different products for the Bath, Hot Tub, Sign and Surfacing markets. ASLLC owns 4 of the current 11 continuous casting machines in the world. These machines are approximately 350’ in length and can produce sheet material in widths up to 110’’. For the Bath and Hot Tub markets, ASLLC produces products with appealing surface characteristics and excellent formability. The majority of our bath products are based on standard bath colors (whites, biscuit, bone, etc.). Approximately 80% of bath and hot tub products combined are made from acrylic (methyl-methacrylate). For the hot tub market, our products focus on new looks and designs, which are much different than our bath market. We use ground acrylic chips in our Quarite® series, which provides a textured surface when formed. This feature is forgiving to both our and our customers’ production processes as it has the ability to “hide” small flaws (mold marks, contamination, etc.). We also make products using special pigment particulates that can impart a “pearlescent” look. We produce the monolithic sheet here in Florence and have partnered with a lamination partner to produce a laminated product, which is backed with extruded ABS. For the Custom Thermoforming market we supply products, which are made into boat engine covers and tractor fenders, to name a few applications. Like a portion of our hot tub sheet, these products are also laminated with ABS. Because of the end use, these products are highly valued for their surface appearance. In the sign market, we supply customers with material that might go into a large billboard, channel letters or a backlit gas station sign. Our surfacing products made in Florence are also acrylic, combined with ATH, a mineral filler. We are the only manufacturer of solid surface products that is capable of making sheet as wide as 60” and in lengths up to 204”. We are capable of making material at any thickness from .125 – .800”. In this offering, we currently make solids and 14 different pattern designs with a number of different colors per pattern. 13 | P a g e 2.3 Manufacturer’s Information Company Name: Address: Telephone: Fax: Email: Contact Person: Title: Hrs of Operation: Aristech Surfaces LLC 7350 Empire Drive, Florence, Kentucky 41042 1-800-354-9858 ext. 4867 1-800 -283-6497 [email protected] Elizabeth Califf Director of Corporate Quality 24/5 14 | P a g e 3.0 Incoming Materials Supplier Address JM Huber, 3100 Cumberland Blvd, Atlanta, GA 30339 BYK USA Inc., 524 South Cherry St., Wallingford, CT 06492 BYK USA Inc., 524 South Cherry St., Wallingford, CT 06492 Rohm& Haas, 100 Independence Mall West, Philadelphia, PA 19106 Arkema Inc., 9502B Bayport Blvd, Pasadena, Texas, 77507 Burje, 5 Lawrence Street, Bloomfield, New Jersey 07003 Schibley Chemical Co., Inc., 1570 Lowell St, Elyria, Ohio 44035 Schibley Chemical Co., Inc., 1570 Lowell St, Elyria, Ohio 44035 Schibley Chemical Co., Inc., 1570 Lowell St, Elyria, Ohio 44035 Schibley Chemical Co., Inc., 1570 Lowell St, Elyria, Ohio 44035 Schibley Chemical Co., Inc., 1570 Lowell St, Elyria, Ohio 44035 Schibley Chemical Co., Inc., 1570 Lowell St, Elyria, Ohio 44035 BYK USA Inc., 524 South Cherry St., Wallingford, CT 06492 BYK USA Inc., 524 South Cherry St., Wallingford, CT 06492 BYK USA Inc., 524 South Cherry St., Wallingford, CT 06492 Xpedex, 6287 Tri-Ridge Blvd, Loveland, OH 45140 Hi-Tech Extrusions12621 Chardon Windsor Rd., Chardon, Oh 44024 3.1/3.2 Approved Material Suppliers/QC for Incoming Materials Material ATH ATU 100 ATU204 BA BRC - 1 BRB-4 (t-butyl peroxypivalate) BRB-5 (t-butyl peroxyneodecanoate) BRB-6 (t-butyl peroxyneodecanoate) BRB-7 (2-ethylhexanoyl peroxy) BRB-8 (t-amyl peroxy-2-ethyl-hexanoate) BRB-9 BYK 1142 BYK 7072 BYKP105 Foil Wrap Gasket Midwest Elastomers, 700 Industrial Dr., Wapokoneta, OH 45895 Ground Chips JX-1 (n-dodecyl mercaptan) Arkema Inc., 900 First Ave., King of Prussia, PA 19406 JX-2 (ethylene glycol dimethacrylate) Evonik Cyro LLC, 299 Jefferson Rd, Parsippany, NJ 07054 JX-15 (HEMA 98 Stabilized w/200ppm MEHQ Evonik Cyro LLC, 299 Jefferson Rd, Parsippany, NJ 07054 JX-44 (triisoctyl phosphite) Hacros Chemicals, Organics Division, 5200 Speaker Rd., Kansas City, KS 66106 JX-50 (Cyasorb or Eversob) Everlight USA, Inc., 10507 Southern Loop Blvd, Pineville, NC 28134 Linseed Oil American Chemical Services, PO Box 190, Griffith, IN 46319 Methymethylacrylate Lucite Int'l, 7275 Goodlett Farms Pkwy, Cordova, TN 38016 Rohm and Haas Chemicals LLC, Louisville Plant, 4300 Campground Rd, Louisville, Ky 40216-000 Evonik Cyro LLC, 10800 River Rd, West Wego, LA 70094 Arkema/Altuglas Int'l, 100 PA Route 413, Bristol, PA 19007 Industrial Thermoplastica Pavese S.P.A. (ITP) Via Cavaliante, 13-27040 Bosnasco(PV-IT) Hi-Tech Extrusions12621 Chardon Windsor Rd., Chardon, Oh 44024 Kronos, PO Box 673788, Detroit, MI 48267 Johnson Doppler Lumber, 3320 Llewellyn Ave, Cincinnati, Oh 45223 Chempoint, 411 108th Ave NE, Bellevue, WA 98004 Chempoint, 411 108th Ave NE, Bellevue, WA 98004 Modifier Polyfilm Polyhose TIO2 Treated Pallets Zelec NE Zelec UN Confidential Color, Particle Size, Oil Absorption, C of A Test particle size distribution on every 10th bag for SS and every 20th bag for acrylic chips Obtain the C of A Purity and Color Obtain C of A C of A & density by wht/gallon Melting Point, C of A, solubility Color, C of A, Acid Value White bucket test on every shipment White bucket test on every shipment White bucket test on every shipment C of A C of A %O2 and purity on each lot %O2 and purity on each lot %O2 and purity on each lot %O2 and purity on each lot %O2 and purity on each lot Melting Point Sp. Gr. Taken from Cof A Refractive index & density by wgt/gal Refractive Index and Infra Red Spec and Grade Testing Protocal White ATH, 17 Micron Untreated Color, dirt count, CofA Obtain the C of A Obtain the C of A White bucket test on every shipment Butyl Acrylate 15 PPM MEHQ Eugenol foil/poly, woven 14# LDPE .000285 PVC Epoxal 9.5 2.8 mil series F masking Film LLDPE 2044 Heat Treated Wood C of A C of A 15 | P a g e 4.0 Manufacturing Process 16 | P a g e 4.1 Production Flowchart Overview of Florence Plant Process Flow MMA Monomer Bulk Storage Solid Surface Process Additives Reactor Promoter Pigments Railcar Ovens Chips Heating Acrylic Sheets Trim & Scrap Solid Surface FG Warehouse Sander Customer Shipment 17 | P a g e 4.2 Formulation and Assembly Specifications This section of the Quality Manual would display the “recipes” for making specific products. Included would be chemicals used, batch sizes, pigment skus, product types, sheet thickness, and machine used. We are not able to include proprietary information within this section. 18 | P a g e 4.3 Description of Production Methods and Controls This section of the Quality Manual would display a number of SJOPs which are relevant to specific departments within the facility. Within these SJOPs, are included the purpose, scope and limitations, chemical references, definitions, responsibilities, chemical hazard data warning, emergency response, safety equipment, procedure and revision history. We are not able to include proprietary information within this section. 19 | P a g e 4.4 Quality Control During Manufacturing Florence, Kentucky Site Laboratory: Quality control responsibilities are present throughout the entire operation. These responsibilities are not relegated to Quality Inspectors, per se. There is one classification of QA inspectors which have the sole function of inspecting and testing our products at the end of the casting line. Within our other departments, there are QA responsibilities within each functional area. When our main raw material, Methyl Methacrylate, arrives at our tank farm (railcar or tanker), the tank farm operator checks each shipment for dirt. If dirt is present to a level that will not be filtered out, the shipment will be denied. Our Analytical Lab checks new lots of raw materials for specific gravity and by GC analysis. Our Pigment Lab inspects TiO2 and ATH for consistency in color and particle size, in addition to developing new pigment formulations and testing new pigments. Since we make our own pigment on-site, the Pigment techs measure, correct and record color data by lot number in our system. For specific pigments which use mica material, each batch is measured on a Hegman grind gage within 24 hours of use in production. Manufacturing: Reactor Room – Viscosities of our base syrup, which we produce, are measured once a shift by the Reactor Room (RR) leadman. The Reactor Room operation is controlled via a Delta V DCS for the operation of all vessels, including the ATH (aluminum tri hydrate) dispersion operation. Filtration is used as material is transferred and poured to the casting machines. It is the responsibility of the 3rd floor operator to assure that the correct filtration is in place as this is critical to quality in certain products. Pigment paste is dispersed in the Reactor Room on a time-controlled sequence in a high shear mixer. Pigments and chips are lot controlled and this information becomes part of the batch record when produced. Casting Machine - Prior to a batch being poured to the casting machine, a sample is taken to the casting machine operator who measures the viscosity. This is done for both chipped acrylic products and Solid Surface products. If the viscosity is too high, it may be thinned down before pouring. If it is too low, the machine may be slowed down to provide the batch in the Reactor Room additional time to build viscosity. In addition to managing the feed to the casting machine, these operators are responsible for setting the machine up for the desired caliper and sheet size, using the correct filters and changing them when necessary. Most importantly, these operators have responsibility for multi-million dollar casting machines. This part of the operation uses a Man Machine Interface (MMI) to track what is happening internally in the machine (temperature, speed, pressure, etc.). The batch is created in our system when the casting machine operator enters the batch number and head in time into our system. This 20 | P a g e begins the systematic tracking of material through our operation. A batch is not a batch until it begins to pour to the casting machine. QA – The QA operators are located at the back of our casting line where our material exits as a “hard, flat and shiny” product. At this part of the operation, the QA operators are measuring caliper variance across the sheet, color, formability, chemical stability, and examining the sheets for defects. We have Cognex Vision Systems on 2 of our casting lines. This equipment has 7 high power lamps and a camera that can check for defects such as bubbles, contamination, gels, etc., and marks defects as they are detected. This information is stored in a PC at the back of the line. Sawline - The sawline operator’s main responsibility is to stack the material onto pallets as it comes off of the line. They are also responsible for quality attributes such as saw cuts, polyfilm application, and sheet size. Since every sheet passes through their hands, they have the responsibility to inspect and report any defects they see. Sander – The sanding operators are responsible for sanding solid surface material to specification. Some of the most critical attributes during inspection of a SS sheet are caliper control, chip distribution, chatter, contamination and rough sanding. If there is chatter or rough sanding present, the sander is stopped and the sanding rolls are inspected. If there is contamination, the sheet will be evaluated as to whether or not it can be reworked. Packaging – Since this is the first view our customers see, it is important that we present a quality product. Packages are labeled with our lot number, barcode, and product type; wrapped or covered as appropriate, banded and shipped to either a warehouse or direct to the customer. 21 | P a g e 5.0 Finished Products 22 | P a g e 5.1 Finished Products Specifications TECHNICAL BULLETIN 200 Physical P r o p e r t i e s - Solid Surfacing S h e e t s Aristech Surfaces LLC Foundations and Studio Solid Surfacing sheet products in attractive granite colors provide exceptionally weatherable, strong, non-porous, scratch and stain resistant material for architectural and utilitarian work surfaces. PROPERTY FOUNDATIONS CLASS I STUDIO STUDIO CLASS I CLASS Ill TEST METHOD General: Thickness Tested Specific Gravity Water Absorption (24 hrs.) Mechanical: Tensile Strength Tensile Modulus Tensile Elongation Flexural Strength Flexural Modulus Barcol Hardness Rockwell Hardness (M) Un-notched Izod Impact Notched Izod Impact Ball Impact (1/2 lb. ball) Thermal: DTUL @ 264 psi Coefficient of Thermal Expansion Boiling Water Resistance High Temperature Resistance Flame Spread Index Smoke Generation Index Combustion Toxicity Surface: Consistency of Color (same sheet) Light Resistance Clean-ability/Stain Resistance Stain Resistance Fungi Resistance Food Zone Use 0.500" 0.500" 1.6 1.6 0.04% 4,000 psi 1,100,000 psi 2.1% 8,000 psi 1,100, 000 psi 60 86 1.40 ft.lbs./ inch 0.14 ft.lbs./inch > 150” 0.500" 1.3 0.03% 0.04% 3,700 psi 1,200,000 psi 0.38% 6,500 psi 1,200,000 psi 60 99 0.67 ft.lbs./inch 0.15 ft.lbs./inch > 150” 2,300 psi 730,000 psi 0.34% 4,100 psi 720,000 psi 51 105 0.42 ft.lbs. /inch 0.15 ft.lbs./inch >150” 200 F 2.3 X 10 -5 in./in./°F No Effect No Effect <25 <25 Solid Colors – 98 Patterns – 67 180 F 2.1 X 10 -5 in./in./°F No Effect No Effect <25 <25 Pattern – 62 Passes No Effect 13/No Effect Passes No Growth NSF 51 Approved Passes No Effect 5/No Effect Passes No Growth NSF 50 Approved ASTM D792 ASTM D570 ASTM D 638 ASTM D 638 ASTM D 638 ASTM D 790 ASTM D 790 ASTM D 2583 ASTM D 785 ASTM D 4812 ASTM D 256 NEMA LD3-3.8 175 F ASTM D 648 2.9 X 10 -5 in./in./°F ASTM D 696 No Effect ISSFA SST 8.1-00 No Effect ISSFA SST 9.1-00 >75 ASTM E 84 >450 ASTM E 84 Pattern – 19 Pittsburgh Protocol (LC50 Test) Passes ISSFA SST 2.1-00 No Effect ISSFA SST 7.1-00 9/ No Effect NEMA LD3-3.4 Passes ANSI Z-124.3 No Growth ASTM G 21 NSF 50 Approved NSF 23 | P a g e FGS – 0025 Issued: Supersedes: References: 3/10/2010 FGS – 0025 Revision Date 6-26-2013 FGS – 0021 Title: SOLID SURFACE SANDED SHEETS Purpose: To provide specifications to be used for internal quality control of all sanded solid surface products. FACE FINISH Sheets are to be finished such that the prime surface displays no visual chatter when viewed under floor lights of 500 watts located next to Sander QA station (overhead lighting masks chatter). As a general rule, the following guideline applies: Infeed Product Type MBX/MFX/NDX MGX/NGX MHX/NRX NEX/NIX Minimum Prime Side Removal Amount ~.010” ~.015” ~.025” ~.035” CHANGES: Revised surface defects description for clarity by removing specific product reference. Approver Print Name: Signature and Date: Title & Dept: Approver Print Name: Signature and Date: Title & Dept: This document and the information contained herein are the property of Aristech Surfaces LLC. Copies are issued in strict confidence and shall not be reproduced, copied, or used as the basis for manufacturing or sale of apparatus without consent 24 | P a g e FGS – 0025 BACKSIDE ROUGH SANDING When a product type is specified that calls for rough back sanding, the minimum amount of material should be removed (50 grit finish) that provides removal of all gloss. No gloss spots are acceptable as are no sander digs or divots; especially in 1/8” as this will show through to the prime surface. It is recommended that the backside of 1/8” be periodically inspected throughout a pallet to guarantee that no digs or divots are being left. SURFACE QUALITY OF SANDED SHEETS B grade sheets: Inventory levels have been identified for each color of ½” product which will supply our B grade program. B grade is sorted on the sander. All material in excess of the B grade levels identified will be scrapped off of the sanding line. Surface Appearance: The surface appearance of the sanded sheet should be visually smooth and distortion free when viewing reflected light off of the surface. This review needs to be done using floor stand lighting with multiple 500 watt fixtures. Pay special attention to any surface scratches which may not be visible if further away than 6"-12". It is necessary to run your hands over the sheets to affirm a smooth surface in addition to viewing a smooth surface. COLOR MATCH AND CHIP DISTRIBUTION Sanded sheets are visually compared to stored sanded standards at the sanding line. If the visual check does not correlate to the standard, place material on hold pending resolution between the Sander Supervisor and the Color Lab. The stored color standards may be slightly darker than the sanded sheet due to a higher level of fabrication. SURFACE DEFECTS Surface defects such as dirt, streaks, contamination, etc. can be observed either at the QA inspection station or the inspection bridge. These defects are not acceptable. Any one of the following defects, determined by the NEMA LD 3.11 procedure, will cause a sheet to be classified as B grade: • Streaks • One 0.6 square mm or larger foreign particle*. (NEMA spec.) • Any group of three or more foreign particles*, each having an area of 0.3 square mm or larger and occurring within a 12 inch diameter circle on a sheet. (NEMA spec.) • More than 10 foreign particles*, each having an area of .3 square mm or larger per sheet. (Aristech spec.) * Foreign particles may be drilled and filled. This document and the information contained herein are the property of Aristech Surfaces LLC. Copies are issued in strict confidence and shall not be reproduced, copied, or used as the basis for manufacturing or sale of apparatus without consent 25 | P a g e FGS – 0025 **** 9117 Kokura (white-on-white), 7810, and 7921: Due to the light tone-on-tone nature of these sheets, this product color offering is prone to chip contamination from a number of sources. At times, there may be as many as 5 particles as large as 5 to 6 square millimeters in size. This level of contamination is acceptable as A grade material in these colors only. Contamination of a frequency of more than 5 particles per sheet is to be documented as to the relative number and placed on hold. Contamination: Contamination defects will be routed to the Drill and Fill area for repair. All product types and colors can be repaired when less than 15 contaminants are present Bubbles: no bubbles or other type of sheet porosity are acceptable. These include pinhead, hidden or surface bubbles. Sander Induced Chatter: Visible chatter is not acceptable in the finished sheet. Broken corners: Acceptable as long as length/width tolerances are maintained and break is 1/4" or smaller. CALIPER SPECIFICATIONS (UNSANDED INFEED FROM CASTER) Caster Nominal Thickness Low High 0.125 0.133 0.236 0.255 0.260 0.315 0.330 0.375 0.472 0.490 0.500 0.510 0.760 0.110 0.125 0.225 0.240 0.245 0.295 0.315 0.360 0.455 0.475 0.480 0.490 0.745 0.140 0.141 0.270 0.270 0.275 0.325 0.345 0.390 0.491 0.505 0.525 0.535 0.775 0.250 0.225 0.275 Dupont This document and the information contained herein are the property of Aristech Surfaces LLC. Copies are issued in strict confidence and shall not be reproduced, copied, or used as the basis for manufacturing or sale of apparatus without consent 26 | P a g e FGS – 0025 CALIPER SPECIFICATIONS (SANDED OUTFEED FROM SANDER) Finish Caliper Caster Nominal Thickness Sander Nominal Thickness 0.125 0.133 0.236 0.255 0.260 0.330 0.375 0.472 0.490 0.500 0.510 0.760 0.125 0.133 0.225 0.315 0.360 0.460 0.745 Low 0.095 0.110 N/A 0.217 0.217 0.295 0.340 0.453 0.453 0.453 0.453 0.725 High 0.125 0.126 N/A 0.255 0.255 0.325 0.370 0.491 0.491 0.491 0.491 0.755 Maximum Variance Across Sheet .010" Maximum Cupping .100" Width 0" / + 1/4" Length 0" / + 1/2" This document and the information contained herein are the property of Aristech Surfaces LLC. Copies are issued in strict confidence and shall not be reproduced, copied, or used as the basis for manufacturing or sale of apparatus without consent 27 | P a g e Grit Level Finish Product Type MBD MBQ MFD MFW MFZ MGD MGW MGZ MHD MHW MHZ NDW NED NEW NGD NGW NGZ NID NIW NRD Face Back 280 320 280 280 280 280 280 280 280 280 280 280 280 280 280 280 280 280 280 280 50 50 50 Glossy 280 50 Glossy 280 50 Glossy 280 Glossy 50 Glossy 50 Glossy 280 50 Glossy 50 Flip Yes Yes Yes Yes Yes No No No No No No Yes Yes Yes No No No Yes Yes No L. Tungate 6-26-2013 This document and the information contained herein are the property of Aristech Surfaces LLC. Copies are issued in strict confidence and shall not be reproduced, copied, or used as the basis for manufacturing or sale of apparatus without consent 28 | P a g e 5.2 Quality Control of Finished Products at Florence, Kentucky Site Since the packaging is the first view our customers see, it is important that we present a quality product. Packages are labeled with our lot number, barcode, and product type; wrapped or covered as appropriate, banded and shipped to either a warehouse or direct to the customer. With our lot number, we have a link to the batch that created that lot and the testing results from that batch. This data is stored in our system and is accessible to a number of different departments within our facility. Lot traceability enables us to understand everything about the sheets we produced from raw materials consumed, defects scrapped on-line, end customer and how the sheet performed in the customers’ shop. There is data entered into the system throughout the process, including the status of a finished lot of material, whether it is on Hold for additional testing, First Quality inventory or B-grade material. Within our warehouse, we know the location and status of each lot of material. 29 | P a g e 5.3 Packaging and Storage of Finished Products COMPANY CONFIDENTIAL ARISTECH ACRYLICS LLC SJOP 92501 Date Revised : 05/ 06, 2014 S AFE J ob Date Reviewed: May 2014 O perating P rocedure SUPERVISOR Sign-Off: M Collins Packaging Pallets PURPOSE The purpose of this document is to outline the proper procedure for Packaging Pallets at this facility. SCOPE AND LIMITATIONS This procedure is applicable to Departments 81, 87, 92, 95 and 98 personnel responsible for packaging pallets. REFERENCES REFERENCE NUMBER SJOP 92110 SJOP 92103 SJOP 92105 SJOP 92102 REFERENCE TITLE CARDBOARD CUTTING TABLE NAIL GUNS AND STAPLERS MATERIAL DOLLIES DEFINITIONS DEPTS SJOP T.S. FANFOLD AIR KNIFE TAG STRIP DEPARTMENTS SAFE JOB OPERATING PROCEDURE TEAM SUPERVISOR CORRUGATED CARDBOARD USED TO MAKE BOXES ATTACHED TO THE CARDBOARD CUTTING TABLE (SJOP92110) LABEL WITH A SIX DIGIT NUMBER ASSIGNED BY SEQUENTIAL NUMBER GENERATOR AND BARCODE PRODUCT LABEL DESCRIBING PRODUCT TYPE 30 | P a g e DOCUMENTATION Document Number Document Title FP-PKG-CHK-001 Weekly Inspection SAFETY HAZARDS Struck By, Caught Between, Slip, Trip, Strain Pinch Point, Cut by, Saw Dust in Eyes, Puncture Splinters SAFETY EQUIPMENT Safety Glasses with side shields, ear plugs, gloves SPECIAL WARNING When feeding banding from the banding cart to the package always keep (cut end) of banding within 1 inch of the outside part of the pulling hand to reduce possible puncture or cut. HAZARDS Cut by, Puncture. Leather gloves need to be replaced when they are no longer safe to use, torn, oily. As a guideline use the photos below to determine if your gloves need to be replaced. As long as your gloves look like “New” or “slightly used” there should be no problems. When they resemble the “used a lot” photo then replace them with new gloves. Hazards Cut by, Puncture. RESPONSIBILITIES AUTHORITIES 31 | P a g e (A) Departments 84, 87, 92, 95, 98 All (1) Responsible for following this procedure properly and safely. (2) Responsible for checking equipment for obvious wear, loose or missing parts. (3) Responsible for informing Team Supervisor of any condition of saw that might lead to personal injury. (B) Departments 87, 92, 98, 95, 84 Team Supervisor (1) Responsible to follow up on all equipment to be repaired or replaced. (2) Responsible for training of all department operators in this procedure. Responsible for updating and revising this procedure. OPERATING PROCEDURES NOTE: Always be aware of your surroundings. 1. The first step is to locate the pallet(s) required and place the pallet in the packaging area. (Pallets staged outside) 2. Cut fan fold to the exact size of the pallet. The fan fold is 70 inches wide. Larger pallets may require two or more pieces of fan fold. Some pallets 70” and under do not require covering. To cut the fan fold, follow these steps: (SJOP 92110) A. A bundle of fan fold will be at the packaging table. Take hold of the top layer of cardboard and unfold it onto the table. (STRAIN, CUT BY) B. Measure the length required. Use the air knife to cut desired length. (POSSIBLE CUT BY AIR KNIFE.) (SJOP 92110 ) 3. Fasten the fan fold to the pallet using one inch staples. Staple each corner and any loose flaps. A pallet which is prepared and ready for use is called a setup pallet. (PINCH POINT, PUNCTURE.) (SJOP 92103) (AIR HOSES COULD BE TRIP HAZARDS) NOTE: MFB and MBB only pallets will have chip board applied at the filpper and they are not to be stapled. White poly film is applied to the empty pallet at the sawline by Sawline Operators. 4. Using a forklift, place the dolly at the sawline where it is to run. 5. Using a forklift pick up the setup pallet and place the pallet on the dolly. Insure that the pallet is positioned securely on the dolly. 6. When removing a pallet from the line insure that the acrylic is stacked neatly and square on the pallet. Packaging must remove 64x148 single batch pallets and must communicate with the sawline lead man or operators. The saw line operators have difficulty moving the dollies with 32 | P a g e 5,000 pounds on them. To do this you must plan your work around being available to remove these pallets, much the same as Reels and U-Pallets. ACRYLIC COULD SLIP FROM PALLET AND CAUSE INJURY. Make sure the area is clear of Sawline Operators. 92501.2 Packaging a pallet. .21 Measure the length, width and height of the material on the pallet. .22 To determine the size cardboard needed, multiply the height by two, add the width. Finally add one inch to this figure. This is the width of cardboard needed. To determine the length, multiply the height by two and add the length, add one inch to this figure. . EXAMPLE: The material is 36 inches by 60 inches. The material is stacked 8 inches high. To determine the width: 8 inches high x two equals 16 plus 36 inches width = 52 inches plus one extra inch equals 53 inches. To determine the length: 8 inches high x two equals 16 plus 60 inches length = 76 inches plus one extra inch equals 77 inches. The cardboard required to make this box would be cut 53 inches by 77 inches. The width of the fan fold is 70 inches. Boxes which are to be made larger than 70 inches require two or more pieces. Boxes this size should be made using the measurements for the width. (SJOP 92110) .23 Having determined the size fan fold needed complete the box as follows: Except Wilsonart pallets. A. Using a utility knife and tape measure, score each side of the fan fold the desired height of the intended box. Crease and fold each side over. Cut each corner at one crease to make a flap. (ALWAYS CUT AWAY FROM YOUR BODY, POSSIBLE CUT BY KNIFE) Staple each flap with ½ inch staples, 2 to 4 per flap. (SJOP 92103) (AIR HOSES COULD BE TRIP HAZARDS) B. When making two or more piece boxes score only three sides and staple the width end of the box. (SJOP 92103) (AIR HOSES COULD BE TRIP HAZARDS) .24 Put corner protectors on each of the four corners of the acrylic. Place a desiccant packet on top at two of the corners before wrapping. Fold the overlap white poly and tape together to create a nice looking package. NOTE: UNDER NO CIRCUMSTANCES SHOULD TAPE BE ATTACHED TO THE POLY FILM. IT TEARS THE POLY FILM WHEN REMOVED. Place the cardboard box on the material. .25 Banding materials on to the pallet can be done in three different positions and by one or two operators. (SJOP 92102) (1). Material can be elevated using the forklift. Elevate to a comfortable height. GLOVES, must be worn, on both hands. (2). Material can be banded while still on the dolly. In this position gloves must be worn. 33 | P a g e (3). Material can be banded while resting on the floor. SAFETY EQUIPMENT IS WORN TO PREVENT SPLINTERS FROM PUNCTURING HANDS WHEN PASSING THE BANDS THROUGH THE CROSS RUNNERS. OR BEING CUT BY THE PLASTIC BANDING. HAZARD: (DO NOT PLACE BODY IN CONTACT WITH THE PALLET OR PACKAGE THAT IS BEING BANDED. POSSIBLE SPLINTERS, PUNCTURE) .27 Use one band on each Length side of the pallet. This is for all size pallets. (SJOP 92102) NOTE: Wilsonart and Avonite pallets do not get length bands. .28 Place an edge protector on the top edge of the box where the band make contact. The Width side of the pallet requires: a. 2 bands for less than 51 inches and solid surface pallets with WIP tags. b. 3 bands for 51 inches to 80 inches. c. 4 bands for pallets 81 inches to 110 inches. d. 5 bands for pallets over 110 inches, plus one additional band for every 25 inches. 92501.3 Placing tag and labels on pallets. Listed below is the proper sequence for packaging and labeling pallets including Wilsonart. This must be followed to allow the bar code system to work properly and to enhance the package appearance. Note: Do not cover labels with banding! ACRYLIC FAMILY GPA, IGP, GPM, I-3, IGM, S-3, IMA, I3M, CFA, DFA, GF .31 Place a customer information tag label on the upper left hand corner of the front and rear of the package. Place the label one tag width from the corner, and 1/2 inch from the top, just inside the band. Press firmly around all edges of the label to insure proper adhesion. Customer Information Label Tag Strip 34 | P a g e .32 Place a tag strip, 1/2 inch from the bottom and one tag width in from the corner of the cardboard on the lower right of the package, front and rear (See Above). Press firmly around all edges of the label to insure proper adhesion. .33 Place a tag strip and a Customer Information Label, one tag width in, on the left side of the both outside runners. Staple both labels on each end, using the Arrow T-50 stapler and 5/16" staples. Be sure that staples are not placed into the Bar Code section of either label. Tag Strip Customer Information Label .34 Place a product label to the left of the tag strip, 1/2 inch, on the front of the package and 1/2 inch from bottom of cardboard. Press firmly around all edges of the label to insure proper adhesion. .35 Place the HMIS label just to the left of the product label, 1/2 inch, on the front of the package and 1/2 inch from bottom of cardboard. Press firmly around all edges of the label to insure proper adhesion. HMIS Label Product 35 | P a g e SOLID SURFACE FAMILY: MF, MB, MG, MH, TF Use a one inch separation between tag strip and information label. Part # label Information Label Information Label Tag Strip HMIS Label NSF-51 Label NOTE: ALL PERSONNEL ARE TO STAY / REMAIN OUT OF THE WAY OF FORKLIFT AND CRANE OPERATORS IN MOVEMENT. ALL CRANE / FORKLIFT OPERATORS ARE TO LOWER LOADS BEFORE PERMITTING ANYONE INTO THEIR AREA. MATERIALS ARE NOT TO BE STACKED OVER 15 FEET HIGH. HAZARDS: UNSTABLE LOADS AND STACKS COULD TOPPLE AND CAUSE SERIOUS INJURY. .036 Place the pallet in the staging area in E Bay. Packages are to be stacked neatly in this area. REVISION HISTORY Date 01/10 07/11 Rev. 1.0 2.0 05/14 3.0 Section Purpose & Operating Procedure Description of revision Initial Revision Small change in wording. 36 | P a g e 6.0 Disposition of Non-Conforming Materials 37 | P a g e 6.1 Policy and Procedure Aristech’s policy on Non-conforming sheet material is that it will be scrapped (both Acrylic and Solid Surface) if defects are found or downgraded to “B Grade” in the case of Solid Surface products. In addition to sheet products, all incoming raw materials, pigments, etc. will either be re-worked, scrapped, or returned to the vendor depending on the issue and if it can be corrected. Non-conforming material can be detected in several different ways as testing is conducted throughout the process. The first step is to approve all incoming raw materials in R&D. Prior to a batch pouring to the casting machine, there are several different qualities which are tested such as viscosity and reactivity. Once the batch exits the back of the casting machine, an inline camera system, illuminated by 7 high intensity lights, inspects and tags several defects such as air, gels, contamination, etc. In addition to this in-line inspection, the QA operators are obtaining batch samples throughout the batch. These samples are tested for color, caliper, thermal stability, formability, and additional visual inspection. The process is similar for Solid Surface on the Sanding line where every sheet is visually inspected and compared to the standard. 38 | P a g e 39 | P a g e 6.2 Definition of Major and Minor Defects 40 | P a g e 6.3 Complaints Procedure In 2013, our defect rate in the field was 0.20% for all Solid Surface and Polyester Products. Reason 1SD - Improperly Sanded CNP - Poor Pattern 4BD - Bad Color 1MP - Mislabeled Package CWP - Warpage 5CN - Contamination Q9B - Cracking Sink TOTAL Total 34% 31% 14% 8% 7% 5% 1% 100% The chart above shows the defect types experienced by customers in 2013, as classified by ASLLC. The largest defect was the result of new sanding equipment that took time to dial in. This defect was addressed, internally, by the sanding and engineering team. This defect was 34% of our total losses at the customer in 2013. 1. If a customer has a justified issue with our products or service, they would contact their Customer Service or Field Sales rep to begin the credit process. If it is a product specific issue, we request samples showing the defect. Once we have received all relevant information, we issue a credit to the customer. 2. We have regularly scheduled conference calls with 3-4 acrylic bath and hot tub customers every 3-4 weeks. 3. We have conducted Kaizen events for one of our customers in out facility, our lamination partner’s facility, and at the customer’s facility. In this situation, we have an ongoing action item list that includes all 3 parties. 4. We review recent performance and identify any new issue that the customer has experienced with our product. 5. If relevant, we request samples for internal analysis. 6. Internally, we develop corrective action plans that are communicated to our customers for their understanding either in writing or during our conference calls. 7. A detailed review of the credits is done on a monthly basis for all markets and major customers. This information is shared with the manufacturing and sales teams. 8. Product quality credits in our acrylic products were reduced from 2.1% in 2011 to 1.5% in 2012 to 1.2% in 2013. Solid Surface products had a decrease of 0.2% from 0.4% in 2012 to 0.2% in 2013. 41 | P a g e 6.4 Non-Conformance Form and Example Non-Conformance Report This is an internal document to be used in the event of non-conforming product (produced or purchased) or services that we provide or that we purchase. Goal: When an instance of non-conformance occurs, a root cause investigation will be initiated. Based on the findings, corrective actions will be put in place, either internally or with our suppliers/customers to prevent the re-occurrence of the non-conformance. Date Submitted: Send to: [email protected] CAPA# (to be filled in by ASLLC): Customer/Vendor/Product: Lucite Lot: Quantity Delivered: Quantity Defective: Customer/Supplier contact person & email: Detailed Description of Issue: 42 | P a g e Corrective Action Request (Initial response required within 24 hours) Action Initiated by: Request Sources: Service Request Process Monitoring QA Inspection Purchasing CAPA # Customer Complaint/Concern Failure Mode Analysis Risk Assessment R&D QA Inspection Trending Data Management Review Problem Description: Evidence Observed: Preliminary Assessment of Potential Impact and/or Risk: 43 | P a g e Corrective Action/Problem Analysis Date: CAPA# List of Possible Causes and Supporting Data: Analysis Results and Data: Root Cause Determination: Analysis Complete Date: By: 44 | P a g e Non-Conformance Report (EXAMPLE) This is an internal document to be used in the event of non-conforming product (produced or purchased) or services that we provide and that we purchase. Goal: When an instance of non-conformance occurs, a root cause investigation will be initiated. Based on the findings, corrective actions will be put in place, either internally or with our suppliers/customers to prevent the re-occurrence of the non-conformance. Date Submitted: 3/12/13 Send to: [email protected] CAPA# (to be created by ASLLC; format: day of month/month/year/seq#): 03121301 Customer/Vendor/Product: Chemical Express Lot: Wx2f-2081-678972 Qty Delivered: Qty Defective: 40,000# 40,000# Customer/Supplier contact person & email: [email protected] Detailed Description of Issue: High level of contamination and GC not indicating MMA 45 | P a g e Corrective Action Request (Initial response required within 24 hours) Action Initiated by: Jim Cannoy Request Sources: Service Request Process Monitoring QA Inspection Purchasing CAPA # 03121301 Customer Complaint/Concern Failure Mode Analysis Risk Assessment R&D QA Inspection Trending Data Management Review Problem Description: A shipment off MMA was received in a tanker at 8am on 3/21/13. The white bucket test revealed a significant amount of contamination which was black, rust and hard gels. The QC indicated there was a chemical contaminant as well as the particulate contamination. Evidence Observed: Black, rust and hard gels. GC indicated a chemical contaminant as well. R&D is working to identify the chemical contaminant. 3/22: ASLLC R&D has determined the contaminant is methacrylic acid. Preliminary Assessment of Potential Impact and/or Risk: Use of this material in the process poses a high level of risk. This material will NOT be used in production and has been returned to Chemical Express. 46 | P a g e Corrective Action Request (Initial response required within 24 hours) Action Initiated by: Jim Cannoy Request Sources: Service Request Process Monitoring QA Inspection Purchasing CAPA # 03121301 Customer Complaint/Concern Failure Mode Analysis Risk Assessment R&D QA Inspection Trending Data Management Review Problem Description: A shipment off MMA was received in a tanker at 8am on 3/21/13. The white bucket test revealed a significant amount of contamination which was black, rust and hard gels. The QC indicated there was a chemical contaminant as well as the particulate contamination. Evidence Observed: Black, rust and hard gels. GC indicated a chemical contaminant as well. R&D is working to identify the chemical contaminant. 3/22: ASLLC R&D has determined the contaminant is methacrylic acid. Preliminary Assessment of Potential Impact and/or Risk: Use of this material in the process poses a high level of risk. This material will NOT be used in production and has been returned to Chemical Express. 47 | P a g e Corrective Action/Problem Analysis Date: 03/23/13 CAPA# 03121301 List of Possible Causes and Supporting Data: Chemical Express has conducted an initial investigation that has revealed the following: the filter media used to transfer material into the truck, had not been changed when scheduled. The filter, when removed, had several small holes. Additionally, a new line had been installed which included a 3-way valve. It has been discovered that the valve was not seating correctly. Analysis Results and Data: Further investigation has determined that methacrylic acid contaminated the shipment. Root Cause Determination: Chemical Express’s failure to change filter when scheduled. Chemical Express’s failure to thoroughly their operation through maintenance checks and analytical analysis. Chemical Express’s Corrective Action: The mechanic responsible for changing the filter, failed to do so and has been terminated based on this and several other errors. The 3-way valve has been replaced and is on a daily operability checklist for the next 6 weeks. After that, the valve will be placed on a weekly operability checklist for 3 months, and, finally, will be placed on a quarterly operability checklist. This NCR will not be closed until the Actions are completed and functioning properly. Estimated next review is July 30th, 2013 Analysis Complete Date: By: 48 | P a g e 7.0 Measuring and Test Equipment 49 | P a g e 7.1 Standardization of Quality Control Equipment Aristech Surfaces, LLC Instrument Calibration Procedure Date Revised:11/10/10 Authorized By: Origination Date: 2/28/02 Page 1 of 18 PURPOSE This procedure is written to define the requirements necessary for establishing and implementing a n effective calibration control program. The aim of the calibration program is to ensure that all process control instrumentation included in the program is calibrated to within the manufacturer's accuracy specifications or the tolerances required by the process for quality and safety purposes. Documented traceability to either the National Institute of Standards and Technology (NIST) or other applicable agency must be maintained. Guidance is provided on the methods to be used for calibrating various instruments by the Systems Engineer. This procedure is to be used with the work order, calibration worksheet, instrument data sheet, database information, and the manufacturer's manual. When the methods described herein are not practical, consult with the Systems Engineer for a proper method.to document any deviations on the calibration worksheet prior to turning-in the work order and attachments to the Systems Engineer after the job is complete. DISTRIBUTION LIST Manager- Engineering and Maintenance (E&M Manager) (Controlled Copy) Maintenance HPLT Systems Engineer (Controlled Copy) Instrument Technician AMENDMENT PROCEDURE The Systems Engineer is responsible for insuring that the procedures accurately reflect current practices within the area and procedural change requests are initiated as needed. Changes are to be discussed between the Systems HPLT, the Instrument Technician, and others as required. Revisions are to be initialed by the Systems Engineer for implementation and copies re-distributed appropriately. 50 | P a g e Aristech Surfaces, LLC Instrument Calibration Procedure Date Revised:11/10/10 Authorized By: Origination Date: 2/28/02 Page 2 of 18 SECTION 1.0 - TABLE OF CONTENTS SECTION NO. 1.0 2.0 3.0 3.10 3.20 3.21 3.30 3.40 3.50 3.51 3.60 3.70 3.80 3.90 4.0 5.0 6.0 7.0 PROCEDURE TITLE Table of Contents Document Control Calibration Procedure Temperature Calibration Level Calibration Funnel Level Switch Pressure Calibration Speed Sensor Calibration P-1 to 23 & R-1 to 12 Flow Switch R-13/14 Water Flow Meters Chemical Delivery Checks Control Valve Checks MMA Level Sensors pH Analyzer Calibration Procedure Records Inspection, Measuring and Test Equipment Calibration Worksheet Master List CURRENT DATE 11/10/10 11/10/10 11/10/10 11/10/10 11/10/10 11/10/10 11/10/10 11/10/10 11/10/10 11/10/10 11/10/10 11/10/10 11/10/10 11/10/10 11/10/10 11/10/10 11/10/10 11/10/10 51 | P a g e Aristech Surfaces, LLC Instrument Calibration Procedure Date Revised:11/10/10 Authorized By: Origination Date: 2/28/02 Page 3 of 18 SECTION 2.0 - DOCUMENT CONTROL Instrumentation Calibration Documents shall be maintained by the Systems Engineer and include the following: Document Calibration Procedure ·--- ·-·-·- Calibration Worksheet Master list of Instruments Copies - 2 ·- 2 1 These will be controlled copies. Uncontrolled copies will be distributed to plant personnel as needed beyond the numbers shown above. Completed Calibration Worksheets are to be filed for reference per Section 4.0. The Systems Engineer shall initial or sign each page of the Calibration Procedure including the cover of the Master List of instruments. The bottom of each Instrument Calibration Worksheet shall contain the initials of the person authorized to approve completion of work as follows: the Systems Engineer, or the salaried designee as specified in writing by way of an interoffice correspondence per the Systems Engineer or the E&M Manager. The E&M Manager may initial and/or a p p r o ve items in the absence of the Systems Engineer. The Master List of Instruments and Data Sheets can be controlled via an electronic database or file as well as in a hard copy format. Electronically controlled copies will be inaccessible except by the Systems Engineer, the Systems Engineer designee, or the E&M Manager through computer security access control. 52 | P a g e Aristech Surfaces, LLC Instrument Calibration Procedure Date Revised:11/10/10 Authorized By: Origination Date: 2/28/02 Page 4 of 18 SECTION 3.0 -VERIFICATION AND CALIBRATION PROCEDURE The calibration of instruments follows good manufacturing practices and is implemented through the education and experience of the engineers on the engineering staff and instrument technicians or approved contractor. The Systems Engineer shall issue work instructions in the form of a maintenance work order for the instruments to be calibrated or interlocks to be checked, and the work order shall have attached a Calibration Worksheet. Manufacturer’s manuals are c o n s u l t e d on an as needed basis f o r performing calibrations. Once issued, the instrument technician performs the calibration. Any problems encountered are documented on the worksheet. If repairs are required prior to the calibration, t h e s e are made and documented also. Generally speaking, a l l instruments in a control loop are calibrated and a final loop check is performed. The work order and worksheet are returned to the Systems Engineer for disposition and computer entry. The work order is then permanently filed per section 4.0 Aristech Surfaces, LLC Instrument Calibration Procedure Date Revised:11/10/10 Authorized By: Origination Date: 2/28/02 Page 5 of 18 SECTION 3.10 - TEMPERATURE 1. Following the Calibration Worksheet, use the RTD calibrator and send a simulated RTD signal to the temperature transmitter. 2. Verify that the transmitter display is within 0.50 deg F of the simulated calibrator temperature. Calibrate the transmitter as needed. 3. Verify that the DCS display is within 0.50 deg F of the simulated calibrator temperature. Calibrate the transmitter and DCS controller as needed. 4. Recheck the loop by simulating the temperature and re-calibrate as needed. 5. Measure the temperature of the process with the RTD simulator. Connect the RTD to the transmitter. Verify that the transmitter and DCS display are reading the actual temperature correctly within 0.50 deg F. 53 | P a g e Aristech Surfaces, LLC Instrument Calibration Procedur Date Revised:11/10/10 Authorized By: Origination Date: 2/28/02 Page 6 of 18 SECTION 3.20 - LEVEL 1. Following the Calibration Worksheet. 2. Check the device(s) to insure the sensing area is free of material buildup. If cleaning is required, be extremely careful not to damage the sensing area. 3. Fill the vessel to approximately 70% with was monomer to send a pressure signal to the pressure transmitter. 4. Verify that the transmitter display is within 1.0 inches of the actual level. Calibrate the transmitter as needed. 5. Verify that the DCS display is within 1.0 inches of the actual level. Calibrate the transmitter and DCS controller as needed. 6. Check 35% and 0% level by transferring material out of the vessel. 7. Have the operator stroke. The valve ·at 0%, 50%, and 100% open or the open And close position for a valve with on/off control. Control valve isolation using Block valves may be necessary. Verify valve position in the field and feedback to the DCS screen if available. Check for smooth stem movement. Perform a visual inspection of the valve, actuator, 1/P converter and all other valve accessories for proper operation. 8. There are a number of level indicating devices throughout the plant. Be sure to familiarize yourself with the specific requirements for each device and the method of checking necessary for each one 54 | P a g e 55 | P a g e 7.2 Equipment and Production Lines Pigment Room – We produce our own pigment from pigment powders and pastes that are purchased. The manufacturing equipment in this department is predominately high shear mixers and roll mills. On specific pigments, a Hegman grind gage is used to measure particle size to assure that the particles will not break through in the finished sheet. Reactor Room – This is the dept where our batches are produced in a liquid form prior to pouring to our casting machines. Manufacturing equipment involved in this area are pumps, automatic valves, high shear mixers, flowmeters, pressure rated vessels between 500 and 1000 gallons, etc. The main processes in this dept are the pre-polymerization of methylmethacrylate to syrup with 20% solids which enable manageable flow to our casting equipment. Temperature and pressure are critical parameters to manage during polymerization. The ATH dispersion process “feeds” this part of the process for our solid surface production. Both of these areas are controlled by DCS. Quality measures taken during the process are viscosity (Brookfield), agitation speed, temperatures, pressures, and volumes (lbs). An additional piece of equipment measures the chemical structure of specific chemicals to validate that the right material is being delivered. Casting – The core of our operation is our 4 continuous casting machines. These machines are controlled by Wonderware (PLC). The parameters of most importance to our final product are speed, zone temps, caliper, and torque. As far as delivery, the casting department expects material that has correct amounts of reaction chemicals and proper viscosity. Reactivity and viscosity are quality checks measured on the front end of the casting machine before a batch begins to pour. The casting machine team enters the time when the batch begins to pour, the sku and the pour width. Sawline – The main function of the sawline is to cut the sheets to the size required. In addition, the sawcuts are measured 1 sheet of a lot for adherence to spec. The sawline time also provides an extra set of eyes with which to identify defects before placing material onto the customers’ pallets. Quality Assurance - The quality assurance team measures the following characteristics of all batches produced: caliper is measured at predetermined distances across the width of the material, color is measured on Spectrum 550 Data Color readout, and a hanging thermal is performed on each batch to verify that the formability of the batch will be within specification. In addition, a 36”x 28”sheet is formed to detect for contamination, air, etc. A review of the material is visually performed to detect defects and to prevent them from going to the customer. In addition, lot numbers are automatically generated when a lot is created. Lot number generation is sequentially generated. Packaging – The packaging team assures the packaging material is correct and that all applicable labels have been adhered to the outside of the package. In addition, when treated pallets are required, this is another responsibility for the packaging team. 56 | P a g e Shipping – Packaged material (whether 1st quality or scrap) are shipped to an outside warehouse, about 3 miles from the plant where it is stored pending shipment. The shipping department also has the ability to cut down material and create pallets for customers from inventory. All of the departments have the responsibility for entering all pertinent data into our database that details the specific results of tests performed in their areas. 7.2 Equipment And Production Lines Major Equipment Continuous Casting Machines Number of Lines/Eqt 4 Reactors 10 Promoters 19 ATH Silos 4 ATH Dispersion Mix Tanks 2 Sheet Cutting Saws 7 Sander and Sheet Moving Eqt 1 57 | P a g e 8.0 Labeling, Traceability, and Records 58 | P a g e 8.1 Policy of Traceable Label and Records NO material is shipped from ASLLC without a label which includes a lot specific ID. This lot specific ID is the lot number. This lot number tells us all that we need to know for identification. With the lot number, we will be able to tell when the material was produced, on which machine it was produced, the physical dimensions of the sheet, the qty of the sheets, what raw materials were used, what defects were encountered during casting, the yield of the batch and to whom the lot was sent to. All of this information is driven by the lot number. All of these records, which make up the details about the lot, are kept in our database. Changes to a lot number, i.e. sheets removed, are adjusted in the database and tracked by user and date. 59 | P a g e 9.0 Policies and Instructions for Third Party Inspections 60 | P a g e 9.1 Policies and Instructions for Third Party Inspections and Listing Mark A Third Party Inspection is defined as “Testing not performed by any parties who might financially profit by 3rd Party Test outcome.” Examples of testing we have had performed by outside testing organizations include Underwriter’s Laboratory (UL), National Science Foundation (NSF), French VOC Regulations per ISO 16000, and International Maritime Organization (IMO), to name a few. A third party inspector may meet with an employee of the company from any of a number of areas (R&D, Sales & Marketing, Production, Quality, etc.). In third party inspections, a representative from a testing organization would review the focus of the inspection with a member from the area about the subject at hand. Most of the following items would be generally reviewed for most third party inspectors: - History of the organization Review of product line and applications Plant and Laboratory tour Sources and internal testing of raw materials Data acquisition within the process Material traceability Once the Third Party inspection was completed, samples may be tested on site or sent to a testing facility. If the material tested, passes, then a Listing Mark may be authorized for use by the organization requesting such certification. If the products did not pass the testing, a Listing Mark would not be allowed to be used for that product and company. 61 | P a g e 9.2 Quality Control Manual Revisions and Inspections The Quality Control Manual will be reviewed for revisions and additions on a two year cycle. In addition, we will inspect the part of the process that is currently being reviewed/updated in the same month. The plan is to have a group of 3-4 employees that will spend up to 1 day on each of these areas. With a team that is knowledgeable about the focus area, we can divide and conquer the review and revisions. The schedule will be as follows: Section 2: General Information Feb of 2014 Completed Section 3: Incoming Materials May of 2014 Completed Section 4: Manufacturing Process Aug of 2014 Completed Section 5: Finished Products Nov of 2014 Section 6: Disposition of NonConforming Material Feb of 2015 Section 7: Measuring and Test Equipment May of 2015 Section 8: Labeling, Traceability, And Records Aug of 2015 Section 9: Policies and Instructions For Third-Party Certifications Nov of 2015 62 | P a g e 9.3 Reviews and Updates Review Date Subject Participants February’14 General Information Sebastian Joseph May ’14 Incoming Materials Jim Cannoy Aug ’14 Manufacturing Process Mel Collins 63 | P a g e LAST PAGE 64 | P a g e
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