2011 PARTNERSHIP AGREEMENT
BETWEEN
OSHA, MIOSHA, UAW INTERNATIONAL UNION,
THE FORD MOTOR COMPANY, AND ACH-LLC

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Partners

The following partners to this agreement include the U.S. Department of Labor, Occupational Safety and Health Administration (OSHA); Michigan Occupational Health and Safety Administration (MIOSHA), International Union, United Automobile, Aerospace and Agricultural Implement Workers of America (UAW); the Ford Motor Company (Ford) and Automotive Component Holdings, LLC (ACH-LLC). This agreement covers all Ford Motor Company and ACH-LLC locations as described in Appendix A.

The Ford Motor Company, ACH-LLC, OSHA and MIOSHA recognize that certain Ford Motor Company and ACH LLC facilities are located in States which have assumed authority for the enforcement of OSHA standards pursuant to Section 18 of the Occupational Safety and Health Act.

Purpose/Scope

The partners agree to construct a partnership based on mutual respect and trust that leverages the resources of all the parties through the systematic anticipation, identification, evaluation and control of health and safety hazards at Ford Motor Company and ACH-LLC locations, thereby continuously reducing worker injury and illnesses.

Goals/Strategies/Measurements

The primary goal of this partnership is to reduce injuries and illnesses year-over-year from baseline OSHA log summary data at each Ford Motor Company and ACH-LLC location through the creation of a pro-active health and safety culture and a cooperative non-adversarial relationship that optimizes the resources of all parties. Performance metrics used to monitor and track health and safety process performance shall include the Total Case Incident Rates (TCIR) and Days Away, Restricted and Job Transfer (DART) rates. The participants may present information collected and reported using Safety and Health Assessment Review Process-Safety Operating System (SHARP-SOS) tools and on OSHA-MIOSHA Day visits where that information has been contributory to achieving the goals of the partnership.

Evaluation

A written annual evaluation will be developed by OSHA and it will address trends noted in the injury and illness data based on a calendar year. Among the information included in the evaluation will also be an analysis of the employer's internal audit results, protocol-related analysis and the results of the OSHA-MIOSHA Day visits for the individual participating sites.

Benefits

• Benefits will include inspection protocols (used to perform focused inspections) and the diminished probability of wall-to-wall inspections under OSHA targeting programs. The inspection protocols will result in shorter more focused inspections. Inspection protocols address top causal factors of injuries and illnesses previously identified by the partnership.
• In addition, provided that the Ford or ACH-LLC facility is following the Ford and ACH-LLC programs and joint processes, OSHA-MIOSHA agrees to maximum penalty reductions based on the agency's current policies for good-faith reductions for effective safety and health programs as detailed in the current version of OSHA's Field Operations Manual.

Verification

Annually, 33% of the participating sites will receive an "OSHA-MIOSHA Day Onsite Non- enforcement Verification Visit". The date of the OSHA-MIOSHA Day visit will be determined by the corresponding OSHA Office in conjunction with the site. Sites will provide a predetermined OSHA Day Information Package, which includes their OSHA 300 log and SHARP-Safety Operating System information for the previous year to the appropriate OSHA-MIOSHA Office at least two weeks prior to the scheduled OSHA-MIOSHA Day visit. OSHA-MIOSHA representatives will review this information prior to the OSHA-MIOSHA Day visit.

The selection process for identifying sites that will receive OSHA-MIOSHA Day visits will be developed by the Partnership Steering Team during their first meeting after the signing of this agreement and annually thereafter.

OSHA-MIOSHA Day Meeting

Annually, 33% of Ford and ACH-LLC locations covered by this agreement (see Appendix A) will conduct an annual OSHA- MIOSHA Day visit where the appropriate local OSHA-MIOSHA representative(s) will be invited to the location and briefed by the Plant Manager, the Union Chairperson and their leadership team. The briefing will include a review of the injury and illness experience for the past year and any developing trends as compiled by OHSIM. The briefing will also include a review of results from continuous internal comprehensive inspections conducted by the Plant Safety Engineer and the Unit Health and Safety Representative and the corrective actions taken. Additionally, the briefing will include the results of the Safety and Health Assessment Review Process-Safety Operating System (SHARP-SOS) conducted since the last OSHA-MIOSHA Day meeting and the corrective actions taken. The written materials from the OSHA-MIOSHA Day meeting will be given to the appropriate OSHA-MIOSHA partnership representative(s) for analysis, including Ford site managers, the UAW, and OSHA's National Office.

During the OSHA-MIOSHA Day, OSHA-MIOSHA will conduct an informal walk-through of the facility. The purpose of the walkthrough is to verify that the information presented in the OSHA-MIOSHA Day briefing is an accurate portrayal of what is occurring within the facility. If observable conditions and program implementation are not consistent with the information provided at the OSHA-MIOSHA Day meeting, a focused inspection could be initiated and expanded to a traditional inspection with the approval of the OSHA-MIOSHA representative. During the visit, if OSHA-MIOSHA personnel identify serious hazards that site management refuses to correct, OSHA-MIOSHA will make a referral for an enforcement inspection.

OSHA may return at a later date for a monitoring visit as an extension to the OSHA-MIOSHA Day visit, to investigate complaints, referrals, and to perform Site Specific Targeting (SST) inspections at partnership plants. Monitoring visits are considered enforcement visits, and as such citations may be issued at that time. The OSHA National Office will be notified when a monitoring visit is scheduled. The OSHA-MIOSHA members of the steering committee will coordinate the monitoring visits.

It is understood that items identified as opportunities for improvement by OSHA-MIOSHA will be prioritized for action, with timing milestones as determined by good health and safety practice and by joint agreement of Ford, ACH-LLC, UAW-Ford and UAW-ACH LLC Health and Safety Professionals. If these tenets are adhered to, OSHA- MIOSHA will not use this information as justification for Willful violations. In general, items identified by Ford, ACH-LLC and the UAW or OSHA-MIOSHA will be abated immediately where practicable, and those will not result in OSHA citations.

Inspection Protocols

Inspection protocols will be based on the annual analysis of U.S. injury and illness experience from the Occupational Health and Safety Information Management (OHSIM) System and from similar analyses provided OSHA for the location selected for inspection. In general, the protocol will include an investigation of hazards or issues covered under joint programs developed by the National Joint Council on Health and Safety (NJCHS). See Appendix B for a list. Protocols may be added/removed via steering committee consensus without making modifications to this agreement.

Management and Operation of Partnership

A steering committee will be designated consisting of members from Ford, ACH-LLC the UAW, and OSHA-MIOSHA. OSHA-MIOSHA steering committee representatives will consist of representatives from OSHA's Directorate of Cooperative and State Programs (DCSP), OSHA Region V, Michigan OSHA, and from any State Plan states who sign similar agreements with the partners. The purpose of the steering committee will be to develop an implementation plan, review data and reports, and to meet as appropriate to resolve any issues that arise during the course of this partnership. The steering committee will also be involved in the coordination of site visits and monitoring inspections.

Ford/UAW and ACH-LLC/UAW

1. Ford and ACH-LLC will provide a complete OSHA Day information packet to the appropriate OSHA-MIOSHA Office 2 weeks prior to the scheduled OSHA-MIOSHA Day.
2. Ford and ACH-LLC agree to facilitate the inspection process by providing OSHA-MIOSHA compliance officers access to the plant injury and illness reports related to the protocols.
3. A corporate annual report for Ford and ACH-LLC will be developed and presented at an annual national meeting between the parties. The report will address trends noted through data analysis. Among the information included in the annual review will be an analysis of the internal audit results, and information from each site's verification report. This report should additionally discuss progress towards meeting the partnership goals.

OSHA-MIOSHA:

1. OSHA-MIOSHA will continue to make maximum use of inquiry letters, phone and fax procedures for minor investigations.
2. OSHA MIOSHA inspections to investigate employee complaints, serious injuries or fatalities, and National or Local emphasis programs are not precluded by this agreement.
3. Ford and ACH-LLC plants selected for General Schedule inspections from the OSHA Site-Specific Targeting (SST) list will receive a focused inspection. The focused inspection will include an evaluation of the inspection protocols listed in the agreement.
4. The OSHA-MIOSHA compliance officer will review the required recordkeeping information; conduct a walk through inspection, and interview workers in accordance with OSHA inspection procedures.
5. OSHA-MIOSHA will complete and submit an OSHA-MIOSHA Day Report within 30 days of the annual OSHA-MIOSHA Day for each site participating in the partnership. Reports shall be forwarded to OSHA's National Office, Ford and ACH LLC Corporate Safety personnel, and UAW-Ford Joint Health and Safety Leadership. The OSHA-MIOSHA Day report template can be found in Appendix C of this document.

Employee and Employer Rights

This partnership does not preclude employees and/or employers from exercising any right provided under the OSH Act (or, for federal employees, 29 CFR 1960), nor does it abrogate any responsibility to comply with rules and regulations adopted pursuant to the Act. For MIOSHA, the provisions of this agreement identified herein, shall not modify any legal or contractual rights and remedies.

Employee awareness and involvement will be facilitated through the contractual processes developed by Ford, ACH-LLC and the UAW.

Term of Partnership

This agreement will terminate on December 31, 2013. The partnership will end with respect to an ACH-LLC facility upon the sale, closure, or transfer of operations to a third party at the facility. If any signatory to this agreement wishes to modify, amend or terminate their participation prior to the established termination date, written notice within 30 days shall be provided of the intent to withdraw to all other signatories and this agreement will terminate as to the party withdrawing on that date.

2011 PARTNERSHIP RENEWAL AGREEMENT
Signature Page

OSHA, MIOSHA, UAW INTERNATIONAL UNION,
THE FORD MOTOR COMPANY, and ACH-LLC
April 8, 2011

APPENDIX A

Participating Sites within Federal OSHA Jurisdiction

Participating Sites in Michigan (State Plan OSHA Jurisdiction)

*ACH-LLC LOCATIONS (Michigan)

Appendix B

Inspection Protocols

1. Ergonomics
2. Energy Control and Power Lock Out (ECPL)
3. Confined Space Entry
4. Hearing Conservation and Noise Control
5. Lifting and Rigging
6. Machine/Equipment Guarding
7. Heat Stress
8. Personal Protective Equipment (PPE)
9. Chemical Safety Training (Hazard Communication)
10. Powered Material Handling Vehicles (PMHV)
11. Maintenance Vehicles
12. Working at Heights
13. Electrical Safety
14. Emergency Preparedness
15. Walking and Working Surfaces

Note: Protocols may be added/removed via steering committee consensus without making modifications to this agreement.

Appendix C

OSHA-MIOSHA DAY REPORT TEMPLATE

1. Date:
2. Plant Name/Location:
3. Key Participants:
   • Ford/ACH:
   • UAW:
   • OSHA:
   • MIOSHA:
4. Observations from Walk-Around:
5. Top 3 Opportunities for Improvement (Please include a follow-up date for each "Opportunity" to check on progress/resolution)
6. Best Practices Observed:
7. Injury and Illness Trends Recordable Rates [Last Three Years]

   (NOTE: See discussion of injury & illness statistics in section 8 of this report.)

   YEAR Current YTD and prior two full years	Hours	Total Recordable Injuries and Illnesses	TCIR	Total cases with Days Away from Work	LTCR	Total Cases with Days Away from Work or Restricted Activity	DART
   *Current
   Year 2
   Year 3

   *Year to date

8. Discussion of Injury and Illness Trends:
9. Outstanding/Overdue Items from Previous SHARP-SOS SELF ASSESSMENTS:
10. Noted Issues of Non-Compliance (if any)
11. Discussion of SHARP-SOS Results Trends:
12. Monitoring Visit Recommended? __Yes __No

    Reasons:
    __ Protocol issue: _____________________________________
    __ Record-keeping issue: _______________________________
    __ Other Compliance issue: _____________________________
    __ Employee Interview Results: __________________________
    __ Other: ____________________________________________
    

13. Other Comments: