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There have been ten OSHA inspections of other Ketchikan Pulp Company facilities 

 including the Annette Hemlock Mill, Ketchikan Saw Mill, Shelter Cove logging camp, 

 Thome Bay Sort Yard and Shop and the Ward Cove wood room Five were voluntary, 

 one resuhed from an injury, and three resulted from or complaints The injury related 

 inspection resulted in a fine of $16,000. A total of $4,000 was paid in fines as a result of 

 all other inspections. 



Ketchikan Pulp Company has a proactive safety management program which includes cash 

 safety awards to employees. Over $1 million has been spent on proactive programs since 

 1991. 



Employee Training and Development 



Ketchikan Pulp Company involves employees throughout all divisions in discovering and 

 fixing the root causes of compliance problems, and seeking solutions which are designed 

 to prevent the recurrence. Planning for environmental compliance is now integrated with 

 planning for product development, process changes, and power plant operations to be sure 

 that production is achieved without compromise to environmental results 



Ketchikan Pulp Company has had success in involving employees in several company wide 

 efforts to improve performance. The Total Quality Commitment program trains each 

 employee in how to contribute to product quality The STOP program trains each 

 employee in how to recognize and stop unsafe acts in the workplace The Company 

 believes that knowledge of environmental requirements accompanied by the daily exercise 

 of individual good judgment on the part of all employees will achieve the commitment and 

 momentum necessary to achieve good results. 



Ketchikan Pulp Company has introduced an Environmental Compliance program that 

 includes engineering, construction, process changes, material substitutions and employee 

 training Employee training is a key element of the program A comprehensive training 

 program for KPC was developed in December, 1995 The program includes job-specific 

 training for KPC's production personnel and general environmental sensitivity/awareness 

 training for all management, administrative and operations personnel The training 

 program was developed in two stages: 



1 . Corporate Responsibility/Business Ethics/Environmental Overview Training. 



2. Mill Operations Training for Environmental Compliance 



The first stage represents training requirements that apply equally to all KPC personnel 

 with emphasis on Corporate Responsibility. This training was completed for all company 

 employees in June, 1996. The second stage involves training requirements that apply to 

 all mill operations personnel. This stage is currently underway. 



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