Peta Blok Area Kebun Hapesong Peta Blok Area Kebun Sisumut Peta Blok Area Kebun Aek Nabara Utara Peta Blok Area Kebun Batang Toru Peta HCV Kebun Hapesong Peta HCV Kebun Sisumut Peta HCV Kebun Aek Nabara Utara Peta HCV Kebun Kebun Batang Toru Peta Topograf

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1. Peta Blok Area Kebun Hapesong

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2. Peta Blok Area Kebun Sisumut

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3. Peta Blok Area Kebun Aek Nabara Utara

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4. Peta Blok Area Kebun Batang Toru

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5. Peta HCV Kebun Hapesong

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6. Peta HCV Kebun Sisumut

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7. Peta HCV Kebun Aek Nabara Utara

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8. Peta HCV Kebun Kebun Batang Toru

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9. Peta Topografi Kebun Hapesong

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10. Peta Topografi Kebun Sisumut

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11. Peta Topografi Kebun Aek Nabara Utara

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12. Peta Topografi Kebun Batang Toru

SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES Sucofindo ICS FRM 3.04 Issue 04 Rev. 6 86of 117 Appendix 2 NCR ATTACHMENT SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES Sucofindo ICS FRM 3.04 Issue 04 Rev. 6 87of 117 Preliminary Audit C. 3. Non Conformity Registers NCR No. P C Description of Nonconformities Company response and proposed action to be taken Result of Auditor Verification Status 1 6.3 Major There was a conflict resolution that was lack of transparency, not effective and unable to ensure the solving problem complete. Data in the Batu Godang Village, Hapesong Estate, was found and there were members of society who had yet to receive compensation tenants, while the organization had given the compensation by representative who could not be ascertained. DTAPS, KHPSG Correction: Identifying back the names of tenants of Batu Godang Village who have received compensation and inviting the representative who received the compensation by discussing together and preparing evidence of implemented compensation. Corrective Action:  Preparing data of tenants in the early phase.  Preparing evidence of compensation result.  Inviting tenant community of Batu All members of society are confirmed to have received compensation during certification audit. CLOSED SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES Sucofindo ICS FRM 3.04 Issue 04 Rev. 6 88of 117 Godang Village and representative who received the compensation for discussion 2 6.3 Major Conflict in Sumuran Village, Batang Toru Estate was found where the resolution conflict could not be ascertained because of difference of compensation value between organization and village community. DTAPS, KBGTU Correction: Approaching to the community and making a mutual agreement on the compensation value as well as coordinating with relevant section in the director’s office for its approval. Corrective Action:  Identifying the names of Sumuran’s Villagers who deserve to receive compensation.  Inviting Villagers of Sumuran to discuss together in the agenda of mutual agreement regarding to the given compensation  Sending a letter to the director’s office regarding to the compensation value  Preparing all documents of Case can’t be closed, it is still open OPEN SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES Sucofindo ICS FRM 3.04 Issue 04 Rev. 6 89of 117 resolution conflict process and the current progress which has been agreed. 3 6.4 Major Data and procedure or work instruction were not found regarding to identification process for the loss of community right in ensuring appropriate compensation process. All Correction: Socializing and ensuring documentation of IK- 3.09-0302. Corrective Actions :  Indentifying entire community around the plantation particularly concerning dispute resolution plan with compensation process.  Socializing the resolution conflict to the community. Data and procedure or work instruction have been available regarding to identification process for the loss of community right. CLOSED 4 1.1 Major Complaint record was found but there was no any respond record for expressing the complaint and ascertainment of resolving the problem. It was found in the Marancar Villange where minute book had been submitted by local stakeholders and signed by Subdistrict Head in June 2011 as for Environmental pollution and Flooding due to bad quality of plantation irrigation system and the company did not keep its promise. Correction : Responding the letter and minutebook from the community of Marancar Village and Arranging follow-up plan of irrigation facility improvement by involving the community in coordination with local government. It cannot be closed because a new NCR arises. OPEN SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES Sucofindo ICS FRM 3.04 Issue 04 Rev. 6 90of 117 Corrective Actions :  Re-identifying the proposed petition from the community of Marancar Village related to the improvement of irrigation facility.  Making improvement plan and coordinating with relevant parties.  Performing discussions together with the community of Marancar Village related to follow-up of implementation. 5 2.1 Major  There is no evidence of an attempt to make adjustment to the changes in the regulation on the plantation units of Batang Toru and Hapesong as required in work instruction No. IK.3-11.0101 Rev.02 on 02.06.2009. Correction : Making adjustment and change in regulations in the way of updating regularly and ensuring the most recent available change in regulations. Corrective Actions :  Re-enlisting all related regulations.  Evaluating and making follow-up its obedience plan. It cannot be closed because it has not been updated to the new regulations, such as The Kyoto Protocol so that a new NCR rises. OPEN SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES Sucofindo ICS FRM 3.04 Issue 04 Rev. 6 91of 117  There was no ascertainment of relationship or connection in obedience with procedure, work instruction or related document.  List of obedience documents for the regulation related to RSPO in PKS Sei Baruhut unit have not been available.  Updating the most recent regulation in recent. Correction : Revising regulatory compliance evaluation form by adding the reference column and distributing it to the plantationunit and district. Corrective Actions :  Re-enlisting all related regulations.  Evaluating and making a follow-up its obedience plan, also identifying IK and related documents. Correction : Making list of related regulation and making evaluation and arranging follow-up plan for the compliance. Corrective Actions :  Re-enlisting all related SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES Sucofindo ICS FRM 3.04 Issue 04 Rev. 6 92of 117 regulations.  Evaluating and making follow-up its obedience plan. Updating the most recent regulation in recent. 6 4.6 Major Organization has not been able to ensure Agrochemical wastes and pesticide packagings have been managed, controlled and disposed by the reference to the regulation in force that is PP No.18 in 1999 on Waste Management B3. Correction : Revising IK-3.03-0102 by including all chemical packagings into Waste B3. Corrective Actions :  Arranging IK-3.03- 0102.  Performing socialization to all workers in the field to control all ex-chemical packagings. IK has been reviewed but it can not be confirmed the effectiveness of enforced IK. Implementation in plantationfactory and necessary changes must be carried out to the impact aspects. OPEN 7 4.8 Major Company did not establish traning program for employees in documentary Correction : Conducting a training program according to the necessities and arranging the follow-up implementation plan. Corrective Actions :  Identifying training necessities. Company has made a correction act by conducting training program according to the necessities. CLOSED SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES Sucofindo ICS FRM 3.04 Issue 04 Rev. 6 93of 117  Conducting a program and arranging the follow-up implementation plan.  Making report. 8 5.6 Minor Organization has not made identification of the sources of greenhouse gases generated from plantation activities and PKS, such as fertilization activities, transportation, waste ponds. Organization has not also had plans to conduct reduction for greenhouse gas emissions caused by company’s activities. Correction : Making IK about identification mechanism of the sources of greenhouse gases, socializing and making plans to reduce emissions caused by company’s activities. Corrective Actions :  Arranging IK about identification mechanism of the sources of greenhouse gases  Identifying all existing operational activities in the plantationfactory.  Making planning program of greenhouse gas emission reduction. It has not been decided by identifying all sources of greenhouse gas emissions from land clearing, planting, maintenance, harvesting, and office activities and any other activities. OPEN 9 2.1 Minor Organization has not ensured how the mechanism for compliance evaluation with legal requirements and other applicable Correction : Completing the permit of The determined IK has not been consistent related to the absence of OPEN SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES Sucofindo ICS FRM 3.04 Issue 04 Rev. 6 94of 117 regulations and associated with the organization’s activities. Such as Batang Toru plantation and Hapesong plantation which didn’t have permit for TPS Waste B3 while PKS Sisumut, their permit of TPS Waste B3 have been expired since March 2010. TPS waste for KBGTU, KHPSG, and PSSUT. Corrective Actions :  Re-enlisting all existing TPS waste B3.  Coordinating with section 3.03 to process the permit.  Distributing all permits of TPS waste B3 any requirement identified as ratified international legislation on global warming and the follow-up that has not been performed. 10 4.3 Minor The recording of follow-up about broken bridge in Hapesong, Afdeling V TT.1999 has not been found according to a report in 2011 Correction : Following-up the plan for repairing the bridge in Afd.V Corrective actions :  Arranging plan for repairing the bridge  Coordinating with related sections Evidence has been found to be recording an email to the director of the production regarding bridge repair plan. CLOSED 11 4.5 Minor a IPM program according to the IK-3.01- 1714 rev.6 on 06-05-2011 consisted of mechanical, biological and chemical control, however in Hapesong and Batang Toru plantation had not been found records of monitoring for the extent of IPM concerning to biological control agent Correction : Performing IPM monitoring program in all afdelings with biological control, also recording and documenting its realization control. Corrective Actions : Structures organization and IPM programs have been already available. CLOSED SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES Sucofindo ICS FRM 3.04 Issue 04 Rev. 6 95of 117 b Training records IPM for employees in Hapesong plantation have not been found. c The company has performed monitoring use of pesticide on oil palm SE No.301SE192011, for example the active substance, Isopropil amina glifosat in Batang Toru and Hapesong plantation.  Establishing IPM team in every afdeling.  Making and arranging IPM program.  Performing biological control through planting the flowers at 8.00 A.M.  Documenting the result of monitored area. Correction : Arranging training program IPM to all IPM officers in Afdeling. Corrective Actions :  Enlisting employees who are in charge of IPM.  Making IPM materials  Performing IPM training. Correction : Performing monitoring program area for application the use of SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES Sucofindo ICS FRM 3.04 Issue 04 Rev. 6 96of 117 However the monitoring unit for toxicity of the pesticide has not been found the active substanceLD 50 per tone of FFB per hectare pesticide active substance per hectare in every afdeling according to the SE 3.01SE192011. Corrective Actions :  Re-enlisting all realization and planning use of chemical substance in afdeling.  Calculating the active substance used per hectare. 12 6.9 Minor The company has determined a policy concerning to the protection of sexual harassment in Code of Conduct, Section IV. Furthermore, it is followed with social dissemination to all employess and labor contractor company BLH. Nevertheless, not all workers have proof to be receiving the information. This is showed from attendance list in the dissemination, for example :  In Batang Toru Estate, where about 528 of total employee data taken in 1 November 2011 only 29,9 were present.  In PKS Sisumut, from 171 employee, only 15 were present. However, programs for the socialization have not been determined Correction: Making and arranging socialization program for employee and BHL who have not received the socialization. Corrective Action:  Enlisting employee and BHL who have not received the socialization  Doing Socialization. The implementation of socialization concerning to the protection of sexual harassment is added with worker from BHL according to the list in each afdeling. CLOSED SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES Sucofindo ICS FRM 3.04 Issue 04 Rev. 6 97of 117 Certification Audit C. 4. Non Conformity Registers NCR No. P C Description of Nonconformities Company response and proposed action to be taken Result of Auditor Verification Status 1 7.3 Major There is no identification of HCV on the development area of Muara Upu so there was no record evidence of map and realization planning for opening land corresponds to identification of HCV. Correction: Identification of HCV was done by team from IPB Bogor excluded Muara Upu Corrective Action: Making identification plan for HCV in the development area of Muara Upu. Management plan related to recommendatio n report of HCV was not found. OPEN Handled by BHCV WG- RSPO 2 6.3 Minor Problems about difference of compensation value between company and Sumuran Village, Correction: There is no agreement of compensation value for payment of land right farmed by tenants. They ask 50 million rupiahHa while the company is only able to give 5 million rupiahHa. Corrective Action: Minor non conformity will see the solution on the next surveillance. OPEN SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES Sucofindo ICS FRM 3.04 Issue 04 Rev. 6 98of 117 Batang Toru Estate still exist. This is related to transfer of land with wide range of 175,84 Ha farmed by farmers. Making solution for time bound plan on the land in 2012. 3 1.1 Minor Complete solutions associated with expressing the complaint on environtmental pollution in the Marancar Village, Batang Toru plantation have not been found. Correction : Following-up letter from Marancar Village about environtmental pollution by testing the water in the population to BAPEDALA. Corrective Actions : Following-up all incoming letters from stakeholders to be immediately followed-up according to IK 3.00-1301. For example, water test at Marancar Village to Health Agency in Tapanuli Selatan District Letter No. KBGTUX3992011, on 23 December 2011. No result of water analysis to ascertain whether the Marancar River was polluted or not. OPEN 4 6.9.1 Minor The company have determined a policy concerning to the protection of sexual harassment in Code of Conduct, Section IV. Furthermore, it is followed with socialization to all employess and labor contractor company BLH. Nevertheless, not all workers had Correction :  When audit is being carried out, most of employees of KANAU have not received social dissemination of sexual harassment protection as well as most of contractor personnel. Corrective Actions : Aek Nabara Utara Plantation has performed social dissemination of sexual harassment to all employees of KANAU and contractor personnel working in KANAU. Performing the social dissemination of sexual harassment to all employees CLOSED SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES Sucofindo ICS FRM 3.04 Issue 04 Rev. 6 99of 117 proof to be receiving the information. This was showed from attendance list in the socialization. In Aek Nabara Utara plantation, where from the total of 724 employees data taken in 11102011 only 345 employees were present, and it had not been planned when the program will be socialized again. 5 4.7.2 Minor The company had performed annual health check periodically, especially to the workers who work in hazardous area. However, its actions were not effective. This was proved from the absence of cholinesterase examination, as found in Kanau Correction : When audit is being carried back to the employess referred to 11 workers, it has not been done because The Aek Nabara Utara Plantation assumes that health check of Hiperkes heldconducted by Section 3.12, The Director of Medan Office. Corrective Actions : The Aek Nabara Utara has requested a letter to the Section 3.12 to conducthold recheck to those 11 workers of KANAU. Company has made a written request to carry out the re- examination of the 11 workers. CLOSED SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES Sucofindo ICS FRM 3.04 Issue 04 Rev. 6 100of 117 plantation where a sampling of 12 workers were taken, there were 11 detected workers. Doctor recommendation in 15 November 2010 states that they could continue to work as long as health check was performed after 6 month. This should be done in May 2011, but it has not been done. 6 2.1.2 Minor Organization has not ensured exactly how to identify and evaluate the compliance of regulation and other requirements which have referred to the set of IK. For instance: some still could not be ascertained that many ratified international Correction : Documenting the most recent regulation such as Kyoto Protocol and Montreal Protocol and evaluating to make follow- up plan. Corrective Actions : Updating the most recent regulation and coordinating with section 3.11. Responses are correct but they have not been provided with evidences. OPEN SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES Sucofindo ICS FRM 3.04 Issue 04 Rev. 6 101of 117 regulations have been identified, such as Kyoto Protocol and Montreal Protocol. Then, there was no follow-up program from evaluation in compliance the regulations and other requirements that had not been fulfilled at the present. 7 5.6 Minor Organization has not determined how to identify sources of greenhouse gases generated from plantation activity as well as from PKS, such as fertilizations, offices, transportations, and produced waste materials. Organizations must define how organizational plans can reduce greenhouse gas Correction : Revising IK-3.12-0601 by adding identification of aspects from sources of greenhouse gases. Corrective Actions : Identifying from all plantationPKS activities to produced waste. KHPSG: Company has identified from all plantationPKS activities to produced waste. KSSUT: Company has identified from all plantationPKS activities to produced waste. KANAU: CLOSED SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES Sucofindo ICS FRM 3.04 Issue 04 Rev. 6 102of 117 emissions caused by company’s activities. Company has identified from all plantationPKS activities to produced waste. 8 4.6.4 Minor As a follow-up of the Preliminary Audit, organization has classified “Agrochemical wastes, pesticide packagings” as B3 waste according to the IK-3.03-0102 revised in November 2011. However, the IK has not been effectively enforced on the organization in documentary. This was related to socialization targets that had not been determined in plantations and factory as well as there had been no Correction : Revising IK_3.12-0114,IK-3.12-0601 and IK-3.03-0102 Corrective Actions : Distributing and disseminating the revised IK. Writing letter to BLH for approval asking of the strorage of B390 days. Looking for B3 waste buyers who have permit. Putting B3 waste into the place where has storage permit KHPSG: Company has made social dissemination KANAU: Company has made social dissemination KBGTU: Company has made social dissemination KSSUT: Company has made social dissemination CLOSED SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES Sucofindo ICS FRM 3.04 Issue 04 Rev. 6 103of 117 revision to the aspect of environmental impacts where previously “Agrochemical wastes, pesticide packagings” were still classified as solid waste. 9 7.1 Minor Development area of Muara Upu has not been found implementation record of program development for plasma farmers. Correction: Making development program for plasma farmers. Corrective Action: Making development program for plasma farmers whether in PKS or Estate. Company has conducted development program for plasma farmers in 2012. CLOSED 10 7.4 Minor There was no evidence of Marginal soil and landslide map in the development area of Muara Upu, including slope and peat soil which are available in proper scale of map. Making identification plan of HCV in the development area of Muara Upu. Company has offered identification task and arrangement plan of management and monitoring for HCV. CLOSED 11 7.6 Minor There is no recorddocument about society who lost public access Correction: Identifying community of Muara Upu who are being influenced from the impact of plantation development. It will be seen in next surveillance with supporting OPEN SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES Sucofindo ICS FRM 3.04 Issue 04 Rev. 6 104of 117 and land rights for agricultural expansion to be given opportunity to get benefit from plantation development. Corrective Action: Documenting all records of negotiation and agreements with the society. Documenting the result of negotiation and calculation of compensation and its payment process. evidence such as reports of negotiation and calculation of compensation 12 4.7 Obs Companies should ensure K3 aspects to be reviewed in the manufacture of SPK-Work Order with 3rd party contractor For example, medical examinations for workers employed and standardize the use of Personal Protective Equipment Correction: Revised related SPK at the general provisions points Corrective Action: Conducting socialization to the contractor contractor personnel to meet the K3 aspects in accordance with the SPK and evaluate its implementation. See the implementation in the next surveillance. 13 5.6 Obs The company should be able to add and create IK when WWTP in force major circumstances as early prevention efforts on the impact of the operation of the WWTP. Example: correction: Revised related SPK at the general provisions points. Corrective action: Conducting socialization to the contractor contractor personnel to meet the K3 aspects in accordance with the SPK and evaluate its implementation. See the implementation in the next surveillance. SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES Sucofindo ICS FRM 3.04 Issue 04 Rev. 6 105of 117 The existing pumps at WWTP can not function properly 14 4.6 5.3 Obs The company should be able to ensure the availability of MSDS, labels symbol B3 and B3 for each of the materials used and waste generated. At The time of the audit found that not all MSDSs available on the chemicals used in the estate mill Correction: supplement labels and symbols on materials B3 and B3 waste in every place. Corrective Action: Identify each B3 and B3 waste then completed with label, symbol B3 then disseminate the handling methods to employees See the implementation in the next surveillance. 15 4.5 Obs In the IK-3.01-17 14 revision 6 year 2011, the program has been madebut not yet incorporate with biological control, it was directly control the use of chemicals klerat Correction: Revise IK-3.01-17 14 by incorporating integrated pest management points to the rat through biological control Corrective Action: Distribute and disseminate IK-3.01-17 14 and make biological control plans See the implementation in the next surveillance. 16 4.1 Obs Have not found the revision socialization Correction: Conducting socialitation related IK revised on May 13, 2011. See the implementation in the next SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES Sucofindo ICS FRM 3.04 Issue 04 Rev. 6 106of 117 recording IK plant 3:01 version May 13, 2011 in the Sisumut, Hapesong estates accordance with the Decree of the Board of Directors of PT. Perkebunan Nusantara III No. 3:12 SKPTS 122011 which states that the previous IK does not apply Corrective Action: Creating a sustainable outreach programs related to changes IK surveillance. 17 8.1 Obs The results of self- assessment activities related to the RSPO requirements should be provided the status of completion Correction: Creating control status for the results of the implementation of the self-assessment of the RSPO Corrective action: Homogenize the results of the self-assessment form by adding the control status column See the implementation in the next surveillance. 18 6.5.2 Obs The company already has a MOU with the contractor a standard format in which already requires that the contractor compliance with Corrective: The Company has conducted monitoring of contractors in compliance with applicable regulations through partner evaluation Corrective action: Giving an assessment to ensure contractor compliance objectively See the implementation in the next surveillance. SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES Sucofindo ICS FRM 3.04 Issue 04 Rev. 6 107of 117 applicable regulations in terms of employment. The company should conduct monitoring of compliance, through the evaluation activity of supplierscontracto rs 19 4.7.2 Obs The company already has a structure P2K3 but has not been revised and re- endorsement related to the changes of current corporate organizational structure Corrective: Revise P2K3 structure adapted to the conditions of recent changes Corrective Action: P2K3 Organizational structure adapted to the current organizational structure See the implementation in the next surveillance. 20 4.7.6 Obs The company already provides P3K equipment and emergency response work in those locations. Companies should make sure of the availability of tools, Correction: Providing equipment P3K in each of P3K box and ensure that all employees use PPE. CorrectiveAction: Socializing the use of PPE to all workers, especially in hazardous locations and complete tool P3K See the implementation in the next surveillance. SUCOFINDO INTERNATIONAL CERTIFICATION SERVICES Sucofindo ICS FRM 3.04 Issue 04 Rev. 6 108of 117 both in quantity and readiness in place needed. Should be ensured that every worker who works in hazardous areas, already use PPE that are tailored to risk danger. Follow Up Audit

C. 5. Non Conformity Registers