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JOB DESCRIPTION

Director of Safety and Compliance Department Environmental Health, Safety & Regulatory Compliance Reports To Head of Operations Location Talpa, TX campus (on-site) FLSA Status Exempt, Full-Time, Regular Position Summary The Director of Safety and Compliance is responsible for developing, implementing, and maintaining comprehensive safety, health, environmental, and regulatory compliance programs for all explosives manufacturing operations at Critical Materials Group. This position serves as the primary liaison with federal, state, and local regulatory agencies and ensures that all operations conform to applicable laws, regulations, and industry standards. The Director of Safety and Compliance plays a critical role in protecting employee safety, preserving company assets, maintaining federal licensure, and upholding the organization's contractual and legal obligations. Key Responsibilities Safety Program Management Develop, implement, and continuously improve the organization's comprehensive Safety & Health Management System (SHMS) in accordance with

OSHA 29 CFR 1910

(General Industry) and applicable OSHA standards. Conduct routine, unannounced, and scheduled safety inspections of all manufacturing areas, storage magazines, and support facilities. Investigate all workplace accidents, incidents, near-misses, and unsafe conditions; prepare written findings and corrective action plans within required timeframes. Administer the organization's Job Hazard Analysis (JHA) and Process Hazard Analysis (PHA) programs; ensure all high-hazard tasks are reviewed and documented prior to commencement. Maintain and update the written Injury and Illness Prevention Program (IIPP), Emergency Action Plan (EAP), and all OSHA-required written programs including Lockout/Tagout, Hazard Communication, Respiratory Protection, and Hearing Conservation. Oversee the selection, procurement, issuance, and maintenance of all personal protective equipment (PPE); ensure employee training and compliance with PPE requirements. Manage the organization's Hazard Communication Program; in cooperation with Production and Supply Chain personnel, maintain accurate Safety Data Sheet (SDS) files and chemical inventories. Direct fire prevention, emergency response, and evacuation programs; coordinate periodic drills and after-action reviews. ATF Regulatory Compliance Serve as a designated Responsible Person (RP) under the organization's Federal Explosives License/Permit (FEL/FEP) issued pursuant to 18 U.S.C. Chapter 40 and 27 CFR Part 555. Ensure full compliance with all Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF) regulations governing the manufacture, storage, transfer, use, and disposition of explosive materials. Maintain all required ATF records including acquisition and disposition (A&D) logs, inventory records, and transaction documents; ensure records are readily available for ATF inspection. Conduct and document physical inventories of all explosive materials in accordance with 27 CFR § 555.127; reconcile discrepancies immediately and report theft or loss to ATF and local law enforcement without delay. Ensure all storage magazines meet ATF construction, location, and security requirements under 27 CFR §§ 555.201-555.220; maintain magazine inspection logs. Coordinate and prepare for ATF compliance inspections; serve as the primary point of contact during ATF audits and inspections; respond to ATF inquiries and notices of violation. Maintain current knowledge of ATF regulatory updates, rulings, and industry explosives safety advisories; communicate relevant changes to management and affected employees. Ensure all employees involved in the manufacture, storage, or handling of explosive materials satisfy ATF eligibility requirements; maintain documentation of employee eligibility determinations. OSHA Compliance Ensure compliance with all applicable OSHA standards, including but not limited to 29 CFR Part 1910 (General Industry) and any applicable process safety management (PSM) requirements under 29 CFR § 1910.119 where processes meet threshold quantities. Maintain

OSHA 300

Log, OSHA 300A Annual Summary, and

OSHA 301

Incident Reports; ensure timely electronic submission via the Injury Tracking Application (ITA) as required. Report OSHA-recordable severe injuries (fatalities, in-patient hospitalizations, amputations, and eye losses) within mandated timeframes. Develop and deliver OSHA-required training programs; maintain comprehensive training records for all employees. Serve as the primary contact for OSHA compliance officers during inspections; accompany inspectors during walkthroughs; respond to OSHA citations and abatement schedules. Implement corrective actions in response to OSHA citations, violations, or directives within required abatement dates; verify effectiveness of corrective measures. DCMA Compliance (Defense Contract Management Agency) Serve as the primary interface with the Defense Contract Management Agency (DCMA) for all quality assurance, safety, and contract compliance matters. Maintain compliance with DoD

MIL-STD-1916, MIL-STD-882

(System Safety), and other applicable military standards governing the manufacture of energetic materials and explosive devices. Support DCMA quality assurance representatives (QARs) during contract surveillance, source inspections, and first-article testing activities. Ensure that safety requirements embedded in government contracts (SOWs, CDRLs, and DIDs) are identified, tracked, and fulfilled; maintain required documentation and deliverables. Coordinate the preparation and maintenance of System Safety Program Plans (SSPPs) and related safety analyses required under government contracts. Facilitate DCMA-directed process audits, corrective action requests (CARs), and surveillance reviews; ensure timely and substantive responses to all government findings. Ensure compliance with DFARS clauses and applicable Federal Acquisition Regulations (FAR) pertaining to contractor safety and health obligations. DSCA Compliance (Defense Security Cooperation Agency) Support organizational compliance with Defense Security Cooperation Agency (DSCA) requirements as applicable to Foreign Military Sales (FMS) and security assistance programs. Assist in the preparation and review of end-use certificates, export documentation, and related compliance submissions for explosive materials subject to DSCA oversight. Coordinate with program managers and legal counsel to ensure that all transfers of explosive materials, technical data, and defense services comply with DSCA policies and applicable International Traffic in Arms Regulations (ITAR) under 22 CFR Parts 120-130. Maintain familiarity with Letters of Offer and Acceptance (LOAs) and associated safety requirements; communicate program-specific compliance obligations to operational personnel. Support internal audits and DSCA program reviews; prepare supporting documentation for security cooperation compliance assessments. Training and Education Design and deliver a comprehensive safety and regulatory compliance training curriculum covering ATF regulations, OSHA standards, explosive safety, emergency response, and job-specific hazards. Conduct new employee orientation safety training; ensure all new hires receive required safety indoctrination prior to performing regulated tasks. Maintain a training management system tracking course completion, certifications, and recertification due dates for all employees. Coordinate and deliver annual refresher training on all regulatory and safety topics; document attendance and assessment results. Develop and maintain training materials, standard operating procedures (SOPs), and reference guides for safe handling, storage, and processing of explosive materials. Recordkeeping and Reporting Develop and maintain a document control system for all safety, environmental, and regulatory records in compliance with applicable retention requirements. Prepare and submit all required regulatory reports, permits, and notifications to ATF, OSHA, EPA, state, and local agencies on time and in the required format. Compile and present monthly and annual safety performance metrics to senior management including incident rates, near-miss trends, compliance status, and corrective action progress. Maintain the organization's explosives inventory management records with accuracy and completeness; support internal and external audits. General Workplace Safety Obligations Comply with all federal, state, and local occupational safety and health regulations, as well as all company safety policies, procedures, and rules at all times. Use, inspect, and maintain all required personal protective equipment (PPE) appropriate to the task and hazard. Report all accidents, injuries, near-misses, and unsafe conditions immediately to a supervisor and to the Safety department. Participate in all required safety training, drills, and emergency response exercises. Never handle, process, or store explosive materials except in accordance with approved procedures and under proper authorization. Follow all posted safety signs, warnings, and exclusion zone requirements in the manufacturing and storage areas. Immediately stop work and notify a supervisor when an unsafe condition or act is observed and cannot be immediately corrected. Maintain a clean and orderly work area; practice good housekeeping at all times to reduce fire, explosion, and trip hazards. Cooperate fully with safety inspections, audits, and investigations conducted by company personnel or regulatory agency representatives. Follow established emergency procedures in the event of a fire, explosion, chemical release, or other emergency; evacuate to designated assembly areas as directed. Supervisory Responsibilities Directly supervises Safety Technicians, Environmental Health & Safety (EHS) Coordinators, and/or administrative support personnel assigned to the Safety & Compliance function. Responsible for scheduling, performance evaluation, coaching, and the assignment and review of work in accordance with company policies and applicable laws. Qualifications Education Bachelor's degree in Occupational Safety & Health, Industrial Hygiene, Chemistry, Engineering, or a closely related field required. Experience Minimum seven (7) years of progressive occupational safety and regulatory compliance experience, with at least four (4) years in an explosives manufacturing, ordnance, ammunition, or energetic materials environment. Demonstrated experience managing ATF Federal Explosives License compliance and serving as a Responsible Person under 27 CFR Part 555. Hands-on experience with OSHA regulatory compliance, OSHA recordkeeping, and interaction with OSHA compliance personnel. Experience supporting DCMA contract surveillance, quality audits, or DoD system safety programs strongly preferred. Certifications Certified Safety Professional (CSP) - required within 18 months of hire, or currently held. Associate Safety Professional (ASP) or Occupational Health & Safety Technologist (OHST) - accepted in lieu of CSP with commitment to obtain

CSP. OSHA

30-Hour General Industry Outreach Training - required. ATF Federal Explosives License Responsible Person Designation - required. Hazardous Materials Technician certification preferred. DoD System Safety (MIL-STD-882) training or certification preferred. Knowledge, Skills, and Abilities In-depth knowledge of 27 CFR Part 555 (Commerce in Explosives), ATF licensing and inspection requirements, and explosives industry safety standards (IME, ISEE). Thorough knowledge of

OSHA 29 CFR

Part 1910 standards including PSM (1910.119), LOTO (1910.147), Hazard Communication (1910.1200), and Respiratory Protection (1910.134). Working knowledge of DoD safety standards including MIL-STD-882E and DoD 4145.26-M (DoD Contractor's Safety Manual for Ammunition and Explosives). Familiarity with

DSCA SAMM

(Security Assistance Management Manual) policies and FMS program compliance obligations. Excellent written and verbal communication skills; ability to prepare clear regulatory submissions, technical reports, and training materials. Demonstrated ability to lead cross-functional teams, manage multiple concurrent priorities, and exercise sound judgment under pressure. Proficiency with Microsoft Office Suite; familiarity with safety management information systems (SMIS) and regulatory tracking software. Working Conditions & Physical Demands The Director of Safety and Compliance regularly works in both office environments and active manufacturing and storage areas at CMG's Talpa, TX campus. Work in manufacturing and explosives storage areas requires the wearing of prescribed PPE including, but not limited to, flame-resistant (FR) clothing, anti-static footwear, hard hat, safety glasses, and hearing protection. The position requires the physical ability to: Stand, walk, and traverse uneven terrain for extended periods during facility inspections. Occasionally lift or carry objects weighing up to 50 pounds. Access confined spaces, elevated platforms, and outdoor storage magazine areas in varying weather conditions. Respond immediately to emergency situations at any hour, including outside of normal business hours. This position may require up to 20% travel for regulatory agency meetings, industry conferences, DCMA/DSCA program reviews, or training activities. This job description reflects the general nature and level of work performed and is not intended to be an exhaustive list of all responsibilities, duties, and skills required. Critical Materials Group reserves the right to amend this description at any time.