IT Landes Safety Manual

05.06.2023

POLICY STATEMENT

IT Landes is firmly commited to the premise that our employees are our most valuable resource and, as a Company, we are dedicated to the safety of our employees. Our policy is to perform work in the safest manner possible, to provide a work environment free of recognized hazards and to ensure employees are not placed at risk of injury.

Preven�on of occupa�onally induced injuries and illnesses is so important that it will be given precedence over opera�ng produc�vity. To the greatest degree possible, management will provide all protec�ons required to protect the personal health and safety of our employees.

The management team of IT Landes is very interested in and commited to working with you to provide a safe place in which to work. The preven�on of accidents and injuries to our employees is the prime objec�ve.

All IT Landes personnel are expected to take an ac�ve and constant interest in the preven�on of accidents. We call upon all employees to make informed decisions in all their ac�ons and take a second to think of the consequences to your fellow employees. We cannot overemphasize that all employees must do their part to minimize accidents. Safety must be incorporated into all our ac�vi�es, and this requires a team effort from all levels of the organiza�on.

The Environmental, Health, and Safety Manual has been developed to guide us in placing EHS ahead of expediency. Each employee must be commited to a safe workplace. We expect and appreciate your coopera�on in our EHS efforts. Together we can reduce injuries and illnesses and con�nue crea�ng a beter work environment. OUR GOALS ARE ZERO ACCIDENTS AND ZERO INJURIES.

Please show your support by demonstra�ng the following:

1. FOLLOWING IT LANDES’S SAFETY RULES.

2. KEEPING WORK AREAS FREE OF UNSAFE CONDITIONS.

3. AVOIDING AND ELIMINATING UNSAFE ACTS.

4. PROMPTLY REPORTING UNSAFE ACTS AND CONDITIONS.

5. REPORTING ALL INCIDENTS IMMEDIATELY.

Accidents cause suffering and pain. We value each of you as individuals and hope you will cooperate with us in this important endeavor.

Any construc�ve cri�cism or sugges�ons toward improving safety on any of our jobs will be given prompt and careful considera�on.

PURPOSE

Safety is good business. It is also reflected in work quality, effec�ve management, cost reduc�on, job efficiency, supervision, and workforce, thereby contribu�ng to the success of IT Landes.

The programs contained in IT Landes’s safety manual have been established to accomplish the following:

1. Protect and promote the health and safety of employees, customers, and others who may be affected by IT Landes’s business ac�vi�es.

2. Comply with all per�nent regulatory obliga�ons.

3. Ensure the health, safety, and loss control programs are given the proper priority and aten�on and are achieving the required results.

4. Coordinate health, safety, and loss control ac�vi�es while maintaining consistency in procedures at the required level of performance.

5. Assist new and exis�ng projects in developing and/or revising health, safety, and loss control programs by interac�ng with each superintendent and providing external resources to ensure consistency with this purpose.

PRINCIPLES

An effec�ve occupa�onal, health and safety program will be maintained. This program is basic to the principles of safe opera�ons and requirements of our business. Qualified personnel and adequate tools and equipment will be provided by IT Landes in keeping with these principles and goals. The following principles are fundamental to a successful opera�on:

1. Appropriate programs need to be implemented to protect employee health and safety and to minimize human suffering.

2. Occupa�onal injuries and illnesses are preventable.

3. Management seeks to define, ini�ate, and maintain programs and procedures to prevent injuries and illnesses.

4. Con�nuing scru�ny of programs and ongoing employee training and educa�on in occupa�onal health and safety are essen�al program elements.

5. Follow industry best prac�ces to achieve world-class status.

DUTIES AND RESPONSIBILITIES

A successful safety management system can only be achieved and maintained when there is ac�ve interest, par�cipa�on, and accountability at all levels of the organiza�on. To ensure this, IT Landes delegates the following safety du�es to all management personnel. In some cases, employees will need to perform safety du�es outside their regular responsibili�es to prevent accidents.

The safety manager must plan, organize, and administer the program by establishing policy, se�ng goals and objec�ves, assigning responsibility, mo�va�ng subordinates, and monitoring results. IT Landes management will support and maintain an ongoing safety and injury and illness preven�on program (IIPP) through the following:

1. Providing clear understanding and direc�on to all management and employees regarding the importance of safety through the development, implementa�on, monitoring, and revision of policy and procedures.

2. Providing financial support for the safety and IIPP through the provision of adequate funds for the purchase of necessary safety materials, safety equipment, personal protec�ve equipment, adequate �me for employee safety training, and maintenance of tools and equipment.

3. Overseeing development, implementa�on, and maintenance of the safety manual, IIPP, and other required safety programs.

4. Maintaining an IT Landes commitment to accident preven�on by expec�ng safe conduct on the part of all managers, supervisors, and employees.

5. Holding all levels of management and employees accountable for accident preven�on and safety.

6. Reviewing all accident inves�ga�ons to determine correc�ve ac�on.

Managers and supervisors play a key role in the preven�on of accidents on the job. They have direct contact with the employees and know the safety requirements for various jobs. Safety responsibili�es for these individuals include, but are not limited to:

1. Enforce all safety program content and ensure safe work procedures.

2. Verify correc�ve ac�on has been taken regarding safety hazards and accident inves�ga�ons.

3. Conduct periodic documented inspec�ons of the worksites to iden�fy and correct unsafe ac�ons and condi�ons that could cause accidents.

4. Act as a leader in IT Landes’s safety policy and set a good example by following all safety rules.

5. Become familiar with local, state, and federal safety regula�ons. The safety manager is available for assistance.

6. Train all new and exis�ng employees in proper safety procedures and hazards of the job.

7. Instruct all employees under their supervision in safe work prac�ces and job safety requirements.

8. Hold weekly safety mee�ngs with employees.

9. Ensure employee proficiency when assigning work requiring specific knowledge, special opera�ons, or equipment.

10. Ascertain that all machinery, equipment, and worksta�ons are maintained in safe working condi�on and operate properly.

11. Correct unsafe acts and condi�ons that could cause accidents.

12. Communicate with all employees about safety and accident preven�on ac�vi�es.

13. Correct the cause of any accident as soon as possible.

14. Ascertain that proper first aid and firefigh�ng equipment is maintained and used when condi�ons warrant its use.

15. Maintain good housekeeping condi�ons at all �mes.

16. Inves�gate all injuries and accidents to determine their cause and poten�al correc�ve ac�ons.

AERIAL LIFTS

1.0 INTRODUCTION

Aerial li�s include boom-supported aerial pla�orms, such as cherry pickers or bucket trucks. This safety program is intended to address the issues of IT Landes’s, hereina�er referred to as “the Company,” employee training, safety requirements, maintenance, and general opera�on of aerial li�s

2.0 TRAINING

Employees will be trained prior to use and reevaluated every three years in both a classroom component and an assessment of the operator performance with the equipment.

Ac�vi�es

• Iden�fy the tasks that require an aerial li�.

• Write and communicate workplace-specific procedures that outline the opera�on and limita�ons of aerial li�s.

• Maintain manufacturer’s requirements, limits, and documenta�on.

• Conduct documented daily inspec�ons prior to use.

• Implement, maintain, and inspect fall arrest systems as required.

• Annually evaluate the aerial li� program to ensure it is relevant and func�oning properly.

Forms

• Aerial Li� Operator Checklist

• Aerial Li� Operator Evalua�on

3.0 PURPOSE

This program defines the process for managing an aerial li�.

4.0 SCOPE

This program applies to all loca�ons where aerial li�s are used or maintained. The procedure covers operator selec�on, training, equipment opera�ons, and maintenance.

5.0 RESPONSIBILITIES

Management

• Iden�fy the tasks that require an aerial li�.

• Ensure the correct type of equipment is purchased.

• Document workplace-specific procedures that outline the opera�on and limita�ons of aerial li�s.

• Ensure operators are ini�ally trained and reevaluated every three years.

• Annually evaluate the aerial li� program to ensure it is relevant and func�oning properly.

Safety Manager

• Work with management to ensure appropriate personal protec�ve and emergency equipment is provided.

• Assist in the development of workplace-specific aerial li� opera�on rules and procedures.

• Evaluate the course of content of the various aerial li� training courses, ensuring they meet the requirements of OSHA standards, and any addi�onal Company requirements as outlined in this program

6.0 PROCEDURE

Aerial Li� Requirements

• Any use of an aerial li� must be in accordance with the requirements and limits iden�fied in the owner’s manual from the manufacturer. Develop and document appropriate workplace-specific rules and procedures where required.

• A pre-use inspec�on must be performed on the aerial li� prior to use each day. If a new operator uses the aerial li� on the same day, that operator must perform their own pre-use inspec�on.

• For Company-owned li�s, a manufacturer’s recommended preventa�ve maintenance program must be followed. For rental li�s, the rental Company’s maintenance schedule must be followed.

• An aerial li� may be “field modified” for uses other than those intended by the manufacturer, provided the modifica�ons have been verified in wri�ng by the manufacturer or by any other equivalent en�ty to be in conformity with all applicable provisions of ANSI A92.2 – 1969 and OSHA 1926.453 and to be at least as safe as the equipment was before modifica�on.

• The insulated por�on of an aerial li� shall not be altered in any manner that might reduce its insula�ng value.

• Ar�cula�ng boom and extensible boom pla�orms, designed as personnel carriers, shall have both pla�orm (upper) and lower controls. Upper controls shall be in or beside the pla�orm within easy reach of the operator. Lower controls shall provide for overriding the upper controls. Controls must be plainly marked as to their func�on.

• Manufacturer manuals are available and stored in weatherproof containers on the aerial li�s or in the mobile units

• The aerial li� must have a reverse signal alarm audible above the surrounding noise level or the vehicle is backed up only when a spoter is used.

7.0 LIFT OPERATIONS

• Ensure that equipment is inspected each day prior to use to determine that controls are in safe working condi�on.

• Fall arrest system lanyards must be used and atached to the anchor point on the floor of the basket or the boom of the li�. Securing the lanyard to an adjacent pole, structure, equipment, or railings of the basket while working from an aerial li� shall not be permited. If employees are required to leave the basket and are subjected to a fall hazard, a second lanyard must be used to ensure that fall protec�on requirements are con�nuous.

• Employees shall always stand firmly on the floor of the basket and shall not sit or climb on the edge of the basket or use planks, ladders, or other devices for a work posi�on.

• Full body harnesses (as part of a personal fall arrest system) shall be worn, and a lanyard shall be atached to the boom or basket when work is in progress

• The manufacturer’s boom and basket weight limits shall not be exceeded.

• The brakes shall be set and when outriggers are used. They shall be posi�oned on pads or a solid surface. Wheel chocks shall be installed before using an aerial li� on an incline, provided they can be safely installed.

• The base or body of an aerial li� truck shall not be moved when the boom is elevated in a working posi�on with employees in the basket, except for equipment which is specifically designed for this type of opera�on.

• Climbers (or similar spiked shoes) may not be worn while performing work from an aerial li�.

• Never allow an aerial li� to be used as a crane or material-li�ing device.

• A hardhat shall be worn at all �mes when opera�ng an aerial li�.

• Entry gates or chains shall be closed before opera�ng an aerial li�.

• For aerial li�s that have both upper and lower controls, the lower controls shall not be operated unless permission has been obtained from the employee in the li�, except in case of emergency.

• Before moving an aerial li� for travel, the boom must be inspected to see that it is properly cradled, and outriggers are in the stowed posi�on.

• When moving the vehicle in reverse, the signal alarm must be audible above the surrounding noise level, or a spoter must be used to signal that it is safe.

• When required to exit or climb out of an elevated aerial li� to a loca�on not otherwise protected by guardrails, floor, or other con�nuous means of fall protec�on, operators shall use a second shock-absorbing lanyard to connect to the new loca�on before disconnec�ng from the aerial li�. When entering an aerial li� from an unprotected loca�on, operators shall connect a shock-absorbing lanyard to the anchorage point in the aerial li� before entering.

• Employees shall not posi�on themselves between overhead hazards, such as joists and beams, and the rails of the basket. If such posi�oning is required, the fall protec�on system must account for the shorter distance to the hazard in case of a fall.

• Never override hydraulic, mechanical, or electrical safety devices.

• Always treat power lines, wires, and other conductors as energized, even if they are down or appear to be insulated.

• Operators shall maintain safe distances from electrical power lines, conductors, and bus bars. Operators must allow for boom or pla�orm movement or electrical line sway or sag. Operators shall follow minimum safe approach distances (MSAD). At no �me will an operator posi�on the bucket closer than 10’ from any electrical source.

8.0 RECORDS AND DOCUMENTATION

• Workplace-specific training (ini�al and refresher) records. An Operator Evalua�on Form must be retained.

• Training records for current operators must be retained for the dura�on they will operate the li�.

• Records should be retained for three years a�er this point.

• Documenta�on of daily li� inspec�on must be maintained.

9.0 SAFETY INFORMATION

• Fuel tanks may not be filled while the engine is running.

• Fuel caps must be in place before star�ng.

• The operator must conduct a safety/circle check of the vehicle to determine hazards.

• The operator must conduct a worksite inspec�on.

• Liquid fuels such as gasoline and diesel fuel must be handled in accordance with NFPA standards for flammable and combus�ble liquids.

• Perform electrical system safety tests on aerial li� devices per ANSI/SIA A92.2 requirements.

• Inspect hydraulic and pneuma�c system components (bus�ng safety factor) on aerial li� devices per ANSI/SIA A92.2 requirements.

• Conduct welding opera�ons on aerial li� devices per Automo�ve Welding Society (AWS) standards.

10.0 TRAINING

The following training must occur before operators are allowed to operate an aerial li� unsupervised, and such opera�ons may not endanger either the operators or the trainee:

• Ini�al informa�on (classroom and discussion)

• Evalua�on and instruc�on on the opera�on of the aerial li� at the workplace

Ini�al Training

• Opera�on training provides skills and knowledge related to the li� the operator is authorized to drive. These include inspec�ons, controls, vehicle stability and capacity and any specific opera�ng limita�ons.

• An evalua�on of the operator, in the workplace, performing typical aerial li� tasks must occur ini�ally.

ACCESS TO EMPLOYEE MEDICAL RECORDS

1.0 PURPOSE

The purpose of this safety policy and procedure is to establish the guidelines and procedures through which employees will be able to obtain and gain access to IT Landes, hereina�er referred to as “the Company,” maintained exposure and medical records. Exposure and medical records are those resul�ng from employment-related exposures, injuries, and/or illnesses.

Employees may be exposed to toxic substances and harmful physical agents to an extent that may severely impair their health. Workers must be informed about the toxic exposures they face and the poten�al health effects. This safety policy and procedure provides guidelines for employees to obtain their exposure and medical records. It includes provisions on training, reten�on requirements for employee exposure and medical records, and response �me to employee requests for exposure and medical records. Addi�onally, guidelines are presented on physician review of employee medical records, OSHA access to medical records, and informa�on that must be shared with new employees.

2.0 RESPONSIBILITIES

It is the general responsibility of the Company to ensure that each employee has access to all exposure and medical records pertaining to their present or past employment with the Company. This chapter provides defini�ons, establishes general provisions, and iden�fies responsibili�es regarding access to employee exposure and medical records.

Managers/Unit Heads

• Maintain employee exposure and medical records

• Ensure compliance with this safety policy and procedure.

• Provide employees with copies of their exposure and medical records when properly requested.

• Ensure the confiden�ality of employee medical records

Supervisors

• Educate and train employees about their rights under this safety policy and procedure.

Employees

• Exposure and medical records may be kept in an employee’s personnel files, in a physician’s office, or contained within claim files such as workers’ compensa�on.

Safety Department

• Prompt assistance to managers/unit heads or others on any mater concerning this safety policy and procedure.

• Assist in developing or securing required training for the effec�ve implementa�on of this safety policy and procedure

• Provide consulta�ve and audit assistance to ensure effec�ve implementa�on of this safety policy and procedure.

3.0 POLICY

The Company will provide all exposure and medical records when properly requested as outlined in this safety policy and procedure.

The Company will ensure that those employees who request their exposure and medical records are provided with confiden�al, fair, and equal treatment.

4.0 ACCESS TO MEDICAL RECORDS

Whenever an employee or a designated representa�ve of an employee requests access to exposure and/or medical records, the Company will provide these documents within 15 working days. If records cannot be provided within this �me period, the employee or representa�ve must be informed and given a date on which the records will be provided along with a reason for the delay. These records will be provided to the employee or representa�ve at no cost for reproduc�on or for the document search itself.

Whenever access is requested to an analysis which reports the contents of employee medical records by either direct iden�fier (name, address, social security number, payroll number, etc.) or by informa�on which could reasonably be used under the circumstances indirectly to iden�fy specific employees (exact age, height, weight, race, sex, date of ini�al employment, job �tle, etc.), those personal iden�fiers must be removed before access is provided.

5.0 EMPLOYEE EXPOSURE AND MEDICAL RECORDS

Upon request, the Company must provide employees or their designated representa�ve access to employee exposure records. If no records exist, the employer must provide records of other employees with job du�es similar to those of the employee. Access to exposure records does not require the writen consent of the other employees. In addi�on, these exposure records must reasonably indicate the iden�ty, amount, and nature of the toxic substances or harmful physical agents to which the employee has been exposed.

The Company must also provide employees and their designated representa�ve access to employee medical records. Access to the medical records of another employee may be provided only with the writen consent of that employee. A request for medical records can be made by using the form (or one substan�ally similar) shown in this program. The Company is responsible for maintaining employee medical records for the dura�on of employment plus 30 years. This recordkeeping does not include health insurance claims, first-aid records (not including medical histories) of one-�me treatment, and medical records of employees who have worked for the Company for less than a year. Employee exposure records and data analysis shall be maintained for the dura�on of employment plus 30 years. It is the responsibility of the employee to ini�ate any request for access to their medical records as outlined in this safety policy and procedure.

If, for any reason, the Company shall cease to do business, the Company shall transfer all records subject to this sec�on to the successor employer. If the Company ceases to do business and there is no successor employer to receive and maintain the records, and the Company intends to dispose of any records required to be preserved for at least 30 years, the employer shall no�fy current affected employees of their rights of access to records at least three months prior to the cessa�on of Company business.

6.0 ENVIRONMENTAL AND BIOLOGICAL MONITORING

In an effort to maintain accurate records of exposure, the Company shall set in place environmental (workplace) monitoring and measuring of all toxic substances or harmful physical agents, including personal, area, grab, wipe, and other forms of sampling as well as related collec�on and analy�cal methodologies, calcula�ons, and other background data relevant to interpreta�on of the results obtained.

Biological monitoring results which directly assess the absorp�on of a toxic substance or harmful physical agent by body systems (e.g., the level of a chemical in the blood, urine, breath, hair, fingernails, etc.) but not including results which assess the biological effect of a substance or agent, or which assess an employee’s use of drugs or alcohol.

7.0 REPRESENTATION BY A PHYSICIAN

The Company may request that a physician be appointed to review medical records with the employee or their designated representa�ve to ensure records are reviewed and properly interpreted. The physician may deny the employee access to records if the physician detects a situa�on which may be detrimental to the health of the employee such as the iden�fica�on of terminal illness or a psychiatric condi�on. In such cases, the employee’s designated representa�ve may request the records even if it is known that the representa�ve may disclose the informa�on to the employee.

Upon receiving a writen request from OSHA, the Company will supply OSHA with any exposure or medical records for analysis. A copy of this request must be posted in a conspicuous place for at least 15 working days. Access to records shall be provided within a reasonable �me, place, and manner.

If access to records cannot reasonably be provided within 15 working days, the Company shall within the 15 working days apprise the employee or their designated representa�ve reques�ng the record of the reason for the delay and the earliest date when the record can be made available.

8.0 NEW EMPLOYEE NOTIFICATION

Upon a person first entering employment and at least annually thereina�er, an employee will be given informa�on of the existence, loca�on, and availability of medical records as well as the name of the person or department responsible for maintaining and providing access to records. Individual employee’s rights of access to these records must be given to all current employees.

New employees will be informed of the following informa�on:

• The existence, loca�on, and availability of any records covered by this safety policy and procedure

• The person responsible for maintaining and providing access to these records.

• Employee’s rights under this safety policy and procedure.

9.0 DEFINITIONS

Access: The right and opportunity to examine, copy, or use any or all exposure and medical records.

Designated Representa�ve: Any individual or organiza�on to whom an employee gives writen authoriza�on to exercise a right of access to exposure or medical records.

Employee: An individual who is employed by the Company and who is being assigned or transferred to work where there will be exposure to toxic substances or harmful physical agents. In a case where the employee is deceased, the employee’s legal representa�ve may directly exercise all of the employee’s rights under this policy.

Employee Exposure Record: A record containing informa�on on the type of environment or hazards present in the workplace.

Employee Medical Record: A record concerning the health status of an employee which is made or maintained by a physician, nurse, or other healthcare personnel or technician.

Exposure: A condi�on that occurs when an employee is subjected to toxic or hazardous environments as a result of their job du�es.

Health Professional: A physician, occupa�onal health nurse, industrial hygienist, toxicologist, or epidemiologist providing medical care or other occupa�onal health services to exposed employees.

Record: Any item, collec�on, or grouping of informa�on regardless of the form or process by which it is maintained.

Toxic Substance: Any chemical substance, biological agent (bacteria, virus, etc.), or physical stress (noise, heat, cold, vibra�on, etc.) to which employees could have been exposed as a result of performing their job func�on.

EMPLOYEE REQUEST FOR ACCESS TO MEDICAL RECORDS

SUBMIT COMPLETED FORM TO YOUR MANAGER OR UNIT HEAD

I, ______________________________, hereby request access to any and all employment-related medical records, maintained on my behalf, by IT Landes. This request, unless specifically noted below, includes all employment-related medical records maintained by IT Landes and/or any private healthcare provider for which IT Landes has knowledge. I acknowledge that this request pertains only to access of employment-related medical records as detailed in IT Landes’s safety policy and procedures.

Specific Records Being Requested

Employee Signature Social Security Number Date

Designated Representative Certification

I, ______________________________, cer�fy that I am the designated representa�ve for the above-named employee and that he/she has authorized me to obtain the medical records as indicated above. Please forward these records to my aten�on at the address below.

Employee Name

Representa�ve Signature

Address

Date

ASSURED EQUIPMENT GROUNDING

1.0 PURPOSE

The purpose of this document is to outline safety requirements surrounding the use and exposure to electricity, and to eliminate all injuries resul�ng from possible malfunc�ons, improper grounding, and defec�ve electrical tools for IT Landes, hereina�er referred to as “the Company.” This policy applies to all sites, personnel, and contractors and must be followed at all �mes.

2.0 RESPONSIBILITIES

Supervisors are responsible for implemen�ng the assured equipment grounding conductor program and shall be designated as competent persons for the program. One or more competent persons must be designated as set forth in CFR 1926.404(b) (11) (iii) & Cal/OSHA T8 CCR 2405.4 to implement the program.

Employees are responsible for abiding by the following policy and requirements of this program. Addi�onally, personnel and employees shall be held responsible to perform regular visual inspec�ons and to remove defec�ve equipment from service. All personnel shall no�fy a supervisor of defec�ve equipment as soon as reasonably possible.

3.0 POLICY

It is the policy of the Company to establish and implement an assured equipment grounding conductor program on all jobsites covering all cord sets, receptacles which are not a part of the permanent wiring of the building or structure, and equipment connected by cord and plug which are available for use by personnel. In fact, OSHA requires that employees shall use either ground fault circuit interrupters (GFCIs) or assured equipment grounding conductor program to protect personnel from electrical shock while working.

A copy of this policy shall be placed at each jobsite for inspec�on and copy by OSHA officials and any affected employee/personnel.

The Company shall use GFCIs in lieu of an assured grounding program as afforded by CFR 1926.400(h).

4.0 GROUND FAULT CIRCUIT INTERRUPTERS

Ground fault circuit interrupters are not required for 120 volts, single phase, or 15 and 20-amp receptacle outlets where all of the requirements of this procedure are implemented at worksites as part of the permanent wing of the building or structure.

Supervisors are designated to implement the assured equipment grounding conductor program. 1926.32(f) defines competent persons as one who is capable of iden�fying exis�ng and predictable hazards in the surrounding area or working condi�ons which are unsanitary, hazardous, or dangerous to employees, and who is authorized to take prompt correc�ve measures to eliminate them.

Equipment found damaged or defec�ve may not be used un�l repaired supervisors shall be responsible and accountable for the following:

• Each cord set, atachment cap, plug and receptacle of cord set, and any cord and plug connected equipment except cord sets and receptacles which are fixed and not exposed to damage, shall be visually inspected before each day’s use for external defects, such as deformed or missing pins, or insula�on damage, and for indica�on of possible internal damage.

• Tests on all cord and plug connected equipment, receptacles which are not a part of the permanent building or structure wiring, and all cord sets must be repaired to be ground.

• Tests shall be documented on the log for the assured equipment grounding conductor program and shall be on all worksites for inspec�on by OSHA officials and/or any affected employee/personnel

The equipment grounding conductor shall be connected to its proper terminal:

• Before each use

• Before equipment is returned to service following any repairs

• Before equipment is used such as when a cord has been run over

• At intervals not exceeding three months

Cord sets and receptacles which are fixed and not exposed to damage shall be tested at intervals not exceeding six months.

Tests performed as required by this program shall be recorded as to the iden�ty of each receptacle, cord set and cord and plug connected equipment that passed the test and shall indicate the last date tested or interval for which it was tested. This record shall be kept by means of logs, color coding, or other effec�ve means and shall be maintained un�l replaced by a more current record. These records shall be made available at the jobsite for inspec�on by the Assistant Secretary and any affected employees.

Equipment that does not meet the prescribed test shall not be put into service. In this case, the following shall occur:

• All equipment grounding conductors shall be tested for con�nuity and shall be electrically con�nuous.

• Each receptacle and atachment cap or plug shall be tested for correct atachment of the equipment grounding conductor. The equipment grounding shall be connected to its terminal.

In accordance with OSHA 1926.21, supervisors shall atend training sessions as the Company may deem necessary.

BEHAVIOR BASED SAFETY

1.0 PURPOSE

IT Landes’s, hereina�er referred to as “the Company,” Behavior Based Safety (BBS) program includes an educa�onal component and observa�on process that are used to improve safety and reduce employee risk in the workplace. The process is proac�ve and is intended to inform employees about the components of BBS and the procedures that will help to reduce workplace injuries by reducing risky behaviors.

2.0 SCOPE

The BBS program applies to all staff. If a customer has a BBS ini�a�ve in place at their loca�on, employees are expected to follow the customer’s BBS. Employees should par�cipate in this BBS program and follow the established guidelines.

3.0 REQUIREMENTS

The founda�on of the Company BBS is safety awareness. The employee is taught to recognize when they are exhibi�ng risky behavior such as:

• Eyes wandering off task

• Mind wandering off task

• Hurrying

• Feeling frustra�on

• Feeling �red

• Feeling complacent (which can cause or contribute to these cri�cal errors)

• In the line of fire

• Losing of balance/trac�on/grip (which may increase the risk of injury)

A Job Safety Analysis (JSA) is conducted on each job to evaluate the work environment and iden�fy risks. The purpose of the JSA is to eliminate or control hazards that may be experienced when doing the job/task. The JSA is included in the BBS process to iden�fy correct behaviors and work procedures to reduce risky behavior.

The process of observa�on helps raise employee safety awareness and provides feedback to ini�ate changes or improvements in design, process, or procedure to reduce risky behaviors. This process has three key components:

Observa�on of Employee Work Behavior

Observa�on of employees provides measurable data on work prac�ces and allows iden�fica�on of safe and unsafe behaviors. Observers collect informa�on about the behavior of employees, contractor employees, and customer employees as they do their job tasks. They provide feedback to management, emphasizing what behavior was observed rather than who was observed.

The observer records their observa�ons on the BBS Observa�on Form, including but not limited to:

• Work environment

• Equipment

• Procedures/methods

• Personal protec�ve equipment

• People

Following the observa�on, the observer discusses the results of their observa�on with the observed and allows the observed to provide feedback. Specifically, the observer:

• Reviews the observa�on with observed employee.

• Begins with a posi�ve comment.

• Follows with posi�ve reinforcement regarding safe behaviors observed.

• Describes and discusses and unsafe behaviors observed.

• Solicits an explana�on of the unsafe behavior by asking open-ended ques�ons.

• Re-emphasizes that there will be no consequences to the observed employee.

Feedback from the employee is documented to help iden�fy what needs to be repeated and what needs to change in order to reduce risks in the workplace.

Collec�on of Data and Performing Trend Analysis

The collected data will be compared by departments, as well as Company-wide, and these results will be tracked in a consistent manner so that numerical and sta�s�cal comparisons can be made.

All BBS Observa�on Forms are forwarded to the corporate safety manager. The corporate safety manager inputs the informa�on into the BBS database and generates reports for management. The data collected will be used to perform trend analysis.

Ac�on Plans Developed A�er the Trend Analysis Is Completed

Following trend analysis, ac�on plans are developed to correct unsafe behaviors. These plans include:

• Evalua�ng and priori�zing the iden�fied unsafe behaviors

• Developing an ac�on plan based on the comments and feedback

• Assigning responsibility and �meframes in the ac�on plan

• Defining who is responsible for the ac�on plan

• Ensuring management support

Ac�on plans must be completed within the �meframe iden�fied. The ac�ons listed in the ac�on plan should be followed up on to ensure closing:

• Employees, safety manager, and senior management review the ac�ons on a monthly basis

• The Company assigns responsibility for closing all ac�on plans

• Ac�on plans and completed ac�on items are archived and documented.

4.0 RESPONSIBILITIES

Oversight

• Act as a coach for observers and encourage con�nuous improvement by developing ac�on plans

• Ensure that all employees atend training on BBS.

• Provide informa�on to employees in a �mely manner.

• Review process modifica�on requests submited by employees.

• Review and provide feedback on the BBS/JSA cards, then forward the cards to the corporate Safety Director.

The BBS process has a specific role for each employee, including observee, observer, supervisor, manager, and safety manager.

Observee

• Be willing to be observed.

• Remain open and coopera�ve.

• Do not be defensive.

• Be an ac�ve par�cipant in problem-solving mee�ngs.

• Be aware of the BBS process.

Observer

• Study the BBS process and understand the benefits of reducing risky behaviors.

• Ac�vely promote the BBS process.

• Proac�vely observe employee behavior.

• Be amenable to coaching.

• Be helpful and polite.

• Offer sugges�ons to employees about how to safely perform a task.

• While observing an employee, communicate with them.

• Be posi�ve and provide construc�ve feedback following an observa�on.

• Accentuate the posi�ve of an employee’s safe behavior prior to discussing the observed risky behaviors.

• Work coopera�vely towards solu�ons when problems are found

• Make good quality comments and observa�ons about “what” and “why” for each risky behavior recorded.

Supervisor

• Review BBS Observa�on Forms on a weekly basis and provide feedback.

• Do not use data from the BBS process to punish employees.

• Help when problem solving, and complete correc�ve ac�ons in a �mely fashion.

• Study the BBS process and understand the benefits of reducing risky behaviors. Manager

• Support the goals and objec�ves of the BBS process by ac�vely promo�ng and par�cipa�ng in it.

• Ensure that all employees are informed as to the expecta�ons regarding the BBS process.

• Inspire employee par�cipa�on in observa�ons in order to reduce accidents and injuries in the workplace.

• Ensure the process is produc�ve by providing resources as required.

• Show up for safety mee�ngs and comment on areas of improvement.

Safety Manager

• Reinforce the goals and objec�ves of the BBS process.

• Encourage and promote the BBS process.

• Provide technical support as required and help to acquire resources necessary for the BBS process.

• Answer any concerns or suggest by field personnel.

• Collect observa�on data cards.

• Enter data from observa�on cards into BBS system.

5.0 TRAINING

Observa�on process training will include:

• Objec�ves of the program, and review of incident metrics

• How to observe

• How to fill out the observa�on form

• What the behaviors mean

• Training in feedback and role play (coaching)

• Informing employees that they may be observed at any �me

BLOODBORNE PATHOGENS

1.0 PURPOSE

The purpose of this document is to outline the Bloodborne Pathogens Exposure Control Plan for IT Landes, hereina�er referred to as “the Company.” OSHA requires that all employers that can “reasonably an�cipate exposure” of employees to infec�ous material to prepare and implement a writen exposure control plan (ECP). This policy has been adopted by the Company to ensure a safe and healthy work environment for its personnel.

2.0 RESPONSIBILITIES

The Company is commited to providing a safe and healthy work environment for all personnel. In pursuit of this objec�ve, the following ECP is provided to eliminate or minimize occupa�onal exposure to bloodborne pathogens in accordance with OSHA 29 CFR 1910.1030 (Occupa�onal Exposure to Bloodborne Pathogens.).This ECP is vital to assist our organiza�on in implemen�ng and ensuring compliance with the OSHA standard, thereby protec�ng our employees.

ECP Administra�on

A safety commitee member shall be responsible for the implementa�on, maintenance, review, and update of this ECP. The ECP should be reviewed at least once a year, but whenever necessary, to ensure the plan aligns with applicable regulatory standards. All personnel who have occupa�onal exposure to blood and or other poten�ally infec�ous materials (OPIM) must comply with the procedures set forth in this policy.

A safety commitee member shall provide and maintain, on behalf of the Company, all necessary personal protec�ve equipment (PPE), engineering controls (e.g., sharps containers), labels, and red bags as required by the standard. A safety commitee member will ensure that adequate supplies of the aforemen�oned equipment are available in the appropriate sizes at all �mes to ensure that all personnel have access if needed.

A safety commitee member shall be responsible for ensuring that all medical ac�ons required by the standard are performed and that appropriate employee health and OSHA records are maintained and current with applicable regula�ons at all �mes. A safety commitee member will be responsible for training, documenta�on of training and for making the writen ECP available to all personnel who perform work for the Company.

3.0 POLICY

4.0 PERSONNEL EXPOSURE DETERMINATION

The Company does not employ personnel with job classifica�ons in which some or all employees have occupa�onal exposure to bloodborne pathogens that may result from the performance of their rou�ne tasks. Designated employees are trained to render first aid and basic life support; execu�ng first aid or basic life support will expose employees to bloodborne pathogens and will require them to adhere to this ECP. Medical sharps or similar equipment is not provided to, or used by, personnel who may render first aid or basic life support. A list of all firstaid and basic-life-support trained employees in this work group shall be maintained at each worksite and within each first-aid kit.

5.0 METHODS OF IMPLEMENTATIONS AND CONTROL

6.0 UNIVERSAL PRECAUTIONS

All employees will u�lize universal precau�ons. Under circumstances in which differen�al of infec�ous bloodborne and non-infec�ous bloodborne body fluids is difficult or impossible, all body fluids will be considered poten�ally infec�ous.

7.0 EXPOSURE CONTROL PLAN

Personnel covered by bloodborne pathogens standards receive an explana�on of the ECP during their ini�al training session as well as an annual refresher training. Access to a copy of the ECP shall be provided to personnel in a reasonable �me, place, and manner; specifically, each employee will receive a copy of the ECP as a part of the Company’s en�re HSE manual at the �me of their hire and an updated/revised copy annually.

If an employee misplaces their copy of the ECP, a new copy will be issued to the employee within five working days. If the employee needs access to the ECP before the Company can provide them with a new copy, a copy will be available at all �mes in the office.

8.0 ENGINEERING CONTROLS AND WORK PRACTICES

Engineering controls and work-prac�ce controls will be used to prevent or minimize exposure to bloodborne pathogens. Sharps disposal containers are inspected and maintained or replaced by the responsible safety officer on a regular basis or whenever necessary to prevent overfilling.

Handwashing facili�es shall be available at all work loca�ons. If a provision of handwashing facili�es is not feasible, then an appropriate an�sep�c hand cleanser in conjunc�on with cloth or paper towels or an�sep�c toweletes shall be provided by the Company.

9.0 PERSONAL PROTECTIVE EQUIPMENT

Personal protec�ve equipment (PPE) shall be provided by the Company to personnel at no cost to the worker. Moreover, workers will be trained by the Company or by a qualified trainer in the use of appropriate PPE for specific tasks or procedures.

The following list of PPE shall be made available to all personnel:

• Hardhats

• Goggles

• Gloves

• Reflec�ve vests

• Fall-arrest

• Lanyards

• Fire retardant clothing

• Reinforced footwear as needed

Addi�onal PPE shall be stored at the office, shop, vehicles, and worksites. A safety commitee member is responsible for making all PPE available to personnel and for keeping all PPE in safe working condi�on. Workers who no�ce PPE in disrepair or in non-working order shall no�fy a safety commitee member to the defec�ve equipment replaced or repaired.

The following work procedures and precau�ons shall be followed by all personnel:

• Wash hands immediately or as soon as feasible a�er removing gloves or other PPE.

• Remove PPE a�er it becomes contaminated and before leaving the work area.

• Used PPE may be disposed of in designated containers for storage, laundering, decontamina�on, or disposal.

• Wear appropriate gloves when it is reasonably an�cipated that there may be hand contact with blood or OPIM.

• Replace gloves if torn, punctured, or contaminated when handling or touching contaminated items or surfaces.

• If the ability of the gloves to func�on as a barrier is compromised, remove immediately.

• U�lity gloves may be decontaminated for reuse if their integrity is not compromised.

• Discard u�lity gloves if they show signs of cracking, peeling, tearing, puncturing, or deteriora�on.

• Never wash or decontaminate disposable gloves for reuse.

• Wear appropriate face and eye protec�on when splashes, sprays, spaters, or droplets of blood or OPIM pose a hazard to the eye, nose, or mouth.

• Remove immediately or as soon as feasible any garment contaminated by blood or OPIM, in such a way as to avoid contact with the outer surface.

• Contaminated needles and other sharps should only be handled by authorized or by trained personnel.

10.0 HOUSEKEEPING

Personnel are responsible for keeping work areas clean and sanitary. All equipment and working surfaces must be cleaned and decontaminated using sani�zing cleanser a�er contact with blood or OPIM. Contaminated work surfaces must be decontaminated with disinfectant upon comple�on of each of the following:

• Directly following the contamina�on or a�er any spill of blood or OPIM.

• At the end of the workday if the surface may have become contaminated since the last cleaning.

• All waste receptacles, buckets, and other containers shall be inspected regularly, cleaned/disinfected, and decontaminated as soon as reasonably possible if the unit is visibly contaminated.

• Broken glass shall be picked up using safe equipment such as a broom, dustpan, tongs, or similar piece of equipment that is probable to mi�gate worker exposure and risk.

• Broken glass must not be picked up directly with the hands even if gloved.

Regulated Waste

Regulated waste is liquid or semi-liquid blood or OPIM. Contaminated items that would release blood or OPIM in a liquid or semi-liquid state if compressed. Regulated waste shall be placed in containers which are closeable, constructed to contain all contents and prevent leakage and appropriately labeled.

Labels

The following labeling methods are used at the Company’s facili�es to iden�fy regulated waste, sharps disposal containers, contaminated laundry bags containers and equipment.

A safety commitee member shall be responsible for ensuring that warning labels or red bags are used as required. Personnel shall no�fy a safety commitee member if they discover regulated waste containers, refrigerators containing blood or OPIM, contaminated equipment, etc. without proper labels.

11.0 RECORDKEEPING

Training Records

Training records are completed for each employee upon successful comple�on of training. These documents will be kept for at least three years at the office.

Training records shall include the following informa�on:

• Names and �tles of all training session atendees

• Names and qualifica�ons of trainer(s)

• Contents or a summary of the training

• Date of training

All training records shall be made available to all personnel upon request.

Medical Records

Medical records shall be maintained for each employee with occupa�onal exposure in accordance with 29 CFR 1010.1020, “Access to Employee Exposure and Medical Records.” Writen employee consent is required prior to the release of employee medical records.

A safety commitee member is responsible for the maintenance of required medical records. These records shall be kept confiden�al in accordance with HIPPA regula�ons for the period of employment plus thirty years. Medical records shall be provided to personnel upon request.

12.0 HEPATITIS B VACCINATION

The Company shall provide Hepa��s B vaccine to all employees that have occupa�onal exposure at no cost to the employee.

CELL PHONE POLICY

1.0 POLICY

IT Landes, hereina�er referred to as “the Company,” has adopted a zero-tolerance stance for any use of a cell phone or any other handheld device while opera�ng any equipment or commercial vehicles. Use of a cell phone while opera�ng a Company or personal vehicle on any jobsite is strictly prohibited.

Cell phone and handheld device usage includes, but is not limited to:

• Talking on a cell phone

• Use of a tablet

• Use of direct connect device

• Tex�ng

• Internet and data usage

Only in the event of an emergency may a cell phone be used as long as the person is out of the work rota�on, pulled off safely to the side, in park, and the emergency brake on. Person(s) observed using a cell phone or handheld device while opera�ng heavy equipment or commercial vehicles may be subject to automa�c dismissal from the Company.

COMPRESSED GAS CYLINDERS

1.0 PURPOSE

This procedure outlines IT Landes’s, hereina�er referred to as “the Company,” environmental, health, and safety (EHS) compressed gas cylinder program. This procedure outlines general requirements for the use of compressed gas cylinders.

2.0 DEFINITIONS

The Interstate Commerce Commission defines a compressed gas as “having a pressure in the container of 40 psi or greater at 70°F or, regardless of the pressure at 70°F, having an absolute pressure exceeding 104 psi at 130°F. In addi�on, any liquid flammable material having a Reid Vapor Pressure exceeding 40 psi at 100°F ”

A mul�tude of gases are available commercially, all having different proper�es and hazards associated with them. Their usage introduces hazards of flammability, explosion, chemical reac�on, toxicity, and serious interference with manual firefigh�ng efforts.

The one common hazard shared by all compressed gases is pressure. There have been documented instances where a cylinder of gas has been damaged to such an extent that the instantaneous release of gas has rocketed the cylinder through a brick wall, and several hundred feet away before coming to rest.

3.0 PROCEDURE

The following requirements must be observed when using, storing, or handling compressed gas cylinders:

• Know the cylinder contents and be sure iden�fica�on labels are in place.

• Know the proper�es of the contents. Safety data sheets (SDSs) for the compressed gas being used, stored, or handled should be reviewed with jobsite personnel by the EHS representa�ve. The review should include informa�on on physical data, fire and explosion data, reac�vity, health hazards, special personal protec�on, storage, spill, and disposal procedures. SDSs may be obtained from the supplier or distributor of the compressed gas.

• Transport and handle cylinders with caps in place, and be sure cylinders are securely fastened during use or storage.

• Do not use valve protec�on caps to li� or transport cylinders.

• When cylinders are frozen use warm, not boiling, water to thaw cylinders loose. Never use bars under valves or valve protec�on caps to pry cylinders loose.

• Store upright and secured in ven�lated areas away from heat or igni�on sources. Compressed gas cylinders shall not be stored while exposed to direct sunlight, par�cularly when ambient temperatures are high since the increase in temperature could also increase the internal pressure beyond safe limits

• When storing combus�ble gases and oxidizing compressed gases, they must be separated by minimum 20 feet distance or have a fire wall rated for 30-minute fire ra�ng between them. Ensure that cylinders will be protected from accidental impact with moving vehicles or forkli�s by suitable barriers. Cylinder storage must also be sufficiently away from hazardous or corrosive chemicals or large fuel tanks.

• Do not tamper with cylinder valves, such as the safety or packing nuts.

• Close the cylinder valve when not in use or empty. Be sure to label empty cylinders as being empty. Please note that even empty cylinders will have some pressure and gas inside.

• Never atempt to refill a cylinder or transfer gas from one cylinder to another. This is par�cularly important when connec�ng mul�ple cylinders to a manifold. Ensure that each cylinder will have a shut off valve on the manifold line.

• Cylinders shall be kept far enough away from welding, cu�ng, and hea�ng opera�ons so that sparks, hot slag, or flame will not reach them or, when this is not prac�cal, fire-resistant shields shall be provided.

• Cylinders shall not be placed where they can contact an electrical circuit.

• Cylinders shall be secured in an upright posi�on at all �mes, except, if necessary, for short periods while cylinders are actually being hoisted or carried. This is par�cularly important for acetylene cylinders since they contain a solvent inside.

• Cylinders shall be secured in an upright posi�on at all �mes during transporta�on. No bungee cords shall be permited to secure cylinders during transporta�on.

• Unless the cylinder valve is protected by a recess in the head, keep the metal cap in place to protect the valve at all �mes when the cylinder is not connected for use. A blow on an unprotected valve might cause gas under high pressure to escape.

• Do not use a cylinder of compressed gas without reducing the pressure through the proper regulator atached to the cylinder valve.

• Use only approved regulators and their related gauges which are in proper working order. Do not interchange gauges and regulators meant for one type of gas for another type.

• Be sure proper relieving devices are installed when there is danger of over pressuring equipment.

• Ensure the threads in a regulator or union correspond with those on the cylinder valve outlet. Do not force connec�ons that do not fit.

• Before making connec�on to a cylinder valve outlet, except that of a hydrogen cylinder, "crack" the valve for an instant to clear the opening of par�cles of dust or dirt.

• Do not crack hydrogen cylinder valves. Always point the valve and opening away from the body and not toward anyone else.

• Never connect an oxygen regulator to a cylinder containing fuel gas or vice versa. Be sure that the connec�ons between the regulators, adapters, and cylinder valves are gas-�ght. Before opening the cylinder valve, release the pressure-adjus�ng screw on the regulator to its limit; that is, see that it is turned counterclockwise (to the le�) un�l it is loose. Open the cylinder valve slightly to let the hand on the highpressure gauge move up slowly. Do not let the gauge hand move quickly. On an oxygen cylinder gradually open the cylinder valve to its full limit, but on an acetylene cylinder make no more than 1-1/2 turns of the valve spindle.

• Disengage the regulator as follows:

o Close the cylinder valve �ghtly.

o Bleed oxygen, acetylene, or gas from all equipment.

o Release the regulator adjus�ng knob.

o Disconnect the regulator from the cylinder.

• Always keep oxygen and fuel gas fi�ngs and hose connec�ons free of grease and oil.

• When connec�ng a fuel gas (LPG, acetylene) cylinder to a welding set-up with oxygen, please ensure that a flame arrestor or flash back arrestor is installed in the fuel gas supply line. This will prevent the unexpected migra�on of flame back to the fuel gas cylinder and poten�al explosion.

• All permanently installed compressed gas lines, fuel, air, nitrogen, etc must be color coded or labeled to iden�fy the contents.

• Do not use temporary hoses, lines that do not meet the full pressure ra�ng for extensions of compressed gas lines.

• Do not drop compressed gas cylinders from a height par�cularly when unloading from trucks. Do not roll cylinders on the ground for moving them around.

• Compressed gas cylinders shall not be taken inside confined spaces. They will be located outside the space and approved hoses carrying the gas may enter the confined space.

CONFINED SPACES

1.0 PURPOSE

The purpose of this program is to establish safe guidelines and procedures for IT Landes, hereina�er referred to as “the Company,” employees and contractors entering permit-required and non-permit confined spaces and to ensure compliance with regulatory confined space standards.

2.0 SCOPE

This program applies to all the Company employees and the Company contractors who enter confined spaces, which are owned by the Company. In cases where the site owner is not the Company, the site owner’s confined space program shall take precedence. If the site owner does not have an adequate confined space program, this program shall be used.

3.0 DEFINITIONS

Acceptable Entry Condi�ons: Condi�ons that must exist in a permit space to allow entry and to ensure that employees involved with a permit-required confined space entry can safely enter into and work within the space.

Atmosphere-Controlled Confined Space: A permit-required confined space in which poten�al or actual atmospheric hazards can be eliminated prior to entry or can be controlled with con�nuous forced mechanical ven�la�on.

Atendant: An individual sta�oned outside the permit spaces who monitors the authorized entrants and who performs atendant’s du�es as required by this program.

Confined Space: Any space that is large enough and so configured that an employee can bodily enter and perform assigned work, has limited or restricted means for entry or exit, and is not designed for con�nuous employee occupancy.

• Confined spaces include, but are not limited to, storage tanks, pits, vats, vessels, environmental chambers, sewer manholes, electrical manholes, vaults, pump or li� sta�ons, sep�c tanks, boilers, pipelines, tunnels, ven�la�on and exhaust ducts, trenches, and excava�ons.

• Common hazards associated with confined space entry include oxygen deficient atmospheres, flammable/explosive atmospheres, toxic atmospheres, engulfment/entrapment hazards, and/or chemical, electrical, or mechanical hazards.

Control Measures: A system or device used, or ac�on taken, to control or prevent the introduc�on of physical hazards into a confined space. Control measures include:

Blanking or Blinding: The absolute closure of a pipe, line, or duct by the fastening of a solid plate (such as a spectacle blind or a skillet blind) that completely covers the bore and that is capable of withstanding the maximum pressure of the pipe, line, or duct with no leakage beyond the plate.

Double Block and Bleed: The closure of a line, duct, or pipe by closing and locking or tagging two in-line valves and by opening and locking or tagging a drain or vent valve in the line between the two closed valves.

Emergency: Any occurrence or event inside or outside of the permit space that could endanger entrants.

Engulfment: The surrounding of a person by finely divided solids or a liquid. A worker in a storage tank filled with sawdust, for example, could fall into an air pocket, be completely surrounded by sawdust, and suffocate to death.

Entrant: Any person who enters a confined space.

Entry: Any ac�on resul�ng in any part of the employees’ body breaking the plane of any opening of the permitrequired confined space and includes any work ac�vi�es inside the confined space.

Entry Permit: The employers’ writen authoriza�on for employee entry into a confined space under defined condi�ons for a stated purpose during a specified �me.

Entry Supervisor or Supervisor: The departmental person responsible for determining if acceptable entry condi�ons are present in a permit space where entry is planned, for authorizing entry and overseeing entry opera�ons, and for termina�ng entry as required by this document.

Hazardous Atmosphere: An atmosphere presen�ng a poten�al for death, disablement, injury, or acute illness from one or more of the following causes:

• A flammable gas, vapor, or mist in excess of 10% of its lower flammable limit (LFL)

• An oxygen deficient atmosphere containing less than 19.5% oxygen by volume or an oxygen enriched atmosphere containing more than 23.5% oxygen by volume

• Airborne combus�ble dust at a concentra�on that meets or exceeds its LFL (airborne combus�ble dust which obscures vision at five feet or less)

• An atmospheric concentra�on of any substance for which a dose is published in Group 14 for Radia�on and Radioac�vity, or a permissible exposure limit is published in Sec�on 5155 for Airborne Contaminants which could result in an employee exposure in excess of its dose or permissible exposure limit, and that could cause death, incapacita�on, impairment of ability to self-rescue, injury, or acute illness

• Any other atmospheric condi�on that is immediately dangerous to life or health (IDLH)

Hot Work Permit: The employer’s writen authoriza�on to perform opera�ons (for example, welding, cu�ng, burning, or hea�ng) capable of providing a source of igni�on.

Immediately Dangerous to Life or Health (IDLH): Any condi�on that poses an immediate or delayed threat to life, or that would cause irreversible adverse health effects or that would interfere with an individual’s ability to escape unaided from a permit space.

Iner�ng: The displacement of the atmosphere in a permit space by a non-combus�ble gas, such as nitrogen, to such an extent that the resul�ng atmosphere is non-combus�ble. Note that this procedure produces an IDLH oxygendeficient atmosphere that can only be entered using self-contained breathing apparatus (SCBA).

Isola�on: The process by which a permit space is removed from service and completely protected against the release of energy and material into the space by such means as: blanking or blinding; misaligning or removing sec�ons of lines, pipes, or ducts; a double block and bleed system; lockout or tagout of all sources of energy; or blocking or disconnec�ng all mechanical linkages.

Line Breaking: The inten�onal opening of a pipe, line, or duct that is or has been carrying flammable, corrosive, or toxic material, an inert gas, or any fluid at a volume, pressure, or temperature capable of causing injury.

Lockout/Tagout: Placing locks or tags on the energy-isola�ng device (e.g., breaker boxes, control switches, valves, etc.) to prevent the unauthorized reenergiza�on of the device or circuit while personnel are performing work. Tags shall indicate that the energy-isolated device shall not be operated un�l the tag is removed by the individual(s) that installed the tag.

Non-Permit Confined Space: A confined space that does not contain or have the poten�al to contain any hazard capable of causing death or serious physical harm.

Permit-Required Confined Space: A confined space that has one or more of the following characteris�cs:

• Contains or has the poten�al to contain a hazardous atmosphere.

• Contains a material that has the poten�al for engulfing an entrant.

• Has an internal configura�on such that an entrant could be trapped or asphyxiated by inwardly converging walls or by a floor which slopes downward and tapers to a smaller cross-sec�on.

• Contains any other recognized serious safety or health hazard (such as noise, welding, electricity, radia�on, or moving parts of machinery).

Permit-Required Confined Space Program: The Company overall program for controlling and, where appropriate, for protec�ng employees from, permit space hazards and for regula�ng employee entry into permit spaces.

Permit System: The Company writen procedures for preparing and issuing permits for entry and for returning the permit space to service following termina�on of entry.

Prohibited Condi�on: Any condi�on in a permit space that is not allowed by the permit during the period when entry is authorized.

Qualified Person: An entry supervisor who is trained to recognize and evaluate the an�cipated hazard(s) of the confined space and who shall be capable of specifying necessary control measures to ensure employee safety.

• The supervisor shall designate an employee(s) as qualified person for the purposes of assuring safe confined space entry procedures and prac�ces at a specific site. The qualified person may also be an entrant when permissible according to this standard.

• Where the supervisor is unable to designate a qualified person, then the supervisor shall coordinate work ac�vi�es with the Safety Manager or their designee.

Rescuer Team: A rescue plan must be put into place for all entries. This plan will be u�lized by the persons whom the employer has designated prior to any permit-required confined space entry to perform rescues from confined spaces. Those designated as rescuer must receive the proper level of training for entry and non-entry rescue procedures.

Retrieval System: The equipment used for non-entry rescue of persons from permit spaces, and includes retrieval lines, chest or full body harness, and a li�ing device or anchor. A retrieval line is primarily of use in ver�cal confined spaces and shall not be used in confined spaces consis�ng of horizontal tunnels or spaces where obstruc�ons could increase the hazard to the entrant during emergency non-entry removal.

Tes�ng: The process by which the hazards that may confront entrants to a permit space are iden�fied and evaluated. Tes�ng includes specifying the tests that are to be performed in the permit space.

Zero Mechanical State: The mechanical poten�al energy of all por�ons of the machine or equipment is set so that the opening of the pipe(s), tube(s), hose(s) or actua�on of any valve, lever, or buton will not produce a movement which could cause injury.

4.0 RESPONSIBILITIES

Safety Manager

• The overall implementa�on of this program into all Company confined space opera�ons.

• Ensure that all supervisors and employees are adequately trained to meet confined space training requirements.

• Apply appropriate disciplinary ac�on if applicable parts of this program are not complied with.

Entry Supervisors

• Know the hazard(s) that may be faced during entry, including informa�on on the mode, signs or symptoms, and consequences of the exposure; this informa�on will be contained on the Permit-Required Confined Space Evalua�on Form for the space in ques�on.

• Verify, by checking that the appropriate entries have been made on the permit, that all tests specified by the permit have been conducted and that all procedures and equipment specified by the permit are in place before endorsing the permit and allowing entry to begin.

• Terminate the entry and cancel the permit when either the entry opera�ons covered by the entry permit have been completed or a condi�on that is not allowed under the entry permit arises in or near the permit space.

• Verify that rescue services are available and that the means for summoning them are operable.

• Remove unauthorized entrants.

• Determine, whenever responsibility for a permit space entry opera�on is transferred and at intervals dictated by the hazards and opera�ons performed within the space that entry opera�ons remain consistent with terms of the entry permit and that acceptable entry condi�ons are maintained.

Atendants

• Con�nuously maintain an accurate count of authorized entrants in the permit space and ensure that the means used to iden�fy authorized entrants accurately iden�fies who is in the permit space.

• Remain outside the permit space during entry opera�ons un�l relieved by another atendant

• Communicate with authorized entrants as necessary to monitor entrant status and to alert entrants of the need to evacuate the space.

• Monitor ac�vi�es inside and outside the space to determine if it is safe for entrants to remain in the space and orders the authorized entrants to evacuate the permit space immediately under any of the following condi�ons:

o If the atendant detects a prohibited condi�on

o If the atendant detects behavioral effects of hazard exposure in the authorized entrants

o If the atendant detects a situa�on outside the space that could endanger the authorized entrant

o If the atendant cannot effec�vely and safely perform the requirements of this sec�on

• Summon rescue and other emergency services as soon as the atendant determines that authorized entrants may need assistance to escape from permit space hazards.

• Warn unauthorized persons to stay away from the permit space, advises the unauthorized persons that they must exit immediately if they have entered the permit space, and informs the authorized entrants and the entry supervisor if unauthorized persons have entered the permit space.

• Perform non-entry rescues as specified herein.

• Perform no du�es that might interfere with the atendant’s primary duty to monitor and protect the authorized entrants.

Entrants

• Be aware of all poten�al hazards that could be presented as a result of the entry.

• Ensure that proper use of personal protec�ve equipment such as respirators, protec�ve gloves and other forms of PPE that are adequate for the task being performed

• Must wear a gas monitor at all �mes.

• Be aware of behavioral signs and symptoms caused by known hazards and their poten�al effects on other entrants and atendants.

• Be aware that you may request addi�onal monitoring at any �me.

• Have con�nuous communica�on with the atendant at all �mes to ensure that you can effec�vely receive no�fica�on and exit the space if the atendant becomes aware of a hazardous condi�on.

5.0 PROCEDURES

Non-Permit Confined Spaces

Level I confined space entry requirements may be followed if the atmosphere is within acceptable limits without using forced air ven�la�on and if the space is effec�vely isolated.

• Entrants or their representa�ves are given an opportunity to par�cipate in the monitoring procedure and review calibrated air-monitoring data before entry.

• Air shall be tested periodically while con�nuous ven�la�on is applied.

• Employees or their representa�ves are en�tled to request addi�onal monitoring at any �me.

• Entrants must review and sign the permit.

• If the confined space toxicity, O2, and LEL levels remain below safe limits; employees may enter and work in the space.

• Entrants must complete the confined space entry permit and make it available to all personnel entering the confined space even if no hazards exist.

• An atendant must be present throughout the dura�on of the confined space opera�on and must remain outside of the confined space at all �mes.

Level I atendant requirements may be exempt if the most recent hazard assessment finds that no hazards are present within the confined space. However, there are special requirements for single person entry, which must be met and approved by the safety manager.

Permit-Required Confined Spaces

If air-monitoring results of the isolated confined space are above acceptable limits without forced air ven�la�on in use; the space requires a permit and should be classified as a permit-required confined space.

• Entrants or their representa�ves are given an opportunity to par�cipate in the monitoring procedure and review calibrated air-monitoring data before entry.

• Air shall be tested periodically while con�nuous ven�la�on is applied.

• Employees or their representa�ves are en�tled to request addi�onal monitoring at any �me.

• A confined space permit must be completed prior to working in a permit required confined space.

• All entrants must review and sign the confined space permit.

• A minimum of one atendant shall be outside of the permit-required confined space while entrants are present.

• Atendants shall maintain communica�on with entrants for the en�re dura�on of the opera�on.

• Entrants must be authorized to enter a permit-required confined space.

• Each entrant must individually sign in and sign out of the permit-required space using the required permit.

• All permit-required confined spaces must display effec�ve warning signs, barricades, or other effec�ve means to prevent unauthorized entry.

• Monitoring must be con�nuous in order to ensure safe levels are maintained throughout the en�re opera�on.

• All permits must be terminated when the opera�ons are completed, paused or when space condi�ons have changed.

• If a hazardous atmosphere or condi�on is detected:

o Entrants must immediately evacuate the confined space.

o Entry supervisor must cancel the entry permit.

o Re-evaluate the space to determine how the hazardous atmosphere developed.

o Entry supervisor must perform a new hazard assessment to determine the cause and correc�ve ac�ons that need to be taken.

o Entry supervisor must ensure that correc�ve ac�ons are taken, and hazards are abated.

o Entry supervisor shall reissue the permit once all hazards have been abated and upon comple�on of a new hazard assessment.

Pre-Entry Prepara�on

The entry supervisor shall conduct a pre-entry safety mee�ng with all entrants and atendants to discuss confined space emergency procedures, known and poten�al hazards, communica�on methods, individual du�es, and other relevant subject mater. The entry supervisor shall also:

• Ensure that the confined space is effec�vely isolated before entry occurs.

• Take precau�onary measures to ensure that entering the confined space itself does not present a hazard.

• Ensure that external objects or debris cannot enter the confined space.

• Whenever possible; clean and ven�late the confined space to minimize the impact of contaminants, vapors, dusts, etc.

• Ensure that confined space entrances or exits are labeled, guarded, or barricaded in order to minimize the possibility of unauthorized entry.

• Prepare hot work permit and implement applicable precau�onary measures when welding, cu�ng or hot work is planned.

• Effec�vely communicate to atendants and entrants when the confined space is ready for entry and when the permit will terminate.

Air Monitoring

• All employees using an air monitoring device must receive the proper level of training for the equipment they are using.

• Calibrated direct-reading instruments must be used to test the atmosphere for oxygen content, flammable gasses and vapors and for poten�al toxic air contaminants before entry to the confined space. The results of these tests are designed to inform all applicable par�es of the poten�al hazards. Therefore, entrants must review and sign the confined space permit to acknowledge that they been informed.

• Confined space atmospheres must be tested periodically with con�nuous ven�la�on applied to ensure that hazards have not been introduced into the opera�on.

• Entrants or their representa�ves shall be provided with an opportunity to observe air monitoring test results for the confined space.

• Employees or their representa�ves are en�tled to request addi�onal monitoring at any �me.

Air Ven�la�on

• Con�nuous forced air ven�la�on shall be applied to the confined space to eliminate atmospheric hazards.

• The supply of ven�la�on air must be clean and free of hazardous vapors, dusts, mists, gasses, and other hazardous material.

• Periodic tests of the confined space atmosphere shall be performed to prevent accumula�on of hazardous vapors, dusts, mists, gasses, and other hazardous material.

• If atmospheric hazards accumulate while ven�la�on is applied, the ven�la�on system is inadequate and shall be redesigned to adequately maintain safe levels while under con�nuous forced ven�la�on.

External Hazards

Proper provisions and procedures for external hazard control including pedestrians and vehicles shall be implemented. Examples of such controls include high visibility barriers, hazard tape, signage or other means which effec�vely control external hazards.

Mul�ple Employers

In order to eliminate confusion and prevent endangering employees of other en��es, the entry supervisor must:

• Inform other employers and their employees of all permit-required confined spaces.

• Supply all relevant confined space specific documenta�on to employers who may have personnel enter or work near confined spaces.

• Inform the employer that compliance with this program or one that is more stringent is mandatory before confined space entry is permited.

• Debrief the contractor at the conclusion of the entry opera�ons regarding the permit space program followed and regarding any hazards confronted or created in confined spaces during entry opera�ons.

• Keep employers informed on the status of each confined space such as when the permits are terminated or reissued.

Addi�onal employers who are responsible for performing confined space opera�ons shall:

• Verify that all documented informa�on regarding all confined spaces has been received before entry is permited.

• Coordinate all confined space opera�ons with the Company entry supervisor when employees of both en��es will be working in or near permit-required confined spaces.

• Inform the Company of the confined space program that the contractor will follow and of any hazards confronted or created in the confined space, either through a debriefing or during the entry opera�on.

• Provide copies of all confined space documenta�on to the Company entry supervisor.

Rescue Services

Rescue services vary depending on the specific circumstances of the confined space or worksite. Therefore, coordina�on between the safety manager and the entry supervisor shall occur in order to determine which service is best suited for the specific circumstances of each confined space. Rescue services shall be provided by:

• The host facility

• An outside service, which is given an opportunity to examine the entry site, prac�ce rescue and decline as appropriate

• The Company, by selec�ng a rescue team that is equipped and trained to perform the needed rescue services

Permit-Required Confined Space Rescue Procedures

• The atendant shall immediately summon rescue by the designated communica�on method such as radio, verbal, alarm, or other effec�ve means upon becoming aware of the need for rescue.

• The atendant shall not leave the immediate vicinity of the confined space while summoning rescue unless the hazard is pu�ng the atendant’s own personal health and safety at risk.

• The atendant shall prevent unauthorized personnel from entering the confined space.

• The atendant shall effec�vely communicate the emergency to the entry supervisor as per the agreed upon communica�on method immediately a�er summoning rescue.

• If the designated rescue service is an outside rescue service, they must be:

o Informed of all hazards that may be presented as a result of rescue

o Provided with access to the confined space

• If the designated rescue service is an equipped and trained team of the Company employees, they must be:

o Provided with the appropriate personal protec�ve equipment that is necessary to effec�vely execute the rescue.

o Properly trained to use the personal protec�ve equipment effec�vely.

o Properly trained to perform rescue opera�ons.

o Required to perform annual rescue drills.

o Properly trained in first aid and CPR.

o At least one rescue team member must hold current cer�fica�ons in first aid and CPR.

Non-Entry Rescue Procedures

• Non-entry rescue requires a “retrieval” system, which must be atached to the entrant upon entering a permit-required confined space, which exceeds a ver�cal depth of 5 feet.

• If the “retrieval” system or its components increases the overall risk of the entry or rescue, then it is not required.

• All rescue entrants must use a full body harness with a D-ring located between the shoulders or above the head during the rescue.

• If the use of a full body harness creates more risk or is not feasible for the rescue opera�on, wristlets may be used as an alterna�ve.

Rescue service must be onsite for immediately dangerous to life and health (IDLH) condi�ons while work is being performed.

Atendants are not allowed to monitor mul�ple confined spaces during an emergency.

Permit Issuance

Confined space permits are valid for one shi� and must expire upon the date and �me specified by the permit. Permits shall not be completed, signed, or issued un�l all pre-entry requirements are fulfilled.

If an injury, incident, reported hazard or unauthorized entry occurs at the confined space, the permit shall be terminated. A new hazard assessment shall also be performed and followed by correc�ve ac�ons to address the issue that caused permit termina�on.

Permit

Termina�on, Closure, and Cancella�on

Permit termina�on, closure and cancella�on have the same defini�on with regard to this program. Termina�ng, closing, or cancelling a permit with regard to this program is defined as an ac�on that makes the confined space permit invalid. An invalid permit requires the issuance of a new permit if confined space opera�ons are to con�nue.

Permits shall be terminated when:

• The confined space opera�on is complete.

• Concluding a regular or irregular shi�.

• When a hazard or poten�al hazard is iden�fied in or near the confined space.

• When condi�ons have changed in or near the confined space.

All confined space entry documenta�on and permits shall be maintained for at least one year from the date of entry.

Program Review

Annual reviews and necessary revisions of this program shall be performed if confined space permits were issued within one year leading up the annual review date. If no permits were issued within one year leading up to the annual review date, then no program review is required. All confined space entry records and permits must be retained and made available for at least one year from the date the entry was performed.

6.0 TRAINING

Training must be provided to all affected employees prior to ini�al assignment, prior to a change in assigned du�es, if a new hazard has been created and/or if special devia�ons have occurred. Should the training become outdated or otherwise inadequate, revisions to the training program subject mater shall be conducted un�l the program meets the requirements of this program and applicable regulatory standards.

Supervisors are responsible for cer�fying that training has been conducted for each affected employee by:

• Ensuring the cer�fica�on includes employee names, signatures of the trainers and the training dates.

• Ensuring that cer�ficates are maintained and available for review by employees, their representa�ves, and other applicable par�es.

Employees shall be retrained when:

• A new hazard that the employee has not received training on is presented.

• The entry supervisor perceives devia�ons from permited confined space procedures.

• The employees’ ac�ons or poten�al ac�ons could endanger themself or other employees.

• The entrant supervisor sees the need for retraining due to some other factor

CRANES

1.0 PURPOSE

The purpose of this document is to outline the Crane and Hoist Program for IT Landes, hereina�er referred to as “the Company.” The Company policy is to maintain a safe workplace for its employees; therefore, only qualified, and licensed individuals shall operate these devices. The safety rules and guidance in this program apply to all opera�ons at the Company that involve the use of cranes and hoists installed in or atached to buildings and to all of the Company employees, supplemental labor, and subcontractor personnel who use such devices.

2.0 RESPONSIBILITIES

Supervisors

• Ensure that employees under their supervision receive the required training and are cer�fied and licensed to operate the cranes and hoists in their areas.

• Provide training for prospec�ve crane and hoist operators. This training must be conducted by a qualified, designated instructor who is a licensed crane and hoist operator and a full-�me employee.

• Evaluate crane and hoist trainees using the Crane Safety Checklist and submi�ng the Qualifica�on Request Form to the safety office to obtain the operator’s license.

• Ensure that hois�ng equipment is inspected and tested monthly by a responsible individual and that rigging equipment is inspected annually.

Crane and Hoist Operators

• Operate hois�ng equipment safely.

• Conduct func�onal tests prior to using the equipment.

• Select and use rigging equipment appropriately.

• Have a valid operator’s license on their person while opera�ng cranes or hoists.

• Par�cipate in the medical cer�fica�on program, as required.

Engineering/Maintenance/Opera�ons Department

• Perform annual maintenance and inspec�on of all cranes and hoists that are not covered by a program with maintenance responsibility.

• Conduct periodic and special load tests of cranes and hoists.

• Maintain writen records of inspec�ons and tests and providing copies of all inspec�ons and test results to facility managers and building coordinators who have cranes and hoists on file.

• Inspect and load tes�ng cranes and hoists following modifica�on or extensive repairs (e.g., a replaced cable or hook, or structural modifica�on.)

• Schedule a non-destruc�ve test and inspec�on for crane and hoist hooks at the �me of the periodic load test and tes�ng and inspec�ng before use new replacement hooks and other hooks suspected of having been overloaded. The evalua�on, inspec�on, and tes�ng may include, but are not limited to, visual, dye penetrant, and magne�c par�cle techniques referenced in ASME B30.10 (Hooks, Inspec�on, and Tes�ng.)

• Maintain all manuals for cranes and hoists in a central file for reference.

Safety Officer

• Conduct training for all crane and hoist operators

• Issue licenses to crane and hoist operators.

• Periodically verify monthly test and inspec�on reports.

• Interpret crane and hoist safety rules and standards.

3.0 POLICY

All workers who use any of the Company crane or hoists shall have an operator’s license. The Company issues licenses for authorized employees who have been specifically trained in crane and hoist opera�ons and equipment safety.

4.0 CRANE AND HOIST OPERATORS

To be qualified as a crane and hoist operator, the candidate shall have received hands-on training from a licensed, qualified crane and hoist operator designated by the candidate’s supervisor. Upon successful comple�on of training, the licensed crane and hoist operator and the candidate’s supervisor will fill out and sign the Qualifica�on Request Form and Crane Safety Checklist and send them to the safety office for approval. The candidate will be issued a license upon approval by the safety manager. crane and hoist operators must renew their license every three years by sa�sfying the requirements described above.

Only those employees qualified by training or experience shall be allowed to operate equipment and machinery. By November 10, 2017, operators shall be qualified/cer�fied by one of the following methods:

• Cer�fica�on by an accredited crane operator tes�ng organiza�on

• Qualifica�on by an audited employer program

• Qualifica�on by the U.S. military

• Licensing by a government en�ty

5.0 CRANE AND HOIST SAFETY DESIGN REQUIREMENTS

• The design of all commercial cranes and hoists shall comply with the requirements of ASME/ANSI B30 and Crane Manufacturer’s Associa�on of America CMAA-70 and CMAA-74.

• Company-fabricated li�ing equipment shall comply with the requirements in Chapter 2.2 (Li�ing Equipment) of the latest edi�on of Mechanical Engineering Design Safety Standards.

• All crane and hoist hooks shall have safety latches.

• Hooks shall not be painted or repainted if the paint previously applied by the manufacturer is worn.

• Crane pendants shall have an electrical disconnect switch or buton to open the main-line control circuit.

• Cranes and hoists shall have a main electrical disconnect switch. This switch shall be in a separate box that is labeled with lockout capability.

• Crane bridges and hoist monorails shall be labeled on both sides with the maximum capacity.

• Each hoist-hook block shall be labeled with the maximum hook capacity.

• Direc�onal signs indica�ng N-W-S-E shall be displayed on the bridge underside, and a corresponding direc�onal label shall be placed on the pendant.

• A device such as an upper-limit switch or slip clutch shall be installed on all building cranes and hoists. A lower-limit switch may be required when there is insufficient hoist rope on the drum to reach the lowest point.

• All cab and remotely operated bridge cranes shall have a mo�on alarm to signal bridge movement.

• All newly installed cranes and hoists, or those that have been extensively repaired or rebuilt structurally, shall be load tested at 125% capacity prior to being placed into service.

• If an overload device is installed, a load test to the adjusted se�ng is required.

• Personnel baskets and pla�orms suspended from any crane shall be designed in accordance with the specifica�ons in 29 CFR 1926.550(g).

6.0 GENERAL SAFETY RULES

• Do not engage in any prac�ce that will divert aten�on while opera�ng the crane.

• Respond to signals only from the person who is direc�ng the li� or any appointed signal person. Obey a stop signal at all �mes, no mater who gives it.

• Do not move a load over people. People shall not be placed in jeopardy by being under a suspended load. Also, do not work under a suspended load unless the load is supported by blocks, jacks, or a solid foo�ng that will safely support the en�re weight. Have a crane or hoist operator remain at the controls or lock open and tag the main electrical disconnect switch.

• Ensure that the rated load capacity of a crane's bridge, individual hoist, or any sling or fi�ng is not exceeded. Know the weight of the object being li�ed or use a dynamometer or load cell to determine the weight.

• Check that all controls are in the off posi�on before closing the main line disconnect switch.

• If spring-loaded reels are provided to li� pendants clear off the work area, ease the pendant up into the stop to prevent damaging the wire.

• Avoid side pulls. These can cause the hoist rope to slip out of the drum groove, damaging the rope or destabilizing the crane or hoist.

• To prevent shock loading, avoid sudden stops or starts. Shock loading can occur when a suspended load is accelerated or decelerated and can overload the crane or hoist. When comple�ng an upward or downward mo�on, ease the load slowly to a stop.

• Equipment must not be assembled or used unless ground condi�ons are firm, drained, and graded to a sufficient extent so that, in conjunc�on (if necessary) with the use of suppor�ng materials, the equipment manufacturer’s specifica�ons for adequate support and degree of level of the equipment are met.

• The manufacturer’s procedures and prohibi�ons must be complied with when assembling and disassembling equipment.

• The assembly/disassembly of equipment must be directed by a competent and qualified person.

• The work zone shall be iden�fied by demarca�ng boundaries such as flag and range limi�ng devices or defining the work zone as 360° around the equipment up to the maximum working radius. The hazard assessment must determine if any part of the equipment could get closer than 20 feet to a power line.

• All manufacturer procedures applicable to the opera�onal func�ons of equipment, including its use with atachments, must be complied with.

7.0 OPERATION RULES

The operator shall have access to procedures applicable to the opera�on of the equipment. Procedures include rated capaci�es (load charts), recommended opera�ng speeds, special hazard warnings, instruc�ons, and operator’s manual. The operator’s manual must be readily available in the cab of the crane at all �mes.

Whenever there is a safety concern, the operator is granted the authority to stop and refuse to handle loads un�l a qualified person has determined that safety has been ensured

The Safety Officer or competent person available on the worksite shall iden�fy hazard areas by marking the boundaries of the crane swing radius with warning lines, railings, or similar barriers. Workers within proximity of the opera�onal equipment shall not stand or work within this safety boundary or at any place where the poten�al to be struck by, pinched, or crushed by the equipment or other related moving parts.

8.0 PRE-OPERATIONAL TEST

At the start of each work shi�, operators shall complete the following steps before making li�s with any crane or hoist:

• Test the upper-limit switch. Slowly raise the unloaded hook block un�l the limit switch trips.

• Visually inspect the hook, load lines, trolley, and bridge as much as possible from the operator’s sta�on; in most instances, this will be the floor of the building.

• If provided, test the lower-limit switch.

• Test all direc�on and speed controls for both bridge and trolley travel.

• Test all bridge and trolley limit switched, where provided, if opera�on will bring the equipment in close proximity to the limit switches.

• Test the pendant emergency stop.

• Test the hoist brake to verify there is no dri� without a load.

• If provided, test the bridge movement alarm.

• Lock out and tag for repair any crane or hoist that fails any of the above tests.

If it is determined that any part of the equipment, load line or load could get closer than 10 feet to a power line then at least one of the following measures must be taken:

• Ensure the power lines have been de-energized and visibly grounded.

• Ensure no part of the equipment, load line or load gets closer than 10 feet to the power line.

• Ensure employees are not placed in proximity to overhead powerlines. Proximity is defined as within 10 feet up to 50 kilovolts, and 4 inches for every 10,000 volts above 50 kilovolts.

9.0 MOVING LOAD

• Center the hook over the load to keep the cables from slipping out of the drum grooves and overlapping, and to prevent the load from swinging when it is li�ed. Inspect the drum to verify that the cable is in the grooves.

• Use a tag line when loads must traverse long distances or must otherwise be controlled. Manila rope may be used for tag lines.

• Plan and check the travel path to avoid personnel and obstruc�ons.

• Li� the load only high enough to clear the tallest obstruc�on in the travel path.

• Start and stop slowly.

• Land the load when the move is finished. Choose a safe landing.

• Never leave suspended loads unatended. In an emergency where the crane or hoist has become inopera�ve, if a load must be le� suspended, barricade and post signs in the surrounding area, under the load, and on all four sides. Lock open and tag the crane or hoist's main electrical disconnect switch.

10.0

PARKING CRANE AND HOIST

• Remove all slings and accessories from the hook. Return the rigging device to the designated storage racks.

• Raise the hook at least 7 feet above the floor.

• Store the pendant away from aisles and work areas or raise it at least 7 feet above the floor.

11.0 RIGGING

General Rigging Safety Requirements

Only select rigging equipment that is in good condi�on. All rigging equipment shall be inspected annually; defec�ve equipment is to be removed from service and destroyed to prevent inadvertent reuse. The load capacity limits shall be stamped or affixed to all rigging components.

The Company requires a minimum safety factor of five to be maintained for wire rope slings. The following types of slings shall be rejected or destroyed:

• Nylon slings with:

o Abnormal wear

o Torn s�tching

o Broken or cut fibers

o Discolora�on or deteriora�on.

• Wire-rope slings with:

o Kinking, crushing, bird caging, or other distor�ons

o Evidence of heat damage

o Cracks, deforma�on, or worn end atachments

o Six randomly broken wires in a single rope lay

o Three broken wires in one strand of rope

o Hooks opened more than 15% at the throat

o Hooks twisted sideways more than 10 ° from the plane of the unbent hook

• Alloy steel chain slings with:

o Cracked, bent, or elongated links or components

o Cracked hooks

o Shackles, eye bolts, turnbuckles, or other components that are damaged or deformed

12.0 RIGGING A LOAD

• Determine the weight of the load. Do not guess.

• Determine the proper size for slings and components.

• Do not use manila rope for rigging.

• Ensure that shackle pins and shouldered eyebolts are installed in accordance with the manufacturer’s recommenda�ons.

• Ensure that ordinary (shoulder less) eyebolts are threaded in at least 1.5 �mes the bolt diameter.

• Use safety hoist rings (swivel eyes) as a preferred subs�tute for eye bolts wherever possible.

• Pad sharp edges to protect slings. Remember that machinery founda�ons or angle-iron edges may not feel sharp to the touch but could cut into rigging when under several tons of load. Wood, �re rubber, or other pliable materials may be suitable for padding.

• Do not use slings, eyebolts, shackles, or hooks that have been cut, welded, or brazed.

• Install wire-rope clips with the base only on the live end and the U-bolt only on the dead end. Follow the manufacturer’s recommenda�ons for the spacing for each specific wire size.

• Determine the center of gravity and balance the load before moving it.

• Ini�ally li� the load only a few inches to test the rigging and balance.

13.0 CRANE OVERLOADING

Cranes or hoists shall not be loaded beyond their rated capacity for normal opera�ons. Any crane or hoist suspected of having been overloaded shall be removed from service by locking open and tagging the main disconnect switch. Addi�onally, overloaded cranes shall be inspected, repaired, load tested, and approved for use before being returned to service.

14.0 WORKING AT HEIGHTS ON CRANES AND HOISTS

Anyone conduc�ng maintenance or repair on cranes or hoists at heights greater than 6 feet shall use fall protec�on. Fall protec�on should also be considered for heights less than 6 feet. Fall protec�on includes safety harnesses that are fited with a lifeline and securely atached to a structural member of the crane or building or properly secured safety nets.

Use of a crane as a work pla�orm should only be considered when conven�onal means of reaching an elevated worksite are hazardous or not possible. Workers shall not ride a moving bridge crane without an approval from the safety office, which shall specify the following as a minimum:

• Personnel shall not board any bridge crane unless the main disconnect switch is locked and tagged open.

• Personnel shall not use bridge cranes without a permanent pla�orm (catwalk) as work pla�orms. Bridge catwalks shall have a permanent ladder access.

• Personnel shall ride seated on the floor of a permanent pla�orm with approved safety handrails, wear safety harnesses atached to designated anchors, and be in clear view of the crane operator at all �mes.

• Operators shall lock and tag open the main (or power) disconnect switch on the bridge catwalk when the crane is parked.

15.0 HAND SIGNALS

A signal person shall be provided any�me the operator’s view is obstructed, if site-specific safety concerns require it, or if the operator determines that it is necessary. The signal person must also be provided for the following situa�ons:

• The point of opera�on is not in full view of the operator.

• The view is obstructed when the equipment is traveling.

• The operator or the person handling the load determines it is necessary due to site-specific concerns.

Signals to the operator shall be in accordance with the standard hand signals unless voice communica�ons equipment (telephone, radio, or equivalent) is used. Signals shall be discernible or audible at all �mes. Some special opera�ons may require addi�on to or modifica�on of the basic signals. For all such cases, these special signals shall be agreed upon and thoroughly understood by both the person giving the signals and the operator and shall not be in conflict with the standard signals.

16.0 INSPECTION, MAINTENANCE, AND TESTING

A competent person must conduct a visual inspec�on of equipment prior to each shi�. The inspec�on must consist of observa�on for apparent deficiencies. Some inspec�on items shall include control mechanisms, pressurized lines, hooks and latches, wire rope, electrical apparatus, �res (when used), and ground condi�ons. All tests and inspec�ons shall be conducted in accordance with the manufacturer’s recommenda�ons.

Monthly Tests and Inspec�ons

Equipment must be inspected monthly by a competent person. The inspec�on must be documented and must be retained for three months. Documenta�on must include the following:

• Items checked

• Results of inspec�on

• Name and signature of the inspector

Annual Inspec�ons

The Safety Department shall schedule and supervise (or perform) annual preven�ve maintenance and inspec�on of all cranes and hoists. The annual preven�ve maintenance and inspec�on shall cover:

• Hois�ng and lowering mechanisms

• Trolley travel or monorail travel

• Bridge travel

• Limit switches and locking and safety devices

• Structural members

• Bolts or rivets

• Sheaves and drums

• Parts such as pins, bearings, sha�s, gears, rollers, locking devices, and clamping devices

• Brake system parts, linings, pawls, and ratchets

• Load, wind, and other indicators over their full range

• Gasoline, diesel, electric, or other power plants

• Chain-drive sprockets

• Crane and hoist hooks

• Electrical apparatus such as controller contractors, limit switches, and push buton sta�ons

• Wire rope

• Hoist chains

Safety devices are required to be on all equipment and must be in proper working order before opera�ons begin. If any of the devices are not in proper working order the equipment must be taken out of service and opera�ons must not resume un�l the device is working properly again. Examples of safety devices may include crane level indicator, boom stops, jib stops, foot pedal brake locks, horns, etc.

Defec�ve cranes and hoists shall be locked and tagged “out of service” un�l all defects are corrected. The inspector shall ini�ate correc�ve ac�on by no�fying the facility manager or building coordinator.

17.0 LOAD TESTING

• Newly installed cranes and hoists shall be load tested at 125% of the rated capacity by designated personnel.

• Slings shall have appropriate test data when purchased. It is the responsibility of the purchaser to ensure that the appropriate test data are obtained and maintained.

• Re-rated cranes and hoists shall be load tested to 125% of the new capacity if the new ra�ng is greater than the previous rated capacity.

• Fixed cranes or hoists that have had major modifica�ons or repair shall be load tested to 125% of the rated capacity.

• Cranes and hoists that have been overloaded shall be inspected prior to being returned to service.

• Personnel pla�orms, baskets, and rigging suspended from a crane or hoist hook shall be load tested ini�ally, then retested annually thereina�er or at each new jobsite.

• All cranes and hoists with a capacity greater than three tons should be load tested every four years to 125% of the rated capacity. Cranes and hoists with a lesser capacity should be load tested every eight years to 125% of the rated capacity.

18.0 MODIFICATIONS

The manufacturer must approve all modifica�ons/addi�ons in wri�ng. A registered professional engineer must be qualified with respect to the equipment involved and must ensure the original safety factor of the equipment is not reduced.

19.0 RECORDS

The Safety Department shall maintain records for all cranes, hoist, and rigging equipment.

ELECTRICAL SAFETY AWARENESS

1.0 PURPOSE

The purpose of this program is to establish IT Landes, hereina�er referred to as “the Company,” safe work prac�ces for electrical tools, equipment, and their related components.

2.0 SCOPE

The scope of this program covers all permanent and temporary Company employees and Company contractors while working on any Company-owned sites. If the Company does not own a par�cular site; the site owner’s program shall be used on that site unless the site owners’ program is less stringent.

3.0 DEFINITIONS

Class I Hazardous Loca�ons: Areas having the presence of flammable gases or vapors in the air, such as natural gas or gasoline vapor. When these materials are found in the atmosphere, a poten�al for explosion exists, which could be ignited if an electrical or other source of igni�on is present. The Code writers have referred to this first type of hazard as Class I. So, a Class I Hazardous Loca�on is one in which flammable gases or vapors may be present in the air in sufficient quan��es to be explosive or ignitable. Some typical Class I loca�ons are:

• Petroleum refineries, and gasoline storage and dispensing areas

• Dry cleaning plants where vapors from cleaning fluids can be present

• Spray finishing areas

• Aircra� hangars and fuel servicing areas

• U�lity gas plants, and opera�ons involving storage and handling of liquefied petroleum gas or natural gas

Class II Hazardous Loca�ons: Areas made hazardous by the presence of combus�ble dust. These are referred to in the Code as “Class II Loca�ons.” Finely pulverized material, suspended in the atmosphere, can cause as powerful an explosion as one occurring at a petroleum refinery. Some typical Class II loca�ons are:

• Grain elevators

• Flour and feed mills

• Plants that manufacture, use or store magnesium or aluminum powders

• Producers of plas�cs, medicines, and fireworks

• Producers of starch or candies

• Spice-grinding plants, sugar plants and cocoa plants

• Coal prepara�on plants and other carbon handling or processing areas

Class III Hazardous Loca�ons: Areas where there are easily ignitable fibers or flying’s present, due to the types of materials being handled, stored, or processed. The fibers and flying’s are not likely to be suspended in the air but can collect around machinery or on ligh�ng fixtures and where heat, a spark or hot metal can ignite them. Some typical Class III loca�ons are:

• Tex�le mills

• Coton gins

• Coton seed mills

• Flax processing plants

• Plants that shape, pulverize, or cut wood and create sawdust or flyings

Circuit Breaker: An automa�c switch that stops the flow of electric current in a suddenly overloaded or otherwise abnormally stressed electric circuit.

Disconnec�ng Means: A device or other means by which circuit conductors can be disconnected from a power supply.

Disconnec�ng Switch: A device, which is used to isolate a circuit or equipment from a power source.

Double Insulated Tool: Tools which are constructed using non-conduc�ve materials that do not require grounded, 3-wire plugs.

Grounded Conductor: A conductor that is used to connect equipment or the grounding circuit of a wiring system to a grounding electrode or several grounding electrodes.

Ground Fault Circuit Interrupter (GFCI): A device that interrupts the electrical circuit to the load when a fault current to the ground exceeds a predetermined value that is less than what is required to operate the over current protec�ve device of the supply circuit.

Qualified Person: A person who currently trained in the opera�on, repair, maintenance, construc�on and implementa�on of electrical equipment and electrical hazards.

4.0 RESPONSIBILITIES

Safety Manager

• Develop electrical safety programs and procedures in accordance with regulatory standards and ae required by each individual site.

• Ensure that Company employees fully comply with this program.

• Ensure that no unqualified employees work on energized electrical circuit equipment or their parts.

Supervisors

• Ensure that only qualified employees and/or qualified contractors perform electrical repairs and installa�ons.

• Ensure that electrical programs and procedures address site-specific hazards or hazards that are presented by unique circumstances at their respec�ve areas of responsibility.

• Ensure that no unqualified employees work on energized electrical circuit equipment or their parts.

Qualified Employees

• Ensure that no unqualified employees work on energized electrical circuit equipment or their parts.

• Ensure individual familiarity with the use of special precau�onary techniques, personal protec�ve equipment, insulated tools, insula�ng materials and shielding materials.

Employees

• Ensure that only qualified employees work on energized electrical circuit equipment or other related parts.

• Report all poten�al electrical hazards to supervisors immediately.

5.0 SAFE WORK PRACTICES

General

• All electrical equipment, tools, and related components must be inspected prior to each use.

• Equipment, tools, and related components, which are unserviceable or faulty, shall be removed from service and tagged appropriately with the date of inspec�on, the name of the inspec�ng employee and signature of inspec�ng employee.

• Only qualified personnel may repair electrical tools, cords, and other related equipment.

• Only cer�fied electricians may repair or conduct maintenance on electrical equipment and wiring systems.

• The site supervisor shall verify contract electrician creden�als before work begins.

• Employees shall not wear conduc�ve apparel such as rings, watches, etc. unless they are rendered nonconduc�ve by covering, wrapping or other insula�ng means.

• When working on or near exposed de-energized parts, those parts shall be treated as live.

• Outlets connected to circuits with different voltages must use a design such that the atachment plugs on the circuits are not interchangeable.

• Mul�ple outlet boxes must be plugged into a wall receptacle.

• Mul�ple outlet boxes must not be used to provide power to microwave ovens, toasters, space heaters, hot plates, coffeepots, or other high-current loads.

• Double insulated tools must have the factory label intact indica�ng the tool has been approved to be used without a three-wire grounded supply cord connec�on.

• Double insulated tools must not be altered in any way, which would negate the factory ra�ng.

• Only approved, cer�fied, electrical contractors may perform construc�on and service work on the Company or client property.

• It is the manager/supervisor’s responsibility to verify the contractor’s cer�fica�on.

Extension Cords

• Use only 3-wire, grounded, extension cords and cables that conform to a hard service ra�ng of 14 amps or higher, and grounding of the tools or equipment being supplied.

• Only commercial or industrial rated-grounded extension cords may be used in shops and outdoors.

• Cords for use other than indoor appliances must have a ra�ng of at least 14 amps.

• Cords must have suitable strain relief provisions at the plug the receptacle ends.

• Work lamps (drop light) used to power electrical tools must have a 3-wire, grounded outlet, unless powering insulated tools.

• Adapters that allow three wire, grounded prongs, connected to two wire non-grounded outlets are strictly prohibited.

• Cords must have a service ra�ng for hard or extra-hard service and have S, AJ, ST, SO, SJO, SJT, STO, or SJTO printed on the cord.

• Cords may not be run through doorways, under mats or carpets, across walkways or aisles, concealed behind walls, ceilings, or floors, or run through holes in walls, or anywhere where they can become a tripping hazard.

• High current equipment or appliances should be plugged directly into a wall outlet whenever possible.

All extension cords shall be plugged into one of the following:

• A GFCI outlet

• A GFCI built into the cord

• A GFCI adapter used between the wall outlet and cord plug

All extension cords and or electrical cords shall be inspected daily or before each use, for breaks, plug condi�on and ground lugs, possible internal breaks, and any other damage. If damage is found, the extension cord or electrical cord shall be removed from service and repaired or replaced.

Extension cords shall not be used on compressor skid to operate heat tapes or any other type of equipment on a temporary basis. Heat tapes or other equipment shall be hard wired per applicable electrical codes.

Illumina�on

Employees shall not enter spaces containing exposed energized parts unless qualified and proper illumina�on exists to enable employees to work safely.

Switches, Circuit Breakers, and Disconnects

• All electrical equipment and tools must have an on and off switch and may not be turned on or off by plugging or unplugging the supply cord at the power outlet.

• Circuit breaker panel boxes and disconnects must be labelled with the voltage ra�ng.

• Each breaker within a breaker panel must be labelled for the service it provides.

• Disconnect switches providing power for individual equipment must be labelled accordingly.

Ladders

• Portable ladders must have non-conduc�ve side rails.

• Ladders must be manufactured using non-conduc�ve materials such as fiberglass or wood.

• Aluminum or metal ladders are strictly prohibited.

• Ladders shall be free of defects and defec�ve components.

• Ladders shall be used per the manufacturer’s recommenda�ons only.

Energized and Overhead High-Voltage Power Lines and Equipment

• A minimum clearance of 10 feet from high-voltage lines must be maintained when opera�ng vehicular and mechanical equipment such as forkli�s, cranes, winch trucks, and other similar equipment.

• When possible, power lines shall be de-energized and grounded or other protec�ve measures shall be provided before work is started.

• Minimum approach distance to energized high power voltages lines for unqualified employees is 10 feet.

• Minimum approach distance for qualified employees shall be followed per 29 CFR 1910.333(c)(3)(i) Qualified

Table S5 Selec�on and Use of Work Prac�ces – Approach Distances for Qualified Employees – Alterna�ng Current). Approach distances are 10 feet for 50 kilovolts plus 4 inches for every addi�onal 10 kilovolts

Confined or Enclosed Workspaces

• When an employee works in a confined or enclosed space that contains exposed energized parts, the employee shall isolate the energy source and turn off the source and lock and tag out the energy source. Only qualified electricians can work on an exposed energy source.

• Protec�ve shields, protec�ve barriers, or insula�ng materials as necessary shall be provided.

Enclosures, Breaker Panels, and Distribu�on Rooms

• A clear working space must be maintained in the front, back and on each side of all electrical enclosures and around electrical equipment for a safe opera�on and to permit access for maintenance and altera�on.

• A minimum, 2-foot working floor space in front of panels and enclosures shall be painted yellow.

• Employees may not enter spaces containing exposed energized parts unless illumina�on is provided that enables the employees to work safely.

• Housekeeping in distribu�on rooms must receive high priority to provide a safe working and walking area in front of panels and to keep combus�ble materials to the minimum required to perform maintenance opera�ons.

• All enclosures and distribu�on rooms must have “Danger: High Voltage Authorized Personnel Only” posted on the front panel and on entrance doors.

• Flammable materials (boxes, rags, cleaning fluids, etc.) are strictly prohibited inside distribu�on rooms.

Lockout/Tagout

• No work shall be performed on (or near enough to them for employees to be exposed due to the dangers of tools or other equipment coming into contact with the live parts) live parts and the hazards they present.

• If any employee is exposed to contact with parts of fixed electric equipment or circuits which have been deenergized, the circuits energizing the parts shall be locked out or tagged or both.

• Conductors and parts of electrical equipment that have been de-energized but not been locked or tagged out shall be treated as live parts.

• Per the Company policy, all electrical will be outsourced and performed only by qualified and licensed electrical contractors who are familiar with the use of special precau�onary techniques, PPE, insula�ng and shielding materials and insulated tools. Any equipment being made ready for maintenance will be locked out using the Company’s lockout/tagout program. Lockouts are performed by the safety manager, shop foreman, or branch manager. Designated employees in some branches may be trained by local management to lock out equipment. If live sources are to be worked, it will only be performed with the knowledge of local management. Only cer�fied electricians may work on electric circuit parts or equipment.

• Only authorized personnel may perform lockout/tagout work on electrical equipment and will follow the Company’s lockout/tagout program.

• Authorized personnel will be trained in lockout/tagout procedures.

• Affected personnel will be no�fied when lockout/tagout ac�vi�es are being performed in their work area.

Fire Ex�nguishers

• Approved fire ex�nguishers must be provided near electrical breaker panels and distribu�on centers

• Water type ex�nguishers shall not be located closer than 50 feet from electrical equipment.

Electric Shock-CPR

• If someone is discovered that has received an electric shock and is unconscious, first check to see if their body is in contact with an electrical circuit. Do not touch a person un�l there is no contact with an electrical circuit.

• When it is safe to make contact with the vic�m, begin CPR if the person’s heart has stopped or they are not breathing

• Call for help immediately.

Electric Welders

• A disconnec�ng means shall be provided in the supply circuit for each motor-generator arc welder, and for each AC transformer and DC rec�fier arc welder which is not equipped with a disconnect mounted as an integral part of the welder.

• A switch or circuit breaker shall be provided by which each resistance welder and its control equipment can be isolated from the supply circuit. The ampere ra�ng of this disconnec�ng means may not be less than the supply conductor ampacity.

Equipment Grounding

• All gas compressors, air compressors, separators, vessels, etc. shall be grounded by means of using a lug and ground strap, nominal in size to a half-inch bolt or larger, atached to a ground rod six feet or longer.

• Equipment bonding jumpers shall be of copper or other corrosion-resistance material.

• The transfer of hazardous or flammable material from a metal or plas�c container with a flash point of 100°F or less shall have a ground strap from the container and atached to the skid or a ground rod placed in the ground.

Assured Grounding

• OSHA requires that employers shall use either ground fault circuit interrupters (GFCIs) or an assured equipment grounding conductor program to protect personnel from electrical shock while working.

• The Company shall use GFCIs in lieu of an assured grounding program.

Ground Fault Circuit Interrupters

• All 120-volt, single-phase 15-amp and 20-amp receptacle outlets on construc�on or maintenance sites, which are not part of the permanent wiring of the building or structure, and which are in use by employees, shall have approved ground fault circuit interrupters for personnel protec�on.

• All hand portable electric tools and extension cords shall use a GFCI.

• Addi�onally, approved GFCIs shall be used for 240-volt circuits in the same service as described above.

• GFCIs must be used on all 120-volt, single-phase 15 and 20-amp receptacles within 6 feet of a sink, damp areas or on installed outdoor equipment.

• The GFCI must be the first device plugged into a permanent receptacle.

• The GFCI must be tested before each use.

6.0 TRAINING

All Company employees both temporary and full �me shall be trained in electrical safety prac�ces and procedures to minimize the risk of electrical shock.

Unqualified employees who may be exposed to electric shock shall receive training and acquire familiarity with electric safety work prac�ces

All Company employees both temporary and full �me shall be trained in safety-related work prac�ces that pertain to their respec�ve job assignments.

Safe work prac�ces shall be used to prevent electric shock or other related incidents as a result of energy source contact while working near or on energized equipment or circuits.

In the event that the Company employees are qualified employees, those employees must adhere to the approach distances in Table S5 of CFR 1910.333.

EMERGENCY ACTION PLAN

1.0 PURPOSE

The purpose of the IT Landes, hereina�er referred to as “the Company,” emergency ac�on plan is to comply with OSHA 29 CFR 1910.38 (Emergency Ac�on Plan), and to prepare employees for dealing with emergency situa�ons. This plan is designed to minimize injury and loss of human life and Company resources by training employees, procuring, and maintaining necessary equipment, and assigning responsibili�es. This plan applies to all emergencies that may reasonably be expected to occur at the Company.

2.0 RESPONSIBILITIES

A safety commitee manager shall manage the emergency ac�on plan for the Company. The emergency plan manager shall also maintain all training records pertaining to this plan. The emergency plan manager is responsible for scheduling rou�ne tests of the Company emergency no�fica�on system with the appropriate authori�es. The emergency plan manager shall also coordinate with local public resources, such as fire department and emergency medical personnel, to ensure that they are prepared to respond as detailed in this plan.

The emergency plan coordinators are as follows:

The emergency plan coordinators are responsible for ins�tu�ng the procedures in this plan in their designated areas in the event of an emergency. Note: Coordinators may also be given the responsibility of accoun�ng for employees/visitors a�er an evacua�on has occurred.

The following individuals shall be responsible for assis�ng employees who have disabili�es or who do not speak English during evacua�on:

The Company will provide adequate controls and equipment that, when used properly, will minimize, or eliminate risk of injury to employees in the event of an emergency. Management will ensure proper adherence to this plan through regular review.

Supervisors shall themselves follow and ensure that their employees are trained in the procedures outlined in this plan.

Employees are responsible for following the procedures described in this plan.

Contractors are responsible for complying with this plan and shall be provided the training described herein by a safety commitee member.

3.0 POLICY

The Company shall keep this writen emergency ac�on plan in the workplace, and it will be available to employees for review.

4.0 REPORTING FIRE AND EMERGENCY SITUATIONS

All fires and emergency situa�ons will be reported as soon as possible to a safety commitee member or other designated responsible person(s) verbally as soon as possible during normal work hours or by telephone if a�er normal work hours or on weekends.

To eliminate confusion and the possibility of false alarms, only a safety commitee member or other designated responsible person(s) is/are authorized to contact the appropriate community emergency response personnel. The telephone numbers and contact informa�on for the emergency response personnel are:

Fire: _____________________

Police: ___________________

Ambulance: _______________

Under no circumstances shall an employee atempt to fight a fire that has passed the incipient stage (that which can be put out with a fire ex�nguisher), nor shall any employee atempt to enter a burning building to conduct search and rescue. These ac�ons shall be le� to emergency services professionals who have the necessary training, equipment, and experience (such as the fire department or emergency medical professionals). Untrained individuals may endanger themselves and/or those they are trying to rescue.

The alarm system shall be dis�nc�ve and recognizable as a signal to evacuate the work area or perform ac�ons designated under the emergency ac�on plan.

Informing Employees of Fires and Emergency Situa�ons

In the event of a fire or emergency situa�on, a safety commitee member or other designated responsible person(s) shall ensure that all employees are no�fied as soon as possible using the building alarm system, which includes both audible and visual alarms 24 hours a day. A safety commitee member or other designated responsible person(s) shall provide special instruc�ons to all employees via the public address system.

If a fire or emergency situa�on occurs a�er normal business hours, a safety commitee member or other designated responsible person(s) shall contact all employees not on shi� of future work status, depending on the nature of the situa�on.

5.0 EMERGENCY CONTACT INFORMATION

A safety commitee member or other designated responsible person(s) shall maintain a list of all employee emergency contact informa�on and shall keep the list in a designated area for easy access in the event of an emergency. In addi�on, the name or job �tle of every employee who may be contacted by employees who need more informa�on about the plan, or an explana�on of their du�es, shall be made available to all personnel and posted at worksites.

6.0 EVACUATION ROUTES

Emergency evacua�on escape route plans are posted in designated areas throughout the Company. In the event that a fire/emergency alarm is sounded, or instruc�ons for evacua�on are given by a safety commitee member, all employees (except key noted personnel) shall immediately exit the building(s) at the nearest exits as shown in the escape route plans and shall meet as soon as possible at the designated assembly area. Employees with offices shall close the doors (unlocked) as they exit the area.

Mobility impaired employees and their assigned assistants will gather at the designated area within the building to ensure safe evacua�on in the pre-determined fashion.

7.0 SECURING PROPERTY AND EQUIPMENT

In the event that evacua�on of the premises is necessary, some items may need to be secured to prevent further detriment to the facility and personnel on hand (such as securing confiden�al/irreplaceable records or shu�ng down equipment to prevent release of hazardous materials). Only the following individuals may remain in the building for the prescribed amount of �me to secure the property and equipment to which they have been assigned:

All individuals remaining behind to shut down cri�cal systems or u�li�es shall be capable of recognizing when to abandon the opera�on or task. Once the property and/or equipment has been secured, or the situa�on becomes too dangerous to remain, these individuals shall exit the building by the nearest escape route as soon as possible and meet the remainder of the employees at the designated assembly area

8.0 ADVANCED MEDICAL CARE

Under no circumstances shall an employee provide advanced medical care and treatment. These situa�ons shall be le� to emergency services professionals, or designated responsible person(s), who have the necessary training, equipment, and experience. Untrained individuals may endanger themselves and/or those they are trying to assist.

9.0 ACCOUNTING FOR EMPLOYEES AND VISITORS AFTER EVACUATION

Once an evacua�on has occurred, responsible person(s) shall account for each employee/visitor assigned to them at the designated assembly area. Each employee is responsible for repor�ng to the appropriate responsible person(s) so an accurate head count can be made. All employee counts shall then be reported to the emergency plan manager as soon as possible.

All employees must be accounted for a�er evacua�on.

10.0 RE-ENTRY

Once the building has been evacuated, no one shall reenter the building for any reason, except for designated and properly trained rescue personnel (such as fire department or emergency medical professionals). Untrained individuals may endanger themselves and/or those they are trying to rescue.

All employees shall remain at the designated assembly area un�l the fire department or other emergency response agency no�fies a designated responsible person(s) that either:

• The building is safe for reentry, in which case personnel shall return to their worksta�ons; or

• The building/assembly area is not safe, in which case personnel shall be instructed by a designated responsible person(s) on how/when to vacate the premises.

11.0 SHELTERING IN PLACE

In the event that chemical, biological, or radiological contaminants are released into the environment in such quan�ty and/or proximity to the Company, authori�es and/or a safety commitee member or other designated responsible person(s) may determine that it is safer to remain indoors rather than to evacuate employees. The emergency plan manager shall announce shelter-in-place status by public address system or other means of immediate no�fica�on available at worksite.

• The designated responsible person(s) shall immediately close the business. If there are customers, clients, or visitors in the building, they shall be advised to stay in the building for their safety.

• Unless there is an imminent threat, employees, customers, clients, and visitors shall call their emergency contacts to let them know where they are and that they are safe.

• The designated responsible person(s) shall turn on call-forwarding or alterna�ve telephone answering systems or services. The recording for voicemail or automated atendant shall be changed to indicate that the business is closed, and that staff and visitors will be remaining in the building un�l authori�es advise that it is safe to leave.

• The designated responsible person(s) shall quickly lock exterior doors and close windows, air vents, and fireplace dampers. In addi�on, designated responsible person(s) familiar with the building’s mechanical systems shall turn off, seal, or disable all fans, hea�ng and air condi�oning systems, and clothes dryers, especially those systems that automa�cally provide for exchange of inside air with outside air. If there is a danger of explosion, responsible person(s) shall close the window shades, blinds, or curtains.

A safety commitee member or other designated responsible person(s) shall gather essen�al disaster supplies (e.g., non-perishable food, botled water, batery-powered radios, first-aid supplies, flashlights, bateries, duct tape, plas�c shee�ng, and plas�c garbage bags), which are stored at a pre-determined designated loca�on, and shall take them to the shelter-in-place loca�on(s) within the building.

If possible, this designated area shall be an interior room(s) above the ground floor, with the fewest windows or vents. The room(s) should have adequate space for everyone to be able to sit. Avoid overcrowding by selec�ng several rooms if necessary. Large storage closets, u�lity rooms, pantries, copy and conference rooms without exterior windows will work well. Avoid selec�ng rooms with mechanical equipment like ven�la�on blowers or pipes. These should be avoided because this equipment may not be able to be sealed from the outdoors. It is ideal to have a hard-wired telephone in the selected room(s). Cellular telephone equipment may be overwhelmed or damaged during an emergency. Call emergency contacts and have the telephone available in case there is a need to report a life-threatening condi�on.

• All employees, customers, and visitors shall move immediately to the shelter-in-place loca�on(s) within the building. Responsible person(s) shall seal all windows, doors, and vents with plas�c shee�ng and duct tape.

• Responsible person(s) shall write down the names of everyone in the room and call the designated emergency contact outside of the building to report who is in the room, and their affilia�ons with the Company (employee, customer, visitor).

• Responsible person(s) shall monitor telephone, radio, television, and internet reports for further instruc�ons from authori�es to determine when it is safe to leave the building.

12.0 SEVERE WEATHER

The emergency plan manager shall announce severe weather alerts (such as tornados) by public address system or other means of immediate no�fica�on available at worksite. All employees shall immediately retreat to the

designated loca�on un�l the threat of severe weather has passed as communicated by the emergency plan manager.

13.0 TRAINING Employee Training

All employees shall receive instruc�on on this emergency ac�on plan as part of new hire orienta�on upon hire. Addi�onal training shall be provided:

• When the plan is developed, or the employee is assigned ini�ally to a job

• When there are any changes to the plan and/or facility

• When an employee’s responsibili�es change

• Annually as refresher training

Items to be reviewed during the training include:

• Proper housekeeping

• Fire preven�on prac�ces

• Fire ex�nguisher loca�ons, usage, and limita�ons

• Threats, hazards, and protec�ve ac�ons

• Means of repor�ng fires and other emergencies

• Names of emergency plan manager and coordinators

• Individual responsibili�es

• Alarm systems

• Escape routes and procedures

• Emergency shutdown procedures

• Procedures for accoun�ng for employees and visitors

• Closing doors

• Sheltering in place

• Severe weather procedures

• Emergency ac�on plan availability

14.0 FIRE AND EVACUATION DRILLS

Fire and evacua�on drills shall be conducted at least once a year and shall be conducted in coordina�on with local police and fire departments. Addi�onal drills shall be conducted if physical proper�es of the business change, processes change, or as otherwise deemed necessary.

15.0 TRAINING RECORDS

Responsible person(s) shall document all training pertaining to this plan and shall maintain records at the designated area.

16.0 PLAN EVALUATION

This emergency ac�on plan shall be reviewed annually, or as needed if changes to the worksite are made, by responsible person(s). Following each fire drill, responsible management and employee representa�ves shall evaluate the drill for effec�veness and weaknesses in the plan and shall implement changes to improve it.

FALL PROTECTION/WORKING AT HEIGHTS

1.0 PURPOSE

The purpose of this document is to outline the safety policy and procedures surrounding fall protec�on for IT Landes, hereina�er referred to as “the Company.”

The hazards of poten�al falls at heights of 6 feet and above will be addressed in this document. This instruc�on describes a systema�c approach that must be used to protect and prevent people from falling. This instruc�on also lists some of the most common fall hazards and provides recommenda�ons and guidelines for selec�ng fall arrest systems.

OSHA 1926.500-503, 1926.502(j)

2.0 RESPONSIBILITIES

Many workers are injured or killed from falls each year, and it is the policy of the Company to provide a healthy work environment for its employees. Therefore, management commits the necessary resources and �me to ensure that all persons on worksites are protected from injury and illness hazards. Management staff at the Company, including the execu�ve team, will lead in the design, implementa�on, and con�nuous monitoring and improvement of the site’s health and safety ac�vi�es.

The Company safety officer is a safety commitee member and is responsible for the administra�on of this program and has full authority to make necessary decisions to ensure success of the program. All Company employees are responsible for safety at all �mes. The Company has expressly authorized this person to halt any Company opera�on where there is danger of serious personal injury.

The fall protec�on plan shall be prepared by a qualified person for the specified worksite.

Management shall perform annual reviews of this safety policy and any corresponding training programs/records to ensure that all workers are trained in the awareness and avoidance of unsafe acts and situa�ons surrounding the use and or exposure of fall protec�on.

Contractor

In addi�on to complying with the fall protec�on requirements that apply to all employees, each contractor who is retained to perform opera�ons that involve fall protec�on will:

• Obtain any available informa�on regarding fall hazards and protec�ve measures from the Company.

• Coordinate fall protec�on opera�ons with the Company when both Company personnel and contractor personnel will be working in or near recognized fall hazard loca�ons.

• Inform the Company of the fall protec�on program that the contractor will follow and of any hazards confronted or created in conduc�ng opera�ons involving fall protec�on within Company-owned facili�es through a debriefing immediately prior to the opera�on.

It will remain the duty of the Company’s ac�ve management team to ensure that all fall preven�on equipment is properly maintained and used by trained personnel.

Employees and personnel of the Company, including part-�me and temporary labor, shall follow this writen safety policy to ensure a safe work environment for all.

Competent Person

A competent person is someone who is capable of iden�fying exis�ng and predictable hazards in the surrounding or working condi�ons which are unsanitary, hazardous, or dangerous to personnel, and who has authoriza�on to take prompt correc�ve measures to eliminate them.

3.0 POLICY

Fall protec�on is required whenever employees are poten�ally exposed to falls from heights that exceed applicable regulatory thresholds. Guard rails, safety nets, or personal or fall arrest systems should be used.

Employees will adhere to the fall protec�on standards set for below depending upon which job func�on they are performing. General Industry 1910.23(b).

Every wall opening from which there is a drop of more than 4 feet shall be protected from falling by the use of guardrail systems, safety net systems, or personal fall arrest systems. Construc�on Industry 1926.501(b)(1)

Each employee on a walking/working surface (horizontal and ver�cal surface) with an unprotected side or edge which is 6 feet or more above a lower level shall be protected from falling by the use of guardrail systems, safety net systems, or personal fall arrest systems. Marine Terminals 1917.112(b)(1)

Guardrails shall be provided at loca�ons where employees are exposed to floor or wall openings or waterside edges, including bridges or gangway-like structures leading to pilings or vessel mooring or berthing installa�ons, which present a hazard of falling more than 4 feet or into the water. Shipyard Industry 1915.73(d).

When employees are exposed to unguarded edges of decks, pla�orms, flats, and similar flat surfaces, more than 5 feet above a solid surface, the edges shall be guarded by adequate guardrails. Steel Erec�on 1926.760(a)(1).

Each employee engaged in a steel erec�on ac�vity and is on a walking/working surface with an unprotected side or edge more than 15 feet above a lower level shall be protected from fall hazards by guardrail systems, safety net systems, personal fall arrest systems, posi�oning device systems or fall restraint systems.

The fall protec�on plan shall be prepared by a qualified person for each specific worksite.

When conven�onal fall protec�on is not used, these loca�ons will be iden�fied and classified as controlled access zones.

Where no other alternate methods have been implemented, a safety monitoring system will be implemented.

A competent person will be assigned to:

• Recognize fall hazards.

• Warn employees if they are unaware of a fall hazard or is ac�ng in an unsafe manner.

• Be on same working surface and in visual sight

• Stay close enough for verbal communica�on.

• Not have other assignments that would take monitor’s aten�on from the monitoring func�on.

Scaffolding must be designed, erected, inspected, labeled, and dismantled by competently trained persons.

All accidents and serious incidents (near accidents) shall be inves�gated, implemen�ng changes to the fall protec�on plan as necessary.

When purchasing equipment and raw material for use in fall protec�on systems applicable ANSI and ASTM requirements will be met.

The Company will provide for prompt rescue of employees in the event of a fall or shall ensure the employees are able to rescue themselves.

The workplace shall be assessed before each assigned job for poten�al fall hazards. Proper fall arrest equipment will be used for jobs requiring fall protec�on when elimina�on of the hazard(s) is not possible. The Company will evaluate the facili�es by department to determine fall hazards. This preliminary evalua�on will detail the required steps for protec�ng employees from fall hazards.

4.0 TRAINING

The Company shall provide a training program for each employee who may be exposed to fall hazards, or who may have the likelihood of exposure to this risk. Training shall enable each employee to recognize the hazards of falling and shall train each employee in the procedure to follow to minimize all associated falling hazards.

The Company will have writen cer�fica�on records showing the following:

• Person(s) trained

• Dates of training

• Signature of person providing training and dates employer determined training was deemed adequate

The Company will provide retraining when the following occur, are noted, or observed:

• Deficiencies in training

• Workplace changes

• Fall protec�on systems or equipment changes that render previous training obsolete

Client Requirement

A training program shall be provided for all employees who will be exposed to fall hazards in the work area and will be conducted by competent personnel. The program will include but will not be limited to:

• A descrip�on of fall hazards in the work area

• Procedures for using fall preven�on and protec�on systems

• Equipment limita�ons

• The elements encompassed in total fall distance

• Preven�on, control, and fall arrest systems

• Inspec�on and storage procedures for the equipment

Generally, workers will be trained to recognize the hazards of falling from eleva�ons and to avoid falls from grade level to lower levels through holes or openings in walking/working surfaces.

Training programs will include preven�on, control, and fall arrest systems. It must be ensured that appropriate fall arrest systems are installed, and that employees know how to use them before beginning any work that requires fall protec�on.

Ini�al Training

Training will be conducted prior to job assignment. The Company will provide training to ensure that the purpose, func�on, and proper use of fall protec�on is understood by employees and that the knowledge and skills required for the safe applica�on and usage is acquired by employees. This standard prac�ce instruc�on will be provided to and read by all employees receiving training.

The training at a minimum will include the following:

• Types of fall protec�on equipment appropriate for use

• Recogni�on of applicable fall hazards associated with the work to be completed and the loca�ons of such

• Load determina�on and balancing requirements

• Procedures for removal of protec�on devices from service for repair or replacement

• All other employees whose work opera�ons are or may be in an area where protec�on devices fall may be u�lized, will be instructed to an awareness level concerning hazards associated with fall protec�on opera�ons

• Fall protec�on equipment iden�fica�on:

o Fall protec�on equipment having iden�fica�on numbers will be checked for legibility

o Fall protec�on equipment having illegible iden�fica�on markings will be turned in to the supervisor for inspec�on

• Equipment maintenance and inspec�on requirements

• Equipment donning and doffing procedures

• Equipment strengths and limita�ons

Cer�fica�on Training

The Company will cer�fy that employee training has been accomplished and is being kept up to date. The cer�fica�on will contain each employee’s name and dates of training. Training will be conducted by competent personnel.

Refresher Training

This standard prac�ce instruc�on will be provided to and read by all employees receiving refresher training. The training content will be iden�cal to ini�al training. Refresher training will be conducted on a semi-annual basis or when the following condi�ons are met, whichever event occurs sooner.

Retraining will be provided for all authorized and affected employees whenever (and prior to) a change in their job assignments, a change in the type of fall protec�on equipment used, or when a known hazard is added to the work environment which affects the fall protec�on program.

Addi�onal retraining will also be conducted whenever a periodic inspec�on reveals, or whenever the Company has reason to believe that there are devia�ons from or inadequacies in the employee’s knowledge or use of fall protec�on equipment or procedures.

Whenever a fall protec�on procedure fails. The retraining will reestablish employee proficiency and introduce new or revised methods and procedures, as necessary.

Cer�fica�on

The Company will cer�fy that employee training has been accomplished and is being kept up to date. The cer�fica�on will contain each employee’s name and dates of training. Training will be conducted by competent personnel.

5.0 FALL PREVENTION Control Procedures Development

Once a facility evalua�on has been accomplished, procedures will be developed, documented, and u�lized for the control of poten�al fall hazards. Fall preven�on plans will be designed by competent individuals or other competent personnel.

Company engineers (where u�lized) or other competent personnel will be provided with any required specialized training to recognize fall hazards, to understand and address fall preven�on techniques, and to become familiar with fall arrest equipment and procedures. It is cri�cal that they consider fall protec�on design for the safety of opera�ons where employees must work at elevated heights. Safety during access and egress from elevated worksites will also be considered.

The following guidelines will be used when planning work at elevated heights:

• Involve the Safety Department early in the project planning/job planning so that they can recommend appropriate fall-protec�on measures and equipment.

• Involve qualified engineers when load ra�ng of anchorage points must be determined or is in doubt. Required training will be provided as necessary.

• Involve engineering and maintenance when anchorage points must be installed.

o The Company and Engineering Departments will use the exper�se of fall protec�on equipment manufacturers such as Rose Manufacturing Company, Miller Equipment Company, Research and Trading Company, and DBI/SALA.

o The Company will be specific in dealing with fall hazards when developing contracts. Contractors will be required to provide a writen fall protec�on program which describes the contractor fall protec�on policies and procedures when they will be working at elevated heights.

6.0 PROTECTIVE MATERIALS AND EQUIPMENT

Appropriate fall protec�on devices will be provided for poten�al fall hazards. Selec�on of the equipment will be based on the fall protec�on evalua�on. Evalua�ons will be conducted by the personnel authorized to evaluate fall protec�on requirements.

Fall protec�on devices will be singularly iden�fied, be the only devices(s) used for controlling falls, not be used for other purposes, and meet the following requirements:

• Capable of withstanding the environment to which they are exposed for the maximum period of �me that exposure is expected.

• Anchor points will not deteriorate when located in corrosive environments such as areas where acid and alkali chemicals are handled and stored.

• Capable of withstanding the ul�mate load of 5,000 pounds for the maximum period of �me that exposure is expected.

• Standardiza�on within Company facili�es. Fall protec�on devices will be standardized whenever possible.

7.0 FALL PROTECTION SYSTEMS

When fall hazards cannot be eliminated through any other means, fall arrest systems will be used to control falls. When u�lizing a fall arrest system employees shall be prohibited from working alone and must prac�ce 100% �e off at all �mes. Proper training on the use of fall arrest equipment is essen�al and will be provided prior to use.

Full-Body Harness Systems

A full-body harness system consists of a full-body harness, lanyard, energy shock absorber, and self-locking snap hook. Before using a full-body harness system, the supervisor and/or user must address such issues as:

• Has the user been trained to recognize fall hazards and to use fall arrest systems properly?

• Are all components of the system compa�ble according to the manufacturer’s instruc�ons?

• Have appropriate anchorage points and atachment techniques been reviewed?

• Has free fall distance been considered so that a worker will not strike a lower surface or object before the fall is arrested?

• Have swing fall hazards been eliminated?

• Have safe methods to retrieve fallen workers been planned?

• Has the full-body harness and all of its components been inspected both before each use and on a regular semi-annual basis?

• Is any of the equipment, including lanyards, connectors, and lifelines, subject to such problems as welding damage, chemical corrosion, or sandblas�ng opera�ons?

8.0 RETRACTABLE LIFELINES

A retractable lifeline is a fall arrest device used in conjunc�on with other components of a fall arrest system. Retractable lifelines should be used by one person at a �me. A properly inspected and maintained retractable lifeline, when correctly installed and used as part of the fall arrest system, automa�cally stops a person’s descent in a short distance a�er the onset of an accidental fall. Retractable lifelines may be considered when working in areas such as on roofs and scaffolds, or in tanks, towers, vessels, and manholes. Retractable lifelines should also be considered when climbing such equipment as ver�cal fixed ladders. Before using a retractable lifeline, the supervisor and/or user must address the following ques�ons:

• Has the user been trained to use a retractable lifeline correctly?

• Is the retractable lifeline being used in conjunc�on with a complete fall arrest system?

• Is the equipment under a regular maintenance program?

• Has the equipment been inspected within the last six months?

9.0 STANDARD HARNESS

Harnesses for general purpose work should be Class III, constructed with a sliding back D-ring. Standard harnesses are suitable for con�nuous fall protec�on while climbing, riding, or working on elevated personnel pla�orms. They are suitable for posi�oning, fall arrest, and the rescue and evacua�on of people who are working at elevated heights.

10.0 INSPECTION AND MAINTENANCE

To ensure that fall protec�on systems are ready and able to perform their required tasks, a program of inspec�on and maintenance will be implemented and maintained. The following at a minimum will comprise the basic requirements of the inspec�on and maintenance program to be performed on a yearly basis:

• Equipment manufacturer’s instruc�ons will be incorporated into the inspec�on and preven�ve maintenance procedures.

• All fall protec�on equipment will be inspected prior to each use, and a documented inspec�on at intervals not to exceed six months, or in accordance with the manufacturer’s guidelines.

• The user will inspect their equipment prior to each use and check the inspec�on date.

• Any fall protec�on equipment subjected to a fall or impact load will be removed from service immediately and inspected be a qualified person (sent back to the manufacturer).

• Check all equipment for mold, damage, wear, mildew, or distor�on.

• Hardware should be free of cracks, sharp edges, or burns.

• Ensure that no straps are cut, broken, torn, or scraped.

• Special situa�ons such as radia�on, electrical conduc�vity, and chemical effects will be considered.

• Equipment that is damaged or in need of maintenance will be tagged as unusable and will not be stored in the same area as serviceable equipment.

• A detailed inspec�on policy will be used for equipment stored for periods exceeding 1 month.

• Anchors and moun�ngs will be inspected before each use by the user and supervisor for signs of damage.

Accident inves�ga�ons shall be conducted to evaluate the fall protec�on plan for poten�al updates to prac�ces, procedures, or training in order to prevent reoccurrence.

11.0 MOST COMMON AND MOST DANGEROUS FALL HAZARDS

The tasks and situa�ons listed below present inherent fall hazards. Give special aten�on to providing fall preven�on and/or fall control for them, remembering that this aten�on is necessary in the design, engineering, planning, and execu�on stages of work. Supervisors will give special considera�on to fall protec�on for the following tasks:

• Working from crane booms and tower cranes

• Working on top of machinery and equipment, such as overhead cranes, furnaces, conveyors, and presses

• Other work that involves fall hazards, such as off-chutes from main piping in duct work or boilers

• Working on roofs, with deteriora�ng or unsupported sec�ons and framing

• Working over chemical tanks or open pits

• Working from fixed or portable ladders or climbing systems

• Performing work on water towers, product tanks, silos, pipe racks, presses, and floor pits

12.0 DEFINITIONS

Anchorage: A secure point of atachment for lifelines, lanyards, or decelera�on devices.

Body Belt: A strap with means both for securing it about the waist and for ataching it to a lanyard, lifeline, or decelera�on device.

Body Harness: Straps which may be secured about the employee in a manner that will distribute the fall arrest forces over at least the thighs, pelvis, waist, chest, and shoulders with means for ataching it to other components of a personal fall arrest system.

Competent Person: A person who is capable of iden�fying hazardous or dangerous condi�ons in any personal fall arrest system or any component thereof, as well as in their applica�on and use with related equipment.

Connector: A device which is used to couple (connect) parts of the personal fall arrest system and posi�oning device systems together. It may be an independent component of the system, such as a carabiner, or it may be an integral component of part of the system.

Decelera�on Device: Any mechanism with a maximum length of 3.5 feet, such as a rope grab, rip s�tch lanyard, tearing or deforming lanyards, self-retrac�ng lifelines, etc. which serves to dissipate a substan�al amount of energy during a fall arrest, or otherwise limit the energy imposed on an employee during fall arrest.

Energy Shock Absorber: A device that limits shock-load forces on the body.

Failure: Load refusal, breakage, or separa�on of component parts. Load refusal is the point where the ul�mate strength is exceeded.

Fall Arrest System: A system specifically designed to secure, suspend, or assist in retrieving a worker in or from a hazardous work area. The basic components of a fall arrest system include anchorage, anchorage connector, lanyard, shock absorber, harness, and self-locking snap hook.

Free Fall: The act of falling before a personal fall arrest system begins to apply force to arrest the fall.

Free Fall Distance: The ver�cal displacement of the fall arrest atachment point on the employee’s body belt or body harness between onset of the fall and just before the system begins to apply force to arrest the fall (maximum of 6 feet). This distance excludes decelera�on distance, and lifeline/lanyard elonga�on, but includes any decelera�on device slide distance or self-retrac�ng lifeline/lanyard extension before they operate and fall arrest forces occur.

Hole: A gap or void 2 inches or more in its least dimension, in a floor, roof, or other walking/working surface.

Lanyard: Flexible line of rope, wire rope, or strap which generally has a connector at each end for connec�ng the body belt or body harness to a decelera�on device, lifeline, or anchorage.

Leading Edge: The edge of a floor roof, or formwork for a floor or other walking/working surface which changes loca�on as addi�onal floor, roof, decking, or formwork sec�ons are placed, formed, or constructed. A leading edge is considered to be an unprotected side and edge during periods when it is not ac�vely and con�nuously under construc�on.

Lifeline: A component consis�ng of a flexible line for connec�on to an anchorage at one end to hang ver�cally or for connec�on to anchorages at both ends to stretch horizontally and which serves as a means for connec�ng other components of a personal fall arrest system to the anchorage.

Opening: A gap or void 30 inches or higher and 18 inches or wider, in a wall or par��on, through which employees can fall to a lower level.

Personal Fall Arrest System: System used to arrest an employee in a fall from a working level. It consists of an anchorage, connectors, a body belt, or body harness and may include a lanyard, decelera�on device, lifeline, or suitable combina�ons of these. As of January 1, 1998, the use of a body belt for fall arrest is prohibited.

Posi�oning Device System: Body belt or body harness system rigged to allow an employee to be supported on an elevated ver�cal surface, such as a wall, and work with both hands free while leaning.

Qualified Person: Recognized degree or professional cer�ficate and extensive knowledge and experience in the subject field who is capable of design, analysis, evalua�on and specifica�ons in the subject work, project, or product.

Retractable Lifeline: A fall arrest device that allows free travel without slack rope but locks instantly when a fall begins.

Rope Grab: A decelera�on device which travels on a lifeline and automa�cally, by fric�on, engages the lifeline and locks so as to arrest the fall of an employee. A rope grab usually employs the principle of iner�al locking, cam/level locking, or both.

Safety-Monitoring System: A safety system in which a competent person is responsible for recognizing and warning employees of fall hazards.

Self-Retrac�ng Lifeline/Lanyard: A decelera�on device containing a drum-wound line which can be slowly extracted from, or retracted onto, the drum under slight tension during normal employee movement, and which, a�er onset of a fall, automa�cally locks the drum and arrests the fall.

Snap Hook: A connector comprised of a hook-shaped member with a normally closed keeper, or similar arrangement, which may be opened to permit the hook to receive an object and, when released, automa�cally closes to retain the object. Snap hooks are generally one of two types:

• The locking type with a self-closing, self-locking keeper which remains closed and locked un�l unlocked and pressed open for connec�on or disconnec�on; or

• The non-locking type with a self-closing keeper which remains closed un�l pressed open for connec�on or disconnec�on. As of January 1, 1998, the use of a non-locking snap hook as part of personal fall arrest systems and posi�oning device systems is prohibited.

Toe Board: A low protec�ve barrier that will prevent the fall of materials and equipment to lower levels and provide protec�on from falls for personnel.

Walking/Working Surface: Any surface, whether horizontal or ver�cal on which an employee walks or works, including, but not limited to, floors, roofs, ramps, bridges, runways, formwork, and concrete reinforcing steel but not including ladders, vehicles, or trailers, on which employees must be located in order to perform their job du�es.

Warning Line System: A barrier erected on a roof to warn employees that they are approaching an unprotected roof side or edge, and which designates an area in which roofing work may take place without the use of guardrail, body belt, or safety net systems to protect employees in the area.

13.0 FALLING OBJECT PREVENTION/PROTECTION OSHA 1926.502(J)

The Company will ensure that toe boards, when used as falling object protec�on, will be erected along the edge of the overhead walking/working surface for a distance sufficient to protect employees below. Any toe board used by the Company must be capable of withstanding, without failure, a force of at least 50 pounds applied in any downward or outward direc�on at any point along the toe board. Toe boards shall be a minimum of 3.5 inches in ver�cal height from their top edge to the level of the walking/working surface. They shall have not more than a 0.25inch clearance above the walking/working surface. They shall be solid or have openings not over 1 inch in greatest dimension.

Guardrail systems, when used as falling object protec�on, shall have all openings small enough to prevent passage of poten�al falling objects.

During the performance of overhead bricklaying and related work, no materials or equipment except masonry and mortar shall be stored within 4 feet of the working edge. Excess mortar, broken or scatered masonry units, and all other materials and debris shall be kept clear from the work area by removal at regular intervals, to prevent injury from falling objects.

During the performance of roofing work, materials which are piled, grouped, or stacked near a roof edge shall be stable and self-suppor�ng.

Canopies, when used as falling object protec�on, shall be strong enough to prevent collapse and to prevent penetra�on by any objects which may fall onto the canopy.

FIRE PREVENTION/EXTINGUISHERS

1.0 PURPOSE

This program is designed to provide procedures to ensure that IT Landes, hereina�er referred to as “the Company,” employees understand how fire ex�nguishers work properly, and employees know how to operate the ex�nguishers safely in the event of a fire.

2.0 SCOPE

The scope of this program encompasses all employees at all loca�ons.

3.0 RESPONSIBILITIES

Safety Manager

• Develop procedures for the use and maintenance of fire ex�nguishers.

• Devise training programs that teach the proper use of these devices

Manager

• Implement fire ex�nguisher training at the manager’s designated loca�on.

Shop Foremen

• Enforce the provisions of the fire ex�nguisher sec�on of the training manual.

Employees

• Follow the provisions of the training manual

4.0 PROCEDURE

Selec�on and Distribu�on

Portable fire ex�nguishers are provided for use by employees. These fire ex�nguishers vary in class based on the type of fire they are made to ex�nguish, the size of the fire, and the degree of hazard that affects the use of the ex�nguisher.

Class A Fire Ex�nguishers: Used on common combus�bles or fibrous materials such as wood, cloth, paper, rubber, and some plas�cs. The distance from employees to any fire ex�nguisher must not exceed 75 feet.

Class B Fire Ex�nguishers: Used on flammable or combus�ble liquids such as gasoline, kerosene, paint, paint thinners, and propane. The distance of the ex�nguisher from an area with Class B hazardous materials must not exceed 50 feet.

Class C Fire Ex�nguishers: Used on electrical equipment that has been energized, such as appliances, panel boxes, and power tools. The distance from an area with Class C hazards to an ex�nguisher is no more than 50 feet

Class D Fire Ex�nguishers: Used on combus�ble metals such as magnesium, �tanium, potassium, and sodium. The distance from a Class D working area to an ex�nguisher is no greater than 75 feet.

Fire Ex�nguisher Labels

• Fire ex�nguishers are mounted in loca�ons that can be easily accessed by employees, are no more than 75 feet from any employee, and are iden�fied by a sign reading, “Fire Ex�nguisher.”

• Fire ex�nguishers will not be blocked, even on a temporary basis, by equipment, boxes, or products.

• A unique number will be assigned to each fire ex�nguisher.

Maintenance

All fire ex�nguishers must be:

• Mounted no higher and no lower than four feet from the floor

• Numbered to iden�fy their designated loca�on

• Fully charged and operable

• Clean and free of defects

• Accessible at all �mes

Inspec�on and Tes�ng

• All fire ex�nguishers shall be inspected on a monthly basis.

• Cer�fied staff from a fire ex�nguisher dealer will perform an annual maintenance check on all fire ex�nguishers and will inspect and recharge fire ex�nguishers a�er use.

• In the event a fire ex�nguisher shows a loss of pressure during the monthly inspec�on, cer�fied staff will inspect and recharge the fire ex�nguisher.

• Completed fire inspec�on logs are to be maintained in the safety files for five years.

Use

• In the event of a fire, an employee will get the nearest appropriate fire ex�nguisher for use on the burning materials and will atempt to put out the fire.

• All other employees in the area will prepare to evacuate the area of the fire if necessary.

• Other employees in the building will be no�fied of the fire.

• A standard fire ex�nguisher emp�es in 10-15 seconds. All employees must leave the area at this �me, even if the fire is not out.

5.0 TRAINING

This sec�on establishes the training procedures required for understanding fire ex�nguishers, their proper use, and incipient-stage firefigh�ng. Training is required prior to ini�al assignment and on an annual basis thereina�er

Even Numbered Years

A member of the local fire department will conduct training, which will include hands on use of a fire ex�nguisher in a “live fire” situa�on.

Odd Numbered Years

The safety manager will conduct training involving a demonstra�on of the use of a fire ex�nguisher, without the actual discharge of the unit. New employees will undergo the odd-numbered-year training upon hire.

Ini�al Training Outline

• General fire principles and fire ex�nguishers

• Hazards of fires in the beginning stages

• When to evacuate the area of a fire

• Hazards of fire ex�nguisher use

• Proper use of a fire ex�nguisher

Retraining

• Establishes employee proficiency and provides updated informa�on on control procedures.

• Is provided for all authorized and affected employees on an annual basis, in the event of a change in job assignment, when knowledge of policies is found to be insufficient.

• When the Company determines that there have been devia�ons from established policies

Training Documenta�on

All training will be documented with the results of each employee’s performance on a hands-on test, Documenta�on shall include the employee’s name, trainer’s name, an outline of the training provided, and date of the training.

FIRST AID

1.0 PURPOSE

The program outlined in this document has been implemented to ensure that IT Landes, hereina�er referred to as “the Company,” employees understand what adequate amounts of first-aid equipment are and supplies are available for employees and to put in place proper procedures for situa�ons requiring first aid.

2.0 SCOPE

This program specifically applies to all of employees regardless of where they are performing work unless otherwise no�fied by the safety manager and documented on the site-specific plan.

3.0 RESPONSIBILITIES

Safety Manager

• Implement and ensure the requirements of this program are followed at all �mes.

• Work in conjunc�on with the Red Cross or other applicable en��es to ensure employees are up to date on applicable training requirements

• Keep all records pertaining to this program in order and current.

Supervisors

• Ensure that first-aid kits are made available and adequately stocked for each worksite.

• Ensure that provisions for prompt medical aten�on, including transporta�on in case of a serious injury, are in place before a project begins

• Provide adequate first-aid supplies and equipment within easy reach when required.

• Ensure that access to emergency and medical phone numbers is available in a conspicuous place to all employees.

Employees

• Follow the requirements of this program where applicable

• Use first-aid supplies and equipment responsibly.

• Immediately no�fy the supervisor of any low first-aid kit supplies.

• Know the loca�on of emergency telephone numbers

4.0 REQUIREMENTS

First-Aid Supplies and Equipment

First-aid supplies and equipment must be available and easily accessible to employees at all �mes. First-aid kits will contain all appropriate items determined to be adequate for the environment in which they will be used. First-aid kits will be assessed periodically to ensure adequate amounts of first-aid supplies are always available. Inadequate first-aid kits must be reported to an immediate supervisor who will then have the kits restocked with adequate supplies prior to the start of the work shi�.

The site supervisor shall perform an inspec�on of the first-aid supplies on a weekly basis. Kits shall be replenished as needed by the site supervisor.

A safety shower, eye wash, and/or other suitable facili�es for quick drenching or flushing shall be provided within the work area of any facility where the eyes or body of any person may be exposed to injurious corrosive materials. Ensure expira�on dates are checked for safety reasons and that the water used in storage devices is sani�zed.

An assessment of the material or materials used shall be performed to determine the type of flushing/drenching equipment will be required at the jobsite. Portable or temporary sta�ons must be set up prior to the use of corrosive materials on all client jobsites.

Medical Response

All minor first aid is to be self-rendered. Because of the risks associated with certain blood-borne pathogens, no one is allowed to tend the minor injuries of another person.

A person who has a valid cer�ficate in first aid shall be available to render first aid, in the absence of an infirmary, clinic, hospital, or physician that is reasonably accessible in terms of �me and distance to the worksite. It is mandatory that a valid cer�ficate in first-aid training must be obtained from the U.S. Bureau of Mines, American Red Cross, or an equivalent training authority which can be verified by documentary evidence.

Universal precau�ons must always be observed when first aid is rendered by authorized employees with the proper training. Universal precau�ons means that the aid giver treats all bodily fluids as if they were contaminated

If 911 is not available refer to the list of posted phone numbers for prearranged medical response providers. All authorized first responders of the Company should have a cell phone as a means of communica�ons; otherwise, handheld radios or telephones shall be used as a means of communica�on.

Transporta�on

Based on the first responders’ assessment of the injuries involved, decide what type of treatment will be performed and the loca�on of the treatment (emergency room, occupa�onal medicine provider, or on-site first aid).

Examples of serious injuries requiring transport to a medical provider are those resul�ng in severe blood loss, possible permanent disfigurement, head trauma, spinal injuries, internal injuries, and loss of consciousness. Keep in mind that the needs and well-being of the injured are the first priority.

Proper equipment for prompt transporta�on of the injured person to a physician or hospital or a communica�on system for contac�ng necessary ambulance service should be available at all �mes.

Choices to consider for proper transport include private automobile, Company vehicle, helicopter, crew boat, EMS vehicles including medi-vac helicopters, or any other transporta�on that can provide safe transporta�on to the hospital or doctor’s office in order to provide medical aten�on to the injured in the quickest manner without the injured employee incurring any addi�onal complica�ons or injuries.

Transporta�on needs must be pre-planned and coordinated with the transporta�on provider prior to an incident requiring such service.

5.0 TRAINING

Volunteers or selected employees are trained by the American Red Cross or equivalent in first aid and CPR. Each of these trained and cer�fied employees are equipped with protec�ve gloves and other required paraphernalia. CPR training must be recer�fied annually and first-aid training must be recer�fied every three years.

1.0 PURPOSE

The purpose of this policy is to establish procedures for IT Landes, hereina�er referred to as “the Company,” to assess fitness for duty of personnel under certain specified circumstances or upon release to return to work following a serious injury or illness.

2.0 SCOPE

This policy applies to all Company opera�ons and affiliated en��es.

3.0 POLICY

If an individual is perceived to be mentally or physically unfit to perform one or more of the essen�al func�ons of their job, each person and/or their supervisor must follow all appropriate sec�ons of this policy. Addi�onally, all personnel must follow the guidelines set forth in this policy in order to return to work from personal injury or a serious health condi�on, whether work-related or not.

4.0 RESPONSIBILITIES

It is the responsibility of each individual, their supervisor, and the EHS director to follow all applicable procedures set forth in this policy. Each individual is ul�mately responsible to be fit for duty. Any supervisor who becomes aware that an individual may be unfit for duty may rely on this policy to ensure that the person in ques�on is removed from their work assignment or prevented from returning to their work assignment un�l such �me that the individual’s fit-for-duty status can be verified under the terms of this policy. The EHS director will be responsible for managing compliance of personnel with all terms outlined in this policy.

Employees must receive training specific to their assigned task (e.g., welding, instrumenta�on, scaffold building, equipment operator qualifica�ons, respirator fit test, etc.).

5.0 PROCEDURE

Procedures must include drug and alcohol tes�ng as prescribed the Company, DOT, or host facili�es.

Employment with the Company is con�ngent on passing a post-hire/pre-placement physical/medical evalua�on.

Safe work procedures must be in place. Examples might include hot work permi�ng, confined space, LOTO, PSM, electrical safety, operator safety, etc.

Self-Report

For the safety and well-being of personnel and coworkers, individuals are not to report to work if they are seriously ill or impaired from drugs, alcohol, fa�gue, or any other reason, especially in cases of communicable diseases. Individuals with mental or physical condi�ons that may prevent them from performing an essen�al job func�on in an effec�ve and/or safe manner should not report for work un�l such �me as they are cleared by the EHS Department and/or personal physician. It is also the responsibility of the employee to no�fy their supervisor if they are fa�gued to the point of not being able to perform their du�es safely.

Personal Illness

Personnel are not to report for duty if they are seriously ill or impaired, especially if the illness is a communicable disease.

Medica�ons

Personnel must report the use of any prescribed or over-the-counter medica�on that may poten�ally impair their mental or physical abili�es to perform the func�ons of their job safely and effec�vely. Such no�ce must be provided to the EHS Department, who will work with the individual’s prescribing physician to evaluate whether the medica�on affects the individual’s ability to safely perform any essen�al job func�on.

Personnel who report for duty or are on duty while knowingly impaired may face disciplinary ac�ons up to and including termina�on. For guidelines, personnel should refer to the substance abuse policy.

On-The-Job and Off-The-Job Illness and Injury

All standards and defini�ons for fit-for-duty evalua�ons and assessments are the same regardless of whether the injury or illness occurred on or off the job.

For all on-the-job injuries, illnesses, or exposures, personnel will follow the accident and incident repor�ng procedures, filling out all appropriate forms and making all appropriate no�fica�ons.

For off-the-job injuries or illnesses, personnel will make the no�fica�on to their supervisor and the EHS Department.

Personnel with an on-the-job or off-the-job injury or illness will be subject to a fit-for-duty evalua�on and fitness assessment as listed below.

Observa�on and Repor�ng

Any individual observed to be mentally or physically impaired and/or who may be unable to perform one or more essen�al func�ons of their job effec�vely and safely may be subject to a fit-for-duty evalua�on by the EHS Department or a qualified designee or may be subject to tes�ng in accordance with the substance abuse policy. Signs of inability to perform may include apparent weakness, illness, disorienta�on, memory loss, erra�c behavior, or inability to successfully complete any individual performance standard associated with their posi�on or a fitness assessment.

Employees are responsible for ensuring they are physically and mentally fit to perform their job func�ons safely. Employees must take responsibility for their own safety as well as not repor�ng to work in a condi�on as to endanger the safety of their fellow workers.

Repor�ng Process

Personnel who observe or who have reason to believe that another individual may be unfit to perform the func�ons of the job effec�vely and/or safely will report such observa�ons to their immediate supervisor. The immediate supervisor of the individual in ques�on should contact the EHS Department, who will make the necessary arrangements to assess the individual’s condi�on. If the supervisor believes that the condi�on could affect the safety of the individual or others, the supervisor will immediately take the individual off duty. In cases where the individual in ques�on is one of the immediate supervisors, personnel should contact the EHS Department directly.

The EHS director is given the discre�on to assess appropriate ac�on to be taken with regard to the individual, which may result in removal of the individual from duty un�l such �me that a fit-for-duty medical evalua�on is completed.

In cases where the individual is removed from duty or needs to be referred for a medical evalua�on or treatment, the EHS Department must no�fy the Human Resources Department.

Referral for Medical Evalua�on

The following reasons may require a medical evalua�on to be performed:

• Post-hire and pre-placement

• When actual problems exist or are reported with the individual’s performance or any essen�al func�on of their job

• When legi�mate concerns exist about whether the individual or their performance poses a direct threat to the health and safety of themselves or others

• To determine the necessity for, or existence of, a reasonable accommoda�on

• When medical evalua�on, screening and monitoring is required by local, state, or federal law

If the individual requires addi�onal treatment for health issues not rela�ng to work, the individual will be responsible for those costs.

Medical Evalua�on to Return to Work

Any individual returning to work from a serious injury or illness, extended absence, or from any other health-related circumstance that may call to ques�on their ability to perform their du�es in a safe and effec�ve manner will need to provide documenta�on that they are able to return to work.

Employees returning to work form a serious injury or illness, extended absence, or from any other health-related circumstance will have to be retrained and/or field verifica�on on all applicable safety-related items.

All safety procedures must be followed. The items above were developed to ensure there is no gap in safety compliance a�er a long �me away from work.

The statement may need to directly reference the employee’s job func�on if their normal job requires job func�ons that are considered safety sensi�ve.

The Company reserves the right to require the individual to see another doctor for a second opinion as needed.

Whenever possible, the Company will meet the restric�ons for work-related injuries. The Company may not accept work restric�ons for individuals who were injured outside of their employment.

FORKLIFTS AND POWERED INDUSTRIAL TRUCKS

1.0 PURPOSE

The purpose of this document is to outline safety policy and procedures surrounding the use of forkli�s and industrial trucks for IT Landes, hereina�er referred to as “the Company.”

The Company and its employees may not operate forkli�s or industrial trucks at every jobsite, however, all employees who work on or around forkli� equipment, whether as the primary contractor or as a subcontractor on any worksite, shall adhere to the following health and safety policy and procedure. This program applies to all powered industrial trucks (PITs), hoists, and li�ing gear.

2.0 RESPONSIBILITIES

Management

• Provide adequate training in safe opera�on of all equipment used to move or access materials.

• Provide equipment that is safe to operate

• Implement an “out of service” program for damaged equipment

• Do not allow modifica�on to equipment except those authorized in wri�ng by the equipment manufacturer.

• Establish safe opera�ng rules and procedures.

Supervisors

• Monitor safe opera�ons of material handling equipment.

• Ensure all equipment is safety checked daily.

• Tag any damaged equipment “out of service ” Employees

• Only operate the equipment for which they have been specifically trained and authorized.

• Conduct required daily pre-use inspec�ons.

• Report any equipment damage of missing safety gear

• Follow all safety rules and opera�ng procedures

3.0 POLICY

4.0 HAZARDS

• Falling loads

• Overloading of equipment

• Impact with equipment

• Piercing of containers

• Loading dock roll off

• Chemical contact (batery acid)

• Fires during refueling

5.0 HAZARD CONTROLS

• Control of equipment keys

• Authorized fueling and recharge areas

• Proper palle�zing of material

• Marked travel lanes

• Equipment warning lights

• Seat belts

• Mounted fire ex�nguishers

6.0 PRE-QUALIFICATION

All candidates for PIT operators must meet the following basic requirements prior to star�ng ini�al or annual refresher training:

• No adverse vision problems that cannot be corrected by glasses or contacts.

• No adverse hearing loss that cannot be corrected with hearing aids

• No physical impairments that would impair safe opera�on of the PIT

• No neurological disorders that affect balance or consciousness.

• Not taking any medica�on that affects percep�on, vision, or physical abili�es.

7.0 TRAINING

Training for PIT operators shall be conducted by an experienced operator selected by management. All opera�onal training shall be conducted under close supervision. All training and evalua�on must be completed before an operator is permited to use a PIT without con�nual and close supervision.

All employees are required to be trained and cer�fied prior to opera�ng each specific type of equipment. Formal instruc�on includes lecture, discussion, interac�ve computer learning, videos, and writen materials Prac�cal training involves instructor demonstra�ons and trainee exercises. Cri�ques are required on the operator evalua�on.

Trainees may operate a PIT only under the direct supervision of persons, selected by management, who have the knowledge, training, and experience to train operators and evaluate their competence; and where such opera�on does not endanger the trainee or other employees.

Training Content

Training consists of a combina�on of formal instruc�on, prac�cal training (demonstra�ons performed by the trainer and prac�cal exercises performed by the trainee), and evalua�on of the operator’s performance in the workplace.

All trainers must have the knowledge and ability to teach and evaluate operators.

Ini�al Training

• Opera�ng instruc�ons, warnings, and precau�ons for the types of truck the operator will be authorized to operate

• Differences between the truck and the automobile

• Truck controls and instrumenta�on (where they are located, what they do, and how they work)

• Engine or motor opera�on

• Steering and maneuvering

• Visibility (including restric�ons due to loading)

• Fork and atachment adapta�on, opera�on, and use limita�ons

• Vehicle capacity

• Vehicle stability

• Any vehicle inspec�on and maintenance that the operator will be required to perform

• Refueling and/or charging and recharging of bateries

• Opera�ng limita�ons

• Any other opera�ng instruc�ons, warnings, or precau�ons listed in the operator’s manual for the types of vehicles that the employee is being trained to operate

Workplace Topics

• Surface condi�ons where the vehicle will be operated

• Composi�on of loads to be carried and load stability

• Load manipula�on, stacking, and unstacking

• Pedestrian traffic in areas where the vehicle will be operated

• Narrow aisles and other restricted places where the vehicle will be operated

• Hazardous (classified) loca�ons where the vehicle will be operated

• Ramps and other sloped surfaces that could affect the vehicle’s stability

• Closed environments and other areas where insufficient ven�la�on or poor vehicle maintenance could cause a buildup of carbon monoxide or diesel exhaust

• Other unique or poten�ally hazardous environmental condi�ons in the workplace that could affect safe opera�on

Refresher Training and Evalua�on

Refresher training, including an evalua�on of the effec�veness of that training, shall be conducted to ensure that the operator has the knowledge and skills needed to operate the PIT safely.

Mandatory refresher training shall be provided when unsafe opera�ons are observed, a�er an accident, if opera�on of a different vehicle type and or changes in condi�ons occur.

Refresher training in relevant topics shall be provided to the operator when:

• The operator has been observed to operate the vehicle in an unsafe manner

• The operator has been involved in an accident or near-miss incident.

• The operator has received an evalua�on that reveals that the operator is not opera�ng the truck safely.

• The operator is assigned to drive a different type of truck

• A condi�on in the workplace changes in a manner that could affect safe opera�on of the truck.

• Once every three years an evalua�on will be conducted of each PIT operator’s performance.

8.0 SAFE OPERATION PROCEDURES AND RULES

• Only trained and authorized personnel will operate PITs.

• All PITs will be equipped with a headache rack, fire ex�nguisher, rota�ng beacon, backup alarm, and seat belts. Seat belts will be worn at all �mes.

• The operator will perform daily pre-trip and post-trip inspec�ons

• Any safety defects (e.g., hydraulic fluid leaks; defec�ve brakes, steering, lights, or horn; and/or missing fire ex�nguishers, lights, seat belts, or backup alarms) will be reported for immediate repair or the PIT will be taken “out of service.”

• The operator will follow the proper recharging and refueling safety procedures.

• Loads will be �lted back and carried no more than 6 inches from the ground. Loads that restrict the

• operator’s vision will be transported backwards.

• PITs will travel no faster than 5 miles per hour or faster than a normal walk.

• Hardhats will be worn by PIT operators in high-li� areas.

• The operator will sound horn and use extreme cau�on when mee�ng pedestrians, making turns, and cornering.

• Passengers may not ride on any por�on of a PIT. Only operators will ride in PITs. “NO PASSENGERS” decals will be affixed on all PITs.

• If a PIT is used as a manli�, an appropriate manli� pla�orm (cage with standard rails and toe boards) will be used.

• The aisle will be maintained, free from obstruc�ons, marked, and wide enough (6-foot minimum) for vehicle opera�on.

• Li� capacity will be marked on all PITs. The operator will ensure load does not exceed rated weight limits.

• PITs will be turned off, forks lowered to the ground, and parking brake applied when unatended

• All PITs (with the excep�on of pallet jacks) will be equipped with a mul�-purpose dry chemical fire ex�nguisher (minimum ra�ng 2A:10B:C).

• Operators are instructed to report all accidents, regardless of fault and severity, to management. Management will conduct an accident inves�ga�on.

• Dock plates will be used wen loading railroad cars and trailers. Operators will ensure dock plates are in good condi�on and will store on edge when not in use.

• Railroad cars and trailers will be parked squarely to the loading area and have wheels chocked in place. Operators will follow established docking/undocking procedures.

9.0 CHANGING AND CHARGING STORAGE BATTERIES

• Batery charging installa�ons shall be located in areas designated for that purpose.

• Facili�es shall be provided for flushing and neutralizing spilled electrolyte, for fire protec�on, for protec�ng charging apparatus from damage by trucks, and for adequate ven�la�on for dispersal of fumes from gassing bateries.

• A conveyor, overhead hoist, or equivalent material handling equipment shall be provided for handling bateries.

• Reinstalled bateries shall be properly posi�oned and secured in the truck.

• A carboy �lter or siphon shall be provided for handling electrolyte.

• When charging bateries, acid shall be poured into water; water shall not be poured into acid.

• Trucks shall be properly posi�oned, and the brake applied before atemp�ng to change or charge bateries.

• Care shall be taken to ensure that vent caps are func�oning. The batery (or compartment) cover(s) shall be opened to dissipate heat.

• Smoking is prohibited in the charging area.

• Precau�ons shall be taken to prevent open flames, sparks, or electric arcs in batery charging areas.

• Tools and other metallic objects shall be kept away from the top of uncovered bateries.

10.0 TRUCKS AND RAILROAD CARS

• The flooring of trucks, trailers, and railroad cars shall be checked for breaks and weakness before they are driven onto.

• The brakes of highway trucks shall be set, and wheel chocks placed under the rear wheels to prevent the trucks from rolling while they are boarded with PITs.

• Wheel stops or other recognized posi�ve protec�on shall be provided to prevent railroad cars from moving during loading or unloading opera�ons.

• Fixed jacks may be necessary to support a semitrailer and prevent upending during the loading or unloading when the trailer is not coupled to a tractor.

• Posi�ve protec�on shall be provided to prevent railroad cars from being moved while dock boards or bridge plates are in posi�on.

11.0 OPERATIONS

• If at any �me a PIT is found to be in need of repair, defec�ve, or in any way unsafe, the truck shall be taken out of service un�l it has been restored to safe opera�ng condi�on.

• Trucks shall not be driven up to anyone standing in front of a bench or other fixed object.

• No person shall be allowed to stand or pass under the elevated por�on of any truck, whether loaded or empty.

• Unauthorized personnel shall not be permited to ride on PITs.

• Arms and legs shall not be placed between the uprights of the mast or outside the running lines of the truck.

• When a PIT is le� unatended, load engaging means shall be fully lowered, controls shall be neutralized, power shall be shut off, and brakes set. Wheels shall be blocked if the truck is parked on an incline.

• A safe distance shall be maintained from the edge of ramps or pla�orms while on any elevated dock, or pla�orm or freight car. Trucks shall not be used for opening or closing freight doors.

• There shall be sufficient headroom under overhead installa�ons, lights, pipes, sprinkler system, etc.

• An overhead guard shall be used as protec�on against falling objects. It should be noted that an overhead guard is intended to offer protec�on from the impact of small packages, boxes, bagged material, etc., representa�ve of the job applica�on, but not to withstand the impact of a falling capacity load.

• A load backrest extension shall be used whenever necessary to minimize the possibility of the load or part of it from falling rearward.

• Trucks shall not be parked so as to block fire aisles, access to stairways, or fire equipment.

12.0 TRAVELING

• All traffic regula�ons shall be observed, including authorized speed limits. A safe distance shall be maintained approximately three truck lengths from the truck ahead, and the truck shall be kept under control at all �mes.

• The right of way shall be yielded to ambulances, fire trucks, or other vehicles in emergency situa�ons.

• Other trucks traveling in the same direc�on at intersec�ons, blind spots, or other dangerous loca�ons shall not be passed.

• The driver shall be required to slow down and sound the horn at cross aisles and other loca�ons where vision is obstructed. If the load being carried obstructs forward view, the driver shall be required to travel with the load trailing.

• Railroad tracks shall be crossed diagonally wherever possible. Parking closer than 8 feet from the center of railroad tracks is prohibited.

• The driver shall be required to look in the direc�on of and keep a clear view of the path of travel.

• Grades shall be ascended or descended slowly. When ascending or descending grades in excess of 10%, loaded trucks shall be driven with the load upgrade. On all grades the load and load engaging means shall be �lted back if applicable and raised only as far as necessary to clear the road surface.

• Under all travel condi�ons the truck shall be operated at a speed that will permit it to be brought to a stop in a safe manner.

• Stunt driving and horseplay shall not be permited.

• The driver shall be required to slow down for wet and slippery floors.

• Dock board or bridge plates shall be properly secured before they are driven over. Dock board or bridge plates shall be driven over carefully and slowly, and their rated capacity never exceeded.

• Running over loose objects on the roadway surface shall be avoided.

• While nego�a�ng turns, speed shall be reduced to a safe level by means of turning the hand steering wheel in a smooth, sweeping mo�on. Except when maneuvering at a very low speed, the hand steering wheel shall be turned at a moderate, even rate.

13.0 LOADING

• Only stable or safely arranged loads shall be handled. Cau�on shall be exercised when handling off-center loads which cannot be centered.

• Only loads within the rated capacity of the truck shall be handled.

• The long or high (including mul�ple-�ered) loads which may affect capacity shall be adjusted.

• Trucks equipped with atachments shall be operated as par�ally loaded trucks when not handling a load.

• A load engaging means shall be placed under the load as far as possible; the mast shall be carefully �lted backward to stabilize the load.

• Extreme care shall be used when �l�ng the load forward or backward, par�cularly when highly �ered. Til�ng forward with load engaging means elevated shall be prohibited except to pick up a load. An elevated load shall not be �lted forward except when the load is in a deposit posi�on over a rack or stack. When stacking or �ering, only enough backward �lt to stabilize the load shall be used.

14.0 FUELING SAFETY

• Fuel tanks shall not be filled while the engine is running. Spillage shall be avoided.

• Spillage of oil or fuel shall be carefully washed away or completely evaporated and the fuel tank cap replaced before restar�ng engine.

• No truck shall be operated with a leak in the fuel system un�l the leak has been corrected.

• Open flames shall not be used for checking electrolyte level in storage bateries or gasoline level in fuel tanks.

15.0 MAINTENANCE OF POWERED TRUCKS

• Any power-operated industrial truck not in safe opera�ng condi�on shall be removed from service. All repairs shall be made by authorized personnel.

• Those repairs to the fuel and igni�on systems of industrial trucks which involve fire hazards shall be conducted only in loca�ons designated for such repairs.

• Trucks in need of repairs to the electrical system shall have the batery disconnected prior to such repairs.

• All parts of any such industrial truck requiring replacement shall be replaced only by parts equivalent as to safety with those used in the original design.

• Industrial trucks shall not be altered so that the rela�ve posi�ons of the various parts are different from what they were when originally received from the manufacturer, nor shall they be altered either by the addi�on of extra parts not provided by the manufacturer or by the elimina�on of any parts. Addi�onal counterweigh�ng of fork trucks shall not be done unless approved by the truck manufacturer.

• Equipment shall be examined before being placed in service and shall not be placed in service if the examina�on shows any condi�on adversely affec�ng the safety of the vehicle. Such examina�on shall be made at least daily. Where industrial trucks are used on a round-the-clock basis, they shall be examined prior to use each shi�. Defects when found shall be immediately reported and corrected.

• When the temperature of any part of any truck is found to be in excess of its normal opera�ng temperature, thus crea�ng a hazardous condi�on, the vehicle shall be removed from service and not returned to service un�l the cause for such overhea�ng has been eliminated.

• Industrial trucks shall be kept in a clean condi�on, free of lint, excess oil, and grease. Non-combus�ble agents should be used for cleaning trucks. Low flash point (below 100°F) solvents shall not be used. High flash point (at or above 100°F) solvents may be used.

16.0 SAFE OPERATION PROCEDURES FOR REFILLING LPG TANK

• No smoking

• Move LPG PIT outside for refueling

• Turn off PIT

• LPG tanks will be removed in the following order:

o Shut off service valve

o Disconnect tank from hose

o Unbuckle and remove tank from bracket

• LPG tanks will be replaced in to following order:

o Place tank in bracket and re-buckle

o Reconnect hose to tank and �ghten firmly

o Open valve slowly and ensure proper seal

Federal law prohibits dispensing an improper fuel type into any vehicle or into a non-approved fuel container.

In Case of LPG Leaks or Tank Rupture

• Do not start or move the PIT.

• If fuel hose is leaking, Close valve immediately and place the PIT “out of service” un�l repaired.

• If tank ruptures, warn other, immediately leave the area (at least 50 feet) and no�fy management. Do not reenter the area un�l cleared by management.

Powered Industrial Truck Pre-Use Checklist

A check of the following items (as applicable) is to be conducted by the operator prior to use each shi�:

• Lights

• Horn

• Brakes

• Leaks

• Warning beacon

• Backup warning alarm

• Fire ex�nguisher

If any deficiencies are noted, the unit is to be placed “out of service” un�l the problem has been corrected.

Addi�onally, it is the operator’s responsibility to no�fy the immediate supervisor and fill out a maintenance request.

GENERAL SAFETY PROVISIONS

1.0 PURPOSE

The purpose of this policy is to outline general health and safety requirements for all employees performing work on behalf of IT Landes, hereina�er referred to as “the Company.”

2.0 RESPONSIBILITIES

Management

• Ensure adequate resources training are provided to all workers.

• Ensure all workers adhere to this policy at all �mes.

Personnel

• Adhere to this policy at all �mes

3.0 POLICY

The Company is commited to providing a safe and healthy environment for all personnel and ensures effec�ve implementa�on of general safety requirements through:

• Staff having access to policies and procedures rela�ng to field of work

• Provision of tailored training to persons with specific tasks

• Record of ac�vi�es, including training provided and undertaken, informa�on provided to clients and use of PPE

• Mechanisms for monitoring compliance

• A person who has a valid cer�ficate in first aid shall be available at the worksite to render first aid

4.0 HOUSEKEEPING

Worksite cleanliness, order and organiza�on are key components to a maintaining an accident-free work environment. To that end, The Company will ensure that a worksite is kept clean and free from materials or equipment that could cause workers to slip or trip.

Management and workers shall complete the following at each worksite regularly:

• Keep an eye out for tools and debris that seem out of place, or that are located in a place or posi�on that may result in harm to a person.

• Keep each work area free of sharp objects that may be on the ground in order to prevent injury from stepping on nails or other sharp items.

• Sweep work area and remove debris regularly.

• Keep chords and other items that may cause a trip out of the way of workers.

• Each employee must be instructed in the recogni�on and avoidance of unsafe condi�ons and the regula�ons applicable to their work environment to control or eliminate any hazards or other exposure to injury or illness

5.0 WORKER COMPETENCY

The Company will ensure that each worker is trained in the safe work prac�ces and health and safety topics that pertain to the job at hand.

If work is to be done that may endanger a worker, the employer must ensure that the work is done by a worker who is competent to do the work, or by a worker who is working under the direct supervision of a worker who is competent to do the work.

The Company will ensure that workers are trained in the safe opera�on of the equipment the worker is required to operate.

The Company will assign a competent person to perform frequent and regular inspec�ons of jobsites, materials, and equipment.

6.0 EQUIPMENT MAINTENANCE

The Company will ensure that all equipment used at each worksite:

• Is maintained in a condi�on that will not compromise the health or safety of workers using or transpor�ng it

• Will safely perform the func�on for which it is intended or was designed.

• Is of adequate strength for its purpose.

• Is free from obvious defects

Only qualified employees by training or experience shall operate equipment and machinery.

7.0 OPERATING EQUIPMENT

Only qualified employees by training or experience shall operate equipment and machinery.

8.0 TRAINING

Each employee must be instructed in the recogni�on and avoidance of unsafe condi�ons and the regula�ons applicable to their work environment to control or eliminate any hazards or other exposure to injury or illness.

GENERAL WASTE MANAGEMENT

1.0 PURPOSE

The purpose of this document is to outline the general waste management policy for IT Landes, hereina�er referred to as “the Company.” The goal of this policy is to ensure effec�ve management, movement, storage, and disposal of waste produced and to minimize harm to personnel while minimizing environmental impacts.

2.0 RESPONSIBILITIES

Safety Officer

• Obtain and review informa�on for each waste stream rela�ng to the relevant legisla�ve requirements and confirming validity with the relevant authori�es.

• Ensure that waste control documenta�on is completed and retained as per procedural/legisla�ve requirements.

• Plan, conduct, and report waste audits.

Management

• Ensure all direct reports follow this policy.

• Assist site directors in waste classifica�on.

3.0 POLICY

4.0 GENERAL

All types of wastes are to be put into designated bins a�er genera�on. Those are to be disposed to iden�fy bins for further handling.

• Biodegradable waste like paper, coton waste, wood will be kept in green bins which will be transferred to iden�fied area in scrap yard for further disposal.

• Non-biodegradable waste include plas�c, polythene, rubber, concrete debris, fire bricks, glass, and welding slugs are to be kept at blue bins and to be disposed to iden�fied place at scrap yard for further disposal.

• Welding slugs are to be collected and used for land filling.

• Oil contaminated wastes are to be collected in one red bin which will be transferred to iden�fied area in scrap yard for further disposal.

• Industrial hazardous wastes in liquid form (used lubricant and used coolant oils) are to be collected in empty oil drums and to be kept under shed and lock and key and the floor must be made of concrete with nonpermeable membrane below ground. The content must be labeled.

• The Company will es�mate the waste that will be generated prior to work being performed so that the need for containers and waste removal, if necessary, can be determined.

• Biomedical wastes are to be sent to Medical Centre for disposing by deep burial method.

5.0 DISPOSAL

• Biodegradable waste includes paper waste, wood waste, coton waste, and cardboard packets. These can be used for land filling or sold to vendor through auc�on.

• Non-biodegradable wastes include plas�c, polythene, rubber, concrete debris; glass cannot be used for landfill. These are to be sold through auc�on for recycling.

• Contaminated waste including oil/grease impregnated coton waste. These cannot be used for land filling and to be incinerated through authorized vendors.

• Metallic waste includes off-cuts of steel tubes, plates and turning and borings of tubes and bars, and also non-ferrous metallic scrap like aluminum, copper and bronze coming out of maintenance. These wastes are to be sold through auc�on.

• Waste materials should be properly stored and handled to minimize the poten�al for a spill or impact to the environment.

• During outdoor ac�vi�es, receptacles must be covered to prevent dispersion of waste materials and to control the poten�al for runoff.

The Company encourages the proper segrega�on of waste materials to ensure opportuni�es for reuse or recycling.

6.0 TRAINING

Employees shall be instructed on the proper disposal method for wastes. This will include general instruc�on on disposal of non-hazardous wastes, trash, or scrap materials. If wastes generated are classified as hazardous, employees shall be trained to ensure proper disposal.

HAND AND POWER TOOLS

1.0 PURPOSE

The purpose of this document is to outline safety policies and procedures surrounding the use of hand and power tools for IT Landes, hereina�er referred to as “the Company.” This program covers hand, electric, pneuma�c, powder-actuated, and hydraulic tool safety.

2.0 RESPONSIBILITIES

Management

• Provide correct tools for assigned tasks.

• Ensure tools are maintained and stored safely.

• Provide employee training

• Provide for equipment repair

Employees

• Follow proper tool safety guidelines.

• Report tool deficiencies and malfunc�ons

• Properly store tools when work is completed.

Administra�ve

• Tool sharpening program.

• Use of PPE

• Control of tool issue.

• Employee training.

• Controlled access to equipment and tool areas

3.0 POLICY

Employees who use hand and power tools and who are exposed to the hazards of falling, flying, abrasive and splashing objects, or exposed to harmful dusts, fumes, mists, vapors, or gases must be provided with the par�cular personal equipment necessary to protect them from the hazard.

All hazards involved in the use of tools can be prevented by following basic safety rules:

• Keep all tools in good condi�on with regular maintenance.

• Use the right tool for the job.

• All hand and power tools must be used under the manufacturer’s recommenda�ons and stored properly as to avoid damage.

• Examine each tool for damage before use.

• Operate according to the manufacturer’s instruc�ons.

• Provide and use the proper protec�ve equipment.

• Ensure all employees receive the proper training on any hand or power tools that may be u�lized.

Whether furnished by the Company or the employee, tools shall be maintained in safe condi�on. Any tool which is not in compliance shall be iden�fied as unsafe by tagging and or locking the controls to render the piece of equipment inoperable or the tool shall be physically removed from its place of opera�on.

4.0 HAND TOOLS

Hand tools are non-powered. They include anything from axes to wrenches. The greatest hazards posed by hand tools result from misuse and improper maintenance. Some examples:

• Using a screwdriver as a chisel may cause the �p of the screwdriver to break and fly, hi�ng the user or other employees.

• If a wooden handle on a tool such as a hammer or an axe is loose, splintered, or cracked, the head of the tool may fly off and strike the user or another worker.

• A wrench must not be used if its jaws are sprung because it might slip.

• Impact tools such as chisels, wedges, or dri� pins are unsafe if they have mushroomed heads. The heads might shater on impact, sending sharp fragments flying.

Employees using hand and power tools and exposed to the hazard of falling, flying, abrasive, and splashing objects, or exposed to harmful dust, fumes, mists vapors, or gases shall be provided with par�cular PPE necessary to protect them from the hazard.

Appropriate PPE (e.g., safety goggles, gloves, etc.) should be worn due to hazards that may be encountered while using portable hand and power tools.

Floors shall be kept as clean and dry as possible to prevent accidental slips with or around dangerous hand tools.

Around flammable substances, sparks produced by iron and steel hand tools can be a dangerous igni�on source. Where this hazard exists, spark-resistant tools made from brass, plas�c, aluminum, or wood will provide for safety.

5.0 POWER TOOL PRECAUTIONS

Power tools can be hazardous when improperly used. There are several types of power tools, based on the power source they use: electric, pneuma�c, powder-actuated, hydraulic, and liquid fuel.

The following general precau�ons should be observed by power tool users:

• Never carry a tool by the cord or hose.

• Never yank the cord or the hose to disconnect it from the receptacle.

• Keep cords and hoses away from heat, oil, and sharp edges.

• Disconnect tools when not in use, before servicing, and when changing accessories such as blades, bits, and cuters.

• Power tools should be inspected and included in a preventa�ve maintenance program.

• All observers should be kept at a safe distance away from the work area.

• Secure work with clamps or a vise, freeing both hands to operate the tool.

• Avoid accidental star�ng. The worker should not hold a finger on the switch buton while carrying a pluggedin tool.

• Tools should be maintained with care. They should be kept sharp and clean for the best performance. Follow instruc�ons in the user’s manual for lubrica�ng and changing accessories.

• Be sure to keep good foo�ng and maintain good balance.

• Some electric power tools may require a hot work plan.

• The proper apparel should be worn. Loose clothing, �es, or jewelry can become caught in moving parts.

• All portable electric tools that are damaged shall be removed from use and tagged “do not use.”

6.0 GUARDS

Hazardous moving parts of a power tool need to be safeguarded. For example, belts, gears, sha�s, pulleys, sprockets, spindles, drums, fly wheels, chains, or other reciproca�ng, rota�ng, or moving parts of equipment must be guarded.

Guards, as necessary, should be provided to protect the operator and others from the following:

• Point of opera�on

• In-running nip points

• Rota�ng parts

• Flying chips and sparks

Guards shall be in place and operable at all �mes while the tool is in use. The guard may not be manipulated in such way that will compromise its integrity or compromise the protec�on in which intended. Guarding shall meet the requirements set forth in ANSI B15.1.

Safety guards must never be removed when a tool is being used. For example, portable circular saws must be equipped with guards. An upper guard must cover the en�re blade of the saw. A retractable lower guard must cover the teeth of the saw, except when it makes contact with the work material. The lower guard must automa�cally return to the covering posi�on when the tool is withdrawn from the work.

7.0 SAFETY SWITCHES

The following hand-held powered tools are to be equipped with a momentary contact “on-off” control switch: drills, tappers, fastener drivers, horizontal, ver�cal and angle grinders with wheels larger than 2 inches in diameter, disc and belt sanders, reciproca�ng saws, saber saws, and other similar tools. These tools also may be equipped with a lock-on control provided that turnoff can be accomplished by a single mo�on of the same finger or fingers that turn it on.

The following hand-held powered tools may be equipped with only a posi�ve “on-off” control switch: platen sanders, disc sanders with discs 2 inches or less in diameter; grinders with wheels 2 inches or less in diameter; routers, planers, laminate trimmers, nibblers, shears, scroll saws and jigsaws with blade shanks 0.25-inch wide or less.

Other hand-held powered tools, such as circular saws having a blade diameter greater than 2 inches, chain saws, and percussion tools without posi�ve accessory holding means, must be equipped with a constant pressure switch that will shut off the power when the pressure is released.

8.0 ELECTRICAL SAFETY

Among the chief hazards of electric-powered tools are burns and slight shocks which can lead to injuries or even heart failure. Under certain condi�ons, even a small amount of current can result in severe injury and eventual death. A shock also can cause the user to fall off a ladder or other elevated work surface.

To protect the user from shock, tools must either have a three-wire cord with ground or be grounded, be double insulated, or be powered by a low-voltage isola�on transformer. Three-wire cords contain two current-carrying conductors and a grounding conductor. One end of the grounding conductor connects to the tool’s metal housing. The other end is grounded through a prong on the plug. Any�me an adapter is used to accommodate a two-hole receptacle, the adapter wire must be atached to a known ground. The third prong should never be removed from the plug.

Double insula�on is more convenient. The user and the tools are protected by normal insula�on on the wires inside or a housing that cannot conduct electricity to the operator in the event of a malfunc�on.

Electric Power Tool General Safety Prac�ces

• Electric tools should be operated within their design limita�ons.

• Gloves and safety footwear are recommended during use of electric tools.

• When not in use, tools should be stored in a dry place.

• Electric tools should not be used in damp or wet loca�ons.

• Work areas should be well lighted.

9.0 POWER ABRASIVE WHEEL TOOLS

Powered abrasive grinding, cu�ng, polishing, and wire buffing wheels create special safety problems because they may throw off flying fragments.

Before an abrasive wheel is mounted, it should be inspected closely and sound or ring-tested to be sure that it is free from cracks or defects. To test, wheels should be tapped gently with a light non-metallic instrument. If they sound cracked or dead, they could fly apart in opera�on and so must not be used. A sound and undamaged wheel will give a clear metallic tone or “ring.”

To prevent the wheel from cracking, the user should be sure it fits freely on the spindle. The spindle nut must be �ghtened enough to hold the wheel in place, without distor�ng the flange. Follow the manufacturer’s recommenda�ons. Care must be taken to ensure that the spindle wheel will not exceed the abrasive wheel specifica�ons.

Due to the possibility of a wheel disintegra�ng (exploding) during start-up, the employee should never stand directly in front of the wheel as it accelerates to full opera�ng speed.

Portable grinding tools need to be equipped with safety guards to protect workers not only from the moving wheel surface, but also from flying fragments in case of breakage.

Powered Grinder Safety Precau�ons

• Always use eye protec�on.

• Turn off the power when not in use.

• Never clamp a hand-held grinder in a vise.

10.0 PNEUMATIC TOOLS

Pneuma�c tools are powered by compressed air and include chippers, drills, hammers, and sanders. There are several dangers encountered in the use of pneuma�c tools. The main one is the danger of ge�ng hit by one of the tool’s atachments or by some kind of fastener the worker is using with the tool. Eye protec�on is required, and face protec�on is recommended for employees working with pneuma�c tools. Working with noisy tools such as jackhammers requires proper, effec�ve use of hearing protec�on.

When using pneuma�c tools, employees are to check to see that they are fastened securely to the hose to prevent them from becoming disconnected. A short wire or posi�ve locking device ataching the air hose to the tool will serve as an added safeguard.

A safety clip or retainer must be installed to prevent atachments, such as chisels on a chipping hammer, from being uninten�onally shot from the barrel.

Screens must be set up to protect nearby workers from being struck by flying fragments around chippers, rive�ng guns, staplers, or air drills.

Compressed air guns should never be pointed toward anyone. Users should never “dead-end” it against themselves or anyone else.

11.0 POWDER-ACTUATED TOOLS

Powder-actuated tools operate like a loaded gun and should be treated with the same respect and precau�ons. In fact, they are so dangerous that they must be operated only by specially trained employees.

Powder-Actuated Tool Safety

• These tools should not be used in an explosive or flammable atmosphere.

• Before using the tool, the worker should inspect it to determine that it is clean, that all moving parts operate freely, and that the barrel is free from obstruc�ons.

• The tool should never be pointed at anybody.

• The tool should not be loaded unless it is to be used immediately. A loaded tool should not be le� unatended, especially where it would be available to unauthorized persons.

• Hands should be kept clear of the barrel end. To prevent the tool from firing accidentally, two separate mo�ons are required for firing: one to bring the tool into posi�on, and another to pull the trigger. The tools must not be able to operate un�l they are pressed against the work surface with a force of at least 5 pounds greater than the total weight of the tool.

If a powder-actuated tool misfires, the employee should wait at least 30 seconds, then try firing it again. If it s�ll will not fire, the user should wait another 30 seconds so that the faulty cartridge is less likely to explode, than carefully remove the load. The bad cartridge should be put in water.

Suitable eye and face protec�on are essen�al when using a powder-actuated tool.

The muzzle end of the tool must have a protec�ve shield or guard centered perpendicularly on the barrel to confine any flying fragments or par�cles that might otherwise create a hazard when the tool is fired. The tool must be designed so that it will not fire unless it has this kind of safety device.

All powder-actuated tools must be designed for varying powder charges so that the user can select a powder level necessary to do the work without excessive force.

If the tool develops a defect during use it should be tagged and taken out of service immediately un�l it is properly repaired.

12.0 POWDER-ACTUATED TOOL FASTENERS

When using powder-actuated tools to apply fasteners, there are some precau�ons to consider. Fasteners must not be fired into material that would let them pass through to the other side. The fastener must not be driven into materials like brick or concrete any closer than 3 inches to an edge or corner. In steel, the fastener must not come any closer than 0.5 inch from a corner or edge. Fasteners must not be driven into very hard or britle materials which might chip or splater or make the fastener ricochet.

An alignment guide must be used when shoo�ng a fastener into an exis�ng hole. A fastener must not be driven into a spalled area caused by an unsa�sfactory fastening.

13.0 HYDRAULIC POWER TOOLS

The fluid used in hydraulic power tools must be an approved fire-resistant fluid and must retain its opera�ng characteris�cs at the most extreme temperatures to which it will be exposed. The manufacturer’s recommended safe opera�ng pressure for hoses, valves, pipes, filters, and other fi�ngs must not be exceeded.

14.0 JACKS

All jacks (lever, ratchet, screw, and hydraulic) must have a device that stops them from jacking up too high. Also, the manufacturer’s load limit must be permanently marked in a prominent place on the jack and should not be exceeded.

A jack should never be used to support a li�ed load. Once the load has been li�ed, it must immediately be blocked up. Use wooden blocking under the base if necessary to make the jack level and secure. If the li� surface is metal, place a 1-inch-thick hardwood block or equivalent between it and the metal jack head to reduce the danger of slippage.

To set up a jack, make certain of the following:

• The base rests on a firm level surface.

• The jack is correctly centered.

• The jack head bears against a level surface

• The li� force is applied evenly.

Proper maintenance of jacks is essen�al for safety. All jacks must be inspected before each use and lubricated regularly. If a jack is subjected to an abnormal load or shock, it should be thoroughly examined to ensure it has not been damaged.

Hydraulic jacks exposed to freezing temperatures must be filled with an adequate an�freeze liquid.

HAZARD COMMUNICATION/GHS

1.0 PURPOSE

The purpose of this document is to outline the hazard communica�on (HAZCOM) program for IT Landes, hereina�er referred to as “the Company.” It provides detailed safety guidelines and instruc�ons for receipt, use, and storage of chemicals at our facility by employees and contractors. Reference: OSHA 1910.1200.

2.0 RESPONSIBILITIES

Management

• Ensure compliance with this program.

• Conduct immediate correc�ve ac�on for deficiencies found in the program.

• Maintain an effec�ve HAZCOM training program

• Make this plan available to employees or their designated representa�ve

Shipping and Receiving Manager

• Ensure all received containers are properly labeled and that labels are not removed or defaced.

• Ensure all shipped containers are properly labeled

• Ensure shipping department employees are properly trained in spill response.

• Ensure received SDSs are properly distributed.

Purchasing Agent

• Obtain SDSs for chemicals purchased from retail sources from the manufacturer.

Safety Manager

• Maintain a chemical inventory of hazardous chemicals using the iden�ty that is referenced on the SDS and upda�ng that list regularly.

• Monitor the effec�veness of the program

• Conduct annual audit of the program

• Monitor employee training to ensure effec�veness.

• Keep management informed of necessary changes

• Ensure SDSs are available as required

• Monitor facility for proper use, storage, and labeling of chemicals.

• Ensure SDSs are available for emergency medical personnel when trea�ng exposed employees.

• Provide informa�on, as requested, concerning health effects and exposure symptoms listed on SDSs

Supervisors

• Comply with all specific requirements of the program.

• Provide specific chemical safety training for assigned employees.

• Ensure chemicals are properly used stored and labeled

• Ensure only the minimum amount necessary is kept at worksta�ons.

• Ensure SDSs are up to date and readily accessible to all employees on all shi�s.

Employees

• Comply with chemical safety requirements of this program.

• Report any problems with storage or use of chemicals

• Immediately report spills of suspected spills of chemicals

• Use only those chemicals for which they have been trained.

• Use chemicals only for specific assigned tasks in the proper manner.

Contractors

• Comply will all aspects of this program

• Coordinate informa�on with the safety manager.

• Ensure contractor employees are properly trained.

• No�fy the safety manager before bringing any chemicals into Company property or facili�es

• Monitor and ensure proper storage and use of chemicals by contractor employees.

3.0 POLICY

This program has been developed based on OSHA’s Hazard Communica�on Standard (HCS) and consists of the following elements:

• Iden�fica�on of hazardous materials

• Product warning labels

• SDSs

• Writen HAZCOM program

• Effec�ve employee training

Some chemicals are explosive, corrosive, flammable, or toxic. Other chemicals are rela�vely safe to use and store but may become dangerous when they interact with other substances. To avoid injury and/or property damage, persons who handle chemicals in any area of the Company must understand the hazardous proper�es of the chemicals.

Before using a specific chemical, safe handling methods and health hazards must always be reviewed. Supervisors are responsible for ensuring that the equipment needed to work safely with chemicals is accessible and maintained for all employees on all shi�s.

A list of the hazardous chemicals known to be present using an iden�ty that is referenced on the appropriate SDS shall be maintained and posted in a conspicuous area at each worksite.

SDSs shall be maintained and readily accessible in each work area. SDSs can be maintained at the primary worksite. However, they should be available in case of an emergency. SDS must be made available, upon request, to employees, their designated representa�ves, the assistant secretary, and the director.

A SDS must be obtained for each required chemical. In addi�on, SDSs are to be maintained in a readily accessible loca�on to employees.

4.0 EMPLOYEE TRAINING

Ini�al Orienta�on Training

All new employees shall receive ini�al safety orienta�on training or training if there is a change in exposure covering the elements of the HAZCOM and right to know program. This training will consist of general training covering:

• Loca�on and availability of the writen HAZCOM program

• Loca�on and availability of the list of chemicals used in the workplace

• Methods and observa�on used to detect the presence or release of a hazardous chemical in the workplace

• The specific physical and health hazard of all chemicals in the workplace

• Specific control measures for protec�on from physical or health hazards

• Explana�on of the chemical labeling system

• Loca�on and use of SDS

Employees shall be provided with effec�ve informa�on and training on hazardous chemicals in their work area at the �me of their ini�al assignment, and whenever a new physical or health hazard the employees have not previously been trained about is introduced into their work area. Informa�on and training may be designed to cover categories of hazards (e.g., flammability, carcinogenicity) or specific chemicals. Chemical-specific informa�on must always be available through labels and SDSs.

Job-Specific

Training

Employees will receive on the job training from their supervisor. This training will cover the proper use, inspec�on and storage of necessary PPE and chemical safety training for the specific chemicals they will be using or will be working around.

Annual Refresher Training

Annual HAZCOM refresher training will be conducted as part of the Company’s con�nuing safety training program.

Immediate On-The-Spot Training

This training will be conducted by supervisors for any employees that request addi�onal informa�on or exhibit a lack of understanding of the safety requirements.

5.0 NON-ROUTINE TASKS

Non-rou�ne tasks are defined as working on, near, or with unlabeled piping, unlabeled containers of an unknown substance, confined space entry where a hazardous substance may be present and/or a one-�me task using a hazardous substance differently than intended (e.g., using a solvent to remove stains from �le floors).

Steps for Non-Rou�ne Tasks

• Step 1: Hazard determina�on

• Step 2: Determine precau�ons.

• Step 3: Specific training and documenta�on.

• Step 4: Perform task

All non-rou�ne tasks will be evaluated by the department supervisor and Safety Department before the task commences, to determine all hazards present. This determina�on will be conducted with quan�ta�ve/qualita�ve analysis (air sampling, substance iden�fica�on/analysis, etc.) as applicable.

Once the hazard determina�on is made, the department supervisor and Safety Department will determine the necessary precau�ons needed to either remove the hazard, change to a non-hazard, or protect from the hazard (use of PPE) to safeguard the employees present. In addi�on, the department supervisor or Safety Department will provide specific safety training for employees present or affected and will document the training using the Chemical Safety Training Checklist which shall be marked “Non-Rou�ne Task Training.”

6.0 OFF-SITE USE OR TRANSPORTATION OF CHEMICALS

A SDS will be provided to employees for each chemical and each occurrence of use or transport away from the Company facili�es. All state and federal DOT regula�ons will be followed including use of cer�fied containers; labeling, marking, and securing of containers; and employee training.

7.0 GENERAL CHEMICAL SAFETY

Assume all chemicals are hazardous. The number of hazardous chemicals and the number of reac�ons between them is so large that prior knowledge of all poten�al hazards cannot be assumed. Use chemicals in as small quan��es as possible to minimize exposure and reduce possible harmful effects.

The following general safety rules shall be observed when working with chemicals:

• Read and understand the SDS

• Keep the work area clean and orderly.

• Use the necessary safety equipment.

• Store incompa�ble chemicals in separate areas.

• Subs�tute less toxic materials whenever possible.

• Limit the volume of vola�le or flammable material to the minimum needed for short opera�on periods.

• Provide means of containing the material if equipment or containers should break or spill their contents.

• Carefully label every container with the iden�ty of its contents and appropriate hazard warnings.

8.0 TASK EVALUATION

Each task that requires the use of chemicals should be evaluated to determine the poten�al hazards associated with the work. This hazard evalua�on must include the chemical or combina�on of chemicals that will be used in the work, as well as other materials that will be used near the work. If a malfunc�on during the opera�on has the poten�al to cause serious injury or property damage, a safe opera�onal procedure (SOP) should be prepared and followed. Opera�ons must be planned to minimize the genera�on of hazardous wastes.

9.0 CHEMICAL STORAGE

The separa�on of chemicals (solids or liquids) during storage is necessary to reduce the possibility of unwanted chemical reac�ons caused by accidental mixing. Explosives should be stored separately outdoors. Use either distance or barriers (e.g., trays) to isolate chemicals into the following groups:

• Flammable Liquids: Store in approved flammable storage lockers.

• Acids: Treat as flammable liquids.

• Bases: Do not store bases with acids or any other material.

• Other Liquids: Ensure other liquids are not incompa�ble with any other chemical in the same storage loca�on.

Lips, strips, or bars are to be installed across the width of storage shelves to restrain the chemicals in case of earthquake.

Chemicals will not be stored in the same refrigerator used for food storage. Refrigerators used for storing chemicals must be appropriately iden�fied by a label on the door.

10.0 CONTAINER LABELS

It is extremely important that all containers of chemicals are properly labeled. This includes every type of container from a 5,000-gallon storage tank to a spray botle of degreaser. The following requirements apply:

• All containers will have the appropriate label, tag, or marking prominently displayed that indicates the iden�ty, safety, and health hazards.

• Portable containers which contain a small amount of chemical need not be labeled if they are used immediately that shi� but must be under the strict control of the employee using the product.

• All warning labels, tags, etc., must be maintained in a legible condi�on and not be defaced. Facility weekly supervisor inspec�ons will check for compliance of this rule.

• Incoming chemicals are to be checked for proper labeling.

Each container label should contain the following informa�on:

• Pictograms

• Precau�onary statements

• Name, address, and phone number of the chemical manufacture

11.0 EMERGENCIES AND SPILLS

In case of an emergency, implement the proper emergency ac�on plan.

• Evacuate people from the area.

• Isolate the area.

• If the material is flammable, turn off igni�on and heat sources.

• Only personnel specifically trained in emergency response are permited to par�cipate in chemical emergency procedures beyond those required to evacuate the area.

• Call for emergency response team assistance if required.

12.0

HOUSEKEEPING

• Maintain the smallest possible inventory of chemicals to meet immediate needs.

• Periodically review stock of chemicals on hand.

• Ensure that storage areas and equipment containing large quan��es of chemicals are secure from accidental spills.

• Rinse emp�ed botles that contain acids or inflammable solvents before disposal.

• Recycle unused laboratory chemicals wherever possible.

• Do not place hazardous chemicals in salvage or garbage receptacles.

• Do not pour chemicals onto the ground.

• Do not dispose of chemicals through the storm drain system.

• Do not dispose of highly toxic, malodorous chemicals down sinks or sewer drains.

13.0 MULTI-EMPLOYER WORKSITES

Where employees must travel between workplaces throughout the course of business, the writen HAZCOM program will be available in the employee “pocket sized safety manual” that shall be kept in each work vehicle at all �mes.

All outside contractors working inside Company facili�es are required to follow the requirements of this program.

The Company will provide contractors informa�on concerning:

• Pre-job briefing shall be conducted with the contractor prior to the ini�a�on of work on the site

• Precau�ons to be taken to protect contractor employees

• Poten�al exposure to hazardous substances

• Chemicals used in or stored in areas where they will be working

• Loca�on and availability of SDSs

• Labeling system for chemicals

• Recommended PPE

A writen HAZCOM program shall be developed, implemented, and maintained at each workplace that describes how labels and other forms of warning, SDSs, and employee informa�on will be met.

14.0 SDS INFORMATION

SDSs are provided by the chemical manufacturer to provide addi�onal informa�on concerning safe use of the product. Each SDS provides:

• Common name and chemical name of the material

• Name, address, and phone number of the manufacturer

• Emergency phone numbers for immediate hazard informa�on

• Date the SDS was last updated

• Lis�ng of hazardous ingredients

• Chemical hazards of the material

• Informa�on for iden�fica�on of chemical and physical proper�es

15.0 INFORMATION CHEMICAL USERS MUST KNOW

Fire and/or Explosion Informa�on

• Material flash point, auto-igni�on temperature, and upper/lower flammability limits

• Proper fire ex�nguishing agents to be used

• Firefigh�ng techniques

• Any unusual fire or explosive hazards

Chemical Reac�on Informa�on

• Stability of chemical

• Condi�ons and other materials which can cause reac�ons with the chemical

• Dangerous substances that can be produced when the chemical reacts

Control Measures

• Engineering controls required for safe product use

• PPE required for use of product

• Safe storage requirements and guidelines

• Safe handling procedures

Health Hazards

• Permissible Exposure Limit (PEL) and Threshold Limit Value (TLV)

• Acute or chronic symptoms of exposure

• Main routes of entry into the body

• Medical condi�ons that can be made worse by exposure

• Cancer causing proper�es if any

• Emergency and first-aid treatments

Spill and Leak Procedures

• Clean up techniques

• PPE to be used during cleanup

• Disposal of waste and cleanup material

16.0 EMPLOYEE USE OF SDS

For SDS use to be effec�ve, employees must:

• Know the loca�on of the SDS

• Understand the major points for each chemical.

• Check the SDS when more informa�on is needed or when ques�ons arise.

• Be able to quickly locate the emergency informa�on on the SDS

• Follow the safety prac�ces provided on the SDS.

17.0 DEFINITIONS

Chemical: Any element, chemical compound, or mixture of elements and/or compounds.

Combus�ble Liquid: Any liquid having a flash point at or above 100°F, but below 20°F, except any mixture having components with flash points of 200°F, or higher, the total volume of which make up 99% or more of the total volume of the mixture.

Compressed Gas: Any compound that exhibits:

• A gas or mixture of gases having, in a container, an absolute pressure exceeding 40 psi at 70°F

• A gas or mixture of gases having, in a container, an absolute pressure exceeding 104 psi at 130°F regardless of the pressure at 70°F

• A liquid having a vapor pressure exceeding 40 psi at 10°F

Container: Any bag, barrel, botle, box, can, cylinder, drum, reac�on vessel, storage tank, or the like that contains a hazardous chemical. For purposes of this sec�on, pipes or piping systems, and engines, fuel tanks, or other opera�ng systems in a vehicle, are not considered to be containers.

Employee: A worker who may be exposed to hazardous chemicals under normal opera�ng condi�ons or in foreseeable emergencies. Workers such as office workers or bank tellers who encounter hazardous chemicals only in non-rou�ne, isolated instances are not covered.

Employer: A person engaged in a business where chemicals are either used, distributed, or are produced for use or distribu�on, including a contractor or subcontractor.

Explosive: A chemical that causes a sudden, almost instantaneous release of pressure, gas, and heat when subjected to sudden shock, pressure, or high temperature.

Exposure (Exposed): An employee is subjected in the course of employment to a chemical that is a physical or health hazard and includes poten�al (accidental or possible) exposure. Subjected in terms of health hazards includes any route of entry (inhala�on, inges�on, skin contact, or absorp�on).

Flammable: A chemical that falls into one of the following categories:

• “Aerosol, flammable” means an aerosol that yields a flame projec�on exceeding 18 inches at full valve opening, or a flashback (a flame extending back to the valve) at any degree of valve opening.

• “Gas, flammable” means a gas that, at ambient temperature and pressure, forms:

o A flammable mixture with air at a concentra�on of 13% by volume or less

o A range of flammable mixtures with air wider than 12% by volume, regardless of the lower limit

• “Liquid, flammable” means any liquid having a flash point below 100°F, except any mixture having components with flash points of 100°F or higher, the total of which make up 99% or more of the total volume of the mixture.

• “Solid, flammable” means a solid, other than a blas�ng agent or explosive as defined in 1910.109(a), that is liable to cause fire through fric�on, absorp�on of moisture, spontaneous chemical change, or retained heat from manufacturing or processing, or which can be ignited readily and when ignited burns so vigorously and persistently as to create a serious hazard

o A chemical shall be considered to be a flammable solid if it ignites and burns with a self-sustained flame at a rate greater than one-tenth of an inch per second along its major axis

Flash Point: The minimum temperature at which a liquid gives off a vapor in sufficient concentra�on to ignite.

Hazardous Chemical: Any chemical which is a physical hazard or a health hazard.

Hazard Warning: Any words, pictures, symbols, or combina�on appearing on a label or other appropriate form of warning which convey the specific health and physical hazard(s), including target organ effects, of the chemical(s) in the container(s).

Health Hazard: A chemical for which there is evidence that acute or chronic health effects may occur in exposed employees. This includes chemicals which are carcinogens, toxic or highly toxic agents, reproduc�ve toxins, irritants, corrosives, sensi�zers, hepatotoxins, nephrotoxins, neurotoxins, agents which act on the hematopoie�c system, and agents which damage the lungs, skin, eyes, or mucous membranes.

Iden�ty: Any chemical or common name which is indicated on the SDS for the chemical. The iden�ty used shall permit cross-references to be made among the required list of hazardous chemicals, the label, and the SDS.

Immediate Use: The hazardous chemical will be under the control of and used only by the person who transfers it from a labeled container and only within the work shi� in which it is transferred.

Label: Any writen, printed, or graphic material displayed on or affixed to containers of hazardous chemicals.

Mixture: Any combina�on of two or more chemicals if the combina�on is not, in whole or in part, the result of a chemical reac�on.

Oxidizer: A chemical other than a blas�ng agent or explosive as defined in 1910.109(a), that ini�ates or promotes combus�on in other materials, thereby causing fire either of itself or through the release of oxygen or other gases.

Physical Hazard: A chemical that is a combus�ble liquid, compressed gas, explosive, flammable, organic peroxide, oxidizer, pyrophoric, unstable (reac�ve), or water reac�ve.

Pyrophoric: A chemical that will ignite spontaneously in air at a temperature of 130°F or below.

Safety Data Sheet (SDS): Writen or printed material concerning a hazardous chemical which is prepared in accordance with OSHA 1910.1200 requirements.

Specific Chemical Iden�ty: The chemical name, Chemical Abstracts Service (CAS) registry number, or any other informa�on that reveals the precise chemical designa�on of the substance.

Unstable (Reac�ve): A chemical which in the pure state, or as produced or transported, will vigorously polymerize, decompose, condense, or will become self-reac�ve under condi�ons of shocks, pressure, or temperature.

Use: To package, handle, react, emit, extract, generate as a byproduct, or transfer.

Water-Reac�ve: A chemical that reacts with water to release a gas that is either flammable or presents a health hazard.

Work Area: A room or defined space in a workplace where hazardous chemicals are produced or used, and where employees are present.

Workplace: An establishment, jobsite, or project, at one geographical loca�on containing one or more work areas.

18.0 GLOBAL HARMONIZATION SYSTEM (GHS) Introduc�on

The GHS is an interna�onal approach to hazard communica�on, providing agreed criteria for classifica�on of chemical hazards, and a standardized approach to label elements and SDSs. The GHS was nego�ated in a mul�-year process by HAZCOM experts from many different countries, interna�onal organiza�ons, and stakeholder groups. It is based on major exis�ng systems around the world, including OSHA’s HCS and the chemical classifica�on and labeling systems of other U.S. agencies.

The result of this nego�a�on process is the United Na�ons’ document en�tled “Globally Harmonized System of Classifica�on and Labeling of Chemicals,” commonly referred to as the Purple Book. This document provides harmonized classifica�on criteria for health, physical, and environmental hazards of chemicals. It also includes standardized label elements that are assigned to these hazard classes and categories and provide the appropriate signal words, pictograms, and hazard and precau�onary statements to convey the hazards to users.

A standardized order of informa�on for SDSs is also provided. These recommenda�ons can be used by regulatory authori�es such as OSHA to establish mandatory requirements for hazard communica�on, but do not cons�tute a model regula�on.

Overview

The revised HCS is a modifica�on to the exis�ng standard. The parts of the standard that did not relate to the GHS, such as the basic framework, scope, and exemp�ons, remained largely unchanged. There have been some

modifica�ons to terminology in order to align the revised HCS with language used in the GHS. For example, the term “hazard determina�on” has been changed to “hazard classifica�on” and “material safety data sheet” was changed to “safety data sheet.” OSHA stakeholders commented on this approach and found it to be appropriate.

Under both the current and revised HCS, an evalua�on of chemical hazards must be performed considering the available scien�fic evidence concerning such hazards. Under the current HCS, the hazard determina�on provisions have defini�ons of hazard, and the evaluator determines whether or not the data on a chemical meet those defini�ons. It is a performance-oriented approach that provides parameters for the evalua�on, but not specific, detailed criteria. The hazard classifica�on approach in the revised HCS is quite different. The revised HCS has specific criteria for each health and physical hazard, along with detailed instruc�ons for hazard evalua�on and determina�ons as to whether mixtures or substances are covered. It also establishes both hazard classes and hazard categories for most of the effects; the classes are divided into categories that reflect the rela�ve severity of the effect. The current HCS does not include categories for most of the health hazards covered, so this new approach provides addi�onal informa�on that can be related to the appropriate response to address the hazard. OSHA has included the general provisions for hazard classifica�on in paragraph (D) of the revised rule and added extensive appendixes (A and B) that address the criteria for each health or physical effect.

Major Changes

The three major areas of change are in hazard classifica�on, labels, and SDSs.

Hazard Classification

The defini�ons of hazard have been changed to provide specific criteria for classifica�on of health and physical hazards, as well as classifica�on of mixtures. These specific criteria will help to ensure that evalua�ons of hazardous effects are consistent across manufacturers, and that labels and SDSs are more accurate as a result.

Labels

Chemical manufacturers and importers will be required to provide a label that includes a harmonized signal word, pictogram, and hazard statement for each hazard class and category. Precau�onary statements must also be provided.

SDSs

SDSs will now have a specified 16-sec�on format.

19.0

HCS SDSs

The informa�on required on the SDS will remain essen�ally the same as that in the current standard (HAZCOM 1994). HAZCOM 1994 indicates what informa�on has to be included on an SDS but does not specify a format for presenta�on or order of informa�on. The revised HCS (HAZCOM 2012) requires that the informa�on on the SDS be presented using specific headings in a specified sequence.

Paragraph (G) of the final rule provides the headings of informa�on to be included on the SDS and the order in which they are to be provided. In addi�on, Appendix D provides the informa�on to be included under each heading. The SDS format is the same as the ANSI standard format, which is widely used in the U.S. and is already familiar to many employees.

The format of the 16-sec�on SDS should include the following sec�ons:

• Sec�on 1: Iden�fica�on

• Sec�on 2: Hazard(s) Iden�fica�on

• Sec�on 3: Composi�on/Informa�on on Ingredients

• Sec�on 4: First-Aid Measures

• Sec�on 5: Firefigh�ng Measures

• Sec�on 6: Accidental Release Measures

• Sec�on 7: Handling and Storage

• Sec�on 8: Exposure Controls/Personal Protec�on

• Sec�on 9: Physical and Chemical Proper�es

• Sec�on 10: Stability and Reac�vity

• Sec�on 11: Toxicological Informa�on

• Sec�on 12: Ecological Informa�on

• Sec�on 13: Disposal Considera�ons

• Sec�on 14: Transport Informa�on

• Sec�on 15: Regulatory Informa�on

• Sec�on 16: Other Informa�on

The SDS must also contain sec�ons 12-15, to be consistent with the United Na�ons’ Globally Harmonized System of Classifica�on and Labeling of Chemicals. Although the headings for sec�ons 12-15 are mandatory, OSHA will not enforce the content of these 4 sec�ons because these sec�ons are within other agencies’ jurisdic�ons.

The HCS 29 CFR 1910.1200(g), revised in 2012, requires that the chemical manufacturer, distributor, or importer provide SDSs (formerly material safety data sheets or MSDSs) for each hazardous chemical to downstream users to communicate informa�on on these hazards. The informa�on contained in the SDS is largely the same as the former MSDS, except now the SDSs are required to be presented in a consistent user-friendly, 16-sec�on format. This brief provides guidance to help workers who handle hazardous chemicals to become familiar with the format and understand the contents of the SDSs.

The SDS includes informa�on such as the proper�es of each chemical; the physical, health, and environmental health hazards; protec�ve measures; and safety precau�ons for handling, storing, and transpor�ng the chemical. The informa�on contained in the SDS must be in English (although it may be in other languages as well). In addi�on, OSHA requires that SDS preparers provide specific minimum informa�on as detailed in Appendix D of 29 CFR 1910.1200.

The SDS preparers may also include addi�onal informa�on in various sec�ons.

Sec�ons 1-8 contain general informa�on about the chemical, iden�fica�on, hazards, composi�on, safe handling prac�ces, and emergency control measures (e.g., firefigh�ng). This informa�on should be helpful to those that need to get the informa�on quickly. Sec�ons 9-11 and 16 contain other technical and scien�fic informa�on, such as physical and chemical proper�es, stability and reac�vity informa�on, toxicological informa�on, exposure control informa�on, and other informa�on including the date of prepara�on or last revision. The SDS must also state that no applicable informa�on was found when the preparer does not find relevant informa�on for any required element.

The SDS must also contain sec�ons 12-15, to be consistent with the United Na�ons’ Globally Harmonized System of Classifica�on and Labeling of Chemicals, but OSHA will not enforce the content of these sec�ons because they concern maters handled by other agencies.

A descrip�on of all 16 sec�ons of the SDS, along with their contents, is presented here:

Section 1: Identification

This section identifies the chemical on the SDS as well as the recommended uses. It also provides the essential contact information of the supplier. The required information consists of:

• Product iden�fier used on the label and any other common names or synonyms by which the substance is known

• Name, address, phone number of the manufacturer, importer, or other responsible party, and emergency phone number

• Recommended use of the chemical (e.g., a brief descrip�on of what it actually does, such as flame retardant) and any restric�ons on use (including recommenda�ons given by the supplier)

Section 2: Hazard(s) Identification

This section identifies the hazards of the chemical presented on the SDS and the appropriate warning information associated with those hazards. The required information consists of:

• The hazard classifica�on of the chemical (e.g., flammable liquid, category 1)

• Signal word

• Hazard statement(s)

• Pictograms (the pictograms or hazard symbols may be presented as graphical reproduc�ons of the symbols in black and white or be a descrip�on of the name of the symbol (e.g., skull and crossbones, flame))

• Precau�onary statement(s)

• Descrip�on of any hazards not otherwise classified

• A statement describing how much (percentage) of the mixture consists of ingredient(s) with unknown acute toxicity for a mixture that contains an ingredient(s) with unknown toxicity (please note that this is a total percentage of the mixture and not �ed to the individual ingredient(s))

Section 3: Composition/Information on Ingredients

This section identifies the ingredient(s) contained in the product indicated on the SDS, including impurities and stabilizing additives. This section includes information on substances, mixtures, and all chemicals where a trade secret is claimed. The required information consists of:

• Substances

o Chemical name

o Common name and synonyms

o Chemical Abstracts Service (CAS) number and other unique iden�fiers

o Impuri�es and stabilizing addi�ves, which are themselves classified and which contribute to the classifica�on of the chemical

• Mixtures

o Same informa�on required for substances

o The chemical name and concentra�on (e.g., exact percentage) of all ingredients which are classified as health hazards and are:

 Present above their cut-off/concentra�on limits

 Present a health risk below the cut-off/concentra�on limits

o The concentra�on (exact percentages) of each ingredient must be specified except concentra�on ranges may be used in the following situa�ons:

 A trade secret claim is made

 There is batch-to-batch varia�on

 The SDS is used for a group of substan�ally similar mixtures

• Chemicals (where a trade secret is claimed)

o A statement that the specific chemical iden�ty and/or exact percentage (concentra�on) of composi�on has been withheld as a trade secret is required

Section 4: First-Aid Measures

This section describes the initial care that should be given by untrained responders to an individual who has been exposed to the chemical. The required information consists of:

• Necessary first-aid instruc�ons by relevant routes of exposure (inhala�on, skin and eye contact, and inges�on)

• Descrip�on of the most important symptoms or effects, and any symptoms that are acute or delayed

• Recommenda�ons for immediate medical care and special treatment needed, when necessary

Section 5: Firefighting Measures

This section provides recommendations for fighting a fire caused by the chemical. The required information consists of:

• Recommenda�ons of suitable ex�nguishing equipment, and informa�on about ex�nguishing equipment that is not appropriate for a par�cular situa�on

• Advice on specific hazards that develop from the chemical during the fire, such as any hazardous combus�on products created when the chemical burns

• Recommenda�ons on special protec�ve equipment or precau�ons for firefighters

Section 6: Accidental Release Measures

This section provides recommendations on the appropriate response to spills, leaks, or releases, including containment and cleanup practices to prevent or minimize exposure to people, properties, or the environment. It may also include recommendations distinguishing between responses for large and small spills where the spill volume has a significant impact on the hazard. The required information may consist of recommendations for:

• Use of personal precau�ons, such as removal of igni�on sources or providing sufficient ven�la�on, and protec�ve equipment to prevent the contamina�on of skin, eyes, and clothing

• Emergency procedures, including instruc�ons for evacua�ons, consul�ng experts when needed, and appropriate protec�ve clothing

• Methods and materials used for containment (e.g., covering the drains and capping procedures)

• Cleanup procedures (e.g., appropriate techniques for neutraliza�on, decontamina�on, cleaning, or vacuuming; adsorbent materials; and/or equipment required for containment and cleanup)

Section

7: Handling and Storage

This section provides guidance on the safe handling practices and conditions for safe storage of chemicals. The required information consists of:

• Precau�ons for safe handling, including recommenda�ons for handling incompa�ble chemicals, minimizing the release of the chemical into the environment, and providing advice on general hygiene prac�ces (e.g., ea�ng, drinking, and smoking in work areas is prohibited)

• Recommenda�ons on the condi�ons for safe storage, including any incompa�bili�es

• Providing advice on specific storage requirements (e.g., ven�la�on requirements)

Section 8: Exposure Controls/Personal Protection

This section indicates the exposure limits, engineering controls, and personal protective measures that can be used to minimize worker exposure. The required information consists of:

• OSHA PELs, American Conference of Governmental Industrial Hygienists (ACGIH) TLVs, and any other exposure limit used or recommended by the chemical manufacturer, importer, or employer preparing the SDS, where available

• Appropriate engineering controls (e.g., use local exhaust ven�la�on, use only in an enclosed system)

• Recommenda�ons for personal protec�ve measures to prevent injury or illness from exposure to chemicals, such as PPE (e.g., appropriate types of eye, face, skin, or respiratory protec�on needed based on hazards and poten�al exposure)

• Any special requirements for PPE, protec�ve clothing, or respirators (e.g., type of glove material, such as PVC or nitrile rubber gloves; breakthrough �me of the glove material)

Section 9: Physical and Chemical Properties

This section identifies physical and chemical properties associated with the substance or mixture. The minimum required information consists of:

• Appearance (physical state, color, etc.)

• Auto-igni�on temperature

• Decomposi�on temperature

• Evapora�on rate

• Flammability (solid, gas, etc.)

• Flash point

• Ini�al boiling point and boiling range

• Mel�ng point/freezing point

• Odor

• Odor threshold

• Par��on coefficient: n-octanol/water

• pH

• Rela�ve density

• Solubility(ies)

• Upper/lower flammability or explosive limits

• Vapor density

• Vapor pressure

• Viscosity

The SDS may not contain every item on the list above because information may not be relevant or available. When this occurs, a notation to that effect must be made for that chemical property. Manufacturers may also add other relevant properties, such as the dust deflagration index (Kst) for combustible dust, used to evaluate a dust’s explosive potential.

Section 10: Stability and Reactivity

This section describes the reactivity hazards of the chemical and the chemical stability information. This section is broken into three parts: reactivity, chemical stability, and other. The required information consists of:

• Reac�vity

o Descrip�on of the specific test data for the chemical(s), which can be for a class or family of the chemical if such data adequately represents the an�cipated hazard of the chemical(s), where available

• Chemical stability

o Indica�on of whether the chemical is stable or unstable under normal ambient temperature and condi�ons while in storage and being handled

o Descrip�on of any stabilizers that may be needed to maintain chemical stability

o Indica�on of any safety issues that may arise should the product change in physical appearance

• Other

o Indica�on of the possibility of hazardous reac�ons, including a statement whether the chemical will react or polymerize, which could release excess pressure or heat, or create other hazardous condi�ons.

o Descrip�on of the condi�ons under which hazardous reac�ons may occur

o List of all condi�ons that should be avoided (e.g., sta�c discharge, shock, vibra�ons, or environmental condi�ons that may lead to hazardous condi�ons)

o List of all classes of incompa�ble materials (e.g., classes of chemicals or specific substances) with which the chemical could react to produce a hazardous situa�on

o List of any known or an�cipated hazardous decomposi�on products that could be produced because of use, storage, or hea�ng

Section 11: Toxicological Information

This section identifies toxicological and health effects information or indicates that such data are not available. The required information consists of:

• Informa�on on the likely routes of exposure (e.g., inhala�on, inges�on, skin and eye contact) or indicate if the informa�on is unknown

• Descrip�on of the delayed, immediate, or chronic effects from short and long-term exposure

• The numerical measures of toxicity (e.g., acute toxicity es�mates such as the LD50 (median lethal dose)) the es�mated amount of a substance expected to kill 50% of test animals in a single dose

• Descrip�on of the symptoms, including the symptoms associated with the lowest to the most severe exposure to the chemical

• Indica�on of whether the chemical is listed in the Na�onal Toxicology Program Report on Carcinogens (latest edi�on), has been found to be a poten�al carcinogen in the Interna�onal Agency for Research on Cancer Monographs (latest edi�ons), or has been found to be a poten�al carcinogen by OSHA

Section 12: Ecological Information (Non-Mandatory)

This section provides information to evaluate the environmental impact of the chemical(s) if it were released to the environment. The information may include:

• Data from toxicity tests performed on aqua�c and/or terrestrial organisms, where available (e.g., acute or chronic aqua�c toxicity data for fish, algae, crustaceans, and other plants; toxicity data on birds, bees, plants)

• Whether there is a poten�al for the chemical to persist and degrade in the environment either through biodegrada�on or other processes, such as oxida�on or hydrolysis

• Results of tests of bioaccumula�on poten�al referencing the octanol-water par��on coefficient (Kow) and the bioconcentra�on factor (BCF), where available

• The poten�al for a substance to move from the soil to the groundwater, indica�ng results from adsorp�on or leaching studies

• Other adverse effects (e.g., environmental fate, ozone layer deple�on poten�al, photochemical ozone crea�on poten�al, endocrine disrup�ng poten�al, global warming poten�al)

Section 13: Disposal Considerations (Non-Mandatory)

This section provides guidance on proper disposal practices, recycling, or reclamation of the chemical(s) or container(s), and safe handling practices. To minimize exposure, this section should also refer the reader to Section 8 (Exposure Controls/Personal Protection) of the SDS. The information may include:

• Descrip�on of appropriate disposal containers to use

• Recommenda�ons of appropriate disposal methods to employ

• Descrip�on of the physical and chemical proper�es that may affect disposal ac�vi�es (language discouraging sewage disposal)

• Any special precau�ons for landfills or incinera�on ac�vi�es

Section 14: Transport Information (Non-Mandatory)

This section provides guidance on classification information for shipping and transporting of hazardous chemical(s) by road, air, rail, or sea. The information may include:

• UN number (i.e., four-figure iden�fica�on number of the substance)

• UN proper shipping name

• Transport hazard class(es)

• Packing group number, if applicable, based on the degree of hazard

• Environmental hazards (e.g., iden�fy if it is a marine pollutant according to the Interna�onal Mari�me Dangerous Goods Code)

• Guidance on transport in bulk (according to Annex II of MARPOL 73/783 and the Interna�onal Code for the Construc�on and Equipment of Ships Carrying Dangerous Chemicals in Bulk (Interna�onal Bulk Chemical Code))

• Any special precau�ons which an employee should be aware of or needs to comply with, in connec�on with transport or conveyance either within or outside their premises (indicate when informa�on is not available)

Section 15: Regulatory Information (Non-Mandatory)

This section identifies the health, safety, and environmental regulations specific for the product that is not indicated anywhere else on the SDS. The information may include any national and/or regional regulatory

information of the chemical or mixtures, including any OSHA, DOT, EPA, or Consumer Product Safety Commission regulations.

Section 16: Other Information

This section indicates when the SDS was prepared or when the last known revision was made. The SDS may also state where the changes have been made to the previous version. You may wish to contact the supplier for an explanation of the changes. Other useful information may also be included here.

20.0 NEW HCS PICTOGRAMS AND HAZARDS

There are nine pictograms under the GHS to convey the health, physical, and environmental hazards. The final HCS requires eight of these pictograms, the excep�on being the environmental pictogram, as environmental hazards are not within OSHA’s jurisdic�on. The hazard pictograms and their corresponding hazards are shown below.

Health Hazard Flame Exclama�on Mark

• Carcinogen

• Mutagenicity

• Reproduc�ve Toxicity

• Respiratory Sensi�zer

• Target Organ Toxicity

• Aspira�on Toxicity

• Flammables

• Pyrophorics

• Self-Hea�ng

• Emits Flammable Gas

• Self-Reac�ves

• Organic Peroxides

• Irritant (Skin and Eye)

• Skin Sensi�zer

• Acute Toxicity (Harmful)

• Narco�c Effects

• Respiratory Tract Irritant

• Hazardous to Ozon Layer (Non-Mandatory)

Gas Cylinder Corrosion Exploding Bomb

• Gases Under Pressure

• Skin Corrosion/Burns

• Eye Damage

• Corrosive to Metals

• Explosives

• Self-Reac�ves

• Organic Peroxides

Flame Over Circle Environment (Non-Mandatory) Skull and Crossbones

• Oxidizers

• Aqua�c Toxicity

21.0 ALLOCATION OF LABEL ELEMENTS (EXAMPLES)

• Acute Toxicity (Fatal or Toxic)

In the revised HCS, OSHA has provided classifiers with the op�on of relying on the classifica�on lis�ngs of IARC and NTP to make classifica�on decisions regarding carcinogenicity rather than applying the criteria themselves. OSHA believes that this will make classifica�on easier for classifiers, as well as lead to greater consistency. In addi�on, OSHA has provided guidance on hazard classifica�on for carcinogenicity in Appendix F (non-mandatory) of the revised rule. Part A of Appendix F includes background guidance provided by GHS based on the Preamble to the

IARC “Monographs on the Evalua�on of Carcinogenic Risks to Humans” (2006). Part B provides IARC classifica�on informa�on. Part C provides background guidance from the Na�onal NTP “Report on Carcinogens” (RoC) Part D is a table that compares GHS carcinogen hazard categories to carcinogen classifica�ons under IARC and NTP, allowing classifiers to be able to use informa�on from IARC and NTP RoC carcinogen classifica�ons to complete their classifica�ons under the GHS, and thus the HCS.

Carcinogenicity

Category 1A

Category 2 Danger Danger Warning

May cause cancer (state route of exposure if it is conclusively proven that no other routes of exposure cause the hazard)

Category 1B

May cause cancer (state route of exposure if it is conclusively proven that no other routes of exposure cause the hazard)

Suspected of causing cancer (state route of exposure if it is conclusively proven that no other routes of exposure cause the hazard)

Recommendations on the Transport of Dangerous Goods Model Regulations.

OSHA is retaining the requirement to include the ACGIH TLVs on the SDS in the revised standard. OSHA finds that requiring TLVs on the SDS will provide employers and employees with useful informa�on to help them assess the hazards presented by their workplaces. In addi�on to TLVs, OSHA PELs and any other exposure limit used or recommended by the chemical manufacturer, importer, or employer preparing the SDS are also required. The Company strictly adheres to these guidelines.

HAZARD IDENTIFICATION/RISK ASSESSMENT

1.0 PURPOSE

The IT Landes, hereina�er referred to as “the Company,” hazard iden�fica�on and risk assessment program should be used as a tool to help iden�fy and evaluate both exis�ng and poten�al hazards on worksites as well as methods to control and eliminate the hazards iden�fied.

2.0 RESPONSIBILITIES

Supervisors shall start the hazard iden�fica�on process before the job begins by iden�fying hazards that are known to exist on-site and documen�ng them. By iden�fying hazards early, the supervisor may be able to implement controls before any workers arrive on-site.

To ensure the process is thorough, the supervisor should:

• Look at all aspects of the work.

• Include non-rou�ne ac�vi�es such as maintenance, repair, or cleaning.

• Look at accident, incident, and near-miss records and include people who work off-site (e.g., at home, on other jobsites, drivers)

• Look at the way the work is organized or done and include experience and age of people doing the work, systems being used, etc.

• Look at foreseeable unusual condi�ons (e.g., possible impact on hazard control procedures that may be unavailable in an emergency situa�on, power outage)

• Examine risks to visitors or the public.

• Include an assessment of groups that may have a different level of risk, such as young or inexperienced workers.

3.0 POLICY

The hazard iden�fica�on process is used for rou�ne and non-rou�ne ac�vi�es as well as new processes, changes in opera�on, products, or services as applicable.

The assessment process must be completed prior to the start of all jobs to iden�fy exis�ng or poten�al hazards to workers and eliminate or control these hazards through the use of engineering or administra�ve controls, proper training, or the use of PPE.

All Company staff and contractors are required to take a proac�ve approach to managing and repor�ng hazards. When they observe a hazard, they are required to take steps to manage that hazard directly (provided they are adequately knowledgeable and trained to safely do so) eliminate the hazard or get assistance from appropriate persons to do so whenever reasonably possible. If hazards cannot be eliminated immediately, take necessary steps to warn others of the hazard. Report hazardous or poten�ally hazardous condi�ons and acts to a supervisor or site contact for contractors.

4.0 RISK ASSESSMENT

The Company has a formal process for iden�fying poten�al hazards. Processes are in place to iden�fy poten�al hazards by the use of job safety analysis (JSA), job hazard analysis, facility-wide or area-specific analysis and inspec�ons.

Employees and/or subcontractors are ac�vely involved in the hazard iden�fica�on process. The program provides processes to ensure employees and/or subcontractors are ac�vely involved in the hazard iden�fica�on process and hazards are reviewed with all employees concerned.

5.0 ENVIRONMENTAL HAZARDS

All environmental hazards and poten�al issues will be outlined and discussed on the JSA.

The JSA will include an environmental checklist which outline the following:

• Streams

• Wetlands

• Cultural/sensi�ve areas

The JSA will also iden�fy environmental and sedimenta�on page numbers that are outlined in customer-specific drawings if applicable.

6.0 CLASSIFICATION

Hazards are classified and ranked based on severity. The program iden�fies hazards are classified/priori�zed and addressed based on the risk associated with the task see the risk analysis matrix outlining severity and probability.

Ranking or priori�zing hazards is one way to help determine which hazard is the most serious and thus which hazard to control first. Priority is usually established by considering the employee exposure and the poten�al for accident, injury, or illness. By assigning a priority to the hazards, a ranking or an ac�on list is created. The following factors play an important role:

• Percentage of workforce exposed

• Frequency of exposure

• Degree of harm likely to result from the exposure

7.0 PROBABILITY OF OCCURRENCE

There is no single or simple way to determine the level of risk. Ranking hazards requires knowledge of workplace ac�vi�es, urgency of situa�ons, and most importantly, objec�ve judgment. One op�on is shown in the following two tables:

Risk Severity Index

Level 1: Fatality or property damage exceeding $50,000

Level 2: Employee admited to hospital or probable permanent disability or property damage between $10,000 and $50,000

Level 3: Employee not able to perform all of their regular du�es or property damage between $1,000 and $10,000

Level 4: Employee able to perform all of their regular du�es or property damage less than $1,000

Occurrence Probability Index Example

Level A: Likely to occur immediately

Level B: Probable in �me

Level C: Possible in �me

Level D: Remotely possible

Could happen any day

Likely to happen if condi�ons are repeated

Under the right condi�ons, the incident might be repeated

Even under similar condi�ons, it is unlikely the incident will be repeated

For the ac�vity being examined, determine the most likely reasonable level of severity. Then determine how likely (probable) the injury would be. For example, being hit by a low-speed car is most o�en a Level 2 injury but is barely possible (Level D) for someone who works a kitchen job. However, put that same person wearing all black on a roadside at night replacing the roadside lightbulbs and the severity increases to Level 1 (fatality reasonably likely) and the probability increases to Level A.

The kitchen worker would have a score of 2D on the table below. The table puts a 2D risk at a Level 3. Simple rules, such as ensuring that kitchen workers have a path to the dumpster that does not involve vehicle traffic, would be an example.

The case of the worker wearing all black on a roadside at night is 1A on the table below, which is a completely unacceptable level of risk. The worker should only do the job during the day in high visibility clothing with proper traffic control barriers

Defini�on Risk is the chance or probability that a person will be harmed or experience an adverse health effect if exposed to a hazard. It may also apply to situa�ons with property or equipment loss.

4 - Low Ac�vi�es in this category contain minimal risk and are unlikely to occur. Organiza�ons can proceed with these ac�vi�es as planned.

3 - Medium Ac�vi�es in this category contain minor to serious risks that are remotely likely to likely to occur. Applica�on of proac�ve risk management strategies to reduce the risk is advised. Organiza�ons should consider ways to modify or eliminate unacceptable risks.

2 - High Ac�vi�es in this category contain unacceptable levels of risk, including catastrophic and cri�cal injuries that are highly likely to occur. Organiza�ons should consider whether they should eliminate or modify ac�vi�es that s�ll have a “high” ra�ng a�er applying all reasonable risk management strategies.

1 - Extreme Ac�vi�es in this category should not be allowed to proceed without very careful planning. The Company needs to evaluate whether the ac�vity is actually necessary in the first place.

Once the risk has been assessed, the appropriate controls shall be put into place. The following describes how iden�fied hazards/risks are addressed and mi�gated:

The main ways to control a hazard include:

• Elimina�on (Including Subs�tu�on): Remove the hazard from the workplace.

• Engineering Controls: Designs or modifica�ons to plants, equipment, ven�la�on systems, and processes that reduce the source of exposure.

• Administra�ve Controls: Controls that alter the way the work is done, including �ming of work, policies and other rules, and work prac�ces such as standards and opera�ng procedures, including training, housekeeping, equipment maintenance, and personal hygiene prac�ces.

• Personal Protec�ve Equipment: Equipment worn by individuals to reduce exposure such as contact with chemicals or exposure to noise.

Develop safe prac�ces/engineering controls to mi�gate risk. These methods are also known as the “hierarchy of control” because they should be considered in the order presented (it is always best to try to eliminate the hazard first, etc.).

Controls are placed:

• At the source (where the hazard “comes from”)

• Along the path (where the hazard “travels”)

• At the worker

Control at the source and control along the path are also known as engineering controls.

Administra�ve controls limit worker exposure by implemen�ng other “rules” such as training, supervision, shorter shi�s in high-risk areas, etc. These control measures have many limita�ons because the hazard itself is not actually removed or reduced. Administra�ve controls are not generally favored because they can be difficult to implement, maintain, and are not a reliable way to reduce exposure

PPE includes items such as respirators and protec�ve clothing (e.g., gloves, face shields, eye protec�on, footwear) that serve to provide a barrier between the wearer and the chemical or material. It is the final item on the list for a very good reason. PPE should never be the only method used to reduce exposure except under very specific circumstances because PPE may “fail” (stop protec�ng the worker) with litle or no warning. For example, “breakthrough” can occur with gloves, clothing, and respirator cartridges.

Once the best and most prac�cal control for a par�cular hazard has been decided, it needs to be documented. The safe work procedure for the job needs to be writen based on those risks and controls. Using the example from earlier with the car striking a worker, the kitchen work procedure for garbage removal should include something about having the dumpster near the back door of the kitchen and not across the parking lot. It could also include instruc�on to the worker to ensure that they report any burnt-out exterior lights. Some may add requirements to put on a reflec�ve vest when taking out the garbage at night. The worker replacing the roadside lightbulbs needs to have a safe work procedure that includes only doing the job during the day in high visibility clothing with proper traffic control barriers Parking a service vehicle in the road ahead of the worker to act as a substan�al physical barrier would further reduce the risk.

8.0 COMMUNICATE THE CONTROLS AND TRAIN THE WORKERS

All employees will be trained in the hazard iden�fica�on process, including the use and care of proper PPE.

Once the control has been put into place, the Company shall train employees how to use it. This applies whether it is an engineering control (e.g., guard, interlock) or an administra�ve control (e.g., safe work procedure for cold weather, par�cular PPE when handling a chemical). Training records and/or documented signoffs are required to show that the workers have been made aware of the hazards and controls.

9.0 REVIEW

Repeat the hazard assessment process every two years, when site condi�ons change, when new tasks are added, or when new workers join the crew in order to prevent the development of unsafe working condi�on.

HEAT ILLNESS PREVENTION

1.0 PURPOSE

The purpose of this document is to is to provide employees with the necessary training and equipment to protect against heat-related injury and illness while working for IT Landes, hereina�er referred to as “the Company.”

2.0 RESPONSIBILITIES

Management

• Ensure that all employees are provided with this policy, the proper training, and any equipment necessary to avoid heat-related injury and illness prior to ini�al assignment where heat may be a factor.

• Designate a competent person to act as the hydra�on monitor on each worksite.

3.0 POLICY

4.0 TRAINING

All employees who are or may be exposed to poten�al heat-related illnesses will receive training on the following:

• The environmental and personal risk factors that cause heat-related illnesses

• Procedures for iden�fying, evalua�ng, and controlling exposures to the environmental and personal risk factors for heat illness

• The importance of frequent consump�on of small quan��es of water (up to 4 cups per hour under extreme condi�ons of work and heat)

• The importance of acclima�za�on

• The different types and common signs and symptoms of heat illness

• The importance of immediately repor�ng to the Company, directly or through the employee’s supervisor, signs or symptoms of heat illness in themselves or in coworkers

• The Company’s procedures for responding to symptoms of possible heat illness, including how emergency medical services will be provided should they become necessary

• Procedures for contac�ng emergency medical services and, if necessary, transpor�ng employees to a point where they can be reached by an emergency medical service provider

• How to provide clear and precise direc�ons to the worksite

Supervisors will receive training on the following:

• How to prevent heat-related illness prior to supervising employees working in heat

• Procedures to follow when an employee exhibits symptoms consistent with possible heat illness, including emergency response procedures

5.0 HEAT CRAMPS

Symptoms of heat cramps include:

• Loss of salt through excessive swea�ng

• Cramping in back, legs, and arms

If someone shows signs and symptoms of heat cramps, they should:

• Stretch and massage muscles

• Replace salt by drinking commercially available carbohydrate/electrolyte replacement fluids

6.0 HEAT EXHAUSTION

Heat exhaus�on occurs when the body can no longer keep blood flowing to supply vital organs and at the same �me send blood to the skin to reduce body temperature.

Heat exhaus�on symptoms include:

• Weakness

• Difficulty con�nuing work

• Headache

• Breathlessness

• Nausea or vomi�ng

• Feeling faint or actually fain�ng

Heat Exhaus�on Treatment

Call 911 for emergency help if a worker is suspected to have heat exhaus�on. While awai�ng emergency assistance, help the worker cool off by:

• Res�ng in a cool place

• Drinking cool water

• Removing unnecessary clothing.

• Loosening clothing

• Showering or sponging with cool water

It takes 30 minutes to cool the body down once a worker becomes overheated and suffers heat exhaus�on.

7.0 HEAT STROKE

Heat stroke occurs when the body can no longer cool itself down and body temperature rises to cri�cal levels.

Heat stroke symptoms include:

• Confusion

• Irra�onal behavior

• Loss of consciousness

• Convulsions

• Lack of swea�ng

• Hot, dry skin

• Abnormally high body temperature

Heat Stroke Treatment

• Call 911

• Provide immediate, aggressive, general cooling.

• Immerse vic�m in tub of cool water, place in cool shower, or spray with cool water from a hose.

• Wrap vic�m in cool, wet sheets and fan rapidly

• Transport vic�m to hospital.

Do not give anything by mouth to an unconscious vic�m.

8.0 WORKERS

Workers are responsible for performing the following:

• Follow instruc�ons and training for controlling heat stress.

• Be alert to symptoms in yourself and others

• Determine if any prescrip�on medica�ons you’re required to take can increase heat stress

• Wear light, loose fi�ng clothing that permits the evapora�on of sweat.

• Wear light-colored garments that absorb less heat from the sun

• Drink small amounts of water (approximately 1 cup every 15 minutes).

• Avoid beverages such as tea or coffee.

• Avoid ea�ng hot, heavy meals.

• Do not take salt tablets unless prescribed by a physician

9.0 HEAT DISORDERS

Symptoms

• Red blotches and extreme itchiness in areas persistently damp with sweat

• Prickling sensa�on on the skin when swea�ng occurs

Treatment

• Cool environment

• Cool shower

• Thorough drying

Heat rashes typically disappear within a few days a�er exposure. The rash may become infected if the skin is not cleaned frequently enough

10.0 ENVIRONMENTAL FACTORS

Procedures must be in place to control the effects of environmental factors that can contribute to heat-related illness. The most common environmental factors are air temperature, humidity, radiant heat sources, and air circula�on.

11.0 PHYSICAL FACTORS

Physical factors that contribute to heat-related illness should be taken into considera�on before performing a task. The most common physical factors that can contribute to heat-related illness are the type of work, level of physical ac�vity and dura�on, and clothing color, weight, and breathability.

12.0 PROVISIONS OF WATER

Employees shall have access to potable drinking water. Where it is not plumbed or otherwise con�nuously supplied, it shall be provided in sufficient quan�ty throughout the work shi�

Water shall be provided in sufficient quan�ty at the beginning of the work shi� to provide 1 quart per employee per hour for drinking the en�re shi� for a total of 2 gallons per employee per 8-hour shi�. Employees may begin the shi� with smaller quan��es of water if effec�ve procedures for replenishment of water during the shi� have been implemented to provide employees 1 quart or more per hour.

13.0 ACCESS TO SHADE

Employees suffering from heat illness or believing a preventa�ve recovery period is needed shall be provided access to an area with shade that is either ven�lated, cooled, or open to the air. Such access to shade shall be permited at all �mes. Shaded areas can include trees, buildings, canopies, lean-tos, or other par�al and/or temporary structures that are either ven�lated, cooled, or open to air movement. The interior of cars or trucks are not considered shaded unless the vehicles are air condi�oned or kept from hea�ng up in the sun in some other way.

14.0 SAFE WORK PROCEDURES

Supervisors must ensure personal factors that contribute to heat-related illness are taken into considera�on before assigning a task where there is the possibility of a heat-related illness occurring. The most common personal factors that can contribute to heat-related illness are age, weight, fitness, drug and alcohol use, prior heat-related illness, etc.

• Give workers frequent breaks in a cool area away from heat.

• Adjust work prac�ces as necessary when workers complain of heat stress.

• Oversee heat stress training and acclima�za�on for new workers and workers who have been off the job for a period of �me.

• Monitor the workplace to determine when hot condi�ons arise.

• Increase air movement by using fans when possible.

• Provide potable water in required quan��es.

• Determine whether workers are drinking enough water.

• Make allowances for workers who must wear personal protec�ve clothing (welders, etc.) and equipment that retains heat and restricts the evapora�on of sweat.

• Schedule hot jobs for cooler �mes of the day.

• Schedule rou�ne maintenance and repair work in hot areas for cooler �mes of the day.

• Make cooling devices (e.g., hardhat liners, bibs, neck bands) available to all workers to help rid bodies of excessive heat.

15.0 EMPLOYEES

Awareness of heat illness symptoms can save your life or the life of a coworker. The following list provides valuable informa�on concerning heat-related illnesses and preventa�ve measures:

• If you are coming back to work from an illness or an extended break or you are just star�ng a job working in the heat, it is important to be aware that you are more vulnerable to heat stress un�l your body has �me to adjust. Let your employer know you are not used to the heat. It takes about 5-7 days for your body to adjust.

• Drinking plenty of water frequently is vital for workers exposed to the heat. An individual may produce as much as 2-3 gallons of sweat per day. In order to replenish that fluid, you should drink 3-4 cups of water every hour star�ng at the beginning of your shi�.

• Taking your breaks in a cool shaded area and allowing �me for recovery from the heat during the day are effec�ve ways to avoid a heat-related illness.

• Avoid or limit the use of alcohol and caffeine during periods of extreme heat as both dehydrate the body.

• If you or a coworker start to feel symptoms such as nausea, dizziness, weakness, or unusual fa�gue, let your supervisor know and rest in a cool shaded area. If symptoms persist or worsen, seek immediate medical aten�on.

• Whenever possible, wear clothing that provides protec�on from the sun but allows airflow to the body. Protect your head and shade your eyes if working outdoors.

• When working in the heat, pay extra aten�on to your coworkers and be sure you know how to call for medical aten�on.

HEAVY EQUIPMENT

1.0 PURPOSE

This program ensures that IT Landes, hereina�er referred to as “the Company,” complies with local regulatory requirements and outlines the responsibili�es of managers, supervisors, and employees in the opera�on and management of Company-owned or rented heavy equipment.

2.0 RESPONSIBILITIES

Safety Manager

• Develop and maintain this program and related procedure, which are stored in the safety manager’s office.

Site Manager or Supervisor

• Implement and maintain this program on their site.

• Ensure that everyone complies with this program.

Employees

• Be familiar with this program and the vehicle safety program for their workplace.

• Follow all requirements of this program

• Report any unsafe condi�ons.

3.0 REQUIREMENTS

The Company shall develop and implement safe work procedures for using powered heavy equipment and shall train employees in applicable safe work procedures.

The heavy equipment operator is directly responsible for opera�ng the equipment safely and must comply with all laws and regula�ons regarding the opera�on of the equipment.

Records of maintenance, including service, repair, or modifica�on which may affect the equipment’s safe performance, must be kept and reasonably available to the equipment operator and maintenance employees during work hours.

Heavy equipment must be maintained in safe opera�ng condi�on. The opera�on, inspec�on, repair, maintenance, and modifica�on of this equipment must be done in accordance with manufacturer instruc�ons or good engineering principles in the absence of manufacturer instruc�ons If heavy equipment must be serviced, repaired, or maintained, it will be done when the equipment is not being operated unless the service requires the opera�on to con�nue, and it is safe to do so.

Heavy equipment will only be operated by authorized employees. The Company authorizes employees who qualify based on appropriate training and proficiency tes�ng. Authorized employees must also have an applicable operator’s license, an airbrake cer�ficate where required, and be familiar with the equipment’s opera�ng instruc�ons. Authoriza�on to operate the equipment will be issued only a�er these requirements are met.

Supervisors must not knowingly operate or permit an employee to operate heavy equipment which would be in viola�on of any local or federal regula�ons or does/could create an undue health or safety hazard to any person.

All heavy equipment will have working signal alarm that sounds when backing up. The operator will ensure that the warning signal operates when the equipment is backing up. If the operator of heavy equipment cannot directly or indirectly (by mirror or other device) see directly behind the machine, the equipment must have an audible warning device that ac�vates when the equipment moves in reverse. If prac�cal, the audible warning device should be audible above the ambient noise level.

No unauthorized personnel are allowed to ride on equipment unless it is designed to safely accommodate riders.

The Company will ensure that operators make a full 360 ° visual inspec�on of equipment and the nearby vicinity prior to star�ng the powered heavy equipment to ensure that no one is endangered by the start up. The operator shall not start powered heavy equipment un�l the full visual inspec�on is completed.

A competent person must inspect all powered heavy equipment for defects and unsafe condi�ons. This must be done as o�en as is necessary to ensure that the equipment is safe to operate. Records of these inspec�ons, repairs, and maintenance are maintained at the workplace and are readily available to the equipment operator. Defects must be repaired, or the unsafe condi�on corrected as soon as is reasonably prac�cable.

The operator of the equipment will inspect and check the assigned equipment at the beginning of each shi�. Any malfunc�on of the clutch, braking, ligh�ng, steering, or control system must be immediately reported to the supervisor and the equipment must be locked or tagged out if necessary.

If defects or condi�ons that affect or are likely to affect the safe opera�on of the equipment are found, the operator must report them to their immediate supervisor (or other authorized person) and submit a writen report as soon as possible. If inspec�on of powered heavy equipment results in a defect or unsafe condi�on being iden�fied that is hazardous or may create a health or safety risk, the Company must ensure that the equipment is taken out of service un�l the defect is repaired or the unsafe condi�on is corrected.

The operator must never leave the controls of heavy equipment unatended unless it is secured against movement (e.g., se�ng the parking brake, placing the equipment in “park,” chocking the wheels). The operator must never leave a suspended load unatended unless the equipment has been immobilized and secured movement.

Never leave powered equipment unatended unless buckets, forks, blades, and similar parts are lowered or solidly supported.

Operators will use the access designed to get on or off equipment. Never jump to the ground. Never operate heavy equipment without using an enclosed cab or approved eye protec�on.

Powered heavy equipment must be equipped with a cab, screen, or guard if there is a risk of a falling object or projec�le to the operator or other worker permited to be in or on the powered heavy equipment.

The Company requires that every forkli� is equipped with a seat belt for the operator (if the forkli� is equipped with a seat), and operators required to use the seatbelt. The operator will fasten and adjust the seat belt before star�ng the engine.

Every vehicle used for li�ing must have a durable and clearly legible load ra�ng chart that is located so it is readily available to the operator. The operator will not load the vehicle or equipment beyond its load limit. The operator will not move loads that have not been centered (because of the length, width, or height) and secured for safe transporta�on.

The Company requires that all heavy equipment that is used for li�ing, hois�ng or similar opera�ons will have the safe working load capacity permanently affixed to the equipment and its nota�on must be legible and clearly visible to the operator.

The operator will not use or atempt to use any equipment in a manner, or for a purpose, other than what it was designated for.

The Company will ensure that the operator’s manual for powered heavy equipment is readily available to the operator.

The Company will ensure that service, inspec�on, disassembly, and reassembly of a �re or �re and wheel assembly of powered heavy equipment will be performed by a competent person in accordance with the specifica�ons of the manufacturer of the powered heavy equipment and the �re manufacturer.

Heavy equipment must have an audible warning signal, a way to illuminate the travel path and taillights in case of insufficient light or unfavorable environmental condi�ons, sa�sfactory ligh�ng in the cab and instruments, and a mirror that provides the operator with an undistorted view behind the heavy equipment

The Company will provide sa�sfactory, approved fire suppression equipment for all heavy equipment.

Prior to filling the fuel tank of a gasoline or diesel vehicle, operators must shut off the engine and ensure that the nozzle is correctly inserted into the filling neck of the tank. Never fuel the vehicle with passengers on the vehicle unless it is specifically required by design. Do not smoke or have open flames nearby during fueling.

If a worker must work beneath raised parts of heavy equipment, the raised parts must be securely blocked.

All materials and equipment that are being transported must be loaded and secured to prevent movement that could cause a hazard to the operator or other people. As such, keep the cab, floor, and deck of the heavy equipment free of tools, materials, or other objects that could cause a tripping hazard, interfere with opera�ng controls, or, could become a hazard to the operator or other occupants in the case of an accident.

If a vehicle, heavy equipment, crane, or similar handling equipment does not allow an operator to have a full view of the intended travel path or its load, the equipment must be operated only with the direc�on of a signaler who is a competent person. The signaler must be located in full view of the operator and have a full view of the intended travel path (but not on the travel path) of the equipment and its load.

The minimum required clearance between power lines (rated more than 750 volts) and any part of the equipment or load must meet applicable requirements by local or federal law.

A worker must never be directed, required, or allowed to work under (or in the range of) a swinging load or por�on of the powered heavy equipment because of the danger to them.

INCIDENT INVESTIGATION AND REPORTING

1.0 PURPOSE

The purpose of this program is to put effec�ve procedures in place for IT Landes, hereina�er referred to as “the Company,” employees to report, evaluate, and inves�gate reported incidents and non-conformance in order to prevent further occurrences.

2.0 RESPONSIBILITIES

Responsibili�es for incident inves�ga�on will be assigned to individuals prior to occurrence of an incident. Individual responsibili�es for repor�ng and inves�ga�on must also be in place and assigned prior to an incident.

Safety Manager

• Ensure inves�ga�ons are conducted in a �mely manner.

• Assist in the iden�fica�on of correc�ve ac�ons.

• Ensure the correc�ve ac�ons are carried out expedi�ously

Site Manager and Supervisors

• Inves�gate or assist in incident inves�ga�ons.

• Ensure all incidents are corrected in order to comply with Company policy

• Assist injured employees to a medical provider for ini�al treatment.

Employees

• Immediately report any injury, job-related illness, spill, or damage to any property to their immediate supervisor; and if their immediate supervisor is unavailable, the employee will immediately no�fy the project manager or next person in the chain of command.

Employees who are eligible to be first responders will be trained and qualified in first-aid techniques in order to help mi�gate the degree of loss during the immediate post-incident phase.

3.0 PROCEDURE

A�er rescue or response, ac�ons to prevent further loss should immediately occur if the scene is safe. For example, maintenance personnel should be summoned to assess the integrity of buildings and equipment and engineering personnel should be summoned to evaluate the need for bracing of structures and special equipment/response requirements such as safe rendering of hazardous materials or explosives employed.

Inves�ga�ons of Incidents and Non-Conformance

Inves�ga�on is an important part of an effec�ve safety program because it determines the root cause and correc�ve ac�ons necessary to prevent similar incidents or non-conformance from occurring in the future.

The following incidents must be immediately reported to the employee’s supervisor. If that person is not available, then the safety manager shall be immediately no�fied for:

• Near-miss incidents with the poten�al to harm people, the environment, or assets

• Work-related injuries or illnesses

• Any damage to property, including vehicle incidents

• Hazardous chemical spillage, which includes loss of containment and contamina�on

• Non-conformance to safety or environmental rules, policies, or standards

The supervisor will no�fy all necessary individuals and agencies and then begin the incident inves�ga�on process.

In the case of a major injury or incident, the scene of the event should be closed off and kept “as is” at the �me of the incident. This is vital for effec�ve incident inves�ga�on.

Incident inves�ga�on will take place as soon as possible, while the facts are s�ll fresh within the minds of everyone involved (i.e., witnesses). Take the opportunity to talk to all of those involved before they become unavailable or their memory fades. An incident inves�ga�on must be thorough and only focused with the cause and preven�on. Administra�ve disciplinary ac�on will be kept separate from the inves�ga�on process.

Equipment

All necessary equipment will be made available to aid in conduc�ng a proper inves�ga�on. Equipment may include some or all of the following items:

• Wri�ng equipment such as pens and paper

• Measurement equipment such as tape measures and rulers

• Cameras, small tools, and audio recorder

• PPE, flags, equipment manuals, etc.

The safety manager shall have an incident inves�ga�on kit prepared in advance to facilitate a thorough inves�ga�on.

Incident Repor�ng Matrix

The incident repor�ng matrix iden�fies who within corporate management shall be verbally no�fied and when based on type of incident. It also specifies which type of report shall be completed based on the type of incident.

Repor�ng of the incident must occur in a specified manner based on site-specific requirements and the repor�ng sequence shall be posted.

Reportable

Time Elements for OSHA and Client No�fica�on

Required incidents must be verbally reported to OSHA within 8 hours of their discovery. Incidents must also be reported to the owner client as soon as possible or no longer than within 24 hours of the occurrence.

Incident Review Team and Incident Inves�ga�on Report

All incidents will be inves�gated according to levels of incident severity. While all incidents will be inves�gated, the extent of such inves�ga�on shall reflect the seriousness of the incident according to a root cause analysis process or other similar method approved and put in place by the safety manager. An incident review team that par�cipates in the determina�on of the final root cause will be formed to aid inves�ga�ve incident repor�ng. The team will consist of representa�ves of management and other personnel assigned by the safety manager.

Ini�al Iden�fica�on of Evidence

Ini�al iden�fica�on of evidence immediately following the incident should include:

• The loca�on of the incident, a lis�ng of people on the scene

• Equipment and materials involved

• A recording of environmental factors such as weather, illumina�on, temperature, noise, ven�la�on, etc.

Collec�on, Security, and Preserva�on of Evidence

Evidence (e.g., people, posi�ons of equipment, parts, papers) must be collected, secured, and preserved through the use of notes, photographs, witness statements, flagging, and the seizing of documents and equipment. All evidence shall be dated appropriately.

Witness Interviews and Statements

Witness interviews and statements must be collected. Loca�ng witnesses, ensuring unbiased tes�mony, obtaining appropriate interview loca�ons, and use of trained interviewers should be detailed. The need for follow-up interviews should also be addressed. All items shall be dated.

The final incident inves�ga�on report will consist of findings with cri�cal factors, evidence, correc�ve ac�ons, responsible par�es, a schedule for correc�ve ac�on, and �meline for comple�on.

Results of incident inves�ga�ons are communicated to employees via the Incident No�ce Form

Prepara�on of the Writen Incident Report

Writen incident reports will be prepared and will include the field incident report along with a detailed narra�ve statement concerning the events. The format of the narra�ve report should include an introduc�on, methodology, summary of the incident, incident review team member names, narra�ve of the event, findings, and recommenda�ons. Photographs, witness statements, drawings, etc. should be included in the report.

The supervisor completes the field incident report and takes the steps outlined below when beginning an incident inves�ga�on:

• Provide emergency assistance as needed and if qualified to do so.

• Secure the area as quickly as possible so that it remains in the same condi�on as it was at the �me of the incident.

• No�fy management by phone according to the incident no�fica�on matrix

• Iden�fy poten�al witnesses

• Use inves�ga�on tools, as needed (camera, drawings, video, etc.).

• Secure any equipment involved as evidence by lockout/tagout.

• Interview witnesses (including the affected employee) and obtain writen, signed statements which will be faxed to the safety manager

• Prepare a field incident report, sign it, and fax it to the safety manager.

• Implement any correc�ve ac�ons needed immediately.

Incident No�ce Form

The Company shall provide documenta�on and communica�on of lessons learned and reviews of similar opera�ons to prevent reoccurrence. Lessons learned are reviewed and communicated to the appropriate personnel. Changes to processes and procedures must then be put into immediate effect to prevent reoccurrence of similar events.

In order to communicate incident informa�on and lessons learned from them, the safety manager shall send the Incident No�ce Form to all worksites. The form shall be posted on all employee bulle�n boards and shall be discussed in weekly safety mee�ngs un�l all employees at the jobsite have been informed of the incident and correc�ve ac�ons put in place.

Root Causes, Correc�ve Ac�ons, and Lessons Learned Resul�ng from Incident Inves�ga�ons

All recordable incidents, at fault vehicle incidents, and serious near misses will require a “why tree root cause analysis” to be completed. General and root cause incident inves�ga�ons should result in correc�ve ac�ons. Individuals should be assigned responsibili�es rela�ve to the correc�ve ac�ons and should be monitored un�l all correc�ve ac�ons have been implemented. The incident inves�ga�on and report can be closed a�er verifying the necessary correc�ve ac�ons have been put in place.

Site managers are held accountable for closing correc�ve ac�ons. Correc�ve ac�ons for safety improvement input are posted at each site and tracked by the safety manager to ensure �mely follow up and comple�on.

Correc�ve ac�ons will also be used as needed for revisions to site-specific safety plans and the Company-wide health and safety management system. A “lessons learned” document with the correc�ve ac�ons must be distributed Company-wide to prevent recurrences.

Injury Classifica�ons

• First Aid: Dressing on a minor cut, removal of a splinter, or other such typical treatments for household type injuries.

• Lost Workday Case (LWDC): An injury that results in an employee being unfit to perform any work on any day a�er the occurrence of an occupa�onal injury.

• Number of Lost or Restricted Workdays: The number of days, excluding the day of injury and the day of return, missed from scheduled work due to being unfit for work or medically restricted to the point that the essen�al func�ons of a posi�on cannot be worked.

• Occupa�onal Illness: Any abnormal condi�on or disorder caused by exposure to environmental factors while performing work. The illness would result in medical treatment by a physician for a skin disorder, respiratory condi�on, poisoning, hearing loss, or other disease (e.g., frostbite, heatstroke, sunstroke, welding flash, diseases caused by parasites). Minor treatments (first aid) for illnesses do not fall within this classifica�on.

• Occupa�onal Injury: An injury which results from a work-related ac�vity.

• Recordable Medical Case (RMC): An occupa�onal injury more severe than first aid that requires advanced treatment, such as fractures, more than one s�tch, prescrip�on medica�on of more than one dose, unconsciousness, removal of foreign body embedded in eye (not flushing), admission to a hospital for more than observa�on purposes, but does not result in lost work �me beyond the day of injury

• Restricted Workday Case (RWDC): An occupa�onal injury which results in a person being unfit for essen�al func�ons of the regular job on any day a�er the injury but where there is no �me lost beyond the actual day of injury. For example, an injured employee is kept at work but not performing the essen�al func�ons of their regular job.

• Work or Work-Related Ac�vity: All incidents that occur in work-related ac�vi�es during work hours, field visits, etc. are reportable must be included if the occupa�onal injury or illness is more serious than requiring simple first aid. Incidents occurring while in transit to or from loca�ons that are not considered an employee’s primary work or during off hours are not reportable.

The following are examples of incidents that will not be considered as recordable:

• The injury or illness involves signs or symptoms that surface on the job but are the result of a non-workrelated event or exposure that occurs outside the work environment.

• The injury or illness results from voluntary par�cipa�on in a wellness program, flu shot, exercise class, racquetball, baseball, or other such ac�vi�es.

• The injury or illness is the result of an employee ea�ng, drinking, or preparing food or drink for personal consump�on whether bought on the Company premises or brought in.

• The injury or illness is the direct result of an employee doing personal tasks (unrelated to their employment) at the establishment outside of the employee’s assigned work hours.

• The illness is the common cold or flu.

Note: Contagious diseases such as tuberculosis, brucellosis, hepa��s A, or plague are considered work-related if the employee is infected at work.

4.0 TRAINING

The Company shall train all personnel in their roles, responsibili�es, and proper incident inves�ga�on techniques. Training frequency will be based on the specific area of responsibility but will never be more than two years apart. Training requirements rela�ve to incident inves�ga�on and repor�ng shall include the following:

• Awareness

• First responder responsibili�es

• Ini�al Inves�ga�on at the accident scene

• Managing the accident inves�ga�on

• Collec�ng and analyzing data

• Developing conclusions

• Judgment needs

• Repor�ng the results

INFECTIOUS DISEASE

PREPARDENESS

AND RESPONSE PLAN

1.0 PURPOSE

IT Landes, hereina�er referred to as “the Company,” is commited to providing a safe, healthy, and secure workplace. As such, the Company has devised an infec�ous disease preparedness and response plan that outlines the Company’s ac�ons in response to pandemics.

Management will con�nue to take the following steps:

• Regularly monitor informa�on supplied by the Centers for Disease Control and Preven�on (CDC) and the World Health Organiza�on (WHO) regarding the status and spread of pandemics.

• U�lize informa�on from the CDC and the WHO to:

o Determine the poten�al exposure of employees to said pandemic.

o Recommend best prac�ces for addressing the outbreak.

• Develop and implement an appropriate ac�on plan based on informa�on obtained from the CDC and the WHO, as well as from informa�on reported to the Company from employees and third par�es

• Regularly assess opera�ons and make adjustments, as needed, to address absenteeism, deliveries and supplies, and social distancing recommenda�ons.

• Periodically conduct training on illness preven�on, spread of disease, and policies concerning illness.

• Communicate updates as necessary and regularly assess plan effec�veness

2.0 SCOPE

This plan applies to all employees, contractors, service providers, and visitors. The informa�on in this plan and the ac�ons and tasks detailed or proposed herein are based upon rapidly evolving informa�on and guidance from the medical community, governmental officials and agencies, and health organiza�ons concerning pandemics. The Company may deviate from this Plan and/or may modify or amend this plan at any �me and for any reason with or without no�ce.

3.0 DEFINITIONS

Close Contact COVID-19: A person who has stayed in the same residence with a suspected or confirmed COVID-19 case. A person who has had close contact (within 6 feet) or was in a closed environment with a suspected or confirmed COVID-19 case.

Company Loca�on(s): Any Company office, facility, or worksite.

Congregate Se�ngs: Public places where close contact with others may occur.

Influenza: An acute respiratory infec�on that emerges and spreads. Seasonal influenza viruses are characterized by a sudden onset of fever, cough (usually dry), headache, muscle and joint pain, severe malaise, sore throat, and a runny nose

Isola�on: Separates sick people with a contagious disease from people who are not sick. Isola�on for public health purposes may be voluntary or compelled by local, state, or federal public health order.

Pandemic: A worldwide spread of a new disease.

Quaran�ne: Separates and restricts the movement of people who were exposed to a contagious disease to see if they become sick.

Self-Observa�on: Remaining alert for subjec�ve fever, cough, difficulty breathing, or other symptoms. If an individual begins to feel feverish or develops a cough or difficulty breathing during self-observa�on, the individual should begin to track their temperature and note progressive symptoms, limit contact with others, and seek health advice by telephone from the nearest healthcare provider or local health department. If the illness becomes severe, call the nearest hospital, report the symptoms, and seek further medical advice for the next steps.

Suspect COVID-19 Case: A pa�ent with severe acute respiratory infec�on (fever, cough, and requiring admission to hospital); and with no other e�ology that fully explains the clinical presenta�on; and with a history of travel to an established community transmission of COVID-19 during the 14 days prior to symptom onset. A pa�ent with any acute respiratory illness that meets at least one of the following condi�ons during the 14 days prior to symptom onset: close contact with a confirmed or probable case of COVID-19 or worked in or visited a healthcare facility where pa�ents with confirmed or probable COVID-19 pa�ents were being treated. A pa�ent with severe acute respiratory infec�on (fever and at least one sign or symptom of respiratory disease (e.g., cough, shortness of breath)) and requiring hospitaliza�on and with no other e�ology that fully explains the clinical presenta�on.

4.0 PROCEDURE

The Company will define an appropriate ac�on plan based on available informa�on and circumstances. The ac�on plan may vary from loca�on to loca�on and will be updated as needed, based on changing situa�ons and circumstances. Ac�ons may include, but are not limited to, the following:

• Require ill employees to stay home.

• Educate and encourage increased hygiene prac�ces

• Prac�ce social distancing (i.e., maintain a 6-foot distance from others when prac�cal)

• Eliminate mee�ngs or large groups of people as defined.

• Increase sanita�on frequencies and scope.

• Eliminate non-essen�al travel

• Follow medical recommenda�ons for appropriate immuniza�ons.

• Implement telecommu�ng requirements.

• Restrict visitors

• Require self-declara�on statements.

• Implement requirements for returning to work a�er illness or suspected illness.

• Par�ally or fully suspend work ac�vity at any Company loca�on

• Other measures as recommended by the CDC, the WHO, or other government authority

5.0 COMMUNICATION

• The Company will keep employees apprised of this plan and of any ac�ons taken or needed to be taken.

• The Company will follow the guiding authori�es and take appropriate measures for those working remotely.

• The Company shall authorize the appropriate employees to communicate this plan to customers, contractors, and service providers.

6.0 CURRENT EMPLOYEE SELF-OBSERVATION RESPONSIBILITIES

At a �me and frequency, every employee must complete the self-declara�on checklist (Appendix A), as may be required by our clients. If any answer is affirma�ve (“yes”), the individual must not enter any office or worksite and should immediately contact a healthcare provider by telephone or local health department. The individual must also contact the Human Resources Department and their supervisor.

7.0 EMPLOYEES EXHIBITING SYMPTOMS OF COVID-19

If an employee suspects or is suspected of exhibi�ng any signs or symptoms of COVID-19, the employee must immediately isolate themselves and cannot return to work without first contac�ng a healthcare provider. The employee must remain isolated and contact a healthcare provider via telephone. The employee must also contact the Human Resources Department who will coordinator the leave.

Addi�onally, following the indica�on of COVID-19 signs or symptoms, the ques�ons in Appendix B will be covered via telephone with the Human Resources Department. The employee should then contact their supervisor to inform them of the inability to remain on the jobsite. The employee must retain medical clearance from a healthcare provider and contact the Human Resources Department prior to returning to any jobsite.

If an employee has been in close contact to a person with suspected or confirmed COVID-19, they should immediately isolate themselves from other employees and contact the Human Resources Department for further instruc�ons.

8.0 VISITORS

All visitors will be required to complete a self-declara�on form, similar to Appendix A, prior to entering any Company loca�on. Entry to any Company loca�on will be denied if any ques�ons are answered affirma�vely (“yes”).

9.0 CONTRACTORS AND SERVICE PROVIDERS

Contractors and service providers must have their own writen infec�ous disease preparedness and response plan. Their plan should include at a minimum:

• Requirements that meet and remain current with the CDC, OSHA, and other applicable standards and guidance

• Iden�fy roles and responsibili�es, including the individual responsible for managing the plan, documen�ng employee self-declara�on surveys, and assessment of employees exhibi�ng symptoms (using forms found in Appendix A and Appendix B, or similar forms)

• Requirements for writen clearance to return to work from a physician for any employee who has received care for COVID-19

• Requirements for managing employee return to work if self-quaran�ned due to symptoms that follow the CDC’s guidance “Discon�nua�on of Home Isola�on for Persons with COVID-19”

• Requirements to contact public health officials for guidance regarding ac�ons or precau�ons that should be taken for poten�ally exposed coworkers

• Requirements for sanita�on a�er a confirmed or suspected contamina�on of vehicles, worksites, equipment, etc.

• Comple�on of a self-declara�on form (Appendix A or similar) prior to entering any Company loca�on

o Entry to any Company loca�on will be denied if any ques�ons are answered affirma�vely (“yes”)

o Contractors are required to resubmit self-declara�ons at the discre�on of management or if circumstances change, resul�ng in “yes” responses

Contractors and service providers shall ensure all subcontractors, sub-suppliers, and sub-service providers who will enter Company loca�ons meet the requirements of the contractor’s COVID-19 preparedness and response plan

If a contractor or service provider employee tests posi�ve for COVID-19, exhibits COVID-19 symptoms, or has been in close contact with a person with suspected or confirmed COVID-19, the contractor or service provider must remove and isolate the employee from the worksite.

Contractors and service providers must immediately report to their Company representa�ve:

• The removal of an employee or subcontractor who is suspected to have COVID-19

• Any knowledge that an individual has been diagnosed or quaran�ned due to COVID-19 exposure

Contractors and service providers must follow the most current guidance from the CDC for “Discon�nua�on of Home Isola�on for Persons with COVID-19” prior to allowing such employees to return to the Company loca�on. At minimum, unless they are cleared by a healthcare professional, they must self-isolate for 14 days and be free from symptoms of COVID-19 to be permited to return to Company loca�ons.

10.0 GENERAL PRACTICES

Prior to the commencement of work, throughout the workday as appropriate, and at the end of each workday, employee, contractor, and visitor tools and equipment should be wiped down with an appropriate cleaning product as designated by the EPA. Use the EPA suggested cleaning products (e.g., Clorox Mul� Surface Cleaner + Bleach, Clorox Disinfec�ng Wipes, Clorox Commercial Solu�ons Clorox Disinfec�ng Spray, Lysol Brand Heavy-Duty Cleaner Disinfectant Concentrate, Lysol Disinfectant Max Cover Mist, Purell Professional Surface Disinfectant Wipes, SaniPrime Germicidal Spray) to wipe down commonly used surfaces, including:

• Job trailers

• Shared tools

• Fuel pumps

• Shared vehicle surfaces

• Bathroom facili�es

Employees, contractors, and visitors should follow these general prac�ces to help prevent exposure to COVID-19:

• Frequently wash hands with soap and water for at least 20 seconds

• If soap and running water are not available, use an alcohol-based hand rub that contains at least 60% alcohol.

• Avoid touching eyes, nose, or mouth with unwashed hands.

• Avoid close contact with people who are sick

11.0 REVIEW

This plan shall be reviewed at least once a year or as otherwise necessary to maintain best pandemic prac�ces. In addi�on to CDC and WHO recommenda�ons, the Company will review informa�on provided by employees and third par�es to ensure ac�on plans are appropriately implemented and followed. During the annual review, management will assess opera�ons during a pandemic and plan effec�veness, including incorpora�ng lessons learned following a pandemic. This review will consist of management, with the assistance of reported informa�on, and may result in writen, internal recommenda�ons and changes to this plan.

APPENDIX A Self-Declara�on

Have you returned from any of the countries listed on the CDC website as the highest risk of transmission (China, Iran, most of con�nental Europe, and/or South Korea)?

Have you had close contact with or cared for someone diagnosed with COVID-19 within the last 14 days?

Have you experienced any cold or flu-like symptoms (fever, cough, sore throat, respiratory illness, and/or difficulty breathing) in the last 14 days?

Have any of your family members or close contacts experienced any of the following symptoms (fever, cough, sore throat, respiratory illness, and/or difficulty breathing) in the last 14 days?

Yes No

Yes No

Yes No

Yes No

APPENDIX B

What is your full name and posi�on?

Where are you from?

Who is your manager?

Where have you worked in the past 14 days?

What symptom(s) have you experienced?

Where did you first experience the symptoms?

Have you been in contact with anyone experiencing these symptoms?

Are you rooming or staying in the same domicile as other crew members or project employees?

Have you contacted a medical professional?

INJURY AND ILLNESS RECORDKEEPING

1.0 PURPOSE

The purpose of this program is to establish standards for recording IT Landes, hereina�er referred to as “the Company,” injuries and illnesses and to comply with applicable regulatory requirements.

2.0 SCOPE

This program applies to all employees on all Company or client facili�es.

3.0 RESPONSIBILITIES

Safety Manager

• Implement this program and make supervisors aware of the requirements.

• Maintain all records pertaining to this program.

Supervisors

• Ensure that all work-related injuries and illnesses are promptly reported to the safety manager.

• Become familiar with the requirements of this program.

Employees

• Ensure that all work-related injuries and illnesses are immediately reported to the supervisor

4.0 PROCEDURE

Writen records of all work-related injuries, illnesses, and fatali�es must be kept ensuring accurate recordkeeping procedures. Therefore, the Company shall:

• Use the following instruc�ons and forms to record injuries and illnesses: htps://www.osha.gov/recordkeeping/forms.

• Record all injuries or illnesses on the OSHA 300 Log within 7 calendar days of receiving informa�on that the injury or illness occurred.

• Maintain OSHA 300 records for at least 5 years as per the OSHA recordkeeping requirements

The OSHA Form 300A shall be reviewed and signed by a Company official.

5.0 POSTING REQUIREMENTS

The Company shall post the OSHA Form 300A in a conspicuous place that is easily accessible and available to employees such as a lunchroom, �me clock area, or other effec�ve common area from February 1 through April 30 as per the OSHA recordkeeping requirements.

If the posted OSHA Form 300A is defaced, altered, or otherwise unreadable, it shall be replaced so that employees can effec�vely read the informa�on on the form.

Electronically post the OSHA 300A by March 1.

• Create an ITA account.

• Create a Login.gov account.

• Create an establishment.

• Manually add 300A summary data.

• Upload a batch file.

• Submit establishment 300A data.

• View API token.

• View, edit, inac�vate an establishment.

JOB COMPETENCY

1.0 PURPOSE

The purpose of this program is to outline basic job competency expecta�ons and guidelines for all employees and contractors performing work on behalf of IT Landes, hereina�er referred to as “the Company.”

2.0 RESPONSIBILITIES

Safety Officer

• Ensure that all personnel performing work on behalf of the Company possess a sufficient level of competency for the task.

• Maintain records of safety training and any applicable cra� skill cer�fica�ons and/or licenses for the task.

Supervisors

• SOP and job-specific orienta�on training

• Administer toolbox talks safety mee�ngs.

• Observe and monitor crew members to ensure job competency.

• Reassign any worker not competent for assigned task

3.0 POLICY

This program is in place to help ensure that all team members are capable of safely and successfully comple�ng the tasks required by their job du�es. Management roles, responsibili�es, and expecta�ons are vital to a safe and healthy workplace and to the training and monitoring of staff. To that end, the Company has established a corporate organiza�onal chart that clearly explains job �tles.

A determina�on will be assessed by management as to the minimum qualifica�ons required to perform each role. Employees found to be deficient in job-related competencies will be assigned an alternate task un�l they exhibit adequate experience. The safety officer will ensure that all employees are qualified and competent for the job �tle they hold and for the tasks/work with which they are engaged through a combina�on of educa�on and work experience.

The safety officer and the Human Resources Department will maintain records of all job descrip�ons. All employees are required to sign a job-specific acknowledgement form sta�ng that they are able to safely and successfully complete all of the tasks listed for their posi�on. Documenta�on is acquired from employees prior to ini�al assignment as proof that they are qualified to perform their job du�es should be established.

4.0 TRAINING

Employee involvement in safety training can only be successful when everyone on the site receives sufficient training to understand their safety responsibili�es, opportuni�es, and how to fulfill them.

All new employees will receive a minimum of 2 hours of safety orienta�on training and review prior to job assignment. Job-specific training must be provided for new or transferred employees. All employees must be trained on the tasks they perform on a regular basis.

A competent person (supervisor, lead hand, etc.) must verify that an employee is competent to perform their roles and responsibili�es before being allowed to work independently.

Orienta�on training will include the following:

• General safety requirements

• Hazard recogni�on

• Incident inves�ga�on/repor�ng

• General job descrip�on and job requirements

• Emergency ac�on plan(s)

• Hazard communica�on

• Motor vehicle opera�on

• Personal protec�ve equipment

• Substance abuse policy and program

This training further extends throughout employment to include weekly toolbox safety mee�ngs, competent persons safety training, and cer�fica�on safety training as needed.

5.0 ON-THE-JOB TRAINING (SOP)

Team trainers are on each crew and to complete new hire and on the job training. Documenta�on all of the equipment training and any other necessary training required that is crew-specific will be retained for a period of 3 years in the corporate office.

6.0 TOOLBOX TALKS

Regular, documented safety topics that are industry-specific will be held perpetually to ensure that employees are always aware of how to avoid hazards. Supervisors are responsible for administering toolbox talks and are trained to encourage crew par�cipa�on and rela�ng toolbox talks to current jobsites. All forms must be signed by all affected and present team members.

JOB HAZARD ANALYSIS

Weekly job-task-specific topics are analyzed by job steps, hazards are iden�fied, and hazard elimina�on controls are discussed and reviewed. Supervisors are responsible for administering the job hazard analysis and are trained to encourage par�cipa�on. All forms must be signed by all affected and present team members.

7.0

JSA AND HAZARD IDENTIFICATION

1.0 PURPOSE

The purpose of this document is to outline the job safety analysis (JSA) and hazard iden�fica�on plan for IT Landes, hereina�er referred to as “the Company.” A JSA, simply put, is a method to iden�fy exis�ng and/or poten�al hazards of a job. Each task undergoing a JSA will be studied, and each step of the job will be recorded so that the en�re job process is considered. Then hazards and/or poten�al hazards are more easily iden�fied and the best way to reduce or eliminate those hazards can be determined.

2.0 SCOPE

This program applies to all work conducted on Company commercial projects, client repair loca�ons, and at any other client sites where tasks are performed. JSAs will be performed in areas where jobs or tasks may require an evalua�on of hazard poten�al and a determina�on of protec�ve controls prior to the implementa�on of personal protec�ve equipment (PPE) requirements.

3.0 RESPONSIBILITIES AND PROCESS Management

• Ensure that all jobs and tasks have been evaluated and hazards are addressed. Where possible, hazards will be controlled before the use of PPE is implemented.

• Eliminate products or processes that generates the hazard.

• Subs�tute less or non-hazardous material or chemical engineering methods such as ven�la�on or guarding.

• Select the appropriate administra�ve controls, such as procedures or task rota�on, to reduce or eliminate hazards based on the types of tasks or ac�vi�es being performed.

• Write opera�ng procedure for tasks or ac�vi�es that require controls or control requirements in exis�ng work and task procedures.

• Maintain control measures and equipment.

• Assess the need for con�nued or addi�onal use of measures and their requirements at least once a year. These assessments should be documented as proof that controls are or not required for certain tasks or ac�vi�es. Documenta�on in the procedure is adequate to fulfill this need; however, any specific tes�ng or monitoring results will need to be documented and maintained separately.

• Ensure that all JSAs are retained at the corporate headquarters for a minimum of three years.

Employees

• Follow established procedures.

• Assist in providing assessment and documenta�on of job hazards as needed or required.

• Conduct JSAs at jobsites prior to the commencement of all tasks. All JSAs must be handwriten. No prepopulated JSAs will be used. All employees must take place in the JSA process and sign off that they understand the hazards and mi�ga�ons put into place.

Safety Employees

• Assist in the implementa�on of the JSA process

JSA Team

• Verify the JSA steps and viability of recommenda�ons.

• Select the correc�ve ac�ons that will be implemented.

• Track correc�ve ac�ons to ensure they are completed

• Ensure correc�ve ac�ons provide the appropriate level of safety do not create addi�onal hazards.

• Determine if procedures, checklists, training, etc. require upda�ng based on recommended correc�ve ac�ons.

4.0 PROCEDURE

Hazard Evalua�on and Determina�on

• Ensure JSAs have been completed. JSAs should be documented to facilitate a later review of the process or ac�vity hazards.

• JSAs shall be performed in all areas to iden�fy hazards that require the use of hazard controls, including PPE requirements. Priority may be given to areas or tasks with higher injury or risk poten�al.

• JSAs or other hazard assessments must be completed before all tasks (tasks not evaluated as part of the current hazard assessments) are started, before changes are made to opera�ng procedures, and when incidents result from inadequate controls or PPE.

5.0 SAFETY INFORMATION

JSAs assist in providing early recogni�on of hazards that may cause injury, occupa�onal illness, or environmental harm. Although all jobs and tasks eventually undergo a JSA, any higher hazard jobs should be priori�zed to reduce the likelihood of injury or illness.

The first priority should be jobs where injuries have previously occurred, or those that have a high frequency of injury, illness, environmental harm, or equipment damage. The second priority should be jobs that have a high poten�al for accidents due to the frequent use of hazardous materials or equipment, or those that have a history of near misses. The third priority should be jobs or tasks that involve the introduc�on of new equipment, tools, chemicals, or materials, or those that have changes in the process of how to perform the job or have regula�ons that guide the method in which the job is performed.

JSA Team

• JSAs should be a team effort and normally involve more than one person; however, in a small business se�ng, two or three people may be sufficient to perform the JSA.

• The most experienced person who performs a job should be on the JSA team. This person has the most familiarity with the job, how it is performed, and any hazards associated with the job. Other operators who may perform the task differently may also be included, as well as any new operators who can bring a “fresh set of eyes” and a different perspec�ve to the JSA.

• Supervisors should be included, as they may know of poten�al workplace changes that can affect the job and can usually provide any funding needed for recommended changes.

• Maintenance staff that service and repair any equipment should be included.

• If available, any technical experts (e.g., safety, engineers, environmental specialists) may be included as they generally have understanding and knowledge of any regula�ons that may affect the job and how they are implemented.

Where to Perform JSAs

• The best place to perform JSAs is at the workplace where the job is performed. By doing the JSA on-site, no steps will be overlooked, workplace condi�ons (ligh�ng, noise, layout, etc.) can be assessed, and

recommenda�ons for changes may be more readily implemented. If possible, the team should watch the job being performed so they can understand the sequence and significance of each step.

• JSAs can be more limited in scope and the job can be reviewed verbally. This is usually done when the job cannot be performed first, it is not a rou�ne job, it is one part of a larger job sequence, or the workplace condi�ons are not conducive to observing the job.

Conduc�ng the JSA

• JSAs will be conducted for all ac�vi�es regardless of the level of risk.

• List the basic job steps. Nearly every job can be broken down into steps. Each step should be observed by the JSA team. The steps and reasons they are included should be discussed so that everyone understands them. The steps should be listed in order of performance. Ac�on words should be used to describe the steps and they should be numbered sequen�ally. There are typically between 3 and 12 steps in a JSA. If there are fewer, then the scope of the JSA is too broad and some hazards may be overlooked. If there are more than 12 steps, then the JSA is too detailed and the JSA team may get “bogged down” with more than they need.

• Determine the poten�al hazards Hazards are determined by asking ques�ons such as:

o Can the employee receive a strain or sprain due to bending, twis�ng, or while performing any of the steps?

o Can the employee receive a crushing injury (e.g., be caught in or on equipment)?

o Can the employee receive a burn or irrita�on due to contact with heat or other physical or biological hazards?

o Could a chemical or material release occur?

• List the exis�ng and poten�al hazards.

• Make recommenda�ons to reduce, eliminate, and control hazards Where possible, eliminate the hazard or subs�tute a non-hazardous material or condi�on that achieves quality results. Where hazards cannot be eliminated, apply engineering controls (barriers, interlocks, tools, etc.) that can reduce or eliminate hazardous condi�ons. Where elimina�on and engineering are not feasible, apply administra�ve controls (procedures, training, limit the exposure �me, etc.) to the tasks. Where all the previous controls cannot provide hazard reduc�on, PPE (e.g., gloves, respirators, specialized clothing) should be considered PPE should be the last control considered. Remember that PPE frequently requires specialized training, cleaning, or maintenance, and records may need to be kept. Refer to the PPE program.

• Make recommenda�ons for every hazard iden�fied, beginning with the first hazard listed. Several recommenda�ons may be made for one hazard, bearing in mind that one or more may not be feasible, cost effec�ve, or �mely. Number each recommenda�on in accordance with its hazard. Recommenda�ons should be specific (e.g., what type of gloves, what specific material will be subs�tuted). If exis�ng controls may already control or eliminate some hazards, be sure to list these so they do not get changed and make the hazardous situa�on worse. Where needed, consider that some regula�ons require specific types of controls to be put in place, and if they are prescribed, they may not be the most feasible or economical to implement.

• Once the JSA is complete, it must be reviewed with all employees performing the work and all affected personnel on-site prior to entering the work area or commencing work.

• At a minimum, the JSA must be reviewed and changed if the following occur:

o Job scope changes

o New personnel are added to the workplace

o Site condi�ons change

o Stop work authority occurs

o Hazards concerns are raised by any employee

o Any incident or near miss

• All employees par�cipa�ng in JSAs require training in the techniques used.

• All employees will be trained in the JSA and hazard iden�fica�on process at new hire orienta�on.

• JSA audits will be performed to review the competency of those comple�ng JSAs.

LADDER SAFETY

1.0 PURPOSE

The purpose of this document is to outline the ladder safety program for IT Landes, hereina�er referred to as “the Company.” This program will establish guidelines for the safe use of ladders throughout worksites by employees, personnel, and contractors.

This safety policy and procedure is established in accordance with 29 CFR 1910.25-27 (Occupa�onal Health and Safety Standards for General Industry) and 29 CFR 1926.1053 (Occupa�onal Health and Safety Standards for Construc�on Industry).

2.0 RESPONSIBILITIES

Managers/Unit Heads

• Ensure that adequate funds are available and budgeted for the purchase of ladders in their areas.

• Obtain and coordinate the required training for the affected employees

• Ensure compliance with this program through their audi�ng process

Supervisors

• Ensure that all ladders (fixed and portable) are regularly inspected and properly maintained.

• Tag ladders in need of repair and remove defected ladders from service for repair or destruc�on

• Audit this program for compliance during their facility and jobsite audits.

Employees

• Comply with all applicable guidelines contained in this program.

• Immediately report suspected unsafe condi�ons or ladders to their supervisor

• Inspect ladders before use and keep ladders clean and in good condi�on.

Safety Officer

• Assist managers/unit heads, supervisors, or other, if applicable, with any mater concerning this program.

• Assist in developing and securing of required training

• Provide consulta�ve and audit assistance to ensure effec�ve implementa�on of this program.

• Work with the Purchasing Department to ensure that all newly purchased ladders comply with this program and current safety regula�ons.

3.0 POLICY

4.0 TRAINING

Employees using the ladders shall be trained in:

• The proper use of the ladders

• What kind of ladder(s) to use

• How to set up ladders

• Ladder inspec�on

• Proper maintenance

This training shall be done upon ini�al employment and/or job assignment. Refresher training shall be provided to employees at the discre�on of their supervisor.

5.0 LADDER HAZARDS AND SAFE USE

Ladder Hazards

There are inherent hazards associated with ladder use. Typical ladder hazards include:

• Insufficient surface resistance on ladder rungs and steps

• Ladder structural failure

• Ladders �pping sideways, backwards, or slipping out at the botom

• Ladder spreaders not fully opened and locked, causing the ladder to “walk,” twist, or close up when a load is applied to the ladder

• Using metal ladders around electricity

• Using deteriorated ladders

• Using fixed ladders without cages or fall protec�on

Safe Use

Employees should follow certain rules when placing, ascending, and descending ladders which include:

• Hold on with both hands when going up or down. If material must be handled, raise or lower it with a rope before going down or a�er climbing to the desired level.

• Always face the ladder when ascending or descending.

• Never slide down a ladder.

• Keep ladders clean and free from dirt and grease.

• Ensure shoes are not greasy, muddy, or slippery before climbing.

• Do not climb higher than the third rung from the top on straight or extension ladders, or the second tread from the top on stepladders. Never stand on the top two rungs of a stepladder.

• Carry tools on a tool belt (not in the hand) and never carry objects that could cause injury in the event of a fall.

• Never lean too far to the sides. Keep the belt buckle within the side rails.

• Use a 4 to 1 ra�o when leaning a single or extension ladder. Place a 12-foot ladder so that the botom is 3 feet away from the object the ladder is leaning against.

• Inspect the ladder for defects before use.

• Never use a defec�ve ladder. Tag or mark it so that it will be repaired or destroyed.

• Never splice or lash a short ladder together.

• Never use makeshi� ladders such as cleats fastened across a single rail.

• Ensure that stepladders are fully open and metal spreaders are locked before climbing.

• Never use ladders during a strong wind except in an emergency and then only when they are securely fastened.

• Never leave placed ladders unatended.

• Never use ladders as guides, braces, or skids, or for any other purpose other than their intended purposes.

• Never atempt to adjust a ladder while a user is standing on the ladder.

• Never jump from a ladder. Always dismount from the botom rung.

• Ladders shall not be loaded beyond the maximum intended load for which they were built nor beyond the manufacturer’s rated capacity.

• Ladders shall be used only for the purpose for which they were designed. Never use ladder in a horizontal posi�on or as scaffolding. Do not place ladders on top of boxes, barrels, crates, etc.

• Ladders shall be used at an angle such that the horizontal distance from the top support to the foot of the ladder is approximately one-quarter of the working length (the distance along the ladder between the foot and the top support) of the ladder.

6.0 LADDER SAFETY DEVICES

Safety devices are available for both portable and fixed ladders to prevent a climber from falling. Safety devices for portable ladders include slip-resistant bases, safety tops, and any other device to increase the ladder stability. A portable ladder posi�oned at a loca�on where it may be �pped over by work ac�vi�es shall be securely fastened at the botom and top. Safety devices for fixed ladders include cages, which enclose the stairwell, or a restraint belt atached to a sliding fixture anchored to the ladder.

7.0 LADDER INSPECTION

Ladders shall be inspected by a competent person for visible defects on a periodic basis and a�er any occurrence that could affect their safe use.

An inspec�on program should be set up by which all ladders are inspected once every three months. Appendix B presents a general inspec�on form. Ladders that are weak, improperly repaired, damaged, have missing rungs, or appear unsafe shall be removed from service for repair or disposal. Before discarding a wood ladder, cut it up so no one can use it again. Tag any ladders that have developed defects “DANGEROUS DO NOT USE,” and remove from service for repair or disposal.

Portable ladders must be maintained in good condi�on at all �mes and inspected frequently. For portable wood ladders, all wood parts shall be free from sharp edges and splinters, and sound and free from shake, wane, compression failures, decay, or other irregulari�es observed during accepted visual inspec�ons. For portable metal ladders, the design shall be without structural defects or accident hazards such as sharp edges, burrs, etc. The selected metal shall be of sufficient strength to meet the test requirements and shall be protected against corrosion.

For fixed ladders, all wood parts shall meet the criteria of wood ladders and all metal parts shall meet the criteria of metal ladders.

8.0 MAINTENANCE

Portable wood ladders may be coated with a water-repellent preserva�ve to provide a suitable protec�ve material. Metal ladders and metal parts on wood ladders should be corrosion-resistant and kept free from nicks. If nicks occur, they should be promptly treated to prevent possible metal fa�gue due to rust.

Portable and fixed ladders with structural defects, such as, but not limited to, broken or missing rungs, cleats, or steps, broken or split rails, corroded components, or other faulty or defec�ve components, shall immediately be marked in a manner that readily iden�fies them as defec�ve or tagged with “DO NOT USE” or similar language, and shall be withdrawn from service un�l repaired.

The ladder side rails shall extend at least 3 feet above the upper landing surface. When ladders are not able to be extended, the top of the ladder shall be secured to a rigid support that will not deflect.

9.0 LADDER INSPECTION CHECKLISTS

All Ladders

• Loose steps or rungs are considered loose if they can be moved at all with the hand

10.0

• Loose nails, screws, bolts, or other metal parts

• Cracked, split, or broken uprights, braces, steps, or rungs

• Slivers on uprights, rungs, or steps

• Damaged or worn non-slip bases

• Rusted or corroded spots

Ladders used by employees must meet OSHA and ANSI specifica�ons. Ladder rungs, cleats, and steps shall be parallel, level, and uniformly spaced when the ladder is in posi�on.

Stepladders

• Wobbly from side strain

• Loose hinges

• Loose or bent hinge spreaders

• Broken stop on hinge spreaders

• Broken, split, or worn steps

Extension Ladders

• Loose, broken, or missing extension locks

• Defec�ve locks that do not seat properly when the ladder is extended

• Deteriora�on of rope from exposure to weather, acid, or other destruc�ve agents

Fixed Ladders

• Loose, worn, or damaged rungs or side rails

• Damaged or corroded parts of cage

• Corroded bolts or rivet heads on inside of metal stacks

• Damaged or corroded handrails or brackets on pla�orms

• Weakened or damaged rungs on brick or concrete slabs

• Obstructed ladder base

DEFINITIONS

Cage: A guard that may be referred to as a cage or basket guard, which is an enclosure that is fastened to the side rails of the fixed ladder or to the structure to encircle the climbing space of the ladder for the safety of the person who must climb the ladder.

Extension Ladder: A non-self-suppor�ng portable ladder adjustable in length. It consists of two or more sec�ons traveling in guides or brackets and is arranged to permit length adjustment. Its size is designated by the sum of the lengths of the sec�ons measured along the side rails.

Fixed Ladder: A ladder permanently atached to a structure, building, or equipment.

Individual-Rung Ladder: A fixed ladder where each rung is individually atached to a structure, building, or equipment.

Ladder: An appliance usually consis�ng of two side rails joined at regular intervals by cross-pieces called steps, rungs, or cleats, on which a person may step in while ascending or descending.

Ladder Safety Device: A device, other than a cage or well, designed to eliminate or reduce the possibility of accidental falls and that may incorporate such features as life belts, fric�on brakes, and sliding atachments.

Pitch: The included angle between the horizontal and the ladder, measured on the opposite side of the ladder from the climbing side.

Pla�orm Ladder: A self-suppor�ng ladder of fixed size with a pla�orm provided at the working level. The size is determined by the distance along the front rail from the pla�orm to the base of the ladder.

Rail Ladder: A fixed ladder consis�ng of side rails joined at regular intervals by rungs or cleats and fastened in full length or in sec�ons to a structure, building, or equipment.

Railings: Any one or combina�on of the railings constructed in accordance with OSHA 1910.23. A standard railing is a ver�cal barrier erected along exposed edges of floor openings, wall openings, ramps, pla�orms, and runways to prevent falls of persons.

Rungs: Circular or oval cross-pieces of a ladder on which a person may step on while ascending or descending.

Sec�on Ladder: A non-self-suppor�ng portable ladder, non-adjustable in length, consis�ng of two or more sec�ons of ladder so constructed that the sec�ons may be combined to func�on as a single ladder. Its size is designated by the overall length of the assembled sec�ons.

Side-Step Ladder: A ladder in which an individual ge�ng off at the top must step sideways in order to reach the landing.

Single Ladder: A non-self-suppor�ng portable ladder, non-adjustable in length, consis�ng of one sec�on. Its size is designated by the overall length of the side rail.

Special-Purpose Ladder: A portable ladder which represents either a modifica�on or combina�on of design or construc�on features in one of the general-purpose types of ladders previously defined, in order to adapt the ladder to special or specific uses.

Stepladder: A self-suppor�ng portable ladder, non-adjustable in length, having flat steps and a hinged back. Its size is designated by the overall length of the ladder measured along the front edge of the side rails.

Steps: Flat cross-pieces of a ladder on which a person may step on while ascending or descending.

Through Ladder: A ladder in which an individual ge�ng off at the top must step through in order to reach the landing.

Well: A permanent, complete enclosure around a fixed ladder, which is atached to the walls of the well. Proper clearances for a well will give the person who must climb the ladder the same protec�on as a cage.

LEAD AWARENESS

1.0 PURPOSE

The purpose of this document is to outline the lead awareness safety policy for IT Landes, hereina�er referred to as “the Company.” The objec�ve of this program is to protect employees from lead contamina�on and to comply with OSHA 29 CFR 1910.1025.

2.0 RESPONSIBILITIES

Safety Officer

• En�re lead safety program, including semi-annual revisions and updates to reflect the current status of the program.

• Engineering and administra�ve controls for lead exposure.

• Employee training and awareness

• Medical surveillance program administra�on.

• Respiratory protec�on program administra�on as it relates to lead.

• Lead disposal program

• Housekeeping program

• Protec�ve clothing issuance, storage, and disposal.

Management

• Provide effec�ve and con�nuous control of all lead opera�ons

• Immediately inform management of any deficiencies in engineering or administra�ve controls.

• Conduct rou�ne assigned inspec�ons and monitoring.

• Immediately correct any devia�on from opera�onal safety requirements

• Provide immediate on-the-spot training for any employee who shows lack of knowledge or applica�on of required opera�onal lead safety requirements.

• Ensure all employees are properly trained before commencing any opera�on that may contribute to lead exposure.

Employees

• Follow all opera�onal and lead safety procedures

• Seek immediate supervisor guidance to resolve ques�ons.

• Conduct opera�ons in accordance with Company-provided training.

• Immediately report to a supervisor any deficiency in engineering or administra�ve controls

• Properly use, store, and dispose of issued and assigned personal protec�ve clothing.

• Maintain change and shower areas and ensure they are neat and orderly.

• Abide by any signs, labels, and assessment reports indica�ng the presence of lead-containing materials and follow appropriate work prac�ces to ensure the lead-containing materials are not disturbed

3.0 POLICY

4.0 HAZARDS

Pure lead (Pb) is a heavy metal at room temperature and pressure and is a basic chemical element. It can combine with various other substances to form numerous lead compounds. The permissible exposure limit (PEL) set by OSHA is 50 micrograms of lead per cubic meter of air (50 µg/m3) averaged over an 8-hour period.

Lead can be absorbed by inhala�on (breathing) and inges�on (ea�ng). Lead is not absorbed through skin. When lead is scatered in the air as a dust, fume, or mist, it can be inhaled and absorbed through the lungs and upper respiratory tract. Lead can also be absorbed through the diges�ve system if swallowed. Handling food, cigaretes, chewing tobacco, or makeup which have lead contamina�on or handling them with contaminated hands will contribute to inges�on.

A significant por�on of inhaled or ingested lead goes into the blood stream. Once in the blood stream, lead is circulated throughout the body and stored in various organs and body �ssues. Some of this lead is quickly filtered out of the body and excreted, but some remains in the blood and other �ssues. As lead exposure con�nues, the amount stored in the body will increase. Lead stored in body �ssues can cause irreversible damage, first to individual cells, then to organs and whole-body systems.

Some possible loca�ons of lead-containing materials are leaded paints, solders, pipes, bateries, circuit boards, cathode ray tubes, glass, and demoli�on/salvage materials.

5.0 SHORT-TERM EFFECTS OF OVEREXPOSURE TO LEAD

Lead is a potent, systemic poison. Taken in large enough doses, lead can cause death in a mater of days. Acute encephalopathy, a condi�on affec�ng the brain, may arise and quickly lead to seizures, coma, and death from cardiorespiratory arrest. There is no sharp dividing line between rapidly developing short-term (acute) effects of lead and chronic effects, which take longer to acquire. Lead adversely affects numerous body systems and causes forms of health impairment and disease, which arise a�er periods of exposure as short as days or as long as several years. Common symptoms of acute lead poisoning are loss of appe�te, nausea, vomi�ng, stomach cramps, cons�pa�on, difficulty sleeping, fa�gue, moodiness, headache, muscle and joint aches, and anemia.

6.0 LONG-TERM EFFECTS OF OVEREXPOSURE TO LEAD

Long-term (chronic) overexposure to lead may result in severe damage to blood-forming, nervous, urinary, and reproduc�ve systems. Common symptoms of chronic overexposure to lead include loss of appe�te, metallic taste in the mouth, pallor, nausea, cons�pa�on, insomnia, excessive �redness, weakness, anxiety, nervousness, irritability, headache, muscle and joint pain or soreness, fine tremors, numbness, dizziness, hyperac�vity, and colic. In lead colic there may be severe abdominal pain.

7.0 MONITORING

Ini�al Determina�on

The Company has made an ini�al determina�on of lead work areas and exposure levels and will conduct subsequent “ini�al determina�ons” in the event of changes to hazard control methods or opera�onal processes that affect employee or environmental exposure. Ini�al determina�ons are conducted to determine if any employee may be exposed to lead at or above the ac�on level of 30 µg/m3 averaged over an 8-hour period.

The Company shall maintain a writen record when a determina�on is made that no employee is exposed to airborne concentra�ons of lead at or above the ac�on level. The record shall include quan�ta�ve sampling data, date of determina�on, loca�on within the worksite, and the name and social security number of each employee monitored.

Monitoring Requirements

• Monitoring and analysis methods shall have an accuracy (to a confidence level of 95%) of no less than plus or minus 20% for airborne concentra�ons of lead equal to or greater than 30 µg/m3 .

• The Company shall conduct monitoring which is representa�ve of the exposure for each employee in the workplace or process area who is exposed to lead when a determina�on shows the possibility of any employee exposure at or above the ac�on level

• For the purposes of monitoring requirements, employee exposure is that which would occur if the employee were not using a respirator.

• Monitoring and sample collec�on shall cover full-shi� (for at least seven con�nuous hours) personal samples including at least one sample for each shi� for each job classifica�on in each work area.

• Full-shi� personal samples must be representa�ve of the monitored employee’s regular, daily lead exposure

8.0 MONITORING FREQUENCY

Blood sampling and monitoring will be conducted every six months un�l two consecu�ve blood samples and analysis are acceptable. The sampling and monitoring will be performed at least once a month during the removal period. Any employee with elevated blood levels will be temporarily removed. Within five working days, employees will be no�fied in wri�ng of lead levels that are not acceptable. The standard requires temporary medical removal with medical removal protec�on benefits.

At or Above Ac�on Level and Below PEL

Every six months, the ini�al determina�on or subsequent monitoring reveals employee exposure to be at or above the ac�on level but below the PEL. Six-month monitoring will con�nue un�l at least two consecu�ve measurements, taken at least seven days apart, are below the ac�on level.

Above

PEL

If the ini�al monitoring reveals that employee exposure is above the PEL, the Company will repeat monitoring quarterly. Quarterly monitoring will con�nue un�l at least two consecu�ve measurements, taken at least seven days apart, are below the PEL but at or above the ac�on level.

Addi�onal Monitoring

Addi�onal monitoring will be conducted whenever there has been a produc�on, process, control, or personnel change which may result in new or addi�onal lead exposure, or whenever any other reason to suspect a change which may result in new or addi�onal exposures to lead.

9.0 EMPLOYEE NOTIFICATION OF MONITORING RESULTS

Within five working days a�er the receipt of monitoring results, each employee will be no�fied in wri�ng of the results which represent their exposure.

Whenever the results indicate that the representa�ve employee exposure, without regard to respirators, exceeds the PEL, the writen no�ce will include a statement that the PEL was exceeded, and a descrip�on of the correc�ve ac�on taken or to be taken to reduce exposure to or below the PEL.

10.0 OBSERVATION

The Company will provide affected employees or their designated representa�ves an opportunity to observe any monitoring of employee lead exposure

Observa�on Procedures

Whenever observa�on of the monitoring of employee lead exposure requires entry into an area where the use of respirators, protec�ve clothing, or equipment is required, the Company will provide the observer with and ensure the use of required respirators, clothing, and equipment, and will require the observer to comply with all other applicable health and safety procedures.

Without interfering with the monitoring, observers are en�tled to:

• Receive an explana�on of the measurement procedures

• Observe all steps related to the monitoring of lead performed at the place of exposure.

• Record the results obtained or receive copies of the results when returned by the laboratory.

11.0 ENGINEERING CONTROLS

Where any employee is exposed to lead above the PEL for more than 30 days per year, the Company will implement feasible engineering and work prac�ce (including administra�ve) controls, to reduce and maintain employee lead exposure

Wherever the engineering and work-prac�ce controls, which can be ins�tuted, are not sufficient to reduce employee exposure to or below the PEL, the Company will s�ll use them to reduce exposures to the lowest feasible level and shall supplement them by the use of respiratory protec�on.

Where any employee is exposed to lead above the PEL, but for 30 days or less per year, the Company will implement engineering controls to reduce exposures to 200 µg/m3, but thereina�er may implement any combina�on of engineering, work prac�ce (including administra�ve), and respiratory controls to reduce and maintain employee lead exposure to or below 50 µg/m3 .

12.0 MECHANICAL VENTILATION

When ven�la�on is used to control exposure, measurements which demonstrate the effec�veness of the system in controlling exposure, such as capture velocity, duct velocity, or sta�c pressure, shall be made at least once every three months. Measurements of the system’s effec�veness in controlling exposure shall be made within five days of any change in produc�on, process, or control which might result in a change in employee lead exposure.

Air Recircula�on

If air from exhaust ven�la�on is recirculated into the workplace, the system must include:

• A high-efficiency filter with reliable backup filter

• Controls to monitor the concentra�on of lead in the return air and to bypass the recircula�on system automa�cally if it fails are installed, opera�ng, and maintained

13.0 ADMINISTRATIVE CONTROLS

If administra�ve controls are used as a means of reducing employees �me-weighted average (TWA) lead exposure, the Company shall establish and implement a job rota�on schedule which includes:

• Name or iden�fica�on number of each affected employee

• Dura�on and exposure levels at each job or worksta�on where each affected employee is located

• Other informa�on which may be useful in assessing the reliability of administra�ve controls to reduce lead exposure

Administra�ve control informa�on and records will be maintained as an addendum to this writen program.

14.0

RESPIRATORS

When respirators are used to supplement engineering, work-prac�ce controls to comply with the PEL, and all other requirements have been met, employee exposure, for the purpose of determining compliance with the PEL, may be considered to be at the level provided by the protec�on factor of the respirator for those periods that the respirator is worn. Those periods may be averaged with exposure levels during periods when respirators are not worn to determine the employee’s daily TWA exposure. The respiratory protec�on program will be conducted in accordance with 29 CFR 1910.134 (b) through (d) (except (d)(1)(iii)) and (f) through (m). The Company will provide a powered air-purifying respirator when an employee chooses to use this type of respirator and such a respirator provides adequate protec�on to the employee.

Respirators must be used during:

• Periods necessary to install or implement engineering or work-prac�ce controls

• Work opera�ons for which engineering or work-prac�ce controls are not sufficient to reduce employee exposures to or below the PEL

• Periods when an employee requests a respirator

15.0

If an employee is exposed to lead above the PEL, without regard to the use of respirators or where the possibility of skin or eye irrita�on exists, the Company will, at no cost to the employee, provide appropriate protec�ve work clothing and equipment such as, but not limited to:

• Coveralls or similar full-body work clothing

• Gloves, hats, and shoes or disposable shoe coverlets

• Face shields, vented goggles, or other appropriate protec�ve equipment

Cleaning and Replacement

The Company will:

• Provide the protec�ve clothing in a clean and dry condi�on at least once a week, and daily to employees whose exposure levels to lead are over 200 µg/m3 as an 8-hour TWA without regard to a respirator

• Clean, launder, or dispose of protec�ve clothing and equipment

• Repair or replace required protec�ve clothing and equipment as needed to maintain their effec�veness.

• Ensure that all protec�ve clothing is removed at the comple�on of a work shi� only in change rooms provided for that purpose

• Ensure that contaminated protec�ve clothing that is to be cleaned, laundered, or disposed of is placed in a closed container in the change room, which prevents dispersion of lead outside the container.

• Inform any person who cleans or launders protec�ve clothing or equipment in wri�ng of the poten�ally harmful effects of lead exposure.

• Ensure that the containers of contaminated protec�ve clothing and equipment required by paragraph (g)(2)(v) are labeled as follows: CAUTION: CLOTHING CONTAMINATED WITH LEAD. DO NOT REMOVE DUST BY BLOWING OR SHAKING. DISPOSE OF LEAD CONTAMINATED WASH WATER IN ACCORDANCE WITH APPLICABLE LOCAL, STATE, OR FEDERAL REGULATIONS

• Prohibit the removal of lead from protec�ve clothing or equipment by blowing, shaking, or any other means which disperses lead into the air.

PPE

• Ensure that employees wash their hands and faces if they come in contact with lead-containing materials.

16.0 HOUSEKEEPING

• All surfaces shall be maintained as free as prac�cable of accumula�ons of lead.

• Floors and other surfaces where lead accumulates may not be cleaned by the use of compressed air.

• Shoveling, dry or wet sweeping, and brushing may be used only where vacuuming or other equally effec�ve methods have been tried and found not to be effec�ve.

• Where vacuuming methods are used, the vacuums shall be used and emp�ed in a manner which minimizes the reentry of lead into the workplace.

17.0 HYGIENE FACILITIES AND PRACTICES

The following requirements pertain to all areas where employees are exposed to lead above the PEL, without regard to the use of respirators:

• No food or beverage storage or consump�on.

• No tobacco product storage or use

• No cosme�cs stored or used

• No personal clothing or ar�cles, except in authorized change areas.

Change Rooms

Clean change rooms are provided for employees who work in areas where their airborne exposure to lead is above the PEL. Change rooms are equipped with separate storage facili�es for protec�ve work clothing and equipment and street clothes, which prevent cross-contamina�on. Employees who are required to shower a�er work shi�s are not allowed to leave the workplace wearing any clothing or equipment worn during the work shi�.

Showers

Employees who work in areas where their airborne exposure to lead is above the PEL must shower at the end of each work shi�.

Lunchrooms

Separate lunchroom facili�es are provided for employees who work in areas where their airborne exposure to lead is above the PEL. These facili�es are temperature controlled, have posi�ve pressure and filtered air supply, and are readily accessible to employees. All affected employees must wash their hands and face prior to ea�ng, drinking, smoking, or applying cosme�cs in the lunchroom area. Employees may not enter lunchroom facili�es with protec�ve work clothing or equipment unless surface lead dust has been removed by vacuuming, down dra� booth, or other cleaning methods.

Lavatories

An adequate number of separate lavatory facili�es are maintained for employees who work in lead-controlled process areas.

18.0 SIGNS

Proper signs will be posted at the entrances and exits of all lead hazard areas. No other signs or statements may appear on or near any lead hazard sign which contradicts or detracts from the meaning of the required sign. All lead

hazard signs will be kept illuminated and cleaned as necessary so that the legend is readily visible. The signs will contain the following or other appropriate warnings:

• WARNING LEAD WORK AREA

• POISON

• NO SMOKING OR EATING

19.0 EMPLOYEE TRAINING

Lead awareness training is required for employees whose work ac�vi�es may contact lead-containing materials but do not disturb the material during their work ac�vi�es. Lead awareness training is required during new hire orienta�on or before assignment to areas containing lead. Refresher training shall be provided annually.

Employee training will consist of:

• Specific OSHA requirements contained in:

o 1910.1025 (Lead)

o Appendix A to 1910.1025 (Substance Data Sheet for Occupa�onal Exposure to Lead)

o Appendix B to 1910.1025 (Employee Standard Summary)

• Specific nature of the opera�ons which could result in lead exposure above the ac�on level

• Purpose, proper selec�on, fi�ng, use, and limita�ons of respirators

• Purpose and a descrip�on of the medical surveillance program and medical removal protec�on program, including informa�on concerning the adverse health effects associated with excessive lead exposure with par�cular aten�on to the adverse reproduc�ve effects on both males and females

• Engineering controls and work prac�ces associated with the employee’s job assignment

• Contents of the Company’s compliance plan

• Instruc�ons that chela�ng agents should not rou�nely be used to remove lead from their bodies and should not be used at all except under the direc�on of a licensed physician

• Materials pertaining to the Occupa�onal Health and Safety Act

A copy of OSHA 1910.1025 and its appendices will be readily available to all affected employees.

Lead awareness training will be documented and include the employee’s name, trainer’s name, and dates of training.

20.0 MEDICAL SURVEILLANCE

The Company has ins�tuted a medical surveillance program for all employees who are or may be exposed above the ac�on level for more than 30 days per year. This medical surveillance program and all medical examina�ons and procedures are performed by or under the supervision of a licensed physician. The program func�ons under the requirements of OSHA 1910.1025. Elements of the program include:

• Biological monitoring

• Employee no�fica�on

• Medical examina�ons and consulta�ons

• Medical removal protec�on

• Medical removal protec�on benefits

21.0 RECORDKEEPING

All records rela�ng to the Company’s lead safety program are to be maintained for at least 40 years or for the dura�on of employment plus 20 years, whichever is longer. The following records will be established and maintained:

Exposure Monitoring

• Date(s), number, dura�on, loca�on, and results of each of the samples taken, including a descrip�on of the sampling procedure used to determine representa�ve employee exposure where applicable

• Descrip�on of the sampling and analy�cal methods used and evidence of their accuracy

• Type of respiratory protec�ve devices worn (if any)

• Name, social security number, and job classifica�on of the employee monitored and of all other employees whose exposure the measurement is intended to represent

• Environmental variables that could affect the measurement of employee exposure

Medical Surveillance

• Name, social security number, and descrip�on of the du�es of the employee

• A copy of the physician’s writen opinions

• Results of any airborne exposure monitoring done for that employee and the representa�ve exposure levels supplied to the physician

• Any employee medical complaints related to lead exposure

• A copy of the medical examina�on results including medical and work history

• A descrip�on of the laboratory procedures and a copy of any standards or guidelines used to interpret the test results or references to that informa�on

• A copy of the results of biological monitoring

Medical Removals

• Name and social security number of the employee

• Date on each occasion that the employee was removed from current lead exposure as well as the corresponding date on which the employee was returned to their former job status

• Brief explana�on of how each removal was or is being accomplished

• Statement with respect to each removal indica�ng whether or not the reason for the removal was an elevated blood lead level

Repor�ng Signs and Symptoms of Health Problems

Employees should immediately no�fy their supervisor if they develop signs or symptoms associated with lead poisoning or if they desire medical advice concerning the effects of current or past lead exposure on their ability to have a healthy child. Employees should also no�fy their supervisor if they have difficulty breathing during a respirator fit test or while wearing a respirator. In each of these cases, the Company will make appropriate medical examina�ons or consulta�ons available to the employee. These must be provided at no cost to the employee and at a reasonable �me and place.

22.0 EXPOSURE LEVELS

The program sets a PEL of 50 µg/m3 averaged over an 8-hour period. This is the highest level of lead in air to which employees may be permissibly exposed over an 8-hour period. Since it is an 8-hour TWA, it permits short exposures above the PEL so long as the average exposure does not exceed the PEL for each 8-hour period.

The Company recognizes that daily lead exposure can extend beyond a typical 8-hour period as the result of over�me or other altera�ons in work schedules. To deal with this, this program contains the below formula which

reduces permissible exposure when employees are exposed for more than 8 hours. For example, if an employee is exposed to lead for 10 hours a day, the maximum permited average exposure would be 40 µg/m3

23.0 MULTI-CONTRACTOR WORKSITES

If employees working immediately adjacent to a lead abatement ac�vity are exposed to lead due to the inadequate containment of such job, the Company shall either remove the employees from the area un�l the enclosure breach is repaired or perform an ini�al exposure assessment.

24.0 SITES

The Company will develop a site-specific compliance program for each new worksite. The site-specific compliance program will address means of engineering, work-prac�ce controls, air monitoring, and a descrip�on of each opera�on in which lead is emited.

The writen program will be revised and updated annually.

LOCKOUT/TAGOUT

1.0 PURPOSE

The purpose of this document is to outline the lockout/tagout program for IT Landes, hereina�er referred to as “the Company.” The purpose of this program is to control hazardous energy. This program establishes the requirements for isola�on of both kine�c and poten�al electrical, mechanical, hydraulic, pneuma�c, chemical, thermal, and gravita�onal energy prior to equipment repair, adjustment, or removal. Reference: OSHA 29 CFR 1910.147 - The Control of Hazardous Energy

2.0 POLICY Hazards

Improper or failure to use lockout/tagout procedures may result in:

• Electrical shock

• Chemical exposure

• Skin burns

• Lacera�ons and amputa�on

• Fires and explosions

• Chemical releases

• Eye injury

• Death

3.0 HAZARD CONTROLS

• Only trained and authorized employees may engage in tasks that require use of lockout/tagout procedures.

• All equipment has a single source of electrical power.

• Lockout procedures have been developed for all equipment and processes.

• Restora�on from lockout is a controlled opera�on.

Poten�al energy may include any source of electrical, mechanical, hydraulic, pneuma�c, chemical, thermal, or other energy.

4.0 TRAINING Authorized Employees

All maintenance employees, department supervisors, and janitorial employees will be trained to use the lockout/tagout procedures. The training will be conducted by the maintenance supervisor or safety coordinator at �me of ini�al hire. Retraining shall be held at least once a year. The training will consist of the following:

• Review of general procedures

• Review of specific procedures for machinery, equipment, and processes

• Loca�on and use of specific procedures

• Procedures when ques�ons arise

• Recogni�on of hazardous energy source

• Type and magnitude of energy available

• Methods and means necessary for energy isola�on and control

• Purpose and use of the energy control procedure

• Never ignore or defeat the tag in any way

Affected Employees

• Only trained and authorized employees will repair, replace, or adjust machinery, equipment, or processes

• Affected employees may not remove locks, locking devices, or tags from machinery, equipment, or circuits

• When tagout systems are used, including the limita�ons of a tag (tags are warning devices and do not provide physical restraint)

• Purpose and use of the lockout procedures

• Purpose and use of the energy control procedure

• Never ignore or defeat the tag in any way

Other Employees

• Only trained and authorized employees will repair, replace, or adjust machinery, equipment, or processes

• Other employees may not remove locks, locking devices, or tags from machinery, equipment, or circuits

• Any other employee whose work opera�ons are or may be in an area where energy control procedures may be u�lized

• Never ignore or defeat the tag in any way

Retraining

• Retraining is required when there is a change in job assignment, machines, energy control procedures, or a new hazard is introduced.

All training and retraining shall be documented, signed, and cer�fied.

Prepara�on

A lockout/tagout survey has been conducted to locate and iden�fy all energy sources to verify which switches or valves supply energy to machinery and equipment. Dual or redundant controls have been removed.

Devices shall indicate the iden�ty of the employee applying the device.

All affected employees shall be alerted of the isola�on of out of service equipment.

A tagout schedule has been developed for each piece of equipment and machinery. This schedule describes the energy sources, loca�on of disconnects, type of disconnect, special hazards, and special safety procedures. The schedule will be reviewed each �me to ensure employees properly lock and tag out equipment and machinery. If a tagout schedule does not exist for a par�cular piece of equipment, machinery, or process, one must be developed prior to conduc�ng a lockout/tagout. As repairs and/or renova�ons of exis�ng electrical systems are made, standardized controls will be used.

5.0 ROUTINE MAINTENANCE AND MACHINE ADJUSTMENTS

Lockout/tagout procedures are not required if equipment must be opera�ng for proper adjustment. This rare excep�on may be used only by trained and authorized employees when specific procedures have been developed to safely avoid hazards with proper training. All considera�ons shall be made to prevent the need for an employee to break the plane of a normally guarded area of the equipment by use of tools and other devices.

6.0 LOCKS HASPS AND TAGS

All qualified maintenance personnel will be assigned a lock with one key, hasp, and tag. All locks will be keyed differently, except when a specific individual is issued a series of locks for complex lockout/tagout tasks. In some cases, more than one lock, hasp, and tag are needed to completely de-energize machinery and equipment. Addi�onal locks may be checked out from the department or maintenance supervisor on a shi�-by-shi� basis. All locks and hasps shall be uniquely iden�fiable to a specific employee.

7.0 GENERAL LOCKOUT/TAGOUT PROCEDURES

Before working on, repairing, adjus�ng, or replacing machinery and equipment, the following procedures will be u�lized to place the machinery and equipment in a neutral or zero mechanical state.

Prepara�on for Shutdown

• Before authorized or affected employees turn off a machine or piece of equipment, the authorized employee will have knowledge of the type and magnitude of energy, the hazards of the energy to be controlled, and the means to control the energy.

• No�fy all affected employees that the machinery, equipment, or process will be out of service.

Machine or Equipment Shutdown

• The machine or equipment will be shut down using the specific procedures for that specific machine.

• An orderly shutdown will be u�lized to avoid any addi�onal or increased hazards to employees as a result of equipment de-energiza�on.

• If the machinery, equipment, or process is in opera�on, follow normal stopping procedures (depress stop buton, open toggle switch, etc.).

• Move switch or panel arms to “off” or “open” posi�ons and close all valves or other energy-isola�ng devices so that the energy source(s) is disconnected or isolated from the machinery or equipment.

Machine or Equipment Isola�on

• All energy control devices that are needed to control the energy to the machine or equipment will be physically located and operated in such a manner as to isolate the machine or equipment from the energy source.

Lockout or Tagout Device Applica�on

• Lockout or tagout devices will be affixed to energy-isola�ng devices by authorized employees.

• Lockout devices will be affixed in such a manner that will hold the energy-isola�ng devices from the “safe” or “off” posi�on.

• Tagout devices will be affixed in such a manner that will clearly state that the opera�on or the movement of energy-isola�ng devices from the “safe” or “off” posi�on is prohibited.

• Tagout devices will be atached to the same point a lock would be atached. If the tag cannot be affixed at that point, the tag will be located as close as possible to the device in a posi�on that will be immediately obvious to anyone atemp�ng to operate the device.

• Lock and tag out all energy devices by use of hasps, chains, and valve covers with an assigned individual lock.

Stored Energy

• Following the applica�on of the lockout or tagout devices to the energy-isola�ng devices, all poten�al or residual energy will be relieved, disconnected, restrained, and otherwise rendered safe.

• Where the reaccumula�on of stored energy to a hazardous energy level is possible, verifica�on of isola�on will be con�nued un�l the maintenance or servicing is complete, or un�l the possibility of such accumula�on no longer exists.

• Released stored energy (e.g., capacitors, springs, elevated members, rota�ng fly wheels, and hydraulic, air, gas, and steam systems) must be relieved or restrained by grounding, reposi�oning, blocking, and/or bleeding the system.

Verifica�on of Isola�on

• Prior to star�ng work on machines or equipment that have been locked or tagged out, the authorized employees will verify that isola�on or de-energiza�on of the machine or equipment has been accomplished.

• A�er assuring that no employee will be placed in danger, test all lockouts and tagouts by following the normal start up procedures (depress start buton, etc.).

Cau�on: A�er tes�ng, place controls in neutral posi�on.

8.0 GROUP LOCKOUT SETTINGS

Where a crew of authorized employees may use a lockout or tagout device, the following procedures shall be followed to ensure the group of employees are provided a level of protec�on equal to that provided by a personal lockout or tagout device:

• An authorized employee will be designated to have primary responsibility for a set number of employees working under the protec�on of a group lockout or tagout device.

• A pre-job safety mee�ng will be held to review the lockout or tagout procedure for the project.

• Each employee shall atach a personal lockout or tagout device to the group’s device while they are working and then removes it when finished.

• During shi� change or personnel changes, there should be specific procedures to ensure the con�nuity of lockout or tagout procedures.

• Documenta�on shall be specific and shall be retained.

Extended Lockout/Tagout

Should the shi� change before the machinery or equipment can be restored to service, the lock and tagout must remain. If the task is reassigned to the next shi�, those employees must lock and tagout before the previous shi� may remove their lock and tag

Release from Lockout/Tagout

Before lockout or tagout devices are removed and the energy is restored to the machine or equipment, the following ac�ons will be taken:

• The work area will be thoroughly inspected to ensure that non-essen�al items have been removed and that machine or equipment components are opera�onal.

• The work area will be checked to ensure that all employees have been safely posi�oned or removed.

• The affected employees will be no�fied that the lockout or tagout devices are being removed.

• Each lockout or tagout device will be removed from each energy-isola�ng device by the employee who applied the device.

9.0 LOCKOUT/TAGOUT PROCEDURE FOR ELECTRICAL PLUG-TYPE EQUIPMENT

This procedure covers all electrical plug-type equipment such as batery chargers, some product pumps, office equipment, powered hand tools, powered bench tools, lathes, fans, etc.

When working on, repairing, or adjus�ng the above equipment, the following procedures must be u�lized to prevent accidental or sudden startup:

• Unplug electrical equipment from the wall or in-line socket.

• Atach “DO NOT OPERATE” tag and plug box and lock on the end of the power cord.

An excep�on is granted to not lock and tag the plug if the cord and plug remain in the exclusive control of the employee working on, adjus�ng, or inspec�ng the equipment.

• Test equipment to ensure power source has been removed by depressing the “start” or “on” switch.

• Perform required opera�ons.

• Replace all guards removed.

• Remove lock and plug box and tag.

• Inspect the power cord and socket before plugging equipment into the power source. Any defects must be repaired before placing the equipment back in service.

Note: Occasionally used equipment may be unplugged from the power source when not in use.

10.0 LOCKOUT/TAGOUT PROCEDURE INVOLVING MORE THAN ONE EMPLOYEE

In the preceding SOPs, if more than one employee is assigned to a task requiring a lock and tagout, each must also place their own lock and tag on the energy-isola�ng device(s).

11.0 MANAGEMENT OF LOCK AND TAGOUTS

Only the employee that locks and tags out machinery, equipment, or processes may remove their lock and tag; however, should the employee leave the facility before removing their lock and tag, the maintenance manager may remove the lock and tag. The maintenance manager must be assured that all tools have been removed, all guards have been replaced, and all employees are free from any hazard before the lock and tag are removed and the machinery, equipment, or process are returned to service. No�fica�on of the employee who placed the lock is required prior to lock removal.

12.0 CONTRACTORS

Contractors working on Company property and equipment must use this lockout/tagout procedure while servicing or maintaining equipment, machinery, or processes.

Periodic inspec�ons of the energy control procedure must be conducted at least once a year to ensure that the procedure is being followed. The program should address who performs the inspec�on, which must be someone other than those actually using the lockout/tagout in progress. A cer�fied review of the inspec�on should be documented and include the date, equipment, employees, and inspector.

13.0 DEFINITIONS

Affected Employees: Employees who operate machinery or equipment upon which locking or tagging out is required under this program. Training of these individuals will be less stringent in that it will include the purpose and use of the lockout procedures.

Authorized (Qualified) Employees: The only ones cer�fied to lock and tagout machinery or equipment. Whether an employee is considered to be qualified will depend upon various circumstances in the workplace. It is likely for an individual to be considered “qualified” with regard to certain equipment in the workplace, but “unqualified” as to

other equipment. An employee who is undergoing on-the-job training and who, in the course of such training, has demonstrated an ability to perform du�es safely at their level of training and who is under the direct supervision of a qualified person, is considered to be “qualified” for the performance of those du�es.

Other Employees: Those that do not fall into the authorized, affected, or qualified employee category. Essen�ally, it will include all other employees. These employees will be provided instruc�on in what the program is and not to touch any machine or equipment when they see that it has been locked or tagged out.

Zero Energy State: A condi�on in which all sources of energy have been removed or neutralized.

MANAGEMENT OF CHANGE

1.0 PURPOSE

The purpose of this standard is to ensure appropriate review occurs before process and structural changes are made to IT Landes, hereina�er referred to as “the Company,” facili�es, processes, and equipment.

A thorough review of the change should improve the operability and reliability of the change, control the introduc�on of hazards into the workplace, improve decision making through collabora�on, promote effec�ve communica�ons and teamwork, and ensure conformance with policy, standards, codes, and regula�ons as they apply to the Company’s opera�ons.

2.0 SCOPE

This document is applicable to all employees.

3.0 REQUIREMENTS

Prior to any change within the scope of this policy, a safety review is to be completed using the Management of Change Procedure Form at the end of this document.

It is the responsibility of the individual or team proposing the change to follow this procedure and complete the safety review prior to making any changes.

Once the review has been completed by the individual or team, it must be approved by the project manager, as well as someone overseeing the project and safety managers.

At the comple�on of the change, the project and safety managers shall audit the changes against the approved plan.

4.0 PROCEDURE

Describe all proposed changes to the following areas on the Management of Change Procedure Form in detail

• U�lity and Energy Requirements: Electrical, hydraulic, compressed air, steam, etc., piping pressures and sizes for liquid and gas supplies, all means for de-energizing u�li�es provided and iden�fied.

• Hazardous Materials: Names and descrip�ons, SDSs, concentra�ons, size and type of packaging, flash point, flammable limits, storage requirements, temperatures, etc.

• Waste Disposal: Waste generated, containers to be used and loca�ons, amounts, flammability, toxicity, reac�vity, ingredients, associated wastes such as gloves and rags, disposal loca�ons, etc.

• Personal Protec�ve Equipment: Types required for hazards present or an�cipated.

• Personnel: Types of training required for HAZCOM, waste disposal, PPE, work permits, confined space, moving vehicles, cranes, fire protec�on, lockout/tagout, new equipment, shi�s to be involved, use of temporary employees, qualifica�ons of operators, tes�ng of operators.

• Material Handling: Li�ing devices required, cranes required, weights to be handled mechanically and manually, forkli� requirements, rack storage requirements, access to racks by forkli�s, power requirements for li�ing aids.

• Fire Protec�on: Access to exis�ng fire ex�nguishers and fire hoses, sprinklers protected and not obstructed, emergency response procedures.

• Walking Surfaces: Access to aisles, aisles not used for working, aisles designated, clean and smooth surfaces, floor mats, trip hazards.

• Machinery and Equipment: Guarding requirements, power transmission guarding, nip points, sharp edges, foot treadles, energy sources, new equipment and tools, maintenance requirements, equipment bolted to the floor, energy-isola�ng requirements (lockout/tagout), special tools required, automa�c start or intermitent opera�ons.

• Ergonomics: Illumina�on, noise, worker posi�on and posture, vibra�on, floor space, machine controls, repe��on, force, tool use, heat and cold, emergency stop loca�on.

• Ven�la�on: Airborne contaminants (vapor, gas, dusts, fumes, mists, smoke, vehicle exhaust, etc.), control, methods, amounts of emissions, local and general (dilu�on) ven�la�on, CFM, permits required.

• Radia�on Sources: Ultra-violet radia�on from arc welding, laser, light energy from cu�ng, plasma, microwave, radio frequency, etc.

MANAGEMENT OF CHANGE PROCEDURE FORM

Purpose: To verify the orderly and comprehensive review of any new opera�ons, processes, construc�on, equipment, machinery, demoli�on, remodeling, etc. prior to the actual change taking place. We must ensure that changes to the way we perform work do not create safety or environmental hazards and that we have considered how changes in one area of work will affect other areas.

Project Loca�on: _________ ___ Requestor: ____

U�lity and Energy Requirements: Rou�ng and type of electrical, hydraulic, compressed air, steam, etc., piping pressures and sizes for liquid and gas supplies, all means for de-energizing u�li�es provided and iden�fied, other.

Hazardous Materials: Names and descrip�ons, SDSs, concentra�ons, size and type of packaging, flash point, flammable limits, storage requirements, temperatures, other.

Waste Management: Wastes generated, containers to be used and loca�ons, amounts, drains used, flammability, toxicity, reac�vity, ingredients, associated wastes such as gloves and rags, disposal loca�ons such as compactor or strategic dumpster or hazardous waste drums, other.

Personal Protec�ve Equipment: Types required, other.

Personnel: Types of training required for HAZCOM, waste disposal, PPE, confined space, moving vehicles, cranes, fire protec�on, lockout/tagout, new equipment, work shi�s to be involved, use of temporary employees, qualifica�ons of operators, tes�ng of operators, other.

Material Handling: Li�ing devices required, cranes required, weights to be handled mechanically and manually, forkli� requirements, rack storage requirements, access to racks by forkli�s, power requirements for li�ing aids, other.

Fire Protec�on: Access to aisles, aisles not used for working, aisles designated, clean and smooth surfaces, floor mats, trip hazards, other.

Walking and Working Surfaces: Access to aisles, aisles not used for working, aisles designated, clean and smooth surfaces, floor mats, trip hazards, other.

Machinery and Equipment: Point of opera�on guarding, power transmission guarding, nip points, sharp edges, foot treadles, energy sources, new equipment and tools, maintenance requirements, equipment bolted to the floor, energy-isola�ng requirements (lockout/tagout), special tools required, automa�c start or intermitent opera�ons, other.

Ergonomics: Illumina�on, noise, worker posi�on and posture, vibra�on, floor space, machine controls, repe��on, force, tool use, heat and cold, emergency stop loca�on, other.

Ven�la�on: Airborne contaminants (vapor, gas, dust, fume, mists, smoke, vehicle exhaust, etc.), control methods, amounts of emissions, local and general (dilu�on) ven�la�on, CFM, permits required, other.

Radia�on: Ultra-violet radia�on from arc welding, laser, light energy from cu�ng, plasma, microwave, radio frequency, other.

If you answered “Yes” to any of the issues above, explain the proposed changes below:

Submited By: ___________________________________

Review/Approval

Supervisor: ____________________________________

Project Manager: _______________________________

Date: ___________________________

Date: ___________________________

Date: ___________

Safety Manager: ________________________________ Date: ___________________________

Client (If Needed): _______________________________

Audits

Date: ___________________________

Project Manager: ________________________________ Date: ___________________________

Safety Manager: _________________________________ Date: ________________________

MANUAL LIFTING

1.0 POLICY

Back disorders can gradually develop as a result of micro-trauma brought about by repe��ve ac�vity over �me or can be the product of a single trauma�c event. Because of the slow and progressive onset of this internal injury, the condi�on is o�en ignored un�l the symptoms become acute, o�en resul�ng in disabling injury. Acute back injuries can be the immediate result of improper li�ing techniques and/or li�ing loads that are too heavy for the back to support. While the acute injury may seem to be caused by a single well-defined incident, the real cause is o�en a combined interac�on of the observed stressor coupled with years of weakening of the musculoskeletal support mechanism by repe��ve micro-trauma. Injuries can arise in muscle, ligament, vertebrae, and discs, either singly or in combina�on.

Incident

Although back injuries do not account for any work-related deaths, they do account for a significant amount of human suffering, loss of produc�vity, and economic burden on compensa�on systems. Back disorders are one of the leading causes of disability for people in their working years and afflict over 600,000 employees each year with a cost of about $50 billion annually in 1991 according to NIOSH. The frequency and economic impact of back injuries and disorders on the workforce are expected to increase over the next several decades as the average age of the workforce increases and medical costs go up.

Back Disorders

Back disorders result from exceeding the capability of muscles, tendons, discs, or the cumula�ve effect of several contributors:

• Bending while li�ing

• Twis�ng while li�ing

• Reaching while li�ing

• Maintaining bent postures

• Poor posture (how one sits or stands)

• Stressful living and working ac�vi�es

• Staying in one posi�on for too long

• Bad body mechanics (how one li�s, pushes, pulls, or carries objects)

• Poor physical condi�on (losing the strength and endurance to perform physical tasks without strain)

• Repe��ve li�ing of awkward items, equipment, or (in healthcare facili�es) pa�ents

• Poor foo�ng such as slippery floors, or constrained posture

• Poor design of job or worksta�on

Signs and Symptoms

Signs and symptoms include pain when atemp�ng to assume normal posture, pain when standing or rising from a seated posi�on, and decreased mobility.

Reports of Back Injuries

These factors usually account for very few work-related back injuries:

• Congenital defects of the spine

• Increase in sta�c standing or si�ng tasks

• Decreases in physical condi�oning and exercise

• Increased awareness of workplace hazards

• An aging workforce

• Job dissa�sfac�on

Inves�ga�on Guidelines

Records Review: OSHA 200 Log

“Note when back or other musculoskeletal disorders appear excessive from Lost Work Day Injury and Illness (LWDII) rate calcula�ons. Understand that excessiveness is rela�ve, since there is no firm figure established that delineates safe from unsafe. A beter measure is to look for trends of escala�ng number of injuries or of increasing severity of injuries. Comparing your target popula�on with BLS data, other company rates, other lines, departments, wings, or occupa�onal �tles can yield a meaningful measuring point to gauge excessiveness.”

Musculoskeletal injuries caused by improper li�ing must be inves�gated and documented. Incorpora�on of inves�ga�on findings into work procedures must be accomplished to prevent future injuries.

Back injuries should be treated as an injury on the OSHA 200 Log regardless of whether the injury was the result of an acute or chronic exposure. To determine if a trend exists, at least several years of the OSHA 200 Log will be needed for review. A hazard assessment shall be completed before every new manual li�ing task is completed.

Employer During Employee Interviews

• Walk around.

• Ask employees about their opinion on the difficulty of the task and personal experiences with back pain.

• Observe employee postures and li�ing

• Determine weight of objects li�ed.

• Determine the frequency and dura�on of li�ing tasks.

• Measure the dimensions of the workplace and li�

Evalua�on

Videotapes should be taken of the work task for later review and for evidence of recognized musculoskeletal hazards.

Manual Li�ing

• Repe��ve material handling increases the likelihood of a disorder.

• Principal variables in evalua�ng manual li�ing tasks to determine how heavy a load can be li�ed are:

o The horizontal distance from the load to the employee’s spine

o The ver�cal distance through which the load is handled

o The amount of trunk twis�ng the employee u�lized during the li�ing

o The ability of the hand to grasp the load

o The frequency with which the load is handled

• Addi�onal variables include floor and shoe trac�on, space constraints, two-handed li�s, size, and stability of the load.

• The NIOSH Li�ing Formula uses the principal variables to compute a theore�cally safe li�.

Preven�on and Control

Engineering controls alter the task to eliminate the hazardous mo�on and/or change the posi�on object in rela�on to the employee’s body such as adjus�ng the height of a pallet or shelf. Engineering controls are preferred.

When available, employees shall use manual li�ing equipment (forkli�s, li�ing jacks, etc.) that can be available at the shop or jobsites.

Manual Materials Handling

Manual materials handling is the principal source of compensable injuries in the American workforce, and four out of five of these injuries will affect the lower back.

• Material handling tasks should be designed to minimize the weight, range of mo�on, and frequency of the ac�vity.

• Work methods and sta�ons should be designed to minimize the distance between the person and the object being handled.

• Pla�orms and conveyors should be built at about waist height to minimize awkward postures. Conveyors or carts should be used for horizontal mo�on whenever possible. Reduce the size or weight of the object(s) li�ed.

• High-strength push-pull requirements are undesirable but pushing is beter than pulling. Material handling equipment should be easy to move with handles that can be easily grasped in an upright posture.

• Workbench or worksta�on configura�ons can force people to bend over. Correc�ons should emphasize adjustments necessary for the employee to remain in a relaxed upright stance or fully supported, seated posture. Bending the upper body and spine to reach into a bin or container is highly undesirable. The bins should be elevated, �lted, or equipped with collapsible sides to improve access.

• Repe��ve or sustained twis�ng, stretching, or leaning to one side are undesirable. Correc�ons could include reposi�oning bins and moving employees closer to parts and conveyors.

• Store heavy objects at waist level.

• Provide li�-assist devices and li� tables.

Job Analysis and Observa�on

Each job in which workers have a greater incidence of back disorders might be subject to a job analysis a�er an appropriate records review and worker survey.

Work Methods Analysis

• No�ce what employees are doing to make themselves more comfortable in the workplace. For example, look for improvised footrests, padding, or homemade tools and devices.

• Watch for repeated mo�ons and the posi�on of the arms, wrists, and trunk (e.g., over-stretching or unusual posture).

• Record the movements used to perform the task. Use a video camera for subsequent slow-mo�on analysis. Describe the posi�ons seen. Ask ques�ons to determine if staffing levels and produc�on pace is truly representa�ve of the normal opera�on. Obtain produc�on data if possible.

• Worksta�on and tool evalua�on may be necessary.

• Conduct periodic evalua�ons at current worksta�on configura�ons and employees’ work techniques to assess the poten�al for and preven�on of injuries.

NIOSH Work Prac�ce Guide for Material Li�ing

In 1981, NIOSH developed an equa�on to assess li�ing condi�ons. In 1991, NIOSH issued a revised equa�on for the design and evalua�on of manual li�ing tasks. The 1991 equa�on uses six factors that have been determined to

influence li�ing difficulty the most, combining the factors into one equa�on. Two of the factors which are new to the revised equa�on include twis�ng (asymmetry) and the quality of the worker’s grip on the load (coupling). Using the equa�on involves calcula�ng values for the six factors in the equa�on for a par�cular li�ing and lowering task, thereby genera�ng a recommended weight limit (RWL) for the task. The RWL is the load that nearly all healthy employees (90% of the adult popula�on, 99% of the male and 75% of the female workforce) can li� over a substan�al period of �me (i.e., up to 8 hours) without placing an excessive load on the back. The revised equa�on also incorporated a term called the Li�ing Index, which is defined as a rela�ve es�mate of the level of physical stress associated with a par�cular manual li�ing task. The es�mate of the level of physical stress is defined by the rela�onship of the weight of the load li�ed divided by the recommended weight limit. A level greater than one indicates that the li�ed weight exceeded the RWL and should be addressed using either administra�ve or engineering controls. A level greater than three indicates that the li�ed weight exceeds the capacity to safely li� for most of the popula�on, is likely to cause injury, and should be modified by implementa�on of engineering controls.

The 1991 equa�on s�ll maintains the 1981 biomechanical criteria for establishing the maximum lower back compression force of 770 pounds. For the revised equa�on, the load constant was reduced from 90 pounds to 51 pounds. This reduc�on was driven by the need to increase the minimum horizontal distance from 6 inches to 10 inches, which is believed to be the minimum atainable horizontal distance as measured from the spine during li�ing, in the 1991 equa�on. Aside from this reduc�on, the 1991 revised equa�on represents only a 2 pound reduc�on from the 1981 version when adjusted for revised horizontal distance.

Applica�on of the NIOSH li�ing tasks assumes the following:

• Li�ing task is two-handed, smooth, in front of the body, hands are at the same height or level, moderatewidth loads (i.e., they do not substan�ally exceed the body width of the li�er), and the load is evenly distributed between both hands.

• Manual li�ing equipment and other engineering controls are provided to employees.

• Manual handling ac�vi�es other than li�ing are minimal and do not require significant energy expenditure, especially when repe��ve li�ing tasks are performed (i.e., holding, pushing, pulling, carrying, walking, or climbing).

• Temperatures (66-79°F) or humidity (35-50%) outside of the ranges may increase the risk of injury.

• One-handed li�s, li�ing while seated or kneeling, li�ing in a constrained or restricted workspace, and li�ing unstable loads, wheelbarrows, and shovels are not tasks designed to be covered the li�ing equa�on.

• The shoe sole to floor surface coupling should provide for firm foo�ng.

• Li�ing and lowering assumes the same level of risk for the lower back.

• Using the guidelines in situa�ons that do not conform to these ideal assump�ons will underes�mate the hazard of the li�ing task under inves�ga�on.

• The computed values of the recommended weight limit are used by the CSHO as a guide to es�mate risk. The numbers by themselves do not iden�fy a hazardous ac�vity.

• The employer’s incidence of injuries and lack of programs for training, work-prac�ce controls, and engineering controls related to li�ing are elements used to determine the seriousness of the hazard.

Safe Li�ing and Carrying Techniques

• Bend to li� an object; don’t stoop

• Keep your back straight by tucking in your chin.

• Li� with the strong leg muscles, not the weaker back muscles.

The following are the basic steps of safe li�ing and handling:

• Size up the load and check overall condi�ons. Don’t atempt the li� by yourself if the load appears to be too heavy or awkward. Check that there is enough space for movement, and that the foo�ng is good.

• Make certain that your balance is good. Feet should be shoulder width apart, with one foot beside and the other foot behind the object that is to be li�ed.

• Bend the knees; don’t stoop. Keep the back straight, but not ver�cal. There is a difference; tucking in the chin straightens the back.

• Grip the load with the palms of your hands and your fingers. The palm grip is much more secure.

• Use your body weight to start the load moving, then li� by pushing up with the legs.

• Keep the arms and elbows close to the body while li�ing.

• Carry the load close to the body. Don’t twist your body while carrying the load. To change direc�on, shi� your foot posi�on and turn your whole body.

• Watch where you are going.

• Bend the knees to lower an object; don’t stoop. To deposit the load on a bench or shelf, place it on the edge and push it into posi�on. Ensure your hands and feet are clear when placing the load.

Remember to use the 5 L’s of back safety:

• Load

• Lungs

• Lever

• Legs

• Lordosis (keep your back straight)

2.0 TRAINING

Worker Training and Educa�on

• Training should include general principles of ergonomics, recogni�on of hazards and injuries, procedures for repor�ng hazardous condi�ons, and methods and procedures for early repor�ng of injuries.

• Job-specific training should be given on safe work prac�ces, hazards, and controls.

• Strength and fitness training can reduce compensa�on costs.

• Rota�ng employees, providing short breaks every hour, or using a two-person li� may be helpful. Rota�on is not simply a different job; it must be a job that u�lizes a completely different muscle group from the ones that have been overexerted.

Other Training

• Standing for extended periods of �me places excessive stress on the back and legs. Solu�ons include a footrest or rail, resilient floor mats, height-adjustable chairs or stools, and opportuni�es for employees to change posi�on.

• Where employees are seated, the chairs or stools must be properly chosen.

• Proper adjustable lumbar support may be provided.

• Sta�c seated postures with bending or reaching should be avoided.

• Training shall be given to all employees on proper li�ing techniques and avoidance of musculoskeletal injuries.

• Refresher training shall be given annually.

• Training shall be provided for all new job tasks.

• Where the use of li�ing equipment is imprac�cal, two-man li�s shall be performed.

NOISE AWARENESS

1.0 PURPOSE

The purpose of this document is to outline the noise awareness program for IT Landes, hereina�er referred to as “the Company.” Conserva�on of hearing is covered in OSHA 29 CFR 1910.95 and is achieved through preventa�ve measures. To reduce occupa�onal hearing loss, all employees who work in poten�ally noisy areas are provided hearing protec�on, training, and annual hearing tests. Engineering controls are applied to reduce noise from equipment and opera�ons.

2.0 RESPONSIBILITIES

Management

• Use engineering and administra�ve controls to limit employee exposure.

• Provide adequate hearing protec�on for employees.

• Post signs and warnings for all high-noise areas

• Conduct noise surveys annually or when new equipment is added.

• Conduct annual hearing tests for all employees.

• Conduct annual hearing conserva�on training for all employees

• Conduct hearing conserva�on training for all new employees.

Employees

• Use Company-provided, approved hearing protec�on in designated high-noise areas.

• Request new hearing protec�on when needed

• Exercise proper care of issued hearing protec�on.

3.0 POLICY

4.0 TRAINING

A training program shall be provided for all employees who are exposed to a noise ac�on level or work in high-noise areas. The training shall be repeated annually for each employee.

Training shall be updated consistent to changes in personal protec�ve equipment (PPE) and work processes and include the proper techniques of wearing hearing protec�on.

The Company will make copies of the noise exposure procedures available to affected employees and shall also post a copy in the workplace. The Company shall also allow the human resources director and division president access to records.

At �me of hire and annually thereina�er, all affected employees must atend hearing conserva�on training. The ini�al training is conducted as part of the new hire orienta�on by the Human Resources Department and consists of:

• Rules and procedures

• Where hearing protec�on is required

• How to use and care for hearing protectors

• How noise affects hearing and hearing loss

5.0 ENGINEERING CONTROLS

A�er it is determined that noise exposure above 85 dB(A) is present, engineering controls should be evaluated and implemented to reduce the noise exposure before administra�ve controls are ini�ated. Some examples of engineering controls include:

• Noise-reducing baffles

• Compartmentaliza�on

• Installing noise-reducing gears

• Installing rubber pads under machinery

When new equipment or machinery is evaluated for purchase, the safety manager should be consulted to conduct an evalua�on from a health and safety standpoint. One criteria of the evalua�on should include the amount of noise the equipment will produce and how it will affect the overall noise exposure.

A con�nuing and effec�ve hearing conserva�on program shall be administered when employees are exposed to sound levels greater than 85 dB(A) on an 8-hour �me-weighted average (TWA) basis.

When informa�on indicates that employee exposure may equal or exceed the 8-hour TWA of 85 dB(A), a monitoring program shall be implemented to iden�fy employees to be included in the hearing conserva�on program.

6.0 ADMINISTRATIVE CONTROLS

A�er engineering controls are evaluated for effec�veness or feasibility, administra�ve controls should be considered to reduce noise exposure. Administra�ve controls include restric�ng exposure �me or using PPE. PPE, such as earplugs or earmuffs, may be used to reduce the amount of noise exposure. Each earplug or earmuff has a noise reduc�ons factor (NR) as evaluated by ANSI S3.19-1974 or Z24.22-1957. For example, if a work area has an ambient noise exposure of 96 dB(A), the hearing protectors should be rated 6 NR or beter to be effec�ve.

An audiometric tes�ng program will be established and maintained by making audiometric tes�ng available to all employees whose exposures equal or exceed an 8-hour TWA of 85 dB(A). Within six months of an employee’s first exposure at or above the ac�on level, a valid baseline audiogram shall be established against which future audiograms can be compared. When a mobile van is used, the baseline shall be established within one year.

Tes�ng to establish a baseline audiogram shall be preceded by at least 14 hours without exposure to workplace noise. Hearing protec�on may be used to meet the requirement. Employees shall also be no�fied to avoid high levels of noise.

At least annually a�er obtaining the baseline audiogram, the Company will obtain a new audiogram for each employee exposed at or above an 8-hour TWA of 85 dB(A). Each employee’s annual audiogram shall be compared to that employee’s baseline audiogram to determine if the audiogram is valid and if a standard threshold shi� has occurred. If a comparison of the annual audiogram to the baseline audiogram indicates a standard threshold shi�, the employee shall be informed of this fact in wri�ng within 21 days of the determina�on.

If a threshold shi� has occurred, use of hearing protec�on shall be reevaluated and/or refited and if necessary, a medical evalua�on may be required. This is done at no cost to employees. Hearing protec�on shall be replaced as necessary. The Company shall ensure that hearing protectors are worn. Employees shall be properly trained in the use, care, and fi�ng of protectors.

The Company shall evaluate hearing protec�on for the specific noise environments in which the protector will be used. Accurate records of all employee exposure and audiometric measurements shall be maintained as required by the regula�on.

According to OSHA regula�ons, each loca�on with noise exposures of 85-89 dB(A) will provide hearing protectors for the employee’s op�onal use. Noise exposures at 90 dB(A) or above require the mandatory use of hearing protec�on. Further, OSHA requires that a variety (earplug and earmuff) of hearing protectors be available for employees to choose.

7.0 TYPES OF HEARING PROTECTORS

Hearing protectors shall be available to all employees exposed to an 8-hour TWA of 85 dB(A) or greater at no cost to the employees. Hearing protectors shall be replaced as necessary. Employees shall be given the opportunity to select their hearing protectors from a variety of suitable hearing protectors provided by the employer.

Hearing protec�on devices are the first line of defense against noise in environments where engineering controls have not reduced employee exposure to safe levels. Hearing protec�ve devices can prevent significant hearing loss, but only if they are used properly. The most popular hearing protec�on devices are earplugs which are inserted into the ear canal to provide a seal against the canal walls. Earmuffs enclose the en�re external ears inside rigid cups. The inside of the muff cup is lined with acous�c foam and the perimeter of the cup is fited with a cushion that seals against the head around the ear by the force of the headband.

8.0 USE OF HEARING PROTECTORS

Hearing protec�on shall be worn by any employee that has been provided hearing protec�on by their employer. Employees will wear hearing protec�on in signed areas while at host facili�es.

Managers, supervisors, and employees shall properly wear the prescribed hearing protectors while working in or traveling through any sec�on of a loca�on that is designated a “high-noise area,” excluding offices, break rooms, and rest facili�es. The following rules will be enforced:

• Personal stereos, such as MP3 players, will not be permited in any opera�ng area of Company property.

• Hearing protectors, at least two types of earplugs and one type of earmuff, will be provided and maintained by the Company.

• Hearing protectors and replacements will be provided free of charge.

• Hearing protectors will be properly worn at all �mes, except in offices, break rooms, and rest facili�es.

Pre-formed earplugs and earmuffs should be washed periodically and stored in a clean area, and foam inserts should be discarded a�er each use. It is important to wash hands before handling pre-formed earplugs and foam inserts to prevent contaminants from being placed in the ear which may increase the risk of developing infec�ons.

PERSONAL PROTECTIVE EQUIPMENT

1.0 PURPOSE

The purpose of this program is to establish procedures for IT Landes, hereina�er referred to as “the Company,” employees using and maintaining personal protec�ve equipment (PPE) that must be used by employees in order to prevent injuries.

2.0 SCOPE

This program applies to all Company employees. It is to be used at all �mes on Company worksites. If an employee performs work on a site other than the Company’s, the facility owner’s plan should be used if it exists and is as strict (or stricter) than this plan. In cases where the other facility’s plan does not exist or is less strict than this plan, employees will operate under this plan.

3.0 RESPONSIBILITIES

Safety Manager

• Help to select appropriate PPE. Some work tasks expose employees to hazards that cannot be eliminated by means of engineering or administra�ve controls. In these cases, the safety manager assists the supervisor and project manager in iden�fying and selec�ng suitable PPE based on the task being performed, the work condi�ons, and the frequency and dura�on of the exposure. Employees provide feedback to the supervisor regarding the fit, comfort, and suitability of PPE to be used. Reasons for the selected PPE are to be provided to employees.

• Assist the supervisor and site manager to ensure obtained PPE meet the requirements of this program and applicable regula�ons.

• Conduct worksite hazard assessments. These assessments must determine whether hazards exist or are likely to exist and if they require the use of PPE. Hazards may include those related to high or low temperatures, impact or mo�on, sharp objects, falling objects, rolling objects, pinching objects, chemicals, materials, radia�on, electrical hazards, and general workplace layout. The safety manager documents the tasks that were evaluated, hazards that were discovered, and the PPE required to protect employees. They also ensure that affected employees are aware of hazards and required PPE prior to being assigned to the hazardous task. The documents are cer�fied and include the cer�fier’s name, signature, and dates, and iden�fy the assessment documents.

Managers and Supervisors

• Regularly monitor employees to ensure PPE is being properly used and cared for.

• Ensure employees receive follow-up training if required so they have the adequate knowledge, skill, and ability to use PPE.

• Use progressive discipline to enforce PPE safety rules and ensure that the required PPE poster is properly posted

Employees

• Properly use and care for PPE.

• Report any changes in exposure that may necessitate a reassessment of the task for PPE

• Report and replace defec�ve or damaged PPE; never use defec�ve or damaged PPE

• Wear required PPE; failure to do so could result in termina�on of employment.

4.0 PROCEDURE General

The Company will PPE, including PPE for head, eyes, face, and extremi�es, respiratory devices, protec�ve clothing, and protec�ve shields and barriers. This protec�ve equipment must be used wherever injury or impairment of func�on of any body part (through absorp�on, inhala�on, or physical contact) is likely due to process or environmental hazards, radiological hazards, chemical hazards, or mechanical irritants. All PPE shall be provided, used, and maintained in a sanitary and reliable condi�on.

Employees are not allowed to use employee-owned equipment, except prescrip�on safety glasses and footwear. The Company shall ensure that employee-owned safety glasses and footwear are adequate, and the Company will maintain and clean them.

Defec�ve or damaged equipment shall not be used and must be tagged or destroyed and replaced.

All issued PPE will be cost-free to the employee. All employees must understand and follow the procedures iden�fied in this program.

Eye Protec�on

Employees must use the required eye or face protec�on when exposed to eye or facial hazards such as flying fragments, chemicals, acids, or caus�c liquids, melted metal, or chemical gases or vapors. PPE used to protect the eyes and face must be in compliance with ANSI Z87.1-2003 (Z87+) (Occupa�onal and Educa�onal Personal Eye and Face Protec�ve Devices).

Safety Glasses

While on Company property, employees, subcontractors, and visitors must wear safety glasses with side shields that meet ANSI Z87.1-2003 with “high-impact lenses” at all �mes. Requirements as described below:

• In shops and warehouses, and at field loca�ons, except in striped safety zones that have been designated and approved.

• In all yard work zones.

• Everyone in the vicinity of loading or unloading equipment.

• All employees who perform mechanic or maintenance work, operate equipment (e.g., forkli� and welding), test stand opera�ons, or do any work that may poten�ally cause an eye injury.

• In a restroom, office, or any other building when performing work that may poten�ally cause an eye injury.

• The Company will provide visitors with safety glasses. If approved, prescrip�on safety glasses are not available for an individual, they must wear “over the glass” type safety goggles or glasses over their regular prescrip�on glasses un�l they obtain approved, prescrip�on safety glasses.

• When assis�ng welders, employees must wear absorbent safety glasses to protect the assistant from ultraviolet and/or infrared rays.

• No employee is allowed to wear dark shaded lens (sunglasses) darker than #1 shade unless welding or assis�ng a welder.

• The requirement to wear safety eyewear will be exempt only based on a writen “excep�ons for medical reasons” from a doctor.

• Employees are not required to wear safety glasses:

o Inside an office

o In parking lots when traveling to and from vehicles

o In office buildings using main doors that do not enter shops

Goggles

• Employees must wear chemical splashproof goggles as recommended on the SDS for the material being handled when handling or mixing liquid chemicals, solvents, paints, etc.

• Employees must wear dust-proof goggles when blowing equipment down with air. They must also be worn when the employee is performing a job task where safety glasses do not do an adequate job of preven�ng airborne par�cles from entering the openings around the lenses and side shields.

Face Shields

• Employees must wear a full-face shield over safety glasses when opera�ng a handheld or immobile grinder with a wire or abrasive wheel.

• Employees must wear a full-face shield when chipping paint or concrete.

• Employees must wear a full-face shield performing job tasks where flying objects may poten�ally strike the face.

• Employees must wear a full-face shield over safety glasses if safety glasses or goggles do not provide adequate protec�on.

Head Protec�on

When working in areas where a head injury is possible due to employee-ini�ated impact, or impact from falling or other moving objects, employees must wear protec�ve helmets. Helmets must be in compliance with ANSI Z89.11997 Class E (American Na�onal Standard for Industrial Head Protec�on) for Type II head protec�on or must be equally effec�ve.

• Hardhats must be worn when working in areas where head injury is possible from falling objects.

• Hardhats must be worn at all warehouse, field, and shop loca�ons, or any loca�on where it is determined to be necessary as per the loca�on’s PPE hazard assessment.

• Never alter hardhats in any way.

• Never paint or apply unauthorized s�ckers, name plates, etc. on hardhats.

• Never drill, cut, bend, or apply heat to a hardhat.

• Never alter the suspension system of a hardhat.

• Employees must inspect hardhats regularly for chips, scratches, cracks, signs of heat exposure (e.g., sun cracks), etc.

• Immediately replace any defec�ve hardhats.

• Never place a hardhat in the rear window of a vehicle; they will be exposed to the sun or may become a projec�le in a vehicle accident.

• Hardhats must be made available to visitors.

• The Company must provide hardhats.

• The Company will train employees in the use, care, and maintenance of head protec�on equipment.

Hearing Protec�on

While in posted “high noise” areas, all employees, subcontractors, and visitors must wear hearing protec�on. See the Company’s hearing conserva�on program for addi�onal informa�on.

All areas that are known or suspected to have noise levels in excess of 85 dB(A) (constantly or intermitently) must have warning signs posted.

When noise caused by machinery, tools, etc., prevents normal conversa�ons to be heard clearly, employees shall wear hearing protec�on even if warning signs are not posted.

General rule of thumb: If you must yell to be heard, you require hearing protec�on.

The Company will supply earmuffs and earplugs in sizes and configura�ons that are comfortable for the employee.

Types

• Preformed inserts (earplugs)

• Canal caps (headband type)

• Muff, either headband or hardhat mounted

Care and Maintenance

• Employees must inspect hearing protec�on before each use.

• Keep hearing protec�on clean to prevent ear infec�ons.

• Discard disposable earplugs when they become dirty, greasy, or cracked.

• Replace any earmuffs that have cracked seals, deteriorated foam inserts, or are defec�ve.

Fit

Because everyone is different, hearing protec�on must be selected for the individual. The employee must try a variety of styles to find one that is comfortable and provides adequate protec�on. The Company will instruct employees in how to obtain the proper fit.

Hand Protec�on Gloves

When performing work tasks that may expose the hands to extreme temperatures, cuts and abrasions, or exposure to chemicals, employees must wear gloves.

• Welding: When performing arc welding or oxy/gas cu�ng, employees must wear welding gloves made of leather or other heat resistant materials.

• Chemical: When handling chemicals that specify gloves as PPE, employees must wear impervious (chemical resistant) gloves. To select the correct glove type, refer to the specific chemical’s SDS. Employees who work with chemicals, such as solvent vats, will be issued their own gloves for hygienic purposes.

• Leather: When working with sharp materials or handling rigging equipment, employees must wear leather gloves.

• Cloth: When handling objects or materials that could cause blisters, splinters, cuts, etc., employees must wear cloth gloves.

• Heat Resistant: When handling hot bearings, races, or other materials or objects (heated beyond room temperature), employees must wear heat resistant gloves.

• Insulated: To prevent frostbite in extreme cold climates, employees must wear insulated gloves.

Glove Inspections

• Prior to each use, inspect gloves for holes, tears, and worn areas.

• Periodically air test chemical gloves for pinholes by �ghtly twis�ng the cuff, expand the glove by applying low air pressure, and submersing the glove in water to check for bubbles.

• Immediately discard any defec�ve gloves.

Excep�on: While working with rota�ng machinery, machinists are exempt from wearing gloves.

Foot Protec�on

All employees with regular du�es in shops, warehouses, and field loca�ons must wear safety footwear.

• Visitors and office workers entering these areas infrequently are not required to wear foot protec�on as long as they stay away from the work being performed.

• If visitors or office workers must be in close proximity to the work, the work must be stopped while in the area or safety footwear must be worn.

• When in shops, warehouses, field loca�ons, and parts departments, employees must wear leather or equivalent boots (lace up or pull up).

• Boots must provide ankle protec�on, have soles that are designed to protect the feet from punctures, and have defined heels for climbing ladders.

• When there is a risk of equipment or material crushing the foot, toe guards must be worn.

• Safety footwear must comply with ANSI Z41-1999.

• Some client loca�ons may require everyone to wear safety footwear. Before visi�ng field loca�ons, check with the local supervisor for client requirements.

Fall Protec�on

When performing certain elevated jobs (over six feet), employees must use personal fall protec�on. Refer to the Company’s fall protec�on program.

Electrical Protec�on

Refer to the Company’s electrical safety program.

Worksite Hazard Assessment

Hazard assessments must be performed, signed, and documented. If it is determined that a hazard exists or is likely to exist, PPE must be used. Following are some hazard sources that may be iden�fied:

• High or low temperatures

• Chemical exposure (see SDS for guidance)

• Flying fragments, melted metal, or other face, eye, or skin hazards

• Falling objects or the possibility of dropping an object

• Employee falling from a height in excess of 6 feet

• Sharp objects

• Rolling or pinching that could crush hands or feet

• Electrical hazards

Any�me that these hazards may cause injury to employees, PPE must be selected to eliminate or substan�ally reduce the poten�al for injury. Employees will be no�fied of the selec�on and reason.

Each affected employee will be apprised of the results of the assessment. A copy of the assessment will be kept at the local office.

Each affected employee must be fited with the selected/iden�fied PPE. The training sec�on of this program addresses fi�ng, including proper donning and doffing; cleaning; and maintenance of PPE. All PPE use exemp�ons must be supported by the PPE hazard assessment.

Monitoring

Site managers and supervisors must monitor worksite tasks to iden�fy changes in hazards or the introduc�on of new hazards. If the site manager or supervisor discovers a new hazard, they must advise the safety manager.

The safety manager conducts a hazard assessment for appropriate PPE for the new hazard.

The safety manager monitors how effec�ve the PPE procedure is and recommends improvements to management.

5.0 TRAINING

The Company will train all employees who may need to wear PPE. Each affected employee must be fited for PPE as required. Training will include:

• When PPE use is required

• What type of PPE is required

• How to put PPE on, take it off, adjust it, and wear it

• PPE limita�ons

• How long PPE is useful and how to dispose of it

• How to clean and maintain PPE to ensure it is sanitary and in reliable condi�on

• How to report and replace defec�ve or damaged PPE; never use defec�ve or damaged PPE

Retraining

Retraining is necessary when:

• There are changes to the workplace that make the previous training obsolete

• There are changes in the type of PPE

• The employee shows improper use, a lack of use, or insufficient skill or understanding in selec�ng PPE, the necessity of PPE, the use of PPE, and its limita�ons

Documenta�on

Records of training will be kept at the local office and will include:

• Employee name(s)

• Training dates

• Subject of the training

RESPIRATORY PROTECTION

1.0 PURPOSE

The IT Landes, hereina�er referred to as “the Company,” respiratory protec�on program is designed to meet or exceed federal safety standards. The Company will make every atempt to remove poten�ally harmful vapors and exposure to oxygen-deficient hazards from the workplace environment. Respiratory equipment shall be provided at no cost to employees that may be exposed to harmful vapors and oxygen-deficient atmospheres. Respirators will be provided during emergencies with high risk of exposure and whenever engineering controls do not effec�vely eliminate respiratory hazards.

2.0 SCOPE

This program is applicable to all Company projects, opera�ons, employees, and contractors.

3.0 RESPIRATORY PROGRAM ADMINISTRATOR

Responsibility for the respiratory protec�on program falls to the safety manager who must ensure that the requirements are followed.

The administrator must have appropriate training, a thorough knowledge of the program, and be able to conduct evalua�ons.

The Company recognizes that individual supervisors will need to implement and enforce most of this program. Performance problems will be reported by the program administrator to the appropriate manager. The manager is responsible for implemen�ng a plan to resolve performance problems. The project manager or their designee carries the responsibility of administering all aspects of the respiratory protec�on program.

Program administrator responsibili�es include, but are not limited to:

• Administering an annual writen evalua�on of the respiratory protec�on program. The evalua�on must be completed by December 31st of each year.

• Making certain that respirators and their required parts are in sufficient supply. This duty may be delegated to a designee, but the program administrator maintains overall responsibility. The �tle of the designee to whom this duty is assigned is the project manager or field supervisor.

• Determining hazards and providing only those respirators cer�fied by NIOSH based on those hazards.

• Ensuring that all workers who may need to use a respirator have been trained in how to use, select, and know the limita�ons of the respirators that may be used. This must be done before the respirator is used for the first �me. The training may be delegated to another person, but the program administrator has the overall responsibility of ensuring that all employees are suitably trained.

• Ensuring that those who use respirators have been evaluated by a medical professional and deemed fit to use the type of respirator required for their job. Medical evalua�ons are to be completed before an employee is assigned to a task that involves the use of a respirator.

• Establishing that all workers who use respirators are tested at least once a year for fit, or more o�en if other federal requirements s�pulate it.

• Making certain that each individual has their own respirator and ensuring that all respirators are cleaned regularly and stored in a clean, easily accessible area. If this duty is delegated, the program administrator s�ll maintains final responsibility over the task.

• Selec�ng respirators based on the hazards that are encountered. This program details basic types of respirators used at this site and which tasks they are used for. In certain circumstances, the program administrator may consult with health and safety staff for assistance in selec�ng the appropriate respirators

• Ensuring that employee exposure is monitored to ensure correct respirator type is used. Exposure monitoring may be delegated to others; however, the program administrator s�ll maintains final responsibility of monitoring comple�on and to request assistance, when necessary.

• Monitoring employees who wear respirators to ensure the employees leave the area to wash, change respirator cartridges, or if break through or resistance is detected.

• Enforcing the program requirements for the selec�on, use, storage, maintenance, and fit are followed.

• Seeing to it that there is no exchange of parts between brands of respirators.

• Guaranteeing that respirators, required training, and medical evalua�ons are provided to the employees at no cost to them.

4.0 MEDICAL REQUIREMENTS

General

A medical evalua�on will be provided by the Company to evaluate the employee’s ability to safely use a respirator before the employee is fited or uses a respirator in the workplace. Should the employee no longer be required to use a respirator, the Company may suspend medical evalua�ons for that employee.

Medical Evalua�on Procedures

Medical evalua�ons will be performed by a physician or other licensed healthcare professional selected by the Company. These evalua�ons will be conducted using a medical ques�onnaire or an equivalent measure.

Medical evalua�ons will be conducted prior to fit tes�ng, confiden�al, and conducted during normal business hours at a convenient �me and loca�on. Medical evalua�on results must be understandable. The employee will be given an opportunity to discuss the results with a physician or PLHCP.

Supplemental Informa�on for the PLHCP

In order to make an informed recommenda�on, the following informa�on will be provided to the PLHCP to help determine whether an employee is able to use a respirator:

• Type and weight of the respirator to be used by the employee

• Extent and frequency of respirator use, including emergency use

• Physical work effort expected of the employee

• Protec�ve clothing and equipment to be worn in addi�on to the respirator

• Extreme varia�ons in temperature and humidity that may be encountered by the employee

The PLHCP will be given a copy of the Company’s respiratory protec�on program.

Note: When a PLHCP is replaced, the Company is responsible for ensuring that the new PLHCP is provided with this informa�on either by providing the documents directly or by transfer of documents from the former PLHCP. Employees will not be reevaluated just because a new PLHCP is selected.

Medical Determina�on

To aid the Company in determining an employee’s ability to safely use a respirator, the Company will get a writen recommenda�on from the PLHCP. The PLHCP’s recommenda�on will contain the following informa�on:

• Whether or not the employee is subject to any medical condi�ons or workplace condi�ons that may prevent the employee from being medically able to use the respirator

• Recommenda�ons for follow-up evalua�ons if necessary

• A signed statement that the employee has received a copy of the PLHCP’s writen recommenda�on

The safety manager will receive a copy of all recommenda�ons.

Addi�onal Medical Evalua�ons

The Company will provide addi�onal medical evalua�ons according to the program requirements if:

• An employee discloses medical signs or symptoms that may affect the employee’s ability to use a respirator.

• A supervisor, the program administrator, or a PLHCP recommends that an employee should be reevaluated

• Informa�on from the procedures set forth in this program, including observa�ons during fi�ng, indicates that the employee needs to be reevaluated.

• Changes in workplace condi�ons, such as an increase in physical work effort or changes in protec�ve clothing or temperature, that may create increased physiological burden on the employee.

Worksite Respirator Procedures

Each worksite that requires the use of respirators shall have site procedures that adhere to the guidelines set forth in this program. Addi�onal procedures may be enforced by the client and will be followed. The following site-specific informa�on must be included:

• Iden�fica�on of site-specific hazards that require respiratory protec�on

• Selec�on of respiratory equipment that shall be appropriate to the par�cular hazards, characteris�cs, and concentra�on levels at the site

• Iden�fica�on of specific brands and models of recommended respiratory equipment

• Confirma�on that all users of respiratory protec�on are qualified, trained, and competent according to the guidelines set forth in this program (i.e., approved medical evalua�on, fit tested, and trained annually)

5.0 RESPIRATORY SELECTION CRITERIA

Respiratory equipment is selected based on the hazards the employee is exposed to. The Company will:

• Iden�fy hazards

• Provide respirators according to those hazards and factors that affect performance

• Iden�fy specific brands and models to be used.

• Provide informa�on on es�mated exposures and contaminants

Hazard Iden�fica�on

Due to the variety of work loca�ons, the Company will iden�fy respiratory hazards according to specific worksite safety plans. Common respiratory hazards that employees may be exposed to include:

• Chemical par�cles

• Gases

• Oxygen-deficient condi�ons

• Fumes

• Dust

Characteris�cs of Hazardous Opera�ons or Processes

• Shaping opera�ons, including cu�ng, filing, sawing, grinding, drilling, and milling

• Solid opera�ons, including pouring, mixing, separa�ng, conveying, crushing, loading, extrac�ng, bagging, and demolishing

• Liquid opera�ons, including degreasing, spraying, pain�ng, dipping, etching, cleaning, brushing, coa�ng, pla�ng, mixing, pickling, galvanizing, and other chemical reac�ons

• Hot opera�ons, including soldering, mel�ng, burning, melding, welding, and other chemical reac�ons.

• Pressurized spraying, including applying pes�cides, cleaning parts, sand blas�ng, degreasing, and pain�ng

Gaseous Contaminants

• Inert gases (neon, argon, helium, etc.), which displace air to create oxygen deficiencies but do not metabolize in the body

• Alkaline gases (NH3, etc.), which are alkalis or create alkalis when they react with water

• Acidic gases (HCL, SO2, H2S, etc.), which are acids or create acids when they react with water

• Organic gases (acetone, butane, etc.), which exist as true gases or vapors from organic liquids

• Organometallic gases (organo-phosphates, tetraethyl lead, etc.), which have metals atached to organic groups

Par�culate Contaminants

• Smoke is a combina�on of chemically generated gases and airborne par�cles (solid and liquid) of organic origins (0.01 to 0.3µm).

• Fumes are par�cles of solid condensa�on (0.1 to 1.0µm diameter).

• Dusts are solid par�cles (0.5 to 10µm diameter) generated by mechanical means.

• Mists are liquid par�culate mater (5 to 100µm diameter).

Respirator Selec�on

When selec�ng a respirator, the following factors should be considered:

Contaminant Type and Concentration

The selected respirator model, type, and affiliated parts, such as cartridges and filters, are determined by the contaminant type and concentra�on. The concentra�on is obtained by taking a sample from the atmosphere.

Identification of Hazardous Area Locations

Hazardous areas include confined spaces, those exposed to nearby contaminants, etc.

Worker Activity

Worker ac�vi�es include being exposed to extreme heat or cold, wearing a welding hood, etc.

Types of Respirators

• Air-purifying respirators are either half masks or full-face masks that filter dusts, fumes, gases, mists, or vapors through mechanical or chemical cartridges. They are not suitable for environments that are oxygen deficient. This can result when another gas displaces the oxygen in the atmosphere or by a chemical reac�on that consumes the oxygen. When oxygen levels drop below 19.5%, a source of supplied air or supplied-air respirators are required. Oxygen levels below 16% are considered very dangerous and could result in death. Contact the safety manager or qualified safety representa�ve of the client to help determine the appropriate cartridge for air-purifying respirators. Take into considera�on the informa�on on the SDS regarding the substance that requires filtering. As soon as the respirator’s user can detect an odor, irrita�on, or taste the contaminant, the cartridge should be replaced immediately. All cartridges and filters should be changed at the beginning of the shi�. All cartridges are assigned a color designa�ng the type of contaminant they will filter:

o White: Acid gas

o Black: Organic vapors

o Green: Ammonia gas

o Yellow: Acid gases and organic vapors

o Purple: Radioac�ve materials

o Orange: Dust, fumes, and mists

o Olive: Other gases and vapors (mul�-contaminants)

• Powered air-purifying respirators are those that pass contaminated air through a filter using a blower. Like regular air-purifying respirators, they filter dusts, fumes, gases, mists, or vapors. The purified air goes into a mask or hood.

• Supplied-air respirators provide the best protec�on against poten�ally highly toxic materials. Supplied-air respirators are air-line respirators or self-contained breathing apparatuses (SCBAs). SCBAs allow a limited amount of air to be carried by the user, providing fewer restric�ons and more mobility than air-line respirators.

• Air-line respirators are connected to a central supply of fresh air via a hose. Fresh air can be obtained from a compressed air cylinder or an air compressor with a minimum of Grade D breathing air.

• Emergency escape breathing apparatuses (EEBAs) provided oxygen in 5, 10, or 15-minute increments depending on the apparatus. EEBAs are to be used in emergencies when an employee needs to escape a situa�on that is immediately dangerous to life or health (IDLH).

Note: The Company does not permit employees to work in environments that are IDLH.

To maintain NIOSH and MSHA approval of respirators, mixing parts (e.g., valves, cartridges, airline hoses, gaskets, etc.) between respirator manufacturers is strictly prohibited. For example, do not use MSA cartridges or gaskets with a North Safety product.

Brand and Models

North Safety, NIOSH-cer�fied respirators have been selected for use by the Company. Only the North Safety brand may be used to be in compliance with the policies and condi�ons of this respiratory protec�on program. Addi�onally, NIOSH-cer�fied respirators are selected based on the hazards that the worker is exposed to.

The specific model to be used will be based on the type of hazard encountered, oxygen levels, concentra�on of the contaminant, type of work being performed, and work environment. Selec�ons shall be made by iden�fying the appropriate North Safety respiratory equipment for the work performed and the encountered hazard using the following guides:

• NIOSH Pocket Guide to Chemicals

• North Respirator Selec�on Guide

• North Cartridge Selec�on Guide

Es�mate of Exposures and Contaminant Informa�on

• Employees are not permited to enter IDLH environments.

• Oxygen levels shall be maintained at a normal level.

• Employees will not be exposed to atmospheric condi�ons that contain concentra�ons exceeding the STEL or PEL for a par�cular hazard.

6.0 RESPIRATOR FIT TESTING

Prior to an employee using a respirator with nega�ve or posi�ve-pressure, �ght-fi�ng facepieces, the employee must be fited with the same make, model, size, and style of respirator that will be used when situa�ons require it.

This por�on of the document lays out the types of fit tests allowed, how to conduct them, and how the results of the tests are to be used.

Employees using respirators must be fit tested annually at a minimum, and more frequently if federal requirements dictate. Supplied air respirators must also be tested for fit.

Qualita�ve fit tests (QLFTs) or quan�ta�ve fit tests (QNFTs) are required for all employees using �ght-fi�ng facepiece respirators. Fit tests for �ght-fi�ng, face-piece respirators must be conducted prior to an employee using the respirator, when the employee uses a different respirator or facepiece (make, model, size, or style), and at least once a year a�er that.

Addi�onal fit tests are required if the employee reports or a Company supervisor, program administrator, or PHLCP observes changes in the physical condi�on of the employee that could affect fit. These physical condi�ons include, but are not limited to, obvious changes in body weight, cosme�c surgery, facial scarring, or dental changes.

If an employee passes a QLFT or QNFT and later no�fies the Company supervisor, program administrator, or PHLCP that the fit is not suitable, the employee will be given opportunity to choose a different respirator facepiece to be retested.

Fit tests are conducted according to OSHA-accepted QLFT or QNFT protocol. The accepted procedures and protocols are outlined in this sec�on.

QLFT is only to be used for fit tes�ng nega�ve-pressure, air-purifying respirators that are required to have a fit factor of 100 or less. Half-face, air-filtering respirators are fit tested with a smoke irritant. Full-face respirators must be fit tested using Portacount.

If protocol determines that the fit factor is 100 or greater for �ght-fi�ng, half facepieces; or 500 or greater for �ghtfi�ng, full facepieces, the QNFT has been passed with that par�cular respirator.

The nega�ve pressure mode will be performed during the QLFT or QNFT to fit test �ght-fi�ng, atmospheresupplying respirators and �ght-fi�ng, powered, air-purifying respirators. The nega�ve pressure mode will be used for the fit test regardless of whether the usual mode of opera�on for that respirator is posi�ve or nega�ve.

To conduct a QLFT for these respirators, the facepiece will be converted into a nega�ve pressure respirator with appropriate filters. Alternately, an iden�cal nega�ve-pressure, air-purifying facepiece with the same sealing surfaces may be subs�tuted.

To conduct a QNFT for these respirators, the facepiece will be modified to allow sampling inside the facepiece’s breathing zone, halfway between the nose and mouth. This will be accomplished by installing a fixed sampling probe onto a subs�tute facepiece or by using a sampling adapter, which provides a temporary means of sampling the air.

Any facepieces that are modified for the purposes of fit tes�ng will be completely restored to their NIOSH-approved configura�ons before they are used by employees in the workplace.

Fit Test Procedures

The requirements in this sec�on apply to all OSHA-accepted QLFT and QNFT fit test methods.

The test subject will be provided with a sufficient variety of respirator sizes to select the most acceptable respirator that correctly fits the subject.

Before beginning the selec�on process, the subject will be shown how to put a respirator on, how to posi�on it on the face, how to set strap tension, and how to evaluate acceptable fit. A mirror will be provided to aid the test subject in determining the posi�on and fit of the respirator. The instruc�on provided during fit tes�ng does not subs�tute for the formal training on respirator use; it is only a review.

The test subject will be informed that a respirator is to be selected that provides the best fit. Each respirator presented will be of a different size and shape. If fited and used properly by the subject, the respirator will provide sufficient protec�on.

Test subjects will be instructed to hold up each chosen facepiece to the face to quickly eliminate those that are obviously a poor fit. The acceptable facepieces are noted.

The most comfortable mask must be put on and worn for five minutes or more to evaluate comfort. To assess comfort, the following points should be considered:

• If the subject is not familiar with how to use a respirator, they will be instructed to put the mask on several �mes and to adjust the straps each �me, so the subject becomes well-versed in se�ng the proper tension on the straps

• Posi�on of the mask on cheeks and face

• Posi�on of the mask on nose

• Room for eye protec�on

• Room to talk

The following criteria will be used to evaluate the suitableness of the respirator’s fit:

• Proper placement of chin

• Sufficient strap tension

• Proper fit across the bridge of the nose

• Appropriate distance from nose to chin

• Respirator’s tendency to slip

• Subject’s self-evalua�on (in a mirror) of fit and posi�on

Evalua�ons should incorporate use of the fit test form.

User Seal Check

Prior to beginning the nega�ve and posi�ve-pressure checks, subjects will be instructed to place the mask on the face and move the head up and down and from side to side while taking slow, deep breaths. The subject will perform a user seal check by using either the posi�ve or nega�ve-pressure seal checks outlined below:

Positive-Pressure Check

Remove the exhala�on valve cover and close off the exhala�on valve. Exhale gently into the facepiece. If a slight posi�ve pressure builds up inside the facepiece with no outward leaks of air at the seal, the face fit is sufficient. Carefully replace the exhala�on valve cover a�er conduc�ng the pressure check.

Negative-Pressure Check

Replace the filter seal over the opening of the canister or cartridge. If the filter seal is not available, cover the inlet opening with the palm of the hand. If the hand does not sufficiently cover the inlet opening, cover it with a thin latex or nitrile glove. Inhale gently. The facepiece should collapse slightly. Hold the breath for ten seconds. If the facepiece remains slightly collapsed and no air leaks inward, the �ghtness of the respirator is sufficient.

The test cannot be conducted if the subject has hair growth at the areas with the skin seals with the surface of the respirator. This includes a beard, moustache, sideburns, or stubble. Any apparel or accessories, including glasses, that interfere with fit should be removed.

If the subject determines that the fit of the respirator is unsa�sfactory, the subject will be allowed to select a different respirator and will be retested. The fit test will be terminated immediately if the subject has difficulty breathing during the tests. The subject will be referred to a physician or other healthcare profession for evalua�on regarding whether the subject can wear a respirator in the performance of their job du�es.

Subjects will be given a descrip�on of the fit test and the subject’s responsibili�es during tes�ng prior to beginning the test. This will include a descrip�on of the exercises to be performed by the test subject. The respirator must be worn for at least five minutes prior to beginning a test.

The subject must wear any safety equipment that may be required during actual respirator use while the fit test is performed.

Test Exercises

Each test exercise lasts one minute except the grimace test, which lasts 15 seconds. The test conductor will ask the subject ques�ons about the comfort of the respirator upon comple�on of the procedures. If the respirator has been deemed unacceptable during or a�er comple�on of the tests, another model will be tested. If the subject cannot perform the test exercises due to medical or health condi�ons, the fit test will not be performed. In this case, the subject is prohibited from using a respirator un�l all elements of the fit test can be completed.

The subject will not be permited to adjust the respirator once the exercises begin. Any adjustment made voids the test and the test must be repeated.

All fit tes�ng methods will require the following exercises to be performed:

• Normal Breathing: The subject will be required to breathe normally while in a standing posi�on without talking.

• Deep Breathing: The subject will be asked to stand in a normal posi�on and take slow, deep breaths, taking care not to hyperven�late.

• Turning Head Side to Side: While standing in place, the subject will be required to turn the head from side to side, to the farthest posi�on at each side. At the farthest posi�on, the subject will be asked to hold and inhale.

• Moving Head Up and Down: While standing in place, the subject will be asked to move the head in an up and down mo�on. The subject will be asked to inhale when the head is in the up posi�on.

• Talking: The subject will be asked to speak slowly and loud enough for the voice to be heard by the test conductor. For this exercise, the subject will read from the “Rainbow Passage” below for one minute.

o “When the sunlight strikes raindrops in the air, they act like a prism and form a rainbow. The rainbow is a division of white light into many beau�ful colors. These take the shape of a long round arch, with its path high above, and its two ends apparently beyond the horizon. There is, according to legend, a boiling pot of gold at one end. People look, but no one ever finds it. When a man looks for something beyond reach, his friends say he is looking for the pot of gold at the end of the rainbow.”

• Grimacing: The test subject will be asked to grimace by smiling or frowning. This exercise is only performed during QNFT tests.

• Jogging in Place: The subject will be required to jog in place for one minute while taking care to be aware of their surroundings.

• Normal Breathing: Repeat the first exercise.

QLFT Protocols

The Company requires that persons conduc�ng QLFTs are able to calibrate equipment, ensure equipment is in proper working order, prepare test solu�ons, properly perform tests, and recognize invalid tests. The Company is responsible for ensuring that QLFT equipment is clean, well-maintained, and opera�onal within its intended parameters.

Irritant Smoke (Stannic Chloride) Protocol

This QLFT tests for leakage into the respirator by using the subject’s reac�on to chemical irritants released in “smoke,” produced by a stannic chloride ven�la�on smoke tube.

General requirements and precau�ons for the irritant smoke protocol:

• Respirators will be equipped with high-efficiency par�culate air (HEPA) or P100 series filters for this test.

• The test shall not be performed in an enclosure. The test subject shall not use a hood; only stannic chloride smoke tubes are permited for use during this protocol.

• The smoke from this test may be irrita�ng to the eyes, nasal passages, and lungs. The test conductor will take precau�onary measures to minimize the smoke irritant the subject is exposed to. Sensi�vity varies according to the individual; some may experience greater irrita�on to the smoke. Precau�ons will be taken when performing the screening to use only the minimum amount of smoke necessary to elicit an olfactory response from the test subject.

• This fit test will be conducted in an adequately ven�lated area to prevent buildup of irritant smoke and to avoid exposing the test conductor to smoke.

• The subject must be able to demonstrate that they can detect a weak concentra�on of the irritant smoke.

• The test conductor will break both ends of the stannic chloride ven�la�on smoke tube. One end of the smoke tube will be atached to a low flow air pump to administer 200 milliliters per minute, or an aspirator squeeze bulb. The conductor will cover the opposite end of the smoke tube with a short piece of tubing to guard against poten�al injury from the jagged end.

• The test conductor will inform the test subject that smoke can irritate the eyes, nasal passages, and lungs and will instruct the test subject to keep the eyes closed while the test is performed.

• The test subject will be permited to smell a weak concentra�on of the smoke before pu�ng the respirator on in order to become familiar with its irrita�ng proper�es and to determine if the subject can detect the smoke’s irrita�ng proper�es. The test conductor will carefully administer a small amount of the smoke directed toward the test subject to determine if they can detect it.

Irritant Smoke Fit Test Procedure

• The test subject will put the respirator on without assistance and will perform the required user seal checks.

• The test subject will be instructed to keep the eyes closed if they are wearing a half-face respirator.

• The test conductor will direct the stream of smoke from the tube toward the face seal area of the subject by using a low flow pump or squeeze bulb. The test conductor will be 12 inches or more from the facepiece and will move the smoke stream around the en�re perimeter of the mask. Gradually, the test conductor will make two more passes (for a total of three �mes) around the perimeter of the mask, moving closer each �me. The test conductor will not move the smoke tube closer than 6 inches.

• If the irritant smoke does not elicit a response from the test subject, proceed with the test exercises.

• The exercises in the “Test Exercises” sec�on will be performed by the test subject. The respirator seal will con�nue to be challenged by direc�ng smoke around the perimeter at a distance of 6 inches.

• If the test subject reports detec�on of the irritant, this is a failed test. The test subject must repeat the en�re sensi�vity check and fit test procedure before being retested.

• If the test subject passes the irritant smoke test with no evidence of a response such as irrita�on or involuntary cough, the subject will be screened for sensi�vity again a�er the respirator is removed, using smoke from the same tube used during the fit test. If they s�ll react to the smoke, the fit test is valid. If there is no response to the irritant smoke, the results of the fit test are invalid.

• The glass tube will be properly disposed of a�er conduc�ng the screenings and fit test.

QNFT Protocols

OSHA has deemed it acceptable to use controlled nega�ve pressure and suitable instrumenta�on to measure a facepiece’s leak rate by volume in order to quan�fy the respirator.

The Company requires that all persons administering QNFTs are capable of calibra�ng equipment, ensuring equipment is in proper working order, performing tests properly, calcula�ng fit factors properly, and recognizing invalid tests.

The Company is responsible for ensuring that equipment for QNFT is clean, well-maintained, and calibrated according to the manufacturer’s recommenda�ons in order to operate as it was designed to.

Portacount Fit Test Requirements

• Examine the respirator to ensure it is fited with a high-efficiency filter. Ensure the sampling probe and line are atached to the facepiece according to established standards.

• Instruct the subject to put the respirator on five minutes prior to the beginning of the test to rid the respirator of ambient par�cles trapped inside and allow the subject to ensure the respirator is comfortable. The subject must already have been trained on proper use of the respirator.

• Check the following to ensure the respirator fits the subject sufficiently:

o Proper placement of chin

o Sufficient strap tension

o Proper fit across the bridge of the nose

o Appropriate distance from nose to chin

o Respirator’s tendency to slip

o Subject’s self-evalua�on (in a mirror) of fit and posi�on

• Instruct the subject to perform a user seal check. If a leak is detected, examine the cause. If it is determined to be caused by an inadequately-fi�ng facepiece, instruct the subject to select a different size of the same model or a different model of respirator.

• Proceed with the test ensuring the Portacount is operated according to the manufacturer’s instruc�ons.

• Instruct the test subject to perform the exercises according to the “Test Exercises” sec�on of this procedure.

• A�er the subject has completed the test exercises, ques�on the subject about the comfort of the respirator. If the fit has become unacceptable, instruct the subject to select another respirator model.

Portacount Test Instrument

The Portacount automa�cally stops and calculates the overall fit factor for all of the exercises completed. The overall fit factor is the one that counts; this is determined by a pass or fail message. If the test reads pass, the test is over. Because the criteria for pass or fail are programmable by the user, the test conductor will ensure that the programmed criteria meet the requirements for the respirator’s minimum performance.

Test results for passing tests will be sent to the safety manager and kept on file. This record must contain:

• The subject’s name

• Make, model, style, and size of respirator

• Overall fit factor

7.0 RESPIRATOR USE, MAINTENANCE, AND CARE

The Company is required to provide for use, inspect, repair, store, clean, and disinfect respirators used by employees. All respiratory protec�ve equipment shall be properly stored and inspected by the Company.

Use

• Factors that can affect the mask to face seal are not permited. This includes, but is not limited to, glasses, clothing, and facial hair.

• A posi�ve and nega�ve-pressure check must be conducted each �me a respirator is worn.

Cleaning and Disinfec�ng Requirements

The Company will provide each employee who requires a respirator one that is clean, sanitary, and in proper working order. The program administrator and safety manager are responsible for the maintenance and care of respiratory equipment. The Company will ensure that respirators are cleaned and sani�zed according to the procedures in the respiratory protec�on program or procedures recommended by the manufacturer if they are equivalently effec�ve. Respirators are required to be cleaned and disinfected:

• When issued to an employee who will use the respirator exclusively, the respirator will be cleaned as o�en as necessary by the employee to maintain sanitary condi�on.

• When used in training and fit tes�ng, the respirator must be cleaned by the safety manager or their designee a�er each use.

• Employees who are assigned cartridge respirators are responsible for the cleaning, inspec�on, and proper storage of the respirator.

Cleaning Procedures

• Remove the respirator’s filters, cartridges, and canisters. Facepieces should be disassembled by removing speaking diaphragms, valve assemblies, hoses, and any other components as recommended by the manufacturer. Defec�ve parts should either be discarded or repaired.

• Wash all parts in a solu�on of warm water and mild detergent or with a manufacturer-recommended cleaner. A non-wire, s�ff-bristled brush may be used to help remove dirt.

• Rinse all the washed components in clean, warm, running water. Drain the parts a�er rinsing.

• If the cleaner does not contain a disinfectant, parts should be submerged in a disinfectant for two minutes. Alterna�vely, alcohol wipes may be used, so long as they are intended for use with respirators.

• Rinse parts in clean, warm, running water. It is important to rinse thoroughly because dried detergents or disinfectants on facepieces may cause derma��s. These cleansing agents may also deteriorate or corrode rubber and metal parts if they are not completely removed Drain the parts a�er rinsing.

• Components should be hand-dried with a clean, lint-free cloth or air dried. Reassemble the facepiece, replacing filters, cartridges, and canisters where necessary. Test the respirator to ensure that all components work properly.

Storage

• Respirators and respiratory equipment must be stored properly to protect them from contamina�on, extreme temperatures, and other damaging condi�ons.

• Respiratory equipment that is intended for use in emergencies will be stored in an easily accessible area that is clearly marked.

Inspec�on

• Respirators that are used rou�nely must be inspected by its assigned employee before and a�er each use and during cleaning.

• The employee must also check the respirator for proper func�on, �ghtness of connec�ons, and condi�on of its parts (e.g., the facepiece, valves, head straps, connec�ng tubes, and cartridges, canisters, or filters).

• Elastomeric parts must be checked for pliability and possible signs of deteriora�on.

• Emergency respiratory equipment must be inspected monthly, at a minimum, and before and a�er each use.

• Respiratory equipment used solely for escape must be inspected before carrying into the workplace.

Breathing Air Quality and Use

The Company will make certain that compressed air complies with the specifica�ons below.

• Compressed breathing air shall meet at least the requirements for Type 1 Grade D breathing air described in ANSI CGA G-7.1-1989 (Commodity Specifica�on for Air), to include:

o Oxygen content (v/v) of 19.5-23.5%

o Carbon monoxide (CO) content equal to or less than 10 ppm

o Hydrocarbon (condensed) content of 5 mg per cubic meter of air or less

o Carbon dioxide content equal to or less than 1,000 ppm

o Lack of no�ceable odor

• The Company will ensure that oxygen is not used in compressed air units

• The Company will ensure that only equipment designed for oxygen service or oxygen distribu�on will use oxygen concentra�ons greater than 23.5%.

• The Company will ensure that cylinders used in supplying breathing air to respirators meet DOT requirements:

o Cylinders have a cer�ficate of analysis from the supplier sta�ng that the breathing air meets the requirements for Type 1 Grade D breathing air

o Moisture content of a cylinder does not exceed a dew point of -50°F at 1 atmosphere pressure

o Cylinders are tested and maintained as recommended in DOT 49 CFR Part 173 and Part 178 (Shipping Container Specifica�on Regula�ons)

• The Company will ensure that compressors used in supplying breathing air to respirators are constructed and placed in a manner that:

o Prevents entry of contaminated air into the air-supply system.

o Minimizes moisture content to keep the dew point at 1 atmosphere pressure to 10°F below the ambient temperature.

o Have appropriate in-line, air-purifying, sorbent beds and filters to protect the quality of the breathing air. Sorbent beds and filters must be maintained regularly and refurbished or replaced periodically according to the manufacturer’s recommenda�ons

o Have a tag maintained at the compressor that contains the most recent change date and the signature of the authorized person who performed the change

• For compressors that are not oil-lubricated, the Company will ensure that carbon monoxide levels of the breathing air do not exceed 10 ppm.

• For oil-lubricated compressors, the Company will use a carbon monoxide and/or high-temperature alarm to monitor levels of carbon monoxide. If using only high-temperature alarms, the air supply must be monitored at regular intervals to sufficiently prevent carbon monoxide in the breathing air from exceeding 10 ppm.

• The Company will ensure that breathing air couplings are incompa�ble with outlets for non-breathable worksite air and other gas systems so as to prevent asphyxia�ng substances from being introduced into the breathing air lines.

Repairs

The Company will ensure that respirators that fail inspec�on or are otherwise deemed defec�ve are immediately removed from service. The defec�ve respirators will be discarded, repaired, or adjusted according to the following procedures:

• Adjustments and repairs are to be made only by authorized persons trained to perform those opera�ons.

• Only the respirator manufacturer’s NIOSH-approved parts designed for the respirator may be used.

• Repairs will be made according to the manufacturer’s instruc�ons, according to the type and extent of repairs needed to be performed.

Voluntary Use

If an employee elects to voluntarily wear a respirator when not required by this program, they will be advised of the following during their training:

• When properly selected and worn, respirators are an effec�ve form of protec�on against designated hazards. Use of respirators is encouraged, even if exposures are below the exposure limit, to provide addi�onal protec�on and comfort for employees.

• If a respirator is not used properly, maintained, and kept clean, the respirator may become a hazard to the employee.

• Certain precau�ons should be taken when employees are provided with respirators for voluntary use to include the following:

o Read thoroughly and follow all instruc�ons as set forth by the manufacturer on the use, cleaning, care, maintenance, warnings, and limita�ons of the respirator.

o Select NIOSH-cer�fied respirators to protect against the contaminant of concern. A label or statement of cer�fica�on should be on the respirator or its packaging. This cer�fica�on details what the respirator is designed for and how much protec�on it provides.

o Do not wear respirators into contaminated areas for which the respirator is not designed and cer�fied to protect against. For example, a respirator designed to filter dust par�cles does not protect against vapors, gases, or very small solid par�cles of fumes or smoke.

o Keep track of your respirator to avoid mistakenly using someone else’s respirator and vice versa.

8.0 WORKPLACE MONITORING

The Health Department has implemented a program to monitor poten�al employee exposures. Project personnel may be assigned to the task of air monitoring. Direct-reading instruments will be u�lized to aid in characterizing poten�al exposures. The data collected will be used to determine the respiratory equipment’s appropriateness.

9.0 RECORDKEEPING

The Company will establish and maintain writen records regarding medical evalua�ons, fit tes�ng, and the respirator program. Medical evalua�on records will be retained and made available according to 29 CFR 1910.1020. The Company will give the employee an opportunity to discuss the ques�onnaire and the results of the employee’s examina�on with the PLHCP.

Records will be treated in a confiden�al manner and maintained in the files of the safety manager in the corporate office.

10.0 PROGRAM EVALUATION

The Company will conduct evalua�ons of the workplace and environment whenever necessary to ensure that the policies and procedures of the current program are being implemented and con�nue to be effec�ve.

The Company will, on a regular basis, consult employees who use respirators to evaluate opinions on the effec�veness of the program and to iden�fy any problems with said program. Iden�fied problems will be corrected. Factors to be evaluated include, but are not limited to:

• Respirator fit

• Ability to use the respirator without interfering with work du�es and performance

• Proper usage of the respirator under the usual condi�ons the employee encounters

• Proper maintenance of the respirator

11.0 TRAINING

Every employee will par�cipate in respirator training ini�ally and at least annually thereina�er if their job classifica�on requires it. Training will be provided prior to requiring the employee to use the respirator and shall address employee knowledge of the following:

• Respirators and fit

• Wearing, use, and limita�ons

• Emergency situa�ons

• Fit checks

• Maintenance and storage

• Medical signs and symptoms of effec�ve use

• General OSHA standards and requirements

Retraining

Employees must be retrained annually and when the following circumstances apply:

• Changes in the workplace or the type of respirator make the previous training obsolete.

• The employee’s knowledge is found to be inadequate

• Other situa�ons that arise that make retraining necessary to ensure employee safety

RETURN TO WORK

1.0 PURPOSE

Ge�ng injured employees with ac�ve workers’ compensa�on cases safely back to work as soon as possible is beneficial for everyone. This policy establishes channels of communica�on between IT Landes, hereina�er referred to as “the Company,” and the injured employee and encourages them to return to light-duty jobs/tasks (if any) as the employee’s medical condi�on allows.

2.0 POLICY

• The Company will inform the Workplace Safety and Insurance Board that it has a return-to-work program when an employee suffers a lost-�me injury as a result of a workplace injury. The Company, through their applicable workers’ compensa�on carrier, will also contact the injured employee on a weekly basis un�l the employee has returned to work.

• The injured employee will cooperate with the Company in submi�ng and obtaining appropriate documenta�on and in returning to work for light-duty jobs that are offered and that they are medically able to do.

• The Company will provide modified work opportuni�es to injured employees whenever prac�cable.

• The injured employee con�nues to receive the same rate of pay while on light-duty work that they received before the injury in accordance with the applicable workers’ compensa�on guidelines.

• Any injured employee unable to return to work will be contacted regularly by the Company to determine the availability of the worker to return to work on light duty or for their regular job.

• Physical demands are assessed for modified-duty jobs to ensure they can be performed safely by injured employees.

• The Company has a partnership with (insert your division-agreed-upon medical group) to assist in the return-to-work program. They can be located at (insert address or atach a separate list with mul�ple facility loca�ons).

• Medical records for injured employees must be kept confiden�al.

Main steps in the return-to-work program include:

• The injured employee will no�fy the atending physician that the Company has an early and safe return-towork program and ask for a Func�onal Abili�es Form to be filled out by the physician. This completed form will be submited to the Company.

• The injured employee will stay in touch with the Company and workers’ compensa�on carrier about their health status while the Company prepares and iden�fies light-duty work that meets the Func�onal Abili�es Form

• When the injured employee returns to work on a light-duty job, their supervisor will monitor the employee’s ability to do the light-duty job safely each day. The modified work provided to injured employees must be consistent with restric�ons provided by the healthcare provider.

• Physician restric�ons are provided to ensure that the restric�ons are followed.

• All documenta�on related to an incident will be maintained by the employer.

• If problems occur that jeopardize the injured employee’s healing process, the tasks in ques�on may stop and other, more suitable light-duty work may be atempted. If none exists, other accommoda�ons may be explored.

• The exit strategy involves a doctor’s visit that clears the now fully recovered worker to return to their preinjury job.

RIGGING AND MATERIAL HANDLING

1.0 PURPOSE

The purpose of this document is to outline the rigging material handling program for IT Landes, hereina�er referred to as “the Company.”

2.0 RESPONSIBILITIES

Management

• Implement the requirements of this program.

• Determine appropriate implementa�on (legisla�ve applicability) and enforcement of this program.

• Train employees on this program or select an outside training facility

Employees

• Follow the provisions set forth in this program.

3.0 POLICY

Only persons who are deemed competent or qualified by experience and training shall atach any loads to a li�ing device and only competent or qualified operators shall operate a crane while engaged in li�ing opera�ons.

4.0 TRAINING

All affected employees shall demonstrate competency and qualifica�ons through training based upon the following objec�ves:

• Proper hardware selec�on, such as hooks, bolts, eye bolts, ropes, chains, slings, etc., that is appropriate for the task at hand

• Inspec�on of equipment prior to use

• Safe methods of load connec�on/hookup

• How to safely secure each load (atach, li�, and guide while elevated, lower, and placement)

5.0 RIGGING MATERIAL HANDLING

• Defec�ve equipment shall not be used and must be immediately removed from service.

• Rigging equipment shall not be loaded beyond its recommended safe working load. Iden�fica�on markings, indica�ng rated capacity for the type(s) of hitch(es) used, the angle upon which it is based, and the number of legs if more than one shall be permanently affixed to the rigging.

• Rigging equipment, when not in use, shall be removed from the immediate work area so as not to present a hazard to employees.

• Tag lines shall be used unless their use creates an unsafe condi�on.

• Hooks on overhaul ball assemblies, lower load blocks, or other atachment assemblies shall be of a type that can be closed and locked, elimina�ng the hook throat opening. Alterna�vely, an alloy anchor type shackle with a bolt, nut, and retaining pin may be used.

• All employees shall be kept clear of loads about to be li�ed and of suspended load.

6.0 INSPECTION

All li�ing and rigging equipment must be cer�fied for current use and in good working order as verified/documented through pre-use inspec�ons.

Each day before being used, the sling, all fastenings, and atachments shall be inspected for damage or defects by a competent person designated by the Company. Addi�onal inspec�ons shall be performed during sling use where service condi�ons warrant. Damaged or defec�ve slings shall be immediately removed from service.

Alloy Steel Chains

• Welded alloy steel chain slings shall have permanently affixed, durable iden�fica�on sta�ng size, grade, rated capacity, and sling manufacturer.

• Hooks, rings, oblong links, pear-shaped links, welded or mechanical coupling links, or other atachments, when used with alloy steel chains, shall have a rated capacity at least equal to that of the chain.

• Job or shop hooks and links; makeshi� fasteners formed from bolts, rods, etc.; or other such atachments shall not be used.

The Company will not use alloy steel-chain slings with loads in excess of the rated capaci�es (i.e., working load limits) indicated on the sling by permanently affixed and legible iden�fica�on markings prescribed by the manufacturer.

Whenever wear at any point of any chain link exceeds that shown in Table H1, the assembly shall be removed from service.

Table H1: Maximum Allowable Wear at Any Point of Link

In addi�on to the inspec�on required by other paragraphs of this sec�on, a thorough periodic inspec�on of alloy steel-chain slings in use shall be made on a regular basis, and are to be determined on the basis of:

• Frequency of sling use

• Severity of service condi�ons

• Nature of li�s being made

• Experience gained on the service life of slings used in similar circumstances.

• Such inspec�ons shall in no event be at intervals greater than once every 12 months.

• The employer shall make and maintain a record of the most recent month in which each alloy steel chain sling was thoroughly inspected and shall make such record available for examina�on.

Wire Rope

The Company will not use improved plow steel-wire rope and wire rope slings with loads in excess of the rated capaci�es (i.e., working load limits) indicated on the sling by permanently affixed and legible iden�fica�on markings prescribed by the manufacturer.

• Protruding ends of strands in splices on slings and bridles shall be covered or blunted.

• Wire rope shall not be secured by knots, except on haul back lines on scrapers.

The following limita�ons shall apply to the use of wire rope:

• An eye splice made in any wire rope shall have not less than three full tucks. However, this requirement shall not operate to preclude the use of another form of splice or connec�on which can be shown to be as efficient, and which is not otherwise prohibited.

• Except for eye splices in the ends of wires and for endless rope slings, each wire rope used in hois�ng, lowering, or pulling loads shall consist of one con�nuous piece without knot or splice.

• Eyes in wire rope bridles, slings, or bull wires shall not be formed by wire rope clips or knots.

• Wire rope shall not be used if, in any length of eight diameters, the total number of visible broken wires exceeds 10% of the total number of wires, or if the rope shows other signs of excessive wear, corrosion, or defect.

• When U-bolt wire rope clips are used to form eyes, Table H2 shall be used to determine the number and spacing of clips.

• When used for eye splices, the U-bolt shall be applied so that the “U” sec�on is in contact with the dead end of the rope.

• Slings shall not be shortened with knots or bolts or other makeshi� devices.

• Sling legs shall not be kinked.

• Slings used in a basket hitch shall have the loads balanced to prevent slippage.

• Slings shall be padded or protected from the sharp edges of their loads.

• Hands or fingers shall not be placed between the sling and its load while the sling is being �ghtened around the load.

• Shock loading is prohibited.

• A sling shall not be pulled from under a load when the load is res�ng on the sling. Rigging equipment for material handling shall be inspected prior to use on each shi�, and as necessary during its use to ensure that it is safe.

• Defec�ve rigging equipment shall be removed from service.

The Company will ensure that rigging equipment has permanently affixed and legible iden�fica�on markings as prescribed by the manufacturer that indicate the recommended safe working load; not be loaded in excess of its

Table H2: Number and Spacing of U-Bolt Wire Rope Clips

recommended safe working load as prescribed on the iden�fica�on markings by the manufacturer; and not be used without affixed, legible iden�fica�on markings

Rigging equipment, when not in use, shall be removed from the immediate work area so as not to present a hazard to employees.

Special custom design grabs, hooks, clamps, or other li�ing accessories for such units as modular panels, prefabricated structures, and similar materials shall be marked to indicate the safe working loads and shall be proof tested prior to use to 125% of their rated load.

7.0 SCOPE

This sec�on applies to slings used in conjunc�on with other material handling equipment for the movement of material by hois�ng in employments covered by this part. The types of slings covered are those made from alloy steel chain, wire rope, metal mesh, natural or synthe�c fiber rope (conven�onal three strand construc�on), and synthe�c web (nylon, polyester, and polypropylene).

8.0 SLINGS

Minimum Sling Lengths

• Cable laid and 6 x 19 and 6 x 37 slings shall have minimum clear length of wire rope 10 �mes the component rope diameter between splices, sleeves, or end fi�ngs.

• Braided slings shall have a minimum clear length of wire rope 40 �mes the component rope diameter between the loops or end fi�ngs.

• Cable laid grommets, strand laid grommets and endless slings shall have a minimum circumferen�al length of 96 �mes their body diameter.

Safe Opera�ng Temperatures

Fiber core wire rope slings of all grades shall be permanently removed from service if they are exposed to temperatures in excess of 200°F.

When non-fiber core wire rope slings of any grade are used at temperatures below -60°F or above 400°F, recommenda�ons of the sling manufacturer regarding use at that temperature shall be followed.

End Atachments

Welding of end atachments, except covers to thimbles, shall be performed prior to the assembly of the sling.

All welded end atachments shall not be used unless proof tested by the manufacturer or equivalent en�ty at twice their rated capacity prior to ini�al use. The employer shall retain a cer�ficate of proof test and make it available for examina�on.

Wire rope slings shall have permanently affixed, legible iden�fica�on markings sta�ng size, rated capacity for the type(s) of hitch(es) used, the angle upon which it is based, and the number of legs (if more than one).

Wire rope slings shall not present a hazard to employees.

Employers must not use natural and synthe�c-fiber rope slings with loads in excess of the rated capaci�es (i.e., working load limits) indicated on the sling by permanently affixed and legible iden�fica�on markings prescribed by the manufacturer.

All splices in rope slings provided by the employer shall be made in accordance with fiber rope manufacturers recommenda�ons.

In manila rope, eye splices shall contain at least three full tucks, and short splices shall contain at least six full tucks (three on each side of the center line of the splice).

In layered synthe�c-fiber rope, eye splices shall contain at least four full tucks, and short splices shall contain at least eight full tucks (four on each side of the center line of the splice).

Strand end tails shall not be trimmed short (flush with the surface of the rope) immediately adjacent to the full tucks. This precau�on applies to both eye and short splices and all types of fiber rope. For fiber ropes under 1 inch in diameter, the tails shall project at least 6 rope diameters beyond the last full tuck. For fiber ropes 1 inch in diameter and larger, the tails shall project at least 6 inches beyond the last full tuck. In applica�ons where the projec�ng tails may be objec�onable, the tails shall be tapered and spliced into the body of the rope using at least two addi�onal tucks (which will require a tail length of approximately six rope diameters beyond the last full tuck).

For all eye splices, the eye shall be sufficiently large to provide an included angle of not greater than 60 degrees at the splice when the eye is placed over the load or support.

Knots shall not be used in lieu of splices.

Safe Opera�ng Temperatures

Natural and synthe�c-fiber rope slings, except for wet frozen slings, may be used in a temperature range from -20°F to 180°F without decreasing the working load limit. For opera�ons outside this temperature range and for wet frozen slings, the sling manufacturer’s recommenda�ons shall be followed.

Splicing

Spliced-fiber rope slings shall not be used unless they have been spliced in accordance with the following minimum requirements and in accordance with any addi�onal recommenda�ons of the manufacturer:

• In manila rope, eye splices shall consist of at least three full tucks, and short splices shall consist of at least six full tucks, three on each side of the splice center line.

• In synthe�c fiber rope, eye splices shall consist of at least four full tucks, and short splices shall consist of at least eight full tucks, four on each side of the center line.

• Strand end tails shall not be trimmed flush with the surface of the rope immediately adjacent to the full tucks. This applies to all types of fiber rope and both eye and short splices. For fiber rope under 1 inch in diameter, the tail shall project at least 6 rope diameters beyond the last full tuck. For fiber rope 1 inch in diameter and larger, the tail shall project at least 6 inches beyond the last full tuck. Where a projec�ng tail interferes with the use of the sling, the tail shall be tapered and spliced into the body of the rope using at least two addi�onal tucks (which will require a tail length of approximately six rope diameters beyond the last full tuck).

• Fiber rope slings shall have a minimum clear length of rope between eye splices equal to ten �mes the rope diameter.

• Knots shall not be used in lieu of splices.

• Clamps not designed specifically for fiber ropes shall not be used for splicing.

• For all eye splices, the eye shall be of such size to provide an included angle of not greater than 60 degrees at the splice when the eye is placed over the load or support.

End Atachments

Fiber-rope slings shall not be used if end atachments in contact with the rope have sharp edges or projec�ons.

Removal from Service

Natural and synthe�c-fiber rope slings shall be immediately removed from service if any of the following condi�ons are present:

• Abnormal wear

• Powdered fiber between strands

• Broken or cut fibers

• Varia�ons in the size or roundness of strands

• Discolora�on or ro�ng

• Distor�on of hardware in the sling

o Employers must use natural and synthe�c-fiber rope slings that have permanently affixed and legible iden�fica�on markings that state the rated capacity for the type(s) of hitch(es) used and the angle upon which it is based, type of fiber material, and the number of legs if more than one

• Synthe�c webbing (nylon, polyester, and polypropylene)

The Company shall have each synthe�c web sling marked or coded to show:

• Name or trademark of manufacturer

• Rated capaci�es for the type of hitch

• Type of material

• Rated capacity shall not be exceeded

10.0 WEBBING

Synthe�c webbing shall be of uniform thickness and width and selvage edges shall not be split from the webbing’s width.

11.0 FITTINGS

Fi�ngs shall be of a minimum breaking strength equal to that of the sling and free of all sharp edges that could in any way damage the webbing.

Atachment of end fi�ngs to webbing and forma�on of eyes s�tching shall be the only method used to atach end fi�ngs to webbing and to form eyes. The thread shall be in an even patern and contain a sufficient number of s�tches to develop the full breaking strength of the sling.

Environmental Condi�ons

When synthe�c web slings are used, the following precau�ons shall be taken:

• Nylon web slings shall not be used where fumes, vapors, sprays, mists, or liquids of acids or phenolics are present.

• Polyester and polypropylene-web slings shall not be used where fumes, vapors, sprays, mists, or liquids of caus�cs are present.

• Web slings with aluminum fi�ngs shall not be used where fumes, vapors, sprays, mists, or liquids of caus�cs are present.

Safe Opera�ng Temperatures

Synthe�c web slings of polyester and nylon shall not be used at temperatures in excess of 180°F. Polypropylene web slings shall not be used at temperatures in excess of 200°F.

Removal from Service

Synthe�c web slings shall be immediately removed from service if any of the following condi�ons are present:

• Acid or caus�c burns

• Mel�ng or charring of any part of the sling surface

• Snags, punctures, tears, or cuts

• Broken or worn s�tches

• Distor�on of fi�ngs

• Shackles and hooks

The Company will not use shackles with loads in excess of the rated capaci�es (i.e., working load limits) indicated on the shackle by permanently affixed and legible iden�fica�on markings prescribed by the manufacturer.

The manufacturer’s recommenda�ons shall be followed in determining the safe working loads of the various sizes and types of specific and iden�fiable hooks. All hooks for which no applicable manufacturer's recommenda�ons are available shall be tested to twice the intended safe working load before they are ini�ally put into use. The Company will maintain a record of the dates and results of such tests.

SEARCH POLICY

1.0 POLICY

To safeguard IT Landes, hereina�er referred to as to “the Company,” customers, Company property, employees, employee property, and to enforce the Company’s policies prohibi�ng misconduct, including the� and the unlawful use or sale of illegal drugs or alcohol, management may ques�on employees and/or inspect any personal property or any area from which the Company conducts business, including any leased spaces, facili�es, and/or vehicles (e.g., briefcases, suitcases, toolboxes, computer bags, backpacks, lunch boxes, purses, or any other container or object brought to and from Company offices, property, worksites, or sponsored func�ons) whenever there is reasonable suspicion to believe that any Company policy is being or has been violated.

The Company may provide offices, desks, vehicles, computers or computer containers, lockers, tools, and other items for employee use These items remain the property of the Company at all �mes The Company may also search any work area and/or item whenever there is reasonable suspicion to believe that a Company policy is being, or has been, violated. Employees are expected to cooperate with Company workplace searches.

Viola�ons of this policy are subject to disciplinary ac�on, including, at the discre�on of Company management, immediate termina�on. Employees with ques�ons regarding this policy should contact Kevin Johnston.

SHORT SERVICE EMPLOYEES

1.0 PURPOSE

The purpose of this policy is to ensure that IT Landes, hereina�er referred to as to “the Company,” contract or short service employees (SSEs) are iden�fied, appropriately supervised, trained, and managed in order to prevent accidents such as personal injury, injury to others, environmental damage, or property damage.

2.0 SCOPE

An SSE is any contractor personnel with less than six months experience in the same job type or with their present employer.

Crew Makeup

• Single person crew cannot be an SSE.

• Crew sizes of less than five shall have no more than one SSE.

• Crews that have more than 20% SSE personnel shall only be permited with a writen SSE variance form, which serves as a mi�ga�on plan, by the appropriate supervisor.

3.0 RESPONSIBILITIES

Supervisor

• Communicate the SSE policy and expecta�ons at the pre-job mee�ng.

Contractor

• Submit the proposed crew makeup and SSE form(s) to the onsite operator supervisor for approval

Onsite Operator Supervisor

• Validate crew makeup and experience level.

Operator Manager

• Approve the SSE variance form

4.0 NOTIFICATION

The proposed crew makeup must be outlined in the SSE form. Prior to the job mobiliza�on, contractors will submit the completed SSE form to the project coordinator, contractor contact, or onsite supervisor for all jobs containing SSE personnel. If an SSE arrives on operator property for which a SSE form has not submited, operator management may elect to send the SSE back to the contractor’s facility at the contractor’s expense. The operator, work owner, or person in charge will determine approval status and retain the original form in project files.

5.0 IDENTIFICATION

SSE personnel shall be visibly iden�fied with high-visibility, colored hardhats.

6.0 SSE MONITORING

Contractors shall monitor their employees, including SSE personnel, for environmental, health, and safety (EHS) awareness. If, at the end of the six-month period, the SSE has worked safely, adhered to EHS policies, and has no recordable incident atributable to them, the SSE iden�fier may be removed at the contractor’s discre�on.

Contractors shall require any employees that do not complete the six-month period recordable free to get operator approval in wri�ng prior to returning to operator property.

7.0 MENTORING PROCESS

Contractors must have some form of mentoring in place, acceptable to the operator, designed to provide guidance and development for SSE personnel. A mentor can only be assigned one SSE per crew and the mentor must be onsite with the SSE to be able to monitor the SSE.

8.0 SUBCONTRACTORS

Operator contractors will manage their subcontractors in alignment with this process.

SILICA EXPOSURE CONTROL

1.0 PURPOSE

The purpose of this document is to outline the silica safety policy for IT Landes, hereina�er referred to as “the Company.”

This program applies to all Company employees and opera�ons and pertains only to sites owned by the Company.

2.0 RESPONSIBILITIES

The Company

• Ensure that the materials (tools, equipment, PPE) and other resources (worker training materials) required to fully implement and maintain this exposure control plan (ECP) are readily available where and when they are required.

• Provide a job-specific ECP for each project, which outlines in detail the work methods and prac�ces that will be followed on each site Considera�ons will include:

o Availability and delivery of all required tools/equipment

o Scope and nature of grinding work to be conducted

o Control methods to be used

o Level of respiratory protec�on required

o Coordina�on plan

• Conduct a periodic review of the effec�veness of the ECP, which includes a review of the available dustcontrol technologies to ensure these are selected and used when prac�cal.

• Ini�ate sampling of worker exposure to concrete dust when there are non-standard work prac�ces for which the control methods to be used have not been proven to be adequately protec�ve

• Ensure that all required tools, equipment, and PPE are readily available and used as required by the ECP

• Ensure supervisors and workers are educated and trained to an acceptable level of competency.

• Maintain records of training, fit test results, crew talks, and inspec�ons (equipment, PPE, work methods/prac�ces).

• Coordinate the work with the prime contractor and other employers to ensure a safe work environment

Management

• Obtain a copy of the ECP from the employer and make it available at the worksite.

• Select, implement, and document the appropriate site-specific control measures.

• Provide adequate instruc�on to workers on the hazards of working with silica-containing materials (e.g., concrete) and on the precau�ons specified in the job-specific plan covering hazards at the loca�on.

• Ensure that workers are using the proper respirators, have been fit tested, and that the results are recorded.

• Direct the work in a manner that ensures the risk to workers is minimized and adequately controlled.

• Communicate with the prime contractor and other subcontractors to ensure a safe work environment

Employees

• Know the hazards of silica dust exposure.

• Use the assigned protec�ve equipment in a safe and effec�ve manner

• Set up the opera�on in accordance with the site-specific plan

• Follow established work procedures as directed by the supervisor.

• Report any unsafe condi�ons or acts to the supervisor

• Know how and when to report exposure incidents.

• Be an experienced and responsible person assigned by the supervisor to work with new employees

• Be selected based on a history of safe work and policy/procedural knowledge

• Be able to communicate the expecta�ons and characteris�cs of work tasks and their associated hazards.

• Have a pa�ent disposi�on and the desire and willingness to devote the necessary �me to succeed as a mentor.

• Possess knowledge and skills in the job tasks assigned to the SSE

• Be willing and able to effec�vely listen to the SSE to determine if the SSE is learning and retaining the knowledge being shared.

• Be willing to watch the SSE perform a job without interfering as long as the SSE is not in a posi�on to harm themselves, others, the environment, or the equipment.

• Adopt a posi�ve safety a�tude, avoid cri�cism, and strive to build confidence and self-esteem in the SSE

• Be able to teach the SSE the proper way to create a quality JSA and to follow that JSA in performing tasks.

• Keep abreast of new equipment in their field of exper�se.

• Refrain from taking shortcuts and doing anything else that jeopardizes health or safety

• Demonstrate a posi�ve work ethic at all �mes

• Introduce the SSE checklist to the new employee; the checklist is a tool to train the new employee and monitor progress.

• Periodically review the SSE checklist with the new employee over a six-month period and forward the informa�on for supervisor and management review

• Follow all Company policies and procedures.

3.0 POLICY

This writen ECP will be evaluated at least once a year and as necessary. Situa�ons where reevalua�on may be necessary include regulatory updates, changes in equipment, and exposure incidents.

4.0 HEALTH HAZARDS

Crystalline silica dust can cause a disabling, some�mes fatal, disease called silicosis. The fine par�cles are deposited in the lungs causing thickening and scarring of the lung �ssue. The scar �ssue restricts the lungs’ ability to extract oxygen from the air. This damage is permanent, but symptoms of the disease may not appear for many years.

A worker may develop any of three types of silicosis, depending on the concentra�ons of silica dust and the dura�on of exposure:

• Chronic Silicosis: Develops a�er ten or more years of exposure to crystalline silica at rela�vely low concentra�ons.

• Accelerated Silicosis: Develops five to ten years a�er ini�al exposure to crystalline silica at high concentra�ons.

• Acute Silicosis: Develops within a few weeks, or four to five years, a�er exposure to very high concentra�ons of crystalline silica

Ini�ally, workers with silicosis may have no symptoms. However, as the disease progresses, a worker may experience:

• Shortness of breath

• Severe cough

• Weakness

These symptoms can worsen over �me and lead to death.

Exposure to silica has been shown to cause silicosis, lung cancer, pulmonary tuberculosis, and other airway diseases. Exposure to silica has also been linked to other diseases, including bronchi�s, tuberculosis, and lung cancer.

5.0 PERMISSIBLE EXPOSURE LIMIT (PEL)

The Company will ensure that no employee is exposed to an airborne concentra�on of respirable crystalline silica in excess of 50 μg/m3, calculated as an 8-hour TWA.

6.0 EXPOSURE ASSESSMENT (GENERAL)

The Company will assess the exposure of each employee who is or may reasonably be expected to be exposed to respirable crystalline silica at or above the ac�on level in accordance with this program.

7.0 SCHEDULED MONITORING OPTION

The Company will perform ini�al monitoring to assess the 8-hour TWA exposure for each employee on the basis of one or more personal breathing zone air samples that reflect the exposures of employees on each shi�, for each job classifica�on, in each work area.

Where several employees from the Company perform the same tasks, on the same shi�, and in the same work area, the Company will sample a frac�on of these exposed employees The Company will sample the employee(s) who are expected to have the highest exposure to respirable crystalline silica.

If monitoring indicates that employee exposures are below the ac�on level, the Company may choose to discon�nue monitoring for those employees whose exposures are represented by such monitoring.

Where the most recent exposure monitoring indicates that employee exposures are at or above the ac�on level but at or below the PEL, the Company will repeat such monitoring within six months of the most recent monitoring.

Where the most recent exposure monitoring indicates that employee exposures are above the PEL, the Company will repeat such monitoring within three months of the most recent monitoring.

Where the most recent (non-ini�al) exposure monitoring indicates that employee exposures are below the ac�on level, the Company will repeat such monitoring within six months of the most recent monitoring un�l two consecu�ve measurements, taken seven or more days apart, are below the ac�on level, at which �me the Company may choose to discon�nue monitoring for those employees whose exposures are represented by such monitoring.

8.0 REASSESSMENT OF EXPOSURES

The Company will reassess exposures whenever a change in the produc�on, process, control equipment, personnel, or work prac�ces may reasonably be expected to result in new or addi�onal exposures at or above the ac�on level, or when the employer has any reason to believe that new or addi�onal exposures at or above the ac�on level have occurred.

9.0 METHOD OF SAMPLE ANALYSIS

The Company will ensure that all samples taken to sa�sfy the monitoring requirements are evaluated by a laboratory that analyzes air samples for respirable crystalline silica.

10.0 EMPLOYEE NOTIFICATION OF RESULTS

Within five working days a�er comple�ng an exposure assessment, the Company will individually no�fy each affected employee in wri�ng of the results of that assessment or post the results in an appropriate loca�on accessible to all affected employees.

Whenever an exposure assessment indicates that employee exposure is above the PEL, the Company will describe in the writen no�fica�on the correc�ve ac�on being taken to reduce employee exposure to or below the PEL.

11.0 OBSERVATION OF MONITORING

Where air monitoring is performed to comply with the requirements of this sec�on, the Company will provide affected employees or their designated representa�ves an opportunity to observe any monitoring of employee exposure to respirable crystalline silica.

When observa�on of monitoring requires entry into an area where the use of protec�ve clothing or equipment is required for any workplace hazard, the Company will provide the observer with protec�ve clothing and equipment at no cost and shall ensure that the observer uses such clothing and equipment.

12.0 METHODS OF COMPLIANCE (ENGINEERING AND WORK-PRACTICE CONTROLS)

The Company will use engineering and work-prac�ce controls to reduce and maintain employee exposure to respirable crystalline silica to or below the PEL, unless the Company can demonstrate that such controls are not feasible.

Wherever such feasible engineering and work-prac�ce controls are not sufficient to reduce employee exposure to or below the PEL, the Company will nonetheless use them to reduce employee exposure to the lowest feasible level and shall supplement them with the use of respiratory protec�on that complies with the requirements of this sec�on.

13.0 ABRASIVE BLASTING

The Company will comply with other OSHA standards, when applicable, such as 29 CFR 1926.57 (Ven�la�on), where abrasive blas�ng is conducted using crystalline silica-containing blas�ng agents, or where abrasive blas�ng is conducted on substrates that contain crystalline silica.

14.0 RESPIRATORY PROTECTION PROGRAM

The Company will provide each employee an appropriate respirator. Respirators will be provided to employees who are exposed to respirable crystalline silica. While this policy is writen in accordance with regulatory guidelines, it is nonetheless a Company-specific policy.

Respiratory protec�on is required:

• Where specified by Table 1 of this policy

• For tasks not listed in Table 1, or where the employer does not fully and properly implement the engineering controls, work prac�ces, and respiratory protec�on described in Table 1:

o Where exposures exceed the PEL during periods necessary to install or implement feasible engineering and work-prac�ce controls

o Where exposures exceed the PEL during tasks, such as certain maintenance and repair tasks for which engineering and work-prac�ce controls are not feasible

o During tasks for which the Company has implemented all feasible engineering and work-prac�ce controls and such controls are not sufficient to reduce exposures to or below the PEL

15.0 SPECIFIED EXPOSURE CONTROL METHODS

The Company will not allow dry sweeping or dry brushing where such ac�vity could contribute to employee exposure to respirable crystalline silica unless wet sweeping, HEPA-filtered vacuuming, or other methods that minimize the likelihood of exposure are not feasible.

The Company will not allow compressed air to be used to clean clothing or surfaces where such ac�vity could contribute to employee exposure to respirable crystalline silica unless:

• The compressed air is used in conjunc�on with a ven�la�on system that effec�vely captures the dust cloud created by the compressed air

• No alterna�ve method is feasible.

Effec�ve engineering controls such as HEPA vacuum atachments and we�ng methods, which control silica dust at its source. These controls have been proven to reduce airborne dust levels significantly when selected and operated in accordance with best prac�ces.

We know that engineering controls alone do not reduce airborne silica to safe levels. So, in most cases, other control measures, including respiratory protec�on, will be necessary.

If the Company takes on a job that could release an unusually high amount of dust and is unsure of the adequacy of our control measures, the Company will conduct air sampling in order to ensure that control methods are protec�ve.

The Company will reduce or eliminate worker exposure to silica dust by selec�ng a combina�on of the following controls listed in order of preference:

• Elimina�on and subs�tu�on

• Engineering

• Administra�ve

• PPE

The Company recognizes the importance of planning the work in order to minimize the amount of silica dust generated. During the project planning phase, the Company will advocate for the use of methods that reduce the need for cu�ng, grinding, or drilling of concrete surfaces (e.g., formwork planning). Whenever possible, the Company will schedule work when concrete is s�ll wet because less dust is released at that �me.

16.0 CONTROL OF DUST

Dust control systems may employ three well-established techniques:

• Local exhaust ven�la�on (LEV)

• Wet dust suppression (WDS)

• Restric�ng or isola�ng the work ac�vity with barriers or full enclosures (this may be the only op�on where LEV or WDS is not prac�cal or effec�ve)

When LEV is used, the Company will employ the following systems and safe work prac�ces:

• Vacuum atachment systems to capture and control the dust at its source whenever possible

• Dust control systems (used regularly and well maintained)

• Grinding wheels operated at the manufacturers’ recommended rpm (opera�ng in excess of this can generate significantly higher airborne dust levels).

• Retrofit shrouds or exhaust cowlings for corner grinding (use manufacturer-specified rpm speeds and a wellmaintained HEPA vacuum)

• Diamond stone grinders, which allow for the use of a more efficient suc�on casing on the grinder, whenever prac�cable.

• HEPA or good quality, mul�-stage vacuum units approved for use with silica dust The vacuum units should be capable of crea�ng a target airflow of at least 70 cfm. This should achieve a face velocity at the shroud of about 1.3 meters per second (260 fpm); the higher the face velocity, the more dust captured at source.

• Work planning, so that concrete grinding can be completed when wet (dust release can be significantly reduced).

• Good housekeeping work prac�ces (e.g., use vacuums with HEPA filters, wet sweeping, etc.).

• Train workers and supervisors on how to properly use and maintain the equipment

17.0 WATER SPRAY SYSTEMS

When water spray systems are used, the Company will follow these safe work prac�ces:

• Pneuma�c grinders will be used instead of electric-powered grinders if water is the method of control.

• Pressure and flow rate of water will be controlled in accordance with tool manufacturers’ specifica�on. For cu�ng saws, a minimum of 0.5 liters of water per minute (0.13 gallons per minute) should be used.

• When sawing concrete or masonry, the Company will use only saws that provide water to the blade.

• Wet slurry will be cleaned from work surfaces when the work is completed using a wet vacuum or wet sweeping.

18.0 BARRIERS

When barriers or enclosures are used, the Company will follow these safe work prac�ces:

• The site foreman will determine the type and design of barrier or enclosure based on the work ac�vity and the work area, and ensure it is constructed in accordance with the work plan.

• Barriers may be simple hazard-flagging ribbon or more restric�ve hoarding.

• The Company will use commercially available, nega�ve air units when construc�ng a full enclosure.

19.0 ADMINISTRATIVE CONTROLS AND SAFE WORK PRACTICES

The Company will follow these safe work prac�ces:

• ECPs and the site risk assessment or work plan will be submited to the general contractor prior to the start of work.

• The Company will establish procedures for housekeeping, restric�ng work areas, personal hygiene, worker training, and supervision.

• As part of project planning, the Company will assess when silica dust may be generated and plan ahead to eliminate or control the dust at the source. Awareness and planning are key factors in the preven�on of silicosis.

• Warning signs will be posted to warn workers about the hazards of silica and to specify any protec�ve equipment required (e.g., respirators).

• Work schedules will be posted at the boundaries of work areas contaminated with silica dust.

• Work that generates silica dust will be conducted a�er hours, when access to other unprotected workers cannot be restricted.

• Full shi�, personal samples shall be representa�ve of the employees regular, daily exposure to silica.

This writen ECP must be available for examina�on and copying by each employee. Copies may be available electronically or physically, depending on loca�on needs and requirements.

20.0 ENGINEERING CONTROLS

Engineering and work-prac�ce controls must be used to reduce employee exposure to respirable crystalline silica to the lowest feasible level and maintain it at that level when required.

Engineering controls, such as ven�la�on or wet methods, must be used to control silica-containing dusts.

21.0 RESTRICTED ACCESS TO WORK AREAS

The Company will schedule work so only required employees directly engaged in the task are in the affected work area to minimize the number of employees exposed to respirable crystalline silica and their level of exposure, including exposures generated by other employers or sole proprietors.

For each employee engaged in a task iden�fied on Table 1, the Company will fully and properly implement the engineering controls, work prac�ces, and respiratory protec�on specified for the task outlined below.

Table 1: Specified Exposure Control Methods When Working with Materials Containing Crystalline Silica

Construc�on Task or Equipment Opera�on

1 Sta�onary masonry saws

Engineering and Work Prac�ce Control Methods

• Use saw equipped with integrated water delivery system that con�nuously feeds water to the blade.

• Operate and maintain tool in accordance with manufacturer’s instruc�ons to minimize dust emissions.

2A Handheld power saws (any blade diameter) when used outdoors

2B Handheld power saws (any blade diameter) when used indoors or in an enclosed area

3 Handheld power saws for cu�ng fiber-cement board (with blade diameter of 8 inches or less) for tasks performed outdoors only

4A Walk-behind saws when used outdoors

• Use saw equipped with integrated water delivery system that con�nuously feeds water to the blade.

• Operate and maintain tool in accordance with manufacturer’s instruc�ons to minimize dust emissions.

• Use saw equipped with integrated water delivery system that con�nuously feeds water to the blade

• Operate and maintain tool in accordance with manufacturer’s instruc�ons to minimize dust emissions.

• Use saw equipped with commercially available dust collec�on system.

• Operate and maintain tool in accordance with manufacturer’s instruc�ons to minimize dust emissions.

• Dust collector must provide the air flow recommended by the tool manufacturer, or greater, and have a filter with 99% or greater efficiency.

• Use saw equipped with integrated water delivery system that con�nuously feeds water to the blade.

4B Walk-behind saws when used indoors or in an enclosed area

• Operate and maintain tool in accordance with manufacturer’s instruc�ons to minimize dust emissions.

• Use saw equipped with integrated water delivery system that con�nuously feeds water to the blade.

• Operate and maintain tool in accordance with manufacturer’s instruc�ons to minimize dust emissions.

5 Drivable saws for tasks performed outdoors only

• Use saw equipped with integrated water delivery system that con�nuously feeds water to the blade.

• Operate and maintain tool in accordance with manufacturer’s instruc�ons to minimize dust emissions.

6 Rig-mounted core saws or drills

• Use tool equipped with integrated water delivery system that supplies water to cu�ng surface.

• Operate and maintain tool in accordance with manufacturer’s instruc�ons to minimize dust emissions.

7 Handheld and standmounted drills (including impact and rotary hammer drills)

• Use drill equipped with commercially available shroud or cowling with dust collec�on system.

• Operate and maintain tool in accordance with manufacturer’s instruc�ons to minimize dust emissions.

• Dust collector must provide the air flow recommended by the tool manufacturer, or greater, and have a filter with 99% or greater efficiency and a filter-cleaning mechanism.

• Use a HEPA-filtered vacuum when cleaning holes.

8 Dowel drilling rigs for concrete for tasks performed outdoors only

• Use shroud around drill bit with a dust collec�on system.

• Dust collector must have a filter with 99% or greater efficiency and a filter cleaning mechanism.

• Use a HEPA-filtered vacuum when cleaning holes.

10 APF 10

9A Vehicle-mounted drilling rigs for rock and concrete

9B Vehicle-mounted drilling rigs for rock and concrete

• Use dust collec�on system with close capture hood or shroud around drill bit with a low-flow water spray to wet the dust at the discharge point from the dust collector.

• Operate from within an enclosed cab and use water for dust suppression on drill bit.

10A Jackhammers and handheld powered chipping tools when used outdoors

10B Jackhammers and handheld powered chipping tools when used indoors or in an enclosed area

10C Jackhammers and handheld powered chipping tools when used outdoors

• Use tool with water delivery system that supplies a con�nuous stream or spray of water at the point of impact.

• Use tool with water delivery system that supplies a con�nuous stream or spray of water at the point of impact.

• Use tool equipped with commercially available shroud and dust collec�on system.

• Operate and maintain tool in accordance with manufacturer’s instruc�ons to minimize dust emissions.

• Dust collector must provide the air flow recommended by the tool manufacturer, or greater, and have a filter with 99% or greater efficiency and a filter-cleaning mechanism.

None APF 10

10D Jackhammers and handheld powered chipping tools when used indoors or in an enclosed area

• Use tool equipped with commercially available shroud and dust collec�on system.

• Operate and maintain tool in accordance with manufacturer’s instruc�ons to minimize dust emissions.

• Dust collector must provide the air flow recommended by the tool manufacturer, or greater, and have a filter with 99% or greater efficiency and a filter-cleaning mechanism.

APF 10 APF 10

11 Handheld grinders for mortar removal (i.e., tuckpoin�ng)

• Use grinder equipped with commercially available shroud and dust collec�on system.

• Operate and maintain tool in accordance with manufacturer’s instruc�ons to minimize dust emissions.

• Dust collector must provide 25 cubic feet per minute or greater of airflow per inch of wheel diameter and have a filter with 99% or greater efficiency and a cyclonic preseparator or filter-cleaning mechanism.

None APF 10

12A Handheld grinders for uses other than mortar removal for tasks performed outdoors only

12B Handheld grinders for uses other than mortar removal when used outdoors

• Use grinder equipped with integrated water delivery system that con�nuously feeds water to the grinding surface.

• Operate and maintain tool in accordance with manufacturer’s instruc�ons to minimize dust emissions.

• Use grinder equipped with commercially available shroud and dust collec�on system.

• Operate and maintain tool in accordance with manufacturer’s instruc�ons to minimize dust emissions.

None None

None APF 10

12C Handheld grinders for uses other than mortar removal when used indoors or in an enclosed area

• Dust collector must provide 25 cubic feet per minute or greater of airflow per inch of wheel diameter and have a filter with 99% or greater efficiency and a cyclonic preseparator or filter-cleaning mechanism.

• Use grinder equipped with commercially available shroud and dust collec�on system.

• Operate and maintain tool in accordance with manufacturer’s instruc�ons to minimize dust emissions.

• Dust collector must provide 25 cubic feet per minute or greater of airflow per inch of wheel diameter and have a filter with 99% or greater efficiency and a cyclonic preseparator or filter-cleaning mechanism.

13A Walk-behind milling machines and floor grinders

• Use machine equipped with integrated water delivery system that con�nuously feeds water to the cu�ng surface.

• Operate and maintain tool in accordance with manufacturer’s instruc�ons to minimize dust emissions.

13B Walk-behind milling machines and floor grinders

• Use machine equipped with dust collec�on system recommended by the manufacturer.

• Operate and maintain tool in accordance with manufacturer’s instruc�ons to minimize dust emissions.

• Dust collector must provide the air flow recommended by the manufacturer, or greater, and have a filter with 99% or greater efficiency and a filter-cleaning mechanism.

• When used indoors or in an enclosed area, use a HEPA-filtered vacuum to remove loose dust in between passes.

14 Small drivable milling machines (less than half-lane)

15A Large drivable milling machines (half-lane and larger) for cuts of any depth on asphalt only

15B Large drivable milling machines (half-lane and larger) for cuts of 4 inches in depth or less on any substrate

• Use a machine equipped with supplemental water sprays designed to suppress dust.

• Water must be combined with a surfactant.

• Operate and maintain machine to minimize dust emissions.

• Use machine equipped with exhaust ven�la�on on drum enclosure and supplemental water sprays designed to suppress dust.

• Operate and maintain machine to minimize dust emissions.

• Use machine equipped with exhaust ven�la�on on drum enclosure and supplemental water sprays designed to suppress dust.

15C Large drivable milling machines (half-lane and larger) for cuts of 4 inches in depth or less on any substrate

16 Crushing machines

• Operate and maintain machine to minimize dust emissions.

• Use a machine equipped with supplemental water spray designed to suppress dust.

• Water must be combined with a surfactant.

• Operate and maintain machine to minimize dust emissions.

• Use equipment designed to deliver water spray or mist for dust suppression at crusher and other points where dust is generated (e.g., hoppers, conveyers, sieves/sizing or vibra�ng components, and discharge points).

• Operate and maintain machine in accordance with manufacturer’s instruc�ons to minimize dust emissions.

• Use a ven�lated booth that provides fresh, climate-controlled air to the operator, or a remote-control sta�on.

17A Heavy equipment and u�lity vehicles used to abrade or fracture silicacontaining materials (e.g., hoe-ramming, rock ripping) or used during demoli�on ac�vi�es involving silica-containing materials

17B Heavy equipment and u�lity vehicles used to abrade or fracture silicacontaining materials (e.g., hoe-ramming, rock ripping) or used during demoli�on ac�vi�es involving silica-containing materials

18A Heavy equipment and u�lity vehicles for tasks such as grading and excava�ng but not including demolishing, abrading, or fracturing silicacontaining materials

• Operate equipment from within an enclosed cab.

• When employees outside of the cab are engaged in the task, apply water and/or dust suppressants as necessary to minimize dust emissions.

• Apply water and/or dust suppressants as necessary to minimize dust emissions.

18B Heavy equipment and u�lity vehicles for tasks such as grading and excava�ng but not including demolishing, abrading, or fracturing silicacontaining materials

• When the equipment operator is the only employee engaged in the task, operate equipment from within an enclosed cab.

None None

22.0 PERSONAL PROTECTIVE EQUIPMENT (PPE)

The Company will provide workers in a restricted area with protec�ve clothing that protects other clothing worn by the worker from silica contamina�on. PPE, such as gloves, coveralls, and eye protec�on, should be used to control silica exposures.

23.0 RESPIRATORY PROTECTION

Where respiratory protec�on is required by this sec�on, the employer must provide each employee an appropriate respirator that complies with the requirements of this paragraph and 29 CFR 1910.134.

• Respiratory protec�on is required:

o Where specified by Table 1 of this program.

o For tasks not listed in Table 1, or where the employer does not fully and properly implement the engineering controls, work prac�ces, and respiratory protec�on described in Table 1 of this program.

o Where exposures exceed the PEL during periods necessary to install or implement feasible engineering and work-prac�ce controls.

o Where exposures exceed the PEL during tasks, such as certain maintenance and repair tasks, for which engineering and work-prac�ce controls are not feasible.

o During tasks for which an employer has implemented all feasible engineering.

• Respirators must be selected based upon measured exposure levels and the assigned protec�on factor of respirators.

• All workers who wear respirators will do so in adherence with our respirator program.

• Respiratory protec�on will be selected based upon the site-specific risk assessment.

• Only NIOSH-approved respirators will be used.

• Workers who wear respirators will be clean shaven. Filtering facepiece respirators give litle or no protec�on to workers with beards, and even a minor growth of stubble can severely reduce the effec�veness of respiratory protec�on.

• All workers who wear respirators will be fit tested.

• Workers will be properly trained in the use of respirators, and a high standard of supervision, inspec�on, and maintenance will be followed.

24.0 MEDICAL SURVEILLANCE

The Company will make medical surveillance available at no cost to the employee, and at a reasonable �me and place, for each employee who will be required under this sec�on to use a respirator for 30 or more days per year.

The Company will ensure that all medical examina�ons and procedures required by this sec�on are performed by a PLHCP.

Ini�al Examina�on

The employer shall make available an ini�al (baseline) medical examina�on within 30 days a�er ini�al assignment, unless the employee has received a medical examina�on that meets the requirements of this sec�on within the last three years.

The examina�on shall consist of:

• A medical work history with emphasis on past, present, and an�cipated exposure to respirable crystalline silica, dust, and other agents affec�ng the respiratory system

• Any history of respiratory system dysfunc�on, including signs and symptoms of respiratory disease (e.g., shortness of breath, cough, wheezing), and any history of tuberculosis

• Smoking status and history

• A physical examina�on with special emphasis on the respiratory system

• A chest x-ray (a single posteroanterior radiographic projec�on or radiograph of the chest at full inspira�on recorded on either film (no less than 14 x 17 inches and no more than 16 x 17 inches) or digital radiography systems), interpreted and classified according to the Interna�onal Labour Office (ILO) Interna�onal Classifica�on of Radiographs of Pneumoconiosis by a NIOSH-cer�fied B Reader

• A pulmonary func�on test to include forced vital capacity (FVC) and forced expiratory volume in one second (FEV1) and FEV1/FVC ra�o, administered by a spirometry technician with a current cer�ficate from a NIOSHapproved spirometry course

• Tes�ng for latent tuberculosis infec�on

• Any other tests deemed appropriate by the PLHCP

25.0 PERIODIC EXAMINATIONS

The Company will make available medical examina�ons that include the procedures at least once every three years or more frequently if recommended by the PLHCP.

26.0 INFORMATION PROVIDED TO THE PLHCP

The Company will ensure that the examining PLHCP has a copy of this standard and shall provide the PLHCP with a descrip�on of the employee’s former, current, and an�cipated du�es as they relate to the employee’s occupa�onal exposure to respirable crystalline silica.

The Company will ensure that the specialist explains the results of the medical examina�on to the employee and provides the employee with a writen medical report within 30 days of the examina�on.

The Company will obtain a writen opinion from the specialist within 30 days of the medical examina�on.

27.0 COMMUNICATION OF RESPIRABLE CRYSTALLINE SILICA HAZARDS TO EMPLOYEES

The Company will include respirable crystalline silica in the program established to comply with 29 CFR 1910.1200 (Hazard Communica�on Standard (HCS)).

The Company will ensure that each employee has access to labels on containers of crystalline silica and safety data sheets and is trained in accordance with the provisions of the HCS.

The Company will ensure that, at a minimum, the following hazards are addressed:

• Cancer

• Lung effects

• Immune system effects

• Kidney effects

28.0 EMPLOYEE INFORMATION AND TRAINING

The Company will ensure that, at a minimum, each employee covered by this sec�on can demonstrate knowledge and understanding of the following:

• The health hazards associated with exposure to respirable crystalline silica

• Specific tasks in the workplace that could result in exposure to respirable crystalline silica

• Specific measures the Company has implemented to protect employees from exposure to respirable crystalline silica, including engineering controls, work prac�ces, and respirators to be used

• The contents of this sec�on and the iden�ty of a competent person

• The purpose and a descrip�on of the medical surveillance program

The Company shall make a copy of this sec�on readily available at no cost to employees covered by this sec�on.

29.0 RECORDKEEPING AIR MONITORING DATA

The Company will make and maintain an accurate record of all exposure measurements taken to assess employee exposure to respirable crystalline silica.

This record shall, at a minimum, include the following informa�on:

• The date of measurement for each sample taken

• The task monitored

• Sampling and analy�cal methods used

• Number, dura�on, and results of samples taken

• Iden�ty of the laboratory that performed the analysis

• Type of PPE, such as respirators, worn by the monitored employees

• Name, social security number, and job classifica�on of all employees represented by the monitoring, indica�ng which employees were actually monitored

The Company will ensure that exposure records are maintained and made available in accordance with 29 CFR 1910.1020.

Objec�ve Data

The Company will make and maintain an accurate record of all objec�ve data relied upon to comply with the requirements of this sec�on.

This record shall, at a minimum, include the following informa�on:

• The crystalline silica-containing material in ques�on

• The source of the objec�ve data

• The tes�ng protocol and results of tes�ng

• A descrip�on of the process, task, or ac�vity on which the objec�ve data was based

• Other data relevant to the process, task, ac�vity, material, or exposures on which the objec�ve data was based

The Company will ensure that objec�ve data is maintained and made available in accordance with 29 CFR 1910.1020.

30.0 MEDICAL SURVEILLANCE

The Company will make and maintain an accurate record for each employee containing the following:

• Name and social security number

• A copy of the PLHCP’s and specialists’ writen medical opinions

• A copy of the informa�on provided to the PLHCP and specialists

The Company will ensure that medical records are maintained and made available in accordance with 29 CFR 1910.1020.

31.0 DATES

This sec�on shall become effec�ve June 23, 2016.

All obliga�ons of this sec�on, except requirements for methods of sample analysis, shall commence June 23, 2017.

Requirements for methods of sample analysis commence June 23, 2018.

32.0 PROTECTIVE CLOTHING

Workers will wear protec�ve clothing as specified in our task-specific safe work procedures to prevent contamina�on of worker clothing. Workers will not use compressed air to clean themselves, their clothing, or their equipment.

33.0 WORKPLACE HOUSEKEEPING

A descrip�on of housekeeping measures used to limit exposure to respirable crystalline silica must be in place.

Workers that have the poten�al for silica exposure will be provided with a list of workplace housekeeping measures and best prac�ces that include items like:

• Vacuuming

• Sweeping

• We�ng

• Other techniques used to limit the amount of respirable crystalline silica exposure during housekeeping ac�vi�es

34.0 TRAINING

A training program will be provided for all employees who are exposed to ac�on level respirable crystalline silica. The training will ensure that employees covered by the writen ECP can demonstrate knowledge and understanding of the health hazards associated with respirable crystalline silica, the specific tasks in the workplace that could result in exposure to respirable crystalline silica, the specific measures taken to protect employees from exposure to crystalline silica, the contents of the respirable crystalline silica rule, and the purpose of the medical surveillance program

Training is required prior to using silica-containing materials or working in an environment known to contain airborne concentra�ons of silica. Periodic refresher training is also required. Refresher training is done each quarter and is documented. Documenta�on is kept on file for all employees.

The Company will ensure that a worker who may be exposed to silica is:

• Informed of the health hazards associated with exposure to that substance

• Informed of measurements made of airborne concentra�ons of harmful substances at the worksite

• Trained in procedures developed by the Company to minimize the worker’s exposure

Training may be performed in house or by a third party.

The Company will train all workers poten�ally exposed to airborne silica dust in the following:

• Hazards associated with exposure to silica dust

• The risks of exposure to silica

• Signs and symptoms of silica disease

• Safe work procedures to be followed (e.g., setup of enclosures, disposal of silica waste, personal decontamina�on)

• Use of respirators and other PPE (e.g., donning and doffing of PPE, cleaning and maintenance of respirators)

• Use of control systems (e.g., LEV and wet methods)

• How to seek first aid (e.g., the loca�on and use of eyewash sta�ons)

• How to report an exposure to silica dust

Records of training will be kept as specified in the Occupa�onal Health and Safety Regula�on.

35.0 HEALTH ASSESSMENTS

The Company will ensure that a worker undergoes a health assessment:

• No more than 30 calendar days a�er the worker becomes an exposed worker

• Every two years a�er the first health assessment

Exposed workers may refuse to undergo part or all of a health assessment by giving the Company a writen statement refusing it.

The Company will cover the cost of the health assessment. The Company will ensure that, if it is reasonably prac�cable, a health assessment is performed during normal work hours.

A list or descrip�on of tasks in the workplace that expose employees to respirable crystalline silica will be placed in a conspicuous area so that all employees have access. Tasks include ac�vi�es such as:

• Sawing

• Drilling

• Jackhammering

• Grinding

• Anything else that is likely to expose employees to respirable crystalline silica will be provided for workers on each affected jobsite

Accurate records of all air monitoring data, objec�ve data, and medical surveillance shall be maintained as required by the regula�on.

This writen ECP will be evaluated at least once a year and as necessary. Situa�ons where reevalua�on may be necessary include regulatory updates, changes in equipment, and exposure incidents.

STOP WORK AUTHORITY

1.0 PURPOSE

The stop work authority (SWA) program is used to resolve a perceived act, error, omission, unsafe condi�on, or lack of understanding that could poten�ally result in an undesirable event. It involves a stop, no�fy, correct, and resume approach. If there are concerns or ques�ons regarding the control of health, safety, or environmental risks of any task or opera�on, all IT Landes, hereina�er referred to as “the Company,” employees are authorized and obligated to stop it.

Employees will not be reprimanded for issuing a stop work interven�on.

2.0 SCOPE

This program applies to all projects and opera�ons undertaken by the Company.

3.0 RESPONSIBILITIES

Management

• Create a work environment where employees feel they can apply SWA without restraint

• Create and reinforce clear expecta�ons for employees to apply SWA

Supervisors

• Ensure the work environment is such that SWA is applied and followed without restraint so that issues are resolved before resuming opera�ons.

• Recognize proac�ve par�cipa�on in SWA

Employees

• Launch a stop work interven�on when warranted.

Those who choose not to comply with the SWA policies must be held accountable by management.

4.0 PROCEDURE

• If an employee iden�fies an unsafe condi�on, they launch the stop work interven�on in coordina�on with the supervisor. All affected personnel and supervisors are no�fied of the stop work issue. The issue is corrected, and work may resume when it is safe to do so.

• Never resume work un�l all stop work issues and concerns are adequately addressed.

• The Company will not tolerate any form of in�mida�on or retribu�on toward an individual or the Company for ini�a�ng a stop work interven�on.

5.0 FOLLOW UP

• Stop work interven�ons must be documented and include the lessons learned and correc�ve measures to be installed.

• Supervisors will review stop work reports to gauge par�cipa�on, interven�on quality and follow up, iden�fy trends (common issues), improvement opportuni�es, and aid in sharing of learning.

• The goal of a stop work interven�on is that all involved people are sa�sfied that the iden�fied safety concern(s) are adequately addressed before resuming work. Although, in most cases, issues can be sa�sfactorily resolved at the jobsite in a �mely manner, some�mes pinpoin�ng and addressing root causes requires supplementary inves�ga�on and correc�ve ac�ons.

6.0 TRAINING

The Company will provide SWA training for employees prior to their ini�al work assignment. Records of training will include the employee’s name, subject mater, and the dates of training.

SUBCONTRACTOR MANAGEMENT

1.0 PURPOSE

The purpose of this document is to outline the subcontractor pre-qualifica�on, evalua�on, selec�on, and monitoring process for IT Landes, hereina�er referred to as “the Company.”

2.0 POLICY

3.0 PRE-QUALIFICATION PROCESS

The Company will ensure that all contractors and subcontractors have a current, up-to-date, and func�oning safety program through the following:

• Ini�al and periodic review of writen safety programs, policies, and procedures to ensure accuracy with relevant legisla�on and that all employees working on behalf of the contractor and/or subcontractor are trained in the writen plan

• Ini�al and periodic review of all safety training documents, including cer�fica�ons that may apply

• Ini�al and periodic review of safety sta�s�cal data

4.0 METRICS EVALUATION AND MONITORING

Prior to ini�al assignment, the Company will perform an evalua�on of all contractor and subcontractor safety metrics, including TRIR, EMR, DART, and fatality rate, as criteria for making hiring decisions. A benchmark of relevant industry-specific Bureau of Labor Sta�s�cs’ industry average will be compared with contractor’s and subcontractor’s current sta�s�cs to ensure only the safest contractors are allowed to perform work on behalf of the Company.

5.0 CONTRACTOR AND SUBCONTRACTOR PARTICIPATION

All contractors and subcontractors performing work on behalf of the Company or on worksites that are under the supervision of the Company will be required to atend all pre-job mee�ngs, safety orienta�ons, and tailgate safety mee�ngs.

In addi�on to pre-job mee�ngs, subcontractors shall be included in job safety analysis/hazard assessments and onthe-job, safety inspec�ons.

6.0 REVIEW AND FOLLOW UP

Upon conclusion of each job, the Company will perform a post-job, safety performance review with all contractors and subcontractors. Con�nual follow up and discussions about safety performance will help the Company maintain safe and healthy worksites.

TRENCHING, SHORING, AND EXCAVATION

1.0 PURPOSE

The purpose of this document is to outline the policy and procedures for the protec�on of employees working in and around excava�ons and trenches for IT Landes, hereina�er referred to as “the Company.”

This program pertains to all Company projects that require any excava�ons or trenching work.

2.0 RESPONSIBILITIES

It is the responsibility of each superintendent and supervisor to implement and maintain the procedures and steps set forth in this program. Each employee involved with excava�on and trenching work is responsible for complying with all applicable safety procedures and requirements in this program.

3.0 POLICY

4.0 HAZARDS

One of the reasons the Company requires a competent person to be on-site during excava�on and trenching are the numerous poten�al hazardous that may be encountered or created. Hazards include:

• Electrocu�on

• Gas explosion

• Struck by equipment

• Entrapment

• Suffoca�on

Hazards associated with excava�ons must be iden�fied and mi�gated prior to beginning work.

5.0 HAZARD CONTROLS

Before any work is performed and before any employees enter the excava�on, a number of items must be checked and insured:

• Underground installa�ons must be determined before any excava�on. This can be accomplished by either contac�ng the local u�lity companies or the local “one call” center for the area. All underground u�lity loca�ons must be documented on the proper forms. All overhead hazards (surface encumbrances) that create a hazard to employees must be removed or supported to eliminate the hazard.

• If the excava�on is to be over 20 feet deep, it must be designed by a professional engineer registered in the state where work will be performed.

• Adequate protec�ve systems will be u�lized to protect employees. This can be accomplished through sloping, shoring, or shielding.

• The worksite must be analyzed in order to design adequate protec�on systems and prevent cave-ins. There must also be an excava�on safety plan developed to protect employees.

• Workers must be supplied with and wear any personal protec�ve equipment deemed necessary to ensure their protec�on.

• All spoil piles will be stored a minimum of 2 feet from the sides of the excava�on. The spoil pile must not block the safe means of egress.

• If a trench or excava�on is 4 feet or deeper, stairways, ramps, or ladders will be used as a safe means of access and egress. For trenches, employees must not have to travel any more than 25 feet of lateral travel to reach the stairway, ramp, or ladder.

• Employees will not work in an excava�on where water is accumula�ng unless adequate measures are used to protect the employees.

• Employees must be protected from water accumula�on, including the use of shields, and must be inspected by a competent person before work begins.

• A competent person will inspect all excava�ons and trenches on a daily basis, prior to employee exposure or entry, and a�er any rainfall, soil change, or any other �me needed during the shi�. A competent person must take prompt measures to eliminate any and all hazards.

• Excava�ons and trenches 4 feet or deeper that have the poten�al for toxic substances or hazardous atmospheres will be tested at least once a day. If the atmosphere is inadequate, protec�ve systems will be u�lized.

• If work is in or around traffic, employees must be supplied with and wear orange, reflec�ve vests. Signs and barricades must be u�lized to ensure the safety of employees, vehicular traffic, and pedestrians.

6.0 COMPETENT PERSON RESPONSIBILITIES

The OSHA standards require that a competent person must be capable of iden�fying exis�ng and predictable hazards in the surroundings and working condi�ons that are unsanitary, hazardous, or dangerous to employees; and have authoriza�on to take prompt correc�ve measures to eliminate them and, if necessary, to stop the work.

A competent person shall examine the possibility of cave-ins, failures, or protec�ve systems, etc. If problems are found, provisions shall be made for immediate personnel removal.

A competent person shall be specified, and their du�es described. Du�es may include inspec�ons prior to entry, atmospheric tes�ng, and removal of workers if condi�ons dictate.

A competent person is required to:

• Have a complete understanding of the applicable safety standards and any other data provided.

• Ensure the proper loca�ons of underground installa�ons or u�li�es and that the proper u�lity companies have been contacted.

• Conduct soil classifica�on tests and reclassify soil a�er any condi�on changes.

• Determine adequate protec�ve systems (sloping, shoring, or shielding systems) for employee protec�on.

• Conduct all air monitoring for poten�al hazardous atmospheres.

• Conduct daily and periodic inspec�ons of excava�ons and trenches.

• Approve design of structural ramps if used.

7.0 EXCAVATION SAFETY PLAN

An excava�on safety plan is required in writen form. This plan is to be developed to the level necessary to ensure complete compliance with the OSHA excava�on standard and state and local safety standards.

Excava�on safety plan factors include:

• U�liza�on of the local “one call” system

• Determina�on of loca�ons of all underground u�li�es

• Considera�on of confined space atmosphere poten�al

• Proper soil protec�on systems and personal protec�ve clothing and equipment

• Determina�on of soil composi�on and classifica�on

• Determina�on of surface and subsurface water

• Depth of excava�on and length of �me it will remain open

• Proper adherence to all OSHA standards, this safety program, and any other coinciding safety programs

8.0 SOIL CLASSIFICATION AND IDENTIFICATION

The OSHA standards define soil classifica�ons within the simplified soil classifica�on systems, which consist of four categories (stable rock, Type A, Type B, and Type C). Stability is greatest in stable rock and decreases through Type A and B to Type C, which is the least stable. Appendix A of the standard provides soil mechanics terms and types of field tests used to determine soil classifica�ons.

Stable rock is defined as natural solid mineral mater that can be excavated with ver�cal sides and remain intact while exposed.

Soil classifica�ons must be determined by tes�ng and protec�ve systems designed according to soil classifica�ons.

Type A soil is defined as:

• Cohesive soils with an unconfined compressive strength of 1.5 tons per square foot (TSF) or greater

• Cemented soils like caliche and hardpan

Soil is not Type A if:

• It is fissured

• It is subject to vibra�on from heavy traffic, pile driving or similar effects

• It has been previously disturbed

• The material is subject to other factors that would require it to be classified as a less stable material

• The exclusions for Type A most generally eliminate it from most construc�on situa�ons

Type B soil is defined as:

• Cohesive soil with an unconfined compressive strength greater than 0.5 TSF but less than 1.5 TSF

• Granular cohesionless soil including angular gravel, silt, silt loam, and sandy loam

• The soil has been previously disturbed except that soil classified as Type C soil

• Soil that meets the unconfined compressive strength requirements of Type A soil but is fissured or subject to vibra�on

• Dry rock that is unstable

Type C soil is defined as:

• Cohesive soil with an unconfined compressive strength of 0.5 TSF or less

• Granular soils including gravel, sand, and loamy sand

• Submerged soil or soil from which water is freely seeping

• Submerged rock that is not stable

9.0 SOIL TESTING

A competent person will classify the soil type in accordance with the defini�ons in Appendix A on the basis of at least one visual and one manual analysis. These tests should be run on freshly excavated samples from the excava�on and are designed to determine stability based on a number of criteria: presence of fissures, presence of layering, presence and amount of water, unconfined compressive strength, dura�on of exposure, prior excava�on, undermining, cohesiveness, and vibra�on.

The cohesion tests are based on methods to determine the presence of clay. Clay, silt, and sand are size classifica�ons, with clay being the smallest sized par�cles, silt intermediate, and sand the largest. Clay minerals exhibit good cohesion and plas�city (can be molded). Sand exhibits no elas�city and virtually no cohesion unless surface we�ng is present. The degree of cohesiveness and plas�city depend on the amounts of all three types and water.

When examining the soil, three ques�ons must be asked:

• Is the sample granular or cohesive?

• Fissured or non-fissured?

• What is the unconfined compressive strength measured in TSF?

The loca�on of underground installa�ons shall be determined before excava�on. When u�lity companies or clients cannot respond to a request to locate underground u�lity installa�ons within 24 hours, or cannot establish exact loca�on of these installa�ons, the employer may proceed, provided the employer does so with cau�on and provided detec�on equipment or other acceptable means to locate u�lity installa�ons are used.

Methods of tes�ng soils include:

• Visual Test: If the excavated soil is in clumps, it is cohesive. If it breaks up easily and doesn’t stay in clumps, it is granular.

• Wet Manual Test: Wet your fingers and work the soil between them. Clay is a slick paste when wet, meaning it is cohesive. If the clump falls apart in grains, it is granular.

• Dry Strength Test: Try to crumble the sample in your hands with your fingers. If it crumbles into grains, it is granular. Clay will not crumble into grains, only into smaller chunks.

• Pocket Penetrometer Test: This instrument is most accurate when soil is nearly saturated. This instrument will give unconfined compressive strength in tons per square foot. The spring-operated device uses a piston that is pushed into a coil up to a calibra�on groove. An indicator sleeve marks and retains the reading un�l it is read. The reading is calibrated in TSF or kilograms per cubic cen�meter.

• Thumb Penetra�on Test: A competent person atempts to penetrate a fresh sample with thumb pressure. If the sample can be dented, but penetrated only with great effort, it is Type A. If it can be penetrated with effort and molded, it is Type B. If it can be penetrated several inches and molded with light pressure, it is Type C.

• Shearvane: Measures the approximate shear strength of saturated cohesive soils. The blades of the vane are pressed into a flat sec�on of undisturbed soil and the knob is turned slowly un�l soil failure. The dial is read directly when using the standard vane. The results will be in TSF or kilograms per cubic cen�meter.

A competent person will perform several tests of the excava�on to obtain consistent, suppor�ng data along its depth and length. The soil is subject to change several �mes within the scope of an excava�on and the moisture content will vary with weather and job condi�ons. A competent person must also determine the level of protec�on based on what condi�ons exist at the �me of the test and allow for changing condi�ons.

Tests should be conducted for air contaminants (oxygen, flammable gases, etc.) and provide ven�la�on where necessary.

Railings and guardrails will be u�lized to protect against falls.

10.0 EXCAVATION PROTECTION SYSTEMS

The three basic protec�ve systems for excava�ons and trenches are sloping and benching systems, shoring, and shields.

The protec�ve systems shall have the capacity to resist without failure all loads that are intended or could reasonably be expected to be applied to or transmited to the system. Every employee in an excava�on shall be protected from cave-ins by an adequate protec�ve system. Excep�ons to using protec�ve systems include:

• Excava�ons that are made en�rely in stable rock

• Excava�ons that are less than 5 feet deep and declared safe by a competent person.

Trench excava�ons shall have ramps, ladders, stairs, etc. The means of egress must be within 25 feet of lateral travel for employees.

Employees should not work under loads of digging equipment where loads may fall.

Sloping and Benching Systems

• Slope to the angle required by the standard for Type C, which is the most unstable soil type.

• The table provided in Appendix B of the standard may be used to determine the maximum allowable angle a�er determining the soil type

• Tabulated data prepared by a registered professional engineer can be u�lized.

• A registered professional engineer can design a sloping plan for a specific job.

Sloping and benching systems for excava�ons 5-20 feet in depth must be constructed under the instruc�on of a designated competent person.

Sloping and benching systems for excava�ons greater than 20 feet must be designed and stamped by a registered professional engineer.

Sloping and benching specifica�ons can be found in Appendix B of the OSHA standard (Subpart P).

Shoring Systems

Shoring is another protec�ve system or support system. Shoring u�lizes a framework of ver�cal members (uprights), horizontal members (whales), and cross braces to support the sides of the excava�on to prevent a cave-in. Common examples are metal hydraulic, mechanical, or �mber shoring systems.

The different examples of shoring are found in the OSHA standard under these appendices:

• Appendix C: Timber Shoring for Trenches

• Appendix D: Aluminum Hydraulic Shoring for Trenches

• Appendix E: Alterna�ves to Timber Shoring

Shield Systems (Trench Boxes)

Shielding is the third method of providing a safe workplace. Unlike sloping and shoring, shielding does not prevent cave-ins. Shields are designed to withstand the soil forces caused by a cave-in and to protect the employees inside the structure. Most shields consist of two flat, parallel, metal walls that are held apart by metal cross braces.

Shielding design and construc�on is not covered in OSHA standards. Shields must be cer�fied in design by a registered, professional engineer and must have either a registra�on plate on the shield or registra�on papers from the manufacturer on file at the jobsite office. Any repairs or modifica�ons must be approved by the manufacturer.

Safety Precau�ons for Shield Systems

• Shields must not have any lateral movement when installed.

• Employees will be protected from cave-ins when entering and exi�ng the shield (e.g., ladder within the shield or a properly sloped ramp at the end).

• Employees are not allowed in the shield during installa�on, removal, or during any ver�cal movement.

• Shields can be 2 feet above the botom of an excava�on if they are designed to resist loads at the full depth and if there are no indica�ons of caving under or behind the shield.

• The shield must extend at least 18 inches above the point where proper sloping begins (the height of the shield must be greater than the depth of the excava�on).

• The open end of the shield must be protected from the exposed excava�on wall. The wall must be sloped, shored, or shielded. Engineer-designed end plates can be mounted on the ends of the shield to prevent cave-ins.

11.0 PERSONAL PROTECTIVE EQUIPMENT (PPE)

It is Company policy to wear a hardhat, safety glasses, and work boots on the jobsite. Because of the hazards involved with excava�ons, other PPE (e.g., goggles, gloves, and respiratory equipment) may be necessary depending on the poten�al hazards present.

12.0 INSPECTIONS

Daily inspec�on of excava�ons, the adjacent areas, and protec�ve systems shall be made by a competent person for evidence of a situa�on that could result in a cave-in, indica�ons of failure of protec�ve systems, hazardous atmospheres, or other hazardous condi�ons.

• All inspec�ons shall be conducted by a competent person prior to the start of work and as needed throughout the shi�.

• Inspec�ons will be made a�er every rainstorm or any other increasing hazard.

• All documented inspec�ons will be kept on file in the jobsite safety files and forwarded to the corporate Safety Director each week.

• A copy of the Daily Excava�on Inspec�on Form is located at the end of this program. (Atached a copy of the form)

• If hazardous environments exist all work must be ceased un�l necessary precau�ons are taken to safeguard personnel.

13.0 TRAINING

A competent person(s) must be trained in accordance with the OSHA excava�on standard and all other programs that may apply (e.g., HAZCOM, confined space, and respiratory protec�on), and must demonstrate a thorough understanding and knowledge of the programs and the associated hazards. All other employees working in and around the excava�on must be trained in the recogni�on of hazards associated with trenching and excava�ng.

14.0 DEFINITIONS

Benching: A method of protec�ng employees from cave-ins by excava�ng the sides of an excava�on to form one or a series of horizontal levels or steps, usually with ver�cal or near-ver�cal surfaces between levels.

Cave-In: The separa�on of a mass of soil or rock material from the side of an excava�on or the loss of soil from under a trench shield or support system and its sudden movement into the excava�on, either by failing or sliding, in sufficient quan�ty so that it could entrap, bury, or otherwise injure and immobilize a person.

Competent Person: One who is capable of iden�fying exis�ng and predictable hazards in the surroundings or working condi�ons, which are unsanitary, hazardous, or dangerous to employees, and who has authoriza�on to take prompt correc�ve measures to eliminate them.

Dura�on of Exposure: The longer an excava�on is open, the longer the other factors have to work on causing it to collapse.

Excava�on: Any man-made cut, trench, or depression in an earth surface, formed by earth removal.

Hazardous Atmosphere: An atmosphere which by reason of being explosive, flammable, poisonous, corrosive, oxidizing, irrita�ng, oxygen deficient, toxic, or otherwise harmful, may cause death, illness, or injury.

Protec�ve System: A method of protec�ng employees from cave-ins, material that could fall or roll from an excava�on, or the collapse of adjacent structures. Protec�ve systems include support systems, sloping and benching systems, shield systems, and other systems that provide necessary protec�on.

Shield: A structure that is capable of withstanding the forces imposed on it by a cave-in and thereby protects employees within the structure. Shields can be permanent structures or can be designed to be portable and moved along as work progresses. All shields must be in accordance with 29 CFR 1926.652(c)3 or (c)4.

Sloping: A method of protec�ng workers from cave-ins by excava�ng to form sides of an excava�on that are inclined away from the excava�on to prevent cave-ins. The angle of incline required to prevent a cave-in varies with differences such as soil type, length of exposure, and applica�on of surcharge loads.

Surcharge Loads: Generated by the weight of anything in proximity to the excava�on, push starts for a cave-in (anything above pushing down). Common surcharge loads include the weight of spoil pile, material and equipment, nearby buildings, poles, pavement, and other structural objects

Trench: A narrow excava�on below the surface of the ground, less than 15 feet wide, with a depth no greater than the width.

Undermining: Can be caused by such things as leaking, leaching, caving, or over-digging. Undermined walls can be very dangerous.

Vibra�on: A force that is present on construc�on sites and must be considered. The vibra�ons caused by backhoes, dump trucks, compactors and traffic on jobsites can be substan�al.

WELDING, CUTTING, AND HOT WORK

1.0 PURPOSE

The purpose of this document is to outline the welding, cu�ng, and hot work safety policy for IT Landes, hereina�er referred to as “the Company.” Welding and hot work, such as brazing or grinding, present a significant opportunity for fire and injury. All precau�ons of this program must be applied prior to commencing any welding or hot work by employees or contractors.

2.0 RESPONSIBILITIES

Management

• Provide training for all employees whose task includes heat, spark, or flame-producing opera�ons such as welding, brazing, or grinding.

• Develop and monitor effec�ve hot work procedures.

• Provide safe equipment for hot work

• Provide proper and effec�ve personal protec�ve equipment (PPE) for all hot work.

Supervisors

• Monitor all hot work opera�ons

• Ensure all hot work equipment and PPE are in safe, working order

• Allow only trained and authorized employees to conduct hot work.

• Ensure permits are used for all hot work, outside, authorized areas.

Employees

• Follow all hot work procedures

• Properly use appropriate hot work PPE.

• Inspect all hot work equipment before use

• Report any equipment problems

Never use damaged hot work equipment!

3.0 POLICY

Gas detectors will be used to iden�fy poten�al combus�ble and flammable atmospheres prior to any hot work ac�vity. Hot work can include, but is not limited to, welding, grinding, sandblas�ng, equipment opera�on, etc. Hot work shall commence within 30 minutes a�er the area has been gas tested. If longer, the area shall be retested.

A hot work assessment/permit will outline the following:

• Loca�on of work ac�vity

• Type of hot work and or heat producing device

• Answering the assessment ques�ons

• Type of fire ex�nguisher to be used

• Type of air motoring equipment including calibra�on date and air readings

• Decision tree deciding if the assessment will lead to hot work monitoring and fire watch

The hot work permit must be revalidated before work can be restarted following an interrup�on due to a stop work authority, unforeseen weather condi�ons, alarms, or any unforeseen dangerous condi�ons.

4.0 HAZARDS

• Fires and explosions

• Skin burns

• Welding “blindness”

• Respiratory hazards from fumes and smoke

5.0 TRAINING

Individuals performing welding or cu�ng must be suitably trained in the safe opera�ons of their equipment and the safe use of the process.

Training shall include:

• Review of requirements listed in OSHA 1910.252

• Use of hot work permit system

• Supervisor responsibili�es

6.0 FIRE WATCH

A fire watch is required when welding, cu�ng, brazing, or soldering is performed near combus�ble materials and/or in loca�ons where fire may develop.

Fire watchers shall have fire ex�nguishers readily available.

Fire Watch Responsibili�es

The fire watch must know:

• That their only duty is fire watch

• When they can terminate the watch

• How to use the provided fire ex�nguisher

• How to ac�vate fire alarm if fire is beyond the incipient stage

• Operator responsibili�es

• Contractor responsibili�es

• Documenta�on requirements

• Respirator usage requirements

• Fire ex�nguisher training

A fire watch shall be maintained at least 30 minutes a�er the welding or cu�ng opera�on was completed.

Assigned fire watchers must be trained in the use of fire ex�nguishing equipment and be familiar with the facili�es for sounding an alarm in the event of a fire.

Hot Work Procedures

• If the possibility of a hazardous atmosphere may be present, gas tes�ng must be done before hot work is commenced. Work must commence within 30 minutes of the ini�al reading.

• If the hazardous atmosphere may be present throughout, con�nuous gas tes�ng is required.

• Where prac�cable, all combus�bles shall be relocated at least 35 feet from the worksite. Where reloca�on is imprac�cal, combus�bles shall be protected with flame proof covers, shielded with metal, guards, curtains, or wet down material to help prevent igni�on of material.

• Ducts, conveyor systems, and augers that might carry sparks to distant combus�bles shall be protected or shut down.

• Where welding or cu�ng is done near walls, par��ons, ceilings, or a roof of combus�ble construc�on, fireresistant shields or guards shall be provided to prevent igni�on.

• If welding is to be done on a metal wall, par��on, ceiling, or roof, precau�ons shall be taken to prevent igni�on of combus�bles on the other side, due to conduc�on or radia�on of heat. Where combus�bles cannot be relocated on the opposite side of the work, a fire watch person shall be provided on the opposite side of the work.

• Welding shall not be atempted on a metal wall, par��on, ceiling, or roof having a covering nor on walls having combus�ble sandwich panel construc�on.

• Welding or cu�ng pipes or other metal in contact with combus�ble walls, par��ons, ceilings, or roofs shall not be undertaken if the work is close enough to cause igni�on by combus�on.

• If the object to be welded or cut cannot readily be moved, all moveable fire hazards should be removed.

• If the object to be welded or cut cannot be moved and if all the fire hazards cannot be removed, then guards, shields, fire blankets, etc. shall be used to confine the heat, sparks, and slag and to protect the immovable fire hazards.

Welding and cu�ng are not permited in:

• Areas not authorized by management

• Sprinkled buildings while such protec�on is impaired

• The presence of poten�ally explosive atmospheres

• Areas near the storage of large quan��es of exposed, readily ignitable materials

• Areas where there is dust accumula�on of greater than 1/16 inch within 35 feet of the area where welding/hot works will be conducted; dust accumula�on should be cleaned up following the housekeeping program of the facility before welding/hot works are permited and suitable ex�nguishers shall be provided and maintained ready for instant use

A fire watch person shall be provided during and for two hours past the comple�on of the welding project. A welding/cu�ng permit will be issued on all welding or cu�ng outside of the designated welding area. If fire hazards cannot be taken to a safe place or guards cannot be used to confine heat, sparks, slag and protect the immovable fire hazards, the welding/cu�ng shall not be performed. Operators of equipment should report any equipment defect or safety hazards and discon�nue use of equipment un�l its safety has been ensured. Repairs shall be made only by qualified personnel.

7.0 WELDING AND HOT WORK FIRE PREVENTION MEASURES

A designated welding area should be established to meet the following requirements:

• Floors swept and clean of combus�bles within 35 feet of work area.

• Flammable and combus�ble liquids and material will be kept 35 feet away from work area.

• Adequate ven�la�on providing 20 air changes per hour, such as a suc�on hood system, should be provided to the work area.

• At least one 10-pound, dry, chemical fire ex�nguisher should be accessible within 35 feet of work area.

• Protec�ve dividers, such as welding curtains and noncombus�ble walls, will be provided to contain sparks and slag to the combus�ble free area.

• Requirements for welding conducted outside the designated welding area.

• Portable welding curtains or shields must be used to protect other workers in the welding area.

• A hot work permit must be completed and complied with prior to welding opera�on.

• Precau�ons that are to be taken shall be in the form of a writen permit. Before welding/cu�ng is permited, the area shall be inspected, and a writen permit shall be used to authorize welding and cu�ng opera�ons.

• Respiratory protec�on is mandatory unless an adequate, monitored, air flow away from the welder and others present can be established and maintained.

• Plas�c materials will be covered with welding tarps during welding procedures

• Fire watch must be provided for all hot work opera�ons.

8.0 ELECTRICAL WELDING

• Ensure fire ex�nguisher is charged and available.

• Ensure electrical cord, electrode holder, and cables are free from defects. No cable splices are allowed within 10 feet of the electrode holder.

• Ensure PPE (e.g., welding hood, gloves, rubber boots/soled shoes, aprons) are available and have no defects.

• Ensure the welding unit is properly grounded.

• All defec�ve equipment must be repaired or replaced before use.

Remove Flammables and Combus�bles

• No welding is permited on or near containers of flammable material, combus�ble material, or unprotected flammable structures.

• Place welding screen or suitable barricade around work area to provide a fire safety zone and prevent injuries to passersby. Do not block emergency exits or restrict ven�la�on.

• Ensure adequate ven�la�on and ligh�ng.

• Execute hot work permit procedures.

Set Voltage Regulator

No higher than:

• 80 volts for manual alterna�ng current welders

• 100 volts for automa�c alterna�ng current welders

• 100 volts for manual or automa�c direct current welders

Uncoil and Spread Welding Cable

To avoid overhea�ng, ensure proper contact of work leads and connec�ons, and remove any metal fragments from magne�c work clamps. To avoid electric shock, do not wrap welding cables around a body part and avoid welding in wet condi�ons.

Fire watch for one hour a�er welding and un�l all welds have cooled.

Perform final fire watch and terminate permit.

9.0

GAS WELDING

• Ensure tanks have gas and fi�ngs are �ght.

• Ensure fire ex�nguisher is charged and available.

• Ensure hoses have no defects.

• Ensure PPE (e.g., welding hood, gloves, rubber boots/soled shoes, aprons) are available and have no defects.

• All defec�ve equipment must be repaired or replace before use.

Remove Flammables and Combus�bles

• No welding is permited on or near containers of flammable material, combus�ble material, or unprotected flammable structures.

• Place welding screen or suitable barricade around work area to provide a fire safety zone and prevent injuries to passersby. Do not block emergency exits or restrict ven�la�on.

• Any welding, cu�ng, or burning of lead-base metals, zinc, cadmium, mercury, beryllium, exo�c metals, or paints not listed here shall have proper ven�la�on or respiratory protec�on.

WORKING NEAR ELECTRICAL LINES

1.0 OVERVIEW

This program contains policy and procedures for working near overhead electrical systems based on OSHA standards and the IT Landes, hereina�er referred to as “the Company,” overhead powerline policy (OPP). It applies to all Company opera�ons. Areas covered include well work, earthwork, excava�on, subsurface explora�on, aerial li� and crane work, survey, and other opera�ons that could expose employees or equipment to poten�al contact to overhead electrical systems.

When working near electrical lines or equipment, avoid direct or indirect contact. Direct contact is contact with any part of the body. Indirect contact is when part of the body touches or is in dangerous proximity to any object in contact with energized electrical equipment. Two assump�ons should always be made:

• Lines are “live” (energized).

• Lines carry high voltage.

Electrical lines can only be considered “dead” when verified by the local electrical department or u�lity.

When there is any ques�on about voltage and safe distance, the work must be shut down and the supervisor or designated representa�ve contacted, and all concerns adequately addressed before ac�vi�es can resume. As voltages increase, minimum clearances increase. Injuries or fatali�es through arcing may occur even if actual contact with high-voltage lines or equipment is not made. Poten�al for arcing increases as voltage increases. Weather and contact with conductors, such as tools, can increase the possibility of becoming energized without contact.

The OPP applies to all overhead conductors, regardless of voltage and required areas to:

• Ensure employees are not placed in proximity to overhead powerlines. Proximity is defined as within 10 feet up to 50 kilovolts, and 4 inches for every 10,000 volts above 50 kilovolts.

• Inform employees of the hazards and precau�ons when working near overhead lines.

• Post warning decals on cranes and similar equipment regarding 10-foot minimum clearance.

• Ensure that when equipment is working near the proximity of overhead lines, a “spoter” is designated, observes for safe working clearances around all overhead lines, and directs the operator accordingly.

• Use warning cones as visible indicators of the 10-foot safety zone when working near the proximity of overhead power lines.

Note: Working near the proximity is defined as working within a distance from any OPL which is less than combined length of the li�ing device, the associated load length, and the required minimum clearance distance (as defined in bullet #1 above).

Required Clearance = Li� Equipment Height + Load Length + At Least 10 Feet

No�fy the local u�li�es at least 72 hours before any work begins which requires the local u�li�es to iden�fy voltages and clearances, de-energize, apply safety grounds, or relocate lines.

2.0 POLICY

All Company employees and subcontractors shall conform to the OPP. The first line of defense in preven�ng electrical contact accidents is to remain outside the minimum, safe distance clearances. Because most Company and business partner employees are not qualified to determine voltage, the local u�lity provider shall be called to establish voltages and minimum clearances and take appropriate ac�on to render the work safe. Where no�fica�on

cannot be made 72 hours prior to beginning work, efforts shall be made to request the local u�li�es to respond immediately.

All Company employees and subcontractors who work near the proximity of overhead lines shall receive specialized, electrical safety training because of their frequent work near overhead electrical systems. The Company’s Health and Safety Department shall determine training content, dura�on, and frequency. Training shall be held in conjunc�on with local training, and shall include characteris�cs, hazards, and precau�ons, for the preven�on of an overhead powerline contact.

3.0 VEHICLES AND EQUIPMENT WITH LOADS IN EXCESS OF 14 FEET

The OPP requires that all vehicles or equipment with loads in excess of 14 feet use specific procedures to maintain safe working clearances when in transit below overhead lined.

• Prior to movement of any load in excess of 14 feet, the operator and the local health and safety department must be no�fied of the equipment move.

• A Company electrician, electrical construc�on representa�ve, or a qualified electrical contractor must check the intended route to the next loca�on before reloca�on.

• Check the new site for overhead lines and clearances.

• Powerlines and communica�on lines shall be noted. Extreme care shall be used when traveling beneath these lines.

• The company moving the load or equipment will provide a driver responsible for measuring each load and ensuring each load is secured and transported in safe manner.

• A Company electrician, electrical construc�on representa�ve, or a qualified electrical contractor shall escort the first load to the new loca�on ensuring safe clearances. A service company representa�ve will be responsible for subsequent loads to follow the same safe route. If proper working clearances cannot be maintained the job must be shut down un�l a safe route can be established or the necessary repairs have been completed to ensure that a safe working clearance has been achieved.

The preferred ver�cal clearance for overhead lines 480 volts and below, including communica�on lines on MWM sites, is 21 feet with an acceptable height of 20 feet for 480-volt lines and 25 feet for 12,000-volt lines. All new overhead lines 480 volts or less, including communica�on lines, will be constructed in such a manner as to maintain a minimum of 21 feet at all points along the line.

4.0 EMERGENCY RESPONSE

If an overhead line falls or is contacted:

• Keep everyone at least 10 feet away

• Use flagging to protect motorists, spectators, and other individuals from fallen or low wires

• Call the local u�lity company immediately.

• Place “guards” around the area

• Do not atempt to move the wire(s)

• Do not touch anything that is touching the wire(s).

• Be alert to water or other conductors present.

• Crews shall have emergency numbers readily available. These numbers shall include local u�li�es police/fire, and medical assistance

If an individual becomes energized, do not touch the individual or anything in contact with them. Call for emergency medical assistance and the local electrical department or u�lity immediately. If the individual is no longer in contact with the energized conductors, CPR, rescue breathing, or first aid should be administered immediately, but only by a trained person. It is safe to touch the vic�m once contact is broken or the source is de-energized.

Wires that contact vehicles or equipment will cause arcing, smoke, and possibly fire. Occupants should remain in the cab and wait for the local emergency response. If it becomes necessary to exit the vehicle, leap with both feet as far away from the vehicle as possible, without touching the equipment. Jumping free of the vehicle is the last resort.

If an overhead wire is contacted while opera�ng the equipment, stop the equipment immediately and, if safe to do so, jump free and clear of the equipment. Maintain balance, keep feet together, and either shuffle or bunny hop away from the vehicle another 10 feet or more. Do not return to the vehicle or allow anyone else to return to the vehicle for any reason.