City Construction, Inc.

Health and Safety Manual

City Construction, Inc. 1100 Bondsville Road Downingtown, PA 19335 (610) 269-9530 Revision Date: 05/31/2017 Revision Date: 02/28/2017 Revision Date: 02/01/2017 Revision Date: 04/21/2017 Origination Date: 01/25/2016 Release Authorized by: Dennis Fallon, Responsible Safety Officer

City Construction, Inc. – Health and Safety Manual Page | 2

Safety Policy Statement It is the policy of City Construction, Inc. that injury and illness prevention shall be considered of primary importance in all phases of operations and administration.

It is the intention of the company's top management to provide safe and healthy working conditions and to establish and insist upon safe practices at all times by all employees.

The prevention of injury and illness is an objective affecting all levels of the organization and its activities. It is therefore, a basic requirement that each supervisor make the safety of employees an integral part of his or her regular management function. It is equally the duty of each employee to accept and follow established safety regulations and procedures.

Every effort will be made to provide adequate training to employees. However, if an employee is ever in doubt how to do a job safely, it is their duty to ask a qualified person for assistance. Employees are expected to assist management in injury and illness prevention activities. Unsafe conditions must be reported. Fellow employees that need help should be assisted. Everyone is responsible for the housekeeping duties that pertain to their jobs.

Any injury that occurs on the job, even a slight cut or strain, must be reported to management as soon as possible. In no circumstance, except an emergency, should an employee leave a shift without reporting an injury that occurred.

When you have an injury and illness, everyone loses; you, your family, your fellow workers, and the company. Please work safely. It's good for everyone.

____________________________________ ___________________________

President / Owner Date

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Contents Safety Policy Statement ........................................................................................................................................... 2 Health and Safety Program .................................................................................................................................... 18 Introduction to Our Program ................................................................................................................................. 18

Creating a safety culture ....................................................................................................................................... 18

Action Plan ........................................................................................................................................................ 18

Culture-building ................................................................................................................................................. 18

Individual Cooperation Necessary ........................................................................................................................ 19 Basic Safety Rules.................................................................................................................................................. 19 Designated Responsible Safety Officer (RSO) ..................................................................................................... 23 Responsibilities ...................................................................................................................................................... 24 Employee Compliance & Accident Free Workplace ............................................................................................ 25 Disciplinary Policy .................................................................................................................................................. 25 Safety & Health Training ........................................................................................................................................ 28 Safety Training Topics ........................................................................................................................................... 29 Safety Training Meetings ....................................................................................................................................... 30 Client Safety Procedures ....................................................................................................................................... 30 Employee Training Documentation ....................................................................................................................... 31 Employee Communication ..................................................................................................................................... 31 Hazard Identification .............................................................................................................................................. 31 Accident Investigation ........................................................................................................................................... 31

Records ................................................................................................................................................................ 32

Initial Identification/Assessment of Evidence .................................................................................................... 32

Collection/Preservation and Security of Evidence............................................................................................. 32

Witness Interviews and Statements .................................................................................................................. 32

Accident Reporting ................................................................................................................................................. 33 Accident Investigation Form ................................................................................................................................. 34 OSHA Records Required ....................................................................................................................................... 35 Injury Management ................................................................................................................................................. 36 Safety Equipment ................................................................................................................................................... 37 Protective Equipment I Clothing ........................................................................................................................... 37 Smoking & Fire Safety ............................................................................................................................................ 37 Code of Safe Practices ........................................................................................................................................... 38

General Safe Practices ......................................................................................................................................... 38

Hazard Specific Code of Safe Practices ............................................................................................................... 41 General Work Environment................................................................................................................................... 41

Personal Protective Equipment & Clothing ........................................................................................................... 41

Walkways ............................................................................................................................................................. 42

Floor & Wall Openings .......................................................................................................................................... 42

Stairs & Stairways ................................................................................................................................................. 42

Exit Doors ............................................................................................................................................................. 43

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Portable Ladders .................................................................................................................................................. 44

Hand Tools & Equipment ...................................................................................................................................... 44

Portable (Power Operated) Tools & Equipment .................................................................................................... 45

Abrasive Wheel Equipment Grinders .................................................................................................................... 45

Powder Actuated Tools ......................................................................................................................................... 45

Machine Guarding ................................................................................................................................................ 46

Electrical ............................................................................................................................................................... 46

Lockout Tagout: Control of Hazardous Energy ..................................................................................................... 48

Welding, Cutting & Brazing ................................................................................................................................... 48

Arc Welders .......................................................................................................................................................... 49

Compressors & Compressed Air .......................................................................................................................... 50

Compressed Air Receivers ................................................................................................................................... 50

Compressed Gas & Cylinders ............................................................................................................................... 51

Material Handling .................................................................................................................................................. 51

Hoist & Auxiliary Equipment.................................................................................................................................. 51

Cranes .................................................................................................................................................................. 52

Industrial Trucks -Forklifts ..................................................................................................................................... 52

Spraying Operations ............................................................................................................................................. 53

General Requirements ........................................................................................................................................... 53 Environmental Controls ........................................................................................................................................ 53

Ventilation for Indoor Air Quality ........................................................................................................................... 54

Flammable & Combustible Materials .................................................................................................................... 55

Fire Protection ...................................................................................................................................................... 56

Company Fire Brigades ........................................................................................................................................ 56

Hazardous Chemical Exposures ........................................................................................................................... 56

Hazardous Substances Communication ............................................................................................................... 57

Identification of Piping Systems ............................................................................................................................ 58

Transporting Employees & Materials .................................................................................................................... 58

Sanitizing Equipment & Clothing ........................................................................................................................... 58

Emergency Action Plan ........................................................................................................................................ 59

Infection Control .................................................................................................................................................... 60

Ergonomics ........................................................................................................................................................... 60

Back & Lifting Safety ............................................................................................................................................. 61

Housekeeping ....................................................................................................................................................... 61

Maintenance Areas ............................................................................................................................................... 62

Material Storage ................................................................................................................................................... 63

Company Vehicles ................................................................................................................................................ 63

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Tire Inflation .......................................................................................................................................................... 64

Fueling .................................................................................................................................................................. 64

Working in the Cold .............................................................................................................................................. 64

Training ............................................................................................................................................................. 64

General ............................................................................................................................................................. 65

Working in the Heat .............................................................................................................................................. 65

Using the Heat Index ........................................................................................................................................ 65

Actions for Low Risk Conditions ....................................................................................................................... 65

Actions for Moderate Risk Conditions ............................................................................................................... 65

Actions for High Risk Conditions ....................................................................................................................... 66

Actions for Very High to Extreme Risk Conditions ............................................................................................ 66

General ............................................................................................................................................................. 66

INDIVIDUAL COMPLIANCE PROGRAMS .............................................................................................................. 67 Safety Training ........................................................................................................................................................ 67 Hazard Assessment ................................................................................................................................................ 68

Purpose ................................................................................................................................................................ 68

Introduction ........................................................................................................................................................... 68

Hazard Identification ............................................................................................................................................. 68

Hazard risk assessment ....................................................................................................................................... 68

Ranking or Prioritizing Hazards ............................................................................................................................ 68

Hazard Identification Record Keeping .................................................................................................................. 69

Conclusions and lessons learned ......................................................................................................................... 69

Hazard Identification Training ............................................................................................................................... 69

Drug and Alcohol Free Workplace ........................................................................................................................ 69 Purpose ................................................................................................................................................................ 69

Administrative Duties ............................................................................................................................................ 69

Company Policy .................................................................................................................................................... 69

Drug and Alcohol Testing ..................................................................................................................................... 70

Company-Sponsored Activities ............................................................................................................................. 70

Supervisor Training ............................................................................................................................................... 70

Employee Education and Awareness ................................................................................................................... 71

Recordkeeping ...................................................................................................................................................... 72

Conviction Notification .......................................................................................................................................... 72

Employee Sanction ............................................................................................................................................... 72

Workplace Violence Prevention ............................................................................................................................ 73 Company Policy .................................................................................................................................................... 73

Responsibility and Accountability .......................................................................................................................... 73

Compliance ........................................................................................................................................................... 73

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Hazard Assessment .............................................................................................................................................. 74

Recordkeeping and Review .................................................................................................................................. 74

Lockout/Tagout Procedures .................................................................................................................................. 76 Purpose ................................................................................................................................................................ 76

Administrative Duties ............................................................................................................................................ 76

Basic Rules for Using Lockout or Tagout System Procedure ............................................................................... 76

Definitions ............................................................................................................................................................. 77

Preparation for Lock and Tag Out Procedures ..................................................................................................... 77

Sequence of Lockout System Procedure .............................................................................................................. 77

Sequence of Tagout System Procedure ............................................................................................................... 78

Restoring Machines/Equipment to Normal Production Operations ....................................................................... 78

Temporary Removal ............................................................................................................................................. 79

Procedure Involving More Than One Person ........................................................................................................ 79

Stored Energy ....................................................................................................................................................... 79

Extended Lockout/Tagout ..................................................................................................................................... 80

Procedure for Electrical Plug-Type Equipment ..................................................................................................... 80

Management's Removal of Lock and Tag Out ...................................................................................................... 80

Additional State Requirements ............................................................................................................................. 80

Training ................................................................................................................................................................. 80

Documentation ...................................................................................................................................................... 81

Affected Employees for Lockout/Tagout ............................................................................................................... 81

Periodic Inspection ............................................................................................................................................... 81

Aerial & Scissor Lift Safety Program .................................................................................................................... 82 Purpose ................................................................................................................................................................ 82

Administrative Duties ............................................................................................................................................ 82

Definitions ............................................................................................................................................................. 82

Fall Protection ....................................................................................................................................................... 82

Equipment ............................................................................................................................................................ 83

Procedures ........................................................................................................................................................... 83

Electrical Safety .................................................................................................................................................... 84

Specific requirements ........................................................................................................................................... 84

Training ................................................................................................................................................................. 85

Ladder Safety .......................................................................................................................................................... 86 Purpose ................................................................................................................................................................ 86

Hazards ................................................................................................................................................................ 86

Inspections ........................................................................................................................................................... 86

Storage ................................................................................................................................................................. 86

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Ratings & Limits .................................................................................................................................................... 87

Ladder Setup ........................................................................................................................................................ 87

Maintenance ......................................................................................................................................................... 87

Additional State Requirements ............................................................................................................................. 87

Personal Protective Equipment ............................................................................................................................. 88 Purpose ................................................................................................................................................................ 88

General Policy ...................................................................................................................................................... 89

Responsibilities ..................................................................................................................................................... 89

Hazard Assessment .............................................................................................................................................. 89

Sources ................................................................................................................................................................ 89

Organize Data ....................................................................................................................................................... 90

Analyze Data ........................................................................................................................................................ 90

Controlling Hazards .............................................................................................................................................. 90

Assessment and Selection ................................................................................................................................... 90

Selection Guidelines ............................................................................................................................................. 90

Fitting the Device .................................................................................................................................................. 91

Devices with Adjustable Features ......................................................................................................................... 91

Reassessment of Hazards .................................................................................................................................... 91

Training ................................................................................................................................................................. 91

Cleaning and Maintenance ................................................................................................................................... 92

Personal Protective Equipment ............................................................................................................................. 92

Equipment Specifications and Requirements ....................................................................................................... 92

Eye and Face Protection ...................................................................................................................................... 93

Description and Use of Eye/Face Protectors ........................................................................................................ 93

Emergency Eyewash Facilities ............................................................................................................................. 94

Hearing Protection ................................................................................................................................................ 94

Respiratory Protection .......................................................................................................................................... 95

Head Protection .................................................................................................................................................... 95

Safety Shoes ........................................................................................................................................................ 96

Hearing Personal Protective Equipment ............................................................................................................... 97

Fall Protection Plan ................................................................................................................................................ 98 Purpose ................................................................................................................................................................ 99

Our Duty to Provide Fall Protection ...................................................................................................................... 99

Worksite Assessment and Fall Protection System Selection ................................................................................ 99

Unprotected Sides and Edges ............................................................................................................................ 100

Leading Edge Work ............................................................................................................................................ 100

Hoist Areas ......................................................................................................................................................... 100

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Holes .................................................................................................................................................................. 101

Formwork and Reinforcing Steel ......................................................................................................................... 101

Ramps, Runways, and Other Walkways ............................................................................................................. 101

Excavations ........................................................................................................................................................ 101

Dangerous Equipment ........................................................................................................................................ 102

Roofing Work on Low-Slope Roofs ..................................................................................................................... 102

Steep Roofs ........................................................................................................................................................ 102

Walking/Working Surfaces Not Otherwise Addressed ........................................................................................ 103

Protection from Falling Objects ........................................................................................................................... 103

Controlled Access Zones .................................................................................................................................... 103

Safety Monitoring Systems ................................................................................................................................. 104

Selection & Use Guidelines for Fall Protection Equipment ................................................................................. 104

General Worksite Policy ..................................................................................................................................... 105

Training Program ................................................................................................................................................ 105

Enforcement ....................................................................................................................................................... 106

Injured Worker Removal ..................................................................................................................................... 106

Post-Fall Procedure ............................................................................................................................................ 106

Incident Investigation .......................................................................................................................................... 107

Changes to Plan ................................................................................................................................................. 107

Infection Control Program ................................................................................................................................... 108 Purpose .............................................................................................................................................................. 108

Training ............................................................................................................................................................... 108

Infection Control Program ................................................................................................................................... 108

Blood borne Pathogens ....................................................................................................................................... 110 Purpose .............................................................................................................................................................. 110

Training ............................................................................................................................................................... 110

Scope ................................................................................................................................................................. 110

Exposure Control ................................................................................................................................................ 110

Hygiene .............................................................................................................................................................. 111

Personal Protective Equipment ........................................................................................................................... 111

Our staff employs the following practices: .......................................................................................................... 112

Hepatitis B Vaccination ....................................................................................................................................... 112

Recordkeeping .................................................................................................................................................... 112

Medical Records. ............................................................................................................................................ 112

Training Records ................................................................................................................................................ 112

Benzene Safety ..................................................................................................................................................... 114 Purpose .............................................................................................................................................................. 114

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Characteristics .................................................................................................................................................... 114

Uses ................................................................................................................................................................... 114

Health Effects ..................................................................................................................................................... 114

Personal Protective Measures ............................................................................................................................ 115

Permissible Exposure Limits ............................................................................................................................... 115

Special Requirements ......................................................................................................................................... 115

Training ............................................................................................................................................................... 115

Emergency Evacuation Plan ............................................................................................................................... 115

Hydrogen Sulfide Safety ...................................................................................................................................... 115 Purpose .............................................................................................................................................................. 116

Characteristics .................................................................................................................................................... 116

Exposure Detection ............................................................................................................................................ 116

Health Effects ..................................................................................................................................................... 116

Permissible Exposure Levels (PEL) .................................................................................................................... 116

Personal Protective Measures ............................................................................................................................ 117

Special Requirements ......................................................................................................................................... 117

Training ............................................................................................................................................................... 117

Emergency Evacuation Plan ............................................................................................................................... 117

Spill Response Policy .......................................................................................................................................... 118 Purpose .............................................................................................................................................................. 118

Policy .................................................................................................................................................................. 118

Definitions ........................................................................................................................................................... 118

Responsibilities ................................................................................................................................................... 118

Procedure ........................................................................................................................................................... 119

Spill Notifications ............................................................................................................................................ 119

Training ............................................................................................................................................................... 120

Crane and Derrick Operation Procedures .......................................................................................................... 121 Administrative Duties .......................................................................................................................................... 121

Training ............................................................................................................................................................... 122

Initial Training ................................................................................................................................................. 122

Training Certification ....................................................................................................................................... 122

Performance Evaluation .................................................................................................................................. 123

Current Crane/Derrick Operators .................................................................................................................... 123

Initial Inspections ................................................................................................................................................ 123

Frequent Inspections ...................................................................................................................................... 123

Pre-Operational Site Activity and Inspection ....................................................................................................... 123

Periodic Inspections ............................................................................................................................................ 123

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Operating Procedures ......................................................................................................................................... 123

General Procedures ........................................................................................................................................ 124

Procedures for Operators ............................................................................................................................... 124

Procedures for All Employees ......................................................................................................................... 125

Procedures for Employees When Using the Suspended Personnel Platform Hoist ........................................ 125

Maintenance ....................................................................................................................................................... 125

Assembly / Disassembly ..................................................................................................................................... 125

Posting ................................................................................................................................................................ 126

Recordkeeping & Certification ............................................................................................................................ 126

Maintenance Records ......................................................................................................................................... 126

Effective Nov. 8, 2010, the new OSHA-Crane and Derrick Standard changes the way cranes are used in the construction industry: .......................................................................................................................................... 126

Controlling Entity: ............................................................................................................................................ 126

Crane Rules .................................................................................................................................................... 126

Work Area Control .......................................................................................................................................... 127

Rigging Material Handling ................................................................................................................................... 128 Purpose .............................................................................................................................................................. 128

Scope ................................................................................................................................................................. 128

Definitions ........................................................................................................................................................... 128

Key Responsibilities ............................................................................................................................................ 128

Procedure ........................................................................................................................................................... 128

General ........................................................................................................................................................... 128

Material Handling ............................................................................................................................................ 128

Training and Education ....................................................................................................................................... 129

Excavation, Trenching and Shoring Procedures ............................................................................................... 130 Definitions ........................................................................................................................................................... 130

Administrative Duties .......................................................................................................................................... 131

Before Excavating ............................................................................................................................................... 131

Testing Methods ................................................................................................................................................. 131

Visual test ....................................................................................................................................................... 132

Manual tests ................................................................................................................................................... 132

Spoil .................................................................................................................................................................... 132

Surface Crossing of Trenches ............................................................................................................................ 132

Ingress & Egress ................................................................................................................................................ 133

Protective Support Systems ................................................................................................................................ 133

Sloping ............................................................................................................................................................ 133

Benching ......................................................................................................................................................... 135

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Support Systems, Shield Systems, and Other Protective Systems .................................................................... 136

Timber Shoring ............................................................................................................................................... 136

Aluminum Hydraulic Shoring ........................................................................................................................... 136

Other Support Systems ...................................................................................................................................... 139

Shielding ............................................................................................................................................................. 139

Other Protective Systems ................................................................................................................................... 139

General Requirements for Excavations .............................................................................................................. 140

Training ............................................................................................................................................................... 140

Training Certification ....................................................................................................................................... 140

Current Certified Excavation Workers ............................................................................................................. 141

Excavation Safety Inspections ............................................................................................................................ 141

Personal Protective Equipment ........................................................................................................................... 141

Exposure to Vehicles .......................................................................................................................................... 141

Exposure to Falling Loads .................................................................................................................................. 141

Recordkeeping .................................................................................................................................................... 141

Hazard Communication Program ........................................................................................................................ 142 Purpose .............................................................................................................................................................. 142

Responsibilities ............................................................................................................................................... 142

Chemical Inventory List ................................................................................................................................... 143

Labels and Other Forms Of Warning .............................................................................................................. 143

Safety Data Sheets ......................................................................................................................................... 144

Employee Information and Training ................................................................................................................ 145

Non-Routine Tasks ......................................................................................................................................... 145

Contractors ..................................................................................................................................................... 146

Recordkeeping ................................................................................................................................................ 146

Concrete ................................................................................................................................................................ 148 Hazards & Solutions ........................................................................................................................................... 148

Purpose .......................................................................................................................................................... 148

Cement Dust ................................................................................................................................................... 148

Wet Concrete .................................................................................................................................................. 148

Respiratory Protection ......................................................................................................................................... 149 Purpose .............................................................................................................................................................. 149

Scope ................................................................................................................................................................. 149

Respiratory Program Administrator ..................................................................................................................... 149

Medical Requirements ........................................................................................................................................ 150

General ........................................................................................................................................................... 150

Medical Evaluation Procedures ...................................................................................................................... 150

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Supplemental Information for the PLHCP ....................................................................................................... 150

Medical Determination .................................................................................................................................... 150

Additional Medical Evaluations ....................................................................................................................... 151

Work Site Procedures ......................................................................................................................................... 151

Respirator Selection Criteria ............................................................................................................................... 151

Hazard Identification ........................................................................................................................................... 151

Characteristics of Hazardous Operation or Process ....................................................................................... 152

Gaseous Contaminants .................................................................................................................................. 152

Particulate contaminants ................................................................................................................................. 152

Selection of Respirator ....................................................................................................................................... 152

Concentration and Type of Contaminant ........................................................................................................ 152

Location of Hazardous Area ........................................................................................................................... 152

Worker Activity ................................................................................................................................................ 152

Types of Respirators ....................................................................................................................................... 153

Brand and Models ........................................................................................................................................... 153

Estimate of Exposures and Contaminant Information ..................................................................................... 154

Respirator Fit Testing ......................................................................................................................................... 154

Fit Test Procedures ........................................................................................................................................ 155

User Seal Check ............................................................................................................................................. 156

Positive Pressure Check ................................................................................................................................. 156

Negative Pressure Check ............................................................................................................................... 156

Test Exercises ................................................................................................................................................ 156

Rainbow Passage ........................................................................................................................................... 157

Qualitative Fit Test (QLFT) Protocols ................................................................................................................. 157

General ........................................................................................................................................................... 157

Irritant Smoke (Stannic Chloride) Protocol ...................................................................................................... 157

General Requirements and Precautions. ........................................................................................................ 158

Irritant Smoke Fit Test Procedure ................................................................................................................... 158

Quantitative Fit Test (QNFT) Protocols ........................................................................................................... 159

Porta count Fit Test Requirements ................................................................................................................. 159

Porta count Test Instrument ............................................................................................................................ 159

Use, Maintenance and Care of Respirators ........................................................................................................ 159

Use ..................................................................................................................................................................... 159

Cleaning and Disinfecting Requirements ............................................................................................................ 160

Cleaning Procedures ...................................................................................................................................... 160

Storage and Inspection ................................................................................................................................... 160

Breathing Air Quality and Use ............................................................................................................................. 161

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Voluntary Use ..................................................................................................................................................... 162

Workplace Monitoring ......................................................................................................................................... 162

Recordkeeping .................................................................................................................................................... 162

Program Evaluation ............................................................................................................................................ 162

Training ............................................................................................................................................................... 163

Retraining ........................................................................................................................................................... 163

City Construction, Inc. Qualitative Respiratory Fit Test Record Sheet ................................................................ 164

Electrical Safety .................................................................................................................................................... 165 Purpose .............................................................................................................................................................. 165

Scope ................................................................................................................................................................. 165

Definitions ........................................................................................................................................................... 165

Responsibilities ................................................................................................................................................... 167

Managers/Supervisor ...................................................................................................................................... 167

Safe Work Practices ........................................................................................................................................... 167

Inspections ...................................................................................................................................................... 167

Repairs ........................................................................................................................................................... 167

Extension Cords ............................................................................................................................................. 167

Outlets ............................................................................................................................................................ 168

Multiple Outlet Boxes ...................................................................................................................................... 168

Double Insulated Tools ................................................................................................................................... 168

Switches, circuit breakers, and disconnects ................................................................................................... 168

Ladders ........................................................................................................................................................... 168

Energized and Overhead High Voltage Power Lines & Equipment ................................................................. 169

Confined or Enclosed Work Spaces ............................................................................................................... 169

Enclosures, Breaker Panels, and Distribution Rooms ..................................................................................... 169

Lock Out/Tag Out ........................................................................................................................................... 169

Contractors ..................................................................................................................................................... 170

Fire Extinguishers ........................................................................................................................................... 170

Electric Shock-CPR ........................................................................................................................................ 170

Electric Welders .............................................................................................................................................. 170

Equipment Grounding ..................................................................................................................................... 170

Assured Grounding ......................................................................................................................................... 170

Ground Fault Circuit Interrupters .................................................................................................................... 171

Training ........................................................................................................................................................... 171

Scaffold Safety Program ...................................................................................................................................... 172 Purpose .............................................................................................................................................................. 172

Applicability ......................................................................................................................................................... 172

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Reference ........................................................................................................................................................... 172

Policy .................................................................................................................................................................. 172

Responsibilities ................................................................................................................................................... 172

Definitions ........................................................................................................................................................... 172

Training ............................................................................................................................................................... 173

Safe Scaffold Erection and Use .......................................................................................................................... 173

Types of Scaffolds .............................................................................................................................................. 173

Responsibilities ................................................................................................................................................... 174

RSO ................................................................................................................................................................ 174

Supervisors ..................................................................................................................................................... 174

Competent Person .......................................................................................................................................... 174

Employees ...................................................................................................................................................... 175

Safety Department .......................................................................................................................................... 175

Purchasing Department .................................................................................................................................. 175

Safety Requirements for Scaffolds ..................................................................................................................... 175

First AID ................................................................................................................................................................. 177 1.0 Policy ............................................................................................................................................................ 177

2.0 Purpose ........................................................................................................................................................ 177

3.0 Definitions ..................................................................................................................................................... 177

4.0 Requirements ............................................................................................................................................... 179

4.1 Designated Medical Treatment Facility ..................................................................................................... 179

4.2 First Aid ..................................................................................................................................................... 179

4.2a Elements of the First Responder Program should include: ..................................................................... 180

First Aid / CPR. ............................................................................................................................................... 180

4.3 First Aid Stations / First Aid Kits ................................................................................................................ 181

4.4 Emergency Eye / Body Wash Stations ..................................................................................................... 181

5.6 Blood borne Pathogens (Universal) Precautions Training ........................................................................ 181

5.6.1 Training Requirements ........................................................................................................................... 182

5.6.2 First Responder Exposure ..................................................................................................................... 182

Confined Space Entry .......................................................................................................................................... 183 1.0 Confined Space Program.............................................................................................................................. 183

1.1 Purpose .................................................................................................................................................... 183

1.2 Objectives ................................................................................................................................................. 183

2.0 Regulations/References ................................................................................................................................ 183

2.1 Regulations ............................................................................................................................................... 183

3.0 Responsibilities/Resources Employed .......................................................................................................... 183

3.1 Safety Manager: ....................................................................................................................................... 183

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3.2 Area Supervisors: ..................................................................................................................................... 183

3.3 Entry Supervisors:..................................................................................................................................... 183

3.4 Trained and Authorized Attendants and Entrants: .................................................................................... 184

3.5 Training Frequency: .................................................................................................................................. 184

3.6 Training Content: ...................................................................................................................................... 184

4.0 Confined Space Locations ............................................................................................................................ 184

4.1 Inventory ................................................................................................................................................... 184

4.2 Reclassification of Permit Required Confined Spaces .............................................................................. 185

5.0 Entry Permits ................................................................................................................................................ 185

5.1 Permit Required Spaces: .......................................................................................................................... 185

5.2 Permit Requirements ................................................................................................................................ 185

6.0 Prevention of Unauthorized Entry ................................................................................................................. 185

6.1 Posting of Confined Spaces ...................................................................................................................... 185

6.2 Other Necessary Precautions ................................................................................................................... 186

7.0 Entry Procedures .......................................................................................................................................... 186

7.1 Entry Procedures: ..................................................................................................................................... 186

7.2 Review of Entry Operations and Procedures: ........................................................................................... 186

7.3 Confined Space Equipment ...................................................................................................................... 186

7.4 Evaluation of Permit Space Conditions ..................................................................................................... 187

7.6 Number of Attendants Required................................................................................................................ 187

7.7 Multiple Employers/Contractors ................................................................................................................ 187

7.8 Conclusion of Operations .......................................................................................................................... 187

8.0 Rescue Procedures ...................................................................................................................................... 188

8.1 Rescue Plan: ............................................................................................................................................ 188

8.2 Rescue Equipment: ................................................................................................................................... 188

8.3 Rescue Practice ........................................................................................................................................ 188

8.4 Rescue Plan and Entry Permit .................................................................................................................. 188

8.5 Offsite Rescue Services ............................................................................................................................ 188

Work Zone Traffic Control ................................................................................................................................... 192 Introduction ......................................................................................................................................................... 192

Work Area Duration ............................................................................................................................................ 192

Mobile Work: ................................................................................................................................................... 192

Short Duration: ................................................................................................................................................ 192

Short-Term Stationary: .................................................................................................................................... 193

Intermediate-Term Stationary: ........................................................................................................................ 193

Long-Term Stationary: .................................................................................................................................... 193

Night work: ...................................................................................................................................................... 193

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Incident Management Situations: .................................................................................................................... 193

Advance Warning Signs .................................................................................................................................. 194

Guidance for Proper Signing ........................................................................................................................... 194

Traffic Controllers (Flagger) ............................................................................................................................ 196

Traffic Observers (Spotters) ............................................................................................................................ 197

Taper Length Criteria for Work Zones ................................................................................................................ 198

CONSTRUCTION WASTE MANAGEMENT .......................................................................................................... 199 PART 1 – GENERAL .......................................................................................................................................... 199

1.1 SUMMARY ............................................................................................................................................... 199

1.2 DEFINITIONS ........................................................................................................................................... 199

1.3 SUBMITTALS ........................................................................................................................................... 199

1.4 PERFORMANCE REQUIREMENTS ........................................................................................................ 199

1.5 QUALITY ASSURANCE ........................................................................................................................... 200

1.3 WASTE MANAGEMENT PLAN ................................................................................................................ 200

1.4 WASTE MANAGEMENT REPORT ........................................................................................................... 200

PART 2 - PRODUCTS (Not Used) ...................................................................................................................... 201

PART 3 - EXECUTION ....................................................................................................................................... 201

3.1 CONSTRUCTION WASTE MANAGEMENT, GENERAL .......................................................................... 201

3.2 SOURCE SEPARATION .......................................................................................................................... 201

3.3 CO-MINGLED RECYCLING ..................................................................................................................... 201

3.4 REMOVAL OF CONSTRUCTION WASTE MATERIALS .......................................................................... 201

SAMPLE WASTE MANAGEMENT PLAN ....................................................................................................... 202

Gas Hazard Awareness ........................................................................................................................................ 203 Purpose .............................................................................................................................................................. 203

Scope ................................................................................................................................................................. 203

Procedure ........................................................................................................................................................... 203

Gas Hazards Equipment ................................................................................................................................. 203

Training ........................................................................................................................................................... 203

In Plant Rail Safety ............................................................................................................................................... 204 Purpose .............................................................................................................................................................. 204

Key Responsibilities ............................................................................................................................................ 204

Procedures ......................................................................................................................................................... 204

Obtain Permission to Work In Advance .......................................................................................................... 204

Safety Equipment ........................................................................................................................................... 204

Protection of Workers from Moving Equipment ............................................................................................... 204

Railroad Crossing Safety ................................................................................................................................ 205

Training ........................................................................................................................................................... 205

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Mobile Equipment ................................................................................................................................................. 205 Purpose .............................................................................................................................................................. 205

Key Responsibilities ............................................................................................................................................ 205

Mobile Equipment ............................................................................................................................................... 205

PROCESS SAFETY MANAEMENT ....................................................................................................................... 209 1.1 Purpose ........................................................................................................................................................ 209

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Health and Safety Program Introduction to Our Program A Health and Safety Program (HSP) protects you and your co-workers from work-related injuries and illnesses. Please take the time to read it carefully. Direct any questions you may have about our HSP to the Responsible Safety Officer (RSO). An effective HSP includes these elements: 1. A written plan designating who's in charge of safety program implementation. 2. An inspection system to identify workplace hazards. 3. Procedures for investigating the cause of accidents, illnesses or injuries. 4. Methods to ensure elimination of hazards once they're identified through inspections and accident investigations. 5. A safety and health training program specific to each job that's required for new employees as well as whenever new substances, processes, procedures or equipment are introduced to the workplace. 6. A system for employees to communicate safety concerns to employers without fear of reprisal. 7. A system for ensuring employee compliance with safety and health practices. 8. Maintenance of appropriate records and steps taken to implement and maintain the accident prevention program. Creating a safety culture A safety culture is a broad, organization-wide approach to safety management. A safety culture is the end result of combined individual and group efforts toward values, attitudes, goals and proficiency of an organization’s health and safety program. In creating a safety culture, all levels of management are highly regarded on how they act toward workers and on a day-to-day basis. Upper management commitment to workplace safety helps workers take it more seriously and translates into a safer work environment for everyone. Responsibility for encouraging the safety culture may start with management, but it trickles down to each individual in the company. Everyone has a part in keeping themselves and others safe. Action Plan To assist management with building a safety culture we appointed a champion at each jobsite. This person is responsible for understanding what it will take to build a safety culture at his or her location, including current hazards, areas for improvement, and necessary employee training for improved safety practices. This person may also gather incident reports and conduct accident investigations. Culture-building Creating an effective safety culture is an ongoing process and is a large commitment on behalf of the entire company, however, the effort results in a positive attitude toward safety and a reduction in accidents and incidents. The following will building a strong safety culture at City Construction, Inc.: 1. Define safety responsibilities: This will include policies, goals and plans for the safety culture. 2. Share your safety vision: Everyone should be in the same boat when establishing goals and objectives for their safety culture. 3. Enforce accountability: Create a process that holds everyone accountable for being visibly involved, especially managers and supervisors. They are the leaders for a positive change.

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4. Provide multiple options: Provide different options for employees to bring their concerns or issues full-face. There should be a chain of command to make sure supervisors are held accountable for being responsive. 5. Report, report, report: Educate employees on the importance of reporting injuries, first aids and near misses. Prepare for an increase in incidents if currently there is under-reporting. It will level off eventually. 6. Evaluate the incident investigation system this is critical to make sure investigations are conducted in an effective manner. This should help get to the root cause of accidents and incidents. 7. Build trust: When things start to change in the workplace, it is important to keep the water calm. Building trust will help everyone work together to see improvements. 8. Celebrate success: Make your efforts public to keep everyone motivated and updated throughout the process.

Individual Cooperation Necessary Safety in the workplace is a team effort. Everyone must do their part to ensure not only their own safety, but the safety of everyone else as well. City Construction, Inc. has established policies and procedures for working safety and provides to our employees mechanical and physical protection, however, "your" safety is ultimately "your" responsibility. Safety Program Goals City Construction, Inc.'s goal is to reduce work-related injuries and illnesses to the lowest possible level. Ultimately, our goal is to eliminate all work-related injuries and illnesses. "NO JOB IS SO IMPORTANT AND NO SERVICE SO URGENT THAT WE CANNOT TAKE TIME TO PERFORM OURWORK SAFELY" Basic Safety Rules

1. Compliance with applicable Federal, State, County, City, Client and Company Safety Rules and Regulations is a condition of employment.

2. Every injury, regardless of its nature or extent, should be reported to your supervisor. Failure to comply with this rule could delay the correction of the situation which caused the injury.

3. The possession or use of alcoholic beverages on company property is prohibited. No worker shall report for duty, or perform duties, while under the influence of intoxicants.

4. The use of narcotics or tranquilizers by employees during working hours is prohibited unless under the supervision of a physician and knowledge of your supervisor.

5. Do not remove, displace, damage, destroy or carry off any safety device, safeguard, notice, or warning. 6. Do not engage in fighting, horseplay, or distraction of fellow employees. 7. Do not attempt to lift anything that may be too heavy or bulky for your physical capacity. If in doubt, get

help. 8. Good housekeeping shall be maintained in all work areas. Clean up waste materials promptly and

completely after a job is completed. 9. Observe all traffic rules and regulations when driving. 10. Do not operate a piece of equipment unless you have been instructed in its use. 11. Smoking is allowed "only" in designated areas. 12. Never use a box, bucket, chair, shelf, etc., as a ladder. Use only approved step-stools or ladders.

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13. Observe and obey all safety signs and procedures in any area you are assigned to work in. 14. Report all damaged or faulty equipment to your supervisor unless you are authorized to make repairs. 15. No unauthorized person shall make electrical or mechanical repairs or adjustments on equipment. 16. Refrain from hanging articles from building fire sprinkler system or insulated steam or water lines. 17. Do not block or obstruct an aisle, passageway, hallway, stairway, escape way, or exit. Do not use these

areas for storage. 18. Maintain adequate access to electrical panels. 19. Do not block or cover fire extinguishers, fire alarms, or sprinkler heads. 20. Approaches doors slowly and open them with caution; someone may be on the other side. 21. Fire doors must not be blocked open or locked in such a way that they cannot be opened in the exit

direction. 22. When using stairs, do not carry loads so large that the view of stair treads is obscured. Keep one hand free

for the hand rail. 23. Keep stairs clear of all objects. Pick up anything you find on the stairs and store or dispose of it properly. 24. Know where the fire extinguisher in your area is, how to use it, and for what types of fires it is rated. 25. The burning of decorative candles is not permitted without specific permission from the fire marshal. 26. Electric coffee pots or other heating devices should be set on tile, metal, or other non-flammable surfaces,

and must be of industrial quality for use in company buildings. 27. Gasoline or similar flammable solvents should not be used to clean floors, walls, or other surfaces, or for

cleaning skin. 28. Do not run over cords, computer cables, or telephone wires across walkways creating a tripping hazard. 29. Do not use extension cords as a substitute for permanent electrical wiring. The only exception to this are

"fused" multi-outlet strips which are "UL listed." If extension cords are necessary for short-term use, use only heavy-duty cords.

30. Report unsafe conditions or behavior to your supervisor or to the RSO. 31. Wipe up all spilled liquids immediately, to prevent falls on polished floors. Place some type of warning

marker near wet spots until dry. Hazardous material spills must be reported to the RSO. Assistance in cleanup will be provided if requested.

32. Do not remove labels from chemical containers unless the containers are empty and have been thoroughly cleaned. Clean, empty containers may be used for other materials if proper new labels are affixed.

33. Clean machine parts using only approved solvents and parts-washing baths specifically designed for such use. Use with adequate ventilation. Dispose of waste solvents through the safety office.

34. Employees are not permitted to stand in the back of moving vehicles or to sit on the sides of moving pickups. Seat belts are to be used wherever provided.

35. Fall Protection Requirements: (SEE FALL PROTECTION PROGRAM) a. Full Body Harness and Lanyards shall be worn and secured any time there is a fall hazard of more

than 6 feet. b. Lifelines shall be erected to provide fall protection where work is required in areas where

permanent protection is not in place. Horizontal lifelines shall be a minimum of 112" diameter wire rope. Vertical lifelines shall be 3/4" manila rope or equivalent and shall be used in conjunction with an approved rope grab.

c. Structural steel erectors are required to "Hook Up" with full body harness and lanyard. d. Workers using their lanyards to access the work or position themselves on a wall or column, etc.,

must use an ADDITIONAL Safety lanyard for fall protection.

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36. Proper use of man lifts: As soon as you enter an articulating boom lift and before the lift is started, you must put on the harness and attach the lanyard to the lift. On scissor lifts employees are not required to wear harnesses.

37. All personnel will be required to attend a Safety Meeting as required by Project Requirements. 38. Burning and cutting equipment shall be checked daily before being used. Flash back arresters shall be

installed at the regulators on both Oxygen and L.P. bottles. All gas shall be shut off and hoses disconnected from bottles and manifolds at the end of the day. Caps shall be replaced on bottles when gauges are removed. When gauges are removed and caps replaced, the Oxygen and L.P. bottles shall be separated into storage areas not less than 20' apart with a "No Fire or Smoking" sign posted and a fire extinguisher readily available. Makeshift field repairs will not be allowed.

39. Drinking water containers are for drinking water and ice only. Tampering with or placing items such as drinks, etc., in the water cooler will result immediate termination. The "common drinking cup" is not allowed. Only disposable cups will be used.

40. All tools whether company or personal, must be in good working condition. Defective tools will not be used. Examples: chisels with mushroomed heads, hammers with loose or split handles, guards missing on saws or grinders, etc.

41. All extension cords, drop cords and electrical tools shall be checked (to include presence of GFI's) and color coded by a designated competent person each month. This shall be part of the assured grounding program. Electrical cords and equipment must be properly grounded with GFI's in place and checked by a competent person. Cords and equipment which do not meet requirements shall be immediately tagged and removed from service until repairs have been made.

42. Jobsite speed limit is 10 MPH. No one is permitted to ride in the bed of a truck standing up. Sitting on outside edges is also prohibited: "YOU MUST BE SITTING DOWN INSIDE THETRUCK OR TRUCK BED WHEN THE VEHICLE IS IN MOTION." Riding as a passenger on equipment is prohibited unless the equipment has the safe capacity of transporting personnel.

43. Adequate precautions must be taken to protect employees and equipment from Hot Work such as welding or burning. Fire extinguishing equipment shall be no further away than 50 ft. from all Hot Work. Return used extinguishers to the RSO to be re-charged immediately. Use of welding blinds is required in high traffic areas.

44. All scaffolding and work platforms must be in accordance with OSHA specifications. All ladders must be in safe condition without broken rungs or split side rails. Damaged ladders shall be removed from service. Ladders shall be secured at the top and bottom and extend 3 past the working surface. Metal ladders around electrical work are prohibited. Never use a step ladder as an extension ladder. A step ladder must only be used when fully opened with braces locked.

45. Crowfoot connections on air hoses shall be wired to prevent accidental disconnection. Compressed air shall not be used to dust off hands, face, or clothing.

46. All floor openings or excavations shall be barricaded on all sides to ensure employees are aware of the hazard. Floor holes shall be covered, the covers SECURED, and clearly marked.

47. Warning signs, barricades, and tags will be used to fullest extent and shall be obeyed. 48. Respiratory protections. (SEE RESPIRATORY PROTECTION PROGRAM) 49. Excavation: (SEE EXCAVATION PROCEDURE) as a minimum:

a. All soils in the Florida and South Georgia Region are considered type "C", which require a wall slope of 1 112 to 1 (34°) or shoring. This applies to trenches 4' or deeper.

b. All spoils, materials and equipment shall be a minimum of 2' from the edge or excavation.

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c. No employees are permitted to work under loads being handled by lifting or digging equipment. d. A stairway, ladder or ramp shall be located in trenches 4' or deeper, no more than 25' away from

the work area. e. Barricade around work area. A barricade must be erected around the excavation.

50. Confined Space: (SEE CONFINED SPACE PROGRAM) a. Any vessel, manhole or pit 5' deep or greater-including trenches, or any structure not meant for

human occupancy is considered a confined space. b. A completed Confined Space Permit by competent person is required prior to entry into permit

required confined spaces. c. Contact your Supervisor prior to starting any Confined Space work for copies of permit required

and a list of required Safety Equipment. d. See Appendix "A" for detailed requirements of equipment and procedures in use at the job site.

51. Lockout/Tagout Procedures: (SEE LOCKOUT/TAGOUT PROCEDURE) a. A written Lockout/Tagout Program is required to be in use at the jobsite when b. Lockout/Tagout procedures are used. This is available from the RSO. c. Every employee involved in the work around energized equipment has the right to put on their own

tag and lock. Otherwise, a gang-type lock box can be used if agreed upon by all parties involved. d. A responsible person from each craft will be designated to lock and tag. They shall be the only

persons able to remove tags and locks after work is complete.

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Designated Responsible Safety Officer (RSO) City Construction, Inc. has designated Dennis Fallon as our Responsible Safety Officer. The designation of an RSO is the most critical part of preparing ourselves to succeed or fail with the establishment and maintenance of our company safety program. The designated RSO is the glue that holds the many aspects of your program together. The key critical ingredients considered in making this decision were: Willingness - the person chosen must indicate a genuine interest and desire to do this work. Knowledge - College degrees in Safety and/or experience in the field are necessary for a full time safety program. Money - A budget needs to be established for this program to, at a minimum, include the following:

• Reference material - software, books, etc. • Designated person attending seminars • Safety committee meetings

The total cost/savings benefit ratio is arrived at by estimating our fines, should OSHA inspect our business before we become prepared, and the plus or minus effect on your experience modifier. Accountability - The person to fulfill these tasks must be accountable only to the company CEO or President in all matters of

safety and health for these reasons: - This plainly demonstrates top management's commitment to the safety program. - Keeps top management in the loop and provides for guidance at all stages of the program. - Prevents creativity of the designated safety person from being thwarted or stifled by intermediate supervisors

who are unaware of the tremendous negative impact OSHA fines and increased workers' compensation premiums can have on the company's bottom line.

Responsibilities - Will be responsible for the administration and implementation of the Safety and Health Regulations as they

apply to City Construction, Inc... In addition, he/she will administer the company safety program and see that it is put into effect and administered as outlined below.

- Will review all accidents, including accidents involving property damage only, the extent of such review / investigation shall be reflective of the seriousness of the accident.

- Will see that all sub and trade contractors abide by their safety and health program and that any alleged violations be reviewed.

- Will maintain and update a set of basic safe work rules. These safety rules will be explained by the company RSO to the President and Supervisor(s) who, in turn, will discuss these with employees.

- Will conduct safety inspections, and review safety program - Will provide safety training for employees.

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- Will read, review and provide the President and Supervisor(s) with updated OSHA Safety Standards. - Will make necessary corrections in company policy and work procedures by advising of changes in OSHA rules

and regulations. - Through the purchasing section, will see that all vendors are advised of the company safety and health

programs as they apply to the vendor and supplier personnel entering the job site. In addition, all purchase orders will require compliance with OSHA Act.

- Will meet regularly with supervisors/management to review safety procedures on the job, and, in general, check on the supervision's compliance with the company safety and health program.

Responsibilities President's Responsibilities - Read and review the OSHA Safety Standards and become knowledgeable of federal, state and local standards. - Responsible to see that a study is made of the work area(s) to determine the exposure to accidents, which may

develop. Particular attention will be given to the protection of the public and to fire prevention facilities. - You should be safety oriented when walking through work areas. Report to the RSO all unsafe acts and

conditions either of your company's or sub or trade contractor's personnel. - Review all accident reports. Supervisor's Responsibilities - The Supervisor is responsible for the implementation of the company safety and health program. - Make available all necessary personal protective equipment, job safety materials, and First Aid equipment. - Instruct the employees that safe practices are to be followed and safe conditions maintained throughout the job. - Inform the Lead person that they are not to require nor permit their workers to take chances they would rather

instruct the workers in proper and safe procedures. - Require all contractors and their prime subcontractors to adhere to all safety regulations. The Supervisor will

report any unsafe conditions on contractor portions of the work to the RSO. - Review all accidents with employee and see that corrective action is taken immediately. - Be familiar with the laws pertaining to safety and their basic requirements. - Investigate all accidents. File a complete accident report with the RSO and correct the causes immediately. Use

OSHA Form 301 or its equivalent. - Be familiar with the laws pertaining to safety and their basic requirements. Employee Responsibilities

- Work according to good safety practices as posted, instructed and discussed.

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- Refrain from any unsafe act that might endanger himself/herself or his/her fellow workers. - Use all safety devices provided for his/her protection. - Immediately report any unsafe situation or acts to his/her supervisor or safety personnel. - In the event of an injury, report to the designated area for First Aid treatment. In all cases, the employee and

Supervisor will report and/or record all accidents. - Maintain a clean and safe work area. - Be a safe worker, off the job, as well as on.

Employee Compliance & Accident Free Workplace City Construction, Inc. promotes employee compliance with the company HSP by rewarding employees who avoid work-related injuries and illnesses by working safely, and by submitting suggestions to management that will reduce our injury and illness rates. However, under no circumstances should any employee "not" report a legitimate work-related injury or illness. Timely and accurate reporting of injuries and illnesses is absolutely critical to an effective safety program. Employees who fail to comply with the safety requirements described in our company's HSP will be subject to the company’s disciplinary action policy.

Disciplinary Policy The disciplinary system does not exist primarily to punish employees. Its purpose should be to control the work environment so that workers are protected and accidents are prevented. A disciplinary system helps ensure workplace safety and health by letting the City Construction, Inc.'s employees know what is expected of them. It provides workers with opportunities to correct their behavior before an accident happens. A disciplinary system is one of the keys to successfully implementing the Company's safety and health program. It ensures that the Company's rules and safe working practices are taken seriously by employees and are actually followed. It lets employees know how City Construction, Inc. expects them to operate in relation to the goals of the Company's safety and health program. And it lays out the actions the Company will take if individuals do not meet the Company's expectations. The employee's supervisor and all members of management are responsible for the enforcement of this disciplinary program. A disciplinary system cannot work in a vacuum. Before the Company can hold employees accountable for their actions, the Company first needs to establish its safety and health policy and disciplinary rules. Policy Statement Employees need to know the Company's position on safety and health and what the Company expects of them. They need a clear understanding of the rules and the consequences of breaking those rules. This is true in all areas of work, but it is especially important for worker safety and health. As part of the policy statement, and in the employee safety handbook, the Company has a written statement setting forth the Company's disciplinary policy. Company managers and supervisors will always be on the lookout for safety violations and will conscientiously and vigorously enforce the Company's commitment to safety.

Employee Information and Training

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It is important that employees understand the system and have a reference to turn to if they have any questions. Therefore, in addition to issuing a written statement of the Company's disciplinary policy, the Company has drawn up a list of what it considers major violations of Company policy and less serious violations. This list specifies the disciplinary actions that will be taken for first, second, or repeated offenses. This list is not all-inclusive other types of violations can result in specific levels of disciplinary action relative to the seriousness of the violation and entirely at the Company's discretion. The list for immediate termination and grounds for immediate discharge are:

- Drinking alcohol, and/or drug abuse prior to or during working hours - Fighting, provoking or engaging in an act of violence against another person on Company property - Theft - Willful damage to property - Failure to wear Personal Protective Equipment (eye protection, hearing protection, safety helmets, etc.). - Not using safety harnesses and lanyards when there is a potential for falling - Removing and/or making inoperative safety guards on tools and equipment - Tampering with machine safeguards or removing machine tags or locks - Removing barriers and/or guardrails and not replacing them - Failure to follow recognized industry practices - Failure to follow rules regarding the use of company equipment or materials - Major traffic violations while using a company vehicle - Engaging in dangerous horseplay - Failure to notify the Company of a hazardous situation and - Other major violations of company rules or policies

General Offences requiring a warning and can lead to termination:

- Minor traffic violations while using Company vehicles - Creating unsafe or unsanitary conditions or poor housekeeping habits - Threatening an act of violence against another person while on company property - Misrepresentation of facts - Unauthorized use of Company property - Excessive tardiest and late to work - Disrespect and/or insubordination to authority - Other violations of Company Policy and rules

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Training Training can reduce the need for disciplinary action. The Company shall instruct employees in the importance of workplace safety and health, the need to develop safety habits, the Company's operations, safe work practices, and the hazards they control, and the standards of behavior that the Company expects. The Company's employees must understand the disciplinary system and the consequences of any deliberate, unacceptable behavior. Supervision Supervision includes both training and corrective action. Ongoing monitoring of the Company's employees' work and safety habits gives the Company's supervisors the opportunity to correct any problems before serious situations develop. In most cases, effective supervision means correcting a problem before issuing any punishment. Where the relationship between employees and their supervisors is open and interactive, problems are discussed and solutions are mutually agreed upon. This type of relationship fosters a work environment where the need for disciplinary action is reduced. When such action is needed, the parties are more likely to perceive it as corrective then punitive. Employee Involvement Employees are encouraged to help informally in the enforcement of rules and practices. The intent here is not to turn employees into spies and informers, but to encourage them to be their "brother's keeper" and to watch out for the safety and health of their colleagues. Many employers successfully have encouraged an atmosphere -- a company "culture" where employees readily speak up when they see an easily corrected problem, for example, a coworker who needs reminding to put on safety goggles. The Company's employees deserve the opportunity to correct their own behavior problems. An effective disciplinary system is a two-way process. Once a problem is spotted, discuss it with the employee, who should be given at least one or two opportunities to change the behavior or correct the problem. Only after these discussions (and possibly some retraining) should disciplinary action is taken. Appropriate Control Measures Disciplinary actions need to be proportionate to the seriousness of the offense and the frequency of its occurrence. It is certainly inappropriate to fire someone for occasional tardiness. It is equally inappropriate to issue only oral warnings to an employee who repeatedly removes a machine guard. Disciplinary procedures should not be instituted without explanation. The Company will provide feedback to the employee on what behavior is unacceptable, why the corrective action is necessary, and how the employee can prevent future violations and disciplinary action. In addition, take time to recognize an employee who improves or corrects his/her behavior. Consistent Enforcement Workers must realize that safe work practices are a requirement of employment and that unsafe practices will not be tolerated. It is necessary, therefore, that the employer has a disciplinary system that is implemented fairly and consistently.

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If the Company's disciplinary system is to work well and be accepted by the Company's workforce, the system applies equally to everyone. This includes subjecting managers and supervisors to similar rules and similar or even more stringent disciplinary procedures. For minor violations, supervisors shall meet with the employee to discuss the infraction and inform the employee of the rule or procedure that was violated AND describe the corrective action needed to remedy the situation. Documentation One key to ensuring fairness and consistency in a disciplinary system is keeping good records. It is in the best interest of both the Company and the employee to have written rules and disciplinary procedures. It is just as important to document instances of good or poor safety and health behavior, including discussions with the employee, and to place relevant information in the employee's personnel file. Documentation serves a variety of purposes. It helps the Company to track the development of a problem, corrective actions, and the impact of measures taken. It provides information so the Company can keep employees informed of problems that need correction. When the Company is evaluating the managerial and supervisory skills of a supervisor, it provides a useful record of how they handled problems. If warnings, retraining, and other corrective actions fail to achieve the desired effect, and if the Company decides to discharge an employee, then documentation becomes even more critical. Conversely, the Company will conduct an annual clearing of the personnel files of employees whose good overall safety records are marred by minor warnings.

Safety & Health Training City Construction, Inc. is committed to instructing all employees in safe and healthy work practices. The Company will provide training to each employee with regard to general, acceptable, safety procedures and to any hazards or safety procedures that are specific to that employee's work situation. Training can take many forms and is synonymous with education and can be attained in a number of ways. Company Safety Rules: Employees should read the rules and understand them. The issuance of these rules should be logged and signed receipts should be kept on file. Each new employee, as he arrives on the job, should be approached in the same manner. Periodic Safety Talks the company should attempt to hold a safety talk with their employees on a weekly or at least monthly basis. The talk may consist merely of restating the company safety rules or warning of dangerous conditions which exist. A particular subject may be covered, such as lockout tagout, confined space, or fire prevention. Changed Conditions -When any of the job operation changes or when new hazardous materials are brought into the workplace, employees should be made aware of new or added potential dangerous situations that might occur and the proper action employees can take to maintain a safe workplace.

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Safety Equipment -Employees should not simply be issued protective equipment. They should be instructed as to its proper and safe use. Consistency/Redundancy -The employer must consistently and routinely entertain the concept of safety training. Once is not enough. At the orientation meeting of new employees, on through the follow-up weekly/monthly safety talks, the central theme must be to dwell on employees not committing unsafe acts. Management Follow-Up -Management must not be content with advising employees on unsafe practices. A follow-up of employee actions must be made. The Supervisor(s) must be instructed to watch for employees committing unsafe acts. Employees should be reprimanded when found doing unsafe acts. (See disciplinary policy) Documentation -All actions taken by Management as it relates to Safety Training/Education should be documented. Documentation of good faith efforts in meeting the training requirements can be invaluable in defending a lawsuit that results from an injury due to an unsafe act by an employee. Also, documentation substantiates your commitment to and compliance with the OSHA Training Requirements. Individual/Group Instruction -Safety Education can be aimed at a group such as at a weekly/monthly safety talk or at an individual as in a case where the employee is being given instruction on use of a new tool, etc., by the Supervisor. Whichever the case may be, it should be documented. Safety training must be ongoing. It must be given to all employees and members of management. Documentation of instruction and other forms of safety awareness techniques must be made. Never assume everyone knows the safest way of performing his or her task. Workers are trained by experienced personnel for a minimum of 8 hours, or until management is convinced that the new employee can perform safely and effectively. Safety observations are conducted on each employee on a regular basis. The Company provides training:

- When the program is first established; - To all new employees; - To all employees given new job assignments for which training has not previously been received; - Whenever new substances, processes, procedures or equipment are introduced to the workplace and

represent a new hazard; - Whenever the employer is made aware of a new or previously unrecognized hazard; and - For supervisors to familiarize them with the safety and health hazards to which employees under their

immediate direction and control may be exposed. Safety Training Topics We train our workers on the following checked training subjects. Other training may be conducted depending on hazards present in the workplace.

- The Company's Code of Safe Practices. - Confined spaces. - Safe practices for operating any equipment.

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- Good housekeeping, fire prevention, safe practices for operating any construction equipment. - Safe procedures for cleaning, repairing, servicing and adjusting equipment and machinery. - Safe access to working areas. - Protection from falls. - Electrical hazards, including working around high voltage lines. - Crane operations. - Trenching and excavation work. - Proper use of powered tools. - Guarding of belts and pulleys, gears and sprockets, and conveyor nip points. - Machine, machine parts, and prime movers guarding. - Lock -out/tag-out procedures. - Materials handling. - Fall protection from elevated locations. - Use of elevated platforms, including condors and scissor lifts. - Driver safety. - Slips, falls, and back injuries. - Ergonomic hazards, including proper lifting techniques and working on ladders or in a stooped posture for

prolonged periods at one time. - Personal protective equipment. - Respiratory Equipment. - Hearing conservation - Hazardous chemical exposures. - Hazard communication. - Physical hazards, such as heat/cold stress, noise, and ionizing and non-ionizing radiation. - Blood borne pathogens and other biological hazards. - Fire extinguisher use. - Ladder Safety - Scaffolding

Safety Training Meetings City Construction, Inc. has safety meetings throughout the year. The purpose of these meetings is to convey information, answer employee questions and meet OSHA requirements. The format of most meetings will be to review, in language understandable to every employee, the content of the injury prevention program, special work site hazards, serious concealed dangers, and Safety Data sheets. Whenever a new practice or procedure is introduced into the workplace, it will be thoroughly reviewed for safety. A sign-up sheet will be passed around each meeting. Employee attendance is mandatory and is compensable unless part of an official state approved training program or pre-employment requirement. City Construction, Inc. also provides tailgate safety meetings on a regular basis.

Client Safety Procedures

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City Construction, Inc. contracts with many different clients. If any of these clients have additional safety regulations, all employees must adhere to these regulations. Supervisors are required to relay these additional regulations to affected employees.

Employee Training Documentation City Construction, Inc. maintains documentation of safety and health training for each employee, including employee name or other identifier, training dates, type(s) of training, and training providers. Employee training records are maintained in the office of City Construction, Inc.

Employee Communication Occupational safety and health matters will be promptly communicated with employees. This will be done by: SAFETY TRAINING MEETINGS: After the training session, management will communicate with employees on safe work practices and review other safety related information. BULLETIN BOARDS: A safety bulletin board will be located in the shop area. The required OSHA poster and the company’s safety policy will be permanently posted. Other safety related items shall be posted when they become available. TAILGATE TALKS: Supervisor’s will talk about safe work practices concerning the particular construction at the jobsite. Hazard Identification City Construction, Inc. contracts with many different clients and jobsites. Each jobsite supervisor will check with the client and or the client’s safety professional to identify any workplace hazards that may exist. Supervisors will communicate the hazard with all affected employees and provide the necessary safeguards. When an imminent hazard exists at the jobsite which cannot be immediately abated without endangering employee(s) and or property, the Company will remove all exposed personnel from the area except those necessary to correct the existing condition. Employees necessary to correct the hazardous condition shall be provided the necessary safeguards.

Accident Investigation It is the policy of City Construction, Inc. that all work related accidents, injuries, illnesses and near-misses are to be reviewed to identify probable causes and are used to develop specific management actions for the prevention of future accidents. Dennis Fallon, RSO, will investigate the accident or assigned one of the supervisors’ to conduct an

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investigation. While all accidents should be investigated, including accidents involving property damage only, the extent of such investigation shall be reflective of the seriousness of the accident. If an accident warrants an investigation it will be documented using the Accident Investigation Report Form (DHHS SB3210S). All information pertaining to this accident shall be put in a single folder with the accident report and any other evidence including witness statements and interviews, and filed in the RSO’s office until the accident investigation concludes. While conducting accident investigations, particular attention will be given to suggesting ways to prevent future occurrences of the events which caused the accident and the corrective action to be taken. Additional manpower, equipment, and records will be supplied by City Construction Inc. if needed in the accident investigation. A satisfactory accident report will answer the following questions: 1. What happened? The investigation report should begin by describing the accident, the injury sustained, the eyewitnesses, the date, time and location of the incident and the date and time of the report. Remember: who, what, when, where and how are the questions that the report must answer. 2. Why did the accident occur? The ultimate cause of the accident may not be known for several days after all the data are analyzed. However, if an obvious cause suggests itself, include your conclusions as a hypothesis at the time you give your information to the person in charge of the investigation. 3. What should be done? Once a report determines the cause of the accident, it should suggest a method for avoiding future accidents of a similar character. This is a decision by the Responsible Safety Officer and the supervisor on the project, as well as top management. Once a solution has been adopted, it is everyone's responsibility to implement it. 4. What has been done? A follow up report will be issued after a reasonable amount of time to determine if the suggested solution was implemented, and if so, whether the likelihood of accident has been reduced. Records Initial Identification/Assessment of Evidence Initial identification of evidence immediately following the incident could include a listing of people, equipment, and materials involved and a recording of environmental factors such as weather, illumination, temperature, noise, ventilation, etc.

Collection/Preservation and Security of Evidence Evidence such as people, positions of equipment, parts, and papers must be preserved, secured and collected through notes, photographs, witness statements, flagging, and impoundment of documents and equipment. All shall be dated.

Witness Interviews and Statements

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Witness interviews and statements must be collected. Locating witnesses, ensuring unbiased testimony, obtaining appropriate interview locations, 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 investigation report consists of findings with critical factors, evidence, corrective actions, responsible parties, and timelines for corrective action completion.

Results of incident investigations are communicated to employees via the Incident Notice form.

City Construction, Inc. maintains records of employee training and accident investigation.

Accident Reporting Within eight (8) hours after the death of any employee from a work-related incident or the in-patient hospitalization of three or more employees as a result of a work-related incident, you must orally report the fatality/multiple hospitalization by telephone or in person to the Area Office of the Occupational Safety and Health Administration (OSHA), U.S. Department of Labor, that is nearest to the site of the incident. You may also use the OSHA toll-free central telephone number, 1-800-321-OSHA (1-800-321-6742). A full investigation with copies to governmental authorities will be required. Also, within 24 hours the host facility / client must be notified by phone call and followed up with written documentation. In less serious cases, the investigation report must be presented to the company for disclosure to its insurance carrier and for remedial action at the worksite.

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SUPERVISOR’S INVESTIGATION OF EMPLOYEE ACCIDENT/INJURY

This report will be provided to the Workers’ Compensation Representative/HR within 24 hours of notification of the accident/injury (Circle) Employee: Date of Injury: Time of Injury: AM PM Dept/Div: Supervisor: Phone No: Job Title: Date Notified of Accident: Date of Investigation: (Circle) (Circle) Shift: A B C Start Time of Work Day: AM PM Medical Treatment Provided Y N Witnesses (attach statement for each) Name: Title: Phone Number: Name: Title: Phone Number: Name: Title: Phone Number: Describe the events immediately prior to the injury and the circumstances causing the employees’ injury: Personal Protection Required (PPE): Foot Prot. Face/Eye Prot. Fall Prot. Respiratory Prot. Hand Prot.

Head Prot. Lifting Assistance Device Apron/Chaps Back Belt Other:

None Was PPE being used? Yes No Was injury caused by failure of the device(s) Yes No Object, equipment, or substance, which caused injury:

Choose factor (s), which directly or indirectly caused the accident to occur:

Lack of Skill/Abilities Physical Weakness/Disability Carelessness Unsafe Act

Failure to Use PPE Failure to Follow Procedures Unsafe Condition Undetermined

Sudden Distraction Fatigue Client Assault Client Caused Other-Describe:

Other Factors: Poor Workplace Design Broken/Damaged Equipment/Object

Inadequate Procedures Inadequate Resources Actions by Another Person/Employee

Other-Describe: Are your findings consistent with employee’s description? Yes No Describe accident if different from employee’s description: Describe actions taken to prevent reoccurrence: Make recommendations to the Safety and Health Director/Committee. Provide additional attachments as required. Supervisor’s Signature: Title: Date: Dept. Head/Area Administrator Initials: Date: Attachments: Witness Statements Dis tribution: DHHS SB3210S (06/30/09)

Accident Investigation Form

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OSHA Records Required Copies of required accident investigations and certification of employee safety training shall be maintained by the Responsible Safety Officer. City Construction, Inc. keeps records of its employee fatalities, injuries, and illnesses that:

- Is work-related; and - Is a new case; and - Meets one or more of the general recording criteria of Title 8 Sections 14300-14300.48.

Each recordable injury or illness is entered on OSHA 300 Log of Work-Related Injuries and illnesses, OSHA 301 Form Injury and Illness Incident Report, and a separate, confidential list of privacy-concern cases, if any, within (7) calendar days calendar days of receiving information that a recordable injury or illness has occurred. The RSO keeps these records up to date. If there is a privacy-concern case, we have the option to not enter the employee's name on OSHA 300 Log of Work-Related Injuries and illnesses. Instead, the text "Privacy Case" is entered in the space normally used for the employee's name. This will protect the privacy of the injured or ill employee when another employee, a former employee, or an authorized employee representative is provided access to the OSHA 300 Log. The company will keep a separate, confidential list of the case numbers and employee names for; your privacy concern cases so that we can update the cases and provide the information to the government if asked to do so. At the end of each calendar year, RSO performs the following steps: 1. Reviews OSHA 300 Log of Work-Related Injuries and illnesses to verify that the entries are complete and

accurate, 2. Corrects any deficiencies identified in the entries, 3. Creates an annual summary of injuries and illnesses recorded on OSHA 300 Log of Work Related Injuries and

Illnesses 4. Ensures that Dennis Fallon, who is the RSO and "President" of the company certifies that he reasonably

believes, based on his/her knowledge of the process by which the information was recorded, that the annual summary is correct and complete, and

5. Posts OSHA 300-A Summary of Work-Related Injuries and illnesses on the Main Office bulletin board from February 1 of the year following the year covered by the records and kept in place until April 30 for a total of three (3) months.

All employees, former employees, their personal representatives, and their authorized employee representatives have a right to access our regulatory-required injury and illness records, with the following limitations:

1. We are allowed to give the requester a copy of OSHA 300 Log of Work-Related Injuries and Illnesses by the end of the next business day.

2. We may choose to not record the employee's name on OSHA 300 Log of Work-Related Injuries and Illnesses in order to protect the privacy of injured and ill employees in certain privacy-concern cases.

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3. We are allowed to give an employee, former employee, or personal representative a copy of OSHA 301

Form Injury and Illness Incident Report by End of the next business day. A personal representative is: - Any person that the employee or former employee designates as such, in writing; or - The legal representative of a deceased or legally incapacitated employee or former employee.

4. We are allowed to give authorized employee representatives under a collective bargaining agreement a copy of OSHA 301Form Injury and Illness Incident Report within seven (7) calendar days.

5. An authorized employee representative is an authorized collective bargaining agent of employees. The authorized employee representative will be provided the OSHA 301 Incident Report section titled 'Tell us about the case.' The company will remove all other information from the copy of the OSHA 301 Incident Report or the equivalent substitute form that is given to the authorized employee representative.

6. While the first copy is free, we may charge a reasonable amount for retrieving and copying additional copies.

7. Employees also have access to OSHA 300-A Summary of Work-Related Injuries and Illnesses, which is posted on the Main Office bulletin board from February 1 of the year following the year covered by the records and kept in place until April 30 for a total of three (3) months.

City Construction, Inc. does not discriminate against employees who request access to any records or otherwise exercise any rights afforded by the OSH Act. The RSO saves the following records for (5) years following the end of the calendar year that these records cover:

- OSHA 300 Log, the privacy case list (if one exists), - the annual summary, and - the OSHA 301 Incident Report forms

During the storage period, The RSO updates OSHA 300 Log of Work-Related Injuries and Illnesses to include any newly discovered recordable injuries or illnesses and any changes that have occurred in the classification of previously recorded injuries and illnesses. If our company changes ownership, Dennis Fallon and the President are responsible for transferring the records to the new owner.

Injury Management

a) A worker who is injured at work must immediately report the incident to their supervisor

b) The supervisor is required to:

• Obtain immediate medical attention for the worker who is injured or ill • Arrange for transportation to get medical care, if needed

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• Follow company requirements for reporting work-related injuries and illnesses • Complete an incident investigation report • Maintain contact with the worker through the recovery period. • The employer and worker will work together to plan RTW

c) The worker is responsible for following medical restrictions on the job

d) Following the worker’s return to work, the supervisor or the RTW coordinator monitors the worker’s

progress, to help resolve any difficulties and ensure that restrictions are carefully followed

e) The worker must immediately report any difficulties performing assigned work, at which point, the

supervisor and worker will work to address the problem.

Safety Equipment Proper safety equipment is necessary for your protection. The Company provides the best protective equipment it is possible to obtain. Use all safeguards, safety appliances, or devices furnished for your protection and comply with all regulations that may concern or affect your safety. Wear your gear properly --all snaps and straps fastened, cuffs not cut or rolled. Your supervisor will advise you as to what protective equipment is required for your job. Certain jobs require standard safety apparel and appliances for the protection of the employee. Your supervisor is aware of the requirements and will furnish you with the necessary approved protective appliances. These items shall be worn and effectively maintained as a condition of your continued employment and part of our mutual obligation to comply with the Occupational Safety and Health Act. Safety goggles, glasses and face shields shall correspond to the degree of hazard, i.e., chemical splashes, welding flashes, impact hazard, dust, etc. Do not alter or replace an approved appliance without permission from your supervisor. Rubber gloves and rubber aprons shall be worn when working with acids, caustics or other corrosive materials. Specified footwear must be worn. No jewelry shall be worn around power equipment. Hearing protection appliances (approved muffs or plugs) shall be worn by all employees working within any area identified as having excess noise levels. Your supervisor will instruct you in the proper use of the appliance.

Protective Equipment I Clothing Proper safety equipment is necessary for your protection. The Company provides the best protective equipment it is possible to obtain. Use all safeguards, safety appliances, or devices furnished for your protection and carry out all regulations that may concern or affect your safety. Wear your gear properly all snaps and traps fastened, cuffs not cut or rolled. Your supervisor will advise you as to what protective equipment is required for your job.

Smoking & Fire Safety Fire is one of the worst enemies of any facility. Learn the location of the fire extinguishers. Learn how to

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Use them. You can help prevent fires by observing the smoking rules: - Smoking is not allowed on the site, except in designated areas. - Smoking is not permitted in restrooms. - If you are not sure about where you may smoke, ask the supervisor.

Code of Safe Practices General Safe Practices

1. All persons shall follow these safe practices rules, render every possible aid to safe operations, and report all unsafe conditions or practices to managers or supervisors.

2. Managers and supervisors shall insist on employee's observing and obeying every rule, regulation, and order as is necessary to the safe conduct of the work, and shall take such action as is necessary to obtain observance.

3. All employees shall be given frequent injury and illness prevention instructions. 4. Anyone known to be under the influence of drugs or intoxicating substances which impair the employee's

ability to safely perform the assigned duties shall not be allowed on the job while in that condition 5. Running, jumping, horseplay, scuffling, and other acts which tend to have an adverse influence on the

safety or wellbeing of the employees shall be prohibited. 6. Work shall be well planned and supervised to prevent injuries in the handling of materials and in working

together with equipment. 7. Employees shall be instructed to ensure that all guards and other protective devices are in proper places

and adjusted, and shall report deficiencies promptly to the manager or supervisor. 8. Employees shall not enter underground vaults, chambers, tanks, manholes, silos, or other similar confined

places that receive little ventilation, unless it has been determined that it is safe to enter. 9. Employees shall not handle or tamper with any electrical equipment, machinery, or air or water lines in a

manner not within the scope of their duties, unless they have received instructions from their supervisor. Respect electricity under all circumstances. Never use electrical equipment in areas of excessive moisture unless all safeguards have been taken. Electric power tools are grounded thru approved cords, including extension, for your safety. Never remove or alter polarized cords or plugs.

10. When lifting heavy objects, the large muscles of the leg instead of the smaller muscles of the back shall be used. Learn and practice the proper way to lift or carry material or any object. Do not operate any type of powered material handling or hoisting equipment unless authorized. Get help in handling heavy or bulky loads.

11. Stay clear of heavy earthmoving equipment. Remain aware of warning devices such as bells, horns or whistles. Hard hats are mandatory; always wear one on any construction job. Use other protective gear as recommended when exposed to unusual hazards. Never attempt an operation with which you are not familiar, ask first for specific instructions. Wear suitable work clothes at all times, heavy soled shoes protect against puncture injury.

12. Basic first aid is of value in the event of injury. Know how, it may save a fellow workman from death. Never attempt to move a person who may possibly suffer from an injured spine or other internal injury unless proper methods are completely understood. All injuries shall be reported promptly to the supervisor or manager so that arrangements can be made for medical or first aid treatment.

13. Accident Prevention: All persons must abide by Construction Safety Orders; General Industry Safety Orders and Company rules. Posters and other safety material are displayed for the benefit of employees, read and abide by these suggestions. Give every possible aid in the event of injury.

14. Accident Reporting: Report all personal injuries to a superior immediately. Obtain authorization for any medical attention off the job. Medical release is necessary before returning to work.

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15. Job Site: Keep work areas free of debris, good housekeeping is essential. Remove or correct any hazards. Never work or pass under suspended loads or equipment.

16. Work Habits: Assist other trades when necessary to maintain safe operations. Never place yourself, or allow others to work in a dangerous position. Use the right tool or equipment for all work. Use of any alcoholic beverage is strictly prohibited on the job. Don't be party to horseplay, pranks can be fatal. Construction sites offer unusual hazards, walk and work with all due respect for them.

17. Hand Tools: Always Use the proper tool and maintain them in good condition at all times. Loose or broken handles, mushroom heads, dull blades, improper size or type of tool should never be used.

18. Power Tools: Power activated tools must only be used by licensed personnel. Know the proper method of using, a skill saw; never block back the retractable guard it is for your protection. Never use a tool with which you are not fully experienced.

19. Protective Devices: Hand or guardrails, protective covers, toe-boards, ramps and safety devices installed on various tools are for your safety. Do not tamper with remove or damage these protective measures. Replace, correct or report any unsafe guard or device.

20. Transportation: When transportation is necessary in other than a passenger vehicle, make sure vehicles are of the correct size and designed for intended use. The vehicles in use shall be maintained in safe working order. Ride in the cab do not ride in the bed of the truck. All loads must be legally secure and within the manufacturer's legal limits. All company vehicles capable of more than 10 mph will have seat belts installed. Only authorized employees are allowed to drive on company business and must carry a driver’s license for the class of vehicle they will be driving. Authorized drivers are not allowed to operate the vehicle while under the influence of alcohol, illegal drugs or certain medications. Reporting of traffic violations and/or vehicle accidents is required. Other requirements are not manipulating radios or other equipment which may cause distraction, not exceeding the posted speed limit and maintaining a safe distance between other vehicles

21. Seat Belts: We value the lives and safety of our employees. Because it is estimated that seat belts reduce the risk of dying in a motor vehicle crash by 45 percent, our company has adopted the following policy concerning employee seat belt usage. In addition to following all traffic regulations, all employees and their passengers are required to use a seat belt when traveling in any vehicle while in the course of conducting company business. The requirement applies to business travel in a vehicle owned by the company, in a rental vehicle and in a vehicle owned by an individual employee, regardless of whether the employee is compensated for the use of his/her vehicle. If an employee is provided a company-owned vehicle that is used in the course of his/her employment and is also available for that employee’s personal use, that employee, together with all passengers who occupy the vehicle at any time and for any purpose, whether business-related or personal, are required to use seat belts at all times the vehicle is in motion. The use of seat belts is to be considered a condition of employment with this company. Failure to abide by this stated policy will be considered a breach of that condition of employment and subject the person in violation to disciplinary action, including suspension and possible termination.

22. Cell Phone Usage: Company employees may not use a hand-held cell phone while operating a vehicle – whether the vehicle is in motion or stopped at a traffic light. This includes, but is not limited to, answering or making phone calls, engaging in phone conversations, and reading or responding to emails, instant messages, and text messages. If company employees need to use their phones, they must pull over safely to the side of the road or another safe location.

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23. Flammables, Solvents: Never use gasoline or other highly volatile liquids for cleaning purposes. Oxygen and acetylene cylinders can be dangerous, secure against rolling or tipping. Do not expose tanks or containers that may contain explosive vapor or liquid to open frame or spark.

Special Note: Non-compliance with these regulations will result in disciplinary action.

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Hazard Specific Code of Safe Practices General Work Environment

- All worksites clean and orderly. - Work surfaces kept dry or appropriate means taken to assure the surfaces are slip-resistant. - All spilled materials or liquids cleaned up immediately. - Combustible scrap, debris and waste stored safely and removed from the worksite promptly. - Accumulated combustible dust routinely removed from elevated surfaces, including the overhead structure

of buildings. - Combustible dust cleaned up with a vacuum system to prevent the dust going into suspension. - Metallic or conductive dust prevented from entering or accumulation on or around electrical enclosures or

equipment. - Covered metal waste cans used for oily and paint-soaked waste. - All oil and gas fired devices equipped with flame failure controls that will prevent flow of fuel if pilots or main

burners are not working. - Paint spray booths, dip tanks and the like cleaned regularly. - The minimum number of toilets and washing facilities provided. - All toilets and washing facilities clean and sanitary. - All work areas adequately illuminated. - Pits and floor openings covered or otherwise guarded.

Personal Protective Equipment & Clothing

- Protective goggles or face shields provided and worn where there is any danger of flying particles or corrosive materials.

- Approved safety glasses required to be worn at all times in areas where there is a risk of eye injuries such as punctures, abrasions, contusions or bums.

- Employees who need corrective lenses (glasses or contacts lenses) in working environments with harmful exposures, required to wear only approved safety glasses, protective goggles, or use other medically approved precautionary procedures.

- Protective gloves, aprons, shields, or other means provided against cuts, corrosive liquids and chemicals. - Hard hats provided and worn where danger of falling objects exists. - Hard hats inspected periodically for damage to the shell and suspension system. - Appropriate foot protection required where there is the risk of foot injuries from hot, corrosive, poisonous

substances, falling objects, crushing or penetrating actions. - Approved respirators provided for regular or emergency use where needed. - All protective equipment maintained in a sanitary condition and ready for use. - Have eye wash facilities and a quick drench shower within the work area where employees are exposed to

injurious corrosive materials. - Special equipment needed for electrical workers is available. - When lunches are eaten on the premises, they are eaten in areas where there is no exposure to toxic

materials or other health hazards. - Protection against the effects of occupational noise exposure provided when sound levels exceed those of

the OSHA noise standard. - If any irritant gets into an employee's eyes, call for medical assistance immediately and flush the eye out

with clean water.

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- Employee owned safely equipment is prohibited from being used at all times. Walkways

- Aisles and passageways kept clear. - Aisles and walkways marked as appropriate. - Wet surfaces covered with non-slip materials. - Holes in the floor, sidewalk or other walking surface repaired properly, covered or otherwise made safe. - There is safe clearance for walking in aisles where motorized or mechanical handling equipment is operating.

Spilled materials cleaned up immediately. - Materials or equipment stored in such a way that sharp projectiles will not interfere with the walkway. - Changes of direction or elevations readily identifiable. - Aisles or walkways that pass near moving or operating machinery, welding operations or similar operations

arranged so employees will not be subjected to potential hazards. - Adequate headroom provided for the entire length of any aisle or walkway. - Standard guardrails provided wherever aisle or walkway surfaces are elevated more than 30 inches above

any adjacent floor or the ground. - Bridges provided over conveyors and similar hazards.

Floor & Wall Openings

- Floor openings guarded by a cover, guardrail, or equivalent on all sides (except at entrance to stairways or ladders).

- Toe boards installed around the edges of permanent floor opening (where persons may pass below the opening).

- Skylight screens of such construction and mounting that they will withstand a load oat least 200 pounds. - The glass in windows, doors, glass walls that are subject to human impact, of sufficient thickness and type

for the condition of use. - Grates or similar type covers over floor openings such as floor drains, of such design that foot traffic or rolling

equipment will not be affected by the grate spacing. - Unused portions of service pits and pits not actually in use either covered or protected by guardrails or

equivalent. - Manhole covers, trench covers and similar covers, plus their supports, designed to carry a truck rear axle

load of at least 20,000 pounds when located in roadways and subject to vehicle traffic. - Floor or wall openings in fire resistive construction provided with doors or covers compatible with the fire

rating of the structure and provided with self-closing feature when appropriate. Stairs & Stairways

- Standard stair rails or handrails on all stairways having four or more risers. - All stairways at least 22 inches wide. - Stairs have at least a 6'6" overhead clearance. - Stairs angle no more than 50 and no less than 30 degrees. - Stairs of hollow-pan type treads and landings filled to noising level with solid material. - Step risers on stairs uniform from top to bottom, with no riser spacing greater than 7-1/2 inches. - Steps on stairs and stairways designed or provided with a surface that renders them slip resistant. - Stairway handrails located between 30 and 34 inches above the leading edge of stair treads. - Stairway handrails have a least 1-1/2 inches of clearance between the handrails and the wall or surface they

are mounted on. - Stairway handrails capable of withstanding a load of200 pounds, applied in any direction.

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- Where stairs or stairways exit directly into any area where vehicles may be operated, adequate barriers and warnings provided to prevent employees stepping into the path of traffic.

- Stairway landings have a dimension measured in the direction of travel, at least equal to width of the stairway. - The vertical distance between stairway landings limited to 12 feet or less. - Elevated Surfaces - Signs posted, when appropriate, showing the elevated surface load capacity. - Surfaces elevated more than 30 inches above the floor or ground provided with standard guardrails. - All elevated surfaces (beneath which people or machinery could be exposed to falling objects) provided with

standard 4-inch toe boards. - A permanent means of access and egress provided to elevated storage and work surfaces. - Required headroom provided where necessary. - Material on elevated surfaces piled, stacked or racked in a manner to prevent it from tipping, falling,

collapsing, rolling or spreading. - Dock boards or bridge plates used when transferring materials between docks and trucks or rail cars. - Exiting or Egress - All exits marked with an exit sign and illuminated by a reliable light source. - The directions to exits, when not immediately apparent, marked with visible signs. - Doors, passageways or stairways, that are neither exits nor access to exits and which could be mistaken for

exits, appropriately marked "NOT AN EXIT", "TO BASEMENT", "STOREROOM", and the like. - Exit signs provided with the word "EXIT" in lettering at least 5 inches high and the stroke of the lettering at

least 1/2 inch wide. - Exit doors side-hinged. - All exits kept free of obstructions. - At least two means of egress provided from elevated platforms, pits or rooms where the absence of a second

exit would increase the risk of injury from hot, poisonous, corrosive, suffocating, flammable, or explosive substances.

- There sufficient exits to permit prompt escape in case of emergency. - Special precautions taken to protect employees during construction and repair operations. - The number of exits from each floor oaf building, and the number of exits from the building itself, appropriate

for the building occupancy load. - Exit stairways which are required to be separated from other parts of a building enclosed by at least two hour

fire-resistive construction in buildings more than four stories in height, and not less than one-hour fire resistive construction elsewhere.

- Ramps are used as part of required exiting from a building, with the ramp slope limited to 1-foot vertical and 12 feet horizontal.

- Exiting will be through frameless glass doors, glass exit doors, storm doors, and such are the doors fully tempered and meet the safety requirements for human impact.

Exit Doors

- Doors that are required to serve as exits designed and constructed so that the way of exit travel is obvious and direct.

- Windows that could be mistaken for exit doors, made inaccessible by means of barriers or railings. - Exit doors open able from the direction of exit travel without the use of a key or any special knowledge or

effort, when the building is occupied. - A revolving, sliding or overhead door prohibited from serving as a required exit door. - Where panic hardware is installed on a required exit door, it will allow the door to open by applying a force of

15 pounds or less in the direction of the exit traffic. - Doors on cold storage rooms provided with an inside release mechanism that will release the latch and open

the door even if it’s padlocked or otherwise locked on the outside.

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- Exit doors open directly onto any street, alley or other area where vehicles may be operated, are adequate barriers and warnings provided to prevent employees stepping into the path of traffic.

- Doors that swing in both directions and are located between rooms where there is frequent traffic, provided with viewing panels in each door.

Portable Ladders

- All ladders maintained in good condition, joints between steps and side rails tight, all hardware and fittings securely attached, and moveable parts operating freely without binding or undue play.

- Non-slip safety feet provided on each ladder. - Non-slip safety feet provided on each metal or rung ladder. - Ladder rungs and steps free of grease and oil. - It is prohibited to place a ladder in front of doors opening toward the ladder except when the door is blocked

open, locked or guarded. - It is prohibited to place ladders on boxes, barrels, or other unstable bases to obtain additional height. - Employees instructed to face the ladder when ascending or descending. - Employees prohibited from using ladders that are broken, missing steps, rungs, or cleats, broken side rails

or other faulty equipment. - Employees instructed not to use the top 2 steps of ordinary stepladders as a step. - Portable rung ladders are used to gain access to elevated platforms, roofs, and the like does the ladder

always extend at least 3 feet above the elevated surface. - It is required that when portable rung or cleat type ladders are used the base is so placed that slipping will

not occur, or it is lashed or otherwise held in place. - Portable metal ladders legibly marked with signs reading "CAUTION" "Do Not Use around Electrical

Equipment" or equivalent wording. - Employees prohibited from using ladders as guys, braces, skids, gin poles, or for other than their intended

purposes. - Employees instructed to only adjust extension ladders while standing at a base (not while standing on the

ladder or from a position above the ladder). - Metal ladders inspected for damage. - The rungs of ladders uniformly spaced at 12 inches, center to center.

Hand Tools & Equipment

- All tools and equipment (both, company and employee-owned) used by employees at their workplace in good and safe condition.

- Hand tools such as chisels, punches, which develop mushroomed heads during use, reconditioned or replaced as necessary

- Broken or fractured handles on hammers, axes and similar equipment replaced promptly. - Worn or bent wrenches replaced regularly. - Appropriate handles used on files and similar tools. - Employees made aware of the hazards caused by faulty or improperly used hand tools. - Appropriate PPE – safety glasses face shields, and similar equipment used while using hand tools or

equipment that might produce flying materials or be subject to breakage. - Jacks checked periodically to assure they are in good operating condition. - Tool handles wedged tightly in the head offal tools. - Tool cutting edges kept sharp so the tool will move smoothly without binding or skipping. - Tools stored in dry, secure location where they won't be tampered with. - Eye and face protection used when driving hardened or tempered spuds or nails.

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Portable (Power Operated) Tools & Equipment

- All tools and equipment (both, company and employee-owned) used by employees at their workplace shall be in good and safe condition any tool that is not in compliance will be tagged “Out of Order” and removed from the worksite to the maintenance area.

- Grinders, saws, and similar equipment shall be provided with appropriate safety guards. - Power tools will be used with the correct shield, guard or attachment recommended by the manufacturer. - Portable circular saws equipped with guards above and below the base shoe. - Circular saw guards checked to assure they are not wedged up, thus leaving the lower portion of the blade

unguarded. - Rotating or moving parts of equipment guarded to prevent physical contact. - All cord-connected, electrically operated tools and equipment effectively grounded or of the approved double

insulated type. - Effective guards in place over belts, pulleys, chains, and sprockets, on equipment such as concrete mixers,

air compressors, and the like. - Portable fans provided with full guards or screens having openings 1/2 inch or less. - Hoisting equipment available and used for lifting heavy objects, and are hoist ratings and characteristics

appropriate for the task. - Ground-fault circuit interrupters provided on all temporary electrical 15 and 20 ampere circuits, used during

periods of construction. - Pneumatic and hydraulic hoses on power-operated tools checked regularly for deterioration or damage.

Abrasive Wheel Equipment Grinders

- The work rest used and kept adjusted to within 1/8 inch of the wheel. The adjustable tongue on the top side of the grinder used and kept adjusted to within 1/4 inch of the wheel.

- Side guards cover the spindle, nut, and flange and 75 percent of the wheel diameter. - Bench and pedestal grinders permanently mounted. - Goggles or face shields always worn when grinding. - The maximum RPM rating of each abrasive wheel compatible with the RPM rating of the grinder motor. - Fixed or permanently mounted grinders connected to their electrical supply system with metallic conduit or

other permanent wiring method. - Each grinder has an individual on and off control switch. - Each electrically operated grinder effectively grounded. - Before new abrasive wheels are mounted, they are visually inspected and ring tested. Dust collectors and

powered exhausts provided on grinders used in operations that produce large amounts of dust. - Splashguards mounted on grinders that use coolant, to prevent the coolant reaching employees. - Cleanliness maintained around grinder.

Powder Actuated Tools

- Employees who operate powder-actuated tools trained in their use and carry a valid operator's card. - The powder-actuated tools being used have written approval of the Division of Occupational Safety and

Health. - Each powder-actuated tool stored in its own locked container when not being used. - A sign at least 7" by 10" with bold type reading "POWDER-ACTUATED TOOL IN USE" Conspicuously posted

when the tool is being used. - Powder-actuated tools left unloaded until they are actually ready to be used. - Powder-actuated tools inspected for obstructions or defects each day before use.

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- Powder-actuated tools operators have and use appropriate personal protective equipment such as hard hats, safety goggles, safety shoes and ear protectors.

Machine Guarding

- There is a training program to instruct employees on safe methods of machine operation. - There is adequate supervision to ensure that employees are following safe machine operating procedures. - There is a regular program of safety inspection of machinery and equipment. - All machinery and equipment kept clean and properly maintained. - Sufficient clearance provided around and between machines to allow for safe operations, set up and

servicing, material handling and waste removal. - Equipment and machinery securely placed and anchored, when necessary to prevent tipping or other

movement that could result in personal injury. - There is a power shut-off switch within reach of the operator's position at each machine. - Electric power to each machine is locked out for maintenance, repair, or security. - The noncurrent-carrying metal parts of electrically operated machines bonded and grounded. - Foot-operated switches guarded or arranged to prevent accidental actuation by personnel or falling objects. - Manually operated valves and switches controlling the operation of equipment and machines clearly identified

and readily accessible. - All emergency stop buttons colored red. - All pulleys and belts that are within 7 feet of the floor or working level properly guarded. - All moving chains and gears properly guarded. - Splashguards mounted on machines that use coolant, to prevent the coolant from reaching employees. - Methods provided to protect the operator and other employees in the machine area from hazards created at

the point of operation, ingoing nip points, rotating parts, flying chips, and sparks. - Machinery guards secure and so arranged that they do not offer a hazard in their use. - Special hand tools are used for placing and removing material to protect the operator's hands. - Revolving drums, barrels, and containers required to be guarded by an enclosure that is interlocked with the

drive mechanism, so that revolution cannot occur unless the guard enclosure is in place, so guarded. - Arbors and mandrels have firm and secure bearings and are they free from play. - Provisions made to prevent machines from automatically starting when power is restored after a power failure

or shutdown. - Machines constructed so as to be free from excessive vibration when the largest size tool is mounted and

run at full speed. - Machinery is cleaned with compressed air, is air pressure controlled and personal protective equipment or

other safeguards used to protect operators and other workers from eye and body injury. - Fan blades protected with a guard having openings no larger than 112 inch, when operating within 7 feet of

the floor. - Saws used for ripping, equipped with anti-kickback devices and spreaders. - Radial arm saws so arranged that the cutting head will gently return to the back of the table when released.

Electrical

- Workplace electricians familiar with the OSHA Electrical Safety Regulations. - Specify compliance with OSHA for all contract electrical work. - All employees required to report as soon as practicable any obvious hazard to life or property observed in

connection with electrical equipment or lines. - Employees instructed to make preliminary inspections and/or appropriate tests to determine what conditions

exist before starting work on electrical equipment or lines. - When electrical equipment or lines are to be serviced, maintained or adjusted, necessary switches are

opened, locked-out and tagged whenever possible.

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- Portable electrical tools and equipment grounded or of the double insulated type. - Electrical appliances such as vacuum cleaners, polishers, vending machines grounded. - Extension cords being used have a grounding conductor. - Multiple plug adapters prohibited. - Ground-fault circuit interrupters installed on each temporary 15 or 20 ampere, 120 volt AC circuit at locations

where construction, demolition, modifications, alterations or excavations are being performed. - All temporary circuits protected by suitable disconnecting switches or plug connectors at the junction with

permanent wiring. - Exposed wiring and cords with frayed or deteriorated insulation is repaired or replaced promptly. - Flexible cords and cables free of splices or taps. - Clamps or other securing means provided on flexible cords or cables at plugs, receptacles, tools, and

equipment and is the cord jacket securely held in place. - All cord cable and raceway connections intact and secure. - In wet or damp locations, electrical tools and equipment are appropriate for the use or location or otherwise

protected. - The location of electrical power lines and cables (overhead, underground, under floor, other side of walls) is

determined before digging; drilling or similar work is begun. - Metal measuring tapes, ropes, hand lines or similar devices with metallic thread woven into the fabric

prohibited where they could come in contact with energized parts of equipment or circuit conductors. - The use of metal ladders is prohibited in area where the ladder or the person using the ladder could come in

contact with energized parts of equipment, fixtures or circuit conductors. - All disconnecting switches and circuit breakers labeled to indicate their use or equipment served. - Disconnecting means always opened before fuses are replaced. - All interior wiring systems include provisions for grounding metal parts of electrical raceways, equipment and

enclosures. - All electrical raceways and enclosures securely fastened in place. - All energized parts of electrical circuits and equipment guarded against accidental contact by approved

cabinets or enclosures. - Sufficient access and working space is provided and maintained about all electrical equipment to permit

ready and safe operations and maintenance. - All unused openings (including conduit knockouts) in electrical enclosures and fittings closed with appropriate

covers, plugs or plates. - Electrical enclosures such as switches, receptacles, junction boxes, etc., provided with tight-fitting covers or

plates. - Disconnecting switches for electrical motors in excess of two horsepower, capable of opening the circuit

when the motor is in a stalled condition, without exploding. (Switches must be horsepower rated equal to or in excess of the motor horsepower rating).

- Low voltage protection is provided in the control device of motors driving machines or equipment, which could cause probably injury from inadvertent starting.

- Each motor disconnecting switch or circuit breaker is located within sight of the motor control device. - Each motor located within sight obits controller or the controller disconnecting means is capable of being

locked in the open position or is a separate disconnecting means installed in the circuit within sight of the motor.

- The controller for each motor is in excess of two horsepower, rated in horsepower equal to or in excess of the rating of the motor is serves.

- Employees who regularly work on or around energized electrical equipment or lines are instructed in the cardiopulmonary resuscitation (CPR) methods.

- Are employees prohibited from working alone on energized lines or equipment over 600 volts - All authorized employee engaging in electrical activities will follow the written procedure and the guidelines

set forth in the Company's Electrical Safety and Ground Fault Protection Program.

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Lockout Tagout: Control of Hazardous Energy

- Lockout is the preferred method of isolating machines or equipment from energy sources. - Lockout Tagout will be used to ensure that the machine or equipment is stopped, isolated from all potentially

hazardous energy sources, and locked out before employees perform any servicing or maintenance where the unexpected energization or start-up of the machine or equipment or release of stored energy could cause injury such as minor to serious shock, burns (chemical or thermal), cuts, or abrasions.

- All employees are required to comply with the restrictions and limitations imposed upon them during the use of lockout.

- The authorized employees are required to perform the lockout in accordance with this procedure. Servicing is to be done only by trained, authorized employees.

- Each new or transferred affected employee and other employees whose work operations are or may be in the area shall be instructed in the purpose and use of the lockout or tagout procedures.

- All employees, upon observing a machine or piece of equipment which is locked out to perform servicing or maintenance, shall not attempt to start, energize, or use the machine or equipment.

- Contractors are required to utilize this company's procedure except when the contractor can demonstrate that their current lockout procedure affords the same level of safety as the Company's procedure.

- All equipment shall be locked out or tagged out to protect against accidental or inadvertent operations when such operations could cause injury to personnel.

- Do not attempt to operate any switch, valve, or other energy-isolating device where it is locked or tagged out. - In the event a piece of equipment is to be isolated for a period of time exceeding one normal shift and the

isolating means is not capable of being locked out, a reasonable effort will be made to affix a device to the isolating means to make capable of being locked out.

- All authorized employee engaging in lockout tagout activities will follow the written procedure and the guidelines set forth in the Company's Lockout Tagout Program.

Welding, Cutting & Brazing

- Only authorized and trained personnel permitted to use welding, cutting or brazing equipment. - All operators have a copy of the appropriate operating instructions and are they directed to follow them. - Compressed gas cylinders regularly examined for obvious signs of defects, deep rusting, or leakage. - Care used in handling and storage of cylinders, safety valves, relief valves, and the like, to prevent damage.

Precautions taken to prevent the mixture of air or oxygen with flammable gases, except at a burner or in a standard torch.

- Only approved apparatus (torches, regulators, pressure-reducing valves, acetylene generators, manifold) used.

- Cylinders kept away from sources of heat. - It is prohibited to use cylinders as rollers or supports. - Empty cylinders appropriately marked their valves closed and valve-protection caps on. - Signs reading: DANGER NO-SMOKING, MATCHES, OR OPEN LIGHTS, or the equivalent posted. - Cylinders, cylinder valves, couplings, regulators, hoses, and apparatus keep free of oily or greasy

substances. - Care taken not to drop or strike cylinders. - Unless secured on special trucks, regulators are removed and valve-protection caps put in place before

moving cylinders. - Cylinders without fixed hand wheels have keys, handles, or non-adjustable wrenches on stem valves when

in service. - Liquefied gases stored and shipped valve-end up with valve covers in place. - Employees instructed to never crack a fuel-gas cylinder valve near sources of ignition.

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- Before a regulator is removed, the valve is closed and gas released from the regulator. - Red used to identify the acetylene (and other fuel-gas) hose, green for oxygen hose, and black for inert gas

and air hose. - Pressure-reducing regulators used only for the gas and pressures for which they are intended. - Open circuit (No Load) voltage of arc welding and cutting machines as low as possible and not in excess of

the recommended limits. - Under wet conditions, automatic controls for reducing no-load voltage are used. - Grounding of the machine frame and safety ground connections of portable machines checked periodically. - Electrodes removed from the holders when not in use. - It is required that electric power to the welder is shut off when no one is in attendance. - Suitable fire extinguishing equipment available for immediate use. - The welder forbidden to coil or loop welding electrode cable around his body. - Wet machines thoroughly dried and tested before being used. - Work and electrode lead cables frequently inspected for wear and damage, and replaced when needed. - Means for connecting cables' lengths have adequate insulation. - The object to be welded cannot be moved and fire hazards cannot be removed, are shields used to ~-,

confine heat, sparks, and slag. - Firewatchers assigned when welding or cutting is performed, in locations where a serious fire might develop. - Combustible floors kept wet, covered by damp sand, or protected by fire-resistant shields. - When floors are wet down, personnel are protected from possible electrical shock. - When welding is done on metal walls, precautions are taken to protect combustibles on the other side. - Before hot work is begun, are used drums, barrels, tanks, and other containers so thoroughly cleaned that

no substances remain that could explode, ignite, or produce toxic vapors. - It is required that eye protection helmets, hand shields and goggles meet appropriate standards. - Employees exposed to the hazards created by welding, cutting, or bracing operations protected with personal

protective equipment and clothing. - A check made for adequate ventilation in and where welding or cutting is performed. - When working in confined places environmental monitoring tests are taken and means provided for quick

removal of welders in case of an emergency. Arc Welders

- Keep your head out of the fumes. - Use enough ventilation or exhaust to remove fumes and gases from the work area. Mechanical equipment

should exhaust at least 2000 cfm of air for each welder, except where individual exhaust hoods, booths, or air-line respirators are used.

- Natural ventilation may be used under certain conditions. For welding or cutting mild steel, natural ventilation is usually sufficient if a room has at least 10,000 cubic feet per welder, with a ceiling height of at least 16 feet. Cross-ventilation should not be blocked, and welding should not be done in a confined space.

- Don't get too close to the arc ("Avoid the plume"). Use corrective lenses to help you maintain the proper distance if necessary.

- Read and understand the Safety Data Sheets (SDS) for the product. - Read and obey warning labels on all containers of welding materials. - Use a smoke extractor-type welding gun for semiautomatic welding processes. - Protect your body from welding spatter and arc flash with clothing made from durable, flame resistant

material, such as woolen fabrics, and gear that includes flame-proof apron and gloves, leather leggings, and high boots.

- Avoid clothing made of synthetic materials, which can melt when exposed to extreme heat or sparks, or cotton unless it is specially treated for fire protection.

- Keep your clothes free of grease and oil, which may ignite. - Protect others from spatter, flash, and glare with non-flammable protective screens or curtains.

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- Be sure to wear safety glasses with side shields when in a welding area. - Be sure you are insulated from the work piece and ground, as well as other live electrical parts. - Don't lean on the work piece. - Use plywood, rubber mats or other dry insulation to stand on, and wear dry, hole-free gloves. - Stay dry, and do not weld when you are wet. Never dip the electrode in water to cool it. - Check equipment to be sure it is properly grounded, in good repair, and installed according to prevailing

codes. - Be sure equipment is turned off when not in use. - Electric current flowing through a conductor causes Electric and Magnetic Fields (EMF), which can interfere

with pacemakers and may affect health in other ways. Consult your physician before arc welding if you have a pacemaker.

- To avoid excessive exposure to EMF, keep the electrode and work cables together, never place your body between the two cables or coil the electrode lead around your body, and do not work directly next to the welding power source.

Compressors & Compressed Air

- Compressors equipped with pressure relief valves, and pressure gauges. - Compressor air intakes installed and equipped to ensure that only clean uncontaminated air enters the

compressor. - Air filters installed on the compressor intake. - Compressors operated and lubricated in accordance with the manufacturer's recommendations. - Safety devices on compressed air systems checked frequently. - Before any repair work is done on the pressure system of a compressor, the pressure is bled off and the

system locked-out. Signs posted to warn of the automatic starting feature of the compressors. - The belt drive system is totally enclosed to provide protection for the front, back, top, and sides. - It is strictly prohibited to direct compressed air towards a person. - Employees prohibited from using highly compressed air for cleaning purposes. - If compressed air is used for cleaning off clothing, the pressure is reduced to less than 10 psi. - When using compressed air for cleaning, employees use personal protective equipment. - Safety chains or other suitable locking devices used at couplings of high pressure hose lines where a

connection failure would create a hazard. - Before compressed air is used to empty containers of liquid, the safe working pressure of the container is

checked. - When compressed air is used with abrasive blast cleaning equipment, the operating valve is a type that must

be held open manually. - When compressed air is used to inflate auto tires, a clip-on chuck and an inline regulator preset to 40 psi is

required. - It is prohibited to use compressed air to clean up or move combustible dust if such action could cause the

dust to be suspended in the air and cause a fire or explosion hazard. Compressed Air Receivers

- Every receiver is equipped with a pressure gauge and with one or more automatic, spring-loaded safety valves.

- The total relieving capacity of the safety valve capable of preventing pressure in the receiver from exceeding the maximum allowable working pressure of the receiver by more than 10 percent.

- Every air receiver provided with a drainpipe and valve at the lowest point for the removal of accumulated oil and water.

- Compressed air receivers periodically drained of moisture and oil.

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- All safety valves tested frequently and at regular intervals to determine whether they are in good operating condition.

- There is a current operating permit issued by the Division of Occupational Safety and Health. - The inlet of air receivers and piping systems is kept free of accumulated oil and carbonaceous materials.

Compressed Gas & Cylinders

- Cylinders with a water weight capacity over 30 pounds equipped with means for connecting a valve protector device, or with a collar or recess to protect the valve.

- Cylinders legibly marked to clearly identify the gas contained. - Compressed gas cylinders stored in areas which are protected from external heat sources such as flame

impingement, intense radiant heat, electric arcs, or high temperature lines. Cylinders located or stored in areas where they will not be damaged by passing or falling objects or subject to tampering by unauthorized persons. Cylinders stored or transported in a manner to prevent them creating a hazard by tipping, falling or rolling. Cylinders containing liquefied fuel gas, stored or transported in a position so that the safety relief device is always in direct contact with the vapor space in the cylinder.

- Valve protectors always placed on cylinders when the cylinders are not in use or connected for use. - All valves closed off before a cylinder is moved, when the cylinder is empty, and at the completion of each

job. - Low pressure fuel-gas cylinders checked periodically for corrosion, general distortion, cracks, or any other

defect that might indicate a weakness or render it unfit for service. - The periodic check of low pressure fuel-gas cylinders includes a close inspection of the cylinders' bottom.

Material Handling

- There is safe clearance for equipment through aisles and doorways. - Aisle ways designated, permanently marked, and kept clear to allow unhindered passage. - Motorized vehicles and mechanized equipment inspected daily or prior to use. - Vehicles shut off and brakes set prior to loading or unloading. - Containers or combustibles or flammables, when stacked while being moved, always separated by dunnage

sufficient to provide stability. - Dock boards (bridge plates) used when loading or unloading operations are taking place between vehicles

and docks. - Trucks and trailers secured from movement during loading and unloading operations. - Dock plates and loading ramps constructed and maintained with sufficient strength to support imposed

loading. - Hand trucks maintained in safe operating condition. - Chutes equipped with sideboards of sufficient height to prevent the materials being handled from falling off. - Chutes and gravity roller sections firmly placed or secured to prevent displacement. - At the delivery end of rollers or chutes, provisions are made to brake the movement of the handled materials. - Pallets usually inspected before being loaded or moved. - Hooks with safety latches or other arrangements used when hoisting materials so that slings or load

attachments won't accidentally slip off the hoist hooks. - Securing chains, ropes, choker or slings are adequate for the job to be performed. - When hoisting material or equipment, provisions are made to assure no one will be passing under the

suspended loads. - Safety Data Sheets available to employees handling hazardous substances.

Hoist & Auxiliary Equipment

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- Each overhead electric hoist is equipped with a limit device to stop the hook travel at its highest and lowest point of safe travel.

- Each hoist automatically will stop and hold any load up to 125 percent obits rated load, if its actuating force is removed.

- The rated load of each hoist is legibly marked and visible to the operator. - Stops provided at the safe limits of travel for trolley hoist. - The controls of hoists plainly marked to indicate the direction of travel or motion. - Each cage-controlled hoist is equipped with an effective warning device. - Close-fitting guards or other suitable devices installed on hoist to assure hoist ropes will be maintained in the

sheave groves. - All hoist chains or ropes of sufficient length to handle the full range of movement for the application while still

maintaining two full wraps on the drum at all times. - Nip points or contact points between hoist ropes and sheaves which are permanently located within 7 feet of

the floor, ground or working platform, guarded. - It is prohibited to use chains or rope slings that are kinked or twisted. - It is prohibited to use the hoist rope or chain wrapped around the load as a substitute, for a sling. - The operator is instructed to avoid carrying loads over people. - Only employees who have been trained in the proper use of hoists allowed to operate them.

Cranes

- The cranes visually inspected for defective components prior to the beginning of any work shift. - All electrically operated cranes effectively grounded. - A crane preventive maintenance program is established. - The load chart is clearly visible to the operator. - Operating controls clearly identified. - A fire extinguisher is provided at the operator's station. - The rated capacity is visibly marked on each crane. - An audible warning device is mounted on each crane. - Sufficient illumination is provided for the operator to perform the work safely. - Cranes of such design, that the boom could fall over backward, equipped with boom stops. - Each crane has a certificate indicating that required testing and examinations have been performed. - Crane inspection and maintenance records maintained and available for inspection.

Industrial Trucks -Forklifts

- Only trained personnel allowed to operate industrial trucks. - Substantial overhead protective equipment is provided on high lift rider equipment. - The required lift truck operating rules posted and enforced. - Directional lighting is provided on each industrial truck that operates in an area with less than 2 foot candles

per square foot of general lighting. - Each industrial truck has a warning horn, whistle, gong or other device which can be clearly heard above the

normal noise in the areas where operated. - The brakes on each industrial truck capable of bringing the vehicle to a complete and safe stop when fully

loaded. - The industrial truck's parking brake will effectively prevent the vehicle from moving when unattended. - Industrial trucks operating in areas where flammable gases or vapors, or combustible dust or ignitable fibers

may be present in the atmosphere are approved for such locations. - Motorized hand and hand/rider trucks so designed that the brakes are applied, and power to the drive motor

shuts off when the operator releases his/her grip on the device that controls the travel.

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- Industrial trucks with internal combustion engine operated in buildings or enclosed areas, carefully checked to ensure such operations do not cause harmful concentration of dangerous gases or fumes.

- Spraying Operations

- Adequate ventilation is assured before spray operations are started. - Mechanical ventilation is provided when spraying operation is done in enclosed areas. - Mechanical ventilation is provided during spraying operations, so arranged that it will not circulate the

contaminated air. - The spray area is free of hot surfaces. The spray area is at least 20 feet from flames, sparks, operating

electrical motors and other ignition sources. - Portable lamps used to illuminate spray areas suitable for use in a hazardous location. - Approved respiratory equipment is provided and used when appropriate during spraying operations. - Fire control sprinkler heads kept clean. - NO SMOKING" signs posted in spray areas, paint rooms, paint booths, and paint storage areas. - The spray area is kept clean of combustible residue. Spray booths constructed of metal, masonry, or other

substantial noncombustible material. - Spray booth floors and baffles noncombustible and easily cleaned. - Infrared drying apparatus is kept out of the spray area during spraying operations. - The spray booth is completely ventilated before using the drying apparatus. - The electric drying apparatus is properly grounded. - Lighting fixtures for spray booths located outside of the booth and the interior lighted through sealed clear

panels. - The electric motors for exhaust fans placed outside booths or ducts. - Belts and pulleys inside the booth fully enclosed. - Ducts have access doors to allow cleaning. - All drying spaces have adequate ventilation.

General Requirements

- The use of any machinery, tool, material, or equipment which is not in compliance with any applicable requirements of this manual is prohibited. Such machine, tool, material, or equipment shall either be identified as unsafe by tagging or locking the controls to render them inoperable or shall be physically removed from its place of operation.

- The employer shall permit only those employees qualified by training or experience to operate equipment and machinery.

- Employees shall use safeguards provided for their protection. - Suitable clothing shall be worn for the job. Sufficient and proper clothing shall be worn to assist in preventing

scratches, abrasions, slivers, sunburn, hot liquid bums, or similar hazards. Loose or ragged clothing, scarves or ties shall not be worn while working around moving machinery.

- Employees shall report to their employers the existence of any unsafe equipment or method or any other hazard which, to their knowledge is unsafe and where such unsafe equipment or method or other hazard exists in violation of this chapter it shall be corrected.

- Nothing herein contained shall prevent the use of existing equipment during its lifetime provided it shall be properly safeguarded, maintained in good condition, be in conformity with applicable safety and health standards and shall conform to safety factors for the material used, as herein provided.

Environmental Controls

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- All work areas properly illuminated. - Employees instructed in proper first aid and other emergency procedures. - Hazardous substances identified which may cause harm by inhalation, ingestion, skin absorption or contact. - Employees aware of the hazards involved with the various chemicals they may be exposed to in their work

environment, such as ammonia, chlorine, epoxies, and caustics. - Employee exposure to chemicals in the workplace is kept within acceptable levels. - Whenever possible a less harmful method or product is used. - The work area's ventilation system is appropriate for the work being performed. - Spray painting operations done in spray rooms or booths equipped with an appropriate exhaust system. - Employee exposure to welding fumes is controlled by ventilation, use of respirators, exposure time or other

means. - Welders and other workers nearby provided with flash shields during welding operations. - If forklifts and other vehicles are used in buildings or other enclosed areas, the carbon monoxide levels are

kept below maximum acceptable concentration. - There has been a determination that noise levels in the facilities are within acceptable levels. - Steps being taken to use engineering controls to reduce excessive noise levels. - Proper precautions being taken when handling asbestos and other fibrous materials. - Caution labels and signs used to warn of asbestos. - Wet methods used, when practicable, to prevent the emission of airborne asbestos fibers, silica dust and

similar hazardous materials. - Vacuuming with appropriate equipment is used whenever possible rather than blowing or sweeping dust. - Grinders, saws, and other machines that produce respirable dust vented to an industrial collector or central

exhaust system. - All local exhaust ventilation systems designed and operating properly such as airflow and volume necessary

for the application. - Personal protective equipment is provided, used and maintained wherever required. - There written standard operating procedures for the selection and use of respirators where needed. - Restrooms and washrooms kept clean and sanitary. - All water provided for drinking, washing, and cooking is potable. - All outlets for water not suitable for drinking clearly identified. - Employees' physical capacities assessed before being assigned to jobs requiring heavy work. - Employees instructed in the proper manner of lifting heavy objects. - Where heat is a problem, all fixed work areas have been provided with spot cooling or air conditioning. - Employees screened before assignment to areas of high heat to determine if their health condition might

make them more susceptible to having an adverse reaction. - Employees working on streets and roadways where they are exposed to the hazards of traffic, required to

wear bright colored (traffic orange) warning vest. - Exhaust stacks and air intakes located that contaminated air will not be re-circulated within a building or other

enclosed area. - Equipment producing ultra-violet radiation is properly shielded.

Ventilation for Indoor Air Quality

- HVAC system provides at least the quantity of outdoor air required by the State Building Standards Code, Title 24, Part 2 at the time the building was constructed.

- The HVAC system inspected at least annually, and problems corrected. - Inspection records retained for at least 5 years. - Control of Harmful Substances by Ventilation - The volume and velocity of air in each exhaust system is sufficient to gather the dusts, fumes, mists, vapors

or gases to be controlled, and to convey them to a suitable point of disposal

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- Exhaust inlets, ducts and plenums designed, constructed, and supported to prevent collapse or failure of any part of the system.

- Clean-out ports or doors provided at intervals not to exceed 12 feet in all horizontal runs of exhaust ducts. - Where two or more different type of operations are being controlled through the same exhaust system, the

combination of substances being controlled will not constitute a fire, explosion or chemical reaction hazard in the duct.

- Adequate makeup air is provided to areas where exhaust systems are operating. The intake for makeup air is located so that only clean, fresh air, which is free of contaminates, will enter the work environment.

- Where two or more ventilation systems are serving a work area, their operation is such that one will not offset the functions of the other.

- Flammable & Combustible Materials

- Combustible scrap, debris and waste materials (i.e. oily rags) stored in covered metal receptacles and removed from the worksite promptly.

- Proper storage practiced to minimize the risk of fire including spontaneous combustion. - Approved containers and tanks used for the storage and handling of flammable and combustible liquids. - Connections on drums and combustible liquid piping, vapor and liquid tight. - Are all flammable liquids kept in closed containers when not in use (e.g. parts cleaning tanks, pans). - Bulk drums of flammable liquids grounded and bonded to containers during dispensing. - Storage rooms for flammable and combustible liquids have explosion-proof lights. - Storage rooms for flammable and combustible liquids have mechanical or gravity ventilation. - Liquefied petroleum gas stored, handled, and used in accordance with safe practices and standards. - Liquefied petroleum storage tanks guarded to prevent damage from vehicles. - All solvent wastes and flammable liquids kept in fire-resistant covered containers until they are removed from

the worksite. - Vacuuming used whenever possible rather than blowing or sweeping combustible dust. - Fire separators placed between containers of combustibles or flammables, when stacked one upon another,

to assure their support and stability. - Fuel gas cylinders and oxygen cylinders separated by distance, fire resistant barriers or other means while

in storage. - Fire extinguishers selected and provided for the types of materials in areas where they are to be used. - Class A: Ordinary combustible material fires. - Class B: Flammable liquid, gas or grease fires. - Class C: Energized-electrical equipment fires. - If a Halon 1301 fire extinguisher is used, employees can evacuate within the specified time for that

extinguisher. - Appropriate fire extinguishers mounted within 75 feet of outside areas containing flammable liquids, and

within 10 feet of any inside storage area for such materials. - The transfer/withdrawal of flammable or combustible liquids is performed by trained personnel. - Fire extinguishers mounted so that employees do not have to travel more than 75 feet for a class "A" fire or

50 feet for a class "B" fire. - Employees trained in the use of fire extinguishers. - Extinguishers free from obstructions or blockage. - All extinguishers serviced, maintained and tagged at intervals not to exceed one year. - All extinguishers fully charged and in their designated places. - A record maintained of required monthly checks of extinguishers. - Where sprinkler systems are permanently installed, the nozzle heads are directed or arranged so that water

will not be sprayed into operating electrical switchboards and equipment.

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- "NO SMOKING" signs posted where appropriate in areas where flammable or combustible materials are used or stored.

- "NO SMOKING" signs posted on liquefied petroleum gas tanks. - "NO SMOKING" rules enforced in areas involving storage and use of flammable materials. - Safety cans used for dispensing flammable or combustible liquids at a point of use. - All spills of flammable or combustible liquids cleaned up promptly. Storage tanks adequately vented to

prevent the development of excessive vacuum or pressure as a result of filling, emptying, or atmosphere temperature changes.

- Storage tanks equipped with emergency venting that will relieve excessive internal pressure caused by fire exposure. Spare portable or butane tanks, which are sued by industrial trucks stored in accord with regulations.

Fire Protection

- Have a fire prevention plan. - Plan describes the type of fire protection equipment and/or systems. - Established practices and procedures to control potential fire hazards and ignition sources. - Employees aware of the fire hazards of the material and processes to which they are exposed. - Local fire department well acquainted with your facilities, location and specific hazards. - Fire alarm system is tested at least annually. - Fire alarm system is certified as required. - Interior standpipes and valves are inspected regularly. - Outside private fire hydrants are flushed at least once a year and on a routine preventive maintenance

schedule. - Fire doors and shutters in good operating condition. - Fire doors and shutters unobstructed and protected against obstructions, including their counterweights. - Fire door and shutter fusible links in place. - Automatic sprinkler system water control valves, air and water pressures checked weekly/periodically as

required. - Maintenance of automatic sprinkler system is assigned to responsible persons or to a sprinkler contractor. - Sprinkler heads protected by metal guards, when exposed to physical damage. - Proper clearance is maintained below sprinkler heads. - Portable fire extinguishers provided in adequate number and type. - Fire extinguishers mounted in readily accessible locations. - Fire extinguishers recharged regularly and noted on the inspection tag. - Employees are annually instructed in the use of extinguishers and fire protection procedures.

Company Fire Brigades City Construction, Inc. does not have any company fire brigades. Hazardous Chemical Exposures

- Employees trained in the safe handling practices of hazardous chemicals such as acids, caustics, and the like.

- Employees aware of the potential hazards involving various chemicals stored or used in the workplace such as acids, bases, caustics, epoxies, and phenols.

- Employee exposure to chemicals is kept within acceptable levels. - Eye wash fountains and safety showers provided in areas where corrosive chemicals are handled. - All containers, such as vats and storage tanks labeled as to their contents--e.g. "CAUSTICS".

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- All employees required to use personal protective clothing and equipment when handling chemicals (i.e. gloves, eye protection, and respirators).

- Flammable or toxic chemicals kept in closed containers when not in use. - Chemical piping systems clearly marked as to their content. - Where corrosive liquids are frequently handled in open containers or drawn from storage vessels or pipelines,

adequate means is readily available for neutralizing or disposing of spills or overflows properly and safely. - Standard operating procedures have been established and are they being followed when cleaning up

chemical spills. - Where needed for emergency use, respirators are stored in a convenient, clean and sanitary location. - Respirators intended for emergency use adequate for the various uses for which they may be needed. - Employees prohibited from eating in areas where hazardous chemicals are present. - Personal protective equipment is provided, used and maintained whenever necessary. - There are written standard operating procedures for the selection and use of respirators where needed. - Respirator protection program requires employees to be instructed on the correct usage and limitations of

the respirators. - The respirators NIOSH approved for this particular application. - They regularly inspected and cleaned sanitized and maintained. - Hazardous substances are used in your processes require a medical or biological monitoring system in

operation. - Familiar with the Threshold Limit Values or Permissible Exposure Limits of airborne contaminants and

physical agents used in your workplace. - Control procedures have been instituted for hazardous materials, where appropriate, such as respirators,

ventilation systems, handling practices, and the like. - Whenever possible, hazardous substances are handled in properly designed and exhausted booths or similar

locations. - Use general dilution or local exhaust ventilation systems to control dusts, vapors, gases, fumes, smoke,

solvents or mists which may be generated in your workplace. - Ventilation equipment is provided for removal of contaminants from such operations as production grinding,

buffing, spray painting, and/or vapor decreasing, and is it operating properly. - If internal combustion engines are used, carbon monoxide is kept within acceptable levels. - Vacuuming used, rather than blowing or sweeping dusts whenever possible for cleanup. - Materials, which give off toxic, asphyxiate, suffocating or anesthetic fumes, are stored in remote or isolated

locations when not in use.

Hazardous Substances Communication

- There is a list of hazardous substances used in your workplace. - There is a written hazard communication program dealing with Safety Data Sheets (SDS) labeling, and

employee training (See Main Program). - The RSO is responsible for SDSs, container labeling, employee training. - Each container for a hazardous substance (i.e. vats, bottles, storage tanks,) is labeled with product identity

and a hazard warning (communication of the specific health hazards and physical hazards). - There is a Safety Data Sheet readily available for each hazardous substance used. - There is an employee training program for hazardous substances. This program includes:

o An explanation of what an SDS is and how to use and obtain one. o An explanation of the new Global Harmonization System for SDS and labeling. o SDS contents for each hazardous substance or class of substances. o Explanation of "Right to Know". o Identification of where employees can see the employer's written hazard communication program

and where hazardous substances are present in their work area.

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o The physical and health hazards of substances in the work area, how to detect their presence, and specific protective measures to be used.

o Details of the hazard communication program. o How employees will be informed of hazards of non-routine tasks, and hazards of unlabeled pipes.

Identification of Piping Systems

- When no potable water is piped through a facility, outlets or taps are posted to alert employees that it is unsafe and not to be used for drinking, washing or other personal use.

- When hazardous substances are transported through above ground piping, each pipeline is identified at points where confusion could introduce hazards to employees.

- When pipelines are identified by color painting, all visible parts of the line are so identified. - When pipelines are identified by color painted bands or tapes, the bands or tapes are located at reasonable

intervals and at each outlet, valve or connection. When pipelines are identified by color, the color code is posted at all locations where confusion could introduce hazards to employees.

- When the contents of pipelines are identified by name or name abbreviation, the information is readily visible on the pipe near each valve or outlet.

- When pipelines carrying hazardous substances are identified by tags, the tags are constructed of durable materials, the message carried clearly ad permanently distinguishable and are tags installed at each valve or outlet.

- When pipelines are heated by electricity, steam or other external source, suitable warning signs or tags are placed at unions, valves, or other serviceable parts of the system.

Transporting Employees & Materials

- Employees who operate vehicles on public thoroughfares have valid operator's licenses. - When seven or more employees are regularly transported in a van, bus or truck, the operator's license is

appropriate for the class of vehicle being driven. - Each van, bus or truck used regularly to transport employees, is equipped with an adequate number of seats. - When employees are transported by truck, provisions are provided to prevent their falling from the vehicle. - Vehicles used to transport employees, equipped with lamps, brakes, horns, mirrors, windshields and turn

signals in good repair. - Transport vehicles provided with handrails, steps, stirrups or similar devices, so placed and arranged that

employees can safely mount or dismount. - Employee transport vehicles equipped at all times with at least two reflective type flares. - A full charged fire extinguisher, in good condition, with at least 4 BC rating maintained is in each employee

transport vehicle. - When cutting tools with sharp edges are carried in passenger compartments of employee transport vehicles,

they are placed in closed boxes or containers which are secured in place. - Employees prohibited from riding on top of any load, which can shift, topple, or otherwise become unstable.

Sanitizing Equipment & Clothing

- Personal protective clothing or equipment, that employees are required to wear or use, is of a type capable of being easily cleaned and disinfected.

- Employees prohibited from interchanging personal protective clothing or equipment, unless it has been properly cleaned.

- Machines and equipment, which processes, handle or apply materials that could be injurious to employees, cleaned and/or decontaminated before being overhauled or placed in storage.

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- Employees prohibited from smoking or eating in any area where contaminates are present that could be injurious if ingested.

- When employees are required to change from street clothing into protective clothing, a clean change room with separate storage facility for street and protective clothing is provided. Employees required to shower and wash their hair as soon as possible after a known contact has occurred with a carcinogen.

- When equipment, materials, or other items are taken into or removed from a carcinogen regulated area, is done in a manner that will not contaminate non-regulated areas or the external environment.

Emergency Action Plan Although City Construction takes precautions to prevent them, emergencies do occur. When they do, they require quick, correct and decisive responses. Employees have been informed of the company’s planned response to emergency situations, and they are expected to adhere to these guidelines. Since all of our work is located at the client’s jobsite their emergency action plan will be followed for the duration of any project and will be reviewed prior to the start of any work. The following is our general emergency action plan: City Construction Company, Inc. 1100 Bondsville Road Downingtown, PA 19335 Company Contact:

• Name: Dennis Fallon • Title: Manager • Telephone/Cell: 6102699530 • Email: dfallon@cityconstructionco.com

Alerts: In the event of an emergency, employees are alerted by:

• Verbal Announcement : Jobsite Emergency • Client's emergency alert system: General Evacuation

Policy: In the event of fire or other emergency, ALL employees shall evacuate immediately.

Routes: In the event of an emergency, employees shall evacuate by means of the nearest available marked exit.

Extinguishers: Employees are not authorized to use any portable fire extinguisher that may be present to fight fires. In the event of fire, employees are to evacuate immediately.

Operations: In the event of an emergency, the following employees are to remain in the workplace to shutdown or monitor critical operations before they evacuate:

Dennis Fallon Robert Fallon Jr.

Duties: No employees are assigned to perform medical or rescue duties during emergency evacuation situations

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Assembly: After an emergency evacuation, employees are to gather in the following location(s):

Safe point determined by client’s emergency action plan.

Accounting: After an emergency evacuation, the procedure for accounting for all employees is:

Forman will be responsible for employee count.

Additional Information: Additional Evacuation Plan and Procedures:

Follow any client's emergency evacuation and emergency plans.

Medical Facilities: The closest emergency medical facility is located at: Brandywine Hospital 201 Reeceville Road, Coatesville, PA 19320 Phone: (610) 383-8000 Infection Control

- A training and information program is provided for employees exposed to or potentially exposed to blood and/or body fluids.

- Infection control procedures have been instituted where appropriate, such as ventilation, universal precautions, workplace practices, personal protective equipment.

- Employees are aware of specific workplace practices to follow when appropriate (Hand washing, handling sharp instruments, handling of laundry, disposal of contaminated materials, reusable equipment.

- Personal protective equipment is provided to employees, and in all appropriate locations. - The necessary equipment (i.e. mouth-pieces, resuscitation bags, other ventilation devices) is provided for

administering mouth-to-mouth resuscitation on potentially infected patients. - Facilities/equipment are to comply with workplace practices available, such as hand-washing sinks,

biohazard tags and labels, needle containers, detergents/disinfectants to clean up spills. - All equipment and environmental and working surfaces are cleaned and disinfected after contact with blood

or potentially infectious materials. - Infectious waste is placed in closable, leak proof containers, bags or puncture-resistant holders proper labels. - Medical surveillance including HBV evaluation, antibody testing and vaccination has been made available to

potentially exposed employees. - Employees are trained on universal precautions, personal protective equipment and needle stick exposure /

management. - Employee are trained on workplace practices which should include blood drawing, room cleaning, laundry

handling, clean-up of blood spills. - Employees potentially exposed to blood borne pathogens are offered Hepatitis B vaccinations at no cost to

the employee. Ergonomics The work can be performed without eyestrain or glare to the employees. Tasks will not require prolonged raising of the arms. The neck and shoulders will not have to be stooped to view the task. There are no pressure points on any parts of the body (wrists, forearms, back of thighs).

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The work can be done using the larger muscles of the body. The work can be done without twisting or overly bending the lower back. Sufficient rest breaks, in addition to the regular rest breaks, to relieve stress from repetitive-motion tasks. Tools, instruments and machinery shaped, positioned and handled so that tasks can be performed comfortably. All pieces of furniture adjusted, positioned and arranged to minimize strain on all parts of the body. Back & Lifting Safety

- Lifting things and moving them from one place to another is a very simple operation. However, if this operation is done incorrectly, it may cause many injuries. You can wrench your back or pull a muscle, or crush or pinch your hands or feet.

- Learn how to lift and prevent injuries. - Use the right kind of personal protective gear. - Hand protection and safety shoes are a must for most lifting jobs. - Some jobs might call for hard hats and goggles. - If it is too big or too heavy for you to handle alone, get help. - Check the material for nails, splinters, rough stripping that might injure your hands. - Lifting Procedures:

1. Face the load. 2. Put one foot alongside the object, and one foot behind. 3. Bend at the knees. Let your legs do the work. 4. Keep back straight and the load as close as possible. 5. Get a good, firm grip with the palms of your hands while lifting by straightening your legs. 6. Avoid twisting as you turn with a load. Shift your feet instead. 7. Don't try to lift something above waist level in one motion. Set the load on a table or bench, and then

change your grip for lifting higher. 8. To put the object down, just follow the lifting procedure, but in reverse

Housekeeping

- Office areas are to be kept neat and orderly. The following general rules apply to prevent injuries and maintain a professional appearance.

- All aisles, emergency exits, fire extinguishers, etc., will be kept clear (a minimum of three feet of either side) of material storage (temporary and permanent) at all times.

- Storage areas will be maintained orderly at all times. When supplies are received, the supplies will be stored properly.

- Spills will be cleaned-up immediately and wastes disposed of properly. - All waste receptacles will be lined with a plastic trash bag to avoid direct contact while handling. Custodial

Employees will use rubber gloves and compaction bar when handling wastes. - Keep file and desk drawers closed when not attended to avoid injuries. Open only one drawer at a time to

prevent tipping of file cabinets. - At the end of the business day, turn off all office equipment (area heaters, lamps, coffee-maker, PCs, etc.)

and lights to save energy and prevent fires. All space heaters must be un-plugged at the end of the day to assure they have been turned-off.

- Work areas will be kept neat and orderly, during operations and as follows: - All aisles, emergency exits, fire extinguishers, eye wash stations, etc., will be kept clear (a minimum of three

feet in front of and to either side) of product storage, material storage, fork trucks and pallet jacks at all times. - Spills will be cleaned up immediately. - All process leaks will be reported to supervision and maintenance for immediate repair and cleanup.

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- Utility Employees will be responsible to keep aisles and work floors clear of excessive debris and waste materials during shift operation, between breaks and at shift change when necessary or directed by supervision; however, all Employees are responsible to communicate slippery floors to supervision for immediate clean-up.

- All refuse and waste materials will be placed in the recognized waste containers for disposal. - Restrooms and break areas are provided as a convenience for all Employees. The following rules will apply: - Employees are expected to clean-up after themselves as a common courtesy to fellow Employees. - Flammable materials (fireworks, explosives, gasoline, etc.) may not be stored in break areas or brought on

company property. - Personal food item will not be stored in break areas overnight. - All waste receptacles will be lined with a plastic trash bag to avoid direct contact while handling and Custodial

Employees will use rubber gloves and compaction bar when handling wastes. - All refuse and waste materials will be placed in the recognized waste containers for disposal.

Maintenance Areas

- All aisles, emergency exits, fire extinguishers, etc., will be kept clear (a minimum of three feet of either side) of material storage (temporary and permanent) at all times.

- Storage Areas will be maintained orderly at all times. - Pipe stock stored horizontally on racks and sorted by size - Metal stock stored horizontally on racks and sorted by size - Sheet metal stock stored vertically in racks and sorted by type - All fittings, etc., stored in bins on shelves and sorted by type and use - All flammables stored in OSHA-approved Fire Cabinets and self-closing cans where necessary - Spills will be cleaned-up immediately by the person responsible and wastes disposed properly. - All refuse and waste materials will be placed in the recognized waste containers for disposal.

The grounds surrounding our main facility and worksites are an extension of the work place. Grounds that are kept neat and orderly show pride by the Company for Employees, customers and neighbors to enjoy. The following general rules will apply: - Keep the parts of buildings that are visible to public roads cleaned by washing them at regular intervals. - Keep the other parts of buildings cleaned at regular intervals. - Keep all doors and loading docks completely free of debris, shrubs, or other obstructions. - Maintain visibility through all windows by washing at regular intervals. - Keep doors and windows properly maintained in good working order. - Repair any damage to doors and windows at regular intervals. - All trash will be discarded only in the waste containers provided. - Park only in the designated assigned area. - The Maintenance Department will be responsible for grounds keeping (mowing, trimming, etc.) as needed.

Maintenance will also establish procedures for ice/snow removal, when necessary, prior to operations each day.

- Provide any stairs or platforms adjacent to or leading into the building(s) with adequate rails, adequate treads to climb and an area clean and free of materials.

- Keep grounds neat and orderly, free of refuse and unnecessary materials. - Store materials outdoors only in designated areas of the grounds. - Provide designated walkways through grounds, preferably paved and kept clear of snow, ice, materials, or

any other physical hazards. - Provide a lighting system that is adequate to allow employees to navigate around the grounds as necessary

at dusk and after dark.

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- Maintain a neat landscaping appearance--trim lawn, trees and shrubs in such a way as to minimize any possible safety hazards.

- Trim grass short enough to prevent trip hazards to employees. - Prevent trees and shrubs from obstructing doors and windows.

Material Storage Proper storage procedures are required for dry, raw materials, flammables and compressed gases storage to prevent fires, keep exits and aisles clear and avoid injuries and illnesses. General rules for material storage are as follows:

- Materials may not be stored any closer than 18 inches to walls or sprinkler heads. A minimum of 3 feet side clearance will be maintained around doorways and emergency exits. Passageways and aisle will be properly marked and a minimum of six feet in width. Materials, forklifts, pallet jacks, etc., may not be stored in aisles or passageways.

- Aisles and passageways will be kept clear of debris. All spills of materials will be immediately cleaned-up by the person responsible.

- All platforms and racks will have maximum load capacity displayed. The weight of stored material will not exceed the rated load capacity.

- All flammables will be stored in OSHA-approved flammable storage cabinets or stored outside (at least 50 feet from any structure)

- Fuels, solvents and other flammables (not stored in original shipping containers) will be stored in OSHA-approved self-closing containers with flame arresters. Flammables may not be stored in open containers (open parts baths, etc.).

- Flammable storage areas will be kept dry and well ventilated. No storage of combustible materials, open flames or exposed electrical components is permitted in the flammable storage area.

- Flammable or combustible materials may not be stored in electrical rooms. Electrical rooms must be kept clean and dry at all times.

- Inspect bottle for defects & proper marking/labels - Ensure stamped date on bottle has not expired - Inspect valve assembly and adapter thread area - Ensure SDS is on file or with shipment - Follow SDS requirements for storage - Cylinder cap securely in place when not in use. - Marked with contents and if empty/full. - Stored up-right and secured to a stationary structure in a shaded and well ventilated area. - Cylinders not stored within 50 feet of exposed electrical components or combustible materials. - Cylinders are protected from accidental rupture. - Chemically reactive gases not stored within 50 feet of each other. - Must be secured to a cart or cylinder trolley - Cap securely fastened - Inspect valve adapter threads. - Inspect all fasteners, hoses & regulators prior to hooking up to cylinder. - Use only for approved purposes. - Use in up-right position. - Fasten cylinder to structure or cart. - Regulators must be of same rated pressure as cylinder - Keep cylinder valve shut when not in use; don't depend on regulators

Company Vehicles

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Some company employees are provided with vehicles for use in their jobs. The following rules apply:

- The company requires all drivers of company vehicles to have current, valid licenses. - Company policy prohibits anyone without a valid driver's license from driving a company vehicle. - An employee who becomes uninsurable by the company's insurance company will be subject to termination. - Company vehicles are to be used only for job-related activities. - People who are not employed by the company or who are not assisting in work-related activities should not

be transported in company vehicles as passengers because it presents a potential exposure to liability. - All traffic laws and regulations are to be obeyed. - Every effort should be made to keep mileage driven to a minimum by combining trips whenever possible.

Special circumstances that may require deviation from this policy must first be cleared by your supervisor. - It is important that when you do drive a company vehicle you obey all traffic regulations, including the 55

miles per hour speed limit. On company roads, a much slower speed should be maintained at all times. Tire Inflation

- Where tires are mounted and/or inflated on drop center wheels a safe practice procedure is posted and enforced.

- Where tires are mounted and/or inflated on wheels with split rims and/or retainer rings a safe practice procedure is posted and enforced.

- Each tire inflation hose has a clip-on chuck with at least 24 inches of hose between the chuck and an in-line hand valve and gauge.

- The tire inflation control valve is automatically shut off the airflow when the valve is released. - A tire restraining device such as a cage, rack or other effective means is used while inflating tires mounted

on split rims, or rims using retainer rings. - Employees strictly forbidden from taking a position directly over or in front of a tire while it's being inflated.

Fueling

- It is prohibited to fuel an internal combustion engine with a flammable liquid while the engine is running. - Fueling operations done in such a manner that likelihood of spillage will be minimal. - When spillage occurs during fueling operations, the spilled fuel is cleaned up completely, evaporated, or

other measures taken to control vapors before restarting the engine. - Fuel tank caps replaced and secured before starting the engine. - In fueling operations there is always metal contact between the container and fuel tank. - Fueling hoses of a type designed to handle the specific type of fuel. - It is prohibited to handle or transfer gasoline in open containers. - Open lights, open flames, or sparking or arcing equipment prohibited near fueling or transfer of fuel

operations. - Smoking prohibited in the vicinity of fueling operations. - Fueling operations prohibited in building or other enclosed areas that are not specifically ventilated for this

purpose. - Where fueling or transfer of fuel is done through a gravity flow system, the nozzles are of the self-closing

type. Working in the Cold Training To protect workers from cold stress hazards, City Construction will train workers.

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Training will include: - How to recognize the environmental and workplace conditions that can lead to cold stress. - The symptoms of cold stress, how to prevent cold stress, and what to do to help those who are affected. - How to select proper clothing for cold, wet, and windy conditions. General

- Wearing the proper clothes may be the most significant precaution to reducing cold stress. Wearing appropriate clothes for cold weather involves using three layers of clothing. Also use layering to protect the head, hands, and feet.

- Drink plenty of fluids, preferably warm, sweet beverages. Thirst is suppressed in a cold environment and dehydration may occur when fluid intake is reduced.

- Increase caloric intake when working in cold environments. Workers in cold environments who wear heavy, protective clothing expend more heat and so require 10-15 percent more calories.

- A work warm-up schedule will be used to provide periodic times for warm-up breaks. Additional breaks will be provided as the wind velocity increases and/or the temperature drops.

- Avoid taking certain drugs such as alcohol, nicotine, caffeine, and medication that inhibits the body's response to cold or impairs judgment.

- Avoid the cold if you are becoming exhausted or immobilized. These conditions can accelerate the effects of cold weather.

- Shield work areas from drafty or windy conditions. Provide a heated shelter for workers with prolonged exposure to equivalent wind-chill temperatures of 20 deg. F or less.

- Select the warmest hours of the day when braving the cold. Minimize activities that reduce circulation. - Employees are trained to recognize symptoms of cold-related stresses: heavy shivering, uncomfortable

coldness, severe fatigue, drowsiness, and/or euphoria. - Use the buddy system. Always work in pairs when working in extreme weather conditions so partners can

monitor one another and obtain help quickly in an emergency. Working in the Heat Using the Heat Index City Construction does use the heat index to protect employees from heat stress. The following protective measures are to be taken at each risk level: Actions for Low Risk Conditions Heat Index Less Than 91°F protective measures:

- Provide drinking water - Ensure that adequate medical services are available - Plan ahead for times when heat index is higher, including worker heat safety training - Encourage workers to wear sunscreen - Acclimatize workers

Actions for Moderate Risk Conditions Heat Index is 91°F to 103°F protective measures in addition to the steps listed above:

- Remind workers to drink water often (about 4 cups/hour)

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- Review heat-related illness topics with workers: • How to recognize heat-related illness • How to prevent it • What to do if someone gets sick

- Schedule frequent breaks in cool, shaded area - Acclimatize workers - Set up buddy system/instruct supervisors to watch workers for signs of heat-related illness

Actions for High Risk Conditions Heat Index is 103°F to 115°F protective measures in addition to the steps listed above:

- Alert workers of high risk conditions - Limit physical exertion (e.g. use mechanical lifts) - Have a knowledgeable person at the worksite who is well-informed about heat-related illness and able to

determine appropriate work/rest schedules - Establish and enforce work/rest schedules - Adjust work activities (e.g., reschedule work, pace/rotate jobs) - Use cooling techniques - Watch/communicate with workers at all times - When possible, reschedule activities to a time when heat index is lower

Actions for Very High to Extreme Risk Conditions Heat Index Greater Than 115°F protective measures in addition to the steps listed above:

- Reschedule non-essential activity for days with a reduced heat index or to a time when the heat index is lower

- Move essential work tasks to the coolest part of the work shift; we will consider earlier start times, split shifts, or evening and night shifts.

- Strenuous work tasks and those requiring the use of heavy or non-breathable clothing or impermeable chemical protective clothing will not be conducted when the heat index is at or above 115°F.

If essential work must be done, in addition to the steps listed above:

- Alert workers of extreme heat hazards - Establish water drinking schedule (about 4 cups/hour) - Develop and enforce protective work/rest schedules - Conduct physiological monitoring (e.g., pulse, temperature, etc.) - Stop work if essential control methods are inadequate or unavailable.

General

- Cooling pads inserted into hardhats or around the neck can help keep the head and neck cooler. Vented hardhats are also available to prevent heat buildup by allowing air to pass through. Neckbands soaked in cold water and worn during the day may also keep workers more comfortable, and wearing cooling vests might also help.

- Protective eyewear offering sufficient ventilation or special lens coatings can help reduce lens fogging in hot conditions. Sweatbands can be worn to absorb perspiration on the forehead before it drips into the eyes.

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- Gloves used for hand protection can be cumbersome and also increase workers' heat complaints. Breathable products, employing nylon mesh or containing perforations, are available to reduce heat buildup. Select a glove that has a liner to absorb sweat.

- Maintaining proper hydration is essential. In some settings, workers can produce two or more gallons of sweat in a day. The National Institute for Occupational Safety and Health (NIOSH), recommends drinking five to seven ounces of fluids (excluding coffee, tea, soda, or alcohol) every 15-20 minutes to replenish the body.

- Physically demanding tasks should be limited to the coolest part of the shift and workers should take frequent breaks in cool areas.

- Employees are trained to recognize symptoms of heat-related stresses: Headache, dizziness, or fainting, weakness and wet skin, irritability or confusion, thirst, nausea, or vomiting.

INDIVIDUAL COMPLIANCE PROGRAMS Safety Training City Construction, Inc. is committed to instructing all employees in safe and healthy work practices. The Company will provide training to each employee with regard to general, acceptable, safety procedures and to any hazards or safety procedures that are specific to that employee's work situation. Training can take many forms and is synonymous with education and can be attained in a number of ways.

- Company Safety Rules: Employees should read the rules and understand them. The issuance of these rules will be logged and signed receipts and be kept on file. Each new employee, as he arrives on the job, will be approached in the same manner.

- Periodic Safety Talks: The Company should attempt to hold a safety talk with their employees on a weekly or at least monthly basis. The talk may consist merely of restating the company safety rules or warning of dangerous conditions which exist. A particular subject may be covered, such as lockout tagout, confined space, or fire prevention.

- Changed Conditions: When a of the job operation changes or when new hazardous materials are brought into the workplace, employees should be made aware of new or added potential dangerous situations that might occur and the proper action employees can take to maintain a safe workplace.

- Safety Equipment: Employees should not simply be issued protective equipment. They should be instructed as to its proper and safe use.

- Consistency/Redundancy: The employer must consistently and routinely entertain the concept of safety training. Once is not enough. At the orientation meeting of new employees, on through the follow-up weekly/monthly safety talks, the central theme must be to dwell on employees not committing unsafe acts.

- Management Follow-Up: Management must not be content with advising employees on unsafe practices. A follow-up of employee actions must be made. The Supervisor(s) must be instructed to watch for employees committing unsafe acts. Employees should be reprimanded when found doing unsafe acts. (See disciplinary program)

- Documentation: All actions taken by Management as it relates to Safety Training/Education should be documented. Documentation of good faith efforts in meeting the training requirements can be invaluable in defending a lawsuit that results from an injury due to an unsafe act by an employee. Also, documentation substantiates your commitment to and compliance with the OSHA Training Requirements.

- Individual/Group Instruction: Safety Education can be aimed at a group such as at a weekly/monthly safety talk or at an individual as in a case where the employee is being given instruction on use of a new tool, etc., by the Supervisor. Whichever the case may be, it should be documented.

In Closing

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Safety training must be ongoing. It must be given to all employees and members of management. Documentation of instruction and other forms of safety awareness techniques must be made. Never assume everyone knows the safest way of performing his or her task. Hazard Assessment Purpose: A hazard assessment is used to identify hazards, assess hazard risks and implement suitable control measures to prevent or reduce workers exposure to chemical, physical and biological agents. Introduction: A hazard assessment will be performed for each jobsite by a competent team of individuals who have a good working knowledge of the scope of work. The team shall consist of the area supervisor, workers, and subcontractors that are the most familiar with the operation. Hazard Identification: The hazard assessment team will identify all of the possible ways in which workers may be harmed through work-related activities. The team shall develop a list of hazards for each task of the scope of work. The team shall re-evaluate the hazards and controls when the following occurs:

- Before and during alterations or changes to the scope of work. - New information on hazards or control measures becomes available. - The start of a new project - A change in the work process. - A change or addition to tools, or equipment. - New employees are hired. - Moving to a new building or work area - Introduction of new chemicals or substances. - Significant changes in weather conditions that will affect the scope of work and for safety of the workers.

Hazard risk assessment: Is the process of assessing risks associated with each hazard identified during the hazard identification process. These assessments are very important as they form an integral part of a good occupational health and safety management plan. Ranking or Prioritizing Hazards: Is one way to determine the potential for accident, injury or illness. The competent team will consider the following when ranking and prioritizing hazards: Percentage of workforce exposed Frequency of exposure Degree of harm likely to result from the exposure Probability of occurrence Hazard Control Program: After determining what hazards exist at the jobsite a hazard control program will consist of all steps necessary to protect workers from exposure to a harmful substance or system and the procedures. The Hierarchy of Control is a list of control measures, in priority order, that shall be used to eliminate or minimize exposure to the hazard. They are:

- Elimination of hazards: An option use to get rid of the hazard altogether. - Substitution of hazards: Substitution involves replacing a highly toxic substance or hazardous work practice

with a less toxic substance I hazardous one. - Use of engineering controls: If the hazard cannot be eliminated, substituted or isolated, an engineering control

is the next preferred option. - Use of work practices and administrative controls to limit exposure: Includes the use of warning signs, regular

rest breaks for employees exposed to hot environments, reducing employee exposure to noisy machines by using a worker rotation policy, and providing supervision and employee training on the associated hazards.

- Personal protective equipment (PPE): Should be considered only when other control measures are not practical.

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Hazard Identification Record Keeping: Hazard identification data must be recorded so that it can be used for risk assessment activities and in determining appropriate control measures. The records will provide the following information:

- Evidence that a quality hazard review was conducted - Determination of the risks involved - Control measures were suitable for the risk(s) - Hazards in the workplace were evaluated and monitored

Conclusions and lessons learned: It is most important that the conclusions reached about risks are documented and that any supporting information on how that decision was made is included in associated records. Hazard Identification Training: Hazard Identification Training to workers and supervisors will consist of a combination of classroom instruction, computer-based training, and organized field reviews. These programs will be used to raise awareness with workers and supervisors, on what constitutes a process hazard and techniques for identifying these hazards at the jobsite. Drug and Alcohol Free Workplace Purpose City Construction, Inc. is dedicated to the protection of its employees from situations arising from substance abuse. To ensure that its workforce is productive, its facility is safe, and the success of its business is not hindered by substance abuse, City Construction, Inc. has established a Substance Abuse Program. At the same time, the program will promote morale and reduce absenteeism, accident potential, and health and workers' compensation insurance. Administrative Duties Our company's Substance Abuse Program Administrator is responsible for developing and maintaining the written substance Abuse Program. This person is solely responsible for all facets of the program and has full authority to make necessary decisions to ensure the success of this program. The Substance Abuse Program Administrator is also qualified via appropriate training and experience that is commensurate with the complexity of the program to administer or oversee it and conduct the required evaluations of program effectiveness. Company Policy Because our company is concerned about:

- Workplace safety, - Worker health, - Product quality, - Productivity, - Public liability, or - Regulatory compliance.

It is committed to a drug-and alcohol-free workplace. Our company substance abuse policy statement is as follows:

The possession, sale, or use of illegal drugs is inconsistent with the company's objective of operating in a safe and efficient manner. Accordingly, no officer, employee, agent, contractor, or visitor shall use or have in his or her possession illegal drugs during working hours or on company property at any time. Additionally, no officer, employee, agent, or contractor shall report to work while under the influence of alcohol or illegal drugs.

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The services of any employee who engages in such conduct will be subject to discipline up to and including discharge per vested authority. The only exception is the taking of prescribed drugs under the direction of a physician. The unlawful involvement with drugs or narcotics off company property will constitute grounds for severe disciplinary action, up to and including termination of employment. City Construction, Inc. will give each employee a copy of our drug-free workplace policy statement. If you have a substance abuse problem, it is your responsibility to seek and complete treatment. If you think someone you know (like a co-worker or a family member) has a drug problem, you could tell the person that based on what you've seen, you believe something is happening and it concerns you. Urge that person to get help. If nothing is done, that person could adversely affect the wellbeing of not only him herself, but you, your family, and the company. Drug and Alcohol Testing We retain the right to test our employees for alcohol and drugs according to the following guidelines:

- Testing of potential new hires for the presence of drugs will be required at the sole discretion of City Construction, Inc.’s management.

- Employees who exhibit through identification of abnormal job performance or behaviors which suggest that drug or alcohol abuse may be a factor, may be requested to test for the presence of alcohol of drug test.

- All employees will undergo unannounced drug testing based on a computerized random selection process. - Will involve any employee in an accident or contributing to an accident as defined in this policy. - All employees who receive some form of rehabilitation may be required to undergo a drug test.

If a test reveals a positive result, then the employee(s) will be subject to disciplinary action up to including termination of employment. Company-Sponsored Activities The Company prohibits the use of alcohol during company-sponsored activities. Supervisor Training Supervisors are the key to the success of our policy. As the people in direct contact with employees, supervisors can detect performance problems that may indicate substance abuse. Supervisors are responsible for:

- Observing and documenting unsatisfactory work performance or behavior; - Talking to employees about work problems and what needs to be done about them (i.e., contacting. the

Employee Assistance Program or local resources); and - Other responsibilities.

In order to carry out their responsibilities properly, supervisors must understand the substance abuse policy, be able to explain the policy to employees, and know when to take action. Our supervisors are not responsible for diagnosing substance abuse problems and treating substance abuse problems. Our supervisors are trained to observe employees' job performance noting the following items:

- Physical signs: Unusual clumsiness and frequent illness;

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- Mood: Unusually lighthearted one day and depressed the next; - Absenteeism: More than usual; - Actions: Violent reactions when things go wrong or when upset; - Accidents: Increased number of accidents; and - Relationships: Easily irritated by others; would prefer being left alone rather than interacting with other

employees. - Other training topics we cover with our supervisors include the following: - Information on specific drugs, - Methods of detecting drug and alcohol use, - Insurance coverage for substance abuse treatment - Prevention and education strategies, and - Background on drug testing issues and how the drug testing program relates to the EAP.

The company training program uses classroom instruction that uses lectures, discussions, videotapes, and/or conference formats. The Human Resources Department is responsible for providing supervisor training. The Human Resource Director and/or RSO are responsible for conducting the training. Employee Education and Awareness Our employees must understand and remain aware of our ongoing commitment to a drug-free workplace. All new and current employees must successfully complete City Construction, Inc.'s Employee Education and Awareness Program. The Human Resource Department will identify when each employee will receive retraining. The Human Resources Department and/or RSO are responsible for conducting this training. The company training program uses Classroom instruction including lecture, discussion, videotape, and/or conferences. Through training, City Construction, Inc. ensures that employees are knowledgeable in the following: Dangers of drug abuse,

- Our drug-free workplace policy, - The availability of any drug counseling programs, - The possible penalties for drug abuse violations occurring in the workplace, - Your company's EAP and its services, - How drugs and alcohol actually affect the company and the employee including productivity, - Product quality, - Absenteeism, - Health care costs and/or accident rates, - Testing procedures, - Health effects of alcohol and drugs, - How drugs affect the community, - Illegal drugs (what they look like, how they are used, their effects), - The symptoms of overdose and withdrawal, - How the use of alcohol and drugs can influence their children's behavior, - How to help others avoid involvement in substance abuse, and - How to recognize the signs of substance abuse.

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Recordkeeping Human Resource Department is responsible for maintaining all records and documentation related to employee training and testing. Conviction Notification City Construction, Inc. will ensure that the contracting agency is notified within 10 days after receiving notice that an employee has been convicted of violating any criminal drug statute. Employee Sanction City Construction, Inc. will ensure that any employee who is convicted of violating any criminal drug statute, will have sanctions imposed or will be required to satisfactorily participate in a drug abuse assistance or rehabilitation program.

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Workplace Violence Prevention Company Policy Our establishment, City Construction, Inc. is committed to our employees' safety and health. We refuse to tolerate any form of violence in the workplace and will make every effort to prevent violent incidents from occurring by implementing a Workplace Violence Prevention Program. (WVPP). We will provide adequate authority and budgetary resources to responsible parties so that our goals and responsibilities can be met. All managers, supervisors and employees are responsible for implementing and maintaining our WVPP Program. We encourage employee participation in designing and implementing our program. We require prompt and accurate reporting of all violent incidents whether or not physical injury has occurred. We will not discriminate against victims of workplace violence. A copy of this policy statement and WVPP Plan is readily available to all employees and from each manager and supervisor. Our plan ensures that all employees, including supervisors and managers, adhere to work practices that are designed to make the workplace more secure, and do not engage in verbal threats or physical actions which create a security hazard for others in the workplace. All employees, including managers and supervisors, are responsible and accountable for using safe work practices, for following all directives, policies and procedures, and for assisting in maintaining a safe and secure work environment. The management of our establishment is responsible for ensuring that all safety and health policies and procedures involving workplace security are clearly communicated and understood by all employees. Managers and supervisors are expected to enforce the rules fairly and uniformly. The WVPP Plan will be reviewed and updated annually. Responsibility and Accountability The Workplace Violence Prevention Program Administrator has the authority and responsibility for implementing the provisions of this program for City Construction, Inc. All managers, supervisors and employees are responsible for implementing and maintaining the WVPP in their work areas and for answering employee questions about the program. In addition, a WVPP Planning Group will be established to assess the vulnerability to workplace violence at our establishment and reach agreement on preventive actions to be taken. This group will be responsible for developing employee training programs in violence prevention and plans for responding to acts of violence. They will also audit our overall Workplace Violence Prevention Program. The Workplace Violence Prevention Group will consist of: Compliance All employees are responsible and will be held accountable for using safe work practices, for following all directives, policies and procedures, and for assisting in maintaining a safe and secure work environment. Managers, supervisors and employees will comply with work practices that are designed to make the workplace more secure, and will not engage in threats or physical actions which create a security hazard for others in the workplace. Managers and supervisors will:

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- Inform employees, supervisors and managers about our Workplace Violence Prevention Program. - Evaluate the performance of all employees in complying with our establishment's workplace security

measures. - Recognize employees who perform work practices which promote security in the workplace. - Provide training and/or counseling to employees who need to improve work practices designed to ensure

workplace security. - Discipline employees for failure to comply with workplace security practices. - Follow established workplace security directives, policies and procedures.

Managers and supervisors will maintain an open, two-way communications system on all workplace safety, health and security issues. Our establishment has a communication system designed to encourage a continuous flow of safety, health and security information between management and our employees without fear of reprisal and in a form that is readily understandable. Our communication system consists of the following items:

- New employee orientation on our establishment's workplace security policies, procedures and work practices. - Periodic review of our Workplace Violence Prevention Program with all personnel. - Training programs designed to address specific aspects of workplace security unique to our establishment. - Regularly scheduled safety meetings with all personnel that include workplace security discussions. - A system to ensure that all employees, including managers and supervisors, understand the workplace

security policies. - Posted or distributed workplace security information. - A system for employees to inform management about workplace security hazards or threats of violence. - Procedures for protecting employees who report threats from retaliation by the person making the threats.

Hazard Assessment The Workplace Violence Prevention Group will perform workplace hazard assessment for workplace security in the form of record keeping and review, and periodic workplace security inspections. The assessment group will identify workplace violence and security issues and make recommendations to management and employees. Recordkeeping and Review Note: Care must be taken to ensure appropriate confidentiality of medical and personnel records, as required by State Administrative Rules, The ADA (Americans with Disabilities Act) and other applicable regulations or policies. Periodic updates and reviews of the following workplace violence reports and records will be made:

- Occupational Safety and Health Administration (OSHA) 300 logs - Workplace violence incident reports - Information compiled for recording assault incidents or near-assault incidents (i.e. Threat & Assault Log) - Insurance records - Police reports - Accident investigations - Training records - Grievances - Inspection information - Other relevant records or information

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The records review annually, except for training records of employees who have worked for less than one year which are provided to the worker upon termination of employment. OSHA 300 Logs are reviewed and maintained per applicable OSHA requirements.

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Lockout/Tagout Procedures Purpose The following procedure is provided for use in both lockout and tagout programs. This procedure may be used when there is limited number or types of machines or there is a single power source. For more complex systems, a more comprehensive procedure will need to be developed, documented, and utilized. Lockout is the preferred method of isolating machines or equipment from energy sources. This procedure establishes the minimum requirements for the lockout of energy isolating devices whenever maintenance or servicing is done on machines or equipment. It shall be used to ensure that the machine or equipment is stopped, isolated from all potentially hazardous energy sources, and locked out before employees perform any servicing or maintenance where the unexpected energization or start-up of the machine or equipment or release of stored energy could cause injury such as minor to serious shock, bums (chemical or thermal), cuts, or abrasions. Administrative Duties Dennis Fallon has overall responsibility for coordinating safety and health programs in this company. He is the person having overall responsibility for the Lockout/Tagout Program. Dennis Fallon will review and update the program, as necessary. Copies of the written program may be obtained in the RSO's office. All employees are required to comply with the restrictions and limitations imposed upon them during the, use of lockout. The authorized employees are required to perform the lockout in accordance with this procedure. Servicing is to be done only by trained, authorized employees. Each new or transferred affected employee and other employees whose work operations are or may be in the area shall be instructed in the purpose and use of the lockout or tagout procedures. All employees, upon observing a machine or piece of equipment which is locked out to perform servicing or maintenance, shall not attempt to start, energize, or use the machine or equipment. Contractors are required to utilize this company's procedure except when the contractor can demonstrate that their current lockout procedure affords the same level of safety as City Construction, Inc. procedure. Basic Rules for Using Lockout or Tagout System Procedure All equipment shall be locked out or tagged out to protect against accidental or inadvertent operations when such operations could cause injury to personnel. Do not attempt to operate any switch, valve, or other energy-isolating device where it is locked or tagged out. This standard does not apply to work on cord and plug connected to electrical equipment for which exposure to the hazards of unexpected energization or start up the equipment is controlled by the unplugging of the equipment from the energy source and by the plug being under the exclusive control of the employee performing the servicing or maintenance. In the event a piece of equipment is to be isolated for a period of time exceeding one normal shift and the ~ isolating means is not capable of being locked out, a reasonable effort will be made to affix a device to the isolating means to make capable of being locked out. Lockout-Tagout protects workers from these energy sources:

- moving machinery (kinetic) - stored energy (potential) - electrical - chemical - thermal - hydraulic

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- gravitational - pneumatic

Definitions Authorized (Qualified) Employees - The only ones certified to lock and tagout equipment or machinery. 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 duties safely at his or her level of training and who is under the direct supervision of a qualified person, is considered to be "qualified" for the performance of those duties. Affected Employees - Those employees who operate machinery or equipment upon which lockout 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. Other Employees - Identified as those that do not fall into the authorized, affected or qualified employee category. Essentially, it will include all other employees. These employees will be provided instruction in what the program is and not to touch any machine or equipment when they see that it has been locked or tagged out. Machinery and Equipment - Lockout is the preferred method of isolating machines or equipment from energy sources. Tagout is to be performed instead of lockout only when there is no way to lockout a machine. Routine Maintenance & Machine Adjustments – Lockout/tagout procedures are not required if equipment must be operating for proper adjustment. This rare exception may be used only by trained and authorized Employees when specific procedures have been developed to safely avoid hazards with proper training. All consideration 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. 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 issues 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 equipment and machinery. Additional locks may be checked out from the Department or Maintenance Supervisor on a shift-by-shift basis. All locks and hasps shall be uniquely identifiable to a specific employee. Preparation for Lock and Tag Out Procedures A Lockout/Tagout survey has been conducted to locate and identify all energy sources to verify which switches or valves supply energy to machinery and equipment. Dual or redundant controls have been removed. A Tagout Schedule has been developed for each piece of equipment and machinery. This schedule describes the energy sources, location of disconnects, type of disconnect, special hazards and special safety procedures. The schedule will be reviewed each time to ensure employees properly lock and tag out equipment and machinery. If a Tagout Schedule does not exist for a particular piece of equipment, machinery and process, one must be developed prior to conducting a Lockout -Tagout. As repairs and/or renovations of existing electrical systems are made, standardized controls will be used. Sequence of Lockout System Procedure

1. Lockout locks cannot be used for any purpose other than lockout, and must meet the following provisions: a. Standardized throughout the plant by color, shape or size.

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b. Durable enough to withstand heat, cold, humidity or corrosiveness. c. Strong enough so that it cannot be removed without heavy force or tools such as bolt cutters. d. Identified by the name of the employee who installs and removes it.

2. The authorized employee (one who performs maintenance or servicing) shall identify the type and magnitude of the energy that the machine or equipment utilizes, shall understand the hazards of the energy, and shall know the methods to control the energy.

3. The authorized employee is to notify all affected employees that servicing or maintenance is required on a machine or equipment and that the machine or equipment must be shut down and locked out to perform the servicing or maintenance.

4. If the machine or equipment is operating, shut it down by the normal stopping procedure (depress stop button, open switch, close valve, etc.).

5. De-activate the energy isolating device(s) so that the machine or equipment is isolated from the energy source(s).

6. Stored or residual energy (such as that in capacitors, springs, elevated machine members, rotating flywheels, hydraulic systems, and air, gas, steam, or water pressure, etc.) must be dissipated or restrained by methods such as grounding, repositioning, blocking, bleeding down, etc.

7. Lockout the energy isolating devices with a lock(s). 8. Ensure that the equipment is disconnected from the energy source(s) by first checking that no personnel

are exposed, and then verify the isolation of the equipment by operating the push button or other normal operating control(s), or by testing to make certain the equipment will not operate.

9. CAUTION: RETURN OPERATING CONTROL(S) TO NEUTRAL OR "OFF" POSITION AFTER VERIFYING THE ISOLATION OF THE EQUIPMENT.

10. The machine or equipment is now locked out. Maintenance or servicing may be performed. Sequence of Tagout System Procedure The authorized employee shall use the tagout procedure ONLY WHEN THE MACHINE OR EQUIPMENT IS NOT CAPABLE OFBEINGLOCKED OUT.

1. The tagout device shall be standardized throughout the plant, and shall meet the following provisions: a. Easy to read and understand, even infused in dirty, corrosive, or damp areas. b. Can't be released with less than 50 pounds of pressure. c. Can be attached by hand. d. Is self-locking. e. Shows the identity of the authorized employee. £ Can't be reused.

2. The tagout device shall be attached at the same location that the lockout device would have been attached. 3. Authorized employees shall utilize additional means as necessary to provide the equivalent safety available

from the use of a lockout device. Additional safety measures that reduce the likelihood of inadvertent energization may include:

a. The removal of an isolating circuit element; b. Blocking of a controlling switch; c. Opening of an extra disconnecting device; or d. The removal of a valve handle.

Restoring Machines/Equipment to Normal Production Operations

1. When the servicing is completed and the equipment is ready to return to normal operating condition, the following steps shall be taken:

2. Check the work area to ensure that all employees are a safe distance from the equipment.

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3. Check the machine or equipment and the immediate area around the machine or equipment to ensure that nonessential items (such as tools) have been removed, and that the machine or equipment components are operationally intact.

4. Reinstall any machine guards. 5. Verify that the controls are in neutral. 6. Remove the lockout and/or tagout devices and reenergize the machine or equipment. 7. Notify affected employees that the servicing or maintenance is completed and the machine or equipment is

ready for use. NOTE: The removal of some forms of blocking may require re-energization of the machine before safe removal. When maintenance or service is done, only the same authorized employee who installed the lock may remove it. When the authorized employee is not available to remove the lock, a "Lockout Removal" form must be completed by the employee removing the lock (see attachment Procedure for Lockout & Tagout Removal). Temporary Removal Occasionally, lockout/tagout devices must be temporarily removed in order to test the equipment or machine. When this occurs the following steps should be taken:

1. Clear away any tools from the danger area. 2. Remove any employees from the danger area. 3. Remove the lockout/tagout device(s). 4. Carefully re-energize and proceed with testing. 5. De-energize and reapply lockout/tagout device(s) following the sequence of lockout/tagout procedures

listed above. 6. Document the name and title of the individual(s) who performs and verifies this process.

Procedure Involving More Than One Person In the preceding steps, if more than one individual is required to lockout or tagout equipment, each shall place his or her own personal lockout or tagout device on the energy isolating device(s). When an energy-isolating device cannot accept multiple locks or tags, a multiple lockout or tagout device (hasp) may be used. If lockout is used, a single lock may be used to lockout the machine or equipment with the key being placed in a lockout box or cabinet which allows the multiple locks to secure it. Each employee will then use his or her own lock to secure the box or cabinet. As a person no longer needs to maintain his or her lockout protection, that person will remove his or her lock from the box or cabinet. If a single authorized employee is given the primary responsibility for a set number of employees working under the protection of a group lockout or tagout device then the following safety measures must be adhered to: Authorized employee must ascertain the exposure status of individual group members. Each employee shall attach a personal lockout/tagout device to the group's device while he/she is working. The device shall be removed when finished. Stored Energy Following the application of the lockout or tagout devices to the energy isolating devices, all potential or residual energy will be relieved, disconnected, restrained, and otherwise rendered safe. Where the re-accumulation of stored energy to a hazardous energy level is possible, verification of isolation will be continued until the maintenance or servicing is complete. Release stored energy (capacitors, springs, elevated members, rotating fly wheels, and hydraulic/air/gas/steam systems) must be relieved or restrained by grounding, repositioning, blocking and/or bleeding the system.

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Extended Lockout/Tagout Should the shift change before the machinery or equipment can be restored to service, the lock and tag out must remain. If the task is reassigned to the next shift, those Employees must lock and tag out before the previous shift may remove their lock and tag. Procedure for Electrical Plug-Type Equipment This procedure covers all Electrical Plug-Type Equipment such as Battery Chargers, some Product Pumps, Office Equipment, Powered Hand Tools, Powered Bench Tools, Lathes, Fans, etc. When working on, repairing, or adjusting the above equipment, the following procedures must be utilized to prevent accidental or sudden startup:

1. Unplug Electrical Equipment from wall socket or in-line socket. 2. Attach "Do Not Operate" Tag and Plug Box & Lock on end of power cord. 3. An exception is granted to not lock & tag the plug is the cord & plug remain in the exclusive control of the

Employee working on, adjusting or inspecting the equipment. 4. Test Equipment to assure power source has been removed by depressing the "Start" or On" Switch. 5. Perform required operations. 6. Replace all guards removed. 7. Remove Lock & Plug Box and Tag. 8. Inspect power cord and socket before plugging equipment into power source. Any defects must be repaired

before placing the equipment back in service. NOTE: Occasionally used equipment may be unplugged from power source when not in use. Management's Removal of Lock and Tag Out Only the Employee that locks and tags out machinery, equipment or processes may remove his/her lock and tag. However, should the Employee leave the facility before removing his/her 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. Notification of the employee who placed the lock is required prior to lock removal. This process must be properly documented. Additional State Requirements Some states include required procedures for equipment that needs to have power supplied to them for repair, adjust, test, or set up activities, including the following:

- A qualified operator must control the activities, - The operator must be in clear view and clear communication with all participants, - Participants must be beyond the reach of machine elements, and - Locking out equipment if machines require the operator to leave the control station. - De-energizing machines at their power sources during adjustment or replacement of machine components. - Outside contractors must use the host employer's LOTO procedures.

Training Authorized Employees Training

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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 time of initial hire. Retraining shall be held at least annually or when there is a change in job assignments, in machines, a change in the energy control procedures or a new hazard is introduced. The training will consist of the following: Review of General Procedures Review of Specific Procedures for machinery, equipment and processes Location and use of Specific Procedures when questions arise. Affected Employee Training 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. Other Employee Training Only trained and authorized Employees will repair, replace or adjust machinery or Equipment. Other Employees may not remove Locks, locking devices or tags from machinery, equipment or circuits Documentation Procedural steps for lockout/tagout for all machines shall be documented on the Lockout/Tagout Schedule form. A copy of this form will be given to the authorized employee and will be kept in the Safety Coordinator's office. Documentation of employee training shall be kept on file in each employee's training file. An inspection shall be performed, certified and documented annually, under the direction of the RSO, to assure compliance with the written program. This will be kept in the RSO's office. The purpose is to ensure that the written procedures and the requirements of the standard are being followed, and that employees understand their responsibilities under the procedures. Affected Employees for Lockout/Tagout Because people may be moved from one work area to another, it would not be appropriate or practical to generate a list of people identified with a particular area. Therefore, the person who initiates, or terminates, a lockout or tagout procedure will notify those persons in the affected area. Periodic Inspection A periodic inspection is done, looking at the energy control procedures performed to ensure that the procedure and requirements of the standard are being followed. This inspection is performed annually.

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Aerial & Scissor Lift Safety Program

Purpose According to NIOSH, about 26 construction workers die each year from using aerial lifts. More than half of the deaths involve boom-supported lifts, such as bucket trucks and cherry pickers; most of the other deaths involve scissor lifts. Electrocutions, falls, and tip overs cause most of the deaths. Other causes include being caught between the lift bucket or guardrail and object (such as steel beams or joists) and being struck by falling objects. (A worker can also be catapulted out of a bucket, if the boom or bucket is struck by something.)

The purpose of this program is to outline policies and procedures for the safe operations of scissors lift and aerial lifts operated by City Construction, Inc. employees. It applies to all operations, programs and locations that require employees to access elevated locations and/or use aerial work platforms; in particular steel erection and inspection.

Administrative Duties Dennis Fallon, RSO is our Aerial & Scissors Lift Operation Program Coordinator, who has overall responsibility for the plan. Copies of this written program may be obtained from the RSO's office.

Definitions Aerial Lift -A piece of equipment, extendable and/or articulating, designed to position personnel and/or materials in elevated locations. Aerial lifts include the following types of vehicle-mounted aerial devices used to elevate personnel to job-sites above ground:

- Extensible boom platforms; - Aerial ladders; - Articulating boom platforms; - Bucket Trucks; - Vertical towers; and - A combination of any such devices. Aerial equipment may be made of metal, wood, fiberglass reinforced

plastic (FRP), or other material; may be powered or manually operated; and are deemed to be aerial lifts whether or not they are capable of rotating about a substantially vertical axis.

ANSI American National Standards Institute.

Lanyard -ANSI approved line designed for supporting one person, with one end connected to a safety harness and the other end attached to a suitable anchorage able to support 5,400 pounds of force. The anchorage can be a structural steel member, an approved lifeline, or other approved anchorage points.

Full Body Harness ANSI approved body device designed for fall protection, which by reason of its attachment to a lanyard and safety line or an approved anchorage point, which will limit a fall to six (6) feet or less.

Fall Protection

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Full body harnesses and lanyards shall only be used, as intended by the manufacturer, for employee fall protection. Appropriate devices shall be used to provide 100% fall protection. The “D" ring on the body harness shall be positioned in the back up between the shoulder blades to minimize impact forces of the body in the event of a fall.

NOTE: Body belts are NOT acceptable as part of a personal fall arrest system

All fall protection equipment shall be carefully inspected prior to each use and periodically throughout the day, Safety equipment showing any signs of mildew, tom or frayed fabric or fiber, bums, excessive wear, or other damage or deterioration which could cause failure shall be permanently removed from service. All fall protection equipment shall be properly maintained and stored when not in use. This includes keeping dry and out of sunlight, away from caustics, corrosives or other materials that could cause defects.

Hard hats and safety harnesses shall be worn by employees in the bucket or platform of any aerial lift device. Other safety personal protective items may be required by either company or client safety policies. High visibility clothing is NOT required for employees, but it is recommended while working in the air.

Consideration must be given to water hazards and appropriate precautions. When 100% fall protection is employed, OSHA water safety standards are not mandated. However it is advisable to take minimum precautions such as readily available buoy and safety line, and a rescue boat. Equipment Aerial lift devices shall conform to ANSI Standards applicable to the type of equipment being used bucket truck, under-bridge inspection vehicle, portable and/or self-propelled personnel lift. Aerial lift devices shall only be used for the purpose(s) intended by the manufacturer. All manufacturer and maintenance department recommendations and warnings regarding operation, capacity and safety precautions shall be strictly followed. Permanent labeling must be conspicuously posted to indicate lifting capacity and travel height. All aerial lift devices shall have an audible back-up alarm or use an observer to alert other people in the area when moving in the reverse direction (backing up). Aerial lifts may be "field modified" for uses other than those intended by the manufacturer provided the modification has been certified in writing by the manufacturer or by any other equivalent entity, such as a nationally recognized testing laboratory, to be in conformity with all applicable provisions of ANSI A92.2-1969 and this section and to be at least as safe as the equipment was before modification.

Only devices approved for lifting personnel shall be used as aerial lifts. Loaders, forklifts or other material lift devices shall NOT be used to transport employees to elevated locations nor as work platforms. Forklifts and cranes may ONLY be used as a last resort, and then only with approved personnel baskets. Modifications shall not be made to any aerial lift device without the expressed written authorization from the manufacturer. Buckets and bucket liners shall not be drilled, cut, welded on, etc.

Procedures Lift equipment shall be inspected upon delivery to the jobsite, and daily prior to use. The daily inspection will include testing the controls prior to use and all inspections shall be documented on the Aerial Lift Daily Inspection form. Before extending or raising the boom or platform, outriggers (if so equipped), shall be positioned properly and the lift will be level. Outriggers shall be placed on mud mats or other SOLID surface, and shall not be used to level the vehicle. If the lift is on unleveled ground, the wheels shall be chocked and the parking brake set. Sufficient

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clearance shall be checked before raising the lift. For under-bridge units, adequate clearance beneath the boom shall be assured. Employees shall keep both feet on the floor of the bucket or platform at all times. When the lift has to be moved, it shall only be moved when the bucket or platform is at the lowered position. For scissor lifts, this is lowered all the way down, and for aerial lifts, this is lowered to the lowest point that the operator can safely see to drive the vehicle. Employees are required to wear full body safety harnesses with lanyards. The lanyards shall be attached to an engineered anchorage point inside the lift. Do not wrap the lanyard around a rail and tie back onto itself. Employees are not to anchor on structural members outside of the lift, unless exiting the lift to get on the structural members. Platform lifts (scissors lifts) shall have a top and mid rail and a kick plate (toe board), along with an engineered anchorage point to tie off. Employees shall not climb nor stand on the mid or top rails, keeping both feet on the floor of the platform.

Tools, parts or any materials shall not be dropped or thrown from the bucket or platform. When using welding or heating equipment from the bucket or platform, the vehicle shall be protected from sparks and slag and special care shall be taken to remove flammable objects away from the lifts.

Electrical Safety When working near electrical lines or equipment, avoid direct or indirect contact. Direct contact is body contact. Indirect contact is when the body touches or is in dangerous proximity to any object that is in contact with energized systems. Always assume lines are "live" and carry high voltage. Electrical lines can only be considered "dead" when verified by licensed electricians from the utilities department, and proper lockout and tagout has been performed.

Employees shall not position any aerial lifts closer than ten (I 0) feet to a power line that carry up to fifty (50) kilovolts. For each kilovolt over 50, add four (4) inches. Employees are to be trained concerning the hazards and precautions of working near power lines. Ensure posted warning placards are in place concerning electrical lines.

If the operator is unable to assess the clearances while operating the aerial lift, then a "spotter" must be used to observe the clearances and warn the operator.

Specific requirements Ladder trucks and tower trucks with aerial ladders shall be secured in the lower traveling position by the locking device on top of the truck cab, and the manually operated device at the base of the ladder before the truck is moved for highway travel.

- Extensible and articulating boom platforms. - Lift controls shall be tested each day prior to use to determine that such controls are in safe working

condition. - Only authorized persons shall operate an aerial lift. - Belting off to an adjacent pole, structure, or equipment while working from an aerial lift shall not be

permitted. - 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 position.

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- A body belt shall be worn and a lanyard attached to the boom or basket when working from an aerial lift. - Boom and basket load limits specified by the manufacturer shall not be exceeded. - The brakes shall be set and when outriggers are used, they shall be positioned on pads or a solid surface.

Wheel chocks shall be installed before using an aerial lift on an incline provided they can be safely installed.

- An aerial lift truck shall not be moved when the boom is elevated in a working position with men in the basket, except for equipment which is specifically designed for this type of operation in accordance with the provisions of paragraphs of 1926.453.

- Articulating boom and extensible boom platforms, primarily designed as personnel carriers, shall have both platform (upper) and lower controls. Upper controls shall be in or beside the platform within easy reach of the operator. Lower controls shall provide for overriding the upper controls. Controls shall be plainly marked as to their function. Lower level controls shall not be operated unless permission has been obtained from the employee in the lift, except in case of emergency.

- Climbers shall not be worn while performing work from an aerial lift. - The insulated portion of an aerial lift shall not be altered in any manner that might reduce its insulating

value. - Before moving an aerial lift for travel, the boom(s) shall be inspected to see that it is properly cradled and

outriggers are in stowed position except as provided in paragraph (b) (2) (viii) of 1926.453. - Electrical tests. All electrical tests shall conform to the requirements of ANSI A92.2-1969 section 5.

However equivalent DC voltage tests may be used in lieu of the AC voltage specified in A92.2-1969; DC voltage tests which are approved by the equipment manufacturer or equivalent entity shall be considered an equivalent test for the purpose of this paragraph (b)(3) of 1926.453.

- Bursting safety factor. The provisions of the American National Standards Institute standard ANSI A92.2-1969, section 4.9 Bursting Safety Factor shall apply to all critical hydraulic and pneumatic components. Critical components are those in which a failure would result in a free fall or free rotation of the boom. All noncritical components shall have a bursting safety factor oft least 2 to 1.

- Welding standards. All welding shall conform to the following standards as applicable: o Standard Qualification Procedure, AWS B3.0-41. o Recommended Practices for Automotive Welding Design, AWS D8.4-61. o Standard Qualification of Welding Procedures and Welders for Piping and Tubing, AWS D10.9-69. o Specifications for Welding Highway and Railway Bridges, A WS D2.0-69.

Training The RSO will identify all new employees in the employee orientation program and make arrangements with department management to schedule training. Before we begin training a new employee, our Aerial & Scissors Lift Program Administrator, Dennis Fallon and/or the Area Supervisor, determines if the potential lift operator is capable of performing the duties necessary to be a competent and safe operator. This is based upon his/her physical and mental abilities to perform job functions that are essential to the operation of the lift.

These capabilities include the level at which the operator must:

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- See and hear within reasonably acceptable limits, (this includes the ability to see at a distance end peripherally, and in certain instances, it is also necessary for the operator to discern different colors, primarily red, yellow, and green);

- Endure the physical demands of the job; and endure the environmental extremes of the job, such as the ability of the person to work in areas of excessive cold or heat. An operator must be able to climb onto and off of a lift, and to stand in the lift for extended periods of time.

- Once our Administrator determines that a potential operator is capable of performing aerial and scissor lift duties, the following person(s) will conduct initial training and evaluation: RSO and/or Area Supervisors. These instructor(s) have the necessary knowledge, training, and experience to train new aerial lift operators.

- Retraining shall be accomplished annually or when an employee shows a lack of understanding of aerial lift safe operating procedures.

Ladder Safety Purpose City Construction, Inc. understands that ladders present unique opportunities for unsafe acts and unsafe conditions. Employees who use ladders must be trained in proper selection, inspection, use and storage. Improper use of ladders has cause a large percentage of accidents in the workplace are of accidents. Use caution on ladders, Hazards Falls from ladders can result in broken bones, crippling injuries and death. Ladder safety is taken very seriously by our company. Ladder hazards include:

- Ladders with missing or broken parts. - Using a ladder with too low of a weight rating. - Using a ladder that is too short for purpose. - Using metal ladders near electrical wires. - Using ladders as a working platform. - Objects falling from ladders.

Inspections

- Inspect ladders before each use: - All rungs and steps are free of oil, grease, dirt, etc. - All fittings are tight. - Spreaders or other locking devices are in place. - Non-skid safety feet are in place. - No structural defects, all support braces intact. - Do not use broken ladders. - Ladder rungs must be uniformly spaced. - Most ladders cannot be repaired to manufacturer specifications. - Broken ladders should be tagged and placed out of service.

Storage

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Store ladders on sturdy hooks in areas where they cannot be damaged. Store to prevent warping or sagging. Do not hang anything on ladders that are in a stored condition. Ratings & Limits Ladder weight ratings I-A 300 pounds (heavy duty) I 250 pounds (heavy duty) II 225 pounds (medium duty) III 200 pounds (light duty). Limits on ladder Height. A stepladder should be no more than 20 feet high. A one-section ladder should be no more than 30 feet. An extension ladder can go to 60 feet, but the sections must overlap. Ladder Setup

- The following procedure must be followed to prevent ladder accidents: - Place ladder on a clean slip free level surface. - Extend the ladder to have about 4 feet above the top support or work area. - Anchor the top and bottom of the ladder. - Place the ladder base 1/4 the height, of the ladder, from the wall when using an extension ladder. - Never allow more than one person on a ladder. - Use carriers and tool belts to carry objects up a ladder. - Do not lean out from the ladder in any direction. If you have a fear of heights -don't climb a ladder. - Do not allow other to work under a ladder in use.

Maintenance

- Keep ladders clean. - Never replace broken parts unless provided by the original manufacturer. - Do not attempt to repair broken side rails. - Keep all threaded fasteners properly adjusted. - Replace worn steps with parts from manufacturer.

Additional State Requirements

- Safety requirements for portable wood ladders placed in service after April 18, 1999 have to meet the requirements of ANSI A14.1-1994, which is incorporated by reference. Safety requirements for portable wood ladders placed in service on or before April 17, 1999, are based on the ANSI A14.1 provisions in effect at the time such ladders were placed in service.

- Cleat Ladders longer than 30 feet cannot be used. - The wood side rails of ladders having cleat steps cannot be less than 1-1/2 inches thick and 3-1/2 inches

deep (2 by 4 inches nominal). - Wood cleats need to be inset into side rails not less than 1/2 inch or attached directly to the edge of the

side rails. Filler blocks of the thickness of the cleats need to be securely attached to the edge of the rail for the full length between cleats, or equivalent construction. The cleats need to be fastened to each rail by three 10-d wire nails or equivalent.

- The cleats on a double cleat ladder must extend the full width of the ladder. - Extra requirements for portable metal ladders include the following:

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- Cross-bracing on the rear section of stepladders cannot be used for climbing unless the ladders are designed and provided with steps for climbing on both front and rear sections.

- These ladders cannot be used near electrical circuits if there is a risk of coming in contact with the circuits. The ladders need to be legibly marked with "CAUTION Do Not Use around Electrical Equipment" or equivalent.

Extra requirements for fixed ladders include the following: If materials other than steel, aluminum, and wood are used, they must meet the design, fabrication, and erection requirements. Wood ladders may be coated with a clear sealant after inspection. Personal Protective Equipment Purpose The City Construction, Inc. provides all Employees with required PPE to suit the task and known hazards. This Chapter covers the requirements for Personal Protective Equipment with the exception of PPE used for hearing conservation and respiratory protection or PPE required for hazardous material response to spills or releases, which if applicable are covered under separate programs. The Dennis Fallon, RSO is the program coordinator, acting as the representative of the plant manager, who has overall responsibility for the program. The RSO will designate appropriate plant supervisors to assist in training employees and monitoring their use of PPE. This written plan is kept in the RSO's office. Then he/she will review and update the program as necessary. Copies of this program may be obtained from the RSO's office. We at City Construction, Inc. believe it is our obligation to provide a hazard free environment to our employees. Any employee encountering hazardous conditions must be protected against the potential hazards. The purpose of protective clothing and equipment (PPE) is to shield or isolate individuals from chemical, physical, biological, or other hazards that may be present in the workplace. Establishing an overall written PPE program detailing how employees use PPE makes it easier to ensure that they use PPE properly in the workplace and document our PPE efforts in the event of an OSHA inspection. City Construction, Inc.'s PPE program covers:

- Purpose - Hazard assessment - PPE selection - Employee training - Cleaning and maintenance of PPE - PPE specific information

If after reading this program, you find that improvements can be made, please contact the RSO, Dennis Fallon. We encourage all suggestions because we are committed to the success of our Personal Protective Equipment Program. We strive for clear understanding, safe behavior, and involvement in the program from every level of the company.

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General Policy Engineering controls shall be the primary methods used to eliminate or minimize hazard exposure in the workplace. When such controls are not practical or applicable, personal protective equipment shall be employed to reduce or eliminate personnel exposure to hazards. Personal protective equipment (PPE) will be provided, used, and maintained when it has been determined that its use is required and that such use will lessen the likelihood of occupational injuries and/or illnesses. All employees owned PPE is prohibited to be used at City Construction, Inc. Responsibilities The RSO will be responsible for assessing the hazards and exposures that may require the use of PPE, determining the type of equipment to be provided, and purchasing the equipment. Input from managers, supervisors, and employees will be obtained and considered in selecting appropriate equipment. Managers/supervisors will be responsible for training employees in the use and proper care of PPE, ensuring that all employees are assigned appropriate PPE, and ensuring that PPE is worn by employees when and where it is required. Employees are responsible for following all provisions of this program and related procedures. They are expected to wear PPE when and where it is required. Hazard Assessment The Company will perform an assessment of the workplace to determine if hazards are present, or likely to be present, which necessitate the use of personal protective equipment (PPE). This assessment will consist of a survey of the workplace to identify sources of hazards to workers. Consideration will be given to hazards such as impact, penetration, laceration, compression (dropping heavy objects on foot, roll-over, etc.), chemical exposures, harmful dust, heat, light (optical) radiation, electrical hazards, noise, etc. Where such hazards are present, or likely to be present, the Company will:

- Select, and have each affected Employee use, the proper PPE - Communicate selection decisions to each affected Employee - Select PPE that properly fits each affected employee. - Train employees in the use and care of PPE as described elsewhere in this program

The Company will verify that the workplace hazard assessment has been performed by conducting a written certification. This certification will be dated and signed by the RSO or person conducting the assessment. Whenever there is a change in process or in the workplace that might introduce or change an exposure or hazard, the company will perform an assessment to determine if there needs to be additional PPE or a change in the PPE provided. These supplemental hazard assessments will also be documented, signed and dated by the person performing the assessment. The Company will review and update the workplace hazard assessment on an annual basis. Sources During the walk-through survey the RSO should observe:

- Sources of motion; i.e., machinery or processes where any movement of tools, machine elements or particles could exist, or movement of personnel that could result in collision with stationary objects;

- Sources of high temperatures that could result in bums, eye injury or ignition of protective equipment, etc.; - Types of chemical exposures; sources of harmful dust; - Sources of light radiation, i.e., welding, brazing, cutting, furnaces, heat treating, high intensity lights, etc.;

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- Sources of falling objects or potential for dropping objects; sources of sharp objects which might pierce the feet or cut the hands;

- Sources of rolling or pinching objects which could crush the feet; - Layout of workplace and location of co-workers; and any electrical hazards. - In addition, injury/accident data should be reviewed to help identify problem areas.

Organize Data Following the walk-through survey, it is necessary to organize the data and information for use in the assessment of hazards. The objective is to prepare for an analysis of the hazards in the environment to enable proper selection of protective equipment. Analyze Data Having gathered and organized data on a workplace, an estimate of the potential for injuries should be made. Each of the basic hazards should be reviewed and a determination made as to the type, level of risk, and seriousness of potential injury from each of the hazards found in the area. The possibility of exposure to several hazards simultaneously should be considered. Controlling Hazards PPE devices alone should not be relied on to provide protection against hazards, but should be used in conjunction with guards, engineering controls, and sound manufacturing practices. Assessment and Selection

- It is necessary to consider certain general guidelines for assessing the foot, head, eye and face, and hand hazard situations that exist in an occupational or educational operation or process, and to match the protective devices to the particular hazard. It should be the responsibility of the RSO to exercise common sense and appropriate expertise to accomplish these tasks. Personal protective equipment will meet the following standards:

- Eye & Face Protection devices -ANSI Z87.1-1989 "American National Standard Practice for Occupational and Educational Eye and Face Protection"

- Head Protection devices -ANSI Z89.1-1986 "American National Standard for Personal Protection -Protective Headwear for Industrial Workers"

- Foot Protection devices -ANSI Z41-1991 "American National Standard for Personal Protection Protective Footwear" Hand Protection -No national standard available -Selection will be based on task performed, conditions present, duration of use, and the hazards and potential hazards identified.

- Electrical Protective equipment -No national standard -Equipment will be tested electrically before first use and every 6 months thereafter or upon indication that insulating value is suspect.

Selection Guidelines

- The general procedure for selection of protective equipment is to: - Become familiar with the potential hazards and the type of protective equipment that is available, and what

it can do; i.e., splash protection, impact protection, etc.; - compare the hazards associated with the environment; i.e., impact velocities, masses, projectile shape,

radiation intensities, with the capabilities of the available protective equipment; - select the protective equipment which ensures a level of protection greater than the minimum required to

protect employees from the hazards;

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- Fit the user with the protective device and give instructions on care and use of the PPE. It is very important that end users be made aware of all warning labels for and limitations of their PPE.

Fitting the Device Careful consideration must be given to comfort and fit. PPE that fits poorly will not afford the necessary protection. Continued wearing of the device is more likely if it fits the wearer comfortably. Protective devices are generally available in a variety of sizes. Care should be taken to ensure that the right size is selected. Devices with Adjustable Features Adjustments should be made on an individual basis for a comfortable fit that will maintain the protective device in the proper position. Particular care should be taken in fitting devices for eye protection against dust and chemical splash to ensure that the devices are sealed to the face. In addition, proper fitting of helmets is important to ensure that it will not fall off during work operations. In some cases a chin strap may be necessary to keep the helmet on an employee's head. (Chin straps should break at a reasonably low force, however, so as to prevent a strangulation hazard). Where manufacturer's instructions are available, they should be followed carefully. Reassessment of Hazards It is the responsibility of the RSO to reassess the workplace hazard situation as necessary, by identifying and evaluating new equipment and processes, reviewing accident records, and reevaluating the suitability of previously selected PPE.

- Defective & Damaged Equipment - Defective or damaged personal protective equipment shall not be used. - Selection of Personal Protective Equipment (PPE)

Personal protective equipment (PPE) will be selected on the basis of the hazards to which the workers' are exposed or potentially exposed. All selections will be made by with input from managers, supervisors and workers. Training Each employee who is required to use PPE will be trained in the following:

- Why PPE is necessary - When PPE is necessary - What PPE is necessary and any alternative choices of equipment - How to properly don, doff, adjust, and wear PPE - The proper care, maintenance, storage, useful life, and disposal of PPE

The training will include an opportunity for employees to handle the PPE and demonstrate that they understand the training and have the ability to use the PPE properly. Training will be provided by the manager or supervisor of the affected employees. Training will be documented in writing with the documentation including the names of each employee trained, the date(s) of the training, and the subject matter covered. Employees must demonstrate an understanding of the training and the ability to use the PPE properly before they are allowed to perform work requiring the use of the equipment. Employees are prohibited from performing work without donning appropriate PPE to protect them from the hazards they will encounter in the course of that work.

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If the RSO has reason to believe an employee does not have the understanding or skill required, the employer must retrain. Since an employee's supervisor is in the best position to observe any problems with PPE use by individual employees, the RSO will seek this person's input when making this determination. Circumstances where retraining may be required include changes in the workplace or changes in the types of PPE to be used, which would render previous training obsolete. Also, inadequacies in an affected employee's knowledge or use of the assigned PPE, which indicates that the employee has not retained the necessary understanding or skills, would require retraining. Employees are trained in the use of PPE in a classroom environment and have a sign-up sheet when they enter and a short quiz after the training to ensure they understand the correct use of PPE. These documents are permanently kept on file. The RSO certifies in writing that the employee has received and understands the PPE training. Because failure to comply with company policy concerning PPE can result in OSHA citations and fines as well as employee injury, an employee who does not comply with this program will be disciplined for noncompliance according to the company's Disciplinary Action Program. Cleaning and Maintenance It is important that all PPE be kept clean and properly maintained by the employee to whom it is assigned. Cleaning is particularly important for eye and face protection where dirty or fogged lenses could impair vision. PPE is to be inspected, cleaned, and maintained by employees at regular intervals as part of their normal job duties so that the PPE provides the requisite protection. Supervisors are responsible for ensuring compliance with cleaning responsibilities by employees. If PPE is for general use, the RSO has responsibility for cleaning and maintenance. If a piece of PPE is in need of repair or replacement it is the responsibility of the employee to bring it to the immediate attention of his or her supervisor or the RSO. It is against work rules to use PPE that is in disrepair, defective, or not able to perform its intended function. Contaminated PPE that cannot be decontaminated is disposed of in a manner that protects employees from exposure to hazards. Personal Protective Equipment Engineering controls shall be the primary methods used to eliminate or minimize hazard exposure in the workplace. When such controls are not practical or applicable, personal protective equipment shall be employed to reduce or eliminate personnel exposure to hazards. Personal protective equipment (PPE) will be provided, used, and maintained when it has been determined that its use is required and that such use will lessen the likelihood of occupational injuries and/or illnesses. The RSO will recommend and/or provide necessary protective equipment where there is a reasonable probability that the use of the equipment will prevent or reduce the severity of injuries or illness. Equipment Specifications and Requirements All personal protective clothing and equipment will be of safe design and construction for the work to be performed. Only those items of protective clothing and equipment that meet National Institute of Occupational Safety and Health (NIOSH) or American National Standards Institute (ANSI) standards will be procured or accepted for use.

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Eye and Face Protection The majority of occupational eye injuries can be prevented by the use of suitable/approved safety spectacles, goggles, or shields. Approved eye and face protection shall be worn when there is a reasonable possibility of personal injury. Supervisors, with assistance from the RSO, determine jobs and work areas that require eye protection and the type of eye and face protection that will be used. Typical hazards that can cause eye and face injury are:

- Splashes of toxic or corrosive chemicals, hot liquids, and molten metals; - Flying objects, such as chips of wood, metal, and stone dust; - Fumes, gases, and mists of toxic or corrosive chemicals; - Aerosols of biological substances.

Prevention of eye accidents requires that all persons who may be in eye hazard areas wear protective eyewear. This includes employees, visitors, researchers, contractors, or others passing through an identified eye hazardous area. To provide protection for these personnel, activities shall procure a sufficient quantity of heavy duty goggles and/or plastic eye protectors which afford the maximum amount of protection possible. If these personnel wear personal glasses, they shall be provided with a suitable eye protector to wear over them. Eye and face protectors procured, issued to, and used by Company personnel must conform to the following design and standards:

- Provide adequate protection against the particular hazards for which they are designed - Fit properly and offer the least possible resistance to movement and cause minimal discomfort while in use. - Be durable. - Be easily cleaned or disinfected for or by the wearer. - Be clearly marked to identify the manufacturer.

Persons who require corrective lenses for normal vision, and who are required to wear eye protection, must wear goggles or spectacles of one of the following types:

- Spectacles with protective lenses which provide optical correction. - Goggles that can be worn over spectacles without disturbing the adjustment of the spectacles. - Goggles that incorporate corrective lenses mounted behind the protective lenses.

Description and Use of Eye/Face Protectors Safety Spectacles. Protective eye glasses are made with safety frames, tempered glass or plastic lenses, temples and side shields which provide eye protection from moderate impact and particles encountered in job tasks such as carpentry, woodworking, grinding, scaling, etc. Single Lens Goggles. Vinyl framed goggles of soft pliable body design provide adequate eye protection from many hazards. These goggles are available with clear or tinted lenses, perforated, port vented, or non-vented frames. Single lens goggles provide similar protection to spectacles and may be worn in combination with spectacles or corrective lenses to insure protection along with proper vision. Welders/Chippers Goggles. These goggles are available in rigid and soft frames to accommodate single or two eye piece lenses.

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Welder's goggles provide protection from sparking, scaling or splashing metals and harmful light rays. Lenses are impact resistant and are available in graduated shades of filtration. Chippers/grinders goggles provide eye protection from flying particles. The dual protective eye cups house impact resistant clear lenses with individual cover plates. Face Shields. These normally consist of an adjustable headgear and face shield of tinted/transparent acetate or polycarbonate materials, or wire screen. Face shields are available in various sizes, tensile strength, impact heat resistance and light ray filtering capacity. Face shields will be used in operations when the entire face needs protection and should be worn to protect eyes and face against flying particles, metal sparks, and chemical biological splash. Welding Shields. These shield assemblies consist of vulcanized fiber or glass fiber body, a ratchet button type adjustable headgear or cap attachment and a filter and cover plate holder. These shields will be provided to protect workers' eyes and face from infrared or radiant light burns, flying sparks, metal spatter and slag chips encountered during welding, brazing, soldering, resistance welding, bare or shielded electric arc welding and oxyacetylene welding and cutting operations. The RSO maintains a supply of various eye and face protective devices. Personnel requiring prescription safety glasses must contact the RSO. Emergency Eyewash Facilities Emergency eyewash facilities meeting the requirements of ANSI Z358.l-1981 shall be provided in all areas where the eyes of any employee may be exposed to corrosive materials. All such emergency facilities shall be located where they are easily accessible to those in need. Hearing Protection Hearing protection devices are the first line of defense against noise in environments where engineering controls have not reduced employee exposure to safe levels. Hearing protective devices can prevent significant hearing loss, but only if they are used properly. The most popular hearing protection devices are earplugs which are inserted into the ear canal to provide a seal against the canal walls. Earmuffs enclose the entire external ears inside rigid cups. The inside of the muff cup is lined with acoustic foam and the perimeter of the cup is fitted with a cushion that seals against the head around the ear by the force of the headband. Preformed earplugs and earmuffs should be washed periodically and stored in a clean area, and foam inserts should be discarded after each use. It is important for you to wash hands before handling preformed earplugs and foam inserts to prevent contaminants from being placed in the ear which may increase your risk of developing infections. Also, check hearing protective devices for signs of wear or deterioration. Replace devices periodically. The RSO and Site Supervisor maintain a supply of a variety of disposable foam ear inserts and earmuffs.

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Respiratory Protection Respiratory hazards may occur through exposure to harmful dusts, fogs, fumes, mists, gases, smoke, sprays, and vapors. The best means of protecting personnel is through the use of engineering controls, e.g., local exhaust ventilation. Respirators protect against airborne hazards when properly selected and used. City Construction, Inc., recommends voluntary use of respirators when exposure to substances is below OSHA permissible exposure limits (PELs) because respirators can provide you an additional level of comfort and protection. The RSO is responsible for the Voluntarily Respiratory Protection Program at the Company. Workers who voluntarily use respirators must first obtain medical approval from a physician to wear a respirator before a respirator can be issued. If you choose to voluntarily use a respirator be aware that respirators can create hazards for you, the user. You can avoid these hazards if you know how to use your respirator properly and how to keep it clean. Take these steps:

- Read and follow all instructions provided by the manufacturer about use, maintenance (cleaning and care), and warnings regarding the respirator’s limitations.

- Choose respirators that have been certified for use to protect against the substance of concern. The National Institute for Occupational Safety and Health (NIOSH) certifies respirators. If a respirator isn't certified by NIOSH, you have no guarantee that it meets minimum design and performance standards for workplace use.

o A NIOSH approval label will appear on or in the respirator packaging. It will tell you what protection the respirator provides.

- Keep track of your respirator so you don't mistakenly use someone else’s. - Clean the respirator after each use, thoroughly dry it and place the cleaned respirator in a sealable plastic

bag. - Store respirators carefully in a protected location away from excessive heat, light, and chemicals. - Do not wear your respirator into:

o Atmospheres containing hazards that your respirator isn't designed to protect against. For example, a respirator designed to filter dust particles won't protect you against solvent vapor, smoke, or oxygen deficiency.

o IDLH atmospheres (City Construction employees are prohibited from entering this type of atmosphere).

o Head Protection Hats and caps have been designed and manufactured to provide workers protection from impact, heat, electrical and fire hazards. These protectors consist of the shell and the suspension combined as a protective system. Safety hats and caps will be of nonconductive, fire and water resistant materials. Bump caps or skull guards are constructed of lightweight materials and are designed to provide minimal protection against hazards when working in congested areas. Head protection will be furnished to, and used by, all employees and contractors engaged in construction and other miscellaneous work in head-hazard areas. Head protection will also be required to be worn by engineers, inspectors, and visitors at construction sites. Bump caps/skull guards will be issued to and worn for protection against scalp lacerations from contact with sharp objects. They will not be worn as substitutes for safety caps/hats because they do not afford protection from high impact forces or penetration by falling objects. Hand Protection

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Skin contact is a potential source of exposure to toxic materials; it is important that the proper steps be taken to prevent such contact. Gloves should be selected on the basis of the material being handled, the particular hazard involved, and their suitability for the operation being conducted. One type of glove will not work in all situations. Most accidents involving hands and arms can be classified under four main hazard categories: chemicals, abrasions, cutting, and heat. There are gloves available that can protect workers from any of these individual hazards or any combination thereof. The first consideration in the selection of gloves for use against chemicals is to determine, if possible, the exact nature of the substances to be encountered. Read instructions and warnings on chemical container labels and SDS before working with any chemical. Recommended glove types are often listed in the section for personal protective equipment. All glove materials are eventually permeated by chemicals. However, they can be used safely for limited time periods if specific use and glove characteristics (i.e., thickness and permeation rate and time) are known. The RSO can assist is determining the specific type of glove material that should be worn for a particular chemical. Gloves should be replaced periodically, depending on frequency of use and permeability to the substance(s) handled. Gloves overtly contaminated should be rinsed and then carefully removed after use. Gloves should also be worn whenever it is necessary to handle rough or sharp-edged objects, and very hot or very cold materials. The type of glove materials to be used (in these situations) includes leather, welder's gloves, aluminum-backed gloves, and other types of insulated glove materials. Careful attention must be given to protecting your hands when working with tools and machinery. Power tools and machinery must have guards installed or incorporated into their design that prevent the hands from contacting the point of operation, power train, or other moving parts. To protect the hands from injury due to contact with moving parts, it is important to: Ensure that guards are always in place and used. Always lock out machines or tools and disconnect the power before making repairs. Treat a machine without a guard as inoperative; and Do not wear gloves around moving machinery, such as drill presses, mills, lathes, and grinders. The RSO can help the supervisor identify appropriate glove selections for their operations. The RSO also maintains a selection of gloves for various tasks. Safety Shoes Safety shoes shall be worn in the shops, warehouses, maintenance, cage wash, glassware, and other areas as determined by the Health and Safety Branch. Recommendations for safety footwear shall be approved by the Health and Safety Branch. All safety footwear shall comply with American National Standards Institute (ANSI) Standard ANSI Z41-1991, "American National Standard for Personal Protection Footwear. Protective footwear purchased before July 5, 1994, shall comply with ANSI Standard Z41.1-1967. Permanent full time employees will be initially issued two pairs of safety shoes of approved type. Shoes will be replaced or repaired as necessary based on supervisory approval. Other than permanent employees will be issued one pair of safety shoes with replacement as necessary based on supervisory approval. Supervisor -Reviews employees work situation and recommends safety footwear as appropriate in accordance with established Institute policy. Requests safety shoes from the RSO for new employees or as indicated for replacement. Ensures that all employees under his supervision use and maintain safety footwear. Makes determination on the need for replacement or repair of safety shoes.

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Employee -Wears Institute provided or approved safety shoes in all areas requiring safety footwear as determined by the supervisor and the RSO. RSO -Consults with supervisors concerning safety shoe requirements and approves issuance of all safety shoes. Arranges for local purchase of all safety shoes. Makes arrangements for necessary repairs. Supervisors must review employee's work situation in consultation with the RSO to decide the need for safety footwear and appropriate types. The "Request for Safety Shoes" must be completed, reviewed and signed by the supervisor and approved by the RSO. Any employee desiring to replace his/her safety footwear must complete the "Request for Safety Shoes" and have it signed by their supervisor. If an employee is unable to find appropriate safety footwear at the designated vendors, he or she should check with the RSO for alternate procedures. Alternate procedures involve employees purchasing safety footwear with their own funds and being reimbursed. Employees who want to have their footwear repaired, should be encouraged to do so. Some footwear is designed to be repaired, and some is not. Repairs would include such items as new soles and heels. The Company will reimburse employees for repairs. Hearing Personal Protective Equipment Hearing protective devices (ear plugs, muffs, etc.) shall be the permanent solution only when engineering or administrative controls are considered to be infeasible or cost prohibitive. Hearing protective devices are defined as any device that can be worn to reduce the level of sound entering the ear. Hearing protective devices shall be worn by all personnel when they must enter or work in an area where the operations generate noise levels of: Greater than 85 dB sound levels, or, 115 dB peak sound pressure level or greater Types of Hearing Protective Devices Hearing protective devices include the following: A device designed to provide an air-tight seal with the ear canal. There are three types of insert earplugs

- Pre-molded - Formable - Custom earplugs. - Pre-molded earplugs are pliable devices of fixed proportions. Two standard styles, single flange and triple

flange, come in various sizes, and will fit most people. Personnel responsible for fitting and dispensing earplugs will train users on proper insertion, wear, and care. While pre-molded earplugs are reusable, they may deteriorate and should be replaced periodically.

- Formable earplugs come in just one size. Some are made of material which, after being compressed and inserted, expands to form a seal in the ear canal. When properly inserted, they provide noise attenuation values that are similar to those from correctly fitted pre-molded earplugs. Individual units may procure approved formable earplugs. Supervisors must instruct users in the proper use of these earplugs as part of the annual education program. Each earplug must be held in place while it expands enough to remain firmly seated. A set of earplugs with a cord attached is available. These earplugs may be washed and therefore are reusable, but will have to be replaced after two or three weeks or when they no longer form an airtight seal when properly inserted.

- Custom Molded Earplugs: A small percentage of the population cannot be fitted with standard pre-molded or formable earplugs. Custom earplugs can be made to fit the exact size and shape of the individual's ear

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canal. Individuals needing custom earplugs will be referred to an audiologist. Earmuffs are devices worn around the ear to reduce the level of noise that reaches the ear. Their effectiveness depends on an air tight seal between the cushion and the head.

- Employees will be given the opportunity to select hearing protective devices from a variety of suitable ones provided by the RSO. In all cases the chosen hearing protectors shall have a Noise Reduction Ratio (NRR) high enough to reduce the noise at the ear drum to 85 dB or lower. The issuance of hearing protective devices is handled through the RSO. The RSO will issue and fit the initial hearing protective devices (foam inserts, disposables). Instruction on the proper use and care of earplugs and earmuffs will be provided whenever HPDs (hearing protective devices) are dispensed. Personnel requiring earmuffs in addition to earplugs will be informed of this requirement and educated on the importance of using proper hearing protection. The RSO will dispense ear muffs when necessary and will maintain a supply of disposable earplugs. Always use and maintain HPDs as originally intended and in accordance with instructions provided. Earmuff performance may be degraded by anything that compromises the cushion-to-circumaural flesh seal. This includes other pieces of personal protective equipment such as eyewear, masks, face shields, and helmets. Reusable earplugs, such as the triple flange or formable devices should be washed in lukewarm water using hand soap, rinsed in clean water, and dried thoroughly before use. Wet or damp earplugs should not be placed in their containers. Cleaning should be done as needed. Earmuff cushions should be kept clean. The plastic or foam cushions may be cleaned in the same way as earplugs, but the inside of the muff should not get wet. When not in use, ear muffs should be placed in open air to allow moisture that may have been absorbed into the cups to evaporate. The maximum of sound attenuation one gets when wearing hearing protection devices is limited by human body and bone conduction mechanisms. Even though a particular device may provide outstanding values of noise attenuation the actual noise reductions may be less because of the noise surrounding the head and body bypasses the hearing protector and is transmitted through tissue and bone pathways to the inner ear. The term "double hearing protection" is misleading. The attenuation provided from any combination earplug and earmuff is not equal to the sum of their individual attenuation values. Appendices Hazard Assessment Form Respirator Clearance Form Fall Protection Plan OSHA currently regulates fall protection for construction under Part 1926, Subpart M. The standards for regulating fall protection systems and procedures are intended to prevent employees from falling off, onto or through working levels and to protect employees from falling objects. Fall protection requirements under the OSHA Construction regulations require considerable planning and preparation.

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Written fall protection procedures establish guidelines to be followed whenever an employee works above dangerous equipment on ramps or runways, or at heights with fall protection at the job site. The regulations:

- Are designed to provide a safe working environment. - Govern use off all protection procedures and equipment.

Written procedures for fall protection establish uniform requirements for fall protection training, operation, and practices. The effectiveness of the written fall protection procedures depends on the active support and involvement of all employees who perform the jobs requiring it. This plan is intended to document procedures that ensure all work requiring fall protection is carried out safely. Purpose City Construction, Inc. is dedicated to the protection of its employees from on-the-job injuries. All employees of City Construction, Inc. have the responsibility to work safely on the job. The purpose of this plan is to:

- Supplement our standard safety policy by providing safety standards specifically designed to cover fall protection on this job.

- Ensure that each employee is trained and made aware of the safety provisions which are to be implemented by this plan prior to the start of erection.

This program informs interested persons, including employees that City Construction, Inc. is complying with OSHA's Fall Protection requirements, (29 CFR 1926.500 to.503). This program applies to all employees who might be exposed to fall hazards, except when designated employees are inspecting, investigating, or assessing workplace conditions before the actual start of construction work or after all construction work has been completed. All fall protection systems selected for each application will be installed before an employee is allowed to go to work in an area that necessitates the protection. Dennis Fallon, RSO, is the program coordinator/manager and is responsible for its implementation. Copies of the written program may be obtained from the RSO's Office. Certain employees are authorized to inspect, investigate; or assess workplace conditions before construction work begins or after all construction work has been completed. These employees are exempt from the fall protection rule during the performance of these duties. They are the RSO and Site Supervisors. These authorized employees determine if all walking/working surfaces on which our employees work have the strength and structural integrity to support the employees. Our employees will not be allowed to work on these surfaces until they have the requisite strength and structural integrity. All employees, or their designated representatives, can obtain further information about this written program, and/or the fall protection standard from Dennis Fallon, RSO. Our Duty to Provide Fall Protection To prevent falls City Construction, Inc. has a duty to anticipate the need to work at heights and to plan our work activities accordingly. Careful planning and preparation lay the necessary groundwork for an accident-free jobsite. Worksite Assessment and Fall Protection System Selection

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Because some sites may require fall protection while others may not, this is the written General Plan developed by our RSO, Dennis Fallon applying to all applicable worksites. This fall protection plan is intended to anticipate the particular fall hazards to which our employees may be exposed. Specifically, we:

- Inspect the area to determine what hazards exist or may arise during the work. - Identify the hazards and select the appropriate measures and equipment. - Give specific and appropriate instructions to workers to prevent exposure to unsafe conditions. - Ensure employees follow procedures given and understand training provided. - Apprise ourselves of the steps our specialty subcontractors have taken to meet their fall protection

requirements. Providing fall protection requires an assessment of each fall situation at a given jobsite. Our criteria for selecting a given fall protection system follow those established at 29 CFR 1926.502, fall protection systems criteria and practices. Each employee exposed to these situations must be trained as outlined later in this plan. Unprotected Sides and Edges Our employees must be protected when they are exposed to falls from unprotected sides and edges of walking/working surfaces (horizontal and vertical surfaces) which are 6 feet or more above lower levels. We know that OSHA has determined that there is no "safe" distance from an unprotected side or edge that would render fall protection unnecessary. We have chosen the following fall protection for unprotected sides and edges at our worksites:

- Guardrails - Safety nets - Personal fall arrest

We maintain the fall protection system(s) chosen until all work has been completed or until the permanent elements of the structure which will eliminate the exposure to falling hazards are in place. Leading Edge Work Leading edges are defined as the edge of a floor, roof, or formwork that changes location as additional floor, roof, or form work sections are placed, formed, or constructed. If work stops on a leading edge it will be considered to be an "unprotected side or edge" and will be covered by the section of this plan on unprotected sides and edges. We presume that it is feasible and will not create a greater hazard to implement at least one of the conventional fall protection systems for our leading edge work. Employees who are not constructing the leading edge, but who are on walking/working surfaces where leading edges are under construction, are also protected from a fall by guardrails, safety nets, personal fall arrest. Hoist Areas In all situations where equipment and material hoisting operations take place, we protect our employees from fall hazards. When we are involved in hoisting operations we will use the following fall protection systems at these specific locations:

- guardrails or personal fall arrest systems

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When operations require the materials to be lifted by crane to a landing zone (and do not require an employee to lean through the access opening or out over the edge to receive or guide materials), we can select either personal fall arrest equipment or a guardrail system. When guardrails (or chains or gates) are removed to facilitate hoisting operations, and one of our employees must lean through the access opening or out over the edge to receive or guide materials they will be protected by a personal fall arrest system. Holes City Construction, Inc. protects employees from:

- Tripping in or stepping into or through holes (including skylights). - Objects falling through holes (including skylights).

We use the following fall protection system to protect our employees working on walking/working surfaces with holes where they can fall 6 feet or more to a lower surface:

- Covers - Guardrails - Personal fall arrest systems

At these worksite employees can trip or step into or through a hole (including skylights) or an object could fall through a hole and strike a worker. In these instances we use covers to prevent accidents. We understand that OSHA does not intend that a guardrail be erected around holes while employees are working at the hole, passing materials, and so on. Therefore, if the cover is removed while work is in progress, guardrails are not required because they would interfere with the performance of work. When the work has been completed, we will be required to either replace the cover or erect guardrails around the hole. Formwork and Reinforcing Steel A jobsite may require formwork or reinforcing steel work 6 feet or more above lower levels. We could be involved in work where different systems fit different applications. Therefore, we have chosen the following fall protection systems that might be used to protect our employees:

- Positioning device - Safety net - Personal fall arrest system

Ramps, Runways, and Other Walkways We equip all ramps, runways, and other walkways with guardrails when employees are subject to falling 6 feet or more to lower levels. Excavations Some jobsites may have excavation edges that will not be readily seen (i.e., concealed from view by plant growth, etc.). When it is necessary, and when the excavation is 6 feet or more deep we protect these excavations by:

- Guardrail systems

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- Fences - Barricades

In addition, walls, pits, shafts, and similar excavations 6 feet or more deep will be guarded to prevent employees from falling into them by:

- Guardrail systems - Fences - Barricades - Covers

Dangerous Equipment City Construction, Inc. is committed to protecting our employees from falling onto dangerous equipment. When this equipment is less than 6 feet below an employee, but because of form or function is dangerous, the employee is protected by guardrails or an equipment guard When this equipment is more than 6 feet below an employee, but because of form or function is dangerous, the employee is protected by guardrails, personal fall arrest system, or a safety net. Roofing Work on Low-Slope Roofs Each of our employees engaged in roofing activities on low-slope roofs (4 in 12 or less, vertical to horizontal pitch) with unprotected sides and edges six-feet or more above lower levels will be protected from falling by:

- Guardrails - Personal fall arrest system - Safety net - A combination of warning line and guardrail - A combination of warning line and safety net - A combination of warning line and personal fall arrest

We follow the guidelines in Appendix A of Subpart M to determine how to correctly measure a roof that is not a rectangle. Steep Roofs We will protect our workers on roofs with slopes greater than 4 in 12 vertical to horizontal pitch (steep roofs) from falling when the roof has unprotected sides or edges more than 6 feet above lower levels by the use of:

- Guardrail with toe boards - Personal fall arrest system - Safety net - Wall Openings

Employees who are exposed to the hazard of falling out or through wall openings (including those with chutes attached) where the outside bottom edge of the wall opening is 6 feet or more above lower levels and the inside bottom edge of the wall opening is less than 39 inches above the walking/working surface must be protected from falling. We protect our employees from falls out or through wall openings by the following methods:

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- Guardrails - Safety nets - Personal fall arrest systems

Walking/Working Surfaces Not Otherwise Addressed We realize there will be situations that are not covered by our written safety plan, for which we have the duty to provide fall protection. All employees exposed to falls of6 feet or more to lower levels must be protected by a guardrail system, safety net system, or personal fall arrest system except where specified otherwise in Part 1926. We have audited all of our worksites for fall protection hazards that are not covered elsewhere in this plan. We have taken the following measures to address these hazards:

- Guardrails - Personal fall arrest system - Safety net

Protection from Falling Objects When employees are exposed to falling objects, we ensure they wear hard hats and also implement one of the following measures:

- Erect toe boards, screens, or guardrail systems to prevent objects from falling from higher levels. - Erect a canopy structure and keep potential fall objects far enough from the edge of the higher level so that

those objects would not go over the edge if they were accidentally moved. - Barricade the area to which objects could fall, prohibit employees from entering the barricaded area, and

keep objects that may fall far enough away from the edge of a higher level so that those objects would not go over the edge if they were accidentally moved.

- Cover or guard holes 6 feet or more above a lower level. Controlled Access Zones A Controlled access zone is a work area designated and clearly marked in which certain types of work (such as overhand bricklaying) may take place without the use of conventional fall protection systems, guardrail, personal arrest or safety net to protect the employees working in the zone. Controlled access zones are used to keep out workers other than those authorized to enter work areas from which guardrails have been removed. Where there are no guardrails, masons are the only workers allowed in controlled access zones. Controlled access zones, when created to limit entrance to areas where leading edge work and other operations are taking place, must be defined by a control line or by any other means that restrict access. Control lines shall consist of ropes, wires, tapes or equivalent materials, and supporting stanchions, and each must be:

- Flagged or otherwise clearly marked at not more than 6-foot (1.8 meters) intervals with high-visibility material

- Rigged and supported in such a way that the lowest point (including sag) is not less than 39 inches (1 meter) from the walking/working surface and the highest point is not more than 45 inches (1.3 meters)--nor

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more than 50 inches (1.3 meters) when overhand bricklaying operations are being performed from the walking/working surface.

- Strong enough to sustain stress of not less than 200 pounds (0.88 kilonewtons). Control lines shall extend along the entire length of the unprotected or leading edge and shall be approximately parallel to the unprotected or leading edge Control lines also must be connected on each side to a guardrail system or wall. When control lines are used, they shall be erected not less than 6 feet (1.8 meters) nor more than 25 feet (7.6 meters) from the unprotected or leading edge, except when precast concrete members are being erected. In the latter case, the control line is to be erected not less than 6 feet (1.8 meters) nor more than 60 feet (18 meters) or half the length of the member being erected, whichever is less, from the leading edge.

- Controlled access zones when used to determine access to areas where overhand bricklaying and related work are taking place are to be defined by a control line erected not less than 10 feet (3 meters) nor more than 15 feet (4.6 meters) from the working edge. Additional control lines must be erected at each end to enclose the controlled access zone. Only employees engaged in overhand bricklaying or related work is permitted in the controlled access zones.

- On floors and roofs where guardrail systems are not in place prior to the beginning of overhand bricklaying operations, controlled access zones will be enlarged as necessary to enclose all points of access, material handling areas, and storage areas.

- On floors and roofs where guardrail systems are in place, but need to be removed to allow overhand bricklaying work or leading edge work to take place, only that portion of the guardrail necessary to accomplish that day's work shall be removed.

Safety Monitoring Systems When no other alternative fall protection has been implemented, the Company shall implement a safety monitoring system. City Construction, Inc. will appoint the site Safety Coordinator or Supervisor to monitor the safety of workers and the Company shall ensure that the safety monitor:

- Is competent in the recognition off all hazards. - Is capable of warning workers off all hazard dangers and in detecting unsafe work practices. - Is operating on the same walking/working surfaces of the workers and can see them. - Is close enough to work operations to communicate orally with workers and has no other duties to distract

from the monitoring function. - Not have other assignments that would take monitors attention from the monitoring function.

Mechanical equipment shall not be used or stored in areas where safety monitoring systems are being used to monitor employees engaged in roofing operations on low-sloped roofs. No worker, other than one engaged in roofing work (on low-sloped roofs) or one covered by a fall protection plan, shall be allowed in an area where an employee is being protected by a safety monitoring system. All workers in a controlled access zone shall be instructed to promptly comply with fall hazard warnings issued by safety monitors. Selection & Use Guidelines for Fall Protection Equipment Providing fall protection requires an assessment of each fall situation at a given jobsite. Our criteria for selecting a given fall protection system follow those established at 29 CFR 1926.502~ fall protection systems criteria and practices. Each employee exposed to these situations must be trained as outlined later in this plan. When

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purchasing equipment and raw materials for use in fall protection systems applicable ANSI & ASTM requirements will be met. General Worksite Policy If anyone of the conditions described in the Workplace Assessment is not met for the area or piece of equipment posing a potential fall hazard then do not perform that work until the condition is met. If you cannot remedy the condition immediately, notify a supervisor of the problem and utilize a different piece of equipment or work in a different area according to the situation. If the situation calls for use off all protection devices such as harnesses or lanyards because the fall hazard cannot be reduced to a safe level~ then the employee must don such protective equipment before beginning the work and use it as intended throughout the duration of the work. Only employees trained in such work are expected to perform it. All places of employment, job sites shall be kept clean and orderly and in a sanitary condition. All walking/working surfaces must be kept in a clean and so far as possible dry condition. Where wet processes are used, drainage shall be maintained and false floors, platforms, mats, or other dry standing places should be provided where practicable. All places of employment, job sites shall be kept clean and orderly and in a sanitary condition Training Program Under no circumstances shall employees work in areas where they might be exposed to fall hazards, do work requiring fall protection devices, or use fall protection devices until they have successfully completed this company's fall protection training program. The training program includes classroom instruction and operational training on recognition and avoidance of unsafe conditions and the regulations applicable to their work environment for each specific fall hazard the employee may encounter. The training program is conducted by the RSO, a "competent person" qualified in each aspect of the program, and must cover the following areas:

- The nature off all hazards in the work area. - Selection and use of personal fall arrest systems, including application limits, proper anchoring and tie-off

techniques~ estimation of free fall distance (including determination of deceleration distance and total fall distance to prevent striking a lower level), methods of use, and inspection and storage of the system.

- The correct procedures for erecting, maintaining, disassembling, and inspecting the fall protection systems to be used.

- The use and operation of guardrail systems, personal fall arrest systems, safety net systems, warning line systems, safety monitoring systems, controlled access zones, and other protection to be used.

- The use of Prusik cords for self-rescue, procedures of self-rescue, injured worker removal, and post-fall procedures.

- The limitations on the use of mechanical equipment during the performance of roofing work on low-sloped roofs.

- The correct procedures for the handling and storage of equipment and materials and the erection of overhead protection.

- The role of employees in fall protection plans. - The standards contained in Subpart M of the construction regulations.

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The RSO will identify all current and new employees who require training and schedule the classroom instruction for those employees. Training on the above components will occur both in the classroom and on the job site, as appropriate. Classroom training will cover written policy/procedures on fall protection and include a training video on the subject. Job site instruction will include demonstration of and practice in wearing fall protection equipment and any instruction necessary for a specific job. Dennis Fallon, RSO has overall responsibility for the safety of employees and will verify compliance with 1926.503(a), training program, for each employee required to be trained. The RSO and/or Site Supervisor has the responsibility of determining when an employee who has already been trained, does not have the understanding and skill required by the training program (I 926.503 (a)). A written certificate of training is required which must include:

- The name or other identity of the employee trained. - The date(s) of training. - The signature of the competent person who conducted the training or the signature of the employer.

Retraining is required when an employee cannot demonstrate the ability to recognize the hazards of falling and the procedures to be followed to minimize fall hazards. Enforcement Constant awareness of and respect for fall hazards, and compliance with all safety rules are considered conditions of employment. The job site superintendent, as well as individuals in the Safety and Personnel Department, reserve the right to issue disciplinary warnings to employees, up to and including termination, for failure to follow the guidelines of this program. Injured Worker Removal Post-fall self-rescue must happen quickly. Within minutes, with no other serious injuries, a fall victim may experience circulatory problems that may damage the heart or cause loss of consciousness. When trained elevated workers carry two Prusik cords (foot loops), they can attach them quickly to their lifeline post fall, then step into them. This relives harness pressure while enabling them to ascend or descend. Under no circumstances should self-rescue be initiated until the competent person on site assesses the fall victim's physical and mental condition. During most construction-related falls, rebounding, entanglement and structural impact all playa factors in the victim's injuries and ability to escape unaided. It is nearly impossible to verbally dissuade a fall victim from attempting self-rescue if he or she is adrenalized, athletic and has a natural take-charge mentality. The first-aid-trained competent person should also try to reconstruct and evaluate the fall incident for any potential injuries the victim may have received. Conscious or unconscious, the victim may be in shock, or may have received critical injuries such as arterial/venal lacerations, spinal cord injury, or head, spleen or lung damage. As there will be an eventual PF AS disconnection point in self-rescue, critical injuries (broken bones, concussion, muscle sprains, groin injuries) may play a significant role in this maneuver. Post-Fall Procedure

- Initiate emergency services 911 for medical and professional rescue services. - Contact First Aid person to evaluate fall victim's condition.

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- Organize equipment, rigging, ropes, barriers, and men for rescue. - Find out if victim can perform a self-rescue. - Perform self-rescue if possible.

Incident Investigation All accidents that result in injury to workers, regardless of their nature, are investigated and reported. It is an integral part of any safety program that documentation take place as soon as possible so that the cause and means of prevention can be identified to prevent a reoccurrence. In the event that an employee falls or there is some other related, serious incident (e.g., a near miss) occurs, this plan will be reviewed to determine if additional practices, procedures, or training need to be implemented to prevent similar types of falls or incidents from occurring. Changes to Plan Any changes to the plan will be approved by the RSO. This plan is reviewed by a qualified person as the job progresses to determine if additional practices, procedures or training needs to be implemented by the competent person to improve or provide additional fall protection. Workers are notified and trained, if necessary, in the new procedures. A copy of this plan and all approved changes is maintained at the jobsite.

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Infection Control Program Purpose It is our policy that medical care will be provided for employees who have been exposed to a communicable disease on the job. We will ensure job placement does not compromise the health and safety of employees. We will maintain confidentiality of all records. Training

- Employees can access the Infection Control Program at time of hire by accessing our Safety Program at City Construction’s Inc. office.

- At an orientation tool box meeting conducted by foremen prior to beginning work at a job site. - At annual safety meetings. Employees will be notified of date, time and place of annual training meetings

as they are scheduled. Attendance is mandatory. Infection Control Program The following are types of communicable diseases:

- HIV - Human Immunodeficiency Virus. - MRSA - Methicillin Resistant Staphylococcus Aureus.

o MRSA is an infection caused by bacterium “staphylococcus aureus” or “staph” also known as a “super bug” which has become resistant to many of the commonly used antibiotics. There are two strains that exist and are based on the origin of exposure - HA-MRSA (hospital acquired) and CA-MRSA (community acquired). September 19, 2007 Arizona legislation passed a statute addressing worker compensation claims involving MRSA (A.R.S. 23-1043.04). The illness must be diagnosed within two to ten days. Person alleged to be a source of a significant exposure shall not be forced to release confidential information. Please note the following information regarding MRSA.

o Anyone can get MRSA. Persons most susceptible have significant exposure to bodily fluids or skin contact or in the regular course of employment have involvement handling or exposure to MRSA.

o Avoid contact with others that have uncovered wounds. o Do not share personal items that come in contact with your skin, nose, mouth or other areas with

exposed bodily fluids. These items include but are not limited to respirators, clothing, uniforms and towels that may have come in contact with the infected wounds.

o MRSA is transmitted primarily by person to person contact with secretions from skin lesions, nasal discharge or by hand.

o MRSA begins as a pimple that has popped, begins to drain and/or has pus. It appears like a spider bite, a boil or infected mosquito bite that progresses to a painful swollen red area with drainage.

o The following facilitate transmission of MRSA: Contact - avoid skin to skin contact with people. Contaminated surfaces - equipment, shared items. Compromised skin - cuts, abrasions. Crowding - assembly areas. Lack of cleanliness - absence of proper hygiene or housekeeping.

o MRSA prevention is based on awareness, cleanliness and education. Disinfect areas most likely to be contaminated with one part bleach and ten parts water. Wash hands regularly with soap and water or use 60% or more alcohol sanitizer. Keep cuts and wounds clean and covered by bandages until healed.

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Develop a written cleaning schedule listing items and surfaces to be disinfected using bleach or alcohol where applicable.

Bandages should be discarded in a separate plastic bag. Remove bandages while wearing plastic gloves and discard with bandage.

- TB - Tuberculosis. - Hepatitis B Virus.

There is a potential for exposure to communicable diseases through the following conditions:

- Punctures. - Lacerations. - Mucous membrane exposure (splash in eye or nose). - Contamination of open wound.

Immediately following exposure to communicable diseases the following steps should be taken:

- Lacerations and punctures should be cleansed with topical antiseptic solution and 60% or higher alcohol. - Mucous membrane exposure (eye, mouth, nose or ear) should be flushed with water. - Employee should report the exposure to foreman immediately and complete worker compensation injury

report notifying our office of exposure. - Employee should call City Construction’s, Inc. company doctor for an evaluation and treatment instructions.

Call 911 first if it is a potential life-threatening situation. - Tetanus vaccine should be administered if not previously done within the last ten years. - We will complete Employers First Report of Injury Form (101).

Employee cooperation is required for infection control.

- Employee will be required to participate in medical follow up. - If employee refuses to be tested for HIV, AIDS, virus, MRSA, etc. employee must sign a release form. - Workers compensation carrier will be notified of the incident and all action taken to date. - Physical exams and lab tests will be completed based upon the most current Center for Disease Control

(CDC) protocol. - Employee will sign a consent form for testing. - Employee shall be evaluated clinically and serologically for evidence of infection as soon as possible after

exposure. - If employee does not want to continue follow up after initial testing demonstrates negative antibody

response the employee must sign a release slip.

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Blood borne Pathogens Purpose In compliance with Federal Register 1910.1030(c) (1) (I) we have designed our Blood Borne Pathogens Control Program to eliminate or minimize employee exposure to blood borne pathogens. All foremen are to have a copy of Federal Register 1910.1030 in their procedure manuals for training and reference. Training Employees will receive instructions on how they can access a copy of our Blood Borne Pathogens Exposure Control Program which is part of our Safety Program at time of hire at our office. Employees will receive blood borne pathogens awareness training from our foremen at an orientation tool box meeting prior to beginning work at a job site. Employees will receive extensive blood borne pathogen training at annual safety training sessions scheduled each year. Employees will be notified of date, time and place of training by payroll check attachment. Attendance is mandatory. Scope This program addresses all occupational exposure to blood or other potentially infectious materials. OSHA requires that all employers that can "reasonably anticipate exposure" of employees to infectious material to prepare and implement a written exposure control plan. Exposure Control Employees who work at job sites that have the following conditions have the potential for exposure to blood borne pathogens:

- Effluent drained on ground when workers hook up to sewer systems. - Exposure to contaminants in portable toilets. - Accidents on the jobsite. - Bodily fluids from fellow workers.

All foremen are to have a first aid kit in their vehicle. Direct access to the first aid kits is limited to foremen. Only foremen are authorized to render first aid and they are limited to treatment of minor cuts and abrasions only. Medically trained personnel are not provided by the company. “Good Samaritan” acts such as assisting another worker with an injury is considered an occupational exposure. Through our Blood Borne Pathogens Exposure Control Program we provide awareness training of blood borne pathogen hazards to all employees. Universal precautions should be observed to prevent contact with blood or potentially infectious materials. Where it is difficult to differentiate between body fluid types all such body fluids shall be considered potentially infectious materials. If there has been an exposure incident, you are entitled to a confidential medical evaluation and follow up;

- However, you must report such an incident to your foreman immediately, - Complete a Report of Significant Work Exposure to Bodily Fluids form and submit it to the office.

o Your Report of Significant Work Exposure to Bodily Fluids form must be filed with our office immediately but in no case later than ten calendar days after your exposure to bodily fluids.

o You must have blood drawn no later than ten calendar days after exposure.

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o You must have blood tested for HIV by antibody testing no later than thirty calendar days after exposure and test results must be negative.

o You must be tested or diagnosed as HIV positive no later than eighteen months after exposure. o You must file a worker’s compensation claim with the Industrial Commission of Arizona no later

than one year from the date of diagnosis or positive blood test if you wish to receive benefits under the worker’s compensation system.

- Foremen are to complete our Foreman’s Report of Injury and Investigation form when a blood borne pathogens exposure incident is reported to them and submit the report to Dennis Fallon, RSO.

- It is our policy that medical care will be provided for employees who have been exposed to a communicable disease on the job. We will ensure job placement does not compromise the health and safety of employees. We will maintain confidentiality of all records.

Hygiene City Construction, Inc. will provide hand washing facilities which are readily accessible to employees. When provision of hand washing facilities is not feasible, the Company will provide either an appropriate antiseptic hand cleanser in conjunction with clean cloth/paper towels or antiseptic towelettes. When antiseptic hand cleansers or towelettes are used, hands will be washed with soap and running water as soon as feasible. City Construction, Inc. will ensure that employees wash their hands immediately or as soon as feasible after removal of gloves or other personal protective equipment City Construction, Inc. will ensure that employees wash hands and any other skin with soap and water, or flush mucous membranes with water immediately or as soon as feasible following contact of such body areas with blood or OPIM. Personal Protective Equipment Where occupational exposure remains after institution of engineering and work practice controls, City Construction, Inc. will provide, at no cost to the employee, appropriate personal protective equipment such as, but not limited to, gloves, gowns, laboratory coats, face shields or masks and eye protection, and mouthpieces, resuscitation bags, pocket masks, or other ventilation devices. Personal protective equipment will be considered "appropriate" only if it does not permit blood or OPIM to pass through to or reach the employee's work clothes, street clothes, undergarments, skin, eyes, mouth, or other mucous membranes under normal conditions of use and for the duration of time which the protective equipment will be used. City Construction, Inc. will ensure that the employee uses appropriate personal protective equipment unless the Company shows that the employee temporarily and briefly declined to use personal protective equipment when, under rare and extraordinary circumstances, it was the employee's professional judgment that in the specific instance its use would have prevented the delivery of health care or public safety services or would have posed an increased hazard to the safety of the worker or co-worker. When the employee makes this judgment, the circumstances will be investigated and documented in order to determine whether changes can be instituted to prevent such occurrences in the future. City Construction, Inc. will encourage employees to report all such instances without fear of reprisal. City Construction, Inc. will ensure that appropriate personal protective equipment in the appropriate sizes is readily accessible at the worksite or is issued to employees. Hypoallergenic gloves, glove liners, powderless gloves, or other similar alternatives will be readily accessible to those employees who are allergic to the gloves normally provided. City Construction, Inc. will clean, launder, and dispose of personal protective equipment required by applicable OSHA regulations, at no cost to the employee. The Company will repair or replace personal protective equipment as needed to maintain its effectiveness, at no cost to the employee. If a garment(s) is penetrated by blood OPIM, the garment(s) will be removed immediately or as soon as feasible. All personal protective equipment will be

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removed prior to leaving the work area. When personal protective equipment is removed it will be placed in an appropriately designated area or container for storage, washing, decontamination or disposal. Our staff employs the following practices:

- All equipment and surfaces are cleaned and decontaminated after contact with blood or other potentially infectious materials.

- Protective coverings (such as plastic trash bags or wrap, aluminum foil or absorbent paper) are removed and replaced.

- All trash containers, pails, bins, and other receptacles intended for use routinely are inspected, cleaned and decontaminated as soon as possible if visibly contaminated.

- Potentially contaminated broken glassware is picked up using mechanical means (such as dustpan and brush, tongs, forceps, etc.).

Hepatitis B Vaccination City Construction, Inc. will make available the hepatitis B vaccine and vaccination series to all employees who have occupational exposure, and post-exposure evaluation and follow-up to all employees who have had an exposure incident at no cost to the employee. City Construction, Inc. will advise an employee following an exposure incident that the employee may refuse to consent to post-exposure evaluation and follow-up from the Company-healthcare professional. When consent is refused, City Construction, Inc. will make immediately available to exposed employees a confidential medical evaluation and follow-up from a healthcare professional other than the exposed employee's Company- healthcare professional. Recordkeeping Medical Records. City Construction, Inc. will establish and maintain an accurate record for each employee with occupational exposure, in accordance with the OSHA regulation. This record will include:

- The name and social security number of the employee; - A copy of the employee's hepatitis B vaccination status including the dates of all the hepatitis B

vaccinations and any medical records relative to the employee's ability to receive vaccination as required by the OSHA regulation;

- A copy of all results of examinations, medical testing, and follow-up procedures as required by the OSHA regulation;

- City Construction’s, Inc. copy of the healthcare professional's written opinion as required by the OSHA regulation; and

- A copy of the information provided to the healthcare professional as required by the OSHA regulation. City Construction, Inc. will ensure that employee medical records required by subsection (h) (l) are:

- Kept confidential; and - Not disclosed or reported without the employee's express written consent to any person within or outside

the workplace except as required by this section or as may be required by law. - City Construction, Inc. will maintain the records required by the OSHA regulation for at least the duration of

employment plus 30 years in accordance the applicable OSHA section. Training Records Training records will include the following information:

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- The dates of the training sessions; - The contents or a summary of the training sessions; - The names and qualifications of persons conducting the training; and - The names and job titles of all persons attending the training sessions.

Training records will be maintained for 3 years from the date on which the training occurred.

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Benzene Safety This safety guideline is intended to provide suitable information to all City Construction, Inc., employees regarding the potential toxic effects of Benzene so that adequate measures can be taken to limit exposures through controls in the workplace. Purpose Of all the hydrocarbons, Benzene poses the most serious long-term threat. Exposure over time, to even low levels of Benzene can cause leukemia, blood changes and aplastic anemia. Benzene is a cancer-causing agent in humans. All contact should be reduced to the lowest possible level. Skin contact may also cause overexposure. Benzene is one of the most hazardous of all petroleum products because of its adverse health hazards and high flammability. Smoking is prohibited in areas where benzene is used or stored. Fire extinguishers must be readily available in areas where benzene is used or stored. Benzene liquid is highly flammable and vapors may form explosive mixtures in air. Characteristics Benzene is a colorless to light-yellow liquid with a pleasant sweet odor. - Formula (C6H6) - CAS No.: 71-43-2 Benzene is a flammable liquid that can accumulate static electricity. Benzene vapors are heavier that air and may travel to a source of ignition and flash back. The vapors are readily dispersed by wind movement and/or air currents. Liquid benzene tends to float on water and may travel to a source of ignition and spread fire. Benzene is highly reactive with no oxidizing materials. Uses Benzene is a component of gasoline, both in the manufacturing process and found naturally in crude oil; Benzene is also used as a feed stock for chemical manufacturing. Health Effects The following adverse health effects are important to remember where there may be a potential exposure to Benzene:

- Acute: At high concentrations (1000 PPM) Benzene has an acute effect on the central nervous systems causing headaches, dizziness, drowsiness, unconsciousness, and possible death. Acute exposure can also cause breathlessness, irritability, and giddiness.

- Chronic: Benzene has the chronic exposure effect on bone marrow (aplastic anemia leukemia). Chronic exposure can also cause convulsions, liver damage, heart damage, blood diseases (aplastic anemia), and cancer (leukemia). These symptoms can take months or years to surface and can develop without physical or visible indications. Repeated skin contact leads to irritant contact dermatitis (rash); as with any petroleum solvent (which Benzene is also classified as), it will leach the natural oils out of the skin. Direct contact with the skin can cause erythematic and/or blistering.

- Benzene is irritating to eyes and mucous membranes. - Flammable/dangerous fire risk: benzene has a very low flash point making it dangerous to have any open

flame, spark or source of ignition when vapors are present. - Explosive limits in air 1.5 to 8% by volume: benzene is highly flammable at low levels of vapor quantity in

air.

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Benzene is a cancer-causing agent in humans. All contact should be reduced to the lowest possible level. The above exposure limits are for air levels only. Skin contact may also cause overexposure. Benzene is one of the most hazardous of all petroleum products because of its adverse health hazards and high flammability. Smoking is prohibited in areas where benzene is used or stored. Fire extinguishers must be readily available in areas where benzene is used or stored. Benzene liquid is highly flammable and vapors may form explosive mixtures in air. Personal Protective Measures City Construction, Inc., employees are not permitted to work in areas where there may be a potential for Benzene exposure. It is the responsibility of the Contracting Company’s Project Manager and the on-site supervisor/foreman to see that any jobsite that may expose employees to Benzene is not manned with personnel until it is proven that it is safe to work within the acceptable OSHA limits without the additional personal protective equipment needed for Benzene. Permissible Exposure Limits City Construction, Inc., shall assure that no employee is exposed to an airborne concentration of benzene in excess of one part of benzene per million parts of air (1 ppm) as an 8-hour time-weighted average. Special Requirements City Construction, Inc., employees are currently prohibited from working in areas that are over OSHA limits. If it is necessary to perform any work where the exposure to Benzene is above the OSHA acceptable limits, then the company must implement a comprehensive OSHA mandated special safety policy and procedure that includes special elements of exposure monitoring, formal medical program, special personal protective equipment, and much more. Training All employees will be provided awareness training in this program in order to be familiar with the potential hazards and proper safe work procedures to follow if exposed to this health hazard. Employees should be aware of clients' contingency plans and provisions. Employees must be informed where benzene is used in the host facility and aware of additional plant safety rules. Emergency Evacuation Plan Under this plan, our employees are informed of the plan's purpose, preferred means of reporting fire, exposure and other emergencies, types of evacuations to be used in various emergency situations, and the alarm system. The plan is closely tied to our emergency action plan where procedures are described for emergency escape procedures and route assignments, procedures to account for all employees after emergency evacuation has been completed, rescue and medical duties for those employees who perform them. Please see the emergency action plan for this information. Hydrogen Sulfide Safety This safety guideline is intended to provide suitable information to all City Construction, Inc., employees regarding the potential toxic effects of Hydrogen Sulfide so that adequate measures can be taken to limit exposures through

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controls in the workplace. As part of the work of City Construction, Inc. our employees may be exposed to Hydrogen Sulfide especially when working in confined spaces, underground vaults, and manholes. Purpose The purpose of this program is to inform interested persons, including employees, that City Construction, Inc. is complying with OSHA's Gases, Vapors, Fumes, Dusts, and Mists standard, Title 29 Code of Federal Regulations 1926.55 and other OSHA rules as needed to ensure that no employee is exposed to inhalation, ingestion, skin absorption, or contact with any material or substance at a concentration above those specified in the "Threshold Limit Values of Airborne Contaminants for 1970" of the American Conference of Governmental Industrial Hygienists found in Appendix A of 29 CFR 1926.55. This program will address potential exposures to Hydrogen Sulfide. Characteristics Hydrogen sulfide is a colorless, flammable, extremely hazardous gas with a “rotten egg” smell. - Formula (H2S) It occurs naturally in crude petroleum and natural gas, and can be produced by the breakdown of organic matter and human/ animal wastes (e.g., sewage). It is heavier than air and can collect in low-lying and enclosed, poorly ventilated areas such as basements, manholes, sewer lines and underground telephone/electrical vaults. Exposure Detection - Site Supervisor shall conduct personal or area sampling for hydrogen sulfide to measure worker exposures. Air

sampling is needed to measure worker exposures and select appropriate engineering controls and respiratory protection.

- DO NOT depend on your sense of smell for indicating the continuing presence of this gas or for warning of hazardous concentrations.

- Can be smelled at low levels, but with continuous low level exposure or at higher concentrations you lose your ability to smell the gas even though it is still present.

- At high concentrations – your ability to smell the gas can be lost instantly. Health Effects Health effects vary with how long, and at what level, you are exposed. Asthmatics may be at greater risk:

- Low concentrations – irritation of eyes, nose, throat, or respiratory system; effects can be delayed. - Moderate concentrations – more severe eye and respiratory effects, headache, dizziness, nausea,

coughing, vomiting and difficulty breathing. - High concentrations – shock, convulsions, unable to breathe, coma, death; effects can be extremely

rapid (within a few breaths).

Permissible Exposure Levels (PEL) While not definitive, an H2S level below 10 ppm appears to cause little short term effects. Current OSHA standards are:

- 20 ppm Ceiling Level

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- 50 ppm Maximum allowable peak for 10 minutes with no other exposure Current NIOSH standards are:

- 10 ppm PEL averaged over 10 minute period - 50 ppm area shall be evacuated

Personal Protective Measures Before Entering Areas with Possible Hydrogen Sulfide:

- The air needs to be tested for the presence and concentration of hydrogen sulfide by a qualified person using test equipment. This individual also determines if fire/explosion precautions are necessary.

- If gas is present, the space should be ventilated and the use of fixed or portable monitors that will alarm at the appropriate permissible exposure limits.

- If the alarm sounds all City Construction, Inc. employees will evacuate the area until the area reaches permissible levels.

- If the gas cannot be removed to permissible levels, City Construction, Inc. employees are prohibited from entry.

- Atmospheres containing high concentrations (greater than 100 ppm) are considered immediately dangerous to life and health (IDLH) and a self-contained breathing apparatus (SCBA) is required.

Special Requirements City Construction, Inc., employees are currently prohibited from working in areas that are over OSHA limits. If it is necessary to perform any work where the exposure to Hydrogen Sulfide is above the OSHA acceptable limits, then the company must implement a comprehensive OSHA mandated special safety policy and procedure that includes special elements of exposure monitoring, formal medical program, special personal protective equipment, and much more. Training All employees will be provided awareness training in this program in order to be familiar with the potential hazards and proper safe work procedures to follow if exposed to this health hazard. Employees should be aware of clients' contingency plans and provisions. Employees must be informed where Hydrogen Sulfide is present in the host facility and aware of additional plant safety rules. Emergency Evacuation Plan Under this plan, our employees are informed of the plan's purpose, preferred means of reporting fire, exposure and other emergencies, types of evacuations to be used in various emergency situations, and the alarm system. The plan is closely tied to our emergency action plan where procedures are described for emergency escape procedures and route assignments, procedures to account for all employees after emergency evacuation has been completed, rescue and medical duties for those employees who perform them. Please see the emergency action plan for this information.

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Spill Response Policy Purpose The purpose of this Policy is to establish procedures and reporting requirements for spills of hazardous materials. Policy It is the policy City Construction, Inc. to comply with all Federal, State, and local regulations pertaining to hazardous materials incidents. The safety of City Construction, Inc. personnel and the public is of primary importance. Environmental protection is also of extreme importance during a hazardous material release. City Construction, Inc. is committed to protecting the natural resources including air, water, and soil during a hazardous material release. Definitions

- “Business Plan” – a plan that requires disclosure of hazardous materials being used or stored by City Construction, Inc. and a strategy to respond to emergencies involving these chemicals.

- “First Responder Awareness Level” – an individual who is likely to witness or discover a hazardous substance release and who has been trained to initiate an emergency response sequence by notifying the proper authorities of the release.

- “First Responder Operations Level” – an individual that would respond to a release or potential releases. These individuals are trained to respond in a defensive fashion (e.g. dike spill from entering a storm drain), isolate the area around the release, and make notifications regarding the release without actually trying to stop the release. Their function is to contain the release from a safe distance, keeping it from spreading, and preventing exposures.

- “Level C” – personal protective equipment that shall be used when the types and concentrations of respirable chemical hazards have been assessed, the types of hazards are known, and employee protection will be assured. This level includes air purifying respirator, one or two piece suit, gloves, and boots with steel toes, hard hat, and cloth coveralls.

- “Level D” – personal protective equipment that is “the basic work uniform” and should only be worn when operations are identified as presenting no chemical hazards to personnel.

- “Release” – any spill, leak, pumping, pouring, emitting, emptying, discharging, injecting, escaping, leaching, dumping, or disposing of hazardous substances into the environment.

Responsibilities Dennis Fallon, RSO:

- Will ensure that this Spill Response Policy is implemented within City Construction, Inc. - Has the authority to delegate any or all portions of the Spill Response Policy to subordinates, but the RSO

will be held responsible for compliance. - First Responder Operations Level training if determined applicable. - Update and maintain the Spill Response Policy on an annual basis. - Provide assistance in the training of employees under the OSHA HAZWOPER Standard. - Provide guidance, advice, and assistance to management to achieve compliance with this Policy.

Employees shall:

- Adhere to all aspects of this Policy when involved in a spill response.

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- Annually attend HAZWOPER training if determined applicable by the RSO. Procedure Spill Notifications Three major laws require DEP to be notified of a spill or release of material to the environment:

- The Pennsylvania Clean Streams Law regulations require that when any pollutant is discharged into surface or groundwater, including sewers, drains and ditches, the person spilling the substance or the person owning the premises from which the substance is spilled must notify the Department immediately. Note that there is no reportable quantity that the requirement includes groundwater, and practically all substances are reportable.

- The Solid Waste Act requires the generator or the transporter to notify the Department immediately if there is a spill of a hazardous waste which affects surface water or groundwater regardless of amount. If there is no effect on water, quantities spilled in excess of a reportable quantity (RQ) must be reported. While the state RQs are fairly complex, it is a conservative assumption to say that all spills of hazardous wastes above five gallons must be reported.

- The Pennsylvania Storage Tank Act requires releases from underground and aboveground storage tanks be reported to the Department by the owner/operator.

Note that the regulatory requirement to report a release to DEP is on the person responsible for the discharge; it is not on the emergency response community. In the event of water runoff from firefighting activities, the fire company is technically responsible for the discharge. For this reason, DEP asks to be notified when firefighting activities may have an effect on a stream. However, regardless of the regulatory requirement, voluntary reporting to the Department is encouraged in the following situations by the incident commander:

- All spills in excess of five gallons of any hazardous material. - All petroleum spills of five gallons or more with potential to pollute. - Air pollution incidents where there may be a release of toxic materials or where smoke from a fire may

create a public nuisance. - Incidents which involve illegal/improper disposal of any material.

State Law requires immediate verbal report of any release or threatened release of a hazardous material that may cause harm to human health or the environment. If you have a release or a threatened release of hazardous materials, immediately call: Police/Paramedics/Fire Phone: 911 After the local emergency response personnel are notified, the supervisor at the spill, who is trained at the First Responder Operations Level, shall notify: DEP - 484-250-5900 DEP prefers that notifications be made to the appropriate regional office. DEP also maintains a statewide toll free number, 1-800-541-2050, which serves as a backup to the regional numbers and also supports a reporting mechanism for people who do not know which regional office is responsible for a particular area. City Construction, Inc. personnel shall not try to positively identify any released hazardous material. City Construction, Inc. personnel shall be trained in passive modes of hazardous material identification. Several agencies recognize a strategy for establishing levels of response to hazardous material releases depending on the severity of the situation.

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Response classification can be categorized into three levels as follows: - Level 1: An incident which can be controlled by the first response agencies and does not require immediate

evacuation of other than the involved structure or the immediate outdoor area. The incident is confined to a small area and does not pose an immediate threat to life or property.

- Level 2: An incident involving a greater hazard or larger area which poses a potential threat to life or property and which may require a limited evacuation of the surrounding area.

- Level 3: An incident involving a severe hazard or large area which poses an extreme threat to life and property and will probably require a large scale evacuation; or an incident requiring the expertise or resources of County, State, Federal, or private organizations.

Other important telephone numbers at the national level include: - National Response Center: (800) 424-8802 for notification, information, and assistance involving Federal

agencies. - CHEMTREC (800) 424-9300, for information and assistance in identifying a hazardous material that has

been released. Training When City Construction, Inc. employees will handle emergency releases, OSHA requires the following levels of training depending on the extent to which the employee will be involved with the response operation:

- First responder awareness level -This level of training is a “baseline” training appropriate for anyone likely to encounter a hazardous materials spill at your facility. These employees need to know the dangers of chemicals stored at the facility, as well as whom to contact so that those who have received more in-depth training can initiate the proper response. This training will be conducted annually.

- First responder operations level - In addition to recognizing a spill and notifying others, employees trained to operations level can initiate basic spill control, containment or confinement measures, but will not actually be involved with stopping the flow of a release or with spill cleanup measures. These employees can also implement decontamination procedures. This training will be conducted annually.

Note: If first responders are not present or properly trained all employees are to evacuate the facility in the event of a spill and use outside resources for response and clean up: Dispose Hazardous Waste – 888-290-8629

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Crane and Derrick Operation Procedures These written Crane & Derrick Operation Procedures establish guidelines to be followed for the use of cranes or derricks owned or operated by City Construction, Inc. These procedures establish uniform requirements designed to ensure that crane and derrick safety training, operation, and maintenance practices are communicated to and understood by the affected employees. These requirements are also designed to ensure that procedures are in place to protect the health and safety of all employees.

These rules are established to:

- Provide a safe working environment, - Govern operator use of cranes and derricks, and - Ensure proper care and maintenance of cranes and derricks.

It is our intent to comply with OSHA requirements for construction activities. These regulations have requirements for crane and derrick operations. Subcontractors must also comply with the applicable requirements of:

Standard or Regulation Name: Details: ANSI B15.1-1958 Safety Code for Mechanical

Power Transmission Apparatus For Guarding

ANSI B30.5-1968 Or SAE J959-1966

Mobile and locomotive Cranes Or Lifting Crane, Wire-Rope Strength Factors for Rope Safety Factors

ANSI B30.6-1969 Safety Code for Derricks For derricks Power Crane and Shovel Association Mobile Hydraulic Crane Standard No. 2

SAE J743a-1964 Pipe Layers and Side Booms – Tractor Mounted Specifications and Tests

For side boom cranes mounted on wheel or crawler tractors

29 CFR 1926.106 Working Over or Near Water For work over water 29 CFR 1926, Subpart M Fall Protection Fall Protection 29 CFR 1926.605 Marine Operations and Equipment For marine vessels 49 CFR 177 Carriage by Public Highway For transporting fuel by vehicles

on public highways 49 CFR 393 Parts and Accessories Necessary

for Safe Operation Parts and Accessories Necessary for Safe Operation

Administrative Duties The RSO is responsible for developing and maintaining the written Crane & Derrick Operation Procedures. These procedures are kept in the Jobsite Trailer and/or RSO's office. As specified under OSHA regulations, our Crane & Derrick Operation Procedures are administered under the direction of the Company's competent person(s), someone capable of identifying existing and predictable hazards in the surroundings or working conditions which are unsanitary, hazardous, or dangerous to employees, and who has authorization to take prompt corrective measures to eliminate them.

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Training It will be the policy of City Construction, Inc. to permit only trained and authorized personnel to operate cranes and derricks. The Dennis Fallon will identify all new employees in the employee orientation program and make arrangements with department management to schedule training. Before training a new employee, the Crane & Derrick Operation Procedures Administrator, Dennis Fallon, determines if the potential crane or derrick operator is capable of performing the duties necessary to be a competent and safe operator. This is based upon his/her physical and mental abilities to perform job functions that are essential to the operation of the crane or derrick. These capabilities include the level at which the operator must:

- See and hear within reasonably acceptable limits. This includes the ability to see at distance and peripherally;

- Endure the physical demands of the job; and - Endure the environmental extremes, such as the ability of the person to work in areas of excessive cold

or heat. An operator must be able to climb onto and off of a crane, to sit in the crane for extended periods of time, and to turn his/her body to look in the direction of travel when driving in reverse.

Once the Administrator determines that a potential operator is capable of performing crane and derrick duties he/she and the Supervisor will conduct initial training and evaluation. This/These instructor(s) has the necessary knowledge, training, and experience to train new crane and derrick operators. Initial Training Training will include both classroom and practical instruction. Each type of crane or derrick has a different "feel" to it, and that makes operating it slightly different from operating other cranes or derricks. The work areas where these cranes or derricks are being used also present particular hazards. For these reasons, it is impractical to develop a single "generic" training program that fits all of our cranes and derricks. Accordingly, during training, the [RSO] must cover the operational hazards of our cranes and derricks, including:

- Hazards associated with the particular make and model of the crane and derrick; - Hazards of the workplace; and - General hazards that apply to the operation of all or most cranes and derricks.

Each potential operator who has received training in any of the elements of the training program for the types of cranes or derricks which that employee will be authorized to operate and for the type of workplace in which the cranes or derricks will be operated need not be retrained in those elements before initial assignment in our workplace if the [RSO] has written documentation of the training and if the employee is evaluated to be competent. Training Certification After an employee has completed the training program, the instructor will administer a performance test or practical exercise to determine whether the potential operator can safely perform the job. At this point the instructor will determine if the training has been adequate. All crane and derrick trainees are tested on the type of equipment they will be operating.

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Dennis Fallon is responsible for keeping records certifying that each operator has successfully completed training and testing. Each certificate includes the name of the operator, the date(s) of the training, and the signature of the person who did the training and evaluation. Performance Evaluation Each certified crane/derrick operator is evaluated annually to verify that the operator has retained and uses the knowledge and skills needed to operate safely. This evaluation is done by Dennis Fallon and the Supervisor. If the evaluation shows that the operator is lacking the appropriate skills and knowledge, the operator is retrained by our instructor(s). When an operator has an accident or near miss or some unsafe operating procedure is identified, we do retraining. Current Crane/Derrick Operators Under no circumstances shall an employee operate a crane or derrick until he/she has successfully completed the company's crane/derrick training program. This includes all new operators regardless of claimed previous experience. Initial Inspections The company inspects and tests all cranes and derricks to ensure they are capable of safe and reliable operation when initially set or placed in service and after any major repairs or design modification. The Maintenance Department is responsible for these inspections and tests. The attached checklist is a minimum and can be used to assist in performing the Initial Inspection. Frequent Inspections There are four frequent inspections:

- Pre-Operational Site Activity and Inspection - Pre-Operational (Daily) Walk Around Inspection - Pre-Start-Up (In Cab) Inspection - Crane Operation Checklist.

Pre-Operational Site Activity and Inspection Accidents can be avoided by careful job planning. The Supervisor has a clear understanding of the work to be performed and considers all potential dangers at the job site. Periodic Inspections Periodic inspections include both monthly by our maintenance department and annual inspections by a manufacturers approved service company. These inspections are documented and kept on file in the maintenance department. Operating Procedures Cranes and derricks can create certain hazards that only safe operation can prevent. That's why we have created a set of operating procedures. Our operating procedures follow:

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General Procedures

- Outriggers will be visible to the operator or a signal person during extension or setting. - No one except the oiler, instructor, or competent person will be allowed on an operating crane. - All equipment will comply with the manufacturer's specifications and limitations at all times. - All attachments used with heavy construction equipment will not exceed the capacity, rating, or scope

recommended by the manufacturer. - Operations must not begin unless all safety devices are in proper working order. If a device stops working

properly during operations, the operator must safely stop operations. If any of the safety devices are not in proper working order, the equipment must be taken out of service and operations must not resume until the device is again working properly.

Procedures for Operators

- Do not operate a crane or derrick unless you are qualified and properly designated. A qualified person is one who, by possession of a recognized degree, certificate, or professional standing, or who by extensive knowledge, training, and experience, has successfully demonstrated his/her ability to solve or resolve problems relating to the subject matter, the work, or the project. A designated person is an authorized person approved or assigned by the employer to perform a specific type of duty or duties or to be at a specific location or locations at the job site.

- A visual inspection of the equipment will be conducted by a competent person prior to each shift. - If the operator has concern over safety the operator has the authority to stop and refuse to handle loads

until a qualified person has determined that it is safe. - Do not hoist, lower, swing, or travel while anyone is on the load or hook. This includes riding a bare hook or

a load of material such as beams, girders, or concrete buckets. - Do not use a crane or derrick to handle materials or loads stored under electric power lines. - Use nonconductive taglines, rather than direct contact lines, to stabilize the load. - Use insulating boots and gloves when connecting loads or contacting the crane or derrick while in the

vicinity of overhead lines. - Signal persons must understand the hand signals for the type of crane you are working with. - (These hand signals are posted at the job site.) - When performing duties on the horizontal boom of hammerhead tower cranes that do not protect you with

guardrails, protect yourself against falling by wearing safety belts and lanyards attached to lifelines. - Keep the crane clean and free of clutter. - Know how to read the load rating chart. - Do not lift a load without knowing whether it is within the rated capacity of the crane or derrick. - Stay within the rated load capacity and working radius. Under adverse field conditions, reduce the load

capacity until it is determined the crane or derrick can safely handle the lift. - When working at boom lengths or radii between the figures shown on the load capacity chart, use the next

lower capacity rating. It is dangerous to guess the capacity for boom lengths or radii between those listed on the rating plate.

- Do not lift a load when winds create an unsafe or hazardous condition. Even a light wind can blow the load out of control, collapse a boom, or tip the machine.

- Take proper precautions when the velocity of wind exceeds 20 mph. If possible, lower or secure booms under high wind conditions.

- Do not use counterweights heavier than the manufacturer's specified weight. - When the machine set is not level, understand that the crane capacity and structural integrity can be

adversely affected. - Keep your feet on the pedals while foot pedal brake locks are in use. Brakes could cool allowing the load to

fall.

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Procedures for All Employees

- All employees will be kept clear of loads about to be lifted and suspended loads. Procedures for Employees When Using the Suspended Personnel Platform Hoist Employees can also contribute to safe personnel hoisting operations and help to reduce the number of accidents and injuries associated with personnel hoisting operations. Employees must adhere to the following safe work practices:

- Never ride the load; use only platforms specifically designed for personnel lifting. - Use tag lines where they are practical and do not create an unsafe condition. - Keep all body parts inside the platform during raising, lowering, and positioning. - Make sure the platform is secured before exiting or entering unless it creates an unsafe situation. - Use fall protection equipment properly. (Refer to appropriate OSHA regulations). - Do not hoist any load while personnel platforms are in use. - Perform any movement slowly and cautiously without any sudden jerking of the crane or platform. - Stay in view of or in direct communication of the signal person. If this is not possible, and use of a signal

person would create a greater hazard, direct communication alone, such as by radio, may be used. - Do not hoist personnel while the crane is traveling except when the employer demonstrates that it is the

least hazardous way to accomplish a task or when portal, tower, or locomotive cranes are used. When cranes are moving while hoisting personnel, obey these rules:

o Restrict travel to a fixed track or runway. o Limit travel to the radius of the boom during the lift. o Keep the boom parallel to the direction of travel. o Do not allow employees to occupy the platform until a complete trial run has been performed. o Do not hoist personnel until the condition and air pressure of the tires (if made of rubber) is

checked and the chart capacity for lifts is applied to remain under the 50 percent limit of the hoist's rated capacity.

Maintenance Any deficiencies found in our cranes and derricks are repaired, or defective parts replaced, before continued use. However, no modifications or additions that affect the capacity or safe operation of the equipment may be made without the manufacturer's written approval. If such modifications or changes are made, the capacity, operation, and maintenance instruction plates, tags, or decals, must be changed accordingly. In no case may the original safety factor of the equipment be reduced. City Construction, Inc. is responsible for ensuring the cranes and derricks are capable of safe and reliable operation after any major repair or design modification. While defective parts may be found, we prefer to invest time and effort into the proper upkeep of our equipment, which results in day-to-day reliability. Keeping up with the manufacturer's recommended maintenance schedules, and completing the proper records, will also increase our cranes' and derricks' longevity and enhance their resale value. The Maintenance Department completes a receiving or delivery inspection whenever our company purchases cranes or derricks, and he/she/they performs the recommended "breaking in" inspections and maintenance. City Construction, Inc. follows the manufacturer's operator instruction manual for daily maintenance. Periodic maintenance (those completed monthly or less frequently) is done by a factory-trained-expert, or a dealer. Assembly / Disassembly When assembling and disassembling crane/derrick (or attachments), City Construction, Inc. will comply with all applicable manufacturer prohibitions and procedures applicable to assembly and disassembly.

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Assembly/disassembly must be directed by a person who meets the criteria for both a competent person and a qualified person, or by a competent person who is assisted by one or more qualified persons (assembly/disassembly director). Posting In order to aid in the use of consistent hand signals for crane and derrick operations, we post the signals at the job site. Rated load capacities, recommended operating speeds, special hazard warnings, i.e., electrical power line clearance requirements, operating procedures, or instructions are posted and visible to the operator while at the control station. Recordkeeping & Certification The Company is responsible for maintaining the following records on file:

- The log of all monthly periodic inspections on critical items in use (i.e., brakes, crane hooks, and ropes), and include:

o The date the crane items were inspected, o The signature of the person who inspected the crane items, o A serial number, or other identifier, for the crane inspected, and o The most recent certification record (maintained on file until a new one is prepared). o The most recent monthly periodic inspection (certification) record.

- A record of the annual inspection for each hoisting machine and piece of equipment used, including the dates and results of the inspection.

- Inspection reports for the annual magnetic particle or other suitable crack detecting inspection. Maintenance Records The following maintenance records will be kept:

- Any results of any equipment specifications and limitations made by a qualified engineer. (If we do not have manufacturer's specifications and limitations for our equipment, determination of those limitations is made by a qualified engineer.)

- Any written approval from the manufacturer of any modifications or additions that affect the capacity or safe operation of our equipment. In no case will the original safety factor of the equipment be reduced.

- Any tests to see that employees are not exposed to unsafe concentrations of toxic gasses or oxygen deficient atmospheres. (If our crane is going to be operated in an enclosed space, tests will be made.)

Effective Nov. 8, 2010, the new OSHA-Crane and Derrick Standard changes the way cranes are used in the construction industry: These are the additions to the program to comply with the new standard. Controlling Entity: Dennis Fallon will be considered the controlling entity that has overall responsibility. Crane Rules City Construction, Inc. is responsible for crane operations; therefore, if we lease a crane then City Construction, Inc. is responsible for the safe operation of that crane. If the operator is not an employee, the first thing done is to

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request a copy of the operator's crane certification/license. Also, verify that the crane has been inspected within the last month and annually, as required.

- Cranes must not be assembled or used unless the "ground conditions" (the ability of the ground to support and level the equipment) are firm, drained and level to sufficiently set up the equipment. The controlling entity must ensure ground conditions are prepared to safely support the crane. In addition, City Construction, Inc. must inform the assembly/disassembly (A/D) director and operator of the location of any hazards beneath the surface such as vaults, utilities, tanks, voids, etc. The A/D director and/or the operator have the right to refuse to set up until the ground conditions are suitable to support the equipment and loads.

- Power line clearances must be determined before the crane is set up. There must be enough clearance to ensure that the equipment, load line or load will not get too close to the power line to cause an arc over or make contact with the power line. City Construction, Inc. must identify the work zone to determine if any part of the crane, line or load could get within 20 ft. of a power line of up to 350kV or within 50 ft. of a power line greater than 350kV.

- If part of the crane is within this short distance, the lines must be de-energized and visually grounded or Table A from the standard must be used to determine the minimum clearance required when encroachment is necessary. After determining the clearance, boundaries of the area must be determined and marked or a range limiting and/or control warning device must be used and employees must be informed of the plan.

- When the operator cannot see where he is picking and placing the load, or the view in which the equipment is traveling is obstructed a signal person is required. Sometimes the leasing company provides a signal person along with the operator. In other cases, City Construction, Inc. designates a member of the crew to be the signal person. In both cases, City Construction, Inc. must ensure that the signal person has been trained and meets the qualifications for the type of signals used (e.g. hand, voice, radio, etc.). Signal persons must be qualified by a third party or employer-qualified evaluator, and documentation of their qualifications must be available at the jobsite.

- Riggers are those responsible for hooking, unhooking, guiding the load, selecting and inspecting the sling or rigging needed for safely handling material. The new rule requires that the rigger meets the criteria for a qualified person. The rigger must be trained in the concepts of rigging, types of slings and rigging to be used, types of rigging hardware, the types of hitches that will be used, how to protect the slings and rigging from cuts or damage and how to select and inspect the slings and rigging. Riggers must also know how to determine the weight and center of gravity of a load. Riggers must pass a test and demonstrate the knowledge to safely rig the kinds of loads expected.

Work Area Control City Construction, Inc. is also responsible for controlling the work area. City Construction, Inc. must erect and maintain control lines, warning lines, railings, or similar barriers to mark the swing radius of the equipment. Employees who are assigned to work on or near the equipment must be trained in how to recognize struck-by and pinch/crush hazard areas.

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Rigging Material Handling Purpose The purpose of this training program is to ensure a safe and incident free lifting operation. Scope All City Construction, Inc. employees are to receive training in “rigging”. When work is performed on a non-owned or operated site, the operator’s program shall take precedence, however, this document covers City Construction, Inc. employees and contractors and shall be used on owned premises, or when an operator’s program doesn’t exist or is less stringent. Definitions Rigging - the art or process of safely attaching a load to a hook by means of adequately rated and properly applied slings and related hardware. Qualified Rigger - any person who attaches or detaches lifting equipment that has successfully completed training. Key Responsibilities

- Management shall determine if this program is required for regulatory compliance within his/her region. - Management shall select a training facility or use an in-house qualified trainer to supply and document the

training. - Supervisors shall assist the managers in the tasks described above. The supervisor shall verify that each of

their employees have the proper training before being involved in rigging operations. - Only qualified and trained personnel can attach or detach lifting equipment to loads or lifting loads.

Procedure General Only "qualified riggers" are allowed to attach any loads to a lifting hook and only "qualified operators" are allowed to operate a crane while engaged in lifting operations. Material Handling

- Rigging equipment shall be inspected to ensure it is safe. Rigging equipment for material handling shall be inspected prior to use and on each shift and as necessary during its use to ensure that equipment is safe.

- Defective rigging equipment shall not be used and removed from service.

- Rigging equipment shall not be loaded beyond its recommended safe working load and load identification

shall be attached to the rigging.

- Rigging equipment 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 condition.

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- Hooks on overhaul ball assemblies, lower load blocks, or other attachment assemblies shall be a type that can be closed and locked, eliminating the hook throat opening. Alternatively, 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 lifted and of suspended loads. No employee shall be

allowed under a suspended load. Training and Education City Construction, Inc. employees shall display their competency in the following topics:

- The selection of proper hardware (eye bolts, shackles, hooks, wire rope products, synthetic slings, chain slings, etc.) for the correct application (weight, hitches, angles, temperatures, center of gravity, etc.).

- The inspection of the selected hardware before, during and after the lift. - The proper methods of securing the load, attaching the load to the hook, lifting the load, handling of the

load during the movement of the load and lowering and placement of load. - The proper storage of the rigging equipment. - All City Construction’s Inc. employees shall re-certify their training on a four (4) year basis.

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Excavation, Trenching and Shoring Procedures One of the preventable hazards of site work is the danger of trench cave-ins. Yet every year in the U.S., there are an estimated 75 to 200 deaths and more than 1,000 lost work days per year from trenching accidents. Other hazards associated with trenches include contact with numerous underground utilities, hazardous atmospheres, water accumulation, and collapse of adjacent structures. For these reasons, we have written Excavation Procedures for both our daily and occasional excavation workers. It is the policy at City Construction, Inc. to permit only trained and authorized personnel to create or work in excavations. Definitions Aluminum hydraulic shoring means an engineered shoring system comprised of aluminum hydraulic cylinders (cross braces), used in conjunction with vertical rails (uprights) or horizontal rails (walers). Such a system is designed specifically to support the sidewalls of an excavation and prevent cave-ins. Benching means a method of protecting employees from cave-ins by excavating the sides of an excavation to form one or a series of horizontal levels or steps, usually with vertical or near-vertical surfaces between levels. Cave-in means the separation of a mass of soil or rock material from the side of an excavation, or the loss of soil from under a trench shield or support system, and its sudden movement into the excavation, either by falling or sliding, in sufficient quantity so that it could entrap, bury, or otherwise injure and immobilize a person. Competent person means one who is capable of identifying existing and predictable hazards in the surroundings, or working conditions that are unsanitary, hazardous, or dangerous to employees, and who has authorization to take prompt corrective measures to eliminate them. All competent persons must complete the 4-hour Physical Plant trenching and shoring class, successfully pass the exam, and be certified for successful completion of the class. A competent person should have and be able to demonstrate the following:

- Training, experience, and knowledge of: o Soil analysis, o Use of protective systems, and o Requirements of applicable OSHA regulations.

- Ability to detect: o Conditions that could result in cave-ins, o Failures in protective systems, o Hazardous atmospheres, and o Other hazards including those associated with confined spaces.

- Authority to take prompt corrective measures to eliminate existing and predictable hazards and to stop work when required.

Excavation means any man-made cut, cavity, trench, or depression in an earth surface, formed by earth removal. Registered professional engineer means a person who is registered as a professional engineer. Shield (shield system) means a structure that is able to withstand the forces imposed on it by a cave-in and thereby protect employees with the structure. Shields can be permanent structure or can be designed to be portable and moved along as work progresses. Also known as trench box or trench shield. Shoring (shoring system) means a structure such as a metal hydraulic, mechanical or timber shoring system that supports the sides of an excavation and which is designed to prevent cave-ins.

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Sloping (sloping system) means a method of protecting employees from cave-ins by excavating to form sides of an excavation that are inclined away from the excavation so as to prevent cave-ins. The angle of incline varies with differences in such factors as the soil type, environmental conditions of exposure, and application of surcharge loads. Trench (trench excavation) means a narrow excavation (in relation to its length) made below the surface of the ground. In general, the depth is greater than the width, but the width of a trench is not greater than 15 feet. If forms or other structures are installed or constructed in an excavation as to reduce the dimension measured from the forms or structure to the side of the excavation to 15 feet or less, the excavation is also considered to be a trench. Administrative Duties Dennis Fallon, RSO is responsible for developing and maintaining the written Excavation Procedures. These procedures are kept in the RSO's office. Our Excavation Procedures are administered under the direction of our competent person(s), someone capable of identifying existing and predictable hazards in the surroundings or working conditions which are unsanitary, hazardous, or dangerous to employees, and who has authorization to take prompt corrective measures to eliminate them. These competent persons include Dennis Fallon and all Site Supervisors. Before Excavating Before anyone at this company begins excavating, we follow the steps below:

1. Plan the job and pre-mark the dig area. 2. Call 811 (PA One Call) before you dig if applicable. 3. Wait the required time for marking after your call. 4. If not applicable:

• Contact the utility companies or property owners and ask the companies or owners to find the exact location of the underground installations in the area.

• If the utility companies or owners do not respond within 24 hours or the period established by law or ordinance, or if they cannot establish the location of the utility lines, the excavation may proceed with caution. In this situation, provide employees with detection equipment or other safe and acceptable means to locate utility installations. Remove or adequately support the following objects (i.e., trees, rocks, and sidewalks) in the excavation area that could create a hazard to employees.

5. Perform a pre-excavation site survey. 6. Using applicable OSHA regulations, classify the type of soil and rock deposits at the site as either stable

rock, Type A, Type B, or Type C soil. The soil classification is based on the results of at least one visual and at least one manual analysis conducted by a competent person. Details of the acceptable visual and manual analyses are to be found in the OSHA regulation. NOTE: Soil classification is not necessary if the excavation will be sloped to an angle of one and one-half horizontal to one vertical.

7. Have the competent person choose the appropriate method for protective support systems, as necessary. See the Protective Support Systems section for the procedures he/she used for selecting this system.

8. Respect the marks. 9. Dig Safely.

Testing Methods The competent person in charge of the excavation shall be responsible for determining whether the soil is Type B or C. The competent person shall use a visual test coupled with one or more manual tests.

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Visual test In addition to checking the items on the trench inspection form, the competent person should perform a visual test to evaluate the conditions around the site. In a visual test, the entire excavation site is observed, including the soil adjacent to the site and the soil being excavated. The competent person also checks for any signs of vibration. During the visual test, the competent person should check for crack-line openings along the failure zone that would indicate tension cracks, look for existing utilities that indicate that the soil has been previously disturbed, and observe the open side of the excavation for indications of layered geologic structuring. This person should also look for signs of bulging, boiling, or sloughing, as well as for signs of surface water seeping from the sides of the excavation or from the water table. In addition, the area adjacent to the excavation should be checked for signs of foundations or other intrusions into the failure zone, and the evaluator should check for surcharging and the spoil distance from the edge of the excavation. Manual tests Thumb penetration test-Attempt to press the thumb firmly into the soil in question. If the thumb penetrates no further than the length of the nail, it is probably Type B soil. If the thumb penetrates the full length of the thumb, it is Type C. It should be noted that the thumb penetration test is the least accurate testing method. Dry strength test-Take a sample of dry soil. If it crumbles freely or with moderate pressure into individual grains it is considered granular (Type C). Dry soil that falls into clumps that subsequently break into smaller clumps (and the smaller clumps can only be broken with difficulty) it is probably clay in combination with gravel, sand, or silt (Type B). Plasticity or Wet Thread Test-Take a moist sample of the soil. Mold it into a ball and then attempt to roll it into a thin thread approximately 1/8 inch in diameter by two inches in length. If the soil sample does not break when held by one end, it may be considered Type B. A pocket penetrometer, shearvane, or torvane may also be used to determine the unconfirmed compression strength of soils. Spoil Temporary spoil shall be placed no closer than 2 feet from the surface edge of the excavation, measured from the nearest base of the spoil to the cut. This distance should not be measured from the crown of the spoil deposit. This distance requirement ensures that loose rock or soil from the temporary spoil will not fall on employees in the trench. Spoil should be placed so that it channels rainwater and other run-off water away from the excavation. Spoil should be placed so that it cannot accidentally run, slide, or fall back into the excavation. Permanent spoil should be placed some distance from the excavation. Surface Crossing of Trenches Surface crossing of trenches should not be made unless absolutely necessary. However, if necessary, they are only permitted under the following conditions:

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- Vehicle crossings must be designed by and installed under the supervision of a registered professional engineer.

- Walkways or bridges must: have a minimum clear width of 20 inches, be fitted with standard rails, and extend a minimum of 24 inches past the surface edge of the trench.

Ingress & Egress Trenches 4 feet or more in depth shall be provided with a fixed means of egress. Spacing between ladders or other means of egress must be such that a worker will not have to travel more than 25 feet laterally to the nearest means of egress. Ladders must be secured and extend a minimum of 36 inches above the landing. Metal ladders should be used with caution, particularly when electric utilities are present. Protective Support Systems The company protects each employee in an excavation from cave-ins during an excavation by an adequate protective system designed in accordance with OSHA standards. Protective system options include proper sloping or benching of the sides of the excavation; supporting the sides of the excavation with timber shoring or aluminum hydraulic shoring; or placing a shield between the side of the excavation and the work area. City Construction, Inc. has the following standard operating procedures regarding protective support systems for excavations, in accordance with safe practices and procedures and OSHA excavation regulations:

- If the excavation is made entirely of stable rock, then no protective system is necessary or used. - If the excavation is less than 5 feet in depth (provided there is no indication of a potential cave-in), then no

protective system is necessary or used. - If the excavation is less than or equal to 20 feet in depth, then competent person chooses the most

practical design approach (that meets required performance criteria) for the particular circumstance, and/or - A registered professional engineer designs all protective systems for use in the excavation.

Sloping When sloping is used to protect against cave-ins, these options can be chosen for designing sloping systems:

- If a soil classification is not made, then slope the sides of the excavation to an angle not steeper than one and one-half horizontal to one vertical (34 degrees). A slope of this gradation or less is considered safe for any type of soil.

- Use the OSHA standard to determine the maximum allowable slope and allowable configurations for sloping systems. The soil type must be determined in order to use this option.

- Use other tabulated data approved by a registered professional engineer. - Have an engineer design and approve the system to be used.

There are a number of exceptions or special cases to these general sloping guidelines, which can be utilized by City Construction, Inc. if the conditions meet the exception's requirements. The exceptions and conditions are outlined below: In Type A soil, simple slope excavations which are open 24 hours or less (short term) and which are 12 feet high or less in depth may have a maximum allowable slope of 1/2 horizontal to 1 vertical. In Type A soil, all excavations 8 feet or less in depth which have unsupported vertically sided lower portions must have a maximum vertical side of 3.5 feet.

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In Type A soil, excavations over 8 feet but less than 12 feet in depth with unsupported vertically sided lower portions must have a maximum allowable slope of 1H: 1 V and a maximum vertical side of 3.5 feet. In Type A soil, excavations 20 feet or less with vertically sided lower portions that are supported or shielded shall have a maximum allowable slope of 3/4 H: 1 V. The support or shield system must extend at least 18 inches above the top of the vertical side. In Type B soil, all excavations 20 feet or less which have vertically sided lower portions shall be shielded or supported to a height at least 18 inches above the top of the vertical side. The excavation shall have a maximum allowable slope of 1H: 1 V. In Type C soil, all excavations 20 feet or less which have vertically sided lower portions shall be shielded or supported to a height at least 18 inches above the top of the vertical side. The excavation shall have a maximum allowable slope of 1-1/2 H: 1 V. When an excavation contains layers of different types of soils, the general sloping requirements do not apply. The excavation must be sloped according to the OSHA standard. Maximum allowable slopes for excavations less than 20' based on soil type and angle to the horizontal are as follows:

Soil Type Height/Depth Ratio Slope Angle Type B 1:1 45 Degrees Type C 1-1/2:1 34 Degrees

A 10-foot-deep trench in Type B soil would have to be sloped to a 45-degree angle, or sloped 10 feet back in both directions. Total distance across a 10-foot-deep trench would be 20 feet, plus the width of the bottom of the trench itself.

In Type C soil, the trench would be sloped at a 34-degree angle, or 15 feet back in both directions for at least 30 feet across, plus the width of the bottom of the trench itself. All simple slope excavations 20 feet or less in depth shall have a maximum allowable slope of 1-1/2: 1.

The competent person chooses the best option for sloping for the job at hand.

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Benching When benching is used to protect against cave-ins, these options can be chosen for designing benching systems:

- Use Appendices A and B of29 CFR 1926, Subpart P to determine the maximum allowable slope and allowable configurations for benching systems. The soil type must be determined in order to use this option.

- Use other tabulated data approved by a registered professional engineer. - Have an engineer design and approve the system to be used.

There are a number of exceptions or special cases to these general benching guidelines, which should be utilized by your company if the conditions meet the exception's requirements. The exceptions and conditions are outlined below:

- In Type A soil, simple slope excavations which are open 24 hours or less (short term) and which are 12 feet high or less in depth may have a maximum allowable slope of 1/2 horizontal to 1 vertical.

- In Type A soil, all excavations 8 feet or less in depth which have unsupported vertically sided lower portions must have a maximum vertical side of 3.5 feet.

- In Type A soil, excavations over 8 feet but less than 12 feet in depth with unsupported vertically sided lower portions must have a maximum allowable slope of 1H: 1V and a maximum vertical side of 3.5 feet.

- In Type A soil, excavations 20 feet or less with vertically sided lower portions that are supported or shielded shall have a maximum allowable slope of 3/4H: 1V. The support or shield system must extend at least 18 inches above the top of the vertical side.

- In Type B soil, all excavations 20 feet or less which have vertically sided lower portions shall be shielded or supported to a height at least 18 inches above the top of the vertical side. The excavation shall have a maximum allowable slope of 1 H: 1 V. In Type C soil, all excavations 20 feet or less which have vertically sided lower portions shall be ·shielded or supported to a height at least 18 inches above the top of the vertical side. The excavation shall have a maximum allowable slope of 1-1/2 H: 1 V.

When an excavation contains layers of different types of soils, the general sloping requirements do not apply. The excavation must be sloped according to the OSHA standard.

There are two basic types of benching, single and multiple, which can be used in conjunction with sloping. All benched excavations 20 feet or less in depth shall have a maximum allowable slope of 1: 1. In Type B soil, the vertical height of the benches must not exceed 4 feet. Benches must be below the maximum allowable slope for that soil type. In other words, a 10-foot deep trench in Type B soil must be benched back 10 feet in each direction, with the maximum of a 45-degree angle.

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Benching is not allowed in Type C soil.

The competent person chooses the best option for sloping for the job at hand.

Support Systems, Shield Systems, and Other Protective Systems Timber Shoring When trenches do not exceed 20 feet, timber shoring according to OSHA design specifications may be used. Designs for timber shoring in trenches for company work sites are determined by the competent person using the following methods): Use the requirements set forth by OSHA. The design specifications for timber shoring provided by OSHA may be found in the OSHA standard. These tables refer to the actual dimensions and not nominal dimensions of the timber. If the competent person chooses to use nominal size shoring, he/she must use the additional tables found in the OSHA standard. The soil type in which the excavation is made must be determined in order to use the OSHA data. NOTE: The specifications do not apply in every situation experienced in the field; the data were developed to apply to most common trenching situations. If the specifications do not apply to the situation encountered in the field, the competent person will make a determination of what approach to use to allow safe protective support of the excavation. Use data provided by the manufacturer of the support system. Use other tabulated data approved by an engineer. Have a registered professional engineer design the system. Aluminum Hydraulic Shoring Determined by the competent person, each design for aluminum hydraulic shoring is based upon the following methods):

- Use the manufacturer's tabulated data and design in accordance with the manufacturer's specifications, recommendations, and limitations. Deviations from the manufacturer's specifications, recommendations, or

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limitations are only allowed upon written approval of the manufacturer, which must be obtained by the competent person prior to implementation. The written approval is kept at the job site during construction of the protective system.

- Use the OSHA specifications if the manufacturer's tabulated data cannot be utilized. o NOTE: Before using the OSHA data, the soil type must be determined.

- Use other tabulated data approved by an engineer. Here are some typical installations of aluminum hydraulic shoring: Vertical aluminum hydraulic shoring (spot bracing)

Vertical aluminum hydraulic shoring (with plywood)

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Vertical aluminum hydraulic shoring (stacked)

Aluminum hydraulic shoring waler system (typical)

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Other Support Systems Designs for our support systems are determined by the competent person using the following methods: Use data provided by the manufacturer of the support system. Use other tabulated data approved by an engineer. Have a registered professional engineer design the system. Shielding Determined by the competent person, designs for shielding are based upon the following methods: Use data provided by the manufacturer of the support system. Use other tabulated data approved by an engineer. Have a registered professional engineer design the system. Other Protective Systems Designs for our protective systems are determined by the competent person using the following methods: Use data provided by the manufacturer of the support system. Use other tabulated data approved by an engineer. Have a registered professional engineer design the system.

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General Requirements for Excavations The following rules are to be followed at all times by all employees working on, in, or near excavations, as applicable:

- Employees exposed to public vehicular traffic must wear warning vests or other suitable garments made of reflectorized or high-visibility material.

- The competent person inspects the excavation and the adjacent areas on a daily basis for possible cave-ins, failure of protective systems and equipment, hazardous atmospheres, or other hazardous conditions (see appendices for Daily Inspection Checklist. Inspections are also required after the occurrence of any natural (such as rain) or man-made events (such as blasting) that could increase the potential for hazards. Employees may not begin work until after being informed by the competent person that these inspections are complete.

- A warning system is used to alert operators of heavy equipment and other employees at the work site of the edge of an excavation.

- Adequate protection is provided to protect employees from falling rock, soil, or other materials and equipment. Protection is provided by placing and keeping such materials or equipment at least 2 feet from the edge of excavations, or by the use of retaining devices that are sufficient to prevent materials or equipment from falling or rolling into excavations, or by a combination of both if necessary.

- Employees are not permitted under loads that are handled by lifting or digging equipment. - Employees are not allowed to work in the excavation above other employees unless the lower level

employees are adequately protected. - While the excavation is open, underground installations are protected, supported, or removed as necessary

to safeguard employees. Adjacent structures are supported to prevent possible collapse. - Employees are not permitted to work in excavations where water has accumulated or is accumulating

unless adequate precautions have been taken. Diversion ditches, dikes, or other means are used to prevent surface water from entering an excavation and to provide drainage to the adjacent area.

- Before an employee enters an excavation greater than 4 feet in depth, the competent person must test the atmosphere where oxygen deficiency or a hazardous atmosphere exists or could reasonably exist (i.e., excavations in landfill areas or excavations in areas where hazardous substances are stored nearby). Emergency rescue equipment is readily available and attended when hazardous atmospheric conditions exist or may develop. Sufficient means for exiting excavations 4 feet deep or more are provided and are within 25 feet of lateral travel for employees.

- Guardrails are provided if there are walkways or bridges crossing over an excavation to protect against falls.

Training Dennis Fallon, RSO will identify all new employees in the employee orientation program and make arrangements with management to schedule training. The following person(s) will conduct initial training and evaluation: Dennis Fallon and/or the Site Supervisor. These instructor(s) have the necessary knowledge, training, and experience to train excavation workers. Training Certification After an employee has completed the training program, our company keeps records certifying that each excavation worker has successfully completed excavation training. The certificate includes the name of the worker, the date(s) of the training, and the signature of the person who did the training. RSO is responsible for keeping a copy of all training certification records.

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Current Certified Excavation Workers Under no circumstances shall an employee create or work in an excavation until he/she has successfully completed this company's excavation training program. This includes all new excavation workers regardless of claimed previous experience. Excavation Safety Inspections Our competent person inspects excavations daily and before each shift, after poor weather, any change in the soil pile, fissures, tension cracks, water seepage, bulging or similar conditions occur. For excavations 4 feet or greater in depth, a trench inspection form shall be filled out for each inspection. (Trench Inspection Form) Personal Protective Equipment All excavation workers required to wear all required personal protective equipment and are trained when it is necessary; what equipment is necessary; how to properly put on, take off, adjust, and wear it; limitations of the equipment; and proper care, maintenance, useful life, and disposal of PPE. Exposure to Vehicles

- Workers exposed to vehicular traffic shall be provided with and required to wear reflective vests or other suitable garments marked with or made of reflectorized or high-visibility materials.

- Trained flag persons, signs, signals, and barricades shall be used when necessary. Exposure to Falling Loads

- All workers on an excavation site must wear hard hats. - Workers are not allowed to work under raised loads. - Workers are not allowed to work under loads being lifted or moved by heavy equipment used for digging or

lifting. - Workers are required to stand away from equipment that is being loaded or unloaded to avoid being struck

by falling materials or spillage. - Equipment operators or truck drivers may remain in their equipment during loading and unloading if the

equipment is properly equipped with a cab shield or adequate canopy. Recordkeeping We keep a copy of the following documents at the job site during construction of a particular excavation protective system and then store them in the RSO’s office at City Construction’s, Inc. where they will be readily available to OSHA upon request:

- Tabulated data for designing any of our sloping or benching systems. - Designs of any sloping or benching systems approved by a registered professional engineer. - Manufacturer's specifications, recommendations, and limitations for designs of support systems, shield

systems, and other protective systems drawn from manufacturer’s tabulated data. - Manufacturer's approval to deviate from the specifications, recommendations, and limitations for designs of

support systems, shield systems, and other protective systems drawn from manufacturer’s tabulated data. - Tabulated data for designing any of our support systems, shield systems, and other protective systems. - Designs of all support systems, shield systems, and other protective systems approved by a registered

professional engineer.

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Hazard Communication Program

Purpose

The purpose of this plan is to establish a program and procedures for the safe use of hazardous chemical substances at City Construction, Inc. The Occupational Safety and Health Administration (OSHA) Hazard Communication Standard (HCS) 29 CFR 1910.1200 (General Industry) and 29 CFR 1926.59 (Construction Industry) call for the development of a hazard communication program when employees may be exposed to any chemical in the workplace under normal conditions of use or in a foreseeable emergency. In 2012, OSHA revised the HCS to align with the Globally Harmonized System of Classification and Labeling of Chemicals (GHS). As a result, this program has been revised to comply with the requirements of the OSHA HCS 2012. The written hazard communication program will include and address the following criteria in order to satisfy the minimum requirements of the OSHA HCS 2012:

• List of all hazardous chemicals known to be present in the workplace or individual work area • Methods used to ensure that all containers, including pipes and holding tanks, are labeled, tagged or marked

properly • Methods used to obtain and maintain safety data sheets (SDSs) • Methods used to provide employees with information and training on hazardous chemicals in their work areas • Methods used to inform employees of the hazards of non-routine work practices • Methods used to provide the employees of other employers (e.g., consultants, construction contractors and

temporary employees) on-site access to SDSs for each hazardous chemical that the other employer’s employees may be exposed to while working in the workplace

• Methods used to inform the employees of other employers of precautionary measures that need to be taken to protect themselves during the workplace’s normal operating conditions and in foreseeable emergencies

• Methods used to inform the employees of other employers of the labeling system used in the workplace The hazard communication program will identify the following:

• Key personnel responsible for the program • Location of chemical inventory list and SDSs • Workplace labeling system • Good work practices and procedures to minimize exposures • How training will be performed • Procedures to maintain the program and update the required information • How records will be maintained

•

Responsibilities

The RSO, Dennis Fallon, is responsible for administering the hazard communication program. This person is also responsible for:

• Reviewing the potential hazards and safe use of chemicals • Maintaining a list of all hazardous chemicals and a master file of SDSs • Ensuring that all containers are labeled, tagged or marked properly

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• Providing new-hire and annual training for employees • Maintaining training records • Monitoring the air concentrations of hazardous chemicals in the work environment • Properly selecting and caring for personal protective equipment • Directing the cleanup and disposal operations of the spill control team • Identifying hazardous chemicals used in non-routine tasks and assessing their risks • Informing outside contractors who are performing work on company property about potential hazards • Reviewing the effectiveness of the hazard communication program and making sure that the program

satisfies the requirements of all applicable federal, state or local hazard communication requirements • Contacting chemical manufacturers and/or distributors to obtain SDSs and secondary labels for hazardous

chemicals used or stored in the workplace.

The receiving department is responsible for: • Reviewing incoming hazardous chemicals to verify correct labeling • Holding hazardous chemicals in the receiving area until receipt of the SDS for the product

Employees are responsible for the following aspects of the hazard communication program:

• Identifying hazards before starting a job • Reading container labels and SDSs • Notifying the supervisor of torn, damaged or illegible labels or of unlabeled containers • Using controls and/or personal protective equipment provided by the company to minimize exposure • Following company instructions and warnings pertaining to chemical handling and usage • Properly caring for personal protective equipment, including proper use, routine care and cleaning, storage,

and replacement • Knowing and understanding the consequences associated with not following company policy concerning

the safe handling and use of chemicals • Participating in training

Chemical Inventory List Attached to this program is a list of hazardous chemicals used, produced and/or stored at City Construction, Inc. Copies of the chemical inventory list are available in the Office. This list will contain the product identifier that is referenced on the appropriate SDS, the location or work area where the chemical is used, and the personal protective equipment and precautions for each chemical product. This list will be updated annually and whenever a new chemical is introduced to the workplace. Labels and Other Forms Of Warning Each container of hazardous chemicals received from the chemical manufacturer, importer or distributor will be labeled with the following information:

o Product identifier o Signal word

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o Hazard statement(s) o Pictogram(s) o Precautionary statement(s) o Name, address and telephone number of the chemical manufacturer, importer or other responsible

party

City Construction, Inc. will use the GHS labeling system for secondary containers. When a chemical is transferred from the original container to a portable or secondary container, the container will be labeled, tagged or marked with a GHS label containing the following information:

o Product identifier o Signal word o Hazard statement(s) o Pictogram(s) o Precautionary statement(s)

Portable containers into which hazardous chemicals are transferred from labeled containers and that are intended to be used by more than one employee or used over the course of more than one shift, the container must be labeled. Food and beverage containers should never be used for chemical storage. Signs, placards, process sheets, batch tickets, operating procedures or other such written materials may be used in lieu of affixing labels to individual, stationary process containers as long as the alternative method identifies the containers to which it is applicable and conveys the information required for workplace labeling. Where an area may have a hazardous chemical in the atmosphere (e.g., where extensive welding occurs), the entire area will be labeled with a warning placard. Pipes that contain hazardous chemicals should be labeled in accordance with ANSI/ASME A13.1 and indicate the direction of flow. (Please note that this not a requirement of the OSHA HCS but a best practice or requirement of local jurisdiction.) Workplace labels or other forms of warning will be legible, in English and prominently displayed on the container or readily available in the work area throughout each work shift. If employees speak languages other than English, the information in the other language(s) may be added to the material presented as long as the information is presented in English as well. Note: After Dec. 1, 2015, distributors may not ship containers labeled by the chemical manufacturer or importer unless the label on the container meets GHS labeling requirements. Safety Data Sheets An SDS will be obtained and maintained for each hazardous chemical in the workplace. SDSs for each hazardous chemical will be readily accessible during each work shift to employees when they are in their work areas. SDSs will be obtained from the chemical manufacturer, importer or distributor. The name on the SDS will be the same as that listed on the chemical inventory list. SDSs for chemicals or process streams produced by the company will be developed and provided by the safety coordinator.

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The safety coordinator will maintain the master file of all original SDSs. Hard copies of the master file will be located in the Office and on the main server. SDSs for new products or updated SDSs for existing products will be obtained by the purchasing agent and forwarded to the safety coordinator. The safety coordinator will then update the master file with new and/or updated SDSs. If problems arise in obtaining an SDS from the chemical manufacturer, importer or distributor, a phone call will be made to request an SDS and to verify that the SDS has been sent. The phone call will be logged and a letter will be sent the same day. The company will maintain a written record of all efforts to obtain SDSs. If these efforts fail to produce an SDS, the local OSHA office will be contacted for assistance. Employee Information and Training Employees included in the hazard communication program will receive the following information and training prior to exposure to hazardous chemicals and when new chemical hazards are introduced to their work area: Requirements of the OSHA Hazard Communication Standard 29 CFR 1910.1200 (General Industry) or 29 CFR 1926.59 (Construction Industry) Operations in the work area where hazardous chemicals are present Location and availability of the hazard communication program, chemical inventory list and SDSs Methods and observations used to detect the presence or release of a hazardous chemical in the work area, such as monitoring devices, visual appearance or odor of hazardous chemicals when being released Physical, health, simple asphyxiation, combustible dust and pyrophoric gas hazards, as well as hazards not otherwise classified of the chemicals in the work area Measures employees can take to protect themselves from hazards, such as appropriate controls, work practices, emergency and spill cleanup procedures, and personal protective equipment to be used Explanation of the labels received on shipped containers Explanation of the workplace labeling system Explanation of the SDS, including order of information and how employees can obtain and use the appropriate hazard information Note: To facilitate understanding of the new GHS system, the OSHA HCS requires that employees be trained regarding the new label elements and SDS format by Dec. 1, 2013. Employers are required to update the hazard communication program and to provide any additional training for newly identified physical or health hazards no later than June 1, 2016. Non-Routine Tasks The safety coordinator and the immediate supervisor of an employee performing a non-routine task, such as cleaning machinery and other process equipment, is responsible for ensuring that adequate training has been provided to the employee on any hazards associated with the non-routine task. Employees share in this responsibility by ensuring that their immediate supervisor knows that the non-routine task will be performed. Special work permits are required for the performance of certain non-routine tasks, such as entry to confined spaces, breaking and opening piping systems, and welding and burning. For some special tasks, employees are required to follow special lockout/tagout procedures to ensure that all machinery motion has stopped and energy sources are isolated prior to and during the performance of such tasks.

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Contractors Prior to beginning work, the safety coordinator will inform contractors with employees working on company property of any hazardous chemicals that the contractors’ employees may be exposed to while performing their work. The safety coordinator will also inform contractors of engineering or work practice control measures to be employed by the contractor, personal protective equipment to be worn by the contractors’ employees, and any other precautionary measures that need to be taken to protect their employees during the workplace’s normal operating conditions and in foreseeable emergencies. Furthermore, the safety coordinator will advise contractors that they must comply with all OSHA standards while working on company property. Appropriate controls will be established with the contractor to ensure that company employees are not exposed to safety and health hazards from work being performed by the contractor and that company operations do not expose contractors’ employees to hazards. The safety coordinator will inform contractors of the workplace labeling system and the availability and location of SDSs for any chemical to which contractors’ employees may be exposed while performing their work. Recordkeeping Records pertaining to the hazard communication program will be maintained by the safety coordinator. The safety coordinator will keep the following records:

o Chemical inventory list o Hazardous material reviews o Copies of phone call logs and letters requesting SDSs o Employee training records o Warnings issued to employees for not following the hazard communication program

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HCS Pictograms and Hazards

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Concrete Hazards & Solutions Purpose City Construction’s main business is working with concrete. These are some of the information and hazards associated with the concrete business:

• More than 250,000 people work in concrete manufacturing. • Over 10 percent of those workers - 28,000 - experienced a job-related injury or illness and 42 died in just one

year. • Potential hazards for workers in concrete manufacturing:

o Eye, skin and respiratory tract irritation from exposure to cement dust; o Inadequate safety guards on equipment; o Inadequate lockout/tagout systems on machinery; o Overexertion and awkward postures; o Slips, trips and falls; and o Chemical burns from wet concrete.

Cement Dust Hazard: Exposure to cement dust can irritate eyes, nose, throat and the upper respiratory system. Skin contact may result in moderate irritation to thickening/cracking of skin to severe skin damage from chemical burns. Silica exposure can lead to lung injuries including silicosis and lung cancer. Solutions: Rinse eyes with water if they come into contact with cement dust and consult a physician. Use soap and water to wash off dust to avoid skin damage. Wear a P-, N- or R-95 respirator to minimize inhalation of cement dust. Eat and drink only in dust-free areas to avoid ingesting cement dust. Wet Concrete Hazard: Exposure to wet concrete can result in skin irritation or even first-, second- or third-degree chemical burns. Compounds such as hexavalent chromium may also be harmful. Solutions: Wear alkali-resistant gloves, coveralls with long sleeves and full-length pants, waterproof boots and eye protection. Wash contaminated skin areas with cold, running water as soon as possible. Rinse eyes splashed with wet concrete with water for at least 15 minutes and then go to the hospital for further treatment.

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Respiratory Protection Purpose It is the intention of City Construction, Inc. to provide a respirator protection program that meets or exceeds all federal standards. City Construction, Inc. will attempt to engineer potential harmful vapors and oxygen deficient atmosphere exposure hazards out of the work environment. If engineering control measures are not feasible or during emergency situations with high exposure then respirators shall be provided which are applicable and suitable for purpose intended at no cost to the employee. Scope This program applies to all City Construction, Inc. projects and operations. Respiratory Program Administrator

- Overall responsibility for the respiratory protection program is assigned to the City Construction, Inc. RSO in order to ensure that specific requirements are followed.

- The Administrator must be knowledgeable of the complexity of the program, able to conduct evaluations and have the proper training.

- This assignment is made, however, with the understanding that individual supervisors will have to implement and enforce major portions of the program. It is understood that the Program Administrator will report performance problems to the appropriate manager for resolution. The person who will have responsibility for administering all the aspects of this program will be the RSO or their designee.

- The responsibilities of the Program Administrator will include, but are not limited to: - Conducting an annual written evaluation of the program. The program evaluation should be completed no

later than December, 31, of each year. - Ensuring an adequate supply of respirators, cartridges, and repair/replacement parts. The Program

Administrator may delegate this duty but will retain overall responsibility. The person(s) to whom this duty has been delegated is the Project Manager and/or Field Supervisor.

- Identifying hazards and ensuring only NIOSH certified respirators must be selected and provided based on those hazards and factors affecting performance.

- Ensuring that all respirator users have been trained in the use, selection and limitations of the type of respirators they will be using prior to the first time the respirator must be used. While the duty of conducting the training may be delegated, the Program Administrator retains final responsibility for seeing that all employees are appropriately trained.

- Ensuring that all respirator users have been medically evaluated and found fit to use the type of respirators that will be required in their job. The medical evaluation must be completed prior to assigning any employee to a task that requires use of a respirator.

- Ensuring that all respirator users are fit-tested at least annually and more often if other federal requirements apply.

- Ensuring that respirators are individually issued, are cleaned and sanitized on a regular basis, and respirators are stored in a clean and accessible location. This duty may also be delegated but the Program Administrator retains final responsibility for seeing that it is done.

- Ensuring that respirators are selected based on the hazard that will be encountered. This program describes the basic respirators that will be used at this site and the tasks for which they will be required. In special circumstances, the Program Administrator will contact the corporate health and safety staff for guidance in selecting the correct respirator.

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- Ensuring that employee exposure is monitored to assure correct respirator type is used. Exposure monitoring may be delegated to others; however, the Program Administrator has final responsibility of monitoring completion and to request assistance when necessary.

- Ensuring surveillance of employees who wear respirators shall leave the area to wash, change cartridges or if they detect break through or resistance.

- Ensuring that the elements of the Respiratory Protection Program for the selection, use, cleaning/maintenance, storage and fit-testing of respirators are followed.

- Ensuring that respirator parts are not exchanged between brands of respirators. - Ensuring medical evaluations, respirators and required training are provided at no cost to the employee.

Medical Requirements General City Construction, Inc. shall provide a medical evaluation to determine the employee's ability to use a respirator, before the employee is fit tested or required to use the respirator in the workplace. City Construction, Inc. may discontinue an employee's medical evaluations when the employee is no longer required to use a respirator. Medical Evaluation Procedures City Construction, Inc. shall identify a physician or other licensed health care professional (PLHCP) to perform medical evaluations using a medical questionnaire or an initial medical examination that obtains the same information as the medical questionnaire. The medical evaluation shall obtain the information requested by the Medical Questionnaire in Forms section (or equivalent). The medical evaluation prior to fit-testing will be confidential, conducted during normal working hours, be at a convenient time and location, be understandable and the employee will be given a chance to discuss the results with the PLHCP. Supplemental Information for the PLHCP The following information must be provided to the PLHCP before the PLHCP makes a recommendation concerning an employee's ability to use a respirator:

- The type and weight of the respirator to be used by the employee; - The duration and frequency of respirator use (including use for rescue and escape); - The expected physical work effort; - Additional protective clothing and equipment to be worn; and - Temperature and humidity extremes that may be encountered.

City Construction, Inc. shall provide the PLHCP with a copy of the City Construction, Inc. Respiratory Protection Program. Note: When City Construction, Inc. replaces a PLHCP, City Construction, Inc. must ensure that the new PLHCP obtains this information, either by providing the documents directly to the PLHCP or having the documents transferred from the former PLHCP to the new PLHCP. However, OSHA does not expect employers to have employees medically re-evaluated solely because a new PLHCP has been selected. Medical Determination

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In determining the employee's ability to use a respirator, City Construction, Inc. shall obtain a written recommendation regarding the employee's ability to use the respirator from the PLHCP. The recommendation shall provide only the following information:

- Any limitations on respirator use related to the medical condition of the employee, or relating to the workplace conditions in which the respirator will be used, including whether or not the employee is medically able to use the respirator;

- The need, if any, for follow-up medical evaluations; and - A statement that the PLHCP has provided the employee with a copy of the PLHCP's written

recommendation. All recommendations are to be sent to City Construction, Inc.’s Safety Manager. Additional Medical Evaluations At a minimum, City Construction, Inc. shall provide additional medical evaluations that comply with the requirements of this program if:

- An employee reports medical signs or symptoms that are related to ability to use a respirator; - A PLHCP, supervisor, or the respirator Program Administrator informs City Construction, Inc. that an

employee needs to be re-evaluated; - Information from the respiratory protection program, including observations made during fit testing and

program evaluation, indicates a need for employee re-evaluation; or - A change occurs in workplace conditions (e.g., physical work effort, protective clothing, and temperature)

that may result in a substantial increase in the physiological burden placed on an employee. Work Site Procedures Each work site where respirators are required to protect the health of the worker shall have work site procedures that follow the guidelines of this program. Specific procedures may also be required by our client who will be followed. The following areas shall be included:

- Identification of specific hazard requiring respiratory protection - The selection of the appropriate respiratory protection equipment based on the specific hazard and

concentration levels, characteristics, etc. Specific brand and models of respiratory equipment to be used shall be identified in the procedures.

- Verification that each user of respiratory protection is qualified (medical approval, current fit test, annual training and demonstrates competency.

Respirator Selection Criteria The selection of the respiratory equipment is based on the hazards the employee is exposed to. City Construction, Inc. shall:

- Perform hazard identification, - Select and provide respirators based on those hazards and factors affecting performance, - Establish brands and models to be used, and - Estimate exposures and contaminant information.

Hazard Identification Due to the many varied work locations City Construction, Inc.’s identification of respiratory hazards will be contained in the various work site specific safety plans. However, common respiratory hazards that will be encountered include:

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- Dust - Fumes - Gases - Chemical particles - Oxygen Deficiency

Characteristics of Hazardous Operation or Process

- Hot operations: welding, chemical reactions, soldering, melting, melding and burning - Liquid operations: painting, degreasing, dipping, spraying, brushing, coating, etching, cleaning, pickling,

plating, mixing, galvanizing and chemical reactions - Solid operations: pouring, mixing, separations, extraction, crushing, conveying, loading, bagging and

demolition. - Pressurized spraying: cleaning parts, applying pesticides, degreasing, sand blasting and painting - Shaping operations: cutting, grinding, filing, milling, melding, sawing and drilling

Gaseous Contaminants

- Inert gases (helium, argon, etc.), which do not metabolize in the body but displace air to produce an oxygen deficiency.

- Acid gases (SO2, H2S, HCl, etc.) which are acids or produce acids by reaction with water. - Alkaline gases (NH3, etc.), which are alkalis or produce alkalis by reaction with water. - Organic gases (butane, acetone, etc.), which exist as true gases or vapors from organic liquids. - Organometallic gases (tetraethyl lead, organic-phosphates, etc.), which have metals attached to organic

groups. Particulate contaminants - Dusts are mechanically generated solid particulates (0.5 to 10μm) - Fumes are solid condensation particles of small diameter (0.1 to 1.0 μm) - Mists are liquid particulate matter (5 to 100 μm) - Smoke is chemically generated particulates (solid and liquid) of organic origins (0.01 to 0.3 μm) Selection of Respirator The following factors shall be taken into account when selecting the proper respirator: Concentration and Type of Contaminant The concentration and type of contaminant will determine the model and type of respirator and cartridges/filters or filters to be used. The concentration is based on a sampling of the atmosphere. Location of Hazardous Area (Confined Space, nearby contaminants, etc.) Worker Activity (Extreme heat, cold, welding hood requirement, etc.)

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Types of Respirators Air-purifying respirators can be either full-face or half masks with mechanical or chemical cartridges to filter dusts, mists, fumes, vapors or gases. Powered air-purifying respirators use a blower to pass the contaminated air through a filter. The purified air is then delivered into a mask or hood. They filter dusts, mists, fumes, vapors and gases, just like ordinary air-purifying respirators. Air-purifying respirators cannot be used in oxygen-deficient atmospheres, which can result when another gas displaces the oxygen or consumption of oxygen by a chemical reaction occurs. Oxygen levels below 19.5% require either a source of supplied air or supplied-air respirator protection. Levels below 16% are considered to be unsafe and could cause death. To determine the proper cartridge for air-purifying respirators contact the City Construction, Inc. Safety Manager or a qualified on-site safety representative of the client. You should also consult the Safety Data Sheet of the substance that needs to be filtered. All cartridges are assigned a color designating the type of contaminant they will filter: White: Acid gas Black: Organic vapors Green: Ammonia gas Yellow: Acid gas and organic vapors Purple: Radioactive materials Orange: Dust, fumes and mists Olive: Other gases and vapors Once the wearer of the respirator can detect an odor, irritation, or taste of the contaminant, the cartridge should be replaced. All cartridges and/or filters shall be changed at the beginning of each shift. Supplied-air respirators provide the highest level of protection against highly toxic and unknown materials. Supplied air refers to self-contained breathing apparatuses (SCBAs) and air-line respirators. SCBAs have a limited air supply that is carried by the user, allowing for good mobility and fewer restrictions than air-line respirators. Air-line respirators have an air hose that is connected to a fresh air supply from a central source. The source can be from a compressed air cylinder or air compressor that provides at least Grade D breathing air. Emergency Escape Breathing Apparatuses (EEBAs) provide oxygen for 5, 10 or 15 minutes depending on the unit. These are for emergency situations in which an employee must escape from environments immediately dangerous to life or health (IDLH). SCBA (Self Contained Breathing Apparatus) City Construction, Inc. does NOT allow employees to work in an Immediately Dangerous to Life and Health (IDLH) environment. In order to maintain the NIOSH/MSHA approval of any respirator, mixing parts from other respirator manufacturers is prohibited. This includes airline hoses, valves, gaskets, cartridges, etc. For example, do not use North cartridges or valve gaskets with an MSA product. Brand and Models

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City Construction, Inc. has selected North Safety as its NIOSH-certified respirator. Only this brand of respirator shall be used in compliance with the conditions of the certification of its Respiratory Protection Program (fit testing model, no mixing of different manufacturer parts, cartridges, filters, etc.). The specific model will be based on the hazard, concentration of contaminant, oxygen level, work environment and type of work being performed. To aid in the selection process the following will be used to identify the proper North respiratory equipment for the work being performed and hazard that is present. • NIOSH Pocket Guide to Chemicals • North Cartridge Selection Guide • North Respirator Selection Guide Estimate of Exposures and Contaminant Information

- No employee shall enter an IDLH environment. - Normal oxygen levels shall be maintained. - No employee shall be exposed to an atmosphere containing concentrations that would exceed the STEL or

PEL for the identified atmospheric hazard. Respirator Fit Testing Before an employee may be required to use any respirator with a negative or positive pressure tight-fitting face piece, the employee must be fit tested with the same make, model, style, and size of respirator that will be used. This section specifies the kinds of fit tests allowed, the procedures for conducting them, and how the results of the fit tests must be used. All respirator users are fit-tested at least annually and more often if other federal requirements apply. Supplied Air Respirators are required to be fit tested as well. City Construction, Inc. shall ensure that employees using a tight-fitting face piece respirator pass an appropriate qualitative fit test (QLFT) or quantitative fit test (QNFT) as stated in this program. City Construction, Inc. shall ensure that an employee using a tight-fitting face piece respirator is fit tested prior to initial use of the respirator, whenever a different respirator face piece (size, style, model or make) is used, and at least annually thereafter. City Construction, Inc. shall conduct an additional fit test whenever the employee reports, or City Construction, Inc.’s PLHCP, supervisor, or Program Administrator makes visual observations of, changes in the employee's physical condition that could affect respirator fit. Such conditions include, but are not limited to, facial scarring, dental changes, cosmetic surgery, or an obvious change in body weight. If after passing a QLFT or QNFT, the employee subsequently notifies City Construction, Inc., Program Administrator, supervisor, or PLHCP that the fit of the respirator is unacceptable, the employee shall be given a reasonable opportunity to select a different respirator face piece and to be retested. The fit test shall be administered using an OSHA-accepted QLFT or QNFT protocol. The OSHA-accepted QLFT and QNFT protocols and procedures are contained in this section. QLFT may only be used to fit test negative pressure air-purifying respirators that must achieve a fit factor of 100 or less. Half face air filtering respirators may be fit tested with irritant smoke while full face air filtering respirators require Porta count fit testing.

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If the fit factor, as determined through an OSHA-accepted QNFT protocol, is equal to or greater than 100 for tight-fitting half face pieces, or equal to or greater than 500 for tight-fitting full face pieces, the QNFT has been passed with that respirator. Fit testing of tight-fitting atmosphere-supplying respirators and tight-fitting powered air-purifying respirators shall be accomplished by performing quantitative or qualitative fit testing in the negative pressure mode, regardless of the mode of operation (negative or positive pressure) that is used for respiratory protection. Qualitative fit testing of these respirators shall be accomplished by temporarily converting the respirator user's actual face piece into a negative pressure respirator with appropriate filters, or by using an identical negative pressure air-purifying respirator face piece with the same sealing surfaces as a surrogate for the atmosphere-supplying or powered air-purifying respirator face piece. Quantitative fit testing of these respirators shall be accomplished by modifying the face piece to allow sampling inside the face piece in the breathing zone of the user, midway between the nose and mouth. This requirement shall be accomplished by installing a permanent sampling probe onto a surrogate face piece, or by using a sampling adapter designed to temporarily provide a means of sampling air from inside the face piece. Any modifications to the respirator face piece for fit testing shall be completely removed, and the face piece restored to NIOSH-approved configuration, before that face piece can be used in the workplace. Fit Test Procedures The requirements in this section apply to all OSHA-accepted fit test methods, both QLFT and QNFT. The test subject shall be allowed to pick the most acceptable respirator from a sufficient number of respirator sizes so that the respirator is acceptable to, and correctly fits, the user. Prior to the selection process, the test subject shall be shown how to put on a respirator, how it should be positioned on the face, how to set strap tension and how to determine an acceptable fit. A mirror shall be available to assist the subject in evaluating the fit and positioning of the respirator. This instruction may not constitute the subject's formal training on respirator use, because it is only a review. The test subject shall be informed that he/she is being asked to select the respirator that provides the most acceptable fit. Each respirator represents a different size and shape, and if fitted and used properly, will provide adequate protection. The test subject shall be instructed to hold each chosen face piece up to the face and eliminate those that obviously do not give an acceptable fit. The more acceptable face pieces are noted in case the one selected proves unacceptable; the most comfortable mask is donned and worn at least five minutes to assess comfort. Assistance in assessing comfort can be given by discussing the following points:

- If the test subject is not familiar with using a particular respirator, the test subject shall be directed to don the mask several times and to adjust the straps each time to become adept at setting proper tension on the straps.

- Position of the mask on the nose - Room for eye protection - Room to talk - Position of mask on face and cheeks

The following criteria shall be used to help determine the adequacy of the respirator fit:

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- Chin properly placed; - Adequate strap tension, not overly tightened; - Fit across nose bridge; - Respirator of proper size to span distance from nose to chin; - Tendency of respirator to slip; - Self-observation in mirror to evaluate fit and respirator position. Use the Fit Test form. User Seal Check Before conducting the negative and positive pressure checks, the subject shall be told to seat the mask on the face by moving the head from side-to-side and up and down slowly while taking in a few slow deep breaths. The test subject shall conduct a user seal check, either the negative or positive pressure seal checks described below: Positive Pressure Check Close off the exhalation valve and exhale gently into the face piece. The face fit is considered satisfactory if a slight positive pressure can be built up inside the face piece without any evidence of outward leakage of air at the seal. For most respirators this method of leak testing requires the wearer to first remove the exhalation valve cover before closing off the exhalation valve and then carefully replacing it after the test. Negative Pressure Check Close off the inlet opening of the canister or cartridge(s) by covering with the palm of the hand(s) or by replacing the filter seal(s), inhale gently so that the face piece collapses slightly, and hold the breath for ten seconds. The design of the inlet opening of some cartridges cannot be effectively covered with the palm of the hand. The test can be performed by covering the inlet opening of the cartridge with a thin latex or nitrile glove. If the face piece remains in its slightly collapsed condition and no inward leakage of air is detected, the tightness of the respirator is considered satisfactory. The test shall not be conducted if there is any hair growth between the skin and the face piece sealing surface, such as stubble beard growth, beard, moustache or sideburns which cross the respirator sealing surface. Any type of apparel which interferes with a satisfactory fit shall be altered or removed, including glasses. If a test subject exhibits difficulty in breathing during the tests, she or he shall be referred to a physician or other licensed health care professional, as appropriate, to determine whether the test subject can wear a respirator while performing her or his duties. If the employee finds the fit of the respirator unacceptable, the test subject shall be given the opportunity to select a different respirator and to be retested. Prior to the commencement of the fit test, the test subject shall be given a description of the fit test and the test subject's responsibilities during the test procedure. The description of the process shall include a description of the test exercises that the subject will be performing. The respirator to be tested shall be worn for at least 5 minutes before the start of the fit test. The fit test shall be performed while the test subject is wearing any applicable safety equipment that may be worn during actual respirator use which could interfere with respirator fit. Test Exercises

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Each test exercise shall be performed for one minute except for the grimace exercise which shall be performed for 15 seconds. The test subject shall be questioned by the test conductor regarding the comfort of the respirator upon completion of the protocol. If it has become unacceptable, another model of respirator shall be tried. If due to medical or health conditions the employee cannot perform the test exercises the fit test shall not be performed and the employee not allowed to use a respirator until all elements of the fit test can be achieved. The respirator shall not be adjusted once the fit test exercises begin. Any adjustment voids the test, and the fit test must be repeated. The following test exercises are to be performed for all fit testing methods prescribed in this procedure: - Normal breathing. In a normal standing position, without talking, the subject shall breathe normally. - Deep breathing. In a normal standing position, the subject shall breathe slowly and deeply, taking caution so as

not to hyperventilate. - Turning head side to side. Standing in place, the subject shall slowly turn his/her head from side to side

between the extreme positions on each side. The head shall be held at each extreme momentarily so the subject can inhale at each side.

- Moving head up and down. Standing in place, the subject shall slowly move his/her head up and down. The subject shall be instructed to inhale in the up position (i.e., when looking toward the ceiling).

- Talking. The subject shall talk out loud slowly and loud enough so as to be heard clearly by the test conductor. - The subject shall read from the Rainbow Passage Rainbow Passage “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 beautiful 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.” Continue to read for one minute. - Grimace. The test subject shall grimace by smiling or frowning. (This applies only to QNFT testing; it is not

performed for QLFT) - Jogging in place. The test subject shall jog in place being careful to be aware of their surroundings. - Normal breathing. Same as exercise (1). Qualitative Fit Test (QLFT) Protocols General City Construction, Inc. shall ensure that persons administering QLFT are able to prepare test solutions, calibrate equipment and perform tests properly, recognize invalid tests, and ensure that test equipment is in proper working order. City Construction, Inc. shall ensure that QLFT equipment is kept clean and well maintained so as to operate within the parameters for which it was designed. Irritant Smoke (Stannic Chloride) Protocol This qualitative fit test uses a person's response to the irritating chemicals released in the ``smoke'' produced by a stannic chloride ventilation smoke tube to detect leakage into the respirator.

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General Requirements and Precautions. The respirator to be tested shall be equipped with high efficiency particulate air (HEPA) or P100 series filter(s). Only stannic chloride smoke tubes shall be used for this protocol. No form of test enclosure or hood for the test subject shall be used. The smoke can be irritating to the eyes, lungs, and nasal passages. The test conductor shall take precautions to minimize the test subject's exposure to irritant smoke. Sensitivity varies, and certain individuals may respond to a greater degree to irritant smoke. Care shall be taken when performing the sensitivity screening checks that determine whether the test subject can detect irritant smoke to use only the minimum amount of smoke necessary to elicit a response from the test subject. The fit test shall be performed in an area with adequate ventilation to prevent exposure of the person conducting the fit test or the build-up of irritant smoke in the general atmosphere. The person to be tested must demonstrate his or her ability to detect a weak concentration of the irritant smoke. - The test operator shall break both ends of a ventilation smoke tube containing stannic chloride, and attach one

end of the smoke tube to a low flow air pump set to deliver 200 milliliters per minute, or an aspirator squeeze bulb. The test operator shall cover the other end of the smoke tube with a short piece of tubing to prevent potential injury from the jagged end of the smoke tube.

- The test operator shall advise the test subject that the smoke can be irritating to the eyes, lungs, and nasal passages and instruct the subject to keep his/her eyes closed while the test is performed.

- The test subject shall be allowed to smell a weak concentration of the irritant smoke before the respirator is donned to become familiar with its irritating properties and to determine if he/she can detect the irritating properties of the smoke. The test operator shall carefully direct a small amount of the irritant smoke in the test subject's direction to determine that he/she can detect it.

Irritant Smoke Fit Test Procedure - The person being fit tested shall don the respirator without assistance, and perform the required user seal

check(s). - The test subject shall be instructed to keep his/her eyes closed if wearing a half face respirator. - The test operator shall direct the stream of irritant smoke from the smoke tube toward the face seal area of the

test subject, using the low flow pump or the squeeze bulb. The test operator shall begin at least 12 inches from the face piece and move the smoke stream around the whole perimeter of the mask. The operator shall gradually make two more passes around the perimeter of the mask, moving to within six inches of the respirator.

- If the person being tested has not had an involuntary response and/or detected the irritant smoke, proceed with the test exercises.

- The exercises identified in the Test Exercises of this procedure shall be performed by the test subject while the respirator seal is being continually challenged by the smoke, directed around the perimeter of the respirator at a distance of six inches.

- If the person being fit tested reports detecting the irritant smoke at any time, the test is failed. The person being retested must repeat the entire sensitivity check and fit test procedure.

- Each test subject passing the irritant smoke test without evidence of a response (involuntary cough, irritation) shall be given a second sensitivity screening check, with the smoke from the same smoke tube used during the fit test, once the respirator has been removed, to determine whether he/she still reacts to the smoke. Failure to evoke a response shall void the fit test.

- If a response is produced during this second sensitivity check, then the fit test is passed. The glass tube shall be disposed of properly.

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Quantitative Fit Test (QNFT) Protocols Using controlled negative pressure and appropriate instrumentation to measure the volumetric leak rate of a face piece to quantify the respirator have been demonstrated to be acceptable to OSHA. City Construction, Inc. shall ensure that persons administering QNFT are able to calibrate equipment and perform tests properly, recognize invalid tests, calculate fit factors properly and ensure that test equipment is in proper working order. City Construction, Inc. shall ensure that QNFT equipment is kept clean, and is maintained and calibrated according to the manufacturer's instructions so as to operate at the parameters for which it was designed. Porta count Fit Test Requirements

- Check the respirator to make sure the respirator is fitted with a high-efficiency filter and that the sampling probe and line are properly attached to the face piece.

- Instruct the person to be tested to don the respirator for five minutes before the fit test starts. This purges the ambient particles trapped inside the respirator and permits the wearer to make certain the respirator is comfortable. This individual shall already have been trained on how to wear the respirator properly.

- Check the following conditions for the adequacy of the respirator fit: Chin properly placed; Adequate strap tension, not overly tightened; Fit across Nose Bridge; Respirator of proper size to span distance from nose to chin; Tendency of the respirator to slip; Self-observation in a mirror to evaluate fit and respirator position.

- Have the person wearing the respirator do a user seal check. If leakage is detected, determine the cause. If leakage is from a poorly fitting face piece, try another size of the same model respirator, or another model of respirator.

- Follow the manufacturer's instructions for operating the Porta count and proceed with the test. - The test subject shall be instructed to perform the exercises in Test Exercises section of this procedure. - After the test exercises, the test subject shall be questioned by the test conductor regarding the comfort of

the respirator upon completion of the protocol. If it has become unacceptable, another model of respirator shall be tried.

Porta count Test Instrument The Porta count will automatically stop and calculate the overall fit factor for the entire set of exercises. The overall fit factor is what counts. The Pass or Fail message will indicate whether or not the test was successful. If the test was a Pass, the fit test is over. Since the pass or fail criterion of the Porta count is user programmable, the test operator shall ensure that the pass or fail criterion meet the requirements for minimum respirator performance. A record of the test needs to be sent to the Safety Manager and kept on file, assuming the fit test was successful. The record must contain the test subject's name; overall fit factor; make, model, style, and size of respirator used; and date tested. Use, Maintenance and Care of Respirators This section requires City Construction, Inc. to provide for the use, cleaning and disinfecting, storage, inspection, and repair of respirators used by employees. Appendix B - Respirator Cleaning Procedures (Mandatory) shall be followed. Use - Items that can affect the face to mask seal are prohibited. This includes facial hair, glasses, clothing, etc. - Each time a respirator is put on a positive and negative pressure check shall be performed.

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Cleaning and Disinfecting Requirements City Construction, Inc. shall provide each respirator user with a respirator that is clean, sanitary, and in good working order. City Construction, Inc. shall ensure that respirators are cleaned and disinfected using the procedures in this Respiratory Protection Program, or procedures recommended by the respirator manufacturer, provided that such procedures are of equivalent effectiveness. The respirators shall be cleaned and disinfected at the following intervals: - Respirators issued for the exclusive use of an employee shall be cleaned and disinfected by the employee as

often as necessary to be maintained in a sanitary condition, - Respirators used in fit testing and training shall be cleaned and disinfected after each use by the Safety

Manager or designated person. - Each individual who is assigned a cartridge respirator is responsible for seeing that the respirator is cleaned,

inspected and properly stored. Cleaning Procedures

- Remove filters, cartridges, or canisters. Disassemble face pieces by removing speaking diaphragms, demand

and pressure-demand valve assemblies, hoses, or any components recommended by the manufacturer. Discard or repair any defective parts.

- Wash components in warm water with a mild detergent or with a cleaner recommended by the manufacturer. A stiff bristle (not wire) brush may be used to facilitate the removal of dirt.

- Rinse components thoroughly in clean, warm, preferably running water. Drain. - When the cleaner used does not contain a disinfecting agent, respirator components should be immersed for

two minutes in commercially available cleansers of equivalent disinfectant quality. Another alternative is to use wipes containing alcohol that are intended for use with respirators.

- Rinse components thoroughly in clean, warm, preferably running water. Drain. The importance of thorough rinsing cannot be overemphasized. Detergents or disinfectants that dry on face pieces may result in dermatitis. In addition, some disinfectants may cause deterioration of rubber or corrosion of metal parts if not completely removed.

- Components should be hand-dried with a clean lint-free cloth or air dried. Reassemble face piece, replacing filters, cartridges, and canisters where necessary. Test the respirator to ensure that all components work properly.

Storage and Inspection - Respiratory equipment shall be stored in a manner to protect it from damage, contamination, temperature

extreme, etc. - Respiratory equipment intended for emergency use shall be stored in an area that is readily accessible and be

clearly marked. City Construction, Inc. shall ensure that respirators are inspected as follows: - All respirators used in routine situations shall be inspected by the employee before each use and during

cleaning; - A check by the employee of respirator function, tightness of connections, and the condition of the various parts

including, but not limited to, the face piece, head straps, valves, connecting tube, and cartridges, canisters or filters; and

- A check of elastomeric parts for pliability and signs of deterioration. - Emergency respiratory equipment will be inspected at least monthly, and before and after each use. - Escape only respiratory equipment will be inspected before being carried into workplace.

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Breathing Air Quality and Use City Construction, Inc. shall ensure that compressed air accords with the following specifications: - Compressed breathing air shall meet at least the requirements for Type 1-Grade D breathing air described in

ANSI/Compressed Gas Association Commodity Specification for Air, G-7.1-1989, to include: o Oxygen content (v/v) of 19.5-23.5%; o Hydrocarbon (condensed) content of 5 milligrams per cubic meter of air or less; o Carbon monoxide (CO) content of 10 ppm or less; o Carbon dioxide content of 1,000 ppm or less; and o Lack of noticeable odor.

- City Construction, Inc. shall ensure that oxygen is not used in compressed air units. - City Construction, Inc. shall ensure that oxygen concentrations greater than 23.5% are used only in equipment

designed for oxygen service or distribution. - City Construction, Inc. shall ensure that cylinders used to supply breathing air to respirators meet DOT

requirements and that: o Cylinders are tested and maintained as prescribed in the Shipping Container Specification Regulations

of the Department of Transportation (49 CFR part 173 and part 178); o Cylinders of purchased breathing air have a certificate of analysis from the supplier that the breathing

air meets the requirements for Type 1--Grade D breathing air; and o The moisture content in the cylinder does not exceed a dew point of -50 deg. F (-45.6 deg. C) at 1

atmosphere pressure. - City Construction, Inc. shall ensure that compressors used to supply breathing air to respirators are constructed

and situated so as to: o Prevent entry of contaminated air into the air-supply system; o Minimize moisture content so that the dew point at 1 atmosphere pressure is 10 degrees F (5.56 deg.

C) below the ambient temperature; o Have suitable in-line air-purifying sorbent beds and filters to further ensure breathing air quality.

Sorbent beds and filters shall be maintained and replaced or refurbished periodically following the manufacturer's instructions.

- Have a tag containing the most recent change date and the signature of the person authorized by City

Construction, Inc. to perform the change. The tag shall be maintained at the compressor. - For compressors that are not oil-lubricated, City Construction, Inc. shall ensure that carbon monoxide levels in

the breathing air do not exceed 10 ppm. - For oil-lubricated compressors, City Construction, Inc. shall use a high-temperature or carbon monoxide alarm,

or both, to monitor carbon monoxide levels. If only high-temperature alarms are used, the air supply shall be monitored at intervals sufficient to prevent carbon monoxide in the breathing air from exceeding 10 ppm.

City Construction, Inc. shall ensure that breathing air couplings are incompatible with outlets for non-respirable worksite air or other gas systems. No asphyxiating substance shall be introduced into breathing air lines. Repairs City Construction, Inc. shall ensure that respirators that fail an inspection or are otherwise found to be defective are immediately removed from service, and are discarded or repaired or adjusted in accordance with the following procedures: - Repairs or adjustments to respirators are to be made only by persons appropriately trained to perform such

operations and shall use only the respirator manufacturer's NIOSH-approved parts designed for the respirator; - Repairs shall be made according to the manufacturer's recommendations and specifications for the type and

extent of repairs to be performed; and

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Voluntary Use If an employee chooses to voluntarily wear a respirator when not required by this Program (contaminants do not meet protection standards, odors, etc.) they will be advised of the following in their training: Respirators are an effective method of protection against designated hazards when properly selected and worn. Respirator use is encouraged, even when exposures are below the exposure limit, to provide an additional level of comfort and protection for employees. However, if a respirator is used improperly or not kept clean, the respirator itself can become a hazard to the employee. Sometimes, employees may wear respirators to avoid exposures to hazards, even if the amount of hazardous substance does not exceed the limits set by OSHA standards. If your employer provides respirators for your voluntary use, of if you provide your own respirator, you need to take certain precautions to be sure that the respirator itself does not present a hazard. You should do the following: - Read and heed all instructions provided by the manufacturer on use, maintenance, cleaning and care, and

warnings regarding the respirators limitations. - Choose respirators certified for use to protect against the contaminant of concern. NIOSH, the National Institute

for Occupational Safety and Health of the U.S. Department of Health and Human Services, certifies respirators. A label or statement of certification should appear on the respirator or respirator packaging. It will tell you what the respirator is designed for and how much it will protect you.

- Do not wear your respirator into atmospheres containing contaminants for which your respirator is not designed to protect against. For example, a respirator designed to filter dust particles will not protect you against gases, vapors, or very small solid particles of fumes or smoke.

- Keep track of your respirator so that you do not mistakenly use someone else's respirator. Workplace Monitoring A program of monitoring potential employee exposures has been implemented through the corporate health and safety department. Project personnel may also be assigned with the task of conducting air monitoring. Direct-reading instruments will also be used in the characterization of potential exposures. All the data collected is used to determine the appropriateness of the respiratory equipment. Recordkeeping City Construction, Inc. will establish and retain written information regarding medical evaluations, fit testing and the respirator program. Records of medical evaluations required by this section must be retained and made available in accordance with 29 CFR 1910.1020. City Construction, Inc. shall provide the employee with an opportunity to discuss the questionnaire and examination results with the PLHCP. Records will be treated confidentially and maintained on file in the City Construction, Inc. corporate office by the Safety Manager. Program Evaluation City Construction, Inc. shall conduct evaluations of the workplace as necessary to ensure that the provisions of the current written program are being effectively implemented and that it continues to be effective. City Construction, Inc. shall regularly consult employees required to use respirators to assess the employees' views on this program’s effectiveness and to identify any problems. Any problems that are identified during this assessment shall be corrected. Factors to be assessed and verified include, but are not limited to: - Respirator fit (including the ability to use the respirator without interfering with effective workplace

performance); Appropriate respirator selection for the hazards to which the employee is exposed;

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- Proper respirator use under the workplace conditions the employee encounters; and - Proper respirator maintenance. Training All employees will receive respirator training during their initial health and safety training class and on at least an annual basis, if required for their job classification. Training shall address employee knowledge of respirators, fit, use, limitations, emergency situations, wearing, fit checks, maintenance & storage, medical signs and symptoms of effective use and general requirements of the OSHA standard. The training must be provided before requiring the employee to use the respirator. Retraining Retraining shall be administered annually, and when the following situations occur: - Changes in the workplace or the type of respirator render previous training obsolete; - Inadequacies in the employee's knowledge or use of the respirator indicate that the employee has not retained

the requisite understanding or skill; or - Any other situation arises in which retraining appears necessary to ensure safe respirator use.

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City Construction, Inc. Qualitative Respiratory Fit Test Record Sheet Note: Employee Must Have Completed Respiratory Protection Training and Passed Airway Exam Prior To Fit Testing

Test Date: __________________

Employee Name: _______________________________ SS# _________________

Test Agent: Irritant Smoke (Stannic Chloride)

Respirator Identification:

Model: North 7700 Series Half Mask Size (circle one): Small Medium Large

Manufacturer: North Safety Products Approval No: 42 CFR 84

Additional Information: Respirator must be equipped with North HEPA filters

Fit Test Protocol (Test Subject Initials indicate steps were performed):

___ TOLD TO KEEP EYES CLOSED DURING SMOKE EXPOSURE

___Test subject smelled irritant smoke before fit test ___Wore respirator 5 minutes before fit test

___Protocol reviewed before fit test ___Test subject did not have hair in fitting area

___Shown how to wear respirator ___Performed positive pressure & negative fit

___Mirror available for use by subject check successfully after seating respirator

___Must wear PPE (hard hat, etc.) if needed

Fit Test Steps (1 minute each except Grimace = 15 seconds)

___ Breath normally ___ Breathe deeply ___ Turned head side to side

___ Nod up and down ___ Talking (Read Rainbow Passage) ___ Grimace

___ Jog in place ___ Breath normally

“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 beautiful 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 his reach, his friends say he is looking for the pot of gold at the end of the rainbow”.

Fit Test Results: _____ Pass _____ Fail

Test Subject Signature: _____________________________ Date: ________________

Examiner's Name: ___________________ Examiner's Signature: ____________________ Date: _____________

Distribution: Employee Local File – City Construction, Inc. Safety & Training Dept.

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Electrical Safety Purpose The purpose of the Electrical Safety program is to set forth procedures for the safe use of electrical equipment, tools, and appliances at City Construction, INC. Scope This program applies to all City Construction, Inc. employees, temporary employees, and contractors. When work is performed on a non-owned or operated site, the operator’s program shall take precedence, however, this document covers City Construction, Inc. employees and contractors and shall be used on owned premises, or when an operator’s program doesn’t exist or is less stringent. Definitions - Affected Personnel - Personnel who normally use and work with electrical equipment, tools, and appliances, but

who do not make repairs or perform lock out/tag out procedures. - Appliances - Electrical devices not normally associated with commercial or industrial equipment such as air

conditioners, computers, printers, copiers, coffee pots, microwave ovens, toasters, etc. - Circuit Breaker - A device designed to open and close a circuit by non-automatic means and to open the circuit

automatically on a predetermined over current without injury to itself when properly applied within its rating. - Disconnecting Means - A device, or group of devices, or other means by which the conductors of a circuit can be

disconnected from their source of supply. - Disconnecting Switch - A mechanical switching device used for isolating a circuit or equipment from a source of

power. - Double Insulated Tool - Tools designed of non-conductive materials that do not require a grounded, three wire

plugs. - Ground - Connected to earth or some conducting body that serves in place of the earth. - Grounded Conductor - A conductor used to connect equipment or the grounded circuit of a wiring system to a

grounding electrode or electrodes. - Ground Fault Circuit Interrupter (GFCI) - A device whose function is to interrupt the electric circuit to the load

when a fault current to ground exceeds some predetermined value that is less than that required to operate the over current protective device of the supply circuit. City Construction, Inc. shall use GFCIs in lieu of an assured grounding program.

- Insulated - A conductor encased within material of composition and thickness that is recognized as electrical insulation.

- Premises Wiring - That interior and exterior wiring, including power, lighting, control, and signal circuit wiring together with all of its associated hardware, fittings, and wiring devices, both permanently and temporarily installed, which extends from the load end of the service drop, or load end of the service lateral conductors to the outlet (s). Such wiring does not include wiring internal to appliances, fixtures, motors, controllers, motor control centers, and similar equipment.

- Qualified Person - One that has been trained in the repair, construction and operation of electrical equipment and the hazards involved.

- Strain Relief - A mechanical device that prevents force from being transmitted to the connections or terminals of a cable or extension cord.

- Class l Locations - Are those in which flammable gases or vapors are or may be present in the air in quantities sufficient to produce explosive or ignitable mixtures.

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- Class 1 Division 1 - Is a location (a) in which hazardous concentrations of flammable gases or vapors may exist under normal operating conditions; or (b) in which hazardous concentrations of such gases or vapors may exist frequently because of repairs or maintenance operations or because of leakage; or (c) in which a breakdown or faulty operation or equipment or processes might release hazardous concentrations of flammable gases or vapors, and might also cause simultaneous failure of electrical equipment.

- Class 1 Division 2 - Is a location o (a) in which volatile flammable liquids or flammable gases are handled, processed, or used, but in which

the hazardous liquid, vapors, or gases will normally be confined within closed containers or closed systems from which they can escape only in case of accidental rupture or breakdown of such containers or systems, or in of abnormal operation of equipment or

o (b) in which hazardous concentrations of gases or vapors are normally prevented by positive mechanical ventilation, and which might become hazardous through failure or abnormal operations of the ventilating equipment; or

o (c) that is adjacent to a Class 1, Division 1 location, and to which hazardous concentrations of gases or vapors might occasionally be communicated unless such communication is prevented by adequate positive-pressure ventilation from a source of clean air, and effective safeguards against ventilation failure are provided.

- Class II locations - Class II locations are those that are hazardous because of the presence of combustible dust. Class II locations include the following:

- Class II, Division 1 - A Class II, Division 1 location is a location o (a) in which combustible dust is or may be in suspension in the air under normal operating conditions, in

quantities sufficient to produce explosive or ignitable mixtures; or o (b) where mechanical failure or abnormal operation of machinery or equipment might cause such

explosive or ignitable mixtures to be produced, and might also provide a source of ignition through simultaneous failure of electric equipment, operation of protection devices, or from other causes, or

o (c) in which combustible dusts of an electrically conductive nature may be present. NOTE: This classification may include areas of, areas where metal dusts and powders are produced or processed, and other similar locations that contain dust producing machinery and equipment (except where the equipment is dust-tight or vented to the outside).

o These areas would have combustible dust in the air, under normal operating conditions, in quantities sufficient to produce explosive or ignitable mixtures.

o Combustible dusts that are electrically nonconductive include dusts produced in the handling and processing produce combustible dusts when processed or handled.

o Dusts containing magnesium or aluminum are particularly hazardous and the use of extreme caution is necessary to avoid ignition and explosion.

- Class II, Division 2 - A Class II, Division 2 location is a location in which:

o (a) combustible dust will not normally be in suspension in the air in quantities sufficient to produce explosive or ignitable mixtures, and dust accumulations are normally insufficient to interfere with the normal operation of electrical equipment or other apparatus; or

o (b) dust may be in suspension in the air as a result of infrequent malfunctioning of handling or processing equipment, and dust accumulations resulting there from may be ignitable by abnormal operation or failure of electrical equipment or other apparatus.

NOTE: This classification includes locations where dangerous concentrations of suspended dust would not be likely but where dust accumulations might form on or in the vicinity of electric equipment. These areas may contain equipment from which appreciable quantities of dust would escape under abnormal operating conditions or be adjacent to a Class II Division 1 location, as described above, into which an explosive or ignitable concentration of dust may be put into suspension under abnormal operating conditions.

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Responsibilities Managers/Supervisor The RSO Manager will develop electrical safety programs and procedures in accordance with OSHA requirements and/or as indicated by events and circumstances. Operations Managers and Supervisors are responsible for ensuring that only qualified employees and or qualified contractors perform electrical repairs or installations. Operations Managers are also responsible for ensuring all applicable electrical safety programs are implemented and maintained at their locations. Employees are responsible to use electrical equipment, tools, and appliances according to this program, for attending required training sessions when directed to do so and to report unsafe conditions to their supervisor immediately. Only qualified employees may work on electric circuit parts or equipment that has not been de-energized. Such employees shall be made familiar with the use of special precautionary techniques, PPE, insulating and shielding materials and insulated tools. Safe Work Practices Inspections - Electrical equipment, tools, and appliances must be inspected prior to each use. - The use of a hard fixed GFCI or a portable GFCI adapter shall be used with all portable hand tools, electric

extension cords, drop lights and all 110 volt equipment. - Faulty equipment, tools, or appliances shall be removed from service immediately and tagged “Out of Service”,

dated and signed by the employee applying the tag. Repairs - Only Qualified Personnel, who have been authorized by the department supervisor or manager, may make

repairs to supply cords on electrical tools and to extension cords. - The names of employees authorized to make repairs will be posted in the workplace. - Only certified electricians shall be allowed to make repairs to electrical equipment and wiring systems. - The supervisor obtaining the services of a certified electrician is responsible to verify the electrician’s credentials. - Employees shall not enter spaces containing exposed energized parts unless qualified and proper illumination

exists to enable employees to work safely. - Employees shall not wear conductive apparel such as rings, watches, jewelry, etc. (unless they are rendered

non-conductive by covering, wrapping, or other insulating means) while working on or near open energized equipment this includes batteries on trucks, forklifts, phone backup systems or other such equipment.

- If employees are subject to handle long dimensional conductor objects (ducts or pipes), steps for safe work practices shall be employed to ensure the safety of workers.

Extension Cords - Use only three-wire, grounded, extension cords and cables that conform to a hard service rating of 14 amperes

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 rating of at least 14 amps. - Cords must have suitable strain relief provisions at both 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.

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

- Cords must have a service rating 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

o A GFCI outlet; o A GFCI built into the cord; o 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 condition and ground lugs, possible internal breaks, and any other damage. If damage is found, the extension cord or electrical cord shall be remove from service and repaired or replaced.

- Extension cords shall not be used on compressor skid to operated 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. Outlets - Outlets connected to circuits with different voltages must use a design such that the attachment plugs on the

circuits are not interchangeable. Multiple Outlet Boxes - Multiple outlet boxes must be plugged into a wall receptacle. - Multiple 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 - Double insulated tools must have the factory label intact indicating the tool has been approved to be used

without a three wire grounded supply cord connection. - Double insulated tools must not be altered in any way, which would negate the factory rating. 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 labeled with the voltage rating. - Each breaker within a breaker panel must be labeled for the service it provides. - Disconnect switches providing power for individual equipment must be labeled accordingly. Ladders - Only approved, non-conductive ladders, may be used when working near or with electrical equipment, which

includes changing light bulbs. - Ladders must be either constructed of wood, fiberglass, or have non-conductive side rails. - Wood ladders should not be painted, which can hide defects, except with clear lacquer. - When using ladders they shall be free from any moisture, oils, and greases.

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Energized and Overhead High Voltage Power Lines & Equipment - A minimum clearance of 10 feet from high voltage lines must be maintained when operating vehicular and

mechanical equipment such as forklifts, cranes, winch trucks, and other similar equipment. - When possible, power lines shall be de-energized and grounded or other protective 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)

o Qualified – Table S5 Selection and Use of Work Practices o Approach Distances for Qualified Employees – Alternating Current). Approach distances are 10’ for 50kV

plus 4” for every additional 10kV. Confined or Enclosed Work Spaces

- 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).

- Protective shields, protective barriers or insulating materials as necessary shall be provided. Enclosures, Breaker Panels, and Distribution 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 operation and to permit access for maintenance and alteration. - A minimum two-foot working floor space in front of panels and enclosures shall be painted yellow. - Employees may not enter spaces containing exposed energized parts unless illumination is provided that enables

the employees to work safely. - Housekeeping in distribution rooms must receive high priority to provide a safe working and walking area in front

of panels and to keep combustible materials to the minimum required to perform maintenance operations. - All enclosures and distribution rooms must have “Danger: High Voltage – Authorized Personnel Only” posted on

the front panel and on entrance doors. - Flammable materials are strictly prohibited inside distribution rooms (Boxes, rags, cleaning fluids, etc.) Lock Out/Tag Out - 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 de-

energized, 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 City Construction, Inc. policy all electrical will be outsourced and performed only by qualified and licensed

electrical contractors who are familiar with the use of special precautionary techniques, PPE, insulating and shielding materials and insulated tools. Any equipment being made ready for maintenance will be locked out using City Construction, Inc.’s Control of Hazardous Energy – Lock Out/Tagout Program. Lockouts are performed by the RSO, 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 certified electricians may work on electric circuit parts or equipment.

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- Only authorized personnel may perform lock out/tag out work on electrical equipment and will follow City Construction, Inc.’s Control of Hazardous Energy – Lock out/Tagout Program.

- Authorized personnel will be trained in lock out/tag out procedures. - Affected personnel will be notified when lock out/tag out activities are being performed in their work area. Contractors - Only approved, certified, electrical contractors may perform construction and service work on City Construction,

Inc. or client property. - It is the Manager/Supervisors responsibility to verify the contractor’s certification. Fire Extinguishers - Approved fire extinguishers must be provided near electrical breaker panels and distribution centers. - Water type extinguishers 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 until you are sure there is no contact with an electrical circuit.

- When it is safe to make contact with the victim, begin CPR if the person’s heart has stopped or they are not breathing.

- Call for help immediately. Electric Welders - A disconnecting means shall be provided in the supply circuit for each motor-generator arc welder, and for each

AC transformer and DC rectifier 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 rating of this disconnecting means may not be less than the supply conductor amp capacity.

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 ½” bolt or larger, attached 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 plastic container with a flash point of 100

degrees F or less shall have a ground strap from the container and attached to the skid or a ground rod placed in the ground.

Assured Grounding OSHA requires that employers shall use either ground fault circuit interrupters (GFCI) or an assured equipment grounding conductor program to protect personnel from electrical shock while working. - City Construction, Inc. shall use GFCI’s in lieu of an assured grounding program.

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Ground Fault Circuit Interrupters The assured equipment grounding conductor program covers all 120-volt, single-phase 15 and 20 ampere receptacle outlets on construction 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 protection. City Construction has designated Dennis Fallon as the competent person to implement the program. - All hand portable electric tools and extension cords shall use a GFCI. - Additionally, approved GFCI’s shall be used for 240-Volt circuits in the same service as described above. - GFCI’s must be used on all 120 volt, single-phase 15 amp 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. - Electrical equipment noted in the assured equipment grounding conductor program must be visually inspected

for damage or defects before each day's use. Any damaged or defective equipment must not be used by the employee until repaired.

- Two tests are required by OSHA. One is a continuity test to ensure that the equipment grounding conductor is electrically continuous. It must be performed on all cord sets, receptacles which are not part of the permanent wiring of the building or structure, and on cord- and plug connected equipment which is required to be grounded. This test may be performed using a simple continuity tester, such as a lamp and battery, a bell and battery, an ohmmeter, or a receptacle tester.

- The other test must be performed on receptacles and plugs to ensure that the equipment grounding conductor is connected to its proper terminal. This test can be performed with the same equipment used in the first test.

- These tests are required before first use, after any repairs, after damage is suspected to have occurred, and at 3-month intervals. Cord sets and receptacles which are essentially fixed and not exposed to damage must be tested at regular intervals not to exceed 6 months. Any equipment which fails to pass the required tests shall not be made available or used by employees. The required tests must be recorded, and the record maintained until replaced by a more current record.

Training - All regular full time and temporary employees will be trained in electrical safety utilizing the City Construction,

Inc. Electrical Safety Training course or an approved equivalent. - Employees who face a risk of electric shock, but who are not qualified persons, shall be trained and familiar

with electrically related safety practices. - Employee shall be trained in safety related work practices that pertain to their respective job assignments. - Employees shall be trained on clearance distances. - Safe work practices shall be employed to prevent electric shock or other injuries resulting for either direct or

indirect electrical contacts when work is performed near or on equipment or circuits which are or may be energized.

- Qualified employees must adhere to the approach distances in Table S5 of CFR 1910.333 (below). Voltage Rage (phase to phase) Minimum Approach Distance

- Over 300V, not over 750V...............1 ft. 0 in. (30.5 cm). - Over 750V, not over 2kV.................1 ft. 6 in. (46 cm). - Over 2kV, not over 15kV.................2 ft. 0 in. (61 cm). - Over 15kV, not over 37kV...............3 ft. 0 in. (91 cm). - Over 37kV, not over 87.5kV............3 ft. 6 in. (107 cm). - Over 87.5kV, not over 121kV..........4 ft. 0 in. (122 cm). - Over 121kV, not over 140kV...........4 ft. 6 in. (137 cm).

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Scaffold Safety Program Purpose The purpose of this safety policy and procedure is to establish guidelines for the protection of City Construction, Inc. employees who work on scaffold work surfaces. Applicability Scaffolding has a variety of applications. It is used in new construction, alteration, routine maintenance, renovation, painting, repairing, and removal activities. Scaffolding offers a safer and more comfortable work arrangement compared to leaning over edges, stretching overhead, and working from ladders. Scaffolding provides employees safe access to work locations, level and stable working platforms, and temporary storage for tools and materials for performing immediate tasks. Scaffolding accidents mainly involve personnel falls and falling materials caused by equipment failure, incorrect operating procedures, and environmental conditions. Additionally, scaffolding overloading is a frequent single cause of major scaffold failure. This safety policy and procedure provides guidelines for the safe use of scaffolds. It includes training provisions and guidelines for scaffold erection and use. Reference This safety policy and procedure is established in accordance with Occupational Safety and Health Standards for General Industry (29 CFR 1910.28) and Occupational Safety and Health Standards for Construction Industry (29 CFR 1926.451). Policy Scaffolds shall be erected, moved, dismantled, or altered only under the supervision of a competent person and will have guardrails and toe boards installed. When scaffolding hazards exist that cannot be eliminated, then engineering practices, administrative practices, safe work practices, Personal Protective Equipment (PPE), and proper training regarding Scaffolds will be implemented. These measures will be implemented to minimize those hazards to ensure the safety of employees and the public. Training will be provided for all employees who work on scaffolds. Responsibilities It is the responsibility of Dennis Fallon, RSO, each manager/unit head, supervisor, and employee to ensure implementation of City Construction, Inc.’s safety policy and procedure on Scaffolds. It is also the responsibility of each City Construction, Inc. employee to report immediately any unsafe act or condition to his or her supervisor. Definitions Brace: A tie that holds one scaffold member in a fixed position with respect to another member. Brace also means a rigid type of connection holding a scaffold to a building or structure. Coupler: A device for locking together the component tubes of a tube and coupler scaffold. Harness: A design of straps which is secured about the employee in a manner to distribute the arresting forces over at least the thighs, shoulders, and pelvis, with provisions for attaching a lanyard, lifeline, or deceleration device. Hoist: A mechanical device to raise or lower a suspended scaffold. It can be mechanically powered or manually operated.

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Maximum Intended Load: The total load of all employee, equipment, tool, materials, transmitted, wind, and other loads reasonably anticipated to be applied to a scaffold or scaffold component at any one time. Mechanically Powered Hoist: A hoist which is powered by other than human energy. Outriggers: The structural member of a supported scaffold used to increase the base width of a scaffold in order to provide greater stability for the scaffold. Platform: The horizontal working surface of a scaffold. Safety Belt: A strap with means for securing about the waist or body and for attaching to a lanyard, lifeline, or deceleration device. Scaffold: Any temporary elevated or suspended platform and its supporting structure used for supporting employees or materials or both, except this term does not include crane or derrick suspended personnel platforms. Training Affected employees will receive instruction on the particular types of scaffolds which they are to use. Training should focus on proper erection, handling, use, inspection, and care of the scaffolds. Training must also include the installation of fall protection, guardrails, and the proper use and care of fall arrest equipment, electrical hazards and falling objects. This training should be done upon initial job assignment. Retraining shall be done when job conditions change. Periodic refresher training shall be done at the discretion of the supervisor. Company designated “competent person(s)” will receive additional training regarding the selection of scaffolds, recognition of site conditions, recognition of scaffold hazards, protection of exposed personnel and public, repair and replacement options, and requirements of standards. Safe Scaffold Erection and Use Safe scaffold erection and use is important in minimizing and controlling the hazards associated with their use. Scaffold work practices and rules should be based on:

• Sound design • Selecting the right scaffold for the job • Assigning personnel • Fall protection • Guidelines for proper erection • Guidelines for use • Guidelines for alteration and dismantling • Inspections • Maintenance and storage

Types of Scaffolds There are many different types of scaffolds used in City Construction, Inc. The three major categories are:

- Self-supporting scaffolds - Suspension scaffolds - Special use scaffolds

Self-supporting scaffolds are one or more working platforms supported from below by outriggers, brackets, poles, legs, uprights, posts, frames, or similar supports. The types of self-supporting scaffolds include:

• Fabricated Frame • Tube and Coupler • Mobile • Pole

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Suspension scaffolds are one or more working platforms suspended by ropes or other means from overhead structures(s). The types of suspension scaffolds include:

• Single-Point Adjustable (Boatswain’s Chairs) • Two-Point Adjustable (Swing Stage) • Multiple-Point Adjustable • Multi-Lend • Category • Float (Ship) • Interior Hung • Needle Beam

Special use scaffolds and assemblies are capable of supporting their own weight and at least 4 times the maximum intended load. The types of special use scaffolds include:

• Form and Carpenter Bracket • Roof Bracket • Outrigger • Pump Jack • Ladder Jack • Window Jack • Horse • Crawling Boards • Step, Platforms, and Trestle Ladder

Responsibilities RSO Dennis Fallon, RSO will ensure adequate funds are available and budgeted for the purchase of scaffolds. They will also identify the employees affected by this safety policy and procedure. Managers Dennis Fallon, RSO will obtain and coordinate the required training for the affected employees. Dennis Fallon, RSO will also ensure compliance with this safety policy and procedure through their auditing process. Supervisors Supervisors will not allow any employee who has not received the required training to perform any of the tasks or activities related to scaffold erection and/or dismantling. Supervisors will communicate appropriate needs to managers/unit heads and/or supervisors. Supervisors will ensure that employees are provided with PPE as necessary for their job. Supervisors will ensure that a competent person is in charge of scaffold erection according to the manufacturer's specifications. Competent Person The competent person will oversee the scaffold selection, erection, use, movement, alteration, dismantling, maintenance, and inspection. The competent person will be knowledgeable about proper selection, care, and use of the fall protection equipment. Additionally, the competent person shall assess hazards.

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Employees Employees shall comply with all applicable guidelines contained in this safety policy and procedure. Employees will report damaged scaffolds, accessories, and missing or lost components. Employees will assist with inspections as requested. Safety Department Safety and Loss Control will provide prompt assistance to managers/unit heads, supervisors, or others as necessary on any matter concerning this safety policy and procedure. Safety and Loss Control will assist in developing or securing required training. Safety and Loss Control will also work with Purchasing and Central Equipment Unit to ensure that all newly purchased scaffolds comply with current safety regulations and this safety policy and procedure. Safety Engineers will provide consultative and audit assistance to ensure effective implementation of this safety policy and procedure. Purchasing Department Purchasing Department is responsible for ensuring that purchased scaffolds and related material and equipment meet or exceed current safety regulations. Safety Requirements for Scaffolds

• The footing or anchorage for scaffolds shall be sound, rigid, and capable of carrying the maximum intended load without settling or displacement. Unstable objects such as barrels, boxes, loose brick, or concrete blocks shall not be used to support scaffolds or planks.

• No scaffold shall be erected, moved, dismantled, or altered except under the supervision of competent persons or as requested for corrective reasons by Safety and Loss Control Personnel.

• Guardrails and toe boards shall be installed on all open sides and ends of platforms more than 10 feet above the ground or floor, except needle beam scaffolds and floats. Scaffolds 4 feet to 10 feet in height having a minimum horizontal dimension in either direction of less than 45 inches shall have standard guardrails installed on all open sides and ends of the platform.

• Guardrails must be 2 X 4 inches, or the equivalent, not less than 36 inches or more than approximately 42 inches high, with a mid-rail, when required, of 1 X 4 inch lumber, or the equivalent. Supports must be at intervals not to exceed 8 feet. Toe board and the guardrail shall extend along the entire opening.

• Scaffolds and their components must be capable of supporting without failure at least 4 times the maximum intended load.

• Any scaffold, including accessories such as braces, brackets, trusses, screw legs, ladders, couplers, etc., damaged or weakened from any cause must be tagged defected and then repaired or replaced immediately, and shall not be used until repairs have been completed.

• All load-carrying timber members of scaffold framing shall be a minimum of 1,500 fiber (Stress Grade) construction grade lumber.

• All planking must be Scaffold Grades, or equivalent, as recognized by approved grading rules for the species of wood used.

• The maximum permissible span for 2 X 9 inch or wider planks is shown in the following: • The maximum permissible span for 1-1/4 X 9 inch or wider plank of full thickness shall be 4 feet with

medium duty loading of 50 psi. • All planking or platforms must be overlapped (minimum 12 inches) or secured from movement. • An access ladder or equivalent safe access must be provided. 7

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• Scaffold plank must extend over their end supports not less than 6 inches or more than 18 inches. • The poles, legs, or uprights of scaffolds must be plumb and securely and rigidly braced to prevent swaying

and displacement. • Overhead protection must be provided for men on a scaffold exposed to overhead hazards. • Slippery conditions on scaffolds shall be eliminated immediately after they occur. • No welding, burning, riveting, or open flame work shall be performed on any staging suspended by means

or fiber of synthetic rope. Only treated or protected fiber or synthetic ropes shall be used for or near any work involving the use of corrosive substances or chemicals.

• Wire, synthetic, or fiber rope used for scaffold suspension shall be capable of supporting at least 6 times the intended load.

• Scaffolds shall be provided with a screen between the toe board and guardrail, extending along the entire opening, consisting of No. 18 gauge U.S. Standard wire one-half inch mesh or the equivalent, when personnel are required to work or pass underneath the scaffolds.

• A safe distance from energized power lines shall be maintained. • Tag lines shall be used to hoist materials to prevent contact. • Suspension ropes shall be protected from contact with heat sources (welding, cutting, etc.) and from acids

or other corrosive substances. • Scaffolds shall not be used during high wind and storms. • Ladders and other devices shall not be used to increase working heights on scaffold platforms. • Scaffolds shall not be moved while employees are on them. • Loose materials, debris, and/or tools shall not be accumulated to cause a hazard. • Employees working on suspended scaffolds shall employ a fall-arrest system. • Scaffold components shall not be mixed or forced to fit which may reduce design strength. • Scaffolds and components shall be inspected at the erection location. Scaffolds shall be inspected before

each work shift, after changing weather conditions, or after prolonged work interruptions. • Casters and wheel stems shall be pinned or otherwise secured in scaffold legs. Casters and wheels must

be positively locked if in a stationary position. • Tube and coupler scaffolds shall be tied to and securely braced against the building at intervals not to

exceed 30 feet horizontally and 26 feet vertically.

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First AID 1.0 Policy To insure that prompt and effective medical assistance is provided to the employees of City Construction, Inc. and its associates in case of workplace injury or illness, the following first aid and medical services procedure is provided. It is the responsibility of each manager / supervisor to assure that compliance to the First Aid & Medical Services Procedure is provided. This policy covers minimum performance standards applicable to all company associates, employees and locations. Local practices requiring more detailed or stringent rules, or local, state or other federal requirements regarding this subject can and should be added as an addendum to this procedure as applicable. 2.0 Purpose This First Aid & Medical Services Procedure is designed to establish specific common guidelines for company branches to follow in assuring that prompt medical attention is provided to employees suffering from either a work related or non-work related injury or illness. Each company facility and jobsite must ensure that readily available medical personnel and first aid supplies are available to all employees to provide advice and consultation within reason, regarding matters of employee occupational health and to respond in case of accident. This includes identifying and posting the location of a designated medical treatment facility and/or emergency care center in a conspicuous location at each fixed location or fixed jobsite. Should outside medical services be unable to respond in a reasonable amount of time as defined by OSHA (3 to 4 minutes), the company facility and jobsite may use various strategies to provide access within this time frame, such as training internal personnel who will be capable of acting as voluntary first responders. 3.0 Definitions Established Medical Treatment Facility means the occupational medical treatment provider and/or emergency care center identified as being capable of, and established to initially treat employee injuries and illnesses. First Aid means the following types of treatment:

• Using non-prescription medications at non-prescription strength • Cleaning, flushing, or soaking wounds on the skin surface • Using wound coverings, such as bandages, ‘Band-Aids’, gauze pads, etc., or using ‘Steri-Strips’ or butterfly

bandages. • Using hot or cold therapy • Using any totally non-rigid means of support, such as elastic bandages, wraps, etc. • Using temporary immobilization devices while transporting an employee, such as splints, slings, neck

collars, or back boards • Drilling a fingernail or toenail to relieve pressure, or draining fluids from blisters • Using eye patches • Using simple irrigation or a cotton swab to remove foreign bodies not embedded in or adhered to the eye. • Using irrigation, tweezers, cotton swab or other simple means to remove splinters or foreign material from

areas other than the eye • Using finger guards • Using massages • Drinking fluids to relieve heat stress

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Illness can be classified as a skin disease/disorder, respiratory condition, poisoning, or other illnesses resulting from an event in the work environment. Examples include, but are not limited to:

• Contact dermatitis • Eczema • Silicosis • Asbestosis • Toxic inhalation • Poisonings by lead, mercury, or other metals • Poisonings by carbon monoxide, hydrogen sulfide, or other gases • Poisonings by organic solvents or by other chemicals • Heatstroke, sunstroke, heat exhaustion, or other heat-related factors • Freezing, frostbite, or other cold-related factors • Effects of Non-ionizing radiation (welder’s flash or lasers) • Blood borne Pathogenic diseases • Microbial Exposure • Ionizing Radiation

Injury means any wound or damage to the body resulting from an event in the work environment. Examples include:

• Cut/laceration • Puncture • Abrasion • Contusion/bruise • Fracture • Chipped tooth • Amputation • Insect bite • Electrocution • Thermal, chemical, electrical or radiation burn • And, sprain/strain injuries to muscles, joints and connective tissues when the result from a slip, trip, fall or

other similar accident.

Medical Treatment means the managing and caring for a patient for the purpose of combating disease or disorder. The following activities are NOT medical treatment:

• First aid • Visits to a doctor solely for observation or counseling • Diagnostic procedures, including the administering prescription medications that are used solely for

diagnostic procedures

Work-related Injury or Illness means an injury or illness resulting from an event or exposure in the work environment causing or contributing to the condition or significantly aggravating a preexisting condition. Work Environment means includes work sites where one or more employees are present as a condition of their employment.

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4.0 Requirements 4.1 Designated Medical Treatment Facility Company associates will ensure that readily available medical personnel are available to employees to provide advice and consultation within reason regarding matters of employee occupational health. Each fixed facility and fixed jobsite must identify and post the location of a designated medical treatment facility and/or emergency care center including name, address, telephone number, and hours of operation. This information should be posted in a conspicuous location at each fixed facility or fixed job site. The designated medical treatment facility or emergency care center should maintain similar hours of operation as the facility and be able to respond to a workplace emergency within a reasonable amount of time. Appendix outlines the format of a posting that should be displayed in a conspicuous location at each fixed facility or fixed job site. Many medical providers have and will provide their own posting. The RSO must determine if the posting has the necessary elements needed to inform employees regarding the designated medical treatment facility. 4.2 First Aid ALL INJURIES, REGARDLESS OF HOW SMALL, MUST BE REPORTED TO THE EMPLOYEE’S IMMEDIATE SUPERVISOR AND TREATED AS SOON AS POSSIBLE AFTER AN ACCIDENT. If an employee becomes injured or ill anywhere due to a work-related or non-work related problem and needs immediate medical aid, it must be reported to his/her Supervisor or the Safety Officer. Failure to report minor injuries or to receive supervised medical treatment may result in serious infections or complications to the employee’s health. In the absence of a clinic or hospital near the workplace, OSHA regulations require that a person or persons be trained to render first aid and that first aid supplies be readily available. Although the term “readily available” has not been defined in the regulations, OSHA has indicated that 3-4 minutes is acceptable as the time frame within which to begin first aid. OSHA’s interpretation presents a challenge to a service company like ours because our “workplace” is not always in a fixed location -- it is a changing environment that follows the employee wherever they may be working. Accordingly, the company will use various strategies to provide employees with access to First Aid. These may include training company personnel to self-administer First Aid. Training company personnel who are willing to serve as “first responders” and render First Aid/CPR to others on a voluntary basis; providing access to trained individuals from other companies who work alongside our employees on job sites (especially construction sites); providing access to client medical clinics; or calling 9-1-1 or local emergency phone numbers as indicated in the Health and Safety Plan. Because of the potential for exposure to blood borne pathogens and significant liability concerns, there is no job in the Company that requires an employee to render First Aid or cardiopulmonary resuscitation (CPR) in the course and scope of their employment, unless such a requirement becomes necessary due to local, State or Federal Safety and Health Regulations. Transportation of injured persons will be by ambulance unless a volunteer chooses to assist by driving the injured employee to a medical facility. If there is any question as to the best method of transportation an ambulance should be utilized. When the company’s strategy for providing access to First Aid/CPR involves the use of “first responders”, a First Responders Program should be established and administered at the local level. The Safety Officer is responsible for monitoring and maintaining this program, if implemented.

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4.2a Elements of the First Responder Program should include: 1. Safety Officer must be certified in basic First Aid & CPR per a recognized certification source such as the Red Cross, local hospital, etc. The Red Cross first aid course and CPR course are approximately 8 hours in duration. CPR requires annual refreshers. First Aid requires refreshers every three (3) years. 2. Responsible Safety Officer will seek employees who wish to volunteer to be trained and certified in basic First Aid & CPR per a recognized certification source as defined by local or State requirements. These employees must maintain “current” First Aid and CPR certification, appropriately documented, in their personnel file. 3. Basic First Aid & CPR will be administered by First Responders only to stabilize the employee until professional medical attention can be provided. 4. Due to the potential occupational exposure to First Responders, it is the responsibility of the Safety Officer or his/her designee to develop and follow an Exposure Control Program, where and to the extent such a program is required by OSHA 29CFR 1910.1030 – Blood borne Pathogens Standard and Policy Section 9 –Blood borne Pathogens. (This program is not required unless First Aid/CPR response is a required part of an employee’s job description and function at our company. However, we will still: encourage Voluntary Responders to learn and follow universal precautions.) First Aid / CPR. Employee training in basic First Aid and cardiopulmonary resuscitation (CPR) is encouraged because of its value and benefit to individuals, their families and the community. The company also supports any employee who, while on the job, chooses to act as a “Good Samaritan” to assist a fellow employee or another person with First Aid or CPR. It is the company’s intent that first Aid supplies and basic personal protective equipment against blood borne pathogens be accessible to employees at every work site during all shifts. If an employee makes the decision to provide first aid to someone, universal precautions shall be followed and it should be assumed that all blood and bodily fluids are contaminated with blood borne pathogens. In addition, they should wear protective medical gloves found in the First Aid Kit and use any other personal protective equipment (such as protective glasses with side shields or a full face shield) to help avoid exposure to blood in the eyes or on the face. First Aid providers should follow the example of emergency medical personnel, doctors and nurses who wear personal protective equipment to prevent exposure to bloodborne pathogens. If blood or potentially contaminated material gets on the skin, it must be washed off immediately using water and a non-abrasive soap. If available, an antiseptic soap or rinse must be used. If blood ever gets in the eyes, lips, mouth or nose, the employee must go to a sink, water fountain, eye wash or body wash station and flush the area with running water as quickly as he/she can. The supervisor must always be aware of the potential exposure to a bloodborne pathogen after the employee has washed or flushed the exposed area. Decontamination of the exposed surfaces, tools and equipment should be conducted. This must be done immediately, and no later than the end of the shift or work period. Remember that there is a vaccine for Hepatitis B. This must be discussed with a physician as soon as possible after a potential exposure. Refer to the requirements of OSHA 29CFR 1910.1030 – Bloodborne Pathogens Standard and Policy Section 9 – Bloodborne Pathogens.

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4.3 First Aid Stations / First Aid Kits A First Aid Station or First Aid Kit is to be readily available to employees as described previously. For employees working off-premises, a first aid kit should be provided in each company vehicle, signed-out for use when traveling in personal vehicles and rental vehicles, or provided on the jobsite. Whether within the facility or in a vehicle, each First Aid Kit must be stored in a properly labeled weather-proof container, stocked with the basic supplies specified in the inventory on Attachment B. The physician’s approval of the inventory list is not required, but may be needed to address unusual exposure situations. IMPORTANT: If an employee declines First Aid and/or medical treatment for a reported on-the-job injury after the Supervisor recommends it, that employee should NOT be allowed to continue work. Supervisors should discuss each situation with the Safety Officer or Project Manager before allowing that employee to return to duty. The Safety Officer, or someone he/she may designate, is responsible for checking and maintaining the First Aid Cabinets. Supervisors on jobsites are responsible for assuring suitable supplies are provided in the first aid kits on-site or in their vehicles. This person will take a weekly inventory of supplies and make sure the station or kit remains adequately stocked. A basic inventory list for First Aid Kits is provided. Because of the variety of operations that the Company is involved in, it is suggested that consultation with the Facility’s designated medical treatment facility be arranged to determine if the First Aid Kits are adequate for the operational exposures of your particular workplace. Attachment B can be photocopied and used as a guide for re-ordering supplies. 4.4 Emergency Eye / Body Wash Stations Where the eyes and/or body of any employee may be exposed to injurious chemical / corrosive materials, suitable eye and/or body drenching and/or flushing facilities shall be provided whether at a company facility or at a temporary worksite. Emergency eye and/or body wash stations can be either of temporary or permanent installation. In areas where the extent of possible exposure to injurious chemical / corrosive materials is very low, a specially designated pressure controlled and identified water hose can be used when proper personal protective equipment also is used (e.g. full face shield). The hose system must be equipped with a proper face and body wash nozzle and provide copious amounts of low velocity potable water. An appropriate portable eye wash device containing not less than one gallon of potable water, would also be acceptable under these conditions. At locations where hazardous chemical / corrosive materials are handled by employees (e.g. battery servicing facility), proper eyewash and body drenching equipment must be available. Although OSHA has not adopted specific requirements regarding flow rates for drenching/flushing facilities, ANSI Z358.1 provides detailed information regarding the installation and operation of emergency eyewash and shower equipment, including the requirements for flow rate. Section 4.1 of ANSI Z358.1 specifies that emergency shower heads shall be capable of delivering a minimum of 20 gallons per minute (gpm) of flushing fluid at a velocity low enough to be non-injurious to the user. A sufficient volume of flushing fluid shall be available to supply the flow rate for a minimum fifteen minute period. As such, both temporary and permanently installed eye / body wash stations must provide at least 20 gpm for 15 minutes. Inspection and maintenance of eye wash systems should be provided at least weekly by assuring sanitary conditions and /or following the manufacturer’s requirements for maintenance. Plumbed systems should also be provided a water flow test to minimize contaminants in the line. Inspection and maintenance should be properly documented. 5.6 Blood borne Pathogens (Universal) Precautions Training When an employee comes into direct contact with blood, bodily fluids or body tissues of another person, they are at risk of becoming infected with diseases that may be carried in the other person’s body fluids. Accidental exposures can happen on or off the work site, in any number of day-to-day situations. This is why the Company believes that each employee should have a basic understanding and awareness of the dangers of contracting a potentially

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deadly disease through such exposures. Communicating basic information about these hazards, including information contained in this policy, is part of the Company’s safety and health program. Therefore, employees should receive a basic awareness level training concerning “Universal Precautions” such that employees may follow Universal Precautions in the event of potential exposure to blood or other body fluids. 5.6.1 Training Requirements Training records must be maintained by the Responsible Safety Officer containing the date of the training, a summary of the training session, names and qualifications of the instructors conducting the training and the names and job titles of the persons attending the training. Training records must be maintained for a minimum of three (3) years from the date the training was conducted. Training must be conducted by a qualified and competent person knowledgeable in the subject matter. 5.6.2 First Responder Exposure If an employee is a First Responder or decides to be a “Good Samaritan” and provides first aid on an injured victim involving blood or bodily fluids, personal protective equipment must be used and Universal Precautions followed treating all bodily fluids as infectious. Refer to OSHA 29CFR 1910.1030 – Bloodborne Pathogens Standard and Policy Section 9 – Bloodborne Pathogens. In addition to those items listed in Appendix 20-B and/or possibly required by a consulting physician, First Aid Stations must at least include the following supplies:

• latex gloves • one-way valve CPR mask • biohazard bags • plastic baggies • tongs

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Confined Space Entry 1.0 Confined Space Program 1.1 Purpose The purpose of this program is to provide specific procedures/safe work practices for employees required to enter confined spaces. These procedures/practices will be implemented in compliance with all applicable state and federal regulations pertaining to confined space entry.

1.2 Objectives The objectives of the Confined Space program at City Construction include:

• To comply with all state and federal regulations regarding confined spaces. • To limit the number of confined space entries. • To identify, evaluate, and eliminate potential hazards within the confined spaces prior to entry. • To establish and implement a permit system for entry into confined spaces. • To train employees who may work in confined spaces on proper procedures and entry techniques.

2.0 Regulations/References 2.1 Regulations Regulations/references pertaining to the Confined Spaces Program are found in the following publications:

Occupational Safety and Health Standards for General Industry (29 CFR 1910.146).

3.0 Responsibilities/Resources Employed 3.1 Safety Manager: The Safety/Health manager serves as the first contact for issues concerning the confined space program. The Safety/Health manager is responsible for establishing a written Confined Space Program that includes evaluations of the confined spaces entered by the employee/contractor. He/she is responsible for establishing and maintaining a training program that will provide exposed employees with the understanding, knowledge, and skills necessary for safe and proper work in confined spaces. The Safety/Health manager shall review the Confined Space Program, using the canceled permits, at least once per year, and shall revise the program as necessary to ensure that employees participating in entry operations are protected from confined space hazards. The Safety/Health manager is responsible for providing employees with the equipment required to safely enter confined spaces. The Safety/Health manager is available to provide training on proper confined space entry techniques, recommend safety equipment, and assist in confined space evaluations. The Safety/Health manager shall review all required host employer confined space procedures prior to authorize entry by any party. 3.2 Area Supervisors: The area supervisor will be responsible for identifying workers that may be expected to enter confined spaces, ensuring that these workers receive required training before entering the spaces, and ensuring that their subordinates follow established entry procedures. 3.3 Entry Supervisors: Entry Supervisors are the persons responsible for determining if acceptable entry conditions are present at the confined space where entry is planned, authorizing entry, supervising entry operations, and terminating entry when required. Entry supervisors shall be trained on necessary skills and responsibilities Entry Supervisors are listed below:

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1) Dennis Fallon 2) Robert Fallon Jr. 3) Michael Fallon

3.4 Trained and Authorized Attendants and Entrants: Trained and authorized attendants and entrants are responsible for working in and around confined spaces according to guidelines and work practices established by City Construction. Authorized entrants are also responsible for refusing to work in confined spaces until an entry supervisor has deemed entry to be safe and has given approval for entry, or if a hazard is identified while working in the confined space. The authorized attendants shall attend only one confined space entry at any one time, and shall not perform any other duties. 3.5 Training Frequency: Confined Space training will occur: before initial assignment to jobs that would require entry into confined spaces; when there is a change in assigned duties; when a change in permit space operations create a new hazard; whenever an employee deviates from established procedure; and when inadequacies in an employee's knowledge is identified. The confined space training will include all Supervisors, attendants, and entrants. Confined space training will establish employee proficiency in the duties required by the confined space standard.

Training documents will include the employee's name, signature of the trainer, and the dates of the training. Certification is made available to employees and their authorized representative.

3.6 Training Content: The training programs established for City Construction include: • Confined space identification • Identification and evaluation of permit space hazards • Proper gas meter operation • Safe entry techniques • Attendant and entrant responsibilities • Communication techniques • Rescue procedures • Ventilation techniques • Supervisory responsibilities • Permit completion/cancellation techniques • Location of permit spaces A copy of the established training program can be obtained from the Safety/Health manager.

4.0 Confined Space Locations 4.1 Inventory Prior to performing any work, City Construction shall meet with the host employer’s safety and health representative to determine if there are any confined spaces at the jobsite. If no inventory of confined spaces exists, the host employer shall conduct an onsite assessment of all areas of the jobsite that may contain potential confined spaces. A confined space assessment form similar to (Appendix A) must be used to classify all confined spaces found. If it is necessary to classify a confined space as a permit-required confined space, the host employer must fulfill all of the OSHA requirements pursuant to § 1910.146, including but not limited to:

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1) Notify the contractor, in writing, of the determination that the confined space is a “permit-required confined space”;

2) Notify the contractor, in writing, of any actual or potential hazard(s) that may be encountered in the confined space;

3) Develop and implement a permit-required confined space entry procedure; 4) Conduct training for the City Construction’s employees on compliance with the host employer’s permit-

required confined space entry program; 5) Identify and label the confined space: DANGER – do not enter permit required confined space. The label

must be visible from outside the confined space; When performing confined space evaluations, air monitoring and inspections will be conducted by the host employer. If not provided by the host employer, a Confined Space Summary sheet indicating permit spaces and requirements for entry will maintained at the jobsite. Prior to performing any work, the Confined Space Summary sheet will be reviewed with all employees at the jobsite.

4.2 Reclassification of Permit Required Confined Spaces When a Permit Required Confined Space is to be reclassified to a “non-permit” status, the host employer shall issue a written certification that contains the date, the location of the space, and the signature of the person making the determination that all hazards have been eliminated. The certification shall be made available to each employee entering the space or to that employee's authorized representative. This documentation must be completed each time a permit-required confined space is reclassified, and remains in effect only as long as all of the hazards remain eliminated. This reclassification procedure is contained in the confined space assessment form (Appendix A), of this program. 5.0 Entry Permits 5.1 Permit Required Spaces: The information necessary to design a permit for permit-required space entry, if not provided by the host employer, is included at the end of this program (Appendix B).

5.2 Permit Requirements The entry supervisor shall prepare an entry permit that contains at least all of the information listed in Appendix B. The permit shall be made available to all supervisors, entrants, attendants, authorized employee representatives, and rescue personnel. The permit must remain posted outside of the permit space entry portal, and remain there for the duration of the authorized entry. Any changes of personnel (supervisors, attendants, entrants), or testing and monitoring data shall be added to the permit. At the end of the authorized entry or after entry operations have been completed, the entry supervisor shall cancel the permit and maintain all cancelled permits for at least one year. A new and updated permit shall be developed, implemented, and maintained for each permit space entry.

6.0 Prevention of Unauthorized Entry 6.1 Posting of Confined Spaces All Permit-Required Confined Spaces that can be readily labeled are posted in a manner designed to inform employees of the existence/location of the dangerous space. The signs read as follows:

DANGER! PERMIT-REQUIRED CONFINED SPACE, DO NOT ENTER!

If posting danger signs cannot be used to inform the exposed employees, use any other effective means to

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warn of the existence, location, and the danger posed by the permit spaces.

6.2 Other Necessary Precautions If it is concluded that posting and training are inadequate to prevent unauthorized entry into permit spaces, covers, guardrails, fences, locks or other methods of restricting access shall be implemented. 7.0 Entry Procedures

7.1 Entry Procedures: The following list identifies the minimal means, procedures, and practices necessary for safe permit space entry operations and shall be the responsibility of the host employer:

1) Identify and evaluate permit space hazards. 2) Control hazards and specify acceptable entry conditions. 3) Allow authorized entrants or employee authorized representative observe monitoring and testing. 4) Isolation of the permit space. 5) Purge, inert, flush, or ventilate the permit space as necessary to eliminate or control atmospheric hazards. 6) Provide barriers to confined spaces that protect entrants from hazards created by pedestrians, vehicles, or

other external factors. 7) Verify that conditions within the permit space are acceptable throughout the duration of the authorized

entry. 8) After authorized entry has concluded, or entry operations have been completed, the permits shall be

cancelled and the permit space isolated from unauthorized entry. 7.2 Review of Entry Operations and Procedures: City Construction shall review entry operations, procedures, and cancelled entry permits at least annually. Additionally, a review shall be conducted if there is reason to believe that the measures taken under City Construction permit space program may not provide affected employees with the necessary protection. The review and revisions shall correct any deficiencies found to exist under the prior entry operations and procedures. Circumstances that require the review of the permit space program are listed below:

• Unauthorized entry of a permit space; • A detection of a permit space hazard not covered by the permit; • The detection of a condition prohibited by the permit; • The occurrence of an injury, or a near-miss during entry operations; • The change in the use or configuration of a permit space; and • Employee complaints about the ineffectiveness of the permit space program.

7.3 Confined Space Equipment When necessary the following equipment will be provided, and properly maintained, at no cost to the employee. City Construction will ensure that employees required working in or around confined spaces will properly use the following equipment:

• Testing and monitoring equipment; • Ventilation equipment; • Communication equipment;

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• Personal protective equipment; • Lighting equipment; • Barriers and shields; • Equipment necessary for safe ingress and egress; • Rescue and emergency equipment; • Other equipment necessary for safe entry and rescue from permit spaces;

7.4 Evaluation of Permit Space Conditions When conducting permit space entry operations City Construction will ensure that the following evaluation of permit space conditions is conducted:

• Test conditions of the permit space prior to any authorized entry. If the space cannot be isolated (large size, or portion of continuous system), conduct pre-entry testing as is feasible, and maintain continuous monitoring of the areas occupied by authorized entrants.

• Test and monitor the permit space as necessary to ensure that acceptable entry conditions are maintained during the course of entry operations.

• When testing for atmospheric hazards the testing shall be conducted in the following order: 1.) Oxygen; 2.) Combustible gases and vapors; and 3.) Toxic gases and vapors

• If the confined space is determined to be immediately dangerous to life and health (IDLH) City Construction does not permit any employees entrance.

• Allow authorized entrant or employee’s authorized representatives observe re-entry and subsequent testing or monitoring data.

• Re-evaluate the permit space if authorized entrant or employee’s authorized representative feel that the evaluation of the permit space was inadequate.

• Immediately provide each authorized entrant or employee’s authorized representative the results of any testing or monitoring.

7.6 Number of Attendants Required Acceptable conditions do not exist, and authorized entry is not permitted, unless there is at least one attendant stationed immediately outside the permit space to be entered. The attendant must be on duty outside the confined space for the duration of entry operations.

7.7 Multiple Employers/Contractors City Construction shall be informed of the permit space locations and permit space hazards at any jobsite. All affected outside employers and contractors will be educated on the confined space program and confined space requirements of City Construction. City Construction shall not enter into any binding business agreement with contractors or employers that do not meet the confined space program and training requirements of 29 CFR 1910.

7.8 Conclusion of Operations City Construction shall be debrief by the host employer at the conclusion of the entry operations regarding the permit space program followed and regarding any hazards confronted or created in permit spaces during entry operations.

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8.0 Rescue Procedures 8.1 Rescue Plan: There shall be a rescue plan developed by the host employer for every permit-required confined space at the jobsite. Whenever feasible, the rescue plan will specify methods that do not involve entry by rescuers into the confined space. The attendant and/or the Entry Supervisor are responsible for preventing unauthorized persons in attempting a rescue inside the confined space.

8.2 Rescue Equipment: All necessary rescue equipment to effectively conduct the rescue shall be provided and in proper working condition prior to entry into the space.

8.3 Rescue Practice At least annually, designated rescuers shall practice making a rescue using either a manikin or an actual entrant, from a space similar to the one being entered. If the space has not been entered for more than one year, the rescue practice will be conducted prior to entry.

8.4 Rescue Plan and Entry Permit The entry permit shall verify that:

• rescuers have been notified; • rescuers are physically located so they can effect a successful and timely rescue at any point during the

entry; • rescuers have been trained on rescue from the particular space being entered; • All required rescue equipment is immediately available.

8.5 Offsite Rescue Services Prior to a decision to use an off-site service to provide rescue, verification shall be made that the off-site rescue services complies with all requirements of this section.

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APPENDIX A

CONFINED SPACE EVALUATION FORM

CONFINED SPACE EVALUTION FORM

CONFINED SPACES ARE DEFINED AS:

1) Large enough and configured such that an employee can bodily enter and performed the assigned work.

2) Has limited or restricted means for entry or exit.

3) Is not designed for continuous employee occupancy. PERMIT-REQUIRED CONFINED SPACES ARE DEFINED AS HAVING ONE OR MORE OF THE FOLLOWING:

1) Contains or has a potential to contain a hazardous atmosphere.

2) Contains a material that has the potential for engulfing an entrant.

3) Has an internal configuration such that an entrant could be trapped or asphyxiated by inwardly converging walls, or by a floor, which slopes downward and tapers to smaller cross-section.

4) Contains any other recognized serious safety or health hazard.

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CONFINED SPACE ASSESSMENT FORM

Name of Evaluator ____________________________________________________

Work Area Assessed ____________________________________________________

Date of Assessment _ ___________________________________________________

Confined Space Determination

1. Area was not designed for continual worker occupancy YES [] NO [] 2. Area can be bodily entered and assigned work performed YES [] NO [] 3. Area has limited and/or restricted means of access and egress YES [] NO [] If you answered yes to all of the above you have met the criteria of a confined space, and must proceed to the next section. Permit-Required Confined Space Determination

1. The area contains or has the potential to contain a hazardous atmosphere YES [] NO [] 2. The area contains a material that has the potential to engulf an entrant (water, grain, sand,

etc.). YES [] NO [] 3. The area has an internal configuration, inwardly converging walls or a floor that slopes

downward and tapers to a smaller cross section. YES [] NO [] 4. The area contains any other recognized serious safety and health hazards (electrical,

thermal, mechanical, physical, chemical, etc.). YES [] NO [] If you answered yes to any one or more of the above you have met the criteria of a permit-required confined space. Permit-required spaces must be identified with the appropriate signs, and implement measures to prevent unauthorized entry (locks, bolts, etc.). If employee entry is required a confined space entry program and training program must be developed and implemented. Reclassification of Permit Required Confined Space A space classified by the employer as a permit-required confined space may be reclassified under the following procedures: 1. If the permit space poses no actual or potential atmospheric hazards and if all the hazards

within the space are eliminated without entry into the space, and the non-atmospheric hazards remain eliminated.

2. The employer shall document the basis for determining that all hazards in a permit space have been eliminated, through a certification date, the location of the space, and the signature of the person making the determination. The certification shall be made available to each employee entering the space or to that employee’s authorized representative.

3. If hazards arise within a permit space that has been declassified to a non-permit space, each person must immediately exit the space. The employer shall then reevaluate the space and determine whether it must be reclassified as a permit space.

Classification of Work Space [] Permit-required confined space []Non permit-required confined space (does not contain hazards capable of causing serious harm or death) [] Enclosed space

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APPENDIX B

CONFINED SPACE ENTRY PERMIT There is not a standard format for a Confined Space Entry Permit. It can be formatted using any method as long as the permit is legible to all exposed employees, can be posted at the confined space entrance, and contains all of the following information.

All Permit-Required Confined Space Permits shall list the following:

1) The permit space to be entered. 2) The purpose of entry. 3) Date and authorized duration of the permit. 4) Authorized entrants (by name). 5) Authorized entrants (by name). 6) Current entry supervisor (by name). With space for name or initials of original entry supervisor who

originally authorized entry. 7) Hazards of permit space to be entered. 8) Measures used to isolate permit space and eliminate or control hazards before entry. 9) Acceptable entry conditions (site specific). 10) Results of initial pre-entry testing and necessary periodic testing, accompanied by the names or

initials of the testers and date/time of the testing. (Note: When testing for atmospheric hazards, test first for oxygen, next for combustible vapors and gases, and then for toxic vapors or gases.)

11) The rescue plan to be used for this space. Verify that all required elements of the rescue plan are in place.

12) The procedures used to maintain communications between authorized entrants and attendants. 13) List of equipment required to maintain compliance. (Example: PPE, testing equipment,

communications equipment, alarm systems and rescue equipment) 14) Additional necessary information (site specific) that will ensure employee safety. 15) Any additional permits that have been issued to authorize work in the permit space. (Example: hot

work)

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Work Zone Traffic Control Introduction

The purpose of work zone traffic control is to provide a safe work area for workers within the roadway, while facilitating the safe and orderly flow of all road users (motorists, bicyclists and pedestrians including persons with disabilities in accordance with the Americans with Disabilities Act of 1990) through the work zone. This manual is intended to provide City Construction, Inc. employees, utility companies, municipalities, and contractors who are involved with the design, set-up and maintenance of highway work zones, or anyone working within the state right-of-way, with the basic principles and elements constituting a safe work zone. The information presented in this manual is based on the requirements set forth in the National Manual of Uniform Traffic Control Devices and the FHA-DOT, review of work zone manuals from a selection of state and federal agencies and American National Standards Institute (ANSI) ISEA 107-2004 - "High-Visibility Safety Apparel and Headwear". This manual includes basic information on work zone traffic control, including a description of traffic control devices, illustrations of acceptable, commonly used devices, and the proper flagger attire and methods. Color diagrams (typical applications) depicting typical traffic control set-ups for two-lane and multilane highways are intended to show the minimum requirements for a safe work zone set-up. Traffic control or protection can be enhanced for situations that may require additional measures such as high traffic or pedestrian volume, high speeds, restricted sight distance, poor or confusing alignment.

Work Area Duration Work duration is a major factor in determining the number and types of devices used in work zone traffic control areas. As a general rule, the longer the operation will last, the more traffic control devices are needed.

Mobile Work: Work that moves intermittently or continuously. Examples:

• Placing cones and/or signs for stationary work zones • Herbicide spraying • Sweeping operations • Paint striping operations • Placing traffic counters

Mobile work zones provide the lowest level of traffic control and safety and should only be used where the work at any specific location will be completed within 15 MINUTES. There may be cases where site specific conditions justify longer duration use of mobile work zones to minimize the exposure of traffic and the workers to each other. In such cases, an exception may be approved by responsible person(s) designated by the region after consideration of relevant factors such as speeds, sight distance, staging of the work, degree of obstruction to traffic, traffic volumes, and the relative severity and duration of exposure to workers and traffic.

Short Duration: Work that occupies a location for up to 1 hour. Examples:

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• Placing traffic counters Re-lamping traffic signals/ streetlights • Pothole repair • Minor guiderail repair • Sign Repair Due to the short work time

Careful consideration of traffic and roadway conditions must be given to each work zone prior to selecting the most appropriate traffic control set-up. Shoulder work and work on low speed, low volume roadways may only require a single warning sign, cones, and a flagger, while a high speed, high volume road would require a more detailed lane closure utilizing more safety control devices such as a barrier vehicle, signs, channelizing devices and a flashing arrow panel.

Short-Term Stationary: Daytime work that occupies a location for more than 1 hour within a single daylight period. Examples:

• Guiderail Repair • Bridge Inspection/Repair • Ditch Maintenance • Concrete Roadway Repair

Short term stationary work areas are typically occupied by materials, equipment and workers, but the work area is cleared at the end of the work day and normal traffic flow restored. Traffic control typically includes signs on portable supports, cones or drums forming a taper and separating the work space from traffic and flashing arrow boards or PVMS as needed. Buffer space or Barrier vehicles are required and impact attenuators are required on the barrier vehicles if prevailing speeds are 45 mph or greater. Traffic control is removed at the end of the work day.

Intermediate-Term Stationary: Work that occupies a location more than one daylight period up to 3 consecutive days, or night time work lasting more than 1 hour. Typically, the work area is occupied by excavations, materials, and/or equipment at times when workers are not present.

Long-Term Stationary: Work that occupies a location for more than 3 consecutive days. Typically, the work area is occupied by excavations, materials, and/or equipment at times when workers are not present.

Night work:

Extra care should be taken when scheduling work at night. Lighting of the work area and/or flagging stations is required. Appropriate devices include reflective signs, large channelizing devices, light dimming arrow panels and additional lights on work equipment.

Incident Management Situations: Examples:

• Traffic accident • Debris on the highway • Initial response to flooding • Emergency road and bridge repairs

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The immediate response to an emergency situation must be handled safely and make use of available devices and equipment available at that moment. Given the opportunity, however, longer-term (longer than 1 hour) emergencies should be treated in a matter similar to a work zone of other temporary traffic control work sites and proper traffic control should be established as soon as possible. Response to an emergency situation is inherently more dangerous than a planned situation. Carefully consider the personal safety risks against the public safety needs when selecting a response to the emergency. If the risks outweigh the public safety benefit, wait for assistance from police and other NYSDOT personnel and equipment.

Advance Warning Signs All work zone signing (ground or truck mounted) shall conform to the NMUTCD and NYS Supplement. Special conditions or emergencies may require additional signing. Refer to the MUTCD for guidance on the proper location, message, spacing, sequence, mounting height and size of signs used for traffic control. Materials Rigid and flexible “roll-up” signs may be used for mobile, short duration and short term stationary work. Rigid signs must be mounted at least 5 feet above grade (7 feet where there are pedestrians or parked cars) for visibility and to avoid windshield penetration if they are impacted. Flexible signs must be mounted at least one foot above grade. Mesh signs shall not be used. Use retro reflectorized rigid signs for night work because they present a flat, uniform reflective surface. Sign stands/posts must meet NCHRP 350 crash testing standards. Ex: Breakaway posts and hinges.. Installation All signs should face at approximately right angles to on-coming traffic and be as close to vertical as possible to avoid reflecting sun glare into the driver’s eye. In mobile and short duration work zones, signs may be mounted on vehicles. Orange flags can be mounted on warning signs to enhance their visibility. Credibility Signs shall be maintained, clean and with the legend fully intact. They shall remain in place only when needed. Signs which do not reflect actual conditions promote driver disobedience of all signs and therefore should be covered, removed or turned away so they are not visible to traffic in any travel lane. Sign covers must be opaque, and cover the sign face completely. Partially visible signs may divert attention away from traffic and other devices. If unneeded signs are to be stored at roadside, try to store them out of the clear zone or as far from traffic as practical. If stored close to traffic, lay the signs flat and fold up the legs of the sign supports. Where operations are performed in stages, only use those devices that apply to the conditions present during the stage in progress. Signs set up over a long distance should be periodically checked.

Guidance for Proper Signing

• Install one or more work zone warning signs whenever the work results in a changed condition which may require a higher level of driver caution. One sign (usually “Road Work Ahead”) may be adequate for minor changes such as removed guide rail, removed edge line or roadside work which does not

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encroach on the shoulder or travel lane. Use “Road Work Ahead” as the first sign in a warning sign series on minor side roads where distance information is not necessary. Use more signs as the impact on traffic increases. For work which obstructs traffic, a 3 sign series is typical. The first sign is a general warning sign to get the motorist’s attention. The second sign warns of the specific condition and the third sign advises the driver of any action to be taken.

• General warning signs such as “Road Work XX Ft” should be limited to the first sign of a series.

Subsequent warning signs in that series should identify specific conditions. Use signs shown in the MUTCD/WZTCM for lane and shoulder closure, alignment and intersection signs, flagger and worker symbol signs, road closed, detour, etc.

• Location of advance warning signs should consider exiting and entering traffic. Advance posting

distances indicated in the MUTCD and WZTCM are starting points and should be adjusted as appropriate for site specific conditions. Avoid starting a warning sign series upstream from a major exit or intersection, except when it is desirable to divert traffic off the route at that point or where the intersection is within 1000 feet of the work site.

• Where single advance warning signs are provided on ramps or minor intersecting roads, the “Ahead”

wording rather than a specific distance is preferred because it is easier to adapt to site conditions and reduces sign inventory needs.

• Warning signs must be located to provide adequate visibility distance to drivers; not blocked by foliage,

roadway features, or other signs and traffic control devices; and not located where glare from light sources behind the sign may reduce visibility. Actual distance from a warning sign to the condition should be close to the stated distance on the sign, but accuracy should not be at the expense of sign visibility.

• Signs must be adequately spaced to provide time for the driver to read each one. Sign spacing varies

with the type of highway and the prevailing speeds and is specified in the MUTCD and WZTCM. See Advance Warning Sign Spacing Table on the next page for details. •

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Traffic Controllers (Flagger) Flagger A flagger may be necessary to alert traffic, or to stop traffic intermittently, as required by the progress of work in a work zone. The flagging operation provides protection for other workers and the public. A flagger should be alert, neat appearing and act responsibly. The flagger’s only job is work zone protection and traffic control. The flagger must never assist the crew with work activities, or engage in any distraction, and must remain on duty until properly relieved. Use stop-slow paddles, where feasible. Flags may be used at intersections or where the back-side message is inappropriate for opposing traffic and where conditions such as high wind make the use of a paddle impractical. Flaggers should be used in the following situations:

• One lane is alternately used for both directions of traffic. • The roadway is closed for a brief period of time. • Traffic speeds need to be substantially reduced. • Inadequate sight distance hinders advance warning. • Information, such as changing conditions, needs to be conveyed to motorists. • Opposing traffic needs to be controlled at an intersection. • Installing and removing other traffic control devices. • Where conditions require unusual precautions.

General No employee is to be utilized as a flagger until the employee has shown conclusively to their Supervisor that they realize fully the importance of the job, and understands the duties and responsibilities associated with it. Flaggers must:

• Always face oncoming traffic. • Never leave their position until relieved. • Know where crew members and equipment are, be aware of changes, and never stand among workers

and equipment. • Be courteous, yet authoritative. • Minimize conversations with motorist and pedestrians. • Be positioned to compensate for limited sight distance, to provide maximum advance warning, and remain

clearly visible to traffic at all times. • Maintain continuous communication with any other flaggers. • Try to maintain color contrast with background; consider sun glare on motorist. • Establish eye contact with drivers to whom they must give direction.

A flagger’s activities bring them into continuous contact with the public. As they are the ones the public sees in most cases, it is important that the flaggers conduct themselves in a manner which will bring credit both to themselves and the Company. Courtesy should be exercised at all times. Even under trying conditions, a flagger should be courteous, though firm.

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The flagger’s supervisor shall determine when flaggers are to be used, how many are needed, where they are to be stationed for a specific operation, and the methods of communication between multiple flaggers. Traffic controllers must use the following equipment and personal protective gear:

• Hard hat. • High Visibility Apparel (Vest, T-Shirt or 3 Season Jacket):

o Must meet approved ANSI/ISEA 107-2004, Performance Class II standards. • 24 inch stop/slow paddle, Red flag (24in by 24in).

o The paddle is the preferred device but the flag may be used at intersections where the stop/slow paddle would offer contradicting information to drivers traveling in opposite directions/legs of the intersection or during emergency situations.

• A red wand flashlight, if working at night, and portable lighting is unavailable.

Traffic Observers (Spotters) A spotter is a person with the same qualifications of the flagger. A spotter may be required to warn workers of errant vehicles, danger from traffic, or to assist drivers of work vehicles in entering or leaving work sites or in performing U-turns.

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Taper Length Criteria for Work Zones

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CONSTRUCTION WASTE MANAGEMENT PART 1 – GENERAL 1.1 SUMMARY A. Section includes: Administrative and procedural requirements for construction waste management activities. B. Related section Demolition and Salvage 1.2 DEFINITIONS A. Construction, Demolition, and Land clearing (CDL) Waste: Includes all non-hazardous solid wastes resulting from construction, remodeling, alterations, repair, demolition and land clearing. Includes material that is recycled, reused, salvaged or disposed as garbage. B. Salvage: Recovery of materials for on-site reuse, or offsite sale or donation to a third party. C. Reuse: Making use of a material without altering its form. Materials can be reused on-site or reused on other projects off-site. Examples include, but are not limited to the following: Grinding of concrete for use as subbase material. Chipping of land clearing debris for use as mulch. D. Recycling: The process of sorting, cleaning, treating, and reconstituting materials for the purpose of using the material in the manufacture of a new product. E. Source-Separated CDL Recycling: The process of separating recyclable materials in separate containers as they are generated on the job-site. The separated materials are hauled directly to a recycling facility or transfer station. F. Co-mingled CDL Recycling: The process of collecting mixed recyclable materials in one container on-site. The container is taken to a material recovery facility where materials are separated for recycling. G. Approved Recycling Facility: Any of the following:

• A facility that can legally accept CDL waste materials for the purpose of processing the materials into an altered form for the manufacture of a new product.

• Material Recovery Facility: A general term used to describe a waste-sorting facility. Mechanical, hand-separation, or a combination of both procedures, are used to recover recyclable materials. Co-mingled containers are to be taken to a material recovery facility with at least a 50% co-mingled recycling rate.

1.3 SUBMITTALS A. Waste Management Plan: Submit plan within seven days of date established for the Notice to Proceed. B. Waste Management Report: Submit report concurrent with the final Application for Payment. 1.4 PERFORMANCE REQUIREMENTS A. General: Material from demolition projects shall be recycled or reused whenever practicable. Divert a minimum of 50% CDL waste, by weight, from the landfill by one, or a combination of the following activities:

• Salvage • Reuse • Source-Separated CDL Recycling • Co-mingled CDL Recycling

B. CDL waste materials that can be salvaged, reused or recycled include, but are not limited to, the following: • Asphalt • Asphalt shingles • Concrete • Metals • Window glass • Wood • Field office waste, including office paper, aluminum cans, glass, plastic, and office cardboard.

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1.5 QUALITY ASSURANCE A. Regulatory Requirements: Conduct construction waste management activities in accordance with State of Pennsylvania Dept. of Environmental Protection and all other applicable laws and ordinances. B. Preconstruction Conference: Review methods and procedures related to waste management including, but not limited to, the following:

• Review and discuss waste management plan including responsibilities of Waste Management Coordinator. • Review requirements for documenting quantities of each type of materials that will be salvaged, recycled or

disposed of as waste. • Review and finalize procedures for materials separation and verify availability of containers and bins

needed to avoid delays. • Review procedures for periodic waste collection and transportation to recycling and disposal facilities. • Review waste management requirements for each trade.

1.3 WASTE MANAGEMENT PLAN A. General: Develop plan consisting of waste types, quantity by weight, methods of disposal, handling and transportation procedures. Include separate sections in plan for demolition and construction waste. B. Organize the waste management plan in accordance with the sample plan included at end of this program, including the following information: 1. Types and estimated quantities, by weight, of CDL waste expected to be generated during demolition and construction. 2. Proposed methods for CDL waste salvage, reuse, recycling and disposal during demolition including, but not limited to, one or more of the following:

• Contracting with a deconstruction specialist to salvage materials generated. • Selective salvage as part of demolition contractor’s work. • Reuse of materials on-site or off-site sale or donation to a third party.

3. Proposed methods for salvage, reuse, recycling and disposal during construction including, but not limited to, one or more of the following:

• Requiring subcontractors to take their CDL waste to a recycling facility, • Contracting with a recycling hauler to haul recyclable CDL waste to an approved recycling or material

recovery facility. • Processing and reusing materials on-site. • Self-hauling to a recycling or material recovery facility.

4. Name of recycling or material recovery facility receiving each of thecal wastes. 5. Handling and Transportation Procedures: Include method that will be used for separating recyclable waste including sizes of containers, container labeling, and designated location on project site where materials separation will be located. 1.4 WASTE MANAGEMENT REPORT A. Waste Management Report: Submit a cumulative waste management report on the form included at end of this Program with the final Application for Payment with the following attachments:

• A record of the type and quantity, by weight, of each material salvaged, reused, recycled or disposed. • Total quantity of waste recycled as a percentage of total waste. • Disposal Receipts: Copy of receipts issued by a disposal facility for CDL waste that is disposed in a landfill. • Recycling Receipts: Copy of receipts issued by approved recycling facilities for co-mingled materials.

Include weight tickets from the recycling hauler or material recovery facility and verification of the recycling rate for co-mingled loads at the facility.

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• Salvaged Materials Documentation: Types and quantities, by weight, for materials salvaged for reuse on site, sold or donated to a third party.

PART 2 - PRODUCTS (Not Used) PART 3 - EXECUTION 3.1 CONSTRUCTION WASTE MANAGEMENT, GENERAL A. Provide containers for CDL waste that is to be recycled clearly labeled as such with a list of acceptable and unacceptable materials. The list of acceptable materials must be the same as the materials recycled at the receiving material recovery facility or recycling processor. B. The collection containers for recyclable CDL waste must contain no more than 10% non-recyclable material, by volume. C. Provide containers for CDL waste that is disposed in a landfill clearly labeled as such. D. Use detailed material estimates to reduce risk of unplanned and potentially wasteful cuts. E. To the greatest extent possible, include in material purchasing agreements waste reduction provision requesting that materials and equipment be delivered in packaging made of recyclable material, that they reduce the amount of packaging, that packaging be taken back for reuse or recycling, and to take back all unused product. Insure that subcontractors require the same provisions in their purchase agreements. F. Conduct regular visual inspections of dumpsters and recycling bins to remove contaminants. 3.2 SOURCE SEPARATION A. General:

• Separate recyclable materials from CDL waste to the maximum extent possible. • Separate recyclable materials by type. • Provide containers, clearly labeled, by type of separated materials or provide other storage method for

managing recyclable materials until they are removed from Project site. • Stockpile processed materials on-site without intermixing with other materials. Place, grade, and shape

stockpiles to drain surface water. Cover to prevent windblown dust. • Stockpile materials away from demolition area. Do not store within drip line of remaining trees. • Store components off the ground and protect from weather.

3.3 CO-MINGLED RECYCLING A. General: Do not put CDL waste that will be disposed in a landfill into a co-mingled CDL waste recycling container. 3.4 REMOVAL OF CONSTRUCTION WASTE MATERIALS A. Remove CDL waste materials from project site on a regular basis. Do not allow CDL waste to accumulate on-site. B. Transport CDL waste materials off Owner's property and legally dispose of them. C. Burning of CDL waste is not permitted.

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SAMPLE WASTE MANAGEMENT PLAN Company: City Construction. Figure 1.

Project: Concrete install, Newark, NJ Designated Recycling Coordinator: John Doe Waste Management Goals: This project will recycle or salvage for reuse xx% [e.g. 75%] by weight of the waste generated on-site. Communication Plan:

• Waste prevention and recycling activities will be discussed at the beginning of each safety meeting. • As each new subcontractor comes on-site, the recycling coordinator will present him/her with a copy of the

Waste Management Plan and provide a tour of the recycling areas. • The subcontractor will be expected to make sure all their crews comply with the Waste Management Plan. • All recycling containers will be clearly labeled. • Lists of acceptable/unacceptable materials will be posted throughout the site.

Expected Project Waste, Disposal, and Handling: The following charts identify waste materials expected on this project, their disposal method, and handling procedures. Demolition Phase Material Quantity, Disposal Method, Handling Procedure Asphalt from parking lot 100 tons Ground on-site, reused as fill Wood supports 6 tons Recycled - Construction Demolition Recycling, Inc. Separate "clean wood" in clean woodbin Remaining Materials 8 tons Landfill - Sound Disposal Dispose in "trash" dumpster WASTE MANAGEMENT PROGRESS REPORT DISPOSED IN MUNICIPAL SOLID WASTE LANDFILL DIVERTED FROM LANDFILL BY RECYCLING, SALVAGE OR REUSE MATERIAL CATEGORY Recycled Salvaged Reused 1. Asphalt (cu yds.) 2. Concrete (cu yds.) 3. Ferrous Metals (lbs.) 4. Non-Ferrous Metals (lbs.) 5. Wood (lbs.) 6. Clay Brick (lbs.) 7. Bond Paper (lbs.) 8. Newsprint (lbs.) 9. Cardboard (lbs.) 10. Plastic (lbs.) 11. Gypsum (lbs.) Total (In Weight) (TOTAL OF ALL ABOVE VALUES – IN WEIGHT) Percentage of Waste Diverted (TOTAL WASTE DIVIDED BY TOTAL DIVERTED)

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Gas Hazard Awareness Purpose It is the intention of City Construction, Inc. (CCC) to provide gas hazards training and detection equipment that meets or exceeds all federal standards. This program is associated with our Respiratory Protection Program. Scope This program is for selected CCC projects and operations. This program supplements the Respiratory Protection Program that is in place in accordance with 29CFR 1910.134. Procedure Gas Hazards Equipment

- Each employee or team shall use a portable gas monitor as required in all high gas or potentially high hazard areas.

- The gas monitor must be calibrated prior to use per manufacturer's recommendations and contain a current calibration sticker on the monitor providing the date of last calibration.

- Bump test are required to be completed at the beginning of each day the monitor is in use per the requesting Owner Client and manufacturer's guidelines to insure the monitor is functioning correctly.

- Owner Client Contingency Plans Awareness - CCC shall insure all employees are aware of the Owner Client’s contingency plan provisions including

evacuation routes and alarms. CCC employees shall participate in emergency evacuation drills and practice rescue procedures.

- Use, Maintenance and Care of Gas Monitors - Only utilize monitors issued by either CCC or made available by the Owner Client - no personally owned

monitors are allowed. - Have the gas monitor on the outside of all clothing. - Check the calibration date prior to bump testing. If the calibration date is expired turn the unit in

immediately to a safety team member for calibration. - Bump test each shift prior to using the monitor. - Monitors are sensitive equipment - avoid physical damage and immediately report any monitor that does

not appear to be performing as expected.

Training All affected employees will receive gas hazards awareness training before their initial assignment and annually thereafter. This shall be in conjunction with the CCC Respiratory Protection training. Training shall address, as a minimum:

- Locations of alarm stations - Gas Monitoring Equipment- Portable and Fixed Detection - Gas Alarms - Gas Hazards - Characteristics of gases, to include oxygen deficiency, oxygen or nitrogen enrichment,

carbon monoxide and hydrogen sulfide

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- Any plant or department specific gases of concern - Signs and symptoms of overexposure - Personnel Rescue Procedures - Use and care of Self-Contained Breathing Apparatus (SCBA) - includes donning and emergency

procedures (if applicable) - Evacuation Procedures - Staging Areas – Primary and Secondary

Gas Hazard Awareness training shall be documented and available for review. In Plant Rail Safety Purpose City Construction, Inc. is required to participate as a contract employer at client locations with railroads or tracks. City Construction, Inc. has no facilities with railroads or tracks however has a duty to ensure its employees and contractors are aware of the hazards and controls associated with working on or near rails or tracks at a client’s Facility. Key Responsibilities Management shall determine if this program is required for regulatory compliance within his/her region. If this program is deemed necessary, then management shall determine which employees within his/her region is required to receive this training. Management shall select a training facility or use an in-house qualified trainer to supply the training. Only trained personnel can be involved in working on or near rails or tracks at a client facility. Procedures Obtain Permission to Work In Advance Prior to performing work within six (6) feet of any railroad track, permission must be obtained from the owner client railroad supervisor or designated person to take the track out of service. If required, complete a client work permit prior to beginning work. Safety Equipment Approved hard hats, high visibility clothing, approved metatarsal boots, gloves and approved safety glasses with permanently attached side shields shall be worn in designated areas associated with rails. Protection of Workers from Moving Equipment Never attempt to crawl under rail equipment or climb over moving rail equipment or attempt to cross in front of moving equipment. Never position any part of the body in a potential pinch point. Rail equipment can move in either direction at any time with no warning,

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Railroad Crossing Safety In all cases pedestrians / employees shall cross at existing designated pedestrian rail crossings where provided. Additionally, vehicle crossings are not intended as pedestrian crossings unless they are so identified and/or located, and no other pedestrian crossings exist in the area. If a designated rail crossing is not available the following general safety procedures for crossing railroad tracks shall be followed:

- Do not cross within 10 feet of the end of a parked rail car. - Do not cross between uncoupled cars - Stop, look and listen prior to proceeding across the tracks - Never step on rails, as they may be slippery.

Training Appropriate training based on complexity of the job and potential hazards related to in plant rail hazards shall be provided to all applicable employees. Assessments shall be used to determine whether the employees have the knowledge and have demonstrated skills to safely perform their work assignments. All training shall be conducted and documented in advance of working on or near in plant rails. Retraining and testing shall be required for unsatisfactory/unsafe performance of job assignments Mobile Equipment Purpose This program is written to be in compliance with local regulatory requirements and provide directives to managers, supervisors, and employees about their responsibilities in the operations and management of City Construction, Inc. mobile equipment. Key Responsibilities RSO - The designated Safety Manager is responsible for developing and maintaining the program and related procedures. These procedures are kept in the designated safety manager’s office. Project Superintendent - Responsible for the implementation and maintenance of the program for their site and ensuring all assets are made available for compliance with the plan. Employees - All shall be familiar with this procedure and the local workplace vehicle safety program. Follow all requirements, report unsafe conditions, and follow all posted requirements. Mobile Equipment The following requirements may be applicable on selected City Construction, Inc. projects City Construction, Inc. must develop and implement safe work procedures for the use of powered mobile equipment in the workplace and must train workers in those safe work procedures. The equipment operator of mobile equipment shall be directly responsible for the safe operation of that equipment and shall comply with all laws and regulations governing the operation of the equipment. Maintenance records for any service, repair or modification which affects the safe performance of the equipment must be maintained and be reasonably available to the operator and maintenance personnel during work hours.

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All mobile equipment shall be maintained in safe operating condition and operation, inspection, repair, maintenance and modification shall be carried out in accordance with manufacturer's instructions or, in the absence of the instructions, in accordance with good engineering practice. Servicing, maintenance and repair of mobile equipment shall be done when the equipment is not in operation, except that equipment in operation may be serviced if the continued operation is essential to the process and a safe means is provided. Only authorized employees shall be allowed to operate mobile equipment. Authorization to operate mobile equipment will be issued to employees qualifying under appropriate training and proficiency testing. The person must also have in possession of an applicable operator's license and an airbrake certificate where required and be familiar with the operating instructions pertaining to the equipment and be authorized to operate the equipment. Authorization will be issued on after these requirements are met. A supervisor must not knowingly operate or permit a worker to operate mobile equipment which is, or could create, an undue hazard to the health or safety of any person or is in violation of any local or federal regulations. Mobile equipment in which the operator cannot directly or by mirror or other effective device see immediately behind the machine must have an automatic audible warning device which activates whenever the equipment controls are positioned to move the equipment in reverse, and if practicable, is audible above the ambient noise level. Unauthorized personnel shall not be permitted to ride on equipment unless it is equipped to accommodate riders safely. At the beginning of each shift, the operator shall inspect and check the assigned equipment, reporting immediately to his/her supervisor any malfunction of the clutch or of the braking system, steering, lighting, or control system and locking/tagging out the equipment if necessary. The operator shall immediately report defects and conditions affecting or likely to affect the safe operation of the equipment to his or her immediate supervisor or other authorized person and confirm this by a written report as soon as possible. If an inspection of powered mobile equipment identifies a defect or unsafe condition that is hazardous or may create a risk to the safety or health of a worker City Construction, Inc. must ensure that the powered mobile equipment is not operated until the defect is adjusted, repaired or the unsafe condition is corrected. The operator of mobile equipment must not leave the controls unattended unless the equipment has been secured against inadvertent movement such as by setting the parking brake, placing the transmission in the manufacturer's specified park position and by chocking wheels where necessary. No operator shall leave unattended a suspended load, machine or part or extension of it unless it has been immobilized and secured against inadvertent movement. Powered equipment shall not be left unattended unless forks, buckets, blades and similar parts are in the lowered position or solidly supported. Before a worker starts any powered mobile equipment City Construction, Inc. shall ensure that the worker makes a complete 360 degree visual inspection of the equipment and the surrounding area to ensure that no worker, including the operator, is endangered by the startup of the equipment. No worker shall start any powered mobile equipment until the inspection is completed.

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All powered mobile equipment is inspected by a competent person for defects and unsafe conditions as often as is necessary to ensure that it is capable of safe operation. A written record of the inspections, repairs and maintenance carried out on the powered mobile equipment is kept at the workplace and made readily available to the operator of the equipment. As soon as is reasonably practicable the defect must be repaired or the unsafe condition is corrected. All mobile equipment shall be equipped with a working signal alarm for backing up. The operator shall make sure the warning signal is operating when the equipment is backing up. The operator shall use access provided to get on or off of equipment. Do not jump to the ground. No operator shall operate mobile equipment without the protection of an enclosed cab or approved eye protection for the type of hazards to the eye. Where there is a danger to the operator of a unit of powered mobile equipment or any other worker who is required or permitted to be in or on a unit of powered mobile equipment from a falling object or projectile City Construction, Inc. requires that the powered mobile equipment is equipped with a suitable and adequate cab, screen or guard. Every forklift will be equipped with a seat belt for the operator if the forklift is equipped with a seat and the operator of a forklift is required to use the seat-belt. Before starting the engine, the driver shall fasten seat belts and adjust them for a proper fit. Each mobile equipment vehicle used for lifting must be provided with a durable and clearly legible load rating chart that is readily available to the operator. The operator shall not load the vehicle/equipment beyond its established load limit and shall not move loads which because of the length, width, or height that have not been centered and secured for safe transportation. Mobile equipment used for lifting or hoisting or similar operations shall have a permanently affixed notation stating the safe working load capacity of the equipment and the notation must be kept legible and clearly visible to the operator. The operator shall not use, or attempt to use any vehicle in any manner or for any purpose other than for which it is designated. The operator's manual for powered mobile equipment must be readily available to a worker who operates the equipment. An employer must ensure that a competent person services, inspects, disassembles and reassembles a tire or tire and wheel assembly of powered mobile equipment in accordance with the specifications of both the tire manufacturer and the manufacturer of the powered mobile equipment. All mobile equipment must be equipped with (a) an audible warning signal; (b) a means of illuminating the path of travel at any time and tail lights when, because of insufficient light or unfavorable atmospheric conditions, (c) adequate illumination of the cab and instruments; and (d) a mirror providing the operator with an undistorted reflected view to the rear of the mobile equipment. Adequate and approved fire suppression equipment shall be provided on mobile equipment. The operator of a gasoline or diesel vehicle shall shut off the engine before filling the fuel tank and shall see that the nozzle of the filling hose makes contact with the filling neck of the tank. No one shall be on the vehicle during

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fueling operations except as specifically required by design. There shall be no smoking or open flames in the immediate area during fueling operation. When a worker is required to work beneath elevated parts of mobile equipment including trucks, the elevated parts shall be securely blocked. Materials and equipment being transported shall be loaded and secured in a manner to prevent movement which could create a hazard to workers or another person. This includes keeping the cab, floor and deck of mobile equipment free of material, tools or other objects which could create a tripping hazard, interfere with the operation of controls or be a hazard to the operator or other occupants in the event of an accident. Where the operator of a vehicle, mobile equipment, crane or similar material handling equipment does not have a full view of the intended path of travel of the vehicle, mobile equipment, crane or similar material handling equipment or its load, the vehicle, mobile equipment, crane or similar material handling equipment shall only be operated as directed by a signaler who is a competent person. The signaler shall be stationed, in full view of the operator and with a full view of the intended path of travel of the vehicle, mobile equipment, crane or similar material handling equipment and its load; and clear of the intended path of travel of the vehicle, mobile equipment, crane or similar material handling equipment and its load. Where a vehicle, crane or similar equipment is operated near a live power line carrying electricity at more than 750 volts, every part of the equipment shall be kept at least the minimum distance from the live power line for the particular voltage as required by local or federal law. Under no circumstance will a worker be directed, required or permitted to work under or remain in the range of a swinging load or part of unit of powered mobile equipment due to the inherent danger.

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PROCESS SAFETY MANAEMENT 1.1 Purpose The purpose of Process Safety Management (PSM) is to prevent or minimize consequences of catastrophic releases of toxic, reactive, flammable or explosive chemicals in various industries such as refineries. The requirements of a Process Safety Management Program are outlined in 29 CFR 1910.119. City Construction employees will perform work at job sites that are covered by this standard. Therefore, the purpose of this written program is to ensure our employees are trained in the practices necessary to conduct their work at PSM covered work sites and to ensure they abide by the safe work practices of the employers that hire us to perform various jobs. 1.2 Objectives Contractors under the Process Safety Management program are those who are involved in the installation or maintenance of equipment and systems at a facility that has one of the following: 1. A process which involves a chemical at or above the specified threshold quantities listed in the OSHA standard. 2. A process which involves a flammable liquid or gas (as defined in 1910.1200) on site in one location, in a quantity of 10,000 pounds (4535.9 kg) or more except for: a. Hydrocarbon fuels used solely for workplace consumption as a fuel (e.g., propane used for comfort heating, gasoline for vehicle refueling), if such fuels are not a part of a process containing another highly hazardous chemical covered by this standard; b. Flammable liquids stored in atmospheric tanks or transferred which are kept below their normal boiling point without benefit of chilling or refrigeration. As contractors covered under the PSM Program, we will be provided necessary information conceming the hazardous process, equipment, and procedures of the particular job site our employees are working at. 1.3 Specific Requirements Prior to allowing City Construction employees to commence work in a process covered under PSM, the following requirements must be completed by the PSM Companv we will be doing work for: I. Obtain and evaluate information regarding City Construction's safety performance and programs (written documentation required). 2. Inform City Construction Area Supervisor or other designated City Construction employee of the known potential fire, explosion, or toxic release hazards related to the work area and processes of the Company. 3. Explain the applicable provisions of the emergency action plan to City Construction employees. Page 441 City Construction Co., inc. -IiPPiSafety iVianuai ADDENDUM 5: Process safety ivianagement 4. Provide the Area Supervisor with copies of local safety programs, safety and emergency procedures and a copy of the PSM program. 5. Complete all the requirements of the Company's Contractors Liability Agreement. 6. Inform City Construction that a periodic performance evaluation will be conducted to ensure our employees are fulfilling our obligations. 7. Inform City Construction that a contract employee injury and illness log related to our work in process areas must be maintained on site for the duration of the contract work. City Construction will provide information to the Contract Employer relating to any unique hazards presented by our employee's work or any hazards found by our employees. Section 2. ReguiationslReferences 2.1 Regulations

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The various lines of defense that have been incorporated into the design and operation of the process to prevent or mitigate the release of hazardous chemicals need to be evaluated and strengthened to ensure their effectiveness at each level. Process safety management is the proactive identification, evaluation and mitigation or prevention of chemical releases that could occur as a result of failures in processes, procedures, or equipment. The process safety management standard targets highly hazardous chemicals that have the potential to cause a catastrophic incident. The purpose of the standard as a whole is to aid employers in their efforts to prevent or mitigate episodic chemical releases that could lead to a catastrophe in the workplace and possibly in the surrounding community. To control these types of hazards, employers need to develop the necessary expeliise, experience, judgment, and initiative within their work force to properly implement and maintain an effective process safety management program as envisioned in the Occupational Safety and Health Administration (OSHA) standard. The OSHA standard is required by the Clean Air Act Amendments, as is the Environmental Protection Agency's Risk Management Plan. Section 3. RcsponsibilitieslResources Employed 3.1 Safetv/Health Manager: The SafetyIHealth manager serves as the first contact for issues concerning the Process Safety Management Program. The Safety/Health Manager can use qualified trainers to aid in training employees. The Safety/Health manager is responsible for establishing a written Process Safety Management program. The Safety/Health manager will provide the following documentation to each PSM covered facility that we will be perfOlming work at: Page 442 City Construction Co., inc. - iiPPiSafety Manuai ADDENDUM 5: Process safety ivianagement I. Our safety program information and other documentation required by the Company's Contractors Liability and Safety Agreement. 2. Certification that we have informed our employees of potential fire, explosion, or toxic release hazards that may exist at or near their work area at the facility, and that we have explained the Company's Emergency Action Plan to our employees. Material Safety Data Sheets will be used to discuss process safety information for the particular site we will be working at. 3. Training documentation concerning training provided to our employees to ensure they understand the safe work practices necessary to safely perform tasks. 4. Certification that we have explained the Hot Works Permit Program of the Company we are working for and other permits the Company uses that will be needed during their time on company property. 5. Agreement to advise the Company we are working for of any unique hazards presented by our work and found during our work. 6. Certification that materials, parts and equipment to be installed meet industry and engineering standards for the application used. 3.2 Area Supervisors: The area supervisor will be responsible for the following: I. Identifying that each employee is trained in the work practices necessary to safely perform his or her job. 2. Ensuring that each employee has received and understood the required training. 3.3 Training: An annual training program for each employee included in the Process Safety Management Program will be conducted by SafetylHealth manager or qualified trainer and will assure that employees have been instructed in known potential fire, explosion, or toxic release hazards

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related to his/herjob. Training will be documented and will consist of the employee's name, the date of training, and the means used to verify that the employee understood the training. Information provided in the training program shall be updated to be consistent with changes in protective equipment and work processes. 3.5 Safe Work Practices: 1. City Construction employees will be required to abide by PSM employer's safe work practices during operations such as lockoutltagout, confined space entry, opening process equipment or piping, and controls over entrance to the facility. Page 443 City Construction Co., inc. - iiPPiSafety iVianuai ADDENDUM 5: Process safety Management 2. Safe work practices will be covered during site-specitic training courses. 3. Training will be documented with form#1. 3.6 Hot Work Before cutting or welding is permitted at a work site, the area must be inspected by the individual responsible for authorizing cutting and welding operations at the Company we are perfOlming work for. City Construction employees will not be allowed to perform hot work until a hot work permit is obtained from the employer's designated representative. The permit shall document that provisions ofCFR 1910.252 (a) have been met. 3.7 Incident Investigations: Employees must immediately report all accidents, injuries and near misses to their Area Supervisor, who will then notify the correct Company individuals. An incident investigation must be initiated within 48 hours. Resolutions and corrective actions must be documented and maintained for five years. 3.8 Trade Secrets: City Construction employees must respect the confidentiality of trade secret information when any Process Safety Information is released to them. 3.9 Program Evaluation: At least annually, the Process Safety Management Program will be evaluated by Safety/Health manager. After the evaluation, the changes/revisions to the program deemed necessary will be made as soon as possible. Page 444 City Construction Co, inc. - iiPPiSafety iVianuai ADDENDUM 5: Process safety Management