Safety, Health And Environmental Manual Preferred Industrial Contractors, Inc.pdf

1 Preferred Industrial Contractors, Inc SAFETY, HEALTH AND ENVIRONMENTAL MANUAL Preferred Industrial Contractors, Inc PO Box 1047, Mont Belvieu, Texas 77580 Office 281 421 0474/Fax 281 421 0007 PIC Re[.]

Preferred Industrial Contractors, Inc

SAFETY, HEALTH

AND ENVIRONMENTAL

MANUAL

Preferred Industrial Contractors, Inc.

PO Box 1047, Mont Belvieu, Texas 77580

Office 281.421.0474/Fax 281.421.0007

PIC Rev 12/12/11

SAFETY, HEALTH &

ENVIRONMENTAL

PROCEDURES &

GUIDELINES MANUAL

PRINTED April REVISED December 12, 2011

PIC Rev 12/12/11

SAFETY, HEALTH AND ENVIRONMENTAL MANUAL

3 SAFETY, HEALTH AND EVIRONMENTAL OBJECTIVE 9

4 ORGANIZATION AND RESPONSIBILITIES 11

6 SAFETY ORIENTATION, EDUCATION AND TRAINING 53

8 SAFE PROGRAM AND JOB SAFETY ANALYSIS 227

9 INCIDENT INVESTIGATION PROCEDURES 234

10 GENERAL SAFETY, HEALTH AND ENVIRONMENTAL RULES 256

18 MATERIAL HANDLING, STORAGE AND USE 331

19 FLAMMABLE AND COMBUSTIBLE LIQUIDS 337

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SECTION

PREFERRED INDUSTRIAL CONTRACTORS

25 ELECTRICAL, LIGHTING AND HEATING 429

27 TEMPORARY FLOORS, STAIRS, RAILINGS AND TOEBOARDS 451

28 MECHANICAL, VEHICLES, MOBILE EQUIPMENT AND CRANES 458

.A APPENDIX – CRANE INSPECTION, MAINTENANCE, AND OPERATION MANUAL

.1 AERIAL LIFTS (BOOM AND SCISSOR LIFTS) 478

.1 RESERVED – (COMMON OCCUPATIONAL HEALTH HAZARDS)

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SECTION

PREFERRED INDUSTRIAL CONTRACTORS

.3 CONFINED SPACE PROCEDURES 734 4 RESPIRATORY PROTECTION PROGRAM 777 5 BLOODBORNE PATHOGENS PROCEDURE 819

.6 RESERVED – (ERGONOMICS PROCEDURE)

.7 HEARING CONSERVATION PROGRAM 827

MAINTENANCE AND CALIBRATION)

36 GENERAL EXPOSURE CONTROL PLAN FOR BENZENE 870

37 HYDROGEN SULFIDE (H2s) REQUIREMENTS 877

38 NATURALLY OCCURRING RADIOACTIVE MATERIAL (NORM) 881

40 GENERAL EXPOSURE CONTROL PLAN FOR HEXAVALENT CHROMIUM 886

41 HAZARDOUS WASTE OPERATIONS (HAZWOPER) 897

42 GENERAL EXPOSURE CONTROL PLAN FOR CADMIUM 964

43 HOT WORK ON CONTAINERS AND PIPING SYSTEMS 976

46 LINE BREAKING/BLINDING AND EQUIPMENT OPENING PROCEDURES 994

48 INDEX OF SAFETY FORMS/HANDOUTS & MISC FORMS 1005

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PREFERRED INDUSTRIAL CONTRACTORS, INC

COMPANY STATEMENT

THIS MANUAL IS PROVIDED FOR THE USE OF THE MANAGEMENT AND EMPLOYEES OF

PREFERRED INDUSTRIAL CONTRACTORS, INC AND ANY OF ITS OFFICES, DIVISIONS, SUB‐

DIVISIONS, PROJECTS, AND SPONSORED JOIN VENTURES ONLY IT IS NOT INTENDED FOR THE

USE OF ANYONE OR ANY ENTITY OUTSIDE OF PREFERRED INDUSTRIAL CONTRACTORS, INC.’S

OPERATIONS PREFERRED INDUSTRIAL CONTRACTORS, INC DOES NOT ASSUME NOR ACCEPT

ANY LIABILITY OR RESPONSIBILITY FOR ANY USE OF THIS MANUAL OR ITS MATERIAL BY

ANYONE OUTSIDE THIS SPHERE OF INFLUENCE

PIC Rev 12/12/11

PREFERRED INDUSTRIAL CONTRACTORS, INC

POLICY STATEMENT

EMPLOYEES ARE OUR MOST IMPORTANT ASSET; THEIR SAFETY IS OUR GREATEST

RESPONSIBILITY IT IS THE RESPONSIBILITY OF THE COMPANY TO MAKE EVERY

EFFORT TO PROVIDE A SAFE WORKING ENVIRONMENT, TO ELIMINATE SAFETY

HAZARDS AND TO PROVIDE ADEQUATE PPE AND SAFETY DEVICES FOR ALL OF

OUR EMPLOYEES FURTHER, IT IS OUR GOAL TO CREATE A CULTURE OF SAFETY

AWARENESS AMOUG OUR MANAGEMENT AND EMPLOYEES SO THAT EACH

INDIVIDUAL UNDERSTANDS THAT HE / SHE HAS THE ULTIMATE RESPONSIBILITY

TO WORK SAFELY UNSAFE WORK PRACTICES BY AN INDIVIDUAL CAN OFTEN LEAD

TO ACCIDENTS EVEN IN A SAFE WORKING ENVIRONMENT IT IS OUR GOAL TO

ELIMINATE BOTH UNSAFE WORK CONDITIONS AND UNSAFE WORK PRACTICES

IT IS OUR RESPONSIBILITY TO:

1 COMPLY WITH ALL FEDERAL, STATE, LOCAL REGULATIONS AND CLIENT

RULES GOVERNING SAFETY ON OUR PROJECTS

2 TAKE EXPEDIENT ACTION TO CORRECT UNSAFE CONDITIONS AND

WORK PRACTICES

3 PROMOTE SAFETY AWARENESS

4 HOLD EACH MANAGEMENT PERSONNEL AND EMPLOYEE ACCOUNTABLE

FOR HIS/ HER INDIVIDUAL RESPONSIBILITY FOR SAFETY

5 ENCOURAGE OUR EMPLOYEES TO INFORM THEIR SUPERVISOR

IMMEDIATELY WHEN UNSAFE CONDITIONS ARE PRESENT WITHOUT

FEAR OR REPRISAL

6 PROVIDE THE TRAINING TO SUPPORT THE ACCIDENT REDUCING

TECHNIQUES NECESSARY IN IMPLEMENTING OUR RESPONSIBILITIES

EVERY REASONABLE EFFORT WILL BE TAKEN TO ASSURE THAT THE EMPLOYEES

CAN ACCOMPLISH THE SAFE COMPLETION OF ASSIGNED TASKS NO TASK IS SO

IMPORTANT, OR SO URGENT, THAT WE CANNOT TAKE THE TIME TO DO IT SAFELY

DIRECTOR AND OWNER

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2.0 DRUG AND ALCOHOL ABUSE POLICY

The Company prohibits the use, possession, or distribution on its premises, facilities, or

work places any of the following: alcoholic beverages, intoxicants and narcotics, illegal

or unauthorized drugs (including marijuana), “look alike” (simulated) drugs, drug related

paraphernalia, inhalants, firearms and unauthorized explosives Company employees

must not report for work under the influence of any drug, alcoholic beverage,

intoxicant, or narcotic or other substance (including legally prescribed drugs or

medicines) which will in any way adversely affect their working ability, alertness,

coordination, response, or adversely affect the safety of others on the job

All applicants for employment and employees of Preferred Industrial Contractors, Inc

may, as a condition of employment or continued employment, be required to submit to

a drug and/or alcohol screening test at the discretion of the company, (allowing

random, post‐accident, and “for cause” testing)

Entry into, or presence on company premises, facility or work place by any person is

conditioned by the company’s right to search the person, personal effects, vehicles,

lockers and baggage of any employee or other entrant for any substance described in

the above paragraph By entering into or being present on Company premises, facility or

workplace, any person is deemed to have consented to such searches which may

include periodic and unannounced searches of anyone while on, entering or leaving

Company premises, facility or workplace The searches may include the use of electronic

detection devices, scent trained dogs, or the taking of blood, urine or salvia samples for

testing to determine the presence of substances named above

The taking of blood, urine, or salvia samples for testing may also be required from any

person on Company premises, facility, or workplace who is suspected of being under the

influence of drugs or alcohol, or who is involved in an accident or is injured in the course

of employment

This program is designed to notify, identify, and provide penalties for those employees

and applicants who by their possession, use, or sale of an illegal drug or alcohol, or who

is involved in an accident or is injured in the course of employment

Any person who refuses to submit to a search, screening or testing as described in this

policy or who is found using, possessing or distributing any of the substances described

above, or who is found under the influence of any such substances, is subject to

disciplinary action up to and including immediate discharge of an employee, voluntary

withdrawal of employment application, or removal from the premises, if not our

employee

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3.1 Purpose

3.0 SAFETY, HEALTH AND ENVIROMENTAL OBJECTIVE

A To eliminate injuries in order to achieve zero injury status for all our

employees To promote maximum efficiency, in order to affect savings by the reduction of business interruptions due to accidents To provide direction and coordination of a program which will be in compliance with established industry practices, OSHA, MSHA, state and owner safety and health standards

3.2 Methods of Obtaining Objective

A Plan all work, first at the project level, then, at the task level, to eliminate

personal injury, property damage and loss of productive time

procedures, unsafe practices and conditions

equipment and mechanical guards

maintenance

all levels of employment through:

1 Safety orientation and training

2 Investigation of all accidents and incidents to determine cause and to take necessary corrective action

3 Safety meetings and craft training held at regular intervals

4 Enforcement of safety requirements on all operations

5 Use of bulletins, posters and other similar materials to stress safety and provide relevant information

6 Solicit safety suggestions from employees

7 Adherence to the Company’s Drug and Alcohol Abuse Policy

8 Provide monetary incentive to all employees to achieve safety goals

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4.0 ORGANIZATION AND RESPONSIBILITIES

 Organizational Chart‐ Safety, Health &

A SAF 4‐1 Project Safety, Health and Environmental Pro ram checklist 24

g

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4.0 ORGANIZATION AND RESPONSIBILITIES

The Board of Directors of the Company, recognizes the importance of, and the need to

implement a Safety, Health and Environmental (SH&E) Program to protect people,

property and the environment in which we work

This manual outlines the requirements and responsibilities of the Board of Directors,

company management and field supervisors, staff and employees, regarding loss

control, accident prevention, promotion of safe and healthful work practices, pollution

prevention and control, hazardous waste management and prevention of occupational

injuries and illnesses

A Applicable client requirements, local, state, and federal and international codes,

law and regulations will be complied with in the performance of all Company

operations

B In the event that there is a conflict between the policies and procedures set forth in

this SH&E Manual and other mandatory codes, laws and regulations, the more

stringent standard will apply

C This SH&E Manual is intended to detail existing Company, safety protection and

practices and to assist in applying good judgment in exercising care and prudence at

all of the company locations

All levels of management within the company must share equally in the responsibility

of creating a safe and healthful working environment for our employees The

expectation is to operate in an incident free environment, where it is believed that the

employee’s opportunity to contribute to its success, will be fully realized

A Board of Directors

Fulfillment of the above mentioned expectation rely quite heavily upon how well

the Board of Directors accomplishes the following:

1 Pursue work with clients that have the same commitment to safety that the

Company has

2 Provide management with the tools to eliminate fatalities, disabling

occupational injuries, and illnesses and the means to reduce the risks of having accidents in order to protect human resources and to maintain accident rates at or below the company goals

3 Implement programs to reduce accident costs in order that the company’s EMR

(Experience Modifications Rate) is below 8

4 Implement programs to minimize equipment and property damage claims

5 Ensure that technical support in the disciplines of safety, industrial hygiene and

environmental regulatory compliance is available to all projects

6 Implement programs that will reduce environmental pollution incidents and

minimize the amount of damage from accidental releases of hazardous Substances

7 Promote safe and healthful work practices and effective training programs

8 Implement adequate protection programs that protect the public and others

who may be inadvertently exposed to company activities

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9 Project an image of the company’s commitment for safety on all projects

10 Shall be responsible for monitoring and positively influencing the Safety and

Health performance of all the company’s projects

11 Ensure that when performance is substandard and is not meeting the

established goals of the company that steps will be taken immediately to bring

the poor safety performance back into compliance Part of this process is to

conduct on‐site safety inspection

B Project Manager

The Project Manager has the ultimate responsibility for executing and maintaining

an effective program of employee protection, of safeguarding exposure to the

public and of protecting the environment as required by the company, client and

regulatory authorities

The Project Manager may delegate authority to expedite and facilitate any

application of the established SH&E Program As with the Board of Directors, it

must be recognized that strong support and active participation at the Project

Manager level are essential to preserve human resources, to minimize lost

production and costs due to accidents and environmental incidents and to achieve

maximum satisfaction of the clients and regulatory authorities Effective Jan 1,

2011, it will be mandatory the Project Manager and the Project Superintendent

demonstrate their knowledge of general construction safety practices This will be

accomplished by successfully completing the OSHA 10 Hour Construction Safety

Course, the Supervisory SH&E Training, the Incident/ Accident Investigation

Training, and the SAFE Training Program

The safety responsibilities of the Project Manager are as follows:

1 Since pre‐job is the most important aspect in establishing a safe environment

on the project it is the responsibility of the Project Manager to implement this program, he must evaluate job specifications and establishes controls for potential safety, health and environmental exposures and hazards

2 Responsible for ensuring that he/she is fully informed regarding the project

site, existing facilities and operations and any and all safety concerns prior to mobilization

3 Ensure that all of the project management staff is orientated pertaining to

safety concerns about the project prior to work being started

4 Ensures the preparation and implementation of, an effective project SH&E

Program to achieve compliance with applicable company, client and regulatory laws, regulations and standards

5 Directs the development and implementation of accident prevention, hazard

control and environmental protection procedures and practices including methods for employee training, objective enforcement of established rules and procedures and the safe handling, storage and disposal of hazardous materials

6 Ensure that the company Hazard Communication Program is being effectively

administered on the project

7 Responsible for ensuring that safety meetings are being conducted both with

the employees and subcontractors

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8 Direct and monitor all subcontractors ensuring that they are in compliance

with the Project SH&E Program

9 Ensure that the subcontractors report all accidents/ incidents to project

management

10 Responsible for ensuring that all safety and environmental issues are

addressed when bidding for new work

11 Personally promote and participate in the SH&E Program and audits of the

work operation to ensure compliance of lower tier supervision with established policies and mandatory requirements

C Project Superintendent

1 The Project Superintendent is directly responsible for providing site specific planning on every job prior to the start of work Every effort must be made to identify and avoid hazards, which could affect employee safety and health At a minimum, the following is a list of items to be addressed prior to the start of the project:

Medical Facilities Hazardous Materials Substance Abuse Testing Employee Exposure First Aid Emergency Procedures 100% Fall Protection Fire Prevention and Control Safety and Other Required Excavations

Posters Confined Space Entry Site Access/Egress Lockout/Tagout Requirements Project Site Orientation Assured Grounding/GFCI Incentive Program Scaffolding/Ladders Safety Responsibilities Electrical Requirements Personal Protective Equipment Crane Requirements Required Training Special Rigging/Lifts Supervisor Qualifications Welding/Cutting/Burning Operator Qualifications Fuel Storage Requirements Equipment Inspections Overtime and Night Work Accident Investigation Sanitation Requirements

2 Effective May 1, 2011, it will be mandatory for the Project Manager and the Project Superintendent demonstrate their knowledge of general construction safety practices This will be accomplished by successfully completing the OSHA 10 Hour Construction Safety Course, the

Supervisory SH&E Training, Incident/Accident Investigation Training and the SAFE Training Program

3 Inform staff and employees of their safety responsibilities, authority, and accountability

4 Enforce all applicable safety rules, regulations, procedures, and standards as set forth by OSHA, MSHA, the Company SHE&E Program and any specific rules and regulations established for certain projects

5 Advise project manager regarding safety on the job as requested or when an accident or incident occurs

6 Ensure that supervisors are conducting their pre‐task planning meetings and completing the documentation as required PIC Rev 12/12/11

3

7 Make daily safety inspections of project site to monitor conditions and

to implement an immediate corrective action for all observed or reported unsafe acts and unsafe conditions

8 Ensure that the project safety policy is understood by each subcontractor before they start work and require their active participation in SH&E Program

9 Conduct and document safety meetings and other required training

10 Monitor and evaluate the use and effectiveness of personal safety equipment and recommend improvements where possible

11 Ensure that subcontractors are in compliance with the Project SHE&E Program

12 Require all subcontractors to submit in writing all accident/incidents that occur during the performance of their work

D General Foremen/ Foremen

The General Foremen / Foreman are the deciding factor on an effective Project

SH&E Program The amount of effort they put into accident prevention determines

whether or not a good safety record is established A General Foreman/ Foreman

shall:

1 Set a good example by constantly promoting safety and ensuring that proper

safety requirements are enforced

2 Instruct employees in safe work practices and methods at the time of hire and

when the employee is given new work assignments Conduct pre‐task meetings

and complete the require documentation

3 Conduct and /or attend Safety Toolbox Meetings

4 Attend management Safety Meetings as required

5 Respond to employee safety concerns in a timely manner

6 Supervise non‐routine operations to ensure that adequate safety precautions

are taken

7 Know the hazards and proper handling of all hazardous materials in the

employee work area and ensure that each employee is properly trained and has

a thorough understanding of how to safely use the materials

8 Ensure that the employees have received the Hazard Communication Program

training

9 Ensure that employees are equipped with and use the proper protective

equipment and tools to perform the job

10 Ensure that equipment is well maintained and used properly

11 Monitor the project site continuously to assure that no unsafe practices or

conditions exist If such conditions or practices are found, it is the foreman’s

responsibility to eliminate, control or report them to the superintendent or

project manager

12 Ensure that first aid is administered to injured employees

13 Make a complete and thorough investigation of accidents and incidents to

determine the facts, take necessary corrective action and promptly report and

record the results of the investigation

14 Assist the superintendent in completing the required accident reports

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15 As foreman, you are ultimately responsible for the safety of your crew and work

area Workplace is company policy and the law, and must be part of your daily

schedule

E Employees

All employees must lean and comply with the Project SH&E Program, mandatory

safety and health rules and regulations to their work and to the general safety and

health of other works on the project

Specific Responsibilities include, but are not limited to:

1 Notifies his/her supervisor immediately when conditions, hazards or practices

may or do cause personal injury or illness or property damage

Learns and observes all rules and procedures related to pollution control and

environmental protection

2 Makes the maximum use of all required personal protective equipment and

follow the good health practices and procedures established to maintain his/her

health and safety

3 Reports safety and health hazards to his/her supervisor immediately

4 Develops and practices good habits of personal hygiene and housekeeping

5 Attend all required safety meetings

F Corporate Safety, Health and Environmental Director

The Safety, Health and Environmental Director(s) report to the CEO and the Board

of Directors

This individual manages the Corporate Safety, Health and Environmental

Department He directs the formulation and promulgation of policies, rules,

procedures and administers the Corporate SH&E protection programs as they apply

to employee protection, public safety, equipment and property protection,

occupational health and hazardous waste / materials

Primary Responsibilities include:

1 Supervises the SH&E Professionals assigned to the Department

2 Serves as a technical advisor to the Board of Directors and project management

3 Monitors operations and advises management relative to compliance

with applicable client and regulatory rules, regulations and/ or laws

4 Assists the Board of Directors in establishing annual Safety Performance goals in

promoting activities to help projects meet or improve upon these goals

5 Recruits, selects, hires, assigns, promotes, transfers and when and if necessary

terminates personnel in the SH&E Department

6 Provides technical support for and has administrative control over operating

unit SH&E Professionals

7 Conducts and supervises periodic safety, health and environmental evaluations

of project operations and advises project management with regard to technical

adequacy and compliance with mandatory rules and regulations

8 Directs and assists in the investigation of serious accidents and environmental

incidents Analyzes investigative data and assists in the development of

preventive measures to eliminate or control hazards and potential liability

9 Assists in the preparation of submittals for bid proposals

5

10 Collects, develops and disseminates material and information used in program

development to further safety, health and environmental protection training

11 Complies and distributes statistical reports on safety performance

12 Serves as the Company’s representative on technical committees and on

professional associations Advises management on proposed standards and

laws relating to Safety, Health and Environmental issues

13 Develops and implements industrial hygiene procedures that reflects both

technically sound and cost effective use of company resources

14 Develops specific occupational health and environmental protection plans

which are both cost effective and responsive to the company’s demands for

technical work

15 Monitors compliance with all legislative requirements relative to the federal,

state and local jurisdiction in which the company’s demands for technical work

16 Provides technical input regarding applicable regulations, manpower needs and

associated costs potentially incurred as a result of project execution

G Safety, Health and Environmental Co‐Director

Reports to the CEO and to the Board of Directors The following responsibilities are

shared or divided between the Safety Director and the Safety Co‐Director:

1 Applies appropriate policies, practices and standards to promote the company’s

SH&E Program and administers assigned functions to aid in this overall

responsibility

2 Administers and coordinates medical and emergency first aid services

3 Develop and implement SH&E training programs

4 Conducts SH&E inspections to eliminate and control occupational injuries and

illnesses

5 Investigates injuries, conditions and incidents that do or could involve actual or

potential liability and makes recommendations to eliminate future occurrences

6 Directs the preparation of records and reports relating to Safety, Health and

Environmental protection and property losses required by law and the

company

7 Maintain and distributes promotional materials to promote good safety and

health practices

8 Acts as the primary liaison with governmental agencies concerning Safety,

Health or Environmental issues

9 Represent the company at hearings or in court on matters involving accidents,

environmental incidents and / or regulatory inspections

10 Supervise Project SH&E Supervisors

11 Monitors all projects and advises project management relative to compliance

with applicable client and regulatory rules, regulations and/or laws

12 Recruits, selects, hires, assigns, promotes, transfers and when necessary

terminates safety personnel on the projects

13 Serves on technical committees and associated with various safety professional

15 Provide technical assistance as needed for SH&E protection and practices

including the safe handling, storage and disposal of hazardous waste

16 Applies accepted Industrial Hygiene procedures, techniques and work practices in a

manner, which reflects both technically sound and cost effective use of project

resources

17 Implement industrial hygiene programs for project specific occupational health and

environmental protection, which will be cost effective and responsive to the

demands of the project work

18 Procures and maintains all consumable health and environmental protection

supplies at a level sufficient to ensure no interruption of project operations

H Project Safety, Health and Environmental Supervisor

SH&E Professionals on project reports in a direct line to the Corporate Safety,

Health and Environmental Department and have a dotted line reporting

responsibility to the Project Superintendent The Project SH&E Supervisor’s

responsibilities are:

1 Applies appropriate policies, practices and standards to promote the Company’s

SH&E program

2 Administers and coordinates medical and emergency first aid services

3 Conducts Safety, Health and Environmental inspections to detect, eliminate and

control hazards, which could contribute to injuries, illnesses, and equipment/

property damage

4 Conducts inspections of equipment, structures and work in progress to assist

project management in compliance with Safety, Health and Environmental

standards of the company and regulatory agencies

5 Participants in safety planning and scheduling meetings

6 Investigates injuries, conditions and incidents that do or could involve actual or

potential liability and makes recommendations to eliminate future occurrences

7 Prepares and submits weekly reports to the Corporate SH&E Department on

project safety activities

8 Prepares or directs the preparation of records and reports relating to Safety,

Health and Environmental protection and property losses required by law and by

the company

9 Administers and coordinates the project security and fire protection programs

10 Maintains, distributes and posts promotional materials to promote good

safety and health practices

11 Assists in the planning and presentation of Safety, Health and Environmental

training materials for employees and supervisors

12 Monitor and assist subcontractors in the development and administration of

their SH&E Program

13 In order to instruct the OSHA 10 Hour Construction Safety course and MSHA 8

Hours Safety course, all Project SH&E Supervisors must successfully completed the

OSHA 500 course or the MSHA Instructor course

14 Maintains all consumable health and environmental protection supplies at a

level sufficient to ensure no interruption of project activities

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I Project Safety, Health and Environmental Representative

When projects do not warrant a full time Project SH&E Supervisor, the Project

Superintendent, with the assistance and agreement of the Corporate Safety, Health

and Environmental Director shall assign a member of the field management staff to

serve as the Project SH&E Representative This individual will report directly to the

Corporate SH&E Department Typically the Project SH&E Representative shall be

responsible for completing and maintaining records of all accidents and with

performing other Safety, Health and Environmental duties as assigned by the

Corporate Safety, Health and Environmental Director These responsibilities will

include:

1 Project Safety, Health and Environmental inspections

2 Equipment inspections prior to use of equipment and also periodic inspections

3 Injury, illness and incident investigations

4 Project liaison with insurance inspectors and regulatory agencies

The Project SH&E Representative must have successfully completed the OSHA 10 Hour Course

or MSHA 8 Hour Course and completed the requirements for a “competent person” in the

construction disciplines the project is involved with

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PREFERRED INDUSTRIAL CONTRACTORS, INC

COMPANY ORGANIZATION CHART

President CEO, Board of Directors

Safety QA/QC Director

Field Operations

Manager

Administrative Assistant Travel Manager

PREFERRED INDUSTRIAL CONTRACTORS, INC

PROJECT SAFETY ORGANIZATION

Safety QA/QC Director

QA/QC Manager Safety Manager

Project Superintendent

Project Safety Supervisor

Training/New Hire Orientation

Subcontractor Safety Representative

Incident Investigation Fire Prevention

First Aid/Medical Security

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PREFERRED INDUSTRIAL CONTRACTORS, INC

PROJECT SAFETY ORGANIZATION CHART

President CEO, Board of Directors Safety QA/QC Director

Project Manager

Field Operations Manager

Estimation Department

Project Superintendent

Foreman

General Foreman

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4.4 Subcontractor Management Plan

1 Subcontractors will be advised of the provisions of the Project SH&E Program,

client stipulations and of contractual obligations at a pre‐job safety meeting

The obligation of all subcontractors is to comply with the Project SH&E

Program, applicable statutory safety, health and environmental laws,

regulations and rules Subcontractors have the sole and complete obligation

to provide a safe and healthful working environment for their employees and

for other persons on the project site who may be exposed to their work

2 All subcontractors shall be pre-qualified by reviewing their safety

programs, safety training documents and safety statistics

3 Project management will request and review the subcontractor’s safety

performance such as recordable and lost workday incidence rates,

experience modification rate and past history of OSHA/MSHA citations

TRIR, EMR, DART and Fatality Rate will be used as criteria for selecting

subcontractors

4 Minimum requirements for subcontractors will be:

a Provide a written SH&E program which includes procedures covering

the work to be performed for review and approval by the Project Management

b Provide a written Hazard Communication Program for review and

approval by the Project Management

c All subcontractors shall be included in pre-job meetings or

kick-off meetings and safety orientations

d Designate in writing a qualified SH&E Representative acceptable to

Project Management and some cases by the client, tailgate safety meetings, JSA and site inspections

e Provide pre‐hire procedures to Project Management for review and

approval These procedures must include the orientation process and the following must be addressed during this process:

1 Personal protective equipment requirements

6 Security requirements

7 Housekeeping procedures

8 Equipment safety

9 Specific project requirements

f Conduct and document Safety Toolbox meetings

g Attend all required Project Safety Meetings

h Complete and promptly report accident and injury reports A copy of

each insurance company first report of injury (E‐1) shall be provided to the Project Superintendent who will forward to the Project Manager A monthly summary of occupational injuries and illnesses including man-hours shall also be submitted to Project Manager

i The subcontractor is responsible for investigating injuries/incidents

and filing a report, in writing to the Project Superintendent, identifying the cause(s) and what corrective actions have been taken to reduce the risk of a re-occurrence

j Inform all of their supervisory personnel of the Project SH&E Program

and their responsibility for providing a safe and healthful place to work for their employees

k Report all OSHA/MSHA/EPA or other State or Local inspections and

provide a copy of any inspection reports and citations to Project Management

l Maintain all equipment and tools in a safe condition

m Cooperate with Project Management, client and other contractors/

subcontractors in maintaining a safe and healthful workplace

5 The Preferred Industrial Contractor, Inc.’s Project Manager will monitor the

SH&E performance of the subcontractors Project Management will notify

the subcontractor of noncompliance of any established SH&E rules or

procedures A “Safety Violation Notice” Form (See Section 7), has been

developed to be used as a formal method for documenting and enforcing the

Project’s SH&E Program

6 If Project Management notifies any subcontractor of any noncompliance with

the provisions of the Project’s SH&E Program or other client or statutory

requirements the subcontractor shall take prompt action and make all

reasonable efforts to correct the unsafe or hazardous condition(s) or act(s)

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Satisfactory compliance shall be made within a reasonable, specified time If

a subcontractor refuses to correct unsafe or hazardous conditions or acts,

the Project Management will initiate appropriate actions in accordance with

the contract provisions and may take one or more of the following steps:

a Cease the operation or a portion thereof (particularly in the case of

e Continued substandard safety performance will be considered

a Breach of Contract and appropriate action will be taken up

to and including cancellation of the contract

f Project Manager shall conduct post-job safety performance review

4.5 Establishing the Project Safety, Health and Environmental Plan

A Plan Requirements

Prior to the commencement of work at a new project site, the Project

Manager shall take steps to implement an effective Project SH&E Plan The

Plan may be tailored to meet the needs of the project, but it must meet the

basic requirements established in this SH&E Manual The Plan must also in

accordance with any client, local state, and federal laws, regulations and

standards The basic requirements of the Project SH&E Plan and appropriate

reference sections of the Manual are listed below:

1 Project Specific Rules

2 Organization Structure and Responsibilities of Key Personnel

9 Safety Incentive Program

10 Emergency Action Plan

11 Fire Protection and Prevention

12 Accident/ Incident Investigations

13 Security

B Organizing the Project Safety, Health and Environmental Plan

The Project Manager shall contact the Corporate Safety, Health and

Environmental Director to determine if a full time SH&E Professional is

required on the project If it is determined that a SH&E Professional is

needed then the Director will recruit for a SH&E Professional or transfer

one to the project prior to the start of work If the project is of the type

or size that a full time SH&E Professional is not warranted, then the

Project Manager or Project Superintendent will submit in writing the

person they want to assume the position of Project SH&E Representative

with qualifications for approval by the Corporate Safety, Health and

Environmental Director If the Project Manager decides not to designate

a Project SH&E Representative then this responsibility will be assigned to

the Project Superintendent who then must submit his/her safety

qualifications to the Safety, Health and Environmental Director for

approval

NOTE: When a project operates on more than one shift, the responsibilities for

carrying out the SH&E Plan shall be delegated to an individual or individuals on the

second and third shifts

C Initial Priorities

1 Adequate safety, fire prevention, medical, security, occupational

health and environment protection measures shall be established as required by the company, client and mandatory regulations The Corporate SH&E Department will assist in the development and implementation of these measures

2 Arrangements shall be made for hospital, doctor, ambulance,

firefighting and police services The telephone numbers and/or other instructions for obtaining these services shall be posted at the telephones in key locations on the project

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3 Liaison must be made by project management with representatives of

the client, insurance carrier, regulatory authorities (if needed) and other

appropriate personnel to determine and coordinate such items as:

exposed to the work operations

b Client, local, state and/or federal laws and regulations that are applicable to the project

property damage and other emergencies

4 Initial investigation of the project site and review of the proposed work

must be made as soon as possible to determine, to the extent possible, existing or probable hazardous conditions

a Planning shall outline steps needed to prevent or eliminate such hazards

b Hazards, which cannot be eliminated, shall be controlled and properly marked as required with warning signs, barricades, etc Such dangers shall be pointed out to visitors and new employees if they will be exposed to these dangers

5 Utilize the Project Safety, Health and Environmental Check List

(Exhibit 4‐1) to plan for and establish an effective Project SH&E Plan

D Key Elements

1 Good advance planning and early establishment of the Project SH&E

procedures and responsibilities are critical to a successful program

Planning should include these basic elements:

a Safety planning and job hazard analysis

b SH&E indoctrination and training

c Project Safety and Health Rules and Emergency Procedures

d Reporting and record keeping requirements

e SH&E inspections, accident analysis and objective enforcement

of established procedures and applicable standards

f Procedures to ensure the active involvement of project supervision in the SH&E training, inspection and enforcement activities

2 Safety meetings for supervisory personnel shall be conducted a minimum

of once a week The importance of project management’s support and

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participation in these meetings is emphasized The Project Superintendent shall reside at the supervisor’s safety meetings and shall

be assisted by the Project SH&E Supervisor/Representative Minutes of these meetings shall be maintained and copy of the minutes shall be distributed to the participants These meetings will be presented in order to:

a Promulgate and review the SH&E procedures and policies applicable to the project

b Identify responsibilities of each of the project management

c Review noted and anticipated SH&E hazards and plan methods

to eliminate or control them

d Analyze accident experience and discuss accidents to determine causes and steps necessary to prevent reoccurrence

e Discuss suggestions and ideas for improving the Project’s SH&E Plan

3 The Project Safety Supervisor/Representative shall attend and take an

active part in scheduling and planning meetings to ensure for the proper planning on SH&E into the work sequence

4 Once a week a formal SH&E inspection of all active work areas shall be

conducted by the Project Superintendent and the SH&E Supervisor/Representative To be effective, such inspections shall occur

on all shifts, shall be unannounced and shall occur at varied intervals

a Imminent danger situations shall be corrected immediately

b Inadequate or deficient protective measures and unsafe or unhealthy work practices shall be brought to the immediate attention of the craft supervision for correction

c The Project Superintendent shall be informed of all deficiencies not immediately correctable and/or which may result in

damage to facilities, equipment or work in progress or which creates hazardous exposures to employees, other workers or the public

5 Appropriate mechanical safety inspections are a part of the equipment

preventive maintenance program and as such are the responsibility of the project supervisors

a Accurate and complete maintenance and repair records are an important part of the preventive maintenance program The

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Project SH&E Supervisor or Representative shall have access to these records and shall make periodic reviews to determine if the equipment is being maintained in a safe condition

b Pre‐Shift safety inspections shall be made by the operators of the equipment These inspections shall be documented on

“Operators Safety Check List” Form (see Section 7)

c Project management shall adhere to federal, client and Company stipulations for testing and inspections of equipment and vehicles

6 Signs and posters of appropriate size and design and bearing standard

pertinent regulations shall be used to convey warnings, directions and instructions to personnel and the public as required by the client and other applicable regulations The observance of such safety and accident prevention signs shall be strictly required of company employees and visitors while on the project

7 Mandatory Safety, Health and Environmental Guidelines (Exhibit 4‐4) and

Rules of Conduct (Exhibit 4‐3) will be posted on employee bulletin boards and in conspicuous locations in the project trailers, offices (if any) and other project facilities

8 It is important to plan for and provide adequate resources to the Project

SH&E Plan to ensure its effectiveness The Project SH&E Supervisor/Representative must be provided with adequate transportation, telephone and/or radio units, suitable desk space and storage facilities, date entry or computer resources, training aids, testing equipment and administrative support

9 Consideration must be given to make the Project Environmental

Protection Plan effective The type and extent of the measures needed for pollution control, hazardous materials handling, hazardous waste control and disposal and for relating occupational health issues will depend upon the contract stipulations, hazards involved, type of operation and mandatory requirements of regulatory authorities Such measures shall include appropriate control methods necessary to prevent and reduce the safe levels exposure to hazardous substances

E Implementation of The Project Safety, Health and Environmental Plan

1 The active involvement of the project management at all levels in SH&E

training, enforcement, inspection and incident investigation activities are necessary to maximize the effectiveness of the Plan

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2 Supervision SH&E Meetings

In order to make the Project Plan most effective, the Project Superintendent shall conduct a meeting at least once a week for all supervisory personnel It may be appropriate to combine this with other scheduling and/or planning meetings The supervisory personnel of subcontractors need to be included in the safety meetings

These meetings will be presented in order to:

a Review and implement SH&E protection procedures and policies Provide training for supervisors

b Review the work schedule for immediate and future operations Pre‐plan safe work methods and procedures and obtain necessary SH&E equipment and supplies

c Discuss accidents and environmental incidents occurring prior

to the meeting, pointing out the causes and how they could have been prevented

d Review the Project’s SH&E performance looking at trends, costs and effectiveness of any recommendations or

3 Work Area Inspections

Inspection of all work areas shall be made daily by the Project SH&E Supervisor or Representative Inadequate and deficient protection measures and unsafe work practices that are noted shall be brought to the attention of the appropriate supervisor for immediate correction

a Periodic inspections by the Project Superintendent, on a weekly basis, is required to visibly demonstrate top management’s concern and support for the Project’s SH&E Plan

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b The Project Superintendent shall be informed of all deficiencies that cannot be corrected immediately

c Inspection of all flammable storage areas shall be made at regular intervals

4 General Methods of Controlling Health Factors or Stresses

As soon as dangerous hazards or stresses are discovered, steps shall be taken to eliminate or control these hazards or stresses General methods

of control to take into consideration, include the following:

a Substitute a less harmful material for one, which is dangerous

to health

b Change or alternate the process to minimize work contact

c Isolate or enclose the process or work operation to reduce the number of persons exposed

d Utilize wet methods to reduce dust on the project

e Safely remove or disperse the contaminants at their source before they reach the workers

f Ventilate with clean air to provide a safe atmosphere

g Utilize personal protective devices

h Maintain good housekeeping This includes the cleanliness of the work area, waste disposal, adequate washing, toilet and eating facilities, sanitary drinking water and control of insects and rodents

i Whenever appropriate, utilize special control methods for specific hazards, such as reduction of exposure time, film badges, continuous or frequent sampling with monitoring device and medical programs to detect intake of toxic materials

j Medical controls should be used as necessary

k Maintain an adequate training and education program to supplement engineering controls

5 Environmental Protection Factors

a Specific methods for controlling environmental factors will vary considerably depending upon each individual situation or problem

b To determine the most feasible solution to pollution and hazardous materials management problems, the

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environmental factors and stresses must be first carefully measured and analyzed This often requires sophisticated equipment and the assistance of expert consultants and laboratory facilities For environmental problems requiring other than routine evaluation and control, contact the Corporate Safety, Health and Environmental Department

6 Protection of Archeological Sites

a All items having any apparent historical, paleontological or archaeological interest, which are discovered in the course of construction activities, shall be left undisturbed and shall be immediately reported to the client

b Any area or site that has been determined to be eligible for inclusion in the National Register of Historic Places in an environmentally restricted area These areas will be left undisturbed and employees and subcontractors shall be directed not to disturb or otherwise cause damage to them

Normally landscaping and restoration is the responsibility of the client/owner but, if this is not the case, the following needs to be considered:

a Wildlife habitat pond dikes where and when necessary will be constructed at specified locations before any material is placed in the drainage areas below these locations When a slope area has been developed to the specified grade, immediate permanent seeding of that area will be undertaken

Immediate permanent seeding will also be done one each disposal area segment that has been developed to the specified grades and approved

b If areas outside the limits of construction are disturbed by our operations, the area will also be restored Restoration of any such areas will be accomplished by grading to provide a well‐

drained slope and shaped to blend into the adjacent undisturbed areas An adequate growth media will be provided, if necessary, and suitable re‐vegetation established

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following procedures comparable to those used for permanent seeding

c All temporary construction facilities such as haul roads, work areas, parking lots, structures, foundations of temporary structures shall be obliterated and the area appropriately landscaped to reflect the surrounding terrain and drainage requirements, covered with a growth medium as necessary and permanently seeded with appropriate grass

4.6 Exhibit(s)

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EXHIBIT 4-1 PROJECT SAFETY, HEALTH AND ENVIRONMENTAL

PROGRAM CHECKLIST

This checklist may vary for different project operations and may not include all items required

for your project However, it does contain the essential elements for establishing an effective

Safety, Health and Environmental and Loss Prevention Program

1 Contact the Corporate Safety,

Health and Environmental

Dept for planning of safety,

medical and environmental

programs

2 Contact the Corporate Human

Resource Department for the

Substance abuse prevention

Program

3 Obtain the Safety, Health and

Environmental Manuals and

The Federal Regulations from

The Corporate Safety, Health

And Environmental Dept

4 Order safety forms from the

Corporate Safety, Health and

Environmental Director for a

Project Safety Supervisor/

Representative

5 Contact the Corporate Safety,

Health and Environmental

Director for a Project Safety

Supervisor/Representative

6 Order first aid kits and supplies

7 Assign trailer/office space to

Safety personnel including desk,

File cabinet and clerical assistance

8 Obtain and assign radio and Telephone

to safety personnel

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TASK ASSIGNED TO DATE COMPLETED

9 Order prescribed personal

Protective equipment, i.e

Hard hats, eye and hearing

Protection, respirators, etc

10 Plan and establish safety

Indoctrination and weekly

Safety training program

11 Order “Employee Safety and

Health Handbook from the

Corporate Safety, Health

And Environmental Dept

12 Establish schedule for

Monthly supervisor’s safety

Meeting

13 Evaluate Project for hazards Or

special requirements and

Develop specific Safety, Health

And Environmental rules and

Procedures

14 Plan and develop procedures

For administering safety programs

For subcontractors including

Preconstruction safety meeting

15 Determine requirements and

Conduct pre-work inspection

For performance and load tests

Of cranes, hoists, etc and similar

Equipment Complete required

Documentation

16 Plan project inspection

Program, frequency of inspection,

Documentation requirements and

Type of inspection should be

TASK ASSIGNED TO DATE COMPLETED

18 Determine record keeping

Reporting requirements of

Regulatory authorities (OSHA,

MSHA, etc.), client, and company

Safety

19 Evaluate the need for an EPA

Storm Water Pollution Plan

And NPDES Storm Water Permit

For construction activities

20 Evaluate security requirements

Such as guards, perimeter fencing,

And lighting

21 Evaluate the need for occupational

Monitoring, i.e noise, water, air

And dust surveys and gas monitoring

Contact the Corporate Safety Health

And Environmental Dept for

assistance

22 Determine and establish safety

Enforcement and disciplinary

Sanctions for Safety, Health and

Environmental Violations Ensure

All employees have been advised

23 Plan and establish emergency

Action plan for medical emergencies,

Fire, flooding, bomb threats, civil

Disturbances, hazard material/

Waste, spills, releases of pollutants

Or toxic gases, etc

24 Determine requirements to Control

and prevent unsafe Conditions, i.e

scaffolding, Standard guardrails,

guards, Accessways, ladders,

lock-out/ Tagout procedures, confined

space

Entry, etc

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TASK ASSIGNED TO DATE COMPLETED

25 Develop fire prevention

Plan and determine fire

Extinguisher and fire

Protection requirements

Order and install equipment

26 Post safety instruction signs,

Posters, and other promotional

Materials/ ideas

27 Implement accident and

Environmental incident

28 Make contacts and establish

Working relationship with local

Medical personnel and facilities,

Local ambulance service, fire

Station and applicable client

Personnel

29 Establish methods to monitor And

document progress of safety

Performance and communicate to

All project personnel

30 Implement company Hazard

Communication Program to

Train employees and to monitor

Health hazards

31 Order and prescribe appropriate

Equipment and media for response

To accidental spills or release of

Hazardous materials

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